March
3
1,2009
Comn~ission President Bryant
Commissioner Creighton
Commissioner Davis
Commissioner Hara
Commissioner
Tarleton
Port of Seattle
27
1
1
Alaskan Way
Seattle, WA 98 12 1
Dear Port of Seattle Commissioners:
We are concerned that the Commission may soon vote on a clean air strategy that is not
an effective use of time and taxpayer dollars. We are concerned about the future of some
400 truck drivers with pre
-
1994 trucks, and we are concerned that this plan will not
reduce dangerous diesel pollution in our communities in a sustainable manner. Under the
staff's current plan, motor carriers and shippers like Wal
-
mart will avoid any
responsibility for the impacts of their business operations on our communities.
We do not believe the Commission has enough details about the staff's truck plan to take
a vote committing funds or authorizing action. Furthermore, the Commission is not being
given a range of alternatives to consider. We do, however, encourage the Port of Seattle
to move forward, when this information is fully provided, to thoughtfully address
dangerous diesel pollution emitted by the 1,800 trucks moving millions of containers
through our communities.
We believe we share with the Port several goals for the trucks air pollution reduction
program
-
goals that are critical for the sake of our local community health as well as that
of the wildlife in the Puget Sound basin. They are:
Meeting the NW Ports Clean Air Strategy 20 10 deadline;
Maximizing:
o
the viability of this program through a sustainable business model
o
making regional air pollution gains by upgrading and maintaining port
trucks
o
meeting global air quality goals by scrapping polluting trucks
Ensuring that environmental benefits are for everyone equally and fairly and do
not unfairly burden any one group of people.
We believe the port's current plan will not meet these goals because the proposed
scrapping and replacement plan is not based on a realistic business model. We understand
that Port staff will recommend a program to ban pre
-
1994 trucks, offer payments to
drivers to scrap pre
-
1994 trucks, and that this will be followed up with development of a
loan or lease program for drivers to obtain cleaner trucks. Other ports have tried, and
failed, to retrofit and upgrade truck fleets through lease and loan programs with
individual drivers.' Under even the best economic conditions, individual drivers are
unable to bear the costs of leasing and maintaining replacement trucks. Although these
drivers are classified as
"
independent contractors,
"
trucking company workers lack the
negotiating rights to pass the costs of clean trucks on to the
trucking companies, the
shippers, or the
buyers.* The proposed plan will force drivers to choose between taking
on substantial additional debt and losing their jobs.
In
the end, this plan may encourage
drivers to simply take their polluting vehicles into other Northwest port communities
such as Everett, Tacoma, and Portland.
The Port of Seattle Commission needs to have all of the information before it votes
to authorize funds or action.
Before committing funds or authorizing action, we urge the Port of Seattle Commission
to direct port staff to:
1)
Present a range of genuine alternatives:
Port staff are offering the Commission
only one plan to accept or reject instead of offering a range of possible models to
meet the clean air goals.
2)
Conduct an independent analysis of the impacts of the top truck plan
alternatives:
Like the Ports of Los Angeles, Long Beach and Oakland, the Port of
Seattle should commission an independent analysis of the environmental, community
and economic impacts of alternative clean truck plans before committing further
public and private resources. With more than 18 months before the December 2010
deadline, we believe there is enough time to conduct a thorough and thoughtful
analysis of a range of alternatives.
3) Fully analyze and present the plans details:
Before authorizing action or funds,
Port Commission should require staff to fully document exactly how the plan to meet
the 20 10 standards will address these important components:
Scrapping: Ensure that scrapped trucks are truly removed and do not appear in
other markets or communities.
Registry: Demonstrate how a truck registry or licensing system will work and will
enable efficient
tracking and enforcement of the truck ban at the terminal gates.
Enforcement: Ensure terminal operators will enforce and document the truck ban
at the gates in a fair and consistent manner, and allow for adaptive management in
the face of new requirements. Port staff must provide adequate public review of
'
Approximately
35
individual drivers have enrolled in a similar program at the Port of Long Beach to
date, and less than a dozen signed up for the Virginia Port Authority's retrofit program.
2
Trucking companies, in comparison, are much better qualified to manage and maintain retrofit trucks.
Trucking companies have better access to credit, can pass costs on to shippers and buyers, are able to
reallocate resources, and are better able to manage risk and fluctuating cargo volumes. Trucking
companies will ultimately be more responsive to the maintenance requirements of retrofit engines and are
less likely to default or violate the terms of a retrofit truck lease or contract.
the specific terms of the implementing agreements between the Port and its
terminal operators.
Incentives:
Incentivize drivers to scrap their pre
-
1994 trucks by ensuring that they
have a real opportunity to stay in the market and prosper. A one
-
time cash
payment of $5,000 is far below the amount needed to obtain a clean replacement
vehicle and the Port Staff has not demonstrated that $5000 is an amount
that will
actually work to accomplish the goal of their proposed program.
Loans:
Establish fair lease and loan terms for retrofit trucks, whether provided by
Cascade Sierra Solutions or other entities and require
trucking companies to enter
into those leases.
Safety:
Ensure that safety maintenance costs, as well as parking, are paid for by
trucking companies. How will the Port or PSCAA make sure that the trucking
companies will provide an adequate level of safety and emissions maintenance
--
costs that are out of economic reach for most drivers but are essential to
protecting our communities?
Sustainability:
Build towards a sustainable program that will work for the 2015
goals without requiring another infusion of taxpayer funds or job losses at that
time.
Before the port commission votes to authorize funds or action on this issue the staff
should fully provide all of the details and alternatives for your consideration. We look
forward to working with you to implement a sustainable, effective and fair clean trucks
program at the Port of Seattle.
Sincerely,
David West, Executive Director
Center for a Changing Workforce
Heather Weiner, Director
Coalition for Clean and Safe Ports
Joyce Tseng, Board of Directors
Community Coalition for
Environmental Justice
Arsalan Bukhari, Executive Director
Council on American
-
Islamic
Relations Washington Chapter
Phil Mitchell
Greater Seattle Climate Dialogues
S haryne S hiu Thornton, Executive
Director
International District Housing
Alliance
Dale Cannon, Business Manager
Laborers Local
242
Steve Marquardt, Research Director
Laborers NW Regional Organizing
Coalition
Ricardo Ortega, Organizer
LELO: A Legacy of Equality,
Leadership
&
Organizing
David Freiboth,
Executive Secretary
-
Treasurer
ML King County Labor Council
Dorry Elias
-
Garcia, Executive Director
Minority Executive Directors
Coalition
John Littel, Political Director
Pacific Northwest Regional Council of
Carpenters
Heather Trim, Urban Bays and Toxics
Program Manager
People For Puget Sound
Howard Greenwich, Research Director
Puget Sound Sage
Vince O'Halloran, President
Puget Sound Ports Council
Maritime Trades Department
AFL-
CIO
Lee Newgent, Executive Secretary
Seattle Building and Construction
Trades Council
Brady Montz, Seattle Chair
Sierra Club
Sergio Salinas, President
SEIU Local
6
Diane Zahn, Secretary
-
Treasurer
UFCW Local
21
Rick Sawyer, Secretary
-
Treasurer
UNITE HERE Local
8
J. Allen Hobart, President
Teamsters Joint Council
28
Chuck Eggert, Secretary
-
Treasurer
Teamsters Local
231
Tracey Thompson, Secretary
-
Treasurer
Teamsters Local
117
Justin (Buck) Holliday, Secretary-
Treasurer
Teamsters Local
690
Rick Hicks, Secretary
-
Treasurer
Teamsters Local
174
Steve Chandler, Secretary
-
Treasurer
Teamsters Local
38
Ken Troup, Secretary
-
Treasurer
Teamsters Local
589
John Ernrick, Secretary
-
Treasurer
Teamsters Local
313
Sally Kinney
Temple Beth Am
John R. Jones, Jr., President
Washington ACORN
Maru Mora Villalpando, Lead Organizer
Washington Community Action
Network
