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pscleanair.org
Puget
Sound
tbit
Ajr
Agency
Warking
togefjaer
for
dean
air
April 7,2009
Sarah
Flagg
Port of Seattle
YO
Box
1209
Seattle,
WA
981
1 1
Dear Ms. Flagg:
Port Truck Removal Program
EXECUTIVE DIRECTOR
Usn~~s
?
Mct
errall
BOARD OF DIRECTORS
BREMERTON
Cory
Borcman.
MV(BYC~I,
EVERETT
Kay Stept~ar!s<:n.
Mayor
KING
COUNTY
F<on
!;:;?IS,
&~c?ctit~vt.
KITSAP COUNTY
Steve Bsuer Co~nn?i.$srorrc.t
PIERCE COUNTY
Pa1
hll:Cclrthy
F
XCCIJ~IVB
PUBLIC AT LARGE
Mar~na
!:ofel
VJi:(!s~r;,th
SEATTLE
Grego~y
J
Niike:s.
b.4ayor
SNOHOMISH COUNTY
Mtke
Cooper
Coc,c.c
lina'i
TACOMA
Jake
Fey
Courii:!:n~an
The
purpose
of
this
letter is to propose
a
design for
a
port
truck
removal
(buy
-
back and smppage) program to support the
Port
of
Seattle's commitment to the Northwest
Ports
Clean Air Strategy.
The
Nortlzwest Ports Clean Air Strategy,
which
was adopted by the
Port
of
Seattle Commission
in
January
2008,
contains tmck en~ission
reduction perfbrmance measures. By 20
10,
the strategy requires port
trucks
to reach
the
equivalent particulate matter
(YM)
etnissio~ls
level of the
1994
or newer heavy
-
duty tr~~ck engiile model year
through vehicle purchase or by using approved retrofit packages. By
2015,
80%
of heavy
-
duty drayage trucks
are
expected to reach the
equivalent
PM emissions level
of
2007
or
newer engine
model
year
through
vehicle
pilrchase or
by
using
approved
retrofit
packages.
This
is
an
interim objective on the way
to
the
goal of
100%
of
heavy
-
duty drayagc trucks meeting 2007 model
-
year levels by 2017.
011
March
31,
2009, Port of Seattle staff proposed to the
Coiwnissioiz and the public,
a
port
truck plan with
four
elements:
*
Terminal operators will enforce
at
gates
-
trucks that enter
terminals
must
be
1994
or newer stat-ting January
1,
201
1
(may
exempt occasional visitors).
Port
to
fund
removal progm for older trucks
-
$1.5
million
in 2009 (unbudgeted).
Continued support for Cascade Sierra Solutions
7
project to
replace older trucks
wlnewer retrofitted trucks.
Continue small business assistance program for owner/
operators.
We
recomineizd that tlze second element
of
this plan, the removal
program for older trucks, meet
the
following design parameters
in
order to achieve
the
201
0
performance measure:
Sarah Flagg
Port of Seattle
April 7,2009
Page Two
Provide a reasonable incentive for participation in
the
program.
We have determined, based upon the retail value of trucks older than 1994, a reasonable
incentive is the greater of $5,000 or the fair market value. The commercial truck
"
blue
book
"
does not provide values for trucks older than the 1992 model year. For the 1992
model year, the range of values, based upon condition, is from $2,900 (rough condition
wholesale) to $8,325 (average retail). The average wholesale value is $5,375. We are
unable to predict with accuracy the number of owners who will choose to scrap their
trucks. Based upon multiple surveys by Port of Seattle staff, the number of eligible
vehcles is approximately 300. We recommend that the Port of Seattle budget
approximately $1.5 million, as discussed at the March
3
1, 2009 Commission meeting.
Ths amount would fimd the buy
-
back of the majority of
trucks
in the pre
-
1994 model
years.
We suggest providing a process for resolving disagreements over the buy
-
back amount,
e.g., when
an
owner believes a truck is worth more
than
"
blue book
"
. The process would
require the applicant to provide values for similarly equipped trucks of the same model
year with appropriate references.
Ensure participants are actively operating at Port of Seattle terminals.
A
document summarizing the truck's port drayage activity during the past year
and
the
past 30 days would provide the information necessary to verify operation at the Port of
Seattle.
A
requirement to provide this information should eliminate participants that are
not regular customers or have recently ceased operations because of the
downtur~l i11 the
economy. The information should be available
fkom the truck owners' records, beneficial
cargo owners, terminal operators, or third
-
party logistics companies.
Include both ownerfoperators and truck companies.
According to the Port's surveys, ownerfoperators and company
-
operated trucks are
approximately evenly split in the fleet. To be equitable and successful, the truck buy
-
back program should be available to both individuals and companies.
Align with options for truck replacements and retrofits.
As trucks are removed Born the road through the buy
-
back program, an opportunity
exists to provide a cleaner, retrofitted replacement truck to the owner or company. We
recommend the integration of the buy
-
back program
with
our partnership with Cascade
Sierra Solutions to provide more efficient, cleaner late
-
model trucks as replacements.
Transition to the
2015f2017
performance measure.
Removal of pre
-
1994 trucks from the road and replacement of those trucks with later-
model, clean trucks sets the stage for achievement of the 2015/2017 performance
measure.
Sarah
Flagg
Port
of
Seattle
April
7,
2009
Page
Three
As
Cyascade
Sierra
Solutions
and
our Agency
gain
experience
with
truck
replacement,
and
affordable
2007
-
compliant
trucks become
available
on
ttlc
used
market,
we
will
be
prcpax-ed
for
the
next
phase
of
the
truck
component
of
the Nortl~west Ports (:lean
Air
Strategy.
The Puget
Sound
Clean Air Agency
is
a
strong
advocate for clean port
trucks
and
the
Northwest Ports Clean Air Strategy.
We
are
prepared
to
manage
a tnrck buy
-
back
and
replacement program
on
behalf of
the
Port of
Scattlc
to
ineel the
port
truck
performance
standards.
Please let either
Paul
Carr
or me
know
if
you have any questions
or
concerns about
these
recc~mmes~datio~is.
David
S.
Kircher,
Manager,
Air
Resources
Department
cc:
Paal
Can
Arny
Fowler
