Exhibit B
" 6" Exhibit Port Commission QgLLiGI August 24, 2009 Meeting of Bill Bryant '- President Port of Seattle Board of Harbor Commissioners 2711 Alaskan Way Seattle, WA 98126 Dear Commission President Bryant: On behalf of the undersigned national trade associations representing importers, exporters, and the logistics industries and service providers that support them, we are writing you in support of the Clean Truck Plan included in the Northwest Ports Clean Air Strategy. We believe this program will improve harbor truck related emissions while sustaining and promoting the competitive position of marine terminals in the region. Other ports around the country are supporting ancillary policies attached to similar clean truck programs that are designed to dramatically restructure the harbor drayage market without any real benet to clean air. We support the Port of Seattle program in its current form and urge the Commission not to endorse policies designed to restructure the drayage market under the guise of clean air initiatives. By way of background, the members of the undersigned trade associations move a significant amount of international cargo through Pacic Northwest ports as well as blue water ports around the country. This cargo supports the many port, transportation, logistics, and warehousing jobs in the region. Much of this cargo transits marine terminals by way of harbor trucks. We have a direct interest to ensure that this truck- borne freight moves efciently, safely, and in an environmentally responsible manner. To that end, we support the elements of the Clean Truck Plan that are designed to reduce harbor truck emissions. These elements, including a rolling ban on the age of the truck, will have an enormous benefit to overall reduction of truck emissions. A similar program that has been in place in marine terminals in Southern California has already converted over 30% of the trucking eet to 2007 US EPA emissions compliant equipment since the program was implemented. That number is expected to reach 50% by the end of the year and will greatly contribute to air quality improvements. We would like to emphasize again widespread support for this rolling ban based truck replacement concept on the part of cargo owners moving freight through Pacific Northwest gateways. We believe the Port of Seattle has taken the right approach by focusing on the truck itself and not on who drives the truck. We are particularly concerned with efforts to amend existing federal law to give port authorities and other localities an exemption from federal preemption over rates, routes and service codied in the Federal Aviation Administration Authorization Act (F4A). Already, the ports of Los Angeles, Oakland and the Port Authority of New York- New Jersey (PANYNJ) support this change in federal law to grant them the ability to regulate port trucking. In our opinion, this attempt by other ports to rewrite longstanding federal trucking laws is designed not to address emissions reductions, safety or security as they claim, but to fundamentally restructure the harbor drayage industry to drive out of business the many hard working independent truckers moving international freight. Current federal laws already allow port authorities to move forward with clean truck programs such as those included in the Northwest Ports Clean Air Strategy. As already noted, the ports of Los Angeles and Long Beach already maintain the legal authority under federal law to ban and replace aging dirty trucks. Other federal laws regarding port security and motor carrier safety are in place to address these issues. The effort to amend the F4A will do nothing to achieve clean air goals while fundamentally and unfairly restructuring the drayage market and increasing costs and supply chain disruptions for the Port of Seattle's many customers. We urge you to oppose efforts to amend the F4A. We stand ready to work with you to implement a Clean Truck Program that truly supports clean air goals and urge the Port not to endorse a change in federal law that will ultimately harm the many truckers that serve Pacic Northwest marine terminals, the customers of those terminals and the competitive position that your port enjoys today. Sincerely, Agriculture Transportation Coalition American Apparel and Footwear Association American Import Shippers Association American Trucking Association Coalition of New England Companies for Trade Consumer Electronics Association Fashion Accessories Shippers Association Footwear Distributors and Retailers of America Harbor Truckers Sustainable Future LA/LB International Warehouse Logistics Association NASSTRAC, Inc. National Association of Waterfront Employers National Home Furnishings Association National Industrial Transportation League National Pork Producers Council National Retail Federation The Health & Personal Care Logistics Conference, Inc. The Waterfront Coalition Pacic Coast Council of Customs Brokers & Freight Forwarders Assns Inc. Pacific Northwest Asia Shippers Association Retail Industry Leaders Association Travel Goods Association US. Association of Importers of Textiles and Apparel United States Council for International Business Washington State Potato Commission West State Alliance Western Home Furnishings Association World Shipping Council PACIFIC COAST COUNCIL OF CUSTOMS BROKERS & FREIGHT FORWARDERS ASSN., INC. 9 Customs Brokers & International Freight Forwarders Assn. of Washington State 6 Columbia River Customs Brokers and Fomrarders Assn. 0 Custom Brokers & Fonlvarders Assn. of Northern California 0 Los Angeles Customs & Freight Brokers Assn 6 San Diego District Customs Brokers Assn. August 21, 2009 Dear Port of Seattle Commissioners, We are an association of small businesses on the Pacific Coast, serving all major port areas; our livelihoods and those of our employees are dependant on the ow of commerce through the Pacific Coast ports, including the Port of Seattle. It is in our interest that all the Ports remain viable and competitive. Therefore, we applaud your efforts to implement a Clean Truck program without new fees. In the same vein, we are hopeful that you will reject proposals to restrict who can own and drive those clean trucks. Despite all the other stated objectives, such proposals would dramatically increase the cost of shipping through the Port of Seattle. We cannot standby and watch, because the maritime business you impact is our business too. The 5 member associations of the Pacific Coast Council of Customs Brokers and Freight Forwarders, including the Customs Brokers & International Freight Fonivarders Association of Washington State facilitate most imports and exports through the west coast. We know that these importers and exporters are continuously seeking the most efficient, cost effective port through which to route their cargo. We also know very well that they have the choice of many ports here on the West Coast, as well as elsewhere. We are working to keep the business here, and are alarmed at any proposals which would do precisely the opposite. Our own companies are based here on the West Coast and in Puget Sound, as are our families and employees. If the Pacific Coast ports remain competitive, our businesses can prosper. As you consider port and freight policies, we invite you to call upon our expertise because we have a mutual interest in the success of the Port of Seattle. Thus far, since the Port's Clean Truck program has focused exclusively on reducing emissions of trucks serving the Ports, it has our whole-hearted support. The so-called FAAAA amendment goes far beyond 'clean trucks.' it is being advocated by those who seek to prohibit individuals from owning the trucks they drive onto the port terminals. Such limitations on truck drivers/owners will significantly increase cost of drayage to and from any port that adopts such a program, without making the air any cleaner. We ask the Port of Seattle to reject any such proposal. Pacific Coast Council ofCustoms Brokers & Freight Forwarders Page 2 Pacic Coast Council of Customs Brokers & Freight Forwarders August 21, 2009 We are also concerned about the impact on small business. The proposal before you would allow ports to limit the number of trucking firms that we, the customs broker or freight fon/varder will be able to deal with. If such a plan were to be adopted, it will particularly injure smaller shippers that do not have enough volume to command reasonable pricing. It has been our experience that many of the large trucking companies now focus their efforts and best pricing on their larger customers. When there are two containers with the same urgency, we see that the larger customer gets his container rst. Small and medium importers and exporters rely on the smaller trucking rms to hustle for them and to help move their cargo timely. Many of our customers are small companies that would find themselves lost among all the customers of those few large trucking companies. Small business will be stuck for delays and demurrage when their containers are bypassed because a large customer demanded that their freight moves first. These additional costs will force small shippers in particular to find other ports were truck drayage remains competitive, in service and price. Again, we applaud the Port of Seattle's approach to environmental responsibility and commercial viability. We are thus hopeful that you will reject any efforts to change current law designed to restrict truck ownership and drivers; this is not the time to render a west coast port non-competitive. Sincerely, Anne-Marie Bush President, Customs Brokers & lnt'l Freight Fon/varders Assn. of Washington State Jayson Gispan President, Customs Brokers & Forwarders Assn. of Northern California Terri Bartle President, Columbia River Customs Brokers and Fon/varders Assn. Dan Meylor President, Los Angeles Customs Brokers & Freight Fon/varders Assn. Gerardo Chavez President, San Diego District Customs Brokers Assn. Jack Hubbard President, Pacific Coast Council of Customs Brokers & Freight Forwarders Assn. Inc. Pacific Coast Council ofCustoms Brokers & Freight Forwarders AgTC Agriculture Transportation Coalition 1120 G Street, NW. Suite 1020 Washington, DC. 20005 Tel: 202-783-3333 Fax: 202-783-4422 www.AgTrans.org Info@AgTrans.org AgTC Board of Advisors Terri Battle Aug ust 18. 2009 TLR Total Logistics Resource, Inc. Emit: Beauregard Port of Seattle Commission Recfco Logistics PO Box 68727 Perry Boumc Seattle. WA 98168 Tyson Fresh Meat Sheila Bmcken Ailenbcrg Cotton Dear Port of Seattle Commission. Liz Chandler ECOM USA lnc. The Agriculture Transportation Coalition has been named Robert Co lcman by the Journal of Commerce as the Allpons Fonivarding Inc. "voice of agriculture exporters in U.S. transportation policy." As such, we continuously strive for Mike Hampel a transportation environment which keeps U.S. agriculture competitive in the global marketplace. Smithcld Foods Inc With this objective In mind, the AgTC has been impressed Matt Han-is by the Port of Seattle's approach to Washington State Potato maintaining and improving the environment, your "Clean Truck" program in particular. We Commission understand that you will be considering the Port's clean air strategy next Tuesday. Anna Fioravanti Kendig E.i. Dupont dc Ncmours Your port recognizes the fragile and highly competitive Richard Kinney nature of global commerce and Florida Citrus Packers agriculture, and we applaud your outreach to the ag exporters. Agriculture exports, so important John Ki'cick to the country and Washington State, simply cannot sustain additional costs which the foreign Pandol Brothers Inc purchasers will not accept and which U.S. growers, packers, producers Don Lake cannot absorb. Thus. we Dunavant Cotton appreciate that the Port has implemented its Clean Truck program without fees. Emily Lauzon Davisco Foods in the same vein, we hope that the Port will Donna Lcmm recognize that manipulation of trucking regulations in order to mandate the type of individual allowed to drive Mallory Group a drayage truck on and off Port premises, Lori McGinty as has been attempted by the Port of Los Angeles, has nothing to do with protecting the DLF International Seeds environment. However, such manipulation would lead to a dramatic increase in the cost of Duncan McGrath drayage trucking. It is estimated that the cost of drayage, in terms of higher Cargili lnc. charges and reduced Chris Mullally scheduling exibility, would triple. if, for example, a dray into a terminal currently costs $150, the Southwest Hide Co. type of trucking regulation manipulation envisioned by the Port of Los Angeles would increase Sabine Przysucha that cost to, in aggregate. about $450. For all practical Caldak lntemational purposes, this would be a new $300 per container fee. Patti Rccdcr G3 Enterprises/ E & J Gallo Winery Our West Coast ports are looking to a future in which the expanded Panama Canal will facilitate Tammy Rossi more direct service to Gulf and East Coast ports Blue Diamond Growers (many of which are in right-to-work states); John Slinkard Prince Rupert offers an alternative for Midwest shippers. Thus, adopting or endorsing any Sun-Maid Growers of measure (such as the so-called FAAAA amendment) that would dramatically increase the cost California of shipping through West Coast ports would constitute Tom Subcr the proverbial "shooting oneself in the foot." U.S. Dairy Export Council Hayden Swofford Pacic Northwest Asia Again. the AgTC has found the Port of Seattle's approach to environmental Shippers Association initiatives to be responsible and sensitive to the needs of U.S. agriculture, both exporters and Joltn Szczepanski importers. We National Hay Association encourage you to maintain this approach and avoid adopting or endorsing any efforts to Howard Tauge manipulate the identity of the truck drivers. .l.R. Simplot Co. Sincerely, 5% Peter Friedmann Executive Director Agriculture Transportation Coalition AgriCulture Transportation Coalition: U.S. Food, Farm & Fiber Shippers August 24, 2009 Hon. Bill Bryant President Port of Seattle Commission 271 1 Alaskan Way Seattle, WA 98126 Dear Commission President Bryant: I am writing on behalf of the members of Pacic Merchant Shipping Association (PMSA) -- a regional trade association representing ocean carriers and marine terminal operators to express my strong support for the NW Ports Clean Air Strategy. It is a strategy formed within the existing regulatory framework, based on sound data, strong partnerships, and one that is achieving results in a measurable way. Our membership will continue to work with the Port of Seattle to achieve the emissions reductions we all want. PMSA members represent the broad spectrum of companies that conduct business at the Port of Seattle ranging from container ship operators, cruise ships, tug and barge companies, fuel providers and marine terminal operators. We have been early supporters, both nancially, and through staff involvement, in the formation of the Maritime Air Forum and the subsequent Marine Air Emissions Inventory. The Inventory is the baseline from which we can measure progress and is based on data gathered from ocean going vessels, harbor vessels, marine terminals, trucks and trains. It was also the rst inventory of its kind to include greenhouse gas emissions. We support the recent moves by the Port to implement the ABC Program AtBerth Clean Fuels. So far 37 ships from six container lines and one cruise line are participating in this voluntary program. Those ships have made 91 calls at the Port of Seattle since January and represent about 35 percent of the vessels that make frequent calls at the Port. Sulfur dioxide emissions from those vessels have declined by more than 20 tons. This success adds to the clean air improvements at your marine terminals through cleaner fuel use, retrots and upgrades to cargo handling equipment. There is still much to do, but your collaborative partnership with industry, non-govemmental organizations and government regulators has allowed us all to move forward -- even in these tough economic times. We also worked together to push approval by Congress ofIMO Annex VI which has resulted in new international standards that will benet us all. As part of this effOIt, an Emissions Control Area (ECA) has been introduced for North America and there is every indication that it will be adopted. This ECA will provide additional clean air standards. These initiatives are important because they will provide Pacic Merchant Shipping Association 250 Montgomery St.. Suite 700. San Francisco, CA 94104 (415) 352-0710 fax (415) 352-0717 the broadest clean air benets while providing a level playing eld while avoiding an unworkable patchwork ofregulations that would create confusion and threaten trade. We greatly appreciate your efforts on these initiatives and will continue to work with you on program implementation. It is vital that you avoid the mistakes we are seeing in California where political science has trumped real science. Up to now, you have successrlly balanced your role in achieving measurable emissions reductions while maintaining a competitive port and providing good service to your customers. We applaud your efforts. Ifyou have any questions regarding these comments please feel free to contact me at (415) 3520710 or our Seattle ofce. Sincerely, John McLaurin President National Retail Federation The Voice of Retail Worldwide August 21, 2009 Mr. Bill Bryant President Port of Seattle Board of Harbor Commissioners 2711 Alaskan Way Seattle, WA 98126 RE: Port of Seattle Commission Meeting Support for Clean Truck Plan Dear Commission President Bryant: On behalf of the National Retail Federation, I would like to express our strong support for the Clean Truck Plan which is included in the Northwest Ports Clean Air Strategy. We understand that the Harbor Commission will receive an update on the strategy during the August 25'h Commission Meeting. The Port of Seattle has taken the right approach working with its stakeholders to develop a plan that will improve harbor truck related emissions without imposing significant supply chain costs on the Port's customers. We strongly support the program in its current form and urge the Commission not to change direction or endorse policies-designed to restructure the harbor drayage market in the name of clean air. By way of background, NRF is the world's largest retail trade association, with membership that comprises all retail formats and channels of distribution including department, specialty, discount, catalog, Internet, independent stores, chain restaurants, drug stores and grocery stores as well as the industry's key trading partners of retail goods and services. NRF represents an industry with more than 1.6 million US. retail companies, more than 24 million employees - about one in five American workers - and 2008 sales of $4.6 trillion. As the industry umbrella group, NRF also represents more than 100 state, national and international retail associations. The Clean Truck Plan included in the Northwest Ports Clean Air Strategy takes the right approach by not including fees and focusing on removing the older trucks which service the port through the rolling ban based on the age of the truck. The Clean Truck Plan should continue to focus on replacing the trucks themselves and not the individual who drives the truck. A similar program that has been implemented in marine terminals in Southern California has already replaced over 30% of the trucking fleet in favor of equipment that meets or exceeds 2007 US. EPA emissions requirements. industry experts expect 50% of the fleet to be converted by the end of the year. The success of this program will greatly contribute to air quality improvements. Liberty Place 325 7th Street NW, Suite 1100 Washington, DC 20004 800.NFiF.HOW2 (800.673.4692) 202.783.7971 fax 202.737.2849 www. nrf.com We strongly oppose current efforts by other ports to amend existing federal law to give port authorities and other localities an exemption from longstanding federal truck rules codified in the Federal Aviation Administration Authorization Act (F4A). Current federal laws already allow port authorities to move fonNard with clean truck programs such as those included in the Northwest Ports Clean Air Strategy. As noted, we have already seen success with the Clean Truck Plan implemented by the Ports of Los Angeles and Long Beach without any changes to federal law or controversial driver related provisions. We urge the Port not to make any changes to its Clean Truck Plan or to support the efforts to amend the F4A. We stand ready to work with you to implement the Clean Truck Program. if you have any questions, please contact Jonathan Gold (goldj@nrf.com), NRF's Vice President, Supply Chain and Customs Policy. 4147M Tracy Muilin President and CEO WI'A WASHINGTON TRUCKING ASSOCIATIONS lxg PRESIDENT OFFICERS: PRESIDENT Albert Ulrich FIRST vrcs PRESIDENT Stan Vander Pol August 19, 2009 SECOND VICE PRESIDENT Donna Hyatt Port of Seattle Commissron. . mum VICE PRBIDENT PO Box 1209 ma Caponlgro Seattle, WA. 981 1 1 TREASURER ""9 ""3 Dear Port of Seattle Commission, The lntermodal Conference of the Washington Trucking Associations, comprise the majority of stake holders in land transportation of container cargo moving through the Port of Seattle. Our families and those of our business partners live here and in nearby communities. As such, we are vitally interested in responsible stewardship of our environment, in particular the air we all breathe. We applaud the Port of Seattle for their pro-active approach to reducing air pollution in our area as it has been set forth in the Puget Sound Clean Air Act which was ratified in April 2009. We too thank the Port of Seattle for the collaborative effort in which the plan was developed. This plan accomplishes signicant reductions in air pollution without the negative economic impact and potential losses of revenue which other Ports have tempted by their levying of per-container fees. While other Ports, in particular LA and Long Beach, have even further jeopardized the economic stability of trade by attempting to impose requirements on the type of business model drayage trucking rms are allowed to operate; the Port of Seattle has seen through the smoke and mirrors, clearly understanding that whether a driver is an employee of a company or the company owner itself, is irrelevant to reducing air pollution. They have resisted the temptation to enter into matters that are clearly out of the realm of a Port Commission. The ports of LA, Oakland, and NY~NJ have announced their support for the concept of allowing port authorities limited regulatory authority over harbor drayage firms in their jurisdictions, such as requiring that only drivers that are employees of a harbor trucking rm would be allowed entrance to a port terminal. The Port of LA had such a mandate in its "clean truck" program, but it was stricken by the courts as a violation of the Federal Aviation Administration Authorization Act (FAAAA), which upholds federal government preemption authority over state and local entities in matters involving interstate commerce. The Teamsters Union is also supporting an amendment to the FAAAA which would allow Ports to require only employee drivers. If enacted, this would abolish the rights of individuals to own their own trucking businesses and triple the cost of drayage per container to shippers. Ports that would open up the possibility of such an unnecessary escalation of costs would be committing economic suicide. We encourage the Port of Seattle Commission to continue in its common sense, result-oriented, collaborative approach to increasing the quality of the air we all breathe in the Pacic Northwest, while remaining an attractive venue for international trade. Sincerely, 70,44" CWW/d) Kent Christopher President, lntermodal Conference Washington Trucking Associations [253) 838-1650 . I-BOO-732-9OI9 I Fax (253] 838-I 793 I 930 S. 336th Street, Suite B I Federal Way, WA c)8003 August 20, 2009 Bill Bryant President Port of Seattle Board of Harbor Commissioners PO Box 68727 Seattle, WA 98168 Dear Commission President Bryant: On behalf of the Waterfront Coalition, I would like to express our support for the Clean Truck Plan included in the Northwest Ports Clean Air Strategy. It is our view that this program will improve harbor truck related emissions without imposing additional supply chain costs on the Port's many customers. Other ports around the country are supporting certain policies attached to similar clean truck programs that are designed to dramatically restructure the harbor drayage market without any benet to clean air. We support the Port of Seattle's program in its current form and urge the Commission not to endorse policies designed to restructure the drayage market in the name of clean air. By way of background, the Waterfront Coalition represents manufacturers, product suppliers, retailers and agricultural producers as well as transportation providers moving international commerce through marine terminals and along the nation's surface transportation system. Our members move a signicant amount of cargo through the Port of Seattle and our members' supply chains rely on the region's harbor drayage industry. We have a direct interest in insuring that the port trucking industry operates safely, efciently and in an environmentally responsible manner. We support the Clean Truck Plan included in the Northwest Ports Clean Air Strategy designed to reduce harbor truck emissions. The rolling ban on the age of the truck will signicantly contribute to harbor truck emissions reductions. A similar program that has been implemented in marine terminals in Southern California has already replaced over 30% of the trucking fleet in favor of equipment that meets or exceeds 2007 US. EPA emissions requirements. Industry experts expect 50% of the eet to be converted by the end of the year. The success of this program will greatly contribute to air quality improvements. We oppose efforts to amend existing federal law to give port authorities and other localities an exemption from longstanding federal truck rules codified in the Federal Aviation Administration Act (F4A). Already, the ports of Los Angeles, Oakland and the Port Authority of New York-New Jersey (PANYNJ) support this rule change so as to 1707 L Street NW 1 Suite 570 [Washington, DC 20036 I (202) 861-0825 | www.portmod.org unnecessarily regulate certain aspects of port trucking. This attempt to rewrite longstanding federal trucking laws is ultimately designed to fundamentally restructure the drayage industry so as to drive out ofbusiness the many hard working independent truckers moving international freight in favor of employee drivers. Current federal laws already allow port authorities to move forward with clean truck programs such as those included in the Northwest Ports Clean Air Strategy. Already the ports of Los Angeles and Long Beach already maintain the legal authority under federal law to ban and replace aging dirty nucks. Other federal laws regarding port security and motor carrier safety are in place to address these issues. The effort to amend existing federal trucking laws will do nothing to achieve clean air goals while mdamentally and unfairly restructuring the drayage market and increasing costs and supply chain headaches for the Port of Seattle's many customers. Support for the amendment could send the wrong message to many cargo owners looking for alternative North American gateways. We stand ready to work with you to implement a Clean Truck Program that truly supports clean air goals and urge not to endorse a change in federal law that will ultimately harm the many truckers that serve Pacic Northwest marine terminals and the competitive position that your port enjoy today. Sincerely, Robin Lanier Executive Director . ' 1131 SW Kllckltat Way ' Seattle Washington 93134 . SSAMa flne 90014223505 tel A Carrlx muprlse 206162343179!" we: I! August 25, 2009 Port of Seattle Commission 2711 Alaska Way Seattle, Wa. 98121 Dear Commissioners, You and your staff have been unique amongst Ports in dealing with Air Quality issues on a number of fronts. First, rather than prescribe solutions to a problem that was not fully understood, you led the industry by developing a fully researched and extensive Air Quality Analysis. This analysis was conducted with full transparency and through collaboration with a broad array of stakeholders. Recognizing that air emissions from all sources affect the entire air shed, and using science and sampling to understand and develop the best solution makes the Port of Seattle and its partners stand out as leaders in the industry. Second, you used this scientic basis coupled with an understanding of the basic operating practices of the maritime industry and the proven success of using practical solutions to achieve results to drive your strategy. These principles formed the basis of your Northwest Ports Clean Air Strategy. Many elements of this strategy have been successfully implemented and you are on track to achieve the goals that you have set. Clearly, practical solutions that can be integrated into existing industry practices are producing the positive environmental results that you had hoped for. Third, throughout the entire process, you have used a collaborative solution based approach, and have focused on providing solutions that can be implemented without significant disruption to the affected businesses. This has consistently been done with keeping an eye on the competitive effects these solutions would have on the increasingly competitive business environment in which we live. Finally, you have set measurable goals that allow you to track progress and measure improvement. On all these fronts, you have demonstrated a model approach, using practical, pragmatic, science based solutions to a problem that affects us all. One element of this program that we have recently been direct participants in is the Drayage Truck Program. It has been designed and executed based on the principles outlined above. Port Staff through outreach to all sectors of the industry and environment have created a set of policies and specific lease requirements that together balance industry needs with meeting the goals of the Port's adopted Northwest Ports Clean Air Strategy. This was achieved by getting all sectors of the industry to voluntarily agree to abide by standards that meet the goals outlined in your long term Clean Air Strategy. What is even more remarkable is that this was done without implementing fees that would negatively affect the competitiveness of the Port of Seattle. In fact, the accomplishment of designing and implementing a program that is supported by industry, meets your goals, and cleans up the environment will serve as yet another reason for customers to build condence in Port of Seattle as a long term cargo gateway. We will be signing the nal lease documents shortly, after a thorough and comprehensive review by all parties. SSA Marine's commitment to adopt these amendments is matched by our competitor's commitment to do the same. Your staff deserves credit for not only pulling together a program that will yield signicant environmental benefits, but for bringing together competing parties to develop a solution that all affected parties can support. We urge you to continue with this same strategy as we tackle other major environmental initiatives. Practical, science based solutions that can be phased in and supported by the affected industries will achieve the overall desired results faster and better and with less disruption to the Port operations. This approach will help continue to build the reputation that the Port of Seattle is an efficient and predictable Port in which to conduct business. Sincerely, " Mark Knudse VP, Business Development SSA Marine m "K" LINE AMERICA, INC. 17011 Beach Boulevard, Suite 1100 Huntington Beach, CA 92647-7402 TEL: (714) 861-5000 FAX: (714) 861-5001 August 22, 2009 President Bill Bryant Port Commission Port of Seattle 2711 Alaskan Way Seattle, WA 98121 President Bryant and Commissioners: We are aware that the Port Commission will be reviewing the Northwest Ports Clean Air Strategy (NWPCAS) at your forthcoming meeting on August 25, 2009 and is interested in feedback as to how your program is impacting your customers and the impact it has on our perception of the Port of Seattle. During a recent meeting of the Clean Cargo Working Group, the Port of Seattle gave a presentation on the development and components of your environmental programs. At that forum, I was pleased to be able to openly compliment the Port of Seattle on the collaborative process used in developing your environmental programs. The Port of Seattle (and your neighbor and environmental partner the Port of Tacoma) has done a good job of reducing the environmental impact of containerized cargo movements while minimizing the economic impact that your policies and regulations impose on your steamship line customers and the shippers who move cargo through the Pacific Northwest. The connection between ill considered and costly environmental initiatives and a negative impression by the ocean carrier of the promoter of those policies should be a concern for all port authorities. Against general trends, the Port of Seattle has seen a growth in "K" Line cargo volumes (for the period through the end of July 2009, "K" Line moved 9,546 loaded TEUs which is a 68% improvement over the same period in 2008) and we would urge the Port of Seattle to maintain the well considered and customer friendly components of your existing environmental programs. Sincerely /MVWV Peter D. Bennett Vice President Pacific Coast Operations CC: Tay Yoshitani Port of Seattle Tim Farrell Port of Tacoma N. Ishida "K" Line America Richmond T. Kessery "K" Line America Chicago C.P. von Kannewurff "K" Line America Richmond S. Gannon "K" Line America Chicago S. Fullerton "K" Line America Seattle Pacific Terminals, Ltd 3480 West Marginal Way SW - Seattle. Washington 98106 - Ph: (206) 923-2155 - Fax: (206) 923- Pacic Tenninais. m "65 August 21, 2009 Pacic Terminals operates Terminal 7-A, handling substantial export tonnage shipped out of Port of Seattle Terminals. Our commitment to a green alternative by offering barge services, the greenest form of transportation, is unmatched. Pacic Terminals existence depends on the Port of Seattle's competitiveness compared to other Ports, especially Tacoma and Vancouver BC. We support Seattle's Clean-Truck Plan, it is a model for other Ports. It does not have a hidden labor agenda. We ask only that the Port of Seattle work in concert with other Ports so that this does not become an economic liability for Seattle. Sincerely, Patrick Cohn General Manager Styrk, Linda From: Kent Christopher [kchristopher@westernports.com] Sent: Thursday, August 20, 2009 10:10 AM To: Bryant, Commissioner Bill Subject: POS Clean Air program Attachments: image002.jpg Commissioner Bryant, i am sending you this note, on behalf of Western Ports Transportation, lnc., in support of the port's Clean Air Program. The Port has certainly been the catalyst over the last two years to move this program along and not let it get tied into social engineering issues. Your staff has done an excellent job in bring the shipping companies, trucking companies, terminal operators, and clean air agencies to the table to work on this important issue. Because of this broad range of groups working together, we were able to develop a program that was not only good for the environment. but a program that will keep Seattle competitive with Canadian and other US Ports that are trying to take our business away! We are working with our owner/operators to make sure that. as a company, we will be ready to comply with the mandated standards on January 1, 2011. In June 2007, 44% of our owner/operator's trucks were older than 1994. I am pleased to report that today 85% of the trucks that our owner/operators are driving are 1994 or newer. As a company, we will be 100% compliant on January 1, 2011! We look fonlvard to working with you and the entire Port of Seattle Commission to reach each of the goals set forth in the program. A strong and competitive Port of Seattle will continue to be an economic and environmental model for the region and the world. Sincerely, Kent Christopher Kent Christopher President 1 Western Ports Transportation, Inc. {PORT ' RANSPOR [AI-[0' INC . SEATTLE FREIGHT SERVICE, INC. August 24, 2009 Port of Seattle Commission POB 68727 Seattle, WA. 98168 Dear Port of Seattle Commission, Seattle Freight Service, Inc. is a major stake holder involved in land transportation of international container cargo moving through the Port of Seattle. Our families, and those of our independent business partners, live here and in nearby communities. As such, we have an vested interest in the responsible stewardship of our environment, particularly the quality of the air we breathe. We commend the Port of Seattle for their collaborative and pro-active approach to reducing air pollution in our area as it has been set forth in the Puget Sound Clean Air Act which was ratied in April 2009. This plan represents signicant strides in the improvement of air quality without the negative economic impact and potential losses of revenue which other Ports have tempted by the levying of per-container fees. While other Ports, in particular, LA and Long Beach have even further jeopardized the economic stability of trade by attempting to impose requirements on the type of business model drayage trucking firms are allowed to operate, the Port of Seattle has demonstrated discernment, clearly understanding that whether a driver is an employee of a company or the company owner itself, is irrelevant to the improvement of air quality. They have resisted the temptation to enter into matters that are clearly outside the responsibility of a Port Commission. In order to preserve free enterprise, which is what has provided these great United States with a standard of living unparalleled anywhere in the world, the trucking industry, which is already tightly regulated, must not be further hand-cuffed with restrictions on their operating model. The ports of LA, Oakland and NY-NJ have announced their support for the concept of allowing port authorities limited regulatory authority over harbor drayage rms in their jurisdictions, such as requiring that only drivers that are employees of a harbor trucking rm would be allowed entrance to a port terminal. Port of LA had such a mandate in its "clean truck" program, but it was stricken by the courts as a violation of the FAAAA. (Federal Aviation Administration Authorization Act, which upholds federal government preemption authority over state and local entities in matters involving interstate commerce.) The Teamsters Union is supporting an amendment to the FAAAA which would allow Ports to require only employee drivers. This type of regulation would abolish the rights of individuals to own their own trucking businesses and triple the cost of drayage per container to shippers. Ports that would open up the possibility of such an unnecessary escalation of costs would be committing economic suicide. 8025 10th Avenue South Seattle, Washington 98108, Phone: 206-7673535, Fax: 206-763-0466 www.5eattlefreight.com SEATTLE E"REI@H 7" SERVICE, INC. We encourage the Port of Seattle Commission to continue in its common sense, resultoriented approach to increasing the quality of the air we all breathe in the Pacic Northwest, while remaining an attractive venue for international trade. We also fully support the on-going efforts of the Port Commission, and encourage it to continue to support the Puget Sound Clean Air Agency's program for buy-back, or some form of compensation and assistance to the independent small businesses that partner with us, in order to upgrade their commercial vehicles to comply with the Northwest Ports Clean Air Act (NPCAA). While a handful of our business partners have purchased 1994 or newer equipment, to comply with the rst phase of NWCAA, many are patiently anticipating the implementation of a scrap/buy-back/purchase option that was presented at an informational trucker meeting, sponsored by the Port, last June. In summary, we appreciate the dedication and hard work of the Commission to gather facts, sift through hype, and have the foresight to agree on and implement a common sense, quality approach to signicantly improve air quality here in the Pacic Northwest, while fostering economic stability and growth for us and our families for years to come. Sincerely, Kevin A. Coon, CDS Safety Director Seattle Freight Service, Inc. 8025 10th Avenue South Seattle, Washington 98108, Phone: 206-767-3535, Fax: 206-763-0466 www.5eattlefreight.com HANUPACTUHINB INDUSTRIAL BDUNBIL August 24, 2009 Gael Tarleton, Commissioner Port of Seattle 711 Alaskan Way Seattle, WA USA. 98121 Re: Northwest Ports Clean Air Strategy Dear Commissioner Tarleton, As participants of the Truck Parking Work Group, we have watched with interest as the Port has begun to put various strategies into action for the Northwest Ports Clean Air Strategy. We appreciate that the Port has chosen to use an incentive based rather than a fee or regulatory approach. The amount of voluntary conversion to low-sulfur fuels should be a good indication that businesses too are willing to do their part to improve the environment. We have been impressed with the range of strategies that the Port is employing in order to impact our local air quality. This in particular allows the drayage businesses of varying size, from single truck operators to large fleet operators, to nd the option that works best for them. The high utilization of the Terminal 25 parking facility may be an early indication that it is a valuable service for truckers. We look fonNard to finding out more about whether it has been useful in addressing the concerns of the local residents. The report that you will receive today represents substantial effort and good progress on the Port's goals. We encourage you to stay the course. Sincerely, yaw - John Odland, Chair Manufacturing Industrial Council P.0. Box 81063 Seattle, Washington 98108 ph: 206.762.2470 fx: 206.762.2492 www.5eattleindustry.org
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