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Port ~ommissionSF\O~ Meeting of 10 1 February 10,2009 Commission President Bill Bryant Commissioner John Creighton Commissioner Pat Davis Commissioner Lloyd Hara Commissioner Gael Tarleton Port of Seattle 27 1 1 Alaskan Way Seattle, WA 98121 Dear President Bryant and Port Commissioners: On behalf of conservation, community, labor, business and other organizations in King County, we applaud the Port of Seattle's leadershipon the clean air issue, appreciate the staff effort in formulating an implementation model, and request three changes for a more effective, sustainable and fair truck retrofit plan. As you know, the Port of Seattle is currently developing a plan1to meet the 2010 port truck standards set under the Northwest Ports Clean Air Strategy in part to protect the health and safety of the South Seattle communities, as well as the men and women who work at the Port itself. The Northwest Ports Clean Air Strategy's standards for2010 would ban 400 of the most polluting trucks now serving the Port of Seattle. The Port will require replacement of almost all of the 1,800 of the diesel trucks now in drayage service by 2015. We believe a sustainable and comprehensive strategy is needed to meet the port's clean air goals and we look forward to working with you on that plan. Three O~tionsto Move to the 2010 and 2015 Goals We strongly support current planning that aims to take the dirtiest h koffsthe road immediately and welcome the idea of providing retrofit replacement trucks through Cascade Sierra Solutions or another non-profit or government entity. This approach could work with any of the implementation options now on the table to meet the 2010 goals to ban pre-1994 trucks. The three options as we understand them are: a. Port of Seattle enters into voluntary agreements with the terminal operators to allow only approved trucks through the terminal gates. b. Port of Seattle requires all port trucking companies conducting business on Port of Seattle property, through either concession or tariff agreements, to use approved trucks and business methods, similar to the programs now used by the Port of Los Angeles. The critical features of the current retrofit proposal are set out in grant proposals that have been submitted to the state Department of Ecology, the Environmental Protection Agency and the California Air Resources Board. c. Port of Seattle requires all port trucking companies to use approved trucks through a King County, City of Seattle or State of Washington ordinance. We urge the Port of Seattle to conduct a hll, comprehensive community economic and environmental analysis of the effectiveness, sustainability and fairness of these models before committing significant resources towards implementationof the clean air standards for 2015. Three Changes are Needed Now There are three changes to the Cascade Sierra Solutions (or similar) retrofit proposal that we believe are critical to ensuring that the Port of Seattle's clean trucks program for 2010 is sustainable, effective, and fair. These changes would meet our combined environmental and community goals as outlined later in this letter: 1) Offer retrofit or replacement trucks leases to trucking companies rather than to drivers. Under current economic and workplace conditions, individual trucking company workers will be unable to bear the costs of leasing and maintaining replacement trucks fiom Cascade Sierra Solutions. Although these drivers are classified as "independent contractors,"truclung company workers lack the power to pass the costs of clean trucks on to the trucking companies, the shippers, or the buyers. The Cascade Sierra Solutions plan is actually an economic disincentive for truck drivers -- requiring them to take on additional costs and debt or involuntarily forcing hundreds of drivers out of their jobs. In the end, this plan may incentivize drivers to take their polluting vehicles into other Northwest communities and will most likely waste taxpayer funding. 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 requirementsof retrofit engines and are less likely to default or violate the terms of a retrofit truck lease or contract. Trucking companies should be allowed to lease a retrofit truck for every driver on payroll who turns in a pre-1994 truck for scrappage. (Some of the pre-1994 trucks are already owned by the companies, who then lease them to drivers.) Most trucking companies will then probably sublease the retrofit trucks to their workers, but the trucking companies themselves will be ultimately responsible for maintaining the trucks at peak performance levels and keeping them in drayage service. The trucking companies should also be required to hire, or at the very least contract with, the drivers who turn in their trucks to avoid inadvertent displacement of current workers who wish to remain in the drayage industry. This is a more sustainable, effective, and fair way to implement the Cascade Sierra Solutions model. 2) Ensure the buyback and scrapping of 1993 and older trucks; retrofit trucks from Washington's drayage fleet first. The most effective way to remove the largest amount of diesel pollution is to take the dirtiest trucks out of service and ensure that they do not reenter the marketplace. Merely banning those trucks from the port docks will not work because drivers will probably take their trucks to other communities in the region. The port's proposed plan must include the buyback of those trucks - estimated at about 400 - and it must guarantee that they will be scrapped, not resold or shipped overseas. We also recommend that instead of spending $2,500 per truck to buy scrapped trucks fiorn California, the port's plan should include buying and retrofitting the many local 1998- 2002 model year drayage trucks now for sale by drivers who are trying to exit the industry.* Under the current proposed plan, local trucks aged 1998-2002 would remain in the region, and continue to decline, for another 5-7 years without pollution improvements.' This would more quickly remove more pollution from the region. 3) Mandate installation of more effective emissions control devices The current plan calls for the use of flow through filters. Those (Level 2) filters capture about 50% of particulate emissions of the retrofit trucks and 0% of nitrogen oxide emissions. Diesel particulate filters (Level 3), however, capture at least 85% of diesel particulate matter and 25% of nitrogen oxide emissions. Over five years, using Level 3 filters alone would reduce emission by an additional 6.6 tons of diesel particulate matter and 0.9 tons of nitrous oxides per truck. We understand there are concerns about which filters would work best for short-distance, low-speed drayage. We encourage the Port to find solutions that would maximize pollution removal from our communities, including the use of hybrid, electric and other diesel engine alternatives. Our Shared Environmental and Communitv Goals We believe we share with the Port the following goals for the effort to reduce air pollution for the sake of our local community health as well as that of the wildlife in the Puget Sound basin: Ensure that we meet the 2010 deadline for the benefit of the community health Ensure that we maximize: o the sustainability of this program for the long term o regional air pollution gains o global air quality goals (including scrapping of the old trucks) Ensure that environmental benefits are for everyone equally and fairly and do not unfairly burden any one group of people Buy backs and retrofits of local trucks would also allow drivers to exit the industry voluntarily; many workers say they are stuck in drayage because they owe money on their trucks and would much rather work in another industry. 3 Unfortunately, no scenario under the Port's standards for 2010 would address the 1994 -1997 trucks or the 2005 - 2006 trucks until 2015. With all of these improvements, the Port of Seattle can make progress towards significantly reducing dangerous diesel pollution and greenhouse gas emissions from its activities in a sustainable, effective and fair way. We urge you to direct the port's staffto incorporate these changes into its plan before approving any clean air truck program. Sincerely, Linda R. Anderson, Executive Board Steve Marquardt, Research Director Amalgamated Transit Union Laborers NW Regional Organizing Coalition David West, Executive Director Center for a Changing Workforce Lynn Domingo, Organizer LELO: A Legacy of Equality, Leadership Michael Ramos, Executive Director & Organizing Church Council of Greater Seattle Sharon Lee, Executive Director Heather Weiner, Director Low Income Housing Institute Coalition for Clean and Safe Ports Vince O'Halloran, President Jonathan Betz-Zall Puget Sound Ports Council Joyce Tseng, Board of Directors Maritime Trades Department AFL-CIO Community Coalition for Environmental Justice David Freiboth, Executive Secretary-Treasurer Arsalan Bukhari, Executive Director ML King County Labor Council Council on American-Islamic Relations Washington Chapter Dorry Elias-Garcia, Executive Director Minority Executive Directors Coalition Linda Orgel, Secretary Friends of Grays Harbor and John Littel, Political Director Grays Harbor Community Alliance Eric Franklin, Communications Director Pacific Northwest Regional Council of Phil Mitchell Carpenters Greater Seattie Climate Dialogues Will Parry, President Sally Kinney, Co-chair Puget Sound Alliance for Retired Interfaith Taskforce on Homelessness Americans Jerome Johnson, Vice President Howard Greenwich, Research Director International Longshore & Warehouse Puget Sound Sage Union 19 Kathy Fletcher, President Nancy Quintero People for Puget Sound Iberoamericana Natalie Novak, Community Organizer Dale Cannon, Business Manager Real Change Laborers Local 242 Lee Newgent, Executive Secretary Ken Troup, Secretary-Treasurer Seattle Building and Construction Trades Teamsters Local 589 Council John Emrick, Secretary-Treasurer Brady Montz, Seattle Chair Teamsters Local 3 13 Sierra Club J. Allen Hobart, President Sergio Salinas, President Teamsters Joint Council 28 SEIU Local 6 Diane Zahn, Secretary-Treasurer Dagmar Cronn, Member UFCW Local 21 South Park Neighborhood Association Rick Sawyer, Secretary-Treasurer Chuck Eggert, Secretary-Treasurer UNITE HERE Local 8 Teamsters Local 231 Jim Woodward, Sub District Director Tracey Thompson, Secretary-Treasurer United Steel Workers District 12 Teamsters Local 117 John R. Jones, Jr., President Justin (Buck) Holliday, Secretary-Treasurer Washington ACORN Teamsters Local 690 Maru Mora Villalpando, Lead Organizer Rick Hicks, Secretary-Treasurer Washington Community Action Network Teamsters Local 174 Laurie Valeriano, Policy Director Steve Chandler, Secretary-Treasurer WA Toxics Coalition Teamsters Local 38
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