Port Commission 2' bw/
MeetingMM
Friends of       W.-
the Earth

4 January 2011

Port of Seattle
2711 Alaskan Way
Seattle, WA 98121

Dear Commissioners and Mr. Yoshitani 

We are writing you today to express our concern about the Port's commitment to
maintaining its environmental leadership in the coming years. Our concerns are
highlighted in two specific current issues of concern: the Cruise MOU amendment
process and the budget allotment

Friends of the Earth (FOE) is a national environmental organization that works to
protect the environment and champion a healthy and just world. FoE's Oceans &
Vessels project campaigns to protect human health and the marine environment
from the substantial air, water, and oil pollution generated by cruise ships,
container ships, oil tankers, tugs, and ferries, as well as port facilities. Foe has
maintained a presence in the NW for over 30 years.

CRUISE MOU
We are concerned about the annual review and update of the cruise ship MOU
between the Port, the NW Cruise Association and Department of Ecology. The
problems associated with the current MOU were known prior to the beginning of
this past cruise season. While the Commission has twice discussed how the MOU
will be updated in the future, it has yet to vote on a resolution regarding this matter
nor have the results of the past cruise season been discussed publicly. While there

was a presentation on the Port's ABC fuels program at the last Commission meeting
of 2010, there has been no discussion of the labor problems resulting in very little
cold ironing occurring this past season or how it will be avoided in the future.

On December 28th we received an email from Ecology notifying us of the annual
MOU meeting January 13th. We were dismayed to read, "The MOU parties have
agreed to amend the MOU very shortly to outline an amendment process. With the
new process, we will be receiving proposed amendments with a public process
beginning in November of 2011 and every three years thereafter." We find such a
statement premature given that the Commission has yet to vote on the proposed
changes and this would preclude resolving the longstanding issues mentioned
below.

While we are open to discussing lengthening the amount of time between updates of
the MOU and a more systematic method to the amendment process, we rst need to
see a greater commitment from the MOU parties to timely public transparency of
MOU compliance issues. We also need to finally resolve how the incineration of
sewage sludge will be addressed. We believe it is more efficient to make sewage
sludge a part of the MOU rather than the NW Ports Clean Air Strategy. The sludge
generated onboard is a result of the operation of the sewage treatment system and
Ecology is already boarding vessels and can request the logs to assure that the
incinerators are not being used in State waters. We also request that the ban on
wastewater discharges at the dock to be codified in the MOU rather than being
subject to individual cruise line preferences each season.

Budget
It is disturbing to see disproportionately large reductions in nonoperational
environmental and public expenses in the 2011 budget the Commission just
approved. We would greatly appreciate an explanation of how a $36 million
reduction in those budgets will affect the Port's commitment to maintaining its
environmental programs, especially in light of the need for increased spending for
environmental cleanups and source control in the Duwamish and in East Waterway
in the near future.

Thank you for your consideration and look forward to working with you to maintain
your leadership in the region's economy and environment.

Sincerely,

Fred Felleman, MSc.
NW Consultant
Friends of the Earth

3004 NW 9301 St.
Seattle, WA 98117
206.783.6676