WATERFRON
[ ~ ~ x - - - l
,PortCommission
w&d
April 1,2009

Tay Yoshitani
Chief Executive Officer
Port of Seattle
2711 Alaskan Way
Seattle, WA 98121
Dear Tay:
On behalf of the Waterfiont Coalition, I would like to express our support for
your concept to address drayage truck emissions in the port of Seattle. As you move
forward jointly with your truck emission program, we would urge you to adopt emission
standards that are within the ports' jurisdiction. We would also urge you not to consider
fees levied on shippers or other industry stakeholders to fund a truck replacement or
retrofit program. Finally, we would also urge you not to consider additional provisions
regulating the drayage industry in your region that do not directly address truck
emissions.
By way of background, the Waterfiont Coalition represents manufacturers, retailers,
agricultural producers and transportation providers moving international commerce
through North American blue water ports including the ports of Seattle and Tacoma, Our
members understand the need to reduce drayage truck emissions in the Pacific Northwest
and throughout the nation. Many of our members participate in broad based industry
efforts, such as the Coalition for Responsible Transportation, to ensure that licensed
inotor carriers deploy clean burning drayage equipment.
We support the outline that Port of Seattle staff presented to us concerning broad
initiatives to reduce drayage truck emissions in the region. The Waterfront Coalition
supports the adoption of a rolling ban on trucks based on the model year of the equipment
without fees imposed on industry stakeholders. This policy allows drayage providers to
identify the most efficient investment decision to comply with the rule while preserving
the competitive advantage marine terminals maintain in the region. The outline of your
truck plan would also keep both ports out of managing drayage operations.
In our view, it is important that your truck plan remain devoid of fees to fund truck
replacement or retrofit technology. As you may be aware, the Clean Truck Program as
endorsed by both the ports of L.A. and Long Beach includes a $70 container (FEU) fee

1707 L St. NW 1 Suite 570 1 Washington, DC 20036 1 (202) 861-0825 1 www.portmod.org

levied on shippers to help fund the replacement of all harbor trucks. This fee has been in
part responsible for a recent diversion of discretionary cargo to load centers outside of the
San Pedro Bay including the ports of Seattle and Tacoma. Similar fees adopted in
Seattle-Tacoma area may erode this competitive advantage currently enjoyed in the
region.
Such fees also have the potential to void investments motor carriers and others have put
into clean burning equipment. Many of our shipper, carrier and drayage members are
collaboratingon business models to ensure that truckers have access to clean burning
equipment. These investments in green technology result in higher dray rates paid by
shippers and ocean carriers. Mandatory fees imposed on industry stakeholders to fund
truck replacement or retrofit equipment may undermine these voluntary investments and
weaken the business investment climate in the region.
As you and your staff develop your truck plan, we would also encourage you not to
include provisions that do not directly address truck emission reductions. Such ancillary
policies may result in added costs to doing business through Seattle marine terminals
that could contribute to a diversion of cargo and tie the ports into lengthy and costly
litigation. Already, the Intermodal Carrier Conference of the American Trucking
Associations has filed suit against both the ports of L.A. and Long Beach for including a
truck concession requirement in their Clean Truck Program designed to restructure the
size and nature of the harbor drayage industry. These provisions do nothing to directly
reduce truck emissions, while forcing out of the industry many hardworking small
business owners and contributing to a poor business climate to guarantee future supply
chain investments.
I would like to thank you for allowing our group to share our views concerning a way
forward to reduce truck emissions. Once again, we support your concept of
implementing a rolling ban based on the age of the truck applicable to Seattle marine
terminals. We are confident that our industry partners will find the most efficient means
of complying with the rule so as to maintain the region's competitive advantage.
Please consider the Waterfront Coalition a resource as you roll out your truck program. I
would welcome any questions or comments and I can be reached at (202) 861-0825.

Sincerely,

Robin Lanier
Executive Director