Port Commission
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1700 N. Moore Street Suite 2250 * Arlington,VA 22209
RETAIL INDUSTRY LEADERS ASSOCIATION
Phone: 703-841-2300 Fax: 703-84 I- 1 184
Retail's Future...Educate, Innovate,Advocate               Email: info@riIa.org www.riIa.org

March 31, 2009
Chief Executive Officer Tay Yoshitani
Port of Seattle '
271 1 Alaskan Way
Seattle, WA 98121
Dear Mr. Yoshitani:
I am'writingon behalf of the Retail Industry Leaders Association (RILA) to express our support for
your outline for a clean truck program that ensures a reduction in truck emissions while maintaining
a healthy business climate for supply chain investments in the ports of Seattle and Tacoma.
Shippers, like RILA's retail members, support the adoption of a rolling ban on trucks based on the
model year of the equipment without fees imposed on industry stakeholders. The timeline included
in your outline allows transportation providers to make sound investments that maintain both the
Seattle and the Tacoma port's competitive advantageover other west coast ports.
By way of background, the Retail Industry Leaders Association (RILA) is a national trade
associationof the largest and fastest growing companies in the retail industry. Its member
companies include more than 200 retailers, product manufacturers, and service suppliers, which
together account for more than $1.4 trillion in annual sales. RILA members operate more than
100,000 stores, manufacturing facilities and distribution centers, have facilities in all 50 states, and
provide millions of jobs domestically and worldwide.
RILA'smembers, who are among the largest shippers through the Port of Seattle, urge you to
continue to not include fees on industry stakeholders to fund truck replacement programs. Earlier
this year, the ports of Los Angeles and Long Beach implemented fees to help hndclean trucks. In
our view, this has led to the movement of some discretionary cargo out of LALB and into other
"fee fiee" ports such as Tacoma and Seattle.
Mandatory fees may void investments that shippers, carriers and drayage providers have already
made to purchase fleets of expensive clean burning harbor trucks. We hope you will chose to rely
on industry to identifjr the most cost effective investments available to comply with the standards
you set.
We urge you not to include unnecessary provisions unrelated to the commission's goals,including
those that would result in added costs to doing business through Seattle and Tacoma marine
terminals. Already, the Intermodal Carrier Conference of the American Trucking Association
(ATA) was successful in their efforts of filing suit against both the ports of LAILB for including a
truck concession requirement in their Clean Truck Program designed to restructure the size and

nature of the harbor drayage industry. We are encouraged by the federal appeals court decision to
support ATA's challenge. The court appropriately found that the ban on owner-operators at the
Port of Los Angeles was illegal and that Long Beach's demands for detailed financial data from
drayage operators and for preference to hire certain drivers were likely illegal as well. ~hese
provisions force hard working small business owners out of the market while doing nothing to
directly reduce truck emissions
Taking an industry friendly approach is good for business in SeattleITacoma. The more SeaTac is
able to differentiate itself from the ports of Southern California by working together with willing
industry partners, the more it will position itself as a preferential gateway---which benefits everyone
tied to the port economy including the truckers and drivers.
Many independent owner operators make a good living and run successful small businesses, the
backbone of the American economy. Independent operators can, will, and have deployed clean
equipment without needing the port to get into the truck fmancing business or to impose any fees ornfi
employee mandates. Many of RILA's members have negotiated rates at the ports of LALB with
their individual trucking providers that allow for the purchase of new, clean equipment that is 100
percent privately funded.
In these tough economic times it is extremely important to approach worthy environmental
mitigation issues such as this one with carehl consideration for unintended consequences. We
must work together to avoid the problems encountered by some of your southern neighbors.
Working in collaboration, we can ensure that we address the shared goal of reducing carbon
emissions around the ports, while protecting the businesses and good jobs affiliated with the port's
operations.
In summary, RILA supports your concept of implementing a rolling ban based on the age of the
truck applicable to both Seattle and Tacoma marine terminals. We are co  dent that industry
stakeholders will find the most efficient means of complying with the rule so as to maintain the
region' s competitive advantage.
Thank you for your consideration and if you have any questions, please contact me.
Sincerely,


Kelly Kolb
Vice President, Global Supply Chain Policy
kelly.kolb@,rila.org
703.841.2300
1700 N. Moore Street, Suite 2250
Arlington, VA 22209