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