Item 6d supp
Item No. 6d supp Date of Meeting November 11, 2008 Briefing on Truck ProgramBriefing on Truck Program DevelopmentDevelopment Briefing OverviewBriefing Overview Background: The Data Background: The Data Northwest Ports Clean Air Strategy Northwest Ports Clean Air Strategy Stakeholder Outreach Stakeholder Outreach Staff Program Analysis Staff Program Analysis Next Steps and Schedule Next Steps and Schedule 2 Puget Sound Region Air Toxics Risk Apportionment 3 Source: Puget Sound Clean Air Agency Puget Sound Maritime Air Emissions Inventory 2005 activity based inventory Spans ~140 miles south-to-north; 160 miles west-to-east Close coordination Canada First to include greenhouse gases 4 Diesel Particulate Matter Puget Sound Clean Air Agency Region 5 Source: 2005 Puget Sound Maritime Air Emissions Inventory Diesel Particulate Matter Port of Seattle 6 Source: 2005 Puget Sound Maritime Air Emissions Inventory Comparison of 2005 Puget Sound Clean Air Agency Region Heavy-Duty Vehicle Emissions, % In the Puget Sound, drayage operations represent: 3% of all DPM emissions from heavy-duty trucking 3% of all heavy-duty vehicle miles traveled 7 Source: 2005 Puget Sound Maritime Air Emissions Inventory Drayage Fleet Age AnalysisDrayage Fleet Age Analysis Updated in 2008Updated in 2008 Estimated drayage fleet size: 1,800 - 2,000Estimated drayage fleet size: 1,800 - 2,000 truckstrucks Average model yearAverage model year Port of Seattle drayage trucks: 1996 Port of Seattle drayage trucks: 1996 Statewide Class 8 heavy-duty vehicles: 1996 Statewide Class 8 heavy-duty vehicles: 1996 PSCAA region Class 8 heavy-duty vehicles: 1998 PSCAA region Class 8 heavy-duty vehicles: 1998 24% of known fleet are older than 199424% of known fleet are older than 1994 8 Northwest Ports Clean AirNorthwest Ports Clean Air StrategyStrategy 2010 performance measure for trucks: 2010 performance measure for trucks: "Reach the equivalent PM emissions level of"Reach the equivalent PM emissions level of 1994 or newer heavy-duty truck engine model1994 or newer heavy-duty truck engine model year"year" 2015 performance measure for trucks: 2015 performance measure for trucks: "80% of trucks reach the equivalent PM"80% of trucks reach the equivalent PM emissions level of 2007 or newer heavy-dutyemissions level of 2007 or newer heavy-duty truck engine model year; 100% meet 2007 bytruck engine model year; 100% meet 2007 by 2017"2017" 9 Current Staff FocusCurrent Staff Focus Implement mandatory program beginning Implement mandatory program beginning 12/31/201012/31/2010 Financial assistance and incentives to Financial assistance and incentives to encourage early adoptionencourage early adoption Verification Verification 10 Stakeholder OutreachStakeholder Outreach South Harbor Truck Parking Work Group South Harbor Truck Parking Work Group NW Ports Clean Air Strategy Truck Work NW Ports Clean Air Strategy Truck Work GroupGroup Clean Air Prosperity Partnership (CAPP) Clean Air Prosperity Partnership (CAPP) Supply chain work group to support cleaner Supply chain work group to support cleaner trucks and increased efficiencies in the entiretrucks and increased efficiencies in the entire container drayage systemcontainer drayage system Seaport Air Quality Program Advisory Seaport Air Quality Program Advisory Group newGroup new 11 Seaport Air Quality ProgramSeaport Air Quality Program Advisory GroupAdvisory Group Purpose: Purpose: To provide input on truck program To provide input on truck program implementation optionsimplementation options 2-3 representatives from: 2-3 representatives from: Trucking Trucking Regulatory Agencies Regulatory Agencies Terminal Operators Terminal Operators Community Community Shippers Shippers OrganizationsOrganizations Shipping Lines Shipping Lines Environmental Groups Environmental Groups Labor Labor 12 Data AnalysisData Analysis Puget Sound Air Toxics Risk Puget Sound Air Toxics Risk ApportionmentApportionment Puget Sound Maritime Air Emissions Puget Sound Maritime Air Emissions InventoryInventory Drayage truck fleet age analysis Drayage truck fleet age analysis 13 Staff Program AnalysisStaff Program Analysis To DateTo Date Internal and external stakeholder work Internal and external stakeholder work groupsgroups Evaluated a range of options for: Evaluated a range of options for: Funding Funding Financial Assistance Financial Assistance Legal and Legislative Legal and Legislative 14 Staff Identified PrioritiesStaff Identified Priorities Focus on NW Ports Clean Air Strategy 2010Focus on NW Ports Clean Air Strategy 2010 performance measure for trucksperformance measure for trucks Create a mandatory programCreate a mandatory program Deliver cleaner air nowDeliver cleaner air now Keep the plan simpleKeep the plan simple Fee freeFee free Advance business & environmental needsAdvance business & environmental needs Work within the legal authorities of WA State and localWork within the legal authorities of WA State and local governmentgovernment Factor in the NW ports' market conditionsFactor in the NW ports' market conditions Give the industry time to adjustGive the industry time to adjust Incentives for early adoptionIncentives for early adoption 15 Staff ProgramStaff Program Analysis CriteriaAnalysis Criteria Definition Importance Meets Strategy 10 Goals (i.e. emission reductions) No Cargo Diversion 9 Social Equity 6 Affordability (Port) 5 Minimizes Legal 4 Risk Administrative 1 Simplicity 16 Program AnalysisProgram Analysis Funding OptionsFunding Options State bonds with Port funding match State bonds with Port funding match Use tax levy Use tax levy Container fee Container fee To be paid by beneficial cargo owner To be paid by beneficial cargo owner Fee paid by terminal operators/carrier Fee paid by terminal operators/carrier "Pay to pollute" "Pay to pollute" Fee for non-compliant trucks Fee for non-compliant trucks 17 Pros and ConsPros and Cons Fees Paid by Industry State Bonds with Port Use Tax Levy "Pay to Pollute" (Container/Other) Funding Match Pros Increases ability to get Costs and administrative Fees paid for by offenders Supports meeting Strategy State/Federal grants burden borne by industry Good way to handle non- goals Immediate and direct Reduces impacts to the frequent callers No cargo diversion, may Simple to administer Port's budget Consistent with CARB actually attract cargo Reduces social justice Drayage Truck Rule Wouldn't increase cost of issues doing business No cargo diversion, may actually attract cargo Wouldn't increase cost of doing business Cons Gift of public funds issue Fee doesn't hit beneficial Gift of public funds issue Gift of public funds issue Not consistent with cargo owners or Not really a financing Administratively complex Commission direction to consumers, who are mechanism reduce tax levy recipients of low cost Administratively complex Limits the Port's ability to transportation Doesn't support Port's invest in other projects Legal issues goal of being clean and Container diversion green impact on revenue/jobs Legal issues Port does not have Port does not have authority to implement authority to implement Strains relationships with Lease implications as a those the Port has direct result of cargo diversion business agreements with Potential social justice issues 18 Program AnalysisProgram Analysis Financial Assistance OptionsFinancial Assistance Options State bonds with Port funding match State bonds with Port funding match Provide funding via restricted vouchers Provide funding via restricted vouchers In partnership with PSCAA In partnership with PSCAA Purchase brand new trucks Purchase brand new trucks $0 in Port funding $0 in Port funding 19 Pros and ConsPros and Cons Provide Funding via Purchase Brand New State Bonds with Port $0 in Port Funding Restricted Vouchers Trucks Funding Match Pros Avoids gift of public Supports meeting or Guarantees meeting the Supports meeting funds issue exceeding Strategy goals 2015 Strategy Strategy goals No financial benefits Minimizes business performance measure Likely wouldn't increase given to some drivers interruption cost of doing business and over others Guarantees that funds create cargo diversion More legally defensible will be spent for intended Minimizes impact to purposes drivers Minimizes impact to Ability to address social drivers justice issues in a way Ability to address social that works for our justice issues in a way business model that works for our business model Cons May have social justice Gift of public funds issue Gift of public funds issue Gift of public funds issue implications Difficult to track that Very expensive Administratively Unlikely to meet funds invested stay here Not cost effective complex Strategy goals Administratively Supply of new trucks will Would increase cost of complex not meet demand doing business Potential tax impacts for One time answer Likely diversion of drivers Administratively cargo complex 20 Program AnalysisProgram Analysis Legal & LegislativeLegal & Legislative Overarching legal issues: Overarching legal issues: Any state legislation still leaves certain federal Any state legislation still leaves certain federal issues unaddressedissues unaddressed Some of these issues are the subject of Some of these issues are the subject of litigation involving the Ports of L.A. and Longlitigation involving the Ports of L.A. and Long Beach in their truck programBeach in their truck program The Port needs to proceed very carefully and The Port needs to proceed very carefully and be prepared to modify the plan to comply withbe prepared to modify the plan to comply with legal requirementslegal requirements 21 Program AnalysisProgram Analysis Legal & Legislative OptionsLegal & Legislative Options Pursue State-wide heavy-duty vehicle rulePursue State-wide heavy-duty vehicle rule PSCAA regulates trucksPSCAA regulates trucks Pursue State authority for Ports to regulatePursue State authority for Ports to regulate "Pay to Pollute" with eventual ban"Pay to Pollute" with eventual ban Adopt Truck Licensing SystemAdopt Truck Licensing System City of Seattle regulates trucksCity of Seattle regulates trucks Ban non-compliant trucks at terminal gatesBan non-compliant trucks at terminal gates Adopt employer-based modelAdopt employer-based model 22 Pros and ConsPros and Cons Pursue State Authority for City of Seattle Regulates Pursue State-Wide Heavy- PSCAA Regulates Trucks Port to Regulate Trucks Duty Vehicle Rule Trucks Pros City is an inherent PSCAA has authority to Clarifies Port authority to Greater benefit to air regulator regulate general air quality regulate quality and public health City has more clear in King, Kitsap, Pierce and Creates an opportunity to Creates a level playing authority over matters Snohomish Counties develop a solution that fits field affecting public health and Would address truck our program Fewer equity issues safety operations at Port of Lessens risk of challenge Tacoma based on authority Port's strong collaborative relationship with PSCAA Cons City of Seattle regulation PSCAA does not have Could lose control of Difficult to achieve wouldn't address truck authority to regulate process and end up with quickly operations at Port of mobile sources something we don't want Expect a lot of opposition Tacoma PSCAA would need to get Creates regulatory inequity Chance of passing is slim City may have to go to Legislative authority between port drayage vs. Potential conflict - Federal Legislature for authority Unintended consequences non-port heavy duty trucks vs. State City would probably look - Port may lose control of Risk of social inequity for Overarching legal issues to Port for financial outcome port drivers assistance PSCAA would look to Port Overarching legal issues Unintended consequences to provide financial - Port may lose control of assistance outcome Overarching legal issues Overarching legal issues 23 Pros and ConsPros and Cons Ban Trucks at "Pay to Pollute" with Adopt Truck Licensing Adopt Employer-Based Terminal Gates Eventual Ban System Model Pros Fewer players - Port and Fees paid for by offenders Ability to address social Ability to address social terminal operators Good way to handle non- justice issues justice issues Less administrative frequent callers Could allow Greater long term complexity Consistent with CARB grandfathering of sustainability Could move more quickly Drayage Truck Rule independent Avoids gift of public funds owner/operators issue Greater long term Easier to achieve Strategy sustainability goals Easier to achieve Strategy Ability to limit number of goals concessions issued and Ability to limit number manage fleet size issued to manage fleet size Cons Likely to cause delays in Gift of public funds issue Very administratively Possible interference with sending/receiving Would increase cost of complex National Labor Relations containers doing business, but not Port would need Act Unhappy customers and likely to divert cargo Legislative authority Very administratively truckers Doesn't meet the Port's Overarching legal issues complex Potential anti-trust goal of being clean and Port would need considerations green Legislative authority Could be seen as Port Administratively complex Overarching legal issues exceeding authority Port would need Terminals want "hold Legislative authority harmless" from Port Overarching legal issues Overarching legal issues 24 Next Steps and ScheduleNext Steps and Schedule November 2008November 2008 First meeting of Advisory Group First meeting of Advisory Group December 2008December 2008 Second meeting of Advisory Group Second meeting of Advisory Group January 2009January 2009 Third meeting of Advisory Group (if needed) Third meeting of Advisory Group (if needed) 1-2 briefings to Commission (as needed) 1-2 briefings to Commission (as needed) Public comment period starts Public comment period starts February/March 2009February/March 2009 Staff presents final recommendations to Commission Staff presents final recommendations to Commission 25
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