Exh D

Port of Seattle Commission Special Meeting
February loth,2009
Comments for Submission to the Record
Joe Rinzel, Vice President, State Government Relations
Retail Industry Leaders Association
1700 North Moore Street, Suite 2250
Arlington, Virginia 22209
703.600.2053
joe.rinzel@rila.org

On behalf of the Retail Industry Leaders Association, I would like 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.
By way of background, the Retail Industry Leaders Association (RILA) is a national trade
association of 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.
Many of our member companies are also affiliated with the Coalition for Responsible
Transportation (CRT), which is committed to being a responsible steward of the environment by
facilitating the implementation of practical and sustainable solutions that reduce port truck
pollution at our nation's blue water ports without disrupting the flow of commerce.
The Coalition for Responsible Transportation was formed in 2007 as a cooperative effort to work
with industry stakeholders to begin to provide an intelligent, industry led response toward
improving air quality in and around our nation's ports. Working together we canand will build
an environmentally sound marine transportation system for the 21'' Century
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 advantage over other west coast ports.
RILA's members, who areamong the largest shippers through the Port of Seattle, urge you to
continue to not include fees on industry stakeholders to fund truck replacement programs. The
ports of Los Angeles and Long Beach will soon implement a $70/FEU fee to help fund clean
trucks. In our view, this has in part led to the movement of some discretionary cargo out of
LAILB and into other "fee fiee" ports such as Tacoma and Seattle.
Mandatory fees may void investments 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 identify 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 and 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 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 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's 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 we have heard
from today.
Many independent owner operators, such as those here today, 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
financing business or to impose any fees or employee mandates. Many of RILA'smembers
have negotiated rates at the ports of LA and Long Beach with their individual trucking providers
that allow for the purchase of new, clean equipment that is totally privately funded.
In these tough economic times it is extremely important to approach worthy environmental
mitigation issues such as this one with careful 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.
I would like to thank you for allowing me to share the Retail Industry Leaders Association's
views concerning a way forward to reduce truck emissions. Once again, 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 confident that industry stakeholders will find the most
efficient means of complying with the rule so as to maintain the region's competitive advantage,

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