January 15, 2010

Sean Ardussi,
Senior Planner
Puget Sound Regional Council

Via Email: sardussi@psrc.org

RE: DRAFT Regional Freight Strategy

Dear Mr. Ardussi,

Thank you for the opportunity to participate in the continuing development of the
Regional Freight Strategy, as an element of Transportation 2040.

Systems Approach

The Chamber suggests that a systems outlook to transportation and logistics needs to be
the guiding principle. Economic regions are not respectful of political entities’
boundaries. The most obvious example in the present context is the exclusion of
Thurston County’s transportation intertie with the PSRC boundaries. (The Strategy does
sometimes recognize the regional economic system when it treats the Military Transport
System, (Executive Summary, Figure 3) and Stampede Pass.

Regional Freight Mobility

The South Puget Sound economy is largely dependant on warehousing and
manufacturing activities related to the movement of goods through the Port of Tacoma
plus commuter and freight transportation associated with Ft. Lewis and McChord AFB
(the future Joint Base Lewis-McChord [JBLM] ). The South Puget Sound is one of the
few communities in the country with an incomplete highway system. The completion of
State Route 167 and State Route 509 is crucial to the efficient movement of people and
goods to promote economic growth. Similarly, building State Route 704, the Cross-base
Highway, the intrabase tie and associated I-5 improvements will provide a direct
connection between Frederickson, Pierce County’s industrial area with the Port of
Tacoma marine-industrial area.

These highway projects will move freight off arterials, easing congestion and improving
travel times. There is no more effective means to promote freight mobility and industrial
job growth than to complete these crucial highway connections. The SR 167 completion
has more economic benefit than any other proposed project according to a Washington
Department of Transportation study. Currently underway, an Office of Economic
Adjustment funded grant administered by the City of Lakewood will document the
impacts and needed improvements associated with the growth of Fort Lewis. These
efforts and results should be included in Regional Freight Strategy.

Military Transport System

The Chamber compliments the PSRC for its inclusion of the Military Transport System
in the Regional Freight Strategy. This defense industry cluster has been targeted by
Pierce County for its development.

Manufacturing Industrial Centers

Tacoma designated the South Tacoma area as a Manufacturing Industrial Center (MIC) in
its Comprehensive Plan. Their next step is to have the South Tacoma MIC designated in
the (Pierce) Countywide Planning Policies. Tacoma is planning to submit an application
to have the South Tacoma MIC designated this year as a possible amendment to the
policies. Once designated in the countywide policies, the South Tacoma MIC becomes
eligible to be submitted to the PSRC for consideration as a regionally designated MIC.
The Regional Freight Strategy should recognize that other MICs may be recognized or
developed and not limit its policy to the eight existing MICs.

Air Quality

Most of the Tacoma metropolitan area is currently designated as a non-attainment area

for PM 2.5. Tacoma’s port-industrial area included, not because its resident monitoring
station was out of compliance, but because the area’s particulate load was assumed to
grow because of a forecast growth in trade,

In addition to most of the Tacoma metro, other parts of the region are perilously close to
designation of non-attainment for PM 2.5 as well. And, the entire region faces a new
federal standard for ozone, with its precursor generation in the urban metro area with the
likely designation of the entire urban region as non-attainment for ozone. Recent
published comments about an appropriate level for ozone standards identify the region as
very likely not to be in compliance.

The Strategy over-emphasizes GHGs and marine sources.

One year after the non-attainment designation for PM-2.5, the area will be subject to the
U.S. Environmental Protection Agency’s Transportation Conformity. Projects that then
receive federal dollars (Federal Highway Administration and Federal Transit
Administration), must comply with EPA’s jurisdiction to achieve attainment. As this
level of pollution has been determined to directly affect the public health in the non-
attainment area, the PSRC must develop a prioritization process which puts regional
highway and transit projects’ contribution to attainment at the head of the line.

Congestion Access and Pricing

Congestion Access and Pricing are not strategies that answer problems without creating
problems themselves. Unintended consequences to these tactics will range from a
shifting by freight carriers to the use of alternative roads to increased demand for
daycare, a lessening of parental support of dependents’ participation in school
extracurricular activities and less parental supervision of homework due to a clash of
personal work schedules. Further, the Strategy should recognize the small business
entrepreneurship in the trucking industry. Ample current events in California have
surfaced many of the concerns with regulatory initiatives that seek to address
environmental issues associated with these small business entrepreneurs, and should be
considered in the Strategy.

Finally, the payments of tolls and fees should benefit the payee as user, not used to
subsidize other users.

Land Use

The Chamber generally applauds the Strategy’s recognition of the value, limitations and
threats to industrial lands. Please note that Sec. 4, Practices, page 18, places an emphasis
on directing industry location with no attention to encroachment/gentrification pressures
from residential, until it addresses Impacts, page 20. It is appropriate to address Practices
in residential land use as it impacts industrial lands.

Two notes on proof-reading:

1. The text needs to capitalize Stampede Pass, Executive Summary, page 7.
2. The Sec. 4, Figure 4.1, pg. 6, should be redrawn so the focus lines extend from the
segment points of the comprehensive “All Transportation” graphic circle as
tangents to the “Freight Transportation” circle.

Sincerely,

Gary D. Brackett, CCR

Manager, Business and Trade

950 PACIFIC AVENUE, SUITE 300, PO BOX 1933, TACOMA WA 98401-1933

PHONE: 253-627-2175, FAX: 253-597-7305, www.tacomachamber.org