Dear Representative Sires and Representative Payne,

RE: Port Drayage Trucks Serving Port Elizabeth and Newark

This is in response to your recent letter to Governor Murphy suggesting that port drayage trucks 2006 and older be banned from Port Newark and Elizabeth. We as a group represent the port community including the drayage trucking industry, owner-operators, terminal operators, labor and shippers - all of whom depend on the success of the ports in Newark and Elizabeth.

Over the past several years, there has been a substantial amount of misinformation regarding port drayage trucks and their emissions in the port region. Facts matter.

We are not diminishing the impact that emissions have on the port region; however, focusing only on one source--which in comparison to others is the smallest contributor--is unfair. A significant amount of effort has been and continues to be done to reduce emissions from all sources at the port, including port drayage trucks.  Please consider the following:

n  Port drayage trucks make up less than 4% of all trucks and 1% of all vehicles on the regional roadways.

n  In 2017 there were 12,845 trucks registered with the PANYNJ serving the ports. Of those trucks, 46% (5,908) were already "clean trucks" (2007 engine model or newer).

n  Since March 2016, only trucks with engine model years 2007 or newer can register to work in the ports.

n  In 2018, the 1994 & 1995 engine models were banned from serving the Port of NY & NJ, further reducing the number of older trucks, increasing the percentage of clean trucks to 47%. The number of older trucks will continue to shrink due to natural attrition, drivers retiring, relocating, and voluntary utilization of truck replacement programs.

• n  If the 6,642 pre-2007 trucks currently serving the port were banned next week, it would result in a port-wide shut-down. Those truckers could easily work on the domestic freight side and keep their trucks, which are legally registered to operate in the United States and fully compliant with EPA standards.
• n  The driver shortage throughout the industry is real. It is already difficult to find truck drivers. Eliminating a significant percentage of drivers from operating at the port would be a disaster.

Considering the thousands of cars and non-port trucks that pass through the port region, along with other emission generating factors (power plants, oil boilers, garbage incinerators, refineries, airport, NJ Turnpike), it is difficult to believe that the current older trucks serving the port are having the such an impact that they should be banned while other emission generators can reduce their emissions via voluntary programs.

We all want to have clean air. The question is … is it fair to make a handful of port drayage truck owners lose their businesses and income when they represent a mere fraction of the actual emissions that exist? No other entity is being asked to make such a sacrifice, and being made to suffer so disproportionately.

Your proposal to ban all 2006 and older trucks from the port would do irreparable harm, not only to the port drayage truck owners, but to the viability of Port Newark and Elizabeth. We are all committed to working with you and other interested parties to find sensible, voluntary solutions to continue to mitigate emissions in and around the port.

Sincerely,

New Jersey Motor Truck Association

Association of Bi-State Motor Carriers

New York Shipping Association, Inc.

Port Drivers Association

New Jersey Retail Merchants Association

Maritime Association of the Port of New York/New Jersey