Comment Log Display

Dear Chair Nichols and Board Members,

We understand that the State of California’s Air Resources Board
(CARB) will be developing an investment plan for the auction
proceeds from the cap-and-trade program to meet the goals of
Assembly Bill 32 to improve public health, develop a clean energy
economy and provide additional environmental and public health
benefits.  The National Oceanic and Atmospheric Administration’s
(NOAA) Office of National Marine Sanctuaries, West Coast Region and
National Marine Fisheries Service, Southwest Region support the use
of these proceeds to create an incentive program that rewards large
ocean-going ships for slowing down while transiting off
California’s coast.  We believe this use of the funds could achieve
multiple environmental benefits important to both of our agencies. 


Research has shown that large ocean-going vessels traveling at slow
speeds substantially reduce their greenhouse gas emissions and
nitrogen oxide and sulfur dioxide pollution.  Encouraging ships to
travel at slower than normal speeds can also reduce the
anthropogenic effects on marine mammals by reducing the risk of
lethal strikes and noise pollution in the marine environment. 
Identifying and minimizing impacts to endangered blue, fin and
humpback whales is a priority for NOAA.  We believe that creating
an incentive program to encourage vessels to travel at slow speeds
could be a benefit to the people and the whales offshore of
California.  

To be successful, the development of an incentive based slow speed
initiative will require collaboration with the shipping industry
and other partners.  We have been in discussion with the Santa
Barbara Air Pollution Control District regarding the viability of
this idea and look forward to working with them and CARB to develop
the idea further.  We have reached out to a number of partners,
including the Marine Exchanges of California, the Pacific Merchant
Shipping Association, and the Sanctuary Advisory Council of Channel
Islands National Marine Sanctuary (i), and received general support
for what we all believe is an idea worthy of further consideration
(see attached letter of support).
  
Thank you for your consideration of using cap and trade auction
proceeds to incentivize ocean-going vessels to reduce speed and
greenhouse gas emissions, and to protect endangered whales.  Please
contact Sean Hastings, Channel Islands National Marine Sanctuary,
sean.hastings@noaa.gov or (805) 884-1472 and/or Elizabeth Petras,
National Marine Fisheries Services, Southwest Region,
Elizabeth.petras@noaa.gov or (562)980-3238 if you have any
questions.

Sincerely,

Rodney McInnis							
Regional Administrator						
Southwest Regional Office
National Marine Fisheries Service				
					
William Douros
Regional Director
West Coast Region
Office of National Marine Sanctuaries

cc:
Channel Islands Sanctuary Advisory Council
Louis D. Van Mullem Jr., Air Pollution Control Officer, Santa
Barbara Air Pollution Control District

Enclosure:
Channel Islands Sanctuary Advisory Council Support Letter

i. In 2009, a report endorsed by the Sanctuary Advisory Council of
Channel Islands National Marine Sanctuary recommended that
incentive-based approaches to slow ships down be explored,
specifically, to reduce ship strike risks on endangered whales. 
See: “Reducing the Threat of Ship Strikes on Large Cetaceans in the
Santa Barbara Channel Region and Channel Islands National Marine
Sanctuary: Recommendations and Case Studies” available online at:
http://channelislands.noaa.gov/sac/pdf/sscs10-2-09.pdf.