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Hello - it is important that staff conduct several CE
calculations for the marine industry so they can understand the
limitations posed by the upcoming CHC regulation.  Once of
which is meeting the CE cap of $30,000 / ton of emission
recutions.  This CE cap MUST be increased similar to the other
industries if CMP is going to serve as an aid in early compliance
and upgrades.   Many of the vessels will have 1-2 year
project lives.  Those that would have longer may have
contracts already in place for their Tier 3 engines, so we will see
more interest in destroying recently funded 2018-2021 model year
engines in order to get a higher funding percentage with the longer
project life.  This will pose problems for the local air
districts, with several applicants reqeusting to be released from
contractual obligations so funding can be taken advantage of for
the Tier 4 engines.  This is a serious problem that must be
addressed.  Please see the emails sent to CARB regulatory and
CMP staff.