| Comment | The CARB regulation should be Technology Neutral as to how
emissions from ships are reduced.
Ø Level the playing field for all technologies to be
implemented.
Ø The proposed regulation allows industry to postpone
emission reductions until 2014 when utility based grid power is
available.
Ø Establish equal timelines based on emissions reductions
regardless of the technology.
Ø Establish an emissions credit bank for early compliance.
Ø Many solutions are available today, we shouldn’t have to
wait for grid power promises
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