Comment Log Display

The proposed equivalent treatment in considering Carl Moyer grants
is ill-advised and ill-timed because:
(i)	30% ZE "capable" is NOT 100 % ZE. There should be different
incentives for 100 % and 30%.; 
(ii)	It's a disincentive to innovate if CARB puts a cap on
development at 30% ZE!
(iii)	It discourages harbor craft operators who have built or are
building 100 %ZE vessels.
(iv)	It disincentivizes harbor craft operators who are planning to
build 100 % ZE vessels.
(v)	It gives the wrong signal to investors to port related ZE
technologies (e.g., green hydrogen, batteries, etc.), and 
(vi)	For California port applications - it's ill-timed and hugely
undermines the goals and mission of California's Hydrogen Hub.   

Further,  
(i)	the path proposed by CARB to qualify for 30% ZE status looks
like an open invitation to be gamed, and
(ii)	the rule enforcement path proposed by CARB is also wide open
to game the rule;
(iii) As written it is impossible to monitor and control unless
CARB's Enforcement Division staff is seriously augmented. 
It's well known throughout the industry that CARB lacks the
enforcement ability and that non-compliant vessels operate with
impunity throughout the state.

Otherwise put, the 30 % ZE CARB carrot - even though it's a
poisoned carrot - is way too tempting  - and the CARB stick is way
too short.

And if you do insist to include a 30% ZE claus4e - first prove that
it works before you open the barn door. 

Thank you for considering these objections to the 30% ZE
equivalency clause.