The Balboa Island Ferry is one of the
15 short-run ferries that will be required to be zero-emission by
December 31, 2025 under the amended Commercial Harborcraft
regulations. Beyond the regulations, we are committed to moving
into the future and being on the right side of history by
converting to electric power. While we have an incredible
historical presence in California as being 100+ year old business,
our focus now shifts to the NEXT 100 years. It is our hope to not
only improve our relationship with the marine ecosystem by
eliminating emissions, but also be at the forefront leading the
maritime community in this transition.
With that in mind we would like to
submit the following recommendations with the intention of better
enabling small business like ourselves to make this dream a reality
of converting our vessel to zero-emission and reducing climate
change in California.
Recommendation #1: As new goals become
a possibility, we ask that there be a reevaluation of Moyer funding
in regards to surplus emissions. As it stands now, Moyer funding is
only available to operators who are able to reduce their emissions
BELOW what is required. That unfortunately eliminates all help for
business that have to reduce to zero emissions. Zero emissions
should be the gold standard we all strive for, but in its current
state Moyer actually disincentivizes such an ideal by only funding
those who reduce instead of eliminate emissions.
Recommendation #2: Include CO2 and CH4
emissions in Moyer funding valuations. Currently there is only
Moyer funding based on a reduction of NOx, ROG, and PM. By
including CO2 and CH4 in Moyer’s emission evaluation, it will
incentivize the industry to move towards zero emissions.
Recommendation #3 Reevaluate dispersal
of to smaller payments based on achieving project milestones.
Currently funding is presented as an end-of-project reimbursement
in one lump sum. While helpful to larger entities that can (at
least temporarily) shoulder the burden of cost for their repower,
it still creates a situation that could be potentially unsurvivable
for smaller qualified groups that can only move forward with at
least partial funding from the start. This is especially true for
zero-emission projects that take longer and cost significantly more
if CARB wants a zero-emission project to be equally viable for a
vessel operator as a diesel repower.
By shifting towards a milestone based
reward system, CARB would actually be making smart, safe
investments that run parallel with demonstrable feedback and
results as repowering moves forward. By incrementally funding from
start to finish using USCG approvals, CARB would also be insulating
itself from possible liability by ensuring only vessels that meet
the USCG’s strictest safety guidelines get funding.
Recommendation 4: Evaluate the need to
bring current Moyer verbiage and categorization up to date by
defining “Zero-Emission Platforms” as its own term and
no longer categorize it under the “Hybrid”
category.
Our hope is, by properly defining a
Zero-emission Platform, total cost of such a massive undertaking
can be properly taken into account for full funding.
Recommendation 5: When converting to a
Zero-emission Platform, it is necessary to take into account the
drastic difference in time needed for conversion compared to a
simple diesel repower. Typically, a vessel is out of service
for half a year to complete conversion, crew training, and
certification by the USCG. Some commercial vessels have taken two
years after the conversion to get the USCG COI. We would like CARB
to consider business lost during this time to be eligible for
funding, so that smaller business like our own can not be
disproportionately disrupted by converting to zero-emission
compared to an operator with half the business disruption doing a
diesel repower.