Comment Log Display

Dear California Air Resources Board Members,
	Sportfishing and whale watching boats are not only valued sources
of outdoor recreation, but they are important economic contributors
to California's coastal communities and their tourist industries.
Commercial passenger boats only represent less than 10% of all
harbor crafts, yet these local small businesses draw in hundreds of
thousands of visitors each year. These businesses have contributed
$5.6 billion a year in economic activity and have supported nearly
40,000 jobs in California. The tourism industry is just beginning
to recover from the devastating impacts of the pandemic, and before
these commercial passenger boat businesses have been able to
recuperate the California Air Resources Board is proposing costly
engine emission regulations.
	These proposed regulations will require technology that has not
yet been developed for use on commercial fishing vessels. The
modifications needed to comply with this regulation are often too
large to fit in existing engine rooms. Even in the cases where the
modifications fit, the California State University of Maritime
Academy concluded that the modifications would significantly impact
vessel stability. Boat owners have many safety concerns beyond
stability issues. There has been little testing done at sea for
engines with DPF's. It is concerning that the U.S. Coast Guard has
not been included in discussions regarding the safety of these
regulations, considering they are responsible for regulating the
safety of commercial passenger vessels.
	The California Air Resources Board has concluded that wood and
fiberglass boats will likely have to be removed from service. Over
80% of commercial passenger boats are constructed of wood and
fiberglass and owners will be required to purchase new metal boats
as soon as 2023. With small businesses continuing to recover from
the pandemic, the costs associated with this regulation would
likely put many commercial passenger boat companies out of
business.
	While we should embrace the need to reduce engine emissions, we
encourage the California Air Resources Board to find a way to do so
that does not place additional burden upon our local small business
boating operations. There must be a solution that is both
economically viable and environmentally sound. This regulation
feels rushed and has not done enough to address the realistic and
valid concerns of the passenger boat industry. We hope that the
California Air Resources Board will choose not to adopt these new
regulations, and instead take the time to find a solution that does
not threaten the important passenger boats that help our coastal
communities thrive.

Sincerely,
Santa Barbara South Coast Chamber of Commerce