Green Yachts is pleased to submit six policy recommendations
that we believe would accelerate California's transition to a
decarbonized future by faciliating the transition to zero-emission
technology in the marine sector.
The six policy recommendations listed below are detailed in the
attached document with explanation, analysis and rationale for
each.
Recommendation #1: Regarding CORE and any
future CARB funding program, treat zero-emission platforms
differently than ICE platforms. A zero-emission platform on a
vessel that is augmented by an ICE generator is still the platform
for a decarbonized future that is easily modified as technology
develops. This is consistent with state policy in the state of
Washington and could begin to create a national standard that
advances zero-emission platforms.
Recommendation #2: Change surplus emissions
funding strategy because it doesn’t work for zero-emission
requirements and it punishes vessel operators who have upgraded to
cleaner engines.
Recommendation #3: Create a valuation for GHG
emission reductions in Moyer funding and all California funding
programs.
Recommendation #4: Update
Moyer funding guidelines for zero-emission (labeled as hybrid in
the Moyer guidelines) projects so that total cost of a
zero-emission project is eligible.
Recommendation #5: Due to the
high cost and long time-frames of a zero-emission repower,
distribute funding during the conversion to zero-emission platform
at defined project milestones instead of as one lump reimbursement
at project completion. Or as a lesser substitute, provide a
zero-interest loan until project completion.
Recommendation #6: Transfer
clean engines to recipient vessels in developing nations or states
with no/low emission standards instead of spiking them.