Comment Log Display

CARB Board and Governor Newsome,

I share Americans concerns on air pollution and its potential
environmental and health threats, but our approach to these
challenges must be both logical and reasonable, especially in our
transition to cleaner forms of mechanical energy.  Your recent
proposals for emission standards for small commercial and fishing
vessels are neither logical nor reasonable.  Exemptions to these
rules have been carved out for military, commercial cargo, and
cruise line ships.  The military exemption is an undesirable but
most necessary action.  However, exempting the massive pollution
and emissions from both cargo ships and large cruise ships, and
instead imposing impossible regulations on the small fishing and
commercial boats, turns a blind eye to the real polluters, and
threatens the livelihoods and survival of small commercial and
fishing boat owners and operators, as well as the industries and
customers that they serve.  

A recent detailed study by the prestigious California Maritime
Academy demonstrated that the engine technology required for small
boats in the proposed regulations DOES NOT CURRENTLY EXIST, and
that the after-market pollution equipment required in their place
present severe stability, fire, safety, and reliability issues.
Many of the affected boats operate many miles from land and often
in isolated conditions.  Vessel stability, fire safety, and
propulsion reliability are ESSENTIAL in these operations.  Imposing
the regulations as currently proposed would place these small boats
and all aboard them squarely in harm's way.

Placing unattainable mandates on small commercial and fishing boats
while exempting the REAL polluters (commercial cargo and cruise
ships), who HAVE the space and capability to safely lower
emissions, is unconscionable in my view, and in the view of many
others.  Rather than penalize (and possibly destroy the lives of)
the owners and operators of small boats with  regulations that
cannot be attained with their current vessels, I suggest that you
drop these regulations, and instead use some of our current
multi-millions of dollars State budget surplus to fund the study
and development of advanced, reliable, and affordable technology to
lessen the emissions from these small boats.  Once proven, the
State could help fund affordable replacement programs for these
boat owners, similar to what has been done for the lower emissions
propulsion engines and generators in recent years.

Don't pick on the "little guys and gals".  Go after the REAL
polluters in the massive cargo and cruise ships, and invest in
technology development for the owners of small commercial and
fishing boats.