Please change the definition of a short-run ferry in the
proposed harborcraft regulations so that a boat that operates
with a diesel engine cannot add multiple legs or add one long leg
in order to avoid the requirements that a short-run ferry be zero
emission. As written, the regulations will cause boat operators to
game the regulations by running more and longer routes and this
will increase CO2emissions by thousands of tons in the Bay Area and this
is wrong. Zero-emission regulations should reduce CO2 emissions not increase them. Please make it
that everyone running a vessel on a short-run route has to follow
the same regulations and be zero-emission without loopholes. That's
only fair and also will ensure the proposed
regulations reduce CO2 emissions created by ferries in the San Francisco
Bay.
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