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I am writing to express my resistance for the proposed amendments
on the Commercial Harbor Craft Regulation. I am a tax paying
citizen in San Diego county, working for a prominent biotech
company. As someone close to the problem of air quality and effects
on long-term healthcare, I certainly can appreciate the impact of a
zero emission goal for the state. I love California; I plan to live
here for the rest of my life and raise a family here. I go fishing
on charter boats regularly, at least 2x per month. The ability to
go on a charter has many profound environmental benefits. The
ability to go on a charter means I do not need to purchase a boat,
which would cause GREATER air pollution than a charter boat if you
consider how many fishermen regularly depart on these (20-40
fishermen means 20-40 boats that aren't on the water). Consider
also these are blue collar business owner/operators who rely on low
ticket price to sustain their businesses. Many of the modifications
proposed will drive these captains out of business. The net result
will be for more individual fishermen to purchase individual boats.
Many individual boats will lead to more environment impact than a
single large boat. Your analysis is confounded and not taking into
account this impact, which is a net negative for the environment.
Instead consider gradually improving emission standards for the
commercial harbor craft regulation. We can achieve lowering
emission standards without substantially impacting a business which
would in turn drive customers to purchase their own watercraft,
thus having a net negative impact. The state should consider tax
incentives for commercial harbor craft to buy engines that meet
your proposed emission standards. There is significant income
generated from these trips that are taxed. If taxes are waived when
a new engine is installed, there is no impact to the business. The
taxes to the state are reduced, and while the state may not be able
to write a 300 page report + multiple appendices of the same length
with significant state hours required to compile and analyze data,
the money goes directly to supporting the goal of zero emissions.
As a former employee of the Federal Government, I have seen how tax
incentives can be more efficiently deployed if the government had
less of a need to sustain these types of analyses. We should all
work together to support the goal of zero emissions, including the
state, and the impact cannot solely be felt by business owners and
taxpayers. The state must bear a load as well through incentivizing
better emission standards, which means less income, which means the
state must become more efficient. Thank you for considering this
comment.