Comment Log Display

Dear Board Chair:

With regard to the subject proposed regulation, we believe the
intent of the regulation is to reduce greenhouse gas emissions from
existing and future marine craft.  While to many this may be a
worthwhile and lofty goal to "do their part" in reducing
atmospheric CO2, the risk versus reward does not appear to justify
the action.  The emission produced by the marine craft fleet,
especially the small recreational and commercial craft fleet is but
a mere fraction (drop in the bucket) of total greenhouse emission
produced by all other forms of transportation in California.  The
consequences of these regulations will be punitive not only to
commercial businesses, their employees, and supporting business
services dependent upon commercial harbor craft, but also to all
those that utilize such services including poor and under served
communities. Many commercial craft that are involved in
recreational fishing for example provide recreational opportunities
for poor and under served communities, especially children.  Many
sportboat operators provide charity charters for inner-city youth
to give them a once in a lifetime opportunity to fish, whale watch,
or conduct marine science aboard a recreational-commercial vessel
(RV). Enacting regulations that impose requirements that will
essentially put them out of business for negligible environmental
benefits is illogical if not unjust.  The state of the science and
industry for propulsion replacement from gas or diesel to all
electric is just not their.  The range of such craft is a fraction
of what a diesel engine can produce.  The battery cell size needed
would likely take up the vast capacity of the craft to make it
practical, thus making it impractical.  The regulations proposed
may be considered a step in the right direction with regard to
reducing C02 emissions, however, now is not the time.  We need to
let the "state of the science" catch up with the proposed
regulation.  Putting thousands of people out of work and killing a
multibillion dollar part of our economy for negligible
environmental benefits is not in the best interests of California. 
Thank you for your consideration.