Comment Log Display

Dear California Air Resources Board Members,
Prior to the COVID-19 pandemic, recreational fishing contributed
$5.6 billion annually in economic activity, supporting nearly
40,000 California jobs. Sportfishing and whale watching businesses
are also a major contributor to Oceanside's economy, drawing
tourists from all over the world, supporting local jobs and
generating tax revenue for public services. 

The sportfishing industry embraces the need to reduce engine
emissions, securing air quality grants over the years to upgrade
vessels with cleaner burning engines. However, the Oceanside
Chamber of Commerce believes harborcraft engine regulations
recently proposed by the California Air Resources Board (CARB)
place an undue burden on family-owned boating operations.

The California State Maritime Academy concluded in a report
commissioned by CARB that the proposed emission standards cannot be
achieved because Tier Four engines do not exist for use on
harborcraft vessels.  Furthermore, the size and weight of the
proposed diesel particulate filters (DPFs)  would make sportfishing
vessels unstable, posing significant safety concerns for passengers
and crew.  Operational issues with the DPFs could result in
unexpected equipment failure when the boats are out at sea with
passengers.  Rather than trying to find a reasonable alternative
afforded to other vessel categories, CARB responded by stating that
boat operators should purchase new vessels when it is not possible
to reconstruct boat hulls to accommodate the new engines and DPFs.


As a result, in just 18 short months from when the regulations are
scheduled to be implemented later this year, the vast majority of
sportfishing and whale watching vessels will have to be taken out
of service as vessels made of wood and fiberglass cannot be
modified as steel hulls can.  Vessels that can be modified will
incur a significant cost for retrofit and will be faced with the
potential safety issues noted above.

Unfortunately, for many boat owners, the option of financing new
boats is not possible when existing boats will have little to no
resale value once deemed noncompliant in California.  To further
impact boat owner's ability to do business, passenger loads will
have to be reduced by over 40 percent to account for the engine
modifications that are greater in size and weight.

Consequently, the proposed regulations force boat owners into an
unattainable position. They can't afford to purchase new vessels
and reconstructed vessels are too expensive to operate with reduced
passenger loads, resulting in fewer ticket sales and lower revenue.
As a result, the industry strongly believes that the State will run
many boat owners out of business within 3-6 years after the new
regulations are implemented. 

Boat owners also have serious reservations about a host of
unresolved safety concerns that extend beyond the stability of
reconstructed boat hulls.  Engines equipped with DPFs have not been
thoroughly tested at sea. It is common for DPFs used on farm
equipment and trucks to experience blockage, creating significant
heat and severe back pressure on engines, sometimes taking hours to
clear exhaust systems and restart engines. While this circumstance
is manageable on land, under the best-case scenario, passengers
could be adrift at sea for hours as boat crews try to recover the
system. The more likely scenario will result in sea rescues due to
engine failure.  In a surprising omission, CARB has not solicited
the input of the United States Coast Guard which regulates the
safety of commercial passenger vessels.
 
As a community, we share the State's desire to reduce engine
emissions, however, the regulations as drafted will adversely
affect sportfishing and whale watching businesses, and communities
economically dependent on a strong and vibrant hospitality and
tourism industry. This is why we believe the proposed regulations
will undermine your economic plan that aims to rebuild California's
economy and recover 1.2 million tourism and hospitality jobs lost
during the COVID-19 pandemic. 

For the aforementioned reasons, we encourage your Administration to
work with the sportfishing industry to develop air quality
regulations that are economically feasible, take into account
existing technology and not putting the safety of passengers and
crew at risk. 

Thank you for your consideration. 

Sincerely, 

Scott Ashton, CEO
Oceanside Chamber of Commerce