Comment Log Display

Ms. Liane Randolph, Chair
California Air Resources Board, c/o chc2021, 1001 I (eye) Street,
Sacramento, CA 95814

Ahoy there,
My name is Captain William Smith of the vessel and company RIPTIDE
CHARTERS. 
I have owned and operated my business since 1998 as a sole
proprietor and this is how I feed my family and pay my bills and
operate my business. 
I am in the process of repowering my vessel (RIPTIDE) to a tier 3
engine. I am committed to reducing emissions with his expensive
project. I am doing this to comply with regulations and to be able
to continue my business to pay my bills.
The regulations as drafted require technology that has not been
developed or proven safe at sea, and consequently are economically
and structurally impossible to comply with - requiring boats
constructed of wood/fiberglass to be removed from service as soon
as 2031.
Timing could not be worse. With the COVID-19 pandemic came economic
consequences and now we are expected to finance a new boat and have
it in operation no later than 2034.We can't afford a new metal
boat. Few financial institutions will approve a loan when my
existing boat has no resale value in California after being deemed
non-compliant.
A very large portion of my business is SEA BURIALS. This is partly
done as a public service to offer families a way to inter their
loved ones in the ocean. It is a viable alternative to cemeteries
both for economic and for religious purposes. This is a vital
public service for families to help with the closure of there loved
one's life. Yes, we also operate fishing and whale watching
charters as well. These trips help to bolster our local community
with the support of hotels and restaurants and stores as these
clients spend many dollars in the local community.

Historically, CARB has regulated commercial fishing/whale watching
boats
and commercial passenger boats the same way - their engines are
technically identical. CARB's proposed regulations apply a double
standard with commercial fishing boats subject to substantially
less stringent and less costly requirements. CARB should return
passenger boats to the same vessel category as commercial fishing
boats so that we can continue to transition to lower emission
engines as it is economically feasible, and technology becomes
available.

I have worked on the ocean for 50 years. To lose my business would
be financially devastating and would force me onto welfare. I am 68
years old, and this is all I have done for my working career.

Capt. Smitty
www.riptide.net
650-728-8433
888- RIPTIDE