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Comment 2434 for Proposed Amendments to Commercial Harbor Craft Regulation (chc2021) - 45 Day.

First NameScott
Last NameSwitzer
Email AddressSWITZERUSA@GMAIL.COM
Affiliation
SubjectPlease don't kill whale watching and sport fishing in California!!
Comment
To the attention of the California Air Resources Board
The new CARB emissions requirements for sportfishing
boats are unfairly targeting two distinct classes: people
who want to fish or whale watch but do not own boats and small
family owned sportfishing boats. 
A large segment of the population does not own boats and
relies on friends with boats, fishing boats and fishing piers
to get out on the water to fish.
Access to sportfishing, diving, whale watching and surfing
the ocean points is a luxury for those boaters that own
boats, whether they are moored, docked or parked in their
drive way.
This very expensive CARB demand targets one of the
smaller vessel groups: family owned sportfishing boats.
The compliance shouldered solely by the sportfishing
industry and coupled with an unreasonable timeline for
compliance with no available parts to remedy the demand.
The technology does not currently exist to accomplish the
new required directives.
The majority of sportfishing boats are older, retrofitting
them is not an option, even if the parts were available.
Their power plants run at much lower rpm's than what
would be necessary for air scrubbers to work without
loading up and damaging the engine.
The time table for compliance is unreasonable,
burdensome and prejudicial.
The sportfishing industry somehow survived the pandemic
and complied with health guidelines for very long and
gradual return to "normal" operations. Coupled with no
business for a year, depleting reserves and no
commitment by CARB to fund grant programs how does
CARB justify issuing new, sudden and drastic compliance
laws. Where is the sensible middle ground?
One solution would be to grandfather in the sport boats
that are operating now and require new sport boat
construction to incorporate the new technology and
comply with the new air quality emission standards.
What is the end game here? Is this an eminent domain
staging for a land grab?
Where is the California Coastal Commission's protection
and defense of access to the ocean for non-boat owners?
Where is the respect, consideration and accommodation
for the sportfishing industry that built and sustained the
waterfront as much as the boatyards, the ship chandleries,
the yacht clubs, the launch ramps?
Please take a step back and help the sportfishing industry.
Thank you. 

Attachment
Original File Name
Date and Time Comment Was Submitted 2021-11-06 17:40:41

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