Comment Log Display

As a small business owner I am urging CARB to consider accepting
SACs proposed compromise on TIER 4 engines. While I do agree and
support CARBs mission of improving air quality, this uncompromising
approach of requiring TIER 4 engines on CFPVs for the following
reasons.
1. TIER 4 engines are unavailable for my size boat. There is not a
TIER 4 engine in existence that will fit inside a vessel of my
size. CARB acknowledges this, yet still is proposing that we be
required to put a piece of technology that doesn't exist in our
vessels
2. TIER 4 engines that do exist in other capacities are extremely
dangerous. These engines produce exhaust gases in excess of 1500
degrees. The fire hazards are extremely high. We have seen the
consequences of a fire on a small wooden boat with the recent
conception tragedy. If TIER 4 engines are implemented risk of
tragedies like the Conception will increase dramatically. In
addition the menus one control technology is very unreliable. This
isn't acceptable 100 miles out at sea. There are times where my
passengers and crews lives are relying on our propulsion to keep us
safe. If CARB does implement this rules the board members will have
to live with themselves if a tragedy is related to the use of this
TIER 4 technology. Business owners faced with the prospect of
losing their livelihoods in an effort to comply will put this
dangerous technology on their boat.
3. Perhaps the most important and overriding factor as to why
people like me are objecting CARBs proposal is the cost . For
myself and at least 3/4s of my colleagues the cost of
implementation is many times greater then what my business is
worth. My vessel of wood and fiberglass construction simply will
not be able to handle the extremely hot exhaust gases of a TIER 4
engine without being a fire hazard. The cost of replacing my boat
with a new one will be in excess of 2 million dollars and take 2-4
years. That is if I can find a boat yard that is able to build my
vessel.

4. Most CFPVs spend less then 20% of their time in state waters. I
cannot Understand why CARB is willing to put small business owner
out of business while hundred of commercial ships that do not
comply with TIER 4 spend days anchored up in state waters producing
hundreds or thousands of times of pollutants then a CFPV. If CARB
was actually concerned with cleaning the air they would focus on
alleviating congestion at our ports.

As an alternative to blanket requirements of TIER 4 engines I would
like to propose a smart time line of requiring vessels to be fitted
with TIER 3 engines. TIER 3 engines are readily available, proven,
reliable and safe to use in our vessels. In addition to fitting
into our vessels without modification, they are clean. A TIER 3
engine produces about 1/5th the NOX and carbon monoxide of an older
pre tier engine. TIER 3 engines are far less polluting then the
class of engines on foreign commercial ships that regularly dock in
our California ports.  This alternative would allow the multi
billion dollar Sportfishing business that provides thousands of
jobs to stay in business and would allow business owners such as
myself to not lose their livelihoods and life's work. 

Sincerely,
Jason Zenor
Owner/ Operator MV Pride