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to whom it may concern,

We urge CARB to require 100% zero-emissions deadline for all vessel
segments of the Commercial Harbor Craft Rule, with a waiver for
specific vessel segments as needed.

NAVTEK Naval Technologies Inc. is a R&D based naval engineering and
design company committed to transforming the carbon intensive
shipping to near-future zero-emission maritime sector.   
Over 40 years, NAVTEK has grown into a highly specialist naval
engineering, design, and shipbuilding company, guided by a
commitment to technological excellence and an innovative
forward-looking approach.  NAVTEK is a well experienced company in
the maritime sector and in innovative marine technologies including
energy, fully electrical marine vessels, renewable energy, low
carbon shipping-port development.
 
The electrification for marine vessels has now been considered as a
proven technology contributing to a decarbonized sustainable
maritime sector. We are witnessing a fast-evolving climate friendly
global technological shift that requires more integrated approaches
entailing alternative fuels, wind and solar energy, renewable
hydrogen, fuel-cell technologies, zero emission dockyards,
autonomous vessels, and many more to overcome the evidence based
expected ecological catastrophe.
 
NAVTEK was the builder and designer of the all-electric GisasPower
tugboat (ZEETUG30). The prototype has been delivered in early 2020
and successfully delivered the heavy-duty daily operations since
then. We have 3 more ZEETUG's under construction.

NAVTEK ZEE-TECH represents the new generation green and high
technology by being re-chargeable and fully electric with almost no
noise and vibration. This innovative design allows the vessels to
operate powerful with higher efficiency in line with not harming
the environment (emission free). The NAVTEK rechargeable and all
electric battery driven technology can be adapted to any short
distance operation profiled vessel (ferry, sea-taxi, workboats and
such). 

We appreciate the work that CARB staff have done on the proposal.
However, the draft rule as written is short-sighted. The rule does
not reduce greenhouse gas emissions and risks creating a stranded
asset scenario for harbour craft owners who may pay to retrofit to
Tier 3 and 4 engines only to be forced to make a full zero-emission
transition in quickly proceeding years later. 
For the marine sector, a strong but achievable standard would be
that all harbour craft operating in the state must be zero
emission.