Comment Log Display

Dear Chair Randolph and Members of the Board,
On behalf of Ocean Conservancy, please find attached 244 comments
from Ocean Conservancy's Californian ocean advocates encouraging
adoption of a strong harbor craft rule. 

I appreciate that this rule includes a first-in-the-nation
requirement for almost 200 vessels to zero-emissions vessels by
2030. While this is a key step, CARB should expand the scope of
their considerations to include other harbor craft segments such as
ferries, tugboats, dredges, and barges. Giving these segments a
zero-emissions target by 2035 would provide a clear regulatory
trajectory for owners. Taking this step, and ultimately taking
similar steps for all components of the maritime sector as this
becomes technologically feasible, is essential to the ultimate
decarbonization of the maritime sector. It is also essential that
CARB provides the necessary avenues to funding or grants for all
vessel types to meet compliance. 

Creating a market for zero-emissions harbor craft will build a
strong market for next generation vessels here in the United
States, creating new jobs while reducing our impact on the climate
and air quality. Rather than prolonging the use of dirty diesel
engines, California and other states must chart a rapid course away
from fossil fuels altogether. Properly supported by CARB this
transition can be done smoothly and quickly. There are currently
over 300 zero-emission ships powered by batteries in operation in
the world, with another 194 on order. The cost of inaction far
outweighs the price of implementation for this rule, which could
save billions of dollars in averted negative health outcomes alone.


Climate change and its ocean impacts are here now, and promise to
get worse if we do not act. I urge CARB to take action now to
tackle this global threat.

Thank you for your consideration,
Dan Hubbell