Comment Log Display

Dear Madam Chair, 

On behalf of the San Diego Regional Chamber of Commerce (Chamber),
whose mission is to make San Diego the best place to do business in
California, I write to you to express our grave concern regarding
the engine emission regulations proposed by the Administration that
will decimate recreational fishing's $5.6 billion annual
contribution to our State's economy and undermine the
Administration's efforts to restore half of the 1.2 million
hospitality and tourism related jobs lost during the COVID-19
pandemic.

The Chamber represents almost 2,500 businesses in the region,
translating to approximately 300,000 jobs. As you well know,
sportfishing and whale watching boats provide coastal communities a
valued source of outdoor recreation and tourism dollars. Their boat
owners are in the business of introducing millions of Americans a
year to the splendor of the open sea and its wildlife.

However, before these boat owners can recover from financial losses
associated with the
pandemic, the California Air Resources Board (CARB) has proposed
costly engine emission
regulations that require technology that has not been developed or
tested safe on passenger
harbor crafts. Similar technology used on trucks and farm equipment
has been known to stall
engines for hours at a time to clean emission control systems, and
in worst case scenarios,
catch fire. On land, a stalled engine or fire is a serious economic
disruption; at sea, it is life
threatening to both passengers and crew.

CARB readily admits the proposed regulations are not compatible
with some vessels,
specifically stating that "vessel replacement will be likely,
especially the categories with wood
or fiberglass vessels." When more than 80 percent of vessels are
constructed with these
materials, industry leaders have reasonably concluded that many, if
not most, boat owners will
go out of business within 6 years from the adoption of the proposed
regulations due to the cost
of vessel replacement.

Moreover, CARB's expectation that these small business owners can
easily finance new steel
vessels is simply unrealistic. Even during the best of economic
times, no business can lose its most valuable asset long before the
end of its useful life and have to completely replace that asset
within six years, especially if their existing vessels, many of
which are still being financed via loans, are deemed illegal and
have no resale value in California.

We share your desire to reduce engine emissions, as do the boat
owners that have been repowering and upgrading their engines for
years. The Administration should consider amending the draft
regulations to incentivize passenger sportfishing and whale
watching boat owners to continue to upgrade their vessels to lower
emission engines, using available technology that is feasible and
does not create safety concerns. This is the reasonable approach
CARB applied to commercial fishing vessels, vessels with engines
that are technically identical to the sportfishing boats.

The Governor has repeatedly underscored the importance of
recreational fishing. It is a great form of outdoor recreation that
is experiencing newfound growth among nontraditional participants
that are younger, more urban, and more diverse with significant
gains among women, African Americans, and Hispanics.

Now more than ever, rebuilding the State's post-pandemic economy is
dependent on continuing this growth and not undermining it by
denying millions of Californians access to offshore fishing and
marine life by putting sportfishing companies out of business or
making excursions unaffordable for disadvantaged communities and
the vast majority of Californians. We understand and respect the
spirit of these proposed new regulations, but the letter of them is
deeply troubling.

Thank you for your consideration. 

Sincerely,
Jerry Sanders
President & CEO
San Diego Regional Chamber of Commerce