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

First NameDavid
Last NameRosenthal
Email AddressTorquemobphotos@gmail.com
Affiliation
SubjectCARB Regulations & Sportfishing
Comment
To Governor Newsom, The California Air Resources Board and everyone
else involved with this proposal,

I am a member of the Sportfishing community as an employee in the
Sportfishing business, as a fisherman and as a local and state
representative of a major coastal conservation organization. This
letter is to express my concerns about the pending emissions
regulations being proposed for Sport fishing Boats in California.
There are many reasons this proposed legislation is flawed:

1.) One of the biggest flaws is the fact that the proponents of
this legislation have not given adequate consideration to the
overall economic impact this legislation will cause to the
Sportfishing industry and the overall loss of tax revenue to the
state of California. The California recreational Sport Fishing
industry generates over 5.6 billion dollars annually and is
responsible for the livelihood of thousands of people and their
families. The proposed legislation would be devastating to not only
the fishing industry but to the lives of many.

2.) The proposed technology for the Diesel Particulate Filter (DPF)
does not exist and due to non existence, has not been approved by
the U.S. Coast Guard. 

3.) The proposed technology has not been tested and has not been
proven to be safe for use at sea. This could lead to putting human
lives in danger.

4.) The California State University Maritime Academy has concluded
that the suggested standards for existing engines does not exist.
In the alternative, treatment equipment (modifications) alone will
significantly impact a vessel's stability.

5.) Over 80% of the existing Sport Fishing fleet is constructed of
wood, fiberglass and combinations of said materials. Boats built of
these materials would not be safe to operate if they could be
retrofitted with proposed emissions devices. The result of the
newly proposed emissions devices would require boats currently
being used, to be replaced with boats made of steel hulls. This
requirement would force most sport fleet operators out of business
as the cost of this would be untenable. 

Please apply common sense and logic to this proposal and end this
madness before the wellbeing of those within the the Sportfishing
industry and so many businesses associated with the Sport Fishing
industry are bankrupted and forced out of business. Please realize
the loss to the entire state if this incompetent proposal is to go
forward. 

Sincerely,
David Rosenthal 

Attachment
Original File Name
Date and Time Comment Was Submitted 2021-11-15 13:51:23

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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