Comment Log Display

ATTN: Ms. Liane Randolph, 
Chair California Air Resources Board,

        I would very much like to briefly address severe concerns
with the proposed amendments to CHC regulations on behalf of
Relentless Charters, our employees, our customers, my family, and
all that have supported us in our seven year existence.
	I am an independently owned small business operating out of
picturesque San Diego, encompassing operations from commercial
sportfishing, whale watching, bird watching, floating classroom
education, and marine research. We specialize in commercial
sportfishing off the coast of Southern California and Northern
Baja. I have worked in industry since graduating high school in
2005, became a licensed 100T Master (United States Coast Guard
licensed Captain) in 2007, started running boats in 2009, and very
proudly entered vessel ownership in 2015. I have spent 16 years
invested in the maritime community here in Southern California and
owe everything I have ever done professionally to the opportunities
we are so fortunate to have available here in California through
our access to the Pacific Ocean. It has been an extremely
challenging, yet invigorating journey thus far. The support from
family, friends, neighbors, customers, and many more have been
beyond humbling. The vessel Relentless is a 57'x19'
plywood/fiberglass USCG inspected passenger carrying vessel. We are
currently capable of sleeping up to 21 passengers, in addition to 5
crew, and operate on trips from a few hours to 3 days. We have
carried local school groups out to experience the beauty and
mystique of the Pacific for the first time, we have had trips of
family meeting each other from all across the nation, we have laid
our nations best to rest. The diversity of the business and our
client base is absolutely awe inspiring. We have celebrated the
elation of a father and son catching a fish together for the first
time, and we have piously celebrated the last birthday of a
terminally ill passengers with his brothers and friends. It is
again humbling, intimidatingly so, to look back at 7 years of trips
and to think that our existence on the Relentless has made a
difference. From the local high school fishing club to out of state
business and tourist events, we are proudly a viable part of the
San Diego waterfront economy and look forward to continuing to be.
To say that our survival has been guaranteed is a gross
misconception. We are still in recovery from the fallout from the
Covid-19 pandemic, as are most all small business, economic
hardship, rising fuel and overhead costs, inflation, these are all
current concerns to all. However, nothing means our imminent demise
as does the proposed Commercial Harbor Craft regulations. 

	We have a wonderful working relationship with the United States
Coast Guard, both locally and in Washington. As an inspected vessel
we are exactly that, inspected thoroughly bi-annually by the USCG.
Under the proposed amendments to CHC, there is no possible way to
remain an inspected passenger carrying vessel and maintain
compliance with CHC regulations. USCG at both the local and
national level has concerns with both stability and heat generation
of required machinery under the proposed regulations. We certainly
share the same interest with CARB for protecting the vitality of
our coastal and offshore waters. Without such a biodiverse aquatic
ecosystem we have nothing special about our business, however these
proposed amendments would put me and my family out of business
permanently. We are in the process of attempting to use the Carl
Moyer Grant program to upgrade to Tier 3 emission motors. We
already applied last year with the San Diego County Air Pollution
District and were not funded on our project. We currently are
reapplying with the help of Robert Mercado and Heidi Gabriel-Pack
to hopefully achieve funding to upgrade to cleaner power for the
vessel Relentless. Currently all revenue generated by the business
has been allocated to just staying above water. Vessel mortgage,
insurance, documentation/permit fees, and vessel maintenance are
all critical to our operations and have allowed no funding
available for out-of-pocket machinery upgrades. Without the ability
for the vessel to operate as an inspected passenger carrying vessel
in California, it unfortunately has very little value. I would lose
virtually everything, not from a failed economy, not from a lack of
business, not from failed fiscal practices, not from Covid-19, but
from an inability to remain compliant with CARB. 
We absolutely need support from the board in staying afloat. We are
registered with both the National Oceanic and Atmospheric
Administration as well as California Fish & Wildlife as a
commercial fishing vessel. We fill out commercial take logbooks for
CA F&W, and are recognized by state and federal agencies as a
commercial vessel with commercial registration numbers. As a fleet
we have done upgraded our fleet to newer and cleaner marine power
than much of the commercial fleet. Why are we not allowed within
the same exemptions and considerations? Without such understanding
and continued cooperation between CARB and the CFPV fleet, then
unfortunately I am one of many whose business is likely to fail or
leave California. My employees will join the ranks of unemployed.
The contractors and businesses that support us (i.e. boatyards,
mechanics, electricians, wholesalers, fish processors, hotels,
restaurants, etc.) will all suffer. I vehement hope there is an
alternate course we can take. 
     

          Sincerely, 
Michael Franchak
Relentless Charters
619-818-5664