Comment Log Display

Chairperson Randolph and Board Members:

My name is Ray Carpenter, and I would like to submit these written
comments in-lieu of live public comments today. I would like my
comments incorporated into the public record. 

I am the President of R.E. Staite Engineering, Inc., a heavy marine
construction and dredging company headquartered in San Diego. My
company is a small family business that has been in operation over
80 years, since 1938. My company has tug boats, dredges, work boats
and barges that will all be impacted by the CHC Proposed
Amendments.  This equipment is integral in the performance of new
construction, repair and maintenance of essential marine
infrastructure for governmental agencies, ports, cities and private
entities along the west coast.

Governor Newsom's Executive Order N-79-20 directed CARB and other
State agencies to transition off-road vehicles and equipment to 100
percent zero-emission by 2035 where feasible and cost effective.
The CHC Proposed Amendments are not feasible, nor cost effective as
required by the Governor's Executive Order. R.E. Staite requests
that the Board deny the CHC Proposed Amendments; if not deny, then
suspend the rulemaking and direct Staff to work with the maritime
industry to develop reasonable, workable regulations that take into
consideration how harbor craft are used in the real world.

Our company has gone out of its way to share company information
and suggest solutions that will make a difference. As a small
business, we do not feel heard or understood. We are extremely
disappointed to see that our company data was incorporated into the
Standardized Regulatory Impact Assessment (SRIA), but that none of
our concerns about safety, practicality, cost or feasibility have
been addressed. We would like to make it clear that our company has
invested millions of dollars since 2009 in up-tiering our equipment
to Tiers 2 and 3 and 4 levels. The goal posts keep moving,
guaranteeing that small business can't keep up with each new and
different requirement imposed by CARB. 

I submitted a letter dated November 15, 2021 that provides
information regarding my company and outlines my specific concerns
and suggested solutions. The CHC Proposed Amendments are not a
workable roadmap for my company or other small family businesses in
California. It is almost certain that my company will go out of
business if the Amendments, as proposed, are adopted. Thousands of
jobs will be lost when you take into consideration our company and
the other small businesses affected by the Amendments. 

We need workable regulations that take our specific harbor craft,
work activities and vessel limitations into consideration. The
Board needs to recognize how much time it takes to go from one
industrial energy source to another. We need a workable timeline
for implementation and enough funding to assist with compliance so
that R.E. Staite Engineering, Inc., and others in the maritime
industry, can continue to contribute to the California economy.

Thank you for your consideration.

R.E. STAITE ENGINEERING, INC.

R.A. Carpenter
President