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Comment 410 for Proposed Amendments to Commercial Harbor Craft Regulation (chc2021) - 45 Day.

First Namechris
Last Namelatorre
Email Addresschris.latorre@gmail.com
Affiliation
Subjectnew regulations on ocean boat owners
Comment
Here is a partial clip of an article written by a couple of local
boat owners. It pretty much covers everything. I wish to express my
dissatisfaction with these potential new rules.


"For as long as most people can remember, local passenger
sportfishing, whale watching and eco-tourism
boats have been introducing Californians to the Channel Islands,
drawing thousands of visitors a year to
our coastline.
However, this could soon change. The COVID-19 pandemic decimated
the region's tourism and

hospitality industry, reducing visitor spending and erasing years
of economic gain. Fortunately, family-
owned boat businesses such as ours have been able to sustain
operations. However, there is a looming

threat to our livelihood that will achieve what COVID-19 did not --
put us out of business.
Even though boat owners have been proactively reducing emissions by
repowering their engines to the
cleanest marine engines on the market today, the California Air
Resources Board (CARB), a board
appointed by Governor Newsom, has proposed engine emission
regulations that require technology not
developed for commercial passenger vessels, nor deemed safe at
sea.
What's more, CARB concluded that the modifications they require are
not structurally safe for some
types of boats, leading them to conclude that "vessel replacement
will be likely, especially the
categories with wood or fiberglass vessels." This is a stunning
admission, for more than 80% of all
passenger sportfishing and whale watching boats are made from these
materials.
So, CARB has concluded that boat owners like us should be mandated
to build new boats as soon as
2023, which would at least double the cost of passenger tickets.
Our existing boats will be deemed
illegal and have no resale value. Even in the best of times, no
small business can have their most
valuable asset made worthless and then be told to go find an
additional loan to rebuild their business.
Then there are the unresolved safety issues. CARB's regulations
require engines to have equipment
installed that has not been thoroughly tested at sea. It is common
for this type of equipment on trucks
and farm equipment to create significant heat and severe back
pressure on engines. Blocked exhaust
systems may be manageable on land, but not at sea. Passengers could
be adrift at sea for hours as boat
crews try to recover the system. The worst-case scenario of a
failed engine would risk the lives of
passengers and crew."

Attachment
Original File Name
Date and Time Comment Was Submitted 2021-10-04 13:57:04

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