Comment Log Display

To Whom It May Concern,

I write this as a former excursion vessel owner/operator that
understands the financial hardships associated with remaining in
this industry. Most of the businesses to be affected are family
owned small businesses. There are few that will be able to absorb
the cost of substantial modification of existing vessel or
construction of a new vessel to meet the letter of CHC2021.

To give you additional context with which to understand my
position, I am an environmental advocate that fully understands the
immediate necessity to move toward carbon neutrality or negativity
by substantial reduction in GHG emissions across the board. Every
little piece of the puzzle is a piece to be addressed, some can be
heavy handed while others need to be on a case by case. CHC2021
should be looked at as one of the examples of case by case. 

My immediate concerns are the small business sportfishing and
excursion vessels that service the Southern California region, but
my comments are generally aimed at all small ocean based businesses
CHC2021 will affect.

As you are aware, marinized Tier 4 diesel engines are not available
for most of the vessels blanketed by CHC2021. And if the technology
does become available, in the format that is anticipated, 75% of
the existing small business sportfishing and excursion vessels will
not be able to make modifications required to install these
engines. The United States Coast Guard has also expressed concern
in this arena. 

If it is the intent to "Darwin" businesses out of existence to
reduce GHG, this initiative will do the trick, but there will be
substantial lash back from many directions. 

As previously stated, I am an environmental advocate.

My views are more moderate when addressing comparatively small
quantity GHG producers. A multi-tiered approach, utilizing engine
replacement with existing technology that will be better than the
current Tier 2 engines utilized in these vessels coupled with
modifications to operations to include some of what is already in
CHC2021:

1) Utilization of shore power immediately upon return to berth
UNLESS the vessel will be underway within a pre-determined
timeframe.

2) Main engine idleing reduction - When not required, main engines
must be secured within a certain timeframe, i.e. 2 mins, 3 mins, 5
mins, etc.

3) Engine maintenance - Engines must be maintained per OEM
recommended intervals for oil/filter changes, air filter changes,
engine adjustments, etc. Documentation of said maintenance to be
electronically provided to CARB at time of maintenance. Yes, this
is a huge work load, but will keep owners honest.

4) SMOG Program - Development of a SMOG program that tests engines
on each vessel every 1 to 2 years to ensure they fall within CARB
guidelines. Similar to tests performed on motor vehicles. Currently
a program of this nature for CHC does not exist. Once again, huge
workload, but will keep owners honest.

New Technology Exploration:

Work with small business CHC and marine PE's to develop usable
technology for these vessels to reduce GHG emissions while
satisfying safety requirements set forth by USCG and accompanying
CFR's.

The following are examples, though presently are not feasible or
practical now in a commercial small passenger vessel, but with
development for the maritime industry this is/will be the future:

1)Installation of batteries, solar panels to allow for reduced
electrical load and GHG emissions.

2) Survey of vessels to determine ways to reduce power consumption
while maintaining safety and comfort for passengers/crew.

3) Nitrogen fuel cell technology

4) Open door discussions to slowly swing the paradigm. Most small
business owners have a very small margin. If you were to work as a
partner to the future instead of Thor's Hammer, threatening to
smash small business, the response would be much better. 

Conclusion:

We all understand that GHG is the problem. Look at the large scale
polluters i.e. ships anchored offshore, large commercial - high
hour operations, etc. But still, there must be a guiding hand and a
paradigm shift. 

Thank you,

Gregory Grivetto
619-843-4256