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Comment 834 for Proposed Amendments to Commercial Harbor Craft Regulation (chc2021) - 45 Day.

First NameSteve
Last NamePazol
Email Addressstevepazol@gmail.com
Affiliation
SubjectCHC2021 Save Our Boats
Comment
It appears that the proposed passenger boat regulations that
require new engines and technology that is not feasible from a
safety, financial or operational standpoint. Please do not put
these small businesses out of business. In the calculated cost
impacts on the 6-pack example could result in $93.51 per passenger
additional cost to only pass along the amortized cost. 

In addition, the cost analysis states that "The maximum 
non-amortized costs for this typical small business is 1.9 times of
their annual revenue, while the maximum amortized costs for this
typical business is 9.3 percent of the average annual revenue for
businesses in the industry.  

This is absolutely not going to allow these business to stay in
business. In fact the report also states "However, staff cannot
rule out the possibility of some business elimination if costs
cannot be passed on to the customer or if passing through costs
would result in a significant decrease in demand."

This will pretty much be the death knell for many of these
businesses, so please look to modify or eliminate these rules to
save these businesses. 

Attachment
Original File Name
Date and Time Comment Was Submitted 2021-10-07 17:45:41

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


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