Comment Log Display

 This regulation as written will not reduce a single ounce of
harmful emissions until January 1st, 2014 at the earliest when
mandated reductions go into effect.  As written the proposed
regulation offers no incentive for early adopters to achieve
compliance before being forced to.  Lastly, compliance standards
within the proposed regulation serve to thwart new technological
solutions that are available today.  This is because the
regulation is based on a presumptive solution: port
electrification.   The problem is that the presumption is flawed.
The costs are staggering, estimated to be $1.2 billion statewide,
and the difficulty to electrify a port means years of construction
to install infrastructure to receive electrical power that is not
available - and there are no plans or budgets to build new
generation capacity to supply this power.
 
Ship-borne air pollution is well documented and proven to cause
serious health problems in people from in all walks of life having
serious effects on children and the elderly. One scientific report
published on November 7th, 2007 by the American Chemical Society
journal Environmental Science & Technology states “…the number of
people dying (globally) from heart and lung disease as a result of
under-regulated shipping emissions totaled 60,000 in 2002, and that
death toll is estimated to grow by 40% by 2012…” 
 
Incentives for early adoption of alternative control solutions are
essential to encourage ocean carriers, vessel owners and terminal
operators to use proven emissions preventative technologies that
are available now.  If encouraged these solutions could reduce
these harmful emissions to the full extent of the regulation in
every seaport in California by year-end 2012 – and at a small
fraction (1/30th) of the cost of port electrification.  That’s 6
years sooner and more than a billion dollars cheaper.  This is
truly a better way.