Comment Log Display

Hello - in regards to Ferries and Tugs.  Happy to discuss offline
if more appropriate. 

1.	Appendix D states "Eligible Ferries and/or Tugs include
unregulated, Tier 1, or Tier 2 marine engines".  In this case, does
"unregulated" refer to Tier 0 / uncontrolled engines?  
2.	If yes - Will this funding only be allocated to those engines
which have not yet reached their Commercial Harbor Craft (CHC)
regulatory compliance date for engine replacement and/or  have
already achieved compliance with the CHC by installing a Tier 2 or
cleaner engine?  Or will you be allowing Tier 0 and Tier 1 engines
to be eligible for funding, even if their engine replacement date
set forth by the CHC has already passed? If CARB plans to follow
the CHC engine replacement schedule, this would only allow for
engines 2003 model year or newer and Tier 2 engines or cleaner to
be upgraded through the mitigation trust funding.  This would
likely result in many projects being a Tier 2 to Tier 3 or 4
upgrade.
3.	Suggestion: I would suggest that CARB utilize the Carl Moyer
guidelines as a framework for managing this category.  However, I
would eliminate the 3 year surplus emissions requirement - this
requires projects to be completed 3 years prior to any regulatory
compliance date.  I would recommend that applicants be deemed
eligible as long as they are awarded funding for engine repower
prior to their compliance date.    I would also allow for
propellers and shafts to be included as an eligible cost for this
category, which the Carl Moyer Program does not allow for. 
4.	Suggestion:  I would follow the Cost Effectiveness Cap set by
Carl Moyer of approximately $30,000 / ton of emission reductions
5.	For all repower / scrap projects I would recommend there be an
opportunity for the applicants to request a "progress payment" for
any engines / equipment prior to the completion of the project. 
Many applicants are not able to come up with the funds needed for
reimbursement type projects.
6.	Suggestion:  I would recommend that the application for diesel
repower / replacement projects be an online application process
similar to those developed by the BAAQMD and SCAQMD.
7.	Suggestion: Although I understand appendix D does not allocate
funds to all commercial harborcraft, I would suggest (if possible)
that a portion of the VW funds be allocated to Carl Moyer programs
throughout the state, so the commercial diesel categories who are
left out of this settlement (like ag, construction and marine) can
also benefit from this funding.  The emission benefits from the
replacement of high usage Tier 0 engines within the unregulated
harborcraft communities are significant. 
8.	Suggestion: I would concur with local Air Districts on the
projects that receive the most reductions in NOX so funding could
be successful in reducing the most NOX / ton / cost to manage
funding.

Thanks,

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