Comment Log Display

The Embarcadero Coalition is excited about the new clean air
standards required by the OGV rule effective Jan 1, 2023. Our
understanding is that all the cruise ships at berth downtown San
Diego will have to connect to shore power or have another method to
reduce emissions to meet an equivalent clean air standard. We
understand that CARB is granting vessels an exemption for
connecting to shore power of up to 5% of their total visits from
the previous year for unavoidable technical difficulties which
create a situation where they cannot connect. This is not 5% gift,
but the VIE can only be used when there is a real problem. 
We don't object to the concept of Carnival combining its various
subsidiaries in order to simplify record keeping, as long as it
doesn't use this method to end up exempting specific vessels that
have not converted. Our understanding is that failure to convert or
provide another clean air methodology is not an exemption. They
don't get to use the exemptions of ships that have converted to
shore power capabilities to cover up for ships that have not gone
through the conversion. If that is the intent, then do not let them
combine fleets and do everything on a ship by ship basis. This in
not a cover up game, but serious clean air requirements. 
We do object to Carnival claiming a total of 20% exemptions (80%
connection rate through 2024) or 10% exemptions (90% connection
rate starting Jan 2025) by including TIE's in their calculation.
Our understanding are that TIE's are purely at the discretion of
the terminal for problems created by the terminal. The Vessels have
no right to TIE exemptions.  Please do not grant Carnival the right
to connect to shore power at less than the 100% less a maximum of
5% VIEs. The TIEs are for unique problems the terminal experiences
and Carnival may qualify for some TIEs, but it is not part of their
calculation. 
Thank you.                                      

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Date and Time Comment Was Submitted: 2022-07-05 15:07:41