Comment Log Display

I am a resident of downtown San Diego, a predominantly residential
downtown with 40,000 densely populated residents living in
high-rise condominiums and apartment complexes. Over 1400 hotel
rooms are across the street from the berthed ships and many
residents are literally one block from the cruise ship terminal, a
distance of about 800 ft. The cruise ships docks are located within
a half-mile radius of high-density residential populations of the
Columbia, Marina and Little Italy neighborhood districts. The
pollution created when the ships are not connected to shore power
is toxic thus I am required to shut all windows and use AC when
ships are at-berth in San Diego.
I don't believe CARB is considering the proximity of the ships to
the residential population in its rulemaking. A one size fits all
scenario for rule-making does not work since the health and welfare
of thousands of people is being put at risk. 
Comment on Section 93130.7 Vessel Operator Requirements
I am pleased passenger vessels will be required to connect to shore
power Jan 1, 2021. I want ALL cruise ships to meet this
requirement, no exceptions, at the San Diego cruise ship terminal.
Cruise ship lines with their use of foreign registration currently
circumvent safety, labor and environmental laws and it is very
likely the cruise ship lines will simply begin repositioning their
ships to berth at a variety of ports in 2021 to maintain the under
6 visits per year to avoid coming into compliance for however long
they can continue circumventing California environmental mandates. 

Section 93130.7b3A-B 
Maintain the current timeframe standards, or make them tougher, to
connect to shore power. One hour after the ship docks to berth is
acceptable. Changing this connection time to 2 hours after Ready to
Work, in our situation, is unacceptable. Vessels and the Port need
to make sure that the connections are maintained and trained labor
personnel are available to connect in one hour. Please do not lower
standards and allow more than two hours to connect to shore power.
At San Diego downtown terminals Celebrity cruise line failed to
connect to shore power on their Millenium and Eclipse ships in
March and April 2020 for many days and nights.  If the ship does
not have trained personnel or proper equipment to make connection
to existing shore power infrastructure then a Port official should
not grant the ship access to a downtown terminal for berthing.  If
a ship is unable to connect to shore power the owner of the ship
line must meet mandate by retrofit, only use nonCalifornia ports,
fund the cost of remediation, high-cost fines and/or fund
infrastructure enhancements at ports they want to visit to allow
for compliance.

Section 93130.8 Vessel Visit Exceptions is too lenient especially
8.e.(1) Until January 1, 2023 previously unregulated vessels are
not subject to the vessel auxiliary engine requirements.
Cruise lines already had years to convert their ships. Cruise ship
lines desiring to come into San Diego Bay to dock at the San Diego
downtown cruise ship terminal should not pollute the neighborhood
people's lungs and homes. 
Section 93130.8a (h) Remediation
Is there an incentive for a Port terminal operator to prefer
remediation rather than ensure an individual cruise ship actually
meets environmental mandates?   Is the “remediation” actually cost
effective for the ship fleet operator?  
Section 93130.9 Terminal Operator Requirements
In order for the Port of San Diego to meet the connection
requirements already proposed, it requires funding to build the
additional infrastructure to provide a second and third shore-power
connection for its 3 berths. Please provide the resources to make
this happen before Jan 1, 2021.  
Although the San Diego Port’s website indicates there are 2
shore-power connections at the downtown cruise ship terminal the
fact is there is a single connection.  The San Diego Port should
not be calendaring any more cruise ships than a single ship and
also ensuring the ship can actually be connected to shore power. 
Unfortunately the San Diego Port has routinely allowed for multiple
ships to be in port concurrently which results in ships not using
shore power due to lack of infrastructure.  Residents, like me,
want this to end before or by Jan. 1, 2021.
Suggestion: Prior to a Port scheduling a visit by a cruise ship
line ensure the proposed visiting ship’s shore power requirements
are known to match the existing shore-power and ensure each
arriving ship will have trained personnel to perform hookup to
shore power.   If the ship cannot connect to the existing
infrastructure then enhanced infrastructure be funded by the cruise
line: cost of purchase, installation and maintenance of shore power
to ensure their line has access to the type of shore power which
their ships require  to meet environmental mandates.  And cruise
ship personnel must be trained to perform hook-up to shore-power
infrastructure each port terminal they plan to berth.
Section 93130.11-16
If a terminal has rarely visited berths within its terminal does
that mean a noncompliant ship would then circumvent simply by
assignment by the port to use the rarely used berth at a terminal. 

I have concerns regarding how compliant local Port terminal
operators are toward ensuring environmental mandates are met due to
a likely close working relationship with fleet operators.  And to
be effective the timeliness of response time on CARB communications
and terminal reporting of vessel visits and incident events is
imperative thus staffing levels must meet those needs.  
Section 93130.11-17 Innovative Concept Compliance Option
Funding the cost and educating ports of innovations toward delivery
of goods which in San Diego is currently done via semi trucks
serving berthed cruise ships at the downtown terminal and the
current transport of passengers by bus/taxi/personal vehicles which
also currently decreases air quality in the immediate and
surrounding area.  Suggest mandate such innovations to ports to
offset poor air quality generated by terminal operations.
Thank you for considering my concerns.  Every hour ships are
allowed to pollute, especially in a densely residential downtown,
places the health and welfare of thousands of people at risk.
Thank you for considering my concerns.