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Commercial Passenger Fishing Vessels are commercial fishing and
should be recognized as such in your regulations. They provide the
public access to our rich fisheries offshore. This is both
recreational and importantly, a source of food, the same as
commercially caught fish by other commercial fishers. 

In a broader sense the proposed regulations are not "practicable"
at this time. Implementing them would simply reduce both safety at
sea and further curtail our ability to sustain peoples' quality of
life through a cascade of unintended consequences. 

An example of this is what we are currently seeing in the backlog
of freight traffic offshore today, ships both pumping out
pollutants while standing by and raising the cost of goods. This is
the result of Prop 5 and the reduced number of truck drivers and
CARB regulations which reduced the number of California Compliant
tractor vehicles. 

Reducing the number of qualified tugs, pilot boats, crew boats and
ferries is likely to further exacerbate problems. 
The governor's mandate and timeline is naive. CARB needs to speak
truth to power in this.