Please change the definition of a short-run
ferry in the proposed harborcraft regulations, so that a
boat that operates with a diesel engine, cannot add multiple legs or add
one long leg, in
order to avoid the requirements that a short-run ferry, be zero
emission. As written, the
regulations will cause boat operators to game the
regulations by running more and longer routes and this
will increase CO2 emissions by thousands of tons in the Bay Area
and this is wrong.
Zero-emission regulations should reduce CO2 emissions not
increase them. Please make it that everyone running a vessel on a
short-run route has to follow the same regulations and be
zero-emission without loopholes. That's only fair and also
will ensure the proposed regulations reduce CO2 emissions created
by ferries in the San Francisco Bay.
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