Comment Log Display

July 3, 2008

Ms. Mary D. Nichols
Chairwoman
California Air Resources Board
1001 I Street
Sacramento, CA 95814

Re:  Proposed Harbor Craft Regulations

Chairwoman Nichols and Members of the Board

The Red and White Fleet (RWF) is a privately owned passenger
vessel fleet in San Francisco bay offering one hour bay cruises.
The RWF operates four vessels with 14 of the fleet’s 16 engines
(mains and generators) having been replaced between 1999 and 2007.


We would like to commend the Board and the ARB staff for the
clarifications made to the definitions of ferry and excursion
vessels. 

It is our understanding that under section 6. (E) 4 b, we will be
able to request a one year extension for a vessel when we have two
vessels that are required to comply with the Tier 2/3 standards in
the same year. While this will offer some operational and
financial relief, we believe the E. O. should be granted greater
flexibility when considering the length of an extension for those
vessels having to comply after 2011, similar to that provided in
section 6. (E) 4 a. 

One factor that does not seem to have been fully considered in the
drafting of these regulations is the cost of replacing generators
and main engines on one vessel at different times as would be the
case with three of the RWF’s vessels if the RWF was to follow the
dates provided in table 7. Duplicating the cost of putting a
vessel in drydock, removing carpet, removing deck hatches, and
completing other major work involved in engine replacement is
infeasible for a private operator such as the RWF. In essence,
this moves the compliance date for each vessel to that of the
oldest engine in the vessel which, in turn, undervalues the
original investments this company made over the past eight years
when it chose to improve emissions by repowering with Tier 1
engines prior to any rule making.  

While we recognize that the ARB staff provided for considerable
flexibility in the manner which an operator can comply with the
regulation dates, we believe the E.O. should have greater ability
to consider the overall fleet emission reductions and investments
made prior to the implementation of this regulation when
evaluating extension requests and have the authority to grant
longer extensions for Tier 1 engines, particularly when in-situ
testing shows them to operate at emission levels below those
mandated by the Tier 1 standards.

It appears there is an unintended advantage given to those
companies who delayed repowering until the implementation of these
rules (while continuing to produce emissions at below Tier 1
standards) and a similar unintended lack of recognition for those
companies who made early investments in cleaner technologies. As
previously stated, one method of addressing this situation would
be to allow these factors to be considered during extension
requests.

The Red and White Fleet wants to thank the Board and the ARB staff
for their efforts to protect our air now and for future generations
as well as for providing this opportunity to share our comments. 

Sincerely,



Joe Burgard
Vice President of Operations
Red and White Fleet.