Ms. Cherie Rainforth, Manager of the Control Strategies Section,

Mr. Todd Sterling, Air Pollution Specialist Page 3

July 3, 2008

Ms. Cherie Rainforth, Manager of the Control Strategies Section,

Mr. Todd Sterling, Air Pollution Specialist
California Air Resources Board

1001 I Avenue

Sacramento, California

RE: Excursion Vessel Operations in South Coast Air District.

Cherie and Todd:

In an effort to comply with your request for additional survey information on our excursion vessels, I am enclosing the following descriptions of our vessels in the South Coast Air District.

Vessel Name / Total No. / Engine Make/Age / Annual Hours of Operation
M/V Entertainer / 2 / Detroit Diesel / 1977-78 / 516 (Mains)
2 / Detroit Diesel /1982-83 / 1032 (Auxiliary )
M/V Just Dreamin / 2 / Detroit Diesel / Uncertain / 366 (Mains)
2 / KILO Pack/Uncertain / 642 (Auxiliary)
M/V Dream Maker / 2 / Detroit Diesel / pre-1971 / 262 (Mains)
2 / Detroit Diesel / pre-1971 / 490 (Auxiliary)
M/V Cabaret / 2 / Detroit Diesel / Uncertain / 205 (Mains)
2 / Northern Lights / (Below 50 hp)
Vessel Name / Total No. / Engine Make/Age / Annual Hours of Operation (Type)
M/V Hornblower / 2 / Detroit Diesel / pre-1971 / 279 (Mains)
2 / Detroit Diesel/(Below 50 hp)
M/V Mojo / 2 / Detroit Diesel / 1972-73 / 520 (Mains)
1 / KILO Pack/ Uncertain / 994 (Auxiliary)
1 / Northern Lights / Uncertain / 994 (Auxiliary)
M/V Endless Dreams / 2 / Detroit Diesel-MTU/2002 / 371 (Mains)
2 / John Deere /2002 / 663 (Auxiliary)
M/V Dream On / 2 / Detroit Diesel /1978 / 311 (Mains)
2 / Isuzu/ Uncertain / 605 (Auxiliary)
M/V Marina Hornblower / 2 / Detroit Diesel/1979-80 / 471 (Mains)
2 / Detroit Diesel/ pre-1971 / 1044 (Auxiliary)
M/V Lady / 2 / Detroit Diesel/ pre-1971 / 256 (Mains)
1 / Northern Lights/Uncertain / 529 (Auxiliary)
M/V Wild Goose / 2 / 308 (Mains)
1 / Cat / (Below 50 hp) / 593 (Auxiliary)
1 / Dae Woo / Uncertain / 593 (Auxiliary)
M/V Zumbrota / 2 / Detroit Diesel/ pre-1971 / 341 (Mains)
2 / Detroit Diesel/ (Below 50 hp)

As you can see the 24 main engines in the South Coast Air District average approximately 350.5 hours annually. The auxiliary engines affected by the legislation (16 engines) average approximately 483.375 hours annually.
To replace the 40 engines in the South Coast Air District will cost approximately $4.5 – 5 million, assuming that such historic vessels as the Goose or Zumbrota could even be done. The costs imposed on vessel owners to achieve a small benefit in air quality would be devastating and drive many owners out of business.

Given the low hours our vessels operate (and the amount of fuel we consume), we respectfully request staff and the Board consider adjusting the annual operating hours, on both main and auxiliary engines for excursion vessels throughout the District and the State, for variations above the 300 hour floor. Given the average number of hours in our fleet, a floor approaching 500 hours would focus the new policy on those vessels that consume larger amounts of fuel and produce greater amounts of emissions. If there is still a remaining concern about the number of engines being governed by the new regulations, staff could consider regulating auxiliary engines only on excursion vessels as these engines are used primarily at dock side.

We would appreciate an opportunity to discuss this new information with you at your earliest convenience.

Sincerely,

/ S /

Joe R. Wyman

Director of Governmental Affairs

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