Submitted Comment Name Joshua Kehoe Affiliation California resident Subject BAE Systems ACE application for Pride of San Diego Drydock Message Dear CARB Personnel: I support this ACE application. Given the dearth of US shipyards capable of working with larger or more complex vessels, I am somewhat surprised BAE doesn't have a Federal exemption to perform their important work outside of State-level regulation. Given their stated focus on shore-based electricity, utilizing the older diesel engines/generators only as backup in case of an emergency where shore-based electiricity was not available, their request to have a backup supply of electrical generation not reliant on the public electrical grid is not unreasonable. Their request to run these generators on occasion is very reasonable. Regarding their crane motor, it appears they are working to have this motor upgraded to Tier IV status. Were CARB able to guarantee uninterrupted, reasonably-priced electricity to replace the diesel motor, I might raise some caveats to my support for BAE in this situation. But given I absolutely do not feel uninterrupted, reasonably-priced electricity is something any California entity is able to guarantee, BAE's request to continue with their Tier 2 crane engine with plans to upgrade to Tier IV seems more than reasonable. I could continue with discussion around the importance of maritime shipping, and vessel repair, and how this has shifted away from the US to Asian countries. Initially Japan and South Korea. Now primarily China. Examining BAE's ACE submission through the lens of a larger geopolitical viewpoint, I see no reason why there should be any objection to BAE's plans. Their proposed diesel engine for the year has to be dwarfed by the total emissions of all the military and international shipping vessels that visit the area annually. The goal of reducing local emissions is admirable, but if emissions for ship repair are necessary, and I feel they are, then offshoring them to non-US entities in order justify shuttering local options (which provide jobs for local, skilled labor) to reduce "local" emissions is short-sighted. "Local" because in the end, emissions are planetary. BAE's submission has provided evidence of their desire to reduce or do away with the NOx and PM associated with diesel generators. Had they not submitted plans for how to reduce those I would be more skeptical. But they do have plans, and I support these. Respectfully, Joshua Kehoe File Upload (i.e., Attachments): N/A N/A
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