7. Attachment

Exhibit A

9/10/24, 3:12 PM

Mail - Commission-Public-Records - Outlook

[EXTERNAL] Public comment regarding Order 2024-10, September 10
Patrick McKee 
Tue 9/10/2024 11:01 AM
To: Calkins, Ryan ; Cho, Sam ; Felleman, Fred ; 
Hasegawa, Toshiko ; Mohamed, Hamdi  
Cc: Commission-Public-Records  

WARNING: External email. Links or attachments may be unsafe.

Commissioners I'm writing to address Order 2024-10, which the Commission is considering later this afternoon; the
order requires "the Executive Director to consider the attainment of greenhouse gas reduction goals
before the renewal of any long-term cruise agreement".
I would urge the Commission not to approve Order 10 today. Setting and meeting GHG reduction
targets is crucial, but this feels unfinished, a press release dressed up as policy. And it's fundamentally
unserious - sufficient neither to the inflection-point moment we're in or to the expressed intent of the
Commissioners themselves, working to reconcile climate and economy.
The order was forwarded with the respectful acknowledgment that it might not go far enough for us.
That's not wrong, but it's not the point. Everybody understands compromise and half measures are
what progress looks like sometimes, as long as we remain clear-eyed about their effectiveness. But this
order is opaque at its core, really a textbook example of greenwashing that doesn't further the mission
of the Port.
In the Introduction the order states, "while the growth of the cruise industry will ... provide ... economic
benefits, without ... zero carbon alternatives ... it will also lead to an increase in greenhouse gas." But
it's not as if we're discussing some dystopian future scenario; cruise growth has already resulted in
enormous GHG increases. A serious "consideration of the attainment of GHG reduction goals" might
convince the Port to address this ruinous present-day reality, instead of compounding catastrophe by
increasing sailings for years to come.
Cruise corporations have "committed to achieving" the IMO's 2023 Strategy of net zero GHG goals by
2050, but that strategy doesn't align even with the Paris Accords. Why not acknowledge that cruise
industry emission goals fail to put us on the path to 1.5C necessary to climate sustainability?
We're told future "clean and zero carbon fuels will eliminate the need for ... Exhaust Gas Cleaning
Systems". Why wait for some new technology? The Port could publicly call on cruise companies to
upgrade to low sulfur fuel tomorrow. Problem solved - no more scrubbers.
The wording of the order reflects a similar reluctance to actually compel the Port's cruise "partners":
rife with equivocal qualifiers like "consider the attainment", "strive", "include language ... that supports
evaluation", "explore the feasibility". Don't bother looking for consequences, for enforcement
mechanisms. Rather, it's business as usual (or promises of future change) spun as bold progress.

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9/10/24, 3:12 PM

Mail - Commission-Public-Records - Outlook

As currently written Order 10 lacks transparency, it's largely aspirational, it's devoid of accountability.
But the crisis we're facing is more serious than this. The Port Commission is more serious than this.
Thank you,
Patrick McKee
323.336.3651

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