Comment Log Display

I am writing to you today as a landscape and garden professional. 
Landscape professionals work every day to take care of our nation's
green spaces, and we share Governor Newsom and other California
policymakers' desire to reduce carbon emissions from gas-powered
equipment as quickly as is feasible. However, a two-year timeline
is simply too fast a transition for commercial users and at this
time is not technically feasible.  The battery powered
commercial-grade equipment on the market today is not yet ready for
high-volume use - it does not perform as well; the repair and
maintenance infrastructure are not there; California's energy grid
may not be able to handle the increased loads, and industry
companies would have to rewire and retrofit their buildings to add
additional powerlines and charging stations - at a significant
cost.  Battery-powered landscape equipment is a good solution for
many suburban and urban homeowners with small yards to maintain,
but the equipment is not ready for high-volume professional use. 
It is less powerful, does not work as well on slopes and grades,
and takes significantly more time to complete the same task as
existing equipment.  In California there are 55,000 landscape
companies and 99% of them are small businesses.  Many are minority
owned and are not prepared to make this transition in only 2 years.

We support a responsible transition to zero emission equipment when
the equipment is ready.  However, currently, commercial
battery-powered equipment has performance issues, cost issues, and
infrastructure issues.  According to its own data, the California
Air Resource Board can allow a much longer timeline for commercial
landscape companies to make the transition to battery equipment and
still meet its emission goals - without placing a financial burden
on the 50,000 small landscape businesses in California.  Because of
this please delay implementation of this transition for
commercial/professional grade equipment to 2026 or beyond.
Lastly, to assist a transition to ZEE there must be a robust rebate
and tax incentive program put into place.  We understand and
acknowledge that the "power of the purse" is vested in the
California Legislature, but we must highlight how concerned we are
as an industry that our voices are not being heard.  While we
appreciate that the California Legislature approved $30 million to
support AB 1346 and this transition, that amount is woefully
inadequate.  Based on the CSUF data published in CARB's ruling, if
ALL that money went to ONLY commercial business (1,911,555) that
would mean that only $15 dollars would be provided per piece of
equipment traded in.  We are talking about investing 10s to 100s of
thousands of dollars for each company to transition and $15 does
not come close to supporting the landscape industry and our
majority small business demographic.  This further highlight how a
delayed transition for commercial grade equipment will make this
transition easier and less costly for all those involved.
In conclusion, the landscape industry cares deeply for the
environment.  We genuinely want to support a transition to ZEE, and
we believe that time is coming but not by 2024 for a complete
transition.  The landscape industry relies on this equipment to
support their employees, customers and families and their concerns
must be considered.