Comment Log Display

I am writing to you today as a concerned citizen.  Landscape
professionals work every day to take care of our nations green
spaces, and they 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; Californias 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. 
They 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.  Landscape professionals
understand and acknowledge that the power of the purse is vested in
the California Legislature, but they must highlight how concerned
they are as an industry that their voices are not being heard. 
While they 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 CARBs
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 the 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.  They genuinely want to support a transition to ZEE,
and 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.