Comment Log Display

I am writing to you today because I am concerned about our
landscape and garden professionals. Landscape professionals work
every day to take care of our nations 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; 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. 
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 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 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.