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 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 most commercial users and at
this time is not technically feasible.  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. The battery powered commercial-grade
equipment on the market today 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.  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.
 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. 
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.
And 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.