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Comment 514 for Amendments to the Small Off-Road Engine Regulations: Transition to Zero Emissions (sore2021) - 45 Day.

First NameDARRYL
Last NameBRAAKSMA
Email Addressdarryl.braaksma@alohasaw.com
AffiliationGreen Valley Aloha Saw and Mower
SubjectAttaining Zero Emissions
Comment
I am greatly concerned the State of California has taken measures
for attaining Zero Emissions by the elimination of Small Off-Road
Engines will likely have a negligible effect in the quality of air
and at a great expense and detriment of California residents and
businesses.
California HAS NOT demonstrated its ability to provide reliable
electrical power.  Currently blackouts and brownouts are a common
occurrence throughout the state.  Currently the source of
electricity for California is dependent on 60% non-renewable
energy.  Logically, an increase in electrical demand would need to
be derived from non-renewable energy such as coal and LPG.  Hence,
the employment of battery powered equipment will place greater
demand on the fragile electrical grid which in turn will require a
greater amount of non-renewable resources to generate the
electricity.  This is NOT creating a state of having Zero
Emissions.  
An environment impact for battery powered equipment has not been
published.  A published report documenting the environmental impact
and cost of Lithium battery production from cradle to grave.  How
much non-renewable fossil fuel is required for the production,
recycle and disposal of the Zero-Emission battery? 
The Battery Powered Industry for outdoor powered equipment is in
its early phase.  The cost of Battery Powered Equipment is
generally three times that of a gas powered equivalent and with a
fraction amount of efficiency.  For example, a common commercial
backpack blower which costs $500 with a blowing force of 32 Newtons
can be substituted with a Battery Powered Blower for $1600 having
only 17 Newtons blowing force.
At best, the current available Battery Powered Equipment is suited
for residential user.  Only for a limited number of applications
does a battery powered tool make sense for commercial applications.
 For example, a tree arborist will employ the small battery powered
chainsaw whilst high in a tree for safety reasons.   The largest
battery powered chainsaw can power a small 18" bar whereas the
forestry and fire response requires bars twice size in length.  In
terms of equivalent chainsaw power, the largest battery powered
chainsaw is roughly equivalent to a 30cc gas powered chainsaw.  A
gas powered chainsaw designed for a 36" bar requires at least an
80cc gas powered engine.  Hence there is no suitable battery
powered equipment for forestry or fire fighting gas powered
equipment, and the list goes on. 
From my perspective, California should not be banning gas powered
outdoor equipment 1) until it has demonstrated the ability to
provide reliable and affordable derived from Zero-Emission
renewable energy;  2) until a fully documented environmental impact
report documents the employment of batteries for powered equipment,
from cradle to grave, will ultimately consume less non-renewable
CO2 emitting energy; 3) without compliance with 1 & 2, at most the
ban should apply to residential use only.
My Sincere Regards,
Darryl Braaksma

Attachment www.arb.ca.gov/lists/com-attach/904-sore2021-B2RTNFwvBDULUgk7.docx
Original File NameCARB 29 November 2021.docx
Date and Time Comment Was Submitted 2021-11-29 11:31:44

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