Comment Log Display

I am writing to you today as a concerned constituent in opposition
to CARBs proposed rule to ban small engine powered equipment in
California by 2024. These proposals, if enacted, would result in
significant hardships for my small business, and my customers.
Please submit these comments to the docket for the CARB SORE2021
rulemaking.

Moving forward with banning small engine powered equipment in 2024
would have numerous negative impacts on emergency responders,
landscapers, outdoor power equipment dealers, and other businesses
throughout the state of California, as well as their employees, and
the various commercial, government and residential customers they
service, at a time when local businesses are already reeling from
the catastrophic effects of a global pandemic.

These proposals would drastically limit equipment choices for
professional landscape contractors and outdoor power equipment
dealers across California. We are small businesses who rely on
small engine powered equipment every day as cost-efficient and
high-performing solutions to install and maintain living landscapes
and green spaces in communities throughout the state, and maintain
our states critical infrastructure. Equipment choices and supply
are already limited due to worldwide supply chain disruptions
caused by COVID-19, and we do not yet see any indications of
recovery and return to normal supply and demand.

Battery powered technology is also not appropriate for all
applications and all users.  Many rural areas lack the
infrastructure needed to charge, transport safely and recycle
battery powered equipment  and this infrastructure will not exist
at the scale necessary to meet the states accelerated timelines.
And, battery powered equipment is simply not a viable option for
many critical services, like fuel mitigation,
infrastructure/utilities maintenance and tree care and clearing
services that depend on small engine-powered equipment to keep our
citizens and infrastructure safe. 

While I appreciate the efforts of legislators and CARB to address
Californias air quality needs, the small engine-powered equipment
category is a comparatively minimal contributor to the states
emissions. Further, the living landscapes our equipment is used to
install and maintain contribute to tangible environmental benefits,
including reductions in the heat island effect, carbon
sequestration, trapping dust and particulate matter, providing
habitat for pollinators, and producing oxygen. Our gasoline powered
products are also needed to combat the catastrophic toll that fires
and other natural disasters have taken on our environment and
communities in California.  

With this in mind, I respectfully request CARB postpone efforts to
ban small engine powered equipment until cost and performance of
and infrastructure for comparable electric powered equipment meet
commercial, emergency, and rural residential use needs. A delay in
implementation would allow the worlds supply chain to recover from
the worldwide pandemic that has disrupted production of all types
of equipment  including both battery and gas powered; and would
allow time to develop solutions for our critical infrastructure
workers who require gas powered equipment for their services. In
the meantime, I encourage CARB to work with equipment manufacturers
to explore additional small engine emission reduction technologies
that can be implemented in the near future.