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Comment 10 for Proposed Heavy-Duty Inspection and Maintenance Regulation (hdim2021) - 45 Day.

First NameMitchell
Last NameDomingos
Email Addressmitchd40@yahoo.com
Affiliation
SubjectSORE Comment
Comment
Hello my name is Mitchell Domingos and thank you for the
opportunity to share.  I have represented power equipment
manufactures in northern ca for 20 years.  Air quality is very
important for the future of California.  The Carb example used at
the beginning of this meeting stated that using a blower for 1 hour
is equivalent to driving to Colorado, the blower used in this
example is only available in ca because of emission credits and
well over CARBs Emission standard.  While according to CARB's
website many CARB certified engines are well below Carb Standard. 

If we really would like to reduce emissions, end the emission
credit system to remove those dirtier engines giving our industry a
poor image.  And let the transition to battery happen organically,
letting technology improve and cost to reduce.    
Roughing into ZEE could do more harm than good if forced.  
I'll give you an example of when a Bay Area City banned backpack
blower due to noise.  Landscapers still needed to continue
beautifying landscape, after the ban landscapers towed generators
on little carts with a corded electric blower plugged in.  Actually
creating more noise using a generator than the previous blower. 
Because they roughed into the ban of blowers without a solution.  I
fear roughing into ZEE could to more harm than good to environment.
 
I suggest removing the emission credits and evaluate resident
product as CARB had identified 85% of the issues revolves around
consumer products.

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Date and Time Comment Was Submitted 2021-12-09 12:56:32

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