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Comment 102 for Amendments to the Small Off-Road Engine Regulations: Transition to Zero Emissions (sore2021) - 45 Day.

First NameMarty
Last NameMcClung
Email Addressmarty@westernmower.com
AffiliationWestern Mower & Engine
SubjectDifficulty for proposed small engine ban
Comment
I have operated a small engine sales & repair business since 1984
and have 5 employees with thousands of customers who depend on the
small engine industry. I first want to say I am concerned about our
environment and want to do my part in keeping it clean but I also
know banning all small engines by 2024 is not really feasible with
the technology in place now or by 2024. All of the brands we
represent have been designing new and environmentally conscious
equipment but some products cannot be replaced with electric power.

Here are some concerns listed:
Among the problems of using battery powered commercial landscape
equipment, there are:
- issues related to charging many batteries such as fire hazards to
a facility
- limits of electrical circuits in a facility
- limits of power availability to a facility that would be charging
at least 1,000 batteries for 50 landscape crews in 1 day (assuming
mowers, blowers, etc would all be using batteries, 20 5ah batteries
per crew which is a bare minimum, not mowing much grass)
- limits of personnel to work overnight to rotate batteries
- limits of "peak hours" where electricity is rationed exactly when
landscapers would need to charge many batteries in the evening
- inability to continuously generate electricity from a gas powered
generator in an emergency
We have been involved with homeowners and business owners that
suffer from power loss, fires, flooding and other losses and our
gas powered small engine equipment has been a life saving resource
to help them! This cannot be taken lightly.
There are also thousands of workers that depend on small engine
equipment to make a living and yes beautify California some would
suffer huge financial losses if this ban goes into affect on 2024.

I would suggest our government looks for more information on
implementing electric power for small equipment and will talk with
industry leaders in our field to see if the proposed restrictions
will work.

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Original File Name
Date and Time Comment Was Submitted 2021-11-12 14:14:34

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