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Comment 105 for Amendments to the Small Off-Road Engine Regulations: Transition to Zero Emissions (sore2021) - 45 Day.

First NameSpencer
Last NameCarlton
Email Addressscarlton@lusagroup.com
AffiliationLUSA Holdings, LLC
Subject2 cycle equipment emissions
Comment
I believe the added costs of inhibiting the use of 2 -cycle
equipment by 2024 will cause more emissions and hardship for the
users of this equipment.  I have a background in commercial
licensing of lithium ion battery technology and believe I have
sufficient understanding to have a real opinion.

Current electric equipment technology is not sufficient to reliably
use in the landscape industry.  The material science in the
batteries is not yet capable of holding a sufficient charge long
enough and deliver enough power to satisfy the typical landscaper. 
The balance of weight, cost, life and load is not yet appropriate
for our use.  

Thus forcing companies to use inferior technology too soon will
only increase the number of batteries, pieces of equipment needed
to be purchased, all drivers of carbon emissions,  while also
increasing drive time for crews, mechanics and repair shops trying
to support each crew in the field.

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Original File Name
Date and Time Comment Was Submitted 2021-11-12 15:13:29

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