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Comment 2 for Amendments to the Small Off-Road Engine Regulations: Transition to Zero Emissions (sore2021) - 45 Day.

First NamePeter
Last NameEstournes
Email Addresspje@gardenworks-inc.com
AffiliationGardenworks Inc.
SubjectSmall Off-Road Engine Regulations: Transition to Zero Emissions
Comment
I urge you to delay implementation of this action to at least
2030.

As a licensed landscape contractor and small business owner,
earlier implementation will lead to economic hardship and potential
loss of business.

While these efforts are to be applauded, current replacement of
small gas engines with battery power is not reliably viable with
current technology.

Some issues with this technology are as follows:
- charge capacity too small to run all day
- discharge rate anxiety by professional users (run down time
highly variable depending upon use)
- reduced battery lifespans due to constant or frequent use
- insufficient torque/power (i.e. more power = less run time) 
- higher price point to purchase
- no to little standardization in battery design
- issues with California's electrical grid including PSPS
- difficulty and or extra costs associated with the need for
charging stations or carrying multiple extra batteries during work
day

In general, the landscape industry is beginning to use some battery
technologies such as portable power equipment (drills, Saws,
chainsaws, small lawn mowers). 

If battery technology was equal to small gas engines in power and
price, I can assure you, many contractors would begin to make the
switch.  If nothing else we are a practical industry.

Thank you for your consideration
 

Attachment
Original File Name
Date and Time Comment Was Submitted 2021-10-15 15:10:48

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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