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Comment 21 for Amendments to the Small Off-Road Engine Regulations: Transition to Zero Emissions (sore2021) - 45 Day.

First NameYujin
Last NameAnderson
Email Addressyyoo@steamericas.com
Affiliation
SubjectPlease Delay AB 1346
Comment
Firstly, as a California resident, I do appreciate your efforts to
minimize climate changing emissions. As a mother of 3 young
children living in Southern California, I care deeply about the air
quality and believe we should take actions sooner than later, but
with a plan to support those who will be immediately affected by
the change in place. At work I serve many customers who are very
hard working small business owners whose livelihood depends on
professional and commercial equipment listed as SORE.

I am afraid prematurely moving forward with banning small engine
powered equipment in 2024 without having alternative technology at
a comparable price range and performance will not have the support
from small business stakeholders. As it stands, it would have
numerous negative impacts on landscapers, mobile washers,
commercial contractors, outdoor power equipment dealers, and other
businesses throughout the state of California, as well as their
employees, and the various commercial and residential customers
they service.  

Currently professional-grade battery/electric equipment to run many
hours straight without charging intermittently in commercial
service settings - and the infrastructure needed to charge,
transport safely, and recycle it - doesn't yet exist at the scale
necessary to meet the state's accelerated timelines.

In the industry I serve (commercial cleaning, pressure washing),
the majority of the (equipment) end user customers are small
businesses (dis-proportionally minority owned or/and operated) who
may or may not have financial means to upgrade their equipment even
if comparable technology and infrastructure to support it readily
existed. It is also my belief that substantial rebates or subsidies
programs (far more aggressive than South Coast AQMD rebates for
lawn and garden equipment) should be offered to mitigate financial
burdens from upgrading equipment to small business owners for this
effort to work until the battery technology truly becomes
mainstream and affordable to all.

To make a difference in improving the air quality, the majority
need to comply. Without feasible means to get the majority who will
be directly affected by it on-board, the adoption of the new bill
will only result in a colossal waste of time and tax dollars.

With this in mind, I respectfully request the Legislature and CARB
postpone efforts to ban small engine powered equipment until the
cost and performance of comparable electric/battery powered
equipment meet commercial, emergency, and rural residential use
needs. 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.

Thank you for your time.

Attachment
Original File Name
Date and Time Comment Was Submitted 2021-11-09 14:33:52

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


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