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Comment 34 for Amendments to the Small Off-Road Engine Regulations: Transition to Zero Emissions (sore2021) - 45 Day.

First NameKyle
Last NameTurk
Email Addresskturk@holtca.com
Affiliation
SubjectAB1346
Comment
Dear SORE Lead Dorothy Fibiger,

I am writing to you today as a concerned constituent in opposition
to AB 1346 and CARB's proposed rule to ban small engine powered
equipment in California by 2024. These proposals, if enacted, would
result in significant hardships for my small business, and my
customers, many of whom are minorities and your constituents. 

Moving forward with banning small engine powered equipment in 2024
would have numerous negative impacts on landscapers, 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. 

These proposals would drastically limit equipment choice for
professional landscape contractors and outdoor power equipment
dealers across California. We are small businesses who rely on
small engine powered equipment every day as cost-efficient and
high-performing solutions to install and maintain living landscapes
and green spaces in communities throughout the state. 

As battery technology has advanced, so too has the availability of
electric outdoor power equipment. However, professional-grade
battery/electric landscape equipment - 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. 

While I appreciate the efforts of legislators and CARB to address
California's air quality needs, the small engine-powered equipment
category is a comparatively minimal contributor to the state's
emissions. Further, the living landscapes our equipment is used to
install and maintain contribute to tangible environmental benefits,
including reductions in the heat island effect, carbon
sequestration, trapping dust and particulate matter, providing
habitat for pollinators, and producing oxygen. 

With this in mind, I respectfully request the Legislature and CARB
postpone efforts to ban small engine powered equipment until cost
and performance of comparable electric 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.

Regards, 
Kyle Turk 
1049 57th St
Sacramento, CA 95819
Image removed by sender.

Attachment
Original File Name
Date and Time Comment Was Submitted 2021-11-10 19:45:04

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


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