Comment Log Display

I am writing to you today as a landscape and garden professional
and leader of a youth motorsport non profit organization.  While I
share Governor Newsom and other California policymakers desire to
reduce carbon emissions from gas-powered equipment as quickly as is
feasible, a two-year timeline is simply too fast a transition for
commercial users and at this time is not technically feasible.  The
battery powered commercial-grade equipment on the market today is
not yet ready for high-volume use  it does not perform as well; the
repair and maintenance infrastructure are not there; Californias
energy grid may not be able to handle the increased loads, and
industry companies would have to rewire and retrofit their
buildings to add additional powerlines and charging stations  at a
significant cost.  Battery-powered landscape equipment is a good
solution for many suburban and urban homeowners with small yards to
maintain, but the equipment is not ready for high-volume
professional use.  It is less powerful, does not work as well on
slopes and grades, and takes significantly more time to complete
the same task as existing equipment.  In California there are
55,000 landscape companies and 99% of them are small businesses. 
Many are minority owned and are not prepared to make this
transition in only 2 years. 
We support a responsible transition to zero emission equipment when
the equipment is ready.  However, currently, commercial
battery-powered equipment has performance issues, cost issues, and
infrastructure issues.  According to its own data, the California
Air Resource Board can allow a much longer timeline for commercial
landscape companies to make the transition to battery equipment and
still meet its emission goals  without placing a financial burden
on the 50,000 small landscape businesses in California.  I implore
CARB to delay implementation of this transition for
commercial/professional grade equipment to 2026 or beyond.
In addition, to assist a transition to ZEE there must be a robust
rebate and tax incentive program put into place.  We understand and
acknowledge that the power of the purse is vested in the California
Legislature, but we must highlight how concerned we are as an
industry that our voices are not being heard.  While we appreciate
that the California Legislature approved $30 million to support AB
1346 and this transition, that amount is woefully inadequate. 
Based on the CSUF data published in CARBs ruling, if ALL that money
went to ONLY commercial business (1,911,555) that would mean that
only $15 dollars would be provided per piece of equipment traded
in.  We are talking about investing 10s to 100s of thousands of
dollars for each company to transition and $15 does not come close
to supporting the landscape industry and our majority small
business demographic.  This further highlights how a delayed
transition for commercial grade equipment will make this transition
easier and less costly for all those involved.
In conclusion, the landscape industry cares deeply for the
environment.  We genuinely want to support a transition to ZEE, and
we believe that time is coming but not by 2024 for a complete
transition.  The landscape industry relies on this equipment to
support their employees, customers and families and their concerns
must be considered.
Regarding the youth motorsports, we utilize a small gas powered
engine designed for lawn mowers that is recognized nationally, if
we are unable to purchase/own/run these engines, then the sport
will die out in California. Quarter midgets have been around since
before World War II, Capitol Quarter Midget Association in
California has operated a dirt track for quarter midgets since
1954, where Jeff Gordon raced. Please consider moving the date to
help everyone adjust and reach the same goals.