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Comment 6 for Amendments to the Small Off-Road Engine Regulations: Transition to Zero Emissions (sore2021) - 45 Day.

First NameMichael
Last NameLloyd
Email Addressmichaellloyd3280@gmail.com
AffiliationRetired
SubjectProposed SORE regulations
Comment
I've always been a firm proponent of reasonable environmental laws,
but the proposed SORE regulations are very impractical, at least in
rural areas of the state. 

For forty years, I've lived on 20 acres of steep oak woodland and
wild grassland in the hills of Mendocino County.

After the seasonal rains stop every spring, due to the fire danger
and Cal Fire mandates I have to cut several acres of wild grass
around my home and along both sides of my 750-foot-long driveway
with a string trimmer ("weed eater").  Since it's impossible to
predict when the last seasonal rain falls, my neighbors and I
sometimes have to cut three times.  

A battery-powered string trimmer only lasts roughly 20-30 minutes
before needing several hours of recharge, and the cutting is much
slower than with a gas-powered device.  An extension cord for an
electric trimmer will only go so far, and can throw sparks into dry
grass where cords plug together.

The grass isn't cut for landscaping purposes, but to enable Cal
Fire to try and save my home, and maybe give us precious seconds to
escape a wildfire.

This spring, due to the drought, three oak trees, plus seven
Douglas fir that I planted 25 years ago all died.  The oaks simply
fell over, the seven Douglas fir I had to cut down.  One of the
oaks fell across my driveway leaving sixty feet of tangled branches
across my driveway, stranding the house and my vehicles on the
wrong side of the blockage.  I had to cut for days and days to make
pieces small enough to stack on level ground.  The Douglas fir I
cut up to pack uphill out of the woods.

I don't know what I'd do with battery-powered chain saw, or an
electric one.

A lot of forest waste can be chipped instead of control burned. 
But chippers need gas engines, and don't work very far from a
road.

Obviously the problem of dead trees isn't just my own, it extends
all over fire-prone northern and central California. 

And then there's my 80+year-old neighbor, who lives alone in the
woods off the grid.  She has solar panels for electricity, with a
generator for when the sun doesn't shine due to prolonged bad
weather, especially when the days are short.  She needs a
gas-powered backup generator to charge her storage batteries.  No
power, no light. And no water from her well pump.

Cal Fire needs large gas chainsaws to fight wildfires.  The logging
industry needs chainsaws to operate far from electricity.
Second-and third-growth forests need thinning to be healthy.  If a
battery goes dead cutting down a tree, the tree can start splitting
up the middle threatening the safety of the faller.

And if people in the cities can't grow lawns economically due to
the high cost of mowing, converting to rock gardens and wood decks
mean that the grass won't be there to cleanse the air and absorb
heat.

How will the power used to generate the electricity to charge the
battery originate?  Hydropower, geothermal, wind and solar won't be
enough.

Please pardon if I've misinterpreted some of the proposed
regulations.  Information is spotty and contradictory at this stage
of the game.

Thank you for your time.
 
Michael Lloyd



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Date and Time Comment Was Submitted 2021-10-21 11:07:31

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