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Comment 395 for Amendments to the Small Off-Road Engine Regulations: Transition to Zero Emissions (sore2021) - 45 Day.

First NameMatthew
Last NameCannon
Email AddressMatthew.Cannon@Brightview.com
AffiliationBrightview Landscape Services
SubjectReasonable Time Frame to Transistion
Comment
While I may not be in CA, I work for a landscape contracting
company that services a large portion of the state.  Also many
legislative items that CA does affects and tends to influence other
states.  With that said, we at BrightView and frankly most
landscape contracting industry do care about the environment and
are constantly finding ways to lower our impact.  Many of us,
including BrightView have already embraced alternative fuel
machinery and electric.  However given the entire industry has been
using combustion engines that run of diesel, unleaded, and mix for
well over a 100 years it will take time to retool our fleets,
crews, business models, pricing to customers and vendors, and train
our employees.  The landscape contracting industry is open to
moving to electric power sources.  However we have to change how we
setup our trucks in trailers in order to be able to store
batteries, charging stations, solar panels, and buy all new
equipment.  We also have to stock new spare parts, tools, and re
train mechanics.  This is a very large investment to make.  Also we
need to analyze our costs and efficiencies with this equipment and
make sure we are charging our customers accordingly otherwise we
risk going out of business and putting more people out of work. 
All this items take a lot of time to analyze, organize, spend, and
assemble to be able to continue to same level of service to our
customers.  In closing a 2 year deadline to make all the above
happen is simply not possible.  It does not make business sense nor
industry sense to make that change that fast.  Our vendors would
not even be able to fulfill orders. Also with this fast deadline
this will push companies to simply buy their products out of state,
thus decreasing commerce and the economy within CA and putting an
undue burden on the vendors out of state and that in turn will put
a burden on the purchasers in those states.  That in turn won't fix
your problem.  Give the industry a reasonable time frame to adjust,
adapt, and evolve.  Lastly many of the landscape contractors are
not large multi million companies.  Meaning they simply do not have
the capitol to change their fleets over to fully electric either at
all or in this timeframe.  Please consider providing a more
reasonable deadline.  We landscape industry and the manufacturers
of these products do welcome this change however just in a more
organic reasonable time.  Thank you.

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Date and Time Comment Was Submitted 2021-11-18 14:30:19

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