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I urge you to delay implementation of this action to at least
2030.

As the Maintenance Department Manager for a licensed landscape
contractor and small business, early (2024) implementation will
cause economic hardship and potential loss of business.
While these efforts are to be applauded, current replacement of
small gas engines with battery power is not reliably viable with
current technology and processes within the landscape industry.

Critique of this technology is as follows:
- charge capacity too small to run all day for large projects
- discharge rate anxiety by professional users (draw down time
highly variable depending upon use and battery size)
- reduced battery lifespans due to constant or frequent use and
constant recharging
- insufficient torque/power (i.e. more power = less run time) 
- high price point to purchase
- high price point for replacement batteries
- no to little standardization in battery design
- issues with California's electrical grid including PSPS
- difficulty and or extra costs associated with the need for
charging stations or carrying multiple extra batteries during
workday
- supply chain issue challenges for foreseeable future
- repair issues - often more economical to throw away than repair

In general, the landscape industry is beginning to use some battery
technologies such as portable power tools (drills, saws, chainsaws,
small lawn mowers). The challenges listed above will lessen over
the next 10 years as the technology improves and price points
reduce. A two-year plan is too soon to avoid the issues above.
If battery technology was equal to small gas engines in power and
price, I can assure you, many landscape contractors would begin to
make the switch.
PLEASE consider a delay until 2030.

Sincerely,
Kristine