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Comment 431 for Amendments to the Small Off-Road Engine Regulations: Transition to Zero Emissions (sore2021) - 45 Day.

First NameRichie
Last NameJohnson
Email AddressRichie@parklandscapemaintenance.com
Affiliation
SubjectSmall engine ban
Comment
As a small business owner, The ban of sale of small engines would
be detrimental to our business. After doing rough calculations it
would cost aroximaetely $75,000 per maintenance truck to convert to
all electric. With 5 maintenance trucks currently in operation that
equals $425,000.  That doesn't include the cost to upgrade the pg&e
service to our property and add additional electrical circuits to
our shop to be able to handle the power needed to charge all the
equipment. A study shows that there are over 2 million pieces of
commercial equipment in the state of California and the proposed
30million in Grant money to replace them only equals 15 dollars per
piece of equipment. That doesn't seem like an equal trade. To
further speak on electrical california as a state is already maxing
out our power grid.. this is the reason for pg&e planed power shut
offs.. if all landscapers are charging our equipment that will put
even more strain on our grid, what happens if we have a power shut
off and can't charge our equipment?? The employees don't work or
get paid?? The business can't charge the clients?? Sounds like a
detriment to the economy. This ban also follows closely behind the
new diesel laws outlawing older diesels weighing over 14 k gvw. We
had to get rid of 2 trucks with just over 100k miles on them and
replace them with equal viechles costing 65k each totalling 120k.
Soon after the diesel laws changed we have the covid 19 pandemic.
We lost some assccounts and some have switched to a partial
maintenance program reducing our maintenance income. And on top of
this we have payed out over 650 hours to pay employees who have
either had covid or have been exposed to someone who has. I think
the ban of gas equipment will be detrimental to not only our small
business but the industry as a whole. We have had to over come a
few large hurdles in the past 5 years we don't need another one.  I
feel if there is proper funding for direct replacement of equipment
that will be the only way company's will be able to survive.  I
also find it interesting that the automobile wis given over 15
years to do research and development to eliminate the sale of gas
viechles by 2035 but the landscape industry is only given 2 years?
I strongly advise administration to think about the consequences
before passing this law. 

Attachment
Original File Name
Date and Time Comment Was Submitted 2021-11-19 15:59:13

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