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Comment 463 for Amendments to the Small Off-Road Engine Regulations: Transition to Zero Emissions (sore2021) - 45 Day.

First NameJoshua
Last NameDrake
Email Addressjdrake@mtadistributors.com
AffiliationMTA Distributors
SubjectZero Emissions on SORE
Comment
MTA Distributors, LLC is a distributor of small lawn & garden
equipment. The company serves a network of both manufacturers of
small equipment and small retail businesses in California, such as
hardware and lawn and garden stores.  We supply these small
businesses with Honda engines and dozens of different pieces of
equipment powered by internal combustion engines.  

While the proposed mandate of no internal combustion engines would
negatively impact the lives of our 60 employees, we do not make
this appeal primarily on our own company's behalf.  Instead, we
make it on behalf of the thousands of employees of our customers'
businesses that we serve.  Many of these Californians would be
instantly unemployed by this legislature.  Last year, we served 631
businesses in California, each employing anywhere from 2 to 40
people. At a conservative estimate, this would represent 2,500
Californians that we currently serve who would be unemployed by
this policy.  This is not even to consider the many employees
served by our competitors.  Moreover, this legislation will create
new financial burdens for all Californian homeowners, and it would
be most painful for the lower income households.  A battery powered
zero-turn mower costs 33% more than its gas-powered equivalent. 
This extra cost will be passed down from the landscaping companies
that service low-income apartments straight through to the
tenants.

Of course, we share your concern for protecting our environment. 
We all desire to care for the earth and work hard to build a
sustainable future.  In fact, MTA has even created an entirely new
staff position for developing green energy.  However, this
legislation will not achieve the intended outcome of reducing
ecological damage. In fact, the net effect of this dramatic
legislation is actually worse for our environment. Any deeper look
into the realities of increasing battery adoption will reveal that
the energy equivalent of 100 barrels of oil is used to make a
battery that can store the equivalent of one barrel of oil (M.
Mills), meaning a move away from combustion engines could cause a
100-fold increase in energy consumption. Furthermore, it is
demonstrated that "green" equipment requires ten times more
material than fossil-fuel equivalents, and 500,000 pounds of ore
must be mined in order to produce 1 battery for an electric car (M.
Mills). 

Please do not attempt a future and putative gain in human welfare
at the expense of an immediate and certain loss of it. We feel
strongly that a more thoughtful and more measured approaches to
alternative energy will better serve both humanity and our precious
environment. 

Attachment
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Date and Time Comment Was Submitted 2021-11-22 13:15:12

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