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To CARB:

I am a third generation gardener. I, along with my brothers and my
father, own a landscape maintenance contracting company in the Los
Angeles area. To build our commercial gardening business has been
both the most incredibly challenging and most rewarding
professional endeavor.

I believe this new proposed regulation, while crafted with great
intentions, parts of it are greatly mistaken and have the potential
to bring incredible harm to small and what I imagine are
predominately minority business owned enterprises.

We have experience using battery powered equipment. We purchased
the commercial grade battery set available from STIHL. We also use
4 of their blowers combined with the AR 3000 backpack battery. This
is the most powerful battery option available in the market today.
In our experience this battery set up has a real run time of about
2 hours. This forces us to purchase more batteries if we want to
perform the full day.

While a STIHL BR 500 (gas powered) blower costs about $500, the
commercial battery option costs about $1500 plus another $1000 for
an extra battery pack. The battery option for the commercial
gardener costs $2500 minimum when the goal is full day performance.
This price tag of 5x is an incredible burden. Not to mention the
increased repair costs and decreased longevity of this option. I
would encourage you to talk to lawn mower repair shops that are
familiar with this such as Garvey Equipment in San Gabriel.

Another factor is increased labor due to more limited portability.
If a job takes slightly longer due to battery run time concerns or
we have to be swapping batteries this increases labor. Labor is
another extreme challenge we face. There are no prospects of labor
becoming more available or less expensive.

To finalize, I would plead to the CARB board to consider making
some sort of exception for commercial enterprises. The use for us
is not the same as it is for a homeowner. 

This regulation for us is like handing us a weighted backpack while
we attempt to hike. a steep hill.