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Comment 495 for Amendments to the Small Off-Road Engine Regulations: Transition to Zero Emissions (sore2021) - 45 Day.

First NameFiliberto
Last NameFonseca
Email AddressF.Fonseca@newpathlandscape.com
Affiliation
SubjectSmall engines gas ban will be detrimental to our business
Comment
To whom it may concern,

I would like to share my sincere concerns towards the proposed gas
small engines ban. We are a commercial landscape business that has
been in operations since 2006 and currently employs over 100 full
time employee's. Having personally been in the landscape industry
since 1998 I feel that I have gained the experience necessary to
provide real insight on this matter. We have had a few small
municipalities in our service area implement a gas powered small
engines ban over the years. Fortunately those clients were not
large properties, therefor there was not a lot of area to maintain.
In an effort to continue to service those clients we invested in a
small number of battery operated pieces of equipment, blowers and
hedge trimmers. Unfortunately not all of our clients were willing
to accept a surcharge for the necessary acquisition of new
equipment. Therefore we had no choice but to absorb the cost. 
Prior to acquiring the equipment we were informed by the
distributors/suppliers that there was nothing available on the
market at the time that would be efficient enough to use on a
competitive level when compared to the gas powered equipment. The
amount of batteries required to operate the equipment for the hours
which we require would make the initial investment alone more than
2.5x that of the gas powered equipment. The ROI in gas savings was
well over 2 yrs. Another big hurdle for us has been the ability to
charge the batteries while on a job in a reasonable amount of time
along with short battery life.  There will also inevitably be
locations were charging the batteries onsite will not even be an
option. 
If there is a state wide ban, we will most certainly find ourselves
in a position in which we will not be able to provide our larger
clients the same level of service in the same duration of time.
This will force us to renegotiate our service contracts at a higher
rate to account for the neccesary added service time. There is no
guarantee that our clients will be willing to increase our fees,
and in most cases will seek out less expensive alternatives. In
essence creating a situation for cheaper competitors to take
business away, that otherwise would not have existed. 
Without stating every single challenge the ban would impose on our
business, I can truthfully say it will create a drastic negative
impact to our business. I plead to those in power to genuinely
consider the strain this will impose on businesses like ours that
utilize such pieces of equipment. And to please wait until the
technology has advanced to the point where the battery powered
option is really viable. Thank you. 

Attachment
Original File Name
Date and Time Comment Was Submitted 2021-11-26 14:08:28

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