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My name is Jay Martinez, owner of JVM Landscape Construction, Inc.
in Sacramento, CA. We are a small business, with full-time
employees, serving the greater Sacramento area. We primarily are a
landscape design and build company, specializing in residential
homes. 

In reference concerning Proposed Amendments to the Small Off-Road
Engine Regulations, Transition to Zero Emissions, Initial Statement
of Reason (ISOR) (published October 12, 2021) I would like to
humbly ask for your support, to support an amendment to the ISOR,
delaying implementation of the transition to Zero Emissions
Equipment for commercial/professional grade small off-road engines
until model year 2028 or later. As a Small business owner, use of
the small engines in questions are crucial to our operations. 

This proposed ruling would hurt our staff, to perform essentially
duties on the jobsite in a safe and effective manner. This ruling
stands to hurt small business owners of color, and employees of
color the most as it stands. I know this first hand as a
practitioner, and a veteran of the landscape industry for several
decades. The additional time would be much needed to allow
professionals to further acclimate to an environment better suited
and tailored to transition to all electric ZEE.

Thank you for your consideration. Feel free to reach out to me
anytime for more information.

Jay Martinez
President 
JVM Landscape Construction, Inc.