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Comment 13 for Amendments to the Small Off-Road Engine Regulations: Transition to Zero Emissions (sore2021) - 45 Day.

First NameAlan
Last NameMetzger
Email Addressalanm@walker.com
AffiliationWalker Distributing Company
SubjectZEE Limitations on Large Zero-Turn Mowers
Comment
I am the GM of distribution for Walker Distributing, based in
Colorado. I wanted to point out one of the current limitations of
batteries for large equipment - specifically the duty cycle
requirements for landscapers using zero-turn mowers.

The typical all-electric ZT mower today (see the Greenworks GZ
series) will offer about 1.75 hours of use at full speed, and then
they will require as much as 12 hours to recharge. The battery is
so large that it does not allow user replacement on the fly. This
simple configuration yields a predicted duty cycle of 1.75 / 13.75
= 12.7%. That is, a landscaper could use this mower for less than
two hours and then would have to park it for up to 12 hours before
using it again. To work straight through an 8-hour day, a
landscaper would have to purchase five of these mowers. That is an
unusually large burden on the typical landscaper.

Battery equipment that can be easily changed on the fly - like
modular batteries for chain saws, trimmers, etc - is ready for the
new policy. But for certain types of equipment, such as large items
(like zero-turn mowers), the viable technology is still many years
away. I ask that you consider exempting zero-turn mowers 17
horsepower and above from the regulations under AB 1346.

Thank you for your consideration.

Alan Metzger

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Date and Time Comment Was Submitted 2021-12-09 12:24:45

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