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Comment 97 for Amendments to the Small Off-Road Engine Regulations: Transition to Zero Emissions (sore2021) - 45 Day.

First NameAlan
Last NameDay
Email Addressalan@ladybuglawn.com
AffiliationLadybuglawn
SubjectElectric vs. Gas Landscape equipment
Comment
While the goal of reducing emissions by eliminating gas powered
landscape equipment is worthwhile, the alternative technology just
does not exist that would be powerful enough and cost effective
enough for commercial maintenance applications. 

For example: we have typically in each of our commercial landscape
maintenance trailers two each gas powered: blower, mower, hedge
trimmer and string edger. Eight pieces of equipment that on average
are used about six hours a day each, that's 48 hours of run time
needed. Equipment that is powerful and can deal with 105 degree
heat, cold near freezing, rain, UV, wet heavy leaves, wet lawns
very efficiently.  

For the alternative equipment battery life is all over the place
and often what's listed is best case, not taking into account that
heat, cold, exposure to rain and UV, heavy power drains like wet
leaves or wet grass all reduce battery life and battery power
(battery power is not constant like gas power) very quickly. So for
our eight pieces of equipment used about six hours a day each we
would need on board at least how many batteries? Dozens ... with a
charging/holding rack that could hold them.

We'd need a new trailer for our trailer to handle the extra weight
and charging racks, not practical, and at how much additional cost
if it was? Or we load it all onto the pickup truck and since it has
to be protected from the elements and theft, we lose the
storage/hauling capacity of the truck. Then we need additional
separate trucks and crews for hauling, what are the costs both
financially and to the environment, to all the extra trucks and
trailers? Very, very significant. 

As for charging ... out trucks run for maybe five minutes as we go
between accounts, then they sit idle/not running when they at an
account for thirty minutes or more. Could all those batteries be
recharged for the next day given those short run times between
accounts? Or would we need a whole separate, massive, charging
station at our small storage yard? By the way, we don't have extra
room for a charging building (has to be indoor, can't be exposed to
the elements or theft), or even electricity for that matter, at our
storage yard. How would we do it and at what very significant
capital investment costs?

What about overall battery life? Not long I suspect with all that
heavy use, in extreme conditions, a few months to a year? So now
you are talking about millions upon millions of dead batteries
annually, that have to be replaced frequently at large cost ... and
that are potentially toxic in and of themselves. Maybe half get
properly recycled ... but the other half are going to end up in the
landfills. What's the cost, both financial and environmental, to
that?

How will this rapid forced change affect the one person commercial
operation? The small operation with a couple of crews? The larger
operations with fleets? How will the many significant costs, and
these are not incremental costs, get passed on to the consumers?

So, while the goal of reducing emissions is worthwhile it does not
appear that this has been thought out, researched or studied. And
it needs to be studied in the field, over time/several years in
different seasons and weather conditions and on the scale needed.
Please do so before implementing any mandates.

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Date and Time Comment Was Submitted 2021-11-12 10:56:58

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