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I appreciate the ARB's efforts to regulate evaporative emissions
for small off-road engines (SORE). However, I would urge ARB also
to consider regulating the overall combustion emissions and use of
these engines, particularly on "spare the air" days in the Bay Area
and other major populated areas.

You know better than me the inefficiency of SOREs as combustion
engines, and that one lawn mower is the equivalent of more than 10
cars. In my area of San Mateo, it is not uncommon to see many lawn
and garden services working daily (I counted 13 on a 4 mile morning
jog through my neighborhood). Considering that each of these "mow
and blow" services use multiple SORE-powered machines to do their
work, the impact on our local pollution and that of the wider Bay
Area is potentially significant.

I would urge ARB to consider regulations to improve the
combustion-efficiency of SOREs, AND to regulate their use
particularly on "spare the air" days. In addition, I would like to
see greater encouragement of the use of electric, or
battery-powered lawn and garden equipment to reduce pollution.

I would be happy to engage with you further on this issue. Thank
you.