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Transition to zero emissions equipment CARB regulations

Transition to zero emissions equipment

California Air Resources Board small off-road engine regulations

by the National Association of Landscape Professionals

In October 2021, California Governor Gov. Gavin signed a bill that would require new small off-road engines (SOREs), used primarily for landscaping, to be zero-emission by 2024. The legislation comes with $30 million in funding to help aid the transition.

The National Association of Landscape Professionals submitted a request to the California Air Resources Board (CARB) to support an amendment to the ISOR and delay implementation of the transition to Zero Emissions Equipment (ZEE) ONLY for commercial/ professional grade small off-road engines (SORE) prior to the deadline at midnight on November 29, 2021. The comments are the culmination of all the arguments NALP has been making since April 2021 and is supported by both qualitative and quantitative data.

The message remains the same: We share Governor Newsom and other California policymakers’ intent to reduce carbon emissions from gas-powered landscape equipment as quickly as possible. Still, we must do so in a responsible manner that mitigates the negative financial impact on the landscape industry.

California's landscape industry is a $9 billion industry annually with more than 55,000 companies employing over 133,000 employees; 99% of these businesses are considered small businesses and a vital industry for entrepreneurs throughout the state of California, many of which are Latino, or minority owned. The comments then specifically articulate issues with the electric equipment performance, cost and lack of infrastructure to support. Our solution is a delay for “commercial grade equipment” which makes up only 15% of carbon emitting equipment in California. Additionally, we note the need for more funding. On December 9, 2021, CARB met to discuss the transition to ZEE and ban the sale of all SORE gaspowered landscape equipment beginning 2024. The meeting lasted nearly six hours starting with CARB staff presenting the item and their proposal to the Board. CARB staff provided the board with some of the concerns stakeholders have expressed and what the staff responses were in regard to the concerns. NALP, along with 60 others, testified with a two-minute limits. More than 40 testified against the rule and proposal; however, the proposal was still approved by the Board. The Board, in acknowledgment of industry concerns, will be amending the rule in a final 15-day open comment period to create a “industry task force” to review implementation and report to the Board next year, which will allow them to make changes if needed to extend the timeline for certain industries or specific equipment beyond 2024. NALP anticipates being part of this task force. Additionally, CARB is committed to assisting in providing additional funding for rebate programs for small businesses and NALP will continue to work with CARB on funding and implementation. California will now have to apply to the EPA for a waiver and NALP has already begun those discussions regarding our concerns. No other state or locality can ban the sale of this equipment at this time due to federal preemption pursuant to the Clean Air Act. This issue remains a top priority for NALP and we will continue to provide updates as we advocate on behalf of the industry for responsible policies to transition the industry to non-carbon emitting equipment.

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