On June 27, the EPA held a virtual public hearing that allowed people to testify over a new waiver proposal. The California Air Resources Board (CARB) submitted a request for waiver from the Clean Air Act to the EPA seeking to implement more stringent emissions regulations for small off-road engines (SORE). Broadly, SORE includes lawn, garden and other outdoor power equipment as well as specialty vehicles. The regulations would require SORE equipment 25 hp and under, starting with model year2024, to meet zero emissions standards. This means all SORE equipment for sale in California, including various types of aerators, mowers and other equipment commonly used on golf courses, would have to be battery-powered instead of gas-powered. It’s important to note that under CARB’s proposed regulation, use of gasoline-powered equipment may continue past the implementation date of Jan. 1, 2024, but the manufacture and sale of such equipment would be prohibited in California.  

While GCSAA appreciates and recognizes some of the benefits and value of certain pieces of zero-emissions equipment (ZEE) and supports its use, GCSAA also recognizes the needs of golf course superintendents in managing golf courses, and some of those needs are not met by ZEE currently on the market, nor will they be by Jan. 1, when the California regulations take effect. GCSAA’s comments submitted to EPA’s docket reflected this reality. 

Michael Lee, senior manager of government affairs at GCSAA, provided oral comment on behalf of superintendents. Because the EPA has a long a history of granting similar waivers to the state of California for other emissions related rules, instead of opposing the waiver outright, GCSAA requested that EPA grant an extension to the current implementation deadline for “commercial and professional grade equipment.” As conveyed by many superintendents during EPA’s open comment period, the current technology of ZEE is not at a capacity for commercial landscapers to use dependably. The batteries are expensive, charging times are long and some equipment does not have emissions-free models, among other reliability issues. Charging infrastructure at most golf course maintenance facilities is also lacking at the scale required to power entire fleets of equipment. Lee asked the EPA to consider the difference between professional and personal use of SORE regarding runtime, range and specialty equipment. While a battery-powered mower may be appropriate for a small lawn, the necessity for increased reliability is much higher among superintendents and their crews who depend on the equipment for hours at a time every day.

GCSAA asks that the EPA consider the mutual needs of equipment manufacturers and consumers. An extension of the current Jan. 1 deadline would allow manufacturers additional time needed to develop, produce and ship ZEE equipment that is dependable and fit for commercial and professional use.