UPDATE DECEMBER 20, 2021
(See communication between Jimmy Welch, CETA Technical Chairman and Christorpher Dilbeck, CARB Board)
Thanks for your clarification on the proposed emission standards for model years 2024 through 2027.
Looking forward to your responses to all comments received during the formal comment period and during the hearing as well as the modified text for 15-day public comment.
Thanks again for listening to our comments, concerns, and questions.
CETA Technical Committee Chairman
Thanks, again, for your engagement in this rulemaking and for your thoughtful comments. We will release modified text for a 15-day public comment period shortly. The proposed emission standards for model years 2024 through 2027 are in Tables II-1 and II-2 in the Staff Report. The proposed emission standards for model year 2028 and subsequent model year generators are zero. We proposed to include 15-day changes to subject pressure washers ≥ 225 cc to the same emission standards as generators of the same displacement (note a more stringent emission standard for > 825 cc engines than for 225-825 cc).
We will respond to all comments received during the formal comment period and during the hearing.
Compliant and CARB-certified engines with complete evaporative emission control systems can be installed after the date of production into equipment.
Table II-1. Current SORE exhaust emission standards and exhaust emission standards under the Proposed Amendments
|Displacement category||Current HC + NOx emission standard
|Proposed HC + NOx emission standard for MY 2024-2027 generators
|Proposed HC + NOx emission standard for all other SORE for MYs 2024 and later
|< 50 cc||50||6.0||0.00|
|50-80 cc, inclusive||72||6.0||0.00|
|> 80 cc – < 225 cc||10.0||6.0||0.00|
|225-825 cc, inclusive||8.0||3.0||0.00|
|> 825 cc||8.0||0.80||0.00|
Table II-2. Current SORE evaporative emission standards and evaporative emission standards under the Proposed Amendments.
|Displacement category||Current diurnal emission standard
|Proposed hot soak plus diurnal emission standard for MY 2024-2027 generators
|Proposed hot soak plus diurnal emission standard for all other SORE for MYs 2024 and later
|≤ 80 cc||N/A||0.50||0.00|
|> 80 cc – < 225 cc except walk-behind mowers||0.95 + 0.056 × nominal capacity (liters)||0.60||0.00|
|> 80 cc – < 225 cc walk-behind mowers||1.0||N/A||0.00|
|≥ 225 cc||1.20 + 0.056 × nominal capacity (liters)||0.70||0.00|
Christopher W. Dilbeck, Ph.D.
Manager, Testing and Certification Section
Monitoring and Laboratory Division
California Air Resources Board
VOIP: (916) 720-2099
Desk: (916) 319-0106
Subject: CETA Thanks CARB STAFF & BOARD
Thank you for your phone call on Wednesday afternoon informing me that CARB Staff would be presenting to the CARB Board at the hearing for pressure washers to follow the generator time line for > 225 cc.
It was GREAT to see the presentation with this proposed revision.
Slide 26 from December 9, 2021 CARB Board Meeting
Thank you for listening to our comments and concerns.
Are these potential exhaust and evaporative standards the final decision?
Slide 29 from March 24, 2021 CARB Workshop Staff Presentation:
- Engines will change for 2024 > 225 cc:
Emission HC+NOx 3.0 g-kWh-1 and Evaporative hot soak + diurnal, g-test-1 0.70
2. ZEE for 2028:
Set emission standards for generators to zero1 for Model Year 2028 and implement a zero-emission generator credit program
1 Emission standards of 0.00 g·kWh-1 (exhaust) and 0.00 g·test-1 (hot soak + diurnal)
During the hearing their were some questions about federal preempt equipment including pressure washers and staff answered it may be but will be looked into. Please keep us informed on this.
Please varify that the regulation is for the engine (produced and properly labeled) in stock can be installed on equipment after the date.
Looking forward to continuing to work with you and other staff members on market readiness.
CETA Technical Committee Chairman
UPDATE DECEMBER 15, 2021
*Clicking blue directs you to their website
We apologize for the delayed update, but we have a “WIN” and are still celebrating!
We would like to thank everyone that participated in this first “WIN” with the CARB SORE Staff & Board which allows engines > 225 cc produced after January 1, 2024, and sold for use on pressure washers into California to follow the same new reduced emission (exhaust & evaporative) regulations as generators till January 1, 2028 at which time ZEE will be required.
While we wait for CARB Staff to officially reply the following is a summary of the new reduced emission requirements:Engines will change for 2024 > 225 cc:
- Emission HC+NOx from 8 to 3.0 (Reduction of -5) g-kWh-1
- Evaporative diurnal, g-test-1 from 1.20 + 0.056 x normal capacity (liters) to hot soak + diurnal, g-test-1 to 0.70
- ZEE for 2028:
- Set emission standards to zero1 for Model Year 202
- 1 Emission standards of 0.00 g·kWh-1 (exhaust) and 0.00 g·test-1 (hot soak + diurnal)
NOTE: This is no easy task, and we need to continue to support our engine and equipment manufacturers as they work towards these aggressive reduction requirements.
During a Friday, December 3, 2021, meeting with CARB Staff we were able to express our concerns, comments, and questions with presentations from each of our member groups (Supplier, Manufacturer, Distributor, & Commercial Pressure Washer).
On Wednesday, December 8, 2021, CARB Staff contacted us to let us know they listened to our comments and decided to present to the Board for pressure washers > 225 cc to follow the same requirement for generators.
On Thursday, December 9, 2020, during the CARB Board meeting Staff presented their proposal, comments were heard, and the Board asked Staff to comment on numerous concerns before a vote was taken to approve Staff’s proposal.
As we know, as CARB introduces and passes more stringent emission regulations other states as well as federal (EPA) will follow so, please continue to support CETA in our efforts. In reality, this not only affects our current members all across North America but also non CETA members so, please join CETA and support our industry.
This is a “GREAT WIN” for our industry, and we would like to recognize our committee members and those who worked diligently throughout this process. A special thank you to those who testified on the industries behalf. Gregg Brodsky, Jim O’Connell, Michael Ricketts, Casey Meekler, Alan Bonifas, Eric Tower along with Jimmy Welch and myself. Furthermore, we would be remiss if we did not recognize Debbie Murray and Tracy Wagoner our awesome CETA Staff who continually goes above and beyond to keep us organized and on task.
The CETA SORE Committee and CETA Staff will continue to collaborate with the SORE Staff as there is still work to be done.
R.Calvin Rasmussen & Jimmy Welch
CETA SORE & Technical Committees
UPDATE NOVEMBER 30, 2021
*Clicking blue directs you to their website
We would like to thank everyone that took the time to send in your comments. See below CETA’s response. You can click on Board Meeting Comments Log (ca.gov) to see responses. CETA is number 483. CETA is making preparations for the hearing set for December 9, 2021.
November 24, 2021
Dorothy Fibiger, Ph.D.
California Air Resources Board
1001 I Street
Sacramento, CA 95814
RE: Comments with respect to the “Public Hearing to Consider Proposed Amendments to the Small Off Road Engine Regulations: Transition to Zero Emissions”
Dear Ms. Fibiger,
The Cleaning Equipment Trade Association (CETA) is an international non-profit trade association made up of manufacturers, suppliers, distributors, contractors/end users, and associates. All these members coordinate efforts to promote public awareness, professionalism, industry-wide safety standards, and education for the advancement of the powered cleaning equipment industry. Environmental regulations and lobby efforts are not inside CETA’s regular scope of work, but we strive to educate our members to promote best practices across the industry.
From that perspective, we have been working to understand the Proposed Amendments related to Small Off-Road Equipment (SORE Amendments or Amendments). We appreciate the opportunity to meet and discuss the Amendments, as without a doubt, they will be incorporated to our industry’s best practices. CETA members are committed to environmental improvement and societal benefit. Many of our members in the State of California are engaged in and empowering contractors to control the spread of disease, combat aquatic invasive species (AIS), lower water usage, and extend the life of materials and structures in corrosive or oxidizing environments. CETA members in the State of California also adhere to state and municipal regulations for the propane burners often used with commercial pressure washers and water reclamation in accordance with the Clean Water Act. From a societal benefit standpoint, CETA members create jobs, supply an extremely low barrier to entrepreneurship, and beautify through cleaning the countless retail, recreation, and tourist attractions for which the State of California is world renowned.
The main tool for a mobile, commercial, cleaning contractor (mobile cleaner) is currently a high-pressure washer. In majority, these tools for these contractors are powered by an internal combustion engine between 225cc to 825cc, and often having a combustion heating element (burner) to increase the cleaning efficiency of the high-pressure stream of water. Comparable to commercial landscapers, mobile cleaners use this tool as a full-time job, typically 6 hours per workday and 200 days per annum.
In contrast to commercial landscapers, the number of mobile cleaners is significantly fewer and many commercial cleaners in California work at night. Many users enter the industry by buying a pressure washer powered by an internal combustion engine smaller than 225cc. The reason mobile cleaners select tools of this description is, high pressure increases the cleaning efficiency, lowers the time and water used, and there is high mobility from the equipment being light weight and compact. The higher the pressure of water, the more efficiently a contaminant is lifted from a surface, or an adhesion is broken requiring less water to loosen the contaminant without chemicals or solvents. From industry member data, the higher flow rates commonly shown in gallons per minute disproportionately lowers the amount of time it takes to clean. The net effect of this is not just increased productivity for the contractor, but also lower water usage. A simple example of this from industry data is that with all other factors being equal 2 GPM flow takes 15 minutes to clean a surface while a 4 GPM flow will take 5 min resulting in a 33% lower water consumption. As an industry best practice, commercial cleaners find the increased efficiency and choose pressure washers greater than 3000 PSI and with flows greater than 3 GPM. The vast majority of units used by mobile cleaners is actually closer to 4000 PSI and 4 GPM, but for the sake of illustration, the 3000 PSI at 3 GPM product will be discussed in more detail. As an example of this difference, a common usage for high pressure washers by municipalities in California is to remove graffiti. This is done whether the municipality buys the pressure washer or contracts with a mobile cleaner. Industry experience shows 4000 PSI will remove graffiti, but 3000 PSI will not.
As said previously, CETA is committed to environmental improvement. Our members’ focus on meeting local propane consumption requirements proves our dedication to improved air quality. While reviewing the Initial Statement of Reasons (ISOR) for the proposed amendments, our membership has expressed detailed concerns which CETA would like to discuss. We look forward to some solution to continue helping the society of California.
About the Proposed Amendments, the main concern is the inability for mobile cleaners to source the main tool used by themselves, their employees, and businesses from 2024. Considering no efficiency loss and not considering the common industry practice those engines should be used at 85% of maximum capacity or less, a 3000 PSI and 3.0 GPM pressure washer needs an input of 5.25 Hp. This converts to 3.9kW which will help illustrate the issue for electric pressure washers.
Common outlets for 120V power at residences or businesses are 15a and sometimes 20a. An Alternating Current Pressure Washer consuming 3.9kW of electricity from a residential outlet would require 32.5a continuously. This explains the phenomenon that all ACPW in the US are roughly half the output of what industry would consider even a residential pressure washer. The conversion of mobile cleaners to ACPW would require adoption of 220V single phase or 3 phase electricity to be common in residences and businesses to maintain the current levels of water conservation and cleaning efficiency provided by higher pressures. In the case of disease control in major CA metropolitan areas, AIS abatement, and disaster clean up, readily available access to these electrical requirements cannot be assumed. Compounding this issue is the common commercial usage of cleaning outside of normal business hours specifically at office parks and retail locations. Beyond this, the in-rush current or starting amperage of electric motors are significantly higher than the operating current further limiting the ability of ACPW to be adopted for commercial use.
When considering Direct Current Pressure Washers, larger current flow is needed to compensate for the lower (battery) voltages compared with ACPW. Energy requirements of the battery eliminate any kind of mobility. Commercially, there are no DCPW’s over 3000 PSI that exist.
CARB’s published data reflects that the vast majority (1.86M) of residential pressure washers are already ZEE. The estimated data also reveals that non lawn & garden business ownership of pressure washers accounts for 1.3% of gas-powered equipment in California. Most self-identified Commercial Pressure Washers in California’s SORE2020 model are used for fewer than 128 hours per annum. Considering the high usage hours of the mobile commercial cleaners that CETA represents (6hrs / day & 200 days / year), this indicates the average usage hours of businesses who buy a commercial pressure washer are much smaller than 128 hours per annum. Conversely, this also indicates the mobile cleaners discussed here are a fractional part of the pressure washer population in the state of California. Further to this, CETA estimates the population of truly commercial pressure washers to be less than 10% of SORE powered pressure washers in the SORE 2020 model.
As is the case with generators, today there is no viable option for replacement of SORE in what would be considered a professional pressure washer. Pressure washers are as indicated above are a vital tool contributing to small business, health, and well-being of the state of California. CETA respectfully requests to work with CARB towards a proposal of mutual benefit and looks forward to a partnership resulting in a cleaner tomorrow.
2021-2022 CETA Technical and Standards Committee Chairman
UPDATE NOVEMBER 4, 2021
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Notice of Public Hearing to Consider Proposed Amendments to the Small Off-Road Engine Regulations: Transition to Zero Emissions
Take Action Now!
A Brief Summary is Below:
- CARB plans to ban sales of new internal combustion engine-powered equipment 1/1/2024.
- Currently no viable alternative for commercial pressure washers with ICE
- Commercial Pressure washers are not Pre-empt
- There will be a public hearing to consider amendments of “transition to zero” 12/9/2021
- The public comment period for this regulatory action started on October 15, 2021. Written comments will not be accepted later than November 29, 2021.
What We Need YOU to do TODAY
- Mail or electronic submit your comments to the California Air Resources Board expressing your opposition to the bill and proposed regulations.
- Email your elected officials in one click! (Red button below)
- Attend the December 9th hearing at the California Air Resource Board, Byron Sher Auditorium
LET YOUR VOICE BE HEARD!
Clerks’ Office, California Air Resources Board
1001 I Street,
Sacramento, California 95814
See Current Comments
Example of Customer Comment
I am a (commercial cleaner/ an industrial supplier to commercial cleaner / small business owner operating a commercial cleaning business) servicing (municipalities / office parks / retail /residential customers) in the greater _______ area for the last ____ years.
I proudly come from the ______ community located in ______ county. I employ X workers and we take great pride in the service we provide the community.
Within the last year, we partnered with ____ to clean _____ and the (main / most efficient) tool we use is an internal combustion powered pressure washer. Beyond this we have x of crews working daily. The mandate of no internal combustion engines being considered would eliminate the jobs of nearly all of our staff.
We care deeply about a clean environment for both the health of our neighbors and beauty of our community. (where applicable) We have participated in water recovery / water treatment as well as propane burner usage in accordance with all state and local regulations.
Thank you for your consideration.
Send an Email to your Official with One Click!
Here is the link developed by OPEI and NALP which equipment dealers and users can submit a prepared message to CARB and their California Legislators.
UPDATE – 10-18-2021
We appreciate the engagement of the Cleaning Equipment Trade Association on the small off-road engine (SORE) regulation workshops and are hoping that will continue as the rulemaking progresses. Our rulemaking package has been posted online, and the 45-day comment period opens on October 15, 2021, and closes on November 29, 2021. We invite you to meet with CARB staff and discuss any questions, comments, or concerns you have about the proposed amendments to the regulations, staff report, or any other rulemaking documents. If you would like to meet with us, please reply and let us know if you would prefer a 30-minute or 1-hour meeting. If you prefer to communicate via email, please send us any questions that you have. Comments for the rulemaking record should be submitted via the Public Comment interface. Below is a summary of the proposed rulemaking. The full staff report and proposed regulations can be found on CARB’s website. This rulemaking will be considered by the Board on December 9 and/or 10, 2021. The Board has not yet taken any action on this rulemaking.
Thank you again for your engagement in the rulemaking process. We look forward to hearing from you.
Dorothy Fibiger, on behalf of the SORE Rulemaking Team
Summary of Proposed 2021 Small Engine Rulemaking
In this rulemaking, California Air Resources Board (CARB or Board) staff is proposing amendments to the Small Off-Road Engine (SORE) Exhaust and Evaporative Emission Regulations and Test Procedures (collectively, Proposed Amendments). SORE are nonroad, nonstationary spark-ignition engines with rated power at or below 19 kilowatts (25.5 horsepower). This rulemaking would not affect emission standards for other classes of engine, or apply to engines regulated solely by the federal government. The Proposed Amendments would transition SORE equipment to zero-emission equipment (ZEE) as soon as possible. The deployment of ZEE is necessary to attain ambient air quality standards and protect the health and welfare of all California residents. The Proposed Amendments are also necessary to meet the requirements in California Executive Order N-79-20, which sets a goal to transition off-road vehicles and equipment operations to 100 percent zero-emission by 2035 where feasible. The Proposed Amendments also include updates to the SORE regulations to help minimize noncompliance and help ensure that SORE equipment sold and used in California will comply with the exhaust and evaporative emission standards throughout its lifetime. The Board will consider the Proposed Amendments at a public hearing on December 9 and/or 10, 2021.
Emission Standards for New SORE
The Proposed Amendments would set emission standards for smog-forming pollutants to zero for all new SORE except for generator engines (see below) beginning with the 2024 model year. The Proposed Amendments would make the emission standards more stringent for generator engines beginning with the 2024 model year. Beginning with the 2028 model year, the standards would be set to zero for generator engines. The SORE regulations and the Proposed Amendments do not apply to stationary generators.
Existing Equipment Is Not Affected
The proposed new emission standards would apply to manufacture of new engines for sale or lease in California. No restrictions on the possession, use, or repair of existing CARB-compliant SORE equipment are being proposed. Under the Proposed Amendments, California residents and businesses can continue using their CARB-compliant SORE equipment, and repair it, until end of its life. Stores may continue to sell any engines and equipment that were manufactured under valid CARB certifications.
Potential Effects of the Proposed Amendments
This proposed rulemaking is key to meeting the expected emission reductions in the Revised Proposed 2016 State Strategy for the State Implementation Plan, the goals of California Executive Order N-79-20, and AB 1346. There is a delayed phase-in for generators to allow time for the zero-emission generator market to develop. Manufacturers would be able to use emissions credits earned prior to model year 2024 on any SORE equipment, including generators, to help meet the standards until the credits are used up. Some users may see savings when using ZEE, while there will be a net cost to other users. Emission modeling shows that this proposal will achieve major reductions in smog-forming pollutant emissions from SORE: 43% reduction in oxides of nitrogen (NOx), and 51% reduction in reactive organic gases (ROG), in 2031, compared to the existing regulations. These emission reductions would result in significant health benefits for Californians, and the economic value of these benefits and other cost-savings from using ZEE would exceed the costs of implementing the Proposed Amendments.
On Saturday, October 9, 2021 California Governor Newsom signed AB-1346 to set zero emission SORE limits. OPEI and several associations including NALP and CETA worked to oppose the bill. The result was several amendments in the Senate, but ultimately the bill passed and has now been signed by the governor, directing CARB to adopt a rule by July 2022 to set SORE zero-emission limits by MY 2024, or when technical feasible, whichever is later. The state has budgeted $30M towards incentive programs.
This would ban the sale of new gas-powered equipment using small off-road engines, a broad category that includes generators, lawn equipment and pressure washers.
Focus now shifts to CARB “formal” rulemaking and comment period, which is expected to kickoff this week or next by way of the publication of the Initial Statement of Reason (ISoR). The Board hearing is expected to be December 9-10.
For complete information link to the SORE page https://ceta.org/news/sore-2021/.
California AB-1346 SORE (Small Off-Road Engines)
AMENDED IN SENATE AUGUST 26, 2021
Use this link to follow the state bill https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202120220AB1346
(1) By July 1, 2022, the state board shall, consistent with federal law, adopt cost-effective and technologically feasible regulations to prohibit engine exhaust and evaporative emissions from new small off-road engines, as defined by the state board. Those regulations shall apply to engines produced on or after January 1, 2024, or as soon as the state board determines is feasible, whichever is later.
(2) In determining technological feasibility pursuant to paragraph (1), the state board shall consider all of the following:
(A) Emissions from small off-road engines in the state.
(B) Expected timelines for zero-emission small off-road equipment development.
(C) Increased demand for electricity from added charging requirements for more zero-emission small offroad equipment.
(D) Use cases of both commercial and residential lawn and garden users.
(E) Expected availability of zero-emission generators and emergency response equipment.
(b) Consistent with the regulations adopted pursuant to this section and relevant state law, the state board shall identify, and, to the extent feasible, make available, funding for commercial rebates or similar incentive funding as part of any updates to existing, applicable funding program guidelines for districts to implement to support the transition to zero-emission small off-road equipment operations.
For complete information, link to the SORE tab.