UPDATE NOVEMBER 4, 2021

*Clicking blue directs you to their website

Notice of Public Hearing to Consider Proposed Amendments to the Small Off-Road Engine Regulations:  Transition to Zero Emissions

Take Action Now!

The California Air Resources Board (CARB or Board) will conduct a public hearing at the date and time noted below to consider approving for adoption the Proposed Amendments to the Small Off-Road Engine Regulations: Transition to Zero Emissions (hereinafter referred to as the Proposed Amendments).·     Location: California Air Resource Board, Byron Sher Auditorium

·     Address: 1001 I Street, Sacramento, California 95814

·     Date: December 9, 2021

·     Time: 9:00 A.M.

This public meeting may continue at 8:30 a.m., on December 10, 2021. Please consult the public agenda, which will be posted ten days before the December 9, 2021, Board Meeting, for important details, including, but not limited to, the day on which this item will be considered and any appropriate direction regarding a possible remote-only Board Meeting. If the meeting is to be held in person – in addition to remote access – it will be held at the California Air Resources Board, Byron Sher Auditorium,

A Brief Summary is Below:

  1. CARB plans to ban sales of new internal combustion engine-powered equipment 1/1/2024.
  2. Currently no viable alternative for commercial pressure washers with ICE
  3. Commercial Pressure washers are not Pre-empt
  4. There will be a public hearing to consider amendments of “transition to zero” 12/9/2021
  5. 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!

Postal Mail

Clerks’ Office, California Air Resources Board

1001 I Street,

Sacramento, California 95814

Electronic Submission

https://www.arb.ca.gov/lispub/comm/bcsubform.php?listname=sore2021&comm_period=A

See Current Comments

https://www.arb.ca.gov/lispub/comm/bccommlog.php?listname=sore2021

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.

Take Action Now! (p2a.co)

 

UPDATE OCTOBER 18, 2021

Dear Jimmy,

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.

Sincerely,

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.


UPDATE OCTOBER 09, 2021

On Saturday, October 9, 2021, California Governor Newsom signed AB-1346 ordering state regulations (CARB) to set “zero” emission limits for new Small Off-Road Engines (SORE).  The regulation applies to engines produced on or after January 1, 2024, or as soon as the state board determines is feasible, whichever is later.  This would ban the sale of new gas-powered equipment using spark-ignition engines rated at or below 19 kilowatts (25 Horsepower), a broad category that includes lawn equipment, pressure washers and generators.

OPEI and several other associations including NALP and CETA worked to oppose the bill and get amendments added which should help engine and equipment manufacturers:

43018.11. (a) (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 off-road 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.

Ultimately the bill passed with the amendments and signed by the governor, directing CARB to adopt a rule by July 2022 to set SORE zero-emission limits by 2024, or when technical feasible, whichever is later.  Yes, this bans the sale of new gas-powered engines used on pressure washer equipment.

The following are some news links:

California law to eventually ban gas-powered lawn equipment – ABC News (go.com)

California moves toward ban on gas lawn mowers and leaf blowers – Los Angeles Times (latimes.com)

California leaf blowers, lawn mowers: State becomes first in nation to phase out gas-powered lawn equipment (fox5sandiego.com)

The move to zero-emission residential landscaping equipment is already well underway.

  • Engine Powered String Trimmer  vs. Battery Powered String Trimmer
  • Engine Powered Zero Turn Riding Mower  vs. Battery Powered Zero Turn Riding Mower

The move to cordless/battery powered residential pressure washers is also underway, with a few manufacturers that have been selling smaller cordless/battery powered product in the 1,200 to 1,500 PSI range:

  • Electric Pressure Washer  vs. Cordless/Battery Pressure Washer

Of course, none come anywhere near the current gasoline powered cold and hot water pressure washers currently being sold.

  • Engine Powered Pressure Washers 2,500 to 4,500 PSI Range
  • Engine Powered Generator  vs. Solar plus Battery Powered Generator

(1) Cost-effective and technologically feasible as the state board determines when feasible.

Since the regulators determine “feasible” we must continue working with them on when cost-effective technology will be ready.

The consumer/residential market has electric powered and alternative cordless/battery powered cold water pressure washers already in the market but there is a big cost difference ($100.00 for electric & $500.00 cordless).

(A) Emissions from small off-road engines in the state.

California estimated there are more than 16.7 million of these small engines in the state.

(B) Expected timelines for zero-emission small off-road equipment development.

Since the riding lawn mower and automotive market has technology for higher horsepower CARB regulators feel the technology is available.

(C) Increased demand for electricity from added charging requirements for more zero-emission small off-road equipment.

California is known for widespread electrical blackouts.

(D) Use cases of both commercial and residential lawn and garden users.

Residential equipment is designed for less operating time than commercial.

(E) Expected availability of zero-emission generators and emergency response equipment.

Generators were extended to 2028.

  • Engine Powered Generator  vs. Solar plus Battery Powered Generator

When the battery is dead and there’s no power on, you have nothing.

(b) Funding for commercial rebates.

Estimated 50,000 small businesses that will be affected.

Budgeted $30 million towards incentive rebates for people to change out their equipment, a move aimed at landscaping businesses that use these machines more often.

Currently gas-powered equipment purchased before the deadlines can still be used, by both property owners and professional landscapers.

Historically once California establishes emission regulation EPA follows a few years later.  For automotive emissions several states like Colorado, Connecticut, Delaware, Maine, Maryland, Massachusetts, New Jersey, New Mexico, New York, Oregon, Pennsylvania, Rhode Island, Vermont, and Washington, as well as the District of Columbia have also adapted California’s stricter requirements.

Our focus now shifts to CARB’s “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.

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

43018.11.

(a) (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 off[1]road 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.


Update:  June 24, 2021 

It is expected the Senate will have the first reading in the next 2-3 weeks

To all interested pressure washer dealers, contract cleaners and other known interested stakeholders in California. Please go to this Honda LINK https://p2a.co/kflWOX0 that was developed by OPEI and NALP which equipment dealers and users can submit a prepared message to CARB and their California Legislators.

The link will only work for people inputting a valid CA zip code. It uses that zip code to determine the appropriate legislators. A dealer or user may receive the same or very similar links from multiple manufacturers.

THERE IS NO BENEFIT from submitting multiple links.

The bill has passed the Assembly and is now in the Senate. It is expected the Senate will have the first reading in the next 2-3 weeks. As a result, it is important to get the messaging out as soon as possible.

Sincerely,

Jimmy Welch
CETA President
CETA Technical Committee Chairman

 

California Air Resource Board is conducting workshops that affect Small Off-Road Engines which are very common on pressure/power washers and will affect all of us as well.  They asked for stakeholder engagement and CETA is actively communicating our concerns.  As we move forward please let the CETA office know if you also want to engage.

See CETA’s response below and the response from the ARB:

April 26, 2021

Dear Mr. Welch,

Thank you for the Cleaning Equipment Trade Association’s comments on the SORE rulemaking. We appreciate CETA’s participation on this issue. We will let you know if we have any questions.

Best,
Dorothy Fibiger, Ph.D.
Air Resources Engineer
Monitoring and Laboratory Division
California Air Resources Board
916-324-8426


April 8, 2021

Dear CARB SORE 2021 Staff,

I am sending this e-mail on behalf of CETA (Cleaning Equipment Trade Association) which has members that supply engines to member manufacturers which in turn produce engine powered cleaning equipment commonly known as pressure washers or power washers and our member distributors that sell the product to end users for cleaning all types of things from building structures, transportation, equipment, and infrastructure.  One of our members sent the 3.24.21 Workshop Staff Presentation in which you indicate you need stakeholder engagement.

While we all agree that we need clean air to breath we also have to consider other environmental concern like clean water to drink and for cleaning.  Both are essential to life and our health.  Federal and state regulations involve not only the scientific sector but also industry and our residences.  We all desire cleanliness especially during this current COVID-19 pandemic where everyone has created what some call the “NEW CLEAN”.

Our engine manufacturer members are constantly investing in new technology to prevent emissions and trying to keep up with new more stringent requirements so our equipment manufacturers can produce products that meets CARB & EPA requirements.  If engines are provided without the exhaust or fuel systems, then the equipment manufacturers submit their fuel systems for approval.

As you report highlights, there are several equipment categories which have other power sources like electrical outlets, but it also has limitations (120VAC/1PH or, 240VAC/1PH and 3PH in industry) limits performance and is not portable.  New technology like batteries which run electric motors work in some applications but much like the generator industry where torque and power load requirements would drain batteries very quickly.  Please consider adding pressure washers as an exemption like you are proposing with generators to allow our industry members time to develop products that can meet the emission requirements.

The following are some examples of cleaning and the challenges they currently present:

1) Residential: Roofs, structures, driveways, and swimming pools areas all need cleaning and while electric pressure washers have been available for many years, they have limited performance because exterior electrical receptacles are limited to 120VAC/1PH which limits performance to below 2,000 PSI.  Battery powered products have recently come on the market; however, the pressure is currently limited to below 500 PSI.  Both of these are not always efficient for cleaning causing more water usage because of the decreased cleaning efficiency taking more time for the homeowner to clean.  Many residential owners hire the exterior cleaning out to professional cleaning contractors who use portable engine powered product to achieve a good flow/pressure balance as well as surface cleaning tools to effectively clean reducing water consumption.

2) Commercial: Has the same exterior cleaning issues but may have 230VAC/1PH power available which could allow higher flow/pressures but may not always be efficient.  Again, professional cleaning contractors are common.

3) Industrial: Has the same exterior cleaning issues but some may have 3PH power available or even a wash bay area to clean their equipment.  Again, professional cleaning contractors are common.

4) Construction: Equipment needs to be cleaned and cannot always be transported to a wash bay.  Electrical power is not always available at construction sites that is why they need generators.  However, operating a pressure washer off a generator is not as efficient as a pressure washer using its own engine.  Portable cleaning can provide more effective cleaning.

5) Agricultural: Equipment needs to be cleaned; some areas require cleaning between field to prevent the spread of diseases.  Again, electrical power may not be available.  Portable cleaning can provide more effective cleaning.

6) Transportation: While cars, vans, SUV’s, and pickup trucks can go to a carwash larger vehicle like buses, dump trucks, semi-trucks have much fewer washing locations in most states like California.

7) Pleasure Craft: Boats need cleaning and in some states after being removed from the water to prevent spread of invasive species.

8) Ships: Need cleaning.  California has many ports and portable cleaning is currently how they are cleaned.

9) Wind Turbine Cleaning: Need cleaning.  California is a leading state in wind power and as you know they get dirty and need cleaning on a regular basis to stay efficient and cleaning is place is the only option.  Engine powered equipment is again the most effective way to clean and maintain the wind turbine.

10) Sewer Jetting: Portable engine powered equipment is commonly used to clean clogged drains.

In summary of above applications, in many cases cleaning in place using engine powered pressure washers is the only current option available while in other cases offers emission reductions over transporting to a wash site and can help contain other environmental hazards.

I hope you get the picture; many things need exterior cleaning and operate more efficiently when cleaned as well as retain their value.  Each of you have probably had the need to clean something, whether you used a water hose, a new battery powered pressure washer, electric powered pressure washer, or an engine powered pressure washer and actually experienced the improved cleaning efficiency and water conservation as you progressed up the performance range used each of them.  We all want to take care of our possessions and keeping our things clean will help maintain them for years of use.  As already mentioned, cleaning efficiency is also an important factor to help conserve our water supply and our precious time.  We are all looking for that balance of clean air and water conservation.  We hope that you will consider including pressure/power washers to CARB’s exempt list.

California residence want to keep their residences clean, so their property value does not go down and they like to shop at stores that are clean and presentable.  Tourists like to arrive to a nice clean hotel and visit your clean theme parks.  Many professional cleaning companies are minority owned as well as their workers.

Our cleaning industry agrees that we need more environmentally friendly product.  Our engine suppliers need time to develop designs to meet the challenge.  We also need battery suppliers and electric motor suppliers to develop designs that will perform in our torque/power range requirements.  Therefore, we ask that you include pressure/power washers as well as water pumps in your exemption like generators.  Several of our manufacture members also product generators and water pumps which are remote power because electricity is not available at the sites they are used at.

Sincerely,

Jimmy Welch
CETA President
11450 U.S. Hwy. 380
Suite 130 # 289
Cross Roads, TX  76227
1-800-441-0111 | Fax: 704-635-7363
website:  www.ceta.org 

Our Vision: CETA will be the top resource for distributors in the power cleaning products industry to get information to better their business, improve profitability, educate ownership and employees, and network to improve industry best practices.

Our Mission: CETA is a non-profit organization providing networking, education, training, and regulatory influence to enable profitable growth to distributors of power cleaning products in North America.