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 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.


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