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I have been in the pressure washer industry for decades
specifically the business to business segment.  Industrial
equipment generally with 10HP to 25 HP engines.  Those pressure
washers are able to conserve water over smaller equipment.   Many
types of cleaning happen over night and in places where higher
power to run electric units is not available.  These applications
are real and very difficult, if not completely impossible to manage
with battery technology.   A small part could be replaced with
higher voltage (230V Single or 3 Phase), however hooking up to
these power sources for a contractor poses many safety risks to the
public and contractor in the small of amount of places that would
work.   Pressure washers use a great deal of energy in order to
conserve water and labor, in a way that cannot be done with battery
technology.  How much extra water will be required if the gas
engine units and the performance they offer isn't available?  

I think a delay of implementation of the SORE rules for Pressure
Washers, especially industrial, should be delayed.    My limited
research shows that gas engines produce between .52 and .59 pounds
of carbon dioxide/KWH of energy.   Looking at the site that shows
CA emissions for power (which is an awesome tool and site), shows
numbers ranging from .16 to .34 pounds of CO2/KWH.   So I can see
that there is a savings that might average to about a savings of
about .32 pounds of CO2/KWH.  That as an awesome savings.   But the
national average for power generator is .92 pounds of CO2/KWH. 
Clearly California is leading in Green House admissions.   However,
right now it seems that each small engine that is replaced in CA
with electric would produce MORE CO2, as CA could provide that
greener power supply to the rest of the country.  Think of it, if
you can eliminate .92 pounds of CO2/KW, or even more as that is a
weighted number at it includes California Power. 

Has the comparison of .59 pounds CO2/KWH for SORE been compared
with the much higher environmental cost of .92 pounds of CO2/KWH
from power generation?   

I encourage you to delay the Pressure Washer engine requirement
until at least 2028 for the sake of CO2 emissions alone, but also
because pressure washers serve needed functions that provide water
savings and health benefits and offer employment to many,
especially in the minority communities.  I also think that many
SORE will be eliminated for residential users because the big box
stores will trend towards battery powered.  Those are not
commercial and won't meet the needs of many applications, but many
SORE will be eliminated.  Also and for reasons we all probably
understand stationery pressure washers that are used in factories
and other places that could use electricity for supplying power
already are.

Thank you again for reading this and answering if it would be best
to wait until over all power generation was lower in CO2 output
than a gasoline engine per KWH, if a water analysis has been done
on this, including waste water recover technology that often
requires the higher HP of large SORE engines, if minorities would
be effected more by these changes in regards to contract cleaner
owners,operators and employees.