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I have been in the pressure washer industry since 1983, 
specifically the sales and service of pressure washers in the
business to business segment.  We primarily deal with 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 overnight and in places where higher
electrical power to run electric units is not available.  These
applications are real and can be 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 they
could possibly work.   Pressure washers use a great deal of energy
in order to
conserve water and labor, in a way that cannot be done with current
battery
technology.  How much extra water will be required if the gas
engine units and the performance they offer isn't available?
Consider the fact that an average garden hose produces 10 gallons
per minute while an average pressure washer consumes 4 gallon per
minute. Another aspect of water use is the recovery operation of
the water in an outside cleaning environment. All mobile water
recovery systems use small gas engines, how will this affect that
operation? 

I believe a delay of implementation of the SORE rules for Pressure
Washers, especially industrial, should be delayed. The research
shows that gas engines produce between .52 and .59 pounds of carbon
dioxide/KWH of energy.   Base upon the site that shows CA emissions
for power shows
numbers ranging from .16 to .34 pounds of CO2/KWH.   So I can see
that there is a savings which could  average to about a savings of
about .32 pounds of CO2/KWH.  This would be an incredible savings,
based on  the national average for electrical power generation is
.92 pounds of CO2/KWH. 
Clearly California is leading in Green House emissions.  However,
right now it seems that each small engine that would be 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 as 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 would 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. This will also allow the
battery technology to catch up with the larger power requirement
needed for the industrial pressure washers. I also think that many
SORE will be eliminated for residential users because the big box
stores will trend towards battery powered equipment.  Those are not
commercial units and won't meet the needs of many applications, but
many SORE will be eliminated.  Also stationery pressure washers
that are used in factories and other places that could use
electricity for supplying power
are already in use.