Comment Log Display

To the California Air Resources Board:

As a dealer of pressure cleaning equipment for over 37 years and
the current president of CETA I appreciate the opportunity to
submit comments on the proposed regulation and any possible
amendments. I agree with the CARB board in their resolve to improve
the air quality and reduce greenhouse gases. I also believe that
small engines and their lack of emission control advancements have
a detrimental effect to air quality. I also realize that ZEE tools
are the direction of the future. 

So while I agree on these things I also believe that the negative
societal and economic impact from banning small engines on
commercial (not residential) pressure washers will outweigh the
incremental increase in air quality and reduced emissions. The main
reason for this is that the technology for ZEE type industrial
pressure washers is non existent and not feasible. Having
experience in the pressure pump industry from a supplier standpoint
I understand the torque and power requirements for industrial
pressure washers and there is no feasible size or feasible cost for
a battery powered industrial pressure washer.
Most commercial pressure washing equipment uses 8 to 20 electric
brake horsepower at full load to do their job.  By jobs I am
referring to graffitee abatement, cleaning city sidewalks and
downtown areas, cleaning parks, cleaning and sanitizing playground
equipment, cleaning invasive species off of boats, also many types
of industrial and commercial and agricultural cleaning that are a
necessity not a luxury or for aesthetic reasons.

So I propose that the board amend the regulation to exempt
industrial pressure washing equipment with engines above 250CC
until 2028 like generators or until feasible technology exists
whichever comes sooner.

Respectfully submitted:

Al Bonifas, owner
ALLSPRAY 121 Main st. Swanton, Ohio 43558
CETA president 2021-2022