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My name is Greg Sprunk and I am the President of Superior Cleaning
Equipment. I have owned this company for 30 years. 25 years we have
been in Southern CA in San Diego. 

We sell and service pressure washers, aqueous parts washers, wash
water recycling systems as well as service, parts and accessories
for the above items. 

We primarily deal with industrial cleaning equipment generally with
10HP to 25 HP engines. Those pressure washers are able to conserve
water over a standard water hose, sometimes as much as 3-4 times.

It was inconceivable to me that much thought went into these
regulations in regards to the industrial applications that they are
going to be affecting. There is no battery technology that will
allow a user to clean anything above 1500 psi at this current time.
Pressure washers use a tremendous amount of energy but also
conserve a great amount of water as mentioned above. Any outside
surface that is currently being cleaned from your civic centers to
restaurants to ships to boardwalks to hotels to entertainment
venues such as Legoland, Sea World all use over 3000 psi. There are
no replacements for that. A water hose is not going to cut it. Let
me give you just one example out of 1000. Cleaning the hulls of
military ships. Most contractors use 5000 psi or more. In order to
power that you need to have a very large 460V highly charged cord
which is not very safe and now you have the water factor as well.
Ever try removing chewing gum from your driveway with a water hose?
I guess you could get out there with a chisel but you still won't
have a clean surface.

And it's not just pressure washers. With the issues facing
California in regards to wildfires there are no chainsaws that run
on battery power that are above 15 to 20 inches long. Nothing
industrial. Are you expecting that the forest service wheels out a
large diesel generator with about 20 extension cords to runoff into
the forest to maintain the utility areas that are continuing to
catch fire? Up in a tree with extension cords? So you've reduced
emissions from the smaller chainsaws but now have a large diesel
generator that is putting out as much if not more than the smaller
units. And by the way the generators run the entire time. Gas
powered chainsaws turn off and on. 

it's easy to take a broad sweeping approach to an incredibly
complicated issue that obviously has not had much research done in
terms of how it will affect the cleanliness, safety and population
base in major areas. I don't have a problem with getting rid of
smaller two-stroke engines where there's battery technology to be
as equal or better. I have an electric battery powered blower for
my home. I can use an electric powered pressure washer at 1500 psi
to clean the outside of my house. For my small yard I can use a
battery powered lawn mower. But that technology is not available to
service large areas, parks for example. 

And based on previous summers in California, you are now going to
load up the infrastructure and in spite of rolling blackouts, now
everybody's going to be charging their batteries on every single
item mentioned above and that's not going to affect or increase the
use of electricity? Which we already do not have enough of?

What's happening here is what has happened time and again.
Legislation that is going to be on the backs of small business
people, who make up the back bone and  fabric of the communities
are going to be the first ones to suffer. There are other options.
Limiting horsepower under 5 for example. Taking a wade-in in
approach instead of a plunge and see how technology can or will
catch up. 

A lot of people here talking about how small are gas powered
blowers or lawnmowers are causing them a lot of distress and air
pollution. And I sympathize with that. But the overreach here in
terms of horsepower here Is going to have a crippling affect on the
small business cleaning, landscaping, services business that has
not been thought through. And when you go to your local facilities
and see somebody hand brushing with a bristle brush the venue, then
using 8 to 10 gallons a minute from a water hose it's going to
catch you that this might not be the best approach. 

There's a better way to go about this, not the sledgehammer all
encompassing, under 25 hp catastrophe that this is about to rain
down on this great state. Let's make sure the technology can handle
the regulation. At this time it cannot.