Comment Log Display

Dear California Air Resources Board:

I write to you regarding the proposal to eliminate Small Off-Road
Engines beginning January 1, 2024 and about the severe impact that
it will have on various aspects of the lives of the citizens of our
wonderful state. My wife and I we both born and raised in the
beautiful state of California, and love raising our children here.
I am employed by a company that manufactures pressure washers in
Redlands, California. This manufacturing facility employs more than
50 people at this Redlands facility who build pressure washers and
support this Californian manufacturing facility. These pressure
washers are sold to distributors, many of which are Californian
small businesses for whom a significant portion of their livelihood
is made by reselling these gas powered pressure washers to local
municipalities and Californian entrepreneurs who use this equipment
to  keep our communities safe and clean. This regulation of Small
Off-Road Engines would effectively eliminate most of the pressure
washing products and the services that we provide to our California
customers which would impact our livelihoods as well as theirs.
A pressure washer is used in order to quickly and effectively clean
and sanitize in a way no other product can. It is a highly
effective piece of equipment that is ideal for a drought
susceptible climate since it uses a fraction of the water used by a
garden hose. If gas powered pressure washers are not available,
there is no current available battery or electric technology to
take its place. The other option of cleaning that will be employed
will be with a garden hose which will lead to less effective
cleaning and significantly more water wasted or in some cases not
cleaning at all. One unique application of pressure washers is by
using hot water. A hot water pressure washer is an industrial piece
of equipment that is the core of our business. It is similar to
using hot water for cleaning your dishes rather than just cold
water. It quickly removes grease, oil, algae, road film and other
grime. It cleans much faster and in many applications completely
eliminates the need to use chemicals. If this product is not
available then the alternative may be to try to use caustic
chemicals to perform the same function which will have a
detrimental effect to our environment. Also, there are some
applications like gum and graffiti removal where a gas powered hot
water pressure washer is the absolute best tool for the job. A hot
water pressure washer can remove a piece of gum from the concrete
in the matter of seconds where there is no other product that can
do this as quickly and effectively. By having gas power, you can
effectively clean anywhere including remote areas such as
agricultural and construction sites.
The state and local municipalities use pressure washers to keep our
state beautiful and safe. Almost every downtown and historic
district is cleaned with pressure washers at night after street
fairs and market nights. Our amusement parks, stadiums, schools
where our children play are cleaned with gas powered pressure
washers. Train, subway and bus stations are all cleaned with
pressure washers. Hot water pressure washers are employed to clean
and sanitize homeless encampments and prevent to spread of deadly
diseases. Our state uses pressure washers to kill zebra and quagga
mussle larvae in boats to prevent the spread of Aquatic Invasive
Species from the Colorado River into our other lakes and streams
which would harm the natural eco systems. Hot water pressure
washers are employed for disaster cleanup after floods, fires, and
oil spills.
Many of the systems that we make, help contractors and
municipalities comply with the Clean Water Act by employing onboard
generators to power a Recovery and Recycle systems. This system not
only picks up the wash water preventing any contaminated wastewater
from entering our streams, lakes, and oceans; it also recycles the
water for reuse conserving even more water which is one of our
states most precious natural resources.
Battery and electric power are currently not an option. We produce
commercial/ industrial products that are not capable of being run
on the standard power grid. The battery technology currently
available is not a feasible or affordable option for this
application of industrial/ commercial cleaning.
I ask you to please reconsider your decisions and to make
commercial and industrial pressure washing equipment preempt from
this proposal due to its heavy use by agriculture and construction
industries that depend on it, as well as the various other
essential cleaning tasks that I have explained. There are many
unseen benefits that these small engine powered products contribute
to our every day lives and the quality of life in keeping our
beautiful state clean and safe.

Thank you very much for your consideration,
Casey Meelker