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Power Washers of North America 1410 Energy Park Drive, Suite 6 Saint Paul, MN 55108 800-393-7962 April 24th, 2011 Sylvia Brumlow Community Liaison Houston Police Department Environmental Investigations Unit Dear Sylvia Brumlow: Hello. My name is Eric Clark and I am the president of the Power Washers of North America. As you may know, the PWNA represents contractors in the power washing industry across North America. Two of the pillars of the PWNA are education and being a clear voice for our industry. We are requesting that the city of Houston provide a public comment period so that we can all work together to achieve the goals of Houston as it relates to clean water. We believe we can help in this regard and provide guidance and education to power washing contractors. The EPA recently published a paper called "Coming Together for Clean Water" where it states...In all cases the EPA is committed to reach out to its many partners and stakeholders in an effort to provide leadership, improve communication, and strengthen participation in pursuit of the objective of providing clean water for this generation and those to come. It is the intention of the PWNA to make that a reality. We formally request a public comment period so that we can help the city of Houston achieve its goals. The PWNA would humbly ask that the public comment period begin at the meeting on July 21, 2011. We would encourage there to be a question and answer session with all of the speakers during the July 21st meeting. We would ask the public comment period extend for 60 days. The U.S. Court of Appeals for the Ninth Circuit ruled: Opportunity for public hearing - The court’s decision requires that the public be given an opportunity to request a public hearing. If the Phase II MS4 general permittee provides public notice for the NOI, the permitting authority will still need to provide the public an opportunity to request a hearing. Thank you for your time and consideration. Please feel free to contact me anytime. I look forward to your response. Sincerely, Eric Clark President Power Washers of North America We will address it to these individuals as well: Mayor Annise D. Parker City of Houston P.O. Box 1562 Houston, TX 77251 Phone: 3-1-1, or 713.837.0311 Email: mayor@houstontx.gov Nelson Espitia Director Citizens' Assistance Office 900 Bagby, Public Level Houston, TX 77002 Phone: 832.393.0955 FAX: 832.393.0952 Email:nelson.espitia@houstontx.gov David M. Feldman City of Houston Legal Department 900 Bagby, 3rd Floor Houston, TX 77002 PHONE: 832.393.6491 E-Mail the City Attorney: david.feldman@houstontx.gov Cynthia Williams Compliance Specialist Small Business & Local Government Assistance Section Region 12, Houston Texas Commission on Environmental Quality 5425 Polk Street, Houston, TX 77023 Direct: 713-767-3459, Email: cynwilli@tceq.state.tx.us Guyneth Williams Environmental Investigator IV City of Houston Public Works & Engineering 2707 Dalton, Houston, TX 77017 T. 713-641-9523, E. guyneth.williams@houstontx.gov Stephen R. Dicker Sr. Police Officer Houston Police Department Environmental Investigation Unit 7125 Ardmore, 4th Floor Houston, TX 77054 Cell: 713-504-7154, Email: Stephen.dicker@cityofhouston.net De’Montra L. Rainey Special Agent US EPA, Office of Criminal Enforcement Criminal Investigation Division Houston Field Office 1919 Smith Street, Suite 925 Houston, TX 77002-8049 Direct: 713-209-4892, Email: Rainey.DeMontra@epamail.epa.gov Almika Millage Department of Health and Human Services Bureau of Consumer Health Off: 832-393-5688, Email: almika.millage@houstontx.gov

In September 2010, the EPA issued its 2011 - 2015 Strategic Plan. The plan has 2 goals, one, to protect human health and second, to protect and restore watershed and aquatic ecosystems. The EPA points to the following statistics for the urgency of their work: · The rate at which waters are being listed for impairment exceeds the rate at which they are being restored · Human health measures for contaminants are exceeded in one fifth of stream samples, and one third of groundwater wells · Mercury and PCBs were detected in all fish tissue samples and nearly 50% of the nation's lakes have mercury fish tissue concentrations above EPA recommended limits · PCBs exceeded EPA recommended limits in 71% of lakes · The amount of nitrogen and phosphorous pollution entering our waters has escalated dramatically · Nitrate drinking water violations have doubled in eight years · Algae blooms are steadily on the rise · 37% of native freshwater aquatic species, including fish and insensitive invertebrates, are now at risk of extinction The EPA says that a lot of progress has been made in the past 40 years but there is much more work to be done. In addition to the EPA's statistics above, there are other dark clouds forming. The nation's drinking water and wastewater infrastructure has a long and successful history of controlling pollution and providing safe drinking water. However, there is growing concern in the water sector over the continuously expanding infrastructure and capital investment needed to continue this history. It is estimated to be over $600 billion over the next 20 years. The additional money needed is attributed to capital investment required to service new growth, complete deferred maintenance, repair and replace aging infrastructure, provide for the increasing competition for water, and the increased implementation of new technologies that protect human health and the environment. This is specifically where power washing and wastewater recovery come in; the EPA says "As financial resources continue to be stretched, protecting source waters from contamination will remain more cost effective than remediating the contamination. And while the Clean Water Act was designed to eliminate discharge of pollutants into "navigable" waters, more than half of the nation's water bodies are now degraded. The problems are getting worse, not better. Blaine Krugerud of Bio Clean and I (Executive Director of the PWNA and owner of RTD Power Washing) met with the Metropolitan Council (Twin Cities POTW - Publicly Owned Treatment Works) and with 3 people of the Minnesota Pollution Control Agency (Twin Cities MS4s - Municipal Separate Storm Sewer Systems ) in early April. We asked about enforcement and were told it is virtually non-existent at this time in the Twin Cities. Blaine's and my concern is that with all that is happening across the country, and especially in Houston, that someday soon someone from the EPA, other government department, or TV news station will witness/film a power washing contractor allowing soap, debris and other pollutants going down a storm drain. It could quickly turn political with restrictions put in place that could shut power washing down or putting unreasonable restrictions on it. One of the main reasons that we initiated the two meetings was to communicate that we are the solution to clean water in our lakes rivers and streams. Here are 2 examples that were given: · A national company was having their fleets cleaned every 2 weeks. A directive came down from corporate banning all fleet washing due to fears of the Clean Water Act. Now, instead of having their fleets cleaned on a regular basis, their drivers would have them washed occasionally. The mobile fleet wash company that was doing the washing had been collecting the wastewater and disposing of it properly to the sanitary sewer. What will happen now is the vehicles will not be washed regularly and all of the dirt, hydrocarbons and other pollutants will be rinsed off the truck when it rains going into storm drains and into our lakes and rivers. · Another example given was a company that was having their fleet cleaned but then decided to change their practice, again, because of the Clean Water Act. When they were having the vehicles washed in the yard, the tractors and trailers were being cleaned and the wastewater was being recovered. Not only was the fleet cleaned, but the parking lot was being cleaned at the same time by the soap and water being used to wash the fleet. Visit that parking lot today and the pavement is filthy with oil stains. Now when it rains, the oil and hydrocarbons on the surface of the parking lot are now being washed into the storm drain and into our lakes, rivers and streams. The illustrations above are just two examples of how fear of the Clean Water Act is actually contributing to the problem. In our meeting we also discussed the importance of exterior building cleaning, sidewalk cleaning, deck and wood restoration and house washing. Kitchen exhaust cleaning is critical to preventing the pollution a fire would create in addition to the health and safety of the food being prepared. Power washing and preventing the wastewater from entering storm drains is the solution to the problem and it is how the power washing industry is instrumental in protecting our lakes, rivers, streams and oceans. The municipal gentlemen we had the meeting with said they had never seen it from that perspective. Unintended consequences of well intentioned people is what we as power washing contractors need to help people see so they can make informed decisions. The two meetings we had were beneficial to everyone who attended. The municipal people appreciated Blaine and me coming in to meet with them. They now have real people, faces, and a national organization that they know are here to help them in their goal of clean water. The PWNA will soon have educational training and certification to help every power washing contractor have the knowledge and confidence to visit their local POTW and MS4s to educate them on how we are here to make their jobs easier. The power washing industry is here to help keep our waters clean for generations to come. It is important every power wash contractor be involved in educating their local community on the necessity of power washing to keep our nations waters clean. Attend the PWNA's Environmental Training course where we will train contractors to do just that at our annual convention being held in Nashville, TN this October 20th through the 22nd. Learn more by visiting Annual Conventions | The PWNA. Much of the information and content of this article came from EPAs "Coming Together for Clean Water" available online at https://blog.epa.gov/waterforum/wp-content/uploads/2011/04/ComingTogether-for-Clean-Water-FINAL.pdf

The PWNA will be teaching the House Washing Certification and the Fleet Washing Certification at the upcoming San Diego Round Table hosted by Sirocco Performance Vacuums. Registration for these courses will be available shortly on the PWNA website - www.pwna.org.

The PWNA Convention will be taking place October 20-22, 2011 at the Hotel Preston in Nashville, TN! Make your room reservation in the PWNA block by 9/20 and receive a discounted room rate of $99/night plus tax. You can make your reservation at Nashville Hotels | Hotel Preston Nashville or by calling 1-866-986-8089. The schedule of events will be available soon!

The PWNA will extend the time allowed to comment on the Proposed BMPs for an additional 7 days until April 22, 2011. We welcome all, including non-PWNA members, to fill out the comment page and return to the PWNA headquarters by mail, fax, or email at 1410 Energy Park Drive, Ste 6, St. Paul, MN 55108, 651-699-6709, or info@pwna.org. You can find the proposed BMPs at Environmental Guidelines | The PWNA

Gain the knowledge at the PWNA Wood Restoration Certification course being offered May 14, 2011, in Linden, Michigan. The Wood Restoration Certification class offers many benefits to new and veteran power washers. We will explore the benefits and needs of wood restoration as well as how to run a successful wood restoration business. This class is a must for the true wood restoration professional. The cost for the one-day course, which includes in-class training and hands on experience, is $395.00 for PWNA members plus $175.00 for each additional representative, and $595.00 for non-members (price includes membership). Register for this course today at Wood Restoration Certification Course | Register Now or call 1-800-393-7962. Don’t postpone registration! Space is limited.

Please note that correct link to register for the Wood Restoration Certification: Wood Restoration Certification Course | Register Now

This letter was written by Mike Hilborn, PWNA Executive Director. It was reviewed and commented on by the PWNA Board of Directors. This letter has been approved for distribution by the PWNA Board of Directors. The Problem Facing Us All Houston could be the tip of the iceberg. I have yet to read a BMP that is as contractor friendly as the BMP/Guide/Paper submitted for review by the PWNA (changes are being made to improve it). Read any of the following already published BMPs and you will learn how potentially dark the future of our industry could be. · http://www.saws.org/conservation/ordinance/PowerWash/Power_Washing_Guide.pdf · http://www.ci.springfield.or.us/esd/bmp%20powerwashbook.pdf · http://www.epa.ohio.gov/portals/41/sb/publications/powerwash.pdf · http://phoenix.gov/streets/bmps.html · http://ci.st-helena.ca.us/images/city/Docs/SurfaceCleaner%20Guide12.04.pdf · Untitled Document · http://www.cabmphandbooks.com/documents/industrial/mobilecleaning_surfacecleaning.pdf BMPs will be written and enforced by municipalities across the country. We the contractors need to be involved in that conversation (please see previous letter for what the BMPs are and what they are not). We more than anyone know how to protect our waters. If we do not lead, well intended politicians and bureaucrats will write the policies and rules which will have unintended consequences therefore increasing the pollutants in our waters. An example: · A recent bulletin board post described (as I understand it) a customer that has suspended all fleet washing because of the liability associated with the Clean Water Act. The customer was having their fleet washed by a PWNA contractor that was preventing waste water from entering the storm drain using their reclaim system. The customer is now going to have their vehicles washed on a much less frequent basis by their drivers. The result will be dirty trucks driving down the road with rain water washing contaminants into storm drains. The exact opposite of the intent of the Clean Water Act. If Others are to Respect Us, We Must Respect Ourselves If we want to protect and grow our industry we have to have the best ideas of everyone. Right now if someone makes a post on a bulletin board that is not to the liking of a select group, that person is insulted, intimidated or bullied. Ewelyn Beatrice Hall once said "I may not agree with what you say but I will defend to the death your right to say it." I talk to some of the sharpest people in our industry that do not post their thoughts and ideas on the bulletin boards because they choose not be mocked and disrespected. Or worse yet, they fear they will be made a target of intimidation and bullying. An example: · I think it is safe to say that the Board of Directors leadership on the BMPs has been controversial. I would humbly submit that as Executive Director of the PWNA, I am the primary face and voice of the PWNA. During the past two weeks I received a quick flurry of annoying texts before I had that number blocked. The Board of Directors received an unprofessional and vulgar email letter referencing me (Jackie reads these emails). In addition a You Tube video posted on 2 bulletin boards was addressed specifically and only to me. I would suggest a phone call would have allowed for a conversation and given me the opportunity to explain my position. If a phone call didn't seem comfortable, then emailing me the You Tube link would have been an appropriate choice. However, I don't believe that was really the purpose of the video being posted on a bulletin board for all to see. It is my opinion (and the opinion of others) that the purpose of the video was to send a message to everyone that if you disagree with this person that he might make you a target. Bullying and intimidating me is one thing: 1. The Executive Director is an unpaid, volunteer position - I don't lose any money if I'm fired or resign 2. I don't have a store or sell anything on the internet 3. I discontinued my franchise program 4. I don't feel like I have a lot to lose in this matter 5. I kind of like the attention However, it will upset me greatly if I see this being done to someone else. I will stand shoulder to shoulder with anyone where this is happening to them. With that said, a recent post compared a letter I wrote last week to have been written by Carlos. I received that as a great compliment. I was always impressed with how well Carlos could write. My writing compared to Carlos; again, I appreciate the compliment. I'm not suggesting we sit around a camp fire singing Kumbaya. I am suggesting that we allow people to express their ideas without fear. If you disagree with me all the time, I would guess you will be right at least 50% of the time. Allow for the opportunity to have a conversation, don't make it personal. The exchanges we have between each other should be positive and build each other up, even when we disagree. It is Time for All of Us to Stand Together It is my opinion that there has never been a more urgent time than now where we all stand together as contractors to defend our industry. I can guarantee that we will not all agree on every issue. However, we can take the best ideas from everyone to form our decisions. John Dickinson said "United We Stand, Divided We Fall". The BMP issue has not yet been decided, you may not see value in our Certification Program, you may not agree with our Water Reclaimer Program, you may not like the history of the PWNA, and I can understand it if you don't like me. Do not let any of those things get in the way of protecting your family, the life you have created, and the business you have built. SIMA Snow and Ice Management Association 1,500 members ICPI Interlocking Concrete Pavement Institute 1,000 members NCMA National Concrete Masonry Association 8,400 members LMCCA Low Moisture Carpet Cleaners Association 2,500 members ACCA Air Conditioning Contractors of America 4,000 members PDCA Painting and Decorating Contractors of America 2,000 members *****/PWNA 300 members How can it be that an industry as large and diverse as ours has only 300 members between the two organizations? I was recently at a meeting with the Twin City Sewer Department (Metropolitan Council) with another PWNA member when the director asked how many members our organization had. When I told him that we had 250 members, he asked if our organization was brand new. All of us as members is what will make us strong. With a large membership comes a loud, powerful, clear voice. One Last Thing It would be my privilege to work together with the leadership of the *****. I'm quite confident that we can accomplish much more together than apart. The past is behind us, let's work together to build the future of our great industry. If anyone would like to talk to me about this post, please call me directly at 612-868-7312 or email me at mike.hilborn@pwna.org. Thank you. Sincerely, Mike Hilborn and the Board of Directors of the PWNA

To date, we haven’t received any suggestions for changes on the proposed BMPs. If you have posted your proposed changes or suggestions on a bulletin board thread, please email, mail, or fax those comments to PWNA Headquarters at: info@pwna.org 1410 Energy Park Drive Suite 6 Saint Paul, MN 55108 Fax: 651-699-6709 The deadline for any proposed changes or suggestions is April 15, 2011.

The Need for a National Organization From the late 80’s and into the early 90’s, contractors in different areas of the country began hearing from enforcement official that they were in violation of the Clean Water Act. This was a major concern as it appeared that the mobile power washing industry may be on a collision course with environmental regulators that would set out to put our industry out of business. It was at this time that Robert Hinderliter began reaching out to the EPA, state and local environmental officials to learn more regarding the future implementation of these laws and what could be done. He was told that to be heard and have influence with governmental agencies there would need to be representation from an industry trade association. Governmental agencies would respond to Trade Associations but not to individual companies. The PWNA was Born In 1992, PWNA was formed and the first trade show was held to discuss the future of the industry and what solutions contractors could implement to survive the future of environmental regulation and enforcement. It has and will continue to be PWNA’s position that law makers and enforcement officials implement practices that will benefit both the environment and the contractors in the mobile power washing industry. By creating regulation that will reasonably allow mobile power washing contractors to comply with the regulations; enforcement officials have found that there will be a high level of voluntary compliance if the regulations are reasonable, rational, and logical. This in turn will reduce the cost of enforcement, greatly increase industry compliance and most importantly reduce the amount of pollutants that would otherwise end up in our lakes, rivers, streams and oceans. In other words, the mobile power washing industry can actually be used to help clean the environment. A Clear Voice for the Industry Since that first meeting the PWNA has had representation that helped create a model ordinance for the City of Fort Worth that is referenced on the EPA website. Many other cities have used the model ordinance and consulted with the PWNA to aid in the development of their cities ordinance. As an aid for regulators and mobile power washing contactors alike a draft Environmental BMP was voted on by the PWNA Board of Directors and is now being released to PWNA members for public comment. The minutes of this Board call, as with every Board call is or will be viewable on the PWNA website. The following is the time line for final approval of the BMPs: · The draft BMPs are being emailed to all current PWNA members for review and comment. The BMPs will also be put on the PWNA website. · Member comments will be posted on the PWNA website. All comments must be submitted by April 15th. · Those comments will be reviewed by the Environmental Committee. The committee will decide which changes, corrections, additions and deletions will be made to the BMPs. · By May 1st, the Environmental Committee will submit an updated draft of the BMPs to the Board of Directors for a vote to either accept, reject, or modify the BMPs. · The membership will be informed on the status of the BMPs after the vote. · PWNA representatives will attend the next Houston meeting. · The Environmental Committee will next begin working on municipal guidelines. Any member interested in being on the committee should contact Jackie. Please submit all questions and comments to Jackie at PWNA headquarters. Email to info@pwna.org or call toll free 1-800-393-7962. Thank you. Sincerely, The Board of Directors

Yes Rob! The PWNA Board of Directors include Eric Clark, Steve James, Doug Barrett, Charlie Arnold, Dan Galvin, Daryl Mirza, Paul Horsley, John Nearon, and Mike Hilborn. You can find biographies for each board member on our website at The PWNA - About The PWNA. Robert Hinderliter is our Environmental Chairman and his biography can be found there as well. PWNA member Scott Stone is a part of our Environmental Committee as well.

The PWNA Board of Directors along with the Environmental Committee will have a follow up call this Wednesday to vote on the proposed BMPs. We will update you as to the result of that call.

The Board of Directors and the Environmental Committee held a conference call yesterday to discuss the PWNA's involvement and how we'll move forward re: the City of Houston and the Clean Water Act. You can read those Minutes at Board of Directors and Environmental Committee conference call 3/24/11 re: City of Houston and the Clean Water Act « The PWNA Blog

If you are a current PWNA member and are interested in being a featured member in a future Cleaner Times article, please contact PWNA at info@pwna.org.

The PWNA Board of Directors will be holding a conference call this Thursday to discuss Houston and how to proceed! We will keep our members updated! This is a closed call!

The PWNA kicked off its certification courses with the House Washing course as well as the Wood Restoration course. Drew Anderson, who attended our Wood Certification, said "I know 200% more about wood today than when I walked in to your store and the class. I think the class is very worth while to anyone who has or is doing wood. Thank you again so very much!" Please watch the PWNA website for our next classes! You won't want to miss out!

If you are a PWNA member and having a hard time finding how your membership can benefit you, please contact PWNA headquarters at 800-393-7962 or email at info@pwna.org. Jackie is happy to help you. If she can't, she will get you over to someone who can!

Don't lose the opportunity to take a PWNA course! Watch our website for updates on round tables and conventions at The PWNA - The Power Washers of North America!

The PWNA has received quite a few new memberships in the past few weeks. We now have 257 current members! Thanks to everyone for helping make us a stronger voice for the industry!

The PWNA Wood Restoration Certification course is happening this Saturday, March 19, in Linden, Michigan. There are still a few seats left available. Register today at Wood Restoration Certification Course | 2010 Power Washing Courses or call PWNA headquarters at 1-800-393-7962. The cost is $395 for PWNA members and $175 for each additional representative, or $595 for non-members.

The Milwaukee Round Table is less than a week away! Register today at http://powerwashstore.com/?mainURL=%2Fstore%2Fitem%2F2yekv%2FTraining_Resources%2FMarch_Educational_Seminar.html. The PWNA will also have a House Washing course. $99.00 for the course and an additional $50.00 for the certification test. Contact PWNA headquarters today to register for that class.

The PWNA will be offering an abbreviated wood restoration course at the upcoming Texas Round Table event, hosted by Delux Cleaning Supply. This event is being held April 2, 2011 at Steamaway, Inc. This is NOT a certification course. For more information on this course or to register, please contact PWNA headquarters at 1-800-393-7962.

The PWNA will be holding a House Washing Course next Thursday, March 17, at Mobi Clean's Round Table. The cost for the course is $99.00 plus an additional $50.00 for the certification test. To register for the event, go to www.powerwashstore.com. To register for the House Washing course offered by the PWNA, please go to www.pwna.org or call 1-800-393-7962 and speak with Jackie!