EPA Regulations Pose Problems for Mobile Detailers
By Tracy Charuhas
Reclaim equipment such is this portable dam and pump help mobile detailers stay in compliance with the law. |
The days when mobile detailers could wash cars in customers' driveways or public parking lots with no thought to water use are supposed to be over--but they're not. Despite stricter enforcement of the Clean Water Act in recent years at local, state and national levels, it is fair to say that a good percentage of mobile detailers still neglect to manage their wastewater properly.
Local situations vary widely across the nation, but the existence of an uneven playing field is difficult for many law-abiding mobile detailers to swallow. But even if all mobile detailers operated according to the rules, there is still a question of whether the cost of compliance would be too much to bear.
Modern Car Care talked to several mobile detailers, manufacturers and carwash industry consultants about the future of mobile detailing to find out if they believe operating a mobile detail service under the law is a viable business.
The panel includes:
- Skip Reisert, owner of Skip's Mobile Detailing, Long Island, NY
- George Khachadoorian, owner of Simple Solution, Fullerton, CA and former president of the Southern California Detailers Association
- Robert Hinderliter, owner and president, Delco Cleaning Systems, Fort Worth, TX
- R.L. "Bud" Abraham, president of Detail Plus Car Appearance Systems, Portland, OR
- Robert Roman, independent consultant for Freytech Inc., Clearwater, FL and former mobile detailer
What type of investment is required to comply with discharge regulations?
Khachadoorian: The cost of a containment device is around $1,000 to $1,500, then you need a pump and also a tank to hold the water--that's about $2,000. The more elaborate guys who wash a lot of cars will probably want to buy systems that recycle the water so they can use it again. That will increase the overall cost.
Hinderliter: There are several options ranging in cost from $500 (using consumer type products) to $2,000 or $3,000 depending on how sophisticated they want to make their operation.
Can the average mobile detailer afford to comply with water discharge restrictions?
Reisert: I think that prices would have to be increased. It will definitely be a strain on mobile detailers who don't have a lot of capital behind them--that's one of the reasons they're in the mobile detailing business because they may not be able to afford the investment of a fixed location.
Roman: Mobile detailing is going to become more problematic. If you collect water the way you're supposed to it's going to take more time. You're adding a lot more steps to your production process and time is money. In order to keep revenues the same you're going to have to increase prices or do more work.
Does every mobile detailer have to make that kind of investment to be in compliance?
Hinderliter: The EPA doesn't provide written endorsements of products, processes or technologies. The EPA's responsibilities are directed at setting specific discharge objectives. Therefore, these objectives will vary from city to city. However, cities can be product specific and most cities are coming up with best management practices or guidelines for mobile detailers.
Why do you think it is difficult for government agencies to enforce the law with mobile detailers?
Roman: The EPA is based out of regional offices and they look to the states who look to the local programs to help enforce the rules. They just don't have the manpower.
Khachadoorian: Mobile detailers are like gypsies--they move around and aren't in a certain place every day at a specific time where a code enforcement officer can catch them.
Abraham: The federal government leaves it to the states to enforce it and the states leave it to the local authorities. Unfortunately for our industry the people get false signals depending on how intense the local authorities are about enforcing these laws.
Have you noticed any changes in enforcement in the last few years?
Khachadoorian: There are several cities (in the Los Angeles area) that have written ordinances that say mobile detailers have to collect their water. They can't get a license to operate until they've shown the city that they have the equipment. This levels the playing field and brings guys up to speed immediately. Now after six years the cities around here are finally giving fines.
When do you think detailers will see stricter enforcement of the Clean Water Act?
Hinderliter: Right now we're in a transition period, and I figure that's going to last about 10 years. Now when the Clean Water Act was passed in 1972 I estimated it would be about 20 years before it got down to the contractor level, and that was pretty close. Within the next 10 years, the population as a whole is going to have to decide the level of enforcement. What are we willing to pay? How far are we willing to go?
Roman: I think if some people start getting popped that's when (the mobile detailers who aren't in compliance) will do something about it. The enforcement has to be strong whether you're going to warn people or impose penalties.
How do you think carwash operators and law-abiding mobile detailers feel about the mobile detailers who aren't in compliance with the law?
Abraham: I don't have a complaint about the mobile detailing business but if I'm a carwash operator and I have to pay thousands and thousand of dollars to collect to the sanitary sewer and put in equipment that allows me to do that why should some guy running around in a truck be able to wash cars in the street and dump this stuff into the storm drain?
Khachadoorian: The mobile detailers who comply with the law get upset when they see a high school kid down the street washing cars and not collecting the water. The kid gets caught and just goes out of business. In the meantime the guy who has gotten all of this equipment is getting this every month. A new guy comes in, cuts his prices and he doesn't have equipment.
Why don't more law abiding mobile detailers report competitors who aren't complying with the law?
Roman: I think it's based on the individual. If I was in compliance and I saw somebody breaking the rules and they were hurting my pocketbook I'd turn them in in a heartbeat. The main thing is not to bust somebody's chops, it's to get them to stop doing what they're doing.
Khachadoorian: Most mobile detailers don't have time to report this. They're too busy doing their jobs.
Do you think stricter enforcement of the Clean Water Act will drive some mobile detailers out of the business?
Abraham: Probably. Most guys I've talked to in the mobile detailing industry got into it because it's cheap. They don't really need to have a fixed location. It's usually a one-man deal. They can run it out of their car or truck. This will change things.
Reisert: The attrition rate will definitely escalate when stricter enforcement comes around.
Khachadoorian: The ones who make a living at this will stay in it. If a guy is just doing it seasonally or for extra money and isn't really serious about it he'll just get out of the business.
Roman: The reason I got into the mobile detailing business in the '70s was because entering the market was so easy. I had a vehicle, I bought some supplies and I got into business. These regulations will make getting into the business more complicated.
Water Discharge--The RulesSection 301 of the Clean Water Act (CWA) prohibits a point source discharge of pollutants into waters of the United States without a permit. According to the EPA's Region 6 headquarters in Dallas, TX, which classifies vehicle washing information under a power/pressure washing activity, anyone using wash equipment must obtain an NPDES permit for each discharge location. But due to the fact that many businesses are mobile, it is understood that it's not realistic to pre-determine discharge locations and obtain permits for each location. Most NPDES permitted process water discharges also require treatment and analysis of the discharge, which may not be practical for mobile detailers and other mobile washers. But there is an easy solution, the agency says: Don't discharge any water. The most common form of non-compliance is to discharge the process water into a storm sewer system or into a city street that drains to a storm water inlet. |