Submitted Comment Name Antonina Markoff Affiliation Climate Action California Subject Comments on CARB's Zero-Emission Space and Water Heater Proposal Message I urge you to implement the approach adopted by the Bay Area Air District rather than the emissive sales limit approach you are now considering If your priority is certainty and public health, the zero-NOx requirement is stronger. The Zero-NOx installation requirement (with exceptions) has many advantages: Clear, simple rule Guarantees real emissions reductions Easier for the public to understand Faster climate and health benefits. The sales-limit credit system has many disadvantages: More complex to administer and enforce Risk of loopholes or gaming the system Slower to deliver guaranteed pollution cuts. Thank you. Antonina Markoff File Upload (i.e., Attachments): N/A N/A
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