California Air Resources Board

As a residential homeowners, I'm writing to express that I strongly favor the approach of the Bay Area Air District requiring that newly installed water and space heaters be zero NOx after specified dates with common sense exceptions.

I'm writing based on my personal experience of electrifying my legacy home, which was built in 1991. Over the last 5 years, I have electrified my gas cooktop, gas space heater, gas water heater and gas clothes dryer. I also purchased two Electric Vehicles and added a Level 2 charger. In doing so, my electrical service remained at 200 amps, and I've seen several of these appliances become available at 120 volts, which offer plug-in capability for a heat pump water heater, or with a battery-on-board stove, also with a 120 volt connection. My view is that your Proposal overstates the costs of space and water heater conversion from fossil gas, and minimizes the potential of conversion. I have since had PG&E turn off the gas at the main under the street, and our home is safer from earthquakes, and healthier without gas in our kitchen.

Here are some of the problems of the Proposal:

1. Proposal does not properly align with state climate goals
2. Proposal will not nearly reduce GHG emissions enough as required by 2022 Scoping Plan
3. Falls far short of eliminating air pollution as needed to match targets of the State Implementation Plan (SIP)
4. The start date should be accelerated as the proposed 2030 date allows for preventable emissions and pollution in years prior
5. The emissive sales limits should ramp down much faster and to a level that accounts for only the most challenging situations
6. Does not have proper mechanisms in place to prevent leaving disadvantaged communities behind
7. The credit system should be restructured such that it does not undermine the emission reduction goals of the regulation
8. Appropriate penalties for non-compliance are critical
9. CARB's analysis overstates the need for electrical service upsizing associated with installing non-polluting devices. Electricians I spoke with say that it would be unlikely to blow a circuit, even with a whole home electrification. That is true -- I've never blown a circuit even with my traditional 200A connection. If I added up all the amperages for every appliance, it would be over 200A. But they are never on all at the same time.

Thank you for listening.