Submitted Comment Name Mark Palmer Affiliation Sausalito Sustainability Commission Subject Heat pump rules Message Dear Bay Area Air District Staff, Thank you for the opportunity to comment. I want to express my strong support for the District’s overall approach of requiring newly installed water and space heaters to be zero-NOx after the specified compliance dates, with truly common-sense exceptions for the rare cases where no feasible alternative exists. However, as currently drafted, the proposal does not properly align with California’s climate goals. It will not achieve anywhere near the greenhouse gas reductions required under the 2022 Scoping Plan, and it falls far short of the air-quality improvements needed to meet State Implementation Plan (SIP) targets. To ensure meaningful progress, the start date should be accelerated. The proposed 2030 implementation timeline risks locking in years of preventable emissions and local pollution exposure. Likewise, emissive sales limits should ramp down much more quickly and ultimately allow for only the most technically challenging situations—not broad categories that slow transition. The regulation must also include stronger equity protections. As written, it lacks adequate mechanisms to ensure that disadvantaged communities are not left behind or disproportionately exposed to continued combustion-related pollution. In addition, the proposed credit system should be restructured so that it cannot undermine the rule’s emission-reduction objectives. Appropriate and enforceable penalties for non-compliance are equally essential for ensuring that the regulation delivers the intended benefits. Finally, CARB’s analysis significantly overstates the frequency and cost of electrical-service upgrades associated with installing non-polluting equipment. Overestimating these impacts skews the cost-effectiveness evaluation and could inadvertently weaken the rule. I urge the District to strengthen the proposal so it delivers the air-quality, climate, and equity outcomes our region urgently needs. Sincerely, Mark Palmer Chair, Sausalito Sustainability Commission Marin Electrification Council File Upload (i.e., Attachments): N/A N/A
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