Submitted Comment Name David Moller Affiliation Marin Electrification Council Subject Zero-Emission Space and Water Heater Standard Message I am very concerned that CARB’s proposed Zero-Emission Space and Water Heater Standard, which relies on emissive sales limits plus credits, does not align with state climate goals and will not reduce GHG emissions anywhere near the requirements of the 2022 Scoping Plan and the State Implementation Plan. The approach adopted by the Bay Area Air District of 100% zero emissions sales with common sense exceptions is much more certain in its timing and effectiveness and should be the model utilized by CARB. To the extent CARB chooses to use the emissive sales limits plus credits approach, the start date should be accelerated. The proposed 2030 start date unnecessarily allows for preventable emissions and pollution in years prior to 2030. And the new emissive equipment installed during this period will continue to emit detrimental combustion products for another life-cycle. The emissive sales limits should ramp-down much faster and to a level that accounts for only the most challenging situations. Additionally, the credit system should be restructured such that it does not undermine the emission reduction goals of the regulation. And it is critical that there be appropriate penalties for non-compliance. Two other concerns I have are that the proposal does not have proper mechanisms in place to prevent leaving disadvantaged communities behind and the analysis supporting the proposal seriously overstates the need for electrical service upsizing associated with installing non-polluting devices. We need CARB to adopt a Zero-Emission Space and Water Heater Standard that greatly accelerates our transition to our clean energy future rather than tiptoeing. We have the technology, the manufacturing capability and the installation capacity to support this. Let’s get going! File Upload (i.e., Attachments): N/A N/A
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