California Air Resources Board

The attached comments explain why the proposed Zero-Emission Space and Water Heater Standard is not appropriate for swimming pool heaters. Pool heaters are fundamentally different from space and domestic water heaters, contribute a de minimis share of statewide NOx emissions, and lack commercially viable zero-emission alternatives at the scale required. The proposal would impose excessive costs, create technical and siting barriers, and risk widespread pool closures—undermining California’s drowning-prevention, public-health, and equity goals. CPSA and PHTA respectfully urge CARB to exclude pool heaters from this rulemaking, conduct a pool-heater-specific emissions and feasibility analysis, and engage directly with affected stakeholders before pursuing any future regulation.