California Air Resources Board

I am a clean air advocate living in Mill Valley, CA. I am writing today to urge CARB to adopt standards similar to the space and water heater rules developed by the Bay Area Air District, which require that newly installed water and space heaters be zero NOx after specified dates with common sense exceptions. This approach is preferable to the emissive sales limit approach currently under consideration by CARB. The emissive sales limit proposal does not align with state climate goals and would fall short in achieving GHG reduction goals set out in the 2022 Scoping Plan. The proposal would also fail to meet air pollution reduction targets targets in the State Implementation Plan (SIP). In order to address these shortcomings, the start date could be accelerated and the emissive sales limits could be reduced much faster and allow for sales only in the case of the most challenging situations. The proposal also needs to adequately address the challenges faced by disadvantaged communities without perpetuating the use of space and water heaters that pollute indoor air. The credit system should be restructured in a manner that promotes emissions reductions. Lastly, appropriate penalties for non-compliance are critical for the program to be effective. Thank you for your consideration.