California Air Resources Board

I am disappointed that the California Air Resources Board (CARB) is choosing a weak, poorly designed market-based approach to boost the adoption of zero-emission heating equipment such as water heaters and space heaters. The climate crisis and our commitment to our children’s health demands a stronger standard.

Electric heat pumps are already the dominant technology in the Nordic countries and, to a slightly lesser extent, in Asia. By contrast, progress on this front in the U.S. has been stymied by the fossil fuel lobby which is powerful and politically entrenched. Policymakers aren’t operating on a level playing field. CARB needs to make a standard that will protect public health as opposed to carving out abundant space for fossil-fuel-burning equipment.

The obvious climate benefits of electrification stem from the high energy efficiency of heat pumps relative to gas appliances (3 to 5 times more efficient), and the fact that California’s electricity grid is already very clean and continuing to improve. Meanwhile, we can’t ignore the fact that lower-income communities and communities of color are disproportionately affected by indoor air pollution; research shows gas-burning heaters can result in nitrogen dioxide levels that exceed outdoor safety standards.

As proposed, CARB’s zero emission space and water heater standard falls far short of the pollution-removal requirements of the State Implementation Plan (SIP).

Specifically, the CARB proposal offers a highly delayed start date which would allow many more fossil-fuel powered appliances to be installed.

In addition, while there is an effort to have a smooth transition by gradually ramping down sales of fossil field equipment, the proposal process is far too generous. I would support a much faster ramping down. It is simply unacceptable to make plans that include fossil fuel combustion as late as 2045 as is done in this proposal. CARB must be forward-looking, encouraging a race to the top with its standards.

To summarize, in its current form, this proposal is a missed opportunity that fails to satisfy the SIP. To protect the health of this and future generations, and fulfill our state’s climate mandates, CARB must implement a far more aggressive ramp-down of combustion-based heater sales. I look forward to seeing a revised standard that closes loopholes for the fossil fuel industry and sets a bold course for California’s electrified future.