Submitted Comment Name Annika Osborn Affiliation Sustainable San Rafael Subject No to CARB's NOx proposal! Message I strongly support the Bay Area Air Quality Management District's approach requiring zero-NOx water and space heaters after specified dates with reasonable exceptions. However, CARB's current proposal falls significantly short of what's needed. The proposal fails to align with state climate goals and will not achieve the GHG emission reductions mandated by the 2022 Scoping Plan. It also falls far short of the air pollution elimination targets in the State Implementation Plan. The 2030 start date is too late—it allows years of preventable emissions and pollution. The emissive sales limits should ramp down much faster and account only for the most challenging replacement situations. Critical concerns include: inadequate protections to prevent disadvantaged communities from being left behind; a credit system that undermines emission reduction goals; insufficient penalties for non-compliance; and an overstatement of electrical service upsizing needs for zero-emission appliance installations. CARB must accelerate timelines, strengthen emission limits, restructure the credit system to support rather than undermine goals, ensure equity protections, establish meaningful compliance penalties, and correct the analysis on electrical infrastructure requirements. File Upload (i.e., Attachments): N/A N/A
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