California Air Resources Board

Dear California Air Resources Board Staff,

On behalf of the Plumbing-Heating-Cooling Contractors of California (PHCC of California), I submit these comments in strong opposition to the proposed Zero-Emission Space and Water Heater Standards as presented in the December 11, 2025 workshop. PHCC of California represents plumbing and HVAC business owners, licensed technicians, apprentices, and our industry partners and affiliates across this state. We are the professionals who install, service, repair, and maintain the very equipment this regulation seeks to eliminate—and we are telling you unequivocally: this proposal is not ready, not workable, and not grounded in real-world conditions.

PHCC of California operates a state and federally approved indentured plumbing apprenticeship program. We train the next generation of skilled workers in the plumbing and HVAC trades. We know what happens on job sites, in customers' homes, and in California's diverse climate zones. We are not opposed to innovation or environmental progress: we are opposed to regulatory overreach built on arbitrary timelines, wishful thinking, and a fundamental disconnect from economic reality.

I. ARBITRARY TIMELINES DIVORCED FROM MARKET REALITY

The dates embedded in CARB's proposed framework are not based on supply chain readiness, workforce capacity, or consumer affordability. They are politically motivated targets masquerading as regulatory milestones.

Let us be direct: you cannot regulate technology into existence, you cannot mandate affordability by fiat, and you cannot conjure a trained workforce out of thin air. The skilled technicians required to install, maintain, and service heat pump equipment take years to develop—and they do not currently exist in sufficient numbers to meet existing demand, let alone support the accelerated transition CARB envisions.

The TECH Clean California program incentives are exhausted. Federal incentives through the Inflation Reduction Act are expected to be fully subscribed by the end of this month—January 2026. No long-term funding source has been identified to bridge the gap between the cost of heat pump technology and what California families and businesses can actually afford. CARB is proposing to force a market transition with no financial support system in place.

This is not policy. This is aspiration dressed up in regulatory language.

II. AFFORDABILITY IS NOT A FOOTNOTE—IT IS THE FOUNDATION

Our industry partner, Bradford White Corporation, has provided CARB with detailed analysis of utility rate impacts across California's four major Investor-Owned Utilities. The data is clear and should concern every policymaker in Sacramento:

Heat pumps are NOT automatically cheaper to operate than gas equipment.

According to Bradford White's analysis submitted with their statement, the operational cost comparisons presented assume off-peak electricity pricing exclusively. Any operation outside off-peak hours—which is inevitable in real households with real hot water demands—subjects consumers to substantially higher costs per kilowatt-hour. The analysis further assumes perfect load management strategies, which most consumers do not have access to, do not understand, and cannot implement without significant education and investment. This raises a critical question: who is responsible for funding this consumer education and load management infrastructure? Is CARB prepared to fund it? Will the obligation fall to publicly-owned utilities? Or is this yet another unfunded burden shifted to consumers and contractors? If CARB has no plan for this, it fundamentally undermines the premise of these regulations.

And let us not forget the first cost. Heat pumps cost significantly more to purchase and install than gas equipment. It is not unusual to relocate a new heat pump in a household because where the current equipment resides may lack sufficient space for ventilation. Heat pumps require substantially more clearance than traditional gas or electric resistance units—often necessitating relocation to garages, utility rooms, or other spaces that may require electrical upgrades, new condensate drainage, and additional ductwork or venting. This means additional materials and labor which can escalate costs significantly, and this assumes the electric panel providing energy to the home is sufficient for the additional power load otherwise offset by a gas appliance. Without robust, sustained incentive programs, these products are simply out of reach for working families, fixed-income seniors, small businesses, and affordable housing providers.

CARB cannot impose an unfunded mandate on California consumers and call it climate policy.

III. WORKFORCE READINESS: WHERE ARE THE TECHNICIANS?

CARB failed to properly consult with the open shop trades who are in fact predominant in the residential service, installation and repair sector across the state for plumbing and HVAC. Had it done so, it would have learned there is a considerable shortfall in the number of qualified plumbers and HVAC technicians needed to fulfill current demand, let alone help the state achieve its own targets for zero-emissions water and space heating. This shortage is not unique to California: according to employment projections compiled by the U.S. Bureau of Labor Statistics, at any given time between the years 2024 and 2034 the placement rate for job vacancies in the plumbing and HVAC fields is roughly 6.5%. Put plainly: there are not enough workers, and there will not be enough workers for years to come.

PHCC of California trains apprentices through a rigorous, state and federally approved indentured program. It takes years for these apprentices to undergo the education and training necessary to competently and successfully perform in this field. The rate of vacancies far outpaces the rate of placement in this field, meaning the timelines set out by CARB to achieve its zero emissions goals are nearly impossible to achieve by virtue of the fact that there simply aren't enough workers and it takes years to train people in this field, regardless of whether they're affiliated with either a signatory or merit shop contractor.

This regulation assumes a workforce that does not yet exist in sufficient numbers. It assumes an electrical infrastructure that is not yet in place. It assumes consumer acceptance that has not materialized despite years of incentive programs.

You are proposing to ban proven, functional equipment before the replacement technology, workforce, infrastructure, and funding are ready. That is not environmental leadership. That is regulatory malpractice.

V. WHAT WE REQUEST FROM CARB

If CARB is serious about achieving emissions reductions rather than simply announcing them, the following conditions should be met before any implementation timeline is established:

Work with utilities to create and prove Heat pump-friendly rates and load management strategies that actually incentivize the use of heat pump technology over gas—not theoretically, but demonstrably in real-world conditions across all climate zones and housing types in California.

Establish a long-term, guaranteed source of funding to reduce the purchase and installation cost of heat pump equipment. This cannot be subject to annual budget negotiations or federal policy changes. If CARB mandates the technology, CARB must guarantee the funding.

Conduct genuine workforce impact assessments in coordination with industry apprenticeship programs, contractor associations, and labor organizations. Understand what it will take to train sufficient technicians before setting arbitrary compliance dates.

Implement any equipment tracking or reporting system in a manner that does not place undue administrative burden on manufacturers, distributors, or contractors. Compliance costs flow downstream to consumers. Every dollar spent on paperwork is a dollar not spent on technology deployment.

Abandon arbitrary timelines and replace them with performance milestones tied to actual market conditions: incentive program funding levels, workforce certification numbers, electrical infrastructure readiness, and demonstrated consumer adoption rates.

VI. CONCLUSION

PHCC of California is not opposed to progress. We are opposed to hyper-aggressive timelines and an approach not rooted in market or technical realities. We are opposed to regulations lacking deference to the skilled professionals who confer daily with the end-users of the equipment mandated by CARB and perform regular maintenance on those products: these professionals understand the capabilities and limitations of the equipment they install based on a variety of complex real-world conditions, and they are in fact uniquely positioned to actually help CARB achieve its climate goals.

We are the professionals California relies on to keep homes warm and water hot. Our reluctance to rubber stamp our approval
of CARB’s approach does not make us obstacles to be overcome, but a resource with irreplaceable expertise and a willingness to work with you.

Otherwise, this proposal, as presented, is simply unacceptable. The timelines are arbitrary. The funding is nonexistent. The workforce is insufficient. The cost burden on consumers is unsustainable. The regulatory framework adds administrative burden without driving meaningful behavior change.

We urge CARB to return to the table with humility, engage authentically with industry stakeholders, and develop a proposal grounded in fact-based science and real-world timeframes.

California deserves better than regulation by aspiration. Contractors deserve better. The consumers and businesses who depend on affordable, reliable hot water and space heating deserve better: ultimately, it is plumbing and HVAC contractors, not CARB, who must personally explain to California homeowners why their heating options are more limited and expensive. CARB is espousing the need for affordable housing while promoting policies that we, as professional contractors, know achieve the exact opposite.

We stand ready to work toward solutions—but not under these terms.

Respectfully but firmly submitted,

Whitney Squire
Chief Executive Officer
Plumbing-Heating-Cooling Contractors of California (PHCC of California)