HomeMy WebLinkAboutLetter of Opposition Regarding South Coast Air Quality Manag (2) ��c�TiNCToti 2000 Main Street,
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92648
City of Huntington Beach
g APPROVED
7-0
File#: 25-165 MEETING DATE: 3/4/2025
REQUEST FOR CITY COUNCIL ACTION
SUBMITTED TO: Honorable Mayor and City Council Members
SUBMITTED BY: Travis Hopkins, Acting City Manager
PREPARED BY: Jennifer Carey, Deputy City Manager
Subject:
Letter of Opposition Regarding South Coast Air Quality Management District (AQMD)
Proposed Amended Rules 1111 and 1121
Statement of Issue:
The Air Quality Management District (AQMD) has proposed Rules 1111 and 1121 which seek to
'establish new zero-emission standards for space and water heaters. The implementation of these
new standards could lead to increased appliance costs, limited appliance options, and costly
appliance repairs. Given that these factors will likely have financial impacts on our City's residents
and businesses, staff recommends submitting a letter of opposition to the South Coast AQMD
Governing Board.
Financial Impact:
The drafting of the proposed letter does not have any fiscal impact.
Recommended Action:
Direct City Manager to Draft and Send a Letter on Behalf of the City of Huntington Beach to the
South Coast Air Quality Management District Governing Board Opposing Proposed Amended Rules
1111 and 1121.
Alternative Action(s):
Do not approve, and direct staff accordingly.
Analysis:
The Air Quality Management District (AQMD) has proposed Rules 1111 and 1121 which seek to
establish new zero-emission standards for space and water heaters. These new rules would be
applicable to both new and existing residential and commercial buildings and would take effect within
the next two to five years.
Implementation of Rules 1111 and 1121 will likely lead to increased costs and added inconvenience
for our residents and business owners. Access to zero-emission appliances is limited, leading to an
City of Huntington Beach Page 1 of 2 Printed on 2/26/2025
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File#: 25-165 MEETING DATE: 3/4/2025
unnecessary burden in seeking these critically needed appliances and finding qualified contractors to
make much needed repairs.:
The City of Yorba Linda recently submitted a letter of opposition (Attachment 1) citing various similar
concerns and also noted the impact on the State's already limited power grid.
Environmental Status:
This action is not subject to the California Environmental Quality Act (CEQA) pursuant to Sections
15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change
in the environment) and 15060(c)(3) (the activity is not a project as defined in Section 15378) of the
CEQA Guidelines, California Code of Regulations, Title 14, Chapter 3, because it has no potential for
resulting in physical change to the environment, directly or indirectly.
Strategic Plan Goal:
Non Applicable -Administrative Item
Attachment(s):
1. City of Yorba Linda Letter of Opposition - South Coast AQMD Proposed Rules 1111 and 1121
City of Huntington Beach Page 2 of 2 Printed on 2/26/2025
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, wig
,A CITY of YORBA LINDA
0
* * OFFICE OF THE CITY COUNCIL
February 20, 2025
Hon. Vanessa Delgado, Chair
South Coast Air Quality Management District Governing Board
`' 21865 Copley Drive
z Diamond Bar, CA 91765
Dear Chair Delgado and Governing Board Members,
On behalf of Yorba Linda's residents, business owners, churches, schools, and
organizations, the City of Yorba Linda opposes South Coast AQMD's Proposed
j Amended Rules 1111 and 1121 and strongly urges you to thoroughly engage with the
17 million stakeholders who would be impacted by such a proposal.
Yorba Linda has several significant concerns regarding the impact of these rules.
Foremost among them is the issue of affordability and lack of consumer choice when
replacing gas furnaces and water heaters with zero-emission appliances. Hot water and
heating are essential human needs. When residents' appliances break down and need
replacement, immediate service is paramount. Replacing a gas appliance with an _
'' electrical one will require far more intrusive electrical and plumbing upgrades and even
physical renovations costing tens of thousands of dollars more —a burden many families
and business owners cannot bear.
Further, the City shares the Orange County Council of Governments' concern that the
substantial costs of compliance could compel owners of older multifamily properties to
sell or redevelop their buildings, potentially leading to a decrease in affordable housing
available throughout the region. If our region's workforce must commute further and
II further to find affordable housing, any emission reductions from these rules will be offset
l/ by substantial increases in vehicle emissions.
tjEqually concerning is that transitioning to all-electric water heaters and furnaces would
increase the demand on California's already inconsistent and delicate power grid. Adding
millions of new electric water heaters and furnaces would require a substantial amount of
power and increase the potential for brownouts or outages. Furthermore, many residents
of Yorba Linda (and many others in AQMD's jurisdiction) have been impacted by Public
Safety Power Shutoffs and have lost their electricity for multiple days during critical fire
weather conditions; a prime example of why adding more load to the current grid is
untenable. The City strongly opposes any efforts to add more load demand until the
necessary energy generation and electrical transmission capacity is constructed and in
service.
4845 Cdsa Coma-Avenue, Yorba Linda, CA92886
714-961-7110 I www.yorbaliriclaca gov
47
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:,tyk. CITY of YO R BA L.I.N DA
7- OFFICE OF T H E CITY COUNCIL
Our City Council shares your commitment to provide clean air and water and other quality
of life benefits that draw and retain the residents and business owners who live here.
However, the proposed amended Rules 1111 and 1121 will deliver consequences that
will lead to a variety of negative impacts, impacting jobs and increasing the cost of living
in our region.
For these reasons, the City of Yorba Linda opposes Proposed Amended Rules 1111
and 1121, including their current concept as discussed at the 7th Working Group Meeting
on February 13, 2025. We request that the AQMD Governing Board not proceed with
11 these rules, and instead, we urge the Board to initiate a comprehensive fact-finding
,, process that gathers public comments and addresses concerns related to costs, timing,
technology, and the availability of potential incentives.
Sincerely,
# A
Janice Lim
Mayor, City of Yorba Linda
9s
11
48,45 Cosa Lama Avenue, Yorba Linda, CA 928.3
714-961-7110. I www.yorbaliriaaca'.gov
48
45� N7iiucT _ CITY 0 F
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' ' a� HUNTINGTON BEACH
040
COUNTY�t;�,�► Pat Burns I Mayor
March 5,2025
Honorable Vanessa Delgado,Chair
South Coast Air Quality Management District Governing Board
21865 Copley Drive
Diamond Bar,CA
91765
Dear Chair Delgado and Governing Board Members,
On behalf of the residents, business owners,churches,schools,and organizations in Huntington
Beach,we strongly oppose the Proposed Amended Rules 1111 and 1121.These rules would
significantly impact over 17 million stakeholders across the region,and we urge you to engage
thoroughly with all affected communities before proceeding.
Affordability and Consumer Choice
One of our primary concerns is the affordability and lack of consumer choice when it comes to
replacing gas furnaces and water heaters with zero-emission alternatives. Hot water and heating
are essential needs,and when appliances break,swift replacement is critical.Replacing a gas
appliance with an electric one will likely require expensive electrical and plumbing upgrades,as
well as physical renovations, potentially costing tens of thousands of dollars. Many families and
business owners simply cannot bear this financial burden.
Strain on the Power Grid •
Transitioningto all-electric water heaters and furnaces would place additional strain on California's
already fragile power grid.The increased demand for electricity could exacerbate the risk of
brownouts and outages. Many Huntington Beach residents have already experienced prolonged
power outages during Public Safety Power Shutoffs,and adding millions of new electric appliances
would further jeopardize grid stability.We strongly oppose any efforts to increase demand on the
grid without first ensuring that sufficient energy generation and transmission capacity are in place.
Economic and Social Impact
While we share your commitment to improving air quality and the overall quality of life in our region,
we believe that the current proposal could result in unintended negative consequences.These
include increased costs of living and broader economic hardship.The City of Huntington Beach
urges you to carefully consider these consequences before moving forward with the proposed
rules.
Request for Further Engagement
We request that the AQMD Governing Board reconsider proceeding with the proposed amendments
to Rules 1111 and 1121 in their current form.Instead,we urge you to initiate a comprehensive fact-
finding process to gather public input,address concerns related to costs,technology feasibility,
Office: (714)536--5553 I 2000 Main Street,Huntington Beach,CA 92648 i www.huntingtonbeachca.gov
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and the availability of incentives,and explore potential alternatives that balance environmental
goals with the financial and practical realities facing our residents and businesses.
Thank you for your attention to these important issues.We look forward to working with you to find
solutions that benefit both the environment and the community.
Sincerely,
4,7:PHI--->erife-e....---e.--,....0
Pat Burns
Mayor
Office: (714)536—5553 i 2000 Main Street,Huntington Beach,CA 92648 1 www.huntingtonbeachca.gov
From: Frakes.Sandie
To: 5uoolementalcomm(asurfcity-hb.org
Subject: FW:City Council agenda item 25-165 AQMD Amendments 1111&1121
Date: Friday,February 28,2025 8:42:04 AM
Original Message
From:Ted Ross<tedross_0077@msn.com>
Sent:Thursday,February 27,2025 6:20 PM
To:CITY COUNCIL(INCL.CMO STAFF)<city.council@surfcity-hb.org>
Subject:City Council agenda item 25-165 AQMD Amendments 1111&1121
HBCC:
Just another example of Non-Elected politicians with an agenda that that is completely over-reach with any thought
about the economic impact to already overtaxed citizens. I indorse your proposed action to let this agencies over
reach is unacceptable.
Sent from my iPhone Ted Ross,Huntington Beach resident
SUPPLEMENTAL
COMMUNICATION
Meeting Date: 3/4/2025
Agenda Item No. 13 (25-165)
SUPPLEMENTAL
COMMUNICATION
From: Tristan Miller MeetingDate: 3/4/2025
To: suoolementalcommtsurfcity-hb.ora:CITY COUNCIL(INCL.CM0 STAFF)
Subject: 25-165 13.Consent Calendar Letter of Opposition Regarding South Coast Air Quality Management District(AQMD)Proposed Amended Rules 1111
and 1121
Date: Monday,March 3,2025 11:22:46 AM Agenda Item No. 13 (25-165)
Attachments: PastedGraohic-2,png
Dear Mayor and City Council,
We do not support a letter opposing SCAQMD's 1111 and 1211 rules.
Our family and business support AQMD's proposed rules for 1111 1211,prioritizing the health,safety,efficiency,
and comfort of our homes.
President Ronald Reagan supported electrification and even hosted a show called Live Better Electrically.
The electrification of the Ronald Reagan Building alone will save over$6.3 million in energy costs annually and
reduce emissions by 16,000 tons.
This ruling aims to achieve similar savings for residents and businesses,preventing thousands of premature deaths,
16,000 cases of early-onset asthma,and over 4,000 ER visits:https://www.aqmd.gov/docs/default-source/rule-
book/Proposed-Rules/1111-and-1121/rule-1 1 1 1-1 121-fact-sheet-engl ish.pdf?sfvrsn=6
Electric heat pumps and water heaters are easy to install,with many models designed to plug directly into a standard
120V outlet,meaning no significant installation costs are involved.I'd like to clarify the point mentioned in the Yorba
Linda Letter.
Research below shows that over 700 homeowners have been 26%more efficient when using electric heat pumps.
There are dozens of heat pump models ready for immediate use with any nearby standard 120V outlet,eliminating the
need for rewiring.Every brand offers an approximately$700 electric resistance tank,an—$800 Ultra Low NOx gas
tank,and a$1500 heat pump tank.This allows consumers to choose a lower-cost electric tank or a higher-cost heat
pump tank based on their short-and long-term budget.One million California households already use an electric
resistance tank,making them the most popular water heater sold in the U.S.
Thank you!
Tristan Miller
Parent of a Family of 5 and Business Owner
Oran_e Coun ,California
Comparison of Peak -day grid impacts (700
customer Avera•e
Pre-Retrofit u'nr,_.
Winter i leatPump Peak 3.9 kW'
Retrofit Peak
m 33kW
I
Y
1.5
1
0.5 26%Reduction in Summer Peak from higher efficiency AC that comes with Heat Pump Retrofit
0
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
The information transmitted is intended only for the person or entity to which it is addressed and may contain CONFIDENTIAL material.
If you receive this material/information in error,please contact the sender and delete or destroy the material/information.
From: Amir Baum
To: 5uoolementalcomm(@surfcity-hb.orq;CITY COUNCIL(INCL.CMO STAFF1
Subject: Re:City Council meeting agenda item 13
Date: Monday,March 3,2025 1:31:00 PM
Some people who received this message don't often get email from amir.baum@gmail.com.I earn why this is
important
Dear Mayor and City Council Members,
I am writing in strong support of the proposed amendments to Rules 1111 and 1121. I applaud
AQMD's work to reduce NOX emissions,thereby reducing new asthma cases, hospital visits
and premature deaths. Our air quality has vastly improved because of your historic efforts, but
we still have some of the worst air quality in the nation.
In the long run,these rules will save money and reduce emissions that impact our environment
and our health. There is evidence to back this up, and the urgency for action cannot be greater
when action at the federal level is falling apart to protect our air and our environment.
Therefore it is contingent on you all as elected members of city council to listen to the
community concerns and place health over profit to make the right decisions for our health
and safety.
Thank you for your efforts in providing better living conditions in our region.
Sincerely,
Amir Baum
From: Marilyn Palomino
To: 5uoolementalcomm(@surfcity-hb.org
Subject: Item 13 on the City Council Meeting Agenda
Date: Monday,March 3,2025 3:55:04 PM
To: City Council Members
I support the South Coast Air Qualities proposed amendments to rules 1111 and 1121. The
quality of the air we breathe is worsening everyday. Gas appliances in the home create toxins
in the air that are negatively impacting the health of people of all ages. Asthma, COPD,
premature birt, cancer and heart disease are on the rise. The quality of the air in our homes
matters!
Huntington Beach residents are already exposed to NOX emissions from oil wells and
drilling. The amendments being proposed won't curb those but they will help reduce
emissions in the long run.
I have lived in Huntington Beach for 38 years. This city had very few bad quality air days
back in the 80s. Now about half the year we experience poor air quality.
Please rescind your letter opposing the SCAQ rules!
Marilyn Palomino
From: Mike Selna
To: 5uoolementalcomm( surfcity-hb.orq
Subject: Agenda Item 13 Proposed Amendments to AQMD Rules 1111 and 1121 March 4,2025
Date: Monday,March 3,2025 6:01:24 PM
Attachments: Letter to City Council 3-4-25.odf
You don't often get email from mwselna@gmail.com.I earn why this is important
Please see the attached letter to the City Council on Agenda Item 13 on their 3-4-2025
Agenda.
Agenda Item 13, March 4, 2025
Proposed Amendments to AQMD Rules 1111 and 1121
Honorable Council Members,
Summary Points:
• AQMD has vastly improved our air quality. This is one more incremental step.
• We have accepted technical solutions inthe past such as auto catalytic converters.
• Heat pumps are highly energy efficient and result in utility cost savings.
• Installations are fast. My home was converted in a day, about like a furnace.
• Homes with AC are even more easily converted.
• These changes are supported by SCE so grid concerns must not be paramount.
• Most importantly,AQMD is doing this to protect health. The American Lung
Association supports these rules.
• Please to do go on record as opposed to protection of the health of your
constituents
I am writing to request that you not oppose the proposed amendments to AQMD Rules
1111 and 1121. AQMD's has worked to reduce NOX emissions,thereby reducing new
asthma cases, hospital visits and premature deaths. Our air quality has vastly improved
because of AQMD's historic efforts, but we still have some of the worst air quality in the
nation.
I witnessed appalling smog events in the 1970's in which we could not see the mountains,
your eyes stung, and your throat burned. As Southern California citizens we gratefully
accepted a technical solution...catalytic converters on our cars. Of course,AQMD also
worked on stationary sources associated with factories and municipal operations. Their
efforts were incremental but, in sum,we now have much better air quality.
What AQMD is trying to do now is move our air basin a little closer to compliance. We are
still way off compared to most of the rest of the nation. The proposed amendments involve
a phased approach so that homeowners are not suddenly hit with a new requirement. Just
as all the cars without catalytic converters were not suddenly pulled off the road, homes
are not required to make these changes unless they elect to or are replacing equipment
that has failed. And the rules are phased in over several years. I have reviewed the process
AQMD has followed, and I believe they have been very sensitive to the input they have
received over a multi-year process.
SoCal Gas has made the point that these rules will only result in a small change in NOX
emissions. That is probably correct, but it mimics the incremental process of correcting
problems such as this. Just as our HB ocean water quality has become incrementally
better with each improvement at OC San's treatment plants, air quality improves in the
same way with each step.
So, I have a question for you. When is the last time you thought about your catalytic
converter when you drove down the road (unless you were worried about it being stolen)?
In the same way,when your heater comes on you will not be thinking about whether it is a
natural gas furnace or an electric heat pump supplying your warmth.
The Yorba Linda letter contains a number of exaggerations. Contrary to what is stated,
these systems are not difficult to install, especially if the home already has an air
conditioning system. We recently had an HVAC heat pump installed in our home that did
not have AC. The installation took less than a day, basically the same time frame as
replacing a natural gas furnace. The HVAC industry is well equipped to install these
systems, and they are very popular across the nation because they operate far more
efficiently. In our area even Costco offers big rebates on these systems.The demand on
the grid will be minimal compared to other pending loads such as data centers. SCE is in
support of these rule changes. Job opportunities will actually increase, not be negatively
impacted as Yorba Linda contends. I know from experience that heat pump systems save
homeowners money on their utility bills.
In the long run,these rules will save money and reduce emissions that impact our
environment and our health. These rules are supported by the American Lung Association,
a fact we should seriously consider. I urge you to not go on record as opposing rules that
protect the health of your constituents.
Thank you for considering my input.
Respectfully,
Af
Michael Selna, HB Resident
Licensed Professional Civil Engineer
Board Certified Environmental Engineer
From: Charles Jackson
To: suoolementalcomm(asurfcity-hb.orq
Subject: Oppose item 13,25-165
Date: Monday,March 3,2025 9:07:56 PM
You don't often get email from cjackson@ieee.org.Learn why this is important
Dear HBCC
I would like to speak against the 13, 25-165
I support the gradual electrification of space heaters and water heaters.
I know I can't change your mind, but I hope that when you write a letter for Huntington Beach
that it is not full of out of date concerns and misinformation.
First, the Yorba Linda letter claims that the change will have severe impacts on multi-family
units, but there will be exceptions, and the concern is invalid.
Second,the Yorba Linda letter makes out dated complaints. Heat pump technology has
advanced in recent years, and commercial units are in place. The costs of replacing units it
overstated.
Third, claiming that the additional costs will cause people to move away from Huntington
Beach is somewhat absurd. Not building new housing in Huntington Beach is raising costs
more. But the new units will cost lest per month, so housing costs will actually go down.
Fourth,water heaters have an insignificant impact of the grid. But space heaters do not
impact the grid in summer; they are used in the winter. It is absurd to say that space heaters
will impact the power grid during peak months. An the change will be spread out over 20
years.
Charlie Jackson, 23 year resident of Huntington Beach
From: Fikes,Cathy
To: uoolementalcommCalsurfcity-hb.orq
Subject: FW:Item 13 on the consent calendar
Date: Tuesday,March 4,2025 9:06:34 AM
Original Message
From:Susan Eaton<seaton727@earthlink.net>
Sent:Tuesday,March 4,2025 7:29 AM
To:CITY COUNCIL(INCL.CMO STAFF)<city.council@surfcity-hb.org>
Subject:Item 13 on the consent calendar
[Some people who received this message don't often get email from seaton727@earthlink.net.Learn why this is
important at j ps://aka.ms/l.earnAboutSenderldentification
The public needs to hear the reasons why 1111&1112 provide the best solutions for CA new homes and
replacements.I was raised in a home with no gas and repeatedly told by my mother that she would not allow gas in
our home because of a safety issue.I am 86 years old.
I now know other reasons for our whole country to convert to electricity.A recent webinar I listened to said that it is
the rage all over the country.
As a forward-looking state,we don't want to be left behind on this issue.Please pull Item 13 and listen and discuss
reasons to support the legislation and vote accordingly.
Susan Eaton
Retired Teacher
Sent from my iPhone
