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Date:4/6/2025 7:46:27 PM
From:"Pete Marsh"
To:"Public Comment" publiccomment@anaheim.net
Subject:[EXTERNAL] Please SUPPORT SCAQMD's Proposed Amended Rule s 1111 and 1121
Attachment:SCAQMD is Phasing Out Deadly Appliance Emissions - Households and Busine sse s CAN Afford This Change - Pete
Marsh - March 2025.pdf;
Warning: This email originated from outside the City of Anaheim. Do not click links or open attachme nts unle ss you recognize the
sender and are expecting the message.
Dear Mayor Aitken and city councilmembers:
I write about Agenda Item 17 on the Anaheim City Council meeting Agenda for April 8th, 2025:
I as k that ins tead of a res olution oppos ing to the Rules , as recommended by the Honorable councilmember Kurtz, the Anaheim City Council s end a letter in
SUPPORT of Propos ed Amended Rules 1111 and 1121.
Thes e rules , contrary to the concerns expres s ed by opponents , will actually s ave the city money. I've attached a White Paper I s ubmitted las t month to the SCAQMD
Governing Board which explains why in great detail.
The bottom line is that while opponents s ay we can't afford to trans ition away from gas -fired appliances , the reality is that we can't afford not to.
I'll acknowledge right up front that fos s il fuels have been very good for humanity in many ways over a couple of centuries . However, we've learned that they come
with s ignificant downs ides to our economy, as well as human health and the environment: air pollution (s uch as the NOx addres s ed by the Propos ed Rules ) caus es
8-10 million premature deaths globally each year, and climate change is costing the economy dearly. Here's an excerpt from the attached white paper:
The US Commodity Futures Trading Commis s ion (CFTC) in September 2020 issued a sobering report titled “Managing Climate Ris k in the U.S. Financial Sys tem.”
(note that this was in the fourth year of Pres ident Trump's firs t term, and he had appointed all five commiss ioners who chartered this report and s igned off on it) The
opening paragraph of the Executive Summary s tates s tarkly:
“Climate change pos es a major ris k to the s tability of the U.S. financial system and to its ability to s us tain the American economy."
The CFTC report further finds : "IRENA es timates that $110 trillion of cumulative worldwide inves tment in the energy s ector will be needed leading up to 2050
(IRENA, 2019). That equates to roughly 2 percent of average global gros s domes tic product (GDP) per year over the period. Of the $110 trillion, $95 trillion is already
required under the reference cas e s cenario of current plans and policies but would need to be redirected from inves tments in high-carbon to low-carbon activities .
An additional $15 trillion is neces s ary to further reduce emis s ions . This trans formation is es timated to boos t total global GDP by 2.5 percent, or 5.3 percent when
cons idering the avoided climate-related damages relative to the reference case (maintenance of current plans and policies ). The trans ition would res ult in $11.8
trillion in s tranded as s ets by 2050, but delaying action would nearly double total s tranded as s ets to $19.5 trillion by 2050. However, the cumulative benefit in terms of
avoided climate-related and air pollution damages ranges from $50 trillion to $142 trillion, and reducing fos s il fuel s ubs idies would generate further s avings of $15
trillion by 2050, relative to the reference cas e.”
Pleas e notice that I haven't mentioned polar bears or unicorns . This about economics ; the quoted passage is from a cons ervative agency finding that Bus ines s As
Us ual is already cos ting the economy, and will impos e increas ing costs.
I'm not naive enough to pretend that this will be eas y. I choos e to work on phas ing out gas appliances from the 120+ million exis ting dwelling units in the US, becaus e
their cus tom nature makes them one of the mos t challenging parts of the low carbon energy trans ition. And the fos s il fuel indus try is around 15% of global GDP, s o
nothing about the trans ition is s imple. But SCAQMD's Propos ed Rules 1111 and 1121 are the most affordable and fair way to make our homes healthier: when an
appliance reaches end of life, the property owner will have to recapitalize that asset no matter what. Ins tead of inves ting in an as s et that will likely become s tranded,
replace it with an as s et that provides better health, better performance, and lower operating cos ts .
Pleas e is s ue a letter in SUPPORT of SCAQMD Propos ed Amended Rules 1111 and 1121.
Thank you.
Pete Marsh
Long Beach, CA (yes , I'm a neighbor, not a res ident of Redlands . But your decis ion impacts the entire air bas in, s o pleas e cons ider this input.)
Small business owner and retired U.S. Coast Guard Commander (O-5) who also held regional leadership roles with a highly successful startup
company and a marquee international technology consulting firm. Pro bono leadership roles in numerous civic and educational commissions
and nonprofit organizations focused on climate solutions, especially the decarbonization of the nation’s existing building stock, including:
USGBC California, AIA California, the Climate Reality Project, Climate Action California, and more.
California’s South Coast Air Quality Management District
(SCAQMD) is Phasing Out Deadly Appliance Emissions in Homes
Households and Businesses CAN Afford this Change:
Here’s Why
Prepared By: Pete Marsh, March 2025
Comments welcome:
Introduction :
This white paper summarizes numerous studies and analyses that illuminate the importance and affordability of two
Proposed Amended Rules under consideration by California’s South Coast Air Quality Management District (SCAQMD).
The rules, PAR 1111 and PAR 1121 , would deliver healthier air by driving down deadly emissions of Oxides of Nitrogen
(NOx) and related toxic gases that are released into the atmosphere and in many cases into nearly six million Southern
California dwelling units. The rules help households upgrade from polluting furnaces and water heaters to state-of-the-art
and highly efficient equipment in the most cost-effective and equitable manner possible: as building owners replace
existing appliances, usually at end of life, manufacturers must meet increasingly high sales targets of non-emitting
appliances.
About the Author :
The author is a solar contractor, small business owner, and retired U.S. Coast Guard Commander (O-5) who held
command assignments both afloat and ashore. He also held regional leadership roles with a highly successful startup
company and a marquee international technology consulting firm, including enterprise resource allocation and budgeting
responsibility in both his public and private sector roles. He holds pro bono leadership roles in numerous civic and
educational commissions and nonprofit organizations focused on climate solutions, especially the decarbonization of the
nation’s existing building stock, including: USGBC California, AIA California, the Climate Reality Project, Climate
Action California, and climate and sustainability commissions and task forces at large cities and and school districts. He
holds multiple degrees: BS in Marine Science from the US Coast Guard Academy, and MS in Telecommunications
Systems Management from the US Naval Postgraduate School (which is roughly half telecom engineering and half MBA).
Comments welcome:
Phasing Out Residential Appliance Emissions:
Households and Businesses CAN Afford this Change - Here’s Why
March, 2025
Page 1 of 34
TABLE OF CONTENTS
EXECUTIVE SUMMARY ...................................................................................................................................... 3
FOSSIL FUEL COMBUSTION DRIVES AIR POLLUTION AND CLIMATE CHANGE ........................................ 6
Air Pollution ..................................................................................................................................................... 6
California Air Resources Board 2022 State Implementation Plan Strategy .............................................. 6
South Coast Air Quality Management District Air Quality Management Plan ........................................... 6
Greenhouse Gases ......................................................................................................................................... 7
Intergovernmental Panel on Climate Change (IPCC) ............................................................................... 7
US Fifth National Climate Assessment (NCA5) ........................................................................................ 7
California’s Fourth Climate Change Assessment (CCA4) ......................................................................... 8
Reducing Air Pollution and Greenhouse Gases: #ElectrifyEverything Does Most of the Work ...................... 9
Safest and Cleanest Sources of Energy: Solar, Wind, Hydro, Nuclear, Geothermal ...................................... 9
AFFORDABILITY - MACROECONOMICS: FINANCIAL IMPACTS OF FOSSIL FUEL COMBUSTION .......... 11
Fossil Fuel Subsidies: $1.2 Trillion per Year of Direct Subsidies, and $6T Indirect ...................................... 12
NOAA: Billion Dollar Disasters Show Rapidly Increasing Disasters and Cost Due to Climate Forcing ........ 12
Insurance and and Reinsurance Industry is Pulling Out of HIgh Risk Areas Due to Climate Risk ................ 12
US Federal Reserve Bank: Climate Change Likely to Increase Financial Shocks and Financial System
Vulnerabilities ................................................................................................................................................ 14
CFTC: Climate Change Poses a Major Risk to the Stability of the US Financial System ............................. 14
Social Cost of Carbon: Accounting for Externalities ...................................................................................... 16
Cost of Doing Nothing / Business as Usual / Status Quo .............................................................................. 17
AFFORDABILITY - ENERGY SYSTEM ECONOMICS ...................................................................................... 18
Electricity Generation: History and Recent Trends ....................................................................................... 18
Growth of Zero Carbon Electricity Generation in the 2010s to 2020s ........................................................... 18
#ElectrifyEverything: the Technology Exists Today, and is Less Expensive than the Status Quo ................. 20
AFFORDABILITY - MICROECONOMICS: INDIVIDUAL HOUSEHOLD IMPACTS .......................................... 22
Household Affordability: Space and Water Heating ...................................................................................... 22
HEALTH IMPACTS ............................................................................................................................................. 25
Global Health Impacts ................................................................................................................................... 25
Air Pollution Causes 8M~10M Premature Deaths Per Year .................................................................... 25
California Health Impacts .............................................................................................................................. 26
South Coast Air District Health Impacts ........................................................................................................ 26
OTHER OBJECTIONS ....................................................................................................................................... 28
Modern Heat Pumps Work Well Below Negative 20 Degrees Fahrenheit .................................................... 28
“The Technology Just Isn’t Ready” (It Is) ....................................................................................................... 29
Yes, the Electric Grid Can Handle Electrification of the Economy ................................................................ 30
Grid Outage Risk: Clean Energy is the Most Reliable Energy ................................................................ 31
Resilience: How Households and Communities Deal with Grid Outages ............................................... 31
100 Amp Panels: Over 90% of Electrical Panels Can Handle Full Electrification ......................................... 33
CONCLUSION .................................................................................................................................................... 34
Comments welcome:
Phasing Out Residential Appliance Emissions:
Households and Businesses CAN Afford this Change - Here’s Why
March, 2025
Page 2 of 34
EXECUTIVE SUMMARY
California’s South Coast Air Quality Management District (SCAQMD) is considering two Proposed Amended Rules that
would phase out the deadly emissions of Oxides of Nitrogen (NOx) and dozens of related toxic fumes that are released
into the atmosphere and in many cases into nearly six million Southern California dwelling units. These two rules phase
out furnaces and water heaters that emit these pollutants in the most affordable and equitable manner possible: as existing
appliances reach their end of life, building owners will upgrade to zero-NOx appliances. Primarily, these will be heat
pumps and heat pump water heaters, which are both highly efficient and a mature / on the shelf technology 1 .
These rules are needed because the Los Angeles area still has the highest levels of ozone in the nation, and is one of only
two regions that are in extreme nonattainment of the 2015 US EPA 8-hour ozone standard, 70ppb. The 2022 AQMP
concludes that only way to achieve the required ozone reductions is to reduce NOx through extensive use of zero emission
technologies across all stationary and mobile sources 2 .
These rules are among the most impactful policies for upgrading existing
buildings with pollution-free technologies under consideration in the state, and
perhaps the nation. SCAQMD is among the early adopters, but not the first: New
York State and City, Massachusetts, Washington State, Colorado, Denver, Boston,
the Bay Area Air Quality Management District, and other jurisdictions who care
about their residents’ health and livelihoods have already passed similar
legislation or regulations. As of January 2025, The Building Decarbonization
Coalition’s policy tracker reflects 152 policies adopted by 130 local governments,
5 states, and 2 regional entities that address building specific operational fuel
types and related emissions in the United States. An interactive map provides details 3 .
Numerous legal mandates require CARB and California’s 35 Air Districts to implement rules to reduce smog, air
pollution, and greenhouse gases: the federal Clean Air Act (CAA) 4 , California’s Assembly Bill 32 (AB32) 5 , the California
Air Resources Board (CARB) 2022 State Implementation Plan (SIP) 6 , the US Nationally Determined Contribution to the
Paris Agreement 7 , and more.
7 UNFCCC. “Nationally Determined Contribution (NDC) to the Paris Agreement Synthesis Report.” Accessed January 11, 2025.
https://unfccc.int/process-and-meetings/the-paris-agreement/nationally-determined-contributions-ndcs/ndc-synthesis-report/ndc-synthe
sis-report
6 California Air Resources Board. “CARB 2022 State Implementation Plan Strategy,” 2022.
https://ww2.arb.ca.gov/sites/default/files/2022-08/2022_State_SIP_Strategy.pdf
5 Nunez. “AB32, California Global Warming Solutions Act of 2006: Air Pollution, Greenhouse Gases,” September 27, 2006.
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=200520060AB32
4 US EPA. “US Clean Air Act, 42 U.S.C. §7401.” Overviews and Factsheets, February 22, 2013.
https://www.epa.gov/laws-regulations/summary-clean-air-act
3 Building Decarbonization Coalition. “Zero Emission Building Ordinances.” BDC. Accessed October 3, 2024.
https://buildingdecarb.org/zeb-ordinances .
2 South Coast Air Quality Management District. “South Coast AQMD Air Quality Management Plan 2022,” page ES-1 Accessed
January 11, 2025. https://www.aqmd.gov/home/air-quality/air-quality-management-plans/air-quality-mgt-plan
1 South Coast Air Quality Management District. “SCAQMD Proposed Amended Rules (PAR) 1111 and 1121.” Accessed October 18,
2024. https://www.aqmd.gov/home/air-quality/air-quality-management-plans/air-quality-mgt-plan
Comments welcome:
petemarsh.re@gmail.com
Phasing Out Residential Appliance Emissions:
Households and Businesses CAN Afford this Change - Here’s Why
March, 2025
Page 3 of 34
These rules have co-benefits of eliminating other criteria pollutants and greenhouse gases, all of which create major
positive impact for human health and the economy.
Opposition groups have expressed numerous objections to these draft rules, the most oft-stated being that Southern
California households and businesses “can’t afford to implement the rules” 8 .
Extensive bodies of research conclude the opposite: the status quo or
Business As Usual approach, in which ~80% of total US energy is
derived from fossil fuel combustion, is already causing ruinous
economic damages from air pollution and climate change-amplified
extreme weather events such as the devastating Los Angeles area
wildfires of January 2025. For instance, a September 2020 US
Commodity Futures Trading Commission (CFTC) report concluded
that if the world transitions to a zero carbon energy economy, “ the
cumulative benefit in terms of avoided climate-related and air
pollution damages ranges from $50 trillion to $142 trillion, and
reducing fossil fuel subsidies would generate further savings of
$15 trillion by 2050 .” 9 Additionally, “the transition would result in
$11.8 trillion in stranded assets by 2050, but delaying action would nearly double total stranded assets to $19.5 trillion by
2050.” 10
According to the World Bank, global subsidies to the fossil fuel industry impose over $7 trillion of cost onto the economy,
about 7% of the global 2023 $106T GDP 11 . These include direct price support to consumers and producers and indirect
subsidies from externalities such as the health and environmental costs of air pollution from fossil combustion, climate
damages, and more.
Affordability of compliance for individual households, especially low income, has been a major concern of commenters
concerned about these rules. Two separate analyses specific to the South Coast Air Basin found that zero-emission
equipment actually costs less up-front than gas-fired in some cases. 12
There’s also a large body of peer-reviewed research which finds that fossil fuel combustion causes massive human health
impacts, including 8 to 10 million premature deaths per year. 13 , 14
14 Wallace-Wells, David. “Ten Million a Year.” London Review of Books, December 2, 2021.
https://www.lrb.co.uk/the-paper/v43/n23/david-wallace-wells/ten-million-a-year
13 Harvard T.H. Chan School of Public Health. “Fossil Fuel Air Pollution Responsible for 1 in 5 Deaths Worldwide,” February 9, 2021.
https://www.hsph.harvard.edu/c-change/news/fossil-fuel-air-pollution-responsible-for-1-in-5-deaths-worldwide
12 Laurie Stone, Jed Holtzman, and Rachel Golden, “Heat Pumps Reduce Smog in Southern California. Available Incentives Mean
They Can Also Cost Less Than Gas Equipment.,” RMI, February 21, 2025,
https://rmi.org/heat-pumps-reduce-smog-in-southern-california-available-incentives-mean-they-can-also-cost-less-than-gas-equipment .
11 International Monetary Fund. “Fossil Fuel Subsidies.” IMF. Accessed March 21, 2023.
https://www.imf.org/en/Topics/climate-change/energy-subsidies
10 Ibid
9 Ibid
8 South Coast AQMD. “Comment Letters on SCAQMD Proposed Amended Rules 1111 and 1121.” Accessed January 11, 2025.
https://www.aqmd.gov/home/rules-compliance/rules/scaqmd-rule-book/proposed-rules/rule-1111-and-rule-1121/comment-letters
Comments welcome:
petemarsh.re@gmail.com
Phasing Out Residential Appliance Emissions:
Households and Businesses CAN Afford this Change - Here’s Why
March, 2025
Page 4 of 34
In the SCAQMD region alone, fossil-fired air pollution is responsible for 76,000 asthma attacks, 30,000 days of missed
school, 130 premature deaths, and $2 billion in health impacts 15 .
At the local level, Long Beach city council members and community advocates often point out that some studies have
found life expectancy in West Long Beach to be up to 17 years shorter than a few miles away in East Long Beach. A
major part of causation is fossil combustion along Interstate 710, colloquially known as the “Diesel Death Corridor.”
Numerous other objections are raised by written and verbal comments in this proceeding; while there are certainly
challenges, the cost of taking action on existing buildings is far less than the cost of inaction. This white paper addresses
many of those objections.
The drivers of both air pollution and climate change are primarily combustion of fossil fuels 16 .
The solution to eliminating emissions of both criteria pollutants and greenhouse gases, which has become clear in the last
decade, is strikingly straightforward: numerous studies conclude that we can power well over 80% of the US and global
economies with electric end use devices that are on the shelf right now, while simultaneously shifting energy supply to low
emission sources - primarily solar, wind, hydro, geothermal, and nuclear 17 . We can and must start immediately on this
journey, while conducting research in the handful of “Difficult To Decarbonize” (DTD) sectors: long distance shipping,
long distance aviation, and a few high heat industrial processes.
The existing building stock falls into the DTD category, not because of a lack of technology, but because of the sheer
quantity of existing buildings that must be addressed, one at a time. There are over 120 million dwelling units in the
United States, and about 70 million of them use gas furnaces and 60 million use gas water heaters. These appliances
together contribute a significant fraction of NOx and other criteria pollutants, and roughly 10% of US greenhouse gas
emissions, Until we replace them with non-emitting appliances, we’ll continue to combust fossil fuels, continuing to
impose cost and health impacts on humanity 18 . The sheer number of these appliances, and the relative uniqueness of each
structure and its electrical wiring, makes it a huge challenge to upgrade homes to electric appliances.
Upgrading gas furnaces and water heaters to zero-NOx appliances as they reach end of life, and while we have large
incentives available from the federal government, state, SoCalREN, and SCAQMD, is by far the most affordable and
equitable way to accomplish this.
18 Griffith, Saul. “Electrify: The Book.” Rewiring America, The MIT Press. October 04, 2022.
https://www.rewiringamerica.org/electrify-the-book
17 Hausfather, Zeke, and Erik Olson. “What New Net-Zero Studies Tell Us About Electricity Decarbonization.” The Breakthrough
Institute. Accessed August 21, 2023. https://thebreakthrough.org/issues/energy/new-net-zero-studies-on-electricity-decarbonization .
16 US Global Change Research Program. “Fifth US National Climate Assessment.” Fifth National Climate Assessment. U.S. Global
Change Research Program, Washington, DC, 2023. https://nca2023.globalchange.gov/downloads .
15 Southern California’s Hidden Air Pollution Problem: Gas Furnaces & Water Heaters,” Coalition For Clean Air and Rocky Mountain
Institute, 2024, https://www.ccair.org/wp-content/uploads/2024/12/South-Coast-Brief.pdf
Comments welcome:
petemarsh.re@gmail.com
Phasing Out Residential Appliance Emissions:
Households and Businesses CAN Afford this Change - Here’s Why
March, 2025
Page 5 of 34
FOSSIL FUEL COMBUSTION DRIVES AIR POLLUTION AND CLIMATE CHANGE
A doctor doesn’t prescribe treatment before making a diagnosis. Similarly, we need to state clearly the diagnosis for
earth’s atmosphere before discussing solutions and whether or not they are affordable.
Air Pollution
California Air Resources Board 2022 State Implementation Plan Strategy
This section summarizes the statutory and federal regulatory framework that require these measures, mostly excerpts
quoted from the CARB SIP.
“These measures are needed across the State of California for areas to meet the federal 70 parts per billion (ppb)
8-hour ozone standard (70 ppb ozone standard) set by the U.S. Environmental Protection Agency (U.S. EPA) in
2015….
“California has the only two areas in the nation with an Extreme classification for the 70 ppb ozone standard, the
South Coast Air Basin (South Coast) and the San Joaquin Valley (Valley). While the Proposed 2022 State SIP
Strategy is being developed primarily as a roadmap for attaining the 70 ppb ozone standard, the emissions
reductions will also support attainment of other ozone (e.g. 80 ppb, 75 ppb) and fine particulate (PM2.5) national
ambient air quality standards (NAAQS), make progress towards the State air quality standards, and improve
visibility across the State….
“Residential and commercial buildings in California are the source of about 66 tpd NOx38 statewide due to
natural gas combustion. Nearly 90 percent of building NOx emissions are due to space and water heating and the
remaining 10 percent are due to cooking, clothes drying, and other miscellaneous end uses. At the regional level,
approximately one-third of projected building related emissions in South Coast could be reduced by 2037 if
zero-emission standards were implemented in 2030 for space and water heating….” 19
South Coast Air Quality Management District Air Quality Management Plan
The California Air Resources Board (CARB) 2022 State Implementation Plan Strategy reports that the Los Angeles area
has the highest levels of ozone (smog), which is created from NOx (oxides of nitrogen), in the nation.
The rules discussed in this white paper focus on Oxides of Nitrogen (NOx), because that criteria pollutant is the one for
which the LA basin is in worst non-attainment. But there are a huge number of other co-benefits to eliminating fossil
combustion, including significant reductions in emissions of other criteria pollutants and greenhouse gases.
On October 1, 2015, the U.S. Environmental Protection Agency (EPA) strengthened the National Ambient Air Quality
Standards (NAAQS) for ground-level ozone, lowering the primary and secondary ozone standard levels to 70 parts per
billion (ppb). The South Coast Air Basin is classified as in “extreme” nonattainment. The 2022 AQMP was developed to
19 California Air Resources Board. “CARB 2022 State Implementation Plan Strategy,” 2022.
https://ww2.arb.ca.gov/sites/default/files/2022-08/2022_State_SIP_Strategy.pdf .
Comments welcome:
petemarsh.re@gmail.com
Phasing Out Residential Appliance Emissions:
Households and Businesses CAN Afford this Change - Here’s Why
March, 2025
Page 6 of 34
address the requirements for meeting this standard and was adopted December 2, 2022 by the South Coast AQMD
Governing Board. 20
Greenhouse Gases
While the rules herein specifically address the criteria pollutant NOx, since that is the legal authority of California's Air
Districts, it is valuable to recognize that reducing NOx emissions will have significant co-benefits, particularly in driving
down the greenhouse gas (GHG) emissions that drive global warming and the economic, human health, and ecosystem
damages that it causes.
Intergovernmental Panel on Climate Change (IPCC)
The 2021 Sixth Assessment Report (AR6) of the Intergovernmental Panel on Climate Change (IPCC) opens with the
straightforward conclusion that “[A.1 It is unequivocal that human influence has warmed the atmosphere, ocean and land.
Widespread and rapid changes in the atmosphere, ocean, cryosphere and biosphere have occurred. [A.1.1]: Observed
increases in well-mixed greenhouse gas (GHG) concentrations since around 1750 are unequivocally caused by human
activities.” 21
Dr. Jonathan Foley of Project Drawdown has one of the most
straightforward graphs that summarize the sources of GHGs. They are
produced by six major sectors of the economy, five of which involve
combustion of fossil fuel (coal, oil and gas) for energy: electricity,
industry, transportation, buildings, and other energy emissions are about
75% of emissions. Food & land use contribute the remaining 25%,
primarily deforestation, methane emissions from cattle and rice fields,
and nitrogen fertilizer overuse.
US Fifth National Climate Assessment (NCA5)
The Fifth National Climate Assessment is the US Government’s preeminent report on climate change science, impacts,
risks, and responses. It is a congressionally mandated interagency effort that provides the scientific foundation to support
informed decision-making across the US 22 . This graphic summarizes several critical realities about climate change:
● Climate change is happening right now in all regions of the US
● Without deeper cuts in global net emissions, climate risks to the US will continue to grow.
● How much more the US warms depends on choices made today.
● Action to limit future warming and reduce risks can have near-term benefits and opportunities.
22 US Global Change Research Program. “Fifth US National Climate Assessment.” Fifth National Climate Assessment. U.S. Global
Change Research Program, Washington, DC, 2023. https://nca2023.globalchange.gov/downloads .
21 Masson-Delmotte, Valérie, Sarah L. Connors, et al., eds. “IPCC Assessment Report 6 - Climate Change 2021: Physical Science
Basis.” Sixth Assessment Report of the Intergovernmental Panel on Climate Change, 2021.
https://www.ipcc.ch/report/sixth-assessment-report-working-group-i .
20 South Coast Air Quality Management District. “South Coast AQMD Air Quality Management Plan 2022,” page ES-1 Accessed
January 11, 2025. https://www.aqmd.gov/home/air-quality/air-quality-management-plans/air-quality-mgt-plan .
Comments welcome:
petemarsh.re@gmail.com
Phasing Out Residential Appliance Emissions:
Households and Businesses CAN Afford this Change - Here’s Why
March, 2025
Page 7 of 34
California’s Fourth Climate Change Assessment (CCA4)
California’s Fourth Climate Change Assessment translates the state of climate science into actionable information. It
“presents findings in the context of existing climate science, including strategies to adapt to climate impacts.” From the
abstract:
In the absence of significant global mitigation action and regional adaptation efforts, rising temperatures, sea level
rise, and changes in extreme events are expected to increasingly disrupt and damage critical infrastructure and
property, labor productivity, and the vitality of our communities. Regional economies and industries that depend
on natural resources and favorable climate conditions, such as agriculture, tourism, and fisheries, are vulnerable to
the growing impacts of climate change.
Rising temperatures, extreme heat, drought, wildfire on rangelands, and heavy downpours are expected to
increasingly disrupt agricultural productivity in the United States. Expected increases in challenges to livestock
health, declines in crop yields and quality, and changes in extreme events in the United States and abroad threaten
rural livelihoods, sustainable food security, and price stability
Our Nation’s aging and deteriorating infrastructure is further stressed by increases in heavy precipitation events,
coastal flooding, heat, wildfires, and other extreme events, as well as changes to average precipitation and
temperature. 23
23 “California’s Fourth Climate Change Assessment,” California Natural Resources Agency, California Energy Commission, California
Governor’s Office of Planning and Research. January 16, 2019. https://climateassessment.ca.gov .
Comments welcome:
petemarsh.re@gmail.com
Phasing Out Residential Appliance Emissions:
Households and Businesses CAN Afford this Change - Here’s Why
March, 2025
Page 8 of 34
Reducing Air Pollution and Greenhouse Gases: #ElectrifyEverything Does Most of the Work
Climate journalist David Roberts, author of the newsletter Volts , in 2021 Published an article in which he laid out “a
simple framework to help people think about how to prioritize climate policies.” 24 This quote from the article is a succinct
summary of the key actions necessary to rapidly reduce both greenhouse gases and air pollution, including NOx (emphasis
added):
“While different climate models disagree about which policies and technologies will be needed to clean
up remaining emissions after 2030, virtually all of them agree on what’s needed over the next decade.
It’s clean electrification:
1. clean up the electricity grid by replacing fossil fuel power plants with renewable energy,
batteries, and other zero-carbon resources;
2. clean up transportation by replacing gasoline and diesel vehicles — passenger vehicles,
delivery trucks and vans, semi-trucks, small planes, agricultural and mining equipment, etc. —
with electric vehicles; and
3. clean up buildings by replacing furnaces and other appliances that run on fossil fuels with
electric equivalents.
Or as I summarize it: electrify everything!
Clean electrification is the entrée. If you decarbonize electricity, transportation, and buildings,
you’ve taken out the three biggest sources of emissions in virtually every country. The
technologies and policies we need to do it exist today, ready to deploy .”
This concise summary has become a guiding principle for many organizations and researchers working to reduce air
pollution and greenhouse gases. But until the last decade, it wasn't at all clear that it would be either technically feasible or
affordable to shift the global energy economy - which constitutes over 15% of global GDP - from its current heavy
reliance on coal, oil, and gas to zero air pollution and zero GHG emissions in both energy supply and energy usage. The
last decade has proven, both empirically in actually deployed technologies and studies assessing growth, that it is both
feasible and affordable.
The next several sections summarize trends in the clean energy transition: history of energy sources, financials,
manufacturing, and deployment of zero carbon energy sources. These, coupled with a clear eyed assessment of the high
cost of doing nothing (stranded assets, externalities, and supply and demand), make it clear that not only can we afford the
clean energy transition, we can't afford NOT to do it - and rapidly.
Safest and Cleanest Sources of Energy: Solar, Wind, Hydro, Nuclear, Geothermal
24 Roberts, David. “On Climate Policy, There’s One Main Thing and Then There’s Everything Else,” January 8, 2025.
https://www.volts.wtf/p/on-climate-policy-theres-one-main
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Since this paper discusses the clean energy transition, it’s vital to establish what energy sources are considered clean. The
chart below from Our World in Data summarizes their 2020 report which concludes “Fossil fuels are the dirtiest and most
dangerous energy sources, while nuclear and modern renewable energy sources are vastly safer and cleaner.” 25
The greenhouse gas emissions intensity of eight
energy sources on the right hand side of this
chart make clear:
● Clean energy includes wind, solar, and
nuclear energy , which each emit only 3
to 5 tonnes of CO2 equivalent per
gigawatt hour (GWh) of electricity
generated.
● Gas, oil, and coal , meanwhile, emit 490,
720 and 820 tonnes of CO2e per GWh,
or from 100 to 200 times more
greenhouse gases per unit of electricity
generated. These are the sources we need to rapidly phase out.
● Hydropower is generally considered both clean energy generation and also Long Duration Energy Storage
(LDES), shifting power generation from the west’s rainy winter season to the dry summer season.
● Biomass is complicated, and a small fraction of power generation.
● Enhanced geothermal energy is not shown on the chart, but is a recently emerging very low emissions generating
technology that is not weather-dependent.
25 “What Are the Safest and Cleanest Sources of Energy?,” Our World in Data, February 10, 2020,
https://ourworldindata.org/safest-sources-of-energy
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AFFORDABILITY - MACROECONOMICS: FINANCIAL IMPACTS OF FOSSIL FUEL
COMBUSTION
The objection most often posed to the low emissions energy transition is “We cannot afford to phase out fossil fuels.”
In fact, the opposite is true: we can’t afford NOT to transition away from fossil fuel combustion.
The majority of stated objections center around individual households, and cite high - often exaggerated - costs for
low-NOx space and water heating appliances. This paper will address those. But in order to understand why it’s important
to eliminate emissions from each individual dwelling unit, we must first understand the staggering magnitude of cost
imposed on society as a whole by fossil fuel combustion. Once we establish that context, the value of addressing each and
every end use machine becomes much more clear.
The status quo, in which ~75% of total US energy is derived from
fossil fuel combustion, will cause tremendous economic damage from
air pollution and climate change-amplified extreme weather events
such as the devastating Los Angeles area wildfires of January 2025.
This section summarizes a few of the many sobering analyses about
climate change economic impacts, followed by the good news
regarding low carbon energy generation.
Many of these reports refer to global, national, or regional economies;
the 2023 scale of each was:
● Global GDP: $106.2T 26 , 27
● US GDP: $27.7T 28
● California GDP: $3.2T 29
● Southern California GDP: $1.95T 30
30 St. Louis Fed. “Real Gross Domestic Product by County 2023: California.” Accessed January 12, 2025.
https://fred.stlouisfed.org/release/tables?rid=397&eid=1071149 .
29 Statista. “Real GDP California U.S. 2023.” Statista. Accessed January 12, 2025.
https://www.statista.com/statistics/187834/gdp-of-the-us-federal-state-of-california-since-1997 .
28 ibid
27 Rao, Pallavi. “Visualizing the $105 Trillion World Economy in One Chart.” Visual Capitalist, August 9, 2023.
https://www.visualcapitalist.com/visualizing-the-105-trillion-world-economy-in-one-chart .
26 World Bank. “GDP Ranking by Nation 2023.” Accessed January 12, 2025.
https://datacatalog.worldbank.org/search/dataset/0038130 .
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Fossil Fuel Subsidies: $1.2 Trillion per Year of Direct Subsidies, and $6T Indirect
The International Monetary Fund reports that in 2023, global
fossil fuel subsidies were $7 trillion, or 7% of GDP . 18%
($1.26T) of the 2022 subsidies are explicit support from
governments to fossil fuel producers, primarily undercharging
for supply costs. The remaining 82% are implicit (indirect)
subsidies, primarily underpricing for local air pollution costs and
climate damages (about 30% each). Other implicit subsidies
include broader road transport externalities such as congestion
and road accidents (17%), and forgone consumption tax revenue
(5%) 31 . Essentially, this means that fossil fuel combustion
imposes a seven percent tax on the global economy.
NOAA: Billion Dollar Disasters Show Rapidly Increasing Disasters and Cost Due to Climate
Forcing
The National Oceanic and Atmospheric Administration (NOAA) has
tracked Billion Dollar Disasters since 1980. These are primarily extreme
weather events, which have been made more likely, more frequent, and
more severe by the 2 degree Fahrenheit increase in global average
temperature since pre-industrial times. As of January 2025, the US has
sustained 403 weather and climate disasters since 1980 where overall
damages/costs reached or exceeded $1 billion (CPI adjusted to 2024 US
dollars). The total cost of these 403 events exceeds $2.9 trillion. The
average in the 1980s was 3.3 events per year, costing 299 human lives and $22B CPI adjusted. In the last five years
(2020-2024) 23.0 events per year, costing 504 human lives and $149B CPI adjusted 32 .
Insurance and and Reinsurance Industry is Pulling Out of HIgh Risk Areas Due to Climate Risk
The reinsurance industry is in the business of providing insurance to
insurance companies. Munich Re is one of the largest reinsurers. Their
website lists 12 categories of risk to their global capital assets, and one of
those is climate change and its consequences.
They introduce the topic thus: “For five decades, Munich Re has been
analysing the effects that global warming and natural climate variations
have on weather-related natural disasters. We focus on the risks involved
as well as on loss prevention and new risk transfer concepts. We make
use of long-term meteorological and loss data to understand changes in
32 NOAA. “Billion-Dollar Weather and Climate Disasters, 1980 - 2024.” NOAA National Centers for Environmental Information,
2020. https://doi.org/10.25921/STKW-7W73
31 International Monetary Fund. “Fossil Fuel Subsidies.” IMF. Accessed March 21, 2023.
https://www.imf.org/en/Topics/climate-change/energy-subsidies
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risk and to adjust our risk models accordingly. With this expertise, we can continue to provide our clients with the usual
level of risk capacity. The current scientific consensus is that human greenhouse gas emissions since the industrial
revolution are overwhelmingly responsible for rising temperatures in the atmosphere and oceans. The consequences of
global warming are many and varied.” 33
Munich Re’s 2015 report “Natural catastrophes 2015 - Analyses, assessments, positions,” was headlined “The earth’s
‘hotting up,’ ” and included the graph at left which shows that the costs attributable to extreme weather disasters globally
have been increasing rapidly, in a pattern very similar to NOAA’s billion dollar disasters.
The risk analytics firm First Street Foundation describes itself as
“The Standard for Climate Risk Financial Modeling. We exist to
make the connection between climate change and financial risk at
scale for financial institutions, companies and governments.… Real
estate, the bedrock of the American economy, is worth over 45
trillion dollars. Climate change has started to erode that
foundation.” 34 Data scientists from First Street Foundation and
Columbia University performed housing market research along the
US East and Gulf coasts, and found that increased tidal flooding
caused by sea level rise has eroded $15.8 billion in property values
between 2005 and 2017. 35
They estimate that “39 million homes are covered at prices
artificially lower than their true risk. They predict that as disasters
continue surging, what they call the “growing climate bubble in the
housing market” will pop — leaving millions of homes uninsurable
and destroying their value. The average homeowner who loses an
insurance policy automatically sees a drop of more than 10 percent
in the home’s value.”
Reinsurers are particularly exposed to these hazards because many insurance companies seek primarily to cover
catastrophic risks — major events like hurricanes that are intensifying as the world warms.”
As a result, the reinsurance industry has paid dearly for much of the last decade; underwriting losses drove $115 billion in
global reinsurance losses in 2022. “There’s a tension over a business model that’s retrospective, with a risk that’s
emerging,” said Frank Nutter, president of the Reinsurance Association of America. The financial foundation of insurance,
in other words, is cracking.
35 First Street Foundation. “Rising Seas Erode $15.8 Billion in Home Value from Maine to Mississippi.” Accessed January 17, 2025.
https://assets.firststreet.org/uploads/2019/03/Rising-Seas-Erode-15.8-Billion-in-Home-Value-from-Maine-to-Mississippi.pdf .
34 First Street Foundation. “The Standard for Climate Risk Financial Modeling.” FirstStreet. Accessed February 16, 2023.
https://firststreet.org .
33 Munich Re. “Climate Change and Its Consequences.” Accessed January 15, 2025.
https://www.munichre.com/en/risks/climate-change.html .
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US Federal Reserve Bank: Climate Change Likely to Increase Financial Shocks and Financial
System Vulnerabilities
The Federal Reserve System ("the Fed," the central bank
of the United States), was created by Congress to provide
the nation with a safe, flexible, and stable monetary and
financial system. In its November 2020 Financial Stability
Report, the Fed addressed climate change for the first
time, and the message was stark: “Climate change, which
increases the likelihood of dislocations and disruptions in
the economy, is likely to increase financial shocks and
financial system vulnerabilities…. Acute hazards, such as
storms, floods, droughts, or wildfires, can quickly alter, or
reveal new information about, future economic conditions
or the value of real or financial assets…. One example of
how climate change is likely to increase financial stability risks is through real estate exposures…. As inundations [from
sea level rise] or storm surges become more frequent, the expected value of exposed real estate may decrease, which may
in turn pose risks to real estate loans, mortgage-backed securities, the holders of these loans and securities, and the
profitability of nonfinancial firms using such properties.” 36
CFTC: Climate Change Poses a Major Risk to the Stability of the US Financial System
The mission of the US Commodity Futures Trading Commission (CFTC) is “to promote the integrity, resilience, and
vibrancy of the U.S. derivatives markets through sound regulation.” In September 2020, CFTC issued a sobering report
titled “Managing Climate Risk in the U.S. Financial System.” 37 The report presents 53 recommendations to mitigate risks
to financial markets posed by climate change. The opening paragraph of the Executive Summary states starkly:
“Climate change poses a major risk to the stability of the U.S. financial system and to its ability to sustain the
American economy. Climate change is already impacting or is anticipated to impact nearly every facet of the
economy, including infrastructure, agriculture, residential and commercial property, as well as human health and
labor productivity. Over time, if significant action is not taken to check rising global average temperatures,
climate change impacts could impair the productive capacity of the economy and undermine its ability to generate
employment, income, and opportunity. Even under optimistic emissions-reduction scenarios, the United States,
along with countries around the world, will have to continue to cope with some measure of climate change-related
impacts.”
Chapter 8, “A Closer Look at Financing the Net-Zero Transition,” includes this paragraph which puts the investments and
savings for the status quo versus the path for limiting [global] warming in perspective:
37 Litterman, Bob. “Managing Climate Risk in the U.S. Financial System,” September 9, 2020.
https://www.cftc.gov/sites/default/files/2020-09/9-9-20%20Report%20of%20the%20Subcommittee%20on%20Climate-Related%20M
arket%20Risk%20-%20Managing%20Climate%20Risk%20in%20the%20U.S.%20Financial%20System%20for%20posting.pdf .
36 Federal Reserve Board of Governors. “Near-Term Risks to the U.S. Financial System.” Accessed January 15, 2025.
https://www.federalreserve.gov/publications/2020-november-financial-stability-report-near-term-risks.htm
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“Investment needs are broadly estimated to be in the trillions of dollars. One estimate comes from the
International Renewable Energy Agency (IRENA), which charts an ambitious yet technically and economically
feasible path for limiting warming to “well below” 2 degrees Celsius, in line with the Paris Agreement. IRENA
estimates that $110 trillion of cumulative worldwide investment in the energy sector will be needed leading up to
2050 (IRENA, 2019). That equates to roughly 2 percent of average global gross domestic product (GDP) per year
over the period. Of the $110 trillion, $95 trillion is already required under the reference case scenario of
current plans and policies but would need to be redirected from investments in high-carbon to low-carbon
activities. An additional $15 trillion is necessary to further reduce emissions. This transformation is estimated to
boost total global GDP by 2.5 percent, or 5.3 percent when considering the avoided climate-related damages
relative to the reference case (maintenance of current plans and policies). The transition would result in $11.8
trillion in stranded assets by 2050, but delaying action would nearly double total stranded assets to $19.5
trillion by 2050. However, the cumulative benefit in terms of avoided climate-related and air pollution
damages ranges from $50 trillion to $142 trillion , and reducing fossil fuel subsidies would generate further
savings of $15 trillion by 2050, relative to the reference case.” 38
This figure illustrates the complexity of the risks posed by air pollution and climate change to the global economy.
Additional takeaways from the CFTC report:
● “A world racked by frequent and devastating shocks from climate change cannot sustain the fundamental
conditions supporting our financial system;”
● “U.S. financial regulators must recognize that climate change poses serious emerging risks to the U.S. financial
system, and they should move urgently and decisively to measure, understand, and address these risks.”
38 Ibid
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This report was prepared by a subcommittee of 34 executives and researchers from industry, public interest groups, and
academia. Notably, the subcommittee was appointed by a decision of the five CFTC Commissioners, all five appointed by
President Trump during his first term. 39 Subcommittee Chair Bob Litterman, founding partner and Risk Committee
Chairman of Kepos Capital, said “I was amazed and gratified that the CFTC asked for this report, and I was honored to
chair the subcommittee, but I think what is most unique about this effort is that more than 30 financial market participants
agreed on so much.” 40
Social Cost of Carbon: Accounting for Externalities
The social cost of carbon (SCC) is an economic field of study that quantifies the costs imposed on society from
combustion of fossil fuels beyond the price paid “at the pump,” by the direct consumer. Technically, it’s an estimate of the
present discounted value of the future damage caused by 1 tonne of CO2 emissions 41 . Dr. William Nordhaus won the 2018
Nobel Prize in Economics for his 1980s work on the Social Cost of Carbon, and President Obama’s Executive Order (EO)
12866 in 2010 established an Interagency Working Group on the Social Cost of Greenhouse Gases (IWG), which
developed a methodology for estimating the SCC 42 .
The costs considered in the IWG’s current SCC methodology are the financial impacts of climate change, including
changes in agricultural productivity, property damage from increased flooding, increased extreme weather events,
increased wildfires, reduced labor productivity, and declines in human health from hotter ecosystems 43 . The IWG
methodology does not currently include several other factors, although a 2017 report by the National Academies of
Science, Engineering, and Medicine (NASEM) to the IWG contains recommendations for considering them. These
include global factors such as forced migration and economic and political destabilization; global biodiversity and species
extinction; and health damages from air pollution, ozone pollution, and wildfire smoke 44 .
The IWG SCC was calculated at $42 during the Obama administration, then reduced to $3 at the beginning of the Trump
administration. In 2021, EO 13990 restored it to $51 ($42 plus inflation), and also ordered a review; that review, delivered
in September 2022, implements many of the NASEM suggestions and concludes that SCC is $190/MT 45 .
Federal agencies are required to use SCC to evaluate proposed regulations. California and 11 other states have adopted the
federal SCC, and also use it in policy analysis 46 . Globally, about 70 nations or sub-nations covering 23% of global
emissions place an actual price on carbon, in the form of either a Cap-and-Trade system like California’s or a carbon tax 47 .
47 “Which countries have put a price on carbon?,” Our World in Data. https://ourworldindata.org/carbon-pricing
46 “States Using the SCC.” https://costofcarbon.org/states
45 US EPA, “EPA External Review Draft of ‘Report on the Social Cost of Greenhouse Gases: Estimates Incorporating Recent Scientific
Advances,’” Sep. 22, 2022. https://www.epa.gov/environmental-economics/scghg
44 Ibid.
43 Ibid.
42 US Interagency Working Group on Social Cost of Greenhouse Gases, “Technical Support Document: Social Cost of Carbon,
Methane, and Nitrous Oxide,” Feb. 2021.
https://www.whitehouse.gov/wp-content/uploads/2021/02/TechnicalSupportDocument_SocialCostofCarbonMethaneNitrousOxide.pdf
41 K. Rennert and C. Kingdon, “Social Cost of Carbon 101,” Resources for the Future, Feb. 03, 2022.
https://www.rff.org/publications/explainers/social-cost-carbon-101 (accessed Apr. 11, 2023).
40 “CFTC’s Climate-Related Market Risk Subcommittee Releases Report.” Accessed January 11, 2025.
https://www.cftc.gov/PressRoom/PressReleases/8234-20 .
39 CFTC. “Former Commissioners of the US Commodity Futures Trading Commission.” Accessed January 18, 2025.
https://www.cftc.gov/About/Commissioners/FormerCommissioners/index.htm .
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California AB-766, “Climate change: corporate disclosures” (Gabriel, Bennett, 2021-2022) did not pass, but would have
required “covered corporations” to begin to account for the cost of emissions 48 .
State Lands Commission Order # W 17166 of 12 April 2023 was clear: “incorporate risk identification and analysis to
provide the transparency necessary to evaluate the efficacy of current and future operations, ” with SCC #9 of 11 areas
of consideration. For decades, ER has not quantified the damages caused by extraction, focusing only on the dollars
flowing into city coffers. SCC gives City Council a tool to understand the magnitude of the health and budget impacts.
Cost of Doing Nothing / Business as Usual / Status Quo
The numerous reports described in this section emphasize a critical thread, too often ignored or downplayed, that runs
through every discussion of air pollution and climate change: the cost of doing nothing .
When an enterprise or its board consultants analyze alternatives, a fundamental principle is that in addition to whatever
options are evaluated, the analysis must assess feasibility and cost of maintaining the status quo.
The reports just summarized make clear that the global, national, and regional economies cannot afford to continue with
the status quo, which involves powering over 80% of the US economy with coal, oil, and gas. In fact, if the US delays its
transition to a low emissions energy economy, it will give away global leadership in the energy economy of the 21st
century. China is already racing far ahead; every policy proposal that gives the US opportunities to more rapidly build our
clean energy economy positions this nation better to compete.
48 AB-766 (proposed, not passed) Climate change: corporate disclosures. (Gabriel, Bennett, 2021-2022.
https://leginfo.legislature.ca.gov/faces/billStatusClient.xhtml?bill_id=202120220AB766
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AFFORDABILITY - ENERGY SYSTEM ECONOMICS
Electricity Generation: History and Recent Trends
Before looking to the future of the US energy system, it’s useful to review the past. In 2016, the US Energy Information
Administration published this 80+ year look-back at utility-scale electric generating capacity by initial operating year,
1930-2016. 49
This chart doesn’t show total electrical energy
generation each year; it shows how much
generating capacity was added each year, and
from which sources. This is important context
as we consider how the grid might further
change in the future. The historical view of
how the electric grid has evolved over nearly a
century reveals several takeaways:
● The grid is not constant - as the saying
goes, the only constant is change.
● The electric grid added enough
capacity to double in the 1950s, and
doubled again in the 1960s. By comparison, the expansion by 2X to 3X over the next three decades that will be
discussed in a subsequent section looks almost modest. It’s not: there’s plenty of complexity. But the grid has
achieved significant growth in the past, and if we trust American engineering, ingenuity, and innovation, we
should be able to do so in the future.
● The chart shows the dominance of coal from the 1950’s into the 1980’s, when the saying “Coal is King” was
prominent.
● The fracking boom of the 2000’s brought that to an end, and for a half decade the US built the most generating
capacity ever, with about 180GW added from 2002 to 2006. One common objection to transforming the grid by
building a lot of renewable energy is “it can’t be done.” The incredible expansion of gas plants in the 2000's shows
that isn’t true: in a little over a decade, the US grid transformed from being dominated by coal to being dominated
by gas, whose emissions intensity for onsite combustion is just half that of coal.
● The US built most of its approximately 100 nuclear power plants in the 1970’s and 1980’s; all but a few remain
online today, and are receiving service life extensions from public service commissions around the country, since
they provide almost 100 GW of clean electricity generation at capacity factors over 90%.
● In the mid-2000’s wind began to grow, and in the mid-2010’s solar followed suit. This EIA chart only extends
through 2016, so it doesn’t show a lot of renewable generation, but a subsequent section focused on the most
recent decade will show the next phase of the transformation in the electrical grid.
Growth of Zero Carbon Electricity Generation in the 2010s to 2020s
49 US Energy Information Administration (EIA). “U.S. Utility-Scale Electric Generating Capacity by Initial Operating Year,
1930-2016.” February 27, 2017. https://www.eia.gov/todayinenergy/detail.php?id=30112 .
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The previous section described US electricity generating sources over nearly a century. This section zooms in to the most
recent timeframe. This chart from the US Energy Information Administration shows a dramatic shift over the last two and
a half decades: gas plans dominated from 2000 to 2007, when wind began to comprise a significant portion of annual
capacity additions; by 2015 wind and solar combined were over half of new capacity and have been every year since
except 2018. By 2023, wind and solar and batteries were over 82% of new capacity, and in 2024 - not shown on this chart
- they comprised 94% of new capacity. 50
What has caused the rapid deployment of
clean energy generation? The same things
that have powered each industry
transformation in our economy (steam
engine, the internal combustion engine,
20th century labor-saving household
appliances, and the computing and internet
revolutions): innovation, R&D,
manufacturing, demand, supply, increasing
scale, judicious government incentives in
many cases, and declining prices.
The following chart and summary from the annual energy transition presentation by the independent nonpartisan
nonprofit, RMI, describes the pace and scale of the clean energy transition. 51 “The energy system is being disrupted by the
exponential forces of renewables, electrification, and efficiency.”
“In economic parlance, we say
knowledge exhibits increasing returns:
the more we discover, the more we
realize there is to find out. Commodities,
on the contrary, exhibit decreasing
returns: the more oil we dig, the more
onerous our efforts need to become.
These decreasing returns from oil or
coal are offset by improvements in the
technologies that extract them. The net
effect, however, is no structural decline
in cost. Oil prices today, in real terms,
are roughly the same as they were 140 years ago, and coal electricity prices are the same as they were
100 years ago.
Solar and battery prices, on the other hand, fall by about 20 percent for every doubling of
deployment. And deployment has been doubling every two to three years. As a result, prices
51 Kingsmill Bond, Sam Butler-Sloss, and Daan Walter, “The Cleantech Revolution - It’s Exponential, Disruptive, and Now,” RMI,
June 2024, https://rmi.org/insight/the-cleantech-revolution
50 Elesia Fasching and US Energy Information Administration (EIA), “Wind, Solar, and Batteries Increasingly Account for More New
U.S. Power Capacity Additions,” Today in Energy, March 6, 2023, https://www.eia.gov/todayinenergy/detail.php?id=55719 .
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have plummeted. Solar prices are down 99.9 percent since the 1950s. Batteries prices are down
97 percent since the 1990s .
The more solar panels and batteries we make, the more we learn how to make them, and the cheaper
they get… and the more we can afford and thus the more we demand.
Developing an energy source that gets cheaper the more we make of it is a milestone for humanity. The
positive repercussions of which will be a defining thread of our era.
The energy transition can be seen as a shift from commodities to technologies; from digging to
manufacturing; and from hunting to harvesting. It is a story of brains beating brawn.”
Humanity is still relatively early in the clean energy transition, as can be seen in the previous EIA chart of US generating
capacity from 1930-2016. But the structural economic, manufacturing, and deployment of renewable energy revealed in
the RMI report makes clear that change is coming, and rapidly.
#ElectrifyEverything: the Technology Exists Today, and is Less Expensive than the Status Quo
Previous sections showed the large scale and rapid pace of clean energy deployment in recent years. Building on that
success, and looking 20 to 30 years into the future, numerous studies in the late 2010s and early 2020s evaluated national
and global energy use across all sources and uses. Three respected peer-reviewed net zero studies were summarized by Dr.
Zeke Hausfather in a 2021 meta-study. 52 All three concluded that the US economy can reach net zero emissions by 2050:
“A slew of new net-zero studies have been published in recent months, including Princeton's Net Zero
America (NZA) project, the Vibrant Clean Energy Zero By Fifty scenario, and by a team of researchers
led by Jim Williams at USF. All three of these take a deep-dive into how the US could reach
net-zero emissions by 2050 , down to the level of where each new generating facility might be located,
where new transmission lines would be built, and how electricity generation sources can meet hourly
grid demand in different regions of the country. Each study contains multiple scenarios looking at the
sensitivity to future technology prices, land use constraints, and other factors.
While the models differ in important ways, they all paint a broadly similar picture. Wind and solar
expand rapidly in the next three decades. US coal use falls off a cliff, reaching zero by 2030 or 2035. At
the same time, natural gas use stays rather flat — or even increases modestly — between 2020 and
2030, as it serves a key role in filling in the gaps in variable renewable generation. Gas capacity
actually increases in two of the three decarbonization models through 2050, though capacity factors —
how often the gas plants are run — fall rapidly, and gas increasingly becomes a blend of hydrogen and
methane closer to 2050.”
Hausfather created this graph to summarize the 2020 US electricity generation mix, as well as the three studies’ projected
generation mix in 2030, 2040, and 2050. The top level takeaway is that each study concludes
52 Zeke Hausfather and Erik Olson, “What New Net-Zero Studies Tell Us About Electricity Decarbonization,” The Breakthrough
Institute, February 22, 2021, https://thebreakthrough.org/issues/energy/new-net-zero-studies-on-electricity-decarbonization .
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Takeaways:
● Future electricity demand: 2050 generation in the three models ranges from about twice the 4,000 Terawatt hour
level of 2020 to three times that. These variations are driven by differing projections of economy-wide
electrification rates, and the degree to which other sectors of the economy can be effectively electrified and their
pace of change.
● All three models find that wind and solar - variable renewable energy , or VRE - deliver between 51% and 91% of
total electricity generation by 2050. The remainder is a mix of clean firm generation (hydro, nuclear, and
geothermal) with large expansions of transmission capacity, demand management, battery storage, and other
dispatchable energy storage.
● One model forecasts a large expansion of nuclear energy, while the other two project a bigger role for offshore
wind.
Dr. Hausfather concludes his meta study with this summary:
“The future electricity mix is difficult to foresee perfectly, and history is a graveyard of failed energy
model predictions. All models are wrong, as the saying goes, but some are useful. These deep
decarbonization models give us a sense of what may be needed. We should not fixate too much on the
specific generation mixes in any particular scenario, but we should take heed of where the models
agree: on the importance of near-term renewables deployment, the medium-term role of gas capacity to
fill in the gaps, and the importance of clean firm generation and complementary technologies to wean
the power system off its dependence on natural gas in the longer term.”
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AFFORDABILITY - MICROECONOMICS: INDIVIDUAL HOUSEHOLD IMPACTS
The South Coast Air District is home to about 17.5 million people, about 44% of California’s population, and 5% of the
US population. 53 This scale presents challenges for reducing NOx and other pollutants. It also means that actions taken
here will have impact around the nation and the world.
● The region has about 5.9 million housing units, or 43% of California’s 13.7 million total; these include roughly 5
million gas furnaces and 5 million gas water heaters.
● Approximately 48% of residential buildings are occupied by renters.
● In 2018, residential combustion emitted 19.1 tons of NOx per day, 32% of the total emissions from stationary
sources.
Household Affordability: Space and Water Heating
The existing building stock is a challenging sector in which to reduce NOx, other air pollutants, and greenhouse gases: in
addition to the South Coast air district housing stock described above, nationwide there are over 120M households, with
~70M gas furnaces and ~60M gas water heaters. 54 Each of those are unique installations, which means that installers can
rarely achieve economies of scale which would reduce costs. When a building owner switches an appliance from gas to
electric power, there can be additional Capital Expenses (CAPEX) beyond what a like-for-like replacement with a gas
appliance would cost. These fall into three categories: Appliance Cost, Electrical Circuit Cost, and Electrical Panel
Upgrades, which are discussed in detail below.
The nonpartisan think tank RMI published a blog post in February 2025 that compares the cost of retrofitting an air-source
heat pump to replace a combined furnace and air conditioner. Their analysis found that zero-emission equipment can
deliver more than $10,000 in up-front cost savings in some cases. Even without federal home energy rebate funding,
low-income households can save between $2,400 and $4,200 when choosing an air-source heat pump over a traditional
furnace and AC system. And low-income households switching to heat pump water heaters from traditional gas units can
save from $2,125 to $2,925. 55
In addition to the RMI analysis, this white paper analyzed actual installation data from the TECH Clean California
program, a statewide initiative to accelerate the adoption of clean space and water heating technology across California
homes in order to help California meet its goal of being carbon-neutral by 2045. In the four counties of the AQMD region,
empirical cost data from 15,552 actual appliance replacements showed that on average, retrofitting heat pumps in place of
a gas furnace with accompanying air conditioner resulted in lower CAPEX than replacing with like-for-like. The retrofits
presented in this data set were performed by licensed California contractors in the TECH Clean California program. 56
56 TECH Clean CA, “TECH Clean California Data Repository: Project Locations, Costs, and Incentives,” data extracted February 7th,
2025, https://techcleanca.com/heat-pump-data/heat-pump-data-visuals
55 Laurie Stone, Jed Holtzman, and Rachel Golden, “Heat Pumps Reduce Smog in Southern California. Available Incentives Mean
They Can Also Cost Less Than Gas Equipment.,” RMI, February 21, 2025,
https://rmi.org/heat-pumps-reduce-smog-in-southern-california-available-incentives-mean-they-can-also-cost-less-than-gas-equipment .
54 Saul Griffith, “Electrify: The Book,” Rewiring America, accessed January 16, 2024,
https://www.rewiringamerica.org/electrify-the-book
53 SCAQMD, “Proposed Amended Rule 1111 and PAR 1121 Working Group Meeting (WGM) #1,” October 5, 2023,
https://www.aqmd.gov/home/news-events/calendar_v2?month=10&day=5&year=2023&id=f892dbef-c2b6-6f27-bf6f-ff00004a91a9
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Appliance Retrofit Cost Summary Table :
4-County
Total / Average
San Bernardino
County
Riverside
County
Orange
County
Los Angeles
County
HPWH installations 2,357 355 811 224 967
HP HVAC installations 13,165 1,507 5,067 2,422 4,169
Average HPWH project cost per residence $6,096 $5,343 $7,270 $5,583 $6,187
Average HPWH incentive per residence $4,841 $4,130 $6,542 $3,902 $4,789
Average HPWH out of pocket cost per residence $1,255 $1,213 $728 $1,681 $1,398
Average HPWH percent savings per residence 79% 77% 90% 70% 77%
Average Gas WH project cost per residence $3,000
Average HPWH out of pocket cost vs higher (lower)
than like-for-like per residence
($1,745)
Average Heat Pump project cost per residence $18,373 $15,996 $17,687 $19,336 $20,472
Average Heat Pump total incentive per residence $1,929 $2,021 $2,086 $1,784 $1,825
Average Heat Pump out of pocket cost per residence $16,444 $13,975 $15,601 $17,552 $18,647
Average Heat Pump percent savings per residence 10% 13% 12% 9% 9%
Average Gas Furnace plus AC project cost per
residence
$18,800
Average Heat Pump out of pocket cost vs higher
(lower) than gas furnace plus ac per residence
($2,356)
Average Gas Furnace project cost per residence $10,000
Average Heat Pump out of pocket cost vs higher
(lower) than like-for-like per residence
$6,444
Each project involved installing either a heat pump water heater or heat pump space conditioning system. This summary
table also compares the costs of fuel-switching retrofits to the costs of like-for-like retrofits, as presented in SCAQMD’s
Working Group Meeting #2 57 ; these costs were taken from a 2019 study by the energy consulting firm E3. 58
So while it is absolutely appropriate to carefully examine household budget impacts, empirical data shows that on average,
retrofitting with zero-NOx appliances is affordable. Here are further details on the three components of retrofit costs:
● Appliance cost (CAPEX) : A heat pump is usually more expensive than a gas furnace, and usually less expensive
than a furnace plus accompanying air conditioner. Heat pump water heaters (HPWH) are more expensive than gas
or electric resistance water heaters. The Summary Table above shows that of the 15,000 retrofits performed:
○ Heat pump water heater retrofits in the project set were almost $3,100 greater than like-for-like gas, but
the average $4,841 incentives made the replacement about $1,800 less expensive than like-for-like.
58 Charles Li et al., “Residential Building Electrification in California,” April 15, 2019,
https://www.ethree.com/e3-quantifies-the-consumer-and-emissions-impacts-of-electrifying-california-homes
57 SCAQMD, “Proposed Amended Rule 1111 and PAR 1121 Working Group Meeting (WGM) #2,” November 28, 2023,
https://www.aqmd.gov/home/news-events/calendar_v2?month=11&day=28&year=2023&id=4601deef-c2b6-6f27-bf6f-ff00004a91a9
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○ When a heat pump retrofit replaces both a gas furnace and an air conditioner, the average price is a few
hundred dollars less than replacing with a gas furnace and air conditioner. And with the average $1,929
incentives, savings increased to an average $2,356. Since 87% of SCAQMD region homes already have
AC, this metric applies to the vast majority of households .
○ When a heat pump retrofit replaces a gas furnace but not air conditioning, the cost is about $6,400 more
than replacing with a like-for-like gas furnace, even with incentives. This condition is found in only about
13% of SCAQMD region households; and it means that the household now has AC, which they didn't
have before.
● Electrical Circuit Cost : To switch these appliances from gas to electric, some homes will need an upgraded
electrical circuit: larger wire gauge, and in rare cases a four wire circuit instead of a three wire circuit. But the
majority of 240 volt heat pumps and heat pump water heaters can use the same two current carrying conductors
and ground conductor that were in place for the gas furnace or water heater being replaced. If an upsized circuit is
needed, that can cost a few hundred to a few thousand dollars.
● Main Panel Upgrades : As recently as 2022, Rewiring America and other groups estimated that as many as about
50% of homes switching from gas to electric would need to upgrade their main electrical panel, and estimated the
cost at $2K~$4K each. But in 2023, New Buildings Institute and Redwood Energy collected empirical data from
over 70,000 households in California's PG&E utility territory, and over 20,000 in PG&E territory. Over the course
of a full year, only 2% of households ever exceeded 88 amps. And the average peak load in all-electric homes was
just 32 amps. 59 This means that most houses with 100 amp panels should be able to electrify without
upgrading, and even add EV charging . (Some will need to add a subpanel, or upgrade the main panel, if they
have no more physical circuit breaker spaces available; and others will choose to replace old panels that appear to
be safety concerns. Nationwide, the US electrical code was upgraded in 1962 to require 100 amp panels, and since
the early 1990s most California homes have been built with 200 amp panels. By using efficient appliances, circuit
sharing devices, and other efficient design techniques, Redwood Energy shows how to operate a 3,000 square foot
home all-electric. 60
This section has focused on the existing built environment. For new construction, building all-electric is less expensive
than dual-fuel homes with both gas and electric. New Buildings Institute found that “The all-electric single-family home is
$7,500-$8,200 cheaper to construct than the baseline code home.” The reason: an all-electric house doesn't have to have a
trench dug to the gas distribution pipe in the street; doesn't have to have the lateral (pipe from street to meter) installed;
doesn't need a gas meter; doesn't need any gas piping inside the house; and doesn't need any venting for combustion
exhaust. 61 Similar studies have found that for multifamily residential, the construction cost savings are about $3,500 per
dwelling unit.
61 Sean Denniston et al, “Cost Study of the Building Decarbonization Code - New Buildings Institute,” April 2022,
https://newbuildings.org/resource/cost-study-of-the-building-decarbonization-code
60 Sean Armstrong, “How to Electrify A Residence Without A Panel Upgrade,” Lawrence Berkeley Laboratory, December 2021,
https://homes.lbl.gov/sites/default/files/2021-12/How%20to%20Electrify%20A%20Residence%20Without%20Panel%20Upgrades.pd
f
59 Amruta Khanolkar, Sean Armstrong, and Tom Kabat, “We Can Power the Homes of the Future with Electric Panels of the Past,”
New Buildings Institute, July 25, 2023,
https://newbuildings.org/we-can-power-the-homes-of-the-future-with-electric-panels-of-the-past
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HEALTH IMPACTS
Global Health Impacts
Air Pollution Causes 8M~10M Premature Deaths Per Year
Our World in Data performed a detailed review of several studies that estimate the global death toll from air pollution.
They found that “ the two most widely-cited estimates attribute around 7 million deaths per year to air pollution . But
the published estimates span a wide range. More recent studies tend to find a higher death toll than earlier studies. This is
not because air pollution – at a global level – is worsening, but because the more recent scientific evidence suggests that
the health impacts of exposure to pollution is larger than previously thought…. Exposure to air pollutants increases our
risk of developing a range of diseases, in three major categories: cardiovascular diseases, respiratory diseases, and
cancers.” 62
It makes sense to think of these estimates as ‘avoidable deaths’ – they are the number of deaths that would be avoided if
air pollution was reduced to levels that would not increase the risk of developing these lethal diseases.
Death is, of course, not the only negative consequence of air pollution. Many millions more suffer from poor health as a
result.
62 Roser, Max. “Our World in Data: How Many People Die Each Year from Air Pollution?” Our World in Data. Accessed March 21,
2023. https://ourworldindata.org/data-review-air-pollution-deaths .
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California Health Impacts
A recent detailed analysis suggests that adoption of low-carbon energy in California to reduce GHG emissions 80 percent
below 1990 levels would lead to a 55 percent reduction in air pollution mortality rates relative to 2010 levels 63 These
public health improvements have a value of $11-20 billion/year in California. The majority of these public health savings
are associated with reductions in PM concentrations, which is the primary air quality challenge in California.
A 2018 report for the California Energy
Commission quantified the health benefits
of deep air pollution and GHG emission
reductions in California in financial terms.
The analysis examined the co-benefits of
reducing greenhouse gases and air
pollutants that accrue when fossil fuel
combustion declines. It concluded that
“Using recent evidence on links between
pollution mitigation and public health, the
model was able to estimate long-term
economic benefits from averted deaths and
medical care attributable to California
climate policy. The team estimated the economic value of these health benefits is comparable to the direct costs of the
entire energy system buildout. Thus, the state’s climate initiative, still controversial for some, could be justified solely on
public health grounds.” 64
South Coast Air District Health Impacts
Despite progress over the last three decades to reduce ozone pollution in the South Coast AQMD, progress has leveled off
recently. We still violate federal health-based ozone standards more than 100 days a year. The 2022 Air Quality
Management Plan (AQMP), the blueprint for cleaning the air in the region, noted that the prior strategy of incrementally
cleaner combustion was not sufficient to make it safe to breathe. In fact, the 2022 AQMP stated clearly that “the only way
to achieve the required NOx reductions is through extensive use of zero-emission technologies across all stationary and
mobile sources.” In particular, the AQMP noted we need to go to zero-emissions everywhere feasible. Upgrading homes
with zero-emission technologies like heat pumps for space and water heating is not only feasible but will deliver enormous
co-benefits like expanding access to cooling in homes.
A recent analysis from the Coalition for Clean Air and RMI noted that “methane gas-burning equipment in residential and
commercial buildings in the South Coast Air Basin is responsible for:
64 California Energy Commission. “Exploring Economic Impacts in Long-Term California Energy Scenarios.” California Energy
Commission, current-date.
https://www.energy.ca.gov/publications/2018/exploring-economic-impacts-long-term-california-energy-scenarios .
63 Zapata, Christina B., Chris Yang, Sonia Yeh, Joan Ogden, and Michael J. Kleeman. “Low-Carbon Energy Generates Public Health
Savings in California.” Atmospheric Chemistry and Physics 18, no. 7 (April 10, 2018): 4817–30.
https://doi.org/10.5194/acp-18-4817-2018 .
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● Approximately 76,000 asthma attacks per year.
● About 30,000 lost school days annually.
● 130 premature deaths each year.
● Annual health impacts valued at $2 billion 65
These vital rules are the largest emission reduction effort in more than three decades. Upgrading homes with
zero-emission technologies for space and water heating when appliances need replacement will dramatically cut pollution
in the region and help bring the region’s air into compliance with state and federal standards.
65 Southern California’s Hidden Air Pollution Problem: Gas Furnaces & Water Heaters,” Coalition For Clean Air and Rocky Mountain
Institute, 2024, https://www.ccair.org/wp-content/uploads/2024/12/South-Coast-Brief.pdf
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OTHER OBJECTIONS
Numerous other objections to the actions necessary to phase out fossil fuel emissions are have been raised in written and
verbal comments. These commenters may not be aware of the current state of heat pump, grid, and other technologies that
make the transition to zero carbon space and water heating not just feasible, but lower lifecycle cost in the vast majority of
cases. This section addresses several common objections:
Modern Heat Pumps Work Well Below Negative 20 Degrees Fahrenheit
Several commenters have argued that heat pumps don't work in cold climates. A couple of decades ago, it was true that
heat pumps only worked above about positive 20 or 30 degrees Fahrenheit. Several advancements in the last decade have
combined to allow heat pumps to operate down to 20 or more degrees F below zero.
● Variable capacity compressors and fans
● Variable Refrigerant Flow (VRF)
● Inverter drive 66
● Computer control
● Vapor injection and liquid injection 67
● Advanced Refrigerants
● Using waste heat to prevent icing below freezing. 68
The Consumer Reports article cited above includes this very balanced quote: “Of course, you’ll also find people who say
that after spending tens of thousands of dollars on the installation, they’re left with a chilly home and sky-high utility bills.
But that’s more likely to happen only if you end up with a contractor unfamiliar with heat pumps. Chances are, if you pick
the right equipment for your home and your climate, make any recommended weather-sealing upgrades, and hire a
reputable contractor with experience installing heat pumps, you should have a good outcome.”
The next generation of cold climate heat pump advancements is underway in the Department of Energy’s Cold Climate
Heat Pump Challenge, in which eight manufacturers are involved: Bosch, Carrier, Daikin, Johnson Controls, Lennox,
Midea, Rheem, and Trane Technologies. 69
How can heat pumps work at temperatures so low? Because physics tells us that any matter contains heat energy whenever
its temperature is above absolute zero , which is ‐273 °C or -459 °F. An easier way to think about it is to use the Kelvin
scale, which reads zero at absolute zero, instead of Celsius, which physicists set for easy reference to water, which freezes
at 0 °C (273 °K) and boils at 100 °C (373 °K). 70
70 Wikipedia, “Absolute Zero,” in Wikipedia, accessed February 24, 2025,
https://en.wikipedia.org/w/index.php?title=Absolute_zero&oldid=1277312264 .
69 US DoE, “Residential Cold Climate Heat Pump Challenge,” US Department of Energy, October 2021,
https://www.energy.gov/eere/buildings/residential-cold-climate-heat-pump-challenge .
68 Chris Baraniuk, “Meet the Heat Pump: An Old Technology That’s the Future of Home…,” Canary Media, February 28, 2023,
https://www.canarymedia.com/articles/heat-pumps/meet-the-heat-pump-an-old-technology-thats-the-future-of-home-heating .
67 Jon Reed, “Bring Home the Latest Cold Climate Heat Pumps - CNET,” CNET, January 23, 2025,
https://www.cnet.com/home/energy-and-utilities/bring-home-the-latest-cold-climate-heat-pumps/ .
66 Liam McCabe, “Can Heat Pumps Actually Work in Cold Climates?,” Consumer Reports, April 9, 2024,
https://www.consumerreports.org/heat-pumps/can-heat-pumps-actually-work-in-cold-climates-a4929629430/ .
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The improvement in heat pump performance is not just theoretical: the chart below shows very high penetration in nations
with the highest incidence of heating degree days: Norway, Sweden, Finland, and Estonia. 71 And in the United States,
Maine is a recognized leader in heat pump deployment.
Another practical approach to cold climates is to use a backup source of heat. Sometimes called dual fuel, hybrid, or
supplemental, these systems use heat pumps until the temperature drops below its capability; at that time, a backup source
of heat comes online. These systems are often only needed for the coldest few nights per year. The backup source can be
one of many choices:
● Electric resistance, whether integrated into the central system or as simple as a plug in space heater.
● A previously existing furnace or boiler, which are sometimes left in place as the backup.
● Wood burning stove, which already exist in many cold climate residences.
“The Technology Just Isn’t Ready” (It Is)
Many of the public comments consisted of assertions that “the technology just isn’t ready yet” (meaning heat pumps and
heat pump water heaters). Most of these comments were based on either outdated information, misperceptions, or simply
disingenuous.
The previous section addressed the fact that cold climate heat pumps are in fact able to fully capable of delivering
comfortable dwellings.
71 Jan Rosenow et al., “Heating up the Global Heat Pump Market,” Nature Energy 7, no. 10 (September 7, 2022): 901–4,
https://doi.org/10.1038/s41560-022-01104-8 .
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Other commenters stated that heat pumps can’t handle larger buildings. Yet, Trane, Daikin, and more offer heat pumps up
to 2,000 kilowatts (6.8MBtu/hr input). 72 , 73 . One of Daikin’s highlighted projects is a building the size of over 23 football
pitches (~football fields). 74
Heat pump water heating is also readily available for commercial and multifamily buildings. The Advanced Water Heating
Initiative (AWHI) has held several annual conferences highlighting the availability and capabilities of these systems. 75
Yes, the Electric Grid Can Handle Electrification of the Economy
Some commenters suggested that electrifying our buildings could have negative impacts on the electric grid, or that the
grid can’t handle full electrification. Most of these assert that electric loads are increasing, but do not acknowledge that
grid capacity is also rapidly expanding.
Southern California Edison submitted a letter to SCAQMD on October 16th, 2024 stating clearly that they are indeed
expanding their grid, and that it will be able to handle electrification.
“SCE is proactively transforming the electric grid to accommodate significant advancements in
decarbonized generation, the widespread adoption of customer-owned distributed energy resources,
and the increasing use of electric vehicles and zero-emission appliances like heat pumps. As outlined
in Edison’s whitepapers “Countdown to 2045” and, most recently, “Reaching Net Zero,” electrification is
the most cost-effective path to decarbonize California’s economy and we are proactively working to
plan for grid infrastructure needs. the necessary grid planning efforts required.” 76
They also point out the value of using demand response to shift demand away from peaks, such as configuring a heat
pump water heater to heat to water at lowest demand times of day, which in most Time Of Use tariff schedules are also the
lowest price per kilowatt hour.
Grid capacity and resilience are important considerations. The good news is that the nation’s 3,000 electric utilities are
hard at work on grid expansion, and there are many excellent companies, nonprofits, and academics working on these
exact issues. As discussed in a previous section, numerous studies over the last half decade have concluded that it is not
only technically feasible to electrify 80 to 90% of the US economy, but also that high electrification is the most cost
effective approach. These studies analyze the dual demands: converting all current fossil fired equipment to electric, and
economic growth in all sectors. They conclude that the US national electric grid must expand from today's generation of
approximately 4,000 terawatt hours per year to between 10,000 and 12,000 terawatt hours per year in nearly three decades.
For comparison, the United States doubled our grid capacity in the 1950s, and doubled it again in the 1960s. So the task
before us, a 2x-3x expansion in about three decades, is arguably more modest.
76 Rosalie Barcinas, “Public Workshop for Proposed Amended Rules 1111 and 1121,” Southern California Edison, October 16th 2024,
https://www.aqmd.gov/docs/default-source/rule-book/Proposed-Rules/1111-and-1121/comment-letter-from-socal-edison-20241016.pd
f?sfvrsn=4 .
75 New Buildings Institute, “Heat Pump Water Heater Day,” Advanced Water Heating Initiative, accessed November 13, 2023,
https://www.advancedwaterheatinginitiative.org/hpwh-day-resources .
74 “Daikin Heat Pump Solutions for Commercial Buildings,” Daikin Internet, accessed February 24, 2025,
https://www.daikin-ce.com/en_us/solutions/heat-pumps-for-commercial-buildings.html .
73 “Heat Pumps,” Trane Corp, accessed February 24, 2025,
https://www.trane.com/commercial/north-america/us/en/products-systems/heat-pumps.html .
72 “Decarbonising Commercial Buildings with Heat Pumps,” Daikin, accessed February 24, 2025,
https://www.daikin-ce.com/en_us/product-group/commercial-heatpumps.html .
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Grid Outage Risk: Clean Energy is the Most Reliable Energy
We often hear assertions that wind and solar energy are unreliable. In particular, after winter storm Uri in Texas, numerous
politicians from fossil-heavy states quickly blamed wind. However, that proved to be wrong: thorough analysis by the
Federal Energy Regulatory Commission (FERC) found that coal and gas plants made up 73 percent of the generator
capacity that experienced unplanned outages or substantially reduced output. 77 The reality is that renewable energy
resources have proven track records of both reducing peak demand and high reliability
This chart from energy transition
researcher and advisor Nat Bullard shows
the 2022 System Average Interruption
Duration Index for each of the 50 states, as
reported by utility companies to the US
Energy Information Administration (EIA).
78 Virginia, with only 5% penetration of
renewables, had the highest average
service interruption rate at over 18 hours
that year, while Iowa with over 60%
renewables penetration was among the
lowest average service interruption rates,
at less than two hours. In California, our
2022 SAIDI was 3.3 hours, in the best
one-third of states.
In California, the Public Utilities Commission tracks outages in detail for every Investor Owned Utility (IOU). 79 SCE’s
2023 SAIDI was 115 minutes or 1.9 hours, and its ten year average is 144 minutes or 2.4 hours. These are better than the
state and national averages. In fact, with outages of only 2.4 hours out of 8,760 hours per year, SCE’s grid has a reliability
up-time of 99.97% over the last ten years.
The evidence is clear: The US electrical grid can handle electrification . California's grid has higher reliability than the
national average. And SCE territory, which has a high degree of overlap with the South Coast Air Basin, os more reliable
than the California average.
Resilience: How Households and Communities Deal with Grid Outages
The US and Southern California electric grids are, as discussed above, highly reliable. But as with any human-engineered
system, outages occur. Resilience is the measure of households’ ability to withstand and recover when outages happen.
79 California Public Utilities Commission, “Electric System Reliability Annual Reports,”CPUC, accessed February 13, 2025,
https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/infrastructure/electric-reliability/electric-system-reliability-annual-rep
orts .
78 Nat Bullard, “Annual Presentation on the State of Decarbonization,” January 30, 2025,
https://www.nathanielbullard.com/presentations .
77 Aaron Schwartz and Ashtin Massie, “Reality Check: Keeping the Lights on in Extreme Winter Weather,” RMI, December 13, 2023,
https://rmi.org/reality-check-keeping-the-lights-on-in-extreme-winter-weather .
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One common assertion by fossil fuel advocates is that keeping gas as a part of the energy mix provides a hedge against
electric grid outages. At first blush, this “dual fuel” approach sounds like a plausible way to avoid “putting all your eggs in
one basket.” But that appearance is false: most modern gas-fired appliances in homes depend on electricity to function.
(While some existing appliances use pilot lights, those are no longer allowed in most appliances and so replacements
would require electricity).
● Gas furnaces require electricity for blower fan motors, control relays, and thermostats.
● Most gas water heaters require electricity for ignition, thermostat, and sensors.
● Gas dryers require electricity for cycle controls, tumbler, and control.
● Modern gas stoves have electronic ignition for igniting the gas. It is possible to light most with a match or lighter,
though many have a thermal flame sense system that requires the flame heats up enough to keep the gas valve on.
Gas ovens generally cannot be lit with a match.
So the positioning of gas as an element of a resilience scheme is a myth.
Actual resilience involves preparedness on the part of both households and communities. A 2018 report by the Center for
Climate and Energy Solutions (C2ES) describes household resilience measures including batteries attached to the
building, gas-fired backup generators, and neighbors helping neighbors. 80 Heat pump water heaters constitute a large
thermal battery, with 40 to 80 gallons of hot water that in a well-insulated tank will last for over 24 hours. Whole-home
batteries have low penetration today, but it is rapidly increasing as battery prices continue to fall steeply, and since the
CPUC’s 2024 introduction of Net Billing Tariffs by utility companies. And portable power stations, sometimes known as
“solar generators,” are portable batteries that can provide backup power for moderate loads for several hours. And while
the economy is still in the early stages of the energy transition, propane heaters and camp stoves provide short-term
resilience.
Cities and communities also have resilience strategies. At the high end, since Hurricane Katrina New Orleans has
implemented electricity system hardening, microgrids, efficiency programs for homes and businesses, and improved
disaster preparedness communication. Community resilience centers are common in many cities, providing residents a
place with space heating and cooling, hot water, and cooking.
Reliable energy supply is vital in modern society. The nation’s and state’s utility companies make it one of their highest
priorities.
80 Ashley Lawson, “Resilience Strategies for Power Outages,” Center for Climate and Energy Solutions (C2ES) (blog), August 2018,
https://www.c2es.org/document/resilience-strategies-for-power-outages .
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Phasing Out Residential Appliance Emissions:
Households and Businesses CAN Afford this Change - Here’s Why
March, 2025
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100 Amp Panels: Over 90% of Electrical Panels Can Handle Full Electrification
Another common objection to electrification is the concern that many electrical panels will have to be upgraded; Rewiring
America as recently as 2022 projected that a few tens of millions of homes would need electric panel upgrades from 100
amps to 200 amps.
However, recent studies have found that panel
upgrades will not be required nearly as often. A July
2023 report from New Buildings Institute and
Redwood Energy points out that in 1962 the “Live
Better Electrically” movement succeeded in
changing the National Electric Code, requiring all
new houses to be built with 100 amps of power at
240 volts, up from 60 amps. And in the 1990s, the
residential standard panel size increased to 200
amps. NBI described a study of over 75,000
Sacramento (CA) Municipal Utility District
(SMUD) homes, which recorded their one-hour peak
power demands over one year and showed that the
average all-electric home peaked at just 32 amps, far less than a 100 amp panel ’s capacity. (By comparison, gas-burning
homes peaked at about 20 amps). 81
The NBI report also described a study of over
22,000 California homes in Pacific Gas and
Electric (PG&E) territory, in which only 2% of
households peaked above 88 amps.
These two large samples of empirical real-world
data show that panel upgrades will not be needed
for the majority of homes.
The NBI report concluded that “there is a cheaper
and easier way to electrify our homes of the future:
keep 100-150 amp panels in place and help
homeowners go on a ‘watt diet.’ A watt diet means intentionally selecting energy-efficient, correctly sized, low power
equipment, and allocating available power to that equipment just when needed.” A valuable tool here is circuit splitters,
which allow two or more devices to share a single electrical circuit, with only one operating at a time. For instance, an EV
charger and a clothes dryer can share a 240V / 40A circuit.
81 Amruta Khanolkar, Sean Armstrong, and Tom Kabat, “We Can Power the Homes of the Future with Electric Panels of the Past,”
New Buildings Institute, July 25, 2023,
https://newbuildings.org/we-can-power-the-homes-of-the-future-with-electric-panels-of-the-past .
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Phasing Out Residential Appliance Emissions:
Households and Businesses CAN Afford this Change - Here’s Why
March, 2025
Page 33 of 34
Similar conclusions were reached by the San Francisco Bay Area Planning and Urban Research Association (SPUR). 82
They found that electric panel and service upgrades are often the most expensive and time-consuming aspects of
electrification, and discourage building owners from undertaking electrification projects. SPUR recommends electrifying
buildings without touching the electrical panel or service.
CONCLUSION
This report is respectfully submitted to show that the zero-NOx rules under consideration by the South Coast Air Quality
Management District, Proposed Amended Rules 1111 and 1121, are not only technically feasible, but are in fact the most
affordable and equitable way to eliminate the health hazards from Nitrogen Oxides by upgrading space heating and water
heating appliances as they reach end of life.
82 Sam Fishman et al., “Solving the Panel Puzzle | SPUR,” San Francisco Bay Area Planning and Urban Research Association (SPUR),
May 13, 2024, https://www.spur.org/publications/policy-brief/2024-05-14/solving-panel-puzzle .
Comments welcome:
petemarsh.re@gmail.com
Phasing Out Residential Appliance Emissions:
Households and Businesses CAN Afford this Change - Here’s Why
March, 2025
Page 34 of 34