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18 February 2025 <br /> <br />Santa Ana City Council <br />20 Civic Center Plaza <br />Santa Ana, CA 92701 <br />eComment@santa-ana.org <br /> <br />RE: OPPOSE Agenda Item #18, a Resolution Opposing SCAQMD Rules 1111 and 1121 <br /> <br />Members of the Santa Ana City Council, <br /> <br />Tonight you will vote on a proposal to oppose South Coast Air Quality Management District <br />(SCAQMD) rules 1111 and 1121. These rules, regulating gas furnaces and water heaters, would <br />regulate one of the largest sources of noxious NOx emissions, would improve public health by <br />reducing the negative effects of diseases like asthma, and clean the air that we all breathe. <br /> <br />SCAQMD is the air regulator for 17 million Californians who suffer from some of the worst air <br />quality in the country. Within the South Coast region, Santa Ana stands out on CalEnviroScreen <br />as a city that is disproportionately burdened by multiple sources of pollution, including the kinds <br />that would be regulated by the proposed rules. <br /> <br />These rules have recently been revised to use a new framework, which, alongside previous <br />claims in the proposed resolution, make most of the statements in the resolution no longer <br />accurate or potentially misleading. Below we respond to each clause of the resolution <br />individually: <br /> <br />● Clause 3 claims “Rules 1111 and 1121…[will deliver] minimal measurable air quality <br />improvements.” At Working Group Meeting #8, held February 13, 2025, AQMD staff <br />presented this slideshow, which on Slide 6 shows that NOx emission reductions from <br />space and water heating would be greater than reductions from refinery equipment, and <br />between 6 to 7 times greater than reductions from electricity generating facilities. <br />● Clause 4 claims “these rules propose a ban on natural gas-powered furnaces.” This is no <br />longer accurate, with Slide 11 of the Working Group Meeting presentation showing that <br />even after 2036, the new framework for the rules would allow gas furnaces to be sold. A <br />plaintext interpretation of that slide can be found here, under “Healthy Air Standards.” <br />● Clause 5 implies that the rules will “significantly elevate costs.” However, the AQMD <br />staff report at pdf page 38 found the rules cost-effective in every instance but one. <br />Additionally, with the new rules framework, the onus is no longer on the owner but on <br />the appliance manufacturer.