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● Clause 6 says “Rules 1111 and 1121 specifically impact individual homeowners, <br />apartment complexes, and businesses.” This is no longer the case, as Slide 12 of the <br />Working Group Meeting presentation shows that solely appliance manufacturers are <br />subject to the proposed rules. <br />● Clauses 7 and 8 state that new electric appliances would be “costly” or “financially <br />burdensome,” however there are numerous rebates available for consumers, including the <br />pilot Go Zero Program by AQMD (of which 75% of rebate funding will go to <br />overburdened communities as shown on pdf page 7), HEEHRA rebates funded by the <br />Inflation Reduction Act, Comfortably CA, and Golden State Rebates. <br />● Clause 7 also mentions electrical panel upgrades, however the AQMD staff report at pdf <br />page 34 finds that at most 9% of homes would need a new electrical panel. <br />● Clause 9 states that these rules will “impose a significant increase in electricity demand <br />on California’s power grid.” This concern may be true, which is why it is important to <br />ease access to more renewable energy sources, generation, and storage, such as making it <br />easier to install, solar panels, wind turbines, and battery energy storage systems. More <br />renewable and distributed energy resources will ease grid demand and enable ratepayers <br />to own their own power and realize lower rates. <br />● Finally, Clause 10 demands “solutions be both practical and equitable, balancing <br />environmental benefits with the economic realities faced by residents and businesses.” <br />These proposed rules have been amended to address affordability concerns and the <br />agency proposing them has begun a pilot rebate program alongside numerous other rebate <br />programs. These proposed rules would reduce emissions by more than could be reduced <br />by regulating every refinery in the South Coast Region. And these proposed rules would <br />reduce health impacts by preventing: <br />● 4,000 premature deaths <br />● 16,000 new asthma cases <br />● 4,000 emergency room visits <br />These rules are practical, will benefit overburdened communities, and represent some of <br />the largest environmental benefits proposed by AQMD. <br /> <br />Given these flaws in the proposed resolution, Climate Action Campaign respectfully requests <br />you vote no on Item 18. <br /> <br />Sincerely, <br /> <br />David Martinez <br />OC Climate Equity Advocate and Organizer <br />Climate Action Campaign <br /> <br /> <br />