Public Comment Period Open for Water Heater Ban

SAMCAR Electrification Task Force | October 6, 2026

Public Comment Period Closes November 1 at 6 PM

On November 4, 2026, the Bay Area Air District Board of Directors will consider changes to Rule 9-6 (mandated ban) for water heaters. The changes being considered would, if approved, provide for some exemptions to the zero-nitrogen oxides standard and could delay the compliance date one year, to January 1, 2028.

Responding to public outcry about the mandate, the Air District has released Proposed Rule Language, a Preliminary Staff Report, an Updated Socioeconomic Impact Analysis, and an Addendum to the Environmental Impact Report for the proposed affordability amendments for Rule 9-6 for water heaters. These materials are available on the Bay Area Air District building appliances webpage.

The public comment period will close on November 1 at 6 PM. SAMCAR members and San Mateo County homeowners are encouraged to provide online comments that must be submitted through the Air District's public comment tool to be considered. Under Air District policy, they will not consider comments on regulations that are submitted by email.

Suggested Talking Points for Public Comments

Members may use or adapt the following points when submitting comments through the Air District's public comment portal:

Dear Bay Area Air District Board of Directors:
Please vote to repeal the current ban on gas water heaters and furnaces. While the staff recommendation to delay the gas water heater ban and carveouts for vulnerable communities is a step in the right direction, it doesn't go far enough. The costs of electrification can be significant and should not fall solely on homeowners. I urge you to consider voluntary phaseouts due to the following concerns:
• Protect housing affordability: Replacing gas appliances with electric alternatives can involve substantial costs, including electrical panel upgrades, wiring, construction, and permitting.
• Respect homeowner choice: Homeowners should have the flexibility to replace functioning appliances with options that meet their household needs and budgets.
• Address grid readiness: The Air District should fully evaluate electrical infrastructure capacity, grid reliability, permitting delays, and the potential costs of upgrades before imposing mandatory phaseouts.
• Consider vulnerable communities: Seniors, low-income households, and owners of older homes may be disproportionately affected by conversion costs.
• Support practical, voluntary solutions: Prioritize rebates/incentives, education, infrastructure improvements, and voluntary electrification rather than mandatory deadlines that may impose significant financial burdens.

SAMCAR supports de-carbonization of homes, but that the policy should be voluntary. SAMCAR has long opposed the mandates on gas water heaters and furnaces bans, citing lack of public outreach, PG&E grid reliability challenges, Bay Area older homes, socio economic impacts, impacts to seniors, and possible high costs for homeowners to electrify their homes.

Please get your comments in ahead of the Bay Area Air District's Board of Directors meeting on November 4.

Additional Resources

Energy Efficiency Toolkit for REALTORS® »

Case Study: Potential Cost Range of All-Electric Conversion »

Fernando Peña

SAMCAR

850 Woodside Way, San Mateo CA 94401 (map)

(650) 696-8200

TAGGED: BAAD, Bay Area Air District, Electrification, Water Heaters

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