Last month, state energy officials warned that California likely will have a shortage of electricity this summer equivalent to what is needed to power about 1.3 million homes. So why are local and state regulators increasingly trying to force Californians to rely on increasingly unreliable electricity?

In Sacramento, the California Air Resources Board is working on its “Advanced Clean Cars II Rulemaking” to try to force the replacement of gasoline-powered cars with electric vehicles. And here in Southern California, the South Coast Air Quality Management District is proposing “control measures” that would require the replacement of natural gas appliances with “zero emission” units in both new and existing residences.

“Zero emission” means it doesn’t work during a power outage.

The South Coast Air Quality Management District has just produced its 2022 Draft Air Quality Management Plan, known as the AQMP. It’s very long, but here’s the short version: The region is required to meet the “2015 federal 8-hour ozone standard” by 2037, and there’s no way it can be done.

Meeting the standard would require reducing emissions of nitrogen oxides (NOx) by 71% more than all our current rules and regulations will achieve. “The only way to achieve the required NOx reductions is through extensive use of zero emission technologies across all stationary and mobile sources,” the executive summary states, but what the AQMD is allowed to regulate “accounts for less than 20 percent of NOx emissions.”

Everything else is under federal or state control, such as ships, off-road equipment and aircraft. The AQMD can only regulate “stationary sources” of emissions, such as power plants, refineries and factories, and they’ve already done that.

So even though “residential combustion” accounts for only a fraction of a fraction of NOx emissions, they’re trying to force the replacement of gas water heaters, furnaces and stoves in up to 5.3 million residences.

How much will it cost?

“The required transition to zero and low emission technologies to meet the standard will be more expensive than traditional control strategies developed for previous federal standards,” the regulators admit. “Ensuring the transition is equitable and affordable will be key to the success of the AQMP.”

To deal with the equity and affordability problem, the AQMD is planning to offer “incentives” to some residents. They’re just not sure where they’ll get enough money to pay for them.

The immediate problem is that in 2018, the U.S. Environmental Protection Agency designated the South Coast Air Basin as an “extreme” nonattainment area for “the 2015 8-hour ozone standard” and regulators are required to have a plan to be in compliance by 2037. But in a section of the Air Quality Management Plan draft titled “Air Quality and Health Effects,” the regulators explain that “weather conditions” are “a primary driver of observed air pollutant levels in our region.” They say our “topography,” “frequent strong temperature inversions” and “abundant sunshine” create a “‘perfect storm’ of conditions for forming air pollution” and high ozone. Another cause of high ozone levels in the region: wildfires.

Given all these factors, perhaps it would make sense to review the ozone standard itself and see if it’s appropriate or delusional. Could our financial resources be directed toward something more beneficial?

Instead of an answer to that question, we have 48 newly proposed “control measures.”

Control measure R-CMB-01 is “requiring zero emission water heating units through a regulatory approach for both new and existing residences.”

“A regulatory approach” means it’s mandatory.

Control measure R-CMB-02 is “requiring zero emission space heating units through a regulatory approach for both new and existing residences.”

Control measure R-CMB-03 “seeks to achieve NOx reductions from residential cooking devices including stoves, ovens, griddles, broilers, and others in new and existing residential buildings.”

Notice that the word “requiring” is missing from the third “control measure,” perhaps because “NOx emissions from residential cooking devices are not currently regulated by the South Coast AQMD.” Not yet, but the Legislature is still in session.

There are dozens more proposed “control measures” affecting commercial and industrial equipment, all of them added on top of the regulations already imposed.

Recognizing that compliance may be impossible in many cases, the AQMD plan offers violators the option of paying a “mitigation fee.” The agency says it’s planning to use mitigation fee revenue to fund its incentive programs “to accelerate the adoption of zero emission units.”

This is an awful lot of trouble and expense to accomplish nothing. Even if ozone is the cause of health problems in Southern California, banning gas appliances doesn’t fix it. The only purpose of the regulations is to comply with other regulations and avoid the potential penalty of even more regulations. Will anyone ever have the courage to call it all out and demand a rational review of what we’re doing?

Probably not, but if you’d like to make your voice heard, the public comment period on the Draft 2022 AQMP runs until June 21. Email your comments to AQMPteam@aqmd.gov or go to AQMD.gov and search for “Air Quality Management Plan.”

According to Table 4-1 of the plan, one of the criteria for evaluating the proposed control measures is “public acceptability,” defined as “the likelihood that the public will approve or cooperate in the implementation of a control measure.”

Let them know what you think.

Susan Shelley can be reached at Susan@SusanShelley.com and you can follow her on Twitter @Susan_Shelley.

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