May 19, 2025
Hon. Doug Chaffee, Chair Orange County Board of Supervisors 400 W Civic Center Dr, Santa Ana, CA 92701
Subject: Adopt Resolution by Supervisor Nguyen to Oppose South Coast Air Quality Management District Proposed Amended Rules 1111 and 1121
Dear Chair Chaffee and Board Members, I respectfully write in opposition to the South Coast Air Quality Management District’s (SCAQMD) proposed Rules 1111 and 1121, and to urge the Board of Supervisors to support Supervisor Nguyen’s resolution urging SCAQMD to indefinitely delay or withdraw these regulations.
Similarly, as proposed, Rule 1111 and 1121 will require residents and businesses- more than 17 million people – to transition their furnaces and water heaters to electrical units and eliminate the use of natural gas. The proposed rules will go into effect for residents in less than two years.
The intent of both proposed rules is admirable, however, I believe the prioritization of an electrification mandate is both misguided and will have a number of negative consequences.
I am in complete support of efforts to improve air quality. However, these proposed rules have not shown that they will make any substantive improvements for Orange County residents. Yet, the pain homeowners will feel to their pocketbooks as they are forced to construct spaces for bigger devices, rewire for new electronic designs and pay for electricity, with appliances pulling an already unstable power supply, will be significant. Water heaters and furnaces are not luxury items; they are necessities.
Californians are facing a housing shortage and housing affordability crisis; now is the wrong time to put new, expensive, rushed mandates in place. According to Cal Matters and 2022 census data, the value of the typical California home is now eleven times more than what the average household makes, compared to four times the average household’s income in the 1960s. Furthermore, the increased cost of home ownership, which in California is nearly 2.5 times higher than the median national home, is exacerbated by rules such as 1111, 1121. These increased costs have resulted in low homeownership rates, with California having the second lowest rate of homeownership of any state in the country. The housing shortage and housing affordability crisis are undeniable in California, and now is not the appropriate time to introduce further mandates which will make life more difficult for homeowners.
In addition, mandates such as those imposed by Rule 1111, 1121 do not help the millions of Californians who are impacted by the current affordability crisis. In fact they make it worse. All across the state Californians are facing financial hardship on a daily basis, whether it is disproportionately high taxes, unnecessarily high prices for gas, which are $ 1.70 more than the national average for a gallon and energy costs, which are 92% higher than the national average. Costly mandates are not the solution and will only further harm Californians.
Mandates such as proposed rule 1111 and 1121 also negatively impact renters in California. Orange County is already the 11th most competitive rental market in the nation and adding these rules as another unnecessary expense will not help. According to both Cal Matters and the PPIC, the state of California, when compared to the national average, has a higher rate of cost-burdened households, with over 50% of renters in the state spending 30% or more of their household income on housing.
I strongly believe that we must find solutions to improve quality in California. However, for the reasons listed above, I urge the South Coast Air Quality Management District to both re-consider their and to oppose Rule 1111 and 1121 and address the challenges of air quality by pursuing improvements and incentives, not unproven bans and mandates.
If you have any questions, please contact my Legislative Director, Aaron Rice, at Aaron.Rice@asm.ca.gov or 916-584-4177.
