The Bay Area Is Ready: Why Rule 9-6 Must Move Forward

The Bay Area has already built much of the foundation for cleaner, safer water heating. Now we must protect that progress while ensuring an affordable and practical transition.

By Tracy Flor Figueroa

Across the region, local governments, community organizations, community choice energy aggregates, and clean-energy partners have spent years preparing for a transition to cleaner air in our homes. In 2023, the Air District passed a landmark rule that would accomplish just that. This rule, known formally as Bay Area Air District Rule 9-6, limits toxic NOx pollution emitted into our homes from gas-fired water heaters. NOx is a byproduct of burning gas, and causes xx and xx, and it increases rates of childhood asthma (or something like that). Rule 9-6 targets this pollution by implementing a zero-NOx standard, which applies only to new equipment or exhisting equipment that needs to be replaced.

When homeowners learn about this rule, they often envision having to immediately install a brand new, expensive electric water heater, requiring immense investment and financial burden. But let’s clear up the confusion:

Rule 9-6 does not require removing a working heater. Most residents may not have to make the switch for years. If your water heater breaks and is unable to be repaired starting in 2028, you (as a homeowner) or your landlord will be required to replace it with a new water heater that meets the zero-NOx standard. If your old water heater continues to work without issue, you may continue to use it, and look forward to a future of having cleaner air in your home once you are ready to replace it. And, in the meantime, clean energy partners are continuing to put pedal to the metal to find ways to make clean water heating even more affordable.


At the Bay Area Air District’s Stationary Source Committee meeting on September 9, Air District staff, Senior Building Decarbonization Coordinator at SF Environment Department, Nik Kaestner, and Energy Programs Director at BayREN, Jane Elias presented progress on implementing the region’s clean appliance standards. They described programs that support consumers, coordinate agencies, streamline permits, and prepare the workforce and market for the transition.

Nik emphasized the significant progress implementation partners have made over the past six months. Although affordability and access gaps remain. The proposed amendment would move the first compliance date to January 2028. This timeline gives the regions time to continue strengthening rebates, financing, consumer education, and support for communities that could otherwise be left behind. Together, these investments are helping create a stronger market for heat pump water heaters and other zero-NOx options. Concerns about cost and grid reliability deserve thoughtful consideration. However, these challenges are reasons to invest in implementation, not reasons to delay cleaner-air protections. The foundation is already in place!

A September 27 San Francisco Chronicle article raised legitimate affordability concerns but centered its premise on whether officials have switched their own appliances. That framing is disappointing and does little to advance the important conversation about decisions that can steer the Bay Area toward a cleaner, lower-cost, and more resilient future. Officials can evaluate evidence without personally owning the technology.

The evidence deserves attention. RMI’s analysis released late September estimates that approximately 95% of modeled Bay Area single-family homes with gas water heating would lower their energy bill by switching to heat pump water heaters, with average annual savings of about $360. These projected operating savings depend on equipment and electricity-rate assumptions. SPUR’s funding analysis identifies roughly $55 million annually for heat pump incentive across the Bay Area region, alongside growing programs offering qualifying households low-cost or no-cost retrofits. Geographic gaps and complicated applications remain. Regional coordination and proposed point-of-sale assistance could help residents access support when replacements become urgent.  

Additional delays could create uncertainty and waste valuable time and resources that should be used to make the transition work for households, renters, and property owners across the region. The proposed Rule 9-6 amendments are designed to provide more time and exemptions for households and properties facing serious barriers. Unfortunately, growing public awareness has also been accompanied by misleading claims about the rules, their costs, and their effects on consumers. Advocates must respond with accurate information while continuing to push for stronger financial assistance and equitable implementation.

The Air District is expected to release the proposed amendments and draft changes that its Board will consider. Once the language becomes available, we will share an analysis of what it means for Rule 9-6 and the region's clean-air goals.

Join us in person at the November 4 Air District meeting and urge Board members to move Rule 9-6 forward with strong clean-air standards and meaningful affordability protections. Further uncertainty could slow the mark and waste momentum that should be used to close affordability gaps. Ask Air District leaders to reduce deadly air pollution. Let’s move Rule 9-6 forward and keep the Bay Area leading toward a healthier, more equitable future.

Frequently Asked Question About Rule 9-6

Does Rule 9-6 ban gas water heaters immediately?
No. It establishes future zero-NOx standards for covered new water heaters. Existing, working water heaters do not have to be removed.

When would the zero-NOx standard begin?
The adopted first compliance date is January 2027 for small water heaters. The proposed amendments would extend it to January 2028, if approved.

Does the rule apply when my water heater is replaced?
The manufacturing standard affects covered new equipment available after compliance date. If does not force replacements before an existing unit reaches the end of its life.

How would affordability and difficult installations be addressed? 
The proposed amendments include added time and targeted exemptions for qualifying low-income properties, certain high-cost installations, space constraints, emergency replacements, and other barriers.

Why does Rule 9-6 matter for health?
NOx helps form ozone and fine particulate matter. Reducing emissions from gas appliances can improve regional air quality and reduce health harms, especially in overburdened communities. 

Resources:

Watch the Stationary Source Meeting Recording

State and Regional Efforts to Advance the Equitable Transition to Clean Appliances Presentation

Read SPUR’s Funding analysis “How Much Money Is Available to Help Bay Area Homeowners Install Heat Pumps?”

Read RMI’s analysis “How Heat Pumps Reduce Energy Bills and Air Pollution in the San Francisco Bay Area”

What to Do Next:

Reduce Deadly Air Pollution in the Bay Area!

RSVP to Press Conference: Bay Area Clean Appliance Standards

Add to Calendar November Air District Meeting: Support Zero-Emission appliances