SPUR appreciates the CEC’s efforts to encourage the use of heat pumps, and we support the proposal's use of compliance incentives for all-electric buildings. However, the proposal is insufficient to shift the market to all-electric new construction. Under current policies, California is projected to miss its 2030 climate goal, emitting 25 million metric tons (MMT) of carbon dioxide equivalent over the goal of 259 MMT. To correct course, the state needs to move expediently to electrify buildings. SPUR urges staff to set strong decarbonization requirements by tightening the gas baseline, in order to lead to broad adoption of all-electric new construction.