As members of a local air district were considering the fate of a rule that would force Bay Area homeowners to replace old gas water heaters with electric heat pumps, dozens of public comments flooded in.
The emails voiced concerns about increased costs to homeowners and urged the air board to agree to undertake more socioeconomic analyses before enforcing it. Regulators took note of the local pushback, and this spring Bay Area Air District (BAAD) staff recommended that the committee put off implementing the rule by a year.
But dozens of letters that were sent to the air district were not, in fact, written and sent by concerned locals, it was later revealed. Instead, at least 85 of them were sent by a software company that uses AI and was paid by an advocacy group called the Bay Area Council, which describes itself as at the “intersection of business and civic leadership.”
According to lobbying disclosures obtained by DeSmog, oil and gas giant Chevron donated approximately $150,000 to the Council during the second quarter of this year, the period in which the organization led a campaign against the electrification rules and pushed for more stringent socioecononomic modeling for future rules before the air board.
Chevron is California’s largest producer of oil and gas and owns a refinery in Richmond, across the bay from San Francisco. It’s a member of the Council, along with utility PG&E and the Western States Petroleum Association.
Chevron did not respond to a request for comment. Rufus Jeffris, senior vice president of communications at the Bay Area Council, did not respond to questions about what Chevron’s payment was used for.
“Onerous mandates and regulation of oil refining in California are a major reason for the state’s nation-leading fuel costs and why Gov. Newsom and the legislature backed away from certain rules and regulations that were forcing refineries to leave – the majority of Californians still drive gas-powered vehicles,” Jeffris wrote in a statement. “And we strongly support enabling and incentivizing consumer- and market-based solutions as part of any solutions, rather than mandates.”
If passed, the Bay Area would be the first air district in the U.S. to phase out gas-powered water heaters, potentially paving the way for other districts and states to impose their own restrictions. Similar state-level regulations are already taking shape in Maryand.
“It would be an enormous victory to to make heat pump water heaters essentially the norm in the Bay Area,” said Sam Fishman, sustainability and resilience policy manager at the San Francisco Bay Area Planning and Urban Research Association. “I think that the air district rules here…if they survive and then succeed, I think that’ll set an enormous precedent for the nation.”
Chevron and other members of the Council could lose financially from the implementation of the air district’s proposed electrification rule. The rule would cut back significantly on the air district’s use of gas – eventually phasing out gas-powered water heaters in 2.8 million households.
Environmental advocates say the Council’s desire to require the air district to include more studies in all future socioeconomic reports — not just the heat pump rule — could also benefit refineries like Chevron, which is regulated heavily by the air board.
“The air district does a socioeconomic analysis whenever it’s going to enact a significant policy, and they wanted to enshrine the details of what that socioeconomic analysis should include and make it more robust, potentially with the interest in making it onerous and therefore harder for the air district to instate rules,” said Tony Sirna, deputy policy director of buildings at Evergreen Action. ”I think that was the main objective of the Bay Area Council. That’s the campaign that they were truly focused on.”
Opposing Electrification
The Bay Area Air District unanimously passed the zero-NOx appliance standards, known as the electrification rules, in 2023. The air district estimated that a switch to electric gas pumps would save nearly $10 million on annual utility bills across the Bay Area. It also predicted that the switch would significantly reduce harmful emissions of NOx (a group of poisonous gases made of nitrogen and oxygen, primarily nitric oxide (NO) and nitrogen dioxide (NO₂), that can impact asthma and lung disease, slashing 3,236 tons annually, and in turn preventing an estimated 37 to 85 premature deaths each year.
Chevron has not spoken out publicly about the proposed electrification rules, but it has criticized California regulators for increasing energy costs it says are passed to consumers. And it opposed a proposed Cap-and-Invest amendment by the state’s air board, which it argued threatened the viability of California’s remaining refineries, jobs, and fuel supply.
The gas company has also poured millions into candidates, lobbying, and campaigns across the state to influence California’s attempts to tighten rules on fossil fuels. From January 1 through June of this year, Chevron reported paying $30,496 to a public relations firm that is responsible for running a Chevron-owned Richmond newspaper that does not report critically on the oil giant. It also paid $2,952,835 to Californians for Energy Independence, a group that advocates for California’s oil and gas industry,and $500,000 to the California Business Roundtable, a group the Council called a “strategic partner” in a 2025 Council presentation on “government relations” obtained by DeSmog. The Roundtable is an advocacy group that promotes pro-business ideals.
Chevron has also tussled directly with the air district. In 2024, the company agreed to pay it $20 million to settle 678 violations it had incurred at its Richmond refinery, and last December BAAD fined Chevron $900,000 for failing to adequately monitor emissions at the refinery.
Last November, BAAD opened a public comment period about any concerns over the water-heater rule, with a focus on addressing affordability, equity, and implementation costs. It was the same month that the Bay Area Council, of which Chevron is a member, launched a website for a group called the Common Sense Coalition. The website read: “The cost of living here is already unbearable. Rent, gas, groceries, power bills — everything keeps going up. But the air district keeps adding rules that drive prices even higher.”
The website also hosted a form where people could submit canned emails to regulators opposing the rules. The form read in part: “I’m a real person struggling with the price of utilities and gas.This was not written with AI. I write with an urgent request: get a hold of rising bills and surprise fees for families by requiring transparency before new rules take effect — starting with Rule 9-6, the new water heater regulation now in front of the board.”
Between November 2025 and June of this year the Common Sense Coalition spent more than $148,000 on Meta advertisements that linked back to the web form, according to Meta’s online ad library.
The San Francisco Chronicle reported in March that it had contacted people whose names were on the forms sent by the software company that the Council hired. They found 10 people who said they had not authorized the opposition emails. The Council has denied using AI to send the forms.
The Coalition’s website has since gone dark.
The air district staff issued recommendations July 8 to delay the implementation date of the electrification rule.
The Council netted another victory in early September when the air board voted to approve a proposal to more robustly study the socioeconomic impacts of future rules before the board. The new policy “set standards and metrics to ensure consistency for analyses conducted beyond the minimum statutory requirements and documents standards of transparency.”
While BAAD already undertook a more stringent socio-economic impact report for the heat pump rule, the new policy applies the need for additional economic studies more broadly to other future rules before the board.
Jeffris said in a statement that the Bay Area Council had opposed the heat pump rule because “these mandates have real-world costs that are not abstract. All this comes as affordability rises as one of the biggest concerns facing many Bay Area and California residents.”
He added off the September approval to bolster future reporting: “The Air District agreed with us and adopted a policy we had advocated for that they conduct socio-economic impact analysis on new rules and regulations.”
Sirna said Chevron, which owns a refinery in Richmond, in particular aims to gain from the ruling.
“They definitely care a lot about what happens at the air district, and the air district is monitoring them regularly and imposing fines on them when they have pollution that goes beyond the regulated limits,” he said. “My concern is that [the policy] will just make it either more difficult for them to enact regulations in general, or that provide more fodder for lawsuits or something.”
A Similar LA Playbook
A year before the Bay Area’s fight over electrification rules, the Los Angeles air district experienced something incredibly similar.
In June 2025 South Coast Air Quality Management District regulators were considering a proposal to phase out gas-powered appliances when tens of thousands of opposition emails began pouring into the district. Ultimately, the board voted 7-5 against the proposal.
The number of letters sent to the board was abnormal and overwhelming. They were signed by real residents, but reporting from the Los Angeles Times later found that at least 20,000 had come from a software company, CivicClick, that uses AI. Political consultant Matt Klink, a partner at California Strategies, whose clients include Sempra, the parent company of SoCalGas, took credit for hiring CivicClick for the campaign.
“We knew that we needed to generate real emails from real voters very quickly on a highly technical air quality regulation — not your common piece of legislation. CiviClick was able to quickly identify real voters in the constituency of the AQMD board and send emails to these people immediately,” Klink told Campaigns & Elections in August 2025.
The Los Angeles Times later reported that they’d spoken to several people who said they had not agreed to use their name on the CivicClick emails.
“We were pretty disturbed by that, and we’ve seen signs of similar things happening in the Bay Area,” Fishman said of the emails sent to the South Coast Air Quality Management District. “It’s a big threat to democracy. You know these governing bodies that really represent pretty large populations rely to some degree on on hearing from their constituents and really understanding and taking the pulse in their regions.”
While there’s been no reporting directly linking the two campaigns against the California air district rules, the use of AI in public comments received state-wide attention. This past August, state legislators passed a law to make it harder for AI-powered letters to influence votes. The law determined that no one can knowingly use AI to falsely represent a real person when engaging with a government agency and that agencies don’t have to treat AI written communications as if they are from real people.
The California Air Resources Board (CARB) is currently developing statewide water heater standards that would phase in zero-emission limits, but wouldn’t take effect until 2030. Back in the Bay Area, residents are awaiting a final vote from the air district board as to whether they’ll accept the staff’s recommendations to delay the electrification rule from taking effect in January 2027 and push it to January 2028. The board is expected to cast its vote this November.
