HomeMy WebLinkAbout2022-10-11; City Council; ; San Diego Regional Decarbonization FrameworkCA Review _RMC_
Meeting Date: Oct. 11, 2022
To: Mayor and City Council
From: Scott Chadwick, City Manager
Staff Contact: Katie Hentrich, Senior Program Manager
katie.hentrich@carlsbadca.gov, 442-339-2623
Jamie Wood, Environmental Sustainability Director
james.wood@carlsbadca.gov, 442-339-2584
Subject:
Districts:
San Diego Regional Decarbonization Framework
All
Recommended Action
Receive a presentation on the San Diego Regional Decarbonization Framework from the County
of San Diego staff.
Executive Summary
The San Diego Regional Decarbonization Framework is a document prepared by the County of
San Diego that examines potential regional decarbonization efforts in partnership with the
following institutions: the University of California San Diego’s School of Global Policy and
Strategy, the University of San Diego, the Energy Policy Initiatives Center and the consulting
firm Inclusive Economics. A summary for policy makers is included as Exhibit 1, and the full
technical report is included as Exhibit 2.
Discussion
The Regional Decarbonization Framework provides technical and policy pathways to
decarbonization in the medium-term to inform near-term policymaking in regional, county and
city governments. Specifically, the framework in the summary for policy makers considers “how
to achieve deep decarbonization of San Diego’s regional energy system, which is defined as the
total production and consumption of energy in the electric power, transportation and buildings
sectors, to align with state and national pathways to reach net zero” greenhouse gas emissions.
The document identifies what are referred to as “low-regret” strategies, which provide the best
assessment of the least costly and most effective near-term solutions for reducing emissions in
each sector. These strategies are presented as a menu of options for local and regional agencies
to consider, as the county does not have land use authority over these entities.
The framework also examines greenhouse gas reductions embedded in local Climate Action
Plans and identifies a “Best CAP Commitment Scenario,” or the most aggressive measures in
each policy category, regardless of jurisdiction size or the year the climate action plan was
Oct. 11, 2022 Item #12 Page 1 of 560
adopted. Carlsbad is listed as having the “Best CAP Commitment” for its strategies related to
Transportation Demand Management, a strategy to reduce single-vehicle trips; fuel reduction
from traffic calming efforts; and residential and non-residential energy retrofits.
The framework finds that even when all the current Climate Action Plan commitments across
the region are totaled up, the collective reduction targets are not sufficient to reach net zero
greenhouse gas emissions by 2035. Specifically, a gap of seven million metric tons of carbon
dioxide equivalent, mostly from natural gas combustion and transportation on roadways, still
exists. The framework encourages a collective, region-wide approach to reach these reduction
goals through the identified strategies and opportunities for collaboration.
Fiscal Analysis
No city funding is requested at this time.
Next Steps
County staff will be preparing an “Implementation Playbook” for the Regional Decarbonization
Framework, with a draft anticipated in December 2022, and will continue to conduct outreach
to the public and other stakeholders. The final Regional Decarbonization Framework and
related documents are expected to be presented to the San Diego County Board of Supervisors
for consideration and adoption in spring 2023.
City staff will continue to participate in meetings related to the Regional Decarbonization
Framework and incorporate any relevant information into the ongoing Climate Action Plan
Update.
Environmental Evaluation
This action does not require environmental review because it does not constitute a project
within the meaning of the California Environmental Quality Act under California Public
Resources Code Section 21065 in that it has no potential to cause either a direct physical
change or a reasonably foreseeable indirect physical change in the environment.
Public Notification
This document was noticed in accordance with the Ralph M. Brown Act and was available for
public viewing and review at least 72 hours prior to scheduled meeting date.
Exhibits
1. San Diego Regional Decarbonization Framework Summary for Policy Makers
2. San Diego Regional Decarbonization Framework Technical Report
Oct. 11, 2022 Item #12 Page 2 of 560
San Diego Regional
Decarbonization Framework
SUMMARY FOR POLICY MAKERS
Exhibit 1
Oct. 11, 2022 Item #12 Page 3 of 560
1
Project Team
Project Director
Gordon C. McCord
Associate Dean & Associate Professor of Economics
Director, SDG Policy Initiative
School of Global Policy and Strategy, University of California San Diego (UC San Diego)
Project Manager
Elise Hanson, County of San Diego, Land Use and Environment Group (LUEG)
San Diego County Representatives
Murtaza Baxamusa
Rebeca Appel
Sarah Aghassi
Yasamin Rasoulzadeh
Michael De La Rosa
Donna Durckel
Nicole Boghossian Ambrose
Jennifer Lawson
Renee Loewer
Chapter Authors
Introduction
Murtaza H. Baxamusa, LUEG
Study Approach
Ryan A. Jones, Evolved Energy Research
Geospatial Analysis of Renewable Energy Production
Emily Leslie, Montara Mountain Energy
Joseph Bettles, UC San Diego
Accelerating Deep Decarbonization in the Transportation Sector
Katy Cole, Fehr & Peers
Chelsea Richer, Fehr & Peers
Eleanor Hunts, Fehr & Peers
Oct. 11, 2022 Item #12 Page 4 of 560
2
Decarbonization of Buildings
Philip Eash-Gates, Synapse Energy Economics
Jason Frost, Synapse Energy Economics
Shelley Kwok, Synapse Energy Economics
Jackie Litynski, Synapse Energy Economics
Kenji Takahashi, Synapse Energy Economics
Asa Hopkins, Synapse Energy Economics
Natural Climate Solutions and other Land Use Considerations
Elise Hanson, UC San Diego
Emily Leslie, Montara Mountain Energy
Employment Impacts through Decarbonization in the San Diego Region
Robert Pollin, Political Economy Research Institute (PERI), University of Massachusetts Amherst
Jeannette Wicks-Lim, PERI, University of Massachusetts Amherst
Shouvik Chakraborty, PERI, University of Massachusetts Amherst
Gregor Semieniuk, PERI, University of Massachusetts Amherst
Key Policy Considerations for the San Diego Region
Joseph Bettles, UC San Diego
Gordon C. McCord, UC San Diego
David G. Victor, UC San Diego
Emily Carlton, UC San Diego
Local Policy Opportunity Analysis
Scott Anders, Energy Policy Initiatives Center (EPIC), University of San Diego School of Law
Nilmini Silva Send, EPIC, University of San Diego School of Law
Joe Kaatz, EPIC, University of San Diego School of Law
Yichao Gu, EPIC, University of San Diego School of Law
Marc Steele, EPIC, University of San Diego School of Law
The San Diego Region as a Model
Elena Crete, UN Sustainable Development Solutions Network (SDSN)
Julie Topf, UN Sustainable Development Solutions Network (SDSN)
Appendix A: Summary of Statewide Energy System Modeling
Ryan Jones, Evolved Energy
Appendix B: Review of Authority for Local Jurisdictions and Agencies to Influence and
Regulate GHG Emissions
Joe Kaatz, EPIC, University of San Diego
Oct. 11, 2022 Item #12 Page 5 of 560
3
Acknowledgments
Special thanks to the County of San Diego Board of Supervisors: Chair Nathan Fletcher, Vice
Chair Nora Vargas, Supervisor Joel Anderson, Supervisor Terra Lawson-Remer, and Supervisor
Jim Desmond for their direction and leadership in establishing this framework.
The authors thank David Victor for his advisory role across the project, as well as Joseph Bettles,
Tyler Spencer, Emily Carlton, Elissa Bozhkov, and Jeffrey Myers for research and editorial
support, and Isaac Wang for project management support.
The project team is grateful to the following individuals for their strategic advice to the County
of San Diego representatives: Elizabeth King (California Environmental Protection Agency),
Jamal Russell Black (San Diego Regional Policy & Innovation Center), Christiana DeBenedict (San
Diego Foundation), Everett Au (San Diego Foundation), Amenah Gulamhusein (San Diego
Foundation), and Susan L. Guinn (San Diego Regional Policy & Innovation Center).
The project team also wants to thank the Technical Working Group and all the participants and
commenters who contributed their time and knowledge by submitting written/oral comments
and attending our meetings and workshops.
Disclaimer
This report was funded by the County of San Diego. The authors declare no competing interests
with relevant entities in the San Diego region.
This summary report should be cited as:
McCord, Gordon C., Elise Hanson, Murtaza H. Baxamusa, Emily Leslie, Joseph Bettles, Ryan A. Jones, Katy Cole,
Chelsea Richer, Eleanor Hunts, Philip Eash-Gates, Jason Frost, Shelley Kwok, Jackie Litynski, Kenji Takahashi, Asa
Hopkins, Robert Pollin, Jeannette Wicks-Lim, Shouvik Chakraborty, Gregor Semieniuk, David G. Victor, Emily
Carlton, Scott Anders, Nilmini Silva Send, Joe Kaatz, Yichao Gu, Marc Steele, Elena Crete, and Julie Topf. San Diego
Regional Decarbonization Framework: Summary for Policy Makers. County of San Diego, California. 2022.
Oct. 11, 2022 Item #12 Page 6 of 560
4
Introduction
The global scientific consensus is unequivocal: the world is experiencing a human-caused
climate crisis and our window to meaningfully reduce greenhouse gas (GHG) emissions is
closing.i Human activities have warmed the planet through rapid accumulations of GHGs in the
atmosphere and the ocean, causing rapid and alarming changes. Global compacts, like the Paris
Climate Agreement, and California policies from legislation and executive orders recognize the
immediacy of decarbonization required across industries. Where past diplomatic efforts have
failed to achieve enough progress on climate change, regional problem-solving models that
account for both global commitments and local needs can represent a more effective approach.
The San Diego Regional Decarbonization Framework’s (RDF’s) Technical Report provides
technical and policy pathways to decarbonization in the medium-term to inform near-term
policymaking in regional, County, and city governments. The report models science-based
pathways to net zero carbon emissions for the San Diego region by 2045, consistent with the
Paris Climate Agreement and California State (State) mandates. The pathways provide a shared
vision for the San Diego region to collectively reduce net GHG emissions in alignment with
California’s net zero goal. This report is a technical analysis of how different sectors in the
energy system can contribute to decarbonization, but does not identify the “right” pathway.
Instead, it shows numerous ways to achieve regional emissions goals in multiple sectors to
highlight trade-offs, co-benefits, decision points, risks, and synergies. The analyses and
pathways should be updated as technologies evolve or uncertainties are resolved or clarified.
To that end, the report explores policy processes to help regional jurisdictions learn about
uncertainties and adjust strategies as information arises.
Study Framework and Key Policy Considerations
This report considers how to achieve deep decarbonization of San Diego’s regional energy
system, which is defined as the total production and consumption of energy in the electric
power, transportation, and buildings sectors, to align with State and national pathways to
reach net zero. Deep decarbonization refers to the process of drastically reducing carbon
dioxide (CO2) and other GHG emissions throughout the economy. By “net zero,” this report
means that human-caused CO2 emissions from the energy system equal human-caused CO2
i Intergovernmental Panel on Climate Change (IPCC), “Climate Change 2022: Impacts, Adaptation, and
Vulnerability. Summary for Policymakers.” WGII Sixth Assessment Report, February 2022. Available at:
https://report.ipcc.ch/ar6wg2/pdf/IPCC_AR6_WGII_FinalDraft_FullReport.pdf
Oct. 11, 2022 Item #12 Page 7 of 560
5
removal and storage, thus making net energy system emissions zero.i The RDF’s Technical
Report does not rely on offsets outside the region to reach net zero targets. Importantly,
emissions from other sectors such as waste were excluded from this analysis because they are
outside the defined energy system scope, which accounts for 80% of regional emissions.ii
Nevertheless, there are numerous co-benefits associated with drastically reducing emissions
from other sectors and the emissions reductions and/or co-benefits may also align with State
goals, as with reducing landfill emissions through waste diversion and composting.
The RDF’s Technical Report’s decarbonization pathways were modeled from larger national
and State deep decarbonization scenarios to ensure alignment with Statewide pathways to
decarbonization. Evolved Energy Research (EER) downscaled State and national models to
develop regional models under five scenarios (also referred to as model cases).iii The deep
decarbonization models allow for quantitative comparative analyses of regional policy options
and decarbonization outcomes in different sectors. An example of EER’s modeling outputs for
the energy sector show how the different model cases affect Statewide decarbonization in both
the total installed electricity capacity required (Figure 1) and CO2 emissions from energy and
industry processes through 2050 (Figure 2). Using these downscaled models is also important
because local energy and transportation systems are interconnected with other regions and
states, so regional jurisdictions should collaborate with other regional and state jurisdictions as
they decarbonize.
i Note that the energy system modeling only considers CO2 emissions, whereas the natural climate solutions and
Climate Action Plan analyses consider other greenhouse gases as well (such as methane, nitrous oxides, etc.).
These GHGs are converted to their “carbon dioxide equivalent” (CO2e) for easier comparison.
ii More details on the scope of the study are available in Chapter 1 and Appendix A. More details on the sectoral
contributions to total regional emissions are available in Chapter 8 and in the San Diego Association of Government’s 2021 Regional Plan’s Appendix X (https://sdforward.com/docs/default-source/2021-regional-
plan/appendix-x---2016-greenhouse-gas-emissions-inventory-and-projections-for-the-san-diego-
region.pdf?sfvrsn=8444fd65_2).
iii More details on the model cases can be found in Chapter 1 and Appendix A.
Oct. 11, 2022 Item #12 Page 8 of 560
6
Figure 1. Results for the total installed electricity capacity required in California to reach net zero Statewide
emissions by 2050 under five different model scenarios (or cases) in the EER model. Appendix A offers more
information about the EER model, downscaling, and model scenarios.
Figure 2. Results for CO2 emissions from energy and industrial processes in California from the EER model for five
different scenarios (or cases). Colors above the x-axis represent positive emissions, and colors below represent
offsetting negative emissions. The black line indicates net CO2 emissions. “Product and bunkered CO2” is either CO2
that ends up sequestered in materials (e.g., asphalt sequesters CO2 during its production) or CO2 reductions not
counted in current inventories (e.g., interstate aviation emissions reductions are not included in a single state’s
emissions accounting, but intrastate aviation is).
Oct. 11, 2022 Item #12 Page 9 of 560
7
Experts in renewable energy production, transportation, and buildings modeled technically
feasible decarbonization pathways for the region to create a science-based roadmap of
regional decarbonization to net zero emissions by mid-century. These models focused on
proven, scalable technologies for decarbonizing the region’s largest GHG emitters (Figure 3)
that are within the jurisdiction of local governments and agencies. This excluded technologies in
experimental or early phases because regional authorities cannot immediately deploy them at
scale. Similarly, renewable energy development in State and federal waters were not included
in modeling efforts except to contextualize resource availability in the San Diego region.
Additionally, the RDF’s Technical Report highlights uncertainties in the decarbonization
process and the need for ongoing planning processes that can adapt as the technology and
policy landscapes evolve. For example, increased renewable energy availability from Imperial
County or Mexico may affect the San Diego region’s renewable energy mix, which could avoid
the need to build higher-cost renewable energy infrastructure locally. Similarly, State and/or
Federal development of offshore wind could reduce the need for onshore renewable
infrastructure development in the San Diego region.
Figure 3. Region-wide estimates of the emissions of carbon dioxide equivalent (CO2e) measured in million metric
tons. The “other” category includes emissions from industrial sources, off-road transportation, waste, aviation,
water, etc., which were not considered in the RDF’s Technical Report. Note that 2035 values account for the
impacts of certain State and federal actions. Source: the SANDAG 2021 Regional Plan’s Appendix X, available here:
https://sdforward.com/docs/default-source/2021-regional-plan/appendix-x---2016-greenhouse-gas-emissions-
inventory-and-projections-for-the-san-diego-region.pdf?sfvrsn=8444fd65_2
Oct. 11, 2022 Item #12 Page 10 of 560
8
Key Policy Considerations
The RDF’s Technical Report identifies “low-regret” strategies which provide the best
assessment of the least cost and most effective near-term solutions for reducing emissions in
each sector. These strategies represent robust decarbonization actions in the near-term,
regardless of how uncertain factors resolve, but whether they are the best pathways over the
long term remains unknown (Table 1).
Successful decarbonization requires both technical solutions and policy strategies that can
adapt with changes in scientific understanding and local political and economic conditions.
Effective learning and policy adjustment requires that local actors – both leaders and people on
the front line – first implement initial solutions and then engage in systematic and continuous
review of results to drive meaningful learning about what works and what does not. The “best”
solutions and pathways can and should evolve over time as science and technology advance
and as local actors learn what is effective in the San Diego region.
Table 1 Examples of “Low Regret” Strategies in the Four Sectoral Pathways.
Renewable Energy Siting
● Support distributed solar resources
(including rooftop solar and infill solar in
areas like parking lots), particularly in low-
income communities.
● Begin planning for utility-scale
development in areas identified by most
scenarios (e.g., the planned JVR region).
Transportation
● Encourage denser and mixed-use development
around existing and new trolley stops, transit
corridors, and mobility hubs.
● Electrify fleet vehicles (jurisdictions, agencies,
school districts, etc.).
● Require electric vehicle (EV) hookups in new
construction or additions; streamline building
permits for EV retrofits.
Buildings
● Create incentives for replacing end-of-life
space and water heaters with electric
alternatives.
● Make new buildings “all-electric.”
● Focus on electrifying low-income,
disadvantaged, and rental residences.
Land Use and Natural Climate Solutions
● Protect natural and working lands.
● Bolster carbon farming throughout the region.
● Increase tree, shrub, and plant cover in urban
and suburban areas.
The RDF’s Technical Report proposes region-wide institutional governance to facilitate
continued collaboration and learning across jurisdictions.i Organized into a Regional Steering
Committee, Sector Working Groups, and Front-Line Advisors, this structure would unite
government officials, planning bodies, regulators, industry stakeholders, experts, and front-line
i More information on collaboration and learning across jurisdictions is available in Chapter 7.
Oct. 11, 2022 Item #12 Page 11 of 560
9
workers in each sector from across the region to test, evaluate, and adjust strategies. Such a
structure is necessary because achieving the significant changes and rapid learning needed to
address climate change is a collective action problem. Individually, local jurisdictions and
agencies in the San Diego region have limited authority over the suite of actions needed to
decarbonize. Region-wide cooperation can increase collective impact through clear, credible,
and consistent policy signals, joint problem-solving, pooling of experience about what works,
and greater leverage and capacity from combined resources. As discussed in Chapters 7 and 8,
examples of regional cooperation include setting incentives for action, collecting data,
conducting analyses, supporting policy development and implementation, convening
stakeholder and working groups, and monitoring progress. A Regional Climate Action Joint
Power Agreement (JPA) or other formal mechanism could facilitate such cooperation, thereby
scaling strategic thinking and decision-making around decarbonization. Figure 4 outlines an
institutional process through which regional governance, informed by the technical solutions
proposed in the RDF and ongoing stakeholder engagement, can drive meaningful learning in
each sector.
Within this institutional process, the RDF’s Technical Report also proposes two strategies for
engaging with actors and agencies beyond the San Diego region to maximize impact within
the region. First, regional decarbonization leaders must engage continually with outside
agencies, especially at the State level, to influence policies that affect local efforts (e.g.,
renewable energy regulations). Second, local leaders should leverage the region’s technology-
focused private sector and multiple universities to establish the San Diego region as a test bed
for pilot and demonstration projects. While regional-scale investments in innovation alone are
unlikely to dramatically impact technological readiness across all sectors, local testing and
deployment of technologies developed elsewhere can contribute to the global effort to push
the frontier of science on climate solutions. External engagement not only supports local
emission reductions, but also promises to bring outside resources and attention from State and
federal policymakers, with potential positive effects on the local economy.
Oct. 11, 2022 Item #12 Page 12 of 560
10
Figure 4. The RDF’s Technical Report as part of an Integrated Decarbonization Framework and institutional
structure. This structure could include San Diego’s regional governance bodies and a conference of governments,
for example.
In sum, the RDF proposes institutionalizing a highly transparent, cooperative process for
eliciting new information about "what works" with deep decarbonization, comparing best
practices within the region, and engaging outside the region with policymakers, industry
stakeholders, and other experts contributing to the evolution of national strategies. These
not only maximize local emissions reductions, but also enable the San Diego region to influence
State and federal climate policy and become an effective leader for other jurisdictions. The San
Diego region makes up just 0.08% of global emissions, so generating followership represents
the region’s best route to truly make an impact on mitigating climate change.
Oct. 11, 2022 Item #12 Page 13 of 560
11
Decarbonizing Electricity
The RDF’s Technical Report identifies low-environmental-impact, high-quality, and technically
feasible areas for renewable energy infrastructure development in the San Diego region and
neighboring Imperial County. Electricity emissions accounted for approximately 20% of the
2016 Regional Greenhouse Gas Emissions Inventory for the San Diego region and comprise the
second largest emissions source in the region (Figure 3). Decarbonizing electricity production
will require substantial deployment of new renewable resources. Siting renewable energy
infrastructure and facilities can have significant impacts on the environment and will require
new and upgraded transmission infrastructure. Thus, the RDF includes a series of scenarios with
different land footprints that are meant to inform the political discussions in jurisdictions across
the region on the trade-offs regarding land use and renewable energy costs.
The San Diego region has sufficient available land area for wind and solar generation to
approach a fully decarbonized energy system in line with the California-wide system model.
However, meeting standards for reliability will require significant, but uncertain, investments
in a suite of additional resources, including excess intermittent and flexible generation,
storage, and demand-side management. The region can produce the projected 2050 energy
demand of 49,979 gigawatt hours (GWh) per year with local utility-scale onshore wind and solar
development (Table 2). However, demand for energy may be higher or lower than the
renewable energy supply at a given time (for example at night or on cloudy days), necessitating
investments in additional energy storage infrastructure to supply reliable renewable energy to
the region. However, the costs of these additional resources, such as batteries and pumped
storage hydropower, remain highly uncertain.
Levelized Cost of Energy (LCOE), which is the adjusted cost of electricity production per
megawatt hour (MWh) that includes transmission costs, was used as a metric to compare
project costs. LCOE allows for both direct comparison of projects and flexibility as
uncertainties are resolved and as infrastructure (power plants, transmission lines,
interconnections, etc.) is built. LCOE can estimate the wholesale cost of electricity for utility-
scale projects. LCOE includes costs of initially building the wind or solar plant and the cost of
interconnecting that project to the grid, which are divided by total energy production to get a
cost per unit of energy output. Transmission costs are included in the project capital costs and
are based off the California Independent Systems Operator (CAISO) Transmission Planning
Process documents. LCOE is a way to compare different types of energy projects based on a per
unit of energy produced. For example, LCOE metrics make it possible to compare a solar power
plant to a natural gas power plant based on cost per MWh that it can produce.
Oct. 11, 2022 Item #12 Page 14 of 560
12
Table 2. Candidate project areas (CPAs) and total annual resource potential in San Diego County and Imperial
County. Utility-scale resources refer to large scale projects for solar, wind, and geothermal resources. Other
resources are from smaller scale projects, including rooftop solar, infill solar or wind, and brownfield solar or wind.
Geothermal CPAs are discrete areas and are listed as the number of potential sites rather than by their total area.
Total annual demand for the San Diego region by 2050 is estimated as 49,979 GWh.
San Diego County San Diego County + Imperial County
Findings
Utility-
Scale Only
With Rooftop, Infill,
and Brownfield
Utility-
Scale Only
With Rooftop, Infill,
and Brownfield
Solar
Area (sq km) 661 985 3,417 3,741
Potential (GWh) 54,784 102,925 84,888 109,742
Onshore Wind
Area (sq km) 86 86 3,712 3,749
Potential (GWh) 730 730 22,540 22,572
Offshore Wind
Area (sq km) 1,660 1,660 1,660 1,660
Potential (GWh) 9,869 9,869 9,869 9,869
Geothermal
Number of sites 0 0 5 5
Potential (GWh) 0 0 10,680 10,680
Total Renewable Resource
Potential (GWh) 65,382 113,523 117,296 142,183
Electricity Resource Balance (GWh) 15,403 63,544 67,317 92,204
The RDF’s Technical Report creates multiple site-selection scenarios for renewable energy
infrastructure to inform decision-making. These include least-cost scenarios; scenarios that
include Imperial County solar, wind, and geothermal resources; scenarios that minimize
impacts to different land types; and scenarios with different mixes of wind and solar
resources (both distributed and utility-scale) in urban, greenfield, and brownfield sites. The
least-cost scenarios (Scenarios 1 and 2) selected utility-scale renewable energy sites from
lowest to highest LCOE. Additional scenarios prioritize different policy goals such as avoiding
certain lands (Scenarios 3 – 5) or prioritizing development on certain lands (Scenarios 6 and 7).
Other scenarios combine resources and policy priorities (Scenarios 8 and 9). The scenarios are
as follows (see Table 3 for values):i
1. Least-cost, high local capacity (San Diego county only) (Figure 5);
2. Least-cost, high transmission deliverability (San Diego and Imperial counties) (Figure 6);
3. Minimize Loss of Land with High Conservation Value (Figure 7);
4. Minimize Loss of Land with High Monetary Value;
5. Minimize Loss of Land with High Carbon Sequestration Potential;
6. Utilize only Developable Land;
i See sections 2.4.5 and 2.4.6 for descriptions of the data and methods for site and candidate project area
selection. See sections 2.5.1 and 2.5.2 for scenario results, discussion, and maps.
Oct. 11, 2022 Item #12 Page 15 of 560
13
7. Infill and Rooftop Solar Scenario;
8. Mixed Mode Scenario (includes a combination of developable areas in the region and
nearby areas with transmission upgrades, nearby geothermal, rooftop solar, brownfield
solar and wind, and battery storage) (Figure 8); and
9. Maximize Rooftop Solar, Minimize Impact to Conservation and Agricultural Lands.
Table 3 Scenario summary of renewable energy resource potential and energy deficit with predicted demand. All
values are in GWh. The “deficit with demand” values are based on the EER model’s Central Case annual demand estimates of 49,979 GWh for the San Diego region by 2050.
Scenario
number Scenario Description
Resource
Type
Resource
Potential
(GWh)
Excess (Deficit)
with Demand
(GWh)
Scenario 1 Least-cost (San Diego county only) Solar, Wind 49,979 –
Scenario 2 Least-cost (San Diego and Imperial counties)
Solar, Wind,
Geothermal 49,979 –
Scenario 3 Low Environmental Impact Solar, Wind 15,777 (34,202)
Scenario 4 Low Land Value Solar, Wind 52,394 2,415
Scenario 5 Carbon Sequestration Potential Solar, Wind 22,844 (27,135)
Scenario 6 Developable Solar, Wind 13,894 (36,085)
Scenario 7 Rooftop and infill solar Solar 17,478 (32,501)
Scenario 8
Mixed-mode resource mix (San Diego and
Imperial counties)
Solar, Wind,
Geothermal 50,147 168
Scenario 9
High Rooftop, Low-Impact to Conservation
Lands, Avoid Valuable Agriculture Lands (San
Diego and Imperial counties) Solar, Wind 44,177 (5,802)
Oct. 11, 2022 Item #12 Page 16 of 560
14
Figure 5. Scenario 1: Least-cost scenario in the San Diego region only. This analysis selects utility-scale solar and
onshore wind resources from lowest to highest cost to meet projected energy demand. The three panels show the
build-out required by each year that would allow the region to approach full energy decarbonization by 2050.
Lighter colors represent Candidate Project Areas (CPAs) that would be built earlier because they are less expensive.
Blue colors are wind resources and orange/red colors are solar resources. This scenario has an average levelized
cost of energy (LCOE) of $40.65 per megawatt hour (MWh).
Oct. 11, 2022 Item #12 Page 17 of 560
15
Figure 6. Scenario 2: Least-cost scenario in San Diego and Imperial counties. This analysis selects solar, onshore
wind, and geothermal resources from lowest to highest cost to meet projected energy demand. These maps show
build out over three time periods where colors represent build out year (lighter colors are earlier) and resources
(red/orange for solar, blue for wind, and green for geothermal). The inset shows the Jacumba Hot Springs area site
selection by 2050 and the area that includes the proposed/planned Jacumba Valley Ranch (JVR) sites. This scenario
has an average LCOE of $42.04 per MWh.
Figure 7. Scenario 3: Exclude land with high conservation value. This scenario minimizes impacts to areas of high
conservation value and other areas that are environmentally sensitive or important. It does not meet regional
energy demand and is relatively more expensive (with an average LCOE of $84.5 per MWh).
Oct. 11, 2022 Item #12 Page 18 of 560
16
The mixed-mode scenario utilizes a mix of proven, scalable technologies that are within the
jurisdictions of San Diego county, Imperial county, or regional entities to build in order to meet
regional demand both in the near-term (2025) and by mid-century (shown in Figure 8). The
technologies include brownfield infrastructure development (solar and wind infrastructure built
on currently or formerly contaminated sites); utility-scale solar and wind in both San Diego and
Imperial counties; rooftop and infill solar (where “infill solar” is defined as solar projects built in
dense, urban settings); and geothermal (which is a clean source of baseload power that does
not rely on wind, sun, or other variable energy sources).
Figure 8. Scenario 8: Mixed-mode Scenario 2050. This figure shows sites selected to meet the 2050 electricity
demand using a variety of resources: 12% rooftop solar, 23% brownfield solar, 0.1% brownfield wind, 6% utility
scale solar on developable land in San Diego county, 0.4% utility-scale wind on developable land in San Diego
county, 38% Imperial solar, 21% Imperial geothermal. The addition of rooftop solar and brownfield resources
together results in 35% reduction in land area impacts. This meets regional energy demand, but it has a high
average cost (with an average LCOE of $109/MWh) partly because of the high costs of rooftop and brownfield
development, as well as the high cost of geothermal.
There are some commonalities across scenarios in the results, suggesting that these might be
“low-regret” renewable energy infrastructure options. The geospatial analyses of renewable
energy siting have demonstrated that rooftop solar, infill solar, and brownfield development
reduce overall land use change in natural and working lands. Additionally, these resources can
bring co-benefits to communities, such as pollution reduction and economic opportunities.
Thus, despite the relatively high costs compared to utility-scale development, building
distributed and urban renewable resources are low-regret strategies that have low impacts on
Oct. 11, 2022 Item #12 Page 19 of 560
17
habitats, agriculture, and rural communities and can provide attractive job training
opportunities where few such opportunities currently exist relative to utility-scale
development.i
Given the high commercial interest and relative proximity to planned or existing renewable
sites, the models highlighted the Jacumba Valley Ranch (JVR) renewable area in most scenarios.
State planning proceedings favor this area, including those by the CAISO (California’s grid
operator) and the California Public Utilities Commission (CPUC), and it may represent a low-
regret scenario for utility-scale infrastructure expansion. These scenarios are not prescriptive
and any policy decision will require careful consideration of environmental justice and a deeper
understanding of the effects that these energy developments will have on communities of
concern, low-income communities, rural communities, and/or disadvantaged communities.
Imperial County has significant solar and geothermal resources that could provide energy to
the San Diego region, but this may require upgrades to the transmission network. As
renewable energy infrastructure develops in neighboring areas – such as Imperial County,
Mexico, or offshore – the site selection scenarios will change in iterative energy supply and
demand analyses. Similarly, as new technologies and permitting make additional renewable
energy resources available (e.g., offshore wind, wave energy, etc.), the scenarios must update
to account for the energy supply from those novel resources (see Table 3 for geothermal and
offshore wind values). This framework is flexible enough to account for additional renewable
energy supply as it becomes available.
The region should coordinate with State agencies to ensure the reliability of the system. The
San Diego region is a part of a larger energy system network, so coordination across agencies
must underpin decision-making, planning, and implementation of renewable energy
infrastructure into the future. For example, there are State-level Integrated Resource Plan (IRP)
proceeding at the CPUC. Load Serving Entities (LSEs) throughout the State are Parties to this
proceeding, and local LSEs, such as San Diego Gas and Electric (SDG&E) and Community Choice
Aggregators (CCAs), are required to submit annual procurement plans. These submittals help
the State anticipate potential reliability issues and help the CAISO plan transmission upgrades
needed to accommodate the LSE plans and climate goals. LSE submissions to the CPUC should
indicate their expected local distributed generation, rooftop solar, community solar, equity-
eligible contractor projects, or other specifications. Additionally, regional government officials
often serve on CCA boards and participate in procurement, planning, and target setting. Board
i See the complementary workforce development report by Inclusive Economics, Inc. for a larger discussion on the
job quality and access characteristics of utility-scale renewable energy versus distributed energy. The report, titled
“Putting San Diego County on the High Road: Climate Workforce Recommendations for 2030 and 2050,” is available on the County’s website: https://www.sandiegocounty.gov/content/dam/sdc/lueg/regional-decarb-
frameworkfiles/Putting%20San%20Diego%20County%20on%20the%20High%20Road_June%202022.pdf.
Oct. 11, 2022 Item #12 Page 20 of 560
18
members can help ensure that LSE plans are implemented for consistency with regional and
State GHG reduction targets. This is especially important where local targets are more
ambitious than State targets.
Beyond the IRP, there are additional State agency proceedings which could benefit from input
from local players (e.g., the CPUC Resource Adequacy proceeding, CAISO Transmission Planning
Process, and the CAISO Local Capacity Requirements proceeding). In the Resource Adequacy
proceeding, CPUC staff analyze power grid reliability. In the Transmission Planning Process, the
CAISO assesses reliability, policy compliance, and cost-effectiveness of planned transmission
system upgrades. In the Local Capacity Requirements proceeding, the CAISO conducts a more
local reliability analysis than other proceedings. For example, Section 3.3.10 of the CAISO 2022
Local Capacity Technical Study is devoted to the San Diego-Imperial Valley region. LSEs such as
SDG&E, San Diego Community Power, and Clean Energy Alliance should coordinate on
procurement, resource adequacy and other issues addressed in these proceedings.
Numerous State goals affect electricity decarbonization, including requirements for rooftop
solar on certain new buildings, requirements for a fully decarbonized electricity system by
2045, and allowances for additional decarbonization efforts beyond State goals. Electricity
decarbonization is the most common CAP measure analyzed and on average contributes more
GHG reductions than any other measure. Most CAPs include a measure to form or join a CCA
program, and additional jurisdictions can increase CCA participation or commit to 100% carbon-
free energy prior to the State 2045 deadline. Additionally, local efforts can enhance or
complement State rooftop solar requirements by adopting reach codes (regulations that go
beyond State requirements) and evaluating mandates or incentives for energy storage systems
paired with rooftop solar to decrease marginal emissions during the electric system’s peak GHG
emission and increase reliability.
Additional work would be needed to make carbon-free electricity supply more accessible.
Historically, rooftop solar has been installed in higher-income neighborhoods and in areas with
higher levels of homeownership. Numerous levers could address the inequitable distribution of
rooftop solar installations, including targeted incentives and financing. Additionally, CCA
programs can maximize participation in the Disadvantaged Communities Green Tariff Program,
subsidize customers in income-qualified discount programs to opt-up to 100% carbon-free
electricity service options, and support inclusive financing for energy upgrades.
Legal authority to regulate energy production:i Jurisdictions in the San Diego region have the
authority to require levels of carbon-free electricity supply through CAPs and procure carbon-
i See Chapter 8, section 8.7 “Decarbonize the Electricity Supply” and Appendix B for further discussion of legal
authority.
Oct. 11, 2022 Item #12 Page 21 of 560
19
free electricity supplies through CCAs and can therefore supply more carbon-free energy than
required by State agencies. However, State and/or federal agencies or entities still regulate
local energy supplies for reliability, which complicates fully decarbonizing the electricity supply
with renewable energy. Additionally, local jurisdictions are also authorized to support
alternatively fueled thermal power plants and related infrastructure that can provide low- or
zero-emission electricity to meet reliability and air quality requirements (e.g., green hydrogen
production and/or power plants). Local jurisdictions are also authorized to streamline
permitting and increase distributed generation through CCAs and reach codes. Further
regulating most fossil-fueled thermal power plants emissions is limited given current State
regulation and uncertainty over federal preemption.
Decarbonizing Transportation
The transportation sector is the largest contributor to regional GHG emissions. In 2016, on-
road transportation was responsible for almost half of regional emissions. In 2035, emissions
from on-road transportation are projected to account for about 41% of the total projected
emissions (Figure 3).i Statewide legislation, executive orders, and State agency targets have set
GHG reduction goals to address these emissions. Additionally, the San Diego region has
implemented measures to reduce regional transportation GHG emissions, including a variety of
vehicle miles traveled (VMT) reduction and vehicle electrification strategies.
The region has a strong policy foundation for reducing emissions related to transportation.
However, current commitments through CAPs and other policies are inconsistent with the
scale of reductions required by State executive orders for carbon neutrality. Even the best
CAP commitments to reduce on-road transportation emissions through VMT reduction, EV
adoption, and fuel efficiency strategies, if applied to the whole region, are not projected to
achieve the State’s zero emissions goals.
Opportunities to accelerate EV adoption and VMT reduction exist based on current regional
policies and patterns of vehicle ownership, travel behavior, and land use development.
Current policies and consumer, driver, and developer behaviors are already increasing EV
adoption and reducing VMT. However, there are additional opportunities to accelerate regional
transportation decarbonization. To reduce VMT, jurisdictions can focus on high-density
development around transit corridors, rail, and trolley stations, and enhance transit and active
transportation (e.g., biking and walking). Adopting “smart growth” policies improves urban and
suburban connectivity, encourages mixed-use developments, shortens trip lengths by changing
i See Chapter 8, section 8.5 for a detailed analysis of CAP commitments as they relate to transportation. Note that
this value includes projected EV sales changes but does not include CAP measures.
Oct. 11, 2022 Item #12 Page 22 of 560
20
zoning, and disincentivizes free parking.i To further reduce emissions, jurisdictions can establish
and enforce existing anti-idling requirements (especially around schools), identify areas for
traffic calming measures, and provide driver behavior incentives. Further, local jurisdictions can
affect vehicle retirement, which can be prioritized in communities of concern to rapidly reduce
local air pollution burdens. Finally, local governments can increase adoption of zero-emission
vehicles (ZEVs) through provision of public EV charging stations and use of alternative, low-
carbon fuels and EVs, particularly for medium-and heavy-duty vehicles, in existing and future
fleets. Figure 9 shows a menu of policy opportunities to increase ZEV adoption, illustrating
policy options that range in both effectiveness (i.e., how well the policy increases ZEV adoption)
and breadth (i.e., how many people it reaches).
Figure 9. A spectrum of policy options to accelerate ZEV adoption. Policies are likely to be more effective moving
right and are likely to have a broader application moving down. Thus, the bottom right is predicted to be the most
effective and to have the broadest application of the policy measure shown where the top left is predicted to be
the least effective and to have the narrowest application of the policy measures shown.
Multiple opportunities for regional collaboration and coordination exist. The nature of on-
road transportation and of existing institutions that coordinate transportation decisions suggest
that regional collaboration on transportation decarbonization will be more effective than
individual CAP measures. CCAs provide an example of a local mechanism, usually through JPAs,
i Opportunities to increase density in in-fill areas have been identified in Chapter 3. Chapter 8 offers more details
on how to reduce VMT.
Oct. 11, 2022 Item #12 Page 23 of 560
21
that can support transportation electrification by developing programs to locally incentivize EV
uptake beyond State and federal programs. Similarly, other regional collaboration efforts may
be identified which can promote local funds for transportation decarbonization. Local
jurisdictions can further collaborate to assess the equitability and effectiveness of investing in
EV deployment versus increased mass transit in various communities and align regional
transportation equity analyses (e.g., SANDAG’s equity analyses) with CAP equity analyses (e.g.,
the City of San Diego’s equity analyses).
Legal authority to regulate transportation decarbonization:i Local jurisdictions and agencies in
the San Diego region have broad authority over transportation, based both on locally derived
land use authority over planning and development and based on delegated State and federal
authority. However, such delegated authorities can be limited or preempted by State or federal
laws, as with fuel and tailpipe emission regulations. Through their authorities, local jurisdictions
can establish climate change policies and regulations to reduce GHGs from transportation in
general plans (GPs), CAPs, zoning, or transit-oriented development regulations. Further, they
can require infrastructure for fuel switching in buildings (e.g., EV charging equipment), build
supporting infrastructure in public right-of-ways or on public land, and support alternative fuel
production and infrastructure, such as hydrogen. Local jurisdictions can regulate their own
fleets through purchasing, maintaining, or changing their fleets. They also have the authority to
regulate indirect transportation emissions to keep local emissions in line with federal and State
air quality standards. State statutes and regulations create an opportunity to align local action
that decreases implementation costs by bringing State funded projects to the region,
particularly in communities of concern, and deploying technology developed by State or federal
funding. Finally, jurisdictions appear to have additional legal authority through land use,
transportation infrastructure siting, delegated authority, and taxation powers to reduce
transportation GHGs than represented by commitments in CAPs. Assessing the limits of local
authority to increase on-road transportation GHG reductions requires additional work.
i See Chapter 8, section 8.5 “Decarbonize Transportation” and Appendix B for further discussion of legal authority.
Oct. 11, 2022 Item #12 Page 24 of 560
22
Decarbonizing Buildings
The RDF’s Technical Report studies the building mix and associated emissions from the region’s
infrastructure and building sector. Direct emissions from buildings come from on-site fossil fuel
combustion and contribute to regional GHG emissions (Figure 3). This analysis focuses on
electrifying systems responsible for end-use emissions, like space and water heating, and using
lower-carbon fuels (such as biomethane and hydrogen) where electrification is not yet feasible.
The chapter considers three modeled pathways to reach a carbon-free building sector by 2050:
a pathway emphasizing high electrification of fossil-fuel systems, a pathway with highly efficient
electric heat pumps, and a pathway using low-carbon fuels to reduce emissions in the interim
while electrification occurs more slowly.i
There are several near-term, low-regret actions for building decarbonization. First, replacing
end-of-life fossil fuel heating systems with electric versions is a near-term priority, as some
existing fossil fuel systems will only turn over once by 2050. Second, setting “electrification-
ready” or “all-electric” standards for new construction and major renovations through building
energy codes will reduce costs associated with transitioning away from fossil fuels. Third,
improved data gathering represents a low-cost, foundational action for future policy
development. More data on building emissions and decarbonization will better inform decision
makers crafting policies for the building sector’s contributions to a net zero region.
Replacing fossil fuel-based space heating and water heating systems with electric systems
should be a primary policy focus for building emission reductions. Space heating and water
heating together consume the vast majority of the natural gas supplied to residential buildings
in the SDG&E service area (Figure 10). Commercial buildings are more varied in their energy
consumption (Figure 11), but space and water heating still consume a large portion of total
energy, and around two-thirds of commercial buildings space heaters use natural gas. Replacing
space and water heating systems and other fossil fuel-based systems like ovens and dryers with
electric versions will yield significant building decarbonization. Current heat pump technologies
for space and water heating are readily available and outperform natural gas systems by
providing more heating per unit of energy used, making these systems especially conducive to
electrification. For building temperature regulation, electric heat pumps offer both heating and
cooling from the same unit, making them ideal for homes that do not yet have air conditioning.
Thus, regional policies should support adoption of efficient heat pump-based space and water
heating systems to replace fossil fuel-based systems in both new and existing buildings.
Additionally, policies aimed at replacing fossil-fuel based space and water heating systems
should focus assistance efforts on increasing uptake among low-income residents and rental
i More details on the modeled pathways are available in Chapter 4, section 4.4 and elsewhere in the chapter.
Oct. 11, 2022 Item #12 Page 25 of 560
23
building owners. Such policies would address historic inequities in housing quality,
environmental injustice, health disparities due to indoor air pollution, and utility costs. Further,
they would ensure that building decarbonization includes low-income residents and renters,
rather than leaving them to pay increasingly higher gas rates.
Figure 10. Average annual natural gas usage (measured in therms) by end use and by utility for households who
use gas as the primary fuel for major end uses. Source: DNV GL Energy Insights (2021). 2019 California Residential
Appliance Saturation Study (RASS).
Figure 11. San Diego regional energy end-use profiles by commercial building type. Percentages are relative to
total end-use energy within each building sector. Annual energy consumption, measured in metric million British thermal units (MMBTU), for each building type is shown in blue at the top of the figure. Water heating is in light
gray (third from the bottom in each bar) and space heating is in medium gray (second from the bottom in each
bar). Natural gas consumption per system varies by commercial building type, but space and water heating are still
significant natural gas consumers, as is visible in the leftmost column (“Total”). Source: Synapse model.
Oct. 11, 2022 Item #12 Page 26 of 560
24
Policies for decarbonizing existing and new buildings are crucial. 80% of the buildings that will
exist in 2050 have already been built, so decarbonizing the building sector requires
decarbonizing the current building stock. While State building codes, like Title 24, regulate
building alterations and additions to certain existing structures, local policies could further
encourage or require energy efficiency and electrification in many other places.i For instance,
decarbonizing municipal buildings through cost-effective electrification should reduce
operation costs and may encourage property owners to follow suit, making it a low-regret
policy.
To decarbonize new buildings, jurisdictions can set local “electrification-ready” or “all-electric”
standards for new construction. Policymakers can benefit from lessons learned in the adoption
of all-electric reach codes or ordinances—which are local codes or ordinances that go beyond
state or federal requirements codes or ordinances—in the cities of Carlsbad, Encinitas, and
Solana Beach.
Low-carbon gaseous fuels can be used for hard-to-electrify end uses, though research and
piloting are required. Some building systems are hard to fully electrify, so one way to reduce
GHG emissions from those systems is to use fuels that do not emit net GHGs into the
atmosphere.ii Similarly, such fuels can be used for these or other systems prior to electrifying
them. Low-carbon gaseous fuels could include biomethane and/or hydrogen. However, each of
these alternate fuels have cost and efficiency trade-offs as well as uncertainties, requiring more
research and piloting before implementation.
Minimizing unnecessary extensions or replacements of the gas pipeline system and
accelerating depreciation of existing utility assets mitigates the gas utility’s risk of not
recovering its investment in assets (i.e., its stranded cost risk). Phasing out end-use natural gas
consumption in buildings can lead to stranded assets, defined as infrastructure that is shut
down before the end of its useful life. For companies like SDG&E, stranded assets represent
potential financial losses because of the high capital costs to build or replace gas infrastructure.
Mitigating these stranded assets will be an important policy consideration.iii One step is to
minimize unnecessary pipeline extensions or replacements. Policies requiring full electrification
in new construction would mitigate stranded asset losses for pipe investments going to new
i See Chapter 8, section 8.6, for more details on examples of local authorities decarbonizing existing buildings. Also
see Chapter 7 section 7.3.1 for a local example.
ii One such example are district energy plants that provide high-temperature steam or hot water to geographic
clusters of buildings. There are several such systems in the San Diego region that serve military bases, hospitals, or
universities. System operators should evaluate the relative costs and benefits of low-carbon fuels and electric
heating technologies (such as high-capacity heat pumps, heat recovery chillers, and electric boilers). iii At the time of this writing, the Public Utility Commission is evaluating key aspects of long-term natural gas
planning in California under proceeding R2001007.
Oct. 11, 2022 Item #12 Page 27 of 560
25
customers, but not from replacing aging infrastructure. Exploring and piloting non-pipeline
alternatives to both new and replacement infrastructure, including electrifying end uses instead
of replacing infrastructure, could identify opportunities to mitigate risk.
CAPs have relatively few measures to electrify buildings and the GHG impact of those
measures is relatively low, despite the sector’s importance to regional decarbonization. Only
seven CAPs in the San Diego region include measures related to building electrification and the
GHG reductions in CAPs associated with efficiency and electrification are relatively low.i
Compared to the level of electrification needed in both new and existing buildings as outlined in
Chapter 4, the CAP measures fall short of the building decarbonization pathway findings in the
RDF’s Technical Report.
There is an opportunity and a need to assess social equity considerations of building
decarbonization policies. Replacing appliances is expensive, so building decarbonization
policies should account for incentivizing electrification equitably, especially in communities of
concern, low-income communities, rural areas, and for renters. Developing the capacity and
tools to understand and address the equity implications of building decarbonization policies in
the San Diego region requires additional work.
Legal authority to regulate building decarbonization:ii Local jurisdictions have the authority to
regulate GHG emissions from building end-use of fossil fuels and other energy sources, which
represents the primary means of decarbonizing buildings. Local jurisdictions also act with
delegated authority over the built environment to require more stringent energy codes, directly
regulate air pollution emissions from buildings, and procure alternate energy supplies in public
buildings. Additional authority may come from the California Environmental Quality Act (CEQA)
by setting more stringent thresholds to determine environmental impact. Local governments
are preempted from establishing energy efficiency appliance standards, regulating natural gas
supply, transmission, and storage, and high global warming potential refrigerants (e.g., HFCs).
i See Chapter 8, Figure 8.33 for details on CAP commitments relating to building electrification.
ii See Chapter 8, section 8.6 “Decarbonize Buildings” and Appendix B for further discussion of legal authority.
Oct. 11, 2022 Item #12 Page 28 of 560
26
Natural Climate Solutions
The RDF’s Technical Report investigates the natural climate solutions (NCSs) available in the San
Diego region and their potential to naturally sequester and store CO2 and other GHGs. NCSs are
processes that protect or enhance natural and working lands’ (NWLs) ability to capture and
store GHGs from the atmosphere through plants and soils or reduce emissions from NWLs.
“Working lands” include agricultural lands like orchards, vineyards, pastures, nurseries,
rangelands, croplands, etc. “Sequestration” is an annual measure of how many GHGs are
removed from the atmosphere and “storage” is the total amount of GHGs that have been
sequestered in plants and soils. Existing carbon stocks (Figure 12) are generally stable and can
store carbon for decades if left undisturbed, so careful regional planning can minimize land use
change that would emit this stored carbon. By understanding a landscape’s carbon storage and
sequestration potential, areas with high levels of stored carbon can be preserved as such and
areas with high sequestration potential can be protected.
Figure 12 Total stored carbon (metric tons (MT) of CO2 equivalent per hectare (ha)) estimates for the San Diego
region. Darker colors represent larger carbon stock estimates and lighter colors represent lower stock estimates.
Regionwide storage totals per vegetation category were calculated from these values and are in Table 5.2. Note
that eelgrass beds were not included because they were not included in the SanGIS shapefiles. However, eelgrass
beds are prevalent in both Mission and San Diego bays and are important blue carbon habitats.
Oct. 11, 2022 Item #12 Page 29 of 560
27
Regional NWLs sequester and store large amounts of carbon dioxide, although not enough to
account for human-caused emissions. NWLs can act as stronger net sinks than they currently
do, though this will require investments in bolstering NCSs and minimizing carbon emissions
from land and land use activities. To accurately account for net carbon land use emissions,
local data need to be collected and integrated into regional carbon calculations. The region
can expand annual carbon sequestration and long-term carbon storage through investing in
NCSs that both increase natural sequestration and reduce emissions from the land, such as
protecting NWLs; investing in “carbon farming;” restoring and expanding “blue carbon”
habitats; planting trees and other plants in urban areas; preventing large-scale, destructive
wildfires; and planting trees in NWLs or otherwise restoring them. Collecting and integrating
local data into NCS policies, incentives, and management techniques can increase regional
sequestration.
Avoiding land use changes by protecting natural and working lands represents the most
effective and inexpensive NCS policy in the San Diego region, except where other
decarbonization actions necessitate land use change (such as siting renewable energy
infrastructure). Existing natural and working lands are natural carbon sinks, so preventing
urbanization of these lands allows for continued annual sequestration and prevents one-time
emissions from vegetation removal, soil disturbance, etc. This report estimates that natural
annual sequestration in NWLs may be up 2 million metric tons (MMT) of CO2 under ideal
circumstances and that there may be 58 MMT of CO2 stored in vegetation, woody debris, leaf
litter, and soils, some of which would be released with land use change.
Housing development and renewable energy infrastructure siting are important activities and
will require some land use change. Implementing these changes to minimize impacts on NWLs
with large natural carbon stores, high sequestration potential, and/or high co-benefits (such as
habitats that improve air and water quality, protect biodiversity, and support public health) will
be critical.
Other important regional NCSs considered by the RDF’s Technical Report may be less
effective and/or more expensive for carbon sequestration, though they yield important co-
benefits. These include carbon farming (farming practices that increase carbon sequestration
and storage and minimize GHG emissions on agricultural lands), increasing wetland extent and
quality (through protection, restoration, and expansion), and urban forestry and greening.
Wildfire prevention will also be important for emissions and numerous other economic,
ecological, and social reasons. Large-scale habitat restoration and reforestation, which were not
considered in this report, are expensive and may not be effective. Other NCS options require
significant capital investments and typically have smaller short-term sequestration returns than
preservation.
Oct. 11, 2022 Item #12 Page 30 of 560
28
NCSs offer quantifiable co-benefits beyond decarbonization. Each of the analyzed NCSs offer
numerous quantifiable co-benefits. These co-benefits include, but are not limited to: improved
air and water quality, improved public health outcomes, biodiversity protection, ecosystem
functioning protection, reduced heat island effects through shading, improved aesthetics in
urban areas, decreased water and fertilizer requirements on farms and rangelands, and the
potential to increase environmental justice. These co-benefits should be considered when
crafting and implementing policies to build ecological, economic, and social resilience.
All NCS decisions must center on equity considerations. NCSs should be viewed through both
decarbonization and equity lenses. Whenever possible, urban greening, tree planting, climate
farming, and habitat restoration projects should prioritize communities of concern because
these NCSs have outsized co-benefits of improving air and water quality as well as human
health. NCSs can help address historic inequities and environmental injustice.
The only quantified CAP measure relevant to this pathway is urban tree planting, but there
are opportunities to implement additional NCSs in a collaborative way. Additional measures
are possible under local land use authority. Tree planting measures contribute on average just
over 1% of local GHG reductions in CAPs. Jurisdictional collaboration can enhance this.
Additional NCS CAP measures are possible under existing authority and can contribute to land
conservation, preservation, and restoration on natural and working lands. Private landowners
and tribal governments can also preserve land, test and fund pilot projects for carbon removal
and storage, and collaborate with public agencies. Collectively, there is an opportunity to
expand protections for natural and working lands to fulfill the new California Senate Bill 27
(2021) mandate that calls for establishing NWL carbon removal and storage projects.
There are also opportunities to include local data in land management and planning and in
CAPs. For instance, CAPs can utilize both publicly available data from agencies and universities
and publicly available carbon accounting methodologies from agencies like the California Air
Resource Board (CARB) to create stronger goals and measures. Additionally, the region can
implement regular carbon accounting and track carbon stocks in NWLs over time to understand
emission, preservation, and storage trends with land use decisions.
Legal authority to regulate negative emissions from NCSs and land use:i It remains unclear
whether local jurisdictions’ ability to use their authority over land use, zoning, land
preservation, and agricultural easements extends to activities on private natural and working
land beyond land use designation that would affect GHG emissions or sequestration. The
region’s land use jurisdiction is further complicated because it is composed of federal, State,
tribal, and privately held land, submerged land, and waters. Various statutes and agencies
i See Chapter 8, section 8.8 “Natural Climate Solutions” and Appendix B for further discussion of legal authority.
Oct. 11, 2022 Item #12 Page 31 of 560
29
regulate different land types, with none focused on GHG emissions or sequestration as it
relates to land use. State land use and regulating agencies also operate with a wide range of
statutory mandates, which apply to lands under multiple jurisdictions and impact GHG
emissions and accounting. California's statutes and executive orders require State land use
agencies to account for GHG emissions from natural and working lands. Additionally, these
State agencies are beginning to assess and regulate carbon removal and storage on these lands
with significant targets in 2030. An opportunity exists for local jurisdictions to work with
landowners and managers to achieve State, regional, and local goals related to NWLs.
Employment Impacts of Decarbonization for the San Diego Region
The RDF’s Technical Report calculates the net change in energy sector jobs in response to the
Central Case of the modeled decarbonization pathways from the EER model. Following
California’s Jobs and Climate Action Plan for 2030, the analysis focuses on employment changes
from 2021-2030 to inform workforce development strategies. Additionally, this report analyzes
overall average annual job creation from 2020-2050, based on the full timeline in the EER
model. For phasing out fossil fuels and modeling associated job losses, the analysis focuses on
the 2021-2030 period, where the Central Case of the EER model estimates modest reductions in
fossil fuel-based activities. This primarily stems from the model’s estimates of steady natural
gas consumption and a 20% decrease in oil consumption by 2030 relative to current levels. The
RDF’s Technical Report focuses on quantitative employment impacts resulting from deep
decarbonization efforts in the energy, building, and transportation sectors and informs a report
by Inclusive Economics on workforce development strategies.i
Between 2021 – 2030, the Central Case decarbonization pathway would generate an average
of nearly 27,000 direct, indirect, and induced jobs per year in the San Diego region. These new
jobs will be created by expenditures on energy demand (Table 4) and supply (Table 5), which
contribute roughly equally to total annual job creation.ii Note that significant labor
opportunities in the fossil fuel sector continue through 2030.
i The Inclusive Economics report titled “Putting San Diego County on the High Road: Climate Workforce
Recommendations for 2030 and 2050,” is available at
https://www.sandiegocounty.gov/content/dam/sdc/lueg/regional-decarb-
frameworkfiles/Putting%20San%20Diego%20County%20on%20the%20High%20Road_June%202022.pdf.
ii For a more detailed accounting of these jobs, please refer to Chapter 6, section 6.3.
Oct. 11, 2022 Item #12 Page 32 of 560
30
Table 4. Average number of jobs created in the San Diego region annually through energy demand expenditures
from 2021-2030, by subsectors and technology. Figures assume 1 percent average annual productivity growth.
Investment Area
Average
Annual
Expenditure
Direct Jobs Indirect Jobs Direct Jobs + Indirect Jobs Induced Jobs
Direct Jobs +
Indirect Jobs +
Induced Jobs
Vehicles $7.7 billion 3,427 1,427 4,854 1,508 6,362
HVAC $897.0 million 1,345 699 2,044 764 2,808
Refrigeration $761.9 million 1,315 491 1,806 711 2,517
Appliances $188.6 million 143 77 220 78 298
Construction $113.4 million 263 149 412 146 558
Lighting $106.6 million 177 95 272 100 372
Manufacturing $45.7 million 40 32 72 27 99
Other commercial
and residential $38.9 million 59 30 89 33 122
Agriculture $17.2 million 144 21 165 45 210
Mining $2.4 million 1 1 2 1 3
TOTAL $9.9 billion 6,914 3,022 9,936 3,413 13,349
Source: IMPLAN 3.1
Table 5. Average number of jobs created in the San Diego region annually through energy supply investment from
2021-2030, by subsectors and technology. Figures assume 1 percent average annual productivity growth.
Investment Area Average Annual
Expenditure
Direct
Jobs
Indirect
Jobs
Direct Jobs +
Indirect Jobs
Induced
Jobs
Direct Jobs +
Indirect Jobs +
Induced Jobs
Fossil fuels $4.4 billion 2,538 3,777 6,315 3,805 10,120
Clean renewables $629.5 million 1,488 601 2,089 848 2,937
Transmission and
storage $45.9 million 34 17 51 31 82
Additional supply
technologies $45.1 million 118 35 153 57 210
Other investments $4.5 million 10 3 13 6 19
TOTAL $5.1 billion 4,188 4,433 8,621 4,747 13,368
Source: IMPLAN 3.1
Oct. 11, 2022 Item #12 Page 33 of 560
31
The RDF’s Technical Report estimates that no jobs in the region’s fossil fuel-based industries
will be displaced before 2030, even with contractions in fossil fuel demand. The energy supply
mix in the EER model suggests that there will be small to no changes in the consumption of
fossil fuels before 2030 and few to no changes in the region’s fossil fuel-related jobs before
2030 as a result.i
The County of San Diego and local governments should develop a viable set of just transition
policies for the workers who will experience job displacement between 2031 – 2050. After
2030, the EER model’s Central Case estimates large contractions in both oil and gas. The model
predicts 95% contraction rates in oil and 75% in gas by 2050. Regional governments must begin
developing policies for a just transition for these workers now so that they can gradually
transition into jobs of equivalent or better quality in the clean energy economy or elsewhere.
A just transition will cost much less if it proceeds steadily rather than episodically. Under a
steady transition, the proportion of workers who will retire voluntarily in any given year will
be predictable, which will avoid the need to provide support for a much larger share of
workers at any given time. The rate of the transition from fossil fuel to renewable energy-
based jobs will impact the equity and fairness of the transition. Rapid changes and contractions
would be more likely to result in sudden job losses, where steady changes and contractions
would potentially result in fewer job losses as employees could transition to new jobs or could
voluntarily retire.
Geothermal energy production from the five sites identified in Imperial County would
generate 1,900 jobs per year over a 10-year period in Southern California. Chapter 2 identifies
five areas for geothermal energy production in Imperial County. This chapter’s analysis finds
that there will be 1,900 jobs created per year in the Southern California region over a 10-year
period for the development and operation of these five geothermal power plants, some of
which may be in the San Diego region. These are in addition to the annual 27,000 jobs creation
estimates in the chapter.
i Details on the EER model’s Central Case, which was used here, can be found in Appendix A.
Oct. 11, 2022 Item #12 Page 34 of 560
32
Local Policy Opportunity
The RDF’s Technical Report assesses current CO2 reduction commitments in CAPs to determine
whether the region needs additional activity to set the region on a trajectory to meet
decarbonization goals. Additionally, it identifies opportunities for local jurisdictions in the
region to take further action to support the decarbonization pathways for energy production,
transportation, buildings, and natural climate solutions.
Several novel analyses inform this chapter. First, it analyzes the authority of local governments
and agencies to influence and regulate GHG emissions and summarizes the authority of key
federal, State, and local agencies, and key legislation and regulation at the federal and State
levels to clarify local governments’ ability to act to reduce GHG emissions.i Second, it reviews all
CAPs in the region to determine how frequently a given measure was included in CAPs, the
relative GHG impacts of CAP commitments, and the integration of social equity considerations.ii
Third, a scenario analysis estimates the total regional GHG reductions that would result from all
adopted and pending CAP commitments. It then estimates the potential GHG impact of a
scenario that applies the best CAP commitments to all jurisdictions.iii This scenario analysis
takes the CAP commitment for a given CAP policy category – for example, tree planting goals –
that will produce the single greatest relative GHG reductions and then applies that commitment
to every jurisdiction in the San Diego region, regardless of current or planned commitments in
that category. This may be considered the upper limit of potential GHG reductions from current
CAP commitments. Finally, this chapter applies the results from these approaches and other
analyses to identify opportunities for further local action and regional collaboration on each of
the four decarbonization pathways.iv
Local jurisdictions have authority to influence and regulate GHG emissions. Local governments
can influence and regulate GHG emissions by accelerating State statutory targets and policies,
adopting ordinances to go beyond State law, and using unique authority to adopt and
implement policies. Local authority comes from both constitutionally derived power, which
grants a broad authority to promote public health, safety, or the general welfare of the
i See Appendix B for more details.
ii See Chapter 8, section 8.3 for an overview and sections 8.5-8.8 for sector specific findings. These are also used to
illustrate the gap between the deep decarbonization goals in Chapters 2 through 5 and the regional CAP
commitments. iii See section 8.4. iv These opportunities were included in each relevant section for this Executive Summary, but they are included in
the sector specific section in Chapter 8.
Oct. 11, 2022 Item #12 Page 35 of 560
33
community, and delegated authority from State statutes. The full extent of a local jurisdiction’s
power to regulate GHG emissions is unknown.i
Adopted CAP commitments are insufficient to reach decarbonization goals. GHG reduction
commitments in adopted CAPs for transportation, electricity, and buildings contribute a
relatively small portion of the total reductions needed to reach net zero GHG emissions in 2045
(Figure 13, dashed line). Even if the most aggressive adopted CAP measures are applied to all
jurisdictions in the region, significant emissions would remain, mostly from natural gas building
end-uses and on-road transportation (Figure 13, dash-dot line). The chapter also analyzed the
City of San Diego’s pending 2022 CAP update, but even including these measures, significant
emissions would remain.
Figure 13. This graph shows the projected GHG emissions in the San Diego region from electricity generation,
natural gas end-use in buildings, and on-road transportation in each of the scenarios analyzed. The Reference
Scenario (solid line), where there are no CAP commitments, only shows reductions based on State and federal
laws, mandates, actions, and goals. The Adopted CAP Commitments Scenario (dashed line) shows the remaining
GHG emissions from a subset of total emissions if all current CAPs were applied in full as written. The Best Adopted
CAP Commitment Scenario (dash-dot line) shows the remaining GHG emissions if the best adopted CAP
commitment from each policy category is applied to every jurisdiction in the region, regardless of adopted CAP
commitments. This graph shows that no analyzed scenario will allow the region to reach net zero emissions by
2050. Note that these analyses assume no new State and federal laws, mandates, actions, and goals, and that
current ones do not change at any point in this period. Further, these analyses do not include all GHG emissions for
the region.
i See section 8.2 and Appendix B for a more detailed discussion of authority.
Oct. 11, 2022 Item #12 Page 36 of 560
34
Jurisdictions can adopt additional CAP measures and strengthen existing measures. Based on
the review of CAPs, more jurisdictions can adopt stronger CAP measures, using other regional
jurisdictions’ measures as examples. Similarly, based on the scenario analysis of the combined
GHG impacts of CAP measures, most jurisdictions can strengthen their existing CAP measures,
especially in the transportation and building sectors. These sectors produce large GHG
emissions (Figure 14, right), but on average represent disproportionately low emissions
reductions in CAPs in 2035 (Figure 14, left).
Figure 14. This graph shows the average contribution of each decarbonization pathway to total GHG reductions
from adopted and pending local CAP measures in 2035 (left) and the distribution of 2016 regional emissions by
emission source (right). It shows that emissions from transportation (blue, right side) account for nearly half of
regional emissions, but on average corresponding reductions from CAP commitments only represent slightly more
than a quarter of local GHG reductions in CAPs (blue, left side). Similarly, electricity accounts for about a quarter of
regional emissions (dark orange, right side) but associated reductions contribute on average just under half of GHG
reductions from CAP commitments (dark orange, left side). Note that because emissions associated with buildings
come from both onsite natural gas combustion and electricity production, the building decarbonization portion of
the bar is shaded to show both light and dark orange to correspond with both natural gas buildings (light orange)
and the electricity supply (dark orange).
Integrating social equity into climate planning requires additional work. Based on a
preliminary review, the integration of social equity in adopted and pending CAPs is limited,
inconsistent, and lacks specificity. Additional work would be needed to develop the capacity
and tools to understand and address the equity implications of all decarbonization policies in
the San Diego region, including data collection and analysis; regional guidance documents; and
regional working groups to coordinate, advise, track, and monitor how equity is being
addressed in climate planning.
Oct. 11, 2022 Item #12 Page 37 of 560
35
The San Diego Region as a Model
Although the San Diego region only accounts for 0.08% of global emissions, its regional
decarbonization efforts can impact global emissions by generating followership among others
and sharing durable, scalable, and replicable innovations. San Diego should actively highlight
its efforts and communicate lessons learned in national and international fora. The creation
of the San Diego RDF can serve as a case study for other jurisdictions across the U.S. and
globally to learn from and adapt to their own long-term decarbonization planning endeavors. In
addition to showcasing this effort in various national and international fora,i the United Nations
Sustainable Development Solutions Network (SDSN) has produced a Guide that will serve as a
toolkit for other communities, governing bodies, research groups, and sustainability
practitioners to follow the process undertaken by the County of San Diego in their own
decarbonization pursuits.
SDSN is working to share the RDF within three horizontal levels across its networks. SDSN will
share the RDF and its key findings in national meetings and fora in the United States,
international groups and consortiums, and the United Nations. For example, the project was
presented during the Innovate4Cities Conference in October 2021 and the feedback and
insights from this event will serve to inform the 2022 IPCC Sixth Assessment Report on impact,
adaptation, and vulnerability to global climate change. These events provide an opportunity to
showcase the results of this project and the San Diego region as a model for the world. With
access to these audiences, the RDF can help inform global roadmaps and pathways to net zero.
The Guide for Regional Decarbonization will aid local jurisdictions in creating unique
decarbonization frameworks. This Guide will provide background information as well as
specific steps and advice on logistics, methodology, stakeholder engagement, long-term
planning, and more. Although the resources within this Guide are relevant and applicable to
decarbonization framework project teams beyond the US, frameworks being created in the
context of emerging economies will likely use different approaches, perspectives, and strategies
in climate action planning. This Guide will be free and available online at UC San Diego’s SDG
Policy Initiative’s website (http://sdgpolicyinitiative.org/guide/) as a way to facilitate the
creation of regional decarbonization frameworks and provide a practical roadmap for
jurisdictions working toward net-zero goals.
i Chapter 9 and Appendix 9.A present extensive lists of US and global consortiums that San Diego County and other
jurisdictions with decarbonization frameworks can connect with, attend, and join the networks to disseminate
their findings across different scales.
Oct. 11, 2022 Item #12 Page 38 of 560
San Diego Regional
Decarbonization Framework
TECHNICAL REPORT
Exhibit 2
Oct. 11, 2022 Item #12 Page 39 of 560
1
Project Team
Project Director
Gordon C. McCord
Associate Dean & Associate Professor of Economics
Director, SDG Policy Initiative
School of Global Policy and Strategy, University of California San Diego (UC San Diego)
Project Manager
Elise Hanson, County of San Diego, Land Use and Environment Group (LUEG)
San Diego County Representatives
Murtaza Baxamusa
Rebeca Appel
Sarah Aghassi
Yasamin Rasoulzadeh
Michael De La Rosa
Donna Durckel
Nicole Boghossian Ambrose
Jennifer Lawson
Renee Loewer
Chapter Authors
Introduction
Murtaza H. Baxamusa, LUEG
Study Approach
Ryan A. Jones, Evolved Energy Research
Geospatial Analysis of Renewable Energy Production
Emily Leslie, Montara Mountain Energy
Joseph Bettles, UC San Diego
Accelerating Deep Decarbonization in the Transportation Sector
Katy Cole, Fehr & Peers
Chelsea Richer, Fehr & Peers
Eleanor Hunts, Fehr & Peers
Oct. 11, 2022 Item #12 Page 40 of 560
2
Decarbonization of Buildings
Philip Eash-Gates, Synapse Energy Economics
Jason Frost, Synapse Energy Economics
Shelley Kwok, Synapse Energy Economics
Jackie Litynski, Synapse Energy Economics
Kenji Takahashi, Synapse Energy Economics
Asa Hopkins, Synapse Energy Economics
Natural Climate Solutions and other Land Use Considerations
Elise Hanson, UC San Diego
Emily Leslie, Montara Mountain Energy
Employment Impacts through Decarbonization in the San Diego Region
Robert Pollin, Political Economy Research Institute (PERI), University of Massachusetts Amherst
Jeannette Wicks-Lim, PERI, University of Massachusetts Amherst
Shouvik Chakraborty, PERI, University of Massachusetts Amherst
Gregor Semieniuk, PERI, University of Massachusetts Amherst
Key Policy Considerations for the San Diego Region
Joseph Bettles, UC San Diego
Gordon C. McCord, UC San Diego
David G. Victor, UC San Diego
Emily Carlton, UC San Diego
Local Policy Opportunity Analysis
Scott Anders, Energy Policy Initiatives Center (EPIC), University of San Diego School of Law
Nilmini Silva Send, EPIC, University of San Diego School of Law
Joe Kaatz, EPIC, University of San Diego School of Law
Yichao Gu, EPIC, University of San Diego School of Law
Marc Steele, EPIC, University of San Diego School of Law
The San Diego Region as a Model
Elena Crete, UN Sustainable Development Solutions Network (SDSN)
Julie Topf, UN Sustainable Development Solutions Network (SDSN)
Appendix A: Summary of Statewide Energy System Modeling
Ryan Jones, Evolved Energy
Appendix B: Review of Authority for Local Jurisdictions and Agencies to Influence and Regulate
GHG Emissions
Joe Kaatz, EPIC, University of San Diego
Oct. 11, 2022 Item #12 Page 41 of 560
3
Acknowledgments
Special thanks to the County of San Diego Board of Supervisors: Chair Nathan Fletcher, Vice Chair
Nora Vargas, Supervisor Joel Anderson, Supervisor Terra Lawson-Remer, and Supervisor Jim
Desmond for their direction and leadership in establishing this framework.
The authors thank David Victor for his advisory role across the project, as well as Joseph Bettles,
Tyler Spencer, Emily Carlton, Elissa Bozhkov, and Jeffrey Myers for research and editorial support,
and Isaac Wang for project management support.
The project team is grateful to the following individuals for their strategic advice to the County of
San Diego representatives: Elizabeth King (California Environmental Protection Agency), Jamal
Russell Black (San Diego Regional Policy & Innovation Center), Christiana DeBenedict (San Diego
Foundation), Everett Au (San Diego Foundation), Amenah Gulamhusein (San Diego Foundation),
and Susan L. Guinn (San Diego Regional Policy & Innovation Center).
The project team also wants to thank the Technical Working Group and all the participants and
commenters who contributed their time and knowledge by submitting written/oral comments and
attending our meetings and workshops.
Disclaimer
This report was funded by the County of San Diego. The authors declare no competing interests
with relevant entities in the San Diego region.
This report should be cited as:
McCord, Gordon C., Elise Hanson, Murtaza H. Baxamusa, Emily Leslie, Joseph Bettles, Ryan A. Jones, Katy Cole, Chelsea
Richer, Eleanor Hunts, Philip Eash-Gates, Jason Frost, Shelley Kwok, Jackie Litynski, Kenji Takahashi, Asa Hopkins,
Robert Pollin, Jeannette Wicks-Lim, Shouvik Chakraborty, Gregor Semieniuk, David G. Victor, Emily Carlton, Scott
Anders, Nilmini Silva Send, Joe Kaatz, Yichao Gu, Marc Steele, Elena Crete, and Julie Topf. San Diego Regional
Decarbonization Framework: Technical Report. County of San Diego, California. 2022.
Oct. 11, 2022 Item #12 Page 42 of 560
4
Table of Contents
Introduction ................................................................................................................................ 6
1. Study Framework ..................................................................................................................... 7
1.1 Introduction ............................................................................................................................... 7
1.2 Study Questions ....................................................................................................................... 11
1.3 The Role of Pathways in Planning ............................................................................................ 11
1.4 Notes on Reading this Report .................................................................................................. 13
2. Geospatial Analysis of Renewable Energy Production ............................................................. 16
2.1 Introduction ............................................................................................................................. 16
2.2 State-Level Context .................................................................................................................. 19
2.3 Data .......................................................................................................................................... 20
2.4 Methods, Assumptions, Total Resource Availability, and Least-Cost Areas ........................... 21
2.5 Results and Discussion ............................................................................................................. 40
2.6 Trends Across Scenarios .......................................................................................................... 52
2.7 Conclusion ................................................................................................................................ 53
Appendix 2.A List of Spatial Data Sources .................................................................................... 57
Appendix 2.B List of Spatial Data Sources ..................................................................................... 58
Appendix 2.C List of Key Assumptions ........................................................................................... 60
Appendix 2.D QGIS Processing Modeler ....................................................................................... 61
Appendix 2.E Floatovoltaics ........................................................................................................... 62
Appendix 2.F Transmission Upgrade Options and Costs ............................................................... 63
Appendix 2.G Downscaling Method .............................................................................................. 64
Appendix 2.H San Diego Vegetation Types with High CO2 Sequestration Potential ..................... 65
3. Accelerating Deep Decarbonization in the Transportation Sector ............................................ 66
3.1 Introduction ............................................................................................................................. 66
3.2 Regional Policy Context ........................................................................................................... 68
3.3 Transportation Modeling & Emissions Forecasts .................................................................... 76
3.4 Decarbonization Strategies: Policy Pathways to Close the Emissions Gap ............................. 79
3.5 Key Actions .............................................................................................................................. 95
3.6 Remaining Challenges and Gaps ............................................................................................ 109
4. Decarbonization of Buildings ................................................................................................ 117
4.1 Introduction ........................................................................................................................... 118
4.2 Buildings in San Diego County ............................................................................................... 119
4.3 Technologies and Fuels for Decarbonizing Buildings ............................................................ 127
4.4 Pathways to Decarbonization of San Diego’s Buildings ......................................................... 139
4.5 Gas Utility and Rate Impacts .................................................................................................. 151
4.6 Key Policy Actions .................................................................................................................. 163
5. Natural Climate Solutions and Other Land Use Considerations .............................................. 171
5.1 Introduction ........................................................................................................................... 172
5.2 Natural and Working Lands – Ecological Carbon Dioxide Sequestration and Storage .......... 180
5.3 Agriculture and Working Lands ............................................................................................. 188
5.4 Blue Carbon and Sea Level Rise ............................................................................................. 195
5.5 Urban Forestry and Greening ................................................................................................ 200
5.6 Additional Natural Climate Solutions .................................................................................... 204
5.7 Regional Natural Climate Solutions Policy Recommendations and Conclusions ................. 206
Oct. 11, 2022 Item #12 Page 43 of 560
5
Appendix 5.A Methods, data, and sources for carbon stock and flow data and sources ........... 216
Appendix 5.B Blue carbon methodology details and blue carbon value sources ....................... 221
6. Employment Impacts through Regional Decarbonization Framework for the San Diego Region
............................................................................................................................................... 223
6.1 Overview of Job Creation Estimates ...................................................................................... 224
6.2 Methodological Issues in Estimating Employment Creation ................................................. 225
6.3 Job Creation Estimates .......................................................................................................... 229
6.4 Job Quality Indicators and Worker Characteristics in Energy Demand and Supply
Employment ................................................................................................................................. 233
6.5 Job Contraction for Workers in Fossil Fuel-Based Industries ................................................ 246
Appendix 6.A Employment Impacts of Geothermal Energy Projects for Imperial County ......... 256
Appendix 6.B Estimating San Diego Region-Specific Employment .............................................. 257
Appendix 6.C Urban Reforestation And Job Creation For The San Diego Region ....................... 260
7. Key Policy Considerations for the San Diego Region .............................................................. 263
7.1 Introduction ........................................................................................................................... 264
7.2 Achieving Deep Decarbonization across the San Diego Region: the Need for more
Experimentation, Collaboration, and Learning ........................................................................... 265
7.3 Case Studies for Regional Action ........................................................................................... 273
7.4 Institutional Structure Built for Learning and Adaptation ..................................................... 280
7.5 Creating Followership: Acting at Home but Impacting Outside the Region .......................... 286
7.6 Conclusion .............................................................................................................................. 290
8. Local Policy Opportunity ...................................................................................................... 294
8.1 Key Findings ........................................................................................................................... 296
8.2 Authority of Local Jurisdictions and Agencies to Influence and Regulate GHG Emissions .... 297
8.3 Review of Climate Action Plans in the San Diego Region ...................................................... 301
8.4 Scenario Analysis of GHG Impacts from Adopted CAPs in the San Diego Region ................. 318
8.5 Decarbonize Transportation .................................................................................................. 327
8.6 Decarbonize Buildings............................................................................................................ 365
8.7 Decarbonize the Electricity Supply ........................................................................................ 399
8.8 Natural Climate Solutions ...................................................................................................... 415
8.9 Other Limitations ................................................................................................................... 429
8.10 Conclusions .......................................................................................................................... 430
Appendix 8.A Assumptions for Estimating GHG Impact of Best CAP Commitment ................... 432
Appendix 8.B Supporting Material for Decarbonize Transportation Policy Assessment ............ 439
9. The San Diego Region as a Model ......................................................................................... 443
9.1 Purpose .................................................................................................................................. 443
9.2 Opportunities for Scaling Impact ........................................................................................... 444
9.3 Planning Across Jurisdictions – Horizontal and Vertical Alignment ...................................... 445
Appendix 9.A Relevant US and Global Communities of Practice Lists ........................................ 449
10. Conclusion ......................................................................................................................... 454
Appendix A. Summary of Statewide Energy System Modeling .................................................. 457
Appendix B. Review of Authority for Local Jurisdictions and Agencies to Influence and Regulate
GHG Emission .......................................................................................................................... 472
Appendix C. Technical Working Group ...................................................................................... 521
Oct. 11, 2022 Item #12 Page 44 of 560
6
Introduction
Recognizing the need for a regional approach to addressing climate change, on January 27th,
2021, the San Diego County Board of Supervisors voted to create a Regional Decarbonization
Framework. This framework is intended to inform our collective future actions on reducing
greenhouse gas emissions in the San Diego region. It is intended to supplement climate action
planning efforts that are currently underway and chart collaborative pathways to implement
our regional goals.
This study is the first step in positioning the San Diego region as a global leader in climate
planning. It is authored by a team led by the University of California San Diego School of
Global Policy and Strategy, working in collaboration with the Energy Policy Initiatives Center
at the University of San Diego School of Law and other consultants with technical expertise in
energy, transportation and building systems. This is the first study of its kind that
quantifies the magnitude of the challenge in achieving meaningful reductions in regional
greenhouse gas emissions. It shows that even if all the municipalities in the region met their
current climate commitments, we would fall far short of our goals in reducing planet-heating
gases in each sector of the region’s economy. Each of us clearly need to do more individually,
however, that is still not going to be enough.
So what do we do with all of this information? The San Diego region is uniquely positioned to
implement deep decarbonization. The implementation of decarbonization pathways in the
years and decades ahead is going to be the true test of the success of this framework. An
equitable implementation strategy would position our region competitively for public and
private investments in the future, while ensuring that our underserved communities are not
left behind. The scale and pace of this effort will require partnerships between local
governments, tribal governments, businesses, labor unions, environmental advocates,
community-based organizations and residents of our communities.
This framework provides the scientific basis for us to convene and spark creative and
collaborative solutions that can benefit us all as well as the planet. These are regional solutions
that cannot be achieved in silos by an individual, government, or business alone. But together,
our greener future is bright!
Murtaza H. Baxamusa, PhD, AICP
Program Manager for Regional Sustainability
Land Use and Environment Group
County of San Diego
Oct. 11, 2022 Item #12 Page 45 of 560
7
1. Study Framework
Ryan A. Jones, Evolved Energy Research
Key Takeaways
● Detailed analyses of land use and the energy, transportation, and building sectors
should inform regional and local decarbonization policies consistent with a system-wide
path to decarbonization at regional, state, and national scales.
● Energy system modeling of pathways to net zero emissions for California and the United
States inform the sectoral analyses in this report, described in more technical detail in
Appendix A.
● Technical pathway studies can identify dead-end strategies, key decision points,
pathways commonalities under sensitivity analyses, while also situating near-term policy
targets relative to long-term goals.
● Uncertainty necessitates an ongoing and iterative planning process, with periodic
updating as new information arises and progress is or is not achieved.
1.1 Introduction
The Paris Agreement calls for “holding the increase in the global average temperature to well
below 2°C above pre-industrial levels and pursuing efforts to limit the temperature increase to
1.5°C.”1 Following the scientific evidence and consensus around climate change, countries,
states, and local jurisdictions around the world have begun adopting the goal of reaching
carbon neutrality, or “net zero.” Executive Order (EO) B-55-18 directs California to reach such a
target by 2045.
The RDF begins with the premise that regional and local policies should be informed by detailed
analysis of the energy system consistent with a system-wide path to decarbonization at
regional, state, and national scales. The RDF focuses on the energy system, defined as the total
production and consumption of energy in the electric power, transportation, and buildings
sectors. This work endeavors to show pathways for the San Diego region that are consistent
with national-level and state-level pathways to reach net zero carbon dioxide emissions from
the energy system by 2045. By “net zero,” this report means that anthropogenic carbon dioxide
emissions from the energy system equal anthropogenic carbon sequestration, and therefore
humans do not contribute net emissions to the atmosphere. We note from the outset that the
energy system does not represent the totality of greenhouse gas flows: GHGs are emitted from
sectors beyond those considered in this report (e.g., wastewater treatment, landfills, aviation,
Oct. 11, 2022 Item #12 Page 46 of 560
8
off-road transportation, etc.); anthropogenic carbon sequestration does not include natural
carbon sequestration in regional ecosystems, including natural and working lands (discussed in
Chapter 5); and GHGs are emitted when materials are created or utilized (see Box 1.1).
Box 1.1 - Embodied Carbon
The RDF Technical Report analyzed energy system emissions from the three primary emissions
sources in the region: electricity production, transportation, and natural gas combustion in buildings.
A different way of calculating emissions considers the process-based emissions that result in a good or
service. These emissions are sometimes called "embodied carbon" and they result from the full
production lifespan of a good like a building. Embodied carbon represents the carbon intensity of a
good or material.2 Embodied carbon is applicable to the building, electricity generation, and
transportation sectors.
Buildings require large inputs of carbon intensive materials, like cement or steel, making embodied
carbon a major source of building emissions. Though beyond the RDF Technical Report’s scope, policy
levers at the local, State, and federal level could reduce the significant building material emissions.
Chapter 4, section 4.6 ("Key Policy Actions") provides some examples of policies to reduce embodied
carbon in buildings from around the State and Appendix B ("Review of Authority for Local Jurisdictions
and Agencies to Influence and Regulate GHG Emissions"), Section B.3 ("Local Authority Related to
Building Decarbonization") provides a discussion of local, State, and federal jurisdictions' authority to
reduce embodied carbon. The California Legislature has introduced a number of bills recently that
have not made it through the legislative process but this continues to be a priority each session. At
the end of the 2022 session, AB 2446 may possibly reach the Governor’s desk to develop a method to
measure and reduce embodied carbon in materials for new construction 40% by 2035. Importantly,
California passed one major piece of legislation in 2021, SB 596 (Becker, Chapter 246, Statutes of
2021), that addresses embodied carbon in cement manufacturing through a net-zero emissions
strategy targeting net-zero emissions by 2045 and an interim 40% reduction target of carbon intensity
by 2035.
Renewable electricity generation requires carbon intensive infrastructure, including solar panels and
wind turbines. So, despite the fact that operating solar and wind power plants produces few
emissions, there is embodied carbon in the materials and infrastructure that produce renewable
energy.
Finally, transportation decarbonization pathways – such as electric vehicles (EVs), increased public
transit, electric bicycles – also require materials and infrastructure that have embodied carbon. For
example, electric vehicles have zero tailpipe emissions, but they require large batteries that are
carbon intensive to produce.
The embodied carbon of renewable energy infrastructure and electric vehicles are beyond the scope
of this study. There are fewer policy options for local jurisdictions and agencies to reduce embodied
carbon in renewable energy infrastructure and EVs because their supply chains are global and
complex.
This technical report for the Regional Decarbonization Framework (RDF) presents a science-
based approach to help governments in the San Diego region plan for policies and investments
Oct. 11, 2022 Item #12 Page 47 of 560
9
to achieve emissions reductions consistent with California’s 2045 net zero emissions goal,
established by EO B-55-18. The analytical approach consists of five main pieces. First, models of
the whole energy system, both at national and state levels, are used to identify five technically
and economically feasible pathways for achieving net zero emissions. These models are
presented in Appendix A. Second, these results are used to guide detailed sector-level analyses
for the San Diego region, presented in Chapters 2 through 4, to best follow these pathways.
Third, additional analyses were conducted on the natural climate solutions available to the
region (Chapter 5), which describes the scope for natural carbon sequestration and storage in
the region, and on changes to regional employment that result from the investments in energy
demand and supply following the Central Case of the energy system decarbonization modeling
(Chapter 6).i Fourth, there are two analyses of policy strategies. Chapter 7 analyzes key policy
considerations in the region and discusses political frameworks that may foster regional
collaboration to achieve deep decarbonization. Next comes an analysis of current Climate
Action Plan (CAP) commitments throughout the region, identification of local opportunities,
and associated legal and jurisdictional authority considerations for instituting decarbonization
strategies. These are presented in Chapter 8 and in Appendix B. Finally, Chapter 9 provides a
description of how the San Diego region can be a model for other jurisdictions, both
domestically and abroad, along with a guidebook for jurisdictions, agencies, and practitioners to
frame their own decarbonization efforts.
Due to the complexity of our energy and climate systems, many analytical approaches examine
a single sector at a time, often in great detail, but do not explicitly consider interactions
between sectors. Such an approach risks insufficient cumulative actions from each sector,
inefficient actions that prove costlier than viable alternatives, or that interactions lead to
unintended negative consequences (for example, multiple sectors transitioning to the same
alternative fuel beyond its sustainable supply). To avoid such outcomes, sectoral analyses in the
RDF are informed by five pathways to net zero emissions identified by state and national-level
models of the whole energy system. Evolved Energy Research performed this systems-level
pathways analysis using the EnergyPATHWAYS and RIO models, drawing on the methodology
and data in an earlier, national-level pathways analysis by Williams et al. (2021) that used these
models.3 The modeling effort will hereafter be called the Evolved Energy Research (EER) model.
For the RDF, modeling tools were updated for consistency with the 2021 EIA Annual Energy
Outlook4 and specific zones were created for Northern and Southern California to aid in
i A separate component of the RDF is a workforce development report by Inclusive Economics, titled “Putting San
Diego County on the High Road: Climate Workforce Recommendations for 2030 and 2050.” It is a qualitative
workforce report that complements Chapter 6’s quantitative analyses of changes to regional employment. Using
Chapter 6’s quantitative data, Inclusive Economics analyzed the qualitative effects of decarbonization on labor
markets and workforce development strategies This report is available here: https://www.sandiegocounty.gov/content/dam/sdc/lueg/regional-decarb-
frameworkfiles/Putting%20San%20Diego%20County%20on%20the%20High%20Road_June%202022.pdf
Oct. 11, 2022 Item #12 Page 48 of 560
10
downscaling the insights from the U.S. at large. Appendix A presents methods, key
assumptions, and results of energy system modeling for the state-level, with those for the
national-level in Williams et al. (2021).3 Importantly, in instances where the particular
circumstances in the region differed from those at a state or national level, the San Diego
specific insights were retained. Thus, the pathways for larger geographic areas informed but did
not prescribe the San Diego region’s pathways.
Guided by the energy system decarbonization pathways for California as a whole, pathways
analysis within each sector in the RDF details what the San Diego region needs (e.g.,
infrastructure investments, local policy commitments, or policy action in other domains) for
alignment with a net zero emissions trajectory in California. Sector-level pathways are
necessary because technical and political challenges vary by sector, necessitating sector-level
pathways and practical policy strategies. Of note, each sector is not expected to arrive at net
zero emissions independently; rather, each will work in conjunction with other sectors and
California regions as an interconnected system to decarbonize.
A system-wide technical pathway to decarbonization by 2045 guides the RDF, aligning with
California’s commitments and statewide energy system analysis. This brings a system-wide
approach to ensure consistency of effort and overall success in reducing emissions, but is not a
binding policy solution setting requirements or prescriptions in each sector. The interconnected
nature of the energy system necessitates that national, State, and local governments move in
concert in their policies and investments to decarbonize.
This report does not set out to identify which, if any, of the pathways is the “right” pathway for
the San Diego region because the best pathway remains unknowable. Instead, it shows multiple
ways forward to elucidate the trade-offs, decision points, risks, and synergies in
decarbonization efforts. This is a unique effort to chart how to reduce carbon dioxide emissions
in the region through fostering collaboration among various municipalities, promoting active
learning and experiments to test diverse ideas, and positioning the region to attract State and
federal resources. Decarbonization will require that each level of government utilize policy
levers within its respective jurisdiction, while also collaborating vertically and horizontally
across jurisdictions to align long-term goals. The RDF Technical Report provides policymakers,
private industry, and stakeholders in the San Diego region the information needed to chart a
path forward, starting with policies necessary to reach interim 2030 targets. It also provides a
framework of regional institutional governance that emphasizes collaborative policy
experimentation and review across governments, industries, and academia, with the
understanding that such cooperation can allow goals, strategies, and policies to improve over
time as lessons are learned and circumstances change.
San Diego’s regional boundaries with Orange County, Imperial County, Mexico, and State
Oct. 11, 2022 Item #12 Page 49 of 560
11
waters form the geographic limits of this study.
1.2 Study Questions
The research team set out to answer two primary questions: (1) what changes are required to
renewable energy infrastructure, patterns of energy use in transportation and buildings, and
modes of transportation for the San Diego region to decarbonize consistent with the State’s
goals; and (2) what policy actions must local officials take for the region to achieve these
changes?
Based on past modeling exercises, this report assumes that it is technologically and financially
possible for California to reach net zero emissions by 2045. Indeed, monetary savings from air
quality improvements or avoided adaptation costs associated with GHG emission reductions
are expected to exceed GHG mitigation costs. Nevertheless, the RDF recognizes that many
policies necessary for reaching net zero emissions fall under State or federal authority, beyond
local governments.i The San Diego region can and should vocally advocate for these policies
(e.g., federal tax incentives), but this study focuses on local actions.
1.3 The Role of Pathways in Planning
The discussion of the role of pathways in planning below draws heavily from a recent report
from the Commonwealth of Massachusetts.5 Rather than simply referring the reader to that
report, we have summarized key ideas from that text here.
The RDF Technical Report uses the term “pathway” to mean a blueprint for the energy and land
systems that reach future GHG reduction targets. The term can refer to both a specific strategy
and to a set of possible blueprints (as in, “multiple pathways to deep decarbonization”). The
Deep Decarbonization Pathways Project (DDPP) coined the term “pathway” in 20146 to capture
the path dependency within different decarbonization strategies. While the physical
transformations represented by these pathways are informed by economic, social, and political
constraints, they should not be mistaken for the impacts of a specific policy or market
intervention.
The study of long-term decarbonization pathways has been a growing trend after early success
using them in California.7 Modeling such decarbonization pathways depends on the ability to
i For a larger discussion of the authority of local jurisdictions to decarbonize, see Chapter 8 (Local Policy
Opportunity) and Appendix B of this report.
Oct. 11, 2022 Item #12 Page 50 of 560
12
represent the existing energy system with a high degree of accuracy. Significant effort goes into
benchmarking and stress testing the models of current energy systems until researchers have a
high degree of confidence that changes in inputs will produce meaningful outputs. After
California, other states (Washington, New York) followed suit with their own pathways
analyses. While pathways analysis has become an integral part of energy planning
processes,the breadth of topics covered and the time horizon analyzed has meant it remains a
unique activity within state-level public policy processes and merits some clarification.
The most critical clarification is that pathways are not forecasts of what will happen. While the
energy system physics and emissions accounting that underpin our models are well-established,
projecting technological progress (particularly cost) and energy service demand has a mixed
track record, even over time spans much shorter than 30 years. This means that selecting a
single pathway as the basis for public policy is fraught because the assumptions underpinning
current evaluations may shift over time. Uncertainty necessitates an ongoing planning process,
with periodic updating as new information becomes available and as decarbonization does or
does not progress. Further, uncertainties in these pathways support the need for a flexible
framework that allows for integration and adaptation to meet continuously changing political
and technological realities.
Rather than predicting the future, pathway studies are valuable for four reasons:
● Identifying and decreasing the risk of dead-end strategies;
● Identifying key decision points;
● Identifying commonalities in pathways under sensitivity analyses;
● Situating near-term policy targets with respect to long-term goals.
Infrastructure projects that produce, deliver, and consume energy are capital intensive and
have long lifetimes. This is illustrated in Figure 1.1, which shows the number of replacement
cycles for common infrastructure types between now and mid-century.5 If a pathways analysis
looked only 10 to 15 years ahead, as is typical in electric utility integrated resource plans, and
decisions were made that would efficiently reduce emissions to hit near-term targets but were
inconsistent with long-term goals, then those decisions would lock in higher emissions or
increase costs due to necessitating early retirement. Thus, a 30-year pathways study can test a
given decarbonization strategy against this backdrop of infrastructure lifetimes to understand
whether an emissions dead-end will be encountered on a given path. Knowing the timing of key
decision points can also help to avoid stranded assets.
Oct. 11, 2022 Item #12 Page 51 of 560
13
Figure 1.1. Typical lifetimes of common energy consuming or producing infrastructure. A simplified overview of the
lifetimes of common energy consuming or producing infrastructure are compared against the 30-year time period
left to reach the net zero target. The black vertical lines delineate points of natural retirement, and the number of
segments correspond to the number of replacement cycles between now and 2050. The lifetime of vehicles by location and duty-cycle. The lifetime of power plants and pipelines is longer than 30 years and thus no natural
retirement is shown on this figure.
As mentioned, the future trajectories of many variables, including technology cost and
performance projections, remain highly uncertain. However, it is possible to develop ranges of
values in which the high and low estimates have a high probability of encapsulating the
eventual revealed value for any variable. Creating multiple pathways within each sector allows
for sensitivity testing of results based on a range of input assumptions. This framework
identifies strategies common across all pathways and shows what drives differences between
pathways. It thus offers more value than a precise blueprint reliant on uncertain assumptions.
This report details a set of “low-regret” strategies for the next 10 years common to all modeled
pathways that successfully reach net zero emissions in that sector.
Finally, pathways studies can be valuable in near-term target settings. Backcasting from a mid-
century net zero energy system to the present reveals milestones or benchmark values (often
ranges) consistent with reaching long-term goals. Chapter 7, Key Policy Considerations for the
San Diego region discusses near-term targets and policy recommendations in more detail.
1.4 Notes on reading this report
Readers of this revised report should be aware of the following:
● This report provides technical analyses and intends to inform decision-making and
implementation plans, but it is neither a decision-making document nor an
implementation plan. As such, the findings in this report are not recommendations to
the County, any city, jurisdiction, municipality, government or agency.
Oct. 11, 2022 Item #12 Page 52 of 560
14
● Throughout the report, we use the term “San Diego region” when referring to the
geographic extent of the county, and “San Diego County” to refer to the county
government.
● Readers interested in high-level findings and recommendations for an institutional
framework to promote decarbonization are encouraged to read Chapter 7, “Key Policy
Considerations for the San Diego Region.” To inform the institutional structure and
processes, Chapter 7 provides an overview of key decarbonization actions, areas of
uncertainty, and County leverage points from each of the four sectors: land use,
buildings, transportation, electric sector. The overview in Table 7.1 provides the basis of
several takeaways that inform a proposed institutional structure to support
decarbonization implementation among policy actors in the San Diego region.
Oct. 11, 2022 Item #12 Page 53 of 560
15
Works Cited:
1. UNFCCC. Paris Agreement to the United Nations Framework Convention on Climate Change.; 2015.
https://unfccc.int/files/meetings/paris_nov_2015/application/pdf/paris_agreement_english_.pdf
2. McKinsey & Company. Data to the rescue: Embodied carbon in buildings and the urgency of now. Our Insights
https://www.mckinsey.com/business-functions/operations/our-insights/data-to-the-rescue-embodied-
carbon-in-buildings-and-the-urgency-of-now (2020). 3. Williams JH, Jones RA, Haley B, et al. Carbon-Neutral Pathways for the United States. AGU Adv. 2021;
2(1):e2020AV000284. doi:10.1029/2020AV000284
4. Nalley, S. & LaRose, A. Annual Energy Outlook 2021 (AEO2021); 2021.
https://www.eia.gov/pressroom/presentations/AEO2021_Release_Presentation.pdf
5. Jones R, Haley B, Williams J, Farbes J, Kwok G, Hargreaves J. Energy Pathways to Deep Decarbonization: A
Technical Report of the Massachusetts 2050 Decarbonization Roadmap Study. Commonwealth of
Massachusetts; 2020.
6. Deep Decarbonization Pathways Project. Pathways to Deep Decarbonization 2015 Report. SDSN - IDDRI; 2015.
7. Energy and Environmental Economics, Inc. (E3). California Air Resources Board (CARB) Scoping Plan. NEWS:
DISTRIBUTED ENERGY RESOURCES, ENERGY AND ENVIRONMENTAL POLICY, RENEWABLES, RESOURCE
PLANNING; https://www.ethree.com/california-air-resources-board-carb-scoping-plan/; 2017.
Oct. 11, 2022 Item #12 Page 54 of 560
16
2. Geospatial Analysis of Renewable Energy Production
Emily Leslie, Montara Mountain Energy
Joseph Bettles, UC San Diego
Key Takeaways
● This chapter identifies low-impact, high-quality areas for wind and solar development in
the San Diego region and neighboring Imperial County.
● The region has sufficient available land area for wind and solar generation to approach a
fully decarbonized energy system in line with the California-wide system model in
Appendix A.
● However, approaching a 100% decarbonized energy system that also meets societal
expectations and regulatory standards for reliability will require significant but uncertain
investments in a suite of additional resources, including excess intermittent and flexible
generation, storage, and demand-side management.
● This chapter informs decision-making by providing a series of site-selection scenarios
that prioritize land value, ease of development, infill solar development plus rooftop
solar, and environmental impact as well as proposing a strategy to address reliability.
● The significant solar and geothermal potential of neighboring Imperial County is a large
potential resource for the San Diego region that may warrant upgrades to the
transmission network.
● San Diego regional jurisdictions should coordinate with State agencies (e.g., California
Public Utilities Commission (CPUC) Integrated Resource Planning team, CPUC Resource
Adequacy team, California Independent Systems Operator (CAISO) Transmission
Planning Process team, CAISO Local Capacity Requirements team) to ensure the
reliability of the system.
● Regardless of how utility-scale development will occur, adequate information supports
early action to pursue growth in rooftop solar, especially in communities with high
pollution burdens from electricity generation plants and low access to renewable energy
opportunities, which have been prioritized for investment under California’s Climate
Investments program.
2.1 Introduction
Decarbonization of the electric sector in the San Diego region will require substantial
deployment of new renewable resources: 90% of the electricity in most decarbonization
scenarios in the literature comes from commercially mature renewable technologies such as
Oct. 11, 2022 Item #12 Page 55 of 560
17
wind and solar photovoltaic (hereafter solar). Decisions on where to site clean energy facilities
can have significant impacts on the environment1 and require development of new or upgraded
transmission infrastructure.2 Many aspects of the energy system and related air quality and
climate impacts of energy planning and procurement decisions are regulated at the State and
federal levels. However, the land use related impacts of energy planning and procurement
decisions tend to be local. This analysis explores the availability of suitable land area within the
region and the siting opportunities and challenges within local governments’ jurisdictional
control. While it is technically and legally feasible (and common practice) to procure clean
energy resources from remote locations, the siting risks, challenges, impacts, and uncertainties
of remote resources are difficult to quantify. The transmission deliverability and reliability
benefits of remote resources are similarly difficult to quantify. A robust analysis at the local
level can clarify what is at stake both locally and in the broader Southern California region, and
it can better inform decision-making for both local and geographically distributed entities
participating in regional energy planning and procurement.
In this chapter we use the electricity demand from the Central Case of Evolved Energy Research
(EER) model and perform downscaling analysis to identify low-impact, high-quality areas for
wind and solar development in the San Diego region.i We define high-quality resources as those
having high energy yield (for example, high solar irradiance and high mean annual wind speed),
close proximity to existing infrastructure, suitable techno-economic criteria (for example,
slope), population density, and suitable environmental criteria. Such criteria include avoiding
conservation priorities such as wetlands, endangered species habitat, and compatibility with
other priorities such as carbon sequestration potential and other zoning designations and
development needs. We compare the resource potential under a range of site suitability
assumptions to the modeled 2050 demand forecast for a fully decarbonized economy to
comment on magnitude and scale of anticipated supply and demand. This report considers
simple least-cost scenarios in San Diego County and scenarios with increased power transfer
between San Diego and Imperial counties. It also considers alternate scenarios of more low-
impact candidate project area selection compared to the least-cost solution. One such scenario
prioritizes rooftop solar and ground-mounted urban infill solar. In this scenario, we estimate
the costs and capacity of prioritizing urban infill and rooftop solar and discuss the potential co-
benefits, including equity benefits such as local economy job creation and pollution reduction.
Finally, we present least-cost actions in the near-term which are valid across site selection
scenarios. The electric sector spatial analysis aims to inform planning and deployment of
renewable electricity capacity in the region based on a range of techno-economic and
environmental variables, including cost of energy, environmental impacts, and resource
i For more information on the macro energy modeling, see Appendix A.
Oct. 11, 2022 Item #12 Page 56 of 560
18
availability.
The purpose of this analysis is to identify plausible near-term options and provide visualizations
indicating what a range of future scenarios might look like. It primarily focuses on current
commercially available technologies, including onshore wind, utility scale solar, rooftop solar,
renewable energy development on brownfields, battery energy storage, and long-duration
energy storage. We also consider emerging technologies such as offshore wind energy. While
offshore wind development is not yet commercially demonstrated in California and is outside
local jurisdictional authority for siting and permitting, nevertheless the magnitude of its
development would affect the required magnitude of land-based renewables. Exploratory clean
energy supply technologies that have not yet demonstrated broad commercial deployment and
market penetration at the time of this writing are considered out-of-scope. Examples of such
technologies include small modular nuclear reactors, bioenergy, waste-to-energy, and
mechanical direct air capture of carbon, floatovoltaics, and to some extent wave energy. The
rationale for the technology scope is to utilize limited planning resources for efforts that are
considered achievable with a high degree of confidence, and to limit exposure to uncertainty
regarding cost, schedule, and technology performance. Additional technology types should be
incorporated into future analyses if and when data becomes available demonstrating they have
become proven and scalable or as they are built.
The geographic extent of this analysis is limited to San Diego County’s boundaries (referred to
as the San Diego region) to focus on options within the jurisdictional control of the County and
city governments therein. Additional geographic analysis is included for adjacent Imperial
County for some scenarios because Imperial County is strongly electrically interconnected with
the San Diego region.
Finally, it is important to note that the scenarios, results, and maps in this chapter are not
recommendations. Instead, they are examples of how, under current land use, technology, and
grid conditions, the San Diego region can generate enough renewable energy to meet the
projected 2050 energy demand and thereby power other important decarbonization efforts,
like fueling electric vehicles, public transit, and buildings. The scenarios demonstrate the
methodology and current results of prioritizing different aspects of public interest, such as
minimizing costs, impacts to natural and working lands, or legal and social barriers to
renewable energy development. All analyses are snapshots of the current regional resources,
infrastructure, and available technologies. These inputs will change over time and the resulting
maps, analyses, and results will also change. This chapter is meant to demonstrate a flexible
pathways methodology for energy decarbonization, and shed light on near-term investments
that are common across pathways and set the region on a path toward decarbonization for
consideration by decision-makers.
Oct. 11, 2022 Item #12 Page 57 of 560
19
2.2 State-Level Context
2.2.1 State-level renewable energy and electric sector decarbonization targets
California's Renewable Portfolio Standard (RPS) program was established in 2002 by Senate Bill
(SB) 10783 with the initial requirement that 20% of electricity retail sales must be served by
renewable resources by 2017. The program was accelerated in 2015 with SB 350,4 which
mandated a 50% RPS by 2030. SB 350 includes interim annual RPS targets with three-year
compliance periods and requires 65% of RPS procurement to be derived from long-term
contracts of 10 or more years. In 2018, SB 1005 was signed into law and increased the RPS to
60% by 2030 and required all the State's electricity to come from carbon-free resources by
2045.
The California Public Utilities Commission implements and administers RPS compliance rules for
California’s retail sellers of electricity, which include large and small investor-owned utilities
(IOUs), electric service providers (ESPs) and community choice aggregators (CCAs). The
California Energy Commission (CEC) oversees certification of electrical generation facilities as
eligible renewable energy resources and adopting regulations to enforce RPS procurement
requirements of public-owned utilities (POUs).6
2.2.2 State-level regulatory proceedings implementing targets
Senate Bill (SB) 3507 created Public Utilities Code Sections 454.51 and 454.52, which mandated
the “Integrated Resource Plan” (IRP) proceeding at the CPUC.8 The IRP proceeding ensures that
load serving entities (LSEs) meet targets that allow the electricity sector to contribute to
California’s economy-wide greenhouse gas (GHG) emissions reductions goals. To evaluate
anticipated needs, the proceeding conducts a 10-year forecast of the following:
● System needs (reliability needs of the overall electric system);
● Local needs (reliability needs specific to areas with transmission limitations); and
● Flexibility needs (such as the resources needed to integrate renewables).
When needs are identified, the CPUC authorizes procurement in the form of a Commission
Decision.
IRP modeling produces 10-year look-ahead portfolios, which are refreshed every two years to
incorporate the latest LSE procurement status and plan information. The current “Preferred
System Plan” is available online at the IRP website.9 The CPUC regularly submits 10-year look-
ahead IRP portfolios to the California Independent System Operator (CAISO), to enable the
CAISO to perform grid power flow modeling and identify future transmission upgrades which
may be needed to accommodate high levels of renewable energy infrastructure expansion. This
Oct. 11, 2022 Item #12 Page 58 of 560
20
power flow modeling occurs in the CAISO Transmission Planning Process (TPP).10 The CPUC 10-
year look-ahead portfolios for TPP are summarized in a regular report, “Modeling Assumptions
for TPP.”11 This document specifies high-resolution location and magnitude of resources of each
type needed to meet State GHG targets for the electric sector. This information helps State
agencies and the local and regional LSEs work together iteratively toward common goals.
For the San Diego RDF, the CPUC IRP modeling data12 were used as a starting point to more
closely examine existing conditions and current development activity at the county level. These
data were paired with the 2050 EER modeling results to map a plausible trajectory from current
conditions, through the TPP’s 10-year planning horizon (2032), toward an aspirational low-
carbon 2050 future for the San Diego region.
2.3 Data
2.3.1 Candidate Project Areas
To identify the resource potential of utility-scale solar and wind candidate project areas (CPAs)
in San Diego and Imperial counties, several data sources were considered: Princeton’s Net Zero
America (NZA) and REPEAT studies (2021), The Nature Conservancy’s (TNC’s) Power of Place
(PoP) study (2021), and the 2009 California Renewable Energy Transmission Initiative (RETI)
(see Appendix 2.A for a full list of spatial data sources). The REPEAT CPAs were identified as the
most recent and state-of-the-art, however, the spatial resolution is low due to the national
scale of the REPEAT analysis. This low resolution resulted in underestimate of the total land
availability; many small polygons had been removed. The PoP spatial data are also recent, but
they occur at a similar resolution as the REPEAT analysis because they cover the entire Western
U.S. Despite their relative age, this report used the RETI CPAs.13 The higher granularity and the
California-centric nature of the RETI analysis made these data more appropriate for the San
Diego region than other datasets, like the Princeton NZA dataset. RETI’s CPA creation process
aimed to identify plausible visualizations of transmission development for renewable energy
that were sufficient to meet California’s ambitious GHG emissions reduction targets. RETI
identified CPAs by applying a series of environmental and GIS-based exclusions (Figure 2.1). For
a full discussion of the spatial analysis performed to identify CPAs, see the NREL “Greening the
Grid” toolkit (technical potential economic potential, and market potential assessments).14 For
a full list of site suitability criteria that were applied to the RETI CPAs in this analysis, see
Appendix Table 2.B.1, 2.B.2, and 2.B.3.
Oct. 11, 2022 Item #12 Page 59 of 560
21
Figure 2.1 A diagram of the CPA creation process for the RETI analysis. For more information and additional
resources and case studies, see reading list provided by the Greening the Grid Initiative.15
In addition to utility-scale CPAs in non-urban settings provided by RETI, this analysis considers
CPAs within densely populated areas, or “infill CPAs.” The infill CPAs are added from a dataset
under development by TNC in an update to the 2019 PoP study. Finally, this report considers
the potential capacity and costs for rooftop solar in the San Diego region using spatial building
footprint data from Microsoft.16
2.4 Methods, Assumptions, Total Resource Availability, and Least-Cost Areas
2.4.1 RDF Candidate Project Areas and Downscaling
To identify low-impact, high-quality areas for renewable electricity development, this analysis
used open-source QGIS software to constrain and analyze CPAs within San Diego and Imperial
counties.i This section begins with the RETI CPAs in the San Diego region and excludes
Conserved Lands identified by SANDAG.17 Lacking equivalent conservation land data for
Imperial County, this analysis relies on the baseline RETI environmental exclusions in that
County (see Appendix 2.B site suitability criteria). All utility-scale CPAs smaller than one square
kilometer (km²) are excluded as unsuitable for development, whereas infill solar polygons of
any size are retained. Based on satellite data, there are a total of 266 Megawatts (MW) over all
existing and solar and wind developments in the region. These were included in the chapter’s
“preliminary scenario” maps, (existing sites above 10 MW were converted into files created
from Google Satellite images and planned sites were digitized from EIR plant maps using the
QGIS Georeferencer tool), and these existing facility areas were erased from the generic future
Candidate Project Areas. To divide the CPAs into developable sites, a grid of 4 km² for solar and
36 km² for wind is overlaid on the sites. Using nameplate power density assumptions of 30 MW
per km² (MW/km²) for solar18 and 2.7 MW/km² for wind,19 CPAs that produce roughly 100 MW
i See Appendix 2.A for Spatial Data Sources used, Appendix 2.C for Key Assumptions, and Appendix 2.D for the
QGIS Processing Modeler.
Oct. 11, 2022 Item #12 Page 60 of 560
22
each are created, which is a typical capacity for project modeling. Finally, as utility-scale solar
provides higher land use efficiency than utility-scale wind for all areas of overlap, solar is
prioritized over wind.20,21
2.4.1.1 Energy Production Estimates
The formula below estimates the total annual electricity generation for each CPA polygon: 𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃 𝑑𝑑𝑃𝑃𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑 (𝑀𝑀𝑀𝑀/𝑘𝑘𝑘𝑘2) ∗𝑎𝑎𝑃𝑃𝑃𝑃𝑎𝑎 (𝑘𝑘𝑘𝑘2)∗𝑐𝑐𝑎𝑎𝑐𝑐𝑎𝑎𝑐𝑐𝑑𝑑𝑑𝑑𝑑𝑑 𝑓𝑓𝑎𝑎𝑐𝑐𝑑𝑑𝑃𝑃𝑃𝑃∗8760 (ℎ𝑃𝑃𝑜𝑜𝑃𝑃𝑑𝑑 𝑑𝑑𝑑𝑑 𝑎𝑎 𝑑𝑑𝑃𝑃𝑎𝑎𝑃𝑃)=𝑎𝑎𝑑𝑑𝑑𝑑𝑜𝑜𝑎𝑎𝑎𝑎 𝑔𝑔𝑃𝑃𝑑𝑑𝑃𝑃𝑃𝑃𝑎𝑎𝑑𝑑𝑑𝑑𝑃𝑃𝑑𝑑 The nameplate capacity, or expected peak instantaneous output, is calculated using the power
density assumptions stated above. The annual generation in MW hours (MWh) is calculated for
each CPA polygon by first multiplying the hours in a year (8,760 hours) and a given capacity
factor, or percentage of time when the site is expected to produce electricity. For utility-scale
solar, the capacity factor is assumed equal to the fixed-tilt solar value in the urban areas
(rooftop, infill, and brownfield sites), and the tracking value in non-urban areas. This is because
tracking technology requires more space (wider row-spacing) and in non-urban areas there is
more likely to be larger developments on open land suitable for less-dense tracking technology.
To identify urban areas, the 2019 US Census Urban Area dataset was used.22
For brownfield solar and wind, data from the US Environmental Protection Agency’ (EPA’s) “RE-
Powering America” initiative are used. RE-Powering America’s Land is an EPA initiative that
encourages renewable energy development on current and formerly contaminated lands,
landfills, and mine sites when such development aligns with the community’s vision for the
site.23 For most sites, the available data include an estimated magnitude of the resource
potential. For sites where there is no estimated resource potential, a value of 5 MW is
assumed.
For offshore wind, CPA data from the Princeton REPEAT study are used.24 There is high
uncertainty regarding cost and economically viable offshore wind resource potential for the San
Diego region, and thus it has not been incorporated into the scenario analysis, but the
candidate project areas are shown for context.
For wave energy, data from the Electric Power Research Institute (EPRI) study “Mapping and
Assessment of the United States Ocean Wave Energy Resource” are used.25 The total available
wave energy resource along the outer continental shelf (notional 200 m depth contour) for the
Southern California region is 43 TWh per year. The technically recoverable energy for this
resource is 68%. This results in 29 TWh technically recoverable energy annually (assuming 15
MW/km packing density). There is high uncertainty regarding cost and economically viable
wave resource potential for the San Diego region, and thus it has not been incorporated into
the scenario analysis; however, the candidate project areas are shown for context. Wave,
Oct. 11, 2022 Item #12 Page 61 of 560
23
floatovoltaics, and offshore wind energy technologies could be incorporated into future
scenarios if new data demonstrates commercial viability.i
This analysis compares the magnitude of estimated renewable resource potential with the
anticipated electricity demand for the San Diego region in 2050. Anticipated demand is based
on the EER model’s Central Case, where the demand for Southern California is downscaled to
San Diego by applying the percentage of Southern California population in San Diego (13.75%).
This downscaling method is consistent with methods used in the literature. See for example the
Princeton Net Zero America Project. Next, the downscaling method accounts for existing and
planned wind and solar generation within the San Diego region. Data from the EPA’s EIA-860
Form26 were used to identify 470 MW of existing and planned wind and solar capacity.
Excluding the 470 MW from the downscaled electricity demand, a balance of 49,979 Gigawatt
hours (GWh) of electricity generation is needed to achieve a 100% renewable target. The
difference between this value and the amount identified through satellite imagery in the
preliminary maps is ignored, due to lack of clear data indicating whether additional capacity will
come to fruition.
Using the nameplate calculations described above, Table 2.1 shows that the total potential
utility-scale, rooftop, brownfield, and infill annual generation from wind and solar CPAs within
the San Diego region is 113,523 GWh. This is 63,544 GWh above forecasted demand. Figure 2.2
shows the relative capacities of solar and wind with and without infill compared to the
estimated demand. Solar resources account for more than 80% of overall renewable resource
potential in the region.
i Floatovoltaics in particular are just emerging as a technically feasible but commercially unproven technology that
could benefit the region. See Appendix 2.E Floatovoltaics for more details.
Oct. 11, 2022 Item #12 Page 62 of 560
24
Table 2.1 Candidate project areas and total annual resource potential in San Diego County and Imperial County.
Utility-scale resources refer to large scale projects for solar, wind, and geothermal resources. Resources beyond
utility-scale include resources from smaller scale projects, including rooftop solar, infill solar or wind, and
brownfield solar or wind. Geothermal candidate project areas are discrete areas and are listed as the number of
potential sites rather than area.
San Diego County San Diego County + Imperial County
Findings Utility-Scale
Only
With Rooftop, Infill,
and Brownfield
Utility-Scale
Only
With Rooftop, Infill,
and Brownfield
Solar
Area (sq km) 661 985 3,417 3,741
Potential (GWh) 54,784 102,925 84,888 109,742
Onshore Wind
Area (sq km) 86 86 3,712 3,749
Potential (GWh) 730 730 22,540 22,572
Offshore Wind
Area (sq km) 1,660 1,660 1,660 1,660
Potential (GWh) 9,869 9,869 9,869 9,869
Geothermal
Number of sites 0 0 5 5
Potential (GWh) 0 0 10,680 10,680
Total Renewable Resource
Potential (GWh) 65,382 113,523 117,296 142,183
Estimated 2050 Electricity
Demand (GWh) 49,979
Electricity Resource Balance
(GWh) 15,403 63,544 67,317 92,204
Oct. 11, 2022 Item #12 Page 63 of 560
25
Figure 2.2 San Diego region’s annual renewable resource energy potential (GWh) by resource type. The leftmost
bar shows the annual generation in the base case, which is utility-scale production only (includes solar, onshore
wind). Note that geothermal and offshore wind resources are beyond the jurisdiction of San Diego regional
authorities). The middle bar shows the annual generation in the base case plus geothermal, rooftop solar, solar
infill, and brownfield wind and solar development. The rightmost bar is the estimated 2050 electricity demand
(gray) based on the downscaled Central Case scenario of the EER model for 2050. This figure shows that, in both
cases, the resource potential in the region exceeds demand.
2.4.2 Levelized Cost of Energy (LCOE) Estimates
To estimate the wholesale cost of electricity for utility-scale CPAs, we calculate the levelized
cost of energy (LCOE), or the adjusted cost of electricity production per MWh. Calculations first
add the solar and wind plant capital cost and the costs of interconnection to the grid. The plant
capital cost reflects a capital expenditure cost assumption for utility-scale solar (1,599 $/kW)
and wind (1,556 $/kW) from the National Renewable Energy Lab (NREL) Annual Technology
Baseline (ATB).27 The interconnection cost is based on the distance to the nearest substation
and a transmission cost assumption of 2,948 $/MW-mile from the NREL ReDS model.28 These
values were cross-referenced with the latest Western Electric Coordinating Council
Transmission Cost Calculator and the CAISO Participating Transmission Owner Per-Unit Costs to
confirm reasonableness. These calculations use a substation dataset from the Department of
Homeland Security29 and the interconnection distance is the Euclidean distance to the nearest
substation.
Oct. 11, 2022 Item #12 Page 64 of 560
26
𝐿𝐿𝑃𝑃𝑐𝑐𝑎𝑎𝑑𝑑𝑑𝑑𝑃𝑃𝑑𝑑−𝑑𝑑𝑐𝑐𝑃𝑃𝑐𝑐𝑑𝑑𝑓𝑓𝑑𝑑𝑐𝑐 𝑑𝑑𝑑𝑑𝑑𝑑𝑃𝑃𝑃𝑃𝑐𝑐𝑃𝑃𝑑𝑑𝑑𝑑𝑃𝑃𝑐𝑐𝑑𝑑𝑑𝑑𝑃𝑃𝑑𝑑 𝑐𝑐𝑃𝑃𝑑𝑑𝑑𝑑=𝑔𝑔𝑃𝑃𝑑𝑑𝑃𝑃𝑃𝑃𝑑𝑑𝑐𝑐 𝑑𝑑𝑑𝑑𝑑𝑑𝑃𝑃𝑃𝑃𝑐𝑐𝑃𝑃𝑑𝑑𝑑𝑑𝑃𝑃𝑐𝑐𝑑𝑑𝑑𝑑𝑃𝑃𝑑𝑑 𝑐𝑐𝑃𝑃𝑑𝑑𝑑𝑑 �$𝑀𝑀𝑀𝑀 𝑘𝑘𝑑𝑑�∗ 𝐶𝐶𝑃𝑃𝐶𝐶 𝑐𝑐𝑎𝑎𝑐𝑐𝑎𝑎𝑐𝑐𝑑𝑑𝑑𝑑𝑑𝑑 (𝑀𝑀𝑀𝑀)∗𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑎𝑎𝑑𝑑𝑐𝑐𝑃𝑃 𝑑𝑑𝑃𝑃 𝑑𝑑𝑜𝑜𝑠𝑠𝑑𝑑𝑑𝑑𝑎𝑎𝑑𝑑𝑑𝑑𝑃𝑃𝑑𝑑 (𝑘𝑘𝑑𝑑)
For remote-located candidate project areas, such as those in Imperial County, transmission
deliverability upgrade costs are added to the capital cost based on Table 2.F in Appendix 2.F,
“Transmission Upgrade Options and Costs.” The selected transmission upgrade has a cost of
$89 million, and transmission capability would increase due to an Area Delivery Network
Upgrade (ADNU) of 2067 MW. Transmission upgrade assumptions are discussed in more detail
in section 2.4.3.
𝐼𝐼𝑓𝑓 𝐶𝐶𝑃𝑃𝐶𝐶 𝑑𝑑𝑑𝑑 𝑎𝑎𝑃𝑃𝑐𝑐𝑎𝑎𝑑𝑑𝑃𝑃𝑑𝑑 𝑠𝑠𝑃𝑃ℎ𝑑𝑑𝑑𝑑𝑑𝑑 𝑑𝑑𝑃𝑃𝑎𝑎𝑑𝑑𝑑𝑑𝑘𝑘𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑃𝑃𝑑𝑑 𝑐𝑐𝑃𝑃𝑑𝑑𝑑𝑑𝑑𝑑𝑃𝑃𝑎𝑎𝑑𝑑𝑑𝑑𝑑𝑑,𝑑𝑑ℎ𝑃𝑃𝑑𝑑 𝑁𝑁𝑃𝑃𝑑𝑑𝑃𝑃𝑃𝑃𝑃𝑃𝑘𝑘 𝑈𝑈𝑐𝑐𝑔𝑔𝑃𝑃𝑎𝑎𝑑𝑑𝑃𝑃 𝐶𝐶𝑃𝑃𝑑𝑑𝑑𝑑 = �$89 𝑘𝑘𝑑𝑑𝑎𝑎𝑎𝑎𝑑𝑑𝑃𝑃𝑑𝑑2067 𝑀𝑀𝑀𝑀 �∗ 𝐶𝐶𝑃𝑃𝐶𝐶 𝑐𝑐𝑎𝑎𝑐𝑐𝑎𝑎𝑐𝑐𝑑𝑑𝑑𝑑𝑑𝑑 (𝑀𝑀𝑀𝑀)
The estimation of annual payments assumes a capital recovery factor of 7.36%.30 The LCOE is
then calculated using the formula below to find the ratio of payments to generation, or the
wholesale cost per MWh of electricity. 𝐿𝐿𝑃𝑃𝐿𝐿𝑃𝑃𝑎𝑎𝑑𝑑𝐿𝐿𝑃𝑃𝑑𝑑 𝑐𝑐𝑃𝑃𝑑𝑑𝑑𝑑 𝑃𝑃𝑓𝑓 𝑃𝑃𝑑𝑑𝑃𝑃𝑃𝑃𝑔𝑔𝑑𝑑= (𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐+𝑐𝑐𝑖𝑖𝑐𝑐𝑖𝑖𝑖𝑖𝑐𝑐𝑖𝑖𝑖𝑖𝑖𝑖𝑖𝑖𝑐𝑐𝑐𝑐𝑐𝑐𝑖𝑖𝑖𝑖+𝑖𝑖𝑖𝑖𝑐𝑐𝑛𝑛𝑖𝑖𝑖𝑖𝑛𝑛 𝑢𝑢𝑐𝑐𝑔𝑔𝑖𝑖𝑐𝑐𝑔𝑔𝑖𝑖𝑔𝑔)∗𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐𝑐 𝑖𝑖𝑖𝑖𝑐𝑐𝑖𝑖𝑟𝑟𝑖𝑖𝑖𝑖𝑟𝑟 𝑓𝑓𝑐𝑐𝑐𝑐𝑐𝑐𝑖𝑖𝑖𝑖𝑐𝑐𝑖𝑖𝑖𝑖𝑢𝑢𝑐𝑐𝑐𝑐 𝑔𝑔𝑖𝑖𝑖𝑖𝑖𝑖𝑖𝑖𝑐𝑐𝑐𝑐𝑐𝑐𝑖𝑖𝑖𝑖
Incorporating tax incentives exceeded the scope of this analysis. The LCOE calculations were
provided for ordinal ranking only, not intended to be used for budgeting or investment
decisions. Similarly, State Resource Adequacy (RA) payment programs for reliability were
beyond the scope of this chapter’s LCOE calculations. RA payment structures are changing over
time, and the timing of the peak demand hour on the grid is also changing over time as installed
solar capacity increases. Incorporation of tax incentives and rebates such as RA payments may
be considered in future work.
For infill solar development, the PoP CPAs are used and the annual generation formula above is
applied. To calculate the LCOE, this analysis uses 2.7 $/W as the capital cost for rooftop solar
installation, which is the average of large and small non-residential capital cost from the
Lawrence Berkeley National Lab’s (LBNL’s) Tracking the Sun Report.31 There is no additional
interconnection cost, as it is assumed within the LBNL capital cost. The same capital recovery
factor of 7.36% is applied and the LCOE is calculated using the formula above. The range of
LCOE across both infill and utility-scale solar and wind CPAs in San Diego county is shown in
Figures 2.3 (solar) and 2.4 (wind). Figure 2.5 shows the combined wind and solar CPAs across
San Diego and neighboring Imperial County. These figures show the full set of possible wind and
solar CPAs.
Oct. 11, 2022 Item #12 Page 65 of 560
27
Figure 2.3 Utility-scale solar candidate project areas in the San Diego region by LCOE per CPA. Darker colors represent higher cost per CPA and the least cost
CPAs are in yellow. These are the full set of possible solar CPAs in the region. Oct. 11, 2022Item #12 Page 66 of 560
28
Figure 2.4 Utility-scale onshore wind candidate project areas in the San Diego region by LCOE per CPA. Darker colors represent higher per CPA costs and the
least cost CPAs are in yellow. These are the full set of possible wind CPAs in the region, including areas that may be better developed as solar installations.Oct. 11, 2022Item #12 Page 67 of 560
29
Figure 2.5 Solar and wind candidate project areas in San Diego (left) and Imperial (right) counties by LCOE per CPA. Darker colors represent higher per CPA
costs and the least cost CPAs are in yellow. These are the full set of possible solar and wind CPAs in the two counties.Oct. 11, 2022Item #12 Page 68 of 560
30
Figure 2.6 Additional candidate project areas beyond those utility-scale solar and onshore wind resources mapped
in Figures 2.3-2.5 in San Diego and Imperial counties. CPAs for offshore wind (dark blue, shown for context but not
included in projections elsewhere), brownfield solar (red dots), brownfield wind (blue dots), rooftop solar (black
areas), wave energy (green line, shown for context but not included in projections elsewhere), and geothermal
development (green circles) are included here. The offshore wind CPAs are from the REPEAT dataset, brownfield
CPAs are from the EPA RE-powering America dataset, and geothermal CPAs are from the RETI dataset. The
offshore wind CPAs show that the LCOE is between $133-672 per MWh.i
i The forthcoming paper is in review in the journal Proceedings of the National Academy of Sciences: Wu, Grace,
Ryan Jones, Emily Leslie, James Williams, Andrew Pascale, Erica Brand, Sophie Parker, Brian Cohen, Julia Prochnik,
and Joe Fargione. “Minimizing Conservation Impacts of Net Zero Energy Systems in the Western United States.”
Submitted: June 14, 2022. In review.
Oct. 11, 2022 Item #12 Page 69 of 560
31
2.4.3 Transmission
The EER model shows increased electricity demand as sectors electrify to decarbonize. As a
result of this increased demand, most site selection scenarios will require an increase in the
capacity of transmission to avoid higher costs32 and curtailment of renewable resources.33
Increased transmission capacity will also enable greater reliability due to interconnection with
more resources that smooth out the hourly profiles of variable power generation.34
Appendix 2.F shows costs and timelines of the six identified major transmission upgrade
options for the region from an analysis by the CAISO.35 While transmission upgrades will be
overseen by State agencies and the local utility, the process will interact with local communities
where new transmission upgrades are sited. The planning process for these six transmission
upgrades is still underway. These are transmission upgrades that have been studied by the
CAISO, and are upgrade options in State-level modeling for the State's Integrated Resource Plan
(IRP). In the IRP proceeding, a Statewide 2032 portfolio with high penetration of renewables is
modeled and least-cost transmission upgrades are selected from this list of options to support
and enable transmission planning for the State’s clean energy and climate goals.
The updated document “Modeling Assumptions for CAISO 2022-2023 Transmission Planning
Process,” released in Q4 2021,11,36, sheds light on which transmission upgrades on the list are
identified as likely justified in IRP modeling: Greater Los Angeles area, Tehachapi, San Diego and
Imperial, Southern Nevada, Southern PG&E, and Northern California. The report states that
“the transmission constraint exceedance in the San Diego & Imperial area could be resolved by
a transmission upgrade that would increase the estimated full capacity deliverability status
(FCDS) transmission capacity by 2,000 MW, with a CAISO estimated cost of $89 million and 18-
month time to complete.” This analysis assumes that this upgrade will occur and that it will be
sufficient to accommodate additional electricity transmission between San Diego and Imperial
counties. This is upgrade number five (highlighted green) in Appendix 2.F, Table 2.F,
“Transmission Upgrades and Costs in San Diego Gas & Electric (SDG&E) Territory.” This upgrade
is incorporated into the LCOE for each Imperial County CPA, on a prorated basis. Any
transmission upgrade may or may not happen and that the process is iterative until the CAISO
Board of Governor approves it and construction begins.
However, the timeframe of IRP modeling ends in 2032 and further upgrades beyond this are
likely necessary in the 2050 timeframe, so the stated LCOE values represent the low end of the
estimated costs to decarbonize the grid by 2050. The CAISO is separately undertaking a 20-year
transmission outlook study process, so clean energy planning efforts in the San Diego region
should incorporate findings from the CAISO 20-year transmission outlook study as they come
available.37
Oct. 11, 2022 Item #12 Page 70 of 560
32
2.4.4 Energy Storage
Any portfolio that includes high levels of wind and solar capacity will likely need energy storage
to provide reliability and avoid energy curtailment.38 Curtailment means reducing output of a
renewable resource below what it would otherwise produce, typically occurring when supply
exceeds demand. It is calculated by subtracting the energy that was actually produced from the
amount of electricity forecasted to be generated.
Energy storage in the 2032 IRP portfolio includes both battery energy storage (4-hour duration)
and long duration energy storage in the form of pumped storage hydropower (PSH). Batteries
come in many forms and utilize a range of chemical reactions to store energy. PSH is a system
where water is pumped from a lower reservoir or body of water to an uphill reservoir when
there is surplus renewable energy generation (for example, during midday when solar
generation is high and demand is low). The water is then released from the upper reservoir to
the lower reservoir through hydropower turbines when demand is high and renewable energy
generation is low (for example, at night when households are using energy and the sun is not
shining). The potential battery storage and PSH locations and energy storage amounts are
shown in Figure 2.7 below. Both technologies are mature enough to allow for their inclusion in
planning, and they can meet different planning needs for the San Diego region. In particular,
battery system costs tend to mostly reflect the total energy stored, while PSH system costs are
driven more by the desired power capacity. This reality justifies the use of batteries for short-
duration storage and PSH for longer-duration storage. Longer-duration options also tend to
become more cost-competitive when optimizing over longer decision timeframes.39
Fuel cells were not included due to lack of spatially explicit site suitability data for this
technology, but future work could possibly include fuel cell siting as well. SDG&E’s 2022 “Path
to Net Zero” study estimates that by 2045, there will be demand for 6.5 million metric tons of
clean hydrogen across the economy, 80% of which is projected to be used to enhance the
reliability of the electric supply.40
Oct. 11, 2022 Item #12 Page 71 of 560
33
Figure 2.7 Potential energy storage sites per “Modeling Assumptions for 2022-23 Transmission Planning Process”
storage system in the San Diego region.11 Battery energy storage (gray) and pumped storage hydropower (red) are
included. Battery energy storage is measured in megawatts and the sizes of the gray circles correspond to energy
storage capacity. These are potential sites that can be built to increase regional energy storage, but they are not
guaranteed.
2.4.5 Initial Scenarios
To sequence the CPA development needed to achieve 100% renewable energy by 2050, we use
10-year timesteps from the EER model’s Central Case. The estimated electric demand forecast
for San Diego is identified starting in 2030. County-level demand is assumed to be a fraction of
Oct. 11, 2022 Item #12 Page 72 of 560
34
State demand in proportion to the county’s population as a fraction of the State.i We
implement a site selection algorithm modeled after Wu et al. (2020)1 and run two initial
scenarios:
● Scenario 1: San Diego-only (utility-scale solar and wind resources within the San Diego
region). See Figure 2.10 in the Results section.
● Scenario 2: San Diego and Imperial Scenario (utility-scale solar, wind, and geothermal
resources within San Diego and Imperial Counties). See Figure 2.11 in the Results
section.
For geothermal resource analysis, the E3 and CPUC Statewide Integrated Resource Plan (R-20-
05-003) estimated geothermal resource potential in neighboring Imperial County is used (no
geothermal sites have been identified in San Diego county).41 Several geothermal sites are
identified in Imperial County with total generation of 10,680 GWh/year of electricity (seen as
green circles in Figures 2.6 and 2.11). This analysis assumes these plants become fully
operational by 2030 and supply the remaining capacity to San Diego after satisfying Imperial’s
electricity demand. The total available generation for the San Diego region is downscaled using
methodology from Section 2.4.1 and it is assumed that 94.7% of the power generated will go to
San Diego for an estimated geothermal resource of 10,113 GWh. In the San Diego and Imperial
Scenario, 10,113 GWh is subtracted from all three time-steps of the forecasted electricity
demand.
2.4.6 Alternate Scenarios
In addition to the least-cost site selection scenarios, we analyze alternate scenarios that factor
in five new policy-relevant variables: 1) environmental impact, 2) pecuniary value, 3) carbon
sequestration potential, 4) developable land, and 5) prioritizing rooftop and infill solar. For each
scenario, the methodology from Section 2.1 identifies the LCOE and available capacity of CPAs
under more constrained land-use assumptions within the boundaries of San Diego County.
Scenario 3: Minimize Loss of Land with High Conservation Value (Figure 2.12)
To show renewable energy site selection under a scenario in which environmental impact
minimization is highly prioritized, the most low-impact siting level areas for wind and solar
resource potential areas in the West are used (SL 4) from the Wu et al. (2020)1 study on low-
impact renewable energy siting. The study incorporated high-resolution ecological and
agricultural datasets to identify sites with low impact on the environment. Areas of
conservation emphasis from the San Diego region’s Multiple Species Conservation Plan were
also removed. Data were reviewed to ensure this scenario did not include any development on
designated critical habitat for species of local concern, such as the endangered Peninsular
i See Appendix 2.G for more details.
Oct. 11, 2022 Item #12 Page 73 of 560
35
Bighorn Sheep. This scenario should not be used as a substitute for site-specific surveys and
environmental impact reports in the style of Endangered Species Act, California Environmental
Quality Act or the National Environmental Protection Act. That type of site-specific project
development work is necessary for investment decisions and is beyond the scope of this
analysis. In this scenario all urban infill CPAs are included because of lower environmental
impacts in urban areas. Rooftop solar is not included because of its high costs.
Scenario 4: Minimize Loss of Land with High Pecuniary Value (Figure 2.13)
To identify CPAs that factor in the pecuniary value of land, the Cropland Data Layer raster from
the US Department of Agriculture is used.42 To analyze the raster with the CPA sites, the zonal
statistics tool is run on a 0.10 sq km grid to identify the mode land use within each cell. To
restrict the CPAs to land with low pecuniary value, the data is filtered to include only
“Fallow/Idle Cropland,” “Grassland/Pasture,” “Forest,” “Wetland,” “Shrubland,” and “Barren.”
Urban infill is excluded in this scenario because of the higher relative value of land in the urban
environment. Rooftop solar is not included because of its high costs.
Scenario 5: Minimize Loss of Land with High Carbon Sequestration Potential (Figure 2.14)
In the third scenario, lands which have high carbon sequestration potential are excluded. We
rely on analysis from Chapter 5, which identifies carbon pools within San Diego county.
SANDAG’s Vegetation Dataset is also used, which classifies the vegetation types in the county.43
The data are filtered to vegetation with high CO2 sequestration potential (see Appendix 2.H for
full list). These lands are excluded from the renewable resource potential to find CPAs under a
scenario that prioritizes natural carbon sequestration. Urban infill sites are included in this
scenario because of the lower carbon sequestration potential of infill land. Rooftop solar is not
included because of its high costs.
Scenario 6: Utilize only Developable Land (Figure 2.15)
This scenario minimizes legal and social barriers by selecting sites that exist on land that is
identified as developable and is thus assumed to be subject to fewer legal and social barriers.
SANDAG’s Developable Land dataset is utilized, which classifies “Vacant” and “Agricultural
Redevelopment” as suitable for development.44 In this scenario, urban infill sites and rooftop
solar are excluded as having higher barriers to development.
Scenario 7: Infill and Rooftop Solar Scenario (Figure 2.16)
Using publicly available building footprint spatial data published by Microsoft, the GIS analysis
of public and private rooftops in the San Diego region identified approximately 2.7 billion
square feet (61,000 acres) of usable roof area. This resulted in a total estimated region-wide
rooftop solar potential capacity of approximately 3,360 MW AC.16 At an assumed 20% capacity
Oct. 11, 2022 Item #12 Page 74 of 560
36
factor based on NREL System Advisor Model simulations,45 this corresponds to 5,930 GWh
annual generation region-wide. This is 12% of estimated 2050 electricity demand.
A recent solar siting survey by Clean Coalition incorporates additional information about how
much distributed generation could be accommodated on specific electric distribution system
circuits in the City of San Diego, based on Integration Capacity Analysis (ICA) data from
SDG&E.46 However, the geographic extent of this analysis includes only the City of San Diego
and no other cities or the unincorporated county. Figure 2.3 shows that these non-residential
solar systems are estimated to be on the high end of candidate project costs, with an average
LCOE of $92/MWh. Future analyses should also perform a detailed ICA, expanding beyond the
City of San Diego to include other jurisdictions throughout the region, to confirm distribution
grid capability to accommodate rooftop solar resources.
The rooftop solar potential estimate is based on existing buildings only, and the rooftop
resource potential would increase if it were updated to additionally include anticipated new
buildings in 2050. Future analyses should estimate the 2050 rooftop solar potential, using the
SANDAG 2050 forecasted footprint of developed land. Relevant GIS data are available through
the SanGIS portal.47 At a high level, urban land area in the U.S. is expected to grow by 1-4 times
by 2100, thereby increasing the anticipated rooftop solar potential.48
The Climate Equity Index (CEI) was created for the City of San Diego in 2019 and updated in
2020 through a stakeholder process to address environmental justice and social equity.49 The
CEI measures access to opportunity at the census tract level through 35 indicators covering
health, housing, socioeconomic, mobility, and environmental categories (Figure 2.8). As with
the SB 535 Disadvantaged Community designation, the communities that score as having “low
access” are primarily in the southern areas of San Diego including Barrio Logan, Lincoln Park,
Mountainview, and the Tijuana River Valley.50
SANDAG has identified Communities of Concern and has a stated goal to ensure that Low
Income and Minority communities benefit from public investments, in particular from
transportation and mobility investments. These county-designated Communities of Concern are
spatially distributed throughout the county (Figure 2.9).51 The highest concentration occurs in
the southwest part of the county on the coast.
These communities in the southwest part of the county are also designated Disadvantaged
Communities (DAC) by the State (Figure 2.9). They are identified by the California
Environmental Protection Authority as disproportionately burdened by and vulnerable to
multiple sources of pollution.52 Under California State law (SB 535 and AB 1550), DACs are
specifically targeted for investment: 25% of State GHG Cap and Trade funds will be invested in
and for Disadvantaged Communities. Known as California Climate Investments (CCI),53 these
Oct. 11, 2022 Item #12 Page 75 of 560
37
funds are aimed at improving public health, quality of life and economic opportunity in
California's most burdened communities while simultaneously reducing pollution that causes
climate change.
Figure 2.8 Communities identified as having Very Low (dark blue), Low (blue), or Moderate (light green) access to
opportunity through the San Diego Climate Equity Index. The CEI scoring is averaged across 41 indicators. For more
details on each indicator, including source information and methods, refer to Appendix B of the City of San Diego's
2019 Climate Equity Index Report.49 The 2021 CEI version added three indicators (Ozone, PM2.5, and Diesel
Particulate Matter), replaced the Heart Attack Fatalities indicator for Cardiovascular Disease, and separated the
Proximity to Waste Sites indicator into four separate indicators: Toxic Releases from Facilities, Clean Up Sites,
Hazardous Waste Generators and Facilities, and Solid Waste Sites and Facilities. Working with community-based
organizations, the City has defined climate equity as efforts addressing historical inequities suffered by people of
color, allowing everyone to fairly share the same benefits and burdens from climate solutions and attain full and
equal access to opportunities regardless of one’s background and identity.
Oct. 11, 2022 Item #12 Page 76 of 560
38
Figure 2.9 State-identified Disadvantaged Communities (Cal Enviroscreen 4.0) and State-identified Low-Income
Communities (Assembly Bill (AB) 1550). These communities have been specifically targeted for California Climate
Investments (Greenhouse Gas Reduction Fund and appropriated by the Legislature). These funds aim to improve
public health, quality of life, and economic opportunity in California’s most burdened communities while reducing
pollution that causes climate change. These funds must be used for programs that further reduce emissions of
greenhouse gases.
A scenario maximizing rooftop and urban infill solar and energy storage in these frontline
communities could result in 5-30% reduction in impacts to previously undisturbed land
(greenfield development). Such a scenario could also have multiple co-benefits, including
progress toward county-level and higher-level equity goals, job creation in “green job” or
“cleantech” sectors with corresponding well-paying wages,54 reduced GHG emissions from land
use change for energy infrastructure, and availability of supplemental funding sources (e.g.,
from the State). Additionally, rooftop solar programs can be designed in such a way that they
can lower energy bills for low-income residents, for instance through rooftop solar incentive
programs. Further study to quantify the local economic and public health benefits of such a
scenario would be valuable; however, adequate information currently exists to support early
action to pursue growth in rooftop solar, especially in communities overly burdened with
pollution and having low access to opportunities.
Oct. 11, 2022 Item #12 Page 77 of 560
39
Scenario 8: Mixed-mode scenario (Figure 2.17)
Because there are inherent trade-offs between and across scenarios, a mixed-mode multi-
benefit scenario is identified, to provide an example of balancing many competing priorities.
This scenario includes:
● Rooftop solar throughout the county for the land-sparing benefits;
● High utilization of brownfield wind and solar sites;
● Lower-cost (but higher land-area) utility-scale wind and solar on SANDAG “developable”
lands;
● Lower-cost utility-scale solar and geothermal from Imperial County, with corresponding
transmission upgrades; and
● 4-hr battery energy storage and long-duration energy storage (pumped hydropower
storage), for reliability.
Energy storage in this scenario occurs at levels below the commercial interest indicated in the
CAISO interconnection queue (7600 MW in San Diego County as of January 2022), but much
higher than any deployment rate in history.
The level of rooftop solar in this scenario assumes an increased level of adoption of rooftop
solar in the communities identified as having very low, low, and moderate access to
opportunity (per the San Diego Climate Equity Index, as seen in Figure 2.9) than in other
communities in the region. This increase is driven by the State mandate requiring 25% of GHG
Cap and Trade funds be invested in and for Disadvantaged Communities per SB 535.
This scenario is the only one that includes the brownfield sites identified by the US EPA RE-
powering America Initiative, which encourages renewable energy development on current and
formerly contaminated lands, landfills, and mine sites when such development is aligned with
the community’s vision for the site.23 Due to the barriers to development known to occur on
contaminated soils, the total solar brownfield resource potential was discounted by 50% to
account for uncertainty.
Scenario 9: High Rooftop, Low-impact (Figure 2.18)
This scenario is designed to maximize rooftop and infill solar, avoid impacts to important
conservation lands per the Multiple Species Conservation Plan, avoid impacts to high-value
agricultural lands, and include lower-cost resources from nearby jurisdictions, such as Imperial
County. Unlike Scenario 8, no brownfield sites are included, no SANDAG “developability” screen
is applied, and high protections for conservation and agricultural lands are assumed. The
location of the resources is not limited to San Diego Community Power (SDCP) jurisdiction
boundaries, but the total generation is compared to SDCP estimated demand.
Oct. 11, 2022 Item #12 Page 78 of 560
40
2.5 Results and Discussion
2.5.1 Initial Least-Cost Scenarios
The results of the least-cost scenarios are shown in Figures 2.10 & 2.11 below. Both figures
show the CPAs that the algorithms selected to produce the estimated 49,979 MWh of total
2050 electricity demand (Table 2.5). In the San Diego-only Scenario (Figure 2.10) the 2030 sites
selected based on LCOE cluster largely around Jacumba Hot Springs in the southeast and
Borrego Springs in the northeast parts of unincorporated San Diego County. In the 2040 and
2050 time-steps, CPAs closer to urban areas are selected. Few urban infill CPAs are selected in
the San Diego scenario as the LCOE for infill CPAs is relatively higher than utility-scale
development due to lower capacity factors. This lower capacity factor is in part from the use of
fixed-tilt installations that maximize land utilization in densely populated areas. The San Diego-
only scenario also requires higher overall electricity generation from renewable resources due
to the lack of geothermal resources from Imperial County. The lack of firm power, or power
that does not rely on intermittent resource availability like wind or sunshine, would also require
higher storage capacity for 100% reliance on intermittent resources. Battery energy storage and
long-duration energy storage could be deployed to meet this need in the San Diego-only
scenario. The 2020-2021 CAISO Transmission Planning model’s (base case) included 300 MW
long-duration energy storage and 660 MW of 4-hr battery energy storage in San Diego county.55
In the San Diego and Imperial Scenario (Figure 2.11) geothermal and solar resources from
Imperial County are factored into the resource potential to meet San Diego’s electricity
demand. While the area east of Jacumba Hot Springs remains an area with high commercial
interest for solar and wind development within the San Diego region, most other CPAs from the
San Diego-only Scenario are not selected as their costs are higher than resources from Imperial
County. Geothermal resources (green points) reduce the overall requirement for wind and solar
resources in either county. In the San Diego and Imperial Scenario, no infill resources are
selected due to the availability of lower-cost sites in Imperial County.
While both scenarios meet forecasted electricity demands from the Central Case of the EER
model, to ensure reliability for a 100% renewable energy supply, overcapacity is likely
necessary. In their study of overcapacity and storage to meet reliability standards across the US,
Shaner et al. (2018)34 find that, for a 75% solar 25% wind scenario, 50% overcapacity and 12
hours of storage results in 98.74% reliability.i Guerra et al. (2020) find that energy storage can
significantly reduce total system costs for grids with high (75%-90%) and ultrahigh (over 90%)
renewable energy generation share, with higher reliance on renewable sources warranting
i Importantly, this level of reliability is below current norms in the U.S., which is currently 99.97% reliable.
Policymakers may choose to aim for greater overcapacity or storage to boost reliability closer to current levels.
Oct. 11, 2022 Item #12 Page 79 of 560
41
greater capacity and duration energy storage.56 In both scenarios, there are additional CPAs
available to meet necessary overcapacity. However, the amount of overcapacity needed is
subject to uncertainty around the future availability of storage, upgrade of transmission
systems, and development of clean firm power. The degree of necessary overcapacity has been
analyzed in the broader EER energy model.
Additionally, these scenarios are snapshots of existing resource potential and availability. As
more resources come online within the San Diego region or outside of the region, such as
Imperial County resources, offshore wind or resources from out of state or Mexico, the results
of these and of the following scenarios would change. Generally, as more resources become
available to the San Diego region for utilization, the reliance on renewable resource
development within the region can be adjusted accordingly.
2.5.2 Alternate Scenarios
As policymakers consider alternate scenarios for siting renewable resources, priorities beyond
the wholesale cost of energy may factor into decision-making. Figures 2.12 through 2.17 show
solar and wind CPAs under several additional policy scenarios within the San Diego region.
Table 2.5 shows a summary of the resource potential for each scenario.
Table 2.5 Scenario summary of renewable energy resource potential and energy deficit with predicted demand. All
values are in GWh. The “deficit with demand” values are based on the EER model’s Central Case annual demand
estimates of 49,979 GWh for the San Diego region by 2050.
Scenario
number Scenario Description
Resource
Type
Resource
Potential (GWh)
Excess (Deficit) with
Demand (GWh)
Scenario 1 Least-cost (San Diego county only) Solar, Wind 49,979 –
Scenario 2 Least-cost (San Diego and Imperial counties)
Solar, Wind,
Geothermal 49,979 –
Scenario 3 Low Environmental Impact Solar, Wind 15,777 (34,202)
Scenario 4 Low Land Value Solar, Wind 52,394 2,415
Scenario 5 Carbon Sequestration Potential Solar, Wind 22,844 (27,135)
Scenario 6 Developable Solar, Wind 13,894 (36,085)
Scenario 7 Rooftop and infill solar Solar 17,478 (32,501)
Scenario 8
Mixed-mode resource mix (San Diego and
Imperial counties)
Solar, Wind,
Geothermal 50,147 168
Scenario 9
High Rooftop, Low-Impact to Conservation Lands,
Avoid Valuable Agriculture Lands (San Diego and
Imperial counties) Solar, Wind 44,177 (5,802)
Oct. 11, 2022 Item #12 Page 80 of 560
42
Figure 2.10 Least-cost site selection scenario: San Diego county only. This analysis only included utility-scale solar and onshore wind resources and selected
least-cost resources first before selecting more expensive resources. The three panels show the build out required by each year that would allow the region to
approach full energy decarbonization by 2050. Lighter colors represent CPAs that would be built earlier because they are less expensive. Blue colors are wind
resources and orange/red colors are solar resources. This scenario has an average levelized cost of energy (LCOE) of $40.65 per megawatt hour (MWh). Oct. 11, 2022Item #12 Page 81 of 560
43
Figure 2.11 Least-cost site selection scenario: San Diego and Imperial counties. This analysis only included utility-scale solar, onshore wind, and geothermal
resources and selected least-cost resources first before selecting more expensive resources. As with Figure 2.10, this shows build out over three time periods
where colors represent build out year (lighter colors are earlier) and resource (red/orange for solar, blue for wind, and green for geothermal). The inset shows
the Jacumba Hot Springs area site selection by 2050 and the area that includes the proposed/planned JVR sites. This scenario has an average LCOE of $42.04
per MWh.Oct. 11, 2022Item #12 Page 82 of 560
44
Scenario 3: Avoid Land with High Conservation Value (Figure 2.12)
The low-impact CPAs taken from Wu et al. (2020)1 reduce the resource potential by 76.5%. Prior
to removal, 1.7% of the Multiple Species Conservation Plan conservation areas were impacted
by selected sites in this scenario. About 5% of the CPAs in this scenario occurred on pre-
approved "take authorized" areas. Most remaining CPAs are in the urban infill areas, which were
included without further restriction from the previous analysis. The remaining total resource
potential is 15,777 GWh, requiring imports, rooftop solar, or brownfield site development to
achieve 100% of electricity demand.
Figure 2.12 Scenario 3: Avoid land with high conservation value. This scenario minimizes impacts to areas of high
conservation value and other areas that are environmentally sensitive or important. It does not meet regional
energy demand and is relatively more expensive (with an average LCOE of $84.5 per MWh)
Oct. 11, 2022 Item #12 Page 83 of 560
45
Scenario 4: Avoid Land with High Pecuniary Value (Figure 2.13)
The exclusion of land with high pecuniary value does not significantly lower the capacity of
utility-scale renewable generation within the San Diego region because most of the land
identified in the previous scenarios was not on high-value cropland. The resulting total resource
potential is 52,394 GWh. Therefore, if 95.4% of the resource potential on land with low value is
developed, the region would be able to achieve 100% of electricity demands with resources
within the county.
Figure 2.13 Scenario 4: Avoid land with high pecuniary value. This scenario minimizes impacts to lands with high
monetary values, such as agricultural lands or urban areas. It meets regional energy demand and is relatively less
expensive (with a mean LCOE of $42.4/MWh).
Oct. 11, 2022 Item #12 Page 84 of 560
46
Scenario 5: Avoid Land with High Carbon Sequestration Potential (Figure 2.14)
When CPAs are designed to avoid land with high carbon sequestration potential, the resulting
capacity is 22,844 GWh, or roughly one-third the original capacity. Much of the remaining CPAs
are located in the urban infill, which are included without further restrictions. In this scenario,
the region would require imports, rooftop solar, or brownfield site development to achieve
100% of electricity demand with renewable energy.
Figure 2.14 Scenario 5: Avoid land with high carbon sequestration potential. This scenario minimizes impacts to
lands with high carbon sequestration potential. It does not meet regional energy demand and is relatively expensive
(with a mean LCOE of $80.7/MWh).
Oct. 11, 2022 Item #12 Page 85 of 560
47
Scenario 6: Focus on Developable Land (Figure 2.15)
Focusing on CPAs on developable land may provide decision-makers with low-hanging fruit in
terms of ease of development. When CPAs are restricted to “Vacant” and “Agricultural
Redevelopment” land types, there is 13,894 GWh of regional resource potential. This is not
enough to fulfill the county’s electricity demand internally, but may provide a good starting
point for near-term resource development.
Figure 2.15 Scenario 6: Focus on developable land. This scenario minimizes legal and social barriers to renewable
energy development by only selecting CPAs on lands that are currently designated as “developable.” It therefore
excludes infill. It does not meet regional energy demand and is relatively less expensive (with an average LCOE of
$40.5/MWh).
Oct. 11, 2022 Item #12 Page 86 of 560
48
Scenario 7: Infill and Rooftop Solar Scenario (Figure 2.16)
Together, infill and rooftop solar resource potential throughout the county is 17,478 GWh,
making up 35% of the estimated 2050 demand (12% and 23% respectively). A higher level of
rooftop solar deployment is assumed in communities having very low, low, or moderate access
to opportunity per the San Diego Climate Equity Index (assuming 50% of rooftop area is usable
instead of 30% assumed elsewhere). The rooftop solar resource potential in these communities
is estimated at 726 GWh, which would provide about 1% of the estimated 2050 demand.
Overall, this focus on maximum possible rooftop and infill solar leaves a deficit of 32,501 GWh,
which would need to come from utility-scale renewable development or from resources outside
of the San Diego region.
Figure 2.16 Scenario 7: Infill and rooftop solar only. This scenario maximizes utilization of rooftop solar and infill
solar development in the region. It does not meet regional energy demand and is relatively expensive (with an
average LCOE of $70/MWh) because of the high costs and lower capacity factors of rooftop and urban infill solar
development.
Oct. 11, 2022 Item #12 Page 87 of 560
49
This preliminary analysis sought to understand rooftop, infill, and brownfield solar potential in
the San Diego region. Other urban land uses and land covers such as parking lots or human-
made bodies of water, such as reservoirs, irrigation ponds, and water treatment holding ponds
may also be considered in future iterations. However, studies have shown that commercial
parking lots have low market penetration partly due to the availability of other lower-cost
options such as utility-scale ground-mounted solar. Innovative incentive or rebate design may be
needed to support economic competitiveness. Results of the analysis on rooftop solar are
summarized in Table 2.6 below.
Table 2.6 Comparative energy production cost scenarios, average LCOE, total energy, and percent of demand met
by renewable energy sources of natural gas, Scenario 1 (Figure 2.10), rooftop solar only, and rooftop and infill solar
(Figure 2.16).
Energy Production Cost Scenarios
Average LCOE
($/MWh)
Total GWh in San
Diego County
Percent of
Demand
Average US Combined Cycle Natural Gas Plant50 35 NA NA
Output of Scenario 1 (Sites selected based on LCOE) 41 49,979 100%
Rooftop Solar 92 5,930 12%
Rooftop and Infill Solar 70 17,478 35%
Oct. 11, 2022 Item #12 Page 88 of 560
50
Scenario 8: Mixed-mode resource mix scenario (Figure 2.17)
In this scenario, the 2050 annual generation from new renewable sources is as follows: 12%
rooftop solar, 23% brownfield solar, 0.1% brownfield wind, 6% utility scale solar on developable
land in the San Diego region, 0.4% utility scale wind on developable land in the region, 38%
Imperial solar, 21% Imperial geothermal. This results in 50,147 GWh of resource potential and
allows for a surplus of 168 GWh.
Figure 2.17 Mixed-mode Scenario 2050. This figure shows sites selected to meet the 2050 electricity demand, for
the mixed-mode scenario. In this scenario, the 2050 annual generation from new renewable sources is as follows:
12% rooftop solar, 23% brownfield solar, 0.1% brownfield wind, 6% utility scale solar on developable land in San
Diego county, 0.4% utility-scale wind on developable land in San Diego county, 38% Imperial solar, 21% Imperial
geothermal. The addition of rooftop solar and brownfield resources together results in 35% reduction in land area
impacts. This meets regional energy demand, but it has a high average cost (with an average LCOE of $109/MWh)
partly because of the high costs of rooftop and brownfield development, as well as the high cost of geothermal.
Oct. 11, 2022 Item #12 Page 89 of 560
51
Scenario 9: High Rooftop, Low-Impact to Conservation Lands, Avoid Valuable Agriculture Lands
(Figure 2.18)
In this scenario, the 2050 annual generation from new renewable sources is as follows: 28%
rooftop solar, 16% infill solar, 3% utility-scale solar in the San Diego region, less than 1% utility-
scale wind in the region, 53% Imperial solar. This results in 44,177 GWh of resource potential,
which is 88% of estimated regional demand in 2050.
The estimated 2050 electricity demand for the newly formed entity, SDCP, is 72% of 2050
regional electricity demand, based on the population of the following member jurisdictions:
Encinitas, Chula Vista, La Mesa, Imperial Beach, National City, City of San Diego, and the
Unincorporated County.57 In this Scenario 9, the annual generation is 123% of estimated 2050
SDCP electricity demand. If the resources of this scenario were limited to include only those
resources physically located within the member jurisdiction boundaries, then resource
availability is reduced to 42% of estimated 2050 SDCP demand.
Figure 2.18 High Rooftop, Low-Impact on Conservation Lands, Avoid High-value Agriculture Lands 2050. This figure
shows sites selected to meet the 2050 electricity demand, for the high rooftop, low-impact scenario, with high-
value agricultural lands removed. In this scenario, the 2050 annual generation from new renewable sources is as
follows: 28% rooftop solar, 16% infill solar, 3% utility-scale solar in San Diego County, less than 1% utility-scale wind
in San Diego, 53% Imperial solar. It does not meet total 2050 regional electricity demand (88%), but it meets 123%
of estimated 2050 SDCP electricity demand. It has a moderate average cost, with an average LCOE of $57/MWh.
Oct. 11, 2022 Item #12 Page 90 of 560
52
2.6 Trends Across Scenarios
Most scenarios in this analysis include some level of development of the high-quality resource
potential in the Boulevard, Campo, and Jacumba areas. Based on CAISO interconnection queue
data, high levels of commercial interest and development activity are already occurring in this
area. Stakeholder comments indicated siting concerns in this region, including habitat loss, land
use change, noise, shadow flicker, and electromagnetic interference. The latter three concerns
are only applicable to wind turbines.
A recent LBNL study indicates that improved understanding of shadow flicker exposure could
provide a basis for exposure thresholds and, in turn, potentially improve community acceptance
of and experience with wind power projects. This study identified a prototypical EU regulatory
threshold limiting wind turbine noise disturbance to no more than 45 dBA and limiting shadow
flicker to no more than 8 hours per year. The majority of points in the study sample had shadow
flicker below this threshold when sited 1500 m or more from residences or other structures.58
Multiple scenarios (such as Scenario 1 and 2) limit the amount of wind and solar in these East
County locations, but there are no scenarios in which development in this area is eliminated
entirely. The recently passed NY Accelerated Renewable Energy Growth and Community Benefit
Act may provide a helpful example of solutions to help alleviate development pressure and
address community concerns in sensitive areas. See excerpted summary below:59
"In order to ensure that renewable energy projects deliver benefits to the local
communities where they are built, the Act establishes several programs.
First, NYSERDA will develop a Host Community Benefit Program as part of its
build-ready initiative, which will offer property owners and communities tangible
benefits and incentives for hosting renewable energy facilities.
The Act also creates a new program that will be established by the Public Service
Commission, which will provide utility bill discounts or other environmental
benefits or compensation for the benefit of residents of host communities.
Finally, in order for communities to participate in the new siting process,
NYSERDA will administer a local intervenor fund for the benefit of local agencies
and community intervenors. Further stakeholder input from residents in these
counties is welcome and appreciated."
Additionally, in 2022 the California Energy Commission held a workshop60 that described how
the State agencies collaborating on SB 100 will work to improve methods for how land use
implications are included in energy resource planning.
Oct. 11, 2022 Item #12 Page 91 of 560
53
2.7 Conclusion
To develop the necessary renewable resources that satisfy 100% of electricity demand by 2050,
the San Diego region will need to engage in near- and long-term planning to ensure priorities
such as environmental protection, cost, carbon sequestration potential, equity, and land value
are considered adequately in deployment. This report has shown that balancing these priorities
is possible with available resources in the San Diego region and nearby Imperial County,
although there will be trade-offs, including the need to import electricity and transmission
upgrades needed to avoid congestion. There are opportunities for power transfer between San
Diego and Imperial Counties, including solar and geothermal firm power, which can reduce
storage requirements and increase reliability. To meet the estimated ~50,000 GWh of demand
(or ~5,700 MW of capacity) for the San Diego region by 2050, there will need to be roughly two
new operational 100 MW clean power plants coming online every year between now and 2050.
If the timeline is constrained to 2035, this would require roughly four new operational 100 MW
clean power plants every year. Close coordination with State agencies such as the CAISO and the
CPUC can help accelerate the deployment of clean energy infrastructure, including transmission.
A scenario maximizing rooftop and urban infill solar and energy storage could result in 5-30%
reduction in infrastructure development on previously undisturbed land (greenfield
development). It could also have multiple co-benefits, including progress toward county-level
and higher-level equity goals, job creation in “green job” or “cleantech” sectors with
corresponding well-paying wages,54 reduced GHG emissions from land use change for energy
infrastructure, and availability of supplemental funding sources for example from the State. If
coupled with apprenticeship programs, job training opportunities could be significant. Further
study to quantify the local economic and public health benefits of such a scenario would be
valuable; however, adequate information exists to support early action in high-quality areas in
East County as well as promoting growth in rooftop solar, especially in communities overly
burdened with pollution and having low access to opportunities.
Oct. 11, 2022 Item #12 Page 92 of 560
54
Works Cited:
1. Wu, G. C., Leslie, E., Sawyerr, O., Cameron, D. R., Brand, E., Cohen, B., Allen, D., Ochoa, M., & Olson, A.
(2020). Low-impact land use pathways to deep decarbonization of electricity. Environmental Research
Letters, 15(7), 074044. https://doi.org/10.1088/1748-9326/ab87d1
2. Zichella, C., & Hladik, J. (2013). Siting: Finding a Home for Renewable Energy and Transmission. The
Electricity Journal, 26(8), 125–138. https://doi.org/10.1016/j.tej.2013.09.001
3. Senator Sher (2002); SB 1078 Renewable energy: California Renewables Portfolio Standard Program.
http://www.leginfo.ca.gov/pub/01-02/bill/sen/sb_1051-1100/sb_1078_bill_20020912_chaptered.html
4. Senator De León. (2015) SB 350 Clean Energy and Pollution Reduction Act of 2015.
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201520160SB350
5. Senator De León (2018) SB 100 California Renewables Portfolio Standard Program: emissions of
greenhouse gases. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB100
6. Summary of state-level renewable energy goals provided by the California Public Utilities Commission
(CPUC) https://www.cpuc.ca.gov/rps
7. Available online at the following URL: https://www.cpuc.ca.gov/industries-and-topics/electrical-
energy/infrastructure/transportation-electrification/transportation-electrification-activities-pursuant-to-
senate-bill-350
8. Available online at the following URL: https://www.cpuc.ca.gov/industries-and-topics/electrical-
energy/electric-power-procurement/long-term-procurement-planning
9. Available online at the following URL: https://www.cpuc.ca.gov/industries-and-topics/electrical-
energy/electric-power-procurement/long-term-procurement-planning/2019-20-irp-events-and-materials
Accessed January 3, 2022
10. http://www.caiso.com/planning/Pages/TransmissionPlanning/Default.aspx
11. “Modeling Assumptions for 2022 -2023 Transmission Planning Process.”
https://files.cpuc.ca.gov/energy/modeling/Modeling_Assumptions_2022_2023_TPP_V2021_12_
16.pdf
12. Available online at the following URL: https://www.cpuc.ca.gov/industries-and-topics/electrical-
energy/electric-power-procurement/long-term-procurement-planning/2019-20-irp-events-and-materials
Accessed January 3, 2022
13. RETI Coordinating Committee, RETI Stakeholder Steering Committee. “Renewable Energy Transmission
Initiative Report.” California Energy Commission, January 2009. Accessible online at
http://www.energy.ca.gov/2008publications/RETI-1000-2008-002/RETI-1000-2008-002-F.PDF 14. NREL “Greening the Grid” Toolkit https://greeningthegrid.org/Renewable-Energy-Zones-
Toolkit/topics/renewable-energy-resource-assessments
15. Greening the Grid Initiative. Topics and Resources: Transmission Expansion Planning. Accessible online at
the following URL: https://greeningthegrid.org/Renewable-Energy-Zones-
Toolkit/topics/Transmission%20Expansion%20Planning
16. Microsoft Building Footprints – Features. 125 million building footprints deep learning generated by
Microsoft for the USA. https://hub.arcgis.com/datasets/esri::microsoft-building-footprints-features/about
(accessed online December 1, 2021).
17. SANDAG, 2021, SanGIS; sangis.org
18. Ong, S., Campbell, C., Denholm, P., Margolis, R., & Heath, G. (2013). Land-Use Requirements for Solar
Power Plants in the United States (NREL/TP-6A20-56290, 1086349; p. NREL/TP-6A20-56290, 1086349).
NREL. https://doi.org/10.2172/1086349
19. Denholm, P., Hand, M., Jackson, M., & Ong, S. (2009). Land Use Requirements of Modern Wind Power
Plants in the United States (NREL/TP-6A2-45834, 964608; p. NREL/TP-6A2-45834, 964608). NREL.
https://doi.org/10.2172/964608
20. Firestone, J., & Kirk, H. (2019). A strong relative preference for wind turbines in the United States among
those who live near them. Nature Energy, 4(4), 311–320. https://doi.org/10.1038/s41560-019-0347-9
21. Sonnberger, M. (2019). Choosing the lesser of two evils? Nature Energy, 4(4), 265–266.
https://doi.org/10.1038/s41560-019-0354-x
Oct. 11, 2022 Item #12 Page 93 of 560
55
22. US Census. (2019). TIGER/Line Shapefile, 2019, 2010 nation, U.S., 2010 Census Urban Area National [Data
set]. Unknown. https://catalog.data.gov/dataset/tiger-line-shapefile-2019-2010-nation-u-s-2010-census-
urban-area-national
23. “Repowering America’s Lands.” U.S. Environmental Protection Agency. Accessed February 21, 2022.
https://www.epa.gov/re-powering.
24. Leslie, Emily, Pascale, Andrew, & Jenkins, Jesse. (2021). Wind and Solar Candidate Project Areas for
Princeton REPEAT (Version 3) [Data set]. Zenodo. https://doi.org/10.5281/zenodo.5021146
25. “Mapping and Assessment of the United States Ocean Wave Energy Resource.” EPRI, 2011.
https://www.osti.gov/servlets/purl/1060943.
26. U.S. Energy Information Administration (EIA). (2021). Form EIA-860 detailed data with previous form data
(EIA-860A/860B). https://www.eia.gov/electricity/data/eia860/
27. U.S. National Renewable Energy Laboratory (NREL). (2020). Index | Electricity | 2020 | ATB | NREL.
https://atb.nrel.gov/electricity/2020/index
28. Cohen, S. M., Becker, J., Bielen, D. A., Brown, M., Cole, W. J., Eurek, K. P., Frazier, A., Frew, B. A., Gagnon, P.
J., Ho, J. L., Jadun, P., Mai, T. T., Mowers, M., Murphy, C., Reimers, A., Richards, J., Ryan, N., Spyrou, E.,
Steinberg, D. C. (ORCID:0000000317692261), … Zwerling, M. (2019). Regional Energy Deployment System
(ReEDS) Model Documentation: Version 2018 (NREL/TP-6A20-72023). National Renewable Energy Lab.
(NREL), Golden, CO (United States). https://doi.org/10.2172/1505935
29. U.S. Department of Homeland Services (DHS). (2020, June). Electric Substations. https://hifld-
geoplatform.opendata.arcgis.com/datasets/electric-substations/explore
30. Masters, G. M. (2004). Renewable and Efficient Electric Power Systems: Masters/Electric Power Systems.
John Wiley & Sons, Inc. https://doi.org/10.1002/0471668826
31. Barbose, G., Darghouth, N., O’Shaugnessey, E., & Forrester, S. (2020). Tracking the Sun | Electricity Markets
and Policy Group. Berkeley Labs. https://emp.lbl.gov/tracking-the-sun
32. Hamoud, G., & Bradley, I. (2004). Assessment of transmission congestion cost and locational marginal
pricing in a competitive electricity market. IEEE Transactions on Power Systems, 19(2), 769–775.
https://doi.org/10.1109/TPWRS.2004.825823 33. Gu, Y., Xie, L., Rollow, B., & Hesselbaek, B. (2011). Congestion-induced wind curtailment: Sensitivity
analysis and case studies. 2011 North American Power Symposium, 1–7.
https://doi.org/10.1109/NAPS.2011.6025167
34. Shaner, M. R., Davis, S. J., Lewis, N. S., & Caldeira, K. (2018). Geophysical constraints on the reliability of
solar and wind power in the United States. Energy & Environmental Science, 11(4), 914–925.
https://doi.org/10.1039/C7EE03029K
35. CAISO. (2021). Transmission Capability Estimates for use in the CPUC’s Resource Planning Process.
http://www.caiso.com/Documents/WhitePaper-2021TransmissionCapabilityEstimates-
CPUCResourcePlanningProcess.pdf
36. CPUC “Preferred System Plan” https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/electric-
power-procurement/long-term-procurement-planning/2019-20-irp-events-and-materials
37. CAISO. (2021). California ISO - 20-Year transmission outlook.
https://stakeholdercenter.caiso.com/RecurringStakeholderProcesses/20-Year-transmission-outlook
38. CAISO curtailment fast facts. Accessible online at the following URL:
https://www.caiso.com/documents/curtailmentfastfacts.pdf
39. Dowling JA, Rinaldi KZ, Ruggles TH, Davis SJ, Yuan M, Tong F, Lewis NS, Caldeira K. Role of Long-Duration
Energy Storage in Variable Renewable Electricity Systems. Joule, Volume 4, Issue 9, 2020, pp 1907-1928.
https://www.sciencedirect.com/science/article/pii/S2542435120303251
40. “The Path to Net Zero: A Decarbonization Roadmap for California.” San Diego Gas and Electric, April 2022.
https://www.sdge.com/sites/default/files/documents/netzero2.pdf.
41. RESOLVE: Renewable Energy Solutions Model. (n.d.). E3. Retrieved August 31, 2021, from
https://www.ethree.com/tools/resolve-renewable-energy-solutions-model/
42. USDA. (2020). CropScape—NASS CDL Program. National Agricultural Statistics Service.
https://nassgeodata.gmu.edu/CropScape/
Oct. 11, 2022 Item #12 Page 94 of 560
56
43. SANDAG. (2021, August 26). Eco Vegetation Layer. SanGIS/SANDAG GIS Data Warehouse.
https://rdw.sandag.org/Account/gisdtview?dir=Ecology
44. SANDAG. (2010). Developable Land.
https://www.sandag.org/resources/maps_and_gis/gis_downloads/downloads/zip/Land/ForecastLand/dev
abledoc.htm#codes
45. Blair et al. “System Advisor Model (SAM) General Description (Version 2017.9.5).” National Renewable
Energy Lab (NREL), 2018. https://sam.nrel.gov/.
46. Clean Coalition Solar Siting Survey (2019). https://clean-coalition.org/solar-siting-survey-san-diego/
47. SANDAG. Planned Land Use for the Series 13 Regional Growth Forecast (2050).
LANDUSE_PLANNED_2050_SG. SanGIS/SANDAG GIS Data Warehouse.
https://gissd.sandag.org/rdw/rest/services/Land_Use/Planned_Land_Use/MapServer/0
48. Gao, J., & O’Neill, B. C. (2020). Mapping global urban land for the 21st century with data-driven simulations
and Shared Socioeconomic Pathways. Nature Communications, 11(1), 2302.
https://doi.org/10.1038/s41467-020-15788-7
49. City of San Diego. (2021). Climate Equity and Jobs | Sustainability | City of San Diego Official Website.
https://www.sandiego.gov/sustainability/social-equity-and-job-creation
50. City of San Diego. (2018). Climate Equity Index Report.
https://www.sandiego.gov/sites/default/files/2019_climate_equity_index_report.pdf 51. SANDAG. (2011). Social Equity: Title VI and Environmental Justice.
https://www.sandag.org/uploads/2050RTP/F2050rtp4.pdf
52. OEHHA, O. (2014, November 27). CalEnviroScreen. https://oehha.ca.gov/calenviroscreen
53. CalEPA. (2021). California Climate Investments to Benefit Disadvantaged Communities | CalEPA.
https://calepa.ca.gov/envjustice/ghginvest/
54. San Diego’s jobs in these industry groups grew 17.6% from 2010 to 2018.
https://www.sandiego.gov/sustainability/social-equity-and-job-creation
55. SANDAG. (2010). Developable Land.
https://www.sandag.org/resources/maps_and_gis/gis_downloads/downloads/zip/Land/ForecastLand/dev
abledoc.htm#codes
56. Guerra O, Zhang J, Eichman J, Denholm P, Kurtz J, and Hodge B. The value of seasonal energy storage
technologies for the integration of wind and solar power. Energy and Environmental Science (July 2020).
https://doi.org/10.1039/D0EE00771D
57. SANDAG. Demographics of the San Diego Region.
https://www.sandag.org/uploads/publicationid/publicationid_2001_20213.pdf
58. Hack, Ryan, Ryan Darlow, Ken Kaliski, Joseph Rand, and Ben Hoen. “In the Shadow of Wind Energy:
Predicting Community Exposure and Annoyance to Wind Turbine Shadow Flicker in the United States,”
May 2022. https://emp.lbl.gov/publications/shadow-wind-energy-predicting.
59. https://www.nyserda.ny.gov/About/Newsroom/2022-Announcements/2022-07-08-NYSERDA-Announces-
Agreements-on-Two-Municpally-Owned-Sites
60. “Joint Agency Workshop to Plan for Senate Bill 100 Resource Build – Analysis of Land Use Implications”
California Energy Commission, February 22, 2022. https://www.energy.ca.gov/event/workshop/2022-
02/joint-agency-workshop-plan-senate-bill-100-resource-build-analysis-land-use
Oct. 11, 2022 Item #12 Page 95 of 560
57
Appendix 2.A List of Spatial Data Sources
Spatial Data Sources
1. On-Shore Wind and Solar Polygons: RETI Coordinating Committee, RETI Stakeholder Steering Committee.
“Renewable Energy Transmission Initiative Report.” California Energy Commission, January 2009. Accessible
online at http://www.energy.ca.gov/2008publications/RETI-1000-2008-002/RETI-1000-2008-002-F.PDF
2. Off-Shore Wind Polygons: Princeton REPEAT, 2022.
https://maps.princeton.edu/catalog?search_field=all_fields&q=netzeroamerica&utf8=%E2%9C%93
3. Infill Solar Polygons: The Nature Conservancy, Power of Place, 2019 (update to 2019 report, not published).
https://www.nature.org/en-us/about-us/where-we-work/united-states/california/stories-in-california/clean-
energy/
4. Conserved Lands Exclusions: San Diego Association of Governments, 2021.
https://rdw.sandag.org/Account/gisdtview?dir=Ecology
5. Existing Utility-Scale Solar and Wind Polygons: Polygons created based on existing and planned sites
identified by EIA, 2021 https://www.eia.gov/electricity/data/eia860/
6. Existing Substations: Department of Homeland Security, Homeland Infrastructure Foundation-Level Data,
2021. https://hifld-geoplatform.opendata.arcgis.com/datasets/electric-substations
7. Urban Areas: US Census, 2019. https://catalog.data.gov/dataset/tiger-line-shapefile-2019-2010-nation-u-s-
2010-census-urban-area-national
8. Transmission Networks: Department of Homeland Security, Homeland Infrastructure Foundation-Level Data,
2021. https://hifld-geoplatform.opendata.arcgis.com/datasets/electric-power-transmission-
lines/explore?location=25.606388%2C-7.477918%2C2.79
9. Geothermal Sites: Points created based on data from E3 and CPUC as part of the statewide Integrated
Resource Plan (R-20-05-003) https://www.ethree.com/tools/resolve-renewable-energysolutions-model/
10. Low Environmental Impact CPAs: Wu et al., 2020 Data Github https://github.com/grace-cc-
wu/LandUsePathwaysTo100
11. Land Value: USDA Cropland Data Layer
https://www.nass.usda.gov/Research_and_Science/Cropland/SARS1a.php
12. High Sequestration Potential: Taken from analysis in the Land Use chapter, the SANDAG “Eco Veg” dataset is
used. https://www.sangis.org/
13. Developable Land: Vacant or Agricultural Redevelopment Land Use. SANDAG, Developable Land, 2010.
https://www.sandag.org/resources/maps_and_gis/gis_downloads/land.asp
14. Microsoft Building Footprints – Features. 125 million building footprints deep learning generated by
Microsoft for the USA. https://hub.arcgis.com/datasets/esri::microsoft-building-footprints-features/about
(accessed online December 1 2021).
Oct. 11, 2022 Item #12 Page 96 of 560
58
Appendix 2.B List of Spatial Data Sources
Table 2.B.1 Category 1 site suitability criteria. Adapted from RETI, 2009
Category 1 Lands
Federal Lands State Lands
Designated Federal Wilderness Areas Private Preserves of The Wildlands Conservancy
Wilderness Study Areas
National Wildlife Refuges
Units of National Park System (National Parks,
National Monuments, National Recreation Areas,
National Historic Sites, National Historic Parks,
National Preserves)
Existing Conservation Mitigation banks under
conservation easement approved by the State
Department of Fish and Game, U.S. Fish and
Wildlife Service or Army Corps of Engineers
Inventoried Roadless Areas on USFS national
forests CA State Defined Wetlands
National Historic and national Scenic Trails CA State Wilderness Areas
National Wild, Scenic and Recreational Rivers CA State Parks
BLM King Range Conservation Area, Black Rock-
High Rock National Conservation Area, and
Headwaters Forest Reserve DFG Wildlife Areas and Ecological Reserves
BLM National Recreational Areas
BLM National Monuments
Lands precluded by development under Habitat
Conservation Plans and Natural Community
Conservation Plans
Lands specified as of May 1, 2008, in Proposed
Wilderness Bills (S. 493, H.R. 3682)
Table 2.B.2 Category 2 site suitability criteria. Adapted from RETI, 2009
Category 2 Lands
BLM Areas of Critical Environmental Concern
USFWS designated Critical Habitat for federally listed endangered and
threatened species
Special wildlife management areas identified in BLM's West Mojave Resource
Management Plan. I.e., Desert Wildlife Management Areas and Mojave
Ground Squirrel Conservation Areas
Lands purchased by private funds and donated to BLM, specifically the
California Desert Acquisition Project by The Wildlands Conservancy
"Proposed and Potential Conservation Reserves" in HCPs and NCCPs
Oct. 11, 2022 Item #12 Page 97 of 560
59
Table 2.B.3 Full List of site suitability criteria for CPA development.
RETI Excluded Lands
Geothermal Solar PV Wind Notes
Category 1 lands Yes Yes Yes
Category 2 lands Yes Yes Yes Pre-identified projects OK
Wetlands and water
bodies Yes Yes Yes Dry lakes not excluded
Native American
reservations Yes Yes Yes Pre-identified projects OK
Military lands Yes Yes Yes Pre-identified projects OK
Mines (surface) Yes Yes Yes
Urban areas Yes Yes, +
buffer
Yes, +
buffer
buffer up to 3 miles depending on
population
Airports Yes Yes Yes, +
buffer
Major airports only. Wind buffer is up
to 5 miles
Military flyways No No Yes Pre-identified projects OK in red zones.
All other open
Williamson Act Prime
Agricultural Land No Yes No Pre-identified projects OK in red zones.
All other open
Williamson Act Non-
Prime Agricultural Land No Yes No Excluded until 2018, pre-identified
projects OK
Renewable resource
quality No No < 6.3
m/sec
Min. contiguous square
acreage No 160 none 640 acres = 1 section = 1 sq mile
Land slope No > 5% > 20% Geothermal evaluated on case-by-case
basis
Oct. 11, 2022 Item #12 Page 98 of 560
60
Appendix 2.C List of Key Assumptions
Key Assumptions
● Solar is prioritized over wind within San Diego County.
● For CPAs located in San Diego County, cost of transmission interconnection can be approximated
by cost of Euclidian distance from CPA to nearest substation. For CPAs located outside of the
county, it is assumed that a transmission upgrade will be required to alleviate the San Diego
Internal constraint (see line 5 in table listing transmission upgrade options).
● Total geothermal resource potential identified by E3 and CPUC as part of the Statewide Integrated
Resource Plan (R-20-05-003) will be operation by 2030.
● Geothermal supply in Imperial is shared with San Diego in an amount equivalent to the ratio of
their combined population.
● Electricity demand model results can be downscaled by the ratio of San Diego population to total
Southern California population.
● Storage and geothermal will help alleviate intermittency pressures on the grid.
● Cost is a very important criteria for site selection.
● The Overall Energy Model Central Case is the best forecast for the purposes of the spatial analysis.
● The capacity factor is equal to the fixed-tilt solar percentage in the urban areas and tracking solar
in non-urban areas.
● Infill solar sites are grid connected.
● All planned and permitted solar sites in San Diego County will be constructed.
● SANDAG’s Conserved Land areas are undesirable for renewable development.
Oct. 11, 2022 Item #12 Page 99 of 560
61
Appendix 2.D QGIS Processing Modeler
Solar CPAs Modeler
Wind CPAs Modeler
Oct. 11, 2022 Item #12 Page 100 of 560
62
Appendix 2.E Floatovoltaics
In addition to utilizing previously disturbed land areas for solar PV deployment, such as rooftop,
brownfield, and urban infill, San Diego may also pursue deploying solar atop human-made
bodies of water, such as reservoirs, irrigation ponds, and water treatment holding ponds. Siting
solar panels atop human-made bodies of water, known as floatovoltaics (FPV), can help to
alleviate land use conflicts with agriculture or biological conservation. Additionally, FPV can
potentially offer unique co-benefits, such as increased panel performance and evaporation of
the associated freshwater resources.1 FPV is growing rapidly in California, with multiple
commercial scale multi-megawatt arrays being deployed in Sonoma County. This is a
demonstration effort to simultaneously increase solar deployment to meet RPS standards,
reduce the need for land use and land cover change for solar deployment, and preserve fresh
water in a drought-prone state.
Techno-economic feasibility and potential analyses have been performed at both the State and
national level to identify candidate water bodies within a strict inclusion criteria.2,3 Specifically,
GIS-based techno-economic potential studies have been conducted to assess the viability and
availability of human-made bodies of water for FPV deployment on a national scale.3 Viability
requirements include categories such as primary water body use type, bathymetric
characteristics, and distance to transmission and substation infrastructure. The analysis
methodology and data used for this analysis is publicly available for potential future
incorporation into this flexible framework.
Appendix 2.E Works Cited:
1. Cagle AE, Armstrong A, Exley G, Grodsky SM, Macknick J, Sherwin J, et al. The Land Sparing, Water Surface Use
Efficiency, and Water Surface Transformation of Floating Photovoltaic Solar Energy Installations. Sustainability
2020;12:8154. https://doi.org/10.3390/su12198154.
2. Liber W, Bartle C, Spencer R, Jordan M, Cagle AE, Lewis T. Statewide potential study for the implementation of
floating solar photovoltaic arrays. Denver, CO: 2019
3. Spencer RS, Macknick J, Aznar A, Warren A, Reese MO. Floating Photovoltaic Systems: Assessing the Technical
Potential of Photovoltaic Systems on Man-Made Water Bodies in the Continental United States. Environmental
Science Technology 2018;53:1680–9. https://doi.org/10.1021/acs.est.8b04735.
Oct. 11, 2022 Item #12 Page 101 of 560
63
Appendix 2.F Transmission Upgrade Options and Costs
Table 2.F Transmission upgrades and costs in San Diego Gas & Electric (SDG&E) Territory, based on CAISO Transmission Capability Whitepaper, July 2021.35
Transmission
Constraint Affected Zones
Estimated Full Capacity Deliverability
Status Based on On-Peak Study
Resource Output
Area Delivery Network Upgrades (ADNU) & Cost Estimate Wind/Solar Area Designation
Existing System (MW)
Increase due to ADNU
(MW) ADNU Construction
Time (months)
Cost
($millions)
East of Miguel Constraint Arizona, Imperial, Baja, Riverside 731 1,412 New Imperial Valley - Serrano 500 kV line 120 $3,680 Solar
Encina-San Luis Rey
Constraint
Arizona, Imperial,
Baja, Non-CREZ
within San Diego
2,901 3,718 New Encina - San Luis Rey
230 kV line 120 $102 Solar
Imperial Valley
transformer
Constraint
Imperial 1,959 400 New Imperial Valley 500/230
kV Bank at new substation 105 $214 Solar
San Luis Rey-San
Onofre Constraint
Arizona, Imperial,
Baja, Non-CREZ
within San Diego
1,748 4,269 New San Luis Rey-San Onofre 230 kV line 120 $237 Solar
San Diego Internal
Constraint
Imperial, Non-CREZ
within San Diego 968 2,067 Internal San Diego
reconductoring 18 $89 Solar
Silvergate-Bay Boulevard Constraint
Imperial, Baja, Non-CREZ within San Diego 1,202 2,119 Silvergate - Bay Blvd 230kV
3-ohm Series Reactor 72 $31 Wind
San Diego
Oceanside
Constraint
Non-CREZ within
San Diego 280 301 Oceanside ADNU 60 $133 Solar Oct. 11, 2022Item #12 Page 102 of 560
64
Appendix 2.G Downscaling Method
First, the proportion of the population of San Diego with respect to the population of Southern
California (SC) is found. The SC population is defined as all counties south of the PG&E territory.i
Therefore, using the following formula to find a result of 13.75%. 𝑃𝑃𝑃𝑃𝑐𝑐𝑜𝑜𝑎𝑎𝑎𝑎𝑑𝑑𝑑𝑑𝑃𝑃𝑑𝑑 𝑃𝑃𝑓𝑓 𝑆𝑆𝑎𝑎𝑑𝑑 𝐷𝐷𝑑𝑑𝑃𝑃𝑔𝑔𝑃𝑃 𝐶𝐶𝑃𝑃𝑜𝑜𝑑𝑑𝑑𝑑𝑑𝑑 / 𝑃𝑃𝑃𝑃𝑐𝑐𝑜𝑜𝑎𝑎𝑎𝑎𝑑𝑑𝑑𝑑𝑃𝑃𝑑𝑑 𝑃𝑃𝑓𝑓 𝑆𝑆𝐶𝐶 𝐶𝐶𝑃𝑃𝑜𝑜𝑑𝑑𝑑𝑑𝑑𝑑𝑃𝑃𝑑𝑑
Table 2.G.1 Proportion of Population in San Diego
San Diego Percentage of Southern CA
San Diego 3,315,404
Total 24,106,838
SD % 13.75%
Then the modeled final energy demand (“d-energy” in the Overall Energy System Model) is used. First,
the total energy demand is filtered to “electricity” and “Southern California.” Then the sum of electricity
demand is found for all years 2018 - 2050. The proportion of Southern California population in San Diego
(13.75%) is applied to find the San Diego electricity demand. Finally, 4,115 GWh of existing and planned
solar and wind resources within the County is removed. The total resource requirements based on
demand are found in Table 2.C.2.
Table 2.G.2 Necessary Renewable Resources to Meet 100% of Demand
Year Total GWh
2020 19,158
2025 20,919
2030 26,689
2035 34,825
2040 42,412
2045 47,045
2050 49,979
i PG&E, 2014. https://www.pge.com/tariffs/assets/pdf/tariffbook/GAS_MAPS_Service_Area_Map.pdf
Oct. 11, 2022 Item #12 Page 103 of 560
65
Appendix 2.H San Diego Vegetation Types with High CO2 Sequestration Potential
Non-Native Vegetation
Disturbed Wetland
Disturbed Habitat
General Agriculture
Orchards and Vineyards
Southern Coastal Bluff Scrub
Coastal Scrub
Maritime Succulent Scrub
Diegan Coastal Sage Scrub
Diegan Coastal Sage Scrub: Coastal form
Diegan Coastal Sage Scrub: Inland form
Riversidian Sage Scrub
Riversidian Upland Sage Scrub
Alluvial Fan Scrub
Sonoran Desert Scrub
Sonoran Creosote Bush Scrub
Sonoran Desert Mixed Scrub
Sonoran Mixed Woody Scrub
Sonoran Mixed Woody and Succulent
Scrub
Sonoran Wash Scrub
Colorado Desert Wash Scrub
Encelia Scrub
Acacia Scrub
Mojavean Desert Scrub
Blackbush Scrub
Great Basin Scrub
Sagebrush Scrub
Big Sagebrush Scrub
Desert Saltbush Scrub
Desert Sink Scrub
Chaparral
Southern Mixed Chaparral
Granitic Southern Mixed Chaparral
Mafic Southern Mixed Chaparral
Northern Mixed Chaparral
Granitic Northern Mixed Chaparral
Mafic Northern Mixed Chaparral
Chamise Chaparral
Granitic Chamise Chaparral
Mafic Chamise Chaparral
Red Shank Chaparral
Semi-Desert Chaparral
Montane Chaparral
Mixed Montane Chaparral
Montane Manzanita Chaparral
Montane Ceanothus Chaparral
Montane Scrub Oak Chaparral
Upper Sonoran Ceanothus Chaparral
Ceanothus Crassifolius Chaparral
Scrub Oak Chaparral
Upper Sonoran Subshrub Scrub
Valley and Foothill Grassland
Native Grassland
Valley Needlegrass Grassland
Valley Sacaton Grassland
Non-Native Grassland: Broadleaf-
Dominated
Foothill/Mountain Perennial Grassland
Transmontane Perennial Grassland
Vernal Pool
San Diego Mesa Vernal Pool
San Diego Mesa Claypan Vernal Pool
Meadows and Seeps
Montane Meadow
Wet Montane Meadow
Dry Montane Meadows
Alkali Meadows and Seeps
Alkali Playa Community
Southern Coastal Salt Marsh
Alkali Marsh
Cismontane Alkali Marsh
Freshwater Marsh
Coastal and Valley Freshwater Marsh
Transmontane Freshwater Marsh
Emergent Wetland
Riparian and Bottomland Habitat
Riparian Forests
Southern Riparian Forest
Southern Coast Live Oak Riparian Forest
Southern Arroyo Willow Riparian Forest
Southern Cottonwood-Willow Riparian
Forest
White Alder Riparian Forest
Sonoran Cottonwood-Willow Riparian
Forest
Mesquite Bosque
Riparian Woodlands
Desert Dry Wash Woodland
Desert Fan Palm Oasis Woodland
Southern Sycamore-Alder Riparian
Woodland
Southern Riparian Woodland
Riparian Scrubs
Southern Riparian Scrub
Mule Fat Scrub
Southern Willow Scrub
Arundo donax Dominant/Southern
Willow Scrub
Great Valley Scrub
Great Valley Willow Scrub
Colorado Riparian Scrub
Arrowweed Scrub
Intertidal
Shallow Bay
Estuarine
Saltpan/Mudflats
Woodland
Cismontane Woodland
Oak Woodland
Black Oak Woodland
Coast Live Oak Woodland
Open Coast Live Oak Woodland
Dense Coast Live Oak Woodland
Engelmann Oak Woodland
Open Engelmann Oak Woodland
Dense Engelmann Oak Woodland
Peninsular Pinon and Juniper Woodlands
Peninsular Pinon Woodland
Peninsular Juniper Woodland and Scrub
Elephant Tree Woodland
Mixed Oak Woodland
Undifferentiated Open Woodland
Non-Native Woodland
Eucalyptus Woodland
Mixed Evergreen Forest
Oak Forest
Coast Live Oak Forest
Canyon Live Oak Forest
Black Oak Forest
Torrey Pine Forest
Southern Interior Cypress Forest
Lower Montane Coniferous Forest
Coast Range, Klamath and Peninsular
Coniferous Forest
Coulter Pine Forest
Bigcone Spruce (Bigcone Douglas Fir)-
Canyon Oak Forest
Sierran Mixed Coniferous Forest
Mixed Oak/Coniferous/Bigcone/Coulter
Forest
Jeffrey Pine Forest
Interior Live Oak Chaparral
Southern Maritime Chaparral
Coastal Sage-Chaparral Transition
Montane Buckwheat Scrub
Oct. 11, 2022 Item #12 Page 104 of 560
66
3. Accelerating Deep Decarbonization in the
Transportation Sector
Chelsea Richer, Fehr & Peers
Katy Cole, Fehr & Peers
Eleanor Hunts, Fehr & Peers
Key Takeaways
● Based on the regional policy context, including SANDAG’s 2021 Regional Plan, the
County’s Electric Vehicle Roadmap, local jurisdiction policies and guiding documents,
and the A2Z Gap Analysis, the region has a strong policy foundation for reducing
transportation-related emissions.
● Nevertheless, projected annual emissions in 2045 and 2050 are inconsistent with the
levels of reductions required by California Executive Order (EO) S-3-05, EO B-30-15, and
EO-B-55-18 for carbon neutrality.
● This chapter shows where regional opportunity areas exist to accelerate zero-emissions
vehicle (ZEV)/electric vehicle (EV) adoption and vehicle miles traveled (VMT) reduction
based on existing countywide policies and patterns of vehicle ownership, travel
behavior, and land use development.
● Both ZEV/EV adoption and VMT reduction strategies will be necessary to meet State
decarbonization goals, and no policy will be a silver bullet.
3.1 Introduction
Over the last two decades, California has led the country in pioneering a number of policy
solutions to mitigate climate change-related hazards and create a sustainable economy. In
2006, the state legislature passed Assembly Bill (AB) 32, which established a program to combat
climate change and set a goal to reduce statewide greenhouse gas (GHG) emissions to 1990
levels by 2020. Recognizing that the transportation sector is the largest source of GHG
emissions statewide,1 California has adopted several additional transportation-focused
measures since that initial landmark climate bill. One such law is the Sustainable Communities
and Climate Protection Act of 2008 (Senate Bill (SB) 375). SB 375 targets cars and light-duty
trucks and directs the California Air Resources Board (CARB) to set regional GHG reduction
targets for each metropolitan planning organization (MPO). It requires MPOs to incorporate a
set of GHG reduction strategies, called a Sustainable Communities Strategy, into their Regional
Transportation Plans (collectively known as RTP/SCS). Transportation-related GHG reduction
strategies included in the RTP/SCS often rely on reduction of vehicle miles traveled (VMT) and
Oct. 11, 2022 Item #12 Page 105 of 560
67
changes to the fleet mix to incorporate more Zero-Emission Vehicles (ZEVs).
A series of executive orders signed over the years have further contributed to the state’s
climate platform. California Executive Order (EO) S-3-05 set a goal to reduce GHG emissions to
80 percent below 1990 levels by 2050, B-30-15 set an interim goal of reducing emissions to 40
percent below 1990 levels by 2030, and B-55-18 called for the state to achieve carbon
neutrality by 2045 at the latest.
Electrification of end-use services, including vehicles, and decarbonization of electricity
generation have been identified as key pathways to achieving a low-carbon future (Appendix
A). Additional executive orders and state legislation have established targets for ZEVs, Electric
Vehicles (EVs), and related charging infrastructure. EO B-48-18 established goals for 200
hydrogen fueling stations and 250,000 EV charging stations (including 10,000 DC fast chargers)
to support 1.5 million ZEVs on the road in California by 2025 and 5 million ZEVs on the road by
2030. AB 2127, signed in 2018, requires the California Energy Commission, working with CARB
and the Public Utilities Commission (PUC), to prepare a statewide assessment of EV charging
infrastructure needed to support levels of EV adoption required to meet the goals of EO-B-48-
18. Finally, EO N-79-20 laid out a set of transportation decarbonization targets, including a
mandate that 100 percent of in-state sales of new passenger cars and trucks are zero-emission
vehicles by 2035 and that operations of medium- and heavy-duty vehicles are zero-emission
vehicles by 2045.
Increasing the share of ZEVs and EVs on the road must come in tandem with strategies to
improve overall travel efficiency through reducing VMT while allowing Person Miles Traveled
(PMT) to remain the same. Transportation emissions are a product of emissions per mile and
vehicle miles traveled, and the number of miles traveled is directly linked to land use and urban
form. Even if all VMT were the product of ZEVs, the lifecycle emissions of vehicle manufacture,
roadway maintenance, and waste management would still occur, along with the impact to
carbon sequestration potential of agricultural or conservation lands that are developed.
Further, while not directly related to emissions, patterns of increasing VMT over time can
worsen things like congestion and crash risks in a community, and limit access for people who
cannot drive. Therefore, policies that emphasize active transportation in densely developed
areas, discourage continued vehicle-dependent sprawl, and encourage construction of more
housing near workplaces and services are critical to reducing VMT and meeting emissions
reductions targets while still enabling people to reach the destinations they need to live
fulfilling, high quality lives.
Neither substituting fossil fuel-based vehicles with ZEVs and EVs nor any single VMT reduction
strategy will be a silver bullet. To meet local and state transportation decarbonization targets,
the County and local jurisdictions will need to pair ZEV/vehicle electrification strategies with
Oct. 11, 2022 Item #12 Page 106 of 560
68
land use changes that reduce trip distance and car dependence. Strategies that simply focus on
the shift to ZEVs and EVs will not lower VMT, and some VMT reduction strategies may limit
movement if they are deployed in places that have no other transportation options beyond a
personal vehicle. Therefore, decision-makers must decide how to best phase in EVs without
encouraging additional driving, and how to best lower VMT without limiting access to
destinations and opportunities. These decisions will be dependent on an area’s context and
must consider environmental, social, and financial trade-offs.
The remainder of this chapter describes the regional policy context for the transportation
sector, the modeling efforts that underpin land use and transportation plans in the region, and
policy pathways to decarbonization through accelerated adoption of ZEVs and EVs, accelerated
reduction of VMT, and continued investment in vehicle and fuel technology.
3.2 Regional Policy Context
The San Diego region has undertaken a number of transportation decarbonization efforts to
date, which have included a variety of VMT reduction strategies and vehicle electrification
strategies. This section details the relevant policy documents that will continue to shape the
San Diego region’s ability to reach accelerated decarbonization targets.
3.2.1 SANDAG’s 2021 Regional Plan & 5 Big Moves
The San Diego Association of Governments (SANDAG) is the MPO for the San Diego region and
has recently adopted the 2021 Regional Plan, a blueprint for land use and transportation
planning in the San Diego region through 2050. This plan serves as the RTP/SCS and provides
the big-picture vision for the future as well as an implementation program to make the region’s
transportation system “faster, fairer, and cleaner.” The 2021 Regional Plan identifies a 2030
target of 771,000 EVs on the road in the San Diego region, supported by 155,200 chargers.2
The 2021 Regional Plan articulates SANDAG’s future investments around the 5 Big Moves, an
aspirational vision that provides a framework for the 2021 Regional Plan. The 5 Big Moves
include VMT reduction strategies and strategies that encourage electrification of surface
transportation vehicles.3 Over the next 30 years, SANDAG will refine the transportation network
and discuss a set of policies and programs to support the following planned infrastructure and
technology improvements: Complete Corridors, Transit Leap, Mobility Hubs, Flexible Fleets, and
Next Operating System.
Oct. 11, 2022 Item #12 Page 107 of 560
69
1. Complete Corridors would provide a balanced and inclusive road and highway network
to maximize capacity, reduce congestion, and enable a variety of travel choices. Key
features include managed lanes, Active Transportation and Demand Management
(ATDM)i, smart high-speed communication networks, priority for shared transportation
modes, and curb management. Complete Corridors are the backbone for the Transit
Leap and Flexible Fleets strategies.
2. Transit Leap would complement Complete Corridors by creating a comprehensive
network of high-speed, high-quality transit services that connect residential areas with
employment centers and attractions. Future transit services would build upon existing
ones through expanded service times, higher frequency and capacity, transit priority,
and better integration with other services.
3. Mobility Hubs are envisioned as a network of connected places with land use
supportive of integrated mobility services and amenities, reducing the distance people
need to travel to reach key destinations and enabling more transit, walking, and biking.
Mobility hub area amenities include interactive trip planning kiosks, electric vehicle
charging, passenger loading areas, and secure parking for bicycles. SANDAG’s proposed
network consists of the San Diego urban core, plus 30 surrounding mobility hub areas
across the region. Mobility Hub prototypes have been developed for eight stops along
the Mid-Coast Trolley route and eight additional locations across the region.
4. Flexible Fleets describes the strategy of shared, on-demand transportation services
which include micromobility, rideshare, microtransit, ride hailing, and last-mile delivery.
This strategy relies on public-private partnership and assumes many of the new modes
introduced would be electric-powered.
5. Next Operating System (OS) is a digital platform that compiles information from various
parts of the transportation system into a centralized data hub, thereby linking residents,
businesses, and operators to real-time transportation data and providing planners and
policymakers with a new repository for analysis. Next OS also includes Intelligent
Transportation Systems (ITS) strategies that can reduce VMT, such as expansion of
broadband to enable remote work and apps to enable payment for mobility services.
The 5 Big Moves are strategies that directly and indirectly reduce VMT and accelerate EV
adoption. In addition, Next OS is an underpinning strategy to improve data about the
transportation sector so that it can continue to be analyzed and optimized over time.
i The ATDM program is intended to support agencies and regions considering moving toward an active
management approach. It involves dynamic demand management, traffic management, parking management, and
efficient utilization of other transportation modes and assets. Under an ATDM approach, the transportation system is continuously monitored and actions are performed in real-time to achieve or maintain system
performance.
Oct. 11, 2022 Item #12 Page 108 of 560
70
3.2.2 Accelerate to Zero Emissions Electric Vehicle Gap Analysis (2021)
The Accelerate to Zero (A2Z) Emissions Collaborative is an initiative by regional organizations
invested in advancing zero-emissions transportation, including the City and County of San
Diego, the San Diego Air Pollution Control District, SANDAG, and San Diego Gas & Electric
(SDG&E). In July 2021, it published the San Diego Regional Electric Vehicle Gap Analysis, which
identified existing efforts and conditions and evaluated zero-emission infrastructure gaps and
barriers. As the A2Z Emissions Collaborative continues its work, the EV Gap Analysis will
facilitate prioritizing Communities of Concerni for transportation decarbonization investments.
The Gap Analysis identifies a 2030 target of 771,000 EVs on the road in the San Diego region,
supported by 139,000 Level 2 chargers; 16,200 DC fast chargers; and 47 hydrogen fueling
stations.4 Building on the Gap Analysis, A2Z has embarked on a Regional EV Strategy, scoped by
SANDAG, which will guide the region in electrifying light-duty, medium-duty, and heavy-duty
vehicles and infrastructure and implementing the Regional Plan.
3.2.3 San Diego County’s Electric Vehicle Roadmap (2019)
The County of San Diego adopted an Electric Vehicle Roadmap in October 2019, which contains
six goals and 11 recommendations that leverage the County’s land use authority, permitting
processes, and outreach platforms in order to increase EV ownership and charging installations
in the unincorporated area and at County facilities.5 These are summarized in Table 3.1, below.
Because this document relates primarily to the unincorporated area of San Diego, the numbers
reported for 2030 EV targets and charger targets are substantially different from the more
current SANDAG or A2Z numbers.
i Pursuant to Title VI, Executive Order 12898 and the 1999 Department of Transportation Memorandum
“Implementing Title VI Requirements in Metropolitan and State Planning,” SANDAG’s Regional Planning
Stakeholders Working Group defined four types of “Communities of Concern” (Low Income Community of
Concern, Minority Community of Concern, Low Mobility Community of Concern, and Low Community Engagement Community of Concern) as part of its 2050 RTP social equity analysis. Selection criteria are detailed at length in
Chapter 4 of the SANDAG 2050 Regional Transportation Plan.
Oct. 11, 2022 Item #12 Page 109 of 560
71
Table 3.1. Summary of actions in San Diego County’s 2019 Electric Vehicle Roadmap. This table shows the goals,
associated targeted outcomes, and recommendations in the roadmap.
Goal Targeted Outcome Recommendations
County Operations Recommendations
1. Further reduce the
County’s fleet of gas-
powered vehicles.
Increase the number of EVs
in the County’s fleet to 501
by 2027.
Amend three Board policies to assist fleet EV
conversion by requiring new light-duty vehicles
to be EV.
Convert 250 County fleet gas-powered vehicles
to EVs by 2025 and install necessary
infrastructure.
Convert an additional 251 County fleet gas-
powered vehicles to EVs for a total of 501 by
2027 and install necessary infrastructure.
Keep pace with technological trends, track the
costs and benefits of fleet conversion, and
update the Green Fleet Action Plan no later than
2025 to set goals for medium- and heavy-duty
fleet vehicle conversions.
2. Accelerate the installation
of EV charging stations at
public locations in County
facilities and in the
unincorporated County.
Contribute to the regional
EV charging network by
installing 2,040 Level II
charging stations at County
facilities and throughout the
unincorporated area by
2028.
Amend Board policy G-15, “Design Standards for
County Facilities” by 2019 to require charging
infrastructure development at new County
facilities.
Install an additional 63 publicly accessible EV
charging stations for a total of 100 chargers at
County facilities by 2021.
Prepare an EV charger site assessment for
County facilities and the unincorporated area
and install 2,040 Level II chargers.
3. Promote and incentivize
County employee EV
ownership.
Increase County employee
EV ownership and use to
reduce employee commute
emissions.
Promote and incentivize County employee EV
use by developing partnerships with banks,
credit unions, and dealerships to extend lending
and pricing benefits.
Unincorporated Area Recommendations
4. Incentivize and/or require
EV charging infrastructure in
new and existing private
multi-family residential
and/or non-residential
development.
Increase charging station
installations in new and
existing private
development.
Prepare a cost-benefit analysis of options to
incentivize and/or require EV charger
installations in private development.
5. Fund EV expert/consumer
advocate as a regional
resource.
Increase EV ownership and
charging station
installations through
education, outreach,
regional collaboration, and
incentives.
Identify regional partners and cost sharing
opportunities to fund a regional EV
expert/consumer advocate on an ongoing basis.
6. Collaborate with regional
partners to support public
and private fleet
electrification.
Increase EV use in regional
light-, medium-, and heavy-
duty fleets.
Develop public and private regional partnerships
to provide fleet electrification technical support
on an ongoing basis.
Oct. 11, 2022 Item #12 Page 110 of 560
72
3.2.4 San Diego County’s Climate Action Plan (2018)
Through Climate Action Plans (CAPs), the County of San Diego and most cities within the region
have set out a series of measures to reduce GHG emissions over the coming decades. The
County’s 2018 CAP, which is currently being revised to achieve compliance with the California
Environmental Quality Act (CEQA), included 11 strategies and 26 measures which focus on
activities that occur within the unincorporated area of the region and within County-owned
facilities.5 The framework for the 2018 CAP is the GHG emissions inventory (baseline year 2014)
and the state’s GHG reduction targets. San Diego County set total emissions targets of
3,147,275 and 1,926,903 metric tons of CO2 equivalent (MTCO2e) for 2020 and 2030,
respectively. Measures in the Built Environment and Transportation GHG emissions sector
specifically are projected to help the County achieve reductions of 233,758 MTCO2e in 2030.6
3.2.5 City of San Diego’s Climate Action Plan (2015)
The City of San Diego adopted its landmark CAP in 2015 and projected that its implementation
would help the city surpass the target of 51 percent below 2010 GHG emissions by 2035 and
maintain its trajectory to meet its proportional share of the 2050 state target. Among the local
strategies for achieving the GHG reduction targets are a range of activities that aim to decrease
transportation-related emissions by improving mobility and reducing VMT. Specific
implementation measures involve changing land uses, promoting alternative modes of travel,
and enhancing vehicle fuel efficiency. As the largest jurisdiction in the region, the policies and
actions of the City of San Diego can help provide resources and examples against which other
jurisdictions can model their approach (more details on regional collaboration can be found in
Chapter 7).
3.2.6 Summary of Additional State, Regional, and Local Goals and Actions
In addition to the County and City of San Diego’s CAPs, the majority of jurisdictions in the region
have also adopted CAPs, with relevant goals around VMT reduction, EV adoption, and emissions
reductions for the transportation sector. Some have additionally developed targets and taken
actions related to the adoption of EVs and/or the implementation of charging infrastructure.
This regional context was included in the A2Z Gap Analysis; the information in that document
has been updated as part of this report and is summarized in Table 3.2 below.
Oct. 11, 2022 Item #12 Page 111 of 560
73
Table 3.2 San Diego regional jurisdictions’ relevant goals, targets, and actions that are relevant to encouraging
ZEVs, EVs, and transportation decarbonization.
Jurisdiction Relevant Goals, Targets, and Actions
Regional and State Agencies
Caltrans
District 11
● Currently partnering with SDG&E to provide charging at park and ride facilities throughout
the region.
● Installing corridor charging at rest areas and remote inter-city travel locations.
● Released a study in 2020 demonstrating the feasibility of building a railroad tunnel through
the University City area to improve service between San Diego and Los Angeles.
County of San
Diego
● Established streamlined permitting processes in 2017, compliant with AB 1236, to encourage
EV charging infrastructure in new developments.
● Adopted the Electric Vehicle Roadmap in 2019.
North County
Transit District
● Developed a Zero-Emission Bus Rollout Plan, detailing full transition by 2042.
● Planning to purchase six battery electric and eight hydrogen fueled buses by 2023.
Port of San
Diego
● Adopted the Maritime Clean Air Strategy to help the Port identify future projects and
initiatives to improve health through cleaner air for those who live, work, and play on and
around San Diego Bay.
SANDAG ● Adopted a Regional EV Readiness Plan in 2014 and launched Plug-In San Diego in 2015.
● Committed $2b for transportation electrification programs through 2050, including:
o $45m through 2025 to support build-out of the Level 2 charger network.
o $52m through 2025 to a new regional zero-emission vehicle incentive program.
o $100m through 2025 for zero-emission buses, zero-emission trucks, and associated
infrastructure.
● Identified additional zero-emissions, electrification, and mode-shift opportunities through
the 2021 Regional Transportation Plan and associated Big 5 Moves.
● Providing climate planning services for local jurisdictions, including the Regional Climate
Action Planning (ReCAP) Framework and preparation of ReCAP Snapshots to assist local
jurisdictions in monitoring CAP implementation.
● Administering the Smart Growth Incentive Program, Active Transportation Grant Program,
Housing Acceleration program, and iCommute programs. ● Improving the LOSSAN rail corridor over the next 20 years, which will improve freight and
passenger movement between major metropolitan areas of Southern California and the
Central Coast, and from the Orange County line to the Santa Fe Depot in Downtown San
Diego specifically within the region.
● Sponsored the Youth Opportunity Pass pilot program to provide free use of MTS and NCTD
services to all riders 18 and under.
San Diego
County Air
Pollution
Control
District
(SDAPCD)
● Developed Community Emissions Reductions Plans to reduce cumulative exposure to air
pollution in individual communities, such as the Portside Communities CERP in 2021.
● Administering grant funding through various incentive programs such as the Carl Moyer
Program, which encourages a transition to cleaner-than-required engines, equipment, and
other sources of air pollution.
● Updated an existing Memorandum of Understanding with CARB in 2021 to expand the
District’s authority to conduct inspections and enforce air pollution regulations for mobile
source pollution.
San Diego Metropolitan
Transit System
● Developed a transition plan to convert its fleet of 800 buses to ZEV by 2040. ● Acquired thirteen battery electric buses by 2021 and will acquire a total of 25 by the end of
2022.
Oct. 11, 2022 Item #12 Page 112 of 560
74
Jurisdiction Relevant Goals, Targets, and Actions
Cities
Carlsbad ● Adopted residential and non-residential ordinances for EV parking.
● Adopted 2011 CAP goal to increase ZEV miles from 4.5% to 25% by 2035.
Chula Vista ● Currently, has 31% of alternatively-fueled fleet vehicles; continuing to work towards their
CAP goal of 40% by 2020.
● Installed around 120 chargers for their fleet vehicles.
Coronado ● Identified “greening” the city’s 100 fleet vehicles as a way to reduce transportation
emissions.
Del Mar ● Adopted CAP goal to increase alternatively-fueled VMT to 20% in 2020 and 30% in 2035.
● Adopted CAP goal to set aside 10% of on-street parking and in city lots for high-efficiency and
clean vehicles by 2020.
El Cajon ● Plans to install 128 new EV charging stations at commercial developments and 79 new EV
charging stations at multi-family developments by 2030.
● Launched a 5-year Vehicle-to-Grid pilot project with SDG&E to test electric school buses.
Encinitas ● Requires new residential units to install EV charging infrastructure.
● Multi-family developments must include EV charging infrastructure at 5% of the total
number of parking spaces.
Escondido ● Plans to install 281 EV charging stations in park and ride lots by 2035.
Imperial Beach ● Encourages developers to install EV charging infrastructure for new and retrofit
developments.
● Planning to assess their municipal fleet replacement timeline for switching to ZEVs.
La Mesa ● Partnered with SANDAG, SDAPCD, and local developers to develop strategies to increase EV
infrastructure at existing multi-family complexes.
Lemon Grove ● Plans to adopt a zoning ordinance requiring installation of EV charging infrastructure at 5% of
the total number of parking spaces at new multi-family and commercial developments.
National City ● Installed charging stations at City Hall.
● Partnered with SDG&E to install EV charging infrastructure across the City.
Oceanside ● Plans to require new single-family developments to include prewiring to enable 240-volt
charging.
Poway ● Installed 11 EV charging stations around the City.
San Diego ● Adopted CAP goal to convert 90% of gas-powered municipal fleet vehicles to zero-emission
by 2035.i
● Installed 57 public EV charging stations at City facilities.
● Partnered with SDG&E on its Power Your Drive project to make EV charging stations more
accessible to apartment and condo dwellers, and workplace employees.
San Marcos ● Require new multi-family and commercial developments to include EV charging
infrastructure at 5% of the total number of parking spaces.
Santee ● Requires all new residential and commercial developments to install e-chargers.
Solana Beach ● Collaborating with SANDAG to increase EVs in the City.
Vista ● Requires new multi-family developments to have 3% of total parking spaces equipped with
EV charging infrastructure.
● Requires new commercial developments to have 6% of total parking spaces equipped with
EV charging infrastructure.
Sources: San Diego Regional EV Gap Analysis, July 2021; SANDAG 2021 Regional Plan; input from San Diego jurisdictions.
i The City of San Diego’s current CAP was adopted in 2015. At the time of this publication, the city was in the
process of gathering public comment on its 2021 CAP. The finalized 2021 plan may include additional
commitments and/or stronger commitments for municipal fleet vehicles.
Oct. 11, 2022 Item #12 Page 113 of 560
75
3.2.7 Limitations of Regional and Local Efforts
As described above, various efforts on the local and regional level inform the direction of the
San Diego region’s ability to reduce transportation-related GHG emissions. The number of entities,
jurisdictions, and planning efforts with unique direct authority over different elements of transportation
decarbonization underscore the need for coordinated action. It is especially important for regional and
local entities to come together around shared goals and vision, despite each entity’s diverse
needs, responsibilities, and direct authority.
For example, the CAP has emerged as one of the primary planning efforts that local jurisdictions
undertake to describe the necessary steps to achieve GHG emissions reductions across all
sectors. They are useful tools to document GHG reduction commitments and implementing
actions and they can be powerful spaces to convene discussions around what is possible within
a jurisdiction. However, they can also be somewhat limiting if a jurisdiction plans to utilize the
CAP to streamline future CEQA reviews to evaluate GHG impacts of land use development or
transportation projects. The CEQA process requires a rigorous level of evidence-based
defensibility, which is not often available for many leading-edge or innovative ideas simply
because they have not yet been established as evidence-based best practices. Therefore, CAPs
often lack incentives to promote innovative transportation or mobility ideas that lack defensible
GHG reductions.
In addition, because they are not interjurisdictional, individual CAPs’ transportation
commitments can only affect local transportation emissions within that jurisdiction’s control,
which may limit measures’ effectiveness at reducing regional VMT and GHG emissions. The
projects that would be most effective at moving the needle on reducing VMT – such as major
investments in rail infrastructure or bus rapid transit (BRT) corridors – are responsive to
regional (e.g., interjurisdictional) travel patterns and needs. The land use commitments in a
jurisdiction’s CAP can complement regional investments and have a major effect on creating a
more compact, walkable, transit-oriented community, thereby reducing local VMT. To have the
greatest effect, these land use goals and commitments must also be reflected in the
jurisdiction’s General Plan, which may or may not be updated on the same timeline as the CAP.
In contrast, SANDAG’s regional planning efforts, such as the 2021 Regional Plan and efforts
through the A2Z Collaborative, can help align local jurisdictions with regional agencies that
implement regional transportation projects, such as MTS and North County Transit District. This
can be a powerful space to convene around a shared vision and set of climate goals. However,
SANDAG lacks the land use and zoning authority to maximize the investments through changes
to land use development patterns that are more compact, diverse, and transit-oriented.
Efforts such as this Regional Decarbonization Framework are a helpful addition to the landscape
Oct. 11, 2022 Item #12 Page 114 of 560
76
because they are not constrained by CEQA requirements, fiscal limitations, or limited
control/authority. This effort aims to identify the key priority actions that can be taken at each
level of authority throughout the San Diego region to maximize a coordinated effort at reducing
VMT, while maintaining access to opportunity and destinations, and accelerating EV and ZEV
adoption for those trips that must be taken in a vehicle.
3.3 Transportation Modeling & Emissions Forecasts
In support of this report, Fehr & Peers has undertaken a review of the assumptions and
outcomes of the SANDAG regional model and Evolved Energy’s EnergyPATHWAYS model
described in Appendix A. There are fundamental differences between the two models. SANDAG
uses an activity-based model (ABM) that simulates individual and household transportation
decisions at a detailed level. The most current model is ABM2+, which is being used to support
the 2021 Regional Plan. EnergyPATHWAYS estimates energy use and GHG emissions given a
specific electrification trajectory and fleet composition.
SANDAG’s ABM2+ simulates travel behavior in the San Diego region using land use and
transportation network data to estimate VMT and estimate corresponding GHG emissions.
ABM2+ starts with a street-based active transportation network, a highway network, and a
transit network. The resident transportation model, disaggregate models, and aggregate
models are executed, and the resulting trip tables are summed up and used by an iterative
traffic assignment process. The outputs – specifically, VMT by speed bin and vehicle
classification – are then converted off-model to greenhouse gas emissions using Emission
Factors (EMFAC) emissions factors.
EnergyPATHWAYS is a stock accounting tool from Evolved Energy that quantifies all energy
infrastructure. The transportation portion of the model uses service demand projections,
existing vehicle stock, and efficiency measures to estimate total emissions. The model can be
made applicable to varying geographies across the nation by modifying the underlying
parameters. In the context of California, it uses the 100% ZEV sales by 2035 goal and makes
assumptions about adoption of EV technologies.i In this model, decarbonization comes from
fuel shifts, not mode shifts. As such, many factors that are central to ABM2+, such as VMT, are
not considered.
For the purposes of this chapter, the 2021 Regional Transportation Plan and SANDAG’s ABM2+
are discussed further. At the conclusion of this chapter, Appendix 3.A provides a summarized
comparison between the two models. Appendix A of the report provides full technical
i For more information on the EER modeling assumptions, see Appendix A.
Oct. 11, 2022 Item #12 Page 115 of 560
77
documentation for the EnergyPATHWAYS model.
3.3.1 SANDAG Emissions Forecasts
As described above, SANDAG’s 2021 Regional Plan includes policy and transportation
investment initiatives that are referred to as the 5 Big Moves, which aim to deliver an efficient
and equitable transportation system that meets regional per capita GHG reduction targets
assigned by the California Air Resources Board. However, these policies and actions are not
sufficient on their own to meet the requirements of EO S-3-05 and EO B-55-18, as described in
the emissions forecasts included in the 2021 Regional Plan Environmental Impact Report (EIR).
In order to reach deep decarbonization goals, additional efforts, such as the policies described
in section 3.5 of this chapter, will be necessary both to rapidly electrify the surface
transportation sector and to reduce VMT.
The 2021 Regional Plan EIR evaluates environmental impacts related to regional growth and
land use change as well as the transportation network improvements and programs of the 5 Big
Moves together because the per-capita CO2 emissions from vehicles addressed by state targets
are influenced by the combined effects of both components. ABM2+ models the effect of the 5
Big Moves in conjunction with the rest of the 2021 Regional Plan through four forecast
scenarios: Baseline Year 2016, interim years 2025 and 2035, and Horizon Year 2050.
Compared to existing conditions, the EIR shows that the regional growth, land use change, and
transportation network improvements included in the 2021 Regional Plan would result in a
reduction of GHG emissions across all sectors for all interim and horizon years. These
reductions are summarized in Figure 3.1, which shows GHG impact of Passenger Cars and Light-
Duty Vehicles with and without the SAFE Rule Impact (the Safer Affordable Fuel-Efficiency
Vehicle Rule, also known as the SAFE Rule, which was adopted in 2019 and rescinded in 2021,
set national fuel economy standards instead of California standards). Passenger Cars and Light-
Duty Vehicles emissions are also forecasted to decrease for all interim and horizon years.
Heavy-Duty Trucks and Vehicles emissions are forecasted to remain the same from 2025
onward. Rail emissions are forecasted to increase between 2016 and 2050. Projected annual
emissions in 2045 and 2050 (18 million MTCO2e across all sectors and 7.5 million MTCO2e for
the Surface Transportation sector, including Passenger & Light-Duty with no SAFE Rule impact,
Heavy-Duty & Trucks, and Rail) would be inconsistent with the levels of reductions required by
EO S-3-05, EO B-30-15, and EO-B-55-18.i
i EO S-3-05 requires a reduction of GHG emissions to 80 percent below 1990 levels by 2050. EO B-30-15 requires a
reduction of GHG emissions to 40 percent below 1990 levels by 2030. EO B-55-18 requires carbon neutrality across
all sectors by 2045.
Oct. 11, 2022 Item #12 Page 116 of 560
78
Figure 3.1 Summary of 2016 Greenhouse Gas Inventory and Greenhouse Gas Projections, (SANDAG 2021 Regional
Plan EIR Table X.3).
Per SB 375, specific GHG emissions reduction targets for the transportation sector are not yet
established for Horizon Year 2050, but the target established for SANDAG for 2035 is to reduce
per capita CO2 emissions from passenger cars and light-duty vehicles to 19 percent below 2005
levels. As shown in Table 3.3, implementation of the 2021 Regional Plan would reduce per
capita CO2 emissions from this sub-sector of Surface Transportation to 20 percent below 2005
levels by 2035, and therefore would meet SB 375 targets.
Oct. 11, 2022 Item #12 Page 117 of 560
79
Table 3.3 SB 375 GHG reduction targets under the proposed plan from passenger vehicles and light-duty trucks,
2035, (2021 Regional Plan EIR Table 4.8-9).
Per Capita Reductions
from 2005 Levels
Per Capita Reduction under the Proposed Plan (On-Model Results Only) -19.30%
Per Capita Reduction under the Proposed Plan (Off-Model Results Only) -3.03%
CARB Adjustment Factor for EMFAC 2007–2014 1.70%
Induced Demand Adjustment Factor 0.20%
Per Capita Reductions -20.40%
CARB Target -19%
The EnergyPATHWAYS model shows that the region needs to reduce transportation GHGs by
25%-47% by 2030, 51%-82% by 2035, and 100%-109% by 2050 in order to reach the State’s
emissions goals. SANDAG’s estimates show projected reductions of 27% by 2030, 34% by 2035,
and 34% by 2050. Therefore, SANDAG’s policy landscape meets the low end of the range that
has been modeled by the EnergyPATHWAYS model for the horizon year of 2030 (the
“Electrification Delay” scenario), but does not meet the range of scenarios modeled after the
2030 horizon year. These gaps suggest that current policies do not put the region on track to
meet State emissions reductions goals.
3.4 Decarbonization Strategies: Policy Pathways to Close the Emissions Gap
Based on the regional policy context summarized above, including SANDAG’s 2021 Regional
Plan, the County’s Electric Vehicle Roadmap, local jurisdiction policies and guiding documents,
and the A2Z Gap Analysis, the San Diego region has a strong policy foundation for reducing
emissions related to transportation through accelerated alternative vehicle and fuel technology
improvements, and accelerated VMT reduction. The remainder of this section describes the
ways in which the region’s jurisdictions can accelerate actions needed to achieve regional
decarbonization of the transportation sector.
3.4.1 Accelerate Alternative Fuel and EV Adoption
Alternative fuels for transportation are those derived from sources other than petroleum.
Electricity is a cost-effective, secure, and powerful alternative fuel that has been the focus of
decarbonization in the transportation sector, especially in passenger vehicles and transit
vehicles. Within the 5 Big Moves and the 2021 Regional Plan more broadly, electrification is
identified as a major factor in reaching regional GHG emissions reduction targets by:
● Establishing programs to incorporate EVs into Flexible Fleets and Transit Leap
● Including incentive programs that could increase the number of EVs and charging
stations throughout the region and within Mobility Hub areas.
Oct. 11, 2022 Item #12 Page 118 of 560
80
Complete Corridors support alternatives to single occupancy driving, including modes such as
transit, shared rides, and active transportation, and would help the San Diego region reach its
2030 decarbonization goals. The 2021 Regional Plan also supports electrification of the region’s
transit buses and supports the state’s Innovative Clean Transit regulation. Per the plan
documentation, it is likely that future high-speed rail projects will be powered by a combination
of both diesel and electricity. In order to accelerate decarbonization through this strategy,
SANDAG would need to adopt an aggressive implementation timeline for Complete Corridors
and Transit Leap, focusing first on implementation in the parts of the region where transit will
be most viable and well-utilized. While high-quality transit expansion is most efficient along
corridors that are heavily populated and traveled, county-wide mass transit adoption will
require transit infrastructure investments, such as BRT and rail, that reach rural and
backcountry areas. Rather than only fulfilling current transit demand, SANDAG can craft a
transit-for-all plan for a systemic adoption of public transit. Additionally, this plan should ensure
that investments are located in a manner that does not contribute to habitat fragmentation.
The 5 Big Moves documentation also mentions several partnerships and policies that can assist
with public charging and hydrogen fueling stations build-out. These include the CALeVIP San
Diego County Incentive Project, which began providing rebates for placement of public level 2
and direct current fast charging stations in late 2020. The County is coordinating with SDG&E to
manage the demands that EV charging places on the grid. SANDAG and SDG&E are also working
to provide programs that install charging stations for workplaces, multi-unit dwelling
communities, and medium- and heavy-duty vehicles. In order to accelerate decarbonization
through this strategy, SANDAG and SDG&E would need to increase the levels of incentives
and rapidly advance EV charging infrastructure installations, focusing first on Communities of
Concern and then in places where transit is not yet viable.
In addition to the electrification-related components of the 5 Big Moves , the A2Z EV Gap
Analysis articulates actions and policies to accelerate EV adoption in the San Diego region.
Although the main goal of the Gap Analysis was to identify needs in order to inform a long-term
strategy, the report captured some initial solutions. These include:
● Decreasing the upfront costs of EV ownership through incentives, targeting both the new
and secondary markets;
● Leveraging cooperative buying for medium- and heavy-duty fleets;
● Exploring alternatives to vehicle-purchase incentives, including low-emission zones, EV
mandates, ordinances, or registration controls to enforce emissions standards;
● Streamlining permitting for charging infrastructure;
● Prioritizing infrastructure in communities of concern;
● Coordinating education campaigns for end users, property owners, and frontline
salespeople; and
● Providing workforce training for commercial drivers and automotive maintenance workers.
Oct. 11, 2022 Item #12 Page 119 of 560
81
3.4.1.1 Downscaled Geographic EV Adoption Targets
The 2021 Regional Plan identifies an EV population target of 771,000 across the San Diego
region by 2030, of which approximately 762,000 are light-duty vehicles or vehicles operated by
Transportation Network Companies (TNCs). Based on the current distribution of registered EVs
in the region, we identified which jurisdictions will need to accelerate adoption policies most
aggressively to meet the stated goals. Table 3.4 shows the share of regional population within
each San Diego regional jurisdiction, the share of total regional VMT, the current number of
EVs, the current number of vehicles, and the proportion of EVs as a share of each jurisdiction’s
vehicle population. Figure 3.2, following the table, shows the share of EVs as a proportion of all
vehicles, by jurisdiction.
Table 3.4 Jurisdiction-level EV population, population share, and VMT share in the San Diego region.
Jurisdiction Total #
EVs
(2020)
Total #
Vehicles
(including
EVs) (2020)
Share % of
Total Vehicles
that are EVs
(2020)
Total Vehicle
Ownership
Share %
(2020)
Share of
Regional
Population
(2020)
Share of
Regional
VMT
(2012)
Unincorporated
San Diego County
7,838 473,689 1.7% 16.9% 15.4% 15%
Carlsbad 3,804 92,092 4.1% 3.3% 3.4% 4.5%
Chula Vista 2,708 205,797 1.3% 7.3% 8.1% 5.7%
Coronado 395 12,727 3.1% 0.5% 0.7% 1.0%
Del Mar 861 13,358 6.4% 0.5% 0.1% 0.3%
El Cajon 1,183 126,488 0.9% 4.5% 3.1% 2.9%
Encinitas 2,318 51,148 4.5% 1.8% 1.9% 2.1%
Escondido 2,222 139,093 1.6% 5.0% 4.5% 4.5%
Imperial Beach 128 17,299 0.7% 0.6% 0.8% [n.d.]i
La Mesa 967 54,751 1.8% 2.0% 1.8% 1.9%
Lemon Grove 145 20,861 0.7% 0.7% 0.8% 0.6%
National City 145 42,934 0.3% 1.5% 1.8% 1.7%
Oceanside 1,979 112,863 1.8% 4.0% 5.3% 4.3%
Poway 1,240 40,736 3.0% 1.5% 1.5% 1.9%
San Diego 25,337 1,179,150 2.1% 42.1% 42.6% 46.3%
San Marcos 1,876 73,657 2.5% 2.6% 2.9% 2.7%
Santee 544 44,691 1.2% 1.6% 1.7% 1.4%
Solana Beach 554 10,580 5.2% 0.4% 0.4% 0.6%
Vista 1,208 88,872 1.4% 3.2% 3.0% 2.6%
TOTAL 55,452 2,800,786 n/a 100% 100% 100%
Notes: 1. EV population and total vehicle population data from California Energy Commission (2020).7 2.
Population data from American Community Survey 5-Year Estimates (2016-2020),8 extracted by jurisdiction.
Unincorporated San Diego County values calculated as the difference of all jurisdictions and the total county
population. 3. VMT data from SANDAG ABM1 (2012).9 Total VMT is calculated using the Origin-Destination method
at the TAZ level and then aggregated to the jurisdictional level, which may result in some double-counting of trips
but overall reflects a reasonable proportional share of the County’s VMT.
i No VMT data were available for Imperial Beach at the time of the analysis.
Oct. 11, 2022 Item #12 Page 120 of 560
82
Figure 3.2 EV share of all vehicles, by jurisdiction in 2020. Darker colors represent higher shares of EVs. Source: California Energy Commission, 2020. Created by
Fehr & Peers, 2022.Oct. 11, 2022Item #12 Page 121 of 560
83
To show where policy efforts can be focused to help accelerate EV ownership efforts, the
countywide 2030 EV targets can be downscaled to the jurisdictional level. Table 3.5 shows the
future target number of EVs based on three alternative methods of calculation:
● Based on population share
● Based on VMT share
● Based on vehicle ownership share
There is no perfect way to downscale EV targets to the local jurisdictional level. Basing the
future target on population would follow the A2Z approach to determining the target number
of EVs in the San Diego region as a proportion of California’s targets. However, this would
produce an overestimated target in places where vehicle ownership rates are lower than
average. Basing the future target on VMT would produce more aggressive targets in places
where people drive longer distances. Basing the future target on vehicle ownership would reify
the existing vehicle ownership patterns, which reflect the current inequities of EV ownership
due to the cost of purchasing a vehicle as well as existing land use and travel behavior patterns.
These travel patterns may change in the future as a result of future land use development
patterns, encouraging more transit-oriented development (discussed further in the section to
follow). These downscaled targets are intended therefore to reflect a range of reasonable order
of magnitude for each jurisdiction’s EV population in 2030.
To support the local acceleration of EV adoption towards the targets identified above, it will
also be necessary to accelerate the rollout of EV charging infrastructure. The County and
SANDAG can enhance the Plug-In San Diego Electric Vehicle Charging Map to provide improved
modeling for charging infrastructure location suitability at a regional scale.i SANDAG and the
County can collaborate with local jurisdictions to encourage them to undertake a local EV
Infrastructure Siting Plan, to identify more granular placement locations, and to support
infrastructure investments in Communities of Concern.
i The Plug-In San Diego EV Charging Stations Map can be found at https://evcs.sandag.org/, which includes
methodological information about how the TAZs were analyzed to identify EV trip end percentiles.
Oct. 11, 2022 Item #12 Page 122 of 560
84
Table 3.5 Downscaled jurisdiction targets to meet regional A2Z EV goals of 762,000 passenger and TNC EVs across
the San Diego region by 2030.
Jurisdiction Total # EVs
(2020)
Future Target # EVs
Based on
Population Share
Future Target # EVs
Based on VMT
Share
Future Target # EVs
Based on Vehicle
Ownership Share
Unincorporated
San Diego
County
7,838 117,392 113,940 128,875
Carlsbad 3,804 26,228 34,303 25,055
Chula Vista 2,708 61,616 43,693 55,990
Coronado 395 5,622 7,592 3,463
Del Mar 861 993 2,374 3,634
El Cajon 1,183 23,669 22,073 34,413
Encinitas 2,318 14,435 16,294 13,916
Escondido 2,222 34,477 34,574 37,843
Imperial Beach 128 6,266 [n.d.]i 4,706
La Mesa 967 13,802 14,152 14,896
Lemon Grove 145 6,130 4,315 5,676
National City 145 14,062 13,125 11,681
Oceanside 1,979 40,277 32,445 30,706
Poway 1,240 11,412 14,849 11,083
San Diego 25,337 324,276 352,920 320,807
San Marcos 1,876 22,058 20,537 20,040
Santee 544 13,160 10,958 12,159
Solana Beach 554 3,049 4,198 2,878
Vista 1,208 23,075 19,657 24,179
TOTAL 55,452 762,000 762,000 762,000
Note: Percentages from Table 3.4 multiplied by A2Z’s Countywide target of 762,000 passenger vehicles and TNC EV
to determine jurisdictional targets.
3.4.1.2 Policy Opportunity Areas to Accelerate ZEV/EV Adoption
Jurisdictions within the San Diego region have a great deal of room to strengthen policies
related to transitioning to EV fleets and providing sufficient charging infrastructure. Based on
the summary of efforts described in the Regional Policy Context section of this chapter, along
with the findings from the A2Z Gap Analysis, there is a wide variety of policies and actions that
have been informally or formally adopted by jurisdictions across the San Diego region, which
range from more encouragement-based to more requirement-based. There is also variation in
how these policies apply to different types of land use and development. The variety of policies
and actions are summarized in Figure 3.3. Additionally, more information on local authority and
local policy opportunities can be found in Chapter 8 and Appendix B of this report.
Policies shown on the left of Figure 3.3 will likely be insufficient to meet aggressive EV adoption
goals, whereas policies shown on the right would be more effective at meeting aggressive EV
adoption goals. Policies on the top of Figure 3.3 have a narrower application and policies on the
i No VMT data were available for Imperial Beach at the time of the analysis.
Oct. 11, 2022 Item #12 Page 123 of 560
85
bottom can be applied more broadly throughout the region. Thus, policies farther to the right
and farther to the bottom are likely to be both the most effective and to have the broadest
impact. For example, a policy requiring private parking lot owners to install EV chargers will be
more effective than a policy that encourages them to do so (farther to the right) and a
requirement in existing development as a retrofit will have a broader impact than a
requirement on only new development (further to the bottom).
Figure 3.3 A spectrum of policy options to accelerate EV adoption. Policies that are more likely to be effective are
further right and policies that are more likely to have a broad application are further down. Thus, policies in the
bottom right are predicted to be the most effective and to have the broadest application of the policy measure
shown where the top left is predicted to be the least effective and to have the narrowest application of the policy
measures shown.
To accelerate decarbonization most effectively, regional jurisdictions can consider moving their
own policies along the spectrum from more encouragement-based to more requirement-based
and expanding the reach of requirements and ordinances to cover more land use contexts. To
support the accelerated adoption of the strongest and most effective policies, jurisdictions in
the region can offer more appealing incentives to developers for installing charging equipment,
streamline development processes and infill benefits, and provide readily accessible
information for property owners and vehicle owners.
Where collaboration across jurisdictions is required, the County or a Decarbonization Regional
Steering Committee proposed in Chapter 7 can promote partnership across jurisdictions to
Oct. 11, 2022 Item #12 Page 124 of 560
86
support workforce development goals, share information and lessons learned, and support
State-level advocacy to bring implementation funding to the San Diego region. Table 3.6
summarizes ways in which the County and other jurisdictions within the region can implement
these actions and policies or partner to make progress.
3.4.1.3 Continue to Explore Alternative Fuels
For some transportation modes, the path to decarbonization may be a transition to renewable
fuels such as hydrogen, natural gas, propane, and vegetable- and waste-derived oils, rather
than a fully electrified fleet. Electricity-powered batteries currently do not have the capacity to
support large elements of the regional transportation system such as shipping, long-haul
trucking, and aviation. These elements may rely on alternative fuels other than electricity and
on the development of technology and infrastructure to support them. Among the co-benefits
of investing in alternative fuel production and transmission is the opportunity to transition
workers out of gas and fossil fuel industries into new green jobs. A waste-to-energy fuel source
would have the co-benefit of reduced waste in landfills. Though decarbonization of these
transportation methods, such as aviation, shipping, and long-haul trucking, are outside of the
scope of this analysis, they are worthy of additional study.
Many of these technologies are still under development. Until there is a clear pathway to
deploying these alternative fuel options, the County and other jurisdictions can support these
alternative fuels primarily through collaboration, investment, and partnership in research
opportunities, and by participating in regional efforts to advance the field. Once technological
solutions are available and commercially viable for these fuel sources, the Regional
Decarbonization Framework and its implementation plans should be updated and should revisit
the approach to planning, funding, and coordinating infrastructure build outs with utility
operators.
Oct. 11, 2022 Item #12 Page 125 of 560
87
Table 3.6 Electrification strategies and implementation approach, including partnership opportunities across
jurisdictions and with agencies.
Strategy Partnership
Opportunity
County & Local Jurisdiction Implementation Approach
Set Public EV Charger
Target
✔ Update 2019 EV Roadmap to include more aggressive targets;
continue to partner with A2Z Collaborative to downscale
jurisdictional targets on appropriate roadways; identify
partnership opportunities with those jurisdictions that have made
the least progress toward their targets to share information and
successful implementation strategies
Set Fleet Adoption Target ✔ Update 2019 EV Roadmap to include more aggressive targets;
identify partnership opportunities with those jurisdictions that
have made the least progress toward their targets to share
information and strategies to accelerate fleet transition
Set-Aside Public Parking
Spots for Clean Vehicles
Adopt requirements in zoning codes that apply to clean air
vehicles as defined by CalGreen
Encourage EV Charging
Infrastructure at
Development Projects
Encouragement through incentives can complement stronger
policy requirements
Require New Development
to be “EV-Ready”
Adopt requirements in zoning codes that apply to clean air
vehicles as defined by CalGreen; adopt ordinance that requires
retrofitting
Require EV Charging
Infrastructure to be
Installed at Developments
Adopt requirements in zoning codes; adopt ordinance that
requires retrofitting
Offer Consumer Incentives
to Purchase EVs
✔ Partner with SANDAG and SDAPCD to accelerate and increase the
amount of incentives, reduce barriers to accessing incentives, and
promote aggressively in CoCs
Provide Readily-Accessible
Information to Property
Owners and Vehicle
Owners
✔ Partner with A2Z to reach private entities, local governments,
SDG&E, CCAs, and community groups to understand information
gaps; partner with SANDAG to produce coordinated educational
materials and aggressively promote
Train Workforce to
Support EV Ecosystem
✔ Partner with educational institutions to develop workforce
training needs; increase funding to existing programs. Coordinate
with SANDAG on workforce training on Electric Vehicle
Infrastructure Training Program (EVITP).
Collaborate to Share
Information Across Region
✔ Continue to partner with A2Z Collaborative
Engage in State-level
Advocacy to Bring
Implementation Funds to
San Diego County
✔ Continue to partner with A2Z Collaborative
Oct. 11, 2022 Item #12 Page 126 of 560
88
3.4.2 Accelerate Reduction of VMT
Current San Diego region actions and policies to reduce VMT are articulated in the 2021
Regional Plan across the 5 Big Moves and regional land use development policies. SANDAG is
required to demonstrate how the region will reach targets by reducing VMT. As such, plans for
the 5 Big Moves describe ways to influence behavior change and support denser land uses. To
meet the targets, single occupancy vehicle trips need to be replaced with biking, walking,
transit, and shared rides. The 2021 Regional Plan articulates the following strategies to reduce
VMT:
● Complete Corridors support a greater variety of transportation options, and the initiative
promises investments in infrastructure to make alternative transportation more
attractive. Complete Corridors also explore congestion pricing as a tool for reducing
demand and VMT during peak times.
● Flexible Fleets provide convenient and affordable alternatives to driving alone and help to
reach communities with limited transit access.
● Transit Leap calls for a multimodal high-speed, high-capacity, high-frequency transit
network that appeals to people who otherwise drive alone. In the 5 Big Moves, SANDAG
states that public transit will “continue to be the most efficient way to move many
people,” therefore reducing VMT.
● Mobility Hub areas are communities with a high concentration of people, destinations,
and travel choices. Higher density Mobility Hub areas have a supportive mix of land uses
that can help to encourage ridership and usage of the Transit Leap system. Mobility Hub
areas in less dense areas may rely more on Flexible Fleets in order to connect residents to
transit.
Table 3.7 provides details on VMT-reduction strategies that would support acceleration of VMT
reduction within the San Diego region. The County, cities, and jurisdictions can only influence
the zoning code within their jurisdictional boundaries, however they should all promote
information sharing, evaluation to prove effectiveness of strategies, and inter-jurisdictional
collaboration to encourage denser, more walkable, and more transit-oriented development.
SANDAG and the County can also initiate the exploration of cross-jurisdictional land use policies
such as transfer of development rights to encourage densification in places where multi-modal
investments are already underway, and also serve to preserve undeveloped and agricultural
lands that can serve as carbon sinks.
Oct. 11, 2022 Item #12 Page 127 of 560
89
Table 3.7 VMT reduction policy strategies and County & local jurisdiction implementation approach. The figure
also notes which VMT policy strategies also have electrification opportunities.
Policy Strategy Electrification
Opportunity
County & Local Jurisdiction Implementation
Approach
Expand geographic reach of bus and
rail services in areas where
development can support transit
use
✔ Identify corridors with land use patterns that can
support transit; partner with transit agencies to
fund additional miles of transit service
Invest additional transit service
hours in places where transit is
productive and high occupancy,
focused on infill locations
✔ Identify highest-performing transit corridors;
partner with transit agencies to fund additional
hours of transit service
Provide incentives and regulatory
relief to facilitate higher density
infill and transit-oriented
development
Modify zoning code along transit corridors to allow
denser development; streamline permitting
process for developments along transit corridors;
leverage parking reductions, density bonuses, and
other incentives to encourage development in
transit corridors.
Encourage local agencies to form partnerships with
each other to explore the potential for a legal
mechanism to transfer development rights from
undeveloped or agricultural lands within one
jurisdiction to infill areas in another jurisdiction.
Disincentivize development in rural
(or non-infill) areas that cannot
support efficient transit use or
multi-modal transportation options
Utilize transit opportunity areas, infill areas, and
VMT efficiency metrics to encourage compact
development and discourage exurban and very
rural development
In existing rural, non-infill, or
underserved transit areas, invest in
TNC partnerships to ensure
sufficient access to opportunities
✔ Identify limited-access areas that would benefit
from additional mobility resources; develop TNC
partnerships to support travel using higher-
occupancy vehicles
Incentivize high occupancy personal
vehicle use
Investigate opportunities to implement pricing
structures (cordon pricing, HOT lanes, etc.) that
incentivize high occupancy vehicles
Design walkable communities,
particularly in places where
compact development patterns are
already established
Adopt pedestrian-oriented design guidelines for all
new development; reduce or remove parking
minimums in walkable neighborhoods
Expand pedestrian and bicycle
facilities, using a network approach
to ensure destinations are served,
corridors and intersections are
Update county bicycle and pedestrian planning
documents; partner with SANDAG to accelerate
implementation of 2010 San Diego Regional
Bicycle Plan; develop Pedestrian Safety and/or
Oct. 11, 2022 Item #12 Page 128 of 560
90
equally comfortable and safe Vision Zero and/or Local Road Safety Plan
Expand modal options including a
wide range of e-bikes, e-scooters,
bikeshare, micro transit, shuttles,
and TNC partnerships
✔ Partner with SANDAG to build out network of
Mobility Hub areas where shared vehicles and new
mobility services can be found. Could involve
coordination on e-bike incentive programs and
expansion of the County Pedal Ahead program.
Conduct programs to ensure people
of all abilities and ages are
comfortable using bicycle and
pedestrian facilities
Partner with mobility advocacy organizations to
fund expanded education programming;
implement periodic regular open streets events
throughout the region.
Encourage Transportation Demand
Management (TDM) programs that
incentivize some proportion of
telework, telemedicine, remote
learning and use of transit
Develop County TDM ordinance and
Transportation Management Organization (TMO)
to work with employers and service providers.
Expand broadband in places where
it is weak to allow more employees
to work from home and enable
substitution of other types of trips,
such as medical visits, with virtual
visits
Conduct broadband gap analysis; seek funding to
improve communications infrastructure in areas
that lag; require enhanced communication
technology in all new development through TDM
ordinance. Where relevant, coordinate with
SANDAG to build on the findings of the broadband
gap analysis completed in the Regional Digital
Equity Strategy and Action Plan (2021).
Restructure distribution centers to
enable more efficient delivery
patterns that enable short-haul
electrified freight vehicles and AV
delivery
✔ Conduct electrified freight study to understand
where opportunities for distribution efficiencies
exist; modify zoning code to encourage smaller
distribution centers in centralized locations close
to population centers. This could involve
coordination with SANDAG and the Port on
Regional MD/HD EV Blueprint development for
goods movement and transit, SANDAG’s
Sustainable Freight Implementation Strategy with
Imperial County, and the Port’s Maritime Clean Air
Strategy.
Address emissions from school-
related trips
✔ Coordinate with programs such as the California
Energy Commission’s School Bus Replacement
Program to replace diesel school buses in priority
communities with zero-emission vehicles.
Oct. 11, 2022 Item #12 Page 129 of 560
91
3.4.2.1 Geographic Opportunity Areas for VMT Reduction
The above strategies are likely to be successful in different locations across the region. Transit-
oriented strategies will be most successful in places where the density of population and
development can support efficient transit vehicle use, or in “infill” locations where walking and
biking strategies will likely be more effective. In non-infill locations, strategies related to trip
reduction through TDM, partnerships with TNCs or County taxis that prioritize electrification
and high-occupancy ridership, and enhancing broadband service may be more successful
strategies to reduce VMT.
Figure 3.4 shows the SANDAG Mobility Hub areas overlaid on the transportation analysis zones
(TAZ) in the San Diego region that meet the following definition of infill:
● Household density above 385 housing units/square mile (selected based on the U.S.
Census definition for urban area);
● Intersection density above 128 intersections/square mile (matches Frost (2018) average
value for ‘Urban Places’);10 and
● A Job Accessibility value of 12.73 (average value for local employment accessibility in
Salon (2014)).11
Over time, additional areas may become well-suited for infill-oriented VMT reduction strategies
as they meet higher population density thresholds. Figures 3.5 and 3.6 show that population
density is anticipated to change from 2012 (Fig. 3.5) to 2035 (Fig. 3.6), creating more
opportunity for future expansion of infill-oriented and transit-oriented strategies.
Oct. 11, 2022 Item #12 Page 130 of 560
92
Figure 3.4 Transportation analysis zones (TAZs) which meet the definition as an infill area (dark blue) and SANDAG Mobility Hub areas (light purple). Source:
SANDAG Series 13 Base Year Model (2012). Created by Fehr & Peers, 2022. Oct. 11, 2022Item #12 Page 131 of 560
93
Figure 3.5 2012 population density (population per square mile) by TAZ. Darker colors represent denser areas. Source: SANDAG Series 13 Base Year Model
(2012). Created by Fehr & Peers, 2022. Oct. 11, 2022Item #12 Page 132 of 560
94
Figure 3.6 2035 Population Density (population per square mile) by TAZ. Darker colors represent denser areas. Source: SANDAG Series 13 Base Year Model
(2035). Created by Fehr & Peers, 2022.Oct. 11, 2022Item #12 Page 133 of 560
95
3.5 Key Actions
This chapter summarizes opportunities to accelerate EV adoption and VMT reduction based on
existing countywide policies and patterns of vehicle ownership, travel behavior, and land use
development in order to address the relevant gaps in EV purchase, EV charging infrastructure,
and VMT reduction that create challenges in reaching deep regional decarbonization.
Recommended areas for accelerated action will help the region meet more aggressive
decarbonization targets that have been established for California but are not yet satisfied by
the guiding policies in the region.
Key actions that will accelerate decarbonization of the transportation sector are largely
grouped into two categories: decarbonization of vehicles and reduction of VMT. In order to
make progress towards deep decarbonization goals, the key actions that the region and local
agencies can pursue over the next 10 years will require a mix of both strategies. Moving
forward, it will be critical to share information and successful implementation strategies across
jurisdictions, and advocate for funding and coordination at the state level.
Neither vehicle decarbonization nor any VMT reduction strategy are a silver bullet. To meet
local and state transportation decarbonization targets, the County and local jurisdictions will
need to pair vehicle decarbonization strategies with land use changes that reduce trip distance
and car dependence. Strategies that simply focus on the shift to EV will not lower VMT, and
some VMT reduction strategies may limit movement. Therefore, decision-makers must decide
how to best phase in EV without encouraging additional driving, and how to best lower VMT
without limiting access to destinations and opportunities.
The details provided in Table 3.8 (vehicle electrification policies) and Table 3.9 (VMT reduction
policies) are intended to allow local jurisdictions to make effective comparisons between
decarbonization investments, and thus enable policy prioritization. This comparison includes
information on decarbonization potential, feasibility, co-benefits, trade-offs, and equity
considerations for each policy. It identifies which actions are the highest priority to initiate,
which geographic areas need more focus, where local jurisdictions have control, and where
actions could benefit from regional coordination and collaboration. To further aid decision-
making, Table 3.8 includes information about cost efficiency of electrification actions, and Table
3.9 includes quantifiable VMT reduction potential.
VMT reduction potential data has been adapted from the Handbook for Analyzing Greenhouse
Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity, a
document assembled by the California Air Pollution Control Officers Association, Caltrans, and
the Sacramento Metropolitan Air Quality Management District.12 The Handbook includes a
range of measures that are frequently used to promote transit and alternative transportation,
Oct. 11, 2022 Item #12 Page 134 of 560
96
support use of alternatively fueled vehicles, or encourage land use planning practices that
reduce vehicle trips and VMT. It is worth noting that when considering which measures are
applicable for a jurisdiction or implementation area, the locational context should be
incorporated into the decision-making process. Many VMT reduction strategies are best suited
for denser landscapes, and the quantification methods and assumptions used in the handbook
to determine strategy effectiveness may not be representative when applied to all geographies.
Further, the effects of combining measure reductions are not always linear or complementary.
Decision-makers should be mindful of potential interactions among different measures, and
should take care to avoid overestimating the VMT reduction potential of multiple strategies
that target the same type of trip or the same population. Additionally, many of the strategies
(for example, land use related strategies) are already accounted for in the SANDAG regional
travel demand model, so additional reductions to VMT produced by the model are not
appropriate.
Finally, Table 3.10 outlines possible next steps that jurisdictions can take toward reducing VMT
and accelerating adoption of ZEVs based on local context. These next steps build on the
actionable items listed in Table 3.8 and 3.9, while additionally considering the relevant goals,
targets, and actions of each jurisdiction from Table 3.2 as well as the current EV uptake from
Table 3.4. At a minimum, all local jurisdictions should review and evaluate their own progress
on the following planning efforts and subsequently update existing efforts or initiate new
efforts where needed. Examples may include updating or initiating the following:
● General Plan that prioritizes compact, mixed-use development around transit corridors,
affordable housing, and transportation investments that support transit service;
● Bicycle and pedestrian plans that set active transportation modeshare goals, create a
network of high-quality, safe facilities that offer access to destinations on par with
vehicle access, in addition to standards and guidelines that embed a Complete Streets
and Safe System approach into all roadway investments;
● Climate Action Plans that set municipal fleet electrification or decarbonization targets
and public EV charger targets, establish incentives for retrofitting existing development
with EV charging, and create climate adaptation strategies that hedge against climate
risks that could make it difficult to achieve active transportation modeshare goals;
● Safe Routes to School Plans that identify opportunities to enable walking, biking, and
bussing to school; or
● Municipal codes that include design guidelines to encourage pedestrian and bicycle
connectivity, to establish transportation demand management ordinances that require
employers to address commute trips and offer alternatives to single-occupancy vehicle
travel, and, where appropriate, to channel transportation impact mitigation fee funds
from development into VMT-reducing actions.
Oct. 11, 2022 Item #12 Page 135 of 560
97
Table 3.8 Key electrification actions and selected opportunities, co-benefits, consideration, trade-offs, context, and effectiveness.
Action Opportunities and Co-Benefits Considerations and Trade-offs Context [a] Strategy
Effectiveness [b]
Strategies to Accelerate EV Infrastructure Buildout
Set and meet aggressive
public EV charging target.
Funding opportunities are available at
multiple geographic scales.
Building out an effective network of EV
charging infrastructure will have
significant impacts on the transmission
grid and its reliability, and deployment
costs (including upfront unit cost,
installation, operations, maintenance,
etc.) may be prohibitive. Additionally,
reliable charging in rural areas may be
complicated by unexpected power
outages.
Roll-out in densely
developed areas may
require fewer
infrastructure- and
utilities-related costs.
Public chargers will not
directly influence uptake,
but a built-out EV charging
network is critical for EV
uptake.
Require new
development to include
EV charging and require
existing development to
retrofit parking with EV
charging.
Beginning January 1, 2023, the CALGreen
building code will require EV charging spaces
and chargers for new multifamily residential
development and hotels/motels.
Requirements for new development present
the opportunity to coordinate with SDG&E
to optimize efforts in unincorporated areas.
Additional requirements for new
construction without incentives may
dampen development. Retrofits may be
cost-prohibitive for some.
Can be an effective
strategy in urban and
rural contexts.
Amendments to building
codes will require a longer
lead time, and will have an
indirect influence on EV
uptake. Retrofit
requirements may be more
costly but more immediate.
Increase dollar value of
incentives, provide
educational resources,
and streamline
permitting process for
landowners to install EV
charging in multi-family
developments.
SANDAG and the San Diego County Air
Pollution Control District have already
partnered with the California Electric Vehicle
Infrastructure Project on the San Diego
County Incentive Project.
Installation will require technical
assistance services for electricians as well
as local governments. Available funding is
limited.
Can be an effective
strategy in urban and
rural contexts, especially
in areas of high
development.
Residential charging
infrastructure is critical for
electrification but only
indirectly influences uptake. Oct. 11, 2022Item #12 Page 136 of 560
98
Action Opportunities and Co-Benefits Considerations and Trade-offs Context [a] Strategy
Effectiveness [b]
Partner with educational
institutions to develop
programs to meet
workforce development
needs; increase funding
to existing programs;
require certification to
install and maintain EV
infrastructure.
Infrastructure construction can employ
California Certified Electricians with EVITP
Certification. This work can support new
green jobs creation, union job creation, and
jobs for and in marginalized communities.
Governments can facilitate partnerships
with industry and trade groups as well as
existing apprenticeship programs.
Electrification will necessitate a shift from
carbon-based jobs, potentially risking
temporary job displacement.
Can be an effective
strategy in urban and
rural contexts, with
potential for greater
opportunity near city
centers where workforce
may be located and
educational institutions
are present.
Does not directly influence
EV uptake but building out
the charging network relies
on a large and skilled
workforce.
Explore measures that
would allow private
parking lot owners to
build solar arrays and sell
electricity to EV owners
who use their lots.
Would not require new utility-owned
infrastructure and would reduce the need
for new infrastructure to support existing
and future building loads. Would not impose
a cost to ratepayers.
A predominantly solar renewable
strategy is not consistent with nighttime
EV charging, as it would require daytime
storage of solar-generated electricity at
the utility level, and nighttime release
from utility storage to EV batteries. If
large scale solar EV charging takes place
at a work destination, it may not be
feasible for employers to subsidize
employee charging.
Would be most effective
in densely populated
areas with a high number
of commercial and office
destinations with parking
lots.
Will not increase EV uptake
but can increase charging
supply. May be costly but
can help build long-term
energy resilience.
Construct commercial EV
charging hubs with
special rate sharing
agreements for small
fleets and small
businesses.
SDG&E’s ongoing “Power Your Drive”
program has a goal of installing charging
infrastructure to support approximately
3,000 medium- and heavy-duty EVs.
Installation will require technical
assistance services for electricians as well
as local governments. Available funding is
limited.
Would be most effective
in densely populated
areas with a high number
of commercial and/or
industrial destinations.
Commercial charging
infrastructure is critical for
electrification but only
indirectly influences uptake.
Oct. 11, 2022Item #12 Page 137 of 560
99
Action Opportunities and Co-Benefits Considerations and Trade-offs Context [a] Strategy
Effectiveness [b]
Strategies to Accelerate EV Uptake
Increase dollar value and
streamline consumer
vehicle purchase
incentives with
application to both new
and used vehicles, and
increase dollar value and
opportunities to retire
gas vehicles.
The San Diego County Air Pollution Control
District’s Clean Cars 4 All and Goods
Movement Emission Reduction Program
supports the acceleration of EV. 28% of the
California Energy Commission’s Clean
Transportation Program Funding is
dedicated to projects located in
disadvantaged and/or low-income
communities. Further incentives may reduce
barriers to access for priority communities.
Application processes could be
streamlined. Coordination on eligibility
requirements needs to be considered.
Funding should be identified to offset
potential losses from lowered gas tax
revenues.
Can be an effective
strategy in urban and
rural contexts, and
especially in
disadvantaged or low-
income communities.
Will directly accelerate EV
uptake.
Diversify types of small
EVs and ZEVs that are
eligible for consumer
purchase incentives.
Encouraging accelerated uptake of small
EVs, such as scooters, e-bikes, and
neighborhood electric vehicles (NEVs) as
well as other types of ZEVs, such as
hydrogen fuel cell vehicles, can better meet
diverse and specific travel needs. Emerging
EVs still require consumption of more
electricity than may be necessary to
complete a given trip. Replacement of
vehicle trips with small EVs can also help
achieve safety benefits for pedestrians and
bicyclists and encourage more compact,
walkable development patterns.
Requires additional funding streams. In
some cases, NEVs may not be allowed on
the local street network without enabling
legislation, ordinances, or adopted NEV
Plans.
Can be effective in urban
and rural contexts,
especially in
disadvantaged or low-
income communities
where a lower purchase
price is more attainable
and the rate of household
vehicle ownership is low.
Will directly accelerate EV
and ZEV uptake, particularly
for smaller vehicles.
Set and meet aggressive
(100%) fleet adoption
target.
EVs have the potential to improve fleet
efficiency and reduce vehicle operation and
maintenance costs. Explore cost-saving
opportunities by joining the Climate Mayor’s
Network EV purchasing collaborative.
Prioritizing implementation of new ZEV
school bus fleets can have VMT reduction
benefits as well as electrification benefits.
EVs still have well-to-wheel emissions.
Consideration must be given to the gas
and diesel vehicles that are discarded
when fleet upgrades are made. Programs
by pollution control districts and others
can help bear the financial and carbon
cost of retiring them.
Can be an effective
strategy in urban and
rural contexts.
Will directly accelerate EV
uptake. Oct. 11, 2022Item #12 Page 138 of 560
100
Action Opportunities and Co-Benefits Considerations and Trade-offs Context [a] Strategy
Effectiveness [b]
Convert all-access
freeway or highway lanes
to HOV or HOT lanes that
permit electric, zero-
emission, and hybrid
vehicles.
HOV/HOT lane conversion can be completed
in support of SANDAG’s Complete Corridors
strategy.
HOV/HOT lane conversion may induce
driving and increase VMT over time by
adding capacity to the roadway system.
This can, to some extent, be mitigated if
HOV lanes require 3+ occupants and HOT
lanes price usage to reflect the true cost
of emissions as well as the time travel
benefits.
Would be applied to
highways and/or
freeways.
Does not directly influence
EV/ZEV uptake, but may
encourage a quicker
transition if EVs/ZEVs are
offered discounted access
into HOT lanes or a lower
occupancy threshold for
HOV lanes.
Note:
[a] Context in which the strategy or action will be the most impactful.
[b] High-level assessment of how directly and how effectively this strategy will influence EV acceleration/uptake. Oct. 11, 2022Item #12 Page 139 of 560
101
Table 3.9 Key VMT actions and selected opportunities, co-benefits, consideration, trade-offs, context, and VMT/GHG reduction potential.
Action Opportunities and Co-Benefits Considerations and Trade-offs Context [a]
VMT & GHG
Reduction Potential [b]
Provide incentives and
regulatory relief to
facilitate higher density
infill and transit-
oriented development.
Areas that can support efficient transit
use or multi-modal transportation
options can prevent development into
natural lands. Land use policies can
facilitate the opportunity for affordable
housing opportunities and assist in
meeting the housing crisis. Opportunity
for community benefits agreements to
create opportunities for local workers
and develop amenities tailored to the
area.
Incentivizing infill and considering a regional
VMT methodology may curtail development
opportunities in more rural communities.
Therefore, in existing rural, non-infill, or
underserved transit areas, the County
should invest in TNC partnerships prioritizing
electric and high-occupancy vehicles to
ensure sufficient and continued access to
opportunities while reducing reliance on
single-occupancy, combustion-engine
vehicle trips.
Most effective in
densely developed
contexts.
Up to 31% of GHG emissions
from project-scale VMT in
urbanized areas.
Disincentivize
development in rural (or
non-infill) areas that
cannot support efficient
transit use or multi-
modal transportation
options.
Potential for electrification and high-
occupancy vehicles to be prioritized.
Prevents opportunity and necessary
infrastructure for the entirety of San Diego
County to shift to sustainable means.
N/A Captured in the estimate
above.
Partner with SANDAG to
build out a network of
Mobility Hub areas
where shared vehicles
and new mobility
services can be found.
Curtail urban sprawl, create
opportunities for affordable housing near
transit, and provide transportation
options for zero vehicle households.
Mobility Hub areas tend to concentrate
transit and mobility investments in areas
that are already transit-supporting.
Only effective in densely
developed contexts.
Up to 31% of GHG emissions
from project-level VMT in
urbanized areas.
Increase street
connectivity, update
county bicycle and
pedestrian planning
documents, and adopt
pedestrian- and bicycle-
oriented design
guidelines for all new
development.
Bikeable, walkable neighborhoods near
transit, jobs and amenities promote
healthier lifestyles and social outcomes,
in addition to reducing emissions and
providing cleaner air, especially in
frontline, working-class communities of
color. Improvements to pedestrian and
bicycle infrastructure can also improve
roadway safety and reduce injuries and
fatalities related to collisions.
May involve major expenses if building a
new street network or retrofitting an
existing street network to improve
connectivity is required.
Most effective in urban
or suburban contexts.
Up to 30% of GHG emissions
from vehicle travel in the
community, depending on the
extent of build-out. Oct. 11, 2022Item #12 Page 140 of 560
102
Action Opportunities and Co-Benefits Considerations and Trade-offs Context [a]
VMT & GHG
Reduction Potential [b]
Reduce or remove
parking minimums in
walkable neighborhoods
Parking lots can be converted into land
uses more urgently needed by a
community, potentially bringing higher
tax revenues.
Reducing parking supply without providing
alternative transportation modes will limit
mobility/access, and may harm local
businesses.
Only effective in densely
developed contexts.
Up to 13.7% of GHG emissions
from resident vehicles
accessing the site.
Expand BRT in transit-
supporting
communities.
Rail may not be presently feasible for
some geographies. In those cases, BRT
may be considered as a stepping stone to
rail investments in the future.
BRT has a higher operator to passenger ratio
than rail and would rely on costly battery
electric buses.
Most effective in
densely developed
contexts.
Up to 11.3% of GHG emission
from vehicle travel in the
plan/ community.
Expand geographic
reach and service hours
of bus and rail services
in areas where
development can
support transit use.
Significant public health benefits in
transit-focused pathways. Collaborate
with MTS and NCTD to develop pathways
for complete streets policies, smart
growth incentives, and optimize transit
options to create inclusive bikeable and
walkable neighborhoods. Emphasizing
public transit may result in less upkeep of
roads and less demand for parking in
urban areas.
By prioritizing transit development and
improvements only in areas that can already
support transit use, unincorporated regions,
tribal communities, and less dense areas are
not given the opportunity for transit-
oriented development.
Most effective in
densely developed
contexts.
Up to 4.6% of GHG emissions
from vehicle travel in the
plan/ community.
Partner with school
districts to expand
bussing using an electric
or zero-emissions fleet,
and to implement
robust Safe Routes to
School programs for
students who live within
walking/biking distance.
This would also confer public health and
safety benefits by improving pedestrian
and bicycle safety of school-aged
children, and by reducing air pollution
near schools. CARB has piloted a Clean
Mobility in Schools program, funded by
California Cap & Trade dollars, to explore
ways to accelerate implementation of
these ideas.
The San Diego region has many school
districts, most of which do not have
dedicated staff tasked with addressing
school transportation emissions or
transportation safety. Additional staff
support and funding from regional and
municipal entities would likely be required
to implement this idea.
Safe Routes to School
programs are most
effective in urban and
suburban environments.
Bussing programs may
be effective in any
context.
Substantial variation exists in
school trips (as a share of all
trips, in trip length, and in
mode share). Some highly
successful bus programs have
been shown to reduce up to
63% of school-related VMT.
Investigate
opportunities to
implement pricing
structures (cordon
pricing, HOT lanes, road
use charge, etc.) that
incentivize high
occupancy vehicles.
Can help reduce the number of single
occupancy vehicles on the road and
alleviate traffic congestion by
encouraging active transportation
modes.
Historic lack of support from the San Diego
region. Must be designed in a way that does
not further transportation inequities—
should provide a discount, rebate, or
exception for low-income residents or
workers within the pricing zone.
Can be applied in urban
and rural contexts, but
most effective in high-
use corridors.
More research is needed;
substantial variation exists for
this strategy dependent on
context. Oct. 11, 2022Item #12 Page 141 of 560
103
Action Opportunities and Co-Benefits Considerations and Trade-offs Context [a]
VMT & GHG
Reduction Potential [b]
Implement on-street
market price public
parking.
Reduces illegal loading/standing in bus
stops and travel lanes, improving transit
times. Incentivizes shifts away from
single-occupancy vehicle modes by
increasing the total cost of driving to a
location.
Potential parking intrusion on nearby streets
without priced parking. Requires staffing
costs to monitor/enforce metered spaces.
Most effective in urban
contexts where
alternatives to driving
exist.
Up to 30% of GHG emissions
form vehicle travel in the
plan/community.
Consider the potential
of TNCs and taxis (as a
publicly regulated
alternative to TNCs),
integrated into the
transit system for the
Flexible Fleet strategy’s
offering of rideshare.
May be easier to incorporate taxis into
the NextOS and Flexible Fleets initiatives
because SANDAG would be able to access
taxi planning data and ensure systems
are designed to encourage safe driving.
San Diego County taxis are regulated
locally through MTS, creating an
opportunity to employ local regulations
and promotions to hasten electrification
of the fleet. Further, taxis are regulated
under the ADA and typically have fewer
deadheading miles than TNCs.
TNCs and taxis have the potential to increase
VMT for short trips that could have been
replaced by lower carbon initiatives such as
transit or walking. This strategy would be
most effective in reducing VMT if it
emphasized multiple occupancy trips, rather
than single occupancy.
TNCs and taxis would be
most beneficial as a
first-last mile
partnership with a
municipality or transit
agency in a densely
developed area.
More research is needed to
quantify the VMT reduction
potential of taxis and TNCs;
existing research shows
varying patterns depending
on context.
Encourage smart growth
and discourage new car-
dependent development
through transfer of
development rights.
Allows higher-density, lower-VMT
“receiving areas” to purchase additional
development rights from designated
“sending areas”. Land owners in
designated “sending areas” agree to
preserve the lands from which the
development rights were sold and keep
them as natural or agricultural lands that
sequester carbon.
Requires formal, legally-binding agreements
between “receiving areas” and “sending
areas” which are likely to be different
jurisdictions with different General Plans,
zoning codes, and appetites for denser
development.
Effective at a regional,
interjurisdictional scale
that include both
“receiving areas” that
can achieve VMT
reductions through
increased development,
and “sending areas”
with opportunities to
keep undeveloped land
as carbon sinks.
More research needed to
quantify the VMT reduction
potential, and associated GHG
reduction potential from
lands that remain as
undeveloped carbon sinks.
Likely to vary greatly
depending on the extent to
which such a regional
program is adopted and
implemented.
Note:
[a] Context in which the strategy or action will be the most impactful.
[b] Information on VMT reduction potential sourced from the California Air Pollution Control Officers Association Handbook for Analyzing Greenhouse Gas Emission
Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity, 2021
Oct. 11, 2022Item #12 Page 142 of 560
104
Table 3.10 Key Policy Actions by Jurisdiction/Agency
Jurisdiction/
Agency EV/ZEV Next Steps VMT Reduction Next Steps
SANDAG ● Continue to expand and increase the available incentives for EV and ZEV
purchase, including for small EVs such as e-bikes, scooters, and NEVs.
● Provide technical assistance to jurisdictions who want to develop an NEV
Plan to enable use of NEVs on the roadway network.
● Expand A2Z Collaborative to partner with private entities (such as vehicle
manufacturers and land use developers) to accelerate EV and ZEV
adoption and develop educational/marketing materials for EV/ZEV
transition.
● Explore programs that would enable transfer of development rights across
jurisdictions.
● Explore a VMT mitigation bank/exchange program to unlock developer
investment in VMT-reducing actions.
● Conduct a regional travel pricing study to understand the opportunities to
re-balance incentives via road pricing, parking pricing, and transit pricing.
MTS ● Look for opportunities to accelerate the transition of the bus fleet to fully
electric before 2040.
● Develop a plan to implement EV charging at all MTS parking lots.
● Expand and streamline incentive programs (such as the Youth Opportunity
Pilot) to reduce the cost of transit for those who are most likely to utilize
transit, such as university students.
● Work with local jurisdictions to implement aggressive transit-oriented
zoning within the ½-mile surrounding every trolley stop to maximize the
impact of transit investments through high-density mixed-use
development.
Unincorporated
San Diego County
● Build on the San Diego County Incentive Project. Increase dollar value of
incentives to buy EV/ZEV and retire gas vehicles.
● Streamline consumer vehicle purchase incentives for both new and used
vehicles and provide educational resources to increase EV/ZEV uptake.
● Provide technical assistance services for electricians and local
governments.
● Set aggressive municipal fleet adoption and public EV charging targets and
track uptake over time.
● Partner with SANDAG to build out Mobility Hub areas.
● Disincentivize development in non-infill areas that cannot support efficient
transit use or multi-modal transportation options.
● Provide incentives and regulatory relief to facilitate higher density infill,
and investigate opportunities to implement pricing structures that
incentivize high occupancy vehicles.
Carlsbad ● Set aggressive municipal fleet adoption and public EV charging targets and
track uptake over time.
● Work with other jurisdictions and agencies to identify procurement
options to ensure progress of fleet adoption goals (such as the Climate
Mayors network and EV purchasing collaborative).
● Expand 2011 CAP goals to accelerate the increase of ZEV miles.
● Adopt pedestrian- and bicycle-oriented design guidelines for all new
development.
● Remove parking minimums in walkable neighborhoods.
● Provide incentives and regulatory relief to facilitate higher density infill and
transit-oriented development.
● Implement transit-oriented zoning within ½-mile of all rail stations to
maximize the impact of transit investments through high-density mixed-
use development
Chula Vista ● Streamline the permitting process for landowners to install EV charging in
multifamily developments.
● Partner with educational institutions to develop programs to meet
workforce development needs.
● Expand on CAP goal of 40% alternatively-fueled municipal fleet vehicles by
2020, setting a new goal for a later horizon year and building upon the
success of recent EV acquisitions.
● Partner with SANDAG to build out Mobility Hub areas.
● Reduce or remove parking minimums in walkable neighborhoods.
● Provide incentives and regulatory relief to facilitate higher density infill and
transit-oriented development.
● Implement transit-oriented zoning within ½-mile of all trolley stations to
maximize the impact of transit investments through high-density mixed-
use development Oct. 11, 2022Item #12 Page 143 of 560
105
Jurisdiction/
Agency EV/ZEV Next Steps VMT Reduction Next Steps
Coronado ● Set aggressive public EV charging targets and track uptake over time.
● Monitor and report on municipal fleet transition to EV/ZEV; set updated
targets that follow the recommendations of the City of Coronado Energy
Roadmap (2012) establishing more ambitious fleet adoption goals.
● Adopt pedestrian- and bicycle-oriented design guidelines for all new
development/redevelopment.
● Provide incentives and regulatory relief to facilitate higher density infill and
transit-oriented development.
Del Mar ● Require new development to include EV charging and require existing
development to retrofit parking with EV charging.
● Increase funding to existing programs to meet workforce development
needs.
● Building on the CAP’s commitment to explore the potential for electrifying
the municipal fleet, set an ambitious adoption goal.
● Increase street connectivity, update local bicycle and pedestrian planning
documents, and adopt pedestrian- and bicycle-oriented design guidelines
for all new development.
El Cajon ● Secure state and regional incentives to increase the dollar value of
incentives for consumers to install EV chargers and purchase new or used
EV.
● Develop an incentive program to retire gas vehicles.
● Partner with educational institutions to develop programs to meet
workforce development needs.
● Follow the recommendations of the City of El Cajon Energy Roadmap
(2013) and the city’s Sustainability Initiative (2020) and establish
ambitious fleet adoption goals.
● Increase street connectivity, update local bicycle and pedestrian planning
documents, and adopt pedestrian- and bicycle-oriented design guidelines
for all new development.
● Implement transit-oriented zoning within ½-mile of all trolley stations to
maximize the impact of transit investments through high-density mixed-
use development
Encinitas ● Set aggressive fleet adoption and public EV charging targets and track
uptake over time.
● Continue to make progress on transitioning all portions of the City’s
municipal fleet.
● Identify funding to support City fleet conversion.
● Adopt pedestrian- and bicycle-oriented design guidelines for all new
development.
● Provide incentives and regulatory relief to facilitate higher density infill and
transit-oriented development.
● Implement transit-oriented zoning within ½-mile of rail station to maximize
the impact of transit investments through high-density mixed-use
development
Escondido ● Secure state and regional incentives to increase the dollar value of
incentives for consumers to install EV chargers and purchase new or used
EV.
● Develop an incentive program to retire gas vehicles.
● Partner with educational institutions to develop programs to meet
workforce development needs.
● Work with other jurisdictions and agencies to identify procurement
options to transition the municipal fleet.
● Work with NCTD to expand BRT by dedicating roadway to bus only lanes in
areas where development can support transit use.
● Implement transit-oriented zoning within ½-mile of all rail stations to
maximize the impact of transit investments through high-density mixed-
use development Oct. 11, 2022Item #12 Page 144 of 560
106
Jurisdiction/
Agency EV/ZEV Next Steps VMT Reduction Next Steps
Imperial Beach ● Require new development to include EV charging and existing
development to retrofit parking with EV charging.
● Secure state and regional incentives to increase the dollar value of
incentives for consumers to install EV chargers and purchase new or used
EV.
● Develop an incentive program to retire gas vehicles.
● Partner with educational institutions to develop programs to meet
workforce development needs.
● Utilize fleet assessment and conversion plans to decide when to replace
vehicles.
● Work with other jurisdictions and agencies to identify procurement
options to transition the municipal fleet.
● Work with MTS to expand BRT by dedicating roadway to bus only lanes in
areas where development can support transit use.
La Mesa ● Require new development to include EV charging and existing development to retrofit parking with EV charging. ● Secure state and regional incentives to increase the dollar value of incentives for consumers to install EV chargers and purchase new or used
EV. ● Develop an incentive program to retire gas vehicles. ● Partner with educational institutions to develop programs to meet
workforce development needs. ● Work with other jurisdictions and agencies to identify procurement
options to transition the municipal fleet.
● Work with MTS to expand BRT by dedicating roadway to bus only lanes in areas where development can support transit use. ● Implement transit-oriented zoning within ½-mile of all trolley stations to maximize the impact of transit investments through high-density mixed-
use development
Lemon Grove ● Partner with educational institutions to help develop programs to meet
workforce development needs and increase funding to existing programs.
● Secure state and regional incentives to increase the dollar value of
incentives for consumers to install EV chargers and purchase new or used
EV.
● Follow the goals of the 2020 CAP and the recommendations of the City of
Lemon Grove Energy Roadmap (2014) and establish ambitious municipal
fleet adoption goals.
● Partner with SANDAG to build out Mobility Hub areas.
● Implement transit-oriented zoning within ½-mile of all trolley stations to
maximize the impact of transit investments through high-density mixed-
use development
● Work with MTS to expand BRT by dedicating roadway to bus only lanes in
areas where development can support transit use.
National City ● Secure state and regional incentives to increase the dollar value of
incentives for consumers to install EV chargers and purchase new or used
EV.
● Develop an incentive program to retire gas vehicles.
● Partner with educational institutions to develop programs to meet workforce development needs.
● Set a municipal fleet adoption goal and work with other jurisdictions and
agencies to identify procurement options.
● Partner with SANDAG to build out Mobility Hub areas.
● Implement transit-oriented zoning within ½-mile of all trolley stations to
maximize the impact of transit investments through high-density mixed-
use development
● Work with MTS to expand BRT by dedicating roadway to bus only lanes in areas where development can support transit use. Oct. 11, 2022Item #12 Page 145 of 560
107
Jurisdiction/
Agency EV/ZEV Next Steps VMT Reduction Next Steps
Oceanside ● Secure state and regional incentives to increase the dollar value of
incentives for consumers to install EV chargers and purchase new or used
EV.
● Develop an incentive program to retire gas vehicles.
● Partner with educational institutions to develop programs to meet
workforce development needs.
● Follow the City’s Energy Climate Action Element (2019) to establish
ambitious municipal fleet adoption goals.
● Partner with SANDAG to build out Mobility Hub areas.
● Work with NCTD to expand BRT by dedicating roadway to bus only lanes in
areas where development can support transit use.
● Implement transit-oriented zoning within ½-mile of all rail stations to
maximize the impact of transit investments through high-density mixed-
use development
Poway ● Require new development to include EV charging and require existing
development to retrofit parking with EV charging.
● Increase funding to existing programs to meet workforce development
needs.
● Follow the recommendations of the City of Poway Energy Roadmap (2015) and establish ambitious municipal fleet adoption goals.
● Adopt a CAP that includes ZEV/EV acceleration strategies.
● Disincentivize development in areas that cannot support efficient transit
use or multi-modal transportation options.
● Increase street connectivity and update bicycle and pedestrian planning
documents.
● Adopt a CAP that includes VMT reduction strategies.
San Diego ● Set aggressive public EV charging targets and track uptake over time.
● Increase funding to existing programs to meet workforce development
needs.
● Work with other jurisdictions and agencies to identify procurement
options to transition the municipal fleet.
● Work with MTS to expand BRT by dedicating roadway to bus only lanes in
areas where development can support transit use.
● Implement transit-oriented zoning within ½-mile of all trolley stations to
maximize the impact of transit investments through high-density mixed-
use development
● Reduce or remove parking minimums in walkable neighborhoods.
San Marcos ● Set aggressive public EV charging targets and track progress toward goal.
● Increase funding to existing programs to meet workforce development
needs.
● Build on the City of San Marcos Energy Roadmap (2011) and the 2020 CAP
to develop a low- and zero-emissions replacement/purchasing policy for
official City vehicles and equipment.
● Identify and secure funding to purchase low- and ZEV fleet vehicles and
equipment
● Work with NCTD to expand BRT by dedicating roadway to bus only lanes in
areas where development can support transit use.
● Disincentivize development in non-infill areas that cannot support efficient
transit use or multi-modal transportation options.
● Provide incentives and regulatory relief to facilitate higher density infill and
transit-oriented development.
● Implement transit-oriented zoning within ½-mile of all rail stations to
maximize the impact of transit investments through high-density mixed-
use development Oct. 11, 2022Item #12 Page 146 of 560
108
Jurisdiction/
Agency EV/ZEV Next Steps VMT Reduction Next Steps
Santee ● Increase dollar value of local incentives and streamline the permitting
process for landowners to install EV charging in multifamily
developments.
● Partner with educational institutions to develop programs to meet
workforce development needs.
● Increase dollar value and streamline the consumer vehicle purchase
incentives at the local level.
● Build on the City of Santee Energy Roadmap (2011) and the Sustainable
Santee Plan (2019) and establish a municipal fleet replacement goal with a
percentage or number of vehicles.
● Update bicycle and pedestrian planning documents and adopt pedestrian-
and bicycle-oriented design guidelines for all new development.
● Consider the potential of TNCs and taxis integrated into the transit system
for rideshare.
● Implement transit-oriented zoning within ½-mile of trolley station to
maximize the impact of transit investments through high-density mixed-
use development
Solana Beach ● In the 2022 CAP update, set aggressive municipal fleet adoption and
public EV charging targets and track uptake over time.
● Adopt a clean vehicle purchasing policy for new fleet vehicles.
● Partner with SANDAG to build out Mobility Hub areas.
● Work with NCTD to expand BRT by dedicating roadway to bus only lanes in
areas where development can support transit use.
● Implement transit-oriented zoning within ½-mile of rail station to maximize
the impact of transit investments through high-density mixed-use
development
Vista ● Secure state and regional incentives to increase the dollar value of
incentives for consumers to install EV chargers and purchase new or used
EV.
● Develop an incentive program to retire gas vehicles.
● Partner with educational institutions to develop programs to meet
workforce development needs.
● Work with other jurisdictions and agencies to identify procurement
options to transition the municipal fleet.
● Increase street connectivity, particularly for people on foot and on bike.
● Work with NCTD to expand BRT by dedicating roadway to bus only lanes in
areas where development can support transit use.
● Implement transit-oriented zoning within ½-mile of all rail stations to
maximize the impact of transit investments through high-density mixed-
use development
Oct. 11, 2022Item #12 Page 147 of 560
109
3.6 Remaining Challenges and Gaps
Additional challenges and major gaps remain which will require collaboration, coordination,
and advances to vehicle technology beyond what exists on the road today. In addition,
outstanding questions regarding environmental externalities are important to consider as the
County accelerates electrification as a key pathway to decarbonize the transportation sector.
3.6.1 Cross-Border Transportation and Tribal Jurisdictions
The San Diego region’s location adjacent to the US-Mexico border creates opportunities and
challenges for regional decarbonization. While Mexican border cities, such as Tijuana, are
distinct political entities, transportation behavior on and around border crossings contributes
to shared effects of carbon emissions. A major challenge of addressing these emissions is that
there is limited jurisdictional control for directly influencing border crossings, as this authority
lies with federal government bodies. Since cross-border traffic is a critical piece of regional
decarbonization, though, it is important for local jurisdictions to coordinate with federal
decision-makers on emissions-reducing regulations wherever possible. Similarly, local and
state governments do not have authority over the 17 tribal governments in the San Diego
region, yet reducing transportation emissions related to tribal jurisdictions are important for
regional decarbonization.
In an effort to coordinate regional planning, SANDAG created the Borders Committee, which
provides oversight for planning activities that impact the borders of the San Diego region as
well as government-to-government relations with tribal nations in the San Diego region.
Membership includes representatives from Mexico, the County of San Diego, Orange County,
Imperial County, Caltrans District 11, Southern California Association of Governments (SCAG),
Southern California Tribal Chairmen’s Association, and several cities. The Borders Committee
advises the SANDAG Board of Directors on major interregional planning policy-level matters,
which are then forwarded to the SANDAG Board of Directors for action.
Another binational coordination effort is the California-Baja California 2021 Border Master
Plan, developed by Caltrans in partnership with the U.S.-Mexico Joint Working Committee, the
U.S. Federal Highway Administration, and Mexico’s Secretariat of Communications and
Transportation. The Border Master Plan coordinates planning and delivery of land ports of
entry and transportation infrastructure projects serving those ports of entry in the border
region. The County and local jurisdictions can work to identify opportunities for efficiency in
processing vehicles at ports of entry and advocate these plans to existing binational
coordination efforts.
To achieve decarbonization, it will be important for regional jurisdictions to reinforce
Oct. 11, 2022 Item #12 Page 148 of 560
110
initiatives related to shared infrastructure, efficient transportation systems, and
environmental planning. Outside of partnerships and direct authority over bi-national and
tribal decisions, the County can further its active transportation work in the areas it has
jurisdiction over. SANDAG’s Transit Leap and Mobility Hubs strategies can influence travel
behavior of those proximate to its jurisdiction by continuing to make investments in complete
streets, expanding high-quality transit options, and siting EV infrastructure in key areas. These
strategies can support the communities that work and live around border crossings and tribal
jurisdictions.
3.6.2 Freight and Trucking
The CARB Advanced Clean Truck Fleets rule requires that medium- and heavy-duty trucks
must run on alternative fuels by 2045. However, current technology is insufficient to support
electrification of or a shift to alternative fuels for long-haul freight and trucking. In support of
this shift, SB 671 (2021) established the Clean Freight Corridor Efficiency Assessment, to be
developed by the California Transportation Commission in coordination with other state
agencies. The assessment will identify freight corridors throughout the state that would be
priority candidates for the deployment of zero-emission medium- and heavy-duty vehicles by
December 1, 2023. The bill also requires the state freight plan to include a description of
needed infrastructure, projects, and operations for the deployment of zero-emission medium-
and heavy-duty vehicles and the development of freight corridors identified in the
assessment. Existing law requires the California Transportation Commission to allocate certain
revenues deposited in the Trade Corridor Enhancement Account and certain federal funds for
eligible infrastructure projects to mitigate emissions from trucks located on or along specified
transportation corridors. This bill would make projects eligible for funding if they employ
advanced and innovative technology to improve the flow of freight, environmental and
community mitigation, or efforts to reduce environmental impacts of freight movement.13
The County might consider conducting a localized clean freight study to understand where
opportunities for distribution efficiencies exist and modifying zoning code accordingly to
encourage distribution centers in efficient locations. It can follow the lead of Los Angeles
County, which set a goal of 25-50% of all medium-duty delivery trucks in the County to be
electric, and 10-40% of heavy-duty regional drayage trucks to be zero-emission by 2028. The
Los Angeles Cleantech Incubator, together with CARB, the Ports of Los Angeles and Long
Beach, and the California Energy Commission, issued a request for information from medium-
and heavy-duty truck manufacturers, EV supply equipment manufacturers, EV charging station
networks, fleet operators, and fleet charging companies to influence the market and uptake of
electrification and alternative fuels. Other zero-emission freight transportation pilot projects
in Los Angeles County focus on seamless corridor approaches and last-mile solutions that
respond to community needs as well as technology, business model, and educational
challenges.
Oct. 11, 2022 Item #12 Page 149 of 560
111
Within the City of Los Angeles, a recently adopted maritime resolution calls on top importers
to adopt 100% zero-emissions ships by 2030. While the technology does not currently exist for
this shift, and while the City does not have enforcement power over internationally-regulated
ships, the goal is to create green shipping corridors that can transition to zero-emissions
corridors as technology improves. The City and the Port of Los Angeles hopes to exert
influence on the shipping industry and on international regulators such as the International
Maritime Organization to transition the industry to cleaner fuels. Local governments can
incentivize clean cargo transportation through grants and special rates. San Diego and its port
can build on the lessons from these initiatives to inform its own projects and policy
recommendations and support the push to widespread zero-emission freight deployment.
3.6.3 Further Research
The following aspects of transportation decarbonization that are outside the scope of this
framework but worthy of additional study by the County include:
● Environmental externalities of electrification, such as end-of-life waste, emissions
associated with the extraction, processing, and distribution of the primary energy
sources used for electricity production (e.g., “well-to-wheel emissions”), and roadway
maintenance emissions associated with heavier vehicles;
● Lifestyle changes in the future that may not be reflected in today’s forecasts or
assumptions, such as changing work from home patterns, home delivery of goods, and
suburban migration that may be changing as a result of the COVID-19 pandemic;
● Policy response to pandemic conditions by transit agencies to match service to lower
ridership levels, or to attempt to recover lost ridership;
● Transportation by and around local military bases; and
● Development and deployment of a metric that better captures travel efficiency, such as
person-miles traveled (PMT) over VMT. Such a metric would encourage VMT reduction
strategies that do not compromise people’s ability to travel, access opportunities, and
move around the San Diego region in a way that meets their needs. The metric could be
used in conjunction with VMT, which is required by the state to determine CEQA
transportation impacts.
3.6.4 Cross-References
Transportation emissions are closely associated with other topics addressed in this
Framework. For example, EV adoption is linked to emissions associated with electricity
generation and VMT is heavily influenced by land use decisions and resulting development
patterns. Collaboration between sectors and comprehensive approaches are necessary to
achieve deep decarbonization. The table below summarizes how transportation
decarbonization is linked to other chapters.
Oct. 11, 2022 Item #12 Page 150 of 560
112
Chapter Cross-Reference
Chapter 2: Geospatial Analysis of
Renewable Energy Production
Additional details on the emissions reductions implications of
EV adoption relative to electricity sector decarbonization, and
discussion of alternative fuels.
Chapter 4: Decarbonization of Buildings Information on the cost of fully electrifying (including EV
charging) new buildings and assumptions for growth.
Chapter 5: Natural Climate Solutions and
Other Land Use Considerations
More information on how land use and transportation
decarbonization pathways are linked.
Chapter 6: Employment Impacts through
Decarbonization for the San Diego Region
More information about workforce development and new job
opportunities related to EV and the charging network.
Chapter 7: Key Policy Considerations for
the San Diego Region
Additional details on region-wide policy and legal authority to
implement strategies related to transportation sector
decarbonization.
Chapter 8: Local Policy Opportunity Additional details on local policy and legal authority to
implement strategies related to transportation sector
decarbonization.
Oct. 11, 2022 Item #12 Page 151 of 560
113
Works Cited:
1. UC Davis.Decarbonizing California Transportation by 2045.
https://www.ucdavis.edu/climate/news/decarbonizing-california-transportation-by-2045 (2021).
2. SANDAG. 2021 Regional Plan Programs and Policies - Electric Vehicles. https://sdforward.com/docs/default-
source/final-2021-regional-plan/appendix-b---implementation-actions.pdf?sfvrsn=f4c1fd65_2 (2021).
3. SANDAG. 5 Big Moves. San Diego Forward https://www.sdforward.com/mobility-planning/5-big-moves
(2021).
4. Black & Veatch Management Consulting. San Diego Regional Electric Vehicle Gap Analysis.
https://www.sdge.com/sites/default/files/2021-
07/FINAL%20San%20Diego%20Regional%20EV%20Gap%20Analysis%20%281%29.pdf (2021).
5. County of San Diego. County of San Diego Electric Vehicle Roadmap.
https://www.sandiegocounty.gov/content/dam/sdc/sustainability/EV-Roadmap/EV-Roadmap-October-
2019.pdf (2019).
6. County of San Diego. County of San Diego Climate Action Plan - Final.
https://www.sandiegocounty.gov/content/dam/sdc/pds/advance/cap/publicreviewdocuments/PostBOSDoc
s/San%20Diego%20County%20Final%20CAP.pdf (2018).
7. California Energy Commission. Zero Emission Vehicle and Infrastructure Statistics
https://www.energy.ca.gov/data-reports/energy-insights/zero-emission-vehicle-and-infrastructure-statistics
(2020).
8. United States Census Bureau. American Community Survey. https://www.census.gov/programs-surveys/acs (2015-2019).
9. SANDAG Activity Based Model. ABM1.
https://www.sandag.org/index.asp?subclassid=120&fuseaction=home.subclasshome (2012).
10. Frost, A. R. (2017). Quantifying the sustainability performance of urban form in California / by Alexander
Rijiro Frost. San Diego State University.
11. Salon, D. (2015). Heterogeneity in the relationship between the built environment and driving: Focus on
neighborhood type and travel purpose. Research in Transportation Economics, 52, 34–45.
https://doi.org/10.1016/j.retrec.2015.10.008
12. California Air Pollution Control Officers Association. Handbook for Analyzing Greenhouse Gas Emission
Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity.
https://www.airquality.org/ClimateChange/Documents/Final%20Handbook_AB434.pdf (2021).
13. SB-671 Transportation: Clean Freight Corridor Efficiency Assessment.
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202120220SB671 (2021).
Oct. 11, 2022 Item #12 Page 152 of 560
114
Appendix 3.A A table showing the comparison of SANDAG 2021 Regional Model (ABM2+) and EnergyPATHWAYS Model.
Model Fleet Mix Assumptions Fuel Mix Assumptions
Passenger Cars and Trucks Transit Vehicles Commercial Vehicles ZEV Adoption Rate
(Passenger and Goods)
Speed SANDAG 2021 Regional Model (ABM2+) 5 classes for traffic
assignment:
- Drive-alone non-
transponder
- Drive-alone
transponder
- Shared-ride 2
- Shared-ride 3+
- Heavy Truck
Each class is broken down
by income or by weight
class for a total of 15
traffic assignment classes.
7 transit modes:
- Tier 1 Heavy Rail
- Commuter Rail
- Light Rail
- Streetcar
- Rapid Bus
- Express Bus
- Local Bus
Inputs vary by mode:
- Frequency of
service
- Travel time
- Fare
5 goods movement
modes:
- Truck
- Rail
- Pipeline
- Marine
- Air cargo
4 commercial truck
types:
- Light vehicle
- Medium truck
(<8.8 short tons)
- Medium truck
(>8.8 short tons)
- Heavy truck
(FHWA classes 7-
13)
Zero-Emission Vehicles (ZEV)
and Electric Vehicles (EV) in
general are handled off-model.
Growth forecasts are based off
EMFAC.
Between Model Year
(MY)2025-2050, required
percent of new Light-Duty
Vehicle (LDV) sales that must
be ZEVs in EMFAC2017:
- Plug-in Hybrid Vehicles
(PHEV): 7.32%
- Battery-Powered Electric
Vehicle (BEV): 4.06%
- Hydrogen Fuel-Cell Electric
Vehicle (FCEV): 14.89%
PHEV, BEV, FCEV are all
referred to as ZEVs.
Inputs that affect speed on
regional highway
networks:
- Posted speed
- Roadway capacity
- Functional
classification
- Roadway operation
(HOV lane, etc.)
- Congestion
- Origin/destination
- Intersection control
- Transportation mode Evolved Energy Model (EnergyPATHWAYS) - Light car
- Light truck
- Motorcycle
- Buses
- Passenger Rail
- Medium truck
- Heavy truck
(divided into short
haul and long haul)
EMFAC growth forecasts.
Different assumptions by class:
more BEV for HD short haul
trucks, more FCEV for HD long
haul.
n/a
Oct. 11, 2022Item #12 Page 153 of 560
115
Model VMT Accounting Resolution
Method Scale Conversion to GHG Spatial Temporal SANDAG 2021 Regional Model (ABM2+) Accounting Methods for GHG
calculations using Vehicle Miles
Traveled (VMT):
- Internal-Internal: all VMT
included in analysis (VMT that
occurs from trips that start and
end in the SANDAG region)
- Internal-External or External
Internal: 50% of VMT included
in analysis (VMT associated
with trips with one trip end in
the SANDAG region and one
outside the SANDAG region)
- External-External: all VMT
excluded in analysis (VMT
associated with trips that start
and end outside of the SANDAG
region are not included).
- Total VMT
and GHG and
per-capita
VMT and
GHG.
VMT data tables are used
within EMFAC for
emissions calculations of
cold starts (trips) and
running emissions (VMT).
Calculations are adjusted
by transportation activity
data (VMT, speed
distribution) and vehicle
populations.
Emissions reductions
associated with various
ZEV policies are also
calculated outside of the
travel demand model.
Different resolution levels for
different steps of the model:
- Microanalysis zones: 23,002
Master Geographic Reference
Area (MGRAs) zones (roughly
equivalent to Census blocks)
- Traffic assignment demand
and skims: 4,996
Transportation Analysis Zones
- Transit assignment demand
and skims: 1,766 Transit Access
Points
Treatment of space is slightly
different for border crossing trips.
Transportation
behavior is
modeled every
half hour. Evolved Energy Model (EnergyPATHWAYS) n/a n/a Electricity and fuel
emissions intensities are
determined by supply-side
optimization subject to
net-zero economy-wide
constraints.
Vehicle stock is modeled for
Southern California region (divide
from Northern California is along
Pacific Gas & Electric
Company/Southern California
Edison service boundary).
Number of households is used to
estimate vehicle stock.
Annual vehicle
stock.
Oct. 11, 2022Item #12 Page 154 of 560
116
Model Analysis Years Input Data
Base
Year
Horizon
Year
Internal (SANDAG) Surveys Outside Data Sources SANDAG 2021 Regional Model (ABM2+) 2016 2050
- SANDAG Household Travel Behavior Survey (2016)
- Transit On-Board Survey (2015)
- SB 1 Transportation Network Company (TNC) Survey
(2019)
- Taxi Passenger Survey (2009)
- Parking Inventory Survey (2010)
- Parking Behavior Survey (2010)
- Border Crossing Survey (2011)
- Visitor Survey (2011)
- Establishment Survey (2012)
- Tijuana Airport Passenger Survey (2017)
- Commercial Vehicles Survey (2011)
- Vehicle Classification & Occupancy (2006)
- San Diego International Airport Air Passenger Survey
(2009)
- San Diego International Airport Passenger Forecasts (2013)
- Decennial Census Summary File-1 tabulation (2010)
- Census Data for Transportation Planning (CTPP)
- Public Use Microdata Sample (PUMS)
- American Community Survey (2015-2017)
- Bicycle counts (2011)
- Jurisdiction annual traffic counts (2016)
- FasTrak Transponder ownership data (2012)
- Caltrans Performance Measurement System (PeMS) (2016)
- Caltrans Highway Performance Monitoring System (HPMS)
(2016) Evolved Energy Model (EnergyPATHWAYS) n/a 2050
n/a - University of Virginia Population Projections
- California Air Resources Board vehicle service numbers
(EMFAC)
- 2021 U.S. Annual Energy Outlook
Oct. 11, 2022Item #12 Page 155 of 560
117
4. Decarbonization of Buildings
Philip Eash-Gates, Synapse Energy Economics, Inc.
Jason Frost, Synapse Energy Economics, Inc.
Shelley Kwok, Synapse Energy Economics, Inc.
Jackie Litynski, Synapse Energy Economics, Inc.
Kenji Takahashi, Synapse Energy Economics, Inc.
Asa Hopkins, PhD, Synapse Energy Economics, Inc.
Key Takeaways
● Reducing emissions from space heating and water heating due to fossil fuel combustion
should be a primary policy focus for buildings within the Regional Decarbonization
Framework. Other uses of fossil fuels in buildings—cooking, laundry, and process
loads—will need to be addressed as well.
● Policies should support increasing adoption of efficient heat pump-based space and
water heating systems in both new and existing buildings, with particular focus on
assistance for communities of concern and rental buildings.
● Setting “electrification-ready” or “all-electric” standards for new construction and major
renovations through building energy codes will reduce costs associated with
transitioning away from fossil fuels.
● Some existing fossil fuel equipment systems will only turn over once by 2050. Near-term
action is needed to guide building owners to replace end-of-life fossil fuel equipment
with electric equipment.
● Low-carbon gaseous fuels can be used for hard-to-electrify end uses, though these fuels
are not proven and scalable, necessitating research and piloting.
● The gas utility can mitigate its risk of not recovering its investment in assets (that is, its
stranded cost risk) by minimizing unnecessary extensions or replacements of the
pipeline system and by accelerating depreciation of existing utility assets.
● Improved data gathering is a low-cost, foundational action for future policy
development.
Oct. 11, 2022 Item #12 Page 156 of 560
118
4.1 Introduction
San Diego County is the fifth most populous county in the United States1 and boasts a large and
diverse building stock.2 The unique geography and varied climates within the San Diego region
have helped create an architectural montage, with distinct attributes across the county’s 18
municipalities and unincorporated areas.3,4 Some local infrastructure also reflects the county’s
18 Native American tribal reservations5,6—the most in any U.S. county—and 16 military bases.7
While it is one of the county’s great assets, the building stock also contributes to emissions: on-
site fossil fuel combustion comprised about 300,000 metric tons of carbon dioxide equivalent
emissions in 2014, roughly 9 percent of the county’s total emissions.8 Decarbonizing existing
and new buildings in the San Diego region represents a critical strategy within the Regional
Decarbonization Framework. This chapter focuses on direct emissions from buildings resulting
from fossil fuel combustion and how to eliminate those emissions by 2045. Chapter 2 and
Appendix A address emissions from electricity generation.
Options for decarbonizing San Diego’s buildings include electrifying end uses that are
responsible for direct emissions (primarily space and water heating) and using lower-carbon
fuels (such as biomethane and hydrogen) for hard-to-electrify end uses of energy. These are the
primary strategies for displacing the use of natural gas, the dominant combustion fuel used in
buildings in the region.i Demand reduction through traditional energy efficiency measures and
programs, such as more efficient combustion equipment, improvements in building shells, and
low-flow fixtures, is not sufficient to meet San Diego’s decarbonization objectives. Transitioning
to efficient electric technologies such as heat pumps and induction cooking results in both
substantially reduced energy demand and greater utilization of the increasingly renewable
electric supply portfolio.
Pathways taking different approaches to building sector decarbonization incur similar relative
costs, within the range of uncertainty. However, an electrification-based approach to
decarbonizing buildings does not depend on technological innovation or deployment of novel
technologies at previously unseen scales, making it generally lower risk.
All building decarbonization pathways cause a substantial transformation in the gas utility
business due to changes in the amount and sources of gas sold. Electrification pathways in
particular require fundamental changes in the gas utility business model because traditional
pipeline gas sales would essentially conclude by mid-century. We conclude this chapter with an
analysis of near-term steps that San Diego Gas & Electric (SDG&E), its regulators, and regional
i Natural gas is a fossil fuel predominantly composed of methane. Natural gas is a source of carbon dioxide when
burned and is also a potent greenhouse gas when leaked into the atmosphere (i.e., due to leaks in the supply
chain, natural gas infrastructure, and appliances).
Oct. 11, 2022 Item #12 Page 157 of 560
119
policymakers could take to mitigate risks associated with this transition and thereby ease
developing a long-term business transition plan.
4.2 Buildings in San Diego County
4.2.1 Residential Buildings
There are an estimated 1.3 million residential units across 0.9 million properties in San Diego
County. These residences comprise approximately 1.7 billion square feet and grow at a rate of
0.9 percent per year.i Multifamily properties represent 9 percent of the total residential floor
area, but are growing at a quicker rate than single-family: 2.2 percent per year compared to 0.7
percent. The relative sizes of the residential building stock vary considerably by municipality, as
depicted in Figure 4.1. The City of San Diego and the unincorporated areas of the county
represent 57 percent of the total. The City and County therefore have a large opportunity to
reduce emissions in this sector through targeted policies, such as building energy codes.
Figure 4.1 Residential building stock floor area (million ft2) by municipality in the San Diego region, 2021. Source:
Synapse analysis of data provided by San Diego County Assessor's Office.
Figure 4.2 breaks down the building stock by type of residence and over time for each
jurisdiction. These distinctions may affect how quickly and cost-effectively a community can
i Synapse analysis of data provided by San Diego County Assessor's Office.
Oct. 11, 2022 Item #12 Page 158 of 560
120
decarbonize its buildings. Strategies for addressing emissions for single-family homes and
multifamily apartments differ due to distinct ownership/occupancy paradigms and types of
end-use energy equipment in the residences. Additionally, for communities with the fastest
relative growth rates—which have recently been Imperial Beach, National City, Chula Vista, San
Marcos, and Santee—more stringent building energy codes can play an important role locally.
Figure 4.2 Residential building stock floor area (million ft2) by municipality in the San Diego region, 2017–2021.
Source: Synapse analysis of data provided by San Diego County Assessor's Office.
Figure 4.3 provides a breakdown of average pipeline gas usage for each major gas end use by
residential customers under three investor-owned utilities, based on the latest Residential
Appliance Saturation Study (RASS).9, i As shown in this figure, the average gas usage for water
heating is 200 therms and accounts for the largest share (about 59 percent) of the total for
major end uses in SDG&E’s jurisdiction. This share far exceeds the water heating usage share
for Pacific Gas & Electric (PG&E), but mirrors the usage share for SoCalGas. On the other hand,
the average residential gas usage for space heating in the SDG&E area accounts for about 29
percent. These gas end-use profiles show that SDG&E residential customers have the greatest
opportunity for GHG savings in water heating. Lastly, a jurisdictional comparison of the total gas
usage data in this figure shows that households in the San Diego region can more easily pursue
i Note that while this figure excludes minor end uses with low customer saturations such as spa and pool heat,
secondary heating, and gas backup for solar water heaters, the average natural gas consumption among all gas customers is lower than the estimates shown in this figure because some customers do not use gas for all major
end uses.
Oct. 11, 2022 Item #12 Page 159 of 560
121
building decarbonization because (1) their overall gas usage is lower and (2) electrifying water
heating typically requires relatively lower-cost, lower-complexity upgrades than are needed for
space heating.
Figure 4.3 Average annual natural gas usage (measured in therms) by end use and utility for households who use
gas as the primary fuel for major end uses. Source: DNV GL Energy Insights (2021). 2019 California Residential
Appliance Saturation Study (RASS).9
Figure 4.4 presents residential fuel-use breakdowns for space and water heating end uses in
terms of the number of utility accounts in the San Diego region. Data for this analysis come
from the 2019 RASS study. As shown in Figure 4.4, natural gas dominates both space and water
heating, more so for water heating (about 83 percent) than for space heating (about 69
percent). Approximately 28 percent of total households use electric space heating, while
electric water heating is used less than half as much: about 12 percent.
Figure 4.5 shows the breakdown of residential space heating equipment in terms of the number
of utility accounts in SDG&E’s service area (which has a nearly perfect overlap with San Diego
county). Electric heat pumps account for about 6.3 percent of all residential systems, up from 2
percent a decade earlier, as indicated by the 2009 RASS study. Central gas furnaces with ducts
account for about 56 percent of the total systems. Three other heating systems that use ducts
are central electric, LPG furnaces, and ducted air-source heat pumps (ASHPs). Together, the
systems relying on ducts account for about 70 percent of the total residential space heaters.
Excluding ducted ASHPs, such systems account for 66 percent of the total. These represent the
prime candidates for fuel switching to ducted ASHP technologies. The rest of the space heaters,
including electric unit heater (13 percent) and other fossil heaters (about 13.6 percent), can be
converted to heat pumps through the use of ductless minisplit heat pumps.
Oct. 11, 2022 Item #12 Page 160 of 560
122
Figure 4.4 Residential space and water heating by fuel type (% of customer accounts). Source: DNV GL Energy
Insights (2021). 2019 California Residential Appliance Saturation Study (RASS).9
Figure 4.5 Residential space heating system share by equipment type. Source: DNV GL Energy Insights (2021). 2019
California Residential Appliance Saturation Study (RASS).9
Oct. 11, 2022 Item #12 Page 161 of 560
123
4.2.2 Commercial Buildings
The commercial sector includes 158,000 building units across 36,000 properties in the county.
Together, these properties represent an estimated 554 million square feet and grow about 0.9
percent per year.i Figure 4.6 highlights the relative sizes of the commercial building stock in
each area within the county. The City of San Diego, the unincorporated areas of the county,
Chula Vista, Carlsbad, Escondido, and Oceanside have the largest total floor areas. Given the
sizable stock of commercial buildings in the City of San Diego, its policies can have an outsized
effect on reducing regional emissions. The City’s Building Energy Benchmarking Ordinance
marks an important step toward managing energy use and emissions in large buildings.10 The
ordinance lays the foundation for future innovative policies such as building performance
standards, which establish mandatory energy or emissions targets that improve over time.ii
The prominence of each commercial building type and the growth rate of the commercial
building stock varies by location and over time, as shown in Figure 4.7. As with residential
buildings, these distinctions influence the jurisdictions’ pathways to decarbonization. Some
building types (e.g., hospitals and restaurants) are harder to retrofit with equipment that
reduces carbon emissions, particularly from onsite combustion of fossil fuels, because they use
specialized equipment or combined heat and power systems. Carlsbad, Imperial Beach, and San
Marcos are experiencing higher rates of growth of commercial buildings.
i Synapse analysis of data provided by San Diego County Assessor's Office.
ii The following resources provide additional information on building performance standards:
American Cities Climate Challenge. 2021. Building Performance Standards: A framework for Equitable Policies to
Address Existing Buildings. Available at: https://www.usdn.org/uploads/cms/documents/bps-framework_july-
2021_final.pdf.
American Council for Energy-Efficient Economy. 2020. Mandatory Building Performance Standards: A Key Policy for
Achieving Climate Goals. Available at: https://www.aceee.org/white-paper/2020/06/mandatory-building-
performance-standards-key-policy-achieving-climate-goals
Carbon Neutral Cities Alliance. 2020. Existing Building Performance Standards Targets and Metrics Final Report.
Available at: http://carbonneutralcities.org/wp-content/uploads/2020/03/CNCA-Existing-Building-Perf-Standards-
Targets-and-Metrics-Memo-Final-March2020.pdf
Oct. 11, 2022 Item #12 Page 162 of 560
124
Figure 4.6 Commercial building stock floor area (million ft2) by municipality in the San Diego region, 2021. Source:
Synapse analysis of data provided by San Diego County Assessor's Office.
Figure 4.7 Commercial building stock floor area (million ft2) by municipality in the San Diego region, 2017–2021.
Source: Synapse analysis of data provided by San Diego County Assessor's Office.
Oct. 11, 2022 Item #12 Page 163 of 560
125
4.2.3 Building emissions
GHG emissions from buildings primarily reflect fossil fuel combustion. Such onsite consumption
provides services such as space heating, water heating, and cooking. Additionally, offsite
generation of electricity, district heating, and district cooling utilize fossil-based fuels, and the
associated emissions are attributable to buildings using these utilities. To identify strategies for
reducing these emissions in the San Diego region, it is important to first understand the fuel use
in local buildings—both how much of each fuel is used and what it is used for. Using data from
SDG&E, the City of San Diego, the San Diego County Assessor’s Office, the U.S. Energy
Information Administration, and prior energy studies,11,12,13,14 we estimated the fuel, energy,
and emission profiles for buildings in the San Diego region. Figure 4.8 presents the results for
each building type and across the total commercial building stock.
Figure 4.8 San Diego regional energy end-use profiles by commercial building type. Percentages are relative to
total end-use energy within each building sector. Annual energy consumption, measured in metric million British
thermal units (MMBTU), for each building type is shown in blue at the top of the figure. Source: Synapse model.
Space heating and water heating are the two building end uses responsible for the most GHG
emissions in the region. This reflects both that they require large amounts of energy—together
they consume over a quarter of all energy used in commercial buildings in the county—and that
they rely heavily on fossil fuels, specifically natural gas. Figure 4.9 provides a breakdown of the
primary fuel used for space and water heating in commercial buildings. Due to the low GHG
emissions associated with electricity generation in California, switching from fossil fuels to
efficient electric technologies (such as heat pumps) for these end uses will immediately reduce
emissions associated with space and water heating in commercial buildings. Additionally, end
Oct. 11, 2022 Item #12 Page 164 of 560
126
uses that rely on electricity will have fewer emissions over time as the electric grid incorporates
more renewable generation. As climate change increases local temperatures, cooling demand
in buildings will increase, partially offsetting the emissions reductions from a cleaner grid for
this end use.i These facts together suggest that reducing emissions from space heating and
water heating should be a primary policy focus within the RDF. The existing equipment within a
building plays an important role in determining what strategies will work best when
decarbonizing a building. A breakdown of existing equipment types for space and water heating
is provided in Figure 4.10 for commercial buildings in the San Diego region.
Figure 4.9 San Diego region primary fuel used in commercial buildings (floor area, million ft2) by building type:
space heating (left) and water heating (right). Source: Synapse model.
i Cooling emissions will, however, trend toward zero as the electric grid approaches 100 percent decarbonization.
Oct. 11, 2022 Item #12 Page 165 of 560
127
Figure 4.10 San Diego region natural gas equipment system used in commercial buildings (floor area, million ft2) by
building type: space heating (left) and water heating (right). Source: Synapse model.
4.3 Technologies and Fuels for Decarbonizing Buildings
4.3.1 Space heating technologies
Electric heat pumps are energy-efficient heating and cooling systems that work for all climates.
Unlike fossil fuel-based heaters that generate heat by burning fuels, heat pumps provide space
heating by extracting heat from outside and transferring it to the inside, using a vapor-
compression refrigerant cycle that connects an outdoor compressor with an indoor heat
exchanger. Heat pumps also work as an efficient air conditioner by reversing the heat transfer
process to remove heat and moisture from indoor air. Because of this heat transfer process,
heat pump efficiency levels typically exceed 250 percent (a coefficient of performance, or COP,
of 2.5) for heating and 400 percent (COP of 4) for cooling. That means for one unit of energy
input, a heat pump can provide 2.5 or more units of heating. By comparison, the most efficient
gas combustion heaters provide 0.98 units of heating for one unit of energy input. Switching
from natural gas heating to heat pumps will increase electricity demand in the winter. Notably,
the electric grid in the San Diego region peaks in the summer and can accommodate additional
winter load from electrification without substantial new investment in power transmission and
distribution infrastructure.
Various types of heat pumps are available in the market. Heat pumps are primarily categorized
by (a) the heat sources they draw from to heat buildings, (b) whether the systems heat air or
water, and (c) how the extracted heat is distributed in the buildings. Primary heat pump
Oct. 11, 2022 Item #12 Page 166 of 560
128
technologies used for space heating include air-source heat pumps (ASHPs), ground-source
heat pumps (GSHPs), water-source heat pumps (WSHPs), and air-to-water heat pump (AWHPs).
ASHPs are the most common heat pump system type used in the country. They move heat in
the air between inside and outside. Because ASHPs use heat in the outdoor air, their
performance (in terms of efficiency and capacity) degrades in cold temperatures. Thus,
conventional ASHPs often have backup electric resistance heating strips for cold temperature
operation. However, cold climate ASHPs that are now widely available in the market can
provide comfortable heat even under freezing temperatures without a backup heater.i Notably,
the winter climate in the San Diego region is moderate compared to the rest of the state and
much of the United States, and there is little need for backup heat in most of the region.ii
ASHPs include ducted ASHPs, mini-split ductless heat pumps, packaged terminal heat pumps,
and variable refrigerant flow (VRF) ASHPs. A short summary of these technologies is provided
below.
● Ducted ASHPs are the most widely installed systems. Ducted ASHPs include split
systems and packaged systems. Split heat pumps have an outdoor condenser and an air
handling unit in the building to deliver heating or cooling through ducts similar to
forced-air gas furnaces. Packaged heat pumps have all the components necessary for
heating, cooling, and air circulation combined into a single system, usually mounted
directly onto the building. They are typically installed on rooftops and thus are often
called rooftop units (RTUs). Ducted ASHPs can be a suitable alternative to aging gas
furnaces. Ducted ASHPs are installed in residential and small to medium commercial
buildings.
● Mini-split ductless heat pumps are relatively new to the U.S. market, but have been
gaining popularity over the past several years as new residential and small commercial
heating systems across the country. Mini-split systems also have outdoor condensers,
but use refrigerant pipes to deliver heating or cooling to each room where an indoor
unit is installed. Because they use small refrigerant pipes and are relatively easy to
install, they are suitable for heating system retrofits where ducts are not available. They
also use variable speed compressors, which allow them to operate more efficiently and
quietly than standard ducted ASHPs and to provide superior temperature controls.
i A field study in Vermont observed that cold climate ASHPs operated at 5° F with a COP of 1.6 and even at -20° F at
above 1 COP. See Cadmus (2017). Evaluation of Cold Climate Heat Pumps in Vermont. Prepared for the Vermont
Public Service Department. Page 24. Available at:
https://publicservice.vermont.gov/sites/dps/files/documents/Energy_Efficiency/Reports/
Evaluation%20of%20Cold%20Climate%20Heat%20Pumps%20in%20Vermont.pdf.
ii San Diego County spans four California climate zones. Most of the population live in Climate Zones 7 and 10,
which are among the most moderate in the state. Climate Zone 14 is the coldest of the four and includes most of
the eastern half of the county. Zone 14 experiences 2422 heating degree days in a typical climate year; by this metric it is less than half as cold as the northern and eastern parts of the state that comprise Climate Zone 16, with
5057 heating degree days per year.
Oct. 11, 2022 Item #12 Page 167 of 560
129
● Packaged terminal heat pumps (PTHP) are all-in-one systems (including compressor,
condenser and evaporator coils, fans, etc.), installed on an exterior wall. They are often
installed in hotels and small apartment units. Compared to other heat pump systems,
PTHPs do not perform well and their operating temperatures are typically limited.
However, a few cold climate PTHP models recently have become available in the
market.15
● Variable refrigerant flow (VRF) ASHPs can distribute heating and cooling to numerous
indoor evaporator units through a main refrigerant line from a single outdoor system.16
Many VRFs can also provide heating and cooling simultaneously in different rooms by
adding a heat recovery system, and thus benefit buildings with diversely loaded zones.17
VRFs are generally suitable for medium to large commercial buildings, but especially for
medium/high-rise multifamily buildings, office, schools, and lodging.18
Compared with ASHP, GSHPs and WSHPs provide better performance in cold temperatures
because they use heat reservoirs that have a higher temperature than ambient air during the
winter.i GSHPs use underground rock or groundwater as a heat reservoir. WSHPs use a well,
lake, aquifer, or other source (e.g., wastewater, cooling loop system, etc.) as a heat reservoir.
GSHPs need to drill holes or dig trenches in the ground to install a heat exchanging group loop
and thus are considerably more expensive than other heat pump technologies; however, total
lifecycle costs for GSHPs can sometimes be lower, due to high-efficiency operation.
AWHPs extract heat in the outdoor air and use water (or a mixture of water and glycol) as a
heat transfer medium within the building instead of forced air. AWHPs are now widely available
as heat pump water heaters for residential buildings. To date, their applications for space
heating have been limited in the United States, although more systems are becoming
commercially available in the early 2020s. For large commercial buildings with existing hot
water heating systems (e.g., gas boilers), large-scale AWHPs can be a more energy-efficient
alternative heating system or can provide supplemental heating.
GSHP, WSHPs, and even AWHPs can also produce temperatures high enough for a district
heating energy system that circulates hot water. For example, Stanford University’s new district
heating energy system includes three large-scale heat recovery chillers (a type of WSHPs) that
extract heat from waste heat from the University’s cooling tower.19
4.3.2 Heat pump performance
For our building energy analysis, we developed average annual coefficient of performance
(COP) values for heat pumps separately for the residential and commercial buildings for a
Central Case and for a Low Demand (high efficiency leading to low energy demand) case, as
i GSHPs and WSHPs also typically provide better cooling performance in hot temperatures because the heat
reservoirs are generally lower temperature than ambient air during the summer.
Oct. 11, 2022 Item #12 Page 168 of 560
130
shown in Table 4.1 below.i We estimated these based on various data sources. These included
our own calculation of COP values based on real-world heat pump performance data on
residential-scale heat pumps in other states, combined with hourly temperatures in San Diego
County.20-22 We also reviewed COP values in California and the US market as a whole.23, 24 For
commercial buildings, we assumed that heat pumps are 20 percent more efficient than
residential systems under the Central Case due to the availability of high-temperature heat
sources, VRF’s high COP values due to simultaneous heating and cooling functions, and
advanced technologies such as multi-stage compressors. Finally, we projected COP values
through 2050 for the Central Case and for the Low Demand Case based on National Renewable
Energy Laboratory’s COP forecasts in its Electrification Futures Study.25
Table 4.1 Synapse projection of COP values for heat pump space heating in the San Diego region.
2021 2030 2040 2050
Central Case
Residential 3.3 3.6 3.8 3.8
Commercial 3.9 4.4 4.5 4.6
Low Demand Case
Residential 3.3 3.8 4.4 5.0
Commercial 3.9 4.5 5.0 5.5
We also forecast total installed costs for heat pumps and gas space heaters for single-family
and multifamily buildings, as shown in Table 4.2. Installation costs include equipment and labor,
but exclude operation and maintenance. We reviewed numerous data sources and developed
the current cost estimates primarily based on a 2019 study by E3 which analyzed residential
building electrification in California.26 We decided to use this data source for three main
reasons: (a) some cost estimates in this study aligned well with our knowledge of system
installed costs and the cost estimates in other trusted data sources; (b) the study conducted a
detailed bottom-up approach to estimate heat pump costs; and (c) the study provided cost
estimates by climate zone, type of building, and building vintage. We selected cost estimates
for coastal Los Angeles and downtown Los Angeles to develop cost estimates for the San Diego
region, as these areas have the most similar climate. We then used various data sources to
develop weighted average cost estimates for single-family and multifamily buildings in the San
Diego region.ii Next, we forecasted future total installed costs of these systems using data from
i See Section 4.4 of this chapter for a discussion of the modeled cases.
ii We used the following sources to develop new construction and HVAC retrofit rates: Joint Center for Housing
Studies of Harvard University. 2021. Improving America's Housing. Available at: https://www.jchs.harvard.edu/sites/default/files/reports/files/harvard_jchs_improving_americas_housing_2021.pdf; Statista. 2021. "Number of
housing units in the United States from 1975 to 2020. Accessed September 27, 2021. Available at:
Oct. 11, 2022 Item #12 Page 169 of 560
131
NREL’s Electrification Future Study.25 Heat pump costs fall, in real terms, over the study period
to reflect the increasing maturity of the technology along with technical and market advances
as the equipment becomes much more widely adopted. (In contrast, gas furnace and boiler
technology is largely mature and we project stable pricing.) Finally, we used the share of floor
area between single-family and multifamily buildings (54 percent single-family and 46 percent
multifamily) to develop per-unit costs for residential buildings on average, to align with how our
decarbonization scenarios are defined. Equipment costs do not differ substantially between
new construction and retrofits, provided that retrofits do not include changes in ductwork.i
Given San Diego’s mild winters and prevalence of air conditioning (approximately two-thirds of
homes),9 we do not expect electric panel upgrades to be required to adopt efficient electric
space or water heating in most homes. Panel upgrades may be required for electric vehicle
charging, with the co-benefit of also increasing capacity for electric end uses in the home; these
costs are not attributed to building sector costs. Due to the relatively small role of new
construction in the overall pathway economic analysis, we did not account for new construction
savings from avoiding the cost of installing gas piping or service lines to the street in the case of
all-electric construction.
Table 4.2 Synapse projection of average total installed costs of residential HP and gas space heaters in San Diego
($2021).
2021 2030 2040 2050
Heat pump
Single-family $14,200 $13,142 $11,967 $10,791
Multifamily $10,900 $10,088 $9,186 $8,284
All residential $12,673 $11,728 $10,680 $9,631
Gas heater
Single-family $15,000 $15,000 $15,000 $15,000
Multifamily $11,400 $11,400 $11,400 $11,400
All residential $13,334 $13,334 $13,334 $13,334
Table 4.3 provides estimated building electrification costs for commercial buildings in the San
Diego region. These include equipment and labor costs to convert existing fossil-based systems
to electric systems as well as related building infrastructure changes. Energy efficiency retrofits,
such as building envelope upgrades to reduce peak-load impact of electrification, are not
included. Equipment maintenance and operation costs are also not included in these estimates.
We draw on data from a 2021 building electrification study for Los Angeles,27 heat pump cost
https://www.statista.com/statistics/240267/number-of-housing-units-in-the-united-states/; San Diego County’s
tax assessor database. We also developed an estimate of HVAC retrofits by homes with ductless heaters (e.g., wall
furnace, electric resistance heater etc.) in San Diego Country based on the 2019 RASS.
i We assume that ducted systems are replaced with ducted, and ductless with ductless, to avoid such costs.
Oct. 11, 2022 Item #12 Page 170 of 560
132
trajectories from NREL’s Electrification Futures Study,25 and 2021 data on building
characteristics from the San Diego County Tax Assessor’s Office. We adjusted these cost data to
align with the local building stock. Our economic analysis in Section 4.3 below is based on costs
to electrify space and water heating (and does not include other end uses, the cost to
disconnect gas, or potential costs to upgrade electrical service).
Table 4.3 Estimated commercial building electrification costs for San Diego County ($2021).
Item Units 2021 2030 2035 2040 2045 2050
Space heat $/sqft $15.83 $13.79 $13.03 $12.28 $11.80 $11.33
Water heat $/sqft $0.65 $0.57 $0.53 $0.49 $0.46 $0.42
Cooking $/sqft kitchen $18.00 $18.00 $18.00 $18.00 $18.00 $18.00
Gas disconnection $/property $922 $922 $922 $922 $922 $922
Electrical upgrades $/property $32,975 $32,975 $32,975 $32,975 $32,975 $32,975
Other end uses, misc. $/sqft $1.75 $1.75 $1.75 $1.75 $1.75 $1.75
Source: Synapse model based on data from Jones (2021),26 Mai et al. (2018),46 and San Diego County Tax Assessor’s
Office (2021). Values represent total gross costs, not incremental cost to fossil fuel systems.
4.3.3 Water heating technologies
Residential water heating is the largest gas-consuming end use in the San Diego region (Figure
4.3) and thus offers the largest GHG emissions savings opportunity through electrification.
Heat pump water heaters (HPWHs) have become widely available and very efficient. Their
efficiency is measured using a Uniform Energy Factor (UEF) which presents an efficiency rating
based on certain testing conditions.i The majority of available products have UEFs above 3, and
several products with a UEF of 4 are now available in the market.28 Electric resistance-based
and combustion-based water heaters, whether tanked or tankless, cannot exceed a UEF of
0.99.
The most popular HPWH technology is a hybrid HPWH which includes a heat pump, backup
electric resistance coils, and hot water storage tanks. Hybrid HPWHs can be installed in many
places, including garages, basements, back porches, and outdoor-vented closets. While siting
details are beyond the scope of this policy document, these technologies’ performances vary
with differences in air temperature and ventilation. Generally, garages are an optimal place for
the best performance in warmer climates, while basements may be a better in cooler
climates.29, 30
Another HPWH technology is a split heat pump water heater with an outdoor compressor,
i UEF is comparable to coefficient of performance: it measures the ratio of the energy service output to the energy
input. It is not exactly equal to the coefficient of performance for a water heater’s heating element because it
incorporates heat losses from the water storage tank.
Oct. 11, 2022 Item #12 Page 171 of 560
133
sometimes called a “pure” HPWH because it does not need a backup resistance heater. As a
split system, it offers more flexibility for placing the indoor unit within the living space. For
example, Sanden produces a split HWPH that uses CO2 as a refrigerant. This split heat pump
water heater has several advantages over hybrid models: it has a substantially higher capacity
(approximately triple that of hybrid models) and efficiency (with a rated COP of 5), it only
requires 13 Amp service, which could avoid upgrading an electrical panel, it can heat water to
175° F, and it can operate in ambient temperatures down to -20° F.31, 32
Both hybrid and pure HPWHs can offer load flexibility and work as demand response resources
by storing additional thermal energy when electricity rates are low to avoid energy usage
during peak hours. A 2018 study by Ecotope, Inc. found that this HPWH load flexibility can yield
15-20 percent savings on customer bills and 35 percent marginal cost savings for utilities in
California.33 The demand flexibility of HPWHs can help mitigate grid impacts associated with
electrification of water heating.
Several large-scale HPWHs (which are either AWHPs or WSHPs) are available for commercial
buildings in the market (including large multifamily buildings), although to date such
applications have been limited in the country. HPWH configurations for commercial buildings
can be quite different from single-family homes because commercial buildings have a lot of
variations in water use and building structures, and also because some buildings have unique
opportunities to utilize different heat reservoirs. For example, HPWHs can be placed in a below-
grade garage, if available, and take advantage of milder temperatures in the garage to produce
hot water.34 Mechanical rooms or laundry rooms can also be a suitable place for HPWHs
installations if such those rooms are currently too hot or too humid, because HPWHs have the
added benefit of cooling and dehumidifying the surrounding air. Further, HPWHs can be placed
where they can utilize waste heat produced in certain commercial facilities such as spas,
restaurant kitchens, or wastewater treatment facilities. Such HPWH applications provide space
cooling benefits to the commercial facilities. Finally, large commercial and institutional
buildings with a standard chiller system with a cooling tower could be a good candidate for
installing HPWHs, more specifically heat recovery chillers. Heat recovery chillers can recover
some of the waste heat from the electric chillers and produce hot water.35
4.3.4 Water heater performance
For our building energy analysis, we developed average annual COP values for HPWH separately
for residential and commercial buildings for a Central Case and for a Low Demand Case, as
shown in Table 4.4 below. We based these values on our assessment of a few different data
sources. The primary source is the Natural Resource Defense Council and Ecotope’s analysis of
HPWH performance in California, which estimated COP values in 16 California climate zones.29
Oct. 11, 2022 Item #12 Page 172 of 560
134
We selected climate zones suitable for the San Diego region from this study and estimated
average COP values for garage and vented-closet placement. We then adjusted the COP values
upward to account for technology improvement, since the study was conducted using UEF
ratings for HPWH products available at the time.27 Finally, we developed our COP projections
and COP estimates for commercial systems loosely based on NREL’s COP forecasts for HWPH in
its Electrification Futures Study.25 NREL’s COP estimates for commercial systems are generally
lower than residential systems, with the difference ranging from 0 percent to about 14 percent,
depending on the years. However, we assume commercial systems perform at least as well as
residential systems and better than NREL’s projections because some commercial buildings
have access to unique heat reservoirs, unlike residential buildings.
Table 4.4 Synapse’ projection of COP values for heat pump water heating in the San Diego region, for central case
and high efficiency (low demand) case.
2021 2030 2040 2050
Central Case
Residential 3.0 3.2 3.5 3.5
Commercial 3.0 3.2 3.5 3.5
Low Demand Case
Residential 3.0 3.3 3.6 4.0
Commercial 3.0 3.3 3.6 4.0
We also developed our forecasts of total installed costs for HPWHs and gas water heaters for
single-family and multifamily buildings, as shown in Table 4.5 below. The installation costs
include equipment and labor, but exclude operation and maintenance. We first developed the
current cost estimates based on a literature review.36, 37 Next, we forecasted future total
installed costs of these systems using data from NREL’s Electrification Future Study. Finally, we
used the share of floor area between single-family and multifamily buildings (54 percent single-
family and 46 percent multifamily) to develop per-unit costs for residential buildings on
average, to align with how our decarbonization scenarios are defined. As with space heating,
we do not find that costs differ substantially between new construction and retrofit
applications. Cost data for water heating electrification for commercial buildings, including
installing HPWHs, are provided in Table 4.3 above.
Oct. 11, 2022 Item #12 Page 173 of 560
135
Table 4.5 Synapse projection of total installed costs of residential HPWHs and gas water heaters in the San Diego
region ($2021).
2021 2030 2040 2050
Heat pump water heater (HPWH)
Single-family $3,000 $2,500 $2,037 $1,852
Multifamily $2,125 $1,771 $1,443 $1,312
All residential $2,595 $2,162 $1,762 $1,602
Gas water heater
Single-family $1,650 $1,650 $1,650 $1,650
Multifamily $1,600 $1,600 $1,600 $1,600
All residential $1,627 $1,627 $1,627 $1,627
4.3.5 Cooking technologies
While cooking with fossil fuels contributes relatively few GHG emissions, this end use is among
those which residents most directly see and engage with. Many people enjoy cooking with gas
stovetops, especially when compared with older electric technologies. Consumers generally
care less about a particular fuel for ovens, and almost every other cooking appliance (such as
microwaves, toasters, and pressure cookers) is natively electric.
In the residential sector, cooking therefore matters less for direct GHG emissions and more for
decarbonization pathway economics, as it shapes whether residents retain a gas connection for
their home, even after switching fuels for water and space heating. Aside from restaurants or
other food preparation businesses, most commercial buildings have no or very low cooking-
related GHG emissions. However, cooking is a larger component of GHG emissions in the
commercial sector than it is in residential, due to high energy use in commercial kitchens and
lower relative demand for hot water and space heating in commercial buildings.
New electric cooking technologies, particularly cooktops that heat using induction, have the
potential to upend customer devotion to cooking with gas. Induction cooking works by using
magnetic fields to excite electric currents in the metal base of pots and pans used for cooking.
These electric currents quickly convert to heat. Directly heating the pan is faster, more
responsive, and more efficient than older cooking technologies, with no waste heat lost into the
room. Heat levels can be changed as fast or faster than with gas, and water commonly boils
faster on an induction cooktop than a comparable gas one. The cooktop itself stays cool, which
improves safety and makes cleanup easy. There are also no combustion emissions, so indoor
and outdoor air quality is improved. Electric ovens are comparably priced competitors to gas
ovens, and do not face technology-specific market or customer adoption barriers.
Barriers to the adoption of induction cooking include relatively higher upfront prices, some pots
Oct. 11, 2022 Item #12 Page 174 of 560
136
and pans being incompatible with induction, and customer unfamiliarity with the new
technology. Both electric cooktops and ovens (and combined systems) can require new electric
circuits to be run to carry enough power, and they could even trigger the need for an electric
panel upgrade (if the panel has not yet been upgraded to serve a fast electric vehicle charger
and/or heat pump system).
4.3.6 Laundry
Electric dryers have a large market share today; in the Pacific census region, the U.S. Energy
Information Administration found that two-thirds of homes that have dryers use an electric
one.38 Aside from potential building-specific barriers stemming from electric-panel capacity and
new circuits, there are no substantial barriers to residential adoption of electric dryers. There
are also new, more efficient electric dryers that use heat pump technology. These pump heat
into the drum, while the cool side of the heat pump condenses the water removed from the
clothes. This eliminates the need for a vent, so heat pump dryers can be used very effectively in
high-performance buildings with tight building envelopes. Heat pump dryers are gentler on
clothes than traditional tumble dryers, but can also take a longer time to dry a load of laundry
and are currently substantially more expensive than traditional dryers.
Commercial laundry systems face higher barriers to the adoption of electric options than do
residential. Running many large electric dryers, as in a laundromat, could require substantial
upgrades to a building’s electrical system if it is transitioning from gas equipment. The slower
speed of heat pump dryers is also more of a challenge in throughput-limited commercial
laundry systems than in residential applications.
4.3.7 Low-carbon fuels
One way to reduce the GHG emissions from buildings without changing building systems (or
before changing those systems to non-emitting options) is to use fuel that does not release net
greenhouse gases into the atmosphere. The two primary ways to generate such fuel are to
process biological waste or separate hydrogen from various feedstocks.
4.3.7.1 Biomethane
Biomethane can replace natural gas in current applications, as methane is the primary
component of fossil natural gas. Many microbes that digest organic matter in the absence of
oxygen (“anaerobic” digestion) release a combination of carbon dioxide and methane, called
syngas. Biological feedstock can also be gasified into syngas using high heat processes (called
“pyrolysis”). The carbon dioxide can be removed (called “scrubbing” the gas), leaving pipeline-
quality methane.
Oct. 11, 2022 Item #12 Page 175 of 560
137
Biomethane supply is currently very limited, and expected to remain well below the level of
current fossil gas consumption. This constraint comes from both the lack of infrastructure to
produce biomethane from biological feedstocks and the more fundamental limitation of the
amount of feedstock biomass material that can be sustainably produced. Given limited supply,
use in the building sector may not be prudent or economical because other sectors (such as
industrial use) that have fewer low-carbon alternatives may require all available supply.
Processing for pipeline use must also compete with the option to combust the unprocessed (or
less processed) fuels at their site of production to generate electricity and transport the
resulting low-carbon energy to customers. There are also concerns about leakage of
biomethane and recovered methane. Fugitive emissions can be high in certain production
processes, including digestate storage and biogas upgrading.39
Biomethane costs and emissions depend on the production pathway used. In general, though,
biomethane has lower, but non-zero, GHG emissions (especially after leakage is considered),
and costs range between $10 per MMBTU to over $50 per MMBTU.40 For reference, fossil
natural gas currently costs less than $5 per MMBTU.
4.3.7.2 Hydrogen-based fuels
There are two primary methods used to produce low-carbon hydrogen. The first of these is
electrolysis, which splits water into hydrogen and oxygen by running electricity through the
water. If the electricity for this purpose is low-carbon, then the hydrogen is low-carbon. This is
referred to as “green” hydrogen. The second method builds on today’s methods for making
hydrogen, which rely on splitting methane into carbon dioxide and hydrogen using “steam
reformation.” So-called “blue” hydrogen is low-carbon if the resulting carbon dioxide is
captured and permanently sequestered. There are no fundamental physical limits to the
amount of green hydrogen that can be produced, so this energy carrier holds promise to meet
combustion energy needs not met by biomethane. Today, approximately 99 percent of
hydrogen produced in the United States is produced directly from fossil fuels, and about 1
percent from electricity (although not all this electricity is low-carbon).41 To play a significant
role in building decarbonization, green hydrogen production would need to increase
spectacularly alongside associated increases in zero-carbon electricity generation beyond what
was modeled for the RDF.
Hydrogen can be blended with natural gas up to the level of about 20 percent by volume, or 7
percent by energy, without requiring changes in pipeline or customer infrastructure. However,
at higher hydrogen concentrations, some pipeline materials could be damaged and customer
appliances might fail to work safely. Using pure hydrogen (or high-hydrogen blends) would
therefore require a substantial infrastructure investment to replace pipes and ensure that all
Oct. 11, 2022 Item #12 Page 176 of 560
138
customer cooktops, furnaces, water heaters, etc., were upgraded before the gas were sent to
their buildings. Because hydrogen-ready appliances are only just being tested today and
pipeline systems would also need upgrading, this transition arguably represents a larger shift
for customers than electrification would be.
One way to limit the need for infrastructure change to accommodate hydrogen would be to
combine the hydrogen with carbon captured from a biological source or from direct air capture,
to produce synthetic methane. When using biological sources, this fuel would face the same
feedstock limits as biomethane. This means that for wholesale replacement of fossil natural gas
with synthetic gas, the carbon would likely need to be captured from the air. Net lifecycle GHGs
from these processes would depend on powering the air capture with zero-carbon sources of
energy and limiting the leakage of the produced methane to low-enough levels so as to not fully
counteract the climate benefits of the fuel.
One planning implication of using green hydrogen, especially paired with direct air capture, is
the immense requirements for electricity to power the electrolysis and air capture processes.
The amount of electricity to produce these fuels and meet customer needs would dwarf the
amount of electricity that would be required to directly meet customer needs with the
generated electricity. As shown in Figure 4.11, meeting the same energy demand with green
hydrogen as with heat pumps would require almost six times as much renewable energy
generation.
While the ability to store and ship hydrogen and synthetic methane allows for distant
generation not aligned with seasonal needs for heating, the added land use and cost associated
with this electricity production warrant consideration. Overall, synthetic natural gas is expected
to cost more than biomethane when using direct air capture: E3 recently estimated a cost of
about $70 per MMBTU.42
In the San Diego region’s context, with the region’s good year-round renewable electricity
resource and lack of strong seasonal heating demand, these technologies face an even greater
competitive challenge. In addition, industrial and heavy duty transportation end uses that are
difficult to electrify would be the first users of low-carbon hydrogen or synthetic fuels, so
supply for buildings would be a secondary market and could be limited.
Oct. 11, 2022 Item #12 Page 177 of 560
139
Figure 4.11 Comparison of efficiency of energy delivery between green hydrogen and heat pumps. Note that this
figure does not include the added cost and efficiency loss from direct air capture and the manufacture of synthetic
methane. Source: London Energy Transformation Initiative, 2021. “Hydrogen: A decarbonisation route for heat in
buildings?,” Reproduced with permission. Available at: https://b80d7a04-1c28-45e2-b904-
e0715cface93.filesusr.com/ugd/252d09_54035c0c27684afca52c7634709b86ec.pdf.
4.4 Pathways to Decarbonization of San Diego’s Buildings
Synapse modeled three different trajectories to reach a carbon-free building sector in 2050.
These scenarios were designed to align with multi-sector analysis performed by Evolved Energy
Research, as detailed in Chapter 1 and Appendix A.i
1. Central (High Electrification). This pathway assumes that over 95 percent of space
heating and water heating equipment sales are fully electric by 2030 and 2032,
respectively. In 2050, no residential water heating is served by gas and only 8 percent of
residential space heating systems are unelectrified. SDG&E adds about 44,000 new gas
customers by 2030, and about 2,000 after.
2. Low Demand (High Efficiency). In this scenario, space and water heating system sales
and stock numbers match the trajectories from the Central Case. Heat pumps are
assumed to perform at higher efficiencies, reducing electricity consumption and
demand.
3. Partial Electrification. This case models an alternative approach, where less than half of
space and water systems sales in 2030 are electric. In this case, a low-carbon gas to use
as a natural gas alternative is required to achieve decarbonization within the study
period. The scenario assumes a linear increase in the use of a low-carbon gas,ii starting
in 2030 and reaching 100 percent in 2045 and later years. SDG&E adds about 60,000
new gas customers by 2030, and about 34,000 more by 2050.
i The Evolved Energy Research (EER) model assumptions are described in Appendix A Table 1.
ii Assumed to be a gas that reduces GHGs by 95 percent relative to fossil gas.
Oct. 11, 2022 Item #12 Page 178 of 560
140
Table 4.6 Some important differences between the three modeled scenarios.
Central Low Demand Partial Electrification
Electric space heat equipment sales
share in 2030
96% (84% heat
pump)
96% (84% heat
pump)
41% (17% heat pump)
Electric share of installed residential
HVAC systems in 2050
92% (75% heat
pump)
92% (75% heat
pump)
75% (54% heat pump)
New residential space heating heat
pump COP in 2050
3.51 5 3.51
Residential and commercial
electricity consumption from space
and water heating in 2050
4.6 TWh 4.2 TWh 4.3 TWh
We have not examined a reference case which fails to achieve zero emissions by 2045, which is
in line with California’s statewide net-zero goal. GHG reductions are required by the state, so
the relevant questions for policymakers and the public relate to which pathway to
decarbonization to choose, not whether to decarbonize at all. Comparing the decarbonization
cases to a “reference” or “business as usual” case that fails to reduce emissions would not
provide useful insights.
We have also not modeled a scenario that reduces emissions from the building sector to zero
(or net-zero) by 2035. Achieving such a target within the San Diego region’s building stock itself
would require either extensive retirement and replacement of operating fossil fuel equipment,
such as furnaces and water heaters, before the end of its useful life, or a rapid and extensive
uptake of low- or zero-emission combustion fuels. Either approach would cost substantially
more than replacing equipment with efficient electric options after a normal lifespan, as
modeled here. It is likely that cost-effectively achieving a net-zero target for the buildings sector
well in advance of 2045 or 2050 would require use of offsets from carbon removal or emission
reductions in other sectors or locations. In the event that the San Diego region pursues this
approach, it will be necessary to continue local emission reduction activities after 2035, such as
those detailed in the scenarios considered here, to reduce dependence on offsets.
Early policy interventions—such as updating building energy codes to require “electrification-
ready” or “all-electric” in all new construction and major renovations—can help achieve the
high market penetration of electric space and water heating equipment, as in the Central and
Low Demand scenarios. Harmonizing the region’s building codes to its decarbonization goals
will reduce the overall costs of transitioning away from fossil fuels, aligning near-term
investments to the 2050 vision. Further, building codes for new construction can help expedite
the adoption of low-carbon technologies into the market, preparing the labor force and
equipment distributors to supply these technologies to existing buildings as well.
The scenario results in the sections below include all equipment stock in buildings: existing
Oct. 11, 2022 Item #12 Page 179 of 560
141
buildings and new construction. We use population growth projections for California to
evaluate the rate of new construction in the San Diego region.43, i We estimate that 8 percent of
the residential and commercial building stock will be new by 2030, increasing to 18 percent by
2050.
4.4.1 Central Scenario (High Electrification) Results
This case illustrates a decarbonization pathway centered on switching space and water heating
systems from natural gas (and delivered fuels) to electricity, predominantly heat pumps. Figure
4.12 shows the breakdown in annual sales for space and water heating in the residential and
commercial markets.
Figure 4.12 Sales of space and water heating equipment, by fuel and type, in the Central Case through 2050.
Residential results are on the top and commercial results are on the bottom. Space heating results are on the left
and water heating results are on the right. Sales for residential buildings are by unit; for commercial, they are
denoted in floor space (million ft2).
i We assume 0.8 percent population growth during the period 2021–2030 and 0.6 percent population growth
thereafter until 2050.
Oct. 11, 2022 Item #12 Page 180 of 560
142
Space heating systems are replaced at a slower rate than water heaters, so some gas space
heating equipment remains in use in 2050 in the Central case, while gas water heating is
effectively eliminated. Figure 4.13 shows the stock of space and water heating systems by fuel.i
As building systems are electrified, the resulting on-site energy use and emissions change. Total
site energy consumption falls, as shown in Figure 4.14, because electric heat pump technologies
are much more efficient than combustion-based or resistive heating.
Figure 4.13 Stock of space and water heating systems, by fuel and type, in the Central Case through 2050.
Residential results are on the top and commercial results are on the bottom. Space heating results are on the left
and water heating results are on the right. Stock for residential buildings is by number of units; for commercial, it is
denoted in floor space (million ft2). “Stock” is here defined as the total installed base of systems in buildings (not
the equipment stocked for sale by distributors).
i By “stock” we mean the total installed base of systems in buildings (not the equipment stocked for sale by
distributors).
Oct. 11, 2022 Item #12 Page 181 of 560
143
Figure 4.14 Total site energy consumption (measured in trillion British thermal units, TBTU) in the San Diego region
for space and water heating in the Central Case through 2050 by building type and end use.
Natural gas use would decline to about 3 percent of current levels, with remaining use primarily
for residential space heating, as shown in Figure 4.15.
On-site GHG emissions, which are currently dominated by natural gas combustion, would
follow a trajectory closely aligned with the natural gas trajectory. Figure 4.16 shows on-site
emissions by fuel. Remaining emissions in the natural gas sector could be reduced by using
small amounts of low-carbon gas such as biomethane.
Electricity use for space and water heating, however, would increase substantially, as shown in
Figure 4.17. Electric sector GHG emissions are set to decline to zero by 2045 as a result of
California state electricity policy.
While this analysis shows more than a tripling in electricity use for space and water heating, this
remains a relatively small part of SDG&E's total electric sales (Figure 4.17). SDG&E’s 2020
electric sales totaled slightly more than 14 terawatt hours (TWh).44 This is because electricity is
used for many other purposes today, and those uses would continue. Additionally, the
projected growth in electric vehicles will account for a greater impact on electricity demand.
Our analysis does not extend to an hourly look at load shapes from different end uses.
However, the increase in electric consumption shown here does not appear likely to drive a
substantial increase in SDG&E’s peak electric demand. In 2020, SDG&E experienced a peak
demand of about 4,600 megawatts (MW), driven by summer air conditioning load, while its
winter peak loads were less than 3,000 MW.44 This indicates there is substantial headroom for
winter heating load without driving new distribution system or transmission system peaks. To
the extent that new water heating loads could add to the summer peak, rate design and control
technologies can help shift these loads to off-peak hours.
Oct. 11, 2022 Item #12 Page 182 of 560
144
Figure 4.15 Total consumption of natural gas (in TBTU) in the San Diego region for space and water heating in the
Central Case through 2050.
Figure 4.16 On-site GHG emissions (in million metric tons of carbon dioxide, MMT CO2) in the San Diego region
from space and water heating by fuel in the Central scenario, without use of low-carbon gas, through 2050.
Oct. 11, 2022 Item #12 Page 183 of 560
145
Figure 4.17 Consumption of electricity (measured in terawatt hours, TWh) for space and water heating in the
Central scenario through 2050 by building type and end use. For context, SDG&E’s 2020 electric sales totaled
slightly more than 14 TWh.
4.4.2 Low Demand Case Results
The primary difference between the Central and Low-Demand cases is that the latter assumes
that electric equipment that replaces combustion-based space and water heating equipment is
more efficient. This case has minimal changes in the sales and stock of natural gas equipment.
Thus, the most substantial difference between the Central Case and the Low Demand Case is
that the Low Demand Case uses less electricity overall, with no difference in emissions or
natural gas use. Figure 4.18 shows the electricity demand trajectory for space and water
heating in this case, compared to the Central Case.
Figure 4.18 Total electricity consumption (in TWh) for space and water heating in the Low Demand scenario (blue)
and the Central scenario (red).
Oct. 11, 2022 Item #12 Page 184 of 560
146
The use of higher-efficiency equipment results in lower electric supply costs (see below) and a
lower demand for the construction of zero-carbon electric generators. This has implications for
the electricity supply analysis presented in Chapter 2. The electric consumption reduction in
this case in 2050 relative to the Central Case, about 330 gigawatt hours (GWh), is equivalent to
avoiding the construction of about 124 MW of solar PV or 97 MW of onshore wind resources.
4.4.3 Partial Electrification Case Results
In the Partial Electrification case, electric technology market share is smaller and increases later
than in the Central Case. Figure 4.19 shows the heat pump market shares for residential and
commercial space and water heating used for this case.
Figure 4.19 Heat pump market shares of new system sales in the Partial Electrification (green) and Central (red)
scenarios through 2050. Results for residential buildings are on the top and results for commercial buildings are on
the bottom. Results for space heating heat pumps are on the left and for water heating heat pumps are on the
right.
As a result of this slower uptake of electric options, the stock of natural gas systems remains
higher throughout the study period, as shown in Figure 4.20. (Compare with Figure 4.13 above.)
On-site pipeline gas use also remains higher through 2050, as shown in Figure 4.21.
To represent potential scaling of low-carbon gaseous fuels in this case, we have increased the
amount of biomethane and synthetic natural gas distributed using the pipeline gas system from
zero in 2030 to 19.4 TBTU in 2045. This is enough to fully replace fossil gas in 2045. As pipeline
gas use continues to fall after 2045, we assume all of the gas supplied is low-carbon gas. If we
optimistically assume that this gas has emissions equal to 5 percent of fossil natural gas
emissions, then the emissions trajectory for this case is as shown in Figure 4.22. For the
Oct. 11, 2022 Item #12 Page 185 of 560
147
purposes of cost estimation in the following section, we assumed that this low-carbon gas has
an average cost of $30 per MMBTU.i This cost reflects the limited quantity of fuel required and
thus the ability of biomethane to meet some or all of the demand.
Figure 4.20 Space and water heating stock in the Partial Electrification scenario through 2050. Residential results
are on the top and commercial results are on the bottom. Space heating results are on the left and water heating
results are on the right. Sales are denoted in floor space (million ft2).
i We also assumed that fossil gas would have the Henry Hub spot price projected by the Annual Energy Outlook
2021 published by the U.S. Energy Information Administration.
Oct. 11, 2022 Item #12 Page 186 of 560
148
Figure 4.21 Pipeline gas consumption (in TBTU) in the Partial Electrification (green) and Central (red) scenarios.
Figure 4.22 Onsite GHG emissions in the Partial Electrification scenario (in million metric tons of carbon dioxide,
MMT CO2), reflecting increasing use of low-carbon fuels in place of pipeline gas starting in 2030 and complete
replacement of fossil gas with low-carbon fuels in 2045 and later.
4.4.4 Capital and Energy Costs
Each decarbonization scenario considered here results in substantial changes in household and
business spending on heating systems, water heaters, and the fuel and electricity to operate
those systems. Space heating heat pumps displace the need to pay for separate air conditioning
and furnace systems, thus offering substantial cost savings on purchasing other equipment.
Heat pump water heaters are more expensive upfront than traditional electric resistance or gas
storage water heaters, but cost less to operate.
Maintaining delivery infrastructure and procuring low- to zero carbon energy sources to reliably
meet demand drive fuel and electricity costs.
Table 4.7 shows the present value of estimated capital and energy costs between 2021 and
2050 for each case, using a 3 percent real discount rate. Interestingly, the three scenarios have
almost indistinguishable present value costs—well within the margin of error of the numerous
cost assumptions they incorporate. As expected, the Partial Electrification case has lower
building system capital costs (because it depends on mature technologies), but fuel costs are
higher as a result of the need for low-carbon gas fuel. If low carbon gas became available at
scale and at costs well below $30 per MMBTU, this case would be distinctly less expensive than
shown here. Similarly, if low carbon gases are not available or only available at scale at costs
above $30 per MMBTU, the high electrification cases would be comparatively less expensive.
While the uncertainty is smaller, electricity costs could have a similar effect. This analysis uses
long-term marginal electric supply costs from SDG&E’s integrated resource plan (approximately
Oct. 11, 2022 Item #12 Page 187 of 560
149
11 cents per additional kWh).45 Maintenance costs for space heating and water heating
equipment in buildings are not included within the estimated scenario costs. Heat pumps
typically have higher maintenance costs than natural gas space and water heating equipment.
However, the cost of maintenance is small—ranging from 2 to 8 percent of the total lifecycle
cost of the equipment46, 47—and would not change the overall economics of the
decarbonization scenarios.
The costs presented here are only the marginal costs associated with the electric and pipeline
gas systems under a case in which those systems continue operating at the current scale and
with the same regulatory treatment. Therefore, these costs do not reflect the potential to
reduce gas system costs in the electrification cases, which are discussed in the following
section; they also do not include the cost of gas piping in new construction. Additionally, the
scenario costs include neither health and safety upgrades that may be needed at the time of
equipment replacement, which are societal costs. The ways in which costs are spread among
customers is a matter of public policy and are not considered here. These considerations may
include incentives, weatherization and utility demand-side management programs, rate design,
and tax policy.
Table 4.7 Present value capital and energy costs under three decarbonization scenarios (in billions of $2021).
Central Low Demand Partial Electrification
Capital costs
Res. space heating $12.8 $12.8 $11.7
Res. water heating $2.9 $2.9 $2.7
Comm. space heating $7.4 $7.4 $7.4
Comm. water heating $0.5 $0.5 $0.4
Electric upgrades $0.6 $0.6 $0.4
Energy costs
Electricity $6.3 $6.1 $4.8
Pipeline gas $2.0 $2.0 $5.2
Total $32.4 $32.2 $32.7
4.4.5 Health, Environmental, Equity, and Economic Co-Benefits
Equitable policymaking for building decarbonization can help address existing social disparities
in the San Diego region. Populations of concern for building decarbonization include
communities with lower incomes, communities of color, and areas with high pollution
exposure. Low-income households already face high energy cost burdens; due to capital
limitations that may prohibit electrification, they are also at risk of being left to bear otherwise
stranded costs for existing natural gas systems. Communities of color have higher rates of
housing rental48 and are adversely impacted by substandard residences due to the history of
Oct. 11, 2022 Item #12 Page 188 of 560
150
redlining in the San Diego region.49 For these reasons, residents in areas with high pollution
exposure are at heightened risk for adverse health impacts associated with combustion of fossil
fuels in buildings. Building decarbonization across these communities of concern can create
resilient and reliable buildings, reduce energy costs to occupants, improve residents’ wellbeing,
alleviate impacts of climate change, and create high-quality jobs.
Reducing use of fossil fuels in buildings not only decreases greenhouse gas emissions, but also
reduces indoor and outdoor air pollutants that contribute to and exacerbate a variety of
negative health and environmental impacts.50, 51 This includes a range of pollutants: nitrogen
oxides (NOX), carbon monoxide (CO), methane (CH4), nitrous oxide (N2O), volatile organic
compounds (VOC), trace amounts of sulfur dioxide (SO2), and particulate matter (PM). Further,
these combustion byproducts include precursors of ground-level ozone or photochemical smog.
As a result, decarbonization of building heating and water heating would provide additional co-
benefits for air quality.
Such reductions in indoor and outdoor air pollution would improve health outcomes in the San
Diego region. The associated benefits include lower rates of mortality, cardiovascular disease,
respiratory disease, emergency room visits, restricted physical activity, and lost work. Recent
work underscores this need, showing the prevalence of unvented combustion in communities
of concern in California and negative health impacts that this can cause.52
Replacing existing gas heating equipment with heat pumps will also add cooling to houses that
do not already have cooling equipment. Thus, space heating electrification could reduce heat-
related illness in the region, an increasing risk due to climate change. According to the 2019
RASS, approximately one-third of households in the SDG&E service territory do not have air
conditioners9 and policies to replace fossil fuel-based space heating systems can target these
households to offer both heating and cooling effects in an equitable way.
The barriers to retrofitting existing housing in communities of concern can be substantial,
necessitating policies and programs to help ensure equitable access to decarbonization
technologies among residents in the San Diego region. Without targeted action by policymakers
and community leaders, historical inequities in access to energy efficiency, renewable energy,
and other decarbonization technologies are likely to persist.53 Initiatives should be developed in
conjunction with local communities of concern and tailored to those communities’ needs and
circumstances.54 Investing in retrofits for these communities can reduce energy costs for
residents, improve pollution exposure, and provide an opportunity to address deferred
maintenance and other safety issues. Further, building decarbonization initiatives can create
jobs through paired investments in workforce development and training programs that target
Oct. 11, 2022 Item #12 Page 189 of 560
151
residents of frontline communities where building investments are most needed.i
4.5 Gas Utility and Rate Impacts
4.5.1 Introduction to Utility Finance and Economics
No matter which pathway is pursued, decarbonizing the San Diego region’s buildings will
transform the business of the gas utility, SDG&E. In any scenario, SDG&E will transport much
less gas to homes and businesses than it does today. This section focuses on the economics and
business model of the gas utility portion of SDG&E. SDG&E as an enterprise also has the ability
to coordinate its electric utility planning with changes on the gas side.
Planning for decreased gas system utilization can reduce the financial impact of SDG&E’s
transformation on ratepayers, and particularly on low-income households. Increased planning
would also decrease the risk of supply issues in the gas and electric utilities. In doing so, SDG&E
can better help the region achieve its deep decarbonization goals. This analysis focuses on the
utility as a business because of the nature of the relationship between a regulated utility and
the residents for whom it provides services. The financial health of the region’s monopoly
electric utility, as well as the safety of its electric and gas systems, are important to both
residents and the utility’s investors.
SDG&E, like all investor-owned regulated utilities in the United States, is allowed to earn a rate
of return based on the amount of capital it has invested in transmission and distribution assets
that serve its customers. Under cost of service ratemaking, which is the standard approach
across the United States, the utility’s rates are designed to recover the company’s “revenue
requirement”—the amount of money it must collect from customers each year to pay for that
year’s depreciation of its assets, cover operating costs, and leave a “just and reasonable” return
on invested capital for its bondholders and shareholders. Gas rates are composed of the
delivery rate, which covers the cost of the local transmission and distribution systems, and the
supply rate, which covers the cost of the commodity fuel that flows through the pipes. SDG&E
does not make any profit on the supply rate – it simply passes fuel costs through as an
operating expense.
Changes in how pipeline gas is used in the San Diego region will cause substantial change in
how this business model functions. If the utility maintains its full gas system and invests in that
system as it has historically done, while gas sales fall, it will need to raise the rates it charges
per unit of gas to recover its full revenue requirement. If it doesn’t raise rates sufficiently, its
returns to investors will fall. However, as the gas utility raises rates, more customers may
i Employment impacts are addressed in Chapter 6 of this report.
Oct. 11, 2022 Item #12 Page 190 of 560
152
choose to use electricity instead of gas, to lower their energy bills. At the same time, greater
utilization of the electric system, if achieved without creating new peak-related costs, would
allow electric rates to decline. Combined, these rate effects would create an accelerating
departure from the gas system, as continued electrification would accelerate the rate
differential.
Delivery rate increases could be mitigated by retaining a larger amount of pipeline gas sales.
However, meeting the region’s emissions reduction goals with such quantities would require
the remaining sales be low-carbon fuel, which is much more expensive than fossil natural gas.
As a result, the supply portion of gas rates would increase substantially.
Low-income customers and tenants are particularly vulnerable to accelerating gas rate
increases because these households have the least ability to invest in changes in their home’s
water and space heating systems to mitigate rate changes. A clear transition path for the gas
utility would allow for improved opportunities to transition low-income households and tenants
to all-electric homes while mitigating the financial burden on these households. The gas utility’s
transition path is also particularly important to the utility employees and contractors who
install and maintain the gas pipeline infrastructure. In all scenarios considered in this analysis,
the gas system continues to have some role, and associated maintenance, for many years.
Nonetheless, having a clear plan would allow the utility and policymakers to support retraining
for employees and help them find comparable jobs in the construction, electric, and renewable
energy sectors.i Understanding the dynamics and timing of rate increases and gas customer
economics is essential to managing the equitable and just transition from the gas system into a
decarbonized future.
4.5.2 Scenario Results without Mitigation
To investigate the impact of changes in gas sales and the number of gas customers as residents
and businesses decarbonize their buildings, we modeled SDG&E’s gas utility revenue
requirements (in total and per customer), rate base, and rates in both the Central and Partial
Electrification cases.ii In both cases, we did not apply any of the mitigating actions that we
detail below. In that way, these results present a bookend case, with higher rates and more
assets at risk than would be experienced in reality. We have also not modeled the impact of
electrification on electric rates and bills (which will also be strongly impacted by transportation
electrification).
Because we assumed no mitigating actions, SDG&E’s total revenue requirements (other than
i More information about on job retraining is covered in Chapter 6 of the report.
ii The Low Demand Case differs from the Central Case only in its electric demand, so we have not addressed it
separately here.
Oct. 11, 2022 Item #12 Page 191 of 560
153
the cost of fuel) and rate base are not affected by the scenario. In both cases, we assume that
SDG&E continues to add new customers through 2036 (albeit at a declining rate) and continues
to replace aging assets at the current pace. It maintains the full extent of its gas pipeline
system. Figure 4.23 shows the resulting revenue requirement for the regulated gas delivery
business (that is, not including the cost of fuel), while Figure 4.24 shows the utility’s rate base. i
In both cases, we have adjusted to real 2020 dollars to eliminate the effect of underlying
inflation.
Where the scenarios differ are in three further aspects: the cost of fuel, the number of
customers, and the amount of fuel delivered. As shown in Figure 4.25, adding the cost of fuel to
the delivery revenue requirement (dashed yellow line) results in the Partial Electrification
(green) and High Electrification (red) trajectories.ii
Figure 4.23 Gas utility revenue requirement (in million 2020$) for delivery services through 2050 in both the
Central and Partial Electrification scenarios.
i Rate base is the amount of unrecovered assets on which the utility earns its return for shareholders. It generally
equals the undepreciated (remaining) value of the utility plant in service, adjusted by the tax treatment of
depreciation.
ii The fossil gas prices used here reflect projections from the U.S. Energy Information Administration’s 2021 Annual
Energy Outlook and do not reflect the recent increase in gas prices seen this winter. The change in prices
observed recently, if sustained into the future, would increase costs.
Oct. 11, 2022 Item #12 Page 192 of 560
154
Figure 4.24 Gas utility rate base (million 2020$) through 2050 in both the Central and Partial Electrification
scenarios.
Figure 4.25 Gas utility revenue (million 2020$), including fuel costs, for the Central (red) and Partial Electrification
(green) scenarios. The delivery revenues only are the same for both scenarios and are shown in the dashed yellow
line. The difference between the dashed line and the solid lines reflects the fuel costs.
To estimate the trajectory for delivered gas rates in each case, we divided the total revenue
requirement by the total sales of pipeline gas in each case. This results in the forward rate
curves shown in Figure 4.26. While the Partial Electrification case has lower rates than the
Central Case, it still shows rates that far exceed today’s average gas rates of just over $1 per
therm. Both cases have rates that exceed $2 per therm by the 2030s (2033 in the Central Case
Oct. 11, 2022 Item #12 Page 193 of 560
155
and 2038 in the Partial Electrification case). These higher per-unit rates could encourage
customers to choose to heat with electricity, absent policy intervention to change the relative
costs of fuels.i
However, customers do not pay rates–they pay bills. Therefore, it is necessary to multiply the
rates by the average consumption per customer to evaluate the impact of each scenario on the
total annual energy costs of the customers who remain connected to the gas system. Figure
4.27 shows the resulting energy bills.
Figure 4.26 Forward gas rate curves (measured in 2020$ revenue per therm) for the Central (red) and Partial
Electrification (green) scenarios.
i This analysis uses the total revenue requirement divided by total sales as a proxy for rate impacts. We do not
distinguish between rate classes, and we do not distinguish between the monthly customer charge and the
marginal rate for consumption, which each send different signals that shape customer behavior. Rate designs
that shift more costs into the monthly customer charge would strengthen gas in marginal competition with
electricity for each end use, while simultaneously giving customers a stronger incentive to fully disconnect from
the gas network.
Oct. 11, 2022 Item #12 Page 194 of 560
156
Figure 4.27 Average annual customer bills (2020$ per customer) for gas customers in the Central (red) and Partial
Electrification (green) scenarios. This can be compared to the increase in electric utility bills from a home switching
from gas to all-electric (blue dashed).
These bills illustrate the challenge facing SDG&E and its stakeholders as it plans a path forward:
in both cases, the cost of gas service per customer increases substantially. While gas customer
bills in the Partial Electrification scenario are lower than in the Central Case, in both cases they
rise to far exceed the bills for equivalent service provided with all electric appliances (Figure
4.27, dashed blue line).i Low-income households are particularly vulnerable to the increasing
gas bills because they will struggle more to invest in electric space and water heating. This
energy burden becomes increasingly impactful as the annual all-electric home bill remains
relatively constant and the gas bills in both the Central and Partial Electrification cases continue
to rise.
Our analysis indicates that, absent policy intervention or mitigating actions, the level of
electrification in 2050 in the Partial Electrification case is not a stable equilibrium. The customer
savings from switching to electricity will continue to increase as more customers electrify,
which will in turn drive further electrification. While some households will face barriers to
electrification, the increasing savings will overcome more and more of those barriers.
4.5.3 Mitigation Approaches
SDG&E, its owners, and its regulators have numerous options to evolve the utility’s practices
and business model to mitigate the rate trajectories that would result from decarbonization.
i The exact customer economics depend on rate design for both gas and electric utilities. Figure 4.27 reflects the
relevant per-customer costs of service (accounting for the fact that building electrification will not drive changes in electric transmission and distribution costs), as a proxy for the costs that would be assigned to each customer
under a reasonable rate design.
Oct. 11, 2022 Item #12 Page 195 of 560
157
The objectives of these approaches would be to more equitably share the cost of the existing
gas system between today’s customers and future customers, as well as to limit the risk to
residents and investors that the utility will leave substantial stranded assets. Stranded assets
are investments that the utility made but which are retired before their full asset value has
been recovered (see Figure 4.28 for an illustration of stranded assets).
The cost of stranded assets could be passed to utility investors, which would risk the financial
viability of the company. This is not optimal because San Diego residents require SDG&E to be a
viable enterprise to continue to provide electric service (at least), and financial difficulties
threaten service to any remaining gas customers. Safety of the electric and gas systems could
also decline in such a case. The value of some stranded assets could instead be recovered from
electric ratepayers or from taxpayers. Both approaches would require changes in fundamental
approaches to utility ratemaking. One option would be securitization, wherein stranded assets
are bought out by a public bond-backed entity with a lower cost of capital (thus lowering the
total funds to be recovered), and then the bond is paid back over an appropriate timeframe
using electric ratepayer funds or tax revenues. California is using securitization to address
electric utility costs associated with wildfire risk reduction.i
To limit the risk from and the amount of stranded assets whose fate must be resolved in
groundbreaking ways, utility financial and infrastructure practices could be changed in the near
term.ii These approaches would have different effects on the utility’s annual revenue
requirements. In some cases, stranded cost risks are mitigated by recovering funds sooner,
while there is still extensive use of the gas system. In other cases, actions mitigate risks by
reducing the size of the total investment at risk. Some actions do not change the total size of
the investment or stranded cost risk, but they can mitigate rate impacts and thereby buy
breathing room to use rates to recover invested capital. In each case below, we change one
aspect of the utility’s action or accounting to illustrate the impact of each change. In reality, the
utility’s management, along with its investors, regulators, and other stakeholders, would
develop a portfolio of actions to best achieve their objectives.
i See, for detail, California Assembly Bill 1054 (passed 2019) and California Public Utilities Code, Sec. 8386.3.
ii One resource to learn more about the options discussed here, and others, is Managing the Transition: Proactive
Solutions for Stranded Gas Asset Risk in California by Bilich, Colvin, and O’Connor (2019) for the Environmental
Defense Fund (available at https://www.edf.org/sites/default/files/documents/Managing_the_Transition_new.pdf ) While the analysis in
this report differs somewhat from that study, the general conclusions and analysis are compatible.
Oct. 11, 2022 Item #12 Page 196 of 560
158
Figure 4.28 Illustration of the amount of stranded asset risk when an asset is no longer used and useful, before the
end of its planned lifetime. Source: Bilich, Colvin, and O’Connor (2019). “Managing the Transition: Proactive
Solutions for Stranded Gas Asset Risk in California.” Environmental Defense Fund. Reproduced with permission.
4.5.4 Accelerated depreciation
Depreciation is the process by which a utility under cost of service regulation recovers the costs
of its investment in assets over the lifetime of the assets. Gas utility assets are generally
depreciated over their expected engineering lifetime—as many as 70 years for new plastic
pipes, for example. However, for intergenerational fairness, this approach assumes that the
pipes will carry roughly the same amount of gas each year throughout their lifetimes. As the gas
sales trajectories shown in this chapter illustrate, this assumption no longer holds. Accelerating
the recovery of the invested capital in the gas system (e.g., so that it would fully recover by
2045) would reduce stranded cost risk, at the cost of higher gas rates in the near term.
Regardless of the treatment of depreciation, long-term gas rates would still rise with falling
sales, as long as operations and maintenance costs of the system do not fall along with sales (in
inflation-adjusted terms).
Figure 4.29 shows the approximate revenue requirement trajectory for SDG&E under an
accelerated depreciation scenario (Figure 4.29, blue solid line), compared with the traditional
depreciation approach (Figure 4.29, red dashed line).i This scenario was developed by setting
the minimum depreciation rate for any asset type to 4 percent (equivalent to a 25-year
depreciation period if there were no removal cost). Revenue requirements, and therefore rates,
i These results are the same for the Central and Partial Electrification cases.
Oct. 11, 2022 Item #12 Page 197 of 560
159
are higher in the near term with accelerated depreciation, as expected.
Figure 4.30 shows SDG&E’s projected rate base with and without accelerated depreciation. The
rate base rises and then falls in the accelerated depreciation case, as the utility continues to
make its historical pattern of capital investments. However, the value of rate base at risk in the
gas utility transition is reduced substantially—by more than $1.4 billion in 2050.
Figure 4.29 Gas utility revenue requirement (million 2020$) with and without accelerated depreciation (blue, solid
line and red, dashed line, respectively).
Figure 4.30 Gas utility rate base (million 2020$) with and without accelerated depreciation (blue, solid line and red,
dashed line, respectively).
One minor, but impactful, change to depreciation practice could be eliminating recovery of
funds to cover gas asset removal upon retirement. Standard depreciation practice recovers not
just the amount invested in the pipe, but also the net cost of removal of the pipe at end of life.
Oct. 11, 2022 Item #12 Page 198 of 560
160
Because this action is expected to occur far in the future (when inflation will have raised the
cost of removal), the removal cost can approach, or even exceed, the value of the asset itself.
As a result, depreciation costs can be almost twice as large as they would otherwise be. If
policymakers decide that gas pipes could be retired and abandoned in place without removal
(or that removal costs would be borne by future taxpayers), regulatory financial calculations
could adjust, lowering gas rate pressures and creating room for accelerated depreciation or
other approaches.
4.5.5 Limiting capital investment
Another approach to limiting stranded cost risk is to limit the total amount of assets the utility
has invested. Because past investments have already been made, the point of impact here has
to do with the rate of new asset investment. SDG&E invests in assets for two primary purposes:
(1) to extend pipes to serve new customers, and (2) to replace old or damaged assets.
Addressing these two drivers would require policy changes tailored to each.
First, investment in pipes to reach new customers would be shaped by whether new customers
demand gas service. If new construction is all electric, there would be no such investment.
Other approaches, such as requiring customers that require a line extension to cover the full
cost themselves, could also limit shareholder and other shared risk from these assets. The
Central Case includes continued, but slowing, expansion of gas service to new customers (about
44,000 by 2030 and about 2,000 after). Figure 4.31 shows the impact of not expanding gas line
investments to reach these new customers on the baseline trajectory of SDG&E’s rate base.
Forgoing these additions reduces the utility’s rate base by about $400 million in 2050.
Figure 4.31 Gas utility rate base (million 2020$) with and without new customer additions (red and blue lines,
respectively).
Oct. 11, 2022 Item #12 Page 199 of 560
161
Second, most of SDG&E’s capital investments relate to replacing old assets with equivalent new
ones. These replacements occur both reactively (to address actual leaks or damage to pipes)
and proactively by SDG&E to improve pipeline safety and reduce leaks. We have not assessed
the necessity of SDG&E’s pipeline replacements. However, to indicate the potential ratepayer
impact of slowing the pace of these replacements (which could correspond to targeting
replacement only to the most urgent locations), we modeled a reduction in the pace of these
replacements by a factor of three. The results are shown in Figure 4.32. This figure also shows
the combined effect of eliminating new gas lines and reducing investment in existing asset
replacement by a factor of three. Together, these changes would reduce the utility’s rate base
at risk in 2050 by $1.15 billion.
Figure 4.32 Gas utility rate base (million 2020$) with Central Case findings (red line), reduced pipeline and service
replacement rate (blue line), and combination of reduced replacements and no new customer additions (purple
line).
4.5.6 Targeted system retirements
One way to reduce the need for new capital investment, while also reducing operation and
maintenance costs, would be to retire gas system assets instead of replacing them, as seen in
Figure 4.33. By targeting all buildings served by a particular gas system asset for electrification,
that gas asset can be retired. Targeted retirement likely represents a more cost-effective way to
manage the gas transition than replacing assets in the face of declining sales.
Oct. 11, 2022 Item #12 Page 200 of 560
162
Figure 4.33 Illustration of the gas infrastructure implications of targeted vs. untargeted electrification. Source: Asa
et al., 2020. “The Challenge of Retail Gas in California’s Low-Carbon Future: Technology Options, Customer Costs,
and Public Health Benefits of Reducing Natural Gas Use.” E3 for the California Energy Commission.
However, the pace of natural system replacements in the San Diego region is much slower than
the pace at which the system might be abandoned, particularly under a High Electrification
decarbonization pathway. SDG&E currently replaces an average of about 33 miles of
distribution main pipes per year. We estimate that SDG&E also replaces about 1,400 service
lines each year.i If the customers served by these mains and services were electrified rather
than the repiped, it would decrease the utility’s stranded cost risk by reducing its new
investments.
While targeting electrification to the areas of pipe replacement would reduce stranded cost risk
by limiting new capital investment, it does not eliminate the issue. Targeted electrification and
pipeline retirement should also reduce operation and maintenance costs since there are fewer
miles of pipe to maintain, which could allow for either lower rates and thus a stronger
competitive position vs. electricity (thus allowing departures and sales reductions to be more
measured and planned) or for more room in constant gas rates to recover asset value
otherwise left stranded.
Figure 4.34 illustrates the impact on the utility’s revenue requirements for gas distribution
service (not fuel supply) in the Central Case if targeted electrification and mains retirement
substituted for mains replacement and if customers due for new service lines were electrified
instead. As modeled, both transitions in utility practice would ramp in over the next decade. In
this example, we have also modeled no new customer additions. In this case, the utility’s rate
i Services are the small pipes that connect customers to the distribution mains.
Oct. 11, 2022 Item #12 Page 201 of 560
163
base in 2050 would be about $1.4 billion less than in the unmitigated case (Figure 4.32).
Targeted electrification, which would involve retiring distribution mains not due for
replacement, would create stranded costs that would need to be addressed in some fashion.
Targeting electrification toward communities of concern could limit the risk that these
populations face from increasing gas rates.
Figure 4.34 Gas utility delivery revenue requirement (without fuel costs, million 2020$) in the Central case (red)
compared with a case where electrification is targeted to allow the utility to avoid rebuilding or replacing aging
distribution mains (blue). The targeted electrification results also include no new customer additions.
4.6 Key Policy Actions
Taking actions immediately represents the best way to put San Diego’s buildings on a course for
decarbonization by mid-century. This timeframe is driven by the long lifetime of building
components such as HVAC systems and water heaters, along with the relatively nascent state of
the market for efficient low-carbon technologies that can reduce direct emissions from the
region’s buildings. By taking action that changes markets swiftly, local policymakers will reduce
the future costs of early equipment replacement and stranded assets. While the end state for
the region’s buildings remains unknown, the initial steps policymakers can take are common
across all pathways and are “low regret” policy choices. These include:
Equity: Leading with communities of concern as part of the market transformation can mitigate
risks of communities being left behind and avoid social costs of helping them transition later.
Investments in building energy efficiency and decarbonization provide an opportunity to
simultaneously address deferred maintenance and existing health and safety issues in existing
buildings, which are more common in buildings occupied by low-income families and
communities of color. Financial support—such as incentive programs, grants, and low-interest
Oct. 11, 2022 Item #12 Page 202 of 560
164
loans—will facilitate decarbonization of low-income housing and buildings for which owners
face financial hardship. Paired investments in workforce development and job training
programs that target residents can simultaneously create good-paying jobs.
Electrification: Increasing adoption of efficient heat pump-based space and water heating
systems in both new and existing buildings, with particular focus on assistance for communities
of concern and rental buildings, is a key first step. Approaches can focus on early replacement
or end-of-life replacement based on the condition of existing space heating, water heating, and
cooling systems.i Market forces alone cannot ensure a timely transition away from fossil fuel
combustion in buildings. Examples of strategies to achieve broader electrification include
building codes and ordinances to require electrification or “electrification readiness,” appliance
replacement incentives, subsidized building retrofit programs, and building emissions
performance standards. Building shell improvements, such as insulation and air sealing, can
help reduce electric system demand peaks and manage system costs associated with building
electrification. Other uses of fossil fuels in buildings—cooking, laundry, and process loads—will
need to be addressed and can typically be electrified as well. Policymakers can look to examples
of building electrification efforts across the country, as cataloged by various organizations
including the American Council for an Energy-Efficient Economy, the Building Electrification
Institute, the New Buildings Institute, the Institute for Market Transformation, and more.
Statewide building codes: The region can benefit from state-level action by working with state
regulators and actively participating in the California Energy Commission’s stakeholder process
to support building energy efficiency standards (Title 24) that prioritize building
decarbonization. Efficient construction will be more costly in some circumstances; however,
high-performance buildings have lower utility costs, which can result in equal or lower monthly
costs when considering rent or mortgage and utilities. Further, all-electric buildings save
substantial gas hookup and plumbing costs. See Chapter 8 for a discussion of the local authority
to establish building codes. Where local jurisdictions do not have authority, collective
participation in state rulemaking processes may be useful.
Local building codes: Setting local “electrification-ready” or “all-electric” standards for new
construction and major renovations through building energy codes would reduce costs
associated with transitioning away from fossil fuels. Policymakers can benefit from lessons
learned in the adoption of all-electric reach codes or ordinances—which are local codes or
ordinances that go beyond state or federal requirements—in the cities of Carlsbad, Encinitas,
and Solana Beach. Local jurisdictions have authority to mandate electrification or expressly
prohibit natural gas plumbing in buildings if all statutory requirements are met. For more
information on local authority, see Chapter 8 of this report.
Existing buildings: Programs and policies must target eliminating combustion of fossil fuels in
existing buildings, which turn over slowly and will continue to generate emissions for decades if
left unchecked. Approximately 80 percent of the buildings that will exist in 2050 in the region
i The end of life of an existing air conditioning system provides an opportunity to replace it with a heat pump and
simultaneously eliminate existing fossil fuel heating equipment.
Oct. 11, 2022 Item #12 Page 203 of 560
165
have already been built. Energy efficiency improvements can reduce emissions associated with
electricity use in existing buildings; however, this opportunity decreases as electricity
generation approaches 100 percent carbon-free. Therefore, electrification should also be a
focus for existing buildings. Market barriers to electrifying the existing building stock include
initial cost hurdles, consumer preferences and awareness, and workforce development needs.
An integrated strategy for existing buildings should include:
• Education and outreach to inform residents and building owners and catalyze local
action. Public resources should inform the community of local and regional
decarbonization initiatives and guide building owners to financial support, technical
assistance, and decarbonization programs. Building owners may need assistance
planning for future conversion of combustion equipment away from fossil fuels; planning
and education efforts should focus on end-of-life equipment replacement. See also the
paragraphs below on education and outreach.
• Financial incentives and financing for building electrification and energy efficiency
retrofits. Low-income homeowners and building owners facing financial hardship may
need extra support. Point-of-sale discounts can support the transition to efficient electric
equipment. By expanding property assessed clean energy (PACE) financing options in the
region and providing utility-meter-tied financing, local agencies can ensure building
owners are not burdened with repayment of costs beyond the duration of ownership.
Local, regional, or state revolving loan funds may provide lower interest loans than
traditional private financing for building retrofits.
• Mandatory energy information disclosure such as (1) disclosure of energy use data and
equipment systems at the time of sale or lease, or (2) mandatory energy reporting for
large buildings like the City of San Diego’s Building Energy Benchmarking Ordinance.
• Energy audits to identify energy and emissions reduction opportunities for buildings.
Programs to defray the cost of audits could be funded publicly or through ratepayer’s
bills.
• Mandatory emission reduction requirements such as building performance standards or
prescribed fuel switching. These requirements can be aligned to the emission reduction
goals of individual jurisdictions or the overall Regional Decarbonization Framework.
• Local government leadership, such as setting aggressive targets for the decarbonization
of publicly owned buildings. Local leadership can showcase the commitment of public
entities to climate action, provide an early market signal to contractors and equipment
suppliers, and create case studies for others to follow. State and federal agencies that
own buildings in the San Diego Region may already fall under governmental
commitments to early decarbonization and can be partners for local government.i
i Note that local government agencies may not have the authority to require State and federal agencies to reduce
Oct. 11, 2022 Item #12 Page 204 of 560
166
Gas pipelines: Utilities and regulators can mitigate stranded cost risk by minimizing
unnecessary extensions or replacements of the gas pipeline system and by aligning
depreciation of existing utility assets with their utilization lifetimes.
Geographic targeting: Focusing electrification and targeting retirement of gas pipeline
segments (e.g., in neighborhood clusters) can help optimize available resources and reduce
ratepayer burden for maintaining the gas distribution network.
Regional coordination: Accomplishing deep decarbonization of the buildings sector requires
action by a diverse set of stakeholders in the region. Regional coordination, such as through
existing or new governance structures, may help to sustain progress over time. For more
discussion of this, see Chapter 7 of this report.
Low-carbon fuels: Research and pilot production and use of low-carbon gaseous fuels can
prepare the region to decarbonize hard-to-electrify end uses in buildings.
Co-benefits: When evaluating prospective policies and programs, consider the full range of
benefits created by building decarbonization, such as improved environmental and human
health and equitable job creation.
Education: Inform building owners of the financial risks of installing new fossil fuel equipment,
which may need to be replaced before the end of its useful life to meet regional
decarbonization targets and may expose building occupants to high future gas rates. Teach
owners about the co-benefits of eliminating fossil fuel combustion in buildings. Building owners
with harder-to-decarbonize end uses may need resources and technical assistance to achieve
full decarbonization. Expand building operator certification programs, with specific curriculum
for building decarbonization and carbon-intensive end uses.
Outreach: Leverage the existing Regional Energy Network and community choice aggregation
platform to promote building electrification through outreach, engagement, and direct
enrollment. Look to building electrification initiatives among the following California providers
for guidance: Central Coast Community Energy, East Bay Community Energy, MCE, Peninsula
Clean Energy, Redwood Coast Energy Authority, Silicon Valley Clean Energy, Sonoma Clean
Power, and Valley Clean Energy.
Information gathering: Improve existing data collection practices to inform future policies and
programs. Local governments can begin identifying the fuel type for space heating and water
heating systems and the capacity of electrical panels. This information can be collected through
building permits and other administrative processes and can be mapped to existing property
databases. Further, building energy benchmarking practices can lay the foundation for building
performance standards, which establish mandatory energy or emissions targets that improve
over time. Cities can expand on the example of the City of San Diego’s building energy
benchmarking ordinance and lead by example by disclosing energy information for public
emissions in local buildings.
Oct. 11, 2022 Item #12 Page 205 of 560
167
buildings.55 Finally, collecting equity-related metrics is foundational to designing equitable
initiatives and monitoring progress.
Embodied carbon: Targeting embodied carbon (the carbon intensity of building materials) in
buildings through zoning or building codes can complement policies focused on operational
carbon from energy use in buildings. Local policymakers can consider adopting “buy clean”
policies such as Marin County’s Low Carbon Concrete Codei or work with state regulators to
build on existing statewide legislation, including the Buy Clean California Act.
i See, for details, Marin County Code Chapter 19.07 Added To Marin County Code Title 19, available at
https://www.marincounty.org/-/media/files/departments/cd/planning/sustainability/low-carbon-
concrete/12172019-update/low-carbon-concrete-code.pdf?la=en.
Oct. 11, 2022 Item #12 Page 206 of 560
168
Works Cited:
1. U.S. Census Bureau. 2021. County Population Totals: 2010-2019. Available at:
https://www.census.gov/data/tables/time-series/demo/popest/2010s-counties-
total.html#par_textimage_242301767.
2. U.S. Census Bureau. 2021. 2019 County Business Patterns. Available at: https://www.census.gov/programs-
surveys/cbp.html. Synapse review of property data provided by San Diego County Assessor's Office
3. The City of San Diego. 2007. San Diego Modernism Historic Context Statement. Available at:
https://www.sandiego.gov/sites/default/files/modernism_2007.pdf.
4. Sutro, Dirk. 2002. San Diego Architecture from Mission to Modern: Guide to the Buildings, Planning, People,
and Spaces That Shape the Region. American Institute of Architects | San Diego. Sunbelt Publications.
5. University of San Diego. 2021. Indian Reservations in San Diego County. Available at:
https://www.sandiego.edu/native-american/reservations.php
6. U.S. Census Bureau. 2021. 2020 Census - Census Tract Reference Map. Available at:
https://www.census.gov/geographies/reference-maps/2020/geo/2020pl-maps/2020-census-tract.html.
7. DATA.GOV. 2021. Military Installations, Ranges, and Training Areas. Available at:
https://catalog.data.gov/dataset/military-installations-ranges-and-training-areas.
8. County of San Diego. 2018. Greenhouse Gas Emissions Inventory, Projections, and Reduction Targets. Available
at:
https://www.sandiegocounty.gov/content/dam/sdc/pds/advance/cap/publicreviewdocuments/CAPfilespublicr
eview/Chapter%202%20Greenhouse%20Gas%20Emissions%20Inventory%2C%20Projections%20and%20Reduct
ion%20Target.pdf. 9. DNV GL Energy Insights. 2021. 2019 California Residential Appliance Saturation Study (RASS). Available at:
https://www.energy.ca.gov/data-reports/surveys/2019-residential-appliance-saturation-study.
10. City of San Diego. Building Energy Benchmarking. Accessed September 23, 2021.
https://www.sandiego.gov/sustainability/energy-and-water-efficiency/benchmark.
11. City of San Diego. Building Energy Benchmarking. Accessed September 23, 2021.
https://www.sandiego.gov/sustainability/energy-and-water-efficiency/benchmark.
12. U.S. Energy Information Administration (EIA). 2013. Commercial Buildings Energy Consumption Survey (CBECS),
2012. Available at: https://www.eia.gov/consumption/commercial/data/2012/. EIA Form 176, Years 2005–
2019; Form 861 and 861S, Years 2005–2019 and Year 2020 early release.
13. Mahone, A., et al. 2018. Deep Decarbonization in a High Renewables Future. Prepared by Energy and
Environmental Economics for the California Energy Commission. Available at:
https://www.energy.ca.gov/publications/2018/deep-decarbonization-high-renewables-future-updated-results-
california-pathways.
14. Itron, Inc. 2014. California Commercial Saturation Survey Report. Prepared for California Public Utilities
Commission. Available at:
http://capabilities.itron.com/wo024/Docs/California%20Commercial%20Saturation%20Study_Report_Final.pdf
15. Armstrong, S., et al. 2019. A Zero Emissions All-Electric Multifamily Construction Guide. Redwood Energy.
Available at: https://fossilfreebuildings.org/ElectricMFGuide.pdf.
16. Mitsubishi . n.d., City Multi Brochure (CM11WD-I), p. 83, Available at:
https://www.mitsubishielectric.com.au/assets/LEG/MEE10K026_CM11WD_I_w.pdf.
17. Northeast Energy Efficiency Partnership (NEEP). 2019. Variable Refrigerant Flow (VRF) Market Strategies
Report. Available at:
https://neep.org/sites/default/files/resources/NEEP_VRF%20Market%20Strategies%20Report_final5.pdf.
18. Bonneville Power Administration. 2018. HVAC Technology Guide. Page 106. Available at:
https://www.bpa.gov/EE/Utility/Momentum-Savings/Documents/2018_BPA_HVAC_Technology_Guide.pdf.
19. Stagner, J.C. n.d. Stanford University’s “fourth generation” district energy system. Available at:
https://sustainable.stanford.edu/sites/default/files/IDEA_Stagner_Stanford_fourth_Gen_DistrictEnergy.pdf.
20. Northwest Energy Efficiency Alliance. 2014. Final Summary Report for the Ductless Heat Pump Impact and
Process Evaluation. Available at: https://neea.org/resources/final-summary-report-for-the-ductless-heat-pump-impact-and-process-evaluation;
Oct. 11, 2022 Item #12 Page 207 of 560
169
21.Cadmus. 2016, Ductless Mini-Split Heat Pump Impact Evaluation. Available at:
http://www.ripuc.ri.gov/eventsactions/docket/4755-TRM-DMSHP%20Evaluation%20Report%2012-30-2016.pdf
22. Schoenbauer, B. 2018. "Cold-Climate Air-Source Heat Pumps." Center for Energy and Environment. Available
at:
http://www.duluthenergydesign.com/Content/Documents/GeneralInfo/PresentationMaterials/2018/Day1/ccA
SHPs.pdf.
23. Mahone, A. et al. 2019. Residential Building Electrification in California - Consumer economics, greenhouse
gases and grid impacts. Energy and Environmental Economics. Available at: https://www.ethree.com/wp-
content/uploads/2019/04/E3_Residential_Building_Electrification_in_California_April_2019.pdf.
24. Air Conditioning, Heating, and Refrigeration Institute. 2021. Directory of Certified Product Performance.
Available at: https://www.ahridirectory.org/Search/SearchHome.
25. Mai, T. T. et al. 2017. Electrification Futures Study: End-Use Electric Technology Cost and Performance
Projections through 2050. National Renewable Energy Laboratory. Available at:
https://www.nrel.gov/analysis/electrification-futures.html.
26. E3. 2019. Residential Building Electrification in California - Consumer economics, greenhouse gases and grid
impacts. Available at: https://www.ethree.com/wp-
content/uploads/2019/04/E3_Residential_Building_Electrification_in_California_April_2019.pdf.
27. Jones, Betony. 2021. Los Angeles Building Decarbonization: Community Concerns, Employment Impacts,
Opportunities. Inclusive Economics.
28. U.S. EPA. 2021. “ENERGY STAR Certified Water Heaters.” Available at:
https://www.energystar.gov/productfinder/product/certified-water-heaters/
29. Delforge, Pierre and Swanson C. 2016. “Very Cool: Heat Pump Water Heaters Save Energy and Money.” NRDC.
Accessed September 27, 2021. Available at: https://www.nrdc.org/experts/pierre-delforge/very-cool-heat-
pump-water-heaters-save-energy-and-money;
30. Hopkins, Asa S., et al. 2018. Decarbonization of Heating Energy Use in California Buildings – Technology,
Markets, Impacts, and Policy Solutions, page 21. Available at: https://www.synapse-
energy.com/sites/default/files/Decarbonization-Heating-CA-Buildings-17-092-1.pdf. 31. Armstrong, S., et al. 2019; Bruce Sullivan. 2017. “CO2 Takes Heat Pump Water Heaters to the Next Level.”
Accessed September 27, 2021. Available at: https://zeroenergyproject.org/2017/05/22/co2-takes-heat-pump-
water-heaters-next-level/
32. Steven Groves. 2018. “Mitigating the Parasitic Effect of Heat Pump Water Heaters on Home Heating Systems in
Cold Climates” Fortis BC. Presentation at the 2018 ACEEE Hot Water Forum, March 21, 2018.
33. Carew, Nick. Et al. 2018. Heat Pump Water Heater Electric Load Shifting: A Modeling Study. Ecotope, Inc.
Available at: https://ecotope-publications-
database.ecotope.com/2018_001_HPWHLoadShiftingModelingStudy.pdf.
34. Ecotope. 2015. RCC Pilot Project: Multifamily Heat Pump Water Heaters in Below Grade Parking Garages in the
Pacific Northwest.
35. Alan Meier et al. 2018. University of California Strategies for Decarbonization: Replacing Natural Gas, p. 76.
Available at http://dms.hvacpartners.com/docs/1001/Public/0A/04-581025-01.pdf.
36. Gartman, M., S. Armstrong. 2020. “Heat Pumps for Hot Water: Installed Costs in New Homes”. Rocky Mountain
Institute and Redwood Energy. Available at: https://rmi.org/insight/heat-pump-hot-water-cost/
37. Jones, B.. 2021. Los Angeles Building Decarbonization: Community Concerns, Employment Impacts,
Opportunities. Inclusive Economics. Available at:
https://drive.google.com/file/d/117bFbCLccCdu316IJAIHkRyoLMhQTQd3/view.
38. U.S. Energy Information Administration. 2015. “Table HC3.8 Appliances in homes in the South and West
regions, 2015” Residential Energy Consumption Survey (RECS). Available at:
https://www.eia.gov/consumption/residential/data/2015/hc/php/hc3.8.php
39. IEA Bioenergy. 2017. Methane emissions from Biogas Plants. Available at:
https://task37.ieabioenergy.com/files/daten-
redaktion/download/Technical%20Brochures/IEABioenergy_Task%2037_methane_emissions_2Psummary.pdf.
40. E3, 2018. Deep Decarbonization in a High Renewables Future: Updated Results from the California PATHWAYS
Model. Prepared for the California Energy Commission. Available at
https://www.energy.ca.gov/publications/2018/deep-decarbonization-high-renewables-future-updated-results-
Oct. 11, 2022 Item #12 Page 208 of 560
170
california-pathways
41. U.S. Department of Energy, Office of Fossil Energy. 2020. Hydrogen strategy: enabling a low-carbon economy.
Available at:
https://www.energy.gov/sites/prod/files/2020/07/f76/USDOE_FE_Hydrogen_Strategy_July2020.pdf
42. E3. 2021. Maryland Building Decarbonization Study Final Report. Available at:
https://mde.maryland.gov/programs/Air/ClimateChange/MCCC/Documents/MWG_Buildings%20Ad%20Hoc%2
0Group/Maryland%20Buildings%20Analysis%20Slide%20Report.pdf.
43. University of Virginia Weldon Cooper Center, Demographics Research Group. (2018). National Population
Projections.
44. San Diego Gas & Electric Company. FERC FINANCIAL REPORT FERC FORM No. 1: Annual Report of Major Electric
Utilities, Licensees and Others and Supplemental Form 3-Q: Quarterly Financial Report for end of 2020/Q4.
45. San Diego Gas & Electric. 2020. Attachment A to the 2020 Integrated Resource Plan.
https://www.sdge.com/sites/default/files/regulatory/Attachment%20A_Cost%20Table%20%281%29_0.pdf
46. Mai, T. T. et al. 2018. Electrification Futures Study: Scenarios of electric technology adoption and power
consumption for the United States. National Renewable Energy Laboratory. Available at:
https://www.nrel.gov/docs/fy18osti/71500.pdf.
47. Jadun, Paige, Colin McMillan, Daniel Steinberg, Matteo Muratori, Laura Vimmerstedt, and Trieu Mai.
2017. Electrification Futures Study: End-Use Electric Technology Cost and Performance Projections
through 2050. Golden, CO: National Renewable Energy Laboratory. NREL/TP-6A20-70485.
https://www.nrel.gov/docs/fy18osti/70485.pdf.
48. U.S. Census Bureau. 2022. ACS 1-Year Estimates 1-Year Estimates-Public Use Microdata Sample, 2019. Available
at: https://data.census.gov/mdat.
49. Nelson, R.K., Winling, L., Marciano, R., Connolly, N. and Ayers, E.L., 2020. Mapping inequality: Redlining in new
deal America. American Panorama: An Atlas of United States History. University of Richmond: Digital
Scholarship Lab.
50. Lin, W., Brunekreef, B. and U. Gehring. 2013. Meta-analysis of the effects of indoor nitrogen dioxide and gas
cooking on asthma and wheeze in children. International journal of epidemiology, 42(6), pp.1724-1737. 51. Buonocore, J.J., Salimifard, P., Michanowicz, D.R. and J.G. Allen. 2021. A decade of the US energy mix
transitioning away from coal: historical reconstruction of the reductions in the public health burden of energy.
Environmental Research Letters, 16(5), p.054030.
52. Holm, S.M., Balmes, J., Gillette, D., Hartin, K., Seto, E., Lindeman, D., Polanco, D. and E. Fong. 2018. Cooking
behaviors are related to household particulate matter exposure in children with asthma in the urban East Bay
Area of Northern California. PloS one.
53. Fournier, E.D., Cudd, R., Federico, F., Pincetl, S., Iles, A. and D. Mulvaney. 2020. On energy sufficiency and the
need for new policies to combat growing inequities in the residential energy sector. Elementa: Science of the
Anthropocene, 8.
54. USDN. 2019. Facilitating Power, and Movement Strategy Center—From Community Engagement to Ownership:
Tools for the Field with Case Studies of Four Municipal Community-Driven Environmental & Racial Equity
Committees. Available at:
https://www.usdn.org/uploads/cms/documents/community_engagement_to_ownership_-
_tools_and_case_studies_final.pdf
55. City of San Diego. 2022. Building Energy Benchmarking. Available at:
https://www.sandiego.gov/sustainability/energy-and-water-efficiency/benchmark.
Oct. 11, 2022 Item #12 Page 209 of 560
171
5. Natural Climate Solutions and Other Land Use
Considerations
Elise Hanson, UC San Diego
Emily Leslie, Montara Mountain Energy
Key Takeaways
● Natural climate solutions (NCSs) are an important component of decarbonization
because they involve natural sequestration and medium to long-term storage of carbon
dioxide (CO2) in lands, but NCSs alone cannot sequester enough CO2 in the San Diego
region to offset current levels of regional emissions.
● To contribute to reaching California's net zero goals, natural and working lands (NWLs)
need to act as stronger net sinks through investments in bolstering NCSs and minimizing
carbon emissions from the land and land use activities. To accurately account for net
carbon land use emissions, local data need to be collected and integrated into regional
carbon calculations.
● Avoiding land use change by protecting NWLs represents the most effective and
inexpensive NCS policy in the San Diego region, except where other decarbonization
actions necessitate land use change (such as siting renewable energy infrastructure).
This report estimates that annual sequestration in NWLs may be up to 2 million metric
tons (MMT) of CO2 under ideal circumstances and that there may be up to 58 MMT of
CO2 stored in vegetation, woody debris, leaf litter, and soils, some of which would be
released with land use change.
● Other important regional NCSs considered here may be less effective and/or more
expensive; these include carbon farming, wetland protection and expansion, and urban
forestry and greening. Wildfire management is important for reducing emissions and
numerous other economic, ecological, and social reasons. Large-scale habitat
restoration and reforestation, which were not considered in this report, are expensive
and may not be effective for decarbonization in the local context. While generally less
cost-effective, these NCSs can still be important options with co-benefits.
● NCSs include co-benefits such as ecosystem services that provide economic, social, and
public health benefits (e.g., ecosystems can reduce storm surge damages; urban trees
provide shade that leads to energy savings and reduced heat island effects). These co-
benefits may help justify the cost of NCSs, even in circumstances where carbon
sequestration and storage may be relatively low.
Oct. 11, 2022 Item #12 Page 210 of 560
172
5.1 Introduction
5.1.1 San Diego region’s ecology
The San Diego region and the larger California Floristic Province are generally considered
“biodiversity hotspots,” characterized by high levels of endemism (where a species exists
nowhere else) and habitat intactness while facing threats of extinction or biodiversity loss.1–3
San Diego county is widely regarded as the most biodiverse county in the nation, in large part
due to its high diversity of native plants, bees, birds, reptiles, and mammals.2,4–7 The region is
largely shrub-dominated, having cool, wet winters with warm, dry summers, and having highly
fragmented habitats near urban and suburban development (Figure 5.1; Table 5.1).2,8 The San
Diego region is also home to over 70 species that are listed as either threatened or endangered
at the state or federal level and over 100 more species that are considered to be at-risk.9
Further, the San Diego region contains areas that are considered refugia – areas that are
relatively protected from stressors that can negatively affect species or ecosystem survival such
as fire, climate change, water stress, and recreational impacts.10 These regions will be
increasingly important for maintaining ecosystem functioning and for protecting ecosystem
services, like carbon storage,10,11 thus highlighting the importance of land use planning at the
ecosystem level across the entire region.12,13
Table 5.1 Area (acres) and percent of total area in the San Diego county boundary per vegetation category,
calculated in QGIS 3.16 from Figure 5.1.
Regionwide total
Vegetation Classification Subcategory Area (acres) Percent
Agriculture and Working Lands (including row crops, orchards, vineyards,
pastures, fields, etc.) 136985.26 5.02
Desert/Dune Community 47065.45 1.73
Disturbed 29627.94 1.09
Forest 85489.40 3.13
Grasslands (not used for grazing or pasture, includes native and non-native) 146750.91 5.38
Marshes and Wetlands 6248.76 0.23
Meadows and Vernal Pools 15115.86 0.55
Riparian and Bottomland Habitat 71195.26 2.61
Scrub and Chaparral 1607073.92 58.93
Settlement 381509.95 13.99
Unvegetated Habitat (includes open water, bays, and unvegetated freshwater) 31452.74 1.15
Woodland 168479.01 6.18
TOTAL 2726994.44 100%
Oct. 11, 2022 Item #12 Page 211 of 560
173
Figure 5.1 Vegetation categories within the San Diego County boundary. All data from SanGIS (SanGIS.org). See
Appendix 5.A for information on shapefiles, geospatial layers, vegetation type classifications, and other data
source information.
5.1.2 Natural climate solutions (NCSs)
Land use contributes both negative and positive emissions in the San Diego region. Negative
emissions refer to greenhouse gases (GHGs) being absorbed and positive emissions refer to
GHG being emitted. The emissions are generally net negative, meaning that most lands absorb
more carbon dioxide than they emit every year and act as carbon sinks (Figure 5.2).12,14,15 Land
management practices and natural resource uses can maintain, increase, or decrease negative
emissions and therefore affect the associated capacity of the land as a carbon sink accordingly.
Actions that maintain or increase negative emissions and bolster carbon sinks in natural and
working lands are commonly known as natural climate solutions (NCSs). Natural lands refer to
lands relatively unchanged by humans and include wildlands, preserves, and restored habitats.
Working lands refer to lands that are worked by humans to produce a good and include all
agricultural lands, like orchards, plant nurseries, row crops, and pasture lands. Most agencies
account for these areas under a single natural and working lands (NWLs) categorization
encompassing all lands that are not urbanized or developed beyond agricultural purposes,
Oct. 11, 2022 Item #12 Page 212 of 560
174
although these two types of land typically have divergent carbon emission profiles and different
carbon management practices.12,16,17
Figure 5.2 Total 2019 NWL carbon dioxide equivalent (CO2e) net emissions per land use and land use change sector
and for total forestry and total agricultural sectors in the United States. Negative values are net negative
emissions, or sequestration, and positive values are net positive emissions. Data are from the 2021 EPA report of
national greenhouse gas emissions, tables 5-1 and 6-1.15 *The “existing settlements” sector includes urban trees,
which offer large sequestration gains. Without urban trees, existing settlements would have net positive
emissions.
NCSs will play a significant role in removing and storing atmospheric carbon dioxide (CO2) in the
future.i One study suggests that global terrestrial and coastal lands and associated NCSs could
contribute up to 30% of the global mitigation needed by 2050 to keep warming to 1.5 degrees
Celcius.18 This finding, along with others, demonstrate the importance of maintaining and
enhancing ecosystem carbon sequestration. These findings also underscore the need for
mitigation and negative emissions technologies to offset natural and anthropogenic
emissions.12,16,18–20
Globally, nationally, and in California, most of the natural mitigation will occur through
reforestation, afforestation, forest management, agroforestry, and other tree-based solutions.ii;
i The California State Budget, 2022-2023 includes funding for “nature-based solutions” to, among other things,
increase carbon sequestration and storage in California’s natural and working lands. See
https://www.ebudget.ca.gov/FullBudgetSummary.pdf for more information (accessed 7/11/22).
ii While reforestation involves planting trees in areas that were once forested, afforestation refers to planting in
areas that did not historically contain forests or large numbers of trees. Agroforestry is the practice of
incorporating trees into agricultural and working lands. Examples of agroforestry may include planting trees in
fields and growing “shade-grown” crops, planting trees in pasture and grazing lands, or planting trees and shrubs
Oct. 11, 2022 Item #12 Page 213 of 560
175
12,18,21,22 The San Diego region is shrub-dominated2 (Figure 5.1), so there are fewer tree-based
NCSs beyond restoring riparian areas and increasing the urban tree canopy cover.12,17 Instead,
local NCSs such as non-forest management of shrublands and shrubland restoration may be
important, despite not being as prominent at the global level.12 These non-forest management
strategies warrant further research but are not considered in this report largely because there
are few studies and data on the effectiveness of non-forest management.
There are two major considerations for land use and NCSs in the RDF: maintaining or increasing
annual GHG sequestration in NWLs and protecting carbon stored naturally by decreasing or
maintaining potential GHG emissions from the land and coastal ecosystems. This analysis
focuses on net carbon dioxide equivalent (CO2e) emissions of NCSs and land use, though there
are numerous co-benefits associated with land use management and NCSs including, but not
limited to: biodiversity and endemism conservation, ecological resilience, and ecosystem
services.
5.1.2.1 Sequestration
Carbon sequestration is the flow of CO2 from the atmosphere into soils, biomass, geological
formations, etc. Natural and working lands can sequester CO2 through photosynthesis and can
sequester methane (CH4) and nitrous oxide (N2O) through bacterial metabolic reactions.23–25
Despite some CH4 and N2O sequestration, NWLs tend to emit more than they sequester, and
thus generally represent CH4 and N2O sources rather than sinks.24,26–28 On average, NWLs
absorb more CO2e than they emit because they can collectively absorb large enough quantities
of CO2 to counteract the climate warming effects of CH4 and N2O emissions and result in a net
decrease of GHGs.20,24
Annual carbon sequestration rates vary by prevailing climate, levels of disturbance, and
dominant plant species,29 however, landscapes with older, larger plants generally have higher
sequestration rates.29,30 As such, forests tend to have higher sequestration rates than
grasslands, for instance, with forests sequestering up to twice as much carbon as
grasslands.20,21,24 While the focus is often on the volume of trees planted, the International
Panel on Climate Change’s most recent report highlights the scientific consensus that land
managers should avoid afforestation in lands like grasslands or savannas that historically have
low tree densities. Afforestation in these areas replaces native and adaptive vegetation with ill-
adapted trees and is therefore more vulnerable to emitting its stored carbon and provides
fewer co-benefits.20,31 Further, the report, along with numerous studies, emphasizes that the
type of tree matters20,32 and that non-forest ecosystem protection and restoration are also
critical.20
around crops and agricultural lands to provide windbreaks.
Oct. 11, 2022 Item #12 Page 214 of 560
176
5.1.2.2 Storage
NWLs hold large quantities of carbon in soils and both living and dead biomass.21,24 Carbon
storage is defined as an accumulated stock of CO2 stored as carbohydrates and other carbon-
containing molecules. Carbon storage in plant tissues occurs when net primary production
(NPP) is positive (i.e., when carbon sequestration occurs in the form of plant growth). Primary
production is the process by which photosynthetic organisms create sugar and oxygen via
sunlight, water and CO2. NPP is the sugar creation minus the CO2 released through respiration.
When NPP is positive, the plant sequesters more CO2 through sugar production than it releases
through respiration.13–15 As plants grow, they store carbon in their tissues in both aboveground
(stems, leaves, trunks, etc.) and belowground (roots) biomass. The fate of that carbon is highly
dependent on local conditions, although generally some belowground biomass becomes soil
carbon, for example as root tissues die and decompose. Additionally, the complex soil ecology
and fungal ecology interact with plant sugar production and also contribute to soil carbon
storage. Aboveground biomass can store carbon in the system as dead/downed woody debris.
This storage is especially important in low humidity systems where decomposition rates are
lower, as they are in Southern California, however there is a trade-off to this storage because it
increases fire fuel.
Despite the fact that natural systems are adept at storing carbon on average and in the long-
term, total carbon storage contributions vary significantly by ecosystem type in the San Diego
region. For instance, though forests and woodlands store and sequester more carbon globally
than any other habitat type, they play a smaller role in Southern California. This reflects
primarily the relative lack of forests in the San Diego region (Figure 5.1, Table 5.1), and
secondarily that existing trees and forests grow more slowly in the majority of Southern
California than in more humid regions.13,17,22
Shrubs and other woody, non-tree plants dominate the San Diego region, as nearly 60% of the
region is classified as scrub or chaparral habitats (Table 5.1), which are locally important for
carbon storage2,12,30 and nitrogen storage.33 Scrub habitats, including coastal sage scrub (CSS)
and chaparral, are somewhat unique in that they continue to provide high sequestration rates
and storage even when they are invaded by non-native grasses, which are themselves
inefficient carbon storage systems.33 Further, because Southern Californian scrub-dominated
ecosystems have longer historic fire regimes (i.e., fires occur less frequently) than forest-
dominated ecosystems or more northerly regions,34–37 San Diego’s scrub ecosystems have low
carbon “turnover” from their dead, woody tissues to the atmosphere and therefore store that
carbon for a longer time period.33
Though marsh and wetland ecosystems are slow to sequester carbon on an annual basis, they
Oct. 11, 2022 Item #12 Page 215 of 560
177
hold large quantities in stable reserves38,39 and can even transport carbon to the deep ocean,
thereby storing it for millennia or longer.40 For the San Diego region and California as a whole,
salt marshes, salt pans, mudflats, and eelgrass (or seagrass) beds are the crucial “blue carbon”
ecosystems that store disproportionately high amounts of carbon for long time periods.39,41,42
5.1.2.3 Avoiding land use and land use change emissions
Avoided emissions refer to emissions that would have come from NWLs if not for some land use
protection or land use change prevention. In California, the majority of avoidable emissions
come from large crown wildfires in forests and from changing land use from forests, shrub,
wetlands, grasslands, and agricultural lands (roughly in that order) to human-made
environments.12,13,43 In the case of wildfires, centuries of fire suppression have left areas with
excess downed woody debris on the forest floor, which fuels faster, hotter fires.36 Additionally,
pest and noxious weed invasions have fueled large, destructive fires by creating larger pools of
downed woody debris and swaths of dead non-native grasses or excessively flammable leaf
litter from non-native plants.36,44 Further, worsening droughts stress plants and therefore
reduce the likelihood that an otherwise healthy forest or scrub ecosystem will withstand a
wildfire or rebound quickly after one. This effect is magnified in an invaded forest or scrub
habitat.12,36,44 For example, the combination of drought and non-native weed and insect species
invasions fueled San Diego’s 2003 and 2007 super fires, where large quantities of dead pine
trees, oak trees, and annual grasses fueled historic fires and permanently altered ecosystems,
changing previously forested lands to scrub-dominated lands.35,44 In the case of land use
change, rapid development has fragmented the San Diego region’s natural ecosystems and has
created large expanses of settled and built up areas that provide little carbon sequestration
value or other ecosystem services.2,8,13,15
Beyond preventing “avoidable” emissions through land use and management practices, some
emissions will be nearly or completely unavoidable. For instance, if there are not large-scale
wetland management practices implemented in the region, there will be future emissions
generated from lost wetlands as sea levels rise. As seawater inundates intertidal zones,
marshes, bogs, and wetlands, the associated plants will die and a portion of the carbon stored
in the sediment and biomass will be emitted.42 These emissions will be unavoidable,45,46 but
they can be mitigated through restoring upland habitats and allow for wetland migration, which
may result in net zero emissions from wetland loss due to sea level rise.17,42,47,48
5.1.2.4 Other considerations (co-benefits)
NWLs provide numerous societal benefits beyond carbon sequestration and storage as a result
of natural ecosystem processes. These are called ecosystem services or nature-based solutions,
and include air and water quality improvements, reduced impacts from natural disasters,
Oct. 11, 2022 Item #12 Page 216 of 560
178
increased food and fiber production, groundwater recharging, soil stabilization and erosion
control, and improved public health through better air quality or increased outdoor recreation
opportunities. The majority of the proposed methods to increase carbon storage and
sequestration naturally have such co-benefits.17,20–22,49 The California Air Resources Board
(CARB) reports that each NCS considered here improves water quality and/or increases water
quantity; protects biodiversity, habitats, and ecosystem health; and improves public health
and/or community resilience to climate change. Additionally, protecting NWLs from land use
change improves air quality, as does urban forestry and chaparral restoration.49
While this report focuses on the carbon storage and sequestration aspects of NCSs, future work
should characterize, quantify, and value the additional ecosystem services and co-benefits to
understand the full impacts of these actions and where they could be implemented to deliver
benefits to people most efficiently and equitably. The full understanding of NCS co-benefits will
be especially important as the San Diego region prepares for a more uncertain climate and
plans mitigation policies to address the possibility of longer and/or more severe droughts, more
frequent and/or severe wildfires, and other natural disasters and changing baseline climatic
realities.50
The rest of the chapter will focus on describing and providing quantifications of four NCSs that
the San Diego region could implement that would sequester atmospheric carbon dioxide,
maintain or increase carbon storage, and provide co-benefits. These four NCSs are: protection
of natural lands from land use change; carbon farming; protection of blue carbon habitats; and
urban forestry and greening. The chapter also describes some additional NCSs without
quantifying their benefits, which merit further study.
5.1.3 Land Use Change and Regional Growth, Development, and Sectoral Decarbonization
There are considerable trade-offs between preventing land use change and development that
are not explicitly considered in the RDF, but that warrant further research and consideration.
Namely, the development for regional decarbonization outlined in this report’s pathways will
generally necessitate some degree of land use change.
5.1.3.1 Renewable energy production and land use change
Given the current technological availability of low-carbon energy production, Chapter 2 of this
report finds that electricity supply decarbonization will require land use change in every
investigated scenario to build renewable energy generation facilities and transmission
infrastructure. This is true even of scenarios that do not allow the region to independently
produce sufficient renewable energy by 2050 to meet the projected demand (Table 2.5). From
an NCS perspective, the scenario that prioritizes protecting lands with high sequestration falls
Oct. 11, 2022 Item #12 Page 217 of 560
179
short of reaching 2050 regional energy demand and would require relatively expensive
investments in developing urban renewable energy resources and significant energy imports
from outside of the region. Even by avoiding lands with high sequestration potential, the
scenario would still impact regional sequestration to some degree. This scenario underscores
the fact that, under the current technological landscape and grid interconnections, there will be
trade-offs between producing low-carbon energy and maintaining existing natural carbon
sequestration in NWLs. Decision-makers will need to weigh the inherent trade-offs between
reducing ongoing energy emissions and preventing the land use change’s one-time emissions
and lost ongoing sequestration potential.
5.1.3.1 Transportation and land use change
Chapter 3 of this report shows that a decarbonized transportation sector will also require land
use change, some of which may be in NWLs. Land use change may be required to update,
expand, and improve public transit; build electric vehicle charging infrastructure; improve
and/or expand regional bikeability and walkability; and to otherwise better connect
communities to reduce vehicle miles traveled. As with decarbonizing energy, decarbonizing the
transportation sector, which is the largest regional GHG emitter, may require some trade-offs
between reducing emissions and enhancing NCSs.
5.1.3.1 Development, housing, and land use change
As cities, towns, villages, and communities in the San Diego region continue to grow, land use
change will be necessary to build housing, public buildings, businesses, and critical
infrastructure, among other building types. This is especially true as the region plans for
housing development to address the regional housing shortage and as the region addresses
housing equity and access for low-income residents. Reports have explicitly examined land use
change and housing in the San Diego region, including the Climate Action Campaign’s “Solving
Sprawl” report.51 This chapter’s findings supports that report’s findings that community-
centered growth that focuses on expanding or enhancing existing community footprints will, by
definition, have fewer disruptions to NWLs than creating new communities in current natural or
working lands. Although the RDF does not explicitly consider housing, this report acknowledges
that housing is an important component of continued development, economic stability, social
justice, and sustainability in the region. This chapter, along with other resources like the Solving
Sprawl report, can offer decision-makers tools to understand the trade-offs of housing,
transportation, renewable energy, and land use change and the accompanying loss of NCSs
associated with development in NWLs. This chapter highlights the negative emissions potential
of the region’s NWLs to provide decision-makers with information on the trade-offs of
preventing or allowing land use change. These trade-offs, as well as emissions accounting from
Oct. 11, 2022 Item #12 Page 218 of 560
180
other regional studies, should be carefully considered.
5.2 Natural and Working Lands – Ecological Carbon Dioxide Sequestration and
Storage
5.2.1 Introduction
NWLs are, on average, carbon sinks and globally recognized for their ability to sequester and
store CO2 in plant biomass and soils.14,20 The current level of global net negative emissions from
NWLs is insufficient to offset anthropogenic emissions and are thus unable to reduce total
atmospheric CO2 until positive emissions are drastically reduced. However, NWLs represent an
important tool for reaching net zero emissions globally, nationally, and locally.12,17,21,22,43 The
NCSs for NWLs are to protect current NWLs from land use change to settlements or barren
landscapes, to enhance lands’ ability to sequester and store carbon through land management,
and to restore degraded or lost NWLs to their natural states.21,22,43
Protecting current NWLs from changing to less photosynthetically productive lands (i.e.
settlements or barren landscapes) is consistently the least expensive NCS and is highly
effective.21,22 This section will focus on the NCS of protecting existing carbon pools and carbon
sequestration potential in NWLs through preventing land use change.
Land use change is a global problem that leads to net emissions as more productive carbon
sequestering lands, like forests or grasslands, are turned into less productive lands, like
settlements or high emissions agriculture.14,20,24 The loss of NWLs that currently hold carbon
and that sequester carbon annually is twofold: there is a one-time loss of carbon that is stored
in soil and biomass and there is the lost sequestration potential of that given land area.14 Net
zero emissions scenarios rely heavily on preventing land use change that would result in net
emissions (e.g. urban expansion, land conversion to croplands) and promoting land use change
that would result in net sequestration (e.g. reforestation).12,19,21,24
Nevertheless, it is important to discuss other common NCSs, even if they are not applicable to
the San Diego region or if they were not analyzed here. While forest management and other
land management techniques are effective tools in California and in the United States,17,22,43
they are less important in Southern California, which is shrub dominated and has few forests
that would benefit from forest management on a large enough scale (Figure 5.1).17 Similarly,
reforestation efforts are costly and ecologically inappropriate in most of the San Diego
region.17,22,43 While other restoration efforts are also expensive, some efforts – like restoring
riparian zones, wetlands, savannas, or woodlands– are generally less expensive than
reforestation and can contribute significantly to negative emissions in the San Diego
Oct. 11, 2022 Item #12 Page 219 of 560
181
region.17,22,52 Riparian restoration is considered in the agriculture and carbon farming section
and blue carbon restoration is discussed in the blue carbon section, while other restoration
efforts are discussed briefly in Section 5.6 of this report. This section will focus on the negative
emissions benefits of protecting existing carbon pools and carbon sequestration potential in
natural and working lands through preventing land use change.
Among the NCSs listed above, preventing land use change is relatively inexpensive. National
estimates for the U.S. suggest that over 60 million metric tons (MMT) of CO2e can be
sequestered in 2025 for marginal abatement costs of $10 or less per metric ton (MT) of CO2e
simply through avoiding conversion of forest and grasslands.22 Comparatively, reforestation,
which has the highest potential for sequestering and storing carbon of any NCSs that are
considered at the global, national, or State level, is relatively expensive (estimates range from
$16 to 100 per MT of CO2e and likely drastically underestimate costs for the San Diego
region).12,20,22,29 In the United States, this is largely due to the high costs of collecting seeds,
raising seedlings in nurseries, and planting saplings in reforestable areas. When additional
costs, such as maintenance and program evaluation, are considered, the costs increase
further.53 Costs vary by prevailing climatic conditions, infrastructure, workforce, and species,
and are likely to be higher in Southern California than in the Southeastern United States or
Northern California, where conditions, infrastructure, and species are more amenable to
reforestation.12,53
In the San Diego region, land use change occurs through both natural processes, such as
ecosystem succession after fires or pest invasions,34,36,44 and through settlement expansion,
such as urban and transportation expansion.2,8,54 This section investigates the current
approximate carbon storage and sequestration in the San Diego region using geospatially
explicit vegetation data types from SANDAG’s GIS portali (see Appendix 5.A for more
information on geospatial source data). It additionally considers approximate carbon storage
and sequestration in eelgrass beds in the San Diego Bay based on published survey results of
total coverage, rather than on geospatially explicit data.
This analysis is not peer-reviewed nor is it a comprehensive analysis of the region’s carbon
accounting in natural and working lands. Instead, it is intended to illustrate the following points:
1) the region’s NWLs are, on average, carbon sinks – meaning that they naturally capture and
store CO2; 2) land use change in these NWLs will release stored carbon while simultaneously
eliminating future sequestration in those areas; 3) land use decisions affect the carbon cost-
benefit calculations of NWLs and, therefore, decision-makers should be aware of the broad
carbon implications of the region’s NWLs.
i SanGIS.org
Oct. 11, 2022 Item #12 Page 220 of 560
182
5.2.2 Methods
All analyses, calculations, and data manipulation were done in QGIS 3.16 and Microsoft Excel.
Carbon storage and sequestration values were taken from the literature (see Appendix 5.A for
sources). Whenever possible, local data were chosen. If local data were not available, then
California, Pacific Coast, Western U.S., U.S., and global data were used, in that order. When
there were multiple estimates or when there was a range of possible values in the same
geographic area, the most conservative value was chosen. All carbon storage values were
converted to metric tonnes of CO2 equivalent or carbon per hectare (MT CO2e ha-1 or C ha-1)
and all carbon sequestration values were converted to metric tonnes of CO2 equivalent per
hectare per year (MT CO2e ha-1 yr-1) if the data were not already reported as such. Total carbon
storage and sequestration values for the entire region were converted into millions of metric
tonnes (MMT) (See Appendix 5.A for methods details).
The total estimated eelgrass of 1,693 acres (685 ha) from the San Diego Bay were also
included.55 Mission Bay eelgrass beds were not included because restoration and data
collecting efforts are ongoing and not yet comprehensive, though more comprehensive data
will be available in the near future and should be integrated into blue carbon and negative
emission calculations.56–59 Marine eelgrass beds were also not included because they are in
State waters and are outside of the jurisdiction of San Diego regional governments and
agencies.
5.2.3 Results
The biodiverse and ecologically rich natural landscapes in the San Diego region have significant
potential for both carbon storage and for annual carbon sequestration (Table 5.2). This analysis
shows that there are approximately 58 MMT of carbon stored in San Diego’s biomass and soils.
Scrub ecosystems, including chaparral and coastal sage scrub, contribute most significantly to
regional carbon storage, due in large part to their abundance and their local adaptations (Figure
5.1). Per hectare, coastal wetlands store the most carbon of any system. They are followed by
tree-dominated systems, like woodlands, forests, and riparian areas. Wetlands are one of the
least abundant systems in the region, though tree-dominated systems also have relatively low
coverage. This is all readily visible in Figure 5.3, which shows the highest carbon storage per
hectare values as darker areas and the lowest carbon storage value as lighter areas.
In addition to storage, the region also has high sequestration values and may be able to
sequester up to 2.25 MMT of carbon per year. An important caveat to this value is that it relies
on several assumptions that may not reflect the biological realities, and this caveat is especially
important in the scrub category because it is the dominant ecosystem type in the region (see
Section 5.2.4 for more discussion of assumptions, caveats, and drawbacks). The largest
Oct. 11, 2022 Item #12 Page 221 of 560
183
sequestration potential is in scrublands, forests, woodlands, and riparian zones. However,
settlements show some high sequestration potential because of urban trees (Table 5.2). Per
polygon, forests and woodlands have the highest annual sequestration rates per hectare
(Figure 5.4 – darker areas have the highest rates, lighter areas have the lowest rates).
Interestingly, disturbed wetlands have net positive emissions,42,48,60 so the associated polygons
have negative sequestration values (Figure 5.4 – light gray polygons). Importantly, these areas
remain significant repositories of carbon stored deeper in the soil, despite having shifted to
become net emitters due to disturbance (Figure 5.3).
Table 5.2 Total carbon storage (MMT CO2e) and sequestration (MMT CO2e yr-1) in the San Diego region by land use
category and for all land uses throughout the region.
Notes:
* Includes row crops, orchards, vineyards, fields and pastures, dairies, plant nurseries, chicken ranches, and
general agriculture.
** Includes urban and developed areas.
*** Includes disturbed wetlands and other habitats.
**** Includes unvegetated areas.
Oct. 11, 2022 Item #12 Page 222 of 560
184
Figure 5.3 Total stored carbon (MT CO2e ha-1) estimates for the San Diego region. Darker colors represent larger carbon stock estimates and lighter colors
represent lower stock estimates. Regionwide storage totals per vegetation category were calculated from these values and are in Table 5.2. Note that eelgrass
beds were not included because they were not included in the SanGIS shapefiles. However, eelgrass beds are prevalent in both Mission and San Diego bays and
are important blue carbon habitats. Oct. 11, 2022Item #12 Page 223 of 560
185
Figure 5.4 Annual sequestration rate (MT CO2e ha-1 yr-1) estimates for the San Diego region. Darker colors represent higher rates, lighter colors represent lower
rates, and light gray represents either zero sequestration or net positive emissions (which is represented as a negative value here). Regionwide sequestration
totals per vegetation category were calculated from these values and are in Table 5.2. Note that eelgrass beds were not included because they were not
included in the SanGIS shapefiles. However, eelgrass beds are prevalent in both Mission and San Diego bays and are important blue carbon habitats that
provide carbon sequestration and storage.Oct. 11, 2022Item #12 Page 224 of 560
186
5.2.4 Discussion
San Diego’s NWLs represent two important NCSs. First, the lands provide stable, long-term
carbon storage for the region and keep CO2 out of the atmosphere. Second, the lands provide
annual net negative emissions by sequestering atmospheric carbon in plant tissues and soils,
thereby removing some of the region’s anthropogenic emissions. This analysis is not
comprehensive and is meant to illustrate that regional lands are currently producing NCSs at
little to no cost and that these lands should be valued for their natural carbon sequestration
and storage abilities.
Further, this analysis demonstrates that there are climate and emissions costs that would be
incurred with land use change in the region. Figure 5.3 shows that land use change throughout
most of the region will result in large one-time emissions of carbon that is currently stored in
biomass and soils. While positive emissions from land use change are not explicitly accounted
for in any of the Climate Action Plans,i such accounting can be an important metric to help
decision-makers understand the inherent emissions trade-offs involved in land use change.
Additionally, Figure 5.4 shows that land use change throughout most of the region will have
long-term sequestration consequences, as those lands will sequester less carbon each year
after usage changes. This accounting can also elucidate trade-offs because the lost
sequestration would need to be replaced with other NWL sequestration to maintain an
equilibrium in the NCSs in NWLs. Alternatively, technological solutions could compensate for
NWL sequestration loss, though this would be costly and potentially difficult to implement.16,18
The exception to this rule of thumb is if the land use change is a change from less
photosynthetically productive lands to more productive lands, as would be the case in
chaparral or woodland restoration on degraded, retired, or disturbed lands, for instance (See
Figure 5.2 for an illustration of land use change that results in greater sequestration).
There are some caveats and drawbacks to this analysis. First, local data were unavailable for
some vegetation classes and the values used may not accurately reflect local conditions or
circumstances. As a result, this analysis made assumptions that generalized carbon storage and
sequestration potential. Importantly, the analysis assumes that all scrub and chaparral habitats
store and sequester a uniform amount of carbon, regardless of the vegetation class within
scrub and chaparral. Without more accurate values based on local data collection, this
assumption was used as a starting point. Local data will become more important in the future
as droughts and other phenomena affect the San Diego region. Additionally, this analysis
assumed that all scrub habitats were intact (i.e., not invaded), which will inflate the storage and
sequestration values. Luo et al. (2007)30 show that chaparral in one part of the San Diego region
i Personal communication Scott Anders, September 2021.
Oct. 11, 2022 Item #12 Page 225 of 560
187
is a strong sink in normal years but an emitter during years of severe droughts, while Wheeler
et al. (2016)33 show that invaded chaparral in the San Diego region stores and sequesters less
carbon than an intact habitat. These studies highlight both the uncertainties in carbon
accounting and the importance of localized data. Second, soil carbon estimates were not
universally included in the literature, or it was not clear whether soil carbon had been included
in some stated values, so this analysis does not universally include soil carbon estimates.
Excluding soil carbon would underestimate the total stored carbon, but it is unlikely to affect
the carbon sequestration rates because the majority of measured soil carbon is relatively
shallow, where much of the long-term soil carbon storage is in deeper soil layers.61 Third, the
full extent of eelgrass and other marine, beach, and intertidal plants and algae were not
included in the vegetation classification shapefiles or were not included in enough detail to
make determinations. Thus, their carbon storage and sequestration potentials are
underrepresented, despite the fact that they are important contributors to negative emissions
in the region and store large quantities of carbon.38,41,56 Fourth, this analysis was done at a
coarser scale than other regional and localized analyses that are forthcoming.i Those more
detailed analyses should be considered more accurate because they will better reflect plant
biomass and soil carbon estimates as well as carbon sequestration potential. Finally, any NWL
carbon accounting analyses would benefit from research done by local institutions and
organizations like WildCoast, the Climate Action Alliance, San Diego State University, and the
Scripps Institution of Oceanography. When local data become available, they should
immediately be incorporated into all land use analyses.
5.2.5 Policy implications
This analysis illustrates that an ounce of prevention is worth a pound of cure – protecting a
hectare of NWLs will prevent emissions and will continue to sequester carbon in a low to no
cost manner. As such, NWLs contribute to negative emissions in the region and thus mitigate
some anthropogenic emissions. Meanwhile, losing NWLs would require expensive restoration,
mitigation, or negative emissions technology investments to capture the one-time emissions of
stored carbon and to continue to sequester the carbon that those lands would have
sequestered naturally.
Further, this analysis illustrates that local efforts to characterize the carbon storage and
sequestration capacity of NWLs in the San Diego region should be supported by local
governments, jurisdictions, and agencies because current policies are generally not informed by
the most localized carbon cycling data. Similarly, this analysis shows that there will be emissions
trade-offs associated with land use change in the region. Thus, regional governments should
i Personal communication Drs. Megan Jennings and Matthew Costa, 2021 and information from the Climate Action
Alliance detailed here: https://www.climatesciencealliance.org/carbon-sequestration
Oct. 11, 2022 Item #12 Page 226 of 560
188
include emissions from lost biomass and soils as well as the lost carbon sequestration potential
when deciding land use policies and decarbonization pathways to better understand the
carbon-related trade-offs of land use decisions. Additional effort should price these emissions
and lost sequestration potential to properly incentivize natural and working land protection and
to understand the extent of regional net negative emissions.
5.2.6 Policy recommendations:
● Support infill development and natural growth in rural communities that minimize loss
of carbon sequestration potential and co-benefits from NWLs. Disincentivize sprawl
growth in NWLs and sprawl growth that cannot support efficient transit use or multi-
modal transportation options.
● Support studies to accurately measure and report local carbon stocks and sequestration
rates.
● Consider incorporating the costs of CO2 emissions from land use change and the lost CO2
sequestration potential into land use planning decisions.
● Consider quantifying co-benefits, like ecosystem services, for incorporation into land use
planning decisions.
5.3 Agricultural and Working Lands
5.3.1 Introduction
Nationally, agriculture is a net GHG emitter because agricultural activities result in net positive
emissions of methane, nitrous oxide, and CO2 (Figure 5.2).14,15,24 However, agriculture is a
relatively small source of regional emissions62 and is the only sector capable of switching from
net positive to net negative emissions, all while producing agricultural goods.12,15 In this way,
the NCSs associated with farming, ranching, and other agricultural activities can support
decarbonization and continue to provide jobs, livelihoods, food, and other agricultural goods to
the region and beyond.
Many NCSs focus on ways to both reduce CO2 emissions and enhance sequestration
potential,21,22,24 where methane and nitrous oxide management are more nuanced and
difficult.25,26 This is also true for agricultural emissions; however, manure and fertilizer
management can reduce methane and nitrous oxide emissions, respectively.21,52 This report
focuses on the CO2 implications of agricultural climate solutions, sometimes referred to as
“carbon farming” or “climate farming,” though it will note important considerations for
methane and nitrous oxide when applicable. NCSs in existing agriculture increase annual
sequestration, decrease emissions, or do both simultaneously. Examples of increasing
sequestration include adding compost to soils, planting cover crops, planting trees in or around
Oct. 11, 2022 Item #12 Page 227 of 560
189
farms or pastures, planting perennial plants rather than annuals, preventing the premature loss
of existing orchard trees, engaging in whole orchard recycling, or adding biochar to soils.
Examples of preventing emissions include cover cropping, practicing no or low-till agriculture,
planting perennial plants rather than annuals, planting trees, or utilizing on-farm
compost.12,20,21,52
Agriculture and working lands are economically and socially important to the San Diego region
and there are NCSs available today that may be able to turn agricultural carbon sources into
carbon sinks and thus contribute to regional decarbonization goals.52,63 Agriculture is thus a
unique industry because it can counteract climate change and simultaneously provide food,
nursery plants, and other agricultural goods for regional consumption.15,63,64 In implementing
these NCSs, it will be critical to accurately assess costs and benefits and to help farmers, farm
laborers, and farming communities to facilitate an equitable and mutually beneficial transition
to climate farming techniques, for example through programs and projects that provide
financial and/or educational assistance.
There are significant uncertainties in GHG accounting in agricultural lands because of the
inherently complex and highly heterogeneous soil gas interchanges. These depend on factors
beyond human control, such as weather and existing soil gas composition, and on land
management and farming practices, like the type and amount of inputs on any given day,
species selection, tillage regime, and land use history.12,27 The majority of agricultural climate
discussions in the United States rely on the Department of Agriculture’s (USDA) COMET
planner.i Discussions that focus on California tend to use a California-specific COMET planner
tool,ii with additional help from CARB and the California Department of Food and Agriculture
(CDFA). This tool is important, though it should be used carefully because there are some
caveats to the data. First, the data behind the estimates represent 10-year averages and the
values should be considered highly uncertain beyond that timeframe and should be updated or
validated.12,65 Second, the models that use the field data are simple relative to the biochemical
interactions in soils. Given that soils are highly dynamic systems, there are concerns that the
COMET planner overestimates the amount of carbon that will be stored and may
simultaneously underestimate the potential nitrous oxide emissions.12,27 Further, the report
“Getting to Neutral: Options for Negative Carbon Emissions in California” notes that the models
underlying the COMET planner also likely overestimate how much carbon is stored in deeper,
and thus longer term, soil storage.12 Thus, the “Getting to Neutral” report, and others,
emphasize the importance of longer term monitoring of local demonstration farms where
climate farming practices have been implemented.12,52
i http://comet-planner.com/
ii http://www.comet-planner-cdfahsp.com/
Oct. 11, 2022 Item #12 Page 228 of 560
190
5.3.2 Discussion
While localized carbon flux data, which would be ideal for calculating climate farming impacts,
is unavailable, Dr. Puja Batra produced a report52 for the unincorporated San Diego region to
recommend policies for the County of San Diego regarding climate farming and transforming
agricultural lands from sources to sinks using California-specific COMET planner data. That
report focused on compost applications in orchards, rangelands, and row crop fields. It also
discussed riparian restoration and preventing the removal of orchard trees due to increasing
marginal costs of watering and losses due to fire.
Compost application is estimated to yield the highest carbon sequestration benefits of any
investigated carbon farming techniques, according to Batra,52 resulting in 227,170 MT of CO2e
sequestered annually. However, the report notes that there are potential problems of nitrogen
leaching into surface water and groundwater if the application rate is too high or if the nitrogen
levels in the compost are too high.52 Repeated application of compost may result in
eutrophication52 and/or net GHG emissions from the soil,12,27,43 so compost application for the
sake of carbon sequestration will need to be coupled with monitoring. Regardless of carbon
sequestration potential, compost application may offer co-benefits in reduced application of
synthetic fertilizers, which could reduce NOx emissions;22 improved manure management,
which could reduce CH4 and NOx emissions;12,22,52 and increased soil water retention.20,22,52
Batra also investigated riparian restoration as a means of sequestering carbon in the region’s
agricultural and working lands. The unincorporated County has nearly 7,000 miles of freshwater
and riparian systems,52 which are typically dominated by shrubs and trees and have higher
carbon sequestration potential than forb and grass-dominated systems.2,6,24 Restoring riparian
ecosystems typically involves planting native trees and shrubs, which is estimated to result in
approximately 2 MT of CO2e sequestration per acre per year.52,65 Batra estimated restoration of
about 25% of riparian habitats and 35 feet of buffer zones around them would result in
approximately 7,230 MTCO2e per year.52
Finally, Batra considered the emissions from recent orchard tree removals and the lost
sequestration value of those trees. The unincorporated County lost approximately one million
orchard trees from 2000 to 2015. Many of the trees were removed because rising marginal
costs of inputs like water forced farmers to choose between paying higher water costs or
removing some of their orchard trees.52 Trees are particularly good at sequestering carbon
because of their size and at storing carbon because they deposit carbon deep in the soil and
store carbon in biomass,12,20,21,29 so removing these orchard trees has two carbon related
impacts. First, it releases stored soil carbon and begins the process of releasing the biomass
carbon. Second, it reduces the orchard’s annual sequestration potential because the removed
Oct. 11, 2022 Item #12 Page 229 of 560
191
tree is no longer able to sequester carbon.52 Batra estimated that the cumulative total lost
orchard trees in this period released 243,468 MT of CO2e and lost the ability to store 131,657
MT of CO2e during that 15 year period. All told, the loss of stored carbon in orchard trees in the
unincorporated County is estimated to be more than 375,000 MT CO2e.52 This analysis
highlights the importance of retaining existing carbon pools, however it also speaks to the
financial difficulties that farmers face when input prices increase.
Beyond Batra’s report, other carbon farming methods to consider should include cover
cropping, improved species selection, and restoration of degraded, abandoned, or marginal
agricultural lands.12,20–22 Importantly, each of these techniques has co-benefits for the farmers,
ranchers, and land owners, including increased soil water retention, more shade for livestock,
and/or increased agricultural yields. The techniques also have co-benefits for the surrounding
ecosystems like improved or increased habitat and/or increased biodiversity.20–22,66 Restoration
of degraded, abandoned, or marginal agricultural lands is likely to offer the greatest co-benefits
for the San Diego region in large part because planting trees and shrubs in grasslands or fields
leads to large belowground and aboveground carbon storage gains as well as improved
biodiversity, soil health, water quality and quantity, and air quality outcomes.12,20–22,24
Additionally, given that much of the region’s agricultural output and acreage consists of
livestock grazing, rangelands, and pasturelands,2,67 planting trees in or around grasslands used
for grazing or pasture, which is a form of agroforestry, is likely to improve regional carbon
sequestration while offering numerous co-benefits to farmers and ranchers, like shade for
livestock, in addition to the restoration co-benefits listed above.52,65 Finally, restoration of
degraded, abandoned, or marginal agricultural lands may offer a source of revenue for farmers
if they are paid for their restoration and carbon sequestration enhancement efforts.i
Addressing methane and nitrous oxide emissions is generally more difficult because there are
generally fewer carbon farming solutions for these sources, despite the fact that they
contribute more warming potential (per metric ton) to the atmosphere than CO2.13,14,21,24,52
Methane in the San Diego region is primarily emitted from landfills, livestock manure, enteric
fermentation, and wastewater, though there are also some methane emissions from natural
decomposition in wetlands and wetland loss.12,17,20,24,47 Of these, only livestock manure and
enteric fermentation are directly applicable to the region’s agricultural emissions. Batra did not
account for the agricultural methane that is prevented from entering landfills because avoided
methane emissions are covered by regional climate action plans and would constitute double
counting.52,68,69 This would also be the case for the City of San Diego’s wastewater
i For example, the USDA’s Natural Resource Conservation Service has provided funding in the past for numerous
carbon farming, restoration, and land management projects across the country, so federal funds could be available for the region’s carbon farming projects (for more information, see:
https://www.nrcs.usda.gov/wps/portal/nrcs/detail/national/newsroom/releases/?cid=NRCSEPRD1829258 ).
Oct. 11, 2022 Item #12 Page 230 of 560
192
emissions.68,69 There are, however, some manure and enteric fermentation management
techniques that are distinct from those already captured in Climate Action Plans for the region.
These include on-site anaerobic manure digestion,70 methane capture or digestion from enteric
fermentation, methane reduction from enteric fermentation.12,52,66,71,72 The opportunities to
reduce methane and nitrous oxide emissions in the region’s agriculture sector require further
study, but they may provide important GHG emissions reductions.
Two demonstration projects hosted by the Resource Conservation District of Greater San Diego
County67,73 and several independent agricultural operations in San Diego Region74 offer
examples of carbon farming and monitoring. These projects are providing data on carbon
farming techniques and will continue to provide insights into the carbon sequestration benefits
as well as the capital costs associated with the new techniques, processes, and monitoring.
Projects like these will be critical for understanding the long-term costs and benefits of carbon
farming and may help create a local market for carbon offsets or other incentive programs.74
A final caveat to this analysis is that agricultural lands can contribute to negative emissions and
reduce regional emissions by diverting some of the waste that would have otherwise gone to
landfills. For instance, Senate Bill (SB) 1383i (Box 5.1) will result in larger quantities of compost
and mulch that are produced as organic materials from homes and businesses are diverted
from landfills. Farms can potentially utilize some of the compost and mulch produced by SB
1383, though transporting and utilizing compost and mulch will come with challenges and costs.
While these potential emissions reductions from organics being diverted from landfills are
important, they should be considered within the waste and landfill sector’s emissions
accounting, not in agricultural accounting. The negative emissions of off-site compost additions
to working lands (or beyond) are also important considerations, but require careful accounting
to only incorporate the additional negative emissions from the off-site compost additions to
avoid double counting and overinflating the value of the climate farming technique. Further
study of integrating the compost and mulch produced by SB 1383 with climate farming will be
important to both proper carbon accounting and to accurately incentivize utilizing off-site
compost.
i https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201520160SB1383
Oct. 11, 2022 Item #12 Page 231 of 560
193
Box 5.1 – Senate Bill 1383
In 2016, the California State Legislature passed SB 1383, or California’s Short-Lived Climate Pollutant
Reduction Strategy, which sets Statewide targets to reduce organic waste disposal by 75% from 2014
levels by 2025 and to rescue at least 20% of currently disposed surplus edible food for human
consumption by 2025. SB 1383 focuses on landfills because organic waste in landfills emits 20% of the
State’s methane gas, with the San Diego region’s landfills producing emissions.i Methane is a more
powerful greenhouse gas than carbon dioxide, despite its shorter lifetime in the atmosphere. Organic
waste like food scraps, yard trimmings, paper, and cardboard make up half of what Californians
dispose of in landfills.
SB 1383 also requires jurisdictions to procure recovered organic waste products – such as renewable
natural gas, compost, and mulch – to drive markets for those goods. Compost and mulch application
to agricultural and working lands are carbon farming techniques with economically and ecologically
important co-benefits like increased soil water holding capacity and improved food nutrition content.
The County of San Diego’s Department of Public Work (DPW) Solid Waste Planning & Recycling section
leads local efforts by chairing the regional Integrated Waste Management Technical Advisory
Committee and Subcommittees, as well as coordinating regional food recovery and organic materials
processing capacity planning. For the unincorporated County areas, DPW Solid Waste Planning &
Recycling works with franchise waste and recycling haulers to provide organics collection services to
residents and businesses. DPW Solid Waste Planning & Recycling also provides technical assistance,
education and outreach materials on reducing and managing organic waste, free composting
workshops and subsidized bin sales, and free indoor collection containers (while supplies last).
However, transporting compost and mulch from facilities to farms incurs costs from fuel, equipment,
and labor. These costs may be prohibitive, especially for small farms which have different economic
realities than large farms and agriculture operations. The San Diego region has thousands of farms
that are 10 acres or fewer,ii so regional incentive structures will need to account for the differing
economics of the region’s farms to ensure efficient and equitable access to this carbon farming
option.
5.3.3 Policy implications
First, localized data from farms, orchards, pastures, and rangelands will be crucial to
understanding the carbon storage benefits of different carbon farming techniques. There are
significant uncertainties associated with the USDA and CDFA’s data that underlie the COMET
planner tools,12,65 largely because soil systems are complex and nuanced and because soil
carbon storage is highly dependent on local conditions.12,27,29 Thus, improved data for local
agricultural productions would enhance the region’s understanding of agricultural carbon fluxes
and would better inform carbon farming techniques and policies.
i SANDAG. Appendix X: 2016 Greenhouse Gas Emissions Inventory and Projections for the San Diego Region.
https://sdforward.com/docs/default-source/2021-regional-plan/appendix-x---2016-greenhouse-gas-emissions-
inventory-and-projections-for-the-san-diego-region.pdf?sfvrsn=8444fd65_2 (2021). ii For more information, see: https://www.sandiegocounty.gov/content/dam/sdc/lueg/docs/State-of-the-Food-
System-for-the-San-Diego-Region-November-2019.pdf
Oct. 11, 2022 Item #12 Page 232 of 560
194
Second, cost data should be collected and incorporated into carbon farming analyses. Many
carbon farming techniques have high costs because they require additional or specialized
machinery. For example, no-till agriculture prevents soil carbon losses from tilling but requires
specialized machinery for seeding. Conversely, compost application requires a much smaller
investment into a tractor attachment and is therefore cheaper for the farmer while still offering
climate farming benefits.52 Further, data collection can be costly and there is little economic
incentive for farmers to independently engage in regular soil testing to track carbon storage.74
Thus, cost-effectiveness and/or cost-benefit analyses of carbon farming should incorporate the
costs of the associated new equipment investments, soil testing, and marginal operating and
management expenses to inform incentivizing or otherwise reducing the costs of carbon
farming.
Third, climate farming should be voluntary, incentivized, and responsive to on-the-ground
conditions and farmer feedback. Investments in climate farming are not without costs and
farmers facing difficult financial decisions should not be required to engage in additional
practices that would incur additional financial costs, like purchasing new equipment or hiring
additional staff, and opportunity costs, like spending time on training or searching for
equipment, employees, or technical help. Instead, the region should actively assist farmers who
are able and willing to engage in climate farming to reduce the financial and time burdens
associated with new techniques to maximize engagement and minimize costs to the farmer.
Additionally, incentives can be structured based on the lessons learned by programs that
currently help farmers engage in climate farming. Regional climate farming efforts should
incorporate feedback from ongoing work by collaboratives, non-profits, and extension services.
Finally, stakeholder input generally agreed that the region’s incentive structures are not set up
to incentivize carbon farming in the region. As Batra notes, farmers in unincorporated San
Diego County face myriad economic challenges, including tree losses from climate change and
the increasing prices of water.52,74 There seems to be high agreement that local farmers need
financial assistance to address their carbon emissions and allow them to engage in carbon
farming, while not providing assistance would place an undue burden on farmers and farming
communities in the region. Policies addressing carbon farming will need to focus on
incorporating farmers’ experiences, concerns, and cost data as well as accurately characterizing
the co-benefits – like healthier soils, higher yields, and better soil water and nutrient retention,
which reduce water and fertilizer needs and may additionally provide ecosystem services – to
maximize carbon storage potential in an equitable manner.
Oct. 11, 2022 Item #12 Page 233 of 560
195
5.3.4 Policy recommendations:
● Support incentivized climate farming in the region to promote agriculture’s unique
ability among regional sectors to produce goods and negative emissions.
● Study local carbon farming techniques to better understand carbon storage and
sequestration potential, costs, associated ecosystem services, and economic benefits.
● Consider incentivizing tree planting in and around agricultural lands and additionally
incentivizing farmers to retain existing trees.
● Engage farmers and other stakeholders to create carbon farming policies that are
equitable, just, and beneficial to farmers and farming communities.
● Support farmers and other stakeholders who are already engaged in climate farming to
foster community knowledge sharing for carbon farming.
5.4 Blue Carbon and Sea Level Rise
5.4.1 Introduction
Blue carbon generally refers to the carbon storage and sequestration potential in vegetated
coastal ecosystems, like eelgrass beds, marshes, wetlands, and mangrove forests, but it
sometimes specifically refers to restoring vegetated coastal ecosystems to improve carbon
sequestration and storage.20,39 Coastal ecosystems are known for their many ecosystem
services, including economically valuable services such as storm surge reduction, wave action
and wind buffering, commercially important fish nursery habitats, and air and water quality
improvements.20,66 These have historically been important reasons to protect and restore blue
carbon and coastal ecosystems, but many coastal ecosystems are now being protected because
they also collectively store disproportionately higher levels of carbon per unit area than most
ecosystems, and can do so on the order of millennia.38,41,75
The San Diego region historically contained over half of the Southern Californian Bight’s blue
carbon habitats (~11,000 hectares), much of which was in the Mission and San Diego Bays.
Since mapping efforts began around 1850, it is estimated that the San Diego region has lost
approximately 69% of its historic wetlands through conversion to non-wetland systems like
urban development.76 Wetlands throughout the region are susceptible to land use change, sea
level rise, and invasive species, all of which would reduce or eliminate annual carbon
sequestration and would emit CO2 and methane currently stored in the soils.17,20,47,48 As with
terrestrial carbon storage and sequestration, the primary methods of maintaining or enhancing
blue carbon are through the protection of existing wetland ecosystems and restoration of
degraded or lost wetland ecosystems.
Oct. 11, 2022 Item #12 Page 234 of 560
196
The San Diego region has lost eelgrass beds, salt marshes, mudflats, coastal riparian zones, and
other intertidal zones39,48,76 and is expected to continue to lose these habitats into the
future.42,46,60 Of these lost ecosystems, only some will be ecologically eligible for
restoration,17,48 which highlights the importance of both protecting existing ecosystems and
restoring degraded or lost ecosystems wherever possible.
Wetland degradation or destruction imposes two significant costs that warrant protecting them
from damage. First, the one-time releases of stored CO2 and methane will be significant
because wetlands have a higher density of carbon storage per unit area than other regional
ecosystems.38,39,41 These positive emissions would be costly to offset, where preventing these
emissions is less costly. Second, wetland restoration is expensive,12,21,22 costing at least as much
as comparable non-forest restoration while yielding less annual sequestration.12,77
Despite these costs, there are strong economic reasons to restore lost or degraded wetlands,
including substantial ecosystem services and preventing CO2 emissions from degraded
wetlands. An estimate by The Nature Conservancy of California found that wetland restoration
in California would result in over $1 billion of avoided climate-related damages due to
ecosystem services provided by expanded wetlands.17 This further highlights the importance of
existing wetlands, which currently provide those services at no cost, and supports the need to
study and invest in wetland restoration in the region. While healthy wetlands contribute
meaningfully to negative emissions, degraded or inundated wetlands are predicted to emit
more CO2 than they sequester. This could occur through sea level rise (SLR), land use change, or
other natural or anthropogenic impacts. Wetland restoration and wetland migration, which is
natural or anthropogenic land use change of upland ecosystems to wetlands as sea water
inundation occurs, can mitigate some wetland loss and associated carbon emissions.42,47,48
Given the inevitability of SLR and of other impacts of climate change,78 restoring wetland and
other blue carbon habitats will be important to blue carbon’s ongoing contributions regional
negative emissions and to critical ecosystem services that can bolster coastal climate
resilience.45,78,79
This analysis focused on wetlands and the potential loss of blue carbon habitats with SLR
because regional wetlands are well mapped and the loss of wetlands with sea level rise is well
studied. However, eelgrass habitats will also be affected by sea level rise, that eelgrass beds are
critical blue carbon habitats, and that further study of eelgrass beds is critical to understanding
regional NCSs (See Box 5.2).
Oct. 11, 2022 Item #12 Page 235 of 560
197
Box 5.2 – Eelgrass
Eelgrass, which is also known as seagrass, grows in populations called eelgrass beds. Eelgrass beds are
areas of shallow coastal and bay habitats where the dominant vegetation is Zostera marina or Z.
pacifica, are important blue carbon habitats.38,41,80 As with marshes, they sequester carbon as they
grow and are capable of storing carbon in their immediate surroundings as tissue and as compounds
deposited into sediments.38,81 Eelgrass is slightly less efficient at sequestering and storing carbon than
marshes and other wetlands, but they play an important role in sequestering carbon and offer many
unique co-benefits, like creating habitat for marine life, reducing turbidity, and improving water
quality.38,80
Beyond the traditional carbon sequestration that plants provide, eelgrass beds offer two additional
decarbonization benefits that are unique. First, eelgrass utilizes dissolved carbon in the water for
photosynthesis. This dissolved carbon acidifies the water and is the primary driver behind the
phenomenon of ocean acidification that causes ecological harm, perhaps most famously in leading to
coral bleaching events. As such, eelgrass beds reduce the acidity of their immediate surroundings,
which may offer some ecological benefits to other species and/or may facilitate additional drawdown
of atmospheric CO2.81–83 Second, eelgrass is capable of transporting some of its sequestered carbon to
the deep ocean.40 This means that restoring and protecting eelgrass beds will ensure that, on average,
some fraction of the sequestered carbon will be locked away in the deep ocean for thousands to tens
of thousands of years.40 Thus, eelgrass beds can offer some of the only NCSs that are essentially
permanent.
Eelgrass beds are also unique because they may potentially benefit from more CO2 in the water. The
excess CO2 from the atmosphere dissolves into the ocean and forms a weak acid which creates the
“ocean acidification” phenomenon where global ocean pH has shifted to be more acidic.84 While most
marine plants, algae, and animals are reacting negatively to ocean acidification, there is some evidence
that eelgrasses are potentially limited by carbon availability (in the form of dissolved CO2) and that
their growth, and thus their carbon sequestration and storage potential, may increase with increasing
ocean acidity because there is more carbon available for photosynthesis.82
Although eelgrass beds are submerged, they require sunlight to penetrate strongly enough through the
water column to fuel photosynthesis and will thus be impacted by sea level rise. Studies by Merkel &
Associates, Inc. have shown that water depth is a primary factor that limits eelgrass distribution in the
region’s bays and inland water systems.55,57 This suggests that SLR may make some current eelgrass
beds too deep for eelgrass, while SLR may simultaneously create new eelgrass habitat out of newly
submerged marsh, wetland, or upland habitats. Overall, the impacts of sea level rise on eelgrass are
less certain and should be monitored to understand the impacts.
The San Diego region has coastal and inland bay eelgrass beds, but the former is in state waters and
are outside of the jurisdictional boundaries of San Diego governments. The Port of San Diego and the
Navy have jurisdiction over the eelgrass beds in the San Diego Bay and the City of San Diego has
jurisdiction over the eelgrass beds in Mission Bay.55,57
Eelgrass surveys and assessments for both the San Diego and Mission Bays have occurred for several
decades. These surveys estimated changes over time to eelgrass bed distribution and found that
eelgrass cover has changed significantly over time, with population blinking in and out.55,57,85 This
suggests that newer data will be important for understanding the current extent of eelgrass beds and
the associated NCSs. To this end, the Port of San Diego was awarded a $150,000 federal grant to study
the San Diego Bay’s eelgrass beds and the associated carbon sequestration in the San Diego Bay.86 This
study will be invaluable in helping regional agencies and authorities understand the negative emissions
of eelgrass beds and the impacts of water conditions on eelgrass beds.
Oct. 11, 2022 Item #12 Page 236 of 560
198
5.4.3 Results
The 1 foot of sea level rise that is anticipated to occur between 2030 and 2050 is projected to
result in a loss or ecosystem change of nearly 800 hectares of blue carbon habitats throughout
the region, an area approximately 1.4 times the size of downtown San Diego (Table 5.3, Figure
5.5).88 One foot of sea level rise will endanger approximately 180,112 MT CO2e that is currently
stored in marsh and wetland plants and soils. Some of this would be emitted directly into the
atmosphere.42 Additionally, if all 800 hectares of susceptible blue carbon habitats are lost (i.e.,
if they do not change to eelgrass beds or other habitats that could sequester carbon), then the
lost habitats would have been able to sequester approximately 1,715 MT CO2e per year (Table
5.3). To offset these one-time emissions and to sequester the CO2 that would have been
sequestered, a comparable level of new wetlands, marshes, and riparian habitats would need
to be restored prior to wetland inundation. However, such restoration efforts would merely
allow the region to break even by sequestering as much as is being emitted from blue carbon
habitats.
Figure 5.5 Some blue carbon habitats will be affected or lost under 1 foot of sea level rise in the San Diego region.
Blue areas in the map show blue carbon habitats that will be affected by 1 foot of sea level rise, which are
quantified by ecosystem category in Table 5.3. Insets show more detail of four of the regions with affected blue
carbon habitats.
Oct. 11, 2022 Item #12 Page 237 of 560
199
Table 5.3 Total blue carbon habitat area (hectares) affected by 1 foot of sea level rise, annual carbon sequestration
(maximum amount of carbon dioxide equivalent sequestration in metric tonnes per year that may be lost), and
long-term storage (maximum amount of carbon dioxide equivalent in metric tonnes that may be emitted upon
habitat type change) per blue carbon vegetation class.
Vegetation
classification
Total area affected by 1
foot of SLR (hectares)
Maximum lost annual
sequestration potential (MT
CO2e yr-1)
Endangered carbon
storage (MT CO2e)
Freshwater marsh 20 28 3,020
Mudflats/Saltpans 22 44 5,082
Riparian scrub 14 60.2 1,400
Salt marsh/estuary 726 1,582.68 170,610
Total terrestrial blue
carbon ecosystems 782 1,714.88 180,112
5.4.4 Discussion
As in the case of regional land use change in forests and non-forest terrestrial ecosystems,
protecting wetlands, marshes, mudflats, and riparian habitats from loss is the first-best option
because doing so both protects existing stored carbon stocks and ensures ongoing annual
sequestration. Protecting existing blue carbon habitats is especially important because they
hold larger quantities of carbon per unit area and for longer periods of time than San Diego’s
forest and non-forest ecosystems.38,56,60,77 Restoring lost or degraded blue carbon habitats and
enhancing existing blue carbon habitats will also be important because failing to do so may
result in greater carbon losses with SLR or other impacts.
Protecting, restoring, and enhancing blue carbon habitats can take many forms and will be
specific to each system. For example, the Kendall-Frost marsh in the northeast corner of
Mission Bay can be expanded such that it reconnects with Rose Creek, which would provide
sediment and freshwater inputs, both of which would naturally protect the marsh from some of
the effects of sea level rise.89 The active restoration of lost marsh habitat in the northeast area
and other areas of Mission Bay would thus serve to both increase carbon storage and
sequestration in Mission Bay while improving habitat quality and resilience.89–91 Jurisdictions
that utilize this NCS should utilize the most recent and localized data possible for their systems
to maximize the systems’ sequestration and storage potential.
Unlike regional land use change, which can generally be planned for and can thereby be
reasonably prevented, blue carbon ecosystem loss is inevitable given current estimations of sea
level rise and the dearth of options to prevent sea water inundation and flooding in low-lying
areas and ecosystems.20,42,46 Restoring or enhancing NCSs in other ecosystems to offset the
anticipated losses of blue carbon ecosystems will be expensive and likely impractical, given the
challenges of large-scale habitat restoration.12,17,53 Therefore, expanding existing blue carbon
Oct. 11, 2022 Item #12 Page 238 of 560
200
habitats to enable wetland migration and protecting existing blue carbon habitats from land
use change will be important NCSs in the region.
5.4.5 Policy implications
Wetland, marsh, and mudflat losses will significantly impact the ability of the region’s NCSs to
contribute to negative emissions. Local carbon sequestration and storage data for marshes,
wetlands, and eelgrass from organizations like the Scripps Institution of Oceanographyi (pers.
comm., Dr. Matthew Costa, July 22, 2021) and from the Port of San Diego are forthcoming,86, 91
which will improve the analysis of anticipated impacts from sea level rise. Nevertheless, the
unique threats of sea level rise and the eventual emissions from blue carbon and other low-
lying ecosystems should be accounted for in decarbonization plans, even if data are imperfect.
5.4.6 Policy recommendations:
● Protect existing carbon storage pools and annual sequestration in blue carbon
ecosystems from anthropogenic land use change.
● Collaborate with organizations and governments to study the feasibility and costs of
wetland migration, wetland restoration, and carbon sequestration enhancement in
existing wetlands. Collaborate regionally and inter-jurisdictionally to implement blue
carbon restoration where feasible and possible.
● Collaborate with organizations and governments to study local blue carbon values to
improve blue carbon accounting in the region.
5.5 Urban Forestry and Greening
5.5.1 Introduction
Urban forestry refers to managing trees that were planted or maintained in some manner
within urban or suburban boundaries.92–94 Urban greening refers to establishing any plants in
urban or suburban areas, including trees. Trees are often planted in urban settings because
they provide ecosystem services like reducing air pollution, providing shade that cools
buildings, reducing urban stormwater runoff, increasing aesthetic value, reducing noise, and
other services.17,92,93 However, urban trees are also being recognized for their contributions to
negative CO2 emissions because their growth reduces atmospheric CO2.17,95,96 Urban forestry
and urban greening provide the only NCSs for urban areas and settlements, so it is critical for
such areas to have urban trees to sequester carbon in lieu of natural landscapes. These trees
also provide co-benefits like ecosystem services that were lost to land use change and can
provide these and other co-benefits to communities, including those disproportionately
i Personal communication with Dr. Matthew Costa, July 22, 2021.
Oct. 11, 2022 Item #12 Page 239 of 560
201
affected by poor air quality, high temperatures, and little shade or green space.17,92
There are, however, some important caveats to urban forestry in particular that are worth
consideration in the San Diego region. First, trees in urban, suburban, and highly developed
areas are more stressed than trees in natural landscapes and thus have shorter lifespans on
average. However, they can still sequester and store carbon throughout their lifetimes, which
can be more than 40 years.97 These shorter lived urban trees will require more frequent
replacement than naturally occurring trees in natural landscapes, which will need to be
factored into planning. Second, if urban trees require large inputs that rely in some sense on
fossil-fuels, like water pumped by carbon-based energy or synthetic fertilizers, then urban
forests may not sequester enough carbon to offset their maintenance-related emissions.97
Third, the species of tree planted has large implications for carbon sequestration, life
expectancy, water and maintenance needs, and potential co-benefits, highlighting the
importance of careful tree selection based on local conditions and needs. Generally, native
trees and shrubs should be prioritized, but drought tolerant non-native trees can also be
successfully and appropriately utilized. Invasive trees should not be planted.i; 97–99 Fifth, as trees
reach the end of their lives, they will need to be replaced for the urban forest to continue to
provide services. Thus, tree planting goals may be too low as urban forests age and die.100
Finally, urban greening often focuses on trees because of their ability to provide unique services
like shading and subsequent cooling, but regional greening should also include planting native
or non-native, drought tolerant shrubs and plants. These plants can offer aesthetic value, air
pollution mitigation, water quality improvements, improved habitat and biodiversity, and
carbon storage while generally requiring fewer inputs than trees.17,92,101
5.5.2 Discussion
In a 2003 San Diego regional analysis, the non-profit American Forests produced a report of the
tree cover in the City of San Diego and 22 surrounding cities and communities and found that,
collectively, these urban forests stored 640,846 MT of carbon and sequestered 4,864 MT of
carbon annually.92 Despite the significant sequestration and storage values, the study region
lost 29% of its tree cover from 1985 to 2002.92 While California as a whole has steadily gained
tree cover and urban carbon sequestration since 1990,95,102 the San Diego region has not seen
similar gains and thus has the potential to create substantial negative emissions through
expanding urban tree cover.17,92,100
i For a more detailed discussion of utilizing native species in regional landscaping, urban greening, and urban
forestry, see the report “San Diego County Native Landscape Program: Program Recommendations by the San Diego County Biodiversity Working Group,” (2022) available here:
https://sdcanyonlands.egnyte.com/fl/XwA3spNiVx#folder-link/?p=5aad0f52-d7f1-4f70-9dd2-c7b82f4924c8
Oct. 11, 2022 Item #12 Page 240 of 560
202
A 2021 national report by American Forests projected carbon storage and sequestration based
on anticipated tree plantings and assuming a 1% die back rate of existing trees using current
carbon storage and sequestration values, recognizing that there will be climate-related
feedbacks to tree growth and life expectancy in response to localized climate change.100 The
report found that the San Diego region is expected to increase its urban tree carbon storage by
approximately 6 MMT of carbon and to increase its annual sequestration rate by 0.32 MMT of
carbon per year from 2010-2060 through urban tree expansion alone.100 The report also noted
that the San Diego region is expected to see an increase in avoided emissions as urban trees are
expected to reduce electricity use for cooling, though, importantly, there will be increased
emissions with urban expansion and overall avoided emissions will be reduced through the loss
of natural lands.100
An analysis by The Nature Conservancy of California found that the San Diego region had
111,763 acres of urban land that was suitable for urban forestry or other greening.17,103 At an
average sequestration rate of approximately 18 MT of CO2e per acre per year,17,99 the report
estimates that fully foresting the San Diego region’s urban areas would result in over 2 MMT
CO2e of annual sequestration.17,103 This roughly equals the estimated annual sequestration in
Section 5.2, though it is important to note that the costs associated with planting such an
extensive urban forest in the region would be significant. This is due to both the upfront costs
of purchasing saplings, trees, or seeds in addition to the labor to initially plant that many trees
and the ongoing marginal costs of maintaining an urban tree, which are higher than maintaining
a tree in NWLs.i Additionally, as the region’s climate changes, hotter, drier conditions may
increase the water input costs and/or the urban tree mortality rate, which would decrease the
sequestration potential. This further underscores the importance of species selection during
urban greening planning and implementation.
Though these estimates from The Nature Conservancy are rough because they are not based on
extensive field data, estimates still highlight the importance of greening the region’s urban
areas as an NCS. As cities and municipalities throughout the region set and achieve tree
planting goals, it will be important to account for accurate, localized carbon stock and
sequestration values based on species, tree age, tree health, and growing conditions.
Additionally, it will be important for jurisdictions to account for both the electricity savings due
to trees’ cooling effects and to account for the emissions from inputs like watering, tree care,
fertilizers, and other inputs.
5.5.3 Policy Implications
Urban forestry is an important NCS for urban and developed areas because it can sequester and
i See Fargione et al., 202153 for a discussion of some of the costs of producing and planting a large number of trees.
Oct. 11, 2022 Item #12 Page 241 of 560
203
store carbon in an environment that is otherwise unable to provide negative emissions,
replacing some of the natural sequestration and storage that was lost with development.92
Their numerous co-benefits and their ability to increase equity and improve social welfare
through air and water quality improvements, cooling effects, aesthetic improvements, and
more are also important reasons to increase urban canopy cover and urban tree
distribution.101,104 However, as an NCS, urban trees pale in comparison to natural systems, so
the first best choice from a decarbonization perspective is to protect and enhance natural
systems that more efficiently generate negative emissions, rather than expand urban areas and
try to offset the damage with urban foresting and greening.12,17,21,29,100
There are ways to increase urban tree carbon sequestration and storage potential and
maximize their ability to sequester and store CO2. First, governments can choose tree species
and adjust tree management practices to maximize carbon benefits. Ideally, species would be
large, long-lived, low-maintenance trees with low water requirements that are well-suited for
the local climate and are not invasive.97 This choice could increase the lifespan of the tree,
increase the lifetime of carbon storage, and reduce total carbon-intensive inputs, like water,
during the tree’s lifetime. Second, governments can integrate tree planning into public land
maintenance and work with private landowners to plan tree locations to maximize cooling
effects on structures or surfaces.97 These locations need to be carefully balanced with providing
defensible space in areas prone to fire. Third, governments can empower and encourage local
communities to collect data on trees in their areas to inexpensively improve overall urban tree
data.92 These data can inform distribution, size, and species urban forest information that can
aid decision-makers in crafting urban forestry policies that will increase carbon storage and
sequestration while providing local co-benefits equitably. Fourth, there are funding
opportunities from the State that the region can utilize and there are initiatives in other regions
and states that the San Diego region can imitate. For example, CARB has provided funding in
the past for urban tree planting and funding available for such efforts should be utilized by
regional authorities when possible.105 Additionally, Washington State’s investments in urban
forestry can serve as an example to local jurisdictions for structuring funding and
implementation plans.106 Finally, local efforts by non-profits, community organizations, and
private companies to plant trees in communities can be promoted, and supported to foster
urban forestry, greening, and regional collaboration.
5.5.4 Policy recommendations:
● Plant trees that maximize lifetime net negative emissions and net carbon storage.
● Plan tree planting locations in public spaces to maximize co-benefits like shade and
provide information and education to private landowners to assist in tree planting
location choices on private land.
Oct. 11, 2022 Item #12 Page 242 of 560
204
● Governments and agencies can collect data on urban forests and actively support non-
profits and community members to also collect data.
● Where feasible and in alignment with community and land management needs, goals,
and visions, protect existing trees from dying to extend carbon sequestration and
storage.
5.6 Additional Natural Climate Solutions
There are other NCSs that are applicable to the region but that were not investigated in this
report, due to either a lack of local data or their limited applicability in terms of negative
emissions and/or geographic extent. Nevertheless, they may be relevant to some areas, may
become more important in the future, or more data and research may elucidate their negative
emissions value in the future.
5.6.1 Tree planting in public, non-urban lands
There are ongoing restoration efforts throughout the region that focus on planting native trees
in areas that have lost them. Tree planting in the region is occurring on tribal, private, state,
federal, and local lands, though there are no comprehensive datasets detailing these efforts.
Some data are being collected, but they may not yet be complete or publicly available. As an
example, the County of San Diego’s Department of Parks and Recreation (DPR) has instituted
two tree-centered NCS programs in County-owned and managed public lands. First, DPR has a
program to protect and preserve old, large trees during prolonged drought periods.107 Under
the conditions associated with severe and/or prolonged droughts, trees become more
susceptible to death or disease, and losing older trees has disproportionately large impacts on
carbon sequestration and storage. In general, older trees are larger and thus have higher
annual sequestration rates, storing more carbon in any given year and in their lifetimes.108 By
protecting these trees, DPR has an outsized impact on the negative emissions where those
trees are. Second, DPR has a tree planting program that is working to plant trees in County
parks and preserves to increase negative emissions.i This program has the goal to plant at least
3,500 trees a year and to replace every dead or dying tree with three new trees. In this way, the
program will mitigate tree loss and strengthen carbon sequestration into the future.
Additionally, this program provides an excellent model for NCSs in the region because of its
focus on planting native species.109,110 Native species are more resilient because they have
i This tree planting program is a part of the County’s 2018 CAP. Although the CAP was not formally approved, the
tree planting program has continued to increase negative emissions, offer co-benefits to the unincorporated areas,
and meet or exceed goals. This program was analyzed in Chapter 9’s CAP analysis and is one of the few examples of how NCSs were incorporated into CAP planning. More details on CAP contributions to regional decarbonization
commitments can be found in Chapter 8 section 8.8.
Oct. 11, 2022 Item #12 Page 243 of 560
205
evolved to live in the region and may be less susceptible to drought, more adapted to seasonal
resource availability, and better able to provide co-benefits like biodiversity or habitat for other
native species.32,97,109
As more data on tree planting and restoration efforts on public, private, and tribal lands
become available, they can be integrated into negative emissions estimates and can facilitate
decision-making, which may include incentives to engage in or continue such NCSs.
5.6.2 Non-forest management
Despite the fact that the region is dominated by chaparral, coastal sage scrub, and other shrub
habitats, there are few resources available for non-forest management, which is management
of shrub-dominated habitats, savannahs, woodlands, or other non-forest ecosystems.
Conversely, forest management, which includes actions like thinning or prescribed burns to
manage forest health and minimize large wildfire risk, is well studied. As such, non-forest
management practices were not investigated in this chapter. However, there are many
agencies and jurisdictions in the region that are managing non-forest ecosystems and the
associated changes to carbon storage or sequestration resulting from this management should
be studied and accounted for in regional NCSs.
Among the non-forest management techniques that could be researched and investigated are
habitat restoration and invasive species management, with a focus on removing non-native,
annual grasses and forbs. Local studies have demonstrated that chaparral systems that are
invaded by non-native, annual grasses have diminished sequestration and storage potential.30
As such, managing these grasses and other non-native plant species can enhance regional NCSs.
Further, non-native, annual plant species invasions are correlated with increased fire risk and
increased fire intensity because they provide fuel between shrubs and that may lead to a larger
fire footprint and/or hotter fires.37,111 Frequent and/or hot wildfires can contribute to
ecosystem shifts and habitat loss, both of which may reduce a landscape’s overall carbon
storage capacity and/or its annual sequestration potential.34,37,44 Finally, non-forest
management techniques that minimize invasive plant species cover can also help chaparral and
scrub ecosystems rebound after a wildfire and resume carbon sequestration faster.34,37 A large
soil seedbank of non-native species can hinder native seedling growth, so managing for invasive
species can assist in ecological resilience.37
5.6.3 Fire management
Beyond the reduced wildfire frequency and/or intensity resulting from managing invasive plant
species, other fire management techniques can prevent or minimize carbon emissions from
wildfires. Given that nearly every contemporary wildfire in the San Diego region has been
Oct. 11, 2022 Item #12 Page 244 of 560
206
ignited by a human-related source,35 preventing anthropogenic ignitions is critical to reducing
the frequency and overall impacts of wildfires. Some wildfire prevention and management
strategies include road, infrastructure, or home hardening, which can minimize sparks from
vehicle or infrastructure ignition sources that can start wildfires and simultaneously minimize
property damage and/or loss.112–114 These management techniques are ongoing in the region,
with opportunities to expand them through education campaigns and to better understand the
NCSs associated with reducing wildfire intensity and/or frequency in the San Diego region.
5.7 Regional Natural Climate Solutions Policy Recommendations and
Conclusions
As the County of San Diego and other governments in the San Diego region plan for
decarbonization to meet their emissions and climate goals, NCSs will be an important part of
the regional carbon accounting. NCSs and NWLs contribute to decarbonization through
sequestering atmospheric carbon annually and through storing atmospheric CO2 in plant tissues
for the medium to long-term. However, NWLs can also contribute to regional emissions when
they are lost or damaged due to development, natural disasters like wildfires, or climate change
induced ecosystem changes like sea level rise. General policy recommendations for carbon
sequestration and storage through NCSs follow.
5.7.1 Sequestration
The simplest, cheapest, most effective regional policy to contribute to NCSs is to prevent land
use change and allow NWLs to continue to sequester carbon naturally. The San Diego region
has a large quantity of conserved lands and has plans to conserve more,54 so continuing to
protect conserved lands and expanding protections to additional areas will provide annual
carbon sequestration and low to no cost negative emissions of more than 2 million tons of CO2e
stored annually. Other NCSs like reforestation, forest management, or other restoration
techniques, are typically highly effective at removing CO2, but they are almost universally more
expensive than protecting existing carbons sinks.21,22 Regional governments and agencies can
contribute to regional net negative emissions through preventing land use change among their
NWLs. In addition to continuing conservation and preservation efforts, governments can
research or partner with research groups to better characterize the carbon sequestration
potential in the region’s NWLs. Doing so will allow for better carbon accounting, reduce
uncertainties, and inform better management policies and practices to maximize NCSs.
Regional governments can research and incentivize carbon farming techniques like compost
application, riparian restoration, and orchard tree retention. Additional research should
investigate how rangeland tree planting, no-till agriculture, crop choice, manure management,
Oct. 11, 2022 Item #12 Page 245 of 560
207
and grazing/livestock feed management affect agricultural emissions. Carbon farming is widely
considered to be the best way to transform the agricultural sector from a carbon source to a
carbon sink and will likely be important for the San Diego region’s decarbonization
efforts.12,22,43,52
Wetlands, marshes, and other blue carbon ecosystems contribute less to annual sequestration
than tree and shrub-dominated ecosystems, but nevertheless play an important role in total
carbon sequestration. Protecting these systems from land use change and restoring them will
contribute to continuing sequestration in the near-term. Restoration of surrounding habitats
may allow blue carbon habitats to migrate as sea level rise inundates coastal areas, thereby
allowing blue carbon systems to continue to sequester carbon in the medium and long-term.
Last, local governments should continue to increase the urban tree canopy and other greenery
cover because these trees and shrubs turn settlement areas into carbon sinks (Table 5.2).
Additionally, governments can select tree species and location selections to maximize carbon
sequestration rates, minimize inputs like water, and maximize co-benefits. The latter will be
especially important as governments pursue environmental justice policies that aim to provide
public goods to disadvantaged and low-income communities.
There are additional NCSs to increase sequestration rates that were not investigated here but
which are important to consider. For example, while forest management is not widely
applicable in the region, non-forest management of chaparral and scrub ecosystems may
improve regional sequestration rates and data gaps should be filled to better understand
effectiveness and cost.
5.7.2 Storage
As with carbon sequestration, the simplest and cheapest way to maintain the naturally stored
carbon is to protect NWLs from land use change. By protecting existing carbon storage, the
region can prevent large one-time emissions from land use change. Beyond protecting lands
from intentional land use change, governments can research carbon storage values in the
region to characterize the magnitude of stored carbon. Such efforts would elucidate the role of
NWLs and help the region understand long-term land use carbon accounting under different
development strategies.
Similarly, blue carbon ecosystems are particularly adept at storing large quantities of carbon
and are therefore disproportionately vulnerable to generating large emissions if they are lost.
Wetlands, marshes, and other coastal systems should be actively protected from land use
change and should be restored and enhanced when possible. Such efforts would both increase
coastal carbon storage and prepare for loss due to sea level rise. Improved understanding of
Oct. 11, 2022 Item #12 Page 246 of 560
208
blue carbon ecosystems would provide similar relevant information as for other land uses in the
region, and it would similarly inform emissions under different development and restoration
strategies.
Agricultural lands hold carbon primarily in trees, like orchard trees, and in soils. Some carbon
farming techniques, like composting and riparian restoration, are likely to increase stored
carbon in agricultural lands. These techniques, and other carbon farming techniques, will have
variable effects by locality, and should thus be researched and better characterized. Regardless
of carbon farming, agricultural lands store more carbon than barren landscapes or settlements
that do not have urban trees. As such, preventing land use change can also be an important
measure for active, productive agricultural lands.
Urban trees and vegetation lead to the only carbon storage that occurs in settlements and
urban areas. These trees, shrubs, and other green spaces are not as efficient at storing carbon
as the native ecosystems that were historically present, however, they still provide medium-
term carbon storage and should be protected and expanded. There are important opportunities
for communities to invest in maintenance of existing trees so overall mortality is reduced.
Carbon storage and other ecosystem services are highest with mature trees, and it will take
newly planted trees significant time to provide the carbon and ecosystem services of the older
trees they replace. However, some mortality is inevitable, and as urban trees die, they should
be replaced with appropriate species to maximize total carbon storage and carbon storage
longevity while also minimizing lifetime inputs, like water.97
Finally, some NCSs that can protect or enhance carbon storage were not included here but are
still important to consider. For instance, wildfire prevention via educational programs and
infrastructure hardening will reduce wildfire emissions and will allow natural systems to
regenerate after wildfires and recover the emitted carbon as plants regrow.34
5.7.3 Future research, alignment, and uncertainty
This chapter has identified ways that natural, working, and urban lands are contributing to
regional decarbonization. It has also highlighted areas for future research and work. Primary
among these are that more regional and localized data can be incorporated into future decision
making to better account for regional NCSs. Additionally, regional governments should quantify
the full breadth of co-benefits and ecosystem services provided by NWLs, carbon farming, blue
carbon, and urban forestry. A wide array of co-benefits should be considered, quantified, and
maximized in addition to carbon sequestration and storage, including: water savings;
groundwater recharge; air and water quality regulation; soil stabilization and erosion control;
soil fertility and maintenance; protection of people and property from storm surges, inland
flooding, and other natural hazards; pollination and pest regulation; livestock fodder
Oct. 11, 2022 Item #12 Page 247 of 560
209
production; recreation opportunities and resulting benefits to physical and mental health;
biodiversity protection; and wildfire risk reduction. A key consideration for these co-benefits is
who benefits and who may be left behind. While carbon sequestration benefits the world
equally wherever it occurs, most other ecosystem services are highly context dependent– their
value varies spatially based on the path of their delivery and the location and activity of the
people who need them. NCS programs should be designed with this in mind to ensure an
equitable distribution of benefits to all people, especially the most vulnerable.
Further, the RDF has shown that the San Diego region can align with State and federal
initiatives and programs to improve regional decarbonization outcomes, fund regional projects,
foster collaboration inside and beyond the San Diego region to better facilitate information
sharing and learning. Regional alignment can and should include decarbonization specific
initiatives, like SB 1383, and can also extend to initiatives that will improve land management
and indirectly contribute to NCSs. Examples of State and federal initiatives include the State’s
30x30 initiative (which aims to protect and conserve 30% of the State’s terrestrial and marine
spaces by 2030, as laid out in California Executive Order N-82-20)115 and the national “America
the Beautiful” initiative (Presidential Executive Order 14008), which includes a “goal of
conserving at least 30 percent of our lands and waters by 2030”116 that will be driven by locally-
designed conservation strategies.117 These initiatives are aligned with this chapter’s findings
that protecting natural and working lands have important carbon sequestration and storage
benefits, in addition to the myriad other benefits. Regional participation in and alignment with
these collaborative efforts will be important both to producing local decarbonization outcomes
and to sharing insights and knowledge with other regions for their benefit.
This report’s analyses have some important uncertainties. These primarily stem from
unavailability of localized carbon storage and sequestration data. This is problematic because
local climate, prevailing fire regimes, ecosystem composition, and environmental stressors like
drought have significant impacts on any given local NCS effectiveness. Regional governments
should utilize the most recent and localized data possible when estimating NCSs’ contributions
to decarbonization. Data on local chaparral and blue carbon storage and sequestration are
forthcoming.i These data will be critical to understanding valuing regional land contributions to
negative emissions and long-term carbon storage.
i Personal communication with Zachary Plopper, Dr. Meagan Jennings, and Dr. Matthew Costa, 2021.
Oct. 11, 2022 Item #12 Page 248 of 560
210
Acknowledgements: The authors wish to thank Dr. Megan Jennings from SDSU, Dr. Matthew
Costa from the Scripps Institution of Oceanography, Zachary Plopper from the Surfrider
Foundation, Dr. Heather Henter from the UC San Diego Natural Reserve System for their
guidance and expertise on local ecosystem functioning and ongoing carbon sequestration
accounting efforts; Michael Wonsidler and Caitlin Lelles from the County of San Diego’s
Department of Public Works; Allison Wood, Anna Van, and Anna Lowe from SANDAG for
guidance on regional efforts to map carbon sequestration; Dick Cameron, Brian Cohen, and Dr.
Joe Fargione from The Nature Conservancy for advice on maps, framing, and sources; and
Jeffrey Myers from UC San Diego School of Global Policy and Strategy, Dr. Becky Chaplin-
Kramer from the Natural Capital Project, and Alex Cagle for reviewing and offering invaluable
edits and comments.
Works Cited:
1. Marchese, C. Biodiversity hotspots: A shortcut for a more complicated concept. Glob. Ecol. Conserv. 3, 297–
309 (2015).
2. Pairis, A. D. et al. Chapter 1: Introduction to San Diego’s Climate and Ecosystems. 1–11 (2018). In: Jennings,
M.K., D. Cayan, J. Kalansky, A.D. Pairis et al. San Diego County ecosystems: ecological impacts of climate
change on a biodiversity hotspot. California’s Fourth Climate Change Assessment, California Energy
Commission. Publication number: CCCA4-EXT-2018-010
https://drive.google.com/file/d/1nXmpWlDHkk9F49H_JdZXgTWxCcLdIrxN/view
3. The Nature Conservancy. San Diego County. The Nature Conservancy https://www.nature.org/en-us/get-
involved/how-to-help/places-we-protect/san-diego-county/ (2021).
4. Cowling, R. M., Rundel, P. W., Lamont, B. B., Kalin Arroyo, M. & Arianoutsou, M. Plant diversity in
mediterranean-climate regions. Trends Ecol. Evol. 11, 362–366 (1996).
5. Hung, K.-L. J., Sandoval, S. S., Ascher, J. S. & Holway, D. A. Joint Impacts of Drought and Habitat Fragmentation
on Native Bee Assemblages in a California Biodiversity Hotspot. Insects 12, 135 (2021).
6. Rebman, J. P. & Simpson, M. G. Checklist of the vascular plants of San Diego County. (San Diego Natural
History Museum, 2014).
7. Wisinski, C. Conservation: It’s Closer Than You Think. Saving Species - Institute for Conservation Research, San
Diego Zoo Global vol. 1 (2018).
8. Soule, M. E., Alberts, A. C. & Bolger, D. T. The Effects of Habitat Fragmentation on Chaparral Plants and
Vertebrates. 10 (1992).
9. California Department of Fish and Wildlife. BIOS Viewer, Version 5.96.99.
https://apps.wildlife.ca.gov/bios/?tool=cnddbQuick (2021).
10. Rojas, I. M. et al. A landscape-scale framework to identify refugia from multiple stressors. Conserv. Biol.
cobi.13834 (2021) doi:10.1111/cobi.13834.
11. Underwood, E. C. et al. The impacts of climate change on ecosystem services in southern California. Ecosyst.
Serv. 39, 101008 (2019).
12. Baker, S. E. et al. Getting to Neutral: Options for Negative Carbon Emissions in California.
https://www.osti.gov/biblio/1597217 (2019) doi:10.2172/1597217.
13. Potter, C. The carbon budget of California. Environ. Sci. Policy 13, 373–383 (2010).
14. Friedlingstein, P. et al. Global Carbon Budget 2020. Earth Syst. Sci. Data 12, 3269–3340 (2020).
15. U.S. Environmental Protection Agency. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2019.
https://www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks (2021).
16. Goldstein, A. et al. Protecting irrecoverable carbon in Earth’s ecosystems. Nat. Clim. Change 10, 287–295
(2020).
17. Chamberlin, S. J. et al. Nature-based Climate Solutions. 113 (2020).
Oct. 11, 2022 Item #12 Page 249 of 560
211
https://www.nature.org/content/dam/tnc/nature/en/documents/TNC_Pathways12-4.pdf
18. Roe, S. et al. Contribution of the land sector to a 1.5 °C world. Nat. Clim. Change 9, 817–828 (2019).
19. International Energy Agency. Net Zero by 2050 - A Roadmap for the Global Energy Sector. 224 (2021).
20. Canadell, J. G. et al. Global Carbon and other Biogeochemical Cycles and Feedbacks.
https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_Chapter_05.pdf (2021).
21. Griscom, B. W. et al. Natural climate solutions. Proc. Natl. Acad. Sci. 114, 11645–11650 (2017).
22. Fargione, J. et al. Natural climate solutions for the United States. Sci. Adv. 4, eaat1869 (2018).
23. Hanson, R. S. & Hanson, T. E. Methanotrophic bacteria. Microbiol. Rev. 60, 439–471 (1996).
24. Smith, P. et al. Agriculture, Forestry and Other Land Use (AFOLU). Edenhofer O R Pichs-Madruga Sokona E
Farahani Kadner K Seyboth Adler Baum Brunner P Eickemeier B Kriemann J Savol. Schlömer C Von Stechow T
Zwickel JC Minx Eds Clim. Change 2014 Mitig. Clim. Change Contrib. Work. Group III Fifth Assess. Rep. Intergov.
Panel Clim. Change Camb. Univ. Press Camb. U. K. N. Y. NY USA (2014).
25. Thomson, A. J., Giannopoulos, G., Pretty, J., Baggs, E. M. & Richardson, D. J. Biological sources and sinks of
nitrous oxide and strategies to mitigate emissions. Philos. Trans. R. Soc. B Biol. Sci. 367, 1157–1168 (2012).
26. Hénault, C. et al. Management of soil pH promotes nitrous oxide reduction and thus mitigates soil emissions
of this greenhouse gas. Sci. Rep. 9, 20182 (2019).
27. Li, C., Frolking, S. & Butterbach-Bahl, K. Carbon Sequestration in Arable Soils is Likely to Increase Nitrous Oxide
Emissions, Offsetting Reductions in Climate Radiative Forcing. Clim. Change 72, 321–338 (2005).
28. Sahoo, K. K., Goswami, G. & Das, D. Biotransformation of Methane and Carbon Dioxide Into High-Value
Products by Methanotrophs: Current State of Art and Future Prospects. Front. Microbiol. 12, 520 (2021).
29. Cook-Patton, S. C. et al. Mapping carbon accumulation potential from global natural forest regrowth. Nature
585, 545–550 (2020).
30. Luo, H. et al. Mature semiarid chaparral ecosystems can be a significant sink for atmospheric carbon dioxide.
Glob. Change Biol. 13, 386–396 (2006).
31. Veldman, J. W. et al. Where Tree Planting and Forest Expansion are Bad for Biodiversity and Ecosystem
Services. BioScience 65, 1011–1018 (2015).
32. Lewis, S. L., Wheeler, C. E., Mitchard, E. T. A. & Koch, A. Restoring natural forests is the best way to remove atmospheric carbon. Nature 568, 25–28 (2019).
33. Wheeler, M. M. et al. Carbon and nitrogen storage in California sage scrub and non-native grassland habitats.
J. Arid Environ. 129, 119–125 (2016).
34. Haidinger, T. L. & Keeley, J. E. Role of High Fire Frequency in Destruction of Mixed Chaparral. Madroño 40,
141–147 (1993).
35. Keeley, J. E. & Syphard, A. D. Historical patterns of wildfire ignition sources in California ecosystems. Int. J.
Wildland Fire 27, 781 (2018).
36. Syphard, A. D. et al. Human Influence on California Fire Regimes. Ecol. Appl. 17, 1388–1402 (2007).
37. Zedler, P. H., Gautier, C. R. & McMaster, G. S. Vegetation Change in Response to Extreme Events: The Effect of
a Short Interval between Fires in California Chaparral and Coastal Scrub. Ecology 64, 809–818 (1983).
38. Mcleod, E. et al. A blueprint for blue carbon: toward an improved understanding of the role of vegetated
coastal habitats in sequestering CO 2. Front. Ecol. Environ. 9, 552–560 (2011).
39. Ward, M. A. et al. Blue Carbon Stocks and Exchanges Along the Pacific West Coast.
https://bg.copernicus.org/preprints/bg-2021-27/bg-2021-27.pdf (2021) doi:10.5194/bg-2021-27.
40. Duarte, C. M. & Krause-Jensen, D. Export from Seagrass Meadows Contributes to Marine Carbon
Sequestration. Front. Mar. Sci. 4, (2017).
41. Howard, J. et al. Clarifying the role of coastal and marine systems in climate mitigation. Front. Ecol. Environ.
15, 42–50 (2017).
42. Kauffman, J. B. et al. Total ecosystem carbon stocks at the marine-terrestrial interface: Blue carbon of the
Pacific Northwest Coast, United States. Glob. Change Biol. 26, 5679–5692 (2020).
43. Cameron, D. R., Marvin, D. C., Remucal, J. M. & Passero, M. C. Ecosystem management and land conservation
can substantially contribute to California’s climate mitigation goals. Proc. Natl. Acad. Sci. 114, 12833–12838
(2017).
44. Keeley, J. E., Safford, H., Fotheringham, C. J., Franklin, J. & Moritz, M. The 2007 Southern California Wildfires:
Lessons in Complexity. J. For. 107, (2009).
45. ICF. Sea Level Rise Vulnerability Assessment - Draft. 68 (2019).
Oct. 11, 2022 Item #12 Page 250 of 560
212
46. Lindsey, R. Understanding Climate | Climate Change: Global Sea Level. NOAA Climate | News and Features
https://www.climate.gov/news-features/understanding-climate/climate-change-global-sea-level (2021).
47. Kroeger, K. D., Crooks, S., Moseman-Valtierra, S. & Tang, J. Restoring tides to reduce methane emissions in
impounded wetlands: A new and potent Blue Carbon climate change intervention. Sci. Rep. 7, 11914 (2017).
48. Southern California Wetlands Recovery Project. Wetlands on the Edge: The Future of Southern California’s
Wetlands: Regional Strategy 2018. (2018).
49. CARB. California 2030 Natural and Working Lands Climate Change Implementation Plan - January 2019 Draft.
(2019).
50. IPCC. Summary for Policymakers. In: Climate Change and Land: an IPCC special report on climate change,
desertification, land degradation, sustainable land management, food security, and greenhouse gas fluxes in
terrestrial ecosystems s [P.R. Shukla, J. Skea, E. Calvo Buendia, V. Masson-Delmotte, H.- O. Pörtner, D. C.
Roberts, P. Zhai, R. Slade, S. Connors, R. van Diemen, M. Ferrat, E. Haughey, S. Luz, S. Neogi, M. Pathak, J.
Petzold, J. Portugal Pereira, P. Vyas, E. Huntley, K. Kissick, M. Belkacemi, J. Malley, (eds.)]. In press.
https://www.ipcc.ch/site/assets/uploads/sites/4/2020/02/SPM_Updated-Jan20.pdf (2019).
51. Millan, B., Marsden, M. & Vasilakis, M. Solving Sprawl: Building Housing for a Sustainable and Equitable San
Diego . (2021).
52. Batra, P. Linking Climate-Friendly Farming Practices to San Diego County’s Climate Action Plan: An Opportunity
Analysis of Carbon Farming in the Unincorporated County. (2018).
53. Fargione, J. et al. Challenges to the Reforestation Pipeline in the United States. Front. For. Glob. Change 4,
629198 (2021).
54. SANDAG. The 2021 Regional Plan - Appendix AA: Regional Habitat Conservation Vision.
https://sdforward.com/mobility-planning/2021-regional-plan-draft (2021).
55. Merkel & Associates, Inc. 2017 San Diego Bay Eelgrass Inventory. (2018).
56. Ward, M. A. et al. Blue carbon stocks and exchanges along the California coast. Biogeosciences 18, 4717–4732
(2021).
57. Merkel & Associates, Inc. Eelgrass Mitigation and Monitoring Plan in Support of the Mission Bay Park
Navigational Safety Dredging Project - Mission Bay, San Diego, California. (2016). 58. Merkel & Associates, Inc. 12-Month Post-Transplant Eelgrass Survey – Mission Bay Harbor Dredging Project.
(2012).
59. MBC Aquatic Sciences. Mission Bay Eelgrass Restoration project.
https://www.mbcaquatic.com/project/mission-bay-eelgrass-restoration (2022).
60. McTigue, N. D., Walker, Q. A. & Currin, C. A. Refining Estimates of Greenhouse Gas Emissions From Salt Marsh
“Blue Carbon” Erosion and Decomposition. Front. Mar. Sci. 8, 661442 (2021).
61. CARB. An inventory of ecosystem carbon in California’s natural and working lands. (2018).
62. SANDAG. Appendix X: 2016 Greenhouse Gas Emissions Inventory and Projections for the San Diego Region.
https://sdforward.com/docs/default-source/2021-regional-plan/appendix-x---2016-greenhouse-gas-
emissions-inventory-and-projections-for-the-san-diego-region.pdf?sfvrsn=8444fd65_2 (2021).
63. County of San Diego. County of San Diego 2020 Crop Statistics and Annual Report.
https://www.sandiegocounty.gov/content/dam/sdc/awm/docs/2020CropReportSanDiego.pdf (2021).
64. County of San Diego. 2019 Report: State of the Food System.
https://www.sandiegocounty.gov/content/dam/sdc/lueg/docs/State-of-the-Food-System-for-the-San-Diego-
Region-November-2019.pdf (2019)
65. California Department of Food and Agriculture. COMET-Planner California Healthy Soils. http://www.comet-
planner-cdfahsp.com/ (2021).
66. Fargione, J. et al. Supplementary Materials for: Natural climate solutions for the United States. Sci. Adv. 4,
eaat1869 (2018).
67. Richards, C. & Caires, K. Carbon Farming Plan. 57 (2018).
68. City of San Diego. Climate Action Plan 2018 Annual Report Appendix. (2018).
69. City of San Diego. Sustainability Division | City of San Diego Official Website.
https://www.sandiego.gov/2020cap#ourclimate (2021).
70. Dudek. Evaluation of Greenhouse Gas Emissions Offset Availability within San Diego County.
https://www.ci.oceanside.ca.us/civicax/filebank/blobdload.aspx?BlobID=49641 (2018).
71. Hristov, A. N. et al. Special topics—Mitigation of methane and nitrous oxide emissions from animal
Oct. 11, 2022 Item #12 Page 251 of 560
213
operations: I. A review of enteric methane mitigation options. J. Anim. Sci. 91, 5045–5069 (2013).
72. Pape, D. et al. Managing Agricultural Land for Greenhouse Gas Mitigation Within the United States. US Dep.
Agric. (2016).
73. Skjellerudsveen, M. Carbon Farm Plan for Angels Farm. (2018).
74. Elmer, M. Farmers Want to Create San Diego’s Carbon Dumps. Voice of San Diego
https://www.voiceofsandiego.org/topics/science-environment/farmers-want-to-create-san-diegos-carbon-
dumps/ (2021).
75. Brevik, E. C. & Homburg, J. A. A 5000 year record of carbon sequestration from a coastal lagoon and wetland
complex, Southern California, USA. CATENA 57, 221–232 (2004).
76. Stein, E. D. et al. Wetlands of the Southern California coast: Historical extent and change over time. South.
Calif. Coast. Water Res. Proj. Tech. Rep. 826, 1–50 (2014).
77. Di Vittorio, A. V., Simmonds, M. B. & Nico, P. Quantifying the effects of multiple land management practices,
land cover change, and wildfire on the California landscape carbon budget with an empirical model. PLOS ONE 16, e0251346 (2021).
78. Sweet, W. V. et al. Global and Regional Sea Level Rise Scenarios for the United States: Updated Mean
Projections and Extreme Water Level Probabilities Along U.S. Coastlines. 111
https://aambpublicoceanservice.blob.core.windows.net/oceanserviceprod/hazards/sealevelrise/noaa-nos-
techrpt01-global-regional-SLR-scenarios-US.pdf (2022).
79. California Coastal Commission. California Coastal Commission Sea Level Rise Policy Guidance: Interpretive
Guidelines for Addressing Sea Level Rise in Local Coastal Programs and Coastal Development Permits. 307
https://documents.coastal.ca.gov/assets/slr/guidance/2018/0_Full_2018AdoptedSLRGuidanceUpdate.pdf
(2018).
80. Murray, B. C., Pendleton, L., Jenkins, W. A. & Sifleet, S. Green Payments for Blue Carbon. 52
https://nicholasinstitute.duke.edu/environment/publications/naturalresources/blue-carbon-report (2011).
81. Beer, S., Bjork, M., Hellblom, F. & Axelsson, L. Inorganic carbon utilization in marine angiosperms (seagrasses).
Funct. Plant Biol. 29, 349–354 (2002).
82. Zimmerman, R. C. et al. Experimental impacts of climate warming and ocean carbonation on eelgrass Zostera marina. Mar. Ecol. Prog. Ser. 566, 1–15 (2017).
83. Maurya, P., Das, A. K. & Kumari, R. Managing the Blue Carbon Ecosystem: A Remote Sensing and GIS
Approach. Adv. Remote Sens. Nat. Resour. Monit. 247–268 (2021) doi:10.1002/9781119616016.ch13.
84. NOAA. Ocean acidification. https://www.noaa.gov/education/resource-collections/ocean-coasts/ocean-
acidification (2020).
85. Merkel & Associates, Inc. Evaluation of Temporal and Spatial Changes of Eelgrass Beds Within San Diego Bay
Using Permanently Monitored Transects (2019-2020).
https://pantheonstorage.blob.core.windows.net/environment/2020-Naval-Evaluation-of-Temporal-and-
Spatial-Changes-of-Perennial-Eelgrass-Beds-within-San-Diego-Bay.pdf (2020).
86. Rodriguez, G. Port of San Diego Secures $150,000 to Study Blue Carbon in San Diego Bay’s Eelgrass. Port of
San Diego | General Press Releases https://www.portofsandiego.org/press-releases/general-press-
releases/port-san-diego-secures-150000-study-blue-carbon-san-diego (2021).
87. NOAA Office for Coastal Management. Sea Level Rise Data Download. https://coast.noaa.gov/slrdata/ (2017).
88. Walshok, M., Shapiro, J., SelfridgeBustos, G. & Carton, G. Downtown San Diego: The Innovation Economy’s
Next Frontier, report for the Downtown San Diego Partnership.
https://extension.ucsd.edu/UCSDExtension/media/UCSDExtensionsMedia/community-and-research/center-
for-research-and-evaluation/Downtown-Partnership-Demographic-Study_1.pdf (2015).
89. Everest International Consultants. ReWild Mission Bay: Wetlands Restoration Feasibility Study Report. 396
https://missionbaywetlands.files.wordpress.com/2018/12/rewild-mb_feasibility-study-report_final-
december-2018_with-preface-and-es.pdf (2018).
90. Elmer, M. The Mission Bay Mud That Could be Worth Millions. Voice of San Diego
https://www.voiceofsandiego.org/topics/science-environment/the-mission-bay-mud-that-could-be-worth-
millions/ (2021).
91. Garrick, D. How much carbon is buried under Mission Bay? Scientists seek to know. San Diego Union-Tribune
https://www.sandiegouniontribune.com/news/politics/story/2021-08-19/new-climate-change-study-will-
analyze-how-much-carbon-marshes-could-sequester-under-mission-bay (2021).
Oct. 11, 2022 Item #12 Page 252 of 560
214
92. American Forests. Urban Ecosystem Analysis San Diego, California: Calculating the Value of Nature. (2003).
93. McPherson, E. G. et al. The structure, function and value of urban forests in California communities. Urban
For. Urban Green. 28, 43–53 (2017).
94. U.S. Department of Agriculture, Forest Service. Urban tree canopy assessment: a community’s path to
understanding and managing the urban forest. 16 (2019).
95. Domke, G. M. et al. Greenhouse gas emissions and removals from forest land, woodlands, and urban trees in
the United States, 1990–2019. US Dep. Agric. For. Serv. North. Res. Stn. Resource Update FS-307, (2021).
96. SANDAG. Climate Action Portal. https://climatedata.sandag.org/ (2021).
97. Nowak, D. J., Stevens, J. C., Sisinni, S. M. & Luley, C. J. Effects of Urban Tree Management and Species
Selection on Atmospheric Carbon Dioxide. 10 (2002).
98. McPherson, E. G., Simpson, J. R., Peper, P. J., Scott, K. I. & Xiao, Q. Tree Guidelines for Coastal Southern
California Communities. 106 (2000).
99. Nowak, D. J., Greenfield, E. J., Hoehn, R. E. & Lapoint, E. Carbon storage and sequestration by trees in urban
and community areas of the United States. Environ. Pollut. 178, 229–236 (2013).
100. Nowak, D. J., Greenfield, E. J. & Ellis, A. Climate Change and Urban Forests. 93
https://www.google.com/url?q=https://www.americanforests.org/wp-content/uploads/2021/04/Nowak-
Study.pdf&sa=D&source=docs&ust=1658165838526864&usg=AOvVaw0IE3a4VNR8BQrPAXF0GXYw (2021).
101. Tree Equity Score & American Forests. Tree Equity Score. https://treeequityscore.org/ (2021).
102. Domke, G. M. et al. Appendix 1.–National Scale Estimates for Individual States, 1990-2019 in Domke, Grant
M.; Walters, Brian F.; Nowak, David J.; Smith, James, E.; Nichols, Michael C.; Ogle, Stephen M.; Coulston, J.W.;
Wirth, T.C. 2021. Greenhouse gas emissions and removals from forest land, woodlands, and urban trees in the
United States, 1990-2019. Resource Update FS-307. Madison, WI: U.S. Department of Agriculture, Forest
Service, Northern Research Station. 5 p. [plus 2 appendixes]. https://doi.org/10.2737/FS-RU-307. (2021).
103. The Nature Conservancy California. Nature-Based Climate Solutions.
https://tnc.maps.arcgis.com/apps/webappviewer/index.html?id=b6386378560a4c0496d5d0edafe56ce8
(2020).
104. Riley, C. B. & Gardiner, M. M. Examining the distributional equity of urban tree canopy cover and ecosystem services across United States cities. PLOS ONE 15, e0228499 (2020).
105. California Air Resources Board. California Climate Investments provided more than $1 billion for underserved
communities in 2019. https://ww2.arb.ca.gov/news/california-climate-investments-provided-more-1-billion-
underserved-communities-2019 (2020).
106. WA - DNR. Urban and Community Forestry. Washington State Department of Natural Resources
https://www.dnr.wa.gov/urbanforestry#grants-and-financial-assistance (2022).
107. County of San Diego Parks and Recreation. Heritage Tree Preservation Program.
https://www.sdparks.org/content/sdparks/en/news-events/news-archives/HeritageTreeProgram.html (2022).
108. Stephenson, N. L. et al. Rate of tree carbon accumulation increases continuously with tree size. Nature 507,
90–93 (2014).
109. County of San Diego. Climate Action Plan - Measure A-2.2 County Tree Planting. San Diego County Data Portal
https://data.sandiegocounty.gov/stories/s/A-2-2-County-Tree-Planting/q64d-hunj/ (2022).
110. County of San Diego. Expanding the number of trees in San Diego County. Climate Action Plan
https://www.sandiegocounty.gov/content/sdc/sustainability/news/CountyTreePlanting.html (2020).
111. Mann, M. L. et al. Incorporating Anthropogenic Influences into Fire Probability Models: Effects of Human
Activity and Climate Change on Fire Activity in California. PLOS ONE 11, e0153589 (2016).
112. Cal Fire. Defensible Space. Cal Fire Programs https://www.fire.ca.gov/programs/communications/defensible-
space-prc-4291/ (2022).
113. San Diego County Fire. California Wildfire Mitigation Program - Home Hardening Initiative FAQs. San Diego
County Fire / Fire Protection District https://www.sandiegocounty.gov/content/sdc/sdcfa/crr/ca-wildfire-
mitigation-program-/faqs.html (2022).
114. Smith, J. E. California to pay for wildfire retrofits up to $40,000 per home, starting with rural San Diego. San
Diego Union-Tribune (2022).
115. California Executive Order N-82-20 (October 7, 2020). https://www.gov.ca.gov/wp-
content/uploads/2020/10/10.07.2020-EO-N-82-20-.pdf
116. U.S. Executive Order No. 14008, pages 7619-7633 (January 27, 2021).
Oct. 11, 2022 Item #12 Page 253 of 560
215
https://www.govinfo.gov/content/pkg/FR-2021-02-01/pdf/2021-02177.pdf
117. U.S. Department of the Interior, U.S. Department of Agriculture, Council on Environmental Quality in The
White House, U.S. Department of Commerce, and the National Oceanic and Atmospheric Administration.
Conserving and Restoring America the Beautiful. (2021) https://www.doi.gov/sites/doi.gov/files/report-
conserving-and-restoring-america-the-beautiful-2021.pdf
Oct. 11, 2022 Item #12 Page 254 of 560
216
Appendix 5.A Methods, data, and sources for carbon stock and flow data and
sources
This analysis used SanGIS’s “ECO_VEGETATION_CN” (date of data: August 2021; downloaded August
2021) and “County_Boundary” (downloaded July, 2021) shapefiles downloaded from SanGIS
(SanGIS.org). The former shapefile contains the vegetation community type for the entire region. The
latter shapefile contains the San Diego County boundary. The layers were reprojected into California
Albers (ESPG: 6414) and invalid geometries were fixed. The ECO_VEGETATION_CN layer was clipped
using the County_Boundary to remove polygons that were in state waters or in other counties. The
resulting layer’s polygons show the San Diego region’s land uses (Figure 5.1). The areas were calculated
for each polygon and converted to hectares.
Carbon values were assigned to the Holland vegetation classes in the ECO_VEGETATION_CN dataset and
were merged into the region’s vegetation shapefile in QGIS. The polygon areas were multiplied by their
corresponding carbon storage and sequestration values to return each polygon’s carbon storage and
sequestration totals. These data were exported to Excel and aggregated by broad land use type based
largely on IPCC land use types. The IPCC’s forest category was disaggregated to forests, woodlands,
riparian, and shrublands; settlements were disaggregated to urban areas, disturbed areas, and
agriculture; grasslands were consolidated to only include grasslands and meadows; and barren areas
were disaggregated to water, barren (here meaning having no vegetation), and desert.
Values used to multiply polygon area by vegetation type are shown in Table 5.A.1. Eelgrass estimates
included San Diego Bay estimates from 2017 surveys and were multiplied by the eelgrass values in Table
5.A.1.
Table 5.A.1 – Carbon stock and flux multipliers by Holland vegetation class type and the sources.
LEGEND C stock (MT CO2eha-1) C flux (MT CO2e ha-1yr-1) Category
11000 Non-Native Vegetation 191 0.012 Disturbed
11200 Disturbed Wetland 2353 -1.074 Wetland
11300 Disturbed Habitat 191 0.012 Disturbed
12000 Urban/Developed 7.665 0.396,7 Settlement
18000 General Agriculture 378 0.388 Agriculture
18100 Orchards and Vineyards 378 0.388 Agriculture
18200 Intensive Agriculture - Dairies, Nurseries, Chicken Ranches 378 0.388 Agriculture
18300 Extensive Agriculture - Field/Pasture, Row Crops 378 0.388 Agriculture
18310 Field/Pasture 378 0.388 Agriculture
18320 Row Crops 378 0.388 Agriculture
21230 Southern Foredunes 0.159 0 Desert
22100 Active Desert Dunes 0.159 0 Desert
22300 Stabilized and Partially-Stabilized Desert Sand Field 0.159 0 Desert
24000 Stabilized Alkaline Dunes 0.159 0 Desert
25000 Badlands/Mudhill Forbs 0.159 0 Desert
31200 Southern Coastal Bluff Scrub 431 1.912 Scrub
Oct. 11, 2022 Item #12 Page 255 of 560
217
32000 Coastal Scrub 431 1.912 Scrub
32400 Maritime Succulent Scrub 431 1.912 Scrub
32500 Diegan Coastal Sage Scrub 431 1.912 Scrub
32510 Diegan Coastal Sage Scrub: Coastal form 431 1.912 Scrub
32520 Diegan Coastal Sage Scrub: Inland form 431 1.912 Scrub
32700 Riversidian Sage Scrub 431 1.912 Scrub
32710 Riversidian Upland Sage Scrub 431 1.912 Scrub
32720 Alluvial Fan Scrub 431 1.912 Scrub
33000 Sonoran Desert Scrub 431 1.912 Scrub
33100 Sonoran Creosote Bush Scrub 431 1.912 Scrub
33200 Sonoran Desert Mixed Scrub 431 1.912 Scrub
33210 Sonoran Mixed Woody Scrub 431 1.912 Scrub
33220 Sonoran Mixed Woody and Succulent Scrub 431 1.912 Scrub
33230 Sonoran Wash Scrub 431 1.912 Scrub
33300 Colorado Desert Wash Scrub 431 1.912 Scrub
33600 Encelia Scrub 431 1.912 Scrub
33700 Acacia Scrub 431 1.912 Scrub
34000 Mojavean Desert Scrub 431 1.912 Scrub
34300 Blackbush Scrub 431 1.912 Scrub
35000 Great Basin Scrub 431 1.912 Scrub
35200 Sagebrush Scrub 431 1.912 Scrub
35210 Big Sagebrush Scrub 431 1.912 Scrub
36110 Desert Saltbush Scrub 431 1.912 Scrub
36120 Desert Sink Scrub 431 1.912 Scrub
37000 Chaparral 431 1.912 Scrub
37120 Southern Mixed Chaparral 431 1.912 Scrub
37121 Granitic Southern Mixed Chaparral 431 1.912 Scrub
37122 Mafic Southern Mixed Chaparral 431 1.912 Scrub
37130 Northern Mixed Chaparral 431 1.912 Scrub
37131 Granitic Northern Mixed Chaparral 431 1.912 Scrub
37132 Mafic Northern Mixed Chaparral 431 1.912 Scrub
37200 Chamise Chaparral 431 1.912 Scrub
37210 Granitic Chamise Chaparral 431 1.912 Scrub
37220 Mafic Chamise Chaparral 431 1.912 Scrub
37300 Red Shank Chaparral 431 1.912 Scrub
37400 Semi-Desert Chaparral 431 1.912 Scrub
37500 Montane Chaparral 431 1.912 Scrub
37510 Mixed Montane Chaparral 431 1.912 Scrub
37520 Montane Manzanita Chaparral 431 1.912 Scrub
37530 Montane Ceanothus Chaparral 431 1.912 Scrub
37540 Montane Scrub Oak Chaparral 431 1.912 Scrub
37800 Upper Sonoran Ceanothus Chaparral 431 1.912 Scrub
37830 Ceanothus crassifolius Chaparral 431 1.912 Scrub
Oct. 11, 2022 Item #12 Page 256 of 560
218
37900 Scrub Oak Chaparral 431 1.912 Scrub
37A00 Interior Live Oak Chaparral 431 1.912 Scrub
37C30 Southern Maritime Chaparral 431 1.912 Scrub
37G00 Coastal Sage-Chaparral Transition 431 1.912 Scrub
37K00 Montane Buckwheat Scrub 431 1.912 Scrub
39000 Upper Sonoran Subshrub Scrub 431 1.912 Scrub
42000 Valley and Foothill Grassland 191 0.012 Grassland
42100 Native Grassland 191 0.012 Grassland
42110 Valley Needlegrass Grassland 191 0.012 Grassland
42120 Valley Sacaton Grassland 191 0.012 Grassland
42200 Nonnative Grassland 191 0.012 Grassland
42200 Non-Native Grassland 191 0.012 Grassland
42210 Non-Native Grassland: Broadleaf-Dominated 191 0.012 Grassland
42300 Wildflower Field 191 0.012 Grassland
42400 Foothill/Mountain Perennial Grassland 191 0.012 Grassland
42470 Transmontane Perennial Grassland 191 0.012 Grassland
44000 Vernal Pool 1513,10 011,12 Wetland
44320 San Diego Mesa Vernal Pool 1513,10 011,12 Wetland
44322 San Diego Mesa Claypan Vernal Pool 1513,10 011,12 Wetland
45000 Meadows and Seeps 191 0.012 Grassland
45100 Montane Meadow 191 0.012 Grassland
45110 Wet Montane Meadow 191 0.012 Grassland
45120 Dry Montane Meadows 191 0.012 Grassland
45300 Alkali Meadows and Seeps 191 0.012 Grassland
45320 Alkali Seep 191 0.012 Grassland
45400 Freshwater Seep 191 0.012 Grassland
46000 Alkali Playa Community 191 0.012 Grassland
52120 Southern Coastal Salt Marsh 2353 2.1814 Wetland
52300 Alkali Marsh 2353 2.1814 Wetland
52310 Cismontane Alkali Marsh 2353 2.1814 Wetland
52400 Freshwater Marsh 1513,10 1.410 Wetland
52410 Coastal and Valley Freshwater Marsh 1513,10 1.410 Wetland
52420 Transmontane Freshwater Marsh 1513,10 1.410 Wetland
52440 Emergent Wetland 1513,10 1.410 Wetland
60000 Riparian and Bottomland Habitat 10015 4.316 Riparian
61000 Riparian Forests 10015 4.316 Riparian
61300 Southern Riparian Forest 10015 4.316 Riparian
61310 Southern Coast Live Oak Riparian Forest 10015 4.316 Riparian
61320 Southern Arroyo Willow Riparian Forest 10015 4.316 Riparian
61330 Southern Cottonwood-Willow Riparian Forest 10015 4.316 Riparian
61510 White Alder Riparian Forest 10015 4.316 Riparian
61810 Sonoran Cottonwood-Willow Riparian Forest 10015 4.316 Riparian
61820 Mesquite Bosque 10015 4.316 Riparian
Oct. 11, 2022 Item #12 Page 257 of 560
219
62000 Riparian Woodlands 10015 4.316 Riparian
62200 Desert Dry Wash Woodland 1352 3.672 Woodlands
62300 Desert Fan Palm Oasis Woodland 1352 3.672 Woodlands
62400 Southern Sycamore-Alder Riparian Woodland 1352 3.672 Woodlands
62500 Southern Riparian Woodland 1352 3.672 Woodlands
63000 Riparian Scrubs 1352 3.672 Woodlands
63300 Southern Riparian Scrub 1352 3.672 Woodlands
63310 Mule Fat Scrub 1352 3.672 Woodlands
63320 Southern Willow Scrub 1352 3.672 Woodlands
63321 Arundo donnax Dominant/Southern Willow Scrub 1352 3.672 Woodlands
63400 Great Valley Scrub 1352 3.672 Woodlands
63410 Great Valley Willow Scrub 1352 3.672 Woodlands
63800 Colorado Riparian Scrub 1352 3.672 Woodlands
63810 Tamarisk Scrub 1352 3.672 Woodlands
63820 Arrowweed Scrub 1352 3.672 Woodlands
64000 Unvegetated Habitat 0 0 Barren
64100 Open Water 0 0 Water
64110 Marine 0 0 Water
64111 Subtidal 0 0 Water
64112 Intertidal 0 0 Water
64121 Deep Bay 0 0 Water
64122 Intermediate Bay 0 0 Water
64123 Shallow Bay 0 0 Water
64130 Estuarine 0 0 Water
64131 Subtidal 0 0 Water
64133 Brackishwater 0 0 Water
64140 Freshwater 0 0 Water
64200 Non-Vegetated Channel or Floodway 0 0 Water
64300 Saltpan/Mudflats 2313 23 Wetland
64400 Beach 0 0 Barren
70000 Woodland 1352 3.672 Woodlands
71000 Cismontane Woodland 1352 3.672 Woodlands
71100 Oak Woodland 1352 3.672 Woodlands
71120 Black Oak Woodland 1352 3.672 Woodlands
71160 Coast Live Oak Woodland 1352 3.672 Woodlands
71161 Open Coast Live Oak Woodland 1352 3.672 Woodlands
71162 Dense Coast Live Oak Woodland 1352 3.672 Woodlands
71180 Engelmann Oak Woodland 1352 3.672 Woodlands
71181 Open Engelmann Oak Woodland 1352 3.672 Woodlands
71182 Dense Engelmann Oak Woodland 1352 3.672 Woodlands
72300 Peninsular Pinon and Juniper Woodlands 1352 3.672 Woodlands
72310 Peninsular Pinon Woodland 1352 3.672 Woodlands
72320 Peninsular Juniper Woodland and Scrub 1352 3.672 Woodlands
Oct. 11, 2022 Item #12 Page 258 of 560
220
75100 Elephant Tree Woodland 1352 3.672 Woodlands
77000 Mixed Oak Woodland 1352 3.672 Woodlands
78000 Undifferentiated Open Woodland 1352 3.672 Woodlands
79000 Non-Native Woodland 1352 3.672 Woodlands
79100 Eucalyptus Woodland 1352 3.672 Woodlands
81100 Mixed Evergreen Forest 1552 8.872 Forests
81300 Oak Forest 1552 8.872 Forests
81310 Coast Live Oak Forest 1552 8.872 Forests
81320 Canyon Live Oak Forest 1552 8.872 Forests
81340 Black Oak Forest 1552 8.872 Forests
83140 Torrey Pine Forest 1552 8.872 Forests
83230 Southern Interior Cypress Forest 1552 8.872 Forests
84000 Lower Montane Coniferous Forest 1552 8.872 Forests
84100 Coast Range, Klamath and Peninsular Coniferous Forest 1552 8.872 Forests
84140 Coulter Pine Forest 1552 8.872 Forests
84150 Bigcone Spruce (Bigcone Douglas Fir)-Canyon Oak Forest 1552 8.872 Forests
84230 Sierran Mixed Coniferous Forest 1552 8.872 Forests
84500 Mixed Oak/Coniferous/Bigcone/Coulter Forest 1552 8.872 Forests
85100 Jeffrey Pine Forest 1552 8.872 Forests
N/A 66.417 4.417 Eelgrass
Appendix 5.A works cited:
1. Wheeler, M. M. et al. Carbon and nitrogen storage in California sage scrub and non-native grassland habitats. J. Arid Environ. 129,
119–125 (2016). 2. Cameron, D. R., Marvin, D. C., Remucal, J. M. & Passero, M. C. Supporting Information for Ecosystem management and land
conservation can substantially contribute to California’s climate mitigation goals. Proc. Natl. Acad. Sci. 114, 12833–12838 (2017).
3. Ward, M. A. et al. Blue carbon stocks and exchanges along the California coast. Biogeosciences 18, 4717–4732 (2021). 4. McTigue, N. D., Walker, Q. A. & Currin, C. A. Refining Estimates of Greenhouse Gas Emissions From Salt Marsh “Blue Carbon”
Erosion and Decomposition. Front. Mar. Sci. 8, 661442 (2021).
5. Bjorkman, J. et al. Biomass, Carbon Sequestration, and Avoided Emissions: Assessing the Role of Urban Trees in California. (2015). 6. Reforestation Hub - Reforestation Opportunities for Climate Change Mitigation. https://www.reforestationhub.org/.
7. Cook-Patton, S. C. et al. Lower cost and more feasible options to restore forest cover in the contiguous United States for climate
mitigation. One Earth 3, 739–752 (2020). 8. Zhu, Z.-L. & Reed, B. C. Baseline and projected future carbon storage and greenhouse-gas fluxes in ecosystems of the Western
United States. (US Geological Survey, 2012). 9. Ayala-Niño, F. et al. Spatial distribution of soil carbon storage in desert shrubland ecosystems of northwest Mexico. J. Arid Environ.
183, 104251 (2020).
10. Bernal, B. & Mitsch, W. J. Comparing carbon sequestration in temperate freshwater wetland communities. Glob. Change Biol. 18, 1636–1647 (2012).
11. Kifner, L. H., Calhoun, A. J. K., Norton, S. A., Hoffmann, K. E. & Amirbahman, A. Methane and carbon dioxide dynamics within four
vernal pools in Maine, USA. Biogeochemistry 139, 275–291 (2018). 12. Fennessy, M. S., Wardrop, D. H., Moon, J. B., Wilson, S. & Craft, C. Soil carbon sequestration in freshwater wetlands varies across a
gradient of ecological condition and by ecoregion. Ecol. Eng. 114, 129–136 (2018). 13. Reed, C. C. et al. Montane Meadows: A Soil Carbon Sink or Source? Ecosystems 24, 1125–1141 (2021).
14. Mcleod, E. et al. A blueprint for blue carbon: toward an improved understanding of the role of vegetated coastal habitats in
sequestering CO 2. Front. Ecol. Environ. 9, 552–560 (2011). 15. Dybala, K. E. et al. Optimizing carbon storage and biodiversity co-benefits in reforested riparian zones. J. Appl. Ecol. 56, 343–353
(2019). 16. California Department of Food and Agriculture. COMET-Planner California Healthy Soils. http://www.comet-planner-cdfahsp.com/
(2021).
17. Murray, B. C., Pendleton, L., Jenkins, W. A. & Sifleet, S. Green Payments for Blue Carbon. 52 https://nicholasinstitute.duke.edu/environment/publications/naturalresources/blue-carbon-report (2011).
Oct. 11, 2022 Item #12 Page 259 of 560
221
Appendix 5.B Blue carbon methodology details and blue carbon value sources
The blue carbon vegetation class was used to determine the emitted carbon from the carbon stock and
the lost carbon sequestration potential. These values were taken from the literature and were
preferentially from San Diego, California, the west coast of the contiguous United States, anywhere in
the United States, or any blue carbon study, in that order. A table of values and sources is in Table 5.B.1.
The carbon stock and sequestration values from the literature were converted to metric tons of CO2e
per hectare (MT CO2e ha-1) if they were not already in those values. They were then multiplied by the
appropriate vegetation class’s total area to get the one-time positive emissions and the foregone
negative emissions from planned land use change in the region.
The “ECO_VEGETATION_CN” layer contains polygons for all land use types as well as water types. To
specifically consider the impacts of sea level rise on blue carbon habitats, the vegetation layer was
filtered to only contain those blue carbon polygons.
Two rounds of filtering occurred. First, polygons were filtered by the broad vegetation categories
(column name: “CATEGORY”) of ‘Bog and Marsh' and 'Riparian and Bottomland Habitat.' To additionally
include degraded wetlands, which still hold carbon, the Holland code and name (column name:
“LEGEND”) of '11200 Disturbed Wetland.'
Next, these broader categories were filtered to only remove the following Holland code polygons,
because they were not considered blue carbon habitats in this analysis: '64400 Beach,’ '64112 Intertidal,'
'64000 Unvegetated Habitat,' '64110 Marine,' '64111 Subtidal,' '64121 Deep Bay,' '64122 Intermediate
Bay,' '64123 Shallow Bay,' '64131 Subtidal,' '64140 Freshwater,' and '64200 Non-Vegetated Channel or
Floodway.' What remained were the blue carbon habitat polygons. Eelgrass was not included in this
mapping because it is not included in the vegetation layers.
The resulting layer was clipped using NOAA’s 1 foot SLR layer (fixed and reprojected to ESPG:6414) such
that the resulting layer only showed those blue carbon habitats that would be inundated with seawater
under a 1 foot SLR scenario. Area was calculated in QGIS and the final attribute table was exported as a
CSV file for carbon emissions and lost sequestration potential calculations in Excel. Values used are
shown in Table 5.A.2. The final areas of each polygon were calculated in units of hectares and final
polygons with an area equal to zero hectares were dropped, as in the land use change section.
Table 5.B.1 – Carbon values and sources used to calculate lost carbon stock and sequestration rates.
Blue Carbon Habitat Type Stock (MT CO2e ha-1) Flow (MT CO2e ha-1yr-1)
Freshwater marsh 151i 1.41
Mudflats/Saltpans 2312 23
Riparian scrub/estuary 1004 4.35
Salt marsh/estuary 2352 2.186
i Assumes that freshwater marsh storage follows the same ratio to saltwater marsh storage (Ward et al., 2021) as
freshwater marsh sequestration (from Bernal & Mitsch, 2012) does to saltwater marsh sequestration (Mcleod et
al., 2011).
Oct. 11, 2022 Item #12 Page 260 of 560
222
Appendix 5.B works cited:
1. Bernal, B. & Mitsch, W. J. Comparing carbon sequestration in temperate freshwater wetland communities.
Glob. Change Biol. 18, 1636–1647 (2012).
2. Ward, M. A. et al. Blue carbon stocks and exchanges along the California coast. Biogeosciences 18, 4717–4732
(2021).
3. Sasmito, S. D. et al. Organic carbon burial and sources in soils of coastal mudflat and mangrove ecosystems.
CATENA 187, 104414 (2020).
4. Dybala, K. E. et al. Optimizing carbon storage and biodiversity co-benefits in reforested riparian zones. J. Appl.
Ecol. 56, 343–353 (2019).
5. California Department of Food and Agriculture. COMET-Planner California Healthy Soils. http://www.comet-
planner-cdfahsp.com/ (2021).
6. Mcleod, E. et al. A blueprint for blue carbon: toward an improved understanding of the role of vegetated
coastal habitats in sequestering CO 2. Front. Ecol. Environ. 9, 552–560 (2011).
Oct. 11, 2022 Item #12 Page 261 of 560
223
6. Employment Impacts through Regional
Decarbonization Framework for the San Diego Region
Robert Pollin, Department of Economics and Political Economy Research Institute (PERI)
University of Massachusetts Amherst
Jeannette Wicks-Lim, PERI, University of Massachusetts Amherst
Shouvik Chakraborty, PERI, University of Massachusetts Amherst
Gregor Semieniuk, PERI, University of Massachusetts Amherst
Key Takeaways
● Between 2021 – 2030, the regional decarbonization pathway would generate an
average of nearly 27,000 jobs per year in the San Diego region.
● Even accounting for the contraction of fossil fuel jobs, we estimate that no workers in
the region’s fossil fuel-based industries will have to experience job displacement before
2030.
● The County of San Diego and local governments should begin to develop a viable set of
just transition policies for the workers in the community who will experience job
displacement between 2031 – 2050.
● The costs of a just transition will be much lower if the transition is able to proceed
steadily rather than episodically. Under a steady transition, the proportion of workers
who will retire voluntarily in any given year will be predictable and the transition
process will thus avoid having to provide support for a much larger share of workers.
● Geothermal production of the five sites identified in Imperial County would generate
1,900 jobs per year over a 10-year period.
In this chapter, we estimate the employment impacts of advancing the clean energy
decarbonization program developed for the San Diego region by Evolved Energy Research
(EER), as summarized in Appendix A of this project. The model that EER describes in Appendix A
includes seven different energy system transformation scenarios between 2020 – 2050. The
purpose of these scenarios is to present pathways through which CO2 emissions in the San
Diego region can fall to zero by 2050. In this chapter, we focus on what the EER model terms
the “Central Case.” They explain that this is the case through which the region can achieve net
zero CO2 emission in 2050 at the lowest net cost. We focus in this chapter on the employment
impacts between 2021 – 2030 through advancing the EER Central Case in the San Diego region.i
i The EER model is for Southern California, defined as including 13 counties in addition to San Diego county. In
order for us to produce estimates of employment impacts within the San Diego region itself, we therefore utilized
Oct. 11, 2022 Item #12 Page 262 of 560
224
This chapter also estimates the impacts of phasing down fossil fuel-based economic activity on
employment in the region. Within the EER Central Case model, the phasing down of fossil fuel-
based activity will be modest between 2021 – 2030, the decade of activity on which we focus
here. EER assumes that natural gas consumption in the region will remain at its current level
through 2030, while the consumption of oil will fall by 20 percent as of 2030 relative to current
consumption levels. There is, at present, already close-to-zero coal consumption in the region.
This chapter will first focus on the employment creation impacts between 2021 - 2030 of the
San Diego region advancing its zero emissions program. We then turn to considering the
employment impacts of phasing down fossil fuels in the region over this same period.i
Our overall findings can be summarized briefly: under the EER model’s Central Case, we
estimate that the region will generate an average of nearly 27,000 jobs per year between 2021
– 2030.This amounts to an expansion of employment in the region of about 1.6 percent. It
means that, if all else were held equal in the regional labor market over 2021 – 2030, regional
decarbonization project itself would be capable of reducing the region’s unemployment rate
from, say, 7.5 percent to 5.9 percent. The newly-created jobs will encompass a wide range of
occupations, at all levels of the regional labor market. At the same time, between 2021 – 2030,
we estimate that no workers in the region’s fossil fuel- based industries will have to experience
job displacement.
6.1 Overview of Job Creation Estimates
According to our calculations, as an average over 2021– 2030, total expenditures within the
Central Case include $9.9 billion per year to purchase a wide range of products that operate
through consuming energy, what we will term “energy demand expenditures.” These include
some assumptions in defining the proportionate level of activity in the San Diego region relative to all 14 counties
constituting Southern California in the EER model’s Central Case. We describe our estimating methodology on this
issue in Appendix 6.A and refer to this model as the EER model.
i This paper provides a primarily quantitative analysis of the employment impacts resulting from the clean energy
transition in the region. Dr. Carol Zabin, Director of the UC Berkeley Labor Center’s Green Economy Program, and
co-authors are producing a more qualitative study focusing on a range of employment policy issues associated with
the San Diego region’s clean energy transition. This report is a part of the County’s Regional Decarbonization
Framework as is available at: https://www.sandiegocounty.gov/content/dam/sdc/lueg/regional-decarb-
frameworkfiles/Putting%20San%20Diego%20County%20on%20the%20High%20Road_June%202022.pdf. Another
related study of clean energy and fossil fuel-based employment levels in the San Diego region is presented in a
November 2020 spreadsheet report, Clean and Renewable Energy in San Diego-Chula Vista-Carlsbad, CA, by the
San Diego Regional Economic Development Corporation, available at: https://docs.google.com/spreadsheets/d/1mVZ4UXWzYG2zHu2XfnTFhXq2-1rwBBkr/edit?goal=0_c2357fd0a3-
b9c8e8882a-84300641#gid=1212436047
Oct. 11, 2022 Item #12 Page 263 of 560
225
electric vehicles, heating and cooling systems, and refrigeration equipment.i It also includes
$5.1 billion per year to expand the supply of both clean renewable energy sources, including
solar, wind, geothermal, and hydro power, as well as other low- to zero CO2-emitting
technologies, including nuclear power, biomass, and carbon sequestration. The average overall
spending total for both energy demand expenditures and energy supply investments therefore
comes to an average of $15.0 billion per year between 2021 – 2030. This is equal to about 3.2
percent of San Diego’s overall economic activity at its midpoint between 2021 – 2030 assuming
that the regional economy grows at an average annual rate of 2.5 percent over this 10-year
period.
Working from these budgetary figures, we then estimate the number of jobs that will be
created as a result of the spending amounts that EER have allocated to all categories in the
areas of both energy demand and supply. Our overall findings are that an average of about
13,300 jobs per year will be generated through $9.9 billion in average annual energy demand
expenditures in the region between 2021 – 2030 and another 13,400 jobs per year will be
generated through spending an average of $5.1 billion per year in low- to zero emissions
technologies in the region. Overall, we estimate that the EER model’s Central Case investments
for the San Diego region will generate an average of about 26,700 jobs between 2021 – 2030 in
the San Diego region. This is equal to about 1.6 percent of the region’s average projected labor
force size between 2021 – 2030. This higher level of employment in the San Diego region will be
sustained throughout this first decade of the region’s clean energy transformation program
(assuming no other major changes in the region’s economy were to occur).
After estimating the number of jobs that these energy demand and supply expenditures will
generate, we then present indicators of the quality of these jobs. These quality indicators
include average compensation levels, health care coverage, and union membership. We also
provide data on the types of workers who are employed at present in the job areas that will be
created by the energy demand and supply expenditures, including evidence on both
educational credentials of these workers as well as their racial, ethnic, and gender composition.
We then report on the prevalent types of jobs that will be generated through both the energy
demand and supply expenditures.
6.2 Methodological Issues in Estimating Employment Creation
Before proceeding to present our detailed job creation and job quality estimates, we first
briefly describe the methodology we used to generate our results.ii Our employment estimates
i Appendix 1 in Pollin et al. (2020)3 provides a full listing of all of the EER spending categories.
ii We provide a fuller discussion of our methodology in Pollin et al. (2020)3 Appendix 2.
Oct. 11, 2022 Item #12 Page 264 of 560
226
are figures generated directly with data from national surveys of public and private economic
enterprises within the U.S. and organized systematically within the official U.S. input-output (I-
O) model. The “inputs” within this model are all the employees, materials, land, energy, and
other products that are utilized in public and private enterprises within the U.S. to create goods
and services. The “outputs” are the goods and services themselves that result from these
activities that are then made available to households, private businesses, and governments as
consumers within both domestic and global markets. Within the given structure of the U.S.
economy broadly and the regional economy specifically, these figures from the input-output
model provide the most accurate evidence available as to what happens within private and
public enterprises when they produce the economy’s goods and services. In particular, these
data enable researchers to observe how many workers were hired to produce a given set of
products or services, and what kinds of materials were purchased in the process.
Here is one specific example of how our methodology works. When the regional economy
expands its solar energy productive capacity by $1 billion, we are able to estimate how much of
the $1 billion will be spent on hiring workers, how much will be spent on non-labor inputs,
including materials, energy costs, and maintaining factory buildings, and how much will be left
over for business profits. Moreover, when businesses spend on non-labor inputs, we estimate
what are the employment effects through giving orders to suppliers, such as glass
manufacturers or trucking companies.
6.2.1 Direct, Indirect and Induced Job Creation
Spending money in any area of an economy will create jobs, since people are needed to
produce any goods or services that the economy supplies. This is true regardless of whether the
spending is done by private businesses, households, or government entities. At the same time,
for a given amount of spending within the economy, for example, $1 billion, there are
differences in the relative levels of job creation through spending that $1 billion in alternative
ways. Again, this is true regardless of whether the spending is done by households, private
businesses, or public sector enterprises.
There are three sources of job creation associated with any expansion of spending: direct,
indirect, and induced effects. For purposes of illustration, consider these categories in terms of
investments in manufacturing electric cars or building wind turbines:
1. Direct effects—the jobs created, for example, by installing solar panels or purchasing
electric vehicles;
2. Indirect effects—the jobs associated with industries that supply intermediate goods
for the solar panels or electric vehicles, such as silicon, steel, and transportation;
Oct. 11, 2022 Item #12 Page 265 of 560
227
3. Induced effects—the expansion of employment that results when people who are
paid in the glass, steel, or transportation industries spend the money they have
earned on other products in the economy. These are the multiplier effects within a
standard macroeconomic model.
In this study, we report on all three employment channels—direct, indirect, and induced job
creation. But we emphasize that estimating induced effects—i.e. multiplier effects—within I-O
models is much less reliable than estimating the direct and indirect effects. In addition, induced
effects derived from alternative areas of spending within a national economy are likely to be
comparable to one another.
Within the categories of direct plus indirect job creation, the amount of money allocated to
activities in an economy generates different levels of employment. As a matter of simple
arithmetic, three allocation possibilities affect direct plus indirect job creation:
1. Labor intensity. When proportionally more money of a given overall amount of
funds is spent on hiring people, as opposed to spending on machinery, buildings,
energy, land, and other inputs, then spending this given amount of overall funds will
create relatively more jobs.
2. Compensation per worker. If $1 billion in total is spent on employing workers in a
given year on a project, and each employee earns $1 million per year working on
that project, then only 1,000 jobs are created through spending this $1 billion.
However, if, at another enterprise, the average pay is $50,000 per year, then the
same $1 billion devoted to employing workers will generate 20,000 jobs.
3. Local content. When a given amount of money is spent in the San Diego region in
either the areas of energy supply or demand, a significant share of the funds will
support activities that occur outside of the region itself. Of course, job creation in
the San Diego region itself will increase as the relative share of locally produced
goods and services rises. Through the input/output model, we are able to observe
the level of job creation at existing local content levels, but we can also estimate
how much overall job creation will change through assuming either an increase or
decrease in the local content share. For example, this can result from active
economic development policies in the region. In what follows, we report job
creation levels resulting from current local content ratios.
6.2.2 Time Dimension in Measuring Job Creation
Jobs-per-year vs. job years. Any type of spending activity creates employment over a given
amount of time. To understand the impact on jobs of a given spending activity, one must
therefore incorporate a time dimension into the measurement of employment creation. For
Oct. 11, 2022 Item #12 Page 266 of 560
228
example, a program that creates 100 jobs that each lasts for only one year needs to be
distinguished from another program that creates 100 jobs that each continue for 10 years. It is
important to keep this time dimension in mind in any assessment of the impact on job creation
of any clean energy investment activity.
There are two straightforward ways to express such distinctions. One is through measuring job
years, which measures cumulative job creation over the total number of years that jobs have
been created. Thus, an activity that generates 100 jobs for 1 year would create 100 job years.
By contrast, the activity that produces 100 jobs for 10 years would generate 1,000 job years.
The other way to report the same figures would be in terms of jobs-per-year. Through this
measure, we are able to provide detail on the year-to-year breakdown of the overall level of job
creation. Thus, with the 10-year program we are using in our example, we could express its
effects as creating 100 jobs per year over the course of the 2021 – 2030 time period.
This jobs-per-year measure is most appropriate for the purposes of this study because the
impact of any new investment, whether on renewable energy or anything else, will be felt
within a given set of labor market conditions at a point in time. Reporting cumulative job
creation figures over multiple years prevents us from scaling the impact of investments on job
markets at a given point in time. For example, as noted above, we estimate that employment
creation in the region from the full set of energy demand and supply expenditures in the region
will average about 26,700 jobs per year over 2021 – 2030. We are able to scale that regional
employment increase relative to the size of the labor force. We estimate that the region’s labor
force will average about 1.7 million between 2021 – 2030. Thus, the increase of 26,700 00 jobs
to the region’s overall force of about 1.7 million jobs will amount to a growth of employment of
1.6 percent. We present the full derivation of these overall results below.
6.2.3 Incorporating Labor Productivity Growth over the 10-Year Investment Cycle
The figures we use for the input-output tables are based on the technologies that are prevalent
at present for undertaking these clean energy investments. Yet we are estimating job creation
through clean energy investments that will occur over the 10-year cycle between 2021-2030.
The relevant production technologies will certainly change over this decade, so that a different
mixture of inputs may be used to produce a given output.
For example, new technologies are likely to emerge, making other technologies obsolete.
Certain inputs could also become scarcer, and, as result, firms may substitute these for other
less expensive goods and services to reduce costs. The production process overall could also
become more efficient, so that fewer inputs are needed to produce a given amount of output.
Energy efficiency investments do themselves produce a change in production processes – i.e., a
Oct. 11, 2022 Item #12 Page 267 of 560
229
reduction in the use of energy inputs to generate a given level of output. In short, the input-
output relationships in any given economy – including its employment effects of clean energy
investments – are likely to look different in 2030 relative to the present.
Pollin et al. (2015) addresses this issue in detail (e.g., pp. 133 - 44).2 For the purposes of the
present discussion, we work with a simple assumption: that average labor productivity in all of
the expenditure areas included in the EER model will rise by 1 percent per year through 2030.
6.3 Job Creation Estimates
Tables 6.1 – 6.5 report on our job creation estimates generated by the EER Central Case to
enable the San Diego region to reach net zero emissions by 2050, with our focus on the 2021 –
2030 period. We report two overall sets of tables for both the energy demand (Tables 6.1 and
6.2) and energy supply expenditures (Tables 6.3 and 6.4) —first, job creation per $1 million in
expenditure (Tables 6.1 and 6.3), then, job creation given the average annual level of spending
incorporated into the EER model (Tables 6.2 and 6.4), i.e., $9.9 billion per year in energy
demand expenditures and $5.1 billion in energy supply investments. We first report figures for
direct and indirect jobs, along with the totals for these main job categories. We then include
the figures on induced jobs and show total job creation when induced jobs are added to figures
for direct and indirect jobs. Finally, Table 6.5 provides a summary of the above information.
In Tables 6.1 and 6.2, we present our estimates of the job creation effects generated by the full
range of energy demand expenditures in the EER Central Case. We have grouped this full set of
projects into 10 categories: vehicles, heating/ventilation/air conditioning (HVAC),
manufacturing, other commercial and residential spending, construction, appliances,
refrigeration, mining, agriculture, and lighting.i As Table 6.1 shows, there is a wide range of
direct plus indirect job creation per $1 million in spending, with mining at the low end (0.7) and
agriculture on the high end (10.0).
i The “other” commercial and residential category of energy demand expenditures combines the “commercial
other” and “residential other” categories within the EER model from the EER model.
Oct. 11, 2022 Item #12 Page 268 of 560
230
Table 6.1 Job creation through energy demand expenditures in the San Diego region, by subsectors and
technology. Job creation values are per $1 million in spending.
Investment Area Direct
Jobs
Indirect
Jobs
Direct Jobs +
Indirect Jobs
Induced
Jobs
Direct Jobs +
Indirect Jobs +
Induced Jobs
Vehicles 0.47 0.19 0.66 0.21 0.87
HVAC 1.57 0.82 2.39 0.89 3.28
Refrigeration 1.81 0.68 2.49 0.98 3.47
Appliances 0.79 0.43 1.22 0.43 1.65
Construction 2.43 1.38 3.81 1.35 5.16
Lighting 1.74 0.93 2.67 0.98 3.65
Manufacturing 0.91 0.72 1.63 0.63 2.26
Other commercial and
residential
1.6 0.8 2.4 0.9 3.3
Agriculture* 8.78 1.27 10.05 2.74 12.79
Mining 0.39 0.33 0.72 0.34 1.06
Notes: Figures are based on current rates of job creation, weighted by total investment amounts over 2021-2030.
Source: IMPLAN 3.1. *Demand-side spending in agriculture includes items such as regenerative agricultural
activities, organic farming and related agriculture research and development, i.e., agricultural items that involve
using reduced rates of energy consumption.
In Table 6.2, we show the level of job creation through spending an average of $9.9 billion per
year on the full set of these projects between 2021 and 2030. As we see, of the full $9.9 billion
average annual spending figure, the largest areas of expenditures include (with rounding): $7.7
billion on clean energy vehicles, $897 million on high-efficiency HVAC systems, and $762 million
on refrigeration equipment. These three spending categories therefore account for roughly 95
percent of total demand expenditures, with spending on clean energy vehicles alone accounting
for 78 percent of all demand-side expenditures.
The result of the demand expenditures at this level will be the creation of an average of about
6,914 direct jobs and 3,022 indirect jobs, for an average between 2021 and 2030 of 9,936 direct
plus indirect jobs. Including induced jobs adds another 3,413 jobs per year to the total figure.
This brings the total net job creation figure for the full set of energy demand expenditures,
including induced jobs, to about 13,400 per year between 2021 – 2030.
Oct. 11, 2022 Item #12 Page 269 of 560
231
Table 6.2 Average number of jobs created in the San Diego region annually through total estimated energy
demand expenditures from 2021-2030, by subsectors and technology. Assumes 1 percent average annual
productivity growth.
Investment Area Average
Annual
Expenditure
Direct
Jobs
Indirect
Jobs
Direct Jobs +
Indirect Jobs
Induced
Jobs
Direct Jobs +
Indirect Jobs +
Induced Jobs
Vehicles $7.7 billion 3,427 1,427 4,854 1,508 6,362
HVAC $897.0 million 1,345 699 2,044 764 2,808
Refrigeration $761.9 million 1,315 491 1,806 711 2,517
Appliances $188.6 million 143 77 220 78 298
Construction $113.4 million 263 149 412 146 558
Lighting $106.6 million 177 95 272 100 372
Manufacturing $45.7 million 40 32 72 27 99
Other commercial
and residential
$38.9 million 59 30 89 33 122
Agriculture $17.2 million 144 21 165 45 210
Mining $2.4 million 1 1 2 1 3
TOTAL $9.9 billion 6,914 3,022 9,936 3,413 13,349
Source: IMPLAN 3.1
In Tables 6.3 and 6.4, we present our estimates as to the job creation effects generated by the
full set of energy supply projects presented in the EER model for the San Diego region between
2021 - 2030. These include clean renewables, transmission, and storage; fossil fuels; additional
supply technologies, including nuclear, carbon sequestration, and biomass; and grouping of
difficult to categorize “other” investments.i By far, the largest share of investments assigned by
the EER model over 2021 – 2030 is in the fossil fuel category.
In Table 6.3, we see that the extent of direct plus indirect jobs ranges from 1.2 jobs per $1
million in spending for “other investments” to 3.5 jobs per million for both the fossil fuel and
clean renewables investment categories. Adding induced jobs brings the range to between 1.9
jobs for other investments to 4.9 for fossil fuels and clean renewables.
Based on these proportions, Table 6.4 shows the levels of job creation in the San Diego region
associated with $5.1 billion in average annual spending on these energy supply investments
between 2021 - 2030. As noted above, the highest proportion of spending among the supply
side investments is in the fossil fuel area, at $4.4 billion of the $5.1 billion total, or about 86
percent of total spending. Spending on clean renewables totals to an average of $630 million
per year, equal to another 12.3 percent of the total. Thus, the spending on fossil fuels and clean
renewables together accounts for 98 percent of all spending on the supply side between 2021 –
2030 in the EER model.
i Our energy supply expenditure “other” category includes electric boilers, hydrogen blend, industrial CO2 capital,
other boilers, and steam production.
Oct. 11, 2022 Item #12 Page 270 of 560
232
Table 6.3 Job creation through energy supply expenditures in the San Diego region, by subsectors and technology.
Job creation values are per $1 million in spending.
Investment Area Direct
Jobs
Indirect
Jobs
Direct Jobs +
Indirect Jobs
Induced
Jobs
Direct Jobs +
Indirect Jobs +
Induced Jobs
Fossil fuels 2.73 0.81 3.54 1.33 4.87
Clean renewables 2.47 1.00 3.47 1.41 4.88
Transmission and
storage 0.61 0.90 1.51 0.91 2.42
Additional supply
technologies 2.35 0.79 3.14 1.27 4.41
Other investments 0.77 0.38 1.15 0.70 1.85
Note: These figures are based on current rates of job creation, weighted by total investment amounts over 2021-
2030. Source: IMPLAN 3.1
Within these budgetary allocations, we see first in Table 6.4 that total direct plus indirect job
creation generated in the San Diego region by this specific expansion in energy supply
expenditures will amount to an average of about 4,200 direct jobs and 4,400 indirect jobs per
year between 2021 – 2030. This totals to about 8,600 direct and indirect jobs. We also estimate
that, as an average between 2021 – 2030, an additional 4,700 induced jobs will be generated in
the San Diego region by these investments. This brings the total of direct, indirect and induced
jobs generated by net energy supply investments to about 13,400 jobs.
Table 6.4 Average number of jobs created in the San Diego region annually through total estimated energy supply
expenditures from 2021-2030, by subsectors and technology. Assumes 1 percent average annual productivity
growth.
Investment Area Average
Annual
Expenditure
Direct
Jobs
Indirect
Jobs
Direct Jobs +
Indirect Jobs
Induced
Jobs
Direct Jobs +
Indirect Jobs +
Induced Jobs
Fossil fuels $4.4 billion 2,538 3,777 6,315 3,805 10,120
Clean renewables $629.5 million 1,488 601 2,089 848 2,937
Transmission and
storage
$45.9 million
34 17 51 31 82
Additional supply
technologies
$45.1 million
118 35 153 57 210
Other
investments
$4.5 million
10 3 13 6 19
TOTAL $5.1 billion 4,188 4,433 8,621 4,747 13,368
Source: IMPLAN 3.1
Table 6.5 brings together our job creation estimates for both the energy demand expenditures
and energy supply investments, resulting from spending an average of $15.0 billion per year
from 2021 - 2030. We show total figures for direct plus indirect jobs only, then we also show
the total when induced jobs are included.
Oct. 11, 2022 Item #12 Page 271 of 560
233
Table 6.5 Estimated average annual job creation in the San Diego region through combined energy supply and
energy demand expenditure estimates, 2021-2030.
Number of Direct
and Indirect Jobs
Number of Direct,
Indirect, and Induced Jobs
1. $9.9 billion in average annual energy demand
expenditures
9,936 13,349
2. $5.1 billion in average annual energy supply
investments
8,621 13,368
3. $15.0 billion in total average annual energy
demand expenditures and energy supply
investments
18,557 26,717
4. Total job creation as a share of projected 2026
labor force (projection is 1.68 million the San Diego
region labor force for 2026)
1.1% 1.6%
Note: Figures assume 1 percent average annual labor productivity growth. Source: Figures derived from EER
energy model for Southern California
We see in row 3 of Table 6.5 that total average direct and indirect job creation between 2021 –
2030—including jobs generated on both the supply and demand-sides of the energy
transformation—is 18,557. Through adding induced jobs, the average annual job creation
figures rise to 26,717. As we see in row 4, this level of direct and indirect job creation would
amount to between about 1.1 percent of the likely regional labor force as of 2026. When we
include induced jobs in the total, we reach 1.6 percent of the likely size of the region’s 2026
labor force.
6.4 Job Quality Indicators and Worker Characteristics in Energy Demand and
Supply Employment
In Tables 6.6 - 6.9, we provide some basic measures of job quality for the direct jobs in the core
areas that will be generated through both the energy demand expenditures and energy supply
investments within the EER Central Case for the San Diego region. These basic indicators
include: 1) average total compensation (including wages plus benefits) for wage-earning
employees; 2) the percentage of workers receiving health insurance coverage through their
employer; 3) the percentage that are union members; 4) the respective levels of educational
attainment for workers in the various employment sectors; and 5) the racial, ethnic, and gender
composition of the workforce in each sector. We first present these figures for the energy
demand categories in Tables 6.6 and 6.7, then for the energy supply investments in Tables 6.8
and 6.9.
To provide a comparative framework for assessing the job quality features and worker
characteristics in the various energy supply and demand sectors, in Appendix 6.B, we report
Oct. 11, 2022 Item #12 Page 272 of 560
234
figures in these areas of job quality for all employed people and worker characteristics for the
total labor force in the San Diego area.i We will also refer to these figures on the overall
regional workforce at various points in the discussion that follows below.
6.4.1 Energy Demand Expenditures and Job Quality
We focus here on figures for the three major energy demand expenditure areas: vehicles,
HVAC, and refrigeration. These three spending categories comprise roughly 95 percent of all
spending on energy demand between 2021 – 2030.
Starting with compensation figures, we see in Table 6.6 that the averages for the energy
demand expenditures range between roughly $62,000 per year for workers in the vehicles
category to nearly $78,000 in the refrigeration category. In general, these figures are all lower
than the average total compensation figures for San Diego of $80,900.ii
Table 6.6 Job quality indicators in energy demand investment areas: direct jobs only.
Investment Area Average total
compensation*
Health insurance
coverage, percentage**
Union membership,
coverage***
Vehicles $62,000 58.2% 14.9%
HVAC $72,000 53.8% 12.9%
Refrigeration $77,600 55.2% 14.7%
Appliances $70,800 51.1% 14.3%
Construction $73,200 51.9% 13.5%
Lighting $73,800 50.9% 14.4%
Manufacturing $71,800 64.9% 6.9%
Other commercial and
residential
$73,800
53.4% 13.6%
Agriculture $59,500 44.7% 5.1%
Mining $61,700 76.3% --
Notes: *Compensation figures reflect only wage and salary workers, and excludes proprietors’ compensation, in
the San Diego region. This is because wage and salary workers’ employment in these activities serve as their
primary jobs whereas proprietors’ employment in these activities are more likely to serve only as secondary jobs.
**Health insurance coverage is based on workers within the San Diego region plus the five surrounding counties
that supply the San Diego region with the highest numbers of commuting workers: Imperial County, Los Angeles
County, Orange County, Riverside County, and San Bernardino County. *** Union membership is based on workers
in the southern region of California. “--” indicates that the sample size was insufficient to produce a reliable estimate. Source: CPS 2015-2019, ACS 2015-2019, IMPLAN 3.1.
The share of workers receiving health insurance coverage is comparable for most of these
i The compensation figures in Tables 6.6, 6.8, and 6.14 are based on employment in the San Diego region. All other
job quality and workforce characteristics presented in Tables 6.6-6.11, 6.14, and 6.15 are based on workers from a
wider geographical area in order to create sample sizes sufficient to generate reliable estimates. See table notes for details.
ii See Appendix 6.B (Table 6.B.1) for more information on regional averages.
Oct. 11, 2022 Item #12 Page 273 of 560
235
major energy demand areas, ranging between 54 percent for HVAC to 58 percent for vehicles.
Similarly, the level of union membership is also comparable for most areas, ranging between
about 13 - 15 percent of the workforce in the area. These figures are comparable to those for
all workers in the region. For the overall regional workforce, 62.2 percent of workers have
health insurance coverage and 13.3 percent are union members (see Appendix 6.B).
6.4.2 Educational Credentials and Racial, Ethnic, and Gender Composition
In Table 6.7, we present data on both the educational credentials for workers employed in the
full range of energy demand categories. We also show data on the racial, ethnic, and gender
composition of the existing workforce in the respective energy demand categories. We focus on
the workers in the three core energy efficiency expenditure categories of vehicles, HVAC, and
refrigeration, as well as the race and gender composition of these workers. We categorize all
workers according to three educational credential groupings: 1) shares with high school
degrees or less; 2) shares with some college or Associate degrees; and 3) shares with Bachelor’s
degree or higher.
As Table 6.7 shows, the distribution of educational credentials is fairly consistent across the
major energy demand spending categories. Thus, the range of workers with high school degrees
or less varies from a low of 45 percent for workers employed in the vehicles category to 61
percent in refrigeration. Similarly, the share of workers with Bachelor’s degrees or higher
ranges from a low of 12 percent in refrigeration to 22 percent in the vehicles category.
In terms of racial and ethnic categories, we see in Table 6.7 that the largest share of the current
labor force are Latinx workers of any race. This includes about 46 percent of workers in
vehicles, and about 60 percent in HVAC and refrigeration. Another 30 percent of the labor force
are White non-Latinx in all three of the major energy demand categories.
For the overall regional workforce, the levels of educational attainment are spread fairly evenly
between the three categories, with 33.7 percent of workers with high school degrees or less,
31.3 percent with some college or Associate’s degrees and 35.0 percent with Bachelor’s
degrees or higher. The racial and ethnic distribution of the overall regional workforce is also
more even than that of the energy demand categories. With the overall workforce, about 39
percent are White non-Latinx, 38 percent are Latinx of all races, 15 percent are Asian and about
5 percent are Black. The share of women employed is between 11 – 21 percent in the major
energy demand areas of vehicles, HVAC, and refrigeration, despite the fact that women make
up 46 percent of the San Diego area workforce.i
i See Appendix 6.B for more details.
Oct. 11, 2022 Item #12 Page 274 of 560
236
Table 6.7. Educational credentials and race/gender composition of workers in energy demand investment areas: direct jobs only.
Investment Area Vehicles HVAC Refrigeration Appliances Construction Lighting Manufacturing
Other
commercial
and
residential Agriculture Mining
Educational
Credentials
% with high school
degree or less 45.0% 58.8% 60.5% 59.7% 61.3% 59.8% 51.0% 59.3% 65.4% 55.8%
% with some college
or Associate degree 32.7% 26.9% 27.7% 26.7% 25.5% 26.6% 24.0% 27.0% 22.0% 20.2%
% with Bachelor’s
degree or higher 22.3% 14.2% 11.8% 13.6% 13.1% 13.6% 25.1% 13.8% 12.5% 24.0%
Racial and Ethnic
Composition
% White, non-Latinx 30.0% 30.0% 29.6% 30.1% 29.8% 29.9% 25.4% 30.0% 24.6% 28.9%
% Black, non-Latinx 9.0% 2.3% 2.2% 2.2% 2.3% 2.1% 2.6% 2.3% 1.1% 3.6%
% Asian, non-Latinx 12.9% 6.1% 5.5% 5.4% 5.1% 5.7% 11.9% 5.9% 4.3% 11.7%
% Other, non-Latinx 2.4% 1.6% 1.6% 1.6% 1.3% 1.5% 1.9% 1.6% 1.2% 4.0%
% Latinx (any race) 45.8% 60.0% 61.1% 60.7% 61.5% 60.7% 58.3% 60.2% 68.8% 51.8%
Gender
% Women 20.8% 12.2% 10.7% 10.5% 10.9% 10.4% 32.6% 11.6% 37.2% 17.1%
Notes: Worker characteristics are based on workers within the San Diego region plus the five surrounding counties that supply the San Diego region with the
highest numbers of commuting workers: Imperial County, Los Angeles County, Orange County, Riverside County, and San Bernardino County. Source: CPS
2015-2019, ACS 2015-2019, IMPLAN 3.1.Oct. 11, 2022Item #12 Page 275 of 560
237
6.4.3 Energy Supply Investments and Job Quality
Tables 6.8 and 6.9 present the job quality and demographic figures for all of the supply
investment categories in the EER model. We focus on the two core areas of expenditures on the
supply side of their model: fossil fuels and clean renewables.
As we see first in Table 6.8, compensation for workers in San Diego’s fossil fuel industry is high,
with pay averaging over $180,000. This figure is clearly well above that for the three main
employment categories on the demand side of the EER model, where the pay range is between
$62,000 and $78,000. Average compensation in clean renewables, at roughly $100,000, is also
well below that for workers in the fossil fuel industry, but still significantly higher than the
averages for the energy demand categories. These compensation figures are also well above
the average for the overall workforce in the San Diego region, as reported in Appendix 6.B.
In terms of the provision of employer-sponsored health care, the coverage rate is 83 percent
for fossil fuel workers and 60 percent for those in clean renewables. The unionization rates are
relatively high in these two largest energy supply areas, at 18 percent in the fossil fuel sector
and 11 percent in clean renewables. These figures are close to those for the main areas of
energy demand.
Table 6.8 Job quality indicators in energy supply investment areas: direct jobs only.
Investment Area Average total
compensation*
Health insurance
coverage, percentage**
Union membership,
coverage***
Fossil fuels $181,800 82.9% 18.0%
Clean renewables $97,600 59.5% 11.5%
Transmission and storage $69,700 69.4% 15.4%
Additional supply technologies $75,100 51.3% 14.6%
Other investments $75,900 55.8% 12.6%
Notes: See notes to Table 6.6. Source: CPS 2015-2019, ACS 2015-2019, IMPLAN 3.1.
6.4.4 Educational Credentials and Racial, Ethnic and Gender Composition
In Table 6.9, we present data on both the educational credentials as well as the racial, ethnic
and gender composition of the workers employed in the supply-side areas of the EER model.
We again focus here only on the workers who are employed directly through these
investments.
As Table 6.9 shows, in the fossil fuel sector, the educational attainment level of the industry’s
workforce is evenly divided between those without high school degrees or less, those with
some college, and those with Bachelor’s degrees or higher. In clean renewables, there is one
major difference, in that nearly half of the workers have only high school degrees or less.
Oct. 11, 2022 Item #12 Page 276 of 560
238
Table 6.9 Educational credentials and race/gender composition of workers in energy supply investment areas:
direct jobs only.
Investment Area
Fossil fuels
Clean
renewables
Transmission and
storage
Additional supply
technologies Other investments
Educational Credentials
% with high school degree
or less 31.1% 46.5% 40.6% 58.8% 51.9%
% with some college or
Associate degree 35.6% 23.4% 28.7% 26.6% 25.8%
% with Bachelor’s degree
or higher 33.4% 30.1% 30.7% 14.6% 22.3%
Racial and Ethnic
Composition
% White, non-Latinx 37.3% 35.2% 34.9% 28.8% 33.9%
% Black, non-Latinx 5.1% 2.7% 3.4% 2.0% 2.6%
% Asian, non-Latinx 11.4% 10.8% 11.6% 5.7% 7.6%
% Other, non-Latinx 2.4% 2.0% 2.3% 1.5% 1.8%
% Latinx (any race) 43.7% 49.4% 47.9% 62.0% 54.1%
Gender
% Women 23.0% 19.0% 20.4% 21.5% 16.3%
Note: See notes to Table 6.7. Sources: ACS 2015-2019, IMPLAN 3.1.
In terms of the racial and ethnic composition, the largest share of the labor force are Latinx of
any race, at 44 percent in the fossil fuel sector and 49 percent in clean renewables. The Latinx
shares are also in that range or higher in the smaller energy supply investment categories.
White non-Latinx workers comprise another 37 percent of the workforce in the fossil fuel sector
and 35 percent in clean renewables. Black non-Latinx workers represent a small share of the
workforce in both fossil fuels and clean renewables, at 5.1 percent and 2.7 percent respectively.
Women remain badly underrepresented in the main areas of supply side expenditures, at 23
percent for fossil fuels and 19 percent in clean renewables. Again, these figures are well below
the share of women in the overall regional workforce, at nearly 46 percent.
6.4.5 Prevalent Job Types with Energy Demand and Supply Employment
In addition to these average results across the various energy supply investment and energy
demand expenditure areas, it is important to consider the range of the types of jobs that will be
generated in each of the specified areas. To provide a picture of this range of jobs, Tables 6.10
A-C and 6.11A-B present more detailed information about the jobs created by the energy
demand and energy supply investments. Table 6.10A shows details for vehicles, Table 6.10B for
HVAC, Table 6.10C for refrigeration, Table 6.11A for fossil fuels, and Table 6.11B for renewable
energy. These tables also show detailed breakdowns on the union status as well as the racial,
ethnic, and gender composition of the labor force in each of the specific job categories.
Oct. 11, 2022 Item #12 Page 277 of 560
239
Tables 6.10A-C provide representative job titles within the major occupational group that we
expect will make up at least 5 percent of the direct jobs created by the three largest demand
investment areas. It is difficult to summarize the detailed data on job categories presented in
these tables, but the overall pattern is clear: investing to build a clean energy economy will
produce new employment opportunities at all levels of the regional economy. New job
opportunities will open for, among other occupations, carpenters, machinists, chemists,
environmental scientists, secretaries, accountants, heating installers, truck drivers, pipelayers,
and construction laborers, as well as a full range of managerial occupations. At the same time,
blue-collar jobs—such as in transportation and material moving, construction, and production
occupations—predominate and such jobs tend to range widely in job quality depending on such
factors as unionization and subcontracting.
To see this, we also provide in Tables 6.10A-C and 6.11A-B several wage measures for each
occupational group. Specifically, we show the 25th wage percentile, the 50th wage percentile
(median), and the 75th wage percentile. The 25th percentile--the wage at which 25 percent of
workers in the occupational group earn less and 75 percent earn more—indicates the typical
pay rate at the low end of the wage distribution. Likewise, the 75th percentile—the wage at
which 75 percent of workers in the occupational group earn less and 25 percent earn more—
indicates the typical pay rate at the high end of the wage distribution. The median figure
provides the wage rate of the worker exactly in the middle of the wage distribution.i
These wage figures in Tables 6.10A-C and 6.11A-B show that the quality of jobs can range
widely, with a significant share reasonably characterized as low wage. For example, production
jobs and transportation and material moving jobs produced by investments in vehicles have
typical pay rates of between $12.00 and $22.00 per hour, with half of workers in these jobs
earning less than $16.00 per hour. Pay rates among construction and office jobs from these
investments range more widely, indicating a greater mix of low- to high-wage jobs. The 25th,
50th, and 75th wage percentiles among these jobs correspond closely with those in the overall
workforce. For the overall regional labor force, as we report in Appendix 6.B, workers in the
25th percentile earn an average of $12.90 per hour, the median worker earns $18.90 per hour,
and the 75th percentile worker is paid $31.90 per hour. ii
Management jobs, on the other hand, consistently provide higher wages, though the range is
i Note that these wage figures are different from the compensation figures in Tables 6.6 and 6.7 which include the
value of benefits, such as employer-sponsored health insurance.
ii Note that these wage estimates are based on wage data pooled from 2015-2019 and are adjusted for inflation to
reflect 2020 dollars. However, during these years the state minimum increased from $9.00 in 2015 to $12.00 in
2019 for employers with at least 26 employees. This minimum is $14.00 as of January 2021 (slightly lower rates applied to smaller employers). If we were able to estimate these wages based only on data from 2021 or even
2019, the 25th wage percentile would undoubtedly be higher.
Oct. 11, 2022 Item #12 Page 278 of 560
240
also wide, with typical hourly rates between $30.00 and $54.00. The types of jobs and
associated pay rates generated from investments in HVAC, refrigeration, and clean renewables
largely mirror those jobs and rates generated through investments in vehicles. The one
significant exception is that construction employment represents a larger share of employment
in the HVAC, refrigeration, and clean renewable sectors, as opposed to the transportation and
material moving jobs, which are more heavily represented in the production of vehicles.
The prevalent job types from spending on fossil fuels have two qualities that distinguish them
from the jobs generated by other spending areas. First, fossil-fuel jobs are composed of a
greater variety of occupations with none of the representative occupations taking up more than
15 percent of total employment generated by these investments. At the same time, blue collar
occupations still comprise about half of the fossil fuel jobs, much higher than the one-fifth that
exists in San Diego’s overall labor market.i Second, with the exception of management
occupations, the fossil fuel jobs pay higher rates—even when compared to jobs within the same
representative occupational groups. Take construction occupations, for example. Typical hourly
pay rates in the construction jobs generated by fossil fuel spending range between $21.00 and
$40.00 as compared to $13.00 to $28.00 among the jobs created by the other spending areas.
In sum, Tables 6.10A-C and 6.11A-B show the wide-range in job types among demand and
supply employment. At the same time, a significant share of these jobs currently pay relatively
low wages. Therefore, the clean energy investments agenda for San Diego should include
policies that will ensure decent wages, benefits and working conditions.
The figures in these tables on racial, ethnic, and gender proportions vary by the specific job
categories. For example, the share of Latinx workers in management positions in all of the
energy supply and demand sectors is relatively low, ranging between 21 – 28 percent while the
share in production jobs is mostly around 70 percent. Similarly, in terms of gender composition,
between about 50 – 70 percent of workers employed in office and administrative support are
women. By contrast, women hold only between 2 – 4 percent of the construction jobs in the
various sectors. White workers hold over 50 percent of the management positions in all of the
specific employment areas. Regional decarbonization should therefore also include measures to
address these disparities by race, ethnicity, and gender as a central feature of its overall policy
package.
i According to data from the Labor Department’s Occupational Employment and Wages Statistics program, the
blue-collar occupational groups (construction and extraction; production; installation, maintenance, and repair; farming, fishing, and forestry; building and grounds cleaning and maintenance; and transportation and material
moving) made up about 20 percent of employment in the San Diego metropolitan area in May 2020.
Oct. 11, 2022 Item #12 Page 279 of 560
241
Table 6.10A Vehicles: prevalent job types (job categories with 5 percent or more employment).
Job Category Transportation and
material moving Construction Production Management Office and
administrative support
Percentage of Total Industry
Employment 38.2% 13.7% 13.6% 9.3% 7.0%
Representative Occupations Order fillers; freight
movers; bus drivers
Electricians;
carpenters;
construction laborers
First-line supervisors;
welding workers;
electrical assemblers;
General managers;
marketing managers;
construction managers
Dispatchers;
bookkeeping clerks;
administrative assistants
Wages
25th percentile $12.20 $13.70 $12.20 $29.50 $14.50
50th percentile (median) $15.60 $18.70 $15.40 $44.40 $20.90
75th percentile $21.50 $27.70 $18.30 $53.70 $26.10
Union Status
% Union Members or
Covered by Union Contract 19.9% 15.3% 10.1% 5.5% 8.8%
Racial and Ethnic Composition
% White, non-Latinx 29.0% 21.0% 13.8% 56.8% 30.4%
% Black, non-Latinx 16.9% 2.2% 2.5% 4.8% 7.8%
% Asian, non-Latinx 12.1% 2.9% 10.6% 12.7% 12.7%
% Other, non-Latinx 3.1% 1.1% 1.2% 3.4% 2.7%
% Latinx (any race) 39.0% 72.8% 71.8% 22.3% 46.4%
Gender
% Women 21.6% 2.3% 20.9% 16.8% 55.7%
Note: This table—aside from wages and unionization rates—is based on workers within the San Diego region plus the five surrounding counties that supply the
San Diego region with the highest numbers of commuting workers. These counties include: Imperial County, Los Angeles County, Orange County, Riverside
County, and San Bernardino County. To achieve sufficient sample sizes, wage and union estimates from the CPS -ORG files are based on workers from the
southern region of California. This region includes the counties of Fresno, Imperial, Inyo, Kern, Kings, Los Angeles, Mono, Orange, Riverside, San Bernardino,
San Diego, Santa Barbara, Tulare, and Ventura. The wage data are adjusted for inflation to reflect 2020 dollars. However, during these years the state minimum
increased from $9.00 in 2015 to $12.00 in 2019 for employers with at least 26 employees (slightly lower rates applied to smaller employers). This minimum is
$14.00 as of January 2021. If we were able to estimate these wages based only on data from 2021 or even 2019, the 25th wage percentile would undoubtedly
be higher. Sources: ACS 2015-2019, IMPLAN 3.1, and CPS-ORG 2015-2019. Oct. 11, 2022Item #12 Page 280 of 560
242
Table 6.10B HVAC: prevalent job types (job categories with 5 percent or more employment).
Job Category Construction Management Production Office and administrative
support
Percentage of Total Industry
Employment 53.0% 13.2% 9.5% 6.3%
Representative Occupations Electricians, first-line
supervisors; painters
Chief executives; operations
managers; sales managers
First-line supervisors; brazing
workers; assemblers
Shipping clerks; accounting
clerks; general office clerks
Wages
25th percentile $14.60 $25.90 $12.90* $13.60*
50th percentile (median) $19.00 $35.70 $16.40 $19.40
75th percentile $27.70 $52.00 $22.60 $26.00
Union Status
% Union Members or Covered by
Union Contract 16.4% 6.8% 9.7% 5.7%
Racial and Ethnic Composition
% White, non-Latinx 21.0% 59.0% 16.5% 40.2%
% Black, non-Latinx 1.7% 2.4% 1.4% 3.7%
% Asian, non-Latinx 2.7% 8.8% 9.2% 8.3%
% Other, non-Latinx 1.2% 2.0% 1.1% 4.1%
% Latinx (any race) 73.4% 27.8% 71.8% 43.8%
Gender
% Women 2.0% 14.7% 17.6% 71.6%
Sources: ACS 2015-2019, IMPLAN 3.1, CPS-ORG, 2015-2019. See notes to Table 6.10A.
Oct. 11, 2022Item #12 Page 281 of 560
243
Table 6.10C Refrigeration: prevalent job types (job categories with 5 percent or more employment).
Job Category Construction Production Installation and
maintenance Management Office and
administrative support
Percentage of Total
Industry Employment 34.2% 21.4% 15.5% 8.9% 6.6%
Representative
Occupations
First-line supervisors;
painters;
construction laborers
Inspectors;
machinists;
soldering workers
General maintenance
workers; heating installers;
heavy vehicle technicians
Marketing managers;
operations managers;
chief executives
Inventory clerks; general
office clerks; auditing
clerks
Wages
25th percentile $14.70 $12.20 $14.90 $25.10 $15.60
50th percentile
(median) $19.00 $16.40 $19.90 $34.60 $19.90
75th percentile $27.70 $20.70 $25.90 $54.20 $28.40
Union Status
% Union Members or
Covered by Union
Contract
16.5% 20.1% 15.7% 7.1% 4.6%
Racial and Ethnic Composition
% White, non-Latinx 21.0% 17.3% 33.6% 61.7% 40.9%
% Black, non-Latinx 1.7% 3.4% 0.9% 2.4% 2.7%
% Asian, non-Latinx 2.8% 4.6% 4.1% 8.5% 9.0%
% Other, non-Latinx 1.1% 1.7% 1.5% 2.0% 4.2%
% Latinx (any race) 73.4% 73.0% 59.9% 25.5% 43.1%
Gender
% Women 2.3% 5.2% 1.7% 15.5% 73.5%
Sources: ACS 2015-2019, IMPLAN 3.1, CPS-ORG, 2015-2019. See notes to Table 6.10A.Oct. 11, 2022Item #12 Page 282 of 560
244
Table 6.11A Fossil Fuels: prevalent job types (job categories with 5 percent or more employment).
Job Category Office and administrative support Production Management Construction Architecture
and engineering
Installation and
maintenance
Transportation and material moving Extraction
Percentage of Total
Industry
Employment
14.3% 13.9% 11.5% 10.5% 8.0% 7.2% 7.1% 6.4%
Representative Occupations
Production clerks; executive secretaries; utility meter readers
Welding
workers;
inspectors;
first-line
supervisors
Financial
managers;
computer systems
managers; general
managers
Construction
equipment
operators;
electricians;
pipelayers
Industrial engineers; mechanical engineers; petroleum engineers
Mobile equipment
service
technicians; truck
mechanics; valve
installers
Pumping station
operators; freight
movers;
driver/sales
workers
Earth drillers; explosive workers; derrick operators
Wages
25th percentile $18.10 $17.20 $22.10 $21.30 $28.40 $20.30 $13.50 $20.30
50th percentile
(median) $26.50 $20.80 $41.50 $31.60 $43.40 $24.80 $22.30 $25.40
75th percentile $35.00 $42.90 $73.20 $39.50 $53.30 $39.30 $27.10 $36.00
Union Status
% Union Members
or Covered by
Union Contract
24.4% 21.5% 0.7% 22.6% 23.1% 34.8% 3.5% 12.2%
Racial and Ethnic Composition
% White, non-Latinx 32.0% 31.8% 58.7% 30.8% 49.7% 32.4% 27.0% 32.7%
% Black, non-Latinx 6.6% 3.4% 4.8% 2.8% 0.8% 4.2% 8.9% 16.6%
% Asian, non-Latinx 10.3% 10.7% 14.4% 1.2% 13.0% 2.6% 0.7% 0.0%
% Other, non-Latinx 5.0% 2.4% 1.4% 3.8% 2.1% 5.7% 0.1% 0.0%
% Latinx (any race) 46.1% 51.7% 20.7% 61.4% 34.3% 55.1% 63.3% 50.7%
Gender
% Women 51.2% 13.6% 31.4% 4.1% 15.3% 1.3% 4.5% 2.4%
Sources: ACS 2015-2019, IMPLAN 3.1, CPS-ORG, 2015-2019. See notes to Table 10A.Oct. 11, 2022Item #12 Page 283 of 560
245
Table 6.11B Clean Renewables: prevalent job types (job categories with 5 percent or more employment).
Job Category Construction Management Life, physical and social
science
Office and administrative
support
Percentage of Total Industry
Employment 46.6% 14.2% 8.0% 6.2%
Representative Occupations Electricians, first-line
supervisors; painters
Operations managers; sales
managers; construction
managers
Chemical scientists; material
scientists; biological
scientists
Customer service
representatives; auditing
clerks; general office clerks
Wages
25th percentile $14.70 $27.70 $20.30 $13.60
50th percentile (median) $19.10 $40.00 $29.90 $18.60
75th percentile $27.70 $59.20 $47.30 $26.00
Union Status
% Union Members or Covered by
Union Contract 16.6% 6.0% 2.0% 4.4%
Racial and Ethnic Composition
% White, non-Latinx 21.0% 57.9% 46.8% 46.5%
% Black, non-Latinx 1.7% 3.6% 3.0% 4.7%
% Asian, non-Latinx 2.7% 12.5% 34.8% 10.2%
% Other, non-Latinx 1.2% 2.8% 2.2% 3.4%
% Latinx (any race) 73.4% 23.3% 13.1% 35.2%
Gender
% Women 1.9% 22.1% 47.1% 73.9%
Sources: ACS 2015-2019, IMPLAN 3.1, CPS-ORG, 2015-2019. See notes to Table 10A.Oct. 11, 2022Item #12 Page 284 of 560
246
6.5 Job Contraction for Workers in Fossil Fuel-Based Industries
The transition for the San Diego region into a net zero emissions economy by 2050 will entail
the phasing out of burning oil, coal, and natural gas to produce energy. In Table 6.12, we show
the rates of contraction for oil, coal, and natural gas within the EER model. As the table shows,
the contraction rates for oil and gas in the EER model are quite modest through 2030. Indeed,
natural gas consumption in the EER model does not decline at all through 2030, while the
consumption of oil falls by only 20 percent. Coal is generally not currently consumed in the San
Diego region, and the EER model shows no coal consumption in 2030.
Table 6.12 Assumptions on contraction rates for the San Diego region fossil fuel sectors: contractions as of 2030
and 2050 based on contraction rates for the region within the EER model.
2030 2050
Oil -20% -95%
Natural Gas No contraction -75%
Coal -100% -100%
As Table 6.12 shows, the EER model shows that the major contractions in oil and gas
consumption in the San Diego region will occur between 2031 – 2050. However, this paper
primarily focuses on the contraction process in oil and gas through 2030 in the San Diego region
and its impacts on regional employment.
6.5.1 Current Levels of Fossil Fuel-Based Employment
Table 6.13 shows the most recent figures on employment levels for all fossil fuel and ancillary
industries in the San Diego region. As we see, total fossil fuel-based employment in the region
as of 2018 is 9,239, or about 0.6 percent of total regional employment. Of this total level of
employment, we also see that 6,434 of the total, or nearly 70 percent of all the fossil fuel-based
jobs in the region, are in natural gas distribution. Another 1,418 jobs, about 15 percent of the
total, are in oil and gas extraction. About 5 percent of the total are in wholesale distribution of
oil. In short, roughly 90 percent of all fossil fuel-based employment in the San Diego region is in
these three areas—first, and most importantly, natural gas distribution, then to a lesser extent,
oil and gas extraction as well as the wholesale distribution of petroleum products.i
i We should note that the ancillary fossil fuel-based industries listed in Table 6.13 approximately match up with the
industries in which indirect employment occurs resulting through fossil fuel sector production, as defined in the
input-output tables, and as we have described above. In estimating the number of workers who might experience
job displacement, it is more accurate to focus on the direct employment figures for these ancillary fossil fuel
industries as opposed to utilizing the indirect employment data from the input-output tables. With the data
reported on in Table 6.13, we are able to incorporate important details on employment conditions in these ancillary industries by working with the available employment data on the specific industries as opposed to relying
on a single generic category of indirect employment for the oil/gas and coal industries. At the same time, for the
Oct. 11, 2022 Item #12 Page 285 of 560
247
Table 6.13 Number of workers in the San Diego region employed in fossil fuel-based industries, 2018.
Industry 2018 Employment
Levels
Industry share of total fossil
fuel-based employment
Natural gas distribution 6,434 69.6%
Oil and gas extraction 1,418 15.4%
Wholesale petroleum and petroleum
products 491 5.3%
Support activities for oil/gas 228 2.5%
Oil and gas pipeline transportation 218 2.4%
Support activities for coal 177 1.9%
Drilling oil and gas wells 118 1.3%
Oil and gas field machinery and
equipment manufacturing 45 0.5%
Fossil fuel electric power generation 41 0.4%
All other petroleum and coal products
manufacturing 32 0.3%
Petroleum refining 29 0.3%
Oil and gas pipeline construction 8 0.1%
Mining machinery and equipment
manufacturing 0 0.0%
Coal mining 0 0.0%
Fossil fuel industry total 9,239 100.0%
TOTAL FOSSIL FUEL EMPLOYMENT AS
SHARE OF SAN DIEGO EMPLOYMENT 0.63%
(the San Diego region 2018
employment = 1,464,125)
Source: IMPLAN 3.0. U.S. Department of Labor.
6.5.2 Characteristics of Fossil Fuel and Ancillary Industry Jobs and Workforce Composition
Table 6.14 provides basic figures on the characteristics of the jobs in fossil fuel-based industries
purposes of drawing comparisons with the figures we have presented above on employment creation through
clean energy investments, it is useful to keep in mind that the figures we are reporting here on ancillary
employment relative to the oil/gas and coal industries are the equivalent of the indirect employment figures we
report in the clean energy industries.
Oct. 11, 2022 Item #12 Page 286 of 560
248
as well as on the educational credentials and racial, ethnic, and gender composition of the
workforce.
Starting with the compensation figures, the table shows that, on average, these are relatively
high-quality jobs. The average overall compensation level is $212,900. Of course, this figure is 2
– 3 times higher than any of the energy demand sectors, as reported in Table 6.6. It is also more
than twice as high as the average compensation level in renewable energy.
Table 6.14 Characteristics of workers employed in the San Diego region’s fossil fuel-based sectors.
Fossil Fuel-Based industries
Average total compensation $212,900
Health insurance coverage 86.8%
Union membership coverage* 21.9%
Educational credentials
Share with high school degree or less 25.2%
Share with some college or Associate degree 36.3%
Share with Bachelor’s degree or higher 38.5%
Racial and ethnic composition
% White, non-Latinx 37.6%
% Black, non-Latinx 4.9%
% Asian, non-Latinx 12.2%
% Other, non-Latinx 3.1%
% Latinx (any race) 42.2%
Gender composition
% Women 26.1%
Note: All the estimates-aside from the compensation figures and union membership coverage—in this table are
based on data from the ACS. Compensation figures are from IMPLAN and are for the San Diego region. The
estimates for the other characteristics are based on data from workers in the San Diego region plus the five
surrounding counties that supply the San Diego region with the highest numbers of commuting workers: Imperial
County, Los Angeles County, Orange County, Riverside County, and San Bernardino County. The one exception is
the union measure. The ACS does not ask about union membership. The union coverage measure is estimated
from the ORG files of the CPS which have smaller sample sizes than the ACS. To construct an adequate sample size,
the union density measure is based on 14 counties that make up the southern region of California: Fresno,
Imperial, Inyo, Kern, Kings, Los Angeles, Mono, Orange, Riverside, San Bernardino, San Diego, Santa Barbara,
Tulare, and Ventura. Source: ACS 2015-2019; CPS ORG 2015-2019.
The figure is even roughly $30,000 higher than the $182,000 average compensation figure we
report in Table 6.8 for the supply-side investments in the fossil fuel sector itself. The reason
that the Table 6.8 and 6.14 figures are not identical, even though they both are showing
compensation figures in the fossil fuel sector, is that the mix of specific spending areas within
the supply investment categories is not the same as the current overall profile of employment
in the region’s fossil fuel sectors.
Oct. 11, 2022 Item #12 Page 287 of 560
249
Workers in these industries are also relatively well off in terms of the benefits they receive from
their jobs. Nearly 90 percent of them receive health insurance from their jobs. Union
membership is at nearly 22 percent. This figure is more than 3 times higher than the average
for the entire U.S. private sector, at only 6.2 percent, and also higher than the average 13
percent for Southern California (see Appendix 6.B). Again, these figures are largely reflecting
the favorable working conditions in the natural gas distribution industry. These job quality
measures are also high in comparison with the figures for the overall regional workforce—i.e.
the same overall regional workforce figures we report in Appendix 6.B and have summarized in
the text above.
With respect to workforce composition, the jobs are, first of all, distributed fairly evenly with
respect to educational credentials, with 25 percent of workers having high school degrees or
less, 36 percent having some college and 39 percent with Bachelor’s degrees or higher.
As with the clean energy sectors, Latinx workers of all races constitute the largest proportion of
the labor force, at 42 percent. White non-Latinx workers represent another 38 percent of the
labor force in the fossil fuel-based sectors. Thus, Latinx and White non-Latinx workers together
account for 80 percent of the overall labor force. Asian non-Latinx workers account for another
12 percent and Black non-Latinx workers represent slightly less than 5 percent of the labor
force. Again, as with clean energy, women are significantly underrepresented, at only 26
percent of the total.
We provide more specifics on the composition of the workforce in the fossil fuel-based
industries in Table 6.15, in which we list all the job categories in which 5 percent or more of the
workforce is employed and their associated wage estimates, as was done in Tables 6.10 and
6.11. As we see, the highest percentage of jobs, at 18.6 percent, are in office and administrative
support, including dispatchers, production clerks, and meter readers. Various forms of
management are the next largest category of employment in the fossil fuel-based industries in
San Diego, at 12.4 percent. Next comes production workers, at 10.6 percent of all employment.
The representative occupations in these jobs include welding workers, inspectors, and first-line
supervisors.
Oct. 11, 2022 Item #12 Page 288 of 560
250
Table 6.15 Prevalent job types in the San Diego region’s fossil fuel-based industries (job categories with 5 percent or more employment).
Job Category
Office and
administrative
support
Management Production Construction Architecture
and engineering
Installation and
maintenance Transportation
Computer and
mathematical
science
Percentage of Total
Industry Employment 18.6% 12.4% 10.6% 9.9% 8.7% 8.6% 5.6% 5.3%
Representative
Occupations
Dispatchers;
production
clerks; meter
readers
Financial
managers;
computer and
information
systems
managers; chief
executives
Welding
workers;
inspectors;
first-line
supervisors
Construction
equipment
operators;
electricians;
construction
laborers
Surveying
technicians;
mechanical
engineers;
petroleum
engineers
Precision
instrument and
equipment
repairers; truck
mechanics;
control and valve
installers
Motor vehicle
operators;
pumping
station
operators;
freight movers
Computer
programmers;
computer systems
analysts; software
developers
Wages
25th percentile $18.10 $18.00 $31.20 $18.00 $40.80 $20.30 $19.90 ---
50th percentile
(median) $29.90 $37.60 $42.90 $24.80 $43.40 $25.60 $20.80 ---
75th percentile $53.90 $54.20 $45.70 $35.50 $53.30 $40.90 $23.60 ---
Union Status
% Union Members or
Covered by Union
Contract
27.0% 0.4% 34.4% 22.5% 30.3% 35.5% 16.3% ---
Racial and Ethnic Composition
White 28.8% 53.7% 39.2% 31.2% 52.8% 34.2% 36.2% 17.8%
Black 6.6% 6.0% 3.9% 4.3% 1.4% 4.8% 6.0% 7.4%
Asian 10.7% 18.8% 10.2% 2.1% 9.0% 2.5% 3.0% 45.0%
Other 5.5% 1.6% 2.6% 6.2% 1.0% 6.5% 0.7% 0.0%
Latinx 48.4% 19.9% 44.1% 56.1% 35.8% 52.0% 54.1% 29.8%
Gender Composition
Women 49.0% 38.0% 13.5% 5.8% 16.8% 1.3% 8.3% 41.3%
Notes: See notes to Table 6.10A. “--” indicates that the sample size was insufficient to produce reliable estimates. Source: ACS 2015-2019, IMPLAN 3.1, and
CPS-ORG, 2015-2019. Oct. 11, 2022Item #12 Page 289 of 560
251
Generally speaking, as with the areas of employment in both the demand and supply sides of
the EER model’s Central Case, the San Diego region’s fossil fuel-based industries employ a wide
range of workers. Some of them will have skills specific to the industry and will therefore face
difficulties moving into new employment areas, but the majority of the workers should be able
to transfer to new employment opportunities in the clean energy economy or elsewhere.
Additionally, as can be expected, the pay rates of fossil fuel-based industry jobs in Table 6.15
look similar to those among jobs generated by the fossil fuel investments represented in Table
6.11A, all of which have higher typical pay rates than the region overall. As a result, for those
workers who need to move into new employment areas, an important component to a just
transition will be the wage insurance policies discussed in the next section.
As we have seen with the clean energy investment areas, there are significant differences in the
racial, ethnic, and gender composition of the labor forces in the respective sectors. Thus, White
workers account for a majority of the workforce in management, architecture, and engineering
jobs. Asian workers account for the largest employment share in computers and mathematical
science positions, at 45 percent of the labor force. Latinx workers represent the largest share in
all other employment categories (office and administrative support, production, construction,
installation and transportation). Women account for nearly 50 percent of the labor force in
office and administrative jobs and roughly 40 percent of the labor force in management and
computer and mathematical science jobs. The share of women otherwise ranges between 1 –
17 percent in the areas of production, construction, architecture/engineering,
installation/maintenance, and transportation.
6.5.3 Estimating Annual Job Losses through Fossil Fuel Contraction
For understanding the impact of the phase-down of the fossil fuel-based industries on
employment in the San Diego region (and elsewhere), the most relevant metric will be the rate
at which workers are likely to be losing their jobs through the phase-down. This analysis
assumes a 20 percent decrease in oil consumption relative to current consumption and no
change in natural gas consumption by 2030 (Table 6.12) and an average of 6,000 new fossil
fuel-related jobs each year through 2030 (Table 6.8). Under these conditions, there will still be
job losses resulting from oil contractions.
However, the assumption of stable natural gas consumption in the San Diego region is crucial
because roughly 70 percent of the current 9,239 fossil fuel industry-based jobs in the region are
in the natural gas distribution sector (Table 6.13). Most of these jobs will remain at current
levels through 2030, but there will be some employment losses in this sector through 2030 due
to reduced natural gas distribution infrastructure investments. As such, it is reasonable to
assume that the construction industry jobs associated with the San Diego region’s natural gas
Oct. 11, 2022 Item #12 Page 290 of 560
252
industry—jobs that would be tied to the expansion of the sector—will be phased out by 2030.
We have incorporated this factor into our estimate below of the overall fossil fuel-based
industry employment losses through 2030.
We therefore estimate the total number of jobs that will be phased out in San Diego’s fossil
fuel-based industries through 2030, based on the assumptions that: 1) oil consumption declines
by 20 percent; 2) natural gas consumption remains constant; and 3) construction activity in the
natural gas sector falls to zero. We then also need to incorporate two other considerations in
generating the job contraction estimates for the region’s fossil fuel-based sectors: 1) the
attrition rate in the sector’s labor force due to voluntary retirements; and 2) whether the rate
of contraction will be steady or episodic.
Labor force attrition through voluntary retirements. About 80 percent of workers in the U.S.
fossil fuel-based industries choose to retire voluntarily once they reach age 65. As the San Diego
region’s fossil fuel-based industries contract, workers will only experience job losses if they are
not choosing to retire. As such, the rate of voluntary retirements in the industry can offset the
rate at which the industry is contracting, thereby reducing the extent of job losses and
displacement. Therefore, voluntary retirement is an important component of our estimate of
job losses in the sector.
Steady versus episodic industry contraction. The scope and cost of any set of policies to
manage a just transition for impacted workers will depend heavily on whether the contraction
is steady or episodic. Under a pattern of steady contraction, there will be uniform annual
employment losses over both the 2020 – 2030 and 2031 – 2050 periods, with the steady rates
determined by the overall level of industry contraction within the given time period. However,
it is not realistic to assume that the pattern of industry contraction will necessarily proceed at a
steady rate. An alternative pattern would entail relatively large episodes of employment
contraction, followed by periods of no further employment losses. This type of pattern would
occur if, for example, one or more relatively large firms were to undergo large-scale cutbacks at
one point in time as the industry overall contracts, or even for such firms to shut down
altogether.
The costs of a just transition will be much lower if the transition is able to proceed steadily
rather than through a series of episodes. One reason is that, under a steady transition, the
proportion of workers who will retire voluntarily in any given year will be predictable. When
retirements are predictable, a smaller share of workers will require support. In episodic
transitions, for example if several large businesses were to shut down abruptly and lay off their
full work force at once, then a larger share of workers, both young and old, would require
support. Similarly, it will be easier to find new jobs for displaced workers if the pool of displaced
Oct. 11, 2022 Item #12 Page 291 of 560
253
workers at any given time is smaller, as would be the case in a steady transition.
For the purposes of our calculations, we assume that the San Diego region will successfully
implement a relatively smooth contraction of its fossil fuel industries. A well-designed and
effectively implemented just transition program should focus on smoothing out fossil fuel
contractions.
Incorporating these considerations, in Table 6.16, we show figures on annual employment
reductions in the region’s fossil fuel-based industries over 2021 – 2030. We also then estimate
the proportion of workers who will move into voluntary retirement at age 65 as of 2030. Once
we know the share of workers who will move into voluntary retirement at age 65, we can then
estimate the number of workers who will be displaced through the industry-wide contraction.
Table 6.16 Attrition by retirement and job displacement for fossil fuel. Workers in the San Diego region, 2021-2030.
Fossil Fuel Workers
1) Total workforce as of 2018 9,239
2) Total job losses over 10-year transition, 2021-2030 1,078*
3) Average annual job loss over 10-year production
decline (= row 2 value divided by 10)
108
4) Number of workers reaching 65 over 2021-2030 period
(=row 1 x % of workers 54 and over in 2019)
1,977
(21.4 % of all workers)
5) Number of workers per year reaching 65 during 10-
year transition period (=row 4 value divided by 10)
198
6) Number of workers per year reaching age 65 and
retiring voluntarily (=row 5 x % retiring voluntarily)
158
(80% of 65+ workers retire voluntarily**)
7) Number of workers requiring re-employment (= row 3
– row 6)
0
Source: Table 6.1. Note: *Job losses include 605 construction jobs in the natural gas distribution industry that will
phase out in phase 1 because the industry will contract by 75 percent during 2031-2050. **The 80 percent
retirement rate for workers over 65 is derived from U.S. Bureau of Labor Statistics data:
https://www.bls.gov/cps/cpsaat03.htm. According to these BLS data, 20 percent of 65+ year-olds remain in the
workforce. We therefore assume that 80 percent of workers aged 65 years and over retire voluntarily.
We begin in Table 6.16 with the total fossil fuel-based industry workforce of 9,239 workers.
Based on the respective contraction rates for the oil and construction activity in natural gas, we
estimate that the total job contraction will amount to 1,078 workers over the 2021 – 2030
period. Assuming a steady rate of contraction, this amounts to an average rate of job losses of
108 per year.
We then estimate that 1,977 workers employed in the industry will reach the age of 65 over
Oct. 11, 2022 Item #12 Page 292 of 560
254
2021 – 2030, which averages to 198 workers per year. Of this total, we assume that 80 percent
of these workers will retire voluntarily once they reach age 65.i This amounts to 158 workers in
the San Diego region’s fossil fuel-based industries retiring voluntarily per year.
Thus, according to our estimates, 108 jobs per year will be lost in the San Diego region due to
the region’s contraction of fossil fuel consumption, while 158 workers per year will voluntarily
retire from the industry. Therefore, the San Diego region should not experience any job
displacements and no fossil fuel workers should require reemployment through 2030 as a result
of the region’s commitment to move onto a zero emissions trajectory through 2030.
6.5.4 Planning a Just Transition Program
In working from the EER model’s Central Case for transitioning the San Diego region into a zero
emissions economy by 2050, we have seen that the region’s fossil fuel industry will not
experience job displacements through 2030. However, job displacements will certainly result
between 2031 – 2050, as oil consumption in the region falls by 95 percent relative to the
present level and natural gas consumption falls by 75 percent. As such, advancing the transition
to a zero emissions economy by 2050 is a critical part of regional decarbonization and the San
Diego region should begin now to develop a viable set of just transition policies for the workers
in the community who will experience job displacement between 2031 – 2050.
In previous work, we have outlined just transition programs both for the U.S. overall and for
specific states, including California and Colorado, that include five policy measures (e.g., Pollin
et al. 2019,4 2020,3 and 20215):
1. Pension guarantees for all workers in fossil fuel-based industries, especially those
workers who will be retiring voluntarily over the transition period;
2. Reemployment guarantees for all displaced workers;
3. Wage insurance for all displaced workers. One approach is to guarantee 3 years of total
compensation at levels the workers had been receiving in their fossil fuel jobs;
4. Retraining support. This could include 2 years of retraining support for workers who
required this in their new areas of employment; and
5. Relocation support. This should be sufficient to cover full moving expenses for all
workers who are forced to relocate.
To date, Colorado has been most active in advancing just transition measures in the state. In
particular, in 2019, it established an Office of Just Transition.1 According to website of the
office, its purpose is as follows:
i Our voluntary retirement figure is based only on those who are 65 years and older. We do not assume any early
retirements (i.e., no workers retire before they reach age 65 years).
Oct. 11, 2022 Item #12 Page 293 of 560
255
“...to assist workers and communities that will be adversely affected by the loss
of jobs and revenues due to the closure of coal mines and coal-fired power
plants. Its purpose is to help workers transition to new, high-quality, jobs, to help
communities continue to thrive by expanding and attracting diverse businesses,
and to replace lost revenues.”i
Colorado Governor Polis has also been active in supporting just transition measures at the
federal level.
It would be beneficial for the San Diego region to begin now to consider the most effective
ways through which to implement this, or some comparable set of measures. Beginning this
process now will greatly increase the likelihood that the region will succeed in building a zero
emissions economy while also preventing large numbers of community members from
experiencing major economic losses as the transition program advances.
i https://cdle.colorado.gov/offices/the-office-of-just-transition/about-the-office-of-just-transition
Oct. 11, 2022 Item #12 Page 294 of 560
256
Appendix 6.A Employment Impacts of Geothermal Energy Projects for Imperial
County
In Chapter 2 of this report, “Geospatial Analysis of Renewable Energy Production,” Emily Leslie
and Joseph Bettles describe a project to develop geothermal energy production sites in Imperial
County. They write:
“Five geothermal sites are identified in Imperial County with generation of 10,680 GWh
of electricity (seen as green points in Figure 2.8). This analysis assumes these plants
become fully operational by 2030 and supply the remaining capacity to San Diego after
satisfying Imperial’s electricity demand (see assumptions in Appendix 2.D).”
Here, we estimate the employment impacts of developing this geothermal energy project.
Because the project will be developed in Imperial County rather than the San Diego region, we
estimate the employment effects throughout Southern California. Our estimate is that this
project will generate about 1,900 jobs per year throughout Southern California over the course
of the 10-year period to complete the work. We derive this result as follows:
1. Chapter 2 states that the aim of the project will be to generate 10,680 GWh of
electricity capacity.
2. This level of electricity generation is equal to 0.04 quadrillion BTUs (“Q-BTUs” of
energy).
3. In its February 2021 report on levelized costs of energy generation, the U.S. Energy
Information Agency estimates the lump sum capital expenditures to develop one Q-BTU
of geothermal generating capacity is $78 billion.i
4. Thus, developing 0.04 Q-BTUs of geothermal electricity generating capacity will cost
about $3.1 billion (i.e. $78 billion x 0.04 = $3.1 billion).
5. From these figures, we document in Table 6.A.1 our estimate of job creation throughout
Southern California from building this level of geothermal capacity in Imperial County.
As Table 6.A.1 shows, we estimate that this project will produce an average of 810
direct jobs, 465 indirect jobs, and 589 induced jobs over the 2021 – 2030 period. This
amounts to 1,275 direct and indirect jobs and 1,864 jobs in total.
Table 6.A.1 Job creation in Southern California through geothermal energy projects in Imperial County.
1. Job Creation
per $1 million
2. Job creation through
$3.1 billion in spending
3. Job creation per year over 10-year period,
2021 – 2030 (= column 2 divided by 10)
Direct Jobs 2.6 8,100 810
Indirect Jobs 1.5 4,650 465
Induced Jobs 1.9 5,890 589
Total Jobs 6.0 18,640 1,864
Sources: IMPLAN 3.0.; citations in text.
i EIA study is here: https://www.eia.gov/outlooks/aeo/pdf/electricity_generation.pdf. See Pollin et al. (2021),5 p.
27 for conversion of EIA capital costs in overall levelized cost framework into lump sum capital expenditures.
Oct. 11, 2022 Item #12 Page 295 of 560
257
Appendix 6.B Estimating San Diego Region-Specific Employment
The EER model for Southern California includes the San Diego county region and 13 additional
counties: Ventura, Fresno, Mono, San Bernardino, Riverside, Santa Barbara, Kings, Los Angeles,
Orange, Kern, Tulare, Imperial, and Inyo. In order for us to generate estimates of employment
impacts within the San Diego region itself, we therefore need to work with some assumptions
in defining the proportionate level of activity in the San Diego region relative to all 14 counties
constituting Southern California in the EER model.
As of 2019, the San Diego region’s total economic output is $417.9 billion. This amounts to
about 14.6 percent the total level of activity throughout Southern California, which is $2.87
trillion. In reviewing the evidence from the EER model as well as the detailed input-output data
for the activities in this model, we conclude that a reasonable assumption for estimating
employment creation in the San Diego region is a straightforward one. That is, we estimate that
the level of employment creation in the San Diego region will amount to 15 percent of the
employment creation in Southern California overall through the EER model. In other words,
employment creation in the region generated by the activities in the EER model will be
proportional to the ratio of total output in the San Diego region relative to Southern California,
i.e., with the San Diego region’s output at roughly 15 percent of that for Southern California.
One could certainly develop more detailed assumptions that would relate to various specific
features of the EER model. But incorporating a more highly specified set of assumptions is not
likely to generate more accurate employment estimates. by attempting to develop any set of
more detailed assumptions. Here are the main considerations through which we reached this
conclusion:
Demand-Side and Supply-Side Activities in EER Model
The EER model consists of two sets of activities: demand-side purchases and supply-side
investments. We consider these two sets of activities separately.
Demand-side purchases. The demand-side purchases include everything that consumers in
Southern California purchase that will provide energy services at reduced rates of energy
consumption. These would include purchases of electric vehicles, electric heat pumps and other
HVAC equipment, appliances, and refrigeration equipment.
With these demand-side purchases, it is reasonable to assume that the San Diego region’s
increased purchases will not be constrained by any shortages that would be specific to the
region itself. Shortages of specific products could well emerge as the level of clean energy
expenditures in the region grows rapidly. But there is no reason to assume that any such
Oct. 11, 2022 Item #12 Page 296 of 560
258
shortages are likely to emerge specifically in the region, as opposed to the broader Southern
California region.
Supply-side investments. The supply-side investments include everything that contributes to
supplying a zero-emissions economy—e.g., architectural, engineering and related services,
communication and energy wire manufacturing, turbine manufacturing, residential
construction, scientific research and development, as well as ongoing investments in the
region’s fossil fuel-based industries.
Relative to the demand-side investments, it is less straightforward with the supply-side
investments to assume that the San Diego share of total Southern California activity will remain
proportionate to the Southern California figure. The major consideration that could produce
disproportionately slower growth with any given investment activity within the region would be
if this investment activity produces significant supply constraints to growth within the region as
clean energy activities scale up throughout the region. For example, the installation of solar
panels in the San Diego region might be disproportionately low because of land-use issues. A
disproportionately large share of solar installations might then take place in, say, Riverside
County. The solar-generated electricity could then be imported from Riverside County to the
San Diego region.
In fact, in examining the current profile of supply-side investments in the San Diego region
within the EER model, it does not appear that there should be significant supply constraints
specific to the region as clean energy investments expand in the region. At present, there are
only 7 supply-side activities in the EER model in which the region’s current share is over 25
percent of all Southern California activity—i.e., significantly greater than San Diego’s current
share of overall Southern California output, at 15 percent. These activities are: natural gas
distribution; sugar cane mills and refining; turbine and turbine generator set units
manufacturing; capacitor and other inductor manufacturing; other communication and energy
wire manufacturing; all other miscellaneous electrical equipment and component
manufacturing; and scientific research and development services. Of these 7 activities, there is
only one in which this activity accounts for more than 2 percent of all of San Diego’s economic
activity. That is scientific research and development services, which currently accounts for
nearly 9 percent of the San Diego region’s total output.
It is not likely that the San Diego region would face supply constraints in expanding its scientific
research and development services. This activity will not generate significant land-use
demands. It will also not produce any significant negative environmental impacts. As such, it is
reasonable to conclude that the San Diego region is well-positioned to absorb a substantial
absolute increase in scientific research activity within the region. Indeed, it is almost certain
Oct. 11, 2022 Item #12 Page 297 of 560
259
that the region will welcome a major expansion of activity in this sector.
Overall, again, it therefore seems reasonable to work with a straightforward assumption that
the San Diego region’s share of supply-side activities in the EER model will be maintained, as
with the demand-side activities, at its current share of aggregate Southern California output.
We therefore assume that the share of both the demand- and supply-side activities within the
EER model for Southern California will generate employment in the San Diego region that is
equal to 15 percent of employment creation in Southern California.
Table 6.B.1 Characteristics of Overall Workforce in San Diego and Adjacent Counties
Average total compensation $80,900
Health insurance coverage 62.2%
Union membership coverage 13.3%
Wage Percentiles
25th percentile $12.90
Median $18.90
75th percentile $31.90
Educational credentials
Share with high school degree or less 33.7%
Share with some college or Associate degree 31.3%
Share with Bachelor’s degree or higher 35.0%
Racial and ethnic composition
% White, non-Latinx 38.6%
% Black, non-Latinx 5.3%
% Asian, non-Latinx 15.4%
% Other, non-Latinx 3.2%
% Latinx (any race) 37.5%
Gender composition
% Women 45.8%
Source: ACS 2015-2019; CPS ORG 2015-2019. Note: All the estimates—aside from the compensation figures and
union membership coverage—in this table are based on data from the ACS. Compensation figures are from
IMPLAN and are for the San Diego region. The estimates for the other characteristics are based on data from the
labor force in the San Diego region plus the five surrounding counties that supply the San Diego region with the
highest numbers of commuting workers. These counties include: Imperial County, Los Angeles County, Orange
County, Riverside County, and San Bernardino County. The wage percentiles and union density rate are estimated
from the ORG files of the CPS which have smaller sample sizes than the ACS. To construct an adequate sample size,
the wage percentiles and union density measures are based on 14 counties that make up the southern region of
California. These include: Fresno, Imperial, Inyo, Kern, Kings, Los Angeles, Mono, Orange, Riverside, San
Bernardino, San Diego, Santa Barbara, Tulare, and Ventura.
Oct. 11, 2022 Item #12 Page 298 of 560
260
Appendix 6.C Urban Reforestation And Job Creation For The San Diego Region
In conjunction with investments to build a clean energy infrastructure, the San Diego region can
also advance its decarbonization program through a series of what are termed “nature-based
climate solutions” or simply “natural climate solutions.” Nature-based climate solutions include
a range of land conservation, restoration, and management practices that both promote carbon
storage in soils, trees, and vegetation and also minimize the release of stored carbon resulting
from land-use modifications, wildfires, deforestation and related practices. Among these
decarbonization benefits, and parallel here to clean energy investments, nature-based climate
solutions will generate employment opportunities. We focus here on the job-generating
potential in the San Diego region of one specific nature-based climate solution: urban
reforestation, i.e., planting trees in urban areas.
In a 2020 study Nature-Based Climate Solutions: A Roadmap to Accelerate Action in California
published by The Nature Conservancy, the authors, Chamberlin et al., describe how urban
reforestation throughout the state will both expand carbon storage capacity and provide more
shade to counteract periods of intense heat in urban settings.6 According to the study, San
Diego region includes roughly 112,000 acres of land available for urban reforestation. This
amounts to about 9 percent of 1.2 million acres of suitable land for urban reforestation
throughout California.
The study estimates that urban reforestation throughout California can generate 54.3 million
metric tons (MMT) of cumulative carbon dioxide equivalent (CO2e) by 2050. This is equal to
about 15 percent of California’s total CO2 emissions of 358 MMT as of 2019.6 Assuming San
Diego region provides emissions reductions equivalent to its share of total suitable land for
urban reforestation, that would mean that San Diego region’s urban reforestation program
would produce about 5 MMT of emissions reduction cumulatively by 2050.
The Nature Conservancy study does not provide a cost estimate for achieving this level of CO2e
reductions through urban reforestation, but an extensive survey on this and related issues by
Fuss et al. (2018) suggests that this cost figure would be in the range of $50 per ton of carbon
sequestered.7 This implies that the total costs of San Diego region achieving 5 MMT of carbon
sequestration by 2050 would be $250 million. If we assume that the program begins in 2023,
that would imply average investments of $9.3 million per year between 2023 - 2050.
We can calculate the impact on employment creation from this budgetary estimate. Working
from the same input/output model through which we estimated job creation through clean
energy investments in the region, we estimate that an urban reforestation program for the
region will generate about 14 jobs per $1 million in spending. Thus, if the region were to spend
Oct. 11, 2022 Item #12 Page 299 of 560
261
$9.3 million per year on this program, it would generate about 130 jobs overall within the
region. This level of job creation would be sustained over the full 27 years in which the program
would operate between 2023 – 2050. Of course, the time frame for the program could be
compressed, so that the full benefits of carbon sequestration would occur sooner than 2050.
This would then also generate a larger number of jobs within any given year of the compressed
reforestation program. For example, if the program operated over 10 years—from 2023 –
2032—rather than 27 years, this would generate about 360 jobs in the region that would be
sustained over the 10-year period.
Oct. 11, 2022 Item #12 Page 300 of 560
262
Works Cited:
1. Colorado Department of Labor and Employment. (n.d.) “The Office of Just Transition.”
https://cdle.colorado.gov/the-office-of-just-transition.
2. Pollin, Robert, Heidi Garrett-Peltier, James Heintz, and Shouvik Chakraborty (2015) Global Green Growth:
Clean Energy Industrial Investments and Expanding Job Opportunities, United Nations Industrial Development
Organization and Global Green Growth Institute, https://www.unido.org/sites/default/files/2015-
05/GLOBAL_GREEN_GROWTH_REPORT_vol1_final_0.pdf
3. Pollin, Robert, Jeannette Wicks-Lim and Shouvik Chakraborty (2020) “Industrial Policy, Employment and Just
Transition,” Chapter 3 in America’s Zero Carbon Action Plan, Sustainable Development Solutions Network,
https://irp-cdn.multiscreensite.com/6f2c9f57/files/uploaded/zero-carbon-action-plan-ch-03.pdf
4. Pollin, Robert, Jeannette Wicks-Lim, Shouvik Chakraborty, and Tyler Hansen (2019) A Green Growth Program
for Colorado, Political Economy Research Institute, https://peri.umass.edu/publication/item/1168-a-green-
growth-program-for-colorado.
5. Pollin, Robert, Jeannette Wicks-Lim, Shouvik Chakraborty, Caitlin Kline, and Gregor Semieniuk (2021) A
Program for Economic Recovery and Clean Energy Transition in California, Political Economy Research
Institute, https://peri.umass.edu/economists/gregor123/item/1466-a-program-for-economic-recovery-and-
clean-energy-transition-in-california
6. Chamberlin, Sydney J., Ashlet Conrad-Saydah, Tanushree Biswas, and Charlotte K. Stanley (2020) Nature-based
Climate Solutions: A Roadmap to Accelerate Action in California, The Nature Conservancy,
https://www.nature.org/content/dam/tnc/nature/en/documents/TNC_Pathways_2020vf.pdf 7. Fuss, S., W.F. Lamb, M.W. Callaghan, J. Hilaire, F. Creutzig, T. Amann, & J.C. Minx (2018) Negative emissions—
Part 2: Costs, potentials and side effects. Environmental Research Letters, 13(6), 063002,
https://iopscience.iop.org/article/10.1088/1748-9326/aabf9f/meta
Oct. 11, 2022 Item #12 Page 301 of 560
263
7. Key Policy Considerations for the San Diego Region
Joseph Bettles, UC San Diego
Gordon C. McCord, UC San Diego
David G. Victor, UC San Diego
Emily Carlton, UC San Diego
Key Takeaways
● Reduction of greenhouse gas (GHG) emissions across the region requires that cities and
agencies coordinate their actions more closely. Yet many of the most impactful actions
are steeped in uncertainty around the best policy, technology, and implementation
strategies. Bridging this uncertainty will require goals and policies that incentivize active
learning and experiments to test diverse ideas in each sector, mechanisms to facilitate
collaborative assessment of these ideas by experts, and adjustment of policies in light of
new information about what works best.
● Each sector analyzed by the RDF has near-term actions that will be worthwhile
regardless of how longer-term uncertainty resolves itself. Local efforts should prioritize
these near-term “low-regret” policies as a starting point.
● Where the best solutions are not yet known, this chapter proposes a flexible, region-
wide governance structure that facilitates experimentation and learning. Organized into
a Regional Steering Committee, Sector Working Groups, and Front-Line Advisors, this
evolving structure can coordinate learning efforts across jurisdictions and adapt to
changing technological and political realities.
● Establishing such committees under a formal partnership mechanism, such as a Regional
Climate Action joint powers authority (JPA), could help boost their impact through
pooling resources, scaling strategic thinking, sustaining collaboration, and ultimately
encouraging policy coordination across jurisdictions.
● Given limited local leverage over many emitting activities, regional climate governance
institutions must directly engage with the State and federal governments to advocate
for policies and programs that support local decarbonization needs.
● For the San Diego region to have a measurable impact on global emissions it should seek
to generate followership among other regions and upscale durable innovations that can
be expanded and replicated. Because the San Diego region accounts for just 0.08% of
global emissions, regional actions that fail to inspire efforts elsewhere will be much less
impactful than those that diffuse more widely as models.
Oct. 11, 2022 Item #12 Page 302 of 560
264
7.1 Introduction
Along with the rest of the world, the governing bodies of the San Diego region – including 18
cities, public agencies, and the County of San Diego – face the unprecedented challenge of
decarbonization by midcentury or earlier. This must happen despite local governments’ limited
direct authority over many emitting activities and amid great uncertainty around changing
technologies, resources, climate impacts, and socio-political realities. Even as science and policy
lead to solutions in the rest of the world, many of which the Regional Decarbonization
Framework (RDF) proposes implementing over the near term, the region still must discover
whether and how those will work in the San Diego context. Beyond the near term, even the
best models cannot perfectly identify the best course of action today.
Given these uncertainties, the RDF is not a prescriptive roadmap to complete decarbonization.
Instead, it aims to initiate and inform an ongoing process of local experimentation to discover
what does and does not work here in the San Diego region. To that end, the RDF sets an
ambitious goal (net zero by 2045) to point climate-related activities in the right direction,
provides a framework for organizing action (by sector), and lays out near-term, least-cost
actions. Based on science and derived from what is working in other contexts, the RDF offers a
starting point for local policy efforts that must adapt over time in light of new information and
experience.
This chapter builds on the earlier chapters by outlining a strategy through which local
governments can adapt and shape their efforts over time in response to new information.
Successful deep decarbonization will require an institutional framework that systematically
rewards experimentation and facilitates learning by government officials, planning bodies, and
regulators as well as local industry stakeholders, civil society groups, and academics. Central to
this strategy is the idea that even as many near-term actions are known and must be pursued,
some of the most impactful actions remain shrouded in uncertainty today. The framework
offered here includes incentives that encourage experimentation around those new ideas.
Finally, as the San Diego region represents a tiny fraction of global emissions, this chapter offers
strategies for regional efforts to have a broader impact on climate policy in other regions of the
country and beyond. Ultimately, the measure of success for the RDF is not how exactly the
pathways laid out in the sector chapters are followed, but how quickly and systematically the
region's various actors can work together to implement, evaluate, and improve them in light of
learning and then how quickly the ideas about what works in San Diego are emulated more
widely.
Oct. 11, 2022 Item #12 Page 303 of 560
265
7.2 Achieving Deep Decarbonization across the San Diego Region: the Need for
more Experimentation, Collaboration, and Learning
7.2.1 The Local Region as an Agent of Change
Local governments are at the front lines of both climate change adaptation and mitigation
efforts.1–4 Especially with inadequate national and international action on climate change,
highly motivated local regions, such as cities and counties are stepping up as the leaders of
greenhouse gas (GHG) emissions reductions.5
While the motivations for action are powerful, making efforts to reduce GHG emissions across
the region requires a careful strategy that will not emerge on its own. Collective action is
needed because, often, no single local agency (or even a whole city) can solve problems by
acting alone. The strategy requires incentives to break away from old investment patterns that
will not achieve deep decarbonization – and incentives to experiment with new ones. The
strategy also requires engaging a broad set of actors – including government but also industry,
academics, and ground level workers – to implement and assess solutions and share learning
about what works and what does not.i,6
Within the San Diego region there are 18 cities, 17 tribal governments, and several agencies
and government offices relevant to decarbonization. Maximizing our efforts requires sustained
and meaningful collaboration, which poses challenges in such a fragmented and diverse region
that the rest of this chapter aims to address. Working as a region can achieve economies of
scale, as combining resources increases leverage and capacity.7,8 Sharing of expertise and
experience among neighboring cities – often facing very similar contexts of opportunities and
challenges – can allow for faster diffusion of successful innovations as well as more equitable
distribution of resources.9 For example, coordination between local governments in Southern
California and the State of California has led to an increasingly equitable distribution of EV
charging stations across census tracts with different income levels.10 Climate action in
geographically defined communities can lead to close relationships between government staff
that makes joint problem solving more effective, building trust that enhances open
deliberation.5
7.2.2 A Collective Shift from the Status Quo
The RDF lays out decarbonization pathways for each sector that require large investments and
rapid change. Table 7.1 provides an overview of key decarbonization actions, areas of
uncertainty, and County leverage points–actions the County has direct or significant influence
i This logic is sometimes called “experimentalist governance.” Cities in the San Diego Region can act as laboratories
for policy innovation that is standardized and entrenched over time. (Victor and Sabel 2022)
Oct. 11, 2022 Item #12 Page 304 of 560
266
over–from each of the four sectors: land use, buildings, transportation, electric sector. This
sector-by-sector approach to deep decarbonization is extremely important because the lesson
learned around the world is that detailed planning for new technologies, business practices,
and policy strategies is much more effective when the big problem of “climate change” is
broken down into smaller units – sectors – because the best solutions vary so markedly across
sectors.11
However, the slow pace of change in most sectors and jurisdictions worldwide so far illustrates
that rapidly moving away from the status quo remains risky, even when actors agree on the
threat of climate change and know many of the actions needed to mitigate it, thanks to
guidance from modeled pathways like those presented here. The risks are especially acute in
sectors where change could be highly disruptive or the right solutions or policies are still
unknown. Guidance from modeled pathways like the RDF helps remove some uncertainty and
reduce risk by laying out and signaling support for near term actions. Even so, for an established
business owner unsure how rules will evolve, which solutions will be most cost effective in their
particular context, or how consumers and investors will respond, it is difficult to justify
significant capital investment in major changes. Individual local leaders facing the same
uncertainties could similarly, and understandably, hesitate risking public backlash on major
changes as well.
Under these conditions, local leaders must step in to send a collective, clear, and credible signal
that the real risk is in doing nothing. This can be done in a variety of ways, both formal and
informal. For businesses, examples include the credible promise that regulations will tighten as
solutions become viable, or the threat of being shut out of the market. For local agencies,
signals come from the pressure of new rules from the State and growing public demand for
action. These “sticks” are most effective when paired with “carrots” that reward early movers,
such as public contracts that guarantee a market for local businesses that decarbonize or
individual-level incentives that increase demand for goods and services aligned with the needs
of a decarbonized future, such as the adoption of heat pumps, EVs, and building shell
improvements.
In the San Diego region, as in the rest of the world, the best types of incentives and the right
pace for implementing them varies by sector. Where the science around the best solutions
remains highly uncertain – for example, in land use, where gaps remain in the evidence around
exactly how much and how reliably natural climate solutions can sequester carbon – the best
sector strategy would emphasize experimentation and rapid learning so that goals and
incentives can be adjusted in line with new information. By contrast, in sectors like electricity
and light-duty transportation where confidence in the solutions is higher (at least over the short
term) but the feasibility of rapid adoption is uncertain, the best approaches would emphasize
Oct. 11, 2022 Item #12 Page 305 of 560
267
Table 7.1. Key emissions sources, key actions, areas of uncertainty, and areas of leverage identified per sector.
Land Use Buildings Transportation Electricity Generation
Key Emission
Sources
● Disturbance of intact
ecosystems (e.g., wildfire,
sea-level rise, development);
some agricultural practices.
● Residential and commercial water
heating and space heating/cooling;
process energy.
● Internal combustion engine
emissions from light- and
heavy-duty vehicles and
freight.
● Electricity generated from natural
gas power plants.
Key
Decarbonization
Actions
● Protect existing carbon pools
to avoid releasing stored sinks
of CO2, prioritizing intact,
native ecosystems.
● Manage existing ecosystems
to increase carbon
sequestration as well as to
mitigate wildfires and storm
surge damage through forest,
chaparral, and wetland
management/restoration.
● Promote “climate farming” to
change agricultural lands
from sources into sinks and to
manage agricultural methane
emissions.
● Increased adoption of
electrification of space and water
heating.
● Geographically targeted
electrification (e.g., in
neighborhood clusters).
● End expansion of the gas utility
system to lower the risk of
stranded assets.
● Building shell improvements to
reduce electric system peaks and
manage system costs.
● Improved data gathering is a low-
cost, foundational action for future
policy development.
● Reduce demand for travel.
● Shifting to EV for LDV, HDV,
and freight.
● Siting charging infrastructure.
● Multi-modal oriented
development where assets are
already present, as well as
investments in new transit
infrastructure.
● Accelerate replacement rates
● Engage with vulnerable
communities.
● The San Diego region has sufficient
solar and wind resource potential
to transition electricity to 100% of
the estimated demand with local
renewable resources, while the
Central Case from the overall
model retains firm power gas
infrastructure to keep costs low.
● Neighboring Imperial County has
significant solar and geothermal
beyond internal population
demands.
● CAISO estimates necessary
transmission network upgrades for
San Diego - Imperial - Baja - Arizona
to be $3.9 billion and will take
decades to complete.
Areas of Uncertainty ● There is a high degree of
uncertainty around the
benefits of reforestation and
afforestation.
● It is uncertain the degree to which natural climate
solutions are a reliable source
of negative emissions. ● Further there is uncertainty
as to the degree that climate change will have an impact.
● The long-term best extent of
electrification is uncertain (70%?
85%? 100%?), but not relevant for
near-term action.
● Uncertain performance/results from new policy levers (at local,
state, federal levels).
● Future cost, availability, and demand for low-carbon gas is
uncertain; this suggests it may need to be saved for sectors hardest to decarbonize.
● Alternative fuels.
● Resilience in the face of supply
disruptions.
● The political feasibility of
mandating shifts. ● The degree of flexible charging
and the feasibility of vehicle to
grid (V2G) systems.
● Ability to upgrade the capacity of
the transmission system to meet
demands.
● Social acceptability of large utility-
scale projects. ● Storage and firm power
● The degree to which Mexico will
provide a source of renewable electricity inputs. Oct. 11, 2022Item #12 Page 306 of 560
268
County Policy
Leverage
● Purchase land for permanent
conservation.
● Education/training on
increasing sequestration for
owners of privately owned
land.
● “Carbon farmer” certification
program that would train
farmers on how to increase
the sequestration on
farmland.
● Incentives for farmers and
landowners to adopt carbon
sequestration practices.
● Building energy use disclosure
policies that enable building
performance standards and/or
energy actions.
● Lead by example with public
buildings.
● Rental property performance
regulations.
● Customer service/resident
guidance/coaching.
● Technical assistance and
commercial guidance.
● Building energy codes/reach codes
(covering new construction and
major renovations) – should be
“electrification ready.”
● Reducing embodied carbon in
buildings through zoning or
building codes could complement
policies focused on operational
carbon.
● Leverage the existing Regional
Energy Network (REN) and
community choice aggregation
(CCA) platform to promote building electrification—including
outreach, engagement, and enrollment in building decarbonization initiatives.
● Use of various funding and finance mechanisms to promote building electrification. ● Building operator certification programs. ● Data gathering on the pace of decarbonization actions along with annual benchmarks for progress, and track/report against benchmarks.
● Align affordable housing with
employment centers.
● Roadway improvements for
biking/walking.
● Remove parking requirements.
● Charging infrastructure in
public ROW and building
improvements.
● Incentives for clean vehicle
purchase
● Pilot programs.
● Flexible charging and V2G pilot
projects with County fleets.
● Power purchase agreements
through SD Community Power
(CCA).
● Approve new projects that come
before the board and identify
public facilities and lands where
renewables can be sited.
● Work with private developers to
identify suitable sites for
renewable energy and engage with
local communities in the process.
Oct. 11, 2022Item #12 Page 307 of 560
269
deployment of known technologies while still learning about the next wave of technologies that
will be needed once the low-regrets options diminish.
In many cases, local agencies may lack the direct authority to implement incentives and
penalties to mobilize action. Thus, regional leaders will need to engage continually with outside
agencies, especially at the state level, to influence policy. This not only supports getting the
right policies to mobilize action in San Diego, but also generates action beyond the region. The
San Diego region accounts for a relatively small fraction of global emissions and thus must
advance local efforts with an eye to how they affect the rest of the world. Section 7.5 later in
the chapter provides greater detail on influencing policy outside the region.
Whether enacting local policies or influencing policies elsewhere, it is essential that the 18 cities
and other key agencies that serve the San Diego region show alignment around moving away
from the status quo. The three main sources of emissions in San Diego are light-duty vehicles
(37%), electricity (23%), and natural gas in buildings (8%).12 Each cross municipal boundaries
and therefore require geographically coherent policies. Even for emissions sources ascribed to a
specific geographic area (e.g., methane from solid waste), a patchwork of uneven penalties and
rewards risks generating confusion, increasing administrative burdens, pushing emissions into
certain geographic pockets of the region, and threatening equitable distribution of costs and
benefits. Finally, where regional agencies lack direct authority to implement incentives, a
united regional voice yields greater influence on state and federal policy than individual
agencies or cities.
While the RDF as a whole focuses on mitigating climate change through decarbonization, the
same logics outlined in this chapter – the need for collective action to mobilize a shift away
from the status quo, drive rapid learning about the best solutions, and engage with frontier
efforts in other jurisdictions – could yield a more effective regional strategy on climate change
adaptation as well. For example, coastal erosion, an adaptation problem currently managed
independently by each coastal city, could benefit from a region-wide strategy, such as for
coastal management projects.13
Achieving alignment on region-wide policies to mobilize action in each sector is a challenge,
especially given the large diversity of preferences and the sheer number of government entities
across the region. It will require bold leadership alongside new institutional mechanisms, some
of which are outlined in the remainder of this chapter. Yet this challenge also offers cause for
optimism, as the range of actors can aid decarbonization. Fragmentation within the region can
create an environment where highly-motivated or capable localities experiment, good ideas
spread quickly to other jurisdictions, and the likelihood of policy coordination across cities
increases.14 For example, the City of Chula Vista was the first city in the region to adopt a
Climate Action Plan (CAP) in 2000 after working with the UN program Local Governments for
Oct. 11, 2022 Item #12 Page 308 of 560
270
the Environment.15 In the years following, nearly all other cities adopted CAPs.16 Despite many
different contexts and interests across the region, pressure is mounting for serious responses to
the challenge of deep decarbonization.
7.2.3 The Need for Collaborative Learning
The complexity and urgency of the decarbonization challenge require – in addition to incentives
for action – active, collaborative learning by relevant local actors, including government,
industry, academics, and ground-level workers. This learning should pursue two critical goals.
First, local actors within each sector must learn how to adapt near-term “low-regret” policies
from other contexts to work here in San Diego. The RDF has identified the least-cost, currently
feasible actions to prioritize, given high confidence that they will be worthwhile regardless of
how uncertainties resolve. Successful implementation requires adapting technologies, policies,
programs, and incentives to suit the environmental, political, and economic contexts of the
region. Some elements of policies that encourage EV adoption in Del Mar likely will not work
the same in Dulzura, for example.
Second, local actors must engage each other and the wider world in search of solutions where
the best approaches remain unclear. To what degree and how rapidly will electrification of
industrial loads take place? What will be the role of low- and zero-carbon liquid fuels for
transportation, or must we electrify all transportation to decarbonize? How reliable are intact
ecosystems in the region as a method for absorbing carbon from the atmosphere – in effect, a
source of negative emissions? While regional scale investments in technological innovation are
unlikely to have dramatic impacts on technological readiness, San Diego's technology-focused
industrial culture and multiple university communities make it an ideal testbed for pilot and
demonstration projects. For example, vehicle to grid (V2G) systems are an emerging technology
that can reduce the need for battery storage of renewable electricity. UC San Diego is home to
a California Energy Commission pilot project in partnership with local startup Nuuve to study
V2G implementation. Cities within San Diego could achieve greater innovation in the
implementation of V2G systems through pilot projects at the municipal scale.
Systematic learning under conditions of uncertainty requires some form of institutional
structure and mechanisms that encourage local actors to try new ideas, then bring together
experts from relevant governments, industry, and academia, to systematically assess how they
work, problem-solve where necessary, and share that learning with others.6 The key is to
establish ongoing processes of providing information about experiments along with review,
where mutual learning and discussion with feedback from those on the front line inform
changes to goals, policy, and planning. An institutional framework that does this successfully
must be flexible enough to respond to changing conditions and lessons learned, but also stable
Oct. 11, 2022 Item #12 Page 309 of 560
271
and collaborative enough to create sustained relationships that increase the likelihood that
policy coordination across jurisdictions–such as the tightening of regulations—will follow.
7.2.4 The Regional Players in San Diego
Building an institutional framework that achieves the iterative, problem-oriented collaboration
described above and maintains it over the long term is difficult, especially in a region as diverse
as San Diego. This challenge results in dozens of groups across the region that nominally
collaborate but often focus on their own narrow range of opinions and interests. Here, we
propose a framework that organizes individuals not by opinion or interest, but by area of
expertise, ensuring that solutions are reviewed by peers who do not necessarily agree but are
all knowledgeable enough to push the search forward.
Fortunately, San Diego already has key government entities well-positioned to act as leaders
and champions for this effort. The largest regional agency, and most relevant for
decarbonization, is the region’s Metropolitan Planning Organization (MPO), the San Diego
Association of Governments (SANDAG). The MPO is designed for regional coordination around
transportation and land use planning. SANDAG already employs iterative planning based on
some ground-level feedback: the 2050 Regional Transportation Plan produced by SANDAG
relies on data from key local actors, extensive public input, and regular progress reports to
inform ongoing GHG reducing land use and transportation planning.19 Additionally, under the
Regional Planning Committee, SANDAG has established several working groups on a variety of
relevant policy areas, which may offer another starting point for increasing collaboration on
GHG reduction. As an established coordinating body in the region with land use and
transportation authority, SANDAG will play an important role in any new governing authority on
decarbonization and may be a natural host. However, successful peer review will require
bringing together experts to perform analysis beyond SANDAG’s typical scope of activities.
The government of San Diego County is another natural coordinating body in the San Diego
region. The County operates in a privileged position in climate governance with a combination
of proximity to the local context and connection to state and federal resources.20 The governing
body, the County Board of Supervisors, represents all areas of the region and holds land use
planning authority in the unincorporated areas of the County. In addition, the County receives
federal and state funds for health, infrastructure, and more recently, economic stimulus.21 The
distinct advantages of proximity to constituents as well as control of state and federal resources
provide the opportunity for coordinating efforts by the County to have a meaningful impact on
regional GHG emissions.
The County has several areas of direct influence in decarbonization as well as indirect influence
as a regional governing body with representation from all parts of the region. The recent
Oct. 11, 2022 Item #12 Page 310 of 560
272
decision to join San Diego Community Power (SDCP) provides the County with influence in the
development and procurement of electricity for the region.22 In addition, the County is a voting
member of several important agencies and boards with authority over transit, water, air
quality, and the airport. Figure 7.1 shows the County’s role in decarbonization in the regional
context. While it lacks direct authority over cities, county-wide representation positions the
County as another important leader of decarbonization efforts in the region.
The benefit of having local government entities like SANDAG or the County hosting a broader
collaborative effort is the power to enter into formal agreements with other agencies or
jurisdictions, both in and outside the region, via Memoranda of Understanding (MOU) or Joint
Powers Authorities (JPA). In San Diego, such partnerships have already begun to form around
some climate-related topics: community choice aggregators throughout the region (including
SDCP) benefit from a JPA to coordinate on the development and procurement of renewable
energy.23
Formalized partnerships can increase leverage, including by allowing the region to apply for
state and federal funding for major projects. They also create institutional stability that could
help sustain collaboration and thus encourage policy coordination across jurisdictions. Defining
the authority for a Regional Climate Action JPA and determining which funding streams would
get pooled, how different stakeholders would be represented, and how decision-making would
happen all require further study. However, this framework would help the region’s various
jurisdictions move beyond nominal collaboration and self-interested action toward regional-
scale strategic thinking and decision-making on decarbonization. Importantly, the JPA
framework—if successful—can be replicated in regions across the country.
Outside of government, San Diego has several private and academic networks, including the
San Diego Regional Climate Collaborative, which coordinate efforts on climate-related
initiatives. These existing networks of local expertise should be involved in review and
assessment of solutions and policies. Individuals from environmental justice and advocacy
groups who possess relevant, sector-specific expertise should also be included.
Oct. 11, 2022 Item #12 Page 311 of 560
273
Figure 7.1. Role of the County of San Diego in the regional decarbonization context.
7.3 Case Studies for Regional Action
Within and beyond the San Diego region are many examples of regional efforts to adopt and
learn from climate solutions. This section outlines seven case studies that highlight institutional
structures that achieved the kinds of functions needed to propel rapid, deep decarbonization,
outlined earlier in this chapter. Those functions include setting ambitious but adjustable goals,
breaking down complex problems into smaller and more focused learning units (usually
sectors), providing strong incentives to deviate from the status quo despite uncertainty,
investing in experiments that test new solutions, systematically reviewing outcomes to assess
what works and what does not, and sharing learnings within and beyond the region.
The case studies that follow illustrate ways that communities have organized themselves to
perform these functions as they grapple with what to do in their context; however, no single
case study illustrates all such functions at once. The following sections of this chapter, 7.4 and
7.5, propose an institutional framework and strategy for balancing these functions.
7.3.1 Buildings: Learning from Mixed Approaches in the San Diego region
In February 2019, the City of Carlsbad was the first in the region to implement building
electrification by mandating electric or solar water heaters for all new construction.24 Encinitas
took a different approach in 2021 when they banned natural gas connections for all new
Oct. 11, 2022 Item #12 Page 312 of 560
274
construction, including space heaters, fireplaces, and stoves.25 These are examples of policies
that disrupt the status quo, creating the conditions for change. Policies creating pressure to
move away from gas are emerging at both the local and state level. Furthermore, they are
yielding results: San Diego Gas and Electric (SDG&E) is actively moving to address carbon
emissions from existing natural gas infrastructure through pilots on blending green hydrogen
that could lower the carbon intensity of gas within buildings.26 While these are good examples
of how policy can create incentives for technological innovation and experimentation, it is still
unknown whether these specific policy and technological solutions are the “right” ones. For
example, even where bans on gas hookups are politically popular and buildings are increasingly
electrified, the aggregate impact of such bans may erode the larger value across the whole
region of a gas pipeline network that may later prove useful distributing decarbonized gas to
boost energy service reliability and resilience. As these experiments in policy and technology
unfold, we must systematically assess them to learn the right lessons and correctly adjust
strategies to decarbonize buildings across the region.
7.3.2 Land Use: State and Federal Collaboration in the San Diego Context for Conservation
and Natural Climate Solutions
The Multiple Species Conservation Program (MSCP) is a cooperative effort between several
jurisdictions within the San Diego region, the California Department of Fish and Wildlife, and
the U.S. Fish and Wildlife Service to streamline the acquisition and management of land for
wildlife refuges in the unincorporated areas of San Diego County.27, 28 The MSCP is a
conservation framework that balances state and federal habitat preservation targets for
multiple species with local economic development goals. Ongoing collaboration and
information sharing between local, state, and federal governments and with private
landowners to provide ecosystem services, recreational opportunities, and habitat conservation
for the region is a unique example of multi-actor collaboration that tailors conservation
solutions to the local context. The result is active decision-making that can have significant
natural climate solutions benefits, despite strong competing interests that can lead to
gridlock.29
7.3.3 Transportation: San Diego Agencies and Industry Align to Plan for Electric Vehicle
Infrastructure
An existing collaborative institution in San Diego, Accelerate to Zero Emissions, brings together
governments, agencies, and industry around the development of a strategy to achieve zero
emissions in transportation.30 The structure shown in Figure 7.2 includes ground-level industry
groups that work alongside government officials to oversee and advise the creation of a
strategic planning process.
Oct. 11, 2022 Item #12 Page 313 of 560
275
This group has already begun important work to assess opportunities and barriers to EV
adoption in the San Diego region. A July 2021 Gap Analysis based on both quantitative data and
interviews with frontline EV ecosystem stakeholders identifies barriers to EV adoption in the
San Diego context ranging from vehicle supply and charging infrastructure availability to end-
user information gaps and workforce inadequacy. It also includes purposeful attention to
disadvantaged communities.31 This type of collaborative stock-taking and assessment is vital in
each sector for identifying effective, equitable strategies. New mechanisms should encourage
policy follow-through from individual jurisdictions to expand successful strategies across the
region while adjusting or abandoning other tactics.
Figure 7.2 Organizational structure of Accelerate to Zero Emissions
7.3.4 Energy Modeling: Policy Informed by Pathways in Massachusetts
Massachusetts Governor Charlie Baker through the Executive Office of Energy and
Environmental Affairs (EEA) commissioned a Decarbonization Roadmap Study with a
Oct. 11, 2022 Item #12 Page 314 of 560
276
“comprehensive understanding of the necessary strategies and transitions in the near- and
long-term to achieve Net-Zero by 2050 using best- available science and research
methodology.”32 The roadmap was created as the scientific foundation for GHG targets and the
state’s policy action plan, signaling the State’s ambition and guiding the level of disruption and
experimentation needed. In addition to the roadmap report, the Office oversaw the creation of
an institutional structure that included an implementation advisory committee with
stakeholders and a technical steering committee with experts across fields. The evidence-based
models developed for the Roadmap became a coordinating mechanism that established
ambitious collective climate goals and anchored efforts around technically feasible solutions.
7.3.5 Climate Network: Bi-directional Governance in German Climate Change Management
In a study of cities as leaders of climate policy in the EU, Kern identifies several lessons that
could prove useful to San Diego.5 She advocates an “embedded upscaling” approach in which
decision-making takes place within cities under the guidance of a larger network. Kern
highlights the case study of the German Climate Change Management (KPL) in which German
states create goals for decarbonization and municipalities decide on implementation strategies
feasible within their context. States provide funding based on adherence to the goals as well as
the financial need of the municipality. Kern notes that a co-benefit of this approach is that city
staff become experts on decarbonization which has led to a knowledge-sharing network across
cities. This case study exemplifies an institutional governance system that incentivizes
experimentation and facilitates local learning. It also demonstrates the importance of direct
engagement between local and state governments, both for supporting the differing needs of
municipalities as well as upscaling the efforts of those municipalities through knowledge
sharing.
7.3.6 Regional Coordination and Experimentation: Orlando and Central Florida
In Central Florida, a newly created council of governments work together to tackle
sustainability and resilience through a regional decarbonization strategy: The East Central
Florida Regional Resilience Collaborative (ECFR2C). This collaborative, started in 2018, is built
upon three pillars: People (health and equity), Places (built infrastructure and natural
environment), and Prosperity (economic resilience). Led by the East Central Florida Regional
Planning Council, this initiative convenes 37 partners (including counties, cities, towns, and
public agencies) with the goal of reducing their carbon footprint, risks, and vulnerabilities, and
increasing sustainability efforts on a region-wide level.33 The steering committee has also
drafted a Memorandum of Understanding which formally recognizes partner local governments
and agencies within 8 counties and 78 cities. This MOU calls on stakeholders to commit to
regional cooperation, develop regional resilience action plans, align decisions with a shared
legislative strategy, engage the community, and participate in an annual summit.34 This
Oct. 11, 2022 Item #12 Page 315 of 560
277
collaborative engagement between different governments and agencies demonstrates the
formation of a united regional voice and emphasizes the importance of aligning on policies
which can then mobilize action.
The City of Orlando is also implementing local government initiatives that connect with global
commitments to reach net zero GHG emissions by 2050.35 Some such initiatives signal the
direction and ambition of change; for example, their 2017 resolution to meet 100% of city-wide
electricity consumption demand by 2050 with renewables and their push to provide renewable
energy for all municipal operations by 2030. Other initiatives target implementation, leveraging
collaboration between municipal agencies, private stakeholders, and other experts to
experiment with new technologies. One example is the robust experimental ecosystem that has
emerged around floating solar arrays. Work on floating solar began locally with just two small
pilot projects, the first in 2016 (5000 watts floated by engineering students at the University of
Central Florida (UCF)) and the second in 2017 (32 kW installed by OUC at one of its own
facilities, the first in the southeast USA to be grid connected). Today, over 1 MW of floating
solar projects are installed at stormwater retention ponds around the city, including the
Orlando International Airport, municipal wastewater treatment facilities, UCF, and Universal
Studios theme park. Front line workers at local organizations, such as OUC, the City of Orlando,
private energy developers, UCF, and project site owners, are undertaking much of the work to
deploy and systematically assess these projects. The research effort is also supported externally
by grants from the US Department of Energy, research collaborations with the National
Renewable Energy Laboratory and UC Davis, and a partnership with a multinational engineering
company. This initiative exemplifies three aspects of successful experimentation: first, active
collaboration between academia, private industry, and government to deploy projects; second,
systematic review and assessment of technologies after deployment; and third, engagement
with external actors to spread learning beyond the region.
7.3.7 Coordination through a Regional Council: Washington, D.C.
The Metropolitan Washington Council of Governments (COG) is one of the nation’s leading
groups in addressing climate change on a regional level.36 The COG is an association of 300
elected officials from local and state governments, as well as members of the U.S. Congress that
collaborate to address major regional issues of climate and energy action in the District of
Columbia, Maryland, and Northern Virginia. The COG set initial goals for sustainable growth –
including GHG emissions reductions – in its 2012 Region Forward vision and continues to assess
progress and update those goals accordingly. With this vision as a guide, COG lays out plans and
priorities for regional collective action in Climate and Energy Action Plans, which are reviewed
and adapted over time (most recently in the 2030 Plan). The climate action section of the plan –
known as the regional mitigation strategy – is broken down roughly by sector: planning, equity,
Oct. 11, 2022 Item #12 Page 316 of 560
278
clean electricity, buildings, zero emission vehicles, zero waste, mode shift and travel behavior,
and sequestration.
Implementation is led by COG’s Climate, Energy and Environment Policy Committee (CEEPC),
which consists of representatives from COG’s member local governments, state agencies and
legislatures, the Air and Climate Public Advisory Committee, regional and federal agencies, and
electric and gas utilities. This committee pools learning from a collection of subcommittees,
technical working groups, and partners. This informs the COG board on a variety of things,
including setting annual legislative priorities for climate and energy and monitoring advances in
the technical feasibility of promising solutions. At the same time, the committee supports local
area governments as they collaborate to try solutions by providing capacity building, training,
data and tools, research, planning, policy/program development, project feasibility
assessments, advocacy, and cooperative procurement to communities. The committee and its
subcommittees also facilitate upscaling through diffusion of knowledge across jurisdictions. For
example, they host one regular forum for problem-solving and lesson-sharing around solid
waste management and another that brings together sectoral actors across jurisdictions and
institutions to unify approaches to managing regional forest canopy.
Like the overarching vision and goals, this structure is flexible and routinely adapted. New ad-
hoc working groups are created to address needs and advance initiatives as they arise and then
disbanded when unnecessary. One program, the Greater Washington Region Clean Cities
Coalition (GWRCCC), was originally established within the COG to work with vehicle fleets, fuel
providers, and community leaders and stakeholders toward the goal of reducing gasoline
consumption in transportation. Over time, it has evolved into a separate private-public
partnership that continues to collaborate closely with COG on zero emission vehicle adoption.
Overall, the COG approach has resulted in considerable progress: in 2012, the region surpassed
its goal of a 10% GHG emissions reduction below business-as-usual projections and by 2018 had
reduced region-wide emissions by 13% from 2005 levels, mainly through deployment of low
carbon distributed generation resources, cleaner cars, and fewer vehicle miles traveled.
7.3.8 Effective Sectoral Problem-Solving through Local Partnerships: Denver
In Denver, models of effective problem-solving have emerged on a local level through focusing
on areas offering the most impact, such as large buildings, transportation, and power
generation. This case study illustrates that when attempting to address the larger issue of
reducing GHG emissions, breaking it into smaller units (in this case, prioritizing key sectors that
will have the largest impact) will allow for more effective experimentation and collaborative
learning by relevant actors within each sector. Denver’s 80 x 50 Climate Action Plan (reducing
GHG emissions 80% below 2005 levels by 2050), released in 2018, engaged technical experts
Oct. 11, 2022 Item #12 Page 317 of 560
279
and community stakeholders to emphasize measurable and equitable carbon reductions.37 This
plan’s stakeholder process included two key groups: the Technical Advisory committee that
created systems-based GHG reduction approaches within four sectors (mobile supply, mobile
demand, stationary supply, and stationary demand) and the Task Force that integrated these
strategies into a larger framework.
Through this Climate Action Plan, Denver aims to strengthen building codes for new buildings,
target homes for efficiency upgrades and pair them with strategies like EV, solar, storage and
fuel switching, and arrange group discounts for energy upgrades via partnerships with local and
national organizations. Denver also committed to continuing its Energize Denver program
which requires buildings greater than 25,000 square feet to report their annual energy use
publicly, adopted the 2018 IECC to ensure stronger building codes for new construction, and
actively develops tools like stretch codes and green lease programs to provide incentives for
high-performing, LEED, and net-zero buildings. In efforts to decarbonize the electricity grid,
Denver has partnered with utility Xcel Energy, exploring a Certified Grid Mix approach to add
renewable energy on new construction buildings, residential rooftops, and community solar
gardens, allow isolated districts and microgrids, increase energy storage and expand renewable
choice programs and incentives. Within the transportation sector, Denver is advocating for
Colorado to adopt Clean Car Standards (including the Zero Emission Vehicle standard), partner
with car share companies to provide access to EVs and subsidize memberships to allow better
access for low-income people, support EV workplace charging programs, and support
electrification of delivery trucks – all with a target of making 40% vehicle registrations in the city
electric vehicles by 2030.
7.3.9 Coordinated Partnerships of Local Leaders: Kansas City
Kansas City has a long history of implementing sustainability initiatives to promote economic,
social, and environmental benefits, and most recently employed a collaborative regional
approach in its 2021 CAP.38 This CAP, which serves 10 counties, and 123 municipalities in the
states of Kansas and Missouri comprises a team of over 130 local and state elected leaders,
community members, and stakeholders. Spearheading this group is both Climate Action KC, a
nonprofit coalition of local leaders from government, nonprofit, public and corporate
organizations focused on reducing emissions and improving quality of life, and the Mid-America
Regional Council, a nonprofit association of city and county governments and the metropolitan
planning organization for Kansas City. Their first regional climate plan establishes goals and
strategies across nine sectors: collaboration and leadership, transportation, energy generation,
finance & innovation, urban greening, healthy & resilient homes and buildings, food systems,
industry & resource management, and community resilience. Since the types of incentives,
pace of technological deployment, and levels of uncertainty vary across sectors, breaking down
Oct. 11, 2022 Item #12 Page 318 of 560
280
GHG reduction plans into distinct components helps ensure successful experimentation and the
creation of opportunities for local actors to take appropriate action.
For each sector, the plan identifies a set of co-benefits such as health & wellbeing, accessibility,
cost savings, or green job development, as well as linkages with other sections of the plan,
thereby illustrating the relevant connections and positive outcomes that information sharing
and coordinated partnerships can achieve. Some of the policy recommendations made for local
government across the different sectors include adopting solar-ready and energy-
benchmarking ordinances, adopting building performance requirements and IECC 2021, linking
economic incentives to building performance, revising zoning codes to allow for accessory
dwelling units and create transit-supportive environments, and include green infrastructure in
capital improvement and asset management plans.
None of these case studies can be transplanted whole into San Diego, but each offers important
lessons for San Diego’s decarbonization approach. From Orlando and Washington D.C.’s
examples of coordination amongst local actors to Denver and Kansas City’s approaches of
breaking down larger GHG reduction goals into manageable components to best identify
sector-specific solutions, these regional case studies represent real-world examples to learn
from.
7.4 Institutional Structure Built for Learning and Adaptation
The RDF has laid out a science-based course of action for decarbonizing the San Diego region by
sector, starting with measures that are “low regret” – options with the lowest costs, highest
technical feasibility, and most familiarity. However, the strategy must look beyond these first
priorities to the time when risks and potential performance of technologies and policy
interventions become more uncertain, and where local idiosyncrasies may have a big impact on
deployment as technologies and conditions evolve constantly.39 For example, ample evidence
demonstrates that EVs are the lowest cost way to decarbonize most light duty transportation,
whereas significant uncertainty remains around the best technology, policies, and operation of
EV charging to balance electricity loads on a grid reliant on solar energy. Beyond uncertainties
identified in the RDF are countless unknowns due to environmental, technological, social,
economic, and political shocks, acutely illustrated by the COVID-19 pandemic. In this dynamic
environment, it is impossible to know, today, exactly the best course of action for implementing
sectoral transitions locally, especially over the mid- to long-term. Rather than abandon
forecasts altogether, we find that the common aphorism, “all models are wrong, but some are
useful” is an appropriate perspective when thinking about regional decarbonization models.
Oct. 11, 2022 Item #12 Page 319 of 560
281
To bridge the uncertainty and enable region-wide decarbonization, government entities across
the region must collaborate to encourage the production of new knowledge about how to
decarbonize by investing in experiments. For example, rather than deciding ex ante on a single
solution for managing regional EV charging, or worse, doing nothing due to uncertainty, San
Diego can encourage investment in pilot projects across various municipalities, similar to the
V2G pilot at UC San Diego. Results from pilot programs can inform policy for the remaining
cities and contribute valuable knowledge to an important global challenge for decarbonization.
Making this kind of local learning systematic requires a regional governance structure that can
respond to the needs of those on the front lines as well as evolving technological and political
realities.
This section outlines key elements of such a structure. It draws on the findings from each of the
four RDF sectors, the broad strategies for local learning described in section 7.2 and illustrated
in 7.3, and core themes from a series of focus groups held locally as part of the RDF process.
7.4.1 Local Focus Group Feedback on Regional Climate Governancei
On the week of August 23rd, 2021, focus group sessions were held on the topics of buildings,
energy, transportation, and land use. The feedback sessions lasted approximately ninety
minutes and included stakeholders from industry, civil society, and academia. The final question
posed to all focus groups solicited feedback on an institutional framework to support
implementation: “Considering the range of stakeholders in this sector -- including public
agencies, advocates, energy providers, and others -- what would a collaborative effort look like
to create and implement the framework?” To identify key themes across focus groups, the
Figure 7.3 shows aggregated responses, summarized into three key actions: 1) establish goals,
2) organize players, and 3) engage and inform. These recommendations, which broadly align
with and support the process of local adaptation and learning described earlier in the chapter,
are integrated into the proposals for regional decarbonization governance that follow.
i More details on the focus groups are provided on the County of San Diego’s Integrated Regional Decarbonization
Framework website: https://www.sandiegocounty.gov/content/sdc/sustainability/regional-decarbonization.html .
Oct. 11, 2022 Item #12 Page 320 of 560
282
Figure 7.3 Aggregated Focus Groups’ Responses used to develop recommendations for regional governance on How to Implement the RDF. Oct. 11, 2022Item #12 Page 321 of 560
283
7.4.2 A Framework for Regional Decarbonization Governance
Figure 7.4 outlines recommendations for organization, incentives, and mechanisms as a starting
point for regional governance, followed by further discussion of each component. Importantly, in
addition to regional collaboration among the governments in San Diego, any new institution must
also coordinate with the region’s 18 Tribal Nations. Bi-national coordination between any new
institution and Tribal governments will be important for knowledge sharing and achieving shared
goals. The Regional Tribal Summits between SANDAG and Tribal governments offer a useful model
for this coordination.40
Regional Steering Committee: As the core governing body of the regional decarbonization effort,
the Steering Committee comprises members in government, industry, academia, and civil society.
This body oversees the overall strategic planning of the network and the establishment and
adjustment of shared goals and priorities. The Steering Committee would be a stock-taking body,
supporting learning by periodically assessing and codifying lessons from technical committees and
pooling knowledge about costs, benefits, and effectiveness of different actions.6 Based on these
lessons, the Committee would work with Sector Working Groups to identify goals and rules that
require tightening or loosening and incentives that may be effective, and advise appropriate
jurisdictions and agencies at the local, state, and federal levels to update or implement
accordingly. As the key oversight body, the Committee would also create Sector Working Groups,
organize subgroups (for example, on heavy duty vehicles or waste), and adjust representation in
such groups or governance processes based on feedback and deliberation.
Sector Working Groups: Starting with the four key sectors, the Working Groups would be technical
committees composed of sector experts from industry, academia, and government. These Groups
would facilitate and support peer review, through which front-line workers implementing
emissions reduction solutions around the region would come together to compare experimental
results and codify what they learn as best practices.6 The Groups would also look for innovations
and lessons from outside San Diego that could usefully be incorporated in this region. If funding
opportunities for pilot programs and investment funds become available, the Sector Working
Groups could decide on the beneficiaries and oversee implementation. Working groups in
SANDAG may serve as existing bodies suitable to this role.
Front-Line Advisors: The advisors are public and private players in the region actively
implementing decarbonization measures with the support of Sector Working Groups. These could
include, for example, a bureaucrat with firsthand knowledge of an emissions reduction program,
an employee of a company trying a new decarbonization strategy, or a specialist with specific
knowledge of a strategy or its effects. In the event of available funding for pilot programs, advisors
could propose projects while also providing feedback on outcomes. Especially motivated advisors
could serve as members of Sector Working Groups, using their experiences to inform policy and
peer review.
Oct. 11, 2022 Item #12 Page 322 of 560
284
Figure 7.4 Proposed Regional Governance of Decarbonization. Oct. 11, 2022Item #12 Page 323 of 560
285
7.4.3 Conference of Governments
Recognizing climate leaders and increasing awareness of successful policy interventions are
both key.5,20,41 A San Diego Conference of Governments (COG), modeled on the international
Conference of Parties, can increase the visibility of the RDF policy agenda, highlight lessons
learned from ground-level experiments, facilitate regional coordination, and engage
stakeholders.42 The proposed conference can convene local stakeholders to achieve region-
wide commitments on decarbonization and both encourage and facilitate the alignment of
Climate Action Plans across jurisdictions in the region. While the conference could take place
annually, it might follow the international COP model in which every fifth year there is a larger
conference that aligns with the release of a new scientific report. Beyond annual meetings, the
conference can catalyze clear, open, and continuous communication across governments and
agencies as well as with local stakeholders.
7.4.4 From Sectoral Pathways to an Institutional Structure for Decarbonization
Figure 7.5 shows the full process that builds on modeled pathways from the RDF with an
institutional structure that enables evolving governance and an annual COG to promote
innovative and lasting solutions for decarbonization.
Figure 7.5 An illustration of the full process from RDF to an institutional structure.
Oct. 11, 2022 Item #12 Page 324 of 560
286
7.5 Creating Followership: Acting at Home but Impacting Outside the Region
Successful decarbonization in the San Diego region requires external engagement. While local
governments are on the front lines of decarbonization, they are limited in statutory and
budgetary authority. The governments in the San Diego region should identify and actively
advocate key policies and programs to state and federal lawmakers to motivate actions and
build capacity for decarbonization at the local level. Benefits of such engagement go beyond
regional decarbonization.
Regional engagement with external efforts to push the frontier of science can generate climate
impact outside the region as well as direct reductions in local emissions. There are also
economic co-benefits of such engagement: opportunities to attract outside resources – such as
innovation grants – and attention from state and federal policymakers, with potential spillover
effects on the development of local businesses. For example, in the recent $15 billion climate
packagei signed by Governor Newsom in September 2021, $20 million is dedicated for
“Regional Climate Collaboratives”, which are community-driven organizations that partner with
public agencies.44 Senate Bill 1072ii will add to existing funding. These are important
developments to track for potential state resources to fund climate initiatives in the San Diego
region.
While the RDF has mostly focused on eliminating GHG emissions within San Diego County, the
region’s contribution to global carbon emissions is .08%, a proportion that will only decrease as
efforts to decarbonize continue and emissions in other regions rise. The pre-pandemic carbon
dioxide equivalent emissions from the San Diego region were approximately 35 million metric
tons (MMTCO₂e).12 Pre-pandemic emissions were roughly 425 MMTCO₂e in California,45 6,558
MMTCO₂e in the US,46 and 43,100 MMTCO₂e globally.47 Therefore, for the San Diego region to
have a meaningful impact on atmospheric carbon, it must not only demonstrate and adapt
frontier innovations – many developed outside the region – to generate local benefits, but also
share learnings with other regions so that they may follow. If the San Diego region focuses from
the start on diffusion of technologies and policies to other regions, it can lead and generate
followership among the many other regions struggling with similar challenges in the effort to
decarbonize.
We outline three mechanisms for generating followership. The San Diego region can be active
in state-level networks (see section 7.5.1 below). Second, the region can explicitly promote
upscaling beyond the region--through political entrepreneurs and the courts (7.5.2). Third,
i Governor Newsom, 2021: https://www.gov.ca.gov/2021/09/23/governor-newsom-signs-climate-action-bills-
outlines-historic-15-billion-package-to-tackle-the-climate-crisis-and-protect-vulnerable-communities/
ii SB 1072, 2018: https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180SB1072
Oct. 11, 2022 Item #12 Page 325 of 560
287
successful models developed here can be emulated when proven cost-effective and politically
sustainable.
7.5.1 A Forum for State Engagement
State leaders in California have increasingly recognized the need for more coordination within
regions and between the state and regions on climate governance. In 2021 the California State
Legislature considered Assembly Bill 897.i The proposed legislation would have created
networks of local governments overseen by the Governor’s Office of Planning and Research
eligible for funding for both climate change mitigation and adaptation. While the bill did not
pass, a fresh proposal for such networks – AB 1640ii – would do the same thing, though with a
singular focus on climate change mitigation. The lead author of this proposal, which has moved
through the Assembly and Senate topic committee and awaits Senate Appropriations, is San
Diego’s own Assemblymember Chris Ward. If and when San Diego follows through with the
creation of a cross-jurisdictional climate governance institutional arrangement – such as the
proposed Regional Steering Committee – this proposal would offer a ready-made avenue for
seeking funding and exchanging information about what works and what does not with the
state and other regions.
7.5.2 Mechanisms for Upscaling
Upscaling14 can be vertical (higher levels of governance) or horizontal (across peer regions).5 In
table 7.2, we provide key pillars and policies, drawn from Williams et al.48 and the US Zero
Carbon Action Plan3 that can guide policymakers’ efforts to influence state and federal level
policy. For a more detailed discussion of state-level policies for decarbonization, see the Local
Policy Opportunity Analysis Chapter of the RDF. Peer-reviewed literature identifies several
mechanisms, summarized in Figure 7.6, that can provide guidance for the San Diego region to
influence action beyond its borders.
● Political Entrepreneurship: Local leaders seeking to shape policies at a higher political
level or beyond the borders of their jurisdiction can facilitate upscaling.14,20,41,49 In the
San Diego context, providing a platform for local political entrepreneurs through the
COG may incentivize action on climate. Leaders in the San Diego Region can also take
advantage of opportunities for leadership roles in existing collaborations and structures
at the state, federal, and international levels. As an example, the San Diego region’s
leadership on the California Air Resources Board provides a platform for innovative
programs that can influence state policy.
● Policy Entrenchment: According to Bernstein and Hoffman, entrenchment of climate
policy can lead to catalytic impact beyond the local level.50 They identify norm changing,
i AB 897l, 2021: https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202120220AB897
ii AB 1640, 2022: https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202120220AB1640
Oct. 11, 2022 Item #12 Page 326 of 560
288
capacity building, and coalitions as the key mechanisms to achieve entrenchment. In a
case study of Palo Alto, California, Anderton and Setzeridentify local governance actions
to achieve entrenchment: 1) legislative mandates that are enforceable in courts, 2)
platforms to promote reforms, and 3) long-term visions.20 These key mechanisms
ensure the durability of local policies and allow for broader impact that can be
embedded into regional governance structures.
● Incentivize Competition: Competition among local jurisdictions can provide incentives
for innovation that lead to the emergence of scalable policies and technologies useful
elsewhere.14 In the San Diego region, pilot funding can amplify incentives for action and
innovation by jurisdictions.
In addition to mechanisms identified here, Chapter 9: San Diego as a Model provides further
insight on how the processes created through the creation of the RDF can serve as a model in
other regions.
Figure 7.6 Mechanisms for vertical and horizontal upscaling of local policies. Adapted from Kern (2019).
Oct. 11, 2022 Item #12 Page 327 of 560
289
Table 7.2 Key State and Federal Policies Critical to Decarbonization at the Local Level
Decarbonization Strategy State and Federal Policies
Electricity Decarbonization. In the
near term, the falling costs of wind,
solar, and storage technologies make
renewables an important strategy
for decarbonizing the electric sector.
● Clean energy: Enact renewable energy standards or carbon pricing to incentivize renewables development
● Energy storage: Require sufficient storage capacity and duration to ensure grid reliability
● Offshore wind: Accelerate leasing development of offshore wind areas
● Oil and gas moratorium: Establish a moratorium on all further on and offshore oil and gas exploration
● Research, develop, demonstrate, and deploy: Incentivize innovating and adopting new technologies.
● Expansion of the grid: Increased coordination on transmission upgrades and expansion among grid-connected states
and federal agencies
Energy Efficiency and Conservation.
Increasing energy efficiency and
conservation mitigates the
increasing demand for electricity
generation. Additionally, efficiency
can lower costs for governments and
ratepayers.
● Efficiency standards: Broaden and tighten standards across a wider range of end uses
● Efficient transport: Financial support for transit infrastructure and allow for greater regulation of vehicles
● Remote work: Support remote work through broadband expansion and incentives
● Aircraft: Incentivize low carbon aircraft fuel and invest in research of new technologies
● Dietary guidelines: Expand dietary guidelines and food product information requirements to include recommended
dietary carbon footprint
● Food waste: Incentivize the reduction of household and post-harvest food waste
Electrification of Buildings and
Transport. Electrification is an
essential strategy to achieve
decarbonization by mid-century
while keeping costs relatively low.
● Clean Air Act: Tighten GHG emissions standards through the Clean Air Act
● EV charging: Expand EV charging station networks
● Biofuels: Restrict biofuels to hard-to-decarbonize transport (e.g., heavy duty vehicles, aviation, shipping)
● Mandates: Nationwide EV mandates similar to California’s
● Hydrogen: Create incentives and support infrastructure for green hydrogen development and distribution
● Energy codes: Encourage states to adopt an energy code to achieve optimal electrification and efficiency
● Enforcement: Funding for the enforcement of new building standards
● Equity: Subsidize the transition of low-income households to electrify buildings and transport
Carbon Capture. Removal of CO2
from combustion processes as well
as from the air are necessary
components of achieving
decarbonization and eventually
negative emissions.
● Research and development: Invest in Carbon Capture and Storage (CCS) pilots to achieve necessary scale
● Procurement: Direct and indirect funding through procurement by state and federal agencies
● Increase the size of the federal tax credit under section 45Q for CCS
● Clean Energy Standard: Make CCS-cleaned energy eligible for meeting clean energy standards
● Negative Agricultural Emissions: Incentivize farmers to store carbon in soils
● Carbon Pricing: Create a price on emissions that incentivizes both CCS and reforestation efforts on private lands Oct. 11, 2022Item #12 Page 328 of 560
290
7.6 Conclusion
One of the lessons from the pandemic is that systems must adjust to changing science and
allow for ongoing learning from front-line experts on implementation. The same should be true
for the historic task of transitioning the regional economy from fossil fuels to net zero
emissions. The structures, mechanisms, and principles proposed in this chapter provide initial
guidance on the design and implementation of a process to achieve climate ambitions.
However, the process can and should evolve over time as science and technology advance. The
collaboration established in the creation of the RDF itself provides a good starting point for the
region. The parts of this collaboration that work well should be developed and scaled up.
Oct. 11, 2022 Item #12 Page 329 of 560
291
Works Cited:
1. Castán Broto, V., & Bulkeley, H. (2013). A survey of urban climate change experiments in 100 cities. Global
Environmental Change, 23(1), 92–102. https://doi.org/10.1016/j.gloenvcha.2012.07.005
2. Measham, T. G., Preston, B. L., Smith, T. F., Brooke, C., Gorddard, R., Withycombe, G., & Morrison, C. (2011).
Adapting to climate change through local municipal planning: Barriers and challenges. Mitigation and
Adaptation Strategies for Global Change, 16(8), 889–909. https://doi.org/10.1007/s11027-011-9301-2
3. SDSN. (2020). Zero Carbon Action Plan. Sustainable Development Solutions Network. https://irp-
cdn.multiscreensite.com/6f2c9f57/files/uploaded/zero-carbon-action-plan.pdf
4. Victor, D.G., & Muro, M. (2020, October 22). Cities are pledging to confront climate change, but are their
actions working? Brookings. https://www.brookings.edu/blog/the-avenue/2020/10/22/cities-are-pledging-to-
confront-climate-change-but-are-their-actions-working/
5. Kern, K. (2018). Cities as leaders in EU multilevel climate governance: Embedded upscaling of local
experiments in Europe. Environmental Politics, 28(1), 125–145.
https://doi.org/10.1080/09644016.2019.1521979
6. Victor, D.G. & Sabel, C.F.. Sabel. (2022). Fixing the Climate: Strategies for an Uncertain World (Princeton
University Press), https://press.princeton.edu/books/hardcover/9780691224558/fixing-the-climate.
7. Holcombe, R. G., & Williams, D. W. (2009). Are There Economies of Scale in Municipal Government
Expenditures? Public Finance and Management, 9(3), 416–438.6.
8. Morrill, R. L. (1989). Regional Governance in the United States: For Whom? Environment and Planning C:
Government and Policy, 7(1), 13–26. https://doi.org/10.1068/c070013
9. Jordan, A., & Huitema, D. (2014). Innovations in climate policy: The politics of invention, diffusion, and
evaluation. Environmental Politics, 23(5), 715–734. https://doi.org/10.1080/09644016.2014.923614
10. Trumbull, K., & DeShazo, J. R. (2021). Southern California Regional Energy Needs Assessment (p. 85). Luskin
Center for Innovation.
11. Victor, D.G., Geels, F.W., Sharpe, S.(2019). “Accelerating The Low Carbon Transition.” Washington, D.C.:
Brookings Institution. https://www.brookings.edu/research/accelerating-the-low-carbon-transition/.
12. SANDAG. (2018). Climate Change White Paper. San Diego Association of Government.
13. Diehl, P. Oceanside will push for beach groins, sand bypass system despite likely denial by state. The San Diego
Union-Tribune (2021). https://www.sandiegouniontribune.com/communities/north-
county/oceanside/story/2021-08-12/oceanside-will-request-permits-for-beach-groins-sand-bypass-system
14. Kalafatis, S. E., & Lemos, M. C. (2017). The emergence of climate change policy entrepreneurs in urban regions.
Regional Environmental Change, 17(6), 1791–1799. https://doi.org/10.1007/s10113-017-1154-0
15. Sampite-Montecalvo, A. Chula Vista council adopts 2017 climate action plan. The San Diego Union-Tribune
(2017). https://www.sandiegouniontribune.com/communities/south-county/sd-se-climate-plan-1005-
story.html
16. SANDAG. (n.d.) Climate Action. San Diego Association of Government (SANDAG).
https://www.sandag.org/index.asp?classid=17&subclassid=46&projectid=565&fuseaction=projects.detail
17. Forrest, K. E., Tarroja, B., Zhang, L., Shaffer, B., & Samuelsen, S. (2016). Charging a renewable future: The
impact of electric vehicle charging intelligence on energy storage requirements to meet renewable portfolio
standards. Journal of Power Sources, 336, 63–74. https://doi.org/10.1016/j.jpowsour.2016.10.048
18. Margoni, L. (2017, June 14). Nuvve and UC San Diego to Demonstrate Vehicle-to-Grid Technology Through
Energy Commission Grant. UC San Diego News.
https://ucsdnews.ucsd.edu/pressrelease/nuvve_and_uc_san_diego_to_demonstrate_vehicle_to_grid_technol
ogy
19. SANDAG (2011). 2050 Regional Transportation Plan. San Diego Association of Government (SANDAG).
Oct. 11, 2022 Item #12 Page 330 of 560
292
https://www.sandag.org/index.asp?projectid=349&fuseaction=projects.detail
20. Anderton, K., & Setzer, J. (2018). Subnational climate entrepreneurship: Innovative climate action in California
and São Paulo. Regional Environmental Change, 18(5), 1273–1284. https://doi.org/10.1007/s10113-017-1160-
2
21. Garrick, D. San Diego and area cities getting $600M in federal COVID-19 relief to help replace lost tax revenue.
The San Diego Union-Tribune (2021).
22. Nikolewski, R. County to join 5-city CCA as alternative to SDG&E. Will it bring lower electric rates? The San
Diego Union-Tribune (2021).
23. CalCCA (2021.) San Diego County to Join San Diego Community Power. California Community Choice
Association (CalCCA). https://cal-cca.org/san-diego-county-to-join-san-diego-community-
power/#:~:text=About%20SDCP%20San%20Diego%20Community,and%20the%20economy%20in%20our
24. PG&E, SDG&E, & SCE (2019). Frontrunner: City of Carlsbad. Statewide Reach Codes Program, California Energy
Codes and Standards, CA Public Utilities Commission. https://localenergycodes.com/content/reach-codes-
frontrunner-city-of-carlsbad/
25. Nikolewski, R. Encinitas just banned natural gas in new buildings, including homes - The San Diego Union-
Tribune. The San Diego Union-Tribune (2021).
26. SoCalGas & SDG&E. SoCalGas and SDG&E Announce Groundbreaking Hydrogen Blending Demonstration
Program to Help Reduce Carbon Emissions. PR Newswire (2020). https://www.prnewswire.com/news-
releases/socalgas-and-sdge-announce-groundbreaking-hydrogen-blending-demonstration-program-to-help-
reduce-carbon-emissions-301178982.html
27. California Department of Fish and Wildlife (2022). Rancho Jamul Ecological Reserve.
https://wildlife.ca.gov/Lands/Places-to-Visit/Rancho-Jamul-ER#10119102-history
28. U.S. Fish and Wildlife Service (2021). San Diego National Wildlife Refuge.
https://www.fws.gov/refuge/San_Diego/about.html
29. San Diego County Department of Parks and Recreation (n.d.). Multiple Species Conservation Program (MSCP).
County of San Diego. https://www.sdparks.org/content/sdparks/en/AboutUs/Plans/MSCP.html
30. SANDAG, SDG&E, County of San Diego, & City of San Diego. (n.d.). Accelerate to Zero Emissions.
http://a2zsandiego.com/static/zero/
31. Black & Veatch Management Consulting. (2021, July). San Diego Regional Electric Vehicle Gap Analysis.
http://a2zsandiego.com/static/zero/regional-gap-analysis.html
32. Massachusetts. (2020). Massachusetts Decarbonization Roadmap (p. 92). MA Executive Office of Energy and
Environmental Affairs.
33. East Central Florida Regional Resilience Collaborative. East Central Florida Regional Planning Council . (n.d.).
https://www.ecfrpc.org/resiliencecollaborative
34. The East Central Florida Regional Resilience Collaborative Memorandum of Understanding. (2019, May 15).
https://www.ecfrpc.org/_files/ugd/4c4fbd_a7e3a59bf14a4bc9b29983ba6613391d.pdf
35. City of Orlando. (2021). The 100% Renewables Cities and Regions Roadmap.
https://renewablesroadmap.iclei.org/wp-content/uploads/2021/11/Orlando-case-study_final.pdf
36. Climate, Energy and Environment Policy Committee. (2020, November 18). Metropolitan Washington 2030
Climate and Energy Action Plan. https://www.mwcog.org/documents/2020/11/18/metropolitan-washington-
2030-climate-and-energy-action-plan/
37. Denver Public Health & Environment. (2018, July). Denver 80x50 Climate Action Plan.
https://www.denvergov.org/files/assets/public/climate-
action/documents/ddphe_80x50_climateactionplan.pdf
38. Mid-America Regional Council, & Climate Action KC. (2021). KC Regional Climate Action Plan.
https://kcmetroclimateplan.org/wp-content/uploads/2021/05/Climate-Action-Plan.pdf
Oct. 11, 2022 Item #12 Page 331 of 560
293
39. Smith, L. A., & Stern, N. (2011). Uncertainty in science and its role in climate policy. Philosophical Transactions
of the Royal Society A: Mathematical, Physical and Engineering Sciences, 369(1956), 4818–4841.
https://doi.org/10.1098/rsta.2011.0149
40. SANDAG. (2018, February). Intraregional Tribal Transportation.
https://www.sandag.org/uploads/publicationid/publicationid_4488_23635.pdf
41. Brouwer, S., & Huitema, D. (2018). Policy entrepreneurs and strategies for change. Regional Environmental
Change, 18(5), 1259–1272. https://doi.org/10.1007/s10113-017-1139-z15.
42. UNFCCC COP https://unfccc.int/process/bodies/supreme-bodies/conference-of-the-parties-cop
43. Myers, J. (2017, August 6). Column: Political Road Map: No one spends more on lobbying in Sacramento than
local governments. Los Angeles Times.
https://www.latimes.com/politics/la-pol-ca-road-map-lobbying-local-governments-20170806-story.html
44. California Strategic Growth Council (2021). SGC Community and Technical Assistance Programs. https://sgc.ca.gov/programs/cace/resources/
45. CARB. (2020). Air Quality and Emissions Data and Statistics. California Air Resources Board.
https://ww3.arb.ca.gov/html/ds.htm
46. EPA. (2019). Inventory of U.S. Greenhouse Gas Emissions and Sinks [Reports and Assessments]. U.S.
Environmental Protection Agency. https://www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-
emissions-and-sinks
47. GCP. (2021). Global Carbon Project (GCP). Global Carbon Project (GCP). https://www.globalcarbonproject.org/
48. Williams, J. H., Jones, R. A., Haley, B., Kwok, G., Hargreaves, J., Farbes, J., & Torn, M. S. (2021). Carbon-Neutral
Pathways for the United States. AGU Advances, 2(1), e2020AV000284.
https://doi.org/10.1029/2020AV000284
49. Huitema, D., Boasson, E. L., & Beunen, R. (2018). Entrepreneurship in climate governance at the local and
regional levels: Concepts, methods, patterns, and effects. Regional Environmental Change, 18(5), 1247–1257.
https://doi.org/10.1007/s10113-018-1351-5
50. Bernstein, S., & Hoffmann, M. (2018). The politics of decarbonization and the catalytic impact of subnational
climate experiments. Policy Sciences, 51(2), 189–211. https://doi.org/10.1007/s11077-018-9314-8
Oct. 11, 2022 Item #12 Page 332 of 560
294
8. Local Policy Opportunity
Scott Anders, Energy Policy Initiatives Center, University of San Diego School of Law
Nilmini Silva-Send, Energy Policy Initiatives Center, University of San Diego School of Law
Joe Kaatz, Energy Policy Initiatives Center, University of San Diego School of Law
Yichao Gu, Energy Policy Initiatives Center, University of San Diego School of Law
Marc Steele, Energy Policy Initiatives Center, University of San Diego School of Law
Overview
Other chapters in this report present results of technical analysis to determine levels of activity in each
of four pathways that are possible and would be needed to reach deep decarbonization goals in the San
Diego region. This chapter assesses current commitments in Climate Action Plans (CAP) to determine if
additional activity would be needed to put the region on a trajectory to meet these goals and to identify
opportunities for local jurisdictions in the region to take further action to support the decarbonization
pathways.
To this end, EPIC completed an analysis of the authority of local governments and agencies to act to
influence and regulate greenhouse gas (GHG) emissions, based on a summary of key federal, state, and
local agencies, and key legislation and regulation at the federal and state levels to help to clarify the
ability of local governments to act to reduce GHG emissions; a review of CAPs to determine the
frequency of measures, relative GHG impact of decarbonization pathways and measures, and
integration of social equity considerations; and a scenario analysis to estimate the total impact of the
GHG reduction commitments in all adopted and pending CAPs and the potential GHG impact of a
scenario of applying the best adopted CAP commitments to all jurisdictions. We use results of the above
analysis and additional research to identify opportunities for further local action and regional
collaboration in each of the four decarbonization pathways. Figure 8.1 summarizes the overall project
approach.
In general, opportunities exist for additional GHG reductions by increasing the number of jurisdictions
adopting an existing measure or policy, making existing measures or policies more aggressive, and
implementing policies not previously adopted in the region. Opportunities for regional collaboration can
include efforts to support local policy development and implementation and those that are regional in
scope that are intended to serve the entire region.
Oct. 11, 2022 Item #12 Page 333 of 560
295
Figure 8.1 Overall Approach to Identifying Local Policy Options
Figure 8.2 illustrates the organizational structure for the analysis and results presented here and
indicates the related Regional Decarbonization Framework Technical Report chapter. The three main
pillars of decarbonization — focused on buildings, electricity supply, and transportation — represent
both the highest emitting sectors and those with the highest potential to reduce GHG emissions. Natural
climate solutions, including agriculture, are important and will be included in the analysis but to a lesser
extent than the three main pathways. The broad pathways can be further organized into policy
categories and subcategories, which allow for a more detailed analysis of policies in CAPs.
Figure 8.2 Examples of Decarbonization Pathways and Related Policy Categories
Oct. 11, 2022 Item #12 Page 334 of 560
296
Organization of Chapter
Section 8.2 summarizes local jurisdiction authority to act to influence GHG emissions. Summaries related
to each decarbonization pathway are provided in those sections. Section 8.3 provides an overview of the
results of the review of CAPs, including general information about CAPs, and data on the frequency and
GHG impacts of CAP measures related to the four decarbonization pathways. A summary of results from
the scenario analysis of GHG impacts is presented in Section 8.4. The next four sections provide a
detailed discussion of the four decarbonization pathways, including opportunities for local policies and
regional collaboration: Decarbonize Transportation (Section 8.5), Decarbonize Buildings (Section 8.6),
Decarbonize the Electricity Supply (Section 8.7), Natural Climate Solutions (Section 8.8). A brief
discussion of the limitations of the analysis presented here is provided in Section 8.9. A brief conclusion
is provided in Section 8.10.
8.1 Key Findings
Based on our analysis, the following overall key findings emerge. More detailed findings are provided in
each section below, including findings from the analysis and opportunities for local action and regional
collaboration.
• Local Jurisdictions Have Authority to Influence and Regulate GHG Emissions – Local governments
can influence and regulate GHG emissions by accelerating state statutory targets and policies,
adopting ordinances to go beyond state law, and using unique authority to adopt and
implement policies. Local authority comes from both constitutionally derived police power and
delegated authority from state statutes. Constitutionally derived police power grants a broad,
elastic authority to act where such action is reasonably related to a legitimate government
purpose and has a reasonable tendency to promote public health, safety, or the general welfare
of the community. It is limited by general state law and state and federal constitutions. The full
extent of a local jurisdiction’s police power to regulate GHG emissions is unknown. Delegated
authority includes, among other things, analyzing land use environmental impacts and
mitigating them, adopting more stringent building codes, building infrastructure, or creating
community choice aggregators (CCA) to supply electricity. Key findings related to authority in
each decarbonization pathway are presented in more detail in Section 8.2 and the sections on
each decarbonization pathway (Sections 8.5 through 8.8). A full discussion of local authority is
provided in Appendix B.
• Adopted and Pending CAP Commitments are Insufficient to Reach Decarbonization Goals – Local
commitments in adopted CAPs for transportation, electricity, and natural gas GHG reductions
contribute a relatively small portion of the total reductions needed to reach net zero GHG
emissions in 2035 — about 2 million metric tons CO2e (MMT CO2e), which would leave about 12
MMT CO2e. Including the commitments from the City of San Diego draft CAP 2022 in this
analysis would yield GHG reductions of about 5 MMT CO2e in 2035, leaving about 8.5 MMT
CO2e. Even if the most aggressive CAP measures are applied to all jurisdictions in the region,
regardless of whether they have a CAP in place, significant emissions would remain
(approximately 7 MMT CO2e in 2035), mostly from natural gas combustion and on-road
transportation. Note remaining emissions from other emissions categories also would have to
be addressed. Similarly, including the best CAP commitments from the City of San Diego draft
CAP 2022 would reduce the amount of remaining emissions to about 5 MMT CO2e in 2035.
More detail is provided in Section 8.4 and Sections 8.5 through 8.8.
• Opportunities Exist for More Jurisdiction to Adopt and Strengthen Existing CAP Measures –
Based on the review of CAPs, there is an opportunity for more jurisdictions to adopt CAP
Oct. 11, 2022 Item #12 Page 335 of 560
297
measures already adopted by some jurisdictions in the region. Similarly, based on the scenario
analysis of the combined GHG impacts of CAP measures, there is an opportunity for most
jurisdictions to strengthen their existing CAP measures. While many policy examples exist in our
region, there also are other examples from around California and the U.S. of policies that have
not been included in CAPs in the region. More detail is provided in Section 8.4 and Sections 8.5
through 8.8.
• Additional Policies Would be Needed to Decarbonize Transportation and Buildings – Based on
adopted CAP commitments, expected GHG reductions in 2035 from measures to reduce vehicle
miles traveled (VMT) and increase use of zero-emissions vehicles (ZEV) are insufficient to
achieve the level of GHG emissions reductions — mainly from ZEVs outlined in Chapter 3. Local
uptake of ZEVs beyond what is expected from state and regional incentives likely would require
more local incentives. Similarly, expected GHG reductions in 2035 from building measures in
adopted CAPs are insufficient to meet the goals outlined in Chapter 4. In particular, more
measures would be needed to electrify existing buildings. More detail on decarbonizing
transportation is provided in Section 8.5 and on decarbonizing buildings in Section 8.6.
• Opportunities Exist for Regional Collaboration in all Decarbonization Pathways – Regional
collaboration could include collecting and tracking data, conducting analysis, providing support
to develop and implement policies, and convening stakeholder and working groups to develop
regional strategies and monitor progress. Examples exist for regional collaboration, including the
Accelerate to Zero (A2Z) project to increase use of ZEVs. More detail on opportunities for
regional collaboration is provided in Sections 8.5.7, 8.6.6, 8.7.6, and 8.8.6.
• Additional Work Would be Needed to Integrate Social Equity into Climate Planning – Based on a
preliminary review, the integration of social equity in adopted and pending CAPs is limited,
inconsistent, and lacks specificity. Additional work would be needed to develop the capacity and
tools to understand and address the equity implications of all decarbonization policies in the San
Diego region, including data collection and analysis; regional guidance documents; and regional
working groups to coordinate, advise, track, and monitor how equity is being addressed in
climate planning. Additional discussion on social equity is provided in Sections 8.3.5, 8.5.7, 8.6.6,
8.7.6, and 8.8.6.
8.2 Authority of Local Jurisdictions and Agencies to Influence and Regulate
GHG Emissions
In general, to reduce GHG emissions, local governments can accelerate state statutory targets and
policies, adopt ordinances to go beyond state law, and use unique authority to adopt and implement
policies. This section provides a summary of a detailed review (provided in Appendix B). It seeks to
answer the following questions related to the ability of local governments and agencies to influence or
regulate GHG emissions:
• What constitutional or delegated authority exists for local action, and to what extent is local
authority preempted by federal or California law or regulation?
• What state and federal players can influence or regulate GHG emissions (e.g., state regulators like
the California Air Resources Board (CARB)), and what are their respective roles relative to local
jurisdictions and agencies?
• What key legislation or regulation applies in a given area (e.g., building electrification) that will
affect GHG emissions at the local level?
Oct. 11, 2022 Item #12 Page 336 of 560
298
8.2.1 Summary of Findings
Local jurisdiction authority to regulate GHGs is created by broad, general constitutionally derived “police
power”i or delegated authority under state or federal law. Use of police authority may not conflict with
“general” law (e.g., state law) under preemption principles found in California Constitutional Article XI,
§7 or federal expressed or implied preemption under the Supremacy Clause of the U.S. Constitution.ii
State and federal preemption analysis, as well as the analysis on the full extent of local police power to
regulate GHG emissions, are factually specific with local jurisdiction authority uncertainty dependent on
the type of action.
Police power of a city or county within its own boundaries is as broad as that of the state legislature and
subject only to limitations of general law.iii Police power "is not a circumscribed prerogative, but is
elastic and, in keeping with the growth of knowledge and the belief in the popular mind of the need for
its application, capable of expansion to meet existing conditions of modern life and thereby keep pace
with the social, economic, moral, and intellectual evolution of the human race."iv Its exercise must be
both:
a) Reasonably related to a legitimate government purposev; and
b) Have a reasonable tendency to promote the public health, morals, safety, or general welfare of
the community.vi
Police power is especially well established in enacting and enforcing land use laws. City and county land
use authority does not rely on delegated general law of the state or federal government. Instead, state
and federal laws are limitations on a city’s or county’s exercise of its police power.vii To this end, local
jurisdictions act with both police power and delegated authority from the legislature to establish climate
changes policies and regulations to reduce GHGs in general plans (GPs), CAPs, zoning, transit-oriented
development regulations, carbon sequestration (including urban forestry), energy conservation actions
through green building practices and reach codes, water conservation, and solid waste reduction. Land
use authority is subject to the vested rights doctrineviii and Subdivision Map Actix that limits how a
subsequent change in local law or the authority to impose conditions apply to a particular improvement
to land or a vesting tentative map for subdivisions.
Local jurisdiction police power is also subject to state preemption. Examples include the California
Energy Commission’s authority to site and license thermal power plants of 50 megawattsx or more and
energy storage resources of 20 MWs or more that discharge for at least two hours or more and will
i Cal. Const. art. XI, § 7.
ii U.S. Const. art. VI, § 2.
iii Candid Enters., Inc. v. Grossmont Union High Sch. Dist., 39 Cal. 3d 878, 885 (1985); Birkenfeld v. City of Berkeley,
17 Cal. 3d 129, 140 (1976); Carlin v. City of Palm Springs, 14 Cal. App. 3d 706, 711 (1971).
iv Miller v. Board of Pub. Works, 195 Cal. 477, 485 (1925).
v Birkenfeld v. City of Berkeley, 17 Cal. 3d 129, 158 (1976). See Consolidated Rock Prods. Co. v. City of Los Angeles,
57 Cal. 2d 515, 522 (1962).
vi Carlin v. City of Palm Springs, 14 Cal. App. 3d 706, 711 (1971).
vii DeVita v. County of Napa, 9 Cal. 4th 763, 782 (1995); Candid Enters., Inc. v. Grossmont Union High Sch. Dist., 39
Cal. 3d 878, 885 (1985).
viii Avco Community Developers v. South Coast Reg’l Comm’n, 17 Cal. 3d 785, 791 (1976), superseded by statute as
stated in Santa Margarita Area Residents Together v. San Luis Obispo County Bd. Of Supervisors, 84 Cal. App. 4th
221, 229 (2000). ix See Government Code §§ 66410–66499.38; Govt Code § 66474.2 & 66498.1(b).
x See Public Resources Code §§ 25500 et seq.; See Public Resources Code §§ 25120 & 25123.
Oct. 11, 2022 Item #12 Page 337 of 560
299
deliver net peak energy by October 31, 2021.i It is notable that the Governor may curtail local land use
authority over siting and regional air quality regulation of these and other related energy resources,
including emergency backup generation, when an emergency declaration is issued for a specified time
period.ii Such declarations can suspend local and state laws by either establishing exclusive licensing
authority that preempts or by expressly suspending air quality laws, the California Environmental Quality
Act (CEQA), and the California Coastal Act (CAC). Emergency declarations may also have the effect of
limiting judicial review of such licenses.
Local land use authority is generally concurrent to, and not preempted by, air quality authority law and
regulation of air pollutants from stationary, nonvehicular sources of emissions. Concurrent authority
may allow local jurisdictions to further regulate air quality under its police power.iii It should be noted
that there is no power granted to local air districts to infringe on an existing local jurisdiction’s authority
over land use (e.g., zoning).iv
Charter cities and counties act with more autonomy over governance decisions than common law cities
and countiesv; however, all local jurisdictions are controlled and subject to general state law. Of the
nineteen local governments in the San Diego region, there are eight charter citiesvi, and the County of
San Diego is a charter county. Notably, all cities act with a higher level of autonomy than the County
because they are voluntarily formed and perform many essential services. Charter cities also act with
more autonomy than common law cities under the “home rule” power to govern matters of “municipal
affairs.”vii Charter counties exercise limited home rule authority.viii This power allows local laws to
expand beyond state law requirements. However, the extent of home rule authority is a legal
determination that depends on the specific charter and municipal code of an individual charter
jurisdiction, whether the exercised authority is for a municipal affair, and whether the matter is of
statewide concern where it is the intent and purpose of the general laws to occupy the field to the
exclusion of municipal regulation.ix Finally, because counties are the legal subdivision of the state, the
state may delegate or rescind any delegated function of the state to a county.
i See California Energy Commission Order No. 21-0908-1 (Adopted September 8, 2021).
ii See Governor’s July 30, 2021 Proclamation of A State of Emergency to address energy supply and demand issues;
See U.S. Const. Amendment X; See California Emergency Services Act: Government Code §§ 8558, 8567, 8571,
8625, & 8627.
iii See Health & Safety Code §§ 39002 & 41508.
iv See Health & Safety Code §§ 40716(b) & 41015.
v See Cal. Const. art. XI; See Government Code § 34871.
vi Cities of Carlsbad, Chula Vista, Del Mar, El Cajon, Oceanside, San Diego, San Marcos, and Vista.
vii Cal. Const. art. XI, § 5.
viii Charter County limited “home rule” authority includes: 1) providing for lection, compensation, terms, removal,
and salary of the governing board; 2) for the election or appointment (except the sheriff, district attorney, and
assessor who must be elected), compensation, terms, and removal of all county officers; 3) for the powers and
duties of all officers; and for consolidation and segregation of county offices. It excludes additional authority over:
1) local regulations; 2) revenue-raising abilities; 3) budgetary decisions; or 4) intergovernmental relations.
ix See Cal. Const. art. XI, § 5, subd. (a); See Jackson v. City of Los Angeles, 111 Cal. App. 4th 899 (2d Dist. 2003); See
City of Santa Clara v. Von Raesfeld, 3 Cal. 3d 239 (1970); See Baron v. City of Los Angeles, 2 Cal. 3d 535 (1970);
Dairy Belle Farms v. Brock, 97 Cal. App. 2d 146, 217 P.2d 704 (1st Dist. 1950); See Wilkes v. City and County of San
Francisco, 44 Cal. App. 2d 393, (1st Dist. 1941); See People ex rel. Scholler v. City of Long Beach, 155 Cal. 604 (1909); See Galli v. Brown, 110 Cal. App. 2d 764 (1st Dist. 1952); See Pearson v. Los Angeles County, 49 Cal. 2d 523
(1957).
Oct. 11, 2022 Item #12 Page 338 of 560
300
Local jurisdictions also act with the authority to tax,i issue bonds,ii and impose fees, charges, and rates.iii
This authority is derived from and limited by the California Constitution and statute, including requiring
voter approval for taxes and bonds.iv
Summary of Findings by Decarbonization Pathway
Table 8.1 summarizes local jurisdiction authority for each decarbonization pathway and policy category.
Also, brief summaries of the authority related to the decarbonization pathways are presented in the
sections on Decarbonize Transportation (Section 8.5), Decarbonize Buildings (Section 8.6), Decarbonize
the Electricity Supply (Section 8.7), and Natural Solutions (Section 8.8). Appendix B contains a more
detailed discussion of the underlying research that forms the basis of the summary below and authority
summaries found in each pathway section.
Table 8.1 Summary of Authority by Decarbonization Pathway
Decarbonization
Pathway Policy Category Policy Subcategory
Decarbonize
Transportation
VMT Reductions
Limited federal or state preemption. Local jurisdiction police power
and delegate authority over land use are primary, with decisions
implemented almost exclusively at the local level. Some authority
uncertainty exists over regulation of indirect emission from
developments.
Fuel Use
Reductions
Limited federal or state preemption. Local jurisdiction police power
and delegate authority over land use are primary, with decisions for
transportation system efficiencies implemented almost exclusively at
the local level.
Alternative Fuel
Vehicles and
Equipment
Local jurisdiction authority is clear over infrastructure development
and municipal fleet procurement. California currently regulates carbon
intensity of fuel with limited opportunity for further local action
beyond incenting and accelerating low-carbon fuels and vehicles.
Decarbonize Buildings
Electrification
Clear authority to mandate electrification using delegated authority if
statutory requirements are met. Police power may be used but there is
uncertainty as to the extent of this power and how to best implement
such a requirement.
Energy
Efficiency
Federal and state preemption exists over appliance energy standards.
Clear police power and delegated authority to create more stringent
building standards if statutory requirements are met. It may be
possible to also exercise police power in this regard.
Low Carbon
Fuels
Police authority may allow mandates that require low-carbon fuels for
end-uses as well GHG based performance standards and benchmarking
for buildings. There is clear authority to procure for public buildings. It may also be possible to regulate GHGs directly or indirectly from
buildings.
i Cal. Const. art. XIIIC, § 2(a) & (d).
ii See generally Municipal Bond Act of 1901 (Government Code §§ 43600–43638) & Government Code §§ 50665.1–
50670.
iii Cal. Const. art XI, § 7; see also Revenue Bond Act of 1941 (Government Code §§ 54300 et seq., Uniform Standby
Charge Procedure Act (Government Code §§ 54984 et seq.); Government Code § 66013; Government Code §
66014; Health & Safety Code § 5471 & 5473; See generally Government Code § 37112. iv See generally Cal. Const. art. XIIIA, XIIIC, & XIIID; See Bradley-Burns Uniform Local Sales and Use Tax Law
(Revenue & Tax Code §§ 7200 et seq.).
Oct. 11, 2022 Item #12 Page 339 of 560
301
Decarbonization
Pathway Policy Category Policy Subcategory
Decarbonize
Electricity
Supply
Grid Supply
Clear authority to create community choice aggregator (CCA),
determine content of electricity for citizens under a CCA, and act to
procure low- or zero-carbon generation to ensure reliability. This
authority is subject to and limited by state and federal reliability
requirements.
Customer Side
Supply
Clear authority to support distributed energy generation through CCA,
incentives, CPUC proceedings, and streamlined permitting. Must
account for changes in state policy that change the regulation and/or
economics for customer side resources across multiple load serving
entities.
Natural Climate
Solutions
Carbon Removal
& Storage
This is an evolving area of state action and law with significant
mandates on state land agencies through executive orders. It is
complicated by federal, tribal, state, private, and local land ownership,
land use authority, and land management agencies. Cooperative
agreements amongst these stakeholders are paramount to achieving
any regionwide action. Existing local jurisdiction land use authority exists, but additional research and development of what is legally
feasible to develop or mandate these types of projects would be
needed. Aligning with state planning and funding could be evaluated.
Carbon Stock
Preservation
This is an evolving area of state action and law with significant
mandates on state land agencies through executive orders. It is complicated by federal, tribal, state, private, and local land ownership,
land use authority, and land management agencies. Cooperative
agreements amongst these stakeholders are paramount to achieving
any regionwide action. Existing local jurisdiction land use authority
exists, but additional research and development of what is legally
feasible beyond easements and land conservation, particularly with
regard to activities on private land, would be needed. Aligning with
state planning and funding could be evaluated.
Agriculture
Methane
Reduction
State authority exists for CARB to regulate, but legislation sets January
1, 2024, as the effective date of any regulation. It is unclear whether
CARB will enact regulations in 2024, leaving potential opportunity for
local jurisdiction action.
8.2.2 Limitations of Review of Authority
The review of authority analyzed federal and state preemption with regards to local jurisdiction police
power and delegated authority. It evaluated opportunities for local jurisdictions to act within existing
constitutional, legislative, and regulatory frameworks and to identify uncertainty with regard to
authority. It was designed to be comprehensive but not exhaustive given the complexity of some of the
laws involved and the lack of activities in certain areas such as natural climate solutions. It did not
evaluate specific local policies — such as permit approval processes — to find barriers. Additional work
would be needed in this area to understand the opportunities and challenges presented by local
policies.
8.3 Review of Climate Action Plans in the San Diego Region
CAPs are planning documents that demonstrate how a local jurisdiction can achieve an adopted
Oct. 11, 2022 Item #12 Page 340 of 560
302
emissions target. Cities develop plans for a variety of reasons, including as mitigation for General Plan
updates or to act as general, aspirational guidance for city actions. In general, CAPs represent what local
jurisdictions have determined to be a reasonable and feasible commitment to reduce GHG emissions at
the time of adoption. EPIC reviewed and analyzed measures and supporting actions contained in 17
adopted and pending CAPs to identify current local policy commitments in the San Diego region that
support decarbonization pathways.
For this analysis, we determined (1) the frequency and distribution of measures and supporting actions
across all 17 CAPs, (2) how much CAP measures and supporting actions contributed to the local GHG
reduction in CAPs, and (3) whether and how CAPs integrate social equity considerations.
8.3.1 Summary of Findings
• Nearly half of the CAPs in the region are scheduled to be updated between 2021 and 2025.
• No adopted CAP analyzed has a net zero GHG emissions target. The City of San Diego draft 2022
CAP update, the only pending CAP as of July 2022, has a net zero emissions target by 2035.
• Significant variability exists across CAPs in how much each decarbonization pathway and policy
category contributes to the local GHG reduction. For example, the contribution from
decarbonizing electricity ranges from 10% to nearly 70% of local GHG reductions. Similarly,
decarbonizing transportation ranges from about 7% to 50%, building decarbonization ranges
from 0% to 42%, and natural climate solutions range from 0% to 5%.
• All adopted and pending CAPs have measures to approach or achieve 100% carbon-free grid
electricity supply before the state deadline of 2045. On average, these measures account for
about 42% of local GHG reductions in CAPs; the majority is through a CCA program.
• Based on GHG commitments in CAPs, transportation-related measures account for the next
highest contribution to local GHG emissions reductions (30%), with alternative fuel use
contributing on average about 16% and VMT reduction on average about 12%.
• On average, GHG reductions in CAPs come disproportionately from decarbonizing electricity
even though on-road transportation is the highest emitting GHG emissions category. This is due
mostly to the statewide policy to achieve 100% carbon-free electricity in California by 2045 and
suggests an opportunity for additional reductions from the Decarbonize Transportation
Pathway.
• Opportunities exist across all decarbonization pathways for more local jurisdictions to adopt
existing CAP measures.
• CAP measures employ a range of implementation mechanisms, including making capital
expenditures and infrastructure investments, typically by local jurisdictions; education,
outreach, and collaboration; financial incentives and financing; evaluations of potential
programs and policies; plans or programs; and requirements. It is common for local
governments to combine approaches.
• In general, social equity considerations in CAPs are limited, inconsistent, and lack specificity. The
City of San Diego draft 2022 CAP update has the most comprehensive integration of social
equity of any CAP in the San Diego region. CAP updates provide an opportunity to integrate
social equity into the entire climate action planning cycle. The SANDAG ReCAP Framework could
be expanded to include guidance for integrating equity considerations into CAPs.
• Regional equity indicators could be developed through a regional program and collaboration,
with a consistent definition of equity, that regularly reports on climate-related equity topics. A
Regional Climate Equity Collaborative or Working Group could educate and advise regional
leaders and collect stakeholder input.
Oct. 11, 2022 Item #12 Page 341 of 560
303
8.3.2 Review of CAPs Approach
To analyze CAP measures and supporting actions, EPIC updated its CAP Mitigation Measure Database to
reflect the most recently adopted and pending CAPs. CAP measures and supporting actions were
categorized using several different characteristics to facilitate analysis in line with the structure of this
report, including decarbonization pathways, policy categories and subcategories, and implementation
mechanisms. The following sections provide more details on this approach.
CAPs Included in the Analysis
Table 8.2 summarizes which CAPs we included or excluded from the review of CAPs. We evaluated
sixteen adopted CAPs or similar plans and one pending. The City of San Diego draft CAP update, which
was released for public review in November 2021 and is anticipated to be adopted in Summer 2022, is
the only draft CAP pending adoption in the region as of July 2022. We excluded the City of National City
because its CAP was adopted in 2011 and had a 2020 emissions target. Further, its methods, data, and
measures predate significant development in methods and state guidance. In addition, the City of El
Cajon rescinded its CAP in 2020; however, it was replaced with a Sustainability Initiative, which contains
measures and actions substantially similar to the CAP and is treated as such in this analysis. Lastly, the
County of San Diego’s CAP, which was adopted in 2018, has since been invalidated through litigation;
however, the County is in the process of revising its CAP and is actively implementing measures included
in its 2018 CAP. For this reason, the County is included in the 17 jurisdictions with adopted and pending
CAPs out of the 19 jurisdictions in the region.
Note that results from the analysis completed based on the Review of CAPs presented throughout this
document, including the frequency of policies and the relative contribution to local GHG emissions, are
based on adopted and pending CAPs. The Scenario analysis presented in Section 8.4 is based on adopted
CAPs only. An alternative scenario that includes the GHG impact of the City of San Diego draft 2022 CAP
update is included.
Oct. 11, 2022 Item #12 Page 342 of 560
304
Table 8.2 CAPs Included in Local Policy Analysis
Jurisdiction CAP Status Included in Analysis
Carlsbad 2020 Y
Chula Vista 2017 Y
Coronado 2022 Y
County of San Diego In Progress Y
Del Mar 2016 Y
El Cajon1 2020 Y
Encinitas 2020 Y
Escondido 2021 Y
Imperial Beach 2019 Y
La Mesa 2018 Y
Lemon Grove 2020 Y
National City 2011 N
Oceanside 2019 Y
Poway N/A N/A
San Diego Pending Y
San Marcos 2020 Y
Santee 2020 Y
Solana Beach 2017 Y
Vista 2021 Y
1 The City of El Cajon has adopted a Sustainability Initiative with measures
similar to a Climate Action Plan.
Policy Categories and Subcategories
The decarbonization pathways constitute the main parts of an overall strategy to reduce GHG emissions.
These include decarbonize electricity, decarbonize buildings, decarbonize transportation, and natural
climate solutions. Policy categories represent the main methods to reduce emissions within a
decarbonization pathway. These can be further broken down into policy subcategories, which we
derived by reviewing adopted and pending CAPs, to allow for more specificity. This categorization
structure provides a framework for this chapter and our analysis of CAP measures.
Table 8.3 shows the categorization used here. In later sections of this chapter, policy subcategories are
further subdivided where appropriate and necessary for discussion on additional policy opportunities.
For instance, building electrification policy options differ between new construction and the current
building stock, and between building types (e.g., residential and non-residential).
Oct. 11, 2022 Item #12 Page 343 of 560
305
Table 8.3 Decarbonization Pathways and CAP Policy Categories
Decarbonization Pathway CAP Policy Category CAP Policy Subcategory
Decarbonize
Transportation
VMT Reductions
Bike, Walk, & Complete Streets
Mass Transit
Parking Reductions
Commuter TDM
Smart Growth Development
Micromobility (excluding bicycles)
Fuel Use Reductions
Traffic Signal Synchronization
Traffic Calming Infrastructure
Vehicle Retirement
Driver Behavior
Alternative Fuel Vehicles
and Equipment
Electric Vehicles
Low Carbon Fuel Vehicles
Hybrid Vehicles
Preferred Parking
EV Charging Infrastructure
Low Carbon Fuel Infrastructure
Low Carbon Fuel Equipment (Off-Road)
Electric Equipment (Off-Road)
Decarbonize
Buildings
Electrification Electrify Select End-Uses
All-Electric
Energy Efficiency Audits, Benchmarking, and Disclosure
Implement Efficiency Improvement(s)
Low Carbon Fuels NA
Decarbonize
Electricity Supply
Grid Supply CCA or Similar
Utility Customer Renewable Energy Procurement
Customer Side Supply Renewable Distributed Generation
Natural
Climate Solutions
Carbon Removal
& Storage
Urban Tree Planting
Conservation & Restoration Projects (Removal)
Urban Gardens
Carbon-Farming Practices (Removal)
Turf Management
Carbon Stock
Preservation
Agriculture Easements
Open Space Easements
Wildfire Prevention
Carbon-Farming Practices (Preservation)
Conservation & Restoration Projects
(Preservation)
Agriculture Methane
Reduction NA
Implementation Mechanisms
CAP measures and actions are differentiated by implementation mechanism, which is how a local
jurisdiction intends to achieve the desired activity. Table 8.4 summarizes the implementation
mechanisms used to organize CAP measures for this analysis. In some instances, a CAP measure or
action may require multiple implementation mechanisms to achieve the stated goal (e.g., education and
outreach, incentives, and requirements).
Oct. 11, 2022 Item #12 Page 344 of 560
306
Table 8.4 CAP Policy Implementation Mechanism Categories
Implementation
Mechanism Description
Capital Improvement
& Infrastructure
CAP measures and actions that require municipal funds to be completed. For
instance, city-wide projects, such as the installation of bike lanes, or projects that
impact municipal facilities or operations, such as conversion of the municipal fleet.
Requirement(s) CAP measures and actions that require a GHG reduction activity through a regulation,
ordinance, or some other mandatory means.
Incentive(s) CAP measures and actions that encourage a GHG reduction activity through monetary
and non-monetary incentives, such as rebates and permit streamlining.
Plan or Program CAP measures and actions to expand or create new plans and or programs that
facilitate mitigation activity.
Education, Outreach,
& Coordination
CAP measures and actions that expand awareness, communicate and share
information, and/or initiate or expand partnerships and relationships.
Evaluation CAP measures and actions that improve feedback, input, and data and information or
conduct further or new analyses.
Policy Frequency
The review of CAPs identified the number of jurisdictions that have committed to one or more policy
action and organized results by decarbonization pathway, policy category, and implementation
mechanism. Identifying the frequency with which specific types of measures and actions are adopted
helps to determine which policy options are most commonly used to achieve GHG reduction. This can, in
turn, illustrate where jurisdictions can achieve additional reductions, either by adopting a new policy or
by strengthening policy commitments. For example, policies that rely solely on education and outreach
efforts are likely to achieve fewer GHG reductions than a requirement. In some instances, a jurisdiction
may have limited authority to use certain implementation mechanisms (e.g., requirements); discussion
on local authority throughout this chapter will help determine the extent to which jurisdictions can use
specific approaches to implement their CAP measures and actions.
Relative Contribution to Local GHG Reduction in CAPs
Comparing GHG reduction values across CAPs can be problematic given potential differences in emission
sources, measures included, methods used to estimate GHG impacts, target, and target year. One way
to compare across CAPs is to show how measures or groups of measures contribute to the overall local
GHG reduction in a particular target year. For example, the portion of GHG reductions in a CAP that
would result from local measures to decarbonize buildings.
One challenge comparing GHG impacts is that there is no common target year across adopted and
pending CAPs in the region; however, 2035 is a common target year in CAPs. For those CAPs where GHG
reductions were not reported for 2035, reductions were extrapolated linearly if 2035 fell between two
target years (e.g., 2030 and 2050), or carried forward from the previous target year (e.g., if 2030 were
the last target year, emissions reductions from 2030 were applied in 2035).
Analyzing the relative GHG reduction contribution of CAP measures at the policy subcategory or a lower
level is difficult given differences in how measures are structured across CAPs. In many instances, a CAP
measure may have multiple elements that cut across policy subcategories, making it difficult to separate
out the GHG reductions associated with each individually. For this reason, the relative GHG contribution
of CAP measures was only analyzed at the decarbonization pathway and policy category levels in target
year 2035.
Oct. 11, 2022 Item #12 Page 345 of 560
307
Local GHG Commitments in CAPs in the San Diego Region
The GHG reductions in CAPs represent the GHG impacts of federal and State mandates and local
commitments that lead to reductions at the local level. After developing a baseline GHG emissions
inventory, emissions are projected to a future year. The jurisdiction establishes one or more emission
targets, and develops the local actions needed to achieve that target.i
The baseline GHG emissions inventory for a given year serves as the basis for projections and targets.
Emissions target levels are most often determined as a percentage reduction from the baseline year. A
business-as-usual (BAU) projection is made based on population, employment, and housing growth,
with no additional future policy changes after the baseline year. The BAU projection is then adjusted to
account for the future emissions impact of federal and State policies in place at the time of CAP
development. This is sometimes called the legislatively-adjusted BAU projection. The difference
between the legislatively-adjusted BAU emissions in a target year and the target level of emissions is
sometimes referred to as the “local emissions gap” or “local gap.”
In Figure 8.3, the upper black line is the BAU projection, and the blue line below is the legislatively-
adjusted BAU projection. The green dashed line represents the emissions trajectory to meet target
emissions levels. The gap between the blue and green dashed lines represents the local gap.ii
Throughout this chapter, we refer to the measures to address this local gap as “local CAP measures” or
“local measures,” which is the focus of the analysis presented here. Remaining emissions are those left
after reaching target emission levels or whatever level can be attained.
Figure 8.3 Illustration of CAP Projections, Legislatively-Adjusted Projection, and Local Gap
8.3.3 General Characteristics of CAPs
Eighteen local jurisdictions in the San Diego region have adopted CAPs or similar plans (Table 8.5). The
County of San Diego previously adopted a CAP but is in the process of updating the document as a result
of litigation. Only the City of Poway has not begun activity to develop a CAP. CAPs are generally updated
i SANDAG Regional Climate Action Planning Framework: TECHNICAL APPENDIX I- GHG Inventories, Projections, and
Target Selection, VERSION 1.1: OCTOBER 2020.
ii For details on this, see SANDAG ReCAP Technical Appendix I, Id.
Oct. 11, 2022 Item #12 Page 346 of 560
308
on a regular basis. Table 8.5 lists the years when local jurisdictions could update their CAP. Eight CAPs
are scheduled to be updated between 2021 and 2025, which provides an opportunity to revise
measures. As noted in the table, nine CAPs are considered to be CEQA-qualified. According to the
SANDAG ReCAP, “[a] ‘CEQA-qualified’ CAP meets the criteria specified in Section 15183.5(b) for a ‘plan
for the reduction of greenhouse gas emissions,’ such that a ‘qualified’ CAP may then be used for the
specific purpose of streamlining the analysis of GHG emissions in subsequent projects.”i
Other public agencies also adopt GHG reduction plans, including the San Diego International Airport,
which has a Carbon Neutrality Plan,ii and the Unified Port District of San Diego.iii Emissions associated
with these public agencies are excluded from local jurisdiction GHG inventories given the lack of
authority to act but are included in the regional GHG inventory included in the SANDAG Regional Plan.
These plans are not included in this analysis.
Table 8.5 Status of CAPs in the San Diego Region
Jurisdiction CAP Adoption Year CAP Update Year2 Whether CEQA Qualified CAP
Carlsbad 2020 2021 Y
Chula Vista 2017 2021 N
Coronado 2022 NA N
County of San Diego In Progress NA NA
Del Mar 2016 2023 N
El Cajon1 2020 2025 N
Encinitas 2020 2025 Y
Escondido 2021 2025 Y
Imperial Beach 2019 2026 N
La Mesa 2018 2027 Y
Lemon Grove 2020 2025-2030 N
National City 2011 NA N
Oceanside 2019 NA Y
Poway NA NA NA
San Diego 2015 NA Y
San Marcos 2020 NA Y
Santee 2020 2021 Y
Solana Beach 2017 2021 N
Vista 2022 2025 Y
1 The City of El Cajon has adopted a Sustainability Initiative with measures similar to a Climate Action Plan.
2 NA (Not Applicable) indicates no CAP, or no updated timeline has been specified in the CAP.
GHG Emissions Targets in CAPs
As noted above, CAPs establish emissions targets. This is the level of emissions the plan seeks to achieve
i SANDAG Regional Climate Action Planning Framework: TECHNICAL APPENDIX V-California Environmental Quality
Act (CEQA) and Climate Action Planning VERSION 1.1: OCTOBER 2020.
ii San Diego International Airport, July 2020. Carbon Neutrality Plan: A Roadmap for Airport Carbon Accreditation
and Beyond. Available at https://www.san.org/Portals/0/Documents/Environmental/2020-Plans/2020_Carbon-
Neutrality-Plan-min.pdf.
iii Unified Port of San Diego, 2013. Climate Action Plan. Available at
https://www.portofsandiego.org/environment/energy-sustainability/climate-action-plan.
Oct. 11, 2022 Item #12 Page 347 of 560
309
after accounting for federal and state mandates and through a range of local actions. Local jurisdictions
have some discretion when selecting target levels of emissions. One source of guidance on target
selection is CARB’s 2017 Scoping Plan. In addition to providing statewide per capita emissions targets of
no more than six metric tons CO2e per capita by 2030 and no more than two metric tons CO2e per capita
by 2050, it provides general guidance on GHG emission targets for local jurisdictions.i Another source of
guidance is GHG-related CEQA litigation, which supports the use of statewide GHG reduction targets by
jurisdictions (lead agencies) and new projects to set thresholds of significance for GHG emissions and
required mitigation. Consistency with statewide GHG emission targets is generally legally defensible and
found to be supported by substantial evidence.
Table 8.6 presents the GHG emission targets in CAPs in the San Diego region, which include both per
capita targets and mass emission reductions that are expressed as a percentage reduction below a
baseline year. La Mesa, Oceanside, and Santee provided targets both in terms of per capita and mass
emissions levels. Escondido, Oceanside, and Santee have targets for multiple years.
Table 8.6 Adopted CAP GHG Emissions Targets
Jurisdiction Baseline Year Target (per capita, % below baseline year1) Target Year
Carlsbad 2012 52% 2035
Chula Vista NA 6 MT/person 2030
Coronado 2016 39% 2030
County, SD NA NA NA
Del Mar 2012 50% 2035
El Cajon 2012 42% 2030
Encinitas 2012 44% 2030
Escondido 2012 42%
52%
2030
2035
Imperial Beach 2012 42% 2030
La Mesa 2010 3.5 MT/person, 53% 2035
Lemon Grove 2012 42% 2030
National City 2005/2006 15% 2020
Oceanside 2013 4 MT/person, 25%
3 MT/person, 42%
2030
2040
Poway NA NA NA
San Diego 2010 50% 2035
San Marcos 2012 42% 2030
Santee 2005 3.8 MT/person, 40%
1.27 MT/person, 49%
2030
2035
Solana Beach 2010 50% 2035
Vista 2012 42% 2030
1 Note: the Draft CARB 2022 Scoping Plan excludes per capita targets.
i CARB 2017 California’s 2017 Climate Change Scoping Plan: The strategy for achieving California’s 2030 greenhouse gas target.
Available at https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/scoping_plan_2017.pdf; Note: CARB’s proposed
2022 Scoping Plan excludes per capital targets, See CARB Draft 2022 Scoping Plan, Appendix D Local Actions, May 2022.
Available at: https://ww2.arb.ca.gov/sites/default/files/2022-05/2022-draft-sp-appendix-d-local-actions_0.pdf .
Oct. 11, 2022 Item #12 Page 348 of 560
310
Net Zero GHG Emissions Targets
No adopted CAP has a net zero GHG emissions target. The City of San Diego is the first local jurisdiction
in the San Diego region to propose a 2035 net zero GHG emissions target in its pending 2022 CAP
update.i Several other cities in California have adopted such targets, including the Cities of San Jose,ii
Irvine,iii and Santa Barbara.iv
8.3.4 CAP Measure Frequency and GHG Impacts
This section summarizes the findings of an analysis to determine on average how frequently categories
of GHG reduction measures are included in adopted and pending CAPs and the GHG impact of those
categories. The findings presented here are broken down by decarbonization pathway.
GHG Contribution by Decarbonization Pathways and Other Categories
Figure 8.4 shows how reductions from local policy efforts in the decarbonization pathways (e.g.,
decarbonize buildings) align with emission sources (e.g., transportation and electricity). For example,
many CAPs rely on measures to decarbonize the electricity supply for a majority of their emissions
reductions; however, the regional inventory shows that a significant majority (44%) of emissions come
from the transportation sector. This signals a potential need — and opportunity — for more local
policies that decarbonizes the transportation sector.
Figure 8.4 Average Contribution to Local GHG Reduction in Adopted and Pending CAPs by Decarbonization
Pathway (left) and San Diego Regional GHG Inventory (right)
i City of San Diego, November 2021. Draft City of San Diego Climate Action Plan: Our Climate, Our Future. Available
at https://www.sandiego.gov/sites/default/files/climate_action_plan_draft.pdf.
ii Maggie Angst, San Jose sets a new goal to become the largest U.S. City to go carbon neutral by 2030. San Jose
Mercury News. November 8, 2021. See also http://sanjose.legistar.com/gateway.aspx?M=F&ID=3fe2ff5e-c5ff-
4573-81ff-7bf3aaf30e98.pdf.
iii City of Irvine Resolution No. 21-50 adopted on August 10, 2021. Available at
https://legacy.cityofirvine.org/civica/filebank/blobdload.asp?BlobID=33611. iv See City of Santa Barbara Sustainability and Resilience Website at
https://sustainability.santabarbaraca.gov/carbon-neutrality/.
Oct. 11, 2022 Item #12 Page 349 of 560
311
Figure 8.5 shows the breakdown of local CAP GHG reductions across decarbonization pathways for the
year 2035.i While there is significant variability across the 17 CAPs shown here, on average, reductions
from decarbonizing the electricity supply (42%) and decarbonizing transportation (30%) account for
most local GHG reductions in CAPs. On average, measures associated with decarbonizing buildings
account for about 9% of total local CAP reductions, and 1% are from measures related to natural climate
solutions. The remaining 18% come from other measures, such as solid waste reduction and water
conservation.
Figure 8.5 Contribution to GHG Reductions by Policy Category (2035).
Figure 8.6 further breaks down local CAP measures into more specific policy categories. It shows both
the number of CAPs with at least one related measure and the average contribution of related measures
toward the local GHG reduction. All 17 adopted and pending CAPs have measures related to increasing
the supply of carbon-free electricity from the grid, typically through CCA programs. On average, these
measures contribute more than one-third of the reductions from local measures. By contrast, measures
related to customer-side energy projects, like rooftop solar, contribute an average of about 10% to local
CAP reductions. This is because much of the reductions associated with customer side solar projects
derive from state policies and general market uptake. All 17 CAPs have measures related to energy
efficiency that contribute on average 8% to local CAP reductions. Only 7 CAPs had measures related to
building electrification, a central strategy in the overall decarbonization strategy, with minimal GHG
reductions. Of the transportation related CAP measures, those to increase use of alternative fuels,
including electric vehicles and charging infrastructure, contribute on average 16% to local CAP
reductions. Those related to reducing vehicle miles traveled represent about 12% of local reductions.
Other policy categories represent relatively minimal GHG reductions in comparison. While most CAPs
have measures related to carbon removal, mostly urban tree planting, they represent about 1% of local
CAP reductions.
i Values in figure represent the estimated or extrapolated GHG reductions in the year 2035 to provide a better
comparison across CAPs. Not all jurisdictions include 2035 as a target year and extrapolated values may not perfectly align with how reductions are calculated in those CAPs. Nevertheless, this figure provides a
representative look at how reductions are spread across decarbonization pathways within each CAP.
Oct. 11, 2022 Item #12 Page 350 of 560
312
Figure 8.6 Summary of Adopted and Pending CAP Measures in Decarbonization Pathways.
More detailed breakdowns by policy subcategory and implementation mechanism are provided in the
sections below that address each building decarbonization pathway.
8.3.5 Social Equity in Climate Action Plans
EPIC completed a preliminary review of adopted and pending CAPs to determine whether and how
social equity factors are considered. This section briefly summarizes findings from this review and
presents opportunities for additional local action and regional collaboration.
Summary of Key Findings
• Inclusion of equity in adopted CAPs is limited, inconsistent, and lacks specificity.
• It appears that the City of San Diego draft 2022 CAP update has the most comprehensive
integration of social equity into a CAP in the San Diego region, including targeted outreach to
communities of concern, equity-focused selection criteria for CAP measures, and an air quality
section to address local emissions of criteria pollutants.
• There is an opportunity to improve integration of equity considerations when CAPs are updated.
• Equity can be integrated across the entire climate action planning cycle. SANDAG’s ReCAP
Framework could be expanded to include guidance for integrating equity considerations into
CAPs.
• Regional programs and collaboration could support the development of regional indicators,
guidance, and regular reporting on climate-related equity topics. For example, a Regional
Climate Equity Collaborative or Working Group could serve to educate regional leaders and
collect stakeholder input.
Defining Social Equity
Most CAPs in the San Diego region do not clearly define social equity. The City of San Diego draft 2022
Oct. 11, 2022 Item #12 Page 351 of 560
313
CAP update defines and provides approaches to address social equity in the context of climate planning.
It states that “[c]limate equity requires addressing historic inequities suffered by people of color,
allowing everyone to fairly share the same benefits and burdens from climate solutions and attain full
and equal access to opportunities regardless of one’s background and identify.”i
Other definitions of social equity exist. As an example, the Urban Sustainability Directors Network has
defined equity in the sustainability context to include the following:ii
• Procedural Equity – Inclusive, accessible, authentic engagement and representation in processes
to develop or implement sustainability programs and policies;
• Distributional Equity – Sustainability programs and policies result in fair distribution of benefits
and burdens across all segments of a community, prioritizing those with the highest need;
• Structural Equity – Sustainability decision makers institutionalize accountability; decisions are
made with a recognition of the historical, cultural, and institutional dynamics and structures that
have routinely advantaged privileged groups in society and resulted in chronic, cumulative
disadvantage for subordinated groups;
• Transgenerational Equity – Sustainability decisions consider generational impacts and don’t
result in unfair burdens on future generations.
A similar definition is used in a regional adaptation planning guidance document in the San Diego
region.iii
Communities of Concern
The State of California has created various definitions of communities related to social equity through
statute. SB 535 (2012) defines disadvantaged communities (DAC) and directed the California
Environmental Protection Agency (CalEPA) to define and identify DACs for investment opportunities and
allocate funds to their benefit. As part of SB 535 (2012), the CalEPA identified low-income and highly
polluted geographical areas, now available through CalEnviroScreen. AB 1550 (2016) created an
additional income-related definition. It defines low-income households as those at or below 80% of
state median income (SMI) or below a threshold identified by the California Department of Housing and
Community Development (HCD). AB 1550 (2016) also identifies low-income communities; however,
analysis of low-income communities would only help to identify where concentrated populations of low-
income residences are within an unincorporated county, not how many households qualify.
In the context of electricity and natural gas policy, the CPUC often includes within the definition of low-
income household “residential customers eligible for California Alternate Rates for Energy (CARE) and
the Family Electric Rates Assistance (FERA) programs, resident-owners of single-family homes in
disadvantaged communities (as defined in Decision (D.) 18-06-0127), or residential customers who live
in California Indian Country (as defined in D.20-12-003)… .”iv
For our purposes here and throughout this chapter, we will use the term “communities of concern” as
i City of San Diego Climate Action Plan: Our Climate, Our Future. Downloaded June 8, 2022 from
https://www.sandiego.gov/sustainability/climate-action-plan.
ii Angela Park, 2014. Equity in Sustainability: An Equity Scan of Local Government Sustainability Programs. Urban
Sustainability Directors Network. Available at http://usdn.org/public/Innovation.html#EquityScan.
iii San Diego Regional Climate Collaborative and San Diego Association of Governments, "Equity- First Approach to
Climate Adaptation" (2021). San Diego Regional Climate Collaborative. 15. https://digital.sandiego.edu/npi-
sdclimate/15.
iv California Public Utilities Commission. Proposed Decision Revising Net Energy Metering Tariff and Subtariffs in
Rulemaking 20-08-020, 12-13-21.
Oct. 11, 2022 Item #12 Page 352 of 560
314
adopted by the City of San Diego in their Climate Equity Index,i understanding that there are many other
terms used.
Local Commitments to Social Equity in CAPs
Although limited, CAPs in the San Diego region integrate social equity considerations in several ways,
including gathering stakeholder input from communities of concern, having a separate section or
chapter on equity, designating equity as a co-benefit, and integrating equity into measure language and
implementation plans.
• Stakeholder Input – Given the relatively limited integration of social equity considerations in
CAPs in the San Diego region, it appears that stakeholder outreach to communities of concern
also was limited. Not all CAPs describe the outreach process used, so it can be difficult to
understand the outreach completed. The City of San Diego’s draft 2022 CAP update released in
November 2021 and intended to be adopted in Summer 2022 includes a detailed explanation
about the process undertaken to solicit and receive stakeholder input, particularly from
communities of concern.ii
• CAP Section or Chapter on Equity – Some CAPs include a separate section or chapter to discuss
how the CAP incorporates and responds to social equity concerns. The City of Del Mar has a
separate chapter on social equity that briefly describes local and regional strategies to ensure
benefits accrue to all residents. Examples include using CCA revenues to subsidize energy
improvements for low-income and senior residents and ensuring that outreach related to CAP
implementation is designed to reach all residents.iii Similarly, the City of San Diego CAP adopted
in 2015 includes a chapter on social equity and job creation, which focuses mainly on job
creation but seeks to prioritize programs and actions in communities of concern. The adopted
San Diego CAP also includes regular monitoring on CAP-related job creation and social equity
impacts of CAP implementation.iv
• Equity as a Co-Benefit – Several cities designate social equity impacts as a co-benefit to identify
measures that would benefit communities of concern, though there is no specificity on how this
would occur and the steps needed to realize positive impacts. In the context of CAPs, a co-
benefit is a positive outcome that results from activity to reduce GHG emissions. For example,
installing solar photovoltaics on a home will reduce emissions from electricity use but may also
reduce utility bills. The energy cost savings and potential return on investment would be
considered co-benefits. This is different from ensuring that CAP measures and policies are
designed and implemented in ways that encourage social equity. For example, CAPs could
consider how to make electric vehicle use or solar photovoltaic installation more equitable
across all communities and how programs to require or encourage solar would affect
communities of concern.
• Integrating Equity into CAP GHG Measures – Few CAPs integrate equity into the development
and implementation of CAP measures. The City of Escondido includes equity considerations as a
performance metric for certain measures and seeks to develop a Clean Energy Equity Plan and
identify priority investment neighborhoods (PIN) to help prioritize implementation in
communities of concern. The CAP states that “[w]here applicable, GHG reduction measures will
i City of San Diego, 2019, San Diego’s Climate Equity Index Report. Available at
https://www.sandiego.gov/sites/default/files/2019_climate_equity_index_report.pdf.
ii City of San Diego, November 2021. Draft City of San Diego Climate Action Plan: Our Climate, Our Future. Available
at https://www.sandiego.gov/sites/default/files/climate_action_plan_draft.pdf. iii City of Del Mar, June 2016. Del Mar Climate Action Plan.
iv City of San Diego, December 2015, City of San Diego Climate Action Plan.
Oct. 11, 2022 Item #12 Page 353 of 560
315
be targeted and prioritized for funding and implementation in priority investment
neighborhoods. These are measures that will improve quality of life, housing stock, health, and
quality of life for residents in vulnerable neighborhoods.”i The Escondido CAP includes
recommended priority neighborhoods based on CalEnviroScreen. The City of San Diego draft
2022 CAP update used climate equity selection criteria to evaluate CAP measures, including the
following:
o Community benefits & burdens: Can it be implemented in a way that distributes
benefits and burdens equitably?
o Community empowerment: Can it be implemented in a way to increase community
capacity or level of engagement?
o Addresses historical disparity: Can it address historical disparities in Communities of
Concern, i.e., lack of sidewalks or low air quality?ii
• Considering Equity in Implementation Sections or Plans – Few CAPs considered equity in the
implementation section of CAPs or separate plans. Cities with stand-alone implementation plans
include high-level consideration of equity but do not include specifics. Some CAPs also mention
social equity in the context of adaptation measures, which we did not consider here because the
focus of the Regional Decarbonization Framework is reducing GHG emissions. As noted above,
City of San Diego integrated implementation considerations when evaluating CAP measures.
Opportunity for Local Jurisdictions to Integrate Social Equity into CAPs
Given the limited consideration of equity in CAPs in the San Diego region, an opportunity exists to
integrate social equity across the CAP planning cycle as described in SANDAG’s Regional Climate Action
Planning (ReCAP) Framework.iii In general, this cycle includes developing and maintaining the CAP,
implementing CAP measures, monitoring and reporting progress, and identifying equity as a cross-
cutting consideration that can apply across all aspects of climate planning. The following sections briefly
discuss how equity could be integrated into each of the main steps in the CAP planning cycle.
Develop and Maintain CAP
This step includes developing a baseline GHG inventory, projecting emissions, setting emissions targets,
and developing and estimating the GHG impacts of CAP measures. Social equity considerations could be
integrated into this step in the following ways.
• Conduct Stakeholder Outreach – While it is true that stakeholder engagement cuts across all
aspects of the climate planning cycle, soliciting and receiving stakeholder input at this initial
step, particularly from communities of concern, could help to inform subsequent steps in the
process.
• Collect and Analyze Data Related to Social Equity – Historically, data related to equity has not
been readily available, particularly as related to CAP development. In recent years, a focus on
equity has expanded access to data and tools related to equity. Examples include the Climate
Equity Index developed by the Cities of Chula Vista and San Diego. Data included in these
indexes can provide context for CAP development. In addition, a specific analysis may be needed
to develop CAP measures, targets for activity levels, and performance metrics related to
i City of Escondido, March 2021. City of Escondido Climate Action Plan.
ii City of San Diego Climate Action Plan: Our Climate, Our Future. Downloaded June 8, 2022 from
https://www.sandiego.gov/sustainability/climate-action-plan.
iii SANDAG, 2020. Regional Climate Action Planning (ReCAP) Framework Summary.
Oct. 11, 2022 Item #12 Page 354 of 560
316
communities of concern. Other analyses could inform aspects of CAP development, including
benefit cost analysis, job impacts analysis, etc.
• Develop Specific Equity-Focused Targets – Another option is to integrate equity into each
measure of the CAP and to develop specific performance indicators that can be monitored over
time. For example, many CAPs include measures to increase the number or coverage of trees.
Developing a specific goal for the number or percentage of trees planted in communities of
concern could help to guide implementation activities. As noted above, detailed analysis may be
needed to determine the best way to direct funding and activity to ensure equitable outcomes.
• Consider Equity Implications of CAP Measures – Local jurisdictions also could consider whether
and how GHG reduction measures could disproportionately affect communities of concern. For
example, the potential increase in utility costs due to building electrification or inequitable
adoption of rooftop solar. The specific equity implications of decarbonizing transportation,
buildings, and the electricity supply are discussed further in the sections below (8.5 through
8.7).
Implement CAP Measures
Most CAPs include a section that provides a high-level summary of how measures will be implemented.
This typically includes a timeline, responsible departments, and sometimes also cost implications. Some
jurisdictions also develop a separate implementation plan. The following actions could help to integrate
social equity into CAP implementation.
• Develop Equity-Focused Implementation Strategies – CAPs could include implementation
strategies that seek to specifically address equity concerns and that prioritize activities in
communities of concern. Several options exist to integrate equity-focused implementation
strategies, including adding specific strategies to the implementation section in a CAP, including
a separate section within the CAP focused on the equity aspects of implementation, and/or
developing a separate implementation plan – or section of plan – that focuses on equity.
• Equity Related Staff Positions in Local Jurisdictions – Several jurisdictions have full-time staff
positions related to equity and environmental justice. These positions can support and monitor
the equity aspects of CAPs. To the extent feasible, other local jurisdictions could create a similar
position.
Monitor and Report Progress
The final step in the climate planning cycle, monitoring and reporting progress, helps local jurisdictions
understand whether emissions targets have been reached and the extent to which CAP measures have
been implemented. This provides an opportunity to track specific equity-focused performance indicators
included in the CAP or to monitor related implementation strategies. In addition to CAP-related
indicators, it also is possible to monitor other equity indicators like energy poverty that might help to
track the overall progress of social equity regardless of whether they are connected to CAP measures.
Opportunity for Regional Collaboration
In addition to the opportunities for local jurisdictions to integrate equity, there are opportunities for
regional collaboration.
Guidance for Integrating Equity into CAPs
Given the relative lack of information to help local jurisdictions address equity in CAPs, there is an
opportunity to develop a guidance document for integrating equity into CAP. For example, developing
an additional element of the ReCAP Framework could provide customizable options to encourage
Oct. 11, 2022 Item #12 Page 355 of 560
317
consistency across jurisdictions. Figure 8.7 illustrates how equity could be integrated into all aspects of
the climate action planning cycle.
Figure 8.7 Illustrative Example of Integrating Equity Across the Climate Action Planning Cycle.
Regional Support for Smaller Jurisdictions
As with climate planning generally, there may be a need for a regional program to provide equity-
related support to smaller jurisdictions that may lack the resources to hire a part- or full-time position
dedicated to equity. A model for this approach is SANDAG’s Energy Roadmap Program, which provided
climate planning support to the smallest 16 cities in the region. SANDAG is still providing some support
to these cities, including GHG inventory development and monitoring and reporting support.i
Develop Regional Equity Indicators
While some local governments have collected and analyzed data related to social equity and climate,
including climate equity indexes, there is no single clearinghouse of equity indicators in the San Diego
region. A regional approach to collect data, develop equity indicators, and publicly display and report
information could help to facilitate integration of equity into CAPs. For example, a regional database
that includes indicators at the census tract level could be displayed geospatially in a public data portal,
similar to SANDAG’s Climate Action Data Portal. Such a tool would allow for regional or subregional
analysis but also enable analysis on a jurisdictional or community level. This could help to identify gaps
and help to allocate resources. For example, while each city has goals to plan trees, a regional analysis
would help to identify the areas with the lowest tree cover that coincide with other equity indicators like
income. A regional program, potentially in addition to CAP efforts, could be developed to direct tree
planting activities into these high-priority areas.
State of Regional Climate Equity Report
Data from a regional database of equity indicators could be used to regularly report on the state of
equity as it relates to climate action planning. The Equinox Project’s Quality of Life Dashboardii provides
an example of regular reporting on a suite of indicators.
i See ReCAP Snapshots and Climate Data Portal available at https://climatedata.sandag.org/.
ii Equinox Projects’ Quality of Life Dashboard. Non-Profit Institute, University of San Diego. Available at
https://www.sandiego.edu/soles/hub-nonprofit/initiatives/dashboard/.
Oct. 11, 2022 Item #12 Page 356 of 560
318
8.3.6 Limitations of the Review of CAPs and Associated Analysis
While our methods seek to minimize them, we acknowledge several limitations when analyzing local
policy commitments across CAPs, including the following.
• CAP language may be high-level and/or vague, requiring subjective judgment when categorizing
the policy into one or more groups.
• CAPs may rely on different methods and inputs (e.g., emission factors) that may change over
time or may vary based on the consultant preparing the CAP.
• Jurisdictions may not have activity in all emissions sectors (e.g., agriculture) and will
consequently not have associated policies included in their CAP.
• Some jurisdictions may implement decarbonization-related policies that are not included within
their CAP.
• Some CAP measures have, since adoption, been superseded by federal, state, and regional
requirements and/or activity (e.g., low carbon fuel standards, updated building code standards,
and SB 375).
• CAP target years do not consistently align and, for some CAPs, data on GHG reductions in
interim years may be limited.
8.4 Scenario Analysis of GHG Impacts from Adopted CAPs in the San Diego
Region
This section presents the results of analysis to estimate the impact of the GHG commitments in adopted
and pending CAPs and a scenario to show the impact of applying the most aggressive GHG reduction
measures across the entire region. This analysis focuses on a subset of GHG emissions, namely, on-road
transportation, electricity, and natural gas. These emissions categories are consistent with the four
decarbonization pathways included in the other chapters of the Technical Report. While the review of
CAPs presented above in Section 8.3 allows for comparison of GHG reductions across CAPs, the scenario
analysis presented here estimates the combined GHG impacts of CAPs.
8.4.1 Summary of Findings
• Commitments in adopted CAPs (Adopted CAP Commitment Scenario) for transportation,
electricity, and natural gas GHG reductions contribute a relatively small portion of the total
reductions needed to reach net zero GHG emissions in 2035, about 2 MMT CO2e, which would
leave about 12 MT CO2e remaining in these categories. Including the commitments from the City
of San Diego draft 2022 CAP update in this analysis would yield GHG reductions of about 5 MMT
CO2 in 2035, leaving about 8.5 MMT CO2e remaining to be addressed.
• CAP measures that aim to increase renewable electricity to 80–100%, mainly through CCA
programs, contribute the largest GHG emissions reduction in 2035 among commitments in
adopted CAPs. Local policy actions to achieve 100% carbon-free electricity supply sooner would
lead to more cumulative GHG reductions, not important for attaining annual emission targets
but consequential to atmospheric warming and the resulting climate impacts.i
i See Riahi, K., Bertram, C., Huppmann, D. et al. Cost and attainability of meeting stringent climate targets without overshoot.
Nat. Clim. Chang. (2021). https://doi.org/10.1038/s41558-021-01215-2. See also Drouet, L., Bosetti, V., Padoan, S.A. et al. Net
zero-emission pathways reduce the physical and economic risks of climate change. Nat. Clim. Chang. (2021).
https://doi.org/10.1038/s41558-021-01218-z.
Oct. 11, 2022 Item #12 Page 357 of 560
319
• Even if the most aggressive CAP measures are applied to all jurisdictions in the region (Best
Adopted CAP Commitment Scenario), regardless of whether they have a CAP in place, significant
emissions would remain (approximately 7 MMT CO2e in 2035), mostly from natural gas
combustion and medium- and heavy-duty vehicles. This suggests that additional measures are
needed to decarbonize buildings and either electrify or use low-carbon fuels in larger vehicles.
Including the best CAP commitments from the City of San Diego draft CAP 2022 would reduce
the amount of remaining emissions to about 5 MMT CO2e in 2035.
• The largest GHG emissions reduction in the Best Adopted CAP Commitment Scenario is from
CAP measures to decarbonize transportation, such as reducing VMT by reducing parking supply
and increasing alternative commute modes.
• Even in the Best Adopted CAP Commitment Scenario, the impact of building electrification is
limited because only CAPs adopted in the last two to three years have considered and
incorporated these strategies. This improves when including the City of San Diego draft 2022
CAP update.
• Given the differences between Current Adopted CAP Commitments and the Best Adopted CAP
Commitments in all decarbonization pathways, even when including the City of San Diego draft
2022 CAP update, there is an opportunity for local jurisdictions to strengthen CAP measures to
reduce additional GHG emissions.
• Under the Natural Climate Solutions Pathway, existing CAP measures only include urban tree
planting, indicating potential to expand removal and storage or other natural climate solutions
in future CAP updates.
8.4.2 Scenario Analysis Approach
The analysis presented here includes the same CAPs and policy organizational structure as described
above for the review of CAPs in Section 8.3. For this analysis, we developed three GHG emissions
scenarios.
Regionwide Reference Scenario without CAP Commitments
The first step was to develop an estimate of regionwide GHG emissions based on a projection of
relevant activity (e.g., electricity use or VMT) without the impact of any CAP commitments. This
scenario, which accounts for the emission impacts of state and federal policies in place in 2021 but not
of local CAP measures, shows emissions from electricity, natural gas, and on-road transportation. These
emissions categories represent the decarbonization pathways evaluated in the other chapters of the
report. The resulting emissions represent the reference scenario for the analysis. For the on-road
transportation category, we used the light-duty vehicle (LDV) and heavy-duty vehicle (HDV) miles driven
and GHG emissions from the 2021 SANDAG Regional Plan.i For electricity and natural gas categories, we
projected electricity and natural gas demand-based California Energy Commission’s mid-case 2020–2030
energy demand forecast for SDG&E planning area.
Adopted CAP Commitment Scenario
As noted above, simply summing GHG reductions reported in CAPs can be problematic potential
differences in emission sources, measures included, methods used to estimate GHG impacts, and target
type and year. For example, recent CAPs may assume more efficient vehicles and lower vehicle emission
rates in GHG calculations, so reducing one vehicle mile would result in lower GHG reductions compared
i San Diego Association of Governments (SANDAG). 2021. San Diego Forward the Regional Plan. Appendix X: 2016 Greenhouse
Gas Emissions Inventory and Projections for the San Diego Region. For LDV emissions, the GHG reduction from SANDAG.
Oct. 11, 2022 Item #12 Page 358 of 560
320
to older CAPs. Another example is how GHG reductions from federal and State policies are included in
CAPs. Measures to encourage or mandate residential solar PV systems were considered a local CAP
measure until 2019 when it became a state mandate.
To avoid the potential shortcomings of summing CAP reductions, we developed a scenario to estimate
the emissions impact of GHG reduction measures in the adopted CAPs considered here. We evaluated
the 17 adopted CAPs and summed the change in activity levels from CAP measures, such as electricity
avoided in kWh due to energy retrofit measures and combustion vehicle miles replaced by electric
vehicle miles (e-VMT) due to electric vehicle (EV) measures. We then calculated the GHG impact of the
aggregated level of activity using a common calculation method. In this way, we avoided the challenge
of methodological or data differences across CAPs. Once completed for all policy subcategories listed in
Table 8.3 above for which quantified CAP measures existed, the resulting GHG emissions impacts
represent GHG impact of all local CAP commitments. Results can be seen as the current regionwide
commitment from CAPs to reduce GHG emissions.
Best Adopted CAP Commitment Scenario
To estimate the impacts of more aggressive measures to reduce emissions, we developed a Best
Adopted CAP Commitment Scenario. We identified the most aggressive measures in each policy
subcategory, regardless of the jurisdiction size or CAP adoption year. For example, under the
Decarbonize Transportation pathway Parking Reduction policy subcategory, the most aggressive
measure out of the measures in the 17 CAPs is Lemon Grove’s CAP Measure T-11 to reduce residential
parking requirements near light rail transit stations by 50%. The complete list of the best adopted CAP
commitments is provided in Appendix 8.A. Since we only included quantified CAP measures, and not all
policy subcategories in Table 8.3 have quantifiable measures associated with them, not all subcategories
are represented in this scenario. Some subcategories are broken down further, because some CAP
measures only contribute to portions of the subcategories. For example, under the Bike, Walk &
Complete Streets subcategory, the most aggressive complete streets policy is from the County of San
Diego CAP, while the most aggressive bicycle infrastructure improvement policy is from the Imperial
Beach CAP.
Once identified, we applied the most aggressive CAP policy to all jurisdictions in the region, regardless of
whether it has an adopted or pending CAP. The result is the Best Adopted CAP Commitment Scenario.
Using the Parking Reduction subcategory as an example, the 50% parking reduction near light rail transit
is applied to all housing units in the 2021 SANDAG Regional Plan Mobility Hubs. The parking reduction
leads to household VMT reductions and associated GHG emissions.
The difference between the Adopted CAP Commitment Scenario and the Best Adopted CAP
Commitment Scenario shows the GHG reductions that would result if all jurisdictions adopted the “best-
in-class” approach. This gap helps to identify opportunities for further action by local jurisdictions. It is
important to recognize that not all jurisdictions may be able to achieve the most aggressive level of
activity for structural reasons, like land use and settlement patterns. Nonetheless, this approach
provides an upper limit of what could be achieved with current policies in CAPs.
8.4.3 Results of Scenario Analysis
Figure 8.8 presents the estimated projected GHG emissions in each scenario. The top thick black line
represents the regionwide Reference Scenario without CAP commitments, which includes the impacts of
state and federal policies in place in 2021 but does not include the GHG impact of local CAP measures.
Oct. 11, 2022 Item #12 Page 359 of 560
321
The upper blue dashed line represents the level of regional emissions after the impacts of adopted CAP
commitments are considered. The bottom blue dashed line represents the Best Adopted CAP
Commitment Scenario. The GHG reductions from existing CAP commitments are relatively small, about
1.9 MMT CO2e in 2035. The smaller impact over time is in part because CAPs typically have a planning
horizon to 2030 or 2035 and also because of the impact of California’s carbon-free electricity
requirement. Even accounting for the GHG impacts of the Best Adopted CAP Commitment Scenario,
approximately 7 MMT CO2e would remain in 2035.
Figure 8.8 Projected Total GHG Emissions in Each Scenario of the Adopted CAP Scenario Analysis
Figure 8.9 shows the GHG impacts of CAP commitments for each decarbonization pathway in both
scenarios. In the Adopted CAP Commitment Scenario, decarbonizing the electricity supply, mainly
through committing to high (80%–100%) renewable and carbon-free electricity, provides the most GHG
reduction among the four pathways. The impact of the Decarbonize Electricity Supply Pathway increases
in the short run but is zero after 2045 because all electric service providers must provide 100%
renewable or carbon-free electricity in 2045. Achieving 100% renewable electricity earlier than 2045
would yield higher cumulative reductions from this pathway (i.e., area of the red wedge) but would not
increase the reduction in 2045 (i.e., the height of the red wedge in 2045). While higher cumulative
reductions do not necessarily help local jurisdictions attain annual CAP emissions targets, they can affect
atmospheric warming. Measures related to electrifying buildings and carbon removal and storage were
not often included in CAPs until recently; therefore, these Pathways have minimal impact in the
Adopted CAP Commitment Scenario, suggesting a need for additional policies. In the Best Adopted CAP
Commitment Scenario, in addition to the Decarbonize Electricity Supply Pathway, the Decarbonize
Transportation Pathway provides significant GHG reductions. Building decarbonization also reduces
more GHG emissions, but still less than what would be needed to meet the level of building
decarbonization contemplated in Chapter 4.
The total GHG emissions shown here include only the emissions from on-road transportation, electricity
Oct. 11, 2022 Item #12 Page 360 of 560
322
and natural gas, not all GHG emitting activities in the region. Even with the Best Adopted CAP
Commitment Scenario and carbon removal and storage, approximately 7 MMT CO2e would remain. The
remaining emissions are mainly from natural gas and HDV, as CAP measures generally focus on
increasing renewable electricity and reducing miles driven LDVs. The remaining emissions in the San
Diego region, including other GHG generating activities, after accounting for reductions in the Adopted
CAP Commitment and Best Adopted CAP Commitment Scenarios are shown in Figure 8.10.
Figure 8.9 Emissions Reductions from Each Pathway under Adopted and Best Adopted CAP Commitment Scenarios
Figure 8.10 Emissions Breakdown under Adopted and Best Adopted CAP Commitment Scenarios
Oct. 11, 2022 Item #12 Page 361 of 560
323
Scenario Analysis Results by Policy Subcategory
The impact of each category and subcategory under the Pathways in both scenarios are discussed in
detail in Section 8.5 through Section 8.8. In summary, the impact of each scenario on GHG emitting
activity level (electricity use, natural gas, and VMT) is shown in Table 8.7. For all decarbonization
pathways, the Best Adopted CAP Commitment Scenario reduces significantly more GHG emissions than
the Adopted CAP Commitment Scenario, indicating the potential for jurisdictions to expand CAP
measures in the next round of CAP updates.
Table 8.7 GHG Emissions Impact of Adopted and Best Adopted CAP Commitment Scenarios
Activity Pathway: Policy
Category Policy Subcategory
Reduction in Activity Level
Adopted CAP
Commitment
Scenario
Best Adopted
CAP Commitment
Scenario
Electricity
Use
Decarbonize
Buildings: Energy
Efficiency
Residential Energy Retrofits 0.01% 5%
Non-residential Energy Retrofits 0.01% 5%
Residential Water Heater
Retrofits 0.0003%
2%
Non-residential Solar Water
Heater Retrofits 0.02%
Natural Gas
Use
Decarbonize
Buildings:
Electrification
Residential New-Construction
Electrification 0.1% 5%
Decarbonize
Buildings: Energy
Efficiency
Residential Energy Retrofits 0.5% 14%
Non-residential Energy Retrofits 0.3% 7%
Residential Water Heater
Retrofits 0.5%
4%
Non-residential Solar Water
Heater Retrofits 3%
VMT
Decarbonize
Transportation:
VMT Reductions
Increase Commute by Biking 1% 1%
Increase Commute by Walking 0.02% 0.3%
Increase Safe Routes to School 0.001% 0.03%
Complete Streets 0.01% 0.13%
Increase Commute by Mass
Transit + Intra-city Shuttle 3% 4%
Reduce Parking 0.2% 13%
Commute TDM Strategies 0.4% 4%
Increase Commute by Vanpool 0.03% 19%
Under the Decarbonize Building Pathway, energy efficiency-related CAP measures mainly reduce natural
gas use and associated GHG emissions, with residential and non-residential energy retrofit measures
contributing the most. This is because the best adopted CAP commitment under residential and non-
residential energy retrofits are from the City of Carlsbad CAP Measures D through F, which aim to
reduce energy use by 50% in 30% of existing homes, and by 40% in 30% of existing commercial spaces.
Water heater retrofit measures provide 7% natural gas reduction under the Best Adopted CAP
Commitment Scenario, but depending on the specific provisions, this type of measure can face federal
Oct. 11, 2022 Item #12 Page 362 of 560
324
preemption issues and could be replaced by electrification measures or other measures to reduce
natural gas use in existing buildings, as discussed in Section 8.6.
Under the Decarbonize Transportation Pathway, increasing commute by vanpool and reducing parking
subcategory reduce the most VMT in the current and best adopted CAP commitment scenario,
indicating the potential to expand these measures in CAPs. For reduced parking measures, the best
adopted CAP commitment is from Lemon Grove’s CAP Measure T-11, which aims to reduce residential
parking requirements near trolley stations by 50%. Applying this requirement to all units in the SANDAG
2021 Regional Plan Mobility Hub would lead to an estimated 13% VMT reduction regionwide. For
increasing commute by vanpool subcategory, the best adopted CAP commitment is from Solana Beach
CAP Measure T-2, which aims to have an additional 19% of the labor force vanpool to work.
The VMT reduction from increasing commute by active transportation modes (i.e., walking and
bicycling) and increasing the Safe Routes to School program are limited in both existing and best
adopted CAP commitment scenarios. This could be because the miles avoided from walking or bicycling
to work are low (average 1 mile per one-way trip for walking and 5 miles per one-way trip for bicycling),
or existing CAPs have not captured all opportunities with the jurisdictions to improve pedestrian and
bicycling infrastructure. The VMT reduction from increasing commute by mass transit and intra-city
shuttle in both scenarios is similar. The opportunity for intra-city shuttles is only limited to jurisdictions
without a robust public transit system.
8.4.4 Limitations of Adopted CAP Scenario Analysis
Only GHG Emitting Activities Related to Decarbonization Pathways are Considered
This analysis is limited to the GHG emissions and CAP measures related to four decarbonization
pathways included in the other chapters of the report. CAP measures to reduce emissions from solid
waste, which can be significant, are not included. Additional analysis would be needed to determine the
GHG impacts of adopted CAP commitments and the application of best adopted CAP commitments in
other GHG emissions categories (e.g., solid waste).
All Jurisdictions May Not Be Able to Achieve the Best Adopted CAP Commitment
It is important to recognize that not all jurisdictions may be able to achieve the most aggressive level of
activity included in the Best Adopted CAP Commitment Scenario due to structural reasons, like land use
and building patterns, and political acceptance. Nonetheless, this approach provides an estimate of the
upper limit of GHG reductions from measures in adopted CAPs in the region. Also, because levels of
remaining emissions after accounting for the best adopted CAP commitments are significant, this
scenario helps to put into perspective the level of activity that would be needed to reach deep
decarbonization targets.
The Best Adopted CAP Commitment Scenario is Not a Best-Case Scenario
The Best Adopted CAP Commitment Scenario presented here is not a best-case scenario analysis
because we limited our review to CAP commitments. As such, we did not consider other local policies
with GHG reduction potential not included in CAPs. Also, we did not compare either the resulting
emissions from the Adopted CAP Commitment or Best Adopted CAP Commitment Scenario to the
results of the Evolved Energy modeling effort due to their different approaches. Also, the level of activity
that results from the Best Adopted CAP Commitment Scenario is less than what would be needed to
achieve the deep decarbonization contemplated in the modeling and other chapters of the report.
Oct. 11, 2022 Item #12 Page 363 of 560
325
Building Electrification and Carbon Removal and Storage Measures are limited in
Adopted CAPs
Even in the Best Adopted CAP Commitment Scenario, the impact of electrification and natural climate
solutions is minimal, because only CAPs adopted in recent two to three years have considered and
incorporated related strategies. For example, we included the City of San Diego’s 2015 CAP in the
analysis, which has limited building decarbonization measures. The City of San Diego’s draft 2022 CAP
update, released in November 2021 and expected to be adopted in Summer 2022, which is not included
in this analysis, has a measure to phase-out 90% of natural gas citywide through building
decarbonization. The impacts of applying this approach regionwide can be seen in the alternative
scenario presented in Section 8.4.5.
Analysis Does not Estimate Impact of Future State and Federal Policies
For this analysis, we created a Regionwide Reference Scenario without CAP Commitments, which is a
projection of future emissions that includes the impacts of state and federal policies in place as of 2021.
It also considers forecasts of activities like the expected increase in rooftop solar systems. However, this
projection does not consider future changes in state or federal policies, which may lower projected
emissions in the region. Additional analysis would be needed to develop a future State and federal
policy scenario.
CAP Measures May Not Represent What is Implemented
CAPs are plans, and the measures included may not represent what is actually implemented over time.
Nonetheless, CAPs represent the reasonable and feasible commitments that local jurisdictions are
willing to commit to. So the Adopted CAP Commitment Scenario can be seen as the level of GHG
reductions that regional leaders are currently willing to commit to. The Best Adopted CAP Scenario can
be seen as an idealized version of regional CAP commitments. Implementation is a key part of the
climate action planning cycle, but our analysis shows that even the Best Adopted CAP Commitment
Scenario for the four decarbonization pathways included here would still result in significant remaining
emissions.
CAPs are typically monitored regularly, sometimes annually, and updated typically every five years. This
process provides opportunities to evaluate implementation status. While our analysis does not include a
systematic review of what has been implemented or of specific levels of activity (e.g., vehicle miles
traveled or percentage renewable electricity supply), where possible we included information about
policies and measures that are being implemented.
8.4.5 Alternative Scenarios with the City of San Diego Draft 2022 CAP Update
The City of San Diego draft CAP 2022 update, which was released for public review in November 2021
and is anticipated to be adopted in Summer 2022, is the only draft CAP pending adoption in the region
as of July 2022. The City of San Diego draft CAP update has an ambitious overall target of net-zero
emissions by 2035 and ambitious measures, including phasing out of 45% of natural gas usage from
existing buildings by 2030 and 90% by 2035, and achieving a 50% walking, cycling, and transit mode
share of all San Diego resident trips.
Due to the scale of potential impact on GHG reductions in the region from the draft City of San Diego
2022 CAP update, two additional alternative scenarios were developed beyond the scenarios described
above: (1) a CAP Commitment Scenario with the Draft City of San Diego 2022 CAP, which includes all
Oct. 11, 2022 Item #12 Page 364 of 560
326
adopted CAPs and replaces the CAP measures from the adopted San Diego 2015 CAP with the measures
from draft City of San Diego 2022 CAP update; and (2) a Best CAP Commitment Scenario with the Draft
City of San Diego 2022 CAP, which re-evaluates the best commitments to include the those in the City of
San Diego draft CAP.
Results of Alternative Scenarios
The results from two alternative scenarios are shown below in Figure 8.11 along with those from the
analysis presented above. The solid green line represents the CAP Commitment Scenario with the City of
San Diego draft 2022 CAP update; and the dashed green line represents the Best CAP Commitment
Scenario with the draft City of San Diego 2022 CAP.
The GHG reductions from CAP commitments that include the draft City of San Diego 2022 CAP would be
about 5.2 MMT CO2e in 2035 (solid green line), compared with the 1.9 MMT CO2e reduction from the
Adopted CAP Commitment Scenario (with the 2015 adopted City of San Diego CAP) (solid blue line). The
additional reduction is mainly due to the new and more aggressive building decarbonization and VMT
reduction measures in the draft City of San Diego 2022 CAP. On building decarbonization, the draft 2022
CAP commits to decarbonize both new and existing buildings, and municipal operations. Measure 1.1
Decarbonize Existing Buildings, alone seeks to phase out 90% of natural gas use from existing buildings
in the City of San Diego, equivalent to phasing out 54% of natural gas use regionwide. The total GHG
reductions from building sector measures is more than 2 MMT CO2e. On VMT reduction, the draft City of
San Diego 2022 CAP commits to achieve 50% walking, cycling, and transit mode share of all San Diego
resident trips, climate-focused land use, and the Walk from Anywhere initiative to reduce citywide
residents’ VMT. Under the CAP Commitment Scenario with the Draft San Diego 2022 CAP, these VMT
reduction measures result in 4.3 billion miles avoided (93% of all miles avoided under the VMT reduction
sub-category in this scenario), equivalent to 1.7 MMT CO2e.
Figure 8.11 Emissions Breakdown under Alternative Scenarios with Draft 2022 San Diego CAP
Oct. 11, 2022 Item #12 Page 365 of 560
327
Taking into consideration the measures in the City of San Diego draft CAP 2022 update, under the Best
CAP Commitment Scenario, approximately 5 MMT CO2e would remain in 2035, compared to the MMT 7
MMT CO2e that would remain under the Best Adopted CAP Commitment Scenario.
Despite the aggressive measures in the draft City of San Diego 2022 CAP, many of the measures
determined to be the most aggressive in the region are attributed to other cities. For example, under
the Increase Citywide Electric Vehicle Miles Driven subcategory, the best commitment is still from both
the Del Mar CAP Goal 16 and the Solana Beach CAP Measure T-1, increasing citywide electric vehicle
miles driven to 30% of total miles. The 2015 San Diego CAP does not have a measure under this
subcategory, and in the draft 2022 CAP, the 2035 target for Measure 2.3 Increase Electric Vehicle
Adoption is to reach 25% e-VMT of all light-duty VMT. In this case, the commitments from Del Mar and
Solana Beach are still the most aggressive under this subcategory.
For VMT measures, some commitments by other cities included in the Best Adopted CAP Commitment
Scenario are replaced by commitments from the draft 2022 San Diego CAP, due to the way the draft City
of San Diego 2022 CAP is structured. For example, instead of focusing on shifting commuter mode share
to walking, biking, and mass transit, the draft 2022 CAP takes a different approach to shift mode share
for all trips citywide, both commute and non-commuter trips. As a result, the previous best
commitments under the Increase Commute by Biking, Walking and Mass Transit subcategories from the
Imperial Beach and San Marcos CAPs are replaced by Measure 3.1 and 3.2 of the draft San Diego 2022
CAP. Measures from the City of San Diego draft 2022 CAP update are considered the best CAP
commitments in several other policy subcategories, including smart growth development and parking
reduction; commute TDM strategies; alternative fuel vehicles in municipal fleet; electrify new
nonresidential buildings; decarbonize existing buildings; and, retrofit/decarbonize municipal buildings. A
complete list of best CAP measures is provided in Appendix 8.A.
8.5 Decarbonize Transportation
On-road transportation accounts for about 47% of 2016 regional GHG emissions, more than any other
category. While the modeling completed for the Regional Decarbonization Framework Technical Report
focuses on accelerated adoption of ZEVs, there are other ways to reduce transportation-related
emissions. In particular, both CAPs and SANDAG’s 2021 Regional Plan (RP2021) include measures to
reduce VMT.i Our analysis of CAP transportation decarbonization measures includes VMT reduction,
system fuel use reduction, and increased alternative fuel use, including ZEV. Table 8.8 summarizes the
key takeaways from our analyses on the Decarbonizing Transportation Pathway.
i VMT reduction is also discussed in Chapter 3 of this report.
Oct. 11, 2022 Item #12 Page 366 of 560
328
Table 8.8 Summary of Key Takeaways for the Decarbonize Transportation Pathway
Policy Category Key Takeaways
VMT Reduction All adopted and pending CAPs have related measures; moderate GHG contribution;
opportunity for more urbanized cities (e.g., higher densities, parking management) to
increase access to basic services from increased transit uptake; opportunity for more
aggressive walk and bike actions; opportunities across all jurisdictions to prioritize related
social equity projects; significant opportunity to coordinate and cooperate as a region.
Fuel Use
Reduction
Half the adopted and pending CAPs have related measures; relatively low GHG
contribution because of the low activity levels; opportunity for increased fuel use reduction
through system efficiencies within jurisdictions and across the region, for example,
improved traffic management coordination across the region.
Alternative Fuel
Vehicles &
Equipment
All adopted and pending CAPs have related measures, including ZEV actions; moderate
GHG contribution due to low local uptake levels; opportunity for more local action
contingent on more local ZEV funding beyond state-based funding; opportunity for more
municipal uptake of other low carbon fuels such as renewable diesel.
8.5.1 Summary of Findings
Key Findings of Analysis
The following are key findings from the review of legal authority to act, from the review of CAPs, and the
scenario analyses of combined GHG impacts from CAPs, which include the impacts of the SANDAG
RP2021.
• Local Jurisdictions Have Broad Legal Authority to Regulate Transportation Emissions – Local
authority over transportation is rooted in land use authority over planning and development
and does not rely on delegated general law of the state or federal government. As shown in
Section 8.2, cities and counties also have delegated and derived powers, taxation powers, and
police powersi which can be limited by state and federal laws, but can provide significant broad
authority. To this end, local jurisdictions act to establish climate change policies and regulations
to reduce GHGs from transportation in GPs, CAPs, zoning, transit-oriented development
regulations, require infrastructure for fuel switching in buildings (e.g., electric vehicle charging
equipment), build supporting infrastructure in public right of ways or on public land, and
support alternative fuel production and infrastructure such as hydrogen. However, regulation of
fuels and tailpipe emissions is largely preempted by state and federal law. Local jurisdictions
have clear procurement authority over their own fleets and with authority to regulate indirect
transportation emissions to maintain attainment or to correct nonattainment of federal and
state air quality standards. State statutes and regulations create an opportunity to align local
action to decrease costs for implementation by bringing state funded projects, particularly in
communities of concern, to the region and deploying technology developed by state or federal
funding.
• On-Road Transportation Remains the Largest Source of GHG Emissions through 2035 – In 2016,
on-road transportation emitted more than 12 MMT CO2e, about 47% of regional emissions. In
2035, emissions from on-road transportation are projected to account for about 7.5 MMT CO2e
out of a regional total of about 19 MMT CO2e, about 41% of the total projected emissions. This
includes market-based ZEV adoption, but does not include the impact of CAP measures. In 2035,
on-road transportation emissions reductions from adopted CAP measures are projected to be
about 0.5 MMT CO2e in year 2035. This would reduce on-road transportation emissions to about
7 MMT CO2e in 2035.
i Police power is generally understood to be the regulatory authority to protect public health, safety, and welfare.
Oct. 11, 2022 Item #12 Page 367 of 560
329
• VMT Reduction is the Main Source of Transportation-Related Emission Reduction in CAPs –
Based on the assessment of quantified CAP measures in the adopted CAP scenario analysis, in
2035, 56% of the transportation-related GHG reductions are expected to be achieved through
VMT reduction measures, 42% from alternative fuel vehicles avoiding fossil fuel use, including
ZEVs, and 2% from measures that reduce fuel use. Public transportation plays the largest role in
reducing VMT according to adopted CAPs. Based on language in CAP measures, local
jurisdictions rely heavily on SANDAG to help achieve their transportation GHG reductions.
• CAP Measures are Insufficient to Achieve State-Aligned Regional ZEV Goals – Without
significantly increased support from the state or federal governments, neither SANDAG’s
RP2021 commitments for ZEV uptake, nor SANDAG RP2021 ZEV commitments in combination
with adopted CAP ZEV measures, which are expected to add about 63,000 ZEVs, for a total of
over 500,000 ZEVs, can achieve the regional share of ZEVs (771,000 ZEVs) needed to meet the
state goal under Executive Order N-79-20 that calls for all new passenger vehicles sold to be
zero emissions by 2035.
• Differences Exist Between Model-based Decarbonization Needs and CAP Commitments – There
is a fundamental difference in the actions developed in CAPs to reduce on-road transportation
emissions and Evolved Energy modeling that suggests focusing on achieving technology-based
solutions and ZEV uptake. CAPs rely on VMT reduction over ZEV uptake. More study would be
needed to determine how CAP VMT commitments align with SANDAG RP2021 mass transit
development in specific communities, and how VMT reduction measures, if implemented as
included in adopted CAPs, affect regional ZEV goals.
Summary of Opportunities for Further Local Action
The following summarizes key opportunities for further action to reduce GHG emissions from
transportation based on the legal authority analysis, the CAP GHG analysis, MPO actions, review of CCA
actions on decarbonizing transportation, and a literature review of social equity in transportation.
• Assess Local Legal Authority to Reduce Transportation GHG Emissions – Jurisdictions appear to
have more legal authority through land use, transportation infrastructure siting, police powers,
delegated authority, and taxation powers to reduce transportation GHGs, than represented by
commitments in CAPs. Additional work by local jurisdictions would be needed to assess the
limits of their authority to increase on-road transportation GHG reductions.
• Promote Mass Transit Use – All adopted and pending CAPs identify mass transit as the single
most important measure to achieve GHG reductions through VMT reduction. Even while
recognizing the significant role of regional cooperation for these measures, local jurisdictions
still have multiple opportunities to promote this mode to reduce VMT. As an example, the
option to provide school bus service through public buses can be assessed.
• Increase Bike and Walk Infrastructure to Increase Access to Basic Needs and Avoid VMT – An
opportunity exists for local jurisdictions to make active transportation plans a requirement of
new developments and evaluate the locational potential for additional active transportation in
their borders. Local jurisdictions also could increase cooperation and coordination with regional
walk and bike implementation projects by SANDAG and prioritize walk and bike projects in
communities of concern.
• Increase Connectivity through Land Use Changes to Avoid VMT – Fewer than half the adopted
and pending CAPs have addressed smart growth, and only one has addressed parking
regulations. Opportunities exist for local jurisdictions to increase density, eliminate parking
minimums, and permit zoning changes to promote mixed-use developments, which reduce
Oct. 11, 2022 Item #12 Page 368 of 560
330
distances to basic needs and promote VMT reduction. Opportunities to increase density in in-fill
areas have been identified in Chapter 3.i
• Manage Transportation Demand – Jurisdictions have the opportunity to implement
Transportation Demand Management (TDM) policies together with employers. Demand
management can be effective through a series of different approaches, such as density bonuses
for reduced parking, trip reduction programs through the employer such as mandatory and
incentivized or voluntary commute trip reduction, cash-out parking programs where employers
pay workers to not drive, and employer and publicly supported vanpools.ii
• Assess Fuel use Reduction Potential through Improved System Efficiencies – Jurisdictions have
an opportunity to identify areas for traffic calming measures, anti-idling requirements, especially
around school, and provide driver behavior incentives.
• Accelerate Vehicle Retirement – CAPs generally do not address vehicle retirement, which is an
opportunity to replace inefficient with cleaner alternatives, including ZEVs. Vehicle retirement
can be prioritized in communities of concern, which can have older less fuel-efficient vehicles.
Replacing inefficient vehicles would lead to significant air pollution reduction with associated
health benefits for all.
• Increase Use of Alternative Fuel Vehicles in Municipal Fleets – More local governments can
increase use of alternative, low-carbon fleet fuels in addition to ZEVs, particularly for medium-
and heavy-duty vehicles. Jurisdictions can leverage and implement the existing fleet greening
studies and plans. Cities could work with school districts to obtain funding for a regionwide
school bus transition.
• Assess the Social Equity Trade-offs between ZEVs and Mass Transit – There is an opportunity for
local jurisdictions to collaborate to assess the equity impacts of ZEV use versus increasing use of
mass transit in various communities, and to align regional transportation equity analysis (e.g.,
SANDAG) with CAP equity analyses (e.g., City of San Diego).
• Assess the Use of LCFS Funding to Promote Transition to Lower Carbon Fuels – There may be
opportunities to use cap and trade funds through the Low-Carbon Fuel Standard (LCFS) to aid in
fleet electrification or transition to a lower carbon fuel as clean vehicle rebates decrease.
• Multiple Opportunities for Regional Collaboration and Coordination – On-road transportation is
especially suited to regional action over local jurisdictional action because interconnections are
needed between jurisdictions to serve basic needs. VMT reduction through improved
connectivity and mass transit, ZEV uptake, and social equity integration may be more effective
through a regional approach rather than through individual local actions as represented in CAPs.
Regional projects such as assessing the use of LCFS for funding the transportation
decarbonization or availability of biofuels are examples of such collaborative opportunities.
• Explore Acceleration of Transportation Decarbonization through Mechanisms such as Joint
Powers Agreements – CCAs provide an example of a local mechanism, usually through Joint
Powers Agreements (JPA), that can support transportation electrification by developing
programs to locally incentivize EV uptake beyond state and federal programs. Similarly, other
regional decarbonize transportation mechanisms may be identified which can promote local
funds for transportation decarbonization.
i Areas in the region which meet infill definitions are provided in Chapter 3 of this report, page 70 ff.
ii Carlson, D. and Howard, Z. Impacts of VMT reduction strategies on selected areas and groups, Evans School of
Public Affairs, Washington State Transportation Center, prepared for the State of Washington, December 20201,
available at https://www.wsdot.wa.gov/research/reports/fullreports/751.1.pdf.
Oct. 11, 2022 Item #12 Page 369 of 560
331
8.5.2 Summary of Authority in the Decarbonize Transportation Pathway
Transportation emissions may be reduced by changing land use patterns to reduce the distances needed
to be traveled (e.g., reducing VMT and/or providing alternative transportation modes to single-occupant
vehicles), by designing communities to reduce system inefficiencies such as those caused by
transportation congestion (e.g., synchronized traffic lights), and by regulating direct (e.g., tailpipe)
emissions from vehicles, including by switching to low-carbon fuels such as clean electricity. The legal
authority to regulate each type of transportation emissions is summarized below.
Land Use Authority
Local authority over transportation is rooted in police power that creates land use authority over
planning and development that determines where residents live and work. Because it is a police power,
city and county land use authority does not rely on delegated general law of the state or federal
government. Instead, state and federal laws act as limitations on a city’s or county’s exercise of its police
power.i To this end, local jurisdictions act with both police power and delegated authority to establish
climate changes policies and regulations to reduce GHGs from transportation in GPs, CAPs, zoning, and
transit-oriented development regulations. Land use authority is subject to the vested rights doctrineii
and the Subdivision Map Actiii that limit how a subsequent change in local law or the authority to
impose conditions apply to a particular improvement to land or a vesting tentative map for subdivisions.
There is limited federal preemption with regard to local land use. Certain transportation land use actions
that include congestion pricing and low emission zones are means to reduce VMT and must be
evaluated for potential federal preemption under the Energy Policy Conservation Act (EPCA), Clean Air
Act (CAA), and Federal Aviation Administration Authorization Act.iv,v State law creates planning
requirements that do not preempt local land use authority. These requirements inform local land use
decision makers by:
• Directing local jurisdictions to identify and mitigate GHG emissions that are found to have
significant environmental impacts under CEQA for projects or general plans;
• Addressing infill to reduce VMT under SB 743 (Steinberg, Chapter 386, Statutes of 2013);
• Providing CEQA streamlining benefits for implementing sustainable community strategies (SCS)
to achieve regional GHG reduction targets under SB 375 (Steinberg, Chapter 728, Statues of
2008).
It is important to understand and distinguish the limited amount of federal and state preemption over
local land use authority compared to the express and definitive federal and state preemption that exists
over emissions from mobile sources (e.g., vehicles). These distinctions are important in understanding
the extent that a local jurisdiction may act.
i DeVita v. County of Napa, 9 Cal. App. 4th 763, 782 (1995); Candid Enters., Inc. v. Grossmont Union High Sch. Dist.,
39 Cal. 3d 878, 885 (1985).
ii Avco Community Developers v. South Coast Reg'l Comm'n, 17 Cal. 3d 785, 791 (1976), superseded by statute as
stated in Santa Margarita Area Residents Together v. San Luis Obispo County Bd. of Supervisors, 84 Cal. App. 4th
221, 229 (2000).
iii See Government Code §§ 66410–66499.38; Govt Code § 66474.2 & 66498.1(b).
iv 49 U.S.C.A. §§ 14501(c)(1) & (c)(2)(A).
v Turner, Amy E. and Burger, Michael, "Cities Climate Law: A Legal Framework for Local Action in the U.S." (2021).
Sabin Center for Climate Change Law. p. 37: https://scholarship.law.columbia.edu/sabin_climate_change/2
Oct. 11, 2022 Item #12 Page 370 of 560
332
Indirect Regulation of Transportation Emissions
The San Diego County Air Pollution Control District (SD APCD) may regulate indirect emissions to reduce
emissions from transportation and areawide emission sources to achieve and maintain state ambient air
quality standards.i However, there is uncertainty over jurisdiction and how to interpret this authority for
indirect emissions.ii Existing authority has been used by other air districts to create a voluntary GHG
reduction credit generation and certification program to help address GHG emissions of this type
through CO2 reductions. There are examples of voluntary programs for transportation emission
reductions that may be applicable to SD APCD.iii Transportation emissions may also be regulated
indirectly through pricing mechanisms, such as congestion or toll pricing, however, these measures may
require compliance and/or approval from state and/or federal governments (See Appendix B, Section
B.1.)
Concurrent authority may allow a local jurisdiction to further regulate air quality under its police
power,iv although local jurisdictions would need to develop internal technical expertise by hiring staff
and avoid state and federal preemption. It should be noted that there is no statutory power granted to
SD APCD to infringe on the existing local government authority over land use with regards to air quality
regulation (e.g., zoning).v
Regulation of Direct Emissions from Vehicles
Federal and state law and regulation preempt local jurisdictions from regulating GHG emissions directly
from on-road and off-road mobile sources under the EPCA and CAA. It is unclear whether local
jurisdiction police power or delegated permit, fees, rules, and regulations under California Public
Utilities Code § 5371.4 (f)–(g) related to city and counties may allow for the acceleration of the
reduction targets and goals for transportation network companies (TNCs). Local authority may exist to
regulate certain small off-road engines, but further research is required. California continues to invest
heavily in reducing emissions from all transportation sources through its state agencies and programs,
particularly CARB and the California Energy Commission (CEC). Aligning local actions and policies with
state policy and funding may accelerate local implementation and decrease costs.
Fuels and Infrastructure
State preemption exists in the form of the CARB administered LCFS, which regulates the carbon intensity
of transportation fuels in California.vi State preemption exists over types of reformed fuels that are sold
in California, including the Low Emission Diesel and Standards for Diesel Fuel regulations,vii as well as the
i Health & Safety Code §§ 40910, 40716–40717
ii Health & Safety Code §§ 42300–42339; See Health & Safety Code §§ 40716(b) & 41015 (sometimes interpreted
as not prohibiting parallel permitting systems for indirect sources); See 76 Ops Call Atty Gen 11 (1993) (Attorney
General opinion that authority of an APCD or AQMD does not extend to requiring permits for indirect sources;
Note: Attorney General opinions are nonbinding).
iii See Sacramento Metropolitan AQMD Rule 206 Mobile and Transportation Source Emission Reduction Credits
(Adopted December 15, 1992; Amended December 5, 1996):
http://www.airquality.org/ProgramCoordination/Documents/rule206.pdf.
iv See Health & Safety Code §§ 39002, 39037, & 41508.
v See Health & Safety Code §§ 40716(b) & 41015.
vi See 17 C.C.R. §§ 95480–95503; See also Executive Order N-79-20, Order No. 9 (September 23, 2020):
https://www.gov.ca.gov/wp-content/uploads/2020/09/9.23.20-EO-N-79-20-Climate.pdf. vii See 13 C.C.R. §§ 2281–2285, 2299–2299.5; 17 C.C.R. §§ 93114, 93117, 93118, 93118.2, 93118.3, 93118.5; 13
C.C.R. §§ 2281–2285 & 2299–2299.5.
Oct. 11, 2022 Item #12 Page 371 of 560
333
development and commercialization of alternative diesel fuels for sale in California.i CPUC regulation
does not automatically extend over compressed natural gas and hydrogen fueling stationsii like
intrastate pipelines for natural gas and hydrogen where entities meet the public utility definition. There
is uncertainty as to whether the Federal Energy Regulatory Commission (FERC) acts with authority over
interstate hydrogen pipelines under the Natural Gas Act.iii
Local jurisdictions may:
• Exercise police and land use authority to prohibit zoning for new gas stations or support
alternative fuel infrastructure through zoning and expediting permitting for renewable natural
gas fueling stations, hydrogen fueling stations, and electric vehicle charging equipment (EVSE);
• Require installation or pre-wiring for EVSE in the public right of way, on new residential and/or
nonresidential buildings, or when additions or alterations to existing residential and/or non-
residential buildings occuriv; and
• Consider state assessments of infrastructure need and funding to inform the exercise of their
own authority to develop and help fund fuels and infrastructure.
New Vehicle Sales and Fleet Procurement
Local jurisdictions act with clear authority to procure fleets for their operations with limited
federal preemption under the “market participant exception” of the Dormant Commerce
Clause.v Local jurisdictions have been prohibited from mandating the purchase of the certain
type of clean technology vehicles for private classes of vehicles, such as taxis.vi Local
jurisdictions act with clear authority to procure fleets for their operations with limited
preemption by the state.vii
8.5.3 GHG Impacts of CAP Measures in the Decarbonize Transportation Pathway
In general, the decarbonization of transportation in CAPs is achieved by (1) reducing VMT; (2)
accelerating uptake of alternative fuels, including ZEVs; and (3) reducing fuel use by increasing the
efficiency of the transportation system such as through traffic calming measures. This section
complements Chapter 3 by summarizing the GHG impacts from CAP measures related to decarbonizing
transportation, including those from the review of CAPs (Section 8.3) and the scenario analysis of GHG
Impacts (Section 8.4).
Historical and Projected Emissions from On-road Transportation
Regional 2016 GHG Inventory and Historical Emissions
In 2016, on-road transportation (LDVs and HDVs) emitted more than 12 MMT CO2e, or about 47% of
i 13 C.C.R. §§ 2293–2293.9.
ii California Public Utilities Code § 216 (f).
iii See 14 U.S.C.A § 717a (5).
iv See 12 C.C.R. Part 11 (2021); See Health & Safety Code §§ 17958.5, 17958.7 & 18941.5(b).
v 49 U.S.C.A § 32919(c); See Engine Mfrs. Ass'n v. South Coast Air Quality Mgmt. Dist., 498 F.3d 1031, 1040 (9th Cir. 2007);
Tocher v. City of Santa Ana, 219 F.3d 1040, 1049 (9th Cir. 2000); See also City of Columbus v. Ours Garage & Wrecker Serv., Inc.,
536 U.S. 424, 431 (2002).
vi Metro. Taxicab Bd. of Trade v. City of New York, 615 F.3d 152, 157 (2d Cir. 2010), cert. denied, 562 U.S. 1264 (2011); Ophir v.
City of Boston, 647 F. Supp. 2d 86, 94 (D. Mass. 2009).
vii See 13 C.C.R. §§ 2023 et seq; See 13 C.C.R. §§ 1963; 1963.1,1963.2,1963.3,1963.4,1963.5,2012,2012.1, & 2012.2; See 17 CCR
§§ 95690.1, 95690.2, 95690.3, 95690.4, 95690.5, 95690.6, 95690.7, and 95690.8.
Oct. 11, 2022 Item #12 Page 372 of 560
334
regional emissions. Based on SANDAG’s modeled regional GHG emissions estimates in 2006, 2012, and
2016, on-road transportation emissions have decreased 33% during this period, and the contribution of
emissions from LDVs, which include passenger vehicles and SUVs, has decreased from 90% to 85%
(Figure 8.12). The contribution of HDVs to GHG emissions increased about 9% during 2012 to 2016.
However, LDVs continue to comprise the largest portion of all regional emissions, about 40%, and similar
to state proportions.
Figure 8.12 Historical on-road transportation emissions, San Diego County.
Projected On-road Transportation Emissions
In 2035, SANDAG’s 2021 Regional Plan estimates a regional total of GHG emissions from all sources to
be about 19 MMT CO2e in 2035, of which nearly 8 MMT CO2e will be from on-road transportation before
CAP measure reductions. On-road GHG emissions are projected to remain the largest source of GHG
emissions in 2035, about 41% of the total projected emissions in 2035, including the impacts of market-
based ZEV adoption. However, LDV contribution to GHGs decreases to 32% in 2035 compared with 41%
in 2016, while HDV emissions contribute relatively more (9%) in 2035 than in 2016 (Figure 8.13).
Oct. 11, 2022 Item #12 Page 373 of 560
335
Figure 8.13 Regional 2016 GHG Inventory and 2035 Projection. Other GHG emitting categories include industrial,
off-road transportation, waste, water, aviation, etc. Source: SANDAG 2021 Regional Plan, Appendix X.
The on-road transportation emissions in 2035 of nearly 8 MMT CO2e include the estimated impacts of
Federal and State measures on fuel efficiency, and an assumed 8% ZEVs in the fleet. On top of those
reductions, SANDAG is expected to achieve an additional 0.41 MMT CO2e reduction in 2035 from
regionally-funded ZEVs and infrastructure EVCS and TDM measures for an estimated 7.5 MMT CO2e
emissions from on-road transportation in 2035.
SANDAG’s regional measures are able to achieve about another 5% decrease in the on-road emissions in
2035. The 38% drop in on-road emissions from 2016 to 2035 translates to per capita CO2e reduction
from 3.7 MT CO2e in 2016 to 2.1 MT CO2e in 2035, despite a projected increase of 2% VMT during 2016-
2035.i The remaining on-road emissions of about 7.5 MMT CO2e in 2035 is equivalent to more 17 million
barrels of oil or enough energy for nearly 1 million homes today.ii To put this into context, if using
natural climate solutions, this would require planting more than 124 million tree seedlings grown for 10
years, according to EPA estimates.iii
The reductions above do not include what is available from local jurisdiction CAP actions, which will be
discussed in the following sections.
Review of CAP On-Road Transportation Policies
For this analysis, we show GHG impacts of the decarbonization pathways to the GHG reduction from all
local measures in adopted and pending CAPs, including the City of San Diego draft 2022 CAP update.
Based on this analysis, CAP measures in the Decarbonize Transportation Pathway account for between
7% and 51% of all local CAP reductions, with an average across all CAPs of 30% (Figure 8.14).
i SANDAG 2021 Regional Plan Appendix X.
ii EPA https://www.epa.gov/energy/greenhouse-gas-equivalencies-calculator.
iii Id. at note 152.
Oct. 11, 2022 Item #12 Page 374 of 560
336
Figure 8.14 Contribution of Measures to Decarbonize Transportation in Adopted and Pending CAPs
A further breakdown of CAP measures to decarbonize transportation from the review of CAPs shows
that nearly all adopted and pending CAPs have measures related to all three policy category approaches
— VMT reduction, fuel use reduction through system efficiencies, and alternative fuel vehicles and
infrastructure (Figure 8.15).i CAP measures related to alternative fuel vehicles, including electric
vehicles, contribute between less than 1% to nearly 50% of the reductions within a CAP, with an average
reduction of 16%. Those related to VMT reduction range from less than 1% to 30%, with an average of
12%. While most CAPs have measures related to fuel use reduction, its average contribution to local
GHG reductions is minimal (approximately 1%).
Figure 8.15 Number of CAPs with Main Approaches to Reduce on-Road Transportation Emissions.
More details from the review of CAPs for each policy category and related subcategories, and from the
existing CAP commitments will be provided in the following sections. As described above in Section
8.3.3, we did not estimate the contribution of the policy subcategories to local GHG reductions across
CAPs.
Scenario Analysis of GHG Impacts from Adopted CAP Commitments
In contrast to the review of CAPs, which considers measures in all emissions categories and does not
consider the combined impact of measures, the scenario analysis evaluates emission reductions from
the three main emission categories — on-road transportation, electricity, and natural gas, and estimates
i Note: the Alternative Fuel category does contain a minor number of off-road policies.
Oct. 11, 2022 Item #12 Page 375 of 560
337
the GHG impact of all related CAP measures. Results of the analysis of emissions associated with
decarbonizing transportation are presented here. The emission reduction from each policy category
within the Decarbonize Transportation Pathway only shows quantified policies as shown in Figure 8.16
as not all policies relating to each policy category are quantified in CAPs.
Figure 8.16 Projected Baseline Impact of Adopted CAP Policy Commitments to Reduce On-Road Transportation
GHG Emissions, 2035.
Based on the Adopted CAP Commitment Scenario, GHG reduction from on-road transportation
measures in CAPs are about 0.5 MMT CO2e in 2035. Of this total, 56% comes from VMT reduction and
42% from alternative fuels, including electricity. This reduction from the 17 CAPs combined is greater
than the 0.41 MMT CO2e reductions achieved by SANDAG VMT actions in 2035. The impact of reduction
from CAP on-road transportation commitments on the projected 2035 regional inventory is shown in
Figure 8.17.
Figure 8.17 Impact of Reduction from CAPs on the Projected 2035 Regional Inventory
The GHG reductions from the Adopted CAP Commitment Scenario for the three policy categories are
shown in Table 8.9. Within the VMT Reduction policy category, mass transit plays the largest role; within
alternative fuels, ZEVs play the largest role; and reducing fuel use by improving transportation system
efficiencies plays only a minimal role.
Oct. 11, 2022 Item #12 Page 376 of 560
338
Table 8.9 Adopted CAP Commitments and GHG Reductions, 2035.
Decarbonization
Pathway
Policy
Category Policy Subcategory
GHG Emissions Reduced in 2035
MT CO2e Distribution within
Pathway
Decarbonize
Transportation
VMT
Reductions
Increase Commute by Biking 42,896 9%
Increase Commute by Walking 1,221 0.2%
Increase Safe Routes to School 79 0.02%
Complete Street 650 0.1%
Increase Commute by Mass Transit +
Intra-city Shuttle 200,963 40%
Reduce Parking 9,781 2%
Commute TDM Strategies 24,140 5%
Increase Commute by Vanpool 2,065 0.4%
Fuel Use
Reductions
Traffic Signal Synchronization 3,893 1%
Install Roundabouts 5,623 1%
Vehicle Retirement 446 0.1%
Alternative
Fuel Vehicles
and Equipment
Increase City-wide electric vehicle miles 187,364 37%
Increase alternative fuel vehicles in
municipal fleet 23,269 5%
Total: 502,389 100%
Best Adopted CAP Commitment Scenario
We estimate the GHG impacts if all jurisdictions were to implement the most ambitious commitment
(Appendix 8.A) in any adopted CAP across the region in 2035. If all CAPs implement the most ambitious
commitment in any CAP for 2035, on-road transportation measures would provide the largest reduction
of the categories included in the analysis, about 3.5 MMT CO2e, with VMT reduction providing the
largest amount followed by ZEVs (Figure 8.18). This reflects the fact that adopted CAPs expect to achieve
the most on-road transportation reductions through VMT policies, especially mass transit. It does not
imply that all jurisdictions should or can apply the currently most ambitious policies, but provides an
upper limit of what could be achieved with current policies in CAPs.
Figure 8.18 Impact of Best Adopted CAP Commitments Applied to All Jurisdictions, 2035.
Figure 8.19 shows the portion of the total GHG reduction attributed to measures to decarbonize
transportation. In the Best Adopted CAP Commitment Scenario, these measures represent a significant
Oct. 11, 2022 Item #12 Page 377 of 560
339
portion of total GHG reductions in 2035 through 2050. However, even with the most ambitious adopted
CAP commitment applied all jurisdictions; the region fails to get much closer to zero emissions.
Figure 8.19 Regional Impact of Best Adopted CAP Commitments to Decarbonize Transportation.
The best Adopted CAP commitment GHG reductions and associated activity levels are shown in Table
8.9. In this scenario, within the transportation reductions, there would be a 43% reduction in VMT
across the region in 2035, within which vanpools, parking strategies, transit commute and commute
TDM policies play the largest roles, in that order. However, the ZEV uptake would contribute a similar
amount of reductions. As mentioned, even if the most ambitious policies were implemented by all
jurisdictions, significant transportation emissions remain to be removed in 2035.
Table 8.10 GHG Reduction by Policy Category and Subcategory (Best Adopted CAP Commitment Scenario).
Decarbonization
Pathway
Policy
Category Policy Subcategory
GHG Emissions Reduced in 2035
(MT CO2e) Distribution within Pathway
Decarbonize
Transportation
VMT
Reductions
Increase Commute by Biking 30,416 1%
Increase Commute by Walking 14,833 0.4%
Increase Safe Routes to School 1,440 0.04%
Complete Street 6,387 0.2%
Increase Commute by Mass Transit +
Intra-city Shuttle 213,231 6%
Reduce Parking 647,937 18%
Commute TDM Strategies 215,248 6%
Increase Commute by Vanpool 927,567 26%
Fuel Use
Reductions
Fuel Reduction from Traffic Calming 12,283 0.3%
Vehicle Retirement 2,973 0.1%
Alternative
Fuel Vehicles
and Equipment
Increase City-wide electric vehicle miles 1,502,651 42%
Increase alternative fuel vehicles in municipal fleet 24,066 1%
Total: 3,599,034 100%
Oct. 11, 2022 Item #12 Page 378 of 560
340
8.5.4 VMT Reduction
In general, increasing accessibility to basic needs and mobility while reducing VMT is the aim of this
policy and requires a shift from single-occupant passenger vehicle use into alternative modes that are
more energy efficient than single occupant vehicles.
Currently, most trips in the region are made by single occupant vehicles (Figure 8.20). Implementation of
SANDAG’s RP2021 is projected to lead to a 20% decrease in per capita VMT by 2035 as required under
SB375.i There is projected to be some change in mode share across the region, but this increase in mode
share 2016–2035 is overtaken by net absolute VMT growth of 2% based on SANDAG’s ABM2+ model.ii
Figure 8.20 Percentage of Passengers by Mode, 2016 and expected in 2035, from the SANDAG RP2021. Source:
SANDAT RP 2021, Appendix T
VMT Reduction Measures in Adopted and Pending CAPs
Results from the review of adopted and pending CAP measures to reduce VMT are summarized by policy
subcategory (down) and implementation mechanism (across) (Figure 8.21). Most CAPs have measures
related to education and outreach, plans or programs, and capital improvement and infrastructure.
There are relatively few CAPs with measures to require or provided incentives for VMT reduction
activities.
Results from the adopted CAP scenario analysis for VMT reduction policies is summarized in Figure 8.22.
Within VMT reduction policies, the largest impacts come from mass transit followed as a distant second
by bike, walk and complete street policy subcategories. Note that CAP VMT reduction measures would
be additional to SANDAG RP2021 measures.
i SANDAG RP2021, Appendix T: Network Development and Performance, Table T6.2.
ii SANDAG RP2021, Appendix T: Network Development and Performance, Table T6.1.
Oct. 11, 2022 Item #12 Page 379 of 560
341
Figure 8.21 Number of Adopted and Pending CAPs with Measures Related to VMT Reduction
Figure 8.22 Emissions Reduced from Measures to Reduce VMT in Adopted CAPs in the San Diego Region
Mass Transit
Mass transit accounts for the most GHG reductions from VMT reductions in CAPs (40%, Figure 8.22).
Most associated measures in CAPs (Figure 8.21) relate to education and outreach; the focus on
education and outreach may suggest the legal and/or capacity limitations of jurisdictional authority over
mass transit. The educational policies for mass transit as written in CAPs also demonstrate a high
reliance on regional collaboration with SANDAG and regional transit agencies such as MTS and NCTD.
Given this dependence, it is unclear whether the GHG reduction commitment potential for mass transit
(40%) as identified in the Adopted CAP Commitment Scenario would in fact be achievable without
regional collaboration and funding. From the review of CAPs, it appears that individual jurisdictions’
capital projects mechanism relates to relatively minor mass transit infrastructure projects, such as
installation of bus shelters. These do not in themselves lead to the large VMT reduction commitments in
the CAPs, though they are necessary additions to a transit network.
Other general implementation mechanisms for mass transit measures in CAPs are provided in Figure
8.10. Mandating new developments to provide connections to the mass transit network is given only in
one CAP.
Oct. 11, 2022 Item #12 Page 380 of 560
342
Table 8.11 General CAP Policies – Mass Transit Policy Subcategory
Implementation Mechanism General Policy
Capital Improvement & Infrastructure • Install mass transit infrastructure (e.g., bus shelters)
• Implement an intra-city shuttle system
Education, Outreach, &
Coordination
• Partner with and encourage transit providers for improved/enhanced
service
• Advocate for improved transit infrastructure
• Participate in regional transit planning programs
• Pursue partnerships and grant opportunities for funding
• Partner with neighboring jurisdictions to identify opportunities to increase
transit ridership
• Partner with school districts to increase school bus ridership
Evaluation • Evaluate transit routes and frequency
Incentives • Provide subsidized or discounted transit fares
Plan or Program • Develop an intra-city shuttle program
• Develop a Safe Routes program to provide access to mass transit network
Requirement(s) • Require new development to provide connections to mass transit network
Even if local government actions as reflected in CAPs are necessary to implement effective mass transit
uptake, the ultimate funding and construction of a transit network requires significant cooperation,
coordination and support at SANDAG, and among member jurisdictions. SANDAG is subject to both
federal law and state law in its planning and construction of projects. SANDAG serves as the regional
federally designated metropolitan planning organization (MPO), regional transportation planning
agency, congestion management agency, and council of governments for San Diego County. For transit,
it is a “consolidated agency” that combines the responsibilities and powers of the SANDAG, the San
Diego Metropolitan Transit Development Board, and the North San Diego County Transit Development
Board for long-term transit planning, funding, and construction.i In particular however, before projects
can be implemented, these must be approved and supported by SANDAG board members, as well as
funded, or funding raised, to plan and construct. This process often requires years or decades to move
from proposal to completion, proving a considerable hurdle for large-scale infrastructure projects such
as transit.
Bike, Walk, and Complete Streets
This shows that of the VMT reduction policy subcategories, more CAPs have the bike, walk and complete
streets subcategory than any other policy subcategory although these provide only 9% of the reductions
in the Adopted CAP Commitment Scenario. All CAPs have at least one related measure implemented
through the capital improvement and infrastructure mechanism, followed by measures to develop a
plan or program and conduct education and outreach. Only two CAPs have measures to mandate
actions related to bike, walk, and complete streets and only one includes evaluation of the impact of
bike, walk and complete street projects as part of the CAP itself. None of the CAPs commit to encourage
bike, walk and complete streets through financial incentives.
Except for the County, other CAPs quantify only bike and walk policies. The County CAP quantifies the
GHG reductions from a complete streets measure as a combination of incentives, improved street
i See SB 1702 (Peace, Chapter 743, Statutes of 2002), available at:
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=200120020SB1703.
Oct. 11, 2022 Item #12 Page 381 of 560
343
connectivity and bike and walk improvements which would fall under the capital improvement and
infrastructure mechanism. General policies in CAPs to address the bike, walk and complete streets policy
subcategory, by implementation type, are shown in Table 8.12.
Table 8.12 VMT Reduction in CAPs: General CAP Policies in the Bike, Walk & Complete Streets Subcategory
Implementation Mechanism General Policy
Capital Improvement &
Infrastructure
• Install bike and pedestrian projects and facilities
• Improve existing bicycle and pedestrian facilities
• Complete streetscape improvements for safety and accessibility
• Implement complete streets policies
• Implement active transportation master plan
• Purchase e-bikes for municipal employee use
• Expand bicycle parking facilities
• Install sharrows on bike routes
• Improve connectivity between mass transit and active transportation
networks
Education, Outreach, &
Coordination • Promote bicycle use and safety
• Facilitate bike-sharing services
• Encourage installation of bike and pedestrian facilities at nonresidential
developments
• Develop partnerships to promote active transportation safety
• Coordinate efforts with SANDAG
• Pursue partnerships and grant opportunities for funding
Evaluation • Monitor bicycle lane usage
Incentives NA
Plan or Program • Develop a Complete Streets policy
• Develop an Active Transportation Plan or Similar (e.g., Bike or Pedestrian)
• Update existing Active Transportation Plans or Similar (e.g., Bike or
Pedestrian)
• Develop a bicycle sharing program
Requirement(s) • Require new development to provide connections to active transportation
network
• Require increased bicycle parking facilities at certain nonresidential locations
Jurisdictions have a certain amount of authority on their own roadways. The limits of this authority for
pricing mechanisms are not known (See Appendix B, Section B.1). The adoption and implementation of
CAP measures such as ATPs may be restricted to local roads or need coordination with the regional
planning agency.
Parking Reductions
Parking reductions are addressed in adopted CAPs largely as a requirement in 7of 17 CAPs, but provide
only 1.9% of the GHG reductions, based on the Adopted CAP Commitment Scenario, due to the small
number of projects included. Examples of policies include removing parking minimums or evaluating the
potential by conducting parking surveys in certain areas (e.g., near mass transit, developing a parking
plan for urban areas, and requiring certain new developments to reduce off-street parking
requirements).
Parking types range from on-street, off-street to surface lots and structures. Especially parking
structures are expensive, with the median construction cost for a new parking structure in 2019 at
$21,500 per space or $64.66 per square foot due to land costs, construction and operating costs and
Oct. 11, 2022 Item #12 Page 382 of 560
344
indirect service costs.i Many cities in California have recently approved parking removal policies:
Sacramento in January 2021 approved abolishing parking minimumsii and are assessing parking
maximums; Berkeley in January 2021 eliminated off-street parking for new developments with some
exceptions for fire and narrow streets, and implemented parking maximums where transit is plentifuliii;
San Francisco in 2018 eliminated parking by ordinance and parking is not required for any new
developments in the cityiv; the City of San Diego’s 2022 Ordinance O-21041 eliminated minimum parking
requirements for many businesses and multifamily developments in Transit Priority Areas so that these
spaces may now be used for other purposes and reduces costs for developments.v These policies may
occur outside of CAPs.
Commuter Transportation Demand Management (TDM)
Commuter TDM measures in adopted CAPs relate mostly to education and outreach, encouraging
employers and employees to manage transportation demand, and assessing demand management.
Seven CAPs commit to develop TDM plans or programs to that can motivate demand reduction, and
three CAPs have relatively weak actions to reduce demand, such as on-line permitting. Plans, programs
and incentives being more voluntary, provide fewer GHG reductionsvi than mandatory TDM measures.
Five jurisdictions, including the County, address commuter TDM through a TDM ordinance as well as
educational outreach. Commuter TDM provides 5% of the CAP reductions in 2035 in the Adopted CAP
Commitment Scenario.
i RMM, More California cities eliminate parking minimums to promote low carbon transportation and affordable
housing. See also Victoria Transport Policy Institute, Transportation cost and Benefit Analysis II – Parking Costs, at
www.vtpi.org, p 5.4-1.
ii Parking Requirements, available at https://www.munistandards.com/ca/sacramento/parking-requirements/.
iii Berkeley City Council ends parking requirements for new housing, available at
https://www.dailycal.org/2021/01/29/berkeley-city-council-ends-parking-requirements-for-new-housing/.
iv Ordinance No 277-18, 10/22/2018 available at
https://sfgov.legistar.com/View.ashx?M=F&ID=6797067&GUID=F6DB5973-9768-48AD-B217-F8E46FF0C86ASan.
v San Diego City Council votes to repeal minimum parking requirements for new housing, available at
https://timesofsandiego.com/politics/2019/03/04/san-diego-city-council-votes-to-repeal-minimum-parking-
requirements-for-new-housing/.
vi P.89, Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and
Advancing Health and Equity Designed for Local Governments, Communities, and Project Developers, Public Draft
August 2021. Henceforth: CAPCOA Handbook 2021. Voluntary TDM measures can provide up to 4% GHG reduction from a project’s employee commute VMT reduction while a mandatory measure can reduce up to 26% from a
project.
Oct. 11, 2022 Item #12 Page 383 of 560
345
Table 8.13 General CAP Policies – Commuter TDM Policy Subcategory
Implementation Mechanism General Policy
Capital Improvement & Infrastructure • Launch and transition to an online municipal permitting system
Education, Outreach, &
Coordination • Facilitate first-mile/last-mile transportation options (e.g., bike- and car-
sharing)
• Collaborate with SANDAG on regional TDM plans
• Promote use of alternative transportation modes (e.g., vanpool, carpool)
• Connect employers with TDM resources
• Promote regional TDM programs
• Encourage employers to develop and participate in TDM programs
• Develop partnerships to promote TDM programs and strategies
• Encourage municipal employees to use a TDM commute method (e.g.,
vanpool, carpool)
Evaluation • Conduct a transportation demand management study
• Review SANDAG’s TDM KPIs annually
• Conduct surveys to determine TDM usage rates
Incentives • Provide incentives to municipal employees who use alternative
transportation
• Provide incentives to businesses with TDM strategies in place
Plan or Program • Develop a citywide TDM plan
• Develop a TDM plan for municipal employees
• Develop an incentive program for municipal employees to use alternative
transportation
Requirement(s) • Require new nonresidential projects and certain retrofits to adopt a TDM
plan/strategies
• Require carpool and vanpool parking in new development
Smart Growth Development
As mentioned previously, not all VMT reduction measures are quantified in CAPs as local actions, and
are therefore not represented in Figure 8.21 and Figure 8.22. Measures not quantified as local actions
but included as policies in CAPs are smart growth plans or programs. General implementation
mechanisms for these policies are shown in Table 8.14.
Smart growth development generally means zoning changes and density increases in new
developments. The CAPCOA Handbook for Analyzing Greenhouse Gasesi includes these as land use
changes, such as increased residential density, increased job density, providing transit-oriented
development, and improving street connectivity. These developments are considered to be part of the
legislatively-adjusted BAU but if identified as specific projects in CAPs could have long-term VMT
reduction potential by planning for focused new development in mobility hubs, for example. CAPs
generally do not estimate reductions from plans and programs, even if they have the potential for long-
term efficient development. Plans or programs (e.g., zoning changes to accommodate density increase)
may be supported at a later stage by incentives (e.g., for example, density bonuses), and at an even later
stage may become requirements for new development (e.g., minimum number of multifamily units), at
which point they could be quantified for GHG reduction in CAPs. Therefore, where jurisdictions can
identify new future developments that are not yet included in the BAU regional projection, CAPs can be
used as the tool to estimate GHG reductions.
i p. 137, CAPCOA Handbook 2021.
Oct. 11, 2022 Item #12 Page 384 of 560
346
Table 8.14 General CAP Policies – Smart Growth Development Policy Subcategory
Implementation Mechanism General Policy
Capital Improvement & Infrastructure NA
Education, Outreach, &
Coordination • Encourage higher density and mixed-use development
• Develop partnerships to identify barriers to higher-density development
• Develop partnerships to expand transit service near new development
sites
• Encourage participation in easement programs for natural and working
lands
Evaluation • Identify areas that can support increased population or employment
Incentives • Provide smart growth incentives to new development
Plan or Program • Develop smart growth related plans, policies, or strategies (e.g., Transit
District Specific Plan)
• Update General Plan
Requirement(s) • Establish standards for new development projects
Micromobility
Micromobility measures, for example, e-bike programs, are not quantified in adopted CAPs.
Micromobility is included in 3 CAPs as an educational opportunity and 1 CAP for evaluation. These
measures are not identified as a project that could assist in transit use, or otherwise shift to non-car
community uses. CAPCOA estimates that up to 0.06% of GHG emissions reduction can be had from a
community with this type of program.i
8.5.5 Reduce Fuel Use
Making the transportation system more efficient, thus using less fuel, includes traffic calming measures,
and encouraging efficient driving behaviors. CAP commitments that have been quantified are mostly in
the form of potential capital improvement projects. Based on the review of adopted and pending CAPs,
half the CAPs use these actions (Figure 8.23), but because of the relatively few projects within each
jurisdiction, the GHG reduction estimate from the Adopted CAP Commitment Scenario for these projects
is only 3% of the total on-road GHG reduction amount (Figure 8.24). It is not possible to assess the
potential magnitude of reduction from increasing the number of such actions across the region without
significant coordination and cooperation in the region.
Figure 8.23 Number of Adopted and Pending CAPs with Measures Related to Reducing Fuel Use
i Id. at 154.
Oct. 11, 2022 Item #12 Page 385 of 560
347
Figure 8.24 Estimated GHG Reductions from Fuel Use Reduction in 2035 in Adopted CAPs
General policies related to these policies are shown in Table 8.15 and Table 8.16. Driver behavior,
included in 3 CAPs as an education measure and one CAP as a requirement, can also affect the efficiency
of fuel use but has not been quantified for GHG reductions in CAPs. Examples of CAP measures include
promoting fuel efficient driving behaviors, working with school districts to improve idling time during
student pick up and drop off times, and limiting construction vehicle equipment and idling, through
ordinances. These measures not only reduce fuel waste and GHG emissions, but also reduce emissions
of criteria pollutants. California anti-idling regulations prohibit diesel trucks and buses, including from
school buses, from idling for more than 5 minutes, with fines of $300-$1,000 per day. Local peace
officers can enforce and the SD APCD actively enforces these regulations under a memorandum of
understanding (MOU) with CARB.i There are no similar regulations for LDVs; however, such actions
would be within the authority of a school district or jurisdiction to adopt and enforce.
Table 8.15 General CAP Policies – Traffic Signal Synchronization Policy Subcategory
Implementation Mechanism General Policy
Capital Improvement & Infrastructure • Synchronize traffic signals at select intersections
• Upgrade traffic signal controllers to smart controllers
Education, Outreach, & Coordination NA
Evaluation • Conduct traffic studies
• Monitor and evaluate intersections for future synchronization
Incentives NA
Plan or Program • Develop a traffic signal master plan
• Update traffic-flow related planning documents (e.g., General Plan
Mobility or Circulation Elements)
Requirement(s) NA
i See Memorandum of Understanding Between The California Air Resources Board and San Diego County Air
Pollution Control District Regarding Enforcement of Selected Air Resources Board Regulations, August 16, 2017,
available at https://www.sdapcd.org/content/dam/sdapcd/documents/compliance/MOU_2017108.pdf; see also SD APCD Mobile Source Program: https://www.sdapcd.org/content/sdapcd/compliance/compliance-
requirements/mobile-source-program.html.
Oct. 11, 2022 Item #12 Page 386 of 560
348
Table 8.16 General CAP Policies – Traffic Calming Infrastructure Policy Subcategory
Implementation Mechanism General Policy
Capital Improvement & Infrastructure • Install roundabouts
Education, Outreach, & Coordination • Pursue partnerships and grant opportunities for funding
Evaluation • Monitor and evaluate potential locations for future roundabouts
Incentives NA
Plan or Program • Update traffic-flow related planning documents (e.g., General Plan
Mobility or Circulation Elements)
Requirement(s) NA
8.5.6 Increase Use of Alternative Fuels Vehicles and Equipment
Alternative fuels are mostly ZEVs but also include renewable natural gas and renewable biofuels.
Renewable natural gas and renewable biodiesel are considered zero emissions.
Most CAPs use the capital improvement and infrastructure and the education, outreach and
coordination mechanisms to address ZEVs and EVCS (Figure 8.25). About half the CAPs address other
low carbon fuels and infrastructure. However, the largest transportation-related reductions come from
ZEVs (37%).
Figure 8.25 Number of Adopted and Pending CAPs with Measures Related to Alternative Fuels and Vehicles
Electric Vehicles and Charging Infrastructure
Nearly all adopted and the pending City of San Diego Draft 2022 CAP address ZEVs and EVCS within the
capital improvement mechanism, requirements for EV charging in developments, and education policies
for both EVs and EVCS, in that order (Figure 8.25). EV capital improvement projects include parking EVCS
policies are equally represented as requirements, capital improvement, where capital improvement
includes installing charging stations, and education. General policies under ZEVs and other alternative
fuels are shown in Tables 8.17 to 8.20.
Electrification of off-road equipment, including construction equipment and residential outdoor
equipment, may provide additional reductions but are not part of the Decarbonize Transportation
Pathway and are not quantified in CAPs generally.
Oct. 11, 2022 Item #12 Page 387 of 560
349
Table 8.17 General CAP Policies – Electric Vehicles Policy Subcategory
Implementation Mechanism General Policy
Capital Improvement &
Infrastructure
• Transition municipal fleet from gas to alternative fuels
• Convert school bus fleet to electric
Education, Outreach, &
Coordination
• Partner with waste hauler to use alternative fuel waste trucks
• Promote regional incentive and rebate programs supporting electric vehicles
• Pursue partnerships and grant opportunities for funding
• Work with municipal departments to develop policies and programs
• Partner with waste hauler to convert vehicles
• Partner with transit service provider to convert vehicles
• Develop partnerships to design municipal plans and policies
• Promote use of EVs
• Work with regional partners to develop a regional EV plan
• Advocate for an EV carsharing network
Evaluation NA
Incentives • Provide incentives to city residents to increase use of EVs
Plan or Program • Develop a municipal fleet management program or plan
• Update vehicle fleet assessment
• Develop a municipal alternative fuels policy
• Integrate low- and zero-emissions vehicles into municipal purchasing policy
• Develop an electric vehicle carshare program
Requirement(s) NA
Table 8.18 General CAP Policies – EV Charging Infrastructure Policy Subcategory
Implementation Mechanism General Policy
Capital Improvement &
Infrastructure
• Install public EV chargers at municipal facilities and sites
Education, Outreach, &
Coordination
• Map locations of publicly available fueling infrastructure
• Develop regional partnerships to increase public refueling infrastructure
• Participate in regional programs focused on infrastructure development
• Support development of public and private sector infrastructure
• Encourage installation of EV chargers in new developments
• Pursue partnerships and grant opportunities for funding
• Create guidance documents for property owners with regional partners
• Promote regional programs supporting EV charging infrastructure
Evaluation • Conduct a pilot program at a municipal site to evaluate feasibility for municipal fleet
Incentives • Provide permit fee waivers for new construction with EV charging infrastructure
• Incentivize installation at gas stations and other retail locations
• Provide grants to residents and businesses
Plan or Program • Develop an EV charging station master plan or similar
Requirement(s) • Require new residential and/or nonresidential development to be EV ready
• Require new multi-family and/or nonresidential development to install a certain
number of EV chargers
• Require multi-family and/or nonresidential properties undergoing major renovations
to install a certain number of EV chargers
• Require residential solar PV installs to prewire for an EV charger
Oct. 11, 2022 Item #12 Page 388 of 560
350
Low-Carbon Fuel Vehicles, Infrastructure, and Equipment
As provided in adopted CAPs, low carbon alternative fuels are most important for municipal fleets and
provide 5% (Figure 8.26) of the CAP on-road transportation reductions in 2035, based on the Adopted
CAP Commitment Scenario. While the GHG reduction potential may be low depending on the size of the
municipal fleet, every municipality could implement a fleet conversion program based on studies
initiated through SANDAG in the years 2012–2018.i Jurisdictions can leverage and implement the
existing fleet greening studies and plans within their CAPs. Conversion of municipal fleet to ZEVs will
fully eliminate those GHGs. According to CAPCOA, using cleaner-fuel vehicles would also increase
transportation resilience by diversifying fuel sources. Alternative low carbon fuel sources can provide
health and equity benefits by generally eliminating or lowering criteria air pollutants, although biodiesel
may increase NOx emissions and lower PM emissions compared with regular diesel.ii
Figure 8.26 GHG Reductions from Alternative Fuels, Including ZEVs, as Estimated for 2035 in CAPs.
i The SANDAG Energy Roadmap Program provided free energy assessments and development of energy roadmaps
including for municipal fleets and facilities, if and as requested by jurisdictions. Specific reduction potentials for
greening the fleet were estimated, with associated fuel savings and GHG reductions. See https://www.sandag.org/index.asp?projectid=373&fuseaction=projects.detail.
ii P. 187, CAPCOA Handbook 2021.
Oct. 11, 2022 Item #12 Page 389 of 560
351
Table 8.19 General CAP Policies – Low Carbon Fuel Vehicles Policy Subcategory.
Implementation Mechanism General Policy
Capital Improvement & Infrastructure • Transition municipal fleet from gas to alternative fuels
• Install a public CNG fueling station at a municipal facility
Education, Outreach, &
Coordination
• Partner with waste hauler to use alternative fuel waste trucks
• Promote regional incentive and rebate programs supporting low carbon fuel
vehicles
• Pursue partnerships and grant opportunities for funding
• Work with municipal departments to develop policies and programs
• Partner with waste hauler to convert vehicles
• Partner with transit service provide to convert vehicles
Evaluation NA
Incentives NA
Plan or Program • Develop a municipal fleet management program or plan
• Update vehicle fleet assessment
• Develop a municipal alternative fuels policy
• Integrate low- and zero-emissions vehicles into municipal purchasing policy
Requirement(s) NA
Table 8.20 General CAP Policies – Low Carbon Fuel Infrastructure Policy Subcategory
Implementation Mechanism General Policy
Capital Improvement &
Infrastructure
NA
Education, Outreach, &
Coordination • Map locations of publicly available fueling infrastructure
• Develop regional partnerships to increase public refueling infrastructure
• Participate in regional programs focused on infrastructure development
• Support development of public and private sector infrastructure
• Partner with waste hauler to use alternative fuel waste trucks
Evaluation NA
Incentives NA
Plan or Program • Develop an integrated transportation strategy, including infrastructure
needs
Requirement(s) NA
Preferred Parking
Several CAP actions that would support the acceleration of ZEVs have not been quantified, including
preferred parking actions for alternative fuel vehicles. Even without quantification, most local
jurisdictions can adopt preferred parking requirements in new developments, parking lots operated by
private entities for public use, city-owned public spaces, and provide incentives for businesses to do so.
Oct. 11, 2022 Item #12 Page 390 of 560
352
Table 8.21 General CAP Policies – Preferred Parking Policy Subcategory
Implementation Mechanism General Policy
Capital Improvement & Infrastructure • Provide designated parking for EVs and AFVs at municipal facilities and
public parking lots
• Designate a percentage of street parking spaces in certain areas for EVs and
AFVs
Education, Outreach, &
Coordination
• Encourage conversion of private parking spaces to EV and AFV preferred
parking
Evaluation NA
Incentives • Provide incentives to businesses that designate EV and AFV preferred
parking spaces
Plan or Program NA
Requirement(s) • Require EV and AFV preferred parking at new nonresidential developments
8.5.7 Opportunities for Additional Local Action to Decarbonize Transportation
Based on the analysis presented above on the authority of local jurisdictions to act, review of CAPs, and
scenario analysis of impact of commitments from CAPs in 2035, this section presents opportunities for
local jurisdictions to take further action to decarbonize transportation. In general, opportunities exist for
more jurisdictions to adopt and implement existing CAP measures and more aggressive measures like
the best adopted CAP commitments.
VMT Reduction
California has two laws relating to VMT reduction — SB 375 and SB 743.i SB 375 requires per capita VMT
reductions applicable to the regional transportation agency and SB 743 requires transportation
environmental impacts to be assessed based on VMT rather than the previous Level of Service (LOC)
criteria. Together, these indicate a shift from purely mobility-based planning to accessibility planning
where a multitude of modes are available for different users. The following local policy opportunities
can be viewed within this context.
Promote Mass Transit Use
CAPs identify mass transit as the single most important measure to achieve GHG reductions through
VMT reduction. Even while recognizing the significant role for regional cooperation for these measures,
jurisdictions still have significant opportunities to promote this mode to reduce VMT. Among these are
requirements are for new developments and existing developments to improve connectivity, increase
residential and job density. Studies have shown that for every 1% residential population density
increase, there can be a 0.22% decrease in VMT. CAPCOA estimates that up to 30% of GHG emissions
from new developments could be avoided through such actions.ii
Within their local jurisdiction, improved transit support infrastructure such as stations, bus depots, bus
shelters can promote mass transit use. A 2018 study by the Utah Transit Authority (UTA) compared
i California is not alone in adopting this approach. The state of Washington also has targets to reduce VMT per
capita by target years while exempting vehicles over 10,000 pounds, which are mostly freight and commercial
vehicles. This law in Washington also aims to reduce on-road GHGs from transportation which is also there, the largest single source of GHGs.
ii P.69, CAPCOA Handbook 2021.
Oct. 11, 2022 Item #12 Page 391 of 560
353
ridership and paratransit demand from before and after bus shelter improvements with a control group.
It found that improved bus stops are associated with a statistically significant increase in overall
ridership and a decrease in paratransit demand. The study concluded that between 2013 and 2016,
there was a 92% increase in ridership due to improved bus stops than at the control group stops, and a
94% decrease in ADA paratransit demand.i
Increasing network coverage and hours, increasing the frequency of service, reducing transit fares are
additional policies that may not be amenable to individual jurisdictional application. However, CAPCOA
estimates that increasing service hours can provide up to 4.6% GHG reductions within a community,
while increasing frequency can mitigate up to 11% GHG emissions from a community.ii Reducing transit
fares also has the potential to increase uptake and reduce GHGs by about 1.7% within a community.iii
However, implementing such changes may require collaboration with transit agencies and regional
transportation agencies. Therefore the likelihood that the GHG reductions estimated for mass transit in
CAPs becomes reality is heavily dependent on collaboration with regional agencies.
If mass transit is to be a regionally significant path forward to transportation decarbonization through
VMT reduction, then electrifying all equipment and transit vehicles would lead to additional reductions.iv
Mass transit also has a significant associated equity component in that it often serves those who have
the least ability to own a vehicle, or even when they do, has huge cost burdens imposed. Sections below
further evaluate the equity components of on-road transportation. A study by Washington statev on the
differential impacts of mass transit on different types of rural versus urban populations showed that
small businesses relying on long-distance workers, low income rural and low-income urban, agricultural
workers, very low density land areas would benefit less from mass transit than in urbanized areas. For
these areas other approaches such as vanpools, destination oriented alternative modes, providing
digital access to reduce the need to travel, ride-sharing programs are options to reduce VMT. SANDAG’s
most recent RP2021 appears to represent these findings.
Increase Bike and Walk Infrastructure to Increase Access to Basic Needs and Avoid VMT
There are opportunities for local jurisdictions to require alternative mode infrastructure to serve local
access and mobility needs from new developments, make active transportation plans a requirement of
new developments and evaluate the potential for additional active transportation (AT) in their city, and
assess the potential for ATs in parts of their jurisdiction. Local jurisdictions could increase cooperation
and coordination with neighboring jurisdictions and with regional walk and bike implementation
projects by SANDAG and prioritize walk and bike projects in communities of concern.
i Impacts of Bus Stop Improvements, Report No. UT-18-04, KY Kim et al, University of Utah, available at
http://mrc.cap.utah.edu/wp-content/uploads/sites/8/2015/12/UT-18.04-Impacts-of-Bus-Stop-Improvements.pdf.
ii P. 169, CAPCOA Handbook, 2021.
iii Id. at p. 183.
iv Electrifying the Nations’ Mass Transit Bus Fleets, available at https://info.burnsmcd.com/white-paper/electric-
bus-fleets. Also see the Road to Net-Zero Is Paved By Electric Buses, by Paola Massoli, May 19, 2020, available at
https://blog.greenenergyconsumers.org/blog/why-electric-buses-make-sense-now, citing a study by the Union of
Concerned Scientists at https://www.ucsusa.org/sites/default/files/attach/2019/04/Electric-Utility-Investment-
Truck-Bus-Charging.pdf that the average 40-foot diesel bus emits 2,680 grams of CO2 per mile (g/mi), an electric
bus charged on the average U.S. energy mix emits 1,078 g/mi, nearly 50% less.
v Carlson, D. and Howard, Z. Impacts of VMT reduction strategies on selected areas and groups, Evans School of
Public Affairs, Washington State Transportation Center, prepared for the State of Washington, December 20201,
available at https://www.wsdot.wa.gov/research/reports/fullreports/751.1.pdf.
Oct. 11, 2022 Item #12 Page 392 of 560
354
The bike, walk and complete streets policy subcategory is the single most frequent policy used in CAPs
and is likely consistent with local jurisdiction legal authority over land use and roads. The County is the
only jurisdiction to quantify a complete streets policy while all other adopted CAPs only quantify bike
and walk policies. There remains opportunity for more jurisdictions to incentivize bike, walk and
complete streets, develop plans and programs, and increase education and outreach. More jurisdictions
could increase evaluation of the impact of bike, walk and complete street to assess effectiveness and
determine the type of improvements that can be made.
Even while the overall GHG reduction potential of this policy subcategory is relatively low, bike, walk and
complete streets policies can be used to address long standing inequities, such as lack of access to basic
local needs (e.g., food, recreation, potentially employment), poor infrastructure, and there are multiple
health and safety benefits of active transportation to all residents and visitors.
Therefore opportunities exist for local jurisdictions to make this policy subcategory a requirement for
new developments and also to assess areas where active transportation plans would lead to increased
uptake of alternative modes for local access and mobility. An example of a recent active transportation
plan comes from the City of Encinitas.i Local jurisdictions could increase cooperation and coordination
with neighboring jurisdictions and with regional walk and bike implementation projects by SANDAG and
prioritize walk and bike projects in communities of concern.
Increase Connectivity through Land Use Changes to Avoid VMT
There are opportunities for local jurisdictions to increase connectivity by increasing residential or job
density, eliminating parking minimums, and permitting zoning changes to promote mixed-use
developments, which reduce distances to basic needs and promote VMT reduction. Opportunities to
increase density in specific in-fill areas have been identified in Chapter 3.ii According to CAPCOA, GHG
reductions from these actions can lead to GHG reductions of up to 30% in the project area, similar to the
promotion of mass transit described above.iii
Manage Transportation Demand
The literature suggests that demand management can be effective through a series of different
approaches, such as density bonuses for reduced parking, trip reduction programs through the
employer, such as mandatory and incentivized or voluntary commute trip reduction, cash-out parking
programs where employers pay workers to not drive, and employer and publicly supported vanpools.iv
Jurisdictions have the opportunity to implement Transportation Demand Management (TDM) policies
together with employers. SANDAG includes some of these programs within its TDM support programs.
Coordination with SANDAG can help identify additional opportunities for increased TDM uptake
especially with large private employers. Voluntary employer programs provide fewer GHG reductions
than mandatory programs, with a range reported by CAPCOA from 4% to 26% per employee, depending
i City of Encinitas Active Transportation Plan, August 22, 2018, available at
https://encinitasca.gov/Portals/0/City%20Documents/Documents/Development%20Services/Planning/Advanced%
20Planning/CMLS/ATP%20Council%20PPT%20Presentation%2008222018.pdf.
ii Areas in the region which meet infill definitions are provided in Chapter 3 of this report, page 70 ff.
iii P.123, CAPCOA Handbook 2021.
iv Carlson, D. and Howard, Z. Impacts of VMT reduction strategies on selected areas and groups, Evans School of
Public Affairs, Washington State Transportation Center, prepared for the State of Washington, December 20201,
available at https://www.wsdot.wa.gov/research/reports/fullreports/751.1.pdf.
Oct. 11, 2022 Item #12 Page 393 of 560
355
on the commute distances.i
Pricing policies such as road fees increased vehicle ownership fees also achieve VMT reduction but may
require regional coordination and cooperation. Peak period road and peak period parking pricing are
effective at reducing commute congestion but may also require regional cooperation. The extent of local
authority for congestion or other road pricing policies within their jurisdiction can be assessed.
Reduce Fuel Use through Efficiency
The following sections summarize opportunities for further action by local jurisdictions in the reduce
fuel use policy subcategory.
Improve Transportation System Efficiency
Because of the relatively few measures and actions within each CAP, the GHG reduction potential of
projects to improve efficiency of the overall transportation system is currently low. It is not possible to
assess the potential magnitude of reduction from increasing the number of such actions across the
region without significant coordination and cooperation in the region. As such, an opportunity exists to
increase regional cooperation and coordination to assess and implement regionwide traffic calming
measures, including traffic signal retiming (see regional cooperation section below).
While not quantified in CAPs, jurisdictions have opportunities to improve system efficiencies by
improving driver behavior actions, including to reduce vehicle idling. Examples of CAP measures would
be to promote fuel-efficient driving behaviors, work with school districts to improve idling time during
student pick up and drop off times, and limit construction vehicle equipment and idling through
ordinances and/or enforce such regulations where they already exist. These measures not only reduce
fuel waste and GHG emissions, but also criteria pollutants, which have local air quality and public health
benefit. California anti-idling regulations prohibit diesel trucks and buses, including school buses, from
idling for more than 5 minutes, with fines of $300-$1,000 per day. Local peace officers and the SD APCD
can enforce these regulations. There are no similar regulations for LDVs; however, such actions may be
within the police powers of a local jurisdiction to adopt and enforce. It is unclear whether a school
district may also regulate these types of emissions directly on their property.
Accelerate Vehicle Retirement
While the County has a program to advance vehicle retirement in their communities, CAPs generally do
not address vehicle retirement. This is an opportunity to reduce inefficient vehicles and replace them
with clean alternatives, including ZEVs. Vehicle retirement can be prioritized in Communities of Concern
which tend to have older less fuel efficient vehicles. Replacing them would also lead to significant air
pollution reduction with associated health benefits for all. California’s Voluntary Accelerated Vehicle
Retirement Program provides incentives to individuals to scrap their older more polluting vehicles and
replace with newer ones. This program is administered by certain air pollution control districts.
Jurisdictions have an opportunity to benefit from this program.
Alternative Fuels and Infrastructure
The following sections summarize opportunities for further action by local jurisdictions in the alternative
fuels and infrastructure policy category.
i P. 76, CAPCOA Handbook 2021.
Oct. 11, 2022 Item #12 Page 394 of 560
356
Increase Use of Alternative Fuel Vehicles in Municipal Fleets
There is an opportunity for local governments to increase use of alternative, low-carbon fleet fuels in
addition to ZEVs, particularly for medium- and heavy-duty vehicles but regional study could assess the
availability and funding requirements for non-electricity alternative fuels (see below, regional
cooperation). More local jurisdictions could address both ZEVs, EVCS and non-electric fuels for their
fleet. While the associated GHG reduction based on our scenario analysis may be low (currently 5%,
Figure 8.26) depending on the size of the municipal fleet, every municipality can implement a fleet
conversion program based on studies initiated through SANDAG in the years 2012-2018.i Jurisdictions
could leverage and implement the existing fleet greening studies and plans within their CAPs.
The conversion of school buses to EVs is addressed in several CAPs. Cities could work with all school
districts to obtain funding for a regionwide school bus transition. A larger question relating to school
buses is to assess whether the school bus system can be part of the public transit system, as is common
in European countries.ii College students in the San Diego region are already a large source of
passengers to the public system, and including school-going passengers would increase the use of the
public transit system in place of several scattered privately operated systems.
Assess the Social Equity trade-offs between ZEVs and Mass Transit
As discussed above, there is little or no integration of social equity in CAP on-road transportation
measures. An opportunity exists for local jurisdictions to collaborate to assess the equity impacts of ZEV
use versus increasing use of mass transit in all communities, and to align regional transportation equity
analysis (e.g., SANDAG) with CAP equity analyses (e.g., City of San Diego).
Opportunities for Regional Collaboration and Coordination
On-road transportation is especially suited to regional action over local jurisdictional action because
interconnections are needed between jurisdictions to serve basic needs. VMT reduction through
improved connectivity and mass transit, ZEV uptake, and social equity integration could be more
effective through a regional approach rather than through individual CAPs. A summary of opportunities
is presented below.
Increase Regional Cooperation to Integrate Social Equity
Because transportation planning has significant long-term implications for social equity, it is important
to coordinate and integrate equity-specific considerations into CAPs in coordination with other regional
equity assessments. Although SANDAG has considered social equity in the 2021 Regional Plan in a much
more significant manner than in previous versions, the City of San Diego has developed an equity index
for guiding city-funded projects and integrated social equity into its 2021 CAP update, the City of Chula
i The SANDAG Energy Roadmap Program 2012–2018 provided free energy assessments and development of energy
roadmaps including for municipal fleets and facilities. Specific reduction potentials for greening the fleet were
estimated for jurisdictions, as desired, with associated fuel savings and GHG reductions. See
https://www.sandag.org/index.asp?projectid=373&fuseaction=projects.detail.
ii See, The Existing school transportation framework in Greece — Barriers and problems comparing to other
European countries, which provides the common practices among European countries. In Germany for example,
certain routes are set up to serve schools at school times. The paper report that in Germany, about 40% of
students aged 6 to 16 years are daily transferred either by public buses for two hours in the morning and two
hours in the afternoon and where the schedule is adapted to schools’ needs and some jurisdictions offering tickets at discounted rates for school children. Safety is implemented by flashing lights similar to California and federal law
sets speed limits at 50 and 80 km/hr for urban and interurban areas respectively.
Oct. 11, 2022 Item #12 Page 395 of 560
357
Vista has also developed an equity index related to climate action, all based on significant inclusive
participation, an opportunity exists for increased coordination between these equity efforts and
analyses.
Similar to our review of CAPs, a literature survey shows that there is no accepted definition of equity in
transportation; however, without equitable distribution of resources in the transition to a low carbon
economy, the benefits of the transition will be felt disproportionately by low income communities for
reasons explained in the sections below.
SANDAG’s equity analysis (App H SANDAG RP2021) considers three population groups that represent
disadvantaged populations in the ABM transportation model: minorities, low-income populations, and
seniors. Demographic thresholds were selected to determine the type of mobility needed for these
groups and this section focuses on low income and seniors. The threshold for seniors was selected as 75
years of age, where mobility is still a concern, but would convert to transit rather than passenger
vehicle. While there is significant regional variation, the low-income population was defined as having
income at or below 200% of the 2016 federal poverty level, and this constituted 25% of the region’s
residents. In addition, 9.8% of the civilian population is classified as disabled, and this is also a group that
needs access to basic needs through transit or special programs. Households with no vehicle available
was also considered, which constituted 5.7% of all households in the region.
Therefore, according to SANDAG’s analysis in its RP2021, more than 30% of the region’s households
would be good candidates for transit use. Figure 8.27 shows that more than 30% of households with less
than $60,000 income walk and/or use transit for all trips data.
Figure 8.27 Household Income by Means of Transportation to Work (SANDAG 2016 Regional Transportation Study,
Volume I, Figure 8.26).
The transportation cost burden of people living in the San Diego region (based on the City of San Diego
as representative) are of the order 100 times greater than their household energy cost burden. The
average transportation cost burden (transportation costi as a % of median income adjusted for
i Transportation cost considers the costs associated with vehicle ownership and usage and use of public
transportation.
Oct. 11, 2022 Item #12 Page 396 of 560
358
household income) for a San Diego resident is 21%, while the energy cost burden (energy cost as % of
median income adjusted for household income) is 2%. The transportation cost burden ranges from
slightly less than 10% to nearly 60% of median income (adjusted for housing cost). Those spending more
than the average 21% all have a median housing-adjusted income less than about $70,000 (Figure 8.28).
Figure 8.28 Transportation Cost Burden, City of San Diego 2010 Census Data, ACS Estimate for 2016.
This very high average transportation cost burden is much higher than the 13% average across the U.S.,
which in turn is considerably higher than any other developed country in the world. As quoted by the
Institute for Transportation and Development Policy (ITDP), “[i]n the US, there is a narrative that if
people work hard, then they can get out of poverty, but we have built cities that make this narrative
impossible. For households making less than $20,000 per year, reliable cars are a pipe dream: a huge
expense that they can’t afford. Without adequate transit, they will remain stuck in place.”i If this is still
correct, for these populations, implementing the SANDAG RP2021 could provide an expanded, fast,
clean, and reliable transit access system designed to result in out-of-pocket transportation costs
decreasing from 5.1% in 2025 to 4.4% in 2050 if implemented.ii
Yet another indicator helps visualize the relatively obvious links between income and vehicle ownership.
Though yet to be developed for San Diego County, for the United States, a recent report from the
International Council on Clean Transportation (ICCT) shows that U.S. households earning less than
$25,000 spend about 50% of their income on vehicle ownership and maintenance not including
registration, financing, or parking costs. Figure 8.29 shows this relationship for the United States.
i Indicators for Sustainable Mobility, ITDP Report.
ii SANDAG RP 2021, Appendix H: Social Equity: Engagement and Analysis, p. H-54.
Oct. 11, 2022 Item #12 Page 397 of 560
359
Figure 8.29 Vehicle Ownership and Transportation Equityi
In addition, even when low income households have vehicles, they tend to be older, more polluting, and
require more maintenance, therefore have higher costs. In contrast, recent reportsii show that, when
adjusted with federal EV incentives, and for all EVs analyzed, the lifetime ownership costs were much
lower than all comparable internal combustion engine vehicles. In addition, the cost savings of 5- to 7-
year-old used EVs was found to be two or three times larger on a percentage savings basis. A question
arises whether the cost of owning an EV, used or not, over its lifetime, is more affordable especially for
low-income households, than using mass transit. Either way, subsidies and initial capital costs would
have to be provided.
The ICCT study on equity impacts of EV adoption also demonstrates that low income communities in
cities that have relatively poor mass transit would benefit significantly from EV assistance uptake in
terms of cost savings, apart from air pollution reduction.
In the San Diego region, the A2Z EV Gap Analysis identified about 290,000 PEVs or FCEVs needed for
multifamily and single family households in communities of concern out of the total over 770,000 ZEVs
needed to meet the region’s share of EV goals. That report also recognizes that moderate and low
income households will need support to purchase ZEVs. How these requirements match the SANDAG
assumptions for increased access to transit has not been examined and could constitute a gap in the
demand by 2030. A major barrier to ZEVs from this study is the “perceived and real cost premium of the
vehicles,” followed by insufficient ZEV public, workplace and multifamily households and the perception
that ZEV fueling is “not affordable to most.” Despite that, acceleration of EV adoption in communities of
concern is a major issue often raised in CAP stakeholder meetings because ZEVs are seen as a way to
improve air pollution and noise.
i Taken from Figure 1. Source: Gordon Bauer, Chih-Wei Hsu, and Nic Lutsey: When might lower-income drivers
benefit from electric vehicles? Quantifying the economic equity implications of electric vehicle adoption. International Council on Clean Transportation Working Paper 2021 -06, February 2021.
ii https://www.consumerreports.org/hybrids-evs/evs-offer-big-savings-over-traditional-gas-powered-cars/.
Oct. 11, 2022 Item #12 Page 398 of 560
360
Therefore, by identifying the communities of concern with low-income households in the region, and
targeting transportation electrification in these areas provides an opportunity to mitigate GHGs for the
future but also to address historical inequities. Along with this, local jurisdictions could assess the cost of
increased ZEV access in communities of concern (short-term and lifetime costs per GHG avoided)
compared to an electrified mass transit system (costs per unit of GHG emissions avoided over the
lifetime of the system) both for the region and for low-income households.
Chapter 3 already identified areas with communities of concern which can be targeted and while
prioritizing communities of concern for EVs does not provide additional GHG reductions. It does help to
re-distribute the benefits, including reducing criteria pollutants.
An opportunity exists to assess the reduction in air pollutants from conversion to electric transportation,
including in school buses. In a follow-up to a Harvard Six Cities Study, which examined the relationship
between improvements in ambient PM2.5 and city-level mortality, a comparison of the 1974–1989
period with a follow-up period, 1990–1998, showed that every 10-mg improvement in city-level average
annual PM2.5 was associated with a 27% improvement in the relative risk of death.
Because transportation planning has significant long-term implications for social equity, there is an
opportunity to integrate equity-specific considerations into CAP and to coordinate with regional
approaches, including SANDAG’s equity assessments. Although SANDAG has considered social equity in
the 2021 Regional Plan more than in previous versions, and the City of San Diego has developed an
equity index for guiding city-funded projects, there is room for increased coordination between
SANDAG’s equity analysis, local equity policies, and climate action planning. Another option is for cities
to coordinate and cooperate through SANDAG to integrate social equity into all future transportation
projects supported by funding.
Increase Regional Collaboration to Increase Transportation System Efficiency
Traffic calming measures have ripple effect across boundaries, and regional cooperation could help to
assess opportunities for regionwide fuel use reduction actions. Installing roundabouts in one jurisdiction
could cause back-ups along the same arterial in another jurisdiction. An example of a regional
roundabout study is one done for Monterey County, where 26 area intersections as proposed by cities
and county were used to identify a prioritized list (Figure 8.30) to help guide roundabout investment
regionally, but also by jurisdiction.
Oct. 11, 2022 Item #12 Page 399 of 560
361
Figure 8.30 Example Results of a Regional Roundabout Study, Monterey County, 2016. Green symbols represent
roundabouts with a positive Benefit-Cost Ratio.
Develop a Regional ZEV Implementation Plan to Meet State Targets
Neither SANDAG incentives for ZEVs nor the additional CAP-based ZEV uptake appear able to reach the
2035 targets for ZEVs for the region estimated in Chapter 3. The opportunity to assess this gap and
develop an implementation plan following the A2Z Gap Analysis report has just started. Coordinating
with CAP measures when updating, including when adopting electric vehicle infrastructure ordinances
for new and significant retrofit construction, could improve regional approaches to increasing ZEV
uptake.
Regional Action Could Lead to Additional GHG Emissions from On-road Transportation
VMT reduction through improved connectivity and mass transit, ZEV uptake, and social equity
integration could be more effective through a regional approach rather than through individual CAPs. An
opportunity exists to coordinate between the regional planning process and the local climate action
planning process to accelerate GHG reduction from on-road transportation. Working with private sector
employers can also help achieve the state goals for GHG reduction.
Assess availability of biofuels for use in fleets
The availability of biofuels for municipal fleets could be assessed especially as more cost-effective short-
Oct. 11, 2022 Item #12 Page 400 of 560
362
and medium-term solutions emerge for heavy-duty vehicle conversion. U.S. production of renewable
diesel, for example, is expected to increase significantly through 2024 and it receives favorable scores
under the LCFS, which incentivizes its use.i Similarly, biodiesel is in high demand for heavy-duty trucks,
although its crop-based needs create a limitation.ii A regional assessment of the benefits and challenges
of using these fuels and their availability and price could help municipalities decide on short-term low-
carbon options for their immediate fleet turnover needs while waiting for more mass availability of
electric or hydrogen-fueled HDTs.
Assess the use of LCFS funding to promote transition to lower carbon fuels
There may be an opportunity to use cap and trade funds through the LCFS to aid in fleet electrification
or transition to a lower carbon fuel. While clean vehicle rebates and incentive programs are phasing out,
the LCFS requires reduction of carbon intensity of fuels over time, and there is market for buying and
selling LCFS credits which can assist in the transition. For example, owners of public EVCS can generate
and sell credits for EV charging. ICCT has shown how the LCFS can support transport electrification,
including the potential for a small revenue stream from home charging that can reduce the cost of
individual EV ownership.iii
Increase regional program development
Providing program development and implementation resources for local measures, including shared,
reduced, or alternative fuel vehicle preferred parking standards; transportation demand management
plans; pedestrian and bicycle infrastructure; improved traffic flow projects; and smart growth
development could help increase awareness and availability of current regional programs and funding
opportunities to increase current participation levels.
Through its ReCAP, SANDAG has provided services to most cities in the region to support climate action
planning activities, including developing and providing templates for methods and monitoring, applying
them to the development of CAPs, and monitoring metrics related to GHG mitigation measures, and
providing results in the form of annual ReCAP Snapshots. SANDAG has developed and hosts the CAP
data through a publicly available Climate Action Data Portal. The ReCAP program has led to some level
of consistency in CAPs across the region, allows the tracking of CAP measure progress over time, and the
monitoring of overall GHG reduction activities in the region.
Such programs could be expanded and new programs and funding mechanisms could be identified to fill
gaps where it appears goals are not being met. Improving the coordination between CAP data gathering
and metric tracking and those that SANDAG must track by regulation, especially under SB 375, can
potentially identify new programs and funding mechanisms to accelerate the achievement of the State
and regional climate and energy goals.
Increase Sub-regional Collaboration
Apart from increased cooperation with the MPO, jurisdictions can work directly with transit agencies to
identify gaps in service, prioritizing communities of concern, and identifying funding for its increased
local policy adoption and implementation.
i U.S. renewable diesel capacity could increase due to announced and developing projects, U.S. Energy Information
Administration, July 29, 2021, at https://www.eia.gov/todayinenergy/detail.php?id=48916.
ii Biodiesel is booming. At https://www.npr.org/2021/10/28/1043413986/biodiesel-is-booming-it-may-help-the-
climate-but-theres-a-big-environmental-risk.
iii Kelly, C. Blog, How low-carbon fuel standards cab support transport electrification, August 6, 2020, at
https://theicct.org/how-low-carbon-fuel-standards-can-support-transport-electrification/.
Oct. 11, 2022 Item #12 Page 401 of 560
363
Accelerate EV Adoption through Joint Powers Agreements
CCA programs in the region represent a local mechanism, usually through JPAs, which can support
transportation electrification by developing programs to incentivize EV uptake beyond state and federal
programs. Examples of local CCA programs that will accelerate EV adoption are summarized in Table
8.22. Once launched, a CCA is completely funded by revenues and not taxpayer dollars. As a result,
surplus funds generated by the CCA can, and often are, used to fund projects to reduce GHGs. It remains
to be seen whether the multiple CCAs currently being formed in San Diego County will follow the
examples given below.
Table 8.22 CCA Programs to Accelerate Transportation
Community
Choice
Aggregator
Number of
Customers
(Accounts)
Transportation Electrification Program - On-
going or Planned Collaboration Needs Addresses
Equity?
Clean
Power
Alliance
1 million
Public EV Charging: incentives to non-
residential customers to install electric
vehicle (EV) chargers that are available for
public use
Pilot Program: EV Chargers: Available to
commercial customers with at least three
Level 2 EV chargers, this program asks
participants to allow their EV chargers to
operate at a reduced rate of charge during
peak events
Collaborate with CALeVIP
and local air resource
boards to expand funding
and expedite
implementation of EV
infrastructure incentives for
CPA customers.
-
Central
Coast
Community
Energy
350,000
Electrify Your Ride: designed to provide
CCCE customers with a “one-stop-shop”
process to apply for post purchase incentives
for one or more of the following four (4)
rebates: EVs, EV Chargers, EV Readiness and
Electric Bikes making this program the single
largest energy program budget to date.
Funds exhausted.
Electrifying our community’s school buses
for a cleaner, healthier and safer Central
Coast. Central Coast Community Energy is
funding up to $200,000 per bus for public
school districts throughout our service area.
50% matching funds requirement to
complete the bus purchase after the CCCE
incentive.
South Central Coast
Incentive Project: with
CALeVIP ($1.75 million)
Central Coast Incentive
Project: with CALeVIP (CEC
and CCSE) and Monterey
Bay Community Power ($7
million), for non-residential,
multi-family, non-profits and
LGs EV chargers in 3
counties
$295,000 given in rebates, funds exhausted
Collaborate with Monterey
Bay Air Resource District:
will replace 6 school buses,
fund exhausted
Yes, based on
Tier 1 and Tier
2 income
classification
CCCE
contributed
$1.75 million of
$12 mi from
CALeVIP, 50%
for DACs
Marin Clean
Energy 450,000
EV rebates for new, used and leased
vehicles, up to $3,500;
Website pointing to multiple state rebates,
CVRP, BAAQMD, PG&E incentives, and
federal tax incentives.
- Yes, income
qualified
Oct. 11, 2022 Item #12 Page 402 of 560
364
Community
Choice
Aggregator
Number of
Customers
(Accounts)
Transportation Electrification Program - On-
going or Planned Collaboration Needs Addresses
Equity?
Peninsula
Clean
Energy
295,000
EV rebates for used and new plug-in hybrid
and battery EVs up to $4,000; also for rentals
EV Ready Program: $28 million funded by
CCA for 3,500 EVCS in county in 4 years
-
Yes, increased
rebates for
income-
qualified
residents
Redwood
Coast
Energy
Authority
62,000
RCEA customers are eligible for a rebate
totaling 50% of whatever incentive amount
they received from the CVRP. Applicants can
only apply for RCEA’s rebate if they have
already been approved by the state CVRP
program, total available $50,000
Residential EV Charging Equipment Rebate
$500, $24,000 available
E-bike rebate $500 ($41,500, funds
exhausted)
- -
San Jose
Clean
Energy
350,000
Park for free at all City of San Jose parking
meters
Website pointing to multiple state rebates,
CVRP, BAAQMD, PG&E incentives, and
federal tax incentives.
Partnership with CEC to
offer light-duty fleet vehicles
rebates on Level 2 chargers.
-
Santa
Barbara
Clean
Energy
EV cash-back: customers are eligible
for $1,500 cash back on Chevy Bolt EV and
EUV and $1,000 cash back on any used BEV
and PHEV; e-bicycle membership 20% cost
share
- -
Silicon
Valley Clean
Energy
270,000
Website pointing to the multiple state
rebates – CA vehicle retirement program, CA
HOV exemption, AC Clean Fuel Reward for
new or lease, CVRP, Beneficial State Bank
<8% interest loans, PG&E rate plans,
Community Housing Dec Corp grants,
BAAQMD incentives including toll discounts
on bridges, and federal tax incentives.
- -
Sonoma
Clean
Power
224,000
EV rebates: $12,500 to non-profits which
purchase or lease an EV or plug-in hybrid
with range at least 25 mile
- -
Valley Clean
Energy 55,000
Website pointing to multiple state rebates,
CVRP, BAAQMD, PG&E incentives, and
federal tax incentives.
- -
Oct. 11, 2022 Item #12 Page 403 of 560
365
8.6 Decarbonize Buildings
In the San Diego region, about 8 MMT CO2e of GHG emissions is associated with electricity and natural
gas end use, much of which is associated with energy use in buildings. GHG emissions associated with
buildings come from the electricity to serve the building and the fuel (e.g., natural gas) combusted in the
building for various end uses. This section focuses on reducing energy used in buildings and switching
from natural gas and other fossil fuels to electricity for building equipment. Decarbonizing the electricity
supply, which is sometimes considered part of building decarbonization, is addressed in Section 8.7.
In general, there are three main methods to reduce GHG emissions from buildings: (1) reducing energy
use through increased efficiency, (2) electrifying building appliances, and (3) increasing use of low-
carbon fuels. Implicit in this is the decarbonization of the electricity supply. Supplying clean or zero
emissions electricity to all-electric appliances not only reduces emissions at the power plant but also in
the building. There are no CAP measures related to use of low-carbon fuels in buildings; therefore, we
provide only limited analysis of this policy category.
The policy categories and subcategories related to decarbonize buildings will be the organizing
framework for the following sections (Figure 8.31). We evaluate various aspects of each of these,
including the legal authority of local jurisdictions to act; existing local commitments in CAPs, including
analysis on the frequency and distribution of measures across all adopted and pending CAPs and the
relative GHG contribution of measures; opportunities for additional local action; and opportunities for
regional collaboration.
Policy Category Policy Subcategory
Electrification Electrify Select End-Uses
All-Electric
Energy Efficiency Audit, Benchmarking, Disclosure
Implement Efficiency Improvement(s)
Low Carbon Fuels TBD
Figure 8.31 Policy Categories within the Decarbonize Buildings Pathway
8.6.1 Summary of Findings
Table 8.23 presents a summary of key takeaways for the decarbonizing buildings pathway.
Oct. 11, 2022 Item #12 Page 404 of 560
366
Table 8.23 Summary of Key Takeaways for the Decarbonize Buildings Pathway
Policy Category Key Takeaways
Energy
Efficiency
All adopted and pending CAPs have related measures; relatively low GHG reductions in CAPs;
least regret opportunity for more jurisdictions to exercise existing authority to adopt reach
codes for new construction, alteration, and addition projects; need to reduce energy use in
existing buildings; GHG impact of energy efficiency declines as the electricity supply
approaches 100% carbon free and appliances are electrified; full authority to act is not
exercised in the region.
Electrification
Relatively few CAPs with measures to electrify buildings; low GHG impacts in CAPs; least
regret opportunity for reach codes for new construction, alteration, and addition projects;
need to electrify existing buildings; existing authority provides multiple paths to electrify new
and existing buildings; full authority to act is not exercised in the region.
Low Carbon
Fuels
No CAP measures use low-carbon fuels in buildings; limited analysis completed; additional
research needed; there is existing authority to act in this regard but uncertainty exists; the
extent of authority is untested and legal risk is dependent on action taken; full authority to
act is not exercised in the region.
Key Findings of Analysis
This section summarizes results of the review of authority to act, the review of CAPs, and scenario
analysis of the aggregated impact of CAPs.
• Authority Exists to Regulate GHG Emissions from Building End-Uses – The police power and
delegated authority to regulate energy end-uses are primary means of implementing building
decarbonization. Police power may be exercised to prohibit natural gas plumbing in new
buildings, require energy benchmarking outside of Title 20, and/or encourage fuel switching to
low- or zero-emission fuels (e.g., renewable natural gas or green hydrogen) through GHG
emission performance standards based on energy benchmarking information. Local jurisdictions
also act with delegated authority over the built environment to require more stringent Title 24,
Part 6 Energy Codes and Part 11 CalGreen Codes, directly regulate criteria pollutant emissions
from buildings, or use their procurement authority, including sole source procurement authority
for energy conservation, cogeneration, and alternative energy supply projects on public
buildings. CEQA also may allow a lead agency to set a GHG-based threshold of significance for all
projects (e.g., carbon neutral or net zero) that decrease building emissions. Local governments
are preempted from establishing energy efficiency appliance standards, regulating natural gas
supply, transmission, and storage, and high global warming potential refrigerants (e.g., HFCs).
• CAPs Have Relatively Few Measures to Electrify Buildings – Only seven CAPs include measures
related to building electrification. By contrast, all adopted and pending CAPs have measures
related to energy efficiency. Most building electrification measures focus on new construction
projects, with the exception of two CAPs which have measures related to electrifying existing
buildings, which focus on electrifying water heating appliances. As noted above in Section 8.2,
depending on the policy approach related to water heating, federal pre-emption concerns may
exist. Based on the relative lack of CAP measures to electrify buildings and the GHG implications
as presented in the scenario analysis, the current commitment to electrification in CAPs is
insufficient to achieve the level of building equipment electrification contemplated in Chapter 4.
• GHG Impact of Building Decarbonization Measures in CAPs is Relatively Low – GHG reductions in
CAPs associated with efficiency and electrification are relatively low. Based on our review of
CAPs, measures related to efficiency contributed about 8% on average to the local CAP
reduction, while electrification contributed about 4%. Based on our scenario analysis, applying
the most aggressive adopted CAP policy to every jurisdiction in the region would increase
Oct. 11, 2022 Item #12 Page 405 of 560
367
estimated GHG reductions in 2035 from about 40,000 MT CO2e to over 720,000 MT CO2e. The
increase would be due mostly to an increase in energy efficiency retrofits. Including the City of
San Diego draft 2022 CAP update measures related to building decarbonization would increase
these GHG reduction values (Section 8.4.5). By contrast, a similar application of the best
renewable electricity supply policy would reduce GHG emissions by about 1.6 MMT CO2e. It is
important to note that GHG reductions from efficiency improvements in electric appliances
decline over time as the electric supply approaches 100% carbon-free and more appliances are
electrified. However, California is developing dynamic time-dependent electric rates and energy
efficiency programs that balance supply and demand to integrate renewable energy and
decrease marginal carbon emissions.
• Policies for the Existing Building Stock are Key to Decarbonize Buildings – Decarbonizing existing
buildings is an important step in reaching regional emissions targets. Buildings that exist in 2021
will represent more than 80% of the buildings that will exist in 2050. State building energy codes
regulate alterations and additions to certain existing buildings, but local policies could further
encourage or require energy efficiency and electrification in many other existing buildings.
There are many examples in the San Diego region and California of policies to increase energy
efficiency in existing buildings, including those to require energy assessments, benchmarking
and disclosure of energy use, efficiency improvements, and retro-commissioning or building
tune-ups. By contrast, there are few policies in California to electrify existing buildings. Most
existing policies focus on new construction, alterations, and additions. Consequently, there are
almost no policies at the local level to require existing building electrification, though efficiency
policies potentially can provide the blueprint for policy development in this area. There are,
however, some market barriers to electrification in the existing building stock, including
consumer preferences and awareness, upfront cost hurdles, and workforce development needs
that would have to be overcome to achieve widespread electrification. Key elements of an
integrated strategy to decarbonize existing buildings include education and outreach, financial
incentive and financing, and requirements.
Opportunities for Further Action
The following summarizes key opportunities for further action.
• Decarbonize New Buildings – Local jurisdictions have the authority to adopt local building codes,
including reach codes to encourage or require energy efficiency and electrification. Because only
four CAPs include at least one measure to require energy efficiency improvements in new
buildings and only four have measures related to electrifying new buildings, there is opportunity
for more local jurisdictions in the San Diego region to adopt these policies. California has a
history of local governments adopting local ordinances to improve energy efficiency, and
numerous examples exist in the San Diego region and around California. Ordinances to require
electrification are relatively new, though an increasing number of local jurisdictions have
adopted local building electrification requirements that go beyond state requirements or have
used their police powers to adopt a moratorium on natural gas infrastructure. Given authority to
act, the numerous examples around California, and existing support to develop and implement
such policies, adopting reach codes is a least regret policy; however, this opportunity may be
limited in its potential to reduce GHG emissions due to regular updates to the State building
energy code.
• Local Governments Can Decarbonize Municipal Facilities – Just over half of CAPs have measures
to improve efficiency at municipal facilities, and none have measures to electrify these facilities.
The federal government has recently adopted a commitment to achieve net zero emissions in
federal facilities. This is a least regret policy as implementing cost effective measures helps
Oct. 11, 2022 Item #12 Page 406 of 560
368
reduce operating costs and can model the type of actions local governments may encourage
homes and businesses to do.
• Regional Collaboration to Support Building Decarbonization – Given the clear, existing authority
that local governments have to adopt local building codes (e.g., reach codes) for new buildings
and the existing knowledge and experience in the region and statewide, developing a regional
approach to support reach code development, adoption, and implementation is a least regret
approach. A similar program could be developed to support efforts to decarbonize the existing
building stock, including analyzing existing building stock, convening an existing building
decarbonization task force, developing a regional strategy to decarbonize the existing building
stock, and a policy development support program similar to the reach code example.
• Assess Social Equity Considerations of Building Decarbonization Policies – In the context of
building decarbonization, there are several aspects of equity to consider, including the high
proportion of renters in communities of concern, the relative lack of data and analysis related to
equity and building-related policies, and potential cost implications of building decarbonization
policies, particularly electrification. Additional work would be needed to develop the capacity
and tools to understand and address the equity implications of building and other
decarbonization policies in the San Diego region.
8.6.2 Summary of Authority in the Decarbonize Buildings Pathway
At the local level, the police power and delegated authority to regulate energy end-uses are the primary
means of implementing building decarbonization actions. Local jurisdictions may use their police power
to prohibit the installation of natural gas plumbing in new buildings,i identify buildings or neighborhoods
that are in need of natural gas infrastructure replacement to electrify (e.g., natural gas infrastructure
pruning), require energy benchmarking for buildings not covered by Title 20 Benchmarking
requirements,ii and/or encourage fuel switching to low- or zero-emission fuels (e.g., renewable natural
gas or green hydrogen) through GHG emission performance standards based on energy benchmarking
information and disclosure. Local jurisdictions can act with delegated authority to require more
stringent Title 24, Part 6 Energy Codes, Part 11 CALGreen Codes, and procurement authority, including
sole source procurement authority for energy conservation, cogeneration, and alternative energy supply
projects on public buildings.iii Local governments could evaluate how to align local requirements and
actions with state policy and programs to decrease costs related to building decarbonization.
Energy Efficiency and Building Material Conservation and Resource Efficiency
Using delegated authority, local jurisdictions may adopt more stringent building code standards that
address energy efficiency, water conservation, building material conservation, or resource efficiency
based on GHG requirements (e.g., material carbon intensity). Where the requirement addresses energy
consumption, the adopted local code (e.g., all-electric reach codes or building performance standards)
must be at least as energy efficient as the state codes, cost-effective,iv and submitted to the CEC to
i Note: the City of Berkeley’s prohibition is currently on appeal to the Ninth Circuit Court of Appeals (CRA v. City of
Berkeley, No. 21-16278, (9th Cir.), filed August 5, 2021); See CRA v. City of Berkeley, Docket No. 4:19-cv-07668,
Judgment, Document 76 (N.D. Cal. Nov. 21, 2019) which dismissed with prejudice cause of action for EPCA
preemption and dismissed without prejudice California state law preemption cause of action.
ii See AB 802 (Williams, Chapter 590, Statutes of 2015); 20 C.C.R. § 1680 et seq. (2021); see also City of San Diego
Building Benchmarking Ordinance adopted pursuant to 20 C.C.R. § 1684 (2021). iii See Government Code § 4217.10 et seq.
iv See to Public Resources Code § 25402.1(h)(2) and Health & Safety Code §§ 17958.5 & 17958.7.
Oct. 11, 2022 Item #12 Page 407 of 560
369
review for compliance with state law.i In all cases where Title 24 is amended, the standards must be
submitted to the Building Standards Commission with the findings for local climatic, geological, or
topical conditions that authorize the change to Title 24. In terms of police authority, the full extent of
local jurisdiction police authority is unknown and largely untested. Additional research is required to vet
other local actions.
Federal preemption exists over setting energy efficiency standards for covered productsii (e.g.,
appliances) under EPCA with limited exception for new construction.iii Local jurisdictions are subject to
state preemption in the form of Title 20 appliance standards that regulate many appliances not
preempted by the EPCA and the triennially updated Title 24 building standards that the CEC adopts.
CEQA Environmental Impact Mitigation Authority
CEQA offers another means to address emissions from the built environment. A lead agency acts with
discretion to determine whether an adverse environmental effect identified in an environmental impact
report (EIR) should be classified as "significant" or "less than significant."iv A lead agency may adopt and
publish a threshold of significance that sets a high threshold for GHG emissions, which could include
requiring all projects to be carbon neutral or zero net carbon,v and must be based on scientific and
factual data to the extent possiblevi to meet the substantial evidence standard.vii This is limited by
existing implied or expressed authority to impose mitigation measures on a project.viii Mitigation
measures cannot be legally infeasibleix — meaning that they may not be beyond the power conferred on
lead and responsible agencies — and are also subject to express limitations, including limits on reducing
housing units.x
Direct Regulation of Building GHG Emissions
Direct regulation of GHG emissions, not currently regulated by Cap-and-Trade, may provide additional
means to reduce emissions, but uncertainty exists around authority.xi It may be possible to create GHG
performance standards for buildings.xii Under existing authority, it may be possible to directly regulate
building and appliance oxides of nitrogen (NOx) emissions from natural gas.xiii Finally, it is uncertain
whether existing tax or fee authority may be used to regulate GHGs.xiv
i See Public Resources Code § 25402.1 (h)(2); see Title 24, Part 6, Section 10-106 (2021).
ii 42 U.S.C. § 6295; See also 10 CFR Parts 430, 431, & 429.
iii 42 U.S.C. §§ 6297(c) & 6297(f)(3); See also 42 U.S.C. §§ 6291 et seq. (Part A-Energy Conservation Program for
Consumer Products Other Than Automobiles); 42 U.S.C. §§ 6311 et seq. (Part A-1-Certain Industrial Equipment).
iv 14 C.C.R. § 15064(b)(1) (2021).
v 14 C.C.R. § 15064.7(b) (2021); see also definition of “threshold of significance” under 14 CCR § 15064.7(a) (2021).
vi 14 C.C.R. § 15064(b)(1) (2021).
vii Mission Bay Alliance v. Office of Community Inv. & Infrastructure, 6 Cal. App. 5th 160, 206 (2016).
viii See 14 C.C.R. § 15040(d)–(d).
ix See Public Resources Code § 21004; See 14 C.C.R. § 15040.
x See Public Resources Code § 21159.26; See 14 C.C.R. § 15092(c).
xi 17 C.C.R. §§ 95811 (a)–(b) & 95812(c).
xii See Health & Safety Code §§ 17958.5, 17958.7, and 18941.5(b); See California Public Resources Code § 25402.10
(d)(2)(F) & 20 C.C.R. § 1684; See City of Berkeley Municipal Code 19.81 – the Building Energy Savings Ordinance
(BESO) (2021). xiii See Health & Safety Code §§ 39002, 39013, 39037, and 41508.
xiv See Cal. Const. art. XIII C & D.
Oct. 11, 2022 Item #12 Page 408 of 560
370
Fuel Switching and Emissions related to End-Uses
Police power authority may be used to require fuel switching to low or zero-carbon sources through
prohibitions on the installation of certain energy infrastructure (e.g., natural gas plumbing) in buildings.
Police power may take the form of adopting an ordinance that expressly prohibits natural gas plumbing
without either amending Title 24, Part 6, changing minimum efficiency standards for covered products
under the EPCA, or requiring the installation of specific appliances or systems as a condition of
approval.i There is currently an effort to preempt local jurisdiction police power under the EPCA. The
City of Berkeley’s Ordinance No. 7,672-N.S. adopted on July 16, 2019, used police power without
amending Title 24 to prohibit natural gas plumbing in new construction. This ordinance survived the
preemption challenge in federal district court and is now on appeal in the Ninth Circuit.ii
Local jurisdictions also act with authority to develop local hydrogen production and infrastructure
through land use, constitutional authority to provide municipal services under California Constitution
Article XI, § 9, franchise agreement authority, and police power authority. The CPUC would regulate
intrastate hydrogen pipelines as a public utility if not owned by a municipal-owned utility.iii End-uses
that depend on ozone-depleting substances (ODS) and ODS substitutes with high-GWP gases,
particularly HFC refrigerants, are subject to federal and state regulations that ban, limit or phase out the
regulated substance offering an opportunity to act locally to accelerate and augment these regulations.iv
Finally, there is an opportunity to engage in the legislativev and regulatory (CPUC) process on the future
of natural gas infrastructure.vi
8.6.3 GHG Impacts of CAP Measures in the Decarbonize Buildings Pathway
This section summarizes the GHG impacts from CAP measures related to building decarbonization,
including those from the review of CAPs and the scenario analysis of GHG Impacts.
i See City of Berkeley Ordinance No. 7,672-N.S. (Adopted July 16, 2019), City of Morgan Hill Ordinance No. 5906
(adopted October 23, 2019), City of San Jose Ordinance No. 30330 (adopted September 17, 2019), and City of Santa Cruz Ordinance No. 2020-06 (adopted April 14, 2020).
ii See California Restaurant Ass. v. City of Berkeley, Order Granting in Part and Denying in Part Motion to Dismiss,
Document 75, Case No. 4:19-cv-07668-YGR (N.D. Cal. July 6, 2021); See See California Restaurant Ass. v. City of
Berkeley, Case No. 21-16278 (9th Cir.), filed Aug. 5, 2021.
iii See Public Utilities Code § 216.
iv See 40 CFR Part 82; See 17 C.C.R. §§ 95380–95398; See 17 C.C.R. §§ 95371–95377; See California Air Resources
Board, Prohibitions on Use of Certain Hydrofluorocarbons in Stationary Refrigeration, Chillers, Aerosols-
Propellants, and Foam End-Uses Regulation, Last Visited January 5, 2022:
https://ww2.arb.ca.gov/rulemaking/2020/hfc2020.
v AB 2313 (Williams, Chapter 571, Statutes of 2016); SB 1440 (Hueso, Chapter 739, Statutes of 2018); see also AB
1900 (Gatto, Chapter 602, Statutes of 2012); See also SB 1440 (Hueso, Chapter 739, Statutes of 2018); AB 3163
(Salas, Chapter 358, Statutes of 2020); See AB 1496 (Thurmond, Chapter 604, Statutes of 2015), SB 1371 (Leno,
Chapter 525, Statutes of 2014) and SB 887 (Pavley, Chapter 673, Statutes of 2016), SB 605 (Lara, Chapter 523,
Statutes of 2014), SB 1383 (Lara, Chapter 395, Statutes of 2016), and AB 1496 (Thurmond, Chapter 604, Statutes of
2015); See SB 1371 (Leno, Chapter 525, Statutes of 2014).
vi See CPUC Rulemaking R.18-04-019, Order Institution Rulemaking to Consider Strategies and Guidance for Climate
Change Adaptation; See CPUC Rulemaking R.18-12-005, Order Instituting Rulemaking to Examine Electric Utility
De-Energization of Power Lines in Dangerous Conditions; See CPUC Rulemaking R. 18-10-007, Order Instituting
Rulemaking too Implement Electric Utility Wildfire Mitigation Plans Pursuant to SB 901 (2018); See CPUC Rulemaking R. 20-01-007, Order Instituting Rulemaking to Establish Policies, Processes, and Rules to Ensure Safe
and Reliable Gas Systems in California and Perform Long-Term Gas System Planning.
Oct. 11, 2022 Item #12 Page 409 of 560
371
Review of Decarbonize Buildings Pathway Policies
For this analysis, we compare GHG impacts across CAPs. Based on the review of CAPs, measures in the
Decarbonize Buildings Pathway account for between 0% and 42% of local reductions, with an average
across all CAPs of about 9% (Figure 8.32).
Figure 8.32 Contribution of Measures to Decarbonize Buildings in Adopted and Pending CAPs
A further breakdown of CAP building decarbonization measures from the review of CAPs shows the
number of jurisdictions with one or more CAP measures or supporting action related to each of the
three-building decarbonization policy categories and the associated average GHG contribution to the
local CAP GHG reduction (Figure 8.33). The entire pathway contributes about 9% to local reductions,
with most coming from energy efficiency measures. All CAPs have measures related to energy efficiency,
and they account for between less than 1% to almost 29% of the GHG reductions from local measures in
CAPs, with an average of about 8%. Only seven CAPs have building electrification measures, with an
average contribution of about 4% to local GHG reductions. No CAPs in the San Diego region have
measures related to increasing use of low-carbon fuels in buildings; therefore, we do not provide a
detailed assessment of this policy category.
Figure 8.33 Number of Jurisdictions with Related CAP Measures and Associated GHG Impacts
Additional results about the number of CAPs that include related measures will be provided in the
following sections that focus on the policy categories and subcategories of building decarbonization. As
Oct. 11, 2022 Item #12 Page 410 of 560
372
described above in Section 8.3.3, we did not estimate the contribution of the policy subcategories to
local GHG reductions across CAPs.
Scenario Analysis of GHG Impacts for the Decarbonize Buildings Pathway
In contrast to the review of CAPs, which considers measures in all emissions categories and does not
consider the combined impact of measures, the scenario analysis only evaluates emissions from on-road
transportation, electricity, and natural gas, and estimates the GHG impact of all related CAP measures.
To assess the combined impact of all adopted CAPs in the region, we summed the activity level in CAP
measures and recalculated a regional GHG impact value. One important factor to consider when
evaluating the GHG emissions impacts of electric energy efficiency is California's increasing supply of
renewable electricity. As the amount of carbon-free electricity increases and as more appliances are
converted to electric, the potential for GHG reductions from efficiency decreases. Nonetheless, as noted
above, efficiency is important during the transition to electrified buildings both from GHG impact and
cost perspectives.i
Figure 8.34 shows the GHG reduction from the building decarbonization measures included in the
Adopted CAP Commitment Scenario. The overall GHG impact is relatively small, about 0.05 MMT CO2e.
Over 90% of the reductions would result from energy efficiency measures and 6% from building
electrification. Note that the City of San Diego draft 2022 CAP update is not included in these results.
Section 8.4.5 provides an estimate of the GHG impacts of the draft City of San Diego CAP to the scenario
analysis of adopted CAPs.
Figure 8.34 Emissions Reduced from Decarbonize Buildings Pathway Policies in Adopted CAPs in the San Diego
Region
Table 8.24 provides a breakdown of the GHG reductions from energy efficiency based on the Adopted
CAP Commitment Scenario. Energy efficiency improvements in existing nonresidential buildings
represent 51% of the reductions in this pathway. Residential energy retrofits and water heater retrofits
represent 16% and 25%, respectively. The relatively small impact of building electrification in Table 8.24
represents what would be expected from residential new construction measures in CAPs.
i Berg, W., E. Cooper, and M. Molina. 2021. Meeting State Climate Goals: Energy Efficiency Will Be Critical.
Washington, DC: American Council for an Energy-Efficient Economy. https://www.aceee.org/research-
report/u2104.
Oct. 11, 2022 Item #12 Page 411 of 560
373
Table 8.24 Emissions Reduced from Decarbonize Buildings Pathway Adopted CAP Commitment Scenario
Decarbonization
Pathway
Policy
Category Policy Subcategory
GHG Emissions Reduced in
2035
(MT
CO2e)
Distribution
within Pathway
Decarbonize
Buildings
Electrification Residential New-Construction Electrification 3,207 8%
Energy
Efficiency
Residential Energy Retrofits 6,421 16%
Non-residential Energy Retrofits 20,294 51%
Water Heater Retrofits 9,758 25%
Total: 37,954 100%
Best Adopted CAP Commitments Scenario for Building Decarbonization
The Best Adopted CAP Commitment Scenario applies the CAP measure with the highest impact to
activity level and emissions to all jurisdictions in the region regardless of whether they have an adopted
or pending CAP. The GHG reduction from measures related to building decarbonization in this scenario
(0.7 MMT CO2e) are significantly higher than what would result from the adopted CAP commitments
(0.04 MMT CO2e), though still relatively low when compared to other decarbonization pathways. For
example, increasing grid supply of carbon-free electricity would reduce GHG emissions by 1.3 MMT CO2e
in the Adopted CAP Scenario and 1.6 MMT CO2e in the Best Adopted CAP Commitment Scenario. The
proportion of GHG reductions from energy efficiency would decline to 77%, and those from
electrification would increase to 23% (Figure 8.35).
Figure 8.35 Emissions Reduced from Best Adopted CAP Building Decarbonization Policies Applied Regionwide
Table 8.25 provides a breakdown of the GHG reductions from energy efficiency by policy subcategory.
Efficiency improvements in existing residential buildings represent 37% of the reductions in this
pathway. Residential energy retrofits and water heater retrofits reduce emissions by 23% and 16%,
respectively.
Oct. 11, 2022 Item #12 Page 412 of 560
374
Table 8.25 Emissions Reduced from Best Building Decarbonization Policies in Adopted CAPS Applied Regionwide
Policy Group Policy
Category Policy Subcategory
GHG Emissions Reduced in 2035
(MT CO2e) Distribution
within Pathway
Policy Group 2:
Decarbonize
Buildings
Electrification Residential New-Construction
Electrification 166,298 23%
Energy
Efficiency
Residential Energy Retrofits 269,074 37%
Non-residential Energy Retrofits 164,672 23%
Residential Water Heater Retrofits 116,645 16%
Non-residential Solar Water Heater
Retrofits 937 0.1%
Total: 717,626 100%
Table 8.26 compares the impact to regional electricity and natural gas use that commitment related to
building decarbonization would have and those expected from the Best Adopted CAP Commitment
Scenario. Overall, measures in adopted and pending CAPs included in this analysis would reduce regional
electricity use by less than one percent and natural gas use by about one percent. The Best Adopted CAP
Commitment Scenario would reduce electric use by 12% and natural gas use by 19%. By comparison,
estimates in Chapter 4 under the central scenario, natural gas use associated with buildings should
reduce by about 50% between 2019 and 2035. Based on this scenario, there would be a significant gap
in the level of building decarbonization needed to be on track to achieve the levels contemplated in
Chapter 4.
Table 8.26 Impact of Best Adopted CAP Commitment in Building Decarbonization on Regional Energy Use.
Activity Policy
Category Policy Subcategory
Reduction in Activity Level1
Adopted CAP
Commitment
Scenario
Best Adopted
CAP Commitment
Scenario
Electricity
Use
Energy
Efficiency
Residential Energy Retrofits 0.01% 5%
Non-residential Energy Retrofits 0.01% 5%
Residential Water Heater Retrofits 0.0003% 2%
Non-residential Solar Water Heater Retrofits 0.02%
Natural
Gas Use
Electrification Residential New-Construction Electrification 0.1% 5%
Energy
Efficiency
Residential Energy Retrofits 0.5% 14%
Non-residential Energy Retrofits 0.3% 7%
Residential Water Heater Retrofits 0.5% 4%
Non-residential Solar Water Heater Retrofits 3%
1 Reduction in activity level of electricity (KWh) and natural gas (Therms) demand, for year 2035.
8.6.4 Increase Energy Efficiency
Energy efficiency has been the foundation of California’s energy policy since the 1970s. In the context of
building decarbonization, energy efficiency can reduce total energy needed by improving building
envelope performance (e.g., insulation, windows, weatherization, etc.) and appliance efficiency,
Oct. 11, 2022 Item #12 Page 413 of 560
375
particularly natural gas appliances in the short run and electric appliances in the medium and long term;
GHG emissions from fossil-fueled and electric appliances in the short run while electrification transition
occurs (in the short-run the emissions rate of electricity is higher, so energy efficiency can have a short
run impact on emissions); and, energy costs, which is important for communities of concern for whom
energy costs can represent a higher portion of income.
CAP Measures Related to Energy Efficiency in the San Diego Region
In the context of CAPs, energy efficiency related measures can be broken into two categories: (1)
measures to encourage or require efficiency improvements, and (2) measures to encourage or require
building owners to audit, benchmark, and disclose information about building energy use. Each of these
can be broken down further by vintage (e.g., new) and building class (e.g., residential). We use the
frequency of CAP measures and the overall GHG contribution to local reductions in CAPs to assess
potential opportunities for additional local actions.
Much of the building decarbonization analysis in Chapter 4 focuses on electrification, though as noted
above, energy efficiency can continue to play a role in cost containment, an important equity
consideration. Also, building-related measures in CAPs focus mainly on efficiency and many of the same
considerations for building energy efficiency policies are relevant to building electrification.
Policies to Encourage or Require Energy Efficiency Improvements
Based on our review of CAPs in the San Diego region, energy efficiency accounts for between about 1%
and 29% of total local reductions in adopted and pending CAPs in 2035, with an average of about 8%.
CAPs include a range of quantified measures and supporting efforts to increase energy efficiency in
buildings. Table 8.27 summarizes the number of CAPs in the region that include at least one quantified
measure related to implementing energy efficiency improvements. It shows which implementation
mechanisms were used and distinguishes building (e.g., residential and nonresidential) and construction
(e.g., new and existing) types. This view helps to understand how often related measures are included in
CAPs across various categories, which can help assess whether there is an opportunity for further local
action. Table 8.27 provides examples of the types of measures included in the implementation
mechanisms.
Table 8.27 Number of Adopted and Pending CAPs with Measures to Implement Energy Efficiency
Implementation Mechanism
Viewing the results in Table 8.27 vertically can help understand the distribution of CAPs across
implementation mechanisms. In this case, education, outreach, and coordination appear to be the
Oct. 11, 2022 Item #12 Page 414 of 560
376
approach included in most CAPs, followed by requirements and incentives. In general, for nearly all
policy categories associated with building decarbonization, the highest number of CAPs with related
measures fall within these three implementation mechanisms.
Education and outreach measures include those to raise awareness about energy efficiency and to
encourage a range of strategies, including water heater efficiency and cool roofs. Examples of measures
related to incentives include expediting permits or waiving permit fees for increased energy efficiency,
and providing financial incentives, and increasing financing opportunities. And energy efficiency
measures also can require energy efficiency improvements at specified intervention points, like time of
sale or major remodel.
Building and Construction Type
Viewing the table horizontally helps understand how the distribution occurs by building type and
construction type. In this case, measures to increase energy efficiency in existing buildings occurred in
the highest number of CAPs and were split about evenly between residential and non-residential. Most
measures use education, outreach, and coordination to increase awareness of energy efficiency.
Requirements represent the second-highest number of measures, followed by incentives.
Energy efficiency measures related to new buildings represent the second-highest number of measures
distributed across implementation mechanisms similar to existing buildings. More than half of CAPs
included measures related to municipal capital improvements and infrastructure related to energy
efficiency projects in local jurisdiction buildings.
Example CAP Measures and Adopted Policies
Table 8.28 provides examples of the types of CAP measures related to implementing energy efficiency
improvements for each of the implementation mechanisms.
Given the relatively small GHG reductions from existing building measures in adopted and pending CAPs
and the potential for these measures to reduce GHG more than new construction, we focus here on
policies to improve efficiency in existing buildings. Additional measures related to new construction are
discussed in Section 8.6.6 below. The following summarizes several relevant policies in the region.
Oct. 11, 2022 Item #12 Page 415 of 560
377
Table 8.28 Examples of CAP Measures to Implement Energy Efficiency Improvements
Implementation Mechanism General Policy
Capital Improvement & Infrastructure • Retrofit streetlights, traffic signals, and other outdoor public lighting
• Implement energy efficiency recommendations through Energy Roadmap
Program
• Install solar water heating systems at municipal facilities
• Install cool roofs on municipal buildings
• Retrofit HVAC and water pump equipment
Education, Outreach, &
Coordination
• Develop partnerships to promote energy efficiency upgrades
• Develop partnerships to promote water heater upgrades
• Promote energy efficiency upgrades
• Promote water heater upgrades
• Promote shade trees
• Promote cool roofs
Evaluation • Evaluate cost effectiveness of energy efficiency activities
• Revisit municipal energy efficiency goals on a regular cycle
• Evaluate feasibility of developing programs or policies
• Track project data through permit applications
Incentives • Expedited permitting for increased energy efficiency
• Incentivize energy efficiency upgrades
• Increase financing opportunities
• Incentivize shade trees
• Waive permit fees for increased energy efficiency
Plan or Program • Develop an energy efficient lighting program for municipal facilities
• Develop a municipal energy strategy
• Include energy efficiency in municipal purchasing policies
Requirement(s) • Require general energy efficiency upgrades at a specified intervention point
• Require water heater upgrades at a specified intervention point
• Require cool roofs at a specified intervention point
• Increase energy efficiency standards for qualifying projects
• Require shade trees
City of Carlsbad
The City of Carlsbad CAP includes three measures to improve energy efficiency in buildings. Measure D
(Encourage Single-Family Residential Energy Efficiency Retrofits) and Measure E (Encourage Multi-Family
Residential Efficiency Retrofits) seek to achieve a 50% energy reduction in 30% of single-family and
multi-family homes. Measure F (Encourage Commercial and City Facility Efficiency Retrofits) seeks to
achieve a 40% energy reduction in 30% of nonresidential buildings. To achieve these levels of energy
reductions, these measures include several implementation mechanisms, including education and
outreach, promoting existing incentive programs and requirements.
The City of Carlsbad has adopted two ordinances to implement these measures. Ordinance CS-347, in
March 2019, requires single-family and multi-family buildings that undergo additions or alterations with
a building permit valuation greater than $60,000 to complete specified energy efficiency improvements.i
Compliance requirements are determined by the type (e.g., single-family) and building age and include
i California Energy Commission. Docket Number 16-BSTD-07, April 22, 2019. Local Ordinance Application – 2016
Standards. TN# 227821. Carlsbad Ordinance CS347 Full Text. Available at
https://efiling.energy.ca.gov/GetDocument.aspx?tn=227821&DocumentContentId=59197.
Oct. 11, 2022 Item #12 Page 416 of 560
378
actions related to duct sealing, attic insulation, cool roofs, and lighting. Note the ordinance also includes
provisions related to water heating in nonresidential buildings, which are included in the section below
on building electrification.
City of Chula Vista
Objective 3.3 (Energy Efficiency Upgrades) of the City of Chula Vista CAP, specifically Strategy 3, seeks to
require energy-savings retrofits in existing buildings at a specific point in time. To implement this
measure, in March 2021, the City of Chula Vista adopted Ordinance No. 3498 to require benchmarking
and energy efficiency improvements in certain multi-family and non-residential buildings.i More
information on the Benchmarking and Disclosure portion of the ordinance is in the section below on this
topic.
Starting 2023 for buildings with a gross floor area (GFA) of at least 50,000 SF and 2026 for buildings with
GFA 20,000 – 49,999 SF, the ordinance also requires certain multi-family and nonresidential buildings to
meet building performance standards every five years. Buildings that do not meet the standard must
achieve performance targets based on Energy Star scores or the site’s weather normalized energy use
intensity (EUI-WN) or to complete both minimum building energy improvements every 10 years based
on Energy Star scores or EUI-WN and a building audit and retro-commissioning. Multi-family buildings
constructed before 2006 for rental tenant spaces where the tenant bears utility costs also have to
complete the minimum number of prescriptive measures.
City of Encinitas
The City of Encinitas CAP includes two measures related to building energy efficiency: BE-1 (Adopt a
Residential Energy Efficiency Ordinance) and BE-3 (Adopt Higher Energy Efficiency Standards for
Commercial Buildings). To implement these measures, the City of Encinitas adopted a comprehensive
Green Building Ordinance 2021-13.ii Several provisions require energy efficiency improvements.
Residential buildings undergoing additions or alterations with a permit valuation of $50,000 or higher
are required to complete specified energy efficiency improvements. Similar to the City of Carlsbad’s
ordinance, compliance requirements depend on building type (e.g., single-family) and age of the
building and include actions related to duct sealing, attic insulation, cool roofs, lighting, and water
heating.
Existing non-residential, certain multi-family residential, and hotel/motel building additions of 1,000
square feet or alterations with a permit valuation of at least $200,000 are required to complete energy
improvements related to outdoor lighting, water heating, and daylighting.
Audit, Benchmark, and Disclosure Policies
Policies to encourage or require energy audits, benchmarking, and disclosure policies are intended to
provide data about energy use to raise awareness and to help develop and implement energy efficiency
improvements. Auditing policies encourage building owners to complete comprehensive energy
i City of Chula Vista, Building Energy saving Ordinance webpage. Available at
https://www.chulavistaca.gov/departments/clean/benchmarking.
ii City of Encinitas. Green Building Ordinances webpage. Available at
https://encinitasca.gov/Government/Departments/City-Manager/Environmental-Services/Climate-Action-
Plan/Green-Building-Ordinances.
Oct. 11, 2022 Item #12 Page 417 of 560
379
assessments that identify opportunities to improve energy and water efficiency.i Benchmarking is a
process of reporting energy use, typically through the ENERGY STAR Portfolio Manager site.ii Once
collected, building energy usage data can be disclosed, either publicly through a governmental website
or directly to prospective tenants or buyers. In general, the goal of these policies is to increase the
amount and availability of information and data about building energy consumption to form the basis
for further action.
Table 8.29 presents the number of CAPs that have at least one measure related to audit, benchmark,
and disclosure policies. Relatively few CAPs include measures related to these policies, and nearly all of
them are associated with existing buildings. While new buildings can disclose estimated energy use
through energy ratings similar to fuel efficiency ratings on new cars, it is more common in existing
buildings, particularly nonresidential buildings.
Based on the information presented in Table 8.29, there appears to be an opportunity to increase the
number of CAP measures related to audit, benchmark, and disclosure policies in existing buildings. Also,
while municipal buildings represent a small portion of energy use and emissions in a local jurisdiction,
action to improve efficiency can provide an opportunity to model actions that could be needed in the
private sector. There is also a potential opportunity for local jurisdictions to assess energy use at
municipal facilities. As with policies to implement energy efficiency improvements, many aspects of
policies to encourage or related to audit, benchmark, and disclosure can be transferred to building
electrification strategies.
Table 8.29 Number of Adopted and Pending CAPs with Measures Related to Energy Audit, Benchmark, and
Disclosure
GHG impact of CAP Measures
Audit, benchmark, and disclosure policies can be considered a foundational step in the efficiency
process but alone may not result in notable energy reductions. As such, associated GHG reductions are
likely relatively low. Evaluation of previous policies shows general energy impacts of these policies. For
example, a comprehensive review of nonresidential benchmarking and transparency policies in 2017
found “3 to 8 percent reductions in gross energy consumption or energy use intensity over a two- to
i Pacific Northwest National Laboratory. September 2011. A guide to Energy Audits. Available at
https://www.pnnl.gov/main/publications/external/technical_reports/PNNL-20956.pdf. ii U.S. Environmental Protection Agency Energy Star Portfolio Manager webpage. Available at
https://www.energystar.gov/buildings/benchmark.
Oct. 11, 2022 Item #12 Page 418 of 560
380
four-year period of [benchmarking and transparency] policy implementation.”i For auditing policies that
do not require efficiency improvements, the number of building owners that complete actions and the
energy impact of those actions are important considerations in determining the impact of these policies.
The GHG impacts of these policies were not considered in the scenario analysis presented in Section 8.4.
Only five CAPs quantified the GHG impacts of these policies. Many CAP measures related to auditing,
benchmarking, and disclosure are supporting actions.
Example CAP Measures and Policies
Table 8.30 provides examples of the types of policies related to the assessment and disclosure of energy
use information for each of the implementation mechanisms. Measures related to municipal buildings
generally commit to conducting audits of municipal facilities. Education and outreach efforts seek to
increase awareness about the process of audits, benchmarking, and information disclosure. In this
context, incentives reduce or eliminate the cost of the energy audit or benchmarking process. Required
action includes audits or benchmarking for certain buildings (e.g., undergoing additions or alterations) or
intervention points (e.g., time of sale).
There are relatively few examples of measures from adopted or pending CAPs related to encouraging or
requiring energy audits, benchmarking, and disclosure. California adopted a benchmarking requirement
with AB 802 (2015), which requires certain buildings to report energy use data. Local ordinances are
implemented in this context and can add to existing requirements.
Table 8.30 Examples of CAP Measures Related to Audit, Benchmarking, and Disclosure
Implementation Mechanism General Policy
Capital Improvement &
Infrastructure • Conduct energy audits of municipal buildings
Education, Outreach, &
Coordination • Educate public on energy performance disclosure
• Target outreach to specific communities
• Develop partnerships to enroll users in benchmarking programs
• Promote information disclosure tools and resources
• Encourage regional partners to provide free energy audits
Evaluation NA
Incentives • Offer free home evaluations
• Develop an incentive program for building benchmarking and disclosure
• Provide free retrofit evaluations
Plan or Program NA
Requirement(s) • Require energy audits for additions and/or alterations to existing
residential and/or nonresidential units
• Require public disclosure at a specific point in time (e.g., time of sale)
i N. Mims, et al., 2017. Evaluation of U.S. Building Energy Benchmarking and Transparency Programs: Attributes,
Impacts, and Best Practices. Energy Analysis and Environmental Impacts Division Lawrence Berkeley National
Laboratory.
Oct. 11, 2022 Item #12 Page 419 of 560
381
Chula Vista Energy Efficiency Ordinance
Objective 3.1 (Energy Education & Enforcement) of the City of Chula Vista CAP includes Strategy 1
(Expand education targeting key community segments and facilitate energy performance disclosure).
Several actions are contemplated to implement this measure, including:
• Action 3.1.1 A: Offer free evaluations through Free Resource & Energy Business Energy
Evaluations (FREBE) & Home Upgrade, Carbon Downgrade programs
• Action 3.1.1 F: Create local incentives or policies for building benchmarking and public disclosure
• Action 3.3.3 A: Require free energy evaluations for businesses as part of licensing process
• Action 3.3.3 B: Include free retrofit evaluations in Home Upgrade, Carbon Downgrade program
In March 2021, the City of Chula Vista adopted Ordinance No. 3498 to require benchmarking and energy
efficiency improvements in certain multi-family and non-residential buildings.i Starting in 2022, owners
of certain non-residential buildings with a GFA of at least 20,000 square feet are required to conduct
regular benchmarking and to submit data annually via Energy Start Portfolio Manager. The City of Chula
will disclose results to the public, and building owners will directly disclose to tenants and buyers.
City of Santee CAP
The City of Santee CAP has several quantified measures related to energy audits. Measure 1.1 (Energy
Audits in the Existing Residential Sector) seeks to require energy audits of existing residential units
requesting permits for major and minor Modifications. Measure 3.1 (Energy Audits in the Existing
Commercial Sector) would require energy audits in existing commercial units requesting permits for
minor or major modifications.
8.6.5 Electrify Building End Uses
Building decarbonization requires replacing fossil fuel end uses with electric or low-carbon fuels.
Chapter 4 identified the following appliances as candidates for electrification (Table 8.31).
Table 8.31 Common Electric Appliances
End Use Electric Appliance Option
Space Heating Air Source Heat Pump; Ground Source Heat Pump
Water Heating Heat Pump Water Heater; On-Demand Electric Water Heater
Cooking Induction Cooktops and Stoves
Laundry Electric Dryers; Heat Pump Dryers
These technologies replace natural gas usage with electricity. Because every fossil-fueled appliance is an
emissions source, electrifying building end uses reduces GHG but also other criteria pollutants, both
indoors and in the vicinity of the building. As the GHG intensity of electricity declines, the overall
amount of GHG emissions associated with these appliances also declines. This reduces direct emissions
from building end uses. Electrifying certain appliances is likely to have a relatively large impact on GHG
emissions, depending on the amount of natural gas required to operate the appliance. For example,
Figure 8.36 illustrates the total residential natural gas end use by appliance within the SDG&E territory.
Water heating appliances account for the largest share of residential natural gas consumption (63%),
followed by space heating (28%).ii
i City of Chula Vista, Building Energy saving Ordinance webpage. Available at
https://www.chulavistaca.gov/departments/clean/benchmarking.
ii California 2019 Residential Appliance Saturation Survey (RASS) preliminary data provided to EPIC.
Oct. 11, 2022 Item #12 Page 420 of 560
382
Figure 8.36 Total Residential Natural Gas End Use by Appliance in the SDG&E Territory
The time of day that buildings use energy also has an impact on emissions. In general, in California, the
rate of emissions is lowest in the middle of the day when solar energy is abundant and highest after the
sun sets in the evening and natural gas power plants increase production to meet the peak demand,
which occurs between around 7 pm (Figure 8.37). In the short run and until California reaches its goal of
100% carbon-free electricity supply by 2045 and energy storage is widespread, using electric appliances
will be associated with some level of carbon dioxide emissions, even if buildings have a distributed solar
system installed. This is because natural gas power generators will supply a portion of the electricity
supply, particularly in the evening and overnight when renewable electricity supplies are lower.
Figure 8.37 Carbon-Dioxide Emissions Rate from CAISO (10-27-21) i
i i California Independent System Operator (ISO) Today’s Outlook webpage. Available at
http://www.caiso.com/TodaysOutlook/Pages/emissions.html.
Oct. 11, 2022 Item #12 Page 421 of 560
383
Efforts to electrify buildings have grown rapidly in the past several years, both at the state and local
levels. At the state level, building requirements in the Energy Code (Title 24 Part 6) are shifting towards
electrification, as seen in the upcoming 2022 standards approved by the CEC in August 2021.i Beginning
January 1, 2023, all new residential construction must be electric-ready and prescriptive requirements
for residential water heating set heat pump water heaters as the standard for most climate zones. It is
anticipated that state requirements will shift even further towards all-electric requirements for both
residential and nonresidential construction in future triennial code updates.
However, there are still opportunities for jurisdictions to go beyond state requirements. Increasingly,
cities are adopting ordinances that encourage or require some degree of electrification. But not all
electrification ordinances are alike, and requirements across the state fall along a broad spectrum
(Figure 8.38). Despite this spectrum, many local governments are willing to pursue all-electric policies.
As of June 2022, 55 jurisdictions have adopted all-electric requirements for residential and/or
nonresidential construction since 2019, including the Cities of Encinitas and Solana Beach (Note: the City
of Los Angeles directed staff to develop similar measures in June 2022). These requirements have come
in two forms: a local ordinance that adopts an all-electric definition for new and/or existing buildings;
and a natural gas infrastructure moratorium.
Figure 8.38 Spectrum of Electrification Options in Current Local Codes
Electrification within the existing building stock is more challenging to address than in new construction.
Several barriers to adoption persist within the current market and will likely need to be directly
addressed to encourage electrification in existing buildings and new construction where requirements
are not present. These include, but are not limited to:ii
• Limited experience or comfort working with electric appliances among contractors;
• Limited awareness and/or negative perceptions of electric technologies among consumers;
• Limited access to low-cost financing for low-income consumers;
• Prioritization of least-cost commonly used technologies in new construction projects;
• Unwillingness of consumers to pay higher upfront costs;
• Perceived “hassle factor” of fuel switching appliances; and
• Inability to rapidly fuel switch when an “emergency” replacement is required (e.g., water
heater failure).
i California Energy Commission. 2022 Building Energy Efficiency Standards. Available at
https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-standards/2022-building-
energy-efficiency.
ii E3 (2019). Residential Building Electrification in California. Appendix D: Market Adoption Barriers and Potential
Solutions (PDF).
Oct. 11, 2022 Item #12 Page 422 of 560
384
CAP Measures Related to Building Electrification in the San Diego Region
Adopted commitments for building electrification in CAPs in the San Diego region are few and only focus
on electrification of specific appliances.i For CAPs that contain at least one electrification measure, these
measures account for one percent of local reductions on average. Figure 8.42 summarizes the number
of jurisdictions with one or more CAP measures or supporting action that addresses building
electrification across all building (e.g., residential and nonresidential) and construction (e.g., new and
existing) types, and implementation mechanisms.
Relatively few CAP measures and supporting actions relate to building electrification. Collectively, only
six of the 19 jurisdictions in the region have committed to some sort of electrification requirement for
select appliances. Even fewer jurisdictions have committed to providing incentives and education on
building electrification (one and three, respectively), and only one jurisdiction committed to all-electric
activity within their CAP. Based on the relative lack of CAP measures to electrify buildings and the GHG
implications as presented in the scenario analysis presented in Section 8.4 and above in this section, the
commitment to electrification in adopted CAPs is insufficient given the level of building equipment
electrification contemplated in Chapter 4.
Table 8.32 Number of Adopted and Pending CAPs with Measures Related to Building Electrification
Implementation Mechanisms
For those jurisdictions that do include building electrification, requirements are the most frequent
approach used, followed by education and then incentives. No adopted CAPs commit to capital
improvement and infrastructure (e.g., electrification of municipal facilities), developing a building
electrification plan or program, or ongoing evaluation of current or future building electrification
opportunities.
Building and Construction Type
Generally, CAPs have focused on electrifying select end-uses in new residential developments. In this
case, measures have specified the electrification of one or more appliances, such as the water heater or
cookstove/range, through the development of a local ordinance. Few CAPs, if any, look to electrify
nonresidential projects and the existing building stock. The one jurisdiction that requires electrification
of nonresidential buildings (new and existing) specifies electrification of water heating equipment. In
i While no CAP in the region commits to all-electric requirements, some jurisdictions have moved towards all-
electric requirements during implementation of their CAP. Examples are provided later in this section.
Oct. 11, 2022 Item #12 Page 423 of 560
385
addition, the electrification requirement for the existing nonresidential building stock only applies to
qualifying addition and alteration projects.
Municipal facilities are covered under nonresidential requirements, but no jurisdiction has specifically
committed to the electrification of municipal facilities.
Examples of Policies in Region
Table 8.33 provides general policies identified in adopted CAP measures and actions related to building
electrification by implementation mechanism. While building electrification measures are only included
in recent CAPs, several local jurisdictions have adopted related policies.
Table 8.33 Examples of CAP Measures to Electrify Select End Uses
Implementation Mechanism General Policy
Capital Improvement &
Infrastructure
NA
Education, Outreach, &
Coordination • Promote installation of heat pump water heaters in renovations
• Provide educational materials on alternative water heaters
• Educate homeowners and businesses on building electrification and
appliance options
Evaluation NA
Incentives • Provide electric appliance incentives to new and existing residential units
• Expedite permitting for replacement of natural gas space and/or water
heaters
Plan or Program NA
Requirement(s) • Require electrification of water heater in new residential and/or
nonresidential construction (including additions and alterations)
• Develop materials to support requirements (e.g., cost effectiveness studies)
• Explore requiring non-natural gas appliances in new residential development
• Require new multi-family residential development to install electric cooking
appliances
City of Encinitas
The 2020 interim revision to the City of Encinitas CAP included two CAP measures that focused on
building electrification. Measures BE-2 (Require Decarbonization of New Residential Buildings) and BE-4
(Require Decarbonization of New Commercial Buildings) estimated the GHG reduction potential of
electrifying water heating in new residential and nonresidential developments through the adoption of a
local ordinance or reach code. In October 2021, the City of Encinitas adopted its Green Building
Ordinance, which included, among other things, electrification requirements for new construction.i This
ordinance goes beyond what was committed to in their CAP and requires all new residential and
nonresidential construction to be all-electric, with some exceptions for commercial kitchens, essential
facilities, and projects that would require significant utility upgrades to accommodate the increased
electric load. For buildings where an exception applies, the building must be electric-ready.
Encinitas developed a Green Building Incentive Program that provides financial incentives, priority plan
i City of Encinitas. Green Building Ordinances webpage. Available at
https://encinitasca.gov/Government/Departments/City-Manager/Environmental-Services/Climate-Action-
Plan/Green-Building-Ordinances.
Oct. 11, 2022 Item #12 Page 424 of 560
386
checks, and City Council recognition to qualifying projects to advance efforts within the city and
encourage electrification in the existing building stock.i
City of Carlsbad
The City of Carlsbad adopted a CAP in 2015, which included Measure J, specifying the adoption of a local
ordinance that requires a solar water heater or heat pump water heater in new residential and
nonresidential construction with exceptions made for central water heating systems that serve multiple
dwelling units. In March 2019, the city adopted this ordinance.ii While not explicitly an electrification
requirement, this ordinance is representative of efforts to electrify certain end-uses, especially those
responsible for most residential natural gas consumption.
City of Solana Beach
The City of Solana Beach did not commit to electrification in their 2017 CAP but recognized the potential
to reach its climate goals by developing an electrification ordinance. In December 2021, the City
adopted Ordinance 518, which requires electrification of most end-uses in new residential and
nonresidential projects.iii End-uses required to be electric include space heating, water heating
(including pools and spas), and clothes drying. The ordinance also has an electric-ready requirement for
buildings plumbed for natural gas or propane cooking appliances.
Worth noting on this ordinance is how it defines new construction. The ordinance applies to certain
existing buildings when they are substantially changed as defined within the ordinance as:
• Any non-residential or mixed-use remodel project that has a permit valuation of $750,000 or
more; or alters 50% or more of major structural components including exterior walls, interior
walls, floor area, roof structure, or foundation; or has an increase of 50% or more of floor area;
and
• Any residential remodel project that alters 50% or more of structural components, including
exterior walls, interior walls, floor area, roof structure, or foundation; or has an addition of 700
square feet or more floor area.
This reflects the discretion local jurisdictions act with when interpreting Title 24 and adopting their own
building standard amendments to Title 24.
8.6.6 Opportunities for Additional Local Policy Action in the Decarbonize Buildings Pathway
Opportunities are a function of authority to act, frequency of measures in CAPs, and the GHG impact. As
noted above, there is a range of policy mechanisms to implement CAP measures. For purposes of
identifying policy options to decarbonize building in the San Diego region, we will focus on three key
mechanisms: education, outreach, and collaboration, incentives and financing, and requirements.
Recognizing that all three policy mechanisms are needed but that GHG impacts increase as we move
from education to requirements, we will focus on incentives and requirements. In addition to these
three, we will consider the equity implications of these policies
i City of Encinitas. Green Building webpage. Available at https://encinitasca.gov/Residents/Environmental-
Programs/Green-Building.
ii City of Carlsbad. Ordinance No. CS-348. Available at
https://localenergycodes.com/download/461/local_government_adoption_ordinance/fieldList/Carlsbad 2019 -
Ordinance No CS-348.PDF.
iii City of Solana Beach. Ordinance 518. See City Council Meeting November 10, 2021. Available at
https://solanabeach.12milesout.com/video/meeting/c5805988-cc39-4106-a75a-30975821258b.
Oct. 11, 2022 Item #12 Page 425 of 560
387
In general, there is an opportunity for more jurisdictions to adopt energy efficiency and electrification
policies and for all jurisdictions to adopt best-in-class policies.
Integrate Equity Considerations into Building Decarbonization Policy Process
As noted in Section 8.3.5 above, the integration of social equity considerations in adopted and pending
CAPs is limited, inconsistent, and lacks specificity. In general, there is an opportunity to integrate these
considerations into CAPs and the resulting measures and policies. In the context of electricity and
natural gas policy, the CPUC often includes within the definition of low-income household “residential
customers eligible for California Alternate Rates for Energy (CARE) and the Family Electric Rates
Assistance (FERA) programs, resident-owners of single-family homes in disadvantaged communities (as
defined in D.18-06-0127), or residential customers who live in California Indian Country (as defined in
D.20-12-003)… .”i
The following provides a preliminary overview of several aspects of equity related to building
electrification, but additional work would be needed to develop the capacity and tools to integrate
equity into the San Diego region's building and other decarbonization policies.
High Proportion of Renters in Communities of Concern
Policies and programs to address energy use in buildings that lease or rent units often face the “split
incentive” dilemma. Building owners often do not pay utility bills and have no incentive to address
building energy, while renters pay the utility bills and have an incentive to improve energy use but do
not own the building or the main energy-consuming appliances and equipment. In communities with a
high proportion of renters, considering the split incentive is particularly important.
There is a range of actions to address the unique challenges that renters face, including the following:
findings from a report by ACEEE focusing on energy efficiency in rental housing.ii Granting renters the
right to make efficiency improvements
• Adopting a renter right of first refusal on property sale
• Creating a rental energy disclosure policy
• Advocating to expand state and utility rental efficiency programs
• Promoting existing state and utility efficiency programs to renters and landlords
• Adopting a rental energy performance standard and assisting affordable housing providers with
compliance
• Instituting limited-scope rental property retrofit requirements
• Designing rental efficiency loan and grant programs with affordability covenants
• Coupling public housing energy-efficient rehab projects with inclusive workforce development
• Including energy efficiency in competitive, affordable housing funding criteria
An example from the San Diego region that addresses the split incentives is the City of Chula Vista
Building Energy Savings Ordinance (Ordinance No. 3498), which requires certain multifamily building
owners to benchmark and disclose energy usage and improve efficiency in rental units. Similar issues
i California Public Utilities Commission. Proposed Decision Revising Net Energy Metering Tariff and Subtariffs in
Rulemaking 20-08-020, 12-13-21.
ii Samarripas, S., and A. Jarrah. 2021. A New Lease on Energy: Guidance for Improving Rental Housing Efficiency at
the Local Level. Washington, DC: American Council for an Energy-Efficient Economy. Available at
aceee.org/research-report/u2102.
Oct. 11, 2022 Item #12 Page 426 of 560
388
and policy opportunities would exist for electrification. However, additional analysis would be needed to
determine the applicability of these approaches in the San Diego region.
Relative Lack of Data and Analysis Related to Equity
In general, there is a lack of comprehensive data and analysis at the local jurisdiction and regional level
for equity aspects of building energy use. Some work has been done to collect data at the local level and
to develop visualization tools. For example, the City of San Diegoi and the City of Chula Vistaii each have
developed a Climate Equity Index, which includes metrics related to energy use and costs. The City of
Escondido’s CAP seeks to develop a Clean Energy Equity Plan and priority investment neighborhoods
(PIN) to help target the implementation of certain CAP measures.iii Examples of detailed building energy
mapping tools exist in other regions of California, including UCLA’s Energy Atlas, which allows users to
explore energy usage and greenhouse gas emissions at varying levels of geographic scale down to the
neighborhood level.iv Researchers from UCLA also have developed equity-related metrics to understand
issues of energy poverty.v Developing regional capacity to do this analysis could help to integrate equity-
focused considerations into the policy development process.
Cost Implications of Building Electrification
The cost to residents in Communities of Concern of electrifying residential units depends on many
factors, including equipment cost, the equipment being installed and replaced, type of construction (i.e.,
new vs. retrofit), age of the building, electric and natural gas rates, expected change in natural gas and
electric consumption, and climate zone. Certain equipment or combinations of equipment have capital
cost, bill, and lifecycle savings, including all-electric new homes with air conditioning, mini-split retrofits,
ducted heat pumps in new construction air conditioning. While others result in additional upfront and
operating costs, including electric induction cooktops and heat pump clothes dryers.vi
CPUC analysis has shown that for certain buildings in the San Diego region, particularly those in a hot
climate zone, switching from mixed-fuel to electric space and water heating can lower monthly energy
utility bills, considering electricity and natural gas use and rates. On the other hand, new all-electric
homes in this same climate zone would have slightly higher bills. This is, in part, due to including less
cost effective equipment like induction cooktops and heat pump clothes dryers.vii This is consistent with
findings in Chapter 4, which notes that “[p]olicies should support increasing adoption of efficient heat
pump-based space and water heating systems in both new and existing buildings, with particular focus
on assistance for low-income residents and rental buildings.” More analysis may be needed to
understand the specific cost implications of building electrification in communities of concern in the San
Diego region and the potential need for financial assistance.
i City of San Diego. Climate Equity Index Mapping Tool webpage. Available at https://www.sandiego.gov/sustainability/social-
equity-and-job-creation.
ii City of Chula Vista. Climate Equity Index Mapping Tool Available at
https://usandiego.maps.arcgis.com/apps/webappviewer/index.html?id=4e6aab73778944148336d512edc032ea.
iii City of Escondido Climate Action Plan, 2021. Available at https://www.escondido.org/climate-action-plan-documents.aspx.
iv UCLA Energy Atlas Mapping Tool. Available at https://energyatlas.ucla.edu/map/usage_income.
v Fournier, ED, et al. 2020. On energy sufficiency and the need for new policies to combat growing inequities in the residential
energy sector. Elem Sci Anth, 8: 24. DOI: https://doi.org/10.1525/elementa.419.
vi E3, “Residential Building Electrification in California” (2019). https://www.ethree.com/wp-
content/uploads/2019/04/E3_Residential_Building_Electrification_in_California_April_2019.pdf.
vii California Public Utilities Commission, 2021. Utility Costs and Affordability of the Grid of the Future: An Evaluation of Electric
Costs, Rates, and Equity Issues Pursuant to P.U. Code Section 913.1.
Oct. 11, 2022 Item #12 Page 427 of 560
389
Adopt All-Electric Building Codes and/or Reach Codes for New Buildings and
Additions/Alterations to Existing Buildings
Buildings have a long lifetime, and the number of buildings affected by energy codes accumulates over
time; improving energy efficiency and electrifying buildings in new construction, additions, and
alterations is a least regret policy. Based on the review of adopted and pending CAPs, there is an
opportunity to increase the number of reach code policies in the San Diego region. Only four CAPs
include at least one measure to improve new residential and nonresidential efficiency. Similarly, only 4
CAPs include requirements for new building – all focused on residential buildings.
Several cities in the San Diego region and many across California have adopted efficiency and
electrification policies. Based on this previous experience, there are many example policies and several
statewide cost effectiveness studies that can facilitate policy development.
However, there are limitations to policies that target new buildings. A relatively small number of
buildings are built each year compared to the existing housing stock. In the San Diego region, new
buildings account for about 1% of the total buildings stock each year. Between 2020 and 2050, the
region will add an estimated 250,000 housing units, a 21% increase. The City of San Diego has the largest
projected increase with 165,869, an increase of about 30% and about 65% of the expected new housing
units in the region. Cities of Chula Vista (about 9% of total), Escondido (5%), and San Marcos (4%) have
the next highest number of expected new housing units.
Table 8.34 Expected New Housing Units 2020–2050 by Jurisdiction
Jurisdiction Change (2020-2050)
Number of New Units Percent Change
San Diego 165,869 30.4%
Chula Vista 23,465 27.3%
Escondido 11,571 23.6%
San Marcos 9,155 28.7%
La Mesa 8,606 33.4%
Carlsbad 5,544 11.7%
National City 5,187 30.1%
Unincorporated 4,891 2.8%
Oceanside 4,767 7.2%
El Cajon 4,303 11.9%
Vista 3,464 10.7%
Imperial Beach 1,571 15.7%
Encinitas 1,352 5.1%
Poway 1,302 7.8%
Lemon Grove 1,279 13.9%
Santee 1,051 5.0%
Coronado 864 9.0%
Solana Beach 856 13.2%
Del Mar 163 6.2%
Regional Total 255,260 21.0%
Also, since California’s building energy codes are so aggressive, any effort to seek incremental efficiency
improvements will yield relatively few energy and GHG reductions. And because codes get stricter every
Oct. 11, 2022 Item #12 Page 428 of 560
390
three years, future options for reach codes may be increasingly limited. Also, as California’s electricity
becomes increasingly clean, GHG reductions associated with efficiency of electric appliances will decline.
So, while there is an opportunity to adopt more reach codes, the potential for GHG reductions is limited.
Key Considerations for All-Electric Construction and Reach Codes
• Revisit Reach Code Opportunities with Building Code Cycle – The State Energy Code updates
every three years, and the opportunities for local requirements are likely to decrease with each
code cycle as requirements are integrated into the building code language. This change can be
seen with solar PV requirements for new construction. In the early to mid-2010s, a significant
portion of reach codes required solar PV in new residential construction. Beginning in 2020,
however, this requirement was mandated through the 2019 State Energy Code,i making a local
requirement unnecessary. Since local jurisdictions have shifted to ordinances requiring PV on
new nonresidential construction, however, this too is included in adopted language for the 2022
Energy Code,ii which is set to take effect January 1, 2023. As state standards tighten,
jurisdictions can explore opportunities to achieve additional energy savings and GHG reductions
from the new and existing building stock.
• Adopt All-Electric Building Codes and/or Reach Codes for New Construction and Existing
Buildings Sooner – Jurisdictions can achieve greater reductions early on by adopting
requirements before they are included in the State Energy Code. This helps state officials
identify key trends statewide that may influence future requirements included in building code
updates and has a greater impact on the cumulative reduction in emissions within the region.
Note: the CEC does not consider All-electric construction to be a reach code, and, consequently
adoption of all-electric requirements does not need CEC review.
• Consider Cost Effectiveness and Energy Savings of Requirements – For a reach code to be
approved by the CEC, a jurisdiction must demonstrate that the requirements (1) consume no
more energy than state standards and (2) are cost-effective. The latter is generally the limiting
factor, especially for newer technologies that may have high costs for adoption. For instance,
many CAPs in the region have included measures to require solar water (SW) heating in new
residential and/or nonresidential construction. However, SW heating requirements are generally
not cost-effective without significant rebates and incentives. For this reason, many jurisdictions
have sought to modify the requirements they are pursuing (e.g., Encinitas updated their SW
heating measure to an electrification measure in their CAP update).
Opportunities for Reach Codes
In addition to the above considerations, a number of resources have been developed by the Statewide
Reach Codes Program, a subprogram of the California Statewide Energy Codes and Standards Program.iii
These resources are specifically designed to help jurisdictions leverage their authority to adopt
requirements that achieve greater building-related energy and GHG savings, highlighting many of the
opportunities for reach code requirements currently available for adoption for new and existing
i California Energy Commission. 2019 Building Energy Efficiency Standards. Available at
https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-standards/2019-building-
energy-efficiency.
ii California Energy Commission. 2022 Building Energy Efficiency Standards. Available at
https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-standards/2022-building-
energy-efficiency.
iii Statewide Reach Codes Program, California Energy Codes and Standards – A Statewide Utility Program. Available
at https://localenergycodes.com/.
Oct. 11, 2022 Item #12 Page 429 of 560
391
buildings. Included in these resources are cost-effectiveness studies that document (1) energy savings
and (2) cost-effectiveness for all climate zones in the state. Current statewide studies for new
construction that pertain to the current 2019 State Energy Code are included in Table 8.33.
Table 8.35 Statewide Cost-Effectiveness Studies for New Construction, 2019 Building Code
Building / Construction Type Building Fuel
Types Analyzed Building Energy Packages Analyzed
New Low-Rise Residential
Construction1
• Mixed Fuel
• All-Electric
• Energy efficiency
• Energy efficiency + increased solar PV
• Energy efficiency + increased solar PV + battery storage
New Mid-Rise Residential
Construction2
• Mixed Fuel
• All-Electric
• Energy efficiency
• Energy efficiency + increased solar PV
New High-Rise Residential
Construction3
• Mixed Fuel
• All-Electric
• Energy efficiency
• Energy efficiency + increased solar PV
New Detached Accessory
Dwelling Units4 • All-Electric • Energy efficiency
• Energy efficiency + increased solar PV
New Nonresidential
Construction5
• Mixed Fuel
• All-Electric
• Energy efficiency
• Energy efficiency + increased solar PV + battery storage
1 CA Energy Codes & Standards Program (2019). 2019 Cost-Effectiveness Study: Low-Rise Residential New Construction.
2 CA Energy Codes & Standards Program (2020). 2019 Mid-Rise New Construction Reach Code Cost-Effectiveness Study.
3 CA Energy Codes & Standards Program (2021). 2019 Cost-Effectiveness Study: 2020 Analysis of High-Rise Residential New
Construction.
4 CA Energy Codes & Standards Program (2021). 2020 Reach Code Cost-Effectiveness Analysis: Detached Accessory Dwelling Units.
5 CA Energy Codes & Standards Program (2019). 2019 Nonresidential New Construction Reach Code Cost Effectiveness Study.
As they relate to building electrification, these studies support the adoption of a range of electrification
requirements within the San Diego region, including electric-preferred and all-electric ordinances for
new residential and nonresidential construction (as illustrated in Figure 8.38 above). Specific
requirements applicable to each jurisdiction will depend on the building climate zone(s) within the
jurisdiction’s boundary. Included with these analyses, jurisdictions may also consider adopting electric
ready requirements (e.g., pre-wiring and panel upgrades); however, these requirements are expected to
be included in the 2022 State Energy Code.
In addition, the City of Carlsbad carried out its own study to support its reach code, which examines the
cost-effectiveness of electrifying water heating in new residential construction.i This study found the
requirement to be cost-effective, paving the way for a similar requirement to be adopted elsewhere as
well.
Currently, there are no studies to support electrification requirements (all-electric or of specific
appliances) for the existing building stock in the San Diego region.
Current opportunities for energy efficiency requirements are much broader than electrification and can
be adopted in coordination with electrification requirements. Again, specific requirements will vary
based on the climate zone(s) within each jurisdiction. In addition, requirements for additions and
alterations may vary based on the building vintage. For instance, potential requirements identified for
residential retrofits depend on the year in which the home was built. Studies developed for new
i California Energy Commission. Docket Number 16-BSTD-07, April 22, 2019. Local Ordinance Application – 2016
Standards. TN# 227844. Existing Building Efficiency Upgrade Cost Effectiveness Study. Available at
https://efiling.energy.ca.gov/GetDocument.aspx?tn=227844&DocumentContentId=59219.
Oct. 11, 2022 Item #12 Page 430 of 560
392
construction may be used to support requirements for certain additions and alterations that are
considered “new” in the context of the reach code. A separate study is also available to support a
handful of requirements for retrofits of existing residential units.i
Explore Other Options for New Buildings
Other possible policy options exist to increase efficiency and electrifications in new buildings, including
energy use rating and disclosure for new homes, improved building energy code compliance, and
assessing and disclosing embedded carbon.
Implement More Policies to Increase Efficiency in Existing Buildings
In addition to the addition and alteration projects covered by reach codes, policies that affect other
existing buildings can reduce GHG emissions. Based on the review of CAPs and the scenario analysis of
GHG impacts, several potential opportunities emerge to increase efficiency in existing buildings.
• Existing Building Incentives and Requirements – Even though nearly half of CAPs include
measures related to encouraging or requiring efficiency improvements because existing
represent the largest portion of building-related GHG emissions is associated with existing
buildings, additional activity related to existing buildings would be necessary.
• Municipal Energy Efficiency Improvements – More than half of the CAPs included in this
analysis include measures to improve energy efficiency at municipal facilities. While related
energy use is relatively small compared with city- or regionwide energy use, implementing cost
effective energy efficiency in municipal buildings provides an opportunity not only to reduce
energy expenditures but to demonstrate leadership by modeling the types of building
improvements that CAPs may contemplate for homes and businesses.
Existing structures are key to building decarbonization since about 80% of buildings that will exist in the
San Diego region in 2050 already exist in 2020. Efficiency remains a way to reduce energy use,
emissions, and energy utility costs, particularly in the short- and medium-term while buildings transition
toward electrification. As noted above, reach codes can address existing buildings that undergo
alterations and additions, but given the number of CAPs with measures related to existing buildings and
the expected GHG impacts both from existing CAP commitments and the best commitment scenario,
there is an opportunity for additional local policy action.
Local jurisdictions have the authority to encourage or require energy efficiency improvements and to
audit, benchmark, and disclose. And, there are numerous examples of these policies in the San Diego
region and across California.
There are relatively few CAPs with audit, benchmarking, and disclosure measures. These
policies result in relatively small energy and GHG emissions reductions but help to raise
awareness of energy use and can form the foundation of future policies. These policies can
transition to include information about associated carbon emissions in the future, especially as
we transition to electric appliances.
Non-Residential
Figure 8.39 includes common elements of policies that require energy efficiency improvements or
related activities in existing non-residential buildings. Policies often include one or more elements and
i CA Energy Codes and Standards Program (2021). 2019 Cost-Effectiveness Study: Existing Single Family Residential
Building Upgrades.
Oct. 11, 2022 Item #12 Page 431 of 560
393
can cover water efficiency. There are examples of local policies that focus on just one of these elements,
while others include nearly all of them.
Figure 8.39 Key Elements of Nonresidential Existing Building Energy Efficiency Policies
• Audits – Policies can require building owners to complete energy audits of buildings to identify cost
effective opportunities to improve efficiency. Energy improvement opportunities identified during
an energy audit can be pursued voluntarily by building owners or form the basis for an energy
improvement requirement.
• Benchmarking – Requiring a building owner to benchmark energy use typically entails collecting and
reporting data through ENERGY STAR Portfolio Manager.i Once disclosed, benchmarking data allows
building owners to compare energy use with similar buildings. As noted above, California has
enacted AB 802 (2015), which requires certain buildings to report energy use data. More generally,
benchmarking serves as a foundational policy that can provide needed information and data to
develop more targeted and appropriate building energy policies.
• Disclosure – Often paired with audits and benchmarking, disclosure policies require building owners
to disclose certain energy use and related data to tenants, lessees, and buyers. Disclosure provisions
also often have local jurisdictions publicly post to a website certain energy data for building subject
to the energy auditing or benchmarking requirement. These policies allow existing and potential
tenants and buyers to understand energy consumption and the potential implications, including
financial.
• Efficiency Improvements – Policies can require that certain buildings complete efficiency
improvements. In general, there are two pathways to demonstrate compliance: performance and
prescriptive. Using performance standards, a building owner can comply by meeting a specified
performance standard, typically energy use per square foot of building area. There is a trend toward
using carbon dioxide as a performance metric. Boston and New York City have adopted GHG
performance standards.ii Using a prescriptive compliance pathway, building owners can comply by
completing specified building energy improvements (e.g., installing insulation). Performance and
prescriptive pathways are used in new building requirements in Title 24, part 6.
• Retrocommissioning and Building Tune-Up – These options focus on low- or no-capital
improvements to energy-related building equipment. According to New York City’s Local Law 87,
retro-commissioning is a “systematic process for optimizing the energy efficiency of existing base
building systems through the identification and correction of deficiencies in such systems, including
but not limited to repairs of defects, cleaning, adjustments of valves, sensors, controls or
i U.S. Environmental Protection Agency Energy Star Portfolio Manager webpage. Available at
https://www.energystar.gov/buildings/benchmark.
ii See New York City Local Law 97, available at https://www1.nyc.gov/assets/buildings/local_laws/ll97of2019.pdf.
See also City of Boston Building Emissions Reduction and Disclosure Ordinance, available at
https://www.boston.gov/departments/environment/building-emissions-reduction-and-disclosure.
Oct. 11, 2022 Item #12 Page 432 of 560
394
programmed settings, and/or changes in operational practices.”i For example, Chula Vista requires
retro-commissioning as a compliance option for conservation requirements for non-residential and
certain multi-family buildings. On the other hand, according to the City of Seattle, a building tune-up
includes an inspection of building systems to identify operational or maintenance issues and
corrections to operational issues identified in the inspection that have relatively short paybacks.ii In
general, retro-commissioning includes more robust documentation than a building tune-up.
Several cities in California have adopted policies to improve energy efficiency in existing nonresidential
buildings that include some or all of these key elements. The City of San Diego has also adopted a policy
requiring benchmarking and disclosure.iii The City of Berkeley’s Building Energy Savings Ordinance
(BESO) requires all buildings, depending on size, to benchmark or audit, and disclose energy usage
information at the time of listing for sales. Certain large buildings have to conduct benchmarking every
1–5 years.iv The City of San Francisco has a similar ordinance for nonresidential and large residential
buildings.v The Cities of Chula Vista, Los Angeles, and San Jose have adopted ordinances that include
benchmarking and disclosure provisions along with a building performance requirement with multiple
compliance options, including completing energy efficiency improvements, audits, and
retrocommissioning. Table 8.36 summarizes policies for a sample of cities in California.
Table 8.36 Comparison of Energy Efficiency Policies for Existing Non-Residential Buildings in CA.
i Erin Beddingfield and Zachary Hart, “Putting Data to Work: Using Data from Action-Oriented Energy Efficiency
Policies and Programs.” IMT. https://www.imt.org/wp-content/uploads/2019/11/IMT-PuttingDatatoWork-Using-
Audit-Data.pdf.
ii City of Seattle, Building Tune-ups Resources.
iii City of San Diego Municipal Code. Article 12, Division 1, Sections 1412.0101 to 1412.0113. See
https://docs.sandiego.gov/municode/MuniCodeChapter14/Ch14Art12Division01.pdf.
iv City of Berkeley Municipal Code Chapter 19.81 Sections 19.81.010 to 19.81.170. See
https://www.cityofberkeley.info/uploadedFiles/Planning_and_Development/Level_3_-_Energy_and_Sustainable_Development/BESOordinanceUpdated_20201215.pdf.
v https://sfenvironment.org/sites/default/files/fliers/files/sfe_gb_ecb_ordinance_overview.pdf.
Oct. 11, 2022 Item #12 Page 433 of 560
395
Residential Buildings
There are fewer adopted policies for existing residential buildings in California. Two examples include
the City of Berkeley’s Building Energy Savings Ordinance and the City of San Francisco’s Residential
Energy Conservation Ordinance (RECO). These policies include auditing, disclosure, and energy efficiency
improvement provisions.
As described above, the City of Berkeley’s Building Energy Savings Ordinance requires all buildings,
including residential buildings with 1-4 units, to conduct a building energy audit and disclose the results
to potential lessees and buyers prior to executing a lease or contract for sale.
The City of San Francisco has adopted a RECO that requires owners of single- and two-family dwellings,
apartment buildings, and residential hotels to conduct an audit and to complete prescriptive energy and
water efficiency improvements at the time of sale and prior to the transfer of title.i In addition to time of
sale, there are several other intervention points for this policy, including metering conversion, major
improvements, and condominium conversions.
Examples of the prescriptive measures required for single- and two-family family buildings include:
insulation, weatherstripping, water heater insulation, low-flow showerhead, caulk and seal openings in
building exterior, insulate heating and cooling ducts, faucet aerators, and low flush toilets. San
Francisco’s RECO includes compliance cost limits of one percent of purchase price or one percent of
assessed value, whichever is great. For a building with two units or fewer, there is a cap of $1,300.
Evaluate Policies to Accelerate Electrification in Existing Buildings
Only two CAPs in the region have measures or supporting actions that seek to electrify the existing
building stock — one through incentives and the other through a requirement. In both instances, the
focus is on water heating only. Since the existing building stock represents an outsized share of building-
related emissions, additional activity to electrify the existing building stock will be necessary to reach
deep decarbonization targets.
California’s building energy code covers additions and alterations to existing buildings but does not
affect the vast majority of existing buildings that are not subject to these requirements. Developing
policies to accelerate electrification in existing buildings would be necessary to reach the level of
building equipment replacement contemplated in Chapter 4. At present, there are very few examples in
California to electrify existing buildings outside of the building energy codes. Two cities that have begun
exploring and developing policies — the City of Berkeley and the City of Sacramento — provide some
guidance.
In April 2021, the City of Berkeley released a draft existing building electrification strategy.ii It includes a
detailed treatment of the social equity considerations related to building electrification, technical
analysis of buildings and energy use, cost analysis, and policy options. The City of Berkeley’s overall
policy framework, as presented in Figure 8.40, includes equity considerations; three main
implementation strategies (pillars) that are similar to those identified in the review of CAPs (Section 8.3);
i San Francisco Housing Code Chapter 12 (Residential Energy Conservation) and Chapter 12 A (Residential Water
Conservation).
ii City of Berkeley. April 2021. Existing Building Electrification Strategy. Available at
https://www.cityofberkeley.info/uploadedFiles/Planning_and_Development/Level_3_-
_Energy_and_Sustainable_Development/Draft_Berkeley_Existing_Bldg_Electrification_Strategy_20210415.pdf.
Oct. 11, 2022 Item #12 Page 434 of 560
396
and four strategies to electrify buildings, including replacing natural gas appliances at the time of
replacement and building renovation, and at the time sale; building performance standards; and
neighborhood approaches to electrification and natural gas pruning, the latter concept is discussed in
Chapter 4. A similar analysis of buildings, equity, and policy options could be done by cities in the San
Diego region or on a regional basis, as described below.
Figure 8.40 City of Berkeley Building Electrification Frameworki
In June 2020, Mayors’ Commission on Climate Change (MCCC) released final recommendations for the
City of Sacramento and the City of West Sacramento to achieve carbon neutrality by 2045, including the
goal of transitioning 25% of existing residential and small nonresidential buildings to all-electric by 2030,
and 100% of existing buildings by 2045.ii In June 2021, the City of Sacramento adopted a to guide
building electrification.iii The framework established goals, objectives, milestones, and a timeline for
completion. It also seeks to integrate social equity-focused considerations.
Key Considerations for Existing Building Policies
There are several key considerations when developing a policy to electrify existing buildings. These also
apply to energy efficiency improvements.
• Applicability – This determines which buildings will be covered by the policy. Applicability is
often determined on the basis of building type (e.g., residential and nonresidential) and size
(e.g., square feet of building area). As important as which buildings are included in which
buildings are specifically exempted or excepted from the provisions of the policy. Exemptions
can be based on many different factors, including who owns the building (e.g., public or private),
the type of equipment used, how recently similar improvements were made, the function of the
buildings (e.g., essential or emergency function), and cost of compliance.
i Id.
ii The Mayors’ Commission on Climate Change webpage. Available at https://www.lgc.org/climatecommission/.
iii Resolution No. 2021-0166, Adopted by the Sacramento City Council, June 1, 2021. Available at
https://www.cityofsacramento.org/Community-Development/Planning/Major-Projects/General-Plan/About-The-
Project/Climate_Change/Existing-Building-Electrification.
Oct. 11, 2022 Item #12 Page 435 of 560
397
• Phasing – This determines when building owners will be subject to the provisions of the policy.
Provisions can be in force at the date of adoption or phased in over time to allow building
owners time to adjust to the requirements.
• Intervention Points – Sometimes called “triggers,” these determine when the provisions of the
policy apply. Intervention points can include: time of sale or time of listing; building size,
typically based on building size (i.e., square footage); point of lease or rental; building
renovation; building maintenance or major system replacement; building resilience upgrade
(e.g., seismic renovation, flood prevention); building type (e.g., single-family or multi-family),
and strategies that implement activities by geography (e.g., neighborhood).i
• Enforcement – Whether and how a local jurisdiction can monitor compliance and enforce a
policy, particularly a requirement, is an important consideration. Enforcement can be related to
the intervention point. For example, policies that use the permitting process as a trigger for a
requirement may be easier to enforce given existing staff and capacity. On the other hand, new
requirements attached to permitting may create a disincentive to acquire a permit.
Local Governments Continue to Demonstrate Building Efficiency and Electrification
Just over half of CAPs have measures to improve efficiency at municipal facilities. This is least regret
policy because implementing cost effective measures help to reduce operating costs and can model the
type of actions local governments may encourage homes and businesses to do. It is possible that these
are already happening but are not included in CAPs, but there appears to be an opportunity for
additional energy efficiency improvements in municipal facilities. It is common for local governments to
conduct audits of existing facilities to identify opportunities for energy efficiency, and some cities have
developed detailed energy strategies.
Potential for Regional Collaboration
While local governments have authority to act to encourage and require efficiency and electrification of
buildings, a regional approach could facilitate broad adoption of policies both for new and existing
buildings.
Regional Program to Support Reach Code Policy Development
Given the clear, existing authority that local governments have to adopt local building codes (e.g., reach
codes) for new buildings and the existing knowledge and experience in the region and around statewide,
developing a regional approach to reach code development, adoption, and implementation is a least
regret policy. Such a program could include the following key elements.
• Conduct a Regional Reach Code Analysis – Conduct regional reach code analysis to identify
opportunities for further action by jurisdiction and climate zone. This analysis could consider the
future build out of the region, analyze future building growth in each jurisdiction, identify the
best approaches, and identify policy gaps and opportunities for each jurisdiction.
• Support Development and Implementation of Reach Code Policies – A regional program could
support development and implementation of regional reach codes. This program could leverage
existing resources, including SDG&E Codes and Standards program and Statewide Reach Code
Program.ii The Clean Power Alliance, the Los Angeles region CCA, completed a report on
potential programs and identified a regional reach code program as one option. Based on the
report, such a program could: develop model ordinances to streamline the process for local
i City of Berkeley Building Energy Saving Ordinance Evaluation Report February 11, 2020. Energy Solutions.
ii https://localenergycodes.com/.
Oct. 11, 2022 Item #12 Page 436 of 560
398
jurisdictions, provide funding to local governments for the development and adoption process
of a building electrification code, and make available technical assistance to municipalities that
want to adopt a building electrification reach code.i The Bay Area Renewable Energy Network,
known as BayREN, has a similar program to support development of local building energy code
policies for new buildings. ii
Regional Program for Decarbonizing Existing Buildings
The largest policy gap in CAPs related to building decarbonization is improving efficiency and electrifying
existing buildings. In particular, there are relatively few CAP measures to accelerate the turnover of
natural gas appliances in both residential and commercial buildings. Federal and state action will
continue to encourage building decarbonization, but there is a role for local jurisdictions.
Historically, improving energy efficiency in existing buildings has been difficult. It is expected that
electrifying existing buildings will be equally challenging. There is an opportunity to evaluate the
potential for a regional program that could complete analysis, help develop policy options and support
the adoption and implementation of related policies. This is similar in concept to the reach code support
program contemplated above, but the prerequisite analysis, materials, and approach are comparatively
less developed than for reach codes. Also, existing building policies are sufficiently different from new
building policies and approaches to warrant a separate effort. The following are examples of elements of
such a program.
• Conduct Data Analysis on Existing Buildings – There is a lack of publicly available data related to
existing building energy use. Collecting and analyzing existing regional building data could help
form evidence-based policies. This could include mapping buildings; collecting data to
characterize buildings by age, type, use, etc.; determining whether they use natural gas
appliances; etc. This work can form the analytical basis for develop a strategy and eventual
policies. Also could provide necessary information and mechanisms to monitor progress over
time, preferably using a publicly available data portal. Because privacy rules exist that govern
the types and granularity of energy consumption data that can be shared publicly, methods
would have to be developed to aggregate results in a way that does not violate these rules.
• Convene an Existing Building Decarbonization Task Force – Results of a regional building energy
analysis could inform the work of a regional building decarbonization task force, which could
comprise key stakeholders from around the region including: community-based organizations,
environmental advocates, San Diego Gas & Electric, community choice aggregation programs,
building officials and related city staff, labor unions, building trades, developers, policy experts,
etc. The goal of the task force could be to develop a regional strategy to decarbonize buildings.
• Develop a Regional Strategy to Decarbonize Existing Buildings – A regional existing building
decarbonization strategy would help to develop a framework and implementation pathways to
accelerate both energy efficiency and electrification. Chapter 4 provides a good first step, but a
more detailed analysis, strategies, and policies are needed. As an example, the City of Berkeley
has developed Existing Buildings Electrification Strategy.iii A strategy could consider social equity
factors, the potential for a regional incentive program, and stakeholder outreach.
• Develop a Program to Support Development of Existing Building Policy – A regional program
could support development, adoption, and implementation of existing building policies. Such a
i Clean Power Alliance. 2020 Local Programs for a Clean Energy Future, p. 26.
ii Bay Area Regional Energy Network (BAYREN). Reach Codes and Policies webpage. Available at
https://www.bayrencodes.org/reachcodes/.
iii City of Berkeley. April 2021. Existing Building Electrification Strategy.
Oct. 11, 2022 Item #12 Page 437 of 560
399
program could include model policies and supporting materials, technical/expert support
throughout the process, and implementation support.
8.7 Decarbonize the Electricity Supply
Decarbonizing the electric supply is a pivotal step in the overall decarbonization framework. Increasing
carbon-free electricity supplies not only reduces GHGs from the electricity sector it also becomes the
low- or zero-carbon energy source of choice for transportation and buildings to enable additional GHG
reductions. In general, there are two main methods to reduce emissions from the electricity supply: (1)
increase the amount of carbon-free electricity supplied to customers from the electric grid, typically
from large-scale projects, and (2) increase installation of distributed renewable energy projects located
on the customer side of the electric meter.
This section follows a similar format as the sections above and will cover authority of local governments
to act; local CAP commitments, including the number of CAPs with related measures and the GHG
impact of those measures; and a summary of opportunities for additional local action and regional
collaboration. The geospatial analysis of renewable energy presented in Chapter 2 estimates the
potential for both large-scale and distributed (e.g., rooftop and infill) in the region. We provide some
findings on the GHG contribution of related CAP policies but did not include distributed solar in our
scenario analysis of CAPs, mainly because associated GHG reductions are included in the reference
scenario.
8.7.1 Summary of Findings
Table 8.37 summarizes key takeaways for the Decarbonize the Electricity Supply Pathway.
Table 8.37 Summary of Key Takeaways from the Decarbonize the Electricity Supply Pathway
Policy Category Key Takeaways
Grid Supply
All adopted and pending CAPs have related measures, typically related to community choice
aggregation (CCA), reflective of existing authority; relatively high GHG reductions in CAPs;
opportunity for more cities to join existing CCAs, and commit to 100% carbon-free service
options for municipal accounts and default community accounts.
Customer Side
Supply
All adopted and pending CAPs have related measures reflective of existing authority;
relatively low GHG reductions in CAPs due mainly to State activity in this area; limited
opportunity for more jurisdictions to adopt reach codes for new construction, but more
opportunity exists for alterations and additions; opportunity to increase customer side
generation in existing buildings, particularly when coupled with energy storage.
Key Findings of Analysis
This is a summary of results of the review of authority to act, the review of CAPs, and the scenario
analysis that estimates the aggregated impacts of CAPs.
• Authority Exists to Procure and Require Carbon-Free Electricity Supply – Local jurisdictions may
supply electricity to their citizens either through the formation of community choice aggregator
(CCA) or municipal utility, with the primary difference between the two being that the municipal
utility owns the distribution and transmission infrastructure while the CCA does not. Both
options allow the procurement and supply of higher renewable energy content electricity than
that required by California’s Renewable Portfolio Standard (RPS) for the incumbent investor-
owned utility. Both options are subject to federal and/or state preemption over reliability, which
complicates fully decarbonizing the electricity supply with renewable energy. However,
Oct. 11, 2022 Item #12 Page 438 of 560
400
authority exists to support alternatively fueled thermal power plants and related infrastructure
that can provide low- or zero-emission (e.g., green hydrogen) electricity to meet reliability and
air quality requirements. Local jurisdictions also play a direct role in increasing distributed
generation through CCAs, reach codes, and permit streamlining. Local jurisdiction over more
stringent regulation of direct emissions from conventional fossil fuel generators is uncertain
because of litigation but possibly preempted by the Federal Clean Air Act. California’s Cap-and-
Trade preempts local jurisdiction authority over GHG emissions from these fossil fuel facilities
unless the facility falls below Cap-and-Trade’s 25,000 metric ton emissions threshold.
• Decarbonizing Electricity has the Highest GHG Reduction in CAPs – Increasing carbon-free
electricity is the single largest contributor to GHG reductions in adopted and pending CAPs. All
17 CAPs evaluated have a measure to achieve a high renewable electricity supply, typically from
forming or joining a CCA program. If the most aggressive CAP policy related to CCA is applied to
all jurisdictions, additional reductions are possible; however, because most CAPs include a
measure to achieve or approach 100% renewable or carbon-free electricity supply, expanding
participation in CCA programs would increase expected GHG reductions by about 30%, which is
less than other policy actions considered in our scenario analysis of GHG impacts from CAP
measures.
Opportunities for Further Action
The following summarizes key opportunities for further action.
• Opportunities Exist for Local Policies to Increase Carbon-Free Electricity Supply – In the San
Diego region, there is an opportunity for more local jurisdictions to join existing CCAs or to
increase renewable supply otherwise and commit to 100% service options for municipal
accounts and default community accounts. CCAs also have the ability to develop programs to
encourage solar installations, including financial incentives for customer-scale projects and feed-
in tariffs for larger scale projects.
• State Requirements for Solar on New Buildings Limit Local Opportunities – In the past, CAPs
sought to require solar in new construction, but the State’s building energy code now requires
solar for new low-rise residential. Also, while local jurisdictions could require solar in
nonresidential new construction, it will be mandated when the next code cycle is effective in
January 2023. As a result, the State requirements limit the role of local jurisdictions to reduce
GHG emissions from distributed solar. An opportunity exists to evaluate mandating or incentives
for energy storage systems paired with solar to decrease marginal emissions during the electric
system’s peak and highest GHG emission hours, which will align both with new net energy
regulations and rates that reflect these realities.
• Opportunities Remain to Require Solar in Alteration and Addition Projects – While upcoming
changes to the State’s building energy code will require solar on new nonresidential buildings,
there is an opportunity for local jurisdictions to adopt reach codes that require solar on
alteration and addition projects. Examples of these policies exist in the region and around
California. GHG reductions associated with these policies likely would be limited given the
number of affected projects but more analysis would be needed to determine the full potential
of these policies.
• Additional Work Would be Needed to Make Carbon-Free Electricity Supply More Accessible –
Research shows that most distributed solar PV systems installed in California have been installed
in higher-income neighborhoods with higher levels of homeownership compared to the
statewide average. Numerous options exist to address the inequitable distribution of solar
installations, including targeted incentives and financing. Also, in the short run before California
Oct. 11, 2022 Item #12 Page 439 of 560
401
meets its 100% carbon-free electricity requirement, enabling residents in communities of
concern to participate in service options with high levels of carbon-free electricity can also
address this issue. CCA programs can maximize participation in the Disadvantaged Communities
Green Tariff Program and subsidize CARE and FERA customers to opt up to 100% carbon free
electricity service options.
8.7.2 Summary of Authority in the Decarbonize the Electric Supply Pathway
Electricity regulation is divided between state regulation of the distribution system and procurement of
supply and federal regulation of bulk-power transmission systems and bulk-power markets. In both
instances, reliability requirements preempt local authority over electricity procurement where the
procurement impacts either CPUC resource adequacy (RA) requirementsi or FERC authority over electric
reliability in bulk-power systems.ii The following will discuss local authority in light of the state and
federal regulation of conventional and renewable electricity supply resources. Additional information
can be found in Appendix B.
Conventional and Fossil Fuel Generation
California’s Cap-and-Trade program regulates covered entities that include cogeneration, self-
generation of electricity, stationary combustion, and first deliverers of electricity that emit 25,000
metric tons or more of CO2e per data year.iii The CEC is the siting authority for thermal power plants of
50 megawatts or more with authority that preempts local jurisdiction land use authority.iv The CEC is
prohibited from siting new nuclear power plants unless there is demonstrated technology or disposal
site for high-level nuclear waste.v The Governor may also preempt local land use authority on a limited
basis through an emergency declaration.vi Finally, all electric utilities and load-serving entities are
prohibited from entering into any baseload power generating commitments of 5 years or more if such
projects are not as clean as a combined-cycle gas turbine project.vii
In terms of air quality, there is uncertainty as to the extent that a local air district may further regulate
GHG emissions in relation to CARB’s authority and U.S. EPA authority due to litigation and presidential
administration changes. A June 2022 U.S. Supreme Court decisionviii limited U.S. EPA’s ability to regulate
new and existing power plant GHG emissions. It remains unclear what action U.S. EPA will take in
response and how that will impact CARB and local air district regulation of new and existing power
plants in California. However, authority exists to create voluntary GHG reduction generation and
certification programs in an air district.
Renewable Energy
Existing authority allows a local jurisdiction to procure electricity supply on behalf of their citizens with a
chosen renewable energy content that meets or exceeds the RPS through a CCA or municipal utility
i See Public Utilities Code § 380; See CPUC Resource Adequacy Proceeding R.19-11-009.
ii See 14 U.S.C. § 8240.
iii 17 C.C.R. §§ 95811 (a)–(b) & 95812(c).
iv Public Resources Code §§ 25500 et seq.
v Public Resources Code § 25524.2.
vi See Governor’s July 30, 2021 Proclamation of A State of Emergency to address energy supply and demand issues;
See U.S. Const. Amendment X; See California Emergency Services Act: Government Code §§ 8558, 8567, 8571,
8625, & 8627. vii Public Utilities Code §§ 8340–8341.
viii See West Virginia v. U.S. EPA, 597 U.S. __ (2022).
Oct. 11, 2022 Item #12 Page 440 of 560
402
corporation (including developing thermal generation fueled from renewable sources such as green
hydrogen), determine the GHG emission content of CCA supplied electricity under its police power or as
a member of a CCA, franchise public rights of way for energy infrastructure, and support of distributed
generation through CCA policy, incentives, and permit streamlining.
8.7.3 GHG Impacts of CAP Measures in the Decarbonize the Electricity Supply Pathway
This section summarizes the GHG impacts from CAP measures related to building decarbonization from
our CAP review. The scenario analysis of GHG impacts from CAPs only looked at policies related to grid
supply. Those results are provided in Section 8.7.4 below.
Review of the Decarbonize the Electric Supply Pathway Policies
For this analysis, we compare GHG impacts across CAPs. Based on the review of CAPs, measures in the
Decarbonize the Electric Supply Pathway account for between 10% and 67% of local reductions, with an
average across all CAPs of 42% (Figure 8.41).
Figure 8.41 Contribution of Measures to Decarbonize the Electricity Supply in Adopted and Pending CAPs.
A further breakdown of CAP measures related to decarbonizing the electric supply from the review of
CAPs shows the number of jurisdictions with one or more CAP measures or supporting action related to
each of the three related policy categories and the associated average GHG contribution to the local CAP
GHG reduction. Figure 8.42 shows that all of the 17 adopted or pending CAPs have measures related to
increasing both grid supply and customer-side renewable energy supplies. Those related to grid supply,
which includes measures to develop a community choice aggregation program, contribute on average
about 36%, and range from about 10% to 55%. On average, measures to increase utility scale renewable
energy contribute more than any other policy category – about twice as much as the next highest
category (Alternative Fuel Vehicles and Equipment, including electric vehicles, at 16%). Measures to
increase use of customer side renewable electricity systems, typically solar photovoltaics, represent on
average about 9% of local CAP GHG reductions and range from about 1% to 29% of local reductions.
Oct. 11, 2022 Item #12 Page 441 of 560
403
Figure 8.42 Number of Jurisdictions with Related CAP Measures and Associated GHG Impacts
8.7.4 Grid Supply of Carbon-Free Electricity
California has a statutory target of 100% carbon-free electricity supply by 2045. So, regardless of local
action, the region’s renewable supply will approach this target. Nonetheless, local governments can
accelerate attainment of this goal, thus realizing more overall GHG reductions and doing so earlier than
the statutory trajectory. GHG emissions impacts associated with CCAs are those above and beyond what
is expected from the state requirements. Table 8.38 summarizes the requirement for renewable and
carbon free content of the electric supply. For example, energy suppliers are required to supply 60%
renewable content by 2030. If a CAP were to commit to increasing that amount to 75%, the difference
would be attributed to CCA and is included in the local CAP GHG reduction.
Table 8.38 SB 100 (2018) Requirements for Renewable and Carbon Free Content in Electric Supply.
Renewable Content Requirement Deadline
44% 21/31/24
50% 12/31/26
52% 21/31/27
60% 12/31/30
100% carbon free 21/31/45
According to the most recent Renewable Portfolio Standards Annual Report submitted to the legislature
by the CPUC, the percentage of RPS-eligible renewable supplies for each of the three large IOUs in
California ranges from 34% to 39%.i SDG&E has the highest percentage at nearly 39% renewable
content. On average, renewable content accounts for about 47% of electricity supplies by Community
Choice Aggregation programs in California.
Values reported for IOUs include unbundled renewable energy credits (REC). These may vary from
values in the CEC Power Source Disclosure process, which account differently for RECs. CCA programs in
the region are not fully operational but have stated that they will not use unbundled RECs and likely will
achieve at least 50% renewable content, given the default service plans described in more detail below.
Scenario Analysis of GHG Impacts for the Decarbonize Buildings Pathway
In contrast to the review of CAPs, which considers measures in all emissions categories and does not
i 2021 Renewable Energy Portfolio Annual Report. November 2021. California Public Utilities Commission. Available
at https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/energy-reports-and-whitepapers/rps-reports-
and-data.
Oct. 11, 2022 Item #12 Page 442 of 560
404
consider the combined impact of measures, the scenario analysis only evaluates emissions from on-road
transportation, electricity, and natural gas, and estimates the GHG impact of all related CAP measures.
For purposes of showing the combined GHG impact of all CAP commitments to decarbonize the
electricity supply, we only looked at those related to exploring, forming, or joining CCA programs. These
represent the vast majority of GHG reductions from CAP commitments, about 1.3 MMT CO2e in 2035.
Figure 8.43 shows the impact of these measures (orange wedge) on regional emissions. The upper
dashed line represents the legislatively adjusted BAU emissions level. The bottom dashed line
represents the impact of policies of all four decarbonization pathways in adopted and pending CAPs.
No customer side renewable electricity is included in the GHG analysis because an increase in
distributed solar is embedded in the legislatively adjusted BAU, and some of the policies to increase the
amount of solar on new residential construction in adopted and pending CAPs are now mandated by
California building energy code Title 24, Part 6. Nonetheless, we provide a review of existing CAP
measures related to customer side renewables.
Figure 8.43 Contribution of Decarbonizing the Electric Supply in the Adopted CAP Commitment Scenario.
GHG Impact from Best Adopted CAP Commitments Applied Regionwide
If the best adopted CAP commitment related to CCA adoption is applied to all local jurisdictions in the
San Diego region, the GHG reduction would be about 1.6 MMT CO2e. As noted in Figure 8.44, while the
contribution of CCA programs is larger, it represents a smaller portion of the overall reduction that
would result from the best adopted CAP commitment in all policy subcategories being applied to all
jurisdictions in the region (bottom dashed line). Also, because all electricity in California must be 100%
carbon free by 2045, the incremental impact from local actions decreases over time as the supply
complies with state mandates. This is why the wedge in both the CAP Commitment (Figure 8.43) and
Best Adopted CAP Commitment Scenario (Figure 8.44) show that accelerating renewable electricity
mandates can lead to higher cumulative GHG reductions (area of the wedge). While this may not affect
whether a CAP attains the required emissions level in a target year, it can affect overall atmospheric
warming.
Oct. 11, 2022 Item #12 Page 443 of 560
405
Figure 8.44 Contribution of Decarbonizing the Electric Supply in the Best Adopted CAP Commitment Scenario
CAP Measures Related to Increasing Grid Supply of Carbon-Free Electricity in the San
Diego Region
Based on the review of CAPs, all 17 of the adopted or pending CAPs reviewed include a measure to
explore, develop, or join a community choice aggregation or similar program (Table 8.39). Examples of
related CAP measures are provided in Table 8.40. While SDG&E offers a 100% renewable option and a
few CAPs include measures related to increasing awareness of this program, it is limited in scope by
statute, and SDG&E has requested that the CPUC suspend the program due to current and expected
declines in enrollment and consequent increases in costs to customers.i In practice, to leverage local
government authority to influence the electricity supply in the region at a significant scale, CCA is the
main policy mechanism in this policy subcategory.
Table 8.39 Number of Adopted and Pending CAPs with Measures Related to Increase Renewable Grid Supply
i Robb Nikolewski. Why SDG&E Wants to Suspend a Program that Offers Customers Extra Renewable Energy. San
Diego Union Tribune, January 6, 2022. Available at https://www.sandiegouniontribune.com/business/story/2022-
01-06/sdg-e-looks-to-suspend-customer-program-for-extra-renewable-energy.
Oct. 11, 2022 Item #12 Page 444 of 560
406
Table 8.40 Examples of CAP Measures to Expand Grid Supplied Renewable Electricity via CCA
Implementation Mechanism General Policy
Capital Improvement & Infrastructure NA
Education, Outreach, & Coordination • Encourage SDG&E to achieve 100% renewable
• Partner with neighboring municipalities to explore CCA feasibility
• Advocate for a regional CCA
Evaluation • Conduct a CCA feasibility study
Incentives NA
Plan or Program • Develop or join a CCA or similar program
• Adopt a renewable energy procurement policy
Requirement(s) NA
Examples of Policies in Region
Because nearly all of the adopted or pending CAPs have a measure to explore, develop, or join a CCA,
we focus here on the implementation of those measures. As a result of CAP measures, in part, there are
two operational CCAs in the San Diego region: San Diego Community Power and Clean Energy Alliance
(Table 8.41). The total number of customers that will be included in these programs is yet to be
determined since local jurisdictions continue to join, and each CCA is not serving all customers. As an
opt-out program, the total number of participating customers depends on the number that affirmatively
opt-out to either continue receiving electricity from SDG&E or from a direct access provider. This will be
unknown until all SDCP residential customers are enrolled by the middle of 2022.
Table 8.41 Community Choice Aggregation Programs in the San Diego Region
CCA Program Member Jurisdictions Status
San Diego
Community Power
(SDCP)
Chula Vista, Encinitas, Imperial Beach, La
Mesa, San Diego
National City and County of San Diego
joining in 2023
Launched service for Municipal customers
in March 2021 and commercial customers
in June 2021. Residential service planned
for early 2022.
Clean Energy
Alliance (CEA)
Carlsbad, Solana Beach, and Del Mar
Escondido and San Marcos joining in 2023
Launched service on May 1 for Carlsbad,
Del Mar and Solana Beach residents.
CCAs can, within statutory limits, determine the percentage of renewable electricity supplied to
customers. SDCP has two service plans: PowerOn, which includes 50% renewable supply and serves as
the default option for customers; and, Power100, which has 100% renewable supply and is available for
the customer to opt-up.i Similarly, CEA has multiple service plans: Clean Impact, which is 50% renewable
and is available for customers to opt-down from the default; Clean Impact Plus, which is 50% renewable
and 75% Carbon-Free, and serves as the default option for customers; and Green Impact, which is 100%
renewable content and is available for the customer to opt-up.ii Figure 8.45 summarizes the renewable
energy or carbon-free content of SDCP and CEA service plans.
i San Diego Community Power. Compare Service Plans webpage. Available at https://sdcommunitypower.org/your-
choice/compare-service-plans/.
ii Clean Energy Alliance Service Options webpage. Available at https://thecleanenergyalliance.org/your-options/.
Oct. 11, 2022 Item #12 Page 445 of 560
407
Figure 8.45 Renewable or Carbon-Free Content of CCE Electricity Service Plans
In addition to the renewable electricity service options offered by CCAs, SDG&E offers EcoChoicei and
Ecoshare.ii These are opt-in programs that provide customers with an option to purchase 100%
renewable electricity. These programs are limited to 59 MW of solar capacity by statute and are
currently available to customers. Given the limited customer uptake for these programs and the number
of customers transitioning to CCA programs, SDG&E has asked the CPUC to suspend the programs.iii
In addition to forming a CCA, there are other actions local governments can take to influence the GHG
emissions impact of these programs.
• Choice of Service Plan for Municipal Operations – Because CCA programs offer service plans
with differing levels of renewable content, local governments can choose to opt-up to the higher
renewable content product for municipal operations. For example, all local governments
participating in SDCP have opted up to the Power100 for municipal operations.
• Choice of Default Service Plan for Customers – City of Encinitas opted for Power100 as the
default option for customers.
Local governments also can influence is the siting and permitting of renewable electricity generation
projects. Currently, no CAPs include measures related to siting electric generation projects. Chapter 2
focuses on siting of large-scale renewable projects in the San Diego region. Based on findings, most
utility scale projects would be located in the unincorporated areas of San Diego County.
8.7.5 Customer Side Renewable Electricity
On average, measures to encourage or require solar on buildings account for about 8% of local
reductions in CAPs in the San Diego region. CAPs include a range of quantified measures and supporting
i San Diego Gas & Electric. Ecochoice webpage. Available at https://www.sdge.com/residential/savings-
center/solar-power-renewable-energy/ecochoice.
ii San Diego Gas & Electric. Ecoshare webpage. Available at https://www.sdge.com/residential/savings-
center/solar-power-renewable-energy/ecoshare.
iii Robb Nikolewski. Why SDG&E Wants to Suspend a Program that Offers Customers Extra Renewable Energy. San
Diego Union Tribune, January 6, 2022.
Oct. 11, 2022 Item #12 Page 446 of 560
408
efforts to increase use of distributed renewable electricity systems, mainly solar photovoltaics.
CAP Measures Related to Distributed Renewable Generation in the San Diego Region
Figure 8.46 summarizes the number of CAPs with at least one measure to increase distributed
renewable electricity supplies across all implementation mechanisms. The values presented here are not
mutually exclusive, and a CAP may have measures in multiple implementation mechanisms or
building/construction types. Table 8.42 below provides examples of CAP measures related to distributed
renewables for each of the implementation mechanisms.
Figure 8.46 Number of Adopted and Pending CAPs with Measures Related to Renewable Distributed Generation.
Based on the number of CAPs in Figure 8.46, measures to increase renewable electricity from
distributed generation systems follow a similar pattern as other policy categories, with most measures
falling into three categories: education, outreach, and coordination; incentives; and requirements. In
this case, the implementation mechanism with the highest number of CAPs with at least one measure
related to education, outreach, and coordination, including a range of actions to raise awareness about
distributed generation options and potential funding sources.
The number of remaining CAPs with related measures is roughly evenly split between incentives and
requirements. Incentive measures include actions to streamline the permitting process to lower the soft
costs associated with solar photovoltaics and make financing available, mainly through property-
assessed clean energy (PACE) programs. Focusing on requirements, the highest number of CAPs have
measures related to new buildings, with a slightly higher number related to non-residential. These
measures include requiring pre-wiring for solar photovoltaics and requiring solar in new construction,
additions, and alterations.
More than half of all CAPs have at least one measure to install distributed renewable systems at
municipal facilities. As noted above, while municipal energy use is relatively small compared with city- or
regionwide energy use, implementing cost effective energy efficiency in municipal buildings provides an
opportunity not only to reduce energy expenditures but to model the types of actions that CAPs may
include for homes and businesses.
Measures associated with new buildings are represented in the highest number of CAPs. Those
associated with new nonresidential building are represented in slightly more CAPs than new residential
buildings. As noted above, CAP measures to require solar photovoltaics in new residential construction
are no longer valid since California building energy codes now require this for most residential buildings.
Measures for existing buildings are relatively underrepresented in CAPs and are mostly requirements
associated with additions and alterations.
Oct. 11, 2022 Item #12 Page 447 of 560
409
Table 8.42 Examples of CAP Measures to Expand Renewable Electricity via Distributed Generation.
Implementation Mechanism General Policy
Capital Improvement & Infrastructure • Install solar PV on municipal facilities and other public buildings, including
parking lots
Education, Outreach, &
Coordination
• Partner with local utility to provide educational materials to account holders
• Support state and regional efforts to increase solar PV installs
• Promote existing funding sources and other resources
• Train city staff to provide educational materials
• Develop regional partnerships to provide educational materials and
technical assistance
• Collaborate with local solar PV providers
• Work with local universities to install solar PV systems
• Pursue partnerships and grant opportunities for funding
• Provide technical resources and case studies
Evaluation • Evaluate potential for microgrid at municipal facilities
Incentives • Make permitting easier (e.g., over-the-counter, streamlined, expedited)
• Expand PACE financing options
• Provide incentives for residential and nonresidential PV installs
Plan or Program • Develop a professional certification permitting program
Requirement(s) • Require pre-wiring for solar in new developments
• Require solar PV in new developments
• Require qualifying nonresidential additions and alterations to install solar PV
Examples of Policies in Region
The 2019 California Building Energy Code (Title 24, Part 6) updates required new low-rise residential
projects to include solar photovoltaics. As a result, there are no adopted ordinances in the region to
require solar on residential new construction. There are two jurisdictions in the San Diego region that
have adopted requirements for certain nonresidential new construction, alteration, and addition
projects to install solar. In the 2022 code update, which will take effect January 2023, new
nonresidential projects will be required to install solar and storage. Once this code update is effective,
reach codes requiring solar on new nonresidential buildings will be obsolete, though opportunities
remain for additions and alterations.
The City of Encinitas adopted Ordinance 2021–13 in October 2021. Section 120.10 requires certain
nonresidential projects to install solar photovoltaics. This requirement applies to all new nonresidential,
high-rise residential, and hotel/motel buildings, alterations that increase total roof area by at least 1,000
square feet, and alterations with a permit valuation of at least $1 million and that affect at least 75% of
building floor area. There are two methods to calculate the required amount of solar: one based on
gross floor area and the other based on time dependent valuation. Several exceptions are included in
the ordinance. For example, buildings with practical challenges, like shading or limited roof space and
commercial GHGs, are not required to meet the solar provisions of the ordinance.
The City of Carlsbad adopted a similar ordinance in March 2019 but has thresholds of 2,000 square feet
of additional roof area for additions.
Oct. 11, 2022 Item #12 Page 448 of 560
410
8.7.6 Opportunities for Further Local Action to Decarbonize Electricity
Integrate Equity Considerations into Policies to Decarbonize the Electric Supply
Several relevant factors related to equity could be considered when considering policies to decarbonize
electricity. The following presents a preliminary summary of some of these issues, but additional work
would be needed to understand and address these issues in the San Diego region.
In California, most distributed solar PV systems have been installed in higher-income neighborhoods
with higher levels of homeownership compared to the statewide average.i However, the proportion of
systems installed in disadvantaged communities has increased in recent years.ii This increase is due in
part to the falling price of PV and equity-focused programs, including SOMAH, Single-Family Affordable
Solar Homes Program (SASH), Multifamily Affordable Solar Housing Program (MASH), and other
programs funded by proceeds from California’s Cap and Trade Program.iii Programs like these, solar PV
leasing, and PACE financing have been associated with higher levels of solar PV adoption in
disadvantaged communities.iv The CPUC has an ongoing rulemaking to change several aspects of NEM
for residential customers, including addressing inequities related to how customers are compensated for
power that is exported to the electric grid.
While demand side factors like household income and homeownership can help determine solar PV
adoption, supply-side factors may also play a role. Recent research indicates that income-targeted
marketing by installers may lead to lower access to installers and fewer quotes by installers.v Several
policy options exist to address supply side factors, including providing incentives for companies to locate
their headquarters in communities of concern, provide incentives based on the number of quotes rather
than systems installed, train installers to understand the needs of customers located in communities of
concern, and explore options for installers to secure financing for these customers like green banks.vi
Owning or leasing a solar PV system is only an option for homeowners. While the MASH program
provides incentives for multi-family building owners to install solar PV and innovative business models
to equitably share the solar production exist,vii solar rooftop ownership or leasing is not an option for
renters. Increasing the percentage of grid electricity provided by zero carbon sources can address this
population. Near zero or zero-carbon service, options can cost more than other electricity service
options by the IOU or CCA. CEA CARE customers could receive the Green Impact Premium service
options, which would have a higher renewable electricity content with a relatively small price premium.
Alternatively, CCAs could subsidize the cost of opting CARE customers to the 100% zero-carbon service
option. Figure 8.47 shows the CEA rates for CARE customers for various service options as compared to
similar options from SDG&E. The cost premium for CARE customers to move from the 50% renewable
i Verdant Associates LLC. Net-Energy Metering 2.0 Lookback Study. Prepared for CPUC. P. 39. See also G.Barbose,
et al. (2021) Residential Solar-Adopter Income and Demographic Trends: 2021 Update. Lawrence Berkeley National
Laboratory, p. 39.
ii Id. at p. 39.
iii Id. at p. 39.
iv E. O’Shaughnessy, et al. (2021) The impact of policies and business models on income equity in rooftop solar
adoption. Nature Energy, Vol 6, p. 84-9.
v E. O’Shaughnessy, et al. (2021) Income-targeted marketing as a supply-side barrier to low-income solar adoption.
iScience 24, 103137. vi Id. at 10.
vii See https://www.ivy-energy.com/.
Oct. 11, 2022 Item #12 Page 449 of 560
411
option to the 100% renewable option is about $2.50 per month, based on the average bill provided.
Figure 8.47 CEA Rates for Standard-DR Residential - CAREi.
More Local Jurisdictions Can Join a CCA Program
Currently, 14 of the 17 CAPs evaluated for this project include CAP measures to increase the supply of
renewable electricity from the grid. Most of these specify forming or joining a CCA or similar program.
No other program options exist to yield the scale of renewable electricity procurement that can result
from CCA programs. As noted above, two CCAs have formed in the San Diego region: SDCP (6
jurisdictions) and CEA (5 jurisdictions). Eight cities in the region have not joined one of the CCA programs
in the region, though it appears that there are ongoing discussions. If the additional cities joined a CCA
or developed another measure to increase the amount of carbon-free electricity delivered to their
jurisdiction earlier than required by state law, more GHG reductions would occur earlier than otherwise
expected. Based on our Aggregated CAP Commitment analysis, adopted CAP commitments would
reduce GHG emissions by 1.2 MMT CO2e, while a scenario in which all jurisdictions adopted the most
aggressive renewable energy measures would result in 1.6 MMT CO2e. The overall GHG impact would be
relatively small since most jurisdictions already have committed to a high percentage of renewable
electricity. And since the law requires 100% carbon free electricity supply by 2045, the annual reduction
in that year would not change; however, reducing emissions earlier than state law requires would lead
to higher cumulative emission reductions.
Develop Options to Supply Higher Carbon-Free Content Electricity to Residents and
Businesses
Because CCAs are opt-out programs, eligible residents and businesses are automatically enrolled into
default service options. Customers can opt-out of the program altogether or select another service
option, which could have a higher level of renewable content. Getting more customers to participate in
the 100% carbon-free service option would increase the GHG impacts of CCA programs. Participating
jurisdictions can consider the following options:
• Make 100% Carbon-Free Default for All Participants – One option is to make 100% renewable
option default for all customers and allow customers to opt-down to lower renewable content
service options. This can be done on a jurisdiction by jurisdiction basis. For example, the City of
Encinitas City Council voted to make SDCP’s 100% renewable option (Power100) the default for
i Proposed Decision Revisiting Net Energy Metering Tariffs and Subtariffs. Rulemaking 20-08-020. 12-13-21.
Available at https://thecleanenergyalliance.org/wp-content/uploads/2021/07/SDGE-CEA-JRC-Online-Template-06-
01-2021_final-1.pdf.
Oct. 11, 2022 Item #12 Page 450 of 560
412
all participants.i East Bay Community Energy provides transparent tracking of the default service
options for all participating cities. Of the 15 participating jurisdictions, five make the 100 carbon-
free service option default for all customers, and another two make it the default for residential
customers only. ii
• Participate in Disadvantaged Communities Green Tariff Program – Because the higher
renewable content service options is often more expensive, not all participants will be able to
cover the incremental costs. As directed by AB 327 (2013), the CPUC developed options for
certain income qualified customers who live in disadvantaged communities (DACs) to have
access to renewable electricity generated locally.iii In June 2018, the CPUC created the
Disadvantage Communities Green Tariff (DAC-GT), which allows income-qualified, residential
customers in DACs who may not be able to install solar to receive a 20% bill discount for higher
renewable content electricity supply.iv The program is similar to the existing Green Tariff portion
of the Green Tariff/Shared Renewables Programsv (i.e., EcoChoice and EcoShare in the SDG&E
service territory) and is available to customers who meet the income eligibility requirements for
the CARE and FERA programs and live in an investor-owned utility service territory (e.g.,
SDG&E).vi
• Subsidize Cost to Opt-up to 100% Carbon Free for CARE and FERA Customers – Additional
options may be possible, including subsidizing the incremental cost for CARE and FERA
customers to opt-up to 100% carbon-free service options. Additional research would be needed
to determine the GHG impacts of opting up and the additional costs to determine whether a
program to opt-up to 100% renewable content is a cost effective means to reduce GHG
emissions.
Supply Municipal Operations with Carbon-Free Electricity
Local jurisdictions that participate in a CCA program can opt up to the 100% carbon-free service options
for municipal operations. All cities in SDCP have opted up to the 100% carbon-free service option for
municipal operations.vii For jurisdictions not participating in a CCA, other options exist, including SDG&E
EcoChoice, though there is a regional CAP on the amount of solar projects that can be installed to supply
this program, and SDG&E has recently requested the CPUC to suspend the program due to limited
uptake.
Require Solar PV on Existing Nonresidential Buildings
Local jurisdictions have the authority to adopt local energy codes that exceed statewide building energy
codes (Title 24, Part 6) and could require solar on new nonresidential construction, additions, and
alterations. California building energy codes already require solar for low-rise residential buildings. The
i Coast News. March 2, 2021. Encinitas commits to San Diego’s renewable electricity offering. Available at
https://thecoastnews.com/encinitas-commits-to-san-diegos-renewable-electricity-offering/.
ii East Bay Community Energy. Service levels transitions webpage. Avaialble at https://ebce.org/transition-to-renewable-
energy/.
iii Assembly Bill (AB) 327 (Perea, 2013)
iv California Public Utilities Commission. Decision 18-06-027 in Rulemaking 12-07-002. Available at
http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M216/K789/216789285.PDF. See also
https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/solar-in-disadvantaged-communities/the-disadvantaged-
communities-green-tariff-dac-gt-program.
v California Public Utilities Commission. Green Tariff/Shared Renewables program (GTSR) webpage. Available at
https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/electric-rates/green-tariff-shared-renewables-program.
vi San Diego Gas & Electric. Bill Payment Assistance webpage. Available at https://www.sdge.com/residential/pay-bill/get-
payment-bill-assistance/assistance-programs.
vii Personal communication with SDCP Director of Data Analytics and Account Services, Lucas Utouh, 9-30-21.
Oct. 11, 2022 Item #12 Page 451 of 560
413
Cities of Carlsbad and Encinitas adopted an ordinance to require solar on non-residential buildings.
While local jurisdictions have authority, statewide cost effectiveness studies are available, and examples
exist in the region, a solar requirement for new nonresidential buildings would be obsolete as soon as
the most recently approved codes are effective in January 2023 since solar and storage will be required
for new nonresidential buildings. However, there is an opportunity for local jurisdictions to adopt reach
codes that require solar on alteration and addition projects. Examples of these policies exist in the
region and around California. GHG reductions associated with these policies likely would be limited
given the number of affected projects, but more analysis would be needed to determine the full
potential of these policies.
Other Local Opportunities
Through the supply procurement authority of existing CCAs in the region, there is an opportunity to
explore options to decrease emissions from in-region and out-of-region thermal fossil fuel generation
that supply electricity to the San Diego region. This may include:
• Evaluating development and procurement of low-carbon or zero-carbon fuel alternatives —
such as hydrogen — to existing natural gas fired base generators and fast start generators that
both achieve GHG reduction objectives, decrease local criteria pollutants, and ensure system
and local reliability; and
• Evaluate carbon removal and storage options for existing in-region or contracted for out-of-
region natural gas generation where these facilities will be required to operate per federal and
state reliability standards.
For distributed energy resources, additional opportunities exist to expand upon state statutory
mandates for streamlined approval of small wind energy systems,i residential rooftop solar PV systems,ii
and advanced energy storage systems.iii There is opportunity to further streamline the application
approval process for larger wind energy systems, nonresidential and large residential solar PV systems,
and energy storage systems that are not covered by the current statutory language.
Potential for Regional Collaboration
In addition to the measures and policies local jurisdictions can adopt on their own, there are
opportunities for collaboration across jurisdictions and even regionally to increase use of carbon-free
electricity.
Develop CCA Customer Programs to Encourage Use and Generation of Clean Electricity
CCAs in California have developed programs to encourage participation in high renewable or carbon-
free electricity service options or installation of distributed solar projects.
• Net Energy Metering (NEM) – NEM allows customers to be compensated for electricity exported
to the electric grid on a monthly basis. The amount of electricity exported to and imported from
the grid is summed, and if a customer is a net importer, they are charged; if the customer is a
net exporter, they are paid the retail value of that amount. Because CCA programs set their own
electric rates, subject to state law and regulatory requirements, they can modify the terms of
certain aspects of NEM, including the crediting process and rate used to compensate net
exporters. Also, customers that are net exporters on an annual basis are eligible for net surplus
compensation, which uses a rate called the default load aggregation point (DLAP) price,
i See AB 45 (Blakeslee, Chapter 404, Statutes of 2009).
ii Government Code §§ 65850.5 & 65850.55.
iii Government Code § 65850.8.
Oct. 11, 2022 Item #12 Page 452 of 560
414
sometimes referred to as average wholesale rates.i This rate is much lower than the retail rate
used for calculating the value of net exported electricity each month. CCAs can also modify the
net surplus compensation rate. For example, Marin Clean Energy offers two times the DLAP
offered by the incumbent utility, Pacific Gas & Electric (PG&E).ii Note that the CPUC has an
ongoing rulemaking to change several aspects of NEM for residential customers that may affect
the cost effectiveness of installing distributed solar.iii
• Financial Incentives – CCAs in California offer financial incentives to encourage installation of
distributed solar and projects that include energy storage. For example, East Bay Community
Energy (ECBE) has a rebate program for solar projects energy storage to improve resilience,iv
and Marin Clean Energy provides MCE solar rebates for communities of concern.v
• Feed In Tariffs – In addition to programs to encourage customers to increase supply of
renewable electricity, CCAs also can develop programs to encourage development of renewable
electricity projects within its service. Some CCAs have Feed-In tariffs (FIT), which purchase
electricity from local projects for a fixed price over a fixed number of years. In January 2021, the
SDCP adopted a FIT and will be launching the program in 2022.vi Other CCAs have existing
programs. For example, Marin Clean Energy has two FIT programs. Projects that are up to 1 MW
are eligible for the FIT Program, while projects between 1 MW and 5 MW are eligible for the FIT
Plus Program.vii
Collect and Assess Data on Equity and other Indicators Related to Renewable Electricity
Similar to other policy categories, there is a general need to continue to develop capacity in the region
to collect, assess, and communicate data on equity and other energy-related indicators. Such data
would allow additional analysis in the region to assess the current impact of renewable electricity
policies in the region and to enable the process to develop policies and processes to address any
inequities found.
Regional Program to Support Reach Code Policy Development
Similar to the opportunity described in Section 8.6.6 above, a regional program could support
development and implementation of regional reach codes to encourage installation of distributed solar.
This program could leverage existing resources, including SDG&E Codes and Standards program and
Statewide Reach Code Program.viii The Clean Power Alliance, the Los Angeles region’s CCA, completed a
report on potential programs and identified a regional reach code program as one option. Based on the
report, such a program could: develop model ordinances to streamline the process for local jurisdictions,
provide funding to local governments for the development and adoption process of a building
electrification code, and make available technical assistance to municipalities that want to adopt a
i In D.11-06-016, the CPUC determined that the electricity portion of the net surplus compensation rate is the
simple rolling average of the default load aggregation point (DLAP) price from 7 a.m. to 5 p.m. that corresponds to
the customer's 12-month true-up period.
ii Marin Clean Energy. Solar Program webpage. Available at https://www.mcecleanenergy.org/solar-customers/.
iii California Public Utilities Commissions. Proposed Decision in Rulemaking 20-08-020 (Dec. 13. 2021).
iv East Bay Community Energy. Resilient Homes Program webpage. Available at https://ebce.org/resilient-home/.
v Marin Clean Energy. Solar Rebates and Discounts for MCE Customers webpage. Available at
https://www.mcecleanenergy.org/solar-rebates/.
vi San Diego Community Power. Community Advisory Committee Presentation, Special Meeting Dec. 9. 2021.
Available at https://sdcommunitypower.org/wp-content/uploads/2020/12/CAC-Presentation_v1.pdf.
vii Marin Clean Energy. Feed In Tariffs webpage. Available at https://www.mcecleanenergy.org/feed-in-tariff/.
viii Statewide Reach Codes Program, California Energy Codes and Standards – A Statewide Utility Program. Available
at https://localenergycodes.com/.
Oct. 11, 2022 Item #12 Page 453 of 560
415
distributed solar reach codes.i
One notable limitation to this approach for distributed solar is that statewide building energy codes
already require solar for certain low-rise residential new construction projects and will require new
nonresidential buildings to install solar and storage in the next triennial code update cycle.
8.8 Natural Climate Solutions
Natural and working lands are becoming a major focal point for state policy and local land use planning.
Existing efforts include quantifying the value of existing carbon stock and sequestration potential and
conserving and restoring existing natural and working lands. According to a recent study by the Institute
for Ecological Monitoring and Management at San Diego State University (IEMM), approximately 2.9
million acres of San Diego County’s more than 3.2 million acres of land, submerged land, and waters are
natural lands. Of these, the un-conserved portion is distributed throughout the region, representing a
significant opportunity to develop nature-based carbon sequestration strategies in CAPs across the
region. This will become more important if net zero GHG emissions, which will require carbon removal
and storage, is the regional target for GHG emissions.
8.8.1 Summary of Findings
Table 8.43 presents the key takeaways of the analysis for the Natural Climate Solutions Pathway.
Table 8.43 Key Takeaways for the Natural Climate Solutions
Policy Category Key Takeaways
Agriculture
Methane
Reduction
No CAP measures related to methane reduction; limited analysis completed, additional
research needed; State preemption may exist starting in 2024 depending on future CARB
regulation.
Carbon Stock
Preservation
Many adopted and pending CAPs have related measures, mostly to conserve and restore
habitat; low GHG contribution; opportunity to continue research on carbon storage
potential and regularly develop regional inventories of carbon stocks; Existing authority
allows conservation, preservation, and restoration of lands for this purpose.
Carbon
Removal
and Storage
Many adopted and pending CAP have related measures, mostly urban tree planting, the
only quantified measure from this pathway; low GHG contribution; opportunity exists to
develop a regional approach to urban tree planting, including equity considerations, and to
track carbon all removal activities regionwide; Existing authority allows conservation,
preservation, and restoration of lands for this purpose. State legislation will create removal
and storage projects with an opportunity to develop such projects in the San Diego Region.
Key Findings of Analysis
This is a summary of results of the review of authority to act, the review of CAPs, and the scenario
analysis that estimates the aggregated GHG impact of CAPs.
• Authority Exists Over Land Use and Land Preservation, But Ownership Issues Require
Cooperation Between Owners and Land Managers – Local jurisdictions exercise police power
over land use and zoning and delegated authority that allows for the preservation of land
through conservation and agricultural easements with regard to natural and working lands.
However, presently it is unclear to what extent local authority can be exercised over activities
i Clean Power Alliance. 2020 Local Programs for a Clean Energy Future. Available at
https://electricenergyonline.com/article/energy/category/ev-storage/143/849132/clean-power-alliance-approves-
new-five-year-clean-energy-programs-plan.html.
Oct. 11, 2022 Item #12 Page 454 of 560
416
on private natural and working land beyond land use designation with regards to GHG
regulation. The region is complicated because it is composed of federal, state, tribal, and
privately held land, submerged land, and waters. Various statutes and agencies regulate the
different land types, with none focused on GHG emissions or sequestration as it relates to land
use. State land use and regulating agencies also operate with a wide range of statutory
mandates. California statutes and executive orders require state land use agencies to account
for GHG emissions from natural and working lands as well as begin to assess and regulate
carbon removal and storage on these lands with significant targets in 2030. Local jurisdictions
act with authority to preserve land, set goals, evaluate how to quantify and implement carbon
storage requirements on existing land, and work with private owners, tribes, and state and
federal land managers to achieve state, regional, and local goals related to natural and working
lands. Developing local GHG targets and aligning with state goals, statutes, quantification
methods informed by San Diego specific carbon valuation science, and funding may provide a
path forward to achieve local natural and working land objectives.
• The Only Quantified CAP Measure Relevant to This Pathway is Urban Tree Planting – Based on
our review of CAPs, nearly all CAPs (15) have at least one measure related to urban tree
planting, though these measures contribute on average just over 1% of local GHG reductions in
CAPs. Based on our scenario analysis, the total GHG reduction expected from urban tree
planting measures, which assumes 7% tree cover in developed areas, would be 0.1 MMT CO2e in
2035. If the best adopted CAP commitment, which assumes 35% tree cover, were applied to all
jurisdictions in the region, the reduction would be 0.6 MMT CO2e.
Opportunities for Further Local Action
The following summarizes key opportunities for further action.
• Opportunities at Jurisdictional Level and Regional Collaboration in Identifying Suitable Tree
Planting Locations – Existing urban canopy cover varies by jurisdiction, ranging from 7% to 22%.
CAP urban tree planting targets do not specify suitable tree planting locations or where trees
are needed the most. Opportunities exist at the jurisdictional level to identify locations based on
local needs. The most aggressive CAP measure commits to 35% urban canopy cover in
developed areas. Not all developed areas in the region are suitable for tree planting. An
opportunity exists for cross-jurisdictional collaboration to identify suitable locations across the
region, including taking into account social equity considerations.
• Continue and Increase Land Conservation, Preservation, and Restoration Across the Region –
Existing authority allows land conservation, preservation, and restoration on natural and
working lands. There is an opportunity to increase existing efforts and to explore additional
actions to further conserve, preserve, and restore these lands.
• Collaboration with Tribes, State and Federal Land Agencies and Managers, and Private Land
Owners – It is necessary to evaluate the various mandates on these lands and waters to
determine where collaboration is viable to achieve local, regional, and state goals for natural
and working lands. Private land owners also serve as important partners to preserve land and to
test and fund pilot projects for carbon removal and storage.
• Continue to Develop and Integrate both State and Local Science for the Value and Integration of
Natural and Working Lands in CAPs and other Land Use Plans – CARB is currently developing
methods to quantify carbon values for these lands and demonstrate sequestration values. This
could be integrated with existing local science on San Diego region's natural and working land
carbon values from San Diego State University’s IEMM and other San Diego specific science.
Oct. 11, 2022 Item #12 Page 455 of 560
417
• Develop Land Use Specific Values for Land Conservation and Restoration, including Agricultural
Land – There are opportunities to conserve and preserve additional land across the region.
There are also some opportunities to restore land. The science behind the value of these actions
is developing and needs additional support. The region could identify lands that can be
conserved or preserved in support of existing and future land use planning. This process must
include all tribal, federal, private, and local government stakeholders. This process could also
account for the new SB 27 (2021) mandate that calls for the creation of natural and working
land carbon removal and storage projects. To the extent possible, the San Diego region could
develop and aid in creating these projects.
• Develop and Regularly Update a Regional Carbon Stock Inventory Based on San Diego Specific
Science – Similar to the CARB Inventory of Emissions from Natural and Work Lands, the San
Diego region could develop a process to regularly estimate and track over time the amount of
carbon stored vegetation, wetlands, etc. This would help to understand how carbon stocks are
being preserved and whether net emissions occurred due to changes in land use. These
emissions are not typically included in the communitywide GHG inventory of local jurisdictions,
but tracking changes over time can help understand the region’s net impact on emissions, which
can imply contribution to warming. A similar process could be developed to track carbon
removal projects regionwide.
8.8.2 Summary of Authority in the Natural Climate Solutions Pathway
The San Diego region is composed of federal, tribal, state, local, and privately held land. The following
will discuss authority over this land, submerged land, water, and coast (land(s)). Authority over the
land(s) directly determines its uses, potentially limiting whether the use can support GHG reductions,
removal, and/or storage. The following will summarize opportunities to engage with federal, tribal, the
State of California, and local authorities regarding natural and working lands. It concludes with an
analysis of agricultural land. Additional research is required to further vet this pathway. Additional
information on all topics presented here can be found in Appendix B.
Local Authority Over Natural and Working Lands
Cities and counties often use planning and land use control authorities to protect or regulate natural and
working lands. In this regard, the full extent of this authority requires further research and development
to determine what is feasible at the local level to regulate, preserve, and augment natural and working
lands for GHG regulations and any removal or storage activities in the region. Additionally, local
jurisdictions act with authority to lobby Congress and the California Legislature, and negotiate with
federal, tribal, and state agencies and lands managers to further these aims. Local jurisdictions may act
with existing authority to create pilots or programs in this regard. Local jurisdictions also act with
existing authority to fund local science to accurately identify and quantify local natural and working
lands carbon stock and sequestration potential to inform local decisions and investment. Further
research would be needed to develop and vet these and other actions on natural and working lands.
Known local government authorities and actions that can be used to regulate and protect natural and
working lands include general plans, specific plans, climate action plans, local coastal plans (LCPs),
zoning, special use permits, subdivision maps, and development agreements. Policies that support
easements (e.g., conservationi — including California Forest Legacy Program Act easementsii — and
i Civil Code §§ 815.1, 815.3, 815.2(a)-(b).
ii Public Resources Code § 12200 et seq.
Oct. 11, 2022 Item #12 Page 456 of 560
418
open-spacei), as well as incentives largely based on easements to preserve land. Local jurisdictions can
also apply for state programs — like the Urban & Community Forestry Program under the Urban
Forestry Actii to support local urban forestry — efforts that are included in general plans or climate
action plans.
Federal Natural and Working Lands
The primary actions local jurisdictions may take related to federal lands is through lobbying Congress,
engaging with federal lands management agencies to create government to government agreements
(e.g., a memorandum of understanding (MOU)), and working directly with federal lands managers to
achieve local objectives across the region.
One such example includes evaluation opportunities from the Energy Act of 2020 that established a
research, development, and demonstration program to test, validate, or improve technologies and
strategies to remove carbon dioxide from the atmosphere on a large scale through activities that
include:
• Direct air capture and storage technologies;
• Bioenergy with carbon capture and storage technologies;
• Enhanced geological weathering;
• Agricultural practices;
• Forest management and afforestation; and
• Planned or managed carbon sinks, including natural and artificial.iii
There is opportunity at the state and local level to develop and demonstrate or benefit from projects
funded by this legislation. Further efforts could be made to investigate this opportunity, particularly with
regard to federal land in the region.
For the four main federal land managers (excluding the Department of Defense), opportunities to
coordinate with local governments or the State of California based on federal land and resources in the
San Diego region:
• National Parks Service (NPS): The NPS’s discretion in achieving its mission suggests that partnering
with local jurisdictions to decrease carbon emissions related to the Cabrillo Monument and increase
natural land carbon removal may be feasible. Any action would need to be consistent with the
purpose of creating the Cabrillo National Monument.iv It may also be possible to preserve land
through the creation of a national park or additional monument in the San Diego region.
• Fish and Wildlife Service (FWS): There is some level of discretion afforded to FWS officials with
regards to uses that should be further analyzed. Opportunities may include increasing the size of
existing refuge and working with FWS officials to exercise their discretion in a way that benefits
regional decarbonization goals.
• Bureau of Land Management (BLM): BLM land managers act with broad discretion to plan and
manage land and resources. Local BLM managers act with different authorities when compared to
U.S. Forest Service officials, who must change already established localized plans developed in
i Government Code § 51070 (The Open-Space Easement Act of 1974).
ii Public Utilities Code § 4799.06–4799.12.
iii 47 H.R. 133 — 116th Congress (2019-2020): Consolidated Appropriation Act, 2021. December 27, 2020 (Public
Law No: 116-260), Division Z (Energy Act of 2020), Title V: https://www.congress.gov/bill/116th-congress/house-
bill/133/text.
iv See United States v. City & County of Denver, 656 P.2d 1 (Colo. 1982).
Oct. 11, 2022 Item #12 Page 457 of 560
419
compliance with existing broad agency rules that limit discretion. This may provide an opportunity
for local jurisdictions to work directly with local BLM land managers on decarbonization efforts in
the San Diego region.
• The U.S. Forest Service (U.S.F.S.): Because there are localized planning requirements and less
manager discretion, there is less flexibility with National Forest land than BLM land without
amending or creating a new local plan under the NFMA. However, inclusion of decarbonization
actions in U.S.F.S. authority to issue broad rules of applicability to manage forest land does create an
opportunity for local jurisdictions to engage in the U.S.F.S. regulatory process that affects local
planning in addition to advocating for changes to existing local plans, such as the Cleveland National
Forest Land Management Plan.
Tribal Authority Over Natural and Working Lands
States and local governments generally act with limited to no authority over tribal land use and activity.
Cooperative intergovernmental policies and agreements that support tribal land preservation, land
conservation, and decarbonization efforts through mechanisms that include the fee-to-trust process
appear to be existing paths to work with tribes in achieving regional decarbonization goals.
State of California Authority Over Natural and Working Lands
California actively manages natural and working lands through various agencies with a wide range of
authority and missions. State authority and specific agency authority to preempt local police power over
zoning is narrow and limitedi to specific statewide objects, that include housing requirements but not
where the units should be zoned,ii and specific areas like the coastal zone or under the Subdivision Map
Act.iii, iv State preemption over charter city municipal affairs is expressly limited by California
Constitution Article XI, §§ 3 and 5. Additionally, CEQA applies to a broad range of projects, as defined, on
natural and working lands and is a major consideration when analyzing land and resource uses. The
California Endangered Species Act may also affect use of habitat and would need to be specifically
analyzed.v
State policy continues to increase focus on natural and working lands that may inform and support local
action or create the opportunity to align with state action. The following summarizes some of these
state policies:
• SB 1386 (Wolk, Chapter 545, Statutes of 2016) established protecting and managing natural and
working lands as state policy to help achieve California’s GHG reduction goals, including the
intent to promote cooperation of owners of natural and working lands.
• Executive Order B-55-18’s 18’s goal to achieve carbon neutrality by 2045 incorporates working
lands, including agriculture, in the CARB’s 2022 AB 32 Scoping Plan update that is currently
under development and expected to be approved by the end of 2022.
• Executive Order N-82-20’s addresses biodiversity, 30% land and coastal water conservation,
acceleration of natural carbon sequestration and climate resiliency on natural and working
lands, and creation of the Natural and Working Lands Climate Smart Strategy, including setting a
statewide target to meet the 2045 carbon neutrality goal.
i See Government Code § 65000 et seq.; See Scrutton v. County of Sacramento, 275 Cal. App. 2d 412, 417 (1978).
ii See Government Code §§ 65913.1(a), 65863.5, 65583(a)(3), 65584, & 65584.01.
iii Government Code §§ 66410 et seq.
iv See Government Code §§ 66411, 66421, 66477, 66478, 66479, 66483, & 66484; see also Friends of Lake
Arrowhead v. Board of Supervisors, 38 Cal. App. 3d 497, 505, (1974).
v Fish & Game Code § 2050 et seq.
Oct. 11, 2022 Item #12 Page 458 of 560
420
• SB 27 (Skinner, Chapter 237, Statutes of 2021) established a Natural and Working Land Climate
Smart Strategy that includes developing a framework to achieve California’s climate goals and
mandates CARB to set CO2 removal targets for 2030 and beyond under its Scoping Plan for all
emission sectors including those in this framework. It also requires the Natural Resources
Agency to create a carbon removal and sequestration registry to identify, list, fund projects by
state agencies and private entities, and retire projects in the state that drive climate action on
the state’s natural and working lands.
• SB 859 (Committee on Budget and Fiscal Review, Chapter 368, Statutes of 2016) Natural and
Working Land Inventory quantitatively estimated the existing state of ecosystem carbon stored
in the State's land base and excluded GHG emissions associated with direct human activity
quantified in CARB’s annual statewide GHG inventory.i
• The Natural and Working Lands Climate Change Implementation Plan set targets out to 2030
and pathways to at least double the pace and scale of state-funded restoration and
management activities, including: 1) increasing the acreage in soil conservation practices for
cultivated land and rangelands by five times to change agricultural land from a net emitter to a
sink by 2030; 2) doubling the pace and scale of forest managed or restored; 3) tripling the pace
of restoration of oak savannas and riparian areas; and 4) and doubling the rate of wetland
seagrass restoration.ii
• 2022 Draft AB 32 Scoping Plan seeks to mitigate the expected increase in emissions from Natural
and Working Lands through active management relevant to San Diego that includes: 1) a ten
times increase in management of forest, shrubland, and grassland; 2) increase investment in
urban trees by at least 20%; 3) restore 60,000 acres or 15% of Sacramento-San Joaquin Delta
wetlands; and 4) decrease conversion of deserts and sparsely vegetated landscapes by at least
50% annually.iii
Agriculture
Local jurisdiction's authority over agricultural land stems from police power over land use and zoning.
Agriculture emissions or GHG mitigation actions also may be part of a local jurisdiction's climate action
plan. It is unclear how and to what extent a local jurisdiction may use its police power to regulate
agriculture activities that cause GHG emissions directly. Some potential opportunities are dependent on
whether and how CARB regulates certain activities.
Federal authority over agriculture land use and practices is limited with certain land use requirements
for leased federal land for farming or animal production but no specific regulation of GHG emissions. As
previously stated, the Energy Act of 2020 established a research, development, and demonstration
program to test, validate, or improve technologies and strategies to remove carbon dioxide from the
atmosphere on a large scale through activities that include Agricultural practices. iv
State policy continues to increase focus on agricultural lands that may inform and support local action or
i See CARB California Natural and Working Land Inventory (2018), p. 7 & 15: https://ww2.arb.ca.gov/nwl-inventory.
ii See January 2019 Draft California 2030 Natural and Working Lands Climate Change Implementation Plan
(Updated January 2019), p. 13–14: https://ww2.arb.ca.gov/sites/default/files/2020-10/draft-nwl-ip-040419.pdf.
iii CARB Draft 2022 Scoping Plan Update, May 10, 2022, p, 201: https://ww2.arb.ca.gov/sites/default/files/2022-
05/2022-draft-sp.pdf.
iv 47 H.R. 133 — 116th Congress (2019-2020): Consolidated Appropriation Act, 2021. December 27, 2020 (Public
Law No: 116-260), Division Z (Energy Act of 2020), Title V: https://www.congress.gov/bill/116th-congress/house-
bill/133/text.
Oct. 11, 2022 Item #12 Page 459 of 560
421
create the opportunity to align with state policy and funding. Beyond SB 1386 (2016) establishing
protecting and managing natural and working lands as state policy, SB 1383 (2016) mandated that CARB
achieve a 40% reduction in methane emissions below 2014 levels by 2030, including reducing emissions
from livestock manure management operations and dairy manure management operations the creation
and implementation of a Short-Lived Climate Pollutant Strategy. SB 1383 (2016) sets the date of on or
after January 1, 2024, as the effective date to implement regulation of these emissions with ongoing
investments and incentives to achieve the reductions. SB 1383 (2016) also limits regulation of enteric
fermentation to incentive-based mechanisms until CARB and the Department of Food and Agriculture
determine that a cost-effective and scientifically proven method of reducing enteric emissions is
available, adoption of which would not damage animal health, public health, or consumer acceptance. It
remains unclear whether CARB will enact regulations in 2024 to achieve these reductions. CARB
regulation will likely preempt local authority action, but the current state offers an opportunity for local
regulation unless, and until, CARB acts.
AB 32 (2006) and SB 32 (2016) authorized programs do not directly regulate agricultural land use, onsite
agriculture GHG emission (excluding off-road emissionsi), require carbon sequestration, or require
carbon removal on working agricultural lands. However, Executive Orders B-55-18, N-82-20 require
agricultural land to meet the 2045 carbon neutrality goal. SB 27’s (2021) Natural and Working Land
Climate Smart, CO2 removal targets for 2030 and beyond under the Scoping Plan for all emission sectors,
including agriculture, and creation of a carbon registry for carbon removal and sequestration will drive
climate action on agricultural land.
These efforts will further support existing agriculture preservation statutes in the coastal zone,ii the
long-term productivity of soil,iii and under the Williamson Act (California’s primary agricultural
preservation statute).iv It will also likely affect CEQA analysis on land conversion and agricultural land
preservation mitigation.
Finally, the April 2019 CARB NWL Implementation Plan, informed by SB 859’s (2016) Natural and
Working Land Inventory’s quantitative estimate of the existing state of ecosystem carbon stored in the
State's land base (excluding GHG emissions associated from direct human activity quantified in CARB’s
annual statewide GHG inventory),v sets targets out to 2030 and pathways to scale needed
implementation. Specific to agriculture, these include increasing the acreage in soil conservation
practices for cultivated land and rangelands by five times to change agricultural land from a net emitter
to a sink by 2030.vi The NWL Implementation Plan also calls for increases in compost application,
agroforestry, grazing land and grassland management, and cropland management to decrease emissions
i See CARB Funding Agricultural Replacement Measures for Emission Reductions: https://ww2.arb.ca.gov/our-
work/programs/farmer-program.
ii See Public Resources Code §§ 30000 et seq. (Coastal Act) & §§ 31000 et seq. (State Coastal Conservancy); Public
Resources Code §§ 31050, 31051, 30241, 30114, 30243, 30108.6, 30500(c), 30200(a), 30514, 30241.5, 30241,
30250, 30610.1, 30242, 31054, 31104.1, 31150, 31151, 31152, 31156.
iii Public Resources Code § 30243.
iv Government Code § 51201(c); See Government Code § 51200 et seq.
v See CARB California Natural and Working Land Inventory (2018), p. 7 & 15: https://ww2.arb.ca.gov/nwl-
inventory.
vi See January 2019 Draft California 2030 Natural and Working Lands Climate Change Implementation Plan
(Updated January 2019), p. 13: https://ww2.arb.ca.gov/sites/default/files/2020-10/draft-nwl-ip-040419.pdf.
Oct. 11, 2022 Item #12 Page 460 of 560
422
and increase carbon sequestration.i The 2022 Draft AB 32 Scoping Plan calls for a five times increase in
healthy soil practices and organic agriculture, the reduction of pesticide use, changes in pest
management practices, decreases of agricultural burning through increase carbon storage practices, and
changes to onsite energy use that reduce GHG emissions from agricultural operations.ii
8.8.3 GHG Impacts of CAP Measures in the Natural Climate Solutions Pathway
Natural Climate Solutions is different from the other decarbonization pathways. The other pathways
focus on reducing GHG emissions. This pathway focuses on carbon removal and storage. We make a
distinction between carbon removal and storage — sometimes referred to as sequestration — and
preserving existing stocks of carbon. For example, the GHG impacts of carbon removal and storage
measures are due to physically removing carbon dioxide from the atmosphere through activities like
urban tree planting and carbon farming. Such activities increase removal capacity (e.g., planting new
trees) or enhance the amount of existing capacity (e.g., increasing the capacity of existing vegetation to
remove carbon). On the other hand, preserving existing carbon stocks seeks to conserve the existing
capacity of natural systems to store carbon. In this case, GHG impacts are associated with avoiding the
conversion of existing land. For example, creating easements prevent development of existing land
prevents potential emissions from disturbing natural vegetation and soil. Note that emissions associated
with avoided development (e.g., reduction in VMT) are addressed in the Decarbonizing Transportation
Section (Section 8.5). Table 8.44 summarizes the policy categories and subcategories used to analyze
this decarbonization pathway. In the context of this decarbonization pathway, methane reduction refers
to emissions related to agriculture, mainly from livestock. Because there are no related CAP measures,
we do not discuss this policy category further in this chapter.
Table 8.44 Policy Categories Included in the Natural Climate Solutions Pathway
Policy Category Policy Subcategory
Carbon Removal
and Storage
Urban Tree Planting
Conservation & Restoration Projects (Removal)
Urban Gardens
Carbon-Farming Practices (Removal)
Turf Management
Preservation of
Carbon Stocks
Agriculture Easements
Open Space Easements
Wildfire Prevention
Carbon-Farming Practices (Preservation)
Conservation & Restoration Projects (Preservation)
Agriculture Methane Reduction TBD
i See January 2019 Draft California 2030 Natural and Working Lands Climate Change Implementation Plan (Updated
January 2019), p. 17: https://ww2.arb.ca.gov/sites/default/files/2020-10/draft-nwl-ip-040419.pdf. ii CARB Draft 2022 Scoping Plan Update, May 10, 2022, p. 208: https://ww2.arb.ca.gov/sites/default/files/2022-
05/2022-draft-sp.pdf.
Oct. 11, 2022 Item #12 Page 461 of 560
423
Review of Adopted and Pending CAP Measures
For this analysis, we compare GHG impacts across CAPs. Based on the review of CAPs, measures in the
Natural Climate Solutions pathway account for between 0% and 5% of local reductions, with an average
across all CAPs of about 1% (Figure 8.48).
Figure 8.48 Contribution of Natural Climate Solutions Measures in Adopted and Pending CAPs.
Based on the review of CAPs, nearly all adopted or pending CAPs include at least one measure related to
carbon removal and storage, but only one has measures related to preserving carbon stocks (Figure
8.49). The estimated GHG impact of these measures in CAPs is minimal. Carbon removal and storage
measures contributed on average just over 1% to local GHG reductions, while preserving carbon stocks
contributes less than 1%. No CAP had measures related to agriculture methane reductions.
Figure 8.49 Number of Jurisdictions with Related CAP Measures and Associated GHG Impacts
Scenario Analysis of GHG Impacts from Adopted CAP Measures
In contrast to the review of CAPs, which considers measures in all emissions categories and does not
consider the combined impact of measures, the scenario analysis only evaluates emissions from on-road
transportation, electricity, and natural gas and estimates the GHG impact of all related CAP measures.
To assess the combined impact of all adopted CAPs in the region, we summed the activity level in CAP
measures and recalculated a regional GHG impact value. For purposes of showing the GHG impact of
policies related to this pathway, we only looked at those related to urban tree planting under the carbon
Oct. 11, 2022 Item #12 Page 462 of 560
424
removal and storage category because all quantified CAP measures focus on this subcategory. The
carbon sequestered would be 0.1 MMT CO2e in 2035. CAP urban tree planting measures include: (1)
municipal (e.g., public right-of-way, parks) tree planting targets; (2) urban canopy target for developed
area in the jurisdiction; and (3) tree planting targets for new residential and commercial developments
(e.g., number of new trees per dwelling unit, number of new trees per surface parking spaces).
Figure 8.50 shows the impact of these measures (green wedge) on regional emissions. The upper and
bottom dashed line represents the full impact of all four decarbonization pathways discussed in this
document.
Figure 8.50 San Diego Emissions in Four Decarbonization Pathways with Adopted CAP Commitments.
A 2015/2016 LiDAR assessment shows existing tree canopy cover at approximately 13% across all
jurisdictions in the region, ranging from 7% to 22%.i With the existing CAP commitment, the region
would have an additional 7% urban canopy cover.
GHG Impact from Best Adopted CAP Commitments Applied Regionwide
If the best adopted CAP commitment related to urban tree planting is applied to all local jurisdictions in
the San Diego region, the carbon sequestration would be about 0.6 MMT CO2e in 2035, as shown in
Figure 8.51.
The best adopted CAP commitment assumes 35% canopy cover of approximately 1 million acres of
developed area in the San Diego region. With the best adopted CAP commitment, the region would
have additional 21% urban canopy cover, more than the adopted CAP commitment (7%). While it is not
clear whether it would be possible to achieve this level of urban canopy cover across the region, this
value represents an upper limit of what can be expected from adopted CAP measures.
i San Diego Tree Canopy Assessment. https://perma.cc/4MNP-JGM6.
Oct. 11, 2022 Item #12 Page 463 of 560
425
Figure 8.51 San Diego Emissions in Four Decarbonization Pathways with Adopted CAP Commitments.
8.8.4 Carbon Removal and Storage
CAP Measure Related to Carbon Removal and Storage
Figure 8.52 summarizes the number of CAPs with at least one measure related to carbon removal and
storage. More CAPs have measures related to urban tree planting than any other policy subcategory
analyzed here. Twelve of the 17 adopted and pending CAPs assessed have a requirement to plant urban
trees. Urban forestry measures are the predominant driver of carbon sequestration related GHG
reductions in local CAPs, and for the few jurisdictions that do include measures and/or actions that
relate to the other policy categories, they are generally not quantified.
Figure 8.52 Number of Adopted and Pending CAPs with Measures Related to Carbon Removal and Storage
Urban Tree Planting
Table 8.46 provides examples of the types of CAP measures related to urban tree planting in each of the
implementation mechanisms.
Oct. 11, 2022 Item #12 Page 464 of 560
426
Table 8.46 Examples of General CAP Policies Related to Urban Tree Planting
Implementation Mechanism General Policy
Capital Improvement & Infrastructure • Plant street trees
• Include trees in capital improvement projects
• Hire an urban forest program manager
• Manage health of urban forest and other open spaces
Education, Outreach, &
Coordination • Pursue partnerships and grant funding opportunities
• Develop partnerships with neighborhood groups, CBOs, and other
stakeholders
• Develop regional partnerships to establish a regional urban forest strategy
• Provide educational materials to residential and nonresidential property
owners
• Establish public-private partnerships for volunteer efforts
Evaluation • Conduct a street tree inventory
• Develop a regional urban tree canopy assessment
• Track trees planted annually
Incentives • Provide streamlined review for projects with additional trees
• Provide incentives that increase tree plantings
• Give away seedlings during special events
Plan or Program • Develop an Urban Forestry Master Plan or similar
• Develop/expand an urban forestry program
• Hire an urban forest program manager
Requirement(s) • Require tree planting in new and redeveloped residential and/or
nonresidential properties
• Require shade trees in parking lots
• Require tree planting at new and redeveloped sites when mature trees are
removed
Urban Gardens
Table 8.46 provides examples of the types of CAP measures related to urban gardens in each of the
implementation mechanisms.
Table 8.46 Examples of General CAP Policies Related to Urban Gardens.
Implementation Mechanism General Policy
Capital Improvement &
Infrastructure
NA
Education, Outreach, &
Coordination
• Encourage and promote urban agriculture including community gardens
Evaluation • Evaluate sites for feasibility of future community gardens
• Assess equity in access to community gardens
Incentives • Reduce property taxes for landowners who convert certain properties to
agricultural uses (Urban Agriculture Incentive Zone Ordinance)
• Provide incentives to multi-family developments with community gardens
• Provide incentives to businesses participating or sponsoring community
gardens
Plan or Program • Update land use plans to permit community gardens in certain zones
• Create a Community Garden Program or similar
Requirement(s) NA
Oct. 11, 2022 Item #12 Page 465 of 560
427
Carbon-Farming Practices (Removal and Storage)
Table 8.47 provides examples of the types of CAP measures related to carbon farming in each of the
implementation mechanisms.
Table 8.47 Examples of General CAP Policies Related to Carbon Farming
Implementation Mechanism General Policy
Capital Improvement & Infrastructure NA
Education, Outreach, & Coordination • Develop partnerships with agriculture-based businesses
• Promote existing incentives and programs
• Promote best-practices in carbon farming
Evaluation NA
Incentives • Provide incentives to establish demonstration carbon farms
Plan or Program • Develop a carbon farming program
Requirement(s) NA
Turf Management
Only three CAPs have measures related to turf management, which all use capital improvement and
infrastructure as the implementation mechanism. These CAPs include measures that use top-dressing of
compost at City parks.
Conservation and Restoration Projects (Removal and Storage aspects)
Only two CAPs have measures related to conservation and restoration projects, which use evaluation as
the implementation mechanism. These CAPs include measures to identify opportunities to enhance and
conserve habitat and to research and monitor Blue Carbon opportunities.
8.8.5 Preservation of Carbon Stocks
CAP Measure Related to Preservation of Carbon Stocks
Figure 8.53 summarizes the number of CAPs with at least one measure related to the preservation of
carbon stocks. Only one adopted or pending CAP includes measures related to the preservation of
carbon stocks. This reference is through agricultural and open space easements and consists of actions
that call for the development of a plan or program and education and outreach efforts. Examples of
education and outreach include working with regional partners to identify funding sources for
agricultural land protection (e.g., acquisition and management). Examples of plans or programs include
developing conservation. No CAPs have measures related to the other policy subcategories listed.
Figure 8.53 Number of Adopted and Pending CAPs with Measures Related to Preservation of Carbon Stocks
Agriculture and Open Space Easements
Several adopted or pending CAPs have measures related to agricultural and open space easements.
Those that do have use plan or program and education outreach and Coordination as implementation
Oct. 11, 2022 Item #12 Page 466 of 560
428
mechanisms. Examples of education and outreach include working with regional partners to identify
funding sources for agricultural land protection (e.g., acquisition and management). Examples of plans
or programs include developing conservation.
Other Policy Subcategories
No relevant measures or actions are currently included in inactive and pending CAPs for the following
policy subcategories: wildfire prevention; carbon-farming practices (storage).
8.8.6 Opportunities for Further Action
The following summarizes key opportunities for further action.
• Opportunities at Jurisdictional Level and Regional Collaboration in Identifying Suitable Tree
Planting Locations – Existing urban canopy cover varies by jurisdiction, ranging from 7% to 22%.
CAP urban tree planting targets do not specify suitable tree planting locations or where trees
are needed the most. Opportunities exist at the jurisdictional level to identify locations based on
local needs. The most aggressive CAP measure commits to 35% urban canopy cover in the
developed area. Not all developed areas in the region are suitable for tree planting. An
opportunity exists for cross-jurisdictional collaboration to identify suitable locations across the
region, including taking into account social equity considerations.
• Continue and Increase Land Conservation, Preservation, and Restoration Across the Region –
Existing authority allows land conservation, preservation, and restoration on natural and
working lands. There is an opportunity to increase existing efforts and to explore additional
actions to further conserve, preserve, and restore these lands.
• Collaboration with Tribes, State and Federal Land Agencies and Managers, and Private
Landowners – It is necessary to evaluate the various mandates on these lands and waters to
determine where collaboration is viable to achieve local, regional, and state goals for natural
and working lands. Private landowners also serve as important partners to preserve land and to
test and fund pilot projects for carbon removal and storage.
• Continue to Develop and Integrate both State and Local Science for the Value and Integration of
Natural and Working Lands in CAPs and other Land Use Plans – CARB is currently developing
methods to quantify carbon values for these lands and demonstrate sequestration values. This
could be integrated with existing local science on San Diego region's natural and working land
carbon values from San Diego State University’s IEMM and other San Diego specific science.
• Identify Land for Conservation and Restoration, including Agricultural Land – There are
opportunities to conserve and preserve additional land across the region. There are also some
opportunities to restore land. The science behind the value of these actions is developing and
needs additional support. The region could identify lands that can be conserved or preserved in
support of existing and future land use planning. This process could include all tribal, federal,
private, and local government stakeholders. This process could also account for the new SB 27
(2021) mandate that calls for the creation of natural and working land carbon removal and
storage projects. To the extent possible, the San Diego region could develop and aid in creating
these projects.
• Develop and Regularly Update a Regional Carbon Stock Inventory Based on San Diego Specific
Science – Similar to the CARB Inventory of Emissions from Natural and Work Lands, the San
Diego region could develop a process to regularly estimate and track over time the amount of
carbon stored vegetation, wetlands, etc. This would help to understand how carbon stocks are
being preserved and whether net emissions occurred due to changes in land use. These
emissions are not typically included in the communitywide GHG inventory of local jurisdictions,
Oct. 11, 2022 Item #12 Page 467 of 560
429
but tracking changes over time can help understand the region’s net impact on emissions, which
can imply contribution to warming. A similar process could be developed to track carbon
removal projects regionwide. Several studies related to carbon stocks have been completed in
the San Diego region, including those in Chapter 5 of this report, an estimate by the SANDAG
using the TerraCount analysis tool, and recent research by SDSU developed regionally-relevant
sequestration rates for all relevant habitats.i
8.9 Other Limitations
There are inherent limitations with any analysis like this that result in a degree of uncertainty. This CAP
policy opportunity analysis uses the best information, data, and methods available at the time.
Nonetheless, in addition to the limitations presented above in Sections 8.5 through 8.8, there are
limitations to the work completed to identify opportunities for each decarbonization pathway.
No Comprehensive Review of Implementation Progress
While implementation is a critical step of the climate action planning cycle, the analysis presented here
focuses on measures and supporting actions included in CAPs and some of the policies that have been
adopted as a result of these measures. We assume that CAPs represent what local jurisdictions and their
elected officials have determined to be a reasonable and feasible commitment to reduce GHG
emissions. While we reference some policies adopted by local jurisdictions related to the four
decarbonization pathways throughout the report, additional research would be needed to determine
whether and to what extent measures have been implemented by local jurisdictions. Such an analysis
likely would require close collaboration with local jurisdictions since much of the data and knowledge
about implementation activities may not be publicly available.
Also, the SANDAG RECAP Technical Appendix VI presents a framework to monitor progress.ii It
comprises two main parts: conducting GHG inventories to determine progress toward GHG emissions
targets and evaluating progress on implementing CAP measures. While it is possible to estimate the
amount of emissions associated with completed CAP activities in some cases, it can be difficult to
attribute the emissions reductions to local jurisdiction's actions. For example, while it is relatively easy
to track the miles of bike lanes installed, it can be difficult to attribute the amount of VMT reduced due
to installing a mile of bike lanes. Similarly, it is difficult to attribute an increase in energy efficiency or
rooftop solar to specific actions taken by local jurisdictions. Also, the SANDAG Climate Action Data Portal
tracks the level of activity in a range of indicators related to CAP measures.iii
No Further Evaluation of Policy Opportunities Completed
The goal of this analysis was to identify local policy opportunities to help achieve deep decarbonization
targets. As such, we did not provide detailed analysis of or prioritize the policies we identified.
Additional work would be needed to evaluate policy options based on selection criteria, including cost,
potential to reduce GHG emissions, feasibility to implement, scalability, social equity implications, etc.
i Megan Jennings, et al., 2021. Carbon Valuation for San Diego’s Natural Landscapes. Institute for Ecological
Monitoring and Management, San Diego State University.
ii SANDAG Regional Climate Action Planning Framework: TECHNICAL APPENDIX VI-CAP Monitoring and Reporting,
VERSION 1.1: December 2020.
iii ReCAP Snapshots and Climate Data Portal available at https://climatedata.sandag.org/.
Oct. 11, 2022 Item #12 Page 468 of 560
430
Limited Analysis of Certain Policy Categories and Subcategories
There are several policy categories or subcategories that we did not analyze to the degree of others. For
example, because there are no CAP measures related to increasing use of low-carbon fuels in building or
reducing methane from agricultural operations, including dairy operations, we included only limited
information. To the extent that stakeholders and decision makers want to learn more about these areas,
additional work would be needed.
No Analysis of Other Public Agency GHG Reduction Plans
This analysis focuses on the GHG reduction commitments in the CAPs of local jurisdictions. It does not
include analysis of plans adopted by other agencies like the San Diego Unified Port District and San
Diego International Airport. Additional analysis would be needed to determine the GHG commitments,
implementation plans, and relationship to local jurisdiction CAPs.
Not All GHG Emissions Categories Included in Analysis
The RDF Technical Report focused on emissions from energy systems — including buildings, electricity
generation, and transportation fuels — and land use and natural climate solutions. While these
emissions comprise the vast majority of emissions, there are other sources of emissions, including solid
waste and industrial gases, that are not addressed in this report. Future analysis could supplement this
report with policy options for emissions and policy categories not included here.
8.10 Conclusion
This chapter assesses current commitments in CAPs to determine if additional activity would be needed
to put the region on a trajectory to meet these goals and to identify opportunities for local jurisdictions
in the region to take further action to support the decarbonization pathways.
We completed analysis in three areas. First, we reviewed the authority of local governments and
agencies to act to influence and regulate GHG emissions, including a summary of key federal, state, and
local agencies, and key legislation and regulation at the federal and state levels to help to clarify the
ability of local governments to act to reduce GHG emissions. Second, we completed a review of CAPs to
determine the frequency of measures, relative GHG impact of decarbonization pathways and measures,
and integration of social equity considerations. Third, we completed a scenario analysis to estimate the
total impact of the GHG reduction commitments in all adopted and pending CAPs and the potential GHG
impact of a scenario of applying the best adopted CAP commitments to all jurisdictions. Using results of
the above analysis and additional research, identify opportunities for further local action and regional
collaboration in each of the four decarbonization pathways.
The review of authority found that local jurisdictions have authority to influence and regulate GHG
emissions using police powers and delegated authority. Some local jurisdictions are exercising delegated
authority, but the full extent of a local jurisdiction’s police power to regulate GHG emissions is unknown.
The review of CAPs and scenario analyses found that the GHG impacts of adopted CAP commitments are
relatively small, and applying the best adopted CAP commitments to all jurisdictions in the region would
still not be enough to reach the levels of deep decarbonization contemplated in the technical analysis
presented in the other chapters of this report. As a result, additional policies would be needed to
decarbonize transportation and buildings, particularly VMT reductions and building electrification,
respectively. Across all decarbonization pathways, there are opportunities for further local action and
for regional collaboration, including collecting and tracking data, providing support to develop and
Oct. 11, 2022 Item #12 Page 469 of 560
431
implement policies, and convening stakeholder and working groups to develop regional strategies and
monitor progress. Finally, based on a preliminary review of CAPs, additional work would be needed to
integrate social equity considerations into climate.
Oct. 11, 2022 Item #12 Page 470 of 560
432
Appendix 8.A Assumptions for Estimating GHG Impact of Best CAP Commitment
Table A.1 Best Adopted CAP Commitment Applied Regionwide – Decarbonize Transportation Pathway
Decarbonization
Pathway
Policy
Category
Policy
Subcategory
Best Adopted CAP Commitment Applied Regionwide
CAP Measure and Assumptions Application to the Region for Year 2035
Decarbonize
Transportation
VMT
Reductions
Increase
Commute by
Bicycling
Additional 4 miles of bike lane per square mile =
additional 4% commute by bicycling (Imperial Beach
CAP Measure T.4: Improve Pedestrian and Bicycle
Facilities)
Additional 76,859 commuters by bicycling (4% of
total regionwide jobs)
One-way commute distance by bicycling: 5 miles
Increase
Commute by
Walking
Additional 10% commute by walking (Imperial Beach
CAP Measure T.4 Improve Pedestrian and Bicycle
Facilities)
Additional 192,147 commuters by walking (10% of
total regionwide jobs)
One-way commute distance by walking: 1 mile
Increase Safe
Routes to School
Additional 9% students walk to school and 0.5%
students ride bicycles to school (Escondido CAP
Measure T-3.3 Implement Safe Routes to School at
Escondido Union School District & Lemon Grove
Measure T-9: Implement the Safe Routes to School
Program)
Additional 172,933 students work to school (9% of
regional 5-14 population) and 9,607 students ride
bicycles to school (0.5% of regional 5-14
population)
One-way walk to school distance: 0.5 mile
One-way ride bicycle to school distance: 1.25 mile
Complete Street
0.13% VMT reduction from implementing multi-
modal enhancements as part of a “Complete
Streets” approach (County of San Diego CAP:
Measure T-2.1: Improve Roadway Segments as
Multi-Modal)
Equivalent to 0.13% VMT reduction in regional LDV
VMT
Increase
Commute by
Mass Transit +
Intra-city Shuttle
Additional 13% commute by mass transit (San
Marcos CAP Measure T-11: Increase Transit
Ridership)
Mass transit: additional 249,792 commuters by
walking (13% of total regionwide jobs)
One-way commute distance by mass transit: 10.4
miles
Intra-city Shuttle: Adopted CAP commitment carry
over
Parking
Reduction
50% reduction in residential parking space
requirements = 25% VMT reduction per household
14 miles avoided per day (25% of household VMT)
per household of the housing units in 2021 Oct. 11, 2022Item #12 Page 471 of 560
433
Decarbonization
Pathway
Policy
Category
Policy
Subcategory
Best Adopted CAP Commitment Applied Regionwide
CAP Measure and Assumptions Application to the Region for Year 2035
(Lemon Grove CAP Measure T-11: Reduce
Residential Parking Requirements Near Trolley
Station)
SANDAG Regional Plan Mobility Hubs (743,711
units)
Commute TDM
Strategies
Additional 10% commuters using alternative modes
= additional 10% commuters not driving alone
(Carlsbad CAP Measure K: Promote Transportation
Demand Management Strategies)
Additional 192,147 commuters not driving alone
(10% of total regionwide jobs)
One-way driving distance avoided: 10.9 miles
Increase
Commute By
Vanpool
Additional 19% commute by vanpool (Solana Beach
CAP Measure T-2: Increase Commuting by Vanpools
to 20 percent of Labor Force)
Additional 365,080 commuters by bicycling (19% of
total regionwide jobs)
One-way commute distance by vanpool: 25 miles
Number of people per vanpool: 6
Fuel Use
Reductions
Fuel Reduction
from Traffic
Calming Policies
Equivalent to 0.25% reduction in VMT (Carlsbad
CAP: General Plan Policies and Measures - Traffic
Calming)
Equivalent to 0.25% VMT reduction in regional LDV
VMT
Vehicle
Retirement
446 MT CO2e avoided from replacing 1,600 vehicles
(County of San Diego CAP: Measure T-3.3 Develop a
Local Vehicle Retirement Program)
Equivalent to 2,973 MT CO2e GHG avoided
regionwide by replacing 10,667 vehicles (15% of
regionwide VMT is from County of San Diego)
Alternative
Fuel Vehicles
and
Equipment
Increase City-
wide electric
vehicle miles
driven
Increase citywide electric vehicle miles driven to
30% total miles (Del Mar CAP Goal 16: Increase
percentage of vehicle miles traveled driven by
electric and alternative fuel vehicles & Solana Beach
CAP Measure T-1 Increase electric vehicles and
alternative fuel vehicles miles traveled to 30 percent
of total vehicle miles traveled)
30% regional LDV VMT is electric
Increase
alternative fuel
vehicles in
municipal fleet
90% reduction in municipal gasoline fleet GHG
emissions (San Diego CAP Action 2.3 Present to City
Council for Consideration a Municipal Alternative
Fuel Policy)
90% of reduction in municipal gasoline fleet
emissions. Municipal gasoline fleet emissions is
0.4% of regionwide transportation GHG emissions. Oct. 11, 2022Item #12 Page 472 of 560
434
Table A.2 Best Adopted CAP Commitment Applied Regionwide – Decarbonize Buildings
Decarbonization
Pathway
Policy
Category
Policy
Subcategory
Best Adopted CAP Commitment Applied Regionwide
CAP Measure and Assumptions Application to the Region for Year 2035
Decarbonize
Buildings
Electrification
Electrify New
Residential
Construction
All-electric new residential (single-family and
multi-family) construction after 2023 (Lemon
Grove CAP Measure E-6: Require New Residential
Uses to be All-Electric and Generate Renewable
Energy On-Site)
New housing units from 2023 to 2035 regionwide:
163,351
196 therms of natural gas avoided and 1,680 kWh of
electricity added per new Energy Code-compliant
unit (average of single-family and multifamily unit in
Climate Zone 7 and 10)
Energy
Efficiency
Residential
Energy Retrofit
50% energy reduction at 30% existing homes
(single-family and multifamily) (Carlsbad CAP
Measure D: Encourage Single-Family Residential
Efficiency Retrofits & Measure E: Encourage
Multi-family Residential Efficiency Retrofits)
15% reduction in regionwide residential energy use =
106 therms of natural gas avoided and 1,989 kWh of
electricity avoided per home (50% of average
regionwide household energy use)
Non-residential
Energy Retrofit
40% energy reduction at 30% existing commercial
spaces (Carlsbad CAP Measure F: Encourage
Commercial and City Facility Efficiency Retrofits)
12% reduction in regionwide commercial energy use
Residential
Water Heater
Retrofit
25% of existing homes retrofitted with solar water
heating (Solana Beach CAP Measure E-5: Solar Hot
Water Heating at 25 Percent of new homes and
home retrofits)
112 therms avoided per natural gas water heater
retrofit (60% of water heaters are natural gas); and
2,300 kWh avoided per electric water heater retrofit
(40% water heaters are electric).
Non-residential
Solar Water
Heater Retrofit
20% of existing commercial spaces retrofitted
with solar water heating (Solana Beach CAP
Measure E-4: Solar Hot Water Heating at 20
Percent of existing commercial spaces)
6% of total commercial energy use is from water
heating. 10% of reduction in water heating energy
use per retrofit.
Oct. 11, 2022Item #12 Page 473 of 560
435
Table A.3 Best Adopted CAP Commitment Applied Regionwide – Decarbonize the Electricity Supply
Decarbonization
Pathway
Policy
Category
Policy
Subcategory
Best Adopted CAP Commitment Applied Regionwide
CAP Measure and Assumptions Application to the Region for Year 2035
Decarbonize
Electricity
Supply
Grid Supply
Community
Choice Energy
(CCE) Program
100% renewable or zero carbon electricity (Encinitas CAP
City Action RE-1: Establish a Community Choice Energy
Program & Escondido CAP Measure E-5.3 Increase Grid-
supply Renewable and/or Zero Carbon Electricity)
95% of the SDG& bundled load in the region
would switch to CCE with 100% renewable or
zero carbon electricity (zero GHG emissions)
Table A.4 Best Adopted CAP Commitment Applied Regionwide – Natural Climate Solutions
Decarbonization
Pathway Policy Category Policy
Subcategory
Best Adopted CAP Commitment Applied Regionwide (with City of San Diego draft 2020 CAP)
CAP Measure and Assumptions Application to the Region for Year 2035
Natural Climate
Solutions
Carbon Removal
and Storage
Urban Tree
Planting or Urban
Canopy Cover
Achieve 35% urban canopy cover (Del Mar CAP Goal
22: Urban Tree Planting & San Diego CAP Measure
5.1 Urban Tree Planting Program)
35% of developed area in the region would
have urban canopy cover. Oct. 11, 2022Item #12 Page 474 of 560
436
Table A.5 Best CAP Commitment with Draft San Diego 2022 CAP Applied Regionwide – Decarbonize Transportation Pathway
Decarbonization
Pathway
Policy
Category
Policy
Subcategory
Best Adopted CAP Commitment Applied Regionwide (with City of San Diego draft 2020 CAP)
CAP Measure and Assumptions Application to the Region for Year 2035
Decarbonize
Transportation
VMT
Reductions
Bike, Walk, and
Complete
Street
25% walking (11% beyond projected) and 10% (8%
beyond projected) cycling mode share of all San Diego
residents’ trips (San Diego Draft 2022 CAP Measure
3.1: Safe and Enjoyable Routes for Pedestrians and
Cyclists)
Cycling: Additional 304,109 trips by cycling (8% of
regionwide population, and one trip per day), one-way
trip distance: 2.9 miles
Walking: Additional 398,238 trips by walking (11% of
regionwide population, and one trip per day), one-way
trip distance: 0.8 mile
Mass Transit +
Intra-city
Shuttle
15% (10% beyond projected) transit mode share of all
San Diego residents’ trips (San Diego Draft 2022 CAP
Measure 3.2: Increase Safe, Convenient, and Enjoyable
Transit Use)
Transit: Additional 347,553person trips by walking
(10% of regionwide population, and one trip per day),
one-way trip distance: 7.9 mile
Intra-city Shuttle: Existing CAP commitment carry over
Smart Growth
Development
and Parking
Reduction
15% VMT (commuter and non-commuter) reductio per
capita (San Diego Draft 2022 CAP Measure 3.5:
Climate-Focused Land Use and Measure 3.6: Vehicle
Management)
15% reduction below 2016 regional wide baseline VMT
per capita: 25.6 miles per capita per day
Commute TDM
Strategies
6% citywide VMT reduction through telecommute
(San Diego Draft 2022 CAP Measure 3.3: increase
Telecommuting)
6% regionwide VMT reduction
Fuel Use
Reductions
Fuel Reduction
from Traffic
Calming Policies
Equivalent to 0.25% reduction in VMT (Carlsbad CAP:
General Plan Policies and Measures - Traffic Calming) Equivalent to 0.25% VMT in regional LDV VMT
Alternative
Fuel Vehicles
and
Equipment
Increase
alternative fuel
vehicles in
municipal fleet
81% reduction in municipal gasoline fleet GHG
emissions (San Diego Draft 2022 CAP Measure 2.2:
Increase Municipal Zero Emission Vehicles)
81% of reduction in municipal gasoline fleet emissions.
Municipal gasoline fleet emissions is 0.4% of region-
wide transportation GHG emissions.
Increase City-
wide electric
vehicle miles
driven
Increase citywide electric vehicle miles driven to 30%
total miles (Del Mar CAP Goal 16: Increase percentage
of vehicle miles traveled driven by electric and
alternative fuel vehicles & Solana Beach CAP Measure
T-1 Increase electric vehicles and alternative fuel
vehicles miles traveled to 30 percent of total vehicle
miles traveled)
30% regional LDV VMT is electric Oct. 11, 2022Item #12 Page 475 of 560
437
Table A.6 Best CAP Commitment with Draft San Diego 2022 CAP Applied Regionwide – Decarbonize Building Pathway
Decarbonization
Pathway
Policy
Category Policy Subcategory Best Adopted CAP Commitment Applied Regionwide (with City of San Diego draft 2020 CAP)
CAP Measure and Assumptions Application to the Region for Year 2035
Decarbonize
Buildings
Electrification
Electrify New
Homes
All-electric new residential (single-family and multi-
family) construction after 2023 (Lemon Grove CAP
Measure E-6: Require New Residential Uses to be
All-Electric and Generate Renewable Energy On-
Site & San Diego Draft 2022 CAP Measure 1.2
Decarbonize New Building Development)
New housing units from 2023 to 2035 regionwide:
163,351
196 therms of natural gas avoided and 1,680 kWh of
electricity added per new Energy Code-compliant unit
(average of single-family and multifamily unit in
Climate Zone 7 and 10)
Electrify New
Nonresidential
Buildings
All-electric reach code starting 2023 at new
commercial development (San Diego Draft 2022
CAP Measure 1.2 Decarbonize New Building
Development)
0.5% of annual regionwide commercial natural gas
use is from new construction and avoided starting
2023. Regionwide commercial natural gas use is about
33% of total energy use.
Decarbonize
Existing
Buildings/
Energy
Efficiency
Residential Energy
Retrofit (Electricity
savings only)
50% energy reduction at 30% existing homes
(single-family and multifamily) (Carlsbad CAP
Measure D: Encourage Single-Family Residential
Efficiency Retrofits & Measure E: Encourage Multi-
family Residential Efficiency Retrofits)
15% reduction in regionwide residential electricity
use, 1,989 kWh of electricity avoided per home (50%
of average regionwide household energy use)
Non-residential
Energy Retrofit
(Electricity savings
only)
40% energy reduction at 30% existing commercial
spaces (Carlsbad CAP Measure F: Encourage
Commercial and City Facility Efficiency Retrofits)
12% reduction in regionwide commercial electricity
use
Residential Solar
Water Heater
Retrofit (Electricity
savings only)
25% of existing homes retrofitted with solar water
heating (Solana Beach CAP Measure E-5: Solar Hot
Water Heating at 25 Percent of new homes and
home retrofits)
2,300 kWh avoided per electric water heater retrofit
(40% water heaters are electric).
Non-residential
Solar Water Heater Retrofit (Electricity
savings only)
20% of existing commercial spaces retrofitted with
solar water heating (Solana Beach CAP Measure E-4: Solar Hot Water Heating at 20 Percent of existing
commercial spaces)
6% of total commercial energy use is from water
heating. 10% of reduction in water heating energy use
per retrofit.
Decarbonize
Existing Buildings
Phase out 90% of natural gas from existing
buildings (San Diego Draft 2022 CAP Measure 1.1
Decarbonize Existing Buildings)
Phase 90% remaining natural gas use (remaining after
electrify new constructions and decarbonize
municipal operations) Oct. 11, 2022Item #12 Page 476 of 560
438
Decarbonization
Pathway
Policy
Category Policy Subcategory Best Adopted CAP Commitment Applied Regionwide (with City of San Diego draft 2020 CAP)
CAP Measure and Assumptions Application to the Region for Year 2035
Retrofit/
Decarbonize
Municipal Building
Phase out 100% natural gas use in municipal
facilities (San Diego Draft 2022 CAP Measure 1.3
Decarbonize City Facilities)
2% of regionwide nonresidential natural gas use is
municipal natural gas use. Phase out 100% is
equivalent to approximately 7 million therms in 2035.
Table A.7 Best CAP Commitment with Draft San Diego 2022 CAP Applied Regionwide – Decarbonize Electricity Supply
Decarbonization
Pathway
Policy
Category
Policy
Subcategory
Best Adopted CAP Commitment Applied Regionwide (with City of San Diego draft 2020 CAP)
CAP Measure and Assumptions Application to the Region for Year 2035
Decarbonize
Electricity Supply
Utility Scale
Energy
Community
Choice Energy
(CCE) Program
100% renewable or zero carbon electricity (Encinitas CAP
City Action RE-1: Establish a Community Choice Energy
Program, Escondido CAP Measure E-5.3 Increase Grid-
supply Renewable and/or Zero Carbon Electricity, & San
Diego Draft 2022 CAP Measure 2.1: Citywide Renewable
Energy Generation)
95% of the SDG&E bundled load in the
region would switch to CCE with 100%
renewable or zero carbon electricity (zero
GHG emissions)
Table A.8 Best CAP Commitment with Draft San Diego 2022 CAP Applied Regionwide – Natural Climate Solutions
Decarbonization
Pathway Policy Category Policy
Subcategory
Best Adopted CAP Commitment Applied Regionwide (with City of San Diego draft 2020 CAP)
CAP Measure and Assumptions Application to the Region for Year 2035
Natural Climate
Solutions
Carbon Removal
and Storage
Urban Tree
Planting or Urban
Canopy Cover
Achieve 35% urban canopy cover (Del Mar CAP
Goal 22: Urban Tree Planting & San Diego Draft
CAP Measure 5.2 Tree Canopy)
35% of developed area in the region would
have urban canopy cover.
Salt Marsh Land
Restoration
Restore 700 acres of salt marsh, other associated
tidal wetland and riparian habitats (San Diego
Draft 2022 CAP Measure 5.2 Tree Canopy)
Same as left Oct. 11, 2022Item #12 Page 477 of 560
439
Appendix 8.B Supporting Material for Decarbonize Transportation Policy
Assessment
B.1 Overlap or Gaps Between CAP Actions and Key Opportunities Identified in Chapter 3
Chapter 3 identified key actions to address two main areas of on-road transportation GHG reduction. These are listed in Table 8.B.1
The extent to which these actions appear as CAP policies, and whether they are quantified for GHG reduction, are also shown.
Table 8.B.1 Overlap Between CAPs and with Key Opportunities Identifies in Chapter 3
Key Actions Chapter 3 Equivalent CAP Policy Category
and Number of CAPs Addressing
# of CAPs with Quantified
GHG Reduction Amount
Challenges as Identified in
CAPs
Local
Opportunity?
VMT Reduction Actions
Expand geographic reach and service
hours of bus and rail services in areas
where development can support transit
use
Mass transit 1 Y - Requires regional
cooperation
Provide incentives and regulatory relief
to facilitate higher density infill and
transit-oriented development
Permit and CEQA streamlining
(regulatory relief) for projects; 2
Local resistance to infill,
higher density and transit-
oriented development
Y
Disincentivize development in rural (or
non-infill) areas that cannot support
efficient transit use or multi-modal
transportation options
Not addressed in CAPs 0 Not addressed in CAPs Y
In existing rural, non-infill, or
underserved transit areas, invest in TNC
partnerships prioritizing electric and high-occupancy vehicles to ensure
sufficient access to opportunities
Not addressed in CAPs 0 Not addressed in CAPs Y Oct. 11, 2022Item #12 Page 478 of 560
440
Key Actions Chapter 3 Equivalent CAP Policy Category
and Number of CAPs Addressing
# of CAPs with Quantified
GHG Reduction Amount
Challenges as Identified in
CAPs
Local
Opportunity?
Investigate opportunities to implement
pricing structures (cordon pricing, HOT
lanes, etc.) that incentivize high
occupancy vehicles
Not addressed in CAPs 0
1. Regional
cooperation/authority;
2. Pricing is used for larger
roads (arterials and
freeways) over which local
jurisdictions have no
authority;
3. Even at the regional level,
road pricing faces local
resistance
N
Adopt pedestrian-oriented design
guidelines for all new development;
reduce or remove parking minimums in
walkable neighborhoods
Bike, walk, complete streets;
parking reduction
16 CAPs address bike, walk
complete streets, 4
address parking reduction
as a requirement or CIP
Local resistance to removing
parking or road diets to
accommodate complete
streets
Update county bicycle and pedestrian
planning documents; partner with
SANDAG to accelerate implementation
of 2010 San Diego Regional Bicycle Plan;
develop Pedestrian Safety and/or Vision
Zero and/or Local Road Safety Plan
Bike, walk, complete streets;
specific to unincorporated
County
Not addressed in CAPs
Needs assessment since
distances are large, may be
practical only in urbanized
areas
Y
Partner with SANDAG to build out a
network of Mobility Hubs where shared
vehicles and new mobility services can
be found
Smart growth
3 CAPs address
micromobility; SANDAG
quantifies GHG reductions
from shared mobility
Local resistance to
micromobility services;
regional cooperation to
establish mobility hubs
Y
Develop County TDM ordinance and
Transportation Management
Organization (TMO) to work with
employers and service providers
County specific - Commuter TDM Half the CAPs address
commuter TDM - Y Oct. 11, 2022Item #12 Page 479 of 560
441
Key Actions Chapter 3 Equivalent CAP Policy Category
and Number of CAPs Addressing
# of CAPs with Quantified
GHG Reduction Amount
Challenges as Identified in
CAPs
Local
Opportunity?
Conduct broadband gap analysis; seek
funding to improve communications
infrastructure in areas that lag; require
enhanced communication technology in
all new development through TDM
ordinance
Not addressed in CAPs Not addressed in CAPs - Y
Conduct electrified freight study to understand where opportunities for
distribution efficiencies exist; modify
zoning code to encourage distribution
centers in efficient locations
Not addressed in CAPs Not addressed in CAPs -
Y for some CAPs
where freight
transport is an
issue
Electrification Actions
Set and meet aggressive public EV
charging target Alternative Fuels, n/a
“Aggressive” needs
definition. Assess A2Z gap
report versus CAP public
charging targets.
Y – see also
“Best
commitment”
Scenario EV
numbers in
2035
Set and meet aggressive (100%) fleet
adoption target
Alternative fuels in municipal
fleets 8 - Y
Require new development to include EV
charging Alternative Fuels, 12 - Y
Require existing development to retrofit
parking with EV charging Alternative Fuels, 12 - Y
Increase dollar value and streamline
consumer vehicle purchase incentives
with application to both new and used
vehicles
Alternative Fuels 4 - Y Oct. 11, 2022Item #12 Page 480 of 560
442
Key Actions Chapter 3 Equivalent CAP Policy Category
and Number of CAPs Addressing
# of CAPs with Quantified
GHG Reduction Amount
Challenges as Identified in
CAPs
Local
Opportunity?
Increase dollar value of incentives,
provide educational resources, and
streamline permitting process for
landowners to install EV charging in
multi-family developments
Alternative Fuels, 4 - Y
Partner with educational institutions to
assess workforce training needs;
increase funding to existing programs
Alternative Fuels, 0 - Y
Continue to partner with A2Z
Collaborative to share information and
successful implementation strategies
across jurisdictions, advocate for
funding and coordination at the state
level
Alternative Fuels, 0 Evaluation/cooperation Y
Oct. 11, 2022Item #12 Page 481 of 560
443
9. The San Diego Region as a Model
Lessons and opportunities on aligning pathways, policies, and resources to identify win-win
scenarios in the transition to net zero
Elena Crete, UN Sustainable Development Solutions Network (SDSN)
Julie Topf, UN Sustainable Development Solutions Network (SDSN)
9.1 Purpose
The San Diego Regional Decarbonization Framework (RDF) is a novel demonstration of
collaborative long-term planning which other regions and jurisdictions should adapt and
replicate to keep global warming below 1.5 degrees Celsius. With the Intergovernmental Panel
on Climate Change (IPCC) now sounding the alarm on climate change with their 2021 Global
Warming of 1.5ºC Special Reporti and 2022 Sixth Assessment Report,ii communities around the
world are beginning to reflect on what reducing and eliminating emissions means for their
specific contexts. While scientists agree we now have the technologies we need to enable the
transition to net zero, the exact configuration of those technologies, accompanied by
supporting policy frameworks and financing, will need to be calibrated for specific conditions
around the globe. Each local process must take into consideration their greenhouse gas
emissions inventory, local economy and workforce, socio-environmental conditions, and long-
term emissions reduction goals in a collaborative and transparent planning process.
The process undertaken by the County of San Diego can serve as a case study for other
jurisdictions across the US and globally to learn from and replicate. In order to facilitate this
dissemination, the RDF project team is working closely with the UN Sustainable Development
Solutions Network (SDSN) to showcase this effort alongside various international fora. This
chapter demonstrates the ways by which the findings of the RDF can be scaled vertically and
horizontally through various consortiums to further contribute to the global climate agenda and
the development of other decarbonization frameworks. Additionally, SDSN has developed an
accompanying Guideiii to serve as a toolkit for other communities, governing bodies, research
groups, and sustainability practitioners to use in their pursuit of decarbonization. This Guide
will serve as an addendum to the larger Regional Decarbonization Framework report. The
purpose of this Guide is to distill the high-level process undertaken so far by the County,
highlight the enabling factors for success, and provide a step-by-step instruction manual for
other jurisdictions who wish to undertake similar long-term planning processes in their efforts
to combat climate change.
As articulated several times in this report, the scenarios and framework described in this
exercise are just a beginning and will require flexibility and alterations along the way. To most
i https://www.ipcc.ch/sr15/
ii https://www.ipcc.ch/assessment-report/ar6/
iii http://sdgpolicyinitiative.org/guide/
Oct. 11, 2022 Item #12 Page 482 of 560
444
effectively take this work forward, it is essential for the San Diego County project team and
researchers to connect with other national and international forums where they can both
garner insights from and inform similar exercises being undertaken around the globe. A few
such opportunities are highlighted below for the County to follow up on.
9.2 Opportunities for Scaling Impact
With broadband access now extending to the most remote parts of the world and the COVID-19
crisis encouraging professionals around the globe to adapt to a virtual workplace, the
opportunity for engaging stakeholders and sharing experiences is greater than ever. Over the
last several decades, there have been new consortiums and networks established that work
both vertically and horizontally across our societies to align development agendas and
resources to accelerate progress in sustainable development and climate change mitigation.
One such consortium is working globally to elevate the academic and science community to
highlight the multidisciplinary approach required to understand and achieve sustainable
development, the UN Sustainable Development Solutions Network (SDSN).i
SDSN was set up in 2012 under the auspices of the UN Secretary-General. SDSN mobilizes
global scientific and technological expertise to promote practical solutions for sustainable
development, including the implementation of the Sustainable Development Goals (SDGs) and
the Paris Agreement. SDSN works closely with United Nations agencies, multilateral financing
institutions, the private sector, and civil society. SDSN is guided by a Leadership Council, which
brings together global sustainable development leaders from all regions and all sectors. Much
of SDSN’s work is led by National or Regional SDSNs, which mobilize knowledge institutions
around the SDGs. Their research and policy work mobilizes experts from around the world on
the technical challenges of implementing the SDGs and the Paris Agreement. The SDG Academy
leads the education work of SDSN. As a member of the network, UC San Diego has brought on
SDSN as a consulting partner in the creation of the RDF and accompanying Guide to ensure that
the process and results of this project are firmly integrated into various multilateral fora, both
within and alongside formal UN processes.
SDSN is working to share the RDF project within three horizontal levels across its network. First,
nationally, SDSN USAii currently hosts nearly 160 institutions across all 50 states, Puerto Rico,
and Washington, DC. These academic institutions have local networks of sustainability
practitioners working in various aspects of the SDGs. SDSN USA builds pathways toward the
achievement of the SDGs in the United States by mobilizing research, outreach, collective
action, and global cooperation. To accomplish this, SDSN USA facilitates and leads coalitions to
address US sustainability challenges; builds sophisticated, practical systems for assessing
progress; promotes public awareness, education, and engagement; and links these efforts with
policymakers and community leaders throughout the US to result in lasting change. In addition
to the other universities in this network who can learn from the RDF, SDSN also has partner
i https://www.unsdsn.org/
ii https://www.unsdsn.org/united-states
Oct. 11, 2022 Item #12 Page 483 of 560
445
networks across the US with whom the final report will be shared in order to disseminate the
results nationally.
The SDSN USA network is also part of a larger network of national and regional networks which
make up the international framework of SDSN.i With more than 1,500 members working across
50 national and regional networks worldwide, SDSN USA is part of a global multidisciplinary
consortium of experts and has access to thought-leaders around the world. This allows the
network to share the results of the RDF directly with like-minded sustainability experts across
various regions and geographies who can glean important lessons learned from the RDF process
and Guide.
Lastly, SDSN serves as an observer organization to the United Nations Economic and Social
Council (ECOSOC) and United Nations Framework Convention on Climate Change (UNFCCC)
processes and is also a partner in the Cities and Climate Change Science Conference which was
co-sponsored by the IPCC in 2018. This effort continued under the auspices of the
Innovate4Cities Conferenceii in October 2021, co-hosted by UN-Habitat and the Global
Covenant of Mayors for Climate & Energy. The RDF project was submitted to this forum and the
inputs of this event were meant to inform the 2022 IPCC Sixth Assessment Report on impact,
adaptation, and vulnerability to global climate change.iii Opportunities for sharing the final
report will be further explored through the UNFCCC Regional Climate Weeks,iv which take place
annually throughout the world. Additionally, SDSN is plugged into several other forums and
networks through which it will share this work. These networks include the Global Solutions
Lab,v the Open Energy Modelling Initiative,vi and the Zero Emissions Solutions Conference,vii to
name a few. These globally recognized consortiums provide an opportunity to showcase the
results of this project and San Diego as a model to the world. With access to these fora, the RDF
project can help inform global roadmaps and pathways to net zero.
Through a concerted effort to enable this ecology of networks, this project can serve as a model
and have a greater impact far beyond the jurisdictional boundaries of San Diego region.
9.3 Planning Across Jurisdictions––Horizontal and Vertical Alignment
Significant progress has been made over the last few decades in decarbonization efforts across
California, however, many of the efforts have been undertaken with a specific technology,
market, policy, or sector focus. This has led to a fragmented approach which only enables parts
of the system to move forward, allowing uncertainties and risk averse behavior to limit the
ambitious, transformative decision-making needed to enable an energy system transformation.
i https://www.unsdsn.org/networks-overview
ii https://www.innovate4cities.org/
iii https://www.ipcc.ch/report/sixth-assessment-report-working-group-ii/
iv https://unfccc.int/climate-action/regional-climate-weeks#eq-1
v https://designsciencelab.com/
vi https://openmod-initiative.org/
vii https://zeroemissions.network/
Oct. 11, 2022 Item #12 Page 484 of 560
446
Only with a systems approach can deep decarbonization be achieved. To apply a systems
approach to decarbonization, detailed pathways analysis is needed to understand the sectors,
stakeholders, and potential physical and economic trajectories that must be accounted for, so
that policies can be developed in ways that compensate for displacement, buffer disruptive
shifts, and ensure a just transition. The San Diego County RDF approach attempts to do exactly
this, laying the groundwork for the institutional framework needed to facilitate long-term
transformational change in the energy system across jurisdictions and political boundaries.
The enabling factors in San Diego included a strong historical precedent of local climate action
planning, as well as pre-established institutional linkages across several areas (for example, the
San Diego Association of Governments (SANDAG)i works with jurisdictions throughout the
region beyond transportation planning), coupled with an ambitious and technically rigorous
vision set by the County leadership. By employing state of the art energy system modeling tools
and working with local experts from universities and public policy think tanks, the County has
demonstrated leadership in mapping key pathways to meeting their climate action plan goals.
The technological capacity of the team, plus the local political support, has created a
collaborative and transparent process through which the RDF was developed. While the exact
future remains unclear as pathways are certain to shift, technologies develop, and priorities
change, the project at the very least presents the institutional framework necessary to take the
work outlined in the RDF forward.
To continue to develop and build on this year-long process, San Diego County should leverage
both national and global fora for resource input, process benchmarking, and access to other
experts. In addition to the key fora highlighted below, Appendix 9.A provides extensive lists of
other national and global consortia that San Diego County and other regional jurisdictions can
connect with to promote this kind of exercise elsewhere.
Nationally, the campaign "America Is All In"ii is the most expansive coalition of leaders ever
established in support of climate action in the United States. Led by climate champions across
the country and consisting of thousands of US cities, states, tribal nations, businesses, schools,
and faith, health, and cultural institutions, the coalition is working alongside the federal
government to develop a national climate strategy to reach net-zero emissions by 2050. Sharing
the findings of the San Diego RDF can help the ~4,000 signatories of the coalition’s joint
declaration of support for climate action understand how to carry out local decarbonization
planning, so that they can effectively act on their pledges. Moreover, connecting with the US
Department of Energy’s National Labsiii across the country also provides the opportunity to
receive support from national interdisciplinary experts and their vast arrays of networks and
resources, as well as to elevate the impact of regional decarbonization frameworks like the San
Diego RDF by engaging with top-level practitioners. The Saoradh Enterprise Partners Cleantech
Innovation Hubsiv can provide a good starting point to identify opportunities for engaging with
i https://www.sandag.org/
ii https://www.americaisallin.com/
iii https://www.energy.gov/national-laboratories
iv https://www.saoradh.com/research#hubs
Oct. 11, 2022 Item #12 Page 485 of 560
447
innovative private sector companies working in the clean tech space, through their deep
mapping of emerging hubs and ranking of the top 40 US hubs based on the strength of their
research funding and results, technology development, venture development, and other
metrics.
At the state level, the US Climate Alliance,i a bipartisan coalition of governors committed to
reducing greenhouse gas emissions consistent with the Paris Agreement, offers an excellent
opportunity for the findings of the RDF to inform smart, coordinated climate action. The
National Governors Association,ii the US bipartisan organization of the nation’s governors, is
another platform where the RDF can contribute to state solutions that improve citizens’ lives
through decarbonization efforts. With the state of California already being a formal member of
both fora, the RDF can easily support and encourage other states to follow in San Diego and
California’s footsteps. Moreover, facilitating decarbonization across US states with the RDF, and
demonstrating continued US climate leadership via such groups, will further encourage other
nations to do the same.
At the city level, with 1,400 mayors of large US cities as its members and sharing best practices
as one of its primary roles, disseminating the findings of the RDF at the US Conference of
Mayorsiii provides a great opportunity to contribute to the development of national urban
policy. The benefits of engaging with the conference also extend beyond the city level because
the policy positions adopted at the annual meeting, which represent the views of the nation’s
mayors, are distributed to the President of the United States and Congress.
And finally, for the districts included within the San Diego RDF, the Urban Sustainability
Directors Networkiv offers a very practical opportunity to work alongside other municipal
leaders at the county level toward implementing climate resilience work. While San Diego
County is already one of the 200 communities representing nearly 90 million residents that are
part of this network, other US and Canadian local governments are eligible to join.
Globally, the United Nations Framework Convention on Climate Change (UNFCCC) offers the
most premier stage to share the RDF. While the Paris Agreement consists of national efforts,
city and regional networks have been increasingly highlighted as key innovators and solution
providers to help nations implement their emissions reduction goals. The annual UNFCCC
Yearbookv is a great resource to explore to understand sectoral solutions and needs from a
global perspective to ensure that the local aspects of the RDF are comprehensive and aligned
with global goals.
Additionally, two of the main global city networks that are actively involved with the UNFCCC
Conference of the Parties include the C40 Cities Climate Leadership Group (C40)vi and the
i http://www.usclimatealliance.org/
ii https://www.nga.org/
iii https://www.usmayors.org/
iv https://www.usdn.org/index.html#/
v https://unfccc.int/sites/default/files/resource/Yearbook_GCA_2021.pdf
vi https://www.c40.org/
Oct. 11, 2022 Item #12 Page 486 of 560
448
International Council for Local Environmental Initiatives (ICLEI).i C40 is a network of mayors of
nearly 100 world-leading cities specifically working together on climate action based on a
science-based and collaborative approach, which the San Diego RDF and pathways-based
planning align well with and contribute to. Also, with the cities of Encinitas and Chula Vista as
members, San Diego County already has established connections in the ICLEI, a global network
of more than 2,500 local and regional governments committed to sustainable urban
development that can significantly benefit from learning how to create regional
decarbonization frameworks on the road to net zero.
Another key global forum to engage with and disseminate the learnings of the San Diego RDF
and other decarbonization frameworks through is the Global Covenant of Mayors for Climate &
Energy,ii the largest global alliance for city climate leadership in the world. The RDF can
contribute to the covenant’s three core initiatives––Data4Cities, Innovate4Cities, and
Invest4Cities––which aim to facilitate local government climate action with knowledge, data,
tools, and technical support. Furthermore, since 2014, the City of San Diego has participated in
the Carbon Disclosure Project (CDP).iii The RDF experience should be shared with them as a
showcase of how carbon mitigation efforts can be scaled regionally and how other variables for
land use conservation can be incorporated into comprehensive planning efforts. Given the
CDP’s global reach, sharing the work here could influence similar districts across the country
and around the globe.
Expanding the impact of the San Diego RDF is exactly the objective of the Guide which
accompanies this report. While this chapter and Appendix 9.A present extensive lists of fora
that San Diego County – and other jurisdictions with decarbonization frameworks––should
connect with, attend, and join the networks of to disseminate their findings across different
scales, the Guide supplements these strategies by outlining how the San Diego RDF process can
be replicated and customized to other jurisdictions in their efforts to chart their own paths
toward decarbonization. Targeted toward other jurisdictions in the US, the Guide provides
process and technical guidance on how to get started on regional decarbonization frameworks,
examples of the tools and methodology available to design and carry out needed analyses,
recommendations for future research, and provides a directory of US and international
decarbonization resources. The Guide is intended to be used by jurisdictions at all phases of the
decarbonization process, whether they are just getting started or building on already existing
climate action plans. By disseminating the findings of the larger RDF report and creating the
accompanying Guide, it is our hope that the process undertaken by San Diego County will help
equip jurisdictions with the strategies and resources they need to accelerate deep
decarbonization efforts during this decisive Decade of Action.
We welcome stakeholders to read and share the accompanying Guide to Regional
Decarbonization created in tandem with this report at http://sdgpolicyinitiative.org/guide/ .
i https://www.iclei.org/
ii https://www.globalcovenantofmayors.org/
iii https://www.cdp.net/en
Oct. 11, 2022 Item #12 Page 487 of 560
449
Appendix 9.A Relevant US and Global Communities of Practice Lists
San Diego Level
Building Industry Association of San Diego
Relevant departments of the City of San Diego
below (full list at www.sandiego.gov/city-hall/
departments)
Fleet Operations Division
Engineering & Capital Projects
Environmental Services Department
Parks and Recreation
Performance & Analytics Department
Planning Department
Public Utilities
Department of Real Estate and Airport
Management
Sustainability
Transportation Department
Clean Coalition
Clean Energy Alliance
Cleantech San Diego
Live Well San Diego
San Diego Building Electrification Coalition
San Diego Community Choice Alliance
San Diego Gas & Electric
San Diego Food System Alliance
San Diego Quality of Life Coalition
San Diego Regional Clean Cities Coalition
San Diego Urban Sustainability Coalition
From “RDF Figure 7.1: Role of the County of San
Diego in the Regional Decarbonization Context”
San Diego Air Pollution Control District
San Diego Airport Authority
San Diego Association of Governments
(SANDAG)
Energy Working Group
Environmental Mitigation Program
Working Group
Military Working Group
Public Health Stakeholders Group
Regional Housing Working Group
Regional Planning Technical Working
Group
Shoreline Preservation Working Group
San Diego Climate Advisory Committee
San Diego Community Power (SDCP)
San Diego County Water Authority
San Diego County’s 18 cities
San Diego County Land Use and
Environment Group
San Diego County Office of Environmental
and Climate Justice
San Diego County Office of Evaluation,
Performance, and Analytics
San Diego Metropolitan Transit System
San Diego North County Transit District
Port of San Diego
Oct. 11, 2022 Item #12 Page 488 of 560
450
California State Level
Building Decarbonization Coalition
Building Industry Association of Southern
California
CalEPA Climate Action Team
California Building Industry Association
California Climate & Agriculture Network
California Climate and Energy Collaborative
California Electric Transportation Coalition
California Energy Alliance
California Energy Storage Alliance
California Indian Environmental Alliance
California Solar & Storage Association
Central Coast Community Energy
Clean Cities Coalition Network (search for
“California” in full list at https://cleancities.
energy.gov/coalitions/contacts/)
Climate Science Alliance
Community Alliance with Family Farmers
East Bay Community Energy
Energy Coalition
Institute for Local Government’s Beacon
Program
MCE Community Choice Energy
Mobility 21
North State Building Industry Association
Pacific Gas and Electric Company
Southern California Edison
TECH Clean California
The Climate Center
The Greenlining Institute
Tri-County Regional Energy Network
Relevant State Agencies below (full list at
https://www.ca.gov/agenciesall/)
California Air Resources Board
California Alternative Energy and Advanced
Transportation Financing Authority
California Boating and Waterways Commission
California Building Standards Commission
California Coastal Commission
California Department of Conservation
California Department of Forestry and Fire
Protection
California Department of Industrial Relations
California Department of Insurance
California Department of Parks and Recreation
California Department of Public Health
California Department of Resources Recycling and
Recovery
California Department of Transportation
California Energy Commission
California Environmental Protection Agency
California High-Speed Rail Authority
California Infrastructure and Economic
Development Bank
California Natural Resources Agency
California Pollution Control Financing Authority
California Public Utilities Commission
California State Lands Commission
California State Mining and Geology Board
California State Transportation Agency
California Transportation Commission
California Workforce Development Board
Cool California
Governor's Office of the Tribal Advisor
Office of Energy Infrastructure Safety
Office of the Governor
Oct. 11, 2022 Item #12 Page 489 of 560
451
US Regional & National Levels
Alliance for Transportation Electrification
Amalgamated Transit Union
America is All In
American Federation of Labor–Congress of
Industrial Organizations
American Planning Association
American Public Power Association
Better Buildings Initiative
Building Decarbonization Coalition
Buildings Performance Standards Coalition
Business Council for Sustainable Energy
Clean Cities Coalition Network
Clean Energy States Alliance
Clean Power Alliance
Climate Mayors
Coalition of Northeastern Governors
Confederation of International Contractors'
Association
Construction Associations (full lists at https://
guides.emich.edu/c.php?g=188171&p=1241588
& https://jobstars.com/construction-profession
al-associations-organizations/)
Consumer Energy Alliance
Cooperative Automated Transportation
Coalition
DOE Office of Energy Efficiency & Renewable
Energy
Electric Power Research Institute
Energy, Emissions, and Equity Initiative
Energy Foundation
Energy Information Administration
EPA Climate Change Partnerships
Equitable & Just National Climate Platform
Federal and State Recognized Tribes (full list at
https://www.ncsl.org/legislators-
staff/legislators/quad-caucus/list-of-federal-
and-state-recognized-tribes.aspx)
Food and Agriculture Climate Alliance
Georgetown Climate Center
Indigenous Climate Action
Indigenous Environmental Network
International Association of Machinists and
Aerospace Workers
International Brotherhood of Electrical Workers
International Brotherhood of Teamsters
International Union of Operating Engineers
Interstate Renewable Energy Council
Native American Finance Officers Association
National Association of Home Builders
National Congress of American Indians
National Energy Marketers Association
National Governors Association
National League of Cities
National Operations Center of Excellence
National Renewable Energy Laboratory
North America's Building Trades Unions
Northwest Energy Efficiency Alliance
Regional Greenhouse Gas Initiative
Rural Utilities Service
Solar Energy Industries Association
Strategic Organizing Center
The American Clean Power Association
The Eastern Transportation Coalition
Transport Workers Union of America
Transportation & Climate Initiative
Tribal Organizations (full list at https://www.
ncai.org/tribal-directory/tribal-organizations)
United Auto Workers
United Food and Commercial Workers
Oct. 11, 2022 Item #12 Page 490 of 560
452
Urban Sustainability Directors Network
US Climate Action Network
US Climate Alliance
US Conference of Mayors
US Energy Association
Relevant US Executive Government Agencies
below (full list https://www.loc.gov/rr/news/
fedgov.html)
US Department of Agriculture
US Department of Commerce
US Department of Defense
US Department of Energy
US Department of Housing and Urban
Development
US Department of the Interior
US Department of Labor
US Department of Transportation
US Farmers and Ranchers in Action
US Government Agencies (full list at
https://www.usa.gov/federal-agencies)
Office of Climate Change and Health Equity
Office of Conservation and Water
Office of Environmental Quality
Office of Global Change
Office of the Special Presidential Envoy for
Climate
Working for Advanced Transmission
Technologies Coalition
Oct. 11, 2022 Item #12 Page 491 of 560
453
International/Global Level
Alliance of Bioversity International and the
International Center for Tropical Agriculture
Alliances for Climate Action
Allied for Climate Transformation by 2025
Center for Climate and Energy Solutions
Climate Action Network International
Climate Alliance
Climate Ambition Alliance
Climate and Clean Air Coalition
Climate Land Ambition & Rights Alliance
Coalition for Supporting Cities To Deliver
Integrated Urban Energy Systems
Coalition for Urban Transitions (now run by a
team at the World Resources Institute)
Council on Urban Initiatives
C40 Cities Climate Leadership Group
Energy Transitions Commission
EPA International Climate Partnerships
Glasgow Action for Climate Empowerment
Work Programme
Global Alliance for Climate-Smart Agriculture
Global Alliance of Territorial Communities
Global Climate Forum
Global Covenant of Mayors for Climate &
Energy
Global Energy Alliance for People and Planet
Global Network of Regional Sustainable Energy
Centres
G7
G20
High-level Political Forum on Sustainable
Development
Intergovernmental Panel on Climate Change
International Council for Local Environmental
Initiatives
International Council on Clean Transportation
International Energy Agency
International Housing Association
International Renewable Energy Agency
International Renewable Energy Agency
Coalition for Action
Least Developed Countries Renewable Energy
and Energy Efficiency Initiative for Sustainable
Development
NDC Partnership
Net Zero World Initiative
Organisation for Economic Co-operation and
Development
Powering Past Coal Alliance
Race to Zero
Rocky Mountain Institute
Transport Decarbonisation Alliance
Under2 Coalition
United Nations Economic and Social Council
United Nations Framework Convention on
Climate Change
UNFCCC partners and relevant
organizations (full list at https://unfccc.
int/topics/science/resources/partners-
and-relevant-organizations-0)
UN-Habitat for a Better Urban Future
UN specialized agencies (full list at https://
www.un.org/en/about-us/specialized-agencies)
Urban Land Institute
World Wind Energy Association
World Urban Forum
Oct. 11, 2022 Item #12 Page 492 of 560
454
10. Conclusion
Gordon C. McCord, UC San Diego
Elise Hanson, UC San Diego
The global scientific consensus is unequivocal: the world is in the midst of a climate crisis.
Human activities and influence have warmed the atmosphere, ocean, and land through rapid
accumulations of greenhouse gases (GHG) in the atmosphere and the ocean, causing rapid and
alarming changes. Global accords like the Paris Climate Agreement and California executive
orders recognize the urgency of decarbonization across all sectors of society and the economy.
Regional and local plans for deep decarbonization that account for both global commitments
and local needs represent critical steps toward finding least-cost solutions that adequately
consider trade-offs and equity considerations.
The San Diego Regional Decarbonization Framework (RDF) Technical Report provides technical
pathways to decarbonization in the medium-term to inform near-term policy making in
regional, County, and city governments toward collectively reducing net GHG emissions such
that they align with the State goal of net zero by 2045. The RDF does not identify the “right”
pathway; instead, it shows multiple ways forward to reach net zero energy system goals that fit
within State- and national-level net zero pathways and highlights trade-offs, decision points,
risks, and synergies in the pathways. The framework is flexible and should be continuously
updated as science, technology, and costs evolve and as uncertainties are resolved or clarified.
Decarbonizing requires collective action through regional collaboration and information
sharing. The RDF proposes region-wide institutional governance for decarbonization that
incentivizes experimentation and learning. Organized into a Regional Steering Committee,
Sector Working Groups, and Front-Line Advisors, this evolving structure can coordinate learning
efforts across jurisdictions and adapt to changing technological and political realities. A
mechanism such as a Regional Climate Action Joint Powers Agreement (JPA) could scale
strategic thinking and decision-making and facilitate closer coordination around
decarbonization. Given limited local leverage over many emitting activities, regional climate
governance institutions must directly engage with State and federal governments to advocate
for policies and programs that support local decarbonization.
The RDF analyzes technical pathways for electricity generation, transportation, and buildings. It
finds that decarbonizing each sector in the region is technically feasible but will require
concerted effort, political will to make difficult trade-offs, and active planning to ensure the
transition does not exacerbate social inequities. Climate plans must also consider the
fundamental importance of natural lands, which provide both carbon storage and annual
Oct. 11, 2022 Item #12 Page 493 of 560
455
sequestration, as well as working lands, which can be managed to provide carbon storage and
sequestration while supporting local agricultural production.
The RDF also analyzes decarbonization’s net impact on energy sector jobs, showing that the
regional pathways will generate decarbonization industry jobs and result in no net job losses,
even with fossil fuel contractions during the period. It is important for regional governments to
begin developing policies for a just transition for fossil fuel workers now. This will allow workers
to transition into jobs of equivalent or better quality in the clean energy economy or elsewhere
both before and after significant reductions in fossil fuel use. A workforce development report,
titled “Putting San Diego County on the High Road: Climate Workforce Recommendations for
2030 and 2050” by Inclusive Economics, complements the Technical Report details these policy
recommendations.i
Since the individual jurisdictions in the San Diego region each prepare Climate Action Plans
(CAPs), the RDF assessed current commitments in CAPs to understand gaps between plans and
decarbonization goals. This entailed both a comparative CAP analysis and a scenario analysis.
An additional analysis applied the CAP measure with the largest GHG reductions to every
jurisdiction, regardless of CAP status, and found that the region would still fall short of
decarbonization goals. Following an analysis of local jurisdictions’ legal authority, the RDF finds
that local governments can influence and regulate GHG emissions by accelerating State
statutory targets and policies, adopting ordinances to go beyond State law, and using unique
authority to adopt and implement policies. However, the full extent of a local jurisdiction’s
power to regulate GHG emissions remains unknown.
The process undertaken by the County of San Diego in producing the RDF can serve as a model
for other jurisdictions across the United States and the world. To facilitate dissemination, the
RDF project team collaborates closely with the UN Sustainable Development Solutions Network
(SDSN), showcasing this effort in various State, national, and international meetings and
reports. Additionally, the project team is developing an accompanying Guide to serve as a
toolkit for other municipalities and communities pursuing regional decarbonization. The Guide
is a separate effort commissioned by the County to facilitate information sharing, highlight the
enabling factors for success, and provide step-by-step instructions for other communities
wishing to undertake similar long-term planning processes in their efforts to combat climate
change.
The Regional Decarbonization Framework brings together the best scientific understanding of
what actions should be taken in the coming years to set the San Diego region on a pathway to
i Available here: https://www.sandiegocounty.gov/content/dam/sdc/lueg/regional-decarb-
frameworkfiles/Putting%20San%20Diego%20County%20on%20the%20High%20Road_June%202022.pdf
Oct. 11, 2022 Item #12 Page 494 of 560
456
decarbonization by 2045. In particular, the Framework highlights “low-regret” strategies and
investments that will be worthwhile regardless of how the longer-term picture evolves. Moving
forward quickly and meaningfully can generate political momentum and inspire other regions
across the country and abroad to follow the science-based, inclusive process that the San Diego
region is pioneering.
Oct. 11, 2022 Item #12 Page 495 of 560
457
Appendix A. Summary of Statewide Energy System
Modeling
As noted in the Study Framework chapter, the detailed sectoral analysis presented in the RDF
was informed by energy system modeling at the state and national level. This work was done by
Evolved Energy Research using the modeling tools EnergyPATHWAYS and RIO presented in
Williams et al. (2021).1 These same modeling tools were also used in the Princeton Net-Zero
America study,2 SDSN’s Zero Carbon Action Plan,3 and the Decarb America Initiative.4 Unlike in
these national studies, the state-level analysis includes two zones for California (north and
south), zones for each of the other ten western states, and a final “other states” zone that
helped to set the boundary conditions for the west around variables such as the availability of
imported biofuels. The zonal representation is shown graphically in Figure A1 and is the same
used for the analysis in Wu et al. (forthcoming).
The Study Framework (Chapter 1) also notes that the energy system modeling was not
prescriptive when it came to the RDF. Instead, it is meant to guide more detailed local-level
analyses capturing the specific circumstances of the San Diego region. The larger energy system
context presented here creates an important backdrop for the region and explicitly
acknowledges the interconnectedness of our energy and land systems. This appendix focuses
on summary results from the EnergyPATHWAYS and RIO modeling, along with the basic input
assumptions. Readers looking for a more detailed description of both the methods and the
underlying system-level dynamics outside of California should reference Williams et al. (2021).
Figure A1. Western state representation used in the EnergyPATHWAYS and RIO models that helped
provide the broader energy system context for the San Diego region.
Oct. 11, 2022 Item #12 Page 496 of 560
458
A.1 Informational flow: state-wide energy system models to regional pathways
The modeling framework used to identify decarbonization pathways at the state and national
levels is organized around energy demand and supply. First, modelers use EnergyPATHWAYS to
estimate final energy demand by type in up to 64 different demand subsectors for each study
year (2020-2045). Inputs to the model include the most recent data on subsector final energy
demand from the Energy Information Agency Annual Energy Outlook and modelers’
assumptions of how technology-use will change over time (e.g., the rate that customers switch
from fossil-fuel to electric appliances or cars, or how the economy activities may shift over
time). The resulting subsector estimates of energy demand are time-varying, meaning that they
include hourly estimates of energy demand for a set of representative days. Next, modelers
input the hourly and yearly demand estimates into the RIO model, which determines the “best”
set of new and existing energy supplies to meet demand in each geographic area. The choices
are constrained by things like emissions limits, operational constraints (e.g., the need to
balance supply and demand in real time), resource scarcity (e.g., biomass), or policy (e.g., a ban
on nuclear energy). The result is a least-cost pathway--an energy investment “plan” – under the
assumptions and constraints applied.
Past decarbonization models have found that reaching net-zero nationwide and in California by
2045 can be done at manageable cost. In their national-level model, Williams et al. (2021)1
estimate that net costs of decarbonization would fall between 0.4% and 0.9% of GDP,
depending on the scenario, compared to a historical range of total US spending on energy
between 5.5%-13% of GDP from 1970 to the present. The geographic distribution of these costs
is not modeled at a high resolution, and so we do not present total decarbonization costs for
the San Diego region in the RDF. However, it should be noted that higher costs in a particular
geographic region are not necessarily a negative, as they imply greater investment, growth in
local industry and employment, and new infrastructure.
These system-level decarbonization pathways provide a useful guide for the detailed, sector-
level pathways laid out in the remainder of the RDF. No individual pathway should be treated as
a plan because the underlying assumptions are too uncertain. However, by applying several
different sets of assumptions and constraints--scenarios--to generate several different least-
cost pathways, modelers get a sense of which types of energy supply investments are most
robust, or chosen as “best” in most circumstances. This gives policymakers a common general
direction, at least initially, helping to alleviate policy gridlock, prevent conflicting approaches,
and eliminate dead-end strategies.
Oct. 11, 2022 Item #12 Page 497 of 560
459
A.2 Scenario Descriptions
A set of five scenarios were modeled to help inform the RDF. First, a reference, or “baseline,”
scenario that does not enforce emissions constraints was run for comparison purposes. From
there, the other four scenarios explore sensitivity to different uncertainties in behavior, societal
preference, and technology development. These were chosen to reflect the broad debates
happening around climate policy and human behavior at the state level, and reflect a wide
range of plausible futures. The Central scenario meets reference energy service demand with
high demand-side uptake of electric, efficient technologies and with all energy-supply
technology options available. The Low Demand scenario uses assumptions from Williams et al.
(2021) to examine the implication of higher energy conservation on mitigating emissions from
the energy system. The Electrification Delay introduces a 20-year lag in the speed at which
customers adopt electric technologies. Finally, the No Sequestration scenario disallows geologic
storage of CO2 and subsequently emphasizes drop-in use of clean fuels, rather than continued
use of fossil fuels with captured carbon offsetting those emissions. This scenario reflects that,
while technical potential exists for geologic storage of carbon in California, political, regulatory,
and economic barriers may prevent this from becoming a reality. A summary of the inputs used
across each of the five scenarios is provided in Table A1.
Oct. 11, 2022 Item #12 Page 498 of 560
460
Table A1. Input summary for each of the five macro-energy scenarios analyzed in the EnergyPATHWAYS and RIO
models.
Oct. 11, 2022 Item #12 Page 499 of 560
461
A.3 Model Implications and Supplementary Results
Some relevant results from the EER state-level energy system modeling are shown below in
Figures A2-A10. Across the scenarios modeled, several broad themes emerge that inform the
detailed sector-level pathways for the San Diego region.
In all scenarios consistent with net zero emissions state-wide by 2045, energy end-uses must
rapidly electrify, implying dramatic reductions in the end-use of pipeline gas and gasoline fuel,
relative to the reference scenario (Figure A2). This means that, even with uncertainty around
the overall rate and extent of electrification, reaching net-zero emissions will require that
nearly all light duty vehicles and many medium and heavy-duty vehicles be electric by 2045
(Figure A7). Likewise, demand for heating and cooling in the built environment, mostly
expected to increase (Figure A6) as new buildings are constructed and temperatures rise
(Figure A5), must be met increasingly by electric devices.
The need for massive electrification drives the regional analyses of the transport and buildings
sectors. In transport, the RDF pathways outlines a need for significant efforts across
jurisdictions to rapidly increase EV adoption and the buildout of charging infrastructure. In
buildings, the RDF pathway emphasizes efforts to incentivize adoption of efficient heat pump-
based space and water heating systems in both new and existing buildings, with particular focus
on assistance for low-income residents and rental buildings.
Simultaneously, the electric sector itself must decarbonize, which in California means massive
increases in solar generation capacity and less in wind (Figure A3). This finding drives the
regional energy production pathway analysis, which identifies substantial opportunity for solar
development throughout the region.
Finally, the EER models show that, if allowed by policy, carbon sequestration will likely be
necessary to achieve net-zero emissions. The land use and natural climate solutions regional
pathway analysis broadly assumes that this will require some level of natural carbon
sequestration and identifies land use and natural climate solutions which can enhance or
increase net negative land emissions.
Oct. 11, 2022 Item #12 Page 500 of 560
462
Figure A2. Final energy demand for different fuel blends in California. Final energy demand for the No Sequestration scenario is the same as that of the Central
scenario; however, pipeline gas in the No Sequestration scenario would need to come from low carbon sources, such as drop-in fuels.
Oct. 11, 2022Item #12 Page 501 of 560
463
Figure A3. Total installed electricity capacity in California. Oct. 11, 2022Item #12 Page 502 of 560
464
Figure A4. CO2 emissions from energy and industrial processes in California. Colors above the x-axis represent positive emissions, and colors below represent
offsetting negative emissions. The black line indicates net CO2 emissions. Product and bunkered CO2 is carbon that ends up sequestered in materials (e.g.,
asphalt) or CO2 not counted in current inventories (e.g., interstate aviation). Oct. 11, 2022Item #12 Page 503 of 560
465
Figure A5. Percent change from 2020 to 2050 for some of the important drivers of energy service demand in California, where state CDD stands for cooling
degree days and HDD stands for heating degree days.Oct. 11, 2022Item #12 Page 504 of 560
466
Figure A6. California's energy service demand for the largest energy consuming subsectors for the Reference and
Low Demand scenarios. Scenarios not pictured have the same energy service demands as the reference case.
Oct. 11, 2022 Item #12 Page 505 of 560
467
Figure A7. Vehicle sales shares and resulting stocks in California Oct. 11, 2022Item #12 Page 506 of 560
468
Figure A8. California 2050 electricity consumption and supply. Fuel conversion loads include both electric boilers and electrolysis. Oct. 11, 2022Item #12 Page 507 of 560
469
Figure A9. Transmission tie capacity from Northern and Southern California to surrounding zones.
Oct. 11, 2022Item #12 Page 508 of 560
470
Figure A10. Capture and utilization of CO2 in California for net-zero scenarios. Oct. 11, 2022Item #12 Page 509 of 560
471
A.4 Limitations
While the EER modeling offers several robust insights about where decarbonization pathways
should begin--massive electrification and renewable deployment--uncertainty makes it
impossible to perfectly model the optimal trajectory, and some questions remain without a
robust answer.
One important area of uncertainty not fully addressed by this modeling exercise is reliability.
Electrification of end uses means greater reliance on the power grid to provide vital energy
services, and large increases of intermittent renewable resources on the grid imply possibly
large changes in energy system reliability over the course of the transition. While EER models
do include grid structure and some temporal granularity, they plan for system reliability only 2-
5 years into the future, rather than over the whole 25-30 years modeled. Thus, model results
on the quantity of energy supply resources at the end of the modeling period (eg. X MW in
2050) should be understood as directional, rather than precise measurements.
Also, regional level costs—both demand and supply-side—reported by the EER model are
subject to significant uncertainty. These models are meant to estimate costs over broad
geographic areas, and do not produce detailed outlines of the geographic distribution of these
costs in sub-regions. The distribution of costs depends on many factors—including fuel
availability, sequestration costs, and economic and population trends, among other—which are
very difficult to estimate over time at a high spatial resolution. For this reason, regional
analyses have treated EER model cost estimates for zones (like Southern California) as broad
approximations and have not been precisely reported here in this Appendix.
Works Cited:
1. Williams, J. H. et al. Carbon-Neutral Pathways for the United States. AGU Adv. 2, e2020AV000284 (2021).
2. Larson, E. et al. Net-Zero America: Potential Pathways, Infrastructure, and Impacts, interim report. 345 (2020).
3. SDSN. Zero Carbon Action Plan. (2020). https://www.unsdsn.org/Zero-Carbon-Action-Plan
4. Decarb America Research Initiative. Reports. https://decarbamerica.org/report/ (2021).
Oct. 11, 2022 Item #12 Page 510 of 560
472
Appendix B. Review of Authority for Local Jurisdictions
and Agencies to Influence and Regulate GHG Emissions
Joe Kaatz, Energy Policy Initiatives Center, University of San Diego School of Law
LEGAL DISCLAIMER: THE FOLLOWING IS FOR INFORMATIONAL PURPOSES ONLY. IT DOES NOT
CONSTITUTE LEGAL ADVICE NOR CREATE AN ATTORNEY-CLIENT RELATIONSHIP BETWEEN THE ENERGY
POLICY INITIATIVE CENTER (EPIC) OR UNIVERSITY OF SAN DIEGO (USD) AND ANY USER OF THE
INFORMATION. USE OF THIS INFORMATION IS AT USERS SOLE RISK AND DISCRETION. EPIC AND USD ARE
NOT LIABLE FOR ERRORS OR OMISSIONS. NO EXPRESS OR IMPLIED WARRANTEE OR GUARANTEE IS
CREATED BY THIS DOCUMENT.
Oct. 11, 2022 Item #12 Page 511 of 560
473
B.1 Introduction
EPIC reviewed constitutionally derived local jurisdiction police power, delegate authority from the state,
and federal and state preemption that may limit local authority. EPIC used this analysis to determine if
and how local jurisdictions and other agencies in the region may influence or regulate greenhouse gas
(GHG) emissions. We also identified key players, regulation, and legislation that effect local authority to
add context regarding a local jurisdiction’s ability to act on its own and in concert with others within the
San Diego region.
In general, local authority derives from both constitutionally derived police power and delegated
authority from state statutes. Constitutionally derived police power grants a broad, elastic grant of
authority to act where such action is reasonably related to a legitimate government purpose and has a
reasonable tendency to promote public health, safety, or the general welfare of the community. It is
limited by general state law and the state and federal constitutions. The full extent of local jurisdiction
police power with regards to regulating GHG emissions is unknown. Delegated authority includes,
among other things, analyzing land use environmental impacts and mitigating them, adopting more
stringent building codes, building infrastructure, or creating community choice aggregators to supply
electricity. The following will summarize local authority by decarbonization pathway.
B.1.1 Summary of Local Authority
Local jurisdiction authority to regulate GHGs is created by broad, general constitutionally derived “police
power”i or delegated authority under state or federally law. Use of police power may not conflict with
“general” law (e.g., state law) under preemption principles found in California Constitutional Article XI, §
7 or federal expressed or implied preemption under the Supremacy Clause of the U.S. Constitution.ii
State and federal preemption analysis, as well as the analysis on the full extent of local police power to
regulate GHG emissions, are factually specific with local jurisdiction authority uncertainty dependent on
the type of action.
Police power of a city or county within its own boundaries is as broad as that of the state legislature and
subject only to limitations of general law.iii Police power "is not a circumscribed prerogative, but is
elastic and, in keeping with the growth of knowledge and the belief in the popular mind of the need for
its application, capable of expansion to meet existing conditions of modern life and thereby keep pace
with the social, economic, moral, and intellectual evolution of the human race."iv Its exercise must be
both:
a) Reasonably related to a legitimate government purpose,v and
b) Have a reasonable tendency to promote the public health, morals, safety, or general welfare of
the community.vi
i Cal. Const. art. XI, § 7.
ii U.S. Const. art. VI, § 2.
iii Candid Enters., Inc. v. Grossmont Union High Sch. Dist., 39 Cal. 3d 878, 885 (1985); Birkenfeld v. City of Berkeley,
17 Cal. 3d 129, 140 (1976); Carlin v. City of Palm Springs, 14 Cal. App. 3d 706, 711 (1971).
iv Miller v. Board of Pub. Works, 195 Cal. 477, 485 (1925).
v Birkenfeld v. City of Berkeley, 17 Cal. 3d 129, 158 (1976). See Consolidated Rock Prods. Co. v. City of Los Angeles,
57 Cal. 2d 515, 522 (1962).
vi Carlin v. City of Palm Springs, 14 Cal. App. 3d 706, 711 (1971).
Oct. 11, 2022 Item #12 Page 512 of 560
474
Police power is especially well established in enacting and enforcing land use laws. City and county land
use authority does not rely on delegated general law of the state or federal government. Instead, state
and federal laws are limitations on a city’s or county’s exercise of its police power.i To this end, local
jurisdictions act with both police power and delegated authority to establish climate changes policies
and regulations to reduce GHGs in general plans (GPs), climate action plans (CAPs), zoning, transit-
oriented development regulations, carbon sequestration (including urban forestry), energy conservation
actions through green building practices and reach codes, water conservation, and solid waste
reduction. Land use authority is subject to the vested right doctrineii and Subdivision Map Actiii that
limits how a subsequent change in local law or the authority to impose conditions apply to a particular
improvement to land or a vesting tentative map for subdivisions.
Local jurisdiction police power is also subject to state preemption. Examples include the California
Energy Commission’s (CEC) authority to site and license thermal power plants of 50 megawattsiv or more
and energy storage resources of 20 MWs or more that discharge for at least two hours or more and will
deliver net peak energy by October 31, 2021.v It is notable that the Governor may curtail local land use
authority over siting and regional air quality regulation of these and other related energy resources,
including emergency backup generation, when an emergency declaration is issued for a specified time
period.vi Such declarations can suspend local and state laws by either establishing exclusive licensing
authority that preempts or by expressly suspending air quality laws, the California Environmental Quality
Act (CEQA), and the California Coastal Act (CAC). Emergency declarations may also have the effect of
limiting judicial review of such licenses.
Local land use authority is generally concurrent to, and not preempted by, air quality authority law and
regulation of air pollutants from stationary, nonvehicular source of emissions. Concurrent authority may
allow local jurisdictions to further regulate air quality under its police power.vii It should be noted that
there is no power granted to local air districts to infringe on an existing local jurisdiction’s authority over
land use (e.g., zoning).viii
Charter cities and counties act with more autonomy over governance decisions than common law cities
and counties,ix however, all local jurisdictions are controlled and subject to general state law. Of the
nineteen local governments in the San Diego region, there are eight charter citiesx and the County of
San Diego is a charter county. Notably, all cities act with a higher level of autonomy than the county
because they are voluntarily formed and perform many essential services. Charter cities also act with
i DeVita v. County of Napa, 9 Cal. 4th 763, 782 (1995); Candid Enters., Inc. v. Grossmont Union High Sch. Dist., 39
Cal. 3d 878, 885 (1985).
ii Avco Community Developers v. South Coast Reg'l Comm'n, 17 Cal. 3d 785, 791 (1976), superseded by statute as
stated in Santa Margarita Area Residents Together v. San Luis Obispo County Bd. of Supervisors, 84 Cal. 4th 221,
229 (2000).
iii See Government Code §§ 66410–66499.38; Government Code §§ 66474.2 & 66498.1(b).
iv See Public Resources Code §§ 25500 et seq.; See Public Resources Code §§ 25120 & 25123.
v See California Energy Commission Order No. 21-0908-1 (Adopted Sept. 8, 2021).
vi See Governor’s July 30, 2021 Proclamation of A State of Emergency to address energy supply and demand issues;
see U.S. Const. Amendment X; See California Emergency Services Act: Government Code §§ 8558, 8567, 8571,
8625, & 8627.
vii See Health & Safety Code §§ 39002 & 41508.
viii See Health & Safety Code §§ 40716(b) & 41015.
ix See Cal. Const. art. XI; See Government Code § 34871.
x Cities of Carlsbad, Chula Vista, Del Mar, El Cajon, Oceanside, San Diego, San Marcos, and Vista.
Oct. 11, 2022 Item #12 Page 513 of 560
475
more autonomy than common law cities under the “home rule” power to govern matters of “municipal
affairs.”i Charter counties exercise limited home rule authority.ii This power allows local laws to expand
beyond state law requirements. However, the extent of home rule authority is a legal determination
that depends on the specific charter and municipal code of individual charter jurisdiction, whether the
exercised authority is for a municipal affair, and whether the matter is of statewide concern where it is
the intent and purpose of the general laws to occupy the field to the exclusion of municipal regulation.iii
Finally, because counties are the legal subdivision of the state, the state may delegate or rescind any
delegated function of the state to a county.
Local jurisdictions also act with the authority to tax,iv issue bonds,v and impose fees, charges, and rates.vi
This authority is derived from and limited by the California Constitution and statute, including requiring
voter approval for taxes and bonds. vii
B.2 Local Authority to Decarbonize Transportation
Transportation emissions may be reduced by regulating direct (e.g., tailpipe) emissions from vehicles,
including by switching to low carbon fuels such as clean electricity, by changing land use patterns to
reduce the distances needed to be traveled (e.g., reducing VMT and/or providing alternative
transportation modes to single-occupant vehicles), and by designing communities to reduce system
inefficiencies such as those caused by transportation congestion (e.g., synchronized traffic lights). The
legal authority to regulate each type of transportation emissions is described below.
Local authority over transportation is rooted in land use authority over planning and development that
determines where residents live and work. City and county land use authority does not rely on
delegated general law of the state or federal government. Instead, state and federal laws are limitations
on a city’s or county’s exercise of its police power.viii To this end, local jurisdictions act with both police
i Cal. Const. art. XI, § 5.
ii Charter County limited “home rule” authority includes: 1) providing for lection, compensation, terms, removal,
and salary of the governing board; 2) for the election or appointment (except the sheriff, district attorney, and
assessor who must be elected), compensation, terms, and removal of all county officers; 3) for the powers and
duties of all officers; and for consolidation and segregation of county offices. It excludes additional authority over:
1) local regulations; 2) revenue-raising abilities; 3) budgetary decisions; or 4) intergovernmental relations.
iii See Cal. Const. art. XI, § 5, subd. (a).; See Jackson v. City of Los Angeles, 111 Cal. App. 4th 899 (2d Dist. 2003); See
City of Santa Clara v. Von Raesfeld, 3 Cal. 3d 239 (1970); See Baron v. City of Los Angeles, 2 Cal. 3d 535 (1970);
Dairy Belle Farms v. Brock, 97 Cal. App. 2d 146, 217 P.2d 704 (1st Dist. 1950); See Wilkes v. City and County of San
Francisco, 44 Cal. App. 2d 393, (1st Dist. 1941); See People ex rel. Scholler v. City of Long Beach, 155 Cal. 604
(1909); See Galli v. Brown, 110 Cal. App. 2d 764 (1st Dist. 1952); See Pearson v. Los Angeles County, 49 Cal. 2d 523
(1957).
iv Cal. Const. art. XIIIC, § 2(a) & (d).
v See generally Municipal Bond Act of 1901 (Government Code §§ 43600–43638) & Government Code §§ 50665.1–
50670.
vi Cal. Const. art. XI, § 7; see also Revenue Bond Act of 1941 (Government Code §§ 54300 et seq., Uniform Standby
Charge Procedure Act (Government Code §§ 54984 et seq.); Government Code § 66013; Government Code §
66014; Health & Safety Code §§ 5471 & 5473; See generally Government Code § 37112.
vii See generally Cal. Const. art. XIIIA, XIIIC, & XIIID; see Bradley-Burns Uniform Local Sales and Use Tax Law
(Revenue & Tax Code §§ 7200 et seq.).
viii DeVita v. County of Napa, 9 Cal. 4th 763, 782 (1995); Candid Enters., Inc. v. Grossmont Union High Sch. Dist., 39
Oct. 11, 2022 Item #12 Page 514 of 560
476
power and delegated authority to establish climate changes policies and regulations to reduce GHGs
from transportation in GPs, CAPs, zoning, and transit-oriented development regulations. Land use
authority is subject to the vested right doctrinei and Subdivision Map Actii that limit how a subsequent
change in local law or the authority to impose conditions apply to a particular improvement to land or a
vesting tentative map for subdivisions.
State law creates planning requirements that do not preempt local land use authority. For example,
state law directs local jurisdictions to identify and mitigate GHG emissions that are found to have
significant environmental impacts under CEQA for projects or GPs and to address infill and reduce
vehicle miles traveled (VMT) under SB 743 (Steinberg, Chapter 386, Statutes of 2013). State law also
provides CEQA streamlining benefits for implementing sustainable community strategies (SCS) to
achieve regional GHG reduction targets under SB 375 (Steinberg, Chapter 728, Statues of 2008).
However, federal and state preemption exists regarding mobile sources of emissions (e.g., vehicles).
B.2.1 Authority to Reduce VMT through Land Use Planning and Related Transportation GHG
Emissions
The following describes the mileage of public roads in San Diego County by regulating authority to
provide background on how existing authority may apply to which roads in the region. The discussion
then turns to land use planning authority and requirements.
Table B1 San Diego County Public Road Mileages and Resulting Authority
There is limited federal preemption with regards to local land use, but there may be federal preemption
for certain transportation land use actions. For example, congestion pricing and low emission zones are
local means to reduce VMT on city and county roads under existing local authority,iii but there is
potential federal preemption under the Energy Policy Conservation Act (EPCA), Clean Air Act (CAA), and
Federal Aviation Administration Authorization Act (FAAAA)iv that must be evaluated and resolved.v
Additionally, tolls on “federal-aid highways” would require compliance with Federal United States Code
section 23 related to highways and approval from the Federal Highway Administration. SANDAG
Cal. 3d 878, 885 (1985).
i Avco Community Developers v. South Coast Reg'l Comm'n, 17 Cal. 3d 785, 791 (1976), superseded by statute as
stated in Santa Margarita Area Residents Together v. San Luis Obispo County Bd. of Supervisors, 84 Cal. App. 4th
221, 229 (2000).
ii See Government Code §§ 66410–66499.38; Government Code §§ 66474.2 & 66498.1(b).
iii See Streets and Highways Code § 900 et seq. & § 1800-1967.11 et seq.
iv 49 U.S.C.A. §§ 14501(c)(1) & (c)(2)(A)
v Turner, Amy E. and Burger, Michael, "Cities Climate Law: A Legal Framework for Local Action in the U.S." (2021).
Sabin Center for Climate Change Law. p. 37: https://scholarship.law.columbia.edu/sabin_climate_change/2.
Oct. 11, 2022 Item #12 Page 515 of 560
477
operates high-occupancy toll (HOT) lanes along I-15 under this type of federal approval.i
State authority extends over state highways under Streets and Highway Code §§ 250 et seq., which
includes acquisition of land, construction of roads, and care to preserve value and utility of the road.
State law also authorizes the creation of toll bridges, roads, and ferries.ii It is unclear whether the state
may create congestion pricing or low emission zones in light of EPCA, CAA, and FAAAA preemption
issues. California is also exploring piloting a road user mileage-based fee under SB 339 (Wiener, Chapter
308, Statutes of 2021) that may offer additional means of addressing GHG emissions. Whether there is
applicability to the local level will need to be further examined.
Local governments have been granted inherent police powers under the California constitution
(California Constitution art. XI, § 7) with primary local control over local land use, including localiii and
county roads.iv The primacy of city and county’s control over land use, therefore, does not rely on
delegated general law of the state or federal government. Instead, state and federal laws act only as
minimal limitations on a city or county’s exercise of its police power.v
To this end, local jurisdictions may establish climate change policies and regulations to reduce GHGs
from transportation in GPs, CAPs, zoning, transit-oriented development regulations, or other types of
plans (e.g., Active Transport Plans). However, land use authority is subject to the vested right doctrinevi
and Subdivision Map Actvii that limit how a subsequent change in local law or the authority to impose
conditions apply to a particular improvement to land or a vesting tentative map for subdivisions. State
law directs local jurisdictions to mitigate GHG emissions that are found to have significant
environmental impacts under CEQA for projects or GPs, to address infill and reduce VMT under SB 743
(Steinberg, Chapter 386, Statutes of 2013), and to incorporate Complete Streets plansviii in major
revisions to a city or county Circulation Element that include all roadways users (e.g., pedestrians and
bicyclists). State law provides grant funding under the Active Transportation Program to mitigate the
impact of proposed transportation facilities or to enhance the environment, where such actions would
otherwise be beyond the authority of the lead agency.ix State law also creates a CEQA streamlining
benefit to implementing SCS to achieve regional GHG reduction targets under SB 375 (Steinberg,
Chapter 728, Statues of 2008). These planning requirements do not preempt local land use authority but
are instead requirements that inform land use decisions.
i See 23 U.S.C.A. § 166.
ii See Streets and Highways Code § 30000 et seq.
iii See Streets and Highways Code § 1800 et seq.
iv See Streets and Highways Code § 900 et seq.
v DeVita v County of Napa, 9 Cal. 4th 763, 782 (1995); Candid Enters., Inc. v. Grossmont Union High Sch. Dist., 39
Cal. 3d 878, 885 (1985).
vi Avco Community Developers v. South Coast Reg'l Comm'n, 17 Cal. 3d 785, 791 (1976), superseded by statute as
stated in Santa Margarita Area Residents Together v. San Luis Obispo County Bd. of Supervisors, 84 Cal. App. 4th
221, 229 (2000).
vii See Government Code §§ 66410–66499.38; Government Code §§ 66474.2 & 66498.1(b).
viii Government Code § 65302 (b)(2)(A)-(B).
ix Note: State law helps to fund Complete Street plans and other active transport activities and plans with funds
appropriated through the Active Transport Program; See SB 99 (Committee on Budget and Fiscal Review, Chapter
359, Statutes of 2013) and AB 101 (Committee on Budget, Chapter 354, Statutes of 2013); See also SANDAG Active Transportation Program Funding:
https://www.sandag.org/index.asp?classid=34&projectid=483&fuseaction=projects.detail .
Oct. 11, 2022 Item #12 Page 516 of 560
478
State and regional entity authority to preempt local land use authority is limited in terms of
transportation land use planning.i At the regional level, SANDAG is responsible for, among other things:
1) regional transportation planning, resource allocation, project development (excluding airport and
Port of San Diego services); 2) preparing a Regional Housing Needs Assessment; and 3) developing a
Regional Comprehensive Plan to integrate transportation and local land use plans. SANDAG, as the
region’s metropolitan planning organization (MPO), is required to prepare and adopt a regional
transportation plan (RTP) under federal lawii to receive federal funding. Under state law, the RTP must
include a long-range SCS per SB 375 (2008) to achieve CARB’s per capita regional GHG reduction targets
for 2020 and 2035.iii CARB’s targets call for the San Diego region to reduce GHG emissions by 15% per
capita by 2020 and 19% per capita by 2035 from a 2005 baseline.iv SANDAG’s SCS must feasibly achieve
the GHG reduction goals based on anticipated development patterns pursuant to local plans, or it must
prepare an alternative planning strategy showing how the regional targets can be met through
alternative development patterns, infrastructure, or additional transportation measures or policies.v
CARB must approve SCS or an alternative development plan to determine if the relevant plan would
achieve the regional emission reduction target. SANDAG submitted and received approval of its most
recent RTP for federal funding purposes in 2019. SANDAG is currently developing a 2050 Regional Plan
that combines the RTP, the SCS, and a Regional Comprehensive Plan and which aligns the region’s
transportation, housing, and land use around CARB GHG reduction targets. These CARB GHG reduction
targets from the RTP are also required to be addressed in SANDAG’s 2050 Regional Plan, recently
adopted on December 10, 2021, and the Regional Plan must include strategies that provide for mode
shift to public transit per AB 805 (Gonzalez Fletcher, Chapter 658, Statutes of 2017).
Notably, the SCS expressly does not regulate land use decisions nor create state approval authority for
local land use decisions, including consistency between the RTP and GPs, or abrogating any existing
vested right created by statute or common law.vi The primary way that the SCS impacts land use
development is through CEQA streamlining. If CARB approves the SCS, then that approved SCS may
serve as the basis for CEQA streamlining of certain residential, transit priority (including residential), and
infill projects that are consistent with the SCS.vii
SB 743 (2013) required the Governor’s Office of Planning and Research to create criteria for determining
the significance of transportation impacts of projects within and outside of transit priority areas that
better align with California’s GHG goals.viii The Governor’s Office of Planning and Research (OPR)
amended the CEQA Guidelines to require VMT impacts of projects as the criteria to measure
transportation environmental impacts starting on July 1, 2020. Lead agencies still exercise discretionary
i See Streets and Highways Code § 50 et seq.
ii 42 U.S.C. § 7506(c); 49 U.S.C. § 5303; 23 C.F.R. Parts 450 & 771; 49 C.F.R. Part 613.
iii See Government Code § 65080.
iv See California Resources Board (CARB) SB 375 Regional Plan Climate Targets by MPO:
https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-program/regional-plan-targets ; Note: Per
capita GHG emissions include all wells-to-wheels emissions per Appendix F, Final Environmental Analysis, Prepared
for the Proposed Update to SB 375 GHG Emissions Reduction Targets (May 9, 2018), p. 69:
https://ww2.arb.ca.gov/sites/default/files/2020-06/SB375_Final_Target_Staff_Report_%202018_AppendixF.pdf.
v Government Code § 65080(b)(2)(B).
vi Government Code § 65080(b)(2)(K).
vii See Public Resources Code §§ 21155.1, 21094.5, 21159.28, CEQA Guidelines § 15183.3, CEQA Guidelines
Appendixes M and N; see also SB 743 (Steinberg, Chapter 386, Statutes of 2013) and Public Resources Code § 21155.4.
viii Public Resources Code § 21099(b).
Oct. 11, 2022 Item #12 Page 517 of 560
479
authority over which VMT methods to adopt and how to implement the chosen methodology by project
type (e.g., residential, commercial, industrial, etc.).i The methodology chosen affects which projects are
either exempt or are found to be above or below the environmental impact threshold of significance.
This determines directly which projects require transportation impact GHG mitigation and may allow a
local jurisdiction to prioritize infill and transit-oriented projects.
Under CEQA, local jurisdictions as lead agencies act with discretion in determining thresholds of
significance to evaluate significant environmental impacts and consequent mitigation from
transportation.ii This may include adopting specific GHG thresholds of significance for the specific
jurisdiction, using compliance with California climate policy such as AB 32 (Núñez, Chapter 488, Statutes
of 2006) to determine a threshold of significance, or adopting an air pollution control district
recommended threshold for transportation GHG emission.iii The threshold of significant controls impact
analysis and mitigation and drives the use of overriding considerations where impacts cannot be
mitigated below the threshold of significance or where mitigation is infeasible.
Recently, the Bay Area Air Quality Management District. (BAAQMD) adopted the following thresholds of
significance for both land use projects and land use development plans that lead agency may voluntary
adopt:
Land Use Project (Must Include A or B):
A. Project must include, at a minimum, the following design elements:
a) Buildings
i) The project will not include natural gas appliances or natural gas plumbing (in both
residential and nonresidential development).
ii) The project will not result in any wasteful, inefficient, or unnecessary energy usage as
determined by the analysis required under CEQA Section 21100(b)(3) and Section
15126.2(b) of the State CEQA Guidelines
b) Transportation
i) Achieve a reduction in project-generated vehicle miles traveled (VMT) below the
regional average consistent with the current version of the California Climate Change
Scoping Plan 9currenlty 15 percent) or meet a locally adopted Senate Bill 743 VMT
target, reflecting the recommendations provided in the Governor’s Office of Planning
and Research’s Technical Advisory on Evaluating Transportation Impacts in CEQA:
(1) Residential projects: 15 percent below the existing VMT per capita
(2) Office projects: 15 percent below the existing VMT per employee
(3) Retail projects: no net increase in existing VMT
ii) Achieve compliance with off-street electric vehicle requirements in the most recently
adopted version of CALGreen Tier 2.
B. Projects must be consistent with a local GHG reduction strategy that meets the criteria under
State CEQA Guidelines Section 15183.5(b)
Land-use Development Plans (Must include A or B):
A. Meet the State’s goals to reduce emissions to 40 percent below 1990 levels by 2030 and carbon
neutrality by 2045; or
i See Governor’s Office of Planning and Research: Transportation Impacts SB 743 (Last visited on October 28,
2021): https://opr.ca.gov/ceqa/sb-743/. ii See 14 C.C.R. § 15064.4.
iii See Center for Biological Diversity v. Department of Fish & Wildlife, 62 Cal. 4th 204, 230 (2015).
Oct. 11, 2022 Item #12 Page 518 of 560
480
B. Be consistent with a local GHG reduction strategy that meets the criteria under State CEQA
Guidelines Section 15183.5(b).i
BAAQMD is further developing guidance around these thresholds and will also return to its board in late
2022 with any recommendations on thresholds of significance for climate impacts from stationary
sources upon completing additional evaluation.
B.2.2 Air District Indirect Emissions and Local Jurisdiction Concurrent Authority
Stationary source direct air pollution is controlled by federal CAA and California air quality laws. Local
land use authority is not preemptive by and is generally concurrent to air quality authority statutes and
regulations that are used by the San Diego County Air Pollution Control District (SD APCD) to regulate
indirect transportation air pollutants from a stationary, nonvehicular source of emissions (e.g.,
transportation emissions related to buildings). Concurrent authority may allow a local jurisdiction to
further regulate air quality under its police power,ii although local jurisdictions would need to develop
internal technical expertise by hiring staff and avoid state and federal preemption. It should be noted
that there is no statutory power granted to SD APCD to infringe on the existing local government
authority over land use with regards to air quality regulation (e.g., zoning).iii
The SD APCD is expressly authorized to “consider indirect source rule to address pollution from mobile
sources that is associated with stationary sources, such as ports, warehouses, and distribution
centers,”iv but has not done so to date but may do so in the future. The SD APCD may also regulate
indirect emissions from transportation to reduce emissions from transportation and areawide emission
sources to achieve and maintain state ambient air quality standards.v This allows regulation of direct and
indirect emissions sources, including large office buildings and large residential and commercial
developments. In certain instances, a permit may be required to carry out activities that emit air
containment or pollutants. However, there is uncertainty over jurisdiction and how to interpret this
authority for indirect emission.vi Additionally, existing authority is used by other air districts to create a
voluntary GHG reduction credit generation and certification program to help address emissions of this
type. Examples exist of creating a voluntary program for transportation emissions reductions at this time
that may be applicable to the SD APCD (see Section 4.1 below).vii
i Bay Area Air Quality Management District CEQA Threshold for Evaluating the Significance of Climate Impacts from
Land Use Projects and Plans, Board of Directors Meeting Agenda Item 15 (Adopted April 20, 2022), p. 152–221:
https://www.baaqmd.gov/~/media/files/board-of-directors/2022/bod_agenda_042022_op_rv-
pdf.pdf?la=en&rev=c8360ec141654c22b244e5e07f8b88b4.
ii See Health & Safety Code §§ 39002, 39037, & 41508.
iii See Health & Safety Code §§ 40716(b) & 41015.
iv See Health & Safety Code § 40100.6.5.
v Health & Safety Code §§ 40910, 40716–40717.
vi Health & Safety Code §§ 42300–42339; See Health & Safety Code §§ 40716(b) & 41015 (sometimes interpreted
as not prohibiting parallel permitting systems for indirect sources); See 76 Ops Call Atty Gen 11 (1993) (Attorney
General opinion that authority of an APCD or AQMD does not extend to requiring permits for indirect sources;
Note: Attorney General opinions are nonbinding).
vii See Sacramento Metropolitan AQMD Rule 206 Mobile and Transportation Source Emission Reduction Credits
(Adopted December 15, 1992; Amended December 5, 1996):
http://www.airquality.org/ProgramCoordination/Documents/rule206.pdf.
Oct. 11, 2022 Item #12 Page 519 of 560
481
Air pollution control district authority exists to address indirect emissions subject to expressed limits.
Health and Safety Code §§ 40716 and 40717 authorizes regulations to reduce VMT and allows the
enforcement of transportation control measures in non-attainment areas by SD APCD and SANDAG.
Health and Safety Code section 40918 allows for regulation where there is moderate air pollution. This
may include transportation control measures to reduce VMT, area wide source control programs, and
indirect source control programs.
In this respect, ozone (O3) is the only air pollutant with nonattainment status in the San Diego region
directly regulated at the local level.i Regional O3 is now considered severe as of July 2, 2021, under the
2015 Eight-Hour Ozone National Ambient Air Quality Standards (NAAQS) by U.S. EPA. Under the
previous moderate designation, the currentii and previousiii Regional Transportation Plan and SD APCD
Plan for Attaining Air Quality Standards of Ozone in San Diego County showed implementation
surpassed for transportation control measures and indirect regulation of O3 with all actions and
measures implemented.iv It is possible that this may be updated to address the recent severe
nonattainment designation that now sets August 3, 2033, as the new attainment date.
The following is a non-exhaustive list of additional restrictions on SD APCD and local jurisdiction
authority with regards to transportation emissions:
• SD APCD is prohibited from requiring an employee trip reduction program unless required by
federal law;v
• SD APCD and regional and local jurisdictions are generally prohibited from requiring that private
parties impose parking charges, restrict parking, or impose measures to reduce retail shopping
trips;vi
• SD APCD or its delegate is limited in imposing transport control measures on event centers;vii
• SD APCD is prohibited from adopting new or more stringent control measures with respect to
pollutants where standards have not been violated unless it prepares an analysis of the costs and
benefits of achieving attainment;viii and
• SD APCD is prohibited from adopting or enforcing a regulation requiring fleet operators to purchase
or lease only those vehicles that meet state motor vehicle pollutant standards,ix but under its
i Note: Nonattainment exists in the region for PM2.5 and PM 10 under 17 C.C.R. §§ 60205 & 60210, but these are
directly regulated by CARB with some local enforcement implemented by SD APCD; See SD APCD’s Mobile Source
Program: https://www.sdapcd.org/content/sdapcd/compliance/compliance-requirements/mobile-source-
program.html.
ii SANDAG San Diego Forward, Federal Regional Transportation Plan, Appendix B Air Quality Planning and
Transportation Conformity), p. 22 (Adopted October 25, 2019 by SANDAG: Adopted November 15, 2019 by U.S.
DOT: https://sdforward.com/docs/default-source/2019federalrtp/draftfinal/app-b---air-quality-planning-and-
transportation-conformity.pdf?sfvrsn=1a47ff65_2.
iii SANDAG Federal Regional Transportation Plan for 2050, Appendix B Air Quality Planning and Transportation
Conformity (2011), p. B-16.
iv SD APCD Plan for Attaining National Air Quality Standards for Ozone in San Diego County, Attachment H (October
2020), p. H-1 (p.338):
https://www.sdapcd.org/content/dam/sdapcd/documents/grants/planning/Att%20A%20(Attainment%20Plan)_ws
.pdf.
v Health & Safety Code § 40717.9 (a).
vi Health & Safety Code § 40717.6.
vii Health & Safety Code § 40717.8.
viii Health & Safety Code § 40930.
ix See Engine Mfrs. Ass'n v. South Coast Air Quality Mgmt. Dist., 541 U.S. 246 (2004).
Oct. 11, 2022 Item #12 Page 520 of 560
482
authority to regulate indirect sources of air pollution may regulate emissions from groups of non-
road construction equipment at development sites (Note: non-road construction equipment is
included as “off-road” emissions in regional and local GHG inventories).i
B.2.3 Legal Authority to Regulate Direct Emissions from Vehicles
Federal and state law and regulation preempt local jurisdictions from regulating GHG emissions directly
from on-road and off-road mobile sources. The federal Energy Policy & Conservation Act (EPCA)
preempts California or a local jurisdiction from setting fuel economy standards or average fuel economy
standards for automobiles.ii Several federal courts have held that local jurisdictions are preempted
under the EPCA from requiring clean energy technology for certain classes of vehicles (e.g., hybrid
taxis).iii Direct tailpipe GHG emissions are also regulated by the U.S. EPA under the CAA Section 202.iv
U.S. EPA and Department of Transportation (DOT) National Highway Transportation Safety
Administration (NHTSA) act with concurrent jurisdiction to regulate GHGs and fuel economy standards
for light-duty and heavy-duty vehicles under the CAA.
Through this concurrent jurisdiction, the U.S. EPA and NHTSA have promulgated fuel economy standards
with GHG tailpipe emissions standards for specified model years. Consequently, federal preemption
exists under NHTSA's Corporate Average Fuel Economy (CAFE)v standards for passenger cars and light-
duty truck models (model years 2017–2021 and 2021–2026vi), medium-duty vehicles (model years
2014–2018), and heavy-duty vehicles (model years 2014–2018vii and 2018–2027 (currently stayed and
pending proposal to withdrawviii)).
California uses delegated federal authority to enforce more stringent emission standards under its
California State Implementation Plan (SIP) for new vehicles using the CAA Section 209 waiver provision.
California, through CARB, regulates light-duty vehicles under the Advanced Clean Cars (ACC) program
i See National Ass'n of Home Builders v. San Joaquin Valley Unified Air Pollution Control Dist., 627 F.3d 730 (9th Cir
2010).
ii 49 U.S.C.A § 32919(a).
iii Metro. Taxicab Bd. of Trade v. City of New York, 615 F.3d 152, 157 (2d Cir. 2010), cert. denied, 562 U.S. 1264
(2011); Ophir v. City of Boston, 647 F.Supp. 2d 86, 94 (D. Mass. 2009).
iv See Revised 2023 and Later Model Year Light Duty Vehicle Greenhouse Gas Emission Standards (Model Years
2023–2024), Final Rule Docket No. EPA-HQ-OAR-2021-0208, 40 C.F.R Part 19, 86, 523, 600, 1066, & 1867:
https://www.epa.gov/regulations-emissions-vehicles-and-engines/final-rule-revise-existing-national-ghg-
emissions.
v See NHTSA: Corporate Average Fuel Economy (Last visited October 29, 2021): https://www.nhtsa.gov/laws-
regulations/corporate-average-fuel-economy.
vi 40 CFR Parts 531, 531.5(d) and 533; Note: NHTSA proposed new CAFE rules for model years 2024–2026 on
August 10, 2021: DOT, NHTSA, 49 CFR Parts 531, 533, 536, and 537, Docket No. NHTSA-2021-0053, RIN 2127-
AM34, Proposed Rulemaking: https://www.govinfo.gov/content/pkg/FR-2021-09-03/pdf/2021-17496.pdf.
vii 40 CFR Parts 85, 86, 600, 1033, 1036, 1037, 1039, 1065, 1066, and 1068 (U.S. EPA) and 40 CFR Parts 523, 534,
and 535 (NHTSA); partially withdrawn in 2013 under 40 CFR Part 1037, 1039, 1042, and 1068 (U.S. EPA) and 40 CFR
Parts 535 (NHTSA).
viii See Final Rule for Phase 2 fuel efficiency and GHG emissions standards for medium-& heavy-duty vehicles,
MY2018–2027 is currently stayed pursuant to an order of the United States Court of Appeals for the District of
Columbia Circuit issued on September 29, 2020 in Case No. 16-1430; NHTSA proposed to repeal the stayed SAFE I
rule on April 22, 2021: DOT, NHTSA, 49 CFR Parts 531 and 533, Docket No. NHTSA-2021-0030, RIN 21217-AM33, CAFE Preemption, Notice of Proposed Rule Making: https://www.nhtsa.gov/sites/nhtsa.gov/files/2021-
04/cafe_preemption_nprm_04222021_1_0.pdf.
Oct. 11, 2022 Item #12 Page 521 of 560
483
with recent action including adopting GHG standards for models years 2022–2025, requiring zero
emission vehicles (ZEV) be developed and sold by manufacturers, developing regulations for model
years 2026 and beyond (Advanced Clean Cars IIi and LEV IV), and enforcing particulate matter
standards.ii CARB approved its funding plan for the Fiscal Year 2021–2022 on November 19, 2021;
allocating $675 million to light-duty related incentives, including $150 million for equity programs (see
programs below). Notably, the CAA preempts the SD APCD from adopting or enforcing any state or local
standard relating to the control of emissions from new motor vehicles or motor vehicle engines.iii
It is unclear whether local jurisdiction police power or delegated permit, fees, rules, and regulations
under California Public Utilities Code § 5371.4 (f)–(g) related to city and counties may allow for the
acceleration of the reduction targets and goals for transportation network companies (TNCs). TNCs are
regulated under SB 1014 (Skinner, Chapter 269, Statutes of 2018), with CARB mandated to establish
GHG emission reduction targets, goals, and baselines that are then implemented by the California Public
Utilities Commission (CPUC) to reduce GHG emission per passenger-mile starting in 2023 as part of the
CPUC’s regulation of TNCs as charter-party carriers.iv Additionally, the San Diego County Regional Airport
Authority (SDCRAA) is authorized by the CPUC to directly regulate TNCs at its airports, which may allow
further regulation of GHG emissions from TNC related trips either through these rules,v its Clean Vehicle
Conversion Incentive Program,vi or through its local police and land use authorityvii related to
environmental impacts for current and future construction, which is subject to federal preemption over
airport operations and review under National Environmental Protection Act (NEPA).viii
In terms of medium- and heavy-duty vehicles, there are a wide range of regulations for on-road vehicles
that include prohibitions on diesel idling for heavy-duty long haul trucksix and school buses,x the LEV III
i See CARB Public Workshop on Advanced Clean Cars II, Draft Regulatory Language for ACC II (October 13, 2021).
ii See Low-Emission Vehicle (LEV) Regulation, LEV III Criteria & LEV III GHG, ZEV Regulation, and ACC II & LEV IV; see
13 California Code of Regulations (C.C.R.) § 1360 et seq.
iii 42 U.S.C.A. § 7543 (a); Engine Mfrs. Ass'n v. South Coast Air Quality Mgmt. Dist., 541 U.S. 246 (2004).
iv See Cal. Const. art. XII; See California Passenger Charter-party Carriers’ Act (California Public Utilities Code §§
5351 et seq.); See California Public Utilities Commission Rulemaking R.12-12-011 & Decision D.13-09-045, Order
Instituting Rulemaking on Regulations Relating to Passenger Carriers, Ridesharing, and New Online-Enabled
Transportation Services (2013); See California Public Utilities Commission General Order 157-E (Effective October
31, 2019): https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M322/K150/322150628.pdf.
v California Public Utilities Commission D.13-09-045, Decision Adopting Rules and Regulation to Protect Public
Safety While Allowing New Entrants To the Transportation Industry (September 23, 2013), p. 33:
https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M077/K192/77192335.PDF; See San Diego County
Regional Airport Authority (SDCRAA) Rules and Regulations, V7.0, § 5.4 (July 2019):
https://www.san.org/DesktopModules/Bring2mind/DMX/API/Entries/Download?EntryId=7364&Command=Core_
Download&language=en-US&PortalId=0&TabId=585.
vi See SDCRAA Clean Transportation Plan (July 2020), p. 28 & 47:
https://www.san.org/Portals/0/Documents/Environmental/2020-Plans/2020_Clean-Transportation-Plan-min.pdf.
vii See SDCRAA Carbon Neutrality Plan (July 2020), p. 51.
viii See U.S. Department of Transportation Federal Aviation Administration, Western-Pacific Region, Finding of No
Significant Impact and Record of Decision, Proposed Airfield Improvements and Terminal 1 Replacement Project,
San Diego International Airport, San Diego, San Diego County, California (October 21, 2021), p. 8:
https://www.san.org/DesktopModules/Bring2mind/DMX/API/Entries/Download?Command=Core_Download&Ent
ryId=14744&language=en-US&PortalId=0&TabId=225.
ix 13 C.C.R. § 2485.
x 13 C.C.R. § 2480.
Oct. 11, 2022 Item #12 Page 522 of 560
484
standards as part of the ACC program,i GHG emission control through Phase 1 and Phase 2 GHG
standards,ii the Advanced Clean Trucks regulation,iii Truck and Bus Regulation,iv Tractor-Trailer
Greenhouse Gas (TTGGH) regulation, the Heavy-Duty Omnibus Regulation,v and other regulations
specific to class or use case.vi These regulations will continue to change to address the executive orders
and to more directly regulate GHG emissions out to 2035. CARB approved its funding plan for the Fiscal
Year 2021–2022 on November 19, 2021; allocating $678.14 million to heavy-duty related incentive
programs (see more detail on these programs below).
Regulation of non-road and off-road engines includes both regulations from U.S. EPA and CARB applied
to specific types and uses of vehicles and engines (Note: off-road is omitted from the policy opportunity
section of Chapter 8). Notably, most of these regulations do not address GHG emissions directly or
regulate GHG emissions indirectly by regulating other pollutants. Zero emission technology also may not
be feasible for off-road engines leaving combustion standards as the best means to reduce emissions.
CARB approved its funding plan for the Fiscal Year 2021–2022 on November 19, 2021, allocating
specifically $194.5 million to the Clean Off-Road Equipment Vouchers (CORE) program with additional
supports of these regulations by other allocations to heavy-duty vehicle programs.
Local authority may exist to regulate certain small off-road engines, but further research is required.
Existing regulations apply to small off-road engines (excluding engines under 25 horsepower (hp)),vii off-
highway recreational vehicles and engines,viii off-road compression-ignition engines and equipment,ix SIP
credit for mobile agricultural equipment in the San Joaquin Valley APCD,x off-road large spark-ignition
engines,xi spark-ignition marine engines,xii in-use off-road diesel-fueled fleets (Tier 4 regulationsxiii (U.S.
EPA preempts emission standards for new farm and construction equipment with engines less than 175
HP (130 kW)xiv)) with Tier 5 regulation stakeholder engagement proposals just introducedxv), portable
i 13 C.C.R. § 1956.8.
ii 13 C.C.R. §§ 1963 et. seq.
iii See Truck and Bus Regulation information: https://ww2.arb.ca.gov/our-work/programs/truck-and-bus-
regulation.
iv See TTGHG Regulation Information: https://ww2.arb.ca.gov/our-work/programs/ttghg.
v See Heavy-Duty OBD Regulation and Rulemaking: https://ww2.arb.ca.gov/resources/documents/heavy-duty-obd-
regulations-and-rulemaking.
vi See Zero-Emission Transport Refrigeration Units Regulation: 13 C.C.R §§ 2477.1–2477.6; 13 C.C.R § 2477.13; 13
C.C.R §§ 2477.17–2477.19; see Zero-Emission Powertrain Certification Regulation: 13 C.C.R § 1956.8; see Zero-
Emission Drayage Truck Regulation: 13 C.C.R § 2027.
vii 13 C.C.R. §§ 2400–2409.
viii 13 C.C.R. §§ 2410–2419.4.
ix 13 C.C.R. §§ 2420–2427.
x 13 C.C.R. §§ 2428.
xi 13 C.C.R. §§ 2430–2439.
xii 13 C.C.R. §§ 2440–2448.
xiii 13 C.C.R. §§ 2449–2449.3 & Appendix A; See also CARB Non-Road Diesel Engine Certification Tier Chart (Last
accessed on November 1, 2021): https://ww2.arb.ca.gov/resources/documents/non-road-diesel-engine-
certification-tier-chart?utm_medium=email&utm_source=govdelivery.
xiv See SORE – List to Determine Preempt Off-Road Applications (Last accessed November 1, 2021):
https://ww2.arb.ca.gov/sore-list-determine-preempt-road-applications.
xv See CARB, Potential Amendments to the Diesel Engine Off-Road Emission Standards: Tier 5 Criterial Pollutants
and CO2 Standards (last access on November 1, 2021): https://ww2.arb.ca.gov/our-work/programs/tier5?utm_medium=email&utm_source=govdelivery; see CARB November 3, 2021 Workshop to
Discuss Potential Amendments to the Diesel Engine Off-Road Emission Standards: Tier 5 Criterial Pollutants and
Oct. 11, 2022 Item #12 Page 523 of 560
485
engine and equipmenti (including fuel containers and spoutsii), portable outboard marine tanks and
componentsiii, aftermarket off-road parts certification proceduresiv, and off-road airborne toxic control
measures for in-use diesel-fueled transport refrigeration units (TRU) and TRU generator sets (including
facilities where TRUs operate).v Additional off-road regulations include evaporative emission
requirements for off-road equipmentvi, large spark-ignition (LSI) engine fleet requirements,vii regulation
of retrofits to control emission from off-road large spark-ignition engines,viii and evaporative emission
requirements for spark-ignition marine watercraft with gasoline-fueled engines.ix There are certain
engine sizes and types that are not regulated, such as small off-road engines under 25 hp, that may be
regulated by a local jurisdiction. It is uncertain as to whether a local jurisdiction may regulate these
types of engines and vehicles for GHG purposes where emissions are regulated for criteria pollutants
and airborne toxins.
California continues to invest heavily in reducing emissions from all transportation sources through its
state agencies and programs, particularly CARB and the CEC. Aligning local actions and policies with
state policy and funding may accelerate local implementation and decrease costs. It is unclear how
much previous or future funding has been or will be received by the San Diego region, but increasing
funding from these sources should be a priority. The region will compete for these funds as most if not
all, funds are administered through a competitive bidding process.
CARB administered Air Quality Improvement Program (AQIP) funded $438 million in projects from Fiscal
Year 2008–2009 through Fiscal Year 2019–2020 and the Low Carbon Transportation Project allocation
from Fiscal Year 2013–2014 through Fiscal Year 2019–2020 totals $2.134 billion.x The State Budget Year
for Fiscal Year 2021–22, including over $1.5 billion for a ZEV Acceleration Package and Air Quality
Improvement Program, received an appropriation of over $1.5 billion for CARB with an additional $3.9
billion over the next three fiscal years across all state agencies (CARB expects to receive $2.3 billion of
this over the next three fiscal years).xi CARB’s approved the following funding plan for Fiscal Year 2021–
2022 on November 19, 2021, for a total of $1,548.09 million allocated in the following ways:
• $525 million for Vehicle Purchase Incentives (Light-duty Clean Vehicle Rebate Project (CVRP) and
Electric Bicycles);
CO2 Standards (last access on November 1, 2021): https://ww2.arb.ca.gov/our-work/programs/tier-5/meetings-
workshops?utm_medium=email&utm_source=govdelivery.
i 13 C.C.R. §§ 2540–2466.
ii 13 C.C.R. §§ 2467–2467.9.
iii 13 C.C.R. §§ 2468–2468.10.
iv 13 C.C.R. §§ 2470–2476.
v 13 C.C.R. §§ 2477–2479.
vi 13 C.C.R. §§ 2750–2774.
vii 13 C.C.R. §§ 2775–2775.2.
viii 13 C.C.R. §§ 2780-2789.
ix See 13 C.C.R. §§ 2850–2869.
x CARB Proposed Fiscal Year 2020–21 Funding Plan for Clean Transportation Incentives (Release Date: November 6,
2020; Board Consideration: December 10–11, 2020), p. 5–8: https://ww2.arb.ca.gov/sites/default/files/2020-
11/proposed_fy2020-21_fundingplan.pdf .
xi CARB, Proposed Fiscal Year 2021–22 Funding Plan for Clean Transportation Incentives (October 8, 2021 Release)
(Board Vote on November 19, 2021), p. 4: https://ww2.arb.ca.gov/sites/default/files/2021-10/fy21-
22_fundingplan.pdf.
Oct. 11, 2022 Item #12 Page 524 of 560
486
• $150 million for Clean Transportation Equity Investments (includes Clean Cars 4 All, Financing
Assistance, Clean Mobility Options, Clean Mobility In Schools Pilot Project, Sustainable
Transportation Equity Project (STEP), and others);
• $873.09 million for Heavy-Duty and Off-Road Equipment (including Clean Truck and Bus Vouchers
(HVIP), Clean Off-Road Equipment Vouchers (CORE), Drayage Truck and Infrastructure Project,
Truck Loan Assistance, and Demonstration and Pilot Projects).i
The CEC currently administers the $100 million per year Clean Transportation Fund (formerly the
Alternative and Renewable Fueled and Vehicle Technology Program) created by AB 118 (Núñez, Chapter
759, Statutes of 2007) and reauthorized by AB 8 (Perea, Chapter 401, Statutes of 2013). This program
received additional funding this fiscal year with the CEC approving a 2021–2023 Investment Plan Update
totaling $1.4 billion on November 15, 2021.ii In terms of vehicle-related investment, the plan will fund
$244 million for ZEV manufacturing that complements CARB administered funding. It sunsets in January
2024.
B.2.4 Fuels and Infrastructure
State preemption exists in the form of the CARB administered Low-Carbon Fuel Standard (LCFS), which
regulates the carbon intensity of transportation fuels in California by reducing the carbon intensity of
fuel by at least 20% by 2030 from a 2010 baselineiii and requires continuing to reduce the carbon
intensity of fuels beyond 2030 with consideration of the full life cycle of carbon.iv State preemption also
exists in the form of what types of reformed fuels are sold in California, including the Low Emission
Diesel and Standards for Diesel Fuel regulations.v California’s Alternative Diesel Fuel regulation governs
the development and commercialization of alternative diesel fuels for sale in California.vi Notably, the
CPUC does not automatically regulate compressed natural gas and hydrogen fueling stationsvii but acts
with regulatory authority over intrastate pipelines for natural gas and hydrogen with authority over
entities that meet the public utility definition. There is uncertainty as to whether the Federal Energy
Regulatory Commission (FERC) acts with authority over interstate hydrogen pipelines under the Natural
Gas Act specific to whether hydrogen is considered an “artificial gas” and whether, and at what
percentage, hydrogen is mixed with natural gas.viii
In terms of fuels, local jurisdictions may exercise police and land use authority to prohibit zoning for new
i CARB, Proposed Fiscal Year 2021–22 Funding Plan for Clean Transportation Incentives (Release Date: October 8,
2021; Board Consideration: November 19, 2021), p. 27: https://ww2.arb.ca.gov/sites/default/files/2021-10/fy21-
22_fundingplan.pdf; CARB approves $1.5 billion investment — largest to date — in clean cars, trucks, mobility
options, Press Release, Release No. 21-57 (November 19, 2021): https://ww2.arb.ca.gov/news/carb-approves-15-
billion-investment-largest-date-clean-cars-trucks-mobility-options.
ii CEC Lead Commissioner Report, 2021–2023 Investment Plan Updated for the Clean Transportation Program, CEC-
600-2021-038-LCF (November 2021): https://www.energy.ca.gov/publications/2021/2021-2023-investment-plan-
update-clean-transportation-program.
iii See 17 C.C.R. §§ 95480–95503.
iv Executive Order N-79-20, Order No. 9 (September 23, 2020): https://www.gov.ca.gov/wp-
content/uploads/2020/09/9.23.20-EO-N-79-20-Climate.pdf.
v See 13 C.C.R. §§ 2281–2285, 2299–2299.5; 17 C.C.R. §§ 93114, 93117, 93118, 93118.2, 93118.3, 93118.5; 13
C.C.R. §§ 2281–2285 & 2299–2299.5.
vi 13 C.C.R. §§ 2293-2293.9.
vii California Public Utilities Code § 216 (f).
viii See 14 U.S.C.A §717a (5).
Oct. 11, 2022 Item #12 Page 525 of 560
487
gas stations or support alternative fuel infrastructure through zoning and expediting permitting for
renewable natural gas fueling stations, hydrogen fueling stations, and electric vehicle charging
equipment (EVSE). Local jurisdictions may also require installation or pre-wiring for EVSE in the public
right of way, on new residential and/or nonresidential buildings, or when additions or alterations to
existing residential and/or non-residential buildings occur.i
Local authorities should also consider state assessments of infrastructure need and funding to inform
the exercise of their own authority to develop and fund fuels and infrastructure. California analyzes the
need for and funds infrastructure to achieve the statutory goals for transportation electrification under
SB 350 (de León, Chapter 547, Statutes of 2015) and ZEVs under Executive Order N-79-20. To this end,
SB 2127 (Ting, Chapter 365, Statutes of 2018) requires the CEC, CARB, and CPUC to conduct a biannual
assessment for electric vehicle charging infrastructure needs to support 5 million ZEVs by 2030 and to
reduce emissions of GHG to 40% below 1990 level by 2030; AB 8 (Perea, Chapter 401, Statutes of 2013)
directs CARB to evaluate fuel cell electric vehicle deployment and hydrogen fuel station network development; and Executive Order N-79-20 Order 4 directs the CEC, CPUC, and CARB to accelerate
affordable fueling and charging options for ZEVs, particularly in low-income and disadvantaged
communities, and Order 6, subsection c) directs the State Transportation Agency, Department of
Transportation, and the California Transportation Commission to support ZEV and infrastructure as part
of larger transportation projects.
CARB’s previously discussed Fiscal Year 2021–2022 funding plan provides significant funding in this
regard, specific to use case and vehicle type. However, infrastructure development is the primary focus
of CEC’s Clean Transportation Program funding approved on November 15, 2021, to close the
infrastructure gap necessary to meet California’s ZEV goals as follows:
• $314 million for light-duty electric vehicle charging infrastructure;
• $690 million for medium- and heavy-duty ZEV infrastructure (battery-electric and hydrogen);
• $77 million for hydrogen refueling;
• $25 million for zero and near-zero carbon fuel production and supply; and
• $15 million for workforce training and development.ii
Specific to hydrogen, AB 8 (2013) set a target of co-funding 100 hydrogen fueling stations (currently,
there are 48 hydrogen fueling stations with another $115.7 million in CEC grant solicitation to co-fund
another 94 stationsiii) and 200 hydrogen stations by 2025 per Executive Order B-48-18. There is currently
one operational hydrogen station in San Diego County, with one more expected to open in 2021iv and
three more stations expected to open in 2022.v There is an opportunity to further develop San Diego
County hydrogen fueling stations with the available state funds and matching private or local funding.
i See 12 C.C.R. Part 11 (2021); See Health & Safety Code §§ 17958.5, 17958.7 & 18941.5(b).
ii CEC Approves $1.4 Billion Plan for Zero-Emission Transportation Infrastructure and Manufacturing (November 15,
2021): https://www.energy.ca.gov/news/2021-11/cec-approves-14-billion-plan-zero-emission-transportation-
infrastructure-and; CEC Lead Commissioner Report, 2021-2023 Investment Update for the Clean Transportation
Program (November 2021): https://www.energy.ca.gov/publications/2021/2021-2023-investment-plan-update-
clean-transportation-program.
iii CARB, 2021 Annual Evaluation of Fuel Cell Electric Vehicle Deployment and Hydrogen Fuel Station Network
Development (September 2021), p. ix: https://ww2.arb.ca.gov/sites/default/files/2021-09/2021_AB-8_FINAL.pdf.
iv It is unknown whether this station opened as of January 7, 2022.
v CARB, 2021 Annual Evaluation of Fuel Cell Electric Vehicle Deployment and Hydrogen Fuel Station Network
Development (September 2021), Appendix B.
Oct. 11, 2022 Item #12 Page 526 of 560
488
Investor Owned Utility (IOU) specific electric vehicle investment funding began in 2016 and was
augmented by SB 350’s (2015) mandate to electrify transportation.i The CPUC approved SDG&E’s first
pilot in 2016ii for $45 million at 350 sites corresponding to approximately 3,500 EV stations over three
years, and the CPUC recently approved a renewal of its Power Your Drive Extension Program for $43.5
million to fund nearly 2,000 L2 EVSEs at workplaces and multi-family dwellings in its service territory.iii
The pilot and original Power Your Drive Program installed 3,040 utility-owned and operated charging
ports at 254 sites at a total cost of $70,253,053, exceeding the approved budget by $25,253,053,
marking the difficulty and expense of implementing this type of program.iv Additionally, AB 1082 (Burke,
Chapter 637, Statutes of 2017) and AB 1083 (Burke, Chapter 638, Statutes of 2017) authorized but did
not require IOUs to support charging infrastructure at schools, state parks, and beaches. SDG&E applied
and received approval for 30 school sites (184 L2 ports and 12 DC Fast Chargers (DCFCs) with either the
customer or SDG&E owning the EVSE), 12 state park and beach sites (64 L2 ports & 10 DCFCs owned by
SDG&E), and 10 sites at city and county parks (52 L2 ports & 10 DCFCs owned by SDG&E).v
Finally, the Volkswagen Diesel Emission Settlement Beneficiary Mitigation Planvi provides $10 million
statewide for light-duty vehicle fueling infrastructure, split evenly between electric vehicles and
hydrogen.
B.2.5 New Vehicle Sales and Fleet Procurement Requirements
Local jurisdictions act with clear authority to procure fleets for their operations with limited federal
preemption under the “market participant exception.” The market participant exception applies to the
Dormant Commerce Clause and is expressly included in the EPCA,vii applied by case law to the CAA,viii
and applied by case law to the FAAAA.ix Local jurisdictions have been prohibited from mandating the
purchase of the certain type of clean technology vehicles for private classes of vehicles, such as taxis.x
Local jurisdictions act with clear authority to procure fleets for their operations with limited preemption
by the state. However, California policy seeks to create a zero-emission only market for new vehicles
under Executive Order No. N-79-20, establishing a 100% in-state sales of new zero-emission passenger
i Public Utilities Code § 740.12(a)(1).
ii CPUC D.16-01-045, Decision Regarding Underlying Vehicle Integration Application and Motion to Adopt
Settlement Agreement (February 4, 2016):
(https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M158/K241/158241020.PDF.
iii CPUC D. 19-10-012, Decision Authorizing SDG&E Company’s Power Your Drive Extension Electric Vehicle Charging
Program (April 19, 2021): https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M378/K429/378429298.PDF.
iv CPUC R.18-12-006, Electric Vehicle-Grid Integration Pilot Program Eight Semi-Annual Report of SDG&E Company
(U902-E) (April 1, 2020), p. 3: https://www.sdge.com/sites/default/files/regulatory/R.18-12-
006%20SDG%26E%20April%201%2C%202020%20Eighth%20Semi%20Annual%20PYD%20Report.pdf.
v CPUC D. 19-11-017, Decision on the Transportation Electrification Pilots for Schools and Parks Pursuant to
Assembly Bills 1082 and 1083 (November 7, 2019).
vi State of California Beneficiary Mitigation Plan For the Volkswagen Environmental Mitigation Trust (June 2018), p.
33–36: https://ww2.arb.ca.gov/sites/default/files/2018-07/bmp_june2018.pdf.
vii 49 U.S.C.A § 32919(c).
viii See Engine Mfrs. Ass'n v. South Coast Air Quality Mgmt. Dist., 498 F.3d 1031, 1040 (9th Cir. 2007).
ix Tocher v. City of Santa Ana, 219 F.3d 1040, 1049 (9th Cir. 2000); See also City of Columbus v. Ours Garage &
Wrecker Serv., Inc., 536 U.S. 424, 431 (2002). x Metro. Taxicab Bd. of Trade v. City of New York, 615 F.3d 152, 157 (2d Cir. 2010), cert. denied, 562 U.S. 1264
(2011); Ophir v. City of Boston, 647 F.Supp. 2d 86, 94 (D. Mass. 2009).
Oct. 11, 2022 Item #12 Page 527 of 560
489
cars and truck by 2035, and to build the electric vehicle charging infrastructure to deploy 5 million ZEVs
by 2030 under Executive Order B-48-18 and to develop ZEV and related supply chains and infrastructure
in California under Executive Order B-16-12.
Consequently, the Innovative Clean Transit (ICT) regulation requires all public transit agencies to
gradually transition to a 100-percent zero-emission bus fleet and encourages these agencies to provide
innovative first and last-mile connectivity and improved mobility for transit riders.i The Advanced Clean
Trucks (ACT) regulation sets a ZEV sales requirement and a one-time reporting requirement for large
entities and fleets.ii The Zero-Emission Airport Shuttle regulationiii requires private and public airport
shuttle fleet owners with fixed routes serving California’s 13 largest airports (including San Diego
International Airport) to fully transition their fleet to zero-emission shuttles by 2035 to reduce and
eliminate GHG emissions, NOx, and other criteria pollution reductions.iv
Additionally, CARB is proposing an Advanced Clean Fleet (ACF) regulation to deploy medium- and heavy-
duty ZEV where feasible. CARB describes this proposed rule as requiring the deployment of ZEVs as
follows: 100% of new drayage trucks by 2035; 100% of new off-road vehicles and equipment by 2035
(where feasible), and 100% medium- and heavy-duty vehicles by 2045 (where feasible).v It is expected
that similar types of programs will be implemented for light-duty vehicles post-2026 model years.
Significant state funding exists to achieve state policy. The Volkswagen Environmental Mitigation Trust
provides the following amounts per use-case:
• $130 million for zero-emission transit, school, and shuttle buses;
• $90 million for zero-emission Class 8 freight and drayage trucks;
• $70 million for zero-emission freight and marine projects; and
• $60 million for freight and marine projects.vi
The CEC’s funding provides the following:
• $75 million SB 110 (Committee on Budget and Fiscal Review, Chapter 55, Statutes of 2017) per
Proposition 39 and $14 million Clean Transportation Program funds for school bus replacement.vii
CARB adopted the following funding allocations for Fiscal Year 2021–2022 for a total of $1,548.09
million allocated in the following ways:
• $525 million for Vehicle Purchase Incentives including:
o $515 million for the Light-duty Clean Vehicle Rebate Project (CVRP); and
o $10 million for the Electric Bicycle Incentive program;
• $150 million for Clean Transportation Equity Investments including:
o $75 million for Clean Cars 4 All;
i 13 C.C.R. §§ 2023 et seq.
ii See 13 C.C.R. §§ 1963, 1963.1, 1963.2, 1963.3, 1963.4, 1963.5, 2012, 2012.1, & 2012.2.
iii 17 CCR §§ 95690.1, 95690.2, 95690.3, 95690.4, 95690.5, 95690.6, 95690.7, and 95690.8.
iv 17 C.C.R. §§ 95690.1, 95690.3, 95690.5, and 95690.6.
v See CARB, Advanced Clean Fleets Fact Sheet (Last accessed on July 12, 2022): https://ww2.arb.ca.gov/our-
work/programs/advanced-clean-fleets/advanced-clean-fleets-fact-sheets.
vi State of California Beneficiary Mitigation Plan for the Volkswagen Environmental Mitigation Trust (June 2018), p.
20–32: https://ww2.arb.ca.gov/sites/default/files/2018-07/bmp_june2018.pdf.
vii CEC Lead Commissioner Report, 2021–2023 Investment Plan Updated for the Clean Transportation Program,
CEC-600-2021-038-LCF, p. 32 (November 2021): https://www.energy.ca.gov/publications/2021/2021-2023-
investment-plan-update-clean-transportation-program
Oct. 11, 2022 Item #12 Page 528 of 560
490
o $23.5 million for Financing Assistance;
o $10 million for Clean Mobility Options;
o $10 million for Clean Mobility In Schools Pilot Project;
o $25 million for the Sustainable Transportation Equity Project (STEP);
o $5 million for Outreach, Community Needs Assessment, Technical Assistance, and Access
Clean California; and
o $1.5 million for Workforce Training and Development;
• $873.09 for Heavy-Duty and Off-Road Equipment including:
o $569.5 million for the Clean Truck and Bus Vouchers (HVIP) program;
o $194.95 million for the Clean Off-Road Equipment Vouchers (CORE);
o $28.64 million for the Truck Loan Assistance; and
o $80 million for the Demonstration and Pilot Projects (includes $40 million for the Drayage
Truck and Infrastructure Project).i
An example of local implementation of funding from state programs includes a local Clean Cars 4 All
program approved by CARB on November 19, 2021, that will fund a $5 million program in the County of
San Diego administered by the SD APCD.ii San Diego County Supervisors voted in October 2019 to bring
this program to San Diego County, but the COVID-19 pandemic delayed it until 2021. SD APCD also
operates a Scrap Car Reimbursement Assistance Program (SCRAP) that provides $1000 for qualified cars
from 1997 or older that are voluntarily retired to reduce air pollution.iii
B.3 Local Authority Related to Building Decarbonization
At the local level, the police power and delegated authority to regulate energy end-uses are the primary
means of implementing building decarbonization actions. Local jurisdictions may use their police power
to prohibit the installation of natural gas plumbing in new buildings,iv identify buildings or
neighborhoods that are in need of natural gas infrastructure replacement to electrify (e.g., natural gas
infrastructure pruning), require energy benchmarking for buildings not covered by Title 20
Benchmarking requirements,v and/or encourage fuel switching to low- or zero-emission fuels (e.g.,
renewable natural gas or green hydrogen) through GHG emission performance standards based on
energy benchmarking information and disclosure. Local jurisdictions act with delegated authority to
require more stringent Title 24, Part 6 Energy Codes, Part 11 CALGreen Codes, and procurement
i CARB, Proposed Fiscal Year 2021–22 Funding Plan for Clean Transportation Incentives (Release Date: October 8,
2021; Board Approved: November 19, 2021), p. 6: https://ww2.arb.ca.gov/sites/default/files/2021-10/fy21-
22_fundingplan.pdf.
ii See CARB, Proposed Fiscal Year 2021–22 Funding Plan for Clean Transportation Incentives (Release Date: October
8, 2021; Board Approved: November 19, 2021), p 59–60: https://ww2.arb.ca.gov/sites/default/files/2021-10/fy21-
22_fundingplan.pdf; See also SD APCD Passenger Vehicle Programs: Clean Cars 4 All:
https://www.sdapcd.org/content/sdapcd/grants/grants-equipment/passenger-vehicles.html.
iii SD APCD Passenger Vehicle Programs: SCRAP: https://www.sdapcd.org/content/sdapcd/grants/grants-
equipment/passenger-vehicles.html.
iv Note: the City of Berkeley’s prohibition is currently on appeal to the Ninth Circuit Court of Appeals (CRA v. City of
Berkeley, No. 21-16278, (9th Cir. filed August 5, 2021)); See CRA v. City of Berkeley, Docket No. 4:19-cv-07668,
Judgment, Document 76 (N.D. Cal. Nov. 21, 2019) which dismissed with prejudice cause of action for EPCA
preemption and dismissed without prejudice California state law preemption cause of action. v See AB 802 (Williams, Chapter 590, Statutes of 2015); 20 C.C.R. § 1680 (2021) et seq.; see also City of San Diego
Building Benchmarking Ordinance adopted pursuant to 20 C.C.R. § 1684 (2021).
Oct. 11, 2022 Item #12 Page 529 of 560
491
authority, including sole source procurement authority for energy conservation, cogeneration, and
alternative energy supply projects on public buildings.i Local governments should evaluate how to align
local requirements and actions with state policy and programs to decrease costs related to building
decarbonization.
At the federal level, the Energy Act of 2020 updated and added provisions and funding for, among other
things, energy and water efficiency, renewable energy and storage, carbon management and removal
from buildings and industry, industry and manufacturing technologies that decrease emissions, grid
modernization and building integration, and related research, development, and deployment.ii President
Biden recently signed Executive Order 14057 directs the federal executive branch to achieve a net-zero
emissions path by 2050. Specific to building decarbonization, the Executive Order, among other things,
orders:
• 100 percent carbon pollution-free electricity on a net annual basis by 2030, including 50 percent
24/7 carbon pollution-free electricity;
• A net-zero emissions building portfolio by 2045, including a 50 percent emissions reduction by
2032;
• A 65 percent reduction in scope 1 and 2 greenhouse gas emissions, as defined by the Federal
Greenhouse Gas Accounting and Reporting Guidance, from Federal operations by 2030 from
2008 levels;
• Net-zero emissions from Federal procurement, including a Buy Clean policy to promote the use of
construction materials with lower embodied emissions; and
• Climate resilient infrastructure and operations.iii
This order builds upon Executive Order 13990 that directed federal agencies to review action from
2017–2022 that may be inconsistent with or conflict with improving public health, protecting the
environment, accessing clean air and water, reducing GHG emissions, and bolstering resiliency to
climate change. Additionally, Executive Order 14008 sets goals for a carbon-free electricity by 2035 and
economy wide net-zero emissions by 2050. Whether these executive order are codified in federal law
remains to be seen, and the orders are subject to rescission by future Administrations.
California policy benefits from over forty years of state regulation designed to decrease energy
consumption from buildings and appliances with a focus on reducing consumer energy consumption and
GHG emissions from buildings. In 2015, AB 350 (de León, Chapter 547, Statutes of 2019) set a goal of
cumulative doubling energy efficiency savings and demand reduction in electricity and natural gas end-
uses by January 1, 2030. AB 350 (2015) tasked the CEC with establishing an annual target to achieve
these reductions with the CEC and the CPUC taking further action through buildings standards, appliance
standards, and CPUC regulated energy efficiency programs administered by IOUs, CCAs, and other third-
party program administrators.iv CCAs may also create their energy efficiency programs separate from
i See Government Code § 4217.10 et seq.
ii 47 H.R. 133 – 116th Congress (2019-2020): Consolidated Appropriation Act, 2021. December 27, 2020 (Public Law
No: 116-260), Division Z (Energy Act of 2020): https://www.congress.gov/bill/116th-congress/house-bill/133/text.
iii Presidential Executive Order No. 14057, Catalyzing Clean Energy Industries and Jobs Through Federal
Sustainability 86 Federal Register 70935 (2021-27114), Sec. 102 (December 8, 2021):
https://www.whitehouse.gov/briefing-room/presidential-actions/2021/12/08/executive-order-on-catalyzing-
clean-energy-industries-and-jobs-through-federal-sustainability/ &
https://www.federalregister.gov/documents/2021/12/13/2021-27114/catalyzing-clean-energy-industries-and-
jobs-through-federal-sustainability.
iv See CPUC Energy Efficiency Rule Making R.13-11-005 & R.19-01-011.
Oct. 11, 2022 Item #12 Page 530 of 560
492
CPUC regulated programs. Innovation is needed to achieve the SB 350 targets, particularly when
converting energy efficiency to avoid GHG emissions, in terms of how to implement demand reduction
flexibility that decreases energy use when GHG emissions are the highest (e.g., seasonal and daily peak
electric load).i
This resulted in a major policy shift towards building decarbonization in 2018 with Executive Order B-55-
18 directing state agencies to achieve carbon neutrality by 2045, AB 3232 (Friedman, Chapter 373,
Statutes of 2018) requiring the CEC in consultation with CARB, the CPUC, and CAISO to assess the
potential to reduce GHG in buildings by 40% below 1990 levels by 2030, and SB 1477 (Stern, Chapter
378, Statutes of 2018) allocating $50 million per year through 2023 to fund the Building Initiative for
Low-Emissions Development (Build) and Technology and Equipment for Clean Heating (TECH).
Additionally, the CPUC adopted changes to its existing energy efficiency rolling portfolio that will set
energy efficiency goals to maximize GHG reductions and grid benefits, including equity, using a Total
System Benefit (TSB) test that expresses the dollar value of lifecycle energy, capacity, and GHG benefits
on a utility’s energy efficiency program portfolio starting in 2024.ii The CPUC set energy efficiency
portfolio goals for 2022–2032 in D.21-09-037 on September 23, 2021.
Pursuant to AB 3232 (2018), the CEC issued a California Building Decarbonization Assessmentiii report
showing that achieving reduction of GHG by 40% below 1990 level by 2030 requires residential and
commercial building decarbonization through electrification, decarbonizing electricity supply, energy
efficiency, refrigerant conversation and leakage reduction, distribute energy resources (DER)
deployment, gas system decarbonization, and demand flexibility. The report found the most readily
achievable pathway to meet the AB 3232 target was through efficient electrification of space and water
heating in buildings combined with refrigerant leakage reduction.
Local governments should evaluate how to align local requirements and actions with state policy and
programs to decrease costs related to building decarbonization. The CEC’s most recent ratepayer-
funded Electric Program Investment Charge (EPIC) plan for 2021–2025 reflects continued investment in
achieving these targets for electrification, high efficiency and low-GWP heat pump water heaters and
HVAC heater pumps, building envelope upgrades, combined heat pump for hot water and heating
conditioning, nanogrid HVAC module development, smart energy management systems, large building
HVAC decarbonization, industrial decarbonization, low-carbon and high-temperature industrial heating,
energy efficient and decarbonization of concrete manufacturing, and industrial energy efficiency
separation processes.iv These investments will serve to vet viable actions to decarbonize these types of
end-uses and lower costs. It will also help to determine what end-uses cannot be decarbonized and
which GHG emissions by source must be removed or sequestered.
i See CEC Final Staff Report, 2019 California Energy Efficiency Action Plan, November 2019, p. 4.
ii See CPUC D.21-05-031, Rulemaking 12-11-005 Assessment of Energy Efficiency Potential and Goals and
Modification of Portfolio Approval and Oversight Process (May 31, 2021), p. 2:
https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M385/K864/385864616.PDF.
iii California Energy Commission: Final Commission Report California Building Decarbonization Assessment,
Publication Number: CEC-400-2021-006-CMF (2021): https://www.energy.ca.gov/publications/2021/california-
building-decarbonization-assessment.
iv California Energy Commission: Final Commission Report The Electric Program Investment Charge Proposed 2021–
2025 Investment Plan, EPIC 4 Investment Plan, (November 2021), p. 130-181: https://www.energy.ca.gov/publications/2021/electric-program-investment-charge-proposed-2021-2025-
investment-plan-epic-4.
Oct. 11, 2022 Item #12 Page 531 of 560
493
Per SB 1477 (2018), the BUILD program aims to incent near-zero-emission building technologies that
reduce GHG emissions significantly beyond minimum code requirements for residential buildings. BUILD
currently provides incentives to new residential housing projects that are all-electric and have no hook
up to the gas distribution system. The TECH program aims to advance California’s market for low-
emission space and water heating technologies that are in early-stage development. These programs,
combined with existing utility energy efficiency programs, form the state policy to address building
decarbonization. Local governments should evaluate how to align local requirements and actions with
state policy and programs to decrease costs related to building decarbonization. There is also an
opportunity to engage in the CPUC’s proceeding on building decarbonization that is implementing the
BUILD and TECH programs, amongst other building decarbonization efforts.i
B.3.1 Energy Efficiency and Building Material Conservation and Resource Efficiency
Using delegated authority, local jurisdictions may adopt more stringent building code standards that
address energy efficiency, water conservation, building material conservation, or resource efficiency
based on GHG requirements (e.g., material carbon intensity). Where the requirement addresses energy
consumption, the adopted local code must be at least as energy efficient as the state codes, cost-
effective (e.g., all-electric reach codes or building performance standards),ii and submitted to the CEC to
review for compliance with state law.iii In all cases where Title 24 is amended, the standards must be
submitted to the Building Standard Commission with the findings for local climatic, geological, or topical
conditions that authorize the change to Title 24. In terms of police authority, the full extent of local
jurisdiction police authority is unknown and largely untested. Additional research is required to vet
other local actions.
Federal preemption exists over setting energy efficiency standards for covered productsiv (e.g.,
appliances) under EPCA with limited exception for new construction.v Local jurisdictions are subject to
state preemption in the form of Title 20 appliance standards that regulate many appliances not
preempted by the EPCA and the triennially updated Title 24 building standards that the CEC adopts.
In California, there is delegated authority for local jurisdictions to adopt more stringent building
standards under Title 24 for energy efficiency and building materials. For example, local jurisdictions
may adopt more stringent Green Building programs — including water conservationvi — by making
voluntary CALGreen standards mandatory or other measures that may include building material
i See CPUC R. 19-01-011: Order Instituting Rulemaking Regarding Building Decarbonization:
https://apps.cpuc.ca.gov/apex/f?p=401:56:0::NO:RP,57,RIR:P5_PROCEEDING_SELECT:R1901011.
ii See to Public Resources Code § 25402.1(h)(2) and Health & Safety Code §§ 17958.5 & 17958.7.
iii See Public Resources Code § 25402.1 (h)(2); see Title 24, Part 6, Section 10-106 (2021).
iv 42 U.S.C. § 6295; See also 10 CFR Parts 430, 431, & 429.
v 42 U.S.C. §§ 6297(c) & 6297(f)(3); see also 42 U.S.C. §§ 6291 et seq. (Part A-Energy Conservation Program for
Consumer Products Other Than Automobiles); 42 U.S.C. §§ 6311 et seq. (Part A-1-Certain Industrial Equipment).
viNote: Water conservation and enforcement programs are also authorized by Water Code §§ 375–378 & 1009,
including water saving devices and rate structure design, which must also comply with Prop 218 limits (Cal. Const.
art. XIIIC–XIIID); See also Water Code §§ 10680.20, 10680.24 (urban retail water suppliers must develop urban
water use targets that cumulatively result in a 20 % reduction from a baseline daily per capita water use by
December 31, 2020); see also Water Code §§ 10609.2, 10609.4 (requires the State Water Control Board, in coordination with the Department of Water Resources, to adopt a long-term standard for efficient use of water
and establish 55 gallons per capita as the daily indoor residential standard water use).
Oct. 11, 2022 Item #12 Page 532 of 560
494
conservation and resource efficiency based on GHG emissionsi, carbon intensity, or carbon
sequestration (e.g., cement made from synthetic aggregate produced from captured compressed CO2) if
it is reasonably necessary because of local climatic, geological, or topographical conditions.ii SB 596
(Becker, Chapter 246, Statutes of 2021) aids in this endeavor by requiring CARB to develop a strategy to
achieve net-zero emission of GHG associated with cement used within California as soon as possible, but
no later than December 31, 2045, with interim targets that include a carbon intensity reduction for
cement of 40% below 2019 average levels by December 31, 2035. It may be possible for local
jurisdictions to help accelerate or surpass this type of state mandate.
B.3.2 CEQA Environmental Impact Mitigation Authority
CEQA offers another means to address emissions from the built environment. A lead agency acts with
discretion to determine whether an adverse environmental effect identified in an environmental impact
report (EIR) should be classified as "significant" or "less than significant."iii A lead agency may adopt and
publish a threshold of significance that sets a high threshold for GHG emissions, which could include
requiring all projects to be carbon neutral or zero net carbon,iv and must be based on scientific and
factual data to the extent possiblev to meet the substantial evidence standard.vi This is limited by
existing implied or expressed authority to impose mitigation measures on a project.vii Mitigation
measures cannot be legally infeasibleviii — meaning that they may not be beyond the power conferred
on lead and responsible agencies — and are also subject to express limitations, including limits on
reducing housing units.ix
B.3.3 Direct Regulation of Building GHG Emissions
Direct regulation of GHG emissions, not currently regulated by Cap-and-Trade, may provide additional
means to reduce emissions, but uncertainty exists around authority. It may be possible to create a GHG
performance standards for buildings. It may also be possible to directly regulate building and appliance
oxides of nitrogen (NOx) emissions from natural gas under existing authority. Finally, it is uncertain
whether existing tax or fee authority may be used to regulate GHGs.
At the state level, California addresses GHG emissions through both direct emissions regulation as well
as procurement of renewable fuel sources. California’s Cap-and-Trade program also regulates covered
entities that emit 25,000 metric tons or more of CO2e per data year, including cogeneration, self-
i Note: current mandatory and voluntary 2019 Title 24, Part 11 CALGreen Codes are not based on GHG life cycle
analysis except for Nonresidential Voluntary Section A5.409 Life Cycle Assessment which allows GHG to be used in
the impacts considered for the analysis of life cycle.
ii See 12 C.C.R. Part 11 (2021); See Health & Safety Code §§ 17958.5, 17958.7 & 18941.5(b).
iii 14 C.C.R. § 15064(b)(1) (2021).
iv 14 C.C.R. § 15064.7(b) (2021); see also definition of “threshold of significance” under 14 CCR § 15064.7(a) (2021);
See also Bay Area Air Quality Management District CEQA Threshold for Evaluating the Significance of Climate
Impacts from Land Use Projects and Plans, Board of Directors Meeting Agenda Item 15 (Adopted April 20, 2022), p.
152–221: https://www.baaqmd.gov/~/media/files/board-of-directors/2022/bod_agenda_042022_op_rv-
pdf.pdf?la=en&rev=c8360ec141654c22b244e5e07f8b88b4.
v 14 C.C.R. § 15064(b)(1) (2021).
vi Mission Bay Alliance v. Office of Community Inv. & Infrastructure, 6 Cal. App. 5th 160, 206 (2016).
vii See 14 C.C.R. § 15040(d)–(d).
viii See Public Resources Code § 21004; See 14 C.C.R. § 15040.
ix See Public Resources Code § 21159.26; See 14 C.C.R. § 15092(c).
Oct. 11, 2022 Item #12 Page 533 of 560
495
generation of electricity, cement production, glass production, hydrogen production, iron and steel
production, lead production, nitric acid production, petroleum and natural gas system, petroleum
refining, pulp and paper manufacturing, suppliers of natural gas, suppliers of RBOB and distillate fuel oil,
suppliers of liquefied petroleum gas, suppliers of liquified natural gas and compressed natural gas,
carbon dioxide suppliers, and stationary combustion.i Regulation of sources below the 25,000 metric ton
of CO2e per data year is not preempted but would require identifying authority to directly regulate, such
as the police power.
For example, it may be possible to create GHG performance standards for buildings based on building
type, square footage, and emission profiles. This would be an exercise of either police power or
delegated authority to amend Title 24 if it is reasonably necessary because of local climatic, geological,
or topographical conditions using Health and Safety Code Sections 17958.5, 17958.7, and 18941.5(b).
Because such standards do not address the diminution of energy, a CEC review would not be required.
The same authority can also be used to create building benchmarking requirements for energy use and
GHG emission disclosures at point-of-sale or point-of-listing that are more expansive than those
required under AB 802 (2015).ii The energy and GHG benchmarking would then serve as the measure to
implement building GHG emission standards that utilize enforcement authority under existing municipal
code for compliance.iii A potential funding source for upgrades could include creating a transfer tax
rebate that refunds a percentage of the transfer tax to property owners who make electrification,
energy efficiency, and water conservation retrofits.iv Equity considerations must be addressed. Because
a fund transfer rebate only benefits property owners who made a recent purchase, other funding would
need to be identified to fund upgrades for recent low-income owners, renters, and long-term
homeowners with limited incomes. Additional research is required to further vet this action.
SD APCD is one of nine air districts that regulates NOx emissions from space heaters and water heaters
and currently sets the most stringent emission limit of 10 ng/j NOx for water heaters in the state.v It may
be possible for a city, county, or air district to take additional action to strengthen these regulations for
water, space heating, or other natural gas end-use or directly regulate natural gas NOx emissions from
buildings and appliances using Health and Safety Code Sections 39002, 39013, 39037, and 41508. For
example, it may be possible for SD APCD to use an incentive to encourage purchase of zero-emission
technologies, adopt zero-emission NOx regulations for space and water heating, and/or regulations to
reduce NOx where zero-emission appliances may not be technically feasible.vi Any regulation that
i 17 C.C.R. §§ 95811 (a)–(b) & 95812(c).
ii California Public Resources Code § 25402.10 (d)(2)(F) & 20 C.C.R. § 1684; See City of Berkeley Municipal Code
19.81 – the Building Energy Savings Ordinance (BESO) (2021).
iii See City of Berkeley Administrative Draft, Existing Buildings Electrification Strategy (April 2021), p. 140–141; See
City of Berkeley Building Energy Savings Ordinance Evaluation Report, p. 12–21, Appendix C, & Appendix I,
(February 11, 2020); See City of Berkeley Municipal Code 1.28 – Administrative Citations (2021).
iv See City of Berkeley Building Energy Savings Ordinance Evaluation Report (February 11, 2020), p. 5.
vSee SD APCD Rules 68-69.6: https://www.sdapcd.org/content/sdapcd/rules.html; see also CARB, Draft 2022 State
Strategy for the State Implementation Plan, January 31, 2022, p. 86:
https://ww2.arb.ca.gov/sites/default/files/2022-
01/Draft_2022_State_SIP_Strategy.pdf?utm_source=Master+List+Created+on+1%2F23%2F2017&utm_campaign=
d9aa050b56-EMAIL_CAMPAIGN_2018_05_14_COPY_01&utm_medium=email&utm_term=0_0c851e413b-
d9aa050b56-92657441.
vi See South Coast AQMD. 2021. "Agenda Item 5 - Proposed Draft NOx Stationary Source Measures." Air Quality
Management Plan - November 10, 2021 Public Workshop. Available at: http://www.aqmd.gov/docs/default-
source/clean-air-plans/air-quality-management-plans/2022-air-quality-management-plan/am-pres-agenda-item-5-
Oct. 11, 2022 Item #12 Page 534 of 560
496
requires zero-emission NOx emitting appliances within its district would also need to be concurrent with
regulation on the installation of natural gas appliances across the district.i It is also possible that SD
APCD would enforce similar state zero-emission regulation if CARB decides to develop and adopt a rule
to ban natural gas water and space heaters by 2030 under the proposed 2022 California State
Implementation Plan and 2022 Draft AB 32 Scoping Plan.ii
Because these code sections further allow local authorities (e.g., city or county) to enact such regulation
under Health and Safety Code Section 39002 as the entity with primary responsibility for air pollution
from all sources other than vehicle sources, it suggests that additional action is possible beyond existing
or future SD APCD regulation. Any such standard may be set more stringent than set by law or CARB for
non-vehicle sources. The full extent of this authority is unknown and untested in terms of a zero-
emission NOx regulation but there are air districts with existing more stringent space heating standardsiii
than SD APCD and other air districts are proposing incentives and zero-emission NOx regulations for
water, space, and other natural gas end-uses.iv Importantly, there are no examples of an exercise of this
type of authority by a city or county in this respect. It would likely be expensive for a city or county to
create and operate such a program, given the required technical expertise needed to implement and
enforce it.
It is uncertain whether a local government may raise a tax or fee on GHG emissions. Local jurisdictions
act with authority — subject to voter approval if a tax — to raise general taxes, special taxes, and fees
for specified purposes under California Constitution Article XIII C & D. Taxes may be placed on real
property and tangible personal property where the property is located. Taxes may also take the form of
license taxes, sale and use taxes, documentary transfer taxes, retail transaction and use taxes, utility
users’ taxes, occupancy taxes, local vehicle license fees,v community facilities taxes, and excise taxes on
developers. Under California Constitution Article XIII C § 2, general taxes must be approved by a majority
vote, while special taxes must be approved by a two-thirds vote. Additionally, a charge that meets one
nox-measures-110621.pdf?sfvrsn=6; see also Bay Area AQMD. 2021. "Draft Amendments to Building Appliance
Rules Regulation 9, Rule 4: Nitrogen Oxides from Fan Type Residential Central Furnaces and Rule 6: Nitrogen Oxides Emissions from Natural Gas-Fired Boilers and Water Heaters." Available at:
https://www.baaqmd.gov/rules-and-compliance/rules/reg-9-rule-4-nitrogen-oxides-from-fan-type-residential-
central-furnaces?rule_version=2021%20Amendment.
i See City of Berkeley, Administrative Draft Existing Building Electrification Strategy, April 2021, p. 129.
ii CARB, Draft 2022 State Strategy for the State Implementation Plan, January 31, 2022, p. 86-88:
https://ww2.arb.ca.gov/sites/default/files/2022-
01/Draft_2022_State_SIP_Strategy.pdf?utm_source=Master+List+Created+on+1%2F23%2F2017&utm_campaign=
d9aa050b56-EMAIL_CAMPAIGN_2018_05_14_COPY_01&utm_medium=email&utm_term=0_0c851e413b-
d9aa050b56-92657441; see also CARB Draft 2022 Scoping Plan Update, May 10, 2022, p, 172:
https://ww2.arb.ca.gov/sites/default/files/2022-05/2022-draft-sp.pdf.
iii San Joaquin Valley and South Coast Air Quality Management District (AQMD) set an emission limit of 14 ng/J NOx
for space heaters.
iv See South Coast AQMD. 2021. "Agenda Item 5 - Proposed Draft NOx Stationary Source Measures." Air Quality
Management Plan – November 10, 2021 Public Workshop. Available at: http://www.aqmd.gov/docs/default-
source/clean-air-plans/air-quality-management-plans/2022-air-quality-management-plan/am-pres-agenda-item-5-
nox-measures-110621.pdf?sfvrsn=6; see also Bay Area AQMD. 2021. "Draft Amendments to Building Appliance
Rules Regulation 9, Rule 4: Nitrogen Oxides from Fan Type Residential Central Furnaces and Rule 6: Nitrogen
Oxides Emissions from Natural Gas-Fired Boilers and Water Heaters." Available at:
https://www.baaqmd.gov/rules-and-compliance/rules/reg-9-rule-4-nitrogen-oxides-from-fan-type-residential-
central-furnaces?rule_version=2021%20Amendment.
v See California Revenue Code § 11101 et seq.
Oct. 11, 2022 Item #12 Page 535 of 560
497
of the requirements is not considered a tax under California Constitution Article XIII C, § 1 (e)(1)-(7)
including, but not limited to:
• A charge imposed for a specific benefit conferred or privilege granted directly to the payor that is
not provided to those not charged, and which does not exceed the reasonable costs to the local
government of conferring the benefit or granting the privilege;
• A charge imposed for a specific government service or product provided directly to the payor that
is not provided to those not charged, and which does not exceed the reasonable costs to the local
government of providing the service or product;
• A charge imposed for the reasonable regulatory costs to a local government for issuing licenses
and permits, performing investigations, inspections, and audits, enforcing agricultural marketing
orders, and the administrative enforcement and adjudication thereof;
• A charge imposed for entrance to or use of local government property, or the purchase, rental, or
lease of local government property;
• A charge imposed as a condition of property development; and
• Assessments and property-related fees imposed in accordance with the provisions of Article XIII D.
If the charge or fee is a “property-related service,” it must also meet the requirements of California
Constitution Article XIII D. It is unclear if any of these charges are viable to place a fee on GHG emissions
and whether California Constitution Article XIII D would apply.
B.3.4 Fuel Switching and Emissions related to End-Uses
Police power authority may be used to require fuel switching to low or zero-carbon sources through
prohibitions on the installation of certain energy infrastructure (e.g., natural gas plumbing) in buildings.
Police power may take the form of adopting an ordinance that expressly prohibits natural gas plumbing
without either amending Title 24, Part 6, changing minimum efficiency standards for covered products
under the EPCA, or requiring the installation of specific appliances or systems as a condition of
approval.i There is currently an effort to preempt local jurisdiction police power under the EPCA. The
City of Berkeley’s Ordinance No. 7,672-N.S. adopted on July 16, 2019, used police power without
amending Title 24 to prohibit natural gas plumbing in new construction. This ordinance survived the
preemption challenge in federal district court and is now on appeal in the Ninth Circuit.ii
There is an opportunity to engage in the legislature and CPUC on the future of natural gas infrastructure.
California regulates natural gas supply, transmission, storage, and the development of renewable
natural gas or biomethane, including procurement targets for IOUs preempting some but not all
additional local action or regulation.iii Natural gas distribution and storage monitoring, leak abatement,
and decreasing emissions from short-lived climate pollutants round out current state policy.iv The CPUC
i See City of Berkeley Ordinance No. 7,672-N.S. (Adopted July 16, 2019), City of Morgan Hill Ordinance No. 5906
(adopted October 23, 2019), City of San Jose Ordinance No. 30330 (adopted September 17, 2019), and City of
Santa Cruz Ordinance No. 2020-06 (adopted April 14, 2020).
ii See California Restaurant Ass. v. City of Berkeley, Order Granting in Part and Denying in Part Motion to Dismiss,
Document 75, Case No. 4:19-cv-07668-YGR (July 6, 2021); See California Restaurant Ass. v. City of Berkeley, Case
No. 21-16278 (9th Cir.), filed Aug. 5, 2021.
iii See AB 2313 (Williams, Chapter 571, Statutes of 2016); SB 1440 (Hueso, Chapter 739, Statutes of 2018); see also
AB 1900 (Gatto, Chapter 602, Statutes of 2012); See also SB 1440 (Hueso, Chapter 739, Statutes of 2018); AB 3163
(Salas, Chapter 358, Statutes of 2020). iv See AB 1496 (Thurmond, Chapter 604, Statutes of 2015), SB 1371 (Leno, Chapter 525, Statutes of 2014) and SB
887 (Pavley, Chapter 673, Statutes of 2016), SB 605 (Lara, Chapter 523, Statutes of 2014), SB 1383 (Lara, Chapter
Oct. 11, 2022 Item #12 Page 536 of 560
498
also mandated to decrease GHG emissions from the intrastate transmission and distribution lines.i In
addition, the CPUC regulates climate impacts to and adaptation for IOU infrastructureii and is currently
adjudicating a proceeding over the future regulation of natural gas in California.iii These proceedings and
the decisions that come out of them will determine how infrastructure is maintained, invested in,
removed, and how stranded costs will be socialized.
Local jurisdiction act with authority to develop local hydrogen production and infrastructure through
land use, constitutional authority to provide municipal services under California Constitution Article XI, §
9, franchise agreement authority, and police power authority. The CPUC would regulate intrastate
hydrogen pipelines as a public utility if not owned by a municipal-owned utility.iv Development,
procurement, and use of hydrogen also exist in state law through the statutory designation of E-
hydrogen procurement as an eligible and carbon-neutral form of energy storage that can be used
prospectively in the renewable energy grid or to fuel certain forms of transportation that can be used by
IOUs to achieve state policy.v Hydrogen development offers more opportunities to support or further
fuel switching to low-emission or green hydrogen as a fuel source for buildings, industrial processes, or
thermal power plants.vi However, current hydrogen production is small, and hydrogen infrastructure
and end-use equipment and appliances are nonexistent or limited. There are current CEC and U.S.
Department of Energy (U.S. DOE) funding efforts to decrease cost and develop end-uses.vii
End-uses that depend on ozone depleting substances (ODS) and ODS substitutes with high-GWP gases,
particularly HFC refrigerants, are subject to federal and state regulations that ban, limit or phase out the
regulated substance. GHG emissions are caused by annual leakage during the equipment’s use and at
end-of-life when the high-GWP gas is vented instead of being captured and destroyed as required by
law. Local authorities may seek to strengthen or accelerate state and federal actions by providing local
enforcement, incentives to install low-GWP equipment, or potentially regulating equipment that uses
these substances under its police power, if not preempted.
HFC refrigerants are common in heat pumps and commercial refrigeration, and certain industrial
production with heat-pump installation projected to increase significantly because of building
395, Statutes of 2016), and AB 1496 (Thurmond, Chapter 604, Statutes of 2015).
i See SB 1371 (Leno, Chapter 525, Statutes of 2014).
ii See CPUC Rulemaking R.18-04-019, Order Institution Rulemaking to Consider Strategies and Guidance for Climate
Change Adaptation; See CPUC Rulemaking R.18-12-005, Order Instituting Rulemaking to Examine Electric Utility
De-Energization of Power Lines in Dangerous Conditions; See CPUC Rulemaking R. 18-10-007, Order Instituting
Rulemaking to Implement Electric Utility Wildfire Mitigation Plans Pursuant to SB 901 (2018).
iii See CPUC Rulemaking R. 20-01-007, Order Instituting Rulemaking to Establish Policies, Processes, and Rules to
Ensure Safe and Reliable Gas Systems in California and Perform Long-Term Gas System Planning.
iv See Public Utilities Code § 216.
v See SB 1369 (Skinner, Chapter 567, Statutes of 2018).
vi See LADWP Joins HyDeal LA, Targets Green Hydrogen at $1.50/Kilogram by 2030 (May 17, 2021):
https://www.ladwpnews.com/ladwp-joins-hydeal-la-targets-green-hydrogen-at-1-50-kilogram-by-2030/; See
Mayor Eric Garcetti, City of Los Angeles, Announcement of Findings of Historic 100 Percent Renewable Energy
Study; See Mayor Eric Garcetti’s 2021 State of City Address: https://lamayor.org/SOTC2021; See HyDeal Los
Angeles: https://www.ghcoalition.org/hydeal-la.
vii See California Energy Commission, Introduction of EPIC Initiative – The Role of Green Hydrogen in a
Decarbonized CA – A Roadmap and Strategic Plan, Docket No. 21-IEPR-05, TN# 239050, (July 27, 2021), accessed from Docket Log: https://efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=21-IEPR-05; see US DOE
Hydrogen Shot, https://www.energy.gov/eere/fuelcells/hydrogen-shot.
Oct. 11, 2022 Item #12 Page 537 of 560
499
electrification.i The U.S. EPA regulates acceptable substitutes for existing refrigerants used in various
end-use applications in the refrigeration and air conditioning (including transportation), foam blowing,
and fire suppression sectors under the Significant New Alternatives Policy (SNAP).ii On May 6, 2021, new
final SNAP regulations became effective, authorizing new refrigerant options with lower-GWP for retail
food cooling as well as residential and light commercial air conditioning and heat pumps.iii The American
Innovation and Manufacturing (AMI) Act of 2020, part of the Consolidated Appropriations Act of 2021,iv
required the U.S. EPA to phase down production and consumption of HFCs in the United States by 85
percent over the next 15 years. On April 30, 2021, the U.S. EPA proposed an HFC phase down regulation
for refrigerants and other industrial purposes under an allowance allocation and trading programv to
implement the recently passed AMI Act of 2020.vi The rule will phase down the production and
importation of 18 types of HFCs. This rule became effective on November 4, 2021, except for
amendatory instruction 3 adding 40 CFR part 84, which became effective on October 5, 2021.
The CAA further prohibits the production and use of CFCs in the United States,vii preventing replacing a
high-GWP ODS substitute with a new lower-GWP CFC refrigerant system. CAA Title VI, Section 605 also
phased out the allowed use of HCFCs, starting with specific HCFCs and then moving to a total ban
subject to limited exceptions.viii Beginning January 1, 2020, there is a ban on the production and import
of HCFC-22 and HCFC-142b,ix and it will be unlawful to produce any HCFCs after January 1, 2030.x
Additionally, CAA Title VI, Section 608xi sets national recycling and emission reduction standards for
Class I ODS covered under Sections 604 and Class II ODS under Section 605.
California regulates high-GWP refrigerants under its Refrigerant Management Programxii created by AB
32 (Núñez, Chapter 433, Statutes of 2006), set a target of a 40% reduction of HFC emission below 2014
levels by 2030 under SB 1383 (Lara, Chapter 395, Statutes of 2016), operates a California SNAP programxiii
i See Figure 30 in Kenney, Michael, Nicholas Janusch, Ingrid Neumann, and Mike Jaske. 2021. California Building
Decarbonization Assessment. California Energy Commission. Publication Number: CEC-400-2021-006-CMF. (August
2021), p. 76; see Figure 3 in Achieving Carbon Neutrality in California: PATHWAYS Scenarios Developed for the
California Air Resources Board. Energy and Environmental Economics, Inc. (October 2020), p. 25.
ii 40 CFR Part 82.
iii U.S. EPA, Final Rule: Protection of Stratospheric Ozone: Listing of Substitutes Under the Significant New
Alternatives Policy Program, 40 CFR Part 82 [EPA–HQ–OAR–2019–0698; FRL–10020–41– OAR], Published Federal
Register: Vol 86, No. 86, May 6, 2021: https://www.govinfo.gov/content/pkg/FR-2021-05-06/pdf/2021-08968.pdf.
iv 47 H.R. 133 – 116th Congress (2019–2020): Consolidated Appropriation Act, 2021. December 27, 2020 (Public Law
No: 116-260), American Innovation and Manufacturing Act of 2020: https://www.congress.gov/bill/116th-
congress/house-bill/133/text; 42 U.S.C.A. § 7675.
v See U.S. EPA Proposed Phasedown of Hydrofluorocarbons: Establishing the Allowance Allocation and Trading
Program under the American Innovation and Manufacturing Act, 40 CFR Part 82 [EPA-HQ-OAR-2021-0044; FRL-
10023-08-OAR], April 30, 2021: https://www.epa.gov/sites/production/files/2021-
05/documents/hfc_allocation_nprm_043021_admin.pdf.
vi See U.S. EPA: Proposed Rule - Phasedown of Hydrofluorocarbons: Establishing the Allowance Allocation and
Trading Program under the AIM Act: https://www.epa.gov/climate-hfcs-reduction/proposed-rule-phasedown-
hydrofluorocarbons-establishing-allowance-allocation.
vii Title VI of the Clean Air Act Section 604: 42 U.S.C.A. § 7671c.
viii 42 U.S.C.A. § 7671b & d.
ix Ibid.
x Ibid.
xi 42 U.S.C.A. § 7671g.
xii 17 C.C.R. §§ 95380–95398.
xiii 17 C.C.R. §§ 95371–95377.
Oct. 11, 2022 Item #12 Page 538 of 560
500
per SB 1013 (Lara, Chapter 375, Statutes of 2018), and received final approval for a CARB regulation
prohibiting certain HFCs in specified stationary refrigeration, chillers, aerosols-propellants, and foam
end-uses and requiring refrigerant recovery, reclaim, and reuse per SB 1383 (2016).i Additionally, SB
1013 (2018) directed the CPUC to consider including low-GWP refrigerants in energy efficiency
portfolios. On April 16, 2020, CPUC D.20-04-010 adopted policies that affect all distributed energy
resources, including energy efficiency, requiring program administrators to account for avoided costs of
high-GWP gases in the energy efficiency portfolio, including refrigerant emissions and methane. CPUC
D.20-04-010 applies avoided costs to, among other things, fuel substitution measures (e.g., the benefit is
lowered methane emissions and costs are refrigerant emissions) and programs that encourage the use
of lower-GWP refrigerants than current practice or regulation. CPUC D.21-05-031, adopted May 20,
2021, required the Refrigerant Avoided Cost Calculator from D.20-04-010 to be used by rolling energy
efficiency program administrators for portfolio forecasts and filings beginning in 2022. Future changes
will be tied to CARB’s rulemaking, market development, and program administrator experiences.
B.4 Local Authority to Decarbonize the Electricity Supply
Electricity regulation is divided between state regulation of the distribution system and procurement of
supply and federal regulation of bulk-power transmission systems and bulk-power markets. In both
instances, reliability requirements preempt local authority over electricity procurement where the
procurement impacts either CPUC resource adequacy (RA) requirementsii or FERC authority over electric
reliability in bulk-power systems.iii The following will discuss local authority in light of the state and
federal regulation of conventional and renewable electricity supply resources.
B.4.1 Conventional and Fossil Fuel Generation
The Energy Act of 2020 made several amendments to the Energy Policy Act of 2005 to address reducing
GHG emissions from fossil generation through funding technological pilots to decrease emissions or fuel
use from natural gas and coal turbines, improve carbon capture and storage, develop a carbon
utilization programs, and study blue hydrogen, among other things.iv There were no new mandates
regarding direct regulation of GHG emissions from power plants from this legislation.
In terms of state authority over GHG emissions, California’s Cap-and-Trade program regulates covered
entities that include cogeneration, self-generation of electricity, stationary combustion, and first
deliverers of electricity that emit 25,000 metric tons or more of CO2e per data year.v State authority also
exists over power siting. The CEC is the siting authority for thermal power plants of 50 megawatts or
more with authority that preempts local jurisdiction land use authority.vi The CEC is prohibited from
siting new nuclear power plants unless there is demonstrated technology or disposal site for high-level
i See California Air Resources Board, Prohibitions on Use of Certain Hydrofluorocarbons in Stationary Refrigeration,
Chillers, Aerosols-Propellants, and Foam End-Uses Regulation, Last Visited January 5, 2022:
https://ww2.arb.ca.gov/rulemaking/2020/hfc2020.
ii See Public Utilities Code § 380; see CPUC Resource Adequacy Proceeding R.19-11-009.
iii See 14 U.S.C. § 8240.
iv 47 H.R. 133 — 116th Congress (2019–2020): Consolidated Appropriation Act, 2021. December 27, 2020 (Public
Law No: 116-260), Division Z (Energy Act of 2020), Title IV & V: https://www.congress.gov/bill/116th-
congress/house-bill/133/text.
v 17 C.C.R. §§ 95811 (a)–(b) & 95812(c).
vi Public Resources Code §§ 25500 et seq.
Oct. 11, 2022 Item #12 Page 539 of 560
501
nuclear waste.i The Governor may also preempt local land use authority on a limited basis through an
emergency declaration.ii Finally, all electric utilities and load-serving entities are prohibited from
entering into any baseload power generating commitments of 5 years or more if such projects are not as
clean as a combined-cycle gas turbine project.iii
In terms of air quality, there is uncertainty as to the extent that a local air district may further regulate
GHG emissions in relation to CARB’s authority, U.S. EPA authority, and continued uncertainty over
power plant GHG regulations due to litigation and presidential administration changes. However,
authority exists to create voluntary GHG reduction generation and certification programs in a district.
The U.S. EPA acts with regulatory authority over existingiv and new power plantv criteria pollutantvi and
GHG emissions standards under the CAAvii with approval authority over local air district rules and
regulations for the California SIP. Any state standard must satisfy the requirements of the CAA and U.S.
EPA’s implementing regulation with U.S. EPA approved SIPs having the force and effect of federal law.viii
SIPs or parts of SIPs that are approved by a state but not yet approved by U.S. EPA are only enforceable
under state law. There is disagreement and uncertainty regarding the authority to regulate GHG
emissions directly using California air quality statutes. However, the CAA preserves state authority to
adopt stationary emissions standards that are as or more stringent than federal requirements.ix
To this end, California adopted its own air quality management statutes, which do not directly call for
the regulation of GHGs but instead mirror the federal CAA with certain sections prohibiting the
enforcement of federal regulations that are less stringent than those that existed in 2002.x Cap-and-
Trade also largely negates and may preempt additional regulation of power plant GHG emissions at the
local level. Consequently, local authority to adopt more stringent GHG standards is subject to
California’s Clean Air Act,xi California Cap-and-Trade statute, California Air Resources Board authority
and review, and U.S. EPA review. It should also be noted that a governor may issue an emergency
declaration suspending air quality regulations during specific events or over a limited period of time,
which may increase GHG emissions that must be quantified and mitigated or removed to meet state
policy.xii
The CAA regulatory framework is currently filled with uncertainty because of regulatory changes and
litigation at the federal level vacating both Obama and Trump administration GHG emissions regulations
i Public Resources Code § 25524.2.
ii See Governor’s July 30, 2021 Proclamation of A State of Emergency to address energy supply and demand issues;
see U.S. Const. Amendment X; see California Emergency Services Act: Government Code §§ 8558, 8567, 8571,
8625, & 8627.
iii Public Utilities Code §§ 8340–8341.
iv 42 U.S.C.A. § 7411 (a) & (d).
v 42 U.S.C.A. § 7411(f).
vi See 40 CFR Part 60 Subpart Da (Standards of Performance for Electricity Steam Generation Units).
vii 42 U.S.C. § 7401 et seq.
viii 42.U.S.C.A. §§ 7410 (k) & (a)(5)(A), 7413.
ix See 42 U.S.C.A. §§ 7407 & 7416.
x See Health and Safety Code § 39000 et seq.
xi Health and Safety Code §§ 42500 et seq.
xii See Governor’s July 30, 2021 Proclamation of A State of Emergency to address energy supply and demand issues;
See U.S. Const. Amendment X; See California Emergency Services Act: Government Code §§ 8558, 8567, 8571,
8625, & 8627.
Oct. 11, 2022 Item #12 Page 540 of 560
502
under CAA Section 111(b)i for new, modified, and reconstructed power plants and 111(d)ii for existing
power plants. On January 1, 2021, U.S. EPA finalized a revised rule for new, modified, and reconstructed
power plants amending existing requirements that set New Performance Source Performance Standards
(NSPS) to limit CO2 emissions from fossil fuel-fueled power plants.iii On March 17, 2021, per President
Biden’s Executive Order No. 13990, U.S. EPA asked the D.C. Circuit to vacate and remand this final rule,
which occurred on April 5, 2021,iv leaving U.S. EPA’s 2015 Final Rule in place.v In January 2021, the D.C.
Circuit struck down the Affordable Clean Energy (ACE) rule for emissions from existing power plants,vi
leaving no effective GHG regulation in place for existing power plants. Emission limits for existing power
plants are now under development. However, the U.S. Supreme Court issued a decision on June 30,
2022 that limits U.S. EPA’s ability to regulate GHG emissions from new and existing facilities and may
further limit U.S. EPA’s reliance on CAA delegated authority for regulation that touch other parts of the
economy through electricity decarbonization.vii What new regulations U.S. EPA will issue for new and
existing facilities remains uncertain at this time. The current state of affairs is reflected in SD APCD’s
Standards of Performance for Greenhouse Gas Emissions for Electric Generating Units,viii which
implements Title V thresholds for stationary sources of emissions from new or modified steam
generation units, integrated coal gasification combined cycle (IGCC), or stationary combustion turbines
that commence construction after January 8, 2014 or reconstruction/modification after June 18, 2014.
With U.S. EPA in the process of creating new standards subject to the recent U.S. Supreme Court
decision, local authority to enact more stringent requirements is uncertain but may become clearer in
the near term. The uncertainty stems from enforcement depending on non-preempted state authority
and delegated authority from U.S. EPA through the approval of a local air quality standard in the SIP.
Once U.S. EPA issues new standards, California likely will evaluate whether and how to adopt more
stringent standards under the CAA. To date, the U.S. EPA has not approvedix any of the following GHG
related local air districts rules for enforcement under California’s SIP:
• Feather River AQMD Rule 10.11x;
i 42 U.S.C.A. § 7411(f).
ii 42 U.S.C.A. § 7411 (a) & (d).
iii Federal Register, 86 FR 2542, 2542-2558 (2021): https://www.federalregister.gov/documents/2021/01/13/2021-
00389/pollutant-specific-significant-contribution-finding-for-greenhouse-gas-emissions-from-new-modified.
iv See California v. Environmental Protection Agency, No. 21-1035, order at p. 1, Document # 1893155 (D.C. Cir.
Apr. 5, 2021).
v See 40 CFR Parts 60, 70, 71, and 98 (2015): https://www.govinfo.gov/content/pkg/FR-2015-10-23/pdf/2015-22837.pdf.
vi See American Lung Association v. Environmental Protection Agency, 985 F.3d 914 (2021).
vii West Virginia v. U.S. EPA, 597 U.S. __ (2022). See also West Virginia v. U.S. EPA, Docket No. 20-1530, 142 S. Ct.
420 (2021) (petitions for writs of certiorari in No. 20-1531, No. 20-1778, and No. 20-1780, granted October 29,
2021): https://www.supremecourt.gov/DocketPDF/20/20-1530/176915/20210429133443663_2021.04.29%20-
%20West%20Virginia%20v.%20EPA%20Petition.pdf.
viii See Title 40, Part 60, Subpart TTTT:
https://www.sdapcd.org/content/dam/sdapcd/documents/rules/appendices/nsps/Subpart-TTTT.pdf.
ix See U.S. EPA Approved Air Quality Implementation Plans in California (last visited January 12, 2022):
https://www.epa.gov/sips-ca. x See FR AQMD Rule 10.11 (Adopted August 1, 2011):
https://ww2.arb.ca.gov/sites/default/files/classic/technology-clearinghouse/rules/RuleID993.pdf.
Oct. 11, 2022 Item #12 Page 541 of 560
503
• Mojave Desert AQMD Rule 1211i;
• North Coast Unified AQMD Rule 111ii; and
• Tehama County APCD Rule 7:3.iii
These rules would be enforced pursuant to authority derived from existing state air quality laws.iv It is
unclear whether California air quality law authority by itself allows enforcement without U.S. EPA
approval, specifically with regards to carbon dioxide emissions (but not other GHGs) from stationary
sources subject to Cap-and-Trade.v
Additionally, two air quality management districts have used their existing authorityvi to create
voluntary programs that certify voluntary GHG reductions generated by in district activity: South Coast
Air Quality Management District (SCAQMD) Rules 2700–2702vii and Sacramento Metropolitan AQMD
Rule 100 et seq.viii Certification of GHG reduction credits may be issued either through use of a third
party verifier (e.g., a carbon registry), through a GHG reduction project developed by the district itself,
or both. These programs are designed to allow generation ownership, sale, trade, or retirement of the
GHG reduction credit. SCAQMD’s program is notable because it allows both third-party certification for
reduction projects in its districts under Rule 2700–2701 as well as a program where a fee is paid to the
district to implement a GHG reduction project in the district under Rule 2702 using approved protocols.ix
It is unclear whether these voluntary programs are successful or whether there is authority to create
mandatory GHG reduction rules and programs. However, authority appears to exist to create a
voluntary GHG reduction program in the SD APCD.
B.4.2 Renewable Energy
Existing authority allows local jurisdictions to procure electricity supply on behalf of their citizens, to
determine the carbon content of this supply, franchise public rights of way for energy infrastructure,
and support distributed generation.
At the federal level, Executive Order 14057 directs the federal executive branch on a net-zero emissions
path by 2050. Specific to renewable energy at the utility and distributed energy level, the Executive
Order, among other things, requires:
• 100 percent carbon pollution-free electricity on a net annual basis by 2030, including 50 percent
24/7 carbon pollution-free electricity;
i See Mojave Desert AQMD Rule 1211 (Adopted February 28, 2011):
https://ww2.arb.ca.gov/sites/default/files/classic/technology-clearinghouse/rules/RuleID1972.pdf.
ii See North Coast Unified AQMD Rule 111 (July 9, 2015):
https://ww2.arb.ca.gov/sites/default/files/classic/technology-clearinghouse/rules/RuleID2138.pdf.
iii Tehama County APCD Rule 7:3 (Adopted February 1, 2011):
https://ww2.arb.ca.gov/sites/default/files/classic/technology-clearinghouse/rules/RuleID3898.pdf.
iv See Health & Safety Codes §§ 40702, 40703, 40704, 40752; See also Health & Safety Code § 42400 et seq.
v Health & Safety Code § 38594 (b).
vi Health & Safety Code §§ 39000 et seq.; see also Health & Safety Code §§ 40400 et seq. and §§ 40950 et seq.
vii South Coast AQMD Rule 2700-2702 (Adopted February 6, 2009; Amended June 4, 2010):
https://www.aqmd.gov/home/rules-compliance/rules/scaqmd-rule-book/regulation-xxvii.
viii Sacramento Metropolitan Rule 100 et seq. (adopted February 23, 2010):
https://ww2.arb.ca.gov/sites/default/files/classic/technology-clearinghouse/rules/RuleID3566.pdf.
ix South Coast AQMD Rule 2702 (Adopted February 6, 2009; Amended June 4, 2010), Table 1.
Oct. 11, 2022 Item #12 Page 542 of 560
504
• A net-zero emissions building portfolio by 2045, including a 50 percent emissions reduction by
2032;
• A 65 percent reduction in scope 1 and 2 GHG emissions, as defined by the Federal Greenhouse
Gas Accounting and Reporting Guidance, from Federal operations by 2030 from 2008 levels; and
• Net-zero emissions from Federal procurement, including a Buy Clean policy to promote the use
of construction materials with lower embodied emissions; and
• Climate resilient infrastructure and operations.i
Implementing these orders will impact federal facilities across the San Diego region and may create
opportunities to scale and benefit from federal action at the local jurisdiction level.
California’s renewable portfolio standard (RPS) requires 60% renewable energy supply by 2030 for all
load-serving entities with SB 100 (de León, Chapter 312, Statutes of 2018), further mandating that load-
serving entities procure 100% carbon-free electricity by 2045.ii The CEC certifies the eligibility of
generating resources to patriciate in the RPS with state law changing eligibility requirements over time
(e.g., renewable hydrogen-fueled generation and biomethane).iii CPUC regulated load serving entities
may be required by the CPUC to exceed the RPS procurement target,iv which suggests that local
jurisdiction may petition the CPUC to require the local electric corporation to procure higher renewable
energy content for their customers. CPUC regulated load serving entity may also voluntarily exceed
procurement targets for any year of a three-year compliance period under the RPS for later use in a
subsequent compliance period if it meets CPUC requirements.v This allows the load serving entity to
supply higher renewable energy contents earlier than a target year. SB 350 (2015) also required the
CPUC to create an integrated resource planning (IRP) that forms the regulated load serving entities (LSE)
component of the ten-year prospective long-term procurement plan to meet state mandates and ensure
reliability.vi This process sets procurement targets to achieve California GHG reductions for CPUC
regulated LSEs with the current proceeding seeking to implement significant energy storage and
renewable energy procurement that further decrease GHG emissions.vii
California offers limited retail competition options in the form of statutes that authorize both a direct
access (DA) programviii to serve a statutorily capped number of commercial customers and the creation
of community choice aggregators (CCA) to serve all customers. This further complicates decarbonizing
electric supply because there may be an IOU, CCA, and/or DA supplying electricity to customers in a
i Presidential Executive Order No. 14057, Catalyzing Clean Energy Industries and Jobs Through Federal
Sustainability, 86 Federal Register 70935 (No. 2021-27114), Sec. 102 (December 8, 2021):
https://www.whitehouse.gov/briefing-room/presidential-actions/2021/12/08/executive-order-on-catalyzing-clean-energy-
industries-and-jobs-through-federal-sustainability/ & https://www.federalregister.gov/documents/2021/12/13/2021-
27114/catalyzing-clean-energy-industries-and-jobs-through-federal-sustainability.
ii See Public Utilities Code §§ 399.11 et seq.
iii See California Energy Commission, Commission Guidebook Renewable Portfolio Standard Eligibility, Ninth
Revised Edition, CEC-300-2016-006-ED9-CMF-REV (January 2017).
iv Public Utilities Code § 399.15 (b)(3).
v Public Utilities Code § 399.13 (A)(5)(B).
vi See Public Utilities Code §§ 454.51 & 454.52.
vii See CPUC Proceeding R.16-02-007, Order Instituting Rulemaking to Develop an Electricity Integrated Resource
Planning Framework and to Coordinate and Refine Long-Term Procurement Planning Requirements:
https://apps.cpuc.ca.gov/apex/f?p=401:56:0::NO:RP,57,RIR:P5_PROCEEDING_SELECT:R1602007; see CPUC R.20-
05-003, Order Instituting Rulemaking to Continue Electric Integrated Resource Planning and Related Procurement
Processes: https://apps.cpuc.ca.gov/apex/f?p=401:56:0::NO:RP,57,RIR:P5_PROCEEDING_SELECT:R2005003.
viii See Public Utilities Code § 365.1.
Oct. 11, 2022 Item #12 Page 543 of 560
505
local jurisdiction. California Constitution Article XI, § 9 also allows local jurisdictions, as municipal
corporations, to establish, purchase, and operate public works to furnish light, water, power, heat, and
other services to residents. These services may be offered outside of a local government’s boundaries
with the consent of the applicable jurisdiction. However, there are no publicly owned electric or natural
gas utilities in the San Diego region and the limited retail competition options of DA and CCAs are used
in the region with the effect that local jurisdictions do not own the electric and natural gas distribution
and transmission systems.
Local jurisdictions also control the public right-of-way needed to deliver electricity, natural gas, or any
other molecule like hydrogen to customers. Local jurisdictions operate with long-term or perpetual
franchise agreements that set terms for SDG&E to install and operate its infrastructure in the public
right-of-way. Franchise agreements provide revenue to local jurisdictions and complicate the removal of
infrastructure. However, it may be possible to exercise franchise rights as a way to increase renewable
energy fuel, such as renewable hydrogen for power plant consumption, by either repurposing existing
infrastructure or building new infrastructure.
Local governments act with the ability to procure their own supply of electricity under a CCAi — such as
San Diego Community Energyii and Clean Energy Allianceiii — subject to requirements like the RPS. CCAs
allow local jurisdictions to exceed the RPS targets (e.g., 100% renewable energy) through the
procurement authority of the CCA to serve customers. CCAs are subject to reliability requirements under
state and federal law, which may complicate achieving a 100% renewable energy supply portfolio or
require carbon removal to address carbon emissions from resources that must run for reliability
purposes to prevent brown or blackouts. CCAs are opt-in by default, but customers may opt-out to
return to the incumbent utility or to a DA electric service provider if there is room under the DA cap.
IOUs are also the provider of last resort (POLR) per SB 520 (Hertzberg, Chapter 408, Statutes of 2019),
currently being instituted by CPUC decisions under R.21-03-011, further complicating decarbonization of
supply portfolios to supply customers that either leave CCAs or DA providers or where a CCA or DA
provider fails resulting in customers returning to the incumbent IOU.iv
Police power allows local jurisdictions to determine the supply portfolio supplied from a CCA for their
citizens and businesses in their jurisdictions pursuant to either a general plan GHG mitigation plan (e.g.,
climate action plan)v or as part of their membership in a CCA. This allows a local government by
resolution to procure a high or 100% renewable energy supply as the default offering for all of their
municipal accounts and/or all of the CCA customers in that jurisdiction who do not opt-out.vi
Local jurisdictions also play an essential role in furthering distributed generation through CCAs, reach
codes, and permit streamlining. CCAs can create distributed generation procurement programs in the
form of net energy metering or feed-in tariffs (FIT) to increase customer installation of renewable
energy generation, including energy storage. Under net energy metering, the CCA credits the customer
i See AB 117 (Migden, Chapter 838, Statutes of 2002).
ii Includes Cities of San Diego, Imperial Beach, Encinitas, La Mesa, Chula Vista, and the County of San Diego.
iii Includes Cities of Carlsbad, Del Mar, and Solana Beach.
iv See Western Community Energy Chapter 9 Bankruptcy: Western Community Energy, 6:21-bk-12821-SY (Bankr.
C.D. Cal.) (Filed May 24, 2021).
v See CEQA Guidelines § 15183 (2021) (14 C.C.R. § 15183).
vi See City of Encinitas Regular City Council Meeting, February 24, 2021, Agenda Item 10B: Adopt Resolution 2021-
17: https://encinitas.granicus.com/MetaViewer.php?view_id=7&clip_id=2347&meta_id=120211.
Oct. 11, 2022 Item #12 Page 544 of 560
506
for the net generation exported to the grid after the onsite load is served. Under a FIT, the CCA pays the
customer for all generation produced by the generating resource with no onsite load served. In terms of
reach codes, Title 24 now requires new low-rise residential construction (1–3 stories) to install solar.
However, local jurisdiction may require additions and alterations of existing residential and
nonresidential buildings to install solar if it is cost-effective pursuant to Public Resource Code § 25402.1
(h)(2) and Title 24, Part 6, Section 10-106. Finally, AB 2188 (Muratsuchi, Chapter 521, Statutes of 2014)
requires permit streamlining for small residential rooftop solar systems and AB 45 (Blakeslee, Chapter
404, Statutes of 2009) encourage adoption of county ordinances to reduce permitting obstacles for
small wind energy systems. Local jurisdictions act with the authority to further streamline permitting
and decrease cost for these types of energy systems or to expand streamlined permit review to more
extensive systems or additional types of buildings (e.g., nonresidential for rooftop solar).
B.5 Local Authority Related to Natural Climate Solutions and Other Land Use
Considerations
The San Diego region is composed of federal, tribal, state, local, and privately held land. The following
will discuss authority over this land, submerged land, water, and coast (land(s)). Authority over the
land(s) directly determines its uses, potentially limiting whether the use can support GHG reductions,
removal, and/or storage. The following will review federal, tribal, California, and local authority. It
concludes with an analysis on agricultural land.
B.5.1 Federal Authority Over Natural Climate Solutions and Other Land Use Considerations
The primary actions local jurisdictions may take related to federal lands is through lobbying Congress,
engaging with federal lands management agencies to create government to government agreements
(e.g., a memorandum of understanding (MOU)), and working directly with federal lands managers to
achieve local objectives across the region.
The U.S. Government owns fee titles in surface land, subsurface mineral rights, less-than-fee in other
surface and mineral rights,i mineral resources under the outer continental shelf, and living marine
resources out to 200 miles offshore.ii Federal land in the San Diego region includes national forest, land
managed by the Bureau of Land Management, a national monument, wildlife refuge, and land managed
by the Department of Defense.
Federal public land law is complex, requiring specific legal and factual analysis that may involve both the
Administrative Procedure Act (APA) of 1946iii and the National Environmental Policy Act (NEPA) of
1969.iv Waters of the United States also include wetlands that are regulated under Section 404 of the
Clean Water Act administered by the U.S. Army Corps of Engineers.v Specific to geological carbon
i The United States owns severed surface estates, severed mineral estates, easements for access, acquired
"wetlands easements" for the benefit of migratory waterfowl, and general conservation or nondevelopment
easements.
ii Fisheries Conservation and Management Act of 1976, 16 U.S.C.A. §§ 1801–1882.
iii 5 U.S.C.A. §§ 551–706.
iv 42 U.S.C.A. §§ 4321–4370d.
v 33. U.S.C.A § 1344; See generally 33 U.S.C.A. §§ 1251 et seq., U.S. Army Corps of Engineers implementing
regulations at 33 C.F.R. §§ 320–330 and U.S. EPA § 404(b)(1) Guidelines for Specification of Disposal Sites for
Dredged or Fill Material at 40 C.F.R. §§ 230–233.
Oct. 11, 2022 Item #12 Page 545 of 560
507
sequestration on public lands, the Energy Independence and Security Act of 2007 required the Secretary
of the Interior to submit to the House Committee on Natural Resources and Senate Committee on
Energy and Natural Resources, in coordination with U.S. EPA, the Secretary of Energy, and heads of
other appropriate agencies, a report:
• Recommending criteria for identifying candidate geological sequestration sites in statutorily
specified types of geological settings (e.g., oil & gas fields, saline formations, etc.);
• A proposed regulatory framework for the leasing of public land or an interest in public land for the
long-term geological sequestration of carbon dioxide, proposed procedures to ensure public review
and comment and protection of natural and cultural resources;
• A description of the status of Federal leasehold or Federal mineral estate liability issues related to
the geological subsurface trespass of or caused by carbon dioxide stored in public land, including
any relevant experience from enhanced oil recovery using carbon dioxide on public land;
• Recommendations for additional legislation that may be required to ensure that public land
management and leasing laws are adequate to accommodate the long-term geological
sequestration of carbon dioxide;
• An identification of the legal and regulatory issues specific to carbon dioxide sequestration on land
in cases in which title to mineral resources is held by the United States but title to the surface
estate is not held by the United States;
• An identification of the issues specific to the issuance of pipeline rights-of-way on public land under
the Mineral Leasing Act (30 U.S.C. 181 et seq.) or the Federal Land Policy and Management Act of
1976 (43 U.S.C. 1701 et seq.) for natural or anthropogenic carbon dioxide; and
• Recommendations for additional legislation that may be required to clarify the appropriate
framework for issuing rights-of-way for carbon dioxide pipelines on public land.i
This report is a starting point for sequestration activity on federal lands and should be used in concert
with land use authority described below.
Additionally, the Energy Act of 2020 amended the Energy Policy Act of 2005 (42 U.S.C.A § 16291 et seq.)
to establish a research, development, and demonstration program to test, validate, or improve
technologies and strategies to remove carbon dioxide from the atmosphere on a large scale through
activities that include:
• Direct air capture and storage technologies;
• Bioenergy with carbon capture and storage technologies;
• Enhanced geological weathering;
• Agricultural practices;
• Forest management and afforestation; and
• Planned or managed carbon sinks, including natural and artificial.ii
There is opportunity at the state and local level to develop and demonstrate or benefit from projects
funded by this legislation. Further efforts should be made to investigate this opportunity, particularly
with regard to federal land in the region.
i Public Land No. 110-140, § 714(a), 121 Stat. 1492, 1715.
ii 47 H.R. 133 — 116th Congress (2019–2020): Consolidated Appropriation Act, 2021. December 27, 2020 (Public
Law No: 116-260), Division Z (Energy Act of 2020), Title V: https://www.congress.gov/bill/116th-congress/house-
bill/133/text.
Oct. 11, 2022 Item #12 Page 546 of 560
508
The following will provide a general explanation of the four primary federal public lands and resources
agencies. An analysis of the Department of Defense is excluded but the Department of Defense should
be included in any regional negotiations and planning. The analysis focuses on opportunities for local
governments or the State of California to engage federal lands managers based on federal lands and
resources in the San Diego region:
• National Parks Service (NPS): The National Park System Act of 1916i is the primary law governing
national parks; the Act grants the NPS broad discretion in achieving its main goals of preservation
and recreation. The National Parks and Recreation Act of 1978ii creates general planning
obligations for the NPS. The Antiquities Act of 1906iii authorizes the presidential designation of
national monuments and the protection of scientific and historical objects. It may be used to
preserve additional land in the San Diego region where such land is already federally owned and
the designation limited to the smallest area compatible with preservation for “historic or scientific
interest,”iv with courts often granting deference to presidential discretion. The Cabrillo National
Monument is the only NPS land in the San Diego region established by Presidential Proclamation
4319 (September 28, 1974).
The NPS’s discretion in achieving its mission suggests that partnering with local jurisdictions to decrease
carbon emissions related to the Cabrillo Monument and increase natural land carbon removal may
be feasible. Any action would need to be consistent with the purpose of creating the Cabrillo
National Monument.v It may also be possible to preserve land through the creation of a national
park or additional monument in the San Diego region.
• Fish and Wildlife Service (FWS): FWS mission includes land management of wildlife refuge system
units created by statute and presidential executive proclamation, and national regulation for
wildlife protection that applies off and on federal lands. Wildlife refuge system units are governed
by the National Wildlife Refuge System Administration Act of 1966,vi the National Wildlife Refuge
System Improvement Act of 1997,vii the Refuge Recreation Act of 1962,viii and the Refuge Revenue
Sharing Act of 1964.ix The National Wildlife Refuge Act of 1997 also created three tiers of use: 1)
Conservation of wildlife, plants, and their habitats; 2) If human use is allowed, wildlife-dependent
recreational uses are entitled to the highest priority; and 3) All other uses with the lowest priority
or prohibition of use.x,xi There is some level of discretion afforded to FWS officials with regards to
uses. Funds to acquire refuge land are authorized by specific appropriation or under multiple
existing statutes including: the Land and Water Conservation Fund Actxii; the Migratory Bird
i 54 U.S.C.A. §§ 100101–100906.
ii 54 U.S.C.A. §§ 100101, 100502, 100507, 100751, 100754, 100901, 100906, 100302, 100702-100703, 100751,
100754, 101301, 10212, 101302, 102701-102702, 104906.
iii 54 U.S.C.A. §§ 320301-320303.
iv 54 U.S.C.A. § 320301.
v See United States v. City & County of Denver, 656 P.2d 1 (Colo. 1982).
vi 16 U.S.C.A. §§ 668dd–668ee.
vii Public Law No. 105-57, 111 Stat.1252.
viii 16 U.S.C.A. §§ 460k–460k-4.
ix 16 U.S.C.A. § 715s.
x 16 U.S.C.A. § 668dd(a)(2).
xi See 71 Fed. Reg. 36408 (2006); Final Appropriate Refuge Uses Policy, available at
http://policy.fws.gov/ser600.html.
xii 54 U.S.C.A. §§ 100506, 100904 to 100905, & 200301–200310.
Oct. 11, 2022 Item #12 Page 547 of 560
509
Conservation Act of 1929i; and the Water Bank Act of 1970.ii FWS acts with exclusive or shared
enforcement authority over wildlife affecting federal, state, and private land. These include the:
Endangered Species Act (ESA) of 1973iii; the Migratory Bird Treaty Act of 1918iv; the Bald Eagle
Protection Act of 1940v; and the Marine Mammal Protection Act of 1972.vi FFWS administration
includes the San Diego National Wildlife Refuge.
There is some level of discretion afforded to FWS officials with regards to uses that should be further
analyzed. Opportunities may include increasing the size of existing refuge and working with FWS
officials to exercise their discretion in a way that benefits regional decarbonization goals.
• Bureau of Land Management (BLM): BLM administers federal lands not reserved to parks or
refuge under a complex statutory regime that dates back to the founding of the Republic. BLM
authority comes from: the Federal Land Policy and Management Act (FLMP) of 1976,vii range
management authority contained in the Taylor Grazing Act of 1934viii and Public Rangelands
Improvement Act of 1978,ix land manager authority contained in the FLMP,x Color of Title Act,xi
and Desert Lands Act of 1877,xii and mineral manager authority under General Mining Law Act of
1872,xiii the Mineral Leasing Act of 1920,xiv the Acquired Lands Leasing Act of 1947,xv and
Geothermal Steam Act of 1970.xvi
BLM land managers act with broad discretion to plan and manage land and resources. Local BLM
managers act with different authorities when compared to U.S. Forest Service officials, who must
change already established localized plans developed in compliance with existing broad agency rules
that limit discretion. This may provide an opportunity for local jurisdictions to work directly with
local BLM land managers on decarbonization efforts in the San Diego region.
• The U.S. Forest Service (U.S.F.S.): The Organic Act of 1897xvii grants authority over forest land,
defines the purpose of national forest management, and set strict limits on timber harvest. Some
management practices, like livestock grazing, administrative wilderness designation, and multi-use
management actions were later codified in law. The Organic Act of 1897 originally granted a wide
range of management discretion. However, the National Forests are now managed with less
discretion because of the Forest and Rangelands Renewable Resources Planning Act (RPA) of
i 16 U.S.C.A. §§ 715–715r.
ii 16 U.S.C.A. §§ 1301–1311.
iii 16 U.S.C.A. §§ 1531–1543.
iv 16 U.S.C.A. §§ 703–711.
v 16 U.S.C.A. §§ 668–668d.
vi 16 U.S.C.A. §§ 1361–1407.
vii 43 U.S.C.A. §§ 1701–1784.
viii 43 U.S.C.A. §§ 315–315r.
ix 43 U.S.C.A. §§ 1901–1908.
x 43 U.S.C.A. §§ 1713–1721.
xi 43 U.S.C.A. §§ 1068–1068b.
xii 43 U.S.C.A. §§ 321–323.
xiii 30 U.S.C.A. §§ 22–47.
xiv 30 U.S.C.A. §§ 181–287.
xv 30 U.S.C.A. §§ 351–354.
xvi 30 U.S.C.A. §§ 1001–1026.
xvii 16 U.S.C.A. §§ 473–482 (partially repealed 1976).
Oct. 11, 2022 Item #12 Page 548 of 560
510
1974, as amended by and merged into the National Forest Management Act (NFMA) of 1976,i
which created an inclusive forest wide planning process for the entire national forest system,
including localized planning. This authority grants discretion to U.S.F.S. to create broad,
encompassing management regulations but compliance with these regulations limits local
manager discretion over local plans. Forest land is also affected by the FLPMA,ii wilderness
designations,iii and the Endangered Species Act of 1973.iv
Because there are localized planning requirements and less manager discretion, there is less
flexibility with National Forest land than BLM land without amending or creating a new local plan
under the NFMA. However, the inclusion of decarbonization actions in U.S.F.S. authority to issue
broad rules of applicability to manage forest land does create an opportunity for local jurisdictions
to engage in the U.S.F.S. regulatory process that affects local planning in addition to advocating for
changes to existing local plans, such as the Cleveland National Forest Land Management Plan.
B.5.2 Tribal Authority Over Natural Climate Solutions and Other Land Use Considerations
States and local governments generally act with limited to no authority over tribal land use and activity.
Cooperative intergovernmental policies and agreements that support tribal land preservation, land
conservation, and decarbonization efforts through mechanisms that include the fee-to-trust process
appear to be existing paths to work with tribes in achieving regional decarbonization goals.
There are eighteen federally recognized tribes and seventeen tribal governments (Note: the Barona and
Viejas Bands share joint-trust and administrative responsibility for the Capitan Grande Reservation) in
the San Diego region.v In terms of natural resources, tribal and individual aboriginal titles include
exclusive rights to use land and resources unless abrogated by treaty or statute.vi On trust and restricted
lands, the U.S. holds natural resources in trust for the tribal or individual owner, owing a fiduciary duty
to the tribe or allottee. Federal executive authority over Indian Affairs, including trust land, flows from
the President to the Secretary of the Interior and through delegation to the Bureau of Indian Affairs
(BIA).vii BIA regulations include: the process to acquire land in trust status for a tribe or individual Indians
(fee-to-trust) viii; removing restrictions on the alienation of Indian allotmentsix; approval and cancelation
of leases on tribal and individual trust landx; issuance of grazing permits on Indian landxi; governing the
leasing of mineral resourcesxii; management of timber resources on tribal landxiii; regulation of certain
i 16 U.S.C.A. §§ 1600–1616.
ii 43 U.S.C.A. §§ 1732(b), 1751–1753, & 1765–1771.
iii 16 U.S.C.A. §§ 1131–1136.
iv 16 U.S.C.A. §§ 1131–1136.
v Note: the San Luis Rey Band of Luiseño Indians and Mount Laguna Band of Luiseño Indians Tribal Governments do
not have federally recognized land but are active in the region.
vi See, e.g., United States v. Dann, 873 F.2d 1189 (9th Cir. 1989), on remand from United States v. Dann, 470 U.S. 39
(1985) (individual aboriginal use rights).
vii See 25 U.S.C.A. §§ 1, 1s, & 2; 43 U.S.C.A. § 1457.
viii 25 C.F.R. part 151.
ix 25 C.F.R. part 152.
x 25 C.F.R. part 162.
xi 25 C.F.R. part 166.
xii 25 C.F.R. parts 200, 211, 212, 225.
xiii 25 C.F.R. § 163.
Oct. 11, 2022 Item #12 Page 549 of 560
511
fishing activitiesi; regulation of Indian tradersii; implementation of portions of the Indian Gaming
Regulatory Actiii; and regulation of certain water rights and irrigation issues.iv
Indian tribes possess the inherent power to govern their territories. While these powers may be limited
by federal laws in certain respects, the authority over tribal health and welfare remains substantial,
allowing tribes to act to the full limit of their inherent governmental authority.v Tribes may enact
environmental tribal codes that establish standards, permit requirements, and penalties for violations
and provide for enforcement in tribal court and through tribal agency proceedings. Tribes may also
exercise environmental law authority delegated by Congress, with tribes assumed to be the primary
regulatory authority or to have primacy for administering most federal environmental law programs.vi
Federal environmental law applies in a tribal territory with either the tribe or the federal agency —
generally the U.S. EPA — responsible for administering the environmental statute.vii
States and local governments generally act with limited to no authority over tribal land use and
activity.viii State and local environmental laws do not apply to Sovereign Tribal Nations unless required
by the Compact with the Stateix or through independent agreements between Tribal Governments and
local agencies. Local jurisdictions may enact policies that affect tribal land expansion through the
existing fee-to-trust applications process, which transfers purchased land to the BIA as trustee.x Per SB
712 (Hueso, Chapter 291, Statutes of 2021), local jurisdictions are now encouraged to work
cooperatively with tribes in a tribe’s nongaming fee-to-trust application and prohibited from adopting or
enforcing a resolution or ordinance that prevents the local government from conducting a fair evolution
of the application based on its merits. The County of San Diego recently acted before this law was signed
by the Governor by voiding Resolution Nos. 94-115, which created a blanket policy of opposition to fee-
to-trust applications in 1994, and 01-162, which set strict criteria for liquor licenses, in May of 2021. The
County of San Diego will be compliant with SB 713 (2021) as it takes effect on January 1, 2022, creating a
cooperative intergovernmental policy that can support tribal land preservation, land conservation, and
decarbonization efforts through the fee-to-trust process.
i 25 C.F.R. parts 241, 242, 247–249.
ii 25 C.F.R. part 140.
iii 25 C.F.R. parts 290 and 291.
iv 25 C.F.R. parts 159, 171–173.
v See Backcountry Against Dumps v. EPA, 100 F.3d 147, 151 (D.C. Cir. 1996).
vi See 1 Cohen's Handbook of Federal Indian Law § 10.01 (2021).
vii See Donovan v. Coeur d’ Alene Tribal Farm, 751 F.2d 1113, 1116 (9th Cir. 1985) (quoting United States v. Farris,
624 F.2d 890, 893–894 (9th Cir. 1980)).
viii See Worcester v. Georgia, 31 U.S. 515 (1832).
ix See Indian Gaming Regulatory Act of 1988 (Public Law 100-497; 18 U.S.C.A. §§ 1166 et seq. & 25 U.S.C.A §§ 2701
et seq.).
x See County of San Diego Resolution No. 94-115 (1994) creating policy to oppose all tribal fee-to-trust applications
and Resolution No. 01-162 (2001) adopting strict criteria for tribal liquor licensing for their facilities (both
resolutions voided by a 4-1 vote on May 5, 2021 of the County of San Diego Board of Supervisor- Land Use, Regular
Meeting, Agenda Item No. 9: “FRAMEWORK FOR OUR FUTURE: COOPERATIVE APPROACH TO TRIBAL
GOVERNMENTS AND FEE TO TRUST PROPOSALS”: https://bosagenda.sandiegocounty.gov/cob/cosd/cob/doc?id=0901127e80cfcf57;
https://bosagenda.sandiegocounty.gov/cob/cosd/cob/doc?id=0901127e80cfdd81).
Oct. 11, 2022 Item #12 Page 550 of 560
512
B.5.3 State of California Authority Over Natural Climate Solutions and Other Land Use
Considerations
B.5.3.1 General Authority
State ownership and authority over state and private natural and working lands are inextricably tied to
federal public lands and statutes. Federal lands are often geographically contiguous with state land or
surrounds state land acquired from a federal government grant or state acquisition of federal land. For
example, the equal footing doctrine and Submerged Lands Act of 1953i presumes that states own title to
submerged lands beneath inland navigable waters and beneath territorial waters within three nautical
miles of the state’s coast. Additionally, federal land grants are often restricted, limiting state discretion
as to the use and disposition of the land.ii
Beyond state land with a federal nexus, California actively manages natural and working lands through
various agencies with a wide range of authority and missions. State authority and specific agency
authority to preempt local police power over zoning is narrow and limitediii to specific statewide objects.
These objectives include housing requirements that determine the number of residential units to be
zoned, including affordable housing, but not where the units should be zoned.iv They also include
specific areas, such as the coastal zone or under the Subdivision Map Act,v which allows specified local
supplementary regulation.vi State preemption over charter city municipal affairs is expressly limited by
California Constitution Article XI, §§ 3 and 5. Additionally, CEQA applies to a broad range of projects, as
defined, on natural and working lands and is a major consideration when analyzing land and resource
uses. The California Endangered Species Act may also affect use of habitat and would need to be
specifically analyzed.vii The following discusses both state policy and relevant laws and agencies.
AB 32 (2006) and SB 32 (Pavley, Chapter 249, Statutes of 2016) authorized programs — such as Cap-and-
Trade — do not directly regulate land use. However, SB 1386 (Wolk, Chapter 545, Statutes of 2016)
established protecting and managing natural and working lands as state policy to be considered by all
parts of the state government, that this policy is important to achieving California’s GHG reduction
goals, and that state policy includes the intent to promote cooperation of owners of natural and working
lands. In addition, the carbon neutrality by 2045 target required by 2018 Executive Order B-55-18’s
incorporates working lands, including agriculture, in the 2022 AB 32 Scoping Plan update that is in draft
form and expected to be approved by the end of 2022. CARB completed several technical working
groups on natural and working lands as part of the Scoping Plan update, with the most recent on
December 2, 2021. In addition, CARB is developing methods to model business-as-usual and several
alternatives that will inform statewide goals in the 2022 Scoping Plan for five natural and working land
categories: 1) forest, shrubland, and grasslands; 2) agriculture; 3) settlements (e.g., urban forests,
wildland urban interface, and rural intermix and influence forests); 4) wetlands; 5) deserts and other
i Submerged Lands Act, 43 U.S.C.A. §§ 1301–1315: The 1953 Act gave coastal states title to the offshore lands three
miles seaward from the coastline; See also United States v. Alaska, 521 U.S. 1 (1997) (ANWR Ownership).
ii George Cameron Coggins and Robert L. Glicksman, Public Natural Resources Law, § 1:7 (2nd Ed., October 2021
Update).
iii See Government Code § 65000 et seq.; See Scrutton v. County of Sacramento, 275 Cal. App. 2d 412, 417 (1978).
iv See Government Code §§ 65913.1(a), 65863.5, 65583(a)(3), 65584, & 65584.01.
v Government Code §§ 66410 et seq.
vi See Government Code §§ 66411, 66421, 66477, 66478, 66479, 66483, & 66484; see also Friends of Lake
Arrowhead v. Board of Supervisors, 38 Cal. App. 3d 497, 505, (1974).
vii Fish and Game Code § 2050 et seq.
Oct. 11, 2022 Item #12 Page 551 of 560
513
lands.i
Executive Order B-55-18 was furthered in 2020 by Executive Order N-82-20’s language regarding
biodiversity, 30% land and coastal water conservation, acceleration of natural carbon sequestration and
climate resiliency on natural and working lands, and creation of the Natural and Working Lands Climate
Smart Strategy, including setting a statewide target to meet the 2045 carbon neutrality goal. The
legislature codified part of Executive Order N-82-20 under SB 27 (Skinner, Chapter 237, Statutes of 2021)
regarding establishing a Natural and Working Land Climate Smart Strategy that includes developing a
framework to achieve California’s climate goals and mandates CARB to set CO2 removal targets for 2030
and beyond under its Scoping Plan for all emission sectors including those in this framework. Finally, SB
27 (2021) requires the Natural Resources Agency to create a carbon removal and sequestration registry
to identify, list, fund projects by state agencies and private entities, and retire projects in the state that
drive climate action on the state’s natural and working lands.
Previously, the 2017 AB 32 Scoping Plan, guided by SB 1386 (2016), sought to address GHG emissions
from natural and working lands, including forests, rangelands, agriculture, wetlands, and soils. The 2017
Scoping Plan sought to maintain natural and working “land as carbon sinks (i.e., net zero or negative
GHG emissions) and, where appropriate, minimize the net GHG and black carbon associated with
management, biomass utilization, and wildfire events”ii out to 2030 as it predated the 2018 executive
order for carbon neutrality. It set a target of sequestering and avoiding emissions in this sector by at
least 15–20 million metric tons by 2030.
The 2022 Draft AB 32 Scoping Plan takes a different track after modeling projected carbon stock losses
on natural and working lands that increase over time.iii It instead seeks to mitigate emissions from
natural and working lands through active climate smart land management. Strategies from the 2022
Draft AB 32 Scoping Plan specific to natural and working lands (excluding agriculture discussed below),
include but are not limited to:
• Increasing forest, shrubland, and grassland management to at least 2.3 million acres a year;
• Increasing annual investment in urban trees in developed lands by at least 20 percent above
historic levels and establishing defensible space on all parcels;
• Restoring at least 60,000 acres, or approximately 15 percent of all Sacramento–San Joaquin River
Delta (Delta) wetlands, by 2045; and
• Cutting land conversion of deserts and sparsely vegetated landscapes by at least 50 percent
annually from current levels.iv
CARB and related agencies completed a Natural and Working Lands Climate Change Implementation
Plan (NWL Implementation Plan) in April 2019. The NWL Implementation Plan was informed by SB 859
(Committee on Budget and Fiscal Review, Chapter 368, Statutes of 2016) Natural and Working Land
Inventory that quantitatively estimated the existing state of ecosystem carbon stored in the State’s land
base and excluded GHG emissions associated from direct human activity quantified in CARB’s annual
i See 2022 Scoping Plan Update Modeling and Scenario Workshop, Natural and Working lands, December 2, 2021:
https://ww2.arb.ca.gov/sites/default/files/2021-12/NWLPublicWorkshopSlides_Dec2_PublicDistribution.pdf.
ii CARB California’s 2017 Climate Change Scoping Plan (November 2017), p. 81:
https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/scoping_plan_2017.pdf.
iii CARB Draft 2022 Scoping Plan Update, May 10, 2022, pp. 200-201:
https://ww2.arb.ca.gov/sites/default/files/2022-05/2022-draft-sp.pdf. iv CARB Draft 2022 Scoping Plan Update, May 10, 2022, p. 201: https://ww2.arb.ca.gov/sites/default/files/2022-
05/2022-draft-sp.pdf.
Oct. 11, 2022 Item #12 Page 552 of 560
514
statewide GHG inventory.i The NWL Implementation Plan sets targets out to 2030 and pathways to at
least double the pace and scale of state-funded restoration and management activities, including: 1)
increasing the acreage in soil conservation practices for cultivated land and rangelands by five times to
change agricultural land from a net emitter to a sink by 2030; 2) doubling the pace and scale of forest
managed or restored; 3) tripling the pace of restoration of oak savannas and riparian areas; and 4) and
doubling the rate of wetland seagrass restoration.ii The Draft 2022 AB 32 Scoping Plan calls for a ten
times increase to forest, shrublands, and grassland management and a five times increase in healthy soil
practices.iii The NWL Implementation Plan also calls for a wide range of activities and acreage goals
based across activities and land types.iv
B.5.3.2 Specific Statutes and Agencies Applicable in San Diego Region
The following discusses specific statutes and agencies that regulate natural and working lands in the San
Diego region. It is non-exhaustive.
The California Coastal Act of 1976v created the California Coastal Commission that administers planning
and permitting regulatory schemes over California’s coastal land and territorial waters (including
wetlands in the coastal zonevi) to balance uses with protecting coastal natural resources. The coastal
zone is as defined in identified maps by the legislature. Local jurisdictions, including ports through
certification of port master plans, play a primary role in implementing the Coastal Act by developing
local coastal plans (LCPs) for certification by the Coastal Commission that determine use and density.
LCPs are subject to CEQA and congruent with the local jurisdiction’s GPvii and become part of the GP
once adopted.viii Once certified, the California Coastal Commission delegates authority to issue coastal
development permits to the local jurisdiction or port. The Coastal Commission retains jurisdictions over
tidelands, submerged land, public trust lands, any state university or college within the coastal zone,ix
where an LCP is not certified, and on appeal of certain types of developments.x The Coastal Commission
is also designated as a planning and management agency under the Federal Coastal Zone Management
Act of 1972. It determines consistency with California’s federally approved coastal management
program with regards to proposed federal activity or federal permitted activity within the coastal zone.xi
The Public Trust Doctrine, enshrined in California Constitution Articles I, § 25, Article X §§ 3–4, and
Article XVI, § 6, creates the basis for stewardship of lands, waterways, and resources entrusted to the
i See CARB California Natural and Working Land Inventory (2018), pp. 7 & 15: https://ww2.arb.ca.gov/nwl-
inventory .
ii See January 2019 Draft California 2030 Natural and Working Lands Climate Change Implementation Plan
(Updated January 2019), p. 13–14: https://ww2.arb.ca.gov/sites/default/files/2020-10/draft-nwl-ip-040419.pdf.
iii CARB Draft 2022 Scoping Plan Update, May 10, 2022, p, 55, 201:
https://ww2.arb.ca.gov/sites/default/files/2022-05/2022-draft-sp.pdf.
iv See January 2019 Draft California 2030 Natural and Working Lands Climate Change Implementation Plan
(Updated January 2019), p. 14–20: https://ww2.arb.ca.gov/sites/default/files/2020-10/draft-nwl-ip-040419.pdf.
v See Government Code § 30000 et seq.
vi See California Coastal Commission Procedural Guidance for the Review of Wetland Projects in California’s Coastal
Zone, Chapter 3: https://www.coastal.ca.gov/wetrev/wettc.html.
vii Public Resources Code §§ 301085 & 30108.6.
viii Citizens of Goleta Valley v. Board of Supervisors, 52 Cal. 3d 553, 571 (1990).
ix Public Resources Code § 30519(b).
x Public Resources Code §§ 30519, 30603(a), & 30604.
xi Public Resources Code § 30330; 16 U.S.C.A. § 1456(c).
Oct. 11, 2022 Item #12 Page 553 of 560
515
state. Accordingly, the State Lands Act created the California State Lands Commission to manage tide
and submerged lands and the beds of naturally navigable rivers, streams, lakes, bays, estuaries, inlets,
and straits.i This includes classifying any or all state lands for their different possible uses and leasing
and sale of state land (including oil and gas leases in the California Coastal Sanctuaryii).
The California Department of Fish and Wildlife acts with authority over wetland resources associated
with rivers, streams, and lakes which is broader than U.S. Army Corps of Engineer authority under Clean
Water Act Section 404 because it includes streamside habitats.iii This authority allows the regulation of
work that: substantially diverts, obstructs, or changes the natural flow of a river, stream, or lake;
substantially changes the bed, channel, or bank of a river, stream, or lake; uses material from a
streambed; or deposits or disposes of debris, waste, or other material containing crumbled, flaked, or
ground pavement where it may pass into any river, stream, or lake, including a broad range of activities
such as gravel mining and timber harvesting.iv
The State Water Resources Control Board acts with authority over “waters of the state” under the
Porter-Cologne Water Quality Act that are not under federal jurisdiction.v The State Water Resources
Control Board regulates projects filling wetlands through General Orders that local Regional Water
Quality Boards implement. In addition, the San Diego Regional Water Quality Control Board acts with
regulatory authority over wetlands through Waste Discharge Requirements and Clean Water Act Section
401 certificates of state water quality standards compliance for fill projects in wetlands and other State
waters.vi
Timber harvests on private and state-owned forest lands are regulated by the Z’berg-Nejedly Forest
Practice Act of 1973vii and CEQA.viii The Board of Forestry adopts regulations under this authority, and
CAL Fire administers the rules that address productivity of timberland and sustained production of
timber that considers sequestration of carbon dioxide,ix recreation, watershed, wildlife, range and
forage, fisheries, regional economic vitality, employment, and aesthetic enjoyment. Adopted rules must
protect the environment,x and more recently, legislation was adopted to address sequestration of
carbon dioxide in forests through the Forest Practice Act of 2010,xi the Working Forest Management
Plan,xii and Programmatic Timberland Environmental Impact Report for Carbon Sequestration and Fuel
i Public Resources Code § 6001 et seq.
ii See Public Resource Code §§ 6240–6245.
iii Fish & Game Code §§ 1600–1616.
iv Fish & Game § 1602.
v See January 25, 2001, Memorandum from SWRCB Chief Counsel to State Board Members and Regional Board
Executive Officers, Effect of SWANCC v. United States on the 401 Certification Program, available at
https://www.waterboards.ca.gov/rwqcb8/water_issues/programs/401_certification/docs/swancc.pdf.
vi See, e.g., Memo from SWRCB Executive Director to Regional Board Executive Officers, Guidance for Regulation of
Discharges to “Isolated” Waters (June 25, 2004), p. 15 of link, available at
https://www.waterboards.ca.gov/water_issues/programs/cwa401/docs/wrapp/comments/jennifer_west.pdf; see
33 U.S.C.A. § 1342; 33 C.F.R. § 325.2(b)(1); 40 C.F.R. § 230.10(b)(1).
vii Public Resources Code § 4511 et seq.
viii Public Resources Code § 21000 et seq.
ix See Public Resources Code §§ 4512.5(a) & (e).
x See Public Resources Code § 4551.
xi AB 1504 (Skinner, Chapter 534 , Statutes of 2010); See Public Resources Code § 4512(c); see also AB 1023
(Wagner, Chapter 296, Statutes of 2011); See Public Resources Code § 4512.5(a) & (d).
xii AB 904 (Chesbro, Chapter 648, Statutes of 2013); See Public Resources Code § 4597 et seq.
Oct. 11, 2022 Item #12 Page 554 of 560
516
Reduction Programi with action taken in tandem with CARB’s Scoping Plan. Executive Order B-52-18
ordered the creation of a California Forest Carbon Plan (2018), and the 2021 Wildfire and Forest
Resilience Action Plan is part of its implementation. To date, there has been limited regulatory activity
related to the statutory mandates at the Board of Forestry, but this will likely change with the adoption
of the 2022 Scoping Plan that will directly address forest management through regionally specific
management strategies to maintain healthy forest through treatment activity and preventing land
conversion.ii It is unclear how this will impact the San Diego region. Additionally, the Forest Practice Act
preempts counties from regulating the activity of timber operators.iii However, the County of San Diego
lacks zoned timber production zones and actively regulates land uses with timber and/or designated as
open space.
B.5.4 Local Authority Over Natural Climate Solutions and Other Land Use Considerations
Cities and counties often use planning and land use control authorities to protect or regulate natural and
working lands. In this regard, the full extent of this authority requires further research and development
to determine what is feasible at the local level to regulate, preserve, and augment natural and working
lands for GHG regulations and any removal or storage activities in the region. Additionally, local
jurisdictions act with authority to lobby Congress, the California Legislatures, and negotiate with federal,
tribal, and state agencies and lands managers to further these aims. Local jurisdictions may also act with
existing authority to create pilots or programs in this regard. Local jurisdiction act with existing authority
to fund local science to accurately identify and quantify local natural and working lands carbon stock
and sequestration potential to inform local decisions and investment. Further research is needed to
develop and vet these and other actions on natural and working lands.
Known local government tools that can be used to regulate and protect natural and working lands
include GPs, specific plans, CAPS, LCPs, zoning, special use permits, subdivision maps, and development
agreements. Policies that support easements (e.g., conservationiv — including California Forest Legacy
Program Act easementsv — and open-spacevi), as well as incentives largely based on easements to
preserve land, are additional tools available to local jurisdictions to preserve and manage natural and
working lands. This includes, but is not limited to:
• Purchase of Agricultural Conservation Easements;vii
• Transfer development credits/transfer of development rights;
• Lease or lease-purchase;
• Fee simple acquisitions;
• Mitigation banking;
• Project specific development agreements;
• City-county agreements and revenue sharing regarding urban growth;
• Greenbelt buffers, cluster development;
i SB 862 (Committee of Budget and Fiscal Review, Chapter 36, Statutes of 2014); See Public Resources Code § 4598
et seq.
ii CARB Draft 2022 Scoping Plan Update, May 10, 2022, p. 64: https://ww2.arb.ca.gov/sites/default/files/2022-
05/2022-draft-sp.pdf.
iii Public Resources Code § 4516.5(d).
iv Civil Code §§ 815.1, 815.3, 815.2(a)-(b).
v Public Resources Code § 12200 et seq.
vi Government Code § 51070 (The Open-Space Easement Act of 1974).
vii Civil Code § 815 et seq.; See County of San Diego PACE Program Guidelines (March 3, 2021).
Oct. 11, 2022 Item #12 Page 555 of 560
517
• Agricultural enterprise zones;
• Agricultural Protection Planning Grant Program;i and
• Development of an agricultural land component as part of an open-space element or agricultural
land element.ii
Finally, local jurisdictions can also apply for state programs like the Urban & Community Forestry
Program under the Urban Forestry Actiii to support local urban forestry efforts that are included in GPs
or CAPs. The Draft 2022 SB 32 Scoping Plan calls for 20% increase in urban tree investment above
historical levels to further support this effort.iv
B.5.4.1 Agriculture
Local jurisdiction’s authority over agricultural land stems from police power over land use and zoning.
Agriculture emissions or GHG mitigation actions also may be part of a local jurisdiction’s CAP. For
example, the Oceanside Carbon Farming Program is a CAP measure with a goal to establish up to 50
acres of demonstration carbon farms by 2025 utilizing alternative management practices that result in
increased carbon sequestration. Such practices include, but are not limited to, synthetic nitrogen
fertilization reductions, compost application, anaerobic digestion of waste, silvopasture, reduced tillage,
cover cropping, conservation crop rotation, range planting, and improved nutrient management.v It is
unclear how and to what extent a local jurisdiction may use its police power to regulate agriculture
activities that cause GHG emissions directly. Some potential opportunity are dependent on whether and
how CARB regulates certain activities.
Federal authority over agriculture land use and practices is limited with certain land use requirements
for leased federal land for farming or animal production but no specific regulation of GHG emissions.
In California, SB 1386 (Wolk, Chapter 545, Statutes of 2016) established protecting and managing
natural and working lands as state policy to be considered by all parts of the state government, that this
policy is important to achieving California’s GHG reduction goals, and that state policy includes the
intent to promote cooperation of owners of natural and working lands. SB 1386 (2016) also defined
farming land as working land under Public Resources Code § 9001.5(d)(1). SB 1383 (Lara, Chapter 395,
Statutes of 2016) mandated that CARB achieve a 40% reduction in methane emissions below 2014 levels
by 2030, including reducing emissions from livestock manure management operations and diary manure
management operations the creation and implementation of a Short-Lived Climate Pollutant Strategy.
SB 1383 (2016) sets the date of on or after January 1, 2024, as the effective date to implement
regulation of these emissions with ongoing investments and incentives to achieve the reductions. SB
1383 (2016) also limits regulation of enteric fermentation to incentive-based mechanisms until CARB
and the Department of Food and Agriculture determine that a cost-effective and scientifically proven
method of reducing enteric emissions is available adoption of which would not damage animal health,
public health, or consumer acceptance. A June 2021 Draft Analysis on the Progress Toward Achieving
i Public Resources Code § 10280 et seq.
ii See Government Code §§ 65565, 65570, 66565, 66565.1; see also Public Resources Code § 10281.5.
iii Public Utilities Code § 4799.06–4799.12.
iv CARB Draft 2022 Scoping Plan Update, May 10, 2022, p. 201: https://ww2.arb.ca.gov/sites/default/files/2022-
05/2022-draft-sp.pdf.
v City of Oceanside, Oceanside Climate Action Plan, 2019, p. 3-41:
https://www.ci.oceanside.ca.us/civicax/filebank/blobdload.aspx?blobid=48919.
Oct. 11, 2022 Item #12 Page 556 of 560
518
the 2030 Dairy and Livestock Sector Methane Emissions Target projected that current activities will
achieve slightly over half of the annual methane emission reductions required by SB 1383 (2016) due to
market, technical, and other barriers signifying the need for significant investment to almost double
emission reduction projects by 2030.i It remains unclear whether CARB will enact regulations in 2024 to
achieve these reductions. CARB regulation will likely preempt local authority action but the current state
offers an opportunity for local regulation unless, and until, CARB acts.
AB 32 (2006) and SB 32 (2016) authorized programs do not directly regulate agricultural land use, onsite
agriculture GHG emission (excluding off-road emissionsii), require carbon sequestration, or require
carbon removal on working agricultural lands. However, Executive Order B-55-18’s incorporates
agricultural working lands in the draft 2022 AB 32 Scoping Plan update to address the carbon neutrality
by 2045 target. Executive Order N-82-20’s language regarding biodiversity, 30% land and coastal water
conservation, acceleration of natural carbon sequestration and climate resiliency on natural and working
lands, and creation of the Natural and Working Lands Climate Smart Strategy — including setting a
statewide target to meet the 2045 carbon neutrality goal — will further focus efforts on agricultural
land. SB 27 (2021), where the legislature codified part of Executive Order N-82-20, mandates a Natural
and Working Land Climate Smart Strategy to achieve California’s climate goals. It also requires CARB to
set CO2 removal targets for 2030 and beyond under its Scoping Plan for all emission sectors, including
agriculture. Finally, SB 27 (2021) mandates will drive climate action on agriculture land through the
creation of a carbon removal and sequestration registry to identify, list, fund projects by state agencies
and private entities, and retire projects.
These efforts will further support existing agriculture preservation statutes in the coastal zone,iii the
long-term productivity of soil,iv and under the Williamson Act (California’s primary agricultural
preservation statute that grants property tax reductions for preserving agricultural and open-space uses
for farming and ranching).v It will also likely affect CEQA analysis on land conversion and agricultural
land preservation mitigation.
Previously, the 2017 AB 32 Scoping Plan sought to address GHG emissions from agriculture from energy
use, methane, and N2Ovi with the objective of maintaining agriculture “land as carbon sinks (i.e., net
zero or negative GHG emissions) and, where appropriate, minimize the net GHG and black carbon
associated with management, biomass utilization, and wildfire events”vii out to 2030 as it predated the
2018 executive order for carbon neutrality. The 2022 AB 32 Draft Scoping Plan seeks to support climate
i CARB, Draft Analysis on the Progress Toward achieving the 2030 Dairy and Livestock Sector Methane Emissions
Target (June 2021), p. ES-2 & 8: https://ww2.arb.ca.gov/sites/default/files/2021-06/draft-2030-dairy-livestock-ch4-
analysis.pdf.
ii See CARB Funding Agricultural Replacement Measures for Emission Reductions: https://ww2.arb.ca.gov/our-
work/programs/farmer-program.
iii See Public Resources Code § 30000 et seq. (Coastal Act) & § 31000 et seq. (State Coastal Conservancy); Public
Resources Code §§ 31050, 31051, 30241, 30114, 30243, 30108.6, 30500(c), 30200(a), 30514, 30241.5, 30241,
30250, 30610.1, 30242, 31054, 31104.1, 31150, 31151, 31152, 31156.
iv Public Resources Code § 30243.
v Government Code § 51201(c); see Government Code § 51200 et seq.
vi Note: the Irrigated Land Regulatory Program requires nitrogen fertilizer management to protect water quality
through nitrogen management plans, which decrease N2O use on farmland and may be used to coordinate further
reductions. Additional water management and water irrigation efficiency are also contributing to N2O reductions.
vii CARB California’s 2017 Climate Change Scoping Plan (November 2017), p. 81:
https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/scoping_plan_2017.pdf.
Oct. 11, 2022 Item #12 Page 557 of 560
519
smart actions around food security, reduce GHGs, increase carbon storage in soil, and reduce public
health impacts by reducing synthetic fertilizer and pesticide use. Strategies from the 2022 Draft AB 32
Scoping Plan specific to agriculture included:
• Accelerate the pace and scale of healthy soils practices to 50,000 acres annually by 2025,
annually conserve at least 6,000 acres of annual crops, and increase organic agriculture to 20
percent of all cultivated acres by 2045;
• Deploy additional climate smart agricultural strategies for croplands identified in the Climate
Smart Strategy (e.g., improved nitrogen use efficiency, whole-orchard recycling, riparian
restoration, on-farm energy generation, and others) and utilize the recommendations included in
CDFA’s Farmer and Rancher-Led Climate Change Solutions report to accelerate deployment of
healthy soils practices, organic farming, and other climate smart agriculture practices;
• Establish or expand financial mechanisms that support ongoing deployment of healthy soils
practices and organic agriculture;
• Implement California Department of Pesticide Regulation’s (DPR) Sustainable Pest Management
Work Group recommendations to accelerate a systemwide transition to safer, more sustainable
pest management;
• Support strategies that achieve co-benefits of safer, more sustainable pest management
practices and the health and preservation of ecosystems;
• Conduct research on the intersection of pesticides, soil health, GHGs, and pest resiliency via a
multiagency effort with DPR, California Department of Food and Agriculture (CDFA, and CARB;
• Conduct outreach and education to develop and facilitate the increased adoption of safer, more
sustainable pest management practices and tools, reduce the use of harmful pesticides, promote
healthy soils, improve water and air quality, and reduce public health impacts;
• In collaboration with state and local agencies, accelerate the deployment of alternatives to
agricultural burning that increase long-term carbon storage from waste agricultural biomass,
including storage in durable wood products, underground reservoirs, soil amendments, and other
mediums;
• Work across state agencies to reduce regulatory and permitting barriers around some healthy
soils practices (e.g., composting), where appropriate; and
• Utilize innovative agriculture energy use and carbon monitoring and planning tools to reduce on-
farm GHG emissions from energy and fertilizer application or increase carbon storage, as well as
to promote on-farm energy production opportunities. i
The April 2019 CARB NWL Implementation Plan, informed by SB 859’s (2016) Natural and Working Land
Inventory’s quantitative estimate of the existing state of ecosystem carbon stored in the State's land
base (excluding GHG emissions associated from direct human activity quantified in CARB’s annual
statewide GHG inventory),ii sets targets out to 2030 and pathways to scale needed implementation.
Specific to agriculture, these include increasing the acreage in soil conservation practices for cultivated
land and rangelands by five times to change agricultural land from a net emitter to a sink by 2030.iii The
NWL Implementation Plan also calls for increases in compost application, agroforestry, grazing land and
grassland management, and cropland management to decrease emissions and increase carbon
i CARB Draft 2022 Scoping Plan Update, May 10, 2022, p. 208: https://ww2.arb.ca.gov/sites/default/files/2022-
05/2022-draft-sp.pdf.
ii See CARB California Natural and Working Land Inventory (2018), p. 7 & 15: https://ww2.arb.ca.gov/nwl-
inventory.
iii See January 2019 Draft California 2030 Natural and Working Lands Climate Change Implementation Plan
(Updated January 2019), p. 13: https://ww2.arb.ca.gov/sites/default/files/2020-10/draft-nwl-ip-040419.pdf.
Oct. 11, 2022 Item #12 Page 558 of 560
520
sequestration.i
SB 859 (2016) established the Department of Food and Agriculture Healthy Soil Program (HSP) to
provide incentives (including loans, grants, and research), technical assistance, and education research
to farmers whose practices contribute to healthy soils, as defined, and result in net long-term on-farm
GHG benefits with GHG reductions quantified using CARB methodologies. The HSP is also authorized to
pilot demonstration projects to further its goals. To date, the Program received $40.1 million in
California Climate Investment (CCI) (e.g., cap-and-trade proceeds) from 2016–2019, $10 million from SB
5 (de León, Chapter 852, Statutes of 2017) California Drought, Water, Parks, Climate, Coastal Protection,
and Outdoor Access For All Act of 2018, and was accepting applications for 2021 with $50 million from
the State General Fund and $25 million from the California Climate Investments for the Healthy Soils
Program per SB 170 (Skinner, Chapter 240, Statutes of 2021) authorized by the Budget Act of 2021.ii
Additional funding with impacts on GHG emissions include:
• $100 million through Fiscal Year 2022–2023 for the State Water Efficiency Enhancement Program
(SWEEP);
• $160 million through Fiscal Year 2022–2023 for the Healthy Soil Program (HSP);
• $80 million through Fiscal Year 2022–2023 for the Dairy Digestor Research & Development
Program (DDRDP) & Alternative Manure Management Program (AMMP);
• $39 million through Fiscal Year 2022–2023 for the Conservation Agriculture Planning Grant
Program; and
• $5 million through Fiscal Year 2021–2022 for the Water Efficiency Technical Assistance Grant.iii
Two other CEC operate programs fund GHG reduction activities on agricultural land. The Food
Production Investment Program provides grants through the CCI to help food processors save energy
and money while reducing GHG emissions through energy efficiency and renewable energy technology.iv
The Renewable Energy for Agriculture Program (REAP)v offers grants that encourage the installation of
renewable energy technology to reduce GHG emissions from agriculture operations, including solar PV
systems, wind turbines, biomass-to-energy generation, or other commercially viable renewable energy
technology.vi It is unclear whether there is additional funding for these programs.
i See January 2019 Draft California 2030 Natural and Working Lands Climate Change Implementation Plan (Updated
January 2019), p. 17: https://ww2.arb.ca.gov/sites/default/files/2020-10/draft-nwl-ip-040419.pdf.
ii See Department of Food and Agriculture, The Office of Environmental Farming and Innovation, Healthy Soil
Program (last visited November 30, 2021): https://www.cdfa.ca.gov/oefi/healthysoils/.
iii See California Department of Food and Agriculture, The Office of Environmental Farming and Innovation (last
visiting on November 30, 2021): https://www.cdfa.ca.gov/oefi/.
iv See CEC Food Production Investment Program (last visited November 30, 2021):
https://www.energy.ca.gov/programs-and-topics/programs/food-production-program.
v See CEC Renewable Energy For Agriculture Program (last visited on November 30, 2021):
https://www.energy.ca.gov/programs-and-topics/programs/renewable-energy-agriculture-program.
vi The program was authorized with the passage of AB 109 (Ting, Budget Act of 2017, Chapter 249, Statutes of
2017) and SB 856 (Budget and Fiscal Review Committee, Chapter 30, Statutes of 2018). The program is receiving
$10 million from the Greenhouse Gas Reduction Fund.
Oct. 11, 2022 Item #12 Page 559 of 560
521
Appendix C. Regional Decarbonization Framework –
Technical Working Group
Name Organization Recommended by
David Flores San Diego County Office of Supervisor San Diego County Supervisor District 1
James Whalen J. Whalen Associates San Diego County Supervisor District 2
Cody Petterson San Diego County Office of Supervisor San Diego County Supervisor District 3
Shalini Vajjhala San Diego Regional Policy and
Innovation Center (SDRPIC)
San Diego County Supervisor District 4
Matthew Adams Building Industry Association (BIA) San Diego County Supervisor District 5
Allison Wood San Diego Association of Governments
(SANDAG)
San Diego Association of Governments
Kathleen Keehan San Diego County Air Pollution Control
District (APCD)
San Diego County Air Pollution Control
District
Philip Gibbons Port of San Diego Port of San Diego
Chad Reese San Diego International Airport San Diego Regional Airport Authority
Annalisa Schilla California Air Resources Board (CARB) California Environmental Protection
Agency & California Air Resources
Board
Dallin Young San Diego Gas & Electricity (SDG&E) San Diego County Land Use &
Environment Group
Matthew
Vasilakis
Climate Action Campaign San Diego County Land Use &
Environment Group
Satomi Zeigler San Diego & Imperial Counties Labor
Council
San Diego County Land Use &
Environment Group
Oct. 11, 2022 Item #12 Page 560 of 560
County of San DiegoCounty of San Diego
A Collaborative Effort to Lower the Region's Carbon Footprint
City of Carlsbad, City Council Item #12
Murtaza H. Baxamusa, PhD, AICP
October 11, 2022
2
Technical Report
3
Workforce Development
Study by Inclusive
Economics
Integrated Regional Decarbonization Framework
4
Technical Report led by
UC San Diego and USD
Implementation
Playbook
Completed
August 2022
Completed
August 2022 1st Draft December 2022
2nd Draft February 2023
Final by Spring 2023
Draft Implementation Playbook & Policy
Development
December 2022
Regional Convenings & Public Review
January 2023
Board Adoption
Spring 2023August2022
Board
Update
Brief Timeline
Public
Workshop
Completion of
Technical Report
& Workforce
Development
Reports
Special
Topic
Working
Groups
Implementation
Playbook 1st
Draft Released
Draft Sustainable
Agriculture &
Food Systems
Policy Report
Implementation
Playbook 2nd
Draft Released
PROGRAM DETAILSImplementation
Playbook &
Framework
Adoption
5
Implementation Playbook
6
All measures in Climate Action Plans
Best in class for
each topic
Voluntary
Menu of options Accessible
Public or private
organizations
Implementation Playbook: Level of Approach
7
Business Operations Communities Region
Implementation Playbook: Sample Topics
8
Buildings
•Better use of energy in existing buildings
Electricity
•Educate residents & businesses about 100% renewable energy
options
Food Systems & Circular Economy
•Bulk purchase of food
•Waste
diversion from landfills
Land Use &
Natural Climate Solutions
•Green streets
Transportation
•Retire polluting
vehicles
9
Workforce
Development
Study
Analysis of all
local Climate
Action Plans
Technical
Report
Implementation
Playbook
Regional
Actions
Regional
GHG
Analysis
Regional
Climate
Action Plan
Next Steps
Possible
Board
Direction in
Spring 2023
Regional Actions: Examples
10
Regional program for
suitable tree planting
locations
Model building code
for electrification
Solar electricity for
low-income renters
County of San DiegoCounty of San Diego
Office of Sustainability and Environmental Justice: https://www.sandiegocounty.gov/osej
Regional Decarbonization Framework: https://www.sandiegocounty.gov/RDF
Email: Murtaza.Baxamusa@sdCounty.ca.gov