HomeMy WebLinkAbout2023-05-09; City Council; ; Electrification of New Buildings in CarlsbadCA Review GH
Meeting Date: May 9, 2023
To: Mayor and City Council
From: Scott Chadwick, City Manager
Staff Contact: Katie Hentrich, Senior Program Manager
katie.hentrich@carlsbadca.gov, 442-339-2623
Subject: Electrification of New Buildings in Carlsbad
Districts: All
Recommended Action
Receive an update, review options and provide direction to staff on how to proceed related to
electrification in new buildings in the next Climate Action Plan draft in 2023.
Executive Summary
Staff presented the fifth Climate Action Plan Annual Report to the City Council on April 19,
2022, followed by an informational item on electrification of new buildings. In response, the
City Council directed staff to “research options to add an ordinance addressing electrification in
new buildings in the City of Carlsbad to the next Climate Action Plan draft in 2023.”
During the City Council discussion on the item, the City Council provided direction that the
research should include, but not be limited to:
•Options related to new building ordinances requiring all-electric power
•What other jurisdictions are doing related to new building electrification
•Issues related to workers, just transition and equity
•Possible costs to customers
•Grid infrastructure and reliability
•Cost-effectiveness studies
•Estimate of number of units impacted
•Estimate of greenhouse gas emissions reduced
This staff report contains the information requested during public comment and by the City
Council. The direction from City Council predates last month’s decision by the U.S. Ninth Circuit
Court of Appeals in California Restaurant Association v. City of Berkeley. The court ruled that
the federal Energy Policy and Conservation Act preempts a City of Berkeley ordinance
prohibiting the installation of natural gas piping within newly constructed buildings, a ruling
that applies to other cities in California.
May 9, 2023 Item #10 Page 1 of 27
Explanation & Analysis
In 2022, staff directed the Energy Policy Initiatives Center, or EPIC, to prepare this research,
attached as Exhibit 1, under an existing professional services agreement.
The key findings from EPIC’s analysis focus on three options for electrifying new buildings:
• Electric only – natural gas moratorium, or building no new gas infrastructure
• Electric only to building code, or requiring that all new construction is electric only
• Electric only plus energy efficiency or photovoltaics, or requiring that all new
construction is electric only and exceeds energy-efficiency standards
The options presented in EPIC’s report are discussed in greater detail in Exhibit 1. The report
was prepared before the California Restaurant Association v. City of Berkeley decision was
issued on April 17, 2023.
Fiscal Analysis
There is no fiscal impact to this item and no city funding is being requested.
Options
Given the Ninth Circuit Court’s ruling, staff are requesting the City Council’s direction on how to
proceed. Staff have identified the following options:
1. Continue implementing the City Council’s April 19, 2022, motion
2. Take no further action
3. Wait for updates to the California Restaurant Association v. City of Berkeley case
4. Proceed with other direction provided by the City Council
Next Steps
In late summer 2023, staff plan to present a Climate Action Plan Update to the City Council and
review the findings collected through public outreach, hear public comment, provide input on
candidate measures, and ultimately confirm next steps for the overall work program.
Environmental Evaluation
The action before the City Council is statutorily exempt from the California Environmental
Quality Act, or CEQA, in accordance with CEQA Guidelines Section 15262 - Feasibility and
Planning Studies. The direction provided by the City Council on this item is for planning
purposes only, and any possible future actions, if any, would be subject to City Council
approval.
Exhibit
1. Energy Policy Initiatives Center Report – Options for an All-Electric New Construction
Requirement
May 9, 2023 Item #10 Page 2 of 27
City of San Diego CAP Implementation Cost Analysis 2-27-22
Energy Policy Initiatives Center
Options for an All-Electric New Construction
Requirement
March 2023
Prepared for the City of Carlsbad
Prepared by the Energy Policy Initiatives Center
University, 5998 Alcalá Park, San Diego, CA 92110 ◆ www.sandiego.edu/epic
Exhibit 1
May 9, 2023 Item #10 Page 3 of 27
{city of
Carlsbad
~EPIC
ENERGY POLICY INITIATIVES CENTER
UNIVERSITY OF SAN DIEGO SCHOOL OF LAW
Options for an All-Electric New Construction Requirement
Energy Policy Initiatives Center
Disclaimer
The Energy Policy Initiatives Center (EPIC) prepared this report for the City of Carlsbad. This report represents
EPIC’s professional judgment based on the data and information available at the time EPIC prepared this
report. EPIC relies on data and information from third parties who provide it with no guarantees such as of
completeness, accuracy or timeliness. EPIC makes no representations or warranties, whether expressed or
implied, and assumes no legal liability for the use of the information in this report; nor does any party
represent that the uses of this information will not infringe upon privately owned rights. Readers of the
report are advised that EPIC may periodically update this report or data, information, findings, and opinions
and that they assume all liabilities incurred by them, or third parties, as a result of their reliance on the
report, data, information, findings and opinions contained in the report.
About EPIC
The Energy Policy Initiatives Center is a research center of the USD School of Law that studies energy policy
issues affecting California and the San Diego region. Energy Policy Initiatives Center’s mission is to increase
awareness and understanding of energy- and climate-related policy issues by conducting research and
analysis to inform decision makers and educating law students.
For more information, please visit the Energy Policy Initiatives Center website at www.sandiego.edu/epic
May 9, 2023 Item #10 Page 4 of 27
Options for an All-Electric New Construction Requirement
Energy Policy Initiatives Center
Table of Contents
1 INTRODUCTION 1
1.1 KEY FINDINGS 1
1.2 STRUCTURE OF THE DOCUMENT 2
2 ALL-ELECTRIC NEW BUILDING REQUIREMENT PATHWAYS 2
2.1 PATHWAY 1: NATURAL GAS MORATORIUM 2
2.2 PATHWAY 2: ELECTRIC-ONLY TO CODE MINIMUM 2
2.3 PATHWAY 3: ELECTRIC-ONLY WITH ADDED EFFICIENCY PLUS PV, AND/OR BATTERY REACH CODE 3
3 ESTIMATED GHG EMISSION AND COST IMPACTS 4
3.1 PATHWAY 1: NATURAL GAS MORATORIUM 5
3.2 PATHWAY 2: ELECTRIC-ONLY TO MINIMUM CODE 5
3.2.1 Single-Family Buildings 5
3.2.2 Multi-Family Buildings 5
3.2.3 Nonresidential Buildings 5
3.3 PATHWAY 3: ELECTRIC-ONLY WITH ADDED EFFICIENCY, PV, AND/OR BATTERY REACH CODE 6 3.3.1 Single-Family Buildings 6
3.3.2 Multi-Family Buildings 6
3.3.3 Nonresidential Buildings 6
4 VIABILITY OF PATHWAYS BY BUILDING TYPE 7
5 OTHER CONSIDERATIONS 8
5.1 GRID RELIABILITY 8
5.2 WORKFORCE CONSIDERATIONS 8
5.3 EQUITY CONSIDERATIONS 8
6 APPENDIX A: SUPPORTING INFORMATION FOR THE POTENTIAL IMPACTS OF AN ALL-ELECTRIC
REQUIREMENT 10
6.1 ESTIMATED NUMBER OF BUILDINGS AFFECTED (2023-2025 CODE CYCLE) 10
6.2 GHG IMPACTS AND COST CONSIDERATIONS FOR ALL-ELECTRIC PATHWAYS 10
6.3 RESIDENTIAL BUILDINGS 11
6.3.1 Residential Single-Family Buildings 11
6.3.2 Multi-Family Buildings 13
6.4 NONRESIDENTIAL BUILDINGS 16
6.4.1 Pathway 3 Reach Code for Medium Retail 16
6.4.2 Pathway 3 Reach Code for Quick-Service Restaurants 17
6.4.3 Pathway 3 Reach Code for Medium Office and Small Hotel 18
6.4.4 Pathway 3 Reach Codes: Cost-effectiveness and Code Compliance for New Nonresidential
Construction 20
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1 INTRODUCTION
Local jurisdictions have authority to adopt local energy codes that are stricter than state standards. While
energy efficiency is still a primary concern, there has been a shift toward building electrification to achieve net
zero emissions by 2045. This document summarizes options to electrify newly constructed buildings through three pathways: a natural gas moratorium, all-electric buildings that achieve the minimum energy code standards,
and all-electric reach codes that include additional measures for energy efficiency (EE), photovoltaics (PV),
and/or batteries. Where data is available from statewide cost effectiveness studies, we present information on
the impacts of all-electric requirements on GHG reductions, the upfront cost to build, energy utility bills, and, for
reach codes, cost-effectiveness and code compliance.
1.1 Key Findings
The following are key findings from this analysis:
• There are three potential pathways to electrify newly constructed buildings in the City of Carlsbad:
Natural Gas Moratorium (Pathway 1), All-Electric to Code Minimum (Pathway 2), and Electric-Only
with Added Efficiency, PV, and/or Battery Reach Code (Pathway 3).
• Pathway 1 (Natural Gas Moratorium) and Pathway 2 (All-Electric to Code Minimum) can be adopted
as local energy codes without state review/approval. These can rely on local jurisdiction authority or
CalGreen (Title 24, Part 11), and need to be submitted to the Buildings Standards Commission but do
not require a cost-effectiveness study (specified by the California Administrative Code, Title 24, Part
1, Chapter 10, Section 10-106).
• Pathway 3 (Electric Only with Added Efficiency, PV, and/or Battery) is considered a reach code and must demonstrate that it reduces energy use and is cost-effective. Reach codes must be reviewed and
approved by the California Energy Commission (CEC) in addition to being submitted to the Building
Standards Commission.
• Single-Family and Multi-Family Buildings: Pathway 1 (Natural Gas Moratorium) and Pathway 2 (All-
Electric to Code Minimum), which do not require cost-effectiveness studies to be reviewed and
approved by the CEC, are viable. Pathway 3 Reach codes for All-Electric + Basic EE and All-Electric +
PV, which were found cost-effective and code compliant, are viable. o In general, all-electric residential buildings reduce more GHGs than the baseline buildings, which use both electricity and natural gas (mixed fuel). All-electric buildings with solar PV
systems had the highest GHG reductions. o Single-Family Cost Impacts: Except for the package with battery storage, all packages result
in lower upfront cost to build a unit compared to the mixed fuel buildings. Only the packages
with solar PV result in annual energy utility bill reductions. The mixed fuel package has
significantly higher build costs per unit but results in lower annual energy utility bills. o Multi-Family Costs Impacts: Electrifying end-uses in Multi-Family buildings generally increases the cost to build a dwelling unit.
• Nonresidential Buildings: Pathway 1 (Natural Gas Moratorium) and Pathway 2 (All-Electric to Code
Minimum), which do not require cost-effectiveness, are viable. However, there is a lack of available GHG and cost data to evaluate these pathways fully. Feasibility should be further considered given
the unknowns about the impacts to the cost to build and energy utility bills, particularly for restaurants.
Nonresidential Pathway 3 Reach Code options are viable for Medium Retail. There are no viable
reach code options for Quick-Service Restaurants, even if kitchen appliances are not electrified and
higher energy efficiency and PV are required. Medium Office and Small Hotels may be found cost-
effective and compliant under future planned updates to the cost-effectiveness study but are currently
not viable as reach codes. o In general, all-electric nonresidential buildings reduce more GHGs than those with both
electricity and natural gas (mixed fuel). However, there is a lack of available data to
quantify GHG reductions from Pathways 1 and 2. o Nonresidential Costs Impacts: There is a lack of available data for Pathway 1 and 2 cost
impacts. Pathways 3 packages result in an increased cost to build, except for Medium Office,
but there are generally mixed results with regard to energy utility impact. Quick-Service
Restaurants see both significant increase in build and utility cost.
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o Pathway 3 Reach Codes: There are identified existing issues for Quick-Service Restaurants,
Medium Office, and Small Hotels in terms of cost-effectiveness and code compliance. Future
cost-effectiveness study updates may address some of these limitations. Reach codes for
Medium Retail are currently viable.
• Grid Reliability: It is not expected that electrification of new construction will pose a reliability issue to
the grid given the small number and incremental addition of these loads. All-electric buildings are
directly affected by load-curtailment events and outages. Further analysis should be undertaken to understand this risk in the City of Carlsbad.
• Workforce: Electrification will increase related workforce while also not displacing the current
workforce for fossil related workforce out to 2030. From 2030-2050, the City of Carlsbad should evaluate the need to transition this workforce as it is affected by electrification. There are several
ways to mitigate workforce impacts, including clean fuel pilots, pairing requirements with incentives,
and requiring qualified workers to be eligible for financial incentives.
• Equity: There are a wide range of positive and negative costs impacts for consideration under these
pathways. Further study may be needed to understand the specific cost and social equity implications
of building all-electric buildings in the City of Carlsbad, particularly where data is lacking.
1.2 Structure of the Document
Section 2 defines and presents summary information about the three all-electric pathways. A summary of the
GHG and cost impacts of each pathway is presented in Section 3. Section 4 summarizes which pathways are
viable and highlights problematic areas for further evaluation. Section 5 briefly identifies and summarizes
several key considerations like grid reliability, workforce development, and social equity. Section 6 is an
appendix containing more detailed back up information to support the findings of this report.
2 ALL-ELECTRIC NEW BUILDING REQUIREMENT PATHWAYS
There are three potential pathways under existing local jurisdiction authority to require newly constructed
buildings to be all-electric: (1) adopt a natural gas moratorium, (2) modify the 2022 Title 24 California Building
Code to require all-electric construction, or (3) require all-electric construction plus additional energy efficiency
measures, which can include solar PV and batteries. This section summarizes these potential pathways, including
information on the number of jurisdictions in California that have adopted these measures under the current 2022 Title 24 Building Code cycle, other jurisdictional approaches, and adopted exclusions.
2.1 Pathway 1: Natural Gas Moratorium
Generally, this approach applies to new construction only by prohibiting permits and installation of natural gas
plumbing. A moratorium may include detached Accessory Dwelling Units (ADUs) with applicability sometimes
limited by ADU size (e.g., applies if over 750 sq. ft.). Adopted exceptions include commercial kitchens, specific
types of buildings (e.g., hospitals, labs, industrial processes), hardship or public interest (e.g., health and safety), attached ADUs, physical infeasibility, or cases in which applicant can prove that there is no prescriptive
performance pathway to achieve all-electric.
This pathway requires City Council approval and adoption of an ordinance and would be effective once filed
with the Building Standards Commission (BSC). It does not require a cost-effectiveness study to be reviewed and
approved by the CEC, nor would the ordinance require state agency approval. It is anticipated that this
pathway would take about 6-12 months to develop and adopt. There are approximately five jurisdictions in
California that use this measure: the cities of Berkeley, Half Moon Bay (prohibits conversion to mixed-fuel and terminates natural gas service by 2045), Morgan Hill, San Jose, and Santa Cruz. The City of Berkeley’s
ordinance has been challenged and is currently on appeal in the 9th Circuit Court of Appeals at the time of
writing.
2.2 Pathway 2: Electric-Only to Code Minimum
Under this pathway, the jurisdiction would not issue a permit for newly constructed buildings that use both
electricity and natural gas (mixed-fuel). New buildings would have to be serviced by electricity only and meet existing minimum energy code efficiency standards. Requirements can be specific to appliances (e.g., space and
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water heating) or apply to the whole building. Examples of exceptions adopted by cities in California include
certain building types (e.g., only apply to new low-rise residential or excludes ADUs), public interest, and cases
in which the applicant can prove that there is no prescriptive or performance pathway to achieve all-electric.
Where an exception applies by building type (e.g., high-rise multi-family and nonresidential), there is generally
a requirement to make the building electric-ready, including pre-wiring to allow for future electrification of
natural gas end-uses (e.g., cooking, space/water heating, etc.).
This pathway requires City Council approval by ordinance adoption, takes about 6-12 months from
development to adoption, and is enforceable once filed with the BSC. It does not require a cost-effectiveness
study to be reviewed and approved by the CEC, nor would the ordinance require state agency approval.
Generally, the jurisdiction defines “all-electric” in its municipal code, amending the California Energy Code (Title
24, Part 6), or by amending CALGreen (Title 24, Part 11). There are currently fifty-eight jurisdictions with
adopted 2022 Building Code electric-only requirements using Pathway 2 for new construction.1 The City of
Encinitas is the first local example of adopting this pathway under the 2022 code cycle. The City of Solana Beach recently adopted all-electric requirements under the 2022 code cycle on March 8, 2023 becoming the
second local example.2.3
2.3 Pathway 3: Electric-Only with Added Efficiency Plus PV, and/or Battery Reach Code
Generally, a jurisdiction would define “all-electric” and require higher energy efficiency standards (e.g.,
prescriptive requirements above minimum energy code standards), additional photovoltaic (PV), and/or a
battery, if cost-effective. There are only two examples of these types of ordinances for new construction in California and it is possible that adoption will accelerate now that cost-effectiveness studies exist for the 2022
building code. It is also possible that these types of codes can be used to regulate mixed-fuel buildings that are exceptions to all-electric definitions, exemptions, or exclusions for more stringent standards. Additionally, it is
unlikely that a jurisdiction would require an increase in PV size beyond expected electrical usage and 2022
code mandates considering net-energy metering (NEM) changes4 that are effective for all interconnection
applications submitted to SDG&E after April 15, 2023. These changes encourage sizing PV to match electrical
usage and combining PV with energy storage. The changes are not accounted for in the current State Reach
Code Cost-effectiveness results presented in this document.
This pathway requires City Council approval by ordinance adoption, takes about 6-12 months from development to adoption, requires a cost-effectiveness study that must be reviewed and approved by the CEC,
and is effective once filed with the BSC and approved by the CEC (about 2-6 additional months). There are
currently no examples of jurisdictions with all-electric requirements with additional reach code requirements for
new construction using Pathway 3. This may change with the recent publications of statewide reach code cost-
effectiveness studies.
Table 1 presents a summary of key considerations for each all-electric requirement pathway.
1 See California Energy Codes & Standards: 2022 Code Cycle Locally Adopted Energy Ordinances (last updated 2/23/23): https://localenergycodes.com/content/adopted-ordinances
2 See City of Solana Beach City Council Meeting and Agenda, adopted March 8, 2023, Item No. C.2. Re-adopt (2nd Reading)
Ordinance 529- Building Standards Code Amendments. (File 0600-05):
https://www.cityofsolanabeach.org/sites/default/files/Solana%20Beach/Meetings/City%20Council/2023/03-08-23/03-08-
23%20Reg/03-08-23%20Agenda%20PACKET%20-%20O.pdf.
3 See Planning Application Processing Fees, City of Encinitas Development Services Department (Updated 7/11/22), Planning Application Fee # 9:
https://encinitasca.gov/Portals/0/City%20Documents/Documents/Development%20Services/Planning/Land%20Development/Pl
anning%20Application%20Processing%20Fees.pdf .
4 See CPUC NEM Revisit Proceeding (R.) 20-08-020: https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/demand-side-management/net-energy-metering/nem-revisit; See CPUC D.22-12-056 (12/19/22): https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M500/K043/500043682.PDF.
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Table 1 Summary of New Construction Building Electrification Pathways5
3 ESTIMATED GHG EMISSION AND COST IMPACTS
The following sections summarize the potential GHG and cost impacts of all-electric requirements. This information is based on published results from statewide cost effectiveness studies and the Local Codes Explorer
website.6 For a more detailed discussion of these results, see Section 6 Appendix A.
5 Based on information presented at a Webinar on 2022 Single-Family New Construction Cost Effectiveness Study Preliminary Results (May 2022). California Energy Codes and Standards Program.
6 https://explorer.localenergycodes.com/.
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Pathway 3: Reach Code Via
Pathway 1: Electric Only Pathway 2: Electric Only Electric Only Plus Added
Consideration Via Natural Gas Moratorium To Minimum Code Efficiency+ PV /Battery**
No new gas nfrastructure Al new construction Al new construction is electric only
Requirements (Hookups or Pipng) is electric only AND meets AND exceeds mnimum Tille 24
mnimum Tille 24 standards efficiency standards
Local Jurisdictional Authority Local Jurisdictional Authority Local Jurisdictional Authority
Authority (e.g., Health and Safety) or CALGreen Title 24, Part 11 or CALGreen, plus Energy Code
Title 24, Part 6
Mechanism Local Energy Code Reach Code
Building Standards
Relevant State Buildings Standards Commission (BSC)
Agency Not Applicable Commission (BSC) and California Energy
Commission (CEC)
State Agency Action None Receive (BSC) Receive (BSC)
Approve (CEC)
Cost-Effectiveness No Study Required? Yes
Relative GHG Low-Medium Reduction Potential* High
6-12 months
Time Required 6-12 months Additional 2-6 months
for CEC approval
Update Frequency No need to update every 3 years Must be updated every 3 years
with Tille 24 Energy Code Cycle with Tille 24 Energy Code Cycle
Cities with Berkeley, Half Moon Bay, Over 50 statewide
Morgan Hill, San Jose, Local examples including None for New Construction Adopted Policy and Santa Cruz Encinitas and Solana Beach
Legal Federal preemption issue may exist depending on Berkeley Case outcome Considerations
•Estimated relative greenhouse gas (GHG) reduction potential of approaches listed here. In general, GHG reduction from new construction policies are
small relative to other types of measures (e.g., increasing renewable electricity supply to all customers) .
.. PV is solar photovoltaics.
Options for an All-Electric New Construction Requirement
Energy Policy Initiatives Center 5
3.1 Pathway 1: Natural Gas Moratorium
Costs and GHG emissions impacts associated with Pathway 1 are not available or included in the statewide
cost-effectiveness studies. For our purposes here, we assume that the results would be similar to Pathway 2. One
potential difference between Pathway 1 and Pathway 2 is that under a Natural Gas Moratorium, there would
be no option for natural gas appliances, so no equipment-based exceptions could be granted. This could affect eventual cost and GHG results.
3.2 Pathway 2: Electric-Only to Minimum Code
3.2.1 Single-Family Buildings
All-electric single-family buildings that meet minimum efficiency standards under Pathways 2 result in larger
GHG reductions than the mixed fuel reach code option evaluated in the statewide cost-effectiveness study.
There is an expected annual energy utility bill increase from Pathway 2. Pathway 2 also shows the largest
decrease in the cost to build a dwelling unit, primarily from eliminating natural gas plumbing and
interconnections. This pathway does not require a cost-effectiveness study as it is identified by the California
Administrative Code, Title 24, Part 1, Chapter 10, Section 10-106. However, the city may choose to perform a
separate benefit-cost analysis to understand the measure and who is experiencing costs and benefits (to those who participate in Climate Action Plan measure activities and the costs to non-participants to subsidize rebates
and incentives).
3.2.2 Multi-Family Buildings
Throughout this document, multi-family includes both low-rise 3-story and mid-rise 5-story buildings. Both 3-story and 5-story multi-family buildings using Pathway 2 show significant GHG reductions compared to both Mixed
Fuel Efficiency and Mixed Fuel Efficiency + PV + Battery reach codes, which show minimal GHG reductions in
the case of 5-story buildings. Data was not available to compare Pathway 2 impacts to energy utility bills and
the cost to build a unit. However, it can be assumed that there will be increased energy utility bills from
electrification from end-uses and increased costs to build a dwelling unit from central heat pump water heating,
similar to Pathway 3. A cost-effectiveness study is not required for this pathway as it is identified by the
California Administrative Code, Title 24, Part 1, Chapter 10, Section 10-106. However, the city may choose to perform a separate benefit-cost analysis to understand the measure and who is experiencing costs and benefits
(to those who participate in Climate Action Plan measure activities and the costs to non-participants to subsidize
rebates and incentives).
3.2.3 Nonresidential Buildings
Based on review of available data and the Pathway 3 cost-effectiveness study that evaluated four building
prototypes that serve as proxies for other nonresidential buildings (Medium Retail, Medium Office, Quick-
service Restaurant, and Small Hotel), several considerations came to light. First, there is a lack of available data
on Pathway 2 GHG impacts. However, it is assumed that Pathway 2 would result in GHG reductions, but it is
unclear how these compare to those from the mixed fuel options. For example, all prototypes show GHG
reductions using the reach code cost-effectiveness analysis for All-Electric to Code Minimum, which is a
prescriptive reach code requirement, except for Medium Office. This may serve as a basis to provide the high range of GHG reductions estimates for Pathway 2, but should not be considered an average. Second, there is a
lack of data on the cost impact for Pathway 2 and further analysis should be undertaken to understand the
implications in this regard.
In addition to these issues, particular care should be taken with regard to electrifying restaurants based on the
Pathway 3 analysis for quick-service restaurants that show the difficulty in electrifying kitchen appliances (e.g.,
process load). Small Hotels and Medium Office buildings also may have similar constraints in terms of cost and
feasibility of process load that should be further evaluated. While code compliance and cost-effectiveness are not required for Pathway 2, further analysis may be needed to determine cost impacts, GHG reductions, and
feasibility of all-electric requirements for new nonresidential buildings. Given the uncertainty described here,
exemptions should be evaluated for end-uses like commercial kitchen appliances with electrification
requirements focusing on space heating/cooling, water heating, and other building end-uses.
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3.3 Pathway 3: Electric-Only with Added Efficiency, PV, and/or Battery Reach Code
Unlike Pathways 1 and 2, which can be adopted using local jurisdiction authority, requirements under Pathway
3 are considered reach codes and must be cost effective, demonstrate energy reductions and compliance with
statewide building energy code standards, and be approved by the CEC and submitted to the BSC.
3.3.1 Single-Family Buildings
All evaluated Pathway 3 packages were cost-effective and code compliant making each evaluated package a
viable reach codes in this pathway. All Pathway 3 reach code evaluated result in GHG reductions with greatest
reductions from the Electrification + EE + PV reach code package. Generally, the results from comparing all-
electric options indicate that adding energy efficiency and PV to all-electric single-family units increases the amount of GHG emissions reduced under Pathway 3. Packages with PV had significantly higher GHG
reductions under Pathway 3. Except for the package with battery storage, all packages result in a lower cost to
build a unit compared to the Mixed Fuel EE + PV + Battery reach code package.
Only the packages with PV result in lower annual energy utility bills. There is an expected annual utility bill
increase from Pathway 3 packages without PV that should be evaluated considering the coming change to net
energy metering.7 It is possible to address utility bill increases by evaluating additional efficiency and PV
requirements that improve on-bill cost-effectiveness. However, there is a decrease in the cost to build a unit due to the lack of natural gas related costs for all packages except where the Electrification + EE + PV + Battery
shows an increased costs because of the battery cost. Comparatively, the mixed fuel package has significantly
higher build costs per unit but resulted in lower annual energy utility bills. Finally, all evaluated reach code
packages were found cost-effective and code compliant.
3.3.2 Multi-Family Buildings
All evaluated Pathway 3 packages were found cost-effective and code compliant making each evaluated
package a viable reach codes in this pathway. Pathway 3 All-Electric + PV shows the greatest GHG reduction
for both 3-story and 5-story buildings under the analysis. The cost-effectiveness study also included
Electrification + Basic EE (all prescriptive measures required) but there is no available data on the GHG
reductions of this package. It is assumed that Electrification + Basic EE would result in more GHG reduction than
Electrification to Minimum Code but less GHG reductions than All-Electric + PV, which is still significantly greater than the evaluated mixed fuel reach codes.
For both 3- and 5- story buildings, there are increased first-year and lifecycle energy utility costs due to
electrification of end-uses but decreased utility costs when paired with PV. It is possible to address utility bill
increases by evaluating additional efficiency and PV requirements that improve on-bill cost-effectiveness. All
reach code packages for both building types show increased costs to build a unit due to central heat pump
water heaters. These costs should be further evaluated to account for changes to net energy metering.
All evaluated reach code packages were found cost-effective and code compliant for both building types under Electrification + Basic EE and Electrification + PV.
3.3.3 Nonresidential Buildings
There are viable reach code options with many considerations to be further evaluated for nonresidential
buildings. Generally, there are GHG reductions from Pathway 3 reach code for all buildings prototypes, except for the Medium Office reach code All-Electric to Code Minimum (prescriptive requirements). It is unclear
how to fully electrify Quick-Service Restaurants using a reach code because of a lack of prescriptive measures
in the Energy Code and cost-effectiveness modeling issues. There is also a lack of cost-effective options for
partial-electrification for Quick-Service Restaurants that would focus on reach codes for space heating and
cooling and water heating. Additionally, Medium Office and Small Hotels also have similar issues, but it is
possible that future cost-effectiveness study updates may resolve some of these issues within Climate Zone 7.
7 See CPUC NEM Revisit Proceeding R.20-08-020: https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/demand-side-management/net-energy-metering/nem-revisit; See CPUC D.22-12-056 (12/19/22): https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M500/K043/500043682.PDF.
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Medium Retail has the most viable Pathway 3 Reach Code as it results in GHG reductions, it is cost-effective,
but it still needs to be further evaluated for code compliance.
Finally, there is significant increases in the cost to build nonresidential buildings and lifetime energy utility bills
associated with full- or partial-electrification of Quick-Service Restaurants. All other prototypes show a range of
build cost increases and generally have energy utility bill reductions.
4 VIABILITY OF PATHWAYS BY BUILDING TYPE
Table 2 summarizes whether a pathway is viable and what issues exist in each pathway for building types
included in statewide cost-effectiveness studies. Pathways 1 and 2 are viable for all building types but cost and
feasibility of implementation by building type should be evaluated. Reach Codes under Pathway 3 are viable
for residential single-family and multi-family. However, many issue arise with cost-effectiveness and code
compliance for nonresidential buildings, particularly Medium Office, Small Hotels, and the difficulty with electrifying cooking appliances for restaurants.
Table 2 Viability of Pathways
May 9, 2023 Item #10 Page 12 of 27
Pathway 1: Electric Only Pathway 2: Electric Only Pathway 3: Electric Only
Building Type Via Natural Gas Moratorium To Minimum Code Plus Efficiency/PV/Battery
Residential I
Single Family
Low-Rise Multi-Viable under Viable Under Existing Authority
Family (1-3 stories) Existing Authority and Cost-Effectiveness Study
Medium-Rise
MuUifamily
(4-5 stories)
Non-Residential I
Exempt Building System without
Prescriptive Pathway in Energy
Medium Office Code (All-electric Only); Further
Viable under Cost-effective evaluation
Existing Authority Required (All-electric +)
Medium Retail Viable Under Existing Authority
and Cost-Effectiveness Study
Kitchen Appliance Electrification
Quick Service Viable under Existing Authority; Kitchen Appliance End-use Constraints Must be Evaluated;
Restaurant Exemptions Should be Evaluated for Cost and Viability Possible only Certain end-uses
can be electrified
Exempt Building System without
Viable under Prescriptive Pathway in Energy
Small Hotel Existing Authority Code (All-electric Only); Further
Cost-effective evaluation
Required (All-electric+)
Options for an All-Electric New Construction Requirement
Energy Policy Initiatives Center 8
5 OTHER CONSIDERATIONS
5.1 Grid Reliability
While an increase in all-electric homes and electric vehicles will increase overall electric consumption, it is not expected that the small number of new buildings constructed each year will pose a risk to grid reliability.
Several factors can affect the impact a new electrified home could have on overall electric grid reliability.
California Building Code allows jurisdictions to reduce the expected energy demand of new homes through
increased efficiency, which can support reliability and help to limit infrastructure investment.8 Also, some all-
electric buildings are required to install solar PV. If coupled with energy storage, homes can store energy
during the day when production is high, and use stored energy in the evening to meet the electric needs of the
home in the evening, when solar production is low or absent and reliability risk is highest.
All-electric buildings are subject to planned outages and unplanned outages on SDG&E’s grid that include
weather events, damage to the system, California Independent System Operator (CAISO) mandated load
curtailment (e.g., rolling blackouts) during extreme weather events, and public safety power shut offs (PSPS)
related to wildfire risk. SDG&E reliability is highly dependent on weather and extreme events.9 The City of
Carlsbad should evaluate new construction risk to CAISO load curtailment events10 based on the relevant circuit
as well as request reliability data specific to the City of Carlsbad and the location of any new construction.
5.2 Workforce Considerations
Based on the 2022 San Diego Regional Decarbonization Framework (RDF) Technical Report, it is expected that
decarbonization will generate an average of 27,000 jobs per year from 2021-2030 in the region with no
fossil fuel related job displacement or need for reemployment through 2030 because of planned retirement.11
From 2030-2050, it is estimated that there will be job displacement due to oil and natural gas consumption
declines. The report cites several approaches to mitigate the impact of this transition on workers, including
pension guarantees, reemployment guarantees, wage insurance, retraining support, and relocation support.12
A companion study to the RDF Technical Report identifies gas infrastructure jobs as the category at most risk in
the San Diego region.13 This includes jobs related to the maintenance and expansion of natural gas infrastructure, and those contracted out by SDG&E for pipefitting, trenching, and excavation work. The report
notes that over time as the natural gas side of our local utility operations may decline, the electric side activities
would increase, and that plumbing jobs related to water efficiency and reuse may be another area for workers
in this job category.
The report also provides a number of recommendations to address this transition to more electrified buildings,
including pilot projects related to waste-to-energy biomethane projects, green hydrogen demonstrations, and
carbon-free district energy. Another approach would be to pair requirements with incentives, such as establishing policies to encourage electric panel and service upgrades to make existing buildings “electric
ready” while providing incentives like streamlined permitting for projects that use a qualified workforce.
5.3 Equity Considerations
In general, residents in disadvantaged communities14 have higher energy costs burdens. They pay a higher
percentage of their income for energy utility bills (i.e., electricity, natural gas, and propane) that residents of
higher-income communities. Also, housing costs pose a barrier to home ownership in the entire region of San Diego. How an all-electric requirement affects residents and businesses located in these communities of
8 See California Energy Commission 2022 Building Energy Efficiency Standards Summary:
https://www.energy.ca.gov/sites/default/files/2021-08/CEC_2022_EnergyCodeUpdateSummary_ADA.pdf.
9 See SDG&E Electric System Reliability Annual Report 2021, p. 13, Table 2-4, & p. 18:
https://www.sdge.com/sites/default/files/SDGE%20Electric%20Reliability%20Report%20for%202021.pdf
10 See SDG&E Rotating Outages by Circuit: https://www.sdge.com/rotating-outages .
11 See 2022 San Diego Regional Decarbonization Framework Technical Report, p. 223 & 254.
12 See 2022 San Diego Regional Decarbonization Framework Technical Report, p. 254.
13 Carol Zabin, Maggie Jones , and Betony Jones , June 13, 2022, “Putting San Diego Count y on the High Road: Climate
Workforce Recommendations for 2030 and 2050, ” Inclusive Economics , Oakland, CA.
14 The State of California defines disadvantaged communities as those with higher economic, health, and environmental burdens. These are typically the highest scoring Census tracts identified through the state’s CalEnviroScreen tool.
May 9, 2023 Item #10 Page 13 of 27
Options for an All-Electric New Construction Requirement
Energy Policy Initiatives Center 9
electrifying residential units depends on many factors, including but not limited to the upfront installation cost of
equipment, the equipment being installed and replaced, type of construction (i.e., new vs. retrofit), age of the
building, electric and natural gas rates, construction costs passed on to the buyer, expected change in natural
gas and electric consumption, and climate zone.
For new buildings in Carlsbad, the financial implications depend on the pathway and building type. For
example, cost results from statewide analysis (Section 6.3.1) shows that for single-family residential buildings, meeting requirements for an all-electric home that meets minimum efficiency standards would be cheaper to
build compared to the mixed fuel baseline home but have an increased annual energy bill. By contract, an all-
electric home with added efficiency and solar PV would be slightly cheaper to build but have an annual energy
utility bill reduction. Similarly, a multi-family unit that is all electric and has solar PV would cost more to build
but result in annual energy utility bill reductions, whereas the all-electric prescriptive option would have a higher
cost to build and higher annual utility costs (Section 6.3.2).
Additional analysis would be needed to understand the specific cost and social equity implications of building all-electric buildings in the City of Carlsbad, such as but not limited to costs passed on to homeowners and
renters.
May 9, 2023 Item #10 Page 14 of 27
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Energy Policy Initiatives Center 10
6 APPENDIX A: SUPPORTING INFORMATION FOR THE POTENTIAL IMPACTS
OF AN ALL-ELECTRIC REQUIREMENT
This section summarizes the estimated impacts of an all-electric requirement for newly constructed buildings,
including the potential number of buildings affected, GHG emissions impacts, changes to the cost to build a unit
and energy utility bills, and reach code considerations applicable to all-electric requirement in the City of
Carlsbad.
6.1 Estimated Number of Buildings Affected (2023-2025 Code Cycle)
Based on adopted methods, the California Local Codes Cost Effectiveness Explorer estimates that during the 2023-2025 code cycle 830 single-family, 246 multifamily units, and approximately 1.3 million square feet of
new ground up nonresidential buildings will be constructed in the City of Carlsbad (Table 3).15 This is the total
estimated number of units that would be subject to an all-electric new building requirement.
The dwelling unit estimates are based on the following equation:
Total Affected Units = Possible Units (est. units per climate zone and vintage) x Applicability Rate
(includes assumptions for exemptions) x Annual Penetration Rate (% expected to comply each year) x
Active Policy Duration (years required).16
Table 3 Estimated Total Number of Affected Dwelling Units and Square Footage (Nonresidential) Affected by Type (2023-2025 Code Cycle)
Single-Family Multi-family Nonresidential
830 Units 24617 Units ~1.3 million
(ft2)18
6.2 GHG Impacts and Cost Considerations for All-Electric Pathways
The GHG reduction potential presented here is based on published results that are available for the Low-Rise Residential New Building Study, Multi-family New Building Study, and Nonresidential New Building Study.19 The
published results focus on electrification with updated results for Energy Code reach codes issued on September
12, 2022 for new Low-Rise Residential, February 28, 2023 for Multi-family, and January 21, 2023 for
Nonresidential. In general, GHG reductions are greatest for combinations of electrification, energy efficiency,
and PV (with and without batteries).
There are several inconsistencies and limitations associated with the results presented here. Per unit build cost
and utility bill costs are Climate Zone 7 specific for multi-family and use different methods than Single-family and Nonresidential, which present results as first-year and lifetime for both utility and per unit build cost. Build
cost and utility bill cost data are only available for certain Nonresidential building prototypes and packages.
There is City of Carlsbad specific cost data for all low-rise single-family residential packages in SDG&E service
territory. Additionally, City of Carlsbad specific GHG impacts were not calculated for projected new
construction multi-family dwelling units and new square footage for Nonresidential construction because of a
lack of available data. GHG results from available cost-effectiveness studies are provided instead. Finally,
15 Retrieved on March 20, 2023 from https://explorer.localenergycodes.com/
16 See Total Affected Units Method at https://explorer.localenergycodes.com/jurisdiction/carlsbad-city/study-results/7-SDGE?only_study_type=new-buildings; This uses an annual 0.93% growth rate from 2023-2025 with a baseline of 35,737 units
in 2020.
17 This uses an annual 0.80% growth rate from 2023-2025 with a baseline of 10,302 units in 2020:
https://explorer.localenergycodes.com/jurisdiction/carlsbad-city/building-estimates.
18 This uses the Cost Effectiveness Explorers’ projected growth in ground up nonresidential square footage for hotels/motels, Office/Banks, and Stores/Restaurants to provide an estimate for the modeled building prototypes from the 2022 Nonresidential
Cost Effectiveness Study. It excludes additions and alterations as well as Manufacturing/Warehouses/Labs, Hospitality/Other
Health Treatment, and Schools/Libraries/Labs.
19 https://explorer.localenergycodes.com/ ; Note: The Statewide Cost Effectiveness Explorer does not currently include estimates for GHG reduction as of March 14, 2023 for Multi-family and certain Nonresidential. GHG reduction information for these studies is taken directly from the relevant cost-effectiveness study.
May 9, 2023 Item #10 Page 15 of 27
Options for an All-Electric New Construction Requirement
Energy Policy Initiatives Center 11
cost-effectiveness studies do not include Pathway 1 (Natural Gas Moratorium). We assume that Pathway 2 (All-
Electric to Code Minimum) represents a proxy for a natural gas moratorium measure in terms of GHG and cost
impact as it is functionally equivalent. Results for Pathway 1 are only included where Pathway 2 All-Electric to
Code Minimum results are available.
Cost-effectiveness studies are not required if the City of Carlsbad adopts a Pathway 1 (Natural Gas
Moratorium) or Pathway 2 (All-Electric to Code Minimum). Certain exemptions are discussed for Pathway 1, Pathway 2, and Pathway 3 Nonresidential new construction because of cost issues, feasibility, and, for Pathway
3 reach codes, limits in prescriptive pathways in the Energy Code or modeling constraints for nonresidential
medium office and small hotels. Under Pathways 1, 2, 3, quick-service restaurant kitchen appliances are difficult
to electrify because of cost, feasibility of electrifying kitchen appliances, and, for reach codes, code compliance
and cost-effectiveness issues. If the City of Carlsbad opts for more stringent efficiency standards than state
code, there are 2022 cost-effectiveness studies published for new residential, multi-family, and non-residential
buildings. Given existing and planned update to these studies, it is anticipated that the City of Carlsbad would not have to conduct additional studies for a proposed local ordinance reach code under the 2022 State
Building Code unless the City of Carlsbad wishes to evaluate a specific building prototype or certain measures that are not covered by the current studies and planned updates to these studies.
The following discusses GHG impacts, cost, and cost-effectiveness for single-family, multi-family, and
nonresidential building new construction.
6.3 Residential Buildings
6.3.1 Residential Single-Family Buildings
Table 4 shows the published GHG and cost impacts based on an estimated total 830 total new single-family
units built between 2023-2025 for a range of all-electric measures and packages in the City of Carlsbad. The
information uses an all-electric prototype that either meets state code or includes the additional stated package (e.g., energy efficiency, PV, battery) for comparison to a mixed-fuel code compliant prototype (baseline). The
results of the published 2022 Cost-Effectiveness Study: Single Family New Construction use these prototypes in the below listed scenarios20 to determine cost-effectiveness, GHG reductions, and cost impacts. The analysis uses
a variety of electrification scenarios that vary by degree of efficiency, use of photovoltaics, and use of
batteries.21
Table 4 shows results specific to the City of Carlsbad for lifetime GHG reduction estimates, change in upfront
build cost per unit, and change in annual utility bill cost per unit for a range of all-electric packages and one mixed fuel reach code package that are included in the updated single-family published results for
comparison.22 Note that cost increases are shown in positive red values and cost reductions are shown in negative green values. The results from comparing all-electric options indicate that all-electric buildings meeting
the energy code minimum measures for Pathways 1 and 2 have higher GHG reductions than the mixed fuel
package (baseline), adding energy efficiency and PV to all electric single-family units increases the amount of
GHG emissions reduced under Pathway 3, and packages with PV had significantly higher GHG reductions
under Pathway 3. Also, except for the package with battery storage, all packages reduce the upfront cost to
build a unit compared to the mixed fuel package (baseline). Only the packages with PV result in annual energy
bill reductions. The mixed fuel baseline package has significantly higher build costs per unit but reduces annual energy utility bills. Finally, all evaluated reach code packages were found to be cost-effective. It is important to
remember that this comparison also includes Electrification to Code, which does not require a cost-effectiveness
analysis for adoption.
20 https://explorer.localenergycodes.com/jurisdiction/carlsbad-city/summary
21 Note: the primary assumptions for GHG reduction on the Explorer calculation were that the measures would be mandatory and that 50% of the electric supply is renewable during the code cycle moving towards zero-carbon by 2045.
22 Note that GHG reductions are the “expected lifecycle emissions savings (in metric tons of CO2 equivalent emissions) for a
measure from all affected dwelling units if the measure were required. This figure is calculated from multiplying the per home
Emissions Savings times Total Affected Units times 30 years…”: https://explorer.localenergycodes.com ; Assumptions used include
50% renewable portfolio standard electric supply (e.g., renewable energy content of electricity supply) reducing to zero-carbon by 2045 with code implementation beginning in July 2023 as mandatory for the specific code package. Difference outcomes are possible depending on the assumptions used.
May 9, 2023 Item #10 Page 16 of 27
Options for an All-Electric New Construction Requirement
Energy Policy Initiatives Center 12
Table 4 Residential Single-Family GHG and Cost Impacts by Measures/Packages for Climate Zone 7
6.3.1.1 Pathway 3 Reach Codes: Cost-Effectiveness and Code Compliance for Single-Family New
Construction
In addition to estimating the impact to upfront build costs and ongoing energy utility bills, statewide analysis
also determines whether a package of building measures is cost effective. For above code all-electric
requirements, the 2022 Cost-Effectiveness Study: Single Family New Construction found that all pathways are
cost-effective in Climate Zone 7 under the time dependent value method (TDV).23 Table 5 reflects efficiency
EDR224 compliance margins that were found cost-effective for specific packages in Climate Zone 7. Because
local reach codes must both exceed the Energy Commission performance budget (i.e., have a positive
compliance margin) and be cost-effective, the Study highlighted cells meeting these two requirements to help clarify the upper boundary for potential reach code policies. All results presented in this Study have a positive
compliance margin. Yellow represents TDV only25 and Green represents both TDV and On Bill26 cost-
effectiveness with positive compliance margins. Note: Electrification to Code is not included here because it does
not require cost-effectiveness analysis.
Table 5 Pathway 3 New Single-Family All-Electric Efficiency EDR2 Margins and Cost-Effectiveness Results
Utility Single-Family ADU
23 Time Dependent Value (TDV) Method: Energy Commission LCC methodology, which is intended to capture the total value or cost
of energy use over 30 years. This method accounts for long-term projected costs, such as the cost of providing energy during peak
periods of demand and other societal costs, such as projected costs for carbon emissions, as well as grid transmission and distribution impacts. This metric values energy use differently depending on the fuel source (e.g., natural gas, electricity, and propane), time of day, and season. For example, electricity used (or saved) during peak periods has a much higher value than
electricity used (or saved) during off-peak periods due to the less inefficient energy generation sources providing peak electricity
(Horii, Cutter, Kapur, Arent, & Conotyannis, 2014). This is the methodology used by the Energy Commission in evaluating cost
effectiveness for efficiency measures in Title 24, Part 6.
24 EDR2 is an Energy Design Rating (EDR) compliance margin based on the hourly time-dependent value (TDV) of energy use from a building. Comparatively, EDR1 is an EDR compliance margin based on source energy only.
25 Note: All-electric construction increases the use of electricity and is generally found not to be cost-effective for On Bill because
of the increased utility cost.
26 Utility Bill Impact (On Bill): Customer-based lifecycle cost (LCC) approach that values energy based upon estimated site energy usage and customer utility bill savings using today’s electricity and natural gas utility tariffs. Total savings are estimated over a 30-year duration and include discounting of future costs and energy cost inflation.
May 9, 2023 Item #10 Page 17 of 27
Pathway 1 & Pathway 2* I Electrification to Code Minimum
Pathway 3: All Electric Reach Code
Electrification + EE+ PV
Electrification + EE+ PV + Battery
Electrification + EE
Electrification + Basic EE
Mixed Fuel I EE + PV + Battery
Lifetime
GHG Reduction
-All Units
(MT CO2e)
3,103
5,889
5,701
3,370
3,189
1,020
* Pathway 1 is used as a proxy for Pathway 2 GHG and cost impacts.
--
Change in
Per Unit Cost
to Build
-$5,802
-$516
$4,928
-$4,201
-$5,288
$8,029
Change to
Annual Per
Unit Energy
Utility Bill
$487
-$450
-$450
$390
$456
-$358
Options for an All-Electric New Construction Requirement
Energy Policy Initiatives Center 13
Climate
Zone
Elect. +
Basic
EE27
EE EE+PV EE+PV/B Code
Min EE EE+PV EE+PV/B
CZ07 SDG&E 2.3 7 728 9.9 0.4 6.3 6.3 9.1
6.3.2 Multi-Family Buildings
There is a lack of available data to consistently quantify, on a per unit basis, the GHG emission reductions for
estimated new construction in the City of Carlsbad similar to the results presented above in Table 4. Consequently, this document relies on results from 2022 Cost-Effectiveness Study: Multifamily New Construction,
which shows GHG reductions for Climate Zone 7 for both All-Electric to Code Minimum and All-Electric + PV.
The Cost-effectiveness Study evaluates All-Electric + Basic EE (e.g., all prescriptive code requirements) but this is
not represented in the GHG analysis results. It is assumed that this package will produce emission reductions
between the All-Electric to Code Minimum and All-Electric + PV packages for Pathways 1 and 2. This means
that Pathway 1 and 2 All-Electric to Code Minimum, which does not require cost-effectiveness, and Pathway 3
reach codes for All-Electric + Basic EE and All-Electric + PV, which were found cost-effective and code compliant, are viable pathways for new Multi-family construction in the City of Carlsbad. Note: This cost results
included in this section use a different method and are not consistent with data provided for Single-Family
Residential and Nonresidential. The studies present costs results for Multi-Family buildings in first-year and
lifecycle formats.
For Multi-Family buildings, the results from the 2022 Cost-Effectiveness Study: Multifamily New Construction
covers low-rise 3-story and mid-rise 5-story building prototypes with GHG reduction in metric tons of carbon
dioxide equivalent per dwelling unit. In the GHG analysis, the study evaluated two all-electric building packages for each prototype: 1) prescriptive all-electric measures that meet 2022 Energy Code requirements
(All-Electric to Code Minimum) and 2) prescriptive all-electric measures with PV that offsets 100% of estimated annual electricity usage (All Electric + 100% PV). For comparison, the study also shows results for two mixed
fuel packages: one with additional energy efficiency (Mixed Fuel Efficiency) and another with energy
efficiency, PV, and battery (Mixed Fuel Efficiency + PV + Battery).
Figure 1 and Figure 2 are taken directly from the statewide study and highlight Climate Zone 7. They compare
estimated GHG impacts across all four packages for the two prototypes in all climate zones. Values are based on average annual GHG impacts per dwelling unit over the 30-year lifetime of the analysis.29,30 Data was not
available to calculate City of Carlsbad specific GHG reduction per dwelling unit as provided above for single-family units. Based on these results, all electric packages reduce more GHG emissions than mixed fuel
packages. Electrification of gas uses combined with PV has the greatest estimated GHG reductions. All electric
units built to the minimum code requirements have the next greatest reduction. Estimated GHG reductions for
mixed fuel packages are lower than the all-electric packages. For five-story buildings, the mixed fuel packages
GHG reductions are significantly lower.
27Note: This analysis is of an all-electric prototype that meets all the prescriptive requirements of the 2022 code.
28 Note: On Bill cost-effectiveness is based on the existing SDG&E Net Energy Metering (NEM) tariffs; the CPUC is currently in the process of changing these tariffs, which may change its On Bill cost-effectiveness. Further review is required once this change
occurs.
29 2022 Cost-Effectiveness Study: Multifamily New Construction, Revision 1.0 (Last modified 2/28/23), p. 31.
30 Note: This study did not account for changes to the Net Energy Metering tariff that will become effective April 15, 2023 in SDG&E service territory. These changes are expected to decrease the on-bill cost-effectiveness of requiring additional solar PV while increasing the cost-effectiveness of the all-electric prescriptive pathway.
May 9, 2023 Item #10 Page 18 of 27
Options for an All-Electric New Construction Requirement
Energy Policy Initiatives Center 14
Figure 1 3-Story GHG Reductions (Metric Tons) per Dwelling Unit
Figure 2 5-Story GHG Reductions (Metric Tons) per Dwelling Unit
For Multi-Family new construction, the first-year and lifecycle utility cost and build cost impacts are provided from the cost-effectiveness study (Table 6 and Table 7).31 The results show increased utility costs and build costs,
primarily because of the cost of central heat pump water heating, per dwelling unit for all-electric prescriptive reach codes. The All-Electric + PV package would reduce energy utility bills because of PV-related utility bill
reductions and increased build costs per unit because of central heat pump water heating. It is expected that
31 2022 Cost-Effectiveness Study: Multifamily New Construction, Revision 1.0 (Last modified 2/28/23), p. 20-28.
May 9, 2023 Item #10 Page 19 of 27
1.0
-;;;o.9 C 0 ~ 0.8
t .§_ 0.7
"' g 0.6 "" V ~ 0.5 .,
a:
~ 0.4
C,
~ 0.3
0 .J:. f 0.2 .,
15 0.1
0.0
1.0
-;;; 0.9 C 0
-~ 0.8
t E 0.7
"' g 0.6
"' V -6 0.5 .,
a:
~ 0.4 C, .,
; 0.3
0 .J:. ~ 0.2
~
c, 0.1
■ Mixed Fuel Efficiency
■ Mixed Fuel Efficiency + PV + Battery
■ All-Electric Code Minimum
■ All-Electric + PV
J J I J JJ.1 .L
CZOl CZ02 CZ03 CZ04 CZOS CZOI CZ07 :Z08 C209 CZlO CZ11 CZ12 C213 CZ14 CZ15 CZ16
■ Mixed Fuel Efficiency
■ Mixed Fuel Efficiency+ PV
■ All-Electric Code Minimum
■ All-Electric + PV
0.0 -_I J __. _I .I .I .I .I .I .I
CZOl CZ02 C203 C204 CZOS CZO CZ07 208 C209 C210 CZ11 CZ12 CZ13 CZ14 C215 C216
Options for an All-Electric New Construction Requirement
Energy Policy Initiatives Center 15
the recent reform to PV net energy metering will maintain these reduced energy utility bills as the PV will serve
increased on-site load, decreasing utility costs.32
Table 6 3-Story Multi-Family: Pathway 3 Build Cost and Utility Bill Impacts
Table 7 5-Story Multi-family: Pathway 3 Build Cost and Utility Bill Impacts
6.3.2.1 Pathway 3 Reach Codes: Cost-effectiveness and Code Compliance for New Multi-Family
Construction
For each prototype, the following represents the results of the cost-effectiveness analysis for efficiency TDV
compliance margins in Climate Zone 7. Because local reach codes must both exceed the Energy Commission
performance budget (i.e., have a positive compliance margin) and be cost-effective, the following highlighted cells meeting these two requirements show the upper boundary for potential reach code policies. All results show
below in Climate Zone 7 have a positive compliance margin (Table 8).
• Cells highlighted in green depict cases with a positive compliance margin and cost-effective results
using both On-Bill and TDV approaches.
• Cells highlighted in yellow depict cases with a positive compliance margin and cost-effective results
using either the On-Bill or TDV approach.
• Cells not highlighted depict cases with a positive compliance margin but that were not cost-effective
using either the On-Bill or TDV approach.
Table 8 New Multi-family Cost-effectiveness and Compliance Margin Results
Climate
Zone Utility 3-Story 5-Story
32 See CPUC NEM Revisit Proceeding R.20-08-020: https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/demand-side-management/net-energy-metering/nem-revisit; See CPUC D.22-12-056 (12/19/22): https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M500/K043/500043682.PDF.
May 9, 2023 Item #10 Page 20 of 27
Pathway 3: All-electric
All-electric Prescri ptive
All-electric+ 100% PV
Mixed Fue l
IEE+ PV + Battery
Pathway 3: All-electric
All-electric Prescriptive
All-electric + 100% PV
Mixed Fue l I EE+ PV
1111 -
Change in
Per Unit Cost to Build
Lifecycle
First Year (2022$)
$697 $1 ,029
$2 ,777 $3 ,734
$3,498 $5,493
Change in
Per Unit Cost to Build
Lifecycle
First Year (2022$)
$608 $1 ,185
$1 ,387 $2 ,198
$212 $237
Change to Annual
Per Unit Energy Utility Bill
Lifecycle
First Year (2022$)
$69 $527
-$723 -$19,318
-$550 -$13,714
Change to Annual
Per Unit Energy Utility Bill
Lifecycle
First Year (2022$)
$74 $500
-$192 -$6,131
$0 $0
Options for an All-Electric New Construction Requirement
Energy Policy Initiatives Center 16
Elect. +
Basic EE33
Electric +
PV
Elect. +
Basic EE34
Electric +
PV
CZ07 SDG&E 20% 20% 11% 11%
6.4 Nonresidential Buildings
There are several considerations that must be accounted for to implement Pathways 1, 2, and 3, particularly for
restaurants. First, there is a lack of data to calculate both GHG, energy utility bill, and build cost impacts for
Pathway 1 and 2. Consequently, only Pathway 3 is discussed below. Further analysis should be undertaken to
better understand the cost effectiveness and feasibility of these pathways even though they are viable from an
authority standpoint. Second, in all viable Pathway 3 reach code packages, there are GHG reductions with the
exception of All-Electric to Code Minimum (prescriptive requirements)35 for Medium Office, which shows a
reduction of 0%. It is possible that future reach code cost-effectiveness and compliance analysis will allow additional measures that increase result in larger GHG reductions for Medium Office buildings. Consequently,
authority exists to adopt a Natural Gas Moratorium or All-Electric to Code Minimum but there is significant
difficulty in achieving Pathway 1, 2, and 3 all-electric minimum code and reach code requirements for Quick-
Service Restaurants. Evaluation of alternatives that require specific end-use electrification should be considered
for cost and feasibility as described below. Additionally, evaluation of Pathway 3 reach codes for Quick-
Service Restaurants, Medium Office, and Small Hotel prototypes should be undertaken given the lack of
prescriptive pathway and/or cost-effectiveness modeling issues. Finally, there are significant upfront build and lifetime energy utility cost increases associated with full or partial electrification of Quick-Service Restaurants.
For Pathway 3 Nonresidential building reach codes, the results from the 2022 code cycle Nonresidential New
Construction Cost-effectiveness Study cover four main prototype buildings: Medium Office, Medium Retail,
Quick-Service Restaurant, and Small Hotel. The energy packages were evaluated over a 15-year lifecycle.
(Note: The Cost-effectiveness study was unable to determine an all-electric prescriptive pathway or all-electric
+ efficiency pathway for Medium Office and Small Hotel prototypes because the pathway could either not
comply with all three-compliance metrics (Efficiency TDV, Total TDV, and Source Energy36) or because of modeling constraints. Future iterations of the study will reevaluate these prototypes with a central heat pump
boiler).37 As such, the “Mixed-Fuel + EE” output is highlighted for these two prototypes to be consistent with study’s conclusion that these building types use higher efficiency compliance requirements for mixed fuel that
exempt end-uses that currently lack a prescriptive pathway for all-electric from a nonresidential all-electric
measure until a later iteration of the study can identify a feasible measure or the modeling constraint is
resolved. For both Medium Office and Small Hotel, an Electric-Preferred38 reach code pathway is cost-effective
and compliant where electrification is required based on a specific viable prescriptive pathway for individual end-uses but not all end-use (e.g., exempt central space heating from being all-electric but require a higher
building performance margin).
6.4.1 Pathway 3 Reach Code for Medium Retail
Figure 3 shows all-electric GHG reductions (green) and GHG increases (red) as a percentage compared to a mixed fuel baseline for Medium Retail. (Note: The GHG multiplier from the California Building Energy Code
Compliance (CBECC) software uses utility emission modifiers assigned for each of the sixteen climate zones;
33Note: This analysis is of an all-electric prototype that meets all the prescriptive requirements of the 2022 code.
34Note: This analysis is of an all-electric prototype that meets all the prescriptive requirements of the 2022 code.
35 Note: This Nonresidential term has a different meaning than the all-electric to minimum code used for single-family and multi-
family. The Nonresidential term refers to mandatory prescriptive requirements, which is above code minimums. The single- and
multi-family terms refers to meeting the code minimum consistent with Pathways 1 and 2.
36 See 2022 Code: Nonresidential New Construction Reach Code Cost-effectiveness Study, Revision 1.0 (last modified 11/16/22), Section 2.3, p. 7-8.
37 See 2022 Code: Nonresidential New Construction Reach Code Cost-effectiveness Study, Revision 1.0 (last modified 11/16/22),
Table 16, p. 39.
38 Defined as: Allow mixed-fuel appliances but require a higher building performance via efficiency, total, or source compliance metric; See 2022 Code: Nonresidential New Construction Reach Code Cost-effectiveness Study, Revision 1.0 (last modified 11/16/22), Section 5, p. 37.
May 9, 2023 Item #10 Page 21 of 27
Options for an All-Electric New Construction Requirement
Energy Policy Initiatives Center 17
however, these multipliers do not vary by utility in each zone. Individual utility assumptions may vary.
Specifically, this method provides a valid output for SDG&E territory that covers all CZ07 but does not account
for Clean Energy Alliance (CEA) electricity supply). There are Pathway 3 All-Electric to Code Minimum
(prescriptive requirements) and All-Electric Code + EE (additional energy efficiency required) show GHG
reductions (Note: We believe that there is an error in the Figure below and that the Code Minimum column
belongs to All-Electric not Mixed Fuel).
Figure 3 GHG Impacts - Medium Retail
Based on the updated Nonresidential published results, Table 9 shows lifecycle build cost per unit and annual
utility bill cost per unit for all-electric packages and one mixed fuel package for medium office buildings.
Lifetime GHG reductions are excluded because data is not available to perform this calculation.
Table 9 New Nonresidential Medium Retail Build Cost and Annual Utility Bill Cost
6.4.2 Pathway 3 Reach Code for Quick-Service Restaurants
Figure 4 shows all-electric GHG reductions (green) and GHG increases (red) as a percentage compared to a
mixed fuel baseline for Quick Service Restaurants. There is a distinction made for Quick Service Restaurants
reflecting the difficulty of fully electrifying commercial kitchen appliances cost-effectively. The Quick Service
Restaurant prototype consequently provides both an all-electric Pathway 3 for 1) electrifying HVAC and service hot water (SHW) called “All-electric “HS””; and 2) All-electric for all usage. The All-electric “HS” (HVAC +
SHW) pathway is both cost-effective and compliant when adding efficiency and solar for CZ07 while the All-
electric pathway is not,39 reflecting a need to exempt kitchen appliances from all-electric measures.
Additionally, the All-electric “HS” (HVAC + SHW) also includes a “EE + LF” pathway. “LF” means “Load
39 See 2022 Code: Nonresidential New Construction Reach Code Cost-effectiveness Study, Revision 1.0 (last modified 11/16/22), Section 5.3 Quick-Service Restaurant (QSR), p. 43.
May 9, 2023 Item #10 Page 22 of 27
CZ
cz0l
cz02
cz03
cz04
cz05
I cz07
cz09
czl0
czll
cz12
czl3
cz14
czlS
cz16
All Electric I Electrifi cation + EE
Mixed Fuel I EE
Mixed Fuel All-electric
EE
-49
1-21
i1e
-14
-h~
-59
-8'
_,IJ,
lj fl
~17
-b.5
-391 -~
Code Min EE
-291 9% I
-fil' 10% l
-SP 11%
-59 10%
-59 12%
7% 14%
3% 13% _.J
-9 3% I
~2 2% I
-11 9%
-8 10%
-5' 10%
0% 3%
-~ 2%
Change in
Per Unit Cost
to Build
$5,795
$8 ,269
Change to
Annual Per
Unit Energy
Utility Bill
$1,734
$1 ,744
Options for an All-Electric New Construction Requirement
Energy Policy Initiatives Center 18
Flexibility” represent three measures: 1) temperature setback using smart thermostat; 2) demand response
capable heat pump water heater (HPWH); and demand response lighting.40
Figure 4 GHG Impacts – Quick-Service Restaurant
Table 10 shows lifecycle build cost per unit and annual utility bill cost per unit for all-electric packages and one
mixed fuel package for quick-service restaurant buildings.
Table 10 New Nonresidential Quick-Service Restaurant Build Cost and Annual Utility Bill Cost
6.4.3 Pathway 3 Reach Code for Medium Office and Small Hotel
Figure 5 and Figure 6 highlight the All-Electric to Code Minimum pathway, as a viable Pathway 3 means of
reducing GHG emissions. Notably, there does not appear to be GHG reductions for Medium Office All-Electric
to Code Minimum (with prescriptive requirements) but both Small Hotel Options show GHG reductions. While other Pathways show GHG reductions, the fact that the reach code option for these prototypes lack a viable
prescriptive pathway under the Energy Code and there are modeling constraints means that there is not a presently viable option beyond the code minimum.
40 See 2022 Code: Nonresidential New Construction Reach Code Cost-effectiveness Study, Revision 1.0 (last modified 11/16/22), Section 3.2.3 Load Flexibility, p. 29-29.
May 9, 2023 Item #10 Page 23 of 27
Mixed Fuel CZ EE
czOl I 10%
cz02 7%
cz03 8%
cz04 7%
czOS 8%
I cz07 6%
cz09 5%
czlO 5%
czll 6%
cz12 6%
cz13 6%
cz14 6%
czlS 4%
cz16 ] 8%
All Electric
All-electric "HS" (HVAC+SHW) All-electric
Code M in EE
:!1% 26%
h6% 9%
14% 0%
12% 7%
14% 0%
8% 14%
9% 12%
10% 13%
13% ]17%
14% b.7%
]12% ]15%
13% b.6%
J 7% J 9%
M % 2)3%
EE+ U: EE+PV Code Min
28% 21% 47%
1% 1% 45%
,2% 12% 45%
9% 9% 43%
!2% !2% 45%
43%
15% h6% I 43%
43%
13% 15% 43%
14% 15% 42%
8% 8% 43%
8% 9% 44%
~6% }7% 43%]
7% l 8% 4~
J 11% J 12% 40%1
211% 2}% 44%
Change in
Per Unit Cost
to Build
EE
52%
49%
51%
49%
51%
48%
48%
46%
46%
46%
46%
48%
46U
4~
42%1
49%
Change to
Annual Per
Unit Energy
Utility Bill
Partial Electrification + EE + PV $389,210 -$12,892
Partial Electrification + EE + Load Flex $209,291 -$3,023
Partial Electrification +EE $187,659 -$1 ,523
Electrification + EE $707,906 -$132, 153
Mixed Fuel I EE $90,123 -$23,348
Options for an All-Electric New Construction Requirement
Energy Policy Initiatives Center 19
Figure 5 GHG Impacts - Medium Office
Figure 6 GHG Impacts - Small Hotel
Table 11 shows lifecycle build cost per unit and annual utility bill cost per unit for all-electric packages and the one mixed fuel package for Medium Office buildings. Small Hotels are excluded because there is no data on
cost impacts for electrification presently available.
May 9, 2023 Item #10 Page 24 of 27
Mixed Fuel All-electric
CZ EE Code Min EE EE+ LF
cz0l ( II. 3~ 4 12%
cz02 1 (~ 1 ~ s~J
cz03 u l ,~ 1 8%
cz04 2 " .!/: 1 ~
cz0S l ~J ( 16 2 161 9%J
cz06 29' 2 16 I 8%
cz07 3~_] ( 16 3 16 l s,d
cz08 3 16 216] sj
cz09 216 -~ 2161 7%
czl0 2~ I % 0 16 Gj(,
czll 1~ % % $%
cz12 u ] % % ]%
cz13 2"1 % % 3 %
cz14 29' % I % Ii%
czlS 3iK -!I: 216] nt
cz16 till. 1 IQ 2 ,1 79'1
CZ Mixed Fuel All-electric All-electric
EE Code Min EE EE+PV Code Min (PTHP)
cz0l ]13% 47;c] 48U 50% 47,c:J
cz02 11% 42% 44% 47% 43%
cz03 12% 43% 45% 48% 43%
cz04 11% 41% 44% 46% 42%
cz0S J 11% 43%_ 45% 48% 43%
cz06 10% 41% 43% 46% 41%
cz07 10% 41% 43% 47% I 41% I
cz08 J 10% """" 42%] 46%] .. .,,.,
cz09 10% 40% 42% 46% 40%
czl0 -11% fi%] 39i] 4~ 3~]
czll 12% 39% 41% 43% 39%
cz12 12% 38% 41% 43% 39%
cz13 11% 37% 39% 42% 37%
cz14 12% 3~ 40% 44% 38%
c,15 J 10% 3~ 3~ 40%] 3~
cz16 13% 43% 46% 48% I 45% I
Options for an All-Electric New Construction Requirement
Energy Policy Initiatives Center 20
Table 11 New Nonresidential Medium Office Build Cost and Annual Utility Bill Cost
6.4.4 Pathway 3 Reach Codes: Cost-effectiveness and Code Compliance for New
Nonresidential Construction
Presently, there are viable reach code options for Medium Retail. Medium Office and Small Hotels may be
found cost-effective and compliant under future planned updates to the study but are currently not viable as reach codes. There are no cost-effective options for Quick-service Restaurant reach codes, either all-electric or
partial-electrification.
For Nonresidential, cost-effectiveness and compliance41 are evaluated. Nonresidential Cost-effectiveness is
evaluated based On-bill42 and time dependent valuation (TDV)43 using a different method from residential and
multi-family. The evaluation assessed incremental build costs of the energy package over a 15-year lifecycle. Cost-effectiveness is presented using net present value (NPV)44 and benefit-to-cost (B/C)45 ratio metrics. The
following show the cost-effectiveness conclusions for the four Nonresidential prototypes (Medium Retail, Quick-Service Restaurant, Medium Office, and Small Hotel). Table 12 through Table 16 present cost-effectiveness and
code compliance results. Similar to the results presented above, results are shaded as follows:
• Cost-effectiveness results with color highlight: o Green highlight: for — for scenarios that are cost-effective on both On-Bill and TDV metrics,
but may or may not be compliant. o Yellow highlight — for scenarios that are cost-effective on either one of the On-Bill/TDV
metrics, may or may not be compliant.
41 A Nonresidential New Construction’s Energy packages must comply three compliance metrics: Efficiency TDV: accounts for all regulated end-uses but does not include the impacts of PV and battery storage; Total TDV: includes regulated end-uses accounting for PV and battery storage contribution; and Source Energy: based on fuel sued for power generation, assuming utilities meet all
renewable portfolio (RPS) goals and other obligations projected over 15-year lifecycle.
42 Nonresidential On-Bill: Customer-based lifecycle cost approach that values energy based upon estimated site energy usage
and customer On-Bill savings using electricity and natural gas utility rate schedules over a 15-year duration accounting for a three percent discount rate and energy cost inflation based on Cost-effectiveness Appendix 8.2.
43 Nonresidential TDV: TDV was developed by the Energy Commission to reflect the time dependent value of energy, including
long-term projected costs of energy such as the cost of providing energy during peak periods of demand and other societal costs
including projected costs for carbon emissions and grid transmission impacts. This metric values energy uses differently depending
on the fuel source (gas, electricity, and propane), time of day, and season. Electricity used (or saved) during peak periods has a much higher value than electricity used (or saved) during off-peak periods. This refers to the “Total TDV” that includes all the energy end uses such as space-conditioning, mechanical ventilation, service water heating indoor lighting, photovoltaic (PV) and
battery storage systems, and covered process loads.
44 NPV: Net savings (NPV benefits minus NPV costs). If the net savings of a measure or package is positive over a lifetime of 15
years, it is considered cost-effective. Negative net savings represent net costs to the consumer. A measure that has negative energy cost benefits (energy cost increase) can still be cost-effective if the incremental costs to implement the measure (i.e., construction and maintenance cost savings) outweigh the negative energy cost impacts.
45 B/C Ration: Ratio of the present value of all benefits to the present value of all costs over 15 years (NPV benefits divided by
NPV costs). The criterion for cost-effectiveness is a B/C greater than 1.0. A value of one indicates the savings over the life of the
measure are equivalent to the incremental cost of that measure. A value greater than one represents a positive return on investment.
May 9, 2023 Item #10 Page 25 of 27
All Electric
Electrification + EE
Electrification + EE + Load Flex
Mixed Fuel
--
Change in
Per Unit Cost
to Build
-$4,434
-$4,434
$2,426
Change to
Annual Per
Unit Energy
Utility B ill
-$641
-$1,965
-$694
Options for an All-Electric New Construction Requirement
Energy Policy Initiatives Center 21
o Gray highlight — for scenarios that are not cost-effective on either metric, either compliant
currently or likely to be compliant in future. o White highlight — for scenarios that are not cost-effective on either metric and are not
compliant.
• Compliance results with cell values: o “EffTDV Margin” percentages — for scenarios that are compliant, across both Manual and
CBECC software output, the reported value is the minimum of the two. o “-” for scenarios that do not comply across any one code compliance metric. o “TBD” – for scenarios that are likely to be compliant with modeling updates or software
versions in future, maybe compliant across either one of the Manual or CBECC software output
approach or has a system type modeling limitation such as central heat pump boiler for
Medium Office and Small Hotel.
Table 12 Cost-effectiveness and Compliance Summary - Medium Retail
Climate Zone Utility All-Electric
EE
CZ07 SDG&E 14%
Table 13 Cost-effectiveness and Compliance Summary - Quick-Service Restaurant (without cooking
electrification)
Climate
Zone
Utility Mixed Fuel All-Electric “HS” (HVAC+SHW)
EE Code Min EE EE+LF EE+PV
CZ07 SDG&E 21% - 9% 13% 9%
Table 14 Cost-effectiveness and Compliance Summary - Quick-Service Restaurant (with cooking electrification)
Climate Zone Utility All-Electric “HS” (HVAC+SHW)
Code Min EE EE+LF
CZ07 SDG&E - 11% 14%
Table 15 Cost-effectiveness and Compliance Summary - Medium Office
Climate Zone Utility Mixed Fuel All-Electric
EE Code Min EE EE+LF
CZ07 SDG&E 5% TBD TBD TBD
May 9, 2023 Item #10 Page 26 of 27
-
Options for an All-Electric New Construction Requirement
Energy Policy Initiatives Center 22
Table 16 Cost-effectiveness and Compliance Summary - Small Hotel
Climate Zone Utility Mixed Fuel All-Electric
EE Code Min EE EE+PV
ZO07 SDG&E 4% TBD TBD TBD
May 9, 2023 Item #10 Page 27 of 27
Tammy Cloud-McMinn
From: James Wang <tc4312@gmail.com>
Thursday, May 4, 2023 7:06 PM All Receive -Agend_a Item# iO Sent:
To: City Clerk For the Information of the:
City Council May 9th Mtg -Item 10 (Building Electrification) DateS/~S~~N;'Lcc ~
CM v ACM .-DCM {3) ~
Subject:
Honorable Carlsbad City Council:
You are already familiar with the unequivocal scientific evidence detailing the severity of our climate
crisis. The EPIC report even describes its unwelcome consequences in Carlsbad.
Given the dire state of the climate and its implications for us and future generations, it behooves us to
lessen its cause, Greenhouse Gas (GHG) emissions, in any way we can.
And if in the course of doing so we should also happen to:
• Save money,
• Improve our health,
• Increase public safety,
• Lessen the danger in our homes,
• Achieve goals of our Climate Action Plan,
• Comply with AB3232, EO B-30-15, SB100, and
• Progress towards satisfying EO B-55-18 ...
so much the better.
Building electrification achieves all of these goals.
Therefore, I urge you to please approve Item 10 with Option 1 (implement Council's April 19, 2022
motion) with instructions to draft the most comprehensive ordinance possible.
Thank you.
· Sincerely,
James Wang
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1
Tammy Cloud-McMinn
From:
Sent:
To:
Subject:
Good morning,
Mark Mervich <mm@memervich.com>
Friday, May 5, 2023 8:27 AM
City Clerk
Climat Action Plan
Building electrification is an effective measure for reducing carbon in our atmosphere. Please include it in your Climate
Action Plan.
Also consider that local solar and wind power generation is a much cheaper solution than large remote solar or wind
farms as it does not require expensive grid upgrades.
Mark Mervich
650-400-0501
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1
Tammy Cloud-McMinn
From:
Sent:
To:
Subject:
Jeff Wegner <Jeff.Wegner@crbgroup.com>
Friday, May 5, 2023 8:34 AM
City Clerk
City Council May 9th Mtg -Item 10
Re: Item 10-ELECTRIFICATION OF NEW BUILDINGS IN CARLSBAD
Carlsbad City Council,
I am a senior mechanical engineer, and member of the SDBEC Technical Assistance, providing designs for the built
environment in the life science markets. I have personally provided all-electric designs for Industrial, Academic,
Laboratory, and Commercial food preparation facilities. In the life sciences, most of our facilities have critical
backup/standby power generation, however they also do not require natural gas. Diesel (and biodiesel) are preferred
thereby eliminating the need for natural gas infrastructure city-wide. While an all-electric design for these greater
energy consuming facilities c·an have its challenges, we have options available today that are cost effective over the
building's life cycle.
For facilities with lower consumption, the options available today are far superior to that of traditional natural gas
appliances, from a total cost of ownership and health+ wellness perspective.
I look forward to hearing Carlsbad's continued leadership on the topic of Building Electrification. Thank you, and please
feel free to call or email with any questions or comments. Best regards, -Jeff Wegner
Jeff Wegner
Fellow -Energy+ Sustainability I Associate
PE, CEM, LEED AP
Engineering I Architecture I Construction I Consulting
3207 Grey Hawk Court, Suite 150 Carlsbad, CA 92010
M: 619.971.9558 0: 760.496.3714 crbgroup.com
THE RELENTLESS PURSUIT OF SUCCESS. YOURS."'
(!D O Click here for more info
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safe.
1
Tammy Cloud-McMinn
From:
Sent:
To:
Subject:
Rita Clement <ritalclement@gmail.com>
Friday, May 5, 2023 12:56 PM
City Clerk
City Council May 9th Meeting item 10
I strongly support "Item 10 -ELECTRIFICATION OF NEW BUILDINGS IN CARLSBAD".
Building Electrification
• Need to electrify buildings, specifically asking for new construction (residential,
multi-family and commercial). There is the expectation that the 2025 state
building codes will mandate this.
• Buildings make up approximately 30% of GHG emissions. In CA all power is to
be generated from renewables by 2045 so removing natural gas (mostly
methane) from buildings means much cleaner buildings as the grid is powered by
more renewables.
• Carlsbad was the first in the state (2019) to have a Reach (stretch) building code
for water heaters; we need to do the same for the entire home.
• There are great substitutes for gas appliances: 1) heat pump water heaters are
3-4x more efficient than gas, 2) heat pump space heaters act not only as heaters
but also air conditioners, 3) induction cooking is safer and faster than cooking
with gas.*
• Cooking with gas has health consequences including almost 13% of childhood
asthma attributed to gas stoves.
Rita Clement
Transportation Team Co -Leader & South Bay Eco-Justice Team Leader
ritalclement@gmail.com
619-675-1925
Fill out the volunteer interest form
Web I Facebook I lnstagram I Twitter I Donate
DI GO +350
CLIMATE ACTION
en attachments or click on links unless you recognize the sender and know the content i
1
Tammy Cloud-McMinn
From:
Sent:
To:
Subject:
Ann Feeney <feeney@scripps.edu>
Saturday, May 6, 2023 4:13 PM
City Clerk
City Council May 9 Item #10
Dear Mayor and City Councilmembers,
I hope that you will support electrification of new construction in Carlsbad as part of your CAP. The IPCC reports have
made it extremely clear that we must stop burning fossil fuels ASAP to avoid the worst impacts of climate
change. Buildings are second only to transportation as a source of GHG emissions. Burning "natural gas", which is
essentially all methane, a very potent greenhouse gas, in homes not only exacerbates the climate crisis with the GHG
emissions, but is also very unhealthy due to the indoor air pollution generated from burning gas inside. Respiratory
illness such as asthma show increased incidence in homes with gas. Luckily, there are excellent, highly efficient, superior
alternatives to gas appliances such as heat pump water heaters and induction stoves. Heat pump space conditioners
both heat and cool homes and other buildings, and with increasing summer temperatures, having this cooling is more
and more essential. Please support electrification of all new construction in Carlsbad, for the sake of your residents and
those who work in Carlsbad.
Sincerely,
Ann Feeney, Ph.D.
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Tammy Cloud-McMinn
From:
Sent:
To:
Subject:
Dear Mayor and City Council,
Mike McMahon <2mmcmahon@gmail.com>
Sunday, May 7, 2023 3:19 PM
City Clerk
City Council Comment May 9th Item 10 -ELECTRIFICATION OF NEW BUILDINGS IN
CARLSBAD
Last year, the city council received a presentation showing the health and safety impacts of gas appliances and on why
moving to all-electric buildings was not only less expensive for the builder, but would put Carlsbad on a path to 100%
sustainable energy for our future while also be aligned with California mandates.
I urge you to continue to implement the City Council's April 19, 2022 motion.
Please promote Pathway 3 and its configuration of electrification plus PV plus Battery as this is most efficient for
residential single-family housing.
Thank you for your consideration,
Michael McMahon
2645 Sutter St
Carlsbad, CA 92010
Note: While a recent 9th Circuit decision created pause, it had specific jurisdiction and that "local governments have no
more or less legal authority than they did before the Ninth Circuit issued it ruling"*
* Climate Law https://blogs. law.columbia .ed u/climatecha nge/2023/04/18/ninth-circuit-holds-berkeleys-gas-ba n-
preempted-by-u-s-energy-policy-conservation-act/
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Tammy Cloud-McMinn
From:
Sent:
To:
Subject:
City Council Members,
Bob Wilcox <rswilcox@gmail.com>
Sunday, May 7, 2023 9:49 PM
City Clerk
City Council May 9th Mtg -Item 10
I am writing in support of adding a building electrification ordinance in Carlsbad {Item 10 on the city council meeting
agenda) as a way to achieve our city's goals of reducing carbon emissions.
As I discussed in my presentation to City Council last year, eliminating gas infrastructure from new buildings reduces
pollution, saves money, and improves public health and safety. There is no good reason to be spending thousands of
dollars to install gas infrastructure in new buildings when we know that gas combustion must be reduced dramatically in
the near future. About 30% of emissions in California come from buildings, and new construction of gas infrastructure
would only exacerbate the problem. These stranded capital assets will be a financial burden and environmental
headache going forward, and we need to stop adding to the problem immediately. Building electric infrastructure from
the beginning will save tremendous amounts of money compared to future retrofits.
I hope that you will do the right thing for the future of our environment and the built infrastructure of the city by
mandating that any new construction is compatible with a clean electric future.
Regards,
Bob Wilcox, Carlsbad
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1
Tammy Cloud-McMinn
From:
Sent:
To:
Subject:
Hello,
Ella Player <e11ap5512@gmail.com>
Monday, May 8, 2023 9:57 AM
City Clerk
City Council May 9th Mtg -Item 10
I am writing today to discuss Item 10 -ELECTRIFICATION OF NEW BUILDINGS IN CARLSBAD.
Below are my talking points.
Building Electrification
• Need to electrify buildings, specifically asking for new construction (residential,
multi-family and commercial). There is the expectation that the 2025 state
building codes will mandate this.
• Buildings make up approximately 30% of GHG emissions. In CA all power is to
be generated from renewables by 2045 so removing natural gas (mostly
methane) from buildings means much cleaner buildings as the grid is powered by
more renewables.
• Carlsl;>ad was the first in the state (2019) to have a Reach (stretch) building code
for water heaters; we need to do the same for the entire home.
• There are great substitutes for gas appliances: 1) heat pump water heaters are
3-4x more efficient than gas, 2) heat pump space heaters act not only as heaters
but also air conditioners, 3) induction cooking is safer and faster than cooking
with gas.*
• Cooking with gas has health consequences including almost 13% of childhood
asthma attributed to gas stoves.
Thanks,
Ella Player
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safe.
1
Tammy Cloud-McMinn
From:
Sent:
To:
Subject:
Hello, City Council,
Susan Kobara <susankobara13@gmail.com>
Monday, May 8, 2023 12:00 PM
City Clerk
City Council May 9th Meeting -Item 10
Regarding Item 10 -ELECTRIFICATION OF NEW BUILDINGS IN CARLSBAD
All Receive -Agenda Item#/ 0
For the Information of the:
_Rf_(_COUNCIL
Date5Jili:l3. CA V--CC ✓
CM vACM £DCM (3) .,.,--
I understand that there will be discussion tomorrow of our Carlsbad Climate Action Plan as well as building
electrification. I support a new construction building ordinance with no exceptions.
I feel strongly that we need to electrify buildings, specifically all new construction. We need to have a Reach building
code for the entire home. Electrification of all new construction is good for our health, the climate and our community.
Thank you.
Susan Kobara
Carlsbad, CA 92009
760.613.4485
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Tammy Cloud-McMinn
From:
Sent:
To:
Subject:
Hello Carlsbad City Council,
Pawel Vijayakumar <pbvijaya@ucsd.edu>
Monday, May 8, 2023 2:00 PM
City Clerk
City Council May 9th Mtg -Item 10
I'm an undergraduate student at UCSD and am enrolled in a class that studies the psychology of social change, with a
focus on the climate change crisis.
We specifically addressed the importance of building electrification, especially in new construction. I learnt that
buildings make up approximately 30% of greenhouse gas emissions and therefore are a major contributor to the climate
change crisis. Furthermore there are already more cost effective substitutes to gas appliances, such as heat pumps and
induction stoves.
As a result, I am in support of Item 10 -ELECTRIFICATION OF NEW BUILDINGS IN CARLSBAD, and would like to see a
policy with few commercial exceptions.
Thank you,
Pawel Vijayakmnar
UCSanDiegQ
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Tammy Cloud-McMinn
From:
Sent:
To:
Subject:
Wendy Mihalic <wmihalic@gmail.com>
Monday, May 8, 2023 2:35 PM
City Clerk
City Council May 9th Mtg -Item 10 Electrification of New Buildings in Carlsbad
Honorable Mayor and Council Members,
I am writing to express my SUPPORT for a building electrification provision in the 2023 Carlsbad CAP. As a
founding member of the Clean Energy Alliance, Carlsbad has access to clean, renewable electricity now -up
to 100% with the Green Impact option. Buildings represent a significant source of GHG emissions now, and
they are long-lived. It is estimated that 80% of the buildings that will exist in 2050 already exist today. That
means that any new gas infrastructure may remain a health and environmental threat for a very long time.
Safe, cost-effective electric appliances are available now. Waiting three years for Title 24 to catch up is not an
option in the face of our climate emergency.
I urge this Council to act now.
Thank you for your consideration,
Wendy Mihalic
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Tammy Cloud-McMinn
From:
Sent:
To:
Subject:
evan wise <wiseinaz@gmail.com>
Monday, May 8, 2023 4:05 PM
City Clerk
"City Council May 9th Mtg -Item 10
All Receive -Agenda Item# / 0
For the Information of the:
~)_T)'_C.OUNCIL
Dat~A v cc v
CM v ACM __r:: DCM (3) i/
Item 10 ELECTRIFICATION OF NEW BUIL_DINGS IN CARLSBAD is a very important issue. Any hope of mitigating climate
change which will bring sea level rise as well as drought, fires and severe weather challenges to Carlsbad starts at the
local level. Success requires three efforts to be implemented simultaneously: 1. Electrification of buildings 2. Conversion
to clean energy from fossil fuels and 3. Transmission upgrades to bring the clean power to the population dense
localities where it will be needed. I hope you will do your part on behalf of Carlsbad, California, the U.S. and the
world. It would be great to hand our grandkids the pleasant climate we have enjoyed.
Evan Wise
WISEWONDERS.NET MY BLOG
wiseinaz@gmail.com
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1
Tammy Cloud-McMinn
From:
Sent:
To:
Subject:
Hello,
All Receive -Agenda Item g/0
For the Information of the:
Serena Pelka <serena@climateactioncampaign.org> c;irr COUNCIL ·
Tuesday, May 9, 2023 1 :30 PM Date5/9/;;:?r.A vec ~
City Clerk CM ir' ACM ✓ DCM (3) ..!:::::
Item 10 -ELECTRIFICATION OF NEW BUILDINGS IN CARLSBAD
My name is Serena Pelka, Policy Advocate at Climate Action Campaign, a non-profit organization based in Southern
California with a simple mission: create a zero carbon future through effective and equitable policy action. In order
to improve quality of life for every community in Carlsbad, building electrification must be prioritized.
Building all-electric brings significant benefits to our communities and climate. Approximately 20% of the region's carbon
emissions come from burning methane gas. When we electrify, we're moving closer to our emissions reduction goals
and protecting the climate. Electrification also saves money -for both developers and residents. With the current State
Building Code requiring homes to be electric-ready, allowing gas infrastructure in new buildings adds a significant,
unnecessary expense. Building all-electric is less expensive and modern electric appliances are incredibly efficient. For
residents, this translates to lower utility bills and can improve access to air conditioning during Carlsbad's hottest
months.
Continuing to use gas in our homes and buildings is also a public health issue. Indoor air quality isn't regulated and
burning gas in our buildings releases toxic pollution into the places we live, work, learn and play. Research shows that a
child living in a home with gas cooking faces a comparable risk of asthma to a child living with household cigarette
smoke and existing inequities caused by environmental racism are exacerbated by the use of gas. This is an equity issue.
We urge the City of Carlsbad to move forward with the adoption of an all-electric ordinance for new construction. Over
75 jurisdictions in California have already adopted ordinances, including neighboring cities such as Encinitas and Solana
Beach. This means abundant resources, templates and best practices are available for the City to utilize. Expanding fossil
fuel infrastructure will lead to stranded gas piping and appliances in the future and is a missed opportunity to take
climate action and protect public health. Please ensure building electrification is prioritized and adopt an all-electric
ordinance for new construction as soon as possible. Thank you!
Sincerely,
Serena Pelka (she/her)
Policy Advocate
Climate Action Campaign
(619) 419-1222 Ext. #715
O~@l~
Like what we do? Support Climate Action Campaign today.
Our mission: to create a zero carbon future through effective and equitable policy action
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1
Tammy Cloud-McMinn
From:
Sent:
To:
Subject:
Attachments:
Rosette Garcia <president@lwvncsd.org>
Tuesday, May 9, 2023 1 :54 PM
City Clerk
Fwd: Item 10, Electrification of New Buildings Ordinance--Support
Carlsbad_Electrification_Endorsement_May2023.pdf
----------Forwarded message---------
From: Rosette Garcia <president@lwvncsd.org>
Date: Tue, May 9, 2023 at 1:48 PM
Subject: Item 10, Electrification of New Buildings Ordinance--Support
To: <keith.blackburn@carlsbadca.gov>, <priya.bhat-patel@carlsbadca.gov>, <melanie.burkholder@carlsbadca.gov>,
<teresa .acosta@carlsbadca.gov>, <ca rolyn.luna@ca rlsbadca .gov>
Cc: <cityclerk@carlsbadca.gov>
LEAGUE OF WOMEN VOTERS~
OF NORTH COUNTY SAN DIEGO
Mayor Blackburn and City Council Members Bhat-Patel, Burkholder, Acosta, and Luna
1 200 Carlsbad Village Drive
Carlsbad, CA. 92008
RE: Item 1 0, Electrification of New Buildings Ordinance--Support
Dear Mayor and City Council Members,
On behalf of the League of Women Voters of North County San Diego, I am writing to urge you to adopt the proposed
ordinance for the City of Carlsbad to require electrification of new buildings with no exceptions.
The League of Women Voters is a non-profit grassroots organization that educates and advocates on policy issues of
concern to our community. Our study of the issues of climate change, renewable energy and sustainability has led us to
endorse policies and action that limit statewide greenhouse gas (GHG) emissions by 2045 or sooner, in alignment with
goals set by the state legislature. We believe eliminating natural gas from buildings is critical not only to reaching these
goals but also to protecting people's health: currently it is estimated that buildings make up approximately 30% of GHG
emissions and that, in California, upwards of 20% of childhood asthma can be attributed to toxic emissions, mostly
methane, from gas cooking stoves.
Transitioning away from mixed-fuel (gas and electric) buildings to all electric buildings will
• provide benefits to the climate and people's health by reducing methane leaks and exposure to this toxic pollutant;
• lead to savings in building costs because all-electric buildings are cheaper to construct.
We urge the city of Carlsbad to continue leading the way in a green energy future by taking the necessary steps to
decarbonize future buildings. Thank you for your consideration.
Respectfully submitted,
1
Rosette Garcia
President
League of Women Voters of North County San Diego
P.O. Box 131272 I Carlsbad CA 92013 I 760-736-1340
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2
LEAGUE OF WOMEN VOTERS
F NORTH C UNTY A DI GO
May 8, 2023
Mayor Blackburn and City Council Members Bhat-Patel, Burkholder, Acosta, and Luna
1200 Carlsbad Village Drive
Carlsbad, CA. 92008
RE: Item 10, Electrification of New Buildings Ordinance--Support
Dear Mayor and City Council Members,
The League of Women Voters is a nonpartisan grassroots organization working to encourage informed
and active public participation in government at all levels. We educate and advocate on public policy
issues of importance to our community. On behalf of the League of Women Voters of North County
San Diego, I am writing in support of the proposed ordinance for the City of Carlsbad to require
electrification of new buildings with no exceptions.
The League of Women Voters endorses policies and action that advance California's ambitious goals
to limit statewide greenhouse gas (GHG) emissions by 2045 or sooner. Eliminating natural gas from
buildings is critical to reducing GHG emissions and to protecting people's health: currently it is
estimated that buildings make up approximately 30% of GHG emissions and that, in California,
upwards of 20% of childhood asthma can be attributed to toxic emissions, mostly methane, from gas
cooking stoves.
Transitioning away from mixed-fuel (gas and electric) buildings to all electric buildings will
• provide benefits to the climate and people's health by reducing methane leaks and exposure
to this toxic pollutant;
• lead to savings in building costs because all-electric buildings are cheaper to construct.
We urge the city of Carlsbad to continue leading the way in a green energy future by taking the
necessary steps to decarbonize future buildings.
Sincerely,
Rosette Garcia
President
P. 0. Box 131272 I Carlsbad, CA 92013-1272 I 760-736-1608 I www.lwvncsd.org
The League of Women Voters North County San Diego is a 501 (c) (3) non-profit organization.
Tammy Cloud-McMinn
From:
Sent:
Vanessa Forsythe <vforsythe13@gmail.com>
Tuesday, May 9, 2023 1 :58 PM
To: City Clerk
Subject: City Council Comment May 9th -Item 10
Dear Mayor Blackburn and City Council Members
I ask that you direct staff and pass a resolution to require all new construction (residential, multi-family, and
commercial) to electrify buildings.There is the expectation that state building codes will soon require this (by 2025).
Buildings make up approximately 30% of the green house gasses in CA. In CA all power is to be generated from
renewables by 2045 so removing natural gas (predominantly methane) form buildings means "cleaner" buildings as the
grid is powered by more renewable energy,
Carlsbad was the first in the state (2019) to have a REACH (stretch building code) for water heaters; we need to do the
same for the entire home and our community businesses (heat pumps and electric appliances, induction stoves).
Please take this under deliberation as we need to respond to climate change in our community and make the city of
Carlsbad more sustainable.
Thank you
Vanessa
2177 Vista La Nisa, Carlsbad, CA 92009
Vanessa Forsythe RN MSN
Pronouns: She/Her
CleanEarth4Kids
California Nurses for Environmental Health and Justice
"/s there no virtue among us? If there be not, we are in a wretched situation. No theoretical checks -no form of
government can render us secure." James Madison
CAUTION: Do not open attachments or click on links unless you recognize the sender and know the content i
safe.
1
Tammy Cloud-McMinn
From:
Subject:
Attachments:
City Clerk
FW: BIA San Diego Letter -Item #1 0: Electrification of New Buildings in Carlsbad
Carlsbad electrification 5.9.23.pdf
From: Adrian Luna <Adrian@biasandiego.org>
Sent: Tuesday, May 9, 2023 1:59 PM
To: Scott Chadwick <Scott.Chadwick@carlsbadca.gov>; Manager Internet Email <Manager@CarlsbadCA.gov>
Cc: Kelly Batten <Kelly@biasandiego.org>
Subject: BIA San Diego Letter -Item #10: Electrification of New Buildings in Carlsbad
Good Afternoon Mr.Chadwick,
Please see the attached letter ahead of today's Carlsbad city council meeting regarding item #10: Electrification of New
Buildings in Carlsbad.
Thank you,
1
BUILDING INDUSTRY ASSOCIATION
-~--OF SAHOlfGOCOaHTV
AFFILIATES
California Building
Industry Association
National Association
of Home Builders
May 9, 2023
Mayor Keith Blackburn
City of Oceanside
300 North Coast Hwy
Oceanside, CA 92054
Sent via email
Subject: Item 10 Electrification of New Buildings in Carlsbad
Dear Honorable Mayor and City Council Members,
The Building Industry Association of San Diego County (BIA) respectfully requests the
City vote No on Item 10, Electrification of New Buildings in Carlsbad. Regulations that
govern land use fundamentally shape what is built and for whom, contributing to the
region's affordability crisis as well as to ongoing patterns of residential segregation.
Additionally, a recent court decision in the 9th Court of Appeals appears to prohibit the
City from moving forward with Item 10, Electrification of New Buildings in Carlsbad.
We urge you to carefully consider current case law when evaluating this item.
Regulatory requirements of all kinds drive up the cost of development and San Diegans
are already struggling to afford homes in our region. The study prepared by the Energy
Policy Initiatives Center (EPIC) regarding the electrification of homes in Carlsbad
determined that in most cases it will cost more to build homes and this will affect
utility costs to residents. As a real-life example, green building standards-meant to
decrease energy use and conserve water-in Los Angeles have increased construction
costs by nearly 11 percent. Research by California 100 shows that a one standard
deviation increase in an index of the strength of land use regulations is associated with
10 percent less permitting overall and 17 percent less multifamily permitting. Land use
regulations at the local level that go beyond State law lead to longer development
timelines, a larger mismatch between housing and jobs, and greater racial inequality.
Excessive land use regulations, such as this current proposal, directly contribute to our
region's high cost of living and this is the primary reason the BIA is in opposition to the
City's proposal. San Diego is in the midst of a housing crisis and an affordability crisis.
The City of Carlsbad should be looking for ways to reduce building costs, not
considering proposals that will increase costs to both builders and residents. The BIA
supports the construction of new homes for all residents in our region and adopting
this ordinance will result in less homes being built. Thank you for your consideration
in our comments.
Respectfully,
Lori Holt-Pfeiler
CEO
Building Industry Association of San Diego
CC: Mayor Pro Tern Priya Bhat-Patel., Councilmember Melanie Burkholder
Councilmember Carolyn Luna, Councilmember Teresa Acosta, Scott Chadwick,
City Manager
BUILDING INDUSTRY ASSOCIATION OF SAN DIECO COUNTY
9201 Spectrum Center Blvd., Suite 170, San Diego, CA 92723-7407
P: (858) 450-7227 / www.biasandiego.org
BOARD OF EDUCATION
DISTRIBUTED DURING PUBLIC
COMMENT AT COUNCIL
MEETING OF99/:J...s 1."1Thco#-/D
SAN DIEGO UNIFIED SCHOOL DISTRICT
IN THE MATTER OF ELECTRIFYING )
THE SAN DIEGO UNIFIED SCHOOL ) RESOLUTION
=-D=IS=T=RI=C~T __________ )
WHEREAS, climate change, which is predominantly driven by burning fossil fuels, has resulted
in unprecedented natural disasters, devastating storms, historic droughts, wildfires, and extreme
heat which may affect San Diego Unified students' physical and mental health; and
WHEREAS, 97 percent of climate scientists and organizations including the US National
Aeronautics and Space Administration, American Association for the Advancement of Science,
National Academy of Sciences, and the Intergovernmental Panel on Climate Change affirm that
anthropogenic climate change is causing dire damage to the planet; and
WHEREAS, San Diego Unified's students and staff are entitled to safe and healthy working and
learning environments that reflect recommendations of reliable scientific studies indicating that
student achievement and attendance and teacher and staff retention are improved when their
environment incorporates natural light, improved indoor air quality and acoustics, and is free of
toxins, thermally comfortable, and well maintained; and
WHEREAS, in 2013, the San Diego Unified Board of Education acknowledged the threat
climate change poses to youth health and adopted a Resolution in Support of a Parent Teacher
Association initiative to tackle climate change and established the Environmental Sustainability
Advisory Committee; and
WHEREAS, San Diego Unified's "Dream Big Solutions for a Sustainable Future" includes a
Climate Action Plan that commits to 100 percent renewable energy by 2035; and
WHEREAS, in 2015, San Diego School Unified created a plan to transition to 100 percent
renewable energy by 2035 in order to mitigate the effects of climate change; and
WHEREAS, San Diego Unified is taking steps toward meeting its goals by retrofitting schools
with more efficient air conditioning and lighting systems; and more than 36,181 lighting fixtures
have been converted to LED, offsetting 1,618 tons of CO2 gas emissions; and installed solar
systems at schools that produce 35 million kWh per year of clean energy and offset 10,000 tons
of CO2; and
WHEREAS, San Diego Unified is a customer of San Diego Community Power, which provides,
a clear path to 100 percent clean energy through the Power 100 service level option; and
WHEREAS, in 2020, San Diego Unified was recognized for its excellence in resource
efficiency, health and wellness, and environmental and sustainability education by the California
DepartmentofEducation;and
WHEREAS, San Diego Unified has previously committed to recognize climate change and
climate justice issues, along with working to create an urgent, just transition away from fossil
fuels; and
WHEREAS, the San Diego Unified School District Board of Education intends for this
resolution to create a long-term, inspiring vision that integrates and strengthens many efforts in
the district, and further recognizes that fully implementing this resolution will take time and
must be achieved in stages.
NOW, THEREFORE, BE IT RESOLVED, that as the San Diego Unified School District
Board of Education seeks to expand upon existing efforts and to create healthier, more
sustainable schools, it hereby establishes the following goals:
• Phase out the use of fossil fuels by electrifying all district infrastructure, including
buildings, bus fleets, maintenance vehicles, as practicable, prioritizing investments at
schools in Communities of Concern. The district will work with community partners and
take a leading role in actively pursuing funding for this transition in order to electrify
systems at a faster rate.
• All future new buildings will be powered by 100 percent electric energy.
• Existing mechanical heating systems, natural gas powered water heaters and gas
stoves and other natural gas powered ·equipment will be replaced at the end of their
useful life with all electric systems.
• Starting in 2024, whole campus modernization projects will include new electric
vehicle charging systems.
• Achieve net-zero energy districtwide by 2035; Improve energy efficiency and
design and construct solar/ photovoltaic energy systems to produce clean renewable
energy.
• Transition to 100 percent clean energy by December 31, 2024 through San Diego
Community Power's Power 100 program.
• Develop a Green Jobs curriculum for students to learn about and prepare for future
career pathways in the electrification and clean energy fields.
• Work with both internal and external labor partners to ensure that electrification
work will be done by union workers with access to living wages, full health and
retirement benefits, and representation ensuring respect and dignity on the job.
Adopted and approved by the Board of Education of the San Diego Unified School District at a
regular meeting held on the 25th day of April 2023.
President
Member
Member
Student Board Member
LEGALITY AND FORM APPROVED
ANDRA M. GREENE, General Counsel
San Diego Unified School District
Vice President
Member
Student Board Member
Approved in public meeting of the Board of Education
of the San Diego Unified School District on
Marty Stultz, Board Action Officer, Board of Education
TODAY’S PRESENTATION
•Background
•Report outline
•Key findings
•Recent case law
•Options
•Recommended action
ITEM 14. ELECTRIFICATION OF NEW BUILDINGS
{ City of
Carlsbad
BACKGROUND
•Minute motion at April 19, 2022 Council meeting during informational item on electrification of new buildings
•“Research options to add an ordinance addressing electrification in new buildings in the City of Carlsbad to the next Climate Action Plan draft in 2023”
•Existing Professional Services Agreement with EPIC
•Report to include info requested during public comment
and by City Council
ITEM 14. ELECTRIFICATION OF NEW BUILDINGS
{ City of
Carlsbad
REPORT OUTLINE
•Options related to new building electrification ordinances
•What other jurisdictions are doing
•Issues related to workers, just transition and equity
•Possible costs to customers
•Grid infrastructure and reliability
•Cost-effectiveness studies
•Estimate of units impacted
•Estimate of GHGs reduced
ITEM 14. ELECTRIFICATION OF NEW BUILDINGS
{city of
Carlsbad
PATHWAYS TO ALL-ELECTRIC NEW CONSTRUCTION
1.Pathway 1: Natural Gas Moratorium
2.Pathway 2: Electric-Only to Code Minimum
3.Pathway 3: Electric-Only with Added Efficiency Plus PV,
and/or Battery (Reach Code)
ITEM 14. ELECTRIFICATION OF NEW BUILDINGS
{ City of
Carlsbad
PATHWAY 1: NATURAL GAS MORATORIUM
Consideration Key Finding
Mechanism •Prevents issuing of permit for and installation of new natural gas
plumbing
Timeframe
and Requirements
•About 6-12 months to develop and adopt
•Requires City Council approval
•Effective once filed with the Building Standards Commission
•No Cost-effectiveness Study Required
GHG Reductions •Greater GHG emission reductions than baseline with mixed-fuel
building
Costs •Lower upfront costs to build for single-family; Higher for multi-family
•Higher electricity consumption costs over life of building
PATHWAY 2: ALL-ELECTRIC TO MINIMUM CODE
Consideration Key Finding
Mechanism •Adopt all-electric definition using Health and Safety authority or
CalGreen
Timeframe
and Requirements
•About 6-12 months to develop and adopt
•Requires City Council approval
•Effective once filed with the Building Standards Commission
•No Cost-effectiveness Study Required
GHG Reductions •Greater GHG emission reductions than baseline with mixed-fuel
building
Costs •Lower upfront costs to build for single-family; higher for multi-family
•Higher electricity utility costs over life of building
PATHWAY 3: ALL-ELECTRIC REACH CODE
Consideration Key Finding
Mechanism •Adopted using granted authority to amend Building Code (Reach
Code)
Timeframe
and Requirements
•About 6-12 months to develop and City Council to adopt
•2-6 months for California Energy Commission approval
•Effective once filed with the Building Standards Commission Cost-
effectiveness Study Required but may be able to use existing
Statewide Cost-effectiveness Studies
GHG Reductions •Results in greatest GHG emission reductions
Costs •Lower upfront costs to build for single-family; higher costs for multi-
family and nonresidential buildings
•Higher electricity costs except for nonresidential buildings
OTHER CONSIDERATIONS
•Grid Reliability
–Electrification of new construction is not expected to pose a reliability issues
–Due to small number of buildings and relatively small incremental energy use increases
–Further analysis may be required
•Workforce
–Electrification expected to increase related workforce
–Not expected to displace current workforce for fossil related workforce out to 2030
–From 2030-2050, it could be necessary to transition workforce electrification grows
•Equity
–Higher upfront housing costs and ongoing utility costs could pose equity issues
–Further study may be needed to understand the implications of a specific policy
ITEM 14. ELECTRIFICATION OF NEW BUILDINGS
{ City of
Carlsbad
CITY OF BERKELEY NATURAL GAS BAN CASE
•All pathways are preempted by federal law for covered products
–Energy Policy Conservation Act (EPCA)
•CRA v. City of Berkeley (4/17/23 Ninth Circuit)
–Natural gas plumbing ban is preempted for covered products because it indirectly prohibits the use of natural gas
–Cannot prohibit natural gas energy use or set efficiency standard directly or indirectly for covered products through building code unless:
•California applies and receives a waiver of preemption (generally appliance specific); or
•Meet requirements that avoid preemption for new construction state and local building code (California Building Code and Reach Code)
•Can still regulate non-covered products
ITEM 14. ELECTRIFICATION OF NEW BUILDINGS
{ City of
Carlsbad
CITY OF BERKELEY NATURAL GAS
BAN CASE
•Case is currently remanded to District Court
to implement opinion and reinstate state-
law claims
•City of Berkeley has until May 31, 2023 to
file for rehearing
•If granted
•Original three judge panel opinion is rescinded
•Case goes before larger panel at 9th Circuit
•If not granted
•Current ruling stands {city of
Carlsbad
ALTERNATIVE PATHWAY TO COMPLY WITH 9TH
CIRCUIT OPINION
•Viable pathway using reach code
•Sets higher building efficiency and energy use ratios or budgets
•Does not require all-electric new construction
–Can prefer all-electric construction without mandating the type of energy use
•Must comply with the exception for new construction under the EPCA
–42 U.S.C. §§6297(c)(3) & (f)(3) for consumer appliances
–42 U.S.C. §6316(b)(2)(B) for commercial appliances
ITEM 14. ELECTRIFICATION OF NEW BUILDINGS
{ City of
Carlsbad
OPTIONS
1.Continue implementing the City Council’s April 19,
2022 motion
2.Take no further action
3.Wait for updates to the California Restaurant
Association v. City of Berkeley case
4.Proceed with other direction provided by the City
Council
ITEM 14. ELECTRIFICATION OF NEW BUILDINGS
{city of
Carlsbad
RECOMMENDED ACTION
Receive an update, review options and
provide direction to staff on how to proceed
related to electrification in new buildings in
the next Climate Action Plan draft in 2023.
ITEM 14. ELECTRIFICATION OF NEW BUILDINGS
{city of
Carlsbad