AIAEB Board Chair Ashley Rybarczyk Speaks in Support for All-Electric Reach Code Adoption in Alameda

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In September 2019, the City Council adopted Alameda’s Climate Action and Resiliency Plan (CARP), which included an action directing staff to prepare ordinances requiring all new residential construction to be 100% electric-powered with no gas hookups.

In October 2019, the City Council took a first and significant step in this direction by adopting a resolution limiting natural gas infrastructure for new residential construction on City-owned property. This proposed amendment to the Alameda Municipal Code (AMC) currently is a targeted “Reach Code,” i.e., a local building energy code that “reaches” beyond the state minimum requirements for energy use in building design and construction. It would extend the all-electric requirement adopted for city-owned property to new construction in Alameda, including development other than residential, thereby fulfilling a key policy recommendation found in the CARP.

Specifically, staff is recommending that the Planning Board consider a resolution recommending that the City Council adopt the all-electric reach code to require all new construction citywide to be all-electric with no natural gas or propane infrastructure installed and electric appliances for space heating, water heating, clothes-drying, and cooking, with certain exceptions.

With Alameda Municipal Power (AMP) now providing 100% clean electricity, Alameda’s greenhouse gas (GHG) emissions from buildings comes primarily from natural gas consumption. Natural gas use in buildings accounts for 27% of Alameda’s total GHG emissions linked to climate change. The only source sector with more local GHG emissions is the transportation sector (70%).

Requiring new development to be all-electric is the first step towards reducing our building emissions. It will also improve indoor air quality and health by eliminating natural gas combustion inside homes. Gas appliances and pipes have been responsible for igniting fires after earthquakes and natural gas use in homes is responsible for almost half of residential house fires. All-electric homes and businesses can also reduce construction costs and save residents and business owners money over the lifetime of the building.

Staff is recommending that the Planning Board consider a resolution recommending that the City Council adopt a resolution containing findings of local climatic, geological, and topographical conditions as required by applicable law, introduce on first reading the attached Ordinance, and direct staff to file the resolution and ordinance with the California Energy Commission.

Funded by the California investor-owned utilities (IOUs), the California Statewide Codes and Standards Program (Statewide Program) led the development of a cost-effectiveness study for Energy Code reach codes that examined different performance-based approaches for new construction of specific building types. There are two kinds of reach code approaches: performance-based ordinances and prescriptive ordinances. Performance-based ordinances mandate an increase in the overall energy efficiency required but leave flexibility for the builder on how to achieve this goal. In contrast, prescriptive ordinances mandate implementation of a specific measure (such as solar panels or cool roofs). The Statewide Program’s analysis focused on performance-based ordinances but some conclusions about prescriptive measures can be made from the results.

Background

The City of Alameda (City) is a leader in climate action and sustainability. In March 2019, the City Council declared a climate emergency and joined a global effort to get to net zero emissions as soon as possible. In September 2019, the City Council adopted an updated and revised CARP with the goal of lowering citywide GHG emissions 50% below 2005 levels by 2030 and achieving the vision of net zero emissions as soon as possible. The CARP identifies the need to reduce greenhouse gas emissions from the use of natural gas in new and existing buildings in the community. 

In November 2019, the City Council adopted a resolution limiting natural gas infrastructure for new residential construction on city owned property. Given that the vacant lands owned by the City at Alameda Point represent a major portion of lands available in Alameda for new construction, the 2019 Council resolution represented a significant step forward in addressing this issue. The proposed reach code would expand and strengthen the Council’s 2019 resolution, by requiring all-electric new construction in all new buildings (both residential and commercial) to all public and private property in Alameda. To avoid confusion and potential conflicting interpretations, staff is recommending that the Council rescind its 2019 resolution upon approval of the citywide reach code.

To advance Alameda’s GHG reduction goals, staff has also worked with developers in recent years to reduce the use of gas infrastructure in new construction beyond Alameda Point. The 52-unit Mulberry residential townhome project on Clement Avenue, the 21-unit Housing Authority townhome project on Eagle Avenue, the 357-unit townhome and stacked-flats project under construction at Alameda Landing Waterfront, and the proposed re-entitlement of the 589 units at Encinal Terminals are all designed or proposed as all-electric new construction.

To further advance Alameda’s climate goals, staff recommends modifying the Alameda Energy Code to require residential and non-residential new construction to be all-electric, with certain exceptions. This report provides an overview of the statewide cost-effectiveness study, details findings, and provides language recommended for the associated reach code for the 2019 building cycle.

Reach Code Adoption Process

Every three years, the State of California adopts new building standards that are organized in Title 24 of the California Code of Regulations, referred to as the California Building Standards Code. This regular update is referred to as a “code cycle.” The previous code cycle was adopted in 2016 and became effective on January 1, 2017. The current code cycle was adopted in 2019 and became effective on January 1, 2020. Cities and counties can adopt reach codes that require items that are above the minimum state code requirements and file them with the State. Reach codes must be updated with every code cycle.

In addition, the California Energy Commission (CEC) requires that a cost-effectiveness study be conducted and filed in the case of local amendments to the Energy Code (Title 24, Part 6). It is required that the City demonstrate to the CEC, using a cost-effectiveness study, that the amendments to the code are financially responsible and do not represent an unreasonable burden to the non-residential and residential applicants. A cost-effectiveness study is not required for amendments to the Green Building Code (Title 24, Part 11).

Statewide Cost-Effectiveness Study for Energy Code Reach Codes

Funded by the California investor-owned utilities (IOUs), the California Statewide Codes and Standards Program (Statewide Program) led the development of a cost-effectiveness study for Energy Code reach codes that examined different performance-based approaches for new construction of specific building types. There are two kinds of reach code approaches: performance-based ordinances and prescriptive ordinances. Performance-based ordinances mandate an increase in the overall energy efficiency required but leave flexibility for the builder on how to achieve this goal. In contrast, prescriptive ordinances mandate implementation of a specific measure (such as solar panels or cool roofs). The Statewide Program’s analysis focused on performance-based ordinances but some conclusions about prescriptive measures can be made from the results.

Building Prototypes

The Statewide Program’s analysis estimated cost-effectiveness of several building prototypes including one-story and two-story single-family homes, a two-story and five-story multifamily building, a three-story office building, a one-story retail building, and a four-story hotel. The single-family homes, multifamily homes, and office building prototypes are directly applicable to Alameda development. The City has averaged about 200 units of new multi-family units and townhomes constructed each year over the past five years. Additionally, recently approved development projects include manufacturing, light industrial and office buildings, and retail.

Community Input

Staff conducted significant outreach during the development of this ordinance, including presentations at Alameda Youth Collaborative (March 25th), CASA (April 1st), and Alameda Chamber of Commerce Government Relations Economic Development Committee (April 7th) meetings. Staff also presented at the League of Women Voters/CASA workshop on Electrifying Alameda’s Homes on April 8th and held two online info sessions on April 12th and 13th for builders and developers.

Discussion

As of March 2021, more than 40 cities and counties across California, including San Francisco, Oakland, San Jose, Berkeley, Richmond, Hayward and others, have adopted ordinances to limit or eliminate the use of natural gas in new buildings, a significant contributor to GHG emissions.

Building on similar ordinances recently passed by neighboring jurisdictions, staff drafted an “all-electric” reach code ordinance for Council’s consideration. The reach code would be applied at permit application for all new buildings seeking construction permits after the ordinance is adopted by Council and approved by the California Energy Commission.

Staff have worked closely with TRC Advanced Energy to interpret the study’s results, noted above, and infer what options may or may not be cost-effective for the building types that are prevalent in Alameda but were not analyzed by the team. TRC also provided consultant support to understand the cost-effectiveness study results and adopting reach codes. The proposed reach codes meet the requirements of the CEC for cost-effectiveness and are cost-effective over the lifetime of the building systems for new construction buildings within city limits, including upfront and operational costs and savings. Notably, the results of the analysis show that all-electric buildings are typically less expensive to construct.

Recommended reach code requirements for newly constructed buildings are:

  • All-Electric Required: Require all newly constructed residential and non-residential buildings to be built all-electric, meaning that the buildings will have no natural gas or propane plumbing installed, and that electricity will be the sole source of energy for all space heating, water heating, cooking appliances, and clothes drying appliances, with some exceptions.
  • Install Solar Photovoltaic (PV): Require solar photovoltaic systems on new high-rise residential and non-residential buildings covering 15 percent of the roof area, with exceptions allowed for shading or over generation.

The recommended exceptions to the all-electric requirements are:

  1. Commercial kitchen cooking appliances for a restaurant open to the public or an employee cafeteria in a newly constructed building.
  2. Non-electric space heating and process systems in newly constructed buildings containing occupancies F, H, or L (e.g. manufacturing, laboratories, or other specialty R&D). To take advantage of this exception applicant shall provide third party verification approved by the City that All-Electric process system requirement is not cost effective or feasible.
  3. Accessory Dwelling Units constructed on a parcel with an existing residential building with gas infrastructure. 
  4. Newly constructed buildings with a valid planning entitlement or Development Agreement approved prior to the effective date of the Ordinance.
  5. If there is not an all-electric prescriptive pathway for a building under the state Energy Code, and the building is unable to achieve the Energy Code’s performance compliance pathway using commercially available technology and an approved calculation method, then the building official has the authority to grant a modification.

Buildings invoking these exceptions must provide additional and supplemental electric infrastructure for future electrification.

Cost Effectiveness/Energy Consumption and Local Amendments Findings

An energy reach code can only be adopted if the jurisdiction adopting it determines that the proposed requirements are cost effective. Alameda’s proposed all-electric reach code has been found to be cost-effective, as discussed below. Additionally, the all-electric reach code would require the diminution of energy consumption levels permitted by the state Energy Code as required by California Health & Safety Code section 25402.1(h)(2).

Cost-effectiveness is measured considering lifecycle costs using a 15-year timeframe for nonresidential buildings and a 30-year timeframe for residential buildings. Generally, electric appliances are not more expensive than natural gas appliances. When considering the avoided cost of installing gas infrastructure (piping), in all modeled cases in Alameda’s climate zone, all-electric construction is cost-effective. In these cost effectiveness studies, air-conditioning is assumed to be in the baseline, which staff has indicated to be a reasonable assumption given recent development proposed in the City. The CEC requires that the cost-effectiveness analysis incorporate the time-dependent valuation (TDV) of energy so that the costs for the construction and operation of the building can be accurately calculated.

Alameda’s finding that its proposed all-electric reach code is cost-effective is based on the statewide cost-effectiveness studies, which are available for review at the following websites:

Additionally, the proposed reach code provides local amendments to Title 24 Part 6, the California Energy Code (CEC).

Staff is therefore recommending that the Planning Board consider these cost effectiveness studies as a basis for finding the proposed reach code is cost effective, in addition to making the findings necessary, as required by applicable law, to support the local amendments.

Financial Impact

Adoption of the proposed reach codes is not anticipated to result in additional costs to the City. Alameda building officials are already transitioning to enforcement of the new California Building Standards as adopted by the City with local amendments and modifications, which occurs on a three-year cycle. Implementation material templates, including project checklists and training resources have been developed by the Bay Area Regional Energy Network. Thus, the introduction of an all-electric building requirement does not represent a significant increase in staff time to review any new permit applications. One advantage of the all-electric ordinance may be to reduce the number of items that need to be inspected in the field (for example, air vents and shutoff safety elements for gas appliances), which could reduce plan check and inspection time.

Municipal Code/Policy Document Cross Reference

Amending the AMC to adopt the all-electric reach code supports General Plan policies to protect the health and safety of the community, improve energy efficiency and meet local Climate Action and Resiliency Plan goals for greenhouse gas reductions.

Environmental Review

This action is exempt from CEQA pursuant to CEQA Guidelines section 15061(b)(3) in that the standards set forth in the ordinance are more protective of the environment than the California Energy Code standards, and there is no possibility that the activity in question may have a significant effect on the environment.  As a separate and independent basis, this action is exempt from CEQA pursuant to CEQA Guidelines section 15308 in that the standards set forth in the ordinance assure the maintenance, restoration, enhancement or protection of natural resources and the environment. In addition, CEQA Guidelines section 15183 (Projects Consistent with a Community Plan, General Plan, or Zoning) applies to the project in that the standards set forth in the Ordinance are consistent with the General Plan and the Climate Action and Resiliency Plan.

Climate Impacts

The all-electric reach code will help implement the City’s Climate Action and Resiliency Plan and its goal of reducing greenhouse gas emissions 50% below 2005 levels by 2030.

Natural gas and the infrastructure needed to transport it to City homes and businesses is a leading source of GHG emissions in the City, and responsible for 27% of the total GHGs released in the City.  The reduce these emissions, the CARP recommends requiring new development to be all-electric and to replace gas appliances and furnaces with electric ones in existing homes.

Recommendation

  1. Approve Draft Resolution Recommending  Council adopt a Resolution Containing Findings of Local Climatic, Geological, Topographical, and Environmental Conditions as Required to Adopt Alameda Local Amendments to the 2019 California Energy Code; (Exhibit 1)
  2. Approve Draft Resolution Recommending  that Council introduce an Ordinance Amending the Alameda Municipal Code by Amending 13-11 (Alameda Energy Code) of Chapter XIII, Article I (Uniform Codes Relating to Building, Housing and Technical Codes) to Make Local Amendments to the 2019 California Energy Code; (Exhibit 2) and
  3. Recommend by Motion that the Council rescind Resolution 15607 Limiting Natural Gas Infrastructure for New Residential Construction on City Owned Property

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