City of Cotati
Sonoma County, California
________________________________________________________________ 201 W. Sierra Ave, Cotati, CA 94931 | (707) 792-4600 | www.cotaticity.gov | @cityofcotati April xx, 2025
The Honorable Nick Schultz, Assemblymember
State Capitol
P.O. Box 942849
Sacramento, CA 94249
RE: Assembly Bill 306 (Schultz): Building Codes – OPPOSE Dear Assemblymember Schultz,
On behalf of the City of Cotati, we write to inform you that we must respectfully oppose Assembly Bill 306. Local governments share the goals of increasing housing supply and lowering costs, and stand at the frontlines of the climate crisis -- grappling directly with the impacts of wildfires, extreme heat, drought, sea level rise, and coastal erosion. However, a moratorium on new state and local building codes for both new and existing housing would not enhance affordability, but would take away a key tool for local governments to streamline processes, ensure public safety, address energy security and affordability, and to achieve their climate commitments.
Far from increasing building costs, state and local reach codes that incentivize all-electric adoption and energy efficient appliances have helped reduce construction costs1 by as much as $10,0002 per home, and saved over $100 billion in avoided energy costs over the last 50 years. AB 306 will block continued progress and the incorporation of emerging efficient technologies into new and existing buildings.
Equally important, maintaining alignment with model building codes is critical to hazard mitigation: The Federal Emergency Management Agency (FEMA) projects that adhere to current and upcoming codes will avoid more than $600 billion in cumulative losses from floods, hurricanes, and earthquakes by 2060.3
As drafted, AB 306 would also prevent improvements to the code by state and local jurisdictions – including the ability of the Building Standards Commission and local governments to adopt and accept online forms, streamline codes & compliance systems, and adapt existing code to accommodate costsaving technology advancements. Pausing new building code updates would prevent the incorporation of pending revisions to the National Electrical Code that would help homeowners avoid unnecessary electrical panel upgrades; these provisions would reduce cost and delays for homeowners. Electric service upsizing and panel replacement costs range from $3000 to $30,000 per household, and unnecessary utility service upsizing contributes to escalating electricity rates. 1 "FAQ - Electrification" CEC, 2022
2 "Residential Building Electrification in California" E3, 2019 3 FEMA, Building Codes Save: A Nationwide Study, 2020
City of Cotati
Sonoma County, California
________________________________________________________________ 201 W. Sierra Ave, Cotati, CA 94931 | (707) 792-4600 | www.cotaticity.gov | @cityofcotati While the stated objective of AB 306 is to increase the supply of housing, this bill freezes updates to building codes for alterations of existing housing. These provisions are critical intervention points for local governments to increase efficiency in existing homes to reduce energy bills and improve climate resilience. Research shows that the costs of land, labor, material price hikes from the pandemic, and entitlement processes are largely responsible for California’s high housing costs.4 Local reach codes are one of our most essential tools for serving regional climate and housing needs. The State requires local Climate Action Plans - and ambitious local plans have been proving grounds to pilot concepts that have been subsequently adopted as part of state code. AB 306 would stall these time sensitive efforts to address the climate and biodiversity crises with the urgency that they demand and deserve.
Curtailing the state’s ability to update codes in general, and eliminating local codes advancing safety, permit streamlining, and sustainability, will not effectively address the intended outcomes of this bill.
For these reasons, we must respectfully oppose AB 306.
Sincerely,
x___________________________
Ben Ford
Mayor
City of Cotati
cc: Speaker of the Assembly Robert Rivas
Senate Pro Tempore Mike McGuire
Assemblymember Damon Connolly, State Senate District 3
Senator Christopher Cabaldon
4 “Californians: Here's why your housing costs are so high” CalMatters, 2024