Substantial Evidence Memorandum
Greenhouse Gas Emissions Reductions
Technical Memorandum
prepared for
City of Foster City
Community Development Department
610 Foster City Boulevard
Foster City, California 94404
prepared by
Rincon Consultants, Inc.
449 15th Street, Suite 303
Oakland, California 94612
October 2024
Table of Contents
Greenhouse Gas Emissions Reductions Technical Memorandum i Table of Contents
1 Introduction .................................................................................................................................... 1
1.1 GHG Emission Reduction Targets........................................................................................ 1
1.2 Mitigation Measures and Actions Organization ................................................................. 2
1.3 GHG Emissions Reductions ................................................................................................. 2 2 Sector E-W: Energy and Water ....................................................................................................... 5 3 Sector T-L: Transportation and Land Use .....................................................................................12 4 Sector W-C: Waste and Consumption ..........................................................................................17 Tables
Table 1 Foster City CAP GHG Emission Reduction Summary by GHG Mitigation Measure ............ 3 Table 2 City of Foster City’s GHG Emissions Reductions Pathway .................................................. 4 Table 4 Sector E-W: Energy and Water GHG Emission Reduction Summary .................................. 5 Table 4 Sector T-L: Transportation and Land Use GHG Emission Reduction Summary ................ 12 Table 5 Sector W-C: Waste and Consumption GHG Emission Reduction Summary ..................... 17
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Introduction
Greenhouse Gas Emissions Reductions Technical Memorandum 1 1 Introduction
This technical memorandum presents the quantification and substantial evidence that supports the greenhouse gas (GHG) emissions reduction potential of the City of Foster City’s Climate Action Plan (CAP). This report supports the CAP’s classification as a qualified GHG reduction plan. The CAP is Foster City’s plan to reduce GHG emissions and address climate change. It includes measures and actions to reduce GHG emissions within the community. The measures identify specific goals and GHG reductions necessary to achieve the community’s GHG reduction targets. The actions under each measure represent the specific steps the City and community will implement through 2030 to support each measure and reduce GHG emissions.
Section 15183.5(b)(1) of the California Environmental Quality Act (CEQA) guidelines establishes several criteria which a plan must meet to be considered a qualified GHG reduction plan and allow for programmatic CEQA streamlining of project GHG emissions. This report details the evidence substantiating the GHG emissions reductions associated with the CAP’s measures pursuant to Subsection (D) which requires measures or a group of measures, including performance standards, that substantial evidence demonstrates, if implemented on a project-by-project basis, would collectively achieve the specified GHG emissions level. This report demonstrates the measures in the CAP provide the GHG emission reductions necessary to meet the City’s 2030 GHG emission reduction target, which aligns with the State’s GHG emission reduction goal established by Senate Bill (SB) 32 and make substantial progress towards the City’s 2045 target which aligns with the State’s goal established by Assembly Bill (AB) 1279.1
Mechanisms to monitor the implementation of the CAP and its progress toward achieving the City’s GHG emission reduction targets are included in the CAP, as required in CEQA Guidelines Section 15183.5(b)(e). If, based on the tracking of community GHG emissions, the City is not on track to reach the 2030 GHG emission reductions specified in this report, the CAP as a whole or specific measures and actions will be amended. Based on these amendments, a CAP Update will be prepared that includes altered or additional measures and actions, with evidence that their implementation can achieve the City’s 2030 GHG emission reduction target and make substantial progress towards the City’s 2045 target.
1.1 GHG Emission Reduction Targets
The City of Foster City’s GHG emission reduction targets align with California’s goal to reduce GHG emissions 40 percent below 1990 levels by 2030 (SB 32) and California’s goal to achieve carbon neutrality by 2045 (AB 1279) defined as reducing GHG emissions at least 85 percent below 1990 levels and removing or sequestering the remaining GHG emissions.
Foster City’s short- and long-term GHG emission reduction targets are:
▪ Reduce GHG emissions 49 percent below 2005 levels by 2030; and ▪ Reduce GHG emissions 88 percent below 2005 levels by 2045.
1 SB 32 established the State goal to reduce GHG emission 40 percent below 1990 levels by 2030. AB 1279 established the State goal to achieve carbon neutrality by 2045. The State defines carbon neutrality as net zero carbon emissions, which is achieved by reducing GHG emissions at least 85 percent below 1990 levels and removing the remaining emissions.
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Substantial Evidence Memorandum
2 1.2 Mitigation Measures and Actions Organization
As part of the CAP process, Foster City has developed a comprehensive set of measures and actions to reduce communitywide GHG emissions to achieve the City’s 2030 GHG emission reduction target.
The GHG mitigation measures and actions are organized according to the following hierarchy:
▪ Sectors: Sectors define the GHG emissions category in which the GHG reductions will occur. The sectors include:
Energy and Water (E-W)
Transportation and Land Use (T-L)
Waste and Consumption (W-C)
Climate Resiliency and Leadership (C-L)
▪ Measures: Measures identify specific goals and GHG reductions necessary to address GHG emissions in each sector and achieve the community’s GHG reduction targets. The reduction of GHG emissions is included for each measure, if quantifiable. ▪ Actions: Actions are the specific steps the City and community will implement to support each measure, which will accomplish the measure goal together. Actions specifically identify the mechanisms required for implementation. Measures and actions can be either quantitative or supportive, depending on whether they directly result in GHG emissions reductions or instead support reductions (for example, the development of partnerships or education programs) This memorandum identifies the measures that are quantifiable (i.e., include GHG emissions reductions) and provides a complete description of their contribution to achieving the City of Foster City’s 2030 GHG emission reduction target. Likewise, this report only details the quantitative actions that enable each GHG mitigation measure. The measures and actions that do not include GHG emissions reductions are excluded from this memorandum because they do not contribute directly to achieving and making progress towards the City’s GHG emission reduction targets. These measures and actions are nonetheless critical to the overall success of the CAP. Detail on the measures and acions without GHG emissions reductions can be found in the CAP.
1.3 GHG Emissions Reductions
Table 1 summarizes the GHG mitigation measures and the GHG emission reductions they would achieve in 2030 and 2045 upon the implementation of their actions.
Introduction
Greenhouse Gas Emissions Reductions Technical Memorandum 3 Table 1 Foster City CAP GHG Emission Reduction Summary by GHG Mitigation Measure Measure ID Measure Text
2030 GHG Emission
Reduction Potential
(MT CO2e)
Sector E-W: Energy and Water
Measure E-W.2.2 Decarbonize existing commercial and residential buildings to reduce natural gas consumption from existing commercial buildings by 19% and natural gas consumption from existing residential buildings by 25% by 2030 or reduce greenhouse gas emissions by 10,792 MT CO2e in existing commercial and residential buildings by 2030.
10,792
Measure E-W.2.3 Support Peninsula Clean Energy in providing 100% carbon neutral electricity by 2030 and maintain a Peninsula Clean Energy opt-out rate of less than 2% for residential customers and less than 2% for commercial customers by 2030.
9,825
Measure E-W.2.4 Adopt a single margin source energy score for new residential and commercial construction that exceeds the State’s minimum standards by 2026.
2,805
Sector T-L: Transportation and Land Use
Measure T-L.2.1 Increase passenger ZEV adoption to 31% by 2030 and commercial ZEV adoption to 25% by 2030.
19,581
Measure T-L.2.2 Decarbonize 18% of off-road equipment and vehicle operations by 2030. 2,594 Measure T-L.3.1 Increase the community’s active transportation mode share to 4% by 2030.
100
Sector W-C: Waste and Consumption
Measure W-C.1.2 Annually procure and apply 2,500 tons of compost by 2030. 991 Total 46,688
Together, the GHG mitigation measures and actions in the CAP provide Foster City with the GHG emission reductions necessary to achieve Foster City’s 2030 GHG emission reduction target (see Table 2). Since the CAP’s measures and actions are intended to be implemented to achieve the 2030 target and then updated in a CAP Update based on new information and future technologies, the measures do not account for progress after 2030. Therefore, due to the evolving nature of the City’s CAP, this memorandum does not quantify GHG emission reductions for 2045. The measures and actions will be updated in future CAP Updates based on information the City gains from implementing this CAP’s actions, new technologies that emerge over the time period, and new state programs and regulations that are established to reduce GHG emissions. These updates will focus on achieving the 2045 target. This CAP’s measures and actions do, however, make substantial progress on the City’s 2045 GHG emission reduction target by aligning the State’s goal for 2030 (SB 32) to put Foster City on a path to acheiveing the 2045 target (AB 1279).
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Substantial Evidence Memorandum
4 Table 2 City of Foster City’s GHG Emissions Reductions Pathway GHG Emission Forecast or Reduction Target 2030 GHG Emissions (MT CO2e) Business-as-usual Forecast 228,862
Adjusted Forecast 182,154
GHG Emissions Reductions (from full implementation of measures) (46,688) GHG Emissions Remaining (after Measure reductions) 135,466 GHG Emission Reduction Target 135,546
GHG Emissions Gap (between remaining GHG emissions and target) (80) Target Anticipated to be Met? Yes
Sector E-W: Energy and Water
Greenhouse Gas Emissions Reductions Technical Memorandum 5 2 Sector E-W: Energy and Water
The City of Foster City’s Energy and Water measures focus on electrifying residential and commercial buildings to leverage the GHG emissions reduction benefits associated with carbon- neutral electricity provided by Peninsula Clean Energy. Electrifying Foster City’s building stock consists of transitioning natural gas stationary equipment—the equipment that heats the water we use and heats and cools the spaces we live and work in—to efficient electric alternatives. When coupled with carbon-neutral electricity, all-electric buildings eliminate GHG emissions from natural gas consumption and transition to a zero-emission operational energy footprint. This characteristic is why Foster City will support Peninsula Clean Energy in providing carbon-neutral electricity to the whole community. Based on this approach, the CAP’s Energy and Water measures with GHG emission reductions consist of the measures presented in Table 3. The following subsections detail the substantial evidence and calculation methodologies used to estimate GHG emissions reductions for this sector.
Table 3 Sector E-W: Energy and Water GHG Emission Reduction Summary Measure ID Measure
2030 GHG Emission
Reductions
(MT CO2e)
E-W.2.2 Decarbonize existing commercial and residential buildings to reduce natural gas consumption from existing commercial buildings by 19% and natural gas consumption from existing residential buildings by 25% by 2030 or reduce greenhouse gas emissions by 10,792MT CO2e in existing commercial and residential buildings by 2030. 10,792
E-W.2.3 Support Peninsula Clean Energy in providing 100% carbon neutral electricity by 2030 and maintain a Peninsula Clean Energy opt-out rate of less than 2% for residential customers and less than 2% for commercial customers by 2030.
9,825
E-W.2.4 Adopt a single margin source energy score for new residential and commercial construction that exceeds the State’s minimum standards by 2026.
2,805
Total 23,423
E-W.2.2: Decarbonize existing commercial and residential buildings to reduce natural gas consumption from existing commercial buildings by 19% and natural gas consumption from existing residential buildings by 25% by 2030 or reduce greenhouse gas emissions by 10,792 MT CO2e in existing commercial and residential buildings by 2030.
Measure E-W.2.2 puts Foster City on a path to reduce existing commercial and residential natural gas consumption by 19 percent and 25 percent, respectively, by 2030 to reduce GHG emissions. The primary Actions that enable this level of adoption include:
▪ Action E-W.2.2.1 which commits the City to adopt amendments to the Foster City Building Code for Green Building, Energy, and Plumbing during the Foster City Building Code 2025 cycle, including a two-way air conditioning ordinance; and
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Substantial Evidence Memorandum
6 ▪ Action E-W.2.2.2 which directs the City to develop and implement a community-wide education and outreach campaign to provide information and incentives, benefits, and technical support for building electrification to increase voluntary adoption of all electric technologies.
These actions will support the Bay Area Air Quality Management District’s (BAAQMD) zero-nitrogen oxides (zero-NOx) rules and existing market trends to require and encourage the electrification of existing residential and commercial water heating and space heating and cooling appliances in Foster City and reduce the associated GHG emissions from natural gas consumption.
First, Action E-W.2.2.1’s two-way central air conditioning ordinance will work to require the electrification of central air conditioning replacements in Foster City’s residential and commercial buildings. The ordinance will require all central air conditioning unit installations and replacements be two-way, providing both heating and cooling with a single unit. The only technologies currently available that provide two-way central air conditioning are heat pumps. In Foster City’s climate zone, heat pumps are a cost-effective and energy efficient way to provide both heating and cooling in buildings due to their lower operating cost (enabled by their 300 to 400 percent energy efficiency) and their ability to replace the need for separate appliances (i.e., air conditioning unit and furnace).2,3 These heat pumps will serve to replace gas air conditioning units and gas furnaces with electric alternatives.
This quantification, however, assumes some noncompliance with the ordinance will occur and uses a compliance rate of 90 percent. The quantification applies this compliance rate to the percent of central air conditioning units reaching the end of their useful life to estimate the percent of electric or heat pump replacements that will occur each year.4, 5 The percent of annual replacements is then combined with the share of residential and commercial natural gas consumption those central air conditioning units and related space heating units account for in the average San Mateo County building.6 Once the number of units being replaced and the total gas reduced per unit electrified is known, the overall reduction in existing residential and commercial natural gas consumption from the ordinance is calculated. The reduction in natural gas consumption is slightly offset by the increased electricity usage from the new heat pumps. This additional electricity usage, however, is minimal due to the high efficiency (i.e., over 300 percent) of electric equipment and heat pumps compared to gas equipment.7 By assuming an implementation year of 2026 after the ordinance is adopted during the 2025 code cycle, Foster City can anticipate reducing overall natural gas consumption from existing residential and commercial buildings by 1,401 MT CO2e and 1,169 MT CO2e, respectively, by 2030.
2 According to the California Energy Codes and Standards’ Cost Effectiveness Explorer, all-electric construction is cost effective for all building types in Pinole except accessory dwelling units (ADUs).
California Energy Codes and Standards. Cost Effectiveness Explorer (2024). 3 Redwood Energy. A Pocket Guide to All-Electric Retrofits of Commercial Buildings (2022). Accessed at: https://assets-global.website- files.com/62b110a14473cb7777a50d28/6377e7c7fd6f8cc30f88afa7_Redwood%20Energy-s%20Pocket%20Guide%20to%20All- Electric%20Commercial%20Retrofits.pdf.
4 The share of residential and commercial buildings with central air conditioning is calculated for San Mateo County from the National Renewable Energy Laboratory’s (NREL) ReStock and ComStock analysis tools. The tools are available at: https://resstock.nrel.gov/. 5 The calculation sources residential and commercial air conditioning unit lifespans are from BAAQMD’s Zero-NOx rule modeling and the US Energy Information Administration’s (EIA) Updated Buildings Sector Appliance and Equipment Costs and Efficiencies report. The EIA report is available at: https://www.eia.gov/analysis/studies/buildings/equipcosts/pdf/full.pdf. 6 The share of residential and commercial natural gas consumption from space heating and cooling is calculated for San Mateo County from NREL’s ReStock and ComStock analysis tools. The tools are available at: https://resstock.nrel.gov/. 7 How efficient is a heat pump? Available at: https://help.leonardo-energy.org/hc/en-us/articles/203047881-How-efficient-is-a-heat- pump-.
Sector E-W: Energy and Water
Greenhouse Gas Emissions Reductions Technical Memorandum 7 Additionally, Foster City is under BAAQMD’s jurisdiction and will be affected by the amendments adopted for BAAQMD’s Rule 9-6: Nitrogen Oxides Emissions from Natural Gas-Fired Boilers and Water Heaters. These amendments, referred to herein as ‘zero-NOx rules,’ govern point of sale emission standards for small water heating systems starting January 1, 2027.8 The only technologies currently available that meet the amended rule are electric water heating systems. Although there are a range of electric alternatives (e.g. electric resistance space heating), heat pump water heaters are the most cost-effective option on the market due to their significantly higher efficiency (300 to 400 percent) and resulting lower operating costs. This measure’s quantification assumes Foster City households and businesses will replace existing small (up to 75 gallon) gas water heaters with heat pump water heaters at the end of the heaters’ useful life once the zero-NOx rule takes effect.9, 10 The percentage of replacements is then combined with the share of residential and commercial natural gas consumption attributed to space heating units in the average San Mateo County building.11 When applied to the forecasted residential and commercial natural gas consumption after new building electrification, the combination of the number of appliances replaced and the gas consumption per appliance provides the overall reduction in existing residential natural gas consumption resulting from the zero-NOx rule. From this zero-NOx rule, Foster City can anticipate reducing overall natural gas consumption from existing residential and commercial buildings by 1,518 MT CO2e and 59 MT CO2e, respectively, by 2030.
Lastly, this measure assumes Action E-W.2.2.2 will support existing electrification market trends to reduce an additional 15 percent of existing residential and commerical natural gas consumption by 2030. The calculation is based on a recent study showing significant growth in the adoption of electric heating appliances in California.12 Electric space heaters increased their market share from five percent in 2009 to 20 percent in 2019, while electric water heaters increased their market share from six percent to 11 percent over the same period. This trend is expected to continue through 2030, driven by the large amount of federal, state, regional, and local incentives available to Foster City community member.13, 14 Action E-W.2.2.2’s education and outreach campaign will help inform community members on the benefits of electrification, the availability of incentives, and the availability of technical support programs such as Peninsula Clean Energy’s design technical assistance for building upgrades.15
8 Under Rule 9-6: Nitrogen Oxides Emissions from Natural Gas-Fired Boilers and Water Heaters, small water heaters are units under 75,000 British Thermal Units (BTU)/hour.
9 The calculation assumes all residential water heaters are small water heaters that will be impacted starting January 1, 2027. The calculation estimates the share of commercial water heaters that are small and will be impacted starting January 1, 2027 from NREL’s Comstock analysis tool using San Mateo County data. The tool is available at: https://resstock.nrel.gov/. 10 The calculation sources residential and commercial water heater lifespans are from the EIA’s Updated Buildings Sector Appliance and Equipment Costs and Efficiencies report. The EIA report is available at:
https://www.eia.gov/analysis/studies/buildings/equipcosts/pdf/full.pdf. 11 The share of residential and commercial natural gas consumption from water heating is calculated for San Mateo County from NREL’s ReStock and ComStock analysis tools. The tools are available at: https://resstock.nrel.gov/. 12 Opinion Dynamics. California Heat Pump Residential Market Characterization and Baseline Study (2022). Accessed at:
https://pda.energydataweb.com/#!/documents/2625/view.
13 According to the California Energy Codes and Standards’ Cost Effectiveness Explorer, all-electric construction is cost effective for all building types in Foster City except accessory dwelling units (ADUs).
California Energy Codes and Standards. Cost Effectiveness Explorer (2024). Accessed at:
https://explorer.localenergycodes.com/jurisdiction/foster-city-city/study-results/3-PGE?only_study_type=new-buildings . 14 See the federal, state, regional, and local funding listed under Measure E-W.2.4 for new building electrification. 15 More information on Peninsula Clean Energy’s design technical assistance is available at:
https://www.peninsulacleanenergy.com/design-technical-assistance/.
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Substantial Evidence Memorandum
8 As such, the calculation assumes 15 percent of the natural gas consumption remaining in 2030 will be reduced through continued market trends. The 15 percent reduction is applied to forecasted residential and commercial natural gas consumption in 2030 after reductions from new building electrification, the two-way air conditioning ordinance, and BAAQMD’s zero-NOx rule for water heaters are taken into account to avoid double counting. This reduction in natural gas consumption is slightly offset by the increased electricity usage from the new heat pumps. This additional electricity usage, however, is minimal due to the high efficiency (i.e., over 300 percent) of electric equipment and heat pumps compared to gas equipment.16 With continued market trends and education support, Foster City can anticipate reducing overall natural gas consumption from existing residential and commercial buildings by 3,138 MT CO2e and 3,507 MT CO2e, respectively, by 2030.
E-W.2.3: Support Peninsula Clean Energy in providing 100% carbon neutral electricity by 2030 and maintain a Peninsula Clean Energy opt-out rate of less than 2% for residential customers and less than 2% for commercial customers by 2030
Measure E-W.2.3 aims to increase the share of Foster City’s residential and commercial electricity consumption sourced from carbon-neutral sources to 100 percent by 2030. The primary action that enables this target is Action E-W.2.3.2, which directs the City to collaborate with Peninsula Clean Energy to achieve and maintain an opt-out rate of two percent for residential customers and three percent for commercial customers in the community.
Peninsula Clean Energy currently offers an electricity option with a GHG emission rate lower than the other electricity options offered in the region. This electricity option, known as ECO100, supplies electricity sourced 100 percent from solar and wind at a GHG emissions rate of zero.17 Currently, electricity customers in Foster City are automatically enrolled in Peninsula Clean Energy’s ECOplus electricity option (with a near-zero GHG emission factor) but are allowed to opt-up to Peninsula Clean Energy’s ECO100 electricity option, opt-out to receive electricity directly from PG&E, or opt- out to procure electricity at wholesale directly from electricity generators (i.e., direct access).
However, by 2025, Peninsula Clean Energy plans to provide all customers 100 percent renewable energy on an hourly basis at cost-effective rates.18 This measure assumes Foster City will support Peninsula Clean Energy in achieving this renewable energy goal by 2025, supplying all Peninsula Clean Energy customers in Foster City with electricity sourced 100 percent from renewable to reduce such customers’ electricity GHG emissions to zero.
It is, however, conservatively assumed some customers in Foster City will opt-out of Peninsula Clean Energy. Currently, Foster City has residential and commercial Peninsula Clean Energy opt-out rates of just over two percent and just under two percent, respectively (or a Peninsula Clean Energy enrollment rate of 98 percent).19 Typical California community choice aggregation (CCA) opt-out rates are zero percent for municipal accounts, five percent for residential accounts, and 15 percent for commercial and industrial accounts.20 For example, the City of Encinitas automatically enrolled
16 https://help.leonardo-energy.org/hc/en-us/articles/203047881-How-efficient-is-a-heat-pump- 17 California Energy Commission. 2022 Power Content Label: Peninsula Clean Energy Authority. Accessed at:
https://www.energy.ca.gov/filebrowser/download/6049.
18 Peninsula Clean Energy. ACHIEVING 24/7 RENEWABLE ENERGY BY 2025 (2023). Available at:
https://www.peninsulacleanenergy.com/wp-content/uploads/2023/01/24-7-white-paper-2023.pdf. 19 Opt-out rate information was provided by Peninsula Clean Energy via email on September 26, 2024. 20 County of Butte. July 2018. Community Choice Aggregation Initial Feasibility Study. Page 18. Accessed at:
http://buttecounty.granicus.com/MetaViewer.php?view_id=2&clip_id=512&meta_id=87147 Sector E-W: Energy and Water
Greenhouse Gas Emissions Reductions Technical Memorandum 9 community members in San Diego Community Power’s Power100 service—their 100 percent renewable and carbon-free service. With no education or incentive initiatives, Encinitas experienced a seven percent opt-out rate and has maintained it since--with increased costs cited as the primary reason for opt-out.21 As directed by Action E-W.2.3.2, Foster City will, thus, implement education initiatives to maintain a reduced opt-out rate of two percent from Peninsula Clean Energy. Studies have shown informational programs can result in up to a 70 percent implementation rate of recommended practices by participants.22 The City will, therefore, include education on the benefits of clean energy for residents and businesses to encourage customers to remain in Peninsula Clean Energy. With these factors it is assumed the City will maintain a Peninsula Clean Energy opt-out rate of two percent for residential and commercial customers in 2030.
The GHG emission reductions from this measure are calculated based on the forecasted residential and nonresidential electricity consumption and the additional electricity consumption expected from new building electrification, existing building electrification, and zero-emission vehicle adoption. The measure assumes all but two percent of this residential and nonresidential electricity consumption will be provided by Peninsula Clean Energy with a GHG emissions rate of zero. Utilizing these assumptions the quantification results in an electricity related emissions reduction of 9,825 MT CO2e in 2030.
E-W.2.4: Adopt a single margin source energy score for new residential and commercial construction that exceeds the State’s minimum standards by 2026
Measure E-W.2.4 commits the City to electrify new construction in the community. The primary actions that enable this measure are Action E-W.2.4.1 which directs the City to adopt a single margin source energy score that exceeds state minimums for all applicable building types during the Foster City Building Code 2025 cycle.
Foster City fully intends to limit new natural gas developments in the community to the extent feasible. However, the U.S. Court of Appeals for the Ninth Circuit’s decision to overturn the City of Berkeley’s natural gas regulation—the ordinance that prohibited the installation of natural gas piping within newly constructed buildings—limits the City of Foster City’s ability to establish regulations to ban new natural gas construction outright.23 Through Action E-W.2.4.1, the City will employ one of the most stringent regulations currently available to electrify all new construction in the community. Action E-W.2.4.1’s ordinance will be designed to strongly encourage electrification of new construction as a cost-effective option.
As a single margin source energy score, the ordinance would establish a low Energy Design Rating (EDR)—a scoring metric that determines a building’s compliance with California’s Building Energy Efficiency Standards—that new residential and commercial buildings in Foster City would need to meet. The EDR would be set to make electrification the most cost-effective pathway to meet the standard. However, since the ordinance does not ban natural gas infrastructure outright, this ordinance may permit some new construction to be built with natural gas. These exceptions are, however, expected to be minimal because of the cost effectiveness of new building electrification in
21 San Diego Community Power (SDCP). Presentation at the San Diego Regional Climate Collaborative’s Networking Meeting on October 17, 2023.
22 Laquatra, Joseph et al. The Consumer Education Program for Residential Energy Efficiency (2009). Accessed at:
https://archives.joe.org/joe/2009december/a6.php.
23 CRA V. City of Berkeley, No. 21-16278. Accessed at: https://law.justia.com/cases/federal/appellate-courts/ca9/21-16278/21-16278- 2023-04-17.html.
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10 Foster City and the available incentives that will help continue the natural growth in electric space and water heater installations seen in California over the past decade.
According to a recent market study, electric space heaters have grown from a five percent market share in California in 2009 to a 20 percent market share in 2019. Likewise, electric water heaters have grown from a six percent market share in California in 2009 to an 11 percent market share in 2019.24 This natural trend is not only expected to continue through 2030 because all-electric new construction has proven to be cost-effective in Foster City for most all buildings types,25 but also be accelerated when coupled with the large amount of funding available for Foster City community members to install electric or heat pump space and water heating appliances. While the total amount of funding available will change with sunset dates and budget cycles, the currently available federal (i.e., High Efficiency Electric Home Rebate [HEEHRA], Homeowner Managing Energy Savings [HOMES] Rebate, Inflation Reduction Act), state (i.e., TEHC Clean California), regional (i.e., Bay Area Regional Energy Network [BayREN] Home+ Program, Bay Area Multifamily Building Enhancements [BAMBE] Program), and local (i.e., Peninsula Clean Energy’s rebates) funding makes it so that low- and middle-income residents in Foster City can install electric or heat pump space and water heaters at no additional cost compared to gas space and water heaters. In some cases, such customers will even be able to install the heat pump water heaters for free.26 For those minimal cases where construction with natural gas may still occur under a single margin source energy score despite cost effectiveness and incentives, this measure relies on CEQA mechanisms to require such buildings to mitigate the GHG emissions from natural gas construction.
The City will utilize the BAAQMD Consistency Checklist which calls for all-electric construction to demonstrate consistency with the State’s goals.27 Projects which do not meet these requirements will need to find other ways to demonstrate their consistency with state goals.
Thus, the GHG emission reductions from this measure are calculated based on the forecasted residential and nonresidential building growth and the assumption that 100 percent of new buildings will be all-electric. The quantification assumes the single margin source energy score will be adopted during the 2025 Building Code Cycle and implemented in 2026 with a compliance rate of 100 percent such that no gas is installed after 2026 due to the assumptions described above. If gas is installed despite the ordinances and CEQA streamlining benefits, the City will need to address this gas use as an existing building problem. However, new buildings will be prewired for all-electric appliances due to Title 24 standards, which should lower long term costs to convert. The quantification also accounts for the emissions from the increased electricity usage associated with the conversion of gas equipment to electric equipment. This additional electricity usage, however, is minimal due to the high efficiency (i.e., over 300 percent) of electric equipment and heat pumps
24 Opinion Dynamics. California Heat Pump Residential Market Characterization and Baseline Study (2022). Accessed at:
https://pda.energydataweb.com/#!/documents/2625/view.
25 According to the California Energy Codes and Standards’ Cost Effectiveness Explorer, all-electric construction is cost effective for all building types in Foster City except accessory dwelling units (ADUs).
California Energy Codes and Standards. Cost Effectiveness Explorer (2024). Accessed at:
https://explorer.localenergycodes.com/jurisdiction/foster-city-city/study-results/3-PGE?only_study_type=new-buildings. 26 Rincon Consultants, Inc. Installation Costs for Zero-NOx Space and Water Heating Appliances (2024). 27 BAAQMD. Air Quality Guidelines Appendix B: CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans (2022). Available at: https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa-guidelines- 2022/appendix-b-thresholds-for-evaluating-significance-of-climate-impacts_final- pdf.pdf?rev=10305f45037b41dba2cd1b45b288d54b&sc_lang=en.
Sector E-W: Energy and Water
Greenhouse Gas Emissions Reductions Technical Memorandum 11 compared to gas equipment.28 Based on the assumptions listed above, this measure is expected to result in a natural gas emissions reduction of 2,805 MT CO2e in 2030.
28 How efficient is a heat pump? Available at: https://help.leonardo-energy.org/hc/en-us/articles/203047881-How-efficient-is-a-heat- pump-.
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Substantial Evidence Memorandum
12 3 Sector T-L: Transportation and Land Use
Foster City’s Transportation and Land Use sector aims to reduce vehicle miles traveled (VMT) through active transportation and leverage renewable and carbon-free electricity to reduce GHG emissions from the remaining VMT. Reducing VMT consists of transitioning Foster City’s residents and visitors out of single-occupancy vehicles and into active transportation mode options (i.e., walking and biking). The remaining VMT will then be decarbonized by increasing the adoption of zero-emission vehicles (ZEV). When combined with renewable and carbon-free electricity, electric vehicles (EV) eliminate GHG emissions from fossil fuel combustion. Additionally, the strategy targets off-road equipment and vehicles for decarbonization through electrification. Based on this approach, the CAP’s Transportation and Land Use strategy consists of the following measures presented in Table 4. The subsections below detail the substantial evidence and calculation methodologies used to estimate the GHG emission reductions associated with this sector.
Table 4 Sector T-L: Transportation and Land Use GHG Emission Reduction Summary Measure
ID Measure
2030 GHG
Emission
Reductions
(MT CO2e)
T-L.2.1 Increase the passenger ZEV adoption to 31% by 2030 and commercial ZEV adoption to 25% by 2030.
19,581
T-L.2.2 Decarbonize 18% of off-road equipment and vehicle operations by 2030. 2,594 T-L.3.1 Increase the community’s active transportation mode share to 4% by 2030. 100 Total 22,274
T-L.2.1: Increase passenger ZEV adoption to 31% by 2030 and commercial ZEV adoption to 25% by 2030.
Measure T-L.2.1 aims to increase passenger ZEV adoption in Foster City to 31 percent by 2030 and commercial ZEV adoption to 25 percent by 2030. Passenger VMT includes automobiles and light- duty trucks while commercial VMT includes medium- and heavy-duty (MDHD) vehicles and trucks as well as buses.29 The primary actions that enable this measure include a focus on publicly accessible EV chargers and compliance with the State’s MDHD vehicle goals and regulations.
While the State is anticipated to reach a 26 percent ZEV adoption rate for passenger vehicles by 2030,30 Foster City plans to exceed this goal by increasing EV charging infrastructure within the City.
The primary action that enables this measure is Action T-L.2.1.5 which focuses on the installation of publicly accessible EV chargers. Action T-L.2.1.5 directs Foster City to facilitate the installation of 313
29 Forecasted VMT is disaggregated by fuel. This measure assumes all diesel VMT is associated with MDHD vehicles and can thus be considered commercial VMT.
30 Based on the ZEV goals for passenger vehicles established by Executive Order N-79-20, eight million zero-emission vehicles are anticipated statewide by 2030. Pinole calculated that these eight million zero-emission vehicles represent 26 percent of the total passenger vehicles expected statewide by 2030 (based on statewide passenger car and light-duty truck counts in 2016 and population estimates for 2016 and 2030).
Crisostomo, Noel et al. Assembly Bill 2127 Electric Vehicle Charging Infrastructure Assessment: Analyzing Charging Needs to Support Zero- Emission Vehicles in 2030. Accessed at: Calmatters.org/environment/2023/03/california-electric-cars- demographics/?utm_id=91724&sfmc_id=4863450.
Sector T-L: Transportation and Land Use
Greenhouse Gas Emissions Reductions Technical Memorandum 13 publicly accessible EV chargers by 2030—the number of public EV chargers needed to support the City’s 31 percent passenger ZEV adoption target—through public-private partnerships and permit streamlining.
This action focuses on public EV chargers because studies have consistently found that limited charging infrastructure is one of the primary barriers to EV adoption.31, 32 Publicly accessible EV chargers make owning an electric vehicle convenient for all drivers—including those who cannot charge at home or drive daily distances longer than their EV battery range. Public charging is especially important for multifamily housing which can be difficult to retrofit for EV charging.
According to a recent study on public charging infrastructure needs, it is expected that 20 percent of EV charging nationally will occur at publicly accessible chargers in 2030.33 This action’s quantification is based on the U.S. Department of Energy’s Electric Vehicle Infrastructure Projection Tool outputs for the San Francisco-Oakland-Berkeley Metropolitan Area.34 The tool is used to calculate the number of publicly accessible EV chargers needed in Foster City to support a 31 percent passenger ZEV adoption in 2030. The quantification assumes all ZEVs will be EVs to remain conservative in the plan for EV chargers. The quantification subtracts the number of existing EV chargers in Foster City from the model outputs to calculate the number of new public EV chargers needed by 2030.35 As such, Foster City will need to install 313 new publicly accessible EV chargers by 2030 to support a 31 percent passenger ZEV adoption rate. Due to the large amount of state and federal funding available to support California’s need for over one million public and shared chargers by 2030 (to meet Executive Order B-48-18’s ZEV goals), it is expected that these chargers are economically feasible and will be implemented through public-private funding and partnerships and permit streamlining.36 The City has recently demonstrated this approach through the installation of several DC Fast Charging stations at the Foster City Library.37 The GHG emission reductions from this measure are calculated based on the reduction in passenger VMT fossil fuel consumption due to the conversion to EV’s.38 First, the VMT reductions from Measure T-L.3.1’s active transportation initiatives are subtracted from the forecasted passenger VMT to avoid double counting VMT reductions. The remaining passenger VMT is then paired with the increase in EV adoption above the forecasted EV adoption baseline (i.e., the difference between the ZEV adoption target and the Adjusted Forecast which accounts for State programs). The result is the amount of fossil fuel powered passenger VMT that will be reduced through this measure. The
31 Kumar, Rajeev Ranjan and Kumar Alok. Adoption of Electric Vehicle: A Literature Review and Prospects for Sustainability (2020).
Accessed at: https://www.sciencedirect.com/science/article/abs/pii/S095965261934781X. 32 Winjobi, Olumide and Kelly, Jarod. Used Plug-in Electric Vehicles as a Means of Transportation Equity in Low-Income Households (2021). Accessed at: https://www.osti.gov/biblio/1658592. 33 Kampshoff, Philipp et al. Building the Electric-Vehicle Charging Infrastructure America Needs (2022). Accessed at:
https://www.mckinsey.com/industries/public-sector/our-insights/building-the-electric-vehicle-charging-infrastructure-america-needs. 34 U.S. Department of Energy. Electric Vehicle Infrastructure Projection Tool (EVI-Pro) Lite. Accessed at: https://afdc.energy.gov/evi-pro- lite.
35 PlugShare. EV Charging Stations in Foster City. Available at: https://www.plugshare.com/directory/us/california/foster-city. 36Office of Governor Gavin Newsom. California Building Bigger, Better Zero-Emission Charging Network. Accessed at:
http://www.gov.ca.gov/2024/02/14/california-building-bigger-better-zero-emission-charging-network/.
Caltrans. California Investing in EV Charging Reliability Statewide with $63 Million in Federal Funding (2024). Accessed at:
https://dot.ca.gov/news-releases/news-release-2024-002.
California Energy Commission (CEC). Electric Vehicle Charging Infrastructure Assessment-AB 2127. Accessed at:
https://www.energy.ca.gov/data-reports/reports/electric-vehicle-charging-infrastructure-assessment-ab-2127. 37 City of Foster City. Electric Vehicle Charging Station Open at the Library Parking Lot. Available at:
https://www.fostercity.org/community/page/electric-vehicle-charging-station-open-library-parking-lot-%E2%80%93-ribbon-cutting-june-
25. 38 Forecasted VMT is disaggregated by fuel. This measure assumes all gasoline VMT is associated with light-duty vehicles and can thus be considered passenger VMT.
City of Foster City
Substantial Evidence Memorandum
14 resulting GHG emissions reductions are slightly offset by the increase in electricity usage from the new EVs. Based on the assumptions listed above, this measure is estimated to reduce passenger VMT GHG emissions by 17,302 MT CO2e in 2030.
For commercial VMT, the measure’s targets are in line with the State’s goals and regulations for MDHD vehicles and buses. California is working towards achieving Executive Order (EO) N-79-20, which aims to reach a 100 percent zero-emission drayage truck population by 2035 and 100 percent zero-emission MDHD vehicle population by 2045. To reach these goals, CARB has adopted the Advanced Clean Trucks regulation which regulates the sale of MDHD vehicles in California and the Advanced Clean Fleets regulation which regulates the purchase and use of zero-emission MDHD vehicles in public and private fleets in California. These regulations have increasing requirements for zero-emission MDHD vehicle sales and use to mandate the phase-in of commercial ZEVs. For example, by 2030, the Advanced Clean Fleets regulation requires 10 percent of sleeper cab tractors and specialty vehicles, 25 percent of pickup trucks and day cab tractors, and 50 percent of box trucks, vans, and package delivery vehicles in a fleet to be zero-emission. Additionally, the State has adopted zero-emission regulations for transit buses including the Innovative Clean Transit rule which requires 100 percent of new transit bus purchases to be to be zero-emission starting in 2029 and 100 percent of transit bus fleets to be zero-emission by 2040.
Overall, it is estimated that compliance with these zero-emission regulations for MDHD vehicles in Foster City will equate to at least a 25 percent commercial ZEV adoption.39 The GHG emissions reductions from this measure’s compliance with state regulations are calculated based on the reduction in fossil fuel powered commercial VMT from the increase in EV adoption.40 The commercial VMT is paired with the increase in EV adoption above the forecasted EV adoption baseline (i.e., the difference between the ZEV adoption target and the Adjusted Forecast). The result is the amount of fossil fuel powered commercial VMT that will be reduced through this measure.
The resulting GHG emissions reductions are slightly offset by the increase in electricity usage from the new EVs. Based on the assumptions listed above, this measure is estimated to reduce commercial VMT GHG emissions by 2,279 MT CO2e in 2030.
T-L.2.2: Decarbonize 18% of off-road equipment operations by 2030.
Measure T-L.2.2 aims for Foster City to decarbonize 18 percent of off-road vehicle and equipment use in the community by 2030. The primary action that enables this measure is Action T-L.2.2.1 which commits the City to enforce the California Air Resources Board’s (CARB) Small Offroad Engine (SORE) ban on fossil fuel equipment use through a local code and compliance with the State’s off- road decarbonization goals and regulations.
CARB’s SORE regulation bans the sale of off-road vehicles and equipment with gasoline- and diesel- powered SOREs starting in 2024 and bans the sale of gasoline- and diesel-powered portable generators starting in 2028. As defined by CARB, SORE are those equipment types with rated power at or below 19 kilowatts (i.e., 25 horsepower). Typical off-road vehicle and equipment types that use these engines include lawn and garden equipment, portable generators, and pressure washers.41 In
39 For example, the Inland Empire Utilities Agency (IEUA) completed a Zero-Emission Vehicle Readiness Plan in 2024. The plan assessed their existing MDHD vehicle fleet and estimated over 30 percent of their fleet would need to be zero-emission by 2030 to comply with the Advanced Clean Fleets regulation.
IEUA. Draft Zero-Emission Vehicle Readiness Plan (2024). 40 Forecasted VMT is disaggregated by fuel. This measure assumes all gasoline VMT is associated with light-duty vehicles and can thus be considered passenger VMT.
41 California Air Resources Board. SORE Applicability Fact Sheet (2021). Accessed at: https://ww2.arb.ca.gov/resources/fact-sheets/sore- applicability-fact-sheet.
Sector T-L: Transportation and Land Use
Greenhouse Gas Emissions Reductions Technical Memorandum 15 2030, SOREs will compromise over 13 percent of the off-road vehicle and equipment fuel used in Foster City.42 Thus, by enforcing CARB’s ban on fossil fuel-powered off-road equipment and vehicle sales, Foster City will effectively reduce 13 percent of the community’s off-road fuel usage as the equipment need replacement.
This SORE decarbonization and remaining five percent of off-road fuel usage decarbonization in other equipment types will also be supported by Action T-L.2.2.2’s incentive and technical assistance program. The program will connect Foster City community members to available incentives to transition to zero-emission off-road equipment and vehicles (e.g., CARB’s Clean Off- road Equipment Voucher Incentive Program) and help them identify such zero-emission alternatives for their fleet. This measure aligns with CARB’s SORE regulation and EO N‑79‑20’s statewide goal to transition off-road vehicles and equipment operations to 100 percent zero-emission by 2035.
In addition, this target will be supported by CARB’s regulations for larger off-road equipment to use renewable diesel. CARB’s 2022 amendment to the In-Use Off-Road Diesel-Fueled Fleets Regulation sets requirements on the procurement and use of renewable diesel—a low-emission, direct substitute for conventional diesel. Starting in 2024, any person, business, or government agency who owns or operates vehicles with a diesel-fueled or alternative diesel fueled off-road compression-ignition engine with maximum power of 25 horsepower or greater are required to procure and only use renewable diesel (i.e., 100 percent renewable diesel or a 99 percent renewable diesel blend).43,44 This regulation will effectively reduce emissions from Foster City’s diesel, non-SORE which, in 2030, will account for 49 percent of Foster City’s off-road fuel usage. To remain conservative, the calculation assumes an 18 percent reduction in off-road emissions by 2030.
The GHG emission reductions are based on the forecasted off-road equipment and vehicle fuel usage and a 18 percent reduction from SORE and renewable diesel requirements. The calculation results in a 2,594 MT CO2e reduction in off-road equipment and vehicle emissions by 2030.
T-L.3.1: Increase the community’s active transportation mode share to 4% by 2030.
Measure T-L.3.1 aims to increase Foster City’s active transportation mode share to four percent by 2030, from the City’s 2022 active transportation mode share of 2.8 percent (1.5 percent pedestrian mode share and 1.8 percent bicycle mode share).45 Foster City is currently developing a Bicycle and Pedestrian Master Plan (BPMP) to address bicycle and pedestrian safety and needs throughout the City.
The objective of the BPMP is to incorporate previous transportation studies (e.g., Foster City’s Bicycle Network Assessment and Safe Routes to School Assessment) and new analysis into a plan that examines bicycle and pedestrian safety and needs within the City, creating a comprehensive
42 Foster City’s SORE fuel usage in 2030 was estimated by filtering CARB OFFROAD2021 model outputs for San Mateo County in 2030 for horsepower ratings less than or less than 25. The results were divided by the total estimated off-road fuel usage in San Mateo County in 2030 to estimate the share, or percentage, of fuel usage attributable to SOREs. This methodology assumes Foster City’s off-road fuel usage will reflect that of San Mateo County’s.
43 CARB. Final Regulation Order. Amendments to Sections 2449, 2449.1, and 2449.2, Title 13, California Code of Regulations. Available at:
https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2022/off-roaddiesel/froa-1.pdf#page=88. 44 CARB. Fact Sheet: Renewable Diesel Fuel Requirements. Available at: https://ww2.arb.ca.gov/resources/fact-sheets/fact-sheet- renewable-diesel-fuel-requirements.
45 US Census Bureau. 2022: ACS 5-Year Estimates Subject Tables. S0801|Communting Characteristics by Sex. Accessed at:
https://data.census.gov/table/ACSST5Y2022.S0801?t=Commuting&g=160XX00US0625338,0657288.
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Substantial Evidence Memorandum
16 document that prioritizes Safe Routes to School, the City’s existing Complete Streets Policy and multi-modal transportation throughout the City. The plan will build upon several existing transportation planning efforts and provide Public Works with the knowledge to enhance the City’s existing bicycle and pedestrian facilities and infrastructure to achieve at least a four percent active transportation mode share by 2030.
The plan will focus on infrastructure because studies have shown that investments in active transportation infrastructure significantly improve active transportation mode shifts and reduce GHG emissions.46 For example, urban cities that make a strong commitment to bicycle travel can see up to an 11 percent reduction in VMT and associated GHG emissions.47 Such VMT reductions can be reasonably expected because in 2017, about 16 percent of vehicle trips made nationally were one mile or less—a distance easily travelled by foot or bicycle.48 To estimate the mode shift potential of developing and implementing a BPMP in Foster City, other cities’ bicycle and road networks were analyzed. The City of Berkeley leads the State with an 18 percent active transportation mode share in 2022 (i.e., 4.9 percent bicycle mode share and 13.4 percent pedestrian mode share) followed by the City of Davis with a 16 percent active transportation mode share in 2022 (i.e., 13.5 percent bicycle mode share and 2.6 percent pedestrian mode share).49, 50 For Foster City, a conservative active transportation mode share of four percent is assumed with the increase coming from bicycle mode share while walking mode share is conservatively assumed to remain constant. These active transportation mode share estimates also provide VMT reductions for Foster City well within the reductions shown in the cited studies.
The GHG emissions reductions associated with this measure are calculated based on Foster City’s forecasted passenger VMT and the increase in bicycle mode share above the baseline (i.e., the difference between the active transportation mode share target and the baseline, assuming the pedestrian mode share remains constant).51 The result is the amount of passenger VMT that will be reduced through this measure. This quantification and assumptions reduce passenger VMT GHG emissions by 100 MT CO2e in 2030.
46 Glazener, Andrew and Khreis, Haneen. Transforming our Cities: Best Practices Towards Clean Air and Active Transportation (2019).
Accessed at: https://link.springer.com/article/10.1007/s40572-019-0228-1 47 Jacob Mason et al., Institute for Transportation & Development Policy and the University of California, Davis. A Global High Shift Cycling Scenario (2015). Accessed at: https://itdpdotorg.wpengine.com/wp-content/uploads/2015/11/A-Global-High-Shift-Cycling- Scenario_Nov-2015.pdf
48 National Household Travel Survey. Population Vehicle Trips Statistics (2021). Accessed at: https://nhts.ornl.gov/vehicle-trips 49 US Census Bureau. 2022: ACS 5-Year Estimates Subject Tables. S0801|Commuting Characteristics by Sex. Accessed at:
https://data.census.gov/table?t=Commuting&g=160XX00US0618100. 50 US Census Bureau. 2022: ACS 5-Year Estimates Subject Tables. S0801|Commuting Characteristics by Sex. Accessed at:
https://data.census.gov/table?t=Commuting&g=160XX00US0606000. 51 Forecasted VMT is disaggregated by fuel. This measure assumes all gasoline VMT is associated with light-duty vehicles and can thus be considered passenger VMT.
Sector W-C: Waste and Consumption
Greenhouse Gas Emissions Reductions Technical Memorandum 17 4 Sector W-C: Waste and Consumption
Foster City’s Waste and Consumption sector focuses on using recovered organic waste for carbon sequestration. As Foster City increases organic solid waste diversion to comply with SB 1383, the diverted waste can be recovered and converted into other products, such as compost. When applied to lands, compost improves soil health and sequesters carbon out of the atmosphere. Based on this approach, the CAP’s Waste and Consumption measures with GHG emission reductions consists of the measure presented in Table 5. It is important to note that consistency with SB 1383 (diverting 75% of organics diverted from the landfill compared to 2014 baseline) was included in the forecast and is therefore, not included here to avoid double counting. The following subsection details the substantial evidence and calculation methodologies used to estimate GHG emissions reductions for this sector.
Table 5 Sector W-C: Waste and Consumption GHG Emission Reduction Summary Measure
ID Measure
2030 GHG
Emission
Reductions
(MT CO2e)
W-C.1.2 Annually procure and apply 2,500 tons of compost by 2030. 991 Total 991
W-C.1.2: Annually procure and apply 2,500 tons of compost by 2030.
Measure W-C.1.2 puts Foster City on a path to exceed the City’s SB 1383 procurement target by 2030 and maintain it thereafter. SB 1383 requires each jurisdiction in California to procure recovered organics waste products to meet annual procurement targets developed by CalRecycle.52 Recovered organic waste products include compost, mulch, renewable energy generated from anaerobic digestion (e.g., transportation fuel, electricity, and gas for heating), and electricity generated from biomass conversion. While a jurisdiction has the option to procure any combination of recovered organic waste products to fulfill 100 percent of its procurement target, Foster City aims to meet their procurement target primarily through the procurement of compost to leverage the carbon sequestration benefits it provides when applied to lands. The primary actions that enable this measure include:
▪ Action W-C.1.2.1 which commits the City to procure and apply 2,500 tons of compost annually by 2030; and
▪ Action W-C.1.2.2 which directs the City collaborate with San Mateo County to identify locations to apply compost, if locations within the City cannot be identified.
These actions direct the City to procure and apply compost to meet and exceed their annual SB 1383 targets. The GHG emission reductions associated with this compliance are based on Foster City’s goal to apply 2,500 tons of compost annually. This data is paired with an average carbon sequestration factor for compost across land types to calculate the GHG emission reductions from
52 CalRecycle. Procurement Targets and Recovered Organic Waste Products. Accessed at:
https://calrecycle.ca.gov/organics/slcp/procurement/recoveredorganicwasteproducts/.
City of Foster City
Substantial Evidence Memorandum
18 the procured compost.53 The calculations result in emissions reductions of 991 MT CO2e in 2030. If Foster City cannot find enough space within its boundaries to apply composte, they can work directly with the County of San Mateo and San Mateo Resource Conservation District Compost Procurement program to find suitable agricultural lands to apply high quality compost.54 For this approach to work the City will need to ensure that the quality of the compost being procured is high.
53 CARB. METHOD FOR ESTIMATING GREENHOUSE GAS EMISSION REDUCTIONS FROM DIVERSION OF ORGANIC WASTE FROM LANDFILLS TO COMPOST FACILITIES (2017). Available at: https://ww2.arb.ca.gov/sites/default/files/classic/cc/waste/cerffinal.pdf. 54 https://www.sanmateorcd.org/project/compost-program/ Sector W-C: Waste and Consumption
Greenhouse Gas Emissions Reductions Technical Memorandum 19
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