1 August 29, 2024
Dear Mayor and Members of the City Council,
I am writing on behalf of Southern California Edison (SCE) to express our support for the City of Goleta’s proposed EV charging reach code. A building decarbonization ordinance, such as an electric-preferred reach code, electric vehicle (EV) charging reach code, or building performance standard, can be a very cost-effective way for local governments to achieve meaningful greenhouse gas reductions and help it achieve its climate and air quality goals. SCE appreciates the opportunity to work with city staff to provide input to the development of this ordinance and ensure it meets our shared greenhouse gas (GHG) reduction goals while also maintaining reliability of the grid. We encourage the city council to adopt the proposed ordinance. SCE offers the following points in support:
1. Transportation is the largest source of emissions in California for GHGs and several criteria pollutants.
2. Using today’s electric grid, EVs produce about 70 percent less GHG emissions compared to equivalent combustion vehicles, according to the California Air Resources Board.
3. Powering a vehicle with electricity is cheaper than fueling it with gasoline or diesel, especially
when customers take advantage of lower cost off-peak electricity rates.
4. The grid is ready to support all electric buildings and electric vehicles – SCE is modernizing and hardening our distribution system, increasing reliability and resiliency.
5. And perhaps most importantly, in order to meet the State’s environmental goals, our Countdown to 2045 study has shown that 90% of passenger vehicles need to be electrified as soon as possible.
Transportation is a major source of emissions in California – for both local air quality and GHGs.
Transportation is responsible for 39 percent of GHG emissions statewide, more if you include emissions from refineries. Further, transportation is responsible for over 75 percent of nitrous oxide emissions, which is a component of smog and associated with negative health effects. Switching to an EV can reduce GHG emissions by 80 percent and criteria pollutants by over 90 percent, compared to an equivalent combustion vehicle. These numbers will only improve over time as the grid gets closer and closer to 100 percent clean energy. Improving access to EV charging is important for increasing EV adoption, especially at work and for multi-family properties. Installing charging at these locations is particularly important for low-income customers who are less likely to live in a single-family home with a garage that has dedicated charging.
We are working to ensure the grid is ready. We are committed to serving the needs of California’s clean energy future, as outlined in our whitepaper, Reimagining the Grid. This requires a grid that supports high levels of carbon-free resources, integrates new technologies and services, and remains safe, reliable, affordable and resilient even as the climate continues to evolve. SCE is modernizing and hardening our distribution system, leveraging increasingly sophisticated hardware and software to manage a complex and intelligent grid. This will not only help enable greater adoption of clean energy technologies, but it will also improve general reliability while making the grid more resilient to threats exacerbated by climate change such as wildfires and heatwaves. Customer-owned resources like rooftop
2 solar and battery storage can offer additional resiliency. We estimate by 2045 about half of single-family homes in our service territory will have some combination of solar and storage. Due to Title 24, all new low-rise residential construction has to have solar and be energy storage ready, and most new commercial also has to have solar.
We appreciate staff taking the time to engage SCE to ensure the proposed ordinance would not negatively impact the electric grid. We support the focus on low-power Level 2 charging in multifamily buildings, hotels, and motels and the exceptions focused on available grid capacity. It would be beneficial for developers to contact SCE at the earliest possible point in the development of their projects. The sooner we are aware of a project, the more likely we will be able to connect them to the grid in a timely manner. SCE would welcome and appreciate anything the city can do to encourage or require developers to contact SCE earlier in the development process.
SCE is excited to partner with the City of Goleta in enabling greater decarbonization and addressing the climate crisis. Emissions from the building and transportation sectors are important to address if we are to meet the city’s and state’s climate goals. We encourage the city council to adopt the proposed EV charging reach code. We look forward to our continued partnership. The future is electric.
Sincerely,
Natalie Yanez
Government Relations Manager
Attachments:
Reliability FAQ
City of Goleta 2024 Circuit Reliability Report
From: CARTER MORGAN
To: City Clerk Group
Subject: City Council Agenda item D.1 - Goleta Municipal Code to Adopt an Electric Vehicle Reach Code Date: Friday, August 30, 2024 1:36:57 PM
Dear Mayor Perotte and City Council Members,
First of all, we want to thank you for the consistent stances this council has taken over the years to protect the environment and natural beauty of our community. As Goleta residents for over 30 years (50+ in the SB area), we appreciate how you show concern for our environment. In particular now, we want to thank the City of Goleta Sustainability staff and elected officials for considering an EV Reach Code.
We are EV owners who have the privilege of owning a home with a garage. This allowed us to install our own EV charging station. Many renters unfortunately do not have this option. We hope that the city council will adopt an EV reach code; this will increase access to EV chargers at new buildings in Goleta. Prioritizing access to EV chargers in multifamily residential properties is essential to supporting the transition to EVs in the Goleta community.
More EVs in our community and state will result in
cleaner air for drivers, bikers, and walkers, and greatly reduce greenhouse gas emissions. EVs also will reduce our dependence on oil and allow Goletans to use clean electricity for power.
As you are no doubt aware, EV Reach Codes help advance the accessibility and affordability of EVs for all future occupants of apartments and commercial buildings.
Greater accessibility for all will mean expanded EV adoption across Goleta in the short term, a necessary step both for improving air quality and mitigating climate change.
We believe that it's important to take every opportunity we can to build a sustainable transportation system. This EV Reach Code is one of the strongest ways our city council can support more EV charging options for more Goletans.
Thank you in advance for adopting an EV Reach Code and continuing the strong environmental advocacy this council is known for.
Appreciatively,
Carter and Wendy Morgan
6542 Camino Caseta
1 BERMANT DEVELOPMENT COMPANY
5383 Hollister Avenue
Santa Barbara, CA 93108
August 31, 2024
Ms. Dana Murray
City of Goleta
130 Cremona Drive
Goleta, CA 93117
Re: PROPOSED DRAFT ORDINANCE AMENDING CHAPTER 15.12 ENTITLED “GREEN BUILDING CODE” OF THE GOLETA MUNICIPAL CODE TO MAKE CERTAIN LOCAL AMENDMENTS TO THE 2022 EDITION OF THE CALIFORNIA GREEN BUILDING STANDARDS CODE (“REACH CODE”)
Dear Dana,
Thank you for arranging the online Team's mee6ng on Monday, August 19th concerning the above-referenced dra@ ordinance. Jeff and I appreciate the City's outreach and effort to consider the input of property owners with respect to the proposed ordinance.
Below are some thoughts for Staff and City Council's considera6on:
1. While the City provides a mul6tude of reasons for implemen6ng the proposed ordinance, the enumerated reasons do not provide a specific environmental harm affec6ng the City of Goleta (“City”) that does not also affect other communi6es throughout the State of California. Please refer to the previously submiSed leSer (aSached) dated May 20, 2024 from Key Bley, Esq. , Cox Castle Nicholson. The City should provide “local clima6c, geologic or typographical features” that are unique to the City that warrant the establishment of more restric6ve EV standards so as to eliminate any ques6on concerning adop6on of the proposed Reach Code ordinance.
2. There is some ques6on concerning the 6ming and scale of this proposed ordinance, par6cularly with reference to the retail and office markets. Retail markets con6nue to recover from high vacancy rates while office buildings con6nue to be significantly impacted by the remote work environment. Office parking lots (including ours) sit half empty or, worse, empty. Where property owners are finally star6ng to fill vacan t spaces, they are forced to incur significant re-tenan6ng costs, well in excess of $200,000. Some6mes these improvements require an increase in power to the electrical systems of buildings. New Sec6on 5.106.5.4 of the CALGreen Code, which became effec6ve July 1, 2024, adds significant new costs to exis6ng non-residen6al property owners that are s6ll trying to fill vacant spaces. The City's proposed Reach Code ordinance places an even greater burden on our community's real proper6es. While the burdens of Sec6on
5.106.5.4 may apply equitably across the State of California, the addi6onal burdens proposed by 2 the City are not equitable and create an unlevel playing field where it will cost companies more to do business in Goleta than elsewhere. This will impact the ability of property owners to aSract and retain business thereby nega6vely impac6ng local jobs, housing, real estate taxes and the economy. 3. Notwithstanding the foregoing, if the City decides to proceed with the Reach Code ordinance, we have a few sugges6ons how to address the issues raised in No. 2 above: (a) Defer implementa6on of the proposed ordinance un6l 2026, at which 6me, business will have adjusted to not only the July 2024 CALGreen code EV requirement, but the next CALGreen code modifica6on scheduled for July 2025. Allow a year or two for this adjustment. Therea@er, if the City s6ll wishes to exceed the CALGreen standard, then it may s6ll adopt the Reach Code ordinance. (b) Incorporate propor6onality into the Reach Code as suggested in the previously referenced leSer from Cox Castle Nicholson. Sec6on 5.106.5.4.3 limits the EV requirements the "[c]ode sec6ons relevant to addi6ons and altera6ons...to the por6ons of the building, being added or altered within the scope of the permiSed work..." as required under Code Sec6on 301.3. While building departments apparently do not interpret this sec6on of CALGreen code to limit the EV requirement to "the por6ons of the building, being added or altered within the scope of the permiSed work," the City can adopt propor6onality in its Reach Code that would be consistent with 5.106.5.4.3 by sta6ng that the addi6onal EV requirements in the Reach Code apply only to the "the por6ons of the building, being added or altered within the scope of the permiSed work." (c) Add an exclusion to addi6onal requirements under the proposed Reach Code ordinance for medical and healthcare companies, including Goleta Valley CoSage Hospital (GVCH). While the State's requirements under Sec6on 5.106.5.4 affect all businesses in California, the City's proposed Reach Code ordinance adds significant cost that could impact the health and safety of our local community. As an example, say GVCH or Sansum (now SuSer Health) or UCLA Health want to install the latest medical imaging technology in Goleta and this technology requires addi6onal power to building electrical systems, these companies will face significant cost installing EV pursuant to CALGreen Code Sec6on 5.106.5.4 and an addi,onal, more significant cost based on the City's proposed Reach Code. Given these extra cost burdens, our medical service providers may well decide that the addi6onal burden associated with the City's Reach Code are not worth the investment, thereby leaving the Goleta community with a lower quality of healthcare than other communi6es. The health and welfare of the community should be the first and most important obliga,on of the City. 4. Finally, we have a few proposed modifica6ons to the proposed Reach Code that you may wqish to consider:
3 (a) In an effort to clarify that parking lot resurfacing, restriping and repairing are to be excluded from Sec6on 5.105.5.4, we suggest modifying the "NOTE" under Sec@on 15.12.020 Local Amendments to Defini@ons to read as follows (inser6on noted in underscored red font): NOTE: Repairs, including, but not limited to, resurfacing, restriping, and repairing parking lot surfaces or maintaining existing lighting fixtures are not considered alterations for the purpose of this section. (b) In the sec6on amending Sec6on 5.106.5.4 under Sec@on 15.12.020 Local Amendments to Defini@ons, we suggest adding the following two provisions under the Excep6ons provision: 5. Altera6ons that solely add Level 1 EV charging receptacles or Level 1 or Level 2 EV chargers and no other addi6on or altera6on is performed. and, 6. An increase in power necessary for the opera6on of medical devices. Conclusion Sadly, the world has failed to address the impacts of the industrial age that affect the air we breathe, the water we drink and the climate of our planet. We are all trying to make up for lost 6me, doing our best to save our planet for future genera6ons. The State has taken ac6on to address some of these impacts by implemen6ng far reaching environmental mi6ga6ons. We understand the City's desire to do its part and even to exceed the State's standards. However, the City's effort should be consistent with State law and consider the addi6onal costs that will fall on the local businesses and homeowners/taxpayers - costs that could significantly impact the local economy and place new impediments on the development of much needed workforce housing. Thank you for your consideration. Respectfully BERMANT DEVELOPMENT COMPANY Andrew S. Bermant Agent
From: Rachel Altman <[email protected]>
Sent: Saturday, August 31, 2024 5:59 PM
To: City Clerk Group
Subject: D.1 Goleta Municipal Code to Adopt an Electric Vehicle Reach Code Dear City of Goleta Sustainability staff and elected officials, I urge you to adopt an EV Reach Code to increase access to EV chargers at new buildings in Goleta. Prioritizing access to EV chargers in multifamily residential properties is essential to supporting the transition to EVs in the Goleta community. This action also supports California’s goals of Carbon Neutrality by 2045. This action is essential to move our county and our state to the climate goals that have been set for us, and that are essential for our future existence, and for our children's futures.
As a grandmother, a leader in the Clim ate Reality movement, and a Santa Barbara resident, I believe that moving toward an EV-only future and making the accessibility of EVs for multi-family housing residents is essential for transportation equity.
Greater accessibility for all will mean expanded EV adoption across Golet a in the short term, a necessary step both for improving air quality and mitigating climate change.
Thank you for your consideration of an EV Reach Code, and for all you have done so far to move us towar
d a carbon-free future.
Rachel Altman
1383 Sycamore Canyon Road
Santa Barbara, CA 93108
From: [email protected]
Sent: Sunday, September 1, 2024 6:11 PM
To: City Clerk Group
Subject: D.1 Goleta Municipal Code to Adopt an Electric Vehicle Reach Code Dear Goleta City Council,
I am writing as a resident of Goleta to urge you to adopt an EV Reach Code to increase access to EV chargers at new buildings in Goleta. I really appreciate the work you have done to make Goleta an eco- friendly place to live -- we live in a beautiful place full of unique natural resources and it is our privilege to be good stewards of these resources. You have supported the proliferation of EVs in our City and, as an EV owner, I really appreciate the supportive community for EVs that we have in Goleta. Vehicles are a top contributor to harmful greenhouse gases (transportation accounts for over 55% of Goleta's emissions) that are causing climate change and natural disasters. Switching to EVs decreases the dependence on oil and increases energy efficiency and sustainability, and are also cheaper to maintain and fuel. Over 44 local governments in California have adopted EV Reach Codes and, as a leader in sustainability, it is time for Goleta to do the same. Adopting a Reach COde component that addresses EV charging infrastructure will help Goleta further electrify our transportation sector so that we can reach zero emissions by 2035. The accessibility of EVs for multi-family housing residents is essential for transportation equity. I lived in a multi-family housing complex and I tried to use an electric vehicle, but because there were no charging stations available at my complex, I had to buy a plug-in hybrid instead. I did ask my housing complex to install chargers, but it took over a year for them to do so, and in the meantime I had to use gas to fuel my car. Having a Reach Code that codifies accessible EV charging will incentivize many people to buy EVs because it will make owning an EV more feasible and affordable. More charging access at multi-family complexes and workplaces allows EV drivers to utilize more affordable off-peak Time-of-Use rates, so that they do not have to charge at more expensive public fast chargers (that are often out of service and/or in such high demand that it is hard to find open chargers). Thank you so much for committing to making Goleta a beautiful, equitable place for the community today and for generations to come.
Best,
Joanna Tang
she/her
PhD, Department of Ecology, Evolution & Marine Biology
University of California, Santa Barbara
From: Emily Engel <[email protected]>
Sent: Monday, September 2, 2024 7:03 AM
To: City Clerk Group
Subject: Amending Chapter 15.12 of the Goleta Municipal Code Hello,
The Sierra Club Santa Barbara - Goleta Group supports and encourages the Goleta City Council to amend Chapter 15.12 of the Goleta Municipal Code to adopt an electric vehicle reach code.
The expansion of clean energy technology and infrastructure strengthens our local community and economy at the same time it provides affordable, accessible green transportation for the benefit of all.
Thank you for all you do to ensure a clean, sustainable, thriving future for Goleta and the the Central Coast.
Sincerely,
Emily Engel
Chair
Sierra Club Santa Barbara - Goleta Group
From: michalcathy
To: City Clerk Group
Subject: EV Reach Code
Date: Tuesday, September 3, 2024 2:57:03 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Thank you so much for considering an EV Reach Code! I own an EV so I know how they work and how difficult it can be find ways to charge them. I have several friends who cannot effectively use their EV or who could not even consider buying one, because they do not live in single family home, have no access to charging.
Please support them and all of us who will benefit from the cleaner air! - Michal Lynch
Yahoo Mail: Search, Organize, Conquer
From: Farah Stack
To: City Clerk Group
Cc: Paula Perotte; Luz Reyes-Martin; Stuart Kasdin; James Kyriaco; Kyle Richards Subject: D.1 Goleta Municipal Code to Adopt an Electric Vehicle Reach Code Date: Tuesday, September 3, 2024 4:00:19 PM
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Dear Mayor Perotte and City Council,
The Community Environmental Council strongly urges the City of Goleta to adopt an EV Reach Code to increase access to EV chargers in new buildings in Goleta. This is crucial for supporting the transition to electric vehicles (EVs) in our community and aligns with California’s goal of achieving carbon neutrality by 2045.
More EVs on the road will lead to cleaner air for drivers, bikers, and walkers while significantly reducing greenhouse gas emissions. EVs are also incredibly energy efficient, with many achieving over 100 miles per gallon equivalent and costing about half as much to charge compared to gasoline. By adopting an EV Reach Code, Goleta can help close the gap between EV charging demand and availability, ensuring that we are prepared for the growing number of EVs.
Over 44 local governments in California
have already adopted EV Reach Codes, helping their
jurisdictions meet state electrification goals. With transportation accounting for over 55% of the City’s emissions, it’s essential for Goleta to take bold action now. Increasing EV infrastructure requirements in new construction will further support our transition to an electrified transportation sector.
As California moves toward an EV-only future by 2035, ensuring that residents of multifamily housing have access to EV chargers is critical for transportation equity. An EV Reach Code will make EVs more accessible and affordable for all future occupants of apartments and commercial buildings, facilitating greater adoption of EVs in Goleta.
Additionally, providing more charging options at multifamily complexes and workplaces will allow EV drivers to take advantage of more affordable off-peak Time-of-Use rates, rather than relying solely on more expensive public fast chargers.
By adopting this EV Reach Code, the Goleta City Council can take a strong step toward building a sustainable transportation system that benefits all residents.
Thank you for your time and consideration.
Sincerely,
Farah Jehan Stack { she/her }
Senior Climate Policy Associate
Community Environmental Council
P.O. Box 90660
Santa Barbara, CA 93190-0660
[email protected]
(805) 730-0878 office
(310) 924-0189 cell
Connect on
LinkedIn
From: Jonathan Ullman
To: City Clerk Group
Subject: Sierra Club supports D.1 Goleta Municipal Code to Adopt an Electric Vehicle Reach Code Date: Tuesday, September 3, 2024 3:59:28 PM
Attachments: EV Reach code Goleta letter 5.7.23 (1).docx CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Sept. 3, 2024
Dear City Clerk:
We are resending our previous letter dated May 5, 2024 to the Goleta City Council supporting an EV Charging reach code, which is on today's agenda item D.1 This piece of legislation will allow Goleta residents the freedom to purchase their vehicle's energy where they sleep without spending money at a station. It's a game- changer.
Thank you.
--
Jonathan Ullman, Director
Sierra Club Santa Barbara-Ventura Chapter
--
Jonathan Ullman, Director
Sierra Club Santa Barbara-Ventura Chapter
P O Box 31241
Santa Barbara, CA 93130-1241
Phone: (805) 617-3106
Chair
Katie Davis
Vice-Chair
Jim Hines
Secretary
Gerry Ching
Treasurer
Maureen Ellenberger
At Large
David Gold
At Large
Alex Pujo
Council Delegate
Emily Engel
Arguello Group Rep
Rebecca August
SB Group Rep
Jim Taylor
Conejo Group Rep
Rebecca August
Ventura Network Rep
Elizabeth Lamar
PO Box 31241
Santa Barbara CA
93130-1241
Dear Goleta Mayor and Councilmembers:
The Sierra Club Santa Barbara Group supports the electric vehicle reach code and municipal use of 100 percent clean energy whether it comes from rooftops, via power lines or both.
For too long, electric vehicles have not been realistically possible for apartment renters and condo owners.
Nearly all multi-unit residential buildings, old and new, do not allow residents to charge their cars in their own building's parking spots. Unlike single family house owners or renters, these owners and renters cannot charge their vehicles while they sleep. This forces them to pay premium prices for outside charging or do what most of their neighbors do: not drive electric.
But shouldn't everyone have the opportunity to avoid paying an oil company $50 a week? Shouldn't everyone have access to EV Charging at reduced pricing at the place where they sleep?
Most multi-unit residential buildings, not all of course, come with a kitchen sink and bathroom, electric outlets to plug things in and major appliances (most of the time.)
Older buildings don't have electric-charging parking spots largely because there weren't EVs when they were built. But now there are.
Many condo owners, associations and landlords are loath to invest in the high costs of heavy duty-copper wiring and electricians' time needed for on-site charger parking. That's a fair point. It's expensive enough to live here. But it's also discriminatory and byzantine because electric car charging overnight is a legitimate standard -- just like bathrooms, kitchen sinks and electric outlets.
A parking spot is not always necessary, but it's a feature designed to let you sleep on the same property your car is parked and charge it with the same electricity in which you dwell at lower off-peak charging rates.
Infrastructure designed for the past is inhibiting much of the population from living a modern life.
That disconnect hopefully stops today for new residential construction, which is much easier and cheaper than existing buildings, to wire from the start. It means that the modern standard in Goleta will be an electric charging parking spot for residents. Does it solve the problems of older buildings or new ones before the law takes effect? No, but it does set a new bar.
Will the requirement for new buildings to have electric-charging parking spots convince existing building owners to offer this modern feature? Will it create a divide between EV-wired and non-EV building dwellers?
Or will it be as logical and beneficial as switching from 8-track tape to digital music streaming, from Super 8 to YouTube.
Will it be as normal and necessary as eliminating cloth wires, banning 1950's, 60s and 70s cancer-causing asbestos, replacing old circuit breakers with modern ones or requiring the installation of a safe, reliable elevator.
While none of us can predict the future, we can do something now.
We can make it required for new buildings and keep finding methods through the law, building maintenance financing, utility subsidies and grants to bring electricity home wherever that may be.
Jonathan Ullman, Director
Sierra Club Santa Barbara-Ventura Chapter