La
w and Legislation Report
915 I Street, 1st Floor
Sacramento, CA 95814
www.cityofsacramento.org
File ID: 2022-01186 June 21, 2022
T
itle: Climate Related Project Updates: New Building Electrification Ordinance, Existing Building Electrification Strategy, and Onsite Water Reuse Study.
Locat
ion: Citywide
R
ecommendation: Review and comment on: 1) preparation for implementation of the City’s New Building Electrification Ordinance; 2) development of the Existing Building Electrification Strategy; and 3) Onsite Water Reuse and Dual Plumbing Study.
C
ontact: Matt Hertel, Principal Planner, 916-808-7158, [email protected], Laura Tuller, Associate Planner, 916-808-3546, [email protected], Community Development Department; Yvette Rincon, Chief of Staff to the Director of Utilities, 906-808- 1806, [email protected], Department of Utilities P
resenter: Laura Tuller, Associate Planner, 916-808-3546, [email protected], Community Development Department.
A
ttachments:
1-Description/Analysis
2-Background
3-New Building Electrification Ordinance Overview
4-Existing Building Electrification Strategy Analysis Framework 5-Onsite Water Reuse and Dual Plumbing Study Summary
Description/Analysis
Issue Detail: The Community Development Department, with support from various City departments, is working to finalize a public draft of the City’s updated Climate Action and Adaptation Plan (CAAP). A preliminary draft of a stand-alone Climate Action Plan will be released for a 30-day early review on July 1, with the full draft CAAP, 2040 General Plan and Master Environmental Impact Report (MEIR) anticipated for a 45-day review by early Fall 2022. The Community Development Department and the City’s Office of Climate and Sustainability are already implementing key greenhouse gas (GHG) emissions reduction measures from the forthcoming CAAP and identified in the Climate Implementation Work Plan, including three key initiatives, outlined below:
• New Building Electrification Ordinance: Preparation for implementation of the City’s New Building Electrification Ordinance (CAAP Measure E-2) which begins January 1, 2023, for newly constructed buildings that are three stories or less.
• Existing Building Electrification Strategy: Development of the City’s Existing Building Electrification Strategy (CAAP Measure E-3) to transition natural gas use in existing buildings to carbon-free electricity by 2045.
• Onsite Water Reuse and Dual Plumbing Study: Development of an Onsite Water Reuse and Dual Plumbing Study to assess the feasibility and implications of adopting an ordinance that would require certain types of new commercial, non-residential construction to be “pre-plumbed” to allow for the future installation of systems that re- use water onsite.
Attachment 2-Background, includes a summary of each of these initiatives. Staff seeks input from the Law and Legislation Committee on the implementation of these three important climate actions.
Policy Considerations: The 2035 General Plan includes the following key policies related to GHG emission reduction:
ER 6.1.5 Community Greenhouse Gas Reductions. The City shall reduce community GHG emissions by 15 percent below 2005 baseline levels by 2020 and strive to reduce community emissions by 49% percent and 83% percent by 2035 and 2050, respectively.
ER 6.1.7 Greenhouse Gas Reduction in New Development. The City shall reduce greenhouse gas emissions from new development by discouraging auto dependent sprawl and dependence on the private automobile; promoting water conservation and recycling; promoting development that is compact, mixed use, pedestrian friendly, and transit oriented; promoting energy-efficient building design and site planning; improving the jobs/housing ratio in each community; and other methods of reducing emissions.
On November 12, 2019, Council adopted the Vision and Guiding Principles for the forthcoming 2040 General Plan and Climate Action Plan Update. This document includes the commitment to take bold action to achieve carbon neutrality by 2045 and become a leading voice in the effort to reduce greenhouse gas emissions and adapt to climate change. New GHG emission reduction targets, GHG reduction measures and actions are being developed as part of the 2040 General Plan and Climate Action Plan Update.
Economic Impacts: Electrification, water conservation and sustainable infrastructure are anticipated to bring new labor demands and workforce development needs. The new building electrification ordinance is anticipated to reduce construction costs for residential development and increase demand for climate friendly appliances. It is anticipated that the economic impacts of implementing an existing building electrification strategy would be incremental costs of electric appliances and reduced overall utility bills over time.
Environmental Considerations:
California Environmental Quality Act (CEQA): City Council rules of procedure generally require that all proposals for ordinances must be reviewed by the Law and Legislation Committee prior to Council review and adoption. This update to the Law and Legislation Committee is not itself a project under the California Environmental Quality Act (CEQA) because it is a request for input as an administrative activity that will not result in any direct or indirect physical change in the environment. (CEQA guidelines section 15378(b)(5).) Environmental review pursuant to CEQA will be conducted prior to any adoption of an ordinance.
Sustainability: It is anticipated that the projects described in this report will have a net positive environmental impact because they will promote water conservation and reduce GHG emissions and other pollution associated with fossil fuel combustion from gas heating systems, stoves, water heaters, and other appliances.
Commission/Committee Action: None.
Rationale for Recommendation: The items in this report are updates on projects directed by City Council through Resolution 2021-0166, the City’s Climate Implementation Work Plan and the forthcoming Draft Climate Action and Adaptation Plan.
Financial Considerations: Not applicable.
Local Business Enterprise (LBE): Not applicable.
Background
New Building Electrification Ordinance
On June 1, 2021, the Sacramento City Council adopted the New Building Electrification Ordinance (Ordinance) which established the regulatory framework and timeline for requiring all-new electric development (Attachment 3-New Building Electrification Ordinance Overview).
The New Building Electrification Ordinance requires:
• Building permit applications filed on or after January 1, 2023, for newly constructed buildings that are three stories or less to be all-electric buildings. • Building permit applications filed on or after January 1, 2026, for newly constructed buildings that are four stories or more to be all-electric buildings.
The N
ew Building Electrification Ordinance includes specific limited exemptions for building permit applications filed on or before December 31, 2025:
• A limited exemption for ground floor food establishments for cooking equipment only. • A limited exemption for manufacturing process loads only within a manufacturing or industrial facility.
• A limited exemption for regulated affordable housing where virtual net energy metering is not available, for water heating only. (Since adoption of the Ordinance, SMUD has established the Virtual Solar program, and therefore this limited exemption will no longer be required.)
Infeasibility Waiver Guidance Technical Panel and Guidance Document Since ordinance adoption and per council direction, City staff have convened an advisory technical panel tasked with vetting barriers where technologies are not yet market-ready for electrification and providing input on an Infeasibility Waiver Guidance Document. The technical panel includes 14 representatives of stakeholder groups as approved by City Council on June 1, 2021. Four technical panel meetings have been held to-date. The technical panel will meet next on July 18
th to review the initial draft Infeasibility Waiver Guidance Document. City staff expect adoption of the final Infeasibility Waiver Guidance Document in Fall 2022, prior to the effective date of the Ordinance.
Next Steps
The City’s New Building Electrification Ordinance is a local amendment to the California Building Standards Code (CBSC). The CBSC is on a three-year cycle with the 2022 CBSC to be released on July 1, 2022, and effective January 1, 2023. The City is required to adopt the New Building Electrification Ordinance again as a local amendment to the 2022 CBSC.
Therefore, staff will be returning to the Law & Legislation Committee and the City Council in the coming months for consideration of the Ordinance, including on August 16, 2022, for review and comment on the framework and timeline for the Ordinance.
Existing Building Electrification Strategy
On June 1, 2021, the Sacramento City Council adopted Resolution 2021-0166 which directed staff to develop an Existing Building Electrification Strategy (Strategy) to transition the City’s existing buildings to carbon-free electricity by 2045. The following components of the Strategy have been completed:
• Community Engagement Plan: Serves as a roadmap for public and stakeholder engagement for the Strategy.
• Analysis Framework: Analysis Framework has been developed, including draft Equity and Effectiveness Criteria to ensure that all policies included in the strategy are feasible and achieve equitable outcomes for residents, businesses, and stakeholders during the electrification process. The full Analysis Framework is included as Attachment 4- Existing Building Electrification Strategy Analysis Framework. • Stakeholder Meetings: To date, several virtual workshops, two in person workshops, and one virtual community-wide workshop, as well as focused meetings with key stakeholders have been held.
Next Steps
• Residential Building Inventory and Energy Modeling: City staff, with support from consultants and SMUD, are conducting energy analysis using Sacramento-specific residential data through Vistar Energy’s (Vistar) XeroHome™ application. The modeling exercise will allow the City to identify the long-term cost savings associated with the replacement of individual appliances for Sacramento residents and businesses. The energy analysis will also be used to identify and evaluate the various policy pathways to be included in the final strategy document.
• Ex isting Building Electrification Draft Policies: During the Spring and Summer of 2022, the team will develop a set of existing building electrification draft policies that meet the equity and effectiveness criteria developed with community members during phase one outreach. Staff will bring these draft policies to the community during phase two outreach and will revise them into the final Existing Building Electrification Strategy document for implementation. The final Strategy will be used to move the City towards a clean energy future and achieve the goals sets forth in the CAAP.
The Existing Building Electrification Strategy is anticipated to come before City Council for consideration by the end of 2022.
Onsite Water Reuse and Dual Plumbing Study
California is in a historic drought period, with the state experiencing the driest winter months in 2021/22 in over 100 years. While the state has experienced drought historically, the impacts of climate change are projected to increase the intensity and frequency of droughts through 2050, even if global GHG emissions are drastically reduced and eliminated in the coming decades.
On June 1, 2021, City Council adopted a Resolution No. 2021-0166 establishing a framework for existing building electrification and directing staff to the evaluate water conservation policies that could conserve water while promoting green job opportunities. City staff are conducting a study to assess the feasibility of requiring certain types of new commercial, non-residential construction to be “pre-plumbed” to allow for the future installation of systems that re-use water onsite. The results of the study will be used to inform a potential new dual-plumbing ordinance that could go into effect by January 1, 2023, to align with the first effective date of the New Building Electrification Ordinance.
In January 2022, the City contracted with a consultant team to evaluate the feasibility of implementing a dual plumbing system program as well as support preparation of an ordinance requiring dual plumbing in new commercial (non-residential) developments for future installation of onsite non-potable water reuse systems. The study is being conducted as joint effort between the Community Development Department and the Department of Utilities.
The Onsite Water Reuse and Dual Plumbing Study consists of two phases:
• Phase One: Dual Plumbing Feasibility Study and Dual Plumbing Ordinance Recommendations
• Phase Two: Onsite Water Treatment Feasibility Study
Staff have received an administrative draft of the phase one study, which includes regulatory, technical, and economic considerations for implementing a potential dual plumbing ordinance.
Three case studies have been developed (San Francisco, Santa Monica, Honolulu) to better understand the technical and administrative requirements of developing and implementing a program, and preliminary cost modeling has been developed to identify the costs of installing dual plumbing and onsite water treatment systems. Phase two of the study, tentatively scheduled for 2024, will review the compliance with state mandated SB 966 requirements and related operational needs of establishing an onsite water reuse program in Sacramento. Initial findings of the draft phase one study are included in Attachment 5- Onsite Water Reuse and Dual Plumbing Study Summary.
Next Steps
City staff have received the administrative draft of the phase one study and anticipate a draft for public reviewing being available in July 2022. Staff anticipate returning to the Law and Legislation Committee in July 2022 with full study results and preliminary options and recommendations. Prior to the July Law and Legislation Committee, staff will be meeting with U.A. Local 447 Plumbers, Pipefitters, Refrigeration Fitters and Service Technicians and other stakeholder groups to discuss the results of the study, answer questions, and get feedback.
The Sacramento City Council adopted the New Building Electrification Ordinance on June 1, 2021. The Ordinance is a “reach code”, which is a local building code requirement that “reaches” beyond California Building Code minimum requirements. The Ordinance supports the City’s climate goals by reducing greenhouse gas emissions and air pollution from fossil fuel combustion within buildings by requiring new buildings to be constructed as all-electric. Existing buildings (room additions, remodels, tenant improvements, etc.) will not be affected by the Ordinance.
The effective dates for t he New Building Electrification Ordinance are as follows:
• New buildings which are 1-3 stories: January 1, 2023 • New buildings which are 4- stories or more: January 1, 2026 The Ordinance provides specific limited exemptions until December 31, 2025, for:
• Manufacturing process loads within industrial or manufacturing facili ties. • Cooking equipment in ground- floor food establishments. • Water heating in regulated affordable housing projects when virtual net energy metering is not available.
There is no additional application process for the three limited exemptions listed above. The Ordinance also provides for an infeasibility waiver process that will not have a s unset date. The infeasibility waiver process will provide flexibility for projects where all -electric is shown to be infeasible by the applicant.
As part of the preparation for implementing the New Building Electrification Ordinance the City is convening in early 2022 an advisory technical panel that is tasked with vetting barriers where technologies are not yet market -ready for electrification and providing input on an infeasibility waiver guidance document for electrifying new construction. The infeasibility waiver guidance document will be adopted by City Council prior to the January 1, 2023 effective date.
All electric construction is feasible and cost effective in most cases , but to avoid unintended consequences, project applicants are advised to plan their projects as all -electric from the beginning.
The adopted Ordinance, topic -based building electrification webinars, an extensive Electrification Ordinance Q&A , and other resources can be found on the New Building Electrification project webpage at:
http://www.cityofsacramento.org/SacElectrificationOrdinance For information on the development of an existing building el ectrification strategy , visit the project webpage at:
http://www.cityofsacramento.org/SacExistingBuildingElectrification .
Rincon Consultants, Inc.
4 8 25 J S t r e e t , S u i t e 2 0 0
Sacramento, California 95819
916 7 0 6 13 7 4
i n f o @ r in c on c o n su l t a n t s . c o m
w w w . r i n c o n c o n s u l t a n t s . c o m
E n v i r o n m e n t a l S c i e n t i s t s P l a n n e r s E n g i n e e r s 3/18/2022
Project No: 21-11723
Laura Tuller
Associate Planner
City of Sacramento | Community Development Department
300 Richards Blvd. Sacramento CA 95811
O: (916) 808-3546 C: (650) 521-3159
Subject: Analysis Framework Memo
Sacramento Existing Building Electrification Strategy
Dear Ms. Tuller:
This Analysis Framework Memo outlines the proposed framework for development of the Sacramento Existing Building Electrification Strategy (EBES) policy pathways and actions. The proposed framework includes:
▪ Draft organizational structure for the electrification actions, which breaks down the existing building electrification goal of the EBES into implementable programs, policies, and procedures ▪ Draft electrification benefits, which will be used to drive the project’s messaging during outreach and engagement and relate to existing building electrification in general ▪ Draft equity criteria that will ensure each initiative is implemented in an equitable manner ▪ Draft effectiveness criteria, which will ensure the electrification actions are feasible and effective The contents of this memo are meant to be an initial draft for the City’s consideration and feedback.
Once further developed, the draft electrification benefits, equity criteria, and effectiveness criteria are intended to be shared with the community as part of the project’s outreach and engagement effort (under project task 2.1). Outreach and engagement will solicit feedback to inform expansion, re- development, and finalization of the criteria. The initial list of electrification actions developed under Task 1.4 will then be screened against the equity and effectiveness criteria in accordance with the organizational structure to meet the final effectiveness criteria (as part of project tasks 2.2 and 2.3).
Electrification Actions Organizational Structure
The EBES will focus on existing building electrification in the residential and nonresidential sectors. To define the structure and vocabulary associated with the EBES electrification actions up-front, Rincon proposes that the EBES be organized around specific policy pathways and actions for both residential and nonresidential buildings. The structure of the overall electrification strategy will be organized in the following way:
▪ Cross Cutting Actions are those actions that support electrification across sectors and could include education and outreach programs, facilitation of financing options, contractor training, and coordination with stakeholders.
City of Sacramento
Existing Building Electrification Strategy
▪ Policy Pathways identify the high-level policy levers for building electrification that together make up the City’s electrification strategy. Example policy pathways include requiring electrification retrofits at time-of-burnout or establishing building performance standards. ▪ Actions identify the component programs, policies, financial solutions, community engagement, and other commitments that together will make the parent policy pathway equitable and feasible. Each group of actions that support a policy pathway will collectively address the potential hurdles to successful policy implementation: equity impacts, community education gaps, funding gaps, and other specific effectiveness gaps identified during project outreach.
The organizational structure will ensure an organized and easily understandable framework for the Sacramento EBES. Organizing electrification actions in this way will ensure that each policy pathway in the residential and nonresidential sectors are supported by a comprehensive set of concrete, implementable, and specific actions tailored to both building types.
Electrification Benefits
Electrifying existing buildings is expected to produce many positive outcomes in Sacramento.
Communicating these positive outcomes during outreach and engagement requires identification of the important benefits the community will see as a result of the EBES . The initial draft list of electrification benefits proposed for the City’s consideration are:
▪ Health: Commonly used appliances that burn gas, including stoves, heating systems, and water heaters, emit hazardous air pollutants inside a home when improperly ventilated, or when leaks occur. These can include nitrogen oxides, sulfur oxides, carbon monoxide, formaldehyde, particular EBES
Cross Cutting
Actions
Residential
Electrification
Policy Pathway
A
Actions
Policy Pathway
B
Actions
Nonresidential
Electrification
Policy Pathway
C
Actions
Policy Pathway
D
Actions
City of Sacramento
Existing Building Electrification Strategy
matter and other harmful pollutants that increase the risk of respiratory disease.1,2,3,4 Health impacts related to cooking with gas appliances in particular can be serious, but are generally not widely understood by consumers.5 Peer reviewed studies have documented that residences with gas stoves have 50 to 400% higher average nitrogen dioxide concentrations than homes with electric stoves.6 Living in a home with a gas stove may increase children’s risk of asthma by 42%.7 Given that Californians spend 70% of a given day indoors,8 and potentially more given the context of the COVID pandemic, indoor air quality is an important health consideration for many. Gas usage in buildings causes outdoor air pollution as well and has generated six times more nitrogen oxides emissions than all in-state power plants combined.9 Outdoor air pollution from buildings has been linked to pre-mature deaths in California.10
▪ Safety: Gas infrastructure carries an inherent safety risk due to the volatile nature of gas, including risk of methane leakage, damage during earthquakes, accidental explosions, or fires. Nationwide, gas ignites over 4,000 home structure fires annually, causing on average 40 deaths and $54 million in property damage each year.11
▪ Energy Affordability: Gas infrastructure costs are expected to increase over the next several decades as more substantial infrastructure upgrades are required. The California Public Utility Commission generally allows each gas utility to increase gas rates based on the necessary
1 Krasner, A., Jones, T. S., & La Rocque, R. (2021). Cooking with Gas, Household Air Pollution, and Asthma: Little Recognized Risk for Children. Journal of Environmental Health, 83(8), 14-18. https://www.proquest.com/scholarly- journals/cooking-with-gas-household-airpollution-asthma/docview/2505418593/se-2?accountid=201395. 2 Seals, B., & Krasner, A. (2020). Health Effects from Gas Stove Pollution. Rocky Mountain Institute, Physicians for Social Responsibility, Mothers Out Front, and Sierra Club. https://rmi.org/insight/gasstoves-pollution-health. 3 4 Zhao, H., Chan, W. R., Cohn, S., Delp, W. W., Walker, I. S., & Singer, B. C. (2020) Indoor air quality in new and renovated low-income apartments with mechanical ventilation and natural gas cooking in California. International Journal of Indoor Environment and Health, 31(3), 717-729. https://doi.org/10.1111/ina.12764. 4 Logue, J. M., Klepeis, N. E., Lobscheid, A. B., & Singer, B. C. (2014) Pollutant exposures from natural gas cooking burners: A simulation-based assessment for Southern California. Environmental Health Perspectives, 122(1), 43-50. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3888569/.
5 Nicole, Wendee. (2014). Cooking up Indoor Air Pollution: Emissions from Natural Gas Stoves. Journal of Environmental Health Perspectives, 122(1). https://doi.org/10.1289/ehp.122-A27. 6 U.S. EPA. Integrated Science Assessment (ISA) for Oxides of Nitrogen – Health Criteria (Final Report, Jul 2008).
U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-08/071, 2008. https://cfpub.epa.gov/ncea/isa/recordisplay.cfm?deid=194645. 7 Weiwei, L., Brunekreef, B., & Gehring, U. (2013). Meta-analysis of the effects of indoor nitrogen dioxide and gas cooking on asthma and wheeze in children. International Journal of Epidemiology, 42(6), 1724–1737. https://doi.org/10.1093/ije/dyt150.
8 Klepeis, N. E., Nelson, W. C., Ott, W. R., Robinson, J. P., Tsang, A. M., Switzer, P., ... & Engelmann, W. H. (2001).
The National Human Activity Pattern Survey (NHAPS): a resource for assessing exposure to environmental pollutants. Journal of Exposure Science & Environmental Epidemiology, 11(3), 231-252. 9 California Air Resources Board. 2016 SIP Emission Projection Data: 2012 Estimated Annual Average Emissions. https://www.arb.ca.gov/ei/emissiondata.htm
10 Dedoussi, I. C., Eastham, S. D., Monier, E., & Barrett, S. R. (2020). Premature mortality related to United States cross-state air pollution. Nature, 578(7794), 261-265.
11 Ahrens, M. & Evarts, B. (2018). Natural Gas and Propane Fires, Explosions and Leaks Estimates and Incident Descriptions. NationalFire Protection Association. https://www.nfpa.org/-/media/Files/News-and-Research/Fire- statistics-and-reports/Hazardousmaterials/osNaturalGasPropaneFires.
City of Sacramento
Existing Building Electrification Strategy
expenditure to keep gas systems operational. Increased utility expenditures on the gas system are therefore expected to lead to escalating consumer costs that will likely impact low-income households significantly.12 Without any building electrification or renewable gas use, the cost of natural gas is expected to double from approximately $1.5 per therm to $3 per therm by 2050.13 These projected increases are already being seen in Sacramento, with 2022 winter gas prices 90% higher than 2021.14 Upgrading buildings to all-electric is also an opportunity to complete other building upgrades such as air sealing and insulation, which can reduce energy costs and improve affordability.
▪ Resilience: When coupled with solar and battery energy storage, all-electric buildings can mitigate impacts of power outages. While many people think having gas appliances provides a redundant system during power outages, gas appliances like water heaters, stoves, and space heaters typically cannot function without electricity to power the fans and controls needed for operation. Clean back- up power is therefore an important asset when the utility grid is down. More local solar and battery storage is also good for grid resilience in the region. Electrification provides an opportunity for increased investment in the electrical grid and improved local resiliency in a safe and healthy way.
For example, pairing heat pump HVAC units with good air filtration and home weatherization can protect residents from wildfire smoke during fires.
▪ High-road Local Jobs: New electrification policies and requirements support opportunities for new local jobs and existing local businesses in construction, building trades, and the “clean and green” economy, key components of the City’s economic development strategy. ▪ Greenhouse Gas Reduction: Gas usage in buildings accounted for 14% of the City of Sacramento’s greenhouse gas (GHG) emissions in 2016.15 The proportion of emissions coming from gas is projected to increase to 30% by 2030 as the emissions from electricity go to near zero due to SMUD’s commitment to provide 100% GHG-free electricity to the community by 2030.16 This means that any appliance converted from gas to electric will have GHG-free operation in 2030. SMUD already provides 72% GHG-free electricity City-wide. Reducing GHG emissions in Sacramento will contribute to the City’s General Plan and Climate Action and Adaptation Plan goals to reduce per capita emissions 63% by 2030.17
12 3 Energy and Environmental Economics, Inc. (2020). The Challenge of Retail Gas in California’s Low-Carbon Future. California Energy Commission. https://www.energy.ca.gov/sites/default/files/2021-06/CEC-500-2019-055- F.pdf
13 Gridworks. (2019). California’s Gas System in Transition: Equitable, Affordable, Decarbonized and Smaller. https://gridworks.org/wp-content/uploads/2019/09/CA_Gas_System_in_Transition.pdf 14 Morales, Caroline. (2022). Here’s why your PG&E gas bill might be high this month. https://www.abc10.com/article/news/local/sacramento/heres-why-your-pge-gas-bill-is-high-this-month/103- b1bb2f2e-4a95-4ef1-af92-cbc4bbb65afd
15 Quantification of GHG emissions from gas in Sacramento's buildings has been conducted as part of the City’s Climate Action and Adaptation Plan effort. The plan has not yet been formally adopted by the City, but Council is anticipated to adopt the plan in spring 2022. The GHG emissions from gas usage in buildings cited here does not include methane leakage.
16 On April 28, 2021, SMUD’s Board of Directors adopted the 2030 Zero Carbon Plan, which establishes the commitment to zero carbon for SMUD’s energy resources by 2030. 17 A 63% reduction below 1990 levels by 2030 is the City’s proposed Climate Action and Adaptation Plan target as of the time of preparing this document. Final Council action is anticipated in spring 2022.
City of Sacramento
Existing Building Electrification Strategy
Equity Criteria
In the Council-adopted Framework for the Electrification of Existing Buildings in the City of Sacramento (Framework),18 the City established a vision of achieving a zero-emission building stock by first ensuring a collaborative and just decarbonization transition. The key equity components of the Framework’s goals and objectives are minimizing the cost-burden and displacement risk to frontline communities; prioritizing financial assistance and access to health, safety, and cost benefits for those most in need; and engaging these communities in the electrification process. To operationalize these goals and objectives, the City plans to develop specific equity criteria that align with the needs of Sacramento’s frontline communities and small local businesses. The equity criteria will be used to concretely evaluate the EBES’ policy pathways for alignment with the Framework’s goals and objectives. The equity criteria provide standards that must be met for any policy pathway and its supportive actions to be considered for inclusion in the EBES. As policy pathways and their associated actions are evaluated against the equity criteria, potential risks and unintended impacts, or equity gaps, may be exposed and additional actions can be incorporated into the policy pathways to address these issues. Every policy pathway must be able to pass the equity criteria analysis in order to be included in the EBES. Those policy pathways which do not pass the equity criteria must be supplemented by specific actions that address the equity gap or be removed from the EBES.
The initial draft of the equity criteria proposed for the EBES for the City’s consideration are included below, but should be updated based on feedback gained through community outreach and engagement, especially with feedback from renters, disadvantaged communities, and small local businesses. Every policy pathway included in the EBES must:
▪ Ensure Equitable Access to Health, Safety, and Comfort Benefits: Ensure renters19 and environmental justice communities have equitable access to the health, safety, and comfort benefits from building electrification, like improved indoor air quality and cooling for hot days for both homeowners and renters.
▪ Ensure Equitable Access to Concurrent Housing Condition Improvements: Ensure that low-income communities have equitable access to solar installation, energy efficiency, building envelope upgrades, and lead and asbestos abatement at the time that electrification retrofits occur.
Electrification of a building provides opportunities for other whole-building improvements that may come with additional up-front costs but would otherwise be more expensive to implement separately. These opportunities for concurrent whole-building improvements should be financially accessible for low-income populations.
18 Accessed at: https://www.cityofsacramento.org/-/media/Corporate/Files/CDD/Planning/Major- Projects/Electrification-of-New-Construction/R20210166-Framework-for-Building-Electrification-and-the- Evaluation-of-Water-Conservation--Green-Job.pdf?la=en
19 It is expected that renters will need financial support for access to high-quality upgrades and the benefits of electrification due to the “split incentive” issue of building electrification in rental units. The split incentive between property owners and renters refers to the issue that renters may want to experience the benefits of electrification but do not own the building and therefore, may not experience the benefits of electrifying long term and have reduced incentive to electrify. On the other hand, because property owners will not experience the benefits of electrification themselves, they also have reduced incentive to electrify.
City of Sacramento
Existing Building Electrification Strategy
▪ Advance Energy Equity: Ensure that building electrification supports access to affordable energy for all community members, especially disadvantaged communities, renters, and small businesses. This includes affordable utility bills, equitable access to affordable funding and financing mechanisms for electrification, and the agency to avoid increasing future natural gas prices. ▪ Ensure Equitable Access to High-Road Job Opportunities: Ensure disadvantaged communities have access to fairly paid high-road training and job opportunities as a result of increased need for an electrification-trained workforce.
▪ Maximize Ease of Installation: Ensure that incentives and programs for the community create meaningful support to renters and disadvantaged communities and include a simple process that minimizes the burdens and impacts associated with the installation of high-quality electric equipment.
▪ Promote Affordable Housing and Anti-Displacement: Ensure electrification upgrades do not displace renters, result in increased rents, or over-burden homeowners. Programs should support housing production, housing preservation, and tenant protections. Programs should also protect against displacement of small local businesses and organizations.
Effectiveness Criteria
In addition to being equitable, the EBES must be effective. Broader “effectiveness criteria” are used in addition to the equity criteria to ensure that the benefits of electrification are fully realized and do not come at the cost of other City priorities and projects and do not harm residents and business owners.
Similar to the application of the equity criteria, policy pathways and their associated actions will be evaluated against the effectiveness criteria to identify and prevent gaps in the electrification approach.
Each policy pathway should include at least one action that directly addresses each of the effectiveness criteria. The initial draft of the effectiveness criteria proposed for the EBES for the City’s consideration are:
▪ Cost-effective: Ensure that costs associated with new requirements are minimized or offset through funding and financing strategies for residents and business owners and efficiently use limited City, SMUD, and other resources.
▪ Programmatic Feasibility: Ensure that electrification policies effectively reflect the most up-to-date electrification practices and regulatory requirements.
▪ Measurable and Sustained Impact: Ensure that electrification policies are impactful and will provide evidence-based results over the long-term.
▪ Technological and Regulatory Feasibility: Ensure that new technologies or upgrades considered for electrification retrofits are technologically feasible to implement on a city-wide scale and do not interfere or counteract regional or state regulations promoting building electrification. ▪ Energy Security: Ensure that energy security is preserved or improved throughout the community in the long-term.
Conclusion and Next Steps
As part of the analysis framework development process, Rincon requests that the City of Sacramento review the proposed draft framework to identify changes or additions that should be made to meet the City of Sacramento
Existing Building Electrification Strategy
needs of the Sacramento community. Updates to the electrification benefits and effectiveness criteria will be shared during future community engagement events and efforts associated with development of the EBES, and community feedback on the effectiveness criteria will be requested as part of that effort.
Upon receipt of community feedback, the effectiveness criteria will be finalized and utilized to evaluate, modify, and improve the equity and effectiveness of the initiatives and actions to be included in the EBES.
Dual Plumbing and Onsite Water Reuse Study Summary
The Dual Plumbing and Onsite Water Reuse Study is a two phased effort. The first phase summarizes the feasibility of implementing dual plumbing systems in Sacramento for the future purpose of reusing non- potable water onsite in certain types of commercial nonresidential new construction (100,000 square feet or larger). Phase two will review compliance with state mandated SB 966 requirements (effective December 1, 2022), related operational responsibilities, system protection requirements, and cost and funding impacts for onsite non-potable water treatment systems. This summary outlines the results of phase one of the study including various options for a potential Dual Plumbing Ordinance.
Regulatory Considerations
• Dual plumbing systems are regulated by the California Plumbing Code (CPC) and the Department of Water Resources Division of Drinking Water. The City of Sacramento could adopt a dual plumbing ordinance consistent with the CPC, but additional processes would be required for onsite non potable water systems (ONWS) to meet treatment and water quality standards. • There are currently no statewide regulations in California regarding ONWS, but draft regulations are being developed and expected to be adopted by December 1, 2022 in accordance with SB 966.
• Amendments to the local Water Reclamation Permit with the Central Valley Regional Water Quality Control Board would be required before indoor non-potable end uses of recycled water could be allowed in the City of Sacramento.
Technical Considerations
• Implementation of dual plumbing and ONWS is dependent on source water and end uses of the system.
o Potential sources that could provide water for reuse: rainwater, stormwater, greywater (wastewater from clothes washing, bathroom sinks, etc.), blackwater (wastewater from toilets, dishwashers, kitchen sinks, and utility sinks), condensate (condensed water from air conditioning equipment), and foundation drainage.
o Potential end uses that could repurpose water treated onsite: toilet and urinal flushing, landscape irrigation, equipment cleaning, cooling systems.
Economic Considerations
• There is an added cost to installing dual plumbing systems. Some of this cost would be offset with savings from buildings being all electric (not requiring gas infrastructure). • Costs of ONWS (treatment and operations) are highly variable depending on source water and end uses.
• There would be an added cost to the City to administer the program. • Since 2010, 13 commercial, non-residential buildings have been constructed in Sacramento that are larger than 100,000 square feet, falling above the potential development threshold the City is considering for onsite water reuse.
Figure: Cost Per Area ($/SF) to Add Dual Plumbing to Commercial Buildings
Figure: Percent Increase to Total Project Cost to Add Dual Plumbing to Commercial Buildings
Dual Plumbing Ordinance – Potential Options
Kennedy Jenks outlined five potential ordinance development options for staff consideration.
1. Adopt a local dual plumbing ordinance which allows new buildings to voluntarily install dual plumbing with or without a non-potable water source.
2. Adopt a dual plumbing ordinance requiring new buildings within the vicinity of existing and planned Sacramento Regional County Sanitation District pipelines and meeting other eligibility criteria to install dual plumbing and connect to municipal recycled water when it becomes available.
3. Adopt a dual plumbing ordinance requiring all new buildings meeting the eligibility criteria (commercial non-residential, 100,000 square feet or greater*) to install dual plumbing. After the state adopts water quality standards, the City can then incorporate these standards for buildings to collect, treat, and re-use water onsite.
4. Adopt a dual plumbing ordinance requiring all new buildings meeting eligibility criteria (commercial non-residential, 100,000 square feet or greater) to also install ONWS or connect to municipal recycled water.
5. Do not adopt a Dual Plumbing Ordinance at this time. Continue to develop the City’s Onsite Water Reuse Strategy with the intent of adopting a dual plumbing ordinance in the future.
*Staff are also considering other factors, such as building use type and density of plumbing fixtures, as potential criteria for program eligibility.