Law and Legislation Committee
Meeting Time: 09-20-22 13:00
eComments Report
Meetings Meeting
Time
Agenda
Items
Comments Support Oppose Neutral
Law and Legislation Committee 09-20-22
13:00
15 4 1 0 1
Sentiments for All Meetings
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Overall Sentiment
Law and Legislation Committee
09-20-22 13:00
Agenda Name Comments Support Oppose Neutral
1. Law and Legislation Log File ID: 2022-00196 1 0 0 0
3. Law and Legislation Committee Meeting Minutes File ID: 2022-01592 1 0 0 0
5. An Ordinance Deleting Chapter 15.30 and Amending Chapter 15.38 of the Sacramento City Code to Adopt Local Amendments to the California Building Standards Code, Relating to New Building Electrification File ID:
2022-01620
2 1 0 1
Sentiments for All Agenda Items
The following graphs display sentiments for comments that have location data. Only locations of users who have commented will be shown.
Overall Sentiment
Agenda Item: eComments for 1. Law and Legislation Log File ID: 2022-00196 Overall Sentiment
David Soohoo
Location:
Submitted At: 10:07pm 09-19-22
My name is Chef David Soohoo. I have a long history helping build our diverse restaurant industry.
I was a Restaurant Industry Representative for our Infeasibility Waiver Technical Panel, to prepare a fair waiver application and process. I was hoping that Sacramento will do outreach, classes, and support our restaurant workers to use electric kitchen appliances.
Instead, Sacramento has copied the Berkeley where the waiver application to use gas is a road block (which we discussed in our Technical Panel Meetings) - there has been only one applicant since January 2020.
Sacramento promised that there will ban an innovation center, to support our local restaurant on how to go electric.
The waiver application is $1,900 to pay for expense of the waiver application. This is NOT TRUE. The actual cost is another $15,000 for attorneys, architects, and engineers to prove infeasibility of electric.
Chinese, API, Mexican, and most ethnic cooking slices ingredients and the breads are flat. Ethnic cooking is very energy frugal, and very little foods are wasted. They work hard hoping to bring a better life to their family.
Our Chinese and ethnic restaurants were promised an innovation center. The Mayor celebrated this on television and the celebration and promise is in our Sacramento Bee newspaper.
Please do not punish our ethnic restaurants with this unjust application high fee of $1,900, and another $15,000 to prove that no electric appliance exists.
Agenda Item: eComments for 3. Law and Legislation Committee Meeting Minutes File ID: 2022-01592 Overall Sentiment
David Soohoo
Location:
Submitted At: 8:10am 09-20-22
The City says that it does not have a qualified Technical Consultant that can objectively determine gas and electric infeasibility, for a waiver. I agree. In all of our Technical Panel meetings, I did not see any API City workers or experts from Frontier, SMUD, or City that has any experience in an ethnic kitchen.
I found that no one knew that ethnic cooking requires high heat to quickly sear sliced foods and flat breads.
Ethnic cooking methods and techniques are energy frugal and very little foods are wasted.
Our Electrification Ordinance is creating a war on our local ethnic restaurants. Once our waiver application is implemented, I do not have the confidence that our review consultant will be fair, Agenda Item: eComments for 5. An Ordinance Deleting Chapter 15.30 and Amending Chapter 15.38 of the Sacramento City Code to Adopt Local Amendments to the California Building Standards Code, Relating to New Building Electrification File ID:
2022-01620
Overall Sentiment
Chris Norem
Location:
Submitted At: 11:15pm 09-19-22
The North State Building Industry Association represents more than 500 member companies building homes in the Sacramento region. We recognize the important role that our industry plays in addressing climate change and would like to be good partners with the City of Sacramento in providing additional housing as well as helping it to achieve Sacramento’s climate action goals.
We would like to suggest technical amendments to the feasibility criteria that would address the concern of availability of new component parts due to ongoing international supply chain shortages, as well as potential cost increases that may develop for consumers once a hard deadline for all electric components is adopted that does not factor in these potential delays.
While a number of builders have already begun the process of shifting over to all-electric construction in advance of state or local standards, the data available to us from SMUD suggests that there is a substantial gap between the current use of all-electric component parts and the potential overall market availability of parts in the City of Sacramento. In 2020, only 230 new housing units were built as all electric in the SMUD service territory, out of a total of more than 6,000 housing units. In 2021 in the City of Sacramento, there were 1,993 apartments built and 1,150 single family homes.
These numbers indicate that it is likely that only between 3-7% of new housing in the City of Sacramento is currently constructed with all-electric components. To comply with the all electric mandate in 2023, builders would need to increase all-electric components by well over 1,000%.
The current feasibility criteria contemplates the unavailability of component parts, but does not contain specificity of timelines or costs that a builder could reasonably rely upon in illustrating infeasibility. As currently drafted, a builder that would have to wait two or even three years for all-electric components would not be exempted because there are no specific timeline criteria. There are also no clear infeasibility criteria on costs in the eventuality that a part manufacturer attempted to charge the builder astronomical sums for parts to comply with the ordinance as drafted.
In seeking a way to phase in the goals of this all-electric ordinance while creating business certainty, the BIA would respectfully request and suggest that the following infeasibility criteria be built into the current criteria such that residential housing will not be subject to the all-electric requirement when:
1. Supply Chain Feasibility
Where a builder or developer can reasonably demonstrate that all-electric home parts required for home sale cannot be acquired from a manufacturer within 120 days of the time of ordering the parts.
2. Grandfathering Clause
a. New subdivisions or planned unit development have existing natural gas infrastructure that is already built or substantially built on January 1, 2023
b. Natural gas infrastructure is assumed for the subdivision, for which architectural master plans have been approved by the City prior to Jan 1, 2023.
3. Cost Feasibility
a. Where a builder or developer can reasonably demonstrate that the cost of providing an all-electric home would add 50% to the cost of the component parts above the costs of installing natural gas appliances, when factoring in cost offsets or rebates from SMUD.
This criteria would be applied on a project by project basis, and reflects what has been adopted by Sacramento County’s Climate Action Plan. Thank you for your consideration.
Sincerely,
Chris Norem
North State Building Industry Association
Rosie Yacoub
Location:
Submitted At: 5:53am 09-19-22
On behalf of 350 Sacramento’s electrification team, I am reiterating some comments relating to the finalization of the New Building Electrification Ordinance and adding some new comments.
City Council and Staff have created a very do-able ordinance that is ready to enact today.
The ordinance impacts only new residences and places of business, which should be cost effective as it is more expensive to develop new buildings that are dual fuel. New gas appliances perpetuate reliance on gas service and lock in all associated GHG emissions for the life of the appliance, unless it is retired early and replaced with an electric alternative, but early retirement of appliances has its own ecological cost.
The ordinance already has categorical exemptions for restaurants and industrial processes, and specifies that these will be re-examined before they are retired. By that time, changes in technology and access to these changes will likely move some construction for businesses towards all-electric even with the exemption. And by that time, more contractors and builders will be doing all-electric buildings as a matter of course. There will be a continued process to apply for waivers, and that process should be reviewed at the same time the categorical waivers will be.
The ordinance should go into effect as approved, starting in 2023. A key strategy the State of CA has identified to reach carbon neutrality by 2045 is to phase out gas usage in the building sector. This means that new gas infrastructure is likely to become a stranded asset: costing the utility more than it will see return during its lifetime.
The maintenance and operational costs associated with new gas infrastructure will need to be paid for by a shrinking number of future gas customers. These customers are likely to be low-income residential customers and others who have either not chosen to or not been able to shoulder upfront costs of electrification. Provisions of the Inflation Reduction Act will help people with the switch to electric appliances, but the New Buidling Electrification ordinance is an important step to take on early to minimize investment in new gas infrastructure, make sure that people living and working in new buildings are not saddled with gas appliances with over 10 year lifetimes, and get started on the path to carbon zero today.
How can the City do better in the future? With the phase out of sales of gas cars by 2035, the City needs to find ways to increase access to EV charging, to support EV adoption by renters. One way to do this is upgrade parking requirements to ensure that all units in multifamily housing that have parking have access to charging, even if that access is to level 1 (standard 120) outlets. Retrofitting electrical for charging is more expensive than building it right the first time. Sacramento should be ahead of the State.
We are glad to see that the City Staff have reduced the minimum square footage for the dual plumbing requirement from 100,000 sq. ft. to 50,000 sq. ft. to support a just transition for Sacramento’s pipefitter professionals. Looking at the report staff brought back, and considering the repeated, prolonged droughts the City has weathered in the last decade, the City should support further research into the feasibility of graywater requirements for single-family residential construction in a future phase. To get better adoption of water conservation measures, the City should consider more thorough outreach about their programs. Also, the City could consider replacing its underutilized ‘laundry to landscape’ rebate program with a program that fully funds laundry to landscape to underserved communities to support tree canopy in these neighborhoods, and contract with unionized pipefitters to do the work. In fact, if there are other aspects of the City’s water conservation program that are underused, they could be similarly re-purposed.