From:
Sent: Monday, June 3, 2024 11:57 AM
To: Distrib- City Clerk <[email protected]> Subject: comment on Consent Calendar Item 4b
Dear San Rafael City Council Members and Staff –
This is to comment on Consent Calendar Item 4b for the June 3, 2024 City Council meeting and to make two requests of San Rafael going forward.
While I am dismayed that the Ninth Circuit Court of Appeals’ decision in California Restaurant Association v. City of Berkeley put all-electric Reach Codes at risk of legal challenge, I would be even more dismayed if that led San Rafael to repeal its all-electric Reach Code.
Please consider instead adopting a resolution to not enforce the all-electric for new buildings Reach Code due to the Ninth Circuit Court’s decision. This would preserve in its Plumbing and Mechanical codes the strong signal that San Rafael WANTS developers to adopt all-electric for new buildings while at the same time shielding the city from legal exposure in the event its Reach Code is challenged.
This suspension of enforcement would only be necessary until BAAQMD’s zero NOx rule for hot water heaters becomes effective January 1, 2027, and for space heaters January 1, 2029 or until a state-wide all-electric for new buildings code is adopted, possibly as early as the 2025 building code cycle. During this interim period it’s critical that we prevent installation of gas infrastructure and equipment in new buildings as such installation will be locking-in the associated GHG emissions for the life of the equipment -- likely twenty years or more!
If San Rafael decides to proceed with repeal of its all-electric for new buildings Reach Code, I respectfully request that the Council direct staff to make a concerted effort to inform applicants that San Rafael strongly desires that new buildings be all-electric in order to reduce GHG emissions, improve public health and safety, and avoid stranded assets. To help ensure the success of this approach, perhaps San Rafael could consider adopting developer incentives such as lower permit fees or enhanced development allowances to encourage developers to go allelectric.
Thank you for your consideration,
Thanks,
Anne-Christine
Anne-Christine Strugnell
“I just want to urge you all to have a good time while you are fighting for freedom.
First of all, we don’t always win, and it might get to be the only fun you’ll ever have.
And second of all, it’s a better way to live.” – Molly Ivins