Agenda packet, first session — Santa Monica City Council, September 10, 2024 (part 3 of 4)

City Council Meeting: September 10, 2024 Santa Monica, California ORDINANCE NUMBER _________ (CCS)
(City Council Series)

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF SANTA MONICA AMENDING MUNICIPAL CODE SECTION 4.08.095 PROHIBITION AGAINST

CAMPING IN PUBLIC PLACES
WHEREAS, in 2022, the City of Santa Monica amended Municipal Code Section

4.08.095 to comply with the Ninth Circuit Court of Appeals ruling in Johnson v. City of Grants Pass, which required public entities to allow the homeless to sleep on public property, with certain conditions and exceptions; and
WHEREAS, the U.S. Supreme Court recently reversed the Ninth Circuit ruling, and held that regulation of sleeping/camping in public should largely be deferred to local jurisdictions; and
WHEREAS, the Council desires to amend the Municipal Code to repeal the amendments made in 2022.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF SANTA MONICA DOES HEREBY ORDAIN AS FOLLOWS:

SECTION 1. Section 4.08.095 of the Santa Monica Municipal Code is hereby amended as follows:

4.08.095 Prohibition against camping in public places.
(a) No person shall camp in a prohibited public place.
(b) For the purpose of this Section:
(1) “Camp” means to erect, maintain, or occupy a camp facility for the purpose of living accommodations.
(2) “Camp facility” means the use of, settling, fixing in place, setting up,

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Packet Pg. 417 Attachment: ORD-CAO-Camping 091024 (6596 : Camping Ordinance)

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locating, or leaving behind in a prohibited public place any or a combination of the following: tents, huts, other temporary physical shelters, cots, beds, sleeping bags, or hammocks, or bedrolls.
(3) “Prohibited public place” means any of the following: the public parks listed in Section 4.55.020, public beaches, the Santa Monica Municipal Pier, public streets, public alleyways, public parking lots, public passageways, public rights-of-way, publicly-owned landscaped areas or greenbelts, public educational institutions including properties owned by the Santa Monica-Malibu Unified School District or Santa Monica College, or other government-owned properties located within the City of Santa Monica.
(c) The City Council may, by majority vote, establish one or more specified camping areas. Such camping areas, if any, may be located in prohibited public places, except that such camping areas shall not be located within public parks. (d) This ordinance does not prohibit those who are homeless from using sleeping bags, blankets, pillows, and/or bedrolls while sleeping.

SECTION 2. Any provision of the Santa Monica Municipal Code or appendices thereto inconsistent with the provisions of this Ordinance, to the extent of such inconsistencies and no further, are hereby repealed or modified to that extent necessary to effect the provisions of this Ordinance.

SECTION 3. If any section, subsection, sentence, clause, or phrase of this Ordinance is for any reason held to be invalid or unconstitutional by a decision of any court of competent jurisdiction, such decision shall not affect the validity of the remaining portions of this Ordinance. The City Council hereby declares that it would have passed this Ordinance and each and every section, subsection, sentence, clause, or phrase not declared invalid or unconstitutional without regard to whether any portion of the ordinance would be subsequently declared invalid or unconstitutional.

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SECTION 4. The Mayor shall sign and the City Clerk shall attest to the passage of this Ordinance. The City Clerk shall cause the same to be published once in the official newspaper within 15 days after its adoption. This Ordinance shall become effective 30 days from its adoption.

APPROVED AS TO FORM:
_________________________
Douglas Sloan, City Attorney

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Packet Pg. 419 Attachment: ORD-CAO-Camping 091024 (6596 : Camping Ordinance) Current City Ordinances. Applicable current Santa Monica City ordinances:
§ 4.08.093 Penalties.

Any persons violating the provisions of Sections 4.08.094 through 4.08.095 shall be guilty of a misdemeanor and upon conviction shall be fined in an amount not to exceed five hundred dollars or imprisoned for a period not to exceed six months, or both. In the case of a person who is granted probation for repeated violation of any offense under Sections 4.08.094 through

4.08.095, the court may issue, or direct the issuance of, an injunction or "stay away" order to abate and prevent the continuance or recurrence of such violation. § 4.08.095 Prohibition against camping in public places. (a) No person shall camp in a prohibited public place.
(b) For the purpose of this Section:
(1) “Camp” means to erect, maintain, store, or occupy a camp facility for the purpose of living accommodations.
(2) “Camp facility” means the use of, settling, fixing in place, setting up, storing, locating, or leaving behind in a prohibited public place any or a combination of the following: tents, huts, other temporary physical shelters, cots, beds, or hammocks. (3) “Prohibited public place” means any of the following: the public parks listed in Section

4.55.020, public beaches, the Santa Monica Municipal Pier, public streets, public alleyways, public parking lots, public passageways, public rights-of-way, publicly-owned landscaped areas or greenbelts, public educational institutions including properties owned by the Santa Monica-Malibu Unified School District or Santa Monica College, or other government-owned properties located within the City of Santa Monica.
(c) The City Council may, by majority vote, establish one or more specified camping areas.

Such camping areas, if any, may be located in prohibited public places, except that such camping areas shall not be located within public parks. (d) This Section does not prohibit those who are homeless from using sleeping bags, blankets, pillows, and/or bedrolls while sleeping.
§ 4.08.097 Prohibition against sitting or lying in doorways at night. (a) No person shall sit or lie down in any entrance to a building in the downtown, Main Street,

8.A.b
Packet Pg. 420 Attachment: Existing Santa Monica Ordinances (6596 : Camping Ordinance) Broadway, Colorado Avenue, Lincoln Boulevard, Pico Boulevard, Santa Monica Boulevard, and Wilshire Boulevard areas between the hours of eleven p.m. and seven a.m. if that entrance is posted with a sign prohibiting such conduct.
(b) As used in this Section, the following items shall have the following meanings:
(1) “Downtown” means the area bounded by and including the west side of Ocean Avenue, the north side of Wilshire Boulevard, the east side of Lincoln Boulevard, and the south side of Pico Boulevard.
(2) “Main Street area” means the area bounded by and including the west side of Neilsen Way, the north side of Pico Boulevard, the east side of Main Street from Pico Boulevard to Strand Street, the north side of Strand Street to Second Street, the east side of Second Street and the City's southern border.
(3) “Broadway” means the area bounded by the west side of Ocean Avenue and the City's eastern border.
(4) “Colorado Avenue” means the area bounded by the west side of Ocean Avenue and the City's eastern border.
(5) “Lincoln Boulevard” means the area bounded by the north side of Wilshire Boulevard and the City's southern border.
(6) “Pico Boulevard” means the area bounded by the west side of Ocean Avenue and the City's eastern border.
(7) “Santa Monica Boulevard” means the area bounded by the west side of Ocean Avenue and the City's eastern border.
(8) “Wilshire Boulevard” means the area bounded by the west side of Ocean Avenue to the City's eastern border.
(9) “Building” means any building, other than a building used for solely residential purposes, located in the areas specified in subsections (b)(1)—(b)(8). (10) “Entrance” means the entire area between the outer edge of any entrance to a building and any exterior door and includes entry ways, doorways, vestibules, alcoves, and areas located under cantilevers.
(c) Any person violating the provisions of this Section shall be guilty of a misdemeanor which

8.A.b
Packet Pg. 421 Attachment: Existing Santa Monica Ordinances (6596 : Camping Ordinance) shall be punishable by a fine not exceeding five hundred dollars per violation, or by imprisonment in the County Jail for a period not exceeding six months, or by both such fine and imprisonment.
(d) The prohibition contained in this Section shall not apply to any person sitting or lying down in any entrance to a building due to a medical emergency. § 3.12.360 Obstructing, leaving or placing property on, or sitting or lying on public rights-of-way or public property.
(a) Sitting or Lying on Sidewalks or In the Promenade Roadway in the Bayside Conservation District of the Downtown Area.
(1) During the hours between six a.m. and one a.m., no person shall:
(A) Sit or lie down upon a public sidewalk in the Bayside Conservation District or upon the Third Street Promenade;
(B) Sit or lie down upon a blanket, chair, stool, bench or any other object placed or installed on a public sidewalk in the Bayside Conservation District or the Third Street Promenade; or (C) Sit, stand, lie down upon or otherwise be present upon any planting, railing, topiary or statue placed upon or installed on a public sidewalk in the Bayside Conservation District or the Third Street Promenade.
(2) The prohibition contained in this Section shall not apply to any person:
(A) Sitting or lying down on a public sidewalk or the Third Street Promenade due to a medical emergency;
(B) Utilizing a wheelchair, walker or similar device to move about the public sidewalk or the Third Street Promenade as the result of a disability;
(C) Sitting while operating or patronizing a commercial establishment or business conducted on the public sidewalk or Third Street Promenade pursuant to a street use permit, license or other City-issued authorization;
(D) Sitting while participating in or attending a parade, festival, rally, demonstration, meeting or similar special event lawfully conducted pursuant to a City-issued permit or license on the

8.A.b
Packet Pg. 422 Attachment: Existing Santa Monica Ordinances (6596 : Camping Ordinance) public sidewalk or Third Street Promenade;
(E) Sitting on a bollard, chair or bench located on the public sidewalk or Third Street Promenade and which is supplied by a public agency;
(F) Sitting on a ledge, step or other masonry surface which borders the fountains or topiary planters on the public sidewalk or Third Street Promenade; (G) Sitting on a public sidewalk within a bus stop zone while waiting for public or private transportation; or
(H) Giving a street performance pursuant to a permit issued by the City.

8.A.b
Packet Pg. 423 Attachment: Existing Santa Monica Ordinances (6596 : Camping Ordinance) 1 David Yakobson
From: Sarah Starks <[email protected]>
Sent: Sunday, September 8, 2024 4:23 PM
To: councilmtgitems; Phil Brock; Lana Negrete; Caroline Torosis; Jesse Zwick; Christine Parra; Oscar de la Torre; Gleam Davis
Subject: Item 8A - Oppose
Follow Up Flag: Follow up
Flag Status: Completed

EXTERNAL
Dear City Councilmembers,
I am writing in strong opposition to the proposed ordinance in Item 8A on the City Council Agenda for the September 10 meeting. I oppose the proposed changes to the Municipal Code and support Option 1 in the Staff Report: "Take no action to amend the Municipal Code." I work in mental health services research with a focus on adults with serious mental illness, studying their experiences with public mental health services, homelessness, and the criminal justice system. I'm also a Santa Monica resident since 2004 and a Samohi and JAMS parent.

Efforts to deter homelessness by making it even more uncomfortable and unsafe are ineffective and inhumane. I agree with the September 7 letter from the Santa Monica Democratic Club that the proposed changes are counterproductive, at odds with the city's goals and existing programs to serve unhoused individuals, and pointlessly cruel to individuals who are already experiencing harsh and exposed conditions.

When municipalities pursue aggressive anti-camping policies that prohibit the use of pillows and blankets, they aren't working to address homelessness; they are engaging in a race-to-the-bottom competition with neighboring municipalities to push unhoused individuals across their borders. Please continue to focus on effective approaches to addressing homelessness, including permanent supportive housing, affordable housing, assistance to people at risk of losing their housing, and outreach and services for unhoused individuals.

Sincerely,
Sarah Starks, Santa Monica
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

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Packet Pg. 433 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) Item 8-A
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Packet Pg. 435 Attachment: Written Comments [Revision 3] (6596 :
1 David Yakobson
From: Dan Charn. <[email protected]>
Sent: Tuesday, September 10, 2024 4:54 PM
To: councilmtgitems; Council Mailbox; Clerk Mailbox; Douglas Sloan; David White Subject: ITEM 8-A. IT'S COMPLICATED.

EXTERNAL

NIKKI- PLEASE POST THIS- IT WAS SENT TO YOU LONG BEFORE THE DEADLINE- YOU DIDN'T POST IT - - OR MAYBE YOU POSTED IT IN THE WRONG ITEM AS YOU DID WITH MY COMMENT ABOUT 4-B Blanket and Pillows.. NOT THE REAL ISSUE IS IT?
Taking away a blanket or sleeping bag from a homeless
person is really not the point here is it.. let these people keep their blankets and pillows because let's face it..at the rate we are going ..they really aren't going to get much more ..maybe an apple, a cheese sandwich and some new socks
from Bomba.

Stop wasting money - approving massive buildings and
letting developers and special interest groups like Abundant Housing and YIMBY.. lobby SCAG and Sacramento to
decide what we should have while favoring their developer backers and selling out affordable housing needs while
playing that card with a poker face.

We could have easily housed all 900+ of our homeless
people- some of the same people have asked for housing
for years and been repeatedly denied. We have over 4000 empty units.. house them .. plenty of studios around
..house them.

Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

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Packet Pg. 436 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 2 Stop this hypocrisy about caring about their blankets and pillows ..because from the absurdity of the missing tens of millions, to the empty beds at The People Concern, to the refusal to require 25-30% inclusionary to the SMRR/ SMF/ Staff and Planning Dept /Commissions to the total
sellout of this City..to not standing up to SCAG to lower the ridiculous mandated ver 6600 affordable units.. blankets and pillows are totally meaningless.

To act so caring about this issue- to call it "cruel and lacking compassion" is laughable considering the special interest power groups have facilitated the ruin of this town while they have done nothing to stop it and everything to feed it all the time making bad deal after bad deal and telling us how good it is for the community.

This issue has moved us from hypocritical to vulgar. Can I get a witness?
Danielle Charney
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

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Packet Pg. 437 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 1 David Yakobson
From: Dan Hall <[email protected]>
Sent: Tuesday, September 10, 2024 11:37 AM
To: councilmtgitems; Phil Brock; Lana Negrete; Gleam Davis; Oscar de la Torre; Christine Parra; Caroline Torosis; Jesse Zwick
Subject: Oppose Item 8A Option 2

EXTERNAL
Mayor Brock, Vice Mayor Negrete, Councilmembers Davis, de la Torre, Parra, Torosis, and Zwick, I am writing in opposition to Item 8A Option 2. Living unhoused, as uncomfortable as that can be for those of us who are privileged to be housed, is not a crime. To prohibit the use of sleeping bags, blankets, pillows, and bedrolls while sleeping is cruel.

Yes – I agree with all of you – not taking action to get folks off of our streets and out of situations that cause them to sleep in our parks is also cruel. Which is why I was proud that the majority of you voted to continue to build permanent supportive housing recently in the face of vocal opposition. The unhoused don't have the same access to power or the luxury of time and the wealth as we housed individuals do and I applaud and thank those of you who courageously voted for those who don't have the ability to speak for themselves.

I encourage you to pursue Option 3, I see no reason to not do an environmental scan. Removal of comfort items is not the answer. As Justices Sotomayor, Kagan, and Brown-Jackson stated in their dissent from the Republican-appointed majority, the Grants Pass decision "leaves the most most vulnerable in our society with an impossible choice. Either stay awake or be arrested." As the Los Angeles County Democratic Party determined last night - in what was an unusually unanimous vote with one voice - Option 2 is "in defiance of Democratic Party values" and is "a needlessly vicious assault on those whom we have already failed and continue to fail." Let our unhoused neighbors keep their pillows, blankets, and bedrolls. Do the compassionate thing.

Oppose Item 8A Option 2.

Dan Hall
Dan Hall for Santa Monica City Council 2024
www.electdanhall.com | @electdanhall
Contribute | Volunteer | Endorse | Subscribe
FPPC ID# 1466499
P.O. Box 3554, Santa Monica, CA 90408
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

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Packet Pg. 438 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 2 David Yakobson
From: Mary <[email protected]>
Sent: Tuesday, September 10, 2024 11:12 AM
To: Phil Brock; Lana Negrete; Oscar de la Torre; Christine Parra; Caroline Torosis; Jesse Zwick; Gleam Davis
Cc: councilmtgitems
Subject: VOTE YES on 8A

EXTERNAL
Dear Mayor Brock and City Councilmembers;
I urge you to VOTE YES on Item 8A to modify the existing no camping in public spaces to include these sections of the proposed modification to the current code:
(a) No person shall camp in a prohibited public place.
(b) For the purpose of this Section:
(1) “Camp” means to erect, maintain, or occupy a camp facility for the purpose of living accommodations.
(2) “Camp facility” means the use of, settling, fixing in place, setting up, locating, or leaving behind in a prohibited public place any or a combination of the following: tents, huts, other temporary physical shelters, cots, beds, sleeping bags, or hammocks, or bedrolls.
—
Residents are fed up. We want to feel safe again in our homes, walking in our neighborhoods, visiting our parks, beaches, all public spaces, and our business districts.

We know the vast majority of the homeless population are coming here from other jurisdictions because Santa Monica is so permissive. They can live where they want, do what they want any where in our city’s public spaces. Including in their vehicles outside our homes and schools.

With the recent SCOTUS decision we are already experiencing a significant influx of homeless people here because other cities are listening to their residents and business people. Our local economy is suffering.

Our SMFD and SMPD are expending significant resources and time trying to respond to all the homelessness issues. Police have told us “our hands are tied”.

Thank you for listening to and acting on the safety and quality of life concerns of us residents.

With appreciation,
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

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Packet Pg. 439 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 3 Mary Hubbell
Sent from my iPad
Sent from my iPad
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

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Packet Pg. 440 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 4 David Yakobson
From: Jason Mastbaum <[email protected]>
Sent: Tuesday, September 10, 2024 11:11 AM
To: Gleam Davis; Jesse Zwick; Caroline Torosis; Phil Brock; Oscar de la Torre; Lana Negrete; Christine Parra
Cc: councilmtgitems; David White; Douglas Sloan
Subject: 9/10/2024 8A oppose

EXTERNAL
Even if you don't oppose taking blankets from homeless people on basic moral grounds (which you should), and even if you don't care about the city attorney analysis that said taking blankets isn't going to actually achieve anything other than taking away blankets, let's take a moment to consider what happens once we criminalize this. Lots of people take blankets and pillows to our parks to lie out and enjoy the sun and the views. Sometimes, they doze off for a nap. This means that in order to enforce the law, our police will either need to engage in across the board enforcement which is extremely unlikely to be popular with residents, or engage in profiling of who "looks homeless" when deciding whose blanket to seize.

As we know from the data on SMPD traffic stops, this is likely to result in disproportionately targeting people of color. How long is it going to take before that results in SMPD putting the city on the hook for another multimillion dollar settlement?
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

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Packet Pg. 441 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 5 David Yakobson
From: Soloff, Michael <[email protected]>
Sent: Tuesday, September 10, 2024 10:56 AM
To: councilmtgitems
Subject: FW: Opposition to Proposed Ordinance under Item 8-A on City Council 9.10.24 Agenda Attachments: Mike Soloff Letter to Council on Item 8-A on City Council 9.10.24 Agenda.pdf

EXTERNAL
Resending with corrected email address.

Michael E. Soloff | Munger, Tolles & Olson LLP
350 South Grand Avenue | Los Angeles, CA 90071
Tel: 213.683.9159 | Fax: 213.683.5159 | [email protected] | www.mto.com From: Soloff, Michael <[email protected]>
Sent: Tuesday, September 10, 2024 10:22 AM
To: [email protected]
Cc: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected].

Subject: Opposition to Proposed Ordinance under Item 8-A on City Council 9.10.24 Agenda Please see the attached letter re Item 8A on tonight’s City Council Agenda Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

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Packet Pg. 442 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) September 10, 2024
To: Santa Monica City Council
Re: Item 8-A on 9/10/24 Agenda: Introduction for First Reading an Ordinance Amending Santa Monica Municipal Code Section 4.08.095
Dear Councilmembers:

I am writing to oppose the amendments to the City’s anti-camping ordinance that are set forth under option 2 in the Staff Report for Item 8-A. I do so in my individual capacity as a 32-year Santa Monica resident, in my capacity as Co-Chair of Santa Monicans for Renters’ Rights, in my capacity as the Membership Vice President of the Santa Monica Democratic Club, and in my capacity as an elected member from California Assembly District 51 of the Los Angeles County Democratic Party Central Committee. While SMRR, SMDC, and LACDP all oppose these amendments, this letter sets forth my personal reasons for opposing the proposed changes.

Prior to the Supreme Court’s Grants Pass decision, the law was simple—the City could not criminalize sleeping in public UNLESS there were places where the homeless could safely sleep inside. I wish Santa Monica had adequate places to bring all the homeless inside and could keep public spaces exclusively for public uses. I have worked to help make this happen both during my seven and one-half year service on the Housing Commission, and by leading efforts to pass the 2016 Measure GS and the 2022 Measure GS. But we all know we do not presently have enough such places. So current Santa Monica law—while outlawing encampments—says it is not a crime to sleep with a blanket, pillow or sleeping bag on the street.

In Grants Pass, the three Supreme Court Justices appointed by Democratic Presidents agreed that this should remain the law—that it is cruel and unusual punishment to criminalize sleeping in public when there is no other place for these human beings to sleep. But the Trumpist and other extremist Republican Justices—the same Justices who took away women’s right to choose, gutted the Civil Rights Act, made up a Constitutional right for unregulated individuals to own military grade weapons, and blessed unlimited partisan gerrymandering—now have said the Constitution allows Cities to punish desperate people who have nowhere else to go for doing nothing more than sleeping in public.

Santa Monica need not and should not follow this immoral and misguided extreme right-wing view.

It is misguided because criminalizing sleeping will not solve the homelessness crisis, as studies show. Rather, it will exacerbate the problem. For a detailed discussion of the current state of the evidence, including citations to the available studies, please see Brief Of 57 Social Scientists With Published Research On Homelessness As Amici Curiae In Support Of Respondents in Grants Pass, available at https://www.supremecourt.gov/DocketPDF/23/23-175/306641/20240403145657027_23- 175%20Amicus%20Brief.pdf.

The majority of Santa Monicans do not want such cruel and ineffective policies enacted in their names. Rather, the majority want our leaders to act as Mayor Bass is acting in Los Angeles by bringing people inside when we have a safe place for them to go.

Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

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Packet Pg. 443 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) We in Santa Monica need to do our fair share to solve the regional homelessness problem (as does every other City in the region, as well as the County). This means creating more permanent supportive housing among many other actions. Permanent supportive housing is an evidence-based solution to ending homelessness.

I say create more permanent supportive housing because we already have some such housing at various locations in the City, although many people do not realize it. This is because Santa Monica’s permanent supportive housing has a good track record of being a good neighbor. Indeed, having the formerly homeless living in supportive housing is much safer both for them and for the public than their living on the streets.

The concerns we heard last meeting about proposed supportive housing in Mid-City are the same concerns I heard a decade ago on the Housing Commission when a permanent supportive housing project was going into Sunset Park. I have not heard of those fears coming to pass there or at other similar projects in the City. Instead last I heard good faith on both sides led to good neighbors.

Rather than demonizing all the homeless as criminals, keep in mind that by far the biggest abuser of the children of our community was Eric Uller—a fully housed employee of the Santa Monica Police Department who got away (despite warnings signs per the L.A. Times) with molesting scores of children at the Police Athletic League over a very long period of time. The point: criminality must be dealt with directly, not through group punishment.

I know some of you think—what does he know or care, he lives North of Montana. But the facts are that there is a sober living facility that abuts NOMA and is within five blocks of my home, and that a permanent supportive housing project larger than the proposed Hollywood Housing permanent supportive housing opened in 2007 within two blocks of my then two teenage daughters’ school, and within a block of my primary grocery store. I often see the residents of that project grocery shopping at the same time as I am shopping, and when I do I feel proud that—paraphrasing Jesus’s words— our City is helping the least of these our brethren.

Six years ago my formerly homeless colleague on the Housing Commission said that the City always talks about helping the homeless, but never does much of anything. I thought she made a fair point and together we successfully championed that Parking Structure 3 become affordable housing, including in part supportive housing. Yet here we are six years later and ground has not yet even been broken for that project because five Council members prioritized a project to place $8 million condos on top of the Miramar Hotel as a more urgent project when pandemic staffing cuts purportedly allowed focus on only one project for three years. And now three current Council members apparently tried to eliminate the proposed Hollywood Housing supportive units while at the same time apparently planning to criminalize those who have no safe indoor place to go for sleeping.

Please do not show tonight that my colleague was right that our City’s commitment to compassionately and effectively solving homelessness is just talk. Reject the proposed changes to the anti-camping ordinance and instead press to get more supportive housing built—not just planned (as well as pressing to use GS funds to keep at-risk renters in their homes and to take other compassionate and effective steps toward ending the homelessness crisis).

Michael E. Soloff
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 444 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 1 David Yakobson
From: mcsvox <[email protected]>
Sent: Tuesday, September 10, 2024 10:25 AM
To: councilmtgitems
Cc: Phil Brock; Lana Negrete; Jesse Zwick; Christine Parra; Oscar de la Torre; Gleam Davis; Caroline Torosis
Subject: LACDP - Santa Monica Municipal Code section 4.08.095 - Oppose change to code Attachments: LACDP - Santa Monica Municipal Code section 4.08.095.pdf

EXTERNAL
Hello Santa Monica City Council,
Please find the attached position letter from the Los Angeles County Democratic Party regarding proposed changes to the Santa Monica Municipal Code regarding "public camping".

Thank you,
Michele Sutter
LACDP Central Committee
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 445 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 533 S Fremont Ave Suite 410 • Los Angeles, CA 90071 • www.lacdp.org • [email protected] September 10, 2024
The Honorable Phil Brock
Members of the Santa Monica City Council
Santa Monica, CA 90401
RE: Amending the Santa Monica Municipal Code section 4.08.095 – Prohibition against public camping Dear Mayor Brock and Members of the Santa Monica City Council, The Los Angeles County Democratic Party (LACDP) considers and debates many bills submitted by legislators and organizations, but rarely weighs in on municipal ordinances within the county. However, this proposed amendment to the Santa Monica Municipal code warranted a response from our members, who last night, voted unanimously in opposition to any change to the Santa Monica Municipal code regarding “public camping”.

California and Los Angeles County have often been on the forefront of innovative policies that can at our best, serve as beacons for the nation. The crisis of homelessness nationally, and particularly here in California poses intractable challenges to our communities. And yet, the City of Santa Monica is a laudable example of a city working and succeeding at providing beds and services to its most vulnerable residents.

The possibility that the June 2024 Grants Pass v Johnson ruling by a compromised and corrupted Supreme Court of the United States (SCOTUS) might be embraced and implemented by the City of Santa Monica is as appalling as it is shocking. As Justice Sotomayor, joined by Justices Kagan and Brown-Jackson, wrote in her powerful dissent in Grants Pass, the decision “leaves the most vulnerable in our society with an impossible choice. Either stay awake or be arrested.”
Despite the heartless absurdity of the SCOTUS ruling, homelessness is not a criminal activity. For Santa Monica to decree that it is would not only be in defiance of Democratic Party values, it would be a needlessly vicious assault on those whom we have already failed and continue to fail.

As is often said by Democratic lawmakers and economic justice advocates, “poverty in America is a policy choice.” Our members urge the Santa Monica City Council to develop policies which better reflect our shared humanity.

LACDP is the official governing body of the Democratic Party in the County of Los Angeles and works in cooperation with the State and National Democratic Committees. LACDP is the largest local Democratic Party entity in the United States, representing more than 3.1 million registered Democrats.

If the LACDP can be of assistance, please contact Andrés Molina, LACDP Executive Director, at [email protected] or (562) 351-8410.

Sincerely,
Mark Ramos, Chair
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 446 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 1 David Yakobson
From: [email protected]
Sent: Tuesday, September 10, 2024 10:51 AM
To: councilmtgitems
Cc: Phil Brock; Lana Negrete; Caroline Torosis; Jesse Zwick; Christine Parra; Oscar de la Torre; Gleam Davis
Subject: Re: Public Comment - Item 8A - SUPPORT - SM City Council Meeting 9/10/2024

EXTERNAL
Supplemental Statement of Support
Homelessness is not a local issue. If neighboring cities restrict or prohibit camping in public, then that will motivate their homeless to camp out in cities which allow public camping. If neighboring cities allow public camping, then those camping in Santa Monica can move there.

Prohibiting camping in public in Santa Monica is not only necessary for our economy and quality of life, it will motivate churches, charities and individuals to step up and provide housing or camping opportunities in their facilities, in their homes, in their yards and in apartments they pay for. If individual residents do not care enough about the homeless to assist them with their housing, they cannot complain about residents being compelled against their will to house them on sidewalks and other public places. A ban on public camping will be an impetus towards moving towards a solution to the homeless problem. Caroline Torosis, Gleam Davis and Jesse Zwick - open your homes and yards and house one or more homeless persons or rent them an apartment. Put your money where your mouth is.

Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 447 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 2 David Yakobson
From: Anastasia Foster <[email protected]>
Sent: Tuesday, September 10, 2024 10:26 AM
To: councilmtgitems
Subject: Oppose 8A - take option 1

EXTERNAL
Last night the LA County Democratic Party, the official voice of the Democratic Party, took the unique action of unanimously voting to oppose this local ordinance some of you asked staff to bring back. This issue needs more study before taking such an extreme and unkind measure. Please choose Option 1 to do nothing. Let the STEP Courts and other measures have time to work. I know it can be frustrating to wait, but this is why a deep knowledge of how the government needs to work and how it does work is a great trait in an elected official. There are guardrails and procedures to follow to ensure equity and equal treatment under the law and to protect the City and the People's budget from unnecessary litigation, and staff is letting you know what those are.

Thank you.
--
Anastasia Foster
Facebook
Instagram
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 448 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 1 David Yakobson
From: Council Mailbox
Sent: Monday, September 9, 2024 4:13 PM
To: councilmtgitems
Subject: Fw: No on 8A
From: Patricia Meyer <[email protected]>
Sent: Sunday, September 8, 2024 9:54 AM
To: Phil Brock <[email protected]>; Lana Negrete <[email protected]>; Caroline Torosis <[email protected]>; Jesse Zwick <[email protected]>; Christine Parra <[email protected]>; Oscar de la Torre <[email protected]>; Gleam Davis <[email protected]>; Council Mailbox <[email protected]> Subject: No on 8A

EXTERNAL
As a thirty-year resident of Santa Monica, I have seen homelessness rise exponentially in our neighborhoods. Meanwhile, the V.A. has done an amazing job housing their veterans on their campus.

Of course, it helps to have the space.

I oppose 8A because it will shut down all the positive efforts Santa Monica officials have exerted in trying to solve this difficult problem.

Please continue providing the resources that will amend this pressing issue.

Thank you for your humanity and generosity at this desperate time, Patricia K. Meyer
Writer/Producer
Assistant Professor
Screenwriting
School of Film & Television
Loyola Marymount University
Mobile: (310)968-4044
Website: patriciakmeyerwriter.com
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 449 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 2 David Yakobson
From: M K <[email protected]>
Sent: Monday, September 9, 2024 3:34 PM
To: councilmtgitems
Cc: Phil Brock; Lana Negrete; Caroline Torosis; Jesse Zwick; Christine Parra; Oscar de la Torre; Gleam Davis
Subject: Oppose Item 8A

EXTERNAL
Dear City Councilmembers,
In Santa Monica we care for ALL our community.

I urge you to vote against Item 8A.

Thank you,
Michael Kirschbaum
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 450 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 3 David Yakobson
From: Kristen Aster <[email protected]>
Sent: Tuesday, September 10, 2024 9:55 AM
To: councilmtgitems
Cc: John Maceri
Subject: Public Comment: Agenda Item 8A

EXTERNAL
One of Los Angeles County’s largest housing and social services agencies and present in every Service Planning Area (SPA), The People Concern is an expert in connecƟng with people on the streets, bringing them inside and then keeping them inside. 92% of people placed in permanent housing by The People Concern never experience homelessness again.

The People Concern is proud to have worked in the City of Santa Monica for over 60 years.

The People Concern is troubled by the proposed amendments to the City’s current anƟ-camping ordinance. The criminalizaƟon of basic survival acƟviƟes, such as sleeping with protecƟve elements, perpetuates a cycle of poverty and instability, making it even harder for individuals to access the help they need to get back on their feet. We know what works to solve homelessness: housing paired with supporƟve services. We are proud to partner with the County of Los Angeles and the City of Santa Monica on intervenƟons that work to solve, not displace, homelessness, including but not limited to services-led encampment resoluƟon efforts, mulƟ-disciplinary outreach services, low barrier interim housing faciliƟes, housing navigaƟon support to help secure permanent housing, and case management services to retain permanent housing. These intervenƟons work and we urge the City to focus strategies and taxpayer resources on effecƟve soluƟons to ending homelessness.

We oppose this draŌ ordinance and urge the council to vote no on the proposed changes.

Kristen Asterௗௗ
Pronouns: (she/her)ௗ
Director of Public Policy and Advocacyௗ
The People Concernௗ
2116 Arlington Ave. Ste. 100, Los Angeles, CA 90018
ௗ
Phone: (323) 973-0093
ௗ

TPC7000
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 451 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 4 David Yakobson
From: Jon Katz <[email protected]>
Sent: Tuesday, September 10, 2024 9:33 AM
To: councilmtgitems
Cc: Phil Brock; Lana Negrete; Gleam Davis; Caroline Torosis; Christine Parra; Oscar de la Torre; Jesse Zwick
Subject: Item 8A - OPPOSE

EXTERNAL
Mayor Brock, Mayor Pro Tempore Negrete, and City Council:

One of the great shortcomings of our American democracy has been the eradication of the Supreme Court over the past several decades into a partisan body. When President Trump appointed three justices, including the replacement of Ruth Bader Ginsburg, it led to a 6-3 MAGA conservative majority which may be with us for quite some time. As such, we are now used to seeing SCOTUS make some extremely disturbing rulings.

This session, the same six justices who recently voted to overturn Roe v. Wade also decided the Grants Pass decision, which is the basis for Item 8A. Please note in the staff report that the City of Santa Monica is currently legally compliant with the Grants Pass decision. No additional action must be taken.

Therefore, any decision made to take further action on this matter would be done so by choice of the City Council.

In her dissent on Grants Pass, Justice Sotomayor wrote, "It is possible to acknowledge and balance the issues facing local governments, the humanity and dignity of homeless people, and our constitutional principles. The City of Grants Pass jails and fines those people for sleeping anywhere in public at any time, including in their cars, if they use as little as a blanket to keep warm or a rolled-up shirt as a pillow.

For people with no access to shelter, that punishes them for being homeless. That is unconscionable and unconstitutional. Punishing people for their status is ‘cruel and unusual’ under the Eighth Amendment.”
It is now time for each Councilmember to decide if they are on the side of Justice Sotomayor, Justice Kagan, and Justice Brown-Jackson; or if they are on the side of the six conservative Supreme Court justices appointed by Republican presidents.

When some of us say there is a conservative majority on Santa Monica City Council, this is why. Please prove me wrong and vote unanimously to take no action on Item 8A. --
Jon Katz | President, Santa Monica Democratic Club
[email protected]
cell: (215) 962-4357
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 452 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 5 David Yakobson
From: Caro Vilain <[email protected]>
Sent: Tuesday, September 10, 2024 8:22 AM
To: councilmtgitems
Cc: Council Mailbox; Gleam Davis; Lana Negrete; Oscar de la Torre; Jesse Zwick; Caroline Torosis; Christine Parra; Phil Brock
Subject: I oppose item 8A

EXTERNAL
Dear council,
As stated when the item first appeared on the agenda, I oppose item 8A.

Recently, I met someone on the streets of our city who has been putting in effort and working with staff to get into housing himself. His words were “It takes time, but I just have to hang in there for now. I can’t wait to be off the street.”
One night a couple weeks ago, he didn’t make into a shelter and had to sleep outside. Because he usually finds a place to sleep at night, he doesn’t carry blankets with him. Yet, when you find yourself sleeping outside on the street, you still have to find a way to stay warm and make it through the night.

He used what he could find, which was a trash bag, filled with recyclable items.

Taking blankets away from those who have them when sleeping on the street won’t help anybody (as shown by the report on the item). It will only make their situation even more miserable than it already is. If you worry about the mental health of our unhoused neighbors, I recommend not making their life more difficult than it already is.

I hope none of you ever find yourselves sleeping on the street, but if you do, I hope we don’t have an ordinance in place that prevents you from having a blanket or a pillow, because you’ll have to figure out a way to stay warm too.

Please oppose item 8A,
Caro Vilain, 90404
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 453 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 1 David Yakobson
From: Joan Sekler <[email protected]>
Sent: Saturday, September 7, 2024 8:00 PM
To: councilmtgitems; Jesse Zwick; Caroline Torosis; Gleam Davis; Oscar de la Torre; Phil Brock; Christine Parra; Lana Negrete
Subject: Vote No—Oppose 8A

EXTERNAL
Don’t be cruel—support those working to find housing for the homeless, treatment for the mentally ill, treatment to stop drug and alcohol abuse,etc.

Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 454 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 2 David Yakobson
From: Santa Monica Democratic Club <[email protected]> Sent: Saturday, September 7, 2024 7:31 PM
To: councilmtgitems
Cc: Phil Brock; Lana Negrete; Caroline Torosis; Jesse Zwick; Christine Parra; Oscar de la Torre; Gleam Davis
Subject: Item 8A - OPPOSE
Attachments: SMDC Letter to Council 9.10 Meeting Item 8A OPPOSE.pdf

EXTERNAL
Please see attached letter from the Santa Monica Democratic Club Executive Board regarding Item 8A of the September 10, 2024, City Council meeting.

Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 455 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) President
Jon Katz
VP Political Action
Derek Devermont
VP Membership
Michael Soloff
VP Programs
Sam Cozolino
VP Communications
Susan Sheu
VP Diversity & Inclusion
Keith Coleman
VP Legislation
Isabel Storey
Treasurer
Luis Barrera Castañón
Recording Secretary
Natalya Zernitskaya
At-Large
Lynn Cervini
Patricia Hoffman
Dolores Sloan
September 7, 2024
Mayor Brock, Mayor Pro Tempore Negrete, and City Councilmembers:

The Santa Monica Democratic Club Executive Committee writes in strong opposition to the proposed ordinance in Item 8A on the City Council Agenda for the September 10 meeting. We oppose the proposed changes to the Municipal Code and support Option 1 in the Staff Report: “Take no action to amend the Municipal Code.” Homelessness is a persistent issue in Santa Monica and surrounding areas – but it’s one on which we’re beginning to make progress with humane, evidence-based solutions. We don’t need to resort to draconian measures such as outlawing pillows and blankets. Our Club strongly believes that criminalizing homelessness is not a solution – the true solution to homelessness is affordable housing.

The west side of Los Angeles County, which includes Santa Monica, saw a nearly 20 percent decrease in the total population of people experiencing homelessness in the past year, according to the Los Angeles County Homeless Services Authority, or LAHSA. In Santa Monica, LAHSA’s Homeless Count showed 774 people experiencing homelessness, a 6 percent decrease from the 826 reported by LAHSA in 2023. “The reduction in people recorded in the county’s 2024 point in time count is promising and reflects the impacts of our strategic efforts to address homelessness,” according to Santa Monica Housing and Human Services Director Heather Averick.

The city continues to push forward and expand its strategic, robust and innovative portfolio of programs and initiatives to address and prevent homelessness, including:
● Working to transition homeless Santa Monicans into interim housing ● Increasing the amount of permanent supportive housing ● Providing housing vouchers to vulnerable Santa Monica individuals and families
● Funding nine homeless outreach teams
P.O. Box 1052 • Santa Monica,CA 90406 • 215-962-4357 • [email protected] Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 456 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) ● Extending the City Council’s local emergency on homelessness through May 31, 2025
● Developing a citywide Homelessness Strategic Plan which will be presented to the City Council in 2025
By contrast, criminalizing homelessness tends to make the problem worse. Fines, citations, and other negative interactions with law enforcement decrease the likelihood that an individual will engage positively with outreach teams offering services in the future. These same fines and citations can become a barrier to permanent housing, too, if any unpaid tickets end up on someone’s record. This can make it much harder to use a housing voucher or other housing resource. There are many studies and examples of criminalization having no impact on
reducing homelessness – or even crime.

In the mid-2000s, LAPD implemented a program called Safer Cities Initiative (SCI), in which they saturated Skid Row with large numbers of police officers tasked with systematically ticketing unhoused people. SCI resulted in massive numbers of arrests and tickets for people trying to survive on the streets, while its impact on crime was negligible - crime went down in Skid Row during that period at the same rate it went down in other parts of the area not subject to such intensive enforcement. The key takeaway was that criminalization and additional policing of unhoused communities does not impact the crime rates. Human Rights Watch Report, 8/14/241 According to the HRW 2024 Report, convictions for crimes can make it harder for people to come out of homelessness by making it more difficult for them to receive public housing or housing subsidies with a criminal record. Violations as low as infractions can create an insurmountable financial burden upon individuals who already experience financial instability.

Harsh policing of homelessness just creates disorder and instability, while not solving the underlying problem. The 2018 Sparks study of zero tolerance policing in San 2 Francisco found that 70% of the homeless individuals were forced to move by an officer and yet 91% continued to live in open spaces. 74% said they didn’t know of legal spaces to sleep so they moved to nearby areas or surrounding neighborhoods.

Homeless residents reported they felt they were being surveilled and were in fear of being approached by officers. The study found that “by increasing citations and arrests, the homeless collect more debt and once arrested, their criminal histories will make it difficult to access social services, housing, employment, and shelters.” 2 “A Qualitative Study: The Impact of Homelessness Criminalization on Unhoused Individuals Living in Los Angeles,” 2023. https://www.proquest.com/openview/7328f8f5f771fd15ed44b410c0699b05/1?pqorigsite=gscholar&cbl=18750&diss=y 1https://www.hrw.org/report/2024/08/14/you-have-move/cruel-and-ineffective-criminalization-unhoused-people-los-ange les
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 457 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) We believe that the humane, evidence-based, and strategic approaches Santa Monica is implementing to solve our homelessness problem are working – and should be continued. It’s not the time to turn to petty and vindictive policies such as snatching away pillows and blankets. This type of enhanced criminalization just leads to emotional distress, financial hardship, a damaging police record – and does little or nothing to reduce crime or get people off the streets.

We urge you to reject the proposed ordinance in Item 8A and adopt Staff Recommendation #1, “Take no action to amend the Municipal Code.” Sincerely,
President, Santa Monica Democratic Club
On Behalf of the Executive Board
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 458 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 3 David Yakobson
From: Jacob Wasserman <[email protected]>
Sent: Friday, September 6, 2024 2:01 PM
To: Council Mailbox; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Jesse Zwick; Caroline Torosis; Oscar de la Torre; councilmtgitems
Subject: Item 8.A: Against Criminalizing Our Unhoused Neighbors

EXTERNAL
Dear Santa Monica City Council,
As a voter, resident, and parent, I oppose the proposed ordinance in Item 10.D. The ordinance proposes is cruel, and it saddens me deeply to see our welcoming City contemplate a both literal and figurative blanket ban.

The ordinance would criminalize people with no other place to go, for merely seeking shelter when they otherwise lack anywhere else safe to sleep. It does nothing to solve homelessness, merely forcibly pushing people from place to place. It wastes our tax dollars while accomplishing very little.

Legal scholars have argued that such ordinances violate basic human rights. The crisis requires far more beds and shelter space than we have available.

I would hate to see the City side with the conservative wing of the Supreme Court here.

Having had unhoused people take shelter in my car ports before, and living myself just next door to a residence housing the formly unhoused, I know that compassion is needed and that our unhoused neighbors simply want a home first and foremost. This proposal is the exact opposite.

Thanks,
Jacob Wasserman
11th and Washington
90403
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 459 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 1 David Yakobson
From: Cynthia Rose <[email protected]>
Sent: Tuesday, August 27, 2024 1:03 PM
To: councilmtgitems; Council Mailbox; Gleam Davis; Jesse Zwick; Caroline Torosis; Lana Negrete; Oscar de la Torre; Phil Brock; Christine Parra; David White Cc: [email protected]; [email protected] Subject: Agenda Item 10D - Opposed
Attachments: 2024-08 CC Agenda item 10D - OPPOSED.pdf

EXTERNAL
Please find our letter in opposition to agenda item 10D Cynthia Rose, Cris Gutierrez and Anya Baroff
--
Cynthia Rose
Co-Chair
Santa Monica Safe Streets Alliance
SaMoSafeStreets.org
I acknowledge with respect and gratitude the Tongva, Kizh, and Chumash Peoples on whose traditional territory I live and work.

Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 460 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance)

August 27, 2024
RE: Agenda Item 10D - Opposed
Dear Mayor and City Council Members:

Santa Monica Safe Streets Alliance opposes the proposed ordinance that criminalizes homelessness and targets our most vulnerable with the abject cruelty of taking warmth and basic comfort from folks without a home by adding the mere existence of “sleeping bags, or bedrolls to the description of an encampment to section 1A and removing section 1D “This ordinance does not prohibit those who are homeless from using sleeping bags, blankets, pillows, and/or bedrolls while sleeping.” from the existing no camping ordinance.

At the same time some council members are also opposing services and supporting housing to provide opportunities for people to get off the streets!
Our City Council must be leaders with intelligence, responsibility and a heart as it solves problems. We urge you to oppose the proposed 10D ordinance and lead responsibly and honorably.

Sincerely,
Cynthia Rose Cris Gutierrez
Co-Chair, Santa Monica Safe Street Alliance Co-Chair, Santa Monica Safe Streets Alliance SaMoSafeStreets.org
Community Human Rights Advocate
The city has requested $515,000 from the Department of Justice to fund the STEP program, which is designed to support supportive housing through STEP court. However, this request is concerning as it coincides with efforts to criminalize homelessness and reduce the supportive housing options it promises in the DOJ proposal. There has been no indication on what supportive housing is offered through this program, how police responses will decrease, or what increases to legal -aid services will be provided to defend those without housing.

This paradoxical approach undermines the intent of the STEP program by potentially exacerbating the very issues it aims to address, creating a situation where the city seeks federal funds for supportive measures while simultaneously enacting local policies that diminish the availability of support for the unhoused population. If not addressed properly the city risks violating the Federal False Claims Act 31 (U.S.C. §§ tel:3729-3733)
*STEP Court -- Shelter, Treatment, and Empowerment Program Court; connecting low-level offenders with necessary services to obtain mental health treatment, addiction treatment, and empowerment program. | Bureau of Justice Assistance https://mayor.lacity.gov/sites/g/files/wph2066/files/2024-01/CIRCLE_FAQ_English_Spanish_Jan%202024.pdf\ Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 461 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 1 David Yakobson
From: Daphne Dennis <[email protected]>
Sent: Tuesday, August 27, 2024 5:14 PM
To: councilmtgitems
Cc: Council Mailbox
Subject: Opposition to items 10 D, 16G, and 16J

EXTERNAL
Dear City Council members,
I urge you to reject items 10D, 16G and J on this evening’s agenda. As a 50-year resident of the City, a member of the City’s 1984-85 Homeless Task Force, and a social services professional, I am very aware of the many challenges in the fight to end homelessness. I find the proposed measures ill-advised because they are not solution-oriented and they are heartless. Please support the programs we know are working and build the housing with services we know provides safety and security for both people who were formerly unhoused, and their resident and business neighbors.

Respectfully,
Daphne Dennis
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 462 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 2 David Yakobson
From: Laura Joy <[email protected]>
Sent: Tuesday, August 27, 2024 4:37 PM
To: councilmtgitems
Subject: Items 10D, 16G, and 16J: OPPOSED

All three of these proposals run counter to every evidence-based best practice for solving homelessness and will without a doubt make our current crisis worse. And yet most stunning of all is the sheer cruelty of what is being proposed. To simultaneously deny an unhoused person a blanket and an alternative place to sleep is both mean and absurd.

Re: Item 10D, Santa Monica already has an anti-camping ordinance, as well as laws against sitting, lying, and sleeping in doorways, sidewalks, parks, and countless other places. Making it illegal for unhoused people to use a blanket or pillow will not make them disappear. It will simply expose desperate people with nowhere to go to even more inhumane conditions, further jeopardizing their health and safety and quite possibly their lives, as more unhoused people die from cold weather in Los Angeles each year than in New York City.

Re: Item 16G, harm reduction programs are evidence-based best practices that have been continually proven to prevent fatal overdoses, curb the spread of infectious disease, reduce costly ER visits, and connect people to substance-use treatment options. Proposals to eliminate these programs in Santa Monica would lead to more preventable deaths and less opportunities for people to get clean – and, as it stands, state law and County Department of Public Health policies supersede our local powers, thereby rendering this request illegal and unenforceable.

Re: Item 16J, removing all the permanent supportive housing (PSH) from the proposed affordable housing project on city-owned surface parking lots off Wilshire would senselessly deny the housing we so desperately need to get people off our streets. In addition, it will jeopardize the financial viability of the entire project, as competitive state funding for affordable housing strongly prioritizes proposals that include supportive housing for formerly homeless individuals.

I have always trusted that Santa Monica was a compassionate, humane city that believed in science and reason and treated everyone with dignity and respect. Please do not give in to the loudest and most hateful voices in our community. Instead, withdraw these cruel and counterproductive proposals and do what is best for our city.

Laura Joy, 90405
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 463 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 3 David Yakobson
From: John Given <[email protected]>
Sent: Tuesday, August 27, 2024 4:19 PM
To: councilmtgitems
Subject: Agenda Items 10D, 16G and 16J

In addition, it will jeopardize the financial
viability of the entire project, as competitive
state funding for affordable housing strongly
prioritizes proposals that include supportive
housing for formerly homeless individuals.

Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 464 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 4 I have always trusted that Santa Monica was a
compassionate, humane city that believed in
science and reason and treated everyone with
dignity and respect. Please do not give in to the
loudest and most hateful voices in our
community. Instead, withdraw these cruel and
counterproductive proposals and do what is
best for our city.

John Given
90405

JOHN GIVEN
[email protected]
310-430-1018
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 465 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 5 David Yakobson
From: AlanToy <[email protected]>
Sent: Tuesday, August 27, 2024 2:36 PM
To: councilmtgitems; Council Mailbox; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Jesse Zwick; Caroline Torosis; Oscar de la Torre Subject: Items 10D, 16G, and 16J: OPPOSED

And yet most stunning of all is the sheer cruelty of what is being proposed. To simultaneously deny an unhoused
person a blanket and an alternative place to sleep is both mean and absurd.Re: Item 10D, Santa Monica already has
an anti-camping ordinance, as well as laws against sitting, lying, and sleeping in doorways, sidewalks, parks, and
countless other places.

Making it illegal for unhoused people to use a blanket or pillow will not make them disappear. It will simply expose desperate people with nowhere to go to even more
inhumane conditions, further jeopardizing their health and safety and quite possibly their lives, as more unhoused Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 466 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 6 people die from cold weather in Los Angeles each year than in New York City.

Re: Item 16G, harm reduction programs are evidencebased best practices that have been continually proven to prevent fatal overdoses, curb the spread of infectious
disease, reduce costly ER visits, and connect people to substance-use treatment options. Proposals to eliminate these programs in Santa Monica would lead to more
preventable deaths and less opportunities for people to get clean – and, as it stands, state law and County Department of Public Health policies supersede our local powers,
thereby rendering this request illegal and unenforceable.

Re: Item 16J, removing all the permanent supportive
housing (PSH) from the proposed affordable housing
project on city-owned surface parking lots off Wilshire would senselessly deny the housing we so desperately
need to get people off our streets. In addition, it will jeopardize the financial viability of the entire project, as competitive state funding for affordable housing strongly prioritizes proposals that include supportive housing for formerly homeless individuals.

I have always trusted that Santa Monica was a
compassionate, humane city that believed in science and reason and treated everyone with dignity and respect.

Please do not give in to the loudest and most hateful voices in our community. Instead, withdraw these cruel and
counterproductive proposals and do what is best for our city.

Thank you,
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 467 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 7 Alan Toy
90402
Sent from my iPad
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 468 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 8 David Yakobson
From: Stephen <[email protected]>
Sent: Tuesday, August 27, 2024 2:30 PM
To: councilmtgitems; Council Mailbox; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Jesse Zwick; Caroline Torosis; Oscar de la Torre Subject: Items 10D, 16G, and 16J: OPPOSED

EXTERNAL
Re: Items 10D, 16G, and 16J: OPPOSED
Dear Santa Monica City Council,
I am a resident of Santa Monica for close to 50 years.

8.A.c
Packet Pg. 469 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 9 affordable housing strongly prioritizes proposals that include supportive housing for formerly homeless individuals.

I have always trusted that Santa Monica was a compassionate, humane city that believed in science and reason and treated everyone with dignity and respect.

Please do not give in to the loudest and most hateful voices in our community. Instead, withdraw these cruel and counterproductive proposals and do what is best for our city.

Stephen Tarzynski, M.D.

Zip code: 90403
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 470 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 10 David Yakobson
From: Melissa Sweeney <[email protected]>
Sent: Tuesday, August 27, 2024 2:22 PM
To: Council Mailbox; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Jesse Zwick; Caroline Torosis; Oscar de la Torre; councilmtgitems
Subject: 10D, 16G, and 16J - OPPOSED

EXTERNAL
Councilmembers:

I strongly oppose items, 10D, 16G and 16J.

These proposals would deny unhoused people basic human needs and block access to life-saving services.

The reasons for homelessness are varied – and very well understood. The three proposals disregard the data.

They devalue the work of nonprofits, social scientists, and local volunteers who have striven to develop longterm solutions from the data. 10D, 16G and 16J fail to acknowledge and address existing conditions that the unhoused are compelled to live with.

If I were a cynical member of the community, I might conclude that 10D, 16G and 16J constitute, in aggregate, a transparent, politically motivated effort to eliminate altogether the unhoused from our streets. I hope that is not the case.

In recent years, my local faith community has joined a westside nonprofit to conduct a homeless memorial service, at which the names of scores of unhoused people who have died in our community in the preceding year are read. Their respective hometowns and survivors, if known, have also been noted. The service presents a moving and tragic reality. It underscores the humanity of those who are forced to live – and too often pass away – in our city from lack of basic needs and services. 10D, 16G and 16J represent an affront to core values, faith-based and secular, that most Americans are raised to uphold. The solutions that
10D, 16G and 16J set forth are short-sighted and inhumane. It’s hard to imagine how these proposed measures accomplish anything but shift the unhoused to surrounding communities.

Solving the problem of homelessness is a long process. Impatience and impulsivity should never guide Council decisions. If anything, our City and community should double down on the good work that has already been done, and build upon the efforts we’re presently undertaking. Please shelve these items and work with residents and local businesses to develop additional solutions that track with our principles.

Melissa Sweeney
Santa Monica 90404
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 471 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 11 David Yakobson
From: Vivian Rothstein <[email protected]>
Sent: Tuesday, August 27, 2024 2:14 PM
To: councilmtgitems; Council Mailbox; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Jesse Zwick; Caroline Torosis; Oscar de la Torre Subject: Item 10D, 16G,and 16J: OPPOSED

EXTERNAL
Dear Santa Monica City Council,
I am a 40 year resident of Sunset Park who raised my children in this city and served as a member of the City Staff. For 10 years I served as Executive Director of the Ocean Park Community Center (now The People Concern) and learned what it takes to end homelessness in our community -- housing that is affordable and supportive services to maintain stability.

And yet most stunning of all is the sheer cruelty of what is being proposed. To simultaneously deny an unhoused person a blanket and an alternative place to sleep is both mean and absurd.

I have always trusted that Santa Monica was a compassionate, humane city that believed in science and reason and treated everyone with dignity and respect.

Please do not give in to the loudest and most hateful voices in our community. Instead, withdraw these cruel and counterproductive proposals and do what is best for our city.

Sincerely, Vivian Rothstein
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 472 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 12 David Yakobson
From: Laila Taslimi <[email protected]>
Sent: Tuesday, August 27, 2024 12:03 PM
To: councilmtgitems; Council Mailbox; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Jesse Zwick; Caroline Torosis; Oscar de la Torre Subject: Council Agenda items 10D, 16G, and 16J OPPOSED

EXTERNAL
Dear Santa Monica City Council,
I am writing to express my strong opposition to Items 10D, 16G, and 16J, which would deny blankets to those sleeping on our streets, deny proven harm reduction and drug treatment strategies to those struggling to get clean, and deny housing opportunities to those ready to come inside.All three of these proposals run counter to every evidence-based best practice for solving homelessness and will without a doubt make our current crisis worse. And yet most stunning of all is the sheer cruelty of what is being proposed. To simultaneously deny an unhoused person a blanket and an alternative place to sleep is both mean and absurd.Re: Item 10D, Santa Monica already has an anti-camping ordinance, as well as laws against sitting, lying, and sleeping in doorways, sidewalks, parks, and countless other places. Making it illegal for unhoused people to use a blanket or pillow will not make them disappear. It will simply expose desperate people with nowhere to go to even more inhumane conditions, further jeopardizing their health and safety and quite possibly their lives, as more unhoused people die from cold weather in Los Angeles each year than in New York City.Re: Item 16G, harm reduction programs are evidence-based best practices that have been continually proven to prevent fatal overdoses, curb the spread of infectious disease, reduce costly ER visits, and connect people to substance-use treatment options. Proposals to eliminate these programs in Santa Monica would lead to more preventable deaths and less opportunities for people to get clean – and, as it stands, state law and County Department of Public Health policies supersede our local powers, thereby rendering this request illegal and unenforceable.Re: Item 16J, removing all the permanent supportive housing (PSH) from the proposed affordable housing project on city-owned surface parking lots off Wilshire would senselessly deny the housing we so desperately need to get people off our streets. In addition, it will jeopardize the financial viability of the entire project, as competitive state funding for affordable housing strongly prioritizes proposals that include supportive housing for formerly homeless individuals.I have always trusted that Santa Monica was a compassionate, humane city that believed in science and reason and treated everyone with dignity and respect.

Please do not give in to the loudest and most hateful voices in our community. Instead, withdraw these cruel and counterproductive proposals and do what is best for our city.

Sincerely,
Laila Taslimi
resident of 90402
from 긕긖긗긘긙긔긚
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 473 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 1 David Yakobson
From: Kathleen Sheldon <[email protected]>
Sent: Tuesday, August 27, 2024 11:53 AM
To: councilmtgitems; Council Mailbox; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Jesse Zwick; Caroline Torosis; Oscar de la Torre Subject: Council items on homeless issues in Santa Monica

EXTERNAL
Dear Santa Monica City Council,
I have lived in Santa Monica since 1975, and have seen many attempts to deal with the tragedy of homelessness. The three items currently being raised are not solutions, but will add to the problem. We cannot treat people like this, but we do need some serious responses to make our city better for everyone who lives here.

Re: Item 16J, removing all the permanent supportive housing (PSH) from the proposed affordable housing project on cityowned surface parking lots off Wilshire would senselessly deny the housing we so desperately need to get people off our streets. In addition, it will jeopardize the financial viability of the entire project, as competitive state funding for affordable housing strongly prioritizes proposals that include supportive housing for formerly homeless individuals.

Instead, withdraw these cruel and counterproductive proposals and do what is best for our city.

Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 474 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 1 David Yakobson
From: Patricia Meyer <[email protected]>
Sent: Tuesday, August 27, 2024 11:15 AM
To: councilmtgitems; Council Mailbox; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Jesse Zwick; Caroline Torosis; Oscar de la Torre Subject: Fwd: IMPORTANT: Earlier emails to city council not sending due to Action Network error, please see details here for resending

EXTERNAL
Subject: Items 10D, 16G, and 16J: OPPOSED
Dear Santa Monica City Council,I am writing to express my strong opposition to Items 10D, 16G, and 16J, which would deny blankets to those sleeping on our streets, deny proven harm reduction and drug treatment strategies to those struggling to get clean, and deny housing opportunities to those ready to come inside.All three of these proposals run counter to every evidence-based best practice for solving homelessness and will without a doubt make our current crisis worse. And yet most stunning of all is the sheer cruelty of what is being proposed. To simultaneously deny an unhoused person a blanket and an alternative place to sleep is both mean and absurd.Re: Item 10D, Santa Monica already has an anti-camping ordinance, as well as laws against sitting, lying, and sleeping in doorways, sidewalks, parks, and countless other places. Making it illegal for unhoused people to use a blanket or pillow will not make them disappear. It will simply expose desperate people with nowhere to go to even more inhumane conditions, further jeopardizing their health and safety and quite possibly their lives, as more unhoused people die from cold weather in Los Angeles each year than in New York City.Re: Item 16G, harm reduction programs are evidence-based best practices that have been continually proven to prevent fatal overdoses, curb the spread of infectious disease, reduce costly ER visits, and connect people to substance-use treatment options. Proposals to eliminate these programs in Santa Monica would lead to more preventable deaths and less opportunities for people to get clean – and, as it stands, state law and County Department of Public Health policies supersede our local powers, thereby rendering this request illegal and unenforceable.Re: Item 16J, removing all the permanent supportive housing (PSH) from the proposed affordable housing project on city-owned Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 475 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 2 surface parking lots off Wilshire would senselessly deny the housing we so desperately need to get people off our streets. In addition, it will jeopardize the financial viability of the entire project, as competitive state funding for affordable housing strongly prioritizes proposals that include supportive housing for formerly homeless individuals.I have always trusted that Santa Monica was a compassionate, humane city that believed in science and reason and treated everyone with dignity and respect. Please do not give in to the loudest and most hateful voices in our community. Instead, withdraw these cruel and counterproductive proposals and do what is best for our city.

Sincerely,
Patricia K. Meyer
Santa Monica, CA 90405
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 476 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 1 David Yakobson
From: Zack <[email protected]>
Sent: Tuesday, August 27, 2024 11:09 AM
To: councilmtgitems; Council Mailbox; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Jesse Zwick; Caroline Torosis; Oscar de la Torre Subject: Items 10D, 16G, and 16J: OPPOSED

EXTERNAL
Dear Santa Monica City Council,I am writing to express my strong opposition to Items 10D, 16G, and 16J, which would deny blankets to those sleeping on our streets, deny proven harm reduction and drug treatment strategies to those struggling to get clean, and deny housing opportunities to those ready to come inside.All three of these proposals run counter to every evidence-based best practice for solving homelessness and will without a doubt make our current crisis worse. And yet most stunning of all is the sheer cruelty of what is being proposed. To simultaneously deny an unhoused person a blanket and an alternative place to sleep is both mean and absurd.Re: Item 10D, Santa Monica already has an anti-camping ordinance, as well as laws against sitting, lying, and sleeping in doorways, sidewalks, parks, and countless other places. Making it illegal for unhoused people to use a blanket or pillow will not make them disappear. It will simply expose desperate people with nowhere to go to even more inhumane conditions, further jeopardizing their health and safety and quite possibly their lives, as more unhoused people die from cold weather in Los Angeles each year than in New York City.Re: Item 16G, harm reduction programs are evidence-based best practices that have been continually proven to prevent fatal overdoses, curb the spread of infectious disease, reduce costly ER visits, and connect people to substance-use treatment options. Proposals to eliminate these programs in Santa Monica would lead to more preventable deaths and less opportunities for people to get clean – and, as it stands, state law and County Department of Public Health policies supersede our local powers, thereby rendering this request illegal and unenforceable.Re: Item 16J, removing all the permanent supportive housing (PSH) from the proposed affordable housing project on city-owned surface parking lots off Wilshire would senselessly deny the housing we so desperately need to get people off our streets. In addition, it will jeopardize the financial viability of the entire project, as competitive state funding for affordable housing strongly prioritizes proposals that include supportive housing for formerly homeless individuals.I have always trusted that Santa Monica was a compassionate, humane city that believed in science and reason and treated everyone with dignity and respect. Please do not give in to the loudest and most hateful voices in our community. Instead, withdraw these cruel and counterproductive proposals and do what is best for our city.

Zachary Coil, LCSW
Santa Monica, CA 90405
Sent from my iPhone
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 477 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 1 David Yakobson
From: Anastasia Foster <[email protected]>
Sent: Tuesday, August 27, 2024 11:03 AM
To: councilmtgitems; Council Mailbox; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Jesse Zwick; Caroline Torosis; Oscar de la Torre Subject: Items 10D, 16G, and 16J: OPPOSED

EXTERNAL
I am opposed to these items. Please don't pass them.
--
Anastasia Foster
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 478 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 2 David Yakobson
From: Megan Kelly <[email protected]>
Sent: Tuesday, August 27, 2024 11:14 AM
To: councilmtgitems; Council Mailbox; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Jesse Zwick; Caroline Torosis; Oscar de la Torre Subject: Subject: Items 10D, 16G, and 16J: OPPOSED

EXTERNAL
Dear Santa Monica City Council,
Thank you for taking the time to read this email. I am a resident of Santa Monica, a mom, and a nonprofit professional. I care deeply about my neighborhood, city, and community. That's why I was particularly alarmed by some of this evening's agenda.

I am writing to express my strong opposition to Items 10D, 16G, and 16J, which would deny blankets to those sleeping on our streets, deny proven harm reduction and drug treatment strategies to those struggling to get clean, and deny housing opportunities to those ready to come inside.All three of these proposals run counter to every evidence-based best practice for solving homelessness and will without a doubt make our current crisis worse. And yet most stunning of all is the sheer cruelty of what is being proposed. To simultaneously deny an unhoused person a blanket and an alternative place to sleep is both mean and absurd.Re: Item 10D, Santa Monica already has an anti-camping ordinance, as well as laws against sitting, lying, and sleeping in doorways, sidewalks, parks, and countless other places. Making it illegal for unhoused people to use a blanket or pillow will not make them disappear. It will simply expose desperate people with nowhere to go to even more inhumane conditions, further jeopardizing their health and safety and quite possibly their lives, as more unhoused people die from cold weather in Los Angeles each year than in New York City.Re: Item 16G, harm reduction programs are evidence-based best practices that have been continually proven to prevent fatal overdoses, curb the spread of infectious disease, reduce costly ER visits, and connect people to substance-use treatment options. Proposals to eliminate these programs in Santa Monica would lead to more preventable deaths and less opportunities for people to get clean – and, as it stands, state law and County Department of Public Health policies supersede our local powers, thereby rendering this request illegal and unenforceable.Re: Item 16J, removing all the permanent supportive housing (PSH) from the proposed affordable housing project on city-owned surface parking lots off Wilshire would senselessly deny the housing we so desperately need to get people off our streets. In addition, it will jeopardize the financial viability of the entire project, as competitive state funding for affordable housing strongly prioritizes proposals that include supportive housing for formerly homeless individuals.I have always trusted that Santa Monica was a compassionate, humane city that believed in science and reason and treated everyone with dignity and respect. Please do not give in to the loudest and most hateful voices in our community. Instead, withdraw these cruel and counterproductive proposals and do what is best for our city.

My best,
Megan Kelly, 90405
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 479 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 3 David Yakobson
From: Santa Monica Forward <[email protected]> Sent: Tuesday, August 27, 2024 11:16 AM
To: councilmtgitems; Council Mailbox; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Jesse Zwick; Caroline Torosis; Oscar de la Torre Subject: City Council Items 10D, 16G, and 16J:

EXTERNAL
To help
protect your
privacy,
Micro so ft
Office
prevented
auto matic
download of
this picture
from the
Internet.

Dear Santa Monica City Council,
We are writing to express our strong opposition to Items 10D, 16G, and 16J, which would deny blankets to those sleeping on our streets, deny proven harm reduction and drug treatment strategies to those struggling to get clean, and deny housing opportunities to those ready to come inside.All three of these proposals run counter to every evidence-based best practice for solving homelessness and will without a doubt make our current crisis worse. And yet most stunning of all is the sheer cruelty of what is being proposed. To simultaneously deny an unhoused person a blanket and an alternative place to sleep is both mean and absurd.

8.A.c
Packet Pg. 480 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 4 costly ER visits, and connect people to substance-use treatment options. Proposals to eliminate these programs in Santa Monica would lead to more preventable deaths and less opportunities for people to get clean – and, as it stands, state law and County Department of Public Health policies supersede our local powers, thereby rendering this request illegal and unenforceable.

Please do not give in to the loudest and most hateful voices in our community. Instead, withdraw these cruel and counterproductive proposals and do what is best for our city. - Santa Monica Forward
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 481 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 5 David Yakobson
From: Council Mailbox
Sent: Tuesday, August 27, 2024 11:31 AM
To: councilmtgitems
Subject: Fw: Items 10D, 16G, and 16J: OPPOSED
Follow Up Flag: Follow up
Flag Status: Flagged
From: Dana Borowka <[email protected]>
Sent: Tuesday, August 27, 2024 11:21 AM
To: Council Mailbox <[email protected]>
Subject: Items 10D, 16G, and 16J: OPPOSED

Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 482 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 6 I have always trusted that Santa Monica was a compassionate, humane city that believed in science and reason and treated everyone with dignity and respect. Please do not give in to the loudest and most hateful voices in our community. Instead, withdraw these cruel and counterproductive proposals and do what is best for our city.

Dana and Ellen Borowka
90403
Have a great week!
Talk to you soon,
Dana
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 483 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 1 David Yakobson
From: Jason Mastbaum <[email protected]>
Sent: Tuesday, August 27, 2024 10:27 AM
To: Phil Brock; Oscar de la Torre; Gleam Davis; Christine Parra; Lana Negrete; Jesse Zwick; Caroline Torosis; councilmtgitems
Subject: City Council Items 10D, 16G, and 16J: OPPOSE
Follow Up Flag: Follow up
Flag Status: Flagged

EXTERNAL
Dear Mayor Brock Mayor Pro Tempore Negrete, and members of the Santa Monica City I am writing to express my strong opposition to Items 10D, 16G, and 16J, which would deny blankets to those sleeping on our streets, deny proven harm reduction and drug treatment strategies to those struggling to get clean, and deny housing opportunities to those ready to come inside.

I have always believed that Santa Monica was a compassionate, humane city that believed in science and reason and treated everyone with dignity and respect. Please do not give in to the loudest and most hateful voices in our community. Instead, withdraw these cruel and counterproductive proposals and do Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 484 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 2 what is best for our city.

Thank you.

Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 485 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 3 David Yakobson
From: Allon Percus <[email protected]>
Sent: Tuesday, August 27, 2024 9:51 AM
To: councilmtgitems
Subject: City Council Items 10D, 16G, and 16J: OPPOSE
Follow Up Flag: Follow up
Flag Status: Flagged

EXTERNAL
Council Comments ,
Dear Mayor Brock Mayor Pro Tempore Negrete, and members of the Santa Monica City I am writing to express my strong opposition to Items 10D, 16G, and 16J, which would deny blankets to those sleeping on our streets, deny proven harm reduction and drug treatment strategies to those struggling to get clean, and deny housing opportunities to those ready to come inside.

Re: Item 16G, harm reduction programs are evidence-based best practices that have been continually proven to prevent fatal overdoses, curb the spread of infectious disease, reduce costly ER visits, and connect people to substance-use treatment options. Proposals to eliminate these programs in Santa Monica would lead to more preventable deaths and less opportunities for people to get clean – and, as it stands, state law and County Department of Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 486 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 4 Public Health policies supersede our local powers, thereby rendering this request illegal and unenforceable.

Thank you.

Allon
California
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 487 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 1 David Yakobson
From: Steven Johnson <[email protected]>
Sent: Monday, August 26, 2024 5:08 PM
To: councilmtgitems; Lana Negrete; Caroline Torosis; Christine Parra; Gleam Davis; Oscar de la Torre
Cc: Andrew Gomez; Maryanne LaGuardia; John Smith; Ann Bowman; Lori Brown; Greg Morena
Subject: August 27, 2024 Council Meeting - Item 10.D - SUPPORT with comment Attachments: campfire-in-library-park.MOV

EXTERNAL
Dear Council Members,
I am writing in support of advancing Item 10.D to improve our anti-camping ordinance in Santa Monica.

As a member of the Recreation & Parks Commission, I regularly visit our neighborhood parks and often see large settlements crop up for the day and sometimes overnight. Lacking a tent, I'm afraid some of these settlements do not rise to the definition of "camping" in the ordinance, but any common sense observation would see that these set-ups are quite extensive, encroach public space and frequently discourage other park visitors.

As an example, pictured below is a fairly extensive encampment that remained in place at Ocean Park Library for several days not too long ago. I attach video, as well, to show that at night, the location even featured a campfire.

Thank you again for your consideration of this ordinance update, and I ask that you remain open to further improvements and enforcement in the future.
* * * * * * * * * *
Steven Johnson
Chair, Recreation & Parks Commission
Resident, Sunset Park
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 488 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 2 Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 489 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 1 David Yakobson
From: Caro Vilain <[email protected]>
Sent: Monday, August 26, 2024 10:45 PM
To: councilmtgitems; Council Mailbox; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Jesse Zwick; Caroline Torosis; Oscar de la Torre Subject: I oppose item 10D

EXTERNAL
Dear Council,
I strongly oppose item 10D. I’m ashamed to see my city treat people experiencing homelessness like they aren’t human beings. We must tackle the root of the issue rather than attack the victims of the problems we are exacerbating by not building enough housing quickly enough.

For anyone who will be voting on this item but didn’t take the time to read the report, here is a paragraph from it:
"The decision does not legally require the City to do anything differently, either in legislation or practices.

There are many legal, resource, and reality considerations. The decision will not eliminate homelessness, but there are some nuanced changes that could be initiated.

Even if sleeping on public property could be completely outlawed, it will not end. Even if it is legally prohibited, resources must be available and there must be the will to cite or arrest, prosecute, then despite zero bail and even if a case makes it to court and the defendant appears, and a jury were to convict, there certainly are not resources nor the will to hold those convicted of low level crimes such as sleeping in public in the County jail. Until there are substantially greater resources available for mental health treatment, substance abuse prevention and treatment, and housing (shelter, transitional, and/or permanent housing), as people necessarily must sleep somewhere, the issue will not be resolved by this Court decision."
Please oppose item 10D, treat all people with dignity, and provide them with resources, which some of you don’t seem interested in doing since some of the 16 items on this agenda do exactly the opposite.

Caro Vilain, 90404
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 490 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 2 David Yakobson
From: Dustin Shahan <[email protected]>
Sent: Monday, August 26, 2024 9:48 PM
To: councilmtgitems; Council Mailbox; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Jesse Zwick; Caroline Torosis; Oscar de la Torre Subject: 10D: oppose changes to municipal code

EXTERNAL
Good evening,
Please oppose the changes to the municipal code outlines in option 2. Attempting to treat the symptom of the homeless crisis through heartless action will not yield any benefits.

Either option 1 or 3 should be taken to allow the city to develop a plan to truly address this crisis in an effective, compassionate, and legal way.

Thanks
Dustin Shahan
90401
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 491 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 3 David Yakobson
From: Brian Sweeney <[email protected]>
Sent: Monday, August 26, 2024 9:19 PM
To: councilmtgitems
Subject: Item 10D: Support for Option 1

EXTERNAL
Dear Mayor Brock and honorable City Council members,
I'm writing in support of Option 1 for Item10D. While I understand the community's frustration around homelessness and the myriad public safety posed by the housing crisis, we already have a robust and enforced anti-camping ordinance (and for anyone who doubts its enforcement, I invite them to take a look at the difference between the Santa Monica and Los Angeles side of Centinela under the 405).

And in that context, I simply do not understand how an additional ban on blankets and bedrolls is going to make a difference re: public safety. Since we're unlikely to have the resources to enforce it against all, it will likely only be enforced against those who are already having other serious problems-and if that's the case, I truly doubt the absence/presence of a blanket/bedroll is going to make the difference as to whether or not PD (or the City) is able to take some enforcement action against any particular individual.

As the City Attorney writes, "Even if sleeping on public property could be completely outlawed, it will not end....current laws do not allow people to be forced to accept shelter, and people can decline to accept shelter." Since that's the case, and thus people will be sleeping outside anyway, why take away people's blankets--frankly, as it gets colder at night, putting them at risk for all sorts of health issues (including possible death)--when it's not going to have an impact on public safety or PD's ability to do their jobs?
I do think our homelessness crisis poses serious public safety risks for both housed and unhoused individuals--but a blanket ban is not the way to ameliorate those issues.

Thank you,
Brian Sweeney
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 492 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 4 David Yakobson
From: Jacob Wasserman <[email protected]>
Sent: Monday, August 26, 2024 8:55 PM
To: Council Mailbox; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Jesse Zwick; Caroline Torosis; Oscar de la Torre; councilmtgitems
Subject: Item 10.D: Against Criminalizing Our Unhoused Neighbors

Legal scholars have argued that such ordinances violate basic human rights. The crisis requires far more beds and shelter space than we have available.

I would hate to see the City side with the conservative wing of the Supreme Court here.

Thanks,
Jacob Wasserman
11th and Washington
90403
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 493 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) 1 David Yakobson
From: Peter DiChellis <[email protected]>
Sent: Friday, August 23, 2024 2:26 PM
To: councilmtgitems
Subject: ITEM 10 D Camping in Public Places

EXTERNAL
I strongly support expanding this prohibition despite the City Attorney all but promising his office will refuse to prosecute a valid and enforceable law, in defiance of any Council decision on the matter.

Time for a new City Attorney? The answer is almost certainly “yes” because Santa Monica needs a dramatic turnaround in its long-failed stance on homelessness, and passive-aggressive bureaucrats should not be allowed to stand in the way.

Sincerely,
Peter DiChellis
Santa Monica
Item 8-A
September 10, 2024
Item 8-A
September 10, 2024

8.A.c
Packet Pg. 494 Attachment: Written Comments [Revision 3] (6596 : Camping Ordinance) City Council
Report
City Council Meeting: September 10, 2024
Agenda Item: 8.B
1 of 2
To: Mayor and City Council
From: Douglas Sloan, City Attorney, City Attorney's Office, Administration Subject: Introduction for First Reading of an Ordinance Adding Santa Monica Municipal Code Section 2.32.290 to Prohibit Acceptance of Gratuities by Public Officials (Continued from 8/27/2024 and Public Input will be heard.) Recommended Action
Staff recommends that Council:

1. Adopt a finding of categorical exemption pursuant to Section 15061(b)(3) (Common Sense Exemption) of the California Environmental Quality Act (CEQA) Guidelines

2. Introduce for first reading an Ordinance to add Section 2.32.290 to the Santa Monica Municipal Code prohibiting the acceptance of gratuities by public officials Summary
The Council approved a 16 Item to direct the City Attorney to address the recent U.S.

Supreme Court decision Snyder v. United States, which, absent a clear ban on gratuities by a local jurisdiction, purports to allow city officials to accept gratuities. The proposed ordinance will prohibit acceptance of gratuities by public officials as a reward or token of appreciation for any official act performed by the public official.

Discussion
The decision in Snyder v. United States stated that providing state and local officials with tokens of appreciation for their official action, for example, gift cards, meals, event tickets, or cash payments, do not subject those officials to federal prosecution. At the same time, the Court reiterated that the decision does not affect the ability of state and local governments to regulate gratuities. A gratuity differs from a bribe in that a gratuity is given after, rather than before, the official act.

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The proposed ordinance will prohibit any City official from accepting or soliciting, directly or indirectly, anything of value from any person to whom the official has conferred a public benefit within the last twelve months, intended as a reward or token of appreciation for or because of an official act performed by the public official. Violations may be prosecuted as a misdemeanor, or by an administrative fine of up to $500 per violation.

Financial Impacts and Budget Actions
There is no immediate financial impact or budget action necessary as a result of the proposed action.

Prepared By: Douglas Sloan, City Attorney
Approved Forwarded to Council
Attachments:

A. ORD-CAO-ord-Gratuity 091024
B. Written Comments

8.B
Packet Pg. 496
1 City Council Meeting: September 10, 2024 Santa Monica, California ORDINANCE NUMBER _________ (CCS)
(City Council Series)

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF
SANTA MONICA ADDING SECTION 2.32.290 PROHIBITING ACCEPTANCE OF

GRATUITIES BY CITY OFFICIALS
WHEREAS, the United States Supreme Court recently ruled that anti-bribery laws do not make it a crime for local officials to accept a gratuity for official acts they have already taken; and
WHEREAS, the Council believes it is unacceptable for City officials to receive gratuities for acts performed in their official capacity, and hereby formalizes the prohibition on so doing.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF SANTA MONICA DOES HEREBY ORDAIN AS FOLLOWS:

SECTION 1. Santa Monica Municipal Code Section 2.32.290 is hereby added to read as follows:

2.32.290. PROHIBITION ON GRATUITIES
(a) No City official shall receive, accept, take, seek, or solicit, directly or indirectly, anything of economic value as a gift, gratuity, or favor, from any person or entity to whom the official has conferred a public benefit within the last 12 months, intended as a reward or token of appreciation for or because of any official act performed by the public official. This Section shall be in addition to the provisions of Charter Section XXII, the Taxpayer Protection Act.

8.B.a
Packet Pg. 497 Attachment: ORD-CAO-ord-Gratuity 091024 (6598 : Gratuities Prohibition Ordinance 9-10) 2 (b) As used herein, the term “public benefit” does not include public employment in the normal course of business for services rendered, but includes a contract, benefit, permit, or arrangement between the City and any individual, corporation, firm, partnership, association, or other person or entity to:
(1) provide services of a value in excess of $5,000 over any 12-month period;
(2) sell or furnish any material, supplies or equipment to the City of a value in excess of $5,000 over any 12 month period;
(3) buy or sell any real property to or from the City with a value in excess of $5,000, or lease or license any real property to or from the City with a value in excess of $5,000 over any 12-month period;
(4) receive an award of a franchise to conduct any business activity in a territory, and for which gross revenue from the business activity exceeds $5,000 in any 12-month period;
(5) confer a land use variance, special use permit, or other exception to a pre-existing master plan or land use ordinance pertaining to real property where such decision has a value in excess of $5,000;
(6) confer a tax abatement, exception, or benefit not generally applicable of a value in excess of $5,000 in any 12-month period; or
(7) receive cash or property of a net value to the recipient in excess of $5,000 in any 12-month period.
(c) Those persons or entities receiving public benefits as defined above shall include the individual, corporation, firm, partnership, association, or other person or entity

8.B.a
Packet Pg. 498 Attachment: ORD-CAO-ord-Gratuity 091024 (6598 : Gratuities Prohibition Ordinance 9-10) 3 so benefiting, and any individual or person who, during a period where such benefit is received or accrues,
(1) has more than a five percent (5%) equity, participation, or revenue interest in that entity, or
(2) who is a trustee, director, partner, or officer of that entity or of another entity that owns or controls the entity receiving the public benefit, excepting persons serving in those capacities as volunteers, without compensation, for organizations exempt from income taxes under Section 501(c)(3), (4), or (6) of the Internal Revenue Code.

However, this exception shall not apply if the organization is a political committee or controls political committees as defined by California Government Code Section 82013 or 2 U.S.C. Section 431(4) or successor provisions.
(d) As used herein, the term “public official” includes any elected or appointed public official acting in an official capacity. This includes, but is not limited to: City Council members, Planning Commission members, and the City Manager, City Attorney, City Clerk, and Department Heads and their designees who may confer public benefits as defined in this section.
(e) Each violation of the provisions of this Chapter shall constitute a misdemeanor. Alternatively, a civil action may also be brought by the City or any interested party before any court of competent jurisdiction. In addition to all other remedies authorized by law, the court may impose a fine of up to five hundred dollars for each violation of this Chapter.

SECTION 2. Any provision of the Santa Monica Municipal Code or appendices thereto inconsistent with the provisions of this Ordinance, to the extent of such

8.B.a
Packet Pg. 499 Attachment: ORD-CAO-ord-Gratuity 091024 (6598 : Gratuities Prohibition Ordinance 9-10) 4 inconsistencies and no further, is hereby repealed or modified to that extent necessary to effect the provisions of this Ordinance.

APPROVED AS TO FORM:
_________________________
Douglas Sloan, City Attorney

8.B.a
Packet Pg. 500 Attachment: ORD-CAO-ord-Gratuity 091024 (6598 : Gratuities Prohibition Ordinance 9-10) 1 David Yakobson
From: Cynthia Rose <[email protected]>
Sent: Tuesday, August 27, 2024 2:11 PM
To: councilmtgitems; Council Mailbox; Gleam Davis; Jesse Zwick; Caroline Torosis; Lana Negrete; Oscar de la Torre; Phil Brock; Christine Parra; David White Cc: [email protected]; [email protected] Subject: August 27th Agenda: Support items 10C-11A -- Opposed items 16F-16G Attachments: 2024-08 CC Agenda items- 10C-11A-16F-16G.pdf

EXTERNAL
Please see the attached letter in support of Agenda Items 10C and 11A and in opposition to Agenda Items 16F and 16G.

Cynthia Rose Cris Gutierrez and Anya Baroff
--
Cynthia Rose
Co-Chair
Santa Monica Safe Streets Alliance
SaMoSafeStreets.org
I acknowledge with respect and gratitude the Tongva, Kizh, and Chumash Peoples on whose traditional territory I live and work.

Item 8-B
September 10, 2024
Item 8-B
September 10, 2024

8.B.b
Packet Pg. 501 Attachment: Written Comments (6598 : Gratuities Prohibition Ordinance 9-10)

August 27, 2024
RE: Agenda Items: 10C, 11A, 16F, 16G
Dear Mayor and City Council Members:

Santa Monica Safe Streets Alliance and community human rights advocate are writing in support of Agenda Items 10C and 11A and in opposition to Agenda Items 16F and 16G.

Support — Agenda Item 10C:

We support this common sense, ethical and accountable approach to preventing the appearance of bias with the acceptance of gratuities by our public officials. Also of concern is public officials awarding gratuities to special interests.

Support – Agenda item 11A:

Our Santa Monica values and priorities for a safe and clean community and robust economic recovery cannot be realized without a humane approach to provide more affordable homes. It is not only our civic and moral duty but the law. How else could anyone really expect to help solve the affordability and unhoused problems? We ask that you stay the course and continue to thoughtfully and expeditiously move these projects forward and not allow them to be undermined by a few loud and privileged voices. Santa Monica needs your thoughtful and steadfast leadership.

Oppose – Agenda item 16F:

We cannot solve our problems - in fact we create more grave problems - by ignoring the solutions to and needed compassion for those in crisis and in need. It is proven that to get our vulnerable population the help they need - we must meet them where they are. We must not vilify humans in crisis and deny them the very services they must have to survive and lift themselves out of homelessness and addiction. That is the essence of what we hope to live up to in Santa Monica – to be a compassionate and mature community.

Oppose - Agenda item 16G
As expressed in opposition to Agenda Item 16F: We cannot solve our problems - in fact we create more grave problems - by ignoring the solutions to and needed compassion for those in crisis and in need. It is proven that to get our vulnerable population the help they need - we must meet them where they are. We must not vilify humans in crisis and deny them the very services they must have to survive and lift themselves out of homelessness and addiction. That is the essence of what we hope to live up to in Santa Monica – to be a compassionate and mature community. We ALL need to do our part to support those in need – not kick them or the issue down the road or across city lines.

8.B.b
Packet Pg. 502 Attachment: Written Comments (6598 : Gratuities Prohibition Ordinance 9-10) City Council
Report
City Council Meeting: September 10, 2024
Agenda Item: 10.A
1 of 6
To: Mayor and City Council
From: Douglas Sloan, City Attorney, City Attorney's Office, Administration Subject: Introduction and First Reading of an Ordinance Amending the City’s Hotel Worker Protection Ordinance
Recommended Action
Staff Recommends that the City Council:

1. Adopt a finding of no possibility of significant effect pursuant to Section 15061(b)(3) (Common Sense Exemption) of the California Environmental Quality Act (CEQA);

2. Introduce for first reading an ordinance amending the City’s Hotel Worker Protection Ordinance (HWPO).

Executive Summary
In September of 2019, at the recommendation of the City’s Commission on the Status of Women, Council adopted the HWPO, which includes measures intended to protect hotel room attendants and other hotel employees from sexual violence and worker exploitation, including provision of panic buttons and protection against excessive workload.

Staff presented several enforcement options, including enforcement through lawsuits, and collaborative civil citation enforcement with the Los Angeles County Department of Business and Consumer Affairs (DCBA), which is used for enforcement of the City’s minimum wage and employee benefit protections. Due to resource constraints at that time, DCBA was unable to assist with enforcement.

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In the years that followed, the City has received several complaints regarding violation of the protections against excessive workload and has sought the expert advice of DCBA on an informal basis. Given present staff capacity, DCBA is now supportive of collaborative enforcement for the workload provision. The proposed amendments would authorize civil citation enforcement as an enforcement method for the workload provision and add several complementary provisions, including clarifying and strengthening the record keeping requirement, and mandating cooperation with Cityauthorized investigators.

Discussion
Municipal Code Section 4.67.030, “Measures to provide fair compensation for workload,” was enacted to respond to concerns that housekeepers were required to work unreasonable workloads within the normal workday, resulting in less satisfactory work, lesser protection of public health, and strain on the workers. The City adopted a provision similar to ordinances that had previously been passed in Long Beach, Oakland, Seattle, Emeryville, and for airport hotel workers in the City of Los Angeles.

The HWPO currently requires that room attendants who clean above the specified threshold of rooms or square footage in an 8-hour day must be paid two times their normal rate of pay for the entire day. The HWPO sets the maximum workload amount as 4,000 square feet for hotels with fewer than forty guest rooms, and 3,500 square feet for hotels with more than forty guest rooms. It also specifies that if any attendant is required to clean seven or more checkout rooms or rooms with extra beds, such as a cot or rollaway bed, the threshold is automatically reached. Thus, once an attendant cleans seven checkout rooms or rooms with extra beds, if she cleans any additional space, she must be paid the double rate for the entire day.

Due to capacity limitations when it was passed, the HWPO did not authorize civil citation enforcement of the workload provision. The only existing enforcement method is by lawsuit brought by the City or any aggrieved person. DCBA now has capacity to assist with enforcement. The proposed amendments would authorize and support civil citation enforcement, which will be carried out in collaboration with DCBA, clarify and

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strengthen the record keeping requirements, and mandate hotel employers’ cooperation with City-authorized investigators.

A. Amendments to 4.67.030(d), Records Requirement for Fair Compensation for Workload Protections
In relevant part, SMMC 4.67.030(d) currently reads as follows:

Each hotel employer shall maintain for at least two years a record of each room attendant's name, rate of pay, pay received, rooms cleaned or total square footage cleaned for each workday, overtime hours worked for each workday, and any written consents provided pursuant to subsection (b) above[.]
While it is clear in context that a hotel employer is already required to maintain records sufficient to demonstrate compliance with the workload provision, the HWPO does not explicitly state that hotel employers must document the number of checkout rooms and rooms with extra beds that each room attendant cleans each day. Because cleaning seven such rooms automatically triggers the threshold after which attendants must be paid double their normal rate of pay for the whole day, this information is necessary to evaluate compliance. The proposed amendment would clarify that hotel employers are required to document the number of such rooms cleaned by each attendant each day and to maintain all original records used to document workload.

It is likewise clear in context that a hotel employer must maintain records in a sufficiently legible format that compliance can be determined with reasonable effort. Nonetheless, in investigating complaints under the workload provision, the City Attorney’s Office has received vague, inconsistent, and/or illegible records. The proposed amendments would clarify that in addition to maintaining all original records used to track workload, a hotel employer shall maintain a daily summary of the workload information in a legible format.

B. Addition of Law enforcement access, remedies, and penalties (1) Records and Interview Access
Unlike the minimum wage and hotel worker living wage ordinances, the HWPO does not currently have a provision mandating compliance with City-authorized investigators, including access to records and permitting interviews with workers during normal

10.A
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4 of 6
business hours. Adding this provision will facilitate efficient enforcement and enable DCBA to issue citations for refusal to provide records or other information necessary to determine whether a violation has occurred.
(2) Increase in maximum daily penalty for record keeping Currently, the damages and penalties provision provides that any person who violates any provision of the HWPO is liable for actual damages suffered by any aggrieved person or for statutory damages of up to one hundred dollars per aggrieved person per day, but with a cap of $1,000 per day for failure to maintain records. This means that even where a large hotel employer completely fails to maintain the required records for tens or hundreds of employees, making it impossible to know if they’ve complied with the workload requirement, statutory damages are capped as if they had only ten employees. The amendments would increase the cap to $3,000, or the equivalent of $100 in statutory damages for thirty employees. The increased damages amount will serve as a more meaningful deterrent for large hotel employers. (3) Authorizing civil citation enforcement
Given resource constraints at the time the HWPO was passed, DCBA did not support collaborative civil citation enforcement of the workload provision. With increased capacity, and complaints received regarding the HWPO’s workload provision, DCBA now supports such enforcement. DCBA has been the primary enforcement entity for minimum wage and employee benefit violations under the City’s Minimum Wage Ordinance and Hotel Living Wage Ordinance. DCBA has experience with these types of investigations, including requesting, receiving and organizing records, entering and analyzing data obtained from such records, and issuing appropriate citations and demands for corrective action, such as payment of back wages. Collaborative civil citation enforcement will allow the City to take advantage of DCBA’s expertise to efficiently respond to complaints of violation of the workload provision.

The proposed amendments would permit civil citation enforcement by enacting a provision authorizing the issuance of administrative citations pursuant to Chapter 1.09 of the Code. This is the same authorization used in the City’s minimum wage and hotel

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living wage laws. The amendments would make the fine amounts the same as those for violations of the minimum wage payment and minimum wage record keeping requirements. The amendments would not alter the existing authority for enforcement through civil lawsuits.

Feedback
Representatives of Unite Here Local 11 have expressed support for these amendments to improve compliance and enforcement of these worker protections. Representatives from Santa Monica Travel and Tourism were consulted and have not expressed opposition to these amendments.

Conclusion
For the foregoing reasons, staff finds that there is a significant public interest in making these amendments to the HWPO.

Enforcement
The City Attorney’s Office Consumer Protection Unit will conduct outreach and education about these amendments. The City Attorney’s Office will continue to take complaints regarding violations of the HWPO and will forward complaints under the workload provision to DCBA for investigation and collaborative enforcement, including civil citation where appropriate.

Financial Impacts & Budget Actions
Enforcement services will be provided pursuant to existing authority and no further action by Council is necessary to authorize this allocation.

Prepared By: Romy Ganschow, Chief Deputy City Attorney
Approved Forwarded to Council

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Attachments:

A. ORD-CAO-Hotel Worker Protections
B. PowerPoint Presentation

10.A
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1 City Council Meeting: September 10, 2024 Santa Monica, California ORDINANCE NUMBER ____ (CCS)
(City Council Series)

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF SANTA

MONICA AMENDING SANTA MONICA MUNICIPAL CODE
SECTION 4.67.030 AND ADDING SECTION 4.67.115 RELATING TO HOTEL

WORKER PROTECTIONS
WHEREAS, on September 10, 2019, the City Council of the City of Santa Monica adopted Ordinance No. 2614 (CCS), adding Chapter 4.67 to the Santa Monica Municipal Code (the “Hotel Worker Protection Ordinance”), to protect hotel workers from physical violence, provide them fair compensation for workload, and require education and training to enable hotel workers to protect their own rights and safety as well as public health and safety; and
WHEREAS, hotel workers have been subject to being assigned overly burdensome workloads and unexpected overtime; and
WHEREAS, ensuring that hotel workers receive fair compensation when their work assignments exceed proscribed limits promotes the public interest and enables hotel workers to receive fair pay for honest work, to perform their work in a manner that adequately protects their personal wellbeing, and to meet personal and family obligations; and
WHEREAS, enforcement of the existing requirement for fair compensation for workload has been hampered by the inability to obtain accurate and legible records that provide information necessary to ascertain compliance in a reasonably concise and organized manner; and

10.A.a
Packet Pg. 509 Attachment: ORD-CAO-Hotel Worker Protections (6566 : Hotel Worker Ord) 2 WHEREAS, third-party contractors and staffing agencies with limited experience operating in Santa Monica are often not aware of the fair compensation for workload provision and the corresponding records requirement and consequently, may not be maintaining sufficiently detailed records of hotel workers’ workload; and WHEREAS, given limited enforcement resources at the time that the Hotel Worker Protection Ordinance was first enacted, said ordinance currently lacks authority for administrative citation enforcement, which has proven effective for the City’s other minimum wage and living wage ordinances; and
WHEREAS, authorizing an administrative citation enforcement mechanism for the workload provision of the Hotel Worker Protection Ordinance will further the public health, safety, and welfare.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF SANTA MONICA DOES HEREBY ORDAIN AS FOLLOWS:

SECTION 1. Santa Monica Municipal Code Section 4.67.030, subsection (d), is hereby amended to read as follows:

4.67.030 Measures to provide fair compensation for workload. (a) Workload Limitation. For hotels with fewer than forty guest rooms, a hotel employer shall not require a room attendant to clean rooms amounting to a total of more than four thousand square feet of floor space in any eight-hour workday, unless the hotel employer pays the room attendant twice the room attendant's regular rate of pay for each and every hour worked during the workday. For hotels with forty or more guest rooms, a hotel employer shall not require a room attendant to clean rooms amounting to a total of more than three thousand five hundred square feet of floor space in any eight-hour

10.A.a
Packet Pg. 510 Attachment: ORD-CAO-Hotel Worker Protections (6566 : Hotel Worker Ord) 3 workday, unless the hotel employer pays the room attendant twice the room attendant's regular rate of pay for each and every hour worked during the workday. If a room attendant is assigned to clean seven or more checkout or additional bed rooms during any eight-hour workday, each such checkout or additional bed room shall for purposes of this subsection count as five hundred square feet, regardless of the actual square footage of each room. The limitations contained herein apply to any combination of spaces, including guest rooms, meeting rooms, and other rooms within the hotel, and apply regardless of the furniture, equipment, or amenities in such rooms. (b) Workload Proration. The maximum floor space set forth in subsection (a) shall be reduced on a prorated basis if a room attendant works less than eight hours in a workday, shall be increased on a prorated basis for each hour of overtime that a room attendant works in excess of eight hours in a workday, and shall be calculated on a prorated basis by room attendant if a room attendant is assigned to clean rooms jointly with one or more other room attendants.
(c) Voluntary Overtime. A hotel employer shall not require or permit a hotel worker to work more than ten hours in a workday unless the hotel worker consents in writing to do so. A hotel worker's consent shall not be valid unless the hotel employer has advised the hotel worker in writing seven days prior to the hotel worker's consent that the hotel worker may decline to work more than ten hours in a workday and that the hotel employer will not subject the hotel worker to any adverse employment action for declining to work more than ten hours in a workday. This subsection shall not apply in the event of an emergency.

10.A.a
Packet Pg. 511 Attachment: ORD-CAO-Hotel Worker Protections (6566 : Hotel Worker Ord) 4 (d) Preservation of Records. Each hotel employer shall maintain for at least two three years a record of each room attendant's name, rate of pay, pay received, rooms cleaned or total square footage cleaned for each workday, overtime hours worked for each workday, and any written consents provided pursuant to subsection (b) above. A hotel employer shall make these records available for inspection and copying to any hotel worker or hotel worker's employee representative, except that the names and other personally identifying information of individual hotel workers shall be redacted except to the extent that the records identify the hotel worker who is making the request. the following information for each room attendant for each workday:
(1) Name, rate of pay, and pay received;
(2) Total number of rooms cleaned;
(3) Total square footage of rooms cleaned;
(4) Number of additional bed rooms cleaned;
(5) Number of checkout rooms cleaned;
(6) Overtime hours worked; and
(7) Any written consents provided pursuant to subsection (c) above.

Hotel employers shall maintain all original records relating to Section 4.67.030(a) and documenting the above information, including without limitation hotel booking records; sign-in sheets; assignment sheets; tabulations by housekeepers, supervisors or other employees, agents or contractors of the hotel employer; and any other documents or records used to track workload each day. In addition to the original records described above, a hotel employer shall maintain for at least three years a daily summary of the room attendant’s name and the information in (2) through (5) above in a reasonably legible

10.A.a
Packet Pg. 512 Attachment: ORD-CAO-Hotel Worker Protections (6566 : Hotel Worker Ord) 5 format, such that compliance with Section 4.67.030(a) for any day over the three-year period can be ascertained without reference to any other documents. A hotel employer that uses a contractor or staffing agency to provide room attendants remains responsible for maintaining both the daily original records and summary records. A hotel employer shall make these records available for inspection and copying to any hotel worker or hotel worker's employee representative, except that the names and other personally identifying information of individual hotel workers shall be redacted except to the extent that the records identify the hotel worker who is making the request.

SECTION 2. Santa Monica Municipal Code Section 4.67.115 is hereby added to read as follows:

4.67.115 Law enforcement access, remedies, penalties.
(a) Records and Interview Access; Cooperation with Investigations. To monitor and investigate compliance with the requirements of this Chapter, every hotel employer shall cooperate with City-authorized investigators, including, but not limited to: accessing records, and allowing investigators to interview persons, including hotel workers, during normal business hours.
(b) Any person violating subsection (a), section 4.67.030, or any rule or regulation adopted pursuant to this Chapter, may be subject to administrative citation pursuant to Chapter 1.09 of this Code.
(c) Unless otherwise specifically provided, the fine amount for a violation of subsection (a) of section 4.67.030 shall be the same as the fine amount for a violation of section 4.63.015; the fine amount for a violation of subsection (d) of section 4.67.030 shall be the same as the fine amount for a violation of subsection (g) of section 4.62.015; and

10.A.a
Packet Pg. 513 Attachment: ORD-CAO-Hotel Worker Protections (6566 : Hotel Worker Ord) 6 the fine amount for a violation of subsection (a) shall be the same as the fine amount for violation of subsection (a) of section 4.62.100.

SECTION 3. Santa Monica Municipal Code Section 4.67.120 is hereby amended to read as follows:
(a) Civil Action. The City or any aggrieved person may enforce the provisions of this Chapter by means of a civil action.
(b) Injunction. Any person who commits an act, proposes to commit an act, or engages in any pattern or practice that violates this Chapter may be enjoined therefrom by a court of competent jurisdiction. An action for injunction under this subsection may be brought by any aggrieved person, by the City Attorney, or by any person or entity who will fairly and adequately represent the interests of an aggrieved person or persons. (c) Damages and Penalties. Any person who violates the provisions of this Chapter is liable for any actual damages suffered by any aggrieved person or for statutory damages up to the amount of one hundred dollars per aggrieved person per day, except that statutory damages for failure to maintain records shall not exceed one three thousand dollars per day in total. For willful violations, the amount of monies and penalties to be paid under this subsection shall be trebled.
(d) Attorneys' Fees and Costs. In a civil action brought under this Section, the court shall award the prevailing party reasonable attorneys' fees and costs, including expert witness fees, except that, notwithstanding Section 998 of the Code of Civil Procedure, a prevailing defendant shall not be awarded fees and costs unless the court finds the action was frivolous, unreasonable, or groundless when brought, or the plaintiff continued to litigate after it clearly became so.

10.A.a
Packet Pg. 514 Attachment: ORD-CAO-Hotel Worker Protections (6566 : Hotel Worker Ord) 7 (e) Cumulative Remedies. The remedies set forth in this Chapter are cumulative.

Nothing in this Chapter shall be interpreted as restricting, precluding, or otherwise limiting a separate or concurrent criminal prosecution under this Code or State law.

SECTION 4. Any provision of the Santa Monica Municipal Code or appendices thereto inconsistent with the provisions of this Ordinance, to the extent of such inconsistencies and no further, is hereby repealed or modified to that extent necessary to effect the provisions of this Ordinance.

SECTION 5. If any section, subsection, sentence, clause, or phrase of this Ordinance is for any reason held to be invalid or unconstitutional by a decision of any court of competent jurisdiction, such decision shall not affect the validity of the remaining portions of this Ordinance. The City Council hereby declares that it would have passed this Ordinance and each and every section, subsection, sentence, clause, or phrase not declared invalid or unconstitutional without regard to whether any portion of the ordinance would be subsequently declared invalid or unconstitutional.

SECTION 6. The Mayor shall sign and the City Clerk shall attest to the passage of this Ordinance. The City Clerk shall cause the same to be published once in the official newspaper within 15 days after its adoption. This Ordinance shall become effective 30 days from its adoption.

APPROVED AS TO FORM:
_________________________
Douglas Sloan, City Attorney

10.A.a
Packet Pg. 515 Attachment: ORD-CAO-Hotel Worker Protections (6566 : Hotel Worker Ord)

PROPOSED AMENDMENTS

TO THE HOTEL WORKER

PROTECTION ORDINANCE
SMMC CHAPTER 4.67
Item 10-A
September 10, 2024
Item 10-A
September 10, 2024

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FAIR COMPENSATION FOR WORKLOAD
REQUIREMENT: SMMC 4.67.030
• Adopted to respond to concerns about unreasonable workloads negatively affecting housekeepers and public health
• Square footage threshold, if exceeded 2x pay for the entire day • Seven checkout rooms or rooms with extra bed = automatic trigger • Records requirement doesn’t specify each category needed to determine compliance • Due to capacity concerns, only explicitly authorized enforcement by lawsuit Item 10-A
September 10, 2024
Item 10-A
September 10, 2024

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AUTHORIZING CIVIL CITATION ENFORCEMENT
• Collaboration with County Department of Consumer and Business Affairs (DCBA), like current enforcement of minimum wage and benefit laws
• For violation of workload, workload records, and compliance with investigation • Citation with the right to administrative appeal, hearing before local hearing examiner • Opportunity to engage in settlement negotiations after appeal Item 10-A
September 10, 2024
Item 10-A
September 10, 2024

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Packet Pg. 518 Attachment: PowerPoint Presentation [Revision 1] (6566 : Hotel Worker Ord) • Fine amounts match those for minimum wage ($500 per violation) • 4.63.015 hotel worker minimum wage
• 4.62.015(g) record keeping
• Total daily statutory damages maximum stays $100 per employee, but max for recordkeeping increased to $3000
Item 10-A
September 10, 2024
Item 10-A
September 10, 2024

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CLARIFICATION OF RECORDKEEPING

REQUIREMENT
• Investigation Challenges
• Increased from two to three years
• Must track total number of rooms, square footage, number of checkout rooms, number of rooms with extra beds (“additional bed rooms”)
• Maintain original records, e.g. workload assignment sheets • Keep daily summary records in legible format, like a spreadsheet • Must be able to determine compliance without reference to other records Item 10-A
September 10, 2024
Item 10-A
September 10, 2024

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Packet Pg. 520 Attachment: PowerPoint Presentation [Revision 1] (6566 : Hotel Worker Ord) City Council
Report
City Council Meeting: September 10, 2024
Agenda Item: 10.B
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To: Mayor and City Council
From: Rick Valte, Public Works Director, Public Works, Office of Sustainability & the Environment
Subject: Introduce for First Reading Local Amendment Ordinance to the 2022 California Energy Code for Energy Performance Approach Reach Code for New Construction and Adoption of Resolution
Recommended Action
Staff recommends that the City Council:

1. Adopt a finding of Categorical Exemption pursuant to Section 15308 and a finding of no possibility of significant effect pursuant to Section 15061(b)(3) of the California Environmental Quality Act (CEQA) Guidelines;

2. Introduce for first reading an ordinance repealing Santa Monica Municipal Code (SMMC) Chapter 8.38 Zero Emission Building Code, amending SMMC Section

8.08.040 to remove reference to the Zero Emission Building Code, and adopting local amendments to the 2022 California Energy Code under SMMC Chapter

8.36 to support improved energy performance in new buildings;

3. Adopt a resolution that provides findings of energy and cost savings as required to adopt local amendments to the 2022 California Energy Code; and

4. Direct the City Manager to file the adopted resolution and ordinance with the California Energy Commission following the second reading of the ordinance.

Summary
If adopted, the proposed Energy Performance Approach would replace the Zero Emission Building Code to achieve the intended outcome of low-emission new buildings within the existing legal and regulatory framework, which has evolved over the last two years. The Energy Performance Approach provides the best and most timely opportunity to continue pursuing Council’s adopted climate action goals described in the Climate Action and Adaptation Plan (Attachment A), which recommends adopting

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carbon neutral construction codes for new residential, commercial, and multi-family properties.

In 2022, Santa Monica joined over 60 California cities in adopting an all-electric requirement for new construction. Called the Zero Emissions Building Code, the policy ensured that nearly all new buildings would be free from natural gas, drastically reducing the carbon footprint of Santa Monica’s new building stock and ensuring improved indoor air quality for building occupants.

On April 17, 2023, a three-judge panel of the Ninth Circuit Court of Appeals ruled in California Restaurant Association v. City of Berkeley, that a similar Berkeley zero emission building code requiring all-electric new buildings was pre-empted by the federal Energy Policy and Conservation Act of 1975 (EPCA). In January 2024, the U.S.

Court of Appeals for the Ninth Circuit, en banc, denied Berkeley's petition for the court to re-hear the case, which left the 2023 decision in effect. Berkeley has chosen not to further appeal the April 17 panel ruling. This ruling affects the ability to continue enforcing zero emission building ordinances in most of the 60 local jurisdictions in California.

In January 2024, the City instituted an administrative stay on enforcement of the Zero Emissions Building Code and began exploring alternative compliance pathways to achieve the City’s goals of reducing carbon emissions from new buildings. The recommended alternative, called the Energy Performance Approach, is a local amendment to the 2022 California Energy Code.

Discussion
In 2019, Council adopted a goal of reducing communitywide carbon emissions 80% below 1990 levels by 2030 and achieving carbon neutrality (zero carbon dioxide emissions) by 2050 or sooner. To achieve carbon neutrality, net increases in carbon emissions from new construction and development must be mitigated by efficient design, construction, and use of on-site and grid-supplied renewable energy. As most buildings have zero emissions electricity sources supplied by the City’s community

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choice aggregator, Clean Power Alliance, methane gas remains the largest source of emissions in buildings.

In 2019, Santa Monica was one of the first cities in the State to adopt an electricpreferred Reach Code, which incentivized all-electric buildings by requiring a higher level of energy efficiency for mixed-fuel buildings. All-electric buildings were not subject to higher levels of energy efficiency and could be built to the State’s standard design requirements.

In 2022, Santa Monica went a step further by adopting the Zero Emission Building Code (ZEB), which required all new buildings to be fully electric, with exemptions for commercial kitchens (though they had to be electric-ready), medical facilities, and labs.

All-electric buildings were proven cost-effective by the Statewide Utility Codes and Standards 2019 study, in addition to the many health, environmental, and safety benefits of removing gas from new buildings. The 2022 ZEB was implemented by adding a new Chapter to the Santa Monica Municipal Code, Chapter 8.38. This effective approach to curbing emissions from new buildings was threatened by the Berkeley legal challenge in 2023, causing many cities to pause enforcement and develop alternative building policies.

In light of the 9th Circuit Panel’s ruling, staff and technical consultants, alongside a growing body of state and local policy-makers, have identified local amendments to the California Energy Code (also known as a “Reach Code”) to reduce greenhouse gas emissions in new buildings as the preferred alternative approach to an all-electric requirement. Since the California Energy Code only regulates certain energy uses, this approach limits the City’s scope and therefore the Reach Code does not apply to cooking equipment (e.g., stoves), laundry dryers, or other unregulated energy uses.

Energy Performance Approach
The new proposed Reach Code Ordinance, called the Energy Performance Approach (Attachment B) includes requirements for new buildings that would result in lower operational greenhouse gas emissions by applying an increased source energy margin

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requirement to all new buildings – both electric and mixed-fuel designs. While the proposed approach is less effective at reducing greenhouse gas emissions than the previous all-electric Zero Emission Building Code, the proposed Reach Code provides the best and most timely opportunity to continue pursuing Council’s adopted climate action goals. This approach has been adopted by other California cities including San Luis Obispo, Santa Cruz, San Jose, Palo Alto, East Palo Alto, Encinitas, and Brisbane.

California Energy Code Energy Evaluation Metrics
The 2022 California Energy Code provides baseline efficiency and building performance standards that a project must meet before receiving a building permit. The California Energy Code provides different metrics for different types of buildings and is organized into three categories:
• Single-Family Residential: A new single-family residential building must meet or exceed “Energy Design Rating” (EDR) scores. There are three EDR score categories:
• EDR1 (Source Energy) – a score representing a building’s source energy consumption and serves as a proxy for greenhouse gas emissions.
• EDR2 Efficiency (Efficiency Energy Design Rating) – a score representing a building’s energy efficiency through the value and cost of energy consumed at different times of the day and year. • EDR2 Total (Total Energy Design Rating) – a score representing the building’s total energy, including the value and cost of energy consumed at different times of the day and year while also factoring in solar and energy demand flexibility.
• Multi-Family Residential: A new multi-family residential building must meet or exceed a standard that combines the value and cost of energy consumed at different times of the day and year (referred to as Time Dependent Valuation of energy, or TDV), and the emissions from the building’s energy source. The 2022 Source Energy metric is new for all

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multifamily buildings, and it was added to support decarbonization and electrification policy goals.
• Non-Residential: A new non-residential building must also meet or exceed a standard that uses TDV energy and Source Energy emissions scores.
• The following metrics are used for both multi-family and non-residential projects:
• Efficiency TDV - accounts for all regulated end-uses but does not include the impacts of PV and battery storage.
• Total TDV - includes regulated end-uses accounting for PV and battery storage contributions.
• Source Energy - based on fuel used for power generation, assuming utilities meet all Renewable Portfolio Standard (RPS) goals and other obligations projected over 15-year lifecycle.

Proposed Energy Performance Enhancements
Staff recommends that Council adopt cost effective local amendments to the California Energy Code that would improve the required EDR1 score for single family residential buildings and the required Source Energy margin scores for most other buildings. As noted in Table 1 below, new single-family residential buildings would be required to have an EDR1 score that is 5 points better (lower) than the standard design. Smaller single-family homes including accessory dwelling units (ADUs) would have a reduced requirement of scoring 2 points below the standard EDR1 score due to their smaller size and energy usage and thus lower capacity for energy improvements.

Table 1 also identifies a Source Energy performance requirement of 7% above the standard for new multi-family buildings with three stories or less, and 3% for multifamily buildings with four or more stories. New non-residential buildings would be required to exceed the standard source energy compliance margin by 2%-14% depending on the building type. Office facilities have a higher compliance margin of 14% because they tend to have larger conditioned floor areas, which translates to higher savings potential.

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There would be an exemption for certain non-residential projects designed with singlezone space-conditioning systems where California Energy Code Section 140.4(a)2 is applicable because the state code prescriptively requires the use of heat pumps, making it difficult for mixed-fuel buildings to comply already.

Because of how the EDR1 and Source Energy scores are calculated in the 2022 California Energy Code, the higher performance standards proposed in the Energy Performance Approach Reach Code would encourage new buildings to include additional electric appliances/mechanical systems, while allowing mixed-fuel building designs that include additional energy efficiency and/or solar PV and battery storage measures. The enhanced performance requirements would apply equally to mixed-fuel and all-electric buildings through the Energy Code’s performance pathway.

Table 1. Proposed Improved Energy Performance Standards Building Type Performance Requirement
Single Family Residential Exceed the standard EDR1 Compliance Margin requirement by at least 5 points relative to standard
design EDR1
Buildings <1,500 sqft – Exceed the standard EDR1
Compliance Margin requirement by at least 2 points
Multi-Family Residential
with 3 stories or less
Exceed the standard Source Energy Compliance Margin
requirement by 7%
Multi-Family Residential
with 4 stories or more
Exceed the standard Source Energy Compliance Margin
requirement by 3%
Non-Residential Exceed the standard Source Energy Compliance Margin requirement by the following:

Hotel – 7%
Small Restaurants – 2%
Office – 14%
All Other Building Types – 7%

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Exceptions Non-residential: When non-residential occupancies are designed with single zone space-conditioning systems
complying with Section 140.4(a)2.

Electric Ready Requirements
The 2022 California Energy Code requires certain mixed-fuel buildings to include “electric ready” components including electric outlets near natural gas appliances, appropriate ventilation for future heat pump appliances, and reserved and labelled breakers in the electrical panel for future electric appliances as follows:
• Single-Family Residential – heat pump hot water heaters are prescriptively required, and “electric ready” infrastructure is required for any building that includes a gas fueled furnace, clothes dryer, and/or cooktop. • Multi-Family Residential – “electric ready” infrastructure is required in a newly constructed multi-family residential unit that includes a gas fueled space heater, water heater, clothes dryer, and/or cooktop.

The proposed Reach Code also includes electric readiness requirements for heat pump water heaters in multifamily buildings that will be mandatory under the 2025 California Energy Code if adopted by the California Energy Commission as anticipated on September 11, 2024 (effective January 1, 2026), in addition to non-residential electric readiness requirements. These amendments will ensure that projects using gas systems initially will have the electrical capacity and space available to switch to heat pumps in the future. (The 2025 California Energy Code formal adoption was postponed to September 11, 2024. Any non-substantive changes to the adopted code language, if made, would be included in the attached Energy Performance Approach ordinance for consistency.) Adopting electric-ready measures will also make it easier for buildings to comply with forthcoming zero-emissions appliance regulations under the South Coast Air Quality Management District’s (SCAQMD) Rule 1146.2.

Practical Effect of the Energy Performance Approach Reach Code

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In an effort to break down the technical details of this Code amendment, this section illustrates the practical effect of the proposed approach by providing a simplified example of how a single-family home designer would comply with both the current State Code and subsequently the proposed Reach Code. To meet the minimum State Code, a building designer working on a single-family home would likely include high efficiency LED lighting, rooftop solar, an electric heat pump hot water heater, a natural gas furnace, insulated walls, an insulated attic, and efficient windows, among other things.

The designer would load the building design into a computer model and estimate its energy performance, which is common practice. The energy modeling software would provide standard reporting metrics, including an EDR1 score. The designer would then compare the EDR1 score to a standard design building on the CF-1R form. The designed building’s EDR1 score would need to be equal to or lower than the standard design building’s EDR1 score to comply with that part of the California Energy Code.

With the Reach Code in place, the designer would now need to achieve an EDR1 score that is 5 points better (lower) than the standard design building. If this building designer replaced the gas furnace with a commonly available heat pump HVAC system, the building would achieve a score that is 5 EDR1 points better than the State Code minimum and would be consistent with the proposed Reach Code requirements.

Alternately, the building designer could keep the gas furnace and install a battery storage system, which would also result in an improvement of more than 5 EDR1 points. The building designer also has the option to develop a package of efficiency and solar measures. As long as the measures lead to an EDR1 score that is at least five points lower than the State Code minimum, it is consistent with the Reach Code.

This example is similar for the other building types where the compliance margins could be achieved by either installing electric heat pump HVAC equipment or installing some package of additional solar capacity and efficiency measures.

Cost Effectiveness
The California Energy Commission (CEC) requires any local amendments to the California Energy Code that affect energy use in regulated buildings to be cost effective

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and to use less energy than the standard requirements. The CEC requires the local agency to adopt a determination that the energy standards are cost effective and to subsequently file (via a resolution) with the Energy Commission.

In support of state reach code development, the California Energy Codes and Standards Statewide Utility Program, which includes the State's Investor-Owned Utilities, has developed and published cost effectiveness studies for single family, multifamily, and non-residential new construction (Attachment C).

These studies and the associated cost-effectiveness data are highly detailed and are included to support Council’s findings and policy decisions. The studies and the associated cost-effectiveness data include a calculated benefit-to-cost ratio for a wide variety of measures, building types, and climate zones. A benefit-cost value of “1” or greater illustrates that the measures save more than they cost and are therefore “cost effective.” These studies and the associated cost-effectiveness data illustrate compliance with the requirements set forth under California Administrative Code Chapter 10-106.

Based on these studies, staff finds the proposed local amendments to the 2022 California Energy Code to be cost-effective and consume less energy than otherwise permitted by Title 24, Part 6.

Available Resources for Lower-Cost All-Electric Buildings For projects that chose to go all-electric, the State of California, and regional entities are providing technical assistance, substantial rebates, and incentives for all-electric new buildings. In addition, the Federal Government offers tax credits and rebates for certain clean energy projects and appliances. Current incentives include:
• California Energy Smart Homes is a utility funded program that provides base incentives for all-electric new market rate residential buildings including $3,000 for single-family homes, $1,600 per multi-family residential unit, $1,750 per accessory dwelling unit.

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• California Electric Homes is provided by the California Energy Commission and provides base incentives for all-electric new market rate residential buildings including $3,000 for single-family homes, $1,600 per multi-family residential unit, $1,600 per accessory dwelling unit, and $5,500 per modular or manufactured home. Incentives are increased for properties located in designated Disadvantaged Communities (DACs) or Hard to Reach (HTR) communities. Program participation is capped at $1.5 million per builder and includes additional incentives for items like induction cooktop and beyond code efficiency measures.
• The Building Initiative for Low-Emissions Development (BUILD) Program is provided by the California Energy Commission and includes technical support and incentives for all-electric new affordable housing including approximately $3,399 per multifamily unit and $5,500 per single-family home. • The Residential Clean Energy Tax Credit, offered through the Federal Tax Code, provides a tax credit of up to 30% of the costs of new, qualified clean energy property such as batter storage technology.
• The South Coast Air Quality Management District is in the process of developing a Go Zero pilot incentive program to provide incentives to consumers, multifamily property owners, and small business owners, with an emphasis on overburdened communities, to install zero-emission appliances such as heat pump water and space heaters.

Public Outreach
On March 18, 2024, the Commission on Sustainability, Equity and Environmental Justice unanimously approved the staff recommendation to adopt the Energy Performance Approach to replace the Zero Emission Building Code.

On April 3, 2024, the Office of Sustainability & the Environment held a stakeholder meeting with the support of TRC, an energy consultant offering technical assistance through the Clean Power Alliance’s Local Reach Codes Program, to review and discuss the proposed Energy Performance Approach. The attendees represented affordable housing developers, housing developers, architecture, and design firms, building

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managers, and green building advocates. The response was positive with notable support from the affordable housing developer Community Corporation of Santa Monica. Stakeholders urged City staff to explore policy mechanisms to continue to encourage all-electric design to reduce emissions in large multi-family buildings. Local stakeholders reviewed the draft reach code ordinance and provided helpful feedback that has been incorporated into the final code language.

Environmental Review
The Energy Performance Approach Ordinance (Ordinance) is categorically exempt pursuant to Section 15308 of the California Environmental Quality Act (CEQA) Guidelines. Section 15308 exempts actions taken by regulatory agencies for protection of the environment (Class 8). The Ordinance would help to achieve the intended outcome of low-emission new buildings, and therefore, is exempt pursuant to Section 15308. In addition, this Ordinance is exempt from CEQA under Section 15061(b)(3), which states that CEQA does not apply, “where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment.” These standards are more stringent than the State energy standards, and as such, there are no reasonably foreseeable adverse impacts, and there is no possibility that the Ordinance in question may have a significant effect on the environment.

Past Council Actions
Meeting Date Descriptions
05/28/2019 (Attachment A) Adopted the Climate Action & Adaptation Plan 09/24/2019 (Attachment D) Ordinance Adopting the 2019 California Energy Code and Local Amendments
09/27/2022 (Attachment E) Adopted the 2022 Zero Emission Building Code and 2022 EV Charger Reach Code
Financial Impacts and Budget Actions
There is no immediate financial impact or budget action necessary as a result of the recommended action. Staff will return to Council if specific budget actions are required in the future.

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Prepared By: Ariana Vito, Sustainability Analyst
Approved Forwarded to Council
Attachments:

A. Climate Action & Adaptation Plan
B. 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) C. 2024 Ordinance
D. 2019 Staff Report - Electric-Preferred Reach Code
E. 2022 Staff Report: Adoption of Zero Emission Building Code F. 2024 Resolution
G. Written Comments

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Prepared by:

Frontier Energy, Inc
Misti Bruceri & Associates, LLC
Prepared for:

Kelly Cunningham, Codes and Standards Program, Pacific Gas and Electric Last modified: 2023/06/20
Revision: 1.1
2022 Cost-Effectiveness Study:

Multifamily New Construction

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Packet Pg. 533 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost
-Effectiveness Analysis: Multifamily New Construction
Legal Notice
This report was prepared by Pacific Gas and Electric Company and funded by the California utility customers under the auspices of the California Public Utilities Commission.

Neither PG&E nor any of its employees makes any warranty, express or implied; or assumes any legal liability or responsibility for the accuracy, completeness or usefulness of any data, information, method, product, policy or process disclosed in this document; or represents that its use will not infringe any privately-owned rights including, but not limited to, patents, trademarks or copyrights.

Acronym List
2023 PV$– Present value costs in 2023
ACH50– Air Changes per Hour at 50 pascals pressure differential ACM– Alternative Calculation Method
ADU – Accessory Dwelling Unit
AFUE– Annual Fuel Utilization Efficiency
B/C– Lifecycle Benefit-to-Cost Ratio
BEopt– Building Energy Optimization Tool
BSC– Building Standards Commission
CA IOUs – California Investor-Owned Utilities
CASE – Codes and Standards Enhancement
CBECC-Res
– Computer program developed by the California Energy
Commission for use in demonstrating compliance with the California Residential Building Energy Efficiency Standards CFI– California Flexible Installation
CFM– Cubic Feet per Minute
CO
2 – Carbon Dioxide
CPAU – City of Palo Alto Utilities
CPUC – California Public Utilities Commission
CZ– California Climate Zone
DHW– Domestic Hot Water
DOE– Department of Energy
DWHR– Drain Water Heat Recovery
EDR– Energy Design Rating
EER– Energy Efficiency Ratio
EF– Energy Factor
GHG
– Greenhouse Gas

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Packet Pg. 534 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost
-Effectiveness Analysis: Multifamily New Construction
HERS Rater– Home Energy Rating System Rater
HPA– High Performance Attic
HPWH– Heat Pump Water Heater
HSPF– Heating Seasonal Performance Factor
HVAC– Heating, Ventilation, and Air Conditioning
IECC– International Energy Conservation Code
IOU– Investor Owned Utility
kBtu– kilo-British thermal unit
kWh–Kilowatt Hour
LBNL– Lawrence Berkeley National Laboratory
LCC– Lifecycle Cost
LLAHU – Low Leakage Air Handler Unit
VLLDCS– Verified Low Leakage Ducts in Conditioned Space MF–Multifamily
NEEA– Northwest Energy Efficiency Alliance
NEM– Net Energy Metering
NPV– Net Present Value
NREL– National Renewable Energy Laboratory
PG&E– Pacific Gas and Electric Company
POU – Publicly-Owned-Utilities
PV– Photovoltaic
SCE– Southern California Edison
SDG&E– San Diego Gas and Electric
SEER– Seasonal Energy Efficiency Ratio
SF– Single Family
SMUD – Sacramento Municipal Utility District
SoCalGas – Southern California Gas Company
TDV– Time Dependent Valuation
Therm– Unit for quantity of heat that equals 100,000 British thermal units Title 24– Title 24, Part 6
TOU– Time-Of-Use
UEF– Uniform Energy Factor
ZNE– Zero-net Energy

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Packet Pg. 535 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Multifamily New Construction Summary of Revisions
Date Description Reference (page or section)
2/28/2022 Original Release N/A
6/20/2023 Minor revisions to content; no change to results 2, 3, 32, 33

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Packet Pg. 536 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Multifamily New Construction

TABLE OF CONTENTS
Executive Summary..........................................................................................................................................................1 1 Introduction................................................................................................................................................................4 2 Methodology and Assumptions...............................................................................................................................5

2.1 Analysis for Reach Codes..................................................................................................................................................... 5

2.1.1 Modeling ....................................................................................................................................................................... 5

2.1.2 Cost-Effectiveness ........................................................................................................................................................ 5

2.1.3 Utility Rates................................................................................................................................................................... 6

2.2 2022 T24 Compliance Metrics .............................................................................................................................................. 8

2.3 Greenhouse Gas Emissions ................................................................................................................................................. 8 3 Prototypes, Measure Packages, and Costs............................................................................................................9

3.2 Measure Definitions and Costs ........................................................................................................................................... 11

3.2.1 Efficiency, Solar PV, and Batteries ............................................................................................................................. 11

3.2.2 All-Electric................................................................................................................................................................... 15

3.3 Measure Packages ............................................................................................................................................................. 18 4 Results......................................................................................................................................................................20

4.1 All-Electric Prescriptive Code.............................................................................................................................................. 20

4.2 All-Electric Plus PV ............................................................................................................................................................. 23

4.3 Mixed Fuel Efficiency .......................................................................................................................................................... 25

4.4 Mixed Fuel Plus PV (Plus Battery for the 3-Story Prototype).............................................................................................. 26

4.5 CARE Rate Comparison..................................................................................................................................................... 29

4.6 Greenhouse Gas Reductions.............................................................................................................................................. 30 5 Summary ..................................................................................................................................................................32 6 References ...............................................................................................................................................................34 7 Appendices ..............................................................................................................................................................36

7.1 Map of California Climate Zones......................................................................................................................................... 36

7.2 Utility Rate Schedules......................................................................................................................................................... 37

7.2.1 Pacific Gas & Electric.................................................................................................................................................. 38

7.2.2 Southern California Edison ......................................................................................................................................... 43

7.2.3 Southern California Gas.............................................................................................................................................. 46

7.2.4 San Diego Gas & Electric............................................................................................................................................ 48

7.2.5 City of Palo Alto Utilities.............................................................................................................................................. 53

7.2.6 Sacramento Municipal Utilities District (Electric Only)................................................................................................. 55

7.2.7 Fuel Escalation Assumptions...................................................................................................................................... 57

7.3 Cost Details......................................................................................................................................................................... 58

7.4 PG&E Gas Infrastructure Cost Memo................................................................................................................................. 59

7.5 Central Heat Pump Water Heater Comparison................................................................................................................... 62

7.6 Summary of Measures by Package .................................................................................................................................... 63

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LIST OF TABLES
Table ES-1. Summary of Efficiency TDV Compliance Margins and Cost-Effectiveness....................................................................... 3 Table 1. Utility Tariffs Used Based on Climate Zone ............................................................................................................................ 8 Table 2. Prototype Characteristics........................................................................................................................................................ 9 Table 3. Base Case Characteristics of the Prototypes........................................................................................................................ 10 Table 4. Base Package PV Capacities (kW-DC) ................................................................................................................................ 10 Table 5. Incremental Cost Assumptions ............................................................................................................................................. 13 Table 6. Heat Pump Water Heater Incremental System Costs (Present Value (2023$)).................................................................... 16 Table 7. Heat Pump Space Heater Costs per Dwelling Unit (Present Value (2023$)......................................................................... 16 Table 8. Lifetime of Water Heating & Space Conditioning Equipment Measures ............................................................................... 17 Table 9. IOU Natural Gas Infrastructure Cost Savings for All-Electric Building................................................................................... 18 Table 10. Multifamily IOU Total Natural Gas Infrastructure Costs ...................................................................................................... 18 Table 11. Multifamily CPAU Total Natural Gas Infrastructure Costs................................................................................................... 18 Table 12. 3-Story Cost-Effectiveness Results per Dwelling Unit: All-Electric Prescriptive Code......................................................... 21 Table 13. 5-Story Cost-Effectiveness Results per Dwelling Unit: All-Electric Prescriptive Code......................................................... 22 Table 14. 3-Story Cost-Effectiveness Results per Dwelling Unit: All-Electric 100% PV...................................................................... 23 Table 15. 5-Story Cost-Effectiveness Results per Dwelling Unit: All-Electric 100% PV...................................................................... 24 Table 16. 3-Story Cost-Effectiveness Results per Dwelling Unit: Mixed Fuel Efficiency..................................................................... 25 Table 17. 5-Story Cost-Effectiveness Results per Dwelling Unit: Mixed Fuel Efficiency..................................................................... 26 Table 18. 3-Story Cost-Effectiveness Results per Dwelling Unit: Mixed Fuel Efficiency + PV + Battery............................................. 27 Table 19. 5-Story Cost-Effectiveness Results per Dwelling Unit: Mixed Fuel Efficiency + PV............................................................ 28 Table 20. On-Bill IOU Cost-Effectiveness Comparison with CARE Tariffs, Results per Dwelling Unit: All-Electric Prescriptive Code 29 Table 21. On-Bill IOU Cost-Effectiveness Comparison with CARE Tariffs, Results per Dwelling Unit: Mixed Fuel Packages ........... 29 Table 22. Summary of Efficiency TDV Compliance Margins and Cost-Effectiveness......................................................................... 33 Table 23. PG&E Baseline Territory by Climate Zone.......................................................................................................................... 38 Table 24. PG&E Monthly Gas Rate ($/therm)..................................................................................................................................... 38 Table 25. PG&E Monthly CARE (GL-1) Gas Rate ($/therm)............................................................................................................... 39 Table 26: SCE Baseline Territory by Climate Zone ............................................................................................................................ 43 Table 27. SoCalGas Baseline Territory by Climate Zone ................................................................................................................... 46 Table 28. SoCalGas Monthly Gas Rate ($/therm) .............................................................................................................................. 46 Table 29. SDG&E Baseline Territory by Climate Zone ....................................................................................................................... 48

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Packet Pg. 538 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Multifamily New Construction Table 30. SDG&E Monthly Gas Rate ($/therm).................................................................................................................................. 48 Table 31. CPAU Monthly Gas Rate ($/therm)..................................................................................................................................... 53 Table 32: Real Utility Rate Escalation Rate Assumptions................................................................................................................... 57 Table 33. Heat Pump Water Heater First Costs per Building (Present Value (2023$))....................................................................... 58 Table 34. Heat Pump Space Heater First Costs per Dwelling Unit (Present Value (2023$)............................................................... 58 Table 35. 5-Story Cost-Effectiveness: All-Electric Prescriptive Code with R-134a Heat Pump Water Heater .................................... 62 Table 36. Mixed Fuel Efficiency Package Measures .......................................................................................................................... 63 Table 37. Upgrade Package PV Capacities (kW-DC)......................................................................................................................... 64

LIST OF FIGURES
Figure 1. 3-Story greenhouse gas reductions (metric tons) per dwelling unit ..................................................................................... 31 Figure 2. 5-Story greenhouse gas savings (metric tons) per dwelling unit.......................................................................................... 31 Figure 3. Map of California climate zones........................................................................................................................................... 36

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1 localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 Executive Summary
The California Codes and Standards (C&S) Reach Codes program provides technical support to local governments considering adopting a local ordinance (reach code) intended to support meeting local and/or statewide energy efficiency and greenhouse gas (GHG) reduction goals. The program facilitates adoption and implementation of the code when requested by local jurisdictions by providing resources such as cost-effectiveness studies, model language, sample findings, and other supporting documentation.

This report documents cost-effective combinations of measures that exceed the minimum state requirements, the 2022 Building Energy Efficiency Standards (Title 24, Part 6 or Energy Code), effective January 1, 2023, for newly constructed multifamily buildings. The analysis considers low-rise and mid-rise multifamily building types and evaluates mixed fuel and all-electric package options in all sixteen California climate zones (CZs) Packages include a code compliant electrification package and a mixed fuel efficiency package, as well as the addition of above-code on-site solar photovoltaic (PV) capacity and battery energy storage. The 2022 Energy Code established electric heat pumps as the prescriptive baseline for space heating in most climate zones. As a result, this analysis primarily focuses on the electrification of central water heating. Space heating electrification was also evaluated where the prescriptive heat pump baseline didn’t apply: In Climate Zone 16 for multifamily buildings three habitable stories or fewer, and Climate Zones 1 and 16 for multifamily buildings greater than three habitable stories.

This analysis used two different metrics to assess the cost-effectiveness of the proposed upgrades. Both methodologies require estimating and quantifying the incremental costs and energy savings associated with each energy efficiency measure over a 30-year analysis period. On-Bill cost-effectiveness is a customer-based lifecycle cost (LCC) approach that values energy based upon estimated site energy usage and customer utility bill savings using today’s electricity and natural gas utility tariffs. Time Dependent Valuation (TDV) is the California Energy Commission’s LCC methodology, which is intended to capture the long-term projected cost of energy including costs for providing energy during peak periods of demand, carbon emissions, grid transmission and distribution impacts. This is the methodology used by the Energy Commission in evaluating cost-effectiveness for efficiency measures in Title 24, Part

6. Two multifamily prototypes were evaluated in this study. A 3-story loaded corridor and a 5-story mixed use prototype, which combined are estimated to represent 91 percent of new multifamily construction in California.

The following summarizes key results from the study:
• The Reach Codes Team found all-electric new construction to be feasible and cost-effective based on the California Energy Commission’s Time Dependent Valuation (TDV) metric in all cases. In many cases allelectric prescriptive code construction results in an increase in utility costs and is not cost-effective On-Bill.

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2 localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 billing tariff is expected to increase On-Bill cost-effectiveness of the all-electric prescriptive code scenario. An all-electric home has better on-site utilization of generated electricity from PV than a mixed fuel home with a similar sized PV system, and as a result exports less electricity to the grid. Since the net-billing tariff values exports less than under NEM 2.0, the relative impact on annual utility costs to the mixed fuel baseline is greater.
• This analysis does justify a modest reach based on either efficiency TDV or source energy for all-electric buildings. However, this may be challenging for some projects given the recent changes to which the industry must adapt, including the efficiency updates and multifamily restructuring in the 2022 Title 24, Part 6 code.

While project compliance margins using a CO2 refrigerant heat pump water heating system are high, the Reach Code Team found lower compliance margins using other heat pump water heater system designs.

Focusing on supporting projects to electrify water heating is expected to support the market shift towards more central heat pump water heaters.
• For jurisdictions interested in a reach code that allows for mixed fuel buildings, a mixed fuel efficiency and PV package (and battery for the 3-story prototype) was found to be cost-effective based on TDV in all cases and cost-effective On-Bill in most climate zones. This path, referred to as “Electric-Preferred”, allows for mixed fuel buildings but requires a higher building performance than for all-electric buildings. The efficiency measures evaluated in this study did not provide significant compliance benefit. As a result, the Reach Codes Team recommends establishing a compliance margin target based on source energy or total TDV. This would allow for PV and battery above minimum code requirements to be used to meet the target. • Jurisdictions interested in increasing affordable multifamily housing should know that applying the CARE rates has the overall impact of increasing utility cost savings for an all-electric building in most climate zones compared to a code compliant mixed fuel building, improving On-Bill cost-effectiveness.

Table ES-1 summarizes results for each prototype and depicts the efficiency TDV compliance margins achieved for each climate zone and package. All results presented in the table have a positive compliance margin (greater than zero percent). Cells highlighted in green depict cases with a positive compliance margin and cost-effective results using both On-Bill and TDV approaches. Cells highlighted in yellow depict cases with a positive compliance margin and costeffective results using either the On-Bill or TDV approach. Cells not highlighted depict cases with a positive compliance margin but that were not cost-effective using either the On-Bill or TDV approach.

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3 localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 Table ES-1. Summary of Efficiency TDV Compliance Margins and Cost-Effectiveness Climate
Zone
Electric
/Gas Utility
3-Story 5-Story
All-Electric
Prescriptive
Code
AllElectric
+ PV
Mixed
Fuel
Efficiency
Mixed
Fuel
Efficiency
+ PV +
Battery
All-Electric
Prescriptive
Code
AllElectric
+ PV
Mixed
Fuel
Efficiency
Mixed
Fuel
Efficiency
+ PV
CZ01 PGE 26% 26% 1% 1% 14% 14% 0% 0%
CZ02 PGE 20% 20% 1% 1% 9% 9% 1% 1%
CZ03 PGE 21% 21% 1% 1% 11% 11% 0% 0%
CZ04 PGE 18% 18% 1% 1% 9% 9% 1% 1%
CZ04 CPAU 18% 18% 1% 1% 9% 9% 1% 1%
CZ05 PGE 23% 23% 1% 1% 12% 12% 0% 0%
CZ05 PGE/SCG 23% 23% 1% 1% 12% 12% 0% 0%
CZ06 SCE/SCG 18% 18% 1% 1% 9% 9% 0% 0%
CZ07 SDGE 20% 20% 0% 0% 11% 11% 0% 0%
CZ08 SCE/SCG 13% 13% 1% 1% 8% 8% 1% 1%
CZ09 SCE 13% 13% 1% 1% 7% 7% 1% 1%
CZ10 SCE/SCG 14% 14% 3% 3% 7% 7% 2% 2%
CZ10 SDGE 14% 14% 3% 3% 7% 7% 2% 2%
CZ11 PGE 14% 14% 3% 3% 8% 8% 2% 2%
CZ12 PGE 17% 17% 2% 2% 9% 9% 2% 2%
CZ12 SMUD/PGE 17% 17% 2% 2% 9% 9% 2% 2%
CZ13 PGE 13% 13% 4% 4% 7% 7% 2% 2%
CZ14 SCE/SCG 13% 13% 3% 3% 6% 6% 2% 2%
CZ14 SDGE 13% 13% 3% 3% 6% 6% 2% 2%
CZ15 SCE/SCG 5% 5% 5% 5% 3% 3% 3% 3%
CZ16 PG&E 24% 24% 5% 5% 9% 9% 2% 2%
Local jurisdictions may also adopt ordinances that amend different Parts of the California Building Standards Code or may elect to amend other state or municipal codes. The decision regarding which code to amend will determine the specific requirements that must be followed for an ordinance to be legally enforceable. Reach codes that amend Part 6 of the CA Building Code and require energy performance (including PV and storage) beyond state code minimums must demonstrate that the proposed changes are cost-effective and obtain approval from the Energy Commission prior to filing with the BSC.

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4 localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 1 Introduction
This report documents cost-effective combinations of measures that exceed the minimum state requirements, the 2022 Building Energy Efficiency Standards, effective January 1, 2023, for newly constructed multifamily buildings. This report was developed in coordination with the California Statewide Investor-Owned Utilities (CA IOUs) Codes and Standards Program, key consultants, and engaged cities—collectively known as the Reach Codes Team. The CA IOU Codes and Standards Program is comprised of IOUs representatives from Pacific Gas and Electric (PG&E), Southern California Edison (SCE) and San Diego Gas and Electric (SDG&E) and two Publicly-Owned-Utilities (POUs) – Sacramento Municipal Utility District (SMUD) and City of Palo Alto Utilities (CPAU), The analysis considers low-rise and mid-rise multifamily building types and evaluates mixed fuel and all-electric package options in all sixteen California climate zones (CZs) 1 Packages include combinations of efficiency measures, on-site renewable energy, and battery energy storage.

The California Building Energy Efficiency Standards Title 24, Part 6 (Energy Code) (California Energy Commission, 2022a) is maintained and updated every three years by two state agencies: the California Energy Commission (Energy Commission) and the Building Standards Commission (BSC). In addition to enforcing the code, local jurisdictions have the authority to adopt local energy efficiency ordinances—or reach codes—that exceed the minimum standards defined by Title 24 (as established by Public Resources Code Section 25402.1(h)2 and Section 10-106 of the Building Energy Efficiency Standards (California Energy Commission, 2022a)). Local jurisdictions must demonstrate that the requirements of the proposed ordinance are cost-effective and do not result in buildings consuming more energy than is permitted by Title 24. In addition, the jurisdiction must obtain approval from the Energy Commission and file the ordinance with the BSC for the ordinance to be legally enforceable.

The Department of Energy (DOE) sets minimum efficiency standards for equipment and appliances that are federally regulated under the National Appliance Energy Conservation Act, including heating, cooling, and water heating equipment (E-CFR, 2020). Since state and local governments are prohibited from adopting higher minimum efficiencies than the federal standards require, the focus of this study is to identify and evaluate cost-effective packages that do not include high efficiency heating, cooling, and water heating equipment. High efficiency appliances are often the easiest and most affordable measures to increase energy performance. While federal preemption limits reach code mandatory requirements for covered appliances, in practice, builders may install any package of compliant measures to achieve the performance requirements.
1 See Appendix 7.1 Map of California Climate Zones for a graphical depiction of climate zone locations.

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5 localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 2 Methodology and Assumptions

2.1 Analysis for Reach Codes
This section describes the approach to calculating cost-effectiveness including benefits, costs, metrics, and utility rate selection.

2.1.1 Modeling
The Reach Codes Team performed energy simulations using software approved for 2022 Title 24 Code compliance analysis, CBECC 2022.2.0.

Using the 2022 baseline as the starting point, prospective energy efficiency measures were identified and modeled to determine the projected site energy (therm and kWh) and compliance impacts. Annual utility costs were calculated using hourly data output from CBECC, and electricity and natural gas tariffs for each of the investor-owned utilities (IOUs).

This analysis focused on residential apartments only (a prior study and report analyzed the cost-effectiveness of above code packages for nonresidential buildings (Statewide Reach Codes Team, 2022b). The Statewide Reach Codes Team selected measures for evaluation based on the single family 2022 reach code analysis (Statewide Reach Codes Team, 2022a) and the multifamily 2019 reach code analysis [ (Statewide Reach Codes Team, 2020), (Statewide Reach Codes Team, 2021)] as well as experience with and outreach to architects, builders, and engineers.

2.1.2 Cost-Effectiveness

2.1.2.1 Benefits
This analysis used two different metrics to assess the cost-effectiveness of the proposed upgrades. Both methodologies require estimating and quantifying the incremental costs and energy savings associated with each energy efficiency measure. The main difference between the methodologies is the manner in which they value energy and thus the cost savings of reduced or avoided energy use:

Utility Bill Impacts (On-Bill): This customer-based lifecycle cost (LCC) approach values energy based upon estimated site energy usage and customer utility bill savings using the latest electricity and natural gas utility tariffs available at the time of writing this report. Total savings are estimated over a 30-year duration and include discounting of future utility costs and energy cost inflation.

Time Dependent Valuation (TDV): This reflects the Energy Commission’s current LCC methodology, which is intended to capture the total value or cost of energy use over 30 years. This method accounts for long-term projected costs, such as the cost of providing energy during peak periods of demand, costs for carbon emissions, and grid transmission and distribution impacts. This metric values energy use differently depending on the fuel source (natural gas, electricity, and propane), time of day, and season. Electricity used (or saved) during peak periods has a much higher value than electricity used (or saved) during off-peak periods due to the less inefficient energy generation sources providing peak electricity (Horii, Cutter, Kapur, Arent, & Conotyannis, 2014). This is the methodology used by the Energy Commission in evaluating cost-effectiveness for efficiency measures in the 2022 Energy Code.

2.1.2.2 Costs
The Reach Codes Team assessed the incremental costs of the measures and packages over a 30-year lifecycle.

Incremental costs represent the equipment, installation, replacements, and maintenance costs of the proposed measure relative to the 2022 Energy Code minimum requirements or standard industry practices. Present value of replacement cost is included for measures with lifetimes less than the evaluation period.

2.1.2.3 Metrics
Cost-effectiveness is presented using net present value (NPV) and benefit-to-cost (B/C) ratio metrics.

NPV: The lifetime NPV is reported as a cost-effectiveness metric, Equation 1 demonstrates how this is calculated. If the NPV of a measure or package is positive, it is considered cost-effective. A negative values represent net costs.

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6 localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 B/C Ratio: This is the ratio of the present value (PV) of all benefits to the present value of all costs over 30 years (PV benefits divided by PV costs). The criteria benchmark for cost-effectiveness is a B/C ratio greater than one. A value of one indicates the NPV of the savings over the life of the measure is equivalent to the NPV of the lifetime incremental cost of that measure. A value greater than one represents a positive return on investment. The B/C ratio is calculated according to Equation 2.

Equation 1
𝑁𝑁𝑁𝑁𝑁𝑁 = 𝑜𝑜𝑜𝑜 𝑙𝑙𝑙𝑙 𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙 𝑏𝑏 𝑏𝑏 − 𝑜𝑜𝑜𝑜 𝑙𝑙𝑙𝑙 𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙 𝑐𝑐 𝑐𝑐 Equation 2
𝐵𝐵 − − 𝐶𝐶 𝑅𝑅𝑅𝑅 = 𝑜𝑜𝑜𝑜 𝑙𝑙𝑙𝑙 𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙 𝑏𝑏 𝑏𝑏
𝑜𝑜𝑜𝑜 𝑙𝑙𝑙𝑙 𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙 𝑐𝑐 𝑐𝑐
Improving the efficiency of a project often requires an initial incremental investment. In most cases the benefit is represented by annual On-Bill utility or TDV savings, and the cost is represented by incremental first cost and replacement costs. Some packages result in initial construction cost savings (negative incremental cost), and either energy cost savings (positive benefits), or increased energy costs (negative benefits). In cases where both construction costs and energy-related savings are negative, the construction cost savings are treated as the ‘benefit’ while the increased energy costs are the ‘cost.’ In cases where a measure or package is cost-effective immediately (i.e., upfront construction cost savings and lifetime energy cost savings), B/C ratio cost-effectiveness is represented by “>1”.

The lifetime costs or benefits are calculated according to Equation 3.

Equation 3
𝑜𝑜𝑜𝑜 𝑙𝑙𝑙𝑙 𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙 𝑐𝑐 𝑐𝑐 𝑜𝑜𝑜𝑜 𝑏𝑏 𝑏𝑏 = �(𝐴𝐴 𝐴𝐴 𝑐𝑐 𝑐𝑐 𝑜𝑜𝑜𝑜 𝑏𝑏 𝑏𝑏 )𝑡𝑡 (1 + )𝑡𝑡
𝑛𝑛
𝑡𝑡=0
Where:
• n = analysis term in years
• r = discount rate
The following summarizes the assumptions applied in this analysis to both methodologies. • Analysis term of 30 years
• Real discount rate of three percent
TDV is a normalized monetary format and there is a unique procedure for calculating the present value benefit of TDV energy savings. The present value of the energy cost savings in dollars is calculated by multiplying the TDV savings (reported by the CBECC simulation software) by a NPV factor developed by the Energy Commission (see E3’s 2022 TDV report for details (Energy + Environmental Economics, 2020)). The 30-year residential NPV factor is $0.173/kTDV for the 2022 Energy Code.

Equation 4
𝑇𝑇𝑇𝑇 𝑜𝑜𝑜𝑜 𝑙𝑙𝑙𝑙 𝑙𝑙𝑙𝑙𝑙𝑙 𝑏𝑏 𝑏𝑏 = 𝑇𝑇𝑇𝑇 𝑒𝑒𝑒𝑒 𝑠𝑠 ∗ 𝑁𝑁𝑁𝑁𝑁𝑁

2.1.3 Utility Rates
In coordination with the CA IOU rate team (comprised of representatives from PG&E, SCE, SDG&E, SMUD, and CPAU), the Reach Codes Team determined appropriate utility rates for each climate zone in order to calculate utility costs and determine On-Bill cost-effectiveness for the proposed measures and packages. The utility tariffs, summarized in Table 1, were determined based on the most prevalent active rate in each territory. Utility rates were applied to each climate zone based on the predominant IOU serving the population of each zone, with a few climate zones evaluated multiple times under different utility scenarios. Climate Zones 10 and 14 were evaluated with both

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7 localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 SCE for electricity and Southern California Gas Company (SoCalGas) for gas and SDG&E tariffs for both electricity and gas since each utility has customers within these climate zones. Climate Zone 5 is evaluated under both PG&E and SoCalGas natural gas rates. Two POU or municipal utility rates were also evaluated: SMUD in Climate Zone 12 and CPAU in Climate Zone 4.

For the IOUs in-unit gas was evaluated under the G1 rate and central gas for water heating was evaluated under the relevant master metered gas tariff, GM. Electricity use for central water heating was evaluated using the residential TOU rates. The water heating utility bill was calculated separately from the in-unit electricity bill. Photovoltaic (PV) and battery energy storage benefits were applied according to virtual net energy metering (VNEM) rules.2 PV was first assigned to the central water heating meter to offset 100 percent of the electricity use. The remaining PV and all of the battery impacts were then split evenly across the apartment meters. The same approach was applied for CPAU and SMUD using the rates described in Table 1.

The multifamily prototypes used in this analysis include common area spaces that serve the residents (lobby, leasing office, corridors, etc.). Most of the energy use for these spaces could not be separated from that for the dwelling units within the CBECC model. As a result, average per dwelling unit hourly energy use was calculated to include both the dwelling unit and common space energy use.

First-year utility costs were calculated using hourly electricity and natural gas output from CBECC and applying the utility tariffs summarized in Table 1. Annual costs were also estimated for customers eligible for the CARE tariff discounts on both electricity and natural gas bills. The CARE tariff was only applied to the in-unit apartment meters.

Appendix 7.2 Utility Rate Schedules includes details of each utility tariff.

For cases with PV generation, the approved NEM 2.0 tariffs were applied along with minimum daily use billing and mandatory non-bypassable charges. In December the California Public Utilities Commission (CPUC) issued a decision adopting a net billing tariff (NBT) as a successor to NEM 2.0 that will go into effect April of 20233 Given the recent timing of this decision there was not time to incorporate these changes into this analysis. The Reach Codes Team conducted a limited sensitivity analysis on the impacts of NBT relative to NEM 2.0 on utility bills. It was found that utility costs will increase for all homes with PV systems; however, the increase was less for an all-electric building compared to a mixed fuel building with a similarly sized PV system. As a result of better onsite utilization of PV generation and thus fewer exports to the grid, the Reach Codes Team expects the cost-effectiveness for the electrification scenarios for the all-electric home evaluated in this report to improve under NBT. Conversely, cost-effectiveness of increasing PV capacity is expected to be reduced under NBT.
2 PG&E: https://www.pge.com/tariffs/assets/pdf/tariffbook/ELEC_SCHEDS_NEM2V.pdf SDG&E: https://tariff.sdge.com/tm2/pdf/tariffs/ELEC_ELEC-SCHEDS_NEM-V-ST.pdf SCE:
https://edisonintl.sharepoint.com/teams/Public/TM2/Shared%20Documents/Forms/AllItems.aspx?ga=1&id=%2Fteams %2FPublic%2FTM2%2FShared%20Documents%2FPublic%2FRegulatory%2FTariff%2DSCE%20Tariff%20Books%2F Electric%2FSchedules%2FOther%20Rates%2FELECTRIC%5FSCHEDULES%5FNEM%2DV%2DST%2Epdf&parent= %2Fteams%2FPublic%2FTM2%2FShared%20Documents%2FPublic%2FRegulatory%2FTariff%2DSCE%20Tariff%20 Books%2FElectric%2FSchedules%2FOther%20Rates
3 https://www.cpuc.ca.gov/nemrevisit

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8 localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 Table 1. Utility Tariffs Used Based on Climate Zone
Climate Zones Electric / Gas Utility Electricity Natural Gas IOUs
1-5,11-13,16 PG&E / PG&E E-TOU Option C G1 (in-unit) & GM (central water heating)1
5 PG&E / SoCalGas E-TOU Option C GM
6, 8-10, 14, 15 SCE / SoCalGas TOU-D Option 4-9 GM
7, 10, 14 SDG&E / SDG&E TOU-DR-1 GM
POUs
4 CPAU / CPAU E-1 (in-unit) & E-2 (central
water heating) G-2
12 SMUD / PG&E R-TOD, RT02 (in-unit) &
RSMM (central water heating) GM
1G1 rate applied to gas use within the apartment units, which only occurs in Climate Zones 1 and 16, see Section 3 for details. GM rate applied to gas use for central water heating.

Utility rates are assumed to escalate over time according to the assumptions from the CPUC 2021 En Banc hearings on utility costs through 2030 (California Public Utilities Commission, 2021a). Escalation rates through the remainder of the 30-year evaluation period are based on the escalation rate assumptions within the 2022 TDV factors. See Appendix 7.2.7 Fuel Escalation Assumptions for details.

2.2 2022 T24 Compliance Metrics
2022 Title 24, Part 6 Section 170.1 defines the energy budget of the building based on source energy and TDV energy for space-conditioning, indoor lighting, mechanical ventilation, PV and battery storage systems, service water heating and covered process loads. In 2022, the Energy Commission introduced the new compliance metric of source energy, which differs by fuel source (as does TDV) and is a reasonable proxy for greenhouse gas emissions. Additionally, for multifamily buildings four habitable stories and higher prescriptive requirements for PV and battery systems were also introduced. This led to the need to differentiate an efficiency compliance metric, which ensured that the building met minimum efficiency standards, and a total energy compliance metric which incorporated the PV and battery standards.

In order to be compliant with the building code a building needs to comply with all three compliance metrics described below:
• Efficiency TDV. Efficiency TDV accounts for all regulated end-uses but does not include the impacts of PV and battery storage.
• Total TDV. Total TDV includes regulated end-uses and accounts for PV and battery storage contributions. • Source Energy. Source energy is based on fuel used for power generation and distribution.

2.3 Greenhouse Gas Emissions
The analysis reports the greenhouse gas (GHG) emission estimates based on assumptions within CBECC. There are 8,760 hourly multipliers accounting for time dependent energy use and carbon based on source emissions, including renewable portfolio standard projections. There are two series of multipliers—one for Northern California climate zones, and another for Southern California climate zones.4 GHG emissions are reported as average annual metric tons of CO2 equivalent over the 30-year building lifetime.
4 CBECC multipliers are the same for CZs 1-5 and 11-13 (Northern California), while there is another set of multipliers for CZs 6-10 and 14-16 (Southern California).

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9 localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 3 Prototypes, Measure Packages, and Costs
This section describes the prototypes, measures, costs, and the scope of analysis drawing from previous reach code research where appropriate.

3.1 Prototype Characteristics
The Energy Commission defines building prototypes which it uses to evaluate the cost-effectiveness of proposed changes to Title 24 requirements. There are 4 multifamily prototypes used in code development: a 2-story garden style, a 3-story loaded corridor, a 5-story mixed use and a 10-story mixed use. Based on work completed for the 2022 Title 24 code development, the 3-story and the 5-story represent 33 percent and 58 percent, respectively, of new multifamily construction in California. As a result, these two prototypes are used in this analysis. Additional details on all four prototypes can be found in the Multifamily Prototypes Report (TRC, 2019).

Table 2 describes the basic characteristics of each prototype.

Table 2. Prototype Characteristics
Characteristic 3-Story Loaded
Corridor 5-Story Mixed Use
Conditioned Floor Area 39,372 ft2
113,100 ft2 total:
33,660 ft2 nonresidential
79,440 ft2 residential
Num. of Stories 3
6 Stories total:
1 story parking garage (below grade)
1 story of nonresidential space
4 stories of residential space
Num. of Bedrooms
(6) Studio
(12) 1-bed
(12) 2-bed
(6) 3-bed
(8) studios
(40) 1-bed units
(32) 2-bed units
(8) 3-bed units
Window-to-Wall Area Ratio 25% 25%
Wall Type Wood framed Wood frame over a first-floor concrete podium
Roof Type Flat roof Flat roof
Foundation Slab-on-grade Concrete podium with underground parking
The methodology used in the analyses for each of the prototypical building types begins with a design that precisely meets the minimum 2022 prescriptive requirements.5 Table 170.2-A and 170.2-B in the 2022 Standards (California Energy Commission, 2022a) list the prescriptive measures that determine the baseline design in each climate zone.

Other features are designed to meet, but not exceed, the minimum requirements and are consistent with the Standard Design in the ACM Reference Manual (California Energy Commission, 2022c). The analysis also assumed electric resistance cooking in the apartment units to reflect current market data. The 3-story building prototype includes a central laundry facility, and the 5-story assumes laundry in the units. Laundry equipment was assumed to be electric in all cases; electrification of laundry equipment was not addressed in this study. The nonresidential 2022 reach code analysis (Statewide Reach Codes Team, 2022b) did consider electrification of central laundry facilities within the small hotel prototype.

Table 3 describes characteristics as they were applied to the base case energy model in this analysis. In a shift from the 2019 Standards, the 2022 Standards define a prescriptive fuel source for space heating establishing an electric 5Due to planned software updates to how the prescriptive requirements are applied in the Standard Design and challenges for certain space types with sizing heating and cooling equipment the same in the Proposed Design as in the Standards, the results compliance margins for the base case models were not exactly zero percent..

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10 localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 heat pump baseline in all climate zones except 16 for multifamily buildings three habitable stories and fewer and 1 and 16 for multifamily buildings four habitable stories and greater.

Table 3. Base Case Characteristics of the Prototypes
Characteristic 3-Story Loaded Corridor 5-story Mixed Use Space
Heating/Cooling1
Individual split systems with ducts in
conditioned space
CZ 1-15: Heat pump
CZ 16: Natural gas furnace with air
conditioner
Individual split systems with ducts in
conditioned space
CZ2-15: Heat pump
CZ1, 16: Dual-fuel heat pump with
natural gas backup
Ventilation Individual balanced fans, continuously
operating
Individual balanced fans, continuously
operating
Water Heater1
Natural gas central boiler with solar
thermal sized to meet the prescriptive
requirements by climate zone.

Natural gas central boiler with solar
thermal sized to meet the prescriptive
requirements by climate zone.

Hot Water
Distribution Central recirculation Central recirculation Cooking Electric Electric
Clothes Drying Electric (central) Electric (in-unit)
PV System
Sized according to the prescriptive
requirements in Equation 170.2-C of the
2022 Title 24 Standards. Size differs by
climate zone ranging from 1.60 kW to

2.90 kW per dwelling unit, see Table 4.

Sized according to the prescriptive
requirements in Equation 170.2-D of the
2022 Title 24 Standards. Size differs by
climate zone ranging from 2.26 kW to

3.34 kW per dwelling unit, see Table 4.

Battery System None None
1 Equipment efficiencies are equal to minimum federal appliance efficiency standards.

Table 4 summarizes the PV capacities for the base case packages.

Table 4. Base Package PV Capacities (kW-DC)
Climate
Zone
Base Package
3-Story 5-Story
CZ01 2.00 2.26
CZ02 1.79 2.68
CZ03 1.70 2.26
CZ04 1.75 2.68
CZ05 1.60 2.26
CZ06 1.77 2.68
CZ07 1.67 2.68
CZ08 1.91 2.68
CZ09 1.92 2.68
CZ10 1.98 2.68
CZ11 2.21 2.68
CZ12 1.96 2.68
CZ13 2.33 2.68
CZ14 1.94 2.68
CZ15 2.90 3.34
CZ16 1.76 2.26

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11 localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20

3.2 Measure Definitions and Costs
Measures evaluated in this study fall into two categories: those associated with general efficiency, onsite generation, and demand flexibility and those associated with building electrification. The Reach Codes Team selected measures based on cost-effectiveness as well as decades of experience with residential architects, builders, and engineers along with general knowledge of the relative consumer acceptance of many measures. This analysis focused on measures that impacted the residential dwelling units only.

The following sections describe the details and incremental cost assumptions for each of the measures. Incremental costs represent the equipment, installation, replacement, and maintenance costs of the proposed measures relative to the base case. Replacement costs are applied for roofs, mechanical equipment, PV inverters and battery systems over the 30-year evaluation period. Incremental maintenance costs are estimated for PV systems, but not any other measures. Costs were estimated to reflect costs to the building owner. All costs are provided as present value in 2023 (2023 PV$).

The Reach Codes Team obtained measure costs from distributors, contractors, literature review, and online sources such as Home Depot and RS Means. Contractor markups are incorporated. These are the Reach Codes Team best estimate of average costs statewide. Regional variation in costs is not accounted for, although it's recognized that local costs may differ. Cost increases due to recent high inflation rates and supply chain delays are not included.

3.2.1 Efficiency, Solar PV, and Batteries
The following are descriptions of each of the efficiency, PV, and battery measures evaluated under this analysis and applied in at least one of the packages presented in this report. Table 5 summarizes the incremental cost assumptions for each of these measures. These measures were evaluated for all climate zones but were ultimately adopted in a subset of climate zones based on cost-effectiveness outcomes.

Lower U-Factor Fenestration: Reduce window U-factor to 0.24. The prescriptive U-factor is 0.30 in all climate zones except Climate Zones 7 and 8 where it is 0.34. This measure is included in Climate Zone 16 only.

Cool Roof: Install a roofing product that’s rated by the Cool Roof Rating Council to have an aged solar reflectance (ASR) equal to or greater than 0.70. Low-sloped roofs were assumed in all cases. The 2022 Title 24 specifies a prescriptive ASR of 0.63 for Climate Zones 9 through 11 and 13 through 15. This measure is included in Climate Zones 9 through 15.

Low Pressure Drop Ducts: Upgrade the duct distribution system to reduce external static pressure and meet a maximum fan efficacy of 0.35 Watts per cfm. This may involve upsizing ductwork, reducing the total effective length of ducts, and/or selecting low pressure drop components such as filters. Fan watt draw must be verified by a HERS rater according to the procedures outlined in the 2022 Reference Appendices RA3.3 (California Energy Commission, 2022b). This measure is included in Climate Zones 1 and 10 through 16.

Verified Low Leakage Ducts in Conditioned Space: Seal the ducts to achieve a measured leakage no greater than 25 cfm leakage to outside. This may be verified using a guarded blower door test to isolate leakage to outside.

Alternatively, this can also be satisfied by demonstrating that total leakage is not greater than 25 cfm. Ducts are assumed to already be located in conditioned space in the baseline. This measure is included in all climate zones.

Solar PV: Installation of on-site PV is required in the 2022 residential code unless an exception is met. The PV sizing methodology in each package was developed to offset annual building electricity use and avoid oversizing which would violate net energy metering (NEM) rules.6 In all cases, PV is evaluated in CBECC according to the California Flexible Installation (CFI) assumptions. This measure is included in all climate zones.

Battery Energy Storage: A battery system was evaluated in CBECC-Res with control type set to “Time-of-Use” and with default efficiencies of 95% for both charging and discharging. This control option assumes the battery system will 6 NEM rules apply to the IOU territories only.

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12 localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 charge or discharge based on a utility tariff time-of use signal. To qualify, the battery system must meet the requirements outlined in the 2022 Reference Appendices JA12.2.3.2 (California Energy Commission, 2022b). This measure is included in all climate zones but only for the 3-story prototype. A 100kWh battery was applied following the battery sizing requirements for multifamily buildings more than three habitable stories per Equation 170.2-E of the 2022 Energy Code.

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13 localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 Table 5. Incremental Cost Assumptions
Measure
Performance
Level
Incremental Cost per
Dwelling Unit
(2023 PV$)
3-Story 5-Story Source & Notes
Non-Preempted Measures
Window U-factor 0.24 vs 0.30 $536 $489 $4.23/ft2 of window area based on analysis conducted for the 2019 and 2022 Title 24 cycles (Statewide CASE Team, 2018).

Low-Sloped Cool
Roof Aged Solar
Reflectance

0.63 vs 0.10 $314 $222
$0.525/ft2 of roof area first incremental cost based on the 2022 Residential Additions and Alterations CASE Report (Statewide CASE Team, 2020b).Total costs assume present value of replacement at year 15.

0.70 vs 0.63 $24 $17
$0.04/ft2 of roof area first incremental cost based on the 2022 Nonresidential High Performance Envelope CASE Report (Statewide CASE Team, 2020a). Costs assume a blended average across roofing product types. Total costs assume present value of replacement at year 15.

Low Pressure
Drop Ducts

0.35 vs 0.45
W/cfm $44 $44
Costs assume half-hour labor per multifamily dwelling unit. Labor rate of $88 per hour is from 2022 RS Means for sheet metal workers and includes a weighted average City Cost Index for labor for California.

Verified Low
Leakage Ducts in
Conditioned
Space
≤25 cfm leakage
to outside $132 $132
Costs assume half-hour labor per multifamily dwelling unit and a $100 HERS Rater fee.

Labor rate of $88 per hour is from 2022 RS Means for sheet metal workers and includes a weighted average City Cost Index for labor for California. Ducts are already assumed to be located in conditioned space and the incremental costs reflect additional sealing and testing only.

PV + Battery
PV System
First Cost $1.47/W $1.47/W
First costs from LBNL’s Tracking the Sun 2022 costs (Barbose, Darghouth, O'Shaughnessy, & Forrester, 2022) and represent median costs in California in 2021 of $2.10/WDC for nonresidential greater than 100kWDC systems. The first cost was reduced by the solar energy Investment Tax Credit (ITC) of 30%.1 Costs are presented as the average of 2023, 2024, and 2025.

Inverter replacement cost of $0.14/WDC present value includes replacements at year 11 at $0.15/WDC (nominal) and at year 21 at $0.12/WDC (nominal) per the 2019 PV CASE Report (California Energy Commission, 2017).

System maintenance costs of $0.31/WDC present value assume $0.02/WDC (nominal) annually per the 2019 PV CASE Report (California Energy Commission, 2017).

Inverter
replacement $0.14/W $0.14/W
Maintenance $0.31/W $0.31/W

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14 localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 Measure
Performance
Level
Incremental Cost per
Dwelling Unit
(2023 PV$)
3-Story 5-Story Source & Notes
Battery
First cost $700/kWh n/a
First cost of $1,000/kWh from LBNL’s Tracking the Sun 2022 costs (Barbose, Darghouth, O'Shaughnessy, & Forrester, 2022) for residential systems > 30kWh. The report derived costs from California’s Self-Generation Incentive Program (SGIP) residential participant cost data. First cost is reduced by the solar energy ITC of 30%.1 No SGIP incentives are included.

Costs are assumed to remain consistent at $1,000/kWh through 2025 and then reduced by 7% annually based on SDG&E’s Behind-the-Meter Battery Market Study (E-Source companies, 2020) over a 10 year period. Replacement is assumed at years 10 and 20. At year 10 the replacement cost is based on the average of expected 2033, 2034, and 2035 costs after applying the ITC for a future value cost of $435. Replacement cost at year 20 is based on a future value cost of $484 and does not include any ITC reduction.

Replacement
cost $564/kWh n/a
1As part of the Inflation Reduction Act in August 2022 the Section 25D Investment Tax Credit was extended and raised to 30% through 2032 with a step-down to 26% in 2033 and 22% in 2034. It’s assumed that the ITC is not renewed and is 0% starting in 2035. https://www.irs.gov/pub/taxpros/fs-2022-40.pdf.

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localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20

3.2.2 All-Electric
This analysis compared a code compliant mixed fuel prototype, which uses natural gas for water heating only in most climate zones, with a code compliant all-electric prototype. In these cases, the relative costs between natural gas and electric appliances and natural gas infrastructure and the associated infrastructure costs for not providing natural gas to the building were included.

To estimate costs the Reach Codes Team leveraged costs from the 2022 Multifamily All-Electric CASE Report (Statewide CASE Team, 2020c) and the 2019 reach code multifamily cost-effectiveness studies ( (Statewide Reach Codes Team, 2020), (Statewide Reach Codes Team, 2021)), and online equipment research. Present value replacement costs are included in the total lifetime incremental costs.

3.2.2.1 Water Heating
Federal regulations establish minimum efficiency requirements for heat pump water heaters with rated storage volume less than 120 gallons. While some heat pump water heaters falling into this regulated category can be used in a central water heater design, they are not required and therefore this measure does not trigger federal preemption and heat pump equipment of any efficiency level may be used for this analysis to justify the basis of a reach code.

For the central heat pump water heating system in the 3-story prototype the system design was based on the 2022 AllElectric Multifamily CASE Report (Statewide CASE Team, 2020c) and used CO2 refrigerant based heat pump water heaters (four Sanden GS3-45HPA-US units), 525 gallons of storage, and a 250 gallon electric resistance swing tank.

The 2022 CASE work based the 5-story system design on Colmac R-134a refrigerant heat pump water heaters. While this is an acceptable design, R-134a or R-410a refrigerant heat pump water heaters were found to be less costeffective for the prototypes evaluated in this analysis due to higher incremental costs and lower overall performance relative to CO2 refrigerant products. As such, the Reach Codes Team evaluated a CO2 refrigerant system for the 5- story prototype for this analysis. As part of the 2025 Energy Code update cycle, designs for both multifamily prototypes are being reexamined using CO2 refrigerant heat pump water heaters. While full design and cost information was not yet available for this analysis, preliminary design data was used to inform sizing of a Sanden system for this prototype.

The system used 10 heat pump water heaters (Sanden GS3-45HPA-US units), 800 gallons of storage, and a 200 gallon electric resistance swing tank.

Table 6 reports costs for the central heat pump water heating systems relative to a gas boiler system with solar thermal that meets the prescriptive requirements of 20% solar fraction in Climate Zones 1 through 9 and 35% solar fraction in Climate Zones 10 through 16. Costs include equipment and labor, gas piping within the building for the boiler system, and additional electrical service necessary for the heat pump system. Replacement costs are based on an effective useful life of 15 years for the water heaters and tanks, and 20 years for the solar thermal collectors. For the solar thermal systems, it’s also assumed that the glycol is replaced at years 9, 18 and 27. Additional details on cost assumptions are presented in Appendix 7.3 Cost Details.

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localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 Table 6. Heat Pump Water Heater Incremental System Costs (Present Value (2023$)) Item
3-Story 5-Story
Source & Notes Central
Gas
Boiler
Central
Heat
Pump
Central
Gas
Boiler
Central
Heat
Pump
First Cost CZs 1-9 $173,772
$211,531
$279,163
$343,920
3-story costs directly from 2022
Multifamily All-Electric CASE
Report. 5-story costs estimated
based on component costs for
the 3-story from the CASE
report.

CZs 10-16 $182,810 $300,883
Replacement Cost CZs 1-9 $32,297
$44,263
$59,930
$110,659
CZs 10-16 $36,943 $69,361
Total Incremental
Cost
CZs 1-9
n/a
$49,725
n/a
$115,486
CZs 10-16 $36,041 $84,335
Incremental Cost
per Dwelling Unit
CZs 1-9 $1,381 $1,312
CZs 10-16 $1,001 $958

3.2.2.2 Space Heating
Table 7 presents the costs for heat pump space heater conversion from gas equipment. In most climate zones the baseline per the 2022 Energy Code is a heat pump space heater, so these costs are only applied in a couple of instances. For the 3-story prototype the baseline in Climate Zone 16 is a gas furnace and air conditioner. For the 5- story prototype the baseline in Climate Zones 1 and 16 is a dual fuel heat pump with a gas furnace as backup. Costs include equipment and labor, gas piping within the building for the boiler system, and additional electrical service necessary for the heat pump system. Most of the cost difference between the two systems is attributed to higher labor costs to install the gas system as a result of gas piping and venting. Additional details on cost assumptions are presented in Appendix 7.3 Cost Details.

Table 7. Heat Pump Space Heater Costs per Dwelling Unit (Present Value (2023$) Item
3-Story 5-Story
Furnace + Source & Notes
Split AC
Heat
Pump
Furnace +
Split HP
Heat
Pump
First Cost
$20,667 $16,776 $21,245 $16,597
Costs largely based on the 2022
Multifamily All-Electric CASE Report with
some updates to reflect online equipment
cost research and labor cost alignments.

Replacement Cost $8,059 $7,326 $9,052 $7,326 See lifetimes referenced in Table 8.

Residual value at the end of the 30-year
analysis period was accounted for to
represent the remaining life of any
Residual Value ($1,591) $0 $0 $0 equipment.

Total $27,135 $24,102 $30,296 $23,924
Incremental Cost ($3,032) ($6,373)
Equipment lifetimes applied in this analysis for the space conditioning measures are summarized in Table 8. The lifetime for the heat pump, furnace, and air conditioner are based on the Database for Energy Efficient Resources (DEER) (California Public Utilities Commission, 2021b). In DEER, heat pump and air conditioner measures are assigned an effective useful lifetime (EUL) of 15 years and a furnace an EUL of 20 years. The heating and cooling system components are typically replaced at the same time when one reaches the end of its life and the other is near

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localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 it. Therefore, it is assumed that both the furnace and air conditioner are replaced at the same time at year 17.5, halfway between 15 and 20 years. For HVAC system costing, air-conditioning is included in all cases in both the base case and proposed models.

Table 8. Lifetime of Water Heating & Space Conditioning Equipment Measures Measure Lifetime
Gas Furnace 17.5
Air Conditioner 17.5
Heat Pump 15
Dual Fuel Heat Pump 15

3.2.2.3 Natural Gas Infrastructure
Eliminating natural gas to a building saves costs associated with connecting a service line from the street main to the building, piping distribution within the building, and monthly meter customer charges from the utility. This section focuses on the first item, not connecting gas service to the building. The latter two are captured in the appliance costs and the utility bill analysis. Cost savings for removing natural gas infrastructure to a multifamily building in IOU territory are presented in Table 9 and Table 10. These costs are applied as cost savings for the all-electric case when compared to the mixed fuel baseline.

These costs are project dependent and may be significantly impacted by such factors as utility territory, site characteristics, distance to the nearest natural gas main and main location, joint trenching, whether work is conducted by the utility or a private contractor, and number of dwelling units per development. All gas utilities participating in this study were solicited for cost information.

Service Extension: Service extension costs to the building were taken from a PG&E memo dated December 5, 2019 to Energy Commission staff (see Appendix 7.4 PG&E Gas Infrastructure Cost Memo for a copy of the memo). The estimated cost of $6,750 excludes costs for trenching and assumes nonresidential new construction within a developed area. For the 5-story building the cost is apportioned between the residential and nonresidential spaces in the building based on associated conditioned floor areas where 84 percent is residential. All of the spaces in the 3-story building are residential based.

Today, total costs are reduced to account for deductions per the Utility Gas Main Extensions rules.7 These rules categorize distribution line extensions as “refundable” costs, which are offset or subsidized by all other ratepayers. The CPUC issued a Decision in September 2022 that eliminates the subsidies effective July 1, 2023 (California Public Utilities Commission, 2022). Since most of the development that will occur during the three-year 2022 code cycle (2023-2025) will not be subject to these deduction allowances they are not included in this analysis.

Meter: Cost per meter provided by PG&E of $3,600 for a commercial meter to serve the central water heating and $600 per multifamily dwelling unit. The $600 dwelling unit meter is only applied in Climate Zone 16 for the 3-story prototype and Climate Zones 1 and 16 for the 5-story prototypes where gas is used either for primary or backup space heating. Two scenarios are presented in the tables. One is the case with electric space heating, no in-unit gas and the only residential gas use is to serve the central water heating system. The other case represents the scenario where there is in-unit gas to service space heating.
7 PG&E Rule 15: https://www.pge.com/tariffs/assets/pdf/tariffbook/GAS_RULES_15.pdf.

SoCalGas Rule 20: https://www.socalgas.com/regulatory/tariffs/tm2/pdf/20.pdf.

SDG&E Rule 15: https://tariff.sdge.com/tm2/pdf/GAS_GAS-RULES_GRULE15.pdf.

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localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 Natural Gas Plan Review: Total costs are based on TRC’s 2019 reach code analysis for Palo Alto (TRC, 2018 ). The cost for the 5-story prototype is apportioned between the residential and nonresidential spaces in the building in the same way as was done for the service extension costs.

Table 9. IOU Natural Gas Infrastructure Cost Savings for All-Electric Building Item 3-Story 5-Story
Service Extension $6,750 $5,695
Meter
No In-Unit Gas
(Gas DHW only) $3,600 $3,600
In-Unit Gas $25,200 $56,400
Plan Review $2,316 $1,954
Table 10. Multifamily IOU Total Natural Gas Infrastructure Costs Prototype Scenario Total
Building
Per Dwelling
Unit
3-Story
No In-Unit Gas $12,666 $352
In-Unit Gas $34,266 $952
5-Story
No In-Unit Gas $11,248 $128
In-Unit Gas $64,048 $728
CPAU provides gas service to its customers and therefore separate costs were evaluated based on CPAU gas service connection fees.8 Table 11 presents the breakdown of gas infrastructure costs used in this analysis for CPAU. The same approach to apportioning the total building costs to the residential spaces as described in the IOU section was applied here for the service extension and plan review costs for the 5-story prototype. Meter costs were based on $1,772 for an 800 cubic foot per hour commercial meter for the central water heating system.

Table 11. Multifamily CPAU Total Natural Gas Infrastructure Costs Item 3-Story 5-Story
Service Extension $5,892 $4,971
Meter $1,772 $1,772
Plan Review $2,557 $2,157

3.3 Measure Packages
The Reach Codes Team evaluated three packages for mixed fuel homes and five packages for all-electric homes for each prototype and climate zone, as described below.

1. All-Electric Prescriptive Code: This package meets all the prescriptive requirements of the 2022 Energy Code.

2. All-Electric Prescriptive Code + PV: Using the code minimum package as a starting point, PV capacity was added to offset 100 percent of the estimated annual electricity use.

3. Mixed Fuel Efficiency Only: This package uses only efficiency measures that do not trigger federal preemption including envelope and duct distribution efficiency measures. 8 CPAU Schedule G-5 effective 09-01-2019: https://www.cityofpaloalto.org/files/assets/public/utilities/utilitiesengineering/general-specifications/gas-service-connection-fees.pdf

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localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20

4. Mixed Fuel Efficiency + PV + Battery: Using the Efficiency Package as a starting point, PV capacity was added to offset 100 percent of the estimated annual electricity use. A battery system was also added. This package only applies to the 3-story prototype. The 5-story prototype includes a battery system in the baseline per the 2022 prescriptive requirements.

5. Mixed Fuel Efficiency + PV: Using the Efficiency Package as a starting point, PV capacity was added to offset 100 percent of the estimated annual electricity use. This package only applies to the 5-story prototype.

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localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 4 Results
Cost-effectiveness results are presented per prototype and measure packages described in Section 3.3. The TDV and On-Bill based cost-effectiveness results are presented in terms of B/C ratio and NPV. Energy savings, compliance margin, utility bill savings, and incremental costs are also shown.

In the following figures, green highlighting indicates that the case is cost-effective with a B/C ratio greater than or equal to 1 and a NPV greater than or equal to 0. Red highlighting indicates the case is not cost-effective.

Compliance margins are presented as percentages both for the efficiency TDV and the source energy metrics. A compliance margin that is equal to or greater than 0 indicates the case is code compliant.

4.1 All-Electric Prescriptive Code
Table 12 and Table 13 shows results for the multifamily all-electric prescriptive code case compared to the 2022 baseline. For both prototypes this scenario is cost-effective based on TDV in all climate zones. This scenario is only On-Bill cost-effective in a few climate zones. The 3-story all-electric case is cost-effective On-Bill in Climate Zones 1 through 3, 4 in CPAU territory, 12 in SMUD territory, and 16. The 5-story all-electric case is cost-effective On-Bill in Climate Zones 1, 4, 12 in SMUD territory, and 16.

In most cases there is a small net increase in utility cost in the first year.

There is an incremental cost for the central heat pump water heater ranging from $361 to $697 per dwelling unit.

The all-electric packages applied to the 3-story prototype in Climate Zone 16 and the 5-story prototype in Climate Zones 1 and 16 incorporate both gas to electric water heating and gas to electric space heating measures. In these cases, there are significant cost savings due to the avoided first costs of installing a gas furnace as compared to a heat pump. As a result, these cases are On-Bill cost-effective.

These results reflect a CO2 refrigerant based central heat pump water heating system. The 5-story prototype was also evaluated with a R-134a refrigerant based central heat pump water heater and these results are shown in Appendix

7.5 Central Heat Pump Water Heater Comparison.

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localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 Table 12. 3-Story Cost-Effectiveness Results per Dwelling Unit: All-Electric Prescriptive Code Climate
Zone
Electric
/Gas Utility
Efficiency
TDV
Comp
Margin
Source
Comp
Margin
Annual
Elec
Savings
(kWh)
Annual
Gas
Savings
(therms)
Utility Cost Savings Incremental Cost On-Bill TDV
First
Year
Lifecycle
(2022$)
First
Year
Lifecycle
(2022$)
B/C
Ratio NPV B/C Ratio NPV
CZ01 PGE 26% 15% -904 135 ($19) $1,676 $97 $429 3.9 $1,247 >1 $4,158 CZ02 PGE 20% 11% -801 115 ($30) $1,061 $697 $1,029 1.0 $32 9.9 $2,998 CZ03 PGE 21% 10% -789 115 ($26) $1,148 $697 $1,029 1.1 $119 9.9 $2,990 CZ04 PGE 18% 9% -759 109 ($31) $922 $697 $1,029 0.9 ($108) 9.2 $2,767 CZ04 CPAU 18% 9% -759 109 $233 $8,191 $765 $1,097 7.5 $7,094 7.7 $2,700 CZ05 PGE 23% 9% -789 112 ($30) $1,009 $697 $1,029 0.98 ($21) 9.3 $2,782 CZ05 PGE/SCG 23% 9% -789 112 ($79) ($515) $697 $1,029 0.0 ($1,545) 9.3 $2,782 CZ06 SCE/SCG 18% 7% -709 100 ($61) ($226) $697 $1,029 0.0 ($1,255) 8.6 $2,551 CZ07 SDGE 20% 8% -704 102 ($69) ($427) $697 $1,029 0.0 ($1,456) 9.1 $2,712 CZ08 SCE/SCG 13% 6% -689 96 ($61) ($302) $697 $1,029 0.0 ($1,331) 8.2 $2,432 CZ09 SCE 13% 5% -698 96 ($64) ($351) $697 $1,029 0.0 ($1,380) 8.0 $2,363 CZ10 SCE/SCG 14% 7% -701 83 ($88) ($1,109) $446 $649 0.0 ($1,758) >1 $1,959 CZ10 SDGE 14% 7% -701 83 ($112) ($1,803) $446 $649 0.0 ($2,452) >1 $1,959 CZ11 PGE 14% 10% -740 91 ($64) ($177) $446 $649 0.0 ($826) >1 $2,212 CZ12 PGE 17% 11% -755 94 ($62) ($70) $446 $649 0.0 ($719) >1 $2,297 CZ12 SMUD/PGE 17% 11% -755 94 $68 $2,942 $446 $649 4.5 $2,293 >1 $2,297 CZ13 PGE 13% 9% -717 86 ($65) ($291) $446 $649 0.0 ($940) >1 $2,050 CZ14 SCE/SCG 13% 7% -748 83 ($102) ($1,413) $446 $649 0.0 ($2,063) >1 $1,759 CZ14 SDGE 13% 7% -748 83 ($128) ($2,191) $446 $649 0.0 ($2,841) >1 $1,759 CZ15 SCE/SCG 5% 2% -607 64 ($89) ($1,403) $446 $649 0.0 ($2,053) >1 $1,305 CZ16 PG&E 24% 29% -1,928 185 ($178) ($1,066) ($4,045) ($2,983) 2.8 $1,917 >1 $4,352

10.B.b
Packet Pg. 561 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-Effectiveness Analysis: Single Family New Construction 22 Results
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 Table 13. 5-Story Cost-Effectiveness Results per Dwelling Unit: All-Electric Prescriptive Code Climate
Zone
Electric
/Gas Utility
Efficiency
TDV
Comp
Margin
Source
Comp
Margin
Annual
Elec
Savings
(kWh)
Annual
Gas
Savings
(therms)
Utility Cost
Savings Incremental Cost On-Bill TDV
First
Year
Lifecycle
(2022$)
First
Year
Lifecycle
(2022$)
B/C
Ratio NPV B/C Ratio NPV
CZ01 PGE 14% 9% -1,146 147 ($49) $1,209 ($4,639) ($5,788) >1 $6,998 >1 $9,816 CZ02 PGE 9% 6% -888 120 ($45) $809 $608 $1,185 0.7 ($375) 3.0 $2,270 CZ03 PGE 11% 7% -874 120 ($46) $778 $608 $1,185 0.7 ($407) 3.1 $2,421 CZ04 PGE 9% 6% -824 113 $18 $2,130 $608 $1,185 1.8 $945 3.1 $2,393 CZ04 CPAU 9% 6% -824 113 $230 $8,205 $635 $1,211 6.8 $6,994 3.0 $2,367 CZ05 PGE 12% 6% -871 117 ($47) $706 $608 $1,185 0.6 ($479) 2.8 $2,065 CZ05 PGE/SCG 12% 6% -871 117 ($99) ($919) $608 $1,185 0.0 ($2,103) 2.8 $2,065 CZ06 SCE/SCG 9% 5% -739 104 ($10) $986 $608 $1,185 0.8 ($199) 2.9 $2,183 CZ07 SDGE 11% 6% -735 106 ($74) ($500) $608 $1,185 0.0 ($1,685) 2.9 $2,215 CZ08 SCE/SCG 8% 4% -710 100 ($79) ($644) $608 $1,185 0.0 ($1,829) 3.0 $2,259 CZ09 SCE 7% 4% -725 100 ($53) ($51) $608 $1,185 0.0 ($1,236) 3.0 $2,274 CZ10 SCE/SCG 7% 4% -729 84 ($111) ($1,615) $361 $831 0.0 ($2,445) 2.7 $1,374 CZ10 SDGE 7% 4% -729 84 ($137) ($2,404) $361 $831 0.0 ($3,234) 2.7 $1,374 CZ11 PGE 8% 5% -790 92 ($86) ($663) $361 $831 0.0 ($1,494) 3.1 $1,656 CZ12 PGE 9% 6% -809 96 ($83) ($527) $361 $831 0.0 ($1,358) 3.0 $1,620 CZ12 SMUD/PGE 9% 6% -809 96 $62 $2,831 $361 $831 3.4 $2,000 3.0 $1,620 CZ13 PGE 7% 5% -754 88 ($83) ($686) $361 $831 0.0 ($1,517) 3.0 $1,570 CZ14 SCE/SCG 6% 3% -803 84 ($131) ($2,085) $361 $831 0.0 ($2,916) 2.2 $928 CZ14 SDGE 6% 3% -803 84 ($165) ($3,106) $361 $831 0.0 ($3,937) 2.2 $928 CZ15 SCE/SCG 3% 1% -602 65 ($105) ($1,775) $361 $831 0.0 ($2,606) 1.9 $695 CZ16 PG&E 9% 11% -1,388 142 ($127) ($675) ($4,886) ($6,142) 9.1 $5,467 >1 $6,704

10.B.b
Packet Pg. 562 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-Effectiveness Analysis: Single Family New Construction 23 Results
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20

4.2 All-Electric Plus PV
Table 14 and Table 15 present cost-effectiveness results for the all-electric plus PV packages for the 3-story and 5-story prototypes, respectively. All cases are cost-effective both On-Bill and based on TDV.

Table 14. 3-Story Cost-Effectiveness Results per Dwelling Unit: All-Electric 100% PV Climate
Zone
Electric
/Gas Utility
Efficiency
TDV
Comp
Margin
Source
Comp
Margin
Annual
Elec
Savings
(kWh)
Annual
Gas
Savings
(therms)
Utility Cost
Savings Incremental Cost On-Bill TDV
First
Year
Lifecycle
(2022$)
First
Year
Lifecycle
(2022$)
B/C
Ratio NPV B/C Ratio NPV
CZ01 PGE 26% 24% 2,127 135 $782 $20,242 $3,638 $5,034 4.0 $15,208 3.2 $9,448 CZ02 PGE 20% 20% 1,835 115 $653 $16,910 $3,294 $4,406 3.8 $12,504 3.3 $8,632 CZ03 PGE 21% 20% 1,711 115 $614 $15,998 $3,076 $4,123 3.9 $11,875 3.4 $8,209 CZ04 PGE 18% 18% 1,558 109 $559 $14,587 $2,841 $3,818 3.8 $10,770 3.6 $8,230 CZ04 CPAU 18% 18% 1,558 109 $489 $14,138 $2,909 $3,886 3.6 $10,253 3.6 $8,162 CZ05 PGE 23% 20% 1,604 112 $579 $15,137 $2,826 $3,798 4.0 $11,338 3.6 $8,026 CZ05 PGE/SCG 23% 20% 1,604 112 $531 $13,613 $2,826 $3,798 3.6 $9,814 3.6 $8,026 CZ06 SCE/SCG 18% 17% 1,207 100 $378 $9,795 $2,364 $3,197 3.1 $6,598 3.8 $7,092 CZ07 SDGE 20% 21% 1,528 102 $723 $19,318 $2,777 $3,734 5.2 $15,584 3.5 $7,623 CZ08 SCE/SCG 13% 17% 1,393 96 $426 $10,842 $2,569 $3,464 3.1 $7,378 3.9 $7,908 CZ09 SCE 13% 15% 1,204 96 $379 $9,756 $2,335 $3,160 3.1 $6,596 3.9 $7,158 CZ10 SCE/SCG 14% 18% 1,381 83 $404 $10,130 $2,237 $2,978 3.4 $7,152 4.1 $7,031 CZ10 SDGE 14% 18% 1,381 83 $621 $16,493 $2,237 $2,978 5.5 $13,514 4.1 $7,031 CZ11 PGE 14% 19% 1,843 91 $625 $15,782 $2,940 $3,893 4.1 $11,889 3.4 $7,748 CZ12 PGE 17% 19% 1,704 94 $579 $14,777 $2,756 $3,654 4.0 $11,124 3.6 $7,607 CZ12 SMUD/PGE 17% 19% 1,704 94 $399 $10,615 $2,756 $3,654 2.9 $6,961 3.6 $7,607 CZ13 PGE 13% 17% 1,572 86 $544 $13,822 $2,567 $3,408 4.1 $10,415 3.6 $7,148 CZ14 SCE/SCG 13% 18% 1,572 83 $449 $11,152 $2,300 $3,060 3.6 $8,092 4.2 $7,668 CZ14 SDGE 13% 18% 1,572 83 $688 $18,158 $2,300 $3,060 5.9 $15,098 4.2 $7,668 CZ15 SCE/SCG 5% 11% 1,163 64 $330 $8,164 $1,966 $2,626 3.1 $5,539 3.9 $5,567 CZ16 PG&E 24% 38% 1,371 185 $700 $19,307 ($1,064) $894 21.6 $18,412 58.9 $11,596

10.B.b
Packet Pg. 563 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-Effectiveness Analysis: Single Family New Construction 24 Results
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 Table 15. 5-Story Cost-Effectiveness Results per Dwelling Unit: All-Electric 100% PV Climate
Zone
Electric
/Gas Utility
Efficiency
TDV
Comp
Margin
Source
Comp
Margin
Annual
Elec
Savings
(kWh)
Annual
Gas
Savings
(therms)
Utility Cost
Savings Incremental Cost On-Bill TDV
First
Year
Lifecycle
(2022$)
First
Year
Lifecycle
(2022$)
B/C
Ratio NPV B/C Ratio NPV
CZ01 PGE 14% 21% 1,437 147 $629 $16,919 ($1,574) ($1,803) >1 $18,721 >1 $18,222 CZ02 PGE 9% 14% 428 120 $262 $7,918 $1,930 $2,904 2.7 $5,015 4.0 $8,679 CZ03 PGE 11% 16% 682 120 $327 $9,417 $2,121 $3,152 3.0 $6,265 4.0 $9,285 CZ04 PGE 9% 13% 92 113 $207 $6,524 $1,476 $2,313 2.8 $4,211 4.1 $7,054 CZ04 CPAU 9% 13% 92 113 $337 $10,667 $1,502 $2,340 4.6 $8,327 4.0 $7,027 CZ05 PGE 12% 16% 451 117 $259 $7,806 $1,815 $2,754 2.8 $5,052 4.0 $8,096 CZ05 PGE/SCG 12% 16% 451 117 $207 $6,182 $1,815 $2,754 2.2 $3,427 4.0 $8,096 CZ06 SCE/SCG 9% 12% -163 104 $98 $3,449 $1,127 $1,859 1.9 $1,590 3.8 $5,035 CZ07 SDGE 11% 15% 74 106 $192 $6,131 $1,387 $2,198 2.8 $3,934 3.9 $6,204 CZ08 SCE/SCG 8% 14% 265 100 $154 $4,666 $1,516 $2,365 2.0 $2,301 4.0 $7,053 CZ09 SCE 7% 12% 60 100 $122 $3,930 $1,307 $2,093 1.9 $1,837 3.7 $5,636 CZ10 SCE/SCG 7% 13% 289 84 $131 $3,912 $1,266 $2,007 1.9 $1,905 3.9 $5,749 CZ10 SDGE 7% 13% 289 84 $238 $6,951 $1,266 $2,007 3.5 $4,945 3.9 $5,749 CZ11 PGE 8% 17% 1,091 92 $417 $10,990 $2,226 $3,256 3.4 $7,734 4.2 $10,472 CZ12 PGE 9% 16% 594 96 $263 $7,487 $1,712 $2,587 2.9 $4,901 4.3 $8,544 CZ12 SMUD/PGE 9% 16% 594 96 $260 $7,419 $1,712 $2,587 2.9 $4,889 4.3 $8,544 CZ13 PGE 7% 17% 1,036 88 $398 $10,479 $2,064 $3,045 3.4 $7,434 4.2 $9,715 CZ14 SCE/SCG 6% 11% 182 84 $102 $3,250 $1,170 $1,883 1.7 $1,368 4.0 $5,515 CZ14 SDGE 6% 11% 182 84 $194 $5,858 $1,170 $1,883 3.1 $3,975 4.0 $5,515 CZ15 SCE/SCG 3% 10% 387 65 $153 $4,119 $1,238 $1,971 2.1 $2,148 3.6 $4,998 CZ16 PG&E 9% 23% 1,007 142 $501 $13,864 ($2,682) ($3,275) >1 $17,139 >1 $16,140

10.B.b
Packet Pg. 564 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-Effectiveness Analysis: Single Family New Construction 25 Results
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20

4.3 Mixed Fuel Efficiency
Table 16 and Table 17 show results for the Mixed Fuel Efficiency packages. The packages are cost-effective based on at least one of the two metrics in Climate Zones 1, 2, 4, and 8 through 16 for the 3-story prototype and in Climate Zones 2, 4, 6, and 8 through 15 for the 5-story prototype. In all cases the NPV values, whether negative or positive, are small. The compliance impacts are also small.

A summary of measures included in each package is provided in Appendix 7.6 Summary of Measures by Package.

Table 16. 3-Story Cost-Effectiveness Results per Dwelling Unit: Mixed Fuel Efficiency Climate
Zone
Electric
/Gas Utility
Efficiency
TDV
Comp
Margin
Source
Comp
Margin
Annual
Elec
Savings
(kWh)
Annual
Gas
Savings
(therms)
Utility Cost
Savings Incremental Cost On-Bill TDV
First
Year
Lifecycle
(2022$)
First
Year
Lifecycle
(2022$)
B/C
Ratio NPV B/C Ratio NPV
CZ01 PGE 1% 1% 41 0 $12 $273 $176 $176 1.6 $98 1.2 $38
CZ02 PGE 1% 0% 24 0 $7 $162 $132 $132 1.2 $30 1.5 $62
CZ03 PGE 1% 0% 17 0 $5 $111 $132 $132 0.8 ($21) 0.8 ($27) CZ04 PGE 1% 0% 21 0 $6 $141 $132 $132 1.1 $9 1.3 $46
CZ04 CPAU 1% 0% 21 0 $3 $74 $132 $132 0.6 ($58) 1.3 $46 CZ05 PGE 1% 0% 19 0 $5 $123 $132 $132 0.9 ($9) 0.8 ($32) CZ05 PGE/SCG 1% 0% 19 0 $5 $123 $132 $132 0.9 ($9) 0.8 ($32) CZ06 SCE/SCG 1% 0% 9 0 $2 $56 $132 $132 0.4 ($75) 0.7 ($44) CZ07 SDGE 0% 0% 7 0 $3 $72 $132 $132 0.5 ($60) 0.4 ($81) CZ08 SCE/SCG 1% 0% 20 0 $6 $140 $132 $132 1.1 $9 1.5 $59 CZ09 SCE 1% 0% 28 0 $8 $192 $146 $156 1.2 $36 1.6 $88
CZ10 SCE/SCG 3% 1% 65 0 $20 $447 $190 $199 2.2 $247 2.4 $277 CZ10 SDGE 3% 1% 65 0 $27 $683 $190 $199 3.4 $484 2.4 $277 CZ11 PGE 3% 1% 91 0 $30 $699 $190 $199 3.5 $499 3.5 $489 CZ12 PGE 2% 0% 98 0 $33 $766 $381 $514 1.5 $252 1.5 $273 CZ12 SMUD/PGE 2% 0% 98 0 $17 $396 $381 $514 0.8 ($118) 1.5 $273 CZ13 PGE 4% 1% 99 0 $33 $765 $190 $199 3.8 $566 3.9 $574 CZ14 SCE/SCG 3% 1% 88 0 $26 $585 $190 $199 2.9 $385 3.1 $427 CZ14 SDGE 3% 1% 88 0 $36 $886 $190 $199 4.4 $686 3.1 $427 CZ15 SCE/SCG 5% 2% 182 0 $54 $1,226 $190 $199 6.1 $1,026 5.8 $957 CZ16 PG&E 5% 4% 16 12 $34 $1,012 $712 $712 1.4 $300 1.3 $184

10.B.b
Packet Pg. 565 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-Effectiveness Analysis: Single Family New Construction 26 Results
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 Table 17. 5-Story Cost-Effectiveness Results per Dwelling Unit: Mixed Fuel Efficiency

4.4 Mixed Fuel Plus PV (Plus Battery for the 3-Story Prototype) Table 18 presents the Mixed Fuel Efficiency + PV + Battery package for the 3-story prototype. The battery system is a 100kWh battery. This scenario is costeffective for all climate zones and under both metrics except for On-Bill in Climate Zone 4 in CPAU territory. Table 19 presents the Mixed Fuel Efficiency + PV package for the 5-story prototype. This package is cost-effective under TDV in all climate zones and cost-effective On-Bill everywhere except in Climate Zones 6 and 7. In the cases where it is not cost-effective, it is very close to being so with small negative NPV. In Climate Zone 6 in the 5-story prototype there is no upgrade to the PV system capacity as the prescriptive PV system already offset all of the estimated electricity use.

Climate
Zone
Electric
/Gas Utility
Efficiency
TDV
Comp
Margin
Source
Comp
Margin
Annual
Elec
Savings
(kWh)
Annual
Gas
Savings
(therms)
Utility Cost
Savings Incremental Cost On-Bill TDV
First
Year
Lifecycle
(2022$)
First
Year
Lifecycle
(2022$)
B/C
Ratio NPV B/C Ratio NPV
CZ01 PGE 0% 0% 5 0 $2 $39 $176 $176 0.2 ($137) 0.2 ($136) CZ02 PGE 1% 0% 11 0 $2 $38 $132 $132 0.3 ($94) 1.9 $118 CZ03 PGE 0% 0% 7 0 $2 $46 $132 $132 0.3 ($86) 0.8 ($23) CZ04 PGE 1% 0% 12 0 $2 $40 $132 $132 0.3 ($92) 1.9 $114 CZ04 CPAU 1% 0% 12 0 $2 $39 $132 $132 0.3 ($93) 1.9 $114 CZ05 PGE 0% 0% 6 0 $1 $17 $132 $132 0.1 ($114) 0.4 ($73) CZ05 PGE/SCG 0% 0% 6 0 $1 $17 $132 $132 0.1 ($114) 0.4 ($73) CZ06 SCE/SCG 0% 0% 12 0 $2 $51 $132 $132 0.4 ($81) 1.4 $49 CZ07 SDGE 0% 0% 10 0 $0 $0 $132 $132 0.0 ($132) 0.9 ($7) CZ08 SCE/SCG 1% 0% 24 0 $8 $184 $132 $132 1.4 $53 2.2 $152 CZ09 SCE 1% 0% 28 0 $4 $96 $142 $149 0.6 ($52) 2.1 $163 CZ10 SCE/SCG 2% 1% 66 0 $21 $491 $186 $192 2.6 $298 3.2 $425 CZ10 SDGE 2% 1% 66 0 $30 $751 $186 $192 3.9 $558 3.2 $425 CZ11 PGE 2% 1% 83 0 $29 $665 $186 $192 3.5 $473 4.2 $621 CZ12 PGE 2% 0% 84 0 $29 $681 $321 $414 1.6 $267 2.3 $546 CZ12 SMUD/PGE 2% 0% 84 0 $16 $372 $321 $414 0.9 ($42) 2.3 $546 CZ13 PGE 2% 1% 95 0 $33 $765 $186 $192 4.0 $573 4.9 $742 CZ14 SCE/SCG 2% 1% 75 0 $11 $246 $186 $192 1.3 $54 3.9 $561 CZ14 SDGE 2% 1% 75 0 $34 $847 $186 $192 4.4 $654 3.9 $561 CZ15 SCE/SCG 3% 2% 172 0 $55 $1,257 $186 $192 6.5 $1,065 7.3 $1,212 CZ16 PG&E 2% 2% 40 4 $23 $616 $665 $665 0.9 ($49) 0.999 ($0)

10.B.b
Packet Pg. 566 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-Effectiveness Analysis: Single Family New Construction 27 Results
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 Table 18. 3-Story Cost-Effectiveness Results per Dwelling Unit: Mixed Fuel Efficiency + PV + Battery Climate
Zone
Electric
/Gas Utility
Efficiency
TDV
Comp
Margin
Source
Comp
Margin
Annual
Elec
Savings
(kWh)
Annual
Gas
Savings
(therms)
Utility Cost
Savings Incremental Cost On-Bill TDV
First
Year
Lifecycle
(2022$)
First
Year
Lifecycle
(2022$)
B/C
Ratio NPV B/C Ratio NPV
CZ01 PGE 1% 16% 2,068 0 $543 $12,588 $4,603 $6,917 1.8 $5,671 1.5 $3,724 CZ02 PGE 1% 16% 1,757 0 $462 $10,718 $3,881 $5,990 1.8 $4,728 1.6 $3,820 CZ03 PGE 1% 17% 1,624 0 $423 $9,797 $3,700 $5,754 1.7 $4,043 1.5 $3,157 CZ04 PGE 1% 17% 1,476 0 $383 $8,878 $3,518 $5,518 1.6 $3,360 1.6 $3,067 CZ04 CPAU 1% 17% 1,476 0 $171 $3,967 $3,518 $5,518 0.7 ($1,551) 1.6 $3,067 CZ05 PGE 1% 18% 1,520 0 $393 $9,107 $3,503 $5,498 1.7 $3,609 1.6 $3,526 CZ05 PGE/SCG 1% 18% 1,520 0 $393 $9,107 $3,503 $5,498 1.7 $3,609 1.6 $3,526 CZ06 SCE/SCG 1% 18% 1,112 0 $336 $7,677 $3,127 $5,009 1.5 $2,668 1.4 $1,917 CZ07 SDGE 0% 20% 1,431 0 $550 $13,713 $3,498 $5,493 2.5 $8,220 1.6 $3,159 CZ08 SCE/SCG 1% 18% 1,311 0 $413 $9,427 $3,328 $5,270 1.8 $4,156 1.4 $2,277 CZ09 SCE 1% 17% 1,129 0 $367 $8,375 $3,129 $5,017 1.7 $3,359 1.4 $1,937 CZ10 SCE/SCG 3% 19% 1,342 0 $420 $9,584 $3,321 $5,254 1.8 $4,331 1.5 $2,588 CZ10 SDGE 3% 19% 1,342 0 $533 $13,303 $3,321 $5,254 2.5 $8,049 1.5 $2,588 CZ11 PGE 3% 17% 1,833 0 $500 $11,587 $3,914 $6,025 1.9 $5,562 1.6 $3,852 CZ12 PGE 2% 17% 1,701 0 $442 $10,239 $3,926 $6,105 1.7 $4,133 1.6 $3,583 CZ12 SMUD/PGE 2% 17% 1,701 0 $285 $6,609 $3,926 $6,105 1.1 $503 1.6 $3,583 CZ13 PGE 4% 17% 1,568 0 $431 $9,983 $3,594 $5,609 1.8 $4,374 1.7 $3,944 CZ14 SCE/SCG 3% 19% 1,556 0 $477 $10,886 $3,388 $5,341 2.0 $5,545 1.6 $3,434 CZ14 SDGE 3% 19% 1,556 0 $607 $15,155 $3,388 $5,341 2.8 $9,815 1.6 $3,434 CZ15 SCE/SCG 5% 19% 1,241 0 $421 $9,616 $3,136 $5,013 1.9 $4,603 1.6 $3,076 CZ16 PG&E 5% 17% 1,286 12 $357 $8,508 $3,894 $5,833 1.5 $2,674 1.6 $3,219

10.B.b
Packet Pg. 567 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-Effectiveness Analysis: Single Family New Construction 28 Results
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 Table 19. 5-Story Cost-Effectiveness Results per Dwelling Unit: Mixed Fuel Efficiency + PV Climate
Zone
Electric
/Gas Utility
Efficiency
TDV
Comp
Margin
Source
Comp
Margin
Annual
Elec
Savings
(kWh)
Annual
Gas
Savings
(therms)
Utility Cost
Savings Incremental Cost On-Bill TDV
First
Year
Lifecycle
(2022$)
First
Year
Lifecycle
(2022$)
B/C
Ratio NPV B/C Ratio NPV
CZ01 PGE 0% 5% 1,446 0 $341 $7,917 $1,889 $2,403 3.3 $5,514 3.0 $4,757 CZ02 PGE 1% 2% 444 0 $55 $1,275 $567 $697 1.8 $578 4.4 $2,365 CZ03 PGE 0% 4% 693 0 $119 $2,766 $801 $1,002 2.8 $1,764 4.4 $3,423 CZ04 PGE 1% 1% 112 0 $14 $324 $226 $254 1.3 $69 3.5 $632 CZ04 CPAU 1% 1% 112 0 $13 $307 $226 $254 1.2 $53 3.5 $632 CZ05 PGE 0% 3% 464 0 $56 $1,310 $550 $676 1.9 $634 4.2 $2,165 CZ05 PGE/SCG 0% 3% 464 0 $56 $1,310 $550 $676 1.9 $634 4.2 $2,165 CZ06 SCE/SCG 0% 0% 12 0 $2 $51 $132 $132 0.4 ($81) 1.4 $49 CZ07 SDGE 0% 1% 95 0 $0 $0 $212 $237 0.0 ($237) 2.8 $423 CZ08 SCE/SCG 1% 3% 299 0 $42 $968 $388 $465 2.1 $504 4.3 $1,527 CZ09 SCE 1% 1% 99 0 $12 $284 $204 $230 1.2 $54 3.0 $465 CZ10 SCE/SCG 2% 3% 364 0 $57 $1,296 $450 $536 2.4 $759 4.2 $1,720 CZ10 SDGE 2% 3% 364 0 $103 $2,566 $450 $536 4.8 $2,030 4.2 $1,720 CZ11 PGE 2% 7% 1,178 0 $281 $6,521 $1,276 $1,610 4.1 $4,911 4.8 $6,162 CZ12 PGE 2% 4% 683 0 $120 $2,791 $898 $1,164 2.4 $1,627 4.2 $3,716 CZ12 SMUD/PGE 2% 4% 683 0 $102 $2,362 $898 $1,164 2.0 $1,198 4.2 $3,716 CZ13 PGE 2% 7% 1,137 0 $274 $6,347 $1,179 $1,484 4.3 $4,863 4.8 $5,599 CZ14 SCE/SCG 2% 2% 266 0 $33 $748 $342 $395 1.9 $353 4.7 $1,447 CZ14 SDGE 2% 2% 266 0 $62 $1,554 $342 $395 3.9 $1,158 4.7 $1,447 CZ15 SCE/SCG 3% 5% 567 0 $125 $2,851 $535 $646 4.4 $2,204 5.6 $2,994 CZ16 PG&E 2% 6% 1,051 4 $237 $5,569 $1,601 $1,883 3.0 $3,686 3.1 $4,011

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localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20

4.5 CARE Rate Comparison
Table 20 presents a comparison of On-Bill cost-effectiveness results for CARE tariffs relative to standard tariffs for the all-electric prescriptive code case. The CARE rates apply to the apartment meters only and don’t impact the central water heating utility costs. Applying the CARE rates lowers both electric and gas utility bills for the consumer and the net impact for an all-electric building in most climate zones is lower overall bills and improved cost-effectiveness relative to the standard tariffs. Although not presented here, the all-electric + PV packages are all still On-Bill costeffective using the CARE tariffs.

Table 20. On-Bill IOU Cost-Effectiveness Comparison with CARE Tariffs, Results per Dwelling Unit: All-Electric Prescriptive Code
Climate
Zone
Electric
/Gas Utility
3-Story 5-Story
Standard CARE Standard CARE
B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV CZ01 PGE 3.9 $1,247 9.5 $3,637 >1 $6,998 >1 $10,045
CZ02 PGE 1.0 $32 3.1 $2,139 0.7 ($375) 2.5 $1,831
CZ03 PGE 1.1 $119 3.1 $2,187 0.7 ($407) 2.6 $1,901
CZ04 PGE 0.9 ($108) 2.8 $1,884 1.8 $945 2.9 $2,218
CZ05 PGE 0.98 ($21) 3.0 $2,041 0.6 ($479) 2.5 $1,773
CZ05 PGE/SCG 0.0 ($1,545) 1.5 $517 0.0 ($2,103) 1.1 $148 CZ06 SCE/SCG 0.0 ($1,255) 0.9 ($57) 0.8 ($199) 2.1 $1,349 CZ07 SDGE 0.0 ($1,456) 1.8 $856 0.0 ($1,685) 1.3 $343
CZ08 SCE/SCG 0.0 ($1,331) 0.8 ($165) 0.0 ($1,829) 1.2 $271 CZ09 SCE 0.0 ($1,380) 0.8 ($204) 0.0 ($1,236) 1.6 $750
CZ10 SCE/SCG 0.0 ($1,758) 0.1 ($574) 0.0 ($2,445) 0.5 ($447) CZ10 SDGE 0.0 ($2,452) 0.8 ($162) 0.0 ($3,234) 0.0 ($1,590) CZ11 PGE 0.0 ($826) 2.7 $1,119 0.0 ($1,494) 1.7 $616
CZ12 PGE 0.0 ($719) 2.9 $1,263 0.0 ($1,358) 2.0 $793
CZ13 PGE 0.0 ($940) 2.4 $936 0.0 ($1,517) 1.6 $491
CZ14 SCE/SCG 0.0 ($2,063) 0.0 ($803) 0.0 ($2,916) 0.3 ($613) CZ14 SDGE 0.0 ($2,841) 0.0 ($3,407) 0.0 ($3,937) 1.1 $61 CZ15 SCE/SCG 0.0 ($2,053) 0.0 ($1,036) 0.0 ($2,606) 0.0 ($1,452) CZ16 PG&E 2.8 $1,917 >1 $5,527 9.1 $5,467 >1 $8,557
Error! Not a valid bookmark self-reference. presents the comparison for the mixed fuel efficiency and PV packages.

Generally, the opposite trend occurs here for the mixed fuel packages where the CARE rate lowers utility cost savings and the benefit-to-cost ratios decline.

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localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 Table 21. On-Bill IOU Cost-Effectiveness Comparison with CARE Tariffs, Results per Dwelling Unit: Mixed Fuel Packages
Climate
Zone
Electric
/Gas Utility
3-Story (Efficiency + PV + Battery) 5-Story (Efficiency + PV) Standard CARE Standard CARE
B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV CZ01 PGE 1.8 $5,671 1.2 $1,113 3.3 $5,514 2.2 $2,765
CZ02 PGE 1.8 $4,728 1.2 $907 1.8 $578 1.5 $337
CZ03 PGE 1.7 $4,043 1.1 $579 2.8 $1,764 2.0 $1,028
CZ04 PGE 1.6 $3,360 1.0 $259 1.3 $69 0.8 ($44)
CZ05 PGE 1.7 $3,609 1.1 $414 1.9 $634 1.7 $442
CZ05 PGE/SCG 1.7 $3,609 1.1 $414 1.9 $634 1.7 $442
CZ06 SCE/SCG 1.5 $2,668 0.9 ($515) 0.4 ($81) 0.3 ($92)
CZ07 SDGE 2.5 $8,220 1.7 $4,106 0.0 ($237) 0.0 ($237)
CZ08 SCE/SCG 1.8 $4,156 1.1 $446 2.1 $504 1.3 $137
CZ09 SCE 1.7 $3,359 0.99 ($26) 1.2 $54 0.9 ($28)
CZ10 SCE/SCG 1.8 $4,331 1.1 $577 2.4 $759 1.3 $180
CZ10 SDGE 2.5 $8,049 1.8 $4,180 4.8 $2,030 0.0 ($536)
CZ11 PGE 1.9 $5,562 1.2 $1,435 4.1 $4,911 2.7 $2,744
CZ12 PGE 1.7 $4,133 1.1 $517 2.4 $1,627 1.8 $905
CZ13 PGE 1.8 $4,374 1.2 $883 4.3 $4,863 2.9 $2,777
CZ14 SCE/SCG 2.0 $5,545 1.3 $1,395 1.9 $353 1.3 $136
CZ14 SDGE 2.8 $9,815 1.4 $2,292 3.9 $1,158 0.0 ($395)
CZ15 SCE/SCG 1.9 $4,603 1.2 $887 4.4 $2,204 1.9 $586
CZ16 PG&E 1.5 $2,674 0.97 ($162) 3.0 $3,686 2.0 $1,908

4.6 Greenhouse Gas Reductions
Figure 1 and Figure 2 compare greenhouse gas reductions across all the packages for the multifamily 3-story and 5- story prototypes, respectively. Savings represent average annual savings per dwelling unit over the 30-year lifetime of the analysis. Electrification of gas uses represents the greatest greenhouse gas reductions, followed by PV.

Greenhouse gas reductions are greatest for the all-electric + PV package.

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localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 Figure 1. 3-Story greenhouse gas reductions (metric tons) per dwelling unit Figure 2. 5-Story greenhouse gas savings (metric tons) per dwelling unit

0.0 0.1

0.2 0.3

0.4 0.5

0.6 0.7

0.8 0.9

1.0 CZ01 CZ02 CZ03 CZ04 CZ05 CZ06 CZ07 CZ08 CZ09 CZ10 CZ11 CZ12 CZ13 CZ14 CZ15 CZ16 Greenhouse Gas Reduc�ons (metric tons)
Mixed Fuel Efficiency
Mixed Fuel Efficiency + PV + Ba�ery
All-Electric Code Minimum
All-Electric + PV

0.0 0.1

0.2 0.3

0.4 0.5

0.6 0.7

0.8 0.9

1.0 CZ01 CZ02 CZ03 CZ04 CZ05 CZ06 CZ07 CZ08 CZ09 CZ10 CZ11 CZ12 CZ13 CZ14 CZ15 CZ16 Greenhouse Gas Reduc�ons (metric tons)
Mixed Fuel Efficiency
Mixed Fuel Efficiency + PV
All-Electric Code Minimum
All-Electric + PV

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localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 5 Summary
The Reach Codes Team identified packages of electrification and energy efficiency measures as well as packages combining these measures with solar PV generation and battery storage, simulated them using building modeling software, and gathered costs to determine the cost-effectiveness of multiple scenarios. The Reach Codes Team coordinated with multiple utilities, cities, and building community experts to develop a set of assumptions considered reasonable in the current market. Changing assumptions, such as the period of analysis, measure selection, cost assumptions, energy escalation rates, or utility tariffs are likely to change results.

Table 22 summarizes results for each prototype and depicts the efficiency TDV compliance margins achieved for each climate zone and package. Because local reach codes must both exceed the Energy Commission performance budget (i.e., have a positive compliance margin) and be cost-effective, the Reach Codes Team highlighted cells meeting these two requirements to help clarify the upper boundary for potential reach code policies. All results presented in this study have a positive compliance margin.
• Cells highlighted in green depict cases with a positive compliance margin and cost-effective results using both On-Bill and TDV approaches.
• Cells highlighted in yellow depict cases with a positive compliance margin and cost-effective results using either the On-Bill or TDV approach.
• Cells not highlighted depict cases with a positive compliance margin but that were not cost-effective using either the On-Bill or TDV approach.

Following are key takeaways and recommendations from the analysis. • The Reach Codes Team found all-electric new construction to be feasible and cost-effective based on the California Energy Commission’s Time Dependent Valuation (TDV) metric in all cases. In many cases allelectric prescriptive code construction results in an increase in utility costs and is not cost-effective On-Bill.

Some exceptions include the SMUD and CPAU territories where lower electricity rates relative to gas rates result in lower overall utility bills.
• All-electric packages have lower GHG emissions than mixed fuel packages in all cases, due to the clean power sources currently available from California’s power providers. • The 2022 Energy Code’s new source energy metric combined with the heat pump space heating baseline in most climate zones encourages all-electric construction. While the code does not include an electric baseline for water heating, the penalty for central electric water heating observed in the performance approach in past code cycles has been removed and a credit is provided for well-designed central heat pump water heaters in most cases.
• Electrification combined with increased PV capacity results in utility cost savings and was found to be On-Bill cost-effective in all cases.
• The results in this study are based on today’s net energy metering (NEM 2.0) rules and do not account for recently approved changes to the NEM tariff (referred to as the net billing tariff). The net billing tariff decreases the value of PV to the consumer as compared to NEM 2.0. As a result, the cost-effectiveness of the packages that include above-code PV capacity is expected to be less under the net billing tariff. Conversely, the net billing tariff is expected to increase On-Bill cost-effectiveness of the all-electric prescriptive code scenario. An all-electric home has better on-site utilization of generated electricity from PV than a mixed fuel home with a similar sized PV system, and as a result exports less electricity to the grid. Since the net-billing tariff values exports less than under NEM 2.0, the relative impact on annual utility costs to the mixed fuel baseline is greater.
• This analysis does justify requiring a modest reach based on either efficiency TDV or source energy for allelectric buildings. However, this may be challenging for some projects given the recent changes to which the industry must adapt, including the efficiency updates and multifamily restructuring in the 2022 Title 24, Part 6 code. While project compliance margins using a CO2 refrigerant heat pump water heating system are high, the Reach Code Team found lower compliance margins using other heat pump water heater system designs.

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localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 Focusing on supporting projects to electrify water heating is expected to support the market shift towards more central heat pump water heaters.
• For jurisdictions interested in a reach code that allows for mixed fuel buildings, a mixed fuel efficiency and PV package (and battery for the 3-story prototype) was found to be cost-effective based on TDV in all cases and cost-effective On-Bill in most climate zones. This path, referred to as “Electric-Preferred”, allows for mixed fuel buildings but requires a higher building performance than for all-electric buildings. The efficiency measures evaluated in this study did not provide significant compliance benefit. As a result, the Reach Codes Team recommends establishing a compliance margin target based on source energy or total TDV. This would allow for PV and battery above minimum code requirements to be used to meet the target. • Jurisdictions interested in increasing affordable multifamily housing should know that applying the CARE rates has the overall impact of increasing utility cost savings for an all-electric building in most climate zones compared to a code compliant mixed fuel building, improving On-Bill cost-effectiveness.

Local jurisdictions may also adopt ordinances that amend different parts of the California Building Standards Code or may elect to amend other state or municipal codes. The decision regarding which code to amend will determine the specific requirements that must be followed for an ordinance to be legally enforceable. Reach codes that amend Part 6 of the California Building Code and require energy performance beyond state code minimums must demonstrate the proposed changes are cost-effective and obtain approval from the Energy Commission.

Table 22. Summary of Efficiency TDV Compliance Margins and Cost-Effectiveness Climate
Zone
Electric
/Gas Utility
3-Story 5-Story
All-Electric
Prescriptive
Code
AllElectric
+ PV
Mixed
Fuel
Efficiency
Mixed
Fuel
Efficiency
+ PV +
Battery
All-Electric
Prescriptive
Code
AllElectric
+ PV
Mixed
Fuel
Efficiency
Mixed
Fuel
Efficiency
+ PV
CZ01 PGE 26% 26% 1% 1% 14% 14% 0% 0%
CZ02 PGE 20% 20% 1% 1% 9% 9% 1% 1%
CZ03 PGE 21% 21% 1% 1% 11% 11% 0% 0%
CZ04 PGE 18% 18% 1% 1% 9% 9% 1% 1%
CZ04 CPAU 18% 18% 1% 1% 9% 9% 1% 1%
CZ05 PGE 23% 23% 1% 1% 12% 12% 0% 0%
CZ05 PGE/SCG 23% 23% 1% 1% 12% 12% 0% 0%
CZ06 SCE/SCG 18% 18% 1% 1% 9% 9% 0% 0%
CZ07 SDGE 20% 20% 0% 0% 11% 11% 0% 0%
CZ08 SCE/SCG 13% 13% 1% 1% 8% 8% 1% 1%
CZ09 SCE 13% 13% 1% 1% 7% 7% 1% 1%
CZ10 SCE/SCG 14% 14% 3% 3% 7% 7% 2% 2%
CZ10 SDGE 14% 14% 3% 3% 7% 7% 2% 2%
CZ11 PGE 14% 14% 3% 3% 8% 8% 2% 2%
CZ12 PGE 17% 17% 2% 2% 9% 9% 2% 2%
CZ12 SMUD/PGE 17% 17% 2% 2% 9% 9% 2% 2%
CZ13 PGE 13% 13% 4% 4% 7% 7% 2% 2%
CZ14 SCE/SCG 13% 13% 3% 3% 6% 6% 2% 2%
CZ14 SDGE 13% 13% 3% 3% 6% 6% 2% 2%
CZ15 SCE/SCG 5% 5% 5% 5% 3% 3% 3% 3%
CZ16 PG&E 24% 24% 5% 5% 9% 9% 2% 2%

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Packet Pg. 573 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Single Family New Construction 34 References
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 6 References
Barbose, G., Darghouth, N., O'Shaughnessy, E., & Forrester, S. (2022, October). Tracking the Sun. Pricing and Design Trends for Distributed Photovoltaic Systems in the United States 2022 Edition. Retrieved from https://emp.lbl.gov/tracking-the-sun
California Energy Commission. (2017). Rooftop Solar PV System. Measure number: 2019-Res-PV-D Prepared by Energy and Environmental Economics, Inc. Retrieved from https://efiling.energy.ca.gov/getdocument.aspx?tn=221366 California Energy Commission. (2022a). 2022 Building Energy Efficiency Standards for Residential and Nonresidential Buildings. CEC-400-2022-010-CMF. Retrieved from https://www.energy.ca.gov/sites/default/files/2022- 12/CEC-400-2022-010_CMF.pdf
California Energy Commission. (2022b). 2022 Reference Appendices for the 202 Building Energy Efficiency Standards.

CEC-400-2022-010-AP. Retrieved from https://www.energy.ca.gov/sites/default/files/2022-08/CEC-400- 2022-010-AP.pdf
California Energy Commission. (2022c, Feb). 2022 Single-Family Residential Alternative Calculation Method Reference Manual. CEC-400-2022-008-CMF-REV. Retrieved from https://www.energy.ca.gov/publications/2022/2022- single-family-residential-alternative-calculation-method-reference-manual California Public Utilities Commission. (2021a). Utility Costs and Affordability of the Grid of the Future: An Evaluation of Electric Costs, Rates, and Equity Issues Pursuant to P.U. Code Section 913.1. Retrieved from https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/office-of-governmental-affairsdivision/reports/2021/senate-bill-695-report-2021-and-en-banc-whitepaper_final_04302021.pdf California Public Utilities Commission. (2021b). Database for Energy-Efficient resources (DEER2021 Update). Retrieved April 13, 2021, from http://www.deeresources.com/index.php/deer-versions/deer2021 California Public Utilities Commission. (2022). Proposed Decision Rulemaking 19-01-011: PHASE III DECISION ELIMINATING GAS LINE EXTENSION ALLOWANCES. Retrieved from https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M496/K876/496876177.PDF E-CFR. (2020). https://www.ecfr.gov/cgibin/retrieveECFR?gp=&SID=8de751f141aaa1c1c9833b36156faf67&mc=true&n=pt10.3.431&r=PART&ty=HTM L#se10.3.431_197. Retrieved from Electronic Code of Federal Regulations: https://www.ecfr.gov/cgibin/retrieveECFR?gp=&SID=8de751f141aaa1c1c9833b36156faf67&mc=true&n=pt10.3.431&r=PART&ty=HTM L#se10.3.431_197
Energy + Environmental Economics. (2020). Time Dependent Valuation of Energy for Developing Building Efficiency Standards: 2022 Time Dependent Valuation (TDV) and Source Energy Metric Data Sources and Inputs.

E-Source companies. (2020). Behind-the-Meter Battery Market Study. Prepared for San Diego Gas & Electric.

Retrieved from https://www.etcc-ca.com/reports/behind-meter-battery-market-study?dl=1582149166 Horii, B., Cutter, E., Kapur, N., Arent, J., & Conotyannis, D. (2014). Time Dependent Valuation of Energy for Developing Building Energy Efficiency Standards.

Statewide CASE Team. (2018). Energy Savings Potential and Cost-Effectiveness Analysis of High Efficiency Windows in California. Prepared by Frontier Energy. Retrieved from https://www.etcc-ca.com/reports/energy-savingspotential-and-cost-effectiveness-analysis-high-efficiency-windows-california Statewide CASE Team. (2020a). Nonresidential High Performance Envelope Codes and Standards Enhancement (CASE) Initiative 2022 California Energy Code. Prepared by Energy Solutions. Retrieved from https://title24stakeholders.com/wp-content/uploads/2020/10/2020-T24-NR-HP-Envelope-Final-CASEReport.pdf Statewide CASE Team. (2020b). Residential Energy Savings and Process Improvements for Additions and Alterations Codes and Standards Enhancement (CASE) Initiative 2022 California Energy Code. Prepared by Frontier

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Packet Pg. 574 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Single Family New Construction 35 References
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 Energy. Retrieved from https://title24stakeholders.com/wp-content/uploads/2020/08/SF-Additions-andAlterations_Final_-CASE-Report_Statewide-CASE-Team.pdf Statewide CASE Team. (2020c). Multifamily All-Electric Codes and Standards Enhancement (CASE) Initiative 2022 California Energy Code. Prepared by TRC.

Statewide Reach Codes Team. (2020). 2019 Mid-Rise New Construction Reach Code Cost-Effectiveness Study.

Prepared by Frontier Energy, Misti Bruceri & Associates, and EnergySoft. Retrieved from https://localenergycodes.com/download/492/file_path/fieldList/2019%20Mid-rise%20NC%20CostEff%20Report.pdf Statewide Reach Codes Team. (2021). 2019 Cost-Effectiveness Study: 2020 Analysis of High-Rise Residential New Construction. Prepared by Frontier Energy and Misti Bruceri & Associates. Retrieved from https://www.localenergycodes.com/download/737/file_path/fieldList/2019%20High-Rise%20NC-CostEff%20Report-2021-02-22.pdf Statewide Reach Codes Team. (2022a). 2022 Cost-Effectiveness Study: Single Family new Construction. Prepared by Frontier Energy and Misti Bruceri & Associates. Retrieved from California Energy Codes & Standards:
https://localenergycodes.com/content/resources
Statewide Reach Codes Team. (2022b). Nonresidential New Construction Reach Code Cost-effectiveness Study.

Prepared by Avani Goyal, Farhad Farahmand, TRC Companies. Retrieved from California Energy Codes & Standards: https://localenergycodes.com/content/resources TRC. (2018 ). 2019 Title 24 Energy Reach Code Cost-Effectiveness Analysis Draft. City of Palo Alto. Retrieved from https://cityofpaloalto.org/civicax/filebank/documents/66742 TRC. (2019). Multifamily Prototypes. Prepared for Southern California Edison. Retrieved from https://title24stakeholders.com/wp-content/uploads/2019/06/SCEMFModeling_MultifamilyPrototypesReport_2019-06-07_clean.pdf

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localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 7 Appendices

7.1 Map of California Climate Zones
Climate zone geographical boundaries are depicted in Figure 3. The map in Figure 3 along with a zip-code search directory is available at: https://ww2.energy.ca.gov/maps/renewable/building_climate_zones.html Figure 3. Map of California climate zones.

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7.2 Utility Rate Schedules
The Reach Codes Team used the CA IOU and POU rate tariffs detailed below to determine the On-Bill savings for each package. The California Climate Credit was applied for both electricity and natural gas service for the IOUs using the 2022 credits shows below.9 The credits were applied to reduce the total calculated annual bill, including any fixed fees or minimum bill amounts.

Electricity rates reflect the most recent approved tariffs. Monthly gas rates were estimated based on the latest available gas rate (December 2022) and a curve to reflect how natural gas prices fluctuate with seasonal supply and demand.

The seasonal curve was estimated from monthly residential tariffs between 2012 and 2022 (between 2020 and 2022 for CPAU). 12-month curves were created from monthly gas rates for each of the eleven years (three years for CPAU).

These annual curves were then averaged to arrive at an average normalized annual curve. This was conducted separately for baseline and excess energy rates. Costs used in this analysis were then derived by establishing the most recent baseline and excess rate from the latest tariff as a reference point (December 2022), and then using the normalized curve to estimate the cost for the remaining months relative to the reference point rate. 9 https://www.cpuc.ca.gov/industries-and-topics/natural-gas/greenhouse-gas-cap-and-trade-program/california-climatecredit

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7.2.1 Pacific Gas & Electric
The following pages provide details on the PG&E electricity and natural gas tariffs applied in this study. Error! Reference source not found. describes the baseline territories that were assumed for each climate zone. A net surplus compensation rate of $0.0474/ kWh was applied to any net annual electricity generation based on a one-year average of the rates between November 2021 and October 2022.

Table 23. PG&E Baseline Territory by Climate Zone
Climate
Zone
Baseline
Territory
CZ01 V
CZ02 X
CZ03 T
CZ04 X
CZ05 T
CZ11 R
CZ12 S
CZ13 R
CZ16 Y
The PG&E monthly gas rate in $/therm was applied on a monthly basis according to the rates shown in Error! Reference source not found.. These are applied to both the G-1 and GM rates. These rates are based on applying a normalization curve to the December 2022 tariff based on eleven years of historical gas data. See the beginning of Section Error! Reference source not found. Error! Reference source not found. for further details. The corresponding CARE rates are shown in Error! Reference source not found. and reflect the 20 percent discount per the GL-1 tariff. The GM master metered wather heating baseline quantity of 0.43 therms per dwelling unit per day in all baseline territories and in both seasons was applied to the centrally metered gas water heating.

Table 24. PG&E Monthly Gas Rate ($/therm)
Month Total Charge
Baseline Excess
January $2.20579 $2.66008
February $2.24291 $2.69637
March $2.11750 $2.58278
April $2.08101 $2.55500
May $2.08062 $2.55844
June $2.09104 $2.56928
July $2.10404 $2.58189
August $2.15162 $2.63251
September $2.18718 $2.67910
October $2.23153 $2.71934
November $2.32121 $2.79158
December $2.34123 $2.80922

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localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 Table 25. PG&E Monthly CARE (GL-1) Gas Rate ($/therm)
Month Total CARE Charge
Baseline Excess
January $1.76463 $2.12806
February $1.79433 $2.15710
March $1.69400 $2.06622
April $1.66480 $2.04400
May $1.66449 $2.04675
June $1.67283 $2.05543
July $1.68323 $2.06551
August $1.72129 $2.10601
September $1.74974 $2.14328
October $1.78523 $2.17547
November $1.85697 $2.23327
December $1.87298 $2.24738

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7.2.2 Southern California Edison
The following pages provide details on are the SCE electricity tariffs applied in this study. Error! Reference source not found. describes the baseline territories that were assumed for each climate zone. A net surplus compensation rate of $ 0.04361/ kWh was applied to any net annual electricity generation based on a one-year average of the rates between November 2021 and October 2022
Table 26: SCE Baseline Territory by Climate Zone
Climate
Zone
Baseline
Territory
CZ06 6
CZ08 8
CZ09 9
CZ10 10
CZ14 14
CZ15 15

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7.2.3 Southern California Gas
Following are the SoCalGas natural gas tariffs applied in this study. Error! Reference source not found. describes the baseline territories that were assumed for each climate zone.

Table 27. SoCalGas Baseline Territory by Climate Zone
Climate
Zone
Baseline
Territory
CZ05 2
CZ06 1
CZ08 1
CZ09 1
CZ10 1
CZ14 2
CZ15 1
The SoCalGas monthly gas rate in $/therm was applied on a monthly basis according to the rates shown in Error! Reference source not found.. These rates are based on applying a normalization curve to the December 2022 tariff based on eleven years of historical gas data. See the beginning of Section Error! Reference source not found.

Error! Reference source not found. for further details. Long-term historical natural gas rate data was only available for SoCalGas’ procurement charges.10 The baseline and excess transmission charges were found to be consistent over the course of a year and applied for the entire year based on 2022 rates. CARE rates reflect the 20 percent discount per the GR tariff.

Table 28. SoCalGas Monthly Gas Rate ($/therm)
Month Procurement
Charge
Transportation Charge Total Charge
Baseline Excess Baseline Excess
January $0.90581 $0.82487 $1.23877 $1.73068 $2.14458
February $0.83669 $0.82487 $1.23877 $1.66156 $1.84967
March $0.80596 $0.82487 $1.23877 $1.63083 $1.82938
April $0.71941 $0.82487 $1.23877 $1.54428 $1.75890
May $0.77049 $0.82487 $1.23877 $1.59536 $1.78548
June $0.86253 $0.82487 $1.23877 $1.68740 $1.83337
July $0.87687 $0.82487 $1.23877 $1.70174 $1.86833
August $0.95391 $0.82487 $1.23877 $1.77878 $1.91089
September $0.85896 $0.82487 $1.23877 $1.68383 $1.83611
October $0.84147 $0.82487 $1.23877 $1.66634 $1.84936
November $0.89018 $0.82487 $1.23877 $1.71505 $1.88836
December $1.05329 $0.82487 $1.23877 $1.87816 $1.98294
10 The SoCalGas procurement and transmission charges were obtained from the following site:
https://www.socalgas.com/for-your-business/energy-market-services/gas-prices

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7.2.4 San Diego Gas & Electric
Following are the SDG&E electricity and natural gas tariffs applied in this study. Error! Reference source not found. describes the baseline territories that were assumed for each climate zone. A net surplus compensation rate of $0.04174 / kWh was applied to any net annual electricity generation based on a one-year average of the rates between January 2022 and December 2022.

Table 29. SDG&E Baseline Territory by Climate Zone
Climate
Zone
Baseline
Territory
CZ07 Coastal
CZ10 Inland
CZ14 Mountain
The SDG&E monthly gas rate in $/therm was applied on a monthly basis according to the rates shown in Error! Reference source not found.. These rates are based on applying a normalization curve to the December 2022 tariff based on eleven years of historical gas data. See the beginning of Section Error! Reference source not found.

Error! Reference source not found. for further details. CARE rates reflect the 20 percent discount per the G-CARE tariff.

Table 30. SDG&E Monthly Gas Rate ($/therm)
Month Total Charge
Baseline Excess
January $2.33762 $2.34748
February $2.26751 $2.28440
March $2.25119 $2.27016
April $2.20192 $2.22744
May $2.24252 $2.26403
June $2.31819 $2.33060
July $2.32406 $2.33630
August $2.37527 $2.38090
September $2.33542 $2.34971
October $2.30366 $2.32151
November $2.31722 $2.33381
December $2.45653 $2.73517

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7.2.5 City of Palo Alto Utilities
Following are the CPAU electricity and natural gas tariffs applied in this study. The CPAU monthly gas rate in $/therm was applied on a monthly basis according to the rates shown in Error! Reference source not found.. These rates are based on applying a normalization curve to the December 2022 tariff based on three years of historical gas data. See the beginning of Section Error! Reference source not found. Error! Reference source not found. for further details. The monthly service charge applied was $106.90 per month per the December 2022 G-2 tariff.

Table 31. CPAU Monthly Gas Rate ($/therm)
Month G2
Volumetric
Totals
January $1.80964
February $1.67009
March $1.68480
April $1.68698
May $1.78478
June $1.88288
July $1.88355
August $2.06943
September $2.06798
October $2.08553
November $2.09681
December $2.45700

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7.2.6 Sacramento Municipal Utilities District (Electric Only) Following are the SMUD electricity tariffs applied in this study. The rates effective January 2023 were used.

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7.2.7 Fuel Escalation Assumptions
The average annual escalation rates in Error! Reference source not found. were used in this study. These are based on assumptions from the CPUC 2021 En Banc hearings on utility costs through 2030 (California Public Utilities Commission, 2021a). Escalation rates through the remainder of the 30-year evaluation period are based on the escalation rate assumptions within the 2022 TDV factors. No data was available to estimate electricity escalation rates for CPAU and SMUD, therefore electricity escalation rates for PG&E and statewide natural gas escalation rates were applied.

Table 32: Real Utility Rate Escalation Rate Assumptions Statewide Natural
Gas Residential
Average Rate
(%/year, real)
Electric Residential Average Rate
(%/year, real)

PG&E SCE SDG&E
2023 4.6% 1.8% 1.6% 2.8%
2024 4.6% 1.8% 1.6% 2.8%
2025 4.6% 1.8% 1.6% 2.8%
2026 4.6% 1.8% 1.6% 2.8%
2027 4.6% 1.8% 1.6% 2.8%
2028 4.6% 1.8% 1.6% 2.8%
2029 4.6% 1.8% 1.6% 2.8%
2030 4.6% 1.8% 1.6% 2.8%
2031 2.0% 0.6% 0.6% 0.6%
2032 2.4% 0.6% 0.6% 0.6%
2033 2.1% 0.6% 0.6% 0.6%
2034 1.9% 0.6% 0.6% 0.6%
2035 1.9% 0.6% 0.6% 0.6%
2036 1.8% 0.6% 0.6% 0.6%
2037 1.7% 0.6% 0.6% 0.6%
2038 1.6% 0.6% 0.6% 0.6%
2039 2.1% 0.6% 0.6% 0.6%
2040 1.6% 0.6% 0.6% 0.6%
2041 2.2% 0.6% 0.6% 0.6%
2042 2.2% 0.6% 0.6% 0.6%
2043 2.3% 0.6% 0.6% 0.6%
2044 2.4% 0.6% 0.6% 0.6%
2045 2.5% 0.6% 0.6% 0.6%
2046 1.5% 0.6% 0.6% 0.6%
2047 1.3% 0.6% 0.6% 0.6%
2048 1.6% 0.6% 0.6% 0.6%
2049 1.3% 0.6% 0.6% 0.6%
2050 1.5% 0.6% 0.6% 0.6%
2051 1.8% 0.6% 0.6% 0.6%
2052 1.8% 0.6% 0.6% 0.6%

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7.3 Cost Details
Table 33 presents additional detail on the first cost assumptions for the central water heating systems. For the 5-story prototype costs are provided both for a CO2 refrigerant Sanden-based and R-134a refrigerant Colmac-based heat pump water heater designs. The results presented in the main body of this report are based on the Sanden design. A sensitivity analysis was also conducted for a Colmac design (see Appendix 7.5 Central Heat Pump Water Heater Comparison) and the cost comparison is presented here. All costs are based on data from the 2022 Multifamily AllElectric CASE Report (Statewide CASE Team, 2020c).

Table 33. Heat Pump Water Heater First Costs per Building (Present Value (2023$)) Item
3-Story (36-units) 5-Story (88-units)
Gas
Boiler
(CZs 1-9)
Gas Boiler
(CZs 10-16)
Heat
Pump
Gas
Boiler
(CZs 1-9)
Gas Boiler
(CZs 10-16)
Heat
Pump
(Sanden)
Heat
Pump
(Colmac)
Water Heating
Equipment $87,602 $87,602 $140,907 $135,146 $135,146 $244,742 $319,485 Solar Thermal
Collector $39,800 $46,888 n/a $74,740 $91,776 n/a n/a
Gas Piping $8,890 $8,890 n/a $9,065 $9,065 n/a n/a
Electrical Circuits n/a n/a $25,000 n/a n/a $25,000 $25,000 Overhead & Markup $37,480 $39,430 $45,624 $60,212 $64,896 $74,179 $94,733 Total $173,772 $182,810 $211,531 $279,163 $300,883 $343,920 $439,218 Table 34 presents additional detail on the first cost assumptions for the space hating systems.

Table 34. Heat Pump Space Heater First Costs per Dwelling Unit (Present Value (2023$) Item
3-Story 5-Story
Furnace + Source & Notes
Split AC
Heat
Pump
Furnace +
Split HP
Heat
Pump
Dwelling Unit HVAC
$5,651 $5,460 $6,109 $5,460
Gas system costs based on 2022
Multifamily All-Electric CASE Report.

Heat pump costs based on online
equipment research indicating a 2-ton
HP is $191 less than a furnace/AC of
the same size.

Refrigerant Piping $563 $563 $423 $423
2022 Multifamily All-Electric CASE
Report. Gas Piping $92 $0 $227 $0
Electrical Circuits $0 $150 $0 $150
Labor
$9,904 $6,985 $9,904 $6,985
Based on the 2022 Multifamily AllElectric CASE Report with adjustments to align with updated
equipment costs.

Overhead & Markup $4,457 $3,618 $4,582 $3,579 Based on a 27% markup Total $20,667 $16,776 $21,245 $16,597
Incremental Cost ($3,891) ($4,647)

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7.4 PG&E Gas Infrastructure Cost Memo

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7.5 Central Heat Pump Water Heater Comparison
Table 35 presents energy and cost-effectiveness results for a R-134a refrigerant based system design using a Colmac central heat pump water heater in the 5- story prototype. This was only found to be cost-effective based on at least one of the two metrics in Climate Zones 1, 4 in CPAU territory, and 16.

Table 35. 5-Story Cost-Effectiveness: All-Electric Prescriptive Code with R-134a Heat Pump Water Heater Climate
Zone
Electric
/Gas Utility
Efficiency
TDV
Comp
Margin
Source
Comp
Margin
Annual
Elec
Savings
(kWh)
Annual
Gas
Savings
(therms)
Utility Cost
Savings Incremental Cost On-Bill TDV
First
Year
Lifecycle
(2022$)
First
Year
Lifecycle
(2022$)
B/C
Ratio NPV B/C Ratio NPV
CZ01 PGE 6% 6% -1,496 147 ($155) ($1,240) ($3,556) ($4,223) 3.4 $2,984 >1 $5,870 CZ02 PGE 4% 2% -1,197 120 ($145) ($1,513) $1,691 $2,749 0.0 ($4,262) 0.5 ($1,287) CZ03 PGE 6% 3% -1,166 120 ($138) ($1,360) $1,691 $2,749 0.0 ($4,109) 0.8 ($523) CZ04 PGE 4% 2% -1,116 113 ($76) ($49) $1,691 $2,749 0.0 ($2,798) 0.7 ($949) CZ04 CPAU 4% 2% -1,116 113 $185 $7,144 $1,718 $2,776 2.6 $4,368 0.6 ($976) CZ05 PGE 5% 2% -1,161 117 ($137) ($1,391) $1,691 $2,749 0.0 ($4,140) 0.5 ($1,412) CZ05 PGE/SCG 5% 2% -1,161 117 ($189) ($3,016) $1,691 $2,749 0.0 ($5,765) 0.5 ($1,412) CZ06 SCE/SCG 4% 1% -1,000 104 ($92) ($879) $1,691 $2,749 0.0 ($3,628) 0.6 ($1,013) CZ07 SDGE 5% 2% -996 106 ($183) ($3,216) $1,691 $2,749 0.0 ($5,965) 0.7 ($936) CZ08 SCE/SCG 3% 1% -948 100 ($156) ($2,413) $1,691 $2,749 0.0 ($5,162) 0.7 ($695) CZ09 SCE 3% 0% -966 100 ($132) ($1,863) $1,691 $2,749 0.0 ($4,612) 0.7 ($738) CZ10 SCE/SCG 3% 1% -962 84 ($188) ($3,375) $1,444 $2,395 0.0 ($5,770) 0.3 ($1,596) CZ10 SDGE 3% 1% -962 84 ($239) ($4,959) $1,444 $2,395 0.0 ($7,354) 0.3 ($1,596) CZ11 PGE 4% 3% -1,029 92 ($165) ($2,487) $1,444 $2,395 0.0 ($4,882) 0.4 ($1,367) CZ12 PGE 4% 3% -1,081 96 ($172) ($2,591) $1,444 $2,395 0.0 ($4,986) 0.3 ($1,667) CZ12 SMUD/PGE 4% 3% -1,081 96 $26 $1,988 $1,444 $2,395 0.8 ($407) 0.3 ($1,667) CZ13 PGE 3% 2% -976 88 ($156) ($2,361) $1,444 $2,395 0.0 ($4,756) 0.4 ($1,452) CZ14 SCE/SCG 2% -1% -1,045 84 ($210) ($3,880) $1,444 $2,395 0.0 ($6,275) 0.1 ($2,056) CZ14 SDGE 2% -1% -1,045 84 ($270) ($5,725) $1,444 $2,395 0.0 ($8,120) 0.1 ($2,056) CZ15 SCE/SCG 2% -1% -718 65 ($146) ($2,713) $1,444 $2,395 0.0 ($5,108) 0.3 ($1,564) CZ16 PG&E -5% 6% -1,913 142 ($276) ($4,142) ($3,803) ($4,577) 1.1 $435 1.2 $746

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7.6 Summary of Measures by Package
Table 36 provides the details of the measures in each of the efficiency package by climate zone. The measures are the same for the 3-story and 5-story prototypes. Table 37 presents the PV capacities per dwelling unit in the upgrade packages. In Climate Zone 6 for the mixed fuel case in the 5-story prototype there is no upgrade to the PV system capacity as the prescriptive PV system already offset all of the estimated electricity use.

Table 36. Mixed Fuel Efficiency Package Measures
Climate
Zone

0.70 Roof
Solar
Reflectance

0.24 U-Factor
Windows

0.35 W/cfm
Verified Low
Leakage Ducts in
Conditioned
Space
1 X X
2 X
3 X
4 X
5 X
6 X
7 X
8 X
9 X X
10 X X X
11 X X X
12 X X X
13 X X X
14 X X X
15 X X X
16 X X X

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localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-06-20 Table 37. Upgrade Package PV Capacities (kW-DC)
Climate
Zone
All-Electric + PV Mixed Fuel + PV
3-Story 5-Story 3-Story 5-Story
CZ01 4.41 4.35 3.69 3.43
CZ02 3.56 3.58 3.02 2.98
CZ03 3.31 3.29 2.80 2.72
CZ04 3.21 3.27 2.73 2.75
CZ05 3.04 3.08 2.57 2.55
CZ06 2.91 3.04 2.49 2.68
CZ07 3.09 3.21 2.64 2.74
CZ08 3.18 3.30 2.76 2.86
CZ09 3.04 3.16 2.63 2.73
CZ10 3.20 3.30 2.79 2.86
CZ11 3.90 3.95 3.42 3.43
CZ12 3.53 3.60 3.05 3.08
CZ13 3.77 3.84 3.32 3.36
CZ14 3.20 3.23 2.79 2.79
CZ15 3.93 3.94 3.58 3.58
CZ16 3.79 3.76 2.60 2.90

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Packet Pg. 605 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code

Prepared by:

Alea German, Claudia Pingatore, Ada Shen, & Keith Saechao, Frontier Energy, Inc Misti Bruceri, Misti Bruceri & Associates, LLC
Prepared for:

Kelly Cunningham, Codes and Standards Program, Pacific Gas and Electric Last modified: 2024/03/25
Revision: 1.1

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-Effectiveness Analysis: Single Family New Construction Legal Notice
This report was prepared by Pacific Gas and Electric Company and funded by the California utility customers under the auspices of the California Public Utilities Commission.

Neither PG&E nor any of its employees makes any warranty, express or implied; or assumes any legal liability or responsibility for the accuracy, completeness or usefulness of any data, information, method, product, policy or process disclosed in this document; or represents that its use will not infringe any privately- owned rights including, but not limited to, patents, trademarks or copyrights.

Acronym List
2023 PV$– Present value costs in 2023
ACH50– Air Changes per Hour at 50 pascals pressure
differential
ACM– Alternative Calculation Method
ADU – Accessory Dwelling Unit
AFUE– Annual Fuel Utilization Efficiency
B/C– Lifecycle Benefit-to-Cost Ratio
BEopt– Building Energy Optimization Tool
BSC– Building Standards Commission
CA IOUs – California Investor-Owned Utilities
CASE – Codes and Standards Enhancement
CBECC-Res– Computer program developed by the California Energy Commission for use in demonstrating
compliance with the California Residential Building
Energy Efficiency Standards
CFI– California Flexible Installation
CFM– Cubic Feet per Minute
CO
2 – Carbon Dioxide
CPAU – City of Palo Alto Utilities
CPUC – California Public Utilities Commission
CZ– California Climate Zone
DHW– Domestic Hot Water
DOE– Department of Energy
DWHR– Drain Water Heat Recovery
EDR– Energy Design Rating
EER– Energy Efficiency Ratio
EF– Energy Factor

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-Effectiveness Analysis: Single Family New Construction GHG– Greenhouse Gas
HERS Rater– Home Energy Rating System Rater
HPA– High Performance Attic
HPWH– Heat Pump Water Heater
HSPF– Heating Seasonal Performance Factor
IECC– International Energy Conservation Code
IOU– Investor Owned Utility
kBtu– kilo-British thermal unit
kWh–Kilowatt Hour
LBNL– Lawrence Berkeley National Laboratory
LCC– Lifecycle Cost
LLAHU – Low Leakage Air Handler Unit
LSC – Long-term System Cost (2025 Title 24, Part 6 compliance metric) MF–Multifamily
NEEA– Northwest Energy Efficiency Alliance
NEM– Net Energy Metering
NPV– Net Present Value
NREL– National Renewable Energy Laboratory
PG&E– Pacific Gas and Electric Company
POU – Publicly-Owned-Utilities
PV– Photovoltaic
SCE– Southern California Edison
SDG&E– San Diego Gas and Electric
SEER– Seasonal Energy Efficiency Ratio
SF– Single Family
SMUD – Sacramento Municipal Utility District
SoCalGas – Southern California Gas Company
TDV– Time Dependent Valuation (2022 Title 24, Part 6 compliance metric) Therm– Unit for quantity of heat that equals 100,000 British thermal units Title 24– Title 24, Part 6
TOU– Time-Of-Use
UEF– Uniform Energy Factor
VLLDCS– Verified Low Leakage Ducts in Conditioned Space ZNE– Zero-net Energy

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Packet Pg. 608 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Single Family New Construction Summary of Revisions
Date Description Reference (page or section)
9/12/2022 Original Release (1.0) N/A
3/25/2024 Updated analysis (1.1) • New simulation results with latest CBECC-Res version (Section 2.1.1)
• Updated utility cost estimates using
recent utility tariff and net billing
tariff (Section 2.1.3)
• New measure costs for heat pumps,
batteries, and PV (Section 3.3)
• Revised packages (Section 3.4)
• Revised Results, Summary,
References, and Appendices
(Sections 4-7)

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2.1 Analysis for Reach Codes..................................................................................................................................................... 5

2.1.1 Modeling ....................................................................................................................................................................... 5

2.1.2 Cost-effectiveness ........................................................................................................................................................ 5

2.1.3 Utility Rates................................................................................................................................................................... 7

2.2 Greenhouse Gas Emissions ................................................................................................................................................. 8

2.3 Energy Design Rating........................................................................................................................................................... 8 3 Prototypes, Measure Packages, and Costs............................................................................................................9

3.1 Prior Reach Code Research ................................................................................................................................................. 9

3.2 Prototype Characteristics...................................................................................................................................................... 9

3.3 Measure Definitions and Costs ........................................................................................................................................... 12

3.3.1 Efficiency, Solar PV, and Batteries ............................................................................................................................. 12

3.3.2 Electrification............................................................................................................................................................... 17

3.4 Measure Packages ............................................................................................................................................................. 22 4 Results......................................................................................................................................................................24

4.1 Compliance Results: All-Electric vs. Mixed Fuel Code Minimum ........................................................................................ 24

4.2 All-Electric Code Minimum Results ..................................................................................................................................... 26

4.3 All-Electric Efficiency, PV, and Battery Results................................................................................................................... 29

4.4 Mixed Fuel Results ............................................................................................................................................................. 31

4.5 Greenhouse Gas Reductions.............................................................................................................................................. 33

4.6 Sensitivity Analysis ............................................................................................................................................................. 35

4.6.1 CARE Rate Comparison ............................................................................................................................................. 36

4.6.2 Utility Infrastructure Cost Sensitivity............................................................................................................................ 38

4.6.3 Utility Rate Escalation................................................................................................................................................. 39 5 Summary ..................................................................................................................................................................42 6 References ...............................................................................................................................................................46 7 Appendices ..............................................................................................................................................................48

7.1 Map of California Climate Zones......................................................................................................................................... 48

7.2 Utility Rate Schedules......................................................................................................................................................... 49

7.2.1 Pacific Gas & Electric.................................................................................................................................................. 50

7.2.2 Southern California Edison ......................................................................................................................................... 57

7.2.3 Southern California Gas.............................................................................................................................................. 61

7.2.4 San Diego Gas & Electric............................................................................................................................................ 62

7.2.5 City of Palo Alto Utilities.............................................................................................................................................. 68

7.2.6 Sacramento Municipal Utilities District (Electric Only)................................................................................................. 70

7.2.7 Fuel Escalation Assumptions...................................................................................................................................... 72

7.3 Summary of Efficiency Measures........................................................................................................................................ 74

7.4 Summary of Applicable Prescriptive Base case Measures ................................................................................................. 76

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LIST OF TABLES
Table 1: Utility Tariffs Used Based on Climate Zone ............................................................................................................................ 7 Table 2: Prototype Characteristics........................................................................................................................................................ 9 Table 3: Base case Characteristics of the Prototypes ........................................................................................................................ 11 Table 4: Base Package PV Capacities (kW-DC) ................................................................................................................................ 12 Table 5: Incremental Cost Assumptions: Efficiency, PV, and Battery Measures ................................................................................ 14 Table 6: Single Family IOU Total Natural Gas Infrastructure Costs.................................................................................................... 17 Table 7: Single Family CPAU Total Natural Gas Infrastructure Costs ................................................................................................ 18 Table 8: ADU Utility Infrastructure Total and Incremental Costs......................................................................................................... 18 Table 9: Effective Useful Lifetime (EUL) of Water Heating & Space Conditioning Equipment............................................................ 19 Table 10: Space Conditioning System Nominal Capacities ................................................................................................................ 20 Table 11: Space Conditioning System Incremental Costs (2023 PV$)............................................................................................... 20 Table 12: Heat Pump Water Heating System Incremental Costs (2023 PV$) .................................................................................... 21 Table 13: Single Family All-Electric Appliance Incremental Costs ...................................................................................................... 22 Table 14: Single Family Cost-Effectiveness: All-Electric Code Minimum............................................................................................ 27 Table 15: ADU Cost-Effectiveness: All-Electric Code Minimum.......................................................................................................... 28 Table 16: Single Family Cost-Effectiveness: Comparison of All-Electric Efficiency Only, PV, and Battery Packages ........................ 29 Table 17: ADU Cost-Effectiveness: All-Electric Energy Efficiency + Additional PV + Battery ............................................................. 30 Table 18: Single Family Cost-Effectiveness: Mixed Fuel Efficiency + PV + Battery............................................................................ 31 Table 19: ADU Cost-Effectiveness: Mixed Fuel Efficiency + PV + Battery ......................................................................................... 32 Table 20: Single Family Greenhouse Gas Reductions (metric tons) .................................................................................................. 33 Table 21: ADU Greenhouse Gas Reductions (metric tons) ................................................................................................................ 34 Table 22: On-Bill Cost-Effectiveness with CARE Tariffs: All-Electric Code Minimum ......................................................................... 36 Table 23: On-Bill Cost-Effectiveness with CARE Tariffs: Mixed Fuel Efficiency + PV+ Battery Package ........................................... 37 Table 24: Single Family Cost-Effectiveness Comparison with Range of Natural Gas Utility Infrastructure Costs: All-Electric Code Minimum........................................................................................................................................................................................ 38 Table 25: Cost-Effectiveness, 2025 LSC Basis: All-Electric Code Minimum ...................................................................................... 40 Table 26: Cost-Effectiveness, 2025 LSC Basis: Mixed Fuel Efficiency + PV + Battery ...................................................................... 41 Table 27: Summary of Single Family EDR1 Margins and Cost-Effectiveness .................................................................................... 44 Table 28: Summary of ADU EDR1 Margins and Cost-Effectiveness .................................................................................................. 45 Table 29: PG&E Baseline Territory by Climate Zone.......................................................................................................................... 50 Table 30: PG&E Monthly Gas Rate ($/therm)..................................................................................................................................... 50 Table 31: SCE Baseline Territory by Climate Zone ............................................................................................................................ 57 Table 32: SoCalGas Baseline Territory by Climate Zone ................................................................................................................... 61 Table 33: SoCalGas Monthly Gas Rate ($/therm) .............................................................................................................................. 61 Table 34: SDG&E Baseline Territory by Climate Zone ....................................................................................................................... 62

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Packet Pg. 611 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Single Family New Construction Table 35: SDG&E Monthly Gas Rate ($/therm).................................................................................................................................. 62 Table 36: CPAU Monthly Gas Rate ($/therm)..................................................................................................................................... 68 Table 37: Real Utility Rate Escalation Rate Assumptions, CPUC En Banc and 2022 TDV Basis ...................................................... 72 Table 38: Real Utility Rate Escalation Rate Assumptions, 2025 LSC Basis ....................................................................................... 73 Table 39: All-Electric Single Family Efficiency Measures, Various Packages..................................................................................... 74 Table 40: Mixed Fuel Single Family Measures, Efficiency + PV + Battery Package........................................................................... 75 Table 41: Efficiency Measures for All ADU Packages ........................................................................................................................ 75 Table 42 Prescriptive Envelope, PV, and Battery Measures by Climate Zone.................................................................................... 77 Table 43 Prescriptive HVAC Measures by Climate Zone ................................................................................................................... 78 Table 44 Prescriptive Water Heating Measures by Climate Zone....................................................................................................... 78

LIST OF FIGURES
Figure 1: Single family all-electric home compliance impacts............................................................................................................. 24 Figure 2: ADU all-electric home compliance impacts.......................................................................................................................... 25 Figure 3: Single family four gas appliance home compliance impacts................................................................................................ 25 Figure 4: Map of California climate zones........................................................................................................................................... 48

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Packet Pg. 612 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Single Family New Construction Executive Summary
1 California Energy Codes & Standards | A statewide utility program 2024-03-25 Executive Summary
The California Codes and Standards (C&S) Reach Codes program provides technical support to local governments considering adopting a local ordinance (reach code) intended to support meeting local and/or statewide energy efficiency and greenhouse gas (GHG) reduction goals. The program facilitates adoption and implementation of the code when requested by local jurisdictions by providing resources such as cost-effectiveness studies, model language, sample findings, and other supporting documentation.

This report documents cost-effectiveness analysis results for traditional new detached single family and detached accessory dwelling unit (ADUs) building types. It evaluates mixed fuel and all-electric package options in all sixteen California climate zones (CZs). Packages include combinations of efficiency measures, on-site renewable energy, and battery energy storage.

This analysis used two different metrics to assess the cost-effectiveness of the proposed upgrades. Both methodologies require estimating and quantifying the incremental costs and energy savings associated with each energy efficiency measure over a 30-year analysis period. On-Bill cost-effectiveness is a customer-based lifecycle cost (LCC) approach that values energy based upon estimated site energy usage and customer utility bill savings using today’s electricity and natural gas utility tariffs. Time Dependent Valuation (TDV) is the California Energy Commission’s LCC methodology, which is intended to capture the long-term projected cost of energy, including costs for providing energy during peak periods of demand, carbon emissions, grid transmission and distribution impacts. This is the methodology used by the Energy Commission in evaluating cost-effectiveness for efficiency measures in Title 24, Part 6.

The following are key takeaways and recommendations from the analysis.

Conclusions and Discussion:
• All-electric buildings have lower GHG emissions than mixed fuel buildings, due to the clean power sources currently available from California’s power providers as well as accounting for increased penetration of renewables in the future. Almost all the all-electric packages evaluated resulted in greater GHG emission savings than the mixed fuel packages, with the exception of the mixed fuel package with battery storage in climate zones with low heating loads.
• The Reach Codes Team found code-compliant all-electric new construction to be feasible and cost-effective based on TDV for single family homes in all cases except Climate Zone 16. • All-electric single family new construction was On-Bill cost-effective in all cases except Climate Zones 1, 3, 14, and 16.
• The all-electric ADU home was cost-effective based on TDV in all cases except in Climate Zones 3, 4, 13, and 14 where the higher cost of installing a ducted heat pump water heater (HPWH) instead of the prescriptively required gas tankless water heater exceed the resulting energy cost savings. In the other climate zones there were first cost savings for installing a heat pump space heater instead of a gas furnace, contributing to an overall TDV cost-effective result.
• Few cases were cost-effective On-Bill for the ADU.
• All-electric code minimum construction results in an increase in first year utility costs relative to a mixed fuel home, except for CPAU and SMUD where electricity rates are much lower than for the investor-owned utilities (IOUs). The addition of efficiency measures, market dominant HPWHs that meet the Northwest Energy Efficiency Alliance’s (NEEA’s) Advanced Water Heating Specification1, high efficiency heat pumps, increased solar photovoltaics (PV), and batteries all reduce utility costs, and a combination of these options was found to reduce annual utility costs relative to a mixed fuel home in all cases. 1 Refer to Section 0 for an explanation of HPWHs certified through NEEA’s Advanced Water Heating Specification, their market status, and how they compare to federal minimum efficiency standards.

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2 California Energy Codes & Standards | A statewide utility program 2024-03-25 • Under the Net Biling Tariff (NBT)2, utility cost savings for increasing PV system size beyond code minimum are substantially less than what they were under prior net energy metering rules (NEM 2.0); however, savings are sufficient to be On-Bill cost-effective in all climate zones for the all-electric single family home. Coupling PV with battery systems increases utility cost savings as a result of improved on-site utilization of PV generation and fewer exports to the grid.
• Applying California Alternate Rates for Energy (CARE) rates in the IOU territories improves On-Bill costeffectiveness for all-electric buildings, as compared to the same case under standard rates, due to higher utility cost savings compared to a code compliant mixed fuel building also on a CARE rate. This is due to the CARE discount on electricity being higher than that on gas.
• If gas tariffs are assumed to increase substantially over time, in line with the escalation assumption from the 2025 LSC development, all-electric new construction was found to be On-Bill cost-effective in almost all scenarios over the 30-year analysis period. There is much uncertainty surrounding future tariff structures as well as escalation values. While it’s clear that gas rates are anticipated to increase, how much and how quickly is not known. Electricity tariff structures are expected to evolve over time, and the California Public Utilities Commission (CPUC) has an active proceeding to adopt an income-graduated fixed charge that benefits lowincome customers and supports electrification measures3. The CPUC will make a decision in mid-2024 and the new rates are expected to be in place later that year or in 2025. While the anticipated impact of this rate change is lower volumetric electricity rates, the rate design is not finalized. While lower volumetric electricity rates provide many benefits like incentivizing electrification, it also will make building efficiency measures harder to justify as cost-effective due to lower utility bill cost savings.

Recommendations:
• A reach code with a single performance target based on source energy (EDR1) can be structured to strongly encourage electrification. This approach requires equivalent performance for all buildings and allows mixed fuel buildings which minimizes the risk of violating federal preemption. Below are examples of how a reach code for single family homes could be set up based on the results summarized in Table 27. o A jurisdiction in Climate Zone 12 could set a performance target at an EDR1 margin of 11.5 (the EDR1 margin for the all-electric Code Minimum package). Any all-electric home meeting or exceeding the prescriptive requirements would comply, and a mixed fuel home would likely need to incorporate a combination of efficiency measures and a battery system to comply. o Similarly, a jurisdiction in Climate Zone 7 may consider setting a performance target of 2.8 EDR1 margin (also the EDR1 margin for the all-electric Code Minimum package). Any all-electric home meeting or exceeding the prescriptive requirements would comply, but a mixed fuel home would likely be able to comply with only a suite of above-code efficiency measures (no battery). Alternatively, a higher EDR1 margin target of 5 would incentivize more energy efficiency or additional PV for allelectric construction, and mixed fuel construction would likely need to incorporate a battery system to comply.
o A jurisdiction in Climate Zone 16 may want to set a performance target at an EDR1 margin of 20.5 (the EDR1 margin for the mixed fuel efficiency + PV + battery package). This would establish a target that a mixed fuel home could cost-effectively meet, likely only after incorporating a combination of efficiency measures and a battery system, and that an all-electric home could easily meet. • The 2022 Title 24 code’s new source energy metric combined with the heat pump baseline encourage allelectric construction, providing an incentive that allows for some amount of prescriptively required building efficiency to be traded off, still meeting minimum code compliance. This compliance benefit for all-electric homes highlights a unique opportunity for jurisdictions to incorporate efficiency into all-electric reach codes.

Efficiency and electrification have symbiotic benefits and are both critical for decarbonization of buildings. As demand on the electric grid is increased through electrification, efficiency can reduce the negative impacts of 2 Refer to Section 2.1.3 for discussion on NBT and NEM
3 https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/electric-costs/demand-response-dr/demand-flexibility-rulemaking

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3 California Energy Codes & Standards | A statewide utility program 2024-03-25 additional electricity demand on the grid, reducing the need for increased generation and storage capacity, as well as the need to upgrade upstream transmission and distribution equipment. The Reach Codes Team recommends that jurisdictions adopting a reach code for single family buildings also include an efficiency requirement with EDR1 margins at minimum consistent with the all-electric code minimum package results in Table 27.
• The code compliance margins for the ADU all-electric code minimum package are lower than for the single family prototype; code compliance and cost-effectiveness can be more challenging for smaller dwelling units.

As a result, the Reach Codes Team does not recommend EDR1 targets above those reported for the allelectric Code Minimum package in Table 28.

This report presents measures or measure packages that local jurisdictions may consider adopting to achieve energy savings and emissions reductions beyond what will be accomplished by enforcing minimum state requirements, the 2022 Building Energy Efficiency Standards (Title 24, Part 6), effective January 1, 2023.

Local jurisdictions may also adopt ordinances that amend different Parts of the California Building Standards Code or may elect to amend other state or municipal codes. The decision regarding which code to amend will determine the specific requirements that must be followed for an ordinance to be legally enforceable. For example, jurisdictions may amend Part 11 instead of Part 6 of the CA Building Code requiring review and approval by the Building Standards Commission (BSC) but not the California Energy Commission (Energy Commission). Reach codes that amend Part 6 of the CA Building Code and require energy performance beyond state code minimums must demonstrate the proposed changes are cost-effective and obtain approval from the Energy Commission. Although a cost-effectiveness study is only required to amend Part 6 of the CA Building Code, this study provides valuable context for jurisdictions pursuing other ordinance paths to understand the economic impacts of any policy decision. This study documents the estimated costs, benefits, energy impacts and greenhouse gas emission reductions that may result from implementing an ordinance based on the results to help residents, local leadership, and other stakeholders make informed policy decisions.

Model ordinance language and other resources are posted on the C&S Reach Codes Program website at LocalEnergyCodes.com. Local jurisdictions that are considering adopting an ordinance may contact the program for further technical support at [email protected]. In addition, jurisdictions in a CCA territory with rates or rate structures that are significantly different than IOU rates may email the program at [email protected] to request a custom analysis.

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4 California Energy Codes & Standards | A statewide utility program 2024-03-25 1 Introduction
This report documents cost-effective combinations of measures that exceed the minimum state requirements, the 2022 Building Energy Efficiency Standards, effective January 1, 2023, for newly constructed single family buildings. This report was developed in coordination with the California Statewide Investor-Owned Utilities (CA IOUs) Codes and Standards Program, key consultants, and engaged cities—collectively known as the Reach Codes Team.

The analysis considers traditional detached single family and detached accessory dwelling unit (ADUs) building types and evaluates mixed fuel and all-electric package options in all sixteen California climate zones (CZs).4 Packages include combinations of efficiency measures, on-site renewable energy, and battery energy storage.

This report documents the key results and conclusions from the Reach Codes Team analysis. A full dataset of all results can be downloaded from the Local Energy Codes Resources5 webpage. Results alongside policy options and the potential citywide impacts for specific jurisdictions can also be explored using the Cost-effectiveness Explorer at https://explorer.localenergycodes.com/.

The California Building Energy Efficiency Standards Title 24, Part 6 (Title 24) (California Energy Commission, 2021a) is maintained and updated every three years by two state agencies: the California Energy Commission (Energy Commission) and the Building Standards Commission (BSC). In addition to enforcing the code, local jurisdictions have the authority to adopt local energy efficiency ordinances—or reach codes—that exceed the minimum standards defined by Title 24 (as established by Public Resources Code Section 25402.1(h)2 and Section 10-106 of the Building Energy Efficiency Standards). Local jurisdictions must demonstrate that the requirements of the proposed ordinance are costeffective and do not result in buildings consuming more energy than is permitted by Title 24. In addition, the jurisdiction must obtain approval from the Energy Commission and file the ordinance with the BSC for the ordinance to be legally enforceable.

High efficiency appliances are often the easiest and most affordable measures to increase energy performance. While federal preemption limits reach code mandatory requirements for covered appliances, in practice, builders may install any package of compliant measures to achieve the performance requirements. 4 See Appendix 7.1 Map of California Climate Zones for a graphical depiction of climate zone locations. 5 https://localenergycodes.com/content/resources/?q=newly%20constructed%20buildings:%20efficiency%20and%20electrification

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5 California Energy Codes & Standards | A statewide utility program 2024-03-25 2 Methodology and Assumptions

2.1 Analysis for Reach Codes
This section describes the approach to calculating cost-effectiveness including benefits, costs, metrics, and utility rate selection.

2.1.1 Modeling
The Reach Codes Team performed energy simulations using software approved for 2022 Title 24 Code compliance analysis, CBECC-Res 2022.3.0.

The general approach applied in this analysis is to evaluate performance and determine cost-effectiveness of various energy efficiency upgrade measures, individually and as packages, in single family buildings. Using the 2022 baseline as the starting point, prospective measures and packages were identified and modeled in each of the prototypes to determine the projected energy use (therm and kWh) and compliance impacts. A large set of parametric runs were conducted to evaluate various options and develop packages of measures that met or exceeded minimum code performance. The analysis utilized a Python based parametric tool to automate and manage the generation of CBECCRes input files. This allowed for quick evaluation of various efficiency measures across multiple climate zones and prototypes and improved quality control. The batch process functionality of CBECC-Res was utilized to simulate large groups of input files at once.

2.1.2 Cost-effectiveness

2.1.2.1 Benefits
This analysis used two different metrics to assess cost-effectiveness of the proposed upgrades. Both methodologies require estimating and quantifying the incremental costs and energy savings associated with each energy efficiency measure. The main difference between the methodologies is the manner in which they value energy and thus the cost savings of reduced or avoided energy use:

Utility Bill Impacts (On-Bill): Customer-based lifecycle cost (LCC) approach that values energy based upon estimated site energy usage and customer utility bill savings using today’s electricity and natural gas utility tariffs. Total savings are estimated over a 30-year duration and include discounting of future costs and energy cost inflation.

Time Dependent Valuation (TDV): Energy Commission LCC methodology, which is intended to capture the total value or cost of energy use over 30 years. This method accounts for long-term projected costs, such as the cost of providing energy during peak periods of demand, and other societal costs, such as projected costs for carbon emissions as well as grid transmission and distribution impacts. This metric values energy use differently depending on the fuel source (natural gas, electricity, and propane), time of day, and season. For example, electricity used (or saved) during peak periods has a much higher value than electricity used (or saved) during off-peak periods due to the less inefficient energy generation sources providing peak electricity (Horii, Cutter, Kapur, Arent, & Conotyannis, 2014). This is the methodology used by the Energy Commission in evaluating cost-effectiveness for efficiency measures in Title 24, Part 6.

2.1.2.2 Costs
The Reach Codes Team assessed the incremental costs of the measures and packages over a 30-year lifecycle.

Incremental costs represent the equipment, installation, replacement, and maintenance costs of the proposed measure relative to the 2022 Title 24 Standards minimum requirements or standard industry practices. Present value of replacement cost is included only for measures with lifetimes less than the 30-year evaluation period.

In calculating On-Bill cost-effectiveness, incremental first costs were assumed to be financed into a mortgage or loan with a 30-year loan term and four percent interest rate. Financing was not applied to future replacement or maintenance costs. In calculating TDV cost-effectiveness, incremental first costs were not assumed to be financed into a mortgage or loan.

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6 California Energy Codes & Standards | A statewide utility program 2024-03-25

2.1.2.3 Metrics
Cost-effectiveness is presented using net present value (NPV) and benefit-to-cost (B/C) ratio metrics.

NPV Savings: The lifetime NPV savings is reported as a cost-effectiveness metric; Equation 1 demonstrates how this is calculated. If the net savings of a measure or package is positive, it is considered cost-effective. Negative savings represent net costs.

B/C Ratio: Ratio of the present value of all benefits to the present value of all costs over 30 years (present value of benefits divided by present value of costs). The criteria benchmark for cost-effectiveness is a B/C ratio greater than one. A value of one indicates the present value of the savings over the analysis period is equivalent to the present value of the lifetime incremental cost of that measure. A value greater than one represents a positive return on investment. The B/C ratio is calculated according to Equation 2.

Equation 1
𝑁𝑁𝑁𝑁𝑁𝑁 𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆 = 𝑃𝑃𝑃𝑃 𝑃𝑃 𝑃𝑃 𝑣𝑣𝑣𝑣 𝑜𝑜𝑜𝑜 𝑙𝑙 𝑏𝑏 − 𝑃𝑃𝑃𝑃 𝑃𝑃 𝑃𝑃 𝑣𝑣𝑣𝑣 𝑜𝑜𝑜𝑜 𝑙𝑙 𝑐𝑐 Equation 2
𝐵𝐵 − − 𝐶𝐶 𝑅𝑅 = 𝑃𝑃𝑃𝑃 𝑃𝑃 𝑃𝑃 𝑣𝑣𝑣𝑣 𝑜𝑜𝑜𝑜 𝑙𝑙 𝑏𝑏
𝑃𝑃𝑃𝑃 𝑃𝑃 𝑃𝑃 𝑣𝑣𝑣𝑣 𝑜𝑜𝑜𝑜 𝑙𝑙 𝑐𝑐
Improving the efficiency of a project often requires an initial incremental investment. In most cases the benefit is represented by annual On-Bill utility or TDV savings, and the cost is represented by incremental first cost and replacement costs. However, some packages result in initial construction cost savings (negative incremental cost), and either energy cost savings (positive benefits), or increased energy costs (negative benefits). In cases where both construction costs and energy-related savings are negative, the construction cost savings are treated as the ‘benefit’ while the increased energy costs are the ‘cost.’ In cases where a measure or package is cost-effective immediately (i.e., upfront construction cost savings and lifetime energy cost savings), B/C ratio cost-effectiveness is represented by “>1”.

The lifetime costs or benefits are calculated according to Equation 3.

Equation 3
𝑜𝑜𝑜𝑜 𝑙𝑙 𝑐𝑐 𝑜𝑜 𝑏𝑏 = �(𝐴𝐴 𝑐𝑐 𝑜𝑜 𝑏𝑏 )𝑡𝑡
(1 + )𝑡𝑡
𝑛𝑛
𝑡𝑡=0
Where: n = analysis term in years
• r = discount rate
The following summarizes the assumptions applied in this analysis to both methodologies. • Analysis term of 30 years
• Real discount rate of three percent
TDV is a normalized monetary format and there is a unique procedure for calculating the present value benefit of TDV energy savings. The present value of the energy cost savings in dollars is calculated by multiplying the TDV savings (reported by the CBECC-Res simulation software) by a NPV factor developed by the Energy Commission (see (Energy + Environmental Economics, 2020)). The 30-year residential NPV factor is $0.173/kTDV kBtu for the 2022 code cycle.

Equation 4
• 𝑇𝑇𝑇𝑇 𝑜𝑜𝑜𝑜 𝑙𝑙 𝑏𝑏 = 𝑇𝑇𝑇𝑇 𝑒𝑒 ∗ 𝑁𝑁𝑁𝑁𝑁𝑁

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2.1.3 Utility Rates
In coordination with the CA IOU rate team (comprised of representatives from Pacific Gas and Electric (PG&E), Southern California Edison (SCE) and San Diego Gas and Electric (SDG&E)) and two Publicly-Owned-Utilities (POUs) (Sacramento Municipal Utility District (SMUD) and City of Palo Alto Utilities (CPAU)), the Reach Codes Team determined appropriate utility rates for each climate zone in order to calculate utility costs and determine On-Bill costeffectiveness for the proposed measures and packages. The utility tariffs, summarized in Table 1, were determined based on the most prevalent active rate in each territory. Utility rates were applied to each climate zone based on the predominant IOU serving the population of each zone, with a few climate zones evaluated multiple times under different utility scenarios. Climate Zones 10 and 14 were evaluated with both SCE/SoCalGas and SDG&E tariffs since each utility has customers within these climate zones. Climate Zone 5 is evaluated under both PG&E and SoCalGas natural gas rates. Two POU or municipal utility rates were also evaluated: SMUD in Climate Zone 12 and CPAU in Climate Zone 4.

Some community choice aggregations (CCAs) have utility rates that are very similar to IOU rates, often within $0.02 per kWh. For these CCA customers, total utility costs will be very similar to those calculated in this study and the results from this study will generally apply. The study results cannot be easily applied to CCAs with rates that do not closely track the IOU rates or municipal utilities outside of SMUD and CPAU.

First-year utility costs were calculated using hourly electricity and natural gas output from CBECC-Res and applying the utility tariffs summarized in Table 1. Annual costs were also estimated for IOU customers eligible for the CARE tariff discounts on both electricity and natural gas bills. Appendix 7.2 Utility Rate Schedules includes details of each utility tariff. For cases with onsite generation (i.e. solar photovoltaics (PV)), the approved Net Billing Tariff (NBT) was applied along with monthly service fees and hourly export compensation rates for 20246. In December 2022, the California Public Utilities Commission (CPUC) issued a decision adopting NBT as a successor to prior net energy metering rules (NEM 2.0) that went into effect April of 2023.7 The ADU was assumed to have separate electric and gas meters from the main house.

Table 1: Utility Tariffs Used Based on Climate Zone
Climate
Zones
Electric / Gas
Utility Electricity Tariff Natural GasTariff
IOUs
1-5,11-13,16 PG&E / PG&E E-ELEC G1
5 PG&E / SoCalGas E-ELEC GR
6, 8-10, 14, 15 SCE / SoCalGas TOU-D-PRIME GR
7, 10, 14 SDG&E / SDG&E EV-TOU-5 (TOU-ELEC for ADU
cases without PV systems8) GR
POUs
4 CPAU / CPAU E-1 G1
12 SMUD / PG&E R-TOD G1
Utility rates are assumed to escalate over time according to the CPUC 2021 En Banc hearings on utility costs through 2030 (California Public Utilities Commission, 2021a). Escalation rates through the remainder of the 30-year evaluation period are based on the escalation rate assumptions within the 2022 TDV factors. A second set of escalation rates were also evaluated to demonstrate the impact that utility cost changes over time have on cost-effectiveness. This utility rate escalation sensitivity analysis, presented in Section 4.6.3, was based on those used within the 2025 Long6 https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/net-energy-metering-nem/nemrevisit/nbtmodel--12142022.xlsb 7 https://www.cpuc.ca.gov/nemrevisit 8 See Section 3.2 Prototype Characteristics for a description of ADU cases that don’t require solar PV prescriptively.

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8 California Energy Codes & Standards | A statewide utility program 2024-03-25 term System Cost (LSC) factors (LSC replaces TDV in the 2025 code cycle) which assumed steep increases in gas rates in the latter half of the analysis period. See Appendix 7.2.7 Fuel Escalation Assumptions for details.

2.2 Greenhouse Gas Emissions
The analysis reports the greenhouse gas (GHG) emission estimates based on assumptions within CBECC-Res. There are 8,760 hourly multipliers accounting for time-dependent energy use and carbon based on source emissions, including renewable portfolio standard projections. There are two strings of multipliers—one for Northern California climate zones, and another for Southern California climate zones.9 GHG emissions are reported as average annual metric tons of CO2 equivalent over the 30-year measure analysis period.

2.3 Energy Design Rating
The 2019 Title 24 Code introduced California’s Energy Design Rating (EDR) as the primary metric to demonstrate compliance with the energy code for single family buildings. This EDR was based on the hourly TDV energy use from a building that is compliant with the 2006 International Energy Conservation Code (IECC) as the Reference Building. The Reference Building has an EDR score of 100 while a zero-net energy (ZNE) home has an EDR score of zero. While the Reference Building is used to set the scale for the rating, the Proposed Design is still compared to the Standard Design based on the Title 24 prescriptive baseline assumptions to determine compliance. In the 2022 Title 24 Code a second new EDR metric was introduced based on hourly source energy. The two EDR metrics are described below:
• EDR1 is calculated based on source energy.
• EDR2 is calculated based on TDV energy.

EDR1 has only one component, “Total EDR1” which represents source energy use for the entire building. EDR2 is composed of two components for compliance purposes: the “Efficiency EDR2”, which represents the energy efficiency features of a home, and the PV/Flexibility EDR2, which includes the effects of PV and battery storage systems. “Total EDR2” combines all energy use of the building including both the Efficiency and PV/Flexibility impacts. While the Efficiency EDR2 does not include the full impact of a battery system, it can include a self-utilization credit for batteries if certain conditions are met.

For a new, single family building to comply with the 2022 Title 24 Code, three criteria must be met:

1. The Proposed Total EDR1 must be equal to or less than the Total EDR1 of the Standard Design, and

2. The Proposed Efficiency EDR2 must be equal to or less than the Efficiency EDR2 of the Standard Design, and

3. The Proposed Total EDR2 must be equal to or less than the Total EDR2 of the Standard Design.

This concept, consistent with California’s “loading order” which prioritizes energy efficiency ahead of renewable generation, requires projects to meet a minimum Efficiency EDR2 before PV is credited but allows for PV to be traded off with additional efficiency when meeting the Total EDR2. A project may improve building efficiency beyond the minimum required and subsequently reduce the PV generation capacity necessary to achieve the required Total EDR2.

However, it may not increase the size of the PV system and trade this off with a reduction of efficiency measures.

Results from this analysis are presented as EDR Margin, a reduction in the EDR score relative to the Standard Design.

EDR Margin is a better metric to use than absolute EDR in the context of a reach code because absolute values vary based on the home design and characteristics such as size and orientation. This approach aligns with how compliance is reported for the 2019 and 2022 Title 24 Code. The EDR Margin is calculated according to Equation 5.

Equation 5
𝐸𝐸 𝑀𝑀 = 𝑆𝑆 𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆 𝑆𝑆 𝐸𝐸 − 𝑃𝑃 𝑃𝑃 𝑃𝑃 𝐸𝐸
9 CBECC-Res multipliers are the same for CZs 1-5 and 11-13 (Northern California), while there is another set of multipliers for CZs 6-10 and 14-16 (Southern California).

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9 California Energy Codes & Standards | A statewide utility program 2024-03-25 3 Prototypes, Measure Packages, and Costs
This section describes the prototypes and the scope of analysis drawing from previous research where necessary, including the 2019 low-rise residential single family reach code study (Statewide Reach Codes Team, 2019).

3.1 Prior Reach Code Research
In 2019, the Reach Codes Team analyzed the cost-effectiveness of residential single family new construction projects for mixed fuel and all-electric packages (Statewide Reach Codes Team, 2019). Using this analysis, several cities and counties in California adopted local energy code amendments encouraging or requiring that low-rise residential new construction be all-electric. As there were few changes to the single family requirements, this analysis for the 2022 code cycle leveraged the work completed for the 2019 reports. Initial efficiency packages were based on the final packages from the 2019 research and were revised to reflect measure specifications and costs based on new data.

3.2 Prototype Characteristics
The Energy Commission defines building prototypes which it uses to evaluate the cost-effectiveness of proposed changes to Title 24 requirements. For the 2022 code cycle the Energy Commission used two single family prototypes, both of which were used in this analysis. Additional details on the prototypes can be found in the Alternative Calculation Method (ACM) Approval Manual (California Energy Commission, 2018).

Additionally, a detached new construction ADU prototype was developed to reflect recent trends in California construction related to the high cost of housing (TRC, 2021). ADUs are additional dwelling units typically built on the property of an existing single-family parcel. ADUs are defined as new construction in the energy code when they are ground-up developments, do not convert an existing space to livable space, and are not attached to the primary dwelling. The evaluated prototype is not representative of an attached ADU constructed as an addition to an existing home.

The Reach Codes Team leveraged prior research to define the detached ADU baseline and measure packages. The house size and number of bedrooms were based on data from a survey conducted by UC Berkeley’s Center for Community Innovation (UC Berkeley Center for Community Innovation, 2021). The survey found that the average square footage for new ADUs statewide is 615 square feet and that the majority (61 percent) of new ADUs have one bedroom.

Table 2 describes the basic characteristics of each prototype. The prototypes have equal geometry on all walls, windows and roof to be orientation neutral.

Table 2: Prototype Characteristics
Characteristic Single Family
One-Story
Single Family
Two-Story ADU
Conditioned Floor Area 2,100 ft2 2,700 ft2 625 ft2
Num. of Stories 1 2 1
Num. of Bedrooms 3 4 1
Window-to-Floor Area Ratio 20% 20% 19.2%
The Energy Commission’s protocol for the two single family prototypes is to weigh the simulated energy impacts by a factor that represents the distribution of single-story and two-story homes being built statewide. Consistent with this protocol, this study assumed 50 percent single-story and 50 percent two-story. Simulation results in this study are

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10 California Energy Codes & Standards | A statewide utility program 2024-03-25 characterized and presented according to this ratio, which is approximately equivalent to a 2,400-square foot (ft2) house.10 ADU results are presented separately.

The methodology used in the analyses for each of the prototypical building types begins with a design that precisely meets the minimum 2022 prescriptive requirements (zero compliance margin). Table 150.1-A in the 2022 Standards (California Energy Commission, 2021a) lists the prescriptive measures that determine the baseline design in each climate zone. Other features are consistent with the Standard Design in the ACM Reference Manual (California Energy Commission, 2022), and are designed to meet, but not exceed, the minimum requirements. See Appendix 7.4 for a list of prescriptive values relevant to the measures explored in this analysis.

Table 3 describes additional characteristics as they were applied to the base case, or baseline, energy model in this analysis. In a shift from the 2019 Standards, the 2022 Standards apply a prescriptive fuel source for space heating and water, where one is gas-fueled and one is a heat pump depending on climate zone. This establishes a prescriptive heat pump baseline. In most climate zones the prescriptive base case includes a heat pump water heater and a natural gas furnace for space heating. In Climate Zones 3, 4, 13, and 14 this is reversed, where the base case has a heat pump space heater and natural gas tankless water heater.

Table 4 summarizes the PV capacities for the base case packages. 10 2,400 ft2 = (50% x 2,100 ft2) + (50% x 2,700 ft2)

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11 California Energy Codes & Standards | A statewide utility program 2024-03-25 Table 3: Base case Characteristics of the Prototypes
Characteristic Single Family ADU
Space
Heating/Cooling1,2
CZs 1-2,5-12,15-16: Natural gas furnace, split
AC 80 AFUE, 14.3 SEER2, 11.7 EER2
CZs 3-4,13-14: Split heat pump – 7.5 HSPF2,

14.3 SEER2, 11.7 EER2
Same as single family
Air Distribution Ductwork located in vented attic Same as single family Water Heater1,2
CZs 1-2,5-12,15-16: Heat pump water heater
(HPWH) UEF = 2.0 located in the garage
CZs 3-4,13-14: Natural gas tankless –
UEF = 0.81
Same equipment type as SF
except HPWH is located inside
the conditioned space with the
supply air ducted from outside
and exhaust air ducted to
outside.3
Hot Water
Distribution
Code minimum
CZs 1,16: Basic compact distribution credit Same as single family Cooking Natural Gas Same as single family
Clothes Drying Natural Gas Same as single family
PV System
Sized to offset 100% of electricity use for space
cooling, ventilation, lighting, appliance, & other
miscellaneous electric loads. Size differs by
climate zone ranging from 2.64 kW to 5.21 kW,
see Table 4.

PV is not required when the PV
system size required based on the
prescriptive calculations is less
than 1.8 kW, as is the case in
Climate Zones 1-9, 12, 14, and

16. In the other climate zones the
PV size ranges from 1.73 kW to

2.51 kW, see Table 4.
4 Foundation Slab-on-grade Same as single family
1 Equipment efficiencies are equal to minimum federal appliance efficiency standards. 2 AFUE = annual fuel utilization efficiency. SEER = seasonal energy efficiency ratio. EER = energy efficiency ratio.

HSPF = heating seasonal performance factor. UEF = uniform energy factor. 3 This version of CBECC-Res used in this analysis did not have the capability to directly model ducted HPWHs even though this configuration is called out as the Standard Design in the 2022 ACM (California Energy Commission, 2022). This was modeled by indicating that the tank is located within the conditioned space with the compressor unit located outside. 4 Exception 2 to Section 150.1(I)14 states that “no PV system is required when the minimum PV system size specified by section 150.1(c)14 is less than 1.8 kWdc.” In this analysis this exception is applied based on the sizes calculated per Equation150.1-C of Section 150.1(c)14. The performance software sizes the PV system based on the estimated energy use, which differs slightly from the prescriptive sizing. As a result, the baseline PV capacity from the performance software for Climate Zone 10 is less than 1.8 kWdc.

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12 California Energy Codes & Standards | A statewide utility program 2024-03-25 Table 4: Base Package PV Capacities (kW-DC)
Climate
Zone
Base Package
Single
Family ADU
CZ01 3.57 0
CZ02 3.03 0
CZ03 2.83 0
CZ04 2.91 0
CZ05 2.64 0
CZ06 2.65 0
CZ07 2.83 0
CZ08 3.11 0
CZ09 2.96 0
CZ10 3.17 1.73
CZ11 3.90 2.06
CZ12 3.14 0
CZ13 4.05 2.09
CZ14 3.15 0
CZ15 5.21 2.51
CZ16 2.93 0

3.3 Measure Definitions and Costs
Measures evaluated in this study fall into two categories: those associated with general efficiency — onsite generation (solar PV), and demand flexibility (batteries) — and those associated with building electrification. Furthermore, general efficiency measures are broken into those that are federally preempted and those that are not; see Section 1 for background information on preemption and Section 3.4 for details of measure packages evaluated in this study. The Reach Codes Team selected measures based on cost-effectiveness as well as decades of experience with residential architects, builders, and engineers along with general knowledge of the relative consumer acceptance of many measures.

The following sections describe the details and incremental cost assumptions for each of the measures. Incremental costs represent the equipment, installation, replacement, and maintenance costs of the proposed measures relative to the base case.11 Replacement costs are applied for roofs, mechanical equipment, PV inverters and battery systems over the 30-year evaluation period. Maintenance costs are estimated for PV systems, but not any other measures.

Costs were estimated to reflect costs to the building owner. All costs are provided as present value in 2023 (2023 PV$).

The Reach Codes Team obtained measure costs from distributors, contractors, literature review, and online sources such as Home Depot and RS Means. Contractor markups are incorporated. These are the Reach Codes Team’s best estimates of average costs statewide. However, it's recognized that local costs may differ, and that inflation and supply chain issues may also impact costs.

3.3.1 Efficiency, Solar PV, and Batteries
The following are descriptions of each of the efficiency, PV, and battery measures evaluated under this analysis and applied in at least one of the packages presented in this report, including how they compare to the current prescriptive requirements. Throughout this report, “Efficiency” measures refer specifically to the following non-preempted 11 All first costs are assumed to be financed in a mortgage and interest costs due to financing are included in the incremental costs.

See Section 2.1.2 for details.

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13 California Energy Codes & Standards | A statewide utility program 2024-03-25 measures. These measures are in addition to or in place of the relevant 2022 base case prototype characteristics outlined in Table 3, and their applicability to measure packages are summarized in Table 39 through Table 41. Table 5 summarizes the incremental cost assumptions for each of these measures.

Reduced Infiltration (ACH50): Reduce infiltration in single family homes from the default infiltration assumption of five (5) air changes per hour at 50 Pascals (ACH50) 12 by 40 percent to 3 ACH50. HERS rater field verification and diagnostic testing of building air leakage according to the procedures outlined in the 2022 Reference Appendices RA3.8 (California Energy Commission, 2021b).

Lower U-Factor Fenestration: Reduce window U-factor to 0.24. The prescriptive U-factor is 0.30 in all climate zones.

Higher SHGC Fenestration: Increase solar heat gain coefficient (SHGC) to 0.50 in climate zones where heating loads dominate (1, 3, 5 and 16). The baseline SHGC applied in the Standard Design is 0.35 in these climate zones.

Cool Roof: Install a roofing product that’s rated by the Cool Roof Rating Council to have an aged solar reflectance (ASR) equal to or greater than 0.25. Steep-sloped roofs were assumed in all cases. The prescriptive ASR is 0.20 for Climate Zones 10 through 15.

Increased Ceiling Insulation: Increase ceiling level insulation in a vented attic to R-38, R-49, or R-60 insulation.

Slab Insulation: Install R-10 perimeter slab insulation at a depth of 16-inches. This measure doesn’t apply to Climate Zone 16 where slab insulation is required prescriptively.

Low Pressure Drop Ducts: Upgrade the duct distribution system to reduce external static pressure and meet a maximum fan efficacy of 0.35 Watts per cfm (compared to the prescriptively required 0.45 W/cfm). This may involve upsizing ductwork, reducing the total effective length of ducts, and/or selecting low pressure drop components such as filters. Fan watt draw must be verified by a HERS rater according to the procedures outlined in the 2022 Reference Appendices RA3.3 (California Energy Commission, 2021b). This applies to the single family prototype only.

Buried Radial Duct Design: Bury all ductwork in ceiling insulation by laying the ducts across the ceiling joists or inbetween ceiling joists directly on the ceiling drywall. Duct design is based on a radial design where individual ducts are run to each supply register. This allows for smaller diameter ducts, reducing duct losses and more easily meeting fully or deeply buried conditions.13 Duct burial and duct system design must be verified by a HERS rater according to the procedures outlined in the 2022 Reference Appendices RA3.1.4.1.5 and RA3.1.4.1.6 (California Energy Commission, 2021b). This applies to the single family prototype only.

Ductless Mini-Split Heat Pump: In the ADU prototype install a ductless mini-split heat pump with three indoor heads.

The system is evaluated as meeting the criteria for the variable capacity heat pump (VCHP) credit, introduced in the 2019 code cycle, which must be verified by a HERS rater according to the procedures outlined in the 2022 Reference Appendices RA3.4.4.3 (California Energy Commission, 2021b). This credit requires verification of refrigerant charge, that all equipment is entirely within conditioned space, that airflow is directly supplied to all habitable space, and that wall mounted thermostats serve any zones greater than 150 square feet. This measure is non-preempted because it does not require the installation of equipment with efficiencies above federal minimum requirements.

Compact Hot Water Distribution: Design the hot water distribution system to meet minimum requirements for the basic compact hot water distribution credit according to the procedures outlined in the 2022 Reference Appendices RA4.4.6 (California Energy Commission, 2021b). In many single family homes this may require moving the water heater from an exterior to an interior garage wall. CBECC-Res software assumes a 30% reduction in distribution losses for the basic credit. This is prescriptively required in Climate Zones 1 and 16 only.

Solar PV: Installation of on-site PV is required in the 2022 residential code unless an exception is met. The PV sizing methodology in each package was developed to offset annual building electricity use and avoid oversizing. In all cases, 12 Whole house leakage tested at a pressure difference of 50 Pascals between indoors and outdoors. 13 The duct systems in the Central Valley Research Homes Project Final Project Report are illustrative of this approach (Proctor, Wilcox, & Chitwood, 2018).

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14 California Energy Codes & Standards | A statewide utility program 2024-03-25 PV is evaluated in CBECC-Res according to the California Flexible Installation (CFI) 1 assumptions. To meet CFI eligibility, the requirements of 2022 Reference Appendices JA11.2.2 (California Energy Commission, 2021b) must be met.

The Reach Codes Team used two options within the CBECC-Res software for sizing the PV system. The first option, “Standard Design PV”, was applied in the base case simulations and packages where the PV system size was not changed from the minimum system size required14. For the PV packages, the second option, “Specify PV System Scaling”, was used. In these cases, a scaling of 100 was applied, indicating that the PV system be sized to offset 100% of the estimated electricity use of the Proposed Design case.

One exception to the PV requirement is when the minimum PV system size required is less than 1.8 kW. This exception applies to the ADU models in Climate Zones 1-9, 12, 14, and 16. For these cases no PV system is required by code and no PV system was modeled in the base case simulations.

Battery Energy Storage: A 10 kWh battery system was evaluated in CBECC-Res with control type set to “Basic” and with default efficiencies of 95% for both charging and discharging. 10kWh battery capacity is representative of systems installed in single family homes based on the Self-Generation Incentive Program (SGIP) participant data. The “Basic” control option charges the battery system anytime PV generation is greater than the house load and discharges the battery whenever the house load exceeds PV generation. The battery does not discharge to the grid, maximizing onsite utilization of the PV system and in turn utility bill benefits under NBT. To qualify for the battery storage compliance credit the battery system must meet the requirements outlined in the 2022 Reference Appendices JA12 (California Energy Commission, 2021b). Batteries are not prescriptively required in any climate zone.

Table 5: Incremental Cost Assumptions: Efficiency, PV, and Battery Measures Measure
Performance
Level
Incremental
Cost
(2023 PV$)1
Source & Notes
Single
Family ADU
Reduced
Infiltration

3.0 vs 5.0
ACH50 $591 $362 $0.115/ft2 based on NREL’s BEopt cost database plus $250 HERS rater verification.

Window Ufactor 0.24 vs 0.30 $2,280 $285 $4.23/ft2 window area based on analysis conducted for the 2019 and 2022 Title 24 cycles (Statewide CASE Team, 2018).

Window
SHGC 0.50 vs 0.35 $0 $0
Based on feedback from Statewide CASE Team that higher SHGC does not necessarily have any incremental cost (Statewide CASE Team, 2017).

Cool Roof

0.25 vs 0.20
aged solar
reflectance
$219 $53
$0.07per ft2 of roof area first incremental cost for asphalt shingle product based on the 2022 Nonresidential High Performance Envelope CASE Report (Statewide CASE Team, 2020a). Total costs assume present value of replacement at year 20 and residual cost for remaining product life at end of 30-year analysis period. Higher reflectance values for lower cost are achievable for tile roof products
Attic
Insulation
R-49 vs R-30 $872 n/a
Based on costs from the 2022 Residential Additions & Alterations CASE Report (Statewide CASE Team, 2020b).

R-60 vs R-30 $1,420 n/a
R-60 vs R-38 $1,096 n/a
Slab Edge
Insulation R-10 vs R-0 $651 $449 $4 per linear foot of slab perimeter based on internet research. Assumes 16in depth. 14 The Standard Design PV system is sized to offset the electricity use of the building loads which are typically electric in a mixed fuel home, which includes all loads except space heating, water heating, clothes drying, and cooking.

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15 California Energy Codes & Standards | A statewide utility program 2024-03-25 Measure
Performance
Level
Incremental
Cost
(2023 PV$)1
Source & Notes
Single
Family ADU
Low
Pressure
Drop Ducts

0.35 vs 0.45
W/cfm $99 n/a
Costs assume one-hour labor for single family and half-hour for the ADU. Labor rate of $88 per hour is from 2022 RS Means for sheet metal workers and includes a weighted average City Cost Index for labor for California.

Buried
Ducts
Buried, radial
design $281 n/a
No cost for laying ducts on attic floor versus suspending, in some cases there will be cost savings. Neutral cost for radiant design versus trunk and branch design. A $250 HERS Rater verification fee is included.

Duct
Insulation R-8 vs R-6 $201 n/a Based on costs from the 2022 Residential Additions & Alterations CASE Report (Statewide CASE Team, 2020b).

Ductless
Mini-Split
Heat Pump
Ductless
system
meeting the
VCHP credit
vs. ducted
split heat
pump
n/a $1,571
Costs were developed based on data from E3’s 2019 report Residential Building Electrification in California (Energy & Environmental Economics, 2019) and the 2022 All-Electric Multifamily CASE Report (Statewide CASE Team, 2020c).

Equipment costs are from the CASE Report for the 10-story multifamily prototype assuming similar sized equipment between the multifamily dwelling unit and the ADU. Thermostat, wiring, electrical, and ducting costs are from the E3 study. A $250 HERS Rater verification fee is also included. Where this measure is applied to the mixed fuel home with a gas furnace, this cost is in addition to the cost difference for a heat pump versus a gas furnace/split AC reported in Section 3.3.2.

Compact
Hot Water
Distribution
Basic credit –
homes with
gas tankless
$196 $0
For single family homes with a gas tankless water heater (mixed fuel homes in Climate Zones 3, 4, 13, 14) assumes adding 20-feet venting at $14.69 per linear foot to locate water heater on interior garage wall, less 20-feet savings for PEX and pipe insulation at $5.98 per linear foot. Costs obtained from online retailers. For single family homes with a HPWH there is an incremental cost savings from less pipe being required. For the ADU it is assumed the credit can be met without any changes to design and there is no cost impact.

Basic credit –
homes with
HPWH
-$134 $0
PV System
First Cost $3.11/
W
$3.11/
W
First costs are from LBNL’s Tracking the Sun 2022 (Barbose, Galen; Darghouth, Naim; O'Shaughnessy, Eric; Forrester, Sydney, 2022) and represent median costs in California in 2022 of $3.78/WDC for residential systems. The first cost was reduced by the solar energy Investment Tax Credit of 30%.2
Inverter replacement cost of $0.14/WDC present value includes replacements at year 11 at $0.15/WDC (nominal) and at year 21 at $0.12/WDC (nominal) per the 2019 PV CASE Report (California Energy Commission, 2017).

System maintenance costs of $0.31/WDC present value assume $0.02/WDC (nominal) annually per the 2019 PV CASE Report (California Energy Commission, 2017).

Inverter
replacement
$0.14/
W
$0.14/
W
Maintenance $0.31/
W
$0.31/
W
Replacement
cost
$648/
kWh
$648/
kWh

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16 California Energy Codes & Standards | A statewide utility program 2024-03-25 Measure
Performance
Level
Incremental
Cost
(2023 PV$)1
Source & Notes
Single
Family ADU
Battery (10
kWh) First cost $782/kWh
$782/
kWh
First costs of $1,101/kWh are from SGIP residential participant cost data for single family projects between 2020 and 2023. The first cost is reduced by 30% due to the Investment Tax Credit2 and also by $0.15/Wh due to the base SGIP incentive3. The SGIP incentive is only accounted for in IOU territories and not for SMUD and CPAU analyses.

Replacement cost at years 10 and 20 was calculated based on the first cost reduced by 7% annually over the next 10 years for a future value cost of $533/kWh. The 7% reduction is based on SDG&E’s Behind-the-Meter Battery Market Study (E-Source companies, 2020). For projects constructed in 2024 or 2025, the first replacement at year 10 would occur in 2034 or 2035. This replacement cost includes an average Investment Tax Credit of 22% in 2034 and 0% in 20352.
1All first costs are assumed to be financed in a mortgage and interest costs due to financing are included in the incremental costs. See Section 2.1.2 for details. Interest costs were not included for calculating TDV costeffectiveness. 2As part of the Inflation Reduction Act in August 2022 the Section 25D Investment Tax Credit was extended and raised to 30% through 2032 with a step-down beginning in 2033. https://www.seia.org/sites/default/files/2022- 08/Inflation%20Reduction%20Act%20Summary%20PDF%20FINAL.pdf 3SGIP incentives vary by ‘steps’ which reflect utility-specific funding across program implementation years. See:
https://www.selfgenca.com/home/program_metrics/

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17 California Energy Codes & Standards | A statewide utility program 2024-03-25

3.3.2 Electrification
This analysis compared a code compliant mixed fuel prototype, which uses natural gas for three appliances (cooking, clothes drying and either space heating or water heating), with a code compliant all-electric prototype. The associated costs included the relative costs between natural gas and electric appliances, differences between in-house electricity and natural gas infrastructure, and the associated infrastructure costs for providing natural gas to the building. To estimate costs the Reach Codes Team leveraged costs from the 2019 reach code cost-effectiveness studies for residential new construction (Statewide Reach Codes Team, 2019) and detached accessory dwelling units (Statewide Reach Codes Team, 2021b), 2022 RS Means, PG&E data, published utility schedules and rules, and online research.

3.3.2.1 Utility Infrastructure
This section addresses utility infrastructure costs during construction; appliance-specific infrastructure costs are addressed in Section 0. Table 6 presents total costs for natural gas infrastructure for a single family building within CA gas IOU territory, including distribution and service line extensions, meter installation, and plan review. These costs are applied as cost savings for an all-electric home when compared to a mixed fuel home. This is the component with the highest degree of variability for all-electric homes, as they are project-dependent and may be significantly impacted by such factors as utility territory, site characteristics, distance to the nearest natural gas main and main location, joint trenching, whether work is conducted by the utility or a private contractor, and number of dwelling units per development. All gas utilities participating in this study were solicited for cost information. The CA IOU costs for single family homes presented are based on cost data provided by PG&E.

Extension of service lines from a main distribution line to the home were provided separately for a new subdivision in an undeveloped area ($1,300) as well as an infill development ($6,750). The service extension is typically more costly in an infill scenario due to the disruption of existing roads, sidewalks, and other structures. For this analysis an average of the new subdivision and infill development costs was used, representing 80 percent of the new subdivision and 20 percent infill. In the case of distribution line extensions, the estimated cost is for new greenfield development.

For the single family analysis, based on the Reach Codes Team's conversations with the industry it is assumed that no upgrades to the electrical panel are required and that a 200 Amp panel is typically installed for both mixed fuel and allelectric homes.

Table 6: Single Family IOU Total Natural Gas Infrastructure Costs Item Cost
Distribution Line Extension $1,020
Service Line Extension $2,390
Meter $300
Plan Review Costs $850
Total $4,560
CPAU provides gas service to its customers and therefore separate costs were evaluated based on CPAU gas service connection fees.15 Table 7 presents the breakdown of gas infrastructure costs used in this analysis for CPAU. There is no main distribution line component since Palo Alto has little greenfield space remaining and most of the development is infill.
15 CPAU Schedule G-5 effective 09-01-2019: https://www.cityofpaloalto.org/files/assets/public/utilities/utilities-engineering/generalspecifications/gas-service-connection-fees.pdf

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18 California Energy Codes & Standards | A statewide utility program 2024-03-25 Table 7: Single Family CPAU Total Natural Gas Infrastructure Costs Item Cost
Service Extension $5,892
Meter $1,012
Plan Review Costs $924
Total $7,828
Electricity infrastructure costs for single family homes were not estimated as part of this work as they are expected to be the same for both all-electric and mixed fuel construction. This will change in July 2024 based on the CPUC’s recent decision to eliminate electric line extension subsidies for new construction projects that use natural gas and/or propane.16 This will increase the utility infrastructure costs for mixed fuel homes, relative to all-electric homes, improving the cost-effectiveness of all-electric construction. The Reach Codes Team intends to quantify this impact in future studies.

Table 8 presents utility infrastructure costs for the detached ADU, both mixed fuel and all-electric designs. These costs are directly from the 2019 detached ADU reach code report (Statewide Reach Codes Team, 2021b) and were obtained from stakeholder interviews and RS Means. For the ADU scenario it’s assumed that natural gas infrastructure already exists on the lot and is being extended to the location of the ADU typically at the back of the lot. There are incremental cost savings for an all-electric ADU from not extending the natural gas service; however, there is also a small incremental cost for upgrading the electric service to accommodate the additional electrical load. The Reach Codes Team found that a new detached ADU would require that the building owner upgrade the service connection to the lot in both the mixed fuel ADU design and the all-electric design. The most common size for this upgrade is to upsize the existing panel to 225A, which would not represent an incremental cost from the mixed fuel project to the all-electric project. Feeder wiring to the ADU and the ADU subpanel, on the other hand, will need to be slightly upgraded for the all-electric design.

Table 8: ADU Utility Infrastructure Total and Incremental Costs Mixed Fuel Measure Mixed Fuel
Total Cost All-Electric Measure All-Electric Total Cost All-Electric
Incremental Cost
Site natural gas service
extension $1,998 No site natural gas service $0 ($1,998) Site electrical service
connection upgrade 225A $3,500
Site electrical service
connection upgrade 225A $3,500 $0
100A feeder to ADU with
breaker $933
125A feeder to ADU with
breaker $1,206 $273
100A ADU subpanel $733 125A ADU subpanel $946 $213
Totals $7,164 $5,652 ($1,512)

3.3.2.2 Equipment
This section provides descriptions and costs of the equipment applied to electrify mixed fuel homes in the all-electric packages. The equipment meets but does not exceed federal efficiency requirements to avoid federal preemption concerns.
16 https://www.cpuc.ca.gov/news-and-updates/all-news/cpuc-eliminates-last-remaining-utility-subsidies-for-new-construction-ofbuildings-using-gas-2023

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19 California Energy Codes & Standards | A statewide utility program 2024-03-25 For the water heating and space conditioning equipment analyzed, cost analyses incorporated the equipment’s effective useful lifetime (EUL), which are summarized in Table 9. The EUL for the heat pump, furnace, and air conditioner are based on the Database for Energy Efficient Resources (DEER) (California Public Utilities Commission, 2021b). Water heating equipment lifetimes are based on DOE’s recent water heater rulemaking (Department of Energy, 2022). Replacement costs are applied when equipment reaches its EUL within the 30-year evaluation period, and in such cases are included in the total lifetime costs. Residual value of the gas furnace and gas tankless at the end of the 30-year analysis period was accounted for to represent the remaining life of the equipment.

In this analysis, replacement costs assume a like-for-like replacement of equipment type and fuel (as listed in Table 9).

However, this may be precluded in the future due to efforts to prohibit the sale of gas equipment currently being considered or undertaken by air districts (ex. BAAQMD, SCAQMD) and the California Air Resources Board (ex. zero NOx appliance rules).

Table 9: Effective Useful Lifetime (EUL) of Water Heating & Space Conditioning Equipment Measure EUL (Years)
Gas Furnace 20
Air Conditioner 15
Heat Pump 15
Gas Tankless Water Heater 20
Heat Pump Water Heater 15
Space Conditioning: This measure covers replacing a prescriptive air conditioner and gas furnace with a minimum efficiency heat pump in applicable climate zones (1, 2, 5 to 12, 15 and 16; see Table 3). Typical incremental costs for this equipment were based on contractor feedback and price variation by system capacity from the AC Wholesalers website and the RS Means cost database (RSMeans, 2022). Costs were applied based on the system capacity from heating and cooling load calculations in CBECC-Res as presented in Table 10. Air conditioner nominal capacity was calculated as the CBECC-Res cooling load, rounded up to the nearest half ton. Heat pump nominal capacity was calculated as the maximum of either the CBECC-Res heating or cooling load, rounded up to the nearest half ton. In both cases a minimum capacity of 1.5-ton was applied as this represents the typical smallest available split system heat pump equipment. Load calculations demonstrated that Climate Zones 2, 5 to 12, and 15 were cooling-dominated while Climate Zones 1 and 16 were heating-dominated. In the heating dominated climate zones the heat pump for the single family home needs to be upsized relative to an air conditioner that only provides cooling.

Replacement costs were estimated based on a contractor survey conducted by the Statewide Reach Codes Team in 2023 (Statewide Reach Codes Team, tbd), less any gas and electric infrastructure costs, and the equipment lifetimes listed in Table 9. Resultant incremental costs are presented in Table 11.

This measure, and thus the incremental cost, does not apply to climate zones where heat pump space conditioning is already prescriptively required (Climate Zones 3, 4, 13, and 14).

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20 California Energy Codes & Standards | A statewide utility program 2024-03-25 Table 10: Space Conditioning System Nominal Capacities
Climate
Zone
Single Family ADU
Air Conditioner
Capacity (tons)
Heat Pump
Capacity (tons)
Air Conditioner
Capacity (tons)
Heat Pump
Capacity (tons)
1 1.5 2.5 1.5 1.5
2 3 3 1.5 1.5
3 - - - -
4 - - - -
5 3 3 1.5 1.5
6 3 3 1.5 1.5
7 3 3 1.5 1.5
8 2.5 2.5 1.5 1.5
9 2.5 2.5 1.5 1.5
10 2.5 2.5 1.5 1.5
11 3 3 1.5 1.5
12 2.5 2.5 1.5 1.5
13 - - - -
14 - - - -
15 4 4 1.5 1.5
16 2 3.5 1.5 1.5
Table 11: Space Conditioning System Incremental Costs (2023 PV$) Climate
Zone
Single Family ADU
First
Cost
Total Lifetime
Cost (Financed)
First
Cost
Total Lifetime
Cost (Financed)
1 $803 $2,705 ($2,120) ($1,717)
2 ($1,044) ($44) ($2,120) ($1,717)
3 - - - -
4 - - - -
5 ($1,044) ($44) ($2,120) ($1,717)
6 ($1,044) ($44) ($2,120) ($1,717)
7 ($1,044) ($44) ($2,120) ($1,717)
8 ($1,445) ($673) ($2,120) ($1,717)
9 ($1,445) ($673) ($2,120) ($1,717)
10 ($1,445) ($673) ($2,120) ($1,717)
11 ($1,044) ($44) ($2,120) ($1,717)
12 ($1,445) ($673) ($2,120) ($1,717)
13 - - - -
14 - - - -
15 ($1,032) $368 ($2,120) ($1,717)
16 $2,331 $5,123 ($2,120) ($1,717)

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21 California Energy Codes & Standards | A statewide utility program 2024-03-25 Water Heater: This measure covers replacing a prescriptive gas tankless water heater with a minimum efficiency HPWH in applicable climate zones (3, 4, 13, and 14; see Table 3). Typical incremental costs were based on costs from prior reach code work and recent contractor feedback. Incremental first costs assume a 65-gal HPWH and incremental replacement costs account for equipment lifetimes listed in Table 9. Replacement costs assume no change in cost from the first cost estimates before accounting for inflation, less any gas and electric infrastructure costs. For the ADU analysis the water heater is evaluated within the conditioned space with the supply air ducted from the outside and exhaust air ducted to the outside. A mechanical contractor provided a cost estimate of $943 for ducting through the attic in an ADU where the water heater is in an interior room. This cost is included in the equipment and installation total for the ADU. Resultant incremental costs are presented in Table 12.

Table 12: Heat Pump Water Heating System Incremental Costs (2023 PV$) Item
ADU Single Family
First
Cost
Total Lifetime
Cost
(Financed)
First
Cost
Total Lifetime
Cost
(Financed)
Equipment & Installation $2,243 $3,930 $1,300 $2,267
Electric Service Upgrade $43 $48 $45 $51
In-House Gas Piping ($580) ($651) ($580) ($651)
Total $1,706 $3,327 $765 $1,666
For this electrification analysis, a HPWH that just meets the federal minimum efficiency standards17 of close to 2.0 Uniform Energy Factor (UEF) was evaluated in order to satisfy preemption requirements. However, the Reach Codes Team is not aware of any 2.0 UEF products that are available on the market. The Northwest Energy Efficiency Alliance (NEEA) established its own rating system for high efficiency HPWHs18 and maintains a database of qualified products.

The lowest UEF currently reported in the database is 2.73. In fact, of the four rating tiers offered by NEEA, those meeting Tier 3 or Tier 4 are the dominant products on the market today. According to NEEA all major HPWH manufacturers are represented in NEEA’s qualified product list19 and there are fewer than 10 integrated products certified as Tier 1 or Tier 2, all of which have UEFs greater than 3.0.20 NEEA Tier 3 water heaters were included in the high-efficiency measure packages (see Section 3.4).

Clothes Dryer and Range: After review of various sources, the Reach Codes Team concluded that the cost difference between gas and electric resistance equipment for clothes dryers and stoves is negligible and that the lifetimes of the two technologies are similar. Resultant incremental costs are presented in Table 13. Note that while induction stoves may be a more likely installation option in many homes, CBECC-Res does not currently differentiate between electric technologies for stoves and therefore they were not considered in this analysis. Relative to electric resistance, induction stoves use less energy and improve performance and user satisfaction, at an additional cost.

Electric Service Upgrade (appliance-specific): The 2022 Title 24 Code requires electric readiness for gas appliances; as a result, the incremental costs to provide electrical service for electric appliances are minimal. The incremental costs accounted for in this study — shown in Table 13 — are calculated as the cost to install 220V service for the electric appliances less the cost for the electric ready requirements and for installing 110V service for the 17 The Department of Energy establishes minimum energy conservation standards for consumer products, as directed in the Energy Policy and Conservation Act. See https://www.ecfr.gov/current/title-10/chapter-II/subchapter-D/part-430/subpart-C/section430.32. 18 Based on operational challenges experienced in the past, NEEA established rating test criteria to ensure newly installed HPWHs perform adequately, especially in colder climates. The NEEA rating requires products comply with ENERGY STAR and includes requirements regarding noise and prioritizing heat pump use over supplemental electric resistance heating. 19 https://neea.org/success-stories/heat-pump-water-heaters 20 As of 3/8/2024: https://neea.org/img/documents/residential-unitary-HPWH-qualified-products-list.pdf

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22 California Energy Codes & Standards | A statewide utility program 2024-03-25 comparable gas appliance. Incremental costs are applied for the space conditioner, water heater, and cooking range.

Based on builder surveys, it’s assumed that in a typical mixed fuel home both electric and gas service are provided to the dryer location and therefore no incremental costs for the dryer were applied. Costs assume 50A service for the range and 30A service for the space conditioner and water heater. Costs are assumed to be the same for the single family and ADU analyses.

In-House Natural Gas Infrastructure (from meter to appliances): Installation cost to run a natural gas line from the meter to the appliance location was estimated at $580 per appliance, as shown in Table 13. These costs were based on material costs from Home Depot and labor costs from 2022 RS Means. The material costs were about 1/3 higher in RS Means than Home Depot, so the Reach Codes Team used the lower costs from Home Depot. The Reach Codes Team conducted a pipe sizing analysis for the two single family and one ADU prototype homes to estimate the length and diameter of gas piping required assuming the home included a gas furnace, gas tankless water heater, gas range, and gas dryer. Total estimated costs were very similar for each of the three prototypes and an average cost per appliance of $580 was determined. Costs are assumed to be the same for the single family and ADU analyses.

Table 13: Single Family All-Electric Appliance Incremental Costs Item
ADU & Single Family
First
Cost
Total Lifetime Cost
(Financed)
Electric Resistance vs Gas Cooking
Equipment & Installation $0 $0
Electric Service Upgrade $100 $113
In-House Gas Piping ($580) ($651)
Total ($480) ($539)
Electric Resistance vs Gas Clothes Drying
Equipment & Installation $0 $0
Electric Service Upgrade $0 $0
In-House Gas Piping ($580) ($651)
Total ($580) ($651)

3.4 Measure Packages
The Reach Codes Team evaluated two packages for mixed fuel homes and five packages for all-electric homes for each prototype and climate zone, as described below.

1. All-Electric Code Minimum: This package applied the prescriptive requirements of the 2022 Title 24 Code and replaced gas equipment with minimum efficiency electric equipment.

2. Efficiency Only, all-electric: This package used only efficiency measures that don’t trigger federal preemption issues including envelope, water heating distribution, and duct distribution efficiency measures. For ADUs, this also included ductless variable capacity heat pumps (VCHPs). This package was evaluated for the all-electric homes only.

3. Efficiency + High Efficiency (Preempted) Equipment, all-electric and mixed fuel: This package builds off the Efficiency Only package, adding water heating and space conditioning equipment that is more efficient than federal standards. The Reach Codes Team considers this more reflective of how builders meet above code requirements in practice. This package was evaluated to compare compliance results against the other nonpreempted packages (see Table 27 and Table 28), however cost-effectiveness was not evaluated for this package since it cannot serve as the basis for adoption of a local ordinance. Specifically, it applied:
a. Water heating, all-electric: Heat pump water heaters with a NEEA Tier 3 rating (3.45 UEF). b. Water heating, mixed fuel: High efficiency (0.95 UEF) gas tankless.

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23 California Energy Codes & Standards | A statewide utility program 2024-03-25 c. Space conditioning, single family: High efficiency (16 SEER2/8 HSPF2) heat pumps. In mixed fuel packages, for climate zones with prescriptive gas heating, high efficiency (16 SEER2/95 AFUE) units were applied.

4. Efficiency + PV, all-electric: This package also builds on the Efficiency Only package, excluding preempted equipment. Instead, PV capacity was added to offset all of the estimated annual electricity use. This package was evaluated for the all-electric homes only.

5. Efficiency + PV + Battery, all-electric and mixed fuel: Using the Efficiency + PV package as a starting point for the all-electric analysis, a battery system was added. For mixed fuel homes the package of efficiency measures differed from the all-electric homes in some climate zones to arrive at a cost-effective solution.

To reiterate previous statements, the non-preempted measures used in all of the above packages (except for the AllElectric Code Minimum package) are referred to as “Efficiency measures”. As noted above, these measures may differ by prototype (single family vs. ADU) and by package. See Table 40 and Table 41 for the details of these measures.

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24 California Energy Codes & Standards | A statewide utility program 2024-03-25 4 Results
Section 4.1 presents compliance results for all-electric versus mixed fuel code minimum packages to provide a broad overview of how these different approaches impact code compliance. Sections 4.2 to 4.5 present EDR results along with other savings data for packages of particular interest, as well as cost-effectiveness results for all packages.

Section 4.5 presents results for sensitivity analyses. All results reflect savings over a 30-year analysis period and are compared against the 2022 prescriptive baseline.

4.1 Compliance Results: All-Electric vs. Mixed Fuel Code Minimum The Reach Codes Team evaluated the compliance impacts of a prescriptive all-electric home as well as a traditional mixed fuel home with four gas appliances (space heating, water heating, cooking, clothes drying). Compliance is relative to the 2022 prescriptive base case home with three gas appliances which, by definition, has a compliance margin of zero in all climate zones. The impacts for the all-electric single family home and the ADU are presented in Figure 1 and Figure 2, respectively. The all-electric single family and ADU home prototypes are code compliant with both EDR1 (source energy) and efficiency EDR2 (TDV energy) in all climate zones, though the compliance margin is highly variable across climate zones. The four gas appliance single family home is presented in Figure 3. This case is not code compliant in any climate zone.

Figure 1: Single family all-electric home compliance impacts. 0 5
10 15
20 25
30 CZ01 CZ02 CZ03 CZ04 CZ05 CZ06 CZ07 CZ08 CZ09 CZ10 CZ11 CZ12 CZ13 CZ14 CZ15 CZ16 EDR Margin
All-Electric Prescrip�ve
Source (EDR1) TDV (EDR2 Efficiency)

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25 California Energy Codes & Standards | A statewide utility program 2024-03-25 Figure 2: ADU all-electric home compliance impacts.

Figure 3: Single family four gas appliance home compliance impacts.

This analysis illustrates a couple of interesting points:

1. The 2022 compliance metrics are important drivers encouraging electrification. The compliance penalties associated with the four gas appliance home scenarios are significant and will require deep efficiency measures to overcome.

2. The 2022 Title 24 Code’s new source energy metric combined with the heat pump baseline encourage allelectric construction, providing a compliance benefit that allows for some amount of prescriptively required building efficiency to be traded off and still comply when using the performance method. 0 2
4 6
8 10
12 14
CZ01 CZ02 CZ03 CZ04 CZ05 CZ06 CZ07 CZ08 CZ09 CZ10 CZ11 CZ12 CZ13 CZ14 CZ15 CZ16 EDR Margin
All-Electric Prescrip�ve
Source (EDR1) TDV (EDR2 Efficiency)
-18
-16
-14
-12
-10
-8
-6
-4
-2
0 2
CZ01 CZ02 CZ03 CZ04 CZ05 CZ06 CZ07 CZ08 CZ09 CZ10 CZ11 CZ12 CZ13 CZ14 CZ15 CZ16 EDR Margin
Mixed Fuel Prescrip�ve, 4 Gas Appliances
Source (EDR1) TDV (EDR2 Efficiency)

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California Energy Codes & Standards | A statewide utility program 2024-03-25

4.2 All-Electric Code Minimum Results
Table 14 shows results for the single family all-electric Code Minimum measure package. Utility cost savings are negative, indicating an increase in utility costs for the all-electric building, everywhere except in CPAU and SMUD territories. In all cases the incremental cost is negative, which reflects cost savings for the all-electric building due to elimination of gas infrastructure costs. The package is cost-effective based on TDV in all cases but one (Climate Zone 16); it’s not cost-effective On-Bill in Climate Zones 1, 3, 14, and 16.

Table 15 shows the all-electric Code Minimum package results for the ADU. Utility savings and incremental costs reflect the same general trend as single family homes. Cost-effectiveness is less favorable than the single family application, with TDV cost-effectiveness not met in Climate Zones 3, 4, 13, and 14, and On-Bill cost-effectiveness met only in Climate Zones 4 in CPAU territory, 10 in SCE/SCG territory, 12 in SMUD/PG&E territory, 11 and 15. Costeffectiveness in Climate Zones 3, 4, 13, and 14 is worse than in the other climate zones due to the higher cost of converting from a gas tankless to a ducted HPWH (see Table 3) which isn’t offset enough by the energy savings. Cost savings due to elimination of gas infrastructure costs are also lower for the ADU relative to the single family home.

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California Energy Codes & Standards | A statewide utility program 2024-03-25 Table 14: Single Family Cost-Effectiveness: All-Electric Code Minimum 1 Though uncommon, incremental costs can be negative, reflecting initial construction cost savings. When paired with increased energy costs (negative benefits), the construction cost savings are treated as the ‘benefit’ while the increased energy costs are the ‘cost,’ which may yield positive cost effectiveness. See Section 2.1.2.3 for more information.

Climate
Zone
Electric
/Gas Utility
Total
EDR1
Margin
Efficiency
EDR2
Margin
Annual
Elec
Savings
(kWh)
Annual
Gas
Savings
(therms)
Utility Cost Savings Incremental Cost1 On-Bill TDV
First
Year
Lifecycle
(2022$) First Year Lifecycle (2022$)
B/C
Ratio NPV B/C Ratio NPV
CZ01 PGE 25.8 12.4 -4,308 398 ($431) ($3,873) ($4,816) ($3,605) 0.9 ($268) >1 $5,702 CZ02 PGE 14.0 8.3 -2,888 246 ($327) ($4,000) ($6,664) ($6,355) 1.6 $2,355 >1 $7,711 CZ03 PGE 9.1 7.7 -2,433 171 ($303) ($4,734) ($4,854) ($4,644) 0.98 ($90) 25.3 $3,887 CZ04 PGE 8.8 5.0 -2,232 163 ($251) ($3,665) ($4,854) ($4,644) 1.3 $979 >1 $4,494 CZ04 CPAU 8.8 5.0 -2,232 163 ($36) $2,123 ($8,122) ($8,314) >1 $10,437 >1 $7,762 CZ05 PGE 6.5 4.0 -1,960 133 ($292) ($4,981) ($6,664) ($6,355) 1.3 $1,373 6.1 $4,633 CZ05 PGE/SCG 6.5 4.0 -1,960 133 ($277) ($4,532) ($6,664) ($6,355) 1.4 $1,823 6.1 $4,633 CZ06 SCE/SCG 4.2 3.5 -1,432 84 ($231) ($4,015) ($6,664) ($6,355) 1.6 $2,339 4.7 $4,353 CZ07 SDGE 2.8 3.2 -1,293 69 ($266) ($5,731) ($6,664) ($6,355) 1.1 $624 4.2 $4,211 CZ08 SCE/SCG 2.1 1.1 -1,293 67 ($228) ($4,192) ($7,065) ($6,983) 1.7 $2,792 4.2 $4,674 CZ09 SCE 3.6 1.9 -1,453 84 ($237) ($4,153) ($7,065) ($6,983) 1.7 $2,831 5.5 $5,013 CZ10 SCE/SCG 4.8 2.3 -1,683 107 ($258) ($4,342) ($7,065) ($6,983) 1.6 $2,642 7.4 $5,287 CZ10 SDGE 4.8 2.3 -1,683 107 ($265) ($5,158) ($7,065) ($6,983) 1.4 $1,825 7.4 $5,287 CZ11 PGE 11.4 4.9 -2,712 226 ($306) ($3,803) ($6,664) ($6,355) 1.7 $2,552 >1 $7,153 CZ12 PGE 11.5 5.6 -2,554 212 ($294) ($3,773) ($7,065) ($6,983) 1.9 $3,210 >1 $7,504 CZ12 SMUD/PGE 11.5 5.6 -2,554 212 $79 $4,731 ($7,065) ($6,983) >1 $11,714 >1 $7,504 CZ13 PGE 8.3 3.2 -2,095 154 ($224) ($3,164) ($4,854) ($4,644) 1.5 $1,480 >1 $4,490 CZ14 SCE/SCG 8.8 3.3 -2,291 159 ($322) ($5,166) ($4,854) ($4,644) 0.9 ($522) >1 $4,105 CZ14 SDGE 8.8 3.3 -2,291 159 ($344) ($6,361) ($4,854) ($4,644) 0.7 ($1,717) >1 $4,105 CZ15 SCE/SCG 0.9 1.0 -1,167 53 ($217) ($4,152) ($6,652) ($5,942) 1.4 $1,791 3.0 $3,439 CZ16 PG&E 21.3 0.7 -4,729 403 ($548) ($6,581) ($3,289) ($1,187) 0.2 ($5,394) 0.4 ($1,339)

10.B.b
Packet Pg. 639 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-Effectiveness Analysis: Single Family New Construction 28 Results
California Energy Codes & Standards | A statewide utility program 2024-03-25 Table 15: ADU Cost-Effectiveness: All-Electric Code Minimum 1 Though uncommon, incremental costs can be negative, reflecting initial construction cost savings. When paired with increased energy costs (negative benefits), the construction cost savings are treated as the ‘benefit’ while the increased energy costs are the ‘cost,’ which may yield positive cost effectiveness. See Section 2.1.2.3 for more information.

Climate
Zone
Electric
/Gas
Utility
Total
EDR1
Margin
Efficiency
EDR2
Margin
Annual
Elec
Savings
(kWh)
Annual
Gas
Savings
(therms)
Utility Cost Savings Incremental Cost1 On-Bill TDV
First
Year
Lifecycle
(2022$) First Year Lifecycle (2022$)
B/C
Ratio NPV B/C Ratio NPV
CZ01 PGE 11.9 6.1 -1,641 114 ($353) ($6,682) ($4,692) ($4,605) 0.7 ($2,077) 3.9 $2,986 CZ02 PGE 5.7 3.4 -1,245 75 ($312) ($6,347) ($4,692) ($4,605) 0.7 ($1,742) 2.7 $2,515 CZ03 PGE 2.9 2.3 -1,672 123 ($377) ($7,138) ($863) $442 0.0 ($7,581) 0.0 ($1,489) CZ04 PGE 2.4 1.4 -1,612 118 ($366) ($6,964) ($863) $442 0.0 ($7,406) 0.0 ($801) CZ04 CPAU 2.4 1.4 -1,612 118 $25 $3,035 ($863) $442 6.9 $2,592 0.0 ($801) CZ05 PGE 1.8 0.8 -1,026 49 ($302) ($6,517) ($4,692) ($4,605) 0.7 ($1,912) 2.0 $2,021 CZ05 PGE/SCG 1.8 0.8 -1,026 49 ($257) ($5,178) ($4,692) ($4,605) 0.9 ($574) 2.0 $2,021 CZ06 SCE/SCG 0.5 0.2 -904 38 ($243) ($4,923) ($4,692) ($4,605) 0.9 ($318) 2.1 $2,135 CZ07 SDGE 0.1 0.1 -884 37 ($337) ($7,903) ($4,692) ($4,605) 0.6 ($3,298) 2.2 $2,205 CZ08 SCE/SCG 0.1 0.1 -878 36 ($241) ($4,894) ($4,692) ($4,605) 0.9 ($289) 2.3 $2,274 CZ09 SCE 0.4 0.1 -903 38 ($243) ($4,914) ($4,692) ($4,605) 0.9 ($310) 2.4 $2,321 CZ10 SCE/SCG 1.0 0.4 -952 43 ($189) ($3,629) ($4,692) ($4,605) 1.3 $976 2.8 $2,577 CZ10 SDGE 1.0 0.4 -952 43 ($249) ($5,689) ($4,692) ($4,605) 0.8 ($1,084) 2.8 $2,577 CZ11 PGE 4.6 2.1 -1,209 71 ($224) ($4,405) ($4,692) ($4,605) 1.0 $200 3.5 $2,870 CZ12 PGE 4.6 2.3 -1,183 69 ($306) ($6,315) ($4,692) ($4,605) 0.7 ($1,710) 3.0 $2,684 CZ12 SMUD/PGE 4.6 2.3 -1,183 69 ($65) ($808) ($4,692) ($4,605) 5.7 $3,797 3.0 $2,684 CZ13 PGE 3.1 1.3 -1,611 112 ($218) ($3,689) ($863) $442 0.0 ($4,131) 0.0 ($858) CZ14 SCE/SCG 3.5 1.2 -1,714 115 ($375) ($6,933) ($863) $442 0.0 ($7,375) 0.0 ($1,089) CZ14 SDGE 3.5 1.2 -1,714 115 ($483) ($10,348) ($863) $442 0.0 ($10,790) 0.0 ($1,089) CZ15 SCE/SCG 0.0 0.0 -864 36 ($172) ($3,359) ($4,692) ($4,605) 1.4 $1,246 2.6 $2,477 CZ16 PG&E 11.2 0.1 -1,781 122 ($379) ($7,167) ($4,692) ($4,605) 0.6 ($2,562) 2.1 $2,133

10.B.b
Packet Pg. 640 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-Effectiveness Analysis: Single Family New Construction 29 Results
California Energy Codes & Standards | A statewide utility program 2024-03-25

4.3 All-Electric Efficiency, PV, and Battery Results
Table 16 and Table 17 compare cost-effectiveness results for the all-electric packages for the single family and ADU prototypes, respectively, with the exception of the all-electric Efficiency + High Efficiency (Preempted) Equipment package (cost-effectiveness was not evaluated for this package but see Table 27 and Table 28 for a comparison of compliance impacts). In almost all cases the packages are cost-effective based on TDV. On-Bill cost-effectiveness generally improves with the addition of efficiency measures, further improves with an upsized PV system, and improves even more once batteries are added. A summary of measures included in each package is provided in Appendix 7.3 Summary of Measures by Package. The efficiency measures added to the all-electric package to meet minimum code requirements are described in Table 39 and Table 41.

Table 16: Single Family Cost-Effectiveness: Comparison of All-Electric Efficiency Only, PV, and Battery Packages Climate
Zone
Electric
/Gas Utility
All-Electric Code Minimum All-Electric Efficiency Only All-Electric-Efficiency + PV All-Electric Efficiency + PV + Battery
On-Bill TDV On-Bill TDV On-Bill TDV On-Bill TDV
B/C
Ratio NPV B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV CZ01 PGE 0.9 ($268) >1 $5,702 >1 $2,945 >1 $8,168 0.9 ($1,313) 1.8 $9,817 1.0 $1,012 1.2 $4,391 CZ02 PGE 1.6 $2,355 >1 $7,711 8.9 $3,870 >1 $9,325 1.5 $2,242 4.2 $12,452 1.3 $4,962 1.5 $8,190 CZ03 PGE 1.0 ($90) 25.3 $3,887 1.1 $168 >1 $3,939 0.8 ($903) 2.8 $6,465 1.1 $2,114 1.1 $1,347 CZ04 PGE 1.3 $979 >1 $4,494 1.7 $1,054 >1 $4,849 1.1 $204 3.5 $7,893 1.2 $3,709 1.3 $4,506 CZ04 CPAU >1 $10,437 >1 $7,762 >1 $10,021 >1 $8,117 >1 $14,776 >1 $11,161 0.9 ($1,076) 1.5 $6,724 CZ05 PGE 1.3 $1,373 6.1 $4,633 1.6 $1,975 >1 $4,985 2.2 $1,457 8.5 $7,927 1.4 $6,203 1.3 $3,876 CZ05 PGE/SCG 1.4 $1,823 6.1 $4,633 1.9 $2,424 >1 $4,985 2.6 $1,907 8.5 $7,927 1.4 $6,652 1.3 $3,876 CZ06 SCE/SCG 1.6 $2,339 4.7 $4,353 1.6 $1,813 >1 $4,119 109.5 $2,638 152.4 $6,727 1.5 $7,153 1.2 $2,276 CZ07 SDGE 1.1 $624 4.2 $4,211 1.2 $839 8.3 $4,070 5.7 $469 >1 $6,079 2.0 $13,798 1.1 $1,186 CZ08 SCE/SCG 1.7 $2,792 4.2 $4,674 1.8 $2,574 17.7 $4,642 >1 $3,329 >1 $7,492 1.7 $8,899 1.2 $2,085 CZ09 SCE 1.7 $2,831 5.5 $5,013 1.9 $2,699 >1 $5,087 >1 $3,634 >1 $8,007 1.7 $9,151 1.3 $3,630 CZ10 SCE/SCG 1.6 $2,642 7.4 $5,287 2.0 $2,668 >1 $5,376 >1 $3,765 >1 $8,347 1.7 $10,088 1.3 $3,901 CZ10 SDGE 1.4 $1,825 7.4 $5,287 1.8 $2,438 >1 $5,376 >1 $2,539 >1 $8,347 2.4 $19,463 1.3 $3,901 CZ11 PGE 1.7 $2,552 >1 $7,153 >1 $4,159 >1 $8,524 1.8 $2,984 4.6 $11,310 1.4 $7,781 1.5 $8,757 CZ12 PGE 1.9 $3,210 >1 $7,504 4.6 $3,742 >1 $8,084 1.9 $2,561 5.5 $11,063 1.3 $6,021 1.5 $8,216 CZ12 SMUD/PGE >1 $11,714 >1 $7,504 >1 $10,665 >1 $8,084 5.8 $13,407 5.5 $11,063 0.9 ($1,237) 1.4 $7,166 CZ13 PGE 1.5 $1,480 >1 $4,490 >1 $2,876 >1 $5,773 1.7 $2,334 3.7 $8,341 1.4 $7,848 1.4 $7,005 CZ14 SCE/SCG 0.9 ($522) >1 $4,105 1.8 $811 >1 $5,461 1.6 $2,558 3.6 $9,965 1.6 $10,569 1.4 $6,204 CZ14 SDGE 0.7 ($1,717) >1 $4,105 1.5 $643 >1 $5,461 1.2 $922 3.6 $9,965 2.1 $20,099 1.4 $6,204 CZ15 SCE/SCG 1.4 $1,791 3.0 $3,439 8.0 $3,267 >1 $4,669 >1 $3,940 >1 $6,120 2.0 $13,576 0.99 ($80) CZ16 PG&E 0.2 ($5,394) 0.4 ($1,339) 0.2 ($1,946) 1.7 $1,894 0.8 ($3,199) 1.6 $6,711 1.0 $206 1.1 $1,690

10.B.b
Packet Pg. 641 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-Effectiveness Analysis: Single Family New Construction 30 Results
California Energy Codes & Standards | A statewide utility program 2024-03-25 Table 17: ADU Cost-Effectiveness: All-Electric Energy Efficiency + Additional PV + Battery Climate
Zone
Electric
/Gas Utility
All-Electric Code Minimum All-Electric Efficiency Only All-Electric Efficiency + PV All-Electric Efficiency + PV + Battery On-Bill TDV On-Bill TDV On-Bill TDV On-Bill TDV
B/C
Ratio NPV B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV CZ01 PGE 0.7 ($2,077) 3.9 $2,986 0.7 ($1,341) >1 $3,243 1.2 $2,389 1.5 $5,353 1.0 ($216) 1.0 ($366) CZ02 PGE 0.7 ($1,742) 2.7 $2,515 0.5 ($2,155) >1 $2,289 1.5 $3,918 1.9 $6,704 1.1 $2,456 1.3 $5,648 CZ03 PGE 0.0 ($7,581) 0.0 ($1,489) 0.0 ($8,481) 0.0 ($2,235) 0.83 ($1,988) 1.2 $1,882 0.86 ($3,653) 1.0 ($492) CZ04 PGE 0.0 ($7,406) 0.0 ($801) 0.0 ($8,319) 0.4 ($1,419) 0.9 ($1,094) 1.4 $3,933 0.9 ($2,801) 1.1 $1,875 CZ04 CPAU 6.9 $2,592 0.0 ($801) 1.5 $1,330 0.4 ($1,419) 1.7 $8,884 1.4 $3,933 0.7 ($8,335) 1.0 $825 CZ05 PGE 0.7 ($1,912) 2.0 $2,021 0.5 ($2,810) 1.7 $1,095 1.7 $4,515 2.1 $5,881 1.2 $3,324 1.1 $2,563 CZ05 PGE/SCG 0.9 ($574) 2.0 $2,021 0.7 ($1,472) 1.7 $1,095 2.0 $5,853 2.1 $5,881 1.2 $4,662 1.1 $2,563 CZ06 SCE/SCG 0.9 ($318) 2.1 $2,135 0.7 ($1,078) 2.5 $1,548 2.1 $6,366 2.4 $6,996 1.2 $3,195 1.3 $4,863 CZ07 SDGE 0.6 ($3,298) 2.2 $2,205 0.4 ($4,038) 2.2 $1,386 2.0 $6,167 2.1 $5,939 1.5 $11,261 1.1 $2,674 CZ08 SCE/SCG 0.9 ($289) 2.3 $2,274 0.7 ($1,046) 2.5 $1,523 2.1 $6,750 2.5 $8,280 1.2 $4,320 1.4 $6,678 CZ09 SCE 0.9 ($310) 2.4 $2,321 0.7 ($1,108) 2.7 $1,624 2.2 $6,954 2.5 $8,052 1.2 $4,600 1.4 $8,273 CZ10 SCE/SCG 1.3 $976 2.8 $2,577 1.1 $280 4.3 $1,936 5.7 $1,120 15.1 $3,840 1.0 ($593) 1.1 $940 CZ10 SDGE 0.8 ($1,084) 2.8 $2,577 0.7 ($1,401) 4.3 $1,936 0.0 ($1,079) 15.1 $3,840 1.4 $6,523 1.1 $940 CZ11 PGE 1.0 $200 3.5 $2,870 1.1 $290 >1 $2,875 0.9 ($216) 3.9 $4,381 1.0 ($600) 1.2 $2,983 CZ12 PGE 0.7 ($1,710) 3.0 $2,684 0.5 ($2,152) >1 $2,222 1.6 $5,030 2.0 $7,018 1.2 $3,451 1.3 $5,859 CZ12 SMUD/PGE 5.7 $3,797 3.0 $2,684 15.3 $2,366 >1 $2,222 1.8 $6,123 2.0 $7,018 0.6 ($8,899) 1.2 $4,809 CZ13 PGE 0.0 ($4,131) 0.0 ($858) 0.0 ($4,116) 0.6 ($879) 0.3 ($4,374) 1.1 $649 0.8 ($3,872) 1.0 $456 CZ14 SCE/SCG 0.0 ($7,375) 0.0 ($1,089) 0.0 ($7,543) 0.5 ($1,340) 1.2 $1,941 1.6 $6,279 1.1 $1,496 1.2 $4,644 CZ14 SDGE 0.0 ($10,790) 0.0 ($1,089) 0.0 ($10,889) 0.5 ($1,340) 1.3 $3,342 1.6 $6,279 1.4 $11,396 1.2 $4,644 CZ15 SCE/SCG 1.4 $1,246 2.6 $2,477 2.8 $1,629 >1 $2,686 >1 $2,115 >1 $3,904 1.2 $2,922 1.2 $2,135 CZ16 PG&E 0.6 ($2,562) 2.1 $2,133 0.6 ($1,707) >1 $2,879 1.7 $5,819 2.1 $8,219 1.2 $4,345 1.3 $6,454

10.B.b
Packet Pg. 642 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-Effectiveness Analysis: Single Family New Construction 31 Results
California Energy Codes & Standards | A statewide utility program 2024-03-25

4.4 Mixed Fuel Results
Table 18 and Table 19 show results for the mixed fuel Efficiency + PV + Battery package for Single Family and ADU prototypes, respectively. On a TDV basis, this package is cost-effective only in Climate Zone 1 for single family and in no cases for ADUs. However, this package is cost-effective On-Bill for the single family home in all climate zones except 4 in CPAU territory and 12 in SMUD/PG&E territory. On-Bill cost-effectiveness for the ADU home, on the other hand, is seen only in Climate Zones 2, 5, 7 through 9, 10 in SDG&E territory, 14, and 16.

Table 18: Single Family Cost-Effectiveness: Mixed Fuel Efficiency + PV + Battery Climate
Zone
Electric
/Gas Utility
Total
EDR1
Margin
Efficiency
EDR2
Margin
Annual
Elec
Savings
(kWh)
Annual
Gas
Savings
(therms)
Utility Cost
Savings Incremental Cost On-Bill TDV
First
Year
Lifecycle
(2022$)
First
Year
Lifecycle
(2022$)
B/C
Ratio NPV B/C Ratio NPV
CZ01 PGE 22.6 18.8 1,571 116 $1,084 $26,667 $11,160 $20,166 1.3 $6,501 1.0 $500 CZ02 PGE 14.1 7.4 1,257 34 $913 $21,353 $10,268 $18,868 1.1 $2,486 0.9 ($1,282) CZ03 PGE 12.8 4.3 858 7 $785 $18,003 $8,708 $16,900 1.1 $1,104 0.7 ($4,777) CZ04 PGE 13.2 4.3 790 6 $803 $18,394 $9,623 $17,938 1.0 $456 0.8 ($3,925) CZ04 CPAU 13.2 4.3 790 6 $123 $2,877 $10,673 $19,172 0.2 ($16,295) 0.7 ($4,975) CZ05 PGE 14.8 4.9 1,178 13 $905 $20,821 $10,021 $18,536 1.1 $2,285 0.8 ($4,048) CZ05 PGE/SCG 14.8 4.9 1,178 13 $900 $20,690 $10,021 $18,536 1.1 $2,154 0.8 ($4,048) CZ06 SCE/SCG 18.3 5.5 888 6 $864 $19,539 $9,266 $17,587 1.1 $1,951 0.8 ($3,941) CZ07 SDGE 18.7 4.8 832 4 $1,134 $27,505 $9,302 $17,636 1.6 $9,869 0.7 ($4,905) CZ08 SCE/SCG 17.1 3.0 777 2 $920 $20,754 $9,134 $17,410 1.2 $3,344 0.7 ($4,341) CZ09 SCE 16.2 3.1 833 3 $922 $20,804 $9,152 $17,435 1.2 $3,369 0.8 ($3,839) CZ10 SCE/SCG 14.4 2.7 846 2 $958 $21,608 $8,828 $17,062 1.3 $4,546 0.7 ($4,146) CZ10 SDGE 14.4 2.7 846 2 $1,288 $31,210 $8,828 $17,062 1.8 $14,148 0.7 ($4,146) CZ11 PGE 12.9 5.1 1,025 26 $1,031 $23,949 $9,099 $17,426 1.4 $6,523 0.98 ($285) CZ12 PGE 13.2 4.8 1,098 23 $923 $21,415 $9,485 $17,964 1.2 $3,451 0.96 ($614) CZ12 SMUD/PGE 13.2 4.8 1,098 23 $253 $6,133 $10,535 $19,199 0.3 ($13,066) 0.9 ($1,664) CZ13 PGE 12.3 4.2 1,006 5 $1,016 $23,250 $9,251 $17,585 1.3 $5,665 0.9 ($1,774) CZ14 SCE/SCG 13.4 5.4 1,514 6 $1,093 $24,697 $10,214 $18,751 1.3 $5,945 0.9 ($1,383) CZ14 SDGE 13.4 5.4 1,514 6 $1,421 $34,477 $10,214 $18,751 1.8 $15,726 0.9 ($1,383) CZ15 SCE/SCG 13.5 3.8 531 2 $1,140 $25,708 $8,586 $16,630 1.5 $9,078 0.6 ($5,490) CZ16 PG&E 20.4 14.2 1,228 114 $1,070 $26,218 $12,086 $20,964 1.3 $5,254 0.98 ($444)

10.B.b
Packet Pg. 643 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-Effectiveness Analysis: Single Family New Construction 32 Results
California Energy Codes & Standards | A statewide utility program 2024-03-25 Table 19: ADU Cost-Effectiveness: Mixed Fuel Efficiency + PV + Battery Climate
Zone
Electric
/Gas Utility
Total
EDR1
Margin
Efficiency
EDR2
Margin
Annual
Elec
Savings
(kWh)
Annual
Gas
Savings
(therms)
Utility Cost
Savings Incremental Cost On-Bill TDV
First
Year
Lifecycle
(2022$)
First
Year
Lifecycle
(2022$)
B/C
Ratio NPV B/C Ratio NPV
CZ01 PGE 18.5 7.7 3,666 20 $1,078 $24,880 $15,088 $25,533 1.0 ($654) 0.7 ($6,375) CZ02 PGE 16.6 3.5 3,472 11 $1,042 $23,928 $13,502 $23,404 1.0 $524 0.8 ($3,785) CZ03 PGE 11.8 1.2 2,679 0 $781 $17,816 $11,433 $20,715 0.9 ($2,899) 0.7 ($6,381) CZ04 PGE 13.3 1.6 2,799 0 $859 $19,588 $11,869 $21,212 0.9 ($1,625) 0.7 ($4,962) CZ04 CPAU 13.3 1.6 2,799 0 $391 $8,911 $12,919 $22,447 0.4 ($13,536) 0.7 ($6,012) CZ05 PGE 16.9 1.1 3,309 2 $1,031 $23,539 $12,222 $21,774 1.1 $1,765 0.8 ($4,320) CZ05 PGE/SCG 16.9 1.1 3,309 2 $1,031 $23,520 $12,222 $21,774 1.1 $1,746 0.8 ($4,320) CZ06 SCE/SCG 19.8 1.2 3,285 1 $953 $21,468 $12,050 $21,543 1.0 ($75) 0.8 ($3,431) CZ07 SDGE 20.3 1.2 3,278 0 $1,296 $31,370 $12,424 $22,045 1.4 $9,325 0.8 ($4,187) CZ08 SCE/SCG 20.4 0.5 3,505 0 $1,040 $23,434 $12,609 $22,292 1.1 $1,141 0.8 ($3,179) CZ09 SCE 19.6 0.5 3,497 0 $1,030 $23,213 $12,347 $21,941 1.1 $1,272 0.8 ($2,974) CZ10 SCE/SCG 19.0 0.6 729 0 $537 $12,107 $8,092 $16,220 0.7 ($4,113) 0.5 ($7,000) CZ10 SDGE 19.0 0.6 729 0 $813 $19,671 $8,092 $16,220 1.2 $3,451 0.5 ($7,000) CZ11 PGE 17.6 3.0 871 10 $663 $15,273 $8,874 $17,182 0.9 ($1,909) 0.7 ($5,184) CZ12 PGE 16.7 2.7 3,594 9 $1,112 $25,496 $13,450 $23,324 1.1 $2,172 0.9 ($2,978) CZ12 SMUD/PGE 16.7 2.7 3,594 9 $537 $12,380 $14,500 $24,558 0.5 ($12,178) 0.8 ($4,028) CZ13 PGE 14.5 2.2 273 0 $551 $12,569 $7,635 $15,518 0.8 ($2,949) 0.5 ($6,560) CZ14 SCE/SCG 14.5 3.2 3,499 0 $1,006 $22,671 $12,471 $21,939 1.0 $732 0.8 ($3,079) CZ14 SDGE 14.5 3.2 3,499 0 $1,351 $32,711 $12,471 $21,939 1.5 $10,772 0.8 ($3,079) CZ15 SCE/SCG 19.2 1.8 551 0 $683 $15,387 $8,134 $16,188 1.0 ($801) 0.5 ($6,677) CZ16 PG&E 18.3 6.3 3,680 24 $1,117 $25,838 $13,274 $23,130 1.1 $2,708 0.8 ($3,161)

10.B.b
Packet Pg. 644 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-Effectiveness Analysis: Single Family New Construction 33 Results
California Energy Codes & Standards | A statewide utility program 2024-03-25

4.5 Greenhouse Gas Reductions
Table 20 and Table 21 present greenhouse gas reductions for the single family and ADU prototypes, respectively. Savings represent average annual savings over the 30-year lifetime of the analysis. Greenhouse gas reductions are greatest for the all-electric Efficiency + PV + Battery package in all cases. For the single family homes, the all-electric Code Minimum case reduces greenhouse gas emissions as much or greater than the mixed fuel Efficiency + PV + Battery package in Climate Zones 1 through 4, 11 through 13, and 16—showcasing the benefit of all-electric construction over even the most ambitious of mixed fuel construction packages evaluated in this study. The trend differs for the ADU where the mixed fuel Efficiency + PV + Battery package results in more greenhouse gas savings than the all-electric Code Minimum in all climate zones except Climate Zones 3, 4, and 13. In most of the climate zones (1, 2, 5 through 12, 15, and 16) the allelectric ADU involves electrification of space heating, cooking, and clothes drying. The space heating loads for the ADU are very low, even in the colder climates, and as a result the greenhouse gas savings from efficiency measures, PV and battery are greater than just code minimum electrification. This is also the case for single family homes in Climate Zones 5 through 10, and 15 where space heating loads are low.

Table 20: Single Family Greenhouse Gas Reductions (metric tons) Climate
Zone
Single Family All-Electric Single Family Mixed Fuel
Code
Minimum
Efficiency
Only
Efficiency +
High
Efficiency
Equipment
Efficiency +
PV
Efficiency +
PV +
Battery
Efficiency +
High
Efficiency
Equipment
Efficiency +
PV +
Battery
CZ01 1.5 1.7 1.8 1.8 2.3 0.8 1.1
CZ02 0.9 1.0 1.1 1.1 1.6 0.5 0.7
CZ03 0.7 0.7 0.8 0.8 1.3 0.2 0.5
CZ04 0.7 0.7 0.8 0.8 1.3 0.2 0.5
CZ05 0.4 0.5 0.6 0.6 1.1 0.2 0.6
CZ06 0.3 0.3 0.3 0.4 0.9 0.1 0.5
CZ07 0.2 0.2 0.3 0.3 0.8 0.1 0.5
CZ08 0.2 0.2 0.3 0.3 0.8 0.1 0.5
CZ09 0.3 0.3 0.3 0.4 0.9 0.1 0.5
CZ10 0.3 0.4 0.4 0.5 1.0 0.1 0.5
CZ11 0.8 0.9 1.0 1.0 1.5 0.4 0.7
CZ12 0.7 0.8 0.9 0.9 1.4 0.4 0.6
CZ13 0.6 0.7 0.8 0.8 1.3 0.2 0.6
CZ14 0.6 0.7 0.8 0.9 1.4 0.2 0.6
CZ15 0.2 0.2 0.3 0.3 0.7 0.1 0.5
CZ16 1.4 1.7 1.7 1.9 2.3 1.0 1.1

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California Energy Codes & Standards | A statewide utility program 2024-03-25 Table 21: ADU Greenhouse Gas Reductions (metric tons)
Climate
Zone
ADU All-Electric ADU Mixed Fuel
Code
Minimum
Efficiency
Only
Efficiency
+ High
Efficiency
Equipment
Efficiency
+ PV
Efficiency
+ PV +
Battery
Efficiency + High Efficiency
Equipment
Efficiency
+ PV +
Battery
CZ01 0.4 0.5 0.5 0.6 1.0 0.2 0.5
CZ02 0.2 0.3 0.3 0.4 0.8 0.1 0.5
CZ03 0.5 0.5 0.6 0.7 1.0 0.1 0.3
CZ04 0.5 0.5 0.5 0.7 1.0 0.1 0.4
CZ05 0.1 0.2 0.2 0.3 0.7 0.0 0.4
CZ06 0.1 0.1 0.1 0.3 0.6 0.0 0.4
CZ07 0.1 0.1 0.1 0.3 0.6 0.0 0.4
CZ08 0.1 0.1 0.1 0.3 0.6 0.0 0.5
CZ09 0.1 0.1 0.1 0.3 0.7 0.0 0.5
CZ10 0.1 0.1 0.2 0.2 0.6 0.0 0.4
CZ11 0.2 0.3 0.3 0.3 0.7 0.1 0.4
CZ12 0.2 0.3 0.3 0.4 0.7 0.1 0.5
CZ13 0.4 0.5 0.5 0.5 0.9 0.1 0.3
CZ14 0.4 0.5 0.5 0.7 1.1 0.1 0.5
CZ15 0.1 0.1 0.1 0.2 0.6 0.0 0.4
CZ16 0.4 0.5 0.5 0.7 1.0 0.2 0.6

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California Energy Codes & Standards | A statewide utility program 2024-03-25

4.6 Sensitivity Analysis
In response to jurisdictional interest, several cases were evaluated under circumstances different than those presented above in order to assess their impact on cost-effectiveness. Altered circumstances include:

1. CARE versus standard tariffs. This comparison is presented for the all-electric Code Minimum and the mixed fuel Efficiency + PV+ Battery packages and shows the impact on On-Bill cost-effectiveness for income qualified utility customers.

2. Infill versus new subdivision single family developments. This comparison applied to the all-electric Code Minimum package demonstrates how costeffectiveness is impacted due to the magnitude of cost savings for all-electric construction from elimination of the natural gas infrastructure.

3. Utility rate escalation factors. The impact on On-Bill cost-effectiveness is presented for the all-electric Code Minimum package from varying the assumptions for escalation of electricity and natural gas utility rates over the 30-year analysis period.

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California Energy Codes & Standards | A statewide utility program 2024-03-25

4.6.1 CARE Rate Comparison
Table 22 and Table 23 present a comparison of On-Bill cost-effectiveness results for CARE tariffs relative to standard IOU tariffs for the all-electric Code Minimum package for the single family and ADU prototypes, respectively. Applying the CARE rates lowers both electric and gas utility bills for the consumer. In the case of the all-electric home, the net impact of CARE rates is improved cost-effectiveness relative to the standard tariffs. This is because the discount on electricity is greater than that for natural gas. The opposite trend occurs for the mixed fuel packages, where the lower CARE rates result in lower utility cost savings and subsequently lower benefit-to-cost ratios.

Table 22: On-Bill Cost-Effectiveness with CARE Tariffs: All-Electric Code Minimum Climate
Zone
Electric
/Gas Utility
Single Family ADU
Standard CARE Standard CARE
B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV CZ01 PGE 0.9 ($268) >1 $3,886 0.7 ($2,077) 1.2 $696
CZ02 PGE 1.6 $2,355 5.1 $5,107 0.7 ($1,742) 1.1 $580
CZ03 PGE 1.0 ($90) 1.7 $1,968 0.0 ($7,581) 0.0 ($4,596) CZ04 PGE 1.3 $979 2.3 $2,619 0.0 ($7,406) 0.0 ($4,526)
CZ05 PGE 1.3 $1,373 2.2 $3,467 0.7 ($1,912) 1.1 $237
CZ05 PGE/SCG 1.4 $1,823 2.5 $3,841 0.9 ($574) 1.4 $1,321 CZ06 SCE/SCG 1.6 $2,339 2.3 $3,535 0.9 ($318) 1.4 $1,225 CZ07 SDGE 1.1 $624 2.1 $3,309 0.6 ($3,298) 0.9 ($627)
CZ08 SCE/SCG 1.7 $2,792 2.3 $3,945 0.9 ($289) 1.4 $1,231 CZ09 SCE 1.7 $2,831 2.4 $4,074 0.9 ($310) 1.4 $1,230
CZ10 SCE/SCG 1.6 $2,642 2.4 $4,083 1.3 $976 1.7 $1,923
CZ10 SDGE 1.4 $1,825 3.0 $4,642 0.8 ($1,084) 1.3 $1,114 CZ11 PGE 1.7 $2,552 5.0 $5,077 1.0 $200 1.6 $1,634
CZ12 PGE 1.9 $3,210 5.0 $5,587 0.7 ($1,710) 1.1 $545
CZ13 PGE 1.5 $1,480 2.7 $2,924 0.0 ($4,131) 0.0 ($2,754) CZ14 SCE/SCG 0.9 ($522) 1.3 $1,191 0.0 ($7,375) 0.0 ($4,754) CZ14 SDGE 0.7 ($1,717) 2.0 $2,295 0.0 ($10,790) 0.0 ($6,496) CZ15 SCE/SCG 1.4 $1,791 1.9 $2,831 1.4 $1,246 1.8 $2,031 CZ16 PG&E 0.2 ($5,394) 0.8 ($351) 0.6 ($2,562) 1.1 $453

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Packet Pg. 648 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-Effectiveness Analysis: Single Family New Construction 37 Results
California Energy Codes & Standards | A statewide utility program 2024-03-25 Table 23: On-Bill Cost-Effectiveness with CARE Tariffs: Mixed Fuel Efficiency + PV+ Battery Package Climate
Zone
Electric
/Gas Utility
Single Family ADU
Standard CARE Standard CARE
B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV CZ01 PGE 1.3 $6,501 0.9 ($2,072) 0.97 ($654) 0.7 ($8,623) CZ02 PGE 1.1 $2,486 0.7 ($5,286) 1.0 $524 0.7 ($7,297)
CZ03 PGE 1.1 $1,104 0.6 ($5,980) 0.9 ($2,899) 0.6 ($8,788) CZ04 PGE 1.0 $456 0.6 ($6,790) 0.9 ($1,625) 0.6 ($8,200) CZ05 PGE 1.1 $2,285 0.7 ($5,646) 1.1 $1,765 0.7 ($6,142) CZ05 PGE/SCG 1.1 $2,154 0.7 ($5,751) 1.1 $1,746 0.7 ($6,157) CZ06 SCE/SCG 1.1 $1,951 0.7 ($5,232) 0.997 ($75) 0.7 ($5,476) CZ07 SDGE 1.6 $9,869 1.1 $1,502 1.4 $9,325 0.9 ($1,935) CZ08 SCE/SCG 1.2 $3,344 0.7 ($4,574) 1.1 $1,141 0.8 ($4,945) CZ09 SCE 1.2 $3,369 0.7 ($4,547) 1.1 $1,272 0.8 ($4,812) CZ10 SCE/SCG 1.3 $4,546 0.8 ($3,683) 0.7 ($4,113) 0.5 ($7,624) CZ10 SDGE 1.8 $14,148 1.3 $4,461 1.2 $3,451 0.8 ($2,615) CZ11 PGE 1.4 $6,523 0.9 ($2,487) 0.9 ($1,909) 0.6 ($7,688) CZ12 PGE 1.2 $3,451 0.7 ($4,560) 1.1 $2,172 0.7 ($6,267) CZ13 PGE 1.3 $5,665 0.8 ($3,372) 0.8 ($2,949) 0.5 ($8,111) CZ14 SCE/SCG 1.3 $5,945 0.8 ($3,074) 1.0 $732 0.8 ($5,341) CZ14 SDGE 1.8 $15,726 1.3 $4,718 1.5 $10,772 1.0 ($1,007) CZ15 SCE/SCG 1.5 $9,078 0.9 ($877) 0.95 ($801) 0.6 ($6,322) CZ16 PG&E 1.3 $5,254 0.8 ($3,523) 1.1 $2,708 0.8 ($5,611)

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California Energy Codes & Standards | A statewide utility program 2024-03-25

4.6.2 Utility Infrastructure Cost Sensitivity
Table 24 compares cost-effectiveness results for the natural gas service line extension cost scenarios that inform the average values presented in Table 8. The average cost scenario reflects the cost-effectiveness results for the single family all-electric Code Minimum package presented in Table 16. Relative to a new subdivision, gas infrastructure cost savings are higher for the infill development case, which translates to higher cost-effectiveness. This is shown by positive costeffectiveness in all metrics except one – On-Bill for Climate Zone 16 – for infill development. Compared to the average cost scenario, there are two cases – OnBill for Climate Zone 4 in PG&E territory and Climate Zone 7 – where the all-electric Code Minimum package is no longer cost-effective based on the new subdivision costs.

Table 24: Single Family Cost-Effectiveness Comparison with Range of Natural Gas Utility Infrastructure Costs:

All-Electric Code Minimum
Climate
Zone
Electric
/Gas Utility
Average New Subdivision Infill Development
On-Bill TDV On-Bill TDV On-Bill TDV
B/C Ratio NPV B/C Ratio NPV B/C
Ratio NPV B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV
CZ01 PGE 0.9 ($268) >1 $5,702 0.6 ($1,492) >1 $4,612 2.2 $4,628 >1 $10,062 CZ02 PGE 1.6 $2,355 >1 $7,711 1.3 $1,131 >1 $6,621 2.8 $7,250 >1 $12,071 CZ03 PGE 0.98 ($90) 25.3 $3,887 0.7 ($1,314) 18.5 $2,797 2.0 $4,806 52.6 $8,247 CZ04 PGE 1.3 $979 >1 $4,494 0.9 ($245) >1 $3,404 2.6 $5,875 >1 $8,854 CZ04 CPAU >1 $10,437 >1 $7,762 >1 $10,437 >1 $7,762 >1 $10,437 >1 $7,762 CZ05 PGE 1.3 $1,373 6.1 $4,633 1.0 $149 4.9 $3,543 2.3 $6,269 11.0 $8,993 CZ05 PGE/SCG 1.4 $1,823 6.1 $4,633 1.1 $599 4.9 $3,543 2.5 $6,719 11.0 $8,993 CZ06 SCE/SCG 1.6 $2,339 4.7 $4,353 1.3 $1,115 3.8 $3,263 2.8 $7,235 8.4 $8,713 CZ07 SDGE 1.1 $624 4.2 $4,211 0.9 ($600) 3.4 $3,121 2.0 $5,519 7.5 $8,571 CZ08 SCE/SCG 1.7 $2,792 4.2 $4,674 1.4 $1,568 3.5 $3,584 2.8 $7,687 7.3 $9,034 CZ09 SCE 1.7 $2,831 5.5 $5,013 1.4 $1,607 4.6 $3,923 2.9 $7,726 9.5 $9,373 CZ10 SCE/SCG 1.6 $2,642 7.4 $5,287 1.3 $1,418 6.1 $4,197 2.7 $7,537 12.6 $9,647 CZ10 SDGE 1.4 $1,825 7.4 $5,287 1.1 $601 6.1 $4,197 2.3 $6,721 12.6 $9,647 CZ11 PGE 1.7 $2,552 >1 $7,153 1.3 $1,328 >1 $6,063 3.0 $7,448 >1 $11,513 CZ12 PGE 1.9 $3,210 >1 $7,504 1.5 $1,986 >1 $6,414 3.1 $8,106 >1 $11,864 CZ12 SMUD/PGE >1 $11,714 >1 $7,504 >1 $10,490 >1 $6,414 >1 $16,610 >1 $11,864 CZ13 PGE 1.5 $1,480 >1 $4,490 1.1 $256 >1 $3,400 3.0 $6,376 >1 $8,850 CZ14 SCE/SCG 0.9 ($522) >1 $4,105 0.7 ($1,746) >1 $3,015 1.8 $4,374 >1 $8,465 CZ14 SDGE 0.7 ($1,717) >1 $4,105 0.5 ($2,941) >1 $3,015 1.5 $3,179 >1 $8,465 CZ15 SCE/SCG 1.4 $1,791 3.0 $3,439 1.1 $567 2.4 $2,349 2.6 $6,687 5.6 $7,799 CZ16 PG&E 0.2 ($5,394) 0.4 ($1,339) 0.0 ($6,618) 0.0 ($2,429) 0.9 ($498) 2.4 $3,021

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California Energy Codes & Standards | A statewide utility program 2024-03-25

4.6.3 Utility Rate Escalation
In this sensitivity analysis, an alternative set of annual utility escalation rates was applied to the gas and electricity savings in select measure packages to show the impact that utility cost changes over time have on cost-effectiveness. This set of rates, detailed in Section 7.2.7, reflects those used by the Energy Commission in their development of the LSC factors for the 2025 code cycle (LSC replaces TDV in the 2025 code cycle). The rates assume steep increases in gas rates starting in 2030. Increased gas rates range from 2% to 6.7% higher than annual rates used in the 2022 code cycle; electricity rates are only marginally (about 0.5%) higher each year.

On-Bill cost-effectiveness results are shown for in Table 25 for the all-electric Code Minimum scenario and Table 26 for the mixed fuel Efficiency + PV + Battery measure package. The alternative rates described above (“2025 LSC”) are shown alongside those reported elsewhere in this report (“CPUC / 2022 TDV”, described in Section 2.1.3) for comparison. In all cases, the 2025 LSC escalation rates improve cost-effectiveness. In some cases, this improvement is enough to change the result from not cost-effective to cost-effective, these cases are summarized below:
• All-Electric Code Minimum package
o Climate Zones 1, 3, 14, and 16 for the single family home o Climate Zones 1, 5 in PG&E/SCG territory, 6, 8, 9, 10 in SDG&E territory, and 16 for the ADU home • Mixed fuel Efficiency + PV + Battery package
o Climate Zones 1, 6, and 15 for the ADU home

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Packet Pg. 651 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-Effectiveness Analysis: Single Family New Construction 40 Results
California Energy Codes & Standards | A statewide utility program 2024-03-25 Table 25: Cost-Effectiveness, 2025 LSC Basis: All-Electric Code Minimum Climate
Zone
Electric
/Gas Utility
Single Family ADU
CPUC / 2022 TDV 2025 LSC CPUC / 2022 TDV 2025 LSC
B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV CZ01 PGE 0.9 ($268) >1 $13,867 0.7 ($2,077) 1.2 $833
CZ02 PGE 1.6 $2,355 >1 $10,458 0.7 ($1,742) 0.95 ($228) CZ03 PGE 0.98 ($90) >1 $4,883 0.0 ($7,581) 0.0 ($4,465) CZ04 PGE 1.3 $979 >1 $5,728 0.0 ($7,406) 0.0 ($4,466)
CZ04 CPAU >1 $10,437 >1 $17,647 6.9 $2,592 20.7 $8,704
CZ05 PGE 1.3 $1,373 5.3 $5,148 0.7 ($1,912) 0.8 ($1,386) CZ05 PGE/SCG 1.4 $1,823 13.5 $5,884 0.9 ($574) 1.2 $807 CZ06 SCE/SCG 1.6 $2,339 4.0 $4,751 0.9 ($318) 1.2 $630
CZ07 SDGE 1.1 $624 1.9 $3,008 0.6 ($3,298) 0.7 ($2,394) CZ08 SCE/SCG 1.7 $2,792 3.0 $4,650 0.9 ($289) 1.1 $591
CZ09 SCE 1.7 $2,831 4.0 $5,233 0.9 ($310) 1.2 $634
CZ10 SCE/SCG 1.6 $2,642 5.4 $5,700 1.3 $976 1.9 $2,147
CZ10 SDGE 1.4 $1,825 7.4 $6,038 0.8 ($1,084) 1.0 $102
CZ11 PGE 1.7 $2,552 >1 $9,997 1.0 $200 1.6 $1,669
CZ12 PGE 1.9 $3,210 >1 $10,077 0.7 ($1,710) 0.9 ($430)
CZ12 SMUD/PGE >1 $11,714 >1 $19,028 5.7 $3,797 >1 $5,367 CZ13 PGE 1.5 $1,480 >1 $5,987 0.0 ($4,131) 0.0 ($1,228) CZ14 SCE/SCG 0.9 ($522) 6.0 $3,876 0.0 ($7,375) 0.0 ($4,363) CZ14 SDGE 0.7 ($1,717) >1 $4,799 0.0 ($10,790) 0.0 ($6,285) CZ15 SCE/SCG 1.4 $1,791 2.2 $3,214 1.4 $1,246 1.9 $2,210 CZ16 PG&E 0.2 ($5,394) >1 $8,516 0.6 ($2,562) 1.2 $629

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Packet Pg. 652 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-Effectiveness Analysis: Single Family New Construction 41 Results
California Energy Codes & Standards | A statewide utility program 2024-03-25 Table 26: Cost-Effectiveness, 2025 LSC Basis: Mixed Fuel Efficiency + PV + Battery Climate
Zone
Electric
/Gas Utility
Single Family ADU
CPUC / 2022 TDV 2025 LSC CPUC / 2022 TDV 2025 LSC
B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV B/C Ratio NPV CZ01 PGE 1.3 $6,501 1.6 $12,598 1.0 ($654) 1.1 $1,379
CZ02 PGE 1.1 $2,486 1.3 $4,914 1.0 $524 1.1 $2,202
CZ03 PGE 1.1 $1,104 1.1 $2,287 0.9 ($2,899) 0.9 ($1,962) CZ04 PGE 1.0 $456 1.1 $1,645 0.9 ($1,625) 0.97 ($594)
CZ04 CPAU 0.2 ($16,295) 0.2 ($15,990) 0.4 ($13,536) 0.4 ($13,067) CZ05 PGE 1.1 $2,285 1.2 $3,855 1.1 $1,765 1.1 $3,074
CZ05 PGE/SCG 1.1 $2,154 1.2 $3,639 1.1 $1,746 1.1 $3,043 CZ06 SCE/SCG 1.1 $1,951 1.2 $3,420 1.0 ($75) 1.1 $1,347 CZ07 SDGE 1.6 $9,869 1.6 $9,831 1.4 $9,325 1.4 $9,070
CZ08 SCE/SCG 1.2 $3,344 1.3 $4,750 1.1 $1,141 1.1 $2,674 CZ09 SCE 1.2 $3,369 1.3 $4,812 1.1 $1,272 1.1 $2,793
CZ10 SCE/SCG 1.3 $4,546 1.4 $6,006 0.7 ($4,113) 0.8 ($3,317) CZ10 SDGE 1.8 $14,148 1.8 $13,960 1.2 $3,451 1.2 $3,290 CZ11 PGE 1.4 $6,523 1.5 $8,837 0.9 ($1,909) 0.96 ($740) CZ12 PGE 1.2 $3,451 1.3 $5,457 1.1 $2,172 1.2 $3,844
CZ12 SMUD/PGE 0.3 ($13,066) 0.4 ($11,864) 0.5 ($12,178) 0.5 ($11,196) CZ13 PGE 1.3 $5,665 1.4 $7,099 0.8 ($2,949) 0.9 ($2,288) CZ14 SCE/SCG 1.3 $5,945 1.4 $7,729 1.0 $732 1.1 $2,213
CZ14 SDGE 1.8 $15,726 1.8 $15,707 1.5 $10,772 1.5 $10,493 CZ15 SCE/SCG 1.5 $9,078 1.7 $10,819 1.0 ($801) 1.0 $204 CZ16 PG&E 1.3 $5,254 1.5 $10,999 1.1 $2,708 1.2 $4,956

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Packet Pg. 653 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-Effectiveness Analysis: Single Family New Construction 42 Summary
California Energy Codes & Standards | A statewide utility program 2024-03-25 5 Summary
The purpose of this study was to examine and document the code compliance and cost-effectiveness impacts of improving performance among single family new construction – both standard sized homes and ADUs. To this end, the Reach Codes Team evaluated packages of energy efficiency measures as well as packages combining energy efficiency with solar PV generation and battery storage, simulated them in building modeling software, and gathered costs to determine the cost-effectiveness of multiple scenarios. The Reach Codes Team coordinated with multiple utilities, cities, and building community experts to develop a set of assumptions considered reasonable in the current market. Changing assumptions, such as the period of analysis, measure selection, cost assumptions, energy escalation rates, or utility tariffs are likely to change results.

Table 27 (single family) and Table 28 (ADU) summarize results for each prototype and depict the EDR1 compliance margins achieved for each climate zone and package. Because local reach codes must both exceed the energy code (i.e., have a positive compliance margin in the performance approach) and be cost-effective, the Reach Codes Team highlighted cells meeting these two requirements to help clarify the upper boundary for potential reach code policies.

All results presented in this study have a positive compliance margin. • Cells highlighted in green depict a positive compliance margin and cost-effective results using both On-Bill and TDV approaches.
• Cells highlighted in yellow depict a positive compliance and cost-effective results using either the On-Bill or TDV approach.
• Cells not highlighted depict a package that was not cost-effective using either the On-Bill or TDV approach. • Cells highlighted in grey depict the high efficiency equipment packages where cost-effectiveness was not evaluated.

The following are key takeaways and recommendations from the analysis.

Conclusions and Discussion:
• All-electric buildings have lower GHG emissions than mixed fuel buildings, due to the clean power sources currently available from California’s power providers as well as accounting for increased penetration of renewables in the future. Almost all the all-electric packages evaluated resulted in greater GHG emission savings than the mixed fuel packages, with the exception of the mixed fuel package with battery storage in climate zones with low heating loads. The Reach Codes Team found code-compliant, all-electric new construction to be feasible and cost-effective based on TDV for single family homes in all cases except Climate Zone 16.
• All-electric single family new construction was On-Bill cost-effective in all cases except Climate Zones 1, 3, 14, and 16.
• The all-electric ADU home was cost-effective based on TDV in all cases except in Climate Zones 3, 4, 13, and 14 where the higher cost of installing a ducted HPWH instead of the prescriptively required gas tankless water heater outweigh the resulting energy cost savings. In the other climate zones there were first cost savings for installing a heat pump space heater instead of gas furnace, contributing to an overall TDV cost-effective result. • Few cases were cost-effective On-Bill for the ADU.
• All-electric code minimum construction results in an increase in first year utility costs relative to a mixed fuel home, except for CPAU and SMUD where electricity rates are much lower than for the IOUs. The addition of efficiency measures, market dominant HPWHs that meet NEEA’s Advanced Water Heating Specification, high efficiency heat pumps, increased PV, and batteries all reduce utility costs, and a combination of these options was found to reduce annual utility costs relative to a mixed fuel home in all cases. • Under NBT, utility cost savings for increasing PV system size beyond code minimum are substantially less than under prior net energy metering rules (NEM 2.0); however, savings are sufficient to be On-Bill costeffective in all climate zones for the all-electric single family home. Coupling PV with battery systems increases utility cost savings as a result of improved on-site utilization of PV generation and fewer exports to the grid.

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California Energy Codes & Standards | A statewide utility program 2024-03-25 • Applying CARE rates in the IOU territories increases improves On-Bill cost-effectiveness for all-electric buildings, as compared to the same case under standard rates, due to higher utility cost savings compared to a code compliant mixed fuel building also on a CARE rate, improving On-Bill cost-effectiveness. This is due to the CARE discount on electricity being higher than that on gas. • If gas tariffs are assumed to increase substantially over time, in-line with the escalation assumption from the 2025 LSC development, all-electric new construction was found to be On-Bill cost-effective in almost all scenarios over the 30-year analysis period. There is much uncertainty surrounding future tariff structures as well as escalation values. While it’s clear that gas rates will increase, how much and how quickly is not known.

Electricity tariff structures are expected to evolve over time, and the CPUC has an active proceeding to adopt an income-graduated fixed charge that benefits low-income customers and supports electrification measures.21 The CPUC will make a decision in mid-2024 and the new rates are expected to be in place later that year or in 2025. While the anticipated impact of this rate change is lower volumetric electricity rates, the rate design is not finalized. While lower volumetric electricity rates provide many benefits including incentivizing electrification, it also will make building efficiency measures harder to justify as cost-effective due to lower utility bill cost savings.

Recommendations:
• A reach code with a single performance target based on source energy (EDR1) can be structured to strongly encourage electrification. This approach requires equivalent performance for all buildings and allows mixed fuel buildings which minimizes the risk of violating federal preemption. Below are examples of how a reach code for single family homes could be setup based on the results summarized in Table 27. o A jurisdiction in Climate Zone 12 could set a performance target at an EDR1 margin of 11.5 (the EDR1 margin for the all-electric Code Minimum package). Any all-electric home meeting or exceeding the prescriptive requirements would comply, and a mixed fuel home would likely need to incorporate a combination of efficiency measures and a battery system to comply. o Similarly, a jurisdiction in Climate Zone 7 may consider setting a performance target of 2.8 EDR1 margin (also the EDR1 margin for the all-electric Code Minimum package). Any all-electric home meeting or exceeding the prescriptive requirements would comply, but a mixed fuel home would likely be able to comply with only a suite of above-code efficiency measures (no battery). Alternatively, a higher EDR1 margin target of 5 would incentivize more energy efficiency or additional PV for allelectric construction, and mixed fuel construction would likely need to incorporate a battery system to comply.
o A jurisdiction in Climate Zone 16 may want to set a performance target at an EDR1 margin of 20.5 (the EDR1 margin for the mixed fuel efficiency + PV + battery package). This would establish a target that a mixed fuel home could cost-effectively meet, likely only after incorporating a combination of efficiency measures and a battery system, and that an all-electric home could easily meet. • The 2022 Title 24 code’s new source energy metric combined with the heat pump baseline encourage allelectric construction, providing an incentive that allows for some amount of prescriptively required building efficiency to be traded off, still meeting minimum code compliance. This compliance benefit for all-electric homes highlights a unique opportunity for jurisdictions to incorporate efficiency into all-electric reach codes.

Efficiency and electrification have symbiotic benefits and are both critical for decarbonization of buildings. As demand on the electric grid is increased through electrification, efficiency can reduce the negative impacts of additional electricity demand on the grid, reducing the need for increased generation and storage capacity, as well as the need to upgrade upstream transmission and distribution equipment. The Reach Codes Team recommends that jurisdictions adopting a reach code for single family buildings also include an efficiency requirement with EDR1 margins at minimum consistent with the all-electric code minimum package results in Table 27.
21 https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/electric-costs/demand-response-dr/demand-flexibility-rulemaking

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California Energy Codes & Standards | A statewide utility program 2024-03-25 • The code compliance margins for the ADU all-electric code minimum package are lower than for the single family prototype; code compliance and cost-effectiveness can be more challenging for smaller dwelling units.

As a result, the Reach Codes Team does not recommend EDR1 targets above those reported for the allelectric Code Minimum package in Table 28.

This report documents the key results and conclusions from the Reach Codes Team analysis. A full dataset of all results can be downloaded at https://localenergycodes.com/content/resources. Results alongside policy options can also be explored using the Cost-effectiveness Explorer at https://explorer.localenergycodes.com/.

Table 27: Summary of Single Family EDR1 Margins and Cost-Effectiveness Climate
Zone
Electric
/Gas Utility
All-Electric Mixed Fuel
Code
Minimum Efficiency
Efficiency +
High
Efficiency
Equipment
Efficiency
+ PV
Efficiency
+ PV +
Battery
Efficiency +
High
Efficiency
Equipment
Efficiency
+ PV +
Battery
CZ01 PGE 25.8 29.1 31.4 32.6 41.4 14.8 22.6
CZ02 PGE 14.0 16.3 18.0 18.9 28.3 9.1 14.1
CZ03 PGE 9.1 10.6 12.2 13.1 24.2 3.6 12.8
CZ04 PGE 8.8 10.4 11.9 12.8 24.6 3.8 13.2
CZ04 CPAU 8.8 10.4 11.9 12.8 24.6 3.8 13.2
CZ05 PGE 6.5 7.9 10.2 10.8 23.3 5.2 14.8
CZ05 PGE/SCG 6.5 7.9 10.2 10.8 23.3 5.2 14.8
CZ06 SCE/SCG 4.2 5.3 6.6 8.4 24.6 4.0 18.3
CZ07 SDGE 2.8 3.6 4.8 6.9 23.6 3.2 18.7
CZ08 SCE/SCG 2.1 2.9 4.2 5.6 21.3 2.7 17.1
CZ09 SCE/SCG 3.6 4.4 5.7 7.1 21.8 3.2 16.2
CZ10 SCE/SCG 4.8 5.8 7.2 8.5 21.9 3.9 14.4
CZ10 SDGE 4.8 5.8 7.2 8.5 21.9 3.9 14.4
CZ11 PGE 11.4 13.4 15.0 15.6 24.5 7.7 12.9
CZ12 PGE 11.5 13.3 14.8 15.5 25.2 7.2 13.2
CZ12 SMUD/PGE 11.5 13.3 14.8 15.5 25.2 7.2 13.2
CZ13 PGE 8.3 10.3 11.9 12.3 22.3 4.1 12.3
CZ14 SCE/SCG 8.8 11.5 13.2 14.3 24.7 4.6 13.4
CZ14 SDGE 8.8 11.5 13.2 14.3 24.7 4.6 13.4
CZ15 SCE/SCG 0.9 2.4 3.7 3.8 15.7 3.5 13.5
CZ16 PG&E 21.3 25.6 27.0 29.1 37.5 16.3 20.4

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California Energy Codes & Standards | A statewide utility program 2024-03-25 Table 28: Summary of ADU EDR1 Margins and Cost-Effectiveness Climate
Zone
Electric
/Gas Utility
All-Electric Mixed Fuel
Code
Minimum Efficiency
Efficiency +
High
Efficiency
Equipment
Efficiency
+ PV
Efficiency
+ PV +
Battery
Efficiency +
High
Efficiency
Equipment
Efficiency
+ PV +
Battery
CZ01 PGE 11.9 15.7 18.5 19.3 33.7 2.9 18.5
CZ02 PGE 5.7 7.9 9.7 10.8 25.6 -4.7 16.6
CZ03 PGE 2.9 4.0 5.9 7.1 23.2 4.0 11.8
CZ04 PGE 2.4 3.9 5.5 6.8 23.6 4.2 13.3
CZ04 CPAU 2.4 3.9 5.5 6.8 23.6 4.2 13.3
CZ05 PGE 1.8 2.9 4.8 6.4 24.0 -12.1 16.9
CZ05 PGE/SCG 1.8 2.9 4.8 6.4 24.0 -12.1 16.9
CZ06 SCE/SCG 0.5 1.3 2.6 5.0 25.7 -15.6 19.8
CZ07 SDGE 0.1 0.9 2.1 5.0 26.4 -16.5 20.3
CZ08 SCE/SCG 0.1 0.7 1.8 4.2 25.1 -15.3 20.4
CZ09 SCE 0.4 1.1 2.3 4.5 25.0 -14.4 19.6
CZ10 SCE/SCG 1.0 2.0 3.5 5.4 25.3 -11.9 19.0
CZ10 SDGE 1.0 2.0 3.5 5.4 25.3 -11.9 19.0
CZ11 PGE 4.6 7.0 8.6 9.6 25.1 -3.5 17.6
CZ12 PGE 4.6 6.6 8.3 9.3 24.5 -5.6 16.7
CZ12 SMUD/PGE 4.6 6.6 8.3 9.3 24.5 -5.6 16.7
CZ13 PGE 3.1 5.5 6.9 7.8 25.2 4.4 14.5
CZ14 SCE/SCG 3.5 6.3 8.0 9.6 26.9 5.1 14.5
CZ14 SDGE 3.5 6.3 8.0 9.6 26.9 5.1 14.5
CZ15 SCE/SCG 0.0 2.2 2.6 4.4 25.3 -9.3 19.2
CZ16 PG&E 11.2 14.7 15.7 18.3 33.7 2.9 18.3

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Packet Pg. 657 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Single Family New Construction 46 References
California Energy Codes & Standards | A statewide utility program 2024-03-25 6 References
Barbose, G., Darghouth, N., O'Shaughnessy, E., & Forrester, S. (2021, October). Tracking the Sun. Pricing and Design Trends for Distributed Photovoltaic Systems in the United States 2021 Edition. Retrieved from https://emp.lbl.gov/tracking-the-sun
Barbose, Galen; Darghouth, Naim; O'Shaughnessy, Eric; Forrester, Sydney. (2022). Tracking the Sun: Pricing and Design Trends for Distributed Photovoltaic Systems in the United States 2022 Edition. Retrieved from https://emp.lbl.gov/tracking-the-sun
California Energy Commission. (2017). Rooftop Solar PV System. Measure number: 2019-Res-PV-D Prepared by Energy and Environmental Economics, Inc. Retrieved from https://efiling.energy.ca.gov/getdocument.aspx?tn=221366 California Energy Commission. (2018). 2019 Alternative Calculation Method Approval Manual for the 2019 Building Energy Efficiency Standards. Retrieved from https://www.energy.ca.gov/publications/2018/2019-alternativecalculation-method-approval-manual-2019-building-energy California Energy Commission. (2021a). Express Terms for the Proposed Revisions to 2022 Title 24, Part 1 and Part 6.

Retrieved from https://efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=21-BSTD-01 California Energy Commission. (2021b). Final Express Terms for the Proposed Revisions to the 2022 Energy Code Reference Appendices. Retrieved from https://efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=21- BSTD-01
California Energy Commission. (2022, Feb). 2022 Single-Family Residential Alternative Calculation Method Reference Manual. Retrieved from https://www.energy.ca.gov/publications/2022/2022-single-family-residentialalternative-calculation-method-reference-manual California Public Utilities Commission. (2021a). Utility Costs and Affordability of the Grid of the Future: An Evaluation of Electric Costs, Rates, and Equity Issues Pursuant to P.U. Code Section 913.1. Retrieved from https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/office-of-governmental-affairsdivision/reports/2021/senate-bill-695-report-2021-and-en-banc-whitepaper_final_04302021.pdf California Public Utilities Commission. (2021b). Database for Energy-Efficient resources (DEER2021 Update). Retrieved April 13, 2021, from http://www.deeresources.com/index.php/deer-versions/deer2021 California Public Utilities Commission. (2022). Proposed Decision of Commissioner Rechtschaffen: PHASE III DECISION

ELIMINATING GAS LINE EXTENSION ALLOWANCES, TEN-YEAR REFUNDABLE PAYMENT OPTION, AND FIFTY PERCENT DISCOUNT PAYMENT OPTION UNDER GAS LINE EXTENSION RULES.

Department of Energy. (2022). Preliminary Analysis Technical Support Document: Energy Efficiency Program for Consumer Products and Commercial and Industrial Equipment. Retrieved from https://www.regulations.gov/document/EERE-2017-BT-STD-0019-0018 E-CFR. (2020). https://www.ecfr.gov/cgibin/retrieveECFR?gp=&SID=8de751f141aaa1c1c9833b36156faf67&mc=true&n=pt10.3.431&r=PART&ty=HTM L#se10.3.431_197. Retrieved from Electronic Code of Federal Regulations: https://www.ecfr.gov/cgibin/retrieveECFR?gp=&SID=8de751f141aaa1c1c9833b36156faf67&mc=true&n=pt10.3.431&r=PART&ty=HTM L#se10.3.431_197
Energy & Environmental Economics. (2019). Residential Building Electrification in California. Retrieved from https://www.ethree.com/wpcontent/uploads/2019/04/E3_Residential_Building_Electrification_in_California_April_2019.pdf Energy + Environmental Economics. (2020). Time Dependent Valuation of Energy for Developing Building Efficiency Standards: 2022 Time Dependent Valuation (TDV) and Source Energy Metric Data Sources and Inputs.

E-Source companies. (2020). Behind-the-Meter Battery Market Study. Prepared for San Diego Gas & Electric.

Retrieved from https://www.etcc-ca.com/reports/behind-meter-battery-market-study?dl=1582149166

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Packet Pg. 658 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Single Family New Construction 47 References
California Energy Codes & Standards | A statewide utility program 2024-03-25 Horii, B., Cutter, E., Kapur, N., Arent, J., & Conotyannis, D. (2014). Time Dependent Valuation of Energy for Developing Building Energy Efficiency Standards.

Proctor, J., Wilcox, B., & Chitwood, R. (2018). Central Valley Research Homes Project. California Energy Commission.

Retrieved from
https://www.researchgate.net/publication/342135376_Central_Valley_Research_Homes_Project_-- _Final_CEC_Report
RSMeans. (2022). Cost data obtained from the 2022 RSMeans online database.

Statewide CASE Team. (2017). Residential High Performance Windows & Doors Codes and Standards Enhancement (CASE) Initiative 2019 California Energy Code. Retrieved from http://title24stakeholders.com/wpcontent/uploads/2017/09/2019-T24-CASE-Report_Res-Windows-and-Doors_Final_September-2017.pdf Statewide CASE Team. (2018). Energy Savings Potential and Cost-Effectiveness Analysis of High Efficiency Windows in California. Prepared by Frontier Energy. Retrieved from https://www.etcc-ca.com/reports/energy-savingspotential-and-cost-effectiveness-analysis-high-efficiency-windows-california Statewide CASE Team. (2020a). Nonresidential High Performance Envelope Codes and Standards Enhancement (CASE) Initiative 2022 California Energy Code. Prepared by Energy Solutions. Retrieved from https://title24stakeholders.com/wp-content/uploads/2020/10/2020-T24-NR-HP-Envelope-Final-CASEReport.pdf Statewide CASE Team. (2020b). Residential Energy Savings and Process Improvements for Additions and Alterations Codes and Standards Enhancement (CASE) Initiative 2022 California Energy Code. Prepared by Frontier Energy. Retrieved from https://title24stakeholders.com/wp-content/uploads/2020/08/SF-Additions-andAlterations_Final_-CASE-Report_Statewide-CASE-Team.pdf Statewide CASE Team. (2020c). Multifamily All-Electric Codes and Standards Enhancement (CASE) Initiative 2022 California Energy Code. Prepared by TRC.

Statewide Reach Codes Team. (2019, August). 2019 Cost-effectiveness Study: Low-Rise Residential New Construction.

Prepared for Pacific Gas and Electric Company. Prepared by Frontier Energy. Retrieved from https://localenergycodes.com/download/800/file_path/fieldList/2019%20Res%20NC%20Reach%20Codes Statewide Reach Codes Team. (2021a). Cost-Effectiveness Analysis: Batteries in Single Family Homes. Prepared by Frontier Energy. Retrieved from
https://localenergycodes.com/download/930/file_path/fieldList/Single%20Family%20Battery%20Costeff%20Report.pdf Statewide Reach Codes Team. (2021b). 2020 Reach Code Cost-Effectiveness Analysis: Detached Accessory Dwelling Units. Prepared by TRC. Retrieved from
https://localenergycodes.com/download/760/file_path/fieldList/2019%20New%20Detached%20ADUs%20Co st-effectiveness%20Report.pdf
Statewide Reach Codes Team. (tbd). 2022 Cost-Effectiveness Study: Existing Single Family Building Upgrades.

Prepared by Frontier Energy. Not yet published.

TRC, P. E. (2021). 2020 Reach Code Cost-Effectiveness Analysis: Detached Accessory Dwelling Units.

UC Berkeley Center for Community Innovation. (2021). Implementing the Backyard Revolution: Perspectives of California’s ADU Owners.

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California Energy Codes & Standards | A statewide utility program 2024-03-25 7 Appendices

7.1 Map of California Climate Zones
Climate zone geographical boundaries are depicted in Figure 4. The map in Figure 4 along with a zip-code search directory is available at: https://ww2.energy.ca.gov/maps/renewable/building_climate_zones.html Figure 4: Map of California climate zones.

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7.2 Utility Rate Schedules
The Reach Codes Team used the CA IOU and POU rate tariffs detailed below to determine the On-Bill savings for each package. The California Climate Credit was applied for both electricity and natural gas service for the IOUs using the 2023 credits shows below.22 The credits were applied to reduce the total calculated annual bill, including any fixed fees or minimum bill amounts.

Electricity rates reflect the most recently approved tariffs. Monthly gas rates were estimated based on recent gas rates (November 2023) and a curve to reflect how natural gas prices fluctuate with seasonal supply and demand. The seasonal curve was estimated from monthly residential tariffs between 2014 and 2023 (between 2017 and 2023 for CPAU). 12-month curves were created from monthly gas rates for each of the ten years (seven years for CPAU).

These annual curves were then averaged to arrive at an average normalized annual curve. This was conducted separately for baseline and excess energy rates. Costs used in this analysis were then derived by establishing the most recent baseline and excess rate from the latest tariff as a reference point (November 2023), and then using the normalized curve to estimate the cost for the remaining months relative to the reference point rate. 22 https://www.cpuc.ca.gov/industries-and-topics/natural-gas/greenhouse-gas-cap-and-trade-program/california-climate-credit

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7.2.1 Pacific Gas & Electric
The following pages provide details on the PG&E electricity and natural gas tariffs applied in this study. Table 29 describes the baseline territories that were assumed for each climate zone. A net surplus compensation rate of $0.07051/ kWh was applied to any net annual electricity generation based on a one-year average of the rates between December 2022 and November 2023.

Table 29: PG&E Baseline Territory by Climate Zone
Climate
Zone
Baseline
Territory
CZ01 V
CZ02 X
CZ03 T
CZ04 X
CZ05 T
CZ11 R
CZ12 S
CZ13 R
CZ16 Y
The PG&E monthly gas rate for G-1 in $/therm was applied on a monthly basis according to the rates shown in Table

30. These rates are based on applying a normalization curve to the November 2023 tariff based on ten years of historical gas data. Corresponding CARE rates reflect the 20 percent discount per the GL-1 tariff.

Table 30: PG&E Monthly Gas Rate ($/therm)
Month Total Charge
Baseline Excess
January $2.05 $2.43
February $2.08 $2.46
March $1.92 $2.31
April $1.80 $2.20
May $1.77 $2.18
June $1.78 $2.18
July $1.80 $2.20
August $1.85 $2.26
September $1.92 $2.33
October $1.99 $2.40
November $2.06 $2.46
December $2.05 $2.44

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7.2.2 Southern California Edison
The following pages provide details on the SCE electricity tariffs applied in this study. Table 31 describes the baseline territories that were assumed for each climate zone. A net surplus compensation rate of $ 0.06030/ kWh was applied to any net annual electricity generation based on a one-year average of the rates between December 2022 and November 2023.

Table 31: SCE Baseline Territory by Climate Zone
Climate
Zone
Baseline
Territory
CZ06 6
CZ08 8
CZ09 9
CZ10 10
CZ14 14
CZ15 15

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7.2.3 Southern California Gas
Following are the SoCalGas natural gas tariffs applied in this study. Table 32 describes the baseline territories that were assumed for each climate zone.

Table 32: SoCalGas Baseline Territory by Climate Zone
Climate
Zone
Baseline
Territory
CZ05 2
CZ06 1
CZ08 1
CZ09 1
CZ10 1
CZ14 2
CZ15 1
The SoCalGas monthly gas rate in $/therm was applied on a monthly basis according to the rates shown in Table 33.

These rates are based on applying a normalization curve to the November 2023 tariff based on ten years of historical gas data. Long-term historical natural gas rate data was only available for SoCalGas’ procurement charges.23 The baseline and excess transmission charges were found to be consistent over the course of a year and applied for the entire year based on 2023 rates. CARE rates reflect the 20 percent discount per the GR tariff.

Table 33: SoCalGas Monthly Gas Rate ($/therm)
Month Procurement
Charge
Transportation Charge Total Charge
Baseline Excess Baseline Excess
January $0.72 $0.86 $1.31 $1.92 $2.36
February $0.50 $0.86 $1.31 $1.57 $2.02
March $0.44 $0.86 $1.31 $1.48 $1.93
April $0.39 $0.86 $1.31 $1.39 $1.84
May $0.41 $0.86 $1.31 $1.43 $1.87
June $0.46 $0.86 $1.31 $1.49 $1.93
July $0.47 $0.86 $1.31 $1.51 $1.96
August $0.51 $0.86 $1.31 $1.58 $2.03
September $0.46 $0.86 $1.31 $1.52 $1.96
October $0.45 $0.86 $1.31 $1.48 $1.92
November $0.48 $0.86 $1.31 $1.54 $1.99
December $0.57 $0.86 $1.31 $1.63 $2.08
23 The SoCalGas procurement and transmission charges were obtained from the following site: https://www.socalgas.com/for-yourbusiness/energy-market-services/gas-prices RES2023.xlsx (live.com)

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7.2.4 San Diego Gas & Electric
Following are the SDG&E electricity and natural gas tariffs applied in this study. Table 34 describes the baseline territories that were assumed for each climate zone. A net surplus compensation rate of $0.04542/ kWh was applied to any net annual electricity generation based on a one-year average of the rates between December 2022 and November 2023.

Table 34: SDG&E Baseline Territory by Climate Zone
Climate
Zone
Baseline
Territory
CZ07 Coastal
CZ10 Inland
CZ14 Mountain
The SDG&E monthly gas rate in $/therm was applied on a monthly basis according to the rates shown in Table

35. These rates are based on applying a normalization curve to the November 2023 tariff based on ten years of historical gas data. CARE rates reflect the 20 percent discount per the G-CARE tariff.

Table 35: SDG&E Monthly Gas Rate ($/therm)
Month Total Charge
Baseline Excess
January $2.34 $2.63
February $2.28 $2.57
March $2.21 $2.51
April $2.14 $2.45
May $2.18 $2.48
June $2.23 $2.55
July $2.26 $2.57
August $2.32 $2.62
September $2.26 $2.59
October $2.21 $2.55
November $2.24 $2.57
December $2.38 $2.70

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7.2.5 City of Palo Alto Utilities
Following are the CPAU electricity and natural gas tariffs applied in this study. The CPAU monthly gas rate in $/therm was applied on a monthly basis according to the rates shown in Table 36. These rates are based on applying a normalization curve to the October 2023 tariff based on seven years of historical gas data. The monthly service charge applied was $14.01 per month per the November 2023 G-1 tariff.

Table 36: CPAU Monthly Gas Rate ($/therm)
Month G1
Volumetric
Total
Baseline
G1
Volumetric
Total
Excess
January $1.83532 $3.35639
February $1.38055 $2.59947
March $1.32506 $2.47695
April $1.29680 $2.44038
May $1.29511 $2.43804
June $1.32034 $2.45406
July $1.35688 $2.61519
August $1.40696 $2.67944
September $1.42130 $2.70301
October $1.42310 $2.48300
November $1.46286 $2.45547
December $1.62415 $2.62128

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California Energy Codes & Standards | A statewide utility program 2024-03-25

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California Energy Codes & Standards | A statewide utility program 2024-03-25

7.2.6 Sacramento Municipal Utilities District (Electric Only) Following are the SMUD electricity tariffs applied in this study. The rates effective January 2023 were used.

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California Energy Codes & Standards | A statewide utility program 2024-03-25

7.2.7 Fuel Escalation Assumptions
The average annual escalation rates in Table 37 were used in this study. These are based on assumptions from the CPUC 2021 En Banc hearings on utility costs through 2030 (California Public Utilities Commission, 2021a). Escalation rates through the remainder of the 30-year evaluation period are based on the escalation rate assumptions within the 2022 TDV factors. No data was available to estimate electricity escalation rates for CPAU and SMUD, therefore electricity escalation rates for PG&E and statewide natural gas escalation rates were applied. Table 38 presents the average annual escalation rates used in the utility rate escalation sensitivity analysis shown in Section 4.6.3. Rates were applied for the same 30-year period and are based on the escalation rate assumptions within the 2025 LSC factors from 2027 through 2053.24 These rates were developed for electricity use statewide (not utility-specific) and assume steep increases in gas rates in the latter half of the analysis period. Data was not available for years 2024, 2025, and 2026 and so the CPUC En Banc assumptions were applied for those years using the average rate across the three IOUs for statewide electricity escalation.

Table 37: Real Utility Rate Escalation Rate Assumptions, CPUC En Banc and 2022 TDV Basis
24 https://www.energy.ca.gov/files/2025-energy-code-hourly-factors. Actual escalation factors were provided by consultants E3.

Year
Statewide Natural
Gas Residential
Average Rate
(%/year, real)
Electric Residential Average Rate
(%/year, real)

PG&E SCE SDG&E
2024 4.6% 1.8% 1.6% 2.8%
2025 4.6% 1.8% 1.6% 2.8%
2026 4.6% 1.8% 1.6% 2.8%
2027 4.6% 1.8% 1.6% 2.8%
2028 4.6% 1.8% 1.6% 2.8%
2029 4.6% 1.8% 1.6% 2.8%
2030 4.6% 1.8% 1.6% 2.8%
2031 2.0% 0.6% 0.6% 0.6%
2032 2.4% 0.6% 0.6% 0.6%
2033 2.1% 0.6% 0.6% 0.6%
2034 1.9% 0.6% 0.6% 0.6%
2035 1.9% 0.6% 0.6% 0.6%
2036 1.8% 0.6% 0.6% 0.6%
2037 1.7% 0.6% 0.6% 0.6%
2038 1.6% 0.6% 0.6% 0.6%
2039 2.1% 0.6% 0.6% 0.6%
2040 1.6% 0.6% 0.6% 0.6%
2041 2.2% 0.6% 0.6% 0.6%
2042 2.2% 0.6% 0.6% 0.6%
2043 2.3% 0.6% 0.6% 0.6%
2044 2.4% 0.6% 0.6% 0.6%
2045 2.5% 0.6% 0.6% 0.6%
2046 1.5% 0.6% 0.6% 0.6%
2047 1.3% 0.6% 0.6% 0.6%
2048 1.6% 0.6% 0.6% 0.6%
2049 1.3% 0.6% 0.6% 0.6%
2050 1.5% 0.6% 0.6% 0.6%
2051 1.8% 0.6% 0.6% 0.6%
2052 1.8% 0.6% 0.6% 0.6%
2053 1.8% 0.6% 0.6% 0.6%

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California Energy Codes & Standards | A statewide utility program 2024-03-25 Table 38: Real Utility Rate Escalation Rate Assumptions, 2025 LSC Basis Year
Statewide Natural
Gas Residential
Average Rate
(%/year, real)
Statewide
Electricity
Residential
Average Rate
(%/year, real)
2024 4.6% 2.1%
2025 4.6% 2.1%
2026 4.6% 2.1%
2027 4.2% 0.6%
2028 3.2% 1.9%
2029 3.6% 1.6%
2030 6.6% 1.3%
2031 6.7% 1.0%
2032 7.7% 1.2%
2033 8.2% 1.1%
2034 8.2% 1.1%
2035 8.2% 0.9%
2036 8.2% 1.1%
2037 8.2% 1.1%
2038 8.2% 1.0%
2039 8.2% 1.1%
2040 8.2% 1.1%
2041 8.2% 1.1%
2042 8.2% 1.1%
2043 8.2% 1.1%
2044 8.2% 1.1%
2045 8.2% 1.1%
2046 8.2% 1.1%
2047 3.1% 1.1%
2048 -0.5% 1.1%
2049 -0.6% 1.1%
2050 -0.5% 1.1%
2051 -0.6% 1.1%
2052 -0.6% 1.1%
2053 -0.6% 1.1%

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California Energy Codes & Standards | A statewide utility program 2024-03-25

7.3 Summary of Efficiency Measures
Table 39 provides the details of the efficiency (non-preempted) measures, by climate zone, included in the following packages for the single family prototype:
• Efficiency Only
• Efficiency + High Efficiency (Preempted) Equipment
• Efficiency + PV
• Efficiency + PV + Battery (all-electric only)
The efficiency measures for the single family mixed fuel Efficiency + PV + Battery package is presented in Table 40, and Table 41 presents the efficiency measures for all the ADU packages. In all tables, the lack of an “X” indicates that the prescriptive values for that climate zone were not changed. See Appendix 7.4 for a list of prescriptive values by climate zone. Efficiency measures are described in Section 3.3.1.

Table 39: All-Electric Single Family Efficiency Measures, Various Packages Climate
Zone
3 ACH50
R-10
Slab
Attic Ceiling
Insulation

0.25 Roof
Solar
Reflectance

0.24 U-Factor /

0.50 SHGC
Windows

0.35 W/cfm
Buried
Ducts
Basic Compact
Hot Water
Credit
1 X R-60 X
2 X R-60 X X X
3 R-60 X X X
4 X R-60 X X X
5 R-49 X X X
6 R-60 X X X
7 R-49 X X
8 R-60 X X X
9 R-60 X X X
10 R-60 X X X X
11 X R-60 X X X X
12 X R-60 X X X X
13 X R-60 X X X X
14 X X R-60 X X X X
15 X R-60 X X X X
16 R-60 X X X

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California Energy Codes & Standards | A statewide utility program 2024-03-25 Table 40: Mixed Fuel Single Family Measures, Efficiency + PV + Battery Package25 Climate
Zone
3 ACH50
R-10
Slab Attic

0.25 Roof
Solar
Reflectance

0.24 UFactor / 0.50
SHGC
Windows

0.30 UFactor / 0.50
SHGC
Windows

0.35 W/cfm
Buried
Ducts
Basic
Compact
Hot Water
Credit
1 X X X
2 X R-49 X X X
3 R-38 X X X
4 X R-49 X X X
5 X R-49 X X X
6 R-49 X X X
7 R-49 X X X
8 R-49 X X X
9 R-49 X X X
10 R-49 X X X
11 R-49 X X X
12 R-49 X X X X
13 R-49 X X X X
14 X R-49 X X X X
15 X R-49 X X X X
16 R-49 X X X
Table 41: Efficiency Measures for All ADU Packages
Climate
Zone
3 ACH50
R-10
Slab

0.25 Roof
Solar
Reflectance

0.24 U-Factor /

0.50 SHGC
Windows
Ductless
VCHP1
Basic
Compact Hot
Water Credit
1 1 X X
2 X X X
3 X X
4 X X X
5 X X
6 X X
7 X X
8 X X
9 X X
10 X X X
11 X X X X
12 X X X X
13 X X X X
14 X X X X X
15 X X X X
16 X X 1 The ductless VCHP and compact hot water measures are only applied to the all-electric packages and not the mixed fuel packages.
25 The efficiency measures for the all-electric version of this package follow those listed in Table 39.

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California Energy Codes & Standards | A statewide utility program 2024-03-25

7.4 Summary of Applicable Prescriptive Base Case Measures This appendix lists the prescriptive values, by climate zone, of building components relevant to the measures included in this analysis. Table 42 outlines envelope, PV, and battery values;

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Packet Pg. 688 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Single Family New Construction 77 Appendices
California Energy Codes & Standards | A statewide utility program 2024-03-25 Table 43 outlines space conditioning values, and Table 44 outlines domestic water heating (DHW) values.

Table 42 Prescriptive Envelope, PV, and Battery Measures by Climate Zone CZ Air
Infiltration1 Foundation Wall
Insulation2
Attic
Insulation3
Roof Aged
Solar
Reflectivity
Window
U-Factor /
SHGC
PV4 Battery
1 5 ACH50 Uninsulated slab R-21 + R-5 R-38 0.1 0.30 / 0.35 code min. none 2 5 ACH50 Uninsulated slab R-21 + R-5 R-38 0.1 0.30 / 0.23 code min. none 3 5 ACH50 Uninsulated slab R-21 + R-5 R-30 0.1 0.30 / 0.35 code min. none 4 5 ACH50 Uninsulated slab R-21 + R-5 R-38 + R-19 0.1 0.30 / 0.23 code min. none 5 5 ACH50 Uninsulated slab R-21 + R-5 R-30 0.1 0.30 / 0.35 code min. none 6 5 ACH50 Uninsulated slab R-15 + R-4 R-30 0.1 0.30 / 0.23 code min. none 7 5 ACH50 Uninsulated slab R-15 + R-4 R-30 0.1 0.30 / 0.23 code min. none 8 5 ACH50 Uninsulated slab R-21 + R-5 R-38 + R-19 0.1 0.30 / 0.23 code min. none 9 5 ACH50 Uninsulated slab R-21 + R-5 R-38 + R-19 0.1 0.30 / 0.23 code min. none 10 5 ACH50 Uninsulated slab R-21 + R-5 R-38 + R-19 0.2 0.30 / 0.23 code min. none 11 5 ACH50 Uninsulated slab R-21 + R-5 R-38 + R-19 0.2 0.30 / 0.23 code min. none 12 5 ACH50 Uninsulated slab R-21 + R-5 R-38 + R-19 0.2 0.30 / 0.23 code min. none 13 5 ACH50 Uninsulated slab R-21 + R-5 R-38 + R-19 0.2 0.30 / 0.23 code min. none 14 5 ACH50 Uninsulated slab R-21 + R-5 R-38 + R-19 0.2 0.30 / 0.23 code min. none 15 5 ACH50 Uninsulated slab R-21 + R-5 R-38 + R-19 0.2 0.30 / 0.23 code min. none 16 5 ACH50 R-7, 16" slab
insulation R-21 + R-5 R-38 + R-19 0.1 0.30 / 0.35 code min. none 1 5 ACH50 is prescriptively required however verification is not required. 2 Cavity wall insulation + continuous rigid insulation. 3 Ceiling/attic insulation R-value. R-38 + R-19 reflect High Performance Attics (HPAs) as defined by Option B in Table 150.1-A. 4 Prescriptive PV capacities (kW-DC) by climate zone are summarized in Table 4.

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California Energy Codes & Standards | A statewide utility program 2024-03-25 Table 43 Prescriptive HVAC Measures by Climate Zone
CZ Heating
Type AC Type HeatingEfficiency1
HVAC
Efficiency
(SEER2/EER2)
HVAC Fan
Efficacy
(W/cfm)
Ducts2
1 Gas Furnace AC 80% 14.3 / 11.7 0.45 R-8, 5%, in attic (not buried) 2 Gas Furnace AC 80% 14.3 / 11.7 0.45 R-8, 5%, in attic (not buried) 3 Heat pump Heat pump 7.5 14.3 / 11.7 0.45 R-6, 5%, in attic (not buried) 4 Heat pump Heat pump 7.5 14.3 / 11.7 0.45 R-8, 5%, in attic (not buried) 5 Gas Furnace AC 80% 14.3 / 11.7 0.45 R-6, 5%, in attic (not buried) 6 Gas Furnace AC 80% 14.3 / 11.7 0.45 R-6, 5%, in attic (not buried) 7 Gas Furnace AC 80% 14.3 / 11.7 0.45 R-6, 5%, in attic (not buried) 8 Gas Furnace AC 80% 14.3 / 11.7 0.45 R-8, 5%, in attic (not buried) 9 Gas Furnace AC 80% 14.3 / 11.7 0.45 R-8, 5%, in attic (not buried) 10 Gas Furnace AC 80% 14.3 / 11.7 0.45 R-8, 5%, in attic (not buried) 11 Gas Furnace AC 80% 14.3 / 11.7 0.45 R-8, 5%, in attic (not buried) 12 Gas Furnace AC 80% 14.3 / 11.7 0.45 R-8, 5%, in attic (not buried) 13 Heat pump Heat pump 7.5 14.3 / 11.7 0.45 R-8, 5%, in attic (not buried) 14 Heat pump Heat pump 7.5 14.3 / 11.7 0.45 R-8, 5%, in attic (not buried) 15 Gas Furnace AC 80% 14.3 / 11.7 0.45 R-8, 5%, in attic (not buried) 16 Gas Furnace AC 80% 14.3 / 11.7 0.45 R-8, 5%, in attic (not buried) 1 AFUE for gas furnaces, HSPF2 for heat pumps. 2 Duct insulation R-value, duct leakage, duct location.

Table 44 Prescriptive Water Heating Measures by Climate Zone CZ DHW Type
DHW Location DHW:

Basic
Compact
Distribution
Credit
Single
Family ADU
1 Heat pump Garage In conditioned space, ducted to/from outside Yes 2 Heat pump Garage In conditioned space, ducted to/from outside No 3 Gas tankless Garage In conditioned space, ducted to/from outside No 4 Gas tankless Garage In conditioned space, ducted to/from outside No 5 Heat pump Garage In conditioned space, ducted to/from outside No 6 Heat pump Garage In conditioned space, ducted to/from outside No 7 Heat pump Garage In conditioned space, ducted to/from outside No 8 Heat pump Garage In conditioned space, ducted to/from outside No 9 Heat pump Garage In conditioned space, ducted to/from outside No 10 Heat pump Garage In conditioned space, ducted to/from outside No 11 Heat pump Garage In conditioned space, ducted to/from outside No 12 Heat pump Garage In conditioned space, ducted to/from outside No 13 Gas tankless Garage In conditioned space, ducted to/from outside No 14 Gas tankless Garage In conditioned space, ducted to/from outside No 15 Heat pump Garage In conditioned space, ducted to/from outside No 16 Heat pump Garage In conditioned space, ducted to/from outside Yes

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California Energy Codes & Standards | A statewide utility program 2024-03-25 Get In Touch
The adoption of reach codes can differentiate jurisdictions as efficiency leaders and help accelerate the adoption of new equipment, technologies, code compliance, and energy savings strategies.

As part of the Statewide Codes & Standards Program, the Reach Codes Subprogram is a resource available to any local jurisdiction located throughout the state of California.

If you are interested in finding out more about local energy reach codes, the Reach Codes Team stands ready to assist jurisdictions at any stage of a reach code project.

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Packet Pg. 691 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction Buildings Prepared by:

Avani Goyal, Farhad Farahmand
TRC Companies Inc.

Prepared for:

Jay Madden
Codes and Standards Program Southern California Edison
Last modified: 2023/03/24
Revision: 1.3
2 0 2 2 C o d e :

Nonresidential New
Construction Reach Code
Cost-effectiveness Study

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Packet Pg. 692 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost
-effectiveness Analysis: Nonresidential New Construction Buildings Legal Notice
This report was prepared by Southern California Edison Company and funded by the California utility customers under the auspices of the California Public Utilities Commission.

Neither SCE nor any of its employees makes any warranty, express or implied; or assumes any legal liability or responsibility for the accuracy, completeness or usefulness of any data, information, method, product, policy, or process disclosed in this document; or represents that its use will not infringe any privately- owned rights including, but not limited to, patents, trademarks, or copyrights.

Acronym List
AC – Air Conditioner
ASHRAE - American Society of Heating, Refrigerating
and Air-Conditioning Engineers
B/C – Benefit-to-Cost Ratio
BOD – Basis of Design
BSC – Building Standards Commission
Btu – British thermal unit
CAV – Constant Air Volume
CBECC - California Building Energy Code Compliance
CBECS - Commercial Building Energy Consumption Survey
CBSC - California Building Standards Commission
CEC - California Energy Commission
CPAU – City of Palo Alto Utilities
CZ – Climate Zone
DCKV – Demand-Controlled Kitchen Ventilation
DHW – Domestic Hot Water
DEER – Database for Energy Efficient Resources
DOE – U.S. Department of Energy
E3 – Energy and Environmental Economics
EUI – Energy Use Index
FDD – Fault Detection and Diagnostics
GHG - Greenhouse Gas
GPM – Gallons Per Minute
HVAC – Heating, Ventilation, and Air Conditioning
IOU – Investor-Owned Utility

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Packet Pg. 693 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost
-effectiveness Analysis: Nonresidential New Construction Buildings kWh – Kilowatt Hour
LADWP – Los Angeles Department of Water and Power
LBNL – Lawrence Berkeley National Lab
LPD – Lighting Power Density
NPV – Net Present Value
QSR – Quick-Service Restaurant
PNNL – Pacific Northwest National Laboratory
POU – Publicly Owned Utility
PTHP – Packaged Terminal Heat Pump
PG&E – Pacific Gas & Electric (utility)
PTAC – Packaged Terminal Air Conditioning
PV - Solar Photovoltaic
SCE – Southern California Edison (utility)
SCG – Southern California Gas (utility)
SDG&E – San Diego Gas & Electric (utility)
SHW – Service Hot Water
SMUD – Sacramento Municipal Utility District
SZ – Single Zone
TDV – Time Dependent Valuation
VAV – Variable Air Volume
TDV - Time Dependent Valuation
Title 24 – California Code of Regulations Title 24, Part6 TOU – Time of Use

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Packet Pg. 694 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction Buildings Summary of Revisions
Date Description Reference (page or section)
11/16/2022 Original Release -
01/31/2023 Minor changes to reflect efficiency compliance margin calculation updates in workbook and report
tables
Section 5
03/24/2023 Minor changes in narrative of quick service
restaurant in reach code considerations
Section 5

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TABLE OF CONTENTS
Executive Summary..........................................................................................................................................................1 1 Introduction................................................................................................................................................................3 2 Methodology and Assumptions...............................................................................................................................5

2.1 Cost-effectiveness ................................................................................................................................................................ 5

2.1.1 Benefits......................................................................................................................................................................... 5

2.1.2 Costs............................................................................................................................................................................. 5

2.1.3 Metrics .......................................................................................................................................................................... 6

2.1.4 Utility Rates................................................................................................................................................................... 6

2.2 Energy Simulations ............................................................................................................................................................... 7

2.3 2022 T24 Compliance Metrics .............................................................................................................................................. 7

2.4 GHG Emissions .................................................................................................................................................................... 8

2.5 Limitations and Further Considerations ................................................................................................................................ 8 3 Prototypes, Measure Packages, and Costs ..........................................................................................................10

3.1 Prototype Characteristics.................................................................................................................................................... 10

3.2 Measure Definitions and Costs ........................................................................................................................................... 12

3.2.1 Fuel Substitution ......................................................................................................................................................... 12

3.2.2 Efficiency..................................................................................................................................................................... 21

3.2.3 Load Flexibility ............................................................................................................................................................ 28

3.2.4 Additional Solar PV and Battery Storage .................................................................................................................... 29

3.3 Measure Packages ............................................................................................................................................................. 30 4 Cost-Effectiveness Results ....................................................................................................................................32

4.1 Medium Office..................................................................................................................................................................... 33

4.2 Medium Retail..................................................................................................................................................................... 34

4.3 Quick-Service Restaurant (QSR)........................................................................................................................................ 35

4.4 Small Hotel.......................................................................................................................................................................... 36 5 Energy Code Compliance Results and Reach Code Considerations ................................................................37

5.1 Medium Office..................................................................................................................................................................... 41

5.2 Medium Retail..................................................................................................................................................................... 42

5.3 Quick-Service Restaurant (QSR)........................................................................................................................................ 44

5.4 Small Hotel.......................................................................................................................................................................... 46 6 Conclusions .............................................................................................................................................................48 7 References ...............................................................................................................................................................50 8 Appendices ..............................................................................................................................................................52

8.1 Map of California CZs ......................................................................................................................................................... 52

8.2 Utility Rate Schedules......................................................................................................................................................... 53

8.2.1 PG&E.......................................................................................................................................................................... 54

8.2.2 SCE............................................................................................................................................................................. 57

8.2.3 SCG ............................................................................................................................................................................ 60

8.2.4 SDG&E ....................................................................................................................................................................... 62

8.2.5 CPAU.......................................................................................................................................................................... 68

8.2.6 SMUD (Electric Only).................................................................................................................................................. 70

8.2.7 Escalation Rates ......................................................................................................................................................... 71

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8.3 HVAC and SHW System Cost Scalers ............................................................................................................................... 71

8.4 Mixed Fuel Baseline Figures............................................................................................................................................... 72

8.5 GHG Savings Summary...................................................................................................................................................... 76

LIST OF TABLES
Table 1. Utility Tariffs Used Based on CZ (October 2022).................................................................................................................... 7 Table 2. Baseline Prototype Characteristics ....................................................................................................................................... 11 Table 3. HVAC and Water Heating Characteristics Summary ............................................................................................................ 14 Table 4. Medium Office Average Mechanical System Costs .............................................................................................................. 15 Table 5. Medium Retail Average Mechanical System Costs............................................................................................................... 16 Table 6. Quick-Service Restaurant Average Mechanical System Costs - HS Package...................................................................... 16 Table 7. Small Hotel HVAC and Water Heating System Costs........................................................................................................... 18 Table 8. Quick-Service Restaurant Cooking Equipment Costs........................................................................................................... 18 Table 9. Small Hotel Clothes Dryer Costs........................................................................................................................................... 19 Table 10. Electrical Infrastructure Costs ............................................................................................................................................. 20 Table 11. Gas Infrastructure Costs by Component............................................................................................................................. 21 Table 12. Total Gas Infrastructure Cost Estimates by Building Type.................................................................................................. 21 Table 13. Efficiency Measures Applicability, Costs, and Sources....................................................................................................... 26 Table 14. Load Flexibility Measure Summary ..................................................................................................................................... 29 Table 15. Additional Solar PV Measure Summary.............................................................................................................................. 30 Table 16. Reach Code Pathway Considerations ................................................................................................................................ 39 Table 17. Cost-effectiveness and Compliance Summary – Medium Office ........................................................................................ 41 Table 18. Cost-effectiveness and Compliance Summary – Medium Retail......................................................................................... 42 Table 19. Cost-effectiveness and Compliance Summary – Quick-Service Restaurant (without cooking electrification)..................... 44 Table 20. Cost-effectiveness and Compliance Summary – Quick-Service Restaurant (with cooking electrification).......................... 45 Table 21. Cost-effectiveness and Compliance Summary – Small Hotel. ............................................................................................ 46 Table 22. Cost-effectiveness and Compliance Summary – Small Hotel (PTHP) ................................................................................ 47 Table 23. Utility Tariffs Analyzed Based on CZ – Detailed View......................................................................................................... 53 Table 24. Real Utility Rate Escalation Rate Assumptions Above Inflation .......................................................................................... 71 Table 25. Materials and Labor Adjustment Factors by Climate Zone ................................................................................................. 71 Table 26. Contractor Markup Values .................................................................................................................................................. 72 Table 27. Mixed Fuel Baseline Model – Medium Office...................................................................................................................... 72

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Packet Pg. 697 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction Buildings Table 28. All-electric Baseline Model – Medium Retail ....................................................................................................................... 73 Table 29. Mixed Fuel Baseline Model – Quick-Service Restaurant .................................................................................................... 74 Table 30. Mixed Fuel Baseline Model – Small Hotel........................................................................................................................... 75

LIST OF FIGURES
Figure 1. Medium Office Cost-Effectiveness Summary....................................................................................................................... 33 Figure 2. Medium Retail Cost-effectiveness Summary ....................................................................................................................... 34 Figure 3. QSR Cost-effectiveness Summary ...................................................................................................................................... 35 Figure 4. Small Hotel Cost-effectiveness Summary............................................................................................................................ 36 Figure 5. Map of California CZs .......................................................................................................................................................... 52 Figure 6. PG&E Electric Schedule - B-1 ............................................................................................................................................. 54 Figure 7. PG&E Electric Schedule - B-10 ........................................................................................................................................... 55 Figure 8. PG&E Gas Schedule – G-NR1 ............................................................................................................................................ 56 Figure 9. SCE Electric Schedule – TOU-GS-1.................................................................................................................................... 57 Figure 10. SCE Electric Schedule – TOU-GS-2.................................................................................................................................. 58 Figure 11. SCE Electric Schedule – TOU-GS-3.................................................................................................................................. 59 Figure 12. SCG Gas Schedule – G-10................................................................................................................................................ 60 Figure 13. SDG&E Electric Schedule – AL-TOU ................................................................................................................................ 62 Figure 14. SDG&E Electric Schedule - EECC .................................................................................................................................... 65 Figure 15. SDG&E Gas Schedule – GN-3 .......................................................................................................................................... 66 Figure 16. CPAU Electric Schedule – E-2........................................................................................................................................... 68 Figure 17. CPAU Gas Schedule – G-2 ............................................................................................................................................... 69 Figure 18. SMUD Electric Schedule – CITS-0/CITS-1........................................................................................................................ 70 Figure 19. Percentage GHG Savings – Medium Office ...................................................................................................................... 76 Figure 20. Percentage GHG Savings – Medium Retail....................................................................................................................... 76 Figure 21. Percentage GHG Savings – Quick Service Restaurant ..................................................................................................... 77 Figure 22. Percentage GHG Savings – Small Hotel ........................................................................................................................... 77

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Packet Pg. 698 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 1 Executive Summary
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Executive Summary
The California Codes and Standards (C&S) Reach Codes program provides technical support to local governments considering adopting a local ordinance, also known as a reach code, intended to support meeting local and/or statewide energy efficiency and greenhouse gas (GHG) reduction goals. The program facilitates the adoption and implementation of reach codes when requested by local jurisdictions by providing resources such as cost-effectiveness studies, model language, sample findings, and other supporting documentation.

The Reach Code Team (the Team) provides this report and accompanying Reach Code Results Workbook to present measures and measure packages that local jurisdictions can adopt to achieve energy savings and emissions reductions beyond what will be accomplished by enforcing the minimum state requirements according to the 2022 Building Energy Efficiency Standards (Title 24, Part 6), effective January 1, 2023. This report documents a variety of above-code electrification, energy efficiency, load flexibility, and solar photovoltaic (PV) packages applied to a set of four nonresidential building prototypes: Medium Office, Standalone Retail, Quick-Service Restaurant, and Small Hotel.

The Team evaluated energy simulation results and code compliance using the CBECC v1.0 software version released in June 2022. Results may change with future software versions. Results across all prototypes indicate the efficiency measures included in the analysis, both On-Bill and TDV, are cost-effective across all climate zones when added to the prescriptive baseline prototype. In all cases all-electric packages are capable of achieving the greatest greenhouse gas emissions reductions as compared to mixed-fuel buildings.

These results, including the attached Reach Code Results Workbook, indicate that all-electric packages can achieve the greatest greenhouse gas emissions reductions as compared to mixed-fuel buildings. Results align with the decarbonization objectives set by California Energy Commission (Energy Commission), and several new construction new construction ordinances focusing on all-electric design. The results of this study by prototype are summarized below:

Medium Office: Due to the lack of a prescriptive compliance pathway and performance modeling approach in CBECC, all-electric space heating is simulated as electric-resistance variable-air-volume reheat. This system selection limits operational benefits, energy code compliance, and cost-effectiveness. All-electric packages are cost-effective with energy efficiency and load flexibility measures in many climate zones, but do not achieve code compliance across all three metrics—with efficiency TDV margin being the most challenging. Results will be updated in the first half of 2023 when central heat pump boilers can be simulated in CBECC. Jurisdictions may adopt reach codes that exempt building systems that do not have a prescriptive pathway in the energy code and cannot be modeled to comply using the performance approach. Efficiency packages over the mixedfuel baseline are cost-effective and compliant across all climate zones.

Medium Retail: All-electric is prescriptively required in most scenarios in Retail buildings. The Team identified cost-effective and code compliant packages with energy efficiency measures over an all-electric baseline in most climate zones. This study analyzed mixed-fuel retail buildings with large (>240 kBtuh) gas furnace packaged units replacing the smaller (<240 kBtuh) packaged heat pumps. The mixed-fuel building is neither cost-effective nor code compliant in most climate zones.

Quick-Service Restaurant: The Team identified cost-effective, nearly cost-effective, and code compliant packages in several climate zones for all-electric space conditioning and service water heating when including energy efficiency and solar PV measures. The Team could not identify cost-effective packages including allelectric commercial cooking equipment except for City of Palo Alto Utility (CPAU) territory. Also, when including energy efficiency measures, restaurants with all-electric cooking achieve compliance and are nearly On-Bill cost-effective in Sacramento Municipal Utility District (SMUD) territory as well. Jurisdictions may adopt AllElectric reach codes that exempt commercial cooking equipment or require energy efficiency for either mixedfuel and/or all-electric buildings, in many climate zones.

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Packet Pg. 699 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 2 Executive Summary
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Small Hotel: All-electric packages are cost-effective and code-compliant in most climate zones. The remaining climate zones are very close to meeting the TDV Efficiency compliance criteria and may achieve compliance by re-evaluating nonresidential-area modeling using central heat pump boiler instead of electric resistance VAV systems. In addition to electrification packages that include single-zone packaged heat pumps, the Team analyzed an alternative scenario with packaged terminal heat pumps (PTHPs) that improved all-electric code minimum cost-effectiveness due to high first-cost savings, but PTHPs do not achieve TDV Efficiency compliance. Mixed-fuel plus energy efficiency is code compliant and cost-effective across all climate zones.

Jurisdictions may use these results for amending Part 6, Part 11, other parts of the California building code, or their municipal code as determined appropriate for the given jurisdiction. A cost-effectiveness study is required to amend Part 6 of the California building code or when adopting energy efficiency or energy conservation measures, including solar PV or batteries. The Energy Commission has previously concluded that all-electric requirements do not constitute an energy efficiency or energy conservation standard and are outside the scope of Public Resources Code section 25402.1(h)(2).
1 Jurisdictions may adopt an All-Electric reach code when amending Part 11 or their municipal code.

Even reach code policies that only require electrification, and do not require energy efficiency or conservation, will benefit from findings in this study to inform potential economic impacts of a policy decision. This study documents the estimated costs, benefits, energy impacts and GHG emission reductions that may result from implementing an ordinance based on the results to help residents, local leadership, and other stakeholders make informed policy decisions.

Model ordinance language and other resources are posted on the C&S Reach Codes Program website at www.localenergycodes.com. Local jurisdictions that are considering adopting an ordinance are encouraged to contact the program for further technical support at [email protected] . 1 CEC Letter to South San Francisco 2021: https://bayareareachcodes.org/wp-content/uploads/2022/10/CEC-Letter-to-SSFSigned.pdf

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Packet Pg. 700 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 3 Introduction
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 1 Introduction
This report documents cost-effective combinations of measures that exceed the minimum state requirements, the 2022 California Building Energy Efficiency Standards Title 24, Part 6 (Title 24) (CEC 2022), effective January 1, 2023, for newly constructed nonresidential buildings. This report was developed in coordination with the California Statewide Investor-Owned Utilities (CA IOUs) Codes and Standards Program, key consultants, and engaged cities—collectively known as the Reach Code Team (or “the Team” for short). The objectives of this report are to inform discourse for local reach code adoption and, where applicable, support approval of local energy code amendments from the California Energy Commission (the Energy Commission).

The Reach Code Team performed cost-effectiveness analysis for the following scenarios above prescriptive 2022 Title 24 code requirements in all 16 California climate zones (CZs):
▪ Fuel substitution with federal code-minimum efficiency appliances, compared to a prescriptive minimum design compliance pathway.
• For the retail building type, the prescriptive code minimum is all-electric. Fuel substitution packages revert to mixed-fuel appliances.
• For all other building types, the prescriptive code minimum is mixed-fuel. Fuel substitution packages switch to all-electric appliances.
▪ Energy efficiency measures
▪ Load flexibility measures
▪ Solar PV and Battery
The Reach Code Team analyzed four prototypes—Medium Office, Medium Retail, Quick-Service Restaurant, and Small Hotel—to represent common nonresidential new construction buildings in the California. The selected building types align with the requests received from dozens of jurisdictions seeking to adopt reach codes. The results of this cost-effectiveness study could potentially be extrapolated to other building types that have similar properties such as occupancy pattern, HVAC design and layout. These results were attained using the first version of California Building Energy Compliance Calculator (CBECC) software that is approved by CEC for 2022 code compliance. There are a few gaps in functionalities and standard design assumptions in this software version, described in Section 2.5, the Reach Code team has been actively coordinating with the CBECC software team to inform future software updates.

Title 24 is maintained and updated every three years by two state agencies: the Energy Commission and the Building Standards Commission (BSC). In addition to enforcing the code, local jurisdictions have the authority to adopt local energy efficiency ordinances—or reach codes—that exceed the minimum standards defined by Title 24 (as established by Public Resources Code Section 25402.1(h)2 and Section 10-106 of the Building Energy Efficiency Standards).

When adopting local energy efficiency or conservation ordinances, local jurisdictions must demonstrate that the requirements of the proposed ordinance are cost-effective and do not result in buildings consuming more energy than is permitted by Title 24. In addition, the jurisdiction must obtain formal approval from the Energy Commission and file the ordinance with the BSC for the ordinance to be legally enforceable. Local jurisdictions do not require Energy Commission approval when adopting ordinances that do not require efficiency or conservation, such as only electrification-required ordinances.

The Department of Energy (DOE) sets minimum efficiency standards for equipment and appliances that are federally regulated under the National Appliance Energy Conservation Act, including heating, cooling, and water heating equipment (E-CFR 2020). Since state and local governments are prohibited from adopting higher minimum equipment efficiencies than the federal standards require, the focus of this study is to identify and evaluate cost-effective packages that do not include high efficiency heating, cooling, and water heating equipment. High efficiency appliances are often the easiest and most affordable measures to increase energy performance. While federal preemption limits

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Packet Pg. 701 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 4 Introduction
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 reach code mandatory requirements for covered appliances, in practice, builders may install any package of compliant measures to achieve the performance requirements.

This study references the statewide reach code study performed in 2019 for newly constructed nonresidential buildings as a starting point for additional measure definitions. Importantly, the current 2022 cost-effectiveness report introduced a new restaurant building type and updated the modeling and cost assumptions.

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Packet Pg. 702 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 5 Methodology and Assumptions
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 2 Methodology and Assumptions
The Reach Code Team analyzed four prototypes—Medium Office, Medium Retail, Quick-Service Restaurant, and Small Hotel—using the cost-effectiveness methodology detailed in this section below.

2.1 Cost-effectiveness
This section describes the approach to calculating cost-effectiveness including benefits, costs, metrics, and utility rate selection.

2.1.1 Benefits
This analysis used both On-Bill and time dependent valuation (TDV) of energy-based approaches to evaluate costeffectiveness. Both On-Bill and TDV require estimating and quantifying the energy savings and costs associated with energy measures. The primary difference between On-Bill and TDV is how energy is valued:
▪ On-Bill: Customer-based lifecycle cost approach that values energy based upon estimated site energy usage and customer On-Bill savings using electricity and natural gas utility rate schedules over a 15-year duration accounting for a three percent discount rate and energy cost inflation per Appendix 8.2. ▪ TDV: TDV was developed by the Energy Commission to reflect the time dependent value of energy, including long-term projected costs of energy such as the cost of providing energy during peak periods of demand and other societal costs including projected costs for carbon emissions and grid transmission impacts. This metric values energy uses differently depending on the fuel source (gas, electricity, and propane), time of day, and season. Electricity used (or saved) during peak periods has a much higher value than electricity used (or saved) during off-peak periods. This refers to the “Total TDV” that includes all the energy end uses such as space-conditioning, mechanical ventilation, service water heating indoor lighting, photovoltaic (PV) and battery storage systems, and covered process loads.

2.1.2 Costs
The Reach Code Team assessed the incremental costs and savings of the energy packages over a 15 year lifecycle.

Incremental costs represent the equipment, installation, replacements, and maintenance costs of the proposed measure relative to the 2022 Title 24 standards minimum requirements or standard industry practices. The Reach Code Team obtained baseline and measure costs from manufacturer distributors, contractors, literature review, and online sources such as RS Means.

For heating, ventilation, and air conditioning (HVAC) and water heating baseline and measure costs, including gas and electrical infrastructure, the Reach Code Team contracted two different firms, one mechanical contractor (Western Allied Mechanical, based in Menlo Park) and one mechanical designer (P2S Engineering, based in Irvine) to provide cost data. The Reach Code Team developed a basis of design for all prototypes described in section 3.1 and worked with the mechanical contractor and designer to get cost estimates. The Reach Code Team determined HVAC design heating and cooling loads and capacities by climate zone from the energy models. For each HVAC system type, the Reach Code Team requested costs for the smallest capacity unit required and the largest capacity unit required and specified federal minimum equipment efficiency.

The mechanical contractor and mechanical designer collected equipment costs and labor assumptions from their vendors and manufacturers’ representatives, as well as through their own recent projects. The mechanical contractor and designer provided material and labor cost estimates for the entire HVAC and DHW systems, disaggregated by the HVAC and DHW equipment itself; refrigerant piping; structural; electrical supply; gas supply; controls; commissioning and startup; general conditions and overhead; design and engineering; permit, testing, and inspection; and a contractor profit or market factor. The mechanical contractor and designer provided costs for each of the system capacities, based on which the Reach Code Team developed a relationship between HVAC system capacity and cost to calculate the cost for each building in each climate zone. In most cases, the analysis uses the average of the costs provided by

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Packet Pg. 703 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 6 Methodology and Assumptions
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 the contractor and the costs provided by the designer. In some limited cases where costs provided by one source were unlikely to be representative of the measure, costs from only the other source were used. The Reach Code Team added taxes, contractor markups, maintenance costs, and replacement costs where needed, and adjusted material and labor costs for each climate zone based on weighting factors from RS Means (presented in Appendix 8.3).

Actual project costs vary widely based on a range of real-building considerations. The costs that the Reach Code Team determined through contractors are likely costs for the given prototypes and are not representative of all projects.

2.1.3 Metrics
Cost-effectiveness is presented using net present value (NPV) and benefit-to-cost (B/C) ratio metrics. ▪ NPV: Net savings (NPV benefits minus NPV costs). If the net savings of a measure or package is positive over a lifetime of 15 years, it is considered cost-effective. Negative net savings represent net costs to the consumer.

A measure that has negative energy cost benefits (energy cost increase) can still be cost-effective if the incremental costs to implement the measure (i.e., construction and maintenance cost savings) outweigh the negative energy cost impacts.
▪ B/C Ratio: Ratio of the present value of all benefits to the present value of all costs over 15 years (NPV benefits divided by NPV costs). The criterion for cost-effectiveness is a B/C greater than 1.0. A value of one indicates the savings over the life of the measure are equivalent to the incremental cost of that measure. A value greater than one represents a positive return on investment.

Improving the energy performance of a building often requires an initial capital investment, though in some cases an energy measure may be cost neutral or have a lower cost. In most cases the benefit is represented by annual On-Bill utility or TDV savings and the cost by incremental first cost and replacement costs. In cases where both construction costs and energy-related savings are negative, the construction cost savings are treated as the benefit while the increased energy costs are the cost.

In cases where a measure or package is cost-effective immediately (i.e., shows positive upfront construction cost savings and lifetime energy cost savings), B/C ratio cost-effectiveness is represented by “>1”. Because of these situations, NPV savings are also reported, which, in these cases, are positive values.

2.1.4 Utility Rates
In coordination with the IOU and POU rate teams the Reach Code Team determined appropriate utility rates for each CZ and package as of October 2022. The utility tariffs, summarized in Table 1, were determined based on the annual load profile of each prototype and the corresponding package, the most prevalent rate in each utility territory, and information indicating that the rates were unlikely to be phased out during the code cycle.

A time-of-use (TOU) rate was applied to most cases, some POUs may not have TOU rates. In addition to energy consumption charges, there are kW demand charges for monthly peak loads. Utilities calculate the peak load by the highest kW of the 15-minute interval readings in the month. However, the energy modeling software produces results on hourly intervals; hence, the Team calculated the demand charges by multiplying the highest load of all hourly loads in a month with the corresponding demand charge per kW. The utility rates applicable to a prototype may vary by package and CZ especially between a mixed fuel and all-electric package if the monthly peak demand loads exceed the applicable threshold.

The Reach Code Team coordinated with utilities to select tariffs for each prototype given the annual energy demand profile of each specific prototype, climate zone, and measure package and the most prevalent rates in each utility territory. The Reach Code Team did not compare a variety of tariffs to determine their impact on cost-effectiveness.

Utility rate updates can affect cost-effectiveness results. For a more detailed breakdown of the rates selected, refer to Appendix 8.2.

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Packet Pg. 704 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 7 Methodology and Assumptions
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 For packages with PV generation, the approved Net Energy Metering (NEM) 2.0 tariffs were applied along with minimum daily use billing and mandatory non-bypassable charges. For the PV cases, annual electric production was always less than the modeled annual electricity consumption; therefore, no credits for surplus generation were necessary.

The analysis assumes that utility rates escalate over time for commercial buildings, as described in Appendix 8.2.

Escalation rates above inflation for electricity beyond 2023 are assumed to be between 0.2% and 0.7%, before dropping to a steady 0.6% escalation per year in 2030. Natural gas is assumed to escalate at a relatively higher rate, peaking at 7.7% in 2024, then escalating more slowly to a rate of approximately 2% in the latter years of the analysis period.

Table 1. Utility Tariffs Used Based on CZ (October 2022) CZs Electric / Gas Utility Electricity Natural Gas
Investor-Owned Utilities
1-5,11-13,16 Pacific Gas & Electric Company (PG&E) B-1 / B-10 G-NR1 6, 8-10, 14,
15 Southern California Edison (SCE) / Southern
California Gas (SCG)
TOU-GS-1 / TOU-GS-2
/TOU-GS-3
G-10 (GN-10)
7, 10, 14 San Diego Gas and Electric Company (SDG&E)
AL-TOU + EECC (AL-TOU)
GN-3
Publicly Owned Utilities
4 City of Palo Alto Utilities (CPAU) E-2 G-2
12 Sacramento Municipal Utilities District (SMUD) CI-TOD 1 (CITS-0 /CITS-1) G-NR1

2.2 Energy Simulations
The Reach Code Team performed energy simulations using California’s Building Energy Code Compliance Software CBECC 2022.1.0 (1250) with ruleset version BEMCmpMgr 2022.1.0 (7361) (California Building Energy Code Compliance 2022).
2 This is the first 2022 Title 24 code compliance software approved by Energy Commission for compliance of nonresidential buildings on June 8, 2022. The CBECC software combined the capabilities of CBECCCom and CBECC-Res software into one to model both nonresidential and multifamily building prototypes in one interface.

The Reach Code Team set up parametric simulations using Modelkit software to run thousands of measure packages for each prototype in all California’s CZs. Individual measures were simulated separately and combined into costeffective measure packages for each CZ. Where necessary, the Reach Code Team employed minor ruleset changes, such as load flexibility measures that alter thermostat setpoint schedules, to improve the cost-effectiveness of measure packages. While these measures produce operational savings, they may not be used to achieve code compliance without further software upgrades.

2.3 2022 T24 Compliance Metrics
2022 Title 24 Section 140.1 defines the energy budget of the building based on source energy and TDV energy for space-conditioning, indoor lighting, mechanical ventilation, photovoltaic (PV) and battery storage systems, and service 2 Prior to the CBECC software, the Reach Code Team used CBECC-Com 2022 and CBECC 2022.0.8 Beta to model nonresidential prototypes for the 2022 reach code analysis. The Reach Code Team noted the changes in results due to updates in functionalities and standard design assumptions.

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Packet Pg. 705 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 8 Methodology and Assumptions
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 water heating and covered process loads. CEC has introduced two new compliance metrics in addition to Total Compliance TDV Margin for 2022 code cycle. A building needs to comply with all three compliance metrics below:
▪ Efficiency TDV. Efficiency TDV accounts for all regulated end-uses but does not include the impacts of PV and battery storage.
▪ Total TDV. Total TDV Compliance metric includes regulated end-uses accounting for PV and battery storage contributions.
▪ Source Energy. Source energy is based on fuel used for power generation, assuming utilities meet all Renewable Portfolio Standard (RPS) goals and other obligations projected over 15-year lifecycle.

2.4 GHG Emissions
The analysis uses the GHG emissions estimates built into CBECC. The GHG emission multipliers were developed by Energy + Environmental Economics (E3) to support development of compliance metrics for use in the 2022 California energy code (E3 2021). There are 8,760 hourly multipliers accounting for time dependent energy use and carbon emissions based on source emissions, including RPS projections. For the 2022 code cycle, the multipliers incorporate GHG from methane and refrigerant leakage, which are two significant sources of GHG emissions (NORESCO 2020).

There are 32 strings of multipliers, with a different string for each California CZ and each fuel type (metric tons of CO2 per kWh for electricity and metric tons of CO2 per therm for natural gas).

2.5 Limitations and Further Considerations
The Team encountered some modeling limitations, outside of the Team’s control that should be noted while using these results to inform reach code policies,
▪ CBECC Software:
• The Reach Code Team coordinated with the CBECC software development team on potential differences in our understanding of 2022 code requirements and its implementation in standard design such as battery controls. The version of 2022 CBECC software v1.0, described in Section 2.2, available to the Reach Code Team at the time of the analysis has limited functionalities and could not model heat pump hydronic system or other measures like drain water heat recovery. As the software evolves, some results may look different.
• The most likely all-electric replacement for a central gas boiler serving a variable air volume reheat system would be a central heat pump boiler; however, this system cannot be modeled in CBECC at the time of the writing of this report. The Reach Code Team is treating this analysis as temporary until a compliance pathway is established for a central heat pump boiler in the Energy Code and results can be updated accordingly.
• The team identified some apparent anomalies in software-reported compliance margins when they became available in June 2022. The Reach Code Team is in the midst of discussing outputs and ramifications with software development team specifically related to ventilation such as fan power and heat recovery, among other modeling methods. Results may change with future software versions. In the interim, the Reach Code Team manually calculated the compliance margins using the mixed fuel baseline model created in this study based on our best understanding. ▪ Prototype Building: The cost-effectiveness analysis is based on standard prototypical buildings, which may differ from actual buildings being constructed. Jurisdictions should keep this in mind while extrapolating to the buildings in their territory.

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Packet Pg. 706 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 9 Methodology and Assumptions
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 ▪ System Cost Assumptions: The incremental electrification and additional measure costs are based on specific system selection and assumptions made by experienced professionals. These costs can vary based on contractor, system design and specifications, and regional variation.

The Team will re-evaluate packages with central heat pump boiler system in Medium Office and Small Hotel in early 2023. In addition to the packages assessed in the report, there are other future potential enhancements that can be considered for more cost-effective or compliant packages:
▪ Adding more solar PV than already analyzed if the building has more roof space to accommodate. ▪ Adding battery at higher levels than prescriptively required in 2022 Title 24 with more advanced controls. ▪ Adding energy efficiency measures as software capability evolves such as drain water heat recovery. ▪ Applying federally pre-emptive (high) efficiency energy systems or appliances.

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Packet Pg. 707 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 10 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 3 Prototypes, Measure Packages, and Costs
This section describes the prototype characteristics and the scope of analysis including measures and their corresponding costs. The Reach Code Team used versions of the following four DOE building prototypes to evaluate cost-effectiveness of measure packages in the occupancy types listed below:
▪ Medium Office
▪ Medium Retail
▪ Quick-Service Restaurant (QSR)
▪ Small Hotel
The Reach Code Team designed the baseline prototypes to be mixed fuel based on 2022 Title 24 Final Express Terms requirements. The Reach Code Team reviewed the 2022 T24 ACM HVAC system map to ensure alignment as applicable for most cases, differences if any are discussed in subsequent sections. The Team built new construction prototypes to have compliance margins as close to zero as possible to reflect a prescriptively compliant new construction building in each CZ. The code compliance is based on the first publicly available CBECC v1.0 compliance software as described in Section 2.2. Misalignments have been reported back to the software team for future software iterations, as described in Section 2.5.

3.1 Prototype Characteristics
The DOE provides building prototype models which, when modified to comply with 2022 Title 24 requirements, can be used to evaluate the cost-effectiveness of efficiency measures (U.S. Department of Energy 2022 A). These prototypes have historically been used by the Energy Commission to assess potential code enhancements. The selection of four building types for this analysis is based on the priority suggested by a group of California cities. The cost-effectiveness results of this study could potentially be extrapolated to other building types that have similar properties such as occupancy pattern, HVAC design and layout.

Water heating includes both service hot water (SHW) for office and retail buildings and domestic hot water for hotel guest rooms. In this report, water heating or SHW is used to refer to both. The compliance software assumes a Standard Design, where HVAC and SHW systems are based on the system maps included in 2022 Nonresidential ACM Reference Manual. However, the Reach Code Team applied both 2022 Title 24 prescriptive requirements and 2022 ACM system map for baseline mixed fuel model, HVAC and SHW system characteristics as described below. ▪ Medium Office
• The HVAC design is a variable air volume (VAV) reheat system with two gas hot water boilers, three packaged rooftop units (one serving each floor), and VAV terminal units with hot water reheat coils. • The SHW design includes one 8.7 kW electric resistance hot water heater with a 5-gallon storage tank. ▪ Medium Retail
• For CZs 2 to 15, the 2022 Title 24 ACM System Map Standard Design informed the baseline model to have three packaged Single Zone Heat Pump (SZHP) systems for the smaller capacity (<240 kBtuh) thermal zones, in alignment with 2022 Title 24 prescriptive code requirements. 3 The large (>240 kBtuh)
core thermal zone has two smaller (<240 kBtuh) SZHPs with VAV fans instead of one large SZHP, since larger rooftop packaged heat pumps are not available in the market. The 2022 Title24 ACM Standard Design assumes a large SZHP for larger zones as well, however this deviation does not impact the results considerably.3
3 https://www.energy.ca.gov/publications/2022/2022-nonresidential-and-multifamily-alternative-calculation-method-reference

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Packet Pg. 708 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 11 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 • For CZs 1 and 16, the baseline model assumed all-electric packaged single zone heat pumps similar to CZs 2-15. The assumption deviates from 2022 Title24 ACM System Map that suggests a single zone dual fuel heat pump. Presumably this will not impact results significantly because the dual fuel system will be in heat-pump mode most times.
• The SHW design includes one 8.7 kW electric resistance hot water heater with a 5-gallon storage tank. ▪ Quick-Service Restaurant
• HVAC includes two SZAC (VAV or constant volume, depending on capacity) with gas furnace, one for kitchen and another for dining area. An exhaust fan is applied for kitchens in all climates based on prescriptive requirements in 2022 Title 24 code.
• The SHW design includes a gas storage water heater with a 100-gallon storage tank. ▪ Small Hotel
• The nonresidential HVAC design is a VAV reheat system with two gas hot water boilers, four packaged rooftop units (one serving each floor), and VAV terminal units with hot water reheat coils. The SHW design includes a small electric resistance water heater with 30-gallon storage tank. • The guest room HVAC design includes one packaged SZAC unit with gas furnace serving each guest room. The water heating design includes a central gas water heater with a 250-gallon storage tank and recirculation pump, serving all guest rooms.

Table 2 summarizes the baseline mixed-fuel prototype characteristics, based on prescriptive 2022 Title 24 new construction requirements.

Table 2. Baseline Prototype Characteristics
Medium Office Medium Retail Quick-Service Restaurant Small Hotel Conditioned floor
area (ft2)
53,628 24,563 2,501
42,554
(77 guest rooms)
(Nonresidential area:
15,282 (36%))
Number of stories 3 1 1 4
Window-to-Wall
Area ratio 0.33 0.07 0.11 0.14
Window Ufactor/SHGC
U-factor:

CZ 1-8, 10, 16 – 0.36
CZ 9, 11-15 – 0.34
SHGC:

CZ 1-8, 10, 16 – 0.25
CZ 9, 11-15 – 0.22
U-factor:

CZ 1-8, 10, 16 – 0.36
CZ 9, 11-15 – 0.34
SHGC:

CZ 1-8, 10, 16 – 0.25
CZ 9, 11-15 – 0.22
U-factor:

CZ 1-8, 10, 16 – 0.36
CZ 9, 11-15 – 0.34
SHGC:

CZ 1-8, 10, 16 – 0.25
CZ 9, 11-15 – 0.22
Nonresidential:

U-factor:

CZ 1-8,10,16 – 0.36
CZ 9, 11-15 –0.34
SHGC:

CZ 1-8,10,16 – 0.25
CZ 9, 11-15 – 0.22
Guest Rooms:

U-factor: 0.36
SHGC: 0.25
Solar PV size 123 kW – 204 kW
Depending on CZ
64 kW – 87 kW
Depending on CZ None 17 kW – 25 kWDepending on CZ
Battery Storage 217 kWh – 360 kWh
Depending on CZ
70 kWh – 94 kWh
Depending on CZ None 16 kWh – 24 kWhDepending on CZ

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Packet Pg. 709 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 12 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Medium Office Medium Retail Quick-Service Restaurant Small Hotel HVAC System
VAV reheat system with
packaged rooftop units,
gas boilers, VAV terminal
units with hot water
reheat
CZ 1
Heat recovery for Core
Retail space only
< 65 kBtu/h: SZHP
> 65 kBtu/h and < 240
kBtu/h: SZHP VAV
> 240 kBtu/h: SZHP VAV
< 65 kBtu/h:

SZAC + gas furnace
> 65 kBtu/h:

SZAC VAV
Nonresidential and Laundry:

VAV reheat system with
packaged rooftop units, gas
boilers, VAV terminal units with
hot water reheat
Guest Rooms: SZAC with gas
furnaces
SHW System 5-gallon electric resistance
water heater
5-gallon electric resistance
water heater
100-gallon gas water
heater
Nonresidential: 30-gallon
electric resistance water heater
Laundry Room: 120-gal gas
storage water heater
Guest rooms: Central gas water
heater, 250 gallons storage,
recirculation loop

3.2 Measure Definitions and Costs
The measures evaluated in the analysis fall into four different categories:

Fuel Substitution
▪ Heat pump or electric
space heating or gas
furnace
▪ Heat pump or electric
water heaters
▪ Electric cooking
▪ Electric clothes dryer
▪ Electrical panel capacity
▪ Natural gas infrastructure
Energy Efficiency
▪ Envelope
▪ Mechanical equipment
(HVAC and SHW)
▪ Lighting
Load Flexibility
▪ Peak Load
shedding
▪ Load shift
Additional solar PV
and/or battery
storage.

These measures are detailed further in this section.

3.2.1 Fuel Substitution
The Reach Code Team investigated the cost and performance impacts and associated infrastructure costs associated with changing the mixed-fuel baseline HVAC and water heating systems to all-electric equipment for all prototypes except Medium Retail where the baseline is already an all-electric design.

For Medium Office, Quick Service Restaurant and Small Hotel, the fuel substitution measure entails electrification including heat pump space heating, electric resistance re-heat coils, electric water heaters with storage tank, heat pump water heating, increasing electrical capacity, and eliminating natural gas connections that would have been present in mixed-fuel new construction.

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Packet Pg. 710 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 13 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 For Medium Retail with all-electric baseline, the fuel substitution measure entails mixed-fuel space conditioning system including single zone packaged AC with gas furnace, dual fuel heat pump, adding gas infrastructure costs and eliminating any additional electric infrastructure.

3.2.1.1 HVAC and Water Heating
The 2022 T24 nonresidential standards analysis uses a mixed-fuel baseline for most of the Standard Design mechanical equipment, primarily gas for space heating, except for some heat pump scenarios in Retail prototype (see Table 2). Quick-Service Restaurant has a gas storage water heater in baseline, and heat pump water heater in allelectric scenario. The Small Hotel has a central gas water heating system serving the guest rooms and a separate gas storage water heater for laundry room. In the all-electric scenario, gas equipment serving HVAC and water heating end-uses is replaced with electric equipment. Full details of HVAC and water heating systems in baseline and proposed fuel substitution measure package are described in Table 3.

Regions of California covered by the South Coast Air Quality Management District have emissions restrictions imposed on mechanical equipment. The Reach Code Team investigated the potential cost implications of meeting these requirements for gas furnaces and boilers but found that costs are minimal for mechanical systems under 2,000,000 Btu/h, and therefore did not include them. All gas-fired mechanical systems in this study are under 2,000,000 Btu/h and are subject to only an initial permitting fee, while larger systems require additional permitting costs and annual renewals.

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Packet Pg. 711 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 14 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Table 3. HVAC and Water Heating Characteristics Summary Medium Office Medium Retail
Quick-Service
Restaurant
Small Hotel
HVAC
Baseline
Packaged DX +
VAV with hot
water reheat.

Central gas
boilers.

All zones and CZs: Single
zone packaged heat
pumps
Packaged SZAC +
gas furnace
Nonresidential: Packaged DX
+ VAV with hot water
reheat. Central gas boilers.

Guest Rooms: Packaged
SZAC +
gas furnaces
Proposed – Fuel
Substitution
Packaged DX +
VAV with electric
resistance reheat.

Core zone (>30 ton):

Packaged SZAC + VAV +
gas furnace
Other small zones: SZHP,
or dual fuel heat pump
for CZ 1 and 16
Single zone packaged
heat pumps
Nonresidential: Packaged DX
+ VAV with electric
resistance reheat
Guest Rooms: SZHPs
SHW
Baseline
Electric resistance
with storage
Electric resistance with
storage
Gas storage water
heater
Nonresidential: Electric
resistance storage
Guest Rooms: Central gas
storage with recirculation
Proposed – Fuel
Substitution
Unitary heat pump
water heater
Nonresidential: Electric
resistance storage
Guest Rooms: Central heat
pump water heater with
recirculation
The Reach Code Team received cost data for mechanical equipment from two experienced mechanical design firms including equipment and material, labor, subcontractors (for example, HVAC and SHW control systems), and contractor overhead.

3.2.1.1.1 Medium Office
For the Medium Office all-electric HVAC design, the Reach Code Team investigated several potential all-electric design options, including variable refrigerant flow, packaged heat pumps, and variable volume and temperature systems. The most likely all-electric replacement for a central gas boiler serving a variable air volume reheat system would be a central heat pump boiler; however, this system cannot be modeled in CBECC at the time of writing of this report. As such, Reach Code Team is treating this analysis as temporary until a compliance pathway is established for a central heat pump boiler in the Energy Code and results can be updated accordingly. This modeling capability is anticipated by Q1 2023 according to discussions with the CBECC software development team, and the costeffectiveness analysis should become available in the first half of 2023.

After seeking feedback from the design community and considering the software modeling constraints, the Reach Code Team determined that the most feasible all-electric HVAC system is a VAV system with an electric resistance reheat instead of hot water reheat coil. A parallel fan-powered box (PFPB) implementation of electric resistance reheat

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Packet Pg. 712 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 15 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 would further improve efficiency due to reducing ventilation requirements, but an accurate implementation of PFPBs is not currently available in compliance software.

The actual gas consumption for the VAV hot water reheat baseline may be higher than the current simulation results due to a combination of boiler and hot water distribution losses. A recent research study shows that the total losses can account for as high as 80 percent of the boiler energy use.4If these losses are considered savings for the electric resistance reheat (which has zero associated distribution loss), cost-effectiveness may be higher than presented.

The all-electric SHW system remains the same electric resistance water heater as the baseline and has no associated incremental costs. Cost data for Medium Office designs are presented in Table 4. The all-electric HVAC system presents cost savings compared to the hot water reheat system from elimination of the hot water boiler and associated hot water piping distribution. CZ10 and CZ15 all-electric design costs are slightly higher because they require larger size rooftop heat pumps than the other CZs.

Table 4. Medium Office Average Mechanical System Costs
Components (HVAC Only)
Baseline – Mixed Fuel Proposed – All-electric Incremental Cost Description
Packaged units, boilers,
hot water piping, VAV
boxes, ductwork, grilles
Packaged units, electric
resistance VAV boxes,
electric circuitry,
ductwork, grilles
VAV Boxes, electric
infrastructure
Material $491,630 $438,555 $(53,075)
Labor $173,816 $102,120 $(71,696)
Electric Infrastructure $0 $112,340 $112,340
Gas Infrastructure $17,895 $0 $(17,895)
Overhead & CZ adjustment ** $267,052 $250,114 $(16,938) TOTAL $950,393 $903,129 $(47,264)
** The overhead and CZ adjustment factors are presented in Section 8.3.

3.2.1.1.2 Medium Retail
The baseline HVAC system includes five packaged single zone heat pumps. Based on fan control requirements in Section 140.4(m), units with cooling capacity ≥ 65,000 Btu/h have variable air volume fans, while smaller units have constant volume fans. For the Medium Retail proposed fuel substitution scenario, the Reach Code Team assumed one large Single Zone Packaged ACs with gas furnaces to replace the two smaller packaged heat pumps in the large core thermal zone. The all-electric SHW system remains the same electric resistance water heater as the baseline and has no associated incremental costs. In addition, according to the prescriptive requirement in Section 140.4 (q), the air system of Core Retail Zone in CZ1 meets the requirement in Table 140.4 J, which should include exhaust air heat recovery. Cost data for Medium Retail designs are presented in Table 5. Costs for rooftop air-conditioning systems are very similar to rooftop heat pump systems.
4 Raftery, P., A. Geronazzo, H. Cheng, and G. Paliaga. 2018. Quantifying energy losses in hot water reheat systems. Energy and Buildings, 179: 183-199. November. https://doi.org/10.1016/j.enbuild.2018.09.020. Retrieved from https://escholarship.org/uc/item/3qs8f8qx

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Packet Pg. 713 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 16 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 For climate zones 2 to 15, the proposed fuel substitution HVAC design includes three SZHP units (VAV or constant volume, depending on capacity) based on prescriptive requirements and one large SZAC that is between 35-45 tons for the core zone.

For climate zones 1 and 16, the smaller capacity (<240 kBtuh) thermal zones may have either of dual-fuel SZHPs or SZACs, depending on capacity. The core zone with 35-to-45-ton cooling capacity is assumed to have one large SZAC.

CZ 1 also assumes an exhaust air heat recovery system for core zone based on prescriptive requirement in Title 24 Part 6 Section 140.4.

Table 5. Medium Retail Average Mechanical System Costs
Components (HVAC
Only)
Baseline – All-electric Proposed – Mixed Fuel Incremental Cost Description SZHPs
Single zone AC +
furnace, SZHP, or dual
fuel SZHP, depending
upon capacity and CZ
SZAC with gas furnace,
Added gas
infrastructure cost
HVAC – Material $189,160 $183,157 $(6,003)
HVAC – Labor $54,785 $52,886 $(1,899)
Electric Infrastructure $0 $0 -
Gas Infrastructure $0 $17,895 $17,895
Overhead & CZ
adjustment **
$94,600 $98,519 $3,919
TOTAL $338,546 $352,458 $13,912
** The overhead and CZ adjustment factors are presented in Section 8.3.

3.2.1.1.3 Quick-Service Restaurant
The baseline HVAC system includes two packaged single zone rooftop ACs with gas furnaces. Based on fan control requirements in Section 140.4(m), units with cooling capacity ≥ 65,000 Btu/h have variable air volume fans, while smaller units have constant volume fans. The SHW design includes one central gas storage water heater with 150 kBtu/h input capacity and a 100-gallon storage tank. For the QSR all-electric design, the Reach Code Team assumed packaged heat pumps and an A.O. Smith CHP-120 heat pump water heater with a 120-gallon storage tank. Cost data for the QSR designs are presented in Table 6, which shows the costs for full electrification of the HVAC and water heating equipment.

Santa Monica City CouncilSeptember 10, 2024

Santa Monica City Council
September 10, 2024