Santa Monica City Council
September 10, 2024

The Team has not included costs of electrifying the cooking equipment because of the negative impact on costeffectiveness, as demonstrated in a 2021 Restaurants cost-effectiveness study (TRC, P2S Engineers, and Western Allied Mechanical 2022). The HVAC and SHW electrification packages are referred to as the HS package to reflect allelectric HVAC and SHW.

Table 6. Quick-Service Restaurant Average Mechanical System Costs - HS Package Components
Baseline – Mixed Fuel Proposed – All-electric Incremental Cost Description Single zone AC + furnace, gas
storage water heater
SZHP, heat pump water
heater
HVAC +SHW
electrification
HVAC Material $50,065 $52,785 $2,719
HVAC Labor $6,748 $6,249 $(499)
SHW – Material $10,198 $13,720 $3,523
SHW – Labor $2,650 $2,529 $(121)
Electric Infrastructure $0 $12,960 $12,960

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Packet Pg. 714 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 17 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Gas Infrastructure $17,895 $15,878 -$2,017
Overhead & CZ adjustment ** $41,633 $47,612 $5,979
TOTAL $150,838 $173,382 $22,544
** The overhead and CZ adjustment factors are presented in Section 8.3.

3.2.1.1.4 Small Hotel
The Small Hotel has two different baseline equipment systems, one for the nonresidential spaces and one for the guest rooms. The nonresidential HVAC system includes two gas hot water boilers, four packaged rooftop units, and twentyeight VAV terminal boxes with hot water reheat coil. The SHW design includes a small electric water heater with storage tank for nonresidential areas and gas storage water heater dedicated to laundry room. The guest rooms HVAC design includes one single-zone AC unit with gas furnace for each guest room, and the water heating design includes one central gas storage water heater with a recirculation pump for all guest rooms.

For the Small Hotel all-electric design, the Reach Code Team assumed the nonresidential HVAC system to be packaged heat pumps with electric resistance VAV terminal units, and the SHW system will remain a small electric resistance water heater. As described in Section 3.2.1.1.1 above, a central heat pump boiler may be the most commonly employed system type but was not evaluated in this study because of modeling limitations. For the guest room all-electric HVAC system, the Team assumed SZHPs and a central heat pump water heater serving all guest rooms. For the laundry room, all-electric HVAC system is same as other nonresidential areas and all-electric water heating is a split heat pump water heater. The central heat pump water heater includes a temperature maintenance loop with an electric resistance backup heater.

Cost data for Small Hotel designs are presented in Table 7. The all-electric design presents substantial cost savings because there is no hot water plant or piping distribution system serving the nonresidential spaces. The incremental cost savings are further enhanced considerably if packaged terminal heat pumps (PTHPs) are used instead of SZHPs in guest rooms compared to split DX/furnace systems with individual flues.

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Packet Pg. 715 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 18 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Table 7. Small Hotel HVAC and Water Heating System Costs Components
Baseline – Mixed Fuel Proposed – All-electric Incremental Cost Description
Non-residential spaces: Packaged
units, boilers, hot water piping,
VAV boxes, ductwork, grilles, gas
water heater for laundry
Guest rooms: SZAC + furnace,
central gas water heater
Non-residential spaces:

Packaged units, electric
resistance VAV boxes, electric
circuitry, ductwork, grilles, heat
pump water heater for laundry
Guest rooms: SZHP, central
heat pump water heater
HVAC (NR and Guest Rooms)
Electrification
SHW (Laundry Room and
Guest Rooms)
HVAC - Material $802,004 $625,642 $(176,361)
HVAC - Labor $366,733 $282,394 $(84,339)
SHW - Material $55,829 $139,087 $83,258
SHW - Labor $11,780 $15,080 $3,300
Electric
Infrastructure
$- $119,625 $119,625
Gas Infrastructure $74,943 $- $(74,943)
Overhead & CZ
adjustment **
$518,741 $461,001 $(57,739)
TOTAL $1,830,029 $1,642,830 $(187,199)
TOTAL
HVAC (PTHP option)
$1,830,029 $1,161,178 ($668,851)
** The overhead and CZ adjustment factors are presented in 8.3.

3.2.1.2 Commercial Cooking Equipment
For Quick-Service Restaurant prototype, the Reach Code Team evaluated electrification of commercial cooking equipment extensively in 2019 Restaurants Cost Effectiveness analysis and leveraged it for cost and other specifications for the this study. It assumes a Type I exhaust hood and shows high incremental cost affecting the costeffectiveness of this measure. Table 8 summarizes the quick-service restaurant cooking equipment costs for both mixed-fuel and all-electric scenarios.

Table 8. Quick-Service Restaurant Cooking Equipment Costs Components
Baseline – Mixed Fuel
Proposed – All-electric (non
“HS” scenario) Incremental Cost
Description Gas based appliances Electric cooking appliance Cooking appliance electrification
Cooking equipment
cost
$21,649 $43,534 $21,886
TOTAL $21,649 $43,534 $21,886
This measure also adds electric infrastructure cost as detailed in Table 10 below.

3.2.1.3 Commercial Clothes Dryer
For the all-electric measure, the Reach Code Team assumed electric resistance clothes dryers for Small Hotel prototype. Commercial-scale heat pump clothes dryers take significantly longer time to dry compared to a conventional

10.B.b
Packet Pg. 716 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 19 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 gas or electric dryer and are not common in the United States On-Premise Laundry (OPL) market, where labor is relatively expensive and use of heat pump dryers implies hotels may need to require more than one shift to perform laundry duties. Most commercial clothes dryers are available in models that use either gas or electricity as the fuel source, so there is negligible incremental cost for electric resistance dryers. Table 9 summarizes the Small Hotel construction costs for both mixed-fuel and all-electric OPL scenarios.

Table 9. Small Hotel Clothes Dryer Costs
Components
Baseline – Mixed Fuel Proposed – All-electric Incremental Cost Description Gas clothes dryer Electric resistance clothes dryer -
Clothes Dryer cost $29,342 $29,342 $0
TOTAL $29,342 $29,342 $(0)
This measure also adds electric infrastructure cost as detailed in Table 10 below.

3.2.1.4 Infrastructure Impacts

3.2.1.4.1 Electrical infrastructure
Electric heating appliances and equipment often require a larger electrical connection than an equivalent gas appliance because of the higher voltage and amperage necessary to electrically generate heat. Thus, many buildings may require larger electrical capacity than a comparable building with natural gas appliances. This includes:
▪ Electric resistance VAV space heating in the medium office and common area spaces of the small hotel. ▪ Heat pump water heating for the guest room spaces of the small hotel.

Table 10 details the cost impact of additional electrical panel sizing and wiring required for all-electric scenarios as compared to their corresponding mixed-fuel scenario The costs are based on estimates from one contractor. The Reach Code Team excluded costs associated with electrical service connection upgrades because these costs are very often rate-based and highly complex.

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Packet Pg. 717 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 20 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Table 10. Electrical Infrastructure Costs
Mixed-Fuel Equipment All-electric Equipment Electrical Infrastructure Impact
Incremental
Cost
Medium
Office
Hot water reheat system
with gas boiler plant and
VAV boxes with hot water
reheat coils
VAV boxes with electric
resistance reheat coils
Upgraded transformers,
transformer feeders,
switchboards, and branch
circuits
$ 112,340
Medium
Retail
Mix of SZHPs and single zone
AC plus furnace serving all
zones
SZHPs serving all zones Electrical requirements are
driven by cooling capacity,
so no impact.
$0
Quick-Service
Restaurant
Gas water heater Heat pump water heater Upgraded switchboard, transformer feeder, and
branch circuits
$12,960
Gas Water heater, Gas
cooking
Heat pump water heater,
Electric cooking
Upgraded switchboard,
transformer feeder, and
branch circuits
$95,260
Small Hotel Guest rooms HVAC: Single
zone AC plus furnace
Non-residential spaces
HVAC: Hot water reheat
system with gas boiler plant
and VAV boxes with hot
water reheat coils.

Water heating: Gas water
heating serving both laundry
and guest rooms.

Process: Gas dryers.

Guest rooms HVAC: SZHPs
Non-residential spaces
HVAC: VAV boxes with
electric resistance reheat
coils.

Water heating: Heat pump
water heating serving both
laundry and guest rooms.

Process: Electric resistance
dryers.

Upgraded transformers,
transformer feeders,
switchboards, and branch
circuits
$119,625

3.2.1.4.2 Gas Piping
The Reach Code Team assumes that gas would not be supplied to the site in an all-electric new construction scenario.

Eliminating natural gas in new construction would save costs associated with connecting a service line from the street main to the building, piping distribution within the building, and monthly connection charges by the utility.

The Reach Code Team determined that for a new construction building with natural gas piping, there is a service line (branch connection) from the natural gas main to the building meter. Table 11 gives a summary of the gas infrastructure costs by component, assuming 1-inch corrugated stainless-steel tubing (CSST) material is used for the plumbing distribution. The Reach Code Team assumes that the gas meter costs vary depending on the gas load.

Based on typical space heating loads for all building types, the Reach Code Team categorized CZs 1 and 16 as ‘Highload CZs’ and CZs 2-15 as ‘Low-load CZs’. The Reach Code Team assumed an interior plumbing distribution length based on the expected layout. Table 12 gives the total gas infrastructure cost by building type. The costs are based on estimates from one contractor.

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Packet Pg. 718 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 21 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Table 11. Gas Infrastructure Costs by Component
Component Details Cost
Meter, including Pressure
Regulator, and Earthquake Valve
Low load CZ (CZ 2-15) $11,056
High load CZ (CZ 1,16) $15,756
Gas lateral Cost per linear foot of 1" CSST $40
Connection charges Includes street cut and plan review $1,015 Interior plumbing distribution Cost per linear foot of 1" CSST $40 Table 12. Total Gas Infrastructure Cost Estimates by Building Type Total gas infrastructure cost
Building Prototype Interior plumbing distribution length (ft) Low load CZ High load CZ Medium Office 100 $17,307 $22,007
Medium Retail 100 $17,307 $22,007
Quick-Service Restaurant 100 $2,017*
Small Hotel 1,412 $70,243 $74,943
*The Quick-Service Restaurant package includes gas cooking appliances, which will require a gas lateral and meter. These costs represent only the interior plumbing distribution costs that would have served the HVAC and SHW systems.

3.2.2 Efficiency
The Reach Code Team started with a potential list of energy efficiency measures proposed for the 2025 Title 24 energy code update by the Statewide Building Codes Advocacy program (CASE Team)5, which initially included over 500 options. Other options originated in previous energy code cycles or were drawn from other codes or standards (examples: ASHRAE 90.1 and International Energy Conservation Code [IECC]), literature reviews, or expert recommendations. The Reach Code Team leveraged the CASE Team's assessment tools for the 2025 Cycle, focusing on measures prioritized by the CASE Team. The Reach Code Team filtered the list of potential measures based on building type (to remove measures that applied to building types not covered in this study), measure category (to remove end-uses and loads that are not relevant to the prototypes) and impacts to new construction. Based on this filtering, the Team was left with around 100 measures to consider. The Reach Code Team ranked this list of potential measures based on applicability to the prototypes in this study, ability to model in simulation software, demonstrated energy savings potential, and market readiness.

Please note that the measures requiring a ruleset update cannot currently be modeled for compliance purposes. The modeling method for each efficiency measure is defined in their respective measure descriptions in Section 3.2.2.1 and if the ruleset amendment was applied. Please refer to Section 2.5 for further details.

The subsections below describe the energy efficiency measures that the Team analyzed, including description, modeling approach, and specification.

3.2.2.1 Envelope

1. Cool Roof: Requires higher reflectance and emittance values for the Medium Office building only. This measure was not shown to produce substantial savings in the other prototypes. 5 https://title24stakeholders.com/

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Packet Pg. 719 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 22 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Modeling: Modeled cool roof measure in efficiency measures package by updating Aged Solar Reflectance (ASR) and/or Thermal Emittance (TE) in CBECC software.

Specification: Increased ASR from 0.63 to 0.70 with a TE of 0.85 in CZs 4 and 6-15.

2. Efficient Vertical Fenestration: Requires lower U-factor and Solar Heat Gain Coefficient (SHGC) for windows in select climate zones for three building types (Medium Office, Retail, and Small Hotel). The measure details and the climate zone selection are based on the proposition of 2022 NR CASE Report (Statewide CASE Team 2020 B).

Modeling: Modeled high performance windows in efficiency measures package by updating U-factor and SHGC inputs in CBECC software.

Specification: Reduced U-factor from 0.36 to 0.34 and SHGC from 0.25 to 0.22 in CZs 2, 6, 7 and 8 for Medium Office and Retail, Reduced U-factor from 0.36 to 0.34 and SHGC from 0.25 to 0.22 in all CZs for Small Hotel.

3. Vertical Fenestration as a Function of Orientation: Limit the amount of fenestration area as a function of orientation for the Medium Office. East-facing and west-facing windows are each limited to one-half of the average amount of north-facing and south-facing windows.

Modeling: Change z-coordinate input of windows in CBECC software for Medium Office to increase or decrease fenestration area for the Medium Office.

Specification: Decreased east-facing and west-facing fenestration area from 468 to 390 square feet.

Increased north-facing and south-facing fenestration area from 703 to 781 square feet.

3.2.2.2 Mechanical Equipment (SHW and HVAC)

4. Water Efficient Fixtures in Kitchen: Specifies commercial dishwashers that use 20% less water than ENERGY STAR® specifications. In addition, the dishwasher includes heat recovery function such that it only needs connection to cold water and reduces hot water demand and central SHW system capacity. For QSRs, which typically specify a three-compartment sink for dishwashing, this measure would replace or add a dishwasher to reduce total hot water load. The measure also adds 1.0 gallon per minute (GPM) faucet aerators to hand-washing sinks in the kitchen to reduce water usage. Title 20 requires kitchen sinks to have a flow rate of 1.8 GPM at most. The reduced hot water load from the water efficient fixtures above allows the heat pump water heater (HPWH) to operate without an electric resistance back-up.

Modeling: Reduced water usage in the ruleset based on calculations of expected water usage from literature review and fixture specifications. HPWH coefficient of performance (COP) is increased since there is no electric resistance back-up.

Specification: Decreased hot water usage by 26% in the software ruleset (13.4 gallons per person to 9.9 gallons per person) and increased HPWH COP from 3.1 to 4.2.

5. Ozone Washing Machines: Adds an ozone system to the large on-premises washing machines. The ozone laundry system generates ozone, which helps clean fabrics by chemically reacting with soils in cold water. This measure saves energy by reducing hot water usage and by reducing cycle time for laundry systems. Refer to DEER Deemed measure SWAP005-01 for more information (California Public Utilites Commission 2022).

Modeling: Reduced the total runtime of each cycle and hot water hourly usage per person (gallons per hour per person) for laundry area in software ruleset.

Specification: Reduced hot water usage by 85%, from 48.4 to 7.3 gal/hour-person based on the deemed measure data from the California electronic Technical Reference Manual (California Technical Forum 2022).

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Packet Pg. 720 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 23 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24

6. Efficient Hot Water Distribution: Reduces domestic hot water (DHW) distribution system pipe heat losses in two ways. First, the Team used pipe sizing requirements in Appendix M of the California Plumbing Code instead of Appendix A. Appendix M reduces pipe diameters for the cold and hot water supply lines based on advancements made in water efficiency standards for plumbing fixtures found in hotel bathrooms. Second, the Team added more stringent pipe insulation thickness requirements for hotels to match that of single and multifamily dwellings using Title 24 Table 160.4-A Pipe Insulation Thickness Requirements for Multifamily DHW Systems instead of Table 120.3-A.

Modeling: The Team calculated the pipe heat loss savings for the Small Hotel prototype by following the modelling methodology applied to the low-rise loaded corridor multi-family building prototype in the 2022 CASE Multifamily Domestic Hot Water Distribution report (Statewide CASE Team 2020 A). The Team designed a riser distribution system for the Small Hotel prototype building using the baseline Appendix A and modern Appendix M pipe sizing tables. The pipe design and total pipe surface area of the supply and return lines for the Small Hotel closely matched the Low-Rise Loader Corridor Building prototype. The hotel insulated pipe heat loss for both Appendix A and M was approximated from the multifamily building heat loss modelling results for the 16 CZs and water heater energy savings calculated for the two sub-measures.

Specification: (a) Pipe diameter decreased from Appendix A requirements to Appendix M multifamily plumbing requirements (b) For pipe diameters at or above 1.5 inches, increase the insulation thickness from 1.5 to two inches thick for fluids operating in the 105-140⁰F temperature range. . The Team reduced the DHW energy consumption by 0.4 – 0.7% depending on CZ in a postprocessing of the model.

7. Demand Control Ventilation (DCV) and Transfer Air: The California Energy Code requires kitchen exhaust to have DCV if the exhaust rate is greater than 5,000 cfm. This measure expands this requirement and applies DCV regardless of the exhaust rate for the QSR. Additionally, the kitchen makeup air supply is decreased by requiring at least 15% of replacement air to come from the transfer air in the dining space that would otherwise be exhausted.

Modeling: Changed exhaust fan from constant speed fan to variable speed and reduce kitchen ventilation airflow rate for the QSR.

Specification: Changed Kitchen Exhaust Fan Control Method to Variable Flow Variable Speed Drive, reduced kitchen ventilation from 2,730 cfm to 2,293 cfm.

8. Guest Room Ventilation and Fan Power: Uses the 2021 IECC fan power limitation requirements for ventilation fans under 1/12 horsepower, and approximates the ASHRAE 90.1 Small Hotel guestroom control requirements, which require shutting off ventilation within five minutes of all occupants leaving the room and changing the cooling setpoint to at least 80⁰F and heating setpoint to at most 60⁰F.

Modeling: Since variable occupancy cannot be modeled in CBECC, the Reach Code Team revised the software ruleset ventilation schedule and setpoints from 8:00 AM to 7:00 PM—the time range where the CBECC software assumed occupancy to be less than half for all guestrooms.

Specification: Heating setpoint reduced from 68°F to 66°F, cooling setpoint increased from 78°F to 80°F PM, and ventilation shut off from 8:00 AM to 7:00 PM. Guestroom ventilation fans have fan efficacy of 0.263 W/cfm.

9. Variable speed Fans: Require variable speed fans at lower capacities than required by Title 24 Part 6 Section 140.4(m), currently at 65,000 Btu/hr. This measure is based on the 2022 Title 24 Part 6, Section 140.4(m),

10.B.b
Packet Pg. 721 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 24 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 where direct expansion units greater than 65,000 Btu/hr that control the capacity of the mechanical cooling directly shall have a minimum of two stages of mechanical cooling capacity and variable speed fan control.

Modeling: Reduced the cooling capacity threshold from 65,000 Btu/hr to 48,000 Btu/hr. Changed the supply fan control from constant speed to variable speed for zones that have cooling capacity > 48,000 Btu/hr and < 65,000 Btu/hr in the Medium Retail and QSR.

Specification: Changed the supply fan control from Constant Volume to Variable Speed Drive for the Front Retail and Point-of-Sale thermal zones in Medium Retail prototype and the Dining Zone in the QSR prototype.

3.2.2.3 Lighting

10. Interior lighting reduced lighting power density: Update lighting power densities (LPD, measured as Watts/ft2) requirements based on technology advances (e.g., optical efficiency, thermal management, and improved bandgap materials). Identify spaces with opportunities for more savings from lowered LPDs—not all spaces are subject to LPD reductions. Take into consideration IES recommended practices and biological effectiveness metrics (such as WELL) when developing the proposed LPD values (WELL 2022).

The 2022 Indoor Lighting CASE Study (Statewide CASE Team 2021 D) provided a survey of 2x2 troffer products available in the Design Lights Consortium Qualified Products List (DLC-QPL) and the efficacy level each measured. This study indicated that at the time of the report approximately 20% of available DLC-QPL products exceeded the performance level of the ‘Standard’ DLC-QPL listing by approximately 15%, meeting the ‘Premium’ listing criteria. The Title 24 2022 CASE Report uses the ‘Standard’ designation performance level as the design baseline for all the LPD calculations in the code. This document proposes using the ‘Premium’ designation performance as the basis of the LPD allowances.

A DOE study on solid-state light sources (LEDs) provides projections of efficacy improvement for LED light sources that are in the range of 2.5 to 3% per year, continuing for the next five or ten years (U.S. Department of Energy 2019 B). So, the products offered for sale by the luminaire manufacturers are improving as older products are discontinued and newer ones are introduced. Even in just three years, the overall performance of the products available can improve by 7 to 9%.

A recent Navigant LED pricing study shows a slightly negative cost to efficacy correlation, indicating that higher performing products may be slightly lower in cost (Navigant Consulting 2018). This is likely to be in part caused by the decreasing cost of the LED chips with each subsequent generation produced. There is likely to be no cost associated with employing higher performing LED luminaires.

Modeling: Reduce LPDs by approximately 13% in each space listed below under regulated lighting below Title 24 prescriptive requirements.

Specification: Medium Office
• All spaces: 0.52 W/ft2
Medium Retail
• Storage: 0.36 W/ft2
• Retail sales: 0.86 W/ft2
• Main entry lobby: 0.63 W/ft2
QSR
• Dining: 0.41 W/ft2
• Kitchen: 0.86 W/ft2
Small Hotel

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Packet Pg. 722 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-Effectiveness Analysis: Nonresidential New Construction Buildings 25 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Stairs: 0.54 W/ft2
Corridor: 0.36 W/ft2
Lounge: 0.50 W/ft2
The measures are summarized below by building type, including measure costs, in Table 13.

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Packet Pg. 723 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 26 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Table 13. Efficiency Measures Applicability, Costs, and Sources Measure Applicability
• Included in packages with energy efficiency measures
- Not Applicable
Measure
Baseline T24
Requirement Proposed Measure
Med
Office
Med
Retail
QuickService
Restaurant
Small
Hotel:

Guest
Rooms
Small Hotel:

Nonresidential
Incremental
Cost Sources & Notes
Envelope

1. Cool Roof For low slope roofs:

ASR = 0.63
TE = 0.75
For low slope roofs:

ASR = 0.7
TE = 0.85
● ─ ─ ─ ─ $0.04/ft2
Final Nonresidential High
Performance Envelope Case
Report (Statewide CASE Team
2020 B)

2. Efficient
Vertical
Fenestration
U-factor = 0.36
SHGC = 0.25
U-factor = 0.34
SHGC = 0.22
● ● ─ ● ● $1.75/ft2
Final Nonresidential High
Performance Envelope Case
Report (Statewide CASE Team
2020 B)

3. Vertical
Fenestration
as a Function
of Orientation
40% window-to-wall
ratio in each
orientation per Title
24 Table 140.3-B.

Redistribute window
areas by orientation
● ─
─
─ ─ $0
No additional cost. This
measure is a design
consideration.

HVAC and SHW

4. Water
Efficient
Fixtures in
Kitchen
Kitchen faucet max
flow rate is 1.8 GPM
(Title 20)
Kitchen faucet flow
rate is 1 GPM
─ ─ ● ─ ─
High efficiency,
door-type, high
temperature
dishwasher:
$7,633/unit
Faucet aerator:
$8/unit
Combination of literature
review, online sources such as
Home Depot and
manufacturer websites

5.Ozone
Washing
Machine
Not required Reduced hot water
use
─ ─ ─ ─ ● $25,469/unit
DEER Deemed measure
SWAP005-01 (California
Public Utilites Commission
2022)

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Packet Pg. 724 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-effectiveness Analysis: Nonresidential New Construction 27 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Measure Applicability
• Included in packages with energy efficiency measures
- Not Applicable
Measure
Baseline T24
Requirement Proposed Measure
Med
Office
Med
Retail
QuickService
Restaurant
Small
Hotel:

Guest
Rooms
Small Hotel:

Nonresidential
Incremental
Cost Sources & Notes

6. Efficient Hot
Water
Distribution
Appendix A Pipe
Sizing with standard
pipe insulation
thickness 1.5’’
Appendix M pipe
sizing with 2” pipe
insulation thickness
─ ─ ─ ● ─ $5,819
Multifamily Domestic Hot
Water Final CASE Report

7. DCV &
Transfer Air
DCV required in
kitchen for exhaust
air rate > 5000 cfm
DCV for all exhaust
fans ─ ─ ● ─ ─ $8,500
Mechanical contractor cost
estimate

8. Guest Room
Ventilation,
Temperature
Setback, and
Fan Power
Guest rooms
required to have
occupancy sensing
zone controls, but
no ventilation fan
power requirement.

Updated fan power
and HVAC schedules
─ ─ ─ ● ─ $0
No cost increase, as guest
rooms already have controls.

9. Variable
Speed Fans
Variable speed
required if cooling
capacity is greater
than 65,000 Btu/h
Variable speed
control for smaller
capacity systems
─ ● ● ─ ─ $6,390/unit
Mechanical contractor cost
estimate
Lighting

10. Interior
Lighting
Reduced LPD
Per Area Category
Method, varies by
Primary Function
Area.

Top 20% of market
products
● ● ● ─ ● $0
Industry report on LED pricing
analysis shows that costs are
not correlated with efficacy.
(Navigant Consulting 2018)

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Packet Pg. 725 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-effectiveness Analysis: Nonresidential New Construction 28 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24

3.2.3 Load Flexibility
The Reach Code Team investigated a range of high-impact demand flexibility strategies potentially applicable to the four prototypes. The list of strategies is informed by DOE’s Grid-interactive Efficient Buildings efforts and the 2022 Nonresidential Grid Integration CASE report (U.S. Department of Energy 2021, Statewide CASE Team 2020). The Team selected the three measures based on their load flexibility potential, cost, compliance software modeling capabilities, savings potential and the ease of project implementation and field verification:

Please note that these measures require a ruleset update and cannot be modeled currently for compliance purposes.

11. Temperature Setback using Smart Thermostat: This measure leverages the existing mandatory requirement for HVAC zone thermostatic controls to pre-condition spaces prior to, and to shed demand during, peak period. This measure introduces a setback in temperature setpoint during peak period and incurs no additional cost because Occupant-Controlled Smart Thermostats (OCSTs) are already required for buildings similar to the Medium Office prototype.

Modeling: Instead of utilizing the demand responsive features, OCST would be used to change temperature setpoints and setpoint schedules. These changes were integrated by altering the setpoint schedules directly in the backend ruleset files of CBECC software.

Specification: In the base case, the Medium Office prototype HVAC equipment schedules dictate "on" hours (at desired temperature) from 6:00 AM through 12:00 AM on weekdays and 6:00 AM – 7:00 PM on Saturdays. All Sunday hours are "off." Cooling setpoints are 75°F during "on" and 85°F when "off" hours; heat setpoints are 70°F during "on" and 60°F during "off" hours. The Team modified this schedule such that the "on" setpoints are stepped back by 2°F from 4:00 PM through 12:00 AM on weekdays; and from 4:00 PM – 7:00 PM on Saturdays.

12. Demand Response Capable HPWH: The Reach Code Team modeled a measure intended to reduce the peak demand of the significant hot water loads in the QSR prototype. The measure increases costs due to adding a 100-gallon storage tank and plumbing hardware. The additional hot water storage enables preheating water ahead of demand by effectively increasing the HPWH’s thermal storage capacity. The extra plumbing hardware is needed to keep the stored hot water stratified to maintain efficient HPWH operations.

The Team did not directly address the issue of storage tank location but assumed floor plan design would be able to accommodate it.

Modeling: The measure uses the HPWH and additional storage tank capacity to produce and store hot water ahead of actual use during evening peak period. QSR hot water baseline schedule exhibits a low morning load (6:00 AM – 8:00 AM), moderate load near lunch time (11:00 AM), and a peak evening load (4:00 PM – 11:00 PM). These changes were made by changing the hot water load fraction in the ruleset.

Specification: Implements an early pre-heat that starts at 12:00 PM and finishes by 7:00 PM, avoiding the super peak hours of 7:00 PM – 9:00 PM.

13. Demand Response Lighting: This measure extends existing Title 24 mandatory requirements for demand responsive lighting by shedding demand during peak hours. There are no additional measure costs because demand responsive control capability is already required for nonresidential buildings with more than 4kW of total lighting load. This measure does not require additional commissioning.

Modeling: The baseline lighting schedule exhibits a plateau of 0.65 load fraction from 8:00 AM – 8:00 PM and trails off after 8:00 PM through the end of the day for weekdays. The Team altered the ruleset to reduce the load fraction during 4:00 PM – 9:00 PM.

Specification: The Team implemented a 10% setback during the 4-9pm peak hours.

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Packet Pg. 726 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 29 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 The load flexibility measure applications to each prototype are summarized in Table 14.

Table 14. Load Flexibility Measure Summary
Measure
Med
Office
Med
Retail
QSR Small Hotel Incremental Cost Other Notes

11. Smart
Thermostat
● - - - $0 Capability already required

12. Demand Control
HPWH - - ● - $5,400
An additional 100-gallon tank,
plumbing hardware, and related
labor hours

13. Demand
Response Lighting
● - - - $0 Capability already required
None of the measures apply to the Medium Retail or Small Hotel prototypes. While the Small Hotel contains some office space and common areas, the Medium Office load flexibility measures were not applied to the Small Hotel spaces because of the potential for unpopular impacts, varying occupancy schedules, difficult field maintenance, and limited energy impacts. Team also explored the impact of load flexibility in all-electric clothes dryer scenario but did not see enough savings impact, hence the measure was not included in the package.

3.2.4 Additional Solar PV and Battery Storage
The Reach Code Team considered additional solar PV and battery storage measures that exceed the 2022 Title 24 prescriptive requirements to improve the cost-effectiveness of proposed scenarios. For Medium Office and Retail, the prescriptive solar PV sizes are large enough to occupy the entirety of the available roof space. Additional rooftop solar PV could not be considered for the two prototypes. For the Quick-Service Restaurant, solar PV is not prescriptively required since the prototype qualifies for the exception and the Reach Code Team considered adding solar PV to improve cost-effectiveness. For Small Hotel, the required PV size in the code-compliant models did not occupy the entire available roof space. Additional PV system capacity was considered as a measure to improve cost-effectiveness.

For the cost-effectiveness analysis, the Team evaluated additional solar PV for all-electric scenarios for the two building types, Quick Service Restaurant and Small Hotel. The additional PV size is calculated based on available roof space, assuming the maximum available space is 50% of total roof space and 15 Watt per square foot panel size.

Modeling: Updated PV capacity (kW) input in CBECC software.

Specification: Baseline requirement is 0 kW and 22-32.6 (depending on climate zone) kW for Quick-Service Restaurant and Small Hotel respectively. Proposed measure specification is 18.8 kW and 79.8 kW for Quick-Service Restaurant and Small Hotel respectively.

The costs for PV include first cost to purchase and install the system, inverter replacement costs, and annual maintenance costs. A summary of incremental costs and sources is given in Table 15 below.

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Packet Pg. 727 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 30 Prototypes, Measure Packages, and Costs
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Table 15. Additional Solar PV Measure Summary
Measure
Med
Office
Med
Retail
QSR
Small
Hotel
Incremental Cost Cost Source
Solar PV - - ● ●
First Cost: $3.20/W
Inverter replacement cost at 10-yr:
$0.15/W
Annual Maintenance Cost: $0.02/W
ITC Federal Incentive: 30%
National Renewable Energy
Laboratory (NREL) Q1 2016
(National Renewable Energy
Laboratory 2016)
E3 Rooftop Solar PV System
Report (Energy and
Environmental Economics,
Inc. 2017)
Upfront solar PV system costs are lowered because of the federal income tax credit (ITC)—approximately 30 percent based on the passage of Inflation Reduction Act. PV energy output is built into CBECC and is based on NREL’s PVWatts calculator, which includes long term performance degradation estimates.

A battery storage system is prescriptively required for three prototypes: Medium Office, Medium Retail, and Small Hotel. The current software, CBECC v1.0, applies the appropriate prescriptive battery size (kWh) and capacity (kW) in the standard design. However, the control assumed in standard design is “Basic Control”, which does not function for optimum battery use. The Team did not evaluate additional battery measures because the compliance software does not apply the “Time of Use” battery control method in standard design, which impacts the incremental energy costs and TDV benefits.

3.3 Measure Packages
The Reach Code Team compared a baseline Title 24 prescriptive package to mixed-fuel packages and two to four electrification packages depending on applicability of building type. Note that most QSR all-electric packages exclude kitchen electrification, while the Small Hotel all-electric package does include electric laundry cost and energy impacts. ▪ Mixed Fuel Code Minimum: Mixed-fuel prescriptive building per 2022 Title 24 requirements. ▪ Mixed Fuel + Efficiency Measures: Mixed-fuel prescriptive building per 2022 Title 24 requirements, including additional efficiency measures.
▪ All-electric Code Minimum Efficiency: All-electric building to minimum Title 24 prescriptive standards and federal minimum efficiency standards. This package has the same PV size as mixed-fuel prescriptive baseline. ▪ All-electric Energy Efficiency: All-electric building with added energy efficiency measures related to HVAC, SHW, lighting or envelope.
▪ All-electric Energy Efficiency + Load Flexibility: All-electric building with added energy efficiency and load flexibility measures.
▪ All-electric Energy Efficiency + Solar PV: All-electric building with added energy efficiency and additional Solar PV. The added PV size is larger than prescriptive 2022 Title 24 code requirements and accounts for roof space availability.

For QSR, the Reach Code Team has analyzed two scenarios for all-electric packages, one with electric cooking and the one with gas cooking (the latter of which is referred to as the “HS” package to reflect all-electric HVAC and SHW).

The results section includes results for both scenarios since all-electric package with electric cooking appliance can be cost-effective in POU territories. This study did not evaluate pre-empted package with all-electric HVAC and SHW to

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localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 have higher efficiency than required by federal regulations, that will potentially enhance cost-effectiveness and/or compliance margins.

For Small Hotel, the Reach Code Team also analyzed an alternative scenario with PTHP instead of SZHP in all-electric scenario. It is denoted by the “PTHP” in parenthesis in package name.

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Packet Pg. 729 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 32 Cost-Effectiveness Results
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 4 Cost-Effectiveness Results
Cost-effectiveness results are presented in this section and the attached workbook per prototype and measure packages described in Section 3. The TDV and On-Bill based cost-effectiveness results are presented in terms of B/C ratio and NPV.

In the following figures, the result Both (shown in green shading) indicates that the result is cost-effective on both OnBill and (Total) TDV basis. The result On-Bill or TDV (shown in yellow shading) indicates that the result is either costeffective on On-Bill or (Total) TDV basis, respectively. The result “ - “ (results with no shading) indicates that the result is not cost-effective on either an On-Bill basis or (Total) TDV basis.

Across all prototypes and climate zones, efficiency measures improve cost-effectiveness when added to the mixed-fuel baseline prototype and all-electric federal code minimum designs.

All-electric cost-effectiveness results by prototype can be summarized as:

Medium Office (Figure 1): All-electric space heating is predominantly achieved through electric resistance due to modeling limitations, which limits operational benefits. Efficiency measures yield some On-Bill costeffective all-electric packages in milder climate zones. Adding load flexibility measures increases the costeffectiveness to most climates.

Medium Retail (Figure 2): All-electric packages are cost-effective in all climate zones with added efficiency measures over all-electric baseline. Proposed mixed-fuel packages are cost-effective too with added efficiency measures in most climate zones primarily driven by cost-equivalency in the all-electric package compared to a mixed-fuel package.

Quick-Service Restaurant (Figure 3): All-electric package with and without cooking electrification is costeffective in CPAU and SMUD territories only, On-Bill. All-electric HVAC and SHW package with added efficiency measures is On-Bill cost-effective in CZs 1, 3-5 and 12. Adding efficiency and solar PV is On-Bill cost-effective in CZs 1-5, 11-13, and 16. While not depicted in Figure 3, the Results Workbook indicates that all-electric HVAC and SHW plus efficiency packages are nearly cost-effective (greater than -$350/month) in all climate zones using On-Bill Net Present Values.

Small Hotel (Error! Reference source not found.): The all-electric hotel has tremendous cost savings compared to a mixed-fuel package, primarily due to the avoidance of gas infrastructure to each guest room.

All-electric packages achieve TDV cost-effectiveness in all CZs except 16. On-Bill cost-effectiveness is limited to CZs 2-5, 12 and 15 with single zone ducted heat pumps, but nearly all CZs with a packaged terminal heat pump.

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4.1 Medium Office
In the all-electric Medium Office building, the upfront cost savings associated with avoiding boiler and gas infrastructure supports cost-effective packages in several climate zones, particularly with additional efficiency and load flexibility measures. ▪ Adding energy efficiency measures over mixed fuel code minimum is On-Bill cost-effective in all climate zones. ▪ The all-electric code minimum efficiency package is cost-effective for CZs 4 (CPAU), 6-10, 12 (SMUD) and 15. ▪ Adding energy efficiency measures to the all-electric code minimum package extends On-Bill cost-effectiveness to CZ 3 as well. ▪ All-electric energy efficiency along with load flexibility measure package is On-Bill cost-effective in most climate zones except 1, 11 and 16.

Figure 1. Medium Office Cost-Effectiveness Summary
CZ1 CZ2 CZ3 CZ4 CZ5 CZ6 CZ7 CZ8 CZ9 CZ10 CZ11 CZ12 CZ13 CZ14 CZ15 CZ16 Utility
Prototype Package
Both Both Both Both Both
Both Both Both Both Both
On-Bill ─ On-Bill ─ ─
On-Bill ─ On-Bill On-Bill ─
Both ─ Both ─ ─
Both ─ Both On-Bill ─
Both Both Both Both On-Bill
Both Both Both Both On-Bill
─
─
Medium Office
(MO)
Mixed Fuel + Efficiency
Measures
Both Both Both
All Electric Code
Minimum Efficiency
─ ─ Both
Both
Both
Both
Both
Both
─
Climate Zone

PG&E PG&E PG&E
PG&E
CPAU
PG&E
─
SDG&E
SCE
SCE
PG&E
SMUD
PG&E
Both
PG&E
PG&E
SCG

SCE SDG&E PG&E SCE
SDG&E
SCE
Both
Both On-Bill
Both
Both
Both Both Both
─ ─
All-Electric Energy
Efficiency + Load
Flexibility
─ Both Both On-Bill Both Both
All Electric Energy
Efficiency
─ ─ Both ─ ─
Both
On-Bill Both
Both Both
Both Both

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localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24

4.2 Medium Retail
2022 Title 24 code prescriptively requires heat pumps in most scenarios already. This report evaluates added energy efficiency measures over the baseline allelectric scenario and proposed mixed-fuel packages. ▪ The mixed-fuel code minimum is not cost-effective by itself in most climate zones. ▪ Adding energy efficiency measures to the mixed-fuel code minimum package is On-Bill and/or TDV cost-effective in most climate zones. ▪ Adding energy efficiency measures over prescriptive all-electric package is also cost-effective in most climate zones except CZ16 using TDV.

Figure 2. Medium Retail Cost-effectiveness Summary

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4.3 Quick-Service Restaurant (QSR)
High incremental cost for HVAC and SHW electrification (“HS” package) makes restaurant electrification challenging. Because cooking electrification packages are very expensive – both upfront and operationally in IOU territories – the Team evaluated HS packages that do not consider cooking equipment electrification.

This affects cost-effectiveness as gas infrastructure cost savings do not materialize. ▪ Adding energy efficiency measures over mixed fuel code minimum is On-Bill cost-effective in all climate zones. ▪ All-electric HVAC and SHW “HS” package is On-Bill cost-effective in CZ4 (CPAU) and CZ12 (SMUD) territory only. ▪ Adding energy efficiency and load flexibility measures extends On-Bill cost-effectiveness to CZs 1, 3 and 5. ▪ All-electric HVAC and SHW “HS” package with energy efficiency and solar PV measure is On-Bill cost-effective in climate zones 1-5, 11-13 and 16. ▪ All-electric package including cooking electrification is On-Bill cost-effective in CZ 4 (CPAU) territory only. ▪ The Results Workbook indicates that all-electric HVAC and SHW plus efficiency packages are nearly cost-effective (greater than -$350/month) in all climate zones using On-Bill Net Present Values.

Figure 3. QSR Cost-effectiveness Summary
CZ1 CZ2 CZ3 CZ4 CZ5 CZ6 CZ7 CZ8 CZ9 CZ10 CZ11 CZ12 CZ13 CZ14 CZ15 CZ16 Utility
Prototype Package
Both Both Both Both Both
Both Both Both Both Both
─ ─ ─ ─ ─
On-Bill ─ ─ On-Bill ─
─ On-Bill ─ ─ ─
On-Bill ─ ─ On-Bill ─
─ ─ ─ ─ ─
On-Bill ─ ─ On-Bill ─
On-Bill On-Bill ─ On-Bill ─
On-Bill On-Bill ─ On-Bill ─
─ ─ ─ ─ ─
On-Bill ─ ─ ─ ─
─ ─ ─ ─ ─
On-Bill ─ ─ ─ ─
─ ─ ─ ─
Quick-Service
Restaurant (QSR)
All Electric Energy
Efficiency
─ ─ ─ ─ ─ ─ ─
On-Bill
On-Bill ─
─
─ ─
─
─
─ ─ ─
PG&E
SMUD
PG&E
SDG&E
SCE

SCE PG&E
─ ─ ─ ─ ─ ─

SCE PG&E
SDG&E
SCE
Both
─
Both
─ ─ ─
Both Both Both Both
Climate Zone

PG&E PG&E PG&E
PG&E
CPAU
PG&E
SCG

SCE SDG&E PG&E
Both
All Electric HS Energy
Efficiency + Solar PV
All Electric Code
Minimum Efficiency
On-Bill
─
On-Bill On-Bill
Both
─
─
─
Mixed Fuel + Efficiency
Measures
Both Both
All Electric HS Code
Minimum Efficiency
All-Electric HS Energy
Efficiency + Load
Flexibility
On-Bill ─
All Electric HS Energy
Efficiency
On-Bill ─
─
Both
─
─ ─
On-Bill ─ On-Bill
─ ─ ─ ─ ─ ─ ─ ─ ─ ─
─ ─ ─ ─ On-Bill
─

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Packet Pg. 733 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-effectiveness Analysis: Nonresidential New Construction 36 Cost-Effectiveness Results
localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24

4.4 Small Hotel
The all-electric hotel has cost savings compared to a mixed-fuel package, primarily due to the avoidance of boilers and gas infrastructure to each guest room. The analysis assumes single zone ducted heat pump for all all-electric scenarios; however, the Team analyzed a Packaged Terminal Heat Pump (PTHP) scenario as well. PTHP shows higher incremental cost savings as compared to a baseline of mixed fuel single zone packaged system and hence are cost-effective in many climate zones.
▪ Adding energy efficiency measures over mixed fuel code minimum is On-Bill cost-effective in all climate zones. ▪ All-electric code minimum packages with or without energy efficiency measure packages are TDV cost-effective in all climate zones except 16, and OnBill cost-effective in CZ4 (CPAU) and CZ12 (SMUD) due to relatively lower electricity costs. ▪ Additional solar PV over all-electric energy efficiency package extends On-Bill cost-effectiveness to CZs 2, 3, 4 (PG&E), 5 and 15. ▪ The alternative all-electric scenario with PTHP is cost-effective in all climates, On-Bill in most CZs except 7,10 and 14 SDG&E territories.

Figure 4. Small Hotel Cost-effectiveness Summary

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Packet Pg. 734 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-effectiveness Analysis: Nonresidential New Construction 37 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 5 Energy Code Compliance Results and Reach Code Considerations This section combines the cost-effectiveness and 2022 Title 24 energy code compliance metric results — efficiency TDV, total TDV, and source energy, described in Section 2.3 — to highlight the viable reach code options for local jurisdictions. The Reach Code Team calculated metrics using both:

1. Software outputs using the ACM standard design and

2. Manually by subtraction against the baseline model because of software limitations that are beyond the Reach Code Team’s control.6
All Efficiency TDV margins presented in this section are the lower of the two approaches, Software output and Manual, to be conservative and inform the minimum compliance margins that can be met by a typical modeler. Full details of compliance margins and cost-effectiveness results are presented in the Final Results Workbook for reference.

Importantly, the workbook shows that for all prototypes, all-electric packages are capable of achieving greater greenhouse savings as compared to mixed-fuel buildings. Below is a summary of how compliance results as well as cost-effectiveness for each prototype and package could influence reach code options. The Reach Code Team outlines recommendations using the following framework, based on reach codes that were adopted across California under the 2019 building code cycle:
▪ Mixed fuel buildings are allowed, with efficiency. Local amendments governing efficiency and conservation must be performed in the Title 24 Part 6 Building Energy Efficiency Standards and be approved by the Energy Commission.
• Energy Efficiency — Require energy efficiency for buildings regardless of fuel type. A jurisdiction can require different compliance thresholds for all-electric and/or mixed-fuel. The thresholds should be set considering how they may affect mixed-fuel or all-electric buildings. • Electric-Preferred — Allow mixed-fuel appliances but require a higher building performance via efficiency, total, or source compliance metric (for example, (Milpitas 2019), section 140.1).7 Applies only to mixed-fuel buildings.
▪ Mixed fuel buildings are not allowed. Local amendments governing green building requirements may be performed in the Title 24 Part 11 Green Building Standards Code and must be filed with the Building Standards Commission. Alternatively, the local amendment may be performed in a municipal code chapter of their respective jurisdictions.
• All-Electric — Require certain all-electric only appliances, with exceptions (for example (Menlo Park 2019). Does not involve efficiency or conservation measures, and cost-effectiveness is a not a legal requirement.
8 Local amendments may be performed through other building code sections, such as Part 11. See discussion on Exceptions below.
• All-Electric + Efficiency — Require certain all-electric appliances, but with a higher building performance via efficiency, total, or source compliance metric. Also requires amendment to Title 24 Part 6 and approval by the Energy Commission.
6 The difference between the two methods of calculating TDV margins occurs due to various software limitations. The Team had challenges modeling a baseline showing zero-percent (exactly compliant) compliance margin, and differing interpretations of 2022 Title 24 code regarding fan power, exhaust fan, heat recovery, battery control, and other aspects. Most scenarios show similar trends between software calculated compliance margin and the Team’s manual subtraction against baseline model, with a difference in magnitude. For example, if the Total TDV Compliance margin as shown by software directly is negative, it is typically negative per manual calculation as well. Nonetheless, modeling limitations introduce error into the calculations, which may affect results. Many scenarios have very low negative compliance margin and are very close to being zero. While this uncertainty in error may lead to imprecision in results, relative performance across packages can yield information helpful for decision-making. 7 Note Milpitas has since adopted an All-electric with Exceptions code for the 2022 code cycle. 8 See letter from CEC to South San Francisco for reference.

Fo
H

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Packet Pg. 735 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 38 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Exceptions enable reach codes to broadly require electrification except for specific building systems. These systems may have uncertainty on energy code compliance, building industry electrification approaches, or other related impacts on economic development. During the 2019 code cycle, cities developed exemptions based on discussions with local stakeholders, resulting in a wide array of exemption types. 9 For the four prototypes in this
study, the Team has determined two exemptions that may be necessary for cities passing All-Electric reach codes. ▪ Building systems without a prescriptive compliance pathway in the energy code. This exemption considers that all-electric central space heating does not have a prescriptive pathway in Title 24, and central heat pump boilers cannot be currently modeled, which has impacted compliance results for the Medium Office and Small Hotel. This exemption has broad precedence and can apply to other large nonresidential buildings (e.g., (Berkeley 2019), section 12.80.040.A Exception 1). These exemptions typically state that the building is also not able to comply via the performance approach using commercially available technology. ▪ Commercial cooking. Cooking electrification does not considerably impact code compliance but is not nearly cost-effective against a mixed-fuel baseline. To account for this challenge, cities may wish to adopt reach codes that exempt commercial kitchen cooking appliances (e.g., (Menlo Park 2019) 100.0(e)2.A Exception 4). 9 See list of exemptions on Bay Area Reach Codes.

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Packet Pg. 736 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 39 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Table 16. Reach Code Pathway Considerations
Prototype Compliance and Cost-Effectiveness Results Summary Energy Efficiency ElectricPreferred All-Electric All-Electric + Efficiency
Medium
Office
The Team could not identify any all-electric package that complies with all three compliance metrics, with the Efficiency TDV Compliance margin being the most challenging.

Future iterations of this study will re-evaluate the Medium Office with a central heat pump boiler, an anticipated compliance software capability in early 2023, instead of electric resistance VAVs.

To Be Determined.

Modeling constraints
impacted achievable
compliance margins
for all-electric
packages.

All CZs. Exempt building
systems without a
prescriptive
pathway in the
energy code.

To Be Determined.

Modeling constraints
impacted achievable
compliance margins
for all-electric
packages
Medium
Retail
The Team identified cost-effective and code compliant packages of all-electric + energy efficiency measures across most CZs.

Mixed-fuel + efficiency was cost-effective but not code compliant in most CZs.

CZs 7 and 9. CZs 7 and 9. CZs 2-15. 2022
T24 prescriptive
baseline
CZs 1-10, 12-14.

QuickService
Restaurant
The Mixed-fuel + efficiency package is cost-effective and compliant in many climate zones. Code compliance and cost-effectiveness results support reach code adoption for all-electric space conditioning and service water heating when adding efficiency and solar PV for CZs 1 and 3-5, many others are likely to be compliant with future modeling input updates. Cost-effectiveness is achieved or nearly achieved (Net Present Value is greater than -$350/month) On-Bill in all CZs.

Cooking electrification does not impact code compliance but is not cost-effective against a mixed-fuel baseline except for CPAU territory.

CZs 1, 3-7. CZs 1-7, 13. CZs 1, 3-7. Exempt
commercial kitchen
appliances, except
CZ4 (CPAU).

Nearly all remaining
CZs have a nearly
cost-effective
and/or nearly
compliant pathway
for HVAC and SHW
only.

CZs 1, 3-5.

Small Hotel
Results support Electric-Preferred reach code for all CZs. The allelectric packages are near compliant and TDV cost-effective for most CZs when including energy efficiency measures and additional solar PV. They are likely to be compliant with future modeling iterations.

Future iterations of this study will re-evaluate the nonresidential areas of the hotel with a central heat pump boiler, as mentioned for the Medium Office, which can potentially improve code compliance.

To Be Determined.

Modeling constraints
impacted achievable
compliance margins
for all-electric
packages.

All CZs. Exempt building
systems without a
prescriptive
pathway in the
energy code.

To Be Determined.

Modeling constraints
impacted achievable
compliance margins
for all-electric
packages.

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Packet Pg. 737 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Cost-effectiveness Analysis: Nonresidential New Construction 40 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 The combined result of cost-effectiveness and code compliance across all climate zones and packages are detailed in Section 0 through 5.4 below. The tables are formatted to show:
▪ Cost-effectiveness results with color highlight:
• Green highlight — for scenarios that are cost-effective on both On-Bill and TDV metrics, may or may not be compliant.
• Yellow highlight — for scenarios that are cost-effective on either one of the On-Bill/TDV metrics, may or may not be compliant.
• Gray highlight — for scenarios that are not cost-effective on either metric, either compliant currently or likely to be compliant in future.
• White highlight — for scenarios that are not cost-effective on either metric and are not compliant. ▪ Compliance results with cell values:
• “EffTDV Margin” percentages — for scenarios that are compliant, across both Manual and CBECC software output, the reported value is the minimum of the two. • “-” for scenarios that do not comply across any one code compliance metric. “TBD” – for scenarios that are likely to be compliant with modeling updates or software versions in future, maybe compliant across either one of the Manual or CBECC software output approach or has a system type modeling limitation such as central heat pump boiler for Medium Office and Small Hotel. The package names in table results columns are as follows, as defined in Section 3.3:
▪ Mixed fuel — Code Min: Mixed Fuel Code Minimum Efficiency ▪ Mixed fuel — EE: Mixed Fuel + Efficiency Measures
▪ All-electric — Code Min: All-electric Code Minimum Efficiency ▪ All-electric — EE: All-electric Energy Efficiency
▪ All-electric — EE + LF: All-electric Energy Efficiency and Load Flexibility ▪ All-electric — EE + PV: All-electric Energy Efficiency and Solar PV The QSR has two electrification scenarios, with and without cooking appliance electrification, which is denoted by “HS” prefix.

The Small Hotel has an extra package that evaluates a different HVAC type in the all-electric Code Minimum Efficiency package, a Packaged Terminal Heat Pump (PTHP) instead of a Single Zone Heat Pump.

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5.1 Medium Office
For Medium Office, the Reach Code Team analyzed EE measures over mixed fuel baseline model and three electrification packages: 1) Code Min, 2) EE and 3) EE + LF packages, results shown in Table 17.

The most likely all-electric replacement for a central gas boiler serving a VAV 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. As such, 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. This modeling capability is anticipated in early 2023 according to discussions with the CBECC software development team, and the cost-effectiveness analysis should become available in the first half of 2023. Heat pump systems are multiple times more efficient, but may also be multiple times more costly, than the electric resistance reheat systems currently analyzed. ▪ Results support reach code adoption for energy efficiency measures over mixed fuel baseline, also known as the “Electric-Preferred”. A compliance margin of 4–5% is achievable depending on the climate zone. ▪ No all-electric package complies with all three-compliance metrics, with the efficiency compliance TDV margin being the most challenging. The Reach Code Team explored other efficiency measures that reduce the efficiency compliance TDV margin, but not enough to make the TDV margin positive. The compliance values are labeled as “TBD” for all-electric packages, as they are likely to be compliant with future modeling and/or software updates. Some climate zones are compliant currently on either one of the Software output or Manual compliance approaches.

Table 17. Cost-effectiveness and Compliance Summary – Medium Office CZ Utility
Mixed
Fuel All-electric
EE Code Min EE EE + LF
cz01 PG&E 4% TBD TBD TBD
cz02 PG&E 5% TBD TBD TBD
cz03 PG&E 5% TBD TBD TBD
cz04 PG&E 4% TBD TBD TBD
cz04-2 CPAU 4% TBD TBD TBD
cz05 PG&E 5% TBD TBD TBD
cz05-2 SCG 5% TBD TBD TBD
cz06 SCE 6% TBD TBD TBD
cz07 SDG&E 7% TBD TBD TBD
cz08 SCE 6% TBD TBD TBD
cz09 SCE 4% TBD TBD TBD
cz10 SDG&E 4% TBD TBD TBD
cz10-2 SCE 4% TBD TBD TBD
cz11 PG&E 3% TBD TBD TBD
cz12 PG&E 4% TBD TBD TBD
cz12-2 SMUD 4% TBD TBD TBD
cz13 PG&E 4% TBD TBD TBD
cz14 SDG&E 4% TBD TBD TBD
cz14-2 SCE 4% TBD TBD TBD
cz15 SCE 3% TBD TBD TBD
cz16 PG&E 4% TBD TBD TBD

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Packet Pg. 739 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 42 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 * These results will be re-evaluated with central heat pump boiler system instead of electric resistance VAV systems, which largely are unable to achieve energy code compliance.

5.2 Medium Retail
For Medium Retail, the Team analyzed EE measure package over an all-electric baseline model and two mixed fuel packages — Code Min and EE, with results in Table 18. ▪ Results support reach code adoption for energy efficiency measures over mixed fuel code minimum package, also known as “Electric-Preferred” or “Energy Efficiency” reach code pathways in climate zones 7 and 9. ▪ Results also support “All-Electric + Efficiency” reach code option, with compliance margins of 4-14% above the all-electric code minimum baseline in climate zones 1-10 and 12-14. ▪ For some scenarios in climate zone 6, 8, 11, 15 and 16, labeled as “TBD”, the package is cost-effective and likely to be compliant in future with modeling input and/or software version updates.

Table 18. Cost-effectiveness and Compliance Summary – Medium Retail CZ Utility
Mixed Fuel Allelectric
Code Min EE EE
cz01 PG&E - - 6%
cz02 PG&E - - 4%
cz03 PG&E - - 12%
cz04 PG&E - - 11%
cz04-2 CPAU - - 11%
cz05 PG&E - - 12%
cz05-2 SCG - - 12%
cz06 SCE - TBD 9%
cz07 SDG&E - 12% 14%
cz08 SCE - TBD 8%
cz09 SCE - 11% 12%
cz10 SDG&E - - 3%
cz10-2 SCE - - 3%
cz11 PG&E - - TBD
cz12 PG&E - - 10%
cz12-2 SMUD - - 10%
cz13 PG&E - - 4%
cz14 SDG&E - - 7%
cz14-2 SCE - - 7%
cz15 SCE - - TBD
cz16 PG&E - - TBD
Cell Color
Cost effective on both TDV/On-Bill metrics
Cost effective on either TDV/On-Bill metrics
Compliant, not cost effective
Not compliant nor cost effective
Cell Value
X% EffTDV Compliance Margin percentages (Lowest common) Compliant on both Manual and Software output approaches TBD
Likely to comply with future modeling updates or software versions, maybe compliant on either Manual or Software output approach - Not compliant on either approach

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Cell Color
Cost effective on both TDV/On-Bill metrics
Cost effective on either TDV/On-Bill metrics
Compliant, not cost effective
Not compliant nor cost effective
Cell Value
X% EffTDV Compliance Margin percentages (Lowest common) Compliant on both Manual and Software output approaches TBD
Likely to comply with future modeling updates or software versions, maybe compliant on either Manual or Software output approach - Not compliant on either approach

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5.3 Quick-Service Restaurant (QSR)
The Team analyzed efficiency measures over a mixed fuel baseline and electrification packages, with and without cooking appliance electrification. For the “HS” scenario including HVAC and SHW electrification only, packages with EE, EE + LF and EE + PV were analyzed, with results in Table 19. ▪ Results support reach code adoption for energy efficiency measures over a mixed fuel baseline, also known as “Electric-Preferred” in climate zones 1 to 7 and 13, or “Energy Efficiency” in CZs 1 and 3 to 7. ▪ All-electric “HS” HVAC and SHW electrification can be adopted in CZs 1 and 3-7 since it is code compliant and nearly cost effective on at least one metric when energy efficiency measures and/or load flexibility or solar PV measure is added, demonstrated by yellow or gray cells. ▪ All-electric “HS” HVAC and SHW option with additional efficiency measures can be adopted in CZs 1 and 3-5.

Adding solar PV makes the package on-bill cost-effective on at least one metric marked as yellow cells.. ▪ Packages labeled as “TBD” may or may not be cost-effective but are likely to be compliant in the future with modeling input and/or software updates.

Table 19. Cost-effectiveness and Compliance Summary – Quick-Service Restaurant (without cooking electrification)
CZ Utility
Mixed Fuel All-electric "HS" (HVAC+SHW)
EE Code Min EE EE + LF EE + PV
cz01 PG&E 16% - 6% 16% 6%
cz02 PG&E 6% - TBD TBD TBD
cz03 PG&E 18% - 8% 13% 8%
cz04 PG&E 16% - 5% 8% 5%
cz04-2 CPAU 16% - 5% 8% 5%
cz05 PG&E 18% - 8% 15% 8%
cz05-2 SCG 18% - 8% 15% 8%
cz06 SCE 16% - 3% 6% 3%
cz07 SDG&E 21% - 9% 13% 9%
cz08 SCE TBD - - - -
cz09 SCE TBD - TBD TBD TBD
cz10 SDG&E TBD - - - -
cz10-2 SCE TBD - - - -
cz11 PG&E TBD - TBD TBD TBD
cz12 PG&E TBD - TBD TBD TBD
cz12-2 SMUD TBD - TBD TBD TBD
cz13 PG&E 7% - TBD TBD TBD
cz14 SDG&E TBD - TBD TBD TBD
cz14-2 SCE TBD - TBD TBD TBD
cz15 SCE TBD - TBD TBD TBD
cz16 PG&E TBD - - TBD -

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Packet Pg. 742 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 45 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 The Reach Code Team analyzed a completely all-electric package including cooking appliances, results shown in Table 20, which show compliance in many climate zones with added efficiency and load flexibility. Remaining CZs are “TBD”, except climate zone 16, which comply on either one of the Manual or Software output approaches currently and are likely to show compliance with future modeling updates. However, the all-electric package is costeffective in CZ4 CPAU territory only and very close to being cost-effective in SMUD territory. Cooking electrification is expensive and challenging to show cost-effective.

Table 20. Cost-effectiveness and Compliance Summary – Quick-Service Restaurant (with cooking electrification)
CZ Utility
All-electric
Code Min EE EE + LF
cz01 PG&E - 6% 15%
cz02 PG&E - TBD 2%
cz03 PG&E - 10% 14%
cz04 PG&E - 8% 10%
cz04-2 CPAU - 8% 10%
cz05 PG&E - 10% 17%
cz05-2 SCG - 10% 17%
cz06 SCE - 6% 10%
cz07 SDG&E - 11% 14%
cz08 SCE - TBD TBD
cz09 SCE - TBD TBD
cz10 SDG&E - TBD TBD
cz10-2 SCE - TBD TBD
cz11 PG&E - TBD 0%
cz12 PG&E - TBD TBD
cz12-2 SMUD - TBD TBD
cz13 PG&E - TBD TBD
cz14 SDG&E - TBD TBD
cz14-2 SCE - TBD TBD
cz15 SCE - TBD 2%
cz16 PG&E - - -

Cell Color
Cost effective on both TDV/On-Bill metrics
Cost effective on either TDV/On-Bill metrics
Compliant, not cost effective
Not compliant nor cost effective
Cell Value
X% EffTDV Compliance Margin percentages (Lowest common) Compliant on both Manual and Software output approaches TBD
Likely to comply with future modeling updates or software versions, maybe compliant on either Manual or Software output approach - Not compliant on either approach
Cell Color
Cost effective on both TDV/On-Bill metrics
Cost effective on either TDV/On-Bill metrics
Compliant, not cost effective
Not compliant nor cost effective
Cell Value
X% EffTDV Compliance Margin percentages (Lowest common) Compliant on both Manual and Software output approaches TBD
Likely to comply with future modeling updates or software versions, maybe compliant on either Manual or Software output approach - Not compliant on either approach

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5.4 Small Hotel
The Team analyzed EE package over mixed fuel baseline and three electrification packages - Code Min, EE, EE+PV, with results in Table 21.
▪ Results support reach code adoption for energy efficiency measures over mixed fuel baseline, also known as “Electric-Preferred” reach code pathway with 2-5% compliance margin. ▪ All-electric packages with efficiency measures and/or solar PV in most CZs are cost-effective and likely to be compliant in future with modeling and/or software version updates. Some climate zones are compliant currently across either one of the Manual or Software output approaches. ▪ All all-electric scenarios are labeled as “TBD” because 36% of conditioned floor area is nonresidential space and has the same system type limitation as Medium Office (see Section 5.1). Hence, the Small Hotel will be reevaluated as well with a central heat pump boiler system instead of electric resistance VAV system in early 2023. The current results show compliance on either one of the Manual or Software output approaches in some climate zones with efficiency measures and solar PV, still labeled as “TBD” until the software inconsistencies are resolved.

Table 21. Cost-effectiveness and Compliance Summary – Small Hotel.

Mixed Fuel
EE Code Min EE EE + PV
cz01 PG&E 5% TBD TBD TBD
cz02 PG&E 4% TBD TBD TBD
cz03 PG&E 5% TBD TBD TBD
cz04 PG&E 5% TBD TBD TBD
cz04-2 CPAU 5% TBD TBD TBD
cz05 PG&E 5% TBD TBD TBD
cz05-2 SCG 5% TBD TBD TBD
cz06 SCE 5% TBD TBD TBD
cz07 SDG&E 4% TBD TBD TBD
cz08 SCE 5% TBD TBD TBD
cz09 SCE 5% TBD TBD TBD
cz10 SDG&E 5% TBD TBD TBD
cz10-2 SCE 5% TBD TBD TBD
cz11 PG&E 3% TBD TBD TBD
cz12 PG&E 4% TBD TBD TBD
cz12-2 SMUD 4% TBD TBD TBD
cz13 PG&E 3% TBD TBD TBD
cz14 SDG&E 4% TBD TBD TBD
cz14-2 SCE 4% TBD TBD TBD
cz15 SCE 5% TBD TBD TBD
cz16 PG&E 2% TBD TBD TBD
CZ Utility All-electric
Cell Color
Cost effective on both TDV/On-Bill metrics
Cost effective on either TDV/On-Bill metrics
Compliant, not cost effective
Not compliant nor cost effective
Cell Value
X% EffTDV Compliance Margin percentages (Lowest common) Compliant on both Manual and Software output approaches TBD
Likely to comply with future modeling updates or software versions, maybe compliant on either Manual or Software output approach - Not compliant on either approach

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Packet Pg. 744 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 47 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 The Team analyzed an additional scenario that proposes PTHP compared to the same SZAC mixed fuel baseline model, results shown in Table 22. Though PTHP is a much cheaper alternative than SZHP, it is not compliant by itself.

Table 22. Cost-effectiveness and Compliance Summary – Small Hotel (PTHP) CZ Utility
All-electric
Code Min
(PTHP)
cz01 PG&E -
cz02 PG&E -
cz03 PG&E -
cz04 PG&E -
cz04-2 CPAU -
cz05 PG&E -
cz05-2 SCG -
cz06 SCE -
cz07 SDG&E TBD
cz08 SCE TBD
cz09 SCE TBD
cz10 SDG&E -
cz10-2 SCE -
cz11 PG&E -
cz12 PG&E -
cz12-2 SMUD -
cz13 PG&E -
cz14 SDG&E -
cz14-2 SCE -
cz15 SCE -
cz16 PG&E -
Cell Color
Cost effective on both TDV/On-Bill metrics
Cost effective on either TDV/On-Bill metrics
Compliant, not cost effective
Not compliant nor cost effective
Cell Value
X% EffTDV Compliance Margin percentages (Lowest common) Compliant on both Manual and Software output approaches TBD
Likely to comply with future modeling updates or software versions, maybe compliant on either Manual or Software output approach - Not compliant on either approach

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Packet Pg. 745 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 48 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 6 Conclusions
The Reach Code Team developed a variety of packages involving fuel substitution, energy efficiency, load flexibility, and solar PV, simulated them in building modeling software, and gathered costs to determine the cost-effectiveness of multiple scenarios. The 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, fuel costs, other costs, energy escalation rates, software or utility tariffs may change the results.

These results, including the attached Reach Code Results Workbook, indicate all-electric packages are capable of achieving the greatest GHG savings as compared to mixed-fuel buildings, see Appendix 8.5. Jurisdictions may adopt a variety of reach codes such as “Energy Efficiency”, “Electric-Preferred”, “All-Electric” or “All-Electric + Efficiency.” In summary:
▪ The Reach Code Team has identified a cost-effective and code compliant energy efficiency measure package for most prototypes and climate zones analyzed, which supports an “Electric-Preferred” and/or “Energy Efficiency” reach code pathways for jurisdictions.
▪ “All-Electric” reach codes are feasible for all building types and climate zones when Part 11 is modified, including some exceptions.
• All-electric HVAC consisting of packaged single zone systems, including rooftop units in the Medium Retail and Quick-Service Restaurant, and single zone heat pumps in the Small Hotel guest rooms, are widely shown to be cost-effective and energy code compliant, with exceptions in CZs 1 and 16. • All-electric SHW systems have a prescriptive pathway for all building types and have not been shown to be an impediment to cost-effectiveness or energy code compliance of all-electric packages in this study.
• All-electric laundry in the Small Hotel can be cost-effective with added energy efficiency and additional solar PV than required prescriptively by 2022 Title 24 code. • Medium Office all-electric packages are cost-effective with energy efficiency and load flexibility measures, but not code compliant due to the use of electric resistance VAV reheat systems. The Small Hotel faces a similar issue for its smaller nonresidential area HVAC systems in some climate zones.

This indicates that further efficiency measures would need to be added to achieve energy code compliance which may not be cost-effective. As described in Sections 5.1 and 5.4, modeling limitations impacted the code compliance results for the medium office and nonresidential portion of the small hotel. These prototypes will be re-evaluated using a more appropriate central heat pump boiler HVAC system, likely available in compliance software in early 2023. In the meantime, jurisdictions can choose to exempt building systems that do not have a prescriptive compliance pathway in the energy code. See Berkeley’s all-electric ordinance (Berkeley 2019) section 12.80.040.A Exception 1 for an example.
▪ Commercial kitchen electrification is challenging to design cost-effectively currently. These results align with a previous study focusing on restaurants (Statewide IOU Team 2022). Jurisdictions may choose to exempt cooking appliances until cost-effectiveness factors improve. See Menlo Park's ordinance (Menlo Park 2019) 100.0(e)2.A Exception 4 for an example.
▪ For the Medium Retail prototype in CZs 2 to 15, there is already a prescriptive pathway to comply with packaged single zone heat pumps in smaller (<240 kBtuh) thermal zones. This study supports an “All-Electric + Efficiency” reach code pathway for many climates. However, mixed-fuel scenarios with SZAC and gas furnaces for larger (>240 kBtuh) thermal zones are challenging to show cost-effectiveness and/or code compliance, except for climate zones 7 and 9, when including efficiency measures.

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Packet Pg. 746 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 49 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Further discussion is required at the jurisdiction and community members to review results and determine appropriate reach code pathways. Please refer to the limitations of this study, described in Section 2.5, while using them to inform reach code policies. Of note:
▪ The Team employed several CBECC ruleset modifications to support achieving cost-effective packages, especially load flexibility measures. Ruleset modifications cannot be used by the building industry for code compliance without supporting justification or alternate methods. Where jurisdictions want to encourage the adoption of Load Flexibility measures through modeling estimates, the Reach Code Team can support cities and building applicants by providing modeling approximations that may achieve similar energy and compliance total impacts, in coordination with the Energy Commission. For example, for the Demand Response Lighting measure, the Team may be able to share a TDV/ft2impact of the measure in that climate zone or provide guidance to the building applicant’s energy consultant on appropriate modeling and documentation. ▪ Results are predominantly based on the code compliance metrics that are manually calculated based on the mixed fuel baseline model and not the standard design model assumed by the current software version. The Team also provided software reported compliance metrics in the workbook for reference. The Team is in communication with software development team to resolve differences in future iterations of this study and the software and improve code compliance reporting.

Even considering the limitations, this study has identified a set of reach code pathways for all climate zones, and jurisdictions have broad discretion on how to interpret the study’s findings. Jurisdictions can adopt reach codes requiring energy efficiency via a Title 24 Part 6 local amendment, or electrification via a Title 24 Part 11 (or municipal code) amendment, or both. Jurisdictions may choose to except particular building systems from certain reach codes pathways.

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Packet Pg. 747 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 50 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 7 References
Berkeley. 2019. Local Energy Codes.
https://localenergycodes.com/download/398/local_government_adoption_ordinance/fieldList/Berkeley%20 2019%20All-Electric%20-%20Ordinance%207672.pdf.

California Building Energy Code Compliance. 2022. CBECC Title-24 Compliance Software. August 2. https://bees.noresco.com/software2022.html.

California Public Utilites Commission. 2022. "Workpaper and Disposition Archive." SWAP005. June 9. http://deeresources.net/workpapers.

California Technical Forum. 2022. THE CA ELECTRONIC TECHNICAL REFERENCE MANUAL (ETRM). June 9. http://www.caltf.org/etrm-overview.

E3. 2021. https://efiling.energy.ca.gov/GetDocument.aspx?tn=233260&DocumentContentId=65748 .

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. 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. 2019a. "Residential Building Electrification in California." April. Accessed 8 2, 2022. https://www.ethree.com/wpcontent/uploads/2019/04/E3_Residential_Building_Electrification_in_California_April_2019.pdf.

Energy and Environmental Economics, Inc. 2017. "2019 Update to the Title 24 Part 6 Building Energy Efficiency Standards: Rooftop Solar PV System." September. Accessed 8 2, 2022. file:///C:/Users/mflores/Downloads/TN221366_20171002T104342_Rooftop_Solar_PV_Stystem_Report%20( 1).pdf.

Lawrence Berkeley National Lab. 2020. Proving the Business Case for Building Analytics. October. http://smartenergy-analytics.org/assets/EMIS%20Report.pdf.

Menlo Park. 2019. Local Energy Codes.
https://localenergycodes.com/download/353/local_government_adoption_ordinance/fieldList/Menlo%20Pa rk%202019%20-%20Ordinance%201057.pdf.

Milpitas. 2019. Local Energy Codes.
https://localenergycodes.com/download/356/local_government_adoption_ordinance/fieldList/Milpitas%20L ocal%20Ordinance%20NO%2065%20148.pdf.

National Renewable Energy Laboratory. 2016. "U.S. Solar Photovoltaic System Cost Benchmark: Q1 2016." NREL.gov.

September. Accessed 8 2, 2022. https://www.nrel.gov/docs/fy16osti/66532.pdf.

Navigant Consulting. 2018. "California LED Pricing Analysis." January. https://www.calmac.org/publications/LED_Pricing_Analysis_Report_-_Revised_1.19.2018_Final.pdf.

NORESCO. 2020. "Time Dependent Valuation of Energy for Developing Building Efficiency Standards." https://efiling.energy.ca.gov/GetDocument.aspx?tn=233257&DocumentContentId=65743 .

San Diego Gas and Electric Company. 2012. "Commercial Kitchen Demand Ventilation Controls-Electric." June 15. https://view.officeapps.live.com/op/view.aspx?src=https%3A%2F%2Fwww.sdge.com%2Fsites%2Fdefault%2F files%2FWPSDGENRCC0019%252520Rev%2525200%252520Demand%252520Ventilation%252520Controls_0. doc&wdOrigin=BROWSELINK.

Statewide CASE Team. 2020. August. https://title24stakeholders.com/wp-content/uploads/2020/08/NR-GridIntegration_Final-CASE-Report_Statewide-CASE-Team.pdf.

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Packet Pg. 748 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 51 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 —. 2011 C. "Fan Control and Integrated Economizers." September. https://title24stakeholders.com/wpcontent/uploads/2020/01/2013_CASE-Report_Fan-Control-and-Integrated-Economizers.pdf. —. 2020 A. Multifamily Domestic Hot Water. September. https://title24stakeholders.com/wpcontent/uploads/2020/09/2022_T24_Final-CASE-Report-MF-DHW-Dist.pdf. —. 2020 B. "Nonresidential High Performance Envelope." October. https://title24stakeholders.com/wpcontent/uploads/2020/10/2020-T24-NR-HP-Envelope-Final-CASE-Report.pdf. —. 2021 D. "Nonresidential Indoor Lighting March." March. https://title24stakeholders.com/wpcontent/uploads/2021/03/2022-T24-Indoor-Lighting_Final-CASE-Report_Statewid-CASE-Team_wAddendum.pdf.

Statewide IOU Team. 2022. "2019 Restaurants Reach Code Cost-Effectiveness Analysis." 2 18. file:///C:/Users/mflores/Downloads/2019%20Restaurants%20Cost-eff%20Report%20(10).pdf.

TRC, P2S Engineers, and Western Allied Mechanical. 2022. "2019 Reach Code Cost-Effectiveness Analysis." February

22. https://localenergycodes.com/download/968/file_path/fieldList/2019%20Restaurants%20Costeff%20Report.pdf.

U.S. Department of Energy . 2021. "A National Roadmap for Grid-Interactive Efficient Buildings." May 17. https://gebroadmap.lbl.gov/A%20National%20Roadmap%20for%20GEBs%20-%20Final.pdf.

U.S. Department of Energy. 2019 B. U.S. Department of Energy. December. https://www.energy.gov/sites/default/files/2020/02/f72/2019_ssl-energy-savings-forecast.pdf. —. 2022 A. Prototype Building Models. June 9. https://www.energycodes.gov/prototype-building-models.

WELL. 2022. wellcertified.com. June 9. Accessed June 8, 2022. wellcertified.com.

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Packet Pg. 749 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 52 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 8 Appendices

8.1 Map of California CZs
Climate Zone geographical boundaries are depicted in Figure 5 below. An interactive GIS location based map and zipcode based search directory is available at: Climate Zone tool, maps, and information supporting the California Energy Code
Figure 5. Map of California CZs

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8.2 Utility Rate Schedules
The Reach Codes Team used the IOU and POU rates depicted in to determine the On-Bill savings for each prototype.

Table 23. Utility Tariffs Analyzed Based on CZ – Detailed View CZs Utility
Electric Rate (Time of Use) Gas Rate
Medium
Office
Medium
Retail QSR Small Hotel All Prototypes
CZ01 PG&E B-10 B-1 B-1 B-1 or B-10 G-NR1
CZ02 PG&E B-10 B-1 or B-10 B-1 or B-10 B-1 or B-10 G-NR1 CZ03 PG&E B-10 B-1 B-1 B-1 or B-10 G-NR1
CZ04 PG&E B-10 B-1 or B-10 B-1 or B-10 B-1 or B-10 G-NR1 CZ04-2 CPAU E-2 E-2 E-2 E-2 G-2
CZ05 PG&E B-10 B-1 B-1 B-1 or B-10 G-NR1
CZ05-2 SCG B-10 B-1 B-1 B-1 or B-10 G-10 (GN-10)
CZ06 SCE TOU-GS-2 TOU-GS-2 TOU-GS-2 TOU-GS-2 G-10 (GN-10) CZ07 SDG&E
ALTOU+EECC
(AL-TOU)
AL-TOU+EECC
(AL-TOU)
ALTOU+EECC
(AL-TOU)
AL-TOU+EECC
(AL-TOU)
GN-3
CZ08 SCE TOU-GS-2 TOU-GS-2 TOU-GS-2 TOU-GS-2 G-10 (GN-10) CZ09 SCE TOU-GS-2 TOU-GS-2 TOU-GS-2 TOU-GS-2 G-10 (GN-10) CZ10 SDG&E
ALTOU+EECC
(AL-TOU)
AL-TOU+EECC
(AL-TOU)
ALTOU+EECC
(AL-TOU)
AL-TOU+EECC
(AL-TOU)
G-10 (GN-10)
CZ10-2 SCE TOU-GS-2 TOU-GS-2 TOU-GS-2 TOU-GS-2 GN-3
CZ11 PG&E B-10 B-10 B-1 or B-10 B-10 G-NR1
CZ12 PG&E B-10 B-1 or B-10 B-1 or B-10 B-10 G-NR1
CZ12-2 SMUD
CITS-1
(CI-TOD 1)
CITS-1
(CI-TOD 1)
CITS-1
(CI-TOD 1)
CITS-1 G-NR1
CZ13 PG&E B-10 B-10 B-1 or B-10 B-10 G-NR1
CZ14 SDG&E
ALTOU+EECC
(AL-TOU)
AL-TOU+EECC
(AL-TOU)
ALTOU+EECC
(AL-TOU)
AL-TOU+EECC
(AL-TOU)
G-10 (GN-10)
CZ14-2 SCE TOU-GS-2 TOU-GS-2 TOU-GS-2
TOU-GS-2 or TOUGS-3
GN-3
CZ15 SCE TOU-GS-2 TOU-GS-2 TOU-GS-2 TOU-GS-2 G-10 (GN-10) CZ16 PG&E B-10 B-1 or B-10 B-1 or B-10 B-1 or B-10 G-NR1

10.B.b
Packet Pg. 751 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 54 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24

8.2.1 PG&E
Figure 6. PG&E Electric Schedule - B-1

10.B.b
Packet Pg. 752 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 55 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Figure 7. PG&E Electric Schedule - B-10

10.B.b
Packet Pg. 753 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 56 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Figure 8. PG&E Gas Schedule – G-NR1

10.B.b
Packet Pg. 754 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 57 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24

8.2.2 SCE
Figure 9. SCE Electric Schedule – TOU-GS-1

10.B.b
Packet Pg. 755 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 58 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Figure 10. SCE Electric Schedule – TOU-GS-2

10.B.b
Packet Pg. 756 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 59 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Figure 11. SCE Electric Schedule – TOU-GS-3

10.B.b
Packet Pg. 757 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 60 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24

8.2.3 SCG
Figure 12. SCG Gas Schedule – G-10

10.B.b
Packet Pg. 758 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 61 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24

10.B.b
Packet Pg. 759 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 62 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24

8.2.4 SDG&E
Figure 13. SDG&E Electric Schedule – AL-TOU

10.B.b
Packet Pg. 760 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 63 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24

10.B.b
Packet Pg. 761 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 64 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24

10.B.b
Packet Pg. 762 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 65 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Figure 14. SDG&E Electric Schedule - EECC

10.B.b
Packet Pg. 763 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 66 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Figure 15. SDG&E Gas Schedule – GN-3

10.B.b
Packet Pg. 764 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 67 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24

10.B.b
Packet Pg. 765 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 68 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24

8.2.5 CPAU
Figure 16. CPAU Electric Schedule – E-2

10.B.b
Packet Pg. 766 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 69 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Figure 17. CPAU Gas Schedule – G-2

10.B.b
Packet Pg. 767 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 70 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24

8.2.6 SMUD (Electric Only)
Figure 18. SMUD Electric Schedule – CITS-0/CITS-1

10.B.b
Packet Pg. 768 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 71 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24

8.2.7 Escalation Rates
Utility rates are assumed to escalate over time, using assumptions from research conducted by Energy and Environmental Economics (E3) in Appendix 8.2. The 2019 study Residential Building Electrification in California (Energy + Environmental Economics 2019a) and escalation rates used in the development of the 2022 TDV multipliers Table 24 below demonstrate the escalation rates used for nonresidential buildings. As stated by E3 in the TDV report, this latter assumption “does not presuppose specific new investments, changes in load and gas throughput, or other measures associated with complying with California’s climate policy goals” (i.e., business-as-usual is assumed).

Table 24. Real Utility Rate Escalation Rate Assumptions Above Inflation Source
Statewide Electric
Nonresidential Average
Rate (%/year, real)
Statewide Natural Gas
Nonresidential Core Rate
(%/year, real)
2023 E3 2019 2.0% 4.0%
2024 2022 TDV 0.7% 7.7%
2025 2022 TDV 0.5% 5.5%
2026 2022 TDV 0.7% 5.6%
2027 2022 TDV 0.2% 5.6%
2028 2022 TDV 0.6% 5.7%
2029 2022 TDV 0.7% 5.7%
2030 2022 TDV 0.6% 5.8%
2031 2022 TDV 0.6% 3.3%
2032 2022 TDV 0.6% 3.6%
2033 2022 TDV 0.6% 3.4%
2034 2022 TDV 0.6% 3.4%
2035 2022 TDV 0.6% 3.2%
2036 2022 TDV 0.6% 3.2%
2037 2022 TDV 0.6% 3.1%

8.3 HVAC and SHW System Cost Scalers
Table 25 shows the material and labor adjustment factors used to determine the costs.

Table 25. Materials and Labor Adjustment Factors by Climate Zone Materials Labor
CZ 01 0.963 0.994
CZ 02 0.963 1.387
CZ 03 1.001 1.291
CZ 04 0.998 1.298
CZ 05 0.964 0.997
CZ 06 0.960 0.997
CZ 07 0.999 0.985
CZ 08 0.998 0.996
CZ 09 0.964 0.996
CZ 10 0.998 0.996
CZ 11 1.002 0.990
CZ 12 1.000 1.000

10.B.b
Packet Pg. 769 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 72 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 CZ 13 1.000 0.990
CZ 14 0.964 0.980
CZ 15 0.963 0.996
CZ 16 0.967 0.990
Table 26 shows the contractor markup values used to determine the costs.

Table 26. Contractor Markup Values
Contractor 1 Contractor 2
General Conditions and Overhead 15% 20%
Design and Engineering 5% 10%
Permit, testing and inspection 5% 3%
Contractor Profit/Market Factor 10% 10%

8.4 Mixed Fuel Baseline Figures
Table 27. Mixed Fuel Baseline Model – Medium Office
Climate
zone
Utility
Annual
Electricity
Consumption
(kWh)
Annual
Natural Gas
Consumption
(therms)
Total
kTDV/ft2
Total TDV
Compliance
kTDV/ft2
Efficiency
TDV
Compliance
kTDV/ft2
GHG
Emissions
Total TDV
Compliance
Margin
Proposed
Elec
Utility
Cost
Proposed
Gas
Utility
tons/yr Cost
CZ01 PG&E 186,894 5,331 130 10 72 63 1 $67,234 $10,377
CZ02 PG&E 163,979 3,253 142 12 107 52 2 $67,798 $6,493
CZ03 PG&E 176,640 2,672 131 5 83 48 1 $67,999 $5,352
CZ04 PG&E 163,768 2,003 125 -2 107 46 1 $68,366 $4,093
CZ04-2 CPAU 163,768 2,003 125 -2 107 46 1 $30,988 $6,966 CZ05 PG&E 170,544 2,575 113 -8 76 46 1 $66,040 $5,156
CZ05-2 SCG 170,544 2,575 113 -8 76 46 1 $66,040 $4,242
CZ06 SCE 163,722 1,066 122 -7 76 39 0 $76,817 $1,980
CZ07 SDG&E 169,611 747 114 -9 76 38 0 $120,127 $1,150
CZ08 SCE 191,703 941 130 -2 76 41 1 $83,752 $1,763
CZ09 SCE 169,514 1,119 135 0 76 41 1 $82,274 $2,046
CZ10 SDG&E 185,682 1,445 141 10 76 45 2 $134,646 $2,113 CZ10-2 SCE 185,682 1,445 141 10 76 45 2 $86,338 $2,474
CZ11 PG&E 209,343 3,309 166 40 136 59 2 $81,001 $6,669
CZ12 PG&E 178,461 2,864 145 19 118 53 2 $72,381 $5,784
CZ12-2 SMUD 178,461 2,864 145 19 118 53 2 $26,576 $5,784 CZ13 PG&E 211,193 2,377 165 37 139 55 2 $81,491 $4,852
CZ14 SDG&E 156,689 3,058 147 13 139 52 3 $128,390 $4,337 CZ14-2 SCE 156,689 3,058 147 13 139 52 3 $83,690 $4,756 CZ15 SCE 209,720 662 161 32 139 47 2 $101,041 $1,311
CZ16 PG&E 177,562 5,799 127 9 94 67 4 $68,281 $11,409

10.B.b
Packet Pg. 770 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 73 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Table 28. All-electric Baseline Model – Medium Retail
Climate
zone
Utility
Annual
Electricity
Consumption
(kWh)
Annual
Natural Gas
Consumption
(therms)
Total
kTDV/ft2
Total TDV
Compliance
kTDV/ft2
Efficiency
TDV
Compliance
kTDV/ft2
GHG
Emissions
Total TDV
Compliance
Margin
Proposed
Elec
Utility
Cost
Proposed
Gas
Utility
tons/yr Cost
CZ01 PG&E 138,367 0 192 110 162 28 -8 $43,917 $0
CZ02 PG&E 131,521 0 211 125 198 28 -15 $50,499 $0
CZ03 PG&E 112,237 0 176 91 156 25 -1 $36,206 $0
CZ04 PG&E 122,256 0 197 111 193 27 -5 $47,522 $0
CZ04-2 CPAU 122,256 0 197 111 193 27 -5 $22,961 $0
CZ05 PG&E 108,753 0 159 76 146 24 -8 $35,179 $0
CZ05-2 SCG 108,753 0 159 76 146 24 -8 $35,179 $0
CZ06 SCE 111,442 0 175 89 146 24 -8 $42,572 $0
CZ07 SDG&E 109,079 0 172 87 146 23 0 $71,108 $0
CZ08 SCE 129,105 0 196 107 146 26 -10 $47,404 $0
CZ09 SCE 123,673 0 193 105 146 26 -3 $46,830 $0
CZ10 SDG&E 114,235 0 174 87 146 25 4 $77,903 $0
CZ10-2 SCE 114,235 0 174 87 146 25 4 $45,763 $0
CZ11 PG&E 144,411 0 229 144 218 30 -6 $54,592 $0
CZ12 PG&E 141,639 0 221 136 211 30 -4 $53,798 $0
CZ12-2 SMUD 141,639 0 221 136 211 30 -4 $21,079 $0
CZ13 PG&E 153,371 0 244 158 236 32 -15 $56,701 $0
CZ14 SDG&E 145,499 0 223 135 236 31 -8 $86,177 $0
CZ14-2 SCE 145,499 0 223 135 236 31 -8 $52,840 $0
CZ15 SCE 146,092 0 244 158 236 29 -24 $56,750 $0
CZ16 PG&E 157,944 0 224 144 214 34 -31 $57,190 $0

10.B.b
Packet Pg. 771 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 74 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Table 29. Mixed Fuel Baseline Model – Quick-Service Restaurant Climate
zone
Utility
Annual
Electricity
Consumption
(kWh)
Annual
Natural Gas
Consumption
(therms)
Total
kTDV/ft2
Total TDV
Compliance
kTDV/ft2
Efficiency
TDV
Compliance
kTDV/ft2
GHG
Emissions
Total TDV
Compliance
Margin
Proposed
Elec
Utility
Cost
Proposed
Gas
Utility
tons/yr Cost
CZ01 PG&E 63,187 12,237 1,974 820 820 80 5 $20,126 $23,401 CZ02 PG&E 66,343 11,170 1,989 839 839 74 20 $21,332 $21,422 CZ03 PG&E 67,877 10,605 1,922 769 769 71 1 $21,657 $20,336 CZ04 PG&E 77,615 10,277 2,062 910 910 71 -4 $24,931 $19,725 CZ04-2 CPAU 77,615 10,277 2,062 910 910 71 -4 $15,041 $30,442 CZ05 PG&E 69,442 10,655 1,898 744 744 71 -2 $22,105 $20,416 CZ05-2 SCG 69,442 10,655 1,898 744 744 71 -2 $22,105 $14,924 CZ06 SCE 78,813 9,600 1,934 778 744 67 -1 $19,698 $13,599 CZ07 SDG&E 76,653 9,425 1,898 739 744 66 18 $26,903 $13,116 CZ08 SCE 77,418 9,554 1,948 792 744 66 28 $20,356 $13,542 CZ09 SCE 77,625 9,687 1,993 837 744 67 7 $20,405 $13,709 CZ10 SDG&E 81,897 9,907 2,032 877 744 69 26 $31,166 $13,782 CZ10-2 SCE 81,897 9,907 2,032 877 744 69 26 $21,407 $13,986 CZ11 PG&E 85,725 10,748 2,259 1,109 1,109 75 -12 $27,885 $20,664 CZ12 PG&E 74,131 10,726 2,080 928 928 72 2 $24,000 $20,605 CZ12-2 SMUD 74,131 10,726 2,080 928 928 72 2 $11,272 $20,605 CZ13 PG&E 88,060 10,441 2,240 1,089 1,089 73 -2 $28,620 $20,070 CZ14 SDG&E 87,498 10,655 2,251 1,097 1,089 74 -31 $30,692 $14,728 CZ14-2 SCE 87,498 10,655 2,251 1,097 1,089 74 -31 $22,471 $14,925 CZ15 SCE 118,353 9,194 2,444 1,289 1,089 71 -13 $28,746 $13,090 CZ16 PG&E 75,373 12,242 2,143 983 983 82 2 $24,194 $23,494

10.B.b
Packet Pg. 772 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 75 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Table 30. Mixed Fuel Baseline Model – Small Hotel
Climate
zone
Utility
Annual
Electricity
Consumption
(kWh)
Annual
Natural Gas
Consumption
(therms)
Total
kTDV/ft2
Total TDV
Compliance
kTDV/ft2
Efficiency
TDV
Compliance
kTDV/ft2
GHG
Emissions
Total TDV
Compliance
Margin
Proposed
Elec
Utility
Cost
Proposed
Gas
Utility
tons/yr Cost
CZ01 PG&E 230,187 16,824 299 161 173 137 7 $72,520 $32,208 CZ02 PG&E 243,164 13,161 287 152 169 117 5 $77,188 $25,351 CZ03 PG&E 232,511 12,725 272 136 151 113 6 $73,496 $24,461 CZ04 PG&E 251,386 11,608 280 146 165 109 5 $80,034 $22,342 CZ04-2 CPAU 251,386 11,608 280 146 165 109 5 $48,175 $34,218 CZ05 PG&E 232,585 12,375 264 127 143 111 6 $73,479 $23,746 CZ05-2 SCG 232,585 12,375 264 127 143 111 6 $73,479 $17,084 CZ06 SCE 251,627 10,100 260 124 143 100 4 $53,976 $14,227 CZ07 SDG&E 250,625 9,977 257 120 143 100 3 $77,312 $13,878 CZ08 SCE 271,204 9,874 269 136 143 101 3 $60,488 $13,943 CZ09 SCE 265,607 10,246 273 140 143 103 4 $60,896 $14,411 CZ10 SDG&E 276,218 9,903 276 142 143 102 3 $91,917 $13,642 CZ10-2 SCE 276,218 9,903 276 142 143 102 3 $63,534 $13,980 CZ11 PG&E 285,482 12,457 315 179 197 118 4 $82,170 $24,172 CZ12 PG&E 263,561 11,890 293 158 176 112 2 $76,104 $23,029 CZ12-2 SMUD 263,561 11,890 293 158 176 112 2 $34,853 $23,029 CZ13 PG&E 293,124 11,309 310 175 193 113 1 $84,632 $21,924 CZ14 SDG&E 276,292 12,071 298 166 193 115 2 $89,492 $16,232 CZ14-2 SCE 276,292 12,071 298 166 193 115 2 $63,611 $16,703 CZ15 SCE 349,319 7,895 309 174 193 98 -4 $78,507 $11,458 CZ16 PG&E 228,611 17,363 310 170 195 142 9 $72,664 $33,471

10.B.b
Packet Pg. 773 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 76 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24

8.5 GHG Savings Summary
This section shows the percent GHG savings for each package. GHG multipliers in CBECC software have utility emissions multipliers assigned only to each of the California’s sixteen climate zones, does not vary by utility within each zone. Individual utility assumptions may vary widely. In the Medium Office, the GHG emissions increases in allelectric package because the proposed all-electric system is electric resistance VAV system instead of a more efficient heat pump boiler system.

Figure 19. Percentage GHG Savings – Medium Office
Figure 20. Percentage GHG Savings – Medium Retail
Mixed Fuel
EE Code Min EE EE + LF
cz01 0% 3% 4% 12%
cz02 1% 0% 1% 8%
cz03 1% 0% 1% 8%
cz04 2% -1% 1% 7%
cz05 1% 0% 2% 9%
cz06 2% 0% 2% 8%
cz07 3% 0% 3% 8%
cz08 3% 0% 2% 8%
cz09 2% -1% 2% 7%
cz10 2% -2% 0% 6%
cz11 1% -3% -1% 5%
cz12 1% -2% -1% 5%
cz13 2% -3% -1% 4%
cz14 2% -4% -2% 5%
cz15 3% -1% 2% 7%
cz16 1% 1% 2% 7%
CZ
All-electric All-electric
EE Code Min EE
cz01 -4% -2% 9%
cz02 -21% -13% 10%
cz03 -18% -8% 11%
cz04 -14% -5% 10%
cz05 -15% -5% 12%
cz06 -7% 4% 13%
cz07 -5% 7% 14%
cz08 -7% 4% 12%
cz09 -8% 3% 13%
cz10 -12% -9% 3%
cz11 -23% -21% 2%
cz12 -19% -11% 9%
cz13 -17% -8% 10%
cz14 -15% -5% 10%
cz15 -3% 0% 3%
cz16 -34% -33% 2%
Mixed Fuel
CZ

10.B.b
Packet Pg. 774 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 77 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Figure 21. Percentage GHG Savings – Quick Service Restaurant Figure 22. Percentage GHG Savings – Small Hotel
Mixed Fuel
EE Code Min EE EE + LF EE + PV Code Min EE
cz01 10% 21% 26% 28% 27% 47% 52%
cz02 7% 16% 19% 21% 21% 45% 49%
cz03 8% 14% 20% 22% 22% 45% 51%
cz04 7% 12% 17% 19% 19% 43% 49%
cz05 8% 14% 20% 22% 22% 45% 51%
cz06 7% 9% 15% 16% 17% 43% 48%
cz07 6% 8% 14% 15% 16% 43% 48%
cz08 4% 9% 12% 13% 14% 43% 46%
cz09 5% 9% 12% 13% 15% 43% 46%
cz10 5% 10% 13% 14% 15% 42% 46%
cz11 6% 13% 17% 18% 18% 43% 46%
cz12 6% 14% 17% 18% 19% 44% 48%
cz13 6% 12% 15% 16% 17% 43% 46%
cz14 6% 13% 16% 17% 18% 42% 46%
cz15 4% 7% 9% 11% 12% 40% 42%
cz16 8% 18% 23% 24% 24% 44% 49%
All-electric "HS" (HVAC+SHW)
CZ
All-electric Mixed Fuel All-electric
EE Code Min EE EE + PV Code Min (PTHP)
cz01 13% 47% 48% 50% 47%
cz02 11% 42% 44% 47% 43%
cz03 12% 43% 45% 48% 43%
cz04 11% 41% 44% 46% 42%
cz05 11% 43% 45% 48% 43%
cz06 10% 41% 43% 46% 41%
cz07 10% 41% 43% 47% 41%
cz08 10% 40% 42% 46% 40%
cz09 10% 40% 42% 46% 40%
cz10 11% 37% 39% 43% 37%
cz11 12% 39% 41% 43% 39%
cz12 12% 38% 41% 43% 39%
cz13 11% 37% 39% 42% 37%
cz14 12% 38% 40% 44% 38%
cz15 10% 33% 35% 40% 33%
cz16 13% 43% 46% 48% 45%
CZ
All-electric

10.B.b
Packet Pg. 775 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code Cost-effectiveness Analysis: Nonresidential New Construction 78 Energy Code Compliance Results and Reach Code Considerations localenergycodes.com California Energy Codes & Standards | A statewide utility program 2023-03-24 Get In Touch
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Packet Pg. 776 Attachment: 2022 Cost Effectiveness Studies (Multifamily, Single-family, Non-residential) (6484 : Energy Performance Approach Reach Code 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 ARTICLE 8 OF THE SANTA MONICA MUNICIPAL CODE BY REPEALING CHAPTER 8.38 ENTITLED “ZERO EMISSION BUILDING CODE” AND

ADOPTING LOCAL AMENDMENTS TO THE CALIFORNIA ENERGY CODE TITLE 24, PART 6 UNDER SANTA MONICA MUNICIPAL CODE CHAPTER 8.36 WHEREAS, scientific evidence has established that natural gas combustion, procurement and transportation produce significant greenhouse gas emissions that contribute to global warming and climate change; and
WHEREAS, the amendments to this Chapter are reasonably necessary because of health and safety concerns as City residents suffer from asthma and other health conditions associated with poor indoor and outdoor air quality exacerbated by the combustion of natural gas; and
WHEREAS, as a coastal city, Santa Monica is vulnerable to sea level rise, and human activities releasing greenhouse gases into the atmosphere cause increases in worldwide average temperature, which contribute to melting of glaciers and thermal expansion of ocean water, resulting in rising sea levels; and WHEREAS, consistent with the City’s Climate Action & Adaptation Plan, this chapter establishes incentives for carbon-neutral construction, which will reduce

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Packet Pg. 777 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) demands for local energy and resources, reduce regional pollution, and promote a lower contribution to greenhouse gases; and
WHEREAS, using electric heating and cooling infrastructure in new buildings fueled by less greenhouse gas intensive electricity is linked to significantly lower greenhouse gas emissions and is cost competitive because of the cost savings associated with all-electric designs that avoid new gas infrastructure; and WHEREAS, the incentivization of electric building design benefits the health, welfare, and resiliency of Santa Monica and its residents; and WHEREAS, the most cost-effective time to integrate electrical infrastructure is in the design phase of a building project because building systems and spaces can be designed to optimize the performance of electrical systems and the project can take full advantage of avoided costs and space requirements from the elimination of natural gas piping and venting for combustion air safety; and
WHEREAS, Public Resources Code (PRC) Section 25402.1(h)(2) and the California Energy Code, Title 24, Part 6, Section 10-106 establish a process by which local jurisdictions may adopt more stringent standards to the energy efficiency and conservation provisions in the California Energy Code, Title 24, Part 6, provided that the standards have been determined to be cost effective and will require buildings to be designed to consume no more energy than permitted by the California Energy Code; and
WHEREAS, staff has reviewed the "2022 Cost-Effectiveness Study: Single Family New Construction Study" and associated study data, the “2022 Cost-Effectiveness Study:

Multifamily New Construction Study” and associated study data, and the “2022 Code:

Non-Residential New Construction Reach Code Cost-Effectiveness Study” and

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Packet Pg. 778 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) associated data developed for the California Energy Codes and Standards Statewide Utility Program, and find them sufficient to illustrate compliance with the requirements set forth under California Administrative Code Chapter 10-106; and WHEREAS, the 2022 California Energy Code offers compliance options that were established through the public rulemaking process of the code update; and WHEREAS, the Council expressly declares that the proposed amendments to the Energy Code are reasonably necessary because of local climatic and environmental conditions; and
WHEREAS, the content and details of this ordinance were the subject of a public stakeholder workshop conducted on April 3, 2024, at which attendees included architects, energy modelers, designers, builders, developers, and residents.

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

SECTION 1 It is the purpose and intent of this Ordinance to establish standards for new buildings to exceed certain minimum 2022 Title 24 Part 6 requirements.

SECTION 2. Santa Monica Municipal Code Chapter 8.38 (Zero Emission Building Code) is hereby repealed in its entirety.

SECTION 3. The California Energy Code, Title 24, Part 6, adopted by the City of Santa Monica codified under Santa Monica Municipal Code Chapter 8.36.010 is hereby amended as follows:

Subchapter 1 – All Occupancies – General Provisions

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Packet Pg. 779 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) Section 100.1(b) is amended to add the following:

ELECTRIC HEATING APPLIANCE. A device that produces heat energy to create a warm environment by the application of electric power to resistance elements, refrigerant compressors, or dissimilar material junctions, as defined in the California Mechanical Code.

NET FREE AREA (NFA) is the total unobstructed area within the air gaps between louver and grille slats in a vent, allowing the passage of air. The narrowest distance between two slats, perpendicular to the surface of both slats is the air gap height. The narrowest width of the gap is the air gap width. The NFA is the air gap height multiplied by the air gap width multiplied by the total number of air gaps between slats in the vent.

Subchapter 2 – Mandatory Requirements for Pool and Spa Systems and Equipment Section 110.4 is amended as follows:
(a) Certification by manufacturers. Any pool or spa heating system or equipment heater for a pool, spa, or a pool and spa combination shall may be installed only if the manufacturer has certified that the system or equipment has all of the following:

1. Efficiency. For eEquipment subject to State or federal appliance efficiency standards, listings in the Commission’s directory of certified equipment showing compliance with applicable standards shall comply with the applicable provisions of Section 110.1; and

2. On-off switch. A readily accessible on-off switch, mounted on the outside of the heater that allows shutting off the heater without adjusting the thermostat setting; and

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Packet Pg. 780 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins))

3. Instructions. A permanent, easily readable and weatherproof plate or card that provides the energy efficiency rating and gives instruction for the energy efficient operation of the pool and/or spa heater, and for the proper care of pool or spa water when a cover is used; and

4. Electric resistance heating. No electric resistance heating.

Exception 1 to Section 110.4(a)4: Listed package units with fully insulated enclosures, and with tight-fitting covers that are insulated to at least R-6.

Exception 2 to Section 110.4(a)4: Pools or spas deriving at least 60 (b) Installation. Any pool and/or spa system or equipment shall be installed with all of the meet the following requirements:

1. Heating Equipment. Equipment installed to heat water for pools and/or spas shall be selected from equipment meeting the standards shown in Table 110.4- A.

Table 110.4-A HEATING EQUIPMENT STANDARDS
Heating Energy Source Standard
Electric Resistance UL 1261
Gas-fired ANSI Z21.56/CSA 4.7a
Heat Pump AHRI 1160 and one of the following: CSA
C22.2 No. 236, UL 1995, or UL/CSA
60335-2-40

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Packet Pg. 781 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) Solar ICC/APSP 902/SRCC 400 for solar pool
heaters, ICC 901/SRCC 100 for solar
collectors

21. Piping. At least 36 18 inches of horizontal or vertical pipe shall be installed between the filter and the heater or dedicated suction and return lines, or built-in or built-up connections shall be installed to allow for the future addition of solar heating equipment;

32. Covers. Outdoor pools and/or spa with electric or gas heating equipment shall be installed with a pool cover. A cover for outdoor pools and/or outdoor spas that have a heat pump or gas heater.; and

43. Directional inlets and time switches for pools. If the system or equipment is for a pool:
i. The pool shall have directional inlets that adequately mix the pool water; and ii. A time switch or similar control mechanism shall be permanently installed as part of a pool water circulation control system that will allow all pumps to be set or programmed to run only during off-peak electric demand period, and for the minimum time necessary to maintain the water in the condition required by applicable public health standards.
(c) Heating Source Sizing. Heating systems or equipment for pool and/or spa shall meet one of the sizing requirements of 1 2, or 3through 5 below:

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Packet Pg. 782 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins))

1. A solar pool heating system with a solar collector surface area that is equivalent to the following:

A. For nonresidential and multifamily buildings, 65 percent or greater of the pool and/or spa surface area.

B. For single family buildings, 60 percent or greater of the pool and/or spa surface area;. or

2. A heat pump pool heater as the primary heating system that meets the sizing requirements of Reference Joint Appendix JA16.3. The control for the heat pump pool heater shall meet the requirements specified in section 110.2(b). The backup supplementary heater can be of any energy source; or

3. A heating system that derives at least 60 percent of the annual heating energy from onsite renewable energy or on-site recovered energy.

4. A combination of a solar pool heating system and heat pump pool heater without any additional supplementary heater; or

5. A pool heating system determined by the Executive Director to use no more energy than the systems specified in Items 1, 2, 3, or 4 above.

Exception 1 to Section 110.4(c): Portable electric spas compliant with 20 CCR § 1605.3(g)(7) of the Appliance Efficiency Regulations.

Exception 2 to Section 110.4(c): Alterations to existing pools and/or spas with existing heating systems or equipment.

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Packet Pg. 783 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) Exception 3 to Section 110.4(c): A pool and/or spa that is heated solely by a solar spool heating system without any backup heater.

Exception 4 to Section 110.4(c): Heating systems which are used exclusively for permanent spa applications in existing buildings with gas availability.

Exception 5 to Section 110.4(c): Heating systems which are used exclusively for permanent spa applications where there is inadequate sSolar Aaccess Roof Area (SARA) as specified in Section 150.1(c)14 for a solar pool heating system to be installed. (d) Controls for Heat Pump Pool Heaters with Supplementary Heating. Heat pump pool heaters with supplementary heaters shall have controls that meet the following:

1. Supplementary heater shall not operate when the heating load can be met by the heat pump pool heater alone; and

2. The cut-on temperature for heat pump heating is higher than the cut-on temperature for supplementary heating, and the cut-off temperature for heat pump heating is higher than the cut-off temperature for supplementary heating.

Subchapter 3 – Nonresidential Hotel/Motel Occupancies, and Covered Processes – Mandatory Requirements
Section 120.2 Required Controls for Space Conditioning Systems is amended to add Section 120.2(l) as follows:
(l) HVAC Hot Water Temperature. Zones that use hot water for space heating shall be designed for a hot water supply temperature of no greater than 130 °F.

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Packet Pg. 784 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) Section 120.6 Mandatory Requirements for Covered Processes is amended to add Section 120.6(k) as follows:
(k) Mandatory requirements for commercial kitchens. Electric Readiness for Newly Constructed Commercial Kitchens shall meet the following requirements:

1. Quick-service commercial kitchens and institutional commercial kitchens shall include a dedicated branch circuit wiring and outlet that would be accessible to cookline appliances and shall meet all of the following requirements:
a. The branch circuit conductors shall be rated at 50 amps minimum.
b. The electrical service panel shall have a minimum capacity of 800 connected amps.

2. The electrical service panel shall be sized to accommodate an additional either 208v or 240v 50-amp breaker.

EXCEPTION 1 to Section 120.6(k): healthcare facilities.

EXCEPTION 2 to Section 120.6(k): all-electric commercial kitchens.

Subchapter 4 – Nonresidential and Hotel/Motel Occupancies Section 130.0 is amended as follows:
a. The design and installation of all lighting systems and equipment in nonresidential and hotel/motel buildings, outdoor lighting, and electrical power distribution

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Packet Pg. 785 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) systems within the scope of Section 100.0(a), shall comply with the applicable provisions of Sections 130.0 through 130.5130.6.

NOTE: The requirements of Sections 130.0 through 130.5130.6 apply to newly constructed buildings. Section 141.0 specifies which requirements of Sections 130.0 through 130.5130.6 also apply to additions and alterations to existing buildings.

Add Section 130.6 - Electric Readiness for Systems Using Gas or Propane:
130.6 Electric Readiness Requirements for Systems Using Gas or Propane Where nonresidential systems using gas or propane are installed, the construction drawings shall indicate electrical infrastructure and physical space accommodating the future installation of an electric heating appliance in the following ways, as certified by a registered design professional or licensed electrical contractor. a) Branch circuit wiring, electrically isolated and designed to serve all electric heating appliances in accordance with manufacturer requirements and the California Electrical Code, including the appropriate voltage, phase, minimum amperage, and an electrical receptacle or junction box within five feet of the appliance that is accessible with no obstructions. Appropriately sized conduit may be installed in lieu of conductors; and
b) Labeling of both ends of the unused conductors or conduit shall be with “For Future Electrical Appliance”; and
c) Reserved circuit breakers in the electrical panel for each branch circuit, appropriately labeled (e.g. “Reserved for Future Electric Range”), and positioned on the opposite end of the panel supply conductor connection; and

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Packet Pg. 786 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) d) Connected subpanels, panelboards, switchboards, busbars, and transformers shall be sized to serve the future electric heating appliances. The electrical capacity requirements shall be adjusted for demand factors in accordance with the California Electric Code; and
e) Physical space for future electric heating appliances, including equipment footprint, and if needed a pathway reserved for routing of ductwork to heat pump evaporator(s), shall be depicted on the construction drawings. The footprint necessary for future electric heating appliances may overlap with non-structural partitions and with the location of currently designed combustion equipment.

Subchapter 5 – Nonresidential and Hotel/Motel Occupancies Section 140.0 - Performance and Prescriptive Compliance Approaches is amended as follows:

Nonresidential and hotel/motel buildings shall comply with all of the following:
a) The requirements of Sections 100.0 through 110.12 applicable to the building project (mandatory measures for all buildings).
b) The requirements of Sections 120.0 through 130.56 (mandatory measures for nonresidential, and high-rise residential and hotel/motel buildings). c) Either the performance compliance approach (energy budgets) specified in Section 140.1 or the prescriptive compliance approach specified in Section 140.2 for the climate zone in which the building will be located. Climate zones are shown in FIGURE 100.1-A.

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Packet Pg. 787 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) NOTE to Section 140.0(c): The Commission periodically updates, publishes and makes available to interested persons and local enforcement agencies precise descriptions of the climate zones, which is available by zip code boundaries depicted in the Reference Joint Appendices along with a list of the communities in each zone.

NOTE to Section 140.0: The requirements of Sections 140.1 through 140.910 apply to newly constructed buildings. Section 141.0 specifies which requirements of Section 140.1 through 140.910 also apply to additions or alterations to existing buildings.

Section 140.1 Performance Approach: Energy Budgets is amended as follows:

A building complies with the performance approach if provided that:

1. The time-dependent valuation (TDV) energy budget calculated for the Proposed Design Building under Subsection (b) is no greater than the TDV energy budget calculated for the Standard Design Building under Subsection (a), and

2. The source energy budget calculated for the proposed design building under Subsection (b) has a source energy compliance margin, relative to the source energy budget calculated for the standard design building under Subsection (a), of at least 7% for hotels, 2% for restaurants, 14% for office, and 7% for all other nonresidential occupancies.

Exception 1 to 140.1 item 2 A source energy compliance margin of 0 percent or greater is required when nonresidential occupancies are designed with single zone spaceconditioning systems complying with Section 140.4(a)2.

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Packet Pg. 788 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) (a) – (c) Subsections 140.1 (a) – (c) are adopted without modification.

Subchapter 7 - Single-Family Residential Buildings
Section 150.0 Mandatory Features and Devices is amended as follows:

Single-family residential buildings shall comply with the applicable requirements of Sections 150(a) through 150.0(v).

NOTE: The requirements of Sections 150.0(a) through 150.0(rv) apply to newly constructed buildings. Sections 150.2(a) and 150.2(b) specify which requirements of Sections 150.0(a) through 150.0(r) also apply to additions or alterations. The amendments to sections 150.0 (t) do not apply to additions or alterations. (a) – (s): Subsections 150.0(a) – (s) are adopted without modification.

Section 150.0(t) of Section 150.0 Mandatory Features and Devices is amended as follows:
(t) Heat pump space heater ready. Systems using gas or propane furnace to serve individual dwelling units shall include the following:

1. A dedicated 240 volt branch circuit wiring shall be installed within 3 feet from the furnace and accessible to the furnace with no obstructions. The branch circuit conductors shall be rated at 30 amps minimum. The blank cover shall be identified as “240V ready”. All electrical components shall be installed in accordance with the California Electrical Code.

2. The main electrical service panel shall have a reserved space to allow for the installation of a double pole circuit breaker for a future heat pump space heater

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Packet Pg. 789 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) installation. The reserved space shall be permanently marked as “For Future 240V use”.

3. A designated exterior location for a future heat pump compressor unit with either a drain or natural drainage for condensate.
(u) – (v): Subsections 150.0(u) – (v) are adopted without modification.

Subchapter 8 – Single-Family Residential Buildings
Section 150.1 Performance and Prescriptive Compliance Approaches for Single-Family Residential Buildings is amended as follows:
(a) Section (a) is adopted without modification.
(b) Performance Standards Approach. A building complies with the performance standards approach if the energy consumption calculated for the proposed design building is no greater than the energy budget calculated for the standard design building using Commission-certified compliance software as specified by the Alternative Calculation Methods Approval Manual, as specified in sub-sections 1, 2 and 3 below.

1. Newly Constructed Buildings. The Energy Budget for newly constructed buildings is expressed in terms of the Energy Design Ratings, which are based on source energy and time-dependent valuation (TDV) energy. The Energy Design Rating 1 (EDR1) is based on source energy. The Energy Design Rating 2 (EDR2) is based on TDV energy and has two components, the Energy Efficiency Design Rating, and the Solar Electric Generation and Demand Flexibility Design Rating. The total Energy Design Rating shall account for both the Energy Efficiency Design Rating and the Solar Electric

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Packet Pg. 790 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) Generation and Demand Flexibility Design Rating. The proposed building shall separately comply with the Source Energy Design Rating, Energy Efficiency Design Rating and the Total Energy Design Rating. A building complies with the performance approach if the TDV energy budget calculated for the proposed design building is no greater than the TDV energy budget calculated for the Standard Design Building AND Source Energy compliance margin of at least 5.0 relative to the Source Energy Design Rating 1 calculated for the Standard Design building.

EXCEPTION 1 to Section 150.1(b)1. A community shared solar electric generation system, or other renewable electric generation system, and/or community shared battery storage system, which provides dedicated power, utility energy reduction credits, or payments for energy bill reductions, to the permitted building and is approved by the Energy Commission as specified in Title 24, Part 1, Section 10-115, may offset part or all of the solar electric generation system Energy Design Rating required to comply with the Standards, as calculated according to methods established by the Commission in the Residential ACM Reference Manual.

EXCEPTION 2 to Section 150.1(b)1. A newly constructed building with a conditioned floor area less than 1,500 square feet shall achieve a Source Energy compliance margin of 2.0 or greater, relative to the Source Energy Design Rating 1 calculated for the Standard Design building.

EXCEPTION 3 to Section 150.1(b)1. If a newly constructed building with a conditioned floor area less than 625 square feet demonstrates that due to conditions specific to the project, it is technically infeasible to achieve

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Packet Pg. 791 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) compliance, the Building Official may reduce the minimum Source Energy compliance margin to between 0 and 2.0, relative to the Source Energy Design Rating 1 calculated for the Standard Design building.

2. Additions and Alterations to Existing Buildings. The Energy Budget for additions and alterations is expressed in terms of TDV energy.

3. Section (b)(3) is adopted without modification.

Section (c) is adopted without modification.

Subchapter 10 - Multifamily Buildings – Mandatory Requirements Section 160.4 Mandatory Requirements for Water Heating systems is amended to remove subsection (a) as follows:
(a) Reserved. Systems using gas or propane water heaters to serve individual dwelling units shall include the following components:

1. A dedicated 125 volt, 20 amp electrical receptacle that is connected to the electric panel with a 120/240 volt 3 conductor, 10 AWG copper branch circuit, within 3 feet from the water heater and accessible to the water heater with no obstructions. In addition, all of the following:

A. Both ends of the unused conductor shall be labeled with the word “spare” and be electrically isolated; and

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Packet Pg. 792 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) B. A reserved single pole circuit breaker space in the electrical panel adjacent to the circuit breaker for the branch circuit in A above and labeled with the words “Future 240V Use”; and

2. A Category III or IV vent, or a Type B vent with straight pipe between the outside termination and the space where the water heater is installed; and

3. A condensate drain that is no more than 2 inches higher than the base of the installed water heater, and allows natural draining without pump assistance; and

4. A gas supply line with a capacity of at least 200,000 Btu/hr.

Sections (b) to (f) are adopted without amendments.

Section 160.9 Mandatory Requirements for Electric Ready Buildings Section 160.9 Sections (a) to (c) are adopted without amendments. Sections (d) through (f) are added as follows:
d) Systems using gas or propane water heaters to serve individual dwelling units shall include the following components:

1. A dedicated 125 volt, 20 amp electrical receptacle that is connected to the electric panel with a 120/240 volt 3 conductor, copper branch circuit rated to 30 amps, within 3 feet from the water heater and accessible to the water heater with no obstructions. In addition, all of the following:

A. Both ends of the unused conductor shall be labeled with the word “spare” and be electrically isolated; and

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Packet Pg. 793 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) B. A reserved single pole circuit breaker space in the electrical panel adjacent to the circuit breaker for the branch circuit in A above and labeled with the words “Future 240V Use”;

2. A condensate drain that is no more than 2 inches higher than the base of the installed water heater, and allows natural draining without pump assistance,

3. The construction drawings shall indicate the location of the future heat pump water heater. The reserved location shall have minimum interior dimensions of 39”x39”x96”

4. A ventilation method meeting one of the following:

A. The location reserved for the future heat pump water heater shall have a minimum volume of 700 cu. ft.,
B. The location reserved for the future heat pump water heater shall vent to a communicating space in the same pressure boundary via permanent openings with a minimum total net free area of 250 sq. in., so that the total combined volume connected via permanent openings is 700 cu. ft. or larger. The permanent openings shall be:
i. Fully louvered doors with fixed louvers consisting of a single layer of fixed flat slats; or
ii. Two permanent fixed openings, consisting of a single layer of fixed flat slat louvers or grilles, one commencing within 12 inches from the top of the enclosure and one commencing within 12 inches from the bottom of the enclosure.

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Packet Pg. 794 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) C. The location reserved for the future heat pump water heater shall include two 8” capped ducts, venting to the building exterior.
i. All ducts connections and building penetrations shall be sealed. ii. Exhaust air ducts and all ducts which cross pressure boundaries shall be insulated to a minimum insulation level of R-6
iii. Airflow from termination points shall be diverted away from each other. e) Central Heat Pump Water Heater Electric Ready. Central water heating systems using gas or propane to serve multiple dwelling units shall include the following:

1. The system input capacity of the gas or propane water heating system shall be determined as the sum of the input gas or propane capacity of all water heating devices associated with each gas or propane water heating system.

2. Space reserved shall include:

A. Heat Pump. The minimum space reserved shall include space for service clearances, air flow clearances, and keep outs and shall meet one of the following:
i. If the system input capacity of the gas water heating system is less than 200,000 BTU per hour, the minimum space
reserved for the heat pump shall be 2.0 square feet per input 10,000 BTU per hour of the gas or propane water heating system, and the minimum linear dimension of the space
reserved shall be 48 linear inches.
ii. If the system input capacity of the gas water heating system is greater than or equal to 200,000 BTU per hour, the
minimum space reserved for the heat pump shall be 3.6

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Packet Pg. 795 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) square feet per input 10,000 BTU per hour of the gas or propane water heating system, and the minimum linear
dimension of the space reserved shall be 84 linear inches. iii. The space reserved shall be the space required for a heat pump water heater system that meets the total building hot water demand as calculated and documented by the
responsible person associated with the project.

B. Tanks. The minimum space reserved shall include space for service clearances and keep outs and shall meet one of the following:
i. If the system input capacity of the gas water heating system is less than 200,000 BTU per hour, the minimum space
reserved for the storage and temperature maintenance tanks shall be 4.4 square feet per input 10,000 BTU per hour. of the gas or propane water heating system.
ii. If the system input capacity of the gas water heating system is greater than or equal to 200,000 BTU per hour, the
minimum physical space reserved for the storage and
temperature maintenance tanks shall be 3.1 square feet per input 10,000 BTU per hour. of the gas or propane water
heating system.
iii. The space reserved shall be the space required for a heat pump water heater system that meets the total building hot

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Packet Pg. 796 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) water demand as calculated and documented by the
responsible person associated with the project.

3. Ventilation shall be provided by meeting one of the following:

A. Physical space reserved for the heat pump shall be located outside, or
B. A pathway shall be reserved for future routing of supply and exhaust air via ductwork from the reserved heat pump location to an appropriate outdoor location. Penetrations through the building envelope for louvers and ducts shall be planned and identified for future use. The reserved pathway and penetrations through the building envelope shall be sized to meet one of the following:
i. If the system input capacity of the gas water heating system is less than 200,000 BTU per hour, the minimum air flow rate shall be 70 CFM per input 10,000 BTU per hour of the gas or propane water heating system and the total external static pressure drop of ductwork and louvers shall not exceed 0.17 inch when the future heat pump water heater is installed. ii. If the system input capacity of the gas water heating system is greater than or equal to 200,000 BTU per hour, the
minimum air flow rate shall be 420 CFM per input 10,000 BTU per hour of the gas or propane water heating system and the total external static pressure drop of ductwork and louvers shall not exceed 0.17 inch when the future heat pump water heater is installed.

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Packet Pg. 797 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) iii. The reserved pathway and penetrations shall be sized to serve a heat pump water heater system that meets the total building hot water demand as calculated and documented by the responsible person associated with the project.

4. Condensate drainage piping. An approved receptacle that is sized in accordance with the California Plumbing Code to receive the condensate drainage shall be installed within 3 feet of the reserved heat pump location, or piping shall be installed from within 3 feet of the reserved heat pump location to an approved discharge location that is sized in accordance with the California Plumbing Code, and meets one of the following:

A. If the system input capacity of the gas water heating system is less than 200,000 BTU per hour, condensate drainage shall be sized for 0.2 tons of refrigeration capacity per input 10,000 BTU per hour B. If the system input capacity of the gas water heating system is greater than or equal to 200,000 BTU per hour, condensate drainage shall be sized for 0.7 tons of refrigeration capacity per input 10,000 BTU per hour
C. Condensate drainage shall be sized to serve a heat pump water heater system that meets the total building hot water demand as calculated and documented by the responsible person associated with the project.

5. Electrical.

A. Physical space shall be reserved on the bus system of the main switchboard or on the bus system of a distribution board to serve the

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Packet Pg. 798 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) future heat pump water heater system including the heat pump and temperature maintenance tanks. In addition, the physical space reserved shall be capable of providing adequate power to the future heat pump water heater as follows:
i. Heat Pump. For the Heat Pump, the physical space reserved shall comply with one of the following:

A. If the system input capacity of the gas water heating system is less than 200,000 BTU per hour, provide 0.1
kVA per input 10,000 BTU per hour
B. If the system input capacity of the gas water heating system is greater than or equal to 200,000 BTU per
hour, provide 1.1 kVA per input 10,000 BTU per hour
C. The physical space reserved supplies sufficient
electrical power required to power a heat pump water
heater system that meets the total building hot water
demand as calculated and documented by the
responsible person associated with the project.
ii. Temperature Maintenance Tank. For the Temperature
Maintenance Tank, the physical space reserved shall comply with one of the following:

A. If the system input capacity of the gas water heating system is less than 200,000 BTU per hour, provide 1.0
kVA per input 10,000 BTU per hour

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Packet Pg. 799 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) B. If the system input capacity of the gas water heating system is greater than or equal to 200,000 BTU per
hour, provide 0.6 kVA per input 10,000 BTU per hour
C. The physical space reserved supplies sufficient
electrical power required to power a heat pump water
heater system that meets the total building hot water
demand as calculated and documented by the
responsible person associated with the project.
(f) The building electrical system shall be sized to meet the future electric requirements of the electric ready equipment specified in sections 160.9 a – e. To meet this requirement the building main service conduit, the electrical system to the point specified in each subsection, and any on-site distribution transformers shall have sufficient capacity to supply full rated amperage at each electric ready appliance in accordance with the California Electric Code.

Subchapter 11 – Multifamily Buildings
Amend Section 170.1 - Performance Approach - as follows:

A building complies with the performance approach if the TDV energy budget calculated for the Proposed Design Building under Subsection (b) is no greater than the TDV energy budget calculated for the Standard Design Building under Subsection (a). Additionally, the energy budget, expressed in terms of source energy, of a newly constructed multifamily building with three habitable stories or less shall be at least 7 percent lower than that of the Standard Design Building. Newly Constructed multifamily buildings with

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Packet Pg. 800 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) four habitable stories or more shall be at least 3 percent lower than that of the Standard Design Building.

Sub-sections (a) to (d) are adopted without amendments.

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 the 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 thirty days after adoption. Building permit applications submitted on or after the effective date of this Ordinance shall be required to comply with the requirements set forth herein.

APPROVED AS TO FORM:

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Packet Pg. 801 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) _______________________
Douglas Sloan, City Attorney

10.B.c
Packet Pg. 802 Attachment: 2024 Ordinance (6484 : Energy Performance Approach Reach Code (15 mins)) City Council Meeting: September 10, 2024 Santa Monica, California

RESOLUTION NUMBER (CCS)
(City Council Series)

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTA MONICA

MAKING FINDINGS REGARDING COST EFFECTIVENESS AND ENERGY

CONSUMPTION PURSUANT TO THE CALIFORNIA ENERGY COMMISSION

REQUIREMENTS TO ADOPT LOCAL REACH CODES
WHEREAS, the California Energy Commission approved and published the 2022 edition of the Building Energy Efficiency Standards (Energy Code) on July 1, 2022; and such code took effect January 1, 2023; and
WHEREAS, Public Resources Code (PRC) Section 25402.1(h)(2) and the California Energy Code, Title 24, Part 6, Section 10-106 establish a process by which local jurisdictions may adopt more stringent standards to the energy efficiency and conservation provisions in the California Energy Code, Title 24, Part 6, provided that the standards have been determined to be cost effective and will require buildings to be designed to consume no more energy than permitted by the California Energy Code; and
WHEREAS, on or about September 20, 2016, the State of California enacted Senate Bill (SB) 32, which added Health and Safety Code Section 38566 to require greenhouse gas emissions to be reduced 40 percent below 1990 levels by no later than December 31, 2030; and
WHEREAS, the City of Santa Monica is committed to reducing greenhouse

10.B.f
Packet Pg. 803 Attachment: 2024 Resolution (6484 : Energy Performance Approach Reach Code (15 mins)) gas emissions in accordance with the United States’ original commitment to the Paris Climate Accord; and
WHEREAS, consistent with its May 2019 Climate Action & Adaptation Plan, which aims to reduce emissions 80% below 1990 levels by 2030, the City of Santa Monica is committed to establishing requirements to increase energy efficiency, support carbon-neutral construction and reduce regional pollution; and WHEREAS, cost effectiveness studies prepared by the California Statewide Energy Codes and Standards Program demonstrate that the local amendments are cost-effective and do not result in buildings consuming more energy than is permitted by the 2022 California Energy Code (Tile 24, Part 6); and WHEREAS, the incentivization of electric building design benefits the health, welfare, and resiliency of Santa Monica and its residents; and WHEREAS, the most cost-effective time to integrate electrical infrastructure is in the design phase of a building project because building systems and spaces can be designed to optimize the performance of electrical systems and the project can take full advantage of avoided costs and space requirements from the elimination of natural gas piping and venting for combustion air safety; and
WHEREAS, staff has reviewed the "2022 Cost-Effectiveness Study: Single Family New Construction Study" and associated study data, the “2022 Cost-Effectiveness Study:

Multifamily New Construction Study” and associated study data, and the “2022 Code:

Non-Residential New Construction Reach Code Cost-Effectiveness Study” and associated data developed for the California Energy Codes and Standards Statewide

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Packet Pg. 804 Attachment: 2024 Resolution (6484 : Energy Performance Approach Reach Code (15 mins)) Utility Program, and find them sufficient to illustrate compliance with the requirements set forth under California Administrative Code Chapter 10-106; NOW, THEREFORE, the City of Santa Monica does resolve as follows:

SECTION 1. The City Council makes the following findings regarding local, Climatic, geological, topographical and environmental conditions related to the local amendments to the 2022 California Energy Code below:
(a) Santa Monica is situated in Southern California, which has extreme arid conditions and periods of severe drought. (Climatic and Environmental) (b) The greater Los Angeles region, including Santa Monica, is a densely populated area having buildings constructed within a region where environmental resources are scarce due to varying and occasional immoderate temperatures and weather conditions. This local condition also challenges the demand and need for energy resources from the local utilities. (Climatic and Environmental) (c) Where climatic conditions in Santa Monica create demands for higher usage of energy and natural resources, measures that allow conservation and efficiencies in construction will promote practices to achieve these goals. (Climatic and Environmental)
(d) As set forth in the CAAP, as a result of climate change, extreme heat events in California and the Los Angeles region are becoming more frequent, more intense, and longer lasting, with the trend expected to continue as climate change

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Packet Pg. 805 Attachment: 2024 Resolution (6484 : Energy Performance Approach Reach Code (15 mins)) worsens. Extreme heat can exacerbate heat-related illnesses and deaths, particularly among vulnerable populations such as the homeless, elderly, infants, and individuals with chronic illnesses, while also affecting communities indirectly through energy disruption and spikes in energy prices, impacting affordability. (Climatic and Environmental)
(e) The local amendments to require highly-efficient new buildings will reduce demands for local energy and resources, reduce regional pollution, promote a lower contribution to GHG emissions, and increase resilience to ongoing climate change. (Climatic and Environmental)
SECTION 2. The 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.

SECTION 3. The City Council expressly finds that the following modifications and changes to the 2022 California Energy Code are reasonably necessary because

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Packet Pg. 806 Attachment: 2024 Resolution (6484 : Energy Performance Approach Reach Code (15 mins)) of the local climatic and environmental conditions, and that the local conditions detailed in Section 1 above apply to the following modifications and changes to the 2022 California Energy Code as follows:

No. Municipal
Code
Chapter
Amendment Summary Justification
from Section 1
of this
Resolution
Local
Conditions
1 8.36.010 Requiring higher levels
of energy performance
and electric-readiness in
new buildings reduces
carbon emissions and
provides health and
safety benefits to
building occupants
(a) through (e) Climatic and
environmental
SECTION 4. The City Clerk shall certify to the adoption of this Resolution and thenceforth and thereafter the same shall be in full force and effect.

APPROVED AS TO FORM:
___________________

DOUGLAS SLOAN
City Attorney

10.B.f
Packet Pg. 807 Attachment: 2024 Resolution (6484 : Energy Performance Approach Reach Code (15 mins)) 1 David Yakobson
From: Diane Forte <[email protected]>
Sent: Tuesday, September 10, 2024 8:28 AM
To: councilmtgitems
Cc: Ariana Vito; Thomas Wong; Joshua P Torres; Rick Valte Subject: Support Agenda Item 10. B. Energy Performance Approach Reach Code Attachments: SCE Support Letter Item 10 B. - Santa Monica Reach Codes Sept 10 2024.pdf

EXTERNAL
Please see aƩached Southern California Edison’s LeƩer of Support for Agenda Item 10. B.

Diane Forte
Government Relations Manager
SCE Corporate Affairs
Local Public Affairs
310.310.5262
1721 22nd Street, Santa Monica, CA 90404
[email protected] | @SCE_DianeF
Item 10-B
September 10, 2024
Item 10-B
September 10, 2024

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Packet Pg. 808 Attachment: Written Comments (6484 : Energy Performance Approach Reach Code (15 mins)) September 10, 2024
Re: Support of Agenda Item 10. B.

Dear Mayor and Members of the City Council,
I am writing on behalf of Southern California Edison (SCE) to express our enthusiastic support for tonight’ council agenda item 10. B. First Reading Local Amendment Ordinance to the 2022 California Energy Code for Energy Performance Approach Reach Code for new Construction and Adoption of Resolution. An Energy Performance Approach Reach Code ordinance can be a very cost-effective way for local governments to achieve meaningful greenhouse gas reductions and help achieve climate and air quality goals. We strongly encourage the City of Santa Monica to adopt a strong Energy Performance Approach Reach Code ordinance with as few exemptions as possible. SCE offers the following points in support:

1. In order to meet the state’s climate goals, SCE’s Countdown to 2045 analysis shows that 95% of all building space and water heating must transition to electric appliances by 2045.

2. Modern electric technologies are very efficient and are often demand response capable.

3. Analysis shows that higher performance standards are a cost-effective way to reduce GHG emissions through improved building energy efficiency.

4. SCE is modernizing our distribution system, making more than $5 billion in investments every year to improve reliability and resiliency – the grid is ready to support increased adoption of electric technologies.

5. Our efforts to strengthen the grid and add energy storage are paying off as evidenced by the state’s ability to avoid rotating outages during recent years’ record-setting heat waves.

6. California Assembly Bill 1279 requires direct GHG emissions reduction of 85% by 2045. Source energy, introduced as a new carbon metric in the 2022 California Energy Code, has been proven to support the state’s 2045 GHG reduction and decarbonization goals.

Buildings are a major source of emissions in California – for both local air quality and greenhouse gases.

Buildings consume almost as much natural gas as the electric sector. Importantly, buildings have decades-long lifespans, so when they are built with fossil fuel infrastructure, multiple decades of additional fossil fuel emissions are locked in.

SCE is modernizing and hardening our distribution system, leveraging increasingly sophisticated hardware and software to manage a complex and intelligent grid. This will not only enable greater adoption of clean energy technologies, but it will also improve general reliability while making the grid more resilient to threats exacerbated by climate change such as wildfires and heatwaves. We are investing approximately $5 billion annually to modernize the grid to support the clean energy future.

Our efforts to strengthen the grid are paying off. With climate change, more extreme weather, including more intense and longer heat waves, are expected in the coming decades. SCE, in partnership Item 10-B
September 10, 2024
Item 10-B
September 10, 2024

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Packet Pg. 809 Attachment: Written Comments (6484 : Energy Performance Approach Reach Code (15 mins)) with state energy regulators, has prioritized and will continue to work on a variety of solutions to address the region’s long-term reliability needs. For example, SCE now has approximately 7,200 MW of battery energy storage owned or under contract, ready to serve our customers—one of the largest portfolios in the country. And we plan to add even more in the coming years.

All-electric new construction is not only cost-effective to build and operate, but will also offer exponential GHG reductions in the years to come. There are many affordable, clean, efficient allelectric options for water heating, space heating, clothes drying, and cooking, all of which can be powered by carbon-free electricity. Studiesshow that the lifetime costs for all-electric homes are either the same as, or less expensive than, mixed-fuel homes for a large majority of Californians. Additionally, since GHG reductions increase with time, reductions from all-electric buildings will increase as the grid transitions to zero-carbon electricity by 2045.

SCE is excited and ready to partner with the City of Santa Monica in addressing the climate crisis.

Emissions from the building sector are an important focal point if we are to meet the city’s and state’s climate goals. We strongly urge the City Council to adopt 10. B., the Energy Performance Approach Reach Code ordinance. We look forward to our continued partnership. The future is electric.

Sincerely,
Diane Forte
Government Relations Manager
Attachments:

Reliability FAQ
SCE Reach Codes Resources
Item 10-B
September 10, 2024
Item 10-B
September 10, 2024

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Packet Pg. 810 Attachment: Written Comments (6484 : Energy Performance Approach Reach Code (15 mins)) 1 David Yakobson
From: Climate Action <[email protected]> Sent: Monday, September 9, 2024 2:29 PM
To: councilmtgitems; Caroline Torosis; Christine Parra; City Council general box; Gleam Davis; Jesse Zwick; Lana Negrete; Oscar de la Torre; Phil Brock Cc: John Zinner; Kent Strumpell; Judy Abdo
Subject: Tues 9/10 Item 10.B,
Attachments: Letter to Council ZE Reach Code 9-10-24.pdf

EXTERNAL
Please accept this letter in support of Item 10B
Item 10-B
September 10, 2024
Item 10-B
September 10, 2024

10.B.g
Packet Pg. 811 Attachment: Written Comments (6484 : Energy Performance Approach Reach Code (15 mins)) September 8, 2024
Mayor Brock and Councilmembers,
The Climate Action Santa Monica (CASM) Steering Committee and Advisors strongly support the adoption of September 10 City Council agenda item 10.B, First Reading Local Amendment Ordinance to the 2022 California Energy Code for Energy Performance Approach Reach Code for New Construction and Adoption of Resolution. The purpose of the Reach Code (a code that goes beyond the California Title 24 Building Code requirements) is to minimize the post-construction climate impact of new buildings. Buildings are responsible for 25 percent of California’s and 30 to 40 percent of national greenhouse gas emissions. Minimizing building carbon is, therefore, critical to abate the impacts of climate change.

As Council knows, Santa Monica’s Zero Emission (ZE) Building Code, which required that all new buildings be all-electric, was withdrawn because The U.S. Court of Appeals for the Ninth Circuit ruled that, under Federal law, it is illegal to ban the use of natural gas. The City’s ZE Reach Code was adopted to partially implement the City’s Climate Action and Adaptation Plan’s goal of adopting carbon-neutral construction codes for new residential, commercial, and multifamily properties.

The proposed Energy Performance Approach (EPA) Reach Code would replace Santa Monica’s ZE Reach Code with requirements that conform to the Federal Court decision because it uses a performance approach that doesn’t forbid the use of any energy source. Instead, all new buildings would have to outperform the Title 24 performance requirement. The thresholds are designed to encourage the installation of additional electric systems and appliances. The EPA Reach Code would also require more electric ready infrastructure in new buildings than required by Title 24 in order to minimize the cost of future electrification.

CASM is all too aware that the proposed EPA Reach Code performance thresholds would legalize the use of natural gas for some, building systems, which would make it more difficult for the City to achieve its goal of an 80% reduction in carbon emissions below 1990 levels by 2030 and carbon neutrality before 2050. We trust that the Council and City Staff will look for opportunities to further reduce the use of natural gas in new buildings.

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

10.B.g
Packet Pg. 812 Attachment: Written Comments (6484 : Energy Performance Approach Reach Code (15 mins)) Sincerely,
Thank you,
Laurene von Klan, Co-Chair
Kent Strumpell, Co-Chair
Item 10-B
September 10, 2024
Item 10-B
September 10, 2024

10.B.g
Packet Pg. 813 Attachment: Written Comments (6484 : Energy Performance Approach Reach Code (15 mins)) City Council
Report
City Council Meeting: September 10, 2024
Agenda Item: 11.A
1 of 6
To: Mayor and City Council
From: Rick Valte, Public Works Director, Public Works, Architecture Services Subject: Approve Skilled Labor Policy for Renewable Energy and Electrical Vehicle Supply Equipment Projects
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) Guidelines.

2. Approve the proposed Santa Monica Skilled Labor Policy for Renewable Energy and Electrical Vehicle Supply Equipment Projects for the Public Works Department.

Summary
In response to direction provided by Council, staff recommends the adoption of a standardized labor policy for renewable energy and electrical vehicle supply equipment projects that incorporates minimum requirements for contractors awarded work requiring the installation of electrical vehicle supply equipment (EVSE), photovoltaics (PV), battery energy storage systems (BESS) and microgrid-related infrastructure, either funded by the City of Santa Monica or installed upon City of Santa Monica property.

The minimum requirements set forth in the Renewable Energy and Electrical Vehicle Supply Equipment Labor Policy would be limited to projects that meet any of the following thresholds:
• Project construction costs exceed $250,000;
• Project scope includes a PV system that is 100 kW or greater; or,

11.A
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• Project scope includes EVSE of at least six Level 2 EV chargers or at least three DC Fast Chargers.

If Council approves the proposed Policy, staff would incorporate the policy requirements into bid documents and only recommend award of construction of renewable energy and electrical vehicle supply equipment projects consistent with the Policy. Any exceptions to this policy would require Council authorization.

Discussion
On July 25, 2023, City Council introduced a Discussion Item (Attachment A) and approved a motion that directed the City Manager to return to Council with recommendations addressing skilled and trained labor requirements for renewable energy projects, electrical vehicle supply equipment, and related infrastructure either City-funded or placed upon City property to be installed by state-certified electricians.

This Discussion Item was presented in alignment with the Sustainable & Connected Community priority to “ensure that City policies and programs enhance our resources, prevent and remedy harm to the natural environment and human health, and benefit the social and economic wellbeing of the community for the sake of current and future generations”. Furthermore, Council communicated that a skilled and trained labor policy may:
• Create a healthier, cleaner, and safer city and built environment • Create eligibility for Federal and State infrastructure and greenhouse gas reduction funding for renewable energy projects and related infrastructure • Create a Green New Economy locally
• Create a pathway for folks into high road jobs
The City Council directed the City Manager to address ten proposed requirements in developing a recommendation for Council consideration. The proposal included that the installation of EVSE, PV, BESS and microgrid-related infrastructure, either funded by the City of Santa Monica or installed upon City of Santa Monica property, conform to the following requirements:

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1. All contracted work shall be performed by State Licensed C-10 Electrical contractors and comply with the requirements thereof set forth in California law.

2. Electrical work will be performed by California state certified general electricians and apprentices registered in the state of California approved joint labor management apprenticeship program.

3. Sixty percent (60%) of all “Journeyman” electricians must be graduates of a Joint Labor Management State of California Approved Electrical Apprenticeship Training Program unless for an EVSE Project.

4. A minimum of twenty-five percent (25%) of job site electrical workers must be OSHA 10-Hour General Industry Safety & Health Certified.

5. At least one job site electrical worker must be OSHA 30-Hour General Industry Safety & Health Certified.

6. The ratio of “journeymen” to apprentices shall comply with requirements set forth in California law.

And further directed that EVSE installations will meet the following additional requirements:

1. At a minimum, one job-site supervisor or job-site foreman supervising the EV Work at each job site is required to be an Electrical Vehicle Infrastructure Training Program (“EVITP”) certified electrician.

2. A minimum of fifty percent (50%) of the state-certified general electricians performing the EV Work on each job site shall be EVITP certified electricians.

3. Fifty percent (50%) of all “Journeyman” electricians must be graduates of a Joint Labor Management State of California Approved Electrical Apprenticeship Training Program.

4. EVITP certification requirements do not apply to apprentices.

City staff reviewed and drafted responses to those requirements and developed recommendations for City Council consideration in an Information Item posted publicly on March 20, 2024 (Attachment B).

The proposed recommendations were incorporated into the Renewable Energy and Electrical Vehicle Supply Equipment Labor Policy as follows:

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Renewable energy and electrical vehicle supply equipment projects requiring the installation of electrical vehicle supply equipment (EVSE), photovoltaics (PV), battery energy storage systems (BESS) and microgrid-related infrastructure, either funded by the City of Santa Monica or installed upon City of Santa Monica property, that meet any of the following thresholds shall conform to the minimum requirements set forth herein.

Project Thresholds
• The project construction costs exceed $250,000;
• The project scope includes a PV system that is 100 kW or greater; or, • The project scope includes EVSE of at least six Level 2 EV chargers or at least three DC Fast Chargers.

Minimum Requirements

1. All contracted electrical work shall be performed by state-licensed C-10 Electrical contractors and comply with the requirements thereof set forth in California law.

2. Electrical work will be performed by California state-certified general electricians and apprentices registered in a state of California approved joint labor management apprenticeship program incrementally as outlined below:
a. Year 1: 30% graduation
b. Year 3: 40% graduation
c. Year 5: 50% graduation

3. “Journeyman” electricians must be graduates of a Joint Labor Management State of California Approved Electrical Apprenticeship Training Program incrementally as outlined below:
a. Year 1: 30% graduation
b. Year 3: 40% graduation
c. Year 5: 50% graduation

4. A minimum of 25% of job site electrical workers must be OSHA 10-Hour General Industry Safety & Health Certified.

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5. At least one job site electrical worker must be OSHA 30-Hour General Industry Safety & Health Certified.

EVSE installations will meet the following additional requirements:

1. At a minimum, at least one electrician on the crew installing the EV Work at each job site is required to hold an Electrical Vehicle Infrastructure Training Program (“EVITP”) certification.

2. At a minimum, at least twenty-five percent (25%) of the state certified general electricians performing the EV Work on each job site of projects that install a charging port supplying 25 kilowatts or more to a vehicle shall hold an EVITP certification.

3. EVITP certification requirements do not apply to apprentices.

If Council approves the proposed Policy, staff would incorporate the policy requirements into bid documents and only recommend award of construction of renewable energy and electrical vehicle supply equipment projects consistent with the Policy. Any exceptions to this policy would require Council authorization. Staff will monitor impacts from this policy and report back to Council with updates as needed.

Environmental Review
The adoption of a labor policy is exempt from CEQA pursuant to Section 15061(b)(3) of the CEQA Guidelines, 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.” The labor policy is administrative in nature and addresses skilled and trained labor requirements. Therefore, it can be seen with certainty that the agreement would not result in adverse physical impacts on the environment, and as such, is exempt from CEQA.

Past Council Actions
Meeting Date Description
07/25/23 (Attachment A) Discussion Item 16.D
03/20/24 (Attachment B) Skilled Labor Policy for Renewable Energy and EVSE Projects Information Item

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

Prepared By: Amelia Feichtner, Capital Program Manager
Approved Forwarded to Council
Attachments:

A. City Council Discussion Item 16.D - July 25, 2023
B. Info Item March 20, 2024 - Skilled Labor Policy for Renewable Energy and EVSE Projects
C. PowerPoint Presentation

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Information Item
Date: March 20, 2024
To: Mayor and City Council
From: Rick Valte, Public Works Director
Subject: Skilled and Trained Labor Policy for Renewable Energy and Electrical Vehicle Supply Equipment Projects
Introduction
Santa Monica City Council introduced a Discussion Item (Attachment A) and approved a motion on July 25, 2023, that directed the City Manager to return to Council with recommendations addressing skilled and trained labor requirements for renewable energy projects and related infrastructure either City-funded or placed upon City property to be installed by state-certified electricians. The motion outlined proposed requirements and staff has drafted responses to those requirements and developed recommendations for City Council consideration herein.

Discussion
On July 25, 2023, City Council introduced a Discussion Item and approved a motion that directed the City Manager to return to Council with recommendations addressing skilled and trained labor requirements for renewable energy projects, electrical vehicle supply equipment, and related infrastructure either City-funded or placed upon City property to be installed by state-certified electricians. This Discussion Item was presented in alignment with the Sustainable & Connected Community priority to “ensure that City policies and programs enhance our resources, prevent and remedy harm to the natural environment and human health, and benefit the social and economic wellbeing of the community for the sake of current and future generations”.

Furthermore, Council communicated that a skilled and trained labor policy may:

11.A.b
Packet Pg. 820 Attachment: Info Item March 20, 2024 - Skilled Labor Policy for Renewable Energy and EVSE Projects (6474 : Skilled Labor Policy for Information Item: Renewable Energy Skilled and Trained Electrical Policy 2 • Create a healthier, cleaner, and safer city and built environment • Create eligibility for Federal and State infrastructure and greenhouse gas reduction funding for renewable energy projects and related infrastructure • Create a Green New Economy locally
• Create a pathway for folks into high road jobs
The City Council directed the City Manager to address ten proposed requirements in developing recommendations for Council consideration. The proposal included that the installation of Electric Vehicle Supply Equipment (EVSE), photovoltaics (PV), battery energy storage systems (BESS) and microgrid-related infrastructure, either funded by or installed upon City of Santa Monica property, conform to the following requirements:

1. All contracted work shall be performed by State Licensed C-10 Electrical contractors and comply with the requirements thereof set forth in California law.

2. Electrical work will be performed by California state certified general electricians and apprentices registered in a state of California approved joint labor management apprenticeship program.

3. Sixty percent (60%) of all “Journeyman” electricians must be graduates of a Joint Labor Management State of California Approved Electrical Apprenticeship Training Program unless for an EVSE Project.

4. A minimum of 25% of job site electrical workers must be OSHA 10-Hour General Industry Safety & Health Certified.

5. At least one job site electrical worker must be OSHA 30-Hour General Industry Safety & Health Certified.

6. The ratio of “journeymen” to apprentices shall comply with requirements set forth in California law.

And further directed that EVSE installations will meet the following additional requirements:

1. At a minimum, one job-site supervisor or job-site foreman supervising the EV Work at each job site is required to be an Electrical Vehicle Infrastructure Training Program (“EVITP”) certified electrician.

2. A minimum of fifty percent (50%) of the state-certified general electricians performing the EV Work on each job site shall be EVITP certified electricians.

3. Fifty percent (50%) of all “Journeyman” electricians must be graduates of a Joint Labor Management State of California Approved Electrical Apprenticeship Training Program.

4. EVITP certification requirements do not apply to apprentices.

11.A.b
Packet Pg. 821 Attachment: Info Item March 20, 2024 - Skilled Labor Policy for Renewable Energy and EVSE Projects (6474 : Skilled Labor Policy for Information Item: Renewable Energy Skilled and Trained Electrical Policy 3 City staff’s review of these proposed requirements is outlined below.

California requirements for C-10 State Licensure and Certified General Electricians A State Licensed C-10 Electrical Contractor places, installs, erects, or connects any electrical wires, fixtures, appliances, apparatus, raceways, conduits, solar photovoltaic cells, or any part thereof, which generate, transmit, transform or utilize electrical energy in any form or for any purpose. Existing law requires that all contracted electrical work for the installation of EVSE, PV, BESS and microgrids shall be performed by State Licensed C-10 electrical contractors and that persons performing work as electricians under a C-10 licensed contractor be certified pursuant to certification standards established by the Division of Labor Standards Enforcement.

California-Approved Joint Labor Management Electrical Apprenticeship Programs Joint Labor Management Apprenticeship Programs are joint Union and Contractor administered programs certified by the Division of Apprenticeship Standards (DAS), Department of Industrial Relations of the State of California. According to the DAS website, all California-approved apprenticeship programs create opportunities for Californians to obtain skills leading to gainful employment and provide employers with a highly skilled and experienced workforce while strengthening California’s economy.

However, only one of the 43 contractors that have submitted bids to the City on EVSE, PV, BESS and microgrid projects since 2019 are listed on any union-based California approved apprenticeship program webpage. In interviews with contractors currently doing work with the City, concerns were communicated that instituting this requirement would likely affect their ability to bid on future work.

In a meeting with representatives from International Brotherhood of Electrical Workers (IBEW) and National Electrical Contractors Association (NECA), staff conveyed the challenges raised by contractors currently doing relevant work with the City. Both IBEW and NECA are aligned with and support the City Council’s goal of creating pathways to gainful career opportunities and delivering quality projects by a trained and certified workforce. Staff, IBEW and NECA committed to work together to increase the eligibility of contractors to meet the Council-proposed requirements, both through the

11.A.b
Packet Pg. 822 Attachment: Info Item March 20, 2024 - Skilled Labor Policy for Renewable Energy and EVSE Projects (6474 : Skilled Labor Policy for Information Item: Renewable Energy Skilled and Trained Electrical Policy 4 IBEW/NECA network and through the development of incremental implementation strategies to bring the local contractor community along.

Current Requirement for Participation in Apprenticeship Programs The Santa Monica Municipal Code Chapter 7.28 establishes current requirements for participation in apprenticeship programs for public works projects receiving Federal, State or City financial assistance, or projects located on land leased by the City to private parties as outlined in Attachment B.

OSHA 10-Hour and OSHA 30-Hour General Industry Safety & Health Certification The OSHA Outreach Training Program provides training on the recognition, avoidance, abatement, and prevention of workplace hazards. Outreach classes also provide overview information regarding OSHA, including workers’ rights, employer responsibilities, and how to file a complaint. The 10-hour General Industry Safety & Health Certification training program is primarily intended for entry level workers. The 30- hour General Industry Safety & Health Certification training program is intended to provide workers with some safety responsibility and a greater depth and variety of training. All outreach training is intended to cover an overview of hazards a worker may encounter on a job site. This training is not currently required by the City, however the training is provided at a low cost without the need for intensive time investment to complete the certification and therefore could be incorporated into the City’s procurement requirements.

California Requirements set forth for the Ratio of “Journeymen” to Apprentices Current City apprenticeship requirements conform with existing law that allows a contractor to have one apprentice for every one journeyman and one apprentice hour worked for every five journeyman hours worked.

Electrical Vehicle Infrastructure Training Program (“EVITP”) The EVITP was an education initiative launched in 2012 by the University of Michigan with partnerships from the automotive and battery manufacturers, investor- and municipal-owned utilities, EV supply manufacturers, electrical inspectors, electrical

11.A.b
Packet Pg. 823 Attachment: Info Item March 20, 2024 - Skilled Labor Policy for Renewable Energy and EVSE Projects (6474 : Skilled Labor Policy for Information Item: Renewable Energy Skilled and Trained Electrical Policy 5 contractors, and first responders to address technical requirements, safety imperatives, and performance integrity of EV charging infrastructure. A nonprofit organization was created to provide the training program to other states. Any licensed or certified electrician in the state or local jurisdiction where the electrician resides is eligible to take the EVITP. The program consists of a 20-hour online training course conducted by subject matter experts on residential, commercial, and industrial charging stations. The curriculum includes, but is not limited to, training on electric vehicle supply equipment, the National Electrical Code, load calculation, site assessment, jobsite safety, personal protection equipment, commissioning, and troubleshooting. EVITP indicates that the curriculum is updated with changes to the industry’s technology, products, and practices. The program currently costs $275, which includes the instruction, exam proctoring, and certification. Certification is contingent on receiving a passing score on the proctored online exam and may be credited towards the continuing education unit credit requirements of a certified electrician. The EVITP certification expires after three years from the date of program completion. To recertify, the latest version of the class and test must be successfully completed.

State-mandated EVITP training requirements went into effect for state-funded electric vehicle charging infrastructure work and equipment performed and provided on and after January 1, 2022. (California Assembly Bill 841-Ting). This training is not currently required by the City for city-funded projects and only one of 26 of contractors that have submitted bids to the City on EV projects since 2019 are listed on EVITP webpage, however the training is provided at a low cost without the need for intensive time investment to complete the certification and therefore could be incorporated into the City’s procurement requirements.

Responses to and Recommendations for Council-Proposed Requirements Responses to and recommendations for the Council-proposed requirements for the installation of EVSE, PV, BESS and microgrid-related infrastructure, either funded by or installed upon City of Santa Monica property, fall into two categories. First are those that are identified as achievable in the short-term because they are already required by California law or training is provided at a low cost without the need for intensive time

11.A.b
Packet Pg. 824 Attachment: Info Item March 20, 2024 - Skilled Labor Policy for Renewable Energy and EVSE Projects (6474 : Skilled Labor Policy for Information Item: Renewable Energy Skilled and Trained Electrical Policy 6 investment to complete the required certification. Second are the requirements that require additional time for contractors to register an existing workforce, set up additional administration policies and practices, and initiate dues that could affect their ability to bid on future work.

Existing law requires all contracted electrical work for the installation of EVSE, PV, BESS and microgrids shall be performed by State Licensed C-10 electrical contractors and that persons performing work as electricians under a C-10 licensed contractor be certified pursuant to certification standards established by the Division of Labor Standards Enforcement. Existing law also requires that persons performing work as electricians under a C-10 licensed contractor be certified pursuant to certification standards established by the Division of Labor Standards Enforcement. Some related infrastructure within the contracted work for the installation of EVSE, PV, BESS and microgrids may include work that requires alternate State Licenses, such as, but not limited to, trenching, fencing, pouring concrete, or the erecting of support structures.

Therefore, it is recommended that the Council-proposed requirements be revised from “All contracted work” to “All contracted electrical work” for clarification and compliance. As indicated below, staff will bring forward a resolution that requires that work shall be performed by State Licensed C-10 Electrical contractors, work shall comply with the requirements thereof set forth in California law, and electrical work will be performed by California state certified general electricians.

Staff recommends the implementation of the Council-proposed requirements for OSHA 10-Hour and 30-Hour General Industry Safety & Health Certification for contractors hired for renewable energy projects and related infrastructure work. It would be advantageous for the City because it would help improve site safety. The training is provided at a low cost without the need for intensive time investment to complete the certification and therefore should be achievable by contractors.

The implementation of a mandated EVITP training requirement that includes, but is not limited to, training on electric vehicle supply equipment, the National Electrical Code, load calculation, site assessment, jobsite safety, personal protection equipment,

11.A.b
Packet Pg. 825 Attachment: Info Item March 20, 2024 - Skilled Labor Policy for Renewable Energy and EVSE Projects (6474 : Skilled Labor Policy for Information Item: Renewable Energy Skilled and Trained Electrical Policy 7 commissioning, and troubleshooting for residential, commercial, and industrial charging stations for contractors hired for EV work would be advantageous for the City by creating a baseline knowledge of the evolving technology in the industry. Although less than 4% of contractors that have submitted bids to the City on EV projects since 2019 are listed on EVITP webpage, this training is provided at a low cost without the need for intensive time investment to complete the certification and therefore should be achievable by contractors. However, it is recommended that the minimum requirement enacted in Santa Monica aligns with that included in California Assembly Bill 841 (Ting).

First, that all electric vehicle charging infrastructure and equipment on the customer side of the electric meter be installed by a contractor with the appropriate license classification, as determined by the Contractors’ State License Board, and at least one electrician on each crew, at any given time, who holds an EVITP certification. Second, that projects installing a charging port supplying 25 kilowatts or more to a vehicle have at least 25% of the total electricians working on the crew for the project, at any given time, who hold EVITP certification. And finally, that EVITP certification requirements do not apply to apprentices.

Considering the feedback from contractors that have submitted bids to the City on EVSE, PV, BESS and microgrid projects since 2019, staff is pursuing a two-pronged approach with IBEW and NECA to address the direction received by Council- related to Joint Labor Management Apprenticeship Training Programs. First, IBEW and NECA will work to connect their networks to Santa Monica’s online procurement portal on OpenGov Procurement to increase the number of contractors that could meet the Council-proposed requirements. Public Works and Finance staff are working together to inform how contractors that meet those requirements may be awarded points in the evaluation of bids for applicable projects. Second, staff, IBEW and NECA will continue to meet to develop a recommendation for an incremental implementation strategy that has been used and proven successful elsewhere to bring the local contractor community along so they can meet the proposed requirements in the near future.

Therefore, it is recommended that the Council-proposed requirements regarding Joint Labor Management State of California Approved Electrical Apprenticeship Training

11.A.b
Packet Pg. 826 Attachment: Info Item March 20, 2024 - Skilled Labor Policy for Renewable Energy and EVSE Projects (6474 : Skilled Labor Policy for Information Item: Renewable Energy Skilled and Trained Electrical Policy 8 Programs are enacted on projects only after staff explore the effects on business and labor administration with IBEW and NECA further and establish an implementation strategy. This will give contractors of all sizes time to augment their business policies, practice, and staff to qualify for future requirements.

In the coming months, staff intend to draft a Resolution for Renewable Energy and Electrical Vehicle Supply Equipment Projects requiring the installation of EVSE, PV, BESS and microgrid-related infrastructure, either funded by or installed upon City of Santa Monica property that exceed $250,000, to conform to the following requirements:

1. All contracted electrical work shall be performed by state-licensed C-10 Electrical contractors and comply with the requirements thereof set forth in California law.

2. Electrical work will be performed by California state-certified general electricians.

3. A minimum of 25% of job site electrical workers must be OSHA 10-Hour General Industry Safety & Health Certified.

4. At least one job site electrical worker must be OSHA 30-Hour General Industry Safety & Health Certified.

EVSE installations will also meet the following additional EVITP requirements that align with those included in California Assembly Bill 841 (Ting):

1. At a minimum, at least one electrician on the crew installing the EV Work at each job site is required to hold an Electrical Vehicle Infrastructure Training Program (“EVITP”) certification.

2. At a minimum, at least twenty-five percent (25%) of the state certified general electricians performing the EV Work on each job site of projects that install a charging port supplying 25 kilowatts or more to a vehicle shall hold an EVITP certification.

3. EVITP certification requirements do not apply to apprentices.

Staff’s proposed resolution will also detail an incremental implementation of requirements regarding Joint Labor Management State of California Approved Electrical Apprenticeship Training Programs based on the final ongoing discussions with IBEW and NECA. Staff anticipate bringing the resolution back before Council in Summer 2024.

11.A.b
Packet Pg. 827 Attachment: Info Item March 20, 2024 - Skilled Labor Policy for Renewable Energy and EVSE Projects (6474 : Skilled Labor Policy for Information Item: Renewable Energy Skilled and Trained Electrical Policy 9 Prepared By: Amelia Feichtner, Capital Program Manager Sebastian Felbeck, Senior Construction Manager
Ariana Vito, Senior Sustainability Analyst
Attachments: Attachment A: City Council Meeting, July 25, 2023, Agenda Item 16.D City Council Discussion Item with Council-Proposed Requirements Attachment B: Santa Monica Municipal Code (SMMC) 7.28 Prevailing Wage and Apprenticeship Law

11.A.b
Packet Pg. 828 Attachment: Info Item March 20, 2024 - Skilled Labor Policy for Renewable Energy and EVSE Projects (6474 : Skilled Labor Policy for City Council
Report
City Council Meeting: July 25, 2023
Agenda Item: 16.D
1 of 1
To: Mayor and City Council
From: Denise Anderson Warren, City Clerk, Records and Election Services Department
Subject: Request of Councilmember Torosis, Mayor Davis and Councilmember Zwick that the City Council direct the City Manager to return to Council with recommendations addressing skilled and trained labor requirements for renewable energy projects and related infrastructure either City funded or placed upon City property to be installed by state-certified electricians. The City Manager should address proposed requirements outlined in attachment A in developing recommendations for Council consideration.

Prepared By: Denise Anderson Warren, City Clerk
Approved Forwarded to Council
Attachments:

A. Renewable Energy jobs - Attachment A
B. Written Comments

ATTACHMENT A

11.A.b
Packet Pg. 829 Attachment: Info Item March 20, 2024 - Skilled Labor Policy for Renewable Energy and EVSE Projects (6474 : Skilled Labor Policy for Attachment A:

1. All contracted work shall be performed by State Licensed C-10 Electrical contractors and comply with the requirements thereof set forth in California law.

2. Electrical work will be performed by California state certified general electricians and apprentices registered in a state of California approved joint labor management apprenticeship program.

3. Sixty percent (60%) of all “Journeyman” electricians must be graduates of a Joint Labor Management State of California Approved Electrical Apprenticeship Training Program unless for an EVSE Project governed by Section 2 of this resolution below.

4. A minimum of 25% of job site electrical workers must be OSHA 10 Hour General Industry Safety & Health Certified.

5. At least one job site electrical worker must be OSHA 30 Hour General Industry Safety & Health Certified.

6. The ratio of “journeymen” to apprentices shall comply with requirements set forth in California law.

7. At a minimum, one job-site supervisor or job-site foreman supervising the EV Work at each job site is required to be an Electrical Vehicle Infrastructure Training Program (“EVITP”) certified electrician.

8. A minimum of fifty percent (50%) of the state certified general electricians performing the EV Work on each job site shall be EVITP certified electricians.

9. Fifty percent (50%) of all “Journeyman” electricians must be graduates of a Joint Labor Management State of California Approved Electrical Apprenticeship Training Program.

10. EVITP certification requirements do not apply to apprentices.

11.A.b
Packet Pg. 830 Attachment: Info Item March 20, 2024 - Skilled Labor Policy for Renewable Energy and EVSE Projects (6474 : Skilled Labor Policy for

ATTACHMENT B

11.A.b
Packet Pg. 831 Attachment: Info Item March 20, 2024 - Skilled Labor Policy for Renewable Energy and EVSE Projects (6474 : Skilled Labor Policy for

11.A.b
Packet Pg. 832 Attachment: Info Item March 20, 2024 - Skilled Labor Policy for Renewable Energy and EVSE Projects (6474 : Skilled Labor Policy for

11.A.b
Packet Pg. 833 Attachment: Info Item March 20, 2024 - Skilled Labor Policy for Renewable Energy and EVSE Projects (6474 : Skilled Labor Policy for

11.A.b
Packet Pg. 834 Attachment: Info Item March 20, 2024 - Skilled Labor Policy for Renewable Energy and EVSE Projects (6474 : Skilled Labor Policy for Skilled Labor Policy for
Renewable Energy and Electrical
Vehicle Supply Equipment
Projects
Item 11-A
September 10, 2024
Item 11-A
September 10, 2024

11.A.c
Packet Pg. 835 Attachment: PowerPoint Presentation [Revision 1] (6474 : Skilled Labor Policy for Staff recommends that 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) Guidelines.

2. Approve the proposed Santa Monica Skilled Labor
Policy for Renewable Energy and Electrical Vehicle
Supply Equipment Projects for the Public Works
Department.

Tonight’s Meeting Request
Item 11-A
September 10, 2024
Item 11-A
September 10, 2024

11.A.c
Packet Pg. 836 Attachment: PowerPoint Presentation [Revision 1] (6474 : Skilled Labor Policy for • On July 25, 2023, City Council introduced a Discussion Item requesting recommendations to address skilled
and trained labor requirements for renewable energy
projects, electrical vehicle supply equipment, and
related City funded infrastructure and projects placed
upon City property.
• City staff drafted responses to the proposed
requirements and developed recommendations for City
Council consideration in an Information Item posted
publicly on March 20, 2024.

Background
Item 11-A
September 10, 2024
Item 11-A
September 10, 2024

11.A.c
Packet Pg. 837 Attachment: PowerPoint Presentation [Revision 1] (6474 : Skilled Labor Policy for The policy applies to:
• Installation of electrical vehicle supply equipment
(EVSE), photovoltaics (PV), battery energy storage
systems (BESS) and microgrid-related infrastructure
Applicability
Item 11-A
September 10, 2024
Item 11-A
September 10, 2024

11.A.c
Packet Pg. 838 Attachment: PowerPoint Presentation [Revision 1] (6474 : Skilled Labor Policy for Project Thresholds:
• The project construction costs exceed $250,000;
• The project scope includes a PV system that is 100 kW or greater; or, • The project scope includes EVSE of at least six Level 2 EV chargers or at least three DC Fast Chargers.

Thresholds
Item 11-A
September 10, 2024
Item 11-A
September 10, 2024

11.A.c
Packet Pg. 839 Attachment: PowerPoint Presentation [Revision 1] (6474 : Skilled Labor Policy for Minimum Project Requirements:

1. All contracted electrical work shall be performed by state-licensed C-10 Electrical contractors and comply with the requirements thereof set forth in California law.

2. Electrical work will be performed by California state-certified general electricians and apprentices registered in a state of California approved joint labor management apprenticeship program incrementally as outlined below:
a. Year 1: 30% graduation, Year 3: 40% graduation, Year 5: 50% graduation

3. “Journeyman” electricians must be graduates of a Joint Labor Management State of California Approved Electrical Apprenticeship Training Program incrementally as outlined below:
a. Year 1: 30% graduation, Year 3: 40% graduation, Year 5: 50% graduation

4. A minimum of 25% of job site electrical workers must be OSHA 10-Hour General Industry Safety & Health Certified.

5. At least one job site electrical worker must be OSHA 30-Hour General Industry Safety & Health Certified.

Proposed Policy
Item 11-A
September 10, 2024
Item 11-A
September 10, 2024

11.A.c
Packet Pg. 840 Attachment: PowerPoint Presentation [Revision 1] (6474 : Skilled Labor Policy for Electric Vehicle Supply Equipment installations will meet the following requirements:
• At a minimum, at least one electrician on the crew installing the EV Work at each job site is required to hold an Electrical Vehicle Infrastructure Training Program (“EVITP”) certification.
• At a minimum, at least twenty-five percent (25%) of the state certified general electricians performing the EV Work on each job site of projects that install a charging port supplying 25 kilowatts or more to a vehicle shall hold an EVITP certification.
• EVITP certification requirements do not apply to apprentices.

Proposed Policy
Item 11-A
September 10, 2024
Item 11-A
September 10, 2024

11.A.c
Packet Pg. 841 Attachment: PowerPoint Presentation [Revision 1] (6474 : Skilled Labor Policy for • Requested by Council
• Supports Sustainable and Connected Council Priority
• Builds a local green economy
• Increases grant eligibility
• Creates a pathway for higher wage jobs
• Creates a healthier, cleaner and safer city
Summary
Item 11-A
September 10, 2024
Item 11-A
September 10, 2024

11.A.c
Packet Pg. 842 Attachment: PowerPoint Presentation [Revision 1] (6474 : Skilled Labor Policy for Staff recommends that 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) Guidelines.

2. Approve the proposed Santa Monica Skilled Labor Policy for Renewable Energy and Electrical Vehicle Supply
Equipment Projects for the Public Works Department.

Recommended Action
Item 11-A
September 10, 2024
Item 11-A
September 10, 2024

11.A.c
Packet Pg. 843 Attachment: PowerPoint Presentation [Revision 1] (6474 : Skilled Labor Policy for City Council
Report
City Council Meeting: September 10, 2024
Agenda Item: 16.A
1 of 1
To: Mayor and City Council
From: Nikima Newsome, City Clerk, Records and Election Services Department Subject: Request of Councilmember Davis to direct the City Attorney, City Manager, and City Clerk to prepare an amendment to the Council Rules that will provide that all 16 items must be approved by the City Attorney as legal and the City Manager as feasible (i.e., reasonably possible given available resources) prior to placing an item on the Council agenda. The City Manager, City Attorney and City Clerk are asked to return to the City Council with proposed amended Council rules as soon as possible.

Prepared By: Nikima Newsome, City Clerk
Approved Forwarded to Council
Attachments:

A. Written Comments

16.A
Packet Pg. 844
1 David Yakobson
From: Dustin Shahan <[email protected]>
Sent: Tuesday, September 10, 2024 11:55 AM
To: councilmtgitems; Council Mailbox; Gleam Davis; Phil Brock; Christine Parra; Lana Negrete; Jesse Zwick; Caroline Torosis; Oscar de la Torre Subject: 16A: It's sad that this is necessary

EXTERNAL
Good morning council
Please support item 16A to require that members submit serious requests. There's no place in a legitimate governing organization to knowingly ignore it's own lawyer's advice and vote for something illegal. It's equally absurd to pursue something without having any idea how your own city manager will actually implement it, and then bluntly ignore requests for clarification.

Your constituents deserve better than leadership "for kicks".

Dustin Shahan
90401
Item 16-A
September 10, 2024
Item 16-A
September 10, 2024

16.A.a
Packet Pg. 845 Attachment: Written Comments (6599 : Amend to Council Rules - Legality and Feasibility of 16 Items) 1 David Yakobson
From: Marc Verville <[email protected]>
Sent: Tuesday, September 10, 2024 10:15 AM
To: Phil Brock; Lana Negrete; Oscar de la Torre; Christine Parra; Gleam Davis; Jesse Zwick; Caroline Torosis
Cc: councilmtgitems
Subject: SMCC 2024-09-10 Item 16.A. - Pre-Approval of 16 Items

EXTERNAL
Dear Mayor Brock and Honorable Councilmembers,
This leƩer is in strong opposiƟon to any limitaƟon on Councilmember prerogaƟves to submit 16 items for council consideraƟon and debate.

This item is would essenƟally introduce subjecƟve criteria that could be used to suppress robust debate on topics of interest to the community and/or constrain strategic council acƟon.

The requirement that an item be “legal” under exisƟng law deprives the council of a strategic opƟon to adopt a posiƟon that could, for example, create help create legal standing for further legal acƟon against a third party enƟty that has enacted laws, regulaƟons or taken acƟons that are detrimental to the residents of Santa Monica.

The requirement that an item be “feasible”, as defined by the city manager, abrogates the council’s prerogaƟve to spur debate on council prioriƟes and shiŌs that power to an unelected city manager. Almost anything can be “feasible”. It is simply a maƩer of prioriƟes. Cuƫng off debate on prioriƟes is completely unacceptable.

Respecƞully,
Marc L. Verville
Sunset Park
Item 16-A
September 10, 2024
Item 16-A
September 10, 2024

16.A.a
Packet Pg. 846 Attachment: Written Comments (6599 : Amend to Council Rules - Legality and Feasibility of 16 Items) 1 David Yakobson
From: Stanley H Epstein <[email protected]>
Sent: Tuesday, September 10, 2024 6:49 AM
To: John Alle
Cc: Phil Brock; Oscar de la Torre; Christine Parra; Lana Negrete; Dan Charn.; councilmtgitems; Clerk Mailbox; Douglas Sloan; Susan Cola Subject: Re: 16-A.

EXTERNAL
Dear John. Thank you for reminding me and the other ccs to this email of the two agreements. Based on your statements as to the substance of those agreements, the following results:

1.Doug Sloan was wrong, either carelessly, or intentionally, but not excuseably, when he stated at the last Council meeting, that Oscar’s Item 16 required our City to take illegal action.I understand that Gleam made a similar statement.

He must acknowledge that before the meeting to Council members and to the public at the meeting this evening.

2. Doug’s “ error” is great proof that no City Attorney should have the authority to decide that a proposed Item 16 is illegal( as is proposed this evening by Gleam) unless he or she provides every Council member and the public, at least 24 hours before the relevant meeting, with a written legal opinion providing that conclusion and the reasons for it.Very often, oral statements at the meeting by Doug and his predecessors on a variety of subjects have been proven to be incorrect. Therefore, the Item 16 proposed by Gleam tonight should be modified in that respect and by eliminating the other portion because City expenditures can always be moved around by Council action.

I suggest you again give all of us again copies of the two agreements.

Sincerely, Stan Epstein. 310 393 7619
Sent from my iPad
On Sep 10, 2024, at 2:00 AM, John Alle <[email protected]> wrote:

The City of Santa Monica DOES have legal authority to END the County's Needle and Glass/Meth Pipe Distribution Handouts component of the Harm Reduction Program in its parks and public spaces.

The Santa Monica Coalition has TWICE provided ALL Councilmembers with the two agreements between the City and the LA County Public Department of Health. 1) The City of Santa Monica's "Legislative Body" (the City Council) is required to publicly review and approve any such program The LA County Health Dept.wishes to implement and,
Item 16-A
September 10, 2024
Item 16-A
September 10, 2024

16.A.a
Packet Pg. 847 Attachment: Written Comments (6599 : Amend to Council Rules - Legality and Feasibility of 16 Items) 2 2) The Santa Monica Chief of Police must approve the program. Santa Monica Police Chief Ramon Batista is publicly on record, in writing and verbally, stating he disapproves of the Needle and Glass/Meth pipe distribution in City Parks and outdoor public spaces.

John Alle
On Mon, Sep 9, 2024 at 2:58 PM Stanley H Epstein <[email protected]> wrote:

Danielle tells me that the quote below is from the Daily Press.

You all will recall that I inquired before the last meeting whether Oscar was not endorsing two contradictory Resolutions, both of which were approved In that context, John and I discussed the basis for arguing that the City had the legal authority to tell the County to stop the needle distribution program . I further suggested that Council require Sloan to give a written opinion each time as to such authority, or lack thereof. That never happened.

Last week, I sent all of you an email requiring such a written legal opinion whenever the City Attorney thinks an Item 16 proposal is illegal. Please ask for that change to Gleam’s poorly drafted Item. Also, please handle my other suggestion, which has to do with moving funds around to pay for expenses required by Item 16s.

Sloan often gives oral opinions without legal review or are intentionally erroneous.

Therefore, as long as he stays in his job, be professional and get written legal opinions whenever there is any doubt and show those opinions to lawyers in the community.

Sincerely, Stan Epstein310 393 7619
Sent from my iPad
Begin forwarded message:

From: "Dan Charn." <[email protected]>
Date: September 9, 2024 at 2:31:14 PM PDT
To: Stanley H Epstein <[email protected]>
Subject: 16-A.

Well- you were right - she caught it - on the agenda
tomorrow ..

Item 16-A
September 10, 2024
Item 16-A
September 10, 2024

16.A.a
Packet Pg. 848 Attachment: Written Comments (6599 : Amend to Council Rules - Legality and Feasibility of 16 Items) 3 "Councilwoman Gleam Davis is asking for an amendment
to Council rules that would require all future discussion to be approved by the city Attorney and City Manager for
legality and feasibility. While not explicitly stated, the item is a response to a discussion at the last meeting that saw a majority of the Council vote for an item to prohibit needle distribution in local parks after being told the council had no legal authority to pass the item and that it would be impossible to implement."
--
John E. Alle

JOHN ALLE COMPANY
www.johnallecompany.com
www.thesantamonicacoalition.org
Cell: (310) 990-7124
Office: (626) 795-1511 (310) 319-1511
The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation to the contents of this information is strictly prohibited and may be unlawful. Kindly delete.

Item 16-A
September 10, 2024
Item 16-A
September 10, 2024

16.A.a
Packet Pg. 849 Attachment: Written Comments (6599 : Amend to Council Rules - Legality and Feasibility of 16 Items) 1 David Yakobson
From: [email protected]
Sent: Monday, September 9, 2024 2:56 PM
To: councilmtgitems
Cc: Phil Brock; Lana Negrete; Caroline Torosis; Jesse Zwick; Christine Parra; Oscar de la Torre; Gleam Davis
Subject: Re: Public Comment - Item 16A- OPPOSITION- SM City Council Meeting 9/10/2024

EXTERNAL
Section 605 of the Charter states:
“All powers of the City shall be vested in the City Council, subject to the provisions of this Charter and to the Constitution of the State of California.”
The Council may not lawfully surrender control of its Agenda, and hence its power to legislate and take other actions, to subordinate officers who are not free from mistaking mistakes. Ms. Davis’s proposal is unlawful, foolish and asinine. The Council should promptly dispose of it and Ms. Davis should use the time to explain what she learned on her City funded trip to Vienna, which she procured while concealing the fact that she had already decided to retire from the Council. And then Ms. Davis should resign from the Council and move out of the City she has served so poorly.

Item 16-A
September 10, 2024
Item 16-A
September 10, 2024

16.A.a
Packet Pg. 850 Attachment: Written Comments (6599 : Amend to Council Rules - Legality and Feasibility of 16 Items) 4 David Yakobson
From: John Alle <[email protected]>
Sent: Tuesday, September 10, 2024 2:00 AM
To: Stanley H Epstein
Cc: Phil Brock; Oscar de la Torre; Christine Parra; Lana Negrete; Dan Charn.; councilmtgitems; Clerk Mailbox
Subject: Re: 16-A.

EXTERNAL
The City of Santa Monica DOES have legal authority to END the County's Needle and Glass/Meth Pipe Distribution Handouts component of the Harm Reduction Program in its parks and public spaces.

The Santa Monica Coalition has TWICE provided ALL Councilmembers with the two agreements between the City and the LA County Public Department of Health. 1) The City of Santa Monica's "Legislative Body" (the City Council) is required to publicly review and approve any such program The LA County Health Dept.wishes to implement and, 2) The Santa Monica Chief of Police must approve the program. Santa Monica Police Chief Ramon Batista is publicly on record, in writing and verbally, stating he disapproves of the Needle and Glass/Meth pipe distribution in City Parks and outdoor public spaces.

John Alle
On Mon, Sep 9, 2024 at 2:58 PM Stanley H Epstein <[email protected]> wrote:

Danielle tells me that the quote below is from the Daily Press.

You all will recall that I inquired before the last meeting whether Oscar was not endorsing two contradictory Resolutions, both of which were approved In that context, John and I discussed the basis for arguing that the City had the legal authority to tell the County to stop the needle distribution program . I further suggested that Council require Sloan to give a written opinion each time as to such authority, or lack thereof. That never happened.

Last week, I sent all of you an email requiring such a written legal opinion whenever the City Attorney thinks an Item 16 proposal is illegal. Please ask for that change to Gleam’s poorly drafted Item. Also, please handle my other suggestion, which has to do with moving funds around to pay for expenses required by Item 16s.

Sloan often gives oral opinions without legal review or are intentionally erroneous. Therefore, as long as he stays in his job, be professional and get written legal opinions whenever there is any doubt and show those opinions to lawyers in the community.

Sincerely, Stan Epstein310 393 7619
Sent from my iPad
Item 16-A
September 10, 2024
Item 16-A
September 10, 2024

16.A.a
Packet Pg. 851 Attachment: Written Comments (6599 : Amend to Council Rules - Legality and Feasibility of 16 Items) 5 Begin forwarded message:

From: "Dan Charn." <[email protected]>
Date: September 9, 2024 at 2:31:14 PM PDT
To: Stanley H Epstein <[email protected]>
Subject: 16-A.

Well- you were right - she caught it - on the agenda tomorrow .. "Councilwoman Gleam Davis is asking for an amendment to Council rules that would require all future discussion to be approved by the city Attorney and City Manager for legality and feasibility. While not explicitly stated, the item is a response to a discussion at the last meeting that saw a majority of the Council vote for an item to prohibit needle distribution in local parks after being told the council had no legal authority to pass the item and that it would be impossible to implement."
--
John E. Alle

JOHN ALLE COMPANY
www.johnallecompany.com
www.thesantamonicacoalition.org
Cell: (310) 990-7124
Office: (626) 795-1511 (310) 319-1511
Item 16-A
September 10, 2024
Item 16-A
September 10, 2024

16.A.a
Packet Pg. 852 Attachment: Written Comments (6599 : Amend to Council Rules - Legality and Feasibility of 16 Items) 6 The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation to the contents of this information is strictly prohibited and may be unlawful. Kindly delete.

Item 16-A
September 10, 2024
Item 16-A
September 10, 2024

16.A.a
Packet Pg. 853 Attachment: Written Comments (6599 : Amend to Council Rules - Legality and Feasibility of 16 Items) 1 David Yakobson
From: Stanley H Epstein <[email protected]>
Sent: Saturday, September 7, 2024 10:54 AM
To: councilmtgitems
Cc: Douglas Sloan; David White; Phil Brock; Lana Negrete; Gleam Davis; Oscar de la Torre; Christine Parra; Caroline Torosis; Jesse Zwick
Subject: Fwd: Agenda Packet - Sep 10, 2024 (Tue) - City Council

EXTERNAL
Item 16 A should be amended in the following respects: 1. If the City Attorney believes a proposed Item would be illegal, he or she must provide a written legal opinion to each Councilmember and the public prior to the
Council meeting stating the basis for that view, and 2. The part about funds not being available is contrary to governmental budgetary principles because future expenditures can always be modified to allow for the proposed costs.

Stan.he H. Epstein. 310 393 7619
Sent from my iPad
Begin forwarded message:

From: City Clerk <[email protected]>
Date: September 4, 2024 at 5:45:21 PM PDT
Subject: Agenda Packet - Sep 10, 2024 (Tue) - City Council Reply-To: City Clerk <[email protected]>
Please see the attached Agenda Packet document for the following meeting:

City Council
Regular Meeting
Tuesday, September 10, 2024 5:30 PM
1685 Main Street, Room 250, Santa Monica, CA 90401
Download PDF Agenda Packet | View Web Agenda Packet
Document Modified: 9/4/2024 5:44 PM
If you no longer wish to be included in this distribution list you can remove yourself through the meeting web portal or reply to this message.

Item 16-A
September 10, 2024
Item 16-A
September 10, 2024

16.A.a
Packet Pg. 854 Attachment: Written Comments (6599 : Amend to Council Rules - Legality and Feasibility of 16 Items) City Council
Report
City Council Meeting: September 10, 2024
Agenda Item: 16.B
1 of 1
To: Mayor and City Council
From: Nikima Newsome, City Clerk, Records and Election Services Department Subject: Request of Councilmember Davis that the City Council, as part of LGBTQ+ History Month, approve City sponsorship of the Rainbow Rewind: A Queer Prom for Grown Ups on October 18, 2024 in the Santa Monica Pier Carousel Building by directing the City Manager to waive the City’s portion of fees for use of the Pier Carousel Building. City fees related to Rainbow Rewind include the rental fees associated with the use of the Pier in an amount up to $7,000 in waived fees.

Prepared By: Nikima Newsome, City Clerk
Approved Forwarded to Council

16.B
Packet Pg. 855