HomeMy WebLinkAbout5/21/2024 Item 7b, Rowley
Sandra Rowley <
To:Stewart, Erica A; Marx, Jan; Pease, Andy; Francis, Emily; Shoresman, Michelle
Cc:E-mail Council Website
Subject:Item 7b, Draft Ordinance: Energy Efficiency Renovation Policy
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Dear Mayor Stewart and Members of the Council,
Since this is a new program it includes some uncertainties: Is there sufficient capacity and capability of
contractors/workers (generally?) to support the program, and how long will it take for staff to train-up in order to quickly
process building plans.
Strongly recommend this be a 1 to 2 year voluntary pilot program before making the program mandatory. Presumably a
voluntary pilot program would help get the bugs out -- like availability of the necessary contractors/workers as well as the
time needed for updating staff’s processing responsibilities. In addition some incentives could be added for those who
choose to volunteer - like reduced fees for the review of building permit plans.
Homeowners (owner-occupied; I don't know if investor-owned) are already making energy efficiency changes: the addition
of dual-pane windows, attic insulation, energy efficient water heaters, new ducts and duct sealing along with installation of
an energy efficient furnace, and solar panels without being mandated to do so. Many are driving electric vehicles or
hybrids. The heat pump water heater and heat pump HVAC system are relatively new. It takes time for a new idea to
catch on; in time these too will have greater popularity.
A clear definition of “residential unit” is needed. Per the staff report, adding two bedrooms and a bath to a house does not
constitute a residential unit. Does including a small kitchen? An exterior entry?
Recommend the exemptions for new residential units (p. 832) and for ADU’s (pgs. 837-8) be eliminated. It appears that
these policies would provide preferential treatment for investors. It also appears that the proposed energy efficiency
upgrades would be borne solely by homes that are owner-occupied.
1. According to our understanding of the proposed and recommended exemptions at #7 on page 832, an addition or
remodel that results in a new residential unit is exempt from making energy upgrades to the rest of the house; however,
homeowners who are remodeling or adding space to meet their own needs would not be exempt. The construction of an
ADU would also exempt the main house from the energy efficiency changes. Although some owner-occupied homes
have added ADU’s, the majority have been built on investor-owned properties. Ditto for residential units attached to or
interior to a home.
2. There is a difference between an owner-occupied home and an investor-owned home: An investor can
deduct/recoup the cost of improvements; a homeowner cannot.
If, however, you do not think that sufficient numbers of homeowners/investors will volunteer, request the following be
considered, and the item be returned with the following updates:
1. Eliminate the exemptions for new residential units and ADU’s for reasons shown above.
2. Define historic buildings in some other way than “not on registry.” There are old (1900-1930?) homes that are not
on the registry that have a floor or wall furnace, are single-wall construction and/or have other anomalies that would make
upgrade of the primary structure difficult and costly.
3. Remove assumptions: a) If two bedrooms and a bath are added, the water heater would be replaced – not
necessarily; b) If electrical service is being upgraded to 200 amps, then conduit, wiring and outlets for future heat pump
systems (hot water & HVAC) must be installed – presumes the homeowner would know their exact future placement and
that something better had not been invented.
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4. Review the requirement for all 8 measure points plus installation of a heat pump water heater or heat pump HVAC
or solar panels on housing affordability for subsequent owners and renters.
5. State and federal rebates/incentives come and go; they cannot be relied upon.
6. Cost effectiveness estimates will need to be reviewed to incorporate the new “based-on-income” requirement for
electricity. Per the staff report, Section 10-106 of the California Energy Code notes that local amendments must be cost
effective & result in buildings that consume less energy than permitted by the state Energy Code. (emphasis added)
7. If implementation of this program impacts the time required to review permit plans, the applicant should not be
penalized with higher fees.
8. Was there an attempt to coordinate with PG&E on these proposals? Many homes with solar panels as well as some
without remained with PG&E. Would they be eligible for 3CE rebates/incentives? Are there PG&E rebates/incentives?
Regardless of whether you choose to begin with a voluntary pilot program or not, there are still some items that should be
considered before approving the proposed ordinance.
Thank you for your time and consideration.
Sincerely,
Sandra Rowley
Chairperson, RQN
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