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HomeMy WebLinkAboutAB 306 (Schultz) - Building Codes - City of San Luis Obispo - Letter of OPPOSITIONCity of San Luis Obispo, Office of the City Council, 990 Palm Str eet, San Luis Obispo, C A, 93401-3249, 805.781.7114, sloci ty.org March 21, 2025 The Honorable Nick Schultz California State Assembly P.O. Box 942849 Sacramento, CA 94249-0044 RE: Assembly Bill 306 (Schultz): Building Codes – City of San Luis Obispo OPPOSE Dear Assemblymember Schultz, On behalf of the San Luis Obispo City Council, I write to respectfully oppose Assembly Bill 306. Based on our analysis, AB 306 does not address housing production or housing affordability, it prevents cost-saving updates from occurring, it prevents progress towards legislatively mandated climate change goals, and presents a barrier to local safety and innovation improvements to address the rapidly evolving impacts of climate change events in local communities. The legislation, as amended as of March 20, includes the following language: (a) The state faces a housing crisis of availability and affordability, in large part due to a severe shortage of housing. (b) Solving the housing crisis therefore requires a multifaceted, statewide approach, which will include, but is not limited to, any or some of the following: (1) Encouraging an increase in the overall supply of housing. (2) Encouraging the development of housing that is affordable to households at all income levels. (3) Removing barriers to housing production. We agree with these assertions and share the goals of reducing housing costs, supporting housing development, and addressing affordability issues. However, a broad moratorium on new state and local building codes would not achieve these goals, and in fact, would have deleterious social, economic and public health and safety effects. We know this because we have local amendments to the California Building Code in place, including amendments to the California Energy Code, and have permitted 1,376 residential units between 2022 and 2024. The City opposes AB 306 for three reasons: 1. There is no evidence that AB 306 would increase housing production or reduce costs for homebuyers or renters. There are many factors that contribute to the increasing costs for homebuyers and renters including land cost, material cost, labor cost, interest rates, developers not building entitled projects, developer overhead and profit, litigation, regulations and fees, and building code compliance. Building code compliance accounts for a small fraction of overall construction costs, and the incremental cost of new code updates is even smaller. If the goal is to increase housing supply and affordability, AB 306 is the wrong approach. The analysis accompanying the bill offers no evidence that halting code updates would result in more housing, nor does it address the actual barriers to housing production and therefore there is no compelling reason to pursue this legislation. 2. The legislation would prevent updates that could reduce costs and increase housing production. The triennial code cycle and reasonable local amendments are critically important because they provide highly regulated deliberative processes to introduce new cost saving measures into the code. Emerging technologies—such as advanced electrical panels, vehicle-to-home energy systems, and next-generation building materials—can reduce construction and operating costs. Freezing building codes in place would slow the adoption of innovations like these, ultimately making housing more expensive by preventing cost-saving advancements from being incorporated into new developments. As a historic example, if the 2013 and 2016 code cycle had been skipped, LED lighting standards would have been missed and the adoption of technology that saves money at the building while also reducing the need for upstream electricity infrastructure would have been substantially slowed. As California’s highly successful efforts at market transformation in support of achieving its legislatively mandated climate goals continues, technology continues to rapidly advance, and the code must be allowed to advance with it so that new homes are able to benefit from these cost saving advancements. 3. The legislation prevents progress towards legislatively mandated climate change goals. AB 1279 (2022) establishes a goal of statewide carbon neutrality by 2045 and the 2022 Scoping Plan identified the road map for achieving these goals. At the state level, this legislative target cannot be achieved without the triennial building code updates. Additionally, the Scoping Plan identifies key roles for local governments to play in helping the state achieve its legislatively mandated goals, one of which is the adoption of local amendments to the California Energy Code. AB 306 would prevent local governments from making meaningful policy related to emissions from new and existing buildings and would prevent the state from achieving its legislatively mandated climate change goals, while removing state and local flexibility to implement innovations to address the evolving and potentially catastrophic impacts of climate change on local communities. In conclusion, AB 306 does not meaningfully address housing production or housing cost-to- occupant, it prevents cost-saving updates from occurring, it prevents progress towards legislatively mandated climate change goals, presents barriers to state and local economic, and pubic health and safety adaptability and innovation, and has numerous areas where the legislative language is ambiguous. For these reasons, the City of San Luis Obispo respectfully opposes AB 306. The City encourage the Legislature to focus on real solutions that increase housing supply while maintaining the critical safety and efficiency improvements that benefit California residents." Sincerely, Erica A. Stewart Mayor City of San Luis Obispo cc: Speaker of the Assembly, Robert Rivas Senate Pro Tem Mike McGuire Assemblymember Dawn Addis Senator John Laird Dave Mullinax, League of California Cities League of California Cities, cityletters@cacities.org