HomeMy WebLinkAbout1/8/2019 Item 5, Codron
City of San Luis Obispo, Council Memorandum
DATE: January 7, 2019
TO: City Council
PREPARED BY: Doug Davidson, Deputy Director, Chris Read, Sustainability Manager, Eric
Hagen, Chief Building Official, Kyle Bell, Associate Planner
FROM: Michael Codron, Community Development Director
VIA:Derek Johnson, City Manager DJ
SUBJECT: Council Agenda Correspondence January 8, 2019 Item #5
On November 27, 2018, the City Council unanimously introduced tiny homes on wheels as an
allowed use via the comprehensive zoning code update. As part of public testimony, questions
emissions. Subsequently, a Councilmember had the following questions on the follow-up
amendments to the Zoning Regulations Update, specifically regarding tiny homes on wheels and
energy efficiency (Item #5 on agenda). This memorandum provides a response to these questions:
1) Should tiny homes on wheels (THOWs) be more energy efficient by complying with Title 24
of the Building Code instead of compliance with the ANSI (American National Standards
Institute) as proposed in the Zoning Ordinance Amendment?
Staff does not recommend this approach. By allowing THOWs in backyards of single-
family residences the City has recognized a unique form of alternative housing. As a
temporary and moveable form of housing, THOWs are subject to a different set of
standards. THOWs generated the most correspondence and discussion of any issue during
the Zoning Ordinance Update through the workshops, Planning Commission, and City
Council study sessions and public hearings. The proposed Ordinance balances the safety
concerns (utility connections, required inspections) with the issues of neighborhood
compatibility (aesthetics, placement, and size) while providing for a viable housing option.
The important distinction here is that THOWs are not residential structures. By definition
they are recreational vehicles (RVs) per the updated Zoning Ordinance and under State
law (Health and Safety Code Section 18010). They are considered RVs by the State
Department of Housing and Community Development (HCD) and regulated as motor
vehicles by the State Department of Motor Vehicles (DMV). The construction or
manufacturing of a THOW is not subject to the energy efficiency standards contained in
Title 24 or any part of the Building Code.
By contrast, residential structures, such as accessory dwelling units on permanent
foundations, are subject to a full Building Code review and issuance of a building permit.
THOWs do have efficiency standards, though they are less stringent than Title 24, ANSI
A119.5 specifically contains energy-related standards for roof, wall, and floor insulation.
Tiny Homes on Wheels Energy Efficiency Standards Page 2
ANSI A119.5 does not include regulations for systems consisting of space heating, water
heating, solar ready installation, or lighting requirements.
In 2014, ANSI published a standardization roadmap to improve energy efficiency in
certified recreational vehicles, see link below:
https://www.ansi.org/standards_activities/standards_boards_panels/eescc/EESCC-
Progress-Report-2016.pdf
This is an ongoing process that has identified substantial areas for coordination by
industry stakeholders. It is apparent from a 2016 progress report that no stone is being
left unturned and the collaborative process is identifying major gaps in regulation where
the establishment of certification criteria will go a long way towards improving efficiency
across the recreational vehicle industry. Staff recommends that the City move forward and
continue to implement ANSI energy efficiency standards as they evolve and improve.
In addition, it is important to consider that THOWs will not be a significant energy user
on a cumulative basis, given the inapplicability of the Building Code, their small size (less
than 400 sq. ft.), and the small number of THOWs anticipated. At this time, City staff is
expecting potentially 12-24 THOW applications to be submitted over the next couple of
years. Notwithstanding the vocal interest in these units, the owner occupancy requirement
will continue to be a major constraint for THOWs and Accessory Dwelling Units in
general. The Climate Action Plan (CAP) initiatives are occurring along several fronts
including the CAP Update, Zoning Regulations Update (electric vehicle parking
requirements), and other policy and programs such as Community Choice Energy.
The City Council and community should also be aware that the City's participation in
Monterey Bay Community Power ensures that the community's electricity portfolio will be
comprised of 100% carbon free resources starting in 2020. Most tiny homes will use
electricity as their energy source, meaning that all energy used onsite will be carbon free
starting in 2020. Carbon free electricity consumption, combined with potential reduction
in vehicle miles travelled (VMT) associated with increased density for tiny homes or
accessory dwelling units, means that all electric tiny homes may be carbon neutral or
carbon negative relative to standard homes with natural gas hookups.
2)Should we clarify the actual mobility of a THOW in and out of the backyard to addressthe
possibility of a substandard one being constructed in the backyard?
As stated above, THOWs are considered RVs and must have a motor vehicle license from
the DMV. They could be towed into the backyard, craned into the backyard if adequate
driveway width does not exist, or constructed in the backyard. For any of the three options,
the THOW must have a vehicle license, ANSI or equivalent certification, and meet the
standards of the Zoning Ordinance, including the appearance of a traditional home, utility
hookups, screening of mechanical equipment, nd
periodic inspections. These actions will ensure that the THOW is maintained safely for
human habitation and compatibility with its surroundings. The City will issue a building
permit to ensure safe adequate utility hook-ups and to serve as a record of the property
approved for a THOW. The construction of a tiny home in a backyard should be considered
similar to other types of construction projects in that these activities would be subject to