HomeMy WebLinkAboutcc - Kern (2019 Building Code Amendments) 8/12/2019
Tonikian, Victoria
From:Molly Kern <molly@slochamber.org>
Sent:Friday, August
To:E-mail Council Website; Read, Chris; Codron, Michael
Cc:Jim Dantona
Subject:Draft Local Amendments to the 2019 California Building Code
Attachments:SLO City Building Decarbonization - SLO Chamber.pdf
Dear Mayor Harmon and Council Members,
I hope this email finds you well.
Attached, please find a letter on behalf of the SLO Chamber regarding the Draft Local Amendments to the 2019
California Building Code. We look forward to answering any questions you might have and further discussing this
important issue.
Thank you for your consideration,
Molly
Molly Kern
Director of Governmental Affairs
San Luis Obispo Chamber of Commerce
T: 805.786.2763 C: 805.440.3941
slochamber.org | imagineslo.com
1
August 9, 2019
City Council
City of San Luis Obispo
990 Palm St., San Luis Obispo, CA 93401
Subject: Draft Local Amendments to the 2019 California Building Code
Dear Mayor Harmon and Council Members,
We would like to take this opportunity to share our comments regarding the proposed code
amendments developed by SLO Chamber volunteers with extensive experience and expertise in green
building, land use planning, and architecture.
We first want to commend your ambitious target of being Carbon Neutral by 2035 and direction to staff
to encourage carbon neutral new buildings as part of that effort.
As outlined in our economic vision, Imagine SLO, we know that moving towards a carbon free future
makes environmental and economic sense. Now more than ever, our collective future depends on
furthering sustainable solutions that support healthy economic growth and ensure community
resiliency. Our opportunity lies in careful stewardship of our resources so that we sustain and enhance
our quality of life for generations to come.
More than just lessening the growth of carbon emissions, we need to focus on solutions that will reduce
our net emissions. To achieve the City and Chamber’s shared goal of becoming a net-zero city, policies
need to be effective (achieves substantial GHG reduction), clear (easy to understand and implement)
and inspirational (encourages creativity and going beyond the bare minimum to reduce GHG’s). Our
taskforce used these criteria to develop the following recommendations:
Overarching
• We can’t fight battles on all fronts in simultaneity. Focus staff time on the issues that have the
largest impact GHG reduction impacts. The primary source of GHG in our area is through
transportation (commuter and passthrough) emissions. The primary mechanism to address GHG
reductions and a fossil free future is to:
o Provide housing options within walking/biking distance to where people work, go to
school, and recreate or, at the very least, shorten commutes. The increase in the
housing stock and elimination of commute trips reduces CO2 by about 7,500 pounds per
year (as validated by the APCD in February.) By comparison, the elimination of a gas
range and gas dryer are 192 and 427 pounds of CO2 respectively.
o Improve transit options
o Electrify transportation
• Building affordably within the city limits is already seen as cost prohibitive to building workforce
appropriate housing. Any cost premium added to housing within the city should be avoided so
as not to push affordable housing outside reasonable ped/bike commuting distances or to an
unaffordable by design scale.
• Work with SLO County and Cal Poly to reduce our regional carbon emissions. To transform the
marketplace, the scale needs to get bigger. Partnering regionally allows us to more impactfully
leverage available funding and avoid unintended commute consequences regarding where and
if housing is built.
• Architecture2030 has done the legwork for you. We would recommend adopting the ZERO Code
model. It is working towards the same end goal, and has the code language crafted along with
the technical support document. Palo Alto has completed the cost effectiveness study.
• Education and workforce development are key.
Code
• When it comes to prescriptive pathway, simple is better. Instead of the complicated mix of
disincentives, legislate a Zero Net Carbon code that gives both flexibility and clarity in
expectations. For example, in the ZERO Code model you just oversize your solar to compensate
for your carbon usage (flexibility and fiscal incentive to design a very efficient electrified
building). This provides a highly simplified mechanism to incentivize a move towards carbon free
fuel sources while also rewarding creativity and innovation in building materials, design and
construction. Today, this approach is being successfully implemented in countries around the
world.
• The state’s energy code is moving incrementally towards similar goals (ZNE and ZNC), in three-
year increments. ZNE in 2020 for residential and 2030 for commercial. Incremental code
updates are expected to similarly move towards ZNC to achieve legislated state fossil fuel free
goals. Any reach code amendments should follow that path and not embark on a tangent that
will require course correction or overlapping regulations down the road.
• Establish a regulatory structure that makes smaller units feasible to build. Additional complexity
adds time and money to building, a cost that is felt most acutely by small projects and
affordable by design units.
Incentives
• As stated in your direction to staff, the City has the opportunity to encourage the construction
of buildings that help us achieve our Net Zero goal. The code, as currently proposed, instead
takes a disincentive/discourage approach that will likely result in other more damaging
outcomes. Integrating incentives and education is something to tackle immediately. Instead of a
carbon offset fee, inspire, encourage and incentivize the performance and electric pathways.
We specifically recommend looking for incentives that address multiple barriers to carbon
neutrality in simultaneity such as energy efficiency and fuel source, energy use and commuting
behavior, etc.
• In offering incentives, make sure they are true incentives (instead of fallacy or disincentives) for
those projects that achieve the standards, such as fossil free new construction that helpful
offset any additional costs associated with this approach. Some “true” incentives could include:
o Free energy modeling services (rebate program) for fossil free residential and non-
residential projects – design and compliance modeling
o Free induction ranges or electric water heaters
o Reduced minimum parking standards
o Up-zoning or density bonuses of parcels
o Reduced energy rates for fossil free projects through Monterey Bay Community Power
o A meaningful guaranteed fast-track with specific turnaround times through the
permitting process (i.e. 5-7 day turnaround)
Funding
• Leverage regional, state and federal grants to make the reduction of GHG’s in our built
environment as enticing, beneficial and easy as possible. This is part of a Major City Goal and,
instead of being used to generate funds, should be an investment priority.
• Our community’s participation in Monterey Bay Community Power is a tipping point to address
not only the fuel source but usage as well. Set it up to fund retrofits straight out of the gate.
• Leveraging 3C-REN https://www.slocounty.ca.gov/Departments/Planning-Building/Department-
News-Announcements/STATE-APPROVES-TRI-COUNTY-REGIONAL-ENERGY-NETWORK.aspx
• Energy Efficiency and Conservation Block Grant (EECBG) Program
• HUD Home Funds
Our community has time and time again been a small but mighty leader on topics ranging from public
art and open space to community health and wellbeing. When it comes to decarbonizing our region, we
once again have an opportunity to lead by example and create a regulatory environment that is
effective, clear and inspirational.
Thank you for your continued efforts to include the business community, we look forward to working
with you and your team throughout this process.
Sincerely,
Jim Dantona
President/CEO
San Luis Obispo Chamber of Commerce
1
Tonikian, Victoria
From:Read, Chris
Sent:Saturday, August 10, 2019 3:52 PM
To:Molly Kern; E-mail Council Website; Codron, Michael
Cc:Jim Dantona
Subject:RE: Draft Local Amendments to the 2019 California Building Code
Dear Molly Kern,
Thank you for the Chamber’s thoughtful comments. We are in receipt, and will reach out to you to discuss as
we work through them.
Sincerely,
Chris Read
Sustainability Manager
City Administration
990 Palm Street, San Luis Obispo, CA 93401-3249
E cread@slocity.org
T 805.781.7151
slocity.org
From: Molly Kern <molly@slochamber.org>
Sent: Friday, August 9, 2019 6:53 PM
To: E‐mail Council Website <emailcouncil@slocity.org>; Read, Chris <cread@slocity.org>; Codron, Michael
<mcodron@slocity.org>
Cc: Jim Dantona <jim@slochamber.org>
Subject: Draft Local Amendments to the 2019 California Building Code
Dear Mayor Harmon and Council Members,
I hope this email finds you well.
Attached, please find a letter on behalf of the SLO Chamber regarding the Draft Local Amendments to the 2019
California Building Code. We look forward to answering any questions you might have and further discussing this
important issue.
Thank you for your consideration,
Molly
Molly Kern
Director of Governmental Affairs
San Luis Obispo Chamber of Commerce
T: 805.786.2763 C: 805.440.3941
2
slochamber.org | imagineslo.com