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Dear San Luis Obispo City Council Members,
The undersigned organizations submit this letter in strong support of the City of San Luis Obispo
Proposed Clean Energy Choice Program which amends the 2019 California Building Energy Efficiency
Standards,
We urge you to vote YES on the Clean Energy Choice ordinance because it is a critically important,
appropriate, and timely response to mitigate the climate, health, safety, and housing affordability
crisis in San Luis Obispo, and across the state.
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Dear San Luis Obispo City Council Members,
The undersigned organizations submit this letter in strong support of the City of San Luis Obispo
Proposed Clean Energy Choice Program which amends the 2019 California Building Energy Efficiency
Standards,
We urge you to vote YES on the Clean Energy Choice ordinance because it is a critically important,
appropriate, and timely response to mitigate the climate, health, safety, and housing affordability
crisis in San Luis Obispo, and across the state.
At the outset, we want to make clear that the Clean Energy Choice ordinance is not an
electrification mandate. Unlike some cities that are banning gas hook ups entirely, the proposed
Clean Energy Choice ordinance will provide options to people who want to develop new buildings
with gas. To account the higher emissions, new buildings with gas will be required to build more
efficient and higher performing buildings and offset gas use by performing retrofits on existing
buildings or by paying an in -lieu fee that will be used for the same purpose.
By adopting this ordinance, the City of San Luis Obispo will lead a wave of cities and counties across
California in declaring that residents and businesses have a right to clean, safe, reliable, and
affordable energy both on the grid, and inside their homes and buildings. San Luis Obispo will not be
alone in deciding to support all -electric new construction. The City of Carlsbad has already adopted a
reach code to require electric heat pumps or solar thermal water heating for new construction. The
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City of Berkeley recently adopted an ordinance prohibiting gas in new construction. Similarly, over fifty
cities and counties in the SF Bay Area, Central Valley, Central Coast, North Coast, and Southern
California are pursuing reach codes and all electric standards to shift to all -electric new construction. As
we have witnessed with rooftop solar and zero -net energy ordinances, city and county leadership is key
to raising the ambition of state policymakers. Change starts at the local level, and climate leadership is
desperately needed today if we are to reduce emissions to comply with climate science.
The ordinance will lower the cost of new construction and support affordable housing. All -electric
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homes are cheaper to build than gas -heated buildings — and they will lower monthly utility bills for
residents and businesses in San Luis Obispo. Encouraging new construction is built without gas
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hookups will help San Luis Obispo developers build more quickly and affordably as there will be no
need for new costly gas infrastructure — an advantage in San Luis Obispo's ongoing housing crisis. A
recent analysis by the Statewide Utility Codes and Standards Team found that building all -electric
reduced construction costs on average $5,000 for single-family homes and over $2,000 per unit in
multi -family buildings.
Building all -electric will also lower energy bills for San Luis Obispo residents and businesses as the state
transitions to a carbon -neutral economy. Southern California Gas company requested rate increases at
the CPUC of 30 percent real (44% nominal) by 2022.5 Beyond this rate increase, Energy and
Environmental Economics (E3) reports in its Future of Gas study for the California Energy Commission,
that it expects gas rates to continue to increase even more rapidly through 2050, making gas
increasingly unaffordable. Gas rate hikes are caused by safety upgrades to the aging gas system and
City of Carlsbad, Water Heating Ordinance, available at:
https://www.carisbadca.gov/services/depts/pw/environment/cap/waterheat.asp
z City of Berkeley, Gas Prohibition Ordinance, available at:
https:Hdrive.google.com/file/d/OB1CjI KwljNVhYklwYlZDeEp4OEZMZWwyU IIxM DIUQm FQdm EO/view
a Synapse Energy, "Decarbonization of Heating Energy Use in California Buildings"
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4 Rock Mountain Institute, The Economics of Electrifying Buildings"
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'So Cal Gas, https:llwww.socalgas.co lregulatorvlA17-10-008.shtml
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decreased gas demand due to the state's energy efficiency goals and the warming climate. As gas
becomes less economical and as more Californians recognize the climate, health and safety hazards of
burning gas in their homes and businesses, people will leave the gas system by replacing gas appliances
with more efficient electric alternatives like heat pumps and induction cooktops. The ongoing decline in
gas throughput will lead to gas rate hikes as fewer ratepayers are burdened with the costs of the gas
system, thereby incentivizing more to leave the gas system and driving up rates for Californians still
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using gas. Gas distribution pipeline extensions to new homes are also expected to become stranded
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assets well before the end of their useful life as more buildings electrify over the coming years.
Stopping investments in new gas infrastructure is a fiscally prudent strategy to avoid saddling ratepayers
and taxpayers with the costs of maintaining and ultimately decommissioning stranded gas
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infrastructure.
The ordinance will improve air quality and public health for San Luis Obispo residents.
All -electric new construction will immediately improve indoor air quality for San Luis Obispo
residents. On average, Californians spend 68 percent of their time indoors, making indoor air
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quality a key determinant of human health. The combustion of gas inside our homes produces
harmful indoor air pollution, specifically nitrogen dioxide, carbon monoxide, nitric oxide,
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formaldehyde, acetaldehyde, and ultrafine particles. These odorless and undetectable gas
combustion pollutants can cause respiratory diseases, as well as more serious conditions,
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including death. Lawrence Berkeley National Laboratory recently found that air pollution
levels in the 60 percent of homes with gas stoves exceed EPA's definition of clean air, i.e. air
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pollution levels indoors in these homes would be illegal if found outdoors. A recent study
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found that gas stoves may be responsible for up to 12 percent of childhood asthma cases.
6 Energy and Environmental Economics, Draft Results: Future of Natural Gas Distribution in California,
h_ttps:f/ww2.enery.ca.ov/research/notices/2019-06-06 workshopf2019-06-06 Future of Gas Distribution.pdf
Ibid.
$ "The 'Rush To Gas' Will Strand Billions As Renewables Get Cheaper, Study Says"
www,foirlbes.co siites effmaarnal�a.�n 2.0 n. 0!!: 2. n. tl�e cru sh ta.2 gas will cost billions in stranded assets as it
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9 Energy and Environmental Economics, Draft Results: Future of Natural Gas Distribution in California,
h_ttps:f/ww2.enery.ca.ov/research/notices/2019-06-06 workshopf2019-06-06 Future of Gas Distribution.pdf
10 Klepeis, N. E.; Nelson, W. C.; Ott, W. R.; Robinson, J. P.; Tsang, A. M.; Switzer, P.; Behar, J. V; Hern,
S. C.; Engelmann, W. H. The National Human Activity Pattern Survey (NHAPS): a resource for assessing exposure to
environmental pollutants. J. Expo. Anal. Environ. Epidemiol. 2001, 11 (3), 231-252.
11 See, Jennifer Logue et al., "Pollutant Exposures from Natural Gas Cooking Burners: A Simulation -Based
Assessment for Southern California” Environmental Health Perspectives Vol. 122 No. 1 pp. 43-50, (2013); Victoria
Klug and Brett Singer."Cooking Appliance Use in California Homes—Data Collected from a Web -based Survey."
Lawrence Berkeley National Laboratory (August 2011); John Manuel, "A Healthy Home Environment?"
Environmental Health Perspectives, Vol. 107, No. 7 1999, pp. 352-357; Nasim Mullen et al., "Impact of Natural Gas
Appliances on Pollutant Levels in California Homes" Lawrence Berkeley National Laboratory, 2012.
12 California Air Resources Board, "Combustion Pollutants" (reviewed Jan. 19, 2017). Available at
lhttiPs //www,airlb.,ca.,gov/ireseairclh/iindo sir/coirmlbtistiion.,Ihtirmn
13Pollution in the Home: Kitchens Can Produce Hazardous Levels of Indoor
Pol I uta nts"https:Hnewscenter.lbi.gov/2013/07/23/kitchens-ca n -prod uce-haza rdous-levels-of-i ndoor-poll uta nts/
14Cooking with gas, damp housing may cause childhood asthma:
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All -electric new construction will also be key to mitigating outdoor air pollution in San Luis Obispo.
Hazardous air pollution is a particularly acute issue for low-income communities and people of color,
who are exposed to higher incidences of particulate matter (PM 2.5) and other harmful pollutants.
While most think of trucks, power plants and industry as the major culprits of air pollution, buildings
have for too long gotten a free pass. Gas combustion appliances lack modern-day pollution controls
and are a major source of air pollution, particularly in the winter from gas heating. Gas appliances in
residential and commercial produce nearly nine times more nitrogen oxide (NOx) emissions than gas
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power plants. Nitrogen oxide is a precursor to ozone and PM 2.5, two pollutants that cause asthma,
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lung cancer, respiratory diseases, and premature death. All -electric new construction is an essential
step to improving air quality in San Luis Obispo and the greater central coast.
The ordinance is a critical step to begin to improve safety, especially in the face of earthquakes. Gas
pipelines are vulnerable to methane leakage, over -pressurization, and earthquakes. Aliso Canyon
(2015/16), Bakersfield (2015), Carmel (2014), San Bruno (2010), and Rancho Cordova (2008), and the
recent fires in North Carolina, Massachusetts, and San Francisco are but a few of the important and
unfortunate reminders of the gas system's inherent risks. Given the San Andreas earthquake fault in
Northern San Luis Obispo, fires exacerbated by leaking gas after earthquakes are of significant concern.
Communities with gas pipelines in earthquake -prone areas of San Luis Obispo face increased risks of
fires since vibration and changes in pipeline tension during seismic events can result in leaking gas that
fuels fires. Aging pipelines and associated equipment, and inflexible pipeline materials are vulnerable to
shifts in the earth and buildings that put additional stress on pipelines, causing cracks and methane
leaks. The California Seismic Safety Commission estimates up to half of total post -earthquake fires are
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related to gas leaks.
The ordinance will make San Luis Obispo homes and businesses safer and more resilient in the face of
climate change. California is experiencing an increasing occurrence of extreme heat waves, with
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practically each summer breaking previously held record temperatures. Many San Luis Obispo
residents, 12 particularly low-income families, do not have air conditioning and are not prepared to adapt
to these heat waves, posing new health and safety risks. Air conditioning is an important bonus from
replacing gas furnaces with electric heat pump space heaters, as the heat pumps can operate in reverse
and provide high efficiency cooling when needed. Electrification offers greater comfort, safety, and
climate resiliency when temperatures peak.
The ordinance is a necessary step to achieve San Luis Obispo's climate goals. The City of San Luis
Obispo is currently working on a climate action plan to achieve its carbon -neutrality goals by 2035.
1s "Emission Inventory Data" 'Iht'1tps://www.airb.(;a. Yov/eii/eirm�iissiiondata,htirm�
16 "Health Effects of Ozone and Particle Pollution"
11 s,.In.5::./..W.A.w;;,ll,,uA,lm, _oir ou�ir ii niitiiatiives/heallthy aiir/sa.�ta/Ilheallth iriisks/
1' California Seismic Safety Commission, Improving Natural Gas Safety in Earthquakes, (Adopted July 11, 2002), p.
1. Available at _tty:llssc.ca.govlfor s pubslcssc 2002-03 natural gas safetv.pdf
""2017 hottest summer in California history"
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Residential and commercial buildings are the second largest source of greenhouse gas emissions in San
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Luis Obispo. Building electrification is a critical step to decarbonize the buildings sector and achieve the
City's emission reduction targets. Electrifying buildings can reduce emissions today compared with
mixed -fuel buildings, and the greenhouse gas savings only grow as the grid gets cleaner. When paired
with Monterey Bay Community Power's carbon free electricity supply, all -electric new buildings can be
carbon -free, while avoiding the affordability, health, safety issues associated with fossil fuels.
Lastly, we are concerned about a scare campaign by the oil and gas industry in opposition to this
ordinance. The oil and gas industry, including their front groups Californians for Balanced Energy
Solutions and Californians for Affordable and Reliable Energy, are actively lobbying against building
decarbonization and electrification in local government, state regulatory agencies, and in the media.
These groups are using scare tactics that are not based in facts, and their mission is driven by
shareholders not residents of San Luis Obispo. The ordinance has been vetted by experts, stakeholders,
and the public on multiple occasions and is ready for Council discussion and a supportive vote. We
encourage you to reach out to the undersigned groups with any questions or comments about the
ordinance.
Sincerely,
SLO Climate Coalition — Eric Veium, Chair
Sierra Club - Andrew Christie, Chapter Director
Surfrider Foundation, San Luis Obispo Chapter — Charles Varni, Coordinator
EcoSLO — Mary A. Ciesinski, Executive Director
Green Business Network —Cory Jones
Central Coast Green Building Council — Brianna Ruland
Sunwork— Elyssa Edwards, Business Development
Extinction Rebellion SLO — Dr. Erin Pearse
Ecologistics, Inc. — Saba Asghary, Treasurer
Sunrise —Aliya Smigel, Co -President
SLO County Progressives —Tarrah Graves, Co -Chair
19 City of San Luis Obispo, https://www.slocity.org/home/showdocument?id=23236
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Fossil Free Silicon Valley
Beyond Efficiency — Dan Johnson, Sustainability Architect Leader
American Passive House Network — Bronwyn Barry, Board President
Association for Energy Affordability — Andrew Brooks, Director of West Coast Operations North
Menlo Spark — Diane Bailey, Executive Director
Redwood Energy — Sean Armstrong, Managing Principle
Guttmann & Blaevoet —Ted Tiffany, Principle & Director of Sustainability
Urban Environmentalists — Nathan Chan, Co -Lead
Project Green Home — Sven Thesen, Founder & CEO
Fossil Free Mid -Peninsula — Carol Cross, Co -Convener
Natural Resources Defense Council — Pierre Delforge, Senior Scientist
Carbon Free Silicon Valley—James Tuleya, Chairperson
Kate Harrison — Berkeley City Council Member, District 4
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