City Council Members,
Opposed to Item K-1 - local amendments to the 2022 California Building Standards Code, without modification
This proposed regulation would extend the California Green Building Code electrification requirements for new construction to “all residential construction additions, alterations, repairs, and/or accessory dwelling unit conversions that include the replacement or upgrade to the main electric panel.”
I am concerned that this requirement will have the effect of displacing low-income residents and those on fixed income, worsening affordability in neighborhoods already stressed by high costs for housing, home insurance and maintenance. Although the aim of the program to reduce greenhouse gas emissions is laudable, I do not believe that the city has thought through the cost implications to owners of older houses.
My own neighborhood, the Willows, is comprised of homes built predominantly between 1940 and 1945. Except for new construction, many homes have multiple barriers to the prewiring requirements of this regulation:
• Substandard wiring that will require rewiring the entire house to meet the requirements for a panel upgrade
• Electrical panel too close to the gas meter (common in older houses)
• Insufficient space to install a heat pump water heater (HPWH) without modifications to interior and exterior walls
Has the EOC or City Council done a survey of how many homes will be impacted by this regulation, and the electrification costs to homeowners?
• A neighbor recently paid $30,000 to rewire their 1200 square foot 1940 house, which did not include costs for replacing blown-in insulation or repairing the walls after rewiring.
• The November 2024 report of the Community Services Electrification Project attached to the agenda indicates that the expenditures from the first installment of the CEC grant ($2.24 million, of which $2.206 million is for home upgrades) will be exhausted by June 2025. As of the date of this report, only 7 homes had signed contracts with Peninsula Clean Energy, which equates to $31,000 per home.
It is reasonable to require new construction and major remodels to meet current standards to support electrification but, in my opinion, requiring prewiring for minor panel upgrades will be counterproductive. Residents may choose to extend the life of their current gas-fired equipment rather than invest large sums in upgrading houses that will be teardowns for the next owner. It will also discourage partial electrification, such as replacement of gas-fired stoves, if that requires a new panel circuit.
I would support this regulation if it includes the following modifications:
• Apply only to major remodels of existing residences
• Eliminate the requirement for a 240V circuit, as there are alternative electrification solutions that can be accommodated with 100 amp, 120V panels
However, I suggest that a vote on this measure be postponed to after March 31, 2025 when PG&E issues their first report to the Public Utilities Commission on their track record in reducing delays in permitting residential electrical upgrades. Currently, permitting delays pose a major barrier to electrification, as evidenced by the fact that none of the PCE projects have commenced construction.
Naomi Goodman
Willows neighborhood, Menlo Park
