Dear Mayor Ashcraft, Vice Mayor Daysog & Council Members Vella, Spencer and Jenkins:
ACT has reviewed the Equitable Building Decarbonization Plan (EBDP) attached as Exhibit 1 to Item 7-B on the Jan. 17 City Council Agenda. We support incentives and rebates provided by Alameda Municipal Power (AMP) and the City to promote the decarbonizing existing buildings by shifting from natural gas use towards all-electric buildings. However, we strongly oppose those parts of the EBDP that propose the requirement of replacing natural gas with electrification for the following reasons:
1. The Ability of AMP to Meet the Increased Service Load: Such a requirement would greatly accelerate the service load on our existing electrical grid. The EBDP describes AMP as being “confident in their capacity of to accommodate additional projected loads.” However, the very next paragraph states, “California as whole is facing continued stress on the statewide electrical grid and the potential for rolling State-ordered blackouts is expected to continue for all California customers, including AMP customers, for the near future.” (p. 26) This begs the question of whether AMP’s confidence is based on only its current incentive/rebate program or the imposition of required transition to electrical service proposed by the EBDP. Even if AMP is confident of its ability to meet the full demands of conversion from gas to electricity, the fragile state of the grid argues strongly against forcing people to depend entirely on electric power.
2. Unreasonable Costs Imposed on Building Owners: Many, if not most of the existing buildings will require upgrades to the electric service panels to bring them up to providing 200-amp service to each unit. In buildings where tenants pay their own electric bills, this will require upgrading “each” electric panel. Most buildings will require opening walls to install electric wiring where none presently exists. This will be disruptive to tenants and may require relocation during construction. The rebates planned to be offered to Alameda property owners will not cover the cost of the necessary upgrades, especially in buildings where the service panels have to be upgraded. In buildings where major appliances, furnace, hot water heater, clothes dryer, and cooking stove are gas, this will be a very expensive process. Upgrading these appliances as they reach the end of life means replacing them one at a time. This is totally unpractical as the electric panel and house wiring upgrades will have to be in place at the time each appliance reaches its end-of-life cycle. Replacing all appliances at one time will be very expensive and beyond the financial abilities of most mom-and-pop landlords.
3. Impact of Requiring Electrification Prior to Sale: One part of the EBDP would require that a building be upgraded to 100% electric before it can be sold. The cost of this upgrade would increase prices/rents in our already expensive housing market.
4. Cost of Gas vs. Electricity: The plan assumes the electric bills to be paid by tenants or low-income property owners after the upgrades will be less than what they pay now for electric and gas combined. At present electricity is much more expensive than gas to heat water or to heat a unit during winter times. While it has been predicted that this will eventually reverse the relative costs. That is currently a prediction not a reality.
In summary, we believe that there is insufficient data to satisfy us that the grid can handle the increased service load created by requiring, rather than incentivizing, electrification and ample evidence that the costs imposed on both owners and tenants will be unreasonable and result in severe consequences to the affordability of living in Alameda.
Sincerely,
Alameda Citizens Task force Board of Directors
The Equitable Building Decarbonization (EBD) is a plan to replace all gas appliances in ALL Alameda buildings by 2030, just 7 years from now. Our reading of the EBD plan is that the requirements to upgrade Alameda properties will not be accomplished on a voluntary basis. The estimate to upgrade a single family home is approximately $45,000. With City/AMP planned rebates of approximately $15,000, the average upgrade for that single family home could be around $30,000 for the property owner. Alameda’s older apartment buildings would cost more.
The City of Alameda has laid out a process for the replacement of gas appliances and has created a rebate schedule that is predicated on the ability of the City to obtain state and federal grant money to offer rebates to property owners for the necessary work required to upgrade Alameda’s buildings to 100% electric. At present there is no guarantee that Alameda will be able to obtain the grants necessary to offer rebates to every property owner in Alameda.
There are also questions about Alameda Municipal Power’s ability to provide the electricity required for a 100% electric Alameda.
At present all new construction in Alameda is required to be 100% electric. But the process of upgrading all existing buildings in Alameda will be a much more difficult process. Many, if not most of the buildings will require upgrades to their electric service panels to bring them up to providing 200 amp service to each unit. In buildings where tenants pay their own electric bills, this will require upgrading “each” electric panel. Most buildings will require opening walls to install electric wiring where none presently exists. This will be disruptive to tenants and may require relocation during construction.
The name of the plan is “Equitable Building Decarbonization”. The plan assumes the electric bills to be paid by tenants or low income property owners after the upgrades will be less than what they pay now for electric and gas combined. At present electricity is much more expensive than gas to heat water or to heat a living unit during winter times. The plan assumes that over time gas prices will continue to rise above what will be required with the new “energy efficient” appliances. Heat exchange units for hot water and building heat may or may not be less expensive over time. A lot depends on the building configuration. Heat exchange systems do provide cooling for summer seasons.
The rebates planned to be offered to Alameda property owners will not cover the cost of the necessary upgrades, especially in buildings where the service panels have to be upgraded. In buildings where major appliances, furnace, hot water heater, clothes dryer, and cooking stove are gas, this upgrade will be a very expensive process. Upgrading these appliances as they reach end of life means replacing them one at a time. This is totally unpractical as the electric panel and house wiring upgrades will have to be in place at the time each appliance reaches it’s end of life cycle. Replacing all appliances at one time will be very expensive and beyond the financial abilities of most mom and pop landlords.
One part of the EBD plan would be any building would have to be upgraded to 100% electric before it could be sold.
As Alameda has a rent control plan where limited construction costs can be recovered in higher rents, the financial burden for landlords will be excessive and in many cases impossible to achieve even with the rebate plan.
All electric households will be healthier to live in. A recent study reports that children who live in homes with gas appliances have higher incidents of Asthma, so that will be big plus for the EBD plan.
“New Study Finds Gas Stoves a Key Cause of US Childhood Asthma”
https://www.motherjones.com/politics/2023/01/study-gas-stoves-cause-asthma/?link_id=24&can_id=e932a47e5b93b9c8baf1df2dafcd47f6&source=email-mccarthy-sells-out-country-to-maga-lunatics-with-devils-deal&email_referrer=email_1780909&email_subject=judge-smacks-trump-down-in-250-million-lawsuit
The City Council agenda is found at the following link:| https://alameda.legistar.com/View.ashx?M=A&ID=1066764&GUID=4E85C669-80B2-4FC3-9DC7-5447A7CBA8CE
The Planning Board recommendation attached to the agenda item can be read at the following link: https://alameda.legistar.com/View.ashx?M=F&ID=11552885&GUID=EF9D805E-1108-4E8F-8AA8-47E930D8731D
The City Council presentation slideshow can be seen at the following link. The slideshow includes the proposed rebates.https://alameda.legistar.com/View.ashx?M=F&ID=11552890&GUID=7D553F43-8263-47C4-BB9C-F1DC6964F5B6
At the January 17th meeting the City Council will be voting to accept the Equitable Building Decarbonization Plan ordinance. If you have concerns regarding this plan, please contact your City officials at the following email addresses before Tuesday January 17th afternoon.
Send emails to the City Council members at:
CITYCOUNCIL-List@alamedaca.gov
Include a cc email to:
clerk@alamedaca.gov
manager@alamedaca.gov
To speak on the agenda item at the City Council zoom meeting you must register at the following link before the meeting starts:
https://alamedaca-gov.zoom.us/webinar/register/WN_waQjuTPhT8KJTRIFk90FeA
If links are not active, cut and paste links into your browser address line.
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The Transit Overlay shown here is where a planned zoning amendment will allow unlimited density development for any parcel inside the overlay.
Please send emails and appear for public comment at the November 15th Council meeting and any subsequent meetings where the proposed upzonings will be discussed.
Measure Z 2.0
In November of 2020, Measure Z was put on the ballot by Mayor Ashcraft and Councilmembers Oddie, Knox-White and Vella with the express purpose of repealing Article 26 of the City Charter that limits maximum residential density to 21 units per acre. 60% of Alameda voters rejected Measure Z, so Article 26 remains on the books today. It’s the law, and that should be the end of the story, but, sadly, it is not.
The State Housing Element Law requires every city to include a “housing element” in its General Plan that is revised every eight years and contains an inventory of land available for new housing construction in all income categories, with the number of units to be available for development in each category determined by a methodology dictated by the Law.
The Law requires that parcels qualifying as available to people in the lower income categories (Income up to 80% of the county median) must be zoned to allow at least 30 units per acre. The conflict created by our 21 units per acre limit was resolved in our 2015-2023 housing element by selecting about 100 acres of vacant land and that was formerly zoned as commercial or mixed use and upzoning it to allow residential development of up to 30 units per acre. This was lawful because Article 26 is pre-empted to the extent required to comply with state law. Since this upzoning did not impact our existing R-2 thru R-6 residential districts, it constituted a minimal exception to Article 26.
The City Planning Department’s new housing element for the 2023-2031 cycle clearly identifies sufficient parcels of land to meet the state determined number of units needed in all income categories without increasing the 21 units per acre density in our residential neighborhoods (known as R-2 thru R-6 zoning districts). Nevertheless, they propose to massively increase the density of these neighborhoods by asserting that state fair housing law requires every zoning district in the city to be densified to allow lower income units to be developed. THERE IS NOTHING IN THE LAW THAT SAYS THAT. It only requires that lower income residents not be isolated in “low opportunity” areas of a city. To Alameda’s credit, it has consistently required market rate developers to provide at least 8% of their project at rents or prices affordable to lower income folks. These units are all being built adjacent to the market rate units. (See Alameda Point, Alameda Marina, Alameda Landing and DelMonte projects)
City Planning Director Andrew Thomas has consistently supported repeal of Article 26 for several years. We believe that his proposed massive densification of these residential districts has little to do with any requirements of state law and everything to do with his steadfast distaste for Article 26. Having failed to repeal the Article with Measure Z, he now seeks to eradicate it without voter approval.
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