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°i Tr�C <br />436 14th Street <br />Oakland, CA 94612 <br />MEMORANDUM <br />To: Gabriel Taylor, Peter Strait (California Energy Commission) <br />ATTACHMENT G <br />August 13, 2019 <br />From: Farhad Farahmand, Abhijeet Pande (TRC), Rafael Reyes (Peninsula Clean Energy) <br />Re: Interpretation of Cost Effectiveness Analysis as it Relates to Menlo Park Reach Code Proposal <br />As part of an amendment to the California Building Standards Code, the City of Menlo Park is seeking a <br />requirement for all new construction buildings to be all -electric but allows for several exceptions. For <br />residential buildings, the City is proposing to allow natural gas to be used for cooking and decorative <br />fireplaces. For nonresidential buildings, certain categories of buildings such as public safety buildings, <br />designated emergency centers as well as commercial buildings containing scientific laboratories that <br />require natural gas for operational and process reasons are proposed to be exempted. <br />This memo serves to clarify the cost-effectiveness justification of these proposals as required by <br />California Code of Regulations (CCR), Title 24, Part 1, 410-106 and request the Energy Commission's <br />preliminary approval of this justification. If approved, an updated version of this interpretation will be <br />included with Menlo Park's application to the Energy Commission. <br />The statewide investor owned utility codes and standards program developed a new construction cost <br />effectiveness analysis for all California climate zones which included ail -electric measures as part of <br />multiple packages. These analyses have been attached, and: <br />♦ Were performed for both residential and nonresidential buildings <br />♦ The residential prototypes included 4 end -uses in analysis: space heating, water heating, <br />cooking, and clothes drying. These assumed savings from avoided natural gas infrastructure <br />to and within the residence. <br />The nonresidential prototypes included 2 end -uses in analysis: space heating and water <br />heating. <br />♦ Found that it is cost-effective to construct all -electric buildings compared to the 2019 Standards <br />ACM baseline, including all end -uses analyzed, partially due to upfront cost savings associated <br />with foregoing a natural gas connection to the building. <br />Menlo Park's code proposal would allow the construction of all -electric buildings which has been shown <br />to be cost-effective using the TDV cost-effectiveness metric. <br />We seek your preliminary confirmation that the existing cost effectiveness studies completed are <br />sufficient to support Menlo Park's proposal, considering further that: <br />♦ In residential buildings, a proposed building with electric space- or water -heating is already <br />compared to a standard building with these electric end -uses. Thus, no cost effectiveness <br />criteria are explicitly required for the electrification of these end -uses. The exemption for gas to <br />P:\City Council Staff Reports\2019\20190910\FOR CLERK ONLY Pending Staff Reports\FINAL\F5 - Reach codes\4-Att G <br />Supplemental TRC Memo.docx 9/3/2019 5:39 PM <br />