ACT Letter: City Council Jan. 17th 2023, Equitable Building Decarbonization Plan

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

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