HomeMy WebLinkAboutStaff Report 2507-49222.Discussion of Gas Utility Transition Study Scoping; CEQA Status - Not a
Project DISCUSSION: 6:50PM – 7:50PM
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Utilities Advisory Commission
Staff Report
From: Alan Kurotori, Director Utilities
Lead Department: Utilities
Meeting Date: September 3, 2025
Report #: 2507-4922
TITLE Discussion of Gas Utility Transition Study Scoping; CEQA Status - Not a Project
RECOMMENDATION
This is a discussion item and no recommendation is being presented to the Utilities Advisory
Commission (UAC) at this time. Staff is seeking UAC feedback on the scope for a study of the
financial and operational impacts of electrification on the gas utility.
EXECUTIVE SUMMARY
Achieving the community’s greenhouse gas emissions reductions goals requires options
including deep reductions in building emissions. Regardless of how quickly the community
reaches these goals, impacts on the gas utility’s financial structure and physical operations are
expected if community members participate in electrification efforts sufficiently to achieve
adopted City Council emissions reduction goals. Staff is beginning a study of those impacts and
is seeking feedback on its approach.
The study will simulate different patterns of electrification throughout Palo Alto; identify
opportunities for gas main and service abandonment which may include operational
efficiencies; and estimate abandonment costs, changes in operational costs, and customer class
cost allocations. The study will prioritize continuing to operate the gas system safely and
identify portions of the gas system that should be retained for operational reasons even after
substantial parts of the system have electrified.
BACKGROUND
Gas utilities throughout California are planning for the possible impacts of widespread building
electrification. The California Public Utilities Commission (CPUC) has a gas transition proceeding
for the investor-owned utilities (IOUs), but many of the issues IOUs face differ from Palo Alto.
IOUs have a different capital structure, service territories with different characteristics, and
different system designs. City staff monitors the CPUC proceeding to learn potential lessons and
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participated in an early workshop that led to the proceeding, however analysis specific to Palo
Alto is also needed.
The UAC received preliminary high-level staff analyses of the potential cost of abandoning the
gas utility, staffing impacts, and rate impacts on November 4, 20201 and January 2021,2 but
additional study is still needed. Abandonment costs are likely significantly higher than the prior
studies showed because they did not sufficiently account for the physical system constraints or
the difference in rate impacts by customer classes.
ANALYSIS
The objective of the Gas Transition Study is to assess the potential financial and physical
impacts of large-scale building electrification on the gas system and identify strategies to
manage those impacts. The study will be conducted primarily in-house, with consultants
assisting in physical gas system modeling and rate modeling.
Staff will simulate four electrification scenarios for single-family, multi-family, and
nonresidential sectors, simulating 20%, 40%, 60%, and 80% reductions in gas sales (see
Attachment A for full scenario definition). Gas usage will be modeled down to the meter level.
For each scenario, staff will estimate the number of gas main segments that could be retired
and the resulting abandonment costs and changes in operational costs. Staff will then estimate
rate impacts by customer class.
Safety will remain the top priority throughout the hypothetical transition, and the study will
analyze resulting cost impacts. Due to the complexity of electrification for some commercial
customers (e.g. restaurants), and for larger industrial and medical users, a core network of gas
lines is expected to be preserved to serve these users. The analysis will assume that retiring
entire blocks of gas mains is more cost-effective than retiring individual services.
Abandoning gas infrastructure at the block level is more efficient than retiring individual
services, primarily because it significantly reduces the number of excavation events. Block-level
abandonment involves digging into the street to cut and cap the main at each end of a block
and removing all associated meters in one operation. This contrasts with the more labor-
intensive process of retiring services one at a time, which also requires much more excavation
and pavement restoration to abandon each customer service lateral. The study will look at the
cost of both block-level and service-level abandonment as strategies and a range of estimates
for the total associated costs.
1 Staff Report ID#11639, November 4, 2020, Discussion of Electrification Cost and Staffing Impacts on the City of Pa
lo Alto's Electric and Gas Distribution Systems, http://cityofpaloalto.org/civicax/filebank/blobdload.aspx?BlobID=7
8897
2 Staff Report ID#11751, January 6, 2021, Discussion of Projected Electrification Impacts on Gas Utility System
Average Rates, https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-
reports/agendasminutes/utilities-advisory-commission/archived-agenda-and-minutes/agendas-and-minutes-
2021/01-06-2021special/01-06-21-uac-item-1.pdf
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Operational costs that may vary during the transition will also be evaluated, such as customer
service, leak monitoring and repair, meter investigation, and overhead allocations. Many of
these functions are shared across utilities, and their costs are allocated based on factors such as
the number of meters served or total revenues. As gas sales decline and parts of the system are
retired, both actual workload and allocation factors will shift—though not always
simultaneously. Operational costs may decrease in increments as work reductions reach critical
thresholds. The study will analyze these patterns, assess positive and negative impacts on other
utilities, and identify strategies on cost management and secondary impacts on other utilities.
Key output metrics will include:
Number of gas mains with low or no usage
Estimated abandonment costs
Changes in operational costs
Financial impacts on other utilities
Effect of reduced natural gas on natural gas cap-and-trade revenues
Effects on General Fund revenue reduction (18% General fund transfer, utility user tax,
cost allocation).
The study will model different likelihoods of residential customers disconnecting gas service
after electrifying space and water heating. This will help assess the influence of disconnection
rates on system outcomes. Staff will also evaluate strategies including funding needed to
encourage disconnection, including incentive programs, rate design, and block-level
electrification initiatives. Commercial buildings will be assumed to retain gas service .
Assumptions like these are only for modeling and do not represent an assessment of whether
this level of electrification is feasible.
The study will also examine the physical layout of the gas network under various electrification
scenarios. Unlike many regional systems, the City’s gas infrastructure is highly networked,
allowing for block-level disconnections. However, not all unused mains can be removed without
affecting system capacity and functionality. For example, a medium-diameter main with no
active services might still be needed to maintain pressure or flow. The study will analyze these
constraints and explore targeted main upsizing and replace to enable other residential main
retirements.
FISCAL/RESOURCE IMPACT
The study is expected to require about $150,000 in consulting costs ($60,000 for building a gas
model and $90,000 for rate analysis and scenario simulation) funded by the Utilities Gas
Engineering and Resource Management Division budgets and about 0.3 FTE in staff time (0.15
FTE from Utilities Water-Gas-Wastewater Engineering and 0.15 FTE from the Utilities Resource
Management Division and the Climate Action Team combined).
The gas utility fiscal and resource impact of widespread electrification on the gas utility and the
costs of gas system abandonment will be assessed in this study.
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STAKEHOLDER ENGAGEMENT
This topic was discussed by the UAC at its November 2020 and January 2021 meetings, as noted
above, and since then the need to more carefully assess the costs of transitioning the gas utility
has been raised in several meetings of the UAC, S/CAP climate stakeholders, the Council
subcommittees focused on climate contexts, and at City Council. Staff also discussed this topic
with the City Council’s Climate Action and Sustainability Committee on June 13, 2025 and the
Climate Action and Sustainability Working Group prior to that meeting. There was support for
the general direction of the analysis. There was also interest in exploring ways to increase the
likelihood customers choose gas disconnection after electrifying space and water heating. Staff
clarified that this will be the subject of subsequent policy discussion through 2026 and 2027
after the initial analysis. The Committee also recommended looking at the studies and pilots of
other gas utilities doing similar work while acknowledging there are a limited number of utilities
pursuing this type of analysis.
ENVIRONMENTAL REVIEW
The UAC’s discussion of this topic does not meet the California Environmental Quality Act’s
definition of a project, pursuant to Public Resources Code Section 21065, and no environmental
review is required.
ATTACHMENTS
Attachment A: Draft Scenario Design for Gas Transition Study
Attachment B: Staff Presentation
AUTHOR/TITLE:
Alan Kurotori, Director of Utilities
Staff: Jonathan Abendschein, Assistant Director, Climate Action
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Attachment A
Draft Scenario Design for Gas Transition Study
Scenari
o
Gas
Sales
Reductio
n
Residential Space
and Water Heating
Electrification
Small and Medium
Non-Residential
Space and Water
Heating
Electrification
Medical and Industrial
Electrification*
1 20%25%25%0%
2 40%50%50%0%
3 60%75%75%0%
4 80%100%100%0%
* In practice, some electrification will occur in this sector, but staff does not have good
visibility on the potential for electrification in this space due to the prevalence of unique /
process loads
Methodology:
• For each scenario staff will run a large number of random iterations assigning space and
water heating electrification to different meters / gas mains. A sensitivity will be run for
each scenario varying the likelihood of resident gas meter disconnection.
• For each scenario staff will calculate the range of gas mains with low or no gas usage
resulting from all the iterations for that scenario.
• Staff or the City’s consultant will add one or two sample iterations for each scenario to its
gas system model and identify how many mains noted for removal by the simulation
could not actually be physically removed. Scenario results will be adjusted accordingly.
• Staff will estimate the average abandonment costs for each scenario including sensitivity
analyses between higher costs of individual services abandonment versus larger block
abandonment costs.
• Staff will estimate changes in operational costs, allocations between utilities, and
reductions in General Fund revenues resulting from the decreased gas sales and gas
main abandonment.
• Staff and the City’s consultant will estimate the customer class average rates for each
scenario based on the estimated abandonment costs, reduced gas sales by customer
class, and changes in operational costs.
Based on these results staff will identify physical and financial issues and develop feasible
strategies to mitigate them.
July 9, 2025 www.cityofpaloalto.org
Gas Transition Study Scoping
Utilities Advisory
Commission
Why Study the Gas Transition?
•City, State, and Regional policies drive building electrification
•If successful, gas use will decline significantly
•The City must plan for financial, physical, and safety impacts
•Goal is a safe, smooth, equitable transition
Council 2025 Priority Objective #32:Share preliminary analysis of
strategies for a physical and financial transition of the gas utility to
relevant policymakers and stakeholders
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Study Goals
•Understand physical impacts of electrification on gas
infrastructure
•Quantify physical, operational, and financial impacts
•Estimate cost of gas main and service abandonment
•Develop strategies to:
•facilitate abandonment
•mitigate physical and financial impacts
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Study Outputs
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Other Outputs
•Cost impacts to other utilities
•General Fund transfer and UUT impacts
For the Gas Utility
•Cost of gas main/service abandonment
•Operational cost impact
•System average rate changes by class
•How much funding would be needed
from some other source to keep gas
rates in line with current forecasts
•Cap and Trade cost and revenue impacts
Electrification Scenarios to Model
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Scenario Reduction in Gas Sales Water and Space Heating Electrification
Residential Commercial
1 20%25%25%
2 40%50%50%
3 60%75%75%
4 80%100%100%
•Medical/industrial, commercial cooking excluded
•Gas disconnection likelihood evaluated for buildings with
water and space heating already electrified
Impacts on Gas Infrastructure
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Potential Opportunities and Constraints
•Mains of certain sizes may need to be retained for operational purposes
•Need to maintain service for key users (e.g. medical, industrial, restaurants)
•Retirement of certain mains (e.g. PVC, steel) may yield more savings
Impacts on Gas Infrastructure
•Fewer customers using the system
•Result: underused or unused gas mains
•Opportunity to retire entire blocks
Cost-Efficiency of Block-Level Gas System Retirement
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Drawbacks and Challenges
•Requires all homeowners to remove all gas appliances before it can be accomplished
•A single person with a single appliance can hold up gas main abandonment
•May be forced to do service by service abandonment – unsafe to leave unused gas
services in place for long durations
Block Level Retirement Benefits
•Standard practice: dig & abandon unused
lines for safety, avoided maintenance
•Abandoning by block cheaper than by
service – fewer excavations, less labor,
less street repair.
Gas Utility Impacts
Declining gas use, gas abandonment reduces workload
Workload may not decline enough to enable staff attrition – this
could increase per-unit gas cost for remaining customers
Changing Utility Costs with Electrification
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Other Utility Impacts
Shift fixed shared costs between utilities (e.g. as gas customers
disconnect customer service cost may shift to other utilities)
General Fund Impacts
Reductions in General Fund transfer, UUT
Potential for increased City gas utility bills
Next Steps
•Summer 2025: Advance study with the goal of having preliminary
results by Fall 2025, if feasible
•Fall 2025:
•Preliminary study results to UAC and CASC
•Results can be used to inform 2026-2027 S/CAP strategies
•Late 2025 / Early 2026: Final report
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CITY OF
PALO
ALTO