HomeMy WebLinkAboutStaff Report 2407-3266CITY OF PALO ALTO
CITY COUNCIL
Special Meeting
Tuesday, November 12, 2024
Council Chambers & Hybrid
5:30 PM
Agenda Item
3.Annual Report on Sustainability and Climate Action Plan (S/CAP) Implementation: 2022
Greenhouse Gas Inventory, Quarterly S/CAP Progress Report, and S/CAP Key Performance
Indicators Annual Progress Report; CEQA status - Not a Project Staff Presentation, Public
Comment
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City Council
Staff Report
From: City Manager
Report Type: STUDY SESSION
Lead Department: Public Works
Meeting Date: November 12, 2024
Report #:2407-3266
TITLE
Annual Report on Sustainability and Climate Action Plan (S/CAP) Implementation: 2022
Greenhouse Gas Inventory, Quarterly S/CAP Progress Report, and S/CAP Key Performance
Indicators Annual Progress Report; CEQA status - Not a Project
RECOMMENDATION
Staff recommends that the City Council review the Sustainability and Climate Action Plan
(S/CAP) Implementation Progress through the second and third quarters of calendar year 2024,
the Palo Alto Citywide Greenhouse Gas (GHG) Inventory for calendar year 2022, the Palo Alto
Municipal GHG Inventory for calendar year 2022, and the S/CAP Key Performance Indicators
(KPI) Annual Progress Report for calendar year 2023.
EXECUTIVE SUMMARY
The City is implementing the Sustainability and Climate Action Plan (S/CAP) to help the City
meet its sustainability goals, including its goals of reducing greenhouse gas (GHG) emissions
80% below 1990 levels by 2030 (the “80 x 30” goal) and achieving carbon neutrality by 2030.
Since the S/CAP was adopted in June 2023, staff has provided three implementation updates,
covering progress in Q3 2023, Q4 2023, and Q1 2024. Unlike previous quarterly updates, this
update includes two quarters of progress. This report was coordinated with the Climate
Protection Ad Hoc Committee.
This report includes the 2022 Palo Alto Citywide GHG Inventory (Attachment A), a comparison
between the 1990 and 2022 Citywide GHG Inventories (Attachment B), the 2022 Palo Alto
Municipal GHG Inventory (Attachment C), and the S/CAP Key Performance Indicators for
calendar year 2023 (Attachments D and E). These reports show that Palo Alto has made
significant progress toward its goal, with a 47.4% decrease in total community emissions from
1990 levels as of 2022, despite a population increase of 21.3% during that same time period.
Emissions increased slightly from 2020 to 2022, as was expected due to the temporary effects
of the pandemic (reduced transportation emissions due to remote work and an economic
downturn).
Despite the progress made toward the 80 x 30 goal, a “straight-line” approach to measuring
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progress would suggest the community should have achieved a 64% decrease from 1990
emissions in 2022. This result is expected, as the S/CAP and the 2023-2025 Work Plan include
an approach of piloting programs and completing studies that are intended to lead to scaling
those programs more widely, with accelerating GHG reduction results. Work underway on pilot
programs and the S/CAP Funding Study will help to define upcoming work and the strategic
balance between incentives and mandates. Ultimately, the S/CAP and the 80 x 30 goal are a
community partnership whose success requires extraordinary programs offered by the City and
strong engagement and participation by community members.
•Modernizing the grid to improve reliability, resiliency, and to enable electrification
•Implementing programs to help the community electrify
•Raising awareness and promoting these programs
•Completing studies to inform decisions about how to manage the electrification
transition
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and flexible energy technologies into electric grid planning, and how to manage the gas utility
through an electrification transition. Some of these studies are receiving grant funding from the
American Public Power Association with the intent of sharing the results nationally with other
publicly owned utilities to help them take similar steps.
BACKGROUND
1 and in October 2022 the City Council adopted the
ambitious goal of achieving carbon neutrality by 2030.2 Staff, with community and the City
Council input, referred to the 2016 Sustainability and Climate Action Plan (S/CAP) Framework
and 2018-2020 Sustainability Implementation Plan to create a comprehensive S/CAP and Three-
Year S/CAP Workplan.
3
certified the Comprehensive Plan Environmental Impact Report Addendum: Update to the
1 City Council, April 18, 2016; Agenda Item #10; SR #6754,
https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/reports/city-manager-reports-
cmrs/year-archive/2016/id-6754.pdf
2 City Council, October 3, 2022; Agenda Item #9; SR #14720,
https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/agendas-minutes/city-council-
agendas-minutes/2022/20221003/20221003accsm-amended-presentations.pdf#page=131
3 2022 Sustainability and Climate Action Plan;
https://www.cityofpaloalto.org/files/assets/public/v/1/sustainability/reports/2022-scap-report_final.pdf
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Sustainability and Climate Action Plan,4 and accepted the 2023-2025 S/CAP Workplan.5 The
S/CAP is an ambitious plan to reduce the city and community’s GHG emissions, while also
guiding how Palo Alto uses land and natural resources in ways that ensure quality of life for
future generations. The S/CAP aligns with several goals of the 2030 Comprehensive Plan
Implementation Plan.6
The first S/CAP implementation update included progress through Q3 2023 and was introduced
in November.7 The second S/CAP Implementation update included progress through Q4 2023
and was introduced in February.8 The third S/CAP Implementation update included progress
through Q1 2024 and was introduced in May.9
The 2022 S/CAP and 2023-2025 S/CAP Work Plan align with one of the four Council Priorities for
CY 2024: “Climate Change & Natural Environment: Protection and Adaptation.” In addition,
there are several overlapping Council Priority Objectives, the status of which can be found in
the 2024 Council Priority Objectives Q2 Report.10 This report references the Council Priority
Objectives in parentheses where applicable.
Both the Palo Alto Citywide and Municipal GHG Inventories calculate emissions for calendar
year 2022. As a result of various City-led initiatives, programs, and activities focused on climate
change and sustainability, by the end of 2022, Palo Alto reduced citywide GHG emissions an
estimated 47.4%, despite a population increase of 21.3% during that same time period. Due to
changes in methodology, it is not possible to do a full comparison of the 2022 Municipal GHG
Inventory with previous inventories.
In previous years, the GHG Inventories were presented to the City Council around Earth Day,
April 22. However, moving forward, in order to better align with data availability and the
cadence of quarterly S/CAP Implementation Updates, future GHG Inventories will be presented
4 Comprehensive Plan Environmental Impact Report Addendum: Update to the Sustainability and Climate Action
Plan, 2023; https://www.cityofpaloalto.org/files/assets/public/v/1/agendas-minutes-reports/agendas-
minutes/city-council-agendas-minutes/2023/2023comprehensive-plan-environmental-impact-report-addendum-
update-to-the-scap.pdf
5 2023-2025 S/CAP Workplan, 2023;
https://www.cityofpaloalto.org/files/assets/public/v/1/sustainability/reports/2023-2025-scap-work-plan_final.pdf
6 2030 Comprehensive Plan; https://www.cityofpaloalto.org/Departments/Planning-Development-
Services/Housing-Policies-Projects/2030-Comprehensive-Plan
7 City Council, November 13, 2023; Agenda Item #11; SR # 2308-1901,
https://www.cityofpaloalto.org/files/assets/public/v/1/sustainability/reports/cy2023-q3-informational-report-on-
sustianability-and-climate-action-plan-scap.pdf
8 City Council, February 5, 2024; Agenda Item #15; SR # 2312-2348,
https://www.cityofpaloalto.org/files/assets/public/v/1/sustainability/reports/cy2023q4-informational-report-on-
sustainability-and-climate-action-plan-scap.pdf
9 City Council, May 20, 2024; Agenda Item #15: SR #2404-2840,
https://www.cityofpaloalto.org/files/assets/public/v/1/sustainability/reports/cy2024-q1-informational-report-on-
sustainability-and-climate-action-plan-scap.pdf
10 City Council, August 19, 2024; Agenda Item #15; SR #2408-3334,
https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=a254d349-012e-417e-8404-3559d52c5887
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to the City Council with the Q2 S/CAP Implementation Update, typically in August.
ANALYSIS
2e) from the residential, commercial, industrial, transportation, waste, water, and municipal
sectors.11 In comparison to the 1990 base year emissions (which were about 780,000 MT), that
is a 47.4% decrease in total community emissions, despite a population increase of 21.3%
during that same time period. This equates to 6.1 metric tons of carbon dioxide equivalent (MT
CO2e) per Palo Alto resident in 2022 compared to 14 MT CO2e per Palo Alto resident in 1990.
The California Air Resources Board’s 2017 Scoping Plan Update recommends a goal for local
governments of 6 MT C02e per capita by 2030.
12) consumption, 13% from declines in solid waste emissions, and 1.6% percent from
declines in wastewater-related emissions.
Figure 1: 1990 vs 2022 Citywide GHG Emissions by Sector
11 Carbon dioxide equivalent is a unit of measure that normalizes the varying climate warming potencies of all six
GHG emissions, which are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs),
perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). For example, one metric ton of nitrous oxide is 210 metric
tons of CO2e.
12 Methane, which is the primary component of natural gas, is a very potent greenhouse gas, with a global
warming potential that is 25 times higher than CO2 over a 100-year period.
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Off-road Vehicles, Caltrain Commuter Rail, Composting, and Palo Alto Landfill Gas Flaring). The
full 2022 Citywide GHG inventory can be found in Attachment A. The full comparison between
the 1990 and 2022 inventories can be found in Attachment B.
Figure 1: 1990 vs 2022 Citywide GHG Emissions by Sector
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commuter rail) and natural gas (methane) use (including residential, commercial, and
industrial).
Figure 2: 2022 Citywide GHG Emissions by Sector
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gas (methane) GHG emissions.
2e) from municipal operations. As shown in Error! Reference source not found., GHG
emissions from Palo Alto’s municipal operations are from five main sectors: buildings and other
facilities, streetlights and traffic signals, wastewater facilities, city vehicles and equipment, and
indirect emissions. Since the methodology has changed significantly for certain sectors since the
first Municipal GHG Inventory was conducted in 2005, it is no longer possible to do a true
comparison with previous Municipal GHG inventories. However, the methodologies for
buildings and other facilities, streetlights and traffic signals, and city vehicles and equipment are
similar enough to do rough comparisons. For reference only, in 2005 the City emitted a total of
40,499 MT of CO2e from municipal operations. The full Palo Alto Municipal Greenhouse Gas
Inventory for calendar year 2022 can be found in Attachment C.
Table 1: 2022 Palo Alto Municipal GHG Emissions
Sector
2022 GHG
emissions
(MT CO2e)
Percent of
total emissions
Total 15,784 100%
Note: Percentages and MT CO2e may not add to the total due to rounding
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first Municipal GHG Inventory was conducted in 2005, so it is no longer possible to do a true
comparison with previous Municipal GHG inventories. However, the methodologies for
buildings and other facilities, streetlights and traffic signals, and city vehicles and equipment are
similar enough to make rough comparisons.
Figure 3: 2005 vs. 2022 Palo Alto Municipal GHG Emissions
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Figure 3: 2022 Progress Towards Carbon Neutrality
2024 S/CAP Quarterly Progress
The S/CAP Goals and Key Actions are divided into eight areas, four of which are climate-focused
and include actions to achieve the city’s 80 x 30 and carbon neutrality by 2030 goals (Climate
Action, Energy, Electric Vehicles, and Mobility) and four of which are focused on actions that
create a sustainable natural environment and adapting to a warming climate (Water, Climate
Adaptation and Sea Level Rise, Natural Environment, and Zero Waste). The Work Plan is
similarly divided between climate-focused and sustainability-focused priorities.
When the S/CAP was updated, the City modeled the outcomes needed to achieve 80 x 30,
keeping in mind updated climate science and the global impacts of climate change, as well as
the need for increased community awareness. The City’s preliminary analysis achieves 71%
reductions below 1990 levels, leaving a 9% gap to be closed through some combination of
deeper vehicle electrification, increased reduction in vehicle miles traveled (VMT), multi-family
and commercial building electrification, carbon dioxide removal, and funding emissions
reductions outside of Palo Alto. Next year, the City will begin developing the 2026 – 2027 S/CAP
Workplan to determine the priority implementation areas for the next three years as well as
the most cost-effective approaches to achieving the additional emissions reductions needed to
close the 9% gap.
There are 23 Council Priority Objectives in the 2024 Council Priority Area Climate Change and
The Natural Environment: Protection & Adaptation (CC&NE), the status of which can be found
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in the 2024 Council Priority Objectives Q2 Report13 and the 2024 Council Priority Objectives Q3
Report.14 This report addresses 18 of those Council Priority Objectives, as well as 2 in Council
Priority Area Community Health, Safety, Wellness, and Belonging (CHSW&B), as shown in Table
2.
Table 2: Council Priority Objectives Addressed in the S/CAP Quarterly Report
Number Council Priority Objective
Climate Change and the Natural Environment: Protection & Adaptation (CC&NE)
13 City Council, August 19, 2024; Agenda Item #15; SR #2408-3334,
https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=a254d349-012e-417e-8404-3559d52c5887
14 City Council, October 28, 2024; Agenda Item #12; SR #2410-3615,
https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=a66f1ec5-4990-4476-9792-d7cc667885a0
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stringent energy efficiency and all-electric readiness requirements to all new
buildings
CC&NE 28 Initiate the 2026 California Building Standards Code update, including the
California Green Building Standards Code
CC&NE 29
Complete community engagement for the Airport’s Long-Range Facilities &
Sustainability Plan in accordance with Federal requirements and hold a study
session with Council on the draft plan
Climate Change Adaptation: Flood Protection
CC&NE 31 Advocate for the San Francisquito Creek Flood Protection capital project (Reach
2) through Council’s JPA representation and any Council approvals involved
CC&NE 32
Complete design and right-of-way acquisition, obtain regulatory permits,
finalize project funding needs including potential Council advocacy with State
legislators, and approve construction contract for the Newell Road Bridge
Replacement project
CC&NE 33 Coordinate with Federal and regional partners on a path forward exploring the
development of a Sea Level Rise Adaptation Plan
Community Health, Safety, Wellness, and Belonging (CHSW&B)
Invest in Reliable Safety Infrastructure and Systems
CHSW&B 70 Approve updated Local Hazard Mitigation Plan and Community Wildfire
Protection Plan
CHSW&B 71 Update Foothills Fire Management Plan
Climate Action
Covering the S/CAP Areas of Climate Action, Energy, Electric Vehicles, and Mobility, this section
reports on progress based on the Work Plan Climate Action Priority areas. This includes five
priorities with various work items under each priority. This report notes where these work
items have been designated as Council priority objectives.
P1. Grid Modernization
P2. Launch Programs
P2.1 Residential Emissions Reduction
P2.2 Non-Residential Emissions Reduction
P2.3 Citywide Mobility
P2.4 Municipal Electrification
P2.5 EV Strategic Plan
P3. Build Awareness and Confidence
P4. Additional Emissions Reductions
P5. Funding Needs and Sources
Separately from the work plan updates, there are two 2024 S/CAP-related Council priority
objectives that did not appear in the Work Plan. The first (CC&NE 27) was to adopt local
amendments to the State’s Energy Code to replace all-electric new construction requirements
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which had been placed under an enforcement moratorium in February 2024.15 On June 3, 2024,
the City Council adopted an ordinance implementing local amendments implementing a One
Margin16 approach to regulating heating and cooling in buildings.17 The City Council reviewed
the Second Reading of the Ordinance on June 17, 2024.18 As required by State law, the
ordinance was sent to the California Energy Commission for review and approval and was
approved September 11, 2024. The ordinance became effective October 4, 2024. The City
provided outreach via email newsletters to the general public, architects, contractors, and
businesses, including some specific outreach to restaurants. The City also held a Q&A session
on September 20, 2024 focused on architects and contractors.
P1. Grid Modernization
Grid Modernization (Work Plan Item 1A, Council Priority Objective CC&NE 16): The City is
upgrading its electric distribution system to enhance reliability and resiliency, modernize the
system, and increase capacity to accommodate widespread electrification. As of September
2024, the first Pilot area is under construction. The City is focused on and working with pole,
transformer, and overhead cable suppliers to secure the necessary parts to complete the first
part of the project. To date, 61 of 74 (82%) poles have been replaced, and a significant amount
of the tree trimming work has been completed. Additionally, 675 of 1,290 (52%) residences in
the Pilot Area now have sufficient transformer capacity for electrification, and the Pilot Area is
on track to be completed by February 2025.
15 City Council, February 26, 2024; Agenda Item #14; SR #2402-2644,
https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=8ac11983-10ba-4a79-a823-3693203c22d7
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A “One Margin” reach code applies additional efficiency requirements to all new buildings, but takes into account
energy use at the source, which favors the additional efficiency and lower emissions of all-electric equipment using
carbon neutral electricity. It uses standard energy modeling practices to set its requirements rather than novel
approaches like local air-quality standards. It does not discriminate between gas and electric appliances like an
“Electric-preferred” code.
17 City Council, June 3, 2024; Agenda Item #17; SR #2405-3073,
https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=5be827a8-943c-4221-a389-e0452ebeaff4
18 City Council, June 17, 2024; Agenda Item #23; SR #2406-3125,
https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=3fd2a8c6-b814-4ac7-a569-934573550972
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Reliability and Resiliency Strategic Plan (Work Plan Items 1B, 1C, Council Priority Objective
CC&NE 23): In April 2024, the City Council accepted the Reliability and Resiliency Strategic Plan
(RRSP).19 A status report on implementation was included in a report to the Utilities Advisory
Commission on September 4, 2024.20 Council approved a contract on September 23, 2024 for a
consultant to assist with some aspects of implementation, particularly RRSP Strategies 3, 4, and
5 focused on cost-benefit analysis and program development. The City is also working on a
partnership with SLAC National Accelerator Laboratory to complete a distribution analysis
(RRSP Strategy 4, Action 2).
Utility Rates and Fees (Work Plan Item 1D): The Utilities Department is on track to complete its
AMI project by March of 2024, with time of use rates planned to become available on an
optional basis in July 2024. The City is pursuing a study to modify its transformer upgrade fees
to avoid situations where the resident who triggers a transformer upgrade pays the entire cost
of that upgrade. The study is partially completed but has been delayed due to staff turnover.
P2. Launch Programs
P2.1. Residential Emissions Reduction
Advanced Heat Pump Water Heater Pilot (Work Plan Items 2.1D, 2.1E, Council Priority Objective
CC&NE 18): The City launched the Advanced Heat Pump Water Heater (HPWH) Pilot Program in
March 2023. The pilot’s goal is 1,000 heat pump water heater installations. It includes both a
full service option (where residents can use the City’s prescreened contractor to complete the
install at a discount) and a rebate option (where residents can hire their own contractor and
receive a rebate), with a new emergency replacement option launched in September 2024. As
of September 19, 2024, 447 residents had either completed installations or signed contracts to
get a heat pump water heater installed through the City’s programs, with 84 of these projects
applying for on-bill financing. With the current pace of new HPWH program signups, the City is
on a pace to complete around 250 water heater conversions per year through the Advanced
HPWH Pilot Program, equivalent to about 20 percent of the water heaters estimated to be
replaced each year. In addition, the City and State Energy Reach Codes encourage new
construction and major renovations to be built all-electric, which adds to this total.
19 City Council, April 15, 2024; Agenda Item #4; SR #2401-2496,
https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=ada33d0c-c1a6-490c-8978-4107b43e6ab5
20 Utilities Advisory Commission, September 4, 2024, Agenda Item 4, Attachment B,
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=13500
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The City is working on various efforts to increase signups for the Advanced HPWH Pilot
Program. In January, the City did a comprehensive review of the program and made various
changes to improve customer experience. The City also expanded outreach to income-qualified
residents, and 17 have participated to-date. In April, the City Council approved a request to
increase the budget for the HPHW pilot program in order to increase participation with higher
rebates.21 In addition, the City launched an Emergency Water Heater Replacement Pilot
Program on September 10, 2024; this program is designed to install a heat pump water heater
within 48 hours and will serve the needs of customers that cannot be met by the current full
service program option. In the FY 2025 budget, Council approved temporary hourly staff to help
with outreach, allowing the City to expand program outreach, which has resulted in increased
signups.
Whole Home Electrification (Work Plan Items 2.1G, 2.1H, Council Priority Objective CC&NE 19):
The City is working with the Climate Protection Ad Hoc Committee and Working Group to
design a comprehensive whole home electrification program by the end of 2024. The program
is expected to launch in two phases. In the first phase, tentatively expected by the end of the
year, the City will launch a program to help people hire their own contractor to do home
electrification projects. The first phase will include a phone number to call for guidance,
incentives, contractor lists, financing, and it may also include some level of technical assistance.
In a second phase scheduled for next summer, the City would develop a full service, turnkey
program to help people who do not want to hire their own contractor with an option for
customers to use a City-prescreened contractor or choose their own contractor. An initial
Whole Home Pilot for 100 homes could have various incentives for electrifying at least one
major appliance. More details on planned incentives can be found in Attachment F. Spending
authority for Phase 1 is included in the Adopted FY 2025 Budget, but additional Council
approvals will likely be needed for Phase 2.
Electric Vehicles and Charging (Work Plan Items 2.1A, 2.1C, 2.1J): The City’s promotion of
electric vehicle (EV) adoption and expansion of multi-family EV infrastructure continued. In Q2
2024, the City held a total of four EV expos, four EV workshops, and two EV discount
campaigns, including the first EV discount campaign to focus on the purchase of used electric
vehicles. In Q3 2024, the City offered an additional two EV expos, three EV workshops, and two
EV discount campaigns. Significant EV expo events included the Stanford Healthcare EV
Showcase in Q2 and the Municipal Services Center Open House in Q3. In Q3, the City also held
the first ever mini EV expo onsite at a recently completed multifamily EV charging installation at
345 Sheridan with the goal of engaging tenants of that property on the benefits of EV
ownership. CPAU anticipates offering additional Discount Campaigns in Q4 for both e-bikes and
pre-owned EVs.
21 City Council, April 15, 2024; Agenda Item #6; SR #2403-2724,
https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=d465d2c6-7ab6-4797-928d-a3c4bda992f0
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make-ready spaces) facilitated through the City's EV programs, with another 12 multi-family
projects in progress representing an additional 781 residential units (7.1% of multifamily units)
and 241 charging ports. Recently completed multifamily projects (Q3 2024) include a 101-unit
condominium property at 101 Alma that installed 97 L2 chargers serving every assigned parking
space, two adjacent Stanford faculty condominium properties with 56 units each at 2500 and
2600 Columbia that together installed 20 L2 chargers and 48 EV-ready parking spaces across the
properties, and an 83-unit apartment complex at 345 Sheridan that installed 10 L2 chargers.
The City is evaluating designs for an expanded version of the City’s multi-family EV program,
and is also considering adding incentives for the purchase of e-bikes and new or used EVs
specifically for income-qualified households.
Affordable Housing Electrification (Work Plan Item 2.1I): The City continues to engage with
multi-family affordable housing providers in Palo Alto on building electrification and vehicle
charging. To-date, the City has collaborated with multiple affordable housing providers on
potential EV charging projects and is engaging in conversations and site assessments regarding
facility energy upgrade needs and electrification opportunities. There are currently 3 affordable
properties with EV charging installations expected to be completed by the end of Q4 2024 or
early in Q1 2025, which will result in 52 new EV chargers and 24 EV ready parking spaces
serving 281 residential units.
P2.2. Non-Residential Emissions Reduction
Rooftop Packaged HVAC (Work Plan Items 2.2A, 2.2B, Council Priority Objective CC&NE 20): In
September, the City launched an update to the rooftop packaged HVAC pilot with a goal of
collecting more data to support the design of an advanced pilot program. The City is providing
significantly enhanced incentives to a limited number of customers (10), and in exchange these
customers must gather additional cost information and other information as they do their
projects that they must provide to the City. Businesses who do not wish to gather this
information can still access the program at the original incentive level. Outreach is proceeding
through various channels to spur participation, and the City has already seen some early
interest from several building owners.22
22 Program rebate amounts and guidelines can be found at http://www.cityofpaloalto.org/commercialhvac
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Major Employer Partnerships (Work Plan Item 2.2C): This work plan item involves developing
customer partnerships for emissions reduction with major employers, including assistance for
City facility projects and the Palo Alto Unified School District (PAUSD). Staffing changes slowed
progress on this item. The City has been in talks with multiple major employers and completed
a project to install EV charging in partnership with Stanford Health Care. The City coordinated
with PAUSD on its HVAC improvements to various schools and the City is exploring potential
City facility electrification projects.
As of September 13, 2024, the Commercial and Industrial Energy Efficiency Program (CIEEP)
completed two major energy efficiency projects with projected energy savings of 261,355 kWh.
Ten projects are currently being installed, with a projected savings of 1,155,996 kWh. Eight
projects are currently conducting onsite assessments which will generate an “Initial
Investigation” report. This reporting will list and quantify potential energy-efficiency findings
and measures. In total, the CIEEP program has 2,469,096 kWh actualized and projected savings
derived from thirteen projects, with an additional eight projects in the pipeline that will drive
further electric savings.
Commuter / Visitor Emissions Reduction (Work Plan Items 2.2D, 2.2E): These work plan items
have been lower priority pending completion of the Electric Vehicle Strategic Plan (renamed
“E-Mobility Strategic Plan” - see Priority 2.5, below).
P2.3. Citywide Mobility
The goals for citywide mobility embodied in the Work Plan include both transportation-focused
and land-use focused actions.
Transportation and Land Use Policies and Programs (Work Plan Item 2.3A): The Safe Routes to
School (SRTS) program continues to grow, with the anticipated addition of a youth-focused
coordinator for programs at the middle and high schools. This year is the 30th anniversary of
the SRTS program, and a celebration is being planned for Bike Month in May of 2025.
The Downtown Housing Plan began in March 2024 with the goal of increasing housing
production while ensuring that the downtown area continues to be an attractive local and
regional destination. The Plan will help implement programs of the Housing Element by
establishing policies and development standards, and plan for the public infrastructure
necessary to support increased housing. The project is in the needs assessment phase which
includes stakeholder engagement. A Community Advisory Group is being formed and the first
community workshop is scheduled for October 10, 2024.
The San Antonio Road Area Plan envisions creating cohesive mixed-use neighborhoods with
improved mobility and interconnectivity through an integrated transportation network that
reduces greenhouse gas emissions and the use of single-occupancy motor vehicles. The Plan
will implement a program in the Housing Element to redevelop a portion of the Bayshore Alma
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San Antonio Priority Development Area (BASA PDA). An RFP was issued in June 2024 for a
consultant to develop the Plan and consultant selection is anticipated near the end of 2024.
Housing Element Adoption and Implementation (Work Plan Items 2.3B, 2.3C): In a joint session
on April 15, 2024, the Planning & Transportation Commission and the City Council readopted
the sixth cycle 2023-2031 Housing Element. On August 20, 2024, the City accomplished the
milestone of receiving Department of Housing and Community Development (HCD) certification
of the Housing Element.23
Last Mile Solutions (Work Plan Items 2.3D, 2.3E and Council Priority Objective CC&NE 25):
During the Budget Adoption process, the City Council reduced its General Fund allocation to the
Palo Alto Link on-demand transit service pilot program and directed staff to make fare and
coverage changes to the service. These will go to Council for adoption in October 2024.
Bicycling Improvements (Work Plan Items 2.3F, 2.3G and Council Priority Objectives CC&NE 14
and CC&NE 15): On April 29, 2024, the City Council received an informational report on collision
data analysis as part of the ongoing development of the Safe Streets for All (SS4A)
comprehensive roadway safety plan.24 The development of the Palo Alto Safety Action Plan is
critical to reaching S/CAP goals because improving safety for vulnerable road users is key to
reducing vehicle miles traveled (VMT) and increasing sustainable travel. The City provided
information on the Safety Action Plan development at the Palo Alto Earth Day Festival on April
21 and the May Fete Fair on May 4. These events provided an opportunity to engage with
community members before preparing the Draft Safety Action Plan. The City is working with
transportation planning firm Fehr & Peers to finalize the draft plan for review at standing
committees and Council in late 2024, with final plan adoption by City Council in early 2025.
25 The feedback gathered will inform the project team's understanding of
23 City of Palo Alto, 6th Cycle 2023-2030 Housing Element, Adopted April 15, 2024, Certified August 20, 2024,
https://paloaltohousingelement.com/wp-content/uploads/2024/08/Palo-Alto-Housing-Element.pdf
24 City Council, April 29, 2024; Agenda Item #3; SR #2404-2839,
https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=79d7c1d2-b1a1-4eb9-acca-039fab914f74
25 City Council, April 29, 2024; Agenda Item #1; SR #2402-2619,
https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=fcfab491-1dae-4afd-a309-be952790121e
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community needs. In the summer, the City began to identify and prioritize policy,
infrastructure, and programmatic recommendations.
Transportation Demand Management (Work Plan Item 2.3H): In May, the City Council received
the Palo Alto Transportation Management Association (TMA) 2023 Annual Report, Strategic
Plan, and Commute Survey.26 The TMA has been conducting essential outreach to businesses
on El Camino Real regarding available transit, bike, and parking programs in advance of the
parking changes to the corridor as part of the Caltrans repaving project. Work on the City’s TDM
Ordinance is on hold until staff capacity is available.
Parking (Work Plan Items 2.3I, 2.3J, Council Priority Objective CC&NE 26): The City initiated a
survey that closed in August to gauge customer satisfaction and support future updates to
parking policies. The City is planning to continue community engagement efforts through the
fall of 2024. The City will select a parking permit vendor by November 2024 and work with the
selected vendor to present options for improvements. Public Works contractors have begun
work on installing Automated Parking Guidance Systems in four Downtown garages. The
systems, similar to the one installed at the 350 Sherman Avenue garage in the California
Avenue district, will display parking availability by level, enabling better efficiency of parking
resources. Improvements will seek to limit the time that drivers spend circulating to find
parking and will offer opportunities to better align parking policies with TDM efforts and more
efficient usage of parking resources.
Traffic Signals (Work Plan Item 2.3K):
26 City Council, May 20; Agenda Item # 14; SR #2404-2932,
https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=98ec6492-339a-4dcf-ac76-73a95f11285e
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In 2024, the City completed upgrades to three intersections along Charleston Road and
implementation of a new traffic signal at Charleston Road and Louis/Montrose Road. The City
also received funding and began a new capital project to upgrade systems at four intersections
along Quarry Road. The City is also working on several projects including at the intersections of
Alma Road/Churchill Avenue, Charleston Road/San Antonio Road, and several updates at
intersections within school zones. Included with the above and future projects will be
implementation of automated traffic signal performance measure systems (ATSPM) to help
optimize operations. The City is also currently working on a needed update of its centralized
traffic signal management system.
Facility Electrification (Work Plan Items 2.4A, 2.4B, 2.4C): In 2023, the City worked on a Facility
Electrification Assessment Plan. The City is evaluating the feasibility of electrifying equipment at
City Facilities each time aging equipment requires replacement. This was put to the test in
December 2023 when the City installed a new heat pump water heater in Palo Alto City Hall
that runs on 100% clean electricity. Completion of an Electrification Plan for City Facilities has
been delayed while a vacant staff position dedicated to this effort is filled.
Fleet Electrification (Work Plan Items 2.4D, 2.4E and Council Priority Objective CC&NE 22): In Q2
2024, the City received delivery of 4 new Chevy Bolt Electric Vehicles, which replaced internal
combustion engine fleet vehicles. There are 32 EVs in the City fleet, or about 15% of the
passenger vehicles and light duty trucks and vans. Six new EV chargers dedicated to the City
fleet vehicles were placed in service at City Hall in Q3 2024.
Publicly Owned Charger Planning (Work Plan Item 2.4F): There are currently 99 City-owned EV
chargers, with a total of 131 charging ports. 10 of those chargers are dedicated to City vehicles,
while the rest are primarily for public use. Six additional Fleet chargers were placed in service in
Q3 2024.
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plan scope and some early design decisions about the plan and analysis at public Ad Hoc
Climate Protection Committee Working Group meetings in March and June and in September
received feedback on a list of strategies for e-mobility development and its supporting
infrastructure to include in the plan. The City anticipates completing a draft of this study before
the end of the year and reviewing it with the Ad Hoc Climate Protection Committee.
P3. Build Awareness and Confidence
Building Awareness of the Need for and Benefits of Climate Action (Work Plan Item 3.1A): The
City continues to publish a monthly Climate Action Blog and a Quarterly Sustainability
Newsletter. In Q2 2024, the City published an April27 and May28 Climate Action Blog; and an
April29 and May30 Sustainability Newsletter. In Q3 2024, the City published an August31 Climate
Action Blog and a September Newsletter32. The Sustainability Newsletters had a 52% open rate,
which is the percentage of readers that open the e-mail you send them. The average open rate
for electronic newsletters is 21.5%.
27 Climate Action Blog, April 2024; https://medium.com/paloaltoconnect/every-action-counts-this-earth-month-
5a4baee866fa
28 Climate Action Blog, May 2024; https://medium.com/paloaltoconnect/bike-for-the-planet-a2d22af2552d
29 Sustainability Newsletter, April 2024; https://myemail-api.constantcontact.com/Sustainability-Newsletter-April-
2024.html?soid=1138677832922&aid=dasQTHT5gLw
30 Sustainability Newsletter, May 2024; https://myemail.constantcontact.com/Sustainability-Newsletter-May-
2024.html?soid=1138677832922&aid=4A-lPazzpto
31 Climate Action Blog, August 2024; https://medium.com/paloaltoconnect/climate-action-series-fall-in-love-with-
sustainability-bcfd70d80ae6
32 Sustainability Newsletter, September 2024; https://conta.cc/4gD60u9
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Earth Day Event, Downtown Palo Alto Farmer’s Market, HP Sustainability Fair, SAP Sustainability
Fair, and Third Thursday on California Avenue.
33, which the City is cosponsoring. The Electric Home tour is scheduled for October 19 and
will highlight a variety of electrified homes across the Peninsula and South Bay. Attendees will
have the opportunity to explore the latest in home electrification, including heat pump water
heaters, heat pumps for both heating and cooling, induction cooktops, electric dryers,
fireplaces, and electric gardening tools. Homeowners will also share their experiences on
selecting appliances, working with contractors, navigating installation, and enjoying cost-saving
benefits.
34 held three Working Group meetings to
discuss the Building Sector Study, the Multi-Family EV Program, the Whole Home Electrification
Program, the Commercial HVAC Program, the Reliability and Resiliency Strategic Plan, the EV
Strategic Plan, the S/CAP Funding Study, and to provide updates on the HPWH Pilot Program. In
Q3 2024, the Climate Protection Ad Hoc Committee held one Working Group Meeting to
discuss the E-Mobility Strategic Plan and provide a brief update on the Whole Home
Electrification Program.
Drive Community Actions to Achieve S/CAP Goals (Work Plan Item 3.1B): The City continued to
implement the Electrification Marketing Plan and the Heat Pump Water Heater Marketing Plan.
The City provided information on sustainability and climate action programs and initiatives for
residents and businesses at the Palo Alto Caltrain Electric Service Launch Party and at the Clean
Air at Home in Palo Alto Event.
S/CAP Reporting and Surveys (Work Plan Items 3.1C, 3.1D): The City continues to calculate an
annual GHG emissions inventory. As previously discussed, for 2022 the City calculated both a
33 Acterra Electric Home Tour, October 2024; https://acterra.org/electrification/greenhome/electric-home-tour/
34 Climate Protection Ad Hoc Committee; https://www.cityofpaloalto.org/Departments/City-Clerk/City-Council-
Committees/Climate-Protection-Ad-Hoc-Committee
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Citywide and Municipal Inventory. The 2022 GHG Inventories can be found in Attachments A, B,
and C of this staff report. This October, the 2022 Citywide GHG Inventory will be reported to
the CDP, an international non-profit that helps companies, cities, states, regions, and public
authorities disclose their environmental impact.
35 did not include a question to directly measure
community awareness, however the 2024 Survey does.
Build Confidence in City’s Electric Infrastructure (Work Plan Item 3.1E): The City continues to
provide updates and engagement around its electric infrastructure.
P4. Additional Emissions Reductions
P5. Funding Needs and Sources (Council Priority Objective CC&NE 24)
Maximize Water Conservation and Efficiency (Work Plan Item 8.A): The near-term focus for
35 City of Palo Alto Community Survey 2023; https://www.cityofpaloalto.org/files/assets/public/v/1/city-
manager/communications-office/general/attachment-a-palo-alto-community-survey-2023-report-of-results.pdf
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water is reducing water consumption while exploring ways to capture and store water and
increase the availability and use of recycled water. The WaterSmart customer portal, an online
water management tool, launched in November 2022. Through this program, home water
reports are sent to around 11,000 single-family customers on a monthly basis. A control group
of around 4,000 single-family customers currently do not get the reports. The average open
rate of home water report emails is 74%. As of August 6, 2024, 24% of all single-family
customers have accessed the portal which provides information about their water consumption
and personalized water conservation recommendations. Preliminary results from the efficiency
study show that sending home water reports results in water-savings of 2.1%.
Design and build a salt removal facility for the Regional Water Quality Control Plant (Work Plan
Item 8.B): The City continues work on the Advanced Water Purification System, which will
reduce the salinity of treated water used for irrigation. In May, the City Council reviewed Site
and Design application for a proposed local advanced water purification system.36 The design is
complete, funding is secured, and staff anticipates Council approving a construction contract in
Spring 2025.
Develop a “One Water” Portfolio for Palo Alto (Work Plan Item 8.C): The City is continuing
development of a “One Water” Plan for Palo Alto, with input from community stakeholders and
the Utilities Advisory Commission. The proposed One Water Plan, which will be a 20-year
adaptable roadmap for implementing water supply and conservation portfolio alternatives,
includes stormwater, recycled water, on-site reuse, conservation, and groundwater.
Develop a tool for dynamic water planning in the future (Work Plan Item 8.D): The City will
develop an excel-based tool for water planning as part of the “One Water” Plan development.
Complete the Sea Level Rise Vulnerability Assessment (Work Plan Item 8.E): The City completed
a Sea Level Rise Vulnerability Assessment in the Fall of 2022. The Vulnerability Assessment
identified risks and hazards to the Palo Alto Baylands, City infrastructure, and residential and
business property. The Assessment considers high tide, 100-year coastal storm event scenarios,
and rising shallow groundwater impacts.
Develop a Sea Level Rise Adaptation Plan (Work Plan Item 8.F and Council Priority Objective
CC&NE 33): The City will coordinate the development of its Sea Level Rise Adaptation Plan to
align with SB272 (Laird): Sea Level Rise Planning and Adaptation requirements and other
regional planning efforts.
36 City Council, May 13; Agenda Item #11; SR #2403-2760,
https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=5f812cd5-ab33-4e51-851a-1b01fde39467
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Despite longer-term regional planning horizons for sea level rise, the City is working on several
near-term goals. These efforts include publishing web-based GIS maps which depict future sea
level rise and shallow groundwater changes for use in City project planning, and inclusion of sea
level rise in long range planning for the Regional Water Quality Control Plant and Palo Alto
Airport.
Begin design process for levee projects (Work Plan Item 8.G): The City continues to advance the
Palo Alto Horizontal Levee Pilot Project (PAHLPP). The PAHLPP will be the first horizontal levee
to be built in the Bay Area to be both irrigated with treated wastewater and hydrologically
connected to San Francisco Bay and will provide much-needed data to inform the design of
future horizontal levees around the greater San Francisco Bay Area. Horizontal levees are
nature-based sea level rise adaptation options with multiple benefits over traditional flood-
control levees such as habitat enhancement, sea level rise adaptation, and
additional wastewater treatment.
A United States Army Corps of Engineers (USACE) cost/benefit analysis determined that there is
no federal interest in funding Palo Alto shoreline improvements at this time, and that
improvements would not be needed until approximately 2060. Valley Water and Shoreline II
partners (CalTrans and the cities of Palo Alto and Mountain View) are developing an agency
factsheet, and other reference materials for public information, and will reconvene after SB272
(Laird): Sea Level Rise Planning and Adaptation requirements are known to identify possible
next steps for coordinating and funding levee improvements.
Identify Protection Strategies from Significant Flood Events (Work Plan Items 8.H, 8.I, 8.J, and
Council Priority Objectives CC&NE 31 and 32): The City continues to work with the San
Francisquito Creek Joint Powers Authority (SFCJPA) member agencies to coordinate the San
Francisquito Creek Flood Protection capital project (Reach 2) with the Newell Road Bridge
replacement project.
Local Hazard Mitigation Plan (Council Priority Objective CHSW&B 70): The federal Disaster
Mitigation Act of 2000 requires all cities, counties, and special districts to adopt a Local Hazard
Mitigation Plan (LHMP) to receive disaster mitigation funding from the Federal Emergency
Management Agency (FEMA). The State of California and FEMA approved the Santa Clara
County Multi-Jurisdictional Hazard Mitigation Plan (MJHMP), Volume I and the associated
Jurisdictional Annexes, Volume II. Staff will seek a City Council resolution to adopt Volume I and
The Palo Alto Annex to Volume II.
Foothills Fire Management Plan and Collaboration on Reducing Wildfire Hazards (Work Plan
Items 8.K, 8.L, 8.M, 8.N, Council Priority Objective CHSW&B 71): The effort to combine the Palo
Alto Foothills Fire Management Plan and Community Wildfire Protection Plan (CWPP) into one
document to integrate the wildfire mitigation efforts among the Palo Alto community is
underway. The updated plan is scheduled to be completed in Q4 2024.
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Increase Palo Alto’s Tree Canopy and Ensure No Net Tree Canopy Loss (Work Plan Items 8.O,
8.P): The City will use the iTree inventory to calculate a baseline and citywide public tree
inventory update. The current baseline, which needs to be updated, is 5,236,420 lbs CO2
sequestered for 35,570 calculated public trees. The inventory data points used to calculate the
current baseline (e.g. tree species) may be outdated (e.g. trees are larger than the data shows,
trees were replaced or removed without updating the data). An effort to establish a baseline
for carbon storage of Palo Alto’s urban tree canopy is on-track to be completed in 2024.
37
Reduce Pesticide Use in Parks and Open Space Preserves (Work Plan Item 8.Q): The City
continues to review the use of pesticides in all parks and open space preserves to identify
opportunities to further reduce both the amount and the toxicity of pesticides that are used.
Coordinate Implementation of City Natural Environment-Related Plans (Work Plan Item 8.R):
The City is working on an update of the Tree and Landscape Technical Manual. In addition, the
Model Water Efficient Landscape Ordinance process is currently under review and should be
completed soon.
Support the Green Stormwater Infrastructure (GSI) Plan and incorporate GSI in Municipal
Projects (Work Plan Item 8.S): This is an on-going effort to achieve a 10% increase in land area
that uses green stormwater infrastructure to treat urban water runoff.
Encourage Commercial Food Waste Prevention and Provide Technical Assistance (Work Plan
Items 8.T, 8.W): This is an on-going effort to encourage food waste prevention and require
edible food recovery for human consumption from commercial food generators, and develop
an outreach tool and technical assistance to the commercial sector.
Promote Residential Food Waste Reduction (Work Plan Item 8.U): The City continues to
promote food waste reduction.
Champion Waste Prevention, Reduction, Reusables, and the Sharing Economy (Work Plan Item
8.V): In June, the City Council approved a memorandum of understanding for the ongoing
management and operation of a countywide edible food recovery program and sharing of
program costs with the cities of Campbell, Cupertino, Gilroy, Los Altos, Milpitas, Monte Sereno,
37 City Council, April 1, 2024; Agenda Item #10; SR #2403-2809,
https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=132d1d26-0e8c-49c2-8773-ff6e0c9dc1f3
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Morgan Hill, Mountainview, San Jose, Santa Clara, Sunnyvale, and Saratoga.38
As part of the new Zero Waste Living outreach campaign, the City published nine Zero Waste
Minute e-newsletters in Q2 2024.
In Q2 2024, the City held two compost workshops for residents to learn how easy it is to make
their own compost. Palo Alto residents receive a free compost bin or worm bin (one per
household) by attending a compost workshop. The City also continued the permanent Compost
Giveaway Station where residents can pick up compost for their homes and landscape at no
charge, and free mulch from tree removal operations is also available at centralized stations
throughout the City.
Prioritize Domestic Processing of Recyclable Materials (Work Plan Item 8.X): Domestic
processing for mixed paper and mixed rigid plastics began in April 2022. The City continues to
review processing efforts.
Eliminate Single-Use Disposable Containers (Work Plan Item 8.Y): The strategy and timeline for
expanding the Disposable Foodware Ordinance is on hold until further clarification is received
through SB 54 final regulations and changes on what will be considered recyclable and
compostable.
Expand the Deconstruction and Construction Materials Management Ordinance (Work Plan
Item 8.Z): In May, the City Council received an update on the Deconstruction and Construction
Material Management Ordinance, which requires all residential and commercial projects
undergoing a whole structure demolition to obtain a deconstruction permit.39 Deconstruction is
the careful disassembly of building components to maximize reuse and recycling.
Implement the Reach Code Standard for Low Carbon Construction Materials (Work Plan Item
8.aa): The City Council approved a reach code standard for low carbon construction materials
in October 2022. The Reach Code went into effect on January 1, 2023.
FISCAL/RESOURCE IMPACT
Current and future initiatives will be managed and funded across various departments and
funds. The Fiscal Year 2025 work items in the 2023-2025 S/CAP Work Plan can proceed with the
actions approved in the Fiscal Year 2025 Adopted Budget. Staff expects to submit additional
resource requests as part of the annual budget process in subsequent years as the work plan
proceeds.
Some items in other work plans are also relevant to the S/CAP Work Plan. The Utilities Strategic
38 City Council, June 18, 2024; Agenda Item #8; SR #2404-2911,
https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=c58305ed-d1d6-42ce-b37a-eca067b2bb09
39 City Council, May 6, 2024; Agenda Item #18; SR #2312-2377,
https://cityofpaloalto.primegov.com/Portal/viewer?id=0&type=7&uid=da6cfa4a-5637-44bd-a7bc-92763615dbc1
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Plan, for example, includes workforce development and advanced metering infrastructure
(AMI) work items that are directly relevant to the S/CAP. Some of these may involve future
budget requests as well.
STAKEHOLDER ENGAGEMENT
ENVIRONMENTAL REVIEW
ATTACHMENTS
APPROVED BY:
Page 1 of 13
Attachment A: Palo Alto 2022 Citywide Greenhouse Gas Emissions Inventory
1.a. Overview of Methodology for Quantifying Greenhouse Gas Emissions
Cities represent the single greatest opportunity for tackling climate change, as they are
responsible for 70 percent of global energy-related carbon dioxide emissions, with
transportation and buildings among the largest contributors.1 The first step for cities to realize
their potential is to identify and measure the sources of their emissions. Best practices for
identifying these sources and quantifying emissions are to utilize a standardized GHG inventory.
There are two types of Greenhouse Gas (GHG) emissions inventories:
1.Generation-based GHG inventory – This measurement method helps a community
understand its level of emissions based on community energy use. It includes 1) direct
consumption of energy, 2) consumption of energy via the electrical grid, and 3)
emissions from the treatment/decomposition of waste. This is the industry-accepted
methodology for quantifying community GHG emissions, with emissions reported by
emission source category.2
2.Consumption-based GHG inventory – This measurement method helps a community
understand its level of emissions based on consumption. It offers an alternative, more
holistic, approach for quantifying emissions within a community, quantifying
consumption of goods and services (including food, clothing, electronic equipment, etc.)
by residents of a city, with emissions reported by consumption category.
In 2014, World Resources Institute, C40 Cities Climate Leadership Group (C40) and ICLEI – Local
Governments for Sustainability (ICLEI)3 partnered to create a global standard protocol for
generation-based GHG inventories. The Global Protocol for Community-Scale GHG Emissions
Inventories (GPC) provides a robust framework for accounting and reporting city-wide GHG
emissions for a generation-based inventory. The GPC Protocol is the official protocol specified
by the Global Covenant of Mayors and defines what emissions must be reported and how. In
addition, this inventory draws on methods from the U.S. Community Protocol,4 which provides
more detailed methodology specific to the U.S. It seeks to:
•Help cities develop a comprehensive GHG inventory to support climate action planning
•Help cities establish a base year emissions inventory, set reduction targets, and track
their performance
•Ensure consistent and transparent measurement and reporting of GHG emissions
between cities, following internationally recognized GHG accounting and reporting
principles
1 See UN Environment Programme, ”Cities and Climate Change,” https://www.unep.org/explore-topics/resource-
efficiency/what-we-do/cities/cities-and-climate-change
2 There are two reporting frameworks commonly used by cities: the U.S. Community Protocol and the Global
Protocol for Communities (GPC). Palo Alto uses the GPC framework.
3 Formerly the International Council for Local Environmental Initiatives, renamed in 2003 to ICLEI – Local
Governments for Sustainability.
4 U.S. Community Protocol; https://icleiusa.org/us-community-protocol/
Page 2 of 13
•Enable city inventories to be aggregated at subnational and national levels
•Demonstrate the important role that cities play in tackling climate change, and facilitate
insight through benchmarking – and aggregation – of comparable data
Palo Alto’s first generation-based citywide inventory was completed for 2005 and then
extrapolated for 1990 (the baseline year). Beginning in 2010, new citywide GHG inventories
were completed annually, enabling Palo Alto to track progress over time.
The 2022 Palo Alto Citywide GHG inventory, completed by Rincon Consultants, follows the
calculation and reporting standards outlined in the GPC BASIC reporting level.5 Inventory
calculations were performed using Rincon’s GHG Inventory tool and uploaded into ClearPath,6 a
software platform designed for creating generation-based GHG inventories.
GHG emissions from community activities are classified into three main sectors:
•Stationary Energy (e.g., building electricity consumption, fugitive natural gas emissions)
•Transportation (e.g., on-road passenger vehicles, off-road equipment)
•Waste (e.g., solid waste disposal, wastewater treatment and discharge)
Activities taking place within a city can generate GHG emissions that occur inside the city
boundary as well as outside the city boundary. To distinguish among them, the GPC groups
emissions into three categories based on where they occur:
•Scope 1: GHG emissions from sources located within the city boundary, such as
stationary fuel consumption.
•Scope 2: GHG emissions occurring due to the use of grid-supplied electricity, heat,
steam, and/or cooling within the city boundary.
•Scope 3: All other GHG emissions that occur outside the city boundary as a result of
activities taking place within the city boundary.
This inventory follows the city-inducted framework in the GPC protocol, which totals GHG
emissions attributable to activities taking place within the geographic boundary of the city.7
Under the Basic reporting level as defined by the GPC protocol, the inventory requirements
cover scope 1 and scope 2 emissions from stationary energy and transportation, as well as all
emissions resulting from waste generating within the city boundary. While the 2022 Inventory
follows GPC BASIC reporting standards and aligns with previous GHG emissions inventories,
minor updates to calculation methodologies were included in the 2022 Inventory and are
discussed in detail below.
Staff did not complete a consumption-based GHG inventory. The California Air Resources Board
(CARB) has been tasked with developing an implementation framework and accounting to track
5 GPC Executive Summary; https://ghgprotocol.org/sites/default/files/2022-12/GPC_Executive_Summary_1.pdf
6 ClearPath tool; https://icleiusa.org/clearpath/
7 GPC Protocol; https://ghgprotocol.org/sites/default/files/standards/GHGP_GPC_0.pdf
Page 3 of 13
consumption-based emissions over time.8 In particular, this framework needs to address how
to account for the embodied emissions in the food, goods, and services the community
purchases not covered by generation-based GHG inventories.
1.b. Palo Alto’s 2022 GHG Emissions
2e) from the residential, commercial, industrial, transportation, waste, water, and municipal
sectors.9 In comparison to the 1990 base year emissions (which were about 780,000 metric
tons), that is a 47.4 percent decrease in total community emissions, despite a population
increase of 21.3 percent during that same time period. This equates to 6.1 metric tons of
carbon dioxide equivalent (MT CO2e) per Palo Alto resident in 2022 compared to 14 MT CO2e
per Palo Alto resident in 1990. The California Air Resources Board’s 2017 Scoping Plan Update
recommends a goal for local governments of 6 MT C02e per capita by 2030.
10) consumption, 13 percent from declines in
solid waste emissions, and 1.6 percent from declines in wastewater-related emissions. In
comparison to 2021, that is a 14.2 percent increase in total community emissions.
8 Executive Department State of California. (2019). Executive Order B-55-18 to Achieve Carbon Neutrality.
https://www.ca.gov/archive/gov39/wp-content/uploads/2018/09/9.10.18-Executive-Order.pdf.
9 Carbon dioxide equivalent is a unit of measure that normalizes the varying climate warming potencies of all six
GHG emissions, which are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs),
perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). For example, one metric ton of nitrous oxide is 210 metric
tons of CO2e.
10 Methane, which is the primary component of natural gas, is a very potent greenhouse gas, with a global
warming potential that is 25 times higher than CO2 over a 100-year period.
Page 4 of 13
Figure 1: 1990 vs 2022 Citywide GHG Emissions by Sector
2e)2e)2e)2e)2e)
331,840 293,413 217,279 185,925 221,923 -33.1%
21,668 21,244 25,478 29,140 n/a
194,000 153,509 134,365 135,697 144,996 -25.3%
4,718 5,009 4,384 4,427 4,709 -0.2%
8,504 2,197 1,388 1,262 2,532 -70.2%
55,057 6,531 6,660 6,522 6,857 -87.5%
186,000 - 100%
2e)
As shown in Figure 2, the two largest categories of emissions are transportation and mobile
sources (including on-road transportation, airport emissions, off-road vehicles, and Caltrain
commuter rail) and natural gas (methane) use (including residential, commercial, and
industrial).
Page 5 of 13
Figure 2: 2022 Citywide GHG Emissions by Sector
Transportation and mobile sources include emissions from private, commercial, and fleet
vehicles driven within the City’s geographical boundaries, as well as the emissions from public
transit vehicles and the City-owned fleet. Off-road vehicles include airport ground support,
construction and mining, industrial, light commercial, portable equipment, and transportation
refrigeration units.
Natural gas (methane) use includes emissions that result from natural gas (methane)
consumption in both private and public sector buildings and facilities, and residential,
commercial, and industrial sources. Fugitive emissions related to natural gas (methane)
consumption are calculated separately and are discussed in Section 1.d. The City’s electricity
supply has been carbon neutral since 2013, when the City Council approved a Carbon Neutral
Electric Resource Plan, committing Palo Alto to pursuing only carbon-neutral electric resources
and effectively eliminating all GHG emissions from the City's electric portfolio.
Page 6 of 13
1.c. Transportation and Mobile Sources
In 2022, transportation and mobile sources accounted for 61.2 percent of total citywide GHG
emissions in Palo Alto. Although GHG emissions from this sector are 24.3 percent lower than
1990 levels, emissions increased 19 percent between 2021 and 2022. As shown in Table 2,
transportation and mobile sources consist of:
•On-Road Transportation – This includes all daily vehicular trips made entirely within the
Palo Alto city limits (in-boundary trips), one-half of daily vehicular trips with an origin
within Palo Alto city limits and a destination outside of Palo Alto city limits (outbound
trips; this assumes that Palo Alto shares half the responsibility for trips traveling from
other jurisdictions), and one-half of daily vehicular trips with an origin outside Palo Alto
city limits and a destination within Palo Alto city limits (inbound trips; this assumes that
Palo Alto shares the responsibility of trips traveling to other jurisdictions). Vehicular
trips through Palo Alto are not included because Palo Alto cannot solely implement
policies that influence the trip-making behavior. Rather, through trips are assigned to
other jurisdictions that can influence either the origin or destination side of the trip-
making behavior.
•Airport Emissions – This includes emissions from take-offs and landings from trips that
start and end at Palo Alto Airport. This includes emergency services helicopters,
sightseeing helicopters, and training flights. Flights that take-off from Palo Alto Airport
but land elsewhere, and flights that land in Palo Alto Airport but take-off from
elsewhere are not included per GPC Basic Protocol.
•Off-road Vehicles - This includes airport ground support (based on take-offs and
landings), construction and mining, industrial (based on employment data), light
commercial (based on employment data), portable equipment, and transportation
refrigeration units (based on service population). Additionally, two new off-road
categories were added to the 2022 Inventory - lawn and garden equipment, and
recreational vehicles (based on service population and population, respectively).
•Caltrain Commuter Rail – This includes emissions from Caltrain travel within Palo Alto.
2e)2e)2e)2e)
293,413 217,279 185,925 221,923 54.1%
2,192 1,664 2,641 1,837 0.4%
14,634 15,029 18,961 20,191 4.9%
4,842 4,552 3,876 7,112 1.7%
Page 7 of 13
The main driver of GHG emissions from transportation and mobile sources is fuel combustion
from internal combustion engine (ICE) vehicles, specifically passenger vehicles, commercial
vehicles, and buses (69 percent, 17 percent, and two percent of all transportation GHG
emissions, respectively). Since electricity in the City is carbon-neutral, there are no GHG
emissions attributed to passenger, commercial, or bus EVs.
11 to estimate GHG emissions from all passenger,
commercial, and bus ICE vehicles. Forty-six percent of VMT was from inbound trips, 45% from
outbound trips, and 9% from in-boundary trips.
12 Commercial and bus VMT data were then multiplied by their respective EV share
percentages to determine EVMT of these vehicle categories.
11 CARB EMFAC v1.0.1.; https://ww2.arb.ca.gov/our-work/programs/msei/on-road-emfac
12 While these percent EV share estimates also come from CEC’s ZEV Statistics database, only county-level data is
available for medium- and heavy-duty (i.e., commercial and bus) ZEVs. The average percent EV share for Santa
Clara and San Mateo County was used as a proxy for Palo Alto because Palo Alto shares one zip code (94303) with
San Mateo, and much I-E/E-I EVMT attributed to Palo Alto is assumed to be between these two counties
Page 8 of 13
based on models at the County level that do not reflect Palo Alto-specific variations. The 2022
inventory sourced Santa Clara County fuel consumption from CARB’s OFFROAD model,13
including airport ground support, construction, mining, industrial, light commercial, portable
equipment, and transportation refrigeration units. All attribution factors used to allocate
countywide fuel consumption to Palo Alto in 2022 remained the same as previous inventories,14
except airport ground support. Attributed fuel consumption from each off-road sector was then
multiplied by its respective GHG emissions factor (MT CO2e/gallon) depending on fuel type
(i.e., gasoline, diesel, or natural gas) to estimate GHG emissions.
Sustainability Report as is most recently available data.15 It is assumed that the total fuel
consumption and allocation methodology described above is comparable to Palo Alto’s share of
Caltrain commuter rail emissions in 2022. Caltrain electrification is a key component of the
Caltrain Modernization program,16 with Caltrain scheduled to be electrified by late September
2024. Once the Caltrain Modernization program is complete, most of the Caltrain commuter rail
emissions will be eliminated.
1.d Natural Gas (Methane) Use
13 CARB OFFROAD v1.0.5.; https://arb.ca.gov/emfac/offroad/
14 Attribution factors are based off demographic data such as population, employment, and service population
(except for airport ground support).
15 Caltrain 2021 Sustainability Report; https://www.caltrain.com/media/30519/download
16 Caltrain Modernization Program; https://calmod.org/
Page 9 of 13
energy accounts for 3.1 percent of total emissions. In 2022, natural gas (methane) use
increased 12.6 percent in the commercial sector, 4.1 percent in the industrial sector and 2.7
percent in the residential sector. While natural gas (methane) usage fluctuates based on factors
such as weather and occupant behavior, the increase in natural gas (methane) emissions in the
commercial sector is likely due to increased occupancy from returning to the office after
working from home, filling commercial building vacancies, and economic recovery - including
increased dining, shopping, and visitors returning to Palo Alto.
1Table 3: 2022 Natural Gas (Methane) Use
Subsector
2019
Consumption
(Therms)
2020
Consumption
(Therms)
2021
Consumption
(Therms)
2022
Consumption
(Therms)
Percent of
Total
2022
Emissions (%)
Residential Energy
Industrial Energy
Commercial Energy
Total Natural Gas
(Methane) Use 28,867,162 25,267,739 25,518,320 27,140,144 35.4%
Natural Gas (Methane) Fugitive Emissions
4), some of which escapes during the drilling, extraction, and
transportation processes. Such releases are known as fugitive emissions. The primary sources of
these emissions may include equipment leaks, evaporation losses, venting, flaring and
accidental releases. Methane is a potent greenhouse gas – approximately 25 times more
powerful than carbon dioxide over a 100-year timescale.
Page 10 of 13
As mentioned in Section 1.a., the GPC Basic methodology includes GHG emissions attributable
to activities taking place within the geographic boundary of the city. As such, the 2022 GHG
inventory does not include a category of emissions that are called “upstream emissions,” which
includes emissions from extraction of natural gas (methane) and its transportation across the
western United States through California to Palo Alto. Leaks during gas extraction and
transportation can be very significant, so the actual impacts of natural gas (methane) use can
be much more significant than is represented in a formal Citywide GHG inventory.
1.e. Solid Waste
17
Figure 3: Annual Diversion Rate Percentage
17 Sustainability and Climate Action Plan Framework, November 2016;
https://www.cityofpaloalto.org/civicax/filebank/documents/64814
Page 11 of 13
Waste Energy Development Company’s (ZWED) Dry Fermentation Anaerobic Digestion (AD)
Facility in San Jose, CA, composting emissions at the Synagro El Nido Central Valley Composting
(CVC) facility in Dos Palos, as well as Palo Alto Landfill Gas Flaring Emissions.
4) – a greenhouse gas much more
potent than CO2. Organic materials (e.g., paper, plant debris, food waste, etc.) generate
methane within the anaerobic environment of a landfill while non-organic materials (e.g.,
metal, glass, etc.) do not. This is why diverting waste from landfills is so important. In 2016,
Governor Brown signed Senate Bill 1383 (SB 1383) to reduce GHG emissions from a variety of
short-lived climate pollutants, including methane from organic materials disposed in landfills.
SB 1383 is the largest and most prescriptive waste management legislation in California since
the California Integrated Waste Management Act of 1989 (AB 939) and aspires to reduce
statewide disposal of organic waste 75% by 2025 and recover at least 20% of the currently
disposed edible food for human consumption by 2025. Palo Alto is in compliance with many of
SB 1383 requirements due to the City’s progressive zero waste programs and initiatives and is
continuing to take initiatives to further reduce organic materials from being disposed in
landfills.
18 While taking all compost-bound wastewater sludge produced by the
Palo Alto RWQCP is a conservative approach to estimating activity data for wastewater sludge
composting emissions, it overestimates the City’s share since Palo Alto’s RWQCP serves several
cities and not all compost-bound wastewater sludge produced is attributed to the City. To avoid
overestimating GHG emissions from this source, an attribution factor of 43 percent (the City’s
service population divided by persons served by Palo Alto’s RWQCP) was used in the 2022
citywide inventory to scale down Palo Alto’s RWQCP compost-bound wastewater sludge to
estimate only the City’s share of wastewater sludge composting emissions. The composting
emission factor in the 2022 Inventory did not change.
18 EPA Waste Reduction Model (WARM); https://www.epa.gov/warm
Page 12 of 13
2Table 4: 1990 vs 2022 Solid Waste Emissions by Subsector
Subsector
1990 GHG
emissions
(MT CO2e)
2019 GHG
emissions
(MT CO2e)
2020 GHG
emissions
(MT CO2e)
2021 GHG
emissions
(MT CO2e)
2022 GHG
emissions
(MT CO2e)
Percent of
Total 2022
Emissions (%)
Composting Not
included 731 1,623 1,256 1,327 0.3%
Palo Alto Landfill
Gas Flaring
Not
included 281 316 237 233 0.1%
Palo Alto Landfill
Gas Fugitive 24,325 n/a19 n/a n/a n/a n/a
Palo Alto Landfill
Waste 30,732 5,519 4,721 5,029 5,297 1.3%
Total 55,057 6,531 6,660 6,522 6,857 1.7%
1.f. Wastewater Treatment
As shown in Table 5, in 2022 the RWQCP wastewater-related emissions accounted for 0.6
percent of total 2022 GHG emissions in Palo Alto – a 100.7 percent increase from 2021 and a
70.2 percent decrease from 1990. RWQCP GHG emissions originate from electricity, natural gas
(methane), and landfill gas usage required to treat the wastewater, as well as GHGs that are
emitted from the wastewater itself either during treatment or after (effluent). The nitrogen
within wastewater is subject to transformation to nitrous oxide at varying stages in the
treatment process as well as after it has been discharged to a receiving water (effluent). These
emissions are included in the RWQCP totals.
The significant increase in indirect GHG emissions from wastewater effluent between 2021 and
2022 is primarily driven by increased nitrogen content in wastewater effluent (an 86 percent
increase). Because the 2021 nitrogen content level is well below the lowest data point during
the COVID pandemic, it can be concluded that the 2021 activity data was the result of a
measurement error and the 2022 activity data is representative of current conditions despite
the comparative increase.20 Accounting for less than one percent of all GHG emissions in the
2022 citywide inventory, however, the effect on total GHG emissions is insignificant. Still, GHG
emissions from wastewater are significantly lower than 1990 levels.
As shown in Figure 4, the RWQCP operations achieved significant GHG reductions in 2019 when
the facility’s sewage sludge incinerators were replaced with the more environmentally friendly
Sludge Dewatering and Truck Loadout Facility. Previously, the RWQCP incinerators were the
City’s largest facility related GHG source. The updated biosolids treatment process has and will
continue to reduce climate-warming GHG emissions by approximately 15,000 MT of CO2e per
19 Not included because the landfill was closed
20 The 2021 nitrogen content level was reported as 1,205 kilograms (kg) of nitrogen (N) per day. The lowest data
point during the COVID pandemic was 1,950 kg N per day. The 2022 activity data was reported as 2,240 kg N per
day.
Page 13 of 13
year when compared to the emissions from incineration. This approximates the carbon dioxide
emissions of 3,000 passenger cars. The dewatered sludge is used as agricultural soil
supplements.
3Table 5: 1990 vs 2022 Wastewater-Related Emissions by Subsector
Subsector
1990 GHG
emissions
(MT CO2e)
2019 GHG
emissions
(MT CO2e)
2020 GHG
emissions
(MT CO2e)
2021 GHG
emissions
(MT CO2e)
2022 GHG
emissions
(MT CO2e)
Percent of
Total 2022
Emissions (%)
Wastewater
Biosolid
Treatment21
Wastewater
Treatment and
Effluent
Total 8,504 2,197 1,388 1,262 2,532 0.6%
Figure 4: RWQCP Historical Total Greenhouse Gas Emissions
21 Includes biosolid composting, anaerobic digestion, and incineration
Attachment B: 1990 vs. 2022 Citywide Greenhouse Gas Emissions by Sector and Subsector
Sector and Subsector
1990 GHG
emissions
(MT CO2e)1
2019 GHG
emissions
(MT CO2e)
2020 GHG
emissions
(MT CO2e)
2021 GHG
emissions
(MT CO2e)
2022 GHG
emissions
(MT CO2e)
% Change
in 2022 from
1990
Percent of
Total 2022
Emissions
Total Transportation & Mobile Sources 331,840 315,081 238,523 211,403 251,063 -24.3%61.2%
-On-Road Transportation 331,840 293,413 217,279 185,925 221,923 -33.1%54.1%
-Airport Emissions Not Included 2,192 1,664 2,641 1,837 n/a 0.4%
-Off-road Vehicles Not Included 14,634 15,029 18,961 20,191 n/a 4.9%
-Caltrain Commuter Rail Not Included 4,842 4,552 3,876 7,112 n/a 1.7%
Total Natural Gas (Methane) Use 194,000 153,509 134,365 135,697 144,996 -25.3%35.4%
-Commercial Energy Not calculated 66,987 53,515 55,676 62,667 n/a 15.3%
-Industrial Energy Not calculated 14,373 11,961 12,176 12,677 n/a 3.1%
-Residential Energy Not calculated 72,149 68,889 67,846 69,652 n/a 17.0%
Natural Gas (Methane) Fugitive Emissions 4,718 5,009 4,384 4,427 4,709 -0.2%1.1%
Total Wastewater-Related Emissions 8,504 2,197 1,388 1,262 2,532 -70.2%0.6%
-Wastewater Biosolid Treatment2 n/a 812 0 0 0 n/a 0%
-Wastewater Treatment and Effluent 8,504 1,385 1,388 1,262 2,532 -70.2%0.6%
Total Solid Waste 55,057 6,531 6,660 6,522 6,857 -87.5%1.7%
-Composting Not Included 731 1,623 1,256 1,327 n/a 0.3%
-Palo Alto Landfill Gas Flaring3 Not Included 281 316 237 233 n/a 0.1%
-Palo Alto Landfill Gas Fugitive 24,325 n/a4 n/a n/a n/a n/a n/a
-Palo Alto Landfill Waste 30,732 5,519 4,721 5,029 5,297 -82.8%1.3%
Brown Power Supply (Electricity)186,000 n/a n/a n/a n/a -100.0%n/a
Total GHG Emissions (MT CO2e)780,119 482,237 385,320 359,312 410,157 -47.4%100%
1 Source: 2016 S/CAP Framework and 2016 Earth Day Report
2 Includes biosolid composting, anaerobic digestion, and incineration
3 2016 Earth Day Report labeled these emissions as biogenic
4 Not included because the landfill was closed
Page 1 of 4
Attachment C: Palo Alto 2022 Municipal Greenhouse Gas Emissions Inventory
Overview of Methodology for Quantifying Greenhouse Gas Emissions
The 2022 Municipal Greenhouse Gas (GHG) Emissions Inventory follows the calculation and
reporting standards outlined in the International Council for Local Environmental Initiatives’
(ICLEI) Local Government Operation (LGO) Protocol1, which aligns with the Global Protocol for
Community-Scale GHG Emissions Inventories (GPC) local government operations protocol.2
Under the LGO Protocol, GHG Emissions from Palo Alto’s municipal operations can be classified
into four main sectors:
•Buildings and other facilities (e.g., stationary combustion)
•Streetlights and Traffic Signals (e.g., electricity use)
•City vehicle and equipment fleet (e.g., mobile combustion)
•Wastewater facilities (e.g., wastewater treatment and discharge)
•Indirect emissions (e.g., employee commuting, landfilled solid waste generation)
Activities taking place within a city can generate GHG emissions that occur inside the city
boundary as well as outside the city boundary. To distinguish among them, the LGO Protocol
groups emissions into three categories based on where they occur:
•Scope 1 emissions: GHG emissions from sources located within the city boundary
•Scope 2 emissions: GHG emissions occurring as a consequence of the use of grid-
supplied electricity, heat, steam and/or cooling within the city boundary
•Scope 3 emissions: All other GHG emissions that occur outside the city boundary as a
result of activities taking places within the city boundary
Palo Alto’s 2022 Municipal GHG Emissions
In 2022, the City emitted a total of 15,784 metric tons of carbon dioxide equivalent (MT of
CO2e) from municipal operations. As shown in Table 1, GHG emissions from Palo Alto’s
municipal operations are from five main sectors: buildings and other facilities, streetlights and
traffic signals, city vehicles and equipment, wastewater facilities, and indirect emissions. Since
the methodology has changed significantly for certain sectors since the first Municipal GHG
Inventory was conducted in 2005, it is no longer possible to do a true comparison with previous
Municipal GHG inventories. However, the methodologies for buildings and other facilities,
streetlights and traffic signals, and city vehicles and equipment are similar enough to make
rough comparisons. For reference only, in 2005 the City emitted a total of 40,499 MT of CO2e
from municipal operations.
1 LGO Protocol Rulebook; https://icleiusa.org/resources/local-government-operations-lgo-protocol/
2 GPC Inventories for local government operations;
https://ghgprotocol.org/sites/default/files/standards/GPC_Full_MASTER_RW_v7.pdf
Page 2 of 4
Table 1: 2022 Palo Alto Municipal GHG Emissions
Sector
2022 GHG
emissions
(MT CO2e)
Percent of
total
emissions (%)
Buildings and Other Facilities 3,398 21.5%
Streetlights and Traffic Signals 0 0%
City Vehicles and Equipment Fleet 1,676 10.6%
Wastewater Facilities (Regional Water Quality Control Plant)5,953 37.7%
Indirect Emission Sources 4,758 30.1%
Total 15,784 100%
Note: Percentages and MT CO2e may not add to the total due to rounding
The majority of municipal GHG emissions—about 38 percent—are attributed to the Regional
Water Quality Control Plant (RWQCP). Since the RWQCP is owned and operated by the City, 100
percent of GHG emissions are attributed to the City and falls under Scope 1. These GHG
emissions include indirect nitrous oxide (N2O) emissions from wastewater effluent (about 92
percent of total wastewater GHG emissions), indirect nitrous oxide emissions from the
nitrification/denitrification of wastewater (about seven percent of total wastewater GHG
emissions), and natural gas combustion/leakage (about one percent of total wastewater GHG
emissions).
The second major contributor to municipal GHG emissions includes GHG emissions from
indirect sources, or the City’s Scope 3 sources. These sources account for about 30 percent of
total GHG emissions and include GHG emissions resulting from employee commute mobile
combustion (about 39 percent of total indirect source GHG emissions) and methane emissions
resulting from landfilled solid waste (about 61 percent of total indirect source GHG emissions).
Landfilled solid waste methane emissions are a product of decomposing organic material
generated and sent to the landfill by municipal operations. This subsector attributes methane
emissions based on total landfilled solid waste generated in the inventory year and does not
account for pre-existing landfilled solid waste methane emissions.
The third major contributor to municipal GHG emissions includes GHG emissions from natural
gas usage in Buildings and Other Facilities (excluding the RWQCP), considered a Scope 1 source.
These GHG emissions accounted for 22 percent of total GHG emissions and are driven by
natural gas combustion (about 97 percent of total Buildings and Other Facilities GHG
emissions), and natural gas leakage (about three percent of total Buildings and Other Facilities
GHG emissions).
The final contributor to municipal GHG emissions includes the City’s Vehicle and Equipment
Fleet, considered a Scope 1 source (except for the City’s Electric Vehicles (EVs), which are
considered a Scope 2 source due to the energy source being purchased electricity). Together,
Page 3 of 4
these account for about 11 percent of total GHG emissions and are mainly driven by the City’s
on-road vehicle fleet powered by gasoline, diesel, and compressed natural gas (CNG) (about 92
percent of total Vehicle and Equipment Fleet GHG emissions) and off-vehicle/equipment fleet
powered by gasoline and diesel (about eight percent of total Vehicle and Equipment Fleet GHG
emissions).
•Administrative Services Department – purchasing and printing
•Community Services Department – administration, arts and culture, recreation, parks
and golf
•Fire Department – operations, support
•Information Technology Department – information technology
•Planning and Development Department – inspection services
•Police Department – police, animal services
•Public Works Department – engineering, facilities management, equipment
management, operations, wastewater treatment operations, storm drainage, refuse,
Palo Alto airport operations
•Utilities Department – administrative services, electric operations, electric engineering,
water / gas / wastewater engineering, water / gas / wastewater operations, resource
management
Table 2: On-Road Vehicle GHG emissions by City Department and Vehicle Fuel Type
City Department
Diesel
Vehicles
(MT CO2e)
Gasoline
Vehicles
(MT CO2e)
CNG Vehicles
(MT CO2e)
Total
(MT CO2e)
8.34
88.94
228.94
2.45
18.06
430
337.8
435.69
Total 498.63 1,045.42 6.17 1,550.22
Page 4 of 4
A comparison of 2005 and 2022 Palo Alto Municipal GHG emissions is shown in Figure 1 and
Table 3. As previously discussed, the methodology has changed significantly for certain sectors
since the first Municipal GHG Inventory was conducted in 2005, so it is no longer possible to do
a true comparison with previous Municipal GHG inventories. However, the methodologies for
buildings and other facilities, streetlights and traffic signals, and city vehicles and equipment are
similar enough to make rough comparisons.
Figure 1: 2005 vs. 2022 Palo Alto Municipal GHG Emissions
Table 3: 2005 vs. 2022 Palo Alto Municipal GHG Emissions
Sector
2005 GHG
emissions
(MT CO2e)
2022 GHG
emissions
(MT CO2e)
Percent Change
in 2022 from
2005 (%)
Total 40,499 15,784 - 61%*
Note: Percentages and MT CO2e may not add to the total due to rounding
* Not a true comparison due to different methodologies
Page 1 of 14
Attachment D: S/CAP Key Performance Indicators Progress Report for 2023
This progress report provides an update on the Sustainability and Climate Action Plan (S/CAP)
Key Performance Indicators (KPIs) for calendar year 2023. The S/CAP Key Actions are
abbreviated for the purposes of this report, but the full key actions can be found in Section 5:
Goals and Key Actions of the S/CAP.1 A summary of the progress on the KPIs for calendar year
2023 can be found in Attachment E. Signification actions and accomplishments from 2023 can
be found on the Sustainability website2.
Climate Action
GOAL
Reduce GHG emissions 80% below 1990 levels by 2030 (the “80 x 30” goal)
KEY ACTIONS
Community assistance
C1. Provide building and transportation emissions consultations for residents
C2. Develop major employer custom emissions reduction plans
Staff Analysis
C3. Study additional key actions needed for 80 x 30
C4. Study staffing and budgetary needs
C5. Study funding alternatives
C6. Conduct an electrification affordability study
C7. Study carbon neutrality options
Staff and Council action
C8. Accelerate GHG reductions
KEY PERFORMANCE INDICATORS
•GHG reductions
•Community awareness
•Participation in Climate Pledge
Climate Action KPI: GHG Reductions
Palo Alto has already made significant progress in its sustainability and climate action efforts,
decreasing its community emissions to 410,157 metric tons (MT) CO2e, or 6.1 MT CO2e per
Palo Alto resident in 2022 (47.4 percent compared to 1990 levels). However, to achieve the 80 x
1 2022 Sustainability and Climate Action Plan;
https://www.cityofpaloalto.org/files/assets/public/v/1/sustainability/reports/2022-scap-report_final.pdf
2 Sustainability Actions and Accomplishments; https://www.cityofpaloalto.org/City-Hall/Sustainability/Goals-and-
Progress/Sustainability-Actions-and-Accomplishments
Page 2 of 14
30 and carbon neutrality by 2030 goals, Palo Alto must meet a greenhouse gas (GHG) emissions
target of 156,024 MT CO2e, or 2 MT CO2e per Palo Alto resident by 2030. Key data needed to
calculate the GHG emissions for calendar year 2023 is not yet available. In order to make
progress on the GHG reductions goal, in 2023 the City focused on community assistance (Key
Action C1, C2), staff analysis (C3, C4, C5, and C6), and staff and Council action (C8).
Climate Action KPI: Community Awareness
3
4
found that 68% of residents indicated that it is essential or very important for Palo Alto to focus
on reducing GHGs in the coming two years. Staff will add a direct question to measure
community awareness in future surveys.
Climate Action KPI: Participation in Climate Pledge
GOALS
Reduce GHG emissions from the direct use of natural gas in Palo Alto’s
building sector by at least 60% below 1990 levels (116,400 MT CO2e
reduction)
Modernize the electric grid to support increased electric demand and to
accommodate state-of-the-art technology
KEY ACTIONS
Reduce greenhouse gas emissions in appliances and equipment
E1.Reduce GHG emissions in Single-Family Appliances and Equipment
E2.Reduce GHG emissions in Non-Residential Equipment
3 2022 Email Marketing Benchmarks Report, https://www.campaignmonitor.com/resources/guides/email-
marketing-benchmarks/
4 City of Palo Alto Community Survey 2023; https://www.cityofpaloalto.org/files/assets/public/v/1/city-
manager/communications-office/general/attachment-a-palo-alto-community-survey-2023-report-of-results.pdf
Page 3 of 14
Reduce natural gas use in buildings
E3.Reduce Gas Use in Major Facilities
E4.Reduce natural gas use at City facilities
E5.Support income-qualified residents and vulnerable businesses with electrification
E6.Develop electric rate options
E7.Use codes and ordinances to facilitate electrification
E8.Electric grid modernization plan
E9.Additional electrification opportunities in commercial and multi-family buildings
KEY PERFORMANCE INDICATORS
•GHG emissions from natural gas use in buildings (single-family, multifamily,
nonresidential)
•Percentage of single-family households with no gas connections
•Percentage of gas use reduction in major facilities and City facilities
In order to make progress on the Energy goals, in 2023 the City focused on key actions to
reduce GHGs in appliances and equipment (E1, E2), reduce natural gas use in buildings (E3, E4),
make it affordable (E5, E6), and pave the road to electrification (E7, E8).
Energy KPI: GHG emissions from natural gas use in buildings (single-family, multifamily,
nonresidential)
In 2023, total natural gas (methane) use in buildings was 27,399,747 therms5 or 144,972 MT of
CO2e. This is a slight increase from 2022, when total natural gas (methane) use in buildings was
27,140,144 therms or 143,599 MT of CO2e. This is most likely because it was colder in the first
three months of 2023 than in was in the first three months of 2022. It could also be because
more people were returning to work in offices and continuing to return to Palo Alto for dining,
shopping, and recreation.
Energy KPI: Percentage of single-family households with no gas connections
The City estimates that 2.1% of single-family households (341 single-family homes) have no gas
connections. The S/CAP impact analysis found that in order to achieve 80 x 30, virtually all
single-family gas appliances need to be switched to electric appliances.
Energy KPI: Percentage of gas use reduction in major facilities and City facilities
Staff estimates a 45 percent reduction in natural gas (methane) use in City facilities compared
to the 2016 baseline. Data is currently not available for other major facilities.
5 One therm is the energy content of approximately 100 cubic feet of natural gas at standard temperature and
pressure.
Page 4 of 14
Electric Vehicles
GOALS
Reduce transportation related GHG emissions at least 65% below 1990
levels (215,696 MT CO2e reduction)
Develop a public and private charging network to support EV adoption
KEY ACTIONS
Education, awareness, and collaboration
EV1.Raise awareness of alternative transportation modes, micro-mobility, and EVs
EV2.Collaborate to promote EV adoption regionally
EV3.Promote EV adoption and alternative commutes for commuters
EV4.Facilitate the adoption of EVs, e-bikes and other light EVs
EV5.Promote alternative transportation modes and infrastructure to support adoption
Expand EV infrastructure
EV6.Expand EV charging access for multi-family residents
EV7.Improve EV charging access for income-qualified residents
EV8.Ensure EV charging capacity supports EV growth
Electrify fleet vehicles
EV9.Electrify municipal vehicle fleet
EV10.Support policy to electrify fleet vehicles
KEY PERFORMANCE INDICATORS
•GHG emissions from vehicle travel
•Percentage of registered EV vehicles in Palo Alto
•Percentage of new vehicle sales that are EVs
•Percentage of multifamily residents with access to overnight EV charging
•Gasoline sales in Palo Alto
EV KPI: GHG emissions from vehicle travel
EV KPI: Percentage of registered EV vehicles in Palo Alto
Page 5 of 14
In 2021, 11% of all registered vehicles in Palo Alto were EVs (5,813).6 In 2022, that increased to
13% (6,573 EV Registrations out of 49,963 total vehicle registrations) and is estimated to be
16% in 2023.7
EV KPI: Percentage of new vehicle sales that are EVs
7 For context, in 2023, electric vehicles accounted for 42.4% of
new auto registrations in Santa Clara County, 25% of new auto registrations in CA, and 8.5% of
new auto registrations nationwide. Achieving the penetrations of electric vehicles needed to
achieve the City’s 80x30 goal requires achieving an EV new vehicle registration share of 85% per
year or more by 2030.
EV KPI: Percentage of multifamily residents with access to overnight EV charging
EV KPI: Gasoline sales in Palo Alto
GOALS
Reduce total vehicle miles traveled 12% by 2030, compared to a 2019
baseline, by reducing commute vehicle miles traveled 20%, visitor vehicles
miles traveled 10%, and resident vehicle miles traveled 6%
Increase the mode share for active transportation (walking, biking) and
transit from 19% to 40% of local work trips by 2030
KEY ACTIONS
Promote alternatives to single occupancy car trips
M1.Increase active transportation and transit for local work trips
M2.Expand availability of transit and shared mobility services
6 Electric vehicles (EVs) and plug-in hybrid electric vehicles combined.
7 2021 and 2022 statistics were calculated based on a data set provided by the California Department of Motor
Vehicles (DMV). That data set was not yet available for 2023 at the time of publication of this report, and the DMV
is removing total registration data from the data set it plans to provide, so DMV data will no longer be usable to
calculate this KPI unless the DMV changes its policies. The City and its partners are advocating to make this data
available again. In the interim, a public DMV data set showing aggregate EV and non-EV registrations by zip code is
being used. Staff generated its estimates of new and total registrations based on data on all Palo Alto zip codes
excluding 94303, which is shared with East Palo Alto. The data sets can be found at
https://data.ca.gov/dataset/vehicle-fuel-type-count-by-zip-code
Page 6 of 14
M3.Implement the Bicycle and Pedestrian Transportation Plan
M4.Improve Transportation Demand Management for employees and residents
Change the way we think about parking cars
M5.Implement smart parking infrastructure in public garages
Learn how we can grow without increasing GHG emissions
M6.Study land use and transportation
M7.Continue to implement the City’s Housing Element
M8.Improve transit and traffic flow
Leverage current tools to foster mobility related GHG reductions
M9.Create housing density and land use mix that supports transit and non-SOV (Single
Occupancy Vehicle) transportation modes
M10.Encourage reductions in GHGs and VMT (vehicle miles traveled)
KEY PERFORMANCE INDICATORS
•Total VMT
•Commute mode share for all modes
•Commute Benefits participation by City employees
•Transit ridership, the proportion of residents within a quarter-mile walkshed of frequent
transit, and the proportion of residents covered by on-demand transit services (data may
not be available every year)
•Number and proportion of residents within a 10-minute walk of retail or other essential
services/land uses (data may not be available every year)
•Number of businesses participating in Transportation Demand Management (TDM)
programs (when regional TDM Program data becomes available)
In order to make progress on the Mobility goals, in 2023 the City focused on key actions to
promote alternatives to single occupancy car trips (M1, M2, M3), change the way we think
about parking cars (M5), learn how we can grow without increasing GHG emissions (M7, M8),
and leverage current tools to foster mobility related GHG reductions (M9).
Mobility KPI: Total VMT
In 2022, total VMT was 575,190,655, which is a 12 percent increase from 2021, when total VMT
was 515,738,090. This can be attributed to more people returning to the office after working
from home due to the COVID-19 pandemic. The VMT data for 2023 is not yet available but will
be included with the 2023 GHG inventory.
Mobility KPI: Commute mode share for all modes
Table 1 shows the commute mode share for Palo Alto in 2021 and 2022. The commute mode
share for Palo Alto for 2023 is not yet available. Year 2019 data is also included as a comparison
to pre-COVID 19 pandemic mode share. In 2022 more people drove alone and less people
carpooled or worked from home than in 2021. However, there was an increase in active
transportation and transit, although transit ridership has not returned to pre-COVID 19 levels.
Page 7 of 14
Table 1: Commute Mode Share for Palo Alto Pre-Pandemic and 2021-20228
Commute Mode (worker 16 years and older)2019 2021 2022
Worked from home 9.7%48.8%32.6%
Drove Alone 61.2%34.9%46.1%
Carpooled 5.2%5.5%2.4%
Bicycle 10%5.0%9.2%
Walked 3.9%2.4%6.4%
Public transportation (excludes taxicabs)8.0%1.2%1.6%
Taxicab, motorcycle, or other means 2.1%2.3%1.7%
Mobility KPI: Commute Benefits participation by City employees
In 2023, 19% of city employees participated in commute benefits programs.
Mobility KPI: Transit ridership, the proportion of residents within a quarter-mile walkshed of
frequent transit, and the proportion of residents covered by on-demand transit services
In 2023, 21.9% of residents were within a quarter-mile walkshed of frequent transit. Walksheds
are a visual representation of the area a pedestrian can travel to access transit. With the
introduction of Palo Alto Link, 99.7% of Palo Altans are now covered by on-demand transit. In
2023, 2.08% of Palo Altans took transit.
Mobility KPI: Number and proportion of residents within a 10-minute walk of retail or other
essential services/land uses
In 2023, 32,700 Palo Alto residents (47.8% of all 68,400 residents) lived within a 10-minute walk
of retail locations or other essential services.
Mobility KPI: Number of businesses participating in Transportation Demand Management
(TDM) programs
The City will report on the “Number of businesses participating in TDM programs” KPI when
regional TDM program data becomes available.
Water
GOALS
Reduce Palo Alto’s potable water consumption 30% compared to a 1990
baseline (subject to refinement based on forthcoming California water
efficiency standards expected in 2024)
8 U.S. Census Bureau American Community Survey; https://www.census.gov/programs-surveys/acs;
https://data.census.gov/vizwidget?g=160XX00US0655282&infoSection=Commuting
Page 8 of 14
Develop a water supply portfolio which is resilient to droughts, changes in
climate, and water demand and regulations, that supports our urban canopy
KEY ACTIONS
W1.Maximize water conservation and efficiency
W2.Build a salt removal facility to improve recycled water quality
W3.Implement One Water Portfolio projects
W4.Develop a dynamic water planning tool
KEY PERFORMANCE INDICATORS
•Estimated indoor per capita residential water consumption
•Estimated outdoor residential water consumption for irrigation
•Water consumption of commercial customers with irrigation meters
•Amount of recycled water used in Palo Alto
•Volume of stormwater that is captured and reused
The near-term focus for water is reducing water consumption while exploring ways to capture
and store water and increase the availability and use of recycled water.
In 2023, the City held eight landscape workshops on water-saving topics including rainwater
harvesting, drought-tolerant landscape design, lawn conversion, and information on available
rebates. The City tabled at five neighborhood events to educate residents on water efficiency
programs and rebates. The City also provides the WaterSmart water management tool which
gives residents information about their water consumption and personalized water
conservation recommendations.
The Water KPIs are shown in Table 2.
Table 2: S/CAP Key Performance Indicators for Water (2023)
Water KPI 2023
Estimated indoor per capita residential water consumption 17,537 gallons per capita
Estimated outdoor residential water consumption for irrigation 620 million gallons
Water consumption of commercial customers with irrigation
meters 312 million gallons
Amount of recycled water used in Palo Alto 81.05 million gallons
Volume of stormwater that is captured and reused
No data to report, no active
stormwater reuse projects
at this time
Page 9 of 14
Climate Adaptation and Sea Level Rise
GOALS
Develop and adopt a multi-year Sea Level Rise Adaptation Plan including a
Sea Level Rise Vulnerability Assessment and adaptation plan
Minimize wildland fire hazards by ensuring adequate provisions for
vegetation management, emergency access and communications, inter-
agency firefighting, and standards for design and development within
wildland areas
KEY ACTIONS
Minimize the impacts of sea level rise
S1.Complete a Sea Level Rise Vulnerability Assessment
S2.Implement a Sea Level Rise Adaptation Plan
S3.Begin design process for a levee project
S4.Complete bridge improvements and identify protection strategies from flood events
Minimize the impacts of wildland fire hazards
S5.Implement the Foothills Fire Management Plan
S6.Minimize fire hazards through zoning
S7.Collaborate on reducing wildfire hazards
S8.Implement CAL FIRE education programs
KEY PERFORMANCE INDICATORS
•Percent of vulnerable locations protected from three feet of sea level rise
•Percent of properties protected from San Francisquito Creek flooding
•Progress towards sea level rise levee alignments
•Implementation of Foothills Fire Management Plan mitigation measures
Sea Level Rise KPI: Percent of vulnerable locations protected from three feet of sea level rise
Sea Level Rise KPI: Percent of properties protected from San Francisquito Creek flooding
Page 10 of 14
Sea Level Rise KPI: Progress towards sea level rise levee alignments
The “Progress towards sea level rise levee alignments” KPI is on hold until the Sea Level Rise
Adaptation Plan is completed. In 2022, the City completed a Sea Level Rise Vulnerability
Assessment9 which documents potential sea level rise hazards to City and community assets
from increments of sea level rise between 12 to 84 inches. The Assessment will inform the
development of the Sea Level Rise Adaptation Plan. Current efforts to develop the Sea Level
Rise Adaptation Plan have been paused in light of two regional efforts that may significantly
change the scope of the City’s efforts:
1. A United States Army Corps of Engineers (USACE) cost/benefit analysis determined that
there is no federal interest in funding Palo Alto shoreline improvements at this time,
and that improvements would not be needed until approximately 2060;
2. SB272 (Laird): Sea Level Rise Planning and Adaptation signed in late 2023 requires a Bay
Area regional sea level rise adaptation plan and harmonized subregional plans. Plan
requirements, and the boundaries of subregions are anticipated from the Bay
Conservation and Development Commission by the end of 2024.
The City is working on various efforts related to implementation of the Foothills Fire
Management Plan, including:
•Leading a multi-departmental Foothills Fire Management Plan Group;
•Coordinating with Santa Clara County Fire Department, Stanford University, Santa Clara
County FireSafe Council, Town of Los Altos Hills, and Woodside Fire Protection District
on regional efforts; and,
•Updating the Palo Alto Foothills Fire Management Plan and Community Wildfire
Protection Plan (CWPP).
The City is working on the deployment of solar battery back-up improvements in key locations
to keep equipment online when electricity may be disrupted or disconnected during a fire. As
part of the Utilities Wildfire Mitigation Plan, the City is undergrounding electric lines and
making other safety improvements. The City is also doing ongoing work to reduce flammable
vegetation and other “fuels” in the foothills.
Palo Alto Fire Department, OES, and CSD completed an interagency project with Stanford
University and Portola Fire Protection District for the installation of fifty N5 smoke sensors
across the Foothills WUI, 12 of which were placed on Palo Alto lands.
The “Implementation of Foothills Fire Management Plan mitigation measures” KPI is shown in
Table 3.
9 2022 Palo Alto Sea Level Rise Vulnerability Assessment;
https://www.cityofpaloalto.org/files/assets/public/v/1/public-works/environmental-compliance/sea-level-
rise/palo-alto-sea-level-rise-vulnerability-assessment-june-2022-062822-linked-final.pdf
Page 11 of 14
Table 3: S/CAP Key Performance Indicators for Foothills Fire Management Plan Mitigation
Measures (2022-2023)
Foothills Fire Management Plan Mitigation Measure 2022 2023
Number of residential defensive space re-inspections that are
required 33 homes 18 homes
Percent of miles of overhead utility line tree trimming in Foothills
completed
65.73%
(7.25 miles)
67.91%
(7.49 miles)
Total miles of electric lines undergrounded in the City of Palo
Alto Utilities Foothills Coverage Area 17,600 feet
Percent of electric line miles undergrounded in the City of Palo
Alto Utilities Foothills Coverage Area 51.3%
As a point of reference, in 2023, the city had about 116 miles of overhead lines and 195
underground lines, much of it in the Stanford Research Park area. About 2,000 residential units
are currently served by the underground system while about 14,000 have overhead lines.
Natural Environment
GOALS
Restore and enhance resilience and biodiversity of our natural environment
throughout the City
Increase tree canopy to 40% city-wide coverage by 2030
By 2030, achieve a 10% increase in land area that uses green stormwater
infrastructure to treat urban water runoff, compared to a 2020 baseline
KEY ACTIONS
Maintain and protect tree canopy
N1.Increase Palo Alto’s tree canopy
N2.Ensure No Net Tree Canopy Loss for all projects
N3.Reduce pesticide use in parks and open space preserves
N4.Enhance pollinator habitat
N5.Establish a carbon storage of tree canopy baseline and KPI
Restore and enhance biodiversity
N6.Maximize biodiversity and soil health
N7.Coordinate implementation of the City Natural Environment-Related Plans
N8.Expand Water Efficient Landscape Ordinance (WELO) requirements
N9.Phase out gas-powered lawn and garden equipment
Reduce pollutants entering the Bay
N10.Support the Green Stormwater Infrastructure Plan.
N11.Incorporate green stormwater infrastructure in municipal projects
KEY PERFORMANCE INDICATORS
Page 12 of 14
•City-wide Tree Canopy coverage
•Native species on City property and in new landscape projects (to measure biodiversity)
•Land area that uses green stormwater infrastructure to treat urban water runoff
The near-term focus for Natural Environment is to increase Palo Alto’s Tree Canopy, reduce
pesticide usage in parks and open space preserves, and support the Green Stormwater
Infrastructure Plan and incorporate it in municipal projects. In order to make progress on the
Natural Environment goals, in 2023 the City focused on key actions to maintain and protect tree
canopy (N2, N3, N4, N5), restore and enhance biodiversity (N6, N7, N8, N9), and reduce
pollutants entering the Bay (N10, N11).
Ongoing tree planting efforts to increase tree canopy will be integrated with traditional tree
planting programs and Green Stormwater Infrastructure to provide co-benefits including
carbon sequestration, improve water quality, capture stormwater when feasible, and reduce
the urban heat island.
In August 2023, the City Council adopted an ordinance to expand the scope of the gas-powered
leaf blower ban in residential neighborhoods and adopted a resolution increasing the
administrative penalty related to gas-powered leaf blower use in residential neighborhoods.10
Natural Environment KPI: City-wide Tree Canopy coverage
In 2023, citywide tree canopy coverage was 44%, however this includes open space and the
Foothills Nature Preserve. Tree canopy coverage in urbanized areas only was 26%.
Natural Environment KPI: Native species on City property and in new landscape projects (to
measure biodiversity)
There were no new landscape projects approved in 2023, so the KPI for “Native species on City
property and in new landscape projects (to measure biodiversity)” cannot be calculated.
Natural Environment KPI: Land area that uses green stormwater infrastructure to treat urban
water runoff
There is currently no data to report for the “Land area that uses green stormwater
infrastructure to treat urban water runoff” KPI. The City is waiting on project approval to send
out a request for proposals to calculate this KPI. The project is estimated to start in the Fall
2024, with reporting estimated to be ready by the end of 2025.
10 City Council, August 7, 2023; Agenda Item #13; SR #2306-1711,
https://recordsportal.paloalto.gov/Weblink/DocView.aspx?id=82491
Page 13 of 14
Zero Waste
GOALS
Divert 95% of waste from landfills by 2030, leading to zero waste
Implement short- and medium-term initiatives identified in the 2018 Zero
Waste Plan
KEY ACTIONS
Education and outreach
ZW1.Encourage food waste prevention and require food recovery from commercial food
generators
ZW2.Promote residential food waste reduction
ZW3.Champion waste prevention, reduction, reusables, and the sharing economy
ZW4.Provide waste prevention technical assistance to the commercial sector
Collaborate on and expand policies
ZW5.Prioritize domestic processing of recyclable materials
ZW6.Eliminate single-use disposable containers
ZW7.Expand the Deconstruction and Construction Materials Management Ordinance
ZW8.Implement Reach Code standard for low carbon construction materials
KEY PERFORMANCE INDICATORS
•Diversion rate
•Number of Zero Waste Plan11 initiatives implemented
11 2018 Zero Waste Plan, www.cityofpaloalto.org/zwplan
Page 14 of 14
clarification is received through Senate Bill 54 final regulations and other recent legislation
creating changes on what will be considered recyclable and compostable. The City developed
and printed postcard and trifold brochures on the Disposable Foodware Ordinance/AB 1276 to
be mailed and handed out to 450 food service establishments.
Zero Waste KPI: Diversion rate
Zero Waste KPI: Number of Zero Waste Plan initiatives implemented
Attachment E: S/CAP Key Performance Indicators Progress Summary
Key Performance Indicator 2021 2022 2023
•GHG reductions (1990 baseline)53.9%47.4% TBD (to be determined)
•Community awareness
* Staff will add a more direct question to
measure community awareness in future
surveys
68% of residents
indicated that it is
essential or very
important for Palo
Alto to focus on
reducing GHGs in
the next 2 yearsCl
i
m
a
t
e
A
c
t
i
o
n
•Participation in Climate Pledge n/a n/a Not launched yet
•GHG emissions from natural gas use in
buildings (MT CO2e)1 135,697 MT CO2e 143,599 MT CO2e 144,972 MT CO2e
•Percentage of single-family households with
no gas connections 1.2% (208 homes)2.1% (341 homes)En
e
r
g
y
•Percentage of gas use reduction in major
facilities & City facilities (2016 baseline)
45% reduction in
City facilities
•GHG emissions from vehicle travel (CO2e)185,925 MT 221,923 MT TBD
•% of registered vehicles that are EVs2 11%13%16%
•% of new vehicle sales that are EVs 24%43%52%
•% of multifamily residents with access to
overnight EV charging 4%
El
e
c
t
r
i
c
V
e
h
i
c
l
e
s
•Gasoline sales in Palo Alto Data unavailable Data unavailable Data unavailable
•Total VMT3 515,738,090 575,190,655 TBD
•Commute mode share for all modes
o Worked from home
o Drove alone
o Carpooled
o Bicycled
o Walked
o Public Transport
o Taxicab and other modes
o 48.8%
o 34.9%
o 5.5%
o 5.0%
o 2.4%
o 1.2%
o 2.3%
o 32.6%
o 46.1%
o 2.4%
o 9.2%
o 6.4%
o 1.6%
o 1.7%
TBD
•City Employee Commute Benefits participation 19%
•Transit ridership
•The proportion of residents within a quarter-
mile walkshed of frequent transit
•The proportion of residents covered by on-
demand transit services
Data unavailable Data unavailable
o 2.08%
o 21.9%
o 99.7%
•Number and proportion of residents within a
10-minute walk of retail or other essential
services/land uses4
Data unavailable Data unavailable
32,700 (47.8% of
all 68,400
residents)
Mo
b
i
l
i
t
y
•Businesses participating in TDM programs5 Data unavailable Data unavailable Data unavailable
1 GHG emissions from natural gas use in single-family, multifamily, and nonresidential buildings
2 “EVs” includes both battery electric vehicles and plug-in hybrid electric vehicles. Plug-in hybrids made up about 5% of
new vehicles in 2023 and 1% of all vehicles.
3 Annual commute, resident, and visitor Vehicle Miles Traveled (VMT)
4 Data may not be available every year
5 Will be reported on when regional Transportation Demand Management (TDM) Program data becomes available
Key Performance Indicator 2021 2022 2023
•Indoor per capita residential water
consumption (estimated)24,904 gallons 24,171 gallons 17,537 gallons
•Outdoor residential water consumption for
irrigation (estimated)
540 million
gallons
427 million
gallons
620 million
gallons
•Water consumption of commercial customers
with irrigation meters
361 million
gallons
348 million
gallons
312 million
gallons
•Amount of recycled water used in Palo Alto 98.1 million
gallons
113.5 million
gallons
81.05 million
gallons
Wa
t
e
r
•Volume of stormwater that is captured and
reused No data to report No data to report No data to report
•Percent of vulnerable locations protected
from three feet of sea level rise n/a n/a No data, project
delayed
•Percent of properties protected from San
Francisquito Creek flooding Data unavailable Data unavailable Data unavailable
•Progress towards sea level rise levee
alignments n/a Not launched yet No data, project
delayed
Cl
i
m
a
t
e
A
d
a
p
t
a
t
i
o
n
a
n
d
S
e
a
L
e
v
e
l
R
i
s
e
•Implementation of Foothills Fire
Management Plan mitigation measures
o Number of residential defensive space
re-inspections that are required
o Percent of miles of overhead utility line
tree trimming in Foothills completed
o Total miles of electric lines
undergrounded in the City of Palo Alto
Utilities Foothills Coverage Area
o Percent of electric line miles
undergrounded in the City of Palo Alto
Utilities Foothills Coverage Area
o 33 homes
o 65.73% (7.25
miles)
o 18 homes
o 67.91% (7.49
miles)
o 17,600 feet
o 51.3%
•City-wide Tree Canopy coverage 36.8%Data unavailable
44% (includes
open space and
Foothills Nature
Preserve)
26% (urbanized
areas only)
•Native species on City property and in new
landscape projects (to measure biodiversity)n/a n/a No new landscape
projects to report
Na
t
u
r
a
l
E
n
v
i
r
o
n
m
e
n
t
•Land area that uses green stormwater
infrastructure to treat urban water runoff n/a n/a No data to report
•Diversion rate 84%91%TBD
Ze
r
o
W
a
s
t
e
•Zero Waste Plan initiatives implemented
18 completed
15 in progress
15 remaining
Page 1 of 1
Attachment F: Proposed Whole Home Electrification Pilot Program Incentives
A comprehensive whole home electrification pilot could include various incentives for electrifying
at least one major appliance. Tentative incentive levels per home can be found in Table 1. Funds
for Phase 1 are included in the Adopted FY 2025 Budget, but additional Council approvals will
likely be needed for Phase 2.
Table 1: Proposed Whole Home Electrification Pilot Program Incentives
Item
Proposed
Incentive per
Home
100 Home
Pilot Comments/Assumptions
Heat Pump HVAC $2,500 $250,000
Additional Items:
Attic/Roof insulation $1,000 $30,000 Assume 30% of homes apply;
$0.75/sqft, max $1000
Electric Panel $1,500 $15,000 10% of homes opt for panel upgrades
Electric Readiness $2,000 $100,000 $500/circuit, up to $2000. Est. 50%
utilization rate
Disconnect Gas Meter $2,000 $20,000 10% of homes go all electric
Program Costs:
Home Electrification Plan $300 $30,000 Plan + Electrification Advisor
Permit Fees*TBD*$75,000 Permit fees, up to a capped amount
Rebate Administration $120 $12,000
Transformer Upgrades TBD TBD Still estimating the cost of this item
Total Program Costs** Up to $9,400
+ permit fees $532,000
* Tentative – staff intends to recommend covering permit fees. Payment method and dollar amounts still being designed.
** Turnkey service in Phase 2 would include additional project management & concierge service fees, to be determined.
Annual Report on S/CAP Implementation
Presenters:
Brad Eggleston, Director, Public Works
Director, Climate Action
Christine Luong, Sustainability Manager
November 12, 2024 www.cityofpaloalto.org
2 2cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
Objectives for Tonight
Review the following:
•2022 Palo Alto Citywide Greenhouse Gas (GHG) Inventory and
progress toward the 80 x 30 goal
•S/CAP Key Performance Indicators 2023 Annual Progress Report
•Sustainability and Climate Action Plan (S/CAP) Implementation
Q2 and Q3 2024 Progress Report Highlights
•Whole Home Electrification Pilot Program
3 3cityofpaloalto.org/ClimateAction
2022 Greenhouse Gas Emissions Inventories
4 4cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
2022 Palo Alto Citywide GHG Emissions Down ~47.4%
Source: 2022 Palo Alto GHG Emissions Inventory
5 5cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
Palo Alto Greenhouse Gas Emissions Per Capita
Source: 2022 Palo Alto GHG Emissions Inventory
6 6cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
2022 Palo Alto Citywide GHG Emissions Down ~47.4%
80 x 30 Target
(156K MT CO2e)
Source: 2022 Palo Alto GHG Emissions Inventory
7 7cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
2022 Palo Alto Citywide GHG Emission Sources
Source: 2022 Palo Alto GHG Emissions Inventory
8 8cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
Progress Towards Carbon Neutrality ~ 66% reductions
Source: 2022 Palo Alto GHG Emissions Inventory
9 9cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
2022 Palo Alto Municipal GHG Emissions
Source: 2022 Palo Alto GHG Emissions Inventory
10 10cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
2023 Key Performance Indicators Progress
11 11cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
2023 Key Performance Indicators Progress Highlights
S/CAP Area Key Performance Indicator 2021 2022 2023
Climate Action GHG Reductions 53.9%47.4%To be determined
Energy GHG emissions from natural
gas use in buildings
135,697 MT CO2e 143,599 MT CO2e 144,972 MT CO2e
Electric Vehicles GHG emissions from vehicle
travel
185,925 MT CO2e 221,923 MT CO2e To be determined
Mobility Total vehicle miles traveled 515,738,090 575,190,655 To be determined
Water Indoor per capita residential
water consumption (estimate)
24,904 gallons 24,171 gallons 17,537 gallons
Climate Adaptation
and Sea Level Rise
Progress towards sea level
rise levee alignments
Not applicable Not launched yet Not launched yet
Natural
Environment
City-wide Tree Canopy
coverage
36.8%Data unavailable 44% (includes open space,
Foothills Nature Preserve)
26% (urbanized areas only)
Zero Waste Diversion Rate 84%91%TBD
12 12cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
2024 2nd and 3rd Quarter Progress
13 13cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
S/CAP Key Issue Areas
cityofpaloalto.org/ClimateAction
SU
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A
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A
B
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Y
A
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14 14cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
Climate Action Progress
•Progress on carbon emissions
–Not on a "straight line" trajectory to achieve 80x30 –but that is expected
–2023-2025 Work Plan Focus is on laying the groundwork for future growth
-Pilots and new infrastructure to support future rapid adoption
-Studies to support scaling up climate effort
-Raising awareness
–S/CAP Climate Action is a partnership –success requires extraordinary support
by the City and extraordinary participation by community members
15 15cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
Climate Protection Ad Hoc Committee
•Climate Protection Ad Hoc Committee
–Council Member Vicki Veenker (Chair) and Council Member Pat Burt
–19 meetings in 2024 plus 3 upcoming
•Climate Protection Working Group
–Bret Andersen, Carbon Free Palo Alto; Lincoln Bleavens, Stanford University;
Justine Burt, Palo Alto Transportation Management Association; Rachel Croft,
Utilities Advisory Commission; Bruce Hodge, Carbon Free Palo Alto; Mark
Hoffberg; Tom Kabat; Phil Metz, Utilities Advisory Commission; Debbie Mytels,
350 Silicon Valley Palo Alto; Matt Passell; Anu Ramamurty, Kat Kid Adventure;
Avroh Shah, Palo Alto Student Climate Coalition; Julia Zeitlin, Silicon Valley
Sunrise Hub and Palo Alto Student Climate Coalition
–8 meetings in 2024 plus 2 upcoming
16 16cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
Climate Action Progress
•Modernizing the Electric Grid
–Goal is to enhance reliability and resiliency, add capacity for electrification,
and modernize to integrate new technologies
–First neighborhood on track for completion early 2025 –about 1000 homes
–Goal is about 5000 more homes each year for the following three years
–Reliability and Resiliency Strategic Plan to evaluate new technologies that may
help with reliability, local resiliency, reduce distribution investment
•Other trends enhancing reliability
–Statewide preservation of generating capacity and growth in battery storage
–Second transmission line continues to be a priority
17 17cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
Climate Action Progress
•Program Successes
–Advanced Heat Pump Water Heater Pilot –over 450 HPWHs
•5-10 times as much participation per capita as other programs
–Multi-family EV Charger Program –shared charger access for
13% of MFR units
•Includes three affordable housing complexes
–Commercial rooftop HVAC pilot
–Last mile transit solutions: extended Palo Alto Link through
June, made progress on micromobility market assessment
–Bicycle & Pedestrian Transportation Plan Update feedback
–Progress on Downtown & San Antonio Housing Plan
development
18 18cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
Climate Action Progress
•New and Upcoming Programs
–Whole Home Electrification Pilot Program
–Study in progress on multi-family and non-
residential technologies to pilot
–Study on EV charging needs and how to greatly
expand access in progress
•Community Outreach
–Outreach via Earth Day Festival, tabling at events,
newsletters
–Added question on climate goal awareness to
Community Survey
–Created Youth Climate Advisory Board
–Utilities Director outreach about electric reliability
19 19cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
Sustainability Progress
•Mitigate the potential for wildfires and plan for sea level rise
–Palo Alto Horizontal Levee -first of its kind
to be built in the Bay Area
–Completed the Palo Alto Annex to the Santa Clara
County Multi-Jurisdictional Hazard Mitigation Plan
•Progress on an efficient and resilient water system
–WaterSmart customer portal, launched November 2022
–Continuing work on the RWQCP Advanced Water Purification System
–Developing a "One Water" Plan for Palo Alto
20 20cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
Sustainability Progress
•Protections to the local natural environment
–Establishing a baseline for carbon storage of Palo Alto’s urban tree canopy
–Completed first year of implementation of the updated Tree Protection
Ordinance
•Progress on zero waste goals
–Countywide edible food recovery program
–Reviewed Fiscal Year 2023 progress on the Deconstruction and Construction
Material Management Ordinance
–Low Carbon Construction Materials Reach Code, went in effect January 1, 2023
21 21cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
Whole Home Electrification Pilot Program
22 22cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
Whole Home Program Two Phase Launch Plan
•Phase One (early 2025) –incentives, financing, technical assistance
–Launch incentives (funding approved in FY 2025 Budget)
–Promote GoGreen Financing
–Provide home electrification plans
–Over the counter mechanical/electrical/plumbing
permit pilot program
•Phase Two (summer 2025) –full service turnkey program
–Contract for full service provider to manage the entire process for
participants
23 23cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
Proposed Whole Home Electrification Pilot Program Incentives
ITEM
PROPOSED
INCENTIVE
per Home
100 Home
Pilot Comments/Assumptions
Heat Pump HVAC $2,500 $250,000
Additional Items:
Attic/Roof insulation $1,000 $30,000 Assume 30% of homes apply; $0.75/sqft, max
$1000
Electric Panel $1,500 $15,000 10% of homes opt for panel upgrades
Electric Readiness $2,000 $100,000 $500/circuit, up to $2000. Est. 50% utilization rate
Disconnect Gas Meter $2,000 $20,000 10% of homes go all electric
Program Costs:
Home Electrification Plan $300 $30,000 Plan + Electrification Advisor
Permit Fees*TBD*$75,000 Permit fees, up to a capped amount
Rebate Administration $120 $12,000
Transformer Upgrades TBD TBD Still estimating the cost of this item
Total Program Costs**Up to $9,400 +
permit fees $532,000
* Tentative –staff intends to recommend covering permit fees. Payment method and dollar amounts still being designed.
** Turnkey service in Phase 2 would include additional project management & concierge service fees, TBD.
24 24cityofpaloalto.org/ClimateAction Acting Now for A Resilient Future
Next steps in S/CAP Implementation
•Ongoing S/CAP Implementation
–Sustainability Programs
–Electrification Programs
–E-Mobility Strategic Plan adoption
–Reliability and Resiliency Strategic Plan policy discussions
–S/CAP Funding Study discussions
•2026-2028 Energy Code updates
•2026-2027 S/CAP Work Plan development
From:David Coale
To:Council, City; Shikada, Ed; Abendschein, Jonathan; Bailey, Diane
Subject:SCAP - Grid modernization and Whole Home Electrification pilot program
Date:Tuesday, November 12, 2024 9:05:50 AM
Attachments:Smart panel cost saving (SWAG1).pdf
CPUC Electrification.pdf
Electrifaction and the NEC.pdf
CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links.
Dear Mayor, City Council, and City staff,
In reviewing the report on the SCAP is it clear we need to move faster in all aspects of
addressing the 80 by 30 GHG reduction goals. As part of the many programs, the Whole
Home Electrification pilot program offers a way to jump start and provide a testing ground
that could speed up, and at the same time, reduce the disruption and cost of the grid
modernization program by $20 to $30 million.
In the report on Grid Modernization that was presented in February this year (Staff report
2401-2508), it shows that the most costly part of the grid modernization is upgrading the
undergrounded portions of the electric service to the homes. See analysis below.
In a study by Home Energy Analytics, it has been shown that there is plenty of electrical
capacity in most home electrical panels and that they are under utilized. In addition, with the
application of the Watt Diet and use of smart panel technologies, as stated in the attached
reports, this could eliminate the costly grid upgrade in the areas where the service to the home
is undergrounded.
With all the advantages of this approach, a pilot program should be pursued ASAP to test out
these concepts/technologies. While the pilot would not necessarily have to be in an area
where the feeder lines to homes are undergrounded, it would be best and would further the
grid modernization efforts. This pilot program could also be combined with the Whole Home
Electrification project to help reduce the cost and realize this pilot program in a timely manor
for the Grid Modernization Plan.
This would also avoid intrusive disruption to the community as well by eliminating trenching
and transformer relocation to above ground locations where most of these will have to be on
private property.
Sincerely,
David Coale
Carbon Free Palo Alto
Coast savings for grid modernization using EMS or smart panels and the Watt Diet
Use of smart panel instead of underground grid upgrades
Description Qty Unit unit cost total Notes
SPAN Panel (200 amp)3144 1 6000 18,864,000 Replacing all undergrounded homes
Lumin cost $4000 with a SPAN panel instead. Use 4000
This would replace for a Lumin panel & about 30M savings
Pad mounted TX 424 1 40,000 16,960,000 From electrification report, see below
Underground cabling 30,900 foot 800 24,720,000 From electrification report, see below
41,680,000
Initial savings 22,816,000 There would be additional savings*
or saving per home 7,257.00 Savings per home
To increase reliability/resiliency/backup power one could add a battery or bidirectional EV charging
Battery backup/load leveling 3144 1 10000 31,440,000
Bidirectional EV charging 3144 1 5000 15,720,000
* There would be likely additional savings as many undergrounded TX will have to be pad mounted and there
will likely be additional cost/compensation in the placement of these TX on private property. There would also
be much less disruption to the community as trenching would be avoided.
Exert from the Staff Report (2401-2508) to the UAC on the Electrical Grid Modernization Plan presented on 2/7/24
R.19-01-011 Phase 4A
Staff Proposal
CPUC ENERGY DIVISION STAFF
Ju ly 1 8 , 202 4
FILED
07/18/24
10:08 AM
R1901011
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CALIFORNIA PUBLIC UTILITIES COMMISSION i
Table of Contents
TABLE OF CONTENTS ........................................................................................... I
ACRONYMNS & ABBREVIATIONS ........................................................................II
TABLES & FIGURES .............................................................................................. III
1 EXECUTIVE SUMMARY ................................................................................... 1
2 BACKGROUND ............................................................................................. 4
2.1 Electrical Panels and Service Upsizing ........................................................ 4
2.2 Meter Socket Adapters .......................................................................... 23
3 CHALLENGES ...............................................................................................32
3.1 Contractors Lack Information Necessary to Assess Amperage Needs .............. 32
3.2 Scope of Cost Recovery for Meter Socket Evaluation is Overly Restrictive ......... 33
4 RECOMMENDATIONS ..................................................................................35
4.1 Mandate that IOUs Provide Additional Data on Customer Bills ....................... 35
4.2 Authorize IOU Evaluation of Non -Isolating Devices....................................... 36
5 CONCLUSION ..............................................................................................37
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Acronymns & Abbreviations
Amp
BUILD
CARB
CPUC
D.
DER
EV
GHG
HPWH
IOU
kWh
LBNL
MSA
NBT
NEC
NFPA
PG&E
PTO
PV
R.
SB
SCE
SDG&E
TECH
WNDRR
Ampere
Build ing Initiative for Low-Emissions Development
California Air Resources Board
California Public Utilities Commission
Decision
Distributed Energy Resource
Electric Vehicle
Greenhouse Gas
Heat Pump Water Heater
Investor Owned Utility
Kilowatt Hour
Lawrence Berkeley National Laboratory
Meter Socket Adatper
Net Billing Tariff
National Electrical Code
National Fire Protection Association
Pacific Gas & Electric
Permission to Operate
Photovoltaic
Rulemaking
Senate Bill
Southern California Edison
San Diego Gas & Electric
Technology and Equipment for Clean Heating
Wildfire and Natural Disaster Resiliency Rebuild
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CALIFORNIA PUBLIC UTILITIES COMMISSION iii
Tables & Figures
Figure 1: Components of an Electrical Service............................................................... 5
Figure 2: PG&E Estimated Service Modification Costs ...................................................... 9
Figure 3: Cost Ranges for Electrical Service Modifications: PG&E and SDG&E ...................... 11
Figure 4: Steps and Timelines for Service Upgrades by PG&E and SDG&E ........................... 14
Figure 5: Sample Load Calculation Using Section 220.83 for a Single -Family Home ............... 18
Figure 6: Peak Power Levels for a Sample of PG&E Homes .............................................. 20
Figure 7: Panel Size vs. Actual Utilization ..................................................................... 21
Figure 8: Available Panel Capacity for 1,477 PG&E Homes .............................................. 22
Figure 9: Maximum Demand for Dwellings ................................................................... 23
Figure 10 : Sample Meter Socket Installation ................................................................ 24
Figure 11: MSA for Solar PV Applications ..................................................................... 26
Figure 12: MSA for Adding Loads, Such as EV Chargers .................................................. 29
Table 1: SCE and SDG&E Costs for Overhead and Underground Services ........................... 10
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1 Executive Summary
This Phase 4A Staff Proposal provides Energy Division Staff’s recommendations for preventing
unnecessary main electrical service panel and service line upsizing, which are costly to both the individual
customer triggering the service panel upsizing and to ratepayers who pay for any service line upsizing costs
borne by the IOUs through electric rates. The cost for distribution grid impacts is determined typically
through the IOU GRC. Unless strategically directed, these investments could be unequitable and risk
leaving behind low-income customers, who would be responsible for bearing a portion of the cost of
electrification in high -income neighborhoods, where early adoption of electric vehicles (EVs) and other
building electrification measures is comparatively higher. Overcoming these barriers will help accelerate
statewide build ing decarbonization efforts to achieve California’s goal of three million climate -ready and
climate-friendly homes by 2030 and seven million climate-ready and climate-friendly homes by 2035,1 and to
help achieve California’s wider climate goal of carbon neutrality by 2045.2
Regardless of income, service line upsizing and any associated distribution system upgrades should
be avoided as much as possible to minimize the costs to all ratepayers. Staff believe that facilitating
alternatives to service line upsizing will reduce the overall cost of building decarbonization measures for
customers and will lower the cost burden to ratepayers. Alternatives to service line upsizing are especially
important for low-income customers, for whom service line upsizing may be cost-prohibitive, and who
already spend a much higher percentage of their household income on energy costs.3
This Staff Proposal identifies two recommendations to help customers avoid service line upsizing.
The first recommendation seeks to make it simpler for customers and contractors to identify existing
electrical demand on a home’s electrical panel and service line. Staff recommend that the IOUs list a home’s
peak demand, over 15-minute intervals, for the previous 30 days and previous year, if applicable, on a
customer’s monthly bill and online customer portal. This information , when readily available, will make it
much easier for contractors to use a provision in California’s Electrical Code , California Code of
Regulations, Title 24, Part 3, to gauge how much remaining electrical capacity exists on a panel and service.
1 Governor Gavin Newsom’s letter to CARB Chair Liane Randolph, July 22, 2022. See: https://www.gov.ca.gov/wp -
content/uploads/2022/07/07.22.2022-Governors-Letter-to-CARB.pdf.
2 Executive Order B-55-18, issued September 10th, 2018. See: https://archive.gov.ca.gov/archive/gov39/wp -
content/uploads/2018/09/9.10.18-Executive-Order.pdf.
3 “How High Are Household Energy Burdens ?,” ACEEE, September 2020. https://www.energy.gov/sites/default/files/2021 -
12/ACEEE%2C%20Household%20Enegy%20Burdens.pdf .
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M eter data from a sample size of residential utility customers show that most residential panels and services
average 34% utilization of full capacity, meaning that many homes likely have sufficient capacity to add
electrical loads associated with building electrification.4 Providing a customer’s peak demand will make it
much easier for contractors to accurately assess a home’s actual demand and potentially add electrical loads
without upsizing. Staff also recommend that IOUs collect customer’s service line capacity when conducting
any visits to customer premises, and to gather such data in a database and report on customer bills, to
further aid customers and contractors to work within existing capacity constraints when electrifying and
avoid unnecessary upsizing.
The second recommendation seeks to widen the pool of technologies available to customers to help
avoid electrical service and panel upsizing. Specifically, Staff recommend that the CPUC authorize the IOUs
to use previously approved funding for evaluating electrical isolating devices, which currently has ample
remaining funds, to recover costs for evaluating the safety and reliability of meter socket adapters (MSA s)
and other technologically similar devices that interface with utility equipment , for situations where additional
load is added to the incoming service line without isolating the premise from the electric grid . Once
assessed, these devices could be approved for electrification end -uses. MSAs connect to the existing service
line between the meter and the main breaker of the electrical panel and can serve a variety of purposes,
including interconnecting solar photovoltaic (PV) systems and adding load . MSAs can prevent the need to
upsize a home’s electrical service by tapping directly into service line (on the line side, behind the meter) and
bypassing the electrical panel. Because devices connected to the MSA do not supply or draw power via the
main service panel, the MSAs can help add PV, energy storage, or additional load without needing to alter
the main service panel.
Currently, R.19-09-009 (“Rulemaking Regarding Microgrids Pursuant to Senate Bill 1339 and
Resiliency Strategies”), via Ordering Paragraph 9 of D.21-01-018, approved IOU cost recovery of up to $3
million for implementing a process for evaluating electrical isolating technologies, the majority of which
have been MSAs.5 The decision, however, did not grant explicit cost recovery for non -electrically isolating
devices. Because MSAs interface with meter sockets and utility meters, the IOUs must assess and approve
their use before customers can install them. No cost recovery mechanism currently exists for evaluating and
4 Home Energy Analytics. See:
https://onedrive.live.com/?authkey=%21AE2eAgVkTO4ssWY&cid=428E7D625E39DE0E&id=428E7D625E39DE0E%2199
5&parId=428E7D625E39DE0E%21993&o=OneUp .
5 See: https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M361/K442/361442167.PDF .
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approving MSAs for situations where disconnection from the grid is not desired . Staff believe that
expanding approval for MSAs for non-electrical isolating use cases, such as solar PV and building and
transportation electrification use cases will add an important tool to the growing list of strategies for
avoiding service upsizing.
The recommendations in this Staff Proposal are intended to provide customers and contractors with
tools to help buildings stay within the existing capacities of their electrical panels and electrical services, even
as such buildings transition to all-electric end -uses. These recommendations are intended to (1) reduce the
costs of building and transportation electrification for customers and make these measures more accessible
to low-income households; (2) reduce delays for customers by eliminating the need to obtain permits and
inspection approvals, and remove the need to coordinate with utility staff for upgrades to utility
infrastructure; and (3) reduce ratepayer impacts by avoiding additional utility spending for service line
upsizing and further upstream distribution infrastructure.
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2 Background
This section first describes what electrical panel and electrical service upsizing comprises, the costs
and barriers associated with these types of projects, the nuances of calculating electrical loads of existing
residential buildings, and why these methods can impact building electrification efforts more broadly.
Second , it describes several potential use cases for MSAs (though not an exhaustive list) and how MSAs can
help avoid panel and service upgrades for customers seeking to add additional electrical load or behind the
meter DERs to their homes.
2.1 Electric al Panels and Service Upsizing
An electrical panel is a piece of customer -owned equipment that connects a building to utility
electrical infrastructure and distributes grid electricity to different circuits in the building to power lights and
appliances. Electrical panels have amperage ratings, which indicate the level of electrical current in amperes
(“amps”) that can safely run through the panel’s physical components without causing fire or shock hazards.
Most residential main electrical service panels in California are rated between 50 amp and 400 am ps, with
roughly half of all residential electrical panels rated to accommodate fewer than 200 amps.6 Since its 2019
cycle update, the California Building Energy Code, Title 24, Part 6, also referred to as the California Energy
Code, has required 200-amp main electrical service panels for single-family homes.7 Th e 2019 Energy Code
update took effect January 1, 2020.
An electrical service refers to the conductors, cables, and other equipment that transfer electricity
from the electric grid to the premise’s utility meter, and from there to the electrical panel. A building’s
electrical service also has a service rating that indicates the amount of current that can safely run through the
service wire and related components. The main electrical panel’s amperage capacity is generally sized to
match the building’s electrical service capacity.
6 “Solving the Panel Puzzle,” SPUR, May 2024, p.8. See: https://www.spur.org/sites/default/files/2024 -
05/SPUR_Solving_the_Panel_Puzzle.pdf . This paper references a forthcoming study, “Electrical Service Panel Capacity in
California Households with Insights for Equitable Building Electrification,” ACEEE and data from the Electric Power Research
Institute’s research on electrical panel upgrades needed across the U.S. See here for more information on the latter:
https://www.epri.com/research/products/000000003002026736 .
7 See: https://energycodeace.com/site/custom/public/reference-ace-
2019/index.html#!Documents/section11010mandatoryrequirementsforsolarreadybuildings.htm .
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Figure 1 illustrates the components of an electrical service and how it connects to a building’s main
electrical service panel (referred to below as a “service breaker panel”). A sub-panel is generally located away
from the main panel and is not depicted as part of Figure 1. The term “electrical panel” can be used to refer
to either a main panel or a sub -panel.
Figure 1: Components of an Electrical Service8
8 “Service Upgrades for Electrification Retrofits Study Final Report,” NV5, May 2022 , p.1. See:
https://pda.energydataweb.com/api/view/2635/Service%20Upgrades%20for%20Electrification%20Retrofits%20Study%20FIN
AL.pdf.
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A building owner may opt to replace an electrical panel for a variety of reasons. The panel may
present safety hazards, either because the equipment is old or degraded, or because the equipment has
known defects that can lead to increased fire or shock risks. It may have insufficient circuit breaker slots to
connect new loads, such as an EV charger or a new heat pump appliance. M ost relevant to this proposal, a
main panel may not have sufficient electrical capacity to handle any additional electrical load or addition of
distributed energy resources, such as solar PV and battery energy storage systems. Similarly, a building
owner may replace an electrical service for safety reasons or because the service capacity is insufficient to
meet the electrical needs of a building. Often, increasing the electrical capacity of a main panel triggers the
need to increase the capacity of an electrical service.
This proposal does not use the term s “panel upgrade” and “service upgrade,” terms that are
commonly used in the discourse around building decarbonization but can be confusing, since they can refer
to different types of modifications to the panel and service. Instead, the terms “panel replacement” and
“service replacement” are used to refer to a like-for-like replacement of equipment with the same or lower
ampacity rating (e.g., for safety reasons), and “panel upsize” and “service upsize” are used to refer to an
increase in the panel or service ampacity rating (e.g., from 100 amps to 200 amps).
Panel Replacements
Panel replacements are necessary for buildings with electrical panels that have documented safety
risks; this type of work should be prioritized , especially if additional load will be added to homes with this
equipment. Such panels include older brands of panels with faulty circuit breakers that do not trip when
overloaded, leading to overheating and fire hazards.9 While the Consumer Product Safety Commission has
recalled a few products, it is important to note that their recalls are reactive, and generally only reflect
instances where numerous complaints have already been made by the public, and only after lengthy
investigation.10 Some contractors have drawn attention to panels that have not been officially recalled, but
still have a known track record of safety issues.11 Panel replacements that proactively eliminate these safety
9 Such brands include Zinsco, certain panels manufactured by Federal Pacific or Federal Pacific Electric, Challenger, and
Pushmatic. See: https://www.pennaelectric.com/unsafe-outdated -electrical-panels/.
10 See the Consumer Product Safety Commission’s website for details on recalled products:
https://www.cpsc.gov/Recalls?tabset=on&search_combined_fields=panel&field_rc_date_value=&field_rc_date_value_1=&fiel
d_rc_hazards_target_id=All&field_rc_recall_by_product_target_id=180&field_rc_manufactured_in_value=&page=1 .
11 See: https://www.pennaelectric.com/unsafe-outdated -electrical-panels/.
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hazards should be prioritized. Additionally, panels that are old, in disrepair, and present any type of safety
hazards should be replaced.
Necessary and Unnecessary Service and Panel Upsizing
Necessary panel and service upsizing in the context of building electrification and electric vehicle
charging is defined as upsizing that is pursued after all other methods have been exhausted to safely, and in
compliance with NEC, avoid panel and service upsizing while still allowing the home to fully electrify its
end uses and add electric vehicle charging. This includes exploring the use of circuit pausing or sharing,
circuit controllers, smart panels, meter socket adapters, or other available technolog y to avoid upsizing;
exploring the use of power-efficient devices such as 120-volt water heaters; considering multifunctional
equipment such as combination cooktops and ovens; considering the use of moderate - or low-speed EV
charging; and strategically emp loying different NEC methods for calculating a building’s total electrical load
(discussed in more detail below).
Unnecessary panel and service upsizing is when the above methods have not been thoroughly
considered and pursued and a customer upsizes their equipment despite there being a safe, compliant, and
viable alternative pathway to full home electrification and electric vehicle charging. Additionally, panels that
are in disrepair, or otherwise present safety hazards should be replaced or relocated .
Costs of Panel Upgrades and Service Upsizing
Panel and service replacements and upsizing can be costly for building owners and electric
ratepayers, the latter of whom foot the bill for utility-side costs related to electrical service modifications and
any upstream distribution infrastructure that must also be replaced or upsized.
If a building owner wishes to replace or upsize a main electrical panel, this will likely cost the owner
between $1,000 and $14,000, excluding the costs for service upsizing (discussed below).12 The actual cost
depends on a variety of factors, such as whether a panel needs to be moved or if construction work needs to
be done to access the service conductors.
12 The lower end estimate is based on TECH data, which found that a panel upgrade added about $1,500 (+/- $500) to an HVAC
electrification project cost. (Source: “TECH Panel Upgrade Analysis, Preliminary Findings” presented by VEIC on September 8,
2023, to the Panel Optimization Work and Electrical Reassessments group.) The upper end of the estimate comes from PG&E
(Source: “Benefit-Cost Analysis of Targeted Electrification and Gas Decommissioning in California,” E nergy + Environmental
Economics, December 2023, p.30. https://www.ethree.com/wp -content/uploads/2023/12/E3_Benefit -Cost-Analysis-of-
Targeted -Electrification -and-Gas-Decommissioning-in-California.pdf).
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Service replacements or service upsizing can add significantly to the costs of panel upsizing. Utilities
provide electric line extension allowances, which cover costs up to a pre-determined value for service line
modifications and potential distribution line modifications. Currently, for residential customers, the electric
line extension allowance is $3,255 for PG&E, $5,718 for SCE, and $3,981 for SDG&E.13 While these
allowances may cover some or all of the costs of upsizing, a variety of factors can greatly increase the costs
of a service line replacement or upsizing , requiring the customer to pay for work in excess of the allowance.
On average, Pacific Gas & Electric (PG&E) reports the average cost for overhead service (before
allowances) as $26,286 and for underground service as $23,275.14 PG&E’s historical data show that the
majority of underground projects fewer than 400 amps (55%) range between $2,500 to $10,000 ; of the
remaining projects, 20% cost less than $2,500, 20% cost between $10,000 and $31,000, and 5% of projects
cost more than $31,000. For overhead projects, PG&E reports that the majority (55%) of overhead projects
fewer than 400 amps cost between $3,000 to $13,000; of the remaining projects, 20% cost less than $3,000,
20% of projects cost between $13,000 and $40,000, and 5% cost more than $40,000. PG&E cites the need
13 PG&E Electric Rule 15, p.8; SCE Electric Rule 15, p.7; and SDG&E Electric Rule 15, p.5 .
14 Data response submitted to CPUC from PG&E on October 3, 2023 .
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to obtain right of way or easements and additional infrastructure or upgrades as the primary reasons for
higher costs.15
Figure 2: PG&E Estimated Service Modification Costs 16
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Southern California Edison (SCE) and San Diego Gas & Electric (SDG&E) report the following
costs for overhead and underground service line modifications, delineated between customer and utility
costs:17
Table 1: SCE and SDG&E Costs for Overhead and Underground Services
Average Costs for Overhead Service
Work
Average Costs for Underground Service
Work
Customer Cost Utility Cost Total Cost Customer Cost Utility Cost Total Cost
SCE 18 $17.13 $881.66 $895.99 $557.23 $2,544.40 $3,075.32
SDG&E19 $736.13 $1,045.07 $1,781.20 $762.51 $1,575.56 $2,338.07
The costs of additional work, such as transformer upsizing and pole replacements , can add
thousands of dollars more to a service line upsizing project. The table below demonstrates the range of
costs for various aspects of service line replacements or upsizing in PG&E and SDG&E territories.20
15 “Solving the Panel Puzzle,” SPUR, May 2024, p.5. https://www.spur.org/sites/default/files/2024 -
05/SPUR_Solving_the_Panel_Puzzle.pdf.
16 Ibid .
17 PG&E reported that it did not have a similar breakdown of customer and utility costs for service modification requests. Data
response submitted to CPUC from PG&E on October 3, 2023 .
18 Data response submitted to CPUC from SCE on September 26, 2023 .
19 Data response submitted to CPUC from SDG&E on September 26, 2023 .
20 This particular study was conducted by PG&E and SDG&E, hence the data reflects only these two service territories. “Service
Upgrades for Electrification Retrofits Study Final Report,” NV5, May 2022, p.32 . See:
https://pda.energydataweb.com/api/view/2635/Service%20Upgrades%20for%20Electrification%20Retrofits%20Study%20FIN
AL.pdf.
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Figure 3: Cost Ranges for Electrical Service Modifications: PG&E and SDG&E21
These cost estimates indicate that panel and service upsizing can place a significant cost burden on
individual property owners as well as ratepayers (via utility side costs) who shoulder a majority of the costs
for service upsizing. However, the above cost estimates do not factor in the additional upstream costs for
the distribution grid that will inevitably be needed as California continues to rapidly electrify its
transportation sector and buildings. In 2021, California’s Building Decarbonization Assessment report
(CEC)22 predicted significant increases in demand caused b y building decarbonization, potentially
necessitating additional investment in distribution and transmission infrastructure compared to what is
already planned to serve the base case load forecast. In 2023, the IEPR recognized the infrastructure
constraints created due to accelerated electric vehicle deployment over the past several years.23 These
upgrades may come at great cost to ratepayers but can be mitigated through measures discussed herein .
21 Ibid .
22 See p.A-114: https://efiling.energy.ca.gov/GetDocument.aspx?tn=239311 .
23 2023 Integrated Energy Policy Report , p.2: https://efiling.energy.ca.gov/GetDocument.aspx?tn=254463 .
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However, it may be possible to avoid a huge portion of these costs through policies that consider DERs,
electric grid, and the gas grid cohesively.
Inflated costs from unnecessary panel and service upsizing may also unfairly disadvantage under-
resourced neighborhoods. For example, in SCE’s 2023 Grid Needs Assessment and Distribution Deferral
Opportunity report, filed in the High DER proceeding , a zip code’s propensity to add EVs is assumed to
have a direct correlation with income, wherein households above $150,000 are assumed to have an EV, and
that zip code’s load forecast and grid load needs are assessed accordingly. 24 If infrastructure upgrades in
lower income households and geographies are not prioritized, and not provided assistance in cases where
the homeowners cannot afford the cost of service upsizing , then under a business-as-usual scenario , these
under-resourced customers are in danger of not only being left out, but bearing the remaining cost of the
state’s gas system .
The state’s push for rapid electrification, including rulemakings initiated by the California Air
Resources Board (CARB) and local air quality management districts, means that millions of homes will need
to switch from gas to electric end uses..25 A study released in 2024 estimated that 49% (around 3.7 million)
of the state’s 7.6 million single family homes have panels rated under 200 amps, which is the standard that
new single-family homes have been built to since 200-amp panels became a Title 24 requirement effective
January 1, 2019 and which are generally considered to be more than sufficient for full-home electrification.26
If all 3.7 million homes follow the prevailing logic that electrical panels and services need to be upsized to
200 amps to accommodate EV charging and home electrification measures, this could mean burdening
ratepayers with significant additional capital costs in the next few decades.
To avoid this scenario, th is Staff Proposal recommends that the CPUC actively encourag e
alternatives to panel and service upsizing wherever possible, though the CPUC does not discourage panel
and service replacement for safety reasons. Building decarbonization advocates have assembled a growing
list of so-called “panel optimization” strategies to avoid panel upsizing, including (but not limited to) usin g
24 Southern California Edison’s Narrative 2023: “Grid Needs Assessment & Distribution Deferral Opportunity Report”; August
2023, pp.22-23. R.21-06-007 Docket. http://docs.cpuc.ca.gov/SearchRes.aspx?DocFormat=ALL&DocID=517610166 .
25 See Bay Area Air Quality Management District’s Rulemakings on Rules 9-4 and 9-6: https://www.baaqmd.gov/rules -and -
compliance/rule-development/building-appliances. South Coast Air Quality Management district is considering similar alterations
to rules 1111 and 1121: https://www.aqmd.gov/home/rules -compliance/rules/scaqmd -rule-book/proposed -rules/rule-1111-
and -rule-1121. And finally, CARB is considering zero -emission space and water heater standards: https://ww2.arb.ca.gov/our-
work/programs/zero -emission-space-and-water-heater-standards.
26 “Quantifying the electric service panel capacities of California’s residential buildings,” Fournier et al, 2024 . See:
https://www.sciencedirect.com/science/article/pii/S0301421524002581 .
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power-efficient appliances, smart panels, and/or circuit splitters and pausers.27 Through this proposal, Staff
hope to expand this list of strategies available to property owners and contractors and avoid unnecessary
panel and service upsizing throughout the state making MSAs and other non -electrically isolating devices as
an option to consumers and contractors.
Timelines for Panel Upgrades and Service Upsizing
Upsizing or replacing a panel or service can add months to an electrification project. If a customer
wants to modify their panel, this may entail:
• Selecting a contractor;
• Requesting a panel upgrade from the utility;
• Having a utility employee conduct a site inspection/visit;
• Requiring the utility to issue a work order;
• Having the contractor pull a local work permit;
• Disconnecting the home from utility service;
• Conducting construction to remove the old panel and rewire a new panel ;
• Obtaining local inspection approval; and
• Reconnecting utility service.28
This entire process for panel replacement generally takes at minimum three weeks, though wait
times can be far longer if design review is required .29 If a customer’s panel needs to be moved to a different
location, such as if the panel does not meet requirements for clearance from gas equipment 30 or working
27 “Solving the Panel Puzzle,” SPUR, May 2024, p.11. See: https://www.spur.org/sites/default/files/2024-
05/SPUR_Solving_the_Panel_Puzzle.pdf.
28 “Service Upgrades for Electrification Retrofits Study Final Report,” NV5, May 2022 , p p.27-30. See:
https://pda.energydataweb.com/api/view/2635/Service%20Upgrades%20for%20Electrification%20Retrofits%20Study%20FIN
AL.pdf and SDG&E’s Renewable Meter Adapter page and video detailing this process:
https://www.sdge.com/residential/savings -center/solar-power-renewable-energy/renewable-meter-adapter.
29 “Solving the Panel Puzzle,” SPUR, May 2024, p.6. See: https://www.spur.org/sites/default/files/2024-
05/SPUR_Solving_the_Panel_Puzzle.pdf.
30 Each utility has set certain standards dictating the minimum clearance between electrical panels and gas service equipment. For
example, PG&E’s Greenbook requires a 36-inch radial clearance from the gas vent and a 10-foot vertical clear zone. See: p.3,
https://www.pge.com/content/dam/pge/docs/account/service-requests/TD-7001M-B011.pdf. SDG&E requires similar
clearance. See: p.392, https://www.sdge.com/sites/default/files/SG2024v0607e.pdf. SCE’s requirements can be found here. See:
p.148,
https://edisonintl.sharepoint.com/teams/Public/Misc/Shared%20Documents/Forms/AllItems.aspx?id=%2Fteams%2FPublic
%2FMisc%2FShared%20Documents%2Fdocuments%2FRegulatory%2FSCE%2DManuals%2FESR%2Epdf&parent=%2Fteam
s%2FPublic%2FMisc%2FShared%20Documents%2Fdocument s%2FRegulatory%2FSCE%2DManuals&p=true&ga=1 .
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requirements,31 this type of project may require additional review from the local utility and often also from
the local building department, consequently costing more time, money, and hassle for customers.
Service upsizing often requires even more coordination with the utility and may require the
customer to apply for a service upgrade with their utility, receive engineering review , obtain permits and
easements, coordinate with local authorities to perform inspections, and schedule crews to perform
energization. The figure below shows the steps and timelines for service upsizing or replacements from
PG&E and SDG&E32:
Figure 4: Steps and Timelines for Service Upgrades by PG&E and SDG&E 33
31 The 2023 National Electrical Code (NEC) Section 110.26 requires a minimum clearance around electrical equipment, including
electrical panels, to ensure adequate working space to access such equipment.
32 This data came from a study commissioned jointly by PG&E and SDG&E. SCE did not participate in this study, so the data
from SCE is not available.
33 Ibid .
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A survey of customers in PG&E and SDG&E territories found that the majority faced significant
delays from utilities and occasional delays with local permitting authorities.34 Such delays can add costs to a
project and can be frustrating for customers and contractors.
Additionally, service upsizing can have indirect timeline impacts on other utility customers. The
additional volume of service upsizing requests can delay other customers who may be waiting for service
energization or other actions by a utility’s service department. This is because a utility’s service department
has limited capacity, and an influx of service upsizing requests may add to the backlog of requests being
processed by the service department. Furthermore, if a service panel upsizing would be required as part of
an interconnection request for additional DER generation by an existing custome r, that DER generator’s
interconnection could be delayed by the service upsizing process required by the utility service department
in parallel with actions by the utility interconnection department. Permission to Operate (PTO) and
consequent timely customer benefits, solar output, and generation to support the grid can all be delayed by a
panel or service up sizing.
Electrical Load Calculations and Panel Sizin g
Decarbonizing buildings means homes would be encouraged to transition away from gas appliances
and toward their electric counterparts. Full-home electrification without strategic decarbonization (energy
efficiency and grid -responsive measures, including load-shifting, demand response and deployable storage)
will thus likely increase a building’s electricity power consumption, also known as its electrical load.
When adding load to an existing building, such as a new HPWH or EV charger, an electrician or
contractor must determine whether the building’s electrical equipment is able to safely handle the additional
electrical load from the new appliance. This includes the building’s main electrical panel and service
conductors (wires leading from the utility grid to the building), which need to be appropriately sized to
handle the potentially increased amount of electric current (measured in amperes, or “amps”) that will flow
through this equipment to power the end -use appliance. As more current flows through a conductor, heat is
generated ; if conductors or a panel’s physical components are not properly sized , they are at risk of
overheating and causing fires or shock hazards.
34 “Service Upgrades for Electrification Retrofits Study Final Report,” NV5, May 2022.
https://pda.energydataweb.com/api/view/2635/Service%20Upgrades%20for%20Electrification%20Retrofits%20Study%20FIN
AL.pdf.
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The National Fire Protection Association (NFPA) oversees NFPA 70, also known as the National
Electrical Code (NEC), which provides guidance on how to safely install such electrical equipment and
wiring in buildings to avoid these risks. The NEC is the most widely adopted standard for electrical safety in
buildings in the U nited States and is the code adopted by California as Part 3 of Title 24. The code is
voluntarily adopted and enforced by local jurisdictions, usually at the state -level, but occasionally at the
county and municipal level. The NFPA updates the code every three years, and the 2023 NEC is the most
recent version. California adopted the 2020 NEC as part of its 2022 California Electrical Code and will likely
update the 2023 NEC in the next update of the California Electrical Code . The NEC is first and foremost a
safety code and does not explicitly focus on advancing energy efficiency or decarbonization goals.
Section 220 of the NEC contains provisions for calculating the electrical load of an existing
residential building and how to safely add new load. There are two primary options available for existing
residential buildings.
The first method , in Section 220.83 (for single-family dwellings) and Section 220.84 (for multi-family
dwellings), prescribes an alternative bottom -up calculation of accounting for loads such as lighting and
appliances. This method may only be used for residences served by a 120/240 volt or 208Y/120 volt 3 -wire
service, which is the case for most residences.
The second method described in Section 220.87 and is a “top down” calculation that determines
existing loads based on observed usage, usually through metering data.
NEC Section 220.87, or the “Top-down” Approach: The top-down approach of determining
existing loads uses metering data to determine a building’s actual energy usage. Within the top -down
approach, there are two options:
1) The NEC allows using peak load data over a one-year period to determine existing load ; the
2023 code is ambiguous about the time interval for this data. The building’s observed load is
then multiplied by a safety factor of 1.25 to arrive at a building’s final existing load. When
factoring in new loads into the load calculations via the top-down approach , all new load is
added at 100% of each appliance’s nameplate rating in load calculations , that is, the maximum
power the device draws under standardized con ditions.35
35 Section 220.83, National Electrical Code.
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2) The NEC also permits using a building’s peak load over a 30 -day period, using 15-minute
interval meter data, to determine the building’s current load. However, a building that has
“renewable energy systems (i.e., solar photovoltaic or wind electric) or employs any form of peak
load shaving” may not use th is method.36
NEC Sections 220.83 and 220.84, or the “Bottom -up” Approach: The bottom -up approach es
described in Section s 220.83 and 220.84 estimates load based off the nameplate ratings of currently installed
appliances instead of actual measured electrical demand . The NEC specifies how to add up all existing
individual loads (e.g., from lighting, stove, laundry units) and apply demand factors, which are essentially
estimates of what percentage the load is expected to be on at the same time. This method of calculating is a
more conservative estimate of a building’s actual load and does not factor in the real-world operation of the
home, such as changes in the number of occupants or occupant behavior.
The figure below demonstrates a sample load calculation via Section 220.83 for a single-family
home. In this approach, all new loads are added at the nameplate ratings of the new appliances (first
section). Per Section 220.83 (B), the first 8,000 watts are counted at 100% of their value, and the remainder
is counted at 40% (second section). Heating and cooling loads are added separately at 100% of their
nameplate rating s and the remaining load (HPWH) is added at 40%.37
36 Ibid .
37 Ampere (amps) is a unit of measure for the flow of current. A volt is a unit of measure for electric “pressure” – or the
difference in electrical potential between two different points. A watt is a measure of power, or how much electricity is con sumed
over a period of time. These units are related via the following equation: Watts = Volts * Amperes.
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Figure 5: Sample Load Calculation Using Section 220.83 for a Single -Family Home38
Comparing Load Calculation Methods
These two methods offer different advantages based on the scenario . The top -down approach
calculates a home’s existing load more accurately and usually results in a smaller calculated existing load for
the building . This means that the home may have more available capacity to add new load within the
constraints of existing electrical equipment and wiring . One disadvantage is that an electrician or contractor
needs to obtain metering data from a customer and convert that to peak load, which can be cumbersome,
confusing , and prone to calculation errors. Additionally, this m ethod only permits adding load at 100% of its
38 “Good Stewardship of the Panel Webinar” presentation, Tom Kabat, January 23, 2024.
https://techcleanca.com/documents/4159/Panel_Symposium.pdf .
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nameplate value and does not allow exclusion of loads that will be replaced or removed from the final load
calculation.
The bottom -up approach, on the other hand, does not require metering data, but does require that
all appliances’ nameplate values be collected , which can be time-consuming to gather. This approach usually
results in a larger existing load calculation than that calculated via Section 220.87 . However, the bottom -up
approach allows for the addition of more new load than the top -down approach . This is because the
bottom-up approach allows most new loads to be added to the total load calculation at less than 100% of
the new load’s nameplate rating.39 The bottom -up approach also allows subtracting out the loads that will
be removed or replaced.
Typically, the top -down approach is the best option when adding a couple of loads or adding loads
over time. The bottom -up approach is the preferred approach when adding many additional new loads, or
when metering data is not readily available.
Importantly, either method can be used to comply with the NEC’s existing load calculation s and
customers can rely on whichever method is most advantageous to their electrification needs.
Existing Load Observations
Preliminary research indicates that peak demand in residential buildings rarely reaches the maximum
capacity of existing electrical panels. This means that electrical panels may have a significant amount of
electrical capacity to add additional load.
Figure 6 illustrates the peak demand of 22,442 homes in PG&E’s service territory. Over the period
of a year, 98% had a peak demand of fewer than 88 amps, 86% had a peak demand of fewer than 50 amps,
and 48% had a peak demand of fewer than 30 amps.
39 New loads in this method are generally added at 40% of the nameplate rating, with the exception of heating, ventilation and a ir
conditioning equipment, which are added at 100% of their nameplate ratings. This 40% discount is called a demand factor.
Demand factors effectively reduce the calculated load that new appliances will add to a building, to reflect how these appliances
will realistically be used in a building. For example, it is unlikely that the clothes dryer and stove will be on all the tim e. Hence, it
does not make sense to add these loads at 100% of their nameplate rating. By reducing how much these new loads add to the
existing building’s load, demand factors helps to reduce oversizing of electrical systems in homes.
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Figure 6: Peak Power Levels for a Sample of PG&E Homes 40
Figure 7 offers insight into the relationship between electric demand and panel size for 1,480 homes
in PG&E territory. It shows that peak demand often only represents 34% of a panel’s full capacity. The X-
axis represents the number of homes, and the Y-axis represents the panel’s rated capacity (in amps). The
blue areas demonstrate the used capacity (i.e., peak demand of the home), and the orange areas represent the
remaining capacity on the panel. As the graph illustrates, the vast majority of homes with main panels sized
40 Home Energy Analytics : https://corp.hea.com/home-electrification .
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100 amps or greater have ample capacity to add load (orange shaded area).
Figure 7: Panel Size vs. Actual Utilization 41
Figure 8 below presents similar data, illustrating that 71% of single-family homes with 100- to 200-
amp panels in PG&E territory have 50% or more of their panel’s capacity available. Of single-family homes
that have panels smaller than 100 amps, 29% still have over 50% of their panel’s capacity available. In multi-
family and manufactured homes, 75% of homes with 100- to 200-amp panels have 50% or more of their
panel’s capacity available for adding loads. These data indicate that most homes with 100- to 200-amp
panels may be able to avoid panel and service upsizing through the “top-down” calculation method (Section
220.87) and/or panel optimization strategies.
41 Home Energy Analytics public data folder:
https://onedrive.live.com/?authkey=%21AE2eAgVkTO4ssWY&cid=428E7D625E39DE0E&id=428E7D625E39DE0E%2199
5&parId=428E7D625E39DE0E%21993&o=OneUp . Staff annotations added.
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Figure 8: Available Panel Capacity for 1,477 PG&E Homes 42
A broader, national study conducted by the Lawrence Berkeley National Lab (LBNL) arrived at
similar conclusions, finding that most homes’ peak demand (over 15 -minute intervals) are only a fraction of
typical panel capacities.43 Figure 9 below shows that, of their sample of homes, the median value of
maximum demand was only 37.5 amps (9 kilowatts at 240 volts). Only 1.8% of homes reached a maximum
demand of 100 amps (24 kilowatts at 240 volts), and only 0.2% reached a maximum demand of 200 amps
(48 kilowatts at 240 volts).
42 “Solving the Panel Puzzle,” SPUR, May 2024, p.10. See: https://www.spur.org/sites/default/files/2024-
05/SPUR_Solving_the_Panel_Puzzle.pdf.
43 See: DOE webinar “Intersection of Energy Codes and Electrical Codes on the Road to Decarbonization,” Slide 71, by Brennan
Less, Lawrence Berkeley National Lab. https://www.energycodes.gov/sites/default/files/2024 -
04/Intersection_energy_electrical_codes.pdf.
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Figure 9: Maximum Demand for Dwellings44
This suggests that even homes with 100-amp panels and service likely have ample capacity to add
load without upsizing.
2.2 Meter Socket Adapters
“MSA” is a generic term for a device that is installed between the utility meter and the meter socket
in the customer’s service entrance equipment. These devices have been around for decades and have a
variety of applications. Examples of use cases include, but are not limited to, converting meter types or the
orientation of meters, electrical isolation of a home from the utility grid, connecting backup generation,
interconnecting solar PV generation systems, and adding load (e.g., electric vehicle chargers). MSAs for
44 See: DOE webinar “Intersection of Energy Codes and Electrical Codes on the Road to Decarbonization,” Slide 71, by Brennan
Less, Lawrence Berkeley National Lab. https://www.energycodes.gov/sites/default/files/2024 -
04/Intersection_energy_electrical_codes.pdf.
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DERs are an emerging technology that can assist with building decarbonization , since MSAs can greatly
reduce the cost of DER installations and help meet the state’s policy and climate goals.
The image below shows a sample MSA installation , with a junction box attached to the top,
connected to flexible conduit containing con ductors that can connect to external load or a solar PV system.
Figure 10 : Sample Meter Socket Installation45
Electrical Isolating versus Non-Isolating MSAs
This staff proposal makes a distinction between electrically isolating MSAs and non -isolating MSAs.
Electrically isolating MSAs have a built-in switch that can “island” a building from the grid, disconnecting a
building from receiving or sending power back to the utility grid. Because the isolating MSAs prevent
backfeeding of power to the grid, they allow a building to safely use b ack-up power from distributed
generation or a storage resource during grid power outages or any disconnection from the utility g rid. Thus,
isolating MSAs play an important role in deployment and commercialization of microgrids for resiliency
measures.
45 Image source: ConnectDER, with Staff annotations added.
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Non-isolating MSAs, in contrast, are MSAs that do not have this electrical isolating capability.
Isolating capabilities and additional functions, such as adding PV, storage, or additional load, are not
mutually exclusive. That is, an MSA with an additional branch circuit for adding EV charging loads, can also
be capable of electrical isolation. However, MSAs for adding EV or other building electrification loads that
are currently commercially available do not have electrical isolation capabilities.
The distinction between isolating versus non -isolating MSAs is important because only isolating
MSAs are currently being evaluated by IOUs for approved use in buildings. This will be discussed in Section
3.2.
Meter Socket Adapter Use in Solar Photovoltaic Interconnection
Utility-owned MSAs for PV solar are already offered by PG&E, SCE, and SDG&E (collectively,
IOUs) as an alternative interconnection option for solar PV systems.46 The IOUs developed these products
to help shorten the standard solar PV interconnection process, as discussed below. An MSA in th is context
connects the solar PV system to the home’s electrical system behind the utility meter (on the “load side”),
but in front of the main panel circuit breaker (on the “supply side”). Figure 11 shows how a PV MSA is
connected to the grid and a home’s existing electrical system.
46 PG&E offers a Green Meter Adapter: https://www.pge.com/assets/pge/docs/account/service-requests/094684.pdf. SCE
offers a Renewable Meter Adapter: https://www.sce.com/sites/default/files/inline-
files/%23126256_Generation%2BMeter%2BAdapter.pdf. SDG&E offers a similar Renewable Meter Adapter:
https://www.sdge.com/residential/savings -center/solar-power-renewable-energy/renewable-meter-adapter.
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Figure 11: MSA for Solar PV Applications 47
The MSA allows PV to be added to a home without altering the main panel ; no additional circuit
breaker space is needed, nor does the panel need to be upsized .
In typical PV installations, a PV system is connected to a building and the grid behind the electrical
panel main breaker, on the load side. In this configuration, the electricity generated from the PV system
must flow through the electrical panel (via a new circuit on the panel) to deliver power to either the other
47 Source: ConnectDER Solar MSA v. 5.1 installation manual: https://connectder.com/wp -
content/uploads/2023/08/ConnectDER_Solar_MSA_v5.1_Installation -Manual-v1.0f.pdf.
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loads on the electrical panel, or back to the grid . This means that the panel has to have sufficient physical
breaker space and amperage capacity to handle this extra flow of electricity.
MSAs, however, allow the PV system to bypass the electrical panel as it supplies electricity to the
grid. This is because the PV system is connected to the building behind the utility meter, but in front of the
electrical panel’s main breaker; this connection is called a line or supply-side connection . Electricity
generated by the PV system flows to the electrical panel (and connected loads) without requiring extra
circuit breaker space, and electricity sent to the grid does not need to pass through the ele ctrical panel at all.
This benefit of MSAs is particularly important, as PV systems are often the main triggers for panel
and service upsizing.48 By avoiding costly panel upsizing, and potentially service upsizing, the MSA saves the
customer and utility time and money.
Meter Socket Adapter Use in Battery Storage
MSAs can also be used to connect battery storage systems to a home’s existing electrical
infrastructure. MSAs can provide a cheaper and speedier alternative to main panel upgrades if storage is
being added to a home or add itional storage is being added to an existing solar system. As mentioned above,
isolating MSAs can provide a mechanism that allows a home to isolate from the electrical grid, thus allowing
a home to use solar and battery storage to power the home when electricity from the grid is unavailable.
MSAs can support the addition of storage in homes that have PV solar systems . In R.20-08-020, the
Rulemaking to Revisit Net Energy Metering Tariffs, D.22-12-056 (approved on December 15, 2022)
established a net billing tariff (NBT), to update incentives for PV solar installations and promote the
adoption of such systems paired with battery storage. By mandating high -differential time-of-use rates (i.e.,
electrification rates), the NBT incents customers to store the electricity produced by PV during the mid dle
of the day and use it for self -consumption during the evening instead of importing high -cost electricity from
the grid.
The future growth of NBT solar-paired -storage is an explicit state policy goal. D.22-12-056
establishes a future “glide path ” for the expected growth of NBT solar -paired storage and states that “the
adopted glide path should encourage sustainable market growth during the transition from a predominantly
48 “Service Upgrades for Electrification Retrofits Study Final Report ,” NV5, May 2022, p p.21-22. See:
https://pda.energydataweb.com/api/view/2635/Service%20Upgrades%20for%20Electrification%20Retrofits%20Study%20FIN
AL.pdf.
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stand -alone solar system program to one that encourages the adoption of solar paired with storage
systems.”49
Meter Socket Adapter Use in Building Electrification and Transportation
Electrification
In the last few years, the market has seen growing commercial availability of MSAs with the ability to
add load to a building. These types of MSAs have an additional branch circuit that allow the addition of
interruptible loads such as EV charging equipment or HPWHs. Some of these MSAs have a built-in load
control systems that stop flow of current to the MSA-connected load when the MSA detects that the load
from the main panel reaches a certain threshold.50 This built-in load control mechanism means that the
combined amperage draw from the MSA-connected load and the main panel will not exceed the rating of
the utility service conductors. One commercially available MSA also offers a supplementary circuit breaker
in front of the main panel’s main breaker, offering additional overcurrent protection. These provisions mean
that neither the main panel nor the utility service needs to be altered to accommodate MSA -connected
loads. Figure 12 demonstrates how a load -adding MSA is connected to the grid and a home’s existing
electrical infrastructure.
49 D.22-12-056 at 124. See: https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M500/K043/500043682.PDF .
50 The ConnectDER EV MSA has an embedded load control system that shuts off power flow to the load connected to the MSA
when it detects that the load exceeds 80% of the main electrical service rating. For example, if a home’s electrical service is rated
at 100 amps, and the MSA detects that the home’s load reaches more than 80 amps, the MSA will shut off power flow to the EV
charger or HPWH that is connected to the MSA.
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Figure 12: MSA for Adding Loads, Such as EV Chargers 51
51 ConnectDER EV MSA – Technical Specifications manual: https://connectder.com/wp -
content/uploads/2024/03/ConnectDER-EV_MSA_V1.0-Technical_Specifications.pdf.
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Additionally, customers using these types of MSAs can avoid the cost and hassle of add ing a
subpanel or replacing their main p anel if their current one lacks physical breaker space. The MSA has its
own built-in branch circuit that can connect to devices, so the added load does not require an additional
branch circuit to be added to the main panel itself. Because these MSAs can avoid rewiring or panel
replacements or upsizing associated with adding loads such as HPWHs or EV charging equipment, these
MSAs can be a lower-cost option for customers looking to electrify their homes with limited panel capacity
and/or breaker space.
Meter Socket Adapter Advantages Over Panel Upsizing or Replacement
MSA installation is simpler and faster than replacing an electrical panel and service. These projects
do not require removal of the panel, shutting off and on utility power, or local building department
inspection. Installation only requires meter removal, installation of the MSA, minor wiring work, and re-
installation of the meter on top of the MSA. Although the installation does currently require utility staff to
remove and reinstall the meter, the work can be completed in as little as an hour.52
Installing and maintaining these MSAs costs less than panel upsizing (resulting from electrical
capacity constraints) or adding a subpanel (resulting from breaker space constraints). As mentioned in
Section 2.1.2, panel upsizing usually costs anywhere from $1,000 to $14,000. The costs for installing
subpanels is slightly lower; a 2024 CPUC -led survey of electricians statewide landed on an average of about
$2,211 for this type of project.53 In contrast, the PV MSAs offered directly by IOUs costs customers $500 in
SCE territory,54 $1,047 for PG&E,55 and $1,326 for SDG&E.56 Third party MSAs used for DER
applications are still in development, and therefore there is limited publicly available price data, but
conversations with one company indicated that the cost for a n EV MSA (not including installation costs)
cost less than $900 as of April 2024.57 The same 2024 CPUC -led survey referenced above found that meter
collar installation by electricians on average cost $1,832.58 Even at the upper end of these cost estimates,
52 https://www.sdge.com/residential/savings -center/solar-power-renewable-energy/renewable-meter-adapter
53 “Fuel Substitution Infrastructure Cost Market Study” summary slides. See:
https://pda.energydataweb.com/api/view/3948/CA%20IOU%20Fuel%20Sub%20Preliminary%20Results%20Presentation_FI
NAL_2024-04-04.pdf.
54 See: https://www.sce.com/sites/default/files/inline-files/%23126256_Generation%2BMeter%2BAdapter.pdf.
55 See: https://www.pge.com/en/about/doing -business-with-pge/interconnections/net-energy-metering-
program.html#accordion -8a141835ac-item-9a34edc3ff.
56 See: https://www.sdge.com/residential/savings -center/solar-power-renewable-energy/renewable-meter-adapter.
57 CPUC communications with ConnectDER, February 16, 2024.
58 See: “Fuel Substitution Infrastructure Cost Market Study” summary slides: https://www.cpuc.ca.gov/about -
cpuc/divisions/energy-division/building-decarbonization/fuel-substitution-in-energy-efficiency.
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customers will likely save anywhere from a thousand to several thousand dollars by opting for MSAs over
panel upsizing or subpanel installations.
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3 Challenges
This section addresses the barriers facing customers and contractors who want to use alternative
methods of calculating a home’s existing electrical load. It addresses the current limitations on cost recovery
for IOUs to expand their evaluation process for non -electrical isolating, utility-interfacing devices, including
non -isolating meter socket adapters.
3.1 Contractors Lack Information Necessary to Assess Amperage
Needs
Currently, if contractors want to use the “top down” load calculation method described in Section
220.87, they must ask customers to provide energy usage data. This requires the customer to download the
data from their utility to share with the contractor. The contractor then needs to (1) determine the metering
interval (e.g., 15-minutes or one-hour), (2) the period over which this data was collected (e.g., 30 days or one
year), and (3) the highest energy consumption over this period, which is usually represented in kilowatt
hours (kWh). The contractor must then convert this consumption data to peak demand (in amps). While
these data are usually available, these steps make it much more difficult for contractors to employ the top -
down load calculation method . Such calculations may also be subject to errors.
The consequence of these barriers is that contractors may turn to the more common load calculation
method s of Sections 220.83 and 220.84, which will generally estimate a higher existing load for a dwelling
than if calculated via Section 220.87. As a result, when adding new electrification loads, a contractor may
end up with a final load calculation that may be greater than the actual new peak demand of the home.
Consequently, these load calculations may push a contractor to recommend upsizing a building’s m ain panel
and electrical service conductors unnecessarily.
Additionally, customers do not have a way to easily discern their service line capacities. IOUs do not
have this data readily available. This information is important for customers and contractors to understand
how much existing capacity they have on their service line , and to potentially work within these constraints
when electrifying their buildings.
As mentioned in the previous section, unnecessary panel and service upsizing can result in burdening
customers with thousands of dollars in costs per building and add significant upward rate pressure in the
coming decades.
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3.2 Scope o f Cost Recovery f or Meter Socket Evaluation i s Overly
Restrictive
MSAs interface with the meter, a utility-owned piece of equipment, and therefore they must receive
explicit IOU approval before customers can install these devices.
The CPUC has already approved a detailed process to assess the safety and reliability of emerging
electrical isolation technologies, which can include isolating MSAs serving this specific function . On January
14, 2021, D.21-01-018 (R.19-09-009, “Regarding Microgrids Pursuant to Senate Bill 1339”) directed PG&E,
SCE, and SDG&E to file Tier 2 advice letters to define the criteria and evaluation process to test electrical
isolation technology and devices in an effort to reduce barriers for microgrid deployment .59 This decision
also allocated $3 million across the IOUs to implement the reliability and safety evaluations .60 These funds
are to be recovered via distribution rates via an Annual Electric True-up advice letter. As of June 2024,
PG&E has spent $232,879, SCE has spent $250,759, and SDG&E has spent $81,82 7 for a combined total
of $565,465 spent of the $3 million allocated for these evaluations.61
The Commission approved a final process for IOUs to follow in Resolution E-5194. The joint
advice letters submitted by the IOUs and Resolution E-5194 describe in detail the evaluation process,
including how third parties should submit technologies for testing, what additional testing the IOUs will
conduct, how IOUs should communicate feedback to third parties, justification for repeating testing already
completed by a Nationally Recognized Testing Laboratory as part of certification to a national standard, and
timelines for completion of the evaluation.62
Thus far, all devices evaluated via this process have been MSAs, though the process stipulated by the
Commission is agnostic to specific device types.
From a technical perspective, this evaluation process could be applied to similar technologies that do
not provide electrical isolation functionality, such as the aforementioned load -adding MSAs. However, the
IOUs are currently only authorized cost recovery for conducting such evaluations on electrical isolating
technologies, and are not currently evaluating non -isolating MSA products. This means that the MSAs that
59 See: https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M361/K442/361442167.PDF .
60 See D.21-01-018, p.79.
61 Data responses received from SDG&E (June 5, 2024), SCE (June 4, 2024), and PG&E (May 29, 2024).
62 See: https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M489/K665/489665658.PDF .
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lack a grid isolating function , though highly similar to MSAs that do have this function, and which could
undergo the established IOU evaluation process, are not being evaluated in practice. As discussed above,
some commercially available MSAs with the ability to add a branch circuit for connecting interruptible loads
do not have electrical isolation capabilities. Thus, under the current situation , while such non-isolating MSA
products may receive third -party certifications and safety approvals, without IOU approval they still cannot
be installed in customers’ homes.
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4 Recommendations
This section recommends that IOUs provide customers with peak demand information on their
bills. Additionally, it recommend s that the CPUC approve expanded cost recovery for IOU evaluation
processes of utility-interfacing devices to include applicable, non -electrically isolating devices.
4.1 Mandate that IOUs Provide Additional Data on Customer Bills
Given that utilities currently have smart metering data readily available, staff recommend that IOUs
report the peak energy consumption (in kWh) and peak demand (in amps) over a 15-minute interval for two
time periods: the last 30 days and the last year (if applicable) from the billing date. IOUs should report this
data clearly on a customer’s monthly electronic and paper bill, including the period over which the data was
collected and interval (i.e., 15 min or 1 hour) of data, and also make this data easily accessible on a
customer’s online account.
This information can be readily used by electricians to calculate a home’s load via the “top down”
Section 220.87 method, without the hassle of downloading customer electricity usage data and additional
calculations. Such smart meter data should be acceptable to use within Section 220.87. Utilities should
implement these billing changes within one year of the release of a proposed decision , and coordinate this
change with other pending and anticipated updates to their billing systems to the greatest extent possible.
Staff also recommend that IOUs collect service line capacity (in amps) for customers and report this
information on customers' bills. This information is not readily available from IOUs currently, but would be
helpful for contractors and customers to understand the existing constraints/capacity of the service line and
find ways to work within this existing capacity. This information should b e tied to meter locations and
stored in a database. Such service line capacity data should be collected alongside when ever utility staff visit
customer premises for other purposes, such as meter inspections or if any on -site work needs to be
conducted.
The Commission has historically been strongly supportive of strategies and technologies to optimize
existing panels, with the end goal of reducing costs for customers interested in electrifying and reducing
upward pressure on rates. Facilitating the use of an alternative load calculation method that can more
accurately estimate existing loads and help avoid unnecessary panel and service upsizing helps to further
support the overarching goal of cost savings for ratepayers.
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4.2 Authorize IOU Evaluation of Non -Isolating Devices
Staff recommend that the IOUs begin using the existing safety and reliability evaluation process for
electrical isolation technologies adopted in Resolution E -5194 to evaluate other highly similar technologies
and devices that do not provide electrical isolation, but for which the existing evaluation process is
applicable from a technical perspective. It is expected that most, if not all, of the latter devices will likely be
MSAs, though the evaluation process for non -isolating technologies should remain neutral to specific
technology types. Staff also recommend that IOUs be authorized to use any remaining funding from the $3
million previously allocated across IOUs in D.21-01-018 for the recommended evaluation of non-isolating
technologies.
Providing a formal cost recovery pathway obligates the IOUs to evaluate non -electrical-isolating
technologies like (but not limited to) MSAs with expanded DER capabilities. This will add another useful
tool to a growing list of electrification strategies aimed at avoiding unnecessary panel and service upsizing
and saving customers and electric ratepayers money.
Expanding DER access via MSAs or other devices that may benefit from this evaluation process)
can also facilitate achieving the goals set out in the CPUC’s Distributed Energy Resources Action Plan 2.0,
which aims to ensure that DER policy implementation helps meet climate goals and is coordinated across
CPUC proceedings.63 That is, expanding DER access via MSAs, or other devices that may benefit from this
evaluation process, contributes simultaneously to the goals of several different CPUC proceedings and
processes, including Building Decarbonization, Transportation Electrification, High DER, Streamlining
Interconnection, Energization, and the Self-Generation Incentive Program.
63 See: https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M467/K470/467470758.PDF .
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5 Conclusion
Building decarbonization is an essential strategy to help California meet its goal of carbon neutrality
by 2045. Ensuring that all buildings in California switch to all-electric end uses will not be a cheap endeavor,
however. Ratepayers may have to cover substantial distribution system upgrade costs to meet the growing
electricity demand from the rapid electrification of buildings and vehicles. With electric rates climbing higher
each year, it is imperative that the CPUC seek to reduce any unnecessary costs in the push for building
decarbonization. Higher electric rates will discourage electrification by pushing up customer bills as they
move off gas and increase their electricity consumption. This has particularly detrimental impacts on low -
income households, who already spend a disproportionately large percentage of their income on energy
costs.
Helping customers avoid electrical panel and service upsizing has the dual benefit of reducing costs
of electrification to individual customers while also reducing utility spending (for service upsizing), which
reduces upward rate pressure. This proposal’s recommendations aim to support strategies that allow
customers to electrify their homes and vehicles within the existing capacities of their electrical panels and
electrical services. By providing customers with peak demand data that is readily available to IOUs, Staff aim
to make it easier for contractors to advise against panel and service upsizing. Additionally, expanding cost
recovery for IOUs to expand their approval process for MSAs and similar non -electrical isolating devices
can help add another “tool” in the toolkit of panel optimization strategies.
Electrification and the NEC
Background
Many cities, in their effort to address climate change are switching their electricity supply to be sourced from
renewable energy and at the same time, now that they have a fossil free source of energy, are embarking on
campaigns to electrify homes and businesses. This is a sound strategy as electric appliances are safer, more
efficient and economical to run over the long term. However, this switch to electricity will require that we
upgrade our grid to handle the extra loads. We will also need to better understand and update the National
Electric Code (NEC), which governs how electrical infrastructure is installed and updated in our homes and
businesses.
Of particular interest in the effort to electrify our homes is the main service panel that connects our home to the
local grid. As we switch out our gas appliances for electric ones, the question is, will the old main service panel
be able to safely handle the larger loads that will be required to accomplish this electrification effort or will a
main panel upgrade be required?
Main panel upgrades are expensive and when done along with other upgrades in the same area, will require the
utility to upgrade the local distribution network to handle the new loads. The NEC specifies the calculations
and methods used to determine the size of panels for new construction and for retrofits, such as the
electrification of existing homes. While good judicial choices for electric replacements of gas appliances can
avoid panel upgrades and reduce utility bills, there will still be a need for many panels to be upgraded.
Electrification
The issue here is that many people are installing larger panels to accommodate electrification than might be
needed and the NEC methods to determine this are very conservative. This in turn requires the Utility to
upgrade transformers and local distribution lines to accommodate these panel upgrades. I suspect that many
upgrades are probably not using the NEC calculation and are just over-sizing panels to avoid any problems in
the home. Even using the NEC calculations, historical data suggest that these calculations are very conservative
and that there is still a lot of headroom for more loads without overloading the panel. One study of 22,442
homes in California (PG&E territory) shows that:
- 98% of homes have peak power less than 88 amps
- 86% have peak loads less then 50 amps
- 48% have peak loads less then 30 amps
See graphs below:
Data from SMUD and Home Energy Analytics (PG&E territory)
Data from HEA (PG&E territory)
The NEC does allow historical data to be used to determine if a panel upgrade is needed, but this requires a
year’s worth of historical data (NEC 220.87), which might not be available in all jurisdictions (smart meters
required). Using historical data essentially allows the headroom shown above to avoid a panel upgrade and
possible local distribution line upgrades while still not overloading the panel. From the NEC code:
220.87 Determining Existing Loads
The calculation of a feeder or service load for existing installations shall be permitted to use actual maximum
demand to determine the existing load under all of the following conditions:
1. The maximum demand data is available for a 1-year period.
Exception: If the maximum demand data for a 1-year period is not available, the calculated load shall be
permitted to be based on the maximum demand (the highest average kilowatts reached and maintained
for a 15-minute interval) continuously recorded over a minimum 30-day period using a recording
ammeter or power meter connected to the highest loaded phase of the feeder or service, based on the
initial loading at the start of the recording. The recording shall reflect the maximum demand of the
feeder or service by being taken when the building or space is occupied and shall include by
measurement or calculation the larger of the heating or cooling equipment load, and other loads that may
be periodic in nature due to seasonal or similar conditions.
2. The maximum demand at 125 percent plus the new load does not exceed the ampacity of the feeder or
rating of the service.
3. The feeder has overcurrent protection in accordance with 240.4, and the service has overload protection
in accordance with 230.90.
Exception: If the feeder or service has any renewable energy system (i.e., solar photovoltaic systems or wind
electric systems) or employs any form of peak load shaving, this calculation method shall not be permitted
The two methods for panel loading are shown below in the following figure. This illustrates quite clearly along
with the other data presented that there is quite a bit of capacity in almost all main service panels that could be
used for electrification.
Recommendations
Careful examination of the NEC and how it is applied can lead to fewer panel upgrades without compromising
safety. Again, judicial choices of appliances (Amp Diet) can reduce or eliminate the need for a panel upgrade
in the first place. The use of smart panels such as the SPAN panel can also reduce panel upgrades and supply
the homeowner with a wealth of information on their energy use. Here are some recommendations on what we
can do now to help with electrification and avoid expensive panel upgrades:
1) Use the historical method (NEC 220.87) whenever possible in determining the size of the electrical panel that
is needed for your electrification project. This method more closely matches real world conditions and will
allow for greater loading of the main service panel while still maintaining safety margins.
There is an exception to this historical method that states if a renewable source of energy is connected to the
main service, then this historical method cannot be used. This should be changed to read: if a renewable energy
system (i.e. solar photovoltaic or wind system) or peak load shaving system (i.e. battery system that back feeds
the grid) is connected to the main service, then the maximum output of the system, calculated from the name
plate value, must be added to the maximum historical load to determine the size of the panel. This is in line
with item (2) in that same section (NEC 220.87) where new loads can be accounted for. This would allow for
the correct accounting of renewable energy systems that are part of an existing home in the load calculations.
This is important as renewable energy systems (i.e. solar) should be encouraged to help reduce the overall load
on the grid and should be accounted for correctly.
2) If one is not using the historical method for load calculations, make sure cities and utilities are requiring load
calculations for new (NEC 220.82) and upgrading of existing panels (NEC220.83) accordingly to avoid
unnecessary over-sizing. The calculations for new construction and existing upgrades are different, with
existing upgrades having a slight advantage so make sure the correct calculations are being used for each case.
If larger panels are required, then charge fees appropriately for these panel upgrades. This will also help to
detour unnecessary (lazy electricians that don’t want to do the calculations) over-sizing and help pay for utility
upgrades. This could also encourage the use of load managing devices like the SPAN panel, and the application
of Amp Diets to reduce loads.
3) Circuit sharing devices can also be used to reduce the loading on the main service panel. For example, using
one of these devices allows a dryer and an EV charger to share the same circuit while only requiring one
connection to the main service panel and thereby only adding one 30-amp 240-volt load to the calculations.
4) Since EV charging can be the largest load, EV owners should be encouraged to install and set EV charging at
20 or 25 amps max. An overnight charge (8 hours) with a 25 amp breaker will give the average EV a range of
115 miles, which is more then twice the daily commute average.
For future consideration
Update the load calculations (NEC 220.83) to more closely match what is being seen in real life. There is
clearly a lot of room for improvement here. The loads per square foot is currently calculated at 3 watts per
square foot. This is to account for lighting and plug loads. With the advent of LEDs and the increased
efficiency of plug load items, this number needs to be adjusted downward to better reflect real world loads. If
this number represented lighting only, this could safely be cut in half.
Another update to this calculation, is implied in the 120% rule for bus bars in a panel, (paraphrased here): when
adding a renewable energy system (solar), the main panel bus bar can be safely operated at 120% of the rated
capacity. If this is true, then we should be able to use this in our calculations for main panel loading and
increase the capacity to 120% of the panels rating. This would mean that a 100 amp rated panel can safely
handle 120 amps of load as calculated in article 220.83. In looking at the historical data, we can see that there is
still quite a margin of safety here as most actual loading is much less then this.
Conclusion
While it can take years to realize changes in the NEC, there are some things that can be done now to help with
electrification while following the existing NEC requirements. Using the allowed historical load calculations
will go a long way in helping to realize electrification and avoid costly upgrades. This is only available where
smart meters are in use to collect this data. There are some changes that should be easier to implement such as
the correct accounting for renewable energy systems in the historical calculations and perhaps the 120% load
allowances implied by the 120% rule. Other changes that will update the accounting for light and plug loads
will probably take longer as well as accounting correctly for coincident loads (heating or cooling loads, but not
both at once). The easier changes should be addressed ASAP or allowed by local jurisdictions as climate
change is not waiting for the next two or three code cycles (three years per cycle) to happen. The historical data
supports such changes and should there be any problems the main breaker will keep things safe.
David Coale
Carbon Free Palo Alto