HomeMy WebLinkAbout2025-10-17 Climate Action and Sustainability Committee Agenda PacketCLIMATE ACTION AND SUSTAINABILITY COMMITTEE
Special Meeting
Friday, October 17, 2025
Community Meeting Room & Hybrid
2:00 PM
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1 October 17, 2025
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CALL TO ORDER
PUBLIC COMMENT
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STANDING VERBAL REPORTS
A.Staff Comments
B.Committee Member Comments and Announcements
ACTION ITEMS
1.Recommendation to the City Council to Approve the Advanced Commercial Heat
Pump HVAC Program Design Guidelines; CEQA Status -– Categorically Exempt
Under CEQA Guidelines Section 153021 (Replacement of Existing Facilities),
Replacement of Existing Rooftop HVAC Units with Heat Pumps is Categorically
Exempt
2.Discussion of Preliminary Analysis of the Infrastructure Impacts Associated with
Gas Decommissioning; CEQA Status - Not a Project
FUTURE MEETINGS AND AGENDAS
Members of the public may not speak to the item(s)
ADJOURNMENT
2 October 17, 2025
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PUBLIC COMMENT INSTRUCTIONS
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3 October 17, 2025
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4 October 17, 2025
Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas.
Climate Action and Sustainability Committee
Staff Report
Report Type: ACTION ITEMS
Lead Department: City Clerk
Meeting Date: October 17, 2025
Report #:2510-5274
TITLE
Recommendation to the City Council to Approve the Advanced Commercial Heat Pump HVAC
Program Design Guidelines; CEQA Status -– Categorically Exempt Under CEQA Guidelines
Section 153021 (Replacement of Existing Facilities), Replacement of Existing Rooftop HVAC
Units with Heat Pumps is Categorically Exempt
This will be a late packet report published on October 9, 2025.
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Climate Action and Sustainability Committee
Staff Report
Report Type: ACTION ITEMS
Lead Department: City Clerk
Meeting Date: October 17, 2025
Report #:2510-5275
TITLE
Discussion of Preliminary Analysis of the Infrastructure Impacts Associated with Gas
Decommissioning; CEQA Status - Not a Project
This will be a late packet report published on October 9, 2025.
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Item 2 Staff Report
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Climate Action and Sustainability Committee
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Public Works
Meeting Date: October 17, 2025
Report #:2507-5024
TITLE
Recommendation to the City Council to Approve the Advanced Commercial Heat Pump HVAC
Program Design Guidelines; CEQA Status – Categorically Exempt Under CEQA Guidelines Section
15302 (Replacement of Existing Facilities)
RECOMMENDATION
Staff recommends that the Climate Action and Sustainability Committee recommend the City
Council approve the Advanced Commercial Heat Pump HVAC Pilot Program Design Guidelines.
EXECUTIVE SUMMARY
As part of the City’s Sustainability and Climate Action Plan (S/CAP), staff launched a pilot
program in summer 2024 to encourage commercial customers to replace gas-fired packaged
HVAC units with electric heat pump HVAC systems.1 To date, 14 customers have enrolled in the
pilot, six projects have secured permits, and three projects have been completed.
Preliminary results confirm that heat pump replacements are technically feasible and ranged
from an 18% savings in up-front cost to a 40% additional cost compared to like-for-like gas
system replacements. When there is additional cost, voluntary adoption can be difficult without
financing options. Early projects also highlighted permitting challenges that add to overall
project costs and complexity. While these requirements are necessary for safety and
compliance, they can discourage voluntary adoption. A study of non-residential building
equipment performed by a City consultant indicated heat pump replacements may result in bill
savings, but this is yet to be confirmed by the projects in progress.
Building on these lessons, staff proposes an Advanced Commercial Heat Pump HVAC (HPHVAC)
Pilot Program. The goal of the program would be to replace direct incentives with scalable
financing options while providing optional technical assistance. The program is designed to
1 https://www.paloalto.gov/Departments/Utilities/Electrification/Business-Electrification/Commercial-Heat-Pump-
HVAC-Program
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reduce barriers to adoption while maintaining compliance with all applicable permitting
requirements.
BACKGROUND
The City’s S/CAP identifies building electrification as a primary strategy for achieving
community-wide greenhouse gas (GHG) reductions. Commercial buildings account for 16% of
the City’s total natural gas use, with packaged HVAC units representing about 70% of
commercial space-heating systems.
In summer 2024, staff introduced a pilot program to incentivize early adoption of heat pump
HVAC systems funded by up to $1.2 million in Public Benefits (Research and Development)
funding. Incentives were temporarily increased for the first 10 complete projects. The program
was designed to generate cost and performance data, inform customer decision-making, and
identify barriers to broader adoption.
Results to date show:
14 customers enrolled in the pilot
6 projects permitted
3 projects completed
While technically successful, the pilot demonstrated that incremental costs remain a major
adoption barrier for property owners. On average, cost estimates for electric heat pump HVAC
systems were approximately 22% higher than comparable gas system quotes, ranging from 18%
below to 40% higher. Among the three completed projects, the average increase in final cost
relative to the initial estimate for electric heat pump HVAC installations was $34,024, and the
average project cost was $244,751. The average price per ton for the installed heat pump HVAC
units was $9,819.
Contractor and customer feedback further indicated that, outside of the program, many
customers replacing gas packaged HVAC units do not obtain permits.
Permitting requirements identified through the pilot included:
Structural engineering studies on roof integrity for rooftop units.
Sound studies to demonstrate compliance with noise standards.
Visual screening/line-of-sight reviews.
Fire Department permits, including hazardous materials documentation and equipment
labeling.
Because participation in the pilot required securing all necessary permits, this added an average
of $3,118 in permit costs plus a variable amount of cost in consulting and contractor fees to
comply, sometimes in the tens of thousands of dollars. Since only three participants in the
program have completed projects so far, staff has limited data points. One community member
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was quoted over $10,000 to complete a sound study, while another completed the study for a
negligible increase to their overall project quote. One community member incurred a $5,000
cost for hazardous materials services. Another was looking at potential increases of over
$10,000 related to roof structural calculations related to the HVAC roof attachment method.
Staff is continuing to gather information on how these additional consulting and engineering
services needs increase project costs, and ways to help community members comply at lower
cost. These requirements are necessary to ensure safety, compliance, and community
standards, but the additional project costs and time can sometimes create uncertainty and
frustration for customers. Two customers withdrew from the program due to the cost and
permitting requirements, despite the enhanced rebates.
ANALYSIS
Staff drew on its experience with the current HVAC enhanced rebate program,3 research done
as part of the S/CAP Funding Study and corresponding Non-Residential Building Sector Study
(which are not yet final), and some interviews (participants, contractors, a financing provider,
and a consultant) as detailed in the Stakeholder Engagement section below, to develop the
Program Design Guidelines for the Advanced Commercial Heat Pump Heating, Ventilation, and
Cooling (HVAC) Pilot Program (Program Design Guidelines) in Attachment A. Staff has learned
from its existing program how to navigate the permitting process and the associated costs. The
studies gave staff indications that packaged space heating electrification should provide long-
term utility bill savings. In the participant and business partner interviews, staff found potential
interest in financing, particularly on-bill financing, and especially if it enabled the cost of
improvements that benefit tenants to be passed through to them based on the bill savings they
would realize.
Customers consistently noted that they would not have been able to pursue these projects
without the boosted incentive, underscoring the importance of strong financial support for
large-scale upgrades. They noted the short payback period needed for a property investor to do
these projects. They also appreciated the technical guidance provided by the third-party
electrification engineering consultant, Prospect Silicon Valley, highlighting the value of ongoing
technical assistance for complex projects such as heat pump HVAC. In addition, customers
valued the hands-on support and direct communication offered by Utilities and Planning and
Development Services staff on permitting matters, which further facilitated successful project
completion.
3 https://www.paloalto.gov/Departments/Utilities/Electrification/Business-Electrification/Commercial-Heat-Pump-
HVAC-Program
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The Program Design Guidelines generally address the following topics:
Financing and Incentives
One of the main challenges in the non-residential sector is the short payback period (2-4 years)
required by most private investors before making a building or energy investment. Based on
staff modeling using information from the S/CAP Funding Study and Non-Residential Building
Sector Study (not yet final), the payback period for electrification of packaged HVAC units that
cost 10% to 15% more than gas units would be 12 to 17 years. This means that even though
these projects potentially provide a net benefit, they will not get done without some assistance.
To date, staff has primarily used incentives. Incentives work if they are high enough, but high
incentives are not a scalable solution for electrifying all of Palo Alto’s packaged HVAC units. In
an Advanced HVAC Pilot Program staff would explore other approaches, primarily financing
with on-bill repayment. Staff is in talks with a potential provider and has built the functionality
in its billing system for on-bill repayment. Building owners prefer on-bill repayment, which they
treat as an operating expense. They may be more willing to engage with this type of financing
than traditional financing.
Building owners also hesitate to make significant energy investments that save money for their
tenants rather than themselves. Staff is exploring a potential tool called “electrification as a
service” to address this. Modeled on “efficiency as a service” programs some energy efficiency
companies run, an “electrification as a service” feature would involve the customer repaying
some or all of the financing provided by the City or a 3rd party with a charge that does not
exceed their utility bill savings. This may enable the placement of the charge on commercial
tenant utility bills, with the right agreements in place, enabling the recovery of some of the
costs for energy improvements from tenants, who experience utility bill reductions as a result.
Funding sources and program structure are still being explored, though as noted in the Fiscal
Impact section, some money is set aside for a program like this from Gas Cap and Trade
revenues in the FY 2026 budget.
These financing and “as a service” features, if feasible, may lead to more financially efficient,
attractive commercial energy programs, that minimize the use of incentive funding.
Technical Assistance
The technical assistance envisioned for the Advanced Commercial HPHVAC Pilot Program is
similar to that provided in the existing HP HVAC Pilot Program. These services included:
Evaluating electrification project designs, including conducting preliminary reviews of
project designs for Heat Pump HVAC installations and performing limited design checks
on equipment, engineering plans, and project specifications.
Providing electrification technical guidance, including offering non-biased, expert
technical advice to CPAU commercial customers and validating equipment selections to
ensure projects meet technical standards.
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Providing electrification cost guidance, including performing savings calculations and
general project cost evaluations, assessing financial feasibility, and providing cost
insights for customer projects.
The consultant, Prospect Silicon Valley, provided electrification technical advisory services to
three commercial customers to support their Heat Pump HVAC projects. Without the
consultant’s guidance, these projects would likely have been delayed for years, potentially
causing the customers to miss rebate opportunities or drop out of the program entirely.
To support the successful adoption of commercial Heat Pump HVAC projects, there is also a
clear interest in some form of assistance finding qualified contractors. The guidelines envision
some form of complementary contractor list, and possibly even providing services to
contractors, such as the ability to use a City financing program or a contact for trying to
understand common permitting pitfalls.
Permit Assistance and Streamlining
Early projects in the current enhanced rebate HVAC pilot have highlighted several permitting-
related challenges that informed the design guidelines and will inform program design:
Many gas-for-gas replacements proceed without permits, avoiding compliance costs
that are unavoidable for heat pump projects participating in a City program.
Noise reports are required for all projects (per PAMC 18.42.190(B)(iii)). Equipment must
be no louder than 15 dB above local ambient noise levels at 25 feet. Hiring an acoustical
engineer can cost thousands of dollars and adds time to the overall project timeline.
Structural engineering analysis is required for all rooftop packaged HVAC projects. These
studies incur a cost and sometimes trigger additional work that needs to be completed
for safety reasons.
Screening requirements add cost, and may result in additional roofing loads, which
could then incur the cost of a roof structural analysis. If a roof upgrade is required, that
can be prohibitively costly and can stop a project.
Fire Department requirements related to HVAC and hazardous materials permits,
equipment labeling, and integration with fire alarm systems need more communication
to applicants up front.
Planning and Development Services and the Fire Department have been active in helping the
Climate Action Team understand permitting requirements and discussing potential approaches
to ease compliance costs and workload.
FISCAL/RESOURCE IMPACT
$1.1 million was approved in the FY 2026 budget5 for the Advanced Commercial HPHVAC Pilot
Program, funded by Gas Cap and Trade revenues, which will support incentives if needed,
5 https://www.paloalto.gov/Departments/Administrative-Services/City-Budget
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outreach, technical assistance, and 3rd party program operation. Launch and operation of the
program is expected to require approximately 0.75 FTE, which will be performed by existing
staff and will include program design and operation, outreach, customer care, and
establishment and operation of a financing and on-bill repayment program if implemented.
Staff will continue to explore opportunities to leverage State and Federal funds if available.
STAKEHOLDER ENGAGEMENT
Staff engaged with pilot program participants, HVAC contractors, property managers, and
lenders to inform program design. Key feedback highlighted the need for financing options,
accessible technical expertise, and contractor familiarity with permitting processes. Detailed
notes from the program are included in Attachment B. Staff will meet with the Climate Action
Working Group in advance of the CASC meeting and will share feedback at that meeting.
Further stakeholder engagement will be needed as staff develops more detailed program
designs.
ENVIRONMENTAL REVIEW
The proposed program is categorically exempt from the California Environmental Quality Act
(CEQA) under CEQA Guidelines section 15302 (Replacement of Existing Facilities). Replacement
of existing HVAC equipment with more efficient units constitutes a minor alteration to existing
facilities and is consistent with the S/CAP adopted in June 20237 and Comprehensive Plan
adopted in November 2017.8
ATTACHMENTS
Attachment A: Design Guidelines for Advanced Commercial Heat Pump HVAC Program
Attachment B: Summary of Results To-Date from HVAC Enhanced Rebate Pilot Program
APPROVED BY:
Brad Eggleston, Director Public Works/City Engineer
7 https://www.paloalto.gov/City-Hall/Sustainability/SCAP
8 https://www.paloalto.gov/Departments/Planning-Development-Services/Housing-Policies-Projects/2030-
Comprehensive-Plan
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Program Design Guidelines for Advanced Heating, Ventilation, and Cooling
(HVAC) Pilot Program
These design guidelines are meant to guide development of a financially accessible
Advanced Packaged HVAC Pilot Program for non-residential customers.
Program goals and scope
The program should:
1. Ease electrification of non-residential packaged HVAC units
2. Pilot financial designs that can be deployed community-wide with little or no additional
funding from the City
3. Enable participation by a wide range of contractors, building types, and landlord-tenant
arrangements for payment of energy bills
4. Address landlord/tenant split incentives while being economically attractive to both
landlords and tenants
Program financial design
To ensure the program is cost-effective, legally viable, and scalable:
1. It should provide financing rather than up-front incentives, and ideally financing that
will encumber a property owner’s balance sheet as little as is feasible, such as on-bill
repayment out of utility bill savings
2. Financial incentives may be offered only if legally appropriate and available, and are
intended to be offered on a temporary basis.
3. Repayment of any financing offered should come from those who benefit, which could
include both tenants and landlords
4. Should not increase tenant utility bills
5. Should be accessible to a range of contractors
6. Should incorporate risk management measures to control risks to the City
Program technical design
To keep program costs lower and easier for participants, staff should explore:
1. Streamlining of permit processes
2. Technical and permitting assistance for participants
3. Contractor training on program rules and operation
4. A courtesy contractor list
Item 1.
Attachment A - Design
Guidelines for Advanced
Commercial Heat Pump
HVAC Program
Item 1.: Staff Report Pg. 7 Packet Pg. 13 of 27
Commercial Heat Pump HVAC Program Update
September 16, 2025
Current Enrollment
As of September 16, 2025, a total of 14 customers applied for the Commercial Heat Pump HVAC Pilot
program. Applicants have primarily learned about the pilot through the Business Electrification Technical
Assistance Program, the Business Customer Rebate Program website, and the Commercial and Industrial
Energy Efficiency Program.
Customers become eligible for rebate approval only after submitting all required documentation and
securing an approved permit. Of the 14 applicants, seven have initiated the permitting process with the
City, and six have received their permits. One customer has received their permit but has not submitted
project cost estimates, resulting in only five customers being officially approved at this stage.
To date, three customers have completed installations and received program rebates. Detailed project
information for these installations is provided in a subsequent section of this report. Two participants
have unenrolled from the program. In one case, a customer required an emergency replacement and
proceeded with equipment available through their contractor, which did not meet the program’s
efficiency requirements. In the second case, permitting requirements significantly increased project
costs, approximately doubling the original estimate, leading the customer to withdraw. Table 1 provides
a summary of the status and progression of all pilot participants.
Table 1. Current Program Participation for the Commercial Heat Pump HVAC Program
Cost Analysis
Item 1.
Attachment B - Summary of
Results To-Date from HVAC
Enhanced Rebate Pilot
Program
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The tables below address the current cost comparisons between project estimates, project costs, and
rebate amounts. Table 2 compares heat pump HVAC quotes and gas quotes received from 10 customers
against project cost estimates developed by Peninsula Clean Energy (PCE) in its 2021 commercial
electrification analysis. PCE’s estimates were based on average equipment and labor costs at the time,
calculated per ton across three equipment size categories: less than 5 tons, 5–10 tons, and 15–20 tons.
On average, heat pump HVAC project estimates were 21.8% higher than gas quotes.
Table 2. Heat Pump HVAC Project Estimate Comparison Between Gas, Electric Heat Pump, and Peninsula
Clean Energy Predicted Costs
Project 2 High Quotes Explained:
• $6,980 out of the total cost is related to a heat pump water heater, meaning part of the total
project estimate was associated with another project this customer plans to do simultaneously.
• The address has a split system (one condenser and four heating units spread through the
building) serving the downstairs and it requires more ducting and equipment.
o The upstairs units use existing ducting, which is lower cost, because they are replacing a
gas rooftop unit (RTU) with a heat pump packaged unit
Project 5 Quotes Explained:
This customer’s total project cost is significantly higher than usual for a project like this. This is because
this customer redid their ducting and piping, which also resulted in added carpentry and painting costs.
They also had additional electrical work done.
• This is the percentage split cost breakdown of the $541,000 project total.
o Carpentry, painting and electrical 21%
o Equipment (condensers outdoor units and fan coils with new stats) 13%
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Attachment B - Summary of
Results To-Date from HVAC
Enhanced Rebate Pilot
Program
Item 1.: Staff Report Pg. 9 Packet Pg. 15 of 27
o Piping (drain pans, condensate piping and hard copper piping for long runs) Labor and
material 28%
o HVAC & Refrigerant (line sets, refrigerant and duct connections, including new plenums)
Labor and material 37%
Project 8 Low Gas Quote Explained:
This participant did not address the cost differential in his documentation. The contractor who provided
him with these quotes has been unresponsive, so he is now going to reach out to a new potential
contractor to receive new quotes.
Project 10 Quotes Explained:
This participant’s higher heat pump HVAC quote reflects several factors: higher equipment and material
costs compared to the gas alternative, additional work such as line setting, conduit, and breaker
installation, and higher anticipated permitting expenses. In contrast, the gas quote did not account for
replacement of the AC units. If those costs had been included, the “like-for-like” comparison would have
been closer.
Completed Project Details
As of September 16, 2025, three customers have fully completed their projects. Table 3-5 highlights the
cost comparison between these customer’s initial quote, final project cost, and rebate paid.
Table 3. Dollar Comparison Between Project #1’s Quote, Project Cost, and Rebate
Please note that this customer’s total project cost is less than the original price estimate received in the
quote because the customer negotiated a lower cost when hiring the contractor to work on multiple
projects at once. The City’s rebate covered 96% of this customer’s project cost.
Item 1.
Attachment B - Summary of
Results To-Date from HVAC
Enhanced Rebate Pilot
Program
Item 1.: Staff Report Pg. 10 Packet Pg. 16 of 27
Table 4. Dollar Comparison Between Project #5’s Quote, Project Cost, and Rebate
This customer’s costs increased from the original quote due to added work by the contractor and
permitting costs, which were $1,268.90. The City’s rebate covered 17% of this customer’s project cost.
Table 5. Dollar Comparison Between Project #7’s Quote, Project Cost, and Rebate
This customer’s total project cost was higher due to the addition of a phase 2 to their project and the
$1,437.84 permit fee. This addition came after the quotes were processed and phase 1 was completed.
Item 1.
Attachment B - Summary of
Results To-Date from HVAC
Enhanced Rebate Pilot
Program
Item 1.: Staff Report Pg. 11 Packet Pg. 17 of 27
The reason for their decision to replace another unit was due to the increased rebates offered by CPAU
and the ease of completing phase 1. Due to the added unit on this project, their rebate came out to be
$43,750, which covered 67% of their total project cost.
Installation Location for HP HVAC Equipment
At this time, we do not have complete data on the installation locations of the heat pump HVAC
equipment for all applicants. Among those who have submitted site plans or permit information, four
projects consist of rooftop HVAC units. Due to the structure of the rooftop, three projects are ground-
level installations. The installation location for the remaining 6 active participants is currently unknown.
It is also possible that some customers may install equipment in both rooftop and ground locations, but
this has not been confirmed. Table 6 below summarizes the number of customers in each category.
Table 6. Locations of Installed Heat Pump HVAC Equipment
Summary of Permitting Comments
As of September 15, 2025, 7 customers have applied for the commercial heat pump HVAC permit
through the City’s Planning and Development Services (PDS) Department. Here is a consolidated list of
corrective comments provided to the customers and their contractors from the City’s PDS Department.
Many customers who participated in the pilot program received similar feedback on their permit
submissions. Learning about these recurring comments help us understand where there are gaps in
permitting instructions and opportunities on where we can smooth out the process for customers.
When submitting plans, PDS wants all details to be accurate and documentation to be complete,
including manufacturer’s specs that match the project plan details, showing where equipment and
electrical panels will be located, and clearly labeling the mechanical and electrical scope. Plans must
show property lines and setbacks. For rooftop equipment, engineers need to confirm the roof can
Item 1.
Attachment B - Summary of
Results To-Date from HVAC
Enhanced Rebate Pilot
Program
Item 1.: Staff Report Pg. 12 Packet Pg. 18 of 27
handle the added weight, show how it will be anchored, and provide details on ductwork, drains, and
demolition. Wood blocks (sleepers) aren’t allowed unless fully roofed over.
The City also checks for noise and safety. Equipment must meet local noise limits, and an acoustical
engineer’s report or post-installation testing is required. Fire safety permits are needed for both
refrigerant removal and installation, and the Fire Department requires notes on the plans and how the
HVAC system connects with the fire system in the building. A special inspection form must also be
submitted, listing contractors, agencies, and required safety checks. Overall, the City’s goal is to make
sure projects are well-documented, safe, and considerate of the community.
Based on the permitting requirements outlined above, some customers were able to provide details on
the additional costs some of these requirements added to their projects. For the structural analysis, one
customer’s initial cost for this study was around $25,000. There is a possibility there will be an added
cost of $12,000-$15,000 if the City’s PDS requires additional analysis for the curbs. For the HazMat
permitting, one customer was quoted $5,000. This is not confirmed though, since the customer hasn’t
completed this portion of the permit yet. There has been mixed feedback on the added cost for the
sound engineering analysis. One customer was told the cost would be “insignificant.” On the other hand,
another customer was quoted $10,000-$12,000. It has been challenging to pinpoint the exact cost of
each study because most engineers group the costs in the final invoice. We are waiting for more
feedback on these items as projects move forward.
Item 1.
Attachment B - Summary of
Results To-Date from HVAC
Enhanced Rebate Pilot
Program
Item 1.: Staff Report Pg. 13 Packet Pg. 19 of 27
Climate Action and Sustainability Committee
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Public Works
Meeting Date: October 17, 2025
Report #:2507-5022
TITLE
Discussion of Preliminary Analysis of the Infrastructure Impacts Associated with Gas
Decommissioning; CEQA Status - Not a Project
RECOMMENDATION
This is a discussion item and no recommendation is requested. Staff is briefing the Climate
Action and Sustainability Committee (CASC) on preliminary results from the Gas Transition
Study to hear questions from the CASC that could inform future work on the analysis and to
provide information that could inform S/CAP work planning and financial planning efforts.
EXECUTIVE SUMMARY
Achieving the community’s greenhouse gas emissions reductions goals requires extensive
reductions in building emissions. Regardless of how quickly the community reaches these goals,
impacts on the gas utility’s financial structure and physical operations are expected. Staff is
studying those impacts. Item 5.D. in the S/CAP workplan, “Gas Utility Financial and Operating
Plan”, seeks to develop a financial and operating plan for declining gas utility sales that
maintains safety and solvency while providing affordable gas service to remaining gas uses. The
study will simulate different patterns of electrification throughout Palo Alto, identify
opportunities for gas main and service abandonment and operational efficiencies, and estimate
abandonment costs, changes in operational costs, and customer class cost allocations. It will
prioritize gas system safety and identify parts of the gas system that may need to be retained
for operational reasons even after substantial parts of the system have electrified. Staff is
sharing preliminary results from the first part of the Gas Transition Study with the CASC so staff
can adjust course as needed as they work to complete the study.
Item 2.
Item 2 Late Packet Report
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BACKGROUND
Staff reviewed the methodology for this analysis with the CASC at its June 13, 2025 meeting1
and with the Utilities Advisory Commission (UAC) at its September 3, 2025 meeting. The study
involves multiple steps:
1. Build a system model for the gas utility to evaluate the system effects of gas main
removal. This step was completed in April 2025.
2. Develop a model of which homes are connected to which mains and estimating what
equipment is in each home based on gas consumption. This step is complete.
3. Simulate different levels of electrification and identifying the number of mains that can
be abandoned and validate using the gas system model.
4. Categorize costs by how they decline, based on declining gas sales, gas meter
disconnections, and gas main abandonment then estimate the impact of varying levels
of electrification on gas utility costs, other utility costs, and General Fund costs.
5. Evaluate impacts on customer groups and identify any groups that could be especially
impacted in the transition without careful planning.
6. Identify potential mitigations to any issues the analysis above identifies.
The scenarios to be analyzed include the following levels of electrification:
Scenario
Gas
Sales
Reduction
Residential
Space and Water
Heating
Electrification
Small and Medium Non-
Residential Space and
Water Heating
Electrification
Medical and
Industrial
Electrification*
1 20%25%25%0%
2 40%50%50%0%
3 60%75%75%0%
4 80%100%100%0%
* In practice, some electrification will occur in this sector, but staff does not have good
visibility on the potential for electrification in this space due to the prevalence of unique /
process loads
Staff already completed phases one and two of the methodology (develop a gas model and
estimate type of equipment in each home) and is currently completing phases three and four,
simulating different levels of electrification and evaluating the impact on gas utility costs.
1 Climate Action and Sustainability Committee, June 13, 2025, Discussion of Gas Utility Transition Study Scoping,
https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=8207&meetingTemplateType=2&compil
edMeetingDocumentId=14791
Item 2.
Item 2 Late Packet Report
Item 2.: Staff Report Pg. 2 Packet Pg. 21 of 27
ANALYSIS
The City’s consultant, Energeia, presented some preliminary results of study phases 2 and 3
(estimating gas equipment in each home and simulating different levels of electrification) in late
August. Attachment A shows estimated quantities of gas equipment in single family homes and
multi-family buildings based on gas usage. The preliminary results estimated 96% of single-
family homes had at least one major gas appliance. About 85% of single-family water heating
and 81% of single-family space heating is estimated to be gas-driven. About 61% of water
heating and 50% of space heating equipment in multi-family buildings is estimated to use gas.
This aligns with preliminary expectations in the process of community electrification, but these
numbers will likely change as results are reviewed in more detail and any data errors or
omissions are identified and fixed.
Using these estimates the consultant simulated the levels of electrification included in the
methodology. The consultant’s simulation found, preliminarily, that as electrification increased
to the point that gas use was reduced 20% and 40% (which represents about 25% and 50%
electrification of residential buildings and commercial buildings excluding medical and
industrial), only a few mains could be abandoned. At 60% reduction in gas use, only about 10%
of mains could be abandoned. Opportunities for gas main abandonment began to increase as
reduction in gas use stepped from 60% to 80% (75% to 100% electrification of residential and
commercial buildings excluding medical and industrial), with the number of mains eligible for
abandonment increasing from 10% to 90%. At 80% gas use reduction, about 90% of residential
mains were eligible for abandonment and most commercial area mains could be abandoned as
well, leaving a small amount of infrastructure available for medical and industrial customers.
These results are preliminary and this scenario is still being modeled in more detail.
One key insight is that significant electrification and reductions in gas sales could take place
before the cost reductions associated with abandoned mains are realized. As noted below,
though, only about 40% of gas utility costs decline as gas mains are abandoned, so the rate
impact will be limited to rate impacts associated with this portion of costs. In the next phase of
the study staff will estimate the scale of potential rate impacts from this disparity between
declines in sales and declines in costs. Staff will also refine the underlying simulations and
develop tables to provide more detailed insights.
A high-level overview of the assumptions and methodology behind the preliminary analysis is
included in Attachment A.
Staff has also begun phase four of the study, identifying which types of costs are expected to
decline based on usage and which costs would require gas main abandonment to decline. A list
of these costs is included in Attachment A. Gas supply, gas transmission, and environmental
charges decline with the number of units of gas sold, as do demand side management (gas
efficiency) and the General Fund transfer. Customer Service costs will eventually decline with
gas disconnections. All of these costs together represent about 60% of the gas utility’s total
Item 2.
Item 2 Late Packet Report
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costs. Other gas distribution costs, which represent the remaining 40% of the gas utility’s costs,
do not decline with declining sales or customer disconnections. Nearly all gas distribution costs
require gas main abandonment before they can be reduced, and they do not necessarily decline
linearly. Attachment A includes a table showing all the different cost categories and how they
decline.
FISCAL/RESOURCE IMPACT
Staff’s takeaway from these two sets of insights is that there are likely to be times during the
gas transition when sales have decreased faster than costs, which could put upward pressure
on rates if not managed properly. Solutions are needed to manage gas utility rates in the early
and middle stages of electrification, which may include new revenue sources or taxes.
Determining feasible and legal alternatives will be an important part of the next phase of work
in 2026 as the Gas Transition Study is continued. In addition, staff will need to evaluate whether
any customer classes experience disproportionate impacts and ensure solutions address those
issues. And lastly, the study will need to estimate potential impacts on income-qualified
customers as well. Special utility revenue sources like Gas Cap and Trade, Electric Cap and
Trade, and Gas and Electric Public Benefits are likely insufficient to manage the gas rate impacts
even if this use aligns with the regulatory requirements.
Preliminary S/CAP Funding Study data3 (presented at the April 4, 2025 CASC meeting) showed
that there are some scenarios in which community benefits from electrification would exceed
community costs, including lost gas revenue. Staff and its consultants will complete more
detailed estimates of the cost and revenue impacts to the gas utility at various levels of
electrification as part of the Gas Transition Study. Staff plans to estimate the cost impacts of
various levels of electrification and the impact on various customer classes in the coming
months and will return to the UAC and CASC in early 2026 with the results and a list of potential
mitigations for any impacts as part of the Gas Transition Study.
The study is still in progress, but staff estimates total cost of $150,000 in consulting services
($60,000 for building a gas model and $90,000 for rate analysis and scenario simulation) and
about 0.3 FTE in staff time (0.15 FTE from Utilities Water-Gas-Wastewater Engineering and 0.15
FTE from the Utilities Resource Management Division and the Climate Action Team combined).
3 Climate Action and Sustainability Committee, April 4, 2025, Discussion of Preliminary Sustainability and Climate A
ction Plan (S/CAP) Funding Study Results, https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?i
d=7672&meetingTemplateType=2&compiledMeetingDocumentId=13682
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Item 2 Late Packet Report
Item 2.: Staff Report Pg. 4 Packet Pg. 23 of 27
STAKEHOLDER ENGAGEMENT
This topic was discussed by the UAC at its November 20205 and January 20216 meetings, and
since then the need to more carefully assess the costs of transitioning the gas utility has been
raised in several meetings of the UAC, S/CAP climate stakeholders, the Council subcommittees
focused on climate contexts, and at City Council.
The UAC discussed these preliminary results at its October 1, 2025 meeting. Commissioners
found the preliminary findings to be validating of their insight expressed at previous meetings
that it would be challenging to get whole blocks to disconnect. There was a request to include
an 80% gas sales reduction scenario done using a Monte Carlo simulation of gas disconnection
rather than just setting residential and small and medium non-residential equipment
electrification rates to 100%. There was appreciation expressed for the clarification that 60% of
gas utility costs would decline with sales, that only 40% was fixed, but also a request to model
those percentages under different gas price assumptions, since commodity prices fluctuate.
They also asked questions about current rates of electrification and future plans to accelerate
electrification. One Commissioner asked that there be eventual consideration of the pros and
cons of trying to sell the gas utility as an option for controlling the potential impact on gas rates
of high levels of electrification. Commissioners provided feedback on how to communicate
some of the insights more effectively.
ENVIRONMENTAL REVIEW
The CASC’s discussion of this topic does not meet the California Environmental Quality Act’s
definition of a project, pursuant to Public Resources Code Section 21065, and no environmental
review is required.
ATTACHMENTS
Attachment A: Assumptions, Methodology, and Preliminary Key Results from Gas Transition
Study Currently in Progress
APPROVED BY:
Brad Eggleston, Director Public Works/City Engineer
5 Staff Report ID#11639, November 4, 2020, Discussion of Electrification Cost and Staffing Impacts on the City of Pa
lo Alto's Electric and Gas Distribution Systems, http://cityofpaloalto.org/civicax/filebank/blobdload.aspx?BlobID=7
8897
6 Staff Report ID#11751, January 6, 2021, Discussion of Projected Electrification Impacts on Gas Utility System
Average Rates, https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-
reports/agendasminutes/utilities-advisory-commission/archived-agenda-and-minutes/agendas-and-minutes-
2021/01-06-2021special/01-06-21-uac-item-1.pdf
Item 2.
Item 2 Late Packet Report
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Attachment A
Assumptions, Methodology, and Preliminary Key Results from Gas
Transition Study Currently in Progress
This attachment gives a high-level overview of various inputs, estimates, assumptions,
methodological detail, and some key preliminary results for the Gas Transition Study.
Estimated Quantities of Gas Equipment in Single-Family Homes Based on Gas Use
Staff’s consultant, Energeia, used anonymized gas usage information from all homes and
businesses in Palo Alto to estimate what gas equipment was in the homes. Seasonal usage
patterns were used to estimate water heating and space heating gas use. Other data used
included home sizes and whether the County Assessor’s data for the parcel noted a pool.
Multi-family building equipment was estimated by looking at the combined gas use for the
entire building, including the house accounts, to determine whether space and water
heating equipment was centrally located or in units and whether that equipment was gas
or electric. Equipment in commercial buildings was not estimated, but basic estimates of
how much gas was used for space heating vs. water heating were created.
Based on that information the following very preliminary estimates for populations of gas
equipment were generated. Note that the total number of single-family and multi-family
units identified are a bit lower than would be expected based on other sources, indicating
the need to review the underlying inputs for missing data. Note that multi-family gas
equipment accounts are expected to be significantly lower than the number of multi-family
units in Palo Alto, since many apartment units do not have dedicated gas meters, having
electric or central gas space heating and central gas water heating.
Equipment # units % gas % electric
Single family
Water heating 13,077 85% 15%
Space heating 82% 18%
Multi-family
Water heating 3,963 61% 39%
Space heating 50% 50%
Gas Utility Costs and How Electrification Would Affect them
The table below lists the different costs the gas utility incurs, what percentage of the
utility’s costs each category represented in FY 2024, and what factors would lead to each
category of costs declining.
Item 2.
Attachment A -
Assumptions, Methodology,
and Preliminary Key Results
from Gas Transition Study
Currently in Progress
Item 2.: Staff Report Pg. 6 Packet Pg. 25 of 27
Attachment A
Cost Category Varies Based On
% of Gas
Utility Cost
(FY24) Decreases when
Commodity, Transportation,
and Environmental
Sales 41%
Sales decline
General Fund Transfers Sales 15% Sales decline
Demand Side Management Sales 1% Sales decline
Customer Service # Customers 4% Customers disconnect
Operations and Maintenance
(incl. Engineering)
Miles of main,
main age
16% Lengths of main are
abandoned, especially
older materials or steel
Capital Investment (incl.
Engineering)
Miles of Main
needing
Replacement
13% Lengths of main needing
replacement are
abandoned
Administrative Overhead: Mostly staffing 7% Enough lengths of main
abandoned that the gas
utility needs fewer staff
Supply Management Does not vary 2% Gas is no longer used in
Palo Alto
Debt Service Debt service
schedule
1% Debt is paid off
Rent Square footage of
gas receiving
stations
1% Gas is no longer used in
Palo Alto
Estimated Gas Main Abandonment Opportunity for Different Electrification Levels
The City’s consultant ran the following simulations, which loosely aligned with the
scenarios discussed with the Climate Action and Sustainability Committee and Utilities
Advisory Commission:
Scenario
Gas
Sales
Reduction
Residential
Space and Water
Heating
Electrification
Small and Medium Non-
Residential Space and
Water Heating
Electrification
Medical and
Industrial
Electrification*
1 20% 25% 25% 0%
2 40% 50% 50% 0%
3 60% 75% 75% 0%
4 80% 100% 100% 0%
* In practice, some electrification will occur in this sector, but staff does not have good
visibility on the potential for electrification in this space due to the prevalence of unique /
process loads
Item 2.
Attachment A -
Assumptions, Methodology,
and Preliminary Key Results
from Gas Transition Study
Currently in Progress
Item 2.: Staff Report Pg. 7 Packet Pg. 26 of 27
Attachment A
The consultant found the following after simulating several iterations of random
electrification among the sectors noted above. The chart below shows the number and
percentage of gas mains with the number of connections shown on the x axis. So, for
example, under the 60% scenario about 300 mains (about 10%) had no connections and
could be removed, while over 500 mains (about 20%) had only one connection. And the
number of mains with no connections increased from almost none under the 20% scenario
to about 40 in the 40% scenario, over 300 in the 60% scenario, and the vast majority of
mains in the 80% scenario.
More work is needed to identify the miles of main that can be removed in each scenario,
how many mains need to be retained for operational purposes, and how many mains have
minimal gas usage and could be retired with the right outreach and incentives to the
connected building owners.
Item 2.
Attachment A -
Assumptions, Methodology,
and Preliminary Key Results
from Gas Transition Study
Currently in Progress
Item 2.: Staff Report Pg. 8 Packet Pg. 27 of 27