The proposal for zero emission space and water heaters places an
unfair burden on those building owners whose electric service panel
cannot support these appliances. A panel upgrade is a complicated
retrofit requiring design and coordination with the utility. The
staff report acknowledges that some buildings will require upgrades
but does not provide any background on its scope. It is
unreasonable to expect building occupants to go without space or
water heating for the time it takes to complete the upgrade. My
wife and I are currently upgrading our panel from 100A to 200A.
Ours is a simple job which will not require moving the panel. We
are three weeks into the process with at least another week before
it can be completed. Our next-door neighbors waited over a year, in
part because PG&E needed to upgrade the neighborhood electric
lines.
For many, a panel upgrade is complicated by relatively
relatively recent PG&E guidelines requiring separation of the
panel and gas meter. The electric panel of many of our neighborhood
homes is directly above the gas meter and cannot be upgraded in
that location. Moving a panel adds considerable complexity, cost
and lead time. Also, PG&E charges thousands of dollars if a new
service drop from the overhead lines is required. For those
building owners, failure of a gas space or water heater would be an
unmitigated disaster.
If the rule's intent is to scare building owners into a
preemptive panel upgrade, the board should consider whether those
upgrades could be completed before 2030. Some report references
indicate that no reliable data is available on the number of
buildings that would require retrofit. One reference estimates one
to two million. Twelve thousand upgrades per month over seven years
would be required to complete one million upgrades. I doubt the
state's utilities or contractor base could support that. It also
seems obvious that a large fraction of homes requiring a panel
upgrade will be in disadvantaged neighborhoods since those
residents would not have had the resources to already upgrade their
homes.
I urge the board to delete this item from the SIP and replace it
with a building code change that requires zero emission water and
space heaters only for homes whose panels can support those
appliances. The board could then recommend state programs to
encourage preemptive panel upgrades.
Climate change due to fossil fuel emissions is obviously a major
problem and we must address emissions as soon as possible, but the
2030 zero emission space and water heater rule is too drastic given
the impact on those without adequate electric service and that the
total building contribution to NOx emission is only 5%. Please
modify this rule as I suggest.