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Reach Codes

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Presentation at Cupertino Chamber of Commerce, Legislative Action Committee meeting. December 6, 12:30pm at Cupertino Community Hall. Public meeting, RSVP here:


First public hearing of the Cupertino electrification reach code, Cupertino City Council Chambers, December 17 

What are Reach Codes?

Every three years, cities and counties across the state adopt the new Building Standards Code (Standards) or Title 24 of the California Code of Regulations. Cities may adopt building codes more advanced than those required by the state, which are known as reach codes. The next set of codes begins enforcement in January 2020.  

Reach codes pull the construction market upward, priming the construction industry for changes that could well be part of the next update for the state baseline energy code. The 2020 reach code effort is also taking place in a regional context, with model codes and studies provided by Silicon Valley Clean Energy, the California Energy Commission, and the Bay Area Regional Energy Network (BayREN). This regional approach can also provide certainty and consistency for the construction sector by developing the reach code through the same public process as other statewide codes, and avoiding the pitfalls inspecting projects for compliance that may use many different standards or approaches to achieving greater performance. 

About 50 California jurisdictions are considering or have already adopted reach codes as mandatory requirements for newly constructed buildings beginning in 2020. 13 Silicon Valley jurisdictions are considering or have already adopted reach codes for 2020.  

How might a reach code impact me? 

Building codes govern the way that buildings are designed, constructed, and remodeled. Reach codes generally establish higher standards for new construction where they are proven to provide the owner with benefits that justify any additional costs of development. In some cases, it has been found that all-electric buildings are lower cost to develop than buildings with natural gas.  

The reach codes under consideration in Cupertino and other Silicon Valley cities are focused on new residential, commercial, and multifamily buildings that will be seeking building permits after January 2020. The scope of reach codes in the past have generally been limited to permits for newly constructed buildings, with exemptions made for cases where the reach code is not found to be cost effective.  

Why Establish Reach Codes? 

Cupertino’s Climate Action Plan outlines a path towards creating a healthy, livable, and vibrant place for its current and future residents to live, learn, work, and play. Because reach codes are designed and adopted locally, they serve as an opportunity to help address our community’s specific needs and achieve our climate goals. For example, Cupertino can enhance the safety and cost savings of our buildings by adopting reach codes that support energy efficiency, renewable energy, and electrification. Like the 13 other Silicon Valley jurisdictions who are in the process of studying reach codes, Cupertino is taking the lead on improving the quality of life for our communities and the health of our environment, in a way that provides economic benefits to the consumer and society.  



What are the advantages of all-electric buildings?

Eliminating combustion of natural gas in livable areas improves the indoor air quality and improves overall safety associated with fires and gas leaks. A 2002 study by the California Seismic Safety Commission found that damaged gas infrastructure caused 20 to 50 percent of post-earthquake fire ignitions. Electric heat pump appliances (such as water heaters, air conditioning and heaters) are 4-5 times more efficient than equivalent natural gas appliances. Buildings with electric heating are allowed a larger winter baseline quantity of electricity. Additionally, all-electric buildings can more effectively utilize on-site solar generation, which is required in the 2019 Building Code.

What are the potential drawbacks of an all-electric building?

Some people still prefer to cook with gas, though customer satisfaction with electric induction stoves is driving a trend toward electric cooking. Electric heat pump water heaters can take up more space than tankless gas water heaters as they include a hot water storage tank.

Are all-electric buildings viable today?

Yes. Electric alternatives to most equipment are available and most building types, including residential, office, restaurants and many other commercial types, are compatible and benefit from all-electric design. Furthermore, a growing but small number of developers in California are now selecting all-electric buildings for their inherent advantages. Institutions such as the University of California are also building new facilities that are all-electric as a matter of policy, including new housing, laboratories, and classrooms.

What buildings must comply with the proposed reach code?

This proposed reach code applies to all new construction and tear down/rebuilds of low-rise residential, high-rise residential and nonresidential buildings. Modest remodels and tenant improvements that comply with the prescriptive pathway of Title 24 Part 6 are exempt. Additionally, nonresidential building occupancies H, F, and L are proposed to be exempt. For-profit kitchens may request a modification in the case that electric alternatives for specific cooking equipment (i.e. wood-fired pizza oven or grill) are not feasible.

Where can I find the cost effectiveness study?

The statewide study covers all geographical regions in California and Cupertino is located in climate zone 4. The 2019 cost-effectiveness studies can be found on the CA Local Energy Codes website.

Is high-performance technology like fuel cells or resiliency needs like diesel or natural gas fired generators affected?

The two reach code options presented by Cupertino staff rely on modifications to Title-24, part 6 (energy code) and part 11 (green building code). Neither of these codes regulate the installation of either fuel cells or generators for emergency or baseload energy needs for a facility. The reach codes do not preclude the installation of natural gas for a fuel cell or generator application.

What about businesses that need natural gas to fuel an industrial process?

The 2019 energy code only lightly regulates industrial process loads. The proposed reach codes do not regulate process appliances, or the fuels used to provide those process services. In addition, Staff is proposing specific exemptions for certain building occupancy types that cannot be feasibly built all-electric, including modifications for commercial kitchen equipment.

Does an all-electric building cost more to build?

In most cases, all electric buildings cost less to build than mixed-fuel buildings because building all-electric eliminates the installation cost of the natural gas infrastructure. These studies examine the upfront costs, maintenance costs, and operational costs of all-electric designs and support these conclusions:

What are the proposed solar panel requirements for non-residential and high rise residential?

The State code requires solar PV only for low-rise residential new construction. Cupertino’s all-proposed reach code does not include any additional solar PV requirements for non-residential building types.

Can a heat pump water heater match the performance of a gas system?

Yes, a heat pump water heater can equal the performance of a gas equivalent. For example, Rheem's 55 gallon unit can deliver 70 gallons of hot water in the first hour, enough for about four showers. For comparison, Rheem's gas equivalent delivers 79 gallons in the first hour. When selecting any hot water heater, no matter the fuel, make sure it is the right size for your use type. A home with a big family might need a larger 80 gallon tank.

More information about selecting an efficient water heater can be found on the ENERGY STAR website.

Can a central heat pump water heater distribute adequate water supply temperature to multiple units simultaneously?

Yes, when designed appropriately. Many entities are supporting design guideline development, which is expected to be publicly available in early 2020.

How does induction cooking compare to gas cooking?

Public outreach indicates that cooking with gas remains highly desirable among consumers and restaurant owners. However, it is also true that modern induction cooking is not well known in the U.S., with 7% market share in the U.S. as of 2017. Induction cooking provides many benefits including more control over cooking, improved indoor air quality, and enhanced safety, but a learning curve is present as with any unfamiliar technology.

Induction cooking provides more specific temperature control and is more responsive to variations than gas, is much safer, and induction cooktops are easier to clean. The City of San Jose has an FAQ on induction cooktops. Already popular in other parts of the world, induction cooking is an up-and-comer in U.S. households. The National Kitchen + Bath Association identified it as the fastest growing kitchen trend in its 2018 Design Trends survey. As the market continues to grow, the industry expects wider availability and more options, which could mean increased affordability.

Researchers at the Lawrence Berkeley National Laboratory have found that cooking with gas lowers indoor air quality and raises a variety of health concerns. Researchers estimated that 60% of California homes where a gas stove was used for cooking at least once a week had indoor pollutant levels exceeding legal outdoor limits. The finding means that millions of people are subjected to levels of nitrogen dioxide, formaldehyde, and carbon monoxide in excess of current standards.

How does the Cupertino proposal compare to the Berkeley natural gas infrastructure ban?

Broadly speaking, there are two ways to encourage all-electric new buildings. One is through amendments to the energy code, which is what Cupertino, Silicon Valley Clean Energy, and many neighboring cities have proposed. The other way is by amending the Municipal codes, which is what Berkeley did by banning installation of natural gas infrastructure in many (not all) new planning entitlements. San Jose has taken a hybrid approach first passing an “electric-preferred” amendment to the energy code, which incentivizes all-electric design, and next considering a natural gas infrastructure ban.

Will PG&E be able to handle the additional load from more electric buildings?

PG&E is on record recommending all-electric building codes. They’ve issued a letter to the City of Cupertino indicating they can accommodate the increased load. The requirements for electric utility service planning are no different for an all-electric building compared to a mixed-fuel building, with the reduced burden of service planning for natural gas.

How reliable is the electric grid as compared to natural gas?

PG&E’s grid reliability has been increasing since 2015. The natural gas grid and electric grid both go down on occasion. In fact, during California's primary natural disaster events, wildfires and earthquakes, utilities are supposed to turn the gas off. For example, 26,000 customers had their natural gas lines turned off in Sonoma County during the recent Kinkade fires, with utilities citing the risk of ignition to the natural gas pipeline system. If 100% reliability is a goal for your home or project, electrification with battery and solar backup via microgrid is an effective solution.

What happens to electric water heaters and induction cooktops when the power goes out? Is it better to have a gas stove to be able to cook meals and a gas water heater to have hot water?

It is true that electric water heaters and induction cooktops will not work in the event of an electrical power failure, unless the home has a battery backup system installed. However, gas appliances may not always work in a power failure either. While most older models of gas stoves can be lit manually during a power outage, certain models of newer gas ranges are made with a safety feature called an interlock that prevents the burner from being manually lit. The purpose of an interlock is to prevent hazardous gas leaks by completely cutting off gas flow to the burners in the event of an electrical outage. (To see if your stove is made with an interlock, check the owner's manual or manufacturer's website.) Similarly, gas ovens require electricity to operate and cannot be manually ignited. In addition, operating a gas stove indoors without proper ventilation fan has been shown to create hazardous indoor air quality conditions.

Gas on-demand water heaters have a control panel that is powered by electricity, which will also not work in a power outage.

Thus, using natural gas appliances is no guarantee in an electrical outage.

Should Cupertino consider requiring even more EV charging spaces?

Staff does not recommend going further than the SVCE model EV charging reach code, which was developed with a careful look towards first cost feasibility, electrical infrastructure requirements, and the market trends of EV adoption. If the utility needs to provide additional power in anticipation of future EV adoption, the building owner can be penalized if that provisioned load doesn’t materialize. Even in a future of all electric vehicles, given advances in EV battery technology, we won’t likely need all parking spaces to be EV ready.


Process and Timeline 

  • July 1, 2019 City Council authorizes staff to study and bring a recommendation on reach codes to the Sustainability Commission 

  • August 29 Sustainability Commission Meeting 

  • September 10 Planning Commission Meeting 

  • October 16 public outreach event at Cupertino Community Hall, 10350 Torre Ave., 6:00pm – 8:00pm (PowerPoint Presentation

  • November draft ordinance 1st reading by City Council 

  • December ordinance 2nd reading by City Council 

  • January 1, 2020 new base building codes begin enforcement 

  • Energy components of any adopted reach codes may not begin enforcement until certified by California Energy Commission.  

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