State rejects Larkspur's building electrification code amendments over missing cost studies

Larkspur's push to require all-electric new construction stalled before it ever reached a reviewer's desk. Staff told the Climate Action Forum on Wednesday that the city's CalGreen Tier 1 building code amendments — already passed by the City Council — were rejected as ineligible ahead of the October 1 submission deadline to the California Energy Commission.

“The code amendments were not eligible for submission because due to incomplete materials required for submission. This is mainly due to the cost effectiveness studies required to submit to the California Energy Commission.”— Shannon O'Hare, city staff, on the CEC rejection

The problem was paperwork, not policy. The CEC requires cost-effectiveness studies to accompany any local reach code, and no jurisdiction in the area had commissioned complete Tier 1 energy studies for the 2022 code cycle. "The code amendments were not eligible for submission because due to incomplete materials required for submission," staffer Shannon O'Hare told the forum. "This is mainly due to the cost effectiveness studies required to submit to the California Energy Commission."

Staff is now looking at ways around the wall: a "flex path" approach, electric-ready requirements rather than outright electrification mandates, and using the city's General Plan update authority to adopt amendments outside the CEC process. Forum member David Mahler pointed to South Bay jurisdictions taking the flex path, enhanced EV charging and A/C-to-heat-pump routes as a possible model.

O'Hare tempered expectations on timing. "I just want to be clear because I at one point heard end of October and I thought that was really ambitious," she said, adding the city expects to have enough information by the end of November to pick a path forward.

Forum backs off tightening the gas leaf blower ban, favors telling homeowners they're the ones on the hook

Larkspur's 2017 leaf blower ordinance, Municipal Code 9.57, still exempts multi-family properties, commercial properties and municipal park areas from the gas-powered ban — a looser rule than neighbors Corte Madera and Fairfax, which require all-electric equipment. Rather than recommend the council strip those exemptions, the Climate Action Forum settled Wednesday on education and incentives first.

“From a commercial property manager perspective I have a really hard time going electric blowers. It does not cover the area that we need... we couldn't do the hill by a long shot without these devices.”— Reed Baxter, commercial property manager

The most persuasive argument was about who actually gets cited. "People are not aware that enforcement is against the homeowner," David Mahler said. "If the homeowner knew that enforcement would be against them as opposed to the gardener, I think that could really change the dynamic." He also argued carrots beat sticks, citing regional trade-in programs where "the range was $50 to $250 for homeowners and $500 to $1,000 for professional gardeners."

Pushback came from the operations side. Reed Baxter, speaking as a commercial property manager, said the electric equipment simply doesn't do the job on his sites: "It does not cover the area that we need... we couldn't do the hill by a long shot without these devices." Another member cautioned against spending discretionary forum funds on rebates before checking whether the money would do more good elsewhere.

Staff proposed a modest 15 to 20 hours of research into what other jurisdictions already offer, including the Fairfax/San Anselmo trade-in program. The consensus direction: study the cost of a homeowner education campaign and a rebate or exchange program aimed at commercial landscapers holding a Larkspur business license, and bring it back as an information item — possibly in December.

Forum cuts a 250-item climate plan down to two priorities for the next six months

Faced with a Climate Action Plan containing roughly 250 items, the forum ran a prioritization exercise Wednesday built on five community submissions. Staff plotted the 12 nominated items on an effort-versus-impact quadrant; three drew support across multiple submissions — EV charging in commercial parking lots, and two renewable energy items tied to solar and gas appliance replacement.

“It's really all about adding additional charging at multi-family housing. It's not about adding more charging to parking lots because this huge portion of the population doesn't really have access to EV charging.”— David Mahler, Climate Action Forum member

Members narrowed to two focus items for the next six months: EV charging (LCTC1G) and replacing natural gas appliances with electric at the time of replacement (RECC3B). David Mahler pushed to redirect the charging item away from retail lots. "It's really all about adding additional charging at multi-family housing," he said. "It's not about adding more charging to parking lots because this huge portion of the population doesn't really have access to EV charging."

Mahler also argued the four-year-old plan's language is outdated: "I would like to suggest that we not limit ourselves exclusively to wordings and actions that are in our four-year-old plan, and go through the countywide EV acceleration strategy and building electrification roadmap to update the wording and focus of these actions." Both countywide documents have already been adopted by the council. Staff will return with effort, cost and timeline estimates before the next meeting.