Letter to the Editor | Not so fast with “Reach Codes” please

The following was sent to the members of the Piedmont City Council:

Dear Members of the Piedmont City Council,

I write to you in order to state my concerns about the Reach Codes (#750 N.S. and # 751 N.S.). 

Let me state from the beginning that I am not against doing whatever we can, based on the integrity of our older homes in Piedmont, to reduce natural gas consumption and to increase our energy efficiency.

#1:  Random Sampling Report of FM3

With an issue of such great importance to the City of Piedmont, I do not feel that a random sampling of 400 households represents all households in Piedmont. 400 is just a shade over 10% of all households in Piedmont.  There is no indication of the ages of any of those 400 homes that were surveyed. My concern is that the sampling is not fairly representative of all Piedmont homes. 

#2:  Flawed Process

The codes appear to be “boiler plate” and not tailored to the age and character of our city.

Our city operates with the input of various commissions which are composed of concerned and interested citizens.  These Commissions solicit other citizen input before make decisions.  It appears that the Planning Commission has not been a part of this “Reach Code” process to date.  Why? 

#3:  Subjectivity of Building Officials

The Reach Codes, in some instances, allow for exceptions to be made by employees of the City of Piedmont Building Department. I have dealt with many of our Building Officials over the past 50 years. Some dealings were because of being a homeowner and others occurred because of my job as a project manager. Some of the officials have been great to work with and others not so much. If a Building Official wants to make a statement that will show his/her power, his/her ability to grant or refuse an exception to the codes could become political and not based on merit.

#4:  Unintended Consequences

I believe that the unintended consequences of the Reach Codes, presently stated, will be a reduction in the character of the older Piedmont homes.

I live in a house that is close to 100 years old. I know when I am no longer living in it, a new owner will want to make some major changes. If those changes cross the larger dollar amount thresholds, as stated in the Reach Codes, it will be cheaper for that new homeowner to tear down my house and start over than to retrofit to meet the “Reach Codes” requirements.  Retrofitting is much more costly than building from the ground up. The turnover of many of the older homes in Piedmont will bring the same dilemma.  In so doing, the historical character of Piedmont will forever be altered.

What I ask of you is to slow down this process which has been thrust upon us in such a presumptive manner.

Regroup and have the whole of Piedmont involved in a survey – not just 10%. Make the process transparent so that we who were not surveyed (close to 90%) will feel that the process represents everyone who lives in our beautiful city.

Thank you for your consideration.

Fran Wolfe
Piedmont Resident

8 thoughts on “Letter to the Editor | Not so fast with “Reach Codes” please

  1. Admittedly I am unfamiliar with induction cooktops. They evidently do adjust to heat changes more quickly than old technology electric cooking; the issue is conversion to such systems in older homes. A quick search reveals that these require a dedicated 240 volt 40-50 amp circuit. Piedmont building code does not allow exterior electrical conduit; older homes without necessary circuitry in place will be significantly more expensive to update to induction with walls being opened and then refinished to accommodate. And apparently induction cooktops do not work with all existing pots and pans.

    I have no issues with requiring all electric appliances and HVAC in new construction though suspect many of the supply sources of the electricity is gas driven so the only real gain is not to the climate but to the bank accounts of HVAC contractors.

    Concerning remodels, the 7/20/2020 Staff report states that the initial FM3 survey found only “about half” supported the proposed REACH codes and the respondents preferred the City give monetary incentives rather than having to adopt specific technologies because of cost issues.

    The Staff report states that while focus group attendees were generally more favorable to the proposed code changes, fundamentally residents wanted a more flexible approach that allows them “to choose the option that works best for their situation.” For other than new construction this is an approach I favor though I do support the requirement of solar panels should an existing structure add a 2nd level or increased roof area of 30% or greater.

    Requiring a heat pump as a replacement for an existing furnace will be an expensive requirement and applied unfairly to older homes. I do not support this.

  2. I am more against the Reach Codes because they are of almost no significance in the face of worldwide Climate Change, than because they are so onerous. At best they are only a feel-good exercise, that will irritate just a few of us per year. Yes, the issue should have gone to the Planning Commission for review and a recommendation. The PC contains architects and other experienced professionals. The charettes were a top-down explanation of what we are going to do to you.
    One obvious flaw with the $25k, 100k triggers approach is that it penalizes those homeowners who have already done the good stuff like attic insulation and water heater blankets, etc. They are then pushed into heat pumps and similar esoteric devices.
    A final thought: electrification is no greener than the source of the electric power, the majority of which comes from non-renewable sources.

  3. 10% is actually a very good sample size for a homogeneous community like piedmont. FM3 presented its results to Council at the July 6 meeting and that can been viewed on the website. Piedmont has the highest median age in Alameda County so I suspect a random survey had sufficient responses from seniors. I think a lesser number of responses were received for public safety cameras.

    The city is increasingly using FM3 to poll the community and its methods should be made more transparent. That said, on the Reach codes, these results and the survey instrument are available to the public. Push surveys are a concern but I don’t see that in this survey. What is most significant is the broad support for electrification In the survey – that’s a new term for most in the discussion of climate change and that it gathered such large support to me says most of Piedmont is ready for theses changes.

    And these are not “one size fits all” code adoptions. The electrification/solar requirements apply to very few new projects. All other requirements are pretty modest and consist of basic energy efficiency actions. Many of theses actions are recommended to be done at time of remodel even without reach codes because they pay for themselves over time. And Susan is right – a tear down would be subject to more stringent title 24 code requirements. And it would likely be required to install solar panels. As of 2020, all new single family homes are required to have solar panels.

    Read the FAQs that staff has posted on the city website. They give detailed answers about how the code will and will not be applied.

  4. #3 Just cannot abide by the claim that officials are biased, believe in or not the world and humans are not perfect. I comes down to the age old struggle of right vs wrong; if you don’t like what an official says, who is the biased one?
    #4 “I know when I am no longer living in it, a new owner will want to make some major changes. If those changes cross the larger dollar amount thresholds, as stated in the Reach Codes, it will be cheaper for that new homeowner to tear down my house and start over than to retrofit to meet the “Reach Codes” requirements”
    How in the world would you know or able to predict, or care for that matter, what the new owner will do…those are big projections and assumptions that have little relevance to the future of how reach codes affect people.

  5. I am troubled that these sweeping Reach codes, which represent important changes to Piedmont’s already strict building addition guidelines, were not heard first by the Planning Commission. I cannot recall another instance where significant changes to the requirements for remodeling were not heard. This raises red flags. Therefore:
    Item #1 There are objective surveys and there are push surveys; the later asks leading questions to arrive at a desired conclusion by the public agency. This is not unknown in Piedmont.
    Item #2 To some the Reach code requirements seem modest; they are only modest if you have a newer home that can accommodate the required changes during remodeling. One size does not fit all here.
    Item #3 Generally Piedmont runs a lean and efficient staff. However, in the past I have seen direct subjective support for projects that even other City officials found troubling (The Blair Park Soccer Field conversion). I hope politics are not part of the building approval process but let’s be real about this.
    Item #4 While Fran Wolfe may be reaching on this one, a required total tear down and rebuild, it is not out of the question. Again referring to item #2, there are older and unusual homes that will be far more expensive to reach compliance with Reach codes than most other homes. What may cost one homeowner several thousand might cost another homeowner tens of thousands.

    My final comment is that an attempt to entirely eliminate gas cooking I do not find appealing.

  6. Re: #1: The survey was designed to be a scientific, representative sample, and done by a reputable outside firm.

    Re: #2: The language is far from boiler-plate and is fact driven by the experience of building officials with the types of permits and conditions that Piedmont houses exhibit. There were numerous public workshops and forums on the Reach Codes. You can review the detailed information about the careful study and rationale for the specific codes developed here: https://www.ci.piedmont.ca.us/government/city_news___notifications/council_to_consider_reach_codes_august_17th

    Re: #4: The statement is a red herring. There is nothing in the Reach Codes so onerous that it would prompt a new owner to tear the house down. In fact, if a new owner chose to do so, the new construction would be subject to even more stringent and costly requirements by building codes (including mandatory solar (https://blog.namastesolar.com/what-is-title-24-part-6) and sprinkler systems, required since 2011 in new residential construction) than a renovation.

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