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Larkspur staff say CalGreen electrification amendments not accepted for CEC filing due to missing cost-effectiveness studies
Summary
City staff told the Larkspur Climate Action Forum that CalGreen Tier 1 amendments the council adopted were ineligible for submission to the California Energy Commission because the required cost-effectiveness studies were missing; staff said they will pursue alternative paths and expect clearer options by late October–November.
City staff told the Larkspur Climate Action Forum on Oct. 8 that the city’s recent CalGreen Tier 1 building-code amendments could not be submitted to the California Energy Commission because the administrative packet lacked required cost-effectiveness studies.
“The code amendments were not eligible for submission because of incomplete materials required for submission,” said Shannon O’Hare, the assistant city manager and staff lead for the forum. She said the city began the submission process to meet an October deadline but lacked complete Tier 1 energy-study documentation for the 2022–2025 cycle.
Why it matters: Tier 1 reach-code measures can require significant changes—such as enhanced EV readiness and electrification pathways—that some jurisdictions have pursued to accelerate building electrification. Missing supporting studies means the state commission will not accept the amendment packet for review, delaying any local enforcement tied to that submission timeline.
What staff will do: O’Hare said staff is working with County of Marin staff, consultants who prepare cost-effectiveness studies, and the California Energy Commission to identify feasible next steps. “The California Energy Commission has been very, very generous with staff across the state if we want to resubmit,” she said, adding that the city can ask CEC staff in advance to verify the completeness of a packet before formal submission.
Staff outlined two alternative tracks: commission a jurisdiction-specific cost-effectiveness study (either paid for by utilities’ consultant pools or by the city) or pursue code changes through other legal mechanisms—examples cited included a general-plan amendment or adopting the state’s model flex path for remodels where the state has already completed study work.
Timeline and staffing: O’Hare said the city hopes to know the viable paths by the end of October and to have additional information by late November. She also told the forum that she will hand off much of the day-to-day process during an upcoming maternity leave but that the city manager and incoming community development director will continue the work.
Next steps: Staff will continue coordination with county partners and the CEC, scope consultant needs and costs, and return to the forum and council with recommended next steps and timelines for public hearings if needed.
The forum’s discussion made clear two practical takeaways: the city can refile if it secures required studies, and there are other code-adoption avenues (including flex-path approaches already used in neighboring jurisdictions) that could deliver many of the same electrification and EV-readiness goals with different procedural steps.
