BOMA SF asks the right questions on city’s Draft Climate Action Plan

Photo of a Silicon Valley power plant courtesy of the American Public Power Association

Nailing down the right path through the energy transition requires a close accounting of the decarbonization tradeoffs in policy decisions like natural gas bans.

John Bryant, CEO of BOMA San Francisco, and his team and membership are asking good questions of their city’s Draft Climate Action Plan, including the role of natural gas bans in a decarbonized future. The BOMA SF team points out, for starters, that transitioning a commercial building to all-electric equipment does not mean that building would have zero-emissions today.

The City’s accounting ignores system-level emissions from the grid that reflect the realities of each day’s dispatch of resources, system level reliability resources and imports, and would ignore electric efficiency pathways to achieve the City’s goals. – BOMA SF

ESG Embedded Carbon in Electricity and Natural Gas Bans

This figure reflects the hourly sum of GHG emissions from internal ISO dispatches and GHG emissions from imports serving ISO load in November 2020.

Additionally, BOMA buildings are subject to state, national, and international performance standards that push performance on both electric and thermal efficiency. For now, the draft Plan reads as though an all-electric office tower with an Energy Star score of 10 is preferable to an electric and gas building with an Energy Star score of 99.

Switching fuels is no easy task for commercial buildings. For a typical office building in the Bay Area, space heating relies on a central boiler system to feed a hot water loop at ~180F supply temperature to deliver space heating through perimeter terminal units in the building. Retrofitting such a system has three options, the most likely would involve electric resistance heating.

Our concern is that especially with the advancing timelines, that the policy could lead BOMA members to be forced into electrification in ways that might not decrease but actually increase carbon emissions and exacerbate our carbon emissions. – BOMA SF

Dollar costs must also be carefully considered. Electrifying natural gas boilers might lead to air distribution costs near $1 per square foot, and upgraded electrical feed infrastructure to 3,000 amp service can run to $100,000. And should enacted policy petrify existing installed equipment with years of useful life remaining, those stranded asset capital costs should also be counted. Increased operational costs must also be considered – on a fuel equivalent basis, electric resistance heat costs 4 times that of natural gas.

On the operational side…we estimate an impact of over $0.50 per square foot, for a total increase of 20% of the average utility bill for BOMA members. – BOMA SF

The above is a summary of some of the highlights – the full letter is well worth the read, as it includes more detail on cost-allocation and cost equality for small businesses left on the natural gas infrastructure, the role of refrigerant gas initiatives, potential exclusions and exceptions, other uses of natural gas, and more.

Additional References

  • From January 2020, a review of the first vote banning natural gas in city buildings in the San Francisco Chronicle.
  • From November 2020, a review of the San Francisco natural gas ban in new buildings in Smart Cities Dive.



About Millen Paschich

Millen began his career at Cambridge Associates, trained in finance at SMU, and has an MBA from UCLA. Talk to him about bicycling, business, and green chile burritos.

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