Dear Council members,
My name is Eduardo Pelegri-Llopart and Im a resident of The Willows. I am submitting this comment as an individual resident of Menlo Park, not as a member of the EQC.
I want to express my support for the staff proposal described in item K1 of the agenda packet for the January 28th, 2025 meeting of the City Council. Replacing or upgrading a panel is an expensive decision. The intention of the proposed amendment to the 2022 California Building Standard is to fully leverage that cost by reserving breakers and capacity in the panel for future electrification needs.
In almost all cases the extra cost required to accommodate those requirements should be very small compared to the cost of replacing or upgrading the panel when done at the same time, while a later retroactive change may be very expensive.
In some cases it is possible that complying with the new requirements might raise some concerns. I can think of two types of situations:
The first case arises because sometimes a panel needs to be replaced for safety reasons. Some houses had/have unsafe panels like the GTE Sylvania-Zinsco panels. I believe very few houses remain with those panels but I could see a situation where a resident with limited resources may need to replace such a panel in urgency. Perhaps an exception may be needed for those cases?
The second case is when intending to replace a panel of one Amp capacity with another of the same capacity for whatever reason - old panel is in bad shape, perhaps a smart panel with the same Amp size, perhaps the resident wants a panel with more physical space, whatever. Upgrading the Amp capacity of a panel may be very expensive if PG&E needs to also upgrade the feed into the house, so it might be best to express goals and give flexibility into how to achieve those goals, to see if an upgrade can be avoided.
I applaud that 1.a.i and 1.a.ii express the outcome without unduly expressing a way to accomplish it. In particular:
* The new generation of electrical appliances are very efficient. The new electric dryers use heat pump technology and only need a standard 120V/15A circuit. Indeed, the latest generation of appliances are combos washer / dryer. These units are efficient in energy and also in space.
* There are beginning to appear electrical ranges that only require a 120V/15A circuit. These induction ranges include a battery - the battery charges slowly from the 15A circuit and it can discharge fast during cooking.
Id ask whether the requirement 1.c (HPWH) should also be expressed through a goal, not a specific solution. In particular, the latest generation of Heat Pump Water Heaters come in 240V/30A and 120V/15A varieties. In our house some years ago we installed a 240V HPWH but only because there were no 120V models available then. We have configured our HPWH to work in HP mode only and that draws very little energy.
A similar comment on goal vs requirement can be made in the case of EV charging. We have had EV vehicles since 2013. I certainly prefer to have a (low Amp) level 2 charger, but it is possible to charge using a Level 1 charger, and even a Level 2 can share its load with another appliance. Perhaps an alternative is to require a dedicated breaker but not indicate whether it is a 120V or a 240V breaker?
Thanks for reading so far. Again, I fully support the staff proposal. I think it will be beneficial for residents as it will help them maximize the benefits they get from the expensive panel replacement/upgrade.
Eduardo Pelegri-Llopart, The Willows
