First Name | Edward |
---|---|
Last Name | Mainland |
Email Address | emainland@comcast.net |
Affiliation | Sierra Club California |
Subject | Sierra Club Comments on Energy Efficiency |
Comment | COMMENTS ON AB 32 PROPOSED SCOPING PLAN, SUBMITTED BY SIERRA CLUB CALIFORNIA, November 19, 2008 3. Energy Efficiency (p. 41) • Sierra Club supports all the energy-efficiency efforts listed by CARB. In fact, we believe that even greater reductions in the pollution that causes global warming can be gained by further strengthening efficiency and conservation efforts. In particular, it is necessary to strengthen independent auditing, measurement and verification of efficiency measures and programs. • The Plan’s goal of 32,000 gigawatt-hours of electric power demand reduction by 2020 falls far short of the economic potential for 60,000 gigawatt-hours of savings if all technology options are included (as described in the California Energy Commission 2007 Integrated Energy Policy Report, p. 98). The larger goal is more in line with the Western Governors efficiency recommendation of 20% reduction from projected demand, which their advisory panel said was likely achievable well before the 2020 target year if best practices were used. • The mandatory Green Building Standards Code update scheduled for 2010 needs to be strengthened. CARB pressure could help. Commissioning, quality control and enforcement of green building standards and practices in actual construction and renovation has become acutely important as evidence mounts within the trade that many so-called “green” projects do not deliver the efficiency savings advertised. • Can CARB provide more detail in terms of the three measures in CR-1 (separate out the expected reductions from the three strategies outlined)? • By 2020, California should be able to go well beyond the SB 1470 goal of only 0.1 million tons of annual reductions from solar water heating, through encouraging public-private partnerships. • CARB should recommend to the CPUC that energy-efficiency programs be administered independently from the utility companies, and expand the use of Standard Offer contracts based upon performance. The California Public Utilities Commission investigated this in 2002 and concluded that independent providers were more cost effective, particularly for residential customers. The CPUC is developing independent and objective systems for measuring and verification of energy-efficiency program savings, and should be urged to fully deploy this in a timely manner. |
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Date and Time Comment Was Submitted | 2008-11-19 18:37:23 |
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