First Name: | Amy Dryden |
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Last Name: | Dryden |
Email Address: | amy@builditgreen.org |
Affiliation | |
Subject | Comments on 2030 Scoping Plan Update, December 2, 2016 |
Comment |
RE: Comments on 2030 Scoping Plan Update, December 2, 2016 Energy Efficiency: As mentioned in the plan cleaner and more efficient technologies, new polices an incentives that better recognize and reward innovation and prioritize low carbon investments. As mentioned SB 375 is one of the ways to address housing and transportation needs and provide climate benefits. AB 32 Scoping plan can expand this effort by assessing and addressing the energy-related and non-energy benefits of accelerating energy efficiency efforts in existing homes, where much of California's GHG emissions come from. Without some careful analysis and consideration of this opportunity, stakeholders and the public in general cannot evaluate how well the draft Scoping Plan will meet the goals for 50% energy use reduction and weatherization of all eligible homes, and improvements in human health and environmental equity. The co-benefits of energy efficiency in existing building also directly correlate to improved living conditions, reduced stress, and reduction in fuel poverty. In the SB 350 barrier repot it is recommend that a common set of NEBs should be defined along with metric to measures them and should be integral to delivery of energy services for low income communities. In a recently published study Occupant Health Benefit of Residential Energy Efficiency (November 2916), it was demonstrated that residential energy efficiency programs that typically improve the building envelop and HVAC systems creating more comfortable homes, improve the environmental conditions and the occupant health including reduced hospital visits. The plan should look to capture and identify these avoided social costs of energy efficiency and support innovative approaches to achieve the co-benefits. One of California's goals is to reduce energy use in existing buildings by 50% by 2030. As noted in the plan (on page 30) Zero Net Carbon Building is an important strategy to achieve our 2050 target, but requires work needs to start now. In that vein, the scoping plan should look to accelerate efforts in the following areas to take advantage of the GHG reduction opportunities in the existing building stock. The plan should evaluate the opportunities to increase energy efficiency in existing buildings to achieve our 50% reduction target including but not limited to the following examples: Explore cost effective ways to reduce GHG emission from a large number of stationary source of CO2 such as furnaces, boilers and water heaters. Identify opportunities to be more aggressive and streamlined ways of weatherizing moderate income homes should be demonstrated and pursued immediately. Demonstrate the opportunity for green building programs to achieve greater reductions in GHGs associated with efforts beyond energy efficiency including overall reduction in energy use, water and resource conservation and waste reduction (possibly in Appendix G in 2017) Support local government initiatives to achieve improvements in existing residential sector. Owner occupied homes can be addressed through requirements at time of sale such as Portland and Berkeley have done. The city of Boulder addressed it rental housing stock through and ordinance to achieve an energy efficiency threshold by a date certain. In light of the potential reduction in federal support for low income weatherization programs in the near future, California may need to expand support to these efforts through other sources in order not to fall shorter of its GHG reduction targets and climate adaptation than planned. Electrification: The plan also identifies the importance of reducing consumption and reliance on natural gas. We understand that we must decarbonize our fuel source in order to meet greenhouse gas emission goals. In this vein, it is recommended that ARB include additional measures to support the decarbonization of our buildings when carbon pricing itself will not be effective. The new policy in Alternative 1 is highly supported, but this option must be coupled with additional actions to have the intended impact on the market. While the technology in the market is increasing, there is a need to make the technology more accessible/affordable, less risky, and more available. In addition, the energy code and the CPUC rule set for fuels switching prevent the electrification of existing homes. ARB should evaluate the scenarios and existing regulation and programs to ensure there are mechanisms to support intended outcomes of carbon reduction. The actions should support fuels switching in existing homes and all electric new homes that will be leveraging a cleaner source of electricity under the RPS. Resiliency: Please consider the opportunity to include resilient design measures for extreme heat and other anticipated climate changes that will affect the most vulnerable populations. Our current building model does not take into account these future impacts and would not address the ability of a building to be thermally comfortable in an extreme heat wave or increased durations of heat waves, as an example. LEED and GreenPoint Rated as green building certification programs have included vulnerability assessments and improvements to address climate adaptation in addition to social equity measures. |
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Original File Name:
Date and Time Comment Was Submitted: 2016-12-16 16:14:44 |
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