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Comment 15 for Energy Comments for the GHG Scoping Plan (sp-energy-ws) - 1st Workshop.
First Name: David
Last Name: Assmann
Email Address: David.Assmann@sfgov.org
Affiliation: City and County of San Francisco
Subject: City of San Francisco Comments on Electricity and Natural Gas
Comment:
The Draft Scoping Plan recognizes that some local governments are already very active in this field; however, many are not. Everything needs to be done to build the capacity of local governments to take action, not only in their own facilities, but to participate in the reduction of GHG´s throughout their jurisdictions. First, Climate Change needs to be brought to the attention of local elected officials. CARB and the Governor´s Office should sponsor workshops with elected officials of every city and county in California. This could be done in ten or so regional meetings. ARB, the Governor, the corresponding members of the state legislature, and local elected officials should meet to discuss the goals, the how this will impact their jurisdiction, their role, how to build their capacity in each local government, and how to build support in their jurisdictions. Second, they need assistance with the ability to take action. Technical assistance can be made available through contracts at the CEC and regional workshops and mentoring can be sponsored by ARB. ARB expects the value of GHG emissions reduction to be determined through a market mechanism of offset trading; however, there are many activities that will not be part of the trading system due to the difficulty of documenting and monitoring ‘additionality’ and other necessary trading criteria. The Draft Scoping Plan stresses the need to expand energy efficiency and renewable energy programs; however, these are investment decisions that are made based on the value of those reductions. Given the vastly destructive ‘potential’ of Climate Change, previously calculated values are undoubtedly too low to have much impact on investment decisions. For example, the CPUC sets energy efficiency cost-effectiveness criteria that affect the investments made by PGC funded programs. That calculation must include what reductions can save in Climate Change impacts, ie avoided costs incurred on the ‘adaptation’ side. New statewide requirements for existing buildings must be addressed through a combination of time-of-sale requirements as well as ‘date certain’ approaches. Air-sealing, ceiling and wall insulation, and solar water heating can dramatically reduce natural gas use. Development of these requirements can leverage existing experience of local ordinances and enforcement will require active participation of all local governments. Additionally, the real estate, remodeling, and repair industries should be engaged by CARB and the Governor´s Office to enlist their participation. In the future, contractor or other State licensing should be contingent upon certification in GHG reduction and monitoring of each license recipient’s activity. The State Board of Education needs to be engaged in the development and implementation of Climate Change curriculum as well as incorporation into the testing requirements. Teachers and schools are frequently overwhelmed by existing requirements and view ‘new requirements’ as just more work. Climate Change can be incorporated into existing work but in some cases it may mean supplanting existing activities. Teachers and schools need direction from the State Board.
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Date and Time Comment Was Submitted: 2008-07-30 18:23:53
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