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Comment 22 for Green Building Comments for the GHG Scoping Plan (sp-greenbuild-ws) - 1st Workshop.
First Name: Heather
Last Name: Larson
Email Address: hlarson@stopwaste.org
Affiliation: Green Building Program Manager
Subject: Green Building and Energy Efficiency measures
Comment:
1) We support that in the appendices the plan identifies green building as a measure under consideration to achieve emissions reductions across sectors. We would like to see clarification around the assumption that the CBSC adopted green building code will be mandatory by 2011, beyond the 17 residential measures currently identified in the standards by HCD. We don’t see how other measures will become mandatory, particularly some of the prescriptive measures, especially since the green building code has been adopted for publication. We are not clear on the proposed public process for these measures to be included as mandatory provisions in the 2010 edition of the California Green Building Standards Code. 2) As the plan states, even if the green building code is mandatory, the state will need to set targets for buildings to go far beyond the green building code in order to reach the reduction goals. The methods for doing so are relatively well defined for government facilities and schools but are less defined for the commercial and residential sectors. We recommend the state promote commercial and residential green building programs (Utility and third party) that contain performance standards for energy efficiency to remedy this discrepancy, particularly since they provide a solution to the legal barriers of prescriptively requiring higher efficiency appliances and equipment. It is unclear how the state will promote or provide incentives to local governments, building industry or the consumers to encourage the use of these green building programs. 3) Language around the % above code requirements/ recommendations/ targets is not entirely clear; the CEC T-24 part 6 2008 energy code update is referred to as a green building measure and assumed to be 15%-20% better than current code (T-24 2005). This causes confusion when using similar language for Utility, green building and NSHP energy efficiency program requirements that are referring to exceeding the 2008 code. Also, as the code becomes more stringent the % better than code definition will change and we recommend tying building energy efficiency criteria to a fixed scale (HERS Index). 4) The appendices acknowledge that we would need to leverage the Utility programs to meet efficiency targets, and to meet the goals set forth would require unprecedented success of Utility programs. Towards this unprecedented success, we would like the plan to further identify how green building programs (which include energy efficiency credit/requirements) and their adoption at the local government level will enable the success of utility programs.
Attachment: www.arb.ca.gov/lists/sp-greenbuild-ws/23-ab_32_scoping_plan_comments_gb_stopwaste.org.doc
Original File Name: ab 32 scoping plan comments_GB_stopwaste.org.doc
Date and Time Comment Was Submitted: 2008-08-11 18:11:23
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