| Comment | California has
been a national leader in setting goals and taking action to
mitigate the impacts of climate change. However, if we do not set
clear priorities, benchmarks, and milestones for decarbonized and
climate-resilient public school buildings and grounds, in alignment
with the state’s 2045 climate goals, then we will put those
vital goals at risk – and we will undermine the learning,
health, and well-being of our 5.9 million students and 650,000
teachers and staff.
California’s 10,545 TK-12 public schools encompass about 125,000 acres of land and more
than 730 million square feet of buildings, making them one of the
largest sectors of public infrastructure. California spends
$15 billion every year on building, maintaining and operating its school
facilities without aligning those investments with our goals for
carbon neutrality and climate resilience. The operation,
maintenance, and upgrading of these buildings involves a patchwork
of local and state funding and responsibilities.
In order to
ensure that those investments work towards the state’s 2045
goals, and not against them, we urge you to consider the following
amendments to the scoping plan:
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Name and prioritize K-12 public school
buildings and grounds in this scoping plan. While the
scoping plan names the need to decarbonize residential and
commercial buildings, it does not refer to public school buildings
and grounds. While
California Green Building Standards Code (Title 24: Part 11) may
eventually require that new school buildings be net zero, districts
are neither on a date-certain timeline to eliminate fossil fuel
systems and equipment from schools nor to address climate
resilience in our buildings and grounds. This is also true of
ongoing maintenance and operations to existing buildings. School
facilities are funded through both state and local sources, and
they are typically left out
of greenhouse gas
emissions-reduction laws that have compelled action by cities and
counties; as a result, school facilities investments that can have
lifespans of over 30 years are being made without consideration for
the state’s 2045 goals. Calling out school buildings and
grounds in the scoping plan will send a powerful message to
education leaders about their role in meeting the state’s
goals as they make decisions about $15B each year.
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Prioritize both decarbonization and climate
resilience in school facilities investments. Outdated
buildings have profound implications for children and
teachers’ health, harming all students and aggravating racial
inequities. Students spend approximately 16,000 hours of their
lives in school from Kindergarten through 12th grade, making
schools second only to the home for children’s indoor
exposure. The effects of climate change, including extreme heat and
wildfire smoke, impact students’ ability to learn, and many
schools are not equipped with air filtration and electric cooling
mechanisms in schools to protect students from these dangers and to
keep schools open during peak instances of heat and smoke. Anxiety,
disruption and trauma lead students to disengage from school. Lost
school days have been shown to diminish learning as measured by
standardized test scores. We must ensure that school buildings and
grounds are both decarbonized and climate-resilient to protect
students from the worsening effects of climate change in our state
and to keep schools open to promote student health and
learning.
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Ensure school district leaders are actively
engaged in local planning processes. Appendix D discusses the importance of
local planning and coordination around decarbonization planning.
However, when city and county leaders develop climate action and
adaptation plans, K-12 schools are not obligated to comply, and are
often overlooked in the planning process. We must name and ensure
that K-12 education leaders are a core part of local planning and
decision-making to ensure that their facilities and grounds
investments are aligned with both state and local
goals.
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Ensure school infrastructure investments in
response to COVID-19 align with state climate goals. For the next 5
years, schools will be upgrading HVAC systems using a mix of
federal, state, and local dollars to ensure schools have proper
ventilation to mitigate the impacts of COVID-19. Without clear
guidance or mandates, many districts will install new fossil-fuel
driven HVAC systems that have lifespans of 25-30 years. In order to
meet California’s statewide goals, the state needs to ensure
that these once-in-a-generation investments in school HVAC systems
require electrification and meet strong standards aligned with
climate goals. Please contact us if we can be helpful by providing
more detailed guidance and language to support this
goal.
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