Comment Log Display

First of all, Climate Resolve, Los Angeles’ climate advocacy
organization, applauds CARB’s groundbreaking work in reducing
greenhouse gas emissions (GHG). Rolling out the California Climate
Investments program is no small feat and the administration is off
to a great start.

However, the greenhouse gas reduction fund (GGRF) has not fulfilled
a key component of the program, namely preparing California for
climate impacts. AB 1532 mandates that program dollars, in addition
to reducing GHG, also “lessen the impacts and effects of climate
change on the State’s communities, economy, and environment.” On
adaptation, the first tranche of GGRF programs have substantively
failed to provide resiliency benefits.

To be clear, climate resilience is not merely thematically related
to the state’s carbon reduction efforts, mitigation and resilience
are profoundly interrelated. Curtailing greenhouse gas emissions
will reduce the need for adaptation. And the benefits run both
ways: attention to climate resilience provides meaningful proof to
the people that climate change is a matter of life and death. 

Climate Resolve proposes that CARB dramatically expand the
Low-Income Weatherization Program, operated by the California
Department of Community Services and Development, to promote a
joint cool roofs and solar roofs program that would reduce GHG,
help people adapt to warmer temperatures, and bestow public health
and economic benefits for disadvantaged communities. These
high-albedo roofing surfaces reflect solar radiation up to fifteen
times more than traditional roofing materials, which means that
during peak summer weather, cool roofs stay approximately 50° to
60°F cooler than traditional materials. Cool roofs reduce the need
to draw on power for cooling buildings, which helps the state reach
its ambitious energy efficiency goals and reduce greenhouses gas
emissions from the power sector. By cooling ambient air
temperatures, cool roofs also help combat the urban heat island
effect, a promising approach for our state’s urban communities to
adapt to temperature increases resulting from climate change.
Extreme heat currently claims more lives than all other natural
disasters combined, so the public health benefits of scaling up
cool roof installations is significant. The urban heat island
effect is usually localized in disadvantaged communities that lack
tree canopy cover, making a cool roofs program right in line with
SB 535 requirements. 

Cool roofs are not only compatible, but they are actually quite
complementary to efforts to increase PV solar installation. Our
experience partnering with Grid Alternatives, a program that puts
PV on qualifying homes in disadvantaged communities, is that many
of those roofs are not structurally sound enough to add PV on top
of them. Replacing these roofs, that are at the end of their useful
life anyway, with cool roofs, has all of the benefits listed above
in addition to making these roofs viable and attractive candidates
for PV installation. That is because PV panels function most
efficiently at 77°F, and also because many PV models can capture
the light that is reflected by the cool roof surface.

Cool roofs are only marginally more expensive than traditional ones
-- in most cases less than $0.50/ft2 more -- yet their widespread
adoption has not yet taken off. By leading this movement with
widespread investments in California, we would help mature the cool
roofing industry and could ultimately set it as standard practice
across the nation. The local cooling impacts are felt immediately,
in terms of comfort and energy bill savings, which gets people and
businesses on board with climate resiliency efforts -- and the
potential of those dividends is tremendous. The project would also
check the box in supporting small-size California businesses.

As it is now, the Low-Income Weatherization Program is tiny in
comparison to the potential it could have to usher in the
widespread adoption of cool roofs. We propose that either this
program get significantly scaled up to meet potential demand and
include specific guidance on cool roofs (by amending the Criteria
for Evaluating Benefits by Project Type, Table 2.A-4 found in
Appendix 2A on page 2.A-11 of the draft funding guidelines), or
otherwise a new standalone program be created to target this
high-potential California Climate Investment sweet spot.

Climate Resolve would very much welcome the opportunity to work
with CARB on developing the proposed program guidelines, and I
thank you for considering the potential of this proposal.

Best regards,
Jonathan Parfrey, Climate Resolve