Comment Log Display

Dear California Air Resources Board:

On behalf of the Collaborative for High Performance Schools (CHPS)
I am submitting comments to recommend that K-12 public schools be
included as an investment priority for Greenhouse Gas Reduction
Fund investments in ARB’s draft Three Year Investment Plan. We
recommend that a new “High Performance Schools” goal be established
and supported by a new “Healthy & Sustainable Schools” grant
program.

One in five Californians spends their day in a K-12 school and
schools contribute roughly 5-8% of California’s greenhouse gas
emissions from energy and water use, transportation, waste, heat
island effects, and more. We support the ARB’s goals for
sustainable communities and reducing greenhouse gas emissions 40%
below 1990 levels by 2030. We believe that California cannot
achieve its goals for sustainable communities and greenhouse gas
reductions without the participation of the state’s 10,300 schools.
Schools are the heart of our communities, housing more than 6
million children and thousands of teachers and staff every day.
Schools are responsible for about 5% of municipal solid waste or
about 763,817 tons per year, about half of which is food waste
(contributing to landfill methane emissions) and about one-third is
paper waste.  Schools have enormous roof and asphalt-covered
acreage contributing to heat island effects and polluted stormwater
runoff. Dirty diesel school buses spew black carbon, increasing
vulnerable children’s exposures, according to ARB’s own studies. 

In contrast, healthy, high performance schools reduce carbon
footprints substantially, save scarce funds, and engage millions of
students, teachers, staff, parents, and school board members in
learning about and practicing environmental sustainability, and
preparing students for green careers and civic responsibility. For
a modest size school district with 9,600 students, the EPA WARM
model predicts that switching the bus fleet to biodiesel can save
582 M tons CO2, increasing the recycling rate from 30% to 35% can
save 461 MT CO2, and adding 32,000 square feet of photovoltaics can
save 441 MT CO2, for a total of 1,484 MT CO2 for one school
district. If all 1,000 California school districts invested in
integrated projects to reduce greenhouse gas emissions, they would
contribute millions of tons of savings. 

Schools are the perfect local venue to invest in integrated
projects that produce numerous co-benefits, including: active
transportation (Safe Routes to School); zero emission school buses;
recycling and composting; tree planting and asphalt removal to
reduce heat island effects and create green schoolyards and outdoor
classrooms; cool roofs; energy and water conservation; stormwater
capture; and other measurable greenhouse gas reduction projects.
And these projects can also serve as visible, hands-on
sustainability learning tools for students and the community.
Several school districts and individual schools in California are
leaders in sustainability.  But the majority of schools – and
especially those in disadvantaged communities – have outdated,
inefficient, unsustainable buildings, grounds, and operations that
contribute to climate change.

ARB’s Draft Three Year Investment Plan does not include K-12
schools as an investment priority for greenhouse gas reductions – a
big gap. The word “schools” appears only once on page 11 of the
draft Plan.  There is one existing program under ARB’s Hybrid and
Zero Emission Truck and Bus Voucher Incentive Project (HVIP) that
includes grants for rural school districts to invest in
lower-emission school buses, and should be continued. Other grant
programs, such as the Organics and Recycling programs managed by
CalRecycle and the Urban Forestry tree planting programs managed by
CalFire, do not include school districts as eligible applicants
(though they could apply with non-profit or local government
partners; in reality school participation has been low).
Proposition 39 provides funding for energy efficiency and
renewables at existing K-12 schools, but does not cover other
greenhouse gas reduction projects like transit, composting, tree
planting, or asphalt removal. And the estimated funds needed to
fully achieve “zero net energy (ZNE)” and “zero emission” schools
are an order of magnitude beyond the funds available and scope of
Proposition 39.   

We urge ARB to include “High Performance Schools” as an investment
element in its Three Year Investment Plan 2016-2019 and to ensure
that K-12 public school districts – especially those in
disadvantaged communities designated by CalEPA – are eligible to
receive GGRF funds via existing or new grant programs. While we
recognize that K-12 schools do not fall under the Administration’s
jurisdiction, healthy, high performance schools are critical to
achieving the State’s greenhouse gas reduction goals.  Currently,
the barriers for K-12 school districts to pursue greenhouse gas
reduction funds are too high, requiring separate complex
applications and reporting to different agencies, and managing
separate partnerships in order to be eligible.

We recommend the establishment of a “Healthy & Sustainable Schools”
integrated grant program for school-based climate action projects
with a single coordinating agency that could coordinate the review
of particular school district greenhouse gas grant applications
with the other relevant state agencies (ARB, CalRecycle, CalFire,
etc) and administer funds to public school districts. Priority
would be given to support greenhouse gas reduction projects at
school districts in disadvantaged communities. This program could
build on existing partnerships between ARB (like the HVIP),
California Department of Education, California Energy Commission
(partnering on Prop 39), California State Water Board (Drought
Response Outreach Program for Schools/DROPS), and others. 

ARB can also consider other means of including K-12 schools and
districts in its investment priorities, whether through
strengthening existing programs, changing eligibility requirements
of existing programs, and/or including schools in other programs
aimed at achieving Sustainable Communities.

CHPS is a national non-profit headquartered in Sacramento,
dedicated to making every school an ideal place to learn.  The
California CHPS (CA-CHPS) Criteria has been the standard for
healthy, high performance schools in California since 2002.  The
new 2014 CA-CHPS Criteria www.chps.net/california embraces a design
toward ZNE paradigm and creates a pathway toward ZNE for new
schools and 50 percent of existing schools by 2030.
Thank you for your consideration of our comments to include schools
as part of California’s solution for mitigating climate change.

Sincerely,

William R. Orr
Executive Director
Collaborative for High Performance Schools