Comment Log Display

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.