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In order to be effective, ARB must make explicit recommendations to
utilize green building opportunities toward achievement of AB32
requirements. ARB’s recommendations with relation to green
building must be clear, and convey motive intent. The green
building section has many ideas prefaced by “Group X could take
Action Y.” ARB has been tasked with recommending - and to a large
degree implementing - solutions to the unprecedented challenge of
reducing California’s greenhouse gas emissions. 

ARB is correct that the majority of individual measures capable of
yielding significant greenhouse gas emissions reductions in the
built environment are largely addressed in other issue areas
within the Scoping Plan, and should not be double-counted under
the heading of Green Building. However, the vast scope necessary
to realize AB32 goals is very complex, and potentially unwieldy.
Existing and upcoming Green Building ratings and metrics are
essential tools to taking an integrated, comprehensive approach at
the project level, and to convey the scope of opportunities for
greenhouse gas reduction and sustainability. Accessible,
intuitively understandable benchmarks, such as the Energy Star
label for buildings and increasing levels of LEED certification,
are tools that help spur the public, practitioners, and investors
to incorporate many sustainability strategies into a given
project. While the California Green Building Code and ongoing
revisions to Title 24 Part 6 energy standards will be the primary
tools for mandatory statewide increases in environmental
performance of buildings, any AB32 related public outreach should
encourage – and incentivize – green building commitments above and
beyond any mandatory standards. 

While ARB has made substantive proposals for greenhouse gas
emissions reduction through alternate fuels and supporting the
efforts of CPUC and CEC to minimize emissions from the operation
of buildings, the best opportunity to influence the future
emissions associated with a building occur in land use planning
and entitlement. Street layout, zoning, and other planning
considerations heavily influence the vehicle miles travelled by
future residents, long term needs to commute to and from a given
site, and the opportunity for effective solar orientation of a
building. With the expectation of 44 million Californians by 2020,
ARB and the state must collaborate with local governments – not
supercede them – to co-locate housing, essential services, and
jobs in new development and redevelopment, to increase the density
of the state’s built environment in ways that will structurally
reduce the transportation needs of the average Californian. San
Francisco, already one of the most dense cities in the western
United States, recognizes that we need to go much further, and is
participating in five separate major development projects under
the USGBC’s LEED for Neighborhood Developments Pilot program,
which provides a benchmark and opportunity for recognition in the
solution to not only greenhouse gas challenges, but opportunities
to increase quality of life by reducing time wasted travelling for
basic neighborhood services. ARB must devote significant resources
to direct support of Smart Growth policies among California local
governments, including provision of consulting dollars, and should
explicitly recommend increased investment in transit in combination
with increased density of existing California communities.

Additional significant opportunities not yet addressed in the
draft Scoping Plan include:
•	Overcome the distinction between capital and operating expenses
in public facilities by establishing and applying a life cycle
costing methodology for state facilities. State adoption of such a
methodology would allow local jurisdictions to employ it as well.
•	California should provide a statewide bond pool to minimize
financing costs for cities establishing energy financing districts
to finance renewable energy systems and energy efficiency
improvements on property tax bills.  AB811 now allows general law
cities to establish such districts on the “Berkeley Model,” which
had previously been limited to charter cities.
•	Work with CEC so that updates to Title 24 Part 6 energy
efficiency standards are targeted at absolute greenhouse gas
minimization. The Base Case in Title 24 energy efficiency
compliance calculations generally utilizes the same systems and
building orientation as the proposed design. This can
inadvertently penalize some significant design opportunities,
including designing for effective natural ventilation. Removing an
HVAC system entirely from a proposed design also removes the HVAC
load from the base case. To cost-effectively move design toward
zero-net energy, it will be necessary to instead propose an energy
budget based on the building size and use type, and give credit for
savings in comparison to a baseline energy budget. The building
energy budget should be based on percentage reductions from
standard practice, such as the Energy Star Target Finder or its
source data, the US Department of Energy’s Commercial Buildings
Energy Consumption Survey (CBECS.)

Last, in order for the ambitious complementary statewide efforts
underway across multiple California state agencies to be
successful, agencies must increase coordination. One helpful
mechanism would be development of a statement and intent of shared
goals – and agreement to defer across jurisdictions – in areas
related to energy efficiency and green buildings. While it’s clear
the California Public Utilities Commission, Energy Commission,
Building Standards Commission, and Air Resources Board are all
obviously aware of one another, it is clear to the outside
observer that there is insufficient communication among state
agencies to effectively align their goals, powers, and outcomes to
realize the state’s ambitious goals. ARB should provide
state-government-wide benchmarks under AB32, and convene regular
public inter-agency workshops and meetings, as well as less formal
exchanges, to keep the state on track to achieve the desired
economy-wide improvements in resource efficiency. 

Original File Name:

Date and Time Comment Was Submitted: 2008-07-30 18:25:15