Comment Log Display

COMMENTS ON AB 32 PROPOSED SCOPING PLAN,
SUBMITTED BY SIERRA CLUB CALIFORNIA, November 19, 2008

3. Energy Efficiency (p. 41)

•  Sierra Club supports all the energy-efficiency efforts listed
by CARB. In fact, we believe that even greater reductions in the
pollution that causes global warming can be gained by further
strengthening efficiency and conservation efforts. In particular,
it is necessary to strengthen independent auditing, measurement and
verification of efficiency measures and programs.  

•  The Plan’s goal of 32,000 gigawatt-hours of electric power
demand reduction by 2020 falls far short of the economic potential
for 60,000 gigawatt-hours of savings if all technology options are
included (as described in the California Energy Commission 2007
Integrated Energy Policy Report, p. 98). The larger goal is more in
line with the Western Governors efficiency recommendation of 20%
reduction from projected demand, which their advisory panel said
was likely achievable well before the 2020 target year if best
practices were used.

 •  The mandatory Green Building Standards Code update scheduled
for 2010 needs to be strengthened. CARB pressure could help. 
Commissioning, quality control and enforcement of green building
standards and practices in actual construction and renovation has
become acutely important as evidence mounts within the trade that
many so-called “green” projects do not deliver the efficiency
savings advertised.

 •  Can CARB provide more detail in terms of the three measures in
CR-1 (separate out the expected reductions from the three
strategies outlined)?

•  By 2020, California should be able to go well beyond the SB
1470 goal of only 0.1 million tons of annual reductions from solar
water heating, through encouraging public-private partnerships.

•  CARB should recommend to the CPUC that energy-efficiency
programs be administered independently from the utility companies,
and expand the use of Standard Offer contracts based upon
performance. The California Public Utilities Commission
investigated this in 2002 and concluded that independent providers
were more cost effective, particularly for residential customers.
The CPUC is developing independent and objective systems for
measuring and verification of energy-efficiency program savings,
and should be urged to fully deploy this in a timely manner.