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Comment 176 for AB 32 Scoping Plan (scopingpln08) - 45 Day.

First NameEdward
Last NameMainland
Email Addressemainland@comcast.net
AffiliationSierra Club California
SubjectSierra Club Comment on Green Building Strategy
Comment
COMMENTS ON AB 32 PROPOSED SCOPING PLAN,
SUBMITTED BY SIERRA CLUB CALIFORNIA, November 19, 2008

13. Green Building Strategy (p. 57)

•  Industry evidence indicates a disquieting fact: in so-called
“green” buildings, we are not getting advertised energy
conservation results owing to improper installation of energy
saving features like insulation, framing and lighting.  Poorly
installed batt-type installation can reduce energy reductions as
much as 80%.  With improper installation, air leaks occur in the
house or building envelope so hot or cold air enters freely, thus
negating any energy savings in cooling or heating designed in the
plans.  Some solar panels are poorly placed. Some reported test
data show that supposedly “green” buildings actually use more
energy once in operation than a well-built regular structure.

•  Apparently, many contractors don't train employees or give them
the time on the job to carefully check their work, nor do building
inspectors find these problems.  More critical is the construction
industry in general is not "Performance Based.” For example, a
building can get “green” status without ever proving if it is
indeed saving energy.  Without feedback, the contractors and
inspectors don't learn, and the architects never learn if their
plans are actually successful in saving energy.  

•  The solution is requiring verification of building  performance
before occupancy.  In addition, a building could get a temporary
green building certification but it would not be final until
several years of energy data are collected to prove that the energy
reductions are actually being achieved. Contractors need to train
their regular employees plus have a well-trained supervisor
carefully watching their day labor force implement correct
techniques. Building inspectors need to be trained, and they need
to enforce proper construction at every step of the project and on
every building in a project. Awarding any state-level green
building certification should be conditional on demonstrated
efficiency.

Absent from the Scoping Plan is a discussion of existing community
preservation and historic preservation.  While green building is
critical for new construction, it should not be used as an excuse
to tear down historic buildings or existing communities. 
Recognition of community preservation and related historic
preservation should be a part of all landuse decisions.  Since
demolition comprises a significant portion of waste generated in
California, community preservation is the source reduction part of
development.  Adaptive reuse of buildings either in place or by
relocation should be discussed either in the Green Building section
or under landuse as well as linked to the Recycling and Waste
section.


Attachment
Original File Name
Date and Time Comment Was Submitted 2008-11-19 19:03:51

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