Comment Log Display
Below is the comment you selected to display.
Comment 20 for 2030 Target Scoping Plan Concept Paper (sp-concept-paper-ws) - 1st Workshop.
First Name: Mona
Last Name: Sheth
Email Address: msheth@ajw-inc.com
Affiliation: AJW, Inc.
Subject: Scoping Plan Concept Materials for Third-Party Delivered EE
Comment:
California has developed a comprehensive statewide program to reduce greenhouse gas (GHG) emissions. The state is rightly recognized as global leader in the effort to combat climate change. As the Scoping Plan Concept Paper recognizes, however, greater effort and innovation is needed to meet future GHG reduction goals to avoid the worst impacts of climate change. Governor Brown has identified the built environment as one of the key “pillars” for additional action (http://www.arb.ca.gov/html/fact_sheets/2030_energyefficiency.pdf). A doubling of energy savings from efficiency measures in buildings is called for over the next fifteen years. While challenging, these savings can be realized if California adopts new or modifies existing policies that more fully incentivize deployment of energy efficiency in the built environment. Third-Party Delivered Energy Efficiency (TPDEE) is a key tool that California can more broadly utilize as part of these efforts. TPDEE includes all forms of energy efficiency projects other than utility- or ratepayer-funded projects. TPDEE projects comprise the majority of efficiency projects conducted in non-residential buildings. Government facilities, schools, universities, hospitals, public housing, industrial facilities and commercial buildings are generally better addressed through TPDEE strategies, and are most often implemented either by an energy service company (ESCO) or by the facility owner or operator. TPDEE approaches and projects deliver customized, turnkey energy conservation solutions financed by cost savings. These private sector-financed projects complement traditional utility-led EE programs and ensure quantifiable GHG reductions. These projects require no ratepayer of taxpayer funding; strengthen state industrial competitiveness; and create quality jobs in the construction and energy sectors. Many states are effectively utilizing TPDEE projects to achieve significant energy efficiency savings. Under the Bush and Obama Administrations, the federal government has pursued significant TPDEE investment in its own facilities. Additionally, the Final Clean Power Plan included TPDEE approaches as a clear option for states to employ to achieve compliance with the rule. While California is a usually a leader in energy efficiency efforts, it has not capitalized on maximizing efficiency in non-residential buildings as other states have done. For example, nationwide, efficiency investments made through the TPDEE tool known as Performance Contracts (PC) are roughly equal to the efficiency investments made through utility- or ratepayer-funded projects. Yet, in California, the only PC projects implemented are on federal sites such as military facilities. In fact, California ranks 35th, trailing states such as Alabama and Rhode Island, in terms of PC-driven efficiency. Additional information is attached regarding the role additional TPDEE could play in California’s efforts maximize savings from energy efficiency and to achieve significant reductions in GHG emissions. Our coalition looks forward to working with policymakers in California and at the Air Resources Board to maximize these opportunities.
Attachment: www.arb.ca.gov/lists/com-attach/22-sp-concept-paper-ws-AHMBclMiByQAaQBy.zip
Original File Name: Supporting Reference Materials CARB Submission.zip
Date and Time Comment Was Submitted: 2016-07-08 12:49:47
If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.