Bruce Mast Sent via email: bmast@frontierassoc.com

    Frontier Associates

    P.O. Box 31356

    Oakland, CA 94604

    bmast@frontierassoc.com

    This correspondence is written regarding the Frontier Associates program proposal entitled "Green Building Technical Support Services." We request the following additional information regarding your proposal:

    · Detailed advisory plans. In what manner will participating cities and/or counties will be advised to adopt the ACWMA residential green building guidelines, and USGBC LEED commercial guidelines and rating system? For example, if financial incentive programs will be suggested, please outline suggested incentive structures. If other methods of adoption will be suggested, please outline suggested plans.

    A response should be provided via e-mail, by noon on Tuesday, March 19, 2002. Please send your response to tdh@cpuc.ca.gov. If you wish to mail a hard copy as well, please use the address listed in the above letterhead, Attn: Tuukka Hess, Energy Division.

    Thanking you in advance for your prompt response,

    Energy Division Staff

    CPUC

On behalf of Frontier Associates and our project partner, Austin Energy, I appreciate the opportunity to provide additional clarification on our Proposal for Green Building Technical Support Services, submitted to the PUC in response to R.01-08-028. I also apologize for the confusion in not recognizing your communication as being specifically directed to me.

In your letter of March 14, you asked for additional information about the manner in which participating cities and/or counties will be advised to adopt the ACWMA and USGBC guidelines. The specific answer to this question will vary on a case-by-case basis but we can sketch out some guiding principles.

The most important principle is that the adoption strategy must be politically viable. Thus it must be consistent with the mandate the governing body has given its staff to develop such a program. If staff is developing a Green Building proposal to present to the governing body for approval, the plan must address specific issues and concerns council members or supervisors might have. The adoption strategy must take into account the relationships between the governing agency, the construction and real estate industries, the broader business community, the voters, community groups, and other stakeholders. As these examples illustrate, we will need to explore the political context within each agency considering adoption in order to craft an adoption strategy that acknowledges any constraints and capitalizes on any opportunities. In some cases, we may be able to modify that context via education and persuasion but we can never ignore it.

A second key principle is that the adoption strategy must represent sound public policy. We consider sound public policies to be those that are cost effective, broadly speaking. We recognize that the benefits of green building are often more difficult to quantify than the costs. Nevertheless, a dispassionate assessment of a sound policy should lead to the conclusion that the likely benefits well outweigh the expected costs, at least from a societal perspective.

A third key principle is that the adoption strategy must be financially and institutionally viable; that is, it must be sustainable. We recognize that a primary barrier limiting local governments' ability to develop green building programs is a lack of technical and human resources. Our proposal is tailored to overcome that barrier. Still our involvement is designed to be of limited duration. The Frontier Team will help develop an adoption strategy but then we will exit the scene. At that point, the agency must be capable of carrying it out over the long term. Thus, the strategy must fit within the agency's financial resources and the policy priorities it has set for those resources. In-house responsibilities must fit within the agency's available staffing.

A corollary to the first two principles is that, all else being equal, the adoption strategy should be generally consistent with the green building adoption strategies in neighboring jurisdictions. This is not to suggest that sensible strategies should be watered down or discarded in mere deference to the neighbors; nor that there is no room for creativity in designing good strategies. We simply mean that uniform program guidelines across jurisdictional boundaries facilitate compliance, thus reducing compliance costs (and improving cost effectiveness) and improving political viability. In designing an adoption strategy, the value of uniformity should be considered.

It is our intention to promote the Alameda County Residential Green Building Guidelines for residential construction in the area due to the fact that Alameda County's guidelines were written by a local development committee made up of government officials, respected leaders in the local building industry who work throughout the San Francisco Bay area, and are known U.S. experts in the field of green building. Their guidelines are of high quality, are appropriate for the local climate, are appropriate for the local building industry, and are already showing signs of strong acceptance by the local building industry and the local marketplace. This does not exclude the option of a local government agency from using their own guidelines, but the Alameda guidelines do create a very appropriate template for the region.

It is our intention to promote the use of the US Green Building Council's Leadership in Energy and Environmental Design (LEED) Commercial Green Building Rating System for use in designing, building, maintaining, and evaluating municipal and institutional buildings. Although this does not preclude the use of another system by a government agency, we have chosen this system because it has become the standard rating system throughout the country for evaluating commercial green buildings. It is an organized, thoughtful and doable system. Government agencies have consistently and dominantly chosen this system over any other system as their primary evaluation and specification tool. LEED has also been heavily funded and supported by the US Department of Energy and Environmental Protection Agency. Among others, it is being used by the US Dept. of State, US Forest Service, US National Parks Service, US Department of Commerce, US Department of the Navy/Air Force/Marines, and the Cities of New York, Austin, Portland, and Seattle.

Given these considerations, we see our role as helping agency staff assess the trade-offs of a variety of possible adoption strategies and then design and implement a plan that fits their needs. Adoption strategies could include any of the following:

_ Direct financial incentives for green building projects

_ Incorporation of green building incentives or requirements in the planning code

_ Project-specific design assistance

_ Marketing support

_ Education and training for members of the construction, real estate, and financing industries and then general public

_ Resource guides and referrals

_ Building commissioning

_ Demonstration projects

_ Builder and/or building certification

This list is by no means exhaustive. As I have hopefully made clear, we will not advocate for a specific adoption strategy. Rather we will act as facilitators, providing technical support and information to help policy makers choose strategies that fit their needs and circumstances.

Thank you again for this opportunity to respond to your questions. I would welcome any other inquiries you might have.

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