SmartRegs letter to Council
The following letter was sent to the Boulder City Council on behalf of PLAN-Boulder County by Leonard May on September 6, 2010:
6 September 2010
Dear Mayor Osborne and Boulder
City Council,
Since adopting a Climate Action Plan (CAP) in 2002 that
committed to reducing greenhouse gas (GHG) emissions by 7% of 1990 levels by 2012,
Boulder’s
greenhouse gas (GHG) emissions have actually increased. Boulder’s
most recent climate action report indicates essentially no GHG reduction (1.5%
decline) for 2009, the second consecutive year of flat results. Boulder’s lack
of progress means that there is virtually no possibility of reaching the 2012 Kyoto goal. However, we can still reach the 2020 goal but
only if we take aggressive action now.
PLAN-Boulder County
strongly supports Smart Regs. This government
intervention is necessary because the split incentive in the rental market
ensures that landlords will not perceive a direct financial benefit for making GHG
reducing improvements, and consequently improvements will not be made.
PLAN-Boulder County also supports the concept behind Option
C. However, we have serious concerns
about the phase-in date extending to January 2, 2019. Extending the Smart Regs compliance date to
2019 means that sixteen years will have elapsed since stating a GHG reduction
goal and taking one of the first concrete steps toward that end. Allowing almost a generation to pass hardly
shows resolve.
Further, extending the timetable to 2019 does not change the
expense that landlords will ultimately incur. If landlords finance extensive
improvements rather than pay for them out of cash flow, extending the
compliance timeframe has no impact other than delaying implementation.
If, on the other hand, landlords pay for improvements out of
cash flow, they are likely to do so incrementally over time rather than wait
until the end of 2018. Therefore, no hardship is created by requiring
incremental improvement between now and the compliance date as landlords are
likely to make those expenditures anyway.
After 8 years of no progress toward GHG reduction, we should
not continue to delay substantive action while setting yet more goals and missing
yet more targets and then creating easier targets. What is gained by
delay? Landlords and renters will have
all the same issues to contend with in 2018 as they will in 2014 and that they
do now. The climate won’t wait. It's
time to get serious!
In order to achieve our 2002 climate action goal and ensure
continuous incremental progress between now and the compliance date ultimately
agreed upon, City Council should take the following steps in adopting Smart
Regs and a revised Option C:
- Accelerate
the phase-in term to 4 years with a January 2, 2015 compliance date.
- Require
prescribed levels of building performance improvements prior to the compliance
date, such as 50 points midway through the phase-in period.
- Require
scheduled performance benchmarks that are tied to prescribed corrective actions
if benchmarks are not achieved.
Establishing a reporting regimen is not terribly useful if at the outset
there is no plan to do anything with the information in the reports.
It is easy
to lose perspective with the climate change issue by focusing solely on local
impacts. Regionally there may be
financial losses by people and businesses such as landowners affected by the
pine bark beetle. There may be impacts
to agriculture and to everyone by alterations in precipitation or runoff
patterns. But there probably won’t be
major or repeated major natural disasters and catastrophic widespread loss of
lives or livelihoods.
But what we
do or don’t do, or delay doing, ultimately does impact people elsewhere. The atmosphere doesn’t care where GHGs emanate
from.
This is why
it is so important for Boulder
and City Council to look at Smart Regs from a holistic and global
perspective. Twenty million people are directly
affected by monsoon related flooding in Pakistan and more than half the
world's population depends on the annual Asian monsoon for water. Only slight deviations from the normal
monsoon pattern can have great impact according to Purdue University
research, causing less summer precipitation, a delay in the start of monsoon
season and longer breaks between the rainy periods. Alternatively, increases in precipitation over
some areas could exacerbate seasonal flooding.
Heavy monsoon rains in central India between 1981 and 2000 were
more intense and frequent than in the 1950s and 1960s, and increased by 10 per
cent since the early 1950s. Severe rains doubled over the same period and at
the same time, there were fewer moderate rains.
The trends are likely linked to rising global temperatures, according to
the Indian Institute of Tropical Meteorology.
For a comprehensive report on the impacts of climate change
refer to the Intergovernmental Panel on Climate Change, (IPCC), the world’s
most authoritative body on the subject.http://www.ipcc.ch/publications_and_data/ar4/wg2/en/contents.html
.
Our combating climate change and our leadership will have
worldwide impact but every person will have to contribute to the effort in
order to succeed. To delay or fail will also have worldwide repercussions
with repeats of events such as the Pakistan flooding, at increased
frequency and ferocity. We Americans, as the 2nd largest
generators of GHGs, have a large share of the responsibility to change.
Ordinary people through simple but noble acts can change the
world, even in the face of opposition by powerful forces.
Mahatma Gandhi: "Be the change you want to see in the
world."
Leo Tolstoy: "Everyone thinks of changing the world, but no one
thinks of changing himself."
City Council should seize this opportunity to change the
world by boldly and swiftly enacting Smart Regs with an accelerated results
based timetable. Act nobly, think
globally.
Leonard May for PLAN-Boulder
County
The following statement to the Boulder City Council was made on behalf of PLAN-Boulder County by Pat Shanks on May 18, 2010:
SmartRegs statement to Council
I’m Pat Shanks- 3345 Broadway- speaking for PBC.
Remember the campaign for the carbon tax in 2006? Remember all the conversation about “low hanging fruit?” This of course means tackling the easy chores first, and in the context of climate action it means attic insulation, sealing air leaks with weather stripping, caulking, and other means, adding energy efficient light bulbs, adding flow restricted showerheads, etc. These are easy and relatively inexpensive. SmartRegs is designed to spur harvesting the low-hanging fruit.
PLAN-Boulder has made climate action our number one advocacy priority because this is the most serious challenge facing our planet and our city. Boulder has led the way before in other areas, and our first-in-the-nation climate action plan follows that tradition. Other cities around the globe are looking to us to show the way, and ``SmartRegs is a critically important step.
City of Boulder in 2002 adopted a climate goal that requires reducing greenhouse gas emissions by 23 percent (to 7 percent below 1990 levels) by 2012. And we need to go far beyond that first step to reverse global warming. Goals defined by the Governor’s Energy Office require reduction of 80% by 2050.
To meet the 2012 Kyoto goal, we need to reduce our carbon emissions in Boulder by about 400 thousand tons. Residential building consumption in Boulder is currently about 225 thousand tons per year, so reductions can have big impact.
SmartRegs are a critical piece of the puzzle. Numerous studies have shown that increasing energy efficiency of our buildings requires a “carrot and stick approach.”
Reasons to support SmartRegs-
- About 50% of our housing stock is in rentals.
- It is a question of social fairness. Some of our least affluent residents are paying unreasonable energy costs because of poorly sealed and insulated apartments.
- In many rental units, small investments can harvest big reductions in carbon emissions.
SmartRegs represent a first step in adding the stick (regulatory clout) to the Climate Action Plan, as part of the broader effort to improve energy efficiency across all building types in the city.
We recognize that landlords will have to bear the initial costs of efficiency upgrades, but there is a lot of help available-
- Landlords may deduct and depreciate improvements as the cost of ownership,
- They can apply for a ClimateSmart loan, which allows a 15 yr payment on the property tax. For example $2000 worth of attic insulation- about R60 in a 1000 ft house- would cost about $20 a month and would result in substantial saving. Note: this program requires participants to sign an energy disclosure waiver, so we will have metric for whether this is working.
- Energy rebates will significantly offset the initial costs.
PLAN-Boulder County supports SmartRegs as recommended in the staff memo and urges you to pass it on first reading.
