Our Comment on the 01/12/23 Staff Workshop on the CalSHAPE Ventilation Program HVAC

Dear Commissioner McAllister:

On behalf of the undersigned organizations, we thank the California Energy Commission (CEC) for the opportunity to comment on the Staff Workshop on the CalSHAPE Ventilation Program HVAC Upgrade and Repair Grants. We greatly appreciate the CEC hosting a workshop on this topic and for its leadership in accelerating our clean energy goals. We write in strong support of the CEC proposal that CalSHAPE HVAC Upgrade and Repair Grants be used for only the installation of zero emission equipment and prioritize funding for schools in underserved and environmental justice communities, near busy roadways, and in communities with poor air quality. And more specifically, we support proposal Option 1 (slide 23): HVAC system replacements with gas equipment should not be eligible for a grant award. 

Residential and commercial buildings account for a quarter of the state’s greenhouse gas (GHG) emissions, and heat pumps are a critical enabling technology for decarbonizing our buildings. As part of California’s decarbonization vision, the state set a goal of installing at least 6 million heat pumps by 2030. This target will require the rapid deployment of heat pumps to decarbonize our building sector, including in our K-12 schools. 

California’s 10,000 K-12 schools – more than 730 million square feet of buildings on nearly 125,000 acres of land – comprise one of California’s largest sectors of public infrastructure, representing billions of dollars of state and local investment. Given that some facility investments have lifespans of more than 30 years, we must ensure that our current actions accelerate progress toward our long-term carbon neutrality goals. It is vital that the state supports vulnerable communities and critical community buildings, such as schools, in becoming independent from the aging gas system. To ensure an equitable zero-emission transition, it is critical to prioritize funding in low-income, environmental justice communities.

Shifting CalSHAPE’s remaining funds to zero emission infrastructure will also improve the efficiency and health of these facilities. Upgrades to school facilities can help remedy air quality issues, improve comfort and health conditions, support better student learning, and provide reductions in school energy bills. In particular, clean energy HVAC systems are integral to learning and health in schools by providing comfortable temperatures with ventilation and filtration for good indoor air quality (IAQ). 

We thank the CEC for its diligent efforts on progressing our clean energy goals and heat pump deployment. We look forward to continued engagement with the CEC as the state looks to decarbonize its building stock to achieve its climate goals.