Jul 19 2021
Dear Council, Staff, and Members of the Pool Advisory Committee,
My sense from last week’s Pool Advisory Committee and from speaking with Council Members is that everyone involved in this project wants a pool facility that emits as few carbon emissions as possible. But the schedule and work plan presented at last week’s Pool Advisory Committee meeting, as well as the draft RFP for a project design team before you tonight have me deeply concerned that we are not on track to do this. I believe that right now we are in danger of being lulled into a design process that is biased, inadequate, and likely to lead to failure. I urge you to send this RFP back to the drawing board and to re-evaluate the project timeline and milestones.
Piedmont’s Climate Action Plan
How we set up the design process for the pool facility now will determine whether or not we are able to make its operations as close to zero carbon as feasible. From the looks of the RFP, we aren’t making a serious attempt at all. First of all, why is there absolutely no mention of Piedmont’s 2019 Climate Action Plan in the RFP? The CAP is a guiding document for the City, developed by staff with community input and approved by Council. If we aren’t going to pay attention to it now, for the first new major municipal construction project since it was passed, why did we bother investing our time and energy to develop it? Why don’t we just admit to the world that we in Piedmont value our comfort and convenience over making a serious effort to reduce our GHG emissions? An explanation of the Climate Action Plan and Piedmont’s GHG emissions targets needs to be part of the “Background” section of the RFP, and it needs to be made clear to potential bidders that their proposals need to clearly explain how they will approach reaching these emissions reduction targets.
2017 Conceptual Design
Planning for serious GHG emissions reductions in line with California and Piedmont emissions reduction targets has not been part of the conversation about the new pool facility to this point — not in the conceptual design process (at least rigorously), not in the UU campaign, not in the interviews for Pool Advisory Committee members. Granted, the early stages of this process were before the completion of our 2019 CAP and before the developed world started to experience widespread and unmistakable climate disasters. Now that we know how concertedly we need to act to mitigate climate change, we cannot move forward assuming that the 2017 conceptual design is the project “bible” and that everything must be planned around it. I am very concerned, based on information presented at the first PAC meeting and in this RFP, that staff and the project management team see that conceptual design as already being locked in.
Previously, Connect was told that the 2017 conceptual design was just a placeholder and that it would be thoroughly re-done when the actual project began. However, the information presented at the PAC meeting seemed to indicate that this 2017 conceptual design is what will be taken before the public for “validation.” Since it’s old, the conceptual design doesn’t take into account the emissions reduction targets set by Piedmont’s 2019 CAP. Its “green tech” elements are simply outdated and inadequate. It proposes to accomplish 55% of the pool water heating with a solar tube array (passive solar), leaving 45% of the pool water heating to natural gas. Since the proposed new facility will triple the pool area of the old facility, the 2017 design will still lead to an increase in the facility’s natural gas usage, despite its “green tech” features. The design would significantly (likely irreparably) set back the City’s GHG emissions reduction efforts. (For more details about the problems with the 2017 conceptual design in terms of emissions reductions, see page 3 of the April report Piedmont Connect prepared at the request of the City Administrator.)
The RFP appears to deepen this problem by paving the way for an early ruling out of attempting a zero emissions design. Instead of starting the project by figuring from scratch how to design a zero emissions facility, it calls for working backwards from the (flawed) 2017 conceptual design to see if it can be made zero emissions. If this is how we go about it, the answer will likely be, “no, it’s impossible.”
If the facility is truly going to achieve as few emissions as possible, the specific emissions reduction technologies that could achieve this need to be incorporated into the conceptual design from the beginning, as the space they would occupy will be part of the space of the overall facility and thus influence its layout (these technologies would likely include high efficiency air-to-water electric heat pumps, powered by on-site solar PV, passive solar elements, etc., all of which need dedicated space). If we try to reverse our way out of the 2017 design, we are almost guaranteed failure.
Emissions Calculations
While those of us in Connect who have been analyzing the possibilities for a zero emissions facility have called for doing the emissions calculations early, we were not asking for what the RFP calls for (“an in-depth feasibility and cost/benefit analysis to determine if the facility can reach a Net Zero Energy for construction, operations and maintenance of the facility. This analysis shall be performed in the Preliminary stage of design to make an early determination of the feasibility of this goal.”). The way the thinking of project managers seems to be going, the zero net carbon features are being seen as add-ins, frills that would be nice to have, but not essential to the project. With this mindset, zero carbon technologies will be first on the chopping block when it comes to value engineering. Instead, they need to be non-negotiable, and, if value engineering is needed, some of the actual frills of the project should be what we cut until we can get to them later. A pool energy system is not something that can easily be revised later. We may need to incorporate some of the elements in stages, but we need to plan for them from the beginning.
In addition, the type of GHG emissions analysis Connect has been calling for is not a simple cost-benefit analysis. This analysis will require a separate team of experts in complex energy and emissions calculations (so this team needs to be added to the RFP’s list of consultants who will be needed). These are not calculations that a team coming at the issue from a cost/benefit perspective will have the expertise to do correctly. They will be unfamiliar with the newer technologies that will be needed in a zero carbon design, and, as such, they could easily rule them out without understanding their role.
CEQA
Another big flaw in the RFP is that the section on CEQA submittals (1.3.4.1) does not reference the GHG assessment that is now part of CEQA (as of 2019). Here’s a link to the new language: https://resources.ca.gov/CNRALegacyFiles/ceqa/docs/2018_CEQA_FINAL_TEXT_122818.pdf
In summary, “The revision of CEQA Guidelines section 15064.4 clarified several points, including the following:
- Lead agencies must analyze the greenhouse gas emissions of proposed projects. (See CEQA Guidelines, § 15064.4, subd. (a).)
- The focus of the lead agency’s analysis should be on the project’s effect on climate change, rather than simply focusing on the quantity of emissions and how that quantity of emissions compares to statewide or global emissions. (See CEQA Guidelines, § 15064.4, subd. (b).)
- The impacts analysis of greenhouse gas emissions is global in nature and thus should be considered in a broader context. A project’s incremental contribution may be cumulatively considerable even if it appears relatively small compared to statewide, national or global emissions. (See CEQA Guidelines, § 15064.4, subd. (b).)
- Lead agencies should consider a timeframe for the analysis that is appropriate for the project. (See CEQA Guidelines, § 15064.4, subd. (b).)
- A lead agency’s analysis must reasonably reflect evolving scientific knowledge and state regulatory schemes. (See CEQA Guidelines, § 15064.4, subd. (b).)
- Lead agencies may rely on plans prepared pursuant to section 15183.5 (Plans for the Reduction of Greenhouse Gases) in evaluating a project’s greenhouse gas emissions. (See CEQA Guidelines, § 15064.4, subd. (b)(3).)
- In determining the significance of a project’s impacts, the lead agency may consider a project’s consistency with the State’s long-term climate goals or strategies, provided that substantial evidence supports the agency’s analysis of how those goals or strategies address the project’s incremental contribution to climate change and its conclusion that the project’s incremental contribution is consistent with those plans, goals, or strategies. (See CEQA Guidelines, § 15064.4, subd. (b)(3).)
- The lead agency has discretion to select the model or methodology it considers most appropriate to enable decision makers to intelligently take into account the project’s incremental contribution to climate change. (See CEQA Guidelines, § 15064.4, subd. (c).)
LEED Certification
In the RFP and in the project management team’s presentation at the PAC meeting, when LEED certification was brought up, it was made to sound like LEED would apply to the entire facility. In my understanding, there’s no LEED certification system for pool water heating systems (I’d love to be proved wrong). LEED may perhaps apply to the pool structure, but it’s the pool water heating that will be by far the major source of the facility’s GHG emissions (unless we eliminate natural gas usage). It’s disingenuous (greenwashing) to label the entire facility as LEED certified, if this leaves out the major source of GHG emissions. In addition, for the structural elements of the pool (such as the pool house), why would we limit ourselves to LEED Silver? Bronze, Silver, Gold, and Platinum LEED standards are older standards and mainly focused on energy efficiency and sustainable building materials. We should be aiming, instead, for the newer LEED Zero Carbon standard, which accounts for energy sources and verifies net zero goals. We strongly urge you to aim for LEED Zero Carbon, for the applicable parts of the project. Even if we can’t reach LEED Zero Carbon in the end, we need to set an ambitious goal to start with, rather than admitting defeat from the beginning.
This can be a pool facility for the 21st century, if we put our minds and wills to it. It’s time to pause and re-do the design team RFP as well as the project work plan and timeline.
Margaret Ovenden, Piedmont Resident
