Taking Shape: The Evolution of AB 841 to CalSHAPE
Many business and facilities experts in California K–12 districts have been following the ongoing development of the Schools Energy Efficiency Stimulus Program (also referred to as the SEES Program, SEESP, Assembly Bill 841, or AB 841).
Many business and facilities experts in California K–12 districts have been following the ongoing development of the Schools Energy Efficiency Stimulus Program (also referred to as the SEES Program, SEESP, Assembly Bill 841, or AB 841). The program was designed to provide grant funding for heating, ventilation, and air-conditioning (HVAC) equipment assessments, repairs, and upgrades as well as replacements for non-code compliant plumbing fixtures in K–12 schools.
Although it has been a relatively short, iterative process, there have been significant changes that have been integrated into the program primarily focused on the HVAC portion of the program based on public feedback. So, what do all of the changes mean for the HVAC side of the program?
For a comprehensive explanation of the SEES Program, please see the initial blog post here. The SEES Program was initially approved via Assembly Bill 841 in September 2020 with the initial draft guidelines released in January 2021 for public review. The HVAC program was initially developed to provide funding for highly-detailed conditions and performance assessments of existing HVAC equipment that would require significant engineering and technical data evaluation.
Based on these assessments, additional funding would be made available for necessary repairs and upgrades as applicable — short of a full HVAC unit replacement. The potential for a full HVAC unit replacement was discussed as a possibility in later program years, pending available program budget. In year one and according to specific socioeconomic metrics, the main criteria for program funding eligibility was determined to be for schools classified as disadvantaged.
As the HVAC assessments require highly-specific and technical activities outside of the qualifications of the average district facilities technicians, program guidelines dictated that all assessment activities must be contracted and conducted by licensed professionals. Subsequently, this set a process for requiring contractors to provide cost estimates to conduct this assessment work, contributing the basis of the grant application and funding request.
The California Energy Commission (CEC), the government agency tasked with administering the program, held multiple workshops to solicit input and feedback from K–12 personnel and HVAC and energy experts.
During the CEC’s virtual workshops, CEC staff provided a forum for the public to discuss the existing program guidelines, ask questions regarding how and why the program was developed, and provide input on how the program could be improved. CEC staff also shared the feedback they received both informally and formally. Some of this feedback included the information that many contractors’ cost estimates had been shared with the CEC and that these cost estimates had been significantly higher than expected by CEC staff. This caused concern that with a limited program budget, fewer districts may be served by the program than initially expected.
Along the same lines, school district officials indicated concern that the “first-come, first-served” competitive process of applying for grant funds would be beneficial to larger districts who have the staff and resources to quickly develop a strategy and apply for funding. District representatives suggested instituting a grant maximum award amount in order to ensure that more school districts could access grant funding through the program.
Numerous school district representatives and HVAC industry experts expressed concern that it might not be a good use of already-limited grant funds to conduct a laborious HVAC assessment on aging HVAC expected to be replaced within a few years. To mitigate this challenge, industry experts recommended a potential hybrid process, suggesting that the full HVAC assessment could be conducted on equipment expected to remain in use for several years into the future and a pared-down approach could be used to provide basic maintenance to equipment expected to be replaced in the near term.
Substantial Changes due to Public Feedback
New Program Name – The CEC made significant changes to the program guidelines based on public feedback, including the program’s name, renaming it the California Schools Healthy Air, Plumbing, and Efficiency Program (CalSHAPE). The two subprograms are now referred to as the Ventilation and Plumbing programs, respectively. In terms of the program’s process, substantive changes were made to the guidelines.
Multiple Assessment Pathways – Rather than one prescriptive process requiring a full assessment of all HVAC equipment, regardless of age or condition, there are now three possible pathways for equipment to be treated:
- Full HVAC Assessment – Equipment that will remain in operation for the foreseeable future will be eligible for a full assessment as previously prescribed.
- Limited/No Mechanical Equipment – For schools with no mechanical cooling equipment, an alternate technical assessment designed to measure ventilation and airflow equipment performance should be used.
- Scheduled for Replacement – The most relevant new pathway for most districts with HVAC equipment that is slated for replacement in the next two years that foregoes the performance analysis activities from the HVAC assessment.
Equipment that is expected to be replaced within the next two years will be eligible for the Scheduled for Replacement pathway, which will provide funding for filter upgrades to MERV 13 rated filters and CO2 monitor installation — without any further assessment tasks required. While offering a sensible, pared-down approach, the potential downside to this pathway is that Scheduled for Replacement equipment will not receive the 20 percent contingency funds to be used to identify the repairs through a full assessment pathway. Additionally, this equipment will be ineligible for upgrade or replacement funding in future program years (if funding for these activities becomes available).
Maximum Grant Award Amounts – In order to serve more districts, the program guidelines now include maximum grant award amounts which cap the cost for the assessment on a per school basis at:
- $40,000 for assessment and report creation for the full HVAC assessment pathway
- $4,000 for the No Mechanical Ventilation pathway
- $2,000 for the Scheduled for Replacement pathway
- $75 per unit for materials and labor for filter replacement
- $500 per classroom for materials and labor for CO2 monitor installation
Effect of Changes
Overall, the changes to the program guidelines establish a much more common-sense approach that will minimize the use of valuable grant dollars on assessing performance from equipment expected to be replaced shortly. The changes also theoretically encourage more equitable funding distribution across the state by allowing more districts to apply and obtain grant funding. The potential drawback to these changes is that by taking the Scheduled for Replacement pathway, districts may be foregoing replacement funding in the future. Regardless, the guideline changes provide necessary parameters that make better use of limited grant funding and give districts clearer direction with capital improvement planning.
The CEC will consider a motion to adopt the revised program guidelines during June 2021, which is the next step in getting the program up and running for application submission. A timeline for accepting applications is expected in the near future once determinations have been made after the meeting.
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