Submitted Comment Name Jack Armstrong Affiliation Structural Insulated Panel Assn. (SIPA) Subject CARB Carbon reporting requirements Message While the goals of this reporting program are admirable, the current state of the carbon reporting system of ingredients is difficult since many supply chain material inputs do not have current data at the industry or individual company level. The creation of PCR (product category rules) takes about two years. These are needed to create the EPDs (environmental product declarations) which also take about two years each and over $30K/each. There are limited consultants and professionals to perform these tasks for the industry. I think a very high level of estimation will be necessary to meet the 2026 reporting requirements. File Upload (i.e., Attachments): N/A
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