Submitted Comment Name Arpad Horvath Affiliation UC Berkeley Subject Comments on CARB-modified USEEIO model and presentation Message 1. A bottom-up approach was unfairly dismissed at the meeting. It is not readily available, but it should be developed because it would be superior to the current CARB-modified USEEIO top-down model. It would be a misdirected effort if CARB's ultimate goal would be to employ this top-down model. 2. The limitations of the CARB-modified USEEIO model were underreported. The model suffers from problems with definitions, data, aggregation, and how it was applied. All models have shortcomings, and certainly all I-O-based models do too. But the limitations were either scattered throughout the presentation of the model or left out. They should be unambiguously revealed and factored into messaging so that the public could appreciate what the model does and does not represent. 3. The USEEIO model is particularly problematic to be applied to the construction sectors and the end-of-life sectors of the economy. This needs to be revealed to the public. 4. The CARB-modified USEEIO model provides a rough, unverified estimate. The limitations of the model lead to high uncertainties, which have not been investigated: The "baseline" can be very close to the actual emissions or very far from it. Every number between the extremes is likely. Uncertainty assessment needs to be performed. An extra-careful interpretation of the model's outputs should be presented. It is little wonder that almost every comment in the room reflected confusion with one aspect or another of the model. 5. This work has been about establishing a "baseline." Only slide 4 lists "reporting priorities and reduction strategies" (as the last item). There was an attempt at the meeting to pivot from the use of the "baseline" for benchmarking towards new reporting priorities by industry and screening for potential environmental contributions to the construction sector in the A1-B4 stages. Why is a baseline needed? If one calls it a "baseline," it is commonly understood that things will be compared against it. This "baseline" cannot be used for action, only to mandate reporting. If that is the goal, it would be the best if this objective was clearly highlighted in future efforts. File Upload (i.e., Attachments): N/A N/A
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