Submitted Comment Name Josh Proudfoot Affiliation Parametrix - Director of Climate and ESG Subject A few thoughts on AB2446 an AB43 Message Howdy. Two thoughts - Top down baseline for embodied emissions versus bottom up and What to do about existing buildings? 1. A top down baseline will get you in the ballpark, but given that it is a baseline and you will want to show progress against it, not having real data will make the improvements forever questionable. This same challenge is coming up everywhere we work where the data is not there yet, which is basically everywhere and in every government and corp supply chain - until the data is collected. I would advocate for bottom up, but I don't think that will work given the desire to get the whole building understood. I think breaking it up by material - doing good LCA work on those materials that account for the largest mass of construction materials in the state is a much easier place to start and already has momentum with buy clean etc. I think that if the data and GHG focus is on producers and distributors of those materials, then architects and engineers can build up their compliance submittals with a spreadsheet of quantities of each material and then show a net reduction over the baselines for those materials and those quantities. Second point - somehow the math needs to work to support repurposing existing buildings over new materials and new buildings. Given the huge vacancy of commercial property there should be an incentive or fast path to compliance built around reuse. Please call me or write to me if you'd like to talk more. We are trying to find the elegant solutions for our clients in the voluntary world and there are lessons to share to the regulatory world. -Josh File Upload (i.e., Attachments): N/A
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