Submitted Comment Name Michael Hammond Affiliation Vitro Architectural Glass Subject Vitro comments on Embodied Carbon in Buildings Message As a leading flat glass manufacturer and sustainability leader in North America, Vitro Architectural Glass proposes that the embodied carbon requirements for buildings should mandate Product Specific Environmental Product Declarations (EPDs). For glass products, we recommend that only the flat glass EPD be required, as it accounts for over 75% of the embodied carbon of the finished product since the current EPD process has a margin of error of +/-20%, which is greater than the embodied carbon of the remaining components other than the flat glass. This approach aligns with the solution implemented by the General Services Administration (GSA). File Upload (i.e., Attachments): N/A
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