California Air Resources Board

These are in response to the Embodied Carbon Workshop held on Sept. 19.
It was mentioned that manufacturers, developers and Builders would be required to report. There seems to be a high degree of potential for double reporting.
• California is not where the majority of construction materials manufacturing is taking place. For those who are here, I would assume that their carbon emissions are or could be regulated through other state regulatory controls and not adding another reporting venue would be prudent to at least not add to the burden of doing business that drives many manufactures from doing business with in the state. If this is going to be required of manufactures who are located outside the state and want to sell within, that seem like a cumbersome thing to enforce. Why are we not relying on EPD's as the reporting mechanism?
• Developers that are voluntarily targeting carbon reductions are currently only measuring a small subset of high impact materials; typically steel, aluminum, glass and concrete. So their full carbon footprint isn't actually captured in their current tracking at this point. For example when they substitute a material not on this list for one that is, it appears as a carbon zero decision. For now it means they are choosing better materials and that is sufficient and the goal is track more in the future. Because developers are in the position to make material decisions, they should be the ones reporting ALL of the materials decisions.
• Reporting from builders could be duplicative as well. Builders include General Contractors as well as Subcontractors. IF what GC's are reporting is scope 2 emissions that are not typically reported in embodied materials impacts of projects and Developers are only reporting materials emissions from the building, that would help reduce duplication.

But all GC's need to report not just GC of a certain size. And all developers not just those of certain size so as not to get skewed results. It is more likely that higher tier GCs and larger scale developers are already voluntarily making better choices.

The start of the framework seems to be focused on improving materials which is great but there also needs to be a focus (especially in the near future) on CHOOSING better materials. Traditional codes and standards are already very biased against bio based materials because of durability and fire. However, if these were preferred materials for other reasons there may be just as many advancements to bring the durability and fire performance of these materials up as there will be to improve environmental performance of concrete, steel and aluminum.

There is a lot of focus on full life cycle performance, however, we know that A1-A5 impacts of a building are the only emissions we can be sure of. We should not require end of life emissions in the reporting. Part of the effort should include continuous funding to create better end of life options that will mitigate end of life impacts. When this is the case, bio based materials should be required to assume biogenic carbon so that the emissions are carried at the end of life where they truly happen.