Submitted Comment Name Grace Olupinyo Affiliation Mazzetti Subject Public Comment on CARB Building Embodied Carbon Reporting Message To the AB 2446 Implementation Team at CARB, We appreciate CARB’s leadership in developing a framework for measuring and reducing embodied carbon in building materials under Assembly Bill 2446 (AB 2446). As an MEP (Mechanical, Electrical, and Plumbing) engineering firm, we strongly advocate for the explicit inclusion of MEP systems in the embodied carbon reporting requirements within the forthcoming baseline reporting framework. MEP systems—including distribution infrastructure (e.g., ductwork, electrical panels and wiring, plumbing piping, and pumps) and distributed equipment (e.g., air handling units, humidifiers, transformers, switchgear, and mechanical ventilation systems)—represent a significant portion of embodied carbon in buildings. Many of these systems fall within MEP 2040 commitments and are critical to holistic carbon reduction strategies. While we recognize that certain consumer appliances and standalone products have been excluded from the reporting framework—such as refrigerators, portable air conditioners, and residential plumbing fittings- these systems are permanent fixtures of the built environment and directly impact a project’s embodied carbon footprint throughout its life cycle. Given the increasing focus on low-carbon mechanical, electrical, and plumbing solutions, including MEP systems in AB 2446’s reporting framework will help drive more informed material choices, supply chain transparency, and embodied carbon reductions in California’s built environment. We appreciate CARB’s guidance on this issue and look forward to further engagement in the rulemaking process. File Upload (i.e., Attachments): N/A
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