California Air Resources Board

Hello, It is very important to consider and involve the concrete subcontractors because they are the purchasers of concrete. More so than developers, owners, engineers, it is the concrete subcontractors that have the most effect over the low carbon concrete revolution because they are the ones buying it. Therefore, it’s very important that we pass codes and policy that is easily understandable. A good precedent is the Marin County and Santa Monica low carbon concrete codes that address concrete in traditional language instead of more novel language like EPDs and GWPs. Both of those city codes have had success because they have a pathway to low carbon concrete that simply addresses limiting Portland cement and replaced the remainder with a pozzolanic material. This is much more accepted among the purchasers of concrete, the subcontractors, than addressing them in novel terms like EPD and GWP. As you consider your policy, please ensure that it is a policy that is easily understandable and motivates the real purchasers of concrete, the subcontractors.