Submission Number: 7911
Submission ID: 54831
Submission UUID: 78f1236c-2e0a-43e1-afc8-cc0fbf392d30

Created: Wed, 11/19/2025 - 12:50
Completed: Wed, 11/19/2025 - 12:50
Changed: Fri, 11/21/2025 - 16:59

Remote IP address: 128.138.65.107
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes


Submitted Comment
Martín Torres
University of Colorado Boulder
Transparent EPDs and whole-building material quantities

Since EPDs often depend on background data, they should be as transparent as possible. EPDs should clearly communicate all underlying calculations, the assumptions made, and the sources of the data. Of course, primary data is preferred, but that should also be reported. When generic/background data is used, a probabilistic LCA approach that quantifies uncertainty should be taken.

If the state requires whole-building LCA (which is a great idea), it could be extremely beneficial if the state helped gather the underlying material quantities for these LCAs. This would involve collecting material quantities broken down by assembly (foundation, columns, floors, etc.) based on modeled drawings (ideally 100% CD), with as-built quantities verified by the contractor. By collecting such data, the State of California could perform interesting meta-analyses, similar to what SE 2050 aims to do, but with higher-quality data.

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