Submitted Comment Name Greg Stevenson Affiliation Environmental Manager Subject Embodied Carbon - Comments Message Hello There. The Goal of reducing Building Material GHG emissions by 40% within 10 years is laudable, but fraught with major problems. I work for a company that manufactures concrete blocks, pavers and clay bricks at a number of locations in the western US and Canada. Other associated companies produce gypsum wallboard, asphalt roofing shingles and paper. We distribute a wide range of building materials including insulation, sealants and timber products. I'm aware of actions by the concrete industry to reduce emissions and as a company, we strive to adopt all feasible GHG reduction technologies. Type 1L cement has been widely adopted, along with renewable fuels and power audits. These have produced meaningful savings that are reflected in our EPDs. Unfortunately, they won't be counted towards our starting benchmark so we will have to search for significant savings in other areas. I'm at a loss of how we can achieve a 40% reduction without buying credits (which are a waste of time and money because we still emit the GHGs). Solar is not an option because cement dust, even in tiny amounts kill solar cells, and carbon sequestration (still experimental) is just plain dangerous in earthquake prone California. There are a number of companies working to develop alternatives to Portland Cement, and we have tried several, but nothing has emerged that is even close to being a low GHG contender. I was reminded of another worrying factor the other day when I prepared an emissions estimate for a customer. 92% of our emissions are Scope 3 and only 6% are Scope 1. As a manufacturer we are at the mercy of our suppliers and will rely almost totally on them for the 40% reduction. I can tell you now we won't be getting the 40% reduction from our Scope 1 and 2 emissions. This leads me to ask how CARB will manage this. Typically, CARB is adept at wielding a big stick but is very light on carrots. I haven't seen even a mention (forgive me if I'm wrong) of any outreach efforts to assist manufacturers in meeting the goals. Is CARB spending any money on developing Portland Cement alternatives? As you know, PC manufacturing makes up 8% of global GHG emissions. Barring some fabulous technological advancements that are ready for widespread adoption in the next few years, I see emissions reductions as a hard slog that will be an expensive process, and we will still fail to meet the 40% target in 2035. Oh, and the reporting burden appears to be expensive and onerous, and will impact California based manufacturers, importers and distributors, giving out of state entities a free kick (see slide 17). I hope this helps. Regards Greg Stevenson File Upload (i.e., Attachments): N/A N/A
Submission information