Submitted Comment Name Kim Hammer Affiliation Sustainable Minds Subject Comments relating to the October 30, 2025 Embodied Carbon Reporting Technical Meeting Message My comments relating to the October 30, 2025 Embodied Carbon Reporting Technical Meeting: 1. I’d like to voice general support for the overall effort, and for the use of LCA via EPDs 2. CARB-approved emissions factors: a. Clarify that emission factors are only applicable to primary data; if this is not true, describe how LCA practitioners would have access to the CARB emissions factors for use in LCA modeling software or how EF would otherwise be accessible for use with secondary data b. Encourage use of supplier-specific data vs. secondary data only c. Discourage the use of EEIO-based approaches for reporting where better approaches are available; establish a hierarchy of approaches 3. Age of primary data requirement: Not all products or materials have meaningful changes to BOMs or production processes after two years, so consider an evaluation instead of requiring an update to mitigate effort and cost burdens. This is especially important given that federal funding expected at the start of program development is no longer available to building material industries. 4. Verification procedures: There should also be consideration of program effects on this process given the data age requirements. Collecting the data, updating results, and going through a new review and third-party verification process every year and a half or so to stay below the 2-year requirement would likely be a heavy burden. Thank you, Kim File Upload (i.e., Attachments): N/A N/A
Submission information