Submission Number: 8055
Submission ID: 55676
Submission UUID: 7c116dca-0e18-4e96-882f-9ae1ea4aad31

Created: Mon, 12/08/2025 - 17:26
Completed: Mon, 12/08/2025 - 17:30
Changed: Tue, 12/09/2025 - 08:21

Remote IP address: 104.51.148.164
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes
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Submitted Comment
Krystinne Mica
Structural Engineers Association of California
October 30, 2025 Workshop Covered Projects Reporting Technical Meeting Public Comment Period

Pamela Gupta, Branch Chief
Building Decarbonization and Innovative Strategies Branch,
California Air Resources Board

Dear Ms. Gupta,

We, members of the Structural Engineers Association of California (SEAOC) Sustainable Design
Committee (SDC), submit the following comments in response to the California Air Resources
Board’s (CARB) request for public comment following the October 30, 2025 public workshop.
This workshop provided an overview of the CARB staff’s proposed reporting requirements and
project reporting tool associated with buildings in California. We greatly appreciate the
opportunity to comment on this proposal.

The members of the SEAOC SDC wish to communicate the perspective of designers who are
heavily involved with the tracking and reduction of embodied carbon of buildings. Structural
engineers play a central role in shaping the material and system choices that influence
embodied carbon outcomes in California’s built environment. Our comments are intended to
be consistent with our organization's commitment to “support public policy and industry
efforts to reduce embodied carbon in the built environment.” Our hope is that the framework
implemented by CARB can align with ongoing efforts as much as possible and support and
incentivize progress towards actionable reduction strategies that ultimately achieve the 40%
reduction goal by 2035.

SEAOC strongly supports the development of clear, consistent, and technically robust
embodied carbon policy through a statewide approach—aligned with state building code
regulations. We look forward to continuing to work with CARB as we collectively work to realize
the ambitious goals set forth by the state of California.

Sincerely,
Members of SEAOC SDC
Rachelle Habchi, P.E., SEAOC SDC Chair
John O’Hagan, P.E., SEAOC SDC Past-Chair
Luke Lombardi, P.E., SEAOC SDC Past-Chair
Lisa Podesto, SEAOCC SDC Chair
Ann Jiras, P.E., SEAOSC SDC Chair
Marisa Nolasco, P.E., SEAONC SDC Vice Chair
Nicholas Miley, S.E., SEAONC SDC Past-Chair
Jacob Gottlieb, P.E., SEAOSD SDC Chair

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