Comment Log Display

Comment Log Display

Below is the comment you selected to display.
Comment 16 for Green Building Comments for the GHG Scoping Plan (sp-greenbuild-ws) - 1st Workshop.


First Name: Bruce
Last Name: Ray
Email Address: bruce.ray@jm.com
Affiliation: Johns Manville

Subject: Energy Efficiency and Indoor Air Quality
Comment:
Johns Manville strongly agrees with the proposal in the draft
Scoping Plan to use Green Building principles and standards to
help achieve the greenhouse gas (GHG) emissions reduction goals in
AB-32.  Many studies have confirmed that constructing new and
retrofitting older buildings to achieve levels of energy
efficiency to beyond what is required by current code is a cost
effective way to achieve significant GHG emissions reductions in
the short term.  In fact, the attached article from the March 2007
The McKinsey Quarterly demonstrates that greater levels of
insulation installed in existing and new homes and buildings are
among the most cost effective ways to fight climate change.  (See
graph on article page 38, pdf page 4.)  Insulation can actually
have a net negative cost, i.e., extra insulation may not cost
money but instead can save it.

But CARB should be careful to avoid poor indoor air quality as an
unintended consequence of increased energy efficiency.  The vast
majority of older homes do not have continuous mechanical
ventilation and instead may depend largely on outside air
infiltration as a principal source of fresh air.  But retrofitting
older homes to achieve a higher level of energy efficiency is all
about making them tighter and reducing air infiltration.  The same
holds true for new homes.  The Offerman ventilation study being
performed for CARB will note that even new homes with ventilation
systems can have an unacceptably low rate of actual air changes
per hour.  The result can be that indoor air pollutants from
building materials, including formaldehyde, may tend to build up
to unacceptable levels in an energy efficient home.

This means that great care must be taken to select non-emitting
building materials, including insulation, for use in new
residential construction and in residential retrofit applications.
 There is an increasing number of no-added formaldehyde alternative
products commercially available today.  This includes Johns
Manville’s full line of Formaldehyde-freeTM fiber glass building
insulation.

As part of the AB-32 energy efficiency measures, we urge CARB to
maintain its previous guidelines on formaldehyde:  

-	CARB Indoor Air Quality Guideline:  “Formaldehyde in the Home”
(Aug. 2004) 
http://www.arb.ca.gov/research/indoor/formaldGL08-04.pdf 
[recommends formaldehyde-free building materials generally]
-	CARB Fact Sheet:  “Reducing Your Exposure to Formaldehyde” (Aug.
2004) http://www.arb.ca.gov/research/indoor/formaldfs08-04.pdf
[recommends formaldehyde-free insulation]

Johns Manville, a Berkshire Hathaway company (NYSE: BRK.A, BRK.B),
is a leading manufacturer and marketer of premium-quality building
and specialty products.  In business since 1858, the Denver-based
company in 2002 converted its entire line of fiber glass building
insulation to a no-added formaldehyde formulation.  Johns
Manville’s fiber glass building insulation plants are the only
ones in the industry exempted by US EPA from Clean Air Act
hazardous air pollutant regulations.  Additional information can
be found at www.jmhomeowner.com.

Thank you.

Attachment: www.arb.ca.gov/lists/sp-greenbuild-ws/16-mckinsey_study_-_cost_curve_for_ghg_emission_reductions_-_march_2007.pdf

Original File Name: McKinsey study - cost curve for GHG emission reductions - March 2007.pdf

Date and Time Comment Was Submitted: 2008-08-01 17:28:21



If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.


Board Comments Home

preload