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Comment 216 for Draft 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameStacy
Last NameSmedley
Email AddressSTACY.SMEDLEY@BUILDINGTRANSPARENCY.ORG
AffiliationBuilding Transparency
SubjectRe: Appendix F - Building Decarbonization
Comment

Currently, the Appendix F document lists embodied carbon of buildings as an area for future consideration. We recommend that this become an area of current prioritization alongside operational decarbonization. Embodied carbon emissions of building materials are currently at least 11% of global carbon emissions. The majority of these embodied carbon emissions of high impact building materials such as cement/concrete, steel, aluminum and glass are produced during the material manufacturing (A1-A3) product stage. Which means that once the material has been made, the emissions are in the atmosphere and can't be taken back or reduced over time. This also means that swift action needs to be taken today to mitigate the emissions of building and infrastructure projects currently in procurement and construction, if zero carbon targets necessary to mitigate climate impacts and limit global warming are to be met. 

Since 2020, there has been a swift increase in both the understanding of embodied carbon emissions in the building and construction sector, as well as the verified data and tools necessary to support accounting for and reducing it, via whole building life cycle assessments during design and low carbon procurement requirements during material specification and procurement. California has been a leader in the latter, with its implemented Buy Clean California policy, and now there are similar procurement policies with aligned requirements in jurisdictions across the United States (city, county, state and federal), as well as work being done at the international level via the United Nations Industrial Deep Decarbonization Initiative (IDDI). 

It would be a detriment to this plan if embodied carbon was not included in today's requirements, and recommend that items such as broadening the materials included in the Buy Clean California Act, as well as requiring whole building life cycle assessments for project over a certain scale/scope are key focus areas for study and implementation. 

The Carbon Leadership Forum's Policy Toolkit is a great resource that outlines embodied carbon policy requirements as well as provides a map of currenly implemented or proposed policies globally: https://carbonleadershipforum.org/clf-carbon-policy-toolkit/#:~:text=The%20Carbon%20Leadership%20Forum%20has,to%20radically%20reduce%20embodied%20carbon.

Building Transparency's free, open access Embodied Carbon in Construction Calculator (EC3) and complimentary WBLCA Revit Plugin, Tally, are examples of the broadly adopted tools in place to provide the data and assessment mechanism for such policies, with continued growth in adoption and use across the private and public sector: https://www.buildingtransparency.org/


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Date and Time Comment Was Submitted 2022-06-24 10:17:02

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