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Comment 218 for Draft 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameBronwyn
Last NameBarry
Email Addressbronwyn@naphnetwork.org
AffiliationThe Passive House Network
SubjectEmbodied Carbon
Comment
The Passive House Network (PHN) and its membership would like to urge the CEC to include the assessment of embodied carbon as soon as possible. PHN launched the PHribbon this year in partnership with Building Transparency. It allows both operational and embodied carbon to be calculated in one energy model (www.naphnetwork.org/PHribbon). We’ve demonstrated it's possible today and can be done by a small entity without too much trouble. 
 
PHN, along with our local partners, are here to help and can assist the CEC in integrating this important next step on the journey to rapidly decarbonize California's buildings. 
 
We strongly encourage the following:
 
  1. immediate roadblock removal by allowing the use of PHPP & PHribbon as an alternate compliance pathway
  2. Establishment of a benchmarking program to track and assess embodied carbon in parallel with operational carbon emissions. 
  3. An incentive or pilot project program to reward front-runner projects. 
 
There’s no time to lose. We’re here to help. 

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Date and Time Comment Was Submitted 2022-06-24 10:35:43

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