Comments for the Draft
2022 Climate Change Scoping Plan
The Draft Scoping plan
does not include strategies to reduce embodied carbon in buildings
and infrastructure and says it is an “Area for Future
In fact emissions from Industry account for over 1/3 of
global anthropogenic emissions, and have been increasing faster
than other sectors.
The emissions within the state of California are slightly
smaller, but if emissions due to imported goods are included then
they are almost as high.
It is untenable to delay until some future date such a large
Moreover, there are clear pathways to
significantly reduce emissions quickly at very low or no
cost. The emissions are dominated by cement and steel,
materials that have clear and multiple pathways to lower ghg
emissions. There has been major progress in the design and
construction industry in the last 5 years on strategies to reduce
embodied carbon through research and advocacy of organizations such
as the Carbon Leadership Forum. Organizations such as
Building Transparency have collected close to 100,000 Environmental
Product Declarations in their free publicly accessible database EC3
providing reliable data on which to base policies.
Embodied carbon is
already being addressed in a number of jurisdictions across the
U.S., as shown here:
https://carbonleadershipforum.org/clf-carbon-policy-toolkit/#map. The Buy Clean California
Acts was one of the first policies to pass, and there are now
standards in place for the covered materials, and an infrastructure
in place to report the data.
Multiple states have followed suit and recently passed
policies. The U.S.
General Services Administration has passed carbon thresholds for
concrete and asphalt which are now in effect nationwide: https://www.gsa.gov/cdnstatic/Horn_GBAC_Embodied%20Carbon.pdf;
and they are piloting whole building lifecycle analysis
(WBLCA). The City of
Vancouver has a WBLCA ordinance currently in effect after piloting
the process for the last 5 years.
Industrial emissions are dominated by two
heavily used materials, steel and cement, both of which have many
opportunities to reduce emissions. For cement California is a
hotbed of innovation with many companies developing promising
technologies. One well documented solution is Limestone Clay
Calcined Cement (LC3) which can replace half the cement in concrete
and reduce the emissions by up to 40% while also improving
performance. One cement manufacturer that has plants on the
West Coast is currently producing LC3 in another state.
Another company--located in Ione, California--has some of the
highest quality clay deposits for LC3 and is preparing to supply
the market at scale. Other companies such as BluePlanet
Aggregates have a pilot plant in Pittsburg, CA, and CarbonBuilt was
incubated at UCLA and won a CarbonX prize for their low carbon
technology. Even without using breakthrough technologies,
there are major opportunities in concrete mix specification to
reduce emissions by 30% or more just by good practice. The
Marin County Low Carbon Concrete Code demonstrated this by
collecting many local mix designs and setting an achievable
threshold within that wide range. Central Concrete in the Bay
Area is supplying low carbon concrete and has a guide for
Since cement is the most expensive component of concrete, these
strategies save money. Moreover, cement kilns in are the
primary facilities still burning coal in the state of California;
the state has weaned itself off coal for power plants and it is
time to reduce demand for coal fired cement, and reduce the impacts
on frontline communities.
In the Pacific Northwest which has been
leading on embodied carbon, they found that just by asking
producers to provide an Environmental Product Declaration, the
embodied carbon in concrete dropped by 20%. Since embodied carbon has
so far not been regulated, there is lots of low hanging fruit. With the new push toward
electrifying new construction in the 2022 T24 energy code and 55
municipal codes, and the increasingly clean California electric
grid, embodied carbon emissions will now often exceed the
operational emissions over a 50 year life cycle analysis. And all of these emissions
occur before the building is even occupied.
The strategies to reduce embodied carbon well
understood by the leading design and engineering firms in the
state. The standards
exist, the software tools are now mainstream, and many projects
have demonstrated the ability to reduce emissions by 30-50% with
low to minimal costs.
As a architect with over 30 years experience
designing low carbon buildings across California, I know this is a
reasonable and affordable strategy to significantly reduce
emissions in the near term.
To delay until some future mistake is to miss one of the
easiest and lowest cost opportunities available.
Scott Shell, FAIA