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Comment 565 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First Namescott
Last Nameshell
SubjectInclude Embodied Carbon Emissions

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 Consideration”.  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 sector. 

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:  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:; 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 specifiers:  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

Original File NameIndustrial Emissions.png
Date and Time Comment Was Submitted 2022-06-24 15:58:35

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.

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