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Comment 590 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameSimone
Last NameBarth
AffiliationAIA California
SubjectScoping Plan: Include the Reduction of Embodied Carbon NOW

We have the tools to track embodied carbon in buildings. The proposed scoping plan moves embodied carbon into Category 5 “Areas for future consideration”. We  need to address how we manage the reduction of embodied carbon in buildings now!

  • By 2050 the world's population is predicted to be at 10 billion, 55% of this population will live in cities. The global building stock is expected to double in size. 

  • 39 % of global CO2 Emissions are created from real estate and the construction sector. 28%  from building operations, and 11% are from  the construction of buildings.

  • We are just transitioning out of a two year pandemic. We all witnessed the increased physical consequences of a changing climate. The wild fires in California in 2020 destroyed over 10,000 structures and cost over $12 billion in damages.

The majority of a building’s total embodied carbon is released upfront in the product stage at the beginning of a building’s life. Unlike with operational carbon, there is no chance to decrease embodied carbon with updates in efficiency after the building is constructed. There is an urgent need to address embodied carbon now to meet short-term and long-term climate targets.

Embodied carbon will be responsible for almost half of total new construction emissions between now and 2050, according to Architecture 2030. We need to get a grip on the embodied carbon now if we want to meet the climate targets by the year 2050.

The rest of the United States and the world look to California’s leadership. It is critical that CARB supports this leadership and addresses the reduction of embodied carbon in buildings NOW.


Simone Barth on behalf of the AIA California

Original File Name
Date and Time Comment Was Submitted 2022-06-24 16:40:51

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