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Comment 621 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameAvideh
Last NameHaghighi
AffiliationZGF Architects
SubjectComments to Scoping Plan

To California Air Resources Board:

We write on behalf of ZGF architects, a leading architectural design firm with over 800 employees and countless projects in California, including the State’s largest Zero Carbon buildings. 

The Draft Scoping plan does not address the urgency of climate change.  We are ready and able to have all-electric residential and commercial buildings NOW.  We already have the technologies, appliances, equipment and infrastructure to make the transition to all-electric buildings.  The 2022 California Energy Code already requires electric-ready construction, meaning all new construction starting January of 2023 will have the necessary infrastructure to be all-electric.  Waiting until 2026 and 2029 for all-electric appliances in residential and commercial construction is a waste of time and an unnecessary delay in decarbonization.  Furthermore, waiting even longer to require electric appliances in existing buildings is a huge missed opportunity.  The existing building stock is a large part of the building sector, and avoiding upgrades to existing buildings is short-sighted and not in the best interest of the State.  We need immediate funding to transition existing buildings to all-electric as fast as we can. 

Furthermore, the Draft Scoping plan does not include strategies to reduce embodied carbon in buildings and infrastructure.  In fact emissions from Industry account for over 1/3 of global anthropogenic emissions, and have been increasing faster than other sectors. 

There are clear pathways to significantly reduce emissions quickly at very low or no cost.  The largest contributors to emissions are 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 few years on strategies to reduce embodied carbon.  Organizations such as the Carbon Leadership Forum and 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. 

The strategies to reduce embodied carbon well understood by 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.  We know from experience that all-electric low-embodied carbon buildings are possible without added cost.  It is imperative that the Air Resources Board considers adding provisions for embodied carbon into the scoping plan.


Avideh Haghighi

Associate Principal

ZGF Architects

Original File Name
Date and Time Comment Was Submitted 2022-06-24 18:36:16

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

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