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
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
fact emissions from Industry account for over 1/3 of global
anthropogenic emissions, and have been increasing faster than other
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: 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
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
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.