Comment Log Display

To: 	Dana Papke Waters
	California Air Resources Board
	December 13th 2021 Workshop on Building Decarbonization
From:	American Institute of Architects California (AIA CA)

The 11,000 architect and design professional members of AIACA
design California's new and existing buildings.  We agree with the
framework CARB outlined for decarbonization progress which includes

	Energy Conservation, Electrification, Renewables and Equity and
Inclusion
Importance of Embodied Carbon
To move forward, it is important to include in our code framework
embodied carbon considerations as they are critical to achieve
decarbonization objectives within a time frame consistent with the
urgency for climate action that has been well documented. 
(https://www.weforum.org/agenda/2021/08/ipcc-report-on-climate-change/).
 
Studies show that even the most highly efficient new buildings can
take from 10 to 80 years to recoup in operational savings the
embodied carbon emissions associated with their construction
(https://living-future.org/wp-content/uploads/2016/11/The_Greenest_Building.pdf)
AIA CA in our own discussions about how to get Carbon integrated
into the code have tentatively identified a few key considerations
summarized as follows:
1.	Start with straightforward big buildings.  The topic is both
vast and complex, and the timeline, budgets and professional
bandwidth to consider embodied carbon is more likely to be found
when new buildings above some area threshold are being designed. 
The numerical threshold could be 50,000 sq. ft as one example, open
to discussion.  Large new buildings of fairly simple occupancy
types would likely be the easiest place to get started, and they
would have potential of significant impact.
2.	Focus on a small number of key materials.  This could range from
just concrete; or include a few more high carbon intensity and high
use materials for which there is a large infrastructure in place in
terms of production, analysis, and sales volume.
3.	Use simple non-proprietary performance-based metrics.  An
example of this might be the 20% carbon reduction basis of existing
low carbon concrete.  The tools to show compliance should be openly
available, and accommodate flexibility so that best practices can
evolve and the marketplace can function efficiently to match supply
with increasing demand.  

We support and encourage launching the topic of embodied carbon for
inclusion in CalGreen in the upcoming midcycle code update process,
and plan to continue working with key stakeholder agencies
including for example CBSC, CEC, DSA, HCD and CARB on this topic in
the upcoming months.  While the challenge of taking this complex
and multidimensional topic and putting it into useable and
actionable code framework is daunting, we believe CalGreen is a
logical place for these kinds of measures, and note that there are
precedents that can help guide progress forward in the near term. 
Action in the next code cycle is imperative. 
CalGreen Leadership
We also recognize that there is a need to have broader
conversations about the potential for reimaging leadership for
CalGreen itself.  Since it's foundation in 2008 as a groundbreaking
and forward-looking new approach to integrating environmental
considerations into our building code framework, CalGreen has not
been able to keep up with the fast pace of change and urgent
timeline for decarbonization and climate action that face us today.
  We believe it is time to launch conversations on how the
leadership of CalGreen might be adjusted so that it can once again
serve as a forward-looking beacon and roadmap for positive change. 
The innovative CalGreen tier system can become a means of
'predicting the future', if it can be more directly aligned with
our aspirations.  The fact that 50+ California jurisdictions that
have not found the current framework helpful for them to meet their
reach code needs is stark evidence that CalGreen is not serving us
as well as it should.  
Support for Retrofit and Repurpose Existing Buildings for Housing
and other pressing needs
Finally, AIA CA believes there is a need for greater support in our
California building code for retrofit and repurpose of our vast
existing building stock.  In particular we see a tremendous
unrealized potential in urban areas for repurposed obsolete
commercial infrastructure as new innovative urban housing; this was
recently well documented by two studies from the Terner Center for
Housing Innovation.  
https://ternercenter.berkeley.edu/blog/two-new-papers-explore-the-potential-of-commercial-to-residential-conversions)/
 
Retrofit and repurpose of existing buildings can be win win win:
addressing California urgent need for more housing, while at the
same time addressing climate action, urban revitalization, equity
and inclusion, and embodied carbon reduction.  Design professionals
are hampered in pursuing these opportunities by the large gap
between the California Existing Building Code and the innovations
that already exist in the International Existing Building Code.  We
encourage the support of CARB and other state agency stakeholders
as we move forward with the AIA CA petition launched in the last
code cycle to amend the CEBC to mirror the full compliance path
framework of the IEBC.

Respectfully Submitted
Michael F. Malinowski FAIA
Code and Regulatory Consultant    AIA California 
mfm@appliedarts.net