First Name: | Bruce |
---|---|
Last Name: | Ray |
Email Address: | bruce.ray@jm.com |
Affiliation | Johns Manville |
Subject | Energy Efficiency and Indoor Air Quality |
Comment |
Johns Manville strongly agrees with the proposal in the draft Scoping Plan to use Green Building principles and standards to help achieve the greenhouse gas (GHG) emissions reduction goals in AB-32. Many studies have confirmed that constructing new and retrofitting older buildings to achieve levels of energy efficiency to beyond what is required by current code is a cost effective way to achieve significant GHG emissions reductions in the short term. In fact, the attached article from the March 2007 The McKinsey Quarterly demonstrates that greater levels of insulation installed in existing and new homes and buildings are among the most cost effective ways to fight climate change. (See graph on article page 38, pdf page 4.) Insulation can actually have a net negative cost, i.e., extra insulation may not cost money but instead can save it. But CARB should be careful to avoid poor indoor air quality as an unintended consequence of increased energy efficiency. The vast majority of older homes do not have continuous mechanical ventilation and instead may depend largely on outside air infiltration as a principal source of fresh air. But retrofitting older homes to achieve a higher level of energy efficiency is all about making them tighter and reducing air infiltration. The same holds true for new homes. The Offerman ventilation study being performed for CARB will note that even new homes with ventilation systems can have an unacceptably low rate of actual air changes per hour. The result can be that indoor air pollutants from building materials, including formaldehyde, may tend to build up to unacceptable levels in an energy efficient home. This means that great care must be taken to select non-emitting building materials, including insulation, for use in new residential construction and in residential retrofit applications. There is an increasing number of no-added formaldehyde alternative products commercially available today. This includes Johns Manville’s full line of Formaldehyde-freeTM fiber glass building insulation. As part of the AB-32 energy efficiency measures, we urge CARB to maintain its previous guidelines on formaldehyde: - CARB Indoor Air Quality Guideline: “Formaldehyde in the Home” (Aug. 2004) http://www.arb.ca.gov/research/indoor/formaldGL08-04.pdf [recommends formaldehyde-free building materials generally] - CARB Fact Sheet: “Reducing Your Exposure to Formaldehyde” (Aug. 2004) http://www.arb.ca.gov/research/indoor/formaldfs08-04.pdf [recommends formaldehyde-free insulation] Johns Manville, a Berkshire Hathaway company (NYSE: BRK.A, BRK.B), is a leading manufacturer and marketer of premium-quality building and specialty products. In business since 1858, the Denver-based company in 2002 converted its entire line of fiber glass building insulation to a no-added formaldehyde formulation. Johns Manville’s fiber glass building insulation plants are the only ones in the industry exempted by US EPA from Clean Air Act hazardous air pollutant regulations. Additional information can be found at www.jmhomeowner.com. Thank you. |
Attachment |
www.arb.ca.gov/lists/sp-greenbuild-ws/16-mckinsey_study_-_cost_curve_for_ghg_emission_reductions_-_march_2007.pdf Original File Name: McKinsey study - cost curve for GHG emission reductions - March 2007.pdf
Date and Time Comment Was Submitted: 2008-08-01 17:28:21 |
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