| A | B | C | D | E | F | |
|---|---|---|---|---|---|---|
1 | Biobased Construction Materials Methodology V2.0 | Methodology ID: | RIV-BIOBM-01-CONST-V2.0 | |||
2 | Public consultation collected comments and responses | Public Consultation period: | January 31st-March 1st, 2024 | |||
3 | Author | Comment | Type | Riverse response | Implemented? | Status |
4 | Simon Deschamps - Climate Dividends Fundation | I understand that this is mainly linked to the lesser valuation of short term removal credits on the market today for several reasons. However, what is the reason for not classifying them as "short term removal credits"? IMHO the option presented here is not representative of the global consequence on climate this has AND it creates confusion on the notion of avoided emissions while we should be looking for more normalization and standardization of the notion today. | General | We acknowledge that this was a confusing way of presenting it so we rewrote the calculations section, and specified more clearly in that only materials with a lifetime of 100+ years are eligible for Riverse removal credits, and will have their biogenic carbon content valued. Otherwise, the materials are eligible for avoidance credits like any other product, and the biogenic carbon content is not recognized. Riverse currently offers no option for "short term removal credits", i.e. removals less than 100 years. Many would argue that a cut off at 100 years is already short term, since 'permanent' removal is often defined on a time scale of thousands of years. Nevertheless, 100 years is a common cutoff in carbon markets based on the goal of removing carbon until peak warming has passed. This goal is rooted in climate science, described well at the link below. Such peak warming cannot realistically and conservatively be expected before 100 years. Additional resource: https://carbonmarketwatch.org/wp-content/uploads/2023/09/FINAL-CMW-version-of-temporary-storage-paper.pdf | Calculations were rewritten for clarity but no "short terms removals" are certified under this methodology | Validated |
5 | Simon Deschamps - Climate Dividends Fundation | Why is it limited? | Technical | In our experience, the more numerous co-benefits are claimed by a project developer, the lower quality they are. We prefer to highlight a smaller number of high-quality, well proven, measurable co benefits. We haven't seen a project prove more than 4 solid co-benefits. | No | Rejected |
6 | Simon Deschamps - Climate Dividends Fundation | In reality, it seems very hard to assess. The performance of materials might increase the quantity that is used (200mm of wood wool = 180mm of rock wool for example). But I don't see many cases where the developer would say: "I can only install 200mm of insulation material, I'll decrease my requirements and the expected performance to accomodate for a less efficient material" | Technical | Yes that is why it will only be assessed qualitatively in the risk assessment template. Note that this only covers the secondary performance characteristics, not the main function of the product. | No | Rejected |
7 | Simon Deschamps - Climate Dividends Fundation | Here, it would be great to provide some details on the scope of reductions: are we considering the building phase, the use phase or both? | Editorial | Specified in paragraph 2.8.2 | Yes | Validated |
8 | Simon Deschamps - Climate Dividends Fundation | It would be beneficial to highlight the fact that materials might not have the same performances here and that baseline and project must be adjusted to take that into account. An example would help too | Editorial | We added the following text in the Substitution section: "If the performance of the primary function of the project scenario material is different from the baseline material, this must be accounted for in the baseline scenario selection. For example, if the project scenario material has a worse performance than the baseline material, a larger quantity of the project material may be required to attain the same performance/function as the baseline material." And the following text in the baseline section: "See the Substitution section for more requirements regarding the performance of project and baseline materials." | Yes | Validated |
9 | Simon Deschamps - Climate Dividends Fundation | I didn't understand this part and I can't easily find the reference you're pointing towards | Editorial | Added a different reference, this is described in the section Methodological Challenges of Wooden Building LCAs of the referenced article. The section has been revised for clarity, but we do not go into further explanation of the +1/-1 method, since it is largely described elsewhere and assumed that people reading this technical section are familiar with the method. | Yes, revised for clarity but no major change | Validated |
10 | Nicolas FERRIERE - CarbonApp | It's important to anticipate product retailers that will break traceability and downstream transportation calculation, and which won't want to provide their clients' names to the wadding producers. They won't communicate more data on their customer base and sites delivery. For cellulosis wadding, with the retailer, we don't know if the insulator will be used for walls or attics, so we lose the final use by the end-user... | Technical | Yes that is why we have set out the requirements presented in the Double Counting section. It is true that if the supply chain is long and there are many intermediaries, the risk of double counting increases. We will monitor this, and if the risk is high for many projects, we will only allow certification of the second project type: building developers. | No | Rejected |
11 | Nicolas FERRIERE - CarbonApp | WARNING! Issue on the French market, the FDES all announce durations of 25-50, 75 years max, but not 100 years. All plinthes, floors, stairs and other are minored to 25-30 years, vertical and horizontal construction items are more between 50 to 75 years. But there are none with 100 years duration. Ok with below information. | Technical | We added the clarification text in paragraph 2.1.1: "Note that the carbon storage duration may differ from the reference service lifetime. If the project developer can justify that the material would be landfilled, and is rather resistant to decomposition, and would continue to store carbon beyond its reference service lifetime, the carbon storage duration may be longer than the reference service lifetime." For example, this is the case for hemp concrete. | Yes, clarification notes were added | Validated |
12 | Nicolas FERRIERE - CarbonApp | Ok on that | General | Ok | No | Rejected |
13 | Nicolas FERRIERE - CarbonApp | It's important to specify that it's the last transforming player before site delivery, which will then be able to justify delivered volumes until the construction site under its supervision, avoiding the risk of loss of material during the downstream transport to the construction site. For example, the manufacturer of CLT pannels could be eligible although it delivers to a manufacturor "préfabois" off-site. We would then have a stakeholder very upstream of the value chain who delivers a product that will be processed and we'll lose mater, so carbon, and the risk of double accounting is stronger downstream of the value chain. Furthermore, it breaks traceability until the site and we'll lose the ability to do real calculation of emissions of downstream transportation. | Technical | - Regarding loss of material during transport: this can evaluated at the project level in the uncertainty assessment, and applied as a buffer. - Downstream transportation is not typically included in the project scope, because it is assumed to be the same as the baseline scenario. - As mentioned above, depending on the nature of projects and the supply chains we encounter, we will consider limiting the eligiblity to building developers. As you suggest, they are the 'last player' and can have the most reliable information on how products are used. | No | Rejected |
14 | Nicolas FERRIERE - CarbonApp | Huge variability of recent market studies with RE2020 that just came and that boosts market changes, we barely make the distinction between new and renovation according to types of application (walls, lost attics, roofs, intermediary floors, ...) | General | We acknowledge the potential variability on this sector given evolution on that market. Therefore we require project to provide with the most recent and most accurate estimate. The Riverse Climate team might provide research if needed. The uncertainty buffer can be used to account for this. | No | Rejected |
15 | Nicolas FERRIERE - CarbonApp | I understand that if we study LCA for Modules A-C, we are going to count for CO2 release at step C. So for the wadding, the biobased property is not counted because it's released at step C. So in reality, if I compare a biobased product to extruded polystyrene, we actually only account for avoided production emissions since we consider that biogenic carbon of the wadding will be released at step C. Therefore, the only guard rail to the method is the type of "biobased" product considered. Because otherwise we could compare rock wool to polystyrene and generate reduction emissions. It's then strange to talk about biobased product but to exculde biogenic sequestration (for low-duration products). I understand that if the product last more than 100 years, we'll be considering removal and the end of life release will probably not be visible in the A-C LCA. | General | Yes you understand correctly. The text has been revised to communicate this more transparently in the last paragraph of the introduction, and throughout the calculations section. | Yes, introduction revised | Validated |
16 | Christophe Nourissier - Augur Associates | According to the brand new EU CRCF, the scope of caron permanence has been expanded and made more granular. For this methodology, it implies new cathegories: - permanent carbon removal in atmospheric or biogenic pools (100y+) - temporary carbon storage in long-lasting products (35 – 100y) Perhaps your methodology should include this additional type of products? | General | Indeed this is a new development from the EU, so we are following it closely and deciding how to incorporate it into our removals approach. For the moment, we have decided to keep our conservative approach and only issue Riverse removal credits for removals >100 years. We will continue to monitor the CRCF and see if/how we can value short term removals according to that framework. | No change but this point might evolve in the future as CRCF is being enruled. | Rejected |
17 | Christophe Nourissier - Augur Associates | What if there are negative emissions outside of the A1-3 module ? Are they also considered as biogenic capture ? | Technical | No, negative emissions outside the scope of the A1-3 module will not be considered biogenic capture. | No | Rejected |
18 | Christophe Nourissier - Augur Associates | How do you intend to include the "R" thermal resistance value in comparing performances ? | Technical | This is considered when selecting the baseline scenario material. We have many EPDs from conventional materials to choose from when designing the baseline scenario, so we screen several factors to make sure we choose the most relevant baseline material. So for example, the R thermal resistance must be similar in the project and baseline material. The list provided in the text is meant to provide examples, and is not an exhaustive list. This has been clarified in the text in paragraph 3.3.6. | Yes, clarifications brought to the content but no major change | Validated |
19 | Arpad Horvath - UC Berkeley | Define "distant" in terms of kilometers. | Editorial | This will be defined and evaluated for each project. | No | Rejected |
20 | Arpad Horvath - UC Berkeley | Define "distant." | Editorial | This section has been removed for other reasons. | No | Rejected |
21 | Arpad Horvath - UC Berkeley | Is there a reference for why the 45% reduction is specified? | Technical | Source added. Note that to align with the Riverse Standard Rules V6 this has been incrased to 73%. | Yes | Validated |
22 | Arpad Horvath - UC Berkeley | Put 2 in superscript. | Editorial | Yes done. | Yes | Validated |
23 | Arpad Horvath - UC Berkeley | Put 2 in subscript (elsewhere in the document too). | Editorial | Yes done. | Yes | Validated |
24 | Arpad Horvath - UC Berkeley | On this line too, 2 should be in the superscript. | Editorial | Yes done. | Yes | Validated |
25 | Arpad Horvath - UC Berkeley | i.e. here should all be e.g., | Editorial | Yes done. | Yes | Validated |