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Written Comments

Santa Monica City Council
April 23, 2024

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Written Comments
Meeting
April 23, 2024
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Santa Monica City Council
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9.1 MB
Text extracted from the city's file for reading and search. Open the original on santamonicacityca.iqm2.com. That file is the official record.

1 David Yakobson
From: Kubiak, Lauren <[email protected]>
Sent: Tuesday, April 23, 2024 11:44 AM
To: councilmtgitems
Subject: NRDC Comments on Agenda Item 10A: Low Carbon Concrete Code - SUPPORT Attachments: NRDC SM Low-Carbon Concrete Code Support Letter.docx

EXTERNAL
Hello,
Please find attached a letter from NRDC in support of the proposed Low Carbon Concrete Ordinance. Thank you for your consideration.

Kind regards,
Lauren

LAUREN KUBIAK
Senior Scientist, Climate & Clean Energy

NATURAL RESOURCES

DEFENSE COUNCIL
111 SUTTER ST

SAN FRANCISCO, CA
LKUBI [email protected]
NRDC.ORG
Item 10-A
April 23, 2024
Item 10-A
April 23, 2024
April 23, 2024
Re: Agenda Item 10A The Santa Monica Low Carbon Concrete Code - SUPPORT Dear Mayor Brock and Councilmembers:

We write to express the Natural Resources Defense Council (NRDC)’s support for the adoption of the proposed Low Carbon Concrete Code in Santa Monica. This ordinance would set embodied greenhouse gas emission limits on concrete used in construction of new buildings in Santa Monica. This motion builds on the amendments to the 2022 California Green Building Standards Code, Part 11, Title 24 (CALGreen) that the California Building Standards Commission adopted in August 2023, aligns with the City’s efforts to decarbonize building energy use in new construction, and would set Santa Monica on a leadership path toward addressing embodied carbon emissions from concrete.

Addressing greenhouse gas emissions from embodied carbon is crucial to meeting California’s climate targets. Globally, embodied carbon emissions from construction materials comprise 8 to 11 percent of global carbon emissions but are estimated to increase as new construction is undertaken to meet the needs of growing populations. The statewide CALGreen embodied carbon requirements are a good start in tackling embodied emissions from buildings and materials, but they were designed to be readily achievable to raise the floor, rather than raise the bar. This proposed rule would raise the bar and set Santa Monica on a pathway toward implementing a robust program that can achieve meaningful emissions reductions from concrete used within the city.

Cement is the binding ingredient in concrete and responsible for 90 percent of concrete’s greenhouse gas emissions despite being only around 10 percent by mass. Often, the amount of cement added to concrete exceeds what is necessary to hold the concrete together. Substituting supplementary cementitious materials (SCMs) for some of that cement can reduce the embodied emissions of concrete by up to 40-50 percent without compromising on strength and durability.

In fact, many SCMs increase the durability of concrete. This proposed motion would set maximum cement limits for different compressive strength levels of concrete to minimize the overuse of cement. It would additionally set global warming potential (GWP) limits on concrete.

By adopting this motion, Santa Monica would leverage the administrative capacity already being utilized to implement the CALGreen amendments to achieve deeper reductions in embodied carbon emissions from concrete. This would unlock additional savings without meaningful increases in city staff time or project costs, but large potential additional emissions reductions.

NRDC supports the adoption of this motion so that Santa Monica can unlock important emission reductions from concrete.

Thank you for your consideration.

Sincerely,
Lauren Kubiak
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April 23, 2024
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Senior Scientist
Natural Resources Defense Council
111 Sutter St., 21st floor
San Francisco, CA 94104
Telephone: (415) 875-6100
Email: [email protected]
Item 10-A
April 23, 2024
Item 10-A
April 23, 2024
2 David Yakobson
From: Cynthia Rose <[email protected]>
Sent: Tuesday, April 23, 2024 10:27 AM
To: councilmtgitems; Council Mailbox; Gleam Davis; Jesse Zwick; Caroline Torosis; Lana Negrete; Oscar de la Torre; Phil Brock; Christine Parra; David White; Shannon Parry Cc: [email protected]
Subject: Support Agenda Item 10A:

Attachments: 2024-04 CC Item 10A Low-Carbon Concrete Policy Ordinance SaMoSSA.pdf

EXTERNAL
Dear Santa Monica City Council and Staff
We write as community organizations to express our full support of the Low-Carbon Concrete Policy Ordinance, item 10- A on this Earth Day in the 30th year of Santa Monica’s leadership for sustainability, now necessarily driven by our City’s Climate Action and Adaptation Plan.

Please see our attached letter of support from the Santa Monica Safe Streets Alliance (SaMoSSA), Climate Action Santa Monica (CASM), Santa Monica Safe Streets Alliance-Youth Leadership Collective (SaMoSSA- YLC), Team Marine, Santa Monica Spoke and Santa Monica Forward.
--
Cynthia Rose & Cris Gutierrez
Co-Chairs
Santa Monica Safe Streets Alliance
SaMoSafeStreets.org
We acknowledge with respect and gratitude the Tongva, Kizh, and Chumash Peoples on whose traditional territory I live and work.

Item 10-A
April 23, 2024
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Agenda Item 10A: Community Organizations letter in support of Low-Carbon Concrete Policy Ordinance Dear Mayor and City Council Members:

On this Earth Day in the 30th year of Santa Monica’s leadership for sustainability, now necessarily driven by our City’s Climate Action and Adaptation Plan, we write as community organizations to express our full support of the Low-Carbon Concrete Policy Ordinance, item 10-A. We commend the staff’s careful, diligent work, in collaboration with local leaders and experts in the construction field, for developing a practical means of reducing at least ten percent of and as much as one-third of our local concrete carbon embodied in the building sector. The Low-Carbon Concrete Policy Ordinance would be a significant climate solution for Santa Monica, setting a standard that other cities in the state and country could follow.

With levels of CO2 in the atmosphere exceeding 419 parts per million on average in 2023, global warming has continued to increase year after year, now most dramatically evident in the extraordinary rise in the oceans temperature, our local climate innovations and influence are invaluable. Already Marin County and the City of Palo Alto have moved to require the low-carbon concrete option. Santa Monica can add its authority to making such a shift and help also advance California’s SB 596 requiring strategies for reducing greenhouse gas emissions in the cement sector. If we are to meet our committed City’s community-wide climate goals of reducing our carbon emissions by 80% below 1990 levels by 2030, there is not a moment to waste. With a low-carbon concrete policy, Santa Monica again proves it is serious about confronting the climate emergency.

Community members have also learned about the structural strength and durability of the low-carbon concrete. For example, the main ingredients of low carbon concrete - pozzolans - have been used coast to coast - recently on the Freedom Tower in NY and the San Francisco - Oakland Bay Bridge in CA because of the increased resilience and strength the pozzolans contribute. In fact, the pozzolans we use in low carbon concrete today are chemically similar to the pozzolans used in the long-lasting Roman concrete. With earthquake vulnerability in the back of some of our minds, that durability means a lot.

What is also exciting is that low-carbon concrete costs no more than traditional concrete: no premium cost and quite possibly cost savings. What more could we want? As our community’s youth have testified with others before Council over three decades to advocate for sustainability and climate actions, our City and community have become more sensitized to the fact that we respect and care for each other by also caring for our Earth. Those voices reverberate from past to present and will do so far into the future as all of us individually and collectively practice habits enabled by policies and programs to confront the climate emergency in every way that we can with vitality and imagination.

We trust that the Council will see that unanimous approval of the Low-Carbon Concrete Policy Ordinance can sustain future generations.

Sincerely,
Cynthia Rose Cris Gutierrez
Santa Monica Safe Street Alliance, Co-Chair Santa Monica Safe Streets Alliance, Co-Chair SaMoSafeStreets.org
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April 23, 2024
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Climate Action Santa Monica: Laurene Von Klan and Kent Strumpell, Co-Chairs SaMo Safe Streets Alliance-Youth Leadership Collective: Emery Cunningham, Sam Cozolino Co-Chairs
Team Marine: Willa Ross, Maya Williams, Emery Cunningham, Co-Captains Santa Monica Spoke: Cynthia Rose, Director
Santa Monica Forward: Brad Ewing, Carl Hansen, Co-Chairs Item 10-A
April 23, 2024
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April 23, 2024
3 David Yakobson
From: David Haake <[email protected]>
Sent: Tuesday, April 23, 2024 9:15 AM
To: councilmtgitems
Cc: Scott Morris; [email protected]; Morgan Goodwin; Kimberly Orbe; Cris Gutierrez Subject: Letter in SUPPORT of Santa Monica City Council Agenda Item 10A - Tuesday, April 23, 2024
Attachments: Sierra Club - Santa Monica Low Carbon Cement Code.pdf

EXTERNAL
Dear Mayor Brock and Councilmembers,
Sierra Club is pleased to submit the attached letter in support of Santa Monica City Council Agenda Item 10A for Tuesday, April 23, 2024.

We are writing to express our strong support for a Low Carbon Concrete Code in Santa Monica. Our letter provides a 7- point detailed justification for why Santa Monica should approve this ordinance and references Sierra Club's Guidance on Cement Manufacturing, which is a important general resource on this topic.

Thank you for the opportunity to submit public comment.

Feel free to contact me if you have questions or would like further discussion.

David Haake, MD
Chair, West Los Angeles Group, Angeles Chapter, Sierra Club Cell 310.237.3447
cc. Ellis Raskin, Scott Morris, Kim Orbe, Morgan Goodwin, Cris Gutierrez Item 10-A
April 23, 2024
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April 22, 2024
Re: Agenda Item 10A The Santa Monica Low Carbon Concrete Code - SUPPORT
Dear Mayor Brock and Councilmembers,
On behalf of the Sierra Club, we are writing to share our strong support for a Low Carbon Concrete Code in Santa Monica.

The Sierra Club is America’s largest and most influential grassroots environmental organization, with more than 3 million members and supporters. In addition to helping people from all backgrounds explore nature and our outdoor heritage, the Sierra Club works to promote clean energy, safeguard the health of our communities, protect wildlife, and preserve our remaining wild places.

The Sierra Club and its allies around the country have been combatting the toxic emissions of cement kilns for decades. Making cement requires temperatures of at least 1400°C (2552°F)— and the chemical reaction that creates cement releases CO2 as well. If the cement industry were a country, it would be the third-largest producer of greenhouse gases on Earth. To meet the targets set at the Paris Agreement, nations around the world must reduce cement emissions by a quarter in the next 30 years.

We strongly encourage the City of Santa Monica to approve this ordinance for the following reasons:

Cost: Low Carbon Concrete has the potential to create more affordable housing and construction because it limits the use of expensive (and highly polluting) Portland cement.1 2 Supply: The materials used to make low carbon concrete, also known as pozzolans, are available in Southern California, including at Santa Monica’s ready-mix plant, Associated Ready Mix.

Resilience: The materials used to make low carbon concrete – pozzolans – happen to have the same chemical composition of materials used in long-lasting Roman concrete (i.e. the Pantheon, the Roman Aqueducts, or the Colosseum). More recently, these pozzolanic materials have been proven to provide resilience in earthquake-heavy Peru.3 Sulfate Resistance: Concrete with pozzolanic material is more resistant to sulfates which is especially beneficial in coastal areas like Santa Monica.4 5 Case Studies: One World Trade Center, the new Oroville Dam, net zero homes, San Francisco-Oakland Bay Bridge, Mario Cuomo Bridge, and the Santa Monica Moonstone.

Code Precedence: Marin County, Palo Alto, Portland, Denver, California, Colorado, NY/NJ Port Authority, and the U.S. General Services Administration.

Exemptions: Similar to Marin County’s and Palo Alto’s low carbon concrete codes, this ordinance provides exemptions for high-early strength applications and opportunistic green premiums.
1 Chan et al. 2023
2 Esau et al. 2021
3 Leon-Miguel et.al 2023
4 Spragg. U.S. DOT
5 American Concrete Institute
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In summary, low carbon concrete is not only the superior, stronger, more resilient concrete, but also a solution to the construction industry's high carbon emissions. For the above reasons, and so many more, and in celebration of the 30th Anniversary of the Santa Monica Sustainable City Plan, we urge you to vote yes on this ordinance.

More information available from the Sierra Club’s Guidance on Cement Manufacturing.

Please feel free to contact me if you have any questions. Thank you for your consideration.

Sincerely,
David A. Haake, M.D.

Chair, West Los Angeles Group, Angeles Chapter, Sierra Club Item 10-A
April 23, 2024
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1 David Yakobson
From: Amanda Grossman
Sent: Monday, April 22, 2024 11:26 AM
To: councilmtgitems
Cc: Peter Roquemore
Subject: Item 10a - Low Carbon Concrete
Attachments: 23.09.18_LowCarbonConcrete2.pdf; 24.01.22_LowCarbonConcrete - signed.pdf Good morning,
Attached are two motions made by the Commission on Sustainability, Environmental Justice, and the Environment regarding Item 10a on Council’s agenda – Low Carbon Concrete Policy. The proposed ordinance was originally presented to the Commission at their regular September meeting. The Commission made a motion in support of the ordinance.

Staff returned to the Commission in January with some updates to the proposed ordinance. The Commission made another motion in support of the proposed updates.

Please let me know if you have any additional questions. Thank you.

Amanda Grossman (She/Her)
Sustainability Analyst
LEED Green Associate, TRUE Advisor, ENV SP
(310) 458-2201 x 2406
santamonica.gov
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Item 10-A
April 23, 2024
Item 10-A
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Memo
To: City of Santa Monica City Council
From : Dean Kubani, Chair, Commission on Sustainability, Environmental Justice and the Environment
Sig na ture :

Da te : September 18, 2023
Re : City of Santa Monica Commission on Sustainability, Environmental Justice, and the Environment Motion Regarding Low Carbon Concrete Ordinance
Peter Roquemore (Sustainability Analyst) provided an update on the Low Carbon Concrete Ordinance to reduce emissions from embodied carbon in the built environment.

Staff recommends adopting an amendment to two CalGreen 2022 Reach Codes that replace a cement limit (amount of cement used in concrete mix) and global warming potential limit (amount of kilograms of carbon dioxide per cubic meter of concrete). Materials like concrete contribute to a large amount of the building sector emissions.

The ordinance would include exemptions for lack of commercially available material necessary to comply or emergency purchases, as we as exemptions for pre-packaged proprietary concrete bags used for small quantities.

After discussion, the Commission on Sustainability, Environmental Justice, and the Environment made the following motion:

The C o m m issio n o n Susta ina b ility, Enviro nm e nta l Justic e , a nd the Enviro nm e nt re c o m m e nd s tha t C o unc il a d o p ts a Lo w C a rb o n C o nc re te O rd ina nc e to re d uc e g lo b a l w a rm ing e m issio ns fro m the C ity’s b uild ing sector.

The motion was made by Member Gold and seconded by Member Kubani Item 10-A
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The motion was approved by the following roll call vote:

Ayes: Chair Kubani
Member Gold
Member Pettit
Member Lempert
Noes: None
Abstain: None

Absent: Vice Chair Mearns, Member Tower, and Member Sokol Item 10-A
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Memo
To:

From :

Sig na ture :

Da te :

Re :

The C o m m issio n o n Susta ina b ility, Enviro nm e nta l Justic e , a nd the Enviro nm e nt re c o m m e nd s tha t C o unc il a d o p ts a n Lo w C a rb o n C o nc re te O rd ina nc e to re d uc e g lo b a l w a rm ing e m issio ns fro m the C ity’s b uild ing se c to r.

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April 23, 2024
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2 David Yakobson
From: Peter Moran <[email protected]>
Sent: Monday, April 22, 2024 8:40 AM
To: councilmtgitems
Subject: Item 10A - Support Letter

EXTERNAL
Mayor Brock and City Councilmembers,
I am a Santa Monica resident and small business owner and I'm writing to express my support for item 10A on your April 23rd agenda, the adoption of the Low Concrete Carbon Code.

The concrete industry is one of the largest contributors to global carbon emissions and this will be a great step toward lowering carbon emissions from the building industry here in Santa Monica. As I'm sure you all know, California often leads the nation and the world in developing and implementing green and sustainable practices for all industries, so hopefully adopting this new Code will also encourage other municipalities to do the same, having a positive domino effect in cutting carbon emissions.

I am in the real estate development and construction industry and have done extensive research into sustainable materials, and implementing this Code would be one of the most effective carbon-cutting strategies for the construction industry. I have personally used low concrete carbon (less Portland cement content) on projects here in southern California and also in Florida. We found that the concrete we poured using the more sustainable mix met and sometimes exceeded our compressive strength requirements and did not come with a cost premium, sometimes it even saved money!
The construction industry can often be one of the slower industries to adapt to changes in trends and technologies - and sometimes the industry needs a nudge in the right direction. And unfortunately, with global climate change reaching catastrophic levels, the time for change is now. Implementing this new Code will make a huge difference in positively impacting the environment with little to no negative impacts on other stakeholders (the concrete industry, subcontractors, developers, etc.).

Thank you for your diligent work and I hope you move to approve Item 10A! Peter Moran
Bay to Bay Development Services, LLC
[email protected] / (301)-580-4171
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3 David Yakobson
From: Scott Morris <[email protected]>
Sent: Friday, April 19, 2024 7:38 PM
To: councilmtgitems
Subject: Agenda Item 10A on the April 23rd Agenda: SUPPORT

EXTERNAL
Dear Mayor Brock and Councilmembers,
I am writing to express my strong support for Item 10A on your April 23rd agenda: adoption of the Low Carbon Concrete Code.

This upcoming week we celebrate Santa Monica’s 30 year anniversary passing the Sustainable City Plan, and what a great anniversary present it would be to adopt this code which addresses one of the most polluting materials on earth - concrete. The ordinance also demands resilient, longer lasting concrete in addition to lower carbon concrete. Concrete accounts for about 8% of global CO2 emissions and passage of this ordinance would be a great belated gift for this April 22 Earth Day! I have personally poured low carbon concrete using Santa Monica’s ready-mix plant - Associated Ready Mix - and the concrete exceeded the engineer’s strength requirements every time.

Thank you for your consideration of my commentary and for your past and, hopefully, future leadership to reach net zero carbon emissions as soon as possible - Zero Can’t Wait! Thank you,
Scott Morris
Santa Monica Resident
2221 Ocean Avenue
Santa Monica, CA 90405
Item 10-A
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4 David Yakobson
From: Scott Morris <[email protected]>
Sent: Friday, April 19, 2024 7:28 PM
To: councilmtgitems
Subject: Agenda Item 10A on the April 23rd Agenda: SUPPORT Attachments: Item 10A April 23, 2024 SUPPORT.pdf

EXTERNAL
Dear Mayor Brock and Councilmembers,
Please accept the attached letter of support for Item 10A from The Low Carbon Initiative. --
To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.

Scott Morris
Zero Can't Wait
lowcarboninitiative.org
818-854-2663
Item 10-A
April 23, 2024
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April 19, 2024
Re: Agenda Item 10A: The Santa Monica Low Carbon Concrete Code - SUPPORT Dear Mayor Brock and Councilmembers,
On behalf of The Low Carbon Initiative - an organization devoted to accelerating decarbonization in the built environment – we strongly urge you to approve this ordinance for the following reasons:

Cost: Low Carbon Concrete has the potential to create more affordable housing and construction because it limits the use of expensive (and highly polluting) Portland cement.1 2
Supply: The materials used to make low carbon concrete, also known as pozzolans, are available in Southern California, including at Santa Monica’s ready-mix plant, Associated Ready Mix.

Resilience: The materials used to make low carbon concrete – pozzolans – happen to have the same chemical composition of materials used in long-lasting Roman concrete (i.e. the Pantheon, the Roman Aqueducts, or the Colosseum). More recently, these pozzolanic materials have been proven to provide resilience in earthquake-heavy Peru.3 Sulfate Resistance: Concrete with pozzolanic material is more resistant to sulfates which is especially beneficial in coastal areas like Santa Monica.4 5 Case Studies: One World Trade Center, the new Oroville Dam, net zero homes, San Francisco-Oakland Bay Bridge, Mario Cuomo Bridge, and the Santa Monica Moonstone.

Code Precedence: Marin County, Palo Alto, Portland, Denver, California, Colorado, NY/NJ Port Authority, and the U.S. General Services Administration.

Exemptions: Similar to Marin County’s and Palo Alto’s low carbon concrete codes, this ordinance provides exemptions for high-early strength applications and opportunistic green premiums.

In summary, low carbon concrete is not only the superior, stronger, more resilient concrete, but also a solution to the construction industry's high embodied carbon emissions. For the above reasons, and so many more, and in celebration of the 30th Anniversary of the Santa Monica Sustainable City Plan and Earth Day, we urge you to vote yes on this ordinance. 5 American Concrete Institute
4 Spragg. U.S. DOT
3 Leon-Miguel et.al 2023
2 Esau et al. 2021
1 Chan et al. 2023
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Sincerely,
Scott Morris
Director
The Low Carbon Initiative
[email protected]
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5 David Yakobson
From: Nathan Forrest <[email protected]>
Sent: Friday, April 19, 2024 4:06 PM
To: councilmtgitems
Subject: Letter of support for Item 10A on the April 23rd City Council Meeting Agenda Attachments: CNCA Support for Santa Monica Low Carbon Concrete Code.pdf

EXTERNAL
Please find aƩached a leƩer of support for Item 10 A on the April 23rd City Council MeeƟng Agenda - IntroducƟon and First Reading of Low-Carbon Concrete Policy Ordinance and AdopƟon of Local Amendments Findings ResoluƟon
Regards,
Nathan Forrest, P.E., ENV SP
Technical Director
Cell: 520-235-0480
[email protected]
Item 10-A
April 23, 2024
Item 10-A
April 23, 2024

April 19, 2024
Santa Monica City Council
Subject: April 23rd Councill Meeting Item 10A – Low Carbon Concrete Code
Dear Council Members,
I am writing on behalf of CNCA (CaliforniaNevada Cement Association), an organization committed to providing solutionsfocused on sustainability, resilience, and economic impact.

We do this with cement-based materialsthat are the very foundation of our civilization. We have had the opportunity to review the Low-Carbon Concrete Policy Ordinance and we are pleased to express our support for thisinitiative.

CNCA is committed to actively participating in and contributing to the success of this initiative.Ourteam is eagerto continue to collaborate with city staff, ready-mix concrete producers, and otherstakeholdersinvolved in the effort. We believe that our expertise in carbon reduction and concrete sustainability will make a meaningful contribution to the efforts outlined in the proposal. By supporting the city in this endeavor, we anticipate positive outcomesthat will not only benefitthe city but also set a precedent for other agencies to follow.

We look forward to the opportunity to work together on thisimportant project and contribute to the advancement of low carbon concrete standards, codes, and specifications.

Sincerely,
Nathan Forrest
TechnicalDirector
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6 David Yakobson
From: Tara Barauskas <[email protected]>
Sent: Friday, April 19, 2024 12:36 PM
To: councilmtgitems
Subject: Item 10A - support
Attachments: Item10Asupport.pdf

EXTERNAL
Please find attached our letter of support for item 10A.

Tara Barauskas, LEED AP
Executive Director
Community Corporation of Santa Monica
We have moved! Our new address is:
1410 2nd Street, Suite 200
Santa Monica, CA 90401
(310) 394-8487 ext. 133
[email protected]
www.communitycorp.org
I acknowledge with respect and gratitude the Tongva, Kizh, and Chumash Peoples on whose traditional territory I live and work.

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