• Compliance: California is leading the way, setting ambitious targets for embodied carbon reduction (explained below). Projects that don’t meet these standards may not even receive the necessary permits to begin construction. Avoid costly setbacks and ensure your project complies with the latest regulations.
• Sustainability Profile: Enhance your project’s appeal and value. Today’s buyers and investors are increasingly prioritizing sustainability. A low embodied carbon footprint can be a key differentiator, attracting tenants and commanding higher prices.
• Cost Savings: Reduce both upfront and long-term costs. Optimizing material use and minimizing waste reduces initial expenses. Choosing durable, low-carbon materials can also lower maintenance and replacement costs over the building’s life cycle.
• Marketing Tool: Tap into the growing market for green buildings. Showcase your project’s low carbon footprint to attract environmentally conscious buyers and gain a competitive edge in the market.

Assembly Bill No. 2446 (AB 2446) 

• • Scope: The bill applies to the construction of new buildings, including residential buildings.
  • Goal: To significantly reduce embodied carbon emissions associated with building materials in California, aligning with the state’s goal of carbon neutrality by 2045.
  • Mandate: Requires the California Air Resources Board (CARB)7 to develop a framework for measuring and reducing embodied carbon by July 1, 2025.
  • Targets: Sets ambitious reduction targets:
    • 40% net reduction in greenhouse gas emissions from building materials by 2035.
    • Interim target of 20% by 2030 (eliminated in AB 43).
  • Baseline: The baseline for these reductions will be determined using industry average data from 2026. 
  • Read more here.

Assembly Bill No. 43 (AB 43)

• • Scope: Amends and adds to existing law (AB 2446) related to reducing greenhouse gas emissions associated with building materials in California.
  • Goal: To further support the reduction of embodied carbon in building materials by authorizing an embodied carbon trading system. This would allow market-based exchange of emissions credits with a target implementation of January 1, 2029.
  • Mandate: Authorizes the California Air Resources Board (CARB) to establish an embodied carbon trading system8.
  • Targets: Maintains the target of 40% net reduction in greenhouse gas emissions from building materials by 2035, but removes the interim target of 20% by 2030.
  • Baseline: Provides flexibility for CARB to determine the baseline for emissions reductions based on either 2026 industry average data or the most relevant, up-to-date information available.
  • Read more here.
    

CALGreen 2022 (effective July 1, 2024) 

• • Scope: Applies to large non-residential buildings (over 100,000 sq ft) and school projects (over 50,000 sq ft), encompassing both new construction and adaptive reuse.
  • Goal: To minimize building-related environmental impact by reducing embodied carbon emissions through promoting lower-carbon materials, encouraging structural reuse, and establishing a pathway for industry-wide global warming potential reduction.
  • Mandate: The CALGreen 2022 Intervening Code Adoption Cycle mandates embodied carbon reductions for applicable building projects and enforces agencies to verify compliance through inspections and reports.
  • Targets: Offers three pathways for compliance and highlights specific GWP limits for materials like concrete, steel, glass, and mineral wool insulation
    • Building Reuse: Mandatory 45% reuse of existing structure and enclosure, with voluntary tiers of 75%, or 75% + 30% interior reuse. Combining reuse with new building, limits the addition area to 200% of the existing building area.
    • WB-LCA9: Mandatory 10% reduction in GWP from baseline, with voluntary tiers of 15% and 20%. Path requires a 60 year cradle-to-grave WB-LCA to be conducted according to ISO 14044.
    • Prescriptive Path: Mandatory 175% of IW-EPD10 GWP Limits for specific materials, with voluntary tiers of 150% or within IW-EPD GWP Limits.

Building codes and environmental regulations are constantly evolving. California is likely to continue strengthening its embodied carbon regulations. While CALGreen’s immediate focus in the July 1, 2024, update is on larger non-residential and school projects, AB 2446 clearly sets the stage for increased LCA requirements in residential construction. Therefore, the target for LCA on residential is tied to the deadlines that AB 2446 set forth, and the resulting frameworks that are produced.

Potential Future Targets:

• Expanding Scope: Future regulations could expand the scope of embodied carbon requirements to include smaller buildings and residential projects.
• Lowering Thresholds: Expect to see the GWP limits within the prescriptive path become more strict over time.
• Life Cycle Assessments: There is a strong possibility of increased requirements for whole building life cycle assessments.
• Material Specific Regulations: Further regulations on specific high carbon foot print materials may restrict their use, in favor of bio-based alternatives.