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A New Era for Carbon Policy in California

Sustainable building design and scope 3 reporting requirements expected to change the landscape of emissions accountability.

From the United Nations down to local governments, climate action is necessary and underway. Among the highest-emitting sectors needing reform to hit greenhouse gas emission targets are transportation, agriculture, and the often-undervalued construction industry.

Demolition, new construction, remodeling, and even adaptive reuse take a significant carbon toll. In California, 40 percent of emissions state-wide are attributed to construction. Fortunately, sustainable construction in the West has a leg up. With certifications such as Leadership in Energy and Environmental Design (LEED) spearheading the sustainability movement, along with progressive state politics, regulations addressing sustainability concerns in the built environment have been historically bleeding edge.

Last month, the California Building Standards Commission passed a regulation set to take effect in July 2024, developed by the CALGreen Carbon Reduction Collaborative, which would require large commercial buildings to reduce their embodied carbon.

What is Embodied Carbon?

Embodied carbon can be thought of as carbon implicit to the building itself rather than emissions stemming from building operations, which is managed by a separate regulation. In other words, they are emissions from building materials, including the manufacturing of these materials, their transportation, installation, maintenance, and disposal.

Who is Affected by the Policy?

Commercial buildings over 100,000 square feet and school projects larger than 50,000 square feet are subject to embodied carbon regulations in California. This includes projects both in new construction and remodeling.

How Does This Affect My Organization?

This regulation predominantly affects architects and design professionals as they are responsible for developing building plans. For those groups, the policy provides three options for achieving compliance, which are:

  • Reusing at least 45 percent of an existing structure
  • Utilizing building materials that comply with emission specifications
  • Conducting a building-wide lifecycle assessment to measure compliance

How Can This Policy Support My Organization’s Climate Action Plans?

While embodied carbon is not often thought of as a part of greenhouse gas accounting, it may be considered a scope 3 source of emissions for building owners. Scope 3 reporting has become a hot topic of discussion recently in the state, as Senate Bill 253 passed the legislature and is set to be signed by Governor Gavin Newsom. The regulation will require all businesses with over $1 billion in annual revenue and which operate in California to disclose all three scopes of greenhouse gas emissions. As this transpires, it will be important to quantify the carbon impact of building materials for the development of climate action plans and strategies to reduce emissions.

Utilizing sustainable building materials can also impact relevant variables, such as facility energy usage via changes in thermal insulation. If your organization is looking into constructing a new facility or remodeling a property in California, this policy may spark conversation on sustainable design aspects.

To learn more about your organization’s carbon footprint or developing a climate action plan, reach out to our Sustainability Solutions team at

APTIM. In Pursuit of Better.