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New California Building Code Rule is Likely First Of Many Addressing Embodied Carbon

An amendment to the California building code going into effect July 1 will require owners of new buildings 100K SF or larger to comply with a set of rules aimed at reducing embodied carbon.


This initial change comes with a low bar for compliance, but developers and architects should expect more stringent regulations down the road as the building code is revised.

"My guess is California did this because they want to get us starting to look at carbon and being accountable, ultimately, for the embodied carbon that our buildings are producing," Lowney Architecture Chief Operating Officer Anthony Cataldo said. "When the building code is updated a year and a half down the road, they’ll start to turn up the heat."

The state's building code is amended every three years and is amended at the halfway point between new versions. 

The new rule will affect new commercial buildings, not including multifamily. Any project receiving a building permit on or after July 1 will be subject to the new regulations. 

Requesters will have to submit proof of compliance with one of three options for addressing the embodied carbon in the building. The options include reusing 45% of an existing building to make the new structure, completing a whole-building assessment that shows the new building will be under a required threshold for carbon emissions or documenting the products that will go into the completed building and showing they met or exceeded certain benchmarks for emissions. 

Embodied carbon includes emissions generated during a building's construction and demolition, and is often considered along with other indirect emissions under the name Scope 3. Scope 3 emissions make up 90% of the average real estate firm's greenhouse gas output, a 2023 Bisnow investigation found

The Securities and Exchange Commission considered a plan to require reporting major companies to disclose these types of emissions but dropped it earlier this year. 

California has passed legislation that would require some companies to report these emissions, but implementation will have to be funded and survive litigation

Cataldo said the July 1 code amendment is "minimal enough" that it will likely be an easy and quick issue to address, even for those who are surprised by it. The analysis is very close to the LEED analysis for embodied carbon, Cataldo said, so if a consultant is needed to complete the paperwork, it will likely be easy to find one that can do it. 

Cataldo sees this summer's amendment as a baby step along a path that will become increasingly more challenging as the state works to meet net-zero goals for buildings. 

He anticipates seeing a rush to file permits before July 1 so that those larger commercial buildings will be grandfathered in under the old code and get to sidestep the new requirements, minimal though they may be. 

Though the push for greater attention to carbon emissions is certainly coming from the state government, Cataldo says there is also interest in more environmental responsibility from many end-users, Cataldo says.

"They're trying to be socially responsible companies," he said.