2024 Updated CALGreen Code: Embodied Carbon Requirements

⚠️ Beginning July 1, 2024, commercial buildings over 100,000 square feet will be required to measure and reduce their embodied carbon.

2022 CALGreen Code Updates presentation on embodied carbon regulations:

  • What’s changed?

  • What is embodied carbon?

  • What is a life cycle assessment?

  • Does my building have to comply with new regulations?

To book GAIA for a client workshop email hello@gaiadevelopment.com


CALGreen: What’s Changed?

We knew this was coming…

In 2019 the California Building Standards Commission (CBSC) published the CALGreen Code (Part 11, Title 24). They hinted at a section for life cycle assessments, commonly referred to as LCAs.

Three years later, the 2022 CALGreen code was released right before July 4th weekend. We joked around the office, "Who's up for some light reading over the holiday?" Trading my beach book for a code book, I expected a new Life Cycle Assessment code to debut. 🤞

Yet, as I flipped through, all I saw were RESERVED placeholders! I figured I’d have to wait another three years before California took decarbonization seriously. 😒

As I read further down the pages, I saw language written out for the future Life Cycle Assessment code; it echoed the LEED v4 Reference Guide, mirroring the Whole Building Life Cycle Impact Reduction credit.

This was great news because GAIA is way ahead of the curve.

Since 2018, we have performed a life cycle assessment on all of our clients’ LEED projects. That's a whopping 300 LCAs completed or currently in process!

We kicked off 2023 by educating our clients on the latest mandatory commercial solar and battery codes from the 2022 CALGreen updates – it was a major change from the previous code, which merely required a solar-ready roof.

GAIA continued to focus on embodied carbon for LEED projects and helping corporations with their decarbonization goals. We expected to wait another three years for the embodied carbon requirements to become a reality but were surprised come Summer.

On August 3, 2023, a unanimous vote by the CBSC brought forth two groundbreaking amendments to the 2022 CALGreen Code Part 11 Title 24:

to limit embodied carbon emissions in the “construction, remodel, or adaptive reuse of commercial buildings larger than 100,000 square feet and school projects over 50,000 square feet.”

The new CAL Green Code offers three (3) pathways to address embodied carbon reduction:

  1. Building reuse

  2. Whole building life cycle analysis (WBLCA)

  3. Prescriptive option for specific products

By 2026, we predict even smaller buildings – those between 50,000 to 100,000 square feet – will fall under these regulations.

With each code revision, more and more structures will have to step up, helping us inch closer to our 2030, 2040, and 2050 climate targets and environmental goals.

California's pioneering stance is more than a regulation. It's a call to participate in responsible climate action. The time for embodied carbon accountability is now. Let’s rise to the challenge and support other cities and states to follow suit.


What is embodied carbon?

Embodied carbon refers to all greenhouse gases emitted during the extraction, production, transportation, and assembly of buildings and the disposal of the building.

Embodied carbon includes all life cycle stages from raw material and construction to maintenance, to end if life, demolition and disposal of building
whole life carbon in buildings is embodied plus operational carbon infographic GAIA
embodied carbon makes up 15% of world carbon emissions infographic GAIA

Of those total emissions, building operations are responsible for approximately 27% annually,

while the embodied carbon of just four building and infrastructure materials (cement, iron, steel, and aluminum) are responsible for an additional 15% annually. (Source: Architecture2030.org)

Almost half of a building's emissions come from its construction. 🤯

Where operational emissions can be whittled down over time through efficiency upgrades and renewables, embodied carbon is “locked in” place once the building goes up, amplifying the urgency of early action.


How do you measure and reduce embodied carbon in construction?

Life cycle assessments, also referred to as LCA, is a tool for measuring the embodied carbon of a building and its environmental impacts.

GAIA conducts a life cycle assessment on every project, helping clients reduce their embodied carbon, gain LEED and GRESB points, and advance their sustainability goals.

Grant Waldron

Director, Sustainability Strategy at GAIA • Linkedin

Grant brings a diverse background to sustainability consulting. With expertise in managing Life Cycle Assessments (LCA), carbon footprint analysis, and Zero NetEnergy and Water projects, he helps clients identify initiatives to scale sustainability across their portfolios. 

https://www.linkedin.com/in/grantlwaldron/
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What is a Life Cycle Assessment?