Are you prepared for California's most significant regulatory shift in years?

California, already a national leader in green construction, is looking to move beyond operational efficiency to address embodied carbon and corporate carbon impact. Specifically, two landmark regulations, CalGreen Title 24 and SB 253, are driving this change and creating new compliance imperatives for contractors across the state.

Put differently, California doesn’t just want to account for a building’s carbon footprint after it’s constructed. It wants to minimize the emissions associated with manufacturing, transporting, and installing building materials.

CalGreen Title 24 is the first-in-the-nation mandate targeting the carbon footprint of building materials for new large-scale projects. At the same time, SB 253 (The Climate Corporate Data Accountability Act) requires large companies doing business in the state to report their entire carbon footprint.

For general contractors, these rules introduce immediate new challenges in data management, material sourcing, and corporate reporting.

Embodied carbon isn’t a minor issue. According to one estimate by environmental sustainability consultant, Circular Ecology, embodied carbon can equal 20 to 50 percent of a building’s lifetime carbon footprint. California’s new regulatory standards aim to reduce this embodied carbon footprint through mandatory reductions and corporate transparency measures.

The regulations are mandatory for non-residential projects, including commercial building construction projects exceeding 100,000 square feet and school construction projects exceeding 50,000 square feet.

To achieve compliance, builders will need to choose and execute one of three pathways:

• Pathway 1 - Building Reuse: Builders can achieve compliance by reusing at least 45 percent of the existing building’s structure and enclosure.
• Pathway 2 - Whole Building Life-Cycle Assessment: Builders can conduct an assessment demonstrating a 10 percent reduction in Global Warming Potential (GWP) compared to a baseline reference building.
• Pathways 3 - Product GWP Limits: Builders can use specified, high-impact building materials (like structural steel, concrete, rebar, glass, and mineral wool insulation) with GWP below a set limit.

These pathways have a direct impact on corporate reporting.

Notably, builders will need to account for the embodied carbon from concrete, steel, and other materials. California’s regulations mean these are no longer just line items on a material form. They are a significant contributor to a job’s Scope 3 Emissions, the indirect emissions from your entire value chain.

Under SB 253, large general contractors are required to report on these Scope 3 emissions. Therefore, the detailed material tracking performed for CalGreen compliance is no longer just a project-level task. It is the building block for your firm’s corporate climate disclosure, making mastering one regulation essential to succeeding with the other.

SB 253 requires annual reporting of a company's total emissions, including third-party assurance for quality across Scope 1 (direct emissions), Scope 2 (purchased energy), and Scope 3 (value chain, including materials and subcontractors).

Because the regulations share similar priorities, your strategy must be unified. Tackling them with separate, siloed processes promises to create inefficiencies and increase compliance risk.

To achieve this:

• Develop a single source of truth for data: Adopt a data management approach that enables seamless integration of project-level carbon data into corporate-level Scope 3 reports.
• Engage your supply chain holistically: Make providing EPDs and emissions data a standard part of your procurement and vetting process.
• Turn integrated compliance into a competitive edge: General contractors that can account for regulatory standards will mitigate the risk of financial penalties and position themselves as leaders ready to win more work.

The data-intensive nature of these regulations unlocks additional opportunities for green builders.

The latest LEED standards, LEED v.5, similarly require builders to quantify, assess, and reduce embodied carbon. By developing systems now to collect, verify, and report on the carbon footprint of every primary material on your job sites, you are positioning your firm for the next generation of green building standards and outmaneuvering your less forward-looking counterparts.

California continues to step up as a leader in ensuring the built environment contributes to a better environment for everyone. CalGreen Title 24 and SB 253 are the latest expressions of this.

Compliance is contingent upon a unified strategy that treats carbon data as a critical business asset and leverages that information to minimize environmental impact and expedite regulatory compliance.

Implementing compliance measures is one thing. Documenting and proving compliance is a significant challenge in its own right. Recognizing that the future of building in California is carbon-accountable, it’s time to get to work updating plans, refining processes, and perfecting reporting standards.

Wiley Gross is a LEED Accredited Professional (BD+C) and Sustainability Associate at Green Badger. Her construction career includes contributing to project teams’ success in emissions tracking, waste management, and achieving LEED certification. In addition to her work on green building initiatives, Gross has supported ESG reporting and climate disclosure efforts, ensuring alignment between clients, architects, and stakeholders.

Photos courtesy of Green Badger and Leapley Construction