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As the urgency to understand and resolve climate change intensifies, new embodied carbon incentives are coming for building developers in Massachusetts.
Embodied carbon is the greenhouse gas (GHG) emissions generated during the production, transportation, and installation of building materials—long before a building starts consuming energy.
While energy efficiency improvements in building operations have been a key focus for reducing carbon emissions, the upfront emissions from materials like concrete, steel, glass, and insulation are a significant contributor to the carbon footprint of a building.
The proposed approach for Massachusetts aims to incorporate embodied carbon reduction strategies into the Mass Save® program—an initiative already well-known for its energy efficiency incentives.
The goal is to keep the program design simple and accessible. This approach allows the construction market to adapt while the industry develops material, technology, and process solutions.
Mass Save, a collaborative of Massachusetts’ natural gas, electric utilities, and energy efficiency service providers, aims to reduce carbon emissions through new and innovative ways. One of the most promising Mass Save initiatives incorporates embodied carbon reduction into its existing, highly successful, building incentive programs. This would be a first-of-its-kind approach in the United States, making Massachusetts a leader in tackling this often-overlooked area of carbon emissions.
The proposed incentive strategies for large scale residential and commercial projects follow a hybrid approach with two key components:
This strategy focuses on embodied carbon in the following specific materials: concrete, steel, glazing, insulation, and gypsum. As compared to selected industry baselines, reducing the embodied carbon in these specific materials will be incentivized with a $0.06 per kilogram of Carbon Dioxide Equivalent (kg CO2e) reduction payout. This approach can help to motivate designers and builders when choosing construction materials.
While materials-based incentives are a great first step, the long-term goal is to encourage the adoption of a whole building life cycle assessment (LCA) approach. LCAs provide a comprehensive view of a building’s carbon emissions from cradle to grave, accounting for every stage of a building’s life—from material production through end-of-life disposal.
This path initially focuses on education and training for project teams, with incentives for submitting LCA analyses. Over time, as industry standards and data improve, this approach could become business-as-usual and an easy lift with significant impact. Importantly, the program will be LCA tool-agnostic, allowing flexibility in the software and methodologies used for assessments.
The initiative is slated for inclusion in the 2025-2027 Mass Save 3-Year Plan, with approval expected from the Department of Public Utilities by February 2025.
In the initial roll-out, incentives will be offered for both materials-based reductions and whole building LCA submissions. For materials, as mentioned above, the incentive is projected at $0.06 per kg CO2e reduction, with possible additional incentives for feasibility studies conducted by the design teams for building reuse.
For the whole building LCA, while no direct savings claims will be made initially, project teams will still receive financial incentives for participating in the LCA process.
It is crucial that this program’s methodologies align with broader state and local policies.
Some efforts to align with existing and upcoming policies have been made. For example, program administrators will utilize RESNET Standard 1550, currently in the development process, to target incentives based on percent reductions of embodied carbon from the established baseline.
Efforts to coordinate with Massachusetts’ Division of Capital Asset Management and Maintenance (DCAMM), which is exploring embodied carbon holistically across materials, are also being made. DCAMM is considering adopting a policy similar to the Buy Clean framework, focusing on environmental product declarations (EPDs) and material transparency for materials like concrete, steel, and insulation.
Yet, another significant policy effort to consider is the Department of Energy Resources (DOER) Massachusetts Stretch Code proposal, which aims to add an embodied carbon credit to the HERS compliance pathway in the residential Mass Stretch Codes. This would provide a three-point credit for incorporating embodied carbon reduction strategies, specifically targeting concrete and insulation.
It is important for Mass Save to align with the Mass Stretch Code in terms of how to document and submit analysis for an LCA or global warming potential (GWP) savings for specific materials, so duplicate effort isn’t going into completing the same type of analysis. Industry baselines such as defined in the proposed LEED version 5 or Federal Buy Clean policy should be aligned, so percentage savings can be consistent in the analysis for code compared to incentives.
Some municipalities in Massachusetts are already taking the lead in addressing embodied carbon. For instance, Cambridge requires non-residential developments over 50,000 square feet to submit a whole building LCA.
Similarly, Green Newton requires new multifamily projects over 20,000 square feet that have embodied carbon reduction plans as well as projects over 50,000 square feet to meet the LEED Material and Resources Building Life-Cycle Impact Reduction credit and demonstrate at least a 10% reduction in embodied carbon relative to standard design and construction practices.
By incentivizing material-based reductions and promoting whole building LCAs, Massachusetts is creating a framework that can evolve as industry data and practices advance. This initiative could pave the way for other states and regions to make a lasting impact on the built environment and the fight against climate change.
If you’re involved in these conversations or have partners asking about these programs, now is the time to connect and align your strategies. Together, we can drive forward a future where reducing embodied carbon is a standard practice in building design and construction.
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