Advancing Code Reform to Address Embodied Carbon

New York has positioned itself as a national leader in climate policy, with the Climate Leadership and Community Protection Act (CLCPA) setting ambitious targets to reduce greenhouse gas emissions. Over the past decade, New York has made meaningful progress in reducing operational carbon in buildings through energy efficiency, electrification, and performance standards. Yet a critical and largely unregulated source of emissions remains: embodied carbon. 

In 2025, the American Institute of Architects New York (AIANY) Chapter released a Building Decarbonization Action Plan detailing actionable policies to address the full life cycle of carbon emissions in the built environment. Building on the Action Plan, AIANY has been a leader in advocating for policies to regulate embodied carbon emissions, bolster low-carbon construction material manufacturing, and support innovation.

Embodied carbon refers to the GHG emissions generated by the manufacturing, transportation, installation, maintenance, and disposal of construction materials used in buildings, roads, and other infrastructure. Globally, embodied carbon accounts for approximately 17 percent of total GHG emissions. Addressing these emissions is essential to meeting near-term climate targets.  

The urgency is further underscored by equity considerations. Embodied carbon is intrinsically linked to climate justice and public health, as frontline communities often bear the brunt of industrial pollution from material production and the impacts of climate change “first and worst.” Reducing embodied carbon can therefore deliver both environmental and social benefits. 

AIANY’s Building Decarbonization Action Plan outlined a comprehensive strategy for reducing emissions across the building lifecycle. Central to this framework is the integration of whole-life carbon thinking into policy, design, and construction practices. To do this, AIANY is advocating for reforms to New York State Building Code. A8456/S7998 would establish a long-term strategy to reduce embodied carbon by setting a flexible compliance framework requiring a 15 percent reduction in embodied carbon for certain building projects. Project teams can meet this requirement through one of three pathways: 

1. Adaptive Reuse: Maintain at least 45 percent of the existing building structure and envelope and do not add more than 50 percent to the total area. 

1. Low-Carbon Construction Materials: Use materials that meet material carbon caps, demonstrating a reduction in A1-A3 life-cycle stages (extraction, transportation, and manufacturing) for covered products. 

1. Whole-Building Life Cycle Assessment: Demonstrate compliance by conducting a whole building life cycle assessment (WBLCA) and compare to a functionally equivalent reference building.

This strategy emphasizes performance-based, design-forward solutions that allow flexibility while driving measurable outcomes. The proposed 15 percent reduction threshold is both pragmatic and conservative. Research from organizations such as Rocky Mountain Institute and Skanska indicates that embodied carbon reduction of 19–46 percent are achievable with less than a 1 percent cost premium. Material substitution strategies alone—such as the use of lower-carbon concrete—have demonstrated reductions of up to 46 percent without requiring major redesign.  

In practice, leading projects are already exceeding these benchmarks. Large-scale commercial developments, including data centers, are reporting reductions in the range of 40–64 percent using currently available technologies and procurement strategies. These findings suggest that the proposed code changes are well within current industry capabilities and can be implemented without significant cost burdens. 

Beyond emissions reductions, embodied carbon policy is a catalyst for broader transformation in the construction sector. Circular economy strategies—such as material reuse, deconstruction, and recycling—can reduce embodied carbon by up to 75 percent globally. At the project scale, practices like incorporating recycled concrete can cut emissions by approximately 40 percent. 

These approaches also unlock economic opportunities. Investing in low-carbon materials and construction methods supports local manufacturing, strengthens supply chains, and creates high-quality jobs in green building trades. As federal support for climate initiatives dwindles, state and local leadership becomes even more valuable to sustaining momentum and fostering innovation. 

AIANY’s continued advocacy reflects a clear understanding: achieving New York’s climate goals requires a comprehensive, whole-life approach to building emissions. Code reform is a powerful tool to accelerate this transition, providing consistency, accountability, and scale.

By advancing policies that address embodied carbon, New York can once again lead—demonstrating how the built environment can contribute to a more sustainable, equitable, and resilient future. As architects, designers, and policymakers collaborate to implement these changes, the opportunity is not only to reduce emissions, but to fundamentally reshape how we design, construct, and value our buildings.