New York State Working Group Releases Embodied Carbon Recommendations 

The New York State Embodied Carbon action plan charts a course for a construction sector that is not only sustainable but also economically vibrant and socially beneficial with high-impact, near-term policy recommendations for reducing embodied carbon across the built environment. Developed over three months by a newly initiated New York State Embodied Carbon Working Group, these recommendations reflect the collective expertise of diverse industry leaders and subject-matter experts. The insights and proposals are designed to inform policymakers on practical pathways to achieving New York’s ambitious climate goals—fostering innovation, creating green jobs, and building healthier, more resilient communities. 

The action plan and near-term recommendations lay out a vision for embodied carbon reduction in New York State (NYS). This vision includes a built environment where an increasing number of buildings in New York will be deconstructed rather than demolished. All large building projects, both public and private, will take action to reduce embodied emissions. A circular economy with supporting businesses and workforce will enable contractors to use recycled materials on projects. Embodied carbon will be disclosed at the time of build, and the new standards for clean design and construction will be achieved through a series of coordinated measures designed to drive economic growth and market innovation. 

This vision aligns directly with New York’s Climate Leadership and Community Protection Act (CLCPA) goals, including achieving an 85 percent reduction in greenhouse gas emissions below 1990 levels by 2050. To achieve this vision, the working group offers a strategic blueprint designed to address both the technical and economic challenges of our current linear model by incentivizing innovation and building a transparent, data-driven system. 

The near-term recommendations document lays out clear actions that policymakers can take to reduce emissions in New York State. These actions are additional to work that’s already underway in New York State, with many helping to establish a framework and foundation for future reductions. 

Incentives and financial support

• A sales tax exemption for low-carbon construction materials
• Demonstration projects for best-in-class low-carbon projects
• Extended producer responsibility for construction materials

Codes and standards

• Statewide emissions reductions target and implementation support, modeled on California’s AB 2446, which calls for a 40 percent reduction in emissions from building materials by 2035
• Road maps with interim targets to operationalize statewide reductions
• An expert advisory group for integration of embodied emissions reductions into codes

Material reuse and circularity

• Deconstruction and reuse pilot programs
• Material disclosures and reuse requirements
• Regional reuse networks and workforce development partnerships 

The public sector in New York State has taken noteworthy steps in recent years to better understand the emissions associated with its building materials.  

• New York’s 2021 Low Embodied Carbon Concrete Leadership Act (LECCLA) instructs state entities to procure low-carbon concrete for their projects, requiring the use of environmental product declarations to demonstrate emissions reductions. 

• NYS Executive Order 22, issued in 2021, directs state agencies to reduce embodied carbon in common construction materials, calculate project emissions, and report on the emissions of new building projects. 

• NYC Executive Order 23 issued in 2021 directs New York City agencies to develop embodied carbon reduction plans for their public projects, submit environmental product declarations, conduct life cycle assessment, and use low-emissions construction equipment.
• New York’s 2022 Climate Action Council Scoping Plan includes a robust set of recommendations to reduce embodied carbon.
• The New York State Office of General Services Executive Order 22 Embodied Carbon Guidance, released in 2023, outlines the commonly used, high-intensity construction materials for reporting and disclosure, includes sample contract language, and lays out a reporting schedule for state projects.
• The New York City Economic Development Corporation published its 2024 circularity guidelines and is undertaking the deconstruction SPARC project.
• New York State made a commitment in 2024 to reduce emissions from concrete used on infrastructure projects by 30 percent by 2028.
• The city of Auburn has passed a 2024 deconstruction ordinance with a model ordinance developed by the CR0WD group, and several other cities are considering adoption.
• New York State Homes and Community Renewal 2025 Sustainability Guidelines for all new construction projects provides guidance for conducting a lifecycle assessment and for Environmental Product Declaration (EPD) submittal. It also prohibits use of high GWP insulation. 

This set of recommendations is part of a larger effort underway in New York State. NRDC has partnered with the American Institute of Architects New York chapter to support a set of bills for consideration in New York State. Three bills, currently before the New York State Legislature, advance key components that are still needed to tackle embodied carbon. 

• Financial tools for embodied carbon, A06566 (Robert Carroll)/S07648 (Brian Kavanagh)
• Sales tax exemption: This bill includes a sales tax exemption for covered low-carbon materials that meet a minimum 15 percent global warming potential threshold, verified through a Type III EPD. Qualifying materials include concrete, steel, engineered wood products, insulation, and various finishes (carpet, ceiling tiles, etc.).
• EPD grants program: The bill would establish a pilot program to provide up to $10,000 per plant to concrete manufacturers to develop EPDs for their mixes. EPDs for concrete are now required on most large public sector projects for NYS agencies.
• Codification of current NYS executive orders A08202A (Harvey Epstein)/S8000 (Leroy Comrie)
• This bill codifies many of the requirements in the existing Executive Order 22 and creates an embodied carbon decarbonization program for New York State agencies.
• Three pathways code bills A08456 (Anna Kelles)/S07998 (Brian Kavanaugh)
• This bill, based on CalGreen in California, would enable a long-term strategy for reducing embodied carbon in all public and private building projects by setting three compliance pathways for reducing embodied carbon in the New York building code. The three pathways are: reusing an existing building or building material; using low-carbon substitutes for specific materials like concrete; or demonstrating reductions at the project level via a whole building life cycle assessment.  

NRDC is excited to support these efforts and to see such a proliferation of embodied carbon projects and commitments in the New York region.  

"This document lays out clear, concrete actions New York policymakers can take to reduce the carbon emissions from building materials. It reflects the contributions of a diverse set of individuals across the policy and practitioner spectrum in New York, many having worked on the most significant embodied carbon efforts in the state to date.” —Mikhail Haramati, state industrial lead, Climate & Energy, at NRDC (Natural Resources Defense Council

“The vision, recommendations, and comprehensive strategies outlined in the document establish an important foundation—a foundation that not only supports critical short-term action but also future efforts for progressive and meaningful reductions in embodied carbon.” —Shawn Wood, U.S. Green Building Council

“AIANY is proud to be a member of the working group demonstrating the power of joining forces with a collection of innovators, advocates, and experts to identify data-driven strategies to reach New York’s climate goals. The near-term recommendations detailed in this action plan build on the strategic leadership demonstrated by New York State to turbocharge our transition to a circular economy and comprehensively address the whole life cycle of carbon.” —Jesse Lazar, executive director, American Institute of Architects New York Chapter

“The transition from a linear to a circular construction economy in New York State will bring economic, environmental, and social benefits to all New Yorkers. It is a transition that requires a collaborative, multipronged approach from numerous stakeholders. The New York State Embodied Carbon Working Group's focus on a roadmap to reduce embodied carbon through a circular construction economy is an important part of this state-wide effort.” —Gretchen Worth, Susan Christopherson Center for Community Planning 

“Prioritizing deconstruction, material reuse, and design for disassembly enables New York State to reduce embodied carbon while driving job creation, strengthening regional reuse networks, and delivering community benefits. This NYS Embodied Carbon Working Group’s roadmap charts a path for New York to lead nationally in establishing the infrastructure, workforce, and policies that will make circular construction a reality.” —Felix Heisel, assistant professor of Architecture, Cornell University; director, Circular Construction Lab