CALGreen: A comprehensive guide to Title 24, Part 11 regulations

3 pathways to compliance

The buildings outlined above must meet one of three compliance pathways for embodied carbon:

Pathway 1: Building reuse

• Mandatory: Reuse 45% of building structure and enclosure.
• Tier 1: Reuse 75% of the structure and enclosure.
• Tier 2: Reuse 75% of structure and enclosure plus 30% of interior non-structural elements.

The global buildings sector continues to grow, with global floor area expected to double by 2060. New buildings contribute to 11% of worldwide GHG, so building reuse is extremely beneficial.

Requirements for building reuse: Maintain a minimum of 45% combined of the existing building's primary structural elements (foundations, columns, beams, walls, floors, lateral elements) and enclosure (roof framing, wall framing, exterior finishes). The calculation does not include window assemblies, insulation, and portions of buildings deemed structurally unsound or hazardous.

Pathway 2: Performance pathway, using a whole building life-cycle assessment (WBLCA)

Conduct a 60-year cradle-to-grave whole building LCA (excluding operating energy), with the following results:

• Mandatory: 10% lower emissions than baseline.
• Tier 1: 15% reduction from baseline.
• Tier 2: 20% reduction from baseline. Show global warming potential (GWP) analysis.

WBLCA evaluates the environmental impacts of a building throughout its entire life-cycle. The steps include:

1. Goal & scope: Define project goals and scope, focusing on a 60-year lifetime and 10% carbon reduction from baseline.
2. Inventory: Quantify materials used in the project by type.
3. Impact assessment: Calculate the environmental impact, focusing on carbon emissions.
4. Results interpretation: Analyze and report findings to ensure compliance with Title 24, Part 11.

How to calculate a baseline for your project

Easily create reference buildings using One Click LCA’s early design tool, Carbon Designer 3D. Create and design options with just building size and type, calculate baseline carbon emissions, and quickly find ways to reduce emissions. 

Pathway 3: Prescriptive pathway, using environmental product declarations (EPDs) for listed materials

To achieve this pathway, you'll need to prove compliance through environmental product declarations (EPDs). EPDs quantify the environmental impact of materials throughout their life-cycle. According to CALGreen, you will need to provide EPDs for the following materials on your building project: steel, glass, mineral wool, concrete, with lower than specified GWP. 

The specified limit is 175% of the industry average GWP for that material. The standard for CALGreen is the same as the Buy Clean California Act, with the addition of ready-mixed concrete.

• Mandatory: 175% of industry average global warming potential limits.
• Tier 1: 150% of industry average global warming potential limits.
• Tier 2: At industry average global warming potential limits.

In the U.S., there are two widely known and commonly used types of EPDs: Industry average and product-specific. Industry average EPDs are developed by organizations (e.g. National Ready Mixed Concrete Association). Data is collected from various constituents and the average data is shared through an EPD. Manufacturers publish product-specific EPDs for their specific products. To fulfill this pathway of CALGreen you will need to provide product-specific EPDs. 

Steps for submitting EPDs:

1. Understand the requirements:
   1. Review the project specifications, particularly Division 1 (General Requirements) and the relevant technical divisions, to understand the EPD requirements.
   2. Identify all materials that require EPDs under the CALGreen prescriptive pathway.
2. Procurement planning:
   1. Develop an action plan for procuring materials that meet Title 24, part 11 requirements.
   2. Engage with suppliers early to ensure they can provide the necessary product-specific EPDs or use One Click LCA’s Materials Compass tool to check available EPDs to create a shortlist of suppliers.
   3. Ensure suppliers understand the need for third-party verified (type 3) EPDs.
3. Collection of EPDs:
   1. Obtain EPDs from suppliers, or use One Click LCA’s global database for all relevant materials. Ensure that these EPDs are product-specific and are third-party verified.
   2. Verify that the EPDs include all required information and cover all mandatory impact categories including the global warming potential (GWP).
4. Documentation preparation:
   1. Organize the EPDs according to the materials they correspond to.
   2. Prepare a summary document that lists all materials requiring EPDs with their respective EPDs and GWP values. This summary should cross-reference the specific sections in the project specifications.
5. EPD submittal package:
   1. Create a comprehensive EPD submittal package. If you use One Click LCA, this EPD package is generated automatically. This package should include:
      1. Cover letter: Briefly explain the purpose of the submission and list the materials included.
      2. Summary document: A detailed list of materials, their respective EPDs, and GWP values.
      3. Individual EPDs: Copies of the actual EPDs, ensuring they are clearly labeled and organized for easy reference.
6. Submission process:
   1. Submit the EPD package as part of the initial material submittal process, adhering to the project's specified format and deadlines.
   2. Ensure the submission is included in the permitting documentation, as CALGreen requires.
7. Review and approval:
   1. Coordinate with the project’s design team and sustainability consultants to review the EPD submission.
   2. Address any feedback or requests for additional information promptly to avoid delays.
8. Progress tracking:
   1. Maintain records of all submitted EPDs and track the approval status.
   2. Ensure that any additional EPDs needed due to material substitutions or changes are submitted and approved.

One Click LCA is an all-inclusive source for CALGreen’s EPD requirements which include:

• A comprehensive global database with all available EPDs
• Product-specific or factory-specific EPDs
• Third-party verified EPDs
• Automatic EPD package creation 

Incentives for achieving higher tiers

Incentives for achieving Tiers 1 and 2 depend on the jurisdiction and specific programs available. Some general incentives include:

• Financial incentives: Rebates, grants, and tax credits
• Expedited permitting: Faster permitting processes
• Reduced fees: Lower building permit fees
• Marketability: Increased market value and appeal
• Operational savings: Lower energy and water costs
• Improved environmental impact: Support for climate goals
• Recognition and certification: Awards and additional green building credentials

One Click LCA's CALGreen tool

One Click LCA's CALGreen-specific tool is designed to help projects comply with Title 24, Part 11 regulations. This tool simplifies compliance by:

• Integrating with Revit and other building information modeling (BIM) and energy modeling tools, via 20+ integrations
• Automating the calculation of embodied carbon reductions
• Making it easy to document and report compliance with CALGreen specific reporting tools

It features the world's largest database of material EPDs and can generate comparative LCA documents to align with CALGreen and LEED requirements.

Summary

Title 24's embodied carbon regulations took effect on July 1, 2024. California is raising the bar for embodied carbon reduction in the building sector. These new standards require developers to follow one of three compliance pathways: Building reuse, whole building life-cycle assessment (WBLCA), or environmental product declarations (EPDs).

One Click LCA's CALGreen tool simplifies the process by integrating with Revit, other BIM, and energy models, automating embodied carbon calculations, and streamlining documentation and reporting. By utilizing this tool, architects and builders can easily meet the new standards, reducing the environmental impact of their construction projects and supporting California's climate goals.