Building Embodied Carbon Requirements into the Local By-Laws

Changes are coming to the Vancouver Building By-law…are you ready?

The local design and construction industry has long-anticipated updates to the local building code from the City of Vancouver – specifically, the way that embodied carbon requirements are addressed. While certainly expected, there is apparent industry apprehension associated with these changes – and with carbon reductions in general – that has only grown over the past few years.

In 2017, the City of Vancouver measured the embodied carbon of a wide cross-section of buildings, ultimately finding the average embodied carbon of these buildings to be 400kgCO2e/m2. Since 2023, the limit on embodied carbon has been set at 800kgCO2e/m2 (which is huge!), and in 2025 (next year!) that limit will become 360kgCO2e/m2.

Broadly speaking, the growing industry apprehension that we are referring to stems from what these new embodied carbon limits could mean for building design, the approval process, and the overall cost of a development. As structural engineers who are passionate about truly sustainable design and construction, we’re excited to see local regulations and embodied carbon policies expanding so quickly. So, while the code changes may still be months away, getting to the heart of the matter sooner rather than later is important to ASPECT…and the industry at large.

The heart of the matter. 

Structures are responsible for about 55% of the total embodied carbon of a building1. More than any other discipline, structural engineers have the ability to improve the efficiency of their designs without impacting building performance. This means we have a significant opportunity to make an impact on the environment.

When it comes to addressing Climate Change head on, there is a hierarchy that can be applied to determine the most effective ways to reduce embodied carbon (see Figure 1.1 below). Still, any time a code or building regulation changes, it can be challenging for building owners, not to mention the architectural community, to stay on top of the far-reaching implications of what the latest changes could mean for their work. Are there new materials on the market to consider in order to adapt to these changes? How and when should a Life Cycle Assessment (LCA) be completed? What could these materials mean for the overall design and construction process? These questions (and many more) have been circulating for quite some time.

In early May, ASPECT Sustainability Lead Caroline Butchart took part in a workshop that was jointly held by the Carbon Leadership Forum and the City of Vancouver. At this Workshop, the City introduced some of the proposed changes to participants, outlining the possible requirements and formally requesting industry feedback. The feedback that the City has received over the past few months has been folded into the upcoming 2025 regulation changes, which are currently open for public comment and were also shared in a webinar with industry professionals last week. Through Caroline’s lens, we’ve compiled a bit of a “roundup” of the information presented so far – taking a closer look at what the upcoming code changes are likely to involve, as well as some guidance on steps that you can take now to be as prepared as possible when these changes come into effect.

 

Figure 1.1: Climate Change “Levels of Intervention”

Chart showing the impact of building decisions through the construction process.

 

Current State: Embodied Carbon Requirements in the Vancouver Building Code Today

Whole building Life Cycle Assessments (LCA) have been required by the City of Vancouver as part of rezoning applications since 2017. In 2023, a specific requirement to report embodied carbon was introduced to the Vancouver Building By-Law, requiring design teams to submit an embodied carbon report with their building permit submissions. With this change, the City of Vancouver became the first jurisdiction in North America to write whole life embodied carbon into their building code.

While making this a requirement was a significant step forward, the limit set for this requirement was initially set as a fairly “easy-to-meet” target, with the intention of allowing the industry time to learn and adapt to the new requirements. Through this 2023 requirement, the limit on embodied carbon was set (and remains) at 800 kgCO2e/m2 – a limit that is quite easy for buildings to obtain with minimal changes to standard processes. This limit is based on data collected from rezoning submissions, which indicate that 400kgCO2e/m2 is “typical” for large (Part 3) buildings in Vancouver. By and large, this change was viewed as a way to acclimate the industry to the practice of reporting data, setting the stage for a more meaningful embodied carbon requirement in the near future. A small (but important) step forward.

Building Anticipation: The new Vancouver requirements.

Updates to the preliminary version of the new Bylaw are expected in March 2025 (official announcement still pending), when new (and more difficult to achieve) reduction targets will come into effect for the City of Vancouver. While still in the approval stage, it is anticipated that this target will include a ten per cent (10%) reduction from the baseline value of 400kgCO2e/m2. As was the case when the 2023 target was introduced, projects that exceed the embodied carbon limit can still meet the requirements by demonstrating a 10% reduction relative to a project-specific baseline.

These targets are not arbitrary, and stem from a detailed review of existing building stock that the City of Vancouver has conducted over the past decade. The City has also consulted published studies2 on the subject, each of which points to 400kgCO2e/m2 as a strong baseline.

The new targets will extend to any developments applying for building permit after March 2025.

Future State: What these changes could mean for your project.

As with any new requirement, questions arise as to whether the expectations are, in fact, reasonable. Over the past few months, and at the two webinar sessions recently held by the City of Vancouver, there have been concerns expressed connected to whether project teams will be able to meet these new requirements. And, if they can meet them, what sort of cost implication is associated? This latter concern stems from the belief / underlying assumption that less carbon will always amount to more cost on a project.

The overall theme of project-based presentations at both the CAGBC Building Lasting Change 2024 Conference and the City of Vancouver hosted webinars, is that a ten per cent (10%) reduction in embodied carbon is easy to achieve at no additional cost to the project. It’s important to remember that there is more than one way to reduce carbon. The most appropriate solution for a given project isn’t necessarily the answer for the next project, and there is more than one way to make an impact. At the end of the day, the most effective approach for minimizing carbon is to look for ways that the materials themselves can be minimized. Less building materials…less embodied carbon.

No time like the present: Work smarter, not more expensively.

When it comes to embodied carbon, ASPECT’s position is that, regardless of the local regulations, we should always design with a view to reduce carbon as much as possible. There are plenty of ways to reduce carbon without driving up costs, and early communication between consultants is the key to success here. The most important thing to keep in mind is that minimizing materials equates to minimizing carbon, and also generates a reduction in cost.

One approach that project teams typically take to minimize carbon is taking a closer look at materiality. Specifying low carbon alternatives, such as low carbon concrete, seems, at face value, to be the easiest solution, given the familiarity (particularly in Canada) with concrete structures. However, these material alternatives often come with a “green premium” price tag, and it’s this price tag that tends to generate the concern that embodied carbon targets will add to project expense.

Mass timber, lightwood frame, and hybrid structures that include mass timber often have lower embodied carbon than those built from steel or concrete. Working with a structural engineer who truly understands the entire supply chain connected to wood and mass timber can keep the building costs reasonable.

 

Figure 1.2: Materiality Considerations

 

Beyond the materials used, there are ways of approaching the structural design that will also lead to carbon reductions. Optimizing the structural grid in a building for the minimum amount of carbon, for example, is an excellent opportunity to reduce emissions. Talking to your structural engineer about early stage grid studies will place carbon front and centre as a metric for success on any project. You can also work with your structural engineer to optimize the building massing overall for carbon reductions.

Similarly, eliminating transfer structures can be one of the most effective ways to make a building more efficient. Transfer slabs are a huge source of carbon emissions, ultimately introducing broader building inefficiencies as well (and requiring extensive coordination in their own right).  The ASPECT team has a bias toward this approach because, logically, reducing material quantities – regardless of what that material actually is – will save costs on the project, and eliminating complex, unnecessary geometry, will save time on the construction site.

Translation: carbon savings do not have to equate to an additional cost for a project. In fact, prioritizing carbon reductions could result in a source of cost reductions.

Think global, act local.

ASPECT is a global company, and Climate Change is a global problem, so naturally we have our eye on regulation changes beyond the province of BC.

In Canada, the National Code is expected to receive updates in 2030 to include mandatory embodied carbon requirements for all of Canada. In the meantime, local municipalities are taking action. Currently, the City of Toronto has an embodied carbon requirement in place in the Toronto Green Standard. Though it is only mandatory for City-owned buildings, any buildings that wish to voluntarily target Tier 2 or 3 of the TGS will need to meet the embodied carbon targets. Further regulation changes are also anticipated for the City of Toronto, particularly surrounding building height regulations for low carbon materials such as mass timber. There is no uniform requirement across the United States, but regulations are regularly evolving at the State level.

Beyond what is regulated, our industry has a responsibility to design and build with intention, particularly given the state of our planet. There are many industry team members who have made the commitment to more significant carbon emissions, even without regulations. Questioning true needs, traditional approaches, and foregone conclusions on every project can lead to critical carbon efficiencies. Regardless of when the new regulations take effect and where, why not apply this way of thinking as soon as possible?

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Interested in talking through what local changes could mean for your project?

Reach out to our Sustainability Lead, Caroline Butchart, to chat further!

 

Footnotes

  1. Building, “Sustainability: Net zero carbon” (June 12, 2020): https://www.building.co.uk/data/sustainability-net-zero-carbon/5106428.article
  2. “Policy Research on Reducing the Embodied Emissions of New Buildings in Vancouver.” Prepared by Zero Solutions, Authored by Zahra Teshnizi (April 2019):  https://vancouver.ca/files/cov/cov-embodied-carbon-policy-review-report.pdf