This page contains a list of frequently asked questions that accompany the EO22 Embodied Carbon Guidance. This page is updated periodically as new questions are added.
Note: Federal government agencies program and policies may have changed since the publishing of this FAQ (March 2026).
What are some good resources to learn more about reducing embodied carbon in construction projects?
Carbon Leadership Forum Resource Library has many helpful resources from benchmark reports, to model embodied carbon specifications, and an Embodied Carbon Training Video Series, which is great for beginners.
RMI (formerly called the Rocky Mountain Institute) has many thought pieces relating to broader trends to reduce embodied carbon in industry, and reports on the state of low carbon materials across the country, and Canada. This includes a “Embodied Carbon 101: Building Materials” primer on reducing embodied carbon in building materials.
AIA-CLF released a 3-part Embodied Carbon Toolkit for Architects (Nov 2023): Part 1: Introduction to Embodied Carbon, Part 2: Measuring Embodied Carbon, Part 3: Strategies to reduce embodied carbon.
Building Transparency’s EC3 website is a good first stop in looking for a material EPD.
What is the definition of “Transportation Projects”?
“Transportation Projects” refers to projects that are administered, owned, or funded by the Department of Transportation (DOT), Central New York Regional Transportation Authority (CENTRO), Capital District Transportation Authority (CDTA), Niagara Frontier Transportation Authority (NFTA), Rochester Genessee Regional Transportation Authority (RTS), and Thruway Authority (THRUWAY), and may include: state roads, road bridges, road tunnels, and roadway service centers. Transportation projects, under this guidance, do not include infrastructure associated with railways, waterways, and air travel.
Why is only ready-mix concrete included, and not precast, or other kinds of concrete products?
Only ready-mix concrete is covered by this Guidance due to the availability of environmental product declarations (EPDs) at the time of developing the guidance. As EPDs become more prevalent, the covered materials list may be subject to change.
Why doesn’t the guidance include more materials?
The guidance is focusing in this round on the most common and highest intensity construction materials, for which environmental product declaration data typically exists.
The General Services Administration (GSA), the agency that contracts for major design and construction projects on behalf of the federal government, has been a leader in identifying construction materials which are carbon intensive, and setting standards to reduce lifecycle emissions associated with those materials. As of March 2026, the GSA maintains low embodied carbon material performance requirements for concrete, cement, concrete masonry units, asphalt, steel and glass they procure on their projects.
Why is there a dollar and quantity limit for Embodied Carbon reporting? Why aren’t all contracts required to report on embodied carbon emissions for all materials?
The focus of this first round of guidance was to collect data on the majority of the emissions associated with state construction materials. Most of these occur via large state contracts. Recipients of large contracts are well resourced firms, so reporting on embodied carbon of the materials used will not be a significant burden relative to the overall size of the project. New York State also contracts with a large number of small, local businesses for repair, maintenance, and minor construction jobs. We purposely excluded these smaller firms to avoid creating an administrative hurdle to conducting work for New York State agencies.
Reporting requirements may be more comprehensive in some agencies. For example, some agencies (referred to as Affected Entities in Executive Order 22) do not enforce a minimum quantity limit for reporting, or a minimum project dollar threshold. Please refer to the agency you are working with if you have any questions.
Why doesn’t the guidance contain Global Warming Potential (GWP) thresholds for the selected materials?
New York State has set GWP limits for the concrete procured on its projects as of Sept 2023. The NYS Buy Clean Concrete Guidelines can be found here.
For other materials, best practice for developing Buy Clean material GWP requirements is to begin with a data collection effort. The federal General Services Administration (GSA) has been directed to develop a program that includes thresholds for high intensity materials. To do so, the agency has adopted threshold limits based on the best performing 20% or 40% of products in a material category. This is an interim approach, with a moving target for materials GWP thresholds.
Why doesn’t it include reporting and disclosure for emissions associated with transportation to the job site (A4) and emissions during installation (A5)?
This first round of guidance is seeking to collect information that can be easily reported using existing mechanisms. Therefore, our focus is on data collection through Environmental Product Declarations (EPDs). At this point, EPDs only collect A1-A3, or Cradle to Gate, emissions data. Future guidance will address A4 and A5 emissions.
When will the next round of guidance come out?
The intent of this round of guidance is to start foundational data collection to develop an understanding of the scope of the problem in New York State. Please follow this website to learn about the next round of guidance which will include new requirements on whole project life cycle analysis calculations.
Is there a requirement that agencies adopt a performance specification for concrete?
Performance-based specifications are a catch all terms for specifications that detail the performance characteristics of a concrete mix (for example, compressive strength, durability, slump, freeze-thaw, etc.) as opposed to prescribing a concrete mix recipe. Most Affected Entities and Industry are moving towards performance specifications for concrete.
This working group convened a special Concrete Technical Subcommittee that supported agencies in developing performance-based specifications that allow for lower carbon concrete, ahead of the lower GWP limits per the NYS Buy Clean Concrete Guidelines (to take effect in 2027).
There is not a mandate that agencies adopt performance-based specs for concrete, but the specifications currently in use should be updated because they likely:
- Do not allow for greater quantities of supplementary cementitious materials (SCMs).
- Do not include the global warming potential (GWP) limits set in the Buy Clean Concrete Guidelines and GreenNY Lower Carbon Concrete Specification. These limits are mandatory starting 1/1/2025.
- Do not require EPD reporting per the Buy Clean Concrete Guidelines and Lower Carbon Concrete Specification. EPD reporting is mandatory for applicable projects starting in 2025.
- Do not reference other testing standards or codes that support low carbon concrete use.
Updating existing prescription-based specifications to performance-based specifications will allow for greater adaptability in the future to implement the Buy Clean Concrete Guidelines or Lower Carbon Concrete Specification and any future updates to those documents.
When will the GWP limits be updated in the Buy Clean Concrete Guidelines and Lower Carbon Concrete Specification?
The GWP limits will be updated in the Buy Clean Concrete Guidelines and Lower Carbon Concrete Specification in 2027. The reduced GWP limits will be set based on data collected from the mandatory E.O.#22 EPD reporting.