C-PACE Embodied Carbon Policy Primer

Embodied carbon, the greenhouse gas emissions associated with building materials and construction, can represent as much as half of a building’s total climate impact. However, most C-PACE programs finance only operational energy measures, leaving a major decarbonization opportunity untapped.

RMI’s C-PACE Embodied Carbon Policy Primer, developed in collaboration with RMI’s C-PACE Embodied Carbon 2025 Cohort, provides ready-to-use, evidence-backed template language and implementation guidance to help C-PACE administrators integrate embodied carbon into C-PACE enabling statutes and program guidelines. The primer is also a valuable resource for commercial real estate developers seeking to incorporate embodied carbon improvements into their next C-PACE project, empowering them to access more inexpensive capital across a greater proportion of their total development costs.

What this primer delivers

• Model statutory and program-guideline language that administrators and policymakers can adapt to their local programs.
• Harmonized pathways that align with existing mandatory embodied carbon code measures and standard C-PACE underwriting processes while responding to local conditions unique to each program and minimizing administrative burdens.
• Data-backed global warming potential (GWP) threshold values for both materials and whole-buildings, with guidance on how to adapt these values to local markets.
• Clear guidance for commercial real estate deal teams on how embodied carbon analyses and documentation can be integrated into C-PACE technical submittals.

Who it’s for

• C-PACE administrators and policymakers updating statutes and program guidelines to make embodied carbon eligible for C-PACE financing.
• Capital providers and developers who want to stay abreast of upcoming opportunities and rules for C-PACE financing of embodied carbon measures.
• Designers, consultants, and software providers developing products and embodied carbon analysis services supporting technical submittal packages for C-PACE applications.

Why it matters

With nearly $10 billion dollars invested, C-PACE is a proven tool for mobilizing private capital for building decarbonization at scale. By expanding program rules to make embodied carbon eligible, administrators can unlock deep decarbonization in commercial real estate while driving even more robust deal volume in C-PACE programs.

RMI is grateful to the attendees of the RMI C-PACE Embodied Carbon Cohort webinar series and the following individuals for their generous feedback and input on this primer: Brad Benke, Rachelle Habchi, Aurora Jensen, Meghan Lewis, Michele Pitale, and Brook Waldman.

Download the primer for model language, implementation pathways, and practical guidance for bringing embodied carbon into your next C-PACE program or project.