Denver has begun accepting applications for an incentive program that offers funding and technical support to reduce the “carbon footprint” of building materials in large commercial projects.

Applications for the city’s “Embodied Carbon Pilot Program” are open through Dec. 2.

“Embodied carbon” is the greenhouse gases released from making building materials, shipping them and building construction — all the emissions that happen before anyone flips on the lights or turns up the heat.

The program applies to new construction or major renovations of commercial, multifamily and industrial buildings of 25,000 square feet or larger.

Selected projects must complete a whole-building life-cycle assessment, provide environmental product declarations for key materials and meet “embodied carbon” reduction targets.

Builders who are selected get direct contract payments — the more aggressive the reductions, the higher the potential funding.

The money comes from Denver’s Climate Protection Fund, created in 2020 when voters approved a 0.25% sales-tax increase that now generates about $40 million a year for climate programs.

Denver’s draft guidebook said the goals “are to gather local market data on embodied carbon intensities, understand the costs and challenges associated with reducing embodied carbon in Denver’s building market, and document successful strategies for future policy development.”

The pilot rested on the findings from “Denver’s Building Sector Embodied Carbon Emissions,” a June 2021 report prepared for the city’s Office of Climate Action, Sustainability and Resiliency by Lotus Engineering and Sustainability.

“This pilot is entirely voluntary. It was designed in collaboration with local builders, architects, and sustainability experts to explore opportunities to reduce embodied carbon in buildings,” Emily Gedeon, spokesperson for Denver’s Office of Climate Action, Sustainability & Resiliency, said in a statement to The Denver Gazette.

The 2021 report also laid out a longer-term path. On page 13, it recommended the city eventually shift to “incentives or requirements” for low-carbon materials and fold “embodied carbon” goals into building codes no later than 2030. The current pilot guidebook said its purpose is to “document successful strategies for future policy development.”

The report claimed “embodied carbon” will rise from a “small fraction” today to the “dominant source” of about 27% of total emissions from buildings built in 2030 — and 100% by 2040 — once operational emissions fall close to zero.

“As buildings become more energy-efficient through a transition to electrification and better design, embodied carbon is becoming a larger share of total emissions in new construction,” Gedeon said. “It reflects a real shift in how emissions are distributed across the building lifecycle. If we’re serious about long-term climate goals, this is a piece of the puzzle we need to understand.”

Critics called highlighting the jump from a small fraction to 27% and then 100% a relative “share illusion” created by slashing operational emissions. In other words, as the operational slice of the pie shrinks dramatically, the “embodied” slice — which was always there — suddenly looks much larger in percentage terms.

“That approach is flawed because it ignores statistical realities and lacks any cost benefit considerations,” said environmental attorney Paul Seby. “Clearly, that’s not a rational way to set policy or develop new regulations.”

Gedeon countered that it “isn’t a rhetorical device” and that Denver “is taking a thoughtful, collaborative approach to see what’s possible.”

The 2021 report did not calculate citywide or cumulative savings from low-carbon substitutes. It offered a single residential case study that showed a 59% cut — dropping a typical single-family home from 55.8 metric tons of CO₂ equivalent to 22.8 metric tons, the report said, and called a 40-to-60% reduction “achievable” with current materials but gave no scaled projection for Denver or Colorado.

That 22.8 metric tons avoided per home equals the annual emissions from driving a gasoline passenger car about 58,000 miles, according to U.S. Environmental Protection Agency equivalency calculations.

“This is also an area where industry is already showing strong leadership, and we’re working to support that momentum,” Gedeon said. “More than 100 firms across North America are involved.”

Denver already requires all-electric new homes and low-rise residential buildings. Commercial and multifamily construction must switch to all-electric by 2027. Existing buildings face phased mandates to replace gas furnaces and water heaters with electric models.

Several federal lawsuits challenge the city’s “Energize Denver” operational rules, arguing they violate the Energy Policy and Conservation Act.

No pilot projects have been selected. The city expects to name winners by December 19 and start contracts in January.