MA S.2967: Clean grid, EPDs, and your next spec
Massachusetts just hardwired clean energy growth into law while pointing procurement toward embodied‑carbon accountability. If you make concrete, steel, glass, asphalt, wood, insulation, or assemblies that use them, S.2967 quietly changes how fast your data will be requested and how often your product is compared on verified GWP. Here’s what actually matters for manufacturers that want to win bids without slowing operations to a crawl.


What the law actually does
Massachusetts enacted S.2967 into Chapter 239 on November 20, 2024. It streamlines clean‑energy siting, authorizes multistate procurements, and directs agencies to lower costs for customers. It also instructs state procurement to measure and reduce embodied carbon using Environmental Product Declarations. (Massachusetts Session Laws, 2024)
The law requires utilities to contract for approximately 5,000 MW of energy storage by July 31, 2030, with interim targets in 2025, 2026, and 2027. That is a big signal for an electrified economy where low‑carbon materials will be compared side by side. (Massachusetts Session Laws, 2024)
EPDs move from “nice to have” to table stakes
S.2967 creates an Embodied Carbon Intergovernmental Coordinating Council and tasks it to recommend maximum GWP processes for common materials and procedures for using EPDs in state contracting. Initial plan due July 31, 2025. Recommendations for setting max GWP processes by January 1, 2026. (Massachusetts Session Laws, 2024)
Translation for manufacturers. Expect more RFPs to ask for product‑specific, third‑party verified EPDs and to prefer or require low‑embodied carbon options. Teams without current declarations get benchmarked with conservative assumptions. That hurts submittals and slows approvals.
Boston accelerates the pull‑through
Starting July 1, 2025, Boston’s Net Zero Carbon zoning requires embodied‑carbon reporting for Large Projects over 50,000 square feet and LCA submission during Article 80 review. Small and Large Projects must report embodied carbon, and most new buildings must be net‑zero operational on day one. (Boston.gov, 2025)
If you supply into Boston, architects will ask for EPDs earlier and more often. A clean, comparable GWP value shortens the back‑and‑forth.
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The grid context matters for factories, too
The Commonwealth’s 2024 climate report highlights a requirement to procure 5,000 MW of storage by 2030 and records a 2,878 MW offshore wind selection in 2024. That combination reduces curtailment risk and helps stabilize electricity for energy‑intensive manufacturing. (MA Climate Report Card, 2024)
MassDOT’s FY26–30 capital plan totals about $18.5 billion. Public jobs of that scale amplify any rule that nudges EPD‑backed materials. (MassDOT, 2025)
What this means for spec wins
Think of S.2967 as switching from dial‑up to fiber for policy. Carbon data will load faster into design models, and products with verified numbers get considered first. You are less likely to be swapped for a rival with a credible EPD when owners chase carbon budgets.
EPDs also de‑risk LEED v5 documentation and municipal submissions. Submittals stop being a scavenger hunt. Reviewers can check, cite, and move on.
Do this quarter
- Prioritize EPDs for the materials named in the law: cement and concrete mixtures, steel, glass, asphalt, and wood. Get plant‑specific where you can. (Massachusetts Session Laws, 2024)
- Pick the right PCR and set your 2024 reference year data pull, then freeze scope so the LCA runs cleanly.
- Publish through a recognized program operator and keep declarations easy to retrieve for estimators and reps.
Watch the rulemaking clock
Deadlines stack up quickly. The embodied‑carbon plan was due July 31, 2025. Processes to set maximum GWP were due January 1, 2026. The Energy Facilities Siting Board and DPU face March 1, 2026 rulemakings that affect grid timelines, which in turn shape project scheduling. If final maximum GWPs are not yet posted publicly, say so in submittal cover notes and provide your product‑specific EPDs to reduce risk for the reviewer. (Massachusetts Session Laws, 2024)
Bottom line for manufacturers
S.2967 links power‑system growth with material transparency. The winners will be the teams that make EPD collection boring and fast, keep LCAs aligned to current PCRs, and arm sales with clear GWP numbers. Get that right and you will definately feel it in spec share long before any cap‑and‑trade headline shows up.
Frequently Asked Questions
What parts of Massachusetts S.2967 directly reference EPDs and embodied carbon?
Chapter 239 establishes an embodied‑carbon council and directs it to develop procedures for using EPDs in state contracting and to recommend processes for setting maximum GWP for common materials like concrete, steel, glass, asphalt, and wood by set dates. (Massachusetts Session Laws, 2024)
Is there a hard requirement today to meet a maximum GWP in Massachusetts?
As of January 21, 2026, the law requires recommendations and a process to set maximum GWPs. Final numeric thresholds for statewide procurement have not been widely posted by the Commonwealth’s sites yet. Use product‑specific EPDs now to avoid conservative default assumptions in bids. (Massachusetts Session Laws, 2024)
How does Boston’s Net Zero Carbon zoning affect product demand?
From July 1, 2025, Large Projects over 50,000 square feet must submit an embodied‑carbon LCA. Small and Large Projects must report embodied carbon, so EPD‑backed products reduce friction in Article 80 review. (Boston.gov, 2025)
Where does the 5,000 MW storage target come from?
S.2967 directs utilities to enter into long‑term contracts totaling approximately 5,000 MW of energy storage by July 31, 2030, with interim procurement milestones in 2025–2027. (Massachusetts Session Laws, 2024)
Do EPDs need to be Type III for Massachusetts work?
Yes. The statute defines EPDs as Type III under ISO 14025 or substantially similar methodologies. (Massachusetts Session Laws, 2024)
