Last updated: June 25, 2024
Timeline
Update on progress and lessons learned from the first year of our IRA LEC program
The construction industry has been responding to low embodied carbon material requirements and IRA-funded market signals. Since the program launched in May 2023, manufacturers have published about 17,000 additional environmental product declarations in the four material categories, demonstrating that industry is responding to market demand for materials made with lower emissions. GSA has experienced geographical constraints for concrete and asphalt with EPDs for some projects in sparsely-populated parts of the country. Continued emphasis by industry needs to be on developing EPDs for LEC materials available in specific local markets where our projects are located. GSA has found low embodied carbon glass and steel to be widely-available based on several procurement actions in process.
In terms of cost and performance, our first IRA-funded awards procured American-made low carbon glass at a price that was competitive with pricing for conventional glass — while delivering the same performance characteristics, and without any schedule impact. Similarly, an asphalt company in Colorado was able to develop and provide its first EPD (for a pre-IRA GSA LEC paving project) in five weeks, without any cost or schedule impact. GSA appreciates suppliers’ initiative, and plans to share more cost, availability, and performance findings as additional awards are made.
GSA is considering ways to systematically prefer bidders whose submitted EPDs don’t just meet our thresholds, but demonstrate exemplary lower-carbon characteristics, even compared to other bidders who submit EPDs that meet the same threshold. GSA continues engaging with industry, other Federal and state agencies pursuing Buy Clean program, and other experts on best practices and efficient, effective policies.
Below are key lessons learned from the pilot.
Asphalt and concrete
Concrete and asphalt are local materials. Neither product is typically suitable for travel beyond an approximate 90-minute radius of project sites before its usability is compromised. Availability of compliant concrete continues to be a challenge, particularly in remote project areas, however our outreach efforts are yielding results and market responsiveness. In Texas, where GSA needs substantial amounts of low-carbon concrete at major land port of entry modernization and paving projects, we engaged with the Texas Department of Transportation, or TXDOT, and the National Concrete Ready-mix Association, and determined that 8 of 15 conventional concrete mixes used by TXDOT at three of our project locations along the border with Mexico may already comply with one of more of our IRA global warming potential (GWP) limits — if EPDs are published to document the compliance of these mixes for use in our IRA LEC projects.
- Missouri — Our outreach has prompted one local ready-mix provider to pursue an EPD. GSA has two LEC projects planned in the St Louis metro area.
- Hawaii — GSA has two projects planned for the Prince Jonah Kuhio Kalanianaole Federal Building-U.S. Courthouse. A ready-mix manufacturer on the island of Oahu is currently developing an EPD.
- North Dakota — New land port of entry construction project in Dunseith is generating market interest and responsiveness for concrete EPDs.
- Vermont — Market research for land ports of entry across the Vermont-Canadian border is indicating potential interest where heretofore, compliant concrete has not been available.
Glass
Three of the four primary American glass manufacturers are now producing glass meeting GSA’s most-stringent top 20% GWP limits. Our project at the Charles E. Whittaker U.S. Courthouse in Kansas City, MO will benefit from these improvements with approximately 375 tons (100,000 square feet) of glass from two U.S. manufacturers. All of that glass will meet our most-stringent GWP limit, while meeting crucial project needs. Additionally, window fabricators are starting to use top 20% flat glass in their insulated glazing units. These IGUs may be suitable for some GSA window replacement projects. That can provide operational benefits though lower energy consumption while also continuing to expand the markets for low-carbon glass and windows.
Steel
The steel industry has shown substantial improvement, with average GWPs (emissions per unit of product) dropping in most of GSA’s steel product subcategories, including hot-rolled sections and cold-formed galvanized steel. Two major U.S. manufacturers of steel have also published their first-ever EPDs, or are currently in the process of doing so. Both companies have said their action was motivated by our Federal Buy Clean leadership.
Moving forward with LEC program implementation
GSA low embodied carbon material requirements remain largely unchanged since the pilot commenced in May 2023. The GWP limits remain the same because consistency in these initial stages helps manufacturers make investments to enable their products to qualify for our IRA funding, instead of potentially shifting targets when industry efforts are just ramping up. Due to industry feedback about the difficulty of tracking and meeting different GWP limits and policies on projects in different states or for different agencies, GSA is also monitoring complementary work by FHWA and EPA that is expected to yield GWP limits for these same material categories. GSA will evaluate future policies and thresholds for their suitability for the GSA project portfolio, and consider opportunities for interagency harmonization.
One substantial change in our IRA LEC post-pilot requirements clarifies the definition of glass material assemblies. Standardizing on the insulating glass unit, or IGU, will yield consistency in applying the “80/20” assembly rule from the EPA Interim Determination — at least 80% of IGU weight must be compliant flat glass. This clarification is noted both in the FAQs and the low embodied carbon glass requirements.
GSA will continue to monitor the market, engage with stakeholders and industry, and learn from our federal government partners. By fully implementing its IRA low embodied carbon program, we will gather more information in more markets on more projects to help understand where, and for which materials, gaps in availability may persist and how those gaps may be addressed.
Environmental product declaration trends
Since the May 2023 launch of the GSA LEC program, the industry has responded with an additional 17,000 environmental product declarations in our IRA LEC product categories.
Flat glass manufacturers have tripled the number of companies with offerings meeting our most stringent limits. The steel industry has also responded with an increase from 173 to 184 North American EPDs in the steel subcategories used by GSA (rebar, hollow structural sections, hot-rolled sections, cold-formed and galvanized, and structural plate). The number of cold-formed and galvanized steel EPDs has increased by about 60% since a year ago. These additional EPDs also reflect industry movement toward lower EPA Global Warming Potential materials.
According to publicly-accessible data, the increase in North American EPDs over the past year includes: over 14,000 additional EPDs for concrete, a 15% increase; 2,700 new asphalt EPDs, quadrupling the number from a year ago; and additional EPDs in most subcategories of steel, including a 60% increase in the number of EPDs for structural steel plate and two steel manufacturers’ first EPDs ever. GSA commends this transparency by manufacturers, and looks forward to these trends continuing and even accelerating further in the years ahead.
| Material category | Published EPDs* before pilot (May 16, 2023) | Published EPDs* after pilot (May 16, 2024) |
|---|
| Asphalt | 903 | 3,615 |
| Concrete (ready-mix, cement, and concrete masonry units) | 96,853 | 111,070 |
| Glass (flat glass) | 19 | 27 |
| Steel (rebar, hollow structural steel, hot-rolled sections, plate, and cold-formed galvanized) | 173 | 184 |
*Total numbers of North American EPDs in GSA’s material categories, regardless of product category rule, as reported from a free, publicly-available EPD database.
Industry engagement
IRA-related industry engagements included:
- February 2, 2023 — Pre-pilot IRA Industry Exchange to collect input and promote public awareness
- February 21, 2023 — Pre-pilot IRA Industry Exchange to collect input, highlight project plans, and promote public awareness
- May 2, 2023 — Joint Engineer Training Conference — San Antonio, TX
- May 16, 2023 — Pacific Coast Collaborative — Portland, OR
- May 20, 2023 — Institute of Industrial and Systems Engineers Conference & Expo — New Orleans, LA
- July 11, 2023 — American Council for an Energy Efficient Economy Low Embodied Carbon Roundtable — Detroit, MI
- August 2, 2023 — GSA Greater Southwest Region Land Port of Entry low embodied carbon pilot paving project Industry Day
- August 8, 2023 — GSA Great Lakes Region Industry Networking Event — Chicago, IL
- August 15, 2023 — Sustainable Purchasing Leadership Council Summit — Atlanta, GA
- September 8, 2023 - National Ready Mixed Concrete Association - Washington, DC
- September 28, 2023 — Greenbuild International Conference and Expo — Washington, DC
- October 18, 2023 — Society of American Military Engineers Fall Conference — Washington, DC
- October 18, 2023 — Texas Aggregates and Concrete Association — Round Rock, TX
- November 8, 2023 — Native American Industry Day — Washington, DC
- November 13, 2023 — International Code Council Forum on Sustainable Building Materials — Washington, DC
- November 14, 2023 — Polyisocyanurate Insulation Manufacturers Association, Washington, DC
- January 30, 2024 — GSA Mid-Atlantic Region LEC Industry Day — Virtual
- March 12, 2024 — GSA Heartland Region Industry Day — Virtual
- March 21, 2024 — GSA National Industry Exchange — Virtual
- March 25-28, 2024 — 2024 National Energy Exchange Conference — Pittsburgh, PA
- March 25, 2024 — American Wood Council — Washington, DC
- April 18, 2024 — NGO/Government Roundtable on Embodied Carbon — Virtual
- April 24, 2024 — Sustainable Pavements Technical Working Group — Baton Rouge, LA and virtual
- May 14, 2024 — American Iron and Steel Institute — Washington, DC
GSA conducted industry outreach by meeting with or presenting to groups, companies, and organizations including, but not limited to:
- American Iron and Steel Institute
- American Institute of Steel Construction
- National Asphalt Paving Association
- National Glass Association
- National Ready Mixed Concrete Association
- Polyiso Insulation Manufacturers Association
- Portland Cement Association
- Steel Manufacturers Association
- Texas Aggregates and Concrete Association
- United Steelworkers
- Several concrete, cement, and glass manufacturers/fabricators
Additionally, GSA received feedback from:
- Auburn University/ National Center for Asphalt Technology
- BlueGreen Alliance
- Building Transparency
- California Department of General Services
- ClimateWorks Foundation
- Colorado Department of Transportation and Colorado Office of the State Architect
- New Buildings Institute
- Texas Department of Transportation
- Third Way
- U.S. Climate Alliance
- U.S. Department of Agriculture
- U.S. Department of Energy
- U.S. Department of Defense
- U.S. Department of Transportation
- U.S. Environmental Protection Agency
- White House Council on Environmental Quality
Projects
For more information on each LEC pilot project see our LEC Pilot Report from December 2023 [PDF - 4 MB]. Additional low embodied carbon results will be posted in the IRA section as procurement actions are finalized. For additional background on the LEC Pilot Program, please visit the archived fact sheet.
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