Reducing Embodied Carbon of Construction Materials through the Inflation Reduction Act
- What is Embodied Carbon?
- Inflation Reduction Act
- Grant Program
- Tools & Resources
- Label Program for Low Embodied Carbon Construction Materials
To further strengthen federal, state and local government efforts to reduce the embodied carbon of construction materials and products through Buy Clean programs, the Inflation Reduction Act passed by the U.S. Congress and signed into law by President Biden in 2022, includes six sections that address embodied carbon of construction materials:
- Sec. 60112 – $250 million to EPA to develop a program to support enhanced standardization, measurement, reporting and verification of embodied carbon of construction materials/products (grants, technical assistance, etc.).
- Sec. 60116 – $100 million to EPA to develop a program to identify and label construction materials/products that have substantially lower embodied carbon, in coordination with the General Services Administration (GSA) and the Department of Transportation Federal Highway Administration (DOT-FHWA).
- Sec. 60503 – $2.15 billion to GSA’s Federal Buildings Fund.
- Sec. 60506 – $2 billion to the DOT-FHWA to reimburse/incentivize eligible recipients for the use of construction materials/ products that have substantially lower embodied carbon (as determined by EPA).
- Sec. 30002 – $837.5 million to Department of Housing and Urban Development (HUD) for direct loans and grants to improve climate resilience of affordable housing, including low-emission building materials/processes.
- Sec. 70006 – Authority for FEMA to provide financial assistance for costs associated with low-carbon materials.
EPA’s Interim Determination on “Substantially Lower Embodied Carbon” Construction Materials
In support of section 60503 and section 60506 above, in December 2022, EPA issued an Interim Determination (pdf) (and cover memo (pdf) from EPA Deputy Administrator, Janet McCabe) to provide the General Services Administration (GSA) and Department of Transportation’s Federal Highway Administration (DOT-FHWA) with actionable guidance on selecting substantially lower embodied carbon materials and products as required by the Inflation Reduction Act. This allowed these agencies to purchase qualifying materials and products with $4.15 billion in Inflation Reduction Act funding.
EPA’s Interim Determination focused on interpreting “substantially lower” embodied carbon for four newly manufactured materials which the Federal Buy Clean Task Force has chosen to prioritize based on high embodied carbon emissions and significant government procurement: cement/concrete, glass, asphalt, and steel. The Interim Determination also identified the use of minimally processed salvaged and reused materials/products and associated services as viable options for meeting Inflation Reduction Act low embodied carbon infrastructure goals. EPA expects that its Interim Determination will evolve as the Agency gains a better understanding of the relevant industry averages of embodied greenhouse gas (GHG) emissions in construction products and develops better methodologies for assessing what materials and products qualify as “substantially lower” embodied carbon.
EPA Initiatives to Address Embodied Carbon of Construction Materials
To carry out its responsibilities under Inflation Reduction Act sections related to embodied carbon, EPA is developing a new set of programs that will provide grants, technical assistance, and tools to help states and Tribal nations, manufacturers, institutional buyers, real estate developers, builders and others to measure, report and substantially lower the levels of embodied carbon and other greenhouse gas emissions associated with the production, use and disposal of construction materials and products. These programs build upon EPA’s work in the ENERGY STAR Industrial Program, the Greenhouse Gas Reporting Program, the Greenhouse Gas Reduction Fund, the Significant New Alternatives Policy, the Sustainable Materials Management Program, and the Environmentally Preferable Purchasing Program, among others. This work includes:
- Environmental Product Declaration assistance, arising from Inflation Reduction Act Section 60112; and
- Labeling Program for Substantially Lower Embodied Carbon Construction Materials, arising from Inflation Reduction Act Section 60116
Sign up for the EPA Environmentally Preferable Purchasing listserv to receive updates on these efforts.
Stakeholder Engagement
In January of 2023, EPA issued a Request for Information (RFI docket #EPA-HQ-OPPT-2022-0924), and more than 200 stakeholders provided feedback on the following Environmental Product Declarations assistance-related questions:
- What construction materials/products should EPA prioritize in implementation of Inflation Reduction Act Sections 60112?
- What data accessibility and improvement approaches should EPA consider?
- What Product Category Rule (PCR) and EPD standardization, measurement, verification, and reporting approaches for use in procurement decision-making should EPA consider?
- What other factors should EPA consider for EPD Assistance programs?
Respondents included representatives from academia, advocacy groups, industry, local/state government, Federal agencies, and others. Recurring themes and areas of agreement included, but are not limited to:
- Broad support for EPA prioritizing cement/concrete, asphalt, steel, glass and salvaged materials, but also for supporting additional material types to “level the playing field” and provide all US-based manufacturers a competitive advantage.
- Recognition that significant investment – in data, standardization, verification, education, etc. – is needed to improve the robustness and usability of Environmental Product Declarations (EPDs) and the associated Lifecycle Assessments (LCAs) and Product Category Rules (PCRs) used to develop them.
- Manufacturers need assistance to create EPDs and for EPDs to be used by purchasers in a fair and equitable way.
- Desire to support life cycle stages beyond the production phase and environmental impacts beyond Global Warming Potential (GWP) will need measurement and reporting assistance if EPDs are to fulfill their potential as a procurement tool.
- Interests in addressing other methods for reducing embodied carbon of construction beyond prioritizing EPDs for procurement of newly manufactured materials/products (e.g., salvage & reuse and Whole Building/Project Life Cycle Assessment, adaptive reuse, dematerialization, alternative material selection).
EPA also received feedback regarding how to shape the carbon labeling program, funded by IRA Section 60116, and will be providing more information on that effort soon. All the stakeholder input received through the RFI has informed, and continues to inform, the development of EPA’s approach across its lower embodied carbon programs.