EPA stresses construction material PCR, EPD data integrity

The C-MORE drafts follow on EPA’s August 2024 release of Implementation Approach for Labeling Low Embodied Carbon Construction Materials, Criteria for Product Category Rules to Support the Label Program for Low Embodied Carbon Construction Materials. The program also launched its technical assistance offerings late last year with a step-by-step guide for manufacturers new to developing EPDs and opening access to free EPD advisory services.

The Environmental Protection Agency Office of Pollution Control, tasked with assisting the General Services Administration and Department of Transportation in construction materials procurement tied to Inflation Reduction Act (IRA) programs, closed out 2024 with a call for stakeholder input on draft technical documents framing carbon dioxide emissions accounting and metrics.

Officials bills a new program and banner, Construction Material Opportunities to Reduce Emissions (C-MORE), as a multi-pronged approach to support U.S. producers or manufacturers in lowering operating costs, achieving efficiencies, and accessing new markets while helping federal purchasers or other buyers procure cleaner, more climate-friendly materials and products (see also Carbon Smart, a column premier this month on page 12). EPA staff overseeing C-MORE invite producers, manufacturers and other stakeholders in lower embodied carbon construction materials to review and refine these drafts or preliminary documents involving product category rules (PCR) and environmental product declarations (EPD) underpinning IRA-compliant project funding:

  • C-MORE Draft EPD Criteria for Data Quality and Transparency
  • C-MORE Interim Digital Data Format for EPDs (to support the Draft

EPD Criteria)

  • C-MORE Draft Approach for Developing Product-Level Embodied Greenhouse Gas Emissions Thresholds
  • Draft Product Eligibility Criteria Template for the U.S. EPA Label Program for Low Embodied Construction Materials

The Agency enters 2025 planning to share additional information and tools, along with a webinar schedule, affording a document overview and stakeholders more opportunity to provide input. Formal review and comment opportunities are set for later this year. In addition, staff behind C-MORE will continue to support increasing the quantity and quality of EPDs available in the marketplace through such technical assistance efforts as:

  • PCR Development Toolkit and Training
  • Industry-specific EPD Verifier Training Program
  • EPD Verification Checklists/Templates based on PCRs
  • Webpage Resource One-Stop Shop for Construction Product PCRs, Life Cycle Assessments (LCAs) and EPDs
  • Guide to Using Upstream EPDs as Within Other EPDs
  • PCR Checklist to Assess Alignment with EPA PCR Criteria
  • Update for Industry and Buy Clean Implementers on EPD Data Quality by Material Category

The agency has also weighed in on the status of data quality efforts for EPDs and product-level embodied greenhouse gas emissions thresholds for the subset of construction materials that IRA programs initially address: concrete, asphalt, steel and glass, plus salvaged and reused construction materials. Specific to the first three:

Concrete. GSA has successfully procured low embodied carbon concrete for IRA-funded building or pavement projects. At the Federal Highway Administration’s request, ready mixed concrete interests have published an updated industry benchmarking report. A committee including FHWA, EPA and GSA representatives is currently updating the PCR for Ready Mixed Concrete. EPA is also reviewing a PCR for Precast Concrete for alignment with related agency criteria, while also determining that SmartEPD’s Part B Product Category Rules for Supplementary Cementitious Materials (version 1.0) meets baseline PCR Criteria requirements.

The agency has selected multiple teams across concrete and cement for $40 million-plus in EPD Assistance grants. They will enable efforts to develop EPDs in all 50 states and address multiple concrete products and their ingredients, led by cement, supplementary cementitious materials and aggregates. Given the progression of PCR updates and EPD development, EPA anticipates establishing thresholds for some concrete products by the end of 2025.

Asphalt. GSA has successfully procured and installed low embodied carbon asphalt mixtures for IRA-funded pavement projects. At FHWA’s request, the National Asphalt Paving Association and industry partners recently published an extensive benchmarking effort. Additionally, EPA has determined that NAPA’s Product Category Rules for Asphalt Mixtures (version 2.0) meet the PCR Criteria baseline requirements, thereby enabling the agency to initiate the process of developing asphalt product thresholds early this year.

Steel. EPA has heard the call from stakeholders on the need to create procurement pathways to decarbonize all parts of the steel industry, including integrated blast oxygen or electric arc furnace mills. The agency has determined that the current levels of supply chain transparency and data quality are insufficient for staff to establish a methodology for steel greenhouse gas intensity, i.e. global warming potential thresholds, at present.

Over the next year, EPA will work with stakeholders to help create greater steel supply chain transparency through various data improvement efforts. The agency has selected the University of Massachusetts for a $6.4 million EPD Assistance Grant to improve steelmaking LCI data and build tools to facilitate steel product declaration development in partnership with stakeholders representing all steelmaking methods. In addition, EPA and GSA are committee members on the Smart EPD Steel Construction Products PCR currently being updated.

Upon data quality and transparency improvement, EPA plans to set a methodology for steel GWP thresholds that considers the emissions intensity of iron and scrap inputs. The agency wants to find an approach that is responsive to stakeholders, motivates all suppliers to produce cleaner steel, and improves data quality for the entire industry. EPA expects to revisit its steel threshold methodology in late 2025, including potentially a sliding scale approach or other methodology that meets agency goals and is in line with statutory obligations.

EMISSIONS REDUCTION POWER
Cemex USA has secured $15 million in Environmental Protection Agency Diesel Emissions Reduction Act Program and Texas Emission Reduction Plant grants to support acquisition of four new locomotives and haul trucks for its cement and aggregate operations in New Braunfels and Katy, Texas. “Through these state and federal programs, significant strides toward advancing responsible business practices are more attainable,” says Cemex U.S. President Jaime Muguiro. “Our new lower-emission vehicles play a key role in the development of building materials for roads, schools, hospitals, and more, while also pivotal to our carbon dioxide emissions reduction roadmap.” Decarbonizing cement, aggregate and concrete operations is a fundamental aspect of Cemex’s Future in Action program, which focuses on achieving sustainable excellence through climate action, circularity, and natural resource management, he adds.

The C-MORE drafts follow on EPA’s August 2024 release of Implementation Approach for Labeling Low Embodied Carbon Construction Materials, Criteria for Product Category Rules to Support the Label Program for Low Embodied Carbon Construction Materials. The program also launched its technical assistance offerings late last year with a step-by-step guide for manufacturers new to developing EPDs and opening access to free EPD advisory services.