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Last updated: May 16, 2024
In 2023, GSA saw the construction industry start to answer the call for lower-carbon options for building materials as the agency implemented a six-month pilot focused on buying clean. This market catalyst continues to pave the way for GSA’s $2 billion investment in low embodied carbon materials for federal facilities nationwide, funded through the Inflation Reduction Act.
The pilot focused on four key carbon-intensive construction materials — asphalt, concrete, glass, and steel — that contribute significant greenhouse gas emissions in their supply chains, from raw materials to transportation to manufacturing. GSA’s LEC projects require Environmental Product Declarations documenting that materials meet thresholds set pursuant to the Environmental Protection Agency’s Interim Determination [PDF]. EPDs standardized, third-party verified documents that can help designers and buyers know a product’s environmental impacts.
The six-month pilot allowed GSA to road-test its requirements and gain insights into the construction materials market, including EPDs, global warming potentials, market availability, project suitability, and cost. GSA continues to gather information, engage industry, and issue contracts on the 11 pilot projects while moving forward with solicitations that apply a lightly-updated version of the LEC requirements released in May to additional Inflation Reduction Act projects in 39 states across the nation. The requirements may be modified as GSA and other agencies (such as the U.S. Department of Transportation’s Federal Highway Administration) collaborate to gather more market information.
Given our nationwide real estate portfolio, expanding the use of LEC construction materials is helping support overall market transformation toward clean materials, in line with the Biden-Harris Administration’s Buy Clean Initiative and federal sustainability goals, including a net-zero-emissions federal building portfolio by 2045 and net zero emissions procurement by 2050.
Eleven projects were highlighted in the pilot.
Starting in May 2023, the U.S. General Services Administration (GSA) piloted interim requirements for the use of low embodied carbon (LEC) construction materials in GSA projects funded by the Inflation Reduction Act of 2022 (IRA). GSA’s first-to-market low embodied carbon material program is helping to advance the Biden-Harris Administration’s Federal Buy Clean Initiative, which leverages the U.S. government’s vast purchasing power to spur demand for construction materials that are made with substantially lower levels of embodied greenhouse gas emissions. The requirements were developed based on industry feedback, and through collaboration with the U.S. Department of Transportation’s Federal Highway Administration (FHWA), the U.S. Environmental Protection Agency (EPA), and the Federal Buy Clean Task Force. The Pilot consisted of 11 new construction projects, land port of entry projects, limited scope modernizations, and paving projects with total estimated low embodied carbon materials valued at more than $300 million. The projects are at different stages of development and execution, and are dispersed across eight states and the District of Columbia. The Pilot evaluated GSA’s Interim IRA Low Embodied Carbon material requirements on a variety of project types utilizing four material categories prioritized by EPA for their embodied carbon reduction opportunities: asphalt, concrete, glass and steel.
The pilot marked a milestone for the Biden-Harris Administration’s clean manufacturing goals, including the Federal Buy Clean Initiative and its efforts to strengthen American leadership in cutting industrial emissions, building resilient supply chains, and supporting good jobs. As part of Buy Clean, GSA’s IRA investments will help catalyze the market for U.S. made low carbon construction materials, promote emerging and sustainable technologies, support American workers, convert GSA facilities to high-performance green buildings, and combat the climate crisis. GSA’s IRA work will accelerate efforts to achieve a net zero emissions federal footprint, catalyze American innovation, and save taxpayers millions in energy costs.
The Pilot sought to gather market research on the availability of low embodied carbon construction materials, to raise awareness of Buy Clean goals, and to build market capacity for providing compliant materials. It helped GSA gain a better understanding of potential supply chain gaps and the relative availability of the material types covered by EPA’s Interim Determination [PDF], which guides GSA and FHWA on how to implement their low carbon IRA appropriations. Extensive collaborative engagement with manufacturers before and throughout the pilot helped GSA gain insights on the suitability of available low embodied carbon construction materials for the performance needs of varied types of projects, along with their environmental product declarations (EPDs), global warming potentials (GWPs), quantities, costs, product category rules, and ENERGY STAR Energy Performance Scores.
By testing GSA’s low embodied carbon requirements on real-world projects across the country, GSA obtained experience acquiring low embodied carbon materials and integrating impactful new material sustainability considerations into the procurement process as an element of construction and modernization projects at land ports of entry, U.S. courthouses, and Federal buildings in varied geographical regions. The pilot also yielded insights about GSA’s IRA project procurement process and contracting needs, such as vendor requests for additional time to develop initial EPDs in certain remote areas.
To establish the requirements, GSA conducted market research and industry outreach activities, including issuing three requests for information, participating in industry days and trade association meetings, and having numerous discussions with construction material industry representatives about the requirements.
Once the pilot was launched, GSA continued its robust industry outreach and engagement strategies to inform the market of its pilot LEC requirements. For example, GSA issued several sources-sought notices to engage industry on the low embodied carbon pilot projects and gain market feedback on the availability of low embodied carbon materials. Additionally, GSA conducted multiple industry days and delivered over a dozen presentations to industry groups, non-governmental organizations, and other agencies on GSA’s IRA low embodied carbon pilot program.
IRA-related industry engagements included:
GSA conducted industry outreach by meeting with or presenting to groups, companies, and organizations including, but not limited to:
Additionally, GSA received feedback from:
GSA’s IRA low embodied carbon projects are at different stages of implementation, and product-specific information is continuing to be gathered across the portfolio of projects. Project-specific market research and material availability reviews were conducted on each of the low embodied carbon pilot projects. To date, GSA has obligated funding for the Powell Courthouse in Virginia, the Powell Courthouse’s Annex, and the Whittaker Courthouse in Missouri, and has received low embodied carbon material proposals for many more IRA LEC projects. More market insights and proposals are being received and considered as the procurements advance. For more information on each LEC pilot project see GSA’s LEC Pilot Report from December 2023. Additional low embodied carbon results will be posted on GSA’s IRA page as procurement actions are finalized.
The construction industry has been responding to GSA’s Pilot program procurements and interim low embodied carbon material requirements. American-made low embodied carbon materials are available, but are subject to geographical constraints for concrete and asphalt for some projects. Continued emphasis by industry needs to be on developing EPDs for LEC materials available in specific local markets where GSA projects are located. GSA has found widely available low embodied carbon glass and steel are available based on several procurement actions in process.
In terms of cost and performance, GSA’s first IRA-funded award 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. Key lessons learned from the pilot include:
Concrete and asphalt are local materials. Neither product is suitable for travel beyond an approximate 90-minute radius of project sites before its usability is compromised. Sourcing these materials is more challenging in some parts of the country including the Southern and Northern borders due to fewer businesses, lower populations and lack of purchasers requesting EPDs until now. Continued market outreach and collaboration with industry is necessary.
GSA’s $2.15 billion for low embodied carbon materials sends an important demand signal, but this amount represents just a small fraction of the total concrete and asphalt purchased in the United States each year. The impact can be increased with the $2 billion in IRA funding that will be distributed by the FHWA for its Low-Carbon Transportation Materials Grants Program, as well as through the buying power of other Federal agencies, states, and local governments implementing Buy Clean programs. GSA is also devoting additional in-house expertise to engage with suppliers and manufacturers to develop EPDs, and is encouraging stakeholders to apply for EPA’s new IRA-funded EPD grant program.
Although only a few companies manufacture flat glass (which can then be fabricated into a wide variety of products) in the United States, glass is readily transportable across the nation, and less localized than concrete and asphalt. The 20% GWP glass that is currently available does not always meet GSA’s performance and/or schedule requirements. Glass that meets GSA’s 40% GWP limit is more widely available and is sometimes the only option for commercial building-like applications. There are also encouraging signs that flat glass manufacturers are responding to market demand by developing lower-carbon glass, new EPDs, or both. GSA continues to seek high-performance glass that meets the top 20% GWP limit. For example:
Yet, more needs to be done to ensure GSA is able to procure the best performing glass. For example, at the Lewis F. Powell Courthouse project in Richmond, VA, it initially appeared that 20% GWP glass would be available. Unfortunately, given the relatively small scale glass purchase (only $5 million), coupled with the project’s accelerated schedules, the identified manufacturer with 20% GWP glass declined to adapt its production line or accelerate the production of glass in the manufacturer’s queue. Therefore, GSA acquired only 40% GWP glass from a vendor that was able to meet the project’s needs. GSA hopes that with longer lead times, and potentially additional EPDs, more suppliers will be able to provide high performance glass that meets the 20% threshold or better.
Market research indicates steel is available within all three GWP limits (Top 20%, top 40%, and Better than Average) but not in all locations in the country. That said, steel is not geographically constrained and can be shipped across the U.S. Although EPDs for materials made in electric arc furnaces (EAF) are widely available, information on the GWP of steel made in integrated mills remains limited. More specific information on the availability and cost of steel meeting the GWP limits will be obtained as procurements continue to advance.
Throughout the pilot and through ongoing engagement with industry and trade associations, GSA has seen an increase in published EPDs for products made in North America, as illustrated in the table below. Over 5,000 additional EPDs have been published in these four material categories during the six months of GSA’s pilot. Notably, flat glass EPDs have almost doubled in number, and asphalt EPDs have nearly tripled. GSA commends this transparency by manufacturers, and looks forward to these trends continuing and even accelerating further in 2024.
| Material category | Published EPDs before pilot (May 9, 2023) | Published EPDs after pilot (Nov. 29, 2023) |
|---|---|---|
| Asphalt | 527 | 1,524 |
| Concrete (ready-mix, cement, and concrete masonry units) | 64,771 | 68,868 |
| Glass (flat glass) | 8 | 15 |
| Steel (rebar, hollow structural steel, hot-rolled sections, plate, and cold-formed galvanized) | 125 | 137 |
EPDs provide third-party verified, standardized documentation of a material’s GWP throughout all relevant stages of its manufacturing. GSA’s approach is based on EPA’s Interim Determination [PDF], which explicitly requires that materials demonstrate compliance with GWP limits through an EPD; no other compliance pathway is mentioned. To help promote robust EPDs, GSA has joined PCR committees. This enables the agency to partner with industry to promote PCRs that result in EPDs that are more comparable, with higher-quality data, and greater reliability.
As GSA works to fully implement its $2.15 billion IRA LEC program, more projects will be seeking qualifying LEC materials. This will underline to industry the importance of obtaining robust EPDs, and will strengthen GSA’s ability to drive market change. GSA’s government-leading investments in low embodied carbon construction materials will be complemented by EPA’s “Reducing Embodied Greenhouse Gas Emissions for Construction Materials and Products” program which will issue $100M of EPD-support grants in 2024. Additionally, FHWA’s $2B IRA appropriation (also for low carbon concrete, asphalt, steel and glass) and a dozen other Federal agencies prioritizing LEC materials through Buy Clean help build this momentum and will further spur the market. Furthermore, the thirteen states in the Federal-State Buy Clean Partnership have committed to prioritize efforts that support the procurement of lower-carbon infrastructure materials in state-funded projects, and to collaborate with the Federal government and one another to send a harmonized demand signal to the marketplace. These coordinated efforts will advance America’s industrial capacity to supply the goods and materials of the future while growing good jobs for American workers.
All materials and products procured for GSA projects must comply with all applicable federal laws. GSA IRA low embodied carbon materials requirements build on the continued application of existing laws such as the Buy American Act of 1933 (updated via the Build America, Buy American Act, which was enacted as part of the Infrastructure Investment and Jobs Act of 2021 [PDF] ), and the Trade Agreements Act of 1979 [PDF]. For GSA’s $2.15B appropriation for low embodied carbon materials (IRA section 60503-funded procurements [PDF] ), existing trade, procurement, and domestic content-related laws will be applied first, before applying GSA’s IRA low embodied carbon material requirements.
For example, the glass for the Lewis F. Powell U.S. Courthouse and Annex in Richmond, VA will be manufactured by Vitro Architectural Glass in Carlisle, PA, using sand that is sourced locally in Northern Virginia in accordance with the Buy American and Trade Agreements Acts. The glass will achieve top 40% GWP.
As part of the Federal Buy Clean Initiative in support of the Buy Clean Task Force, the Buy Clean Technical Advisory Group (TAG) meets bi-weekly. The Buy Clean TAG is led by the White House Council on Environmental Quality and Climate Policy Office, and includes representatives from the Departments of Defense, Energy, Health and Human Services, Interior, State and Transportation, as well as representatives from EPA, GSA and Veterans Affairs. Agencies’ Buy Clean initiatives range from advisory interests to technical support to fully-funded procurement or grant programs. Each meeting provides an opportunity for representatives to share the latest updates from their agency to deliver on the Biden-Harris Administration’s Federal Buy Clean Initiative. This promotes cross-agency dialogue that expedites research and sharing of pre-decisional information for feedback from federal agency peers to promote a whole-of-government approach. For example, following the early-2023 public comment period for GSA’s discussion draft of low embodied carbon material requirements, and GSA updates to the Buy Clean TAG, FEMA arranged agency-to-agency conversations with GSA about data resources, training opportunities, and methodologies for setting up a Buy Clean program. There have also been mutually-beneficial information exchanges between GSA, the Department of Defense, and various offices within the Department of Energy. Last but certainly not least, GSA is also monitoring FHWA’s outreach to industry organizations to identify data for determining whether materials qualify as substantially lower embodied carbon under the EPA Interim Determination. Details of the FHWA Low-Carbon Transportation Materials Program are expected in Winter 2023-2024.
EPA is also a key Buy Clean TAG participant, and has IRA funding for a low carbon material labeling program in addition to EPD grants. To leverage the implementation experience from GSA’s first-to-market low embodied carbon material program, GSA shares LEC product and material data and other documentation with EPA. EPA’s intent is to understand greenhouse gas metrics, cost implications, procurement lessons, and other key data points associated with GSA’s implementation of the EPA Interim Determination required by IRA Section 60503. These findings can help inform future EPA efforts to support industry, capitalize on strengths, and address challenges.
GSA low embodied carbon material requirements remain largely unchanged since the pilot commenced in May 2023. The GWP limits remain the same because market research suggests there have not been dramatic shifts in the GWP of products, nor new industry-wide EPDs, in these four material categories over the past six months. Also, consistency in these initial stages helps manufacturers make investments to enable their products to qualify for GSA’s IRA funding.
The most substantial change in the requirements clarifies the definition of glass material assemblies. Standardizing on the Insulating Glass Unit (IGU) will yield consistency in applying the “80/20” assembly rule from EPA’s 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 now, and increasing the number of project solicitations, GSA is further signaling to the market the breadth and significance of its IRA program and the broader Buy Clean initiative. This will allow GSA to 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. By moving forward, GSA will also stay on track to obligate the funds by the legislatively mandated date of September 30, 2026.
Blog post: GSA pilot spurring market for clean construction materials
GSA IRA low embodied carbon material requirements for asphalt, concrete, glass and steel
Low embodied carbon material requirements FAQs
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