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Buy through us
Explore buy through us
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  4. Inflation Reduction Act
  5. LEC program details
  6. Program updates

Program updates

Last updated: June 25, 2024

Timeline

  • Aug. 16, 2022 — Inflation Reduction Act of 2022 enacted
  • Oct. 4, 2022 — GSA Buy Clean request for information
  • May 16, 2023 — GSA launches LEC pilot
  • Nov. 2023 — GSA concludes pilot
  • Dec. 12, 2023 — GSA publishes fact sheet with findings and lessons learned
  • May 16, 2024 — GSA marks first anniversary of its IRA Buy Clean efforts, noting federal progress on spurring clean construction materials

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 categoryPublished EPDs* before pilot (May 16, 2023)Published EPDs* after pilot (May 16, 2024)
Asphalt9033,615
Concrete (ready-mix, cement, and concrete masonry units)96,853111,070
Glass (flat glass)1927
Steel (rebar, hollow structural steel, hot-rolled sections, plate, and cold-formed galvanized)173184

*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. 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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Last updated: May 1, 2025
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    • Heavy machinery
    • Airplanes
    • Vessels
    • Vehicles
  • Real property for which GSA is responsible. It can be either federally owned or leased from a public or private property owner.

  • An SBA program that gives preferential consideration for certain government contracts to business that meet the following eligibility requirements:

    • Be a small business
    • Be at least 51 percent owned and controlled by U.S. citizens, a Community Development Corporation, an agricultural cooperative, a Native Hawaiian organization, or an Indian tribe
    • Have its principal office located in a HUBZone
    • Have at least 35 percent of its employees live in a HUBZone

    See Title 13 Part 126 Subpart B of the Code of Federal Regulations for more information.

  • A type of contract when the quantity of supplies or services, above a specified minimum, the government will require is not known. IDIQs help streamline the contract process and speed service delivery.

  • A fee paid by businesses who are awarded contracts under Multiple Award Schedule to cover GSA’s cost of operating the program. The fee is a fixed percentage of reported sales under MAS contracts that contractors pay within 30 calendar days following the completion of each quarter.

  • A law that provides $3.375 billion for us to:

    • Invest in federal buildings with low-carbon materials and sustainable technologies, making them more efficient, saving taxpayer dollars and creating opportunities for small businesses
    • Leverage emerging clean technologies to achieve greater carbon reductions and catalyze American innovation
    • Help boost the competitiveness of American manufacturers developing sustainable materials

    This includes $2.15 billion for low embodied carbon materials in construction projects, $975 million to support emerging and sustainable technologies, and $250 million for measures to convert more buildings into High Performance Green Buildings.

  • An investment in our nation’s infrastructure and competitiveness. The law provides funding for LPOE modernization projects that will create new good-paying jobs, bolster safety and security, and make our economy more resilient to supply chain challenges.

  • A written agreement entered into between two federal agencies, or major organizational units within an agency, which specifies the goods to be furnished or tasks to be accomplished by one agency (the servicing agency) in support of the other (the requesting agency).

  • A facility, also known as a border station, that provides controlled entry into or departure from the United States for persons or materials. It houses the U.S. Customs and Border Protection and other federal inspection agencies responsible for the enforcement of federal laws related to entering into or departing from the U.S.

  • An employee who is responsible for preparing, negotiating, awarding and monitoring compliance of lease agreements.

  • Criteria used to select the technically acceptable proposal with the lowest evaluated price. Solicitations must specify that award will be made on the basis of the lowest evaluated price of proposals meeting or exceeding the acceptability standards for non-cost factors.

  • The rate of reimbursement for driving a privately owned vehicle when your agency authorizes it. Current rates are at gsa.gov/mileage.

  • Long-term governmentwide contracts with commercial firms providing federal, state, and local government buyers access to more than 11 million commercial products and services at volume discount pricing. Also called Schedules or Federal Supply Schedules.

  • The standard federal agencies use to classify business establishments for the purpose of collecting, analyzing, and publishing statistical data related to the U.S. business economy.

  • A family of six separate governmentwide multiple award, IDIQ contracts for management and advisory, facilities, technical and engineering, logistics, intelligence services, research and development, environmental, and enterprise solutions.

  • A formal, signed agreement between GSA’s Public Buildings Service and a federal agency for a specific space assignment.

  • Services performed under a contract with a federal agency that include:

    • Cemetery maintenance
    • Electrical systems and energy management control systems
    • Elevator inspection and maintenance
    • Energy management and audit services
    • Fire alarm and fire suppression system maintenance
    • Janitorial
    • Landscaping and snow removal
    • Marine vessel maintenance and repair services
    • Painting
    • Pest control
    • Plumbing or pipe fitting
    • Refrigeration or heating, cooling, and air conditioning
    • Smart buildings
  • The per day rates for the lower 48 continental United States, which federal employees are reimbursed for expenses incurred while on official travel. Per diem includes three allowances:

    • A rate for lodging
    • A rate for meals
    • A rate for incidental expenses
  • An identification card that allows credentialed government personal to access facilities, computers, or information systems. May also be referred to as HSPD-12 card, LincPass, Smart Card, or CAC.

  • Furniture and equipment such as appliances, wall hangings, technological devices, and the relocation expenses for such property.

  • Information that can be used to distinguish or trace an individual’s identity, either alone or when combined with other information that is linked or linkable to a specific individual. Get our agency's privacy policies and practices as they apply to our employees, contractors, and clients.

  • You should only drive a privately owned vehicle for official travel after your agency evaluates the use of:

    • A common carrier
    • A government-furnished vehicle
    • A rental car

    When your agency has determined a POV to be the most advantageous method of transportation, you are authorized reimbursement for mileage and some additional allowances (parking, bridge, road and tunnel fees, etc.).

  • Approvals from GSA’s congressional authorizing committees, the U.S. Senate Committee on Environment and Public Works and the U.S. House Committee on Transportation and Infrastructure, for proposed capital and leasing projects that require funding over an annually established threshold.

  • Region 1 (New England): Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont

    Region 2 (Northeast and Caribbean): Northern New Jersey, New York, Puerto Rico, U.S. Virgin Islands

    Region 3 (Mid-Atlantic): Delaware, parts of Maryland, Southern New Jersey, Pennsylvania, parts of Virginia, West Virginia

    Region 4 (Southeast Sunbelt): Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee

    Region 5 (Great Lakes): Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin

    Region 6 (Heartland): Iowa, Kansas, Missouri, Nebraska

    Region 7 (Greater Southwest): Arkansas, Louisiana, New Mexico, Oklahoma, Texas

    Region 8 (Rocky Mountain): Colorado, Montana, North Dakota, South Dakota, Utah, Wyoming

    Region 9 (Pacific Rim): Arizona, California, Hawaii, Nevada

    Region 10 (Northwest Arctic): Alaska, Idaho, Oregon, Washington

    Region 11 (National Capital): Washington, D.C., area including parts of Maryland and Virginia

  • Formal agreements between GSA and a federal agency customer where GSA agrees to provide goods, services, or both, and the federal agency agrees to reimburse GSA’s direct and indirect costs. The customer portal for RWA information is called eRETA at extportal.pbs.gsa.gov.

  • A document used in negotiated procurements to communicate government requirements to prospective contractors (firms holding Multiple Award Schedule contracts) and to solicit proposals (offers) from them.

  • A document used to communicate government requirements, but which do not solicit binding offers. Quotations submitted in response are not offers. The Multiple Award Schedule order is the offer, and then the contractor can do something to show acceptance, like ordering supplies or contacting subcontractors.

  • An SBA program that gives preferential consideration for certain government contracts to businesses that meet the following eligibility requirements:

    • Be a small business
    • Be at least 51% owned and controlled by one or more service-disabled veterans
    • Have one or more service-disabled veterans manage day-to-day operations and also make long-term decisions
    • Eligible veterans must have a service-connected disability
    • Permanently and totally disabled veterans who are unable to manage the daily business operations of their business may still qualify if their spouse or appointed, permanent caregiver is assisting in that management

    See Title 13 Part 128 Subpart B of the Code of Federal Regulations for more information.

  • An SBA designation for businesses that meet size standards set for each NAICS code. Most manufacturing companies with 500 employees or fewer, and most non-manufacturing businesses with average annual receipts under $7.5 million, will qualify as a small business.

    See Title 13 Part 121.201 of the Code of Federal Regulations for more information.

  • To improve and stimulate small business utilization, we award contracts to businesses that are owned and controlled by socially and economically disadvantaged individuals. We have contracting assistance for:

    • 8(a) Business Development contractors
    • Historically underutilized business zone
    • Service-disabled, veteran-owned small businesses
    • Small businesses
    • Small disadvantaged businesses
    • Veteran-owned small businesses
    • Women-owned small businesses
  • A Small Business Administration program that gives preferential consideration for certain government contracts to business that meet the following eligibility requirements:

    • Be a small business
    • The firm must be 51% or more owned and controlled by one or more disadvantaged persons
    • The disadvantaged person or persons must be socially disadvantaged and economically disadvantaged

    See Title 13 Section 124.1001 of the Code of Federal Regulations for more information.

  • The basis for the lease negotiation process, which becomes part of the lease. SFOs include the information necessary to enable prospective offerors to prepare proposals. See SFO minimum requirements.

  • Specific supply and service subcategories within our Multiple Award Schedule. For the Information Technology Category, a SIN might be new equipment or cloud services.

  • An online system at sam.gov, which the U.S. Government uses to consolidate acquisition and award systems for use by contractors wishing to do business with the federal government. Formerly known as FBO.gov, all contracting opportunities valued over $25,000 are posted at sam.gov.

  • When you use a government purchase card, such as the "GSA SmartPay" travel card for business travel, your lodging and rental car costs may be exempt from state sales tax. Individually billed account travel cards are not tax exempt in all states. Search for exemption status, forms and important information.

  • The finishes and fixtures federal agency tenants select that take a space from a shell condition to a finished, usable condition and compliant with all applicable building codes and standards.

  • A statute that applies to all Multiple Award Schedule contracts, unless otherwise stated in the solicitation or contract, which requires contractors to sell to the U.S. Government only products that are manufactured or “substantially transformed” in the U.S. or a TAA-designated country.

  • An option for vendors to report transactional data — information generated when the government purchases goods or services from a vendor — to help us make federal government buying more effective.

    See our TDR page for which SINs are eligible and which line-item data to submit.

  • A unique number required to do business with the federal government.

  • An indicator of how efficiently a federal agency is currently using space, it is traditionally calculated by dividing the usable square feet of the space, by the number of personnel who occupy the space.

  • A Small Business Administration program that gives preferential consideration for certain government contracts to businesses that meet the following eligibility requirements:

    • Be a small business, as defined by the size standard corresponding to any NAICS code listed in the business’s SAM profile
    • Have no less than 51% of the business owned and controlled by one or more veterans
    • For those veterans who are permanently and totally disabled and unable to manage the daily business operations of their business, their business may still qualify if their spouse or appointed, permanent caregiver is assisting in that management

    Get a full list of eligibility requirements.

  • A governmentwide acquisition contract exclusively for service-disabled veteran-owned small businesses to sell IT services such as:

    • Data management
    • Information and communications technology
    • IT operations and maintenance
    • IT security
    • Software development
    • Systems design
    • New and emerging technologies
  • The amount of solid waste, such as trash or garbage, construction and demolition waste, and hazardous waste, that is reused, recycled or composted instead of being put in a landfill or burned.

  • A GSA program designed to promote recycling and reuse of solid waste.

  • A Small Business Administration program that gives preferential consideration for certain government contracts to businesses that meet the following eligibility requirements:

    • Be a small business
    • Be at least 51% owned and controlled by women who are U.S. citizens
    • Have women manage day-to-day operations who also make long-term decisions

    See Title 13 Part 127 Subpart B of the Code of Federal Regulations for more information.