AGC Shares Feedback as EPA Initiates Construction Materials Program

The U.S. Environmental Protection Agency (EPA) is working on new programs to standardize the use of environmental product declarations (EPDs) and develop a low-carbon emission construction materials program as specified by the Inflation Reduction Act (IRA). EPDs provide data on the environmental attributes of a product and are a tool to support “buy clean” programs that mandate the use of low-carbon materials. Buy clean programs are new and untested. On May 1, AGC provided written feedback to EPA that urges a measured approach to reduce any negative impacts on the supply chain and encourages innovation. AGC highlighted the need to control the risks that arise when deviating from traditional roles and materials on projects, as well as, the importance of incentivizing markets while safeguarding materials’ performance.

The White House has encouraged agencies to focus their buy clean efforts initially on asphalt, concrete/cement, steel, and glass; and EPA’s interim program targets these materials. AGC encouraged EPA to avoid expanding the program to cover too many materials, which would quickly become unworkable. AGC also raised the need for a waiver process when materials are not readily available and the establishment of pilot programs to provide a safe proving ground for materials.

EPA also requested feedback on how to approach minimally processed, salvaged and reused materials. The construction industry has a long history of recycling, and EPA data show construction industry recycling rates at 76 percent. AGC expressed concern that a reliance on EPDs may leave recycled materials at a disadvantage even though these materials may reduce emissions.

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