GSA Drafts Carbon Limits for Select Building Materials

As part of the Federal Buy Clean Initiative, the U.S. government has committed to reducing the greenhouse gas emissions from the manufacture and use of most construction materials. That mandate now has funding through the Inflation Reduction Act (IRA), so the General Services Administration (GSA) has to figure out how to prioritize “low-carbon selections for the most carbon-intensive materials (concrete, steel, glass, and asphalt) for construction and building projects, which account for 98% of what the federal government spends on construction materials.”

The IRA’s edict is to choose products with “substantially lower levels of embodied greenhouse gas emissions,” which the U.S. Environmental Protection Agency (EPA) has defined as the 20% of products with the lowest embodied carbon compared against industry averages. And that is the criterion used in the draft standard, GSA IRA Low Embodied Carbon Material Standards. According to the draft, if the top 20% of materials or products are not available, then the top 40% is allowed. If the top 40% are not available, then “better than the estimated industry average” is the default. Once finalized, the standard would apply to apply to GSA projects using IRA funding.

The embodied carbon information will be taken from environmental product declaration (EPD) data found on the EC3 database using its “Uncertainty-Adjusted GWP.” (EC3, short for “Embodied Carbon in Construction Calculator,” is a free software tool giving digital access to EPDs and allowing users to estimate a building project’s embodied carbon using that data.) This fudge factor takes into account an EPD’s source data­—such as whether it is a product- or industry-specific EPD.

So what does this mean? For concrete, there are nearly 80,000 EPDs included in EC3, and the tools for ready-mix facilities to create EPDs are readily available, so design teams should be able to find concrete that meets performance objectives as well as GSA IRA standards.

It’s important to note that the GSA IRA product-level embodied carbon standards are just one part of its overall carbon-reduction goals. Since 2021, the GSA has required consideration of every federal building project’s overall life-cycle carbon impacts, stating that “new construction and major modernization designs must target a 20% reduction in their buildings’ embodied carbon, compared to a project-specific standard baseline design, as determined by the architect.”

Correction: This article was updated 3/7/23 with a correction requested by GSA. The standards, once finalized, will apply to projects funded with Inflation Reduction Act funding, not all GSA projects.