The Inflation Reduction Act (IRA) of 2022 has been ramping up funding for several programs to decarbonize building materials and transform the market. The biggest news in February 2024 was the Environmental Protection Agency (EPA) announcement of developing a low embodied carbon (LEC) certification and labeling scheme for construction materials, including flat glass. Will this have the same implications for the trajectory of flat glass embodied carbon (EC) as the EPA’s Energy Star and National Fenestration Rating Council’s (NFRC’s) energy performance labeling programs have had for residential window energy performance? If so, it could be highly transformational for the glass and glazing industry.
Before diving into the details of this new program to see how the different initiatives fit together, it is important to review where we already know the impact of IRA funding on construction material decarbonization. Are these programs a recipe for market transformation?
Low-Carbon Material Procurement and Specification:
The IRA provided $3.375 billion for the General Service Administration (GSA)–the largest U.S. landlord–to invest in reducing carbon emissions from federal building construction and U.S. construction materials manufacturing, aligned with the Federal Buy Clean Initiative. The funds are designed to allow GSA to use its buying power and additional investments to catalyze U.S. construction material manufacturers to generate lower carbon emissions from their production and raw material extraction processes. GSA’s LEC procurement program was therefore created, which, when fully implemented, is expected to lower global warming potential (GWP) from GSA’s construction projects by 22,000 and 40,000 metric tons of CO2e.
To buy “low-carbon” materials, GSA had to define what low-carbon means. In conjunction with the EPA last year, the GSA set initial EC limits (interim determinations) on several building materials, including flat glass. Refer to my blog in February 2023 for more details on the background and issues with the precision of the data. As a follow-up to that blog, the GSA quickly realized that setting limits for processed glass, such as insulating glass, was currently too challenging because of the lack of robust data from multiple sources and the sheer number of different processing options. As a result, GSA decided to focus its LEC specification on flat glass alone. Since the EC of flat glass is typically around 75% of the total EC of an IGU, it seemed like an appropriate first place to focus.
California was the leader in this field, setting a precedent with its “Buy Clean California Act,” which defined EC limits for flat glass, concrete and insulation used in state-owned buildings in 2022.
The GSA rules for its LEC program state, where feasible, that environmental product declarations (EPDs) must be manufacturer and supply-chain-specific and that facility-specific data is desired. If facility-specific data is not available, a non-facility-specific EPD will be accepted. The Energy Star energy performance score for the manufacturing float glass plant is also required.
In September 2023, GSA announced its first LEC material procurement for glass. It awarded a $5.3 million option to buy windows made with low-carbon glass, including a $16.5 million renovation of the U.S. Courthouse in Richmond, Virginia. Vitro Architectural Glass supplied the glass for this project. Vitro’s flat glass has an EC of 1,350 KgCO2e/ton, according to its EPD, which lands in the top 40% of North American flat glass, per the GSA’s and EPA’s analysis.
In November 2023, GSA announced $2 billion of the IRA funding assigned to more than 150 federal building projects eligible for LEC materials. Once fully implemented, the GSA’s program will need over one million square feet of glass. This is a significant opportunity for those flat glass manufacturers who can demonstrate EC in the 20th or 40th percentile.
Several additional states are actively working on their own “buy clean” initiatives supported through the Buy-Clean Federal State Partnership. Colorado has already enacted such a policy for state buildings, effective Jan. 1, 2024, that impacts glass with an EC limit of 1510 Kg CO2e, about 5% over the industry average. There is a tax incentive to encourage LEC glass use in private buildings. Four other states–Oregon, Minnesota, New York and Maryland–are currently developing limits.
Grant Program for Reducing EC in Construction Materials
In September 2023, the EPA announced a competitive grant program to support manufacturers in creating and verifying EPDs, again funded by the IRA. EPA will award up to 40 grants or cooperative agreements in 2024 to address several barriers to the widespread availability of reliable and verified EPDs for construction materials. The grant program aims to fund projects that:
- Improve the data used for EPDs.
- Improve the robustness of product category rule (PCR) development, including identifying critical data, how it should be collected and reported and the verification that is needed for appropriate EPD credibility;
- Create tools and resources to support development and verification of EPDs;
- Assist manufacturers in the development of EPDs and their verification; and
- Create robust platforms that support availability, reporting and verification of EPDs, including integration into construction design and procurement systems.
The cost of creating an EPD remains a major barrier for many fabricators in the glass industry, especially for small and mid-size companies. This funding could make a big impact–especially the funding for direct assistance to manufacturers and for creating robust tools and resources. The latter would support, for example, the creation of a fenestration EPD builder. Such a tool has been discussed with Building Transparency as a way of generating EPDs for fenestration assemblies more cost-effectively and with data that is more customized to the specific configuration and therefore more useful for low-carbon design decision making. See my October 2023 blog for more details.
Phil Northcott, principal at C-Change, co-founder of Building Transparency, and lead developer of the Embodied Carbon in Construction Calculator (EC3), spoke at the annual Fenestration and Glazing Industry Alliance (FGIA) meeting in February 2024. He noted that funding will be available as part of the IRA to support starting in the next few months to be provided to manufacturers in creating EPDs. This could be a big deal for smaller fabricators. Stay tuned for more information!
Low Carbon Material Certification and Labeling
Now, on to a review of the biggest and most recent announcement by EPA: The development of a low-carbon labeling system for construction materials. EPA is currently soliciting feedback from the industry on the program design.
The program’s initial focus is on high-impact construction materials: steel, asphalt mixtures, concrete mixtures and flat glass–aligned with the categories in the EPA’s interim determination and the Federal Buy Clean initiative. The plan is for the program development to have a phased approach, with a pace based on the current market maturity and data availability for the specific material. The “labeling” will be for GWP only, and the goal is for the data to be sourced from reliable EPDs. The availability of quality data is the biggest challenge. To address this, the EPA plans to invest in improving background data sets and document a process to ensure the data inputs used for LCAs are of sufficient quality. This data quality strategy aligns with the investment being made through the EPA grant initiative.
Ultimately, EPA’s vision is to implement a tiered rating system with an online, public registry of certified construction materials and products. EPA is using its experience with other labeling and certification programs (like Energy Star) to inform this new program.
Implications for the Glass Industry
The Energy Star program for windows has been a tremendous success in driving residential window performance. It has done exactly what above-code performance programs are designed to do: In combination with tax incentives (initiated by the American Recovery and Reinvestment Act), it pulled up the top end of the market, and with it, the bottom end too. The market penetration of Energy Star 6.0 was close to 85% at the time of transition to the higher stringency, Version 7.0 last year. And the performance values for Version 6.0 are now being incorporated into the model codes (bottom end). NFRC’s fenestration certification and labeling program underpinned the Energy Star program by providing verified energy performance data.
A similar trajectory could happen for low-carbon flat glass (and ultimately insulating glass and fenestration assemblies when looking long-term). The new certification and labeling program for LEC materials provides an easily referenceable and credible standard. Just like Energy Star. This makes it much easier for construction project teams to specify and meet their carbon goals. It could also make it easier for incentive programs at the federal, city, state and utility levels to motivate the market to design with LEC targets.
Is the Market Moving Already?
The government’s LEC initiatives are already starting to move the market. Glass manufacturers are creating manufacturer specific EPDs and drive to lower GWP glass. Guardian Glass just published an updated EPD for its unprocessed flat glass, showing a drop of approximately 24% from 1,455 KgCO2e/ton to 1,102 KgCO2e/ton (TRACI 2.1 Method), jumping them well into the top 20% category. According to Alan Kinder, director of the commercial segment at Guardian Glass, this has been achieved by combining many different strategies.
Kate Krezowski, Guardian’s ESG stewardship manager, identified their Stewardship Framework as a driver, encouraging the company “to use fewer resources, minimize waste and improve the environmental performance and effectiveness of our products and processes.”
She also shared that several of its North American plants have undergone cold tank repair (which makes them more efficient) and have enhanced operational efficiencies by implementing operating sensors and monitoring systems.
Much additional leading-edge work in EC reduction in flat glass is concentrated in Europe where the market is driving faster. NSG, for example, has been leading in alternative fuel evaluation (hydrogen and biofuels) and recently announced a carbon capture trial. This work can provide a roadmap for U.S. operations to take steps to lower EC flat glass yet further.
It is exciting to see this kind of market movement and it seems like there is more to come, especially with LEC labeling and certification. Stay tuned!