A handful of states that are gathering EPDs also require construction products to meet certain emissions thresholds, which are known as global warming potential limits.
In 2022, California’s Buy Clean policy began requiring that four categories — structural steel, concrete reinforcing steel, flat glass, and insulation — used in public works projects meet GWP limits equal to or below the industry average. The Buy Clean Colorado Act similarly calls for setting industry-average thresholds for three types of steel, as well as asphalt, concrete, glass, and wood used in new state projects from January 2024 on. Next year, Colorado’s Office of the State Architect will review those limits and report to the Legislature on the program’s progress.
New York, for its part, set GWP standards in 2023 for concrete mixes used in all state building and transportation projects, making it the first state to do so. The Buy Clean Concrete guidelines, which began as voluntary, became mandatory last month. The current threshold is equivalent to 150% of the emissions for average concrete mixes in the eastern U.S. The idea is to create a policy that’s initially attainable not just for major manufacturers but also “mom-and-pop concrete plants” in rural parts of the state “for whom this is all fairly new,” said Mariane Jang, a senior policy advisor on the resiliency and sustainability team in New York state’s Office of General Services.
However, starting in 2027, the limits will progressively lower to reflect ongoing efforts to slash emissions from cement and concrete production. In the meantime, “the aim is to do more capacity-building and to engage even those smaller companies to prepare them for the upcoming changes,” Jang said.
Pressing on without a key partner
The ability to gather accurate data from many disparate suppliers is essential to achieving the ultimate goal of Buy Clean: slashing embodied carbon from construction materials.
That work will potentially get harder if the Trump administration succeeds in its attempts to claw back congressionally mandated climate and energy spending.
Among the funding stuck in political purgatory is a nearly $160 million grant program by the Environmental Protection Agency to help dozens of businesses develop “high-quality” EPDs for 14 material categories.
The National Asphalt Pavement Association was selected last year to receive $10 million of that funding, which hasn’t yet made it out the door, according to Richard Willis, who manages the organization’s team that works on engineering and sustainability issues. The industry association has developed widely used software that helps asphalt-mix producers develop and publish EPDs for individual plants and mixtures. But using the tool costs companies around $3,000 to $6,000 per plant.
Willis said the EPA funding would be used to reduce costs and other barriers for asphalt-mix producers while helping fill in the “data gaps” from the businesses that supply additives. The contents of asphalt pavement — made from aggregate and a liquid petroleum-based binder — can vary widely depending on the local climate and the types of ingredients available nearby.
“Asphalt is about as local of a material as it gets,” Willis said. That makes it tricky to create robust EPDs using general industry information or to develop plans for curbing emissions at a given plant.
A $1.2 billion program from the Federal Highway Administration is similarly ensnared in Trump’s funding freeze. In November, the FHWA selected transportation agencies in 37 states; Washington, D.C.; and Puerto Rico to receive grants to help them study, track, and ultimately purchase cleaner materials for roads and highways.
New York was tapped to receive $31.9 million, though because the funding wasn’t legally obligated before Trump took office, it’s unclear if the state will ever actually get it, said Bruce Barkevich, who is vice president of the New York Construction Materials Association, a trade group representing producers of asphalt, aggregate, and ready-mix concrete in the state.
The timing of the grant would’ve been especially helpful for New York manufacturers and suppliers working to develop EPDs. State construction projects that use over 8,000 short tons of asphalt are now required to gather such data; projects of all sizes will have to do the same starting in 2026. New York’s policy, Executive Order 22, also requires agencies to report the quantities of concrete mixes, five types of steel products, and three types of glass products procured for state projects and provide EPDs when available.
“Even with that [funding uncertainty], we’re not losing the emphasis on sustainable pavements and low-carbon materials, because we’re in New York state — we have laws on the books,” Barkevich said. He added that companies and agencies in the state have worked together for years to curb emissions from asphalt production, including by reducing temperatures used in asphalt-mixing plants and incorporating more recycled material.
Emily Rubenstein, the deputy commissioner for resiliency and sustainability in New York state’s Office of General Services, said her team continues to press ahead with the state’s Buy Clean strategy, including by hosting public webinars, meeting with industry, and training staff in various state agencies. The office is also currently analyzing embodied-carbon data from state projects with the goal of identifying future pathways for reducing embodied carbon.
“This work takes a village, and we’ve been thrilled with how both supporting agencies and industries have been in [backing] the transition,” she said, adding that she’s also glad the U.S. Climate Alliance has picked up the mantle of organizing states.
In New York and other Buy Clean states, program leaders said they’re still meeting quarterly through the climate alliance and trading notes to learn from each other’s experiences. Such collaboration is especially pertinent now that the biggest player in the game — the federal government — is stepping back, said Ted Fertik, vice president for manufacturing and industrial policy at the BlueGreen Alliance, a coalition of labor unions and environmental groups.
“There’s a broad recognition that, in most cases, one state’s procurement is probably not sufficient to drive large-scale shifts in production processes,” Fertik said. “So there will need to be more intentional efforts around harmonizing [state efforts] to drive decarbonization.”