This summer, I’ve spent several days with groups of state DOT engineers, university faculty, trade association staff and Federal Highway Administration (FHWA) and Environmental Protection Administration (EPA) program managers, watching as they presented and discussed ideas for quantifying and reducing the climate impacts associated with the construction and use of transportation infrastructure. Possibly the most interesting takeaway from these meetings is that the state DOTs are fully committed.
Often, when Congress sets a policy regarding federally funded highways and then the FHWA promulgates an implementing regulation, the states find ways to work around the requirements and continue doing what they’ve always done. That’s not the case here.
State DOTs are investing heavily in the staff and tools needed to evaluate the lifecycle emissions of climate warming gases associated with alternative materials and construction practices. They are using the available data to evaluate climate impacts as they also look at cost and long-term performance when selecting design approaches and construction materials. States report they are ready to do more but are often frustrated by a lack of data. Environmental product declarations (EPDs) for many products are either not available or lack data on impacts during the use and disposal phases of a product’s life cycle.
Notably, state DOTs are finding it easier to recruit engineers when sustainability is built into the job descriptions posted for open positions. The new engineering workforce is one that is oriented toward building a more sustainable infrastructure.
Several university civil engineering departments are taking leadership roles in collaborative efforts to reduce the emission of climate warming gases associated with construction and infrastructure. Some schools have multi-million-dollar grants from the EPA and FHWA for research on methods to evaluate the climate impact of highway construction materials and technologies. These academic departments are graduating engineers every year looking for career opportunities that include sustainability as a major objective in the work they will do for DOTs and highway design and construction companies.
The leading trade associations, including groups representing the asphalt, concrete and steel industries, have developed product category rules (PCRs) for construction products supplied by their association members, and they are rolling out web-based generators that will facilitate the preparation of EPDs for these products. Encouragingly, ACMA is also focused on the development of PCRs and later this year will launch the LCA + EPD Generator for composite products.
That brings us to the EPA and FHWA. These agencies are implementing the sustainability programs described in the Bipartisan Infrastructure Law (BIL) and the Inflation Reduction Act (IRA), as well as executive orders issued by the Biden White House.
The IRA, for example, directs the EPA to use EPDs to identify construction products associated with emission of climate warming gases at levels less than the industry average of similar products. The EPA has released a draft approach for implementing its Label Program for Low Embodied Carbon Construction Materials, which will establish certain standards for the robust EPDs needed for valid comparison of the climate impacts associated with competing products.
And among other programs, the FHWA is advancing the use of EPDs to evaluate construction materials through its Every Day Counts initiative, a state-based model that aims to identify and rapidly deploy proven, yet underutilized innovations.
Lessons for the Composites Industry
It’s increasingly clear that composites manufacturers will need EPDs for their products to be considered for construction and infrastructure projects. (ACMA wants every manufacturer of composite construction products to have at least one EPD by the end of 2026.)
And composites manufacturers will need to be “sustainability literate” to participate in discussions with designers, builders and owners of buildings, highways and other infrastructure. An EPD is not intended to convey and explain all the information that may be relevant to the sustainability of a construction project; it’s an instrument for providing information in a standardized format that will facilitate discussions between infrastructure builders and product suppliers.
Since our industry is just starting to develop programs in this area, we have an important opportunity to use PCRs and other guidance documents to ensure the EPDs for industry products are based on high-quality data and use transparent assessment methods. These data quality and transparency objectives will be built into the PCRs we develop and ACMA’s LCA + EPD Generator that will be launched later this year.
John Schweitzer is vice president of EH&S and sustainability at ACMA. Email comments to jschweitzer@acmanet.org.
ACMA will launch its LCA + EPD Generator later this year to provide robust EPDs for composite products at about one-third the typical cost to a company of preparing an EPD on its own.
