Low-embodied carbon program details
Last updated: Dec. 12, 2023
The Inflation Reduction Act of 2022, Public Law 117—169, was enacted Aug. 16, 2022. It provided $3.375 billion to our agency to invest in federal buildings to help reduce carbon emissions and catalyze innovation. Section 60503 appropriated $2.15 billion for the procurement of low-embodied carbon construction materials.
This investment furthers the Federal Buy Clean Initiative, and will help catalyze our purchasing power to spur markets for American-made products that have substantially lower levels of embodied greenhouse gas emissions associated with their production, use, and disposal. Additionally, the funding will help us achieve federal sustainability goals including a net zero emissions federal building portfolio by 2045, and net-zero emissions procurement by 2050, while supporting good American manufacturing jobs.
By incorporating low-embodied carbon material into our construction projects, we estimate it will reduce total embodied carbon emissions associated with these projects by at least 22,000 and up to 40,000 metric tons of carbon dioxide equivalent.
We based the low end of this range on our projects using source materials with a global warming potential that is 10% below industry average.
We based the high end of this range on our projects being able to source materials our most stringent top 20% IRA GWP limit, which is based on EPA’s Interim Determination [PDF].
Actual reductions will depend on the final GWP values reflected in product-specific material, or Environmental Product Declarations that we provide for completed projects. Additionally, our LEC projects help send the demand signal for low-embodied construction materials to manufacturers across the country.
Our process for identifying qualifying projects
We selected projects based on a strategy to invest in “core assets” consistent with our portfolio optimization efforts. We identified investment priorities by asset condition and our ability to deliver projects within mandated timeframes. We also identified project candidates based on significant needs for materials including asphalt, concrete, glass, and steel.
We selected projects to deliver work across the country, meet our most pressing repair and construction needs, and align with opportunities to incorporate LEC materials. We are leveraging:
- $561 million in LEC funding on 16 large-scale capital projects. These investments help us continue to reshape our portfolio and invest in core assets.
- $507 million in LEC funding on 99 smaller-scale capital projects. These smaller-scale projects enable us to address minor renovation and alteration needs in the Public Buildings Service portfolio.
- $935 million in LEC funding on 39 Bipartisan Infrastructure Law land port of entry projects, which often need larger amounts of material in the four IRA LEC categories.
In alignment with the Federal Buy Clean Initiative, LEC funding is limited to asphalt, concrete, glass and steel and the necessary expenses to design, construct and install the materials. Therefore, LEC funding requires us to leverage other funding sources for remaining design, construction, management and inspection costs not related to these materials.
Some proposed projects will use IRA funds from Section 60502 and Section 60504. Our Capital Program, Minor Repairs and Alterations Program, and BIL Program will also supplement projects receiving IRA funding.
We continue to report a significant backlog of repairs and renovations that require reinvestment dollars across the portfolio, including $14.9 billion reported in fiscal year 2023. Our Basic Repairs and Alterations funds and full access to the Federal Buildings Fund will be critical to pay for necessary construction expenses and support execution of the LEC program within the required obligation timeframes.
Interim LEC requirements pilot
We announced a pilot of interim requirements to procure substantially LEC construction materials in our projects that the Inflation Reduction Act funds. We established the interim requirements based on the U.S. Environmental Protection Agency’s Interim Determination [PDF]. It set global warming potential limits for key carbon-intensive materials the federal interagency Buy Clean Task Force prioritized: asphalt, concrete, glass, and steel.
These limits reflect feedback from our three requests for information on LEC construction materials, our two industry days, and close interagency collaboration through the Buy Clean Task Force. The pilot will span May to November 2023. It includes 11 projects that required LEC materials. Read the pilot fact sheet [PDF - 125 KB].
We continue to implement the 11 pilot projects, and we made progress sourcing LEC materials on them. We anticipate making additional awards the first half of fiscal year 2024. We will announce additional LEC projects to inform the market of the breadth of our plan, and help position U.S. manufacturers, suppliers, and installers to capitalize on this exciting opportunity.
We will continue to learn from the pilot and use the experience to inform broader project implementation, including any necessary adjustment in our LEC material approach. Planned projects are subject to change depending on availability of other agency funding sources and market responsiveness including availability, pricing, and compliance of LEC materials. We have additional projects that we can consider if we need to adjust the list.
Buy American requirements and IRA LEC requirements
Implementation of IRA LEC materials requirements do not supersede existing laws such as the Buy American Act of 1933 (updated via the Build America, Buy America Act, which was enacted as part of the Infrastructure Investment and Jobs Act, Pub. L. No. 117-58, 135 Stat. 429, 1301-1316 (2021)) [PDF] or the Trade Agreements Act of 1979. All materials and products procured for our projects must comply with all applicable federal laws. For Section 60503-funded procurements, existing trade-related laws will be applied first; then we will apply our LEC material requirements.
LEC acquisition criteria
Our pilot and future project solicitations will favor offers by applying a sustainability source selection evaluation factor in our IRA project solicitations that incorporate asphalt, concrete, glass, and steel with substantially lower levels of embodied carbon.
This approach will call for offeror commitments to furnish IRA-eligible materials with the lowest available global warming potential values for each applicable material type as reported through a Type III EPD, in accordance with the EPA Interim Determination [PDF].
Map of all projects
Find a full list of LEC projects. The list is subject to change based on pricing, market responsiveness, and material availability.
LEC materials national overview
Total cost for LEC project materials
Estimated total LEC funding: $2 billion
Estimated reduction of metric tons of embodied carbon by region
Regional materials breakdown
LEC materials — New England Region projects
Estimated total LEC funding: $191 million
LEC materials — Northeast and Caribbean Region projects
Estimated total LEC funding: $76 million
LEC materials — Mid-Atlantic Region projects
Estimated total LEC funding: $87 million
LEC materials — Southeast Sunbelt Region projects
Estimated total LEC funding: $61 million
LEC materials — Great Lakes Region projects
Estimated total LEC funding: $189 million
LEC materials — Heartland Region projects
Estimated total LEC funding: $222 million
LEC materials — Greater Southwest Region projects
Estimated total LEC funding: $356 million
LEC materials — Rocky Mountain Region projects
Estimated total LEC funding: $147 million
LEC materials — Pacific Rim Region projects
Estimated total LEC funding: $266 million
LEC materials — Northwest Arctic Region projects
Estimated total LEC funding: $148 million
LEC materials — National Capital Region projects
Estimated total LEC funding: $262 million