AASHTO Comments on Low Carbon Construction Material Rules

The American Association of State Highway and Transportation Officials recently noted that while supportive of efforts by the Environmental Protection Agency to harmonize Product Category Rules (PCRs) and Environmental Product Declarations (EPDs) for “low embodied carbon” construction materials, several issues remain – especially with materials made outside of the United States.

[Above image by WVDOT]

“One concern is the potential lack of repeatability,” AASHTO said in a comment letter to the EPA. “It is important to ensure PCR development is stringent enough to allow for repeatable results from two independent verifiers given the same scenario for a material/product from a given facility. Standardizing the PCR format will help verifiers.”

Photo by the WVDOT

AASHTO added that there is also “little detail” available on the evaluation of data quality methodology at this time, which is a large part of harmonization and transparency – and that is a course of concern for state departments of transportation.  

“The states would like to know potential impacts of a federal label program to states that have already developed or are developing EPD policies based on state law,” AASHTO noted in its letter. “For example, how will construction materials or products from outside the U.S. be addressed? How will PCRs account for that?”

The organization also wants to ensure that the EPA works in tandem with industry groups – such as the National Asphalt Pavement Association, National Ready Mix Concrete Association, and others – as it develops new construction material criteria.

“That is critical if the current PCRs being used by asphalt or concrete industry do not meet the new criteria,” AASHTO stressed. “The states want a seamless transition into new PCRs and proper cut off dates and transition time for existing EPDs and developments of new ones.”  

Related articles