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GSA Pilot Program for Low Embodied Carbon Standard 

[May 2023] The United States General Services Administration (GSA) announced a six-month pilot program applying interim Inflation Reduction Act Low Embodied Carbon (LEC) Material Requirements for eleven GSA construction projects.  

GSA’s interim requirements set global warming potential limits for asphalt, concrete, glass and steel. NGA provided public comments to GSA on the draft LEC Standard in February. Note that following the public comment period, GSA revised the global warming potential (GWP) limits to exclude processed glass and insulating glass units from its initial IRA Low Embodied Carbon Material Requirements. The requirements now only include limits for Flat Glass.  

Highlights of GSA interim requirements for glass

• Global warming potential limits for flat glass (EPD-Reported GWPs, in kilograms of carbon dioxide equivalent per metric ton) are:  
  • Top 20% limit: 1331  
  • Top 40% limit: 1370  
  • Better than average limit: 1401 
• Construction product assemblies (such as window assemblies) qualify for IRA funding if at least 80% of the assembly’s total cost or total weight comprises materials that meet the requirements. 
• Facility-specific EPDs are required “where feasible.” 
• The Energy Star Energy Performance Score for the supplying flat/float glass plant is required.  
• Three of GSA’s eleven pilot construction projects include glass. 

Access NGA’s resources on Sustainability, including the Flat Glass PCR and Industry Average Flat Glass EPD.

NGA Public Comments to DOE on Inflation Reduction Act 

[April 2023] NGA provided input on the U.S. Department of Energy request for information regarding Section 50131 of the Inflation Reduction Act: Technical Assistance for Latest and Zero Building Energy Code Adoption. Read NGA’s Public Comments.  

In summary:  

• NGA supports energy code development through a consensus-based process with broad and balanced interests.  
• NGA supports continued and enhanced funding to the national labs for the development of software tools such as EnergyPlus, COMcheck, REScheck, COMFEN, WINDOW, and THERM that help demonstrate improved energy code compliance and assessment of the impact of glazing on building performance. 
• NGA supports groups such as the Partnership for Advanced Windows Solutions (PAWS) to develop supporting data and narratives to convey the benefits of retrofit solutions. 
• NGA encourages an increased focus on building performance standards to include criteria for building envelopes in addition to shorter term fixes such as lighting and mechanical systems. All systems need to be analyzed together to maximize cost effectiveness and longevity of improvements to the existing building stock.   

Processed Glass PCR

[March 2023] NGA submitted public comments to UL on the Processed Glass Product Category Rule (PCR). The UL Review Panel will decide if any comments received require review by a committee. If so, the redline draft will be posted again for public comment. The current version can be downloaded from UL. The scope of the PCR includes processed, coated and fabricated glass such as heat-treated, insulating and laminated glass. If you have any changes you would like to incorporate, please email Amber Johnson.

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