Craig Wieden, from Colorado DOT, joins us to discuss Environmental Product Declarations (EPDs) and shares insights into implementing EPD requirements for material used in projects throughout the state.
AASHTO re:source Q&A Podcast Transcript
Season 4, Episode 16: Environmental Product Declarations (EPDs) and the CO DOT
Recorded: August 17, 2023
Released: September 12, 2023
Hosts: Brian Jonson, AASHTO Accreditation Program Director; Kim Swanson, Communications Manager, AASHTO re:source
Guest: Craig Wieden, State Materials Engineer, Colorado Department of Transportation
Note: Please reference AASHTO re:source and AASHTO Accreditation Program policies and procedures online for official guidance on this, and other topics.
Transcription is auto-generated.
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00:00:02 ANNOUNCER: Welcome to AASHTO resource Q & A. We're taking time to discuss construction materials testing and inspection with people in the know. From exploring testing problems and solutions to laboratory best practices and quality management, we're covering topics important to you. Now here’s our host, Brian Johnson.
00:00:22 BRIAN: Welcome to AASHTO resource Q&A. I'm Brian Johnson.
00:00:25 KIM: And I'm Kim Swanson.
00:00:26 BRIAN: And today, we're going to talk to a guest from the Colorado dot State Materials engineer, Craig Wieden. Welcome to the podcast.
00:00:34 CRAIG: Thank you, Brian. Thank you, kIM.
00:00:36 BRIAN: We invited Craig to talk about environmental product declarations, which is something that I've been hearing about at the AASHTO Committee on Materials and pavements meetings and other industry meetings for the last few years. There's always been a little bit of discussion, but not a whole lot. And then I found out that Colorado dot has been making some strides with their implementation of these requirements to collect EPD's or environmental product declarations. So, we invited Craig to talk about it. Craig, can you tell us just briefly what an EPD is?
00:01:09 CRAIG: Sure thing, Brian. So, an EPD is a transparent and verified report that presents the environmental impacts of a product. In this case the ones that we're interested in are the construction products that are utilized on our construction.
00:01:25 KIM: So, what type of products are you collecting these EPD's for?
00:01:29 CRAIG: So, Colorado House Bill 21/13/03 is the reason that we're doing this and within that bill, it stipulated that the Colorado Department of Transportation began to collect EPD's on several products. Those products listed in the bill were cement and concrete. Features asphalt and asphalt mixtures and steel. Those are the five basic categories that we were interested in collecting based on the bill.
00:01:53 KIM: What kind of information is included in an environmental product declaration.
00:01:58 CRAIG: There are numerous aspects of the environmental impacts of a particular product that are presented in the EPD's. I don't know that I am skilled enough to make the distinction on what those actually are, but the one that we're interested in is the global warming potential. That's the particular value that we are looking for in these EPD's. They list other. Environmental factors such as ozone depletion, acidification. Nutrification, Smog, Air and I'm looking at an asphalt one, right now, and they're all fairly consistent in what they present. They all present the same environmental information, so proceed out. We're looking specifically at the global warming potential which is presented in kilogram CO2 equivalent.
00:02:40 BRIAN: OK. But at this point, we're benchmarking, right? So you don't have any limits established at this point? Right.
00:02:48 CRAIG: That's correct. What we're trying to do with our benchmarking effort is to collect EPD's for the products that are produced specifically in Colorado or provided to our Colorado projects that meet our specifications. There are some national averages across the US that could be utilized to help establish some of these benchmarks or GWP thresholds. But we really want to try to capture those products that represent.
00:03:10 CRAIG: CDOT notification materials and that's what we're hoping to achieve with this benchmarking.
00:03:13 BRIAN: Effort. So C DOT is mainly interested in the global warming potential, and is that determined through carbon footprint or how do you determine that?
00:03:26 CRAIG: I believe it's developed through the embodied carbon during the production of the materials, so the EPD's that we're looking at are considered cradle to gate EPD's. So they're not looking at the full use life cycle analysis of the particular product. You know how long you put it down the use phase, how long it lasts, etcetera. What we're looking at is the cradle to gate. It's the upstream. Production energy usage, such as the extraction of the aggregates, the crushing of the aggregates, the trucking and transport to plant site. And then the energy production required to actually produce. And mix them at. The site, but that gate portion ends when whether it's asphalt or concrete, it leaves the dryer drum or the batch drum and drops into the back of a truck for transport to the project site. So that's the end of the EPD. From what we're looking at right now.
00:04:13 BRIAN: OK, that negates out what should be similar carbon cost of the effort to install material if I'm producing the material overseas and shipping it over and the environmental cost of transportation and storage and all the other things that factor? That should be considered relative to a local producer, you know, so it would be advantageous to bring that business to the local company, you know, and it also push the local company to do the right things environmentally, like clean up their plants and then it would be another way to promote that.
00:04:55 CRAIG: Related to the transport of overseas materials and things like that, that at least would be captured in the Ed's that we are collecting the cradle to gate because that transport cost of those raw materials to the site where they are going to be mixed and produced and then dropped into a truck. To be delivered to a site would be captured, and that can inflate the EPD GWP values that transport costs. We're lucky here in Colorado to have a lot of natural resources that we can use locally. We have this event and the asphalt plant here locally that I think is going to help with some of that. Certainly there are benefits to helping the communities, helping everything else, and we're looking forward to that as well. One of the things that we have heard in terms of a benefit in the industries being able to generate these EPD's is it's going to allow them to see where the most impactful portions of their production are and enable them to fine tune some of those and make adjustments to actually produce cleaner materials because you don't know what you don't know, frankly. So the background data set that's required to be able to generate these PDF's, all of that collection of that information is going to enable them to focus in on areas that they could potentially hone and clean up a little bit.
00:06:03 BRIAN: I was surprised to hear that the driving force behind this was a a State House. Though I would have thought that something like this would have been mandated by the Federal Highway Administration. How did the State House become the leader, or were they mandated to do that because it just seems like something that a State House would either not have an appetite for or would not have. The understanding of these requirements. No offense to the elected officials in Colorado. But I'm just, it seems. Like a very technical requirement to place upon the state Government office, but maybe I just don't understand any of it, which is probably the case.
00:06:42 CRAIG: I'll attempt to answer that. Obviously I can't put myself into the mind of our legislatures, but Colorado is a pretty progressive state, right? We have a lot of lot of environmental concerns because we have. Such a diverse geography across Colorado, we have the plains. We have the. Mountains. We have a lot of outdoor activities, so we have a lot of environmentally conscious personnel and people in the state of. Colorado and I. Think that trickles over into our legislatures. So I would say that our legislatures are looking to do a lot in terms of protecting the environment in Colorado and this is. Just one of the. Additional methods that they can employ and help us conserve our natural resources here in Colorado because ultimately I think that's what the intent of this bill is going to be. It's entitled the by clean color. To act so it's looking into how can we leverage the state purchasing power through the Colorado Department of Transportation to incorporate some greener or cleaner construction materials into our projects.
00:07:39 BRIAN: What does this look like down the line? So right now you're in the early phases, right? You're collecting information. Where do you see this going? Or where does the state see this going down the line?
00:07:50 CRAIG: What we're in right now is, I guess, our benchmarking period. We're trying to collect EPD's on our current products using our current specifications to determine where are we at in terms of global warming potential for these various products that we're collecting EPD's. The next step for us is to utilize the information that we have to develop global warming potential benchmarks or thresholds for these particular products, and that process will start next year in 2024 and by July 1 of 2025, we need to have a policy in place for C dot that establishes those thresholds. Of the global warming potential of these products, that's what we're ultimately striving to achieve is to collect enough information now so that we can make some informed decisions on how we establish those GWP 3. The last thing that we want to do in Colorado is set a threshold that's going to eliminate that. We want to make an informed decision. Like I said, when we established those GDP thresholds, that still enables competitive bidding on our projects, but then we can work with the industry associations to figure out how to collaboratively clean up the materials. Down the road and get reduced. TWP associated with them.
00:08:58 BRIAN: Yeah. Do you see any other products or materials being added to C dots roster of required?
00:09:05 CRAIG: EPD's that really plays into the industry. Readiness aspect that I talked about a. Little earlier so when we were trying to educate ourselves on what EPD's we want to. Be able to. Collect the ones that we initially tackled out of the blocks were. Asphalt mixtures, concrete and steel, reinforcing steel in particular, because those industries were ready to go, there were product category rules available for those products to enable them to generate EPD. And so, July 1 of 2022 projects advertised after that date, and we began to require EPD's for asphalt mixtures, concrete and reinforcing steel on those projects. We continued to. Engage with industries in the offseason, so after July 1 of 2022, throughout the remainder of that year and early into 2023. We worked to see what other industries we could bring on board, but still working on alignment of those products. Our bid products that aligned with the bill products and so projects advertised after July 1 of 2023, we incorporated some new EPD requirements for our year 2. Roll out. And those products that we're continuing to collect. EPD's on. This year, after July 1, 2023 include precast products. So whether it's precast underground or precast pre stressed elements for our bridges, we're requiring EPD's on those. Now in addition to. That we have structural steel that we have brought on board as well.
00:10:29 BRIAN: And there's some product categories that I'm kind of wondering about right now. And don't people that I know in those industries don't get mad at me for. Asking this but. I noticed you didn't say plastic pipe. His plastic pipe been discussed at all.
00:10:43 CRAIG: It has been brought up. But plastic is not included in the bill and what we're really trying to work on right now is just compliance with the bill has passed. We may expand that down the road because the bill doesn't limit us to the products that are listed in it. But at this time, we're just focusing on compliance with the bill and the five broad bill categories.
00:11:00 BRIAN: That are listed. So here's the other one. And this is part of both of the ones that you're working on now, but also is used separately and that's aggregate. So I would assume that aggregate is factored into the overall EPD for asphalt mixtures and four concrete. But is it a separate category for use as a sub base material or any of the other uses that aggregate has outside of being mixed with asphalt Binder or cement?
00:11:31 CRAIG: It certainly could be. We're not currently looking at it as a separate standalone product at this time. You are correct that the aggregate extraction, crushing all of that preparation aspect goes into the development of an EPD for the asphalt mixture or a concrete mixture.
00:11:46 BRIAN: It'd be interesting to see where that goes. I did read a little bit about this and it sounds like the producers are the ones who are responsible for determining what these values are. Is that correct or did I misunderstand that?
00:12:02 CRAIG: It is the materials producer that is responsible for generating the EPD because they have the in-depth knowledge to be able to populate the background information that's required to. Generate the information in the EPD. Generally these EPD's that the producers are developing are governed by a product category rule and those are ran by a program operator and the example I can give is for asphalt mixtures the program operator is Napa. The National Asphalt Pavement Association and they have developed a tool that will enable asphalt mix producers to. Generate EPD's by the use of that tool. Another example of a program operator is the national ready Mix Concrete Association, who administers the PCR for concrete.
00:12:45 BRIAN: Oh, that's interesting. When you said program operator, I was immediately thinking about a Federal Highway administration representative. That is kind of a master control. Either of these individual products, but it's kind of interesting to hear that the association of the producers is the controller for that. So I guess that at least gives you some consistency across the manufactured product industry to rely on. But I'm a skeptic of a lot of things. And putting that number in the hands of the producer does seem like it presents a little bit of a risk as. Whereas you know will they inflate or deflate the value depending on what you're looking for to promote their product over a different product.
00:13:32 CRAIG: So the Napa IMO Green Eco label tool was developed for their members and non members even which ensures that consistency to the concrete industry. They list three different approved consultants that can generate. Fees for them. They didn't develop those standardized tool, but. Those 3 consultants can develop EPD's the EPD's the one of the beauties of them is that they have to be third party verified. So the inputs that go into them have to be checked by a third party before they are published on the respective program operator website. In terms of the data that goes in and out, that's really the governing aspect behind it.
00:14:07 BRIAN: Colorado is an interesting state because you do produce cement in the state and you do produce asphalt in the state, you know, not all states can say that, right? Has that helped with the communication, having those producers in your state, or does it not matter?
00:14:25 CRAIG: It's more of a national perspective. I mean, we've had some individual outreach with some of those manufacturers here in Colorado. We've had some individual outreach with the asphalt producers in Colorado. We've engaged with them and emphasized the importance of them. Developing an EPD for their cement and for their asphalt binders specifically. Right now, I believe two of the three cement manufacturers in Colorado, one has an EPD, one is actively developing an EPD and the other should be developed shortly. So the submit manufacturers in Colorado have heard us they're on board. They're developing EPD's for their products, which is going to help greatly with the granularity that we're looking for in terms of the EPD's that are generated for concrete, because cement is one of the primary drivers of global warming potential in the concrete mixture for the asphalt side of the house. There's a little bit of work yet to be done. The Napa annual Green Eco label tool that enables the generation of EPD's right now only has four generic binder types in it that are used to generate the EPD value for specific. Mixtures we were concerned about that and the asphalt Institute has stepped up and they have decided to become the program operator for a new asphalt binder product category rule. And so there's a PCR committee that has been headed up at this point and is in process of developing a product category. Rule for asphalt? Reminders that will help with some more of the granularity related to asphalt mixtures. When we get down that. Phase. So in terms of what we're seeing right now, all of the EPD's are generated based on those four base binders that are available in the Napa tool. And at some point, we expect that there will be a lot more granularity, a lot more specificity in the asphalt binder background data set that generates those EPDS.
00:16:13 BRIAN: Interesting. Kim, do you have any other questions about EPD's at this point?
00:16:18 KIM: As you were talking, I was wondering if some additional cost to the producers or the people submitting this to gain the EPD is in an additional expense to get this that you're putting on producers and contractors in Colorado.
00:16:32 CRAIG: There is and we had discussions early on about how we were going to try to accommodate that cost and some of the cost dollar amounts that we heard were, you know, 2 to $3000 up to $30,000 to generate an EPD. So you know for a smaller company. That could be a pretty significant. Yet we discussed it. We made the decision that we weren't going to compensate for it. It's just going to be business as usual in Colorado moving forward. And so each and every material supplier is treated equally. They're all responsible for developing the EPD's and then we figure that cost is going to be passed on through us, the cost to generate an EPD. For an asphalt mixture, for example, if they're a Napa member. I believe it's 3000 or $5000 per plant to buy into it and then they can generate all the EPD's they want. So it's a one time buy into the program to be able to generate EP's, not a big dollar item. When you factor that out over a you know a 50,000 ton job. It's pretty much a wash where there is some additional cost is the plant personnel and the company. You know who are pulling together that background information. To be able to generate the ID because they have to have a full year's usage of energy details and things like that, that. Goes into that. Background but cost wise it's it's not as much as we thought it was going to be. And then it's a especially the Napa tool. It's a one. Time buy in the ready Mixed concrete association. Like I said, they have three different consultants that they listed that could generate EP's in accordance with their product. Library rule and I think each of those 3 consultants has a similar type of tool, but once they engage with a manufacturer on then they work to develop a specific tool for that manufacturer that then enables them to generate EPD's based on different input. So it's not that big of a deal in terms of cost wise, my opinion for the materials perspective and when you factored out like you said over the million tons of asphalt that we pay for in a year, it's it's pretty. Minor, but we are. Watching the bid prices to see if there's any discernible difference, but frankly, with the inflation that we've been seeing, I think that has. Overwhelmed any potential cost? Increase that we have seen related to.
00:18:38 KIM: And what are you hearing from the industry about these new requirements? What are some of their concerns?
00:18:44 CRAIG: A lot of industry concern that we have had is that we utilize these EPD's and the global warming potentials to play off asphalt against concrete. We're not actually planning on doing that. We we can't do that because the end product is not the same, right. So you can't compare an EPD for an asphalt mixture to a EPD for a concrete because it doesn't have the same pure. That's one of the industry concerns.
00:19:06 KIM: So do you have concerns about how the EPD's and what that information gives goes into the quality and the durability of the material going into the roads?
00:19:19 CRAIG: One of the big things that we want to ensure is that we don't sacrifice durability, quality and longevity of these materials for the sake of reduction in GWP. Obviously that's where the full life cycle. Analysis would come. In, but if you put down a cleaner material, then only lasts half as long and you got to replace it all of a sudden. Now you're doubling up on it, you know, whereas before you could have put down a slightly dirtier material. So that's one of our primary concerns. Behind it.
00:19:43 KIM: So you mentioned the House bill in Colorado that kind of mandated that Colorado dot do that and that was passed in 2021 I believe.
00:19:53 CRAIG: Correct, correct, yes. Our governor signed that into law in July of 2021, and we've been. Working to implement it.
00:19:59 KIM: Since then, it is still relatively early if it's, you know, been two years, any challenges or anything gone better than expected as you kind of got this off the ground?
00:20:09 CRAIG: There are numerous challenges. I'll say that you know, industry readiness plays into it pretty heavily in terms of the ability to generate EPD's for these construction materials we're looking at. So we had to do our homework when the. Was passed the FHWA Sustainable Pavements program has been great in helping us gain more knowledge related to that. But some of the challenges that we ran into obviously were what materials have the ability to generate EPDS because the five broad based build categories that we had in our House bill 21/13/03, we didn't know. So we had to do some homework. To find out. What of these products? Can we get EPD's for? Or what industries are ready to provide those EPD's so that was some of the challenges right off the bat is just trying to. And who could provide an EPD if we asked for it? Some things that I would say have gone better than others are the buy in that we've gotten from the local industry in Colorado. So our planned outreach was to engage the industry representatives or the industry associations for the respective materials that we were looking to collect DVD's for. And I would say that our industry associations here in Colorado have helped us with that effort.
00:21:18 KIM: And I also wanted to know, do you know what's happening in other states around EPD?
00:21:23 CRAIG: I have a little bit of information and again we've been participating in the FHWA, sustainable pavement technical working group and that has numerous states around the country that are involved in some of these aspects. I will say that we were not the first state to begin requiring EPD's California was the original implementer of this in 2017. I believe that by Clean California Act was passed and that primarily from my understanding was affecting. Vertical structure or building? And that's honestly where most of these EPD's actually got their start was related to lead certifications and buildings. They could get different lead credits for providing greener materials. I believe we were the first state in the nation to implement a horizontal construction aspect of EPD collection on a wholesale basis, leave California pilots. Some as well. So again, they're right there with us in lockstep. You're seeing a lot of growth across the country, a lot of interest in epubs across the country. I believe legislation has been passed now in. Oregon and more recently in Washington and Minnesota, but don't quote me on the Washington One Port Authority of New York and New Jersey has been collecting EPD's for some time on some of their works. They're more of a local government entity, not a state dot. And then through the FHWA Climate Challenge program, there was a huge interest in huge participation in other states. Across the country that are beginning to look into these EPD's and and begin. To collect these. On construction products. So overall, there's a lot of interest nationwide. There's a lot of information on the FHWA Sustainable Payments website that I think can help guide other state DOT's on how to best implement.
00:23:00 KIM: This do you have any advice of, you know, hard lessons you learned or just best practices to get this off the ground?
00:23:07 CRAIG: Best practice I would say is work with your industry associations in. State get them on board with what you're trying to do with the collection of the EPD's. Engage them early, get their buy in and that will help trickle down to the members. The actual producers that are going to have to generate these. Helping with education, there are numerous areas that they could look, but I would steering towards the FHWA website. There is a buy clean community of knowledge that they have stood up, which is a more of a quarterly aspect where they do different webinars and present on different topics. Those have been very beneficial and helpful to us in in helping to further our knowledge as well. Another recommendation I would have for State DOT's who are looking to implement an EPD program is to engage with a subject matter expert. Somebody who's skilled in the background behind these EPD's who's had a career in life cycle assessments and can help guide and educate the state dot folks. Because we're not experts in. But these guys are they're subject matter experts and we were very fortunate to engage with one that was local. But there are several known SME's around the country who are highly skilled in EPD development.
00:24:13 KIM: Do you have any advice for producers in your state that need to kind of go through this process? With you or what kind of resources do you have available or advice for? The people that you're getting this information from.
00:24:27 CRAIG: That's another reason why we engage some of the industry associations so that they could help build that knowledge and help educate their own producers and members. We have gone so far as to arrange for training and brought in a consultant who is skilled in the generation. Of these EDP'S the precast industry associations, we brought in a consultant. You could help kind of explain the background and what information might be needed from them to help generate these PDF's. So it's just an educational aspect. And helping people get more familiar with what they're going to have to provide in order to generate. An EPD we've tried to. Put everything out there that we can to help you know our staff and the contractors know what we're looking for there so.
00:25:08 KIM: And I will say that the Colorado DOT's website you sent us a link, we'll put it in. The show notes as well. Has a ton Of information, I mean just in this conversation, I've. Learned so much from. Reviewing that website, so we'll share that in the show notes for everybody. But those are. Kind of my pressing thoughts and questions.
00:25:26 BRIAN: Well, I don't have any other questions about Epp's for you, Craig. Thank you so much for your time today and. Good luck developing all these benchmarks and progressing as you learn more about, I guess what the what the environmental impacts are going to be on this ultimately.
00:25:44 CRAIG: That sounds good, and I appreciate you having me on the podcast to discuss EPD's in in Colorado's efforts today. I really appreciate it.
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