IIBEC Joins Industry Letter Warning of Unintended Consequences of Low Carbon Mandates

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November 3, 2022

By John Boling

IIBEC joined the National Roofing Contractors Association and Polyisocyanurate Insulation Manufacturers Association on a November 3 letter responding to the US General Services Administration’s (GSA) request for information regarding construction materials with substantially lower embodied carbon.

The response seeks to assure GSA that Environmental Product Declarations for materials used in the building enclosure sector are increasingly widely available and that designers base their material selection decisions on numerous factors. The letter makes this unambiguously clear by stating, “We oppose policies that restrict choice among design professionals and building owners based on environmental impacts alone.”

The letter then seeks to educate the GSA that building enclosure system selections are based on multiple performance attributes and that limiting embodied carbon in products or as a percentage of the final product could lead to a bad end. GSA is informed that a product may serve multiple systems and that eliminating it from consideration could lead to suboptimal design choices. Additionally, limiting a whole building’s embodied carbon allowance could lead to fewer systems being placed on a roof or forgoing an addition to an exterior wall assembly that would have improved its operation, but without it reduces its effectiveness.

The letter drives home the point by declaring that “establishing maximum allowable limits on embodied carbon for products used in building enclosure systems can be counterproductive and lead to unintended consequences.”

IIBEC will continue to monitor GSA’s actions in regard to embodied carbon and will work to preserve the building enclosure designer’s ability to select the best product for the project that will serve the customer’s interests.