California Air Resources Board

On behalf of the National Glass Association (NGA), thank you for the opportunity to provide input on the Embodied Carbon Reporting Requirements by CARB.

NGA has more than 1900 member companies across the United States and around the globe, representing more than $10.3 billion in annual sales in the glazing and glass building products industry. Our nonprofit organization represents manufacturers and allied companies covering the entire supply chain of the glazing and glass building products industry from the primary glass manufacturers, glass and metal fabricators, insulating glass manufacturers, manufacturers of completed glass products and systems, spacer and other component suppliers, to the final retail glass and window and door businesses and contract glaziers/installers.

The glass industry manufactures a broad range of final products, which creates an exceptional challenge with regards to Environmental Product Declaration (EPD) development, particularly for processed glass used in the final building product. There are nearly infinite combinations of annealed glass, heat strengthened glass, tempered glass, laminated glass with different thicknesses and interlayers, coated glass with hundreds of different coating products, fire-rated glazing, ballistic / blast resistant / security glass with different configurations, bird-friendly glass, acoustic glass, patterned / fritted / etched glass, decorative glass, dynamic glass, vacuum insulating glass, and insulating glass unit (IGU) configurations with different numbers of panes, glass types, glass thicknesses, spacers, sealants, and desiccants. EPDs for this vast range of processed glass and glazing assemblies do not exist currently.

NGA strongly advise against the request for facility-specific EPDs for architectural glass under “Method 1: Environmental Product Declarations (EPD)”. The flat glass industry in the U.S. consists of a small number of large manufacturers who then supply the diverse chain of fabricators that make processed glass and glazing assemblies. Each flat glass manufacturer has several float plant facilities, at which different products (regular clear, low-iron clear, tints, coated, specialty) are made. Some plants may manufacture many products; others may be dedicated to one. The disclosure of facility specific environmental impact data will result in the disclosure of business sensitive confidential data that could be used in ways that would be competitively disadvantageous. NGA and its Forming Committee manufacturers are highly conscientious regarding avoidance of exchange of information that could be used for anti-competitive purposes.

CARB “Method 2: Facility-Specific Data” temporarily allows manufacturers to supply facility-specific information separately and privately to CARB rather than through a published EPD. This temporary non-public option does not resolve NGA Forming Committee’s concerns in the long term. Facility-specific information would be impractical and overly burdensome for the glass supply chain to track the source of glass because any project can be sourced from multiple glass manufacturing and fabrication locations.

Furthermore, Method 1 requirement that EPDs use facility-specific data that is less than 2 years old is an overly burdensome and unrealistic request. Facilities would need to conduct almost continuous EPD updates in order to keep up with the proposed CARB Embodied Carbon Reporting requirement, as EPDs are usually comprised of 12 months’ worth of data and can take just as long to compile and verify. This level of granularity exceeds that of existing standard and adds cost without improving environmental accuracy. Currently, there is a 5-year data validity standard for EPDs that would be much more practical for manufacturers to maintain. We recommend CARB allows manufacturers to continue using the 5-year data period.

We also recommend that CARB allow manufacturers to report using a Product Carbon Footprint (PCF) in lieu of a full EPD. CA AB 2446 sets a target for a 40% net reduction in GHG emissions from building materials by 2035. It does not include targets or goals for other common impact parameters declared in an EPD such as eutrophication potential, photochemical ozone creation potential, etc. This raises the question of whether an EPD is necessary to meet the intent of CA AB 2446 and demonstrate progress towards California’s GHG goals. PCFs provide the relevant embodied carbon information and reduce the regulatory burden and resourcing cost.

NGA is in strong support of the initiatives to foster sustainability through building materials, and we look forward to continued partnership in improving the built environment in the public interest.