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Energy DivisionAdvocacyLCA/EPD Sub-Committee

Helen Sanders, Technoform

Mark Silverberg, Technoform

April 24, 2018

NGA-GANA’s Role The role of the association is to be a forum for discussions and to

facilitate contact between a third party data collection entity and the member company

NGA-GANA will not be involved in data collection or calculations.

There are potential legal ramifications that NGA general counsel will be reviewing as the project proceeds.

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Agenda MOU progress on PCRs with other 3 associations

What’s changing in the market environment re: sustainability?

AB262 update

Survey results re: sustainability issues

Industry-wide EPD considerations

Go Forward Plan

MOU Progress Update with Other Industry Associations

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MOU PCR progress (1) MOU = Memorandum of Understanding to create PCRs for windows

Members AAMA, NGA/GANA, IGMA, WDMA

Structure: 1 staff rep + 2 member reps from each association

PCR for windows issued September, 2015, 5 year expiration

Consensus within 4 associations staff representatives

Focus on new PCRs for windows, not Band-Aid the current PCR, target completion 2020

New ISO 21930 mandates new provisions in PCRs, basis for updating

Work with new Program Administrator for new window PCRs

Streamline process, better represent industry interests

Split residential and commercial

Business to Business

Business to Consumer with energy use phase calculation

MOU PCR progress (2) Go Forward Plan

Convene MOU working group to review and implement staff discussions

Create potential list of Program Administrators to solicit RFPs

Develop RFP

Finalize RFP candidates

Solicit RFP, review, recommend one to associations

Draft work plan, time line and budget

Review and approval of RFP by MOU

Create working committee for PCR development

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What’s Changing in the MarketRegarding Sustainability?

▶In North America, the USGBC’s LEED is the foremost green building rating system.

▶LEEDv4 MR Credits

▶Building Life Cycle Impact Reduction (Whole Building LCA)

▶Building Optimization and Disclosure: Environmental Product Declarations (LCA, EPDs)

▶Building Optimization and Disclosure: Sourcing of Raw Materials (CSR)

▶Building Optimization and Disclosure: Material Ingredients (HPD)

LEEDv4 is Driving Requirements

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Owners Are Driving Requirements for Major Projects

AEC Firms Are Driving Requirements

10.06.2015 10

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Major Retailers Are Driving Requirements

Code, Standards, and Rating Systems are Driving Requirements

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CA AB 262 UpdateRegulatory Change Driver

Regulatory Change is Driving Requirements California AB 262 Background

On October 16, 2017 California enacted the Buy Clean California Act (AB 262) to address carbon emissions.

The new law is in response to Executive Order B- 30-151.

State agencies must consider the Global Warming Potential (GWP) of “eligible materials” in their sourcing.

Carbon steel rebar

Structural steel

Mineral wool board insulation

Flat glass

Other western states are considering similar bills

Other impact categories may be added in the future

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California AB262 requirements By January 1, 2019 California Department of General Services (DGS) must

establish a maximum acceptable GWP for each category of eligible materials.

DGS must set the maximum acceptable GWP at the industry average of facility-specific GWP emissions for each material category.

DGS can set the industry average by consulting Environmental Product Declarations (EPD) or consult LCAs or EPDs that have had critical review.

On or after July 1, 2019 an awarding authority must require the successful bidder to submit a current Environmental Product Declaration (EPD) developed in accordance of specified standards (i.e., ISO 14044 and ISO 14025/EN 21930) for the eligible material.

By January 1, 2022, and every 3 years thereafter, the law requires DGS to review the maximum acceptable GWP for each category of eligible materials, and authorizes DGS to adjust that number downward for any eligible material to reflect industry improvements.

Survey Results on Sustainability

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Survey Results 2018 (1)

Market segments, 32 respondents: 37% commercial, 62% both segments

Business type: FGM 19%/6, Fabricators 37%/12, Suppliers 37%/12

Familiarity with LCA/EPD

Very 41%/13, Somewhat 45%/14, Not 13%/4

Requests for sustainability information and documentation

Last 12 months – 68%

Next 12 months – 72%

Next 26 months – 84%

Frequency of requests

1-5x 62%, 6-9x 14%, 10-25x 19%, More than 25x 5%

Survey Results 2018 (2)

Who asked, do you expect to ask?

Architects 87%, consultant 39%, owners 13%, engineers 18%, other 39%

What kind of information was requested?

LCA 28%/7, EPD 76%/19, Ingredient toxicity 56%/14, Other 12%/3

In your opinion, how important is it your company provide an LCA or EPD to your customers?

Very 17%, Important 33%, Not very 30%, Not at all 20%

How much importance does your company place on providing an LCA and/or EPD to your customers?

High 13%, Medium 26%, Low 30%, None 23%

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Survey Results 2018 (3)

How important for NGA/GANA provide resources? (weighted average)

Education and information – 3.76

Advocacy resources – 3.62

Research on market trends and drivers – 3.60

Industry wide LCA and EPD for processed glass – 3.27

Industry wide LCA and EPD for flat glass – 2.97

Survey Results 2018 (4)

If NGA/GANA were to facilitate an industry wide LCA/EPD for flatglass, likelihood of your company using the data?

Highly 10%, Likely 38%, Unlikely 38%, Highly unlikely 14%

If NGA/GANA were to facilitate an industry wide LCA/EPD for processed glass, likelihood of your company using the data?

Highly 14%, Likely 48%, Unlikely 10%, Highly unlikely 7%

Likelihood your company would provide funding for industry wide LCA?

Highly likely 3.5%, Likely 21%, Unlikely 21%, Highly unlikely 10%, Would depend on cost 21%

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Conclusions from 2018 survey

Most members are receiving requests for material ingredient and toxicity information

Most members project an increase in these requests in the next 12 and 26 months

Member preferences if they would use an NGA/GANA sponsored LCA or EPD for:

Flat glass - 50/50

Processed glass – 62/17 (rest are N/A since they aren’t fabricators)

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0.00%

5.00%

10.00%

15.00%

20.00%

25.00%

30.00%

35.00%

40.00%

45.00%

50.00%

Flat Glass Manufacturer Glass Fabricator Supplier Professional or Consultant Contract Glazier Distributor

Your company's business type is:

2016 2018

0.00%

5.00%

10.00%

15.00%

20.00%

25.00%

30.00%

35.00%

40.00%

45.00%

50.00%

Very Familiar Somewhat Familiar Not Familiar

What is your level of familiarity and understanding of the concepts and business impacts associated with life cycle assessment (LCA) and environmental product declarations (EPD)?

2016 2018

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0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%

70.00%

from 1 - 5 times from 6 - 9 times from 10 - 25 times more than 25 times

If you have received these requests within the past year, per question #4, how many times did you receive these requests?

2016 2018

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0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%

70.00%

80.00%

90.00%

100.00%

Architect Owner Consultant Engineers Other (please specify)

If you indicated yes to #4 above, what type of organization has asked/do you expect will ask you for this information? (Check all that apply)

2016 2018

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%

70.00%

80.00%

LCA EPD Ingredient toxicity (example HPD, DECLARE label) Other (please specify)

What kind of information was requested or do you expect will be requested, per question #6? (Check all that apply)

2016 2018

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0.00%

5.00%

10.00%

15.00%

20.00%

25.00%

30.00%

35.00%

40.00%

45.00%

50.00%

Very Important Important Not very important Not necessary at all

In your personal opinion, how important is it to your company's business success to provide an LCA or EPD to your customers?

2016 2018

0.00%

5.00%

10.00%

15.00%

20.00%

25.00%

30.00%

35.00%

40.00%

45.00%

50.00%

High Medium Low None Don't Know

Based on what you know about your company's plans and priorities, how much importance does your company place on providing an LCA and/or EPD to your customers?

2016 2018

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0

0.5

1

1.5

2

2.5

3

3.5

4

Provide education and information Provide advocacy resources Provide an industry-wide LCA (and EPD)for flat glass

Provide industry-wide LCAs (and EPDs) forprocessed glass (coated, heat treated,

laminated, insulating etc.)

Provide research on market trends anddrivers

Please rank each category for how important it is to your company that GANA provide the following LCA/EPD related resources.

2016 2018

0.00%

5.00%

10.00%

15.00%

20.00%

25.00%

30.00%

35.00%

40.00%

45.00%

Highly Likely Likely Unlikely Highly Unlikely

If GANA were to facilitate an industry-wide LCA/EPD for flat glass, what is the likelihood of your company utilizing the resulting data (e.g. as an input into a product specific processed glass EPD)?

2016 2018

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If GANA were to facilitate an industry-wide LCA for processed glass (coated, heat treated, laminated, insulating), what is the likelihood of your company participating by providing, strictly on a confidential basis, process data (understanding that not participating could limit my company’s use of the final data and/or credit received under programs like LEED)?

0.00%

5.00%

10.00%

15.00%

20.00%

25.00%

30.00%

35.00%

Highly Likely Likely Unlikely Highly Unlikely Participation would depend on thecost

Not applicable, as I'm not aFabricator

If GANA were to facilitate an industry‐wide LCA for processed glass (coated, heat treated, laminated, insulating), what is the likelihood that your company would participate by providing funding?

2016 2018

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Industry-Wide LCA or EPD ConsiderationsFlat and Processed Glass

Industry-wide EPD considerationsAlternative Pros ConsIndustry-wide EPD

Leverages industry economy of scale of flat and processed glass fabricators. A flat glass LCA/EPD will provide the secondary data necessary to create a processed glass EPD.

Industry-wide EPDs allow ½ product vs. product specific EPDs allow full product towards 20 products needed

Establishes industry benchmark based on current information, not old information from public or EU databasesIndustry benchmark allows participating member companies to differentiate their higher performing products with product specific EPDs

To qualify for the optimization credit (Option 2) you need the industry average. Only companies participating in the contributing to the industry average data can pursue Option 2.

Cost effective vs. product specific EPD

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Industry-wide EPD considerationsAlternative Pros Cons

Industry-wide EPD

Only sponsoring companies can use the resulting industry-wide EPD unless partially funded by associationDemonstrates industry leadership and expands marketability of glazingAllows companies to earn LEED points for all covered products that are permanently installed, differentiated by product type, including interior permanently installed glass productsEnables individual companies that contributed data to the industry-wide EPD to develop their own product-specific EPDs, either in-house with a GaBi Envision software interface, or with outside help from a consultant

Industry-wide EPD considerationsAlternative Pros Cons

Industry-wide LCA

All listed advantages of developing an industry-wide average LCA, including 3rd

party critical review.

Lacks 3rd party EPD verification, thus no LEED points are available (LEED only credits product-specific LCAs)

Product specific EPDs

Highest contribution to the LEED EPD credit (1 full Product)

Each company bears the burden of funding and supporting their own EPD

Product specific EPDs

To qualify for the optimization credit (Option 2) requires industry average.

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Confidentiality Information collected by LCA practitioners is covered under

confidentiality and non-disclosure agreements. GANA has been working with thinkstep, one such company, though not exclusively.

The descriptions and examples below are from thinkstep’s NDA:

Keep the disclosing party’s information confidential and use it only for the purpose of the study.

To return or destroy confidential information upon request of the disclosing party.

Hold all confidential information with strictest confidence, not disclosing it to third parties.

Not make copies of confidential information.

What is considered confidential information? Any information disclosed by the company, whether provided orally or in writing

and on whatever medium, concerning the disclosing party’s business and/or operations and includes without limitation any materials, trade secrets, know-how, formulas, processes, algorithms, ideas, strategies, inventions, data, designs, flow charts, drawings, proprietary information, business and marketing plans, financial and operational information, and all other non-public information, material or data relating to the current and/or future business and operations of the disclosing party.

Any analyses, compilations, studies, summaries, extracts or other documentation prepared by thinkstep based on the information disclosed by the disclosing party.

What is not considered confidential?

Anything that is already in the public domain

Anything that is lawfully in thinkstep’s possession, without an obligation of confidentiality

Anything that is received independently by thinkstep from a third party who was free to lawfully disclose such information

Anything that is independently developed by thinkstep without the use of confidential material.

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What data is gathered? At very high level all inputs (e.g., raw materials, utilities, packaging,

etc.) and outputs (e.g., final products, emissions, waste) on an annual basis.

Though this data exists within the gates of your business, you will need to extract the data from the silos in which it lives. How this practically works depends on the internal data management system in place within each company.

The scope of data collected is defined by the LCA or EPD study whether it applies to flat and/or processed glass. If it includes processed glass the processes included will be defined, i.e. tempered, heat strengthened, frit, decorative, insulating, etc.

The complexity of the data collected affects the cost of the data collection process.

LEED points for LCA/EPDs At least 20 different permanently installed products sourced from at

least five different manufacturers are required to qualify for available points.

Permanently installed products with an industry wide EPD count towards 1/2 of a product for purposes of credit achievement calculation under LEED v4.

The same products with a product specific EPD count as a full product.

There is also an optimization credit available for manufacturers who want to benchmark their product specific EPD against an industry wide EPD.

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Cost drivers - industry-wide EPD for processed glass

How many member companies will participate?

How many facilities will data be collected from?

What type of products will be included?

What are the deliverables? LCA only or LCA and EPD?

Are onsite meetings required at facilities, how many?

Will there be a NGA/GANA project manager? Who will drive the project?

Recommended go forward steps:

Phase 1: Onsite Goal and Scope Workshop to scope the solution

Output: Define approximate cost and timeline based on Phase 1

Other Building Products Association Activity 58 Building product associations created industry-wide EPD’s so they

can provide accurate industry-average impacts

Flat glass has no industry-average GWP

Some industries compete with glass and glazing

Cladding

Mineral wool insulation

Air barriers are starting their work

Information Source: ULE, update 3/2018

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Other Building Products Industry AssociationsIndustry Wide EPDs Organization

Program Operator

Aluminum Extrusions Aluminum Extruders Council ULAlum. specialty products incl. ceiling and wall systems CISCA ULAPP modified bitumen roofing membrane (torch applied) Asphalt Roofing Manufacturers Association (ARMA) ULArchitectural and Insulated Precast Wall Panels

CMC ASTM

Asphalt Shingles Asphalt Roofing Manufacturers Association (ARMA) ULBlended Hydraulic Cements PCA ASTMBuilt-up asphalt roofing membrane (Installation: hot asphalt) Asphalt Roofing Manufacturers Association (ARMA) ULCement Grout for Tile Installation: Made NA TCNA -The Tile Council of North America ULCement Mortar for Tile Installation: Made NA TCNA -The Tile Council of North America ULCeramic Tile: Made in North America TCNA -The Tile Council of North America ULClosed-Cell Medium-Density Spray Polyurethane Foam Insulation

SPFAUL

Cold Formed Steel Studs and Tracks Steel Recycling Institute SCSCopper Tubing International Copper Association Brazil ULDrywall Finishing Joint Compound Drywall Finishing Council (DWFC) ULEPDM Non-reinforced roofing membrane SPRI (Single Ply Roofing Industry) UL

Other Building Products Industry AssociationsExpanded Polystyrene EPS Industry Alliance UL

Fabricated hollow structural steel sections American Institute of Steel Construction UL

Hollow Structural Steel Sections Steel Tube Institute ULHomogeneous Vinyl Flooring Resilient Floor Covering Institute UL

Hot-dipped galvanized steel American Galvanizers Association UL

Insulated Metal Panels MCA ULInsulation NAIMA ULLow-VOC adhesive SPRI (Single Ply Roofing Industry) ULMasonry Cements PCA ASTM

Metal Composite Material Panels MCA ULOpen-Cell, Low Density Spray Polyurethane Foam Insulation

SPFAUL

Portland Cements PCA ASTM

Primary Structural Steel Frame Components MBMA ULReady Mixed Concrete NRMCA NSF

Resilient Flooring/Heterogeneous Vinyl Flooring Resilient Floor Covering Institute ULRoll Formed Metal Wall and Roof Panels MBMA UL

Roll Formed Steel Panels (Canada) CSSBI UL

Roll Formed Steel Panels (NA) MCA UL

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Other Building Products Industry AssociationsRubber Floor Tile

Resilient Floor Covering Institute ULSBS-modified btumen roofing membrane (Installation: cold adhesive)

Asphalt Roofing Manufacturers Association (ARMA) UL

SBS-modified btumen roofing membrane (Installation: hot asphalt)

Asphalt Roofing Manufacturers Association (ARMA) UL

Secondary Structural Steel Fram Components MBMA UL

Slag Cement Slag Cement Association ASTM

Spray Polyurethane Foam Insulation and Roofing Systems

SPFAUL

Steel Decking SDI UL

Steel Joists and Joist Girders SJI ULSteel specialty products incluing ceiling and wall systems,… CISCA UL

Structural Precast Concrete CMC ASTM

Thermally Improved Aluminum Extrusions Aluminum Extruders Council UL

Underground Precast Concrete CMC ASTM

Vinyl Composition TileResilient Floor Covering Institute UL

Vinyl Tile - Luxury Vinyl Tile & Solid Vinyl TileResilient Floor Covering Institute UL

Wallboard - Gypsum Board Type X GA FP Innovations

Other Building Products Industry AssociationsWood: Cellulosic Fiberboard AWC UL

Wood: Glued Laminated Timbers AWC UL

Wood: I-Joists AWC UL

Wood: Laminated Strand Lumber AWC UL

Wood: Laminated Veneer Lumber AWC UL

Wood: MEF AWC UL

Wood: Oriented Strand Board AWC UL

Wood: Particleboard AWC UL

Wood: Redwood Decking AWC UL

Wood: Softwood Lumber AWC UL

Wood: Softwood Plywood AWC UL

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Go Forward Options

Go Forward Options – Flat Glass (1) Do nothing = DGS will calculate the industry average GWP with data from

published EPD’s from Guardian and Vitro. Risky with only 2 companies data.

Industry-wide LCA = Minimum 3 flat glass manufacturers provide gate-to-gate manufacturing data for North American production, requires critical review.

Companies that already have LCA data prepared by an experienced LCA practitioner will not need to do additional data collection for this project, as the data has already been collected and QA’d by the practitioner.

Companies that need to collect data will go through the data collection process with the LCA practitioner to ensure the same process is followed.

Estimated cost $25-35,000 including critical review possible if the two flat glass manufacturers with EPDs contribute their LCA data.

Two stages of reporting:

1) PPT summary to NGA/GANA to satisfy CA AB 262 timing and data requirements.

2) Generate a full LCA report with critical review, required step to input LCA into an industry-wide EPD for processed glass.

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Go Forward Options – Flat Glass (2) Industry-wide EPD = Same description and assumptions as option two

with the added step of the creation and verification of an EPD by a third-party Program Operator.

An industry-wide LCA or EPD for flat glass can be used as the data that feeds into a processed glass LCA/EPD.

EPD would be a market-facing, business-to-business declaration in the standardized reporting format.

Estimated cost $30,000 - $45,000 depending on the number of companies that participate. Requires high quality data. Estimate includes background LCA report, but excludes any fees by third parties, such as those for program operator.

Go Forward Options – Processed Glass #1: Do nothing = Each company may provide Product Specific EPDs as

they choose.

#2: Industry-wide LCA = Requires LCA data collected from a minimum of 3 major glass fabricators based on industry average LCA data from flat glass manufacturers.

Document is not market facing, only internal.

Estimated cost depends on number of participants.

#3: Industry-wide EPD = Same assumptions as option #2 plus creation and verification of an EPD by a third-party Program Operator.

EPD would be a market-facing, business-to-business declaration in the standardized reporting format.

Cost depends on the number of companies participating, how many products are included, what processes are included, number of participating companies, how many facilities. Goal and scope workshop engagement would be first step.

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Conclusions If flat glass industry doesn’t provide industry-average LCA data, CA will do

it themselves

No control on data sources that contribute to their method

Glass industry will not like the result of CA calculation based on 2 data sources

Without industry-wide average LCA data from flat glass, we can’t do an industry-wide LCA or EPD for:

Processed glass

Windows (under consideration by industry associations)

EPD standards are evolving and standardizing, and are the benchmark for compliance

Environment is changing – it’s not just LEED driving requirement for environmental transparency documentation

More western states are considering similar legislation

Additional impact categories to GWP may be added in the future

Scenarios for timeline and deliverables

Path Price Range (per mfr.) Program Operator Fee Timeline

1a – Product-specific LCA Middle range NA, critical review $3-5,000 3+ months

1b – Product-Specific EPD High range Yes, annual maintenance 4+ months

2a – Industry-wide LCA Low range NA, critical review $3-5,000 8+ months

2b – Industry-wide EPD Middle range Yes, annual maintenance 9+ months

3 – Hybrid Solution Middle – high range Yes, annual maintenance 10+ months

4 – Do nothing $0 $0 NA

Fill to block background fill to block background fill to block

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Image showing we will rise or fall together.