Price: The Switch from ‘Buy Clean’ to ‘Buy Dirty’ Explained

TL/DR –

The Inflation Reduction Act has allocated $4billion to the General Services Administration and Federal Highways Administration for “Buy Clean” programs that favor purchasing products with “substantially lower” emissions. The Environmental Protection Agency defines “substantially lower” as products with the lowest 20% of embodied emissions when compared to similar materials. There’s criticism that the General Services Administration (GSA) has adopted a dual standard that evaluates separately steel products made in electric and blast furnaces, incentivizing higher emissions products, in contradiction to the original “Buy Clean” intent.

The Inflation Reduction Act’s Impact on ‘Buy Clean’ Programs

The Inflation Reduction Act (IRA) has allocated over $4 billion to the General Services Administration (GSA) and Federal Highways Administration (FHWA) for ‘Buy Clean’ initiatives. The mandate ensures that only products with ‘substantially lower’ emissions, defined by the Environmental Protection Agency (EPA) as the lowest 20% of embodied emissions, are purchased.

Recent Environmental Product Declarations (EPDs) provide clarity on which steel products qualify under this framework. Below is a tabulated list of per-ton carbon intensities reported by top American steel producers – Nucor, Steel Dynamics (SDI), and U.S. Steel (USS).

Despite clear instructions to prioritize steel products with ‘substantially lower’ emissions, the GSA has adopted a dual standard that separates products based on production process. This contradicts the core principle of ‘Buy Clean’ programs, enabling high emissions products to qualify under the guise of being less harmful than other high emitting options.

By applying the dual standard to the above hot-rolled carbon intensities, it becomes evident that high emitting facilities such as USS Granite City (Mill 9) and USS Gary (Mill 10) would be deemed clean, while lower emitting facilities like Nucor Indiana (Mill 3) and USS Big River Steel (Mill 4) would not.

Alternative methods like dual standards and sliding scales proposed by major steel producers are inconsistent with the IRA’s language and ‘Buy Clean’ program’s intent. They result in unfair advantages for carbon-intensive producers, mislabel ‘dirty’ steel as clean, and dilute the efforts to decarbonize the industry.

The FHWA can correct this by applying the ‘Buy Clean’ provisions of the IRA as intended by Congress. Two tons of carbon is not ‘substantially lower’ than one, no matter the creative interpretations. The FHWA should avoid following GSA’s flawed policies that contradict climate goals and the statute’s intent.

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