Measuring Construction Industry 

Envir o nmental Per formance 

September 2007 

Contents 

Contents ........................................................................................................................................... i

Introduction..................................................................................................................................... 1

Normalizing Data............................................................................................................................ 3

Green Building Practices ................................................................................................................ 4

Construction and Demolition Debris Management ...................................................................... 14

Diesel Air Emissions..................................................................................................................... 21

Stormwater Compliance................................................................................................................ 24

Energy Use and Greenhouse Gas Emissions ................................................................................ 35

Appendix: State Sampling Approach for NOIs ............................................................................ 38

Endnotes........................................................................................................................................ 39

September 2007 Page i 
Introduction 

As EPA seeks new and better ways to pursue its mission, the measurement of environmental 

progress has become even more important. Through the Sector Strategies Program in the Office 

of Policy, Economics, and Innovation, EPA works together with many sectors to reduce their 

environmental impacts in cost-effective ways and to share information with the public. By 

engaging a broad range of stakeholders in the process, EPA hopes to promote a culture of 

understanding and environmental stewardship. For the construction sector, EPA Sector Strategies 

formed a partnership with the Associated General Contractors of America (AGC) to work 

together to improve the environmental performance of the construction industry. 

Tracking the environmental performance of the construction sector in particular presents some 

unique challenges including: the large number of construction firms (and even larger number of 

construction sites); the prevalence of small businesses; and the lack of centralized data (federal 

or state) on environmental measures for this non-manufacturing sector. Often-used sector 

environmental performance measures and data sources are either not applicable to or not 

available for the construction sector—for example, chemical releases from the Toxics Release 

Inventory, or the details of air permits. Instead, this sector’s environmental footprint includes 

areas such as sediment and contaminants in stormwater runoff, disposal of debris, and air 

emissions from nonroad equipment—all areas not well covered by EPA databases. Data on some 

of the topics of interest for construction are available from sources such as at the state-level, 

however, even using these data present challenges: the data collection can be infrequent within a 

state and inconsistent across states. 

To address these challenges, this report provides recommendations on possible measures of 

environmental performance for the construction sector.

1 The information is this report will help 

EPA select the most meaningful measures for construction, and will be of interest to other 

government agencies working with construction, as well as other construction industry 

stakeholders. 

Note that throughout the report only available data were investigated; new information collection 

efforts are not proposed. Currently, AGC is in the process of surveying its members on their 

environmental practices related to green buildings, diesel retrofits of equipment, construction 

debris, and environmental management systems. Their survey is expected to be recurring, which 

may make it possible to use the survey data to analyze trends over time. As this effort is 

currently underway and information from it has not yet been made publicly available, the data 

could not be included in this report. 

As the impacts of construction are of concern to multiple EPA programs and offices, a team 

representing all of the EPA programs with a focus on the construction industry was assembled, 

1 Note that this report focuses on the construction phase of the built environment; it does not address activities prior 

to construction such as siting of buildings, the selection of materials, or post-construction activities (e.g., building 

operation). 

September 2007 Page 1 
September 2007 Page 2

with leadership provided by the Sector Strategies Program. This team worked together to choose

the environmental topic areas where measurement was needed. This report provides background

information for each of these topic areas relevant to the construction sector, recommends

measures, and also describes other measures considered. The topic areas are:

 Normalizing Data

 Green Building Practices

 Construction and Demolition Debris Management

 Diesel Air Emissions

 Stormwater Compliance

 Energy Use and Greenhouse Gas Emissions
Normalizing Data 

Background .....................................................................................................................

This report frequently refers to “normalized” data when presenting trends over time. 

Normalizing means adjusting the actual annual numbers (e.g., count of Notices of Intent, gallons 

of fuel consumed) to account for changes in the sector’s output over the same time period. For 

example, if the gallons of fuel consumed increased steadily over time, this could be due to an 

increase in construction activity, rather than an indication of reduced fuel efficiency. Without 

accounting for the increase in construction activity, the graph would show an upward trend. After 

adjusting for the increase in construction activity (i.e., after normalizing the data), the rate of 

increase would be reduced. 

Recommended Measures ...............................................................................................

McGraw-Hill Construction. Current and historical data on the “Value of Construction” and the 

number of projects in the residential, non-residential building, and engineering (roads, bridges, 

dams, airports, water and sewers, etc) subsectors are available from McGraw-Hill Construction. 

These data are updated quarterly, and 2006 is the most current complete year of data available. 

Data are available by state. The data do not distinguish between projects based on their acreage 

or, for residential projects, the number of dwelling units (e.g., one project could have 50 dwelling 

units). For non-residential and non-building projects, the number of projects includes the number 

of unique project types. For example, if a site includes constructing a hospital and a parking 

garage, that would be counted as two projects. Because the McGraw-Hill custom report covers 

the construction sector more comprehensively than the Census data, it is included in this report 

as the recommended measure. 

Other Measures Considered ..........................................................................................

U.S. Census Bureau. U.S. Census tracks the national dollar value of construction put in place 

on a monthly basis by the type of construction (e.g., construction for residential, commercial, 

lodging) through 2005. However, these data are not readily available at the state level. The 

Census Bureau does provide state-specific data on the dollar value for private non-residential 

construction put in place. A report costing $200 includes annual data from 1993 through 2005 by 

state, but these data exclude public construction, residential construction, power, communication, 

and railroad construction.

1 

Census data are also available for the annual number and valuation of privately owned housing 

units authorized by building permits, by state, for 1980-2005.

2 These data, also referred to as 

construction starts or housing starts, are of limited value as a normalizing measure for the 

construction sector as a whole, in that they cover only the residential subsector of construction. 

September 2007 Page 3 
September 2007 Page 4

Green Building Practices

Background .....................................................................................................................

Stakeholders throughout the construction sector are increasingly promoting practices aimed at

reducing the environmental impact of construction activities. Green building actually

encompasses numerous environmental topics, but this report focuses on measuring performance

only during the construction phase of the built environment; it does not address activities prior to

construction such as design, siting of buildings, specification of materials, or operation of

structures.

Several different types of rating or certification systems are now available to assess green

buildings. From a measurement perspective, the program with the most data available is the

Leadership in Energy and Environmental Design (LEED) Green Building Rating SystemTM.

LEED, which was developed by members of the U.S. Green Building Council (USGBC), is a set

of voluntary standards for designing, constructing, and operating high-performance green

buildings. First released in 2000 as a green building rating system for new commercial

construction, LEED has expanded since then to cover additional aspects of building construction

and operation, including existing building operations and maintenance, commercial interiors

projects, and core and shell development projects. LEED certification distinguishes building

projects that have demonstrated a commitment to green building by meeting performance

standards. Tracking the construction sector’s contributions to LEED certification provides a

possible indicator of the sector’s shift toward operations that are more environmentally

sustainable.

Currently, AGC is in the process of surveying its members on their practices related to green

buildings, among other environmental topics. Their survey is expected to be recurring, which

may make it possible to use the survey data to analyze trends over time. As this effort is

currently underway and information from it has not yet been made publicly available, the data

could not be included in this report.

Recommended Measures ...............................................................................................

LEED-NC Credits Related to Construction Activity. Construction practices play a key role in

a building’s LEED certification. Projects must meet prerequisites to qualify for certification. One

of these prerequisites is specifically construction-related, requiring a site-specific plan to reduce

pollution from construction activities by controlling soil erosion, waterway sedimentation, and

airborne dust generation. In addition to the prerequisites, projects receive points for each

performance benchmark (credit) that they meet within each of five categories: sustainable sites;

water efficiency; energy and atmosphere; materials and resources, which include credits for

recycling and salvaging construction and demolition debris; and indoor environmental quality.3

A project’s point total, as assessed by an independent certifier, determines whether it will receive

certification, and dictates its level of certification. Levels of certification range from “Certified”

for projects receiving at least 26 points, to “Platinum” for projects earning 51 points or more.
September 2007 Page 5

Although the USGBC defines the credits or criterion by the intent, requirements, strategies, and

technologies associated with each, it is not always obvious which criteria are associated with

decision-making at the construction contractor level. This report assigns each criterion to one of

three categories: 1) not construction-related, 2) construction-related, or 3) possibly constructionrelated. Table 1 lists the specific criteria assigned to each category based on the criteria for

LEED-NC: Green Building Rating System for New Construction and Major Renovations

(version 2.2). In order to obtain credits, a project must first meet certain prerequisites for each

category. Though projects must complete the prerequisites before acquiring credits, the

prerequisites themselves do not add to the total number of credits (and are thus not presented in

the graph of total LEED credits). Figure 1 displays the number of credits received between 2000

and 2006 by all certified projects for all construction-related and possibly construction-related

criteria combined.

Table 1: Categories with Construction-Related Prerequisites and Credits

Construction-Related Prerequisite

Sustainable Sites

Construction Activity

Pollution Prevention

Reduce pollution from construction activities by controlling soil erosion,

waterway sedimentation and airborne dust generation.

Criteria Flagged as Construction-Related or Possibly Construction-Related

Construction-Related

Materials & Resources

Construction Waste

Management, Divert

50% from Disposal

Divert construction, demolition and land-clearing debris from disposal in

landfills and incinerators. Direct recyclable recovered resources back to the

manufacturing process. Direct reusable materials to appropriate sites.

Construction Waste

Management, Divert

75% from Disposal

Divert construction and demolition debris from disposal in landfills and

incinerators. Direct recyclable recovered resources back to the manufacturing

process. Direct reusable materials to appropriate sites.

Indoor Environmental Quality

Construction IAQ

Management Plan,

During Construction

Reduce indoor air quality problems resulting from the construction/renovation

process in order to help sustain the comfort and well-being of construction

workers and building occupants.

Construction IAQ

Management Plan,

Before Occupancy

Reduce indoor air quality problems resulting from the construction/renovation

process in order to help sustain the comfort and well-being of construction

workers and building occupants.

Possibly Construction-Related

Sustainable Sites

Stormwater Design,

Quantity Control

Limit disruption of natural water hydrology by reducing impervious cover,

increasing on-site infiltration, reducing or eliminating pollution from stormwater

runoff, and eliminating contaminants.

Stormwater Design,

Quality Control

Limit disruption and pollution of natural water flows by managing stormwater

runoff.

Site Development,

Protect or Restore Habitat

Conserve existing natural areas and restore damaged areas to provide habitat

and promote biodiversity.
September 2007 Page 6

Materials & Resources

Building Reuse, Maintain

75% of Existing Walls,

Floors & Roof

Extend the life cycle of existing building stock, conserve resources, retain

cultural resources, reduce waste and reduce environmental impacts of new

buildings as they relate to materials manufacturing and transport.

Building Reuse, Maintain

95% of Existing Walls,

Floors & Roof

Extend the life cycle of existing building stock, conserve resources, retain

cultural resources, reduce waste and reduce environmental impacts of new

buildings as they relate to materials manufacturing and transport.

Building Reuse, Maintain

50% of Interior NonStructural Elements

Extend the life cycle of existing building stock, conserve resources, retain

cultural resources, reduce waste and reduce environmental impacts of new

buildings as they relate to materials manufacturing and transport.

Materials Reuse, 5% of

total value of materials

used

Reuse building materials and products in order to reduce demand for virgin

materials and to reduce waste, thereby reducing impacts associated with the

extraction and processing of virgin resources.

Materials Reuse, 10% of

total value of materials

used

Reuse building materials and products in order to reduce demand for virgin

materials and to reduce waste, thereby reducing impacts associated with the

extraction and processing of virgin resources.

Recycled Content, 10%

(post-consumer + 1⁄2 preconsumer)

Increase demand for building products that incorporate recycled content

materials, thereby reducing impacts resulting from extraction and processing of

virgin materials.

Recycled Content, 20%

(post-consumer + 1⁄2 preconsumer)

Increase demand for building products that incorporate recycled content

materials, thereby reducing the impacts resulting from extraction and

processing of virgin materials.

Regional Materials, 10%

Extracted, Processed &

Manufactured Regionally

Increase demand for building materials and products that are extracted and

manufactured within the region, thereby supporting the use of indigenous

resources and reducing the environmental impacts resulting from

transportation.

Regional Materials, 20%

Extracted, Processed &

Manufactured Regionally

Increase demand for building materials and products that are extracted and

manufactured within the region, thereby supporting the use of indigenous

resources and reducing the environmental impacts resulting from

transportation.

Rapidly Renewable

Materials, 2.5% of total

value of materials and

products

Reduce the use and depletion of finite raw materials and long-cycle renewable

materials by replacing them with rapidly renewable materials.

Certified Wood, 50% of

wood-based materials and

products

Encourage environmentally responsible forest management.

Indoor Environmental Quality

Low-Emitting Materials,

Adhesives & Sealants

Reduce the quantity of indoor air contaminants that are odorous, irritating

and/or harmful to the comfort and well-being of installers and occupants.

Low-Emitting Materials,

Paints & Coatings

Reduce the quantity of indoor air contaminants that are odorous, irritating

and/or harmful to the comfort and well-being of installers and occupants.

Low-Emitting Materials,

Carpet Systems

Reduce the quantity of indoor air contaminants that are odorous, irritating

and/or harmful to the comfort and well-being of installers and occupants.

Low-Emitting Materials,

Composite Wood &

Agrifiber Products

Reduce the quantity of indoor air contaminants that are odorous, irritating

and/or harmful to the comfort and well-being of installers and occupants.

Source: USGBC. LEED-NC: Green Building Rating System for New Construction and Major Renovations. v2.2. 2005.
Figure 1: Total LEED-NC Construction-Related Credits Received 

Num

ber of Credits 

Across 

Projects 

2,800 

2,400 

2,000 

1,600 

1,200 

800 

400 

0 

Per Year 

2000 2001 2002 2003 2004 2005 2006 

Year 

Construction-Related 

Possibly Construction-Related 

Total (Construction- & Possibly Construction-Related) 

Source: USGBC. 2007. LEED-NC v2 Certified Projects. June 2007;

USGBC. 2005. LEED-NC: Green Building Rating System for New Construction and Major

Renovations. Version 2.2. October 2005.

September 2007 Page 7 
Year

The growth in construction-related credits earned closely tracks the overall increase in 

LEED certified projects, as would be expected. To show the trend in construction 

contractors’ contributions on a per project basis, Figure 2 depicts the average number of 

construction-related credits received per project in each year. A total of 22 credits are 

defined as either “construction-related” or “possibly construction-related.” An increase 

over time in the average number of these credits received per project would indicate an 

increasing contribution of the construction sector in achieving green building 

certifications. As presented in the graph below, the average number of constructionrelated credits received per project increased between 2000 and 2002, and has remained 

relatively constant since then with approximately 11 credits per project. 

Figure 2: Average Construction-Related Credits Per LEED-NC 

Project 

0 

5 

10 

15 

20 

25 

2000 2001 2002 2003 2004 2005 2006 

Average Number of Credits/Project 

Construction-Related 

Possibly Construction-Related 

Total (Construction- & Possibly Construction-Related) 

Total Construction- and Possibly Construction-Related Credits Available 

Source: USGBC. 2007. LEED-NC v2 Certified Projects. June 2007.

USGBC. 2005. LEED-NC: Green Building Rating System for New Construction and Major

Renovations. Version 2.2. October 2005.

September 2007 Page 8 
Construction Contractors with Professional LEED Accreditation. In addition to the building 

certification process, the USGBC administers a program whereby individuals can earn LEED 

Professional Accreditation. Of the 25,700 LEED Accredited Professionals listed in the USGBC’s 

directory, 610 of them selected “General Contractor” as their area of practice.

4 2006 was the first 

year that the USGBC tracked the affiliation of LEED Accredited Professionals. Tracking the 

year-to-year change in the number of construction contractors who receive accreditation could 

provide an indicator of the trend in the green building knowledge of professionals and trades 

people in the sector. A change in the number of LEED Accredited Professional contractors is an 

indirect measure of the construction sector’s investment in the requisite human infrastructure 

needed to expand green building practices. As the database is populated in the coming years, the 

trend in contractors receiving LEED accreditation could be tracked, as shown in Figure 3. 

Figure 3: LEED Accredited Professional General Contractors 

300 

400 

500 

600 

700 

800 

900 

2006* 2007 2008 2009 2010 

Year 

Number of contractors 

* First year of data collection 

Source: USGBC Accredited Professionals database 

http://www.usgbc.org/LEED/AP/ViewAll.aspx?CategoryID=1306&CMSPageID=1585 

September 2007 Page 9 
Other Measures Considered ..........................................................................................

LEED Certified Projects. The trend in LEED certified projects was considered as a potential 

measure of the construction industry’s green building practices, however, it is possible for a 

building to achieve the points required for LEED certification without employing any green 

construction practices beyond the prerequisites. Tracking the change in the number of buildings 

certified over time, therefore, gives an inconclusive indication of the construction sector’s 

contributions to LEED certification, and thus is not included as a recommended measure. 

Figures 4 and 5 show trends in the number of LEED certified projects as of August 2007. Figure 

4 shows the cumulative number of LEED certified projects, by project type. The total number of 

certified buildings increased from 5 in 2002 to 960 through August 2007. Figure 5 shows the 

annual number of LEED certified projects (this graph is not cumulative). In 2002, five buildings 

received LEED certification, and in 2006, 236 buildings received certification. For both graphs, 

note that data for 2007 are included for January through August only. Also note that during this 

time period, additional options for LEED certification became available, such as for existing 

buildings, that weren’t available in 2002. The total number of LEED New Construction projects 

is shown by certification level in Table 2. 

Figure 4: LEED Certified Projects 

(cumulative by year*) 

0 

200 

400 

600 

800 

1000 

1200 

2001 2002 2003 2004 2005 2006 2007 

Year 

Number of certified projects 

LEED NC LEED EB LEED CI LEED CS Total *A s of August 2007 

NC = New Construction, EB = Existing Buildings, CI = Commercial Interiors, CS = Core & Shell

Source: Personal communication with Kurt Steiner, U.S. Green Building Council. August 2007.

September 2007 Page 10 
September 2007 Page 11

NC = New Construction, EB = Existing Buildings, CI = Commercial Interiors, CS = Core & Shell

Source: Personal communication with Kurt Steiner, U.S. Green Building Council. August 2007.

Table 2: Total LEED Certified New Construction

Projects in the United States

Level Score LEED Certifications at

This Level*

Certified 26-32 250

Silver 33-38 199

Gold 39-51 149

Platinum ≥ 51 22

*As of August 1, 2007

Additional Green Building Standards.

Green GlobesTM provides another program for rating green buildings in the United States.

The Green Building Initiative (GBI) brought Green GlobesTM—an online rating system for

commercial structures developed by BOMA Canada’s Green Go Plus program—to the U.S.

market in 2004. The Green Globes system rates commercial buildings based on their

environmental performance in seven areas: project management, site, energy, water,

resources, emissions, and indoor environment. Projects that achieve 35% or more of the total

points available to them receive a rating of one or more Green Globes:

Figure 5: LEED Certified Projects

(actual value by year*)

0

50

100

150

200

250

300

350

2001 2002 2003 2004 2005 2006 2007

Year

Number of certified projects

LEED NC LEED EB LEED CI LEED CS Total *As of August 2007
September 2007 Page 12

 Projects achieving 35-54% of the total points receive one Green Globe.

 Projects achieving 55-69% of the total points receive two Green Globes.

 Projects achieving 70-84% of the total points receive three Green Globes.

 Projects achieving 85-100% of the total points receive four Green Globes.

To date, eight projects in the U.S. have been awarded Green Globes: one project received

four Green Globes, one received three Green Globes, and six projects received two Green

Globes. Given that this program is relatively new to the U.S. market, and that it currently has

so few U.S. awards, the data on the specific construction-related points that the award

buildings received have not been incorporated into this report at this time.

The Standard Project Committee 189 (SPC 189) of the American Society of Heating,

Refrigerating and Air-Conditioning Engineers (ASHRAE) is establishing minimum standards

for the design of high-performance green buildings. The standards apply to new commercial

buildings and major renovation projects and addresses sustainability, water use and energy

efficiency, the building’s impacts on the atmosphere, materials and resources, and indoor

environmental quality. The provisions of this standard do not apply to low-rise residential

buildings, manufactured houses, and buildings that do not use either electricity or fossil fuel.

Using USGBC’s LEED® Green Building Rating System as a key resource, the standard will

be an ANSI-accredited standard that can be incorporated into building code. It is anticipated

that the standard will eventually become a prerequisite within LEED.5

Green Home Building. The National Association of Home Builders (NAHB) published its

Model Green Home Building Guidelines in 2005. Intended as a toolkit for residential

builders and local home builders associations, these guidelines address lot preparation and

design; resource efficiency; energy efficiency; water efficiency/conservation; occupancy

comfort and indoor environmental quality; and operation, maintenance, and education.6The

NAHB Web site states that “by the end of 2007, more than half of NAHB’s members, who

build more than 80 percent of the homes in [the United States], will be incorporating green

practices into the development, design and construction of new homes.”7 Apart from this

claim, the NAHB does not provide any metrics that would be useful for tracking trends in

green building practices among residential builders.
Use of Environmentally Preferable Products. Tracking trends in the construction sector’s use 

of environmentally preferable products (e.g., low VOC paint or FSC certified wood products) is 

another area of interest to EPA. Construction contractors usually have a limited influence on the 

types of materials that are used in buildings, so use of environmentally preferable products is not 

a recommended measure in this report. One measure that was considered was the use of certified 

wood products. Projects pursuing LEED Certification can receive one credit for using Forest 

Stewardship Council (FSC) certified wood. In order to receive this credit, a minimum of 50% of 

the project’s wood-based building components (i.e., structural framing and general dimensional 

framing, flooring, sub-flooring, wood doors, and finishes) must be certified in accordance with 

the Forest Stewardship Council’s (FSC) Principles & Criteria of Forest Stewardship. These apply 

to the management of forests used for the production of wood products.

8 FSC tracks the number 

of LEED certified projects that have received the certified wood credit, as shown Figure 6.

9 

Construction contractors have limited influence on whether or not certified wood is used; 

therefore, this metric was not recommended as a measure of the environmental performance of 

the construction sector. 

Figure 6: LEED Certified Buildings Receiving Certified Wood 

Credit 

0 

10 

20 

30 

40 

50 

2001 2002 2003 2004 2005 2006 

Year 

Num

ber of certified 

buildings 

Source: Miller, K. Forest Stewardship Council, Washington, DC. Personal communication, 

December, 2006. 

September 2007 Page 13 
September 2007 Page 14

Construction and Demolition Debris Management

Background .....................................................................................................................

Construction and demolition (C&D) debris is produced when new structures are built and when

existing structures are renovated or demolished. C&D debris is a significant contributor to the

nation’s solid waste. Most of this debris is disposed of, such as in landfills, rather than recycled.

EPA and the construction sector share a focus on reducing the impact of C&D debris on the

environment, so a national measure of C&D debris generation and management would be a

valuable metric. Currently, there is no centralized, national source for information on quantities

of C&D debris generated or recycled.

Currently, AGC is in the process of surveying its members on their practices related to C&D

debris management, among other environmental topics. Their survey is expected to be recurring,

which may make it possible to use the survey data to analyze trends over time. As this effort is

currently underway and information from it has not yet been made publicly available, the data

could not be included in this report.

The following section uses several terms that are similar but not equivalent. In general, the term

generation refers to the amount of waste produced, whereas disposal refers only to waste that is

not recycled or reused (in many cases, this is also referred to as landfilled waste). Recycled waste

refers to any waste that has undergone processing so that it may be used again (in some

instances, this may include the direct reuse of materials and composting). Some states also refer

to source reduction quantities, which are input materials that are not used and therefore do not

become waste.

Recommended Measures ...............................................................................................

Trends in C&D Debris Recycling Rates at the State Level. One approach for estimating the

quantity of C&D debris generated annually in the U.S. is to use state-level C&D debris data,

normalized for changes in state-level construction activity. It should be noted, however, that

C&D debris measurement practices differ significantly among states so that a national trend

cannot be projected.

A number of states including California,10 Florida,11 Iowa,12 Maryland,13 Missouri,14 Virginia,15

Wisconsin, Massachusetts, and Washington track the amount of C&D debris disposed of, but

only Florida, Maryland, Virginia, Massachusetts, and Washington publish the data regularly.

Among these five states, there are several inconsistencies in the data they present, including:

 Florida, Maryland, and Massachusetts are the only states identified that regularly collect data

for C&D debris disposal and recycling.

 Virginia tracks only the amount of C&D debris that is landfilled or recycled at permitted

facilities.

 Maryland and Virginia C&D debris data are currently available through 2005.
September 2007 Page 15

 Florida and Massachusetts C&D debris data are currently available only through 2004.

 Washington tracks the amount of C&D recycled annually by conducting mandatory surveys;

however, waste handlers do not face any penalty for not returning the survey. Though

Washington tracks waste landfilled annually, the data only includes the demolition and inert

materials categories.

In addition to these states, other states may also have some supplementary information, although

not necessarily data that are suitable for a trend analysis. For example, Ohio has 2003 data on the

amount of C&D debris processed at C&D facilities, as well as 2006 data on the amount of C&D

debris disposed at both C&D and MSW facilities. These Ohio data sources are problematic for

two reasons: the 2003 data exclude a large portion of generated C&D material, and data were

only collected for two years. Iowa, Missouri, Wisconsin, and Oregon also have limited data with

similar issues. Table 3 summarizes data availability and limitations in the states investigated for

this report.
September 2007 Page 16

Table 3: C&D Debris Data Availability by State

State Data Availability Data Limitations

California Total Generated and Diverted by Year C&D debris data are not updated in

regular intervals.

Connecticut Connecticut does not report annual amounts of C&D

disposed or recycled.

Florida C&D Collected and Recycled 1997-2004

Iowa Does not track C&D recycling or disposal. Iowa has data

on the amount of C&D landfilled in 1998 and 2005.

Maryland Tracks total tons of C&D debris managed and recycled

from 1999 to 2005 at permitted refuse disposal facilities.

Massachusetts Tracks total tons of C&D debris generated, disposed of,

and diverted from 1998 to 2004.

Missouri

Missouri does not track C&D debris generation regularly.

Has a waste characterization report from the late 1990s.

Missouri suggests applying the percentage of C&D debris

from that study to the 2005 disposal tonnage.

This method assumes that total waste

disposal changes equally across all

sectors.

New York

New York does track disposal and recycling data to some

extent. Data were not included due to reporting

inconsistencies and completeness.

Does not include waste that is

exported or does not go to disposal

facilities. Annual report data may be

incomplete.

Ohio

Sent data from 2003 on C&D debris at C&D disposal

facilities. Also sent 2006 data on C&D debris disposal at

C&D and MSW facilities.

2003 data does not include C&D

debris not going to C&D facilities (a

large underestimate). 2006 data

does not include recycling.

Oregon

Does not separate disposal numbers into C&D. For

disposal and recycling, data is listed by material type.

May be able to provide an indication on C&D material.

Material types listed do not include

inert material such as concrete.

Texas

Texas has tracked C&D disposal information from 2001

to 2005 for permitted and registered facilities. Texas

does not track recycling.

Virginia Tracks C&D material received and recycled at permitted

facilities.

This does not include waste that does

not go to permitted facilities (captive

waste management). This results in a

large underestimate of total recycling.

Washington

Washington tracked annual C&D diversion from 1999 to

2005. Disposal data are also available but only in

“demolition” and “inert materials” categories.

Diversion data is based on voluntary

survey results. Disposal data are not

presented specifically for C&D.

Wisconsin

Wisconsin only has some C&D debris numbers from a

waste-sort in 2002 at MSW facilities. Does not track

recycling.

Sources: All information obtained from state environmental department websites or personal

communications.16
Trends in C&D debris recycling are presented in Figure 7 for five states: Florida, Maryland, 

Massachusetts, Virginia, and Washington (with the aforementioned caveats). The “5 States 

Combined” line shows the average percent C&D debris recycled by aggregating the five states’ 

tons recycled and dividing by the aggregated tons generated to calculate the percentage of 

material recycled. The percentage of C&D debris that is recycled in these states combined has 

remained relatively steady over the six years examined, fluctuating between 28% and 36%. 

These data are presented as state-specific examples, not as a quantitative indicator of a national 

trend in C&D debris recycling. Further research, beyond the scope of this report, is needed to 

better understand the drivers that cause the vastly different recycling rates among the states 

presented and within states. For example, Massachusetts’ high recycling rate may be the result of 

the state’s mandatory C&D debris recycling requirements for several materials. 

Figure 7: Generated C&D Debris That Is Recycled in Five 

States 

0% 

20% 

40% 

60% 

80% 

100% 

1998 1999 2000 2001 2002 2003 2004 2005 

Year 

Percent Recycled 

Maryland Florida Massachusetts 

Virginia 5 States Combined Washington 

Sources: 

http://www.mde.state.md.us/Programs/LandPrograms/Recycling/publications/index.asp ­

recycling;

17 http://www.dep.state.fl.us/waste/categories/recycling/pages/03_data.htm;18 MA 

DEP, 2004;

19 2006;20 Virginia DEQ;21 Washington Department of Ecology, 2006.22 

September 2007 Page 17 
Other Measures Considered ..........................................................................................

National C&D Debris Trends for Building-Related and Road and Highway Construction. 

For EPA’s Office of Solid Waste, Franklin Associates developed a methodology to estimate the 

quantity of C&D debris generated in the United States in 2003 from the construction, demolition, 

and renovation of residential and nonresidential buildings.

23 As a preliminary estimate, this study 

calculated that 164 million tons of building-related C&D debris was generated in the United 

States in 2003.

24 Of that quantity, approximately 40% was recycled, and the remainder was 

disposed of.

25 The methodology for this study combined national Census Bureau data on 

construction industry activities (e.g., construction permits and construction value) with point 

source waste assessment data (i.e., waste sampling and weighing at a variety of construction and 

demolition sites) to generate a national estimate of building-related wastes. Findings are 

presented in the draft report, Characterization of Building-Related Construction and Demolition 

Debris Materials in the United States, expected to be final later in 2007. Considerable 

uncertainty is associated with the estimates presented in this study because the methodology 

relied on data from a limited number of waste assessments from new construction sites (293 

residential, 12 nonresidential), the majority of which could now be considered outdated. For 

example, only 8 of the 293 studies were conducted after 1997, and the most recent study was 

conducted in 2000. Furthermore, the estimation of demolition debris was based on data from the 

demolition of five residential buildings and 27 nonresidential buildings. Additionally, reviewers 

of the study’s methodology expressed concern that the Census Bureau undercounts the number 

of construction permits issued. In the future, if point source waste assessments were conducted 

more systematically, at regular intervals, and with a larger sample size representative of 

nationwide building construction and demolition, this could become a potential method for 

estimating changes in C&D debris practices nationwide. Currently, this study could provide an 

overview of national C&D trends by comparing the 2003 findings to those presented in a similar 

report published by EPA in 1996. 

A method similar to the Franklin Associates method was developed for EPA’s Office of Solid 

Waste to assess the quantity of C&D debris generated in the United States from road 

construction.

26 This methodology used road statistics published by the Federal Highway 

Administration (FHWA) to determine the number of lane-miles in the U.S. in 12-foot lane 

widths. By combining the area measurement with assumptions (obtained from literature and 

industry experts) about pavement type, maintenance time frames, reconstruction and resurfacing 

depths, and weight factors, this methodology was used to estimate road C&D debris generation 

on a tons per year basis. The preliminary estimate of road-related C&D debris generation was 

167 million tons, of which 88% was recycled and the remainder was disposed of.

27 Similar to the 

building-related C&D debris assessment, this study is not updated regularly and is therefore of 

limited value for reporting trends in road and highway C&D debris generation. 

National Surveys 

Both the Construction Materials Recycling Association (CMRA) and the National Demolition 

Association (NDA) have conducted national surveys to gauge levels of recycling activity. In 

1997 and 2004, the CMRA surveyed its members and developed estimates of total C&D waste 

processed and recycled. The CMRA survey estimated that national C&D recycling by C&D 

September 2007 Page 18 
processing plants was at 197 million tons in 2004, up from 96 million tons in 1997.

28 However, 

the CMRA currently does not have any plans for a future survey. NDA conducted its surveys in 

1995 and 2005. The survey results reflect the amount of demolition debris generated and 

recycled by NDA members, nationwide. In 2005, NDA members who responded to the survey 

reported an aggregated demolition debris generation total of nearly 16 million tons and a 

demolition debris recycling total of over 11.5 million tons.

29 Using a statistical model, NDA 

extrapolated from the survey results to develop a national demolition waste generation number 

for all demolition activity (NDA members and non-members). Although NDA estimates the 

national amount of demolition debris generated, it does not include a national estimate of 

demolition recycling.

30 

Trends in C&D Debris Generation at the State Level. In addition to examining state-level 

recycling data, an analysis of trends in state-level C&D debris generation was also considered as 

a possible measure. After normalizing generation data for changes in state-level construction 

activity, inferences could be drawn about the level of materials reuse activity in each state. For 

example, if the normalized quantity of debris generated in a particular state decreased over time, 

it might suggest that C&D debris reuse was increasing in that state. Data for five states are 

shown in Figure 8. 

Figure 8: Amount of C&D Debris Generated 

0 

5 

10 

15 

20 

25 

30 

2001 2002 2003 2004 2005 

Year 

Millions 

of Tons* 

Maryland Florida Massachusetts 

Virginia 5 States Combined Washington 

* Normalized by value of construction from McGraw -Hill Construction. 

Sources: http://www.mde.state.md.us/Programs/LandPrograms/Recycling/publications/index.asp ­

recycling;

31 http://www.dep.state.fl.us/waste/categories/recycling/pages/03_data.htm;32 MA DEP, 

2004;

33 2006;34 Virginia DEQ;35 Washington Department of Ecology, 2006;36 and McGraw-Hill 

Construction, U.S. Total Construction Value. 

September 2007 Page 19 
This approach has several data limitations and caveats. First, although more states 

regularly track C&D generation than track recycling, few were identified that had 

accessible data collected at regular intervals. Second, the McGraw-Hill data does 

not include information specific to demolition or renovation activities; normalizing 

disposal data for overall construction activity that may not include demolition or 

renovation could generate misleading results. Third, as with the recycling data, each 

state defines C&D disposal differently and has varying methods for collecting and 

measuring disposal information. These disparities make developing an aggregated 

year-to-year percentage change problematic. For these reasons, it does not seem 

likely that recommending a measurement of trends in C&D debris disposal data will 

add value to this report. 

September 2007 Page 20 
September 2007 Page 21

Diesel Air Emissions

Background .....................................................................................................................

Most construction vehicles are powered by diesel engines. Diesel engines are also used

frequently in other kinds of equipment found at construction sites, such as generators and

compressors. Diesel air emissions are a focus for EPA because diesel exhaust (from all sources)

is one of the largest sources of fine particulate matter in the U.S., and this exhaust also contains

ozone-forming nitrogen oxides and other air pollutants.

In 2003, EPA proposed new emission standards for new nonroad diesel engines. These engine

standards will begin to take effect in the 2008 model year, so significant reductions in air

emissions are expected in 2008 and beyond. To help reduce emissions from the existing fleet of

nonroad engines, innovative programs at both the federal and state level encourage retrofits of

engines currently in use. For example, EPA’s National Clean Diesel Campaign (NCDC) awards

grants for projects designed to demonstrate effective emissions reduction strategies for dieselpowered vehicles, including construction equipment.

Currently, AGC is in the process of surveying its members on their diesel retrofit activities,

among other environmental topics. Their survey is expected to be recurring, which may make it

possible to use the survey data to analyze trends over time. As this effort is currently underway

and information from it has not yet been made publicly available, the data could not be included

in this report.

Recommended Measures ...............................................................................................

Emissions Reductions from Diesel Retrofits. EPA’s regional offices track emission

reductions from the EPA-funded projects and from retrofit projects funded by non-EPA sources.

The data are then uploaded quarterly to the National Clean Diesel Campaign (NCDC) database.

The national database uses an equation that incorporates the type of equipment retrofitted, the

horsepower and model year of the retrofitted equipment, the year in which the retrofit occurs,

and the number of vehicles retrofitted in order to estimate the reductions in particulate matter

(PM), carbon monoxide (CO), nitrogen oxide (NOx) and hydrocarbon (HC) emissions from the

projects.

This database could be used to measure the year-to-year change in emission reductions

associated with voluntary diesel retrofits, which are primarily particulate matter (PM) and nitrous

oxide (NOx). Baseline data indicate 7,793 tons of PM emissions and 39,747 of tons of NOx

emissions were eliminated through diesel retrofits from 2003 through 2006. Data through 2006

are shown in Figure 9, with the following limitations:

 There is no requirement to report diesel retrofit activities to EPA; therefore, this database

provides a lower-end estimate of total emission reductions from construction equipment.

 Emission reductions are not estimated for all of the projects tracked by the database

because complete information (i.e., type of vehicle retrofitted, number of vehicles
September 2007 Page 22

retrofitted, or horsepower of vehicles retrofitted) is only available for 40 of the 85 tracked

projects.

 As additional data become available for projects already in the NCDC database, it is

possible that estimated emission reductions could change, even if the number of retrofit

projects does not change.

 Only baseline data are currently available. At the end of 2007, an additional data point

will be available to show the annual change from the 2003 – 2007 combined data as

compared to the 2003 – 2006 combined data.

Figure 9: Emission Reductions from Construction Diesel

Retrofits, 2003-2006

0

10

20

30

40

50

PM NOx

Tons, thousands

2003-2006 (baseline data)

Note: Eighty-five projects are included in the NCDC database, but emission reduction data

are available for only forty of the projects; therefore, this graph reflects emission reductions

from those forty projects only.

Source: Went, J. USEPA Office of Transportation and Air Quality. Personal communication,

August 2007.
Other Measures Considered ..........................................................................................

Criteria Air Pollutant Emissions. EPA’s Emission Factor and Inventory Group (EFIG) in the 

Office of Air Quality Planning and Standards (OAQPS) prepares a national inventory of the 

criteria air pollutant (CAP) emissions, based on input from numerous state, tribal, and local air 

pollution control agencies as well as EPA-generated and industry-submitted data. This inventory, 

called the National Emissions Inventory (NEI), is updated every three years and includes 

emissions of carbon monoxide, nitrous oxides, particulate matter, and sulfur dioxide. Non-road 

mobile sources in NEI include emissions from the operation of construction equipment, such as 

tractors, generators, excavators, rubber tire loaders, and off-highway trucks. However, the 

published NEI data combine emission estimates from construction equipment with emission 

estimates from mining equipment. Therefore, emission estimates from construction equipment 

alone are not readily available. 

Emission Reductions from State Retrofit Programs. At the state level, the two most 

significant engine emissions reduction programs are in California and Texas. These programs 

provide financial incentives for reducing NOx and PM emissions from a variety of sources, 

including construction equipment.37,38 

The Texas Emissions Reductions Program (TERP) awards funds through a competitive process. 

It provides grants to equipment owners to make voluntary equipment changes (i.e., new 

purchases, replacements, re-powers, and retrofits) that reduce emissions of NOx. TERP awards 

funding based on the dollar amount requested by the applicant as compared to the NOx 

reductions expected from their proposed project (i.e., lowest dollars per ton of NOx reduced).

39 

For funded projects, TERP tracks the associated NOx reductions. Data are presented for on-road 

and nonroad projects; however, nonroad includes other applications in addition to construction 

(e.g., agriculture, irrigation, mining). Without specific knowledge of each project, emissions 

reductions specific to the construction sector cannot be tracked. 

California’s Carl Moyer Program has been funding engine emissions reductions projects since 

1998. The program provides funds on an incentive-basis for the incremental cost of cleaner-thanrequired engines and equipment. Data are available for the first six years (1998-2004) of the Carl 

Moyer Program, and show that 322 construction equipment-related engines have been repowered or retrofitted. These projects have achieved NOx emission reductions of 892 tons/year 

and PM emission reductions of 47 tons/year.

40 

September 2007 Page 23 
Stormwater Compliance 

Background .....................................................................................................................

Since the early 1990s, EPA has regulated construction activity disturbing five or more acres of 

land and discharging stormwater to surface waters (Phase I). EPA and authorized states establish 

general National Pollutant Discharge Elimination System (NPDES) permits, which codify 

specific site management practices and reporting requirements for construction sites disturbing 

five acres or more. The promulgation of the Phase II rule in 2003 reduced the threshold for 

permit coverage to one acre of disturbance. Obtaining coverage under a state or EPA 

Construction General Permit (CGP) requires developing a stormwater pollution prevention plan 

(SWPPP) describing how the operator will minimize erosion, contain sediment and other 

construction-related pollutants, and control runoff volume and speed. Before starting land 

disturbance, the operator develops a SWPPP and submits a “Notice of Intent” (NOI) form, which 

is an application for permit coverage. 

Stormwater is one of the most significant environmental issues for this sector, and is a focus for 

both EPA and construction trade associations. Given this emphasis on stormwater management, 

a measure of trends in this area is needed, however, tracking trends in stormwater compliance 

has been challenging for several reasons. Data on the quantities of sediment or contaminants 

entering waterways from construction sites is not available, as there are no practical site-specific 

techniques to measure this. Data on site-specific stormwater management practices could 

potentially be used to estimate runoff prevented, but are not available because SWPPPs are not 

submitted to the permitting authority. Alternatively, data are available on the number of NOIs 

submitted. This metric does not give a direct environmental measure (e.g., tons of sediment in 

site runoff), but it does provide an indication of the number of sites that are aware of the 

requirements and likely have developed and implemented a SWPPP. 

Measures Recommended ...............................................................................................

Nationally Representative Trends in NOIs Submitted 

The trend in NOI submissions is the only national information available on construction 

stormwater compliance. When adjusted to account for changes in construction activity, such as 

the number of projects per state per year, the count of annual NOIs over time could indicate 

whether compliance with the NPDES requirement to obtain permit coverage is increasing or 

decreasing. 

The primary challenge in tracking the trend in NOI submissions is that there is no data source 

available that tracks the number of construction sites subject to stormwater requirements. While 

the McGraw-Hill data track the number of projects by project type, they do not track the number 

of construction sites. One site that requires one NOI may be listed in the McGraw-Hill data as 

two or more projects. For example, a construction site where a roadway and a pipeline are being 

constructed would be listed as two projects (because they are two different types of construction) 

September 2007 Page 24 
September 2007 Page 25

in the McGraw-Hill count of projects, but may only require one NOI. Further complicating the

ability to track NOI trends is that individual construction sites may obtain more than one NOI

when different owner/operators are responsible for different stages of the project. Additionally,

stormwater permits are typically issued at the state-level. All but five states are authorized to

issue NPDES permits. Among the authorized states, the information on NOIs varies. Most states

collect basic site information through the NOIs submitted, such as owner/operator name, site

address, date of construction start and end, and, in some cases, site acreage.

NOI Data Sources Available for Tracking Trends in NOIs Submitted

Data Source for States Where EPA is the Permitting Authority. In the five states where

EPA rather than the state is the permitting authority, NOIs are submitted through the EPA’s

centralized NOI Processing Center. These five states are: Alaska, Idaho, Massachusetts, New

Hampshire, and New Mexico. The NOI Processing Center’s information is expected to be the

most consistent source among all states for tracking the trend in the number of NOIs

submitted, and could show how NOI submittals are changing as contractors increasingly

become aware of the requirements. Since July 2003, the NOI Processing Center has collected

NOIs electronically (known as the eNOI). Prior to the eNOI, NOIs were submitted to EPA on

paper. Submissions dating back to 1997 have been entered into a database (separate from

eNOI) and are available from EPA’s NOI Processing Center. These data, however, are not

considered as reliable as the post-2003 eNOI data that includes both paper and electronic

submissions. Based on this reduced data reliability, NOIs submitted prior to 2003 are not

included in the recommended presentation.

In addition to providing a count of NOIs submitted annually, eNOI data include information

on the acreage disturbed, allowing a separate examination of trends for sites greater than five

acres (as a proxy for those sites covered under Phase I) and sites less than five acres (as a

proxy for Phase II sites). U.S. territories (except the U.S. Virgin Islands) and Indian Country

must submit NOIs directly to EPA as well. Counts of these NOIs are not presented here due

to the difficulty of obtaining normalizing data for each of these areas.

Data Sources for Authorized States. The data maintained on NOIs vary among authorized

states. Even a basic metric such as the number of NOIs per year can be challenging to

compile, because states’ information management protocols and systems vary in what

information is collected on NOIs, how many years records are retained, and whether data are

maintained electronically or on paper. Based on the research conducted as background in

developing this report, it appears that most states track NOIs electronically, however, several

data inconsistencies among states were identified, including:

 Not all states track the acreage of the sites obtaining NOIs.

 Some states’ NOI data are maintained by individual counties or districts.

 States differ in how they define construction activity requiring an NOI (e.g., requiring

sites less than one acre to obtain coverage, requiring pit excavation activities to obtain

coverage under the CGP).
September 2007 Page 26

Method Used for Developing a National Trend in NOIs Submitted

Sampling Approach. By combining data from authorized states with data from states where

EPA is the permitting authority, a nationally representative trend in NOIs was developed.

This analysis required obtaining data from states identified through a sampling plan

developed to account for the variation in state-level construction activity that influences the

number of NOIs received per state. The details of the sampling approach used are included in

the Appendix. As described in the sampling approach, using probability sampling techniques

allows the use of design-based estimation methods, so that the results are nationally

representative. First, the five states where EPA is the permitting authority were included in

the sample for their completeness and quality of data; however, these states accounted for

only 4% of the national total value of construction in 2006. Next, the size distribution of the

states was examined (based on value of construction). The three largest states (California,

Florida, and Texas) accounted for 29%

of the national total value of

construction in 2006, and were

therefore included in the sample with

certainty. The remaining states were

sorted based on their EPA Regions.

From this sampling frame, 12 states

were drawn using value of construction

in 2006 as the measure of size. The

resulting sample included a total of 20

states (5 states where EPA is the

permitting authority + 3 largest states +

12 randomly selected states).

Data Collection. Based on the

sampling plan, NOI data were accessed

from the states identified, either

through data retrieval from the state

website or by contacting state

stormwater coordinators. The number

of NOIs submitted by each state was

normalized by the annual value of

construction in the state. Table 4

presents the contribution of each state

to the total number of NOIs in the

sample in 2006. Table 5 outlines the

quality of data collected from the

sample of 20 states.

Table 4: Contribution by State of NOIs Included

in the Nationally Representative Sample (2006)

State Percent of 2006 NOIs

TX 20.5%

CA 19.2%

FL 10.4%

AL 8.1%

MN 6.1%

PA 4.8%

NM 4.2%

IL 4.0%

NY 3.6%

SC 2.8%

MO 2.7%

UT 2.4%

ID 2.1%

NV 1.9%

MA 1.6%

KY 1.5%

AK 1.2%

NH 1.2%

AR 1.2%

CT 0.4%

NOTE: CT data include only NOIs for projects greater than 5 acres,

2006 South Carolina are incomplete.

Sources: EPA Office of Water eNOI database for AK, ID, MA,

NH, NM., Stormwater program data from AL, AR, CA, CT, FL, IL,

KY, MN, MO, NV, NY, PA, SC, TX and UT.
September 2007 Page 27

* EPA is the permitting authority.

Sources: EPA Office of Water eNOI database for AK, ID, MA, NH, NM. Stormwater program data from AL, AR, CA, CT, FL,

IL, KY, MN, MO, NV, NY, PA, SC, TX, and UT.

Table 5: Availability and Completeness of Data From EPA Permitted and Authorized States

State Surveyed Overall Acreage

Alaska* Complete Occasional incomplete records.

Alabama Complete No acreage data available.

Arkansas Occasional incomplete records. Occasional incomplete records.

California Complete Occasional incomplete records.

Connecticut Data unavailable for projects below

5 acres. All projects greater than 5 acres.

Florida Complete Complete

Idaho* Complete Occasional incomplete records.

Illinois Complete Occasional incomplete records.

Kentucky Occasional incomplete records. No acreage data available.

Massachusetts* Complete Occasional incomplete records.

Minnesota Complete Occasional incomplete records.

Missouri Complete No acreage data available.

New Hampshire* Complete Occasional incomplete records.

New Mexico* Complete Occasional incomplete records.

Nevada Complete Complete

New York Data unavailable for January and

February 2003.

No acreage data available for 2003.

Complete for 2004-2006.

Pennsylvania Complete Occasional incomplete records.

South Carolina

Data unavailable for coastal

counties for several months in

2006.

Occasional incomplete records for 2003-

2005.

No acreage data available for 2006.

Texas Complete Occasional incomplete records.

Utah Occasional incomplete records. Complete
Trends in NOI Submissions 

National Trend in NOIs Submitted, by Acreage Disturbed, Normalized by Value of 

Construction. Figure 10 shows the nationally-representative trend in NOI submissions, 

based on the sample of 20 states. The data were adjusted to account for the changes in 

construction activity, as measured by the state-specific annual construction value. From 2003 

to 2006, NOI submissions, normalized by the state-specific value of construction, increased 

by 45%. 

Note that the trend may be impacted because states’ Phase II regulations took effect at 

different times. Some states did not develop a permit for construction sites that are one to 

five acres in size by the March 2003 deadline, as required by EPA’s Phase II rule. After a 

state implements the Phase II permit requirements, the number of NOIs submitted in that 

state would be expected to increase significantly. If a state implemented the Phase II permit 

in 2004, for example, the number of NOI submissions in 2004 would be expected to be 

considerably greater than the number submitted in 2003. This increase, however, would 

reflect the expansion of permit coverage to the smaller sites rather than an increase in the 

percent of covered sites obtaining an NOI. 

* Acreage was unknown for at least one NOI submitted in MA, AK, NH, NM, ID, AL, AR, CA, CT, IL, KY, MN,

MO, NY, PA, SC, and TX. Acreage data were not available for AL, KY, MO, NY in 2003, and SC in 2006.

NOTE: 2003 New York data and 2006 South Carolina data are incomplete.

Sources: EPA Office of Water eNOI database for AK, ID, MA, NH, NM, Stormwater program data from AL, AR,

CA, CT, FL, IL, KY, MN, MO, NV, NY, PA, SC, TX, and UT. 2003 – 2006 data on construction value from

McGraw-Hill Construction, U.S. Total Construction Value.

September 2007 Page 28 
September 2007 Page 29

National Trend in NOIs Submitted by Acreage Disturbed, Normalized by Number of

Construction Projects. As an alternative to tracking the trend in NOI submissions per dollar

of construction value, the trend in NOI submissions per construction project could be

examined as an indication of trends in obtaining permit coverage. If the number of NOIs

submitted increases at a greater rate than construction activity (as measured by number of

projects), this would indicate improving permit coverage rates. The data presented in Figure

11 indicate: The Number of NOIs Submitted/The Number of Projects in the McGraw-Hill

Database.

This method does not indicate the percentage of sites in compliance with the NOI submission

requirement because there is no data source available that tracks the number of NOIs

required. The McGraw-Hill data on the number of construction projects for certain types of

projects (specifically, non-residential and non-building projects) count the number of

individual project types, which does not correspond to the number of NOIs required. One

construction site that requires one NOI may be included in the project count as multiple

construction projects. For example, a hospital and a parking garage for the hospital may be

constructed together, under a single contract, but in the McGraw-Hill data, these are two

different types of projects and would be considered as two different projects in the count of

the number of projects. They may, however, require only one NOI. Data are not available to

adjust the number of projects to account for this situation, where activities at a single site are

counted as multiple projects. Without this adjustment, the number of projects is

overestimated.

To improve the trend estimate, several adjustments were made when examining the number

of NOIs per construction project to get the percent of construction projects submitting NOIs:

 Adjustment to the number of NOIs submitted. Construction sites may have multiple

operators that are required to obtain permit coverage, so the actual number of NOIs

submitted could be higher than the total number of construction sites requiring permit

coverage. Based on information from the eNOI database, it is assumed that 10% of NOIs

are multiple submissions for the same site. Therefore, the number of NOIs was multiplied

by 0.90 to account for the multiple submissions for a single project site.41

 Adjustment to the number of projects. The number of projects includes sites less than

one acre in size. For example, EPA estimated that 25% of sites were less than one acre in

the 1999 Economic Analysis of the Final Phase II Storm Water Rule.42 Therefore, the

number of projects was multiplied by 0.75 to better estimate the number of projects

requiring an NOI.

 Adjustment to the number of projects. EPA estimated that 15% of sites qualify for a

waiver from stormwater program requirements; therefore, the number of projects was

multiplied by 0.85 to better estimate the number of projects requiring an NOI.43
While these adjustments improve the metric, Figure 11 still does not indicate the percentage 

of sites in compliance with the NOI submission requirement. The denominator (“Number of 

Projects”) still overestimates the number of projects requiring an NOI because a single 

construction site may be counted multiple times if it happens to include multiple project 

types. Instead, Figure 11 indicates the trend in NOI submissions, and shows that the 

percentage of construction projects with NOIs increased by 63% from 2003 to 2006. 

NOTE1: Number of NOIs was adjusted to account for multiple submissions from a single site. Number of 

projects was adjusted to account for sites less than one acre and sites qualifying for a waiver. 

NOTE 2: 2003 New York data and 2006 South Carolina data are incomplete. 

NOTE 3: Because all projects do not require an NOI, this is not an indicator of percent of projects in 

compliance with the requirement to submit an NOI. 

Sources: Number of projects from McGraw-Hill Construction - US Total Construction Number of Projects 

by State, 2005. Number of NOIs from eNOI for AK, ID, MA, NH, NM and from state-specific data files for 

AL, AR, CA, CT, FL, IL, KY, MN, MO, NV, NY, PA, SC, TX, and UT. Adjustment for multiple NOIs 

from EPA Office of Water, Water Permits Division, via December 15, 2006 email. Adjustment to estimate 

construction projects less than one acre from U.S. EPA, Economic Analysis of the Final Phase II Storm 

Water Rule, October 1999, page 3-7. 

September 2007 Page 30 
Other Measures Considered ..........................................................................................

National Trend in NOIs Submitted by Acreage Disturbed, Not Normalized. Figure 12 

displays the total number of NOIs submitted each year for the nationally representative sample of 

20 states. It shows a 57% increase in NOI submissions from 2003 to 2006. Without normalizing 

the data, this measure does not account for changes in construction activity. 

NOTE: 2003 New York data and 2006 South Carolina data are incomplete. 

Sources: Number of NOIs from eNOI for AK, ID, MA, NH, NM. and from state-specific data files for AL, AR, CA, 

CT, FL, IL, KY, MN, MO, NV, NY, PA, SC, TX, and UT. 

Trend in Percentage of Construction Projects with NOIs Submitted, by State. Using the 

McGraw-Hill data for number of construction projects per state per year, the number of NOIs per 

construction project could be calculated by state for 2003 - 2006. Although this ratio indicates 

the relative change over time in obtaining permit coverage, it does not serve as an indicator of 

the state-level permit coverage compliance rate for the same reasons as discussed in above for 

the recommended measures. 

Figure 13 shows this measure for the sample of 20 states over a four-year period. For the 20 

states in the sample, the ratio of NOI submissions to total construction projects ranged from 2% 

to 28%. The ratio increased from 2003 to 2006 for 19 states in 2006. Only Texas showed a 

declining ratio of NOI submissions to construction projects. The absolute number of NOIs 

submitted in Texas increased by 12% from 2003 to 2006, but during this same time period the 

number of construction projects in the state increased by 22%. 

September 2007 Page 31 
NOTE1: Number of construction projects includes projects less than one acre in size.

NOTE2: 2003 New York data and 2006 South Carolina data are incomplete.

Sources: Number of projects from McGraw-Hill Construction - US Total Construction Number of Projects by State.

Number of NOIs from eNOI for AK, ID, MA, NH, NM. and from state-specific data files for AL, AR, CA, CT, FL, IL,

KY, MN, MO, NV, NY, PA, SC, TX, and UT.

Although Figure 13 illustrates an increase in the number of sites that are aware of the 

requirements and likely have developed and implemented a SWPPP, it does not show a 

nationally representative trend. To show this trend on a national level, the measure shown in 

Figure 11 was developed. 

September 2007 Page 32 
September 2007 Page 33

Trends in the Percentage of Stormwater Inspections Resulting in Violations or Actions.

National Trends. ICIS-NPDES is a modernized data system covering Clean Water Act

compliance and enforcement that may provide a new measure in the future. Structurally,

ICIS-NPDES contains expanded permit and compliance information for stormwater

requirements and the stormwater permits, which were not available in the legacy Permit

Compliance System. However, only states where EPA is the NPDES permitting authority

and the states that directly entered their data into PCS are using ICIS-NPDES. Between now

and the end of FY08, the states that are involved in batch uploads and hybrid data entry are

expected to be in the new system. In addition, while states are not required to submit

compliance information on minor NPDES permits to EPA, an increasing number of states do

(http://www.epa.gov/echo/about_data.html). To the extent that ICIS-NDPES is populated by

state programs providing information for stormwater permits, it would be possible to

measure the percentage of inspections or inspected locations where violations are found or an

enforcement action occurs. However, such a measure would not be representative of the

sector as a whole because sites suspected of having issues (e.g., where a complaint was

made) are more likely to be inspected, thus skewing the data.

Quantitative Geographically-focused Analysis. EPA staff identified several specific state,

county, or local construction stormwater programs as having a particularly strong presence.44

If strong programs could be identified that collect more-extensive data, metrics of interest to

EPA such as percentage of construction stormwater inspections resulting in violations could

potentially be examined. EPA contacts also mentioned municipal separate storm sewer

systems (MS4s) as potential sources of additional information on construction stormwater.

MS4s transport and discharge polluted stormwater runoff into local rivers and streams

without treatment. To meet their EPA stormwater requirements, operators of regulated MS4s

are required to develop and implement a program to control construction site runoff,

including plan review, inspection, and enforcement. However, following a discussion of the

quantitative geographically focused approach with EPA Headquarters and Region 3 staff, it

was determined that sufficient and consistent data are currently not available to conduct a

quantitative analysis. If MS4s could be identified that inspected all constructions sites, the

bias associated with targeted inspections would be removed and a metric of the percentage of

inspected sites with violations could be calculated. While the violation rate would be accurate

for that particular MS4, it would only be applicable to a small geographic area and could not

be considered nationally representative.

Qualitative Geographically-focused Analysis. Given that a quantitative, representative

sampling approach to tracking trends in stormwater violations does not appear to be feasible,

a qualitative approach could be considered as an alternative. This approach would involve

purposeful sampling where data sources, such as selected MS4s, are strategically and

purposefully selected. Potential sampling approaches include:

 Maximum variation sampling. In this approach, the trends in violations could be

compared between one or more strong MS4s and one or more MS4s that are considered

to have a weak program related to construction activity. This approach is intended to

show the range of construction stormwater activity among MS4s.
September 2007 Page 34

 Criterion sampling. If weak MS4s cannot be identified, a criterion sampling approach

could be used where all cases that meet some criterion are selected. For this analysis, the

approach could involve an examination of the violation trends from MS4s that inspect all

construction sites in the MS4. This approach eliminates the bias in examining violation

data from areas conducting targeted inspections. Criterion sampling is intended to

maximize the information presented on construction stormwater while keeping costs low.

 Typical case sampling. Typical case sampling is used to illustrate or highlight what is

typical or average performance. This approach would be feasible if MS4 programs that

are considered “typical” with respect to stormwater inspections at construction sites could

be identified, such as through a review of annual reports, or by an EPA expert.

Once a sampling approach is selected, any available data on stormwater inspections of

construction sites could be analyzed, such as the frequency of inspections and violations per

inspection (delineated between first-time and repeat inspections for any given site). If

sufficient information were available, the goal of the analysis would be to assess trends in the

percentage of inspections resulting in violations. Data analysis would be supplemented with

interviews of inspection and program management staff to gain insight into the drivers

behind the trends observed. In some cases, such as that of weak MS4s in a maximum

variation sample, data may not be available and the analysis would rely solely on the

anecdotal interview information obtained. Findings would be presented in a case study

format and would not be nationally representative.
September 2007 Page 35

Energy Use and Greenhouse Gas Emissions

Background .....................................................................................................................

Energy is used in construction in several ways: on building sites to meet electricity needs, as

fuels to power construction equipment, in offices, and by transport of materials to and from the

site. In addition to reducing the air quality impacts of diesel emissions discussed earlier, reducing

energy use could reduce costs and greenhouse gas emissions. Greenhouse gas emissions in the

construction sector appear to come mostly from energy use.

Recommended Measures ...............................................................................................

Carbon Dioxide (CO2) Emissions from Energy Consumption. CO2 emissions from

construction were estimated based on data on purchases of distillate fuel, natural gas, and

electricity from the U.S. Census Bureau’s 2002 Economic Census Industry Series Report for

Construction, and presented in a preliminary report prepared for EPA’s Sector Strategies

Division.45 These Census data are updated every five years, and the 2002 report is the most

recent data currently available. Spending on fuel was converted to consumption values, and

purchased electricity was converted to electricity consumption using the cost of fuel and

electricity, respectively, from the U.S. Department of Energy’s State Energy Data Report

published by the Energy Information Administration (EIA). Consumption values were converted

to emissions using EIA’s Electric Power Annual. Caveats related to this estimate include:

 Fossil fuel combustion and electricity emission estimates include only CO2. Combustion

activities also generate emissions of methane (CH4) and nitrous oxide (N2O), however

such emissions have not been estimated.

 Electricity and fuel combustion emission estimates assume national average CO2

emission factors.

 Regional differences in energy prices could not be accounted for; the method applies the

national average costs of fuels and electricity to all construction energy purchases.

 The U.S. Census (2002) provides dollars spent on gasoline and diesel fuel as one lumped

sum, which needed to be disaggregated to estimate non-CO2 emissions. Because the

Census data provided dollars spent by on- and off-highway fuel use, for the purpose of

this calculation the emission estimates were based on the assumption that all off-highway

fuel use was diesel and all on-highway use was motor gasoline.

 Trend data using this method are not currently available.

Table 6 presents the 2002 CO2 emissions in units of teragrams of CO2 equivalent (Tg CO2 Eq.).

Table 6: Carbon Dioxide Emissions from Construction, 2002

Source Emissions, Tg CO2 Eq.

Fossil Fuel Combustion 84.7

Electricity 29.4

Total 114.1
Trend in Greenhouse Gas Emissions from Nonroad Construction Equipment. The 

Inventory of U.S. Greenhouse Gas Emissions and Sinks is published annually by EPA’s Office of 

Atmospheric Program’s Climate Change Division, to fulfill obligations stemming from the 

United Nations Framework Convention on Climate Change. The Inventory reports GHG 

emissions and sinks in the U.S. across multiple sources. Data specific to construction equipment 

are included for three greenhouse gases—carbon dioxide (CO2), methane (CH4), and nitrous 

oxide (N2O) —and for total greenhouse gas emissions. These data include emissions resulting 

from gasoline and diesel fuel combustion by mobile construction equipment. Note that mobile 

construction equipment is defined in the Inventory as including both mobile construction and 

mining equipment. This report is published annually and could allow tracking of trends over 

time; however, it is focused on emissions resulting from non-road mobile sources, and does not 

include energy use associated with other aspects of construction such as electricity use and 

transport of materials to sites. 

Annual GHG data specific to construction equipment are presented in Figure 14 in carbon 

dioxide equivalents with units of teragrams of CO2 equivalent (Tg CO2 Eq.). This measure uses 

global warming potential of each gas relative to CO2. In 2005, these emissions represented 

0.91% of the U.S. total anthropogenic GHG emissions.

46 

Figure 14: Greenhouse Gas Emissions from 

Nonroad Construction Equipment* 

0 

20 

40 

60 

80 

2000 2001 2002 2003 2004 2005 

Year 

Tg 

C

O2 E

q. 

Emissions (Absolute) Emissions (Normalized)** 

* Includes emissions from both construction and mining nonroad mobile equipment. 

** Normalized based on national value of construction put in place from U.S. Census Bureau. 

Note: Includes CO2, CH4, and N2O emissions. 

Source: U.S. EPA, Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 – 2005, EPA 430-R07-002, Annex Table A-108, published April 2007. U.S. Census Bureau, Construction Spending 

(Value Put in Place), normalized based on national value of construction put in place (including private 

and public; residential and nonresidential) to a 2000 baseline year in 2000 dollars. 

September 2007 Page 36 
Fuel Used by Construction Equipment. Fuel oil sales data are available from the U.S. Energy 

Information Administration (EIA) of the U.S. Department of Energy (DOE), in the Fuel Oil and 

Kerosene Sales report.

47 This report includes data on annual off-highway distillate fuel oil sales 

for the construction industry, which is defined to consist of all facilities and equipment including 

earthmoving equipment, cranes, generators, air compressors, etc. EIA defines distillate fuel as 

the petroleum fractions produced in conventional distillation operations including No. 1, No. 2, 

and No. 4 fuel oils and diesel fuels.

48 EIA data are collected through surveys at the point of 

delivery or use, and are aggregated to determine national totals. This report is published annually 

and could allow tracking of trends over time; however, it is focused on off-highway distillate fuel 

use, and does not include energy use associated with other aspects of construction such as 

electricity use and transport of materials to sites. As an environmental measure, fuel sales could 

indicate trends in air emissions related to fuel consumption, as shown in Figure 15. 

Figure 15: Sales of Off-Highway Distillate Fuel Oil for 

Construction 

0 

500 

1,000 

1,500 

2,000 

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 

Year 

G

allo

n

s, millio

n

s* 

* Normalized based on national value of construction put in place from U.S. Census Bureau. 

Source: Energy Information Administration, Fuel Oil and Kerosene Sales reports 1995-2005, Table 24. 

http://www.eia.doe.gov/oil_gas/petroleum/data_publications/fuel_oil_and_kerosene_sales/foks_historic 

al.html and U.S. Census Bureau, Construction Spending (Value Put in Place), normalized based on 

national value of construction put in place (including private and public; residential and nonresidential) 

to a 1995 baseline year in 1995 dollars. 

September 2007 Page 37 
Appendix: State Sampling Approach for NOIs 

For a given calendar year, the submission of NOIs takes place at the state level, except for five 

states where the NOIs are submitted to EPA. It is expected that most states store the NOIs in an 

electronic format, but we do not currently know which specific states store the NOIs in hard 

copy format. Therefore, in the sampling approach discussed below we assume that all states and 

the District of Columbia are eligible for sample selection. 

The specific sampling method that will be employed is called one-stage cluster sampling. In onestage cluster sampling a sample of states (primary sampling units (PSU)) is drawn at the first 

stage of sampling. All NOIs for a given calendar year associated with each sample state (PSU) 

are then included in the sample of NOIs. Sampling variability is increased compared to a simple 

random sample of the same sample size of NOIs. A simple random sample of NOIs is however 

not possible, because a complete sampling frame of all NOIs in the U.S. cannot be assembled. 

The sample of NOIs will be used in conjunction with state level and national data on the value of 

construction (from the U.S. Census Bureau’s 2002 Economic Census) to examine year-to-year 

changes in the total number of NOIs. The use of a ratio estimator may be appropriate for 

examining change over time in the total number of NOIs in relation to the total value of 

construction. Sampling weights will be needed to adjust for unequal sampling probabilities. 

Alaska, New Hampshire, Idaho, New Mexico, and Massachusetts are the five states for which 

the EPA directly collects NOIs. The completeness and quality of the NOIs for these states makes 

it advisable to include all of them in the state sample. These states however account for only 

3.6% of the national total value of construction in 2006. 

For the remaining 46 states and DC, a probability proportional to size (PPS) sample will be 

drawn. The measure of size for the PPS sample will be the total value of construction in 2006. 

We prefer to use the total number of NOIs, but this is not available for all states. In PPS 

sampling the largest states will be selected with certainty. We examined the size distribution of 

the states and determined that the three largest states account for 29.3% of the national total 

value of construction in 2006. The following three states will therefore be included in the sample 

with certainty: California, Florida, and Texas. 

The remaining state sampling frame consists of 43 states. The sampling frame will be sorted by 

EPA region. A systematic PPS sample of 12 noncertainty states will then be drawn using value 

of construction in 2006 as the measure of size. This sampling approach will make it possible to 

estimate standard errors using a paired PSU variance estimation technique. We have used the 

current sampling frame to draw the sample of 12 states: Connecticut, New York, Pennsylvania, 

Alabama, Kentucky, South Carolina, Illinois, Minnesota, Arkansas, Missouri, Utah, and Nevada. 

The entire sample consists of 20 states. 

September 2007 Page 38 
Endnotes 

1 http://www.census.gov/const/C30/statead.pdf 

2 http://www.census.gov/const/www/C40/table2.html#annual 

3 https://www.usgbc.org/ShowFile.aspx?DocumentID=1095 (accessed Dec 2006) 

4 http://www.usgbc.org/LEED/AP/ViewAll.aspx?CMSPageID=280& (accessed Nov 2006) 5 http://spc189.ashraepcs.org/index.html 

6 http://www.nahb.org/fileUpload_details.aspx?contentTypeID=7&contentID=1994 

7 http://www.nahb.org/publication_details.aspx?publicationID=1994§ionID=155 

8 USGBC LEED-NC: Green Building Rating System for New Construction & Major Renovations. 

Version 2.2 Oct 2005. https://www.usgbc.org/ShowFile.aspx?DocumentID=1095 

9 Miller, K. Forest Stewardship Council, Washington, DC. Personal communication, Dec 2006. 10 Targeted Statewide Waste Characterization Study: Detailed Characterization of Construction and 

Demolition Waste, June 2006. http://www.ciwmb.ca.gov/Publications/default.asp?pubid=1185 

11 The State of Construction and Demolition Debris Recycling in Florida Report – 2001. 

http://www.dep.state.fl.us/waste/categories/recycling/pages/canddreport.htm 

12 Iowa Construction and Demolition Debris Recycling. 

http://www.iowadnr.com/waste/recycling/cndiowa.html 

13 Solid Waste Management in Maryland, Sept 2006. 

http://www.mde.state.md.us/assets/document/SW_Managed_in_MD_Report_CY_2005.pdf 

14 The Missouri Solid Waste Composition Study, 1999. http://www.mapinc.org/Publications/Publications/Waste Composition.pdf 

15 Solid Waste Managed in Virginia During Calendar Year 2005, June 2006. 

http://www.deq.state.va.us/waste/pdf/swreport2005.pdf 16 Personal communications with Abt Associates Inc. and: David Lancher, New York DEC; Matthew 

Hittle and Michelle Kenton, Ohio EPA; Peter Spendolo, Oregon DEQ; Washington Dept. of Natural 

Resources; Becky Jolly, Iowa DNR; Missouri DNR; Cynthia Moore, Wisconsin DNR; Connecticut 

DEP; and Texas Commission on Environmental Quality. 2007. 17 http://www.mde.state.md.us/Programs/LandPrograms/Recycling/publications/index.asp - recycling 18 http://www.dep.state.fl.us/waste/categories/recycling/pages/03_data.htm 19 MA Department of Environmental Protection (MA DEP). 2004. 3rd Annual Progress Report on the 

Beyond 2000 Solid Waste Master Plan. Sept 2004. 20 MA Department of Environmental Protection (MA DEP). 2006. Solid Waste Master Plan: 2006 

Revision. June 2006. 21 Solid Waste Managed in Virginia During Calendar Year 2005, June 2006. 

http://www.deq.state.va.us/waste/pdf/swreport2005.pdf 22 Washington Department of Ecology. 2006. Solid Waste in Washington State: Fifteenth Annual Status 

Report. December 2006. http://www.ecy.wa.gov/programs/swfa/solidwastedata/ 

23 U.S. EPA, Municipal and Industrial Solid Waste Division, Office of Solid Waste. Characterization of 

Building-Related Construction and Demolition Debris Materials in the United States (DRAFT), July 

2006. Final document expected in 2007. 24 Ibid. 25 Cochran, Kim, EPA Office of Solid Waste, comment submitted on the January 12, 2007 draft version of 

this Report 

September 2007 Page 39 
26 U.S. EPA, Municipal and Industrial Solid Waste Division, Office of Solid Waste. Characterization of 

Road and Bridge Related Construction and Demolition Debris Materials in the United States (DRAFT), 

Oct 2005. 27 Ibid. 28 Construction Materials Recycling Association (CMRA). 2004. CMRA Member Survey Evaluation & 

Extension to US C&D Marketplace. 29 National Demolition Association (NDA). 2005. Status of NDA Demolition Debris Generation and 

Recycling Survey Evaluation. 30 Personal communication with Mike Taylor, National Demolition Association. May 2007. 31 http://www.mde.state.md.us/Programs/LandPrograms/Recycling/publications/index.asp - recycling 32 http://www.dep.state.fl.us/waste/categories/recycling/pages/03_data.htm 33 MA Department of Environmental Protection (MA DEP). 2004. 3rd Annual Progress Report on the 

Beyond 2000 Solid Waste Master Plan. Sept 2004. 34 MA Department of Environmental Protection (MA DEP). 2006. Solid Waste Master Plan: 2006 

Revision. June 2006. 35 Solid Waste Managed in Virginia During Calendar Year 2005, June 2006. 

http://www.deq.state.va.us/waste/pdf/swreport2005.pdf 36 Washington Department of Ecology. 2006. Solid Waste in Washington State: Fifteenth Annual Status 

Report. December 2006. http://www.ecy.wa.gov/programs/swfa/solidwastedata/ 

37 http://www.tceq.state.tx.us/implementation/air/terp/ 

38 http://www.arb.ca.gov/msprog/moyer/moyer.htm 

39 Telephone conversation between Abt Associates Inc. and Steve Dayton, TERP, September 22, 2004. 40 California Air Resources Board. The Carl Moyer Program 2006 Status Report. January 2007. 

http://www.arb.ca.gov/msprog/moyer/status/2006status_report.pdf 41 Email from Nikos Singelis. EPA Office of Water, Water Permits Division. December 15, 2006. 42 EPA’s Economic Analysis of the Final Phase II Storm Water Rule. October 1999. page 3-7. 43 Ibid. 44 Telephone conservation between Abt Associates Inc. and Nikos Singelis and Rachel Herbert, EPA 

Office of Water, Water Permits Division, December 21, 2006. 45 U.S. EPA. Sector Strategies Greenhouse Gas Emissions: Preliminary Analysis. June 2007. Prepared by 

ICF Consulting. 46 U.S. EPA. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 – 2005. EPA 430-R-07-002. 

Table 2-14 and Annex Table A-108. April 2007. 47 U.S. DOE, Energy Information Administration. Fuel Oil and Kerosene Sales reports 1995-2005. 

Table 24. http://www.eia.doe.gov/oil_gas/petroleum/data_publications/fuel_oil_and_kerosene_sales. 48 U.S. DOE, Energy Information Administration. http://www.eia.doe.gov/glossary/glossary_d.htm 

September 2007 Page 40