Reducing Our Carbon Footprint

Implementing The Inflation Reduction Act

FEMA Public Assistance Staff | October 2023
Opening Remarks 
Federal Emergency Management Agency

Agenda

• Overview of Public Assistance and Low-Carbon Materials

• External Resources

• Carbon Leadership Forum

• Building Transparency

• Frequently Asked Questions

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Federal Emergency Management Agency

Key Messages 

• The Inflation Reduction Act (IRA) authorizes the Robert T. Stafford Disaster Recovery

and Emergency Act to provide financial assistance for costs associated with lowcarbon building or construction materials.

• The use of low-carbon materials is voluntary and based on Applicant discretion.

• Terminology around climate resilience may be new to FEMA staff. There are many

resources available to support learning about this topic.

• These authorities are applicable to disasters declared on or after May 22, 2023.

• Inclusion of low-carbon materials in projects does not affect the federal cost share

percentage for the project.

• FEMA PA staff are not expected to be technical experts in low-carbon materials

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Inflation Reduction Act (IRA) Law and Policy
Federal Emergency Management Agency

Inflation Reduction Act (IRA) Overview 

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• Signed into law on August 16, 2022, the Inflation Reduction Act (IRA) provides a total

of $370 billion across Federal agencies to address clean energy and climate change.

• Section 70006 of the IRA provides FEMA the authority to fund low-carbon materials for

three FEMA programs:

o Public Assistance (PA)

o Hazard Mitigation Grant Program (HMGP)

o Building Resilient Infrastructure and Communities (BRIC)

• Authority to fund low-carbon material exists through September 30, 2026.
Federal Emergency Management Agency

Inflation Reduction Act (IRA) Implementation Memo

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• The Implementation Memo for IRA Section 70006(1) for Public Assistance and Hazard

Mitigation Assistance programs was issued March 21, 2023

• Memo highlights include:

o Identifying that the memo applies to disasters declared on or after May 22, 2023

o Highlighting that the use of low-carbon materials is voluntary and based on Applicant

discretion

o Increased costs for low-carbon materials are deemed reasonable under cost principles

o Identifying that FEMA will fund four low-carbon materials: concrete, asphalt, glass, steel
Inflation Reduction Act (IRA) Implementation 
Federal Emergency Management Agency

IRA Implementation Overview

• FEMA PDMGs and Field Leadership will provide Recipients and Applicants information

on potential eligibility of low-carbon materials for use in their projects.

• Applicants may elect to use low-carbon materials in their permanent work projects.

• If an Applicant elects to use low-carbon materials, those materials will be identified in

the project scope of work.

• CRC staff will validate costs or develop the scope of work and estimate costs that

include low-carbon materials.

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Federal Emergency Management Agency

Field Leadership Responsibilities

• We need to support the recovery priorities of our SLTT partners. This includes

encouraging them to utilize all available funding sources, including resilience funding,

to achieve their priorities.

• Coordinate with Recipients to provide content for the Applicant’s Briefing, including

information about the Inflation Reduction Act (IRA). This may include slides or a onepage hand out.

• Field Leadership need to establish consistent messaging regarding the low-carbon

materials for their PDMGs to deliver to their Applicants.

o Talking points will be provided by Field Leadership and passed down through chain of

command to the PDMGs so there is consistent messaging being delivered to the

Applicants.

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Federal Emergency Management Agency

IRA Implementation by Phase 

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Federal Emergency Management Agency

Program Delivery Manager Responsibilities (1 of 2)

List of Impacts Through Recovery Scoping Meeting (RSM)

During the RSM, the PDMG will:

• Provide information on the IRA

initiative

• Provide the Applicant with a

hand-out detailing how the

Applicant can learn more about

and take advantage of eligible

low-carbon materials (concrete,

asphalt, glass, and steel) in their

recovery efforts

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Federal Emergency Management Agency

Program Delivery Manager Responsibilities (2 of 2)

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The PDMG will also:

• Ensure Applicant adds comment at the project level that indicates they will use lowcarbon materials or add the comment if the Applicant is unable to.

o When adding a comment indicating that an Applicant is electing to use low-carbon

materials include as much information as possible. (see examples on next slide)

• During regular weekly follow up meetings with the Applicant, address any questions or

concerns with low-carbon materials

• PDMGs should follow normal procedures to formulate projects and continue to process

them to the CRC for review.

• PDMGs will add the Policy Issue “IRA 70006, Low-Carbon Materials” at the damage

line item where low-carbon materials are being claimed.
Federal Emergency Management Agency

Applicant Responsibilities 

• The Applicant should determine whether they will

use low-carbon materials in their PA projects.

o When determining the method of restoration,

the Applicant can estimate the cost of the lowcarbon materials. This estimate will be used as

part of their scope of work. If the Applicant

prefers, CRC staff will develop scope of work

and cost.

• The Applicant should add a comment at the

project level that indicates they will use lowcarbon materials.

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Federal Emergency Management Agency

• Coordinate with FEMA field leadership to establish priorities for low-carbon materials

• Consider adding low-carbon material content to Applicants Briefings

• Support applicants in decision making around low-carbon materials and in gathering

documentation

Recipient Responsibilities 

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Federal Emergency Management Agency

CRC Responsibilities

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• There may be higher costs for low-carbon

concrete, asphalt, glass, and steel, compared

to traditional materials.

• CRCs should follow normal procedures for

processing projects:

o For work completed, CRC will validate scope,

work, and cost, and reflect inclusion of lowcarbon materials.

o For work to be completed, site inspection and

DDD are complete, CRC will write the scope of

work, cost, and reflect inclusion of low-carbon

materials

o Verify that a material is a low-carbon material

based upon the Environmental Product

Declaration (EPD) information using a tool

such as the Building Transparency EC3 Tool.
Carbon Leadership Forum 
© Copyright 2023, Carbon Leadership Forum

What are low-carbon 

materials?
© Copyright 2023, Carbon Leadership Forum

Emissions are released during the life cycle of construction materials
© Copyright 2023, Carbon Leadership Forum

What makes manufacturing lower carbon?

Every construction material is made 

differently, so each requires different strategies 

to produce low carbon materials. 

• Energy efficient manufacturing processes

• Switching to cleaner fuels and power 

sources

• Lower-carbon ingredients (e.g. recycled, 

waste byproducts, bio-based)

Image Sources: pexels.com
© Copyright 2023, Carbon Leadership Forum

Environmental Product Declarations (EPDs) Disclose the 

Embodied Carbon of a Product

Source: Fueleconomy.gov

Source: FHWA.dot.gov/everydaycounts
© Copyright 2023, Carbon Leadership Forum

EPDs are used to demonstrate whether a product is low carbon

▪ Per the Environmental Protection Agency (EPA)’s definition, concrete, asphalt, glass, and 

steel products can qualify as low-carbon materials if they have a Global Warming Potential 

(GWP) lower than the estimated industry average for similar products in North America as 

demonstrated by their Environmental Product Declaration (EPD). 

▪ This means that low-carbon concrete, asphalt, glass, and steel products used on FEMA 

projects will need an third-party verified EPD to prove that they are low carbon. 
© Copyright 2023, Carbon Leadership Forum

Why should you use lowcarbon materials on your 

project?
© Copyright 2023, Carbon Leadership Forum

Global greenhouse 

gas emissions and 

the life cycle of 

buildings

Embodied carbon is significant
© Copyright 2023, Carbon Leadership Forum

Particulate 

matter (PM)

Ozone (O3)

Diesel 

PM

Emissions from the life cycle of materials have negative health 

and environmental impacts on communities

Global Impacts from 

Climate Change

Regional/Local Impacts 

on Health and 

Environment

GHG
© Copyright 2023, Carbon Leadership Forum

Design and construction is the only chance we have to reduce 

embodied carbon

Image Sources: pexels.com
© Copyright 2023, Carbon Leadership Forum

Sourcing low carbon materials is urgent
© Copyright 2023, Carbon Leadership Forum

Low-Carbon Materials: 

Frequently Asked Questions
© Copyright 2023, Carbon Leadership Forum

Q: What if a manufacturer doesn’t have an EPD?

While there are thousands of environmental product declarations (EPDs) available already for 

construction products, availability is lower for some regions, and not all products with EPDs are 

low carbon.

▪ Manufacturers can get an EPD relatively quickly (i.e. months, not years). This varies by 

material. A growing number of tools are available to speed up this process.

▪ The EPA has announced the first $100 million of Inflation Reduction Act funded grants aimed 

at funding development of more EPDs. Once these grant programs launch, project teams 

can encourage manufacturers to get EPDs for free through these IRA-funded programs.
© Copyright 2023, Carbon Leadership Forum

Q: Are low-carbon materials new, untested materials?

▪ Many low carbon materials have been available for a long time, but may require

manufacturers to invest in facility upgrades or keep more ingredients on-hand (like keeping

many cement alternatives on-hand at a concrete supply facility).

▪ Some low carbon materials are already available, but without requiring transparency (via an

environmental product declaration (EPD)), a purchaser won’t be able to identify or request

them.

▪ Some materials do include newer technologies or ingredients. However, they are required

to meet the same performance standards / functional requirements as their more polluting

competitors.
© Copyright 2023, Carbon Leadership Forum

Q: Will low-carbon construction materials alter the construction 

schedule?

▪ Coordination between the contractor, engineer, and architect are crucial to limit any 

schedule impacts.

▪ Lower-carbon concrete and asphalt products may use a different mix design than a 

traditional product. Some of these may take longer to cure. Supplier, contractor, and 

engineer can coordinate on which components can allow for longer curing in the 

construction schedule.

▪ Performance-based specifications (e.g. specifying strength and other performance 

requirements, not ingredients) can help
© Copyright 2023, Carbon Leadership Forum

Q: Are low-carbon construction materials more expensive?

▪ Savings or costs for reducing carbon vary by the material and by the size and complexity of 

the project, the geographic location (which can have a large impact on availability of 

products and feasibility of certain design strategies), and the experience of the architect, 

engineer, and contractor.

▪ Potential savings may come from dematerialization, meaning less material is used to 

achieve the same function, or from reducing the use of some of the higher cost ingredients 

for a product, such as Portland Cement.

▪ In some cases, lower carbon materials are cheaper. The table on the bottom shows an 

example of how three cement replacement options, all cheaper than cement, vary in price 

primarily due to transportation distance.

Source: RMI’s Concrete Solutions 

Guide
© Copyright 2023, Carbon Leadership Forum

Steel reinforced concrete slab Wood-framing with concrete Tilt-Up concrete

slab

Cradle-to-gate embodied carbon reductions:

46% 41% 19%

RMI Case Study Analysis

Embodied Carbon Reductions
© Copyright 2023, Carbon Leadership Forum

Key Findings:

• Optimizing the ready-mix concrete design can lead to 

significant embodied carbon reductions at no cost

• Rebar with high recycled content coming from efficient mills, 

electric arc furnaces, and clean electrical grids can have dramatic 

impacts at a small cost premium

• Glazing remains a critical challenge for reducing embodied carbon

• Insulation material selection can drive project-level embodied 

carbon, depending on baseline type and quantity

• Finish materials can serve as a key carbon-reduction or carbonstorage opportunity

RMI Case Study Analysis

Embodied Carbon Reductions
Building Transparency 
About Building Transparency

Building Transparency's core mission is to provide open access data and tools 

necessary to enable broad and swift action across the building industry in 

addressing embodied carbon's role in climate change.

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Embodied Carbon in Construction Calculator

Washington State 501c(3) nonprofit dedicated to sustainability in construction.

Free to use | Open access

Upfront Carbon Assessment Tool

tallyLCA

Revit plugin | Design-focused

Whole-Building LCA Tool

tallyCAT

Revit plugin | Design-focused

Upfront Carbon Assessment Tool
Lead Sponsors

Pilot Sponsors

Association Sponsors Manufacturer Sponsors Technology Partners

Autodesk Mitacs

Azure Mindful Materials

Climate Earth Sustainable Minds

Kieran Timberlake

Partners & Sponsors
Life Cycle Stages

Upfront Carbon:

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Product

70%

Construction

5%

Use

20%

End-of-life

5%
The Embodied Carbon in 

Construction Calculator

EC3 
Growing EPD 

Database of 3rd party 

verified EPDs

Find & Compare 

Materials Function

Plan & Compare 

Buildings Function

The EC3 tool = An open access database of digitized EPDs and a project planner
FEMA Filter Demo

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Register for a Free Account at buildingtransparency.org

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Find Compliant Product EPDs

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Once you are logged in to EC3, click “Find and Compare 

Materials” located in the top left corner of the screen, just 

below the EC3 logo.
Find Compliant Product EPDs

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Find Compliant Product EPDs

46
Find Compliant Product EPDs

47
Find Compliant Product EPDs

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Download EPD

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What if I can’t find the EPD for a product used on my project?

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How to add an EPD to EC3

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Questions? 

Katie.poss@buildingtransparency.org
Planning and Implementation Resources 
Federal Emergency Management Agency

Internal Resources (1 of 2)

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• Implementation Memo for IRA Section 70006(1) – The memo from Dr. Forbes announces

FEMA’s implementation of IRA Section 70006 under PA. The memo explains PA’s

responsibilities under the IRA and includes definitions that relate to the IRA.

• 2022-2026 FEMA Strategic Plan – The Strategic Plan highlights FEMA’s commitment to

climate resiliency. Goal 2, Lead Whole of Community in Climate Resilience, focuses on this

commitment and provides guidance for FEMA staff on climate issues being addressed by

FEMA.

• FEMA Resources for Climate Resilience - This document offers a description of available

FEMA resources to be used in planning for, response to, recovery from, and mitigation

against the adverse impacts of climate change.
Federal Emergency Management Agency

Internal Resources (2 of 2)

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• FEMA and the Changing Climate The enclosed messages are key to building a climate literate

FEMA workforce. These foundational messages complement existing programmatic outreach and

will inform FEMA staff of climate related talking points.

• FEMA Climate Foundational Messaging - This fact sheet provides topline messaging on climate

change from the unique FEMA emergency management perspective.

• 2022 National Preparedness Report - This report presents preparedness data and underscores the

challenges that emergency managers face in addressing a continuously expanding risk

environment triggered by climate issues. Emergency managers can look to this report to help

support decisions about program priorities, resource allocations and community actions.

• Building a Clean, Climate-Resilient Economy through FEMA’s Grant Programs | FEMA.gov –

Webpage which outlines FEMA’s low-carbon materials funding initiatives under IRA Section 70006

and how they support the Federal Buy Clean Initiative.
Frequently Asked Questions
Federal Emergency Management Agency

Frequently Asked Questions (1 of 2) 

Am I expected to become an expert on low-carbon materials? 

No, FEMA PA staff are NOT technical experts on low-carbon materials, and we do not 

expect FEMA PA staff to become technical experts. In support of IRA Implementation, 

FEMA staff will provide information on services and materials available through the PA 

process to assist Applicants in their climate resiliency efforts. This includes ensuring 

applicants have access to all Low Carbon Materials Resources, links, and information 

(through the 1 pager). The terminology around climate may be new to FEMA staff. 

There are many resources available to support learning about this topic.

Will there be changes to GM due to the Inflation Reduction Act implementation? 

A policy flag has been added to Grants Manager for the PDMG to add to the damage 

line item where low-carbon materials are being claimed.

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Federal Emergency Management Agency

Frequently Asked Questions (2 of 2) 

Will we be receiving further training on IRA or low-carbon materials?

If there are any other changes or implementations to IRA Section 7006 that affect 

FEMA PA additional information will be provided at that time. 

FEMA PA field leadership is looking into providing event specific IRA Section 7006 

training opportunities, you will be notified by your leadership if and when these occur.

I still have questions about the IRA, low-carbon materials, or how this changes what I am 

supposed to do. Who can I ask? 

If you still have additional questions after reviewing the materials, and additional 

resources that were provided ask your leadership as its possible others may have the 

same questions. Or you can email the mailbox on the next slide. 

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Contact Information for IRA Implementation

FEMA-IRA-Implementation@fema.dhs.gov