NAPA comments on EPA’s Draft Low Embodied Carbon Label Program PCR Criteria
NAPA continues to engage with the Environmental Protection Agency (EPA) on the agency’s proposed low carbon construction material labeling program.
NAPA provided draft criteria for the Product Category Rules (PCR) for the low carbon label program in an April 4 letter to Deputy Assistant Administrator Jennie Romer at the EPA’s Office of Chemical Safety and Pollution Prevention.
NAPA previously provided comments on the EPA’s Label Program for Low Embodied Carbon Construction Materials on March 18.
“While NAPA is the trade association for the asphalt paving industry, it also serves as the Program
Operator for the Product Category Rule (PCR) for Asphalt Mixtures in North America,” the April 4 letter reads. “As Program Operator, NAPA ensures that its PCR and environmental product declarations (EPDs) for asphalt mixtures are compliant with the latest standards.”
The eight-page letter outlines three general suggestions and additional comments specific to the criteria. NAPA suggests the PCR criteria be published as an interim set of requirements, to begin with, and also encourages the EPA to be diligent in protecting confidential business information and trade secrets.
The letter, developed by a task force representing NAPA’s Sustainability and PCR Committees and led by NAPA Sustainable Pavements Director Joseph Shacat, also suggests the implementation timelines create a “moving target” that may be difficult to achieve.
“Depending on the date that such datasets are finalized, program operators may have very little time to adopt these new datasets within the specified time frame,” Shacat writes.
