Introduction and summary
The materials at the bedrock of the United States’ infrastructure and economy—such as cement, iron, and steel—contribute significantly to today’s climate crisis. The industrial sector accounts for nearly one-third of annual greenhouse gas (GHG) emissions in the United States, and the manufacturing of construction materials and products is responsible for 15 percent of global GHG emissions annually.1 Industrial facilities also emit criteria air pollutants and toxic air pollutants that present health risks for communities in the surrounding area.2 Rooted in the legacy of redlining, communities of color are disproportionately burdened by pollution from industrial facilities.3 After years of inaction, federal focus finally began to shift to industrial decarbonization through the Inflation Reduction Act (IRA) and the Infrastructure Investment and Jobs Act (IIJA), yet industrial subsector emissions are still either increasing or staying flat.4 By 2035, the industrial sector is expected to be the highest-emitting sector of GHGs in the United States, overtaking both transportation and power.5 To avoid the worst impacts of climate change, safeguard public health, and ensure high-quality manufacturing jobs, immediate action is needed across all levels of government. Federal inaction or reversals on climate and clean energy make it especially important for states to take the lead.
States have historically pioneered ambitious policies that have helped inform and inspire federal action, particularly in the power, transportation, and buildings sectors.6 The industrial sector too is in urgent need of bold, innovative policy action that reduces and strives to eliminate GHGs and harmful air pollutants. States have an opportunity to lead in charting this path forward, as well as a responsibility to implement policies that consider the unique needs of their communities.
The industrial sector is far from uniform and requires subsector-specific solutions to sufficiently achieve comprehensive emissions reduction across GHGs and toxic air pollutants. The most emission-intensive industrial subsectors include construction materials such as cement, glass, aluminum, iron, and steel, and other subsectors such as chemical and petrochemical manufacturing, food and beverages, and forest products.7 Given construction materials’ large-scale utility across society without existing substitutes, this report focuses on solutions to transform how construction materials—particularly mineral- and metal-based products—are produced to reduce emissions. It does not focus on industries for which overproduction is at the core of the issue, such as single-use plastics or on petrochemical-based building materials.8 This report also focuses primarily on solutions to air pollution, though it should be noted that the industrial sector is also responsible for significant water pollution and hazardous waste.9
This report highlights the importance of emission-reducing policies that target the manufacturing of key high-emission industrial products, with a focus on construction and building materials, and reviews existing state policies to better understand lessons from which other state and federal policymakers can learn. Based on these examples, states, especially high emitters in these sectors, should consider adopting the following policies to strengthen the resilience of their industrial facilities and improve public health:
- Set binding statutory targets and/or create cap-and-invest programs for industrial greenhouse gas reductions that are on track to reach net-zero emissions by 2050.
- Reinvest revenue from emission reduction programs into decarbonization efforts as well as solutions that benefit the communities most affected by air pollution.
- Establish grant programs and tax incentives for industrial facilities to alleviate the costs associated with developing and implementing decarbonization and air pollution reduction technologies.
- Implement green public procurement programs such as Buy Clean to ensure demand for low-GHG emission construction materials and establish emission reporting requirements for products or facilities.
- Pair decarbonization policies with additional air pollution programs and environmental justice (EJ) provisions.
- Prohibit permits for new or expanding industrial facilities that would increase the air pollution burden of underserved communities.
- Mandate the reduction of harmful air toxics from existing facilities located in overburdened communities.
- Pair all standards and incentives with policies that ensure the production of low-embodied carbon materials is creating and maintaining high-quality, union jobs.
Background
The production of building materials emits climate change-causing GHG emissions, as well as co-pollutants that are harmful to public health. The following sections compare air emissions from several metal and mineral construction material industries, both nationally and by state.
Industrial greenhouse gas emissions
National and global trends
In 2022 the industrial sector was the second-largest contributor of GHG emissions of any U.S. economic sector, responsible for 30 percent of direct and indirect domestic GHG emissions. The direct emissions from the sector—process emissions in manufacturing, emissions from burning fuel for power or heat, and leaks from equipment—accounted for 78 percent of the sector’s total emissions. The remaining 22 percent was from indirect emissions, such as those emitted to produce the electricity that powers industrial facilities and machinery.10
Globally, GHG emissions from the industrial sector have risen dramatically and faster than any other sector, with a 70 percent increase since 1990.11 This industrial expansion and increase in demand for industrial products can be attributed to population growth and urbanization, as well as rising income levels.12 However, the United States has seen a nearly 16 percent decrease in the same time frame.13 Building and construction materials, which account for about one-fourth of the industrial sector, have seen an even steeper decline (down 19 percent since 2005) than the sector as a whole (down 8.5 percent since 2005).14
Yet despite the decrease in emissions nationally, industrial sector emissions are projected to rise in the coming years. Rhodium Group predicts industry GHG emissions in the United States will increase as much as 12 percent above 2022 levels by 2035, outpacing transportation as the highest-emitting sector.15 A rise in production from the chemical industry is expected to drive much of the industry growth, while direct emissions from the cement and concrete and iron and steel industries would likely stay relatively flat.16 Given the large impact of these heavy industries and the deep decarbonization needed to limit warming to 1.5 degrees Celsius, emissions staying constant is insufficient.
Of the commonly used building materials, the mineral and metal industries encompass some of the highest-emitting yet essential products. Concrete, usually made from cement, is the second-most widely used material in the world after water.17 Lime is extremely versatile and is used across environmental and chemical applications, as well as in steel manufacturing, soil stabilization for roads, and as an additive to asphalt.18 More than 1 billion tons of steel are produced every year to be used across the buildings, transportation, appliance, and energy infrastructure industries.19 All of these products are also large GHG emitters, as shown in Figure 1.
State trends
The makeup of industrial production varies drastically across states, and each has a different set of emission-reduction challenges. The majority of GHG emissions for iron and steel production nationwide comes from just two states: Indiana (26.7 million metric tons of carbon dioxide equivalent, or CO2e) and Ohio (9.9 million metric tons CO2e).20 While the iron/steel and cement/concrete industries emit relatively similar amounts of GHGs nationwide—61 million and 68 million metric tons CO2e, respectively—the cement industry is distributed more evenly across states. For the industries displayed in Figure 2—cement and concrete; iron and steel; lime; glass; and aluminum—Indiana is in the top 10 for GHG emissions in all five, and Texas is a top-10 emitter for all but the aluminum industry. Alabama, Michigan, Ohio, Pennsylvania, and Missouri are all top-10 emitters for three of the five industries.21
Industrial co-pollutant emissions
Criteria air pollutants
In addition to greenhouse gas emissions, the industrial sector emits all six criteria air pollutants and numerous hazardous air pollutants that are detrimental to human health.22 The criteria air pollutants include particulate matter (both PM2.5 primary and PM10 primary), sulfur dioxide, nitrogen dioxide, and nonmethane volatile organic compounds, which are ground-level ozone precursors. These pollutants create adverse health effects ranging from respiratory symptoms to premature mortality and pose serious health risks to surrounding communities.23 These pollutants—and their health impacts—are concentrated in communities of color and in low-income communities.24
Across all of the U.S. facilities in the selected building material-related industries, iron and steel had the highest total criteria air pollutant emissions even though the subcategory is only 7 percent of the total number of facilities included. PM2.5, while not the most abundant criteria air pollutant, is particularly harmful to health, especially in neighboring communities, due to its small size and ability to penetrate deep into the lungs and enter the bloodstream.25 Even low-level exposure to these fine particles is found to increase mortality at alarming rates.26 Eliminating PM2.5 emissions and its precursors in iron, metallurgical coke (used to produce iron), steel, cement, and aluminum production could avoid up to 2,830 deaths per year, 70 percent of which are a result of iron and steel manufacturing.27 PM2.5 emissions exposure also disproportionately affects communities of color, largely driven by industrial sources.28
Figure 4 shows the 10 states with the highest amounts of PM2.5 emissions from building material-related industries. Indiana has the highest emissions from fine particulate matter, with most of the emissions coming from the iron and steel industry.
Hazardous air pollutants
The production of mineral and metal sector building materials emits hazardous air pollutants, also referred to as air toxics. Air toxics include known cancer-causing chemicals and contribute to respiratory, cardiovascular, reproductive, and other diseases.29 More than 130 hazardous air pollutants were emitted across the selected subsectors, summed together from all the U.S. facilities shown in Figure 5. The largest emissions from the selected industry subgroups were hydrochloric acid, chlorine, and hydrogen fluoride, although many of the other chemicals can have severe consequences on surrounding communities even in small doses.
Millions of pounds of carcinogens are released into the air from industrial facilities annually and are felt disproportionately by Black, Hispanic, and Latino Americans, as well as in low-income neighborhoods.30 Black Americans are 10 percent to 20 percent more likely to live in census tracts with exposure to the highest levels of industrial emissions from the cancer-causing substances benzene, 1,3-butadiene, ethylene oxide, formaldehyde, trichloroethylene, and nickel, while Hispanic and Latino Americans face a 16 percent to 21 percent higher likelihood of exposure to benzene, 1,3-butadiene, and ethylene oxide.31 In addition, exposure to air toxics from the cement industry is almost 50 percent higher for low-income Black Americans than low-income white Americans.32 Health impacts from these air pollutants are putting affected communities at risk at alarming rates, and industry-specific actions are necessary to reduce these environmental injustices.
Figure 6 highlights hazardous air pollutant emissions from the selected subsectors in the 10 states with the highest air toxics emissions by weight. For these 10 states, within building material-related industries, metal industry facilities including aluminum, iron, and steel are responsible for a majority of air toxics emissions by weight. Utah has high levels of air toxics from other metal industries, while Kentucky’s aluminum industry is responsible for a large portion of its air toxics.
Examination of these subsector-specific emissions reveals that policymakers have an opportunity to advance policies that reduce GHG, criteria, and hazardous pollutant emissions within their states and sufficiently protect frontline communities disproportionately affected by harmful pollution. Conversely, if states adopt GHG measures that do not also reduce criteria and toxic emissions, significant health threats will remain in communities across the country.
State policies and recommendations
This report analyzes and describes select state policies that either require or incentivize decarbonization from industrial sectors related to the manufacturing of core construction and building materials such as iron, steel, and cement. Due to the necessity of these materials in society, the solutions examined focus on transforming manufacturing processes to reduce emissions rather than decreasing overall production. Decarbonization policies should maintain the availability of domestically produced materials and a robust manufacturing industry, which will secure supply chains and strengthen the economy. Manufacturing workers and their associated facilities are essential to the economic health of the United States, and the need to decarbonize for the climate can also be an opportunity to promote innovation, create jobs, and lead the world in producing the cleanest building materials.
Emissions from the chemical industry
In contrast to building materials, decreasing chemical sector emissions requires reducing the artificial market demand created by the petrochemical industry. Although cement and steel GHG emissions have been declining in the United States, emissions from the chemical sector have increased by 6 percent since 2005 due to increased demand and the increased domestic availability of cheap natural gas as a feedstock.33 In the United States, the proliferation of the petrochemical industry has resulted in almost 12,500 high-risk chemical facilities that put people who live within 3 miles of these facilities—a figure that encompasses nearly 40 percent of the U.S. population—at constant risk of chemical disaster.34 Emissions from chemical production and exposure are linked to health risks including cancer—such as in Louisiana’s predominantly Black, low-income communities between New Orleans and Baton Rouge nicknamed “Cancer Alley” —-as well as neurological issues, respiratory issues, and reproductive toxicity.35 The impacts of the chemical industry have not been adequately measured and the industry operates largely unregulated. A more comprehensive approach is necessary to reduce greenhouse gas emissions and co-pollutants.36 While the chemical industry falls outside the scope of this report, it is a critical piece of the industrial sector that must be sufficiently addressed to meet climate targets and to safeguard community health.
The standard-setting, incentive, and public procurement policies discussed below serve as examples of successful decarbonization efforts from which other states can learn valuable lessons. Some policies additionally incentivize industrial facilities to significantly lower their emission of harmful air pollutants. The list of policies examined is not intended to be exhaustive.
Emission reduction requirements
State governments have used two approaches to push industrial facilities to reduce greenhouse gas emissions: 1) setting binding statutory emission reduction targets specifically for the industrial sector; and 2) implementing market-based policies such as a cap-and-trade system. These policies can include additional limits for co-pollutants; however, most enacted so far target only GHG emissions.
Only Colorado, Massachusetts, and Maine have established requirements for GHG emissions reductions specifically for the industrial sector, in addition to an economywide goal. Thirteen other states and Puerto Rico have enacted legislation requiring an economywide GHG reduction, without a subgoal for the industrial sector.37 However, one of these states—California—passed additional legislation that set a goal at the product level, enacting the first state cement decarbonization law.38
In addition to their GHG reduction targets, California and Washington have implemented market-based policies to limit emissions from their industrial sectors. These programs cover most high-polluting building material manufacturers, as well as other major emission sources.39 Many states in the Northeast participate in the Regional Greenhouse Gas Initiative (RGGI), but this cap-and-trade program is just for power sector emissions.40
Greenhouse gas reduction targets
Colorado’s GHG emission reduction targets
In 2019, Colorado passed the Climate Action Plan to Reduce Pollution (H.B. 19-1261), which set targets to reduce statewide GHG pollution economywide 50 percent by 2030 and 90 percent by 2050 relative to 2005 levels.41 The plan also directed the Colorado Air Quality Control Commission (AQCC) to require energy-intensive, trade-exposed manufacturing stationary sources to undertake energy and emissions audits.42
GEMM 1
In fulfilling the economywide GHG emissions reduction goal set by the Climate Action Plan, Colorado adopted the Greenhouse Gas Emissions and Energy Management for Manufacturers in Colorado (GEMM 1) rule in 2021. GEMM 1 regulated emissions from trade-exposed industrial facilities that release at least 25,000 tons of GHG emissions annually. The rule applied to four facilities—one steel mill and three cement plants—which together accounted for 36 percent of emissions from Colorado’s large stationary manufacturing sources.43
GEMM 1 required facilities to prove through an audit process that they use the best practices and technologies to save energy and reduce GHG emissions. If the audit proved a facility was already using the best controls, it would only be required to reduce its GHG emissions intensity by an additional 5 percent per year, starting in 2025. If not, facilities were required to reduce the same amount of emissions that using the best controls would achieve as well as an additional 5 percent intensity reduction. Facilities were then required to submit a compliance plan demonstrating how they planned to adhere to their limit and improve air quality for nearby communities.44
GEMM 2
Also in 2021, Colorado passed its Environmental Justice Act, which intended to address environmental justice inequities through multiple GHG and air pollution reduction provisions.45 The law directed the AQCC to adopt rules that reduced GHG emissions from the industrial and manufacturing sectors by at least 20 percent by 2030 relative to 2015 levels. AQCC finalized this rule by adopting the Greenhouse Gas Emissions and Energy Management for Manufacturing 2 rule (GEMM 2) in 2023.
GEMM 2 required facilities with manufacturing operations that emit at least 25,000 metric tons of GHGs per year to collectively achieve a 20 percent GHG emissions reduction relative to 2015 levels by 2030. Facilities were required to submit plans on how to achieve the necessary reduction, and those that cannot cost-effectively comply have the option to buy GHG credits that have been generated by other regulated industrial facilities that exceeded 2030 emission reduction requirements. If there happens to be a shortage of such credits, GEMM 2 facilities will be required to pay into a state-managed fund that would be used to finance state decarbonization projects.46 The 18 facilities that qualified were collectively responsible for 46 percent of Colorado’s large stationary manufacturing emissions. They included producers of construction and building materials such as aluminum and drywall, semiconductor manufacturers, energy producers, and the food and beverage industry.47 The state estimated the reduction from GEMM 2 would reduce 550,000 tons of CO2e annually and could provide more than $950 million from the avoided cost of climate change.48
Facilities were also required to cut harmful air pollutants, defined as EPA-designated criteria air pollutants and hazardous air pollutants.49 Facilities located within 1 mile of a disproportionately affected community additionally were required to prioritize GHG reduction measures that also reduce the greatest amount of co-pollutants. The state estimated that the reduction of co-pollutants from GEMM 2 could provide more than $170 million in health benefits, and result in about 500 avoided deaths and more than 10,000 avoided asthma attacks by 2050.50
While facilities are instructed to “prioritize onsite reductions” of GHG emissions, they are also allowed to purchase GHG credits from other GEMM facilities that have already surpassed their 2030 reduction requirement.51 This emissions trading system will be established in December 2024, with the first auction of credits in June 2025.52 Earthjustice and other environmental groups have accused the decision to allow for emission trading of violating the Environmental Justice Act’s mandate to protect disproportionately affected communities since companies can comply with the law without reducing the co-pollutants surrounding their facilities.53 They have also criticized the law for failing to monitor a sufficient number of toxic air pollutants and for allowing facilities to request that any monitoring requirements end after two years.54
Massachusetts’ Clean Energy and Climate plans
In 2021, Massachusetts passed legislation requiring the Executive Office of Energy and Environmental Affairs to set interim emissions limits—including sector-specific limits—every five years.55 This resulted in the Clean Energy and Climate Plan for 2025 and 2030, as well as a plan for 2050, which set a target for the industrial and nonenergy sectors to reduce emissions below 1990 levels by 34 percent, 48 percent, and 76 percent, respectively.56
Massachusetts is not a large producer of building materials, and its climate plans do not include strategies for decarbonizing materials such as steel and cement.57 Instead, the state plans to prioritize reducing the usage of gases with high global warming potential, such as hydrofluorocarbons in cooling systems and heat pumps.58
California’s GHG reduction targets
California passed its Global Warming Solutions Act in 2006 (AB 32), requiring the California Air Resources Board (CARB) to develop regulations limiting economywide GHG emissions. AB 32 required CARB to publish a scoping plan every five years, the most recent of which was released in 2022.59 The plan aims to reduce GHG emissions 40 percent below 1990 levels by 2030 and achieve carbon neutrality by 2045 as mandated by the 2022 California Climate Crisis Act (AB 1279).60 California in 2022 also passed AB 2446, which required CARB to develop a framework to achieve a 40 percent net reduction in GHG emissions from building materials by 2035.61
Cement sector emission reduction goal
California is the second-largest cement-producing state in the country with seven cement plants, and the state’s industry is still heavily reliant on coal.62 In 2021, California passed SB 596 to address the significant emissions the industry is responsible for and to help achieve the targets in the Global Warming Solutions Act. This legislation required CARB to develop a strategy for the state’s cement sector to achieve a GHG intensity 40 percent below baseline levels by 2035 and net-zero greenhouse gas emissions by 2045. The law directed CARB to identify actions that reduce adverse air quality impacts but does not specifically require co-pollutant reductions.63
CARB plans to release its final strategy on how the state will achieve the goals of SB 596 in 2024.64 Many public commenters have noted that the law’s success will require public procurement policies for low-emission cement and concrete.65
Cap-and-invest programs
California’s cap-and-trade
In 2013, California launched its cap-and-trade (or “cap-and-invest”) program. Through this program, the state places an annually declining limit, or “cap,” on major greenhouse gas emission sources, distributes emission allowances to cover sources primarily via auction, and then reinvests program revenues into clean technologies and other emissions-reduction measures. The state’s GHG emissions cap declined by 3 percent annually from 2015 to 2020 and is projected to decline by 5 percent from 2021 to 2030. The program applies to any industrial facility, electric power plant, or fuel distributor that emits at least 25,000 tons of carbon dioxide equivalent per year. Facilities are either freely allocated portions of the cap or bid for them at a yearly auction, and the revenue goes to the state’s Greenhouse Gas Reduction Fund.66 These funds are appropriated through the state’s budget process for a variety of air quality, conservation, clean energy, and other environmental projects. The most recent plan for cap-and-trade auction proceeds recommended funding innovative industrial emissions reduction projects and prioritizing projects that maximize local air pollution benefits.67
The program covers about 85 percent of the state’s emissions and is a central component of the state’s broader GHG reduction goal. In 2016, California met its goal of reducing GHG emissions to 1990 levels by 2020, as outlined by the Global Warming Solutions Act, and now the state aims to achieve a 40 percent reduction below 1990 levels by 2030.68 CARB, which implements the program, credits cap-and-trade for successfully incentivizing industrial facilities to clean up their processes and to reduce GHG emissions while maintaining production levels. CARB also notes that there has been a near 100 percent compliance rate every year since implementation.69
California’s cap-and-trade program does not regulate air pollution; CARB regulates this separately, including through AB 617, which requires the agency to address air quality in communities most exposed to toxic and criteria air pollutants.70 The state also targets at least 35 percent of program revenues into low-income and disadvantaged communities, a policy model that inspired policies in New York, Washington state, and ultimately federal policy with the Justice40 Initiative.71 Some studies, including one by the University of Southern California’s Equity Research Institute, found that disadvantaged communities saw some improvement in reduced pollutants from cap-and-trade facilities but less improvement than many nondisadvantaged communities.72 However, another study from Arizona State University and the University of California, Santa Barbara found that disparities in local air pollution concentrations from cap-and-trade facilities have decreased since the program’s implementation.73
Washington’s cap-and-invest
In 2021, Washington state passed the Climate Commitment Act, which established a cap-and-invest program that started at the beginning of 2023. The program set a statewide cap on GHG emissions that lowers over time and established a market for companies to buy pollution allowances for their portion of the cap that would become increasingly expensive.74 It is one of the policies contributing to the state’s goal of reducing GHG emissions to 45 percent below 1990 levels by 2030, 70 percent by 2040, and 95 percent by 2050. The program covers facilities that emit more than 25,000 metric tons of carbon dioxide (CO2) per year, which accounts for 75 percent of statewide emissions. Companies that do not comply are issued a fine of up to $50,000 per violation, per day.75 The program includes an exception for emissions-intensive, trade-exposed industries that are susceptible to global and regional market fluctuations, allowing them to buy allowances at little or no cost for the first 12 years of the program. This attempt to prevent carbon leakage—the idea that companies would move out of state to continue polluting—would decrease the revenue of the program but does not affect the overall emissions cap.76
Washington’s cap-and-invest program has a more ambitious target than California’s, with a 2050 goal to reduce emissions below 1990 levels by 95 percent, compared with California’s 80 percent goal.77 In designing their program, Washington officials worked to remedy some of the California law’s shortcomings. For example, companies in California can cancel out some of their CO2 emissions by buying offsets that absorb the same amount of carbon, such as planting trees. However, some of these forests used for offsets have been burned in wildfires. In Washington’s program, if a company relies on an offset, then a pollution allowance will be removed from the company’s pool when it pollutes so that the offset is not considered a replacement for reducing emissions. In addition, companies can only use offsets for up to 5 percent of their required emissions reductions in the early stages of the program.78
Washington is the first state to pair a cap-and-invest system with a regulatory air quality program and relies on the advice of its Environmental Justice Council for implementing the policy and deciding how to spend the revenue. The state plans to identify communities that are overexposed to air pollution and then set air quality goals and conduct regular analyses in those areas to ensure pollution is lowered.79
The revenue from cap-and-invest goes to projects that reduce emissions, implement clean energy, or address climate adaptation. At least 35 percent of the revenue will be invested in vulnerable communities, with an additional 10 percent set aside for projects that benefit Native American Tribes.80 In 2023, the four auctions held generated almost $2 billion.81
State environmental justice policy
Across the country, communities of color and low-income communities face a disproportionate burden from the pollution caused by fossil fuel, energy, and industrial infrastructure and the impacts of climate change. These cumulative and compounding threats have galvanized EJ communities across the country to advocate for policies that aim to lessen the cumulative impacts in their communities by identifying overburdened communities, restricting pollution in overburdened communities, and requiring climate policies to deliver reductions in both climate and local pollution sources in EJ communities.82
Environmental justice laws
New Jersey was the first state with an environmental justice law that required the state environmental agency to evaluate and act to reduce the cumulative environmental and public health impacts on overburdened communities when issuing permits to polluting facilities.83 New York passed a similar law giving permitting agencies the authority to deny permit renewals or modifications if a proposed facility would significantly increase the pollution burden in communities designated as disadvantaged based on their pollution burden and vulnerability. Other states have passed laws with similar intentions, although they are smaller in scope: Minnesota’s limits the geography and type of permits allowed, and Massachusetts’ law limits the law to just requiring a cumulative impact assessment.84
Environmental justice in climate policy
Given the disproportionate burden in EJ communities caused by co-pollutants’ emissions, advocates have pushed for policies that require mandatory GHG emission reductions to also include co-pollutants in EJ communities. To date, there are no state policies in place that achieve the mandate for mandatory emission reductions in EJ communities. Advocates have also pushed for guardrail policies, which are restrictions on climate policies and technologies that would further harm overburdened communities. New York’s Climate Leadership and Community Protection Act is an example of the guardrail approach and includes language to restrict activities that would add to disproportionate burdens in communities.85
Recommendations for setting emission reduction requirements
States should set binding statutory targets for their greenhouse gas emissions from the industrial sector with ambitious interim targets that put the sector on track to be net zero by 2050. The states that produce high levels of certain materials should implement targets at the product level, as California did as the second-highest cement-producing state.86 States such as Indiana, which alone is responsible for 43 percent of national GHG emissions from iron and steel production, must be leaders in pursuing decarbonization policies (see Figure 2). Goal setting should be paired with coordinated governance and planning policies to encourage early stakeholder engagement from relevant industries and mitigate the risk of carbon leakage. To overcome thin margins and to ensure continued domestic production, these goals should be coupled with incentive programs that encourage industry to make decarbonization improvements.
Cap-and-invest programs, if designed and implemented well, have been effective in reducing emissions as intended, with successful examples in the United States and around the world.87 In California, overall GHG emissions have declined by 14 percent since the start of the cap-and-trade program; however, this success cannot be attributed solely to this policy.88 States should consider cap-and-invest programs a policy tool to be used in conjunction with a suite of other climate change mitigation efforts, as well as policies that specifically target reducing harmful air pollutants. States can follow Washington’s lead in pairing its cap-and-invest program with an additional air quality program. They should also pass EJ provisions within or in addition to climate legislation, such as setting facility-level air pollution limits, denying permits as New Jersey’s Environmental Justice Law does, or requiring mandatory emission reductions in EJ communities.
In addition, the revenue states receive from implementing market-based policies should be reinvested to clean up industrial facilities more quickly, with requirements that a percentage of the investment benefits communities affected by air pollution. Both California’s and Washington’s cap-and-trade programs require that at least 35 percent of revenue is used to benefit underserved communities, while the federal government’s Justice40 Initiative aims for 40 percent.89 Likewise, states that participate in the RGGI have used their portion of auction proceeds to reinvest in programs focused on environmental justice and equity while reducing emissions, such as installing weatherization and energy efficiency upgrades in low-income households or installing electrification infrastructure in EJ communities.90
Decarbonization incentives
Several states have established grant programs and tax incentives to alleviate the high costs associated with reducing climate and conventional pollution from industrial facilities, driven by the desire to keep these trade-exposed industries in their jurisdictions. In addition to helping reduce GHG pollution at these facilities, these programs assist in scaling the deployment of technologies that could drive a wider impact across the industrial sector. Some states are also taking advantage of new federal funding opportunities in IRA and IIJA programs by using flexible grant funding to create or expand state incentive programs and by “stacking” state incentives on top of new federal incentives to give their industries additional incentive and economic advantage.91
Grant programs
Colorado’s Clean Air Program
To help industrial facilities meet the state’s emission reduction goals described above, Colorado has been working to provide incentives for facilities that invest in cleaner practices. In 2022, Colorado passed the Air Quality Improvement Investments, resulting in the Clean Air Program, which offers reimbursement-based grants for industrial and manufacturing facilities that voluntarily reduce their GHG emissions and air pollutants.92 These grants can be applied to installing renewable energy, undergoing electrification to fossil fuel-powered equipment or processes, and producing or utilizing “clean hydrogen” or carbon capture in industrial facilities. The legislation establishing the program also recognizes that industrial emissions often “disproportionately impact low-income, minority, or housing cost-burdened communities in the state.”93 The program will award up to $25 million by 2028 and has already awarded $3 million to two industrial heat pumps in 2023 that are projected to avoid more than 35,8000 metric tons of CO2e a year by 2028.94
California’s INDIGO program
In 2022, California established the Industrial Decarbonization and Improvement of Grid Operations (INDIGO) program, which provides $100 million in incentives for industrial facilities that reduce GHG emissions and support the electric grid.95 Eligible projects under INDIGO include ones that enhance electrical grid reliability, electrify processes that use fossil fuels, incorporate energy storage or renewable resources, increase energy efficiency, and develop and deploy novel decarbonization technologies and strategies. The program also aims to create benefits for priority populations. Applications for projects that are located in and benefit disadvantaged communities that demonstrate meeting a direct community need are prioritized in the selection process.96 Implementation of the INDIGO program is intended to help standardize industrial facility operations to reduce their production of GHG emissions, electrical demand during net peak periods, and criteria air pollutants harmful to the environment and human health.
New York’s Commercial and Industrial Carbon Challenge
New York recently completed its Commercial and Industrial Carbon Challenge, which provides industrial facilities and other nonresidential large energy consumers grants to reduce carbon emissions through electrification, energy efficiency, or manufacturing process emission reduction.97 Each successful project can be awarded anywhere from $500,000 to $5 million. Since its inception in 2018, the Commercial and Industrial Carbon Challenge has awarded grants to 19 projects that will cumulatively reduce 3 million metric tons of carbon dioxide equivalent.98
The RISE PA program
In July 2024, the U.S. Environmental Protection Agency (EPA) awarded Pennsylvania almost $400 million as part of its Climate Pollution Reduction Grant program. The selected application outlined Reducing Industrial Sector Emissions in Pennsylvania (RISE PA), a plan to create a statewide industrial decarbonization incentive program and reduce GHG and other emissions from Pennsylvania’s industrial sector, the highest-emitting sector in the commonwealth. Incentives and grants ranging from $25,000 to $300 million will be offered for small-, medium-, and large-scale decarbonization projects at industrial facilities, and the financial support of the grant will address current funding gaps for industrial decarbonization projects in Pennsylvania.99
Energy efficiency incentives
Multiple states have grant programs for industrial facilities to implement energy-efficient solutions, including Maine’s Commercial and Industrial Prescriptive Initiative; Maryland’s Commercial, Industrial and Agricultural Grant Program; and the Mississippi Industrial Energy Efficiency Program. Although program budgets and application requirements differ slightly across states, all of these programs provide incentives for industrial manufacturers to upgrade their facility lighting, water heating and energy system controls, heating, ventilation, and air conditioning to more energy-efficient appliances. Manufacturers that own facilities supporting agricultural production or farming are also eligible to apply to these programs.100
Green hydrogen incentives
States are also using incentives to encourage the development of green hydrogen production, which could be critical for a few key sectors in their efforts to decarbonize, notably iron and steel. Washington passed legislation in 2022 authorizing public utility districts to produce, sell, own, and operate pipelines to supply green electrolytic hydrogen (hydrogen produced through electrolysis).101 Municipalities are authorized to construct, acquire, and operate facilities to supply green and renewable hydrogen (hydrogen produced using renewable resources). The legislation also added the production of green electrolytic hydrogen to several existing tax exemptions for renewable hydrogen. California’s Clean Hydrogen Program was also created in 2022 and offers $40 million for hydrogen projects that produce, process, deliver, store, or use hydrogen derived from water using eligible renewable energy resources.102 Hydrogen utilization should be judged critically on its best use, and efforts should be made to assess local pollution impacts and to prevent pollution resulting from direct combustion.
Tax credits and exemptions
Low-carbon building material tax incentives
Multiple states are encouraging the purchase of low-emission building materials through tax credits or exemptions. New Jersey passed legislation in 2021 requiring builders to offer a unit concrete product that utilizes carbon footprint-reducing technology and provides tax credits to customers using that concrete. The product must generate at least 50 percent less CO2 emissions than an ordinary concrete unit would emit in production and utilization.103 In 2023, New Jersey expanded on this legislation to make concrete producers who supply at least 50 yards of concrete for state-funded construction projects eligible for a performance-based tax credit if they deliver concrete with quantifiable reductions in embodied carbon.104 Producers who submit certified Type III Environmental Product Declarations (EPDs) that validate Global Warming Potential (GWP) scores that fall below the established embodied carbon baseline can be awarded a tax credit of up to 8 percent of the total cost of the contract.105 This first-of-its-kind incentive is designed to accelerate the rate at which private producers develop and adopt innovations.
Colorado passed legislation in 2022 to exempt all sales, storage, and use of low-carbon construction materials from state sales and use tax. This effort was included among other state tax credits and exemptions that also incentivized buying and installing commercial and residential heat pump systems and water heaters.106 In 2023, Colorado passed legislation to fund the Colorado Industrial Tax Credit Offering (CITCO), which offers tax credits for industrial facilities implementing improvements that reduce emissions.107
Federal action
While the state incentive programs mentioned above can fill in some of the financial and policy gaps in the industrial decarbonization sector, the federal government also has a large role to play in defraying the costs of these efforts. This is particularly important for the multiple states—such as Indiana, Texas, or Missouri—that have yet to pass ambitious policies but have the highest emissions from industry. The passage of the IRA established numerous federal incentives that could be partnered with state programs. Environmental justice advocates and analysts, including the White House Environmental Justice Council, have raised numerous concerns about the potential harm some of the IRA investments could cause to communities living near industrial polluters—particularly investments in carbon management technologies, hydrogen, nuclear, and refining of alternative fuels.108
Notably, significant funding from the IRA and IIJA supported early or first-of-its-kind technology demonstrations for replicable projects that can offer deep decarbonization, timeliness, market viability, and community benefits for energy-intensive industrial subsectors. Funding has been allocated to projects in the iron and steel, cement and concrete, food and beverage, paper and forest products, aluminum, and other energy-intensive manufacturing industries, as well as in cross-cutting technologies.109 Some examples include:
- Major investments across the steel industry that will replace a blast furnace in Ohio and natural gas- and coke- (derived from coal) fired boilers in Pennsylvania, Alabama, and the Gulf Coast with electrified processes and hydrogen-ready iron production, the technology at the forefront of driving a full-scale decarbonization of the industry110
- Decarbonizing food and beverage manufacturing at Unilever, Kraft, and Diageo primarily through electrification and other technologies such as industrial heat pumps, heat batteries, and thermal energy storage, which will replace natural gas boilers and other emissions-intensive processes111
Other federal programs underway that have the potential to support decarbonizing and reducing harmful local pollution in the industries that produce core building materials include:
- Industrial Efficiency and Decarbonization Program, $104 million: Funding for decarbonization technologies that will reduce the carbon footprint of the industrial sector, including chemicals, iron and steel, food and beverage products, cement and concrete, paper and forest products, and cross-sector decarbonization technologies112
- Industrial Research and Assessment Center Implementation Grants, $400 million: Funding for manufacturers to conduct upgrades including improved efficiency, cybersecurity, and advanced manufacturing113
- Onsite energy technical assistance partnerships, $23 million: Funding for a regional network of technical assistance partnerships to help industrial facilities and other large energy users increase the adoption of onsite energy technologies, including battery storage, combined heat and power, district energy, fuel cells, geothermal, industrial heat pumps, renewable fuels, solar photovoltaics, solar thermal, thermal storage, and wind power114
- Advanced Energy Manufacturing and Recycling Grant Program, $750 million: Funding for industrial or manufacturing facilities to install greenhouse gas reduction equipment, which is intended for small- and medium-sized manufacturing firms including those located in communities that have experienced coal mine or coal-fired power plant unit closures115
- Applied research and development projects to drive industrial decarbonization, $156 million: Funding to advance high-impact applied research, development, and demonstration projects to reduce greenhouse gas emissions across the U.S. industrial sector116
Recommendations for decarbonization incentives
Economic incentives can be an effective policy tool for governments to accelerate decarbonization efforts in the industrial sector. Providing industrial and manufacturing facilities the opportunity to be reimbursed for reducing their GHG emissions can encourage and accelerate innovation and the use of clean technologies and strategies. Incentives should be designed to ensure that high-quality manufacturing jobs and economic benefits are maintained and expanded. Allowing flexibility in award requirements rather than requiring a specific type of industrial decarbonization effort will make it easier for facilities to select solutions that best fit their unique needs, maximize efficiency, and allow for innovation. New York’s Commercial and Industrial Carbon Challenge demonstrates this strategy well: The project budget range is very large—$500,000 to $5 million—and can accommodate either a practice that is lower cost (such as retrofitting machines) or more ambitious (such as installing new systems).
Due to exposure to global trade and thin margins creating fierce competition, decarbonizing the industrial sector will require interventions that prevent upfront costs from disincentivizing industry. Offering incentives for decarbonization efforts can help remove barriers to cleaning up industrial emissions, and creating taxpayer investments in a more sustainable economy can return benefits that can strengthen local economies through new job creation. For example, industrial facilities typically prefer to use natural gas over electricity because natural gas is cheaper and because the price ratio of electricity/natural gas varies by state.117 Incentives that offset this disadvantage for electrification could help spur decarbonization. A technology-neutral production or investment tax credit could be developed for low-embodied carbon products, industrial electric usage, or industrial equipment that uses low-carbon electricity instead of fossil fuels. States and industries should leverage support from the federal government for research and development, infrastructure development, and demonstration project funding through loans, grants, and cooperative partnerships to further address these and other transition cost challenges.118
States on their own will likely not be able to fund the costs required to transition their industry practices to low and zero emissions. It is also difficult for federal programs on their own to fulfill the unique needs of different state industrial sectors, as economic priorities and accessibility to specific materials vary by state. To fill this financial gap, policies by state governments and agencies need to utilize and complement federal programs, and funding needs to be deployed continuously to ensure funds are consistently available for decarbonization efforts. California’s INDIGO award is an example of this. Applicants can either receive funding for a new project or receive subsequent funding from the U.S. Department of Energy to continue research from a previously awarded federal grant as long as it meets the requirements of the program.119While incentive programs can front or fill in costs so that states are able to execute industrial decarbonization plans in a timelier manner, it is also important to note that existing programs do not include stipulations or incentives for local pollution reduction in addition to GHGs. To avoid further entrenching and expanding racialized disparities in exposure to pollutants caused by these industries, states need to expand the use of incentives to prioritize and support adopting technologies and process changes that deliver reductions in overburdened communities.
Buy Clean and green public procurement programs
Leveraging existing public spending to support a public good is an established strategy to achieve policy outcomes at little to no cost. Buy Clean is the version of this strategy that seeks to drive spending decisions by government procurement agencies toward clean construction and building materials, focusing mostly on the materials produced with the most greenhouse gas emissions—for example, steel and cement. While still an evolving model, different iterations of Buy Clean and similar green public procurement policies are becoming more prevalent at the state and federal agency levels. The majority of these have focused on transparency and disclosure of embodied GHGs in core manufactured goods. Movement toward specific standards for GHGs has begun, as well as the inclusion of additional materials and impacts on jobs, as states and the federal government further develop these programs.
States have been a useful lab for demonstrating Buy Clean models. Each example has built off of earlier ones, with the first being California’s effort to jump into the fray in 2017. Three examples are worth exploring in more detail.
Colorado’s Buy Clean Act
Colorado has attempted to incorporate nearly all of the core elements of the Buy Clean policy and apply them to the broadest set of materials.120 The Buy Clean Colorado Act applies to seven categories of materials and covers public projects that cost more than $500,000. It requires contractors to submit EPDs to show the GWP of each covered material. In 2024, the state is to establish a maximum GWP for each material, and beginning in 2026—after review and reporting—it can determine whether that maximum GWP should be lowered. All in all, the act mandates reporting of EPDs, sets maximum GWP, establishes Buy Clean standards, and incorporates a mechanism that potentially results in ratcheting the strength of the program.
New York’s Low-Embodied Carbon Concrete Leadership Act
New York launched its Buy Clean effort with a sole focus on concrete. The state originally passed the Low-Embodied Carbon Concrete Leadership Act (LECCLA) in 2021, a law that provides incentives for cleaner concrete by considering climate impacts when awarding contracts.121 Following the passage of LECCLA, New York adopted Executive Order 22 in 2022.122 This effectively launched the beginning of the Buy Clean policy implementation in the state by pushing state agencies to identify and seek to reduce embodied carbon in common construction materials including concrete, asphalt, steel, and glass. In 2023, the state adopted mandatory rules establishing emissions limits on concrete used in state-funded projects.123
Washington’s Buy Clean program
Washington state has taken a concerted approach to getting the Buy Clean policy right. In 2021, Washington passed a pilot program to evaluate the feasibility of data collection and analysis.124 After the successful delivery of the report on the pilot, the state legislature passed a detailed data collection, reporting, and review bill in 2024 that will establish a strong framework and understanding of the extent and impact of embodied carbon in construction materials in the state. Perhaps the most novel thing about Washington’s approach is that it incorporated reporting on working conditions for employees in facilities affected by the law.125 Multiple other states have rightly included representatives from labor unions in technical and reporting committees on Buy Clean and its emissions impacts, but Washington is the first to specifically include reporting on working conditions.
Federal action
The Biden-Harris administration has taken Buy Clean and broader green public procurement further than any other administration. In 2021, Executive Order 14057 created the Federal Sustainability Plan and officially launched a Buy Clean Task Force.126 The task force, composed of members representing different agencies, is responsible for developing recommendations on policies to expand the federal procurement of construction materials with low-embodied emissions. The General Services Administration was the first agency to pilot a federal Buy Clean program, using $2.15 billion from the Inflation Reduction Act.127 The IRA also included $250 million for the EPA to develop an EPD assistance program to support the standardization and reporting criteria of EPDs.128
In March 2023, the Biden-Harris administration launched the Federal-State Buy Clean Partnership with California, Colorado, Hawaii, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, New Jersey, New York, Oregon, and Washington, committing to prioritize efforts that support the procurement of low-carbon infrastructure materials.129
“A Green Buyers Club: Transatlantic Cooperation on Green Public Procurement”
Green public procurement policies incentivize economywide decarbonization by helping low-carbon products become the default option in the marketplace. This report analyzes the status of green public procurement policies for construction materials (also known as “Buy Clean”) in Germany, Canada, and the United States.
Recommendations for green public procurement programs
The development trajectory of Buy Clean policies has necessarily begun with a strong focus on transparency and disclosure before advancing to standard-setting once more is known about state material use. While the data on embodied emissions is starting to become available, it is available only in a handful of states and is being collected in different formats and according to various methodologies. Common definitions of what clean materials, or “near-zero emissions,” entail are still elusive across the country, let alone around the world, though the North America-based Embodied Carbon Harmonization and Optimization project is working to develop common definitions.130 The implementation of Buy Clean in states and the launch of the Buy Clean Task Force and pilot projects at the federal level have shown that the federal government needs to lead in establishing a data apparatus associated with embodied emissions—encompassing emissions generated throughout the entire lifecycle of the product—and in developing common definitions (e.g., “what is green steel?”). This can be done solely within the United States but would preferably be achieved in collaboration with like-minded nations such as Canada and Germany that are also developing Buy Clean and green public procurement programs.131 Cities also should collaborate on implementing green public procurement programs with aligned standards and can model innovative policies for their states. Cities around the world already collaborate on achieving climate goals, such as through the C40 network that includes 96 member cities.132
Immediately after the United States sets a comfortable path toward the alignment of data collection methods and definitions, Buy Clean will be ready to evolve as a policy to establish strong standards that incentivize the procurement of only the cleanest of goods produced through the best possible processes. Doing so will require three changes. First, each Buy Clean policy needs to include a specific date for when standards either prioritize or identify a path to zero to near-zero emissions. Second, those standards must apply to toxic emissions in addition to GHGs. Third, the standards should be paired with Buy Fair-like policies to ensure that the production of these clean materials is creating high-quality, union jobs, and the standards should always be paired with strong Buy America preferences. Ideally, states should codify action in legislation rather than set executive orders or recommendations in a state climate plan.
Summary of recommendations
The examples and lessons of state policies listed above provide a strong start that needs to be expanded on to build a comprehensive response to building America’s industry of the future. In addition to doing their part to address the urgency of the climate crisis, states can enact ambitious policies now to improve the air quality and public health of their communities, create high-quality jobs, and ensure their manufacturing facilities stay competitive as industrial production evolves globally. Many of the policies focus exclusively on GHG emission reductions and some include provisions to reduce toxic air pollution. It is essential to consider this effort holistically. For example, procurement and investment programs will have the highest impact when they are paired with cumulative impact policies that guarantee pollution reduction; provide facility workers with safe, secure jobs with unfettered access to collective bargaining; and ensure that neighboring communities are protected from toxic pollution.
Recommendations for states include:
- Set binding statutory targets and/or create cap-and-invest programs for industrial GHG emissions with ambitious interim targets that put states on track to be net zero by 2050.
- Where they occur, reinvest revenue from emission reduction programs into decarbonization efforts as well as solutions that benefit the communities most affected by air pollution.
- Pair GHG emission reduction policies with incentive programs that will offset the costs of decarbonization and air pollution reduction efforts and ensure continued domestic production.
- Pair GHG emission reduction policies with additional air quality programs and EJ provisions such as setting facility-level air pollution limits, denying permits for new or expanded industrial facilities, or requiring mandatory emission reductions in EJ communities.
- Pair all standards and incentives with policies that ensure the production of low-embodied carbon materials is creating high-quality, union jobs.
- Lead by example and create demand for low-embodied emission building materials by establishing green public procurement policies such as Buy Clean with standards for toxic emissions in addition to GHGs.
Yet while states can initiate significant progress on their own, the fastest path to reaching national net-zero targets will require state and federal collaboration. Federal assistance will be necessary to fill the gaps in funding, staff capacity, and technical expertise that most states lack. In addition, many of the states with the highest industrial production have made the least progress in curtailing their emissions or taking advantage of federal incentive programs. Here too, federal regulations and procurement policies are needed to encourage facilities to clean up production where they are rather than move to a less restrictive state. Accelerated leadership and cooperation at both the state and federal levels are needed to build a robust, clean industrial sector that benefits all Americans.
Conclusion
States, the laboratories of public policy, have the opportunity and responsibility to showcase how America’s industrial sectors can be transformed. This process has already begun, and the ongoing efforts have made it clear that comprehensive action is the ideal path forward. Policymakers in states across America should strive to set up programs that cut GHG and toxic air pollutant emissions from facilities, maximize community benefits, and ensure that the associated jobs are good union jobs. States should take the lead in focusing investments on developing technologies and processes that eliminate GHG emissions and toxic pollution and continue progress on climate and clean energy deployment, particularly as the federal government is poised to undermine climate action on the federal level in the short term.
Community and public infrastructure cannot be built without cement, iron, and steel. But a community also does not exist without its people. Now is the time for states across the country to lead in producing the building materials America needs while ensuring safer, healthier, and more prosperous communities.
Acknowledgments
The authors would like to thank Michele Roberts, Miriam Rotkin-Ellman, and Stephanie Herron of the Environmental Justice Health Alliance; and Sam Ricketts, Shannon Baker-Branstetter, Akshay Thyagarajan, Leo Banks, and Cathleen Kelly of the Center for American Progress for their thoughtful contributions to this report. They would also like to thank Emma Lofgren, formerly of CAP; Ankita Gangotra of the World Resources Institute; Kareem Hammoud of the U.S. Climate Alliance; David Soll of the Great Plains Institute; and Mikhail Haramati, Dharma Santos-Santiago, Jaden Kielty, Renée Sharp, and Sonya Lunder of the Natural Resources Defense Council for their review and input on this report. The views expressed in this report are solely attributable to the authors.
Methodology
Figure 1 and Figure 2 use facility-level data from the EPA’s Greenhouse Gas Reporting Program (GHGRP). The GHGRP only requires reporting from large GHG-emitting sources, fuel and industrial gas suppliers, and carbon dioxide injection sites in the United States; therefore, the dataset does not reflect total U.S. GHG emissions. The data were reported to the EPA by facilities prior to August 18, 2023. Data for Figure 1 were downloaded from the EPA’s Facility Level Information on Greenhouse Gases Tool (FLIGHT) for the sectors “minerals” and “metals” in the data year 2022. For minerals, the subsector “soda ash manufacturing” was added to “other minerals,” while all other subsectors were left separate. For metals, the subsectors “ferroalloy production,” “lead production,” “magnesium,” and “zinc production” were added into “other metals,” while all other subsectors were left separate. The subsectors displayed in Figure 1 were chosen because of their relevance to building materials and construction. The same subsectors, with the exception of other metals and other minerals, were used for Figure 2.
Figure 3, Figure 4, Figure 5, and Figure 6 use facility-level data from the EPA’s National Emissions Inventory (NEI) dataset using the 2020 NEI Data Retrieval Tool. Figure 3 and Figure 4 analyze criteria air pollutant (CAP) data, downloaded by selecting “CAP” under “pollutant type,” while Figure 5 and Figure 6 analyze hazardous air pollutant (HAP) data, downloaded by selecting “HAP.” Facilities were sorted manually into the same seven industry sections used for Figure 1 and Figure 2 by searching for the following key terms under “facility type” and NAICS in the dataset:
- Cement and concrete industry: “cement” and “concrete”
- Lime industry: “lime”
- Glass industry: “glass”
- Iron and steel industry: “iron” and “steel”
- Aluminum industry: “aluminum”
- Other metals industries: “metal” “nonferrous” “foundries” “gold” “copper”
- Other minerals industries: “mine,” “mining” (excluding coal and anthracite), “asphalt,” “clay,” “graphite,” “gypsum,” and “stone”
Instances where the key term was part of a different word (i.e., “cement” in “replacement”) were excluded, as were instances where a key term directly followed “except” or “not” (i.e., “except aluminum”). Entries with the keyword “fiberglass” were also excluded. In addition, entries with the following key terms were excluded for not being related to manufacturing: “wholesale,” “shop,” “store,” “contractor,” “school,” “repair,” and “equipment rental.” All entries were considered for relevance to building materials in developing the key terms list in order to ensure all appropriate industries were included (i.e., the key term “zinc” was unnecessary, as all North American Industry Classification System codes that mention zinc also mention “copper” and therefore were captured under other metals industries.)
The original NEI dataset contains CAP emissions data for 76,655 facilities nationwide, 9 percent of which were labeled as one of the seven building materials. It contains HAP emissions data for 63,572 facilities nationwide, 7 percent of which were labeled as one of the seven building material sections. For more information on NEI emissions reporting requirements, visit the 2020 National Emissions Inventory Technical Support Document.