jjpectorStrategies
Measuring Construction Industry
Environmental Performance
September 2007
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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
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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. 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,
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
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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
September 2007 Page 2
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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
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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 System™.
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
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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 construction-
related. 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
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
Construction Waste
Management, Divert
50% from Disposal
Construction Waste
Management, Divert
75% from Disposal
Construction IAQ
Management Plan,
During Construction
Construction IAQ
Management Plan,
Before Occupanc
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.
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 Ei
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.
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
Stormwater Design,
Quantity Control
Stormwater Design,
Quality 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.
Limit disruption and pollution of natural water flows by managing Stormwater
runoff.
Site Development, Conserve existing natural areas and restore damaged areas to provide habitat
Protect or Restore Habitat and promote biodiversity.
September 2007
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Building Reuse, Maintain
75% of Existing Walls,
Floors & Roof
Building Reuse, Maintain
95% of Existing Walls,
Floors & Roof
Building Reuse, Maintain
50% of Interior Non-
Structural Elements
Materials Reuse, 5% of
total value of materials
used
Materials Reuse, 10% of
total value of materials
used
Recycled Content, 10%
(post-consumer + 1/2 pre-
consumer)
Recycled Content, 20%
(post-consumer + 1/2 pre-
consumer)
Regional Materials, 10%
Extracted, Processed &
Manufactured Regionally
Regional Materials, 20%
Extracted, Processed &
Manufactured Regionally
Rapidly Renewable
Materials, 2.5% of total
value of materials and
products
Certified Wood, 50% of
wood-based materials and
products
Low-Emitting Materials,
Adhesives & Sealants
Low-Emitting Materials,
Paints & Coatings
Low-Emitting Materials,
Carpet Systems
Low-Emitting Materials,
Composite Wood &
Agrifiber Products
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.
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.
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.
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.
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.
Increase demand for building products that incorporate recycled content
materials, thereby reducing impacts resulting from extraction and processing of
virgin materials.
Increase demand for building products that incorporate recycled content
materials, thereby reducing the impacts resulting from extraction and
processing of virgin materials.
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.
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.
Reduce the use and depletion of finite raw materials and long-cycle renewable
materials by replacing them with rapidly renewable materials.
Encourage environmentally responsible forest management.
Reduce the quantity of indoor
and/or harmful to the comfort
Reduce the quantity of indoor
and/or harmful to the comfort
Reduce the quantity of indoor
and/or harmful to the comfort
air contaminants that are odorous, irritating
and well-being of installers and occupants.
air contaminants that are odorous, irritating
and well-being of installers and occupants.
air contaminants that are odorous, irritating
and well-being of installers and occupants.
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.
September 2007
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2,800
Figure 1: Total LEED-NC Construction-Related Credits Received
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
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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 construction-
related 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
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2000 2001 2002 2003 2004 2005 2006
— • — Construction-Related
— • — Possibly Construction-Related
— A — 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
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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
900
800
o 700
TO
8 600
"o
i_
o
•? 500
400
300
2006*
2007
2008
Year
2009
2010
"First year of data co llectio n
Source: USGBC Accredited Professionals database
http://www.usgbc.org/LEED/AP /ViewAll.aspx?CategorvID=1306&CMSPageID=1585
September 2007
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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*)
a.
•o
01
•E
1
01
.a
1200
1000
800
600
400
200
2002
2005 2006
*Asof August 2007
2003 2004
Year
LEEDNC —O— LEEDEB —n— LEED Cl —o— LEED CS
2007
•Total
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
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Figure 5: LEED Certified Projects
(actual value by year*)
350
300
2, 250
"8 200
o
o
"o
o
1
150
100
*As of August 2007
2002 2003 2004 2005 2006 2007
Year
LEEDNC —o— LEEDEB -a— LEEDCI —o— LEEDCS —I—Total
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.
Level
Table 2: Total LEED Certified New Construction
Projects in the United States
Score
LEED Certifications at
This Level*
Certified 26-32
Silver 33-38
Gold
Platinum
39-51
> 51
250
199
149
22
* As of August 1,2007
Additional Green Building Standards.
Green Globes™ provides another program for rating green buildings in the United States.
The Green Building Initiative (GBI) brought Green Globes™—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:
September 2007
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• 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. The
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." 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.
September 2007 Page 12
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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
2001
2002
2003
2004
2005
2006
Year
Source: Miller, K. Forest Stewardship Council, Washington, DC. Personal communication,
December, 2006.
September 2007
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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
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. 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 15
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State
California
Connecticut
Table 3: C&D Debris Data Availability by State
Data Availability
Data Limitations
Total Generated and Diverted by Year
Connecticut does not report annual amounts of C&D
disposed or recycled.
C&D debris data are not updated
regular intervals.
ated in
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.
.. . Tracks total tons of C&D debris generated, disposed of,
lassacnusetts and diverted from 1998 to
Missouri
New York
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.
New York does track disposal and recycling data to some
extent. Data were not included due to reporting
inconsistencies and completeness.
This method assumes that total waste
disposal changes equally across all
sectors.
Ohio
Oregon
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.
Does not include waste that is
exported or does not go to disposal
facilities. Annual report data may be
incomplete.
2003 data does not include C&D
debris not going to C&D facilities (a
large underestimate). 2006 data
does not include recycling.
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.
Texas
Texas has tracked C&D disposal information from 2001
to 2005 for permitted and registered facilities. Texas
does not track recycling.
Material types listed do not include
inert material such as concrete.
Virginia
Tracks C&D material received and recycled at permitted
facilities.
Washington
Washington tracked annual C&D diversion from 1999 to
2005. Disposal data are also available but only in
"demolition" and "inert materials" categories.
Wisconsin
Wisconsin only has some C&D debris numbers from a
waste-sort in 2002 at MSW facilities. Does not track
recycling.
This does not include waste that does
not go to permitted facilities (captive
waste management). This results in a
large underestimate of total recycling.
Diversion data is based on voluntary
survey results. Disposal data are not
presented specifically for C&D.
Sources: All information obtained from state environmental department websites or personal
communications.16
September 2007
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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.
100%
Figure 7: Generated C&D Debris That Is Recycled in Five
States
o%
2004
1998 1999 2000 2001 2002 2003
Year
—A— Maryland —o— Florida —•— Massachusetts
—0—Virginia ^*^5 States Combined —I—Washington
2005
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.htnu18 MA
DEP, 2004;19 2006;20 Virginia DEQ;21 Washington Department of Ecology, 2006.22
September 2007
Page 17
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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 of25 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 of27 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
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28
processing plants was at 197 million tons in 2004, up from 96 million tons in 1997. 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
30
25
15
10 -
5
2001
2002
- Maryland
-Virginia
2003
Year
- Florida
•5 States Combined
2004
- Massachusetts
— Washington
2005
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
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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
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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 diesel -
powered 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 21
-------
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
50
40
V)
•O
ra 30
V)
o
« 20
o
10
NOx
] 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.
September 2007
Page 22
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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-than-
required 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 re-
powered 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
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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 S WPPPs 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
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in the McGraw-Hill count of projects, but may only require one NOT. Further complicating the
ability to track NOT trends is that individual construction sites may obtain more than one NOT
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 25
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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% Tab|e 4. Contribution by state of NOIS Inc|uded
of the national total value of jn the Nationally Representative Sample (2006)
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 ^OIE. CT data include only NOIs for projects greater than 5 acres,
1 J 2006 South Carolina are incomplete.
Sample of 20 States. 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.
TX
CA
FL
AL
MN
PA
NM
IL
NY
SC
MO
UT
ID
NV
MA
KY
AK
NH
AR
CT
Percent of 2006 NOIs
20.5%
19.2%
10.4%
8.1%
6.1%
4.8%
4.2%
4.0%
3.6%
2.8%
2.7%
2.4%
2.1%
1 .9%
1 .6%
1 .5%
1 .2%
1 .2%
1 .2%
0.4%
September 2007
Page 26
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Table 5: Availability and Completeness of Data From EPA Permitted and Authorized States
State Surveyed
Alaska*
Alabama
Arkansas
California
Connecticut
Florida
Idaho*
Illinois
Kentucky
Massachusetts*
Minnesota
Missouri
New Hampshire*
New Mexico*
Nevada
New York
Pennsylvania
South Carolina
Texas
Utah
Overall
Complete
Complete
Occasional incomplete records.
Complete
Data unavailable for projects below
5 acres.
Complete
Complete
Complete
Occasional incomplete records.
Complete
Complete
Complete
Complete
Complete
Complete
Data unavailable for January and
February 2003.
Complete
Data unavailable for coastal
counties for several months in
2006.
Complete
Occasional incomplete records.
Acreage
Occasional incomplete records.
No acreage data available.
Occasional incomplete records.
Occasional incomplete records.
All projects greater than 5 acres.
Complete
Occasional incomplete records.
Occasional incomplete records.
No acreage data available.
Occasional incomplete records.
Occasional incomplete records.
No acreage data available.
Occasional incomplete records.
Occasional incomplete records.
Complete
No acreage data available for 2003.
Complete for 2004-2006.
Occasional incomplete records.
Occasional incomplete records for 2003-
2005.
No acreage data available for 2006.
Occasional incomplete records.
Complete
* 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.
September 2007
Page 27
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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.
Figure 10: Nationally Representative Trend in NOI Submissions, by
Acreage Disturbed, Based on a Sample of 20 States
4.000
2003
2004
2005
2006
Year
* 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
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National Trend in NOIs Submitted by Acreage Disturbed, Normalized by Number of
Construction Projects. As an alternative to tracking the trend in NOT submissions per dollar
of construction value, the trend in NOT 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
September 2007 Page 29
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While these adjustments improve the metric, Figure 11 still does not indicate the percentage
of sites in compliance with the NOT submission requirement. The denominator ("Number of
Projects") still overestimates the number of projects requiring an NOT 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 NOT submissions, and shows that the
percentage of construction projects with NOIs increased by 63% from 2003 to 2006.
Figure 11: Nationally Representative Trend in NOI Submissions, by
Acreage Disturbed, Based on a Sample of 20 States (Adjusted)
2003
2004
2005
2006
Year
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
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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.
Figure 12: Trend in NOI Submissions for 20 States
60,000
50,000
40,000
£ 30,000
£
o
* 20,000
10,000
2003
2004
2005
2006
Year
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
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Figure 13: Ratio of NOI Submissions to Total Construction Projects
0.30
0.25
0.20
0.15
0.10
0.05
0.00
AK HM MN AL NH CA PA
MA NY UT TX MO
State
IL KY AR SC FL NV CT
12003
12004 D2005
12006
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
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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 33
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. 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 34
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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 CC>2. Combustion
activities also generate emissions of methane (CtLi) and nitrous oxide (N2O), however
such emissions have not been estimated.
. Electricity and fuel combustion emission estimates assume national average CC>2
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-CC>2 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 CC>2 emissions in units of teragrams of CC>2 equivalent (Tg CC>2 Eq.).
Table 6: Carbon Dioxide Emissions from Construction, 2002
Source Emissions, Tg CO2 Eq.
Fossil Fuel Combustion
Electricity
Total
84.7
29.4
114.1
September 2007
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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 (CCh), methane (CtLi), 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 CC>2 equivalent (Tg CC>2 Eq.). This measure uses
global warming potential of each gas relative to CC>2. 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*
80
60
LLI
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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
(A
O
2,000
1,500
. 1,000
to
O
O
500
0
1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005
Year
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
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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 one-
stage 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
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Endnotes
1 http://www.census.gov/const/C30/statead.pdf
2 http://www.census.gov/const/www/C40/table2.htmltfannual
3 https://www.usgbc.org/ShowFile.aspx?DocumentID= 1095 (accessed Dec 2006)
4 htto://www.usgbc.org/LEED/AP/ViewAll.asDx?CMSPageID=280& (accessed Nov 2006)
5 http://spcl89.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
1: The State of Construction and Demolition Debris Recycling in Florida Report - 2001.
http://www.dep.state.fl.us/waste/categories/recvcling/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/S W_Managed_in_MD_Report_C Y_2005. pdf
14 The Missouri Solid Waste Composition Study, 1999. http://www.map-
inc.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
Kittle 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
18http://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
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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 ofNDA 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
32http://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/mover/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 fromNikos Singelis. EPA Office of Water, Water Permits Division. December 15, 2006.
42 EP A'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
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