United States
Environmental Protection
Agency
Office of Policy
(1807T)
November 201 3
EPA 100-K-13-014
Evaluation of the
Environmentally
Preferable
Purchasing
Program
Promoting Environmental Results
Through Evaluation
-------
TABLE OF CONTENTS
EXECUTIVE SUMMARY
CHAPTER 1 | INTRODUCTION
Introduction to EPP Program and Purpose of Evaluation 1-1
Report Organization 1-1
EPP Program Logic Model 1-2
Evaluation Scoping Challenges 1-5
Defining the Boundaries of the EPP Program 1-5
Identifying EPP's Major Program Activities 1-6
Data Availability 1-7
EPP Product and Service Sectors Selected for Evaluation 1-7
Electronics 1-8
Building Products 1-10
Hospitality and Travel 1-12
Evaluation Questions 1-14
Questions on EPP Outcomes Specific to the Federal Government 1-14
Broader Evaluation Questions (Beyond the Federal Government Realm) 1-15
CHAPTER 2 | METHODS
Use of Existing Data 2-1
Cross-Sector Federal Data Sources Reviewed 2-1
GSA Advantage 2-1
Federal Procurement Data System - Next Generation (FPDS-NG) 2-2
Other Federal Sources of Comprehensive EPP Purchasing Data 2-3
Electronics Purchases Data Sources and Analytic Approaches 2-5
EPEAT 2-5
FEC 2-5
Building and Construction Product Data Sources and Analytic Approaches 2-6
Agency-Specific Sources for Building and Construction Purchasing Data 2-6
GSA Schedule Data 2-7
Mini-Market Analysis 2-8
Other Building and Construction Product Data Sources 2-12
Hospitality and Travel Data Sources 2-13
Existing Data Sources on Non-federal Green Purchasing Trends 2-13
States 2-13
-------
Universities 2-14
Other Non-Federal Institutional Purchasers 2-14
Data on Use of EPP Website 2-75
New Data Collections 2-15
Survey of Federal Purchasers 2-75
Identification of Survey Participants 2-16
Survey Mode 2-17
Overview of Re spondents 2-79
Survey Analysis 2-20
Interviews 2-24
Strengths and Weakness of the Methodology 2-29
Strengths 2-29
Limitations 2-29
CHAPTER 3 | FINDINGS
Question 1: Changes in Federal Purchaser Attitudes toward Green Purchasing 3- 7
Introduction 3- 7
Key Findings 3-2
General Awareness of and Attitudes toward Environmentally Preferable Purchasing 3-3
Advantages and Disadvantages of Environmentally Preferable Purchasing 3-5
Importance of Environmental Attributes in Purchasing Decisions 3-7
Question 2: Changes in Federal Purchaser Behavior Regarding Green Purchasing 3-9
Introduction 3-9
Key Findings 3-9
General Environmentally Preferable Purchasing Behavior 3-10
Incorporating Green Criteria into Agency Purchasing 3- 72
Responsiveness to Executive Orders 3-14
QuestionS: Federal Purchases of Green Products and Services 3-75
Introduction and Key Findings 3- 75
Electronics Sector 3-75
Building and Construction Products 3-18
Furniture 3-79
Carpet 3-27
Question 4: Leading by Example 3-23
Introduction 3-23
Key Findings 3-24
Survey Evidence of Leading by Example 3-24
Interview Evidence of Leading by Example 3-26
EPA Participation in FEC 3-27
-------
QuestionS: Environmental Benefits of Federal Green Purchases 3-32
Introduction 3-32
Key Findings 3-32
Calculation of Environmental Benefits of Federal EPEAT Purchases 3-32
Impact of EEBC Assumptions on Total Environmental Benefits of EPEAT 3-35
Question 6: Use and Influence of EPP Program Outputs 3-37
Introduction 3-37
Key Findings 3-38
Use and Helpfulness of EPP Program Outputs 3-38
EPEAT and Other Electronics 3-39
Building and Construction Products 3-47
Hospitality and Travel 3-45
Influence of EPP Outputs on Purchasing Attitudes and Behaviors 3-45
Standards Development 3-47
Question 7: EPP Program Coordination with Other Federal Agencies 3-50
Introduction 3-50
Key Findings 3-50
Electronics 3-50
Standards Development 3-54
Other Electronics Efforts 3-54
Building Products 3-54
Standards Development 3-54
Other Building Product Efforts 3-55
Travel and Hospitality 3-55
Standards Development 3-55
Other Travel and Hospitality Efforts 3-55
Other Collaborative Efforts 3-56
Interview Suggestions for Improving Future Collaborations 3-56
Question 8: Federal Electronics Challenge 3-57
Introduction 3-57
Key Findings 3-58
Notes on this Analysis 3-59
Overview of FEC Activities 3-59
Power Management 3-60
End of Life 3-65
Question 9: Federal Electronics Challenge and EPEAT Purchases 3-69
Introduction and Key Findings 3-69
Electronics Purchase Data 3-70
Proportional Levels of EPEAT Purchases and the 'Early Adopter' Hypothesis 3-74
FEC Program Participation 3-78
in
-------
Trends in EPEAT Certification Levels among FEC Partners 3-79
Question 10: Use of EPP Outputs Outside of the Federal Government 3-81
Introduction 3-81
Key Findings 3-81
Overall EPEAT Impacts: Non-Federal Buyers 3-82
Sales and Associated Environmental Benefits of EPEAT Electronics 3-82
State Trends 3-86
General Trends 3-88
Trends in Northeastern States 3-89
Electronics 3-90
State Electronics Challenge 3-97
Building and Construction Products 3- 93
Hospitality and Travel 3-94
University Trends 3-95
General Trends 3-95
Electronics 3-95
Building and Construction Products 3-96
Hospitality and Travel 3-96
Trends among Other Non-Federal Institutional Purchasers 3-96
General Trends 3-96
Electronics 3-97
Building and Construction Products 3- 97
Hospitality and Travel 3-98
Question 11: Use of Voluntary Consensus Standards by Manufacturers 3-99
Introduction 3-99
Key Findings 3-99
Use of the IEEE 1680 (EPEAT) Standards by Electronics Manufacturers 3-100
Use of Voluntary Consensus Standards by Building Product Manufacturers 3- 702
Use of the ASTM Green Meetings and Events Standards by Industry Participants 3- 704
Evaluation Question 12: Success Factors for Voluntary Consensus Standards 3-705
Introduction 3- 705
Key Findings 3- 706
Market Success Factors 3- 706
Other Success Factors 3-777
Question 13: EPP Effects on the Marketplace 3-775
CHAPTER 4 | RECOMMENDATIONS
EPP Standards Development and Promotion 4- 7
Other EPP Resources for Purchasers 4-2
Additional Research 4-3
IV
-------
Procurement Data Recommendations 4-4
Measurement Recommendation 4-5
APPENDICES
Appendix A. EPP Program Activities
Appendix B. Survey Instrument
Appendix C. Survey Results by Survey Question
Appendix D. Interview Guides
Appendix E. Interview List
-------
EXECUTIVE SUMMARY
EPA's Environmentally Preferable Purchasing (EPP) Program was established in 1993 by Executive
Order 12873, "Federal Acquisition, Recycling and Waste Prevention." It has been reaffirmed and
expanded by subsequent Executive Orders, most recently Executive Order 13514, "Federal Leadership in
Environmental, Energy, and Economic Performance," in 2009. EPP is administered by EPA's Office of
Pollution Prevention and Toxics (OPPT), and is a high-priority area for the office. EPP activities include
taking a leadership role or participating in the development of product and service standards, creating
procurement guidance, developing model contract language, and developing tools to help buyers assess
specific products and services. The program's objectives are to achieve significant reductions in the
environmental footprint of federal purchasing, and to make the overall consumer marketplace more
environmentally sustainable through federal leadership.
OPPT requested a program evaluation to better understand EPP outcomes, in terms of quantitative
changes in spending on environmentally preferable products and services, resulting environmental
benefits, and the influence and utility of EPP activities and resources within the federal government and
in the broader marketplace. EPA's Evaluation Support Division (ESD) awarded funding to OPPT under
EPA's Program Evaluation Competition (PEC) to support the evaluation. ESD contracted with Industrial
Economics, Incorporated (lEc) to conduct the evaluation.
The evaluation was guided by 14 questions (see the text box on the next page). These include questions
on EPP outcomes specific to the federal government (questions 1-9) and beyond the federal realm
(questions 10-13). Question 14 inquires about recommendations for the program moving forward. Given
the breadth of topics covered by the evaluation, and the range of activities undertaken by the EPP
Program, we were not able to examine EPP's activities in every product and service sector that the
program has worked on. lEc worked with EPA to select three sectors to focus on for this evaluation:
electronics, building and construction products, and hospitality and travel services. Chapter 1 describes
EPP's activities and the criteria for selecting the sectors.
lEc used several research methods to answer the evaluation questions, detailed in Chapter 2. First, lEc
conducted an exhaustive search for a comprehensive, cross-sector data source for federal environmentally
preferable purchasing data. As discussed in Chapter 2, no comprehensive source of federal purchasing
data exists. Experts in the federal acquisition community interviewed for this evaluation concur that the
government's current inability to track environmentally preferable purchasing information in a uniform
manner is a major challenge facing the federal procurement community. As such, lEc relied on a mix of
methods for this evaluation, including existing data at the sector level, a survey effort, and interviews. lEc
surveyed more than 2,500 purchasers from across the federal government, and studied differences in
purchasing attitudes and behaviors for purchasers with low exposure to EPP Program resources versus
those with high exposure, hypothesizing that those with higher exposure would demonstrate more
environmentally preferable attitudes and behaviors. Moreover, we compared the results of our survey to
ES-1
-------
EPP EVALUATION QUESTIONS
Questions on EPP Outcomes Specific to the Federal Government
1 • How has federal purchaser awareness of green products and services changed since the 2001 baseline
assessment?
2. How have federal agencies changed purchasing of green products and services since the 2001 baseline
assessment, including incorporating green criteria into specifications and contract language?
3. What are the outcomes of these purchasing changes in terms of changes in the proportion of green products
and services purchased by federal agencies?
4. Is EPA leading by example in terms of purchasing behavior for green products and services?
5. What are the outcomes of federal green purchases in terms of reduced energy use and associated greenhouse
gas emissions, reduced water use, and reduced use of hazardous materials?
6. How have the EPP Program's outputs, such as technical assistance, information dissemination, decision tools,
standards, and policy and contract language, been utilized by federal agencies?
a. How have EPP activities contributed to purchasing changes at federal agencies?
7. How effective is the EPP Program in coordinating with green purchasing programs at other federal agencies?
8. The Federal Electronics Challenge (FEC), a key EPP priority area, has reported an apparent decline in energy
savings from 2009 to 2010. Is this decline in reported energy savings indicative of backsliding on energy savings
behavior reported to FEC?
a. If yes, why has backsliding occurred?
b. If yes, what changes are needed within FEC to address backsliding?
9. How effective is the FEC's voluntary approach in promoting purchases of EPEAT-labeled electronics among
federal agencies?
Broader Evaluation Questions (Beyond the Federal Government Realm)
10. How have the EPP Program's outputs, such as technical assistance, information dissemination, decision tools,
standards, and policy and contract language, been utilized by purchasers outside of the federal government,
including state and institutional purchasers?
11. To what extent are manufacturers using the voluntary consensus standards that EPA has helped to develop?
12. What factors influence the extent to which the voluntary consensus standard approach is successful in
designating and promoting green products and services?
13. How has EPP affected the availability of green goods and services in the marketplace?
14. Should EPA consider changes in EPP's future approach to promoting green products and services?
a. If yes, what changes may be appropriate given resource constraints, changing regulatory requirements, and
other external factors?
ES-2
-------
results of a 2001 baseline assessment that addressed similar topics; we describe changes in federal
purchaser awareness, attitudes, and behaviors between 2001 and 2013. In addition, we conducted
interviews with more than 40 individuals, including EPP staff, hospitality and travel stakeholders, EPA's
Office of Acquisition Management, federal purchasing managers, non-federal purchasing managers,
General Services Administration (GSA) procurement contacts, and standards stakeholders. The mix of
methods used for each sector is summarized below:
• Electronics: Rich existing data sources are available for the electronics sector, which includes EPP
activities on the Electronic Product Environmental Assessment Tool (EPEAT) and the Federal
Electronics Challenge. Therefore, we rely heavily on existing data for quantifying the impacts of the
EPP Program on the electronics sector, and we also collect information on use of the EPEAT standard
and other green electronics purchasing attitudes and behavior through a survey effort described
below, and through interviews.
• Building and construction products: For the building and construction product sector, we use a mix
of methods to explore EPP impacts, including survey questions on purchaser attitudes and behaviors
relative to purchases in this sector, interviews, and case studies of manufacturers.
• Hospitality and travel: lEc was not able to identify a robust source of existing purchasing data for
hospitality and travel services, and the sector does not have mature outcomes that we were able to
survey purchasers about; therefore, we relied primarily on qualitative research to answer the
evaluation questions for this sector.
The report organizes findings by evaluation question in Chapter 3; we provide key findings by
evaluation question below.1
QUESTION 1: CHANGES IN FEDERAL PURCHASER ATTITUDES TOWARD GREEN PURCHASING
• We found clear evidence of a broad shift among federal purchasers toward greater awareness
and more positive attitudes toward EPP. A strong majority of purchasers report having positive
views toward EPP in general (see Exhibit ES-1) and purchasers appear to be accepting a greater
degree of responsibility for bringing environmental considerations into their purchasing decisions.
Both of these findings represent distinct differences from the results of the 2001 study. Furthermore,
individuals who have been purchasers for three or more years report becoming more knowledgeable
and more favorably inclined toward EPP over that time.
EXHIBIT ES-1. CHANGES IN ATTITUDE OVER THE PAST THREE YEARS
Over the PAST THREE YEARS, has your attitude
towards environmentally preferable purchasing
become more favorable, less favorable, or
stayed the same?
LESS
FAVORABLE
4.9%
STAYED THE
SAME
49.7%
MORE
FAVORABLE
42.8%
DON'T KNOW
2.6%
1 As lEc's response to Question 13 summarizes information provided in findings for Questions 10-12, we omit Question 13 findings from the
Executive Summary.
ES-3
-------
• Purchasers today identify higher cost and several factors related to a lack of information as the
key disadvantages of EPP. In contrast, the 2001 study indicated that the key problems at that time
were a perceived lack of quality for environmentally friendly products and a lack of support from top
management; these are no longer major concerns for most purchasers.
• Purchasers are giving more importance to environmental considerations in their purchasing
decisions than they did in the 2001 study. At that time, it was rare for purchasers to explicitly
consider environmental factors when purchasing goods or services. Now, most purchasers say that
environmental characteristics are an important consideration. While most purchasers do not give
particularly high priority to environmental factors compared to other product attributes, neither do
they ignore them.
QUESTION 2: CHANGES IN FEDERAL PURCHASER BEHAVIOR REGARDING GREEN PURCHASING
• Environmentally preferable purchasing activity is much more widespread now than it was at
the time of the 2001 baseline assessment. Similarly, many individuals who have been federal
purchasers for at least three years indicate that their levels of environmentally preferable purchases
have increased over that time. Thus, consistent with the shift in attitudes described in Evaluation
Question 1, we found that federal purchasers as a group have changed their behavior to engage in
more environmentally preferable purchasing.
• Nonetheless, EPP activity is still not routine. Most purchasers consider environmental factors
occasionally, but do not buy environmentally preferable products or services at particularly high rates.
• Purchasers rely heavily on materials developed by their own agencies and departments and on
the Federal Acquisition Regulation (FAR) to guide their purchasing decisions. This underscores
the need for interagency collaboration if the EPP Program is to maximize its impact on federal
purchasing behavior.
• Interviews with a small number of purchasing policy managers indicate that GSA and the
Department of Energy (DOE) have taken substantial actions to incorporate environmental
criteria into their own purchasing, including many of the standards the EPP Program helped to
develop. These agencies are leaders in this field; other agencies' efforts appear less robust.
QUESTION 3: FEDERAL PURCHASES OF GREEN PRODUCTS AND SERVICES
• Comprehensive trend data on federal purchases are available for the electronics sector only and
specifically for purchases of EPEAT products. Comparable data are not available for the products
certified to the building and construction standards reviewed in this evaluation, and we cannot
extrapolate the limited information available for building and construction product sales to the federal
government as a whole. No purchasing data are available on changes in federal hospitality and travel
associated with EPP activities.
• Total EPEAT sales to the federal government increased 50% from 2008 - 2010, as shown in
Exhibit ES-2 below.
ES-4
-------
EXHIBIT ES-2. EPEAT UNIT PURCHASES BY THE FEDERAL GOVERNMENT
Desktops
Monitors
Laptops
Integrated Systems
Total
2008
577,260
181,141
213,275
0
971,676
2009
1,156,682
1,134,811
644,564
4
2,936,061
2010
515,184
unknown
561,852
111,187
unknown
Source: data originally collected by the Information Technology Industry Council and reported to the Green
Electronics Council. Provided to lEc through personal correspondence with Cate Berard, EPA, Dec. 14, 2011.
Total EPEAT purchases by the federal government increased from 2008 to 2010, but the pattern of
growth was not steady over that period. Purchases tripled from 2008 to 2009: laptops, desktops, and
monitors all showed a substantial increase. Desktop purchases fell sharply in 2010, while the decline
for laptops was more modest; notably, laptops accounted for a higher number of EPEAT purchases
than desktops in 2010. This mirrors a more general market-wide shift away from desktops and toward
laptops.
• Data on non-EPEAT computer sales to the federal government are not available, which
precludes estimating the overall proportion of federal EPEAT sales. EPEAT purchases by the
federal government decreased by about 36% from 2009 to 2010 (excluding monitors, for which data
was not available in 2010). We suspect this drop may have been driven by broader trends in agency
budgets (i.e., a sharp increase in purchasing due to the stimulus of the American Recovery and
Reinvestment Act, followed by subsequent cutbacks). However, analysis of data on non-EPEAT
computer sales would be required to confirm this suspicion.
QUESTION 4: EPA LEADING BY EXAMPLE
• EPA does not track its proportion of environmentally preferable versus conventional
purchases. This seriously hinders the ability to evaluate EPA's performance compared to other
agencies. Reliable purchasing data is a critical need for any future efforts to evaluate EPA's
performance in this area.
• Survey data are somewhat mixed, but on the balance, indicate that EPA purchasers buy more
environmentally preferable products and services than non-EPA purchasers. This appears to be
due to a small group of EPA purchasers, rather than a widespread Agency-wide effect.
• While we have limited interview data, our interviews indicate that EPA has taken some steps to
green its own purchasing, and is using purchasing tools to promote procurement of environmentally
preferable electronics, building and construction products, and office supplies.
• Many EPP staff view leading by example as a secondary concern for the program compared to
efforts to develop standards and other resources that could have a broader impact on the market.
• EPA offices participate in the FEC at rates well above the federal government as a whole. EPA
FEC partners' performance is also well above other FEC partners with respect to EPEAT purchases
and enabling rates of Energy Star power management settings.
ES-5
-------
QUESTION 5: ENVIRONMENTAL BENEFITS OF FEDERAL GREEN PURCHASES
• The environmental benefits of federal EPEAT purchases are substantial. In 2010, the benefits of
federal EPEAT purchases were roughly equivalent to eliminating: the annual electricity consumption
of 25,000 average U.S. homes; the greenhouse gas emissions of 40,000 U.S. cars for one year; and the
solid waste generation of 252 U.S. households for one year. See Exhibit ES-3 below for more details
on environmental benefits.
EXHIBIT ES-3. ENVIRONMENTAL BENEFITS FROM FEDERAL GOVERNMENT EPEAT PURCHASES
BENEFIT CATEGORY
Electricity
Primary Materials
Air Emissions (including greenhouse gases)
Greenhouse Gas Emissions
Water Emissions
Toxic Materials
Solid Waste
Hazardous Waste
UNIT
Megawatt- hours
Metric tons
Metric tons
Metric tons carbon
equivalent
Metric tons
Metric tons
Metric tons
Metric tons
YEAR
2008
203,175
359,004
829,300
38,140
1,737
24
328
987
2009
885,263
1,572,906
3,565,784
165,919
7,556
91
1,379
3,439
20101
293,234
525,582
1,212,922
56,081
2,548
31
503
1,308
1 2010 figures do not include any benefits from monitor purchases and thus understate actual benefits.
• There is substantial year-to-year variability in the benefits of federal EPEAT purchases. These
fluctuations are driven by the number of products purchased, the type of products purchased
(especially laptops versus desktops), and assumptions on the per-unit environmental benefits of each
product type.
• Because of the nature of the assumptions used to calculate environmental benefits, these estimates
should be viewed as approximations rather than precise measurements.
• Due to a lack of purchasing data and tools to quantify benefits, estimates of the environmental
benefits of federal purchases are not available for the building and construction products or travel and
hospitality sectors.
QUESTION 6: USE AND INFLUENCE OF EPP PROGRAM OUTPUTS
• Direct use of EPP outputs such as model contract language and EPP policies by federal
purchasers is limited. However, all EPP outputs tested in the survey were rated moderately
helpful or very helpful by a majority of purchasers who have used them. Purchasers rely heavily
on agency-specific purchasing policies and guidelines in their purchasing decisions. Thus, the EPP
Program may have an indirect influence on purchasers through contract language and other EPP
outputs adopted by agencies and incorporated in agency-specific purchasing policies. The survey was
unable to explore indirect relationships.
ES-6
-------
• In general, higher exposure to EPP outputs is statistically associated with current greener
purchasing behavior. There is a statistically significant relationship between the level of exposure to
EPP outputs and the percent of purchases that are environmentally preferable. However, we found no
relationship between exposure to EPP outputs and changes m purchasing behavior over the last 3
years.
• Federal buyer use of standards that EPP helped to develop has mixed findings from the survey.
EPP staff helped develop voluntary consensus standards in several sectors. On one hand, a high
percent of purchasers who regularly purchase building and construction products looks for the carpet,
floor coverings, and gypsum board standards that EPP helped to develop. Also, respondents with
higher exposure to EPP outputs were more likely to consider environmental factors in determining
"best value" (59.6% versus 49.5%); this difference is statistically significant. On the other hand, only
33% of electronics purchasers report looking for EPEAT, and about half of purchasers cannot
estimate the percent of their spending on products certified to EPEAT or to the building and
construction standards. Importantly, purchasers who use these standards are loyal users. In other
words, once purchasers start using a "green" standard, they generally use it for the majority of
relevant purchases.
• Interviewees indicate that EPP made meaningful and significant contributions to the voluntary
consensus standards featured in this evaluation - a key output of the EPP Program. EPP
catalyzed the development of the standards and brought credibility and rigor to the process. EPP's
participation also resulted in more environmentally protective standards.
QUESTION 7: EPP PROGRAM COORDINATION WITH OTHER FEDERAL AGENCIES
• Interviewees indicate that EPP played a key role in moving the electronics, building products,
and travel and hospitality sectors toward multi-stakeholder, multi-attribute standards.
Interviewees also report that EPP's involvement in standard development processes resulted in these
standards being more protective of the environment.
• EPP worked effectively with other agencies on several green purchasing efforts including:
EPEAT through the Federal Electronics Stewardship Workgroup; green building products through the
Federal Green Construction Guide; and green travel and hospitality through the Region 9 Green
Meetings and Conference Policy (GCMP). Interviewees noted EPP's strategic guidance and
leadership in these initiatives.
• More collaboration with GSA is needed to incorporate travel standards that EPP supported into the
Federal Travel Regulations.
QUESTION 8: FEDERAL ELECTRONICS CHALLENGE
In 2010, the program results that FEC submitted to the Pollution Prevention Division (PPD) showed a
35% downturn in energy savings and greenhouse gas emissions reductions between 2009 and 2010. Our
analysis probed the extent to which this decline is attributable to backsliding versus other factors.
• We found that of the 35% decrease reported, only 6.1% was due to backsliding, i.e., FEC
partners engaging in less environmentally-friendly activity. The downturn in FEC's results as
reported to PPD is due to a number of factors including anomalous data points, likely caused by
human error in the reporting process; variations in the overall number of electronics products in the
ES-7
-------
system; and fluctuations in which partners reported in a given year (i.e., high numbers of partners
reporting in 2009 relative to 2010).
QUESTION 9: FEDERAL ELECTRONICS CHALLENGE AND EPEAT PURCHASES
• Overall, we found strong, albeit indirect, evidence that FEC partners purchase EPEAT
electronics at higher rates than the rest of the federal government.
o FEC partners had relatively high rates of EPEAT purchases in all years, from a low of 80.9% in
2007 to a high of 96.4% in 2009.
o The data indicate that FEC purchased EPEAT products at higher rates than the rest of the federal
government in the early years of the program. This suggests that FEC partners were early
adopters of EPEAT. However, the disparity between the FEC and the rest of the federal
government has lessened over time.
• A relatively high number of federal facilities participate in the FEC program compared to other
voluntary environmental programs. FEC partners also account for a significant fraction of all federal
EPEAT purchases. Thus, FEC has also been successful in terms of its overall reach.
QUESTION 10: USE OF EPP OUTPUTS OUTSIDE OF THE FEDERAL GOVERNMENT
• Looking across all purchasers, EPEAT's reach has grown markedly since the program's inception.
EPEAT's total sales and market share of laptop computers, in particular, have grown dramatically.
More than 50 million EPEAT certified products were purchased in the U.S. in 2010, and nearly 100
million worldwide.
• The environmental benefits of EPEAT purchases are substantial. As an example, worldwide
EPEAT purchases in 2010 produced greenhouse gas reductions equivalent to eliminating the annual
emissions from over 1 million cars in the U.S.
• EPEAT has achieved significant success among state purchasers. At least 11 states have adopted
EPEAT as a purchasing criterion for computers and monitors. Further, the State Electronics
Challenge - which was modeled after the Federal Electronics Challenge, and draws heavily on tools
developed by EPP - has expanded from the northeastern U.S. to the entire country. Third-party
surveys of state procurement officials confirm the widespread adoption of EPEAT.
• At least 13 states have adopted the NSF 140 carpet standard, and at least two states are specifying
to the BIFMA e3/Level furniture standard. Starting in January 2010, NSF 140 Platinum superseded
California Gold as the required standard for all State of California government agency carpet
purchases. As of January 2012, GSA specifies the NSF 140 standard (minimum of gold level) for
carpet; this means that five states also specify the standard by default, as these states mirror the GSA
schedule: Florida, Louisiana, Ohio, New Mexico, and Texas.
• Two states report using hospitality and travel tools developed by EPP. One state reports using the
ASTM Green Meetings and Events standards, and two states report using the Convention Industry
Council's (CIC) Green Meetings Report, which was developed by EPP. Several stakeholders who
participated in developing the ASTM Green Meetings and Events standards predict the standards will
achieve greater adoption overtime. At least one large supplier of hospitality services is already
incorporating the standards in their training and operations.
ES-8
-------
• A number of universities have adopted EPEAT as a purchasing criterion, and at least two
universities are specifying the NSF 140 carpet standard. lEc did not identify any universities that
are using other building and construction product standards and tools, or travel and hospitality
standards and tools, developed by EPP. However, we did not conduct a comprehensive review of
purchasing specifications.
• Many cities, businesses, and other non-federal purchasers have adopted EPEAT. Uptake of
other EPP tools by non-federal purchasers, outside of states and universities, has been limited.
However, the current draft of the 2012 Edition of the ICC 700 National Green Building Standard - a
consensus-based standard that received ANSI approval - includes references to NSF 140 carpet, NSF
332 resilient flooring, and ULE 100 gypsum board.
• lEc did not identify any states that are specifying to the NSF 332 resilient flooring standard or
the ULE 100 gypsum board standard. However, we did not conduct a comprehensive review of all
state purchasing specifications.
QUESTION 11: USE OF VOLUNTARY CONSENSUS STANDARDS BY MANUFACTURERS
• The Institute of Electrical and Electronics Engineers (IEEE) 1680.1 standard (which underpins
the EPEAT product registry) is widely used. As of December 2010, 54 manufacturers, including
all of the largest producers of personal computers, had products certified under the standard. There
were a total of 2,830 unique EPEAT-registered products at that time. In another sign of the
importance of the EPEAT program, when Apple briefly withdrew from EPEAT in mid-2012, it faced
a strong backlash from its customers and immediately re-joined.
• In the building products sector, two sustainability standards in particular have enjoyed
widespread adoption by manufacturers, the NSF 140 carpet standard and BIFMA-e3 furniture
standard. While only two manufacturers are using the ULE 100 gypsum board standard, they
represent the two largest players in the industry, with 50% market share in the U.S.; thus, the gypsum
board standard has also seen success with respect to uptake by manufacturers. In contrast, the NSF
332 floor covering standard has had limited uptake.
• There is not sufficient information available to determine the extent to which industry
participants are using the ASTM Green Meetings and Events standards. We found some
anecdotal evidence of meetings planners utilizing the standards, but they mostly seem to be using
them as a menu of environmentally preferable actions, rather than a firm set of criteria leading toward
certification.
QUESTION 12: SUCCESS FACTORS FOR VOLUNTARY CONSENSUS STANDARDS
• Several market success factors influence the success of voluntary consensus standards.
These include market demand drivers; the history and dynamics within specific sectors; extent of
market clarity and awareness; Executive Orders and Federal Acquisition Regulation that specify
standards; and promotion by EPP. Promoting voluntary standards is important for raising
awareness and increasing adoption; however, EPP generally lacks the authority to promote
standards. Market success factors are cross walked with specific standards in Exhibit ES-4 below.
ES-9
-------
EXHIBIT ES-4.
STANDARDS AND MARKET SUCCESS FACTORS
IEEE/EPEAT
Computers
and
Monitors
BIFMA
e3/Level
Office
Furniture
APEX/ASTM
Meetings
and Events
NSF 332
Resilient
Floorin
ULE 100
Gypsum
Board
Market demand drivers
History and dynamics
within sectors
Market clarity and
awareness
Executive Orders and
Federal Acquisition
Regulation
Promotion by EPP
Strong factor presence Weak factor presence
Factor not present
Insufficient data/too early to judge
Other findings on success factors for voluntary consensus standards include the following:
• Cost may not be as much of a barrier as is widely perceived.
• The nature of voluntary consensus standards means that EPP does not control the process. This, in
turn, often requires compromise on substance.
• Developing standards requires effective coordination across multiple parties with competing interests
and perspectives.
• Stakeholders agree that the standards are more environmentally protective with EPP's involvement,
but some question whether they are environmental "leadership" standards.
• Seemingly minor procedural details can influence the substance and content of the standards. For
example, standard development organizations' rules on membership or voting help determine the
relative influence given to different stakeholders. This in turn may affect the provisions that can be
included in a draft standard and garner sufficient support to ultimately be approved.
• EPP needs to remain continuously engaged to ensure ongoing standards improvement.
RECOMMENDATIONS
Based on the findings of the evaluation, lEc presents recommendations below. For recommendation areas
where the proposed actions are less dependent on actors or events outside of EPP, we frame
recommendations as EPP "should" undertake activities that the evaluation findings suggest are critical;
we say that EPP "should consider" undertaking activities that are not critical. However, several of the
recommendations below address challenges that the EPP Program has limited control over, including 1)
advancing the implementation and use of EPA's proposed guidelines for evaluating environmental
ES-10
-------
standards and ecolabels, which may potentially result in a list of select voluntary consensus standards
recommended for use in federal procurement, and 2) updating procurement systems used by other federal
agencies to track green purchasing. We make recommendations in these two areas because they are very
important to fulfilling EPP's mission and demonstrating the program's impact. Although EPP has limited
control over outcomes in these two areas, we think that limited, if any, progress will be made in these
areas without EPP's involvement. In these two areas, we often frame recommendations as EPP working
with other agencies, playing a leadership role, and advocating for change. This work can entail different
activities depending on the context, but in general we are referring to EPP leading the coordination of
interagency work on these issues, and EPP regularly communicating about the importance of these issues
with decision-makers within EPA and outside of the Agency. EPP is already demonstrating this type of
leadership in advancing the guidelines for evaluating standards and ecolabels; we suggest that EPP
engage in similar work to overcome procurement data challenges.
EPP Standards Development and Promotion
• The federal government should develop a list of recommended environmental standards and ecolabels
for use in federal procurement to: overcome informational barriers to green purchasing among federal
buyers by identifying recognized standards and certified products on federal procurement sites;
clarify the landscape of standards for non-federal buyers and subsequently reduce greenwashing; and
to allow EPP to promote the voluntary consensus standards that it helps to develop. As such, EPP
should continue its leadership role in discussions of formal guidelines for evaluating
environmental standards and ecolabels that can lead to the development of the above list.
• If the guidelines process moves ahead in 2013,2 and leads to the development of a widely utilized
and referenced list of environmental standards and ecolabels, then EPP should continue to
participate in the development of new voluntary consensus standards on the same scale as in
recent years, resources permitting. Given the lessons learned from the evaluation regarding
successful standards, we recommend that EPP apply the following factors when selecting future
product categories and standards development processes to engage in:
o Positive market success factors identified in this evaluation;
o Potentially high environmental benefit relative to other product categories; and
o Availability of a standards development organization appropriate for the particular standard being
considered (in terms of relevance, policies and procedures, etc.).
• If the guidelines process is not finalized in 2014, or results in a list that is not widely used or
referenced outside of EPA, then EPP should narrow its participation in new voluntary
consensus standards development moving forward. Specifically, EPP should focus on product
categories that have positive market success factors as listed in the first three rows of Exhibit ES-4,
and have a consumer audience. These product categories are most likely to have green standards
succeed, in terms of market penetration, without federal recognition and promotion. EPP may want to
consider developing federal standards (i.e., such as Energy Star and WaterSense) for product
categories that do not meet these criteria.
2 EPA published draft guidelines for public comment (http://www.epa.gov/epp/draftGuidelines/) on November 20, 2013, as this report was being
finalized.
ES-11
-------
• If the guidelines are finalized, EPP should develop and execute a promotion campaign for
federally recognized standards that emerge from the process and that EPP supports, perhaps in
collaboration with GSA and other federal partners. Survey results from this evaluation indicate that
EPEAT registered products and building and construction standards are utilized by less than one-third
of federal purchasers that report buying relevant products. We would expect that more purchasers
would procure more certified products once they are clearly identified in federal procurement
systems, but promotion may also be necessary to make substantial progress toward the 95% green
procurement requirement.
• EPP should continue to remain engaged with standards that it has worked on to date, to ensure
that environmental considerations are appropriately addressed as standards are revised.
Stakeholders have raised concerns about the potential for standards to be weakened over time with
respect to environmental protectiveness if EPP does not stay involved.
• Given that inclusion in the EO 13514 and FAR were key to EPEAT's success, EPP should work
with GSA, CEQ, OFEE, and other relevant agencies to advocate for including federally
recognized standards in the FAR.
• In future standards development processes, EPP should ensure that all EPA staff involved in
developing the standard, and ideally all federal staff, engage in an upfront dialog to ensure a
shared understanding of how the process will work and the federal goals for the standard. Lack
of upfront agreement hindered travel and hospitality standards processes in particular.
• EPP should continue to work to include building and construction standards in GSA Schedules
and in the USGBC LEED family of standards, which are key market drivers for this product
category. Currently, only the NSF 140 carpet standard is included in a GSA Schedule, and LEED has
not incorporated any of the building and construction standards that EPP has substantially contributed
to.
Other EPP Resources for Purchasers
• Given that purchasers rely more on resources developed by their own agencies than on EPP
resources, EPP should consider reviewing other agencies' purchasing policies and procedures to
see if they generally comport with EPP's model policies, contract language, and specifications.
If not, EPP should reach out to agencies to inform them about EPP tools and how they may be
beneficial in helping agencies reach the 95% green procurement requirement contained in EO 13514.
If EPP undertakes this review, it should prioritize agencies according to their level of purchasing (i.e.,
focus on the largest purchasers) and extent of purchasing in sectors for which EPP has developed
standards, tools, and resources.
• EPP should update its website to ensure that content is current, and to provide information on
federally recognized standards that it has helped to develop. The survey found that EPP's website
is the EPP resource that federal purchasers report using the most.
Additional Research
• Currently, no existing methodology or calculator exists to quantify the environmental benefits of
purchasing greener building and construction products, which limits understanding of EPP's impact
ES-12
-------
in this area. Thus, we recommend that EPP should develop environmental benefits calculators for
building and construction products that the program works on.
Similarly, no existing methodology or calculator existing to quantify the environmental benefits of
purchasing greener travel and hospitality services, which will limit understanding of EPP's impact in
this area in the future. Thus, we recommend that EPP should work to develop a methodology or
calculator for travel and hospitality, in particular for capturing the energy savings and GHG
emission reductions associated with greener air travel (or avoided air travel). The work already
developed by EPP under the City Pairs program may provide a foundation for developing a
methodology or calculator.
Federal purchasers are generally instructed to purchase goods and services that provide the "best
value" to the government. Factors included in making a best value determination can include initial
price and several other factors including past performance, product lifespan, product warranties, and
environmental and energy efficiency considerations.3 To analyze price and energy efficiency
together, the purchaser would need to know the lifecycle cost of the product, factoring in energy use.
Most simply, a lifecycle cost analysis would entail adding the initial price of the product to the
projected cost of energy use of the product over the product's lifespan. The survey results forthis
evaluation found that approximately one-third of purchasers emphasize first costs over lifecycle costs
in purchasing decisions. It can be difficult and time-consuming for purchasers to estimate lifecycle
costs; purchases may need to research product energy use and lifespans, and perform some
mathematical calculations. Thus, to address the issue of lifecycle costs and simplify the process for
purchasers, EPP should consider supporting analyses designed to develop a recommended price
premium allowance for first costs, for product categories such as electronics where significant
energy use occurs during the use of the product. Ultimately, these allowances could be
programmed into procurement systems so they are clearly visible to purchasers.
EPP should consider supporting additional research to better understand the market
penetration in the domestic private sector of standards that EPP helped to develop. Existing data
and literature provide good insights only for market penetration among states and institutions of
higher learning (with the exception of EPEAT).
EPP should consider supporting additional research to understand if and/or how the building
and construction standards that it helped to develop could be marketed internationally
(researching international markets was out of the scope of this evaluation).
EPP should consider conducting limited additional research to understand the limited use of
the BIFMA standard among federal purchasers, despite generally positive market factors, and
to investigate whether the use of this standard is higher in the private sector. We hypothesize
that BIFMA may have higher uptake in the private sector because furniture is the least commoditized
of all products included in this evaluation, and BIFMA may be more popular among higher-end
commercial buyers and consumers.
EPP should consider conducting additional research to understand the program's indirect
influence and spillover effects. This evaluation was not able to probe the indirect or spillover effects
5 Federal Acquisition Regulation, Section 8.405-1, available at: http://www.acquisition.gov/far/current/pdf/FAR.pdf
ES-13
-------
of EPP's activities, although we have indications that these effects may be substantial. EPP's diverse
audiences - including federal agencies, purchasing managers, procurement staff, state and
institutional buyers, manufacturers, suppliers, vendors, and the public - constitute a "network"
through which EPP disseminates information and tools beyond the confines of the program.
Innovative evaluation techniques, such as Social Network Analysis (SNA), may help EPP understand
how information flows from the program to its intended audiences.4
• The Federal Acquisition Institute (FAI), which administered the federal purchaser survey used for this
evaluation, provides training for federal procurement staff that covers incorporating green criteria into
purchasing. EPP should work with FAI to ensure that FAI's training reflects the barriers
identified in the federal purchaser survey.
Procurement Data Recommendations
• EPP should work with OARM and other federal agencies to facilitate tracking of green product
and service sales to the federal government via comprehensive systems updating. Barring this
change, the federal government will not be able to fully assess its performance against the 95%
green procurement requirement included in EO 13514, and EPP will not be able to assess its
own impact in a comprehensive manner, outside of EPEAT.
o EPP should work with OARM to update EPA's EAS procurement system, and any other relevant
procurement systems, to facilitate tracking of green product sales to the Agency.
o EPP should advocate for updating federal procurement systems to facilitate tracking of green
product sales, and specifically tracking of all green standards and ecolabels recognized by the
federal government.5 Although all procurement systems should be updated, EPP should prioritize
working with agencies with high levels of purchasing: GSA Advantage!; DOD EMALL; and
internal procurement systems within DHS, HHS, DOE, and other agencies with relatively high
levels of purchasing.
o EPP should work with GSA to update the Federal Procurement Data System (FPDS-NG), which
stores all federal procurements over $3000, to store green attributes associated with purchasing
data (i.e., the environmental standard or ecolabel that purchased products or services are certified
to). Updating FPDS will enable the federal government to manage green purchasing data from all
of the government's procurement systems in one central database, facilitating analysis of green
purchasing data moving forward.
4 SNA maps relationships and flows of information and knowledge between people, groups, or organizations. (Presentation by Chris Ellis, National
Oceanic and Atmospheric Administration (NOAA), "Social Network Analysis and Evaluation," 2010 Environmental Networking Evaluators Forum,
Washington D.C.) SNA typically relies on surveys of individuals within a network to understand with whom they are collaborating, on whom they rely
for information, and what types of information they have gathered. The information gathered through the surveys is then mapped to show the
pattern and strength of information flows through a network. This analysis can then be repeated after a period of time to assess how information
flows have changed. Applying SNA over time allows a series of "snapshots" of network structure, which could logically be related to immediate
program outcomes and be correlated with program activities and outputs. (However SNA does not prove that changes in network structure are the
result of program impacts.)
5 See recommendation on Section 13 for discussion on the need to expand standards and ecolabels recognized by the federal government to include
third-party standards and ecolabels.
ES-14
-------
• EPP should inform OMB about problems encountered with their data on government EPEAT and
non-EPEAT purchases, which are used for official reporting purposes. lEc does not have enough
information about OMB's data collection and QA/QC process to diagnose the root cause of the
problems, but our review of the OMB data in conjunction with manufacturer-supplied sources of
EPEAT data indicates that several of OMB's data points do not accurately reflect actual government
purchases. If the above procurement data recommendations are implemented, OMB will have access
to comprehensive federal purchasing data on EPEAT and non-EPEAT products, directly from federal
procurement systems, and will no longer need to ask agencies to self-report EPEAT and non-EPEAT
purchases. As an interim measure, OMB and EPP could consider asking the Green Electronics
Council (GEC) to gather data on sales of non-EPEAT purchases to the federal government, along
with the EPEAT sales data that GEC already collects in collaboration with the Information
Technology Industry Council (ITI). However, a potential barrier to this approach may be GEC/ITFs
ability to gather data that is not covered by manufacturers' agreements with EPEAT.
MEASUREMENT RECOMMENDATION
• Evaluation Question 8 asked about the cause of apparent "backsliding" by FEC partners. lEc's
analysis showed that actual backsliding was minimal, and the apparent backsliding was actually due
to reporting fluctuations and changes in the number of monitors in use. Using proportions as part of
FEC metrics would prevent this false appearance of backsliding. Thus, FEC should track and report
proportion-based annual metrics to PPD, in addition to the estimated energy savings it has been
reporting:
o The percentage of computers and monitors, across all FEC partner facilities, that is Energy Star-
enabled.
o The percentage of computers, monitors, and printers, across all FEC partner facilities, that is
disposed of through reuse, recycling, landfilling, and unknown disposition.
o For the new life extension area, the average lifespan of computers, monitors, and printers across
all FEC partner facilities.
We recommend that PPD use only proportion-based measures to assess FEC's performance
because absolute energy savings are driven by several factors in addition to performance of
FEC facilities, including the number of FEC reporters in a given year and annual fluctuations
in equipment use. However, we understand that FEC and PPD must continue to report FEC data on
existing measures because FEC data are aggregated with data from other programs to assess progress
on specific measures included in EPA's Strategic Plan.6
After lEc completed this evaluation, EPA decided to undertake substantial changes to the FEC program model. As a result, some of the
recommendations regarding the FEC appearing in this report may no longer be applicable to the program in its current form. Nonetheless, we have
left the recommendations in our report unchanged in order to more accurately document our evaluation of the FEC as it existed at the time of our
analysis.
ES-15
-------
CHAPTER 1 | INTRODUCTION
INTRODUCTION TO EPP PROGRAM AND PURPOSE OF EVALUATION
EPA's Environmentally Preferable Purchasing (EPP) Program was established in 1993 by Executive
Order 12873, "Federal Acquisition, Recycling and Waste Prevention." It has been reaffirmed and
expanded by subsequent Executive Orders, most recently Executive Order 13514, "Federal Leadership in
Environmental, Energy, and Economic Performance," in 2009. EPP is administered by EPA's Office of
Pollution Prevention and Toxics (OPPT), and is a high-priority area for the office. EPP activities include
taking a leadership role or participating in the development of product and service standards, creating
procurement guidance, developing model contract language, and developing tools to help buyers assess
specific products and services. The program's objectives are to achieve significant reductions in the
environmental footprint of federal purchasing, and to make the overall consumer marketplace more
environmentally sustainable through federal leadership.
Although EPP is considered a stand-alone program, it is actually comprised of several distinct efforts for
various product and service categories, led by different individuals within OPPT. EPP also engages in
cross-cutting efforts that address multiple product and service categories, such as the Federal Green
Construction Guide for Specifiers (FGCG). Moreover, the work of the EPP Program is intertwined with
EPA's broader sustainability efforts, which involve other offices at EPA beyond OPPT.
OPPT requested a program evaluation to better understand EPP outcomes, in terms of quantitative
changes in spending on environmentally preferable products and services, resulting environmental
benefits, and the influence and utility of EPP activities and resources within the federal government and
in the broader marketplace. EPA's Evaluation Support Division (ESD) awarded funding to OPPT under
the Office of Policy's Program Evaluation Competition (PEC) to support the evaluation. ESD contracted
with Industrial Economics, Incorporated (lEc) to conduct the evaluation.
REPORT ORGANIZATION
This report presents the evaluation findings, conclusions, and recommendations. The report is organized
as follows:
• The remainder of Chapter 1 presents the EPP logic model, describes the scoping challenges inherent
in evaluating the EPP Program, introduces the EPP product and service sectors selected for
evaluation, and presents the evaluation questions.
• Chapter 2 presents the evaluation methodology. lEc used several methods to assess EPP Program
outcomes. Existing data sources include: EPEAT computer and monitor sales; GSA Schedule data;
sales data collected from manufacturers; Federal Electronics Challenge (FEC) data; and FGCG
website data. lEc also collected primary data from a survey of federal purchasers and interviews with
EPP stakeholders.
• Chapter 3 presents the evaluation findings organized by evaluation question.
1-1
-------
• Chapter 4 presents recommendations for the EPP Program moving forward.
A series of appendices is attached, including: a summary table of EPP Program activities; survey
instrument; results for each survey question; interview guides; and interview list.
EPP PROGRAM LOGIC MODEL
To illustrate the various components of the EPP Program and to inform development of specific
evaluation questions, EPA and lEc developed a logic model for the program. A logic model is a graphical
representation of the relationships between program inputs, outputs, and intended changes in
knowledge/attitude, behavior, and condition. As shown in Exhibit 1-1, the key components of the model
include:
• Mission — to reduce the environmental footprint of the federal government and broadly influence
the marketplace towards more sustainable products and services.
• Inputs — resources and programmatic investments dedicated to the program: staff, contractor
support, partners, and funds.
• Activities — the specific procedures or processes used to achieve program goals. EPP Program
activities are broad and include work on standards, guidance, recognition, technical tool development,
outreach, and leadership.
• Outputs — the immediate products that result from activities and are often used to measure short-
term progress. For example, EPP outputs include environmentally preferable product standards;
procurement guidance, contract specifications, and model contract language; awards; technical
assessment tools; and the EPP website.
• Audiences — groups and individuals that EPP seeks to influence through the program's activities
and outputs. For example, EPP interfaces with procurement staff and buyers at federal agencies and
outside of the federal realm, manufacturers and suppliers, and the public.
• Knowledge/attitude (short-term outcome) — changes in knowledge, awareness, attitudes,
understanding, and skills resulting from program outputs that are designed to result from the EPP
Program. For example, EPP's procurement guidance and specifications are designed to lead to
increased awareness of environmentally preferable purchasing mandates among the purchasing
community.
• Behavior (intermediate outcome) — changes in behavior resulting from changes in knowledge and
attitudes. For example, EPP's procurement guidance and specifications are designed to first lead to
increased awareness of environmentally preferable purchasing mandates among the purchasing
community, and then lead to behavioral changes including an increased use of environmentally
preferable criteria in contracts and purchasing specifications; an increased proportion of federal
spending on environmentally preferable products and services; and ultimately an increased market
share of environmentally preferable products and services.
• Condition (long-term outcome) — the overarching goals of the program, which in EPP's case
include environmental benefits (reduction in hazardous materials incorporated into products or used
during production processes, energy conservation, and water conservation), and cost savings through
pollution prevention and energy and water savings.
1-2
-------
Finally, the logic model makes note of external factors that are beyond the direct control of the EPP
Program, but may influence program outcomes - e.g., political and economic circumstances, available
EPA budget to promote EPP, availability of federal agency budgets to buy EPP products and services,
and level of participation of standards-setting organizations in the development of voluntary consensus
standards for environmentally preferable purchasing. In addition, we list an assumption that monitoring
and evaluation activities inform learning, knowledge capture and dissemination, and programmatic
improvements.
1-3
-------
EXHIBIT 1-1. ENVIRONMENTALLY PREFERABLE PURCHASING (EPP) PROGRAM LOGIC MODEL
IISSION: To reduce the environmental footprint of the federal government and broadly influence the marketplace towards more sustains ble products and services.
ACTIVITIES
OUTPUTS
AUDIENCES
KNOWLEDGE/
ATTITUDE
BEHAVIOR
CONDITION
Standards. Spearhead
or participate in the
development of EPP
standards
Guidance. Develop
model contract
language, procurement
guidance, and related
EPP policy
Recognition. Provide
recognition and awards
(e.g. FEC)
Tools. Develop tools
(e.g. calculators) to
help buyers assess
products and services
Outreach. Develop
and disseminate
outreach and
educational materials
Leadership. Lead by
example (e.g..create
frameworks for EPP;
join FEC; integration
intoFSSI and other
interagency contract
vehicles; etc.)
EPPstandards(e.g.
IEEE/EPEAT, ULE,
BIFMA, ASTM
standards)
New/EPP procurement
guidance, contract
specs, and policies
Awards
Assessmenttools (e.g.
environmental benefit
calculators)
Website (including EPP
database); guides:
brochures; conference
exhibits and
presentations
Blanket purchase
agreements; model
contractlanguage;
MOD guidance
Manufacturers,
suppliers, and
buyers
Procurement staff
and officials in the
public and private
sectors
Federal facilities
and agencies,
manufacturers, and
suppliers
Buyers (federal,
state, and private)
Manufacturers.
vendors, buyers,
andthe public
EPA and other
federal agencies
Increased awareness
of EPP productand
service features and
standards
Increased knowledge
of EPP mandates (e.g.
EO 13514) and
awareness of EPP
contractlanguage,
specs, and policies
Increased knowledge
of awards criteria and
motivation to win
Increased knowledge
of environmental and
financial benefits of
pro curing EPP
products and services
Increased knowledge
of EPP Program. EPP
attributes, contract
language, etc.
Increased recognition
of the EPP Program
within EPAand other
agencies, and
strengthened
commitmenttoEPP
activities
BUYERS AND
PROCUREMENT
OFFICIALS (including
federal agencies, state
and regional agencies,
and institutional buyers):
• Increased use of EPP
criteria in contracts,
purchasing specs, and
policies
• Increased proportionof
federal spendingon EPP
products and services
• Increased marketshare
of EPP products and
services
MANUFACTURERS
• Increase in products
invented/redesigned to
comply with EPP
standards
• Increased marketshare
of EPP products and
services
VENDORS AND
SUPPLIERS
• Increased offering of
EPP products and
services
• Increased marketshare
for EPP products and
services
ENVIRONMENTAL
BENEFITS
• Reduced hazardous
mate rials re I eased
incorporated into
products, orused in
processes
• Reduction in total
chemical use and
hazardous chemical use
• Energy conservation
• Water conservation
FINANCIAL BENEFITS
• Costsavingsthrough
pollution prevent!on
improvements, energy
and water conservation
External factors; Political and economiccircumstances; available EPAbudgetto promote EPP; availability offederal agency budgetsto buy EPP products and
services; level of participation of standards-setting organizations in the development of voluntary consensus stan dardsforEPP.
Assumptions: Monitoring and evaluation activities inform learning, knowledge capture and dissemination, and programmatic improvements.
1-4
-------
EVALUATION SCOPING CHALLENGES
lEc aimed to conduct a focused, informative, and cost-effective evaluation of the EPP Program. To
accomplish this, we conducted initial research to address some scoping challenges posed by the EPP
Program, discussed below.
Defining the Boundaries of the EPP Program
The first evaluation scoping challenge was to determine the boundaries of the EPP Program. Although
EPP is a stand-alone program, its structure resembles a group of conceptually linked activities more than
an administratively distinct program with its own staff and funding. Activities related to promoting
environmentally preferable purchasing (broadly defined) take place in various EPA offices (including
EPA Regional offices as well as Headquarters) and in other federal government agencies. For evaluation
purposes, it is necessary to define the EPP "program" in terms that are readily understandable and easily
applied. Thus, it is important to distinguish between activities relating to environmentally preferable
purchasing in general, and specific activities undertaken by EPA EPP staff.
lEc relied on EPA's management structures and mechanisms to create boundaries for the EPP Program.
For purposes of reporting contributions toward meeting EPA's Strategic Goals, EPP is considered part of
the Pollution Prevention Program, which is housed within OPPT. Other parts of the Pollution Prevention
Program include Green Chemistry, Green Engineering, and Design for the Environment. This evaluation
focuses on activities conducted only by the EPP Program, as illustrated in the logic model. We further
define the EPP Program as utilizing only OPPT staff that 1) focus on environmentally preferable product
and service issues, and 2) are not affiliated with one of the other EPA Pollution Prevention areas. Thus,
the evaluation does not focus on activities that occur in other OPPT offices - such as the Design for the
Environment Program - or in other EPA offices - such as the development of Energy Star specifications
- except to the extent that EPP contributes to or promotes these activities. We also exclude activities
undertaken by third parties with funding obtained from Pollution Prevention Resource Exchange (P2RX)
grants, which are administered by OPPT's Pollution Prevention Program, but not by EPP specifically.
Another key issue concerned the role of Regional EPA staff in EPP activities. Based on our research,
including conversations with staff and management from the EPP Headquarters team and the Regions, it
appears that Region 9 is the Regional office with the most robust EPP Program. Region 9's EPP activity
has included:
• Active, ongoing participation with Headquarters in the development of voluntary consensus standards
for electronics products;
• Working with the State of California to insert language specifying EPEAT-registered electronics
products into the state's procurement policy; and
• Development of a Green Meetings and Conference Policy, completed in 2009, and subsequent
collaboration with the General Services Administration (GSA) to create new federal guidelines for
environmentally preferable meetings based on Region 9's policy.
The Green Meetings and Conference Policy is particularly significant, since it is one of the only EPP
Program outcomes in this sector that is sufficiently mature to be included in a retrospective evaluation
(details are provided in the EPP Product and Service Sectors Selected for Evaluation/Hospitality and
1-5
-------
Travel section).7 While Region 9 developed this policy without input from Headquarters EPP staff, there
was strong interest among EPP management in exploring the impacts of this activity further. Thus, we
included Region 9 activities within the boundaries of the EPP Program for purposes of this evaluation. No
other region reported engaging in EPP activities at the same scale as Region 9.
Identifying EPP's Major Program Activities
Aside from the issue of defining boundaries, lEc needed to develop a clear understanding of the nature
and extent of the EPP Program's major activities. The process of developing voluntary consensus
standards demonstrates the difficulties involved in teasing out EPP-specific activities. While EPA has
developed product standards and guidelines through its Energy Star, WaterSense, and Design for the
Environment programs, the EPP Program itself does not have an explicit mandate to independently
develop any product standards. Indeed, EPA is restricted in its ability to develop its own standards by the
National Technology Transfer and Advancement Act (NTTAA). The NTTAA directs federal agencies to
participate in voluntary consensus standards development and use technical standards that are developed
in this fashion.
EPP staff has played key roles in developing numerous third-party standards, including standards
developed by NSF International, Underwriters Laboratory (UL), the Institute of Electrical and Electronics
Engineers (IEEE), ASTM International, and other groups. Due to the inherently collaborative nature of
the consensus standard development process, it was difficult to precisely define the EPP Program's
involvement in voluntary standards development through a cursory examination of available information.
Thus, we conducted initial research to assess the extent to which the EPP Program can be credited with
environmental benefits that may have resulted from standards developed through a voluntary consensus
process, a challenge we refer to as an "attribution challenge."
To address this challenge, lEc considered several aspects of EPP's involvement in standard development
processes. First, we considered the general level of involvement of EPP staff involved in developing
standards. EPP made significant contributions to the development of several product and service
standards by virtue of its EPP staff leadership positions on standards development committees. In
addition, we considered whether the standard would have been as protective of the environment in the
absence of EPP staff involvement. While our scoping research provided some insight into these various
considerations, lEc conducted additional investigation into these questions as part of the evaluation, to
characterize the contribution of the EPP Program to the environmental benefits produced from voluntary
consensus standards. We gathered this information primarily through interviews with EPP staff and other
standards stakeholders. lEc did not consider the impetus behind the development of the standard as a
defining criterion for EPP's contribution. Many of the standards that members of the EPP staff were
involved in were initially advanced by manufacturers or trade associations; our charge was to investigate
whether the standard would have been as protective without EPP's involvement.
lEc also needed to better understand EPP's program activities beyond standard development. Because the
total scope of EPP's program activities was not clear from publicly available information, we spoke with
staff members working in key areas to gain deeper insight into the program's past and current efforts. As
shown on the logic model, other activities include:
7 With the exception of the Region 9 Green Meetings and Conference Policy and the Headquarters Green Meetings Report, the travel and hospitality
sector meets the criterion for an emerging category as described below in the section on EPP Product and Service Sectors Selected for Evaluation.
1-6
-------
• Developing model specifications and contract language for environmentally preferable purchasing
(e.g., the Federal Green Construction Guide for Specifiers);
• Promoting environmentally preferable purchasing through outreach mechanisms such as awards,
presentations, etc. (e.g., the Federal Electronics Challenge);
• Developing tools to help buyers assess products and services (e.g., environmental benefit calculators);
• Developing and disseminating outreach and educational materials (e.g., EPP website, guides,
brochures, and conference exhibits); and
• Disseminating information on environmentally preferable product standards and procurement
resources developed by other EPA programs (e.g., the Office of Resource Conservation and
Recovery's Comprehensive Procurement Guidelines). The activity of disseminating information
developed by other programs is particularly nebulous from an evaluation perspective, because it is
difficult to assess how much "credit" for outcomes should be given to EPP versus the program that
developed the information. This is another attribution issue that complicated this evaluation. We
explored this issue during interviews, and this report describes, to the extent possible, EPP's
dissemination of other programs' materials. However, we were not able to quantitatively assign any
environmental benefits from these activities to EPP.
Based on our scoping research, lEc compiled a summary table with the major activities undertaken by the
EPP Program (Appendix A). Note that Appendix A is current as of January 2012.
Data Availability
A third challenge in our scoping research was to identify quantitative data available to support the
evaluation. Because the EPP Program is focused on changing purchasing behavior, we were particularly
interested in identifying data sources on actual procurement of environmentally preferable products and
services, although we were also interested in locating data on other EPP Program results. The availability
of robust, relevant data helped to inform the selection of sectors for the evaluation. Data availability also
influenced the evaluation methodology by illustrating where further research and data development were
needed. For product or service categories without purchasing data, the evaluation focused on interim
program impacts, such as changes to procurement policies and contract language, and changes in
knowledge and attitudes.
lEc was able to identify a comprehensive data source for one sector (electronics); data are available on
federal and non-federal purchases of EPEAT products (which is discussed further in Chapter 2 under the
section on "Existing Data"). However, no comprehensive data source exists for federal purchases of other
environmentally preferable products or services within EPP's purview. A full discussion of existing data
is contained in Chapter 2.
EPP PRODUCT AND SERVICE SECTORS SELECTED FOR EVALUATION
The EPP Program is active in several different product and service sectors. As discussed above, it was not
possible to address all of these areas in the program evaluation. lEc therefore consulted with EPP and
ESD staff to develop criteria to use in recommending sectors to include in the evaluation. The criteria for
inclusion were as follows:
1-7
-------
• A significant level of EPP Program activity, either currently or in the past. Simply put, sectors
where EPP has had only minimal action do not reflect the EPP Program's impact as much as sectors
where EPP has been more heavily involved. We considered EPP to be heavily involved in sectors for
which there is a designated contact person within EPP; sectors that are promoted on the EPP website;
and sectors in which EPP has developed or contributed to concrete program outputs in the recent past
(sustainability standards, model contract language, etc.). Also, as discussed above, we limited this
evaluation to EPP work that is managed by OPPT staff rather than other EPA offices, since OPPT is
charged with implementing the EPP Program and is accountable for its progress. As such, we
excluded the landscaping sector from the evaluation because EPA's green landscaping work is
administered by ORCR, not OPPT. Other sectors that were excluded for this reason include: vehicles;
paper products (governed by the Comprehensive Procurement Guidelines covering recycled content,
administered by ORCR); food; and whole buildings (as distinct from building products).
• Purchasing data availability: At a minimum, the evaluation had to focus on at least one product or
service category that has federal government purchasing data available.
• Engagement with voluntary consensus standards: A key question among EPP Program
management is whether voluntary consensus standards represent an effective approach to making
products and services more sustainable. Thus, the evaluation examined sectors in which EPP staff has
led or substantially contributed to the development of voluntary consensus standards.
• Mix of mature and emerging categories: Given that this is a retrospective evaluation focused on
program outcomes, the evaluation had to include sectors where EPP has been working for several
years. However, EPP was also interested in including at least one sector where the program's efforts
are in earlier stages.
• Interest of EPP management and staff: EPP management and staff identified certain sectors as
particular priorities. One effect of this criterion was that product categories where EPP was formerly
active, but no longer has significant activities, were excluded from the evaluation. For instance, due to
a shift in program emphasis and the absence of a clear contact person, our initial scoping review did
not thoroughly examine the information available on office supplies, even though EPP had previously
worked in this area. In addition, lEc did not conduct research into fleets or food services because of a
shift in program emphasis and lack of an available contact.
Based on these criteria, lEc recommended the following sectors for inclusion: electronics, building and
construction products, and hospitality and travel services.8
Electronics
The electronics category comprises several distinct product types. The EPP Program website on
electronics includes information on computers, monitors/displays, optical and imaging equipment, and
printers/plotters, and a generic "electronics" category covering numerous products. Members of the EPP
staff have also worked on standards for televisions, servers, and mobile devices. Despite this wide range,
program activities to date have focused mainly (though not exclusively) on computers and monitors. Until
recently, the Electronic Product Environmental Assessment Tool (EPEAT), Federal Electronics Challenge
1 I EC also included the cleaning sector among the original list of sectors to be included in the evaluation; however, after discussion with EPA, we
removed this sector from the evaluation due to resource constraints.
1-8
-------
(FEC), the existing IEEE standards, and the Electronic Environmental Benefits Calculator (EEBC) all
addressed computers and monitors, and nothing else. As such, lEc recommended focusing on computers
and monitors specifically. Below, we discuss the electronics product category in relation to the selection
criteria.
• EPP Program activity: There is significant EPP activity on electronics. The two most important
areas of activity center on the EPEAT product registry and the FEC voluntary program.
o EPEAT is a listing of computer and monitor models designated as "green" by virtue of meeting
defined criteria; it bills itself as "the definitive global registry for greener electronics." At present,
to be included in EPEAT, products must be certified under the relevant IEEE 1680 standard. EPP
staff was instrumental in developing these IEEE standards for computers and monitors; two EPP
staff served as co-chairs of the sponsoring IEEE committee and also led various sub-groups. EPP
also provided funding for facilitating meetings during the standard development process, as well
as start-up funding for the Green Electronics Council (GEC), which is now self-sufficient and
manages the EPEAT program.
o EPP staff is currently involved in the development of other electronics standards, including a
ULE standard for mobile devices and an IEEE standard for servers, which may be incorporated
into the EPEAT program in the future. EPP staff was also engaged in IEEE standards
development efforts for televisions and imaging equipment; these standards were adopted in early
2013.
o In another effort closely tied to EPEAT, the EPP Program also funded the development of the
Electronics Environmental Benefits Calculator (EEBC), created by Abt Associates but currently
managed by EPA. The EEBC is used to calculate the net benefits of the entire EPEAT program
(i.e., the benefits of all EPEAT-registered product sales worldwide as compared to non-EPEAT
products).
o FEC is a voluntary partnership program for federal agencies and facilities. It encourages
purchases of EPEAT and Energy Star products, implementation of energy-saving measures (i.e.,
sleep mode), and reuse and recycling at end of life. FEC uses a reporting framework, where
partners are asked to provide data regarding their electronics purchases, use, and end-of-life
efforts on an annual basis. Through 2010, reporting was strictly voluntary, with the result being
that reporting rates fluctuated from year to year.
• Data availability: Quantitative data exist for both the EPEAT and FEC programs, as discussed in
Chapter 2 (see the "Existing Data" section). More quantitative data are readily available for
electronics than for any other product or service sector that EPP has worked on.
• Maturity: FEC began as a pilot effort in 2003, and was launched in its present form in 2004. The
EPEAT program was launched in 2006. Electronics therefore represents a fairly mature area of EPP
activity, at least with respect to computers and monitors.
• Voluntary consensus standards: As noted above, the EPP Program played a major role in
developing the IEEE 1680 standards on computers and monitors. Members of the EPP staff have
served as co-chairs of the standard development committee; led several sub-committees; and funded
facilitation efforts during the stakeholder consensus process. This experience provided a solid
foundation for an exploration of the effectiveness of the voluntary consensus standard approach.
1-9
-------
• Staff and management interest: Interest in the electronics sector was very high; the draft evaluation
questions developed by EPP staff included specific references to the IEEE electronics standards and
the FEC program.
Building Products
• EPP Program activity: The EPP Program has expended significant effort on environmentally
preferable building products. There are two major components of this effort.
o The first component is involvement in the development of a number of voluntary consensus
standards for product sustainability. One EPP staff member is the co-chair of the ASTM
sustainability working group, which oversees product sustainability standards for that
organization; EPP staff members have played major roles in other standards organizations as
well. Building product standards that EPP staff members have worked on or are currently
working on include:
• NSF/BIFMA e-3 Business and Institutional Furniture Sustainability Standard (initially
finalized 2008, revised 2010)
• NSF/ANSI 140 Sustainability Assessment for Carpet (initially finalized 2007, revised 2010)
• NSF/ANSI 332 Sustainability Assessment for Resilient Floor Coverings (draft 2007, finalized
2010)
• NSF/ANSI 336 Sustainability Assessment for Commercial Furnishings Fabric (draft 2007,
finalized 2011)
• NSF/ANSI 342 Sustainability Assessment for Wallcoverings (finalized 2010)
• NSF/ANSI 347 Sustainability Assessment for Single Ply Roofing Membranes (draft 2011)
• ULE 100 Standard for Sustainability of Gypsum Board (finalized 2010)
• ULE 105 Standard for Sustainability of Suspended Ceiling Panels and Boards (draft 2010)
• ULE 115 Standard for Sustainability of Thermal Insulation (draft 2011)
• Numerous standards that do not relate to individual product categories, such as ASTM
standards on life cycle assessment, terminology, and data collection.
o The EPP Program's second major effort in the building and construction product sector is the
Federal Green Construction Guide for Specifiers (FGCG). The aim of the FGCG is to "address
the need for a comprehensive guide for procuring environmentally preferable building products
and construction/renovation services within the Federal government," in effect providing a one-
stop shop for information on environmentally preferable building techniques and materials for
decision makers overseeing building construction projects. This document features model
specifications addressing environmental concerns for numerous building products that can be
incorporated directly into construction contracts. Work on the project commenced in 2000; the
Guide was most recently updated in 2011. Although it is intended primarily for a governmental
audience, because the Guide is publicly available, it is possible that it has been taken up by users
in the broader marketplace as well.
1-10
-------
o It is also important to note that EPP disseminates information on the efforts of other EPA
programs to develop environmentally preferable building products, including WaterSense,
Energy Star, and SNAP (Significant New Alternatives Program, concerning non-ozone depleting
chemicals), among others. Also, ORCR's Comprehensive Procurement Guidelines database has
hundreds of building products listed that meet environmentally preferable procurement
guidelines. EPP's role as an information clearinghouse may have resulted in more widespread
awareness and adoption of these environmentally preferable products. However, as noted above,
this evaluation was not able to quantitatively attribute environmental benefits to these activities.
• Data availability: Data availability for sales of building and construction products to the federal
government is limited. GSA provided limited data on sales of certified carpet through GSA
Schedules, but those data have several important limitations (see Chapter 2 - "Existing Data"). As
discussed in Chapter 2 (see the section on "New Data Collections"), lEc attempted to collect data on
sales of environmentally preferable building and construction products to federal agencies through a
"mini-market analysis" of manufacturers that sell certified products to the federal government.
However, the number of companies that provided data - and the total market share of these
participating companies - was too small to draw any general conclusions about federal sales of
environmentally preferable building and construction products.
• Maturity: For certain product categories, EPP Program activities were sufficiently mature to allow
for retrospective evaluation. Most notably, the NSF carpet standard (NSF/ANSI 140), which EPP
played a major role in developing, was first released in 2007, while the NSF/BIFMA furniture
standard was released in 2008. The FGCG was first developed in 2000 and has since gone through
multiple revisions.
• Voluntary consensus standards: EPP has done more work on consensus standards for building and
construction products than in any other area. Members of the EPP staff have participated in the
development of standards for carpet, furniture, flooring, gypsum board, wallcoverings, commercial
furnishings fabric, roofing membrane, ceiling panels, and thermal insulation, as well as standards for
environmentally preferable buildings that can include product requirements. Building products
therefore represented an excellent opportunity to evaluate the effectiveness of the voluntary
consensus standard approach.
• Staff and management interest: Again, initial conversations indicated a high level of interest in this
area from EPP staff and management. It is our understanding that EPP staff working on building
products helped develop some of the language used in OPPT's application for Program Evaluation
Competition funding. The emphasis on voluntary consensus standards also means that EPP staff and
management have a particular interest in evaluating the building products sector.
Building products represents an extremely diverse sector, covering dozens of product types from basic
construction materials (e.g., concrete, lumber), to finished products regularly purchased by individual
consumers (carpet and flooring), to services (building construction and commissioning). Limited
evaluation resources restricted lEc's ability to address each of the building products that EPP has worked
on. Thus, lEc worked with EPA to identify four building products to include in the evaluation: carpet,
floor coverings, furniture, and gypsum board. We identified these four products based on their inclusion
in the FGCG, the maturity of the standard associated with each product, and the role of EPP staff in
developing the standard. Also, it is important to note that given the scope of EPP activities, the evaluation
1-11
-------
focused on building products, rather than
architectural and engineering techniques used to
develop green and energy efficient buildings (see
sidebar).
Hospitality and Travel
The environmentally preferable hospitality and travel
sector is a very broad service sector, encompassing
environmentally preferable meetings and
conferences, environmentally preferable hotels, and
environmentally preferable travel (and in particular,
less carbon intensive aviation).
• EPP Program activity: EPP has worked with a
variety of stakeholders to develop standards and
guidelines for environmentally preferable
hospitality and travel. Activities have been
carried out at the federal level and in a few
regions:
o At the federal level, the EPP Program
worked with the Convention Industry
Council and the Green Meeting Industry
Council (GMIC), as well as a range of other
stakeholders, to develop a suite of nine
ANSI-accredited ASTM standards for
environmentally preferable hospitality,
meetings, and events. Eight of the nine
standards were approved in February 2012;
the ninth standard (Accommodations) was published in April 2013.9 According to the EPP
Environmentally Preferable Hospitality/Travel lead, the language appearing in the final ASTM
standards - though incorporating much of the substance, language, and ideas provided by the EPP
Program - differs significantly from the language and substance that the EPP Program originally
recommended. We explored this issue further during our interview with EPP staff to understand
how EPP contributed to developing the ASTM standards (see Chapter 3).
The EPP Program has also been working with GSA and several other federal agencies (as well as
other participating EPA programs) to amend federal travel guidelines and related procurement
rules, with EPP staff sitting on the steering committee for the inter-agency effort. The proposed
revisions include, for example, changes in RFP procurement language for contract airline routes
to include "GHG emissions" as one of the scoring criteria. This is a work in progress on several
fronts. While EPP has assisted GSA in developing language for some of the proposed revisions
ERA'S GREEN BUILDING WORK
EPA also works to strengthen green building
standards and certification systems, which are
used to design and construct buildings that use
less energy, water, and toxic materials; and
protect indoor air quality. EPA works with the
U.S. Green Building Council to increase the
environmental protectiveness of its LEED rating
systems, which are the most common green
building systems used in the U.S., and are
recognized and recommended by GSA for use in
federal green construction. EPA provides formal
comments on draft LEED standards, and works
to develop LEED pilot credits. EPA has also
worked to develop and improve the
International Green Construction Code, and
works to strengthen other green building
approaches including ASHRAE 189 and the ICC-
700 National Green Building Standard.
It is important to note that while EPP staff
regularly contribute to the above activities, and
in particular provide leadership in the area of
strengthening toxics provisions of green building
standards, official purview for green building
efforts at EPA rests within the Office of Policy
and its Office of Sustainable Communities. This
was one consideration in excluding green
buildings from the scope of this evaluation.
' "Sustainable Meeting Standards Now Available for Purchase as a Bundle," April 23, 2012; and "APEX/ASTM Standard on Accommodations
Published," April 12, 2013. Convention Industry Council website: http://www.conventionindustrv.org/Newsroom/headlines.aspx.
1-12
-------
(such as the revisions to the conference planning provisions of the Federal Travel Regulation), the
proposed revisions have not yet been published.10
o Region 9 developed a Green Meetings and Conference Policy, which was published in 2009.n
According to Region 9's Environmentally Preferable Lodging and Hospitality lead, the Region
developed the policy on its own, without funding or technical support from EPA Headquarters.12
Subsequently, Region 9 distributed the policy to federal facility partners in the region, and posted
the policy on its website.13
o Subsequent to developing the policy, the EPP HQ Hospitality and Travel Lead recruited a Region
9 PPD staff person to participate on the interagency committee advising GSA on developing
guidelines for environmentally preferable meetings and events. GSA has decided to create a new
version of the federal guidelines based on Region 9's Green Meetings and Conference Policy.
In addition, the Region 9 staff person has been involved in the development of ASTM standards
for environmentally preferable hospitality. She stated that she has worked on a different standard
than the HQ contact, but the two have coordinated their activities as needed.
o Region 5 has taken steps to green at least three large meetings/conferences, including the 2006
and 2007 National Community Involvement Conferences hosted by ORCR. Environmentally
preferable activities included ensuring availability of recycling bins, promoting the hotels'
environmentally preferable features, reducing paper associated with the conference, and
eliminating the bags for conference materials. At EPA's National Brownfields Conference that
was held in Detroit in 2008, EPA Region 5 led the greening efforts via a green team, which
included establishing a comprehensive recycling program at the conference center.
o In 2003-2004, a former EPP staffer served on the Convention Industry Council's Green Meetings
Task Force, and helped to develop the Task Force's resulting Green Meetings Report. The report
identifies best practices for event suppliers and event organizers.
Data availability: Existing retrospective data are not available on the EPP's hospitality and travel
activities. Region 9 is in the process of developing a database to track the use of the Region's Green
Meetings and Conference Policy, but this is still a work in progress.
Maturity: While EPP has been working on hospitality and travel for some time, key milestones such
as adopting standards and policies are just now occurring. Region 9's Green Meetings and
Conference Policy and the Convention Industry Council's Green Meetings Report are the only
specific activities that were mature enough for a retrospective evaluation. However, lEc conducted
10 In addition to the activities discussed in the main text, it should be noted that the EPP Green Meetings website
(www.epa.gov/oppt/greenmeetings/) includes a link to a "meetings assistance planning tool." It is lEc's understanding that GMIC developed the
tool independently, without technical assistance or funding from the EPP Program. See BlueGreen Meetings, http://www.bluegreenmeetings.org/;
accessed October 26, 2011.
11 US Environmental Protection Agency Region 9, Sustainable Region 9 Green Meetings and Conference Policy, 2009.
12 Green Lodging and Hospitality Lead and Pollution Prevention Coordinator, U.S. Environmental Protection Agency Region 9; telephone interview,
October 26, 2011.
13 According to one Region 10 contact, that Region is using the policy. Email communication from Robert Drake, EPA Region 10, February 23, 2012.
1-13
-------
interviews with hospitality and travel contacts that inquired more broadly about outcomes from
activities to date.
• Voluntary consensus standards: Standards have been a major focus of EPP activities in this sector.
As noted above, the EPP Program played a significant role in developing a suite of ANSI-accredited
ASTM standards for Green Meetings and Events, and previously worked with GMIC and the
Convention Industry Council to develop a standard. This experience provided a foundation for
assessing the effectiveness of the voluntary consensus standard approach.
• Staff and management interest: EPP Program staff and management expressed significant interest
in including environmentally preferable hospitality and travel in the evaluation.
EVALUATION QUESTIONS
The evaluation questions that guided this evaluation effort are below. At the beginning of this evaluation,
EPP staff provided five initial questions, many of which contained several questions in one. lEc
subsequently disaggregated the original evaluation questions, and worked with EPA to develop the
following list of 14 evaluation questions.
Questions on EPP Outcomes Specific to the Federal Government
1. How has federal purchaser awareness of green products and services changed since the 2001 baseline
assessment?
2. How have federal agencies changed purchasing of green products and services since the 2001
baseline assessment, including incorporating green criteria into specifications and contract language?
3. What are the outcomes of these purchasing changes in terms of changes in the proportion of green
products and services purchased by federal agencies?
4. Is EPA leading by example in terms of purchasing behavior for green products and services?
5. What are the outcomes of federal green purchases in terms of reduced energy use and associated
greenhouse gas emissions, reduced water use, and reduced use of hazardous materials?
6. How have the EPP Program's outputs, such as technical assistance, information dissemination,
decision tools, standards, and policy and contract language, been utilized by federal agencies?
a. How have EPP activities contributed to purchasing changes at federal agencies?
7. How effective is the EPP Program in coordinating with green purchasing programs at other federal
agencies?
8. The Federal Electronics Challenge (FEC), a key EPP priority area, has reported an apparent decline in
energy savings from 2009 to 2010. Is this decline in reported energy savings indicative of backsliding
on energy savings behavior reported to FEC?
a. If yes, why has backsliding occurred?
b. If yes, what changes are needed within FEC to address backsliding?
1-14
-------
9. How effective is the FEC's voluntary approach in promoting purchases of EPEAT-labeled electronics
among federal agencies?14
Broader Evaluation Questions (Beyond the Federal Government Realm)
10. How have the EPP Program's outputs, such as technical assistance, information dissemination,
decision tools, standards, and policy and contract language, been utilized by purchasers outside of the
federal government, including state and institutional purchasers?
11. To what extent are manufacturers using the voluntary consensus standards that EPA has helped to
develop?15
12. What factors influence the extent to which the voluntary consensus standard approach is successful in
designating and promoting green products and services?
13. How has EPP affected the availability of green goods and services in the marketplace?
14. Should EPA consider changes in EPP's future approach to promoting green products and services?
a. If yes, what changes may be appropriate given resource constraints, changing regulatory
requirements, and other external factors?
14 An earlier version of this question asked about FEC's "voluntary reporting approach." We subsequently deleted the word "reporting" to clarify
that we are asking about the efficacy of the program itself rather than the voluntary data collection method specifically.
15 An earlier version of this question referred to "manufacturers and purchasers"; we subsequently dropped "purchasers" from this question.
Purchaser use of standards is addressed in evaluation questions 6, 10, and 12.
1-15
-------
CHAPTER 2 | METHODS
This chapter presents the methods used in the EPP evaluation. We first discuss use of existing data, and
then discuss new data collections including the survey, interviews, and mini-market analysis. A summary
table of methods by evaluation question is presented at the end of the chapter in Exhibit 2-7.
USE OF EXISTING DATA
Existing data were necessary to address evaluation question 3 regarding changes in purchasing outcomes,
and subsequently evaluation question 5 on the environmental impacts of those changes, because it was not
feasible for lEc or for federal agencies to attempt to collect new data, retrospectively, on actual purchases.
In addition, existing data were needed to address questions 8 and 9 on the FEC.
lEc conducted a search for a comprehensive, cross-sector data source for federal environmentally
preferable purchasing data, and contacted experts in GSA and the Department of Defense (DOD) to
inquire about the availability of such a data source. GSA and DOD experts confirmed our research that
such a source does not exist, and added that the government's current inability to track environmentally
preferable purchasing information in a uniform manner is a key challenge facing the federal procurement
community. In this section, we first document sources reviewed and their shortcomings. Then, we discuss
lEc's strategy of using data sources specific to product sectors to support the evaluation. Finally, we
discuss existing data sources that lEc identified on environmentally preferable purchasing trends outside
of the federal government.
Cross-Sector Federal Data Sources Reviewed
GSA Advantage
lEc researched the availability of environmentally preferable purchasing data from GSA Advantage
(www.gsaadvantage.gov/X an online procurement tool that GSA offers to all federal agencies.16 GSA
Advantage offers a variety of products in multiple categories, including building and construction
products and electronics. Federal buyers shop online using various search filters, including the following
"green" icons: BioPreferred, CPG, Energy Star, EPA Primary Metals Free, EPEAT, FEMP, Low VOC,
NESHAP, PRIME, SNAP, and WaterSense.17 Although many of the standards that EPP has worked on
16 In certain circumstances, state and local governments may also use GSA Advantage. For purposes of this evaluation, our data request was
restricted to federal purchasing data.
17 When lEc prepared the data request in October 2011, the following green icons were also listed on GSA Advantage: Biodegradable, Forest
Stewardship Council, Green Guard, and Green Seal. GSA had these icons on the site but removed them promptly after receiving some criticism
that GSA needed a transparent process for selecting non-governmental ecolabels for inclusion in GSA Advantage. This was one impetus behind the
work to develop guidelines for evaluating non-governmental standards and ecolabels for federal purchasing; see the sidebar in Chapter 3 on p. 3-2
for more detail.
2-1
-------
are not captured in GSA Advantage, we had intended to use some of the green icons in GSA Advantage
as proxies for EPP's influence.
We requested GSA to provide purchasing data for the electronics and building and construction products
covered by this evaluation, including the quantity purchased and dollars spent through GSA Advantage,
broken out by the year of purchase and the agency making the purchase, and the green icons, if any,
associated with each product.18 Unfortunately, the GSA Advantage data have significant limitations,
including the following:
The total volume of purchases in our product categories that is directed through GSA Advantage is
too low to extrapolate to the total universe of federal purchases. Use of GSA Advantage is not
mandatory, and it appears that most federal purchases do not go through GSA Advantage. lEc initially
planned to estimate the portion of federal purchases that goes through GSA Advantage, by agency and
product category, by comparing the purchasing data in GSA Advantage to total federal purchases as
reported in the Federal Procurement Data System - Next Generation (see below). However, this was not
possible because the total volume of agency purchases in our product categories that goes through GSA
Advantage is too small to extrapolate to the total universe of federal purchases.
There are substantial discrepancies in the GSA Advantage data, including inconsistent use of the
relevant green icons for our product categories. lEc found substantial discrepancies in the electronics
data and building and construction product data that we received from GSA, including low volumes of
purchases, sharp year-on-year fluctuations in purchasing volumes, unit prices that do not look plausible,
missing data for several building and construction product categories, and internal inconsistences in the
dataset. The dataset also contains very low volumes of "green" purchases. Regarding the latter point,
some of the green icons on GSA Advantage were added as recently as March 2011. GSA did not update
the "green" status of products that were sold on GSA Advantage before the green icons were added. Also,
manufacturers are responsible for tagging their items with the applicable green icons; the information is
not entered automatically and seems to have been updated inconsistently. These factors likely explain the
substantial discrepancies in the data.
lEc worked with GSA over a period of several months in an attempt to resolve the data issues. All told,
we received three different versions of the dataset. Finally, we held a teleconference with the Director of
the Program Analysis Division in GSA's Office of Acquisition Management, who confirmed that the data
would not be useable for our purposes for the EPP evaluation.
Federal Procurement Data System - Next Generation (FPDS-NG)
Established by the Office of Management and Budget (OMB) and managed by GSA through a private
contractor, the Federal Procurement Data System - Next Generation (FPDS-NG) provides a relatively
comprehensive database of federal purchases. As specified in the Federal Acquisition Regulation (FAR),
federal agencies are required to report contract actions (including purchases) in the amount of $3,000 and
above to FDPS-NG, and all contract modifications regardless of the amount.19 Federal agencies reported
more than $532 billion in contract actions for CY 2010.20
18 GSA Advantage classifies products according to the United Nations Standard Products and Services Code (UNSPSC) classification system.
19 FAR, Subpart 4.6 - Contract Reporting, www.acquisition.gov/far/current/html/Subpart%204 6.html#wp1089036. Accessed on November 9, 2011.
20 FPDS-NG, https://www.fpds.gov/common/isp/FPDS.isp. Report generated on November 9, 2011.
2-2
-------
The FPDS-NG database contains comprehensive data from FY 2004 through the present; in addition, over
12 million legacy contract actions (dating back to 1979) were migrated from an older data system and are
now available in FPDS-NG.21 For each purchasing transaction in the system, FPDS-NG includes the
product or service code (PSC), PSC description, description of purchase requirements, federal agency,
and date of purchase. However, FPDS-NG has no historical data (prior to October 2011) on
environmentally preferable attributes, with the exception of products designated as meeting the
requirements of the Comprehensive Procurement Guidelines (CPG), which certifies the use of recovered
materials from solid waste in new products.22 CPG is not an appropriate proxy for standards that EPP
helped to develop because CPG is an OSWER program, implemented independently of EPP, and because
there is little overlap between designated CPG products and the products associated with standards that
EPP helped to develop. Therefore, we were not able to use FPDS-NG as a source of environmentally
preferable purchasing data.
Other Federal Sources of Comprehensive EPP Purchasing Data
lEc conducted an exhaustive search for other federal sources of comprehensive, cross-sector
environmentally preferable purchasing data. Specifically, we investigated more than 25 data leads
identified by EPA and lEc, including other GSA data sources, OMB reports, government-wide
acquisition contracts (GWACs), and agency-specific data sources. The rest of this section describes the
major categories of federal data sources that we investigated and their limitations.
Other GSA data sources. lEc explored the potential for using other GSA data sources, including GSA
Global Supply, but we confirmed that Global Supply was included in the dataset that we already received
from GSA. Another data source, GSA Advantage Spend Analysis Program (ASAP), was not publicly
available, but we understand that it uses the same dataset and has the same limitations as GSA Advantage.
We also looked at GSA's Comprehensive Professional Energy Services Blanket Purchase Agreement;
however, this is for energy services only, and does not cover the products that are the focus of the EPP
evaluation.
OMB/OFPP. OMB's Office of Federal Procurement Policy (OFPP) submits biennial reports to Congress
on federal agencies' compliance with requirements to buy recycled and bio-based products. lEc reviewed
the November 2011 report and related guidance materials issued by OMB.23 The report includes: a
summary of sustainable acquisition practices across 22 federal agencies in FY09; trends in OMB/OFEE
Environmental Stewardship Scorecard's "environmentally preferable purchasing score" for 22 agencies at
three points in time (2006, 2008, and 2010); percent of agency purchases in FY08 and FY09 that
contained recycled material (for DOD and six large civilian agencies); and whether or not DOD and the
six large civilian agencies purchased bio-based products in FY08 and FY09. While the report mentions
environmentally preferable product standards that EPP helped to develop or standards that could
potentially serve as proxies for EPP's influence, these standards are not the report's focus, and the report
21 FPDS-NG Home Page, "Welcome to Federal Procurement Data System - Next Generation,"
https://www.fpds.gov/common/html/public welcome text.html.
22 As of October 2011, "recovered materials" was updated to "recovered materials/sustainability," and now includes other environmental
attributes. The change is not retroactive to purchases reported before October 2011.
23 Report to Congress on Implementation of the Resource Conservation and Recovery Act (RCRA), Farm Security and Rural Investment Act of 2002
and the Food, Conservation, and Energy Act of 2008, November 2011.
2-3
-------
does not include any purchasing data for the products and standards that our evaluation covers. Therefore,
although the report provided useful context for the evaluation, we were not able to use it as a source of
federal purchasing data.
Government-wide acquisition contracts (GWACs). GWACs are contracts for information technology
(IT) products and services that are established by one federal agency for use by all federal agencies. Each
GWAC is operated by an executive agent designated by OMB. While we have data from 2008-2010 for
EPEAT (see discussion below), we thought that GWACs might provide us with 2006 and 2007 data on
EPEAT sales. lEc reviewed two lists of GWACs - Report on the Use of Interagency Contracting (OMB,
August 2010) and the OFPP master list. A number of the GWACs did not cover the products that we
looked at for our evaluation, but a few GWACs - GSA's IT GWACs, NASA's Solutions for Enterprise
Wide Procurement (SEWP) IV GWAC, and HHS/NIH's Electronic Commodities Store (ECS III) GWAC
- held promise as potential data sources. However, we ultimately learned during discussions with the
GWAC offices that the GWACs would not provide useable data because the offices are unable to
disaggregate sales of products versus services. Furthermore, in the case of SEWP and ECS III, the
GWAC offices do not have comprehensive sales data on products with specific environmental attributes
(e.g., EPEAT) that were sold through the GWAC.
Individual agency data. Given the lack of comprehensive federal sources of environmentally preferable
purchasing data, we looked at data sources maintained by individual agencies, including: EPA's EPEAT
federal sales data and the FEC annual reports; the DOD Green Procurement Report and DOD EMALL;
and the Department of Energy's (DOE) Sustainable Acquisition, Recycling, and Pollution Prevention
Practices, Fiscal Year 2008 Report (February 2009), 2077 Strategic Sustainability Performance Plan
(May 31, 2011), Pollution Prevention Tracking and Reporting System, Strategic Integrated Procurement
Enterprise System, and Strategic Petroleum Reserve: Buy It Green (BIG) initiative. EPEAT and the FEC
annual reports provide rich quantitative data for the electronics sector that we used for the evaluation (see
the discussion under the next heading - Electronics Purchases Data Sources and Analytic Approaches).
We also submitted a request to EPA's OARM for green purchasing data, but OARM confirmed that such
a data set does not exist.
Given our relatively complete data for the electronics sector, we focused on obtaining building and
construction product data from the DOD and DOE data sources. Unfortunately, the DOD sources that we
identified did not work out; DOD EMALL does not include acceptable proxies for the environmentally
preferable standards that EPP helped to develop for the building and construction products of interest, and
we had indications that the Green Procurement Report would have similar limitations, although we were
not able to obtain the data from the DOD/Defense Logistics Agency (see the discussion below under
Agency-Specific Sources for Building and Construction Purchasing Data/DOD). Similarly, the DOE data
sources do not include green purchasing data for the product standards that EPP helped to develop for
building and construction products of interest.24 Given the lack of comprehensive data available from
EPA, DOD, and DOE, lEc determined that it was very unlikely that other agencies had comprehensive
sources of EPP data, which was later verified through interviews.
24 lEc reviewed five separate DOE green purchasing data leads. Only one of these sources included the volume or quantity of green purchases, and
only for electronics, but not building and construction products.
2-4
-------
Electronics Purchases Data Sources and Analytic Approaches
Rich data sources are available for the electronics sector, which includes EPP activities on EPEAT and
FEC. These data were used to address evaluation questions 2, 3, 4, 5, 8, 9, and 11 for the electronics
sector.
EPEAT
EPEAT is a listing of computer and monitor models designated as "green" by virtue of meeting defined
criteria; it bills itself as "the definitive global registry for greener electronics." The Green Electronics
Council (GEC), which manages the EPEAT program, produces annual reports on the environmental
benefits of all sales of EPEAT-registered products. The reports use aggregate sales data (i.e., sales to all
purchasers) reported by manufacturers of EPEAT-registered computers and monitors. Because the reports
also track sales of non-EPEAT products, they can also be used as a data source to determine the total
market share of EPEAT certified products. Reports are available dating back to 2007, the year after the
EPEAT program began. In addition, EPP Program staff provided lEc with aggregate data on sales of
EPEAT products to the federal government, covering 2008 - 2010.
The EPP Program also funded the development of the Electronics Environmental Benefits Calculator
(EEBC), created by Abt Associates and currently managed by EPA. The EEBC is an Excel-based model
that compares the environmental characteristics of EPEAT products, by registration tier (gold, silver,
bronze), to the characteristics of non-EPEAT products, to calculate the net environmental benefits
attributable to the EPEAT program. The calculator estimates benefits on a number of dimensions,
including materials use, toxic chemicals and hazardous waste, air and water pollution, and energy use and
greenhouse gases. EPEAT's annual environmental benefits reports use this calculator to estimate the net
benefits of the entire EPEAT program. Based on lEc's review, the EEBC is a reputable and robust
calculator, and we used the calculator when discussing the environmental impact of the EPEAT program.
FEC
FEC, a voluntary program for federal facilities, has additional quantitative data available. FEC encourages
purchases of EPEAT and Energy Star products, implementation of energy-saving measures (i.e., sleep
mode), and reuse and recycling at end-of-life. The program uses a reporting framework, where partners
are asked to provide data regarding their electronics purchases, use, and end-of-life efforts on an annual
basis. The FEC data are available in electronic form back to 2005, with paper records available for
another two years before that.25 Raw data on individual facilities are available in addition to summary
results.
FEC uses the same calculator as EPEAT, the EEBC, to translate direct program results into environmental
impacts. lEc used the EEBC to calculate the environmental impact of the FEC. While the FEC's publicly-
released annual "Accomplishments Surveys" do not allocate the results reported by FEC partners among
different EPA programs (EPEAT, Region 9, Energy Star, FEC), program staff do apportion these
environmental benefits for internal reporting. lEc used the same allocation method used by FEC staff26
25 Because FEC was in a pilot phase prior to 2005, lEc did not analyze data from paper-based reporting available for the pilot, which would have
required extensive resources for data entry and QA/QC.
26 FEC excludes all benefits of the EPEAT program in reporting its results. This ensures that these benefits are not double-counted in the EPP
evaluation.
2-5
-------
One important issue to note is that in the period covered by our analysis, FEC partners' reporting was
strictly voluntary, with the result being that reporting rates have fluctuated from year to year. FEC's
reported results also have not been contextualized within the broader trends of electronics purchases at
federal facilities. lEc hypothesized that both of these phenomena may have contributed to the apparent
decline in FEC program effectiveness from 2009 to 2010; they may have masked or distorted the
program's actual impact in other years as well. Thus, in addition to discussing the overall results reported
by the FEC, lEc normalized these results with respect to 1) the total number of electronics products
(whether environmentally preferable or not environmentally preferable) being purchased by the reporting
FEC facilities, and 2) to the extent possible, the specific FEC facilities reporting or not reporting results in
any given year. See evaluation question 8 for the results of this analysis.
The FEC model uses transparency (public reporting) and recognition (awards) to encourage purchases of
EPEAT computers and other environmentally preferable behavior. lEc compared data on EPEAT
purchases among FEC participants and non-participants to explore the effectiveness of FEC's voluntary
approach (evaluation question 9). If the FEC approach is effective, we would expect to see
proportionately more EPEAT purchases among FEC participants compared to non-participants.
A key limitation of this analysis is that lEc was not able to control for self-selection bias, which could
contribute to positive results. That is, because agencies and facilities voluntarily join the FEC, those
predisposed to more environmentally preferable behavior may be drawn to the program. Hence, it is
possible that these agencies and facilities may have increased purchases of EPEAT computers even if
they had not joined FEC. However, given the fact that promoting EPEAT purchases is one of FEC's core
goals, it seems likely that at least some of the observed difference between FEC partners and other federal
facilities is attributable to the influence of the FEC program (this issue is further explored in Chapter 3,
under evaluation question 9).
Building and Construction Product Data Sources and Analytic Approaches
Existing purchasing data for building and construction products were intended to be used primarily to
address evaluation questions 2, 3, 4, and 5. However, lEc was not able to identify a robust source of
existing purchasing data for this sector. Therefore, we pursued other options for collecting building and
construction product data, including a "mini-market" analysis of companies that sell certified products to
the federal government. The following sections describe our attempts to obtain existing purchasing data,
and our methodology for the mini-market analysis.
Agency-Specific Sources for Building and Construction Purchasing Data
Initially, lEc considered obtaining purchasing data directly from individual agencies. Given resource
constraints, we would not have been able to contact every agency. Instead, we planned to select up to four
agencies (plus EPA), based on their share of total purchases in our selected product categories. However,
as described below, we were unable to obtain useable environmentally preferable building and
construction purchasing data from any federal agency that we contacted.27
27 It is important to note that even if we had been able to follow through with the "agency-specific" data collection approach, this approach would
have had several limitations. First, it would not have provided a broad picture of federal purchases that spans multiple agencies. As such, it would
likely not have been appropriate to quantitatively extrapolate findings from a small subset of agencies to the federal government as a whole.
Second, different agencies may use different definitions of "environmentally preferable" products, which may have posed difficulties in analyzing
2-6
-------
DOD. DOD was a clear choice for the above approach, because the agency is a large purchaser and has
been implementing environmentally preferable purchasing initiatives for many years. lEc worked with the
Defense Logistics Agency (DLA) to obtain environmentally preferable and non-environmentally
preferable sales data for building and construction products managed by DLA. Unfortunately, DLA does
not manage the products of interest and had no sales for those products from 2004 to 2011. Therefore, we
did not obtain any sales data from DLA.
Besides the products that DLA manages directly, DLA managed the Green Procurement Report (GPR) -
an online environmentally preferable procurement tracking system for DOD. GPR was decommissioned
in October 2011. Moreover, we had indications that building products of interest were not covered in the
GPR and data in the GPR were not reported at a sufficient level of detail for our analysis. Hence, we did
not pursue this avenue further.
We also considered DOD EMALL as a potential data source for DOD purchases of building and
construction products. DOD EMALL tracks environmentally preferable attributes using environmental
attribute codes (ENACs). Working with our DLA contacts, we specified the environmental attributes of
interest for our specific product categories. Unfortunately, the ENACs that DOD EMALL tracks do not
include acceptable proxies for the environmentally preferable standards that EPP helped to develop for
the building and construction products of interest.28 Therefore, we were not able to use DOD EMALL as
a data source for this evaluation.
EPA. lEc requested EPP spending data from EPA OAM covering the Agency's electronics, building and
construction product, and meetings and travel purchases from FY 2001 through FY 2011. OAM
confirmed that these data are not available.
GSA Schedule Data
As discussed in the previous section, GSA Advantage data could not be used to support the evaluation.
However, lEc researched data for building and construction products that may be available through
GSA's Multiple Award Schedules. Multiple Award Schedules are long-term, government-wide contracts
with commercial firms that provide access to a wide range of commercial products and services at volume
discount prices. The contracts are managed by GSA. Four GSA Schedules offer the building and
construction products covered by the evaluation: Schedules 71 (Furniture), 72 (Furnishings and Floor
Coverings), 51V (Hardware Superstore), and 56 (Buildings and Building Materials, Industrial Services
and Supplies). We requested GSA to provide purchasing data for the four Schedules.
GSA provided purchasing data for all of the requested schedules except Schedule 71. The data show
annual federal purchases through each Schedule, broken out by Special Item Number (SIN). GSA
mandates all manufacturers on specific SINs to offer environmentally preferable products. For example,
since January 2011, all manufacturers that sell carpet through SINs 31-301 and 31-304 (Schedule 72) are
data and aggregating data across agencies. Third, this approach would have required significant evaluation resources, as it would have required
working directly with different agencies to coordinate on a data request, and would have entailed agency-specific analyses of data.
28 The ENACs include the following environmental attributes: asbestos alternative products, biobased, FEMP, Energy Star, EPEAT, non-cadmium,
non-mercury, CPG, and low VOC. Low VOC is the only attribute that we identified as an acceptable proxy for building and construction products,
but the ENACs for low VOC do not cover our product categories. See Federal Logistics Information System: FLIS Procedures Manual Multiple
Application References/Instructions I Tables and Grids, DoD 4100.39-M, Volume 10, October 2010.
2-7
-------
required to sell NSF 140 certified carpet at the gold level or higher. GSA maintains data sales that went
through "green mandate" SINs (e.g., 31-301 and 31-304).
Although we used the GSA Schedule data to provide some sense of the magnitude of environmentally
preferable carpet sales to the government, the Schedule 72 data have a number of limitations. First,
federal agencies can still buy non-environmentally preferable carpet through Schedule 72 if they buy from
a small business SIN, or if they are buying specialty carpet (again through a separate SIN). Second,
manufacturers on other (non-"green mandate") SINs may opt to sell environmentally preferable products,
but we do not know the relative mix of environmentally preferable versus non-environmentally preferable
sales through those SINs. Third, the GSA Schedules do not account for all sales to the federal
government; federal agencies can purchase building and construction products outside of the GSA
Schedules. Fourth, GSA was unable to provide a breakdown of GSA Schedule purchases by federal
agency; therefore, we do not know which agencies account for the majority of purchases through the
Schedules.
Given these limitations, we sought to supplement the GSA Schedule data by requesting sales data directly
from manufacturers that sell environmentally preferable building and construction products through the
GSA Schedules. Our approach to this "mini-market" analysis is described below.
Mini-Market Analysis
Given the limitations of the federal purchasing data, lEc sought to obtain data directly from manufacturers
that sell select environmentally preferable building and construction products to the federal government.
Specifically, we were interested in sales data for products that are certified to environmentally preferable
standards that EPP helped to develop.
lEc cross-walked publicly available lists of manufacturers that sell certified building and construction
products to the list of manufacturers on the relevant GSA Multiple Award Schedules, including:
• Thirty manufacturers that sell BIFMA e3 certified furniture through Schedule 71;
• Eleven manufacturers that sell NSF 140 certified carpet through Schedule 72;
• Two manufacturers that sell NSF 332 certified flooring through Schedule 72; and
• One manufacturer that sells ULE 100 certified gypsum board through Schedule 5IV.29
As a first step, lEc sent a "screening" email to all of the above manufacturers. The email explained the
intent of our query and provided substantial context. The email also indicated that participation was
completely voluntary, and that lEc would not identify manufacturers in reporting data to EPA. The email
included a brief series of screening questions:
• Do you have existing data on sales ($ value sold) to the federal government of [product] certified to
the [x] standard?
• Is this information readily available? Are you able to provide it to the public upon request?
• If yes, can you please send it to us?
!9 Because our analysis did not look at all manufacturers in the product categories being evaluated, but only at the manufacturers selling through
the Multiple Award Schedules, this was a smaller undertaking than a full-fledged market analysis.
2-8
-------
• If these data are available online or in an existing report, can you identify where the information
might be found? If yes, can you provide us the location?
After sending the screening email, lEc followed up with every manufacturer by telephone and/or email to
ascertain if they had the information and were willing to participate in the evaluation.30 We contacted
each manufacturer at least three times. Four furniture manufacturers and one carpet manufacturer
provided sales data; we did not receive data from any resilient flooring companies or the gypsum board
company. To ensure consistency in reporting and to facilitate aggregation of sales data across the
manufacturers, we sent a standardized data request to participating manufacturers (Exhibit 2-1) and asked
them to fill in a standardized data collection template (Exhibit 2-2). In addition, we conducted telephone
interviews with all but one participating manufacturer. The interviews probed their reasons for selling
certified products to the federal government, and asked about any changes in their products or production
processes that were required to obtain certification.
50 If more than nine manufacturers had been willing and able to participate, we would have had to narrow our universe to nine participants, in
keeping with the requirements of the Paperwork Reduction Act. However, this was not an issue because fewer than nine companies indicated that
they were willing to participate.
2-9
-------
EXHIBIT 2-1. MINI-MARKET ANALYSIS DATA REQUEST
1. Could you provide existing data on:
a. Sales to the federal government of carpet certified to the NSF/ANSI 140 standard, from when you
started selling the product through 2011?
b. Sales to the federal government of carpet that is not certified to any green standard, from 2001 through
2011?
c. Sales to the federal government of carpet certified to any other third-party green standard (e.g.,
GreenGuard), from 2001 through 2011?
d. Sales to the federal government of carpet that your firm considers "green" or "low VOC," but was not
certified to any third party standard, from 2001 through 2011?
e. Can you provide the same data as requested in a-d above, but for non-federal customers?
We are providing a spreadsheet for you to provide available data [see Exhibit 2-2].
2. Why did your firm decide to certify carpet to the NSF/ANSI standard?
3. When you certified carpet to the standard, did you have to change any aspect of your manufacturing
process? If yes, explain.
4. Did you previously manufacture green carpet prior to the availability of the NSF/ANSI 140 standard? If yes:
a. Did you have to change any aspect of your manufacturing process when you originally started to produce
green carpet? If yes, explain.
b. When you certified carpet to the NSF/ANSI standard, did you have to make additional changes to your
manufacturing process? If yes, explain.
5. Has selling NSF/ANSI 140 certified carpet to the federal government changed your business practices or
marketing of certified carpet to non-federal customers (including any state or local government customers,
in addition to the private sector)? If so, how?
6. What is the trend in demand for NSF/ANSI 140 certified carpet among federal customers?
a- State and local government customers?
b. Private sector customers?
7. Do you sell any carpet to the government through a distributor? If yes:
a. What is the name of the distributor?
b. What proportion of all of your carpet sales to the federal government go through this distributor?
c. What proportion of NSF/ANSI 140 certified carpet sales to the federal government go through this
distributor?
8. Can you estimate your overall market share of NSF/ANSI 140 certified carpet?
9. Could you estimate your share of NSF/ANSI 140 sold to the federal government?
2-10
-------
EXHIBIT 2-2. DATA COLLECTION TEMPLATE FOR THE MINI-MARKET SHARE ANALYSIS
CARPET SALE
Sales to Federal Government
No Green Standard
Certification
NSF/ANSI 140 Certified
Other Green Certification, not
NSF/ANSI 140 Certified
Green or Low VOC, but not
certified to any green third-
party standard
Sales to Non-Federal Customers
No Green Standard
Certification
NSF/ANSI 140 Certified
Other Green Certification, not
NSF/ANSI 140 Certified
Green or Low VOC, but not
certified to any green third-
party standard
CY 2001
3
S
e
z
LL.
O
CJ
N/A
N/A
LU
—I
N/A
N/A
CY
2002
3
S
e
z
LL.
O
CJ
N/A
N/A
LU
—I
N/A
N/A
CY
2003
3
S
e
z
LL.
O
CJ
N/A
N/A
LU
—I
N/A
N/A
CY
2004
3
S
e
z
LL.
O
CJ
N/A
N/A
LU
<
N/A
N/A
CY
2005
3
S
e
z
LL.
O
CJ
N/A
N/A
LU
_l
N/A
N/A
CY
2006
3
S
£
z
LL.
O
CJ
LU
_l
CY
2007
3
S
e
z
LL.
O
CJ
LU
_l
CY
2008
3
S
£
z
LL.
O
CJ
LU
_l
CY
2009
3
S
e
z
LL.
O
CJ
LU
_l
CY
2010
3
S
e
z
LL.
O
CJ
LU
_l
CY
2011
3
S
P
z
LL.
O
CJ
LU
_l
2-11
-------
The four furniture manufacturers account for approximately 10% of GSA Schedule sales of all furniture
manufacturers that sold BIFMA e3 certified products to the federal government in FFY11. The one carpet
manufacturer accounts for about 15% of GSA Schedule sales of manufacturers that sold NSF 140
certified carpet to the federal government in FFY11. Given the relatively low number of respondents, and
the relatively low market share for these respondents, we cannot extrapolate to the universe of
manufacturers as a whole. Therefore, we took a "case-based" approach to our analysis, characterizing
environmentally preferable sales and motivations behind the decision to become certified for the
participating manufacturers. The results of the analysis are presented in Chapter 3.
Other Building and Construction Product Data Sources
• Federal Green Construction Guide for Specifiers (FGCG) web hit data. EPP has developed
detailed model contract language through the Federal Green Construction Guide for Specifiers
(FGCG). Much of this language addresses environmental characteristics of specific products, such as
carpets, doors, and ceiling panels. Because the Guide is available online, lEc requested data on
downloads and page views. This would provide an idea of the first-order impacts of EPP activities in
this area (i.e., information dissemination), but would not address the extent to which the Guide has
actually been used or influenced procurement practices in the marketplace. Due to changes in the
structure of the FGCG website, and migration to a new software application, historical web data on
the use of the FGCG was limited. However, we obtained Google Analytics data on page views,
average time on page, entrances, and bounce rate for 2010-2012, and the most commonly viewed
documents (hits and visits) in 2012.31
• Data from industry associations and standards organizations. lEc searched for data from industry
associations and standards organizations covering relevant products on rates of adoption by
manufacturers and purchasers of environmentally preferable product standards. NSF and ULE do
track and publicly list products certified under their standards, but they do not track any data on the
use of the standards by major purchasers or on market share of certified products more generally.
None of the trade associations that cover relevant product categories track data on the use of
sustainability standards by manufacturers or purchasers.
• McGraw Hill Construction Dodge SpecShare database. The McGraw Hill database tracks
specifications issued for current construction projects throughout the U.S. Theoretically, the database
could be used to track the extent to which voluntary standards or the FGCG are being referenced in
construction specifications, and by proxy, used in actual construction projects. However, a McGraw
Hill representative informed us that acquiring data on five standards or other search terms over a 90-
day period would cost at least $15,000. The cost would be more for longer time horizons. The EPA
evaluation team determined that such a report would be too costly for this evaluation, given the
narrow coverage of the report.
• Environmental benefits calculators. EPA has not quantified the environmental contribution of
environmentally preferable building and construction product purchases to date. The ability of lEc to
quantify changes in environmental condition for these products with the available evaluation
resources was dependent upon the availability of existing, reputable calculators that could be used,
31 We also received Google Analytics data for 2009, but we did not use the 2009 data in our analysis because we were advised that it was not
comparable with the 2010-2012 data.
2-12
-------
without adaption (or existing, reputable reports that perform such calculations themselves with
respect to the available data). lEc searched for environmental benefits calculators for the building and
construction products covered by the evaluation, including an extensive literature search and inquiries
with standards stakeholders interviewed, but was not able to identify any relevant calculators.
Notably, several stakeholders acknowledged the need for this type of tool.
Hospitality and Travel Data Sources
While EPP has been working on hospitality and travel for some time, key milestones such as adopting
standards and policies are recent developments. Moreover, there are no existing datasets on the outcomes
of EPP's hospitality and travel activities, partly because it is premature to measure outcomes from recent
developments, such as adopting standards and policies. As noted earlier, Region 9 is in the process of
developing a database to track the use of the Region's Green Meetings and Conference Policy, but this is
still a work in progress and was not populated with information at the time that lEc conducted this
analysis in 2012.
Given the absence of purchasing data, analysis of EPP's travel and hospitality sector was based on
qualitative research. We interviewed current EPP Headquarters, and Region 9 staff, who have been
actively involved in environmentally preferable hospitality and travel work. In addition, we interviewed a
small number of individuals outside of EPA who are familiar with the hospitality and travel work and its
impact.
It should be noted that lEc was not able to quantify the environmental benefits of the hospitality and
travel sector because of the emerging nature of EPP outcomes in this sector and lack of existing data.
Existing Data Sources on Non-Federal Green Purchasing Trends
One aim of this evaluation is to understand the EPP Program's influence beyond the federal realm,
including:
• If states, universities, and other non-federal institutional buyers are using EPP Program outputs,
including standards that the EPP Program was instrumental in developing (evaluation question 10);
• The extent to which the voluntary consensus standard approach is successful in designating and
promoting environmentally preferable products and services (evaluation question 12); and
• The availability and market share of products and services that are certified to those standards
(evaluation question 13).
To address these questions, lEc relied on information gathered through interviews (discussed later in this
document) and existing datasets. lEc identified several data sources, primarily surveys, which shed light
on state and institutional purchasing trends.
States
The National Association of State Procurement Officials (NASPO), in partnership with the Responsible
Purchasing Network (RPN), conducted a survey of NASPO-RPN members (i.e., purchasing officials)
from each of the 50 states and the District of Columbia. The survey was first conducted in February 2009
and was repeated in March-May 2010. The NASPO-RPN Survey Reports (2009-2010) include
information on annual procurement budgets; the prevalence of responsible purchasing policies; the
importance of various social and environmental factors in purchasing decisions; percent of annual
2-13
-------
spending actually influenced by social and environmental factors; allowable price premiums for goods
and services with socially and environmentally preferable attributes; standards and certifications that are
recognized and used; the extent of measuring and reporting on social and environmental impacts; and
plans for responsible purchasing going forward.
We also reviewed a survey of northeastern states that was conducted by the Northeast Recycling Council
for the Rhode Island Resource Recovery Corporation in 2009. The survey has limited data available, but
it does indicate which northeastern states have implemented a formal environmentally preferable
purchasing program; the years states began incorporating EPP into their purchasing decisions; the product
and service categories in which states are considering EPP criteria; the nature of the criteria being used;
and whether states are tracking their EPP purchases.
The Northeast Recycling Council also runs the State Electronics Challenge (SEC), a program modeled
after the Federal Electronics Challenge.32 SEC's membership includes states in the Northeast and other
regions throughout the U.S., as well as municipalities and other entities. SEC reports on total EPEAT
purchases and end-of-life disposal of their participating partners, and translates these into environmental
benefits using the EEBC. This source allowed us to gain more detailed quantitative information on
electronics purchases by state and local entities.
Finally, lEc obtained some limited information from NSF on the prevalence of state governments
specifying products certified under NSF sustainability standards (chiefly the NSF 140 carpet standard),
which was useful for characterizing environmentally preferable procurement trends at the state level.33
Universities
The National Association of Educational Procurement (NAEP) and SciQuest surveyed approximately
1,250 NAEP member institutions in 2009 and 2010; results were summarized in the Green Procurement
Trends in Fligher Education reports (2009-2010). These reports include questions on whether an
institution has an environmentally preferable procurement policy; drivers of institutional sustainability;
institutional priorities and challenges; and efforts to measure success. However, information on actual
expenditures for environmentally preferable products and services is limited. Nonetheless, the
NAEP/SciQuest survey was useful for characterizing general trends in environmentally preferable
purchasing by universities.
Other Non-Federal Institutional Purchasers
In addition to the joint NASPO-RPN survey of state purchasing officials discussed above, RPN surveyed
its broader membership in 2007-2010, including state purchasers plus other non-federal and federal
buyers. Unfortunately, the RPN report does not separate state purchasers from other institutional
purchasers. Further, respondents include federal agencies and non-federal purchasers (e.g., state agencies,
municipal agencies, educational institutions, non-profit organizations, religious congregations, business
membership organizations, and corporations); however, the RPN report does not disaggregate responses
for federal purchasers versus non-federal purchasers. Finally, RPN respondents are not likely
representative of mainstream procurement trends, since RPN is committed to sustainable procurement.
32 See http://www.stateelectronicschallenge.net/
33 As noted previously, however, NSF and ULE do not maintain data on sales or market share of certified products.
2-14
-------
Given these limitations, we were unable to characterize general trends for non-federal institutional
purchasers, outside of states and universities.34
Data on Use of EPP Website
As noted above, one potentially important function of the EPP Program is to serve as an information
clearinghouse, providing information on a wide variety of resources relating to environmentally
preferable purchasing. One way in which EPP does this is through its website, which includes information
not just on the EPP Program's direct activities but also on related programs such as Energy Star,
WaterSense, and non-EPA initiatives. lEc initially planned to analyze EPP website data, including web
traffic trends overtime, a profile of users (i.e., from within or outside of EPA and the federal government
more generally), page views and downloads of particular pages and resources, etc. However, we
subsequently learned that no historical web hit data is readily available, the archived records would be
costly for EPA to retrieve, and the archived data has changed formats several times and so does not lend
itself to trend analysis.35'36
NEW DATA COLLECTIONS
Survey of Federal Purchasers
A 2001 baseline assessment, Qualitative Measurement of Environmentally Preferable Purchasing (EPP)
Among Federal Employees in 2000, found only limited awareness of environmentally preferable
purchasing options among federal purchasers. EPP staff suspects there have been substantial
improvements in overall awareness of environmentally preferable purchasing options in the past decade
as a result of EPP Program activities and strengthened environmentally preferable purchasing
requirements. lEc conducted a survey of federal purchasing officials to examine current federal purchaser
awareness and behaviors with respect to environmentally preferable purchasing, to compare to the
baseline assessment. The survey included but was not limited to the product categories that are the focus
of the evaluation.37 This survey also assessed awareness and use of EPP Program outputs. As such, the
survey was designed primarily to address evaluation questions 1, 2, and 6:
34 We also identified a survey conducted by EcoMarkets, Center for a New American Dream, and the North American Green Purchasing Initiative
(NAGPI) in 2007, 2008, and 2009. The survey was deployed to procurement professionals from governmental, non-governmental, and private
organizations in the United States and Canada. However, the survey results have similar limitations as the RPN data, and the data is not current.
35 Email correspondence from OPPT staff to lEc evaluation team, July 6, 2012.
36 While lEc potentially could have conducted a limited analysis of "snapshot" website data, the data were not provided to lEc. Hence, we could not
conduct any analysis of EPP website statistics.
37 The 2001 study was conducted by NuStats - an Austin-based market research firm - and was based on qualitative research with 133 individuals,
using a combination of one-on-one in-person and telephone interviews, focus groups, dyads, and triads. The study population included "doers"
(actual federal purchasers) and "facilitators" (federal employees who set policy, conduct training, and provide information) who had been in their
job position for at least six months. The results were presented in qualitative terms - e.g., "There is some indication that...," "a perception held
by many respondents was...," etc. lEc's survey was limited to actual federal purchasers (not managers or facilitators) and we present the results
quantitatively. Because the 2001 baseline study and lEc's survey employed different approaches, we were not able to draw direct quantitative
comparisons between the two studies. However, lEc's survey included questions about awareness, attitudes, and behaviors similar to the 2001
baseline study, and we were able to explore general trends between 2001 and 2013 (e.g., increases in purchaser awareness of EPP). In addition,
lEc's survey included questions that asked specifically about changes in the respondents' EPP knowledge, awareness, and behavior over the past
three years.
2-15
-------
1. How has federal purchaser awareness of green products and services changed since the 2001 baseline
assessment?
2. How have federal agencies changed purchasing of green products and services since the 2001
baseline assessment, including incorporating green criteria into specifications and contract language?
6. How have the EPP Program's outputs, such as technical assistance, information dissemination,
decision tools, standards, and policy and contract language, been utilized by federal agencies?
a. How have EPP activities contributed to purchasing changes at federal agencies?
lEc developed a survey instrument with input from EPA; Appendix B contains the complete survey. The
survey was designed to be completed in 15 minutes or less. The survey included general questions to
measure attitudes and behaviors towards environmentally preferable purchasing, as well as specific
questions related to selected electronics and building and construction products. Respondents were only
asked questions relating to specific products if they indicated that they routinely purchased those
products.
Identification of Survey Participants
We surveyed federal purchasers, defined as individuals who are employed by the federal government in a
civilian or military agency or department (excluding contractors) and whose primary job responsibilities
include the following: making purchasing decisions, identifying vendors or suppliers, conducting pre-
purchase evaluations, and/or purchasing products and services. Our aim was to measure awareness and
behaviors of individuals whose main responsibilities entail making actual purchases; as such, we excluded
senior sustainability officers, chief acquisition officers, contract officers whose main responsibilities
entail overseeing federal contractor workflow, and other individuals who set purchasing policy as
opposed to conduct actual purchasing. In addition, we limited our target participants to individuals with at
least one year of experience performing purchasing-related activities, as individuals with less than one
year of experience may be too new to their role to offer an informed perspective.
Several factors complicated the effort to identify survey participants. First, we wanted to survey
purchasers from across federal agencies and departments, but the evaluation team was not able to identify
a comprehensive list of federal purchasers. Therefore, it was necessary to compile a list of contacts using
multiple sources:
• Contacts referred by purchasing managers. As a first step, we identified two lists of senior
procurement officials and chief acquisition officers using publicly available information on the
Internet; one list was available through the Office of the Federal Environmental Executive (OFEE)
and the other through the Chief Acquisition Officer's Council (CAOC).38 Although these individuals
were not in our target population of survey participants, we thought they might be able to provide the
names and contact information of federal purchasers in their respective agencies. As a next step, we
sent an email message to the 150 officials on the two lists requesting the names and contact
information of federal purchasers. The Chief of the Prevention Integration Branch of OPPT's
Pollution Prevention Division, followed up by sending an email to her colleagues requesting them to
identify federal purchasers to take the survey. This effort yielded 189 survey contacts.
! Lists are available at: http://caoc.gov/index.cfm?function=nienibersspe and http://www.ofee.gov/sso.asp.
2-16
-------
• Commercial purchaser list. lEc researched commercially available lists of federal purchasers. After
exploring several options, the evaluation team purchased the "All Federal Buyers" list from
Fedmarket.com. The list, which is updated once every three to four months, included the email
addresses for approximately 44,000 federal purchasers from across civilian and military agencies. The
list only includes email addresses; it does not identify the product and service categories that
purchasers buy from, nor does it provide demographic information about the purchasers. However,
the email extensions follow a consistent format - @[agency name].gov - that indicates the federal
agency that each purchaser works for. As discussed below, lEc used this information to look for
evidence of response bias in our survey respondents.
• Federal Acquisition Institute (FAI) list. FAI was created in 1976 under the Office of Federal
Procurement Policy Act to promote and facilitate the development of the federal acquisition
workforce. Among other activities, FAI provides training to acquisition professionals to support their
career development. FAI maintains a list (FAITAS) of approximately 107,000 federal purchasers and
other federal staff involved in purchasing and contracting. As discussed below, FAI agreed to
distribute our survey directly to FAFs list as well as the 44,000 federal purchasers on the commercial
list and the 189 individuals referred by purchasing managers.39
Another complicating factor was that once we identified the email addresses of federal purchasers, we did
not know how long they had been in their position, what types of products or services they purchased, and
what exposure (if any) they had to the EPP Program. For these reasons, we were not able to use statistical
sampling or ensure that specific types of respondents (e.g., individuals who purchase a certain type of
product or have had specific types of exposure to the EPP Program) were represented in our survey.
Instead, we surveyed everyone who was identified to us as being a federal purchaser, including FAFs list,
the commercial list, and the individuals referred by purchasing managers. Although we do not know the
exact number of federal purchasers, we are confident that we captured a substantial portion of the federal
purchaser population.
Survey Mode
FAI administered the survey online on behalf of the evaluation team, using FAFs in-house survey
software. FAFs survey tool includes advanced "skip logic," which avoids asking questions that do not
apply to the subject. If the response to an initial question does not require a follow-up question, the survey
automatically skipped subsequent questions in the series, thereby reducing the burden to the respondent.
The survey was conducted as follows:
• Pre-test the survey. lEc pre-tested the survey with four randomly selected purchasers. We debriefed
each purchaser by telephone to ensure that the survey questions were clear and interpreted as
intended, and to ensure that respondents could complete the survey within the intended timeframe.
The feedback from the pre-test did not indicate the need for any changes to the survey.
• Engage senior management. ESD coordinated with the Director of EPA's OAM, who in turn
briefed his colleagues on the Chief Acquisition Officers Council (CAOC), which includes senior
acquisition officials from across federal agencies. In addition, OAM briefed the Office of
' FAI conducted a comparison of its FAITAS list and the commercial list of purchasers and noted little overlap between the two lists.
2-17
-------
Management and Budget (OMB) about the survey effort. Based on OMB's suggestion, and
subsequent conversations between EPA and FAI, it was agreed that FAI would administer the EPP
federal purchasing survey.
Advertise the survey on FAI's website. FAI posted an advertisement on the FAI.gov homepage
approximately two weeks before the launch of the survey. The blurb included a brief overview of the
purpose of the survey and the EPP Program evaluation, indicated that the survey would be open soon,
and encouraged participation.
Send email invitation and survey link. The survey launched on January 7, 2013. FAI sent an email
invitation to everyone on the FAITAS list as well as the commercial purchaser list, including the 150
purchasers referred by purchasing managers.40 The invitation was sent to more than 149,000 email
addresses, including 105,048 FAITAS users and 44,265 commercial purchasers.41 The invitation
explained the purpose of the survey, encouraged participation, ensured confidentiality, and included a
link to the survey. The message also indicated that purchasers would receive one Continuous
Learning Point (CLP) as an incentive for completing the survey.
Upon clicking the link, respondents were directed to FAI's EPP survey page with an introduction to
the survey. The introduction reiterated the purpose of the survey and the fact that the survey was
confidential. It emphasized that there were no "right" or "wrong" answers, and encouraged
participants to be candid in their responses. It clearly stated that the purpose of the survey was to
assess the impacts associated with EPA's EPP Program, not to assess purchasers' compliance with
environmentally preferable purchasing mandates. It also reiterated that purchasers who completed the
survey were eligible to receive one CLP.
Screen out individuals who are ineligible for the survey. Following the introduction, participants
were directed to a series of screening questions to ensure that they have been performing federal
purchasing functions as a key part of their job for at least one year. Individuals who did not pass the
screening questions were directed to a screen-out page, thanking them for their time and terminating
the survey.42 Those who passed the screening questions were directed to the survey questionnaire.
Send template to purchasing policy managers. During the month that the survey was open, FAI
sent a template to purchasing policy managers on the CAOC to encourage staff to complete the
survey.
Close the survey effort. FAI closed the survey effort on February 6, 2013. Individuals were not able
to complete the survey after it closed.
40 IEc added the 150 emails that were referred to us by federal purchasing managers to the commercial list before forwarding the list to FAI. FAI
subsequently cross-checked this list against its own proprietary FAITAS list before sending out the survey invitation.
41 FAI's tracking system indicated that 101,221 FAITAS users and 38,234 commercial purchasers successfully received the survey. The remainder had
invalid email addresses, "bounced" back, or had other technical issues.
42 Twenty-five respondents clicked "none of the above" and at least one other option for the question asking which activities they perform on a
routine basis. Of these 25, 22 clicked on another answer that let them continue with the survey. We include their responses in our analysis.
2-18
-------
Overview of Respondents
All told, 2,539 respondents completed the survey.43 This represents roughly 2% of the roughly 149,000
individuals who received the survey invitation; however, it is not clear what percent of eligible
respondents is included in the 149,000. Because there is no comprehensive list of federal purchasers, as
noted above, we used the FAITAS list, a commercial list, and individuals referred by purchasing
managers. We know from the screen-outs (i.e., individuals who attempted to take the survey but did not
pass the screening criteria) that these lists include individuals who were not eligible to take the survey,
either because they do not perform the functions of a federal purchaser as defined in our survey, or
because they have not been performing those functions for at least one year. However, we have no way of
knowing how many individuals who received the survey invitation were in our target population.
If we use the commercial list as the "lower bound" and the FAITAS list as the "upper bound," we can
estimate a response rate between 2% and 6%.44 While this is not a high response rate, our results may be
representative of the federal purchasing population provided that there was no systematic response bias.
In other words, if the portion of individuals who completed the survey is representative of the federal
purchasing population as a whole, we can be reasonably confident in extrapolating our survey results to
the population. On the other hand, if respondents are not typical of most federal purchasers - for example,
if respondents have more favorable attitudes towards purchasing, or if purchasers from a small number of
federal agencies dominated the survey results - we would be reluctant generalize our findings.
lEc looked for evidence of response bias by comparing the proportion of purchasers in each agency for
the survey "population" versus survey respondents. We calculated the "population" of purchasers in each
agency with information contained in the email addresses. Almost all addresses follow a similar format:
[individual's name]@[agency name].gov. By separating out the @[agency name].gov extension from the
first part of the email address, we were able to count the number of recipients in each agency.45 Then, we
used the survey results, which included a mandatory question on which agency the respondents works for,
to calculate the portion of respondents from each agency. By comparing the proportion of respondents
from each agency to the population as a whole, we were able to test whether or not particular agencies
were overrepresented or underrepresented in the survey results. Exhibit 2-3 presents the results of our
analysis of potential response bias. As shown in the exhibit, there is generally little or no substantive
difference (less than 5%) between the "population" proportion and the survey respondent proportion. The
exception is DOD, which is underrepresented in the survey results (-11.5%). We find no evidence of
response bias, with the exception of DOD, which suggests that the results are representative of civilian
purchasers but may not be representative of military purchasers.
This includes 31 "incompletes" who answered all survey questions and provided an email address, but did not click "submit." Another 2,472
individuals partially answered the survey questions (without providing an email address) or were ineligible to take the survey based on their
answers to the screening questions. Due to the following technical issues with the survey tool, lEc was not able to use incomplete responses from
individuals who did not provide an email address: (i) The survey tool records responses in such a way that there can be overlap between the
"complete" dataset and the "incomplete" dataset, and duplicates cannot be identified and removed without an email address (this is necessary to
avoid double counting); and (ii) The survey tool has the potential to record "false no's" - in certain situations, the tool does not distinguish
between an actual "no" versus no answer. False "no's" were corrected in the completed surveys based on the answers to subsequent questions;
however, this method could not be consistently applied to incomplete responses.
44 Counting incompletes and screen-outs, the response rate would be between 5% and 11 %.
45 Neither EPA nor lEc had access to the FAITAS list. Instead, FAI provided a count of the total number of FAITAS users belonging to each agency.
2-19
-------
Given the almost complete lack of demographic information about the purchasers on our lists, we were
not able to look for other potential sources of response bias, such as years on the job, purchase size, etc.
However, we see diversity among the types of products and services purchased, number of years on the
job, and level of familiarity with EPP Program resources among our survey respondents. Similarly, the
results do not indicate a positive bias toward environmentally preferable purchasing. Furthermore, we
note that the incentive of one CLP for completing the survey may have reduced response bias by
attracting respondents beyond those who are normally interested in EPP.
EXHIBIT 2-3. COMPARISON OF "POPULATION" TO SURVEY RESPONDENTS
18%
16%
14%
12%
10%
8%
6%
4%
2%
0%
• iiinirr
11 m
/yss/ /*
I Actual Perc
lSurvey_Perc
Survey Analysis
The survey aimed to measure changes in federal purchaser awareness and behaviors with respect to
environmentally preferable purchasing since the 2001 baseline assessment. The survey also attempted to
document the influence of the EPP Program versus other factors (e.g., purchasing mandates) in driving
changes in awareness and behaviors. In addressing these key questions, the survey also attempted to shed
light on a number of related topics, including:
• The role of environmental considerations versus other factors in federal purchasing decisions;
• The perceived advantages and perceived disadvantages of environmentally preferable purchasing;
2-20
-------
• How purchasers evaluate "cost" and define "best value;"
• Barriers to environmentally preferable purchasing;
• Variations in attitudes and behaviors between purchasers of products and purchasers of services, and
across our specific product categories (electronics and building and construction products);
• Potential outcomes of buying more environmentally preferable products, including both positive (e.g.,
pride in compliance with mandates, external recognition) and negative (e.g., higher cost, poorer
product performance) outcomes; and
• The relative usefulness of various EPP tools and resources.
We conducted the following analyses using the survey data:
• We calculated descriptive statistics, including the number and percentage of purchasers who
responded in various ways to each question, overall and broken out for purchasers of products versus
services, purchasers of products within our specific product categories, and EPA purchasers versus
other federal purchasers, as appropriate. A complete set of survey results by survey question is
included in Appendix C.
• We analyzed changes in environmentally preferable purchasing awareness, attitudes, and behaviors
over time. We did this in two ways:
o We conducted a qualitative comparison of responses to questions about awareness, attitudes, and
purchasing behavior from our survey to the 2001 baseline assessment; and
o We summarized self-reported changes in knowledge, attitudes, and behaviors related to
environmentally preferable purchasing over the past three years, for survey respondents who
indicated that they have been performing federal purchasing activities for at least three years.
• We analyzed the contribution of EPP resources and other factors to changes in attitudes and
behaviors. Specifically, we constructed a weighted index to measure survey respondents' level of
exposure to EPP Program resources ("exposure index"). The index was calculated as the number of
EPP Program resources that survey respondents checked off, weighted by the intensity of each
resource (1 = low, 3 = high), using the weights shown in Exhibit 2-4.
EXHIBIT 2-4. EXPOSURE INDEX WEIGHTINGS
EXPOSURE ACTIVITY
Accessed information on EPA's EPP website
Used EPP's tools/environmental benefits calculators
Used EPP's guidance documents
Attended a seminar or conference where EPP staff made a presentation
Used EPP's model policy, contract language, and/or specifications
Attended a training event offered by EPP staff
Participated in a working group with EPP staff
Engaged in regular (informal) interactions with EPP staff
Received direct technical assistance from EPP staff
WEIGHT
2-21
-------
Using the exposure index, we constructed comparison groups for individuals with high versus low
exposure to EPP Program resources, using five and below as "low" and six and above as "high." This
gave us 412 respondents in the low exposure group and 500 respondents in the high exposure group.
This particular analysis did not include individuals who reported no exposure to the EPP Program
(exposure index score = 0). The reason is that if we compared individuals with no exposure to the
program to those with high exposure, we might unduly bias the results in favor of EPP, due to
possible self-selection bias among those with no exposure. That is, individuals who have not used any
EPP resources may be disinclined towards environmentally preferable purchasing irrespective of their
contact with the EPP Program. As such, any difference that we observed between purchasers with no
exposure and other purchasers would likely reflect fundamental differences in the attitudes and
behaviors of the two groups, not the influence of the EPP Program. By limiting our analysis to
individuals who have used at least one EPP Program resource, we are testing the hypothesis that
higher exposure to EPP Program resources is associated with "greener" purchasing attitudes and
behaviors, while partially controlling for self-selection bias. This is a conservative approach for
probing the influence of the EPP Program because we are excluding individuals whose attitudes and
behaviors are very likely less "green" than those who have used EPP Program resources.
Using our "comparison groups" for high versus low exposure, we conducted statistical tests to
examine whether or not higher exposure to the EPP Program is statistically associated with "greener"
purchasing attitudes and behaviors. To test for this statistically significant association, we ran chi-
squared tests for independence. Chi-squared tests are useful when working with qualitative data (i.e.,
data with categorical rather than numerical responses), and are based on counts that represent the
number of items in the sample falling into each category. As a first step, we created a contingency
table, which lists the observed counts of observation for a given criterion. Exhibit 2-5 shows an
example of a contingency table.
EXHIBIT 2-5. SAMPLE CONTINGENCY TABLE
PURCHASE ENVIRONMENTALLY
PREFERABLE PRODUCTS?
Yes
No
TOTAL
EXPOSURE TO EPP PROGRAM
RESOURCES?
Yes
45
15
60
No
13
27
40
TOTAL
58
42
100
Next, we calculated the expected counts for each category, as follows:
(Row total\
(Row total\
Expected count = Column total *
\ n /
where n= total observations.
If there is no association between exposure to EPP Program resources and environmentally preferable
purchasing, we would expect the same proportion of respondents to purchase environmentally preferable
2-22
-------
products regardless of whether or not they have exposure to EPP resources. To calculate the expected
counts, we first found the overall proportion in each category ((Row total /n) in the above equation). We
found that overall, 58 of the 100 respondents in our hypothetical example purchase environmentally
preferable products (58%). If exposure to EPP resources had no association with purchasing
environmentally preferable products, we would expect to see 58% of participants with and without
exposure to EPP resources purchasing environmentally preferable products. Thus, the expected count of
environmentally preferable purchasers with exposure to EPP resources would be 58% of 60 (or 35), and
the expected count of those without would be 58% of 40 (or 23). However, we see that the actual counts
are 45 and 13, respectively. To test whether the difference between the expected and actual values is
statistically significant, we first calculated the chi-squared statistic:
(Observed count — Expected count}2
Chi - Squared Statistic = £- -—=- —
Expected count
We then compared the chi-squared statistic to the critical value from the chi-squared table (which can be
found in statistics textbooks) to test whether we can reject the null hypothesis that the variables have no
relationship to each other. If the chi-squared statistic is larger than the critical value, the finding is
statistically significant. If the chi-squared statistic is smaller than the critical value, the finding is not
statistically significant.
There was one more step in our analysis. Specifically, while the chi-squared test tells us if there is a
statistically significant association between two variables, it does not tell us the strength of that
association. To assess the strength of the association between two variables, we needed to calculate the
Cramer's V statistic as follows:
\chi — squared statistic
Cramer sV =
n(q - 1)
where:
n = total observations
q = smaller number of rows or columns
Specifically, Cramer's V gives us the association between two variables as a percentage of their
maximum possible variation. A Cramer's V of one would denote a perfect relationship, while a Cramer's
V of zero would indicate that the two variables are statistically independent. The Cramer's V statistic also
lets us compare the relative strength of relationships between different variables. In other words, variables
with a larger Cramer's V than others have a stronger relationship to each other than variables with a lower
Cramer's V. In Chapter 3, we present the results of our analysis and use Cramer's V to rank the EPP
resources by strongest association with greener purchasing behavior.
2-23
-------
Interviews
lEc's second major data collection effort consisted of a series of one-on-one telephone interviews with
individuals who interacted with EPP staffer used EPP Program outputs, as well as with EPP staff
members themselves. The interviews were intended to address several evaluation questions in part or in
full, including 2, 3, 4, 6, 7, 10, 11, and 12.
For some evaluation questions, and for some sectors, existing quantitative data were not available, and
interviews provided the main source of information. This was particularly true with the travel and
hospitality sector. We explored the following travel and hospitality topics through the interviews:
• Changes in contract language used for hospitality, meetings, and/or business travel services resulting
from Region 9's Green Meetings and Conference Policy
• Outcomes of the Convention Industry Council's Green Meetings Report
• EPP's contribution to the process of developing the suite of ASTM Green Meetings and Events
standards
• Changes in procurement language to include greenhouse gas emissions as a criterion for contract
airline routes
In other cases, interviews supplemented existing data. lEc chose interviews for questions 10 and 11,
which focus on non-federal impacts, because conducting a survey would have been infeasible due to
Information Collection Request (ICR) requirements. For other evaluation questions, interviews were
preferable to a survey because of the nature of the question (questions 4, 7, and 12).
lEc identified a number of potential interview participants among the contacts we made in the course of
our scoping work. Other potential interviewees were recommended to us by our initial contacts. Finally,
we identified some interviewees through a review of several reports on environmentally preferable
purchasing and through targeted Internet searches.
We made initial contact through an introductory email and followed up as necessary with unresponsive
individuals. If the interview target remained unresponsive to repeated requests or declined to be
interviewed, we used an alternate. A list of interviewees is included in Appendix E; only position and
affiliation are included. To encourage candor, lEc committed to maintain confidentiality and not disclose
any individual's responses to EPA without interviewee consent.
lEc organized interviewees into several categories:
• EPP Staff: We interviewed all current EPP staff46 We confirmed the staff list with the EPP members
of the evaluation team and with the other EPP staff members already identified. These interviews
allowed us to confirm our understanding of the EPP Program's activities in the sectors being
evaluated and gauge EPP staff members' perceptions of the division's interactions with other federal
agencies. Also, several members of the EPP staff have been involved in creating or promoting
voluntary consensus standards, and we asked additional questions for this group concerning standards
issues.
* This excludes EPA staff at Regional offices working on environmentally preferable purchasing issues, with the exception of Region 9 staff working
on green hospitality and travel.
2-24
-------
• Hospitality and Travel Contacts: We interviewed all current EPP Headquarters, and Region 9 staff,
who have been actively involved in that office's environmentally preferable hospitality and travel
work. In addition, we interviewed a small number of individuals outside of EPA who are familiar
with the hospitality and travel work and its impact, including contacts at GSA (which is developing
its own environmentally preferable hospitality and travel rule amendments and policy guidance based
in part on input from EPP staff, as well as Region 9's past efforts) and stakeholders in the
development of the new ASTM Green Meetings and Events suite of standards. We revised our list of
interviewees based on recommendations from the EPP Headquarters lead for this area.
• EPA OAM: We interviewed one individual from EPA's Office of Acquisition Management (OAM).
This interview primarily addressed changes to EPA's procurement policies and processes, and the
contribution of EPP Program outputs on OAM activity.
• Federal Environmentally Preferable Purchasing Managers: We interviewed environmentally
preferable purchasing program managers at other agencies. In addition to questions about changes in
procurement policies and processes, these interviews probed EPP's interactions with other agencies
and the use of EPP's outputs.
• Non-federal Environmentally Preferable Purchasing Managers: Looking beyond the federal
realm, we interviewed environmentally preferable purchasing managers at non-federal organizations,
including state governments and universities. Due to ICR limitations, we were limited to nine
interviews of this type. These interviews provided information on environmentally preferable
purchasing practices outside the federal government, the extent to which EPP has influenced these
practices, and the impact of voluntary consensus standards that EPP has been instrumental in
developing. We used this information in conjunction with the other sources noted here to characterize
state purchasing trends.
• Standards Stakeholders: We interviewed key stakeholders in the voluntary consensus standard
development process. This included representatives from the standards organizations themselves
(NSF, ULE, IEEE), manufacturers, trade associations, government agencies (aside from EPA), and
NGOs. We targeted individuals that were heavily involved in the development of the standards, such
as committee co-chairs, and we covered all of the standards addressed in this evaluation. We aimed to
talk with at least two individuals outside of EPA involved in each standard that EPP participated in.
• GSA Procurement Contacts and Multiple Award Schedule (MAS) Managers: During our
scoping research, we spoke with GSA MAS managers for carpet and furniture. We had also planned
to interview the managers of other key GSA MASs for building and construction products. These
conversations would have focused on changes to procurement policies and processes and any
resulting changes in environmentally preferable procurement done through the GSA schedules.
However, despite repeated attempts, we were unable to secure an interview with any additional MAS
managers.
lEc developed a series of interview guides to ensure consistency in conducting interviews. The guides are
included in Appendix D.
As shown in Exhibit 2-6, lEc conducted interviews with 44 individuals in eight categories.
2-25
-------
EXHIBIT 2-6. INTERVIEWS
CATEGORY
EPP Staff
Hospitality and Travel Contacts
EPAOAM
Federal Environmentally Preferable Purchasing Managers
Non-federal Environmentally Preferable Purchasing Managers
Standards Stakeholders
GSA Procurement Contacts
Other *
Total
NUMBER
8
7
1
5
9
8
4
2
44
* Includes one interview for the State Electronics Challenge and one interview for the Federal Green Challenge.
lEc compiled the interview data into one consolidated file; this was the first step in conducting the
analysis. The file was organized by evaluation question, and arrayed each interview question in rows,
with each interviewee's response in columns. This organization enabled us to look across interviews for
patterns in the data and conduct a thematic analysis. Due to the relatively small number of interviews
conducted, and the small number of people that answered the same interview question, formal coding of
interview responses was unnecessary to discern trends. Our analysis focused on identifying broad trends,
such as areas of consensus or sharp disagreement between interviewees. We looked for such trends both
within and between interviewee categories, with a particular view to any differences between EPA staff
and individuals outside the agency. Our analysis also highlighted any areas in which interviewee
responses diverged significantly from our expectations. Where there were significant points of
disagreement between interviewees, or between our expectations and the overall results, we explored
potential contributing factors.
Due to the small sample size, it was not possible to assign any statistical significance to the interview
results, and thus we did not conduct any statistical analysis of interviewee data. Yet even in the absence of
statistical analysis, information obtained through interviews provided useful insights into how well the
EPP Program is functioning and achieving its aims. Interviews frequently provide deeper and more
nuanced understanding than other evaluation methods,47 which can be particularly valuable in situations
where the interplay of various dynamics may be unclear or complicated. We found this to be true in the
interviews that we conducted for this evaluation.
47 See "2011 Program Evaluation Competition Workshop: Introduction to Program Evaluation." August 17-18, 2011. Presented by the EPA Evaluation
Support Division, John Mclaughlin, Mclaughlin Associates, and Tracy Dyke-Redmond, Industrial Economics, Inc. See also Bamberger, Michael and
Jim Rugh. "Real World Evaluation: Working Under Budget, Time, Data, and Political Constraints." American Evaluation Association Professional
Development Workshop Session 21, November 5, 2008.
2-26
-------
EXHIBIT 2-7.
SUMMARY CROSSWALK OF EVALUATION QUESTIONS AND METHODS UTILIZED
EVALUATION QUESTION
ENVIRONMENTALLY PREFERABLE
ELECTRONICS
ENVIRONMENTALLY PREFERABLE
BUILDING PRODUCTS
ENVIRONMENTALLY PREFERABLE
HOSPITALITY/TRAVEL
1 . How has federal purchaser awareness of
green products and services changed since
the 2001 baseline assessment?
2. How have federal agencies changed
purchasing of green products and services
since the 2001 baseline assessment,
including incorporating green criteria into
specifications and contract language?
3. What are the outcomes of these purchasing
changes in terms of changes in the
proportion of green products and services
purchased by federal agencies?
4. Is EPA leading by example in terms of
purchasing behavior for green products and
services?
5. What are the outcomes of federal green
purchases in terms of reduced energy use
and associated greenhouse gas emissions,
reduced water use, and reduced use of
hazardous materials?
6. How have the EPP Program's outputs, such
as technical assistance, information
dissemination, decision tools, standards,
and policy and contract language, been
utilized by federal agencies?
a. How have EPP activities contributed
to purchasing changes at federal
agencies?
7. How effective is the EPP Program in
coordinating with green purchasing
programs at other federal agencies?
• Federal purchaser survey
•
• Federal purchaser survey
• Analysis of existing EPEAT and FEC data
• Interviews with federal purchasing
managers, EPP staff, 0AM
• Analysis of existing EPEAT and FEC data
• Analysis of EPA's EPEAT and FEC data
• Interviews with EPP staff and 0AM
• Federal purchaser survey
• Application of the EEBC to findings from
Question 3
• Federal purchaser survey
• Interviews with federal purchasing
managers, EPP staff, 0AM
• Review FGCG web hit and download
data
• Mini-market analysis
• Interviews with EPP staff and 0AM
• Federal purchaser survey
N/A
N/A
• Interviews with EPA Regional contacts and
GSA hospitality contacts
• Interviews with EPA Regional contacts and
GSA hospitality contacts
• Interviews with EPP staff and 0AM
•
N/A
• Federal purchaser survey
• Interviews with federal purchasing managers, EPP staff, 0AM, federal hospitality contacts, and standards stakeholders
• Interviews with federal purchasing managers, EPP staff, 0AM, federal hospitality contacts
2-27
-------
EVALUATION QUESTION
8. The Federal Electronics Challenge (FEC), a
key EPP priority area, has reported an
apparent decline in energy savings from
2009 to 2010. Is this decline in reported
energy savings indicative of backsliding on
energy savings behavior reported to FEC?
a. If yes, why has backsliding occurred?
b. If yes, what changes are needed
within FEC to address backsliding?
9. How effective is the FEC's voluntary
approach in promoting purchases of
EPEAT-labeled electronics among federal
agencies?
ENVIRONMENTALLY PREFERABLE
ELECTRONICS
• Analysis of FEC facility data
• Analysis of data from FEC participants and
non-participants
ENVIRONMENTALLY PREFERABLE
BUILDING PRODUCTS
N/A
N/A
ENVIRONMENTALLY PREFERABLE
HOSPITALITY/TRAVEL
N/A
N/A
BROADER EVALUATION QUESTIONS (BEYOND THE FEDERAL GOVERNMENT REALM)
10. How have the EPP Program's outputs, such
as technical assistance, information
dissemination, decision tools, standards,
and policy and contract language, been
utilized by purchasers outside of the
federal government, including state and
institutional purchasers?
11. To what extent are manufacturers using
the voluntary consensus standards that
EPA has helped to develop?
12. What factors influence the extent to
which the voluntary consensus standard
approach is successful in designating and
promoting green products and services?
13. How has EPP affected the availability of
green goods and services in the
marketplace?
14. Should EPA consider changes in EPP's
future approach to promoting green
products and services?
a. If yes, what changes may be
appropriate given resource
constraints, changing regulatory
requirements, and other external
factors?
• Existing reports on environmentally
preferable purchasing trends in non-
federal sectors
• Interviews with environmentally
preferable purchasing program managers
at states and universities
• Interviews with EPP staff
• Review of existing EPEAT manufacturer
data
• Interviews with standards stakeholders
• Interviews with non-federal
environmentally preferable purchasing
managers (same as Question 10), EPP
staff, and standards stakeholders
• Same as electronics sector, and
review FGCG web hit data
• Review of existing ULE and NSF data
on manufacturers
• Interviews with standards
stakeholders
• Interviews with non-federal
environmentally preferable
purchasing managers (same as
Question 10), EPP staff, and
standards stakeholders
• Interviews with environmentally preferable
purchasing program managers at states
• Interviews with hospitality and travel
stakeholders
N/A
• Interviews with EPA and GSA hospitality
contacts, EPP staff, and standards
stakeholders
• Synthesis of information collected for Questions 10-12
• Synthesis of information collected for all evaluation questions, to develop findings
• Discussion of findings, and exploration of associated recommendations, with evaluation team
2-28
-------
STRENGTHS AND WEAKNESSES OF THE METHODOLOGY
The strengths and weaknesses of the methodology are summarized below.
Strengths
Multiple methods and triangulation: This evaluation relied on multiple data collection and analytical
methods, including a survey, interviews, and analyses of existing data. lEc analyzed interview findings in
conjunction with findings from analysis of existing data sources, and in limited cases (e.g., for evaluation
question 2), in conjunction with findings from the federal purchaser survey. Triangulating across multiple
sources of information to address the same question provides the opportunity for findings from one source
to validate or contradict findings from another source. As a general rule, if we see consistent themes
across methods, it bolsters the strength and confidence of evaluation findings. As discussed in Chapter 3,
several evaluation findings are supported by validation from more than one source.
Comparison groups: Comparison groups provide an alternative to experimental designs for attributing
benefits to the program. By comparing entities that did and did not receive program services, it may be
possible to infer the extent to which the program resulted in observed outcomes. We used comparison
groups to discern statistically significant differences between purchasers with low versus high exposure to
EPP Program resources regarding environmentally preferable purchasing attitudes and behaviors.
Specifically, we had a sufficiently high number of respondents, and sufficient variation in their responses,
to construct comparison groups of individuals with high versus low exposure to EPP resources. Similarly,
we were able to apply statistical methods to rank the EPP resources that are most strongly correlated with
greener purchasing behavior.
We were also able to conduct a comparative analysis to test the impact of the FEC program. EPEAT
started in 2006; we have data for EPEAT sales to the government from 2008 through 2010;48 and we have
annual EPEAT sales data for FEC participants from 2007 through 2010. We were able to compare trends
in EPEAT sales over time for FEC participants and non-participants, which provided insight into whether
FEC participation is correlated with greater rates of increased EPEAT purchases than non-FEC
participants. Our methods do not establish causality, and it is likely that selection bias may be a factor in
FEC's influence. Nonetheless, our analysis suggests an influence of the FEC program in promoting
EPEAT purchases.
Longitudinal analysis: The survey provided longitudinal data on changes in knowledge, attitudes, and
behaviors with respect to environmentally preferable purchasing over the past three years, and further
enabled us to conduct a high-level analysis of changes between the 2001 baseline assessment and the
present. As far as we know, this was the first survey of its kind of federal purchasers to be conducted on
such a wide scale. We also conducted longitudinal analysis in the electronic sector using EPEAT data.
Limitations
Limited coverage: Due to resource constraints, this evaluation covered three important sectors that EPP
has worked. However, we cannot address EPP impacts specific to other sectors.
48 We do not know how many, if any, products would have qualified for EPEAT before EPEAT existed. However, despite strong economic incentive
to register for the successful EPEAT standard, it took years before many computers and monitor models qualified for EPEAT Gold. The absence of
a perfect counterfactual is another limitation in assessing the impact of EPP.
2-29
-------
Could not apply an experimental design: We were not able to apply an experimental design (namely, a
randomized controlled trial) to attribute benefits to the EPP Program. As with most of EPA's voluntary
programs, it was not possible to conduct a randomized controlled trial for the EPP Program, because
doing so would have required the program to randomly assign individuals to a treatment group and a
control group prior to delivering services. This was not done, nor would it have been feasible or desirable,
since the program is designed to cause spillovers: to share information with wide and diverse audiences
beyond the boundaries of the program. For example, the FGCG provides procurement language designed
to be incorporated into federal agencies' purchasing policies. If the language of the Guide is incorporated
in agency purchasing policies, it could indirectly influence the purchasing behaviors of purchasing staff
without the EPP Program or the purchasers themselves knowing it. A related limitation of the
methodology is that we were unable to systematically probe these types of spillover effects (see below).
Inability to quantify indirect influence and spillover effects. The EPP Program is designed to
disseminate information, and influence purchasing behavior, beyond the boundaries of the program. As
illustrated by the FGCG example in the previous paragraph, agencies may incorporate model contract
language developed by the EPP Program into agency purchasing policies that influence the behavior of
purchasers at those agencies. Similarly, EPA's blanket purchase agreement (BPA) for information
technology (IT) products incorporates EPEAT, a standard that was heavily influenced by the EPP
Program. However, because EPP does not "brand" its outputs, purchasers may not be aware that they are
using standards that EPP helped to develop. Therefore, our survey of federal purchasing staff was not able
to quantify the program's indirect influence.
A related challenge is that the federal government does not centrally track the purchases of its contractors.
This may have several implications for understanding EPP influences. For example, many federal
facilities are government-owned but contractor-operated (GOCOs), including 19 federal laboratories and
several DOD facilities.49 GOCOs may conduct their own procurements outside of federal contracting
mechanisms. As such, purchases of EPEAT computers and monitors by GOCOs, as well as other types of
green purchases, may not be captured in federal data. This issue also comes into play with federal facility
construction and renovation projects. For example, the Leadership in Energy & Environmental Design
(LEED) standard includes a provisional credit for the NSF 140 carpet standard, a product standard which
EPP helped to develop. Federal construction projects must meet sustainability standards, and GSA
officially recognizes LEED as the certification system to use to meet these standards.50 Thus, if private
contractors buy NSF 140 carpet for LEED-certified federal buildings, or any other green building or
construction product, these purchases would not be captured in a federal procurement system.
Inability to quantify changes in federal purchases of environmentally preferable products and
services or the resulting environmental benefits, beyond the electronics sector: This limitation is the
result of an absence of green purchasing data and lack of environmental benefits calculators outside the
electronics sector. As discussed in Chapter 4, key recommendations that stem from this evaluation include
improving the government's tracking of environmental attributes of federal purchases and developing
calculators to estimate the environmental benefits of these purchases.
49 Information about GOCO labs can be found at: http://www.sandia.gov/about/historv/goco.html
50 US DOE, Pacific Northwest National Laboratory, Green Building Certification System Review, prepared for GSA, March 2012.
2-30
-------
Inability to precisely define survey universe: We were not able to precisely define the survey universe
because we did not have a single master list of all federal purchasers. This limitation, as well as the lack
of information about the target population, precluded statistical sampling. However, we are confident that
between the FAITAS list of 107,000 purchasers and the commercial list of 44,000 purchasers, most if not
all of the total population received the invitation to complete the survey. Furthermore, we do not find
evidence of response bias in terms of the agencies represented in the survey results, with the exception of
DOD, which is underrepresented. We also see wide variation in respondents' knowledge, attitudes, and
behaviors with respect to environmentally preferable purchasing, which does not suggest the presence of
"green bias" on the part of survey respondents. In this regard, the continuous learning credit offered to all
respondents who completed the survey may have encouraged participation from a more diverse group of
purchasers. Although we cannot definitively rule out the possibility of response bias, the available data
does not provide any evidence that this was a significant problem in our survey.
2-31
-------
CHAPTER 3 | FINDINGS
This chapter presents evaluation findings, organized by evaluation question. For each evaluation question,
we provide a short introduction and key findings, followed by detailed findings.51
QUESTION 1: CHANGES IN FEDERAL PURCHASER ATTITUDES TOWARD GREEN PURCHASING
Introduction
This question explores changes in federal purchasers' perceptions of green products and services over
time. Evaluation Question 1 asks, "How has federal purchaser awareness of green products and services
changed since the 2001 baseline assessment?" For purposes of this question, we have interpreted
"awareness" to include attitudes toward green products and services as well as familiarity. This evaluation
question does not concern awareness of or attitudes toward the EPP Program specifically, but rather
environmentally preferable purchasing in general. Thus, when we refer to "EPP" in the discussion of
Evaluation Question 1, we are referring to environmentally preferable purchasing in general, and not to
the EPP Program.
Our main baseline for this comparison is a report prepared for the Pollution Prevention Division (PPD) in
2001, "Qualitative Measurement of Environmentally Preferable Purchasing (EPP) Among Federal
52
Employees in 2000." This study, undertaken by NuStats, was aimed at developing a baseline
characterization of environmentally preferable purchasing (EPP) in the federal realm (see text box on next
page for details). We also included questions in the 2013 survey that asked respondents to compare their
views on green purchasing today to their views three years ago.
To describe current attitudes and awareness toward EPP, we analyzed responses to several key questions
from our survey of federal purchasers, discussed in detail in Chapter 2. We compared our findings from
relevant survey questions to the corresponding results of the 2001 baseline assessment. This approach
presents two main challenges:
• Unlike our current effort, the 2001 study did not include a quantitative survey, nor did it provide
quantitative analysis of its interview or focus group findings.
• Not all of the relevant questions on attitudes and awareness posed in the 2013 federal purchaser
survey correspond precisely to the particular topics discussed in the 2001 assessment.
51 Question 13 is addressed by the findings from Questions 10-12, and question 14 is addressed by the recommendations in Chapter 4.
52 "Qualitative Measurement of Environmentally Preferable Purchasing (EPP) Among Federal Employees in 2000." Prepared for Julie Winters,
Pollution Prevention Division, Office of Pollution Prevention and Toxics, U.S. Environmental Protection Agency. EPA742-R-01-001. February 2001.
3-1
-------
Both of these factors limit our ability to draw
precise comparisons between the two data
sources, and as a result, we therefore can only
compare the 2013 survey data to the baseline
study results in general terms. Nonetheless, the
results of the 2001 baseline assessment relevant
to this evaluation question were generally quite
unambiguous, and the results for applicable
survey questions were similarly clear. As a
result, we have a fairly high degree of
confidence in our findings.
Key Findings
• We found clear evidence of a broad shift
among federal purchasers toward greater
awareness and more positive attitudes
toward EPP. A strong majority of
purchasers report having positive views
toward EPP in general, and purchasers
appear to be accepting a greater degree of
responsibility for bringing environmental
considerations into their purchasing
decisions. Both of these findings represent
distinct differences from the results of the
2001 study. Furthermore, individuals who
have been purchasers for three or more
years report becoming more knowledgeable
and more favorably inclined toward EPP
over that time.
• Purchasers today identify higher cost and
several factors related to a lack of
information as the key disadvantages of
EPP. In contrast, the 2001 study indicated
that the key problems at that time were a
perceived lack of quality for
environmentally friendly products and a
lack of support from top management;
these are no longer major concerns for most
purchasers.
• Finally, purchasers are giving more
importance to environmental considerations
in their purchasing decisions than they did
in the 2001 study. At that time, it was rare
OVERVIEW OF THE 2001 BASELINE ASSESSMENT
In February 2001, NuStats produced a report for PPD
entitled "Qualitative Measurement of Environmentally
Preferable Purchasing (EPP) Among Federal Employees
in 2000." It was the first phase of a larger research
project aimed at evaluating current efforts relating to
environmentally preferable purchasing and determining
what led people to integrate environmental
considerations into their purchasing decisions.
The assessment was guided by five broad "learning
questions":
• What are the general attitudes, behaviors, and
perceived information needs regarding purchasing?
• What are the attitudes, behaviors, and perceived
information needs in defining environmental
preferability?
• What is the general awareness of the "Greening of
Government" initiative?
• What are the awareness levels and opinions about
EPP outreach materials?
• Are there opportunities to fit EPP into day-to-day
procurement activities?
NuStats' research was qualitative in nature, using
interviews, focus groups, and other small group sessions
to generate data. 130 participants took part in the
study, including federal staff involved in all aspects of
the purchasing process, from the individuals requesting
products and services to those overseeing procurement,
contracting, and purchasing.
The researchers summarized their results in eight key
findings:
1. Executive Order provisions on the "Greening of
Government" are not perceived as mandates.
2. Agency- or department-specific mandates motivate
purchasers more than government-wide Executive
Orders.
3. Study participants consider different factors when
evaluating products versus services.
4. Few study participants recognized the term
"environmentally preferable purchasing."
5. Some federal purchasers and requesters consider
the environment in a purchase decision.
6. Study participants believe the responsibility for
doing EPP lies elsewhere.
7. Federal purchasers and requesters rarely mention
environmental factors as a primary consideration.
8. Awareness of EPA's EPP tools and resources is low
among study participants.
3-2
-------
for purchasers to explicitly consider environmental factors when purchasing goods or services. Now,
most purchasers say that environmental characteristics are an important consideration. While most
purchasers do not give particularly high priority to environmental factors compared to other product
attributes, neither do they ignore them.
We discuss these findings in more detail below.
General Awareness of and Attitudes Toward Environmentally Preferable Purchasing
The 2001 baseline assessment found very low levels of awareness of the term "environmentally
preferable purchasing" or what it entailed. While buyers readily understood the concept once it was
defined for them, it was not something that most had any familiarity with, and they had no grasp of the
specifics of EPP.53
The introductory language of the survey provided survey takers with a working definition of EPP, thereby
guaranteeing at least a minimal level of familiarity. Nonetheless, survey data provides indications that
federal purchasers have higher levels of awareness of EPP now than in 2001. One survey question asked
purchasers whether they had considered environmental attributes at least once in the past year when
making purchasing decisions; 62% of respondents indicated that they had done so. While this is a
measure of behavior, it also indicates purchasers' awareness of EPP, since awareness of environmentally
preferable purchasing is a precondition for behavior incorporating environmental factors into purchasing
decisions. Thus, the 62% of survey respondents indicating that they had considered environmental factors
in the past year represents a minimum level of purchasers that have familiarity with the concept of EPP.
This is a dramatic change from the 2001 baseline assessment.
Attitudes towards EPP have also changed markedly since the baseline assessment. While that study did
not directly report findings on purchasers' general attitudes, it appears that most purchasers at that time
had at best neutral and at worst negative views toward EPP.54 Several participants in the 2001 study
reported "that they or others in their agency do not make environmental purchasing considerations
because it has little or no relevance to their agency's mission or what they purchase." The baseline
study also identified a widely-shared belief among purchasers that environmentally preferable products
were inferior to conventional products. Finally, most participants in the study indicated that they would
not integrate EPP more fully into their routine procurement activities unless they were required to do so,
stating that "it's not my job." These responses paint a picture of a procurement workforce that, on the
whole, took a dim view of EPP.
The 2013 survey asked purchasers directly about their views toward EPP and yielded much more
favorable results (Exhibit 3-1). Over 80% of purchasers described their attitude toward EPP as "somewhat
positive" or "very positive," compared to less than 8% choosing "very negative or somewhat negative."
Twelve percent (12%) indicated that they did not know or had not made up their mind. Service purchasers
appeared to have somewhat more favorable views than product purchasers, but the difference was not
53 Ibid, p. 10.
Mlbid, p. 17.
55 Ibid, p. 16.
56 Ibid, p. 21.
3-3
-------
statistically significant (and in addition, other survey questions provide a contradictory view of the
differences between the two groups). Clearly, a strong majority of current federal purchasers has positive
attitudes toward EPP.
EXHIBIT 3-1. VIEWS TOWARD ENVIRONMENTALLY PREFERABLE PURCHASING
In general, how would you describe your view towards environmentally preferable purchasing?
50%
40%
30%
20%
10%
0%
Very Somewhat Somewhat Very positive Don't know
negative negative positive
• Product purchasers • Service purchasers
One way in which negative attitudes toward EPP were manifested in the 2001 study was that purchasers
did not take responsibility for bringing environmental considerations into purchasing decisions. The
report describes "finger pointing regarding when the decision making should occur," with many buyers
arguing that environmental considerations "would be best handled at the beginning of the purchase
process (i.e., when the need is identified or the specifications are written), before it gets to
procurement." NuStats identified as one of their key findings the belief among study participants that
responsibility for EPP lay elsewhere
58
Like awareness of EPP, we did not test the question of a sense of responsibility directly in our survey of
federal procurement staff. However, once again, there is data available to address the issue. The survey
asked purchasers of electronics and building and construction products (separately) about the proportion
of their purchases in these product areas that were certified to certain specific sustainability standards.
Purchasers indicating that less than 50% of their purchases were certified to these standards were given a
follow-up question on their reasons for not buying more certified products. A very low proportion
indicated that their reason for not buying more certified products was that they were not required to do so:
18% of purchasers with low rates of EPEAT certified electronics purchases, and 7% of purchasers with
"Ibid, p. 12.
581 bid, p. 8.
3-4
-------
low rates of certified building and construction product purchases. It should also be noted that, because
the subsample of survey takers that were asked this question was already low, the absolute numbers of
purchasers citing this reason for not buying more certified products are extremely low, just 13 electronics
purchasers and 14 building and construction product purchasers. The fact that very few purchasers are
using the lack of a requirement as a justification for low rates of environmentally preferable purchases
suggests that most purchasers have internalized at least some degree of a sense of responsibility for
integrating environmental considerations into their purchasing decisions.
Although it does not provide a direct comparison to the baseline study, the survey also asked respondents
who had been federal purchasers for at least three years about changes in their attitudes and awareness
regarding EPP over that time. Consistent with the findings outlined above, the results for these survey
questions show that the procurement workforce as a whole has become more knowledgeable and more
favorably disposed toward EPP over time (Exhibit 3-2). A majority of respondents indicated that they felt
more knowledgeable than they did three years ago; most of the rest felt equally knowledgeable. Similarly,
43% of respondents reported more favorable attitudes toward EPP, while most of the rest thought their
attitudes had stayed the same. Less than 5% reported feeling less knowledgeable or having less favorable
attitudes toward EPP than they did three years ago.
EXHIBIT 3-2. CHANGES IN AWARENESS AND ATTITUDES OVER THE PAST THREE YEARS
Do you feel more knowledgeable, less
knowledgeable, or equally knowledgeable about
environmentally preferable purchasing today
than you did THREE YEARS AGO?
Over the PAST THREE YEARS, has your attitude
towards environmentally preferable purchasing
become more favorable, less favorable, or
stayed the same?
LESS
KNOWLEDGEABLE
4.9%
LESS FAVORABLE
4.9%
EQUALLY
KNOWLEDGEABLE
38.5%
STAYED THE
SAME
49.7%
MORE
KNOWLEDGEABLE
52.9%
MORE
FAVORABLE
42.8%
DON'T
KNOW
3.7%
DON'T
KNOW
2.6%
Advantages and Disadvantages of Environmentally Preferable Purchasing
In addition to the general attitudes and awareness discussed above, we also analyzed several specific
aspects of purchasers' views toward EPP. One of these is the relative advantages and disadvantages of
EPP. The 2001 baseline assessment did not discuss the advantages of EPP beyond a passing comment that
among the small group of purchasers who did engage in EPP, their reason for doing so was a personal
interest or sense of civic duty. The lack of a discussion of EPP benefits is significant in its own right;
evidently, the benefits of EPP were not seen as sufficiently important to warrant further consideration.
The 2013 survey asked purchasers directly about the key advantages of considering environmental factors
in purchasing decisions (Exhibit 3-3). As one might expect, the most frequently chosen responses were
"environmental benefits" (76%) and "fulfill obligations/mandates" (63%). However, purchasers also
listed several other advantages; more than 40% identified "improve worker health and safety" and "best
value" as key advantages of considering environmental factors in purchasing decisions. Only 5% chose
'Ibid, p. 17.
3-5
-------
"none of the above," which implies that the other 95% of purchasers felt that EPP had at least one major
advantage.
EXHIBIT 3-3. PERCEIVED ADVANTAGES OF EPP
WHAT DO YOU SEE AS THE KEY ADVANTAGES OF CONSIDERING ENVIRONMENTAL
FACTORS IN YOUR PURCHASING DECISIONS? (CHECK ALL THAT APPLY)
Environmental benefits
Fulfill obligations/mandates
Improve worker health and safety
Best value
Sense of pride
Positive image/recognition and awards
None of the above
Other
76.4%
62.9%
44.7%
43.4%
22.0%
12.7%
5.2%
3.0%
The baseline assessment identified three key disadvantages or barriers to EPP.
• First, the study indicated that many purchasers did not buy environmentally preferable products due
to a perceived lack of quality. This was a widespread attitude. However, purchasers' impressions of
inferior product quality were rarely based on recent firsthand experience. Thus, "nearly everyone said
their 'experience' was based on a product that was used several years ago (some 10 or more years
ago), or they explained that they did not have personal experience but rather their knowledge was
based upon 'hearsay' from other colleagues."
• Second, there was a lack of buy-in from upper management across most federal agencies to buy
greener products. Several study participants "felt that they needed stronger leadership from their
upper management in making [EPP] more of a priority in their agency.
,,61
Third, purchasers cited a lack of information. Many purchasers felt that it would take too much time
for them to research specific products to meet environmental criteria, and suggested that they needed
easier ways to identify products that would meet environmental criteria, perhaps through a green label
or something similar.
62
We asked participants in the 2013 survey directly about the key disadvantages of EPP. The results were
straightforward (Exhibit 3-4). The most commonly cited disadvantage was higher cost, chosen by 62% of
respondents. Only 24% of survey takers identified inferior product/service quality as a disadvantage of
EPP, and 11% listed lack of management support, making these the least-cited of all options listed in the
survey; thus, the two most serious problems from the 2001 baseline study are no longer major concerns
for most purchasers. In contrast, lack of information remains a challenge. Thirty-eight percent of survey
respondents identified lack of information as a key disadvantage of EPP, and furthermore, a closely
related consideration, unclear definition of "green," was chosen by an even higher number (56%). Sixty-
60 Ibid, p. 17.
61 Ibid, p. 18.
62 Ibid, pp. 8-9.
3-6
-------
five percent of respondents identified lack of information and/or unclear definition of "green" as
disadvantages of EPP (Exhibit 3-5).
EXHIBIT 3-4. PERCEIVED DISADVANTAGES OF EPP
WHAT DO YOU SEE AS THE KEY DISADVANTAGES OF CONSIDERING ENVIRONMENTAL
FACTORS IN YOUR PURCHASING DECISIONS? (CHECK ALL THAT APPLY)
Higher cost
Unclear definition of "green" /difficult to verify "green"
marketing claims
Lack of available environmentally preferable
products/services that meet requirements
Lack of information
Time-consuming/inconvenient to purchase
Inferior product/service quality
Lack of management support
None of the above
Other
61.5%
56.1%
46.1%
38.1%
28.7%
24.1%
10.8%
9.8%
3.4%
EXHIBIT 3-5. PURCHASERS CITING LACK OF INFORMATION AND/OR UNCLEAR DEFINITION OF
"GREEN" AS KEY DISADVANTAGES OF EPP
Lack of
information
Unclear
definition of
"green"
737 respondents (29%) selected
both "lack of information and
"unclear definition of
green/difficult to verify green
marketing claims"
918 respondents (36%) (9% + 27%)
selected one factor or the other
884 respondents (35%) selected
neither factor
Importance of Environmental Attributes in Purchasing Decisions
One critical way in which purchasers' attitudes toward EPP influences their behavior is in the relative
weight that they assign to environmental attributes when making purchasing decisions. Both the 2001
baseline assessment and the 2013 survey probed this issue and found that cost and performance were the
most important factors driving purchase decisions. The 2001 study indicated that cost was paramount,
3-7
-------
followed by quality, vendor reputation, and performance. Similarly, in the more recent survey, more
than 95% of all purchasers considered quality, cost, and best value to be either "very important" or
"moderately important."
While these factors have shown little change over time, there has been a more marked shift on the
importance of environmental attributes. When NuStats conducted the 2001 baseline assessment, they
found that purchasers would rarely mention environmental factors unprompted as a consideration in their
purchasing decisions. Even when asked specifically about environmental attributes, purchasers made it
clear that they did not routinely consider environmental issues when making purchase decisions. The
survey data shows a very different situation today. Seventy-eight percent (78%) of product purchasers and
67% of service purchasers consider environmental attributes "very important" or "moderately
important." This places environmental attributes in the middle of the factors evaluated, above such
considerations as easiest to purchase, small business set-asides, mandatory sources, and even brand
reputation (Exhibit 3-6). In other words, most purchasers do not give environmental attributes particularly
high priority when ranked against other factors, but neither do they give the environment particularly low
priority - and most purchasers do consider environmental factors to be important in the abstract. Clearly,
this represents a significant change from the 2001 study.
EXHIBIT 3-6. CHANGES IN AWARENESS AND ATTITUDES OVER THE PAST THREE YEARS
How important is each
of the following factors
in your purchasing
decisions for products?
Cost
Quality
Best Value
Brand Reputation
Past Experience with the
Product
Meeting exact
specifications
Environmental attributes
Easiest to purchase of all
available choices
Small business set-asides
Mandatory sources (e.g.,
AbilityOne, NIB/NISH,
UNICOR)
Other
NOT AT ALL
IMPORTANT
0.2%
0.4%
0.4%
7.5%
1 .0%
0.6%
4.8%
8.8%
6.4%
4.8%
8.7%
SLIGHTLY
IMPORTANT
1.7%
1 .0%
1.5%
22.8%
4.7%
3.6%
13.2%
21 .6%
14.3%
8.4%
2.2%
MODERATELY
IMPORTANT
17.3%
10.5%
12.3%
41.5%
31.6%
24.0%
38.3%
40.0%
30.9%
22.5%
6.3%
VERY
IMPORTANT
80.5%
87.9%
84.8%
24.8%
61 .2%
70.2%
39.9%
26.0%
41.6%
56.4%
7.5%
DON'T KNOW/
NO OPINION/
NOT APPLICABLE
0.4%
0.5%
1 .0%
3.4%
1 .4%
1.7%
3.7%
3.6%
6.8%
7.9%
75.3%
631 bid, p. 9.
64 Ibid, p. 10.
65 The implication that product purchasers have more favorable attitudes toward EPP than service purchasers contradicts the other survey results
comparing these two groups, discussed above. As such, we do not believe there is a clear difference in attitudes between these two groups.
3-8
-------
QUESTION 2: CHANGES IN FEDERAL PURCHASER BEHAVIOR REGARDING GREEN PURCHASING
Introduction
Following our analysis of changes in federal purchasers' attitudes in Evaluation Question 1, we turn next
to changes in their behavior. Evaluation Question 2 asks, "How have federal agencies changed purchasing
of green products and services since the 2001 baseline assessment, including incorporating green criteria
into specifications and contract language?" Similar to Evaluation Question 1, this evaluation question
does not examine the extent to which the EPA EPP Program contributed to any observed changes; rather,
this analysis concerns environmentally preferable purchasing behavior in general. Also, it is important to
note that the EPA EPP Program's influence on federal purchasers' behavior is addressed in Evaluation
Question 6.
The data sources and methods for this analysis are similar to those used in Evaluation Question 1. Once
again, the analysis draws heavily on a comparison between results reported in the 2001 baseline
assessment, "Qualitative Measurement of Environmentally Preferable Purchasing (EPP) Among Federal
Employees in 2000," and our 2013 survey of federal purchasers. As we noted in Evaluation Question 1,
this approach poses two major challenges: the 2001 study did not include a survey or quantitative analysis
of its interview or focus group findings, and not all of the relevant questions in the 2013 federal purchaser
survey correspond precisely to research covered by the baseline assessment. Thus, we can make only
general comparisons between these two sources. Unlike Evaluation Question 1, our analysis for
Evaluation Question 2 is also informed by interviews and other data-gathering efforts undertaken in the
course of this evaluation.
Key Findings
• Environmentally preferable purchasing activity is much more widespread now than it was at the time
of the 2001 baseline assessment. Similarly, many individuals who have been federal purchasers for at
least three years indicate that their levels of environmentally preferable purchases have increased over
that time. Thus, consistent with the shift in attitudes described in Evaluation Question 1, we found
that federal purchasers as a group have changed their behavior to engage in more environmentally
preferable purchasing.
• Nonetheless, EPP activity is still not routine. Most purchasers consider environmental factors
occasionally, but do not buy environmentally preferable products or services at particularly high rates.
• Purchasers rely heavily on materials developed by their own agencies and departments and on the
Federal Acquisition Regulation (FAR) to guide their purchasing decisions. This underscores the need
for interagency collaboration if the EPP Program is to maximize its impact on federal purchasing
behavior.
• Interviews with a small number of purchasing policy managers indicate that GSA and the Department
of Energy (DOE) have taken substantial actions to incorporate environmental criteria into their own
purchasing, including many of the standards the EPP Program helped to develop. These agencies are
leaders in this field; other agencies' efforts appear less robust.
' "Qualitative Measurement of Environmentally Preferable Purchasing (EPP) Among Federal Employees in 2000," February 2001, op. cit.
3-9
-------
We discuss these findings in more detail below.
General Environmentally Preferable Purchasing Behavior
The 2001 baseline assessment found a low level of EPP activity among federal purchasers. Although
some purchasers would occasionally purchase environmentally preferable products or services, this was
not a widespread pattern of behavior. In general, purchasers did not consider environmental factors when
making purchase decisions, and they indicated mandates from their managers were needed to bring EPP
into their routine purchasing activities.
The 2013 survey of federal purchasers included several questions on purchasers' behavior in evaluating
and choosing environmentally preferable versus conventional products and services. We discuss only a
few of the most pertinent survey questions here, but a complete summary of the survey data is available in
Appendix C. Overall, the survey data indicates that EPP is far more common among federal purchasers
now than it was during the baseline assessment, but it is still not routine. As one basic measure, we asked
purchasers whether they had made at least one purchase in the last year in which they considered
environmental factors in their purchasing decision. Nearly two-thirds of survey respondents (62%) had
incorporated environmental factors at least once, while the remainder had not. These data suggest that a
broad segment of the procurement workforce addresses environmental concerns in their purchasing at
least occasionally.
Perhaps the most critical measure of behavior in the survey is the percentage of total purchases made over
the past year that was environmentally preferable (Exhibit 3-7). A third of purchasers indicated that 25%
or less of their purchasers were environmentally preferable, while another third did not know the
proportion. Just 17% of purchasers reported that a majority of their purchases over the past year qualified
as environmentally preferable. As we will discuss in more detail in Evaluation Question 4, GSA
purchasers were well above average on this question, while EPA purchasers' performance was
unremarkable compared to the performance of other agencies.
We asked similar questions for electronics purchasers and building and construction products purchasers
specifically. Most building and construction product purchasers either did not know how many of the
products they purchased were certified to specific sustainability standards (36%), or bought only a low
number of certified products (24%) (Exhibit 3-7). The results for building and construction product
purchasers were broadly similar to the pattern for all purchasers noted above, although building and
construction purchasers demonstrate slightly greener behavior than other purchasers.
Electronics purchasers showed a somewhat different pattern (Exhibit 3-8). We asked these purchasers
about their levels of EPEAT, Federal Energy Management Program (FEMP), and Energy Star purchases.
The strong majority of purchasers could not estimate their level of EPEAT or FEMP certified purchases
(65% and 73% respectively), but of those that could, most reported that more than 75% of their purchases
met these criteria. Purchasers were far more aware of Energy Star: a majority of electronics purchasers
reported that 75% or more of their electronics purchases were Energy Star certified, while just 28% chose
"don't know." Evidently, Energy Star has far more visibility for purchasers than the other electronics
standards (perhaps due to its much longer history), but for all of the standards, purchasers that are aware
of them buy certified products at high rates.
'Ibid, pp. 10, 21.
3-10
-------
EXHIBIT 3-7. ENVIRONMENTALLY PREFERABLE PURCHASING BEHAVIOR
In the past year, approximately what percentage of the products/services that you purchased was
environmentally preferable? (Building and construction products purchasers: percentage of building and
construction products purchased certified to one of the standards listed)
40%
30%
20%
10%
0%
Less than 26-50% 51-75% More than Don't know
25% 75%
• All purchasers • Building & construction product purchasers
EXHIBIT 3-8. ENVIRONMENTALLY PREFERABLE PURCHASING AMONG ELECTRONICS PURCHASERS
In the past year, approximately what percentage of the computers and monitors that you purchased was
certified under the following standards?
26-50%
Less than
25%
• Energy Star
51-75% More than Don't know
75%
FEMP EPEAT (IEEE 1680)
3-11
-------
The survey also asked respondents who had been federal purchasers for at least three years about changes
in their attitudes and awareness over that time. The results show a broad but not uniform shift towards
more environmentally preferable purchasing (Exhibit 3-9); 42% of respondents reported that the
proportion of products or services they purchased that was environmentally preferable had increased over
the past three years, while an equal number felt it had stayed the same. Just 1.5% reported a lower rate of
environmentally preferable purchases compared to three years ago.
EXHIBIT 3-9. CHANGES IN PURCHASING BEHAVIOR OVER THE PAST THREE YEARS
Over the PAST THREE YEARS, has the portion of
products/services that you purchased that was
environmentally preferable increased,
decreased, or stayed the same?
DECREASED
1.5%
STAYED THE SAME
42.1%
INCREASED
42.0%
DON'T KNOW
14.4%
To better understand purchasers' behavior, we asked them to identify which environmentally-related
resources they used when making purchasing decisions. A strong majority of survey respondents
indicated that they used resources produced by their own agency or department, as well as the Federal
Acquisition Regulation (FAR) - 89% and 80% respectively. Thirty-nine percent (39%) reported using
Presidential Executive Orders. At the bottom of the list were EPA's EPP website guidance and materials
from EPA, and guidance and materials issued by other federal agencies, with less than 20% of purchasers
using each resource. On its face, this would suggest rather limited influence for these resources. However,
O J OO J
indirect effects cannot be captured by the survey question; for instance, agency-level procurement
materials may have been influenced by EPA guidance without survey takers being aware of it. (For the
same reason, purchasers' rates of buying certified products may be higher than reflected here, if the
procurement systems they use incorporate green certifications such as EPEAT without the purchasers
being aware of it.) Thus, these items may have had greater impact on federal purchasing than the results
would indicate. Even so, these survey results point to the paramount importance of agency-level resources
in guiding purchasers' behavior.
Incorporating Green Criteria Into Agency Purchasing
In addition to green purchasing behavior in general, Evaluation Question 2 also asks about the extent to
which federal agencies have incorporated new green criteria into specifications and contract language
since the 2001 baseline assessment. Because the 2013 survey was aimed primarily at federal purchasers
and their activities rather than the managers that set purchasing policy, we have only limited survey data
to address this question. However, we also conducted a limited number of interviews with federal
purchasing policy managers, and additional research, that can also provide insight into this issue.
Perhaps the most basic step a federal agency can take to promote EPP is to adopt a formal EPP policy.
The 2001 baseline study showed that purchasers considered agency policies to be more binding than
Executive Orders, indicating that these instruments had greater weight in shaping their behavior.
However, agency-level EPP policies were not common at that time; most purchasers indicated that they
3-12
-------
were not required to make environmentally preferable purchases and that they had limited management
support for EPP.68
The survey indicates that EPP policies are now more widespread. Sixty percent (60%) of survey
respondents stated that their agency or department had an EPP policy, with just 6% saying it did not (34%
were not sure). Similarly, 62% of survey takers said that their agency or department gave environmentally
preferable products and services some kind of preference, with just 9% saying there was no preference
given and 29% reporting that did not know. Of those purchasers indicating their agency had an EPP
policy, 55% indicated that the policy required EPP for some or all purchases.
We interviewed purchasing policy managers from GSA and DOE to better understand EPP activities in
these agencies. These agencies were chosen because of their ties to EPA and their importance in federal
procurement. According to the individuals interviewed, GSA and DOE have incorporated numerous
sustainability standards and other criteria into their purchasing. DOE has made use of nearly all of the
sustainability standards that EPA's EPP Program helped to develop, as well as recycled content
guidelines and USDA's BioPreferred program.
GSA has incorporated several green criteria into GSA Schedules and GSA Advantage! GSA Advantage!
is a major online purchasing system used throughout the federal government, in addition to agency-
specific systems. Exhibit 3-10 reproduces a portion of the GSA Advantage! interface showing green
criteria available for purchasers to use in product searches. GSA Advantage! did not have any searchable
green criteria of this kind at the time of the 2001 baseline assessment; thus, all of the criteria shown have
been added since that time.
It is notable that EPEAT is the only non-government certification currently represented in GSA
Advantage!; the other criteria refer to federal programs (BioPreferred, Energy Star) or criteria that are
unaffiliated with any specific environmental certification system (Low VOC). Exclusion from GSA
Advantage! is a major factor hindering greater uptake of non-governmental product standards among
federal purchasers. In fact, at one point GSA had included several other certifications in the GSA
Advantage! system, including the NSF 140 carpet standard, Green Seal, GreenGuard, and Forest
Stewardship Council certification for wood products. However, industry pressure from competing
ecolabels and affiliated manufacturers led them to withdraw these standards. This was one of the factors
that led to the creation of the current effort to address the federal use of environmental standards and
ecolabels, which we discuss in Evaluation Question 6.
GSA has also incorporated the EPEAT and NSF 140 standards into its own purchasing, as well as several
other green criteria not developed by the EPP Program (e.g., BioPreferred, Energy Star, and WaterSense,
among others). GSA's Public Building Service, which oversees federal buildings, also has policies in
place requiring compliance with LEED and Energy Star (with different requirements applying to different
types of buildings).
We also interviewed purchasing policy managers from the Department of Defense and the Office of
Personnel Management; the interviews suggested that their efforts to incorporate green criteria into their
68 Ibid, pp. 8, 9,21.
69 Industry representatives suggested that GSA may also be using the BIFMA e3 furniture standard for its own purchasing, but we did not corroborate
this with GSA.
3-13
-------
purchasing were not as robust as DOE's or GSA's. The managers did not portray their agencies' efforts
as particularly systematic, and they indicated that their policies were not aligned with the requirements of
EO 13514. Other than EPEAT, the only other green criterion mentioned was the NSF 140 carpet standard,
which was used by OPM. Given their particular missions, we expect that DOE and GSA are more likely
the exception than the rule with respect to efforts to incorporate green criteria into agency purchasing.
EXHIBIT 3-10. GREEN ICONS IN GSA ADVANTAGE!
Go Green
GSA offers products and services that
support your Green efforts and help
our nation build a clean energy future
and protect the environment.
> learn more about GSA's Green Initiatives »
Product Search
Confused About
Buying Green?
Learn More
Look for:
in All Categories
Select an environmental program below
Note: checking more than one will return only those items having all the indicators selected
BioPreferred
Energy Star
Compliant
CPG Item
EPEAT
FEMP
FEMP Energy
HEMP
Efficient item
NESHAP
Compliant
?RHK PRIME Item
ES3 S.N.A.P. Approved
EPA
Primary
Metals Free
LowVOC
WaterSense
Responsiveness to Executive Orders
The final aspect of purchaser behavior that we analyze in this Evaluation Question is responsiveness to
Presidential Executive Orders. At the time of the 2001 baseline assessment, the most recent Executive
Order to address EPP was EO 13101, "Greening the Government through Waste Prevention, Recycling,
and Federal Acquisition," issued by President Clinton in September 1998. This EO was an area of
particular emphasis in the baseline assessment; one of the five "learning questions" shaping the evaluation
addressed the level of awareness of this EO in the federal procurement community. In fact, NuStats' first
'key finding' from the baseline assessment was that most participants did not view the Greening the
Government EO as imposing mandatory requirements.
71
Our results from the 2013 survey are somewhat more difficult to interpret, but they indicate that at least a
substantial minority of purchasers has altered its behavior in response to the recent EO 13514, "Federal
Leadership in Environmental, Energy, and Economic Performance," which President Obama signed in
70 We also interviewed a purchasing policy manager from EPA; we address EPA's green purchasing efforts under Evaluation Question 4.
71 Ibid, p. vi.
3-14
-------
October 2009. Thirty-nine percent (39%) of purchasers indicated that they had changed their purchasing
behavior following the EO; 32% had not, while the remaining 29% did not know. On its face, this would
suggest that the EO had only a modest impact in actually changing federal behavior. However, it is
possible that some of the purchasers who did not report any change in behavior were already purchasing
environmentally preferable products and services at high levels, and thus were already in compliance with
the requirements of the EO. In addition, as we noted above, it is possible that the EO may have had an
indirect effect by prompting changes in agency purchasing policies and procedures that survey takers
were unaware of.
QUESTION 3: FEDERAL PURCHASES OF GREEN PRODUCTS AND SERVICES
Introduction and Key Findings
Evaluation Question 3 asks: "What are the outcomes of these changes [in federal purchaser awareness and
behavior] in the proportion of green products and services purchased by federal agencies?" As discussed
in Chapter 2, comprehensive trend data on federal purchases are available for the electronics sector and
specifically for purchases of EPEAT products. These data indicate that total EPEAT sales to the federal
government increased 50% from 2008 - 2010. As discussed in Chapter 2, comparable data are not
available for the products certified to the building and construction standards that EPP helped to develop.
As such, this section describes the limited data that are available through GSA Schedules for building and
construction product sales, and provides case study-level findings derived from the mini-market analysis.
It is important to note that we cannot extrapolate the limited information available for building and
construction product sales to the federal government as a whole. In addition, as noted in Chapter 2, no
purchasing data are available on changes in federal hospitality and travel associated with EPP activities.
Electronics Sector
To address federal agencies' purchases of environmentally preferable products in the electronics sector,
our primary information source is data on federal purchases of EPEAT-registered electronics, including
desktop computers, laptop computers, monitors, and integrated systems.
The EPEAT registry has been in existence since 2006; EPP played a key role in developing and launching
the registry and the underlying IEEE standards. Since that time, EPEAT has figured prominently in the
federal government's sustainable procurement efforts. In January 2007, President Bush signed Executive
Order 13423, which required federal agencies to purchase EPEAT products for 95% of their electronics in
product categories with EPEAT standards. The 95% requirement was reaffirmed in President Obama's
Executive Order 13514, signed in October 2009. Due to the involvement of the EPP Program in
developing EPEAT, and EPEAT's centrality in government-wide environmentally preferable purchasing
policy, EPEAT represents the logical focus for our analysis of the electronics sector.
The Green Electronics Council (GEC), which was established with start-up funding from EPP, currently
manages implementation of the EPEAT program. GEC provided lEc with data on total sales of EPEAT
electronics to the federal government (equivalent to total federal purchases of EPEAT electronics) for
2008 - 2010; this data is reproduced in Exhibit 3-11.
3-15
-------
EXHIBIT 3-11. EPEAT PURCHASES BY THE FEDERAL GOVERNMENT1
Desktops
Monitors
Laptops
Integrated Systems
Total
2008
577,260
181,141
213,275
0
971,676
2009
1,156,682
1,134,811
644,564
4
2,936,061
2010
515,184
unknown2
561,852
111,187
unknown
1 Data reported is number of products purchased (not dollar amounts).
2 Reported sales of EPEAT monitors in 2010 were 7,823,459; GEC staff consider this data
point unreliable, but have been unable to obtain corrected data. (That level of
purchases would amount to more than two monitors for every federal employee.) We
therefore exclude this data point from our analysis.
Source: data originally collected by the Information Technology Industry Council and
reported to the Green Electronics Council. Provided to lEc through personal
correspondence with Cate Berard, EPA, Dec. 14, 2011.
1,400,000
1,200,000
1,000,000
2 800,000
600,000
400,000
200,000
0
EPEAT Purchases by the Federal Government
•Laptops
• Desktops
Monitors
• Integrated Systems
2008
2010
Total EPEAT purchases by the federal government increased from 2008 to 2010, but the pattern of
growth was not steady over that period. Purchases tripled from 2008 to 2009, with laptops, desktops, and
monitors all showing a substantial increase. Desktop purchases fell sharply in 2010, while the decline for
laptops was more modest; notably, laptops accounted for a higher number of EPEAT purchases than
desktops in 2010. This mirrors a more general market-wide shift away from desktops and toward laptops,
3-16
-------
a point we will return to in other evaluation questions. Overall EPEAT purchases by the federal
government decreased by about 36% from 2009 to 2010 (excluding monitors, for which data was not
available in 2010). While we have not undertaken a comprehensive investigation of this issue, we
speculate that the general pattern of fluctuating purchase levels may have been driven by broader trends in
agency budgets (i.e., a sharp increase in purchasing due to the stimulus of the American Recovery and
Reinvestment Act, followed by subsequent cutbacks).
Ideally, to evaluate federal purchases of green products, we would calculate the proportion of total
computer and monitors purchases made up of EPEAT products over time, but reliable data on total
(EPEAT and non-EPEAT) sales to the federal government are not available. In exploring this issue, lEc
obtained data on government-wide electronics purchases from the Office of Management and Budget
(OMB), which collects this data to report on federal agencies' progress toward meeting the sustainable
purchasing goals laid out in Executive Order 13514. However, our review of the OMB data, particularly
in comparison to data obtained from other sources, reveals several issues that lead us to question its
accuracy. As a result, we are unable to report data on EPEAT's market share of government purchases.
Excluding monitors, total EPEAT purchases by the federal government were 50% higher in 2010 than in
2008. This compares to a 16% increase in EPEAT sales for the United States as a whole over this time
period. In other words, the federal government increased its purchases of EPEAT electronics at a faster
rate than the market as a whole; indeed, the federal government's rate of increase was greater than the
United States as a whole in all four product categories. Because we have only three years of purchasing
data, this preliminary trend does not support a definitive conclusion, but it nonetheless suggests that the
72 The issues with OMB's federal purchasing data become evident when these data are compared to other sources that we reviewed in the course of
our analysis the Federal Electronics Challenge (FEC) program's effectiveness in encouraging EPEAT sales among its partner facilities (Evaluation
Question 9). Specific points that cast doubt on the accuracy of OMB's federal purchasing data include the following:
1) FEC partners reported more purchases of non-EPEAT products in absolute numbers than are shown for the entire federal government in the
OMB data. This is true in both 2009 and 2010 (there was no OMB data for 2008), in all product categories, with the exception of monitors in 2010
(where FEC's purchases supposedly accounted for 96% of all non-EPEAT purchases in the federal government). Unless FEC partners are over-
reporting their non-EPEAT purchases for their reporting to FEC - but not to OMB - this can only mean that federal agencies are under-reporting
their purchases of non-EPEAT products.
2) The federal government's proportion of EPEAT vs. non-EPEAT purchases is suspiciously high within the OMB data, particularly in comparison to
the FEC. OMB's data purport to show that the federal government purchased at least 98% EPEAT products in all categories and in all years from FY
2009 through FY 2011, with the exception of monitors in FY 2010, when the proportion of EPEAT products was 95.8%. Note that this would imply
full and immediate compliance with the 95% EPEAT purchase requirement of Executive Order 13514. In contrast, FEC partners purchased 96.4%
EPEAT products in 2009 and 91.3% in 2010. Given the FEC program's particular emphasis on EPEAT purchases and voluntary reporting of data, we
would expect that FEC partners are both more committed to EPEAT purchases, and more rigorous and accurate in their reporting, than non-FEC
partners. This would strongly suggest that non-FEC facilities are reporting unrealistically high proportions of EPEAT purchases.
3) GEC reports total EPEAT sales to the federal government two to five times the numbers reported by OMB (varying by year and product
category). Considered in light of the other evidence, we believe this is an indication of significant under-reporting of total purchases by federal
agencies in the OMB data, rather than over-reporting of sales by manufacturers in the GEC data.
4) Related to this last point, the OMB data as reported suggest that in 2009, FEC facilities accounted for 78.5% of the federal government's total
electronics purchases. (For 2010, the figure was 31.5%.) The FEC actually includes about 20% of all non-postal federal employees, and presumably
a similar level of electronics purchases. This, too, suggests that the OMB data are under-counting total federal electronics purchases.
All in all, these points strongly suggest that OMB's data on EPEAT vs. non-EPEAT purchases by the federal government is significantly flawed.
Given OMB's use of this data as a means to verify compliance with the requirements of Executive Order 13514, we recommend that OMB consider
taking action to validate the information submitted by federal agencies to ensure its accuracy. As we understand, OMB does not currently provide
any guidance or quality control to improve the accuracy of this data.
3-17
-------
federal government has made significant strides to increase its purchases of environmentally preferable
electronics. As additional data become available in future years, it should be easier to assess the
purchasing behavior of the federal government compared to the market as a whole.
Building and Construction Products
The evaluation team was not able to identify a robust source of purchasing data for the building and
construction product sector.73 Given the lack of purchasing data maintained by the federal government,
lEc contacted manufacturers that sell select environmentally preferable building and construction
products to the federal government. Specifically, we were interested in products that are certified to
environmentally preferable standards that EPP helped to develop. lEc cross-walked publicly available
lists of manufacturers that sell certified building and construction products to the list of manufacturers on
the GSA Multiple Award Schedules. We identified:
• 30 manufacturers that sell BIFMA e3/Level certified furniture through GSA Schedule 71;
• 11 manufacturers that sell NSF 140 certified carpet through GSA Schedule 72;
• 2 manufacturers that sell NSF 332 certified resilient flooring through GSA Schedule 72;
• 1 manufacturer that sells ULE 100 certified gypsum board through GSA Schedule 5IV.
lEc sent initial screening emails to all of the above manufacturers to request publicly available sales data;
the response was limited. We followed up via email and telephone with all of these companies to request
their participation in our voluntary data request. Ultimately, we received sales data from one carpet
manufacturer and four furniture manufacturers; we did not receive data from the resilient flooring
companies or the gypsum board company.
The four participating furniture companies account for approximately 10% of GSA Schedule sales of all
furniture manufacturers that sold BIFMA e3/Level certified products to the federal government in
FFY11.74 The participating carpet manufacturer accounts for approximately 15% of GSA Schedule sales
of all manufacturers that sold NSF 140 certified carpet to the federal government in FFYII.75 Given the
relatively low number of respondents, and the relatively low market share for these respondents, we
cannot extrapolate to the universe of manufacturers as a whole. Furthermore, the year in which
respondents began selling certified product varies: of the four furniture respondents, one began selling
BIFMA e3/Level certified furniture in 2010, two began in 2011, and one did not begin until 2012, which
is outside our study period. Also, although we asked all respondents to provide data using a standardized
data collection template, not all respondents provided data in a consistent way, limiting our ability to
aggregate the sales numbers. Despite these caveats, the evaluation team believes that the analysis provides
useful anecdotal information for the selected companies.
73 GSA provided some data on sales of certified carpet through GSA schedules, which we present below in Exhibit 3-14; however, those data have
important limitations. The evaluation team also tried to obtain building and construction product data directly from selected federal agencies,
but could not obtain these data. Further details are provided in the methodology chapter.
74 $91 million out of $875 million. The total is based on sales for 25 companies: Five furniture companies sell to the federal government through other
contractors on Schedule 71.
75 $3.7 million out of $24.2 million. The total is based on sales for nine companies: While two other companies that sell NSF 140 certified carpet were
listed in the GSA Schedule database, sales data for these companies was not available for FFY 2011.
3-18
-------
In addition to collecting sales data, lEc conducted telephone interviews with all but one participating
manufacturer (one furniture manufacturer provided data, but declined to participate in an interview). The
discussions covered their reasons for selling certified products to the federal government, other "green"
product standards used, changes in their production process and/or marketing, and trends in demand
among federal and non-federal purchasers. We present this qualitative information as well as the sales
data in the following sections.
Furniture
The four furniture manufacturers report selling $67.2 million of furniture (certified and uncertified) to the
federal government in CY 2011.76 Of these four companies, one began selling BIFMA e3/Level certified
furniture in 2010, two began in 2011, and the fourth began in 2012. Exhibit 3-12 shows total federal sales,
BIFMA e3/Level certified sales, and BIFMA e3/Level certified sales as a percent of the total for the four
furniture companies. As shown in the exhibit, the portion of BIFMA e3/Level certified sales among these
four manufacturers rose from zero in 2009 to more than a quarter (26%) in 2011.
EXHIBIT 3-12. BIFMA E3/LEVEL FEDERAL FURNITURE SALES FOR FOUR MANUFACTURERS
FURNITURE SALES ($ VALUE)
Federal Sales1
BIFMA e3 /Level Certified2
BIFMA e3 /Level Certified % of Total
CALENDAR YEAR (JANUARY 1 - DECEMBER 31)
2007
16,641,812
-
-
2008
22,344,747
-
-
2009
23,847,503
-
-
2010
69,188,135
10,695,432
15%
2011
67,211,863
17,559,767
26%
1 2007-2009 federal sales figures are based on data for three companies; 2010-2011 federal sales are based on
four companies. The four companies account for approximately 10% of total sales of furniture manufacturers
that sell BIFMA e3/Level certified products to the federal government. Therefore, the information in this table
is anecdotal and may not be representative of all companies selling BIFMAe3/Level certified furniture to the
federal government.
2 Sales of BIFMA e3/Level certified products in 2010 are based on data for one company; sales for 201 1 are
based on three companies. The fourth company in our analysis achieved BIFMA e3/Level certification in 2012.
Exhibit 3-13 provides information on other green federal sales for two of the four participating furniture
manufacturers (the other two companies did not fill in the table). Other (non-BIFMA e3/Level) green
certification, such as GreenGuard, accounted for 25% of sales, on average, between 2007 and 2011.
Products that manufacturers considered green or low VOC, but without a green label, accounted for less
than 1% of federal sales. With the introduction of BIFMA e3/Level sales in 2011 (5%), the portion of
"other green certification" and green or low VOC (but not certified) both increased, while the percentage
of sales with no green standard certification declined. This suggests that BIFMA e3/Level certification
76 The GSA Sales Query (https://ssq.gsa.gov/) indicates that the four participating furniture manufacturers sold $91 million of products through
Schedule 71 in FFY 2011. Federal sales data that the companies provided directly to lEc shows total sales of $67.2 million in CY 2011. The reason
for the discrepancy is unclear: this may be partly due to the difference in timing (FFY vs. CY), and partly due to which sales manufacturers
included when they provided data (for example, it is possible that manufacturers provided a subset of their total sales through GSA Schedule 71).
3-19
-------
expanded the companies' green product offering, but did not displace existing green certifications or
practices.
EXHIBIT 3-13. OTHER GREEN FEDERAL SALES FOR TWO MANUFACTURERS
FURNITURE SALES ($ VALUE)
Sales to Federal Government1
No Green Standard Certification
% Total
BIFMA e3 /Level Certified2
% Total
Other Green Certification, not BIFMA
e3 /Level
% Total
Green or Low VOC, but not certified
to any green third-party standard
% Total
Discrepancy
CALENDAR YEAR (JANUARY 1 - DECEMBER 31)
2007
12,422,877
8,681,131
69.9%
-
-
3,685,827
29.7%
55,919
0.5%
-
2008
16,634,129
12,522,876
75.3%
-
-
4,060,620
24.4%
50,631
0.3%
2
2009
18,060,063
14,243,531
78.9%
-
-
3,777,174
20.9%
39,358
0.2%
-
2010
22,603,389
17,822,484
78.8%
-
-
4,739,546
21 .0%
32,359
0.1%
9,000
2011
16,807,625
11,748,261
69.9%
848,41 8
5.0%
4,172,938
24.8%
38,008
0.2%
-
1 Based on data for two companies. A third company noted that 50% of its casegoods were Greenguard
certified in 2006, and 100% of its seating was Greenguard certified in 2008; however, the company did not
break out sales by product category. The fourth company provided BIFMA e3/Level and non-Level sales, but
did not further break out non- Level sales.
2 One company represented in this table achieved BIFMA e3/Level certification in 2011, the other in 2012.
The sales data are consistent with qualitative information provided by the manufacturers. As noted above,
lEc held telephone conversations with three of the four furniture companies about their reasons for selling
certified products to the federal government, changes in their production process, changes in marketing
practices, and demand for certified products. All three companies stated that BIFMA e3/Level was a
credible standard that was necessary to help counter "green washing" in the furniture industry. All three
companies offered other green certified furniture prior to BIFMA e3/Level, although one company had to
change its manufacturing process to attain BIFMA e3/Level certification. All three companies
interviewed mention BIFMA e3/Level in their marketing, although the standard does not appear to be a
key element of their marketing strategy. The manufacturers anticipate growth in federal demand for the
standard; they also noted the importance of federal leadership to stimulate demand among non-federal
purchasers.
The furniture manufacturers offered the following observations:
• One furniture manufacturer who achieved BIFMA e3/Level certification in 2011 did so because it
saw the need for a credible standard that would help eliminate "green washing" in the furniture
industry. After just one year, BIFMA e3/Level certified products account for approximately 85% of
this company's total federal sales. Prior to BIFMA e3/Level, the company was selling GreenGuard
3-20
-------
certified products (since 2006); currently most of their products are GreenGuard certified, and there is
overlap between products certified to both BIFMA eS/Level and GreenGuard. However, attaining
BIFMA e3/Level certification required additional changes to the company's manufacturing process.
Specifically, the company changed its upholstery and finishing processes to reduce formaldehyde,
VOC, and HAPS, and also changed its adhesive structures. In addition, the company created "work
cell environments" to separate out recyclables for distribution to recycling centers. The company has
not changed its marketing practices, other than stating that it offers BIFMA e3/Level certified
furniture. The company reports that one in five federal clients requests various BIFMA/ANSI tests
(e.g., furniture emissions testing), but clients have not requested information on what level the
furniture is certified to at this time.
• Another furniture manufacturer echoed the sentiment that BIFMA e3/Level would help counter
"green washing" in the furniture industry; this company participated in the process of creating the
standard, and adopted BIFMA e3/Level for all of its furniture products in 2011. Prior to BIFMA
e3/Level, 50% of the company's case goods were GreenGuard certified in 2006, and 100% of its
seating was GreenGuard certified in 2008; in addition, the company has Forest Stewardship Council
(FSC) Chain of Custody (CoC) certification. Achieving BIFMA e3/Level certification did not require
changes to the company's manufacturing processes, but may require changes in the future as the
company moves towards a higher level of certification. The company mentions its green certifications
in its marketing materials, but BIFMA e3/Level certification has not changed how the company goes
to market. The company reported increasing demand among federal customers, and expects this
demand will "trickle down" to state, local and private customers, although this has not happened yet.
The company noted that if BIFMA e3/Level certification is incorporated into LEED, this would be an
important consideration for more customers.
• A third furniture company received BIFMA e3/Level certification in 2012; a "strong push" from the
federal government was a major factor in the company's decision to obtain BIFMA e3/Level
certification. While the federal government did not specify BIFMA e3/Level certification, there was a
strong sense that the industry needed to enhance its sustainability credentials, and the company
identified BIFMA e3/Level as the best standard on the market. The company attained certification in
February 2012, and expects all of its sales for 2012 will be BIFMA e3/Level certified. Prior to
BIFMA e3/Level, the company was one of the first to obtain FSC CoC certification, and has had
GreenGuard certification, for more than five years. Achieving BIFMA e3/Level certification did not
require changes in the company's manufacturing processes. However, the company updated its
marketing materials to promote its use of the BIFMA e3/Level standard. The company reports that
demand among federal customers is increasing very quickly, as the standard is becoming more of a
widespread requirement. Some federal departments (including the Department of Homeland Security
and the U.S. Navy) are already requiring the standard. State and local demand is not as strong, but the
company expects it will follow federal demand; in particular, since many state contracts are
predicated on GSA, if GSA integrates BIFMA e3/Level certification into purchasing schedules, states
will follow. Similarly, there is growing demand from the private sector, but not as strong.
Carpet
We collected two sources of purchasing data for environmentally preferable carpet: federal sales data
through GSA Schedule 72 and "mini-market" sales data from one carpet manufacturer.
3-21
-------
• GSA Schedule Data. GSA Multiple Award Schedules are long-term, government-wide contracts
with commercial firms that provide access to a wide range of commercial products and services at
volume discount prices. The contracts are managed by GSA. Four GSA Schedules offer the building
and construction products covered by the evaluation: Schedule 71 (Furniture), 72 (Furnishings and
Floor Coverings), 51V (Hardware Superstore), and 56 (Buildings and Building Materials, Industrial
Services and Supplies). GSA provided purchasing data for all of the requested schedules except
Schedule 71 (Furniture). The Schedule data show annual federal purchases through each Schedule,
broken out by Special Item Number (SIN). Specific SINs require contractors to provide
environmentally preferable products.
Since January 2011, carpet sold through SINs 31-301 and 31-303 (Schedule 72) is required to be NSF
140 certified at the gold level.77 Prior to January 2011, NSF 140 carpet was preferred but not
required. GSA maintains data on sales that went through "green mandate" SINs (e.g., 31-301 and 31-
303). Exhibit 3-14 shows total Schedule 72 spending, as well as the volume and percentage of
spending that went through "green" SINs (i.e., 31-301 and 31-303) for FY07 through FY10. As
shown in the exhibit, GSA recorded approximately $23 million in annual sales through the "green"
SINs, out of a total of approximately $63 million in annual sales through Schedule 72. The percent of
"green" sales (37%) remained roughly constant from FY07 through FY10.
EXHIBIT 3-14. GREEN SPEND THROUGH GSA SCHEDULE 72 - FURNISHINGS AND FLOOR COVERINGS
FY07
• GREEN SINS
FY08 FY09
^H TOTAL SCHED 72 •
FY10
GREEN %
Although these data can provide some sense of the magnitude of environmentally preferable carpet
sales to the government, the Schedule 72 data have a number of limitations. First, Schedule 72 sells
products other than carpet; hence, the share of green carpet (as opposed to other furnishings and floor
coverings) sold through Schedule 72 is likely to be much higher than the percentage shown in the
exhibit. Second, federal agencies can still buy non-environmentally preferable carpet through
77 We are using the data for carpet sales because we were able to interpret and validate the data by speaking directly with the GSA Schedule
contact for carpet (Schedule 72). lEc was not able to arrange calls with the other GSA Schedule managers.
3-22
-------
Schedule 72 if they buy from a small business SIN, or if they are buying specialty carpet (again
through a separate SIN). Third, manufacturers on other (non-"green mandate") SINs may opt to sell
environmentally preferable products on a voluntary basis, but we do not know the relative mix of
environmentally preferable versus non-environmentally preferable sales through those SINs. Finally,
the GSA Schedules do not account for all sales to the federal government; federal agencies can
purchase building and construction products outside of the GSA Schedules.
• Mini-market data. We supplemented the GSA Schedule data with the mini-market analysis. As
noted above, we received sales data from one carpet manufacturer out of 11 contacted; this
manufacturer accounts for approximately 15% of total carpet sales of manufacturers that sell NSF 140
certified carpet products to the federal government, and may not be representative of the industry as a
whole. However, this manufacturer has annual U.S. carpet sales of approximately $350 million. As
shown in Exhibit 3-15, since FY 2008 the company's annual sales to the federal government have
fluctuated between $3.6 million and $6.9 million. Since 2006, 100% of this company's carpet sales to
the federal government are certified to the Carpet and Rug Institute's Green Label Plus. Since 2007,
all federal sales are also NSF 140 certified at the platinum or gold level, depending on the backing
used.
EXHIBIT 3-15. FEDERAL CARPET SALES FOR ONE CARPET MANUFACTURER
CARPET SALES ($)
Sales to Federal Government
FEDERAL FISCAL YEAR (OCTOBER 1 - SEPTEMBER 30) ALL CARPET IS
NSF 140 CERTIFIED AND GREENLABEL PLUS CERTIFIED
2008
5,894,549
2009
6,968,203
2010
4,928,544
2011
3,696,834
According to a company spokesperson, the company did not adopt any major changes to its
production process to achieve NSF 140 certification. In general, the most challenging aspect of
becoming NSF 140 compliant is the requirement for 10% post-consumer recycled content, which the
company offers in its platinum certified product line. The spokesperson stated that many
manufacturers had to create a special product offering to meet this requirement.
According to this manufacturer, marketing the standard has been challenging, and this responsibility
has largely fallen to the manufacturers. Many buyers still are not aware of NSF 140. Of those who are
aware, many buyers are seeking information on the specific credits that carpet manufacturers earned
to get NSF 140 certification (manufacturers can obtain certification in different ways), and they are
confused by the variety of standards and labels in the market. Nonetheless, this manufacturer supports
the standard.
QUESTION 4: LEADING BY EXAMPLE
Introduction
As the organizational home of the EPP Program and the federal agency charged with environmental
protection, EPA's performance regarding environmentally preferable purchasing is of particular interest.
3-23
-------
In several areas of environmental stewardship, EPA has strived to publicly demonstrate a good example
for other federal agencies and non-federal institutions; for example, EPA has publicized efforts to green
its own facilities and purchase electricity from renewable sources. With this context as a backdrop,
Evaluation Question 4 asks, "Is EPA leading by example in terms of purchasing behavior for green
products and services?"
To answer this question, ideally, lEc would compare quantitative purchasing data for EPA and the rest of
the federal government, examining relative rates of environmentally preferable and conventional
purchases. However, such data is not available, for either the federal government as a whole (excluding
the EPEAT data discussed in Evaluation Question 3) or for EPA. In the absence of such purchasing data,
we have gathered information on attitudes and behaviors regarding EPP purchasing from a variety of
sources, including the survey of federal purchasers and interviews with EPA staff. We also examined data
from the Federal Electronics Challenge (FEC), to compare EPA facilities to other facilities participating
in the FEC program.
Key Findings
• EPA does not track its proportion of environmentally preferable versus conventional purchases. This
seriously hinders the ability to evaluate EPA's performance compared to other agencies. Reliable
purchasing data is a critical need for any future efforts to evaluate EPA's performance in this area.
• Survey data are somewhat mixed, but on the balance, indicate that EPA purchasers buy more
environmentally preferable products and services than non-EPA purchasers. This appears to be due to
a small group of EPA purchasers, rather than a widespread Agency-wide effect.
• While we have limited interview data, our interviews indicate that EPA has taken some steps to green
its own purchasing, and is using purchasing tools to promote procurement of environmentally
preferable electronics, building and construction products, and office supplies.
• Many EPP staff view leading by example as a secondary concern for the program compared to efforts
to develop standards and other resources that could have a broader impact on the market.
• EPA offices participate in the FEC at rates well above the federal government as a whole. EPA FEC
partners' performance is also well above other FEC partners with respect to EPEAT purchases and
enabling rates of Energy Star power management settings.
Survey Evidence of Leading By Example
In lEc's survey of federal purchasers, we compared the responses of EPA and non-EPA purchasers on
several key questions addressing environmentally preferable purchasing behavior. We also compared
EPA purchasers to purchasers from a handful of other specific agencies on certain key questions.
81% of EPA purchasers indicated that their agency or department had an environmentally preferable
purchasing policy, compared to 60% of all purchasers. Similar numbers indicated that their agency or
department gave some kind of preference to environmentally preferable products (82% and 62%). Thus,
in terms of agency policy, EPA appears to be promoting environmentally preferable products more than
other agencies. Of course, this does not necessarily mean that EPA purchasers actually buy
environmentally preferable products or services at higher rates. Thus, we compared EPA and non-EPA
purchasers' responses to survey questions on individual purchasing behavior. Two particularly important
questions were:
3-24
-------
• "In the past year, have you made at least one purchase where you considered environmental factors in
your purchasing decision?"
• "In the past year, approximately what percentage (expenditures) of the products/services that you
purchased was environmentally preferable?"
On the first question, we found no difference between EPA purchasers and non-EPA purchasers; 62.3%
of EPA purchasers and 62.4% of non-EPA purchasers chose "yes" (Exhibit 3-16). EPA lagged well
behind GSA on this question, and was somewhat behind USDA as well.
EXHIBIT 3-16. PURCHASERS CONSIDERING ENVIRONMENTAL FACTORS AT LEAST ONCE IN THE
PAST YEAR
AGENCY
All
GSA
USDA
Department of Energy
EPA
Department of Homeland Security
RESPONSES
2539
194
413
25
191
317
% CONSIDERING
ENVIRONMENTAL FACTORS
62.4%
78.4%
68.3%
64.0%
62.3%
54.3%
On the second question, EPA purchasers exhibited more environmentally preferable purchases than non-
EPA purchasers to a statistically significant degree (Exhibit 3-17). We used a chi-square test for this
analysis, which compares observed results to the results that would be expected if there was no difference
between the two groups. This analysis provides perhaps the clearest evidence of EPA leading by example.
However, the results appear to be driven by a relatively small group of purchasers. Specifically, if there
was no different between the groups, we would expect 14 EPA purchasers for whom 75% or more of their
purchases were environmentally preferable. In fact, 23 EPA purchasers indicated this high rate of EPP
purchases, a difference of just nine individuals. Thus, while the difference is statistically significant, only
a small number of EPA purchasers exhibit any meaningful divergence in behavior from the rest of the
federal procurement workforce. The results of the question discussed above, showing that an identical
proportion of EPA and non-EPA purchasers considered environmental factors at least once in the past
year, lends further support for this interpretation. Note, in addition, that GSA purchasers indicated higher
rates of environmentally preferable purchasing activity than EPA purchasers on this question.
We also compared EPA and non-EPA purchasers' responses to several other questions, in which we did
not find any statistically significant differences. These include rates of environmentally preferable
purchases for electronics and building and construction products specifically, and changes in
environmentally preferable purchasing levels over the past three years. However, with respect to
purchases in the individual product categories, the lack of a significant difference appears to be due to a
low sample size - there were just 24 EPA electronics purchasers and 14 EPA building product purchasers
- and a high number of EPA respondents choosing "don't know." Furthermore, the fact that EPA
purchasers do not appear to be increasing their levels of EPP purchases over time more than non-EPA
3-25
-------
purchasers could simply indicate that EPA purchasers were already buying EPP products at relatively
high rates three years ago and have plateaued since that time, while other agencies are now catching up.
For these reasons, we maintain that the most appropriate conclusion of the survey data is that EPA
purchasers are buying environmentally preferable products at somewhat higher rates than non-EPA
purchasers, due to the influence of a small number of highly committed purchasers.
EXHIBIT 3-17. ENVIRONMENTALLY PREFERABLE PURCHASING OF EPA VS. NON-EPA PURCHASERS:
CHI-SQUARE TEST
PERCENTAGE OF
ENVIRONMENTALLY
PREFERABLE PURCHASED
PRODUCTS/SERVICES
Less than 25%
25-50%
51-75%
More than 75%
Don't know
Total
EPA PURCHASERS
OBSERVED
65
36
15
23
52
191
Chi-square = 9.760; P value = 0.045
EXPECTED
65
33
19
14
61
%
DIFFERENCE
1%
11%
-22%
68%
-15%
NON-EPA PURCHASERS
OBSERVED
739
369
224
147
706
2,185
EXPECTED
739
372
220
156
697
%
DIFFERENCE
0%
-1%
2%
-6%
1%
Interview Evidence of Leading By Example
We interviewed one staff person from the Office of Administration and Resources Management (OARM),
the office with primary responsibility for EPA's procurement activities, to discuss EPA's efforts to
purchase green products and services. We also interviewed five members of EPP Headquarters staff, plus
three other EPA staff members in closely related positions, but these interviews were not focused on the
issue of EPA leading by example. Thus, we have a limited basis for our interview-related findings on the
leading by example question.
The OARM interviewee stated that they had seen a definite increase in environmentally preferable
purchasing awareness and behavior in EPA in recent years. The interviewee credited this mainly to
OARM's behind-the-scenes efforts to facilitate purchasers choosing sustainable options; they viewed
these activities as complementary to the EPP Program's efforts to encourage green purchases. However,
without quantitative purchasing data, we cannot confirm the interviewee's assertion that EPA's
environmentally preferable purchasing has been increasing.
The interviewee reported that EPA makes use of several green purchasing tools, which could promote
higher levels of environmentally preferable purchasing. One of these is a Blanket Purchase Agreement
(BPA) for electronics, described as a "mandatory first option" for all electronics purchases; all of the
computers and monitors included in this BPA are EPEAT certified. Thus, we would expect that a high
percentage of EPA's total electronics purchases are EPEAT certified, and indeed, FEC data on EPA's
EPEAT purchases, discussed below, support this contention.
3-26
-------
Other important green purchasing tools that EPA uses include:
• The Federal Green Construction Guide for Specifiers, an important output of the EPP Program, which
has been used to guide purchases of building and construction products for some EPA buildings;
• GSA's Sustainable Facilities Tool (SFTool), which offers a wide variety of resources and guidance on
building and construction products; and
• A BPA on office supplies, developed in 2003 with significant assistance from the EPP Program (see
sidebar).
EPA's use of these tools for its operations
indicates that EPA is taking at least some steps
to green its own procurement.
Our interviews revealed that EPP staff are
divided on whether leading by example is an
important part of the EPP Program's mission.
Most felt that it was not, stating that EPP had
evolved away from earlier efforts where
procurement leadership was more important;
these staff felt that EPP's resources were
better spent working on developing voluntary
consensus standards and other tools with the
potential to influence the market more
broadly. Several EPP staff also suggested that
while leading by example is important, it is
more appropriate to see this as a role for the
entire federal government, setting a good
example for other institutional buyers such as
businesses and state governments. However, a
minority of EPP staff indicated that they
would like to see greater procurement
leadership from EPA. They indicated that EPP
needs to improve coordination with OARM to
promote environmentally preferable
purchasing within the Agency and verify that
OARM's green purchasing policies are
actually being followed.
OFFICE SUPPLY BPA
This evaluation has not focused on the office supply
product sector because it is not a current area of focus
for the EPP Program. However, the EPP Program
performed extensive work in this area in prior years. In
2003, EPA undertook a major effort to develop a Blanket
Purchase Agreement (BPA) for office supplies. EPP and
OARM were both involved in this endeavor.
The BPA changed EPA purchasers' experience of
purchasing office supplies. EPA awarded a single-source
BPA, meaning they had only one supplier for all of their
office supplies. EPA created incentives for the supplier
to increase the number of environmentally preferable
products offered, by offering an extension on the sole-
source BPA in exchange for an increase in the number of
environmentally preferable products. In response to the
BPA, EPA's supplier created a new special section of the
office supply catalog exclusively featuring green
products. The supplier also created a green icon to
identify sustainable products when they were listed
elsewhere in the catalog.
Other government stakeholders have recognized the BPA
as a major success. GSA used similar criteria in its
Federal Strategic Sourcing Initiative, and the White
House recognized EPA with a prestigious 'Closing the
Circle' award. Part of the reason the EPP Program is not
currently focused on office supplies may be that its past
success has reduced the need for further efforts.
EPA Participation in FEC
The Federal Electronics Challenge (FEC) is a voluntary partnership program for federal facilities and
agencies that promotes sustainable electronics purchasing and use. Two evaluation questions (8 and 9) are
devoted to analyzing the FEC program's performance; we provide more detail on program structure and
activities there. In this section, we focus on EPA's participation in the FEC and how the Agency's
performance compares to other FEC partners. Our primary data source for this analysis is facility-specific
performance information provided by FEC. We evaluate four metrics:
3-27
-------
• Participation rate;
• Purchase rates of EPEAT vs. non-EPEAT electronics;
• Enabling of Energy Star power management features during equipment use; and
• Disposal of electronics products at end of life.
As of 2010, 16 EPA program offices and all 10 Regional offices were FEC partners, representing most if
not all of the Agency. EPA offices accounted for 15% of all FEC partners from 2008 - 2010. According
to the FEC program manager, FEC covers approximately 20% of all federal employees;78 all else being
equal, we would assume that the program would cover a similar proportion of federal facilities. This
would imply that if FEC participation were distributed evenly among all federal agencies, about 20% of
the facilities or program offices in any given agency would be FEC partners. Using this metric, EPA has a
very high participation rate compared to the rest of the federal government.
EPA partners have also demonstrated leadership in several of the performance areas FEC tracks. Perhaps
most important for our purposes is the proportion of EPEAT vs. non-EPEAT purchases. In every year
from 2008 - 2010, EPA partners purchased EPEAT products for over 99% of their computers and
monitors (Exhibit 3-18). While the FEC as a whole also had impressive levels of EPEAT purchases, their
results were well below the EPA figures. The margin by which EPA partners out-performed the FEC as a
whole ranged from 3% in 2009 to 12% in 2008.
FEC also promotes and tracks enabling of Energy Star power management features. Again, EPA partners'
performance is strong compared to other FEC partners in this area (Exhibit 3-19). With the exception of
monitors in 2008, EPA partners enabled Energy Star settings at higher rates than non-EPA partners in
every year from 2008 - 2010 for both monitors and computers. While the differences were relatively
modest for monitors, EPA partners had substantially higher enabling rates for computers; average
enabling rates were 46.7% for all FEC partners compared to 93.3% for EPA partners. EPA partners
reached 100% Energy Star enabling for both monitors and computers in 2010.
EPA partners' performance is less impressive in end-of-life disposal. Combining recycling and reuse for the
sake of simplicity, we see that EPA partners chose these disposal options at slightly higher rates than other
FEC partners in 2008, with a more pronounced difference in 2009 (Exhibit 3-20). EPA partners sent very
few electronics products to landfills or incinerators in those years. However, results for 2010 are
dramatically different. In that year, EPA partners disposed of roughly 20% of their electronics through
landfill or incineration, compared to about 5% for the FEC as a whole. EPA partners' rate of reuse and
recycling dropped correspondingly. It is important to note that all of the reported EPA landfill/incineration
in 2010 came from one office, OARM; additional follow-up may be required to verify this data point given
that it is an outlier.
8 This metric excludes postal employees.
3-28
-------
EXHIBIT 3-18. EPEAT AND NON-EPEAT PURCHASES, EPA VS. ALL FEC PARTNERS
100%
TO
80%
fcf 60%
Q_
& 40%
20%
Q_
LJJ
sp
0%
2008
2009
2010
AIIFEC
partners
3-29
-------
EXHIBIT 3-19. ENERGY STAR ENABLING, EPA VS. ALL FEC PARTNERS
All FEC partners*
EPA partners only
EPA margin
MONITORS
2008
94.5%
92.0%
-2.5%
2009
95.7%
98.3%
2.6%
2010
87.3%
100.0%
12.7%
COMPUTERS
2008
36.4%
87.6%
51 .2%
2009
50.6%
92.2%
41.6%
2010
53.1%
100.0%
46.9%
* Excluding anomalous data points.
100%
0%
2008
All FEC - monitors
•All FEC - computers
2009
2010
•EPA partners - monitors
•EPA partners - computers
3-30
-------
EXHIBIT 3-20. END-OF-LIFE DISPOSITION, EPA VS. ALL FEC PARTNERS
MONITORS
2008
2009
2010
COMPUTERS
2008
2009
2010
% Reused
All FEC partners
EPA partners only
EPA margin
53.4%
43.7%
-9.7%
37.7%
61.6%
23.9%
39.3%
63.8%
24.5%
48.3%
41.8%
-6.5%
46.4%
61.6%
15.2%
42.3%
58.6%
16.3%
% Recycled
All FEC partners
EPA partners only
EPA margin
36.7%
48.0%
11.3%
42.7%
34.0%
-8.7%
47.3%
13.4%
-33.9%
41 .4%
44.1%
2.7%
37.0%
36.6%
-0.4%
47.4%
18.8%
-28.6%
% Unknown Disposition/Sales
All FEC partners
EPA partners only
EPA margin
8.3%
8.2%
-0.1%
21 .9%
3.2%
-18.7%
4.8%
1.1%
-3.7%
9.2%
13.9%
4.7%
18.0%
1 .3%
-16.7%
4.0%
2.4%
-1.6%
% Sent to Landfill/ Incinerator
All FEC partners
EPA partners only
EPA margin
2.2%
0.1%
-2.1%
1.7%
0.0%
-1.7%
5.6%
21.3%
15.7%
1.8%
0.1%
-1.7%
1.3%
0.0%
-1.3%
4.0%
19.1%
15.1%
100% of EPA computers and monitors sent to landfill/incinerator in 2010 are from OARM.
o
c
LLJ
4->
TO
"ro
to
O
Q.
100%
80%
60%
40%
20%
2008
•All FEC - reuse/recycling
•All FEC-landfill
2009
2010
•EPA partners - reuse/recycling
•EPA partners - landfill
3-31
-------
QUESTION 5: ENVIRONMENTAL BENEFITS OF FEDERAL GREEN PURCHASES
Introduction
In this section, we explore the environmental impacts of federal green purchases. Specifically, Evaluation
Question 5 asks, "What are the outcomes of federal green purchases in terms of reduced energy use and
associated greenhouse gas emissions, reduced water use, and reduced use of hazardous materials?" As
noted in our discussion of Evaluation Question 3, lEc was able to find comprehensive federal green
purchasing data only for the electronics sector. The electronics sector was also the sector for which we
identified a reliable means to translate green purchases into quantified environmental benefits. As a result,
our analysis of environmental benefits focuses on the electronics sector exclusively, and specifically
purchases of EPEAT certified computers and monitors.
Key Findings
• The environmental benefits of federal EPEAT purchases are substantial. In 2010, the benefits of
federal EPEAT purchases were roughly equivalent to eliminating: the annual electricity consumption
of 25,000 average U.S. homes; the greenhouse gas emissions of 40,000 U.S. cars for one year; and the
solid waste generation of 252 U.S. households for one year.79
• There is substantial year-to-year variability in the benefits of federal EPEAT purchases. These
fluctuations are driven by the number of products purchased, the type of products purchased
(especially laptops versus desktops), and assumptions on the per-unit environmental benefits of each
product type.
• Because of the nature of the assumptions used to calculate environmental benefits, these estimates
should be viewed as approximations rather than precise measurements.
• Due to a lack of purchasing data and tools to quantify benefits, estimates of the environmental
benefits of federal purchases are not available for the building and construction products or travel and
hospitality sectors.
Calculation of Environmental Benefits of Federal EPEAT Purchases
The Green Electronics Council (GEC), which manages the EPEAT program, produces publicly-available
Environmental Benefits Reports on an annual basis. These reports summarize the market impact of the
EPEAT program, describing the combined sales of all EPEAT products by all participating manufacturers
in the U.S. and much of the rest of the world.
The Environmental Benefits Reports also detail the environmental benefits associated with EPEAT sales.
GEC uses the Electronics Environmental Benefits Calculator, or EEBC, to estimate these environmental
benefits, by comparing the energy, water, and other impacts of EPEAT certified electronics products to
those of conventional units. The EEBC was initially developed by Abt Associates under EPA contract.
The calculator was peer-reviewed when it was initially developed, and based on conversations with EPP
staff and a limited review by lEc, it appears to be a reasonably robust method of estimating environmental
79 As discussed below, environmental benefits were calculated based on data from GEC's EPEAT Environmental Benefits Reports. Equivalencies are
also adapted from these reports.
3-32
-------
benefits. For that reason, lEc has opted to use GEC's reported benefits for the EPEAT program as a
whole, which rely on the EEBC, as a basis for estimating the benefits stemming from federal government
or\
purchases of EPEAT electronics. We report benefits only for 2008-2010, because we do not have
o 1
EPEAT purchasing data beyond this timeframe.
The EEBC is based on a series of assumptions characterizing both the average EPEAT product at each
registry level (bronze, silver, and gold) and the average non-EPEAT product. It calculates benefits by
comparing the estimated impacts of the purchased EPEAT product to the impacts of a default non-
EPEAT product. While the EEBC's assumptions appear to be reasonable, other, equally plausible
assumptions exist that would result in significantly different estimates of environmental benefits. We
discuss this issue in greater detail below.
Data on federal purchases of EPEAT products is included in our analysis of Evaluation Question 3.
Unfortunately, these data do not include detail on the number of products purchased at each level of
EPEAT certification (bronze, silver, or gold). For that reason, it would not provide any methodological
advantage to enter the total federal purchase numbers into the EEBC to calculate environmental benefits
directly (since benefits vary with certification level). Instead, we simply multiply GEC's reported total
environmental benefits from worldwide EPEAT sales in any given year (which does account for
differences in EPEAT certification levels) by the federal government's share of worldwide EPEAT
sales. We use worldwide rather than U.S. sales data because GEC reports benefits for each individual
product category (laptops, desktops, monitors, and integrated systems) on a worldwide basis, but not for
the U.S. alone.
Because we use the federal government's share of worldwide total sales as the basis for estimating its
share of EPEAT's environmental benefits, our methodology implicitly assumes that the federal
government's EPEAT purchases reflect the same proportional split between bronze, silver, and gold
products as does the market as a whole. If the federal government actually purchases gold-level products
in higher proportions than the market average, this approach would understate the government's
environmental benefits slightly; conversely, if the government's purchases are more heavily weighted
toward bronze products, we may overstate the government's benefits. Note, however, that any uncertainty
in this regard would make an appreciable difference only with respect to energy and municipal solid
waste-related benefits. For all other environmental impacts, there is less than a 10% difference in benefits
between bronze and gold EPEAT certified products in the most recent version of the EEBC (and in most
cases, the difference is less than 3%).
In undertaking this analysis, lEc uncovered some evident errors in the benefits reported by GEC for specific product categories (though not, as far
as we are aware, for total benefits across all product categories). These errors were evident because the reported total benefits for each category
did not sum correctly to produce the reported totals across categories; inconsistencies in year-by-year trends and in equivalencies (e.g.,
translating kilowatt-hours of electricity saved into an equivalent number of U.S. homes' annual electricity demand) provided further evidence of
the errors. lEc therefore corrected the apparent errors before calculating the federal government's share of EPEAT benefits. Specific errors
corrected by lEc include the following: 1) 2009 electricity benefits from desktops were overstated by a factor of 10; 2) 2009 air emission benefits
from desktops were overstated by a factor of 1,000; 3) toxic material benefits from desktops mistakenly repeated the same figure reported for
laptops; and 4) 2010 electricity benefits from laptops were overstated by a factor of 10.
81 Data for 2011 was released after we had completed our analysis.
82 EPEAT calculated environmental benefits based on specific certification levels in 2009 and 2010, but not in 2008.
3-33
-------
Exhibit 3-21 presents information on the federal government's share of U.S. EPEAT purchases. The
overall impacts of EPEAT, beyond the federal government, are discussed under findings for Evaluation
Question 10.
EXHIBIT 3-21. FEDERAL GOVERNMENT SHARE OF WORLDWIDE EPEAT PURCHASES
PRODUCT TYPE
Desktops
Monitors
Laptops
Integrated
Systems
Total
2008
FEDERAL
GOVT.
EPEAT
PURCHASES
577,260
181,141
213,275
0
971,676
FEDERAL
GOVT. SHARE
OF
WORLDWIDE
PURCHASES
2.96%
0.47%
0.67%
0.0%
1 .07%
2009 1
FEDERAL
GOVT. EPEAT
PURCHASES
1,156,682
1,134,811
644,564
4
2,936,061
FEDERAL
GOVT. SHARE
OF
WORLDWIDE
PURCHASES
14.63%
3.71%
1.60%
0.0%
3.65%
2010
FEDERAL
GOVT.
EPEAT
PURCHASES
515,184
N/A
561,852
111,187
N/A
FEDERAL
GOVT.
SHARE OF
WORLDWIDE
PURCHASES
6.42%
N/A
0.91%
3.15%
N/A
1 EPEAT implemented a country-specific registry protocol in 2009. One result of this change is that reported total
sales for 2009 and 2010 exclude EPEAT sales in all countries other than the 40 represented in the registry; these
other countries had previously been included in worldwide sales totals. This change is likely responsible for the
reported decrease in EPEAT products from 2008 to 2009, and the concomitant increase in the U.S. federal
government's share of the worldwide market. Because reported worldwide environmental benefits dropped along
with purchases, this change should not affect this portion of our analysis.
Environmental benefits associated with federal EPEAT purchases are shown in Exhibit 3-22. Although
OQ QA
we calculate the federal government's benefits for each product category separately, ' for ease of
presentation we show only the aggregated figures across all product categories.
To put these in perspective, the federal government's estimated environmental benefits in 2010 are
85
roughly equivalent to the following:
• The annual electricity consumption of 25,000 average U.S. homes
• The greenhouse gas emissions of 40,000 U.S. cars for one year
• The solid waste generation of 252 U.S. households for one year
Across all categories, the federal government's environmental benefits increased dramatically between
2008 and 2009 before dropping back in 2010. This is driven by the year-by-year trends in purchasing
noted in our analysis of Evaluation Question 3; we believe (but cannot be sure) that the drop in EPEAT
83 EPEAT reports benefits by product category for 2009 and 2010, but not for 2008. As a result, we use the federal government's total market share
of all products (1.07%) divided by worldwide benefits for all products in 2008.
84 EPEAT counts integrated systems as laptops for purposes of calculating benefits. We account for this by using the weighted average of the federal
government's market share of laptops and integrated systems to determine its share of worldwide environmental benefits for those categories.
85 Equivalencies are adapted from GEC's 2009 and 2010 EPEAT Annual Benefits Reports.
3-34
-------
purchasing mirrors a drop in overall governmental computer purchasing. We reiterate that, due to
abnormalities in the underlying data, we do not include an estimate of federal monitor purchases in 2010;
environmental benefits would be higher in that year if monitors were included.
EXHIBIT 3-22. ENVIRONMENTAL BENEFITS FROM FEDERAL GOVERNMENT EPEAT PURCHASES
BENEFIT CATEGORY
Electricity
Primary Materials
Air Emissions (including greenhouse gases)
Greenhouse Gas Emissions
Water Emissions
Toxic Materials
Solid Waste
Hazardous Waste
UNIT
Megawatt-hours
Metric tons
Metric tons
Metric tons carbon
equivalent
Metric tons
Metric tons
Metric tons
Metric tons
YEAR
2008
203,175
359,004
829,300
38,140
1,737
24
328
987
2009
885,263
1,572,906
3,565,784
165,919
7,556
91
1,379
3,439
20101
293,234
525,582
1,212,922
56,081
2,548
31
503
1,308
1 2010 figures do not include any benefits from monitor purchases and thus understate actual benefits.
Impact of EEBC Assumptions on Total Environmental Benefits of EPEAT
Differences in environmental benefits between desktop and laptop computers play a large role in shaping
the year-by-year trends in the federal government's total environmental benefits. As treated by the EEBC,
EPEAT laptops deliver only a small fraction of the benefits of EPEAT desktops. Thus, as the federal
government shifts its purchasing away from desktops and toward laptops, the result will be a decrease in
total environmental benefits from EPEAT. The magnitude of this effect is determined by 1) the rate at
which purchases shift from desktops to laptops, and 2) the relative benefits accruing to each product type.
While the first of these factors is easily measured via the sales data reported above, the second factor is
more difficult to measure precisely.
Differences between desktops and laptops are present in all categories of environmental impacts, but they
are especially pronounced in energy, primary materials, greenhouse gas emissions, and air and water
emissions. This is as we would expect; by their nature, virtually all laptops use less energy and raw
material than desktops, and consequently, the absolute difference between high-performing and
o/r
conventional models should also be smaller for laptops. However, the effect of these differential
impacts is magnified by methodological choices built into the EEBC. To calculate environmental
benefits, the EEBC compares the impacts of EPEAT products to the impacts of baseline (non-EPEAT)
86 For example, under the EEBC version 2.0, a conventional desktop is estimated to use 507 kWh of electricity annually, while a conventional laptop
is estimated to use 75 kWh, a difference of 432 kWh per year. Thus, even a hypothetical laptop that used zero energy would not produce as much
incremental energy savings over a conventional laptop (75 kWh per year) as a conventional laptop saves in comparison to a desktop. The same
phenomenon is true in other impact categories as well. This highlights the fact that laptop computers do not have as much variation in
environmental performance (in absolute terms) as do desktops, and thus there will be less of a difference between high- and low-performing
units.
3-35
-------
products. In version 2 of the EEBC (released in March 2009), which is used to calculate EPEAT program
benefits in 2008 - 2010, baseline products were assumed to meet the outdated Energy Star version 3.0
specifications, while EPEAT products were required to meet the criteria for the newer Energy Star
version 4.0 or 4.1 specifications.87 Thus, the benefits accruing to each product are equivalent to the
performance improvement between the Energy Star specification versions 3.0 and 4.0 or 4.1 (for those
benefit categories where EPEAT's performance is based on Energy Star). lEc is not able to readily assess
the foundation for this assumption, but it is beyond the scope of this evaluation to propose alternatives.
The change in performance requirements from Energy Star version 3.0 to 4.0/4.1 was more dramatic for
desktop computers than for laptops, in both relative and absolute terms. Average annual energy
consumption for Energy Star desktops dropped by 27.3%, from 507 to 369 kWh (a difference of 138
kWh). In contrast, energy consumption for Energy Star laptops only decreased by 1%, from 75 to 74 kWh
Thus, after accounting for all stages of the product lifecycle, as estimated by the EEBC version 2.0,
EPEAT laptops delivered only about 1% of the benefits of EPEAT desktops for energy, primary
materials, greenhouse gases, and air and water emissions. Benefits were more comparable in the other
oo
categories. EPEAT monitors generated between 34 and 60% of the benefits of desktops. Per-unit
benefits are shown in Exhibit 3-23.
As noted above, because the federal government (and the market as a whole) is shifting from desktops to
laptops, total environmental benefits of EPEAT purchases are becoming considerably lower overtime
than they would be if the product mix held steady. Every laptop purchased instead of a desktop between
2008 and 2010 resulted in a 99% drop in potential energy, air, and water-related benefits (as measured by
the EEBC). This is not to suggest that it would be environmentally preferable for a purchaser to choose an
EPEAT desktop over an EPEAT laptop; it simply reflects the fact that the overall environmental impact
of laptops, whether EPEAT or non-EPEAT, is significantly lower than the impact of desktops, and thus
the benefits of a high-performing laptop versus a conventional one are less than the benefits of a high-
performing desktop versus a conventional desktop.
In version 3.0 of the EEBC, released in April 2012, baseline products are assumed to match the profile of
the now-obsolete Energy Star version 4.0 specifications, while EPEAT products must meet Energy Star
version 5.0. However, changes between these Energy Star specifications did not proceed along the same
track as they had between Energy Star versions 3.0 and 4.0. The latest changes produced a very different
profile of environmental benefits than had been seen previously. In the newer EEBC, EPEAT laptops
produce 5-6% of the energy and related benefits of desktops - still a small fraction, but far greater than
the 1% benefits previously obtained. These per-unit benefits are shown on the right side of Exhibit 3-23.
87 Because energy and related benefits (greenhouse gas emissions, air emissions) are due to the criterion that EPEAT electronics must meet Energy
Star technical specifications, the EPEAT environmental benefits reported here may include some benefits that are attributed to the Energy Star
program rather than EPEAT within EPA internal reporting (i.e., tracking the programs' contributions towards EPA's strategic goals). lEc could not
determine how the Agency handles internal attribution. It should be noted several factors make it difficult to apportion credit to each program,
including: the fact that EPEAT electronics must meet Energy Star technical specifications, but do not need to be Energy Star-certified; the question
of to what extent obtaining Energy Star certification spurs manufacturers to also pursue EPEAT-certification, and vice versa; and the question of
whether institutional purchasers or other buyers would have opted to buy either Energy Star- or EPEAT-certified products if the other program had
not existed (i.e., determining the baseline to measure against in determining the programs' impact).
88 These figures compare EPEAT products certified at the silver level.
3-36
-------
EXHIBIT 3-23. PER-UNIT ENVIRONMENTAL BENEFITS OF EPEAT PRODUCTS: EEBC VERSIONS 2.0 AND
3.0
BENEFIT
CATEGORY
Electricity
Primary Materials
Air Emissions
(including
greenhouse gases)
Greenhouse Gas
Emissions
Water Emissions
Toxic Materials
Solid Waste
Hazardous Waste
UNIT
Kilowatt-
hours
Kilograms
Kilograms
Kilograms
carbon
equivalent
Kilograms
Kilograms
Kilograms
Kilograms
EEBC VERSION 2.0 (MARCH 2009)
DESKTOPS
570.76
1012.89
2338.57
107.71
4.90
0.05
0.62
1.64
LAPTOPS
(% OF
DESKTOPS)
6.33
(1.1%)
8.25
(0.8%)
18.34
(0.8%)
0.90
(0.8%)
0.04
(0.8%)
0.01
(17.9%)
0.26
(41 .2%)
0.69
(42.3%)
MONITORS
(% OF
DESKTOPS)
197.99
(34.7%)
350.83
(34.6%)
809.86
(34.6%)
37.31
(34.6%)
1.70
(34.6%)
0.03
(53.0%)
0.26
(42.0%)
0.97
(59.5%)
EEBC VERSION 3.0 (APRIL 2012)
DESKTOPS
553.32
978.76
2258.99
104.11
4.73
0.05
0.87
1.64
LAPTOPS
(% OF
DESKTOPS)
31.66
(5.7%)
48.30
(4.9%)
109.70
(4.9%)
5.21
(5.0%)
0.23
(4.9%)
0.01
(17.9%)
0.68
(77.8%)
0.69
(42.4%)
MONITORS
(% OF
DESKTOPS)
65.53
(11.8%)
110.55
(11.3%)
253.90
(1 1 .2%)
11.81
(11.3%)
0.53
(11.3%)
0.03
(53.0%)
0.54
(62.3%)
0.97
(59.5%)
The changes in impacts between different versions of the EEBC highlights a point raised earlier, namely,
that obsolete Energy Star specifications may not be an ideal proxy for baseline electronics products.
While the older Energy Star specifications may represent useful approximations of the 'average' product
and be easier to document than other options, it is almost certainly not the case that the per-unit energy
savings of EPEAT laptops grew fivefold over a three-year period (from 6.33 to 31.66 kwh), as would be
implied by a literal interpretation of the results from the two versions of the EEBC.
Over the long run, it seems likely that changes in Energy Star requirements will track (and indeed, drive)
changes in the environmental performance of the market as a whole. Nonetheless, we should view the
EPEAT program's environmental results in any given year with a critical eye. The reported year-by-year
trends in EPEAT's total environmental benefits (whether for the federal government, the market as a
whole, or another unit of evaluation) should be seen as approximations, but not as perfect reflections of
reality. The apparent downturn in total benefits from 2009 to 2010 should be viewed with this in mind.
QUESTION 6: USE AND INFLUENCE OF EPP PROGRAM OUTPUTS
Introduction
This question explores the use of EPP Program outputs. Evaluation Question 6 asks:
6. How have the EPP Program's outputs, such as technical assistance, information dissemination,
decision tools, standards, and policy and contract language, been utilized by federal agencies?
3-37
-------
a. How have EPP activities contributed to purchasing changes at federal agencies?
The survey findings and interviews were our main data sources for this evaluation question.89 We also
analyzed FGCG web hit data.
Key Findings
• Direct use of EPP outputs such as model contract language and EPP policies by federal purchasers is
limited. However, all EPP outputs tested in the survey were rated moderately helpful or very helpful
by a majority of purchasers who have used them. Purchasers rely heavily on agency-specific
purchasing policies and guidelines in their purchasing decisions. The EPP Program may have an
indirect influence on purchasers through contract language and other EPP outputs adopted by
agencies and incorporated in agency-specific purchasing policies. The survey was unable to explore
indirect relationships.
• In general, higher exposure to EPP outputs is statistically associated with current greener purchasing
behavior. There is a statistically significant relationship between the level of exposure to EPP outputs
and the percent of purchases that are environmentally preferable. However, we found no relationship
between exposure to EPP outputs and changes m purchasing behavior over the last 3 years.
• Federal buyer use of standards that EPP helped to develop has mixed findings from the survey. On
one hand, a high percent of purchasers who regularly purchase building and construction products
looks for the carpet, floor coverings, and gypsum board standards that EPP helped to develop. Also,
respondents with higher exposure to EPP outputs were more likely to consider environmental factors
in determining "best value" (59.6% versus 49.5%); this difference is statistically significant. On the
other hand, only 33% of electronics purchasers report looking for EPEAT, and about half of
purchasers cannot estimate the percent of their spending on products certified to EPEAT or to the
building and construction standards. Importantly, purchasers who use EPP-developed standards are
loyal users. In other words, once purchasers start using a "green" standard, they generally use it for
the majority of relevant purchases.
• EPP made meaningful and significant contributions to the voluntary consensus standards featured in
this evaluation - a key output of the EPP Program. EPP catalyzed the development of the standards
and brought credibility and rigor to the process. EPP's participation also resulted in more
environmentally protective standards.
We discuss these findings in detail below.
Use and Helpfulness of EPP Program Outputs
Exhibit 3-24 summarizes the use of EPP outputs by survey respondents. As shown in the exhibit, the EPP
website was the most frequently used resource (30%), followed by EPP guidance documents (25%),
EPP's model policy and contract language (20%), and EPP tools and environmental benefits calculators
(16%). Fewer purchasers have used the other EPP outputs. However, the survey questions did not capture
indirect relationships, for example, if a model policy was incorporated into an agency policy.
89 The survey analysis includes both descriptive and inferential statistics, including analyses of the statistical association, if any, between higher
exposure to EPP outputs and purchasing attitudes and behaviors. Chapter 2 describes the methodology for conducting the survey analyses.
3-38
-------
All EPP outputs were rated moderately helpful or very helpful by a majority of purchasers who have used
them, as shown in Exhibit 3-25. The highest-rated outputs (counting moderately or very helpful) included
the EPP website (75%) and EPP guidance documents (71%). Outputs with the highest percentage of
applicable respondents indicating that the resource was very helpful include: EPP presentations (35%);
direct technical assistance (34%); and working groups with EPP staff (34%). Opinion was mixed on
working groups, informal interactions, and direct technical assistance: 19% of applicable respondents
rated each of these not at all helpful.
EXHIBIT 3-24. USE OF EPP OUTPUTS
EPP RESOURCE
EPP website
EPP guidance docs
EPP model policy, contract language, and /or specs
EPP tools/environmental benefits calculator
Attended seminar or conference where EPP staff presented
Attended training event offered by EPP staff
Engaged in regular (informal) interactions with EPP staff
Received direct technical assistance from EPP staff
Participated in working group with EPP staff
One or more of the above
Three or more of the above
HAVE USED IN THE
PAST YEAR %
29.5%
25.7%
20.0%
15.7%
1 1 .0%
10.6%
7.9%
7.7%
7.6%
35.9%
20.7%
HAVE NOT USED IN
THE PAST YEAR %
70.5%
74.3%
80.0%
84.3%
89.0%
89.4%
92.1%
92.3%
92.4%
64.1%
79.3%
EPEAT and Other Electronics
FAR 23.705 and Executive Order 13514 require federal agencies to meet at least 95% of their annual
acquisition of eligible electronic products with EPEAT certified products.90 All of the federal purchasing
policy managers that lEc interviewed stated that their agencies (EPA, DOD, GSA, and DOE) use EPEAT;
for instance, EPEAT has been incorporated in EPA's blanket purchase agreement (BPA) for information
technology. However, the survey found a difference between policy and practice: As shown in Exhibit 3-
26, only 33% of electronics purchasers typically look for EPEAT; this is a higher percentage than look for
FEMP (24%), but much lower than Energy Star (81%). The difference between the percent of purchasers
that typically look for Energy Star and EPEAT could be a function of time and exposure: Energy Star
started in 1992, and EPEAT started in 2006. In addition, even if federal purchasers do not typically look
for EPEAT certified products, they may nonetheless be purchasing EPEAT products through their
90 The FAR requires agencies to meet at least 95% of their annual acquisition requirement for electronic products categorized by EPEAT unless there
is no EPEAT standard for such products. EO 13514 requires federal agencies to ensure that 95% of new contract actions are environmentally
preferable (e.g., EPEAT registered), where such products and services meet agency performance requirements.
3-39
-------
agency's purchasing vehicles. For example, EPA's BPA for IT is the "mandatory first option" for EPA
purchasers; therefore, purchasers who use the BPA are likely purchasing EPEAT products even if they are
not consciously looking for the EPEAT label. Our survey was not able to quantify this indirect effect.
EXHIBIT 3-25. HELPFULNESS OF EPP OUTPUTS
EPP RESOURCE
EPP website
EPP guidance docs
EPP model policy, contract language,
and /or specs
EPP tools/environmental benefits
calculator
Attended seminar/conference where EPP
staff presented
Attended training event offered by EPP
staff
Engaged in regular (informal) interactions
with EPP staff
Received direct technical assistance from
EPP staff
Participated in working group with EPP
staff
Note: Excludes N/A; rounding
NOT AT ALL
HELPFUL
%
4.7%
6.9%
8.9%
12.0%
13.3%
12.6%
18.6%
18.9%
18.9%
MARGINALLY
HELPFUL
%
20.8%
22.2%
24.1%
25.8%
19.0%
19.6%
20.6%
16.9%
18.9%
MODERATELY
HELPFUL
%
43.5%
42.6%
40.8%
37.6%
32.6%
34.1%
26.0%
27.4%
27.0%
VERY
HELPFUL
%
31 .0%
28.3%
26.2%
24.6%
34.8%
33.0%
32.8%
34.3%
33.7%
EXHIBIT 3-26. ELECTRONICS STANDARDS THAT PURCHASERS TYPICALLY LOOK FOR
ENERGY STAR
81.3%
FEMP
24.1%
EPEAT (IEEE
1680)
32.6%
NONE OF THE
ABOVE
12.8%
OTHER
5.6%
The survey also asked purchasers what percent of computers and monitors that they purchased in the past
year was certified to various standards. As shown in Exhibit 3-27, 65% of respondents who purchased
computers in the past year do not know the proportion of EPEAT certified computers they purchased. Of
those who do know, the majority bought 75% or more EPEAT computers. Based on the figures for
EPEAT and the other certifications, it appears that when computer purchasers use certifications, they
purchase the majority of their computers to follow those certifications.
3-40
-------
EXHIBIT 3-27. PERCENT OF PURCHASES CERTIFIED TO ELECTRONICS STANDARDS
In the past year, approximately
what percent of computers and
monitors that you purchased was...
Energy Star certified
FEMP certified
EPEAT (IEEE 1680) certified
LESS THAN
25%
4.9%
4.0%
3.8%
25-50%
6.2%
5.2%
4.0%
51%-75%
7.6%
3.5%
5.6%
MORE THAN
75%
53.2%
14.5%
21.8%
DON'T
KNOW
28.1%
72.8%
64.8%
We also asked purchasers about the use of the EEBC. One federal purchasing policy manager that we
spoke with (DOE) reported using the EEBC. The overwhelming majority (95%) of electronics purchasers
who responded to the survey have not used the EEBC. This is not surprising, since the EEBC is more
likely to be used by purchasing policy managers than by purchasing staff.
Building and Construction Products
Similar to the electronics standards, we explored the use of building and construction product standards
and related outputs by federal agencies and purchasing staff. GSA requires NSF 140 certification for most
carpet sold on the GSA Multiple Award Schedules (Schedule 72). DOE has incorporated NSF 140, NSF
332, and BIFMA e3 into its specifications and contract language. We did not interview any federal
purchasing managers using the ULE 100 gypsum standard.
Exhibit 3-28 shows the percentage of survey respondents using each standard, for all building and
construction purchasers and for purchasers of specific building and construction products. All of the
building and construction standards and labels show at least modest use. Overall, the most commonly
used labels are low VOC and BioPreferred, which are each used by more than one-third of building and
construction product purchasers. It is not surprising that low VOC and BioPreferred are more commonly
used, because these standards cover multiple product categories within the building and construction
product sector. The floor covering, carpet, and gypsum board standards are used by a clear majority of
purchasers of those products (80.1%, 72.4%, and 62.4%, respectively). The BIFMA e3 standard is not
widely used by federal purchasers; only 11.6% of furniture purchasers used the standard.
For each building product category, nearly half of the respondents did not know the proportion of their
purchases that met the standards; for furniture, 74% of purchasers could not estimate their proportion of
green purchases. As shown in Exhibit 3-29, for purchasers who did know the proportions:
• For both NSF standards, the majority of purchasers purchased more than 50% certified product.
• Purchase rates for BIFMA certified furniture were low, with most purchasers that indicated a
percentage buying less than 50% BIFMA e3 certified furniture.
• Gypsum board purchasers were split fairly evenly on their purchases of ULE certified products.
Again, similar to electronics purchasers, those who know their portion of green purchasing are generally
buying green (except BIFMA e3).
3-41
-------
EXHIBIT 3-28. BUILDING AND CONSTRUCTION PRODUCT STANDARDS THAT PURCHASERS
TYPICALLY LOOK FOR
Low Volatile Organic Compounds (VOC)
BioP referred
Green Seal
None of the above
NSF/ANSI Standard 332 (floor covering standard)
NSF/ANSI Standard 140 (carpet standard)
GreenGuard
Comprehensive Procurement Guidelines (CPG)
ULE ISR 100 (gypsum board /wallboard standard)
Forest Stewardship Council (FSC)
BIFMA e3 (furniture solutions)
Other* (respondents specified)
PURCHASERS USIN<
ALL BUILDING AND
CONSTRUCTION PRODUCT
PURCHASERS
38.4%
35.6%
27.3%
26.0%
24.7%
24.3%
19.1%
18.9%
16.3%
15.4%
11.7%
4.8%
3 THE STANDARDS
PURCHASERS OF SPECIFIC
PRODUCTS
80.1%
72.4%
62.4%
11.6%
EXHIBIT 3-29. PERCENT OF PURCHASES CERTIFIED TO BUILDING AND CONSTRUCTION STANDARDS
Over the past year, approximately
what percent of the [product] that
you purchased was [x] certified?
Carpet (NSF 140)
Floor coverings (NSF 332)
Furniture (BIFMA e3)
Gypsum board (ULE 100)
LESS THAN
25%
8.8%
9.0%
10.9%
14.2%
25-50%
7.2%
7.8%
5.5%
10.6%
51-75%
11.6%
15.1%
3.9%
12.1%
MORE THAN
75%
27.6%
19.9%
5.7%
14.2%
DON'T
KNOW
44.8%
48.2%
74.0%
48.9%
We also analyzed the use of the FGCG. Interviews with federal purchasing managers indicate that the
Guide is used in some capacity by several agencies. EPA uses the Guide as a resource, and DOE indicated
that its use is optional within the agency, but not given priority. GSA's Public Buildings Service (PBS)
and EPP staff had different perspectives on the use of the Guide by PBS: according to EPP staff, PBS
adopted parts of the Guide into its Facilities Standards (P100), but our contact at PBS was not aware that
they had used the Guide. This discrepancy points back to the potential indirect influence of the EPP
Program, and the difficulty in tracking the use of EPP Program outputs. In this case, PBS may have
incorporated language that was introduced in the FGCG, unbeknownst to the individual who we
interviewed. EPP staff also reported that military agencies used the Guide to incorporate environmentally
preferable principles into Unified Facilities Guide Specifications. lEc did not have an opportunity to
corroborate this account with the users of the Specifications.
3-42
-------
As shown in Exhibit 3-30, a low overall proportion of building and construction product purchasers in our
survey have used the Guide (13%). However, 84% of purchasers who have used the Guide indicated that
products meeting its criteria were given priority in their purchasing decisions, and about half (51%)
indicated that products meeting the Guide's criteria were required by their agency or department. Again,
this survey result points to the finding of loyal use among those purchasers that use EPP outputs.
lEc also conducted an analysis of FGCG website data. Exhibit 3-31 summarizes the number of page
views, unique page views, and average time spent on the page from 2010-2012. The exhibit shows there
were more than 30,000 page views (more than 27,000 unique page views) in 2010 - 2012; the average
time spent on the page averaged slightly less than two minutes. The number of page views has declined
each year; page views in 2012 were less than half the level in 2010. According to the individual who
provided the FGCG data to lEc, it is difficult to interpret the decline, but the decline is not due to changes
in how EPA tracks web hit data. He noted there could be several reasons why FGCG pages are not being
viewed as much as in earlier years, including the possibility that people have already downloaded the
information and may not need to download it again.91
EXHIBIT 3-30. SURVEY RESULTS ON USE OF THE FGCG
Have you used the Federal Green Construction
Guide for Specifiers?
Are products that meet the criteria of the
Federal Green Construction Guide for
Specifiers given priority in your purchasing
decisions?
Are products that meet the criteria of the
Federal Green Construction Guide for
Specifiers optional or required by your
agency /department?
All
Building
products
purchasers
FGCG users
FGCG users
YES
4.3%
12.8%
YES
83.5%
OPTIONAL
25.7%
NO
95.7%
87.2%
NO
16.5%
REQUIRED
50.5%
DON'T KNOW
23.9%
91 Email from Director, Information Technology, National Institute of Building Sciences, to lEc, April 18, 2013.
3-43
-------
EXHIBIT 3-31. FGCG WEBSITE ANALYTICS
2010
2011
2012
Total
PAGE VIEWS
15,612
11,301
6,782
33,695
UNIQUE PAGE VIEWS
12,742
9,111
5,486
27,339
AVERAGE TIME
SPENT ON PAGE
(MINUTES:SECONDS)
1:54
1:37
1:51
Note: 2009 data was tracked differently and is not comparable to subsequent years
We also analyzed summary data for the top 3,000 documents downloaded from the Whole Building
Design Guide in 2012 (http://www.wbdg.org/).92 The Whole Building Design Guide includes - but is not
limited to - the FGCG specifications; therefore, the top 3,000 downloads include FGCG specifications
and other information. The top three most downloaded FGCG specifications in 2012 were solar energy
electrical power generation equipment (ranked 854 out of 3,000), commissioning (904 out of 3,000), and
plumbing fixtures (1,098 out of 3,000). Exhibit 3-32 presents download data of the FGCG specifications
for carpet, floor covering, furniture, and gypsum board. The specifications for resilient flooring and
gypsum board were the most frequently downloaded, followed closely by carpeting. The specification for
systems furniture was downloaded less frequently. This pattern echoes the survey findings on the use of
EPP standards, which showed furniture lagging resilient flooring, gypsum board, and carpeting.
EXHIBIT 3-32. DOWNLOADS OF SELECTED GREEN SPECIFICATIONS
RANK
1,935
1,944
2,083
2,579
DOCUMENT
/ccb/fedgreen/fgs_096500.pdf
/ccb/fedgreen/fgs_092900.pdf
/ccb/fedgreen/fgs_096800.pdf
/ccb/fedgreen /fgs_1 25900. pdf
TOPIC
Resilient Flooring
Gypsum Board
Carpeting
Systems Furniture
HITS
453
462
404
298
VISITS
433
430
393
297
! Data was not available for prior years.
3-44
-------
Hospitality and Travel
Our information on the use of hospitality and travel
outputs is limited. Nonetheless, we found some
indications that purchasers are using EPP's hospitality
and travel outputs. EPA Region 9 used the Convention
Industry Council's (CIC) report as a resource to develop
the Region's Green Meetings and Conference Policy
(GMCP), and the Region uses the "14 questions" from the
CIC report to book meeting venues. GSA is revising the
Federal Travel Regulation based, in part, on the GMCP.
Region 10 is also adapting the GMCP for its own use.
Moreover, some facilities that participate in the Federal
Green Challenge have used the GMCP as a resource to
fulfill the program's requirements. (See the sidebar for
more information about the Federal Green Challenge.) It
is premature to see federal agencies using the ASTM
Green Meetings and Events Standards, which were
finalized within the past year. Moreover, it is unclear if
EPA is going to use these standards.
Influence of EPP Outputs on Purchasing Attitudes
and Behaviors
lEc used statistical analyses (chi-squared test) to examine
the relationship (if any) between EPP outputs and
purchaser attitudes and behaviors. We compared survey
respondents with high exposure to EPP outputs to
respondents with low exposure, and tested whether or not
greater exposure to EPP outputs is statistically associated
with greener purchasing attitudes and behaviors. (Chapter
2 describes our methodology for constructing the high
exposure and low exposure groups and the statistical
methods employed in our analysis.)
FEDERAL GREEN CHALLENGE
The Federal Green Challenge (FGC) is a
national voluntary program that encourages
federal agencies to reduce their
environmental impact. Participants commit
to an improvement of at least 5% in a
minimum of two of the six target areas -
waste, electronics, purchasing, energy,
water, and transportation.
The FGC is modeled on the FEC and has
adopted much of FEC's structure. When
participants join FGC, they are required to
provide baseline data and establish
performance goals, and must follow up by
providing performance data on an annual
basis. However, FGC's focus is broader than
FEC. FGC initially had four target areas:
energy, transportation, waste, and water. In
2010 the program added purchasing and
electronics. When electronics was added as a
target area, FGC chose to use many of the
same measures that FEC is tracking for
purchasing and power.
FGC has monthly "web academies" as well as
additional events on a regional level. These
activities were also modeled after FEC,
which has a similar educational component.
According to the co-creator of the FGC, the
program was "inspired by FEC's success." In
addition, the FGC has received technical
assistance and resources from EPP
Headquarters staff, focusing on the
electronics area. According to the co-
creator, the FEC has been very important to
FGC's success.
Exhibit 3-33 provides an overview of the results. As shown in the exhibit, we did not find any statistically
significant relationship between the level of exposure to EPP outputs and purchasers' current views
towards environmentally preferable purchasing. However, we did find a statistically significant
relationship between level of exposure to EPP outputs and changes in attitudes over the past three years.
The results for behavior are reversed: Exposure to EPP outputs is correlated with current purchasing
behavior, but is not correlated with changes in purchasing behavior. These findings, while generally
positive, are somewhat difficult to interpret. Based on our theory of the EPP Program, as reflected in the
logic model in Chapter 1, we would expect changes in attitudes to precede changes in behavior. However,
our analysis of the survey findings shows statistically significant results for changes in attitudes and
current behavior (but not changes in behavior). This may reflect some channel of influence that is not
3-45
-------
captured in the logic model, or it may be a function of the survey. The available information does not
allow us to offer a definitive explanation for the results in Exhibit 3-33.93
EXHIBIT 3-33. CORRELATION BETWEEN EXPOSURE TO EPP OUTPUTS AND ATTITUDES/BEHAVIORS
Attitudes
Behaviors
Current
Change over 3 Years
Current
Change over 3 Years
STATISTICALLY SIGNIFICANT?
YES
X
X
NO
X
X
We also looked for evidence of any differences in how high exposure and low exposure purchasers
consider environmental factors in their purchasing decisions. As shown in Exhibit 3-34, respondents with
higher exposure to EPP outputs were more likely to consider environmental factors in determining "best
value" (59.6% versus 49.5%); this difference is statistically significant at the 5% confidence level.
However, there was relatively little difference between high exposure and low exposure purchasers in
how respondents evaluate cost (initial or lifecycle), as shown in Exhibit 3-35.
EXHIBIT 3-34. FACTORS THAT PURCHASERS CONSIDER IN DETERMINING "BEST VALUE"
FACTOR
Environmental considerations
EXPOSURE
Low
High
%
49.5%
59.6%
EXHIBIT 3-35. FACTORS THAT PURCHASERS CONSIDER IN EVALUATING COST
FACTOR
Initial cost
Lifecycle cost
Don't know
EXPOSURE
Low
High
Low
High
Low
High
%
31 .8%
37.8%
64.6%
58.2%
3.6%
4.0%
93 The chi-squared tests involve creating contingency tables to compare the actual and expected frequencies of events. See Chapter 2, Exhibit 2-5
for an example of a contingency table. For reasons of presentation and flow, we have not presented the contingency tables in this chapter.
3-46
-------
Given the evaluation's heavy focus on EPP standards, we also looked at the relationship between being
familiar with an EPP standard and the percent of products purchased with certification to that standard.
We find a statistically significant relationship between looking for EPEAT and the percent of computers
and monitors purchased with EPEAT certification.94 Similarly, for the building and construction
standards, there is a statistically significant relationship between being familiar with a particular EPP
standard (NSF 140, NSF 332, BIFMA e3, ULE 100) and the percent of eligible products purchased with
certification to that standard.95
There is also a statistically significant relationship between familiarity with the EPP standards and the
percent of purchases made in the past year that were environmentally preferable. Although all of these
relationships are statistically significant, we used the Cramer's V to statistically rank the standards that
are most strongly associated with environmentally preferable purchasing. The order (from strongest to
weakest degree of association) follows:
• ULE 100 (gypsum board)
• NSF 140 (carpet)
• BIFMA e3 (furniture)
• NSF 332 (floor coverings)
• EPEAT (electronics)96'97
The ULE 100 gypsum standard is both the most strongly correlated with green purchasing and arguably
the least known; EPEAT has the weakest (but still statistically significant) correlation with green
purchasing and is the most widely known of the standards. The findings suggest that the more widely
known a standard is, the more likely a purchaser is to be familiar with it but not use it.
Standards Development
The voluntary standards for the product and service categories covered in this evaluation constitute key
EPP Program outputs and are of significant interest to EPP Program managers. Therefore, in addition to
examining the use of the EPP standards by federal purchasers (discussed above), the evaluation explored
EPP's role in developing the standards and the environmental stringency of the standards. (The sidebar
includes information on EPP's role in the cross-sector ASTM International Committee E60 on
Sustainability.)
94 The question asked: "Which of the following environmental standards/labels do you typically look for when purchasing computers and monitors?"
The questions for building and construction standards asked: "How familiar are you with the [x] standard?"
95 All results are significant at the 5% confidence level, except NSF 140, which is significant at the 10% confidence level.
96 We also tested for the influence of Executive Order 13514, which specifically requires EPEAT. To do this, we compared purchasers who look for
EPEAT and are familiar with the EO to those who look for EPEAT but are not familiar with the EO. There is no statistical difference between the
proportions of purchasers in both categories who buy more than 50% environmentally preferable products/services.
97 We also found a statistically significant relationship between using the EEBC and percent of environmentally preferable purchases.
3-47
-------
Participants in the standards development process indicated
that EPP played an important role in several standards by
adding credibility and rigor to the process:
• EPEAT, the first of the voluntary standards to be
adopted, grew out of an initiative launched in 2001
between EPA Regions 9 and 10, industry, and other
stakeholders to develop a method for assessing the
environmental attributes of electronic products. EPP
Headquarters staff became involved in 2003, and steered
the committee toward developing an ANSI-accredited
standard. EPP staff also served on standards
development workgroups and provided technical input.
In addition, EPP provided seed funding for the Green
Electronics Council, which administers and promotes
EPEAT.
• Within the building and construction sector, industry
and other stakeholders recognized the need to address
sustainability issues, but they were concerned that
developing and certifying to product standards would be
time-consuming and resource-intensive, and the
standards might not gain acceptance in the market. Also,
not all stakeholders agreed on the type of standards that
should be developed - for example, single or multiple
attributes - and which process was best - for example, whether standards should be developed by
industry associations, by government, or through open committees. EPP staff steered industry toward
a multi-attribute, multi-stakeholder process. In addition, EPP provided assurances that voluntary
standards would have credibility with the government and in the broader market.
• Several interviewees recalled a presentation by EPP staff at the Greenbuild Conference in Chicago as
a turning point in their thinking about whether, and how, to develop standards. As one industry
representative recalled, "Based on what I heard at the conference, I realized that EPA had interest in
this, that EPP had legs and would be around for a while; it didn't seem like a flash in the pan."
Similarly, a standards stakeholder from the furniture industry recalled a similar turning point during a
meeting with EPP staff at EPA Headquarters in late 2005: "Based on EPA's feedback at that meeting,
we got the sense that an ANSI standard would be credible," given that ANSI standards use an open
and transparent process with multi-stakeholder involvement. In the case of gypsum board, UL
Environment (ULE) had already developed an initial draft of the standard in house, prior to
convening the standards committee - this is ULE's standard operating procedure - but EPP staff
provided input on the draft standard before it was released to the market for use by manufacturers.
Importantly, EPP staff also served on the committees that developed the standards and provided
technical input and coordination. EPP staff played a leadership role for NSF 140 and NSF 332, and a
supporting role for BIFMA e3 and ULE 100.
ASTM INTERNATIONAL COMMITTEE E60
ON SUSTAINABILITY
In 2008, ASTM launched a cross-sector
standards development committee -
ASTM International Committee E60 on
Sustainability. The committee has grown
from 20-30 people initially to 800, due
in part to EPP's participation as well as
broader market and cultural changes.
All ASTM sustainability standards are
under the committee's purview. The
committee established a platform for
green building standards covering a wide
breadth of topics, and also works on
hospitality standards. A case can be
made that EPP played a role in
catalyzing the development of all of the
ASTM sustainability standards that have
been developed since the committee
was established. Relationships built with
other stakeholders through the ASTM
committee process have also been
important in other standard
development processes such as IgCC.
3-48
-------
• In the hospitality and travel sector, EPP staff convened the Convention Industry Council's Accepted
Practices Exchange (CIC/APEX) and the Green Meetings Industry Council (GMIC) to develop
ANSI-accredited standards through the ASTM process. It is unlikely that the stakeholders would have
developed ANSI-accredited standards for green hospitality and travel without EPP's involvement.
EPP staff played a leadership role on the committees and provided technical input for the standards.
Across the board, EPP staffs participation raised the profile of the standards, brought stakeholders to the
table, and enhanced the credibility and rigor of the process. According to the individual who chaired three
of the standards committees (NSF 140, NSF 332, and BIFMA e3): "There was a strong desire by industry
to have EPA involved because the standard wouldn't be seen as credible without EPA, and there were
elements of the standard where EPA had technical expertise." Similarly, the head of the ASTM Green
Meetings and Events committee stated that EPP (and other EPA staff) provided substantive input on both
the structure and contents of the standards. Likewise, gypsum board stakeholders reported that EPP
brought scientific and technical rigor to the process. A number of stakeholders expressed a desire for EPP
staff to be even more involved in developing the standards, and noted that EPP's active and continuous
engagement was important for the process to succeed. Some stakeholders noted the need for greater
participation from other parts of EPA, especially in cases where the EPP staff lead may not have as much
expertise in a particular subject area.
Standards stakeholders further noted that EPP staff increased the environmental protectiveness of the
standards. For example:
• EPP staff insisted that Energy Star requirements were included in the IEEE 1680.2/EPEAT standards
for computers and monitors. According to EPP staff, industry pushed back because manufacturers did
not want the expense of becoming Energy Star qualified; the compromise was that IEEE products
need to meet the technical specifications of Energy Star, but do not actually have to be Energy Star
qualified.
• For the NSF 140 carpet standard, a participant noted that EPP staff "pushed industry beyond what
they were comfortable doing otherwise" - for example, EPP ensured that NSF 140 included metrics
for volatile organic compounds.
• Similarly, the Vice Chair of the NSF 332 committee stated that EPP staff "pushed the envelope and
the committee" in making the standard more protective of the environment.
• Likewise, a furniture industry representative stated that EPP's involvement pushed the BIFMA
e3/Level standard to go beyond what industry was already doing with respect to chemicals of
concern. In addition, the BIFMA e3 standard incorporated Energy Star in its scoring criteria.
• Gypsum board and green hospitality/travel stakeholders also reported these standards were more
rigorous as a result of EPP's involvement.
However, as discussed under the findings for Question 12, there is some disagreement as to whether the
standards that EPP helped to develop are true "leadership" standards.
3-49
-------
QUESTION 7: EPP PROGRAM COORDINATION WITH OTHER FEDERAL AGENCIES
Introduction
Evaluation Question 7 asks, "How effective is the EPP Program in coordinating with green purchasing
programs at other federal agencies?" In this section, we present our findings on this evaluation question,
drawn from 10 interviews with EPP staff and purchasing policy managers at several different federal
agencies, including the Department of Energy (DOE), Department of Defense (DOD), the General
Services Administration (GSA), and EPA's Office of Acquisition Management (OAM).
A significant portion of EPP's dealings with other federal agencies comes in the context of the standards
development process; other interactions included ongoing interagency workgroups and workgroups
assembled to address discrete tasks. Recognizing the diverse positions of the different players that
influence purchasing activity in the federal government, we evaluated how EPP interacted with any
relevant contacts at other federal agencies, without limiting our analysis only to contacts in formal green
purchasing programs. We also consider EPP's collaborations with other program offices within EPA.
Key Findings
• Interviewees indicate that EPP played a key role in moving the electronics, building products, and
travel and hospitality sectors toward multi-stakeholder, multi-attribute standards. Interviewees also
report that EPP's involvement in standard development processes resulted in these standards being
more protective of the environment.
• EPP worked effectively with other agencies to promote EPEAT through the Federal Electronics
Stewardship Workgroup; green building products through the Federal Green Construction Guide; and
green travel and hospitality through the Region 9 Green Meetings and Conference Policy (GCMP).
Interviewees noted EPP's strategic guidance and leadership in these initiatives.
• More collaboration with GSA is needed to incorporate travel standards that EPP supported into the
Federal Travel Regulations.
Exhibit 3-36 summarizes the interactions between EPP and other federal agencies identified by lEc.
While we do not discuss all of these efforts in detail, the exhibit provides context for our discussion of the
key highlights from each sector. Because we conducted a relatively limited number of interviews that
address this evaluation question, our conclusions are applicable only to a subset of the collaborative
activities that EPP has undertaken with other agencies; we do not reach any global conclusions regarding
the entirety of EPP's collaborative activity. Even so, we believe our conclusions are useful in highlighting
some specific successes, and shortcomings, of the EPP Program.
Electronics
EPP appears to have had substantial impact on electronics purchasing across the federal government.
Interviewees remarked that EPP has met 'real success' in electronics, and have favorably noted
collaborative relationships developed with EPP staff. On the whole, EPP has been effective in its
collaborations with other agencies in this sector.
3-50
-------
EXHIBIT 3-36. KEY EPP INTERACTIONS WITH OTHER FEDERAL AGENCIES
SECTOR
Building
Products,
and Travel &
Hospitality
Electronics
Building
products
Building
products
Travel &
hospitality
INTERACTION
Coordination on
standards
development process
Federal Electronics
Stewardship
Workgroup (FESWG)
Green Building
Workgroup
Federal Green
Construction Guide
Workgroup
EPA Region 9 Green
Meetings and
Conference Policy
workgroup
OTHER PARTIES INVOLVED
Other EPA program and
Regional offices; DOE,
GSA, and other federal
agencies
Numerous federal
agencies, institutional
consumers, state and
local governments, and
industry representatives.
Chaired by the Office of
the Federal
Environmental Executive
(OFEE)
Over 100 individuals
across EPA program
offices
Formerly co-chaired by
EPP, now chaired by
Office of Sustainable
Communities
EPA, OFEE, Whole
Building Design Guide
(WBDG)
Region 9, other EPA
regions, GSA, DOD
YEAR
STARTED
2004
2003
Formed in
2000;
released
FGCGS in
2006
2009
GOALS
Coordinate between experts
in different agencies and
offices to develop coherent
government positions on
standards development
issues
Information exchange
Coordinate interagency
efforts on stewardship
Help develop policies,
guidance, reporting metrics,
etc. for EO 13514
Acts as advisory board for
FEC
Clarify definition of Green
Buildings
Influence standards such as
USGBC LEED, ASHRAE 189,
IgCC
Better reflect lifecycle and
systems thinking, and all
costs of green building
OUTCOMES
Unclear
Development and
promotion of EPEAT
Hraft FDA
Recommended Green
Building Principles,
Goals and Practices
EPA comments on
numerous draft green
building standards
Guiding Principles for
Federal Leadership in
High Performance and
Sustainable Buildings
Federal Green
Construction Guide for
Specifiers
GSA adapting GCMP
into Federal Travel
Regulations (FTR).
EPP provided draft
amendments to the
NOTES
Parties involved
vary from
standard to
standard.
Interviewees
report that GSA's
adoption of the
GCMP into the
FTR/FAR has the
3-51
-------
SECTOR
Travel &
hospitality
Travel &
Hospitality
Travel &
Hospitality
Cross-sector
INTERACTION
City Pairs Program
EPA Acquisition
Regulation s
(EPAAR)Procurement
Language
OCFO workgroup on
travel- related GHGs
Federal Green
Challenge
OTHER PARTIES INVOLVED
GSA, EPA Region 10, DOD,
DOT
EPAOAM
EPA OCFO, other EPA
offices, GSA, DOD, DOT
First created by EPA
Regions 9 and 1 0;
currently managed by EPA
ORCR
YEAR
STARTED
Collab-
oration
began in
2009
2007
2009
2008
GOALS
Integrate consideration of
GHGs emissions into
evaluation of which airlines
receive contracts for federal
travel in existing GSA
program.
Revise EPAAR to include
more specific guidance on
procurement for meetings
and travel.
Working groups include:
1 . Amending the Federal
Travel Regulations (FTR)
2. Amending the Federal
Acquisition Regulations (FAR)
3. Encouraging hybrid
vehicles
4. City Pairs (see above)
5. Encouraging
teleconferencing
Encourage green actions in
six areas waste, electronics,
purchasing, energy, water
and transportation
OUTCOMES
rule which GSA is
expected to use (at
least in part).
Unclear
The "14 Questions,"
intended to guide
travel- related
procurement
decisions.
Recommendation lists.
NOTES
potential to
influence the
entire federal
government.
Collaboration is
currently stalled,
due to
miscommunication
of different goals
for the program,
and difficulty of
identifying
acceptable
metrics.
EPP noted that
the 14 questions
are designed to
raise awareness,
but are not
enforceable and
are not intended
to be a permanent
solution.
OCFO played
facilitating role.
EPP played a
central role in all
subgroups and
producing the
resulting
recommendations.
Inspired by FEC
and uses similar
voluntary
reporting
framework. EPP
3-52
-------
SECTOR
Cross-sector
Cross-sector
Other
INTERACTION
Green Products
Roundtable
Interagency Section
13 Product Standards
& Ecolabels Subgroup
Sustainable
Acquisition and
Materials
Management
Practices Workgroup
(SAMM)
OTHER PARTIES INVOLVED
35 members, including
GSA, DOE, EPA, MIST, and
several industry and non-
profit representatives
Led by GSA and EPA, with
representatives from
several other agencies
Convened by OFEE; 40
active members from
various agencies,
including DOD and GSA
YEAR
STARTED
2009
2010
GOALS
Increasing green purchasing
among institutional buyers by
providing guidance to
improve decision-making
capabilities.
Support the product
environmental-related
procurement goals of EO
13514
Provide a clear rationale to
evaluate product
environmental standards
Simplify sustainable
acquisition for the federal
workforce
Develop green purchasing
and recycling policy
implementation guidance
recommendations.
OUTCOMES
Glossary; framework
for differentiating
green products; green
marketing pledge; and
set of preferred
practices.
Draft Guidelines for
Evaluating Standards
and Ecolabels
Unclear
NOTES
collaboration is
through providing
technical
assistance on
electronics issues.
Generally well-
regarded, but
sustainable
acquisition area is
viewed as weak.
Work is still in
process.
Extent of EPP
participation is
unclear.
Formerly known
as EO 131 01
Interagency
Advisory Group.
3-53
-------
Standards Development
EPP was influential in the development of the IEEE (EPEAT) electronics standards, and a major part of
EPP's work in this area was coordinating with experts at EPA and other federal agencies to develop
coherent government positions. Our interviews indicate that EPP was very successful in this area. One
interviewee who participated in the standard development process noted that EPP's hard work and expert
facilitation was a key element of the standard's success.
Other Electronics Efforts
Outside of the standards development process, EPP's major ongoing collaborative effort in the electronics
sector is the Federal Electronics Stewardship Workgroup (FESWG). Created in 2004, the FESWG acts as
an interagency forum for coordinating, developing and promoting federal electronics policies and
activities. Interviewees from other agencies involved in the workgroup had high praise for EPP staff and
stated that they have been effective in using the forum to promote purchases of EPEAT products.
Another important interaction concerns the Federal Acquisition Regulations (FAR). When the EPEAT
program was first developed, EPP staff worked with GSA to develop language incorporating purchase
requirements for EPEAT computers and monitors into the FAR. They have recently done similar work in
advance of the new EPEAT standards on televisions and imaging equipment. Interviewees noted that
having this language in the FAR has been an important means of increasing purchases of EPEAT
products.
Finally, the Federal Electronics Challenge (FEC) provides multiple avenues for collaboration with other
government programs. Most directly, it recruits purchasers from a wide array of federal agencies for
direct participation in the program, which encourages EPEAT purchases, energy conservation practices,
and product recycling or reuse at end of life. We discuss FEC's effectiveness in these areas in more detail
under Evaluation Questions 8 and 9. FEC also provides trainings and technical assistance to other
agencies directly (e.g., DOD, DOE) and through the Federal Green Challenge (FGC), a voluntary cross-
agency program modeled in large part on the FEC. An interviewee from DOE praised the FEC
coordinator's assistance in facilitating DOE's participation in the program, mentioning her well-deserved
awards from EPA. Consequently, DOE built off of the FEC model for their own program. An interviewee
involved in the FGC noted that FEC staff have been very important to FGC's ongoing success.
Building Products
Standards Development
Interviewees indicated that through its involvement in the NSF/ANSI carpeting and floor covering
standards and the BIFMA furniture standard, EPP drove the industries toward the use of multi-attribute,
multi-stakeholder standards, and made the standards more environmentally protective. Stakeholders for
both the carpet and floor covering standards remarked that the EPP staff pushed the industry
representatives on the committee to a higher level of environmental stewardship than they otherwise
would have been comfortable with. For example, EPP's efforts resulted in the inclusion of criteria
addressing volatile organic compounds in the carpet standard. Interviewees also noted that while EPP
staff effectively steered the standards toward greater environmental protectiveness, they did not do so in
an overbearing way.
3-54
-------
Other Building Product Efforts
Aside from standards development, EPP's primary collaboration in the building products sector was on
the development and distribution of the Federal Green Construction Guide for Specifiers (FGCGS), the
first guide of its kind. The aim of the FGCGS is to "address the need for a comprehensive guide for
procuring green building products and construction/renovation services within the federal government."98
Because we did not interview any non-EPP staff involved in developing the FGCGS, we cannot assess the
collaborative process that took place.
Travel and Hospitality
Standards Development
EPP Headquarters staff pulled in several subject matter experts from EPA Regional offices to participate
in the development of the APEX/ASTM Green Meetings and Events standards. By all accounts, this
collaboration was a challenging one. The main difficulty stems from the fact that the Headquarters and
Regional EPA staff had different goals for the standards. While EPA Headquarters staff envisioned the
standards as a potential tool for guiding sustainable procurement that focused on measurable performance
targets (e.g., energy and water use), Regional staff viewed them more as a means to engage with industry
practitioners to develop environmental management practices (e.g., policies and procedures). This
philosophical difference also emerged between some of the other, non-EPA participants. However, the
issue was not discussed explicitly at the beginning of the collaborative process and did not become clear
until later on. The results were a somewhat challenging (though still functional) process, and a set of
standards viewed as potentially useful but not fully satisfactory to all participants. An upfront dialog on
the objectives of the standards could have lessened some of these difficulties.
According to one interviewee, the collaboration was also hindered by the fact that not all of the EPA staff
involved had prior experience developing voluntary consensus standards. EPA's standards executive has
worked with the National Institute of Standards and Technology (NIST) to develop a training course on
standards and the standards development process; she recommended that EPA staff new to the standards
development process take the course.
Other Travel and Hospitality Efforts
EPP played a key facilitating role in several other initiatives concerning green travel and hospitality, with
the clearest success relating to Region 9's Green Meetings and Conference Policy (GMCP).
• To at least some extent, EPP has been successful in promoting the GMCP, and is working to expand
its impact across the federal government. EPP convened a workgroup to adapt the GMCP developed
by EPA Region 9 in 2009 into GSA's Federal Travel Regulations (FTR). A GSA participant in the
workgroup noted that EPP was actively engaged, drafting numerous documents and seeking to make
the guidance more protective of the environment. This was sometimes perceived as overbearing by
GSA participants. While the GMCP has not yet been adopted into the FTR, if and when this occurs, it
will have strong potential for use across the federal government.
98 Whole Building Design Guide. "Federal Green Construction Guide for Specifiers." Updated July 8, 2011.
http://www.wbdg.org/design/greenspec.php
3-55
-------
• Similar to the GMCP effort, EPP led a workgroup with several agencies set up by EPA's Office of the
Chief Financial Officer (OCFO) focusing on developing recommendations for reducing the cost and
greenhouse gas impact associated with federal travel. EPP coordinated the process, and the EPP staff
person involved was regarded by interviewees as an expert leader. However, it is unclear how OCFO
has used or plans to use the workgroup's recommendations.
• One outgrowth from the EPA OCFO workgroup was an initiative on the City Pairs program. City
Pairs is a GSA program that awards contracts to airlines for federal employees' travel on a route-by-
route basis. Starting in 2009, EPP collaborators sought to integrate prior work by EPA Region 10 on
calculating travel-related GHG emissions into the GSA decision-making process, by adding
emissions as an evaluation factor. Unlike some of the other collaborative efforts noted above, this one
has not been successful. The City Pair program has been hindered by challenges in determining how
to weigh GHG emissions versus cost, and on how to measure emissions, but it appears that the effort
has also been plagued by miscommunication. Specifically, in our interviews, EPP staff (including
both Headquarters and Regional staff) described relatively modest goals for the initiative of setting up
information systems to inform sustainable travel choices, whereas the GSA staff person interpreted
EPP's aims as being more ambitious, seeking immediate emissions reductions by airlines. This
disconnect has led to a perceived lack of goal alignment between EPP and GSA that, among other
factors, has hindered progress in the collaboration.
Other Collaborative Efforts
Beyond the sector-specific endeavors described above, EPP staff have also engaged in several broader
initiatives, including the Green Products Roundtable, the Sustainable Acquisition and Materials
Management Practices Workgroup (SAMM), and the Section 13 Interagency Product Standards and
Ecolabels Sub-working Group. Our interviews did not address the Green Products Roundtable or the
SAMM. The Section 13 workgroup is engaged in ongoing work to facilitate the use of product
sustainability standards by federal purchasers, by developing guidelines for purchasers to use in assessing
standards. Participants in this workgroup considered the EPP staff person involved "extremely
knowledgeable and effective" and gave them high accolades. It is unclear what the outcome of the
collaboration will be, as its work is still underway.
Although it is outside of the three product sectors being addressed in this program evaluation, one other
effort worth brief mention is a 2003 collaboration between EPP and EPA OAM to develop a blanket
purchase agreement (BPA) for office supplies. An OAM staff person involved in this effort saw the
collaboration as a major success that changed the concept of how EPA purchasers bought their goods.
The BPA was awarded to a sole supplier and created incentives to increase the number of
environmentally preferable products offered. In response, the supplier created anew section of its product
catalog and a new green icon to designate environmentally preferable product. EPA was recognized with
a "Closing the Circle" Award from the White House for the BPA, and GSA is now using similar criteria
in its Federal Strategic Sourcing Initiative.
Interview Suggestions for Improving Future Collaborations
Overall, our interviews indicate that where EPP has engaged with other federal agencies, the EPP staff
members' efforts have generally been well-received, with positive assessments from other stakeholders.
This has been true both for coordination on standards development and for other interactions, such as
3-56
-------
interagency workgroups. However, the interviews do provide some suggestions for improving future
collaborations:
• EPP's experience in the travel and hospitality sector highlights the importance of having goal
alignment and clear communication between stakeholders from the beginning of the effort. A
relatively small upfront investment of time may have prevented difficulties later on in the process.
• Interviewees suggested that certain aspects of EPA's culture may be hindering effective collaboration.
One interviewee mentioned "micro-managing" by EPA management as an obstacle; another
interviewee felt that valuable EPP staff members were underappreciated by EPA management. We do
not have enough information to evaluate the validity of these comments, but we flag them here for
EPA's consideration.
• Several interviewees felt that EPP needed to focus on changing behavior, rather than tracking
compliance. Suggestions included building on the FEC model to further incentivize green purchasing
in a broader sense (i.e., beyond electronics); the Federal Green Challenge may address this comment.
Suggestions also include advocating for more federal purchases of green products beyond those
included in current federal regulations, which the Section 13 workgroup process is designed to
facilitate.
• The scope of our interviews generally did not allow us to identify missed opportunities where EPP
could have pursued a coordinated effort with another agency but did not do so, and our analysis is
limited in that respect. However, there is one exception. An overarching finding from our evaluation
of the EPP Program is that a lack of data tracking currently hinders green purchasing efforts
throughout the federal government, which is discussed in several other areas in this report. However,
DOE used its own Pollution Prevention Tracking and Reporting System for 14 years to track green
product purchases, and reportedly offered the data to both EPA and GSA, who declined it. As a result,
DOE stopped collecting these data in 2011. Note that the DOE staff person spoke to EPA staff that
were outside of EPP, and did not contact the EPP Program directly. Nonetheless, this represents a
missed opportunity that could have been avoided through stronger collaborations between EPP and
DOE and/or between EPP and other EPA offices.
QUESTION 8: FEDERAL ELECTRONICS CHALLENGE
Introduction
The Federal Electronics Challenge (FEC) is a voluntary partnership program for government agencies and
individual facilities. Its aims are to encourage its participating partners to purchase environmentally
preferable electronics; reduce the environmental impacts of electronics while in use; and manage the
disposal of electronics safely at the end of their useful life. FEC focuses on a defined group of widely-
used electronics products, including desktop and laptop computers, monitors, and printers." Other
electronic products, such as televisions and mobile devices, may be added to the program in the future.
In 2010, the program results that FEC submitted to the Pollution Prevention Division (PPD) showed a
substantial downturn in energy savings and greenhouse gas emissions reductions between 2009 and 2010.
' See http://www.federalelectronicschallenge.net/
3-57
-------
FEC had reported energy savings of approximately 1,684 billion BTUs in 2009; in 2010, it reported
approximately 1,087 billion BTUs in energy savings - a 35% decrease. The downturn came from a 32%
decrease in energy savings from power management activities and a 37% decrease in energy savings from
end-of-life management.
lEc's analysis of the FEC, motivated by this circumstance, is designed to answer the following evaluation
question:
8. The Federal Electronics Challenge, a key EPP priority area, has reported an apparent decline in
energy savings from 2009 to 2010. Is this decline in reported energy savings indicative of backsliding
on energy savings behavior reported to FEC?
a. If yes, why has backsliding occurred?
b. If yes, what changes are needed within FEC to address backsliding?
Key Findings
Our analysis focused on the downturn in energy savings we would we have seen from 2009 to 2010, if we
measured only the changes in the specific behaviors that FEC is trying to promote: proportional rates of
Energy Star-enabling during use, and reuse at end of life. Combining the results of the power
management and end-of-life analyses, we find that rather than the 35% decrease reported, this alternative
means of evaluating the data would show a drop in energy savings of about 6.1%. This 6.1% downturn
was driven almost entirely by a decline in FEC partners' rate of reuse of computers (but not monitors) at
end of life.
The much larger decline in FEC's results as reported to PPD is due to a number of factors:
• Anomalous data points, likely caused by human error in the reporting process, were responsible for a
modest proportion of the decline in the power management area.
• Fluctuations in which specific partners submitted data to FEC accounted for a large majority of the
downturn in the power management area. These fluctuations also contributed nearly half of the
decline in the end-of-life area.
• Variations in the overall number of electronics products in the system - regardless of what
environmental steps were being taken - were responsible for a sizable portion of the apparent
decrease.
• Actual backsliding, i.e., less environmentally preferable behavior, was a negligible factor in power
management. Backsliding was more evident in end-of-life, but this must be tempered by the fact that
lower rates of equipment reuse were partially balanced by higher rates of equipment recycling, the
benefits of which are awarded to ORCR, not FEC.
Due to the assumptions and uncertainties inherent in our analysis, which are discussed below in this
section, the quantified environmental benefits discussed in this analysis should be understood to be
approximations and not precise figures. Different assumptions would yield different results. See the
textbox at the end of this evaluation question for further details on calculations.
3-58
-------
Notes on this Analysis
This analysis is narrowly focused. It is not concerned with longer-term trends, e.g., in FEC's program
growth or reporting rates since its inception. The analysis is focused only on the benefits associated with
FEC's internal reporting: Energy Star-enabling of computer equipment (power management) and
equipment reuse at end-of-life.100 Moreover, the analysis also does not examine non-energy related
environmental benefits.
lEc obtained and reviewed FEC's database aggregating the information submitted by individual partners,
to investigate several factors that may have contributed to the apparent decrease in energy savings.
Potential contributing factors include backsliding (i.e., FEC partners engaging in less environmentally-
friendly activity); reduced use of electronics equipment in 2010 compared to 2009 (simply using fewer
pieces of equipment); fluctuations in which specific facilities reported results; and human error in
reporting or tabulating results. Our results, detailed below, indicate that each of these factors impacted
FEC's bottom-line results. However, our key finding is that the vast majority of the apparent decline was
due to 1) reduced use of electronics equipment, and 2) fluctuations in which facilities reported results in
each year. Only a small portion of the decline in energy savings behavior reported by FEC from 2009 to
2010 was actually due to backsliding by FEC partners. The magnitude of the decline due to backsliding is
sufficiently small that no major changes to the FEC program are warranted. Different measures of the
available data yields very different results, and strongly indicate that FEC's actual performance was not as
poor in 2010 as the reported results would suggest.
Overview of FEC Activities
FEC engages in a variety of activities to achieve its goals. It provides technical assistance to assist its
partners in reducing electronics-related environmental impacts. It also serves as a forum to exchange
information and resources (for both partners and non-partners). In addition, FEC partners can apply for
awards, which give their efforts greater visibility and provide an incentive to undertake more aggressive
efforts. The award application includes a menu of optional activities for the applicant to choose from,
promoting environmental stewardship beyond the basic activities expected of every FEC partner. For
FY2010, FEC recognized seven platinum-level award winners, four gold-level winners, 12 silver-level
winners, and 16 bronze-level winners.
FEC partners are, by and large, individual facilities, but two federal agencies (the Departments of
Education and Transportation) with centralized procurement and IT management functions are FEC
agency partners and report aggregate data covering all of their facilities.101 FEC partners are strongly
encouraged to submit information tracking their performance on an annual basis, using a standardized
reporting form. FEC program staff review this data, consult with partners to address suspicious data
points, aggregate data across all partners reporting in that year, and use the Electronics Environmental
100 FEC now also includes results for life extension, i.e., using products for a longer time before disposing of them. However, this activity was not
included in FEC's reported 2009 or 2010 results. For that reason, we do not consider it in our analysis.
101 lEc considered the potential issue of agency partners having internally inconsistent data that would skew FEC's results. If these agencies would
have to gather data from each of their individual facilities but report only aggregate data to FEC, then FEC would have no readily available means
to determine whether the partners had any nonresponsive facilities in any given year. Thus, FEC would have no way of knowing whether any year-
to-year fluctuations in results for these partners were driven by actual changes in behavior or simply by inconsistent reporting. However, because
the relevant functions at FEC's two agency partners are performed in a centralized manner, the necessary data is held at the agency level and
does not need to be collected from individual facilities. Thus, the two agency partners present no added difficulties for FEC to validate data.
3-59
-------
Benefits Calculator (EEBC) to translate the
data reported by FEC partners into estimated
environmental benefits for the year.
Historically, reporting has been voluntary,
meaning that membership in the FEC has not
been contingent on consistent reporting.
However, as of 2012, partners must submit
their results or face expulsion from the
program.
There are several activities that FEC partners
report on, including:
• Use of an Environmental Management
System (EMS)
• Purchase of EPEAT electronics
• Use of Energy Star power management
features on computers and monitors
• Lifespan of desktop computers
• Default use of double-sided printing
• End-of-life management, including reuse,
recycling, landfill/incineration, and
unknown disposition/sales
Federal Electronics Challenge
Baseline Survey and
Annual Reporting Form
Updated; B/9/2011
SECTION 2: ACQUISITION & PROCUREMENT
1. How many electronic products purchased, leased, and/or provided under seat
management were, or were not, EPEAT registered?
Desktop computers
Cathode ray tube (CRT) monitors
Liquid ciysta! display (LCD) monitors
Laptop/ notebook computers
Printers'
Multifunction devices {MFDs}*
Televisions"
Servers*
Cellular/mobile telephones1
Personal digital assistants (PDAs)-
Number of
EPEAT
registered
units
(Bronze)
Number of
EPEAT
registered
units
(Silver)
Number of
EPEAT
registered
units
(Gold)
Number of
units not
EPEAT
registered
"Reporting acquisition information for these products is optional for partners completing
this form for annual reporting.
SECTION 3: OPERATION & MAINTENANCE
1. How many computers and monitors are in use at your organization?
Desktop computers
CRT Monitors
LCD Monitors
Laptop/notebook computers
2. Are ENERGY STAR® power management features enabled on non-exempt computers
(desktops and laptops/notebooks) and/or monitor at your organization?
D Yes
Estimated percentage of enabled non-exempt monitors: %
Estimated percentage of enabled non-exempt computers: _
D No
D Don't Know
A page from FEC's Annual Reporting Form
While FEC reports the environmental benefits generated by all of these activities (to the extent possible)
in its publicly-available annual accomplishments summaries, only a subset of the benefits are attributed to
FEC when the program internally reports its contributions toward EPA's Strategic Goals. For example,
EPEAT sales are attributed to the EPEAT program, and recycling at end of life is attributed to ORCR;
benefits from these activities are excluded from FEC's results. Exhibit 3-37 summarizes FEC's handling
of the various categories of environmental benefits relating to its program activities. As shown in the
table, FEC gets internal credit only for Energy Star-enabling of computer equipment (power management)
and equipment reuse at end-of-life.
Power Management
Energy savings from power management are calculated in a three-step process. First, FEC partners report
on the total number of desktop computers, laptops, and CRT and LCD monitors in use at their
organization. They then estimate the percentage of monitors and computers for which Energy Star power
management features are enabled. Finally, FEC program staff multiplies the number of products in use by
the proportion that is Energy Star-enabled, and uses the EEBC to translate those figures into
environmental benefits.
3-60
-------
EXHIBIT 3-37. TREATMENT OF ENVIRONMENTAL BENEFITS FROM ACTIVITIES TRACKED BY FEC
ACTIVITY TRACKED BY FEC
Environmental Management
System (EMS)
EPEAT purchases
Energy Star-enabling (power
management)
Lifespan extension
2-sided printing
Equipment reuse at end of life
Equipment recycling at end of life
Unknown disposition, sales,
landfill, or incineration of
equipment at end of life
TREATMENT OF ENVIRONMENTAL BENEFITS
ATTRIBUTED
TO FEC
X
X
ATTRIBUTED
ELSEWHERE
X
X
X
NOT
CALCULATED
X
X
X
X
NOTES
Not included in EEBC.
Attributed to EPEAT; benefits
remain within EPP.
FEC claims benefits of Energy
Star-enabling above assumed
default enabling rate;
benefits of default level of
Energy Star-enabling accrue
to Energy Star.
FEC started measuring
benefits of lifespan extension
starting in 2011 . Thus, these
benefits are excluded from
I EC'S analysis.
Not included in EEBC.
Attributed to ORCR; benefits
do not remain within EPP.
No benefits assumed in EEBC.
The first step in the analysis was to search for anomalous data points. lEc identified eight facilities with
abnormal results, relating to dramatic changes in the proportion of Energy Star-enabled equipment.102
Working with the FEC coordinator, lEc contacted the partners involved to request confirmation or
correction of the anomalous data points. In three cases, partners responded with corrected information,
which we used in our analysis. One partner confirmed that the suspicious data point was, in fact, correct.
The remaining four did not respond to our request for information. We removed the data from these four
facilities from our analysis.103
102 In addition to the eight facilities noted here, results for the Department of Energy headquarters also appeared anomalous on initial review. DOE
showed a huge increase in the number of electronics units in use from 2008 to 2009, with a return to prior levels in 2010. For example, PCs in use
jumped from 5,700 in 2008 to 126,977 in 2009 before dropping back to 5,700 in 2010. However, the FEC coordinator had already investigated and
validated these figures when they were provided in 2009. In that year, DOE had aggregated results for several (though not all) of its FEC partner
facilities, and reported all of these as belonging to the Headquarters facility. Thus, while the facility-level results for DOE Headquarters (as well
as the other DOE facilities involved) were incorrect for 2009, the overall results across all DOE facilities were accurate. We have therefore
retained all of these facilities in our reported results.
103 These four facilities accounted for 3.8% of Energy Star-enabled monitors in 2009 and 1.1% in 2010, and 7.7% of Energy Star-enabled computers in
2009 and 3% in 2010.
3-61
-------
Exhibit 3-38 shows the total number of pieces of electronics equipment in use among reporting FEC
partners in 2009 and 2010, as originally reported and then excluding the questionable data points just
noted. These figures reveal an obvious pattern: total electronics equipment use among all reporting
partners dropped substantially from 2009 to 2010. The number of PCs in use dropped by more than 20%,
while the decline in monitor use was even steeper.
EXHIBIT 3-38. ELECTRONICS IN USE AND ENERGY STAR ENABLING AMONG FEC PARTNERS
MONITORS
2009
2010
CHANGE
COMPUTERS
2009
2010
CHANGE
TOTAL
2009
2010
CHANGE
As reported
Partners
reporting
Total units in
use
130
977,199
109
659,672
-16.2%
117
-32.
929,953
102
734,208
-12.
-21.0%
1,907,152
1,393,880
-26.9%
Energy Star-
enabled units
in use
932,727
542,974
-41.
484,201
358,904
-25.9%
1,416,928
901,878
-36.3%
Excluding anomalous data points
Partners
reporting
Total units in
use
127
937,642
106
614,951
-16.5%
113
-34.^
883,407
98
673,584
-13.
-23.J
1,821,049
1,288,535
-29.2%
Energy Star-
enabled units
in use
897,040
536,932
-40.1%
446,721
357,983
-19.9%
1,343,761
894,915
-33.^
It is important to consider the implications of these data. If FEC partners had continued to enable Energy
Star settings at the same rate in 2010 as in 2009, FEC's results would still reflect this as a decrease in
energy savings behavior, corresponding exactly to the drop in total equipment use. Yet this would not
actually reveal anything about the FEC program's effectiveness in reducing the environmental impact of
its partners, because a facility's decisions about how many computers and monitors to use is unrelated to
FEC's aims. Thus, a tension exists between the way in which FEC reports its results and the actual
environmental benefits it is seeking. For this reason, a more meaningful metric for FEC's success is
the proportion of all computers and monitors at FEC partner facilities that are Energy Star-
enabled. We have included this measure in Exhibit 3-39.
Excluding the anomalous data points noted above, while Energy Star-enabling of monitors dropped
somewhat from 2009 to 2010, the enabling rate for computers increased. Because we are dealing with
proportions and not absolute numbers for the reasons just articulated, we cannot translate this precisely
into environmental benefits. However, as an approximation, we can estimate the environmental benefits
that would result from these changes in enabling rates, //the total number of products in use remained
constant at 2009 levels. Using the EEBC, we find that these enabling rates would have resulted in a 1.5%
3-62
-------
increase in environmental benefits from 2009 to 2010.104 That is to say, the environmental gain from
improved Energy Star enabling in computers in 2010 more than offset the lower rate of Energy
Star enabling in monitors.
EXHIBIT 3-39. PERCENTAGE RATES OF ENERGY STAR ENABLING AMONG FEC PARTNERS
As reported
Excluding
anomalous data
points
MONITORS
2009
95.4%
95.7%
2010
82.3%
87.3%
%
CHANGE
-13.1%
-8.4%
COMPUTERS
2009
52.1%
50.6%
2010
48.9%
53.1%
%
CHANGE
-3.2%
2.5%
TOTAL
2009
74.3%
73.8%
2010
64.7%
69.5%
%
CHANGE
-9.6%
-4.3%
Much of the decrease in the number of products in use is driven by differences in which FEC partners
reported in which specific years. Reporting rates dropped between 2009 and 2010. In 2009, 130FEC
partners reported results for Energy Star-enabling of monitors, while 117 reported on Energy Star-
enabling of computers. In 2010, 109 and 102 partners reported results on monitors and computers,
respectively. Further complicating matters, only 96 and 85 partners reported results consistently in both
years for monitors and computers, respectively (Exhibit 3-40); several partners reported only in one year
or the other.
To explore the magnitude of the effect of these reporting differences on FEC's bottom-line results, we
examined trends among those facilities that reported in both years, i.e., excluding facilities that reported
only once in 2009 - 2010 (see Exhibit 3-40).105 Key results from those facilities are as follows:
• The number of products in use dropped substantially from 2009 to 2010. This indicates that a
substantial portion of the apparent downturn in energy savings is likely due to individual facilities
using fewer pieces of electronics equipment.
• 85.6% of all monitors in use were Energy Star-enabled in 2009. An essentially equivalent 85.4% were
Energy Star-enabled in 2010.
• In both 2009 and 2010, 53.1% of all computers in use were Energy Star-enabled.
• Again, we cannot translate this precisely into environmental impacts. However, if we hold the total
number of products in use constant at 2009 levels, the slight decline in Energy Star enabling would
have resulted in a decrease in energy savings of only 0.1%.
Comparing these results to those of all FEC partners, it becomes clear that the population of FEC partners
reporting only in 2009 does not match closely with the population as a whole, in ways that heavily
influenced the program's overall results. Partners that reported only in 2009 had higher rates of Energy
This process is described in more detail later in this analysis.
105 Because the evaluation question being addressed concerns only 2009 and 2010, facilities that did not report in either year have no impact on our
analysis.
3-63
-------
Star enabling for monitors (though somewhat lower enabling rates for computers), and, more importantly,
more electronics units in use per facility. Partners reporting only in 2010 were more characteristic of the
population as a whole. This means that the failure of many partners that reported in 2009 to report again
in 2010 accounts for a substantial part of the drop-off in observed energy savings.
EXHIBIT 3-40. ELECTRONICS IN USE AND ENERGY STAR ENABLING AMONG FEC PARTNERS
REPORTING IN BOTH YEARS
Partners
reporting
Total units
in use
% Energy
Star-
enabled
Energy Star-
enabled
units in use
MONITORS
2009
96
555,705
85.6%
475,877
2010
96
507,896
85.4%
433,516
%
CHANGE
N/A
-8.6%
-0.2%
-8.9%
COMPUTERS
2009
85
672,015
53.1%
357,175
2010
85
558,964
53.1%
296,876
%
CHANGE
N/A
-16.8%
0.0%
-16.9%
TOTAL
2009
1,227,720
67.9%
833,052
2010
1,066,860
68.5%
730,392
%
CHANGE
-13.1%
0.6%
-12.3%
Exhibit 3-41 shows how each of the factors discussed above - anomalous data points, reporting
fluctuations, decreased equipment use, and backsliding - contributed to the decrease in the number of
Energy Star-enabled products at reporting FEC facilities. The same basic pattern would hold true for the
downturn in reported energy savings, although there may be some minor differences in the exact
numbers.106 Only a miniscule portion of the observed decline was due to backsliding. The remainder was
caused by other factors.
We cannot definitively state that the patterns noted above for facilities reporting in both years (i.e.,
minimal change in rates of Energy Star-enabling, coupled with a modest decrease in the total number of
units in use) would also hold true for the entire universe of FEC partners, for the simple reason that there
are many FEC partners whose actual results we cannot observe for 2010 (since they did not report any
results). 96 partners reported results for monitors in both years; this represents 76% of all facilities
reporting in 2009, and 91% of facilities reporting in 2010. Similarly, 85 partners reported results for
computers in both years, accounting for 75% of all facilities reporting in 2009 and 87% of facilities
reporting in 2010. If the facilities excluded from this calculation had different characteristics from the
ones that were included, then our estimated results may be inaccurate. However, the relatively high
proportion of facilities reporting in both years suggests that the overall pattern would not change too
drastically if we had data for these other facilities that we could include in our analysis.
106 Because per-unit environmental benefits vary by equipment type (CRT monitors, LCD monitors, desktop computers, and laptops), the overall
change in environmental benefits across all equipment types would be slightly different from the change in the numbers of Energy Star-enabled
units across all equipment types.
3-64
-------
EXHIBIT 3-41. FACTORS CONTRIBUTING TO THE DECREASE IN ENERGY STAR-ENABLING OF
ELECTRONICS PRODUCTS AMONG FEC PARTNERS FROM 2009-2010
0.3%
I Reporting fluctuations
I Decreased equipment use at partners reporting
in both years
I Anomalous data points
I Backsliding at partners reporting in both years
We also cannot conclusively state that the 'actual' backslide in energy performance among the entire
universe of FEC partners was only 0.1%. Nonetheless, //the same trends held true for non-reporting
facilities as for reporting facilities, the observed downturn in energy savings from power management
activities would disappear almost entirely. As noted above, a relatively high proportion of FEC partners
reported in both years, giving us confidence that the overall result for all FEC partners would likely not be
dramatically different. While the precise result (which is unknowable) may be slightly different, this
analysis clearly indicates that FEC's performance in the area of power management was not nearly as
poor as the numbers reported to PPD suggest.
End of Life
The second area in which FEC reported results in 2009 and 2010 was end of life. The process for
calculating benefits from end of life is similar to power management. FEC partners report on the total
number of desktop computers, laptops, and CRT and LCD monitors in their facilities that reached the end
of their life in the past year. They then estimate the percentages that were disposed of through reuse,
recycling, landfill and incineration, and unknown disposal. FEC program staff multiplies the number of
items being disposed of by these proportions, and uses the EEBC to calculate environmental benefits.
FEC claims environmental benefits only for products that are reused. The benefits of recycled electronics
are attributed to ORCR. Electronics that are sent to landfill or that have unknown disposal are considered
not to generate any environmental benefits. FEC began tracking end-of-life treatment for printers in 2010,
but because there is no comparable data for 2009, we exclude printers from our analysis and evaluate only
monitors and computers.
There are three factors that contributed to the downturn in reported energy savings from 2009 to 2010:
• Differences in which specific facilities reported results;
• A lower number of electronics products reaching their end of life; and
3-65
-------
A lower proportion of electronics being reused at end of life.1
In addition, the fact that recycling benefits are attributed to ORCR further complicates matters, in that
gains in one environmentally preferable means of disposal may come at the expense of another.
As with the power management area, there is a disconnect between what FEC reports and what
constitutes an actual environmental good in end-of-life disposal, which distorts measures of the program's
effectiveness. The number of products reaching the end of their useful lives does not tell us anything
about FEC's effectiveness in encouraging partners to reuse or recycle electronics rather than disposing of
them in a landfill.108 However, the number of products reaching end of life directly affects how FEC
calculates its results. The proportion of end-of-life electronics being reused is a better metric of FEC's
effectiveness than the absolute number of electronics being reused, since it would better illustrate how
FEC partners are changing their behavior.
Exhibits 3-42 and 3-43 characterize end-of-life treatment for all reporting FEC partners in 2009 and 2010.
Note that there was a 26% decrease in the total number of electronics products reaching their end-of-life
in 2010. The proportion of products being reused dropped slightly, from 43.5%to 41.5% (Exhibit 3-43).
Recycling increased from 38.9% to 47.4%, but as noted above, EPA attributes this to ORCR, not EPP.
EXHIBIT 3-42. ELECTRONICS REACHING END OF LIFE AMONG FEC PARTNERS
Partners
reporting
Units reaching
end of life
Reused units
Recycled units
MONITORS
2009
100
93,906
35,394
40,078
2010
92
52,927
20,826
25,034
%
CHANGE
-8.0%
-43.6%
-41 .2%
-37.5%
COMPUTERS
2009
109
189,535
87,941
70,205
2010
97
146,611
62,057
69,452
%
CHANGE
-11.0%
-22.6%
-29.4%
-1.1%
TOTAL
2009
283,441
123,335
110,283
2010
199,538
82,883
94,486
%
CHANGE
-29.6%
-32.8%
-14.3%
Again, we examined data for the subset of facilities that reported results in both years, to explore the
impact of year-to-year differences in reporting activity (Exhibit 3-44). Results for these facilities were as
follows:
• The total number of units reaching end-of-life dropped by 18.8%. This indicates that a substantial
portion of the apparent downturn in energy savings is likely due to facilities extending the lifespan of
their electronics equipment, and/or normal fluctuations in cycles of electronics procurement and
disposal.
IEc did not find any anomalous data points among the individual FEC partners reporting results in the end-of-life area.
108 However, the number of products reaching end of life may indirectly point to an environmental benefit from FEC partners deferring the disposal
(and presumably, the replacement) of electronics by keeping them in use for a longer period of time. Starting in 2011, FEC has tracked these
benefits through another metric, namely, the average lifespan of computers in use at partner facilities.
3-66
-------
EXHIBIT 3-43. PERCENTAGE RATES OF REUSE AND RECYCLING AT END OF LIFE AMONG FEC
PARTNERS
% Reused
% Recycled
MONITORS
2009
37.7%
42.7%
2010
39.3%
47.3%
%
CHANGE
4.4%
10.8%
COMPUTERS
2009
46.4%
37.0%
2010
42.3%
47.4%
%
CHANGE
-8.8%
27.9%
TOTAL
2009
43.5%
38.9%
2010
41.5%
47.4%
%
CHANGE
-4.5%
21.7%
• Reuse of monitors increased from 2009 to 2010, but this was more than offset by a decline in reuse of
computers. Combined, the rate of reuse dropped from 43.5% to 38.5%, but recycling increased
dramatically, from 37% to 51% (Exhibit 3-44).
• As before, we cannot translate these numbers precisely into environmental benefits without adopting
some additional assumptions. Nonetheless, //we hold the overall number of products reaching end-of-
life constant at 2009 levels, a drop from 43.5% to 38.5% reuse would result in a 10% decrease in
energy savings from reuse from 2009 to 2010, rather than the 37% decrease reported by FEC.109
EXHIBIT 3-44. ELECTRONICS REACHING END OF LIFE AMONG FEC PARTNERS REPORTING IN BOTH
YEARS
Partners
reporting1
Units reaching
end of life
% Reused
% Recycled
Reused units
Recycled units
MONITORS
2009
73
45,867
23.1%
42.8%
10,609
19,647
2010
73
29,716
31.1%
53.8%
9,227
15,990
%
CHANGE
N/A
-35.2%
34.2%
25.6%
-13.0%
-18.6%
COMPUTERS
2009
61
123,269
51.1%
34.8%
62,944
42,869
2010
61
107,578
40.6%
50.2%
43,642
53,999
%
CHANGE
N/A
-12.7%
-20.6%
44.3%
-30.7%
26.0%
TOTAL
2009
169,136
43.5%
37.0%
73,553
62,516
2010
137,294
38.5%
51 .0%
52,869
69,989
%
CHANGE
-18.8%
-11.5%
37.9%
-28.1%
12.0%
The main difference between facilities reporting in both years and those reporting only in 2009 were that
the consistent reporters had much lower monitor reuse rates. This contributed to the observed downturn in
energy saving behavior from 2009 to 2010. Other differences between the two groups were less dramatic.
' This was calculated via a similar process to that noted above for power management.
3-67
-------
Exhibit 3-45 shows how reporting fluctuations, fewer products reaching end of life, and lower rates of
reuse (i.e., backsliding) each contributed to the decrease in the overall number of products being reused.
Again, the same basic pattern would hold true for the decrease in reported energy savings, but the exact
numbers would be slightly different due to the differing environmental characteristics of the various
product groups.
Backsliding, as opposed to other factors, is a more significant contributor to the observed decline in end
of life than was the case for power management activities. Even so, only about 22% of the decline was
due to backsliding. It is also important to emphasize that 'backsliding,' in this context, does not account
for the substantial increase in electronics recycling, the benefits of which accrue to ORCR instead of FEC.
The estimated 10% decrease in environmental benefits noted above (i.e., the decrease due to backsliding
among partners reporting in both years) would only be a 7.5% decrease if benefits from recycling were
included in FEC's results.
EXHIBIT 3-45. FACTORS CONTRIBUTING TO DECREASE IN REUSE OF ELECTRONICS PRODUCTS AT
END OF LIFE AMONG FEC PARTNERS
I Reporting fluctuations
Decreased equipment reaching end of life at partners reporting in both years
I Backsliding at partners reporting in both years
3-68
-------
Details On Calculations Used In This Analysis
The hypothetical energy savings downturn of 6.1% was estimated in the following manner:
• First, we used the Electronics Environmental Benefits Calculator to estimate the marginal energy savings
associated with a single piece of equipment of each type going through each of the treatments tracked
by FEC. For instance, we evaluated the benefits of a single Energy Star-enabled desktop computer, a
single LCD monitor being reused at end of life, etc. In estimating per-unit benefits, we assumed that all
EPEAT electronics were certified at the silver level, which is the default used in the EEBC.
• We then multiplied the per-unit benefits in each category by the total number of products in that
category in 2009 among those facilities reporting in both years. This gives us an estimate of the total
energy benefits accruing to the consistently reporting FEC partners in 2009.
• For each category, we multiplied the estimated total benefits in 2009 by the relevant proportional
measures for 2010 and 2009 described above in the main body of the report. For example, for reuse of
monitors, we multiplied 2009 results by 31.1% T 23.1% = 1.346. The interpretation of this step is that
among consistently reporting FEC partners, in 2010, there was a 34.6% increase in the proportion of
monitors being reused. Note that in this step, we used aggregated (weighted) proportions combining
both desktop and laptop computers, and both CRT and LCD monitors.
• Finally, we summed benefits across all categories to arrive at a total for 2010, and compared this to the
estimate for 2009 to determine the extent of the 2009-2010 downturn.
Several factors introduce uncertainty and imprecision into this analysis, including the use of EPEAT silver as a
default, rather than analyzing all EPEAT levels individually; the aggregation of desktop and laptop computers,
and CRT and LCD monitors; and the assumption that non-consistently reporting partners follow the same
patterns as consistently reporting partners. Thus, our numerical result should be considered approximate,
not definitive. Even so, the evidence is clear enough to support the findings.
QUESTION 9: FEDERAL ELECTRONICS CHALLENGE AND EPEAT PURCHASES
Introduction and Key Findings
As discussed above, the Federal Electronics Challenge (FEC), a voluntary partnership program for federal
facilities and agencies, promotes a variety of environmentally-motivated activities among its members,
and tracks data on those partners' performance. While FEC does not receive credit for all of these
activities when reporting program results to PPD, the program may nonetheless be an important means of
driving more environmentally-conscious behavior even in areas for which it does not officially receive
credit.
One area that FEC addresses, but for which the program does not receive credit, is encouraging the
purchase of EPEAT-registered electronics by federal agencies. Because this is an important aspect of
FEC's efforts, Evaluation Question 9 asks, "How effective is the FEC's voluntary approach in promoting
purchases of EPEAT-labeled electronics among federal agencies?"110
110 In our methodology report, this evaluation question was worded to explore the FEC's "voluntary reporting approach." We have dropped the word
"reporting" from the question to emphasize that we are examining the overall effectiveness of the FEC program, rather than its reporting aspect
in particular. As noted in our analysis of Evaluation Question 8, FEC engages in a variety of activities, including technical assistance, information
exchange, and awards in addition to progress reporting.
3-69
-------
Overall, we found strong, albeit indirect, evidence that FEC partners did purchase EPEAT electronics at
higher rates than the rest of the federal government: Our main findings for this evaluation question are as
follows:
• FEC partners had relatively high rates of EPEAT purchases in all years, from a low of 80.9% in 2007
to a high of 96.4% in 2009.
• FEC's proportion of total federal EPEAT purchases is shrinking over time, implying that the rest of
the federal government is catching up to the high bar set by FEC early on.
• FEC partners accounted for more purchases of EPEAT monitors in 2008 than the entire rest of the
federal government.
• Most importantly, if we make two key assumptions - that FEC is doing no worse than the rest of the
federal government at purchasing EPEAT electronics, and that FEC provides a reasonable proxy for
the whole federal government with respect to total (EPEAT and non-EPEAT) electronics - the data
indicate that FEC purchased EPEAT products at higher rates than the rest of the federal government
in the early years of the program. This suggests that FEC partners were early adopters of EPEAT.
However, the disparity between the FEC and the rest of the federal government has lessened over
time. We cannot evaluate whether FEC is still purchasing proportionally more EPEAT products than
the rest of the government.
• A relatively high number of federal facilities participate in the FEC program compared to other
voluntary environmental programs. FEC partners also account for a significant fraction of all federal
EPEAT purchases. Thus, FEC has also been successful in terms of its overall reach.
• Finally, although not directly related to this evaluation question, we note that FEC partners have
shifted decisively from predominantly silver to gold certified EPEAT products, which are more
protective of the environment.
The data available and methods used in this analysis do not allow us to establish causation, so we cannot
state with complete certainty that the FEC program was effective in promoting purchases of EPEAT
products. Nonetheless, the results are consistent with the presence of an "FEC effect," and provide strong
evidence that membership in the FEC is correlated with more EPEAT purchases. At least a portion of this
effect is likely a product of selection bias, wherein federal facilities that were more predisposed to
purchase EPEAT products opted in to the FEC. However, given the fact that promoting EPEAT purchases
is one of FEC's core goals, it seems likely that at least some of the observed difference between FEC
partners and other federal facilities is attributable to the influence of the FEC program. We therefore
conclude that the FEC's voluntary approach has likely been effective in promoting EPEAT purchases
among federal agencies.
Electronics Purchase Data
To answer this question, lEc compared EPEAT purchase data for FEC partners to data for the entire
federal government. The FEC data was compiled from data provided to FEC by its individual partners, as
discussed in our analysis of Evaluation Question 8 above. We obtained government-wide purchasing data
from the Green Electronics Council (GEC), the organization which manages the EPEAT program; GEC,
in turn, collected this data through the Information Technology Industry Council (ITI). Because the
3-70
-------
government-wide data covers only the years 2008-2010, our analysis focuses predominantly on those
years.
lEc also obtained data on government-wide electronics purchases from the Office of Management and
Budget (OMB), which collects this data to report on federal agencies' progress toward meeting the
sustainable purchasing goals laid out in Executive Order 13514. However, as noted in our discussion of
Evaluation Question 3, our review of the OMB data revealed several issues that led us to question its
accuracy.111 Thus, we have chosen to use GEC's data for this analysis, notwithstanding several
methodological challenges that we face in relying on that data (discussed below).
The clearest way to measure the FEC's effectiveness in promoting EPEAT purchases would be to
compare FEC partners' share of electronics purchases that are EPEAT-registered to the proportion for the
federal government as a whole (excluding FEC partners). However, with the exception of the
questionable OMB data, we were unable to find information on the total number of computers and
monitors purchased by the federal government in any given year, and as a result, we cannot determine
how the federal government's EPEAT purchases may compare to total electronics purchases. Thus, we
can only provide indirect evidence of the FEC's effectiveness.
To provide greater consistency from year to year, in this analysis we exclude data from FEC partners that
reported data in only one year from 2008 - 2010, and instead use data from FEC partners that reported in
at least two of these three years. All reported FEC data reported in this section reflects this convention
unless otherwise noted. This has only a relatively small effect on our overall numbers; excluded facilities
accounted for just 0.9% of all FEC electronics purchases in 2008, 5.5% in 2009, and 18.2% in 2010. In
addition, unless otherwise noted, we also exclude all FEC purchases when reporting data for the federal
government, so that our comparison is between FEC partners and all other federal facilities.
The starting point for this analysis is data on total (EPEAT and non-EPEAT) electronics purchases by
FEC partners and EPEAT purchases for the rest of the federal government. Exhibit 3-46 provides this
data for the FEC, excluding those facilities that reported data in only one year. Data for the federal
government is shown in Exhibit 3-47.
Note that FEC partners' purchases of EPEAT monitors in 2008 were greater than the purchases made by
the rest of the federal government (Exhibit 3-48). We will return to this point later.
111 To briefly recap the issues raised on this subject in our analysis of Evaluation Question 3, the specific points that cast doubt on the accuracy of
OMB's federal purchasing data include the following:
1) FEC partners reported more purchases of non-EPEAT products in absolute numbers than are shown for the entire federal government in the
OMB data.
2) The federal government's proportion of EPEAT vs. non-EPEAT purchases is suspiciously high, particularly in comparison to the FEC reporting.
3) GEC reports total EPEAT sales to the federal government two to five times the numbers reported by OMB (varying by year and product
category).
4) As reported, the OMB data suggest that in 2009, FEC facilities accounted for 78.5% of the federal government's total electronics purchases.
(For 2010, the figure was 31.5%.)
All in all, these points strongly suggest that OMB's data on EPEAT vs. non-EPEAT purchases by the federal government is significantly flawed.
3-71
-------
EXHIBIT 3-46. ELECTRONICS PURCHASES AMONG FEC PARTNERS
Desktops
Monitors
Laptops
Total
2007
EPEAT
71,329
64,416
2,921
138,666
NOT
EPEAT
12,438
11,334
0
23,772
2008
EPEAT
88,851
99,131
30,886
218,868
NOT
EPEAT
9,851
11,367
7,940
29,158
2009
EPEAT
197,566
228,273
91,030
516,869
NOT
EPEAT
6,085
10,737
2,554
19,376
2010
EPEAT
73,612
66,506
60,997
201,115
NOT
EPEAT
6,025
11,540
1,503
19,068
EXHIBIT 3-47. EPEAT PURCHASES FOR THE FEDERAL GOVERNMENT
Desktops
Monitors
Laptops
Total
2008 EPEAT
488,197
81,939
181,013
751,149
2009 EPEAT
948,542
893,104
547,795
2,389,441
2010 EPEAT
428,002
N/A1
487,662
915,664
1 Reported sales of EPEAT monitors in 2010 were 7,823,459; GEC staff consider this data point
unreliable, but have been unable to obtain corrected data. (That level of purchases would
provide more than two monitors for every federal employee.) We therefore exclude this data
point from our analysis.
EXHIBIT 3-48. EPEAT MONITOR PURCHASES, 2008
99,131
81,939
FEC
Federal government (excluding FEC)
3-72
-------
An obvious question is how FEC's growth rates in EPEAT purchases compares to the federal
government's. To illustrate these growth rates, we set EPEAT purchase levels in 2008 (the first year for
which we have complete data) equal to 1.0, and then show how purchase levels in subsequent years
compare to that baseline. The results are shown in Exhibits 3-49 and 3-50.
Broadly speaking, the data for both FEC and the federal government indicate sharp increases in EPEAT
purchases in 2009, followed by declines in 2010. However, as shown in Exhibits 3-49 and 3-50, the
federal government ended at a higher point relative to the 2008 baseline than did FEC in the two
categories for which we have data (desktops and laptops). Furthermore, the sharp increase in EPEAT
monitor purchases for the federal government in 2009 - more than ten times the level from the year
before - suggests that the 2010 level for that product category was likely also higher for the federal
government than for FEC.
In short, the federal government's rate of increase in EPEAT purchases outstripped FEC's. This metric
therefore does not indicate that the FEC had a positive effect in promoting EPEAT sales. Yet as discussed
below, an alternative interpretation of this data, in conjunction with other figures, suggests otherwise.
EXHIBIT 3-49. EPEAT PURCHASES AMONG FEC PARTNERS (NORMALIZED TO 2008)
10 -
8 -
6 -
4 -
2
2008
•Desktops
2009
Monitors
2010
•Laptops
3-73
-------
EXHIBIT 3-50. EPEAT PURCHASES FOR THE FEDERAL GOVERNMENT (NORMALIZED TO 2008)
10 -
8 -
2008
•Desktops
2009
Monitors
2010
•Laptops
monitor sales in zuiu exciuaea aue to tne unreiiaoiuty or tne underlying data.
Proportional Levels of EPEAT Purchases and the 'Early Adopter' Hypothesis
The relative rates of increase in EPEAT purchases imply that the federal government as a whole is
making greater strides in this area than the FEC. But this fact on its own is not necessarily inconsistent
with the FEC demonstrating leadership in this area. FEC partner facilities were already relying heavily on
EPEAT electronics by 2008; it is possible that the rest of the federal government lagged the FEC as of
2008, and faster growth since then simply reflects them making up some of this lost ground. If that
premise is correct, the trends described above would indicate that the federal government is beginning to
catch up to the FEC, but not necessarily outperforming them in terms of the actual rates of purchases of
EPEAT vs. non-EPEAT electronics. Exhibit 3-51 translates the data from Exhibit 3-46 into proportions of
EPEAT and non-EPEAT purchases among FEC partners.
EXHIBIT 3-51. PROPORTIONS OF EPEAT AND NON-EPEAT PURCHASES AMONG FEC PARTNERS
Desktops
Monitors
Laptops
Total
2007
EPEAT
85.2%
85.0%
55.8%
80.9%
NOT
EPEAT
14.8%
15.0%
44.2%
19.1%
2008
EPEAT
90.0%
89.7%
79.5%
88.2%
NOT
EPEAT
10.0%
10.3%
20.5%
11.8%
2009
EPEAT
97.0%
95.5%
97.3%
96.4%
NOT
EPEAT
3.0%
4.5%
2.7%
3.6%
2010
EPEAT
92.4%
85.2%
97.6%
91.3%
NOT
EPEAT
7.6%
14.8%
2.4%
8.7%
3-74
-------
As noted previously, we do not have similar, reliable data for the federal government as a whole, making
an "apples-to-apples" comparison impossible. But certain other data strongly suggests that FEC facilities
likely purchased EPEAT electronics at higher rates in the earlier years than did the federal government.
For instance, FEC's share of the entire federal government's EPEAT purchases shrunk in every year from
2008 - 2010 (Exhibit 3-52).m
EXHIBIT 3-52. FEC SHARE OF TOTAL FEDERAL EPEAT PURCHASES
Desktops
Monitors
Laptops
Total
2008
15.4%
54.7%
14.5
22.5%
2009
17.1%
20.1%
14.1
17.C
FEC partners were purchasing EPEAT electronics in relatively high proportions in each of these three
years (80% or greater), yet their share of total federal government EPEAT purchases shrank. This implies
that the federal government as a whole began this period with more room for improvement. That is to say,
the federal government was likely starting from a lower base of proportional EPEAT purchases in 2008
than was the FEC, meaning that FEC partners were earlier adopters of EPEAT. If true, this would indicate
that the FEC program did have a positive impact in promoting EPEAT sales, but that the effect has
weakened over time. Such a phenomenon would not be surprising, since EPEAT electronics have gained
market share generally over this timeframe, and federal agencies have taken stronger steps to respond to
the EPEAT purchasing requirements of Executive Orders 13423 and 13514.
We can explore this hypothesis in greater detail by making two hypothetical assumptions:
1. FEC facilities are no worse than the rest of the federal government with respect to the proportion of
their electronics purchases that are EPEAT-registered. Put more concretely, this would mean that the
federal government's maximum proportions of EPEAT purchases in 2010 (the last year for which we
have data) would be equal to FEC's observed proportions. Given the FEC program's emphasis on
EPEAT purchases, this appears to be a sound proposition.
2. The universe of FEC facilities constitutes a reasonable proxy for the federal government as a whole
with respect to year-by-year trends in total electronics purchases (counting both EPEAT and non-
EPEAT products). FEC partners include hundreds of facilities across a broad swath of federal
agencies and departments, purchasing hundreds of thousands of electronics products each year and
representing a significant fraction of the entire federal government. Thus, this assumption also
appears to be reasonable as well, at least as an approximation.
112 Because this point considers FEC's contribution to total federal purchases, the data for the federal government used for these calculations does
not exclude FEC purchases, as is the case elsewhere in this analysis.
3-75
-------
If we accept those two assumptions, we can use 1) the government's actual EPEAT purchases in 2010;113
2) the presumed 'maximum' proportion of government EPEAT purchases in that year (based on the
proportion seen in the FEC data); and 3) the assumed trend in overall electronics purchases, to calculate
the highest possible proportion of EPEAT purchases the government could have achieved in 2008 and
2009 (again based on FEC data). The calculation steps required are somewhat complicated, so we
describe them in detail below.
• First, we apply FEC's proportions of EPEAT and non-EPEAT purchases in 2010 to the data on
federal government purchases, representing the best-case scenario for federal EPEAT purchases (per
assumption #1). This allows us to estimate federal purchases of non-EPEAT electronics in that year.
See Exhibit 3-53.
EXHIBIT 3-53. CALCULATION OF 2010 TOTAL PURCHASES
2010 EPEAT
PURCHASES
(OBSERVED)
2010 EPEAT
PROPORTION OF
TOTAL (BASED ON
FEC)
2010 NON-EPEAT
PURCHASES
(CALCULATED)
2010 TOTAL
PURCHASES
(CALCULATED)
Desktops
428,002
• We then multiply the calculated 2010 total government purchases by the ratio of FEC's 2009 total
purchases to its 2010 total purchases, as illustrated in Exhibit 3-54. This gives us estimated total
government purchases for 2009. Comparing these totals to the observed government EPEAT
purchases for that year, we can calculate the proportions of EPEAT versus non-EPEAT purchases for
the government in that year.
• Because the data point for 2010 federal monitor purchases was unreliable, we perform the same
calculation described above for computers in 2010 to estimate federal monitor purchases in 2009.
EXHIBIT 3-54. CALCULATION OF 2009 EPEAT PROPORTION OF PURCHASES
Desktops
Monitors
Laptops
2010 TOTAL
PURCHASES
(CALCULATED)
463,033
499,678
Total |
2009 TOTAL
SALES T- 2010
TOTAL SALES
(BASED ON FEC)
2.6
N/A
1.5
N/A
2009 TOTAL
PURCHASES
(CALCULATED)
1,184,087
935,112
748,190
2,867,389
2009 EPEAT
PURCHASES
(OBSERVED)
948,542
893,104
547,795
2,389,441
2009 EPEAT
PROPORTION OF
TOTAL
(CALCULATED)
80.1%
95.5%
73.2%
83.3%
113 Because the data point for EPEAT monitor purchases in 2010 is unreliable, we perform this analysis using the 2009 data point in that product
category.
3-76
-------
• We repeat this calculation to find the corresponding figures for 2008 (Exhibit 3-55).
EXHIBIT 3-55. CALCULATIONS OF 2008 EPEAT PROPORTION OF PURCHASES
Desktops
Monitors
Laptops
Total
2009 TOTAL
PURCHASES
(CALCULATED)
1,184,087
935,112
748,190
2,867,389
2008 TOTAL
SALES T- 2009
TOTAL SALES
(BASED ON FEC)
0.4
0.4
0.3
0.4
2008 TOTAL
PURCHASES
(CALCULATED)
516,606
387,844
246,929
1,151,379
2008 EPEAT
PURCHASES
(OBSERVED)
488,197
81,939
181,013
751,149
2008 EPEAT
PROPORTION OF
TOTAL
(CALCULATED)
94.5%
21.1%
73.3%
65.2%
• Finally, we compare the calculated EPEAT proportions of government purchases in each year to the
FEC proportions to determine the extent to which FEC over-performed (or under-performed) relative
to the rest of the government. See Exhibit 3-56.
EXHIBIT 3-56. FEC VS. FEDERAL GOVERNMENT EPEAT PURCHASES
EPEAT PROPORTION OF TOTAL PURCHASES
2008
2009
FEC (reported)
Desktops
Monitors
Laptops
Total
90.0%
89.7%
79.5%
88.2%
97.0%
95.5%
97.3%
96.^
Federal government (maximum; calculated)
Desktops
Monitors
Laptops
Total
94.5%
21.1%
73.3%
65.2%
80.1%
95.5%
73.2%
83.3%
FEC margin above federal government (minimum; calculated)
Desktops
Monitors
Laptops
Total
-4.5%
68.6%
6.2
23.0%
16.9%
O.C
24.1%
13.1%
2010
92.4%
85.2%
97.e
91.3%
If the starting assumptions for this calculation hold true, then the federal government had a maximum
proportion of EPEAT purchases of 65.2% in 2008 and 83.3% in 2009. These figures are well below the
FEC's observed rates of 88.2% and 96.4%, respectively. As we would expect, the margin between FEC
and the rest of the government shrank over time.
3-77
-------
It is important to reiterate that this calculation rests on the two critical assumptions noted above that,
while plausible, cannot be verified with the data on hand. As such, the numerical results should not be
interpreted literally. Nonetheless, they provide support for the contention that FEC facilities likely
purchased EPEAT electronics at proportionally higher rates than did other federal agencies in 2009 and
earlier. These data are exactly what we would see if FEC facilities were, in fact, early adopters of EPEAT
relative to the rest of the federal government. For that reason, this analysis strongly suggests that
membership in the FEC was correlated with an increased likelihood of purchasing EPEAT rather
than non-EPEAT electronics in the early years of the registry. However, the effect has lessened over
time. Note that while we have assumed for this analysis that the FEC is performing at least as well as the
rest of the federal government, we do not have sufficient data to determine whether FEC is continuing to
outperform the rest of the federal government.
As one other point of support for the early adopter argument, recall that FEC partners purchased more
EPEAT monitors in 2008 than did the rest of the federal government (99,131 versus 81,939). This is
reflected in the massive, 68.6% margin between the FEC's and the federal government's estimated rates
of EPEAT purchases shown in Exhibit 3-57. While we do not know the exact proportion of the federal
government that participated in the FEC in that year, it is certainly not a majority. At a minimum, then, it
seems safe to conclude that FEC facilities purchased EPEAT monitors at higher levels than other federal
facilities, even if the evidence for other EPEAT products is less direct.
FEC Program Participation
Determining how individual FEC program participants compare to non-participants with respect to
EPEAT purchases is a critical part of addressing this evaluation question. But to evaluate the FEC's
effectiveness in promoting EPEAT purchases among federal agencies, it is also important to consider the
overall reach of the FEC program, to determine whether it has been successful in enrolling a large number
of partners that constitute a significant portion of the total federal government.
Based on our review of FEC program data, there were a total of 120 partners that participated in the FEC
and reported data in 2008 (the first year for which we reviewed data), 136 partners in 2009, and 124
partners in 2010. As we have already mentioned, not all partners reported data in all years; 161 total
partners reported data in at least one year from 2008 - 2010. There were 30 new partners reporting data in
2009 and eight in 2010. However, some of these partners may have reported data in 2007 or earlier, so we
cannot state for certain that they were new to the FEC program without reviewing earlier records.
To put this in context, there are approximately 40 federal facilities in the Energy Star for Buildings
program, or about one-third the number of facilities actively participating in FEC (i.e., reporting data) in
any given year.114 Another voluntary government program, Waste Wise (which focuses on waste reduction
114 On the Energy Star website, searching for federal government Energy Star partners yields a list of 44 facilities; see
http://www.energystar.gov/index.cfm?fuseaction=estar partner list.showlmproversSearch&s code=ALL&partner type id=ESB&cntrv code=ALL&a
ward search=N. An alternative search of Energy Star labeled buildings by facility owner produces a list of 38 facilities owned by various federal
agencies; see
http://www.energystar.gov/index.cfm7fuseaction4abeled buildings.showMoreOptions&SEARCH OWNER ID=1&S CODE=ALL&PROFILES=&YEAR=&B
UILDING TYPE ID=ALL%20Buildings&SEARCH SPP ID=&CITY=&NEWQUERY=true&ZIP=&SEARCH PROP MANAGER ID=&FILTER B ID=&optionType=ow
ner id. Note that there are considerably more Energy Star buildings outside of the federal sector; the program boasts just over 20,000 total
certified buildings and plants. See http://www.energystar.gov/index.cfni7fuseaction4abeled buildings.locator
3-78
-------
and recycling), lists 25 federal partners.115 However, it should be noted that because many of the
Waste Wise partners are agencies rather than facilities, there may be considerably more individual
facilities participating in that program (GSA, for example, is listed as a single partner). Nonetheless,
viewed in comparison to these other voluntary programs, FEC's participation rate appears quite high.
Beyond the number of participating facilities, we can also examine purchasing data. Exhibit 3-56 showed
FEC's share of total federal EPEAT purchases, including just those FEC partners reporting in two or
more years from 2008 - 2010. Exhibit 3-57 reproduces that data, adding in data for all FEC partners.
EXHIBIT 3-57. FEC SHARE OF TOTAL FEDERAL EPEAT PURCHASES
2008
2009
FEC partners reporting in two or more years:
Desktops
Monitors
Laptops
Total
15.4%
54.7%
14.5
22.5
17.1
20.1%
14.1%
17.C
All FEC partners:
Desktops
Monitors
Laptops
Total
15.4%
54. £
15.1%
22.7%
18.0%
21.3%
15.C
18.6%
FEC partners accounted for 22.7% of all federal EPEAT purchases in 2008 and 18.6% in 2009; based on
the category-by-category trends for desktops and laptops, the proportion likely fell further in 2010. As
discussed above, the downward trend over time is likely driven more by the rest of the government
increasing its EPEAT purchases than by any significant downturn on the FEC's part. What is important
for this part of the analysis is that FEC covered about one-fifth of all federal electronics purchases. We
consider this to be a high participation rate.
Trends in EPEAT Certification Levels Among FEC Partners
While Evaluation Question 9 asks about overall levels of EPEAT purchases, FEC's purchasing data
reveals an additional, related trend worth discussing. Specifically, FEC partners have shifted from
purchasing mainly silver-level EPEAT products to mostly gold-level products, which must meet stricter
requirements and are therefore more protective of the environment. Exhibit 3-58 shows purchasing data
broken out by certification level.
5 See http://www.epa.gov/epawaste/conserve/smni/wastewise/about.htni
3-79
-------
EXHIBIT 3-58. PROPORTIONS OF EPEAT PURCHASES AMONG FEC PARTNERS, BY CERTIFICATION LEVEL
Desktops
Monitors
Laptops
Total
2007
BRONZE
0.5%
0.3%
10.9%
1 .9%
SILVER
72.4%
74.8%
35.7%
68.2%
GOLD
12.3%
9.9%
9.2%
10.9%
NOT
EPEAT
14.8%
15.0%
44.2%
19.1%
2008
BRONZE
1.6%
1 .2%
4.1%
1.8%
SILVER
14.3%
71.7%
58.4%
46.8%
GOLD
74.2%
16.9%
17.1%
39.7%
NOT
EPEAT
10.0%
10.3%
20.5%
11.8%
2009
BRONZE
0.7%
0.1%
1.1%
0.5%
SILVER
10.3%
33.8%
23.8%
23.2%
GOLD
86.0%
61.6%
72.3%
72.7%
NOT
EPEAT
3.0%
4.5%
2.7%
3.6%
2010
BRONZE
2.1%
3.5%
2.7%
2.8%
SILVER
2.1%
26.0%
24.7%
17.0%
GOLD
88.3%
55.7%
70.2%
71.6%
NOT
EPEAT
7.6%
14.8%
2.4%
8.7%
3-80
-------
In 2007, more than two-thirds of FEC partners' electronics purchases were EPEAT Silver, the middle
certification level, while just 10.9% of electronics products were EPEAT Gold. There was a dramatic
change over the next two years. In 2008, the share of silver certified products dropped by 20 percentage
points, while gold products increased by nearly 30 points. By 2009, silver products were a distinct
minority, at 23.2% of purchases, while gold, with 72.7%, had come to dominate FEC partners'
purchasing. Bronze-level products contributed a trivial portion to FEC purchases in all years.
We do not have tier-specific information on EPEAT purchases by the federal government or the United
States as a whole, so we do not have a baseline to measure FEC's performance against in this area.
Nonetheless, FEC's shift from silver to gold products was dramatic, and we suspect that this likely
represents a move toward greater environmental protection by FEC partners that was not wholly matched
by other purchasers.
QUESTION 10: USE OF EPP OUTPUTS OUTSIDE OF THE FEDERAL GOVERNMENT
Introduction
While the evaluation of the EPP Program focuses primarily on outcomes in the federal government realm,
it also addresses the broader influence of the EPP Program in the non-federal sector. Specifically,
Evaluation Question 10 asks: "How have the EPP Program's outputs, such as technical assistance,
information dissemination, decision tools, standards, and policy and contract language, been utilized by
purchasers outside of the federal government, including state and institutional purchasers?"
This section presents our findings for Evaluation Question 10. Overall impacts of EPEAT sales outside of
the federal sector are discussed first. We then present findings specific to states, universities, and other
non-federal institutional purchasers. Within each section, we briefly summarize general trends in
environmentally preferable purchasing based on third-party survey results and other secondary research;
then, we present results for our three specific categories (electronics, building and construction products,
and hospitality and travel) based on primary research conducted for this evaluation.
Key Findings
• Looking across all purchasers, EPEAT's reach has grown markedly since the program's inception.
EPEAT's total sales and market share of laptop computers, in particular, have grown dramatically.
Although EPEAT's total sales (and market share) of desktop computers and monitors have fallen, this
is reflective of the broad market shift away from desktops and toward laptops; the total sales of
EPEAT products has continued to increase. More than 50 million EPEAT certified products were
purchased in the U.S. in 2010, and nearly 100 million worldwide.
• The environmental benefits of EPEAT purchases are substantial. As an example, worldwide
EPEAT purchases in 2010 produced greenhouse gas reductions equivalent to eliminating the annual
emissions from over 1 million cars in the U.S. However, due to the market-wide move from desktops
to laptops, total estimated environmental benefits of EPEAT have fallen fairly consistently from 2007
through 2010. lEc's assessment is that the EEBC's methodology potentially exacerbates the
magnitude of the reduction of EPEAT benefits that result from shifting from desktops to laptops.
• EPEAT has achieved significant success among state purchasers. At least 11 states have adopted
EPEAT as a purchasing criterion for computers and monitors. Further, the State Electronics
Challenge - which was modeled after the Federal Electronics Challenge, and draws heavily on tools
3-81
-------
developed by EPP - has expanded from the northeastern U.S. to the entire country. Third-party
surveys of state procurement officials confirm the widespread adoption of EPEAT.
• At least 13 states have adopted the NSF 140 carpet standard, and at least two states are specifying
to the BIFMA e3/Level furniture standard. Starting in January 2010, NSF 140 Platinum superseded
California Gold as the required standard for all State of California government agency carpet
purchases. As of January 2012, GSA specifies the NSF 140 standard (minimum of gold level) for
carpet; this means that five states also specify the standard by default, as these states mirror the GSA
schedule: Florida, Louisiana, Ohio, New Mexico, and Texas.
• Two states report using hospitality and travel tools developed by EPP. One state reports using the
ASTM Green Meetings and Events standards, and two states report using the Convention Industry
Council's (CIC) Green Meetings Report, which was developed by EPP. Several stakeholders who
participated in developing the ASTM Green Meetings and Events standards predict the standards will
achieve greater adoption overtime. At least one large supplier of hospitality services is already
incorporating the standards in their training and operations.
• A number of universities have adopted EPEAT as a purchasing criterion, and at least two
universities are specifying the NSF 140 carpet standard. lEc did not identify any universities that
are using other building and construction product standards and tools, or travel and hospitality
standards and tools, developed by EPP. However, we did not conduct a comprehensive review of
purchasing specifications.
• Many cities, businesses, and other non-federal purchasers have adopted EPEAT. Use of other
EPP tools by non-federal purchasers, outside of states and universities, has been limited. However,
the current draft of the 2012 Edition of the ICC 700 National Green Building Standard - a consensus-
based standard that received ANSI approval - includes references to NSF 140 carpet, NSF 332
resilient flooring, and ULE 100 gypsum board.
• lEc did not identify any states that are specifying to the NSF 332 resilient flooring standard or
the ULE 100 gypsum board standard. However, we did not conduct a comprehensive review of all
state purchasing specifications.
Overall EPEAT Impacts: Non-Federal Buyers
Sales and Associated Environmental Benefits of EPEAT Electronics
The EPP Program's most prominent output in the electronics sector is the EPEAT registry for
environmentally preferable computers and laptops, along with the closely-related IEEE 1680 standards
that underlie the registry.116 lEc reviewed annual sales data of EPEAT products, as reported by the Green
Electronics Council (GEC), as a primary means of assessing EPP's impact in the electronics sector. This
evaluation has already reported data on sales of EPEAT electronics to the federal government, and to FEC
program participants; in this section, we provide figures on total EPEAT sales in the U.S. and worldwide.
116 To be included in the EPEAT registry, products must meet the specifications of the relevant IEEE product standard. It appears that all products
certified to the IEEE standards are included in the EPEAT registry.
3-82
-------
Key data on total EPEAT sales for 2007 - 2010 are shown in Exhibit 3-59.11? Two important caveats are
necessary for interpreting this data.
EXHIBIT 3-59. U.S. AND WORLDWIDE EPEAT SALES
YEAR
2007
2008
2009
2010
U.S. EPEAT Purchases
Desktops
Monitors
Laptops
Integrated Systems
Total
12,403,405
18,883,816
10,375,874
1,196,621
42,859,716
8,106,204
18,455,653
16,351,938
1,133,557
44,047,352
4,735,905
18,938,387
23,499,428
1,358,947
48,532,667
3,340,172
12,474,055
32,628,963
2,612,388
51,055,578
Worldwide EPEAT Sales (including U.S.)
Desktops
Monitors
Laptops
Integrated Systems
Total
35,865,425
48,709,354
24,156,128
1,196,680
109,927,587
19,512,831
38,612,720
31,671,055
1,146,067
90,942,673
7,904,561
30,617,703
40,298,554
1,629,802
80,450,620
8,021,529
20,115,100
61,694,686
3,532,100
93,363,415
60,000,000
50,000,000
40,000,000
30,000,000
20,000,000
10,000,000
0
U.S. EPEAT Sales
I Laptops
i Desktops
Monitors
i Integrated Systems
2007 2008 2009
Year
2010
117 At the time this analysis was conducted, the most recent available information was through 2010. GEC released its 2011 EPEAT Annual Benefits
Report in November 2012, after we had concluded our analysis. In broad terms, the 2011 report shows increases in sales and in most categories of
environmental benefits over 2010.
3-83
-------
Worldwide EPEAT Sales
120,000,000
100,000,000
80,000,000
Ifl
'E 60,000,000
D
40,000,000 -
20,000,000 -
I Laptops
I Desktops
Monitors
I Integrated Systems
0
2007 2008 2009* 2010*
*Due to a change in reporting conventions, 2009-2010 data are not comparable to 2007-2008.
• First, GEC's 2008 EPEAT benefits report notes that only 20 - 30% of EPEAT manufacturers
reported on non-U.S. sales in that year, and as a result GEC included only U.S. sales data in its report
for that year. The worldwide 2008 data reported here is included in subsequent reports, but it is not
clear whether this reflects only the 20-30% of manufacturers noted in the 2008 report, or if the data is
more comprehensive. If the former is true, then non-U.S. sales for 2008 may be substantially
underestimated.
• Second, GEC changed its reporting procedure and implemented a country-specific registry protocol in
2009. As a result, the reported total sales for 2009 and 2010 exclude EPEAT sales in all countries
other than the 40 represented in the registry; these other countries were included in worldwide sales
totals for 2007 and 2008. This change is likely responsible for the reported decrease in worldwide
EPEAT sales from 2008 to 2009.
• Due to these two factors, 2009 and 2010 are the only two years for which the worldwide data are truly
comparable. Neither of these issues impacts the U.S. sales figures.
In the U.S., there has been steady growth in EPEAT sales, from about 43 million total units in 2007 to 51
million in 2010, an increase of 19% (Exhibit 3-59). Yet the overall trend masks distinct differences
between product categories. Most notably, sales of desktop computers have fallen by nearly three-fourths,
while laptop sales have tripled. Thus, the overall mix of EPEAT products being sold in the U.S. has
changed dramatically since the registry was first developed.
It is less easy to interpret the worldwide sales data, due to the factors noted above. Nonetheless, as
reported, worldwide sales appear to follow a fairly similar pattern, i.e., a three-fourths decline in desktop
sales offset by a substantial (over 250%) increase in laptop sales (Exhibit 3-59). The decrease in monitors
is more pronounced worldwide (a nearly 60% drop) than in the U.S. (34%). Total sales across all product
categories fell by 15% from 2007 to 2010, but in the only two years with truly comparable data, there was
a 16% increase in total sales from 2009 to 2010.
3-84
-------
To highlight the extent to which the EPEAT program is affecting the market as a whole, we present data
on the market share of EPEAT products in Exhibit 3-60 below. GEC reports this data only for desktop
and laptop computers,118 and so we must follow the same convention here.
EXHIBIT 3-60. MARKET SHARE OF EPEAT PRODUCTS
YEAR
2007
2008
2009
2010
U.S. EPEAT Market Share
Desktops1
Laptops
Combined
40%
35%
37%
NR
NR
NR
20%
50%
42%
16%
72%
58%
Worldwide EPEAT Market Share (including U.S.)
Desktops1
Laptops
Combined
24%
19%
22%
NR
NR
NR
7%
23%
17%
6%
30%
22%
NR = Not reported
The GEC report includes the following disclaimer: This percentage does not accurately
reflect EPEAT's presence in the system's covered countries. Because EPEAT reporting
excludes many countries where sales are reported by Gartner, the Gartner worldwide
unit sales denominator is out of scale with EPEAT's 41 -country reporting territory.
1 Includes integrated systems.
EPEAT has come to dominate the U.S. market for laptop computers, with a 72% market share in 2010. In
contrast, the registry's share of desktop computers has shrunk from 40% in 2007 to 16% in 2010; this
trend is likely influenced by the overall decline in desktop computer use. For these two product categories
combined, EPEAT's U.S. market share has risen dramatically, from 37% in 2007 to 58% in 2010, helped
in part by a widespread market transition from desktops to laptops. Clearly, the registry has been
extremely successful in terms of market adoption - so much so, in fact, that one interviewee expressed the
opinion that if EPEAT is to continue to push the industry toward greater sustainability by promoting
exceptional products, the program will need to adopt stricter standards and accept a lower market share in
the future.
Worldwide, EPEAT's market share is respectable, but does not approach its dominance in the U.S.
EPEAT had 30% of the global market for laptops in 2010, up from 19% in 2007. In desktop computers,
worldwide market share fell to just 6% in 2010.
lEc did not investigate why EPEAT's market share has risen over the last few years for laptops while
falling for desktop computers; there are several factors that could explain this dynamic:
118 GEC reports EPEAT market share data for laptops and desktops combined, and for laptops alone. We have used this data to interpolate market
share for desktops alone.
3-85
-------
• One possibility is that because laptop computers as a group are much less energy- and material-
intensive than desktop computers and monitors, sustainability-minded consumers may have shifted
toward greater reliance on laptops. If true, this would mean that consumers who continue to use
desktop computers are less environmentally concerned, leading EPEAT to gain market share for
laptops while losing ground in desktops.
• A related possibility is that institutional buyers may be shifting from desktops to laptops. We do not
have precise data, but our impression is that institutional buyers account for a significant portion of
EPEAT purchases. If this core group is changing its purchasing behavior, it could explain the trends
in both EPEAT purchases and market share.
• Finally, we note that there are substantially more EPEAT certified laptop models available than
EPEAT certified desktop models - 9,762 vs. 2,549 in 2010.119 We do not have data to determine the
proportion of computer models (rather than units sold) that are EPEAT certified vs. non-certified. We
also cannot determine whether the disparity in the number of EPEAT certified models is a cause or
consequence of the difference in EPEAT's market share. Nonetheless, it is possible that supply, rather
than demand, is creating the observed pattern.
Regardless of the cause, assuming consumers continue to move toward laptops, EPEAT's relative lack of
uptake in the desktop computer market will prove to be less important than its marked success with
laptops.
Exhibit 3-61 shows environmental benefits from EPEAT purchases, as reported by GEC.120 Benefits have
fallen in most categories and in most years from 2007 - 2010, leading to a broad decrease in benefits over
time. For example, in the U.S., electricity and primary materials benefits were 70% lower in 2010 than in
2007. However, the annual benefits of the EPEAT program are still quite significant. To put the impacts
in perspective, estimated environmental benefits of the EPEAT program in 2010 are roughly equivalent to
avoiding the following impacts:121
• The annual electricity consumption of 390,000 average U.S. homes (for U.S. sales) or 760,000 U.S.
homes (for worldwide sales)
119 GEC reports this data for each country individually. Thus, a single model of computer that is EPEAT-registered in 10 different countries would be
counted as 10 different models in this data, significantly inflating the totals. For context, EPEAT had 2,830 unique product registrations in 2010
(i.e., excluding duplicates across different countries). This issue notwithstanding, this data illustrates the different availability of models of EPEAT
laptops vs. desktops within different countries, and suggests that consumers within a given country likely have far more choices of EPEAT laptops
than EPEAT desktops.
120 As noted in our analysis of Evaluation Question 5, because energy and related benefits (greenhouse gas emissions, air emissions) are due to the
criterion that EPEAT electronics must meet Energy Star technical specifications, the EPEAT environmental benefits reported here may include
some benefits that are attributed to the Energy Star program rather than EPEAT for purposes of internal reporting (i.e., tracking the programs'
contributions towards EPA's strategic goals). We could not determine how any such internal attribution occurs. However, there are several factors
that complicate proportioning benefits to each program, including: the fact that EPEAT electronics must meet Energy Star technical specifications,
but do not need to be Energy Star-certified; the question of to what extent obtaining Energy Star certification spurs manufacturers to also pursue
EPEAT-certification, and vice versa; and the question of whether institutional purchasers or other buyers would have opted to buy either Energy
Star- or EPEAT-certified products if the other program had not existed (i.e., determining the baseline to measure against in determining the
programs' impact).
121 Equivalencies are adapted from GEC's 2009 and 2010 EPEAT Annual Benefits Reports.
3-86
-------
The annual greenhouse gas emissions of 578,000 U.S. cars (for U.S. sales) or 1,127,000 U.S. cars (for
worldwide sales)
The annual solid waste generation of 8,800 U.S. households (for U.S. sales) or 16,100 U.S.
households (for worldwide sales)
Hazardous waste with the weight of 21,000,000 bricks (for U.S. sales) or 29,763,000 bricks (for
worldwide sales)
EXHIBIT 3-61. ENVIRONMENTAL BENEFITS FROM U.S. AND WORLDWIDE EPEAT PURCHASES
BENEFIT CATEGORY
UNIT
YEAR
2007
2008
2009
2010
U.S. Benefits
Electricity
Primary Materials
Air Emissions (including
greenhouse gases)
Greenhouse Gas Emissions1
Water Emissions
Toxic Materials
Solid Waste
Hazardous Waste
Megawatt-hours
Metric tons
Metric tons
Metric tons
carbon equivalent
Metric tons
Metric tons
Metric tons
Metric tons
16,500,000
29,400,000
68,000,000
1 ,290,000
142,319
1,190
N/A
46,700
8,400,000
14,800,000
34,200,000
1 ,570,000
71,683
1,021
14,353
43,337
6,700,000
11,700,000
27,000,000
1 ,240,000
57,000
935
18,174
43,395
4,700,000
8,100,000
18,600,000
860,000
40,000
791
17,571
42,001
Worldwide Benefits
Electricity
Primary Materials
Air Emissions (including
greenhouse gases)
Greenhouse Gas Emissions1
Water Emissions
Toxic Materials
Solid Waste
Hazardous Waste
Megawatt-hours
Metric tons
Metric tons
Metric tons
carbon equivalent
Metric tons
Metric tons
Metric tons
Metric tons
42,200,000
75,500,000
174,400,000
3,310,000
364,789
3,220
N/A
124,000
19,000,000
33,600,000
77,500,000
3,560,000
162,322
2,227
30,649
92,231
10,900,000
19,000,000
44,000,000
2,000,000
93,482
1,537
29,127
71,724
9,000,000
16,000,000
36,300,000
1,600,000
77,054
1,156
31,992
59,525
1 The EEBC changed its conversion factor from electricity to GHGs in 2008, reflecting a change in the underlying
EPA data source. This explains why electricity benefits fell by approximately 50% from 2007 to 2008 while GHG
benefits remained at about the same level.
3-87
-------
As we discussed in detail in our analysis of Evaluation Question 5, GEC uses the Electronics
Environmental Benefits Calculator (EEBC) to estimate the environmental benefits associated with
EPEAT purchases. Because the EEBC attributes much smaller environmental benefits to laptops than to
desktops, estimated total annual environmental benefits have fallen markedly since the program was
created, both in the U.S. and worldwide, due largely to the widespread market shift from desktops to
laptops. This decline in benefits is evident in spite of the fact that reported annual sales have grown in the
U.S., and fallen only modestly worldwide. In addition, the reporting procedure change noted above led to
a substantial reduction in reported worldwide EPEAT sales in 2009 compared to 2008; this change carries
through to the estimates of worldwide environmental benefits as well. Thus, the benefits figures reported
above should be viewed with a critical eye and an understanding of the underlying assumptions. The
success of the EPEAT program should be judged by figures for both EPEAT sales and resulting
environmental benefits, rather than examining one set of numbers in isolation from the other.
State Trends
General Trends
The National Association of State Procurement Officials (NASPO) and the Responsible Purchasing
Network (RPN) surveyed NASPO-RPN members from the 50 states and the District of Columbia (DC).
NASPO is comprised of the directors of the central purchasing offices in each of the 50 states, the District
of Columbia, and the territories of the United States. RPN is a network of government agencies (federal,
state, and local), colleges and universities, non-profit organizations, and private businesses dedicated to
socially responsible and environmentally sustainable purchasing.122 Because RPN members are
committed to sustainable procurement, the survey results are not likely representative of mainstream
procurement practices. Nonetheless, the results provide useful information about trends in state
purchasing, and the use of voluntary consensus standards developed by EPP.123 The survey was
administered in 2009 and 2010; we focus on the results from 2010.
The survey has several encouraging findings. Two out of three respondents (67%) had a formal (54%) or
informal (13%) "green" purchasing policy. While nearly all respondents rated product performance,
purchase price, availability, and durability as "important" or "very important" factors in their purchasing
decisions, a solid 68% rated environmental considerations as "important" or "very important," and 60%
rated social impact considerations in this manner. The majority of respondents (58%) reported they
"usually" or "always" consider environmental and social criteria in their purchasing decisions. Recycled
content (88%), energy conservation (79%), human health (79%), and recyclability (79%) topped the list
of environmental and social impact considerations.
The survey also probed the recognition and use of ecolabels and standards. As shown in Exhibit 3-62,
one-third of respondents recognized at least 18 labels/standards in the survey; however, only nine of these
labels/standards were usedby at least one-third of purchasers. With respect to standards that EPP
contributed to the development of, EPEAT enjoyed a high level of recognition and use (95%
recognition/77% use). Recognition of EPEAT rose by seven percentage points between 2009 and 2010,
while the use of EPEAT increased by 13 percentage points. Just under one-third of respondents (32%)
122 http://www.responsiblepurchasing.org/
123 Respondents to the 2009 survey represented 46 states plus DC; respondents to the 2010 survey represented 25 states plus DC.
3-88
-------
recognized Level/BIFMA e3, and only 9% of respondents reported using this standard. Level/BIFMA e3
was relatively new when the survey was administered in 2010; recognition and use of this standard may
have increased in the time since the survey was conducted.
The survey also examined challenges to environmentally and socially preferable purchasing. A solid
majority of respondents (78%) identified cost as the single most important hurdle to sustainable
purchasing. Other significant barriers to sustainable purchasing included: lack of experience on how to
specify responsible products (65%) and unclear or conflicting information about ecolabels/standards
(61%).
EXHIBIT 3-62. RECOGNITION AND USE OF STANDARDS AND CERTIFICATIONS
Sta nd a rd/ Certification
ENERGY STAR
LEED
EPEAT
Recognized
/ Used
Green Seal
EcoLoqo (Environmental Choice)
EnerqyGuide
CRI Green Label
USDA Organic
CFPA (Chlorine-Free Products
Association)
Fair Trade Certified
FSC (Forest Stewardship Council)
GreenGuard
Green-e
DfE (Design for Environment)
C2C (Cradle-to-cradle)
Wate (Sense
SCS (Scientific Certification
Systems)
SFI (Sustainable Forest Institute)
Level (from BIFMA, Business and
Institutional Furniture
Manufacturer's Association)*
Rainforest Alliance Certification*
MSC (Marine Stewardship
Council)*
100%
95% /
95% /
91% /
87% /
82% /
78% /
73% /
66% /
64% /
63% /
47% /
46% /
45% /
45% /
41% /
/ 100%
78%
77%
65%
55%
46%
48%
50%
22%
18%
36%
30%
5%
18%
9%
4%
39% / 10%
38% / 14%
32% / 9%
29% / 5%
14% / 0%
|
•
Notes: *New labels that were added to the report in 2010
Source: Responsible Purchasing Network and National Association of State
Procurement Officials, Responsible Purchasing Trends 2010: The 'State' of
Sustainable Procurement
Trends in Northeastern States
While the NASPO-RPN survey in the previous section considered all 50 states (plus DC), the Northeast
Recycling Council (NERC) conducted a survey focused on ten northeastern states (April 2009). Of the 10
states included in the survey, five had formal EPP programs: Connecticut, Maine, Massachusetts, New
York, and Pennsylvania.
3-89
-------
The ten northeastern states purchase a variety of environmentally preferable products. Eight procure
environmentally preferable electronics. Of particular note for this evaluation, six states purchase
environmentally preferable computers; six purchase environmentally preferable carpet; four purchase
environmentally preferable flooring; and four purchase environmentally preferable furniture.
The states use a variety of EPP criteria to inform their purchasing decisions, such as green standards and
eco-labels, federal legislation, and state laws and executive orders. As shown in Exhibit 3-63, five states
use EPEAT as a criterion.
EXHIBIT 3-63. EPP CRITERIA USED
EcoLogo
Energy Star
EPA's Comprehensive Procurement
Guidelines (CPGs)
EPA's Design for the Environment
EPEAT
European Union
Federal Legislation
Forest Stewardship Council (FSC)
Green Seal
LEED
State Executive Orders
State Law
CT
X
X
X
X
X
X
DE
X
X
X
ME
X
X
X
X
X
X
X
MA
X
X
X
X
X
X
X
NH
X
X
X
NJ
X
X
X
X
NY
X
X
X
X
X
PA
X
X
X
X
X
X
X
X
Rl
X
X
X
X
VT
X
Source: Environmentally Preferable Purchasing by Northeast States: Compilation of Survey Responses from
Northeast States Research Conducted by Northeast Recycling Council, Inc. for Rhode Island Resource Recovery
Corporation, April 14, 2009.
The ten northeastern states also vary in terms of their cost allowance for environmentally preferable
products and services. Four states - Connecticut, Delaware, New York, and Vermont - allow price
premiums up to 10% or more for certain types of environmentally preferable products. On the other hand,
three states - New Hampshire, New Jersey, and Rhode Island - have no cost allowance for
environmentally preferable purchases.
Electronics
EPEAT has enjoyed significant recognition and use in the non-federal realm. As noted above, in the RPN-
NASPO survey conducted in 2010, 95% of state purchasing officials reported that they recognized
EPEAT, and 77% reported using EPEAT in their purchasing decisions.124 While this may represent a high
estimate (RPN members likely have a more favorable view of environmentally preferable purchasing than
non-RPN members), it is broadly indicative of the widespread recognition and use that EPEAT has
124 Responsible Purchasing Network and National Association of State Procurement Officials, Responsible Purchasing Trends 2010: The 'State' of
Sustainable Procurement.
3-90
-------
achieved. The NERC survey of northeastern states indicated that five out often states had adopted
EPEAT as of April 2009.
In addition, the Green Electronics Council reports that the Western States Contracting Alliance (WSCA)
- an alliance of 15 western states for cooperative multi-state contracting - is also using EPEAT. WSCA
uses a "lead state" model where one WSCA state leads the procurement and manages the contract based
on that state's statutory requirements and processes; all other governmental entities within WSCA states
are eligible to use WSCA contracts.125 The WSCA website indicates that Minnesota is currently the "lead
state" for computer equipment; according to the Green Electronics Council, Minnesota has adopted
EPEAT. Overall, the Green Electronics Council reports that at least 11 states are using EPEAT as of
January 2012, including: California, Maine, Massachusetts, Michigan, Minnesota, New York, Ohio,
Oregon, Pennsylvania, Washington, and Wisconsin.126 Interviewees from the States of California and
Washington also reported that they use the EEBC. In addition, the State of Washington (Department of
Ecology) received support from the EPP Program's EPEAT coordinator; an interviewee from the
Department stated that EPP's staffs contributions were timely and effective. This same interviewee noted
that the Department is purchasing EPEAT computers (silver and gold), and has increased the timeframe
for computer turnover to five years.
In addition, EPEAT and EEBC play a key role in the State Electronics Challenge (SEC), which includes
participants from states across the country.
State Electronics Challenge
The Northeast Recycling Council (NERC) launched the State Electronics Challenge (SEC) in 2008 with
financial support from a federal Resource Conservation Challenge Grant. The SEC was initially piloted
within the 10 northeastern states that comprise NERC; the program went national in 2011. State agencies,
counties, towns, tribal units, public schools and universities, and other public-sector entities can become
SEC partners. As of February 2013, the SEC had 105 partners in 36 states.
The SEC was heavily influenced by the Federal Electronics Challenge. According to the SEC's program
manager, NERC borrowed as much as possible from the Federal Electronics Challenge model. The EPP
Program's FEC coordinator served on the advisory committee that set up the SEC. In addition, one of
NERC's staff members had served as a consultant to the Federal Electronics Challenge and helped
develop the original version of the EEBC. As with the Federal Electronics Challenge, EPEAT and the
EEBC play a central role in the SEC. The Federal Electronics Challenge continues to influence the SEC;
for example, the SEC regularly borrows webinars, interactive maps, and other tools from the Federal
Electronics Challenge website. In addition, the SEC provides partners with annual sustainability reports,
recognizes well-performing partners, and offers free technical support to partners.
http://www.aboutwsca.org/content.cfm/id/WSCA FAQs
126 Green Electronics Council, EPEAT Purchasers, Representative Sample - as of January 2012. In addition, the results of the NERC survey suggest
that New Jersey is also using EPEAT.
3-91
-------
Exhibit 3-64 presents the SEC's environmental results for 2008-2011.127'128 From its inception through
2011, SEC partners reduced their energy use by at least 188 million kWh - equivalent to the amount of
electricity needed to power 15,770 U.S. households for one year - and reduced greenhouse gas emissions
by more than 25,000 metric tons of carbon equivalents - which is equivalent to removing 16,889 cars
from the road for one year. In addition, SEC partners reduced municipal solid waste by 1,785 tons, which
is equivalent to the waste generated by 809 U.S. households in a year.
EXHIBIT 3-64. SEC RESULTS - ENVIRONMENTAL BENEFITS
REDUCTION IN
Energy use
Greenhouse gas emissions
Toxic materials, including lead and mercury
Municipal solid waste
Hazardous waste
HOW MUCH?
188 million kWh
25,148 metric tons of carbon equivalents
7,490 pounds
1 ,785 tons
520 tons
Source: SEC, http://www.stateelectronicschallenge.net/total results.html
Notes: Calculations made by SEC using Version 2.0 of the Electronics Environmental Benefits
Calculator, dated 3-2-09, available at
http://isse.utk.edu/ccp/proiects/benefitscalculator/elecbenecalc.html. Calculations for paper
reduction made using the WARM model conversion factors,
http://www.epa.gov/climatechange/wycd/waste/downloads/Paper%20Products.pdf, February 2012.
Exhibits 3-65 and 3-66 present data on computer and monitor purchases, reuse, and recycling, and data
reported by partners for computers in service. SEC partners reported purchasing nearly 16,000 EPEAT-
registered desktop computers, more than 14,000 EPEAT-registered LCD monitors, and more than 10,000
EPEAT-registered notebook computers from 2008-2011. A significant percentage of reporting partners
enabled power management features on their computers. It is important to note that the EPEAT figures
shown below are included in total EPEAT purchases presented earlier - i.e., the figures presented in the
table below are a subset of EPEAT purchases presented earlier in the report (they are not additive). As
shown in Exhibit 3-66, since 2011, SEC is also tracking reductions in paper use. Starting in 2012, SEC
requires double-sided printing features to be enabled on 75% of printers and copiers. SEC uses EPA's
Waste Reduction Model (WARM) to calculate the benefits of avoided paper savings, and uses EEBC to
calculate other environmental benefits.
This information is publicly available on the SEC website, http://www.stateelectronicschallenge.net/total results.html. lEc has not
independently verified the data.
128 The cumulative 2008-2011 results include: 13 Partners reporting in 2008; 12 Partners reporting in 2009, 26 Partners reporting in 2010, and 39
Partners reporting in 2011. 2012 environmental results had not been posted to the SEC website as of March 2013.
3-92
-------
EXHIBIT 3-65. AGGREGATED DATA REPORTED BY PARTNERS COMPUTER ft MONITOR PURCHASES,
REUSE, AND RECYCLING
Products Purchased
EPEAT Bronze
EPEAT Silver
EPEAT Gold
Total Purchased
Reused (units)
Recycled (units)
+ 671,361 Ibs. of mixed office equipment
+ 703 cell phones
DESKTOP
COMPUTERS
0
1,661
14,261
15,922
8,167
12,638
LCD
MONITORS
29
2,909
11,600
14,538
1,653
2,808
NOTEBOOK
COMPUTERS
40
4,287
6,149
10,476
17,089
2,989
CRT
MONITORS
N/A
N/A
N/A
N/A
1,382
10,340
Source: SEC, http://www.stateelectronicschallenge.net/total results.html
EXHIBIT 3-66. DATA REPORTED BY PARTNERS FOR COMPUTERS IN SERVICE, 2008-2011
(AVERAGES)
Power
management
enabled
Computers
Monitors
Average equipment lifespan
(months)
Paper reduction (reams of paper)
2008
59%
68%
62
N/A
2009
51%
86%
61
N/A
Source: SEC, http://www.stateelectronicschallenge.net/total results.html
2010
73%
95%
63
N/A
2011
81%
86%
58
10,779
Notes: The data is this table should not be considered to reflect trends. Rather, it reflects the practices
of the Partners that reported in that calendar year. Reporting on paper reductions began in 2010.
It is beyond the scope of this evaluation to attempt to quantify the portion of the above benefits that can
be attributed to SEC, much less the EPP Program. However, it seems reasonable to conclude that the EPP
Program inspired the creation, and influenced the design of, the SEC, through the successful Federal
Electronics Challenge. As the SEC program manager stated, "The Federal Electronics Challenge is a
fabulous program, and I'm thrilled to have been able to steal it."
Building and Construction Products
We reviewed data from a number of sources to identify states making use of the building and construction
product standards that EPP helped to develop, including a variety of formal reports and personal
communications with representatives from standards development organizations and other stakeholders.
However, there is no comprehensive list of states (or other purchasers) using these standards; as a result,
the information we report here provides an incomplete listing.
3-93
-------
Among the building and construction product standards, the NSF 140 carpet standard has had the greatest
uptake by state purchasers, and has been adopted by at least 13 states. Starting in January 2010, NSF 140
Platinum superseded California Gold as the required standard for all State of California government
agency carpet purchases.129 As of January 2012, the U.S. General Services Administration (GSA)
specifies the NSF 140 standard (minimum of gold level) for carpet; this means that five states also specify
the standard by default, as these states mirror the GSA schedule: Florida, Louisiana, Ohio, New Mexico,
and Texas.130 A further seven states have also adopted the standard in their specifications: Delaware,
Maine, Minnesota, New York, Pennsylvania, Virginia, and Washington.131 In addition, interviewees from
Washington's Department of Ecology and California's Department of General Services (DGS) reported
that their states have used the EPP Program's procurement guidance for carpet.
The BIFMA e3/Level furniture standard has also achieved some recognition and adoption among state
purchasers. As noted above, 32% of respondents to the 2010 NASPO-RPN survey recognized BIFMA
e3/Level, and 9% of respondents reported using the standard. These percentages may have increased since
the survey was conducted. The States of California and Washington are including BIFMA e3 in their
specifications. California's DGS requires BIFMA for state purchases, which is significant given the
state's substantial buying power. Interviewees from California DGS further noted that EPP Program
resources have been helpful for specifying sustainable furniture.
California has also made use of EPP's Federal Green Construction Guide for Specifiers. In general, DGS
has found EPP Program resources to be helpful for understanding what other purchasers are requiring of
manufacturers, and to inform the development of their own specifications.
We found less evidence that states have adopted NSF 332 (resilient flooring) and ULE 100 (gypsum
board). While individual state purchasers or departments may be specifying these standards, we did not
receive any reports the states are requiring these standards. However, NSF 332 and ULE 100 are
relatively new; recognition and use may increase over time.
Hospitality and Travel
Activities in the hospitality and travel sector are generally less mature than in other sectors, and the full
impact of these activities has not yet been felt at the federal or state level. However, at least two states are
already using outputs developed by EPP Program staff. Notably, the State of Washington reports using
the ASTM Green Meetings and Events standards; in addition, the State uses the Convention Industry
Council's (CIC) Green Meetings Report, which was developed by EPP. The State of California also uses
the Green Meetings Report. As with building and construction products, we did not find a comprehensive
list of states (or other purchasers) using the ASTM standards or other EPP resources, and thus, they may
be used more widely than we have reported here.
129 Revised Department of General Services Management Memo 10-01, Carpet Purchases to Meet Environmentally Preferable Criteria, 31 December
2009: "Effective immediately, all carpet purchased by State agencies shall be certified to meet the NSF/ANSI 140-2007 Standard at its Platinum
level."
130 Written communication from Dave Kitts, VP-Environment, Mannington to his sales group, quoted in email from Dave Kitts to Daniel Kaufman, lEc,
6 June 2012.
131 Email from Dennis Gillan, NSF, to Dan Leistra-Jones, lEc, re: "FW: City/Country NSF 140 Purchasing," December 21, 2011. Note: According to an
interviewee from the Washington Department of Ecology, NSF 140 is "not required, but prioritized."
3-94
-------
University Trends
General Trends
The National Association of Educational Procurement (NAEP) conducted a survey in 2009 and 2010 to
collect information on environmentally preferable procurement trends in higher education. The survey
was distributed to 1,246 NAEP member institutions in February 2009 and February 2010; 101 institutions
(8%) responded in 2009, compared to 230 institutions (19%) in 2010. Almost one-third of respondents
(32%) had a formal green procurement policy in 2010, up from 24% in 2009. Sixty-five percent (65%) of
respondents had a campus sustainability plan, and 33% had a climate action plan. The main drivers of
sustainability among respondents included "do the right thing" (81%), reduce carbon (73%), improve
image (73%), reduce consumption (72%), and reduce costs (65%).
The survey also asked respondents: "What green product certifications are in your procurement system?"
The percentage of respondents that recognize green labels increased from 2009 to 2010, although Energy
Star was the only green label recognized by more than 50% of respondents (57%). Other recognized
labels included "recycled" (40%), Green Seal (32%), and Green Guard (20%). Respondents also
mentioned EPEAT, LEED, FSC, EcoLogo, and SCS; however, percentages were not provided). More
than one-third of respondents (38%) "don't use any" green products or labels.
Respondents identified the following factors as the most challenging barriers to green procurement:
measuring progress with green procurement (43%), changing user behavior to focus on sustainability
(42%), justifying cost for green purchasing (42%), and validating suppliers' "green" claims (38%). Other
challenges included: securing executive support for green programs (15%), getting suppliers to provide
accurate and updated product information (23%), and effectively promoting certified products and
suppliers to end users (32%). Notably, several of these challenges echo concerns raised in the federal
purchasing survey and NASPO-RPN state purchaser survey, including: justifications for higher upfront
costs, difficulty verifying green marketing claims, and quantifying/tracking the volume of green
purchases.132 Respondents to the NAEP survey also expressed concerns about the training (or lack
thereof) they had received in green purchasing: One-third of respondents indicated they have not received
any "green" procurement training at their institution, and an additional one-third indicated they received
training that was "fair" or "poor." The lack of training and the absence of systems may pose a significant
barrier to green purchasing, even for procurement officials who are receptive to the idea of buying green.
Electronics
EPEAT has achieved considerable success in the university sector, with numerous colleges and
universities including EPEAT in their procurement specifications, including: University of California
system (10 campuses), Arizona State University, Central Michigan University, Cornell University,
Harvard, Michigan State, Penn State, University of Pittsburgh, University of Utah, and Yale. EPEAT was
also featured in the College Sustainability Scorecard 2010. Out of the approximately 300 colleges and
universities surveyed, 190 (more than 60%) used EPEAT as a criterion in their electronics purchasing
decisions; of these, 70 schools (more than one in five) purchased exclusively EPEAT-registered
132 Although we draw a high-level qualitative comparison across the results of the federal, state, and university purchaser surveys, we cannot
compare the results in quantitative terms because of the different methodologies used for each survey. Each survey phrased its questions
differently and used different screening criteria to select survey respondents; for example, the federal purchaser survey was limited to purchasing
staff, whereas the other surveys included purchasing policy managers.
3-95
-------
electronics products.133 EPEAT is also recognized in the AASHE STARS certificate system for higher
education, and is also a criterion for the Consortium on School Network (K-12 association) Green IT
certificate.
Though not the focus of this evaluation, it is worth noting that universities outside the U.S. are also
specifying EPEAT, including: Universite Laval (Canada), Centre Nationale des Recherches Scientifiques
(France), Linkoping University (Sweden), and Warsaw University of Technology (Poland).
Building and Construction Products
At least two universities are specifying NSF 140: Penn State (requires NSF 140 Platinum) and Rutgers.
The evaluation team was not able to locate information on other universities that are specifying NSF 140
or the other voluntary standards for building and construction products. However, given that we do not
have complete information for all of the thousands of colleges and universities across the U.S., these
findings should be interpreted as inconclusive, as other colleges and universities may be specifying one or
more of these standards without our knowledge.
Hospitality and Travel
We did not find evidence that universities are using EPP Program standards, guidance, or tools related to
green hospitality and travel. As noted above for building and construction products, these findings should
be seen as inconclusive. Furthermore, colleges and universities may use EPP hospitality and travel
outputs to a greater extent as these outputs reach maturity and are more widely disseminated.
Trends Among Other Non-Federal Institutional Purchasers
General Trends
In addition to the joint RPN-NASPO survey of state purchasing officials discussed above, RPN surveyed
its broader membership in 2007 - 2010, including state purchasers plus other non-federal and federal
buyers. Unfortunately, the RPN report does not separate state purchasers from other institutional
purchasers. Further, respondents include federal agencies and non-federal purchasers (e.g., state agencies,
municipal agencies, educational institutions, non-profit organizations, religious congregations, business
membership organizations, and corporations); however, the RPN report does not disaggregate responses
for federal purchasers versus non-federal purchasers. Finally, RPN respondents are not likely
representative of mainstream procurement trends, since RPN is committed to sustainable procurement.
Given these limitations, we were not able to use the survey results to characterize general trends for non-
federal institutional purchasers, outside of states and universities.
However, we found another data source that gives some indication of the use of EPP building and
construction standards by other non-federal institutional purchasers. Specifically, the Criteria for High
Performance Schools (CHPS) incorporates two of the building and construction product standards that we
evaluated: NSF 140 and NSF 332. CHPS started in 1999 as a multi-stakeholder collaborative to improve
the quality of schools in California; it is now used throughout the country. CHPS is a flexible rating
system that defines the characteristics of a high performance school building. School districts are
encouraged - and, in some states, required - to apply the criteria for new school buildings. The criteria
3 Green Electronics Council, EPEAT Purchasers, Representative Sample - as of January 2012.
3-96
-------
can also be used for major renovations. Our research found that four states incorporate the EPP standards
in their CHPS criteria: California, Washington, Colorado, and Texas.
Electronics
Consistent with state and university purchasers, EPEAT has achieved significant recognition and use
among other non-federal institutional purchasers. The Green Electronics Council has identified a number
of cities and private enterprises that were specifying EPEAT as of January 2012. Cities that are specifying
EPEAT include: San Francisco, Phoenix, San Jose, Seattle, Portland, LA County, Culver City (CA), and
Keene (MI). Private enterprises specifying EPEAT include: Broadlane, Catholic Healthcare West,
Charles Schwab, Deutsche Bank, Fairmount Hotels, HDR, HSBC, Kaiser Permanente, KPMG (U.S.),
Marriott International, McKesson, Microsoft, NBC-Universal, Nike, Premier Inc., and Tesco.134
Moreover, a number of sustainability systems recognize EPEAT, including: LEED, Green Guide for
Health Care, and Practice Greenhealth Awards.135 Finally, the RPN itself features EPP tools on its
website, including the EEBC.136
Though not the focus of this evaluation, it is worth noting that a number of other non-federal purchasers
outside the United States are also using EPEAT. National government agencies/ministries in the
following countries are specifying EPEAT: Canada, Australia, New Zealand, France (multiple ministries),
Scotland, UK Environment Agency, Mexico, Poland, and Singapore; and Thailand, Ecuador, Costa Rica,
and Colombia. Cities outside of the U.S. that are using EPEAT include Vancouver and Leeds (U.K.).
Other buyers specifying EPEAT include the Provinces of British Columbia, Nova Scotia, Ontario,
Quebec; Warwickshire County (UK), and Minas Gerais State (Brazil).137
Building and Construction Products
Interviews with industry association representatives, manufacturers, and standards stakeholders suggest
that the uptake of building and construction product standards by purchasers outside the federal realm has
so far been modest. A possible exception may be the NSF 140 carpet standard; according to the chair of
the standard committee, there have been reports that some architectural specifiers are calling for NSF 140.
However, lEc was not able to obtain quantitative information on the number of specifiers requiring the
various building and construction product standards or the number of times the standards were included in
specifications.138
The number of copies of the standards sold may serve as a rough proxy for adoption of the standards.
NSF reported selling 90 copies of the NSF 140 carpet standard and 23 copies of the NSF 332 flooring
standard through 2011. However, NSF notes that they give away several copies of the standards each
year, and some associations they work with do the same.139 This suggests that the actual number of
134 Green Electronics Council, EPEAT Purchasers, Representative Sample - as of January 2012.
135 Ibid.
136 http://www.responsiblepurchasing.org/purchasing guides/computers/calculator
137 Green Electronics Council, EPEAT Purchasers, Representative Sample - as of January 2012.
138 The evaluation team decided not to subscribe to the McGraw-Hill Construction Guide, which may have provided limited data on this topic. See
the methodology chapter.
139 Email communication from Dennis Gillan, NSF, to Dan Leistra-Jones, lEc, 9 January 2012.
3-97
-------
organizations using the standards may be significantly greater than the figures suggest. On the other hand,
the figures do not indicate which types of organizations purchased the standards. lEc was not able to
obtain the number of copies sold of the BIFMA e3/Level standard.
Several standards stakeholders interviewed believe that adoption of building and construction standards
that EPP supported will increase over time. Notably, one indication that the standards may be gaining a
foothold in the marketplace is that the current draft of the 2012 Edition of the ICC 700 National Green
Building Standard references NSF 140, NSF 332, and ULE ISR 100.14° The ICC 700 National Green
Building Standard was established in 2007 by the National Association of Home Builders (NAHB) and
the International Code Council (ICC); it is consensus-based and received ANSI approval. The Standard
defines green building for single-family homes, multi-family buildings, residential remodeling projects,
and site development projects; certification to the standard is provided by the NAHB Research Center.141
While it is too soon to tell if NSF 140, NSF 332, and ULE ISR 100 will remain in the final version of the
2012 Edition, their inclusion in the draft 2012 Edition of ICC700 is a positive sign that the standards may
be gaining traction.
Though not the focus of this evaluation, it is worth considering if and how the building and construction
product standards could be marketed internationally, as has EPEAT. lEc did not focus specifically on the
adoption of voluntary consensus standards outside the United States, but our discussions with EPP staff
suggest that the building and construction standards are not enjoying international success comparable to
EPEAT. However, in an encouraging development, it appears that the Government of Canada has adopted
certain criteria from the BIFMA e3 standard as part of a set of environmental specifications for
government-wide National Master Standing Offers for office furniture. According to information on the
Canadian government's website: "In preparation for the eventual introduction of third party registration to
the BIFMA Sustainability standard (BIFMA E3-2008), the GoC (Government of Canada) has adopted
certain criteria from the Sustainability standard at this time. As soon as there is a registration program in
place, the GoC will be considering the silver level as the minimum standard for all office furniture NMSO
programs."142 An interviewee from BIFMA indicated that as of June 2012, the Canadian government was
considering e3 Standard credits for "potential" use in the Canadian procurement process. lEc is not aware
of countries outside the U.S. that are considering or actually using the other building and construction
standards (NSF 140, NSF 332, and ULE 100), although as noted above, this was not the focus of our
study. More research would be needed to understand if/how the building and construction standards could
be marketed internationally.
Hospitality and Travel
Although the ASTM Green Meetings and Events standards were recently published, there are already
positive indications that the standards will impact hospitality and travel booking behavior in the general
marketplace (outside of the federal government). Several stakeholders who participated in the
development of the standards, including EPA Regional staff and non-government stakeholders, stated that
140 NAHB Research Center, Public Comments Report on the Development of the 2012 Edition of the ICC 700 National Green Building Standard,
October 15, 2012.
141 http://www.nahbgreen.org/ngbs/default.aspx
142 Public Works and Government Services Canada, "Minimum Sustainability Requirements for Federal Government Office Furniture."
http://www.tpsgc-pwgsc.gc.ca/app-acq/rccgmb-gofacm/mobilierexigences-furniturerequirements-eng.html. Date Modified: 2011-12-09.
3-98
-------
the standards are a useful resource for meeting planners and a helpful guide to show suppliers what they
must do to win business. The head of the ASTM Committee was cautiously optimistic that the standards
will be incorporated into the specifications (Requests for Proposal) that meeting planners issue to hotels,
convention centers, and other suppliers and vendors. She noted that Hyatt, Marriott, and Wyndham,
among others, are already showing interest, and indicated that the draft standards are already being used.
Aramark - a leading provider of food services, facilities management, and related services - reports they
have already started incorporating the standards in their training and operations. According to an
interviewee in Aramark's sports and entertainment group, Aramark is working to build capacity by
bringing the standards into trainings for their own sales staff and adopting some aspects of the standards
into their own practices. In addition, Aramark is promoting the standards and working to build awareness
of the standards with their clients at convention centers, and to a lesser extent, at sports facilities. They are
also starting to pay more attention to sustainability metrics, because some clients are starting to request
data on the impact of their events. While they are not yet aware of meeting planners specifying the
standards (because the standards are still new), Aramark anticipates that planners will demand the
standards going forward.
QUESTION 11: USE OF VOLUNTARY CONSENSUS STANDARDS BY MANUFACTURERS
Introduction
While Evaluation Question 10 addressed the use of EPP Program outputs by non-federal purchasers,
Evaluation Question 11 addresses the program's influence on manufacturers. Specifically, it asks, "To
what extent are manufacturers using the voluntary consensus standards that EPA has helped develop?"143
This section presents our findings on this evaluation question. We obtained what we believe to be
comprehensive data on manufacturers' use of the standards EPP helped develop in the electronics and
building products sectors. We have only limited anecdotal information on the travel and hospitality sector,
gleaned from interviews with industry participants.
Key Findings
• The Institute of Electrical and Electronics Engineers (IEEE) 1680.1 (EPEAT) standard is widely used.
As of December 2010, 54 manufacturers, including all of the largest producers of personal computers,
had products certified under the standard. There were a total of 2,830 unique EPEAT-registered
products at that time. In another sign of the importance of the EPEAT program, when Apple briefly
withdrew from EPEAT in mid-2012, it faced a strong backlash from its customers and immediately
re-joined.
• In the building products sector, two sustainability standards in particular have enjoyed widespread
adoption by manufacturers, the NSF 140 carpet standard and BIFMA-e3 furniture standard. While
only two manufacturers are using the ULE 100 gypsum board standard, they represent the two largest
players in the industry, with 50% market share in the U.S.; thus, the gypsum board standard has also
143 The original wording of the question, as laid out in our methodology document, asked about standards use by both manufacturers and
purchasers. We have addressed purchasers' use of standards in our analysis of Evaluation Questions 10 and 12; thus, to avoid redundancy, we
restrict our analysis of Evaluation Question 11 to manufacturers.
3-99
-------
seen success with respect to uptake by manufacturers. In contrast, the NSF 332 floor covering
standard that EPP helped to develop has had limited uptake.
• There is not sufficient information available to determine the extent to which industry participants are
using the ASTM Green Meetings and Events standards. We found some anecdotal evidence of
meetings planners utilizing the standards, but they mostly seem to be using them as a menu of
environmentally preferable actions, rather than a firm set of criteria leading toward certification.
Use of the IEEE 1680 (EPEAT) Standards by Electronics Manufacturers
The IEEE 1680.1 standard sets the requirements for computers, monitors, and integrated systems to be
included in the EPEAT electronics registry. The IEEE standard was first released in 2006 and was
updated in 2009; as of November 2012, a second round of revisions was underway. All electronics
certified to meet the IEEE 1680.1 standard are included in the EPEAT registry, and thus membership in
the registry and use of the standard can be considered interchangeable.
The Green Electronics Council (GEC), which manages the EPEAT program, tracks both the number of
manufacturers participating in EPEAT and the number of products in the registry, and reports these
figures in its Annual Benefits Reports. Exhibit 3-67 summarizes this data.
EXHIBIT 3-67. MANUFACTURER PARTICIPATION AND PRODUCT REGISTRATION IN EPEAT
Manufacturers producing EPEAT
products
2007
23
2008
30
2009
37
2010
54
Products in EPEAT registry:
Unique product registrations
Total country registrations
735
975
1408 (US),
277 (ROW)
1408 (US),
8376 (ROW)
2219 (US),
611 (ROW)
2219 (US),
15857 (ROW)
ROW = Rest of world
It appears that most if not all major computer manufacturers have EPEAT-registered products.
Participating manufacturers in 2010 included (among others) Hewlett-Packard, Acer, Dell, Lenovo,
Toshiba, and Apple, which at the time represented the five largest manufacturers of personal computers
worldwide (excluding Apple) and in the U.S. (excluding Lenovo).144 The breadth of the EPEAT
program's reach makes it clear that it is a major force in the marketplace, and one that manufacturers feel
they must address. Nowhere is this illustrated more clearly than in Apple's recent decision to leave the
EPEAT program, only to backtrack under pressure and re-join just a few days later (see text box on next
page).
144 "Gartner Says Worldwide PC Shipments in Fourth Quarter of 2010 Grew 3.1%; Year-End Shipments Increased 13.8%
http ://www.gartner. com/it/page.jsp?id= 1519417
' Gartner, January 12, 2011.
3-100
-------
We do not have information on the total number of different computer and monitor models (including
both EPEAT and non-EPEAT) available in the marketplace, so we cannot determine what proportion of
all product models are EPEAT-registered. However, as noted in our analysis of Evaluation Question 10,
EPEAT enjoys a 22% worldwide market share for computer purchases. This would imply that a
significant portion of all models of computers (and presumably, monitors as well) are EPEAT-registered.
In summary, it is clear that manufacturer participation, as well as overall market share and use by major
purchasers, indicates that the IEEE 1680.1/EPEAT standard for computers and monitors has been widely
adopted. It stands as a clear success of the EPP Program.
Market Power of EPEAT: Apple Example
In July 2012, Apple abruptly withdrew all of its 39 EPEAT-registered products withdrew from participation in
the EPEAT registry. Critics speculated that the decision was tied to the design of the new MacBook Pro, which
have batteries glued into the case and cannot be disassembled for recycling, as required by the IEEE standard.
Many observers were surprised by the withdrawal, as Apple had been actively involved in creating the
standard. Environmental and technology reporters were quick to pick up the story. Public upset ensued;
several organizations started petitions; and most prominently, the City of San Francisco decided not to buy
any new Apple products.
The City of San Francisco's Department of Environment is a strong supporter of third-party ecolabels as easy-
to-use procurement tools for identifying environmentally preferable products. In 2008, the City adopted a
policy requiring that any City electronics purchases be EPEAT silver certified; in 2009, they updated the
requirement to EPEAT Gold. When the City heard about Apple's withdrawal from EPEAT, they decided to
cease purchasing Apple computers. The City did not publicly decry Apple or declare a boycott; they simply
stated that they could not continue to buy Apple products since they had an EPEAT Gold requirement that
Apple would no longer satisfy. Observers expected other institutional purchasers to follow suit.
A week after the withdrawal, Apple's Senior Vice President of Hardware Engineering announced in an open
letter that Apple placed all of its products back on the EPEAT registry. Mansfield acknowledged receiving
complaints from many Apple customers and called the decision to leave EPEAT a "mistake." He affirmed
Apple's continued commitment to the environment, and remarked that Apple's relationship with EPEAT "has
become stronger as a result of this experience, and we look forward to working with EPEAT as their rating
system and the underlying IEEE 1680.1 standard evolve."
Sources:
Hull, D. and Boudreau, J. Apple's withdrawal from 'green' certification program surprises purchasers. July 10, 2012.
http://www.mercurynews.com/business/ ci_21038486/apple-withdrawal-epeat-green-certification-p
Mansfield, B. A letter from Bob Mansfield. July 13, 2012. http://www.apple.com/environment/ letter-to-customers/
Geiger, Chris, City of San Francisco Department of the Environment. Personal communication. September 6, 2012.
In mid-2012, IEEE finalized standards 1680.2 and 1680.3, which set environmental criteria for imaging
equipment (i.e., printers) and televisions, respectively, to be admitted to the EPEAT registry. As of May
2013, the EPEAT registry included 411 products certified under the imaging equipment standard,
including 173 silver and 15 gold-rated products. Participating manufacturers included Canon, Dell,
Epson, Hewlett-Packard, Konica Minolta, Lexmark, Ricoh, Samsung, and Xerox. For the TV standard,
two manufacturers (LG and Samsung) had 123 certified products, including 84 silver and 39 gold (there
are no bronze-level televisions registered as of yet). The high number of products certified so quickly
3-101
-------
after the standards were finalized, particularly at the higher rating levels, has led some observers to
conclude that industry participants unduly influenced the standard development process, which is
discussed in evaluation question 12.
Use of Voluntary Consensus Standards by Building Product Manufacturers
BIFMA, NSF, and ULE provide information on their websites regarding products certified under their
standards, and the manufacturers of these products. We also gathered information on the number of
manufacturers with certified products through interviews with industry representatives and GSA schedule
managers, and through internet searches. Based on this research, it is clear that none of these information
sources provide a comprehensive list of all manufacturers producing certified products (with the possible
exception of BIFMA, which appears to have a complete list of furniture companies with products certified
to the BIFMA-e3 sustainability standard). Exhibits 3-68 and 3-69 summarize the available information on
manufacturers and products associated with each of the building product sustainability standards being
evaluated.
EXHIBIT 3-68. MANUFACTURER PARTICIPATION AND PRODUCT CERTIFICATION IN THE BUILDING
PRODUCT SECTOR
PRODUCT CATEGORY
Carpet
Resilient Floor Coverings
Furniture
Gypsum Board
STANDARD
NSF 140
NSF 332
BIFMA e3
ULE ISR 100
PARTICIPATING
MANUFACTURERS
13
5
48
2
CERTIFIED
PRODUCTS
>305
>74
2685
2
The NSF 140 carpet standard has enjoyed the most success in terms of overall market share. All four of
the world's largest carpet companies (Shaw, Mohawk, Beaulieu, and Interface) have products certified
under NSF 140; these companies alone have more than 50% of the global market share in the industry.
Thus, the 13 certified manufacturers represent most of the global market. Overall, more than 300 products
are certified to meet the NSF 140 standard.145 The carpet industry is widely considered a leader in
sustainability issues, and has been involved in sustainable standard development since the 1990s. The
Carpet and Rug Institute (CRI), a major industry association, is very active in promoting the standard. As
discussed in our analysis of Evaluation Questions 10 and 12, demand for NSF 140 certified carpet is also
driven by extensive requirements from GSA, states, universities, and other private sector customers.
The NSF 332 resilient floor covering standard has had somewhat lower adoption from manufacturers,
attributed by interviewees in part to a shorter history in the industry of addressing sustainability, lack of
145 The NSF website identifies nine companies selling NSF 140 certified carpet, with 305 certified products between them. It appears that these nine
companies represent those whose products were certified by NSF (as opposed to another certification group, which can also certify compliance
with NSF standards). Products that were certified to the NSF 140 standard by other certifying bodies are not included; thus, there are more total
NSF 140 certified products than the 305 reported. The same is true for NSF 332 certified floor coverings.
3-102
-------
leadership in the sector, and ultimately a lack of external demand drivers. However, the five participating
manufacturers have more than 74 NSF 332 certified products between them.146
EXHIBIT 3-69. MANUFACTURER PARTICIPATION BY PRODUCT CATEGORY
CARPET (NSF
140)
RESILIENT
FLOOR
COVERINGS (NSF
332)
FURNITURE
(BIFMA E3)
FURNITURE
(BIFMA E3)
CONT.
FURNITURE
(BIFMA E3)
CONT.
GYPSUM BOARD
(ULE ISR 100)
Atlas Carpet
Mills
Armstrong
Affordable
Interior Systems
(AIS)
Allseating
Allsteel
National Gypsum
Beaulieu Group
Congoleum
Baker
Manufacturing
Bentley Prince
Street
Flexco
Carolina
Bernhardt
Design
DARRAN
Furniture
Bush Industries
Dauphin
Blueridge
Commercial
Carpet
Johnsonite
(Tarkett;
Azrock)
Davies Office
Refurbishing
Descor
Industries
First Office
Dixie Group
(Masland
Contract;
Whites pace)
Mannington Mills
Global Contract
(Global Total
Office)
Godrej & Boyce
Haworth
InterfaceFLOR
J+J / Invision
Mannington Mills
Milliken a
Company
Mohawk Group
Shaw
Tai Ping Carpets
International
Tandus Flooring
HBF
Herman Miller
High Point
Furniture
Humanscale
Indiana
Furniture
I nscape
Interstuhl
Euro mo be I
lzzy+
Jasper Desk
Company
Jofco
Keilhauer
Kl
Kimball Office
Knoll
Krug
Lamex
MooreCo
Loewenstein
National Office
Furniture
Maxon Furniture
Nightingale
Nucraft
OFS
Paoli
Spec Furniture
Steelcase
Teknion
The Gunlocke
Company
The HON
Company
Trendway
Trinity Furniture
Versteel
Via Seating
United States
Gypsum Co.
The BIFMA-e3 furniture standard, approved in 2008, has also enjoyed a fair amount of success in terms
of its adoption by manufacturers. The 48 companies with products certified under BIFMA-e3 account for
about 45% of the furniture association's members. The 110 BIFMA members (including those without e3
certified carpet) produce an estimated 80% of the office furniture sold in North America.
' See footnote 3.
3-103
-------
Finally, the ULE ISR 100 gypsum board standard, approved in 2010, has only two manufacturers
producing certified products. However, these two manufacturers are responsible for a majority of the
gypsum board sold in the U.S., making them the largest players in the industry. Both of these
manufacturers use the standard as a marketing tool. Stakeholders interviewed suggested that the limited
adoption of the standard is due to the lack of demand drivers, such as codes specifying use of the
standard, and purchasing requirements.
For each of the building product standards being considered, we discuss the main factors driving their
success (or lack thereof) in greater detail in Evaluation Question 12. In addition, in the course of our
research we obtained limited information on the extent to which manufacturers needed to make changes
to their production processes in order to achieve certification to the various standards; that information is
presented in Evaluation Question 3.
Use of the ASTM Green Meetings and Events Standards by Industry Participants
There are nine standards in the suite of ASTM Green Meetings and Events Standards. Eight of the nine
were finalized in early 2012; the last standard, on accommodations, was completed in early 2013. These
standards cover:
• Destinations;
• Exhibits;
• Transportation;
• Audio visual (AV) and production;
• Communication and marketing materials;
• Onsite offices;
• Food and beverage;
• Venues; and
• Accommodations.
We were not able to obtain data comparable to the information presented above on the number of industry
participants using these standards, for several reasons:
• ASTM does not appear to track the use of its standards in the same way as the building product
standards organizations, meaning there is no centralized data source on standards uptake.
• The Green Meetings and Events Standards are relatively new, and have not had sufficient time to gain
significant traction in the market.
• The ASTM standards address services and materials for one-time occurrences (i.e., meetings and
events), rather than mass-produced physical products; this makes it difficult to classify a given
manufacturer or service provider as using the ASTM standards on an ongoing basis.
• Finally, the nine standards cover very different aspects of meetings and events, so an event planned to
meet one standard may not necessarily meet the others. Thus, a count of meetings and events certified
to one or more of the ASTM standards (if one were available) would provide an incomplete picture at
best.
3-104
-------
In light of the above limitations, we can provide only limited anecdotal information on the use of the
ASTM Green Meetings and Events Standards, gathered through interviews with industry participants.
One interviewee stated that their company was training its employees on the standards, and starting to
work with clients and business partners to build awareness. The company's aim is to position itself to be
able to meet demand for ASTM-compliant meetings and events, if it materializes. The interviewee stated
that at present, event planners in their company were using some elements of the ASTM standards, but
were not yet designing whole events that would satisfy all of the standards' requirements.
Another interviewee said that while it is too soon to see any major impacts, they expect that in time the
meetings and events standards will change behavior and promote more sustainable events. Meeting
planners' typical approach is to issue RFPs to hotels, convention centers, and other stakeholders for
specific events; the interviewee stated that they expect planners to start incorporating elements of the
ASTM standards into these RFPs. The collaborative nature of event planning also suggests that
knowledge of and experience with the ASTM standards could spread through the industry quickly. The
same interviewee noted that major hotel chains such as Hyatt, Marriott, and Wyndham have already
shown interest in the Green Meetings and Events standards, and used draft versions for some events.
While these are encouraging signs, it appears that the standards will be of limited use to the federal
government. We discuss the reasons for this under Evaluation Question 12. For now, we simply note that
if the federal government (and potentially, other major purchasers as well) does not see the ASTM
standards as a useful procurement tool, it could reduce the number of meeting planners and other industry
participants that choose to use the standards.
QUESTION 12: SUCCESS FACTORS FOR VOLUNTARY CONSENSUS STANDARDS
Introduction
Evaluation Questions 12 asks, "What factors influence the extent to which the voluntary consensus
standard approach is successful in designating and promoting green products and services?" lEc's
findings for Evaluation Question 12 are summarized below. We base our findings on our assessment of
six groups of standards that EPP staff contributed to developing:
• IEEE/EPEAT standards for desktop computers, laptops, and monitors;
• NSF 140 carpet standard;
• NSF 332 resilient flooring standard;
• BIFMA e3/Level standard for office furniture;
• ULE 100 standard for gypsum board; and
• APEX/ASTM green meetings and events standards.
Our assessment draws on several data sources: interviews with EPP staff, non-federal purchasing policy
managers, standards stakeholders, and EPA and GSA hospitality and travel contacts; publicly available
NSF 140 and BIFMA e3 certification data; and data provided by standards development organizations.
3-105
-------
Key Findings
• Market demand drivers play an important role in motivating industry to embrace voluntary standards.
• The history and dynamics within specific sectors also influence the adoption of voluntary standards.
• Market confusion and lack of awareness hinder recognition and use.
• Executive Orders and Federal Acquisition Regulation can push federal buyers to specify purchases
meeting specific standards.
• Promoting voluntary standards is important for raising awareness and increasing adoption; however,
EPP lacks the authority to promote the standards that it helps to develop.
• Cost may not be as much of a barrier as is widely perceived.
• The nature of voluntary consensus standards means that EPP does not control the process. This, in
turn, often requires compromise on substance.
• Developing standards requires effective coordination across multiple parties with competing interests
and perspectives.
• Stakeholders agree that the standards are more environmentally protective with EPP's involvement,
but some question whether they are environmental "leadership" standards.
• Seemingly minor procedural details can influence the substance and content of the standards. For
example, standard development organizations' rules on membership or voting help determine the
relative influence given to different stakeholders. This in turn may affect the provisions that can be
included in a draft standard and garner sufficient support to ultimately be approved.
• EPP needs to remain continuously engaged to ensure ongoing standards improvement.
We group these key findings in two categories: market success factors and other success factors. The
following two sections describe the key findings for each category.
Market Success Factors
lEc identified five market factors that mediate the influence and use of voluntary consensus standards.
The heat map in Exhibit 3-70 arrays these market success factors against six groups of voluntary
standards that EPP staff contributed to developing. Green indicates strong factor presence, yellow
indicates weak factor presence, and red indicates the factor is not present; gray indicates insufficient
information/too early to judge. Each factor is discussed in detail below.
Market demand drivers play an important role in motivating industry to embrace voluntary
standards. Market drivers are required to motivate companies to incur the effort and expense of
certifying to voluntary standards. Large institutional buyers, in particular, can play a significant role in
developing the market for voluntary standards. For example, according to EPP staff and other
stakeholders that participated in developing the EPEAT standards for computers and monitors, the
success of these standards is due, in part, to the strong demand for these products by institutional
purchasers within and outside the federal sector. Federal, state, and local governments, universities, and
corporations purchase large quantities of computers and monitors, and as discussed in the findings for
Question 10, many have adopted EPEAT as a green purchasing criterion. Some EPEAT stakeholders
3-106
-------
expressed uncertainty about whether the EPEAT standard for televisions, which are not as integral to the
operations of many institutional buyers, will achieve a similarly high level of market penetration.
EXHIBIT 3-70. STANDARDS AND MARKET SUCCESS FACTORS
Success Factors
Market demand drivers
IEEE/EPEAT
Computers
and
Monitors
History and dynamics
within sectors
Market clarity and
awareness
NSF 332
Resilient
Floorin
BIFMA
e3/Level
Office
Furniture
ULE100
Gypsum
Board
APEX/ASTM
Meetings
and Events
Executive Orders and
Federal Acquisition
Regulation
Promotion by EPP
Strong factor presence Weak factor presence
Factor not present
Insufficient data/too early to judge
In the building and construction product sector, a number of standards stakeholders noted the absence of
two potentially powerful market demand drivers: GSA Schedules and LEED. With the notable exception
of NSF 140, which GSA requires for most types of carpet, and which received a provisional LEED credit,
voluntary building and construction product standards have not been incorporated into GSA Schedule
requirements or LEED standards. Several interviewees indicated that including other building and
construction product standards in the GSA Schedules and LEED would provide an important incentive
for manufacturers to "green" their products and become certified, particularly because states, local
governments, and many institutional buyers tend to follow the federal government's lead. This is
particularly important for industries that do not have a history of competing on sustainability issues. For
example, flooring and gypsum board stakeholders stated that the standards would gain limited traction in
the market unless they are included in procurement specifications, contract language, and federal codes.
As one gypsum stakeholder put it, "We don't think it's a bad standard, but it's the sort of thing that needs
to be driven by customers. Usually, it would be driven by code standards and programs calling for these
types of certifications, but right now the standard is not written into any code or language, so there are no
demand drivers." Similarly, an NSF 332 representative commented, "Sometimes when these standards are
put in place, businesses have anxiety about whether things will pan out. Some companies want assurances
that this will last before they spend the time and money to get their products certified."
BIFMA may be an exception to this general trend. As discussed in the findings for Question 10, at least
two states - California and Washington - specify BIFMA e3/Level even though this standard is not
included in GSA Advantage or LEED. Also, as noted in the findings for Question 11, a number of
3-107
-------
furniture manufacturers have adopted the standard. However, the survey results indicate that purchaser
use of the BIFMA e3/Level standard is low.
Interviewees in the hospitality and travel sector identified "green" meetings and events as a growth area
for this sector, as reflected in the large and growing level of corporate resources committed to "green"
initiatives and marketing - e.g., sustainable lodging and food. EPA interviewees in regions 9 and 10 also
reported high demand on the west coast for "green" meetings and events. In general, hospitality and travel
stakeholders stated that they expect hotels, convention centers, and other providers of hospitality and
travel services will use the APEX/ASTM Green Meetings and Events standards if meeting planners
specify the standards in their requests for proposal.
The history and dynamics within specific sectors influence the adoption of voluntary standards.
Electronics (computers and monitors) manufacturers were accustomed to competing on sustainability
issues prior to EPEAT, primarily due to Energy Star as well as efforts to reduce waste and recycling of
electronics.
Within the building and construction product category, the success of the NSF 140 carpet standard
reflects, in part, the history and dynamics of the carpet industry. Specifically, Ray Anderson, the founder
of Interface Flooring, served on President Bill Clinton's Council on Sustainability and was an early
adopter of sustainable business practices. With Interface leading on sustainability issues, sustainability
became a competitive issue for the carpet industry from as early as the 1990s. Several other standards that
address carpet were developed prior to NSF 140, including GreenGuard, Green Label, Cradle to Cradle,
and the Scientific Certification Systems (SCS) carpet standard. California adopted the SCS standard, but
subsequently developed its own California Gold Sustainable Carpet Standard. Interviewees who
participated in the NSF 140 standard committee stated that California's actions put pressure on the carpet
industry to develop one unified standard that would be accepted nationwide. (The State of California
subsequently replaced California Gold with NSF 140 Platinum.) Similarly, carpet manufacturers had a
strong incentive to embrace the final version of the standard, owing to the industry's history of competing
on sustainability issues and the fact that purchasers were requiring environmentally preferable carpet.
The focus on sustainability among carpet manufacturers put competitive pressure on the resilient flooring
industry to develop its own standard, so as not to appear "behind the curve" on sustainability issues.
However, manufacturers have been slower to certify to NSF 332 than NSF 140; according to interviewees
who participated in the development of both standards, this may be due, in part, to the resilient flooring
industry's shorter history of competing on sustainability issues, and the absence of a clear sustainability
"leader" in the resilient flooring sector.
In the furniture sector, the proliferation of ecolabels and standards in other sectors was one impetus
behind the development and subsequent adoption of the BIFMA e3 standard by manufacturers; moreover,
some furniture manufacturers have a history of using sustainable wood. Gypsum board does not have a
history of competing on sustainability issues, although two large gypsum board manufacturers are
currently marketing their ULE 100 certification.
The travel and hospitality sector has a history of competing on sustainability issues. For example, even
before the publication of the APEX/ASTM Green Meetings and Events standards, the Convention
Industry Council (CIC)'s Accepted Practices Exchange (APEX) was providing information on best
practices for green meetings and events. Similarly, a leading meetings and events service provider
3-108
-------
reported that their company has been working on environmental issues for the past six to eight years,
which suggests the company views sustainability as a competitive issue.
Greater market clarity and awareness raise the likelihood that manufacturers and purchasers will
recognize and use a standard. Manufacturers and purchasers need to be aware that standards exist
before they will certify to or require the standards. Moreover, standards need to pass muster with the
federal government, which requires that the standards have (or are perceived to have) a sufficiently high
degree of environmental protectiveness.
It takes time for any new standards to gain recognition, but it is particularly challenging when the EPP
Program and the rest of the government is hindered in its ability to actively promote the standards (see
discussion below). In addition, companies and buyers need clarity about which standards will be required
and which should be adopted; this becomes much more difficult when there are competing standards for
the same product or service category. For example, EPP Program staff attributed some measure of
EPEAT's success to the fact that no other comprehensive standards existed for computers prior to
EPEAT. Similarly, although NSF 140 is not the only carpet standard, it has enjoyed a fair amount of
recognition and broad acceptance; for example, the State of California adopted NSF 140 Platinum to
replace California Gold.
On the other hand, there has been a significant amount of debate within the furniture industry between the
Forestry Stewardship Council and the Sustainable Forestry Initiative about what constitutes sustainable
wood. The BIFMA e3/Level standard was delayed for more than a year because of this debate, and this is
also a major cause of delay in releasing the latest version of LEED. This situation has created uncertainty
in the market which, according to some stakeholders, has made it more difficult for the government to
specify the BIFMA e3 standard. It is possible that other competing furniture standards, such as Cradle to
Grave, are also contributing to uncertainty in the market.
On a related note, two stakeholders questioned whether the market is moving away from voluntary
consensus standards in favor of environmental product declarations (EPDs). One of these stakeholders
observed that the voluntary standards are not only competing with other standards, but with EPDs and
other sustainability initiatives. Lack of market clarity hinders buyers' ability to specify the standards, and
reduces manufacturers' incentives to certify to these standards.
As discussed in the findings for Questions 6 and 11, EPP staff indicated that the federal government does
not view the APEX/ASTM meetings and events standards as being sufficiently protective of the
environment, and does not plan to adopt these standards in federal procurement requirements. While it is
too early to judge the market uptake of these standards, experience in other sectors suggests that the
federal government's decision not to specify the APEX/ASTM meetings and events standards may put a
damper on their adoption in the market.
Executive Orders and Federal Acquisition Regulation can push federal buyers to specify standards.
EPEAT is the only voluntary consensus standard among those that EPP helped to develop that was
explicitly referenced in Executive Order (EO) 13514 and the Federal Acquisition Regulation (FAR).147
According to EPP staff, manufacturers, and other standards stakeholders in the electronics sector and the
147
EPP staff filed the proposal to include EPEAT in the FAR. However, EPA has been told that specifying additional individual environmentally
preferable standards in the FAR will not be allowed due to concerns expressed by the United States Trade Representative (USTR).
3-109
-------
building and construction products sector, the inclusion of EPEAT in EO 13514 and the FAR partly
explains EPEAT's significant success. The inclusion of EPEAT in the EO and the FAR raised the
standard's profile, and motivates federal buyers to specify purchases meeting the standard. It may also
explain why more state purchasers adopted EPEAT compared to the other standards that EPP helped to
develop, as many state purchasers follow official federal signals regarding green purchasing preferences.
Given the vast market power of the federal government, it is possible that federal purchases of EPEAT
products, and subsequent EPEAT purchases at the state level, helped to galvanize the market for EPEAT
products, and build institutional and even consumer awareness for the label. With high federal and state
demand for EPEAT products, manufacturers were incentivized to offer more models that were certified to
the label. It is also likely that changes to production or sourcing required to manufacture EPEAT products
became more affordable for manufacturers, and more engrained, as the volume of EPEAT product sales
increased. In terms of awareness, the visual ubiquity of the EPEAT label at federal and state offices likely
raises awareness of EPEAT; for example, if a consumer visits a state or federal office and sees EPEAT
computers, he or she may become aware of the label. Or if that individual uses an EPEAT computer at
work, he or she is likely aware of the label, and may be more likely to consider purchasing an EPEAT
computer for home use.
Finally, inclusion in the EOs and in the FAR has given EPP and the federal government greater flexibility
to promote the standard, including the development of the FEC program (see below).
Promoting voluntary standards is important for raising awareness and increasing adoption; however, EPP
lacks the authority to promote the standards that it helps to develop. Among the standards considered in
this evaluation, EPEAT is the only standard that EPA has actively promoted. The Federal Electronics
Challenge (FEC) and the Federal Electronics Stewardship Workgroup have promoted EPEAT to federal
buyers, as has EPP staff through conferences, workshops, and awards. The active promotion of EPEAT is
one factor in the widespread adoption of the standard for computers and monitors. However, one EPP
staff member reported that within the past year, there has been less support within EPA for efforts to
promote EPEAT.
With the exception of EPEAT, EPP has not actively promoted the voluntary standards that it helped to
develop. This reflects, in part, an ongoing discussion across EPA, GSA, other federal agencies, and
industry about the criteria that the government should use when evaluating and specifying standards. It
also reflects the federal government's inability to "endorse" private standards, products, and services. As
such, EPP is largely dependent on manufacturers to educate their customers and promote the standards.
Some manufacturers have promoted, and continue to promote, voluntary standards that they certify to, but
they are looking to EPP to assume a more active role in promotional activities. A few industry
stakeholders expressed concerns that if GSA and other agencies only promote and specify standards
developed by the government, such as Energy Star and WaterSense, it will put voluntary consensus
standards at a disadvantage. Although this is a policy issue that is mostly beyond EPP's control, it affects
market recognition and adoption of the standards.
3-110
-------
The federal government recognizes this
challenge and is taking steps to address it.
Specifically, EPA, in consultation with
GSA and other agencies, has developed
draft Guidelines to evaluate environmental
performance standards, including but not
limited to the standards that EPP helped to
develop (see sidebar). Once implemented,
the Guidelines could provide a means for
the federal government to recognize
voluntary consensus standards, subject to
the provisions in the NTTAA and OMB
Circular A-l 19 (see below).
Other Success Factors
The evaluators examined a number of other
success factors, including the following:
Cost may not be as much of a barrier as
is widely perceived. Some interviewees
reiterated the widely held view that cost is
a barrier to certification, especially for
small businesses. However, data provided
to EPA's Office of Policy by 10 standards
development organizations, which manage
more than 200 standards, suggest that more
than 40% of businesses qualifying for the
leading North American, non-federal
product environmental standards are small
businesses, defined for this sector as
having annual revenues under $25 million
and/or fewer than 500 employees.148
Available data indicate that over half of
firms with products qualifying for BIFMA
e3/Level certification have fewer than 500
employees. More than half of the
companies with products qualifying for the
leading environmental standards of ULE,
EcoLogo, and GreenGuard have annual
revenues under $25 million; only about 9%
of companies qualifying for these standards
would qualify as Fortune 500 firms based
on their revenues. It appears that a similar
DRAFT EPA GUIDELINES FOR EVALUATING STANDARDS AND
ECOLABELS
Federal agencies face a number of requirements on
sustainable procurement. Most notably, EO 13514 requires
95% of the government's purchases to be sustainable. In
addition, the NTTAA directs agencies to "use technical
standards that are developed or adopted by voluntary
consensus standards bodies, using such technical standards
as a means to carry out policy objectives or activities,"
except when "inconsistent with applicable law or
otherwise impractical."
However, as discussed in this report, federal purchasers
have indicated uncertainty regarding which product
sustainability standards are appropriate for use in
purchasing. For example, as discussed in Evaluation
Question 6, only a minority of purchasers made regular use
of the standards addressed in this evaluation.
Informational barriers have led to an inconsistent
approach to using standards and ecolabels in federal
procurement.
To address these issues, EPA, in collaboration with other
agencies, has developed a set of draft Guidelines to
evaluate non-governmental environmental standards and
ecolabels for use in federal procurement. These
Guidelines provide a means to evaluate the robustness of
product sustainability standards alongside federal
requirements and mission needs. The Guidelines are
organized into four categories, including standard setting
process, standard substance, conformity assessment, and
ecolabel program management. The primary outcome of
this evaluation will be a list of conforming sustainability
standards and ecolabels.
If widely adopted for use by federal agencies, the
Guidelines could have numerous benefits with respect to
promoting environmentally preferable purchasing. Most
directly, the Guidelines are intended to provide clarity as
to the standards and ecolabels, and therefore products,
that EPA considers "environmentally preferable." The
Guidelines could also be used to make sustainable
purchasing choices the default, by adding approved
standards as "default selections" in acquisition planning
systems to contract terms. Furthermore, consistent use of
a list of recognized products could be used to facilitate
better tracking of "green spend." For example, the
federal Procurement Data System Next Generation (FPDS-
NG) could be aligned with the Guidelines.
! Personal communication between individual standards development organizations and Stephan Sylvan, EPA's Office of Policy.
3-111
-------
share of small businesses qualify for GreenSeal standards. Thus, while the cost of green product
certification may be an important consideration for some firms, available data suggest that cost is not a
prohibitive barrier for many smaller firms.
The voluntary consensus standards process requires EPP to relinquish control of the process and to
compromise on substance. EPP's efforts to develop voluntary, consensus-based standards are guided by
the National Technology Transfer and Advancement Act or NTTAA (Public Law 104-113), which directs
federal agencies and departments to "use technical standards that are developed or adopted by voluntary
consensus standards bodies," with limited exceptions, and provides that the government "shall, when such
participation is in the public interest and is compatible with agency and departmental missions,
authorities, priorities, and budget resources, participate with such [voluntary, private sector, consensus
standards] bodies in the development of technical standards." OMB Circular A-l 19, "Federal
Participation in the Development and Use of Voluntary Consensus Standards and in Conformity
Assessment Activities," establishes policies on federal use and development of voluntary consensus
standards.
The nature of the voluntary consensus standard process requires compromise. According to EPA's
Standards Executive, "No one should go into these standard development processes and demand and
expect to get everything. These processes require compromise while working together with industry."
The requirement to go through the voluntary consensus standard process, and the compromise that the
process requires, have implications for the substance of the standards that EPP helps to develop. Put
simply, standards developed through a voluntary consensus process, which includes negotiations with
industry representatives, may not be as environmentally protective as standards that the government
develops on its own.
The process also has implications for assessing EPP's contribution to the development of standards - i.e.,
the fact that a standard may not incorporate all of EPP's recommendations reflects the framework in
which EPP is required to operate; it does not reflect a failure on the part of EPP staff. A better measure of
success is the extent to which standards are more protective of the environment than they would have
been without EPP's involvement. By this measure, EPP has performed well; as discussed in the findings
for Question 6, all of the standards that we assessed are more protective of the environment than they
would have been without EPP's input.
Developing standards requires effective coordination across multiple parties with competing
interests and perspectives. This finding is borne out from EPP's experience coordinating with various
stakeholders in developing the standards covered by this evaluation. A number of interviewees noted that
coordination within EPA (for example, between EPA Headquarters and the regions) can be as challenging
as fostering coordination between EPA and industry. For example, EPA Headquarters and the regions had
different visions for the Green Meetings and Events standards: EPA Headquarters was focused on
quantifiable environmental outcomes, whereas the regions were more focused on management practices.
Despite the different visions of what the standards should be, this issue was not addressed explicitly until
the process was well underway. In retrospect, an upfront discussion and resolution about the purpose and
objectives of the standards would have been helpful.
Other standard stakeholders observed that the attitude and temperament of EPP staff can also enhance or
diminish their effectiveness. Industry representatives, in particular, appreciated EPP's willingness to work
with industry and other stakeholders rather than dictate the terms of the standard. For example,
3-112
-------
stakeholders described the EPP representative on the NSF 140 committee as "fair and reasonable."
Although industry was aware that the standards would ultimately need to pass muster with EPA, EPP
staff was careful not to "overplay their hand," as one stakeholder put it. Stakeholders also appreciated
EPP's ability to marshal scientific evidence to inform the debate. Similarly, EPP staff noted that a key
part of their role in the standard development process is coordinating with subject matter experts from
across EPA to provide input on the standards. In the case of EPEAT, some industry stakeholders
expressed concerns that EPP staff was too insistent that certain environmental provisions be included in
the computer standard. While this may be true from industry's perspective, EPP's firmness on these
issues resulted in a more environmentally robust standard.
Stakeholders agree that the standards are more environmentally protective with EPP's
involvement, but some question whether they are environmental "leadership" standards. In
particular, some EPP staff and standards stakeholders expressed concerns about EPEAT and NSF 140,
noting the high adoption rate of both standards in their respective industries. One interviewee whose
company sells certified carpet products cited an article in Environmental Building News that compared
NSF 140 and BIFMA e3/Level (among other standards); the article noted that while a majority of NSF
140 certified products are certified to platinum - the highest level - and some to gold, only 20% of
BIFMA e3/Level certified products have achieved gold, and less than 1% have achieved platinum.149 One
interpretation is that NSF 140 is less rigorous than BIFMA e3/Level, is easier to certify to, and is
therefore not a true leadership standard. However, other observers note that the carpet industry got a
"head start" on sustainability issues and may be farther along the path to sustainability (see below);
further, the State of California and other large buyers demand NSF 140 Platinum, making it less
worthwhile for manufacturers to certify to the other levels of the standard.150 Regardless, critics contend
that if the majority of products are certified to the highest level, buyers cannot differentiate across
products.
A similar critique has been made for EPEAT: Given the very high level of adoption of the IEEE 1680.2
standard for computers and monitors, it has become difficult to differentiate across products that are
certified to the standard. Moreover, as EPEAT gains market share and expands into new product
categories, some manufacturers are pushing back on certain environmental criteria (e.g., Energy Star
specifications). Industry players have become far more active in IEEE since the development of the
EPEAT computer standards in 2006. In fact, there are indications that large industry players may have
largely "captured" the IEEE standard development process for EPEAT televisions and imaging
equipment.151 In December 2012, in response to industry pressure, IEEE dissolved the consensus-based
taskforce that develops the policies and procedures that govern the standard development process.152 EPA
is under pressure from environmental groups to abandon IEEE in favor of another standards organization
for future EPEAT standards.153
149 Atlee, Jennifer, "What's New in Multi-Attribute Environmental Certifications." Environmental Building News, Vol. 19, No. 12, December 2010.
150 Ibid.
151 Kyle, Barbara, "Big Electronics: Bully of the eco-label playground." Electronics TakeBack Coalition, January 29, 2013.
http://www.electronicstakeback.com/2013/01/29/big-electronics-bullv-of-the-eco-label-playground/.
152 Ibid.
153 Ibid.
3-113
-------
The new EPEAT television and imaging equipment standards are not as stringent as the computer
standard was when it came out in 2006. In 2006, no model qualified for gold for at least six months, and
most models only qualified at bronze for years. Gold was a "reach" for most manufacturers for a time, as
the Green Electronics Council noted in 2008.154'155 In contrast, at the end of February 2008, the registry
for imaging equipment had been open for two months and already had 28 gold products, 70 silver
products, and 86 bronze products. Put differently, 15% of total registered imaging equipment was gold
certified and more than half (53%) was gold or silver certified within two months of the registry's
opening. The data corroborates concerns that the EPEAT standard for TVs and imaging equipment is not
a leadership standard.
Seemingly minor procedural details can influence the substance and content of the standards.
Different standard development organizations (SDOs) have different procedures, and seemingly minor
procedural issues can influence the outcome. EPP staff noted the importance of understanding differences
across SDOs and choosing the best SDO for the task at hand. Further, regardless of the SDO selected for
a particular standard, EPP needs to understand the rules before engaging; this is a key lesson learned
based on EPP's experience to date. For example, EPP staff acknowledged that IEEE's rules presented
challenges that EPP did not fully understand when they selected IEEE to develop EPEAT. IEEE's rules
require a three-fourths majority of all voting members to pass anything, which can make it difficult to get
things done. IEEE has two membership categories - individuals and organizations - and the committee
chose individual membership because it costs less, and would give everyone an opportunity to participate
regardless of finances. However, because every individual gets one vote, larger organizations with more
members have greater influence. New members can join at any time: one manufacturer joined six months
into the process and wanted to revisit major decisions that the group had already made; another
manufacturer reportedly sent staff to the committee "for the express purpose of opposing certain criteria"
in the standard.
In a similar vein, a stakeholder on the ASTM Green Meeting and Events committee noted that EPA
Headquarters staff and event planners were not familiar with the ASTM process; as a result, "there were a
number of false starts, where the group put a huge amount of effort into things that went nowhere." At the
same time, it should be acknowledged that the voluntary standard process was new for many of the
participants involved, and EPP staff has learned from experience. For example, a standards stakeholder
who participated in developing NSF 140 and NSF 332 stated that their experience with carpet informed
the committee's approach to flooring.
Standard development is an ongoing process, subject to advances as well as setbacks; EPP needs to
remain continuously engaged to ensure ongoing environmental improvement. In some sense,
voluntary consensus standards are never really "final"; rather, they continue to go through new iterations
and revisions. As one industry stakeholder noted, "There's an expectation that standards will keep getting
belter and better, but that's not necessarily so."
1MGreen Electronics Council. "Environmental Benefits of 2007 EPEAT Purchasing." May 2008. P. 9.
155 Omelchuck, Jeff and Wayne Rifer (Green Electronics Council), "Product Stewardship in the Real World: Why the new EPEAT standard for
electronics has been so successful." ISSP Insight, October 2008. http://www.sustainabilityprofessionals.org/files/ProductStewardshiplnsight.pdf.
3-114
-------
EPP's ongoing involvement may be needed to ensure that successful standards remain leadership
standards. As the same industry stakeholder noted, "Carrying the burden is onerous; it gets harder and
harder as time goes on, because companies tend to do the easier things first." For example, now that a
majority of NSF 140 certified carpet meets the highest level (platinum), it may be time to revisit the
criteria for platinum certification to ensure that NSF 140 remains a leadership standard.
Ongoing involvement by EPP staff may also be needed to prevent backsliding. As noted above, since the
initial version of IEEE 1680.2 was published, some industry stakeholders have sought to remove the
requirement for products to meet Energy Star specifications. EPA has held firm on this issue and has so
far managed to prevent this change from occurring. However, this example illustrates the importance of
EPP continuing to be involved in standards committees even after the initial version becomes "final."
Similarly, one of the APEX/ASTM Green Meetings and Events standards stakeholders stated that the
current version of the standards is "too rigorous," but went on to state, "This is just the first cut, so we can
revisit it later."
QUESTION 13: EPP EFFECTS ON THE MARKETPLACE
Question 13 asks, "How has EPP affected the availability of environmentally preferable goods and
services in the marketplace?" The answer to this question is influenced by all of the factors covered in
Evaluation Questions 10-12. Thus, this section briefly summarizes relevant key findings for the previous
evaluation questions, organized by EPP product/service category:
• Electronics: EPEAT is a major force in the electronics sector. A number of cities, states, universities,
businesses, and other non-federal purchasers inside and outside of the U.S. have adopted EPEAT, and
most if not all major manufacturers participate in EPEAT, including the top five computer companies
worldwide and in the U.S. (as of 2010). EPEAT's market presence has grown markedly since the
program's inception. More than 50 million EPEAT certified products were purchased in the U.S. in
2010, and nearly 100 million worldwide. EPEAT's total sales and market share of laptop computers,
in particular, have grown dramatically. U.S. purchases of EPEAT certified laptops tripled from 10
million units in 2007 to 32 million units in 2010; U.S. market share increased from 35% to 72% over
the same time period. EPEAT's total sales and market share of desktop computers and monitors have
fallen, but this reflects the broad market shift away from desktops and towards laptops; total sales
across all EPEAT products have continued to increase. As calculated by the EEBC and reported in
EPEAT's annual benefits reports, the environmental benefits of EPEAT purchases are substantial.
• Building and construction products: The NSF 140 carpet standard and BIFMA e3/Level furniture
standard have gained traction with non-federal purchasers and have enjoyed widespread adoption by
manufacturers. At least 13 states and two universities have adopted NSF 140, and at least two states
are specifying to BIFMA e3/Level. The 13 manufacturers of NSF 140 certified carpet account for a
clear majority of the global carpet market. The 48 companies with products certified under BIFMA
e3/Level account for about 45% of BIFMA members, and these 110 BIFMA members produce an
estimated 80% of office furniture sold in North America. However, the survey results indicate more
limited use of the BIFMA e3/Level standard by federal purchasers. NSF 332 (resilient flooring) and
ULE ISR 100 (gypsum board) have been less successful in gaining adoption by manufacturers,
although the two largest U.S. gypsum board companies, which are responsible for a majority of the
3-115
-------
market, certify to ULE ISR 100. Quantitative data are not available on total sales or market share of
environmentally preferable building and construction products.
• Hospitality and travel services: Quantitative data are not available on the use of the ASTM Green
Meetings and Events standards, which were only approved in 2012. However, at least two states are
already using hospitality and travel tools developed by EPP. Interviews provided some anecdotal
evidence that event planners are beginning to use the ASTM standards, and expect more uptake in the
future. However, if the federal government does not use the standards, it may limit their use by event
planners and other industry participants.
The evaluation identified several factors contributing to the market success of voluntary standards,
including: market demand drivers (e.g., including certified products in GSA Schedules); history and
dynamics within specific sectors; market awareness and clarity around standards and ecolabels; and
inclusion in Executive Orders and the Federal Acquisition Regulation.
3-116
-------
CHAPTER 4 | RECOMMENDATIONS
Based on the findings of the evaluation, lEc presents recommendations below. For recommendation areas
where EPP has a large degree of control over outcomes, we frame recommendations as EPP "should"
undertake activities that the evaluation findings suggest are critical; we say that EPP "should consider"
undertaking activities that are not critical. However, several of the recommendations below address
challenges that the EPP Program has limited control over, including 1) advancing the implementation and
use of EPA's forthcoming guidelines for evaluating environmental standards and ecolabels, which will
result in a list of select voluntary consensus standards recommended for use in federal procurement, and
2) updating procurement systems used by other federal agencies to track green purchasing. We make
recommendations in these two areas because they are very important to fulfilling EPP's mission and
demonstrating the program's impact. Although EPP has limited control over outcomes in these two areas,
we think that limited, if any, progress will be made in these areas without EPP's involvement. In these
two areas, we often frame recommendations as EPP working with other agencies, playing a leadership
role, and advocating for change. This work can entail different activities depending on the context, but in
general we are referring to EPP leading the coordination of interagency work on these issues, and EPP
regularly communicating about the importance of these issues with decision-makers within EPA and
outside of the Agency. EPP is already demonstrating this type of leadership in advancing the guidelines
for evaluating standards and ecolabels; we suggest that EPP engage in similar work to overcome
procurement data challenges.
EPP STANDARDS DEVELOPMENT AND PROMOTION
• The federal government should develop a list of recommended environmental standards and ecolabels
for use in federal procurement to: overcome informational barriers to green purchasing among federal
buyers by identifying recognized standards and certified products on federal procurement sites;
clarify the landscape of standards for non-federal buyers and subsequently reduce greenwashing; and
to allow EPP to promote the voluntary consensus standards that it helps to develop. As such, EPP
should continue its leadership role in discussions of formal guidelines for evaluating
environmental standards and ecolabels that can lead to the development of the above list.
• If the guidelines process moves ahead in 2013,156 and leads to the development of a widely
utilized and referenced list of environmental standards and ecolabels, then EPP should continue
to participate in the development of new voluntary consensus standards on the same scale as in
recent years, resources permitting. Given the lessons learned from the evaluation regarding
successful standards, we recommend that EPP apply the following factors when selecting future
product categories and standards development processes to engage in:
EPA published draft guidelines for public comment (http://www.epa.gov/epp/draftGuidelines/) on November 20, 2013, as this report was being
finalized.
4-1
-------
o Positive market success factors identified in this evaluation;
o Potentially high environmental benefit relative to other product categories; and
o Availability of a standards development organization appropriate for the particular standard being
considered (in terms of relevance, policies and procedures, etc.).
• If the guidelines process is not finalized in 2014, or results in a list that is not widely used or
referenced outside of EPA, then EPP should narrow its participation in new voluntary
consensus standards development moving forward. Specifically, EPP should focus on product
categories that have positive market success factors and have a consumer audience. These product
categories are most likely to have green standards succeed, in terms of market penetration, without
federal recognition and promotion. EPP may want to consider developing federal standards (i.e., such
as Energy Star and WaterSense) for product categories that do not meet these criteria.
• If the guidelines are finalized, EPP should develop and execute a promotion campaign for
federally recognized standards that emerge from the process and that EPP supports, perhaps in
collaboration with GSA and other federal partners. Survey results from this evaluation indicate that
EPEAT registered products and building and construction standards are utilized by less than one-third
of federal purchasers that report buying relevant products. We would expect that more purchasers
would procure more certified products once they are clearly identified in federal procurement
systems, but promotion may also be necessary to make substantial progress toward the 95% green
procurement requirement.
• EPP should continue to remain engaged with standards that it has worked on to date, to ensure
that environmental considerations are appropriately addressed as standards are revised.
Stakeholders have raised concerns about the potential for standards to be weakened over time with
respect to environmental protectiveness if EPP does not stay involved.
• Given that inclusion in the EO 13514 and FAR were key to EPEAT's success, EPP should work
with GSA, CEQ, OFEE, and other relevant agencies to advocate for including federally
recognized standards in the FAR.
• In future standards development processes, EPP should ensure that all EPA staff involved in
developing the standard, and ideally all federal staff, engage in an upfront dialog to ensure a
shared understanding of how the process will work and the federal goals for the standard. Lack
of upfront agreement hindered travel and hospitality standards processes in particular.
• EPP should continue to work to include building and construction standards in GSA Schedules
and in the USGBC LEED family of standards, which are key market drivers for this product
category. Currently, only the NSF 140 carpet standard is included in a GSA Schedule, and LEED has
not incorporated any of the building and construction standards that EPP has worked on in a
meaningful way.
OTHER EPP RESOURCES FOR PURCHASERS
• Given that purchasers rely more on resources developed by their own agencies than on EPP
resources, EPP should consider reviewing other agencies' purchasing policies and procedures to
see if they generally comport with EPP's model policies, contract language, and specifications.
4-2
-------
If not, EPP should reach out to agencies to inform them about EPP tools and how they may be
beneficial in helping agencies reach the 95% green procurement requirement contained in EO 13514.
If EPP undertakes this review, it should prioritize agencies according to their level of purchasing (i.e.,
focus on the largest purchasers) and extent of purchasing in sectors for which EPP has developed
standards, tools, and resources.
• EPP should update its website to ensure that content is current, and to provide information on
federally recognized standards that it has helped to develop. The survey found that EPP's website
is the EPP resource that federal purchasers report using the most.
ADDITIONAL RESEARCH
• Currently, no existing methodology or calculator exists to quantify the environmental benefits of
purchasing greener building and construction products, which limits EPP's understanding of its
impact in this area. Thus, we recommend that EPP should develop environmental benefits
calculators for building and construction products that the program works on.
• Similarly, no existing methodology or calculator existing to quantify the environmental benefits of
purchasing greener travel and hospitality services, which will limit EPP's understanding of its impact
in this area in the future. Thus, we recommend that EPP should work to develop a methodology or
calculator for travel and hospitality, in particular for capturing the energy savings and GHG
emission reductions associated with greener air travel (or avoided air travel). The work already
developed by EPP under the City Pairs program may provide a foundation for developing a
methodology or calculator.
• Federal purchasers are generally instructed to purchase goods and services that provide the "best
value" to the government. Factors included in making a best value determination can include initial
price and several other factors including past performance, product lifespan, product warranties, and
environmental and energy efficiency considerations.157 To analyze price and energy efficiency
together, the purchaser would need to know the lifecycle cost of the product, factoring in energy use.
Most simply, a lifecycle cost analysis would entail adding the initial price of the product to the
projected cost of energy use of the product over the product's lifespan. The survey results forthis
evaluation found that approximately one-third of purchasers emphasize first costs over lifecycle costs
in purchasing decisions. It can be difficult and time-consuming for purchasers to estimate lifecycle
costs; purchases may need to research product energy use and lifespans, and perform some
mathematical calculations. Thus, to address the issue of lifecycle costs and simplify the process for
purchasers, EPP should consider supporting analyses designed to develop a recommended price
premium allowance for first costs, for product categories such as electronics where significant
energy use occurs during the use of the product. Ultimately, these allowances could be
programmed into procurement systems so they are clearly visible to purchasers.
• EPP should consider supporting additional research to better understand the market
penetration of EPP standards in the domestic private sector. Existing data and literature provide
good insights only for market penetration among states and institutions of higher learning (with the
exception of EPEAT).
' Federal Acquisition Regulation, Section 8.405-1, available at: http://www.acquisition.gov/far/current/pdf/FAR.pdf
4-3
-------
• EPP should consider supporting additional research to understand if and/or how the building
and construction standards that it helped to develop could be marketed internationally
(researching international markets was out of the scope of this evaluation).
• EPP should consider conducting limited additional research to understand the limited use of
the BIFMA standard among federal purchasers, despite generally positive market factors, and
to investigate whether BIFMA uptake is higher in the private sector. We hypothesize that
BIFMA may have higher uptake in the private sector because furniture is the least commoditized of
all products included in this evaluation, and BIFMA may be more popular among higher-end
commercial buyers and consumers.
• EPP should consider conducting additional research to understand the program's indirect
influence and spillover effects. This evaluation was not able to probe the indirect or spillover effects
of EPP's activities, although we have indications that these effects may be substantial. EPP's diverse
audiences - including federal agencies, purchasing managers, procurement staff, state and
institutional buyers, manufacturers, suppliers, vendors, and the public - constitute a "network"
through which EPP disseminates information and tools beyond the confines of the program.
Innovative evaluation techniques, such as Social Network Analysis (SNA), may help EPP understand
how information flows from the program to its intended audiences.158
• The Federal Acquisition Institute (FAI), which administered the federal purchaser survey used for this
evaluation, provides training for federal procurement staff that covers incorporating green criteria into
purchasing. EPP should work with FAI to ensure that FAI's training reflects the barriers
identified in the federal purchaser survey.
PROCUREMENT DATA RECOMMENDATIONS
• EPP should work with OARM and other federal agencies to facilitate tracking of green product
and service sales to the federal government via comprehensive systems updating. Barring this
change, the federal government will not be able to fully assess its performance against the 95%
green procurement requirement included in EO 13514, and EPP will not be able to assess its
own impact in a comprehensive manner, outside of EPEAT.
o EPP should work with OARM to update EPA's EAS procurement system, and any other relevant
procurement systems, to facilitate tracking of green product sales to the Agency.
o EPP should advocate for updating federal procurement systems to facilitate tracking of green
product sales, and specifically tracking of all green standards and ecolabels recognized by the
158 SNA maps relationships and flows of information and knowledge between people, groups, or organizations. (Presentation by Chris Ellis, National
Oceanic and Atmospheric Administration (NOAA), "Social Network Analysis and Evaluation," 2010 Environmental Networking Evaluators Forum,
Washington D.C.) SNA typically relies on surveys of individuals within a network to understand with whom they are collaborating, on whom they rely
for information, and what types of information they have gathered. The information gathered through the surveys is then mapped to show the
pattern and strength of information flows through a network. This analysis can then be repeated after a period of time to assess how information
flows have changed. Applying SNA over time allows a series of "snapshots" of network structure, which could logically be related to immediate
program outcomes and be correlated with program activities and outputs. (However SNA does not prove that changes in network structure are the
result of program impacts.)
4-4
-------
federal government.159 Although all procurement systems should be updated, EPP should
prioritize working with agencies with high levels of purchasing: GSA Advantage!; DOD
EMALL; and internal procurement systems within DHS, HHS, DOE, and other agencies with
relatively high levels of purchasing.
o EPP should work with GSA to update the Federal Procurement Data System (FPDS-NG), which
stores all federal procurements over $3000, to store green attributes associated with purchasing
data (i.e., the environmental standard or ecolabel that purchased products or services are certified
to). Updating FPDS will enable the federal government to manage green purchasing data from all
of the government's procurement systems in one central database, facilitating analysis of green
purchasing data moving forward.
• EPP should inform OMB about problems encountered with their data on government EPEAT and
non-EPEAT purchases, which are used for official reporting purposes. lEc does not have enough
information about OMB's data collection and QA/QC process to diagnose the root cause of the
problems, but our review of the OMB data in conjunction with manufacturer-supplied sources of
EPEAT data indicates that several of OMB's data points do not accurately reflect actual government
purchases. If the above procurement data recommendations are implemented, OMB will have access
to comprehensive federal purchasing data on EPEAT and non-EPEAT products, directly from federal
procurement systems, and will no longer need to ask agencies to self-report EPEAT and non-EPEAT
purchases. As an interim measure, OMB and EPP could consider asking the Green Electronics
Council (GEC) to gather data on sales of non-EPEAT purchases to the federal government, along
with the EPEAT sales data that GEC already collects in collaboration with the Information
Technology Industry Council (ITI). However, a potential barrier to this approach may be GEC/ITI's
ability to gather data that is not covered by manufacturers' agreements with EPEAT.
MEASUREMENT RECOMMENDATION
• Evaluation Question 8 asked about the cause of apparent "backsliding" by FEC partners. lEc's
analysis showed that actual backsliding was minimal, and the apparent backsliding was actually due
to reporting fluctuations and changes in the number of monitors in use. Using proportions as part of
FEC metrics would prevent this false appearance of backsliding. Thus, FEC should track and report
proportion-based annual metrics to PPD, in addition to the estimated energy savings it has been
reporting:
o The percentage of computers and monitors, across all FEC partner facilities, that is Energy Star-
enabled.
o The percentage of computers, monitors, and printers, across all FEC partner facilities, that is
disposed of through reuse, recycling, landfilling, and unknown disposition.
o For the new life extension area, the average lifespan of computers, monitors, and printers across
all FEC partner facilities.
159 See recommendation on Section 13 for discussion on the need to expand standards and ecolabels recognized by the federal government to
include third-party standards and ecolabels.
4-5
-------
We recommend that PPD use only proportion-based measures to assess FEC's performance
because absolute energy savings are driven by several factors in addition to performance of
FEC facilities, including the number of FEC reporters in a given year and annual fluctuations
in equipment use. However, we understand that FEC and PPD must continue to report FEC data on
existing measures because FEC data are aggregated with data from other programs to assess progress
on specific measures included in EPA's Strategic Plan.160
160 As noted previously, after lEc completed this evaluation, EPA decided to undertake substantial changes to the FEC program model. As a result,
some of the recommendations regarding the FEC appearing in this report may no longer be applicable to the program in its current form.
Nonetheless, we have left the recommendations in our report unchanged in order to more accurately document our evaluation of the FEC as it
existed at the time of our analysis.
4-6
------- |