OregonDOT_LCTM_App-to-share.pdf

Grant Proposal

Low-Carbon Transportation Materials Program

Inflation Reduction Act Section 60506

Volume 1: Technical Application

Submitted by: Oregon Department of Transportation (ODOT)

Date: June 6, 2024

Funding Requested: $40,500,000

Agency Technical Contact: Zechariah Heck

555 13th Street NE | Salem, OR 97301 zechariah.heck@odot.oregon.gov

503-779-4815 i

1. Introduction

2. Program Alignment with Federal Priorities

2.1. Climate Change and Sustainability

2.2. Safety

2.3. Equity and Environmental Justice

2.4. Workforce Development, Job Quality, and Wealth Creation

3. Project Description

3.1. Overview

3.2. Technical Description

3.2.1. Task 1 – Establish Framework for LCTM Program Implementation

3.2.2. Task 2 – Low-Carbon Materials Quality Assurance and Specifications

3.2.3. Task 3 – Identify Eligible Projects

3.2.4. Task 4 – Expand Use of Low-Carbon Materials on Projects

3.2.5. Task 5 - Substantially Lower Embodied Carbon

3.2.6. Task 6 - Quality Assurance and Acceptance

3.2.7. Task 7 – Institutionalize the Use of Low-Carbon Materials

3.3. Team Information

3.3.1. ODOT Personnel

3.3.2. Anticipated Partners

3.4. Overall Readiness

3.4.1. Schedule

3.4.2. Project Risks and Mitigation Strategies

3.5. Eligible Application Factors

1. Introduction

The Federal Highway Administration (FHWA) Low-carbon Transportation Materials Grant

Program (LCTM Program) was created in the Inflation Reduction Act (IRA, Pub. L. 117-169, August 16, 2022) and included in Title 23, United States Code (U.S.C.), Section 179. The LCTM

Program provides funding for the use of construction materials that have substantially lower levels of greenhouse gas (GHG) emissions. This application is in response to the FHWA’s Request for

Applications (RFA) to the LCTM Program. The goals of the LCTM Program are to:

1) Increase the use of low-carbon materials in projects funded under Title 23 U.S.C;

2) Facilitate the use of low-carbon materials while ensuring appropriateness for use in projects funded under Title 23 U.S.C.;

3) Support state transportation departments to develop low-carbon material identification frameworks that include environmental product declarations (EPDs);

4) Provide technology transfer and workforce development for the agency personnel and the transportation construction workforce in general;

5) Support state transportation departments in updating or developing specifications to allow for the use of low-carbon materials in eligible construction projects.

The Oregon Department of Transportation (“ODOT” or “the agency”) appreciates the opportunity to apply for LCTM Program funding. ODOT’s application includes this document (i.e., Volume 1 – Technical Application), Volume 2 – Budget Application, the SF424 required forms, and several attachments as supporting documents (i.e., Exhibit A: List of example construction operations and asset management approaches to be considered for use in ODOT’s LCTM program;

Exhibit B: List of example Title 23 U.S.C. projects where LCTM Program funding could be applied; Gantt chart identifying project schedule and key milestones; letters of support from external partners). ODOT’s proposed program, as articulated in the application herein, aligns with the LCTM Program goals listed above and positively responds to the review factors listed in Section

8 of the LCTM Program RFA.

2. Program Alignment with Federal Priorities

The U.S. Department of Transportation (USDOT) has several published priorities, summarized below, that ODOT considered when developing the program proposed in this application.

2.1. Climate Change and Sustainability

The Biden Administration has undertaken several activities to reduce GHG emissions in all sectors of industry. Specific programs include the Federal Buy Clean Initiative and Executive Order

(E.O.) 14057, Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability (86 FR

70935). ODOT’s climate efforts date back more than a decade with the Statewide Transportation

Strategy: A 2050 Vision for Greenhouse Gas Reduction, which provides a roadmap for Oregon to reduce transportation-related emissions. ODOT’s Strategic Action Plan (SAP) includes several policies related to addressing climate change and sustainability for agency operations.1

Furthermore, ODOT recently updated the Oregon Transportation Plan to include several policies relating to expectations around low-carbon materials. Below are a few examples of policies relevant to FHWA’s goals for the LCTM Program:

• SC.1.4.3: Transition to low-carbon materials and fuels in project construction and maintenance.

1 These policies are: 1) Reduce GHG emissions from ODOT activities by 20% by 2028; and 2) Reduce GHG emissions from materials used by the agency.

https://www.oregon.gov/odot/climate/Documents/Oregon_Statewide_Transportation_Strategy.pdf https://www.oregon.gov/odot/climate/Documents/Oregon_Statewide_Transportation_Strategy.pdf https://www.oregon.gov/odot/SAPDocs/Strategic-Action-Plan.pdf https://www.oregon.gov/odot/Planning/Documents/Oregon_Transportation_Plan-Executive_Summary.pdf

• SC.1.5.2: Identify and implement energy-efficient construction and maintenance practices.

• SC.2.1.2: Reduce the consumption of nonrenewable materials in the construction and maintenance of transportation infrastructure and facilities.

ODOT’s low-carbon materials program proposed in this application will adhere to the tenets of these policies and others. A central component of ODOT’s implementation of the LCTM Program is to comply with the U.S. Environmental Protection Agency (EPA) Interim Determination (ID) on selecting materials and products that meet the standards of the IRA Sections 60503 and 60506. The approach to compliance is presented in the Project Description.

2.2. Safety

Safety is an overarching priority of the USDOT and ODOT. The Oregon Transportation Plan identifies climate, safety and equity as the three lenses by which to make transportation decisions.

The agency’s proposed program aligns with the Oregon Transportation Plan, the National Roadway

Safety Strategy (NRSS), and the Fiscal Years 2022-2026 [US]DOT Strategic Plan with respect to advancing safe and efficient transportation.

2.3. Equity and Environmental Justice

To the extent permitted by other constraints, the LCTM Program seeks to fund activities and projects that will create proportional impacts on all populations in a project area, remove transportation-related disparities to all populations in a project area, and increase equitable access to project benefits, consistent with E.O. 13985, Advancing Racial Equity and Support for Underserved

Communities Through the Federal Government (86 FR 7009).

The activities that will be conducted by ODOT under the LCTM Program are also expected to support the major goals of the Equity component of ODOT’s SAP, which are:

i) Building a diverse workforce, supported by equitable operations and policies, and establishing an informed culture that delivers authentic inclusivity.

ii) Promoting economic opportunity for Oregonians through transportation investments, including working with businesses owned by people who identify as Black, Indigenous, Latino/a/x, Asian, Pacific Islander, Native, Tribal, people of color, women, or others who have been marginalized through institutional and structural oppression.

iii) Utilizing the viewpoints of those who reside in communities, ODOT serves, and are likely to be affected by our decisions and investments.

iv) Investing in the protection of marginalized communities from environmental hazards.

2.4. Workforce Development, Job Quality, and Wealth Creation

ODOT's proposed program will incorporate the components of E.O. 14052, Implementation of the Infrastructure Investment and Jobs Act (86 FR 64335) that apply, and will, where possible and applicable, include the participation of Disadvantaged Business Enterprises (DBEs), Minority-owned Businesses, Women-owned Businesses, or 8(a) firms. This program also intends to support

Made in America goals consistent with E.O. 14005, Ensuring the Future Is Made in All of America by All of America's Workers (86 FR 7475).

ODOT encourages DBEs to participate in contracts through the agency’s Civil Rights Program.

It is ODOT’s policy never to exclude any person from participation in, deny any person the benefits of, or otherwise discriminate on the basis of race, color, sex, national origin, or disability in the award and administration of USDOT-assisted contracts.

The LCTM Program presents a great opportunity for ODOT to leverage available resources to not only reduce the climate impact of construction materials but also to accelerate an emerging economy for small businesses producing local materials. This increases jobs in rural Oregon, utilizes abundant materials with low environmental impact, and reduces agency costs to procure materials. ODOT’s proposal also includes the development of a low-carbon materials education center, which is intended to expand knowledge and interest within the construction materials workforce.

3. Project Description

3.1. Overview

ODOT completed a GHG inventory in 2021 and found that 70% of the agency’s carbon footprint from ODOT’s activities is attributed to construction materials. Part of the project was the development of recommendations for the agency to consider in reducing its carbon footprint.

Developing an EPD program and further research into the use of supplementary cementitious materials (SCMs), as well as increasing the use of reclaimed asphalt pavement (RAP) are examples of the recommendations that relate to the LCTM Program’s objectives referenced above. In 2022, the Oregon Legislature passed House Bill (HB) 4139 that establishes an EPD program within

ODOT. Since the passage of the bill, the agency has been developing a program to collect EPDs and strategize ways to reduce embodied carbon from materials. The LCTM Program fits nicely within

ODOT’s vision for implementation of HB 4139 and will expand opportunities to institutionalize the use of low-carbon materials in ODOT’s construction program.

ODOT proposes to utilize LCTM Program funding to establish a comprehensive program to use construction materials and products that have “substantially lower”2 levels of embodied GHG emissions associated with the production stage as compared to the estimated industry averages of similar materials or products.3 If funded, ODOT will develop specification language and conduct research and identification activities needed to demonstrate that low-carbon materials are appropriate for use on construction projects eligible for federal-aid construction projects.

Additionally, ODOT will specify in certain Title 23 U.S.C. construction projects the use of low-carbon materials and will establish procedures to monitor and report the performance of those projects after construction. Oregon requests LCTM Program funding for development activities and use of the following eligible material categories: asphalt mixtures, concrete (and cement), and steel.

Oregon’s program will be implemented through several tasks presented in Section 3.2, below, and, when relevant, the processes associated with each task will be documented using

Implementation Progress Reports (IPRs). These IPRs will be submitted to the FHWA for approval before ODOT obligates any funding for construction projects, as established in the RFA requirements.

The EPA’s ID established that “substantially lower” embodied carbon is interpreted as meaning a material having a GWP in the best performing 20 percent when compared to similar materials or products. The best performing, or “top

20 percent”, means the material has a GWP in the lowest 20 percent when compared to similar materials or products. If no materials or products in the top 20 percent are available in a project’s location, a material or product qualifies for funding under IRA Section 60506 per this ID if its GWP is in the top 40 percent (i.e., lowest 40 percent in embodied

GHG emissions). If materials or products in the top 40 percent are not available in a project’s location, a material or product qualifies for funding under IRA section 60503 or 60506 per this ID if its GWP is better than the estimated industry average.

3 ODOT intends to establish regional/local benchmark(s) that may be used to incentivize use of low-carbon materials per LCTM Program guidelines.

https://www.oregon.gov/odot/Programs/TDD%20Documents/ODOT%20Operational%20GHG%20Reductions%20-%20BPs%20and%20Recs%20--%20FINAL%202022.01.05.pdf

3.2. Technical Description

ODOT’s implementation of the LCTM Program will focus on asphalt mixtures, concrete (and cement), and steel as eligible material categories. For each material type, ODOT’s program will involve a number of tasks that in turn encompass subtasks or “activities” to accomplish the program goals presented in Section 1. The initial step in the program is developing a series of IPRs that will provide specific details on each task and its activities reflective of ODOT’s objective to institutionalize the use of low-carbon materials. If awarded funding, ODOT will establish a program team – comprised of agency staff, university partners, and consultants – to assist in developing the specific IPRs to launch the program. Consultants and university partners will be engaged starting at the earliest stages of the program to achieve the tightest possible schedule and expedite the program. Additional IPRs will be developed, if needed, as the program evolves. ODOT will work diligently to send IPRs for approval to FHWA and be responsive in addressing comments to obtain the required approval. Additionally, ODOT acknowledges that IPR approval is needed before construction projects can be obligated using LCTM Program funds and that all funds requested

(including those for use on construction projects) must be obligated before September 30, 2026.

Other than developing the IPRs, the other tasks envisioned at this time are summarized in the following sections. For each task, a table is included identifying the specific activities anticipated for each eligible material.

3.2.1. Task 1 – Establish Framework for LCTM Program Implementation

As mentioned previously, HB 4139 established an EPD program within ODOT and directs the agency to develop strategies to reduce GHG emissions from materials. The agency will begin collecting EPDs no later than January 1, 2026. This legislative mandate ensures that ODOT can implement an extensive low-carbon materials program as envisioned by FHWA’s LCTM Program for several reasons:

• ODOT already has dedicated staff with capacity and knowledge to execute and manage implementation of the proposed work.

• Agency staff have spent the last two years developing an EPD-collection process, educating contractors and producers on EPDs, and general education on infrastructure life cycle assessments (LCAs).

• A technical advisory committee with low-carbon material subject matter experts has been established and meets regularly.

• Upper management is supportive of this program, as detailed in the Strategic Action Plan and Oregon Transportation Plan.

The activities under Task 1 are designed to build off the work already underway at the agency.

To establish a framework for program implementation, the agency anticipates spending considerable time conducting the following activities:

• Assessing training needs, including training materials and access to tools. To be followed by actual training activities for agency personnel, contractors, and material producers.

• Researching available data and databases, including life cycle assessment (LCA) data

(focused on “cradle-to-gate") for construction materials available in Oregon.

• Engaging in stakeholder outreach, including contractors, material providers, asset managers, and environmental advocates to discuss questions/concerns about the program as well as seek cooperation on obtaining materials and necessary LCA data.

• Developing a process for gathering and storing EPDs.

• Identifying materials that meet the EPA ID of "substantially lower" embodied carbon benchmarks.

• Establishing a local/regional embodied carbon benchmark that complies with ISO acceptable practices. This work includes engaging national and state industry organizations, FHWA, universities/consultants, and other DOTs with similar goals.

• Learning about the EPA’s Energy Star Performance Score and developing a process to collect relevant information from contractors.

This work will be conducted by a program team of existing staff, consultants, and university partners. This team will be responsible for administering the program, ensuring expectations are met on time and within budget. Task 1 is intended to be funded through the incremental funding process described in the RFA.

The collection of EPDs will require cooperation with material providers, many of whom are already partners in progressing the practice of EPDs. The starting point will be to investigate how available low-carbon materials in each eligible category under the LCTM Program fit into existing product category rules (PCRs). It will be necessary to ensure that for eligible materials, a facility-specific material/product-specific EPD, developed using ISO procedures, can be delivered at the time of construction. Because of work already underway through implementation of HB 4139, ODOT will have contract language in place to require EPD submittals on certain construction projects. A policy manual will be in place that outlines acceptable EPDs and their submittal process.

ODOT intends to contract with an entity that offers EPD database management (e.g., verification of

EPD submissions, portfolio statistics, technical training, etc.) through LCTM Program funding. This database may include standardization of digital information format for submittals and application for reviewing and quality assurance. A goal is to develop digital integration of EPD data with job mix formula information and performance related testing information, as well as integration into other decision support and asset management software. ODOT anticipates working with other

LCTM Program participants, federal agencies and industry organizations in this effort. Furthermore, ODOT may also explore incentivizing the submittal of EPDs to increase availability throughout the market. A goal with this activity is to identify a plan for EPD collection in the long-term, with a focus on continuous improvement of EPD-data quality.

Specific activities to be conducted under Task 1 are shown in Table 1, grouped by eligible material. For reference, Exhibit A, in the Additional Supporting Documents section, provides a list of low-carbon materials, construction operations, and asset management approaches being considered for use in ODOT’s program (e.g., warm mix asphalt and alternative cementitious materials). Such products will initially be tested in demonstration projects with the intention of incorporating in highway pavement projects, curb and gutter replacements, sidewalks, electric vehicle charging station construction, and more.

An important component of Task 1 is to establish substantially lower embodied carbon thresholds that meet the EPA ID for each eligible material ODOT will include in the program. The

RFA provides two options to establish thresholds for each eligible material.4 As part of the IPR for

Task 1, ODOT will detail the process to be used for determining the GWP benchmark to be used for each material (i.e., asphalt, cement concrete, and steel). To do accomplish this task, ODOT will work with consultants and university partners to determine a suitable process to identify thresholds

4 Option (1): An agency may reference the established thresholds as published on the FHWA website; Option (2): An agency may determine local or regional thresholds for asphalt mix, concrete (and cement), and steel, following accepted

International Organization for Standardization (ISO) standards to develop thresholds. When following Option 2, ODOT will disclose the GWP, the methodology for determining the percentiles and averages, the source(s) used for each material/product, and the parameters (including performance specification) used to set the GWP.

that will be used to make determinations for eligible materials. Initially, the agency ODOT will use the results of FHWA’s process for identifying industry averages. And, depending on the results of the benchmarking of currently used materials, ODOT may develop local thresholds within Oregon regions based on ISO 21678. An important subtask in the potential effort of creating its own benchmarks/thresholds, is for ODOT to develop IT processes for using digital EPD information integrated with materials and performance testing data considering functional and application categories for materials.

Table 1, below, provides anticipated activities that will occur under Task 1.

Table 1 – Task 1 activities anticipated for all eligible materials.

Establish Framework for LCTM Program Implementation

Eligible Material for Activity

Concrete

(Cement) Asphalt Steel Glass

1.1 Development of Task 1 IPRs. X X X

1.2 Identify eligible materials, training needs, data needs, and specification review.

X X X

1.3 Task 1 stakeholder outreach. X X X

1.4 Development of a process to collect, store and analyze EPDs. X X X

1.5 Identification of local or regional embodied carbon benchmarks. X X X

1.6 Conduct Task 1 training. X X X

3.2.2. Task 2 – Low-Carbon Materials Quality Assurance and Specifications

An important step in transitioning to the widespread use of low-carbon materials is developing a suitable quality assurance (QA) program. For asphalt, concrete (and cement), and steel, asset managers will also need to decide if any changes in design processes or specifications will be required to use low-carbon materials. Design changes can be modeled and examined before construction and post-construction performance monitoring and will provide data to further improve design processes. ODOT will assess if existing specifications allow for the use of identified low-carbon materials. If updates are needed, ODOT will develop new special provisions for planned low-carbon materials. On an ongoing basis, ODOT will evaluate need for new special provisions for new materials or refinement of applications or functional performance categories needed for future benchmarking efforts.

Activities under Task 2 include the development of ODOT’s QA plan for low-carbon materials, as well as a plan for monitoring performance post-construction. The development of both plans will require testing to establish measures of performance appropriate for new materials or to demonstrate that existing testing and specifications are applicable. For asphalt and cement concrete products, existing mixture designs will need to be evaluated and may require adjustment to ensure performance. ODOT intends to explore asphalt mixes with higher percentage of reclaimed asphalt pavement (RAP), included additives like fibers and plastics, and modifying plant practices like covering stockpiles or the use of renewable fuels. For cement concrete products, the agency will work with the industry to test local SCMs like volcanic pumice ash, explore the use of ettringite-based cements, and optimization of aggregate crushing to reduce cement content demand.

An additional need is to establish constructability of low-carbon materials and, to the extent possible over the duration of grant funding, establish the durability and resilience of low-carbon asphalt and cement concrete mixtures. Updating existing specifications or developing special provisions for new materials will follow, from developing preliminary mixture designs in the laboratory to limited field testing, including test strips to ensure constructability.

In many cases, new test methods will be required to establish material properties to be included in new specifications. It is expected that existing ODOT testing facilities need augmented capabilities to adequately assess and accept low-carbon materials. Therefore, a major activity under

Task 2 will be to assess the need for additional testing equipment for ODOT laboratories and undertake procurement of that equipment, install the additional equipment, train key laboratory personnel on use, and then integrate the new testing capabilities into the agency’s QA program.

Additional stakeholder outreach to socialize new QA protocols and specification requirements will involve academic and industry partners.

Other important activities under Task 2 are the development of processes for verifying EPDs and for ensuring materials delivered to the construction site are the actual materials covered by the provided EPDs. Obtaining EPD verification will involve the participation of the material providers and will likely involve changes to processes and equipment used to batch and deliver construction materials to a job site. There are emerging technologies for ready-mix concrete trucks, for example, that provide EPD verification with batch tickets. The use of this type of reporting and similar reporting for other LCTMs will require ODOT validation.

The work in Task 2 will be conducted primarily by ODOT’s university partners, agency personnel and consultants and will be funded through the incremental funding process described in the RFA. Agency personnel will lead specification writing and the assessment of laboratory capabilities, with guidance from consultants and university partners. Throughout Task 2, there will be an additional need for training of agency personnel as well as training contractor and material producer’s personnel. Specific activities to be conducted under this Task are shown in Table 2, grouped by eligible material.

Table 2. Task 2 activities anticipated for all eligible materials.

Low-Carbon Materials Quality Assurance and Specifications

Eligible Material for Activity

Concrete

(Cement) Asphalt Steel Glass

2.1 Development of Task 2 IPRs X X X

2.2 Development of QA plans and/or performance monitoring plans X X X

2.3 Task 2 stakeholder outreach X X X

2.4 Update of existing material specifications / development of new special provision to facilitate use on projects X X X

2.5 Preliminary mixture design and testing to evaluate materials X X X

2.6 Testing equipment to accept and verify low-carbon materials X X X

2.7 Construction of Task 2 low-carbon material test strips X X X

2.8 Development of a verification process for low-carbon materials using EPDs X X X

2.9 Task 2 training X X X

3.2.3. Task 3 – Identify Eligible Projects

Tasks 1 and 2 will set in place the foundation to move toward actual construction using low-carbon materials that meet the EPA’s ID. The next step is identifying eligible Title 23 U.S.C projects. Given the time span between the grant initiation and construction, it is not possible to predict with any certainty which eligible Title 23 U.S.C projects will be used. However, ODOT has identified potential projects that use eligible materials (e.g., the US 395: Punking Center Safety

Improvements project that will use asphalt, cement concrete, and steel). An example list of potential projects is presented in Additional Supporting Documentation - Exhibit B.

As part of Task 3, ODOT will work with contractors to identify the most suitable projects to incorporate into the agency’s low-carbon materials program. In Task 1, a preliminary list of low-carbon materials will be developed. In Task 3, that list will be updated with specific project opportunities for inclusion of low-carbon materials. For example, an alternative cement may be available only in small quantities, or a particular asphalt mixture using low-carbon materials may not meet the engineering requirements dictated by the traffic on a specific Federal-aid route.

Working with consultants, universities, and industry partners, the best application for low-carbon technologies will be identified, ensuring the best chance of success for each selected technology.

Working with industry stakeholders, the agency will develop a plan for incorporation of low-carbon materials on Title 23 U.S.C. projects. Elements of the plan will include material procurement, mixture design submittal processes, establishing contractor capabilities for construction and quality control (QC), acceptance criteria, as well as life cycle performance monitoring. This will roll up into a larger activity of developing project-specific construction contract language. The contract writing will be conducted primarily by agency personnel, with consultant assistance, and will be funded through the incremental funding process described in the

RFA. Specific activities to be conducted under this task are shown in Table 3, grouped by eligible material.

Table 3. Task 3 activities anticipated for all eligible materials.

Identify Eligible Projects

Eligible Material for Activity

Concrete

(Cement) Asphalt Steel Glass

3.1 Development of Task 3 IPRs. X X X

3.2 Identify eligible construction projects. X X X

3.3 Develop a plan for incorporation of low-carbon materials on construction projects.

X X X

3.4 Development of project-specific construction contract language. X X X

3.5 Task 3 industry outreach and coordination. X X X

3.6 Task 3 training. X X X

3.2.4. Task 4 – Expand Use of Low-Carbon Materials on Projects

Activities under this task include selecting from the preliminary project list, developed under

Task 3, and to select final projects for use of low-carbon materials. An important component of this task is for agency staff to examine construction documents for specific projects and identify measures to minimize impacts that may stem from use of the low-carbon materials. As an example, maturity or in-situ strength measurement techniques may be employed to identify the time for opening a concrete placement to traffic. Additional activities will involve developing a methodology to determine the incremental costs associated with using a material with substantially lower embodied carbon on a Title 23 U.S.C. project. Other than material costs, a methodology for evaluating other costs of using low-carbon materials needs to be developed for a holistic cost estimate to be included. Agency personnel will engage with contractors and industry representatives to explore the best methodology to include costs on existing projects or new construction -consultants may be used depending on staff capacity. Examples of additional costs incurred from using low-carbon materials include costs for a contractor to mobilize for the project (e.g., temporary materials silo) or additional workforce training or certification.

All applicable Federal cost principles will be followed as part of this task. ODOT anticipates

Task 4 to be funded through the incremental funding process described in the RFA, the incentive amount process described in the RFA, or a combination of the two depending on the specific material. The IPRs will provide greater detail on funding method. Specific activities to be conducted under this task are shown in Table 4, grouped by eligible material.

Table 4. Task 4 activities anticipated for all eligible materials.

Expand Use of Low-Carbon Materials on Projects

Eligible Material for Activity

Concrete

(Cement) Asphalt Steel Glass

4.1 Development of Task 4 IPRs. X X X

4.2 Estimation of costs of low-carbon materials. X X X

4.3 Comparison of low-carbon material costs and traditional material costs.

X X X

4.4 Low-carbon materials bid items (added solely to facilitate use). X X X

3.2.5. Task 5 - Substantially Lower Embodied Carbon

Activities under Task 5 include collecting EPDs and verifying compliance with the EPA ID.

ODOT will, as necessary, add a pay item to construction contracts to facilitate EPD collection.

Additionally, the agency will request and gather Energy Star Performance Scores from upstream material producers where applicable. A pay item incentive may be explored to encourage producers to achieve Energy Star Certification, if supported by the LCTM Program.

Another important activity will be the establishment of appropriate and necessary quality incentives as part of the developed special provisions, or by other means within the construction contracting process. Any other additional agency costs incurred in the use of a low-carbon material in a specific project will be identified and reimbursement will be requested using the appropriate

IPR process. All reimbursements will be in accordance with federal regulations and cost control provisions.

This work will be conducted primarily by agency personnel, academic partners and consultants.

ODOT anticipates Task 5 will be funded through the incremental funding process described in the

RFA, the incentive amount process described in the RFA, or a combination of the two depending on the material. Specific activities to be conducted under this task are shown in Table 5, grouped by eligible material.

Table 5. Task 5 activities anticipated for all eligible materials.

Substantially Lower Embodied Carbon

Eligible Material for Activity

Concrete

(Cement) Asphalt Steel Glass

5.1 Development of Task 5 IPRs. X X X

5.2 EPD bid item to facilitate collection. X X X

5.3 Collection of Energy Star Performance scores. X X X

5.4 Quality incentives for environmental & engineering performance + other costs to facilitate use of low-carbon materials.

X X X

3.2.6. Task 6 - Quality Assurance and Acceptance

Accomplishing the activities under this task requires close coordination between material providers, contractors, and ODOT personnel. The QA plan developed in Task 2 will be implemented with the understanding that changes may be required as it is rolled out. Pre-construction test strips will be placed to evaluate the testing included in the QA plan but also to ensure constructability and long-term performance. Contractor engagement will be key and pre-construction test strips or mock-ups will provide opportunities to train contractor personnel on placement, finishing, and/or installation of low-carbon materials in the field. It is possible that pre-construction evaluation will identify additional QA testing requirements, and, in turn, that may lead to the need for additional testing equipment and training. The QA plan will verify as-placed material meets both the developed GWP thresholds and the necessary engineering requirements. In some cases, this validation will require inspections at material production facilities to observe production of the material, followed by testing to validate EPD compliance and to ensure key engineering properties are met.

An important part of the QA plan will be the sampling process, which needs to be thorough without being onerous. Access to materials for sampling, and delays in construction due to testing, shall be minimized through cooperation and communication with all stakeholders. It may be necessary to provide quality incentives to achieve all desired properties for a low-carbon material to be incorporated into construction.

This QA process may require testing utilizing third-party laboratories and consultants. However, the program will follow Stewardship and Oversight requirements outlined by the FHWA Oregon

Division office. Overall, Task 6 will be largely conducted by agency personnel and academic partners and will be funded through the incremental funding process, the incentive amount process described in the RFA, or both depending on the material and activity. Specific activities to be conducted under this task are shown in Table 6, grouped by eligible material.

Table 6. Task 6 activities anticipated for all eligible materials.

Quality Assurance and Acceptance

Eligible Material for Activity

Concrete

(Cement) Asphalt Steel Glass

6.1 Development of Task 6 IPRs. X X X

6.2 Construction of Task 6 low-carbon material test strips. X X X

6.3 Additional testing equipment and/or testing required to accept low-carbon materials.

X X X

6.4 Verification that material placed meets thresholds for substantially lower carbon.

X X X

6.5 Verification of engineering properties of low-carbon materials. X X X

3.2.7. Task 7 – Institutionalize the Use of Low-Carbon Materials

The intention of Task 7 is to increase the routine use of low-carbon materials at ODOT and institutionalize the consideration of environmental quantification in the agency’s construction program. Building off previous tasks (e.g., EPD collection and establishment of local/regional GWP benchmarks), this task will focus on strategies to incorporate low-carbon materials into construction activities during the LCTM Program timeline and beyond. Activities conducted under this task will largely involve agency personnel working in close collaboration with university partners and industry.

This task includes performance monitoring plans for projects that use low-carbon materials to assess post-construction and long-term performance in a way that will inform future policies.

ODOT will develop project-specific asset structure performance monitoring plans that include constructability and engineering performance evaluation. These monitoring plans will include environmental review (for materials with EPDs), initial engineering performance review, and economic evaluation where appropriate. The intention is to create a pipeline for future low-carbon material use that meet engineering performance expectations.

An important component of institutionalizing the use of low-carbon materials is integration with the agency’s asset management systems. Infrastructure designs are context-specific based on the required serviceability they are intended to provide (e.g., traffic, climate). The initial designs and subsequent anticipated treatments over the life cycle of a pavement, for example, inform the quality and quantity of construction materials. Asset management systems play a crucial role in monitoring the performance of construction materials used in projects and validate if the initial assumptions made through QA and laboratory testing are accurate. Therefore, this task includes activities to enhance the tie between ODOT’s asset management systems and the construction materials data for monitoring long-term performance relative to the properties of low-carbon construction materials used in construction projects.

Lastly, as part of ODOT’s long-term monitoring plan, reporting mechanisms will need to be established for producing informative data not just for the agency but for public dissemination as well. As part of ODOT’s participation in the LCTM Program, agency staff and academic partners will publish results and lessons learned through research reports, industry publications, and academic journals where appropriate. The activities will be funded through the incremental funding process, the incentive amount process described in the RFA, or both. Specific activities to be conducted under this task are shown in Table 7, grouped by eligible material.

Table 7. Task 7 activities anticipated for all eligible materials.

Institutionalize the Use of Low-Carbon Materials

Eligible Material for Activity

Concrete

(Cement Asphalt Steel Glass

7.1 Development of Task 7 IPRs. X X X

7.2 Develop project-specific asset structure performance monitoring plans. X X X

7.3 Results from long-term performance monitoring plans. X X X

7.4 Incentives / incremental cost reimbursement. X X X

7.5 Construction support for industry and ODOT Region Engineer Offices. X X X

7.6 Integration of low-carbon materials program into asset management systems.

X X X

3.3. Team Information

3.3.1. ODOT Personnel

ODOT is well positioned for successful implementation of the proposed program because the agency has dedicated staff that have been working in the low-carbon materials space for several years. ODOT’s Sustainability Program managed the agency’s first GHG inventory, which used

EPDs to inform emission factors for the asphalt, concrete and steel products used by the agency. It was from this effort that FHWA requested Sustainability Program staff to become a member of

FHWA’s Sustainable Pavements Technical Working Group (SPTWG). Furthermore, in 2023 the

Construction Section hired a Sustainability Engineer to implement the requirements set forth in HB

4139. ODOT’s Climate Office and Construction Section have rapport that will be critical in meeting the overarching objectives of the program.

ODOT anticipates assigning the necessary workload to implement the proposed program across the agency in an amount estimated to be the equivalent of eight fulltime employees (FTEs). This is reflective of ODOT’s strategy to complete most of the work in-house to utilize agency expertise, in addition to the goal to institutionalize the work beyond the LCTM Program sunset in 2031. The amount of FTE will fluctuate throughout the program (i.e., initial program development will take more staff time), but ODOT presumes a minimum of three FTE will be required to maintain the program in perpetuity. Positions that ODOT envisions will be utilized at various times throughout program implementation include:

• Program Manager /

Contract Administrator

• State Construction and

Materials Engineer

• Sustainability Engineer

• State Pavement Services

Engineer

• STIP Coordinators

• Pavement Quality and

Materials Engineer

• Research Engineer

• Structure Services Engineer

A project manager will oversee implementation of the agency’s low-carbon materials program in general and will be responsible for managing contracts with consultants and academic partners, as well as regular engagement and reporting to FHWA. The sustainability engineer will be the agency subject matter expert on low-carbon materials. Engineering managers, like the state construction and materials engineer and state pavement services engineer, will manage staff, approve of specification or contract language updates, and coordinate inclusion of low-carbon materials within construction projects. The agency’s Contract Administration Engineer’s group will lead the effort to update project contract language for the use of low-carbon material incentives.

Project delivery staff and Statewide Transportation Improvement Program (STIP) coordinators will need to work with region and district managers to identify suitable projects. Research engineers will be required to oversee work performed by academic partners through existing contracts.

Engineering technicians will develop test methods related to low-carbon materials.

Technical program implementation will be managed by ODOT’s Delivery and Operations

Branch, with coordination with the agency’s Policy, Data and Analysis Division for matters concerning policy strategies, contract administration, general reporting and GHG accounting.

ODOT has existing staff who work on federal grants in the Statewide Investment Management

Branch. The federal aid funding manager, through coordination with the program manager, will be responsible for LCTM grant financial management.

Note: some of the costs currently proposed under ODOT personnel may be shifted to consultants if determined to be necessary.

3.3.2. Anticipated Partners

3.3.2.1. Consultants

In response to the need for specialized expertise to implement ODOT’s low-carbon materials program, the agency will initiate a consultant selection process as soon as possible. Agency staff will develop a comprehensive list of the program's objectives, scope of work, expected timeline, and required qualifications of the consultant. Staff will determine if a single contract meets the needs of the agency or if multiple contracts will need to be established. Contracts will be publicly advertised to ensure broad visibility and attract a diverse pool of applicants.

Interested consultants will be invited to submit detailed proposals highlighting their qualifications, project approach, relevant experience, and cost estimates. The agency will establish a selection committee to evaluate these proposals based on predetermined criteria such as technical expertise, methodology, and cost-effectiveness. Final selection(s) will be based on the committee’s assessments and will be followed by contract negotiation, with the chosen consultant, clearly defining the terms of engagement, deliverables and timelines. This process ensures that ODOT partners with the most suitable consultant(s) to support implementation of the program, while maintaining transparency and adherence to federal and state regulations.

3.3.2.2. Universities

ODOT has a standing agreement with Oregon State University (OSU) and plans to utilize this contract to partner with the university’s engineering department. ODOT would also like to partner with the Oregon Institute of Technology (OIT) and will need to establish a contract to do so. These universities – and potentially others – will be critical partners in ODOT’s effort to meet the objectives of the LCTM Program. Agency staff met with university staff on multiple occasions to discuss opportunities, in addition to ensuring capacity and expertise to meet assigned deliverables as part of LCTM Program implementation.

Academic partners will assist ODOT in the following ways (not an exhaustive list, but detailed statements for all ideas are available upon request):

• Outline a QA approach for low-carbon specifications.

• EPD benchmarking and quality control (e.g., developing a process to connect asphalt mix properties and parameters with EPDs to aid in LCTM Program reimbursement calculations and overall implementation).

• Development of QA/QC processes additives in asphalt concrete with goals of reducing virgin binder content, increasing RAP use, and reducing production GHG emissions.

• Develop a concrete mix that uses raw Mazama Ash (a plentiful local resource in Oregon that can replace up to 30% of the portland cement in a typical concrete mixture).

• Develop a list of all pozzolanic materials that are likely to be used in the Pacific Northwest.

Quantify the performance of these materials and ensure ODOT specifications are ready for materials to be used in agency projects.

• Optimize aggregate crushing process and resulting aggregate gradations to minimize binder content.

• Develop a broad range of cement-based solutions based on ettringite acceleration that can be used broadly for concrete repair, rehabilitation, and ultimately increased service-life.

• Develop field test methods and specifications for in-situ quality assurance of constructed roadways using low-carbon materials.

• Create an education center to teach the meaning of different climate-related terms and factors and their connection to transportation pavements, bridges, and structures.

3.4. Overall Readiness

As described in Section 2, ODOT leadership has set several expectations for the agency to reduce GHG emissions from construction materials. Program staff have discussed the LCTM

Program with senior leadership; there is support and general excitement to participate in the LCTM

Program because of the opportunities to expand existing efforts. With several recent accomplishments in climate-related efforts and improvements within the agency, ODOT is well-positioned to successfully implement the proposed low-carbon materials program. For many years, the agency has allowed low-carbon cements (e.g., Portland-limestone; natural pozzolans; ternary blends) to be included in concrete mix designs. RAP percentages, which relate to the carbon intensity of asphalt mixes, are in line with industry standards. A balanced mix design method for asphalt materials with performance verification was developed within the last eight years and started to be tested in construction projects. Life-cycle cost analysis has always been a part of

ODOT’s asset management processes. These elements position ODOT to effectively drive the proposed low-carbon materials program to successful implementation.

The agency already has dedicated staff focused on sustainability and low-carbon initiatives ensuring specialized attention and continuity for scaling up the program to meet LCTM Program expectations. ODOT's participation in the SPTWG further enhances its readiness by enabling staff to stay informed on the latest best practices and innovative approaches in sustainable pavements and infrastructure LCAs. Agency staff working on low-carbon materials already connect with FHWA

Oregon Division Office staff on a regular basis and will continue to do so in order to successfully implement the proposed program.

ODOT has strong relationships with academic partners, particularly those with extensive experience in low-carbon materials, and frequently tests innovate materials and construction techniques that increase performance and reduce GHG emissions. ODOT and OSU have partnered previously on low-carbon material topics like asphalt binder modifications, renewable fuels at material plants, optimizing aggregate crushing to reduce cement paste, and many more. LCTM

Program funding will enable ODOT to vastly expand partnerships with universities to further push the agency’s efforts to lower the embodied carbon content of construction materials.

Agency staff also have established relationships with many consultants within the low-carbon materials space. This is in part due to ODOT’s participation on the FHWA’s SPTWG. While the agency is not sure who it will ultimately contract with to provide consulting services, staff are confident they know the experience and skillsets required to meet the program expectations. ODOT will aim to bring a consultant team onboard as soon as possible to assist with overall program guidance and assistance on specific tasks.

The agency proposes a program that is conservative in terms of deliverability, but not so much that FHWA’s LCTM Program objectives will not be met. Again, ODOT is well-prepared and confident in successfully implementing the low-carbon materials program described in this application. With support from the industry and academia, ODOT has already been developing and implementing several low-carbon strategies within the last decade. The funding from FHWA’s

LCTM Program will complement all past efforts of the agency and result in a rapid and successful implementation that can create an excellent example for other states.

ODOT’s…