NPCA today sent the following letter to Livia Shmavonian, director of the Made in America Office within the White House Office of Management and Budget.
On March 13, 2023, the Precast/Prestressed Concrete Institute and the National Precast Concrete Association provided comments to Deidre A. Harrison, deputy controller, at the Office of Federal Financial Management office on OMB’s guidelines for the Build America, Buy America Act (BABA) Pub. L. No. 117-58, §§ 70901-52 under the 2021 Infrastructure Investment and Jobs Act (IIJA).
NPCA provides industry leadership by promoting quality precast concrete products across all markets, addressing industry challenges and developing opportunities for member success. NPCA members are manufacturers of industrial plant-produced precast concrete products and the suppliers of products and services for the industry.
Our comments explained why materials to make precast/prestressed concrete, which are molded in a factory setting, should be treated the same as cast-in-place (or wet) concrete that is placed on a construction site. Precast concrete is heavily used in construction projects and is produced by casting concrete in a reusable mold or “form,” which is then cured in a controlled environment (the plant), transported to the construction site, and lifted into place. In contrast, standard cast in place (wet) concrete is poured into site-specific forms and cured on site.
The current BABA guidelines necessitate precast concrete to meet the 55% “cost of components” test because of its manufactured state, whereas cast-in-place concrete products, which are basically the same, are not beholden to this requirement. This means that the cost of the components of the manufactured precast product that are produced in the United States must be greater than 55% of the total cost of all components of the manufactured product.
Yet, the four basic components that comprise concrete – cement, water, aggregates, and admixtures (stone, sand or gravel) – that are exempted from the Buy American preference for infrastructure are not exempted in the total cost of components. The precast concrete industry maintains that the same BABA exemptions that cast-in-place concrete manufacturers receive should apply to the raw materials used to make precast concrete end products, since their components–cement, water, aggregates, and admixtures–are exempted under BABA rules.
The precast concrete paradox
Under BABA rules, precast concrete is considered a manufactured product because cementitious materials are combined and produced in a factory setting. But, just like cast-in-place concrete, precast combines the same four key construction elements of cement, water, aggregates, and admixtures (stone, sand, or gravel) to produce specific forms. Other components, such as steel reinforcement, are often added to a “precast” product to fortify it for more effective building constituents.
The precast (in factory) process has obvious benefits as it allows for production in a controlled environment at quantities of scale. Given the controlled production conditions, precast concrete can often achieve higher strength and durability standards compared to cast-in-place counterparts, avoiding costs associated with maintenance. Moreover, fewer on-site activities reduce the risk of accidents associated with concrete pours and related activities. It all amounts to an increased pace of much needed infrastructure construction.
BABA guidelines disadvantage precast concrete
The “Buy America” objective under BABA is to prioritize the purchase and use of goods, materials, and products manufactured in the United States, with a “Buy America” preference for projects receiving federal assistance. It aims to bolster America’s industrial base, protect national security, and support high-paying jobs and American workers. We laud and support these goals.
The precast concrete industry is concerned, though, that under the new BABA guidelines, precast concrete receives unequal treatment vis-a-vis cast-in-place concrete. The guidelines inadvertently disadvantage precast cementitious products by not exempting the raw cementitious materials and aggregates used to manufacture precast concrete products.
The precast industry faces certain challenges relative to this requirement as discussed below.
A continuous supply of raw cementitious materials largely depends on the strength of the economy. During a strong and robust economy, precast concrete can be sourced locally, providing a high level of dependability while saving on delivery time and cost. However, if an economy experiences global supply chain interruptions, as we have recently experienced during the pandemic, causing raw material availability to fluctuate, the industry must have the flexibility to source raw materials from around the globe when needed and not be constrained by Buy America requirements. In 2021 and 2022, for example, supply chain constraints caused manufacturers to import raw materials. If these imported materials had not been available, federal, state and other building projects would have been delayed.
When local domestic aggregates are not available or fail to meet engineering specifications, members in some areas of the country rely on imported materials to meet specifications and product demand.
Precast vs cast-in-place concrete and how precast is used
Precast concrete is an essential component to the nation’s infrastructure, and is used in many common construction applications in the United States, including but not limited to:
- Structural elements (beams, columns, slabs, walls, staircases).
- Architectural panels (decorative exterior finishes).
- Transportation infrastructure (bridges, railroad ties, sound walls, and tunnel linings).
- Utility structures (manholes, vaults, culverts).
- Housing and building (modular building systems or individual precast components for homes and commercial buildings).
- Landscaping (pavers, fence posts and other decorative elements).
Precast concrete is available in essentially any color, form, finish, or texture, and water and sewer infrastructure.
Precast concrete has steadily been growing in popularity among government specifiers due to its many benefits: speed of construction, efficiency, durability, versatility, quality control, and reduced need for onsite labor. It is preferred for projects that require repetitive elements like parking garages, bridge beams, and modular buildings. There are also regional and project-specific reasons to prefer precast over wet concrete, such as weather (which may constrain onsite curing of wet concrete), or a limited labor force.
In short, precast concrete products are a critical part of U.S. infrastructure projects because they arrive finished – ready for easy and efficient installation. They can be delivered “just in time” so units may be lifted directly into place. This eliminates the need for onsite storage space and unnecessary handling, while other materials are dependent upon job site access and favorable weather conditions.
PCI and NCPA do not question whether the key materials to make concrete should be considered exempt. These materials are necessary ingredients for finished products, such as concrete, because they are essential building blocks for America’s infrastructure needs. The precast industry simply argues that even though precast concrete products are produced in a factory setting, they still use the same four key components – cement, water, aggregates, and admixtures – that cast-in-place concrete uses and that are individually exempt under the Buy America Preference exclusion. Thus, these components, and these components only, should be exempted for purposes of producing precast concrete.
PCI and NCPA respectfully request that the same exclusions be extended to the raw materials used for precast concrete as for cast-in-place concrete. We also request to meet with you to discuss our position in greater detail.
We thank you for your time and consideration of our position respecting precast concrete.
Interim President and CEO
National Precast Concrete Association