PII Comment Submitted by DuPont Performance Building Solutions

See attached file Re: DuPont Performance Building Solutions Comments on Request for Information Regarding Products and Categories of Products Used in Housing Programs Pursuant to the Build America, Buy America Act Dear Sir or Madam: DuPont Performance Building Solutions (PBS) appreciates the opportunity to provide comments in response to HUD's Request for Information regarding products and categories of products used in housing programs under the Build America, Buy America Act (BABA). DuPont PBS manufactures high-performance building envelope products used throughout residential and commercial construction, including insulation, weather barriers, air sealing systems, and related building technologies that improve energy efficiency, durability, resilience, and occupant comfort. Through our U.S. manufacturing and distribution footprint, DuPont supports domestic jobs, domestic supply chains, and housing construction markets across the United States. We appreciate HUD's efforts to better understand the availability of domestically manufactured products used in HUD-assisted housing programs and to ensure that implementation of BABA requirements strengthens U.S. manufacturing while supporting housing affordability objectives. Housing Affordability Should Consider Ongoing Operating Costs Housing affordability is influenced not only by the initial cost of construction, but also by the long-term operating costs borne by homeowners, renters, housing authorities, and affordable housing providers. High-performance building envelope systems help reduce energy consumption by improving thermal performance, moisture management, and air tightness. These measures can lower utility costs over the life of a home and help improve affordability for occupants, particularly in affordable housing developments and among households facing high energy burdens. As HUD evaluates products and policies associated with BABA implementation, the agency should recognize the role that energy-efficient building materials can play in reducing long-term housing costs and supporting more affordable housing outcomes. Maintaining Access to Innovative Building Products Supports Durable and Resilient Housing Modern housing depends on access to innovative building materials that help improve energy efficiency, durability, resilience, and occupant comfort. Building envelope products are an important component of housing performance and can help protect structures from weather-related damage, improve indoor environmental quality, and support long-term building durability. Continued access to domestically manufactured, high-performance building products will help ensure that housing projects can achieve affordability, resilience, and performance objectives simultaneously. HUD should continue to support policies that encourage domestic manufacturing while preserving access to the products necessary to meet the diverse needs of housing projects across the country. BABA Implementation Should Be Clear, Practical, and Workable DuPont supports the objectives of strengthening domestic manufacturing and promoting the use of American-made products in federally supported construction projects. As HUD continues implementing BABA requirements, the agency should provide clear, practical, and workable guidance that allows affordable housing projects to move forward efficiently. Implementation approaches that create unnecessary administrative burdens, delays, or uncertainty may hinder housing development and increase project costs without advancing the core objectives of the statute. In applying BABA requirements, HUD should focus on whether the finished building product is domestically manufactured, recognizing that ingredient- or sub-component-level sourcing may involve separate compliance considerations and should not obscure the central objective of supporting domestic finished product manufacturing. Accordingly, HUD should seek implementation approaches that strengthen domestic finished product manufacturing while supporting timely housing development and maintaining access to products essential for affordable, durable, and energy-efficient housing. Conclusion DuPont appreciates HUD's consideration of these comments. We support the agency's efforts to advance domestic manufacturing objectives while ensuring that housing programs continue to promote affordability, energy efficiency, durability, and resilience. We look forward to continued engagement as HUD evaluates BABA implementation in housing programs. Thank you for your attention to this important matter. Please feel free to contact me at Jeffrey.hansbro@dupont.com. Sincerely, Jeff Hansbro Global Advocacy Director, DuPont Performance Building Solutions