ID#10204 made on
SSp1 - Erosion and sedimentation control
LEED O+M: Existing Buildings, LEED O+M: Schools, LEED O+M: Retail
The San Gabriel Valley Corporate Campus (SGVCC) is a multi-tenant office park located in a suburban area of Irwindale, CA. The property is pursuing LEED certification under EB:O&M version 2008. Th...
The San Gabriel Valley Corporate Campus (SGVCC) is a multi-tenant office park located in a suburban area of Irwindale, CA. The property is pursuing LEED certification under EB:O&M version 2008. The project is attempting Sustainable Sites Credit 3 and seeks clarification and guidance from the USGBC in regards to Universal Notification for non-least toxic exterior pesticide applications. The property's pest control vendor has attempted to control a persistent rat population with least-toxic methods and mechanical controls which have proven to be ineffective. Monitoring blocks (sugar cubes) show daily rodent activity in the property's planter beds, loading dock areas and other exterior locations around the perimeter of the three building campus. Rodenticides are placed out for a few days, then removed and replaced with the monitoring blocks. Within a few days rodent activity is present again and tenants report evidence of rodents in the property's pest sighting log shortly after the rodenticide is removed. Page 17 of the EB 2009 Ref Guide states: "Exterior pest management should focus on keeping the site's animal and insect pest populations under control and preventing pests from entering the building." Keeping rats and mice under control at some properties requires more aggressive treatment than least toxic and monitoring regimes are able to achieve. It is not clear how to properly implement and document Universal Notification for these properties in either the v2008 or v2009 LEED EB Reference Guides. Issue #1: For exterior pesticide applications at multi-tenant properties in areas like loading docks and planter beds, it's not clear who the landlord should notify. Sending an e-mail to the individual occupants is infeasible. Most landlords will be unwilling to send weekly e-mails or hard copy notifications to every tenant's point-of-contact. In any case, these types of notifications to a single tenant contact are unlikely to reach the broader population of occupants. Signage or postings at the exterior treatment areas would seem to be the only effective option. Issue #2: For properties like SGVCC where controlling the rodent population is a constant struggle, it is not feasible for the property management team to post paper signage in exterior areas and then replace it on a daily or weekly basis ad infinitum. Permanent signage in exterior areas that require frequent treatment, supplemented with a detailed notification to tenants on a periodic basis, would seem to satisfy the Universal Notification requirement. However it's not clear from the Reference Guides if this would be acceptable. An example of the permanent signage could read: "Caution, Non-Least Toxic Pesticides or Rodenticides May Be Applied in This Immediate Area. Please Contact Building Management at xxx-xxx-xxx for Chemical Information and Application Schedules" We request that USGBC clarify the implementation guidance and submittal requirements for SSc3 related to Universal Notification for the circumstances at SGVCC. Because universal notification is a key portion of SSc3 and many EBOM projects attempt this credit, we ask that the USGBC consider publishing the technical response as a LEED Interpretation.
The use of non-least toxic pesticides or rodenticides as pest control in areas requiring frequent treatment on a permanent basis is not an acceptable strategy for this credit. Projects are encouraged to use integrated management methods and explore alternatives to chemical pesticides. If a building is located on a site in which integrated methods are unable to control pest populations, and non-least toxic pesticides are continuously applied to the site, this credit may not be achievable. Internationally applicable.
Related Addenda (Corrections & Interpretations)