ID#2383 made on
MRc2.1 - Construction waste management - divert 50% from disposal
LEED BD+C: New Construction, LEED BD+C: Core and Shell, LEED BD+C: Schools, LEED ID+C: Commercial Interiors, LEED O+M: Existing Buildings
We have the opportunity to use several different processors, all who claim to be able to recycle in excess of 90% of the materials typically found in Construction & Demolition (C&D) debris; ho...
We have the opportunity to use several different processors, all who claim to be able to recycle in excess of 90% of the materials typically found in Construction & Demolition (C&D) debris; however they are using significantly different methods for determining the recyclability of the loads they accept. Facility A: Has a processing facility staff member look at the loads when they come in to visually estimate the recycling percentage. We are concerned with the potential for "Green Washing" as many of these facilities are reporting very high LEED recycling rates despite overall facility rates that remain low. The business model of these facilities is typically focused on land filling waste and / or using C&D debris as Alternate Daily Cover (ADC) and calling it "recycling". Facility B: Is one of the co-mingled recycling facilities in our region that consistently achieves high recycling rates that are based upon the total tonnage shipped out of their facility on a monthly basis. All materials at their facility are accounted for in their recycling percentage, including the waste they generate from their own lunchrooms and offices while they process the co-mingled debris. They also generate detailed annual reports supporting their monthly calculations and provide them to the Washington State Department of Ecology and the Tacoma-Pierce County Health Department for third party review. We are confident in the recycling capability and the accuracy of the reports generated by facility B; however economics make it more advantageous to utilize the other facilities like Facility A when they are closer to our jobsites. 1.) Does the USGBC offer a prescriptive method for facilities to back-up commingle recycling percentage claims? 2.) Which of the two methodologies above are acceptable reporting methodologies? Both example facilities above sell varying percentages of ADC. When calculating recycling percentages the USGBC does not seem to have a limit on how much ADC can be claimed as a "recyclable" commodity. In a recent CIR dated 07/16/08 the response stated "Any construction debris processed into a recycled content commodity which has an open market value - e.g. alternate daily cover material, etc. - may be applied to the construction waste calculation". This ruling implies a waste facility can take C&D debris and simply process it as ADC and give a 95% recycling rate on a project. 3.) Can the USGBC define a limit on how much ADC can be applied to the waste recycling calculation (example: no more than 20% of the C&D stream can go to ADC on any given project)?
The CIR asks 3 distinct questions. They are each addressed below: 1. The first question asks if the USGBC has a prescribed method for facilities to back-up comingled recycling percentage rate claims. Per LEED-NC MRc2 CIR ruling dated 12/02/05, if the average annual recycling rate for the specific sorting facility is used, the facility's method of recording and calculating the recycling rate must be regulated by a local or state government authority. . 2. The second question asks the USGBC to provide input on preferred method of inspection. Visual inspection is not an acceptable method of inspection for purposes of documenting percentage of commingled waste diverted from landfill. Method A as described in the CIR is unacceptable and cannot be used as a contribution to achievement of this credit.. 3. The final question asks if the USGBC can define a limit for how much ADC can be used in calculating compliance for MRC2. Currently ADC is an acceptable method for compliance with this credit. As seen in CIR ruling date 05/17/02, ADC meets the intent of MRC2. As a layering substance is required for end of day use at landfills, recycled material from project sites can be processed and sold to fit this need. At this time there is no limit as to how much ADC can be used to fulfill credit compliance. Use of ADC may not the best use of Construction and Demolition waste. Project teams are encouraged to favor reuse, recycle, and salvage for as much material as possible. Please see CIR ruling date 08/02/08 for clarification. Applicable Internationally.
Related Addenda (Corrections & Interpretations)