EBOM 2009 SSc3: Integrated Pest Management, Erosion Control, and Landscape Management Plan

Alyson, I could see this being a part of a landscape management plan that earns this credit, although I don't think it will make or break the credit. You would need to have a set of comprehensive practices covering multiple areas. I don't see it being the basis for an EP point, simply because synergies among credits aren't considered as a basis for EP. Nice work, though!

You should include a narrative the describes the positive environmental impacts of each sustainable measure that is implemented as part of your plan. Try to be as specific as possible.

The literal requirements of the credit focus mainly on animal and insect pests, but the credit intent is that non-chemical methods are used in lieu of herbicides wherever possible as well. The SF Hazard Screening List lists Roundup Pro (and it's active ingredient "glyphosate") as a Tier II product, therefore it would not be considered a least-toxic alternative. I'd suggest spending a bit of time researching non-chemical herbicides, as there are a number on the market, and use hand-pulling as your backup plan. Remember, if all else fails, you are allowed to use a non least-toxic product during your performance period, but you need to explain the least-toxic methods that were found to be ineffective before resorting to the toxic option.

In general the plan addresses should address erosion concerns like slope stabilization after rain events, checking drainage systems like roof drains and storm drains, looking for evidence of erosion and sedimentation and then also erosion and control provisions for any future site construction work.

If there is any other stormwater infrastructure on site like a detention area or other, that infrastructure should be covered by the plan as well.

Robin, this is one of the many areas of confusion created by the new Credit Forms. In this case, what GBCI is trying to express is that, depending on your project building and site, you may not need to addressing landscape waste management or chemical fertilizers. For instance, a zero-lot line building in the middle of an urban core may have no related activities over the course of a year.

However, the Credit Form may be giving the impression that project buildings who have landscaping on-site have the option to address landscape waste management and/or chemical fertilizer use if they choose. This is absolutely not the case. Your plan must address these elements if you have any landscaping waste management or fertilizer activities.

Makes all the sense in the world,

I'm hoping the folks who build these forms have a chance to see the feedback on LEEDUser on this and the other topics so they are armed with enough info to revise and modify their tools.

Thanks for the feedback Jason.

RO

Anderson, there is no threshold like this, below which you could consider notification unnecessary. I would consider it necessary in all cases.

Honestly, Steve, this seems like a comment from a confused Review Team. What you have provided is an iron-clad performance metric for chemical fertilizers. Maybe they didn't like it because the word "chemical" is still in there. All I can suggest is that you provide a supporting document in the form of a log of fertilizer applications over the performance period, making sure to indicate when a fertilizer is organic and highlighting the percent of total fertilizer applications that meet the organic criteria. It wouldn't hurt to include a narrative as well stating that no chemical fertilizers are ever used on the project site.

Jason, we had a similar experience with an informal GBCI review. The comments that came back for both SSc2 & SSc3 had to do with peformance metrics and they are asking to provide some type of documentation / log to show we meet the minimum 20%. I'm advising my client to go back and pull invoices and maintenance records to come up with a log to document compliance. However, their initial review had a performance period that was over a year and a half long. Do you think it would be acceptable to change the peformance period to the 3 month minimum so they don't have to pull so many records in order to document the compliance? Any feedback is appreciated. Thanks!

Well, to date, reviewer are correct in asking for evidence of "continuous improvement". Basically, if your plan indicates that you are shooting for anything less than 100% compliance with each aspect of site management, the reviewer needs a log that verifies that you're meeting the minimum of 20% compliance. To answer your question, I think it's fine to change your performance period to three months - just make sure that the end of all performance periods fall within 30 days of each other.

Thanks Jason. I also posted in another forum "LEED Reviews: LEED Online, Appeals, Design/Construction Submittals, and more" and the response I got there said that it was probably NOT OK but they were not sure and said I could call GBCI to ask. Has anyone else on LEEDUser had any experience with changing the performance period after the initial review?

I am fairly sure that you can attempt the credit in this situation provided you have an appropriate policy for whatever is applicable, and that you explain why whatever is not applicable is not.

One might ask whether, LEED points aside, it makes a ton of sense to pursue, but hey... there is that point.

Yes, pretty much any building type that qualifies for EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. certification is eligible for this credit. Given the description of your project site, I agree that fertilizer usage wouldn't be all that relevant. However, your plan should definitely address erosion and sedimentation control, especially to address impacts from future construction/renovation projects on the building exterior.

You'll need to be prepared to demonstrate that the pesticides chosen are indeed the least-toxic possible. We have a number of tips on the IEQc3.6 checklist page that get into this.

Depends a lot on the project. How much waste do you generate on your project and where does it normally go?

I would say the easiest way is to divert all of it to an onsite
compost pile. Document the policy that all landscape waste goes there,
where it is, and what happens to it.

If we cannot compost all onsite, would number of truck loads be a possibility, as we are not going to weigh the amount or determine volume?

A consistent weight or volume measurement would be ideal. If it's going out in truckloads could you just use the volume of the truck as your measurement?

To the extent that measurements will be inexact, I would recommend aiming for 100% compliance, or as close to it as possible, to demonstrate that there's no doubt you're meeting the credit threshold.

Confirming that tracking compostable landscape waste removed from the site in a consistent manner would meet the requirements. Additional third-party certifications from the receiving dump site is not required. Our building is the first stop on the landscaper's calendar and waste is commingled throughout their day and dumped in a "green" bin back at their shop. Service removes "green" bin of commingled eligible landscape waste to composting site. Assume some sort of third-party certification would help support credit eligibility, but is not required.

First, I'm curious what kind of climate or building this is where flies are constantly hovering near doorways, and this is a problem warranting constant use of pesticides? My reason for asking is to check the plausibility that this mister system is really needed.

The credit requires 100% use of IPM. Can this practice be jusified under IPM? If not, then it's not possible to earn the credit.

Pablo,

The pest-specific language is intended as guidance for building operators when they run into certain common pests. This language is not a required component of a LEED-compliant IPM plan. The required elements are written in black text and even some of those sections are not absolutely crucial (i.e., teams are not required to follow the LEED-EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. Plan model for IPM as this document is intended to be a technical and trade-specific).

Thank you Shira. Regards

Shilpi,

As long as you issue universal notificationUniversal notification means notifying building occupants not less than 72 hours before a pesticide is applied in a building or on surrounding grounds under normal conditions, and within 24 hours after application of a pesticide in emergency conditions. Use of a least toxic pesticide or self-contained nonrodent bait does not require universal notification; all other pesticide applications do. prior to using the pesticides, you can use them. Of course, it's always better to use non-toxic or least-toxic options before using such pesticides.

Shilpi,

If you can record the WHO identification number or another identification number akin to the EPA registration number, you should be able to meet the log requirements. The key is to provide documentation demonstrating that when you use pesticides in or around the project building, you keep a log of the ID numbers to ensure that if occupants come to you with questions, you can easily look up the toxicity and hazard information for them. Additionally, when you issue universal notificationUniversal notification means notifying building occupants not less than 72 hours before a pesticide is applied in a building or on surrounding grounds under normal conditions, and within 24 hours after application of a pesticide in emergency conditions. Use of a least toxic pesticide or self-contained nonrodent bait does not require universal notification; all other pesticide applications do. for the use of non-least toxic pesticides, you'll want to provide enough information to building occupants to allow them to research the pesticide on their own.

Have you reviewed the steps discussed above in the Checklists tab? One point is that even if you have vendors, you need to integrate the credit requirements into their contract language. Also, the credit goes beyond integrated pest managementIntegrated pest management (IPM) is the coordinated use of knowledge about pests, the environment, and pest prevention and control methods to minimize pest infestation and damage by the most economical means while minimizing hazards to people, property, and the environment.. Be sure to also cover erosion control and landscape management.

Sal, the LEEDuser tool is focused on LEED v2009, including LEED-EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems.. However, the 2008 and 2009 versions of LEED-EBOM are quite similar, and so our tool should be able to help with that. If you have any specific questions, don't hesitate to post here on the forum.