This credit focuses on diverting waste from landfills by finding multiple alternatives for end uses of the waste, namely recycling, reuse on site, donation for reuse on another site, or resale. All of these diversion methods count towards credit compliance—50% construction waste diverted for one point, 75% for two points.
Look for opportunities to prevent the generation of waste on construction sites because the less waste you generate, the less you have to recycle or reuse to earn the credit.
There are two different approaches to recycling construction and demolition (C&DConstruction and demolition) waste: separating materials at the source (onsite), or commingling them and sending them to an off-site waste sorting facility. Either approach can work well. Your choice will depend on whether there is room for sorting onsite, whether the contractor is willing to take that on, and if there are good sorting facilities nearby.
The ease or difficulty of this credit depends on project-specific and regional conditions.
The general contractor (GC) is responsible for developing the CWM plan early in the construction process, if not before (during preconstruction). The GC does this in collaboration with the project team and is then responsible for implementing it, verifying that it is being followed throughout the construction process, and documenting the results.
Waste generated off-site, even for modular construction and pre-fabrication of major assemblies is not accounted for in the MRc2 calculations. MRc2 looks only at the management of waste generated onsite.
LEED InterpretationLEED Interpretations are official answers to technical inquiries about implementing LEED on a project. They help people understand how their projects can meet LEED requirements and provide clarity on existing options. LEED Interpretations are to be used by any project certifying under an applicable rating system. All project teams are required to adhere to all LEED Interpretations posted before their registration date. This also applies to other addenda. Adherence to rulings posted after a project registers is optional, but strongly encouraged. LEED Interpretations are published in a searchable database at usgbc.org. #10265 made on 01/01/2013 provides the best official guidance for this situation. The approach that is approved in that situation involves multiple buildings, all being certified to LEED-NC. The ruling allows the project to track together all demolition and construction waste diverted, and to then apply a weighted average based on gross square footageSum of the floor areas of the spaces within the building including basements, mezzanine and intermediate-floored tiers, and penthouses with headroom height of 7.5 ft or greater. It is measured from the exterior faces of exterior walls or from the centerline of walls separating buildings, but excluding covered walkways, open roofed-over areas, porches and similar spaces, pipe trenches, exterior terraces or steps, chimneys, roof overhangs, and similar features. to each LEED project. Each building must meet the required threshold for waste diversion in order to earn the credit and in addition, the Construction Waste Management (CWM) Plan must outline goals for diversion for each building, not just as an aggregate across all projects.
If your project is in a similar situation but with different specific circumstances, LEEDuser would recommend adopting that advice as closely as possible, while accounting for any differences in a way that meets the LEED credit intent. Some projects may want to get an official ruling—either a CIR or LEED Interpretation.
Yes, materials that would otherwise be waste, but that are diverted from the landfill to be salvaged or reused can contribute to MRc2.
No. Hazardous waste does not count and it is excluded from the numerator and denominator portions of the credit calculations. You may want to include a brief narrative on the hazardous waste you found and how your project abated the material.
There has been some debate about this, since on the one hand this waste does not qualify as typical C&D waste, but on the other hand it is waste generated onsite, which this credit is intended to address. LEEDuser's experts recommend including this waste because it falls under the broader definition of waste generated onsite, and because reduction, recycling and diversion programs can be extremely effective in reducing the quantity of this waste. Having workers pay attention to this waste makes them more aware of overall job-site recycling, and not mixing lunch waste with construction waste like scrap metal increases the recyclability of the construction waste.
USGBC has ruled (for example, see LEED Interpretation #10061) that diverting waste to incineration facilities does not contribute to MRc2, but that Wood Derived Fuel (WDF) does meet the intent of this credit. As that ruling states, "The WDF process differs from incineration processes that are not allowed in this credit because the recycling facility provides a value-added process; it is a service that exists to sort and distribute materials appropriate to the highest end uses possible. In addition, the revenue generated by the WDF commodity helps to make this business successful and thus facilitates recycling of wood to other end uses as well as recycling of other materials."
According to the LEED Reference Guide, land-clearing debris includes soil, vegetation, and rocks.
Use the solid waste conversion factorsEstimates are presented in customary U.S. units. Floorspace estimates may be converted to metric units by using the relationship: 1 square foot is approximately equal to 0.0929 square meters. Energy estimates may be converted to metric units by using the relationship: 1 Btu is approximately equal to 1,055 joules; one kilowatthour is exactly equal to 3,600,000 joules; and one gigajoule (109 joules) is approximately 278 kilowatthours (kWh). in the LEED Reference Guide to account for recycled materials in dumpsters billed by volume.
It is typically better to use project-specific diversion data when you can get it, and this data should typically be accepted in a LEED review. However, there are other options.
There are LEED Interpretations such as LEED Interpretation #10060 made on 5/9/2011 that allow use of a facility-wide recycling rate, if approved by local regulators. On similar lines, a 5/9/2011 addendum added this note to the LEED Reference Guide: “For commingled recycling the average annual recycling rate for a sorting facility is acceptable for recording diversion rates only when the facility's method of recording and calculating the recycling rate is regulated by a local or state government authority.”
Either identify a hauler with a strong recycling program, or research and find local recycling facilities to which you can send your hauler.
Research the waste management system:
Check local government websites for recycling programs. Also search for other ways to put materials back in circulation, such as exchange programs and brokers. For example, pallets and packaging can be sold or given away through these programs.
Construction materials vary with project location and building type. Some materials are easier to recycle than others. For example, copper wire and steel studs are readily recycled into new products, but vinyl tiles may not be. Research and specify what materials can be recycled, reused, or salvaged in the project’s municipality or region—and design with these materials so that waste scrap can be diverted from the landfill. For example, specify carpet from a manufacturer that has a take-back program, or ceiling tiles that are easily recyclable. Using precast concrete will avoid waste generation from in-situ concrete that will help in total waste generated.
Demolition projects can give away furniture, computers, and other equipment. Projects can also reuse items like doors, and crush demolished concrete and other paving materials to be reused as fill onsite. Demolition and renovation jobs can present many opportunities for salvaging items like wood timbers, architectural detailing, stonework, and millwork for reuse on another project, sale, or donation.
Research and use manufacturer “take-back” programs as much as possible. Manufacturers increasingly take back equipment and materials at no or low cost to the project. These programs are common with certain equipment and computers, ceiling tiles, and carpeting, for example.
Develop a list of construction materials from the budget estimate.
Determine if the waste will be measured by volume or by weight and keep it consistent. (Most projects pursue measurement by weight instead of volume.)
Target materials that are plentiful and either heavy or voluminous, depending on your documentation approach, and that are easy to recover and recycle to meet the 50% or 75% credit thresholds.
If discarding a lot of heavy stone, metal or masonry products, it will probably be more advantageous to track weight.
If discarding lots of packaging, insulating foam, and other light materials, you may prefer to track volume.
Selecting the right waste processor can minimize cost, but you have to strike a balance between cost and the feasibility of using that waste processing plant based on distance from the site and whether the hauler will agree to use that facility.
Recycling often generates revenue for the hauler who may then reduce the fee for the project. It also generates savings by reducing landfill tipping fees, which is beneficial to the contractor.
Contractors may claim that the CWM coordination and administrative oversight cost more money than recycling is worth, but many good contractors have figured out how to do CWM and can make it work for the same amount or less than typical trash hauling. This is somewhat dependent on the location of the project and available local resources.
If dealing with an existing building and a large amount of material is salvageable, consider deconstruction and materials salvage as an alternative to demolition. The contractor will have to oversee the process carefully. Many resources are available on deconstruction. (See Resources.)
Deconstruction will add extra cost to the project due to the additional labor required to take materials apart, remove nails from wood, and maintain material integrity. Ideally, the contractor will find a buyer for the materials to help offset these costs.
Thinking long term, consider what design decisions can increase the likelihood of deconstruction further down the road when specifying materials and systems to be used in the current project. Material selection and assembly type can impact how materials may be deconstructed and reused at the end of the building’s life-cycle.
Perform a site survey to decide whether deconstruction makes sense. This will depend on how the building was assembled and the value of the materials to be salvaged.
Deconstruction is a good practice for maintaining a building material’s integrity so it can be reused. It certainly diverts waste from landfill and contributes to credit compliance as waste diversion.
Typically, good materials to salvage via deconstruction include wood framing, steel columns and beams, hardwood flooring, multi-paned windows, architectural details, plumbing and electrical fixtures, hardware and cabinetry, and high-quality brick work.
Renovation and restoration projects are good candidates for deconstruction.
There are industry standards on good practices for deconstruction as well as directories of experienced contractors, such as the Deconstruction Institute (see Resources).
Deconstruction can take longer than demolition. Project teams should estimate whether the extra labor spent on deconstruction can be offset by the value of the salvaged materials. Other benefits to weigh include the environmental benefits of reduced waste and avoiding use of new resources, and publicity benefits for materials reuse.
The project team should discuss the appropriate recycling process, including whether sorting will occur on or off site. This decision may be made after the general contractor joins the team. Both options have pros and cons (see table).
Early in the project, the architect should be involved in the plan to schedule construction and deconstruction with the contractor.
Hire a general contractor early in the project to discuss the deconstruction process and phasing.
Integrate CWM plan and MRc2 requirements into the construction specifications.
For guidance on how to write LEED specifications and CWM requirements into construction documents, see MasterSpec (see Resources).
If separation is occurring off-site at a comingled or mixed-debris processing plant, make sure the processor or recycling facility can provide documentation for the amount of waste processed, by weight or by volume, as agreed, as well as a diversion rate from the facility. This could be either a project-specific diversion rate supplied by the facility, or a letter from the state regulating body with the facility's average rate of recycling.
Waste prevention is an important part of CWM.
Orienting the GC to the tracking tools early on and providing on-going support to the CWM effort is critical to success.
The GC and project team should hold an orientation meeting to review all LEED-specific issues related not only to recycling and reuse, or salvaging, but also to reducing waste onsite in general.
The GC develops the CWM plan.
A CWM plan is an action plan for how to deal with construction and demolition (C&D) waste. At a minimum, it needs to identify what the recycling goals are, what materials will be recycled, reused or salvaged, which materials will be landfilled, and the estimated amounts of each (either by volume or by weight, but consistently throughout the project), processors that will receive the construction and demolition waste, and onsite procedures for achieving the stated goals.
Developing the CWM plan is the responsibility of the contractor but, ideally, the project team should work together to come up with a thorough CWM plan that addresses not only recycling, but also reusing and salvaging as many materials as possible.
In developing a CWM plan, take into account regional constraints, and weigh the feasibility of recycling or salvaging materials against other environmental factors, such as the impact of hauling waste long distances if recyclers are far from the project site. In such an instance, if site conditions allow, one strategy would be to stockpile material to be hauled only once or twice during a project to cut down on transportation cost and associated environmental impact.
Source separating, or onsite sorting, can yield the highest recycling rate and the best price for materials. Try to encourage the contractor to locate separate containers onsite to sort the materials.
Providing a sample CWM plan and guidelines on how to communicate it to subcontractors and workers can help to minimize any hesitation on the part of the GC.
Hiring construction teams that already have LEED experience and are familiar with CWM is helpful for credit achievement. They may already have developed CWM plans, have existing relationships with haulers and recyclers, and know how to train construction field personnel in CWM practices and track diversion rates.
Review LEED requirements with contractors during the bidding process so that they understand their responsibilities.
Subcontractors should be contractually required to implement their part of the CWM plan. Accountability is key to successfully implementing a CWM plan.
Hire a special deconstruction contractor if required.
Provide a deconstruction-detailed drawing and specification with specific handling instructions for each material to be removed, such as whether it will be salvaged and sold, reused onsite, or marked for recycling.
Require measures for deconstruction in the CWM plan.
The GC is responsible for implementing the CWM plan and making sure the recycling and reuse goals are met. (The GC should make sure to review the action steps and tips associated with developing the CWM plan, above.)
Provide training for each contractor and subcontractor about the CWM plan and the importance of documenting it. Make sure everyone is on the same page regarding recycling goals. Make each training session specific to that trade.
As new subcontractors start work on site, have a LEED orientation session as part of safety trainings or other jobsite orientation meetings.
Consider designating a recycling coordinator (most likely someone in the GC’s office) to deal with all issues both onsite and off-site pertaining to CWM and making sure the plan is implemented properly and followed by all involved.
Weekly construction meetings should include an update, with a biweekly or monthly report collected by the LEED consultant, architect or owner. The CWM plan should outline this step, but it is important to make sure that all subcontractors and the GC are working together to comply during construction.
The contractor should communicate with all subcontractors about the recycling policy to make sure it is being followed. Recycling activities should be discussed regularly at job meetings.
A designated recycling coordinator can facilitate communication with all field personnel and address problems in the field promptly. This can reduce the risk of getting to the end of construction and falling short of diversion goals when it is too late to do anything about it.
The GC and recycling coordinator should track the deconstruction process and make sure requirements and specifications are being met.
The deconstruction contractor submits sales receipts, donation receipts, and recycling weight tickets to the GC or recycling coordinator, so the diversion rates can be included in the CWM tally.
Preserving materials for reuse reduces waste disposal fees.
Train the staff on how to streamline onsite waste sorting. Identify champions within each subcontractor’s team to lead the CWM effort for their teams.
Designate a separate area to place bins for recycling. If waste is commingled (for off-site separation by the recycling center), some additional space is still required to keep wet waste and other garbage apart from recyclables.
A good CWM plan will include measures for waste prevention so that less waste is created in the first place. Consider requesting subcontractors to ask their vendors to use minimal or take-back packaging. As an incentive, specify that all subcontractors are responsible for returning pallets or recycling their packaging.
Use signage to support the CWM plan—reminding subcontractors to sort waste appropriately. Post signs on the sorting bins, garbage cans, and throughout the site. Signs should include whatever languages are needed to communicate with workers on the jobsite.
The recycling coordinator tracks onsite waste recycling every month, or with every filled bin, to stay on track. The bins may fill at different times, depending on the material. Every time a bin is emptied and weighed, fill in the data on the tracking sheet.
In cities where tipping fees are high, a lot of waste haulers separate waste automatically, just to avoid the fees, so contractors and subcontractors may have to source-separate onsite anyway.
Consider fencing recycling areas, screening recycling and trash dumpsters from the public or locating them in an inconspicuous area. Neighborhood “use” of dumpsters to dispose of old mattresses and other furnishings is a problem that contractors deal with regularly, especially in cities where disposal of bulky items is expensive. On the other hand, in areas where there are limited resources for construction waste recycling, projects can stockpile wood and other potentially desirable construction waste and make it available to workers and the community to take home. This material can then count towards diversion.
If separation is occurring off-site, make sure recyclables are not contaminated with other garbage and wet waste. Provide separate containers for food waste and miscellaneous garbage and mark all containers clearly and prominently.
Keeping coffee cups and food waste out of recycling bins can be especially challenging. Use clear signage to prevent this and make it easy for food waste to be properly disposed of by providing trash cans clearly marked and in various locations on the site or at each building level.
If separation is occurring off-site at a mixed-debris processing plant, make sure the recycling facility can provide documentation for the amount of waste processed, by weight or by volume, as well as monthly recycling rate information, which is required for documentation purposes.
Keep an ongoing log of weight tickets and receipts. The GC needs to track construction waste throughout the construction process. It is crucial that contractors request and keep all receipts and weight tickets from recycling companies to prove that diversion goals were achieved, as well as letters from recycling companies certifying their monthly recycling rates.
Maintain a project log to input all the monthly reports in one place. This will track project waste recycling rates and provide an alert if the average is lower than the target of 50% or 75%. Address these shortfalls early in the process to ensure that final diversion rates can be met.
LEED project managers should provide contractors with tracking or log-book forms to simplify the tracking process. See the Resources section for the LEEDuser CWM tracking calculator.
Waste amounts must be tracked consistently, either by weight or volume. If materials are very heavy, it is best to use the weight approach. Most waste processors track by weight, anyway. But this will depend on what the bulk of the project’s waste is made of.
Do not include land-clearing debris or excavated soil or rock in your calculations. Even if diverted from landfill, it is not to be included in the credit calculations. Contractors often think that trees and stumps are still part of the diverted waste, but take them out of the LEED credit form and supporting documentation if the contractor includes them.
Compile construction waste recycling data from all the monthly reports, and complete your LEED documentation online for submission to the USGBC.
Monthly reports from recycling facilities, showing their average monthly recycling rates, are an appropriate form of documentation for this credit.
Build on construction waste management practices for future renovations and remodeling.
Excerpted from LEED 2009 for New Construction and Major Renovations
To divert construction and demolition debris from disposal in landfills and incineration facilities. Redirect recyclable recovered resources back to the manufacturing process and reusable materials to appropriate sites.
Recycle and/or salvage nonhazardous construction and demolition debris. Develop and implement a construction waste management plan that, at a minimum, identifies the materials to be diverted from disposal and whether the materials will be sorted on-site or comingledA process of recycling materials that allows consumers to dispose of various materials (such as paper, cardboard, plastic, and metal) in one container that is separate from waste. The recyclable materials are not sorted until they are collected and brought to a sorting facility.. Excavated soil and land-clearing debris do not contribute to this credit. Calculations can be done by weight or volume, but must be consistent throughout. The minimum percentage debris to be recycled or salvaged for each point threshold is as follows:
You may use the LEED v4 version of this credit on v2009 projects. For more information check out this article.
Establish goals for diversion from disposal in landfills and incineration facilities and adopt a construction waste management plan to achieve these goals. Consider recycling cardboard, metal, brick, mineral fiber panel, concrete, plastic, clean wood, glass, gypsum wallboard, carpet and insulation. Construction debris processed into a recycled content commodity that has an open market value (e.g., wood derived fuel [WDF], alternative daily coverAlternative daily cover is material (other than earthen material) that is placed on the surface of the active face of a municipal solid waste landfill at the end of each operating day to control vectors, fires, odors, blowing litter, and scavenging. material, etc.) may be applied to the construction waste calculation. Designate a specific area(s) on the construction site for segregated or comingledA process of recycling materials that allows consumers to dispose of various materials (such as paper, cardboard, plastic, and metal) in one container that is separate from waste. The recyclable materials are not sorted until they are collected and brought to a sorting facility. collection of recyclable materials, and track recycling efforts throughout the construction process. Identify construction haulers and recyclers to handle the designated materials. Note that diversion may include donation of materials to charitable organizations and salvage of materials on-site.
Source for receiving salvaged or deconstructed materials.
Waste management solutions - New York only.
New York City's only non-profit retail outlet for salvaged and surplus building materials.
A step-by-step guide on deconstruction for contractors.
Template for writing specifications on construction waste management as part of the MasterSpec licensed spec system.
Federal Green Construction Guide for Specifiers sample spec language.
Sample CWM Plan.
Resources Guide to developing a CWM plan.
This is a resource database of contractors proficient with deconstruction and organizations, distributors, or contractors seeking material to salvage.
This website from the California Integrated Waste Management Board contains information on recycling and the use of recycled-content materials. The site includes many publications available for free download, such as sample construction and demolition debris recycling specifications.
This online database contains information on companies that haul, collect and process recyclable debris from construction projects sorted by zip code.
CMDepot is a place where you can buy & sell excess construction material, tools, & equipment. You simply login, submit a listing of your excess material, and wait for a buyer. If a buyer contacts you, you can work out payment details and a delivery method.
Comprehensive web page on construction waste management for large projects, with links to other resources.
WasteCapTRACE is an online documentation program for tracking construction and demolition debris recycling. It generates a custom construction waste management plan, provides a forum in which multiple team members can record data, and outputs reports and charts for your LEED submission. WasteCapTRACE is priced on a per-project basis, with fees linked to project square footage (like LEED application fees).
PlanetReuse is a nationwide reclaimed construction material broker and consultant company. They make it easier to use a wide variety of reclaimed materials in new projects as well as help find new projects for building materials being deconstructed, guiding owners and contractors through every step of the process. LEED documents are also provided for waste management documentation.
This guide is developed by wastematch.org, an organization that matches donors to recipients.
Model specification language that can be used by architects and engineers who want to reduce waste during construction.
Use clear signage such as in these example to keep construction and demolition waste separated for diversion purposes.
If you use commingled construction waste management, in which CWM is commingled and weighed off-site or calculated using a recycling facility's average diversion rate, you'll need special documentation to justify your rates for LEED. This sample was provided by Sustainable Solutions Corporation.
Use a tracking sheet and calculator like this one to monitor your credit compliance.
This document provides key tips and sample tracking sheets and checklists for your project's construction waste management (CWM) plan.
The following links take you to the public, informational versions of the dynamic LEED Online forms for each NC-2009 MR credit. You'll need to fill out the live versions of these forms on LEED Online for each credit you hope to earn.
Version 4 forms (newest):
Version 3 forms:
These links are posted by LEEDuser with USGBC's permission. USGBC has certain usage restrictions for these forms; for more information, visit LEED Online and click "Sample Forms Download."
As the general contractor on a recently completed LEED project, all of the tickets I've received from the off-site waste separation facility listed the tonnage diverted by item, i.e., concrete, metal, wood, plastic, cardboard, etc. Then, one of our subcontractors - who provided his own containers -used the same recycling facility, the tickets I've received from them do not separate the items, the tonnage recycled was just provided, not the breakdown. The recycling facility assured me the material was 100% recycled and not landfilled - can I include that tonnage as "MIXED DRY REC." since i cannot be more specific as to the contents? Thanks!
Christine - Was this waste collected as commingled or site-separated? Based on your description of what you received from the recycling facility, it seems like your description makes sense and you'd need to also show this as commingled on the form (Diverted or Landfill Waste column) and provide backup from the recycling facility showing the overall recycled percentage.
Michelle - the waste was commingled and separated off site. Just so I understand, your interpretation is I can use the tonnage as Mixed Dry Recycled, as long as i have backup from the recycling facility showing the overall recycled percentage?
I am glad to know it was commingled. This makes this approach even more straightforward.
To answer your question - yes; however, I want to clarify that the percentage from the recycling facility is for your specific job and not a facility-wide recycling rate. If it is not specific, see the last FAQ above and the reference to LI ID #10060 - http://www.usgbc.org/leed-interpretations?keys=10060 regarding facility-wide recycling rates.
We have receipts for 238 wooden pallets which were returned. I am trying to decipher if these can be considered diverted material as the alternative here is to take them to the landfill. However, we haven't been given a weight but, that wouldn't be to hard to find out. Has anyone else been successful in claiming these this way? Or, is there another way they can be utilized for credit?
Lisa - Sorry for my tardy reply. I was away from all communications while on vacation.
I haven't had your exact situation before but it appears that you can count these pallets as diverted since they otherwise would have been landfilled... It sounds like you are doing your calculations by weight and hence only need the weight to calculate the overall contribution to diversion from the landfill. Combined with your receipts for the pallets return, the weight calculation would make a complete set of backup if the reviewer questioned your approach. Way to go on going the extra mile for diversion!
Thank you so much Michelle. Great to know. I will include these in our calculations.
We have a project on a large campus which has involved demolition of over a dozen buildings. There has been a strong focus on waste diversion which has allowed us to achieve just over 95% thus far. One of the smaller remaining structures has gained the interest of local fire departments which have requested the opportunity to use it as for a training burn. They would ignite the building on site and use it for a day-long series of practice exercises. Presumably little but ash and foundation would be left at the end of the day.
Has anyone encountered this situation in a LEED project before? Do we count this as diverted because the structure is slated for demolition and doesn't end up in a landfill? Entirely exclude it from the calculation on the basis that it isn't construction waste if used for a different purpose prior to demolition?
Brian - Sorry for my tardy reply. I was away from all communications while on vacation.
I don't have experience with this situation and it doesn't seem like anyone else has as no one has chimed in yet. Based on what you've shared, totally excluding it does not seem right because there will be waste after the burn that your project will need to remove in order to complete your project. I would include the remaining materials after the burn as either diverted or landfilled waste - depending on their disposal.
Thank you for the reply. The owner decided that coordinating a fire training exercise with an active construction site was not feasible. So, I won't be able to fill folks in on the intricacies of this situation. It's an interesting one, and I agree with your assessment.
I have a question about doing an overseas project. Do we need some kind of Letters of Certification for the recycling facilities we are using? Do they have to be vetted in some way as a recycling center?
John - I haven't had the opportunity yet to work on any overseas projects; however, I am not aware of any special requirements for international projects for MRc2. Does anyone else have experience on this who can share his/her insights?
I don’t have overseas experience either, but I have dealt with a couple regulatory issues that apply to ALL projects, but differently depending on locale:
1. Minimum Project Requirement MPR 1 requires all project work to “comply with applicable federal, state, and local building-related environmental laws and regulations in place where the project is located.” Therefore, all laws regulating waste disposal and recycling in you jurisdiction apply. Your waste handlers, recyclers, & disposal sites must comply with certifications, registrations, & any other qualifications required by local regulators.
2. Also, for commingled waste that is sorted at an off-site facility, LEED Interpretations #10060 & #3000 and Addenda Item #100000902 prescribe a method of calculating diversion rates base on annual averages, but this method only applies if the facility is regulated by local “government authority as a closed system.” See:
If local government does not regulate the sorting facility, each commingled load must be evaluated by weight as described by “Methodology #1” in the ruling for LI# 5171:
Jon - Thanks for sharing your thoughts.
I reached out to USGBC and a reviewer replied that there are no specific requirements for projects outside the U.S. She did highlight the same information that you mention regarding commingled waste verification. She pointed specifically to 5/9/2011 Reference Guide Correction ID #100000902 - http://www.usgbc.org/leed-interpretations?keys=100000902 - and if the annual average recycling rate of the sorting facility is used, then it must come from a regulating local or state government authority.
Thank you both for your information. It has been a big help.
Incidentally, Construction Waste & Demo Specs that I have worked with include contract language requiring compliance with local regulations and licensing requirements. As a result, the submitted Construction Waste Management Plans (CWMPs) have included evidence of approval from local regulators. These attachments may become part of the LEEDonline submittal when we upload the CWMP, as required, to the MRc2 form.
Also, if the waste table on your MRc2 form includes commingled entries, LEEDonline requires you to upload documentation to support the reported diversion rates. If using the “average annual” facility rated allowed above, that documentation must come from the local regulator.
Review your waste contract language, research local requirements, and work with local regulators to obtain proper documentation.
On a demo project where material was brought to multiple recycling centers, some of the recyclers gave me both net and gross tonnage, and some only gave me pounds, which i converted to net tonnage. My question is should i be using the gross tons weight where i have it and use the net tonnage where i dont have gross tonnage info?
Your units must be consistent. I am assuming that gross tonnage includes the weight of the bin in which case you should be using the net tonnage.
Hi Christine - I agree with Scott. You need to be reporting your information in consistent units and you care about the actual materials weight, which I assume to be net tonnage.
I'll be submitting a CIRCredit Interpretation Ruling. Used by design team members experiencing difficulties in the application of a LEED prerequisite or credit to a project. Typically, difficulties arise when specific issues are not directly addressed by LEED information/guide on this, but does anyone have any guidance on redirecting drywall to be pulverized and used as a cap on a landfill closure? Wondering if there is an issue with this not being seen as a waste diversion from landfill.
Allison - I'm sure you've checked the current LI Database (http://www.usgbc.org/leed-interpretations) on this subject, right? I can't remember an instance of using a material as a landfill cap but I've never looked specifically for it before. It sounds awfully close to alternative daily coverAlternative daily cover is material (other than earthen material) that is placed on the surface of the active face of a municipal solid waste landfill at the end of each operating day to control vectors, fires, odors, blowing litter, and scavenging. that is currently allowed. I’m sure you’re aware of the latest process with Project CIRs - http://www.gbci.org/Certification/Resources/cirs.aspx and the next step LEED Interpretations - http://www.usgbc.org/sites/default/files/LEED_Interpretations_Guidance.pdf. Maybe some other LEEDuser member has some experience they will share.
The pulverized dry wall will emit hydrogen sulfide and should not be used for landfill cover.
Is the pulverized drywall from new drywall or used drywall?
We have a project with some existing asphalt pavement that will be busted up and used as clean fill on the same project. Will LEED accept measurements of the length, width and depth of this material instead of trucking it offsite to get it weighed? What if these measurements were done by a licensed Civil Engineer - would that make them more credible?
I would do it like this: I recall there is an official volume to weight conversion chart on the USGBC site somewhere; possibly even in the credit resources tab in the right-hand box of the credit info page on line, or in the Ref Guide. Measure the asphalt and photograph the measuring so that actual distances are readable on the tape, as proof of volume. You can upload those photos. Then make the calculations using the table.
Susan - Thanks for getting Lawrence headed in the right direction! Lawrence - You do not have to weigh. Have whoever did the measurements now develop a volume in cubic yards. Then they can calculate a weight in lbs based on the Solid Waste Conversion FactorsEstimates are presented in customary U.S. units. Floorspace estimates may be converted to metric units by using the relationship: 1 square foot is approximately equal to 0.0929 square meters. Energy estimates may be converted to metric units by using the relationship: 1 Btu is approximately equal to 1,055 joules; one kilowatthour is exactly equal to 3,600,000 joules; and one gigajoule (109 joules) is approximately 278 kilowatthours (kWh). are located in Table 2 on page 360 of the first edition of the Reference Guide. Having a qualified professional familiar with the asphalt will be a bonus for your piece of mind and will be useful in case there is a question about the diversion but a licensed Civil Engineer is not required.
As part of the owners precronstuction abatement flooring adhered to hazardous floor tile was removed by an abatement contractor. Are we correct that all of this material is excluded from calculations?
Yes, I would say so—if it's adhered you don't have much choice about diverting it.
I work for a commercial waste hauler and C&DConstruction and demolition recycling facility. We have recently started recycling scrap drywall from new construction projects. Our process for recycling this material allows us to use this product locally in the agricultural process.
My question is, does the process qualify under regional priority or innovation and design for some bonus points on a LEED project?
Hi Craig - I applaud you on your efforts but...
Your work to use this product locally in agriculture contributes to MRc2 and diverting waste from the landfill, which is the intent behind this credit (To divert construction and demolition debris from disposal in landfills and incineration facilities. Redirect recyclable recovered resources back to the manufacturing process and reusable materials to appropriate sites.) Hence your efforts are not achieving "significant, measurable environmental performance using a strategy not addressed in the LEED 2009 for New Construction and Major Renovations, LEED 2009 for Core and Shell Development, or LEED 2009 for Schools Rating Systems," which is required for Path 1 - Innovation in Design under IDc1. But if you were to help a project achieve 95% diversion you could help them get an innovation point for Path 2 - Exemplary PerformanceIn LEED, certain credits have established thresholds beyond basic credit achievement. Meeting these thresholds can earn additional points through Innovation in Design (ID) or Innovation in Operations (IO) points. As a general rule of thumb, ID credits for exemplary performance are awarded for doubling the credit requirements and/or achieving the next incremental percentage threshold. However, this rule varies on a case by case basis, so check the credit requirements. under IDc1.
Regional Priority points are awarded for current LEED credits assigned as RP based on project’s zip code. If MRc2 is a regional priority for a project’s zip code, then you might be able to earn a point there but there’d have to be a shortage of landfill space or some other waste issue to have MRc2 designated as an RP. I haven’t seen it. Visit http://www.usgbc.org/rpc to confirm.
We are working on a project where the customer wants to divert wood donating it to people to use in their home furnaces (for cooking and heating). Can we document this as waste diversion?
You may be able to argue this especially if the wood is clean with no paint on it. But I think the chance of it being approved is small. All the publicly available literature I can find says that wood can only be counted as diverted if it is "Wood Derived Fuel" used at an "industrial plant." Burning wood generates a lot of particulates and home furnaces aren't likely to capture and scrub a lot of that before it's emitted to the neighborhood air. See ID #2629
Our Project got 100% diversion. This was a result of a very hard work implemented by the builder, the owner and the entire costruction team. They even recycled the wrapping pappers from the paving blocks. They trained the workers, there was a person auditing the construction site full time every day, they even found a company that recycled cement bags, a hazardous waste, which does not count for this credit but we'd like to mention to illustrate the effort that was implemented. All this and the final review decision was to deny the 2 points of the credit and 1 point of exemplary performanceIn LEED, certain credits have established thresholds beyond basic credit achievement. Meeting these thresholds can earn additional points through Innovation in Design (ID) or Innovation in Operations (IO) points. As a general rule of thumb, ID credits for exemplary performance are awarded for doubling the credit requirements and/or achieving the next incremental percentage threshold. However, this rule varies on a case by case basis, so check the credit requirements.....Was all or nothing, very unfair.
Now we are entering the appeal stage but we don't even know what type of arguments we could use to prove all the actions taken. On the preliminar review we already submitted all the waste haul receipts, spreadsheets and a letter signed by the general contractor stating all the actions taken to achieve such result. And the comitee denied. Is it even worth to try? How? What other type of documentation could we possibly submit to prove this?
Marcio - Can you give us more information as to why it was denied (give us the review comments) and when (meaning what review phase was it denied at)? Without having more information as to why they denied the credit it is hard to respond. If you truly diverted 100% per LEED requirements, I am puzzled by the denial and it could be an instance of a reviewer error.
I work hard to not have credits denied and so have never dealt with a formal appeal. I would direct you to the LEED Certification Policy Manual - https://www.leedonline.com/irj/go/km/docs/documents/usgbc/leed/config/te... - to understand the logistics and documentation process (start on page 20).
Maybe other LEED users can assist as well.
It's our first time appealing as well. That's why we are feeling a little insecure about the procedure.
I've read the Appeal Policy, and they mention such things as "First Level Appeal" and "Final Level Appeal", which just made me more confused....and plus, and this goes on "appeal as a challenge to GBCI Determination" and Appeal to pursue new credits". These last ones I understood, I think we fit on the 1st case, since we disagree with the decision.
Here's the review comment:
"(...) However, a 100% diversion rate is above typical industry best practices since there are usually product containers, small scraps, and debris that are not recyclable. Please provide a narrative explaining how miscellaneous materials such as those listed above were diverted from landfill."
As I mentioned in the other post, they even recycled the wraping paper of all materials that arrives in the construction site. To respond to this "however" in the preliminar review we submitted: 1) all the waste haul receipts, 2) letter signed by the general contractor explaining all the actions taken to achieve 100%, 3) spreadsheet showing the monitoring of all waste generated over the entire construction period.
Don't know what else can we say to prove...
Marcio - I think the thing that you'll have a hard time overcoming is the 100% claim. The EP point threshold is 95%. Beyond pride, is there a reason to push for 100% and not 95%?
Also, I hope you write up a case study on these unusual materials diverted. There are a lot of projects and contractors that would be interested in your innovative processes.
Marcio, if you want to work with me on a case study of 100% diversion, please contact me. I think Susan hit the nail on the head, though.
Susan and Tristan - Thanks for chiming in. Susan is spot on with the 95% diversion rate and the request that you write up your innovative strategies.
Marcio - You should take Tristan up on his offer!
But first, the comment you quoted sounds like a clarification request - not a denial. Are you sure it was denied and is not pending per the request for additional information?
No Michelle, it's written "denied", I've double checked. This review coment I posted above is the last one we got, from the preliminary review application report. I looked but couldn't find an updated report available between final decision and acceptance of final decision. For our other projects, I could easily access the report imediatelly after acceptance of deicision. But since this one is "in between" decision/acceptance of decision I didn't see any report avaliable...
So folks, in order for us to proceed with the appeal process, do you see any other type of documentation that we could use to retrieve these 3 points? It's okay for us to keep it between 95%<100%. I just wonder how we would "unsay" what it's already said...since we've already said, two times (1sr in the original submission and 2nd in response to the review comments), we diverted a 100%, how can we go about to say now that we diverted less than this without seeming that we are saying it just to gain these 3 points?
Thanks for the invite, we would love to engage our team in working on a case study with you! Tristan, guess the link you sent with your contact is broken, would you mind sending it again?
Marcio, the link works fine for me. It should go to our contact page.
Marico - Do you have photographs, receipts, and other documentation you can provide? You need to build a case and show what you did.
Here is the link from Tristan again - http://www.leeduser.com/contact.
I have been involved in several appeals. Something is not quite right. Though I agree with the 95% comment by Susan and all the advice you've been given, it seems to me that what you need to make your argument is their second review response. If I understand correctly, you submitted your data and got their preliminary comment. You then resubmitted your responses and got denied.
There would have to be a second comment responding to your "resubmitted" data that should give you the key as to why they are still unhappy. I'm not sure why you can't get a report that shows it, but have you tried the Review Comment link on the Credit Information page of that specific credit?
If it were me, in order to build my argument, I would first pursue their response to the resubmitted data.
Hi Michelle! I'm so glad you mentioned the Review Comment link on the credit informaiton page I haven't clicked there. Just found out that there was a misinterpretation somewhere along the way. For some reason, they though we sent waste for incineration and didn't inform how much! No idea where they got that from...I wonder if was a language thing since we submitted in portuguese. Oh wow, that makes it even more unfair...now the client will have to pay for it in order to appeal. And the worst thing is that the 2nd comment is completely diferent from the 1st comment, which states the 'problem' is proving the 100%. In the second comment the problem turns out to be incineration. Crazy! Comments from the second review below. What's the best way to respond to that?
"However, as stated in LEED InterpretationLEED Interpretations are official answers to technical inquiries about implementing LEED on a project. They help people understand how their projects can meet LEED requirements and provide clarity on existing options. LEED Interpretations are to be used by any project certifying under an applicable rating system. All project teams are required to adhere to all LEED Interpretations posted before their registration date. This also applies to other addenda. Adherence to rulings posted after a project registers is optional, but strongly encouraged. LEED Interpretations are published in a searchable database at usgbc.org. #3004, #2141, and #10138, and based on the credit intent, incineration of construction waste materials cannot be used as an alternative for diverting waste from the landfill. The credit intent states, "Divert construction and demolition debris from disposal in landfills and incineration facilities." From the documentation provided, it is not clear of the amount diverted from landfill what amount of waste had not been sent to incineration facilities. Therefore it is not possible to determine the total percentage of construction waste actually diverted from landfill as defined and outlined by the LEED Building Design and Construction Reference Guide 2009 Edition."
Marico - It's so great that resourceful folks, like Michelle, provide their insight. I am glad you discovered the issue but do not despair about the unfairness yet. This is the perfect opportunity to use the Questions about Review Comments dropdown from the GBCI Contact Us page - http://www.gbci.org/org-nav/contact/Contact-Us/Project-Certification-Que.... If a mistake was made during the reviews, you should not have to pay to appeal it - especially if a language barrier was part of the issue. BEFORE YOU APPEAL, use the method I note about and explain your case. Based on my past experience with this method, you should be able to get assistance to get this corrected without a fee.
Thanks for showing me this oportunity! I use the GBCI contact page often, but didn't know there was a chance of questioning the final review and even get the appeal fee waived.
My only concern is about the deadlines they are giving for response. We no longer have this kind of time to wait for GBCI's answer. The appeal has to be submitted 25 business days after the final review righ? Is it possible to request an extension for the appeal period? Who should I ask this extension for? GBCI? My review team??
Don't worry about the time. They will extend the dates if you are working on an issue with the review comments. I would mention the deadline in your inquiry about the review comments. However, if you feel it is necessary, you can also request an extension (I've never had one denied) via GBCI - Contact Us. Select Project Review Extension Request from the dropdown. You have to be the Project Team Administrator and Manager to do this. Hope this helps!
Marico - I contacted a GBCI contact on your behalf. She said the information you’ve gotten here is spot on! She said using the Contact Us page is the best route to get this issue resolved. She generously offered to help usher you through this if you would provide me the project number (and I will get it to her) - but she stressed that she would be the middle person and Contact Us would be more direct. I would urge you to just use Contact Us as noted above and get this resolved directly.
I agree with Michelle. If there is truly no incineration showing in your documentation, you should be able to fight this. It is my understanding that reviewers are not supposed to bring up something new on the second round, unless there is really good reason to based on the clarification info provided. That I can't speak to, and I'm not sure how they deal with international language based issues.
However, this sounds more to me like you sent up a red flag for them by saying 100% and from there they were basically looking for the error you must have made because they were skeptical from the start. Please note they could also have initiated a mid-review clarification request on this and didn't. Unfortunate.
Using the contact page can work and you could also try a direct email to the review team assigned to your project if you have a team email on your Team Admin page. With respect to the appeal timeframe and fee, you're right that time is limited after final review. I would include that concern and see what happens. Though I have known them to reverse these kinds of things, I have never known them to refund money that has been handed over. If you don't have any time at all, you may have to consider eating the fee if you need the points.
Michelle Reott and Michelle Rosenberger: I just can't tell how helpful you have been to our case! I already sent a request under "Questions on review comments" in GBCI Contact us page. I informed them about the new information provided in the final review about incineration and my concerns about the deadline. I told them which date the final report was published and what was our deadline. I also informed that the documentation was sent in portuguese and that was no claim at all for incineration as an alternative diversion method. Just to make sure we would be fine, I called GBCI and asked for an extension over the phone, asking them 25 more business days and a confirmation email with the new deadlines, so if anything happens, we can prove we are covered. They already sent the confirmation email, end of March 31st is our new deadline.
M. Reott - the Project ID# is 100002268 Borg Warner Itatiba Master Site. And the final report on a dependent block Project (P10 Entrada Borg Warner Brasil ID#1000022629) was already published and the MRc2 + exemplar performance is showing as denied as well. Thank you so much for your intervention, look forward any feedback!
M. Rosenberger - we haven't handed any money yet, and now we are under the new deadline, as GBCI confirmed to us by email. So we have a little more time to deal with it and get the best solution!
Than you all!!
If I were a reviewer I would question the 100% diversion rate. As a long time contractor, I know there are waste streams that are not economically worthy of segregation. The accumulated debris from daily sweeping that includes sweeping compound, shell casings and plastic strips from powder actuated tools, sawzall blades, sawdust, masonry dust, plastic strips from shim bundles, nuts, bolts, screws, drywall mud, cigarette butts, caulk and adhesive drippings, lunch debris, the dirt that walks in on the shoes of the construction workers, etc., etc. I would be very impressed if this waste stream is separated and diverted from a landfill.
Hi Samuel, thanks for your input. Yes, you are right, there was waste that was not economically feasible to send for recycling, such as styrofoam and gipsum, which don't weight much but have big volume. But even those were sent for recycling, despite the higehr cost. Over the course of the Project the construction company posed as a challenge to itself to achieve 100% diversion goal. That definitely helped them in building a reputation on the local Market. From their perspective, this Project was kind a pilot project as far as waste management.
We are trying to get in touch with the GBCI to get this resolved because the major issue now is that the review team, in the final report, stated that we claimed incineration as an alternate method of diversion, but we never claimed that.
Wanted to tie up a few loose ends on this thread…
Marcio - I did NOT pass your project ID along to USGBC contact because you were already following the correct channels for communication.
Be sure to stress the pilot project nature of your project but I have to say that true 100% diversion would be almost miraculous.
Michelle Rosenberger - Thanks so much for chiming in! I agree with your statement that reviewers are not supposed to bring up anything new in the clarification round - yet I'd like to expand on your "really good reason." Sarah Alexander answered that question on the January 2014 Quarterly Connect. She stated that if during clarifications, new information brings to light new issues or puts previous information into question, then they can bring up something new in their response. Otherwise, if they missed something in the first review, they are only supposed to raise it as an FYI only.
Hi Michelle, I already re-sent the question to GBCI because the first answer we received from them was not conclusive. They only agreed to give us the extension, but made no comments on the main issue.
At this point we are not even worried about the 100% anymore, but we also do not want it to be all or nothing. Was a very hard work to settle for 0% diversion. So we are ok with desconsidering some of the residues and claiming a percentage 95%<100%. But we still believe there is a way to do that without having to pay for an appeal, since we never claimed incineration as a diversion method and that point was never mentioned by the reviewers until the final report.
Regarding your point about bringing up new issues though, in our case, they did not bring up this new issue as a FYI. They brought it up as the reason why the project were not awarded the points. This is questionable, right? We don't want this situation to incur in any unecessary fees to our client.
Marcio (sorry for misspelling your name in some of my earlier posts) - Having not seen your review comments, but based on what you've shared, I would say yes - bringing up incineration seems questionable.
No problem about the misspelling Michelle! Our team appreciate all the inputs. We will keep you folks up to that on that issue so we can all learn.
I'm happy to announce that our request to GBCI under 'contact us' tool had a positive outcome! They asked the review team to double check the analysis of MRc2 and its exemplary performanceIn LEED, certain credits have established thresholds beyond basic credit achievement. Meeting these thresholds can earn additional points through Innovation in Design (ID) or Innovation in Operations (IO) points. As a general rule of thumb, ID credits for exemplary performance are awarded for doubling the credit requirements and/or achieving the next incremental percentage threshold. However, this rule varies on a case by case basis, so check the credit requirements.. The review team apologized for the mistake and granted the 3 points. No need to appeal! The master site final report and the P10 (building) final report were already updated.
I just want to thank you all for your precious insights, we would never be able to achieve that result without your help. Our facility is now LEED Silver, superseeding the original expectations of a basic certification!
Hurrah! Way to end the week on high note!! Con mucho gusto!!
I have one last silly question: since we thought we would have to make an appeal, we had clicked the "enter appeal stage" button on the overview tab in LEED online. And now that no appeal will be necessary, what is the procedure? I can just click the "cancel appeal" button and it will go back to the previous screen that says "proceed to post-certification"?
Marcio - As noted earlier, I don't have experience with appeals but if there is a "cancel appeal" button that seems like the way to go. When in doubt, call GBCI Customer Service for assistance or to ask your question.
Not sure where to post this question but here's our issue: we received the final decision about our multiple buildings Project. We are going to appeal MRc2 which we pursued via master site. However they already made a decision on one of the 4 buildings associated with this master site. And they already denied the MRc2 credit before our appeal process is finished! How does this work? We never made an appeal before, especially for multiple buildings. Does the client have to pay a separate appeal fee for each building + master site even though is the same credit??
Is there a deadline that we have to enter appeal stage after master sites final decision? How many days?
Marcio - Please see my response above. I don’t think this forum can answer your questions on appeals and hope Tristan Roberts or others will chime in. When in doubt, you can also contact USGBC/GBCI Customer Service or use the Contact Us page of GBCI - http://www.gbci.org/org-nav/contact/Contact-Us/Project-Certification-Que....
Marcio, I would do as Michelle suggests and contact GBCI. This seems like a confusing situation for everyone, and for us looking at it from the outside it's especially hard to tell what's going on.
Hi folks. I intended to learn more about "dependent" credits on an appeal stage, how it Works regarding the fees (MRc2 + its exemplar performance, credits pursued via master site). Found the appeal section of the forum, already posted there. Have also sent a question to GBCI. Thanks!
To make room for our new structure, we have some existing metal buildings on our site that will be dismantled and reassembled by others on someone else's property. We can get weights of the materials, but do we need additional documentation on where they are rebuilt and who did the work?
Martin - For LEED documentation, I think having the just the weight and hauler/location is all you need. But for your backup (your own records), you should have more detailed information on the sale (or donation) of the buildings and the location(s) where they are going to be reassembled - in case there are any questions from GBCI.
Also, make sure that these metal buildings are outlined in your CWM Plan and discuss they are going to be dismantled and reassembled elsewhere.
It wants me to select one of the "additional details" but neither seem correct. What is considered "standard submittal" process?
Robyn, the standard submittal path is basically everything that comes before the Additional Details section of the LEED Online form.
You are not required to select the Additional Details if they don't apply—that's why they're "additional"!
Thanks. When I set the form as complete, it is telling me that I may be missing documentation and need to look at the additional detail section, but the only document I was required was the plan. So I was wondering if I misinterpreted the form.
Robyn - Which version of the form (lower right corner) are you using? Some of the earlier forms did have glitches and you have to type some text into the Special Circumstances to get it to show compliance. (I recently had to do this on an EAp1 form. I just typed: "In order to get the form to show compliance, we had to enter something in the Special Circumstances area of the form.")
Do you need to upload any commingled waste documentation? This should be handled in Upload MRc2-2.
The signs need to be in both English and Spanish to be effective in separating the materials.
LEED AP BD+C, ID+C, O+M, Managing Principal
Earthly Ideas LLC
Reused building components that don’t reach the MRc1.1 or MRc1.2 thresholds may be applied to MRc2 as waste diversion.
If onsite material is being reused but is not being counted toward MRc1 or MRc3, it may count toward MRc2.
Do you know which LEED credits have the most LEED Interpretations and addenda, and which have none? The Missing Manual does. Check here first to see where you need to update yourself, and share the link with your team.
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