NC 2009 MRc2: Construction Waste Management

Jiri, I saw your post over on the SSp1 board, so I'll leave that one to the experts over there.

In regards to MRc2, all construction and demolition waste does need to be accounted for in your calculations. You mentioned in your other post that much of the "demolition" was tree clearing, site clearance, etc. Land clearing debris such as these should not be included in MRc2 calculations.

With all of that being said, LEED registration can be a good indicator of when LEED requirements should begin. This is obviously not the case with all credits, but may be applicable to your situation.

Jiri -

Typically a decision to pursue LEED needs to be made during design (or before it begins) so that the construction documents reflect the LEED requirements – especially of the prerequisites. I personally do not agree that LEED Registration is an indicator of when LEED requirements begin because you can register late in the game and that does not mitigate the need to meet the requirements of the prerequisites and credits. There is initial work that needs to be done to ensure that you can earn LEED certification regardless of when you register.

There are quite a lot of pitfalls of starting LEED certification after the design documents are done. For instance, how will the contractor know what the requirements are for materials (i.e., MRc3-7) as well as low-emitting materials (IEQc4.1-4.4)? Unless you were already considering a green project, you will not have commissioning requirements incorporated into construction documents (EAp1). It also can be tricky (or nearly impossible) to earn EAc3. Then there is the need for the design to meet the ASHRAE guidelines for energy (EAp2) and ventilation (IEQp1). These are just a few examples.

If you have not already done so, I would suggest you look closely at all the prerequisites as well as the Minimum Program Requirements to ensure you can meet all of those. I would also suggest studying the LEED Certification Policy Manual - https://www.leedonline.com/irj/go/km/docs/documents/usgbc/leed/config/te... - as well.

You can still achieve a green building without pursuing LEED certification (we did this before LEED existed) but it still requires the documents to reflect the owner’s targets for water and energy efficiency, indoor air quality, and materials selection and vigilance in the field to ensure items are installed and sustainable goals are met. Good luck!

Thank you for your help.
In the perfect world the client would decide to pursue the LEED certificate before the design phase begins. However, a lot of clients want to achieve LEED certification just because of marketing and because of creating incentives for getting bank loans. Therefore they can make the decision during a construction phase.
I agree that LEED registration is not the imaginary starting point of LEED certification. But there should be some precedent about what the LEED certification includes.
For example,
client buys a land where is an old building and immediately demolish the building and carries out land clearing. After a few months (maybe years) he decides to build there a green office building and pursues LEED certification. Why should he include the demolition works into LEED scope if the decision about building the green office building was made after that (maybe even by different project team).

Jiri, you will have a hard time convincing the reviewer that excluding the demolition is ok, because just like excluding certain areas from your project boundary this would be considered gerrymandering. For MR c2 and SS P1 you will have to meet the criteria also for the demolition. Having worked on lots of projects, which made the LEED decision late in the process. I know that this is much harder. We were lucky to have local laws and regulations that covered all the requirements already and a good photo documentation.

As for the demolition work in general, we have had projects in buildings which did demo the space years ago. This had nothing to do with the project at hand and we can't reasonably expect the project to include this. In your case though it's clearly related to the project and also directly prior to the project.
Good luck with your project.

Jiri –

The two cases you presented (your 1/19/12 post vs. your 1/23/12 post) are very different. Susann summed it up well regarding what should have to be counted and not - based on the project start time. Your original case should clearly have to count the demolition as it is part of the current project. In a perfect world, we wouldn’t need LEED but since we’re not there yet, it is best to clearly advise the owner of the hurdles involved in starting LEED late in the game or employ an experienced team member who can.

Tanja, unfortunately for your project burning the construction waste is not consider recycling or reuse. It's therefore treated the same as if you would just dispose it in a landfill. see also Tristan's comment in one of the posts below.

Thanks Susann, I just wonder how this is possible. Where in the EU waste directive says that combustion for district heating is seen as energy recovery.

I'm from Germany and came to the US 4 years ago. I can't speak for the USGBC, but maybe offer some insight in the differences between the two continents. I think the reasoning for that is the actual waste combustion practice here in the US. Even thought there is s "Clean Air Act" limiting air pollution from power plants, it's not even close to regulations in Europe in this regard. Also the efficiency of power plants and district heat plants isn't very good either compared to the EU. Just think of the smoking sidewalk in the movies. That's steam from the district heat plants and unfortunately still a common sighting in the US. This I think is one reason for seeing it different then in the EU.
Another reason is that burning your waste no matter what is still one of the least favorable approaches in regards to carbon emission and environmental impact in the life cycle of a material or product.

Tanja -

As LEED is moving to address more international projects, I would encourage you to post a comment about your situation to the LEED 2012 Third Public Comment Draft, which is supposed to be released in January - http://www.usgbc.org/DisplayPage.aspx?CMSPageID=2360. LEEDuser will most likely have another Guide and Open Forum as well where you could post your concerns instead for this credit.

Susann – Your thoughts on the differences would also be useful for the TAGLEED Technical Advisory Group (TAG): Subcommittees that consist of industry experts who assist in developing credit interpretations and technical improvements to the LEED system. to hear.

Tanja,
It doesn't seem to be that easy. I have signed up as volunteer for the TAGLEED Technical Advisory Group (TAG): Subcommittees that consist of industry experts who assist in developing credit interpretations and technical improvements to the LEED system. especially because there is so little international representation in the TAGs. But that doesn't mean you get to be on one. As for LEED 2012 unfortunately you can only send in one comment per credit per person. Having worked on so many international projects made me have plenty of suggestions and comments, because international projects just have to deal with so many situation not considered by LEED, which are due to cultural, technical and regulatory differences.
You may have seen our new topic about LEED for international projects. http://www.leeduser.com/topic/international-projects-alternative-complia...
User there discuss the short comes and improvement ideas for LEED specifically for international projects.

I can't speak to how USGBC selects members of the TAGs but we will have 3 changes per credit per person to comment on LEED 2012. There have been 2 public drafts already with 2 chances to comment per credit, we now have one more chance - supposedly in January. Even if your part of the credit is not revised and available for comment, I got several replies to comments for the first public draft saying that my comments would be considered by the TAG for future versions. Since the comment process is a public and USGBC facilitated, I feel you have a better chance at being heard by USGBC and having ideas captured for the future.

If you have a spare ID slot, try applying your unique (at least here in the US, burning waste for fuel) circumstances. If the benefits of burning waste gives you more energy (heat &hot water) compared to recycling it, then there goes your green argument. Of course, you have to document that pros out-weight the cons. That will be interesting!

Paola, I would say that if you can divert this waste from the landfill in an environmentally safe manner, more power to you and you should include this in the diverted waste calculations. I would note this in the narrative and fully explain the approach, and in case it's questioned by a reviewer, hopefully you're not relying on that waste portion for a key point.

MIng, you need to document in some way the percentage of waste that is being diverted from the landfill. Diversion for use as "alternate daily cover" or ADC is allowed but you do need to document in some way how much of your waste is going to that. Sorting out and measuring  the wood waste would be one way to help with that.

Does the sorting out and measuring the wood waste have to be done by contractor? Can contractor just get the information from landfill?

As long as it is reliably documented for the project, it is not important who does it.

If the landfill does it, make sure you don't confuse the facility-wide rate vs. the project-specific rate.

Andre, be sure when you Add/Remove Credits, it is for IDc1.1 for Construction and not the Design IDc1.1. That could be why you are having trouble since MRc2 is a Construction credit. The icon to the left of the ID credit number on the Scorecard page should be the hammer. If you have any empty or unused Design ID creidts but they are assigned credits, it could prevent you from adding the Construction ID credit. Also, be certain that the MRc2 LEED Credit Form confirms that you have achieved greater than 95% in the final calculation.

And suddenly there was a point in Innovative in Design. Thanks :)

Michelle, all of your comments are right on as far as I can see. 

I was able to find a company that would grind up the roof on site with a brick grinder, but it was going to cost a fortune. Any other options out their?
Thanks!

SB, my understanding is that recycling this material requires special
grinding equpiment that is not yet in market use. (See the EBN article Better
Choices in Low Slope Roofing.) I think if anyone is going to do it,
it would be the manufacturer, though.

I think that argument number 1 was debunked a long time ago. If you're doing the work, then why can't you get credit for it? As for argument number 2, I'm a little confused. Are you using waste concrete and masonry as clean fill and can't find a fair market value? My v2.2 Reference Guide mentions the use of concrete and masonry fill in the same manner as my v3 Reference Guide. Both state that one should use the open market value but I'll give you that the v2.2 RG is more vague than the v3 RG. Why the change? I think it has to do with encouraging teams to divert as much as they can from landfills while not allowing teams to claim extravagent cost savings for doing it.

Gee, if that arguement was debunked a long time ago, then I must not have been paying attention for a long time. To respond to your question about why not get credit for doing the work, I would have to say that it matters hugely what you are referring to as "the work": In this case, the USGBC awards credit for diverting clean fill from the landfill and, to me, THAT is "the work". In 100% of the construction projects that I've seen up close and personal, I've never known a contractor to pay to send concrete and masonry debris to the landfill (which, for what they weight, would result in a staggering costs to the GC) but, instead, just looks around for the first "CLEAN FILL WANTED" sign. And, in that reality, the GC hasn't taken any action to *divert* anything from the landfill and so why would you want to credit them for incorporating sustainable measures into their practice?

Andrew, to find keywords on LEEDuser, you can use the search function in the upper right, and/or use your browser to search for a specific word(s) on the page.

Regarding your question, I would say that the ease of diverting certain high-weight construction debris is part of why the thresholds for this credit are set so high: as high as 95%. In LEED 2012, it appears that this will get even tougher.

Sorry for the delay. Your original post referred to situations that did exist in the very early days of LEED. There were many contractors out there that would not or did not consider that their 'standard' practice counted and felt that they would have to change something. Debunking happened when they were finally able to realize that diverting waste responsibly was green no matter how long they've been doing it.

Thanks for the heads up on the credit change. There is a lot to consider in LEED 2012. Do you have a link or study name regarding the design changes?

I would think that materials purchased and unused by a project that are returned to the manufacturer instead of being sent to the landfill would contribute to credit achievement.

Jeff, USGBC gives the intent for MRc2 (see credit language above) as diverting materials from landfills or incineration. The point about whether you are being paid for the waste, or paying to dispose of it, is interesting, but I don't think it affects how LEED sees the material: it doesn't meet the credit requirement for diversion in any case.

Beyond MRc2 consideration, if your choices are landfill or incinerate in a modern facility, I would go with the latter.

Tristan, thanks very much and this is what I expected. The issue then becomes how will this be addressed with recyclers, and that is what I am trying to help them with. Recyclers will have to weigh the benefit of processing materials to meet specs for becoming a fuel product for sale, or simply the cost to place it in a landfill.

Tristan, as I read the language further in the Credit Language in the Potential Technologies & Strategies, it makes this statement - 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. Can you please clarify how a fuel product (for sale) would not meet this requirement? My understanding is in LEED 2012 ADC will not be permitted, will this be the same for wood derived fuel? Thanks in advance for clarifying this.

Jeff, you raise a good point that I had forgotten about. I think this reverses my opinion here. The key difference is between an incineration facility which burns everything it takes in, and a recycling facility which sorts waste and directs it to its highest use. It appears that USGBC accepts incineration of material if it goes through such a process.

Thanks Tristan. Personally, I believe there should be some sort of incentive for recycling facilities to send materials to end-use destinations that are not incinerators. It appears the USGBC places the same reward for grinding old carpet up with wood and sending to an incinerator versus baling and sending scrap carpet to Shaw to be manufactured into new carpet. Recyclers operate on cost/benefit, so if grinding is less expensive, then we can imagine where it goes. Thanks again

Due to conflicting opinions found here and having a project that has the ability to benefit (or not) from a local waste-to-energy plant I decided to check the 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 library for clarification. The request to count waste-to-energy as diversion has been made 4 times and denied 4 times. I reviewed rulings from 3/24/2004, 5/25/2008, 6/25/2008, & 5/9/2011. Reasons? There are several given, but a statement from the 6/25/2008 ruling pretty much sums it up: "Energy-from-waste facilities may have virtues compared to landfills, but they are not equivlant to salvage and recycling with regards to the intent and requirements of this credit."

The Certification of Recycling Rates (CORR) under development by the CMRA is a 3rd-party certification of the disposition of C&DConstruction and demolition materials by a reuse or recycling facility. It includes an evaluation of the certified facility and requires detailed documentation of the end-market of materials produced or sold by the certified facility. It requires verification of the type of materials and whether reused, recycled, bio-fuel, ADC or disposal as separate categories.

I think it would be by the standard procedure, quantity and either by weight or volume.

I have a project where the GC's superintendent has taken for his own use the wood pallets for materials delivered to the project site. I am assuming that this action would count as the pallets being salvaged and therefore diverted from the landfill and would help me with my Construction Waste Mangagement calculations, right?

Tim – I think so. The pallets are being diverted. I would suggest getting a letter from the GC stating that he has taken possession of the pallets for his own use as backup – in case there is any question from GBCI.

I recently had a schools (v2007) project where the main school building was seeking LEED certification but the athletic facility was not. Due to site constraints and logistics, it was impossible to set multiple rolloffs for each project. Using the cost of each project, we came up with a percentage for each project and multiplied the weights of each of the recycled and landfilled materials by this percentage to determine the LEED Site vs. non-LEED Site construction waste amounts. In our case, the majority of the waste was from the LEED Site where it seems like your situation is the opposite.

Note: On two co-located LEED-NC v2.0 projects, this strategy was successful as well. There is a LEED-NC v2.2 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 (Ruling dated 8/25/2008 – now listed as ID # 2316 in the LEED Interpretations database) that we referenced as well. It states, “If the project team can devise and document a method that accurately assigns the waste from the two separate projects before combining, then this would be an acceptable compliance path.” According to the Applicable Rating Systems and Tools chart in the LEED Interpretation, this ruling was not yet considered for LEED-NC v2009 – although it has been used for v2009 for Schools, CS, and CI. It might be worth further investigation.

Further clarification - the ACM is considered Category 1 non-friable, if that makes a difference.

Anyone have any thoughts? I am also questioning if the non-friable material WOULD be included in the const waste total, or if I can safely NOT count is as part of the waste total. This could drastically effect our success or failure of this credit and would not be something that could be fixed later.

Answer to the June 10 question: Your non-friable material would not count in your construction waste total and neither would material coated with lead-based paint. They are considered hazardous materials and I have always excluded them from calculations.

Answer to the May 31 question: This is difficult. If the local authorities will allow work in the space around the non-friable ACM, then I would suggest your GC/demolition subcontractor create a work plan to remove as much of the "clean" material as possible without disturbing the ACM and provide an alternate cost proposal. Then upon removal of ACM the amount of "clean" materal contaminated will be less than if they just crushed it together and hauled the now hazardous material to the landfill. Depending on your region and economy this selective demolition may be more or less expensive than ACM abatement.

Recommendations:
In the future some ways to avoid this scenario might be to 1) make the Owner aware and responsible for abatement prior to demolition sequence, and 2) add langauge to Architect's specification, or GC's bid instructions and GC's demolition subcontracts: that either require abatement prior to demo or requires selective demolition prior to removal of ACM or lead-based paint (another material that creates a similar situation).

Note that without these controls, if a project specification or bid instruction/contract were to require the demolition contractor achieve a specific high waste diversion rate (i.e. 75% or 95%) it makes incentive for the demo subs to take all the heavy high dollar value recyclables out and then crush all the clean small/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. material with the ACM or lead-based paint material so their numbers come out near perfect- not meeting the intent of the credit. I have seen this becoming a trend, so make sure there are proper safe-guards so the incentive will be to meet the credit intent.

Hopefully you will find some selective demolition that is within your budget to give you as much recyclable tonnage before it gets contaminated and is no longer required to be counted in LEED.

Good luck!

-Has anyone officially asked for a formal clarification from USGBC on this matter. We have numerous projects where the owner does not have the funding to fully abate a building, just to demolish it.

Well it's definitely being diverted from a landfill :). But seriously I'd still count it. It wouldn't hurt to keep the police reports as backup if they ask for it. I'd just fill in "stolen" for the place/company that it was diverted to.

Jeffrey, I beg to differ with Michelle’s approach for a couple of reasons. First, the project lost control of the material. Secondly, GBCI does not allow “visual estimates” for reporting. Lastly, I would not advise claiming something in LEED documentation that is not an approved compliance path and just hoping you don’t get asked about it. At the very least, you would need to submit 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 for direction on whether it would be approved. You could also proactively approach your reviewer on it.
To solve your theft problem on this project Jeffrey you might consider bins that lock. You might also consider more frequent pickups using smaller bins. Since I don’t know the size of the project, video cams and/or security fencing may or may not be options. Perhaps you could ask the police to drive by as part of their routine to at least discourage theft.

I don't see any harm with doing a pre-step to the 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 - send the question to USGBC, and see what they say! Be clear in your information, the projected REASONABLE recycled amount expected per the Const Waste Plan, the assumed loss due to theft, and the police reports. Inquire if the credit could be achieved via "special circumstance" if you provide the CWM plan, the documentation of what you were able to recycle, ALL the police reports, and a narrative explaining the theft, how you attempted to curtail it once it happened (more frequent pick-ups, request for police drive by, locked dumpsters, etc, and why you believe you think the stolen amt would have allowed you to achieve your required diversion rate. It never hurts to ask. And if they say no, you could always attempt the special circumstance approach anyway (no guarantees).

For MRc2 I have encouraged my vendors removing and re-installing items to determine the weight of their vehicle and trailer by 1) reviewing owner's manuals for weight of vehicle and trailer or 2) running it empty through a truck scale on a nearby interstate, or local transfer station, or place where you buy aggregate or mulch. Then have them run the full truck and trailer through the scales again to determine the amount of the furniture/play equipment. This would be the most accurate way to measure.

Or you could look up product data sheets on the exact or similar furniture and play equipment to get approximate weight.

Also, if the original location of these products is within 500 miles of the new project site, then you can count these materials for MRc5. The $ material value to use for this credit could be either what the replacement cost would have been or what you paid for the materials (removal, storage, installation).

Good luck!

Thanks Jennifer, the truck weighing idea was something I wondered about, but after an internet search, I'm realizing that there aren't any weight stations open in the area any more. Driving an hour one way to get weighed doesn't seem very sustainable. I may have to attempt to gather the data via product data sheets (this will not be fun).

Just to be clear, since it would be diverted and NOT commingled waste, I wouldn't have to have any official statement/receipt from a company to prove my calcs? I could just do due dilligence, calculate to the best of my ability, and call it a day for those items that are salvaged by the client?

I am not clear on the specific requirements for documentation. I have heard others say only 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. loads need to be documented, but this may be for just the new version of LEED Online?

Because, I have had review teams request haul tickets and documentation for every load/product on the old version of LEED Online, I continue to provide haul tickets, salvage tickets, my own spreadsheets for calculating reused products, and monthly facility diversion rate sheets. So far this has not been questioned. Perhaps just have your spreadsheets ready to submit if clarifications are requested?

Glad to see they seem to have been accepting of your calculation spreadsheets. I am going to take that route: do my own calculations in a spreadsheet and submit it as part of my documentation. Thanks!

Renee, since you are submitting your question under v3, I will assume you have a v3 project. That said, I would recommend only uploading the required documentation for MRc2, which is for 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. Waste. Of course it is imperative to have your internal spreadsheets ready to go for the GBCI Reviewer if asked. Our approach to LEED documentation is to submit only, but fully, what is asked for but be prepared to provide verification if that credit is challenged. As a LEED consulting firm, we require the backup of the contractor in the monthly progress reports to verify that the team is on track with the project goals and to be sure the credit requirements and reporting is fully understood.