We recieved the same exact comment on a recent project. Then the comment was followed by several examples of products the reviewer mentioned and all were metal/steel related products. Basically we took it as saying if the product is not 100% recycled content then it is questionable whether or not it can be counted as 100% regional material becuse there will be "virgin" material within the product as well. We took each item mentioned and got manufacturer letters to back up our data/explain the calculations and break out the recycled material with the location extracted and also each virgin material with their location of extraction.

Some manufacturers could not completely back-up their claim, so we used the recycled content percentage as the regional material percentage because they were able to determine the recycled content was either from the plant or a local recycling center that was within the 500 miles of the project.

This was an accepted approach from our review team.

I think they are looking closely at regional material claims now and want more manufacturer's letters over and above the 20% they require to be uploaded.

Thanks for the feedback. I figured it might be related to steel, but I was wondering what this meant for documentation..... as in, are they asking me to go back more steps to trace the raw materials as it relates to where the recycled portion came from? I thought, as a general rule, we only had to go back so many steps as far as a raw material to document.

It's interesting that you say that they want more for back up docs these days...I don't like to hear 'they want more than 20% uploaded." I generally do end up with more than 20%, but at the same time, I do not think that is fair of a reviewer to request if that is not the current rule. USGBC/GBCI needs to make it 30/40/50% or whatever they want so it's a recognized threshold instead of some reviewers asking for more and some not. I hate when it's arbitrarily requested or enforced. Not saying this is happening, but I am sure they can understand our frustrations when rules are changed in the middle of the game- especially when they are not published rules but at the whim of the reviewer on your project.

Agreed on the threshold. Only (1) of our claims actually was changed due to the review comment all others were confirmed through further manufacturer letters. That is what makes me think reviewers want more data uploads than the 20% (or particular product data).

We were not required to trace back the recyled content material.

This same comment came up on a recent review for us as well. Seems a new trend.

Perhaps one solution is to upload all of the steel claims and 20% of the rest. (Not that I'm agreeing with the upscaling of the 20% requirement.)

Hi Jaume,

Take a look at the table above, in the LEEDuser Bird's Eye View for this credit. It specifies that for materials salvaged on site, you can count the site as both the manufacturing and extraction location. And yes, you can count them for both credits.

Thanks for your quick answer.
Your coment refers to "both credits", if one credit is MRC5, which is the other?
Thanks.

Ah, good question! I was thinking the Materials Reuse credit, but I hadn't focused on that clearly enough. Since you're reusing them in the same location/function, these materials don't qualify for that. (My head has been in LEED v4 lately, which handles all this in a more logical way--sorry!)

OK.
Now it is clear.
Thanks

I typed a long response that somehow didn't post...but before I type it again, how many times are projects "questioned" on this issue?

I can think of several legitimate situations where the "recovery" location and "final manufacturing" location would be the same.

Even more difficult is it's rare that scrap steel is collected in a single location. More often scrap is recovered and processed in MANY locations many of which can be within 500 miles of the job. So there won't be a 'single zip code' to enter into the form. In those cases, I have heard project teams will enter the zip code of the mill in the form.

I sincerely wish USGBC and/or GBCI would consult the market before issuing blanket (often vague) guidance......

Keith, I don't think GBCI is disallowing this kind of data entry. It just raises a flag for them and they might ask project teams to verify the information. "Yes, I really meant that, and here's why."

Not saying this is the best possibly approach, but it's routine for questions like this to come up.

Hello, Keith you are correct that sometimes the extraction and manufacture location are the same, however the more common case found in documentation is that the project team does not know the extraction location and re-enters the manufacturing location incorrectly. This is a red flag for reviewers. Thanks for the FAQ addition Tristan!

Bryan, I realize you posted this question on our HC forum and haven't gotten a response yet, but let's keep the conversation over there, because the question is specific to HC credit language.

Benj, the credit requirements are for "travel distance," so it's up to you to to your best to accurately calculate that with the information you have.

Jessica, I would include it. The key point isn't who bought a material, but was it in the project budget and scope, and it sounds here like it is.

It's not part of the project budget (will clarify w/ the GC). I think the GC is only including a installation fee for the carpet. Should we still include?

Jessica, I don't think I'm fully understanding the situation. Does the scope of the NC project involve installing a new carpet and windows? If so, then it seems as though purchase of that carpet is relevant to LEED compliance.

Jaida, your question has been answered by the more recent discussion—see above.

Sara, I would ask the consultant for the source of their information on this. Although there are some gray areas and technicalities around some aspects of this credit and MRc4, there is no clear-cut exception by which recycled content can automatically be called regional.

Note that the point structure in LEED-CI  is a little different than in other rating systems—you can get partial credit for regional manufacture only.

Also, since I have seen you post under the LEED for Homes forum, I will note that if this is about LEED-H, I am less familiar with its requirements.

This question is strictly for a LEED-NC 2009 application. I have a feeling that our consultant is just misinformed. I just wanted to verify that no one knew about 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 that clarifies this question a little more. Thanks for your help, I will ask that our consultant show the source of their information. Until then I will instruct our contractor to request information from the manufacturer about the source of their recycled content.

In all of our recent project reviews, the review teams are now asking for documentation that any scrap metal that was used to make steel/etc. with recycled content was also obtained by the manufacturer within 500 miles of the project per the MRc5 requirements.

Taylor, if you are claiming that recycled steel for MRc5 as well as for MRc4, it seems reasonable to have to provide that documentation, and in keeping with the credit requirements. However, I realize that it may be a shift from what you've seen in previous reviews.

In previous reviews this documentation was not required, and it was approved as 'regional' including the recycled content.

I am clarifying above that 'yes' you have to show that the scrap/recycled content came from within 500 miles of the project site as well as the fabrication/manufacture point of the end-material.

For LEED-H this documentation is not required other than a letter showing Regionality of the end-material, as the requirements are less stringent than LEED NC/CI/Commercial projects.

I am not an expert either, but I would interpret the wording to mean that I need to know the extraction location, the mode of transport to the manufacturer, the manufacturer's location, and the mode of transport to the site. I would calculate the distances as the crow flies, not the actual routes taken, in order to be consistent with the method used in Option 1. Based on the wording "500 mile total", I would add the two distances together after using the weighted formula. If that total is less than 500, then I would count it as a regional material.

Personally, I disagree with how this whole credit is setup/worded (as I explained in my post on this forum on October 31), and I completely understand the confusion with the new option. I don't work for LEED User, but I typically look/ask here for answers to confusing questions like this one. If there doesn't seem to be a satisfactory answer, I would definitely consider filing 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 to get an official ruling.

Zachary: Thanks for your thoughts. I would think that for Option 2 you would have to use the actual route taken by both the product and the raw materials since the requirement reads "within a 500 mile (800 kilometer) total travel distance of the project site." The words "total travel distance" are different than in Option 1 where the word "radius" is used instead. If it was as a crow flies, it would be a radius. That being said, it is very difficult to document this. Seldom is a contract with a supplier or a transport provider written to stipulate the actual route traveled by the raw material to the manufacturing facility or by the product to the job site.

I would agree with you that the total distance traveled would include all the zig-zags.

Has anyone ever received documentation from a supplier or vendor for any of the travel information successfully?

I don't believe this would count toward MRc5. Regional materials must be both exracted and manufactured within the 500 mile radius. In your scenario, the material is extracted within 500 miles, but it is not manufactured within 500 miles, so it cannot be considered a regional material. If you follow the worksheet provided by LEEDUser, you need to enter in the distance between the site and the manufacturer and the distance between the site and the extraction point. Both distances must be less than 500 miles for the material to qualify.

Mark, in my opinion the harvest location for your product would be the location of the forest where the trees came from.

Tristan,

Thanks for posting your reply. It seems to me that it will be very difficult for any woodworking firm in coastal SC to contribute to this credit. Yet we often see specs that are asking for this credit contribution in the Div. 6 specs. Do you have any advice as to how to address this issue during the bid process and/or during project completion?

Mark, my advice would be twofold. One, use the LEED requirements an incentive to seek out local supplies, and to urge your suppliers to work with you. Two, be honest in what you can offer. Many building product suppliers over-promise LEED credits, which may raise expectations that all products should contribute.

Mark, I'll add in an agree to Tristan's comment on LEED being an incentive for you. There are places in your 500 mile radius that do make or supply FSCIndependent, third-party verification that forest products are produced and sold based on a set of criteria for forest management and chain-of-custody controls developed by the Forest Stewardship Council (FSC), an international nonprofit organization. FSC criteria for certifying forests around the world address forest management, legal issues, indigenous rights, labor rights, multiple benefits, and environmental impacts. wood. Because your company work and negotiates with the suppliers, you are a critical link in the market transformation LEED encourages. It is a challenge and an opportunity. As encouragement for your company, virtually all of the SC coast is within 500 miles of the DC area and Atlanta and a lot of Florida. You're positioned well; take advantage of it.

As for Div 6 specifications, as a person who writes specs, the language will be in there to cover the whole spec section and all of the companies specified. You may not be able to contribute MRc5 but your competitor does. A contractor needs to weigh the value of your bid and non LEED contribution are against your competitors bid and MRc5 contribution plus the whole LEED plan. We ask for Action Plans that really are there to get the contractor thinking of how s/he will earn those LEED credits. If you aren't a big player to the MRc5 credit calcs, then you will likely be considered. Conversely if your product is a large component of the MRc5 plan, you won't be considered.

Melissa, I am not aware of any LEED guidance regarding how many "levels" of extraction are tracked for this credit. Except in specific cases (with recycled content), I think the actual extraction location is what is intended, not an intermediary.

I'd like to know what home or revert means too.
Anyways, how about contacting Gerdau about their definition?

For projects that are located more than 500 miles from the mill, consider the recovery/harvested location as the individual scrap collection locations that fall within the project 500 mile radius. Gerdau can provide a regional percentage value based on which of our scrap providers are located within 500 miles of the project. The Regional Material Value can be calculated using the reported regional percentage of the recycle content (recovered/harvested scrap) of the product used. Please contact Gary Peters at gary.peters@gerdau.com or at (813) 207-2353 for project specific information.

Noriko,

Thank you for the reply, and for the Gerdau contact info. I had gone to their website in search of further information. Otherwise, I have a pretty good handle on the regional content, which came from multiple suppliers/mills.

We seem to be meeting our project targets using the mill locations (as permitted per the LEED 2009 addenda). I realize some of the mills can offer futher informaiton on scrap sourcing, but it does not seem that all can.(I think this is one of the considerations taken into account in the addenda).

Thanks again.

Good question! I'm also interested in this, so I'll see what I can find out and get back to you. It's hard to get good data comparing different modes of frieght transport that include both inland waterways and ocean-going vessels, but the little I've seen wouldn't justify such a big differential.

LEED Canada has had a mode of transport differential since it's beginning, but it just has 1x for trucks and 3x for all rail and shipping.

Sorry it took so long, but I was finally able to learn where these multipliers came from. This Alternative Compliance Path originated from the LEED International Working Group, and it's based on data from this report: "Transport at a crossroads. TERM 2008: indicators tracking transport and environment in the European Union." The relevant numbers are on page 12, and they are sourced to this German transportation impacts calculator: EcoTransitIT World.

I spent a little while trying to see how the Transportation at a Crossroads report got to those numbers, but the EcoTransit methodology is pretty complicated, so it wasn't obvious how to verify them. I'm still curious why they're so different from the numbers used in LEED Canada--perhaps someone who has researched this area will help us sort that out eventually.

In my opinion, this may be taking that steel logic a bit too far. The steel logic is not ideal from the perspective of accuracy, but it's argubably necessary given the nature of the steel marketplace.

If the windows have wood components, the component maker should be able to give an extraction location. WIth other components such as glass, aluminium, steel, etc., it may get tricky, but I would push them on this.

Paola,

You're correct. Anything extracted farther than 500 miles won't count. 

Thank you Emily,
It comforts me your the response, it is the same than I think.
The problem it is that some manufacturers claim that their material insulating material it is regional.
Perhaps the right thing most it is not consider these materials for MRc5 and not consider their cars certifications.
thanks again

you will find that some manufacturers include MRc5 as a potential credit that their product can contribute for on their general LEED documentation marketing materials--but fundamentally that contribution always depends on the location of your project, and it's relation to their manufacturing locations and extraction locations.

It is simply the excel sheet format - the cell is uneditable and the amount/text is too long for the cell. I will note in my documentation. It still seems to calculate correctly.

Mike,

For clarification I assume you mean "numerous locations" for recovery of scrap to make new steel? If that's the case, it sounds like 47% of the weight of the materials were sourced/recovered from within a 500 mile radius of the project site. Some steel producers track incoming scrap (i.e - the step just prior to melting the scrap into new semi-finished steel products) by mill and by zip code.

It's possible that any steel fabrication can be made up of steel from several mills, but not typical.

The LEED 2009 addenda includes language whereby you can use the 'scrap recovery' locations or the location of steel mill melt shop.

So ultimately the value you should submit is 47% of the total value of the steel product. In other words, if you have $100,000 of steel delivered to the project from a final manufacturing location which is within 500 miles from the project site, you'd include $47,000 as the regional material value.

I had a similar reviewer question on a recent project. I submitted "Scrap Harvest Location letters" from the mills to show the mill location, steel recycling locations from which the distance to the project site can be calculated via Google Earth. We did get the credit accepted in the final review.

Identifying the mill location is one potential path or (according to the latest addenda) you could identify the scrap processing yards which ultimately delivery the scrap to the mill. We can provide a customer the % of scrap data at the scrap processing yard or the mill.

You should the cost to the project of the components, which in this case would include the fabrication costs by the subs (but, as you say, not the erection labor costs).

As a follow on to this, consider this situation. My steel supplier PO was $250,000. They provide LEED information showing a material cost of $173,000 and a regionally produced value of 47%. Now, the project paid $250,000, so that is what my total material estimate uses. Should I enter the $250,000 or the $173,000 in the regional materials form?

From the information you provided, I would enter 47% of the $250,000. That said, any erection costs, field assembly or other site provided labor should not be included in the $250,000. If all that site related work is invoiced separately it's straight-forward.

Dwayne, first some context: usually projects meet success with MRc5 through big-ticket items like wood, steel, drywall, concrete, etc. I am surprised that a project is in a situation where the regional qualification of a coating, let alone 20% of the coating, is the make-or-break for MRc5. Quite interesting! It also reminds me of EBOM MRc5, where there is a lot of gray area when you get into ingredients of food.

It also brings to mind discussion of whether water should count toward MRc4—see the second or third page of comments on MRc4 for that.

I would think that in this context, it makes sense to count the water as a regional material as you would any other ingredient.

However, to play devil's advocate, the main benefit of using water is to reduce VOC emissions, so it seems like your company will get plenty of recognition for that, no?