Regional materials are those that are extracted, harvested, and manufactured within a certain distance of your project site.
How far, exactly? Historically LEED has used a 500-mile radius to define regional products, but that made it difficult or impossible for coastal or remote regions to pursue this credit. A July 2012 LEED addendum added a more flexible approach, and now MRc5 offers two options to LEED 2009 projects:
The Option 2 credit calculation is much more complicated, and finding the necessary information could be a lot of work. It will be a most effective option for projects that really need to earn the credit, and can ideally focus their calculations on a handful "big ticket" items—see below. However, projects can choose either option on a per-product basis, so they don't need to commit to just one or the other.
Begin researching products early—this will help ensure that there are sufficient regional materials available to specify. If you delay your research, you run the risk that non-regional materials may be specified and purchased before you find a regional alternative. Use the estimated project budget to keep tabs on your performance against the credit threshold.
Many projects fail to earn this credit because they wait until all the materials are purchased before doing the credit calculations.
The 500-mile radius is big enough to cover a lot of ground, but depending on your location, can be tough to work with. Seeing the radius on a map can help quickly assess the product areas where you might have better luck.
If there are enough materials available in your region, this credit can be very easy to achieve. Focusing on a few more expensive items that can be sourced regionally—like structural steel or concrete, for example—may represent enough value to earn the credit. If you combine these big-ticket items with the requirements of other MR credits, you can earn multiple points for a relatively small number of product selections. This strategy has the benefit of reducing the number of items you need to track and document.
Often, product manufacturers will get their materials from a wide variety of sources, making extraction location trickier to determine. It can also be challenging to understand how LEED determines the manufacturing locations for materials that are salvaged onsite or reused, those that contain recycled content, or are part of assemblies. Use the chart below to clarify how you should document the manufacturing and extraction location for these materials.
You can claim recycled content as a regional material, and you don't have to trace it back to its original extraction location. According to the LEED Reference Guide, the extraction point for recycled materials is the location of the raw material prior to the manufacturing of the final building product. That might be the recycling facility, scrapyard, depository, stockpile, or another location where the material was collected and packaged for market purchase before manufacturing. It is not necessary to track the raw material back to its original point of extraction.
For a product with multiple points of manufacture, the point of manufacture should be listed as the location farthest from the site.
LEED is very clear that no MEP or specialty items can be counted in the MR credit calculations. There are several reasons for this, including the fact that MEP items are very expensive relative to their weight, and including these materials skews the calculations and performance thresholds achieved. Also, LEED considers the performance of mechanical equipment paramount, and so consideration of these materials really falls under performance based energy and water credits.
No. See 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. #3901 for additional information.
All steps of the manufacturing process must be within the required distance in order for the product to qualify. If the product meets this requirement, you must list the manufacture location farthest from the project site as the “manufacture distance” for the material.
Option 2, which originated as an Alternative Compliance Path for non-U.S. projects, but which is available to all projects, allows a material to come from a farther distance than 500 miles if it reaches the site by more fuel-efficient modes of transportation (ship and rail).
The two options are available to be used on the basis of an individual product or material, so you can mix and match as needed.
The new equation is embedded in the BD&C Materials and Resource Calculator. The calculator has a spot for materials that comply using the standard 500-mile radius (Option 1), and a spot for those that comply using the weighted average calculation (Option 2). See LEEDuser's Documentation Toolkit tab for a copy of the calculator.
Unless the manufacture location (steel mill, steel coil producer, aluminum extrusion/fabrication facility, etc.) contains a recycling facility, scrap yard, depository, ore mine, or some kind of collection point on-site, it is very unlikely that the manufacture and extraction distances are the same.
Look for unique regional resources to help earn this credit, like this wood flooring salvaged from beetle-killed pine, which would help earn this credit in the Colorado region.Early on, research the availability of materials harvested or extracted and manufactured within 500 miles of the project site. Consider resources such as stone quarries, timber resources, agricultural resources, and manufacturing centers.
The 500-mile radius around a site (Denver shown here), is measured as the crow flies—not the distance that products may actually travel.The 500-mile requirement is measured as a radius around the site “as the crow flies.” In other words, the actual miles and path traveled by the product or material is not as relevant for the calculation.
Begin by creating a baseline materials budget. This is the total amount of money that will be spent on building materials. Use the Materials Calculator from the Documentation Toolkit to compile the baseline material list in a way that facilitates adding information on environmental attributes.
Your material budget assumptions and material costs should be consistent across MRc3, MRc4, MRc5, MRc6, and MRc7. The LEED Online credit form helps ensure this automatically.
Include in your new wood materials baseline budget the material cost (excluding labor) of all new wood items that apply under CSI Master Spec 2004 Format Divisions 3–10, 31.60 Foundations, 32.10 Paving, 32.30 Site Improvements, and 32.90 Planting. Division 12 Furniture is optional. Mechanical, electrical, plumbing and equipment costs are excluded. (See Resources for Master Spec information.)
Adding Division 12 Furniture to your baseline materials budget for this credit is optional, but must be applied consistently across MRc3, MRc4, MRc5, MRc6, and MRc7. Analyze the baseline material budget to see if adding Division 12 furniture works to the project’s advantage. Generally, if the furniture helps contribute to the above MR credits it is in a project’s interest to take credit for it—however, it may help with some while making others more difficult.
Choose one of two options in creating a baseline budget—the default budget, or the actual budget (excluding labor). The default budget method gives you a baseline materials budget as 45% of your total budget, while the actual budget gives you a baseline based on what you actually spend.
A default budget is useful if you don’t want to break out the cost of materials and labor separately. You can take the total cost (material plus labor) of all items in the applicable CSI divisions and assume that cost of materials is 45% and labor cost is 55%.
The default budget is less time-consuming because the contractor does not have to break out the material and labor costs of items that are not being tracked for LEED credits, allowing the project to focus on tracking only the materials that contribute to LEED credits. You can take the total cost (material plus labor) of all items in the applicable CSI divisions and assume that cost of materials is 45% and labor cost is 55%. However, this option may put the project at a disadvantage in terms of getting full credit for the actual value of materials.
You can alternatively use the actual materials budget (excluding labor) of all materials purchased in the applicable CSI categories.
How do you decide whether to use the actual material budget or the default budget as your baseline? The lower you can get the baseline, the easier it is to purchase enough regional material to reach the credit threshold. For example, a project that is renovating an existing building will have low material costs and high labor costs. It might be better for this project to use the actual budget as the 45% default may bring the baseline too high.
How do you know how many regional materials you need to incorporate into your project? Look at the baseline material budget. Determine how much you want to spend on regional materials. Ten percent of the budget cost will give the project one point and 20% will give the project two points. Go through the project’s preliminary budget and identify specific items that are manufactured and harvested/extracted locally. Do these items add up to the amount needed to get one or two points?
Include a cushion for this credit, in case of changes in design and purchasing. For example, if you are counting on points for using 20% regional materials, plan for 30% of your budget to be spent on regional materials to avoid coming up short.
Using the estimated budget to integrate regional materials into the design and specs early on can help prevent costly change orders during construction.
Use your estimated budget as a guide throughout the project. Many projects fail to earn this credit because they wait until all the materials are purchased before doing the credit calculations.
Focus on “big ticket” items when seeking materials to meet regional purchasing requirements. If you can find regional materials like structural steel and concrete, these more expensive materials will go a long way toward meeting the required percentage of your materials budget. This approach allows you to Iimit the overall number of items you need to track and document, reducing contractor headaches. If these big-ticket items do not get you to the threshold you’re trying to meet, target medium-priced items next until you reach your goal.
A single product or material can contribute to multiple credits. For example, a chair made both locally and with recycled materials contributes to MRc5 as well as MRc4. Focusing on products and materials with multiple environmental attributes can also limit the overall number of items that must be tracked.
Product manufacturers may not have extraction information readily available. Allow for time in your process to research this information.
The location of final assembly is considered the “manufacturing location.” Extraction locations are determined by the location from which the raw material was sourced.
Products salvaged on site can count the site as the manufacturing and extraction location.
Look at product cut sheets and manufacturing data to determine whether a product contains regional materials.
When a product is made of multiple materials that are manufactured and extracted in different locations, or only part of the product can count as regional, use these special considerations.
The cost value for the LEED calculation is determined by weight as a percentage of the total. For example, a $100 piece of casework assembled locally contains 20% wood, and 80% marble, by weight, but only the wood was harvested and manufactured locally. Even though the piece of casework was manufactured and assembled locally, only $20 of the casework would contribute to this credit as being both manufactured and harvested locally.
Request that manufacturers provide assembly information broken down by weight.
Follow special considerations for products that are salvaged or reused or have recycled content.
Use the vendor or salvage location in place of the manufacturing location for salvaged, reused, or refurbished materials. Use the location from which the vendor salvaged the material in place of extraction location.
If a material is salvaged onsite and reused again onsite, you can count the site as both the manufacturing and extraction location. For example, parking lot concrete might be ground up and reused as infill on the same site.
Use replacement costs of salvaged materials (rather than actual costs) for all LEED materials calculations. For example, if you received free filing cabinets from a local office rehab you would use the cost of what you might spend on a filing cabinet if you had to replace the free one. This can work to your advantage, since the cost of used cabinets would probably be lower.
The actual budget method can be more time-consuming for the contractor because it requires tracking the actual costs of all materials purchased, even those in the applicable CSI divisions that do not necessarily contribute to LEED credits.
Include in your new wood materials baseline budget the material cost (excluding labor) of all new wood items that apply under CSI MasterFormat Divisions 03–10, 31 (31.60.00 Foundations), and 32 (32.10.00, Paving, 32.30.00 Site Improvements, and 32.90.00 Plantings). Division 12 Furniture is optional as long as it is consistently applied across all credits. Mechanical, electrical, plumbing and equipment costs are excluded. (See Resources for Master Spec information.)
Revisit your baseline materials budget as the design evolves to make sure the numbers remain accurate and that you remain on track to achieve your goal for the credit.
Incorporate regional product requirements into individual construction specifications.
For guidance and sample specification language for incorporating LEED specifications into construction documents, see MasterSpec, or the Whole Building Design Guide. (See Resources.)
Incorporating the LEED requirements directly into the drawings as well as into the specs is a good way to remind the contractor and subcontractors of the requirements.
Analyze the initial cost budget to know what materials the project can target and incorporate LEED requirement language accordingly into construction specs for the specific materials. The contractor will appreciate not having to fill out forms for materials that are not local, or that have so little cost value that it is a waste of time.
Whenever possible, designate in the construction specifications that contractors use specific product manufacturers that you have verified as producers of locally manufactured and extracted items. This will help save research time for the contractors.
Include submittal requirements within each targeted construction spec section and add general requirements to the Division 1 bid package. Include a copy of any submittal documents that the contractor may need to fill out.
Carefully review manufacturer data. Don’t pay attention to vague claims such as “Our product will give you a regional LEED point” when in truth it will only contribute to the credit. No matter what the manufacturer claims, you’ll still need to ask for manufacturing and extraction locations.
The general contractor (GC) should be oriented to all LEED construction-related issues, such as IAQ management, low-emitting materials, environmental materials tracking tools, and construction waste management.
LEED documentation and materials tracking are usually the GC’s responsibility even though specific materials selection may have been already determined by the architect or designer.
The GC should hold an orientation meeting with the subcontractors to review the LEED responsibilities related specifically to their trades. This exercise helps to build trust and is crucial for obtaining buy-in from all participants in the process.
Give the GC and subcontractors the following tools to help them track materials data for all MR and IEQ credits. (See the Documentation Toolkit for access.)
Enabling coordination and communication among the GC, subcontractors and design team early in the process can minimize scheduling delays and pushback from subcontractors.
For any materials not yet specified, research the availability of additional regional materials before construction begins to ensure that the project earns this credit. If product decisions are made after construction begins, there may be less time to review data sheets carefully and much greater risk of using a noncompliant product.
The contractor starts gathering and environmental data and cut sheets from subcontractors for approval.
The GC functions as the overall quality assurance provider for this credit. Responsibilities include conducting weekly reviews of subcontractor product submittals and tracking forms.
Review subcontractor product suggestions ahead of time to avoid the purchase of inappropriate materials and eliminate the need for costly change orders.
Streamline documentation and research by taking data gathered from subs via the Environmental Materials Reporting Form and transfer it into a master spreadsheet for all the items being tracked for each product across MR and IEQ credits. For example, you may need to ask the millworker for regional information for MRc5, certified wood information for MRc7, and information about adhesives installed on site for IEQc4.1. If one spreadsheet collects all the data, it can streamline your documentation, associated research, and help with quality control. Use the Materials Calculator spreadsheet in the Documentation Toolkit.
A master spreadsheet facilitates information collection for subcontractors, giving them a road map of exactly what types of information to collect for each product.
Assign a responsible party to input the subcontractors’ tracking forms into the Materials Calculator (see Documentation Toolkit). A LEED consultant or an administrative assistant in the GC’s office may be the best choice for this role.
Breaking out specific materials costs (excluding labor) for construction materials that contribute to LEED credits is a requirement for LEED MR credits. Some subcontractors prefer not to do this because there are always hidden markups in the materials that subcontractors purchase at wholesale. However, you can simply include the product markup when breaking out a product’s material cost from installation and labor costs.
Even if you use the default budget method for your baseline material budget, you have to break out the actual cost of materials you are tracking for LEED.
Transfer all the data collected in the Materials Calculator spreadsheet (see Documentation Toolkit) to the LEED Online form and upload the product cut sheets.
Only a random 20% sampling of product cut sheets need to be uploaded to LEED Online to document this credit.
Keep a list of sustainable materials used on the project so that operations staff can use these products for future renovations.
Develop regional procurement recommendations and incorporate the recommendations into a purchasing policy. This will contribute to EBOM MRp1: Sustainable Purchasing Policy.
Excerpted from LEED 2009 for New Construction and Major Renovations
To increase demand for building materials and products that are extracted and manufactured within the region, thereby supporting the use of indigenous resources and reducing the environmental impacts resulting from transportation.
Use building materials or products that have been extracted, harvested or recovered, as well as manufactured, within a specified distance of the project site for a minimum of 10% or 20%, based on cost, of the total materials value. If only a fraction of a product or material is extracted, harvested, or recovered and manufactured locally, then only that percentage (by weight) must contribute to the regional value. The minimum percentage regional materials for each point threshold is as follows:
All building materials or products have been extracted, harvested or recovered, as well as manufactured within a 500 mile (800 kilometer) radius of the project site.
Building materials or products shipped by rail or water have been extracted, harvested or recovered, as well as manufactured within a 500 mile (800 kilometer) total travel distance of the project site using a weighted average determined through the following formula:
(Distance by rail/3) + (Distance by inland waterway/2) + (Distance by sea/15) + (Distance by all other means) ≤ 500 miles [800 kilometers]
Mechanical, electrical and plumbing components, and specialty items such as elevators and equipment cannot be included in all calculations. Include only materials permanently installed in the project. Furniture may be included if it is included consistently in MR Credit 3: Materials Reuse through MR Credit 7: Certified WoodWood from a source that has been determined, through a certification process, to meet stated ecological and other criteria. There are numerous forest certification programs in general use based on several standards, but only the Forest Stewardship Council's standards, which include requirements that the wood be tracked through its chain-of-custody, can be used to qualify wood for a point in the LEED Rating System..
Establish a project goal for locally sourced materials, and identify materials and material suppliers that can achieve this goal. During construction, ensure that the specified local materials are installed, and quantify the total percentage of local materials installed. Consider a range of environmental, economic and performance attributes when selecting products and materials.
This free online tool allows you to draw a 500-mile radius around a point on a map, which can help visualize the Regional Materials boundaries for your project location, and help you look for sources within those boundaries.
PlanetReuse is a nationwide reclaimed construction material broker and consultant company. At no cost to the design team, they match materials with designers, builders and owners to serve LEED efforts, save money, and sustain the planet. 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 clients through every step of the process.
Architectural Computer Services, Inc. (ARCOM) offers a free downloadable PDF of the Master Spec divisions. Check this to verify which materials are included in this and other MR credits.
This book and CD-ROM from Master Spec offers useful guidance and sample specification language for incorporating LEED specifications into construction documents. (Requires purchase.)
Support on incorporating LEED requirements into specifications.
Many products contain materials with different extraction or harvest locations. Use this spreadsheet to determine how much of the assembly you can count toward the Regional Materials credit. Includes sample calculation.
Teams can use this tool to track all materials across various MR and IEQ credits. It helps teams develop a roadmap of what information needs to be tracked for different products. It can also be used early on to create the baseline budget and ensure the products that are being used will apply to the various credit thresholds.
This is a materials tracking form that helps subcontractors record the environmental values of products they purchase. This can be distributed to each trade subcontractor and submitted to the GC for filing.
Manufacturers often highlight regional manufacturing and extraction information in cut sheets and letters, as shown here. In some cases information may be misleading or incomplete, and you'll need to follow up (see annotations on the PDF).
Use a letter like this sample to orient the contractor to their responsibilities for all MR and IEQ credits. This letter is an introduction that can be customized for the credits your project is pursuing.
This is a VOC tracking sheet that helps subcontractors record the low-emitting qualities of the products they purchase and can be distributed to each trade subcontractor and submitted to the GC for filing. Use it specifically for earning low-emitting materials credits, but in conjunction with documentation for MR credits.
Use this form to track your concrete mixes and their recycled content and distance to the manufacturing and extraction sites.
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."
Documentation for this credit is part of the Construction Phase submittal.
Hi all, I am spinning my wheels second guessing what is now accepted. If a manufacturer provides a letter stating 100% of the steel used has been manufactured and extracted within 500 miles from my project site, but does NOT include specific locations for extraction, can we count this material and upload their letter as supporting documentation?
Sara, I have been successful submitting this type of documentation not only for steel but for other materials as well. My only caveat for the steel is that you be careful with the wording. This type of claim from the steel manufacturer's typically refer only to the recovered/scrap steel and not the virgin material. For that reason, you would be essentially claiming the recycled content percentage as the regional percentage. See the discourse between myself and Kristina Bach one comment down. I hope this helps.
We have steel on a project that is documented to be 99% recycled content, all recovered within 500 miles of the project site. GBCI rejected this claim stating that since we did not know where the 1% of bauxite and iron ore were mined we cannot claim it. Is this for real?
Did you claim that the steel was 99% regional (and not 100%)? Otherwise I don't see why the GBCI asked for the 1% iron ore extraction point... For the projects we worked on, we never had problems claiming recycled steel as regional providing that the steel scrap is recovered and processed within 500 miles of the project site
Chris, my assumption is that they rejected it because you claimed 100% as the regional material percentage when you should have claimed 99%. Does this sound plausible?
This also leads to a question I have regarding the calculation of the regional value of steel. Lately, I have seen project specific letters from steel mills which state what percentage of their scrap steel is regional. For instance: "90% of the recovered/scrap steel was harvested within 500 miles of your project site." I think these letters are great, I am just wondering how to claim the regional percentage in these cases.
For instance with a steel product that contains 85% recycled content (70 post-consumerWaste generated by end users (households or commercial, industrial and institutional facilities) of a product no longer able to be used for its intended purpose that is recycled into raw material for a new product. and 15 pre-consumer). If I receive a letter with the above language from the mill, am I claiming 90% as my RM value or 76% (85% x 90%)?
In the past, when we've pushed back on manufacturers to describe that sort of a statement (90% of recovered/scrap is regional..."), they've always come back saying that they are only willing to report/track the recycled/salvaged material and not the raw materials, simply due to the fact that the percentage of raw materials is so low for most steel products that it's not cost-effective for them to track on a per-product basis.
So in instances like your example, we'd claim an overall regional material for the product of 76.50% (85.00% recycled/recovered x 90.00% regional recovered). We haven't had that be rejected in a review, however, we have heard of projects getting products rejected when they claim the 90% regional if the letter only actually speaks to the locations of the scrap.
Hope that helps!
Thanks so much for sharing your experience, Kristina. It helps a lot. I agree with the method you use to derive the regional percentage since the manufacturer's language speaks only to the recovered steel, and this is how I typically document it. Thus far, however, I have not received an official review on this type of documentation. Sometimes other members of the project team question this calculation and so it's good to know of others having success documenting it this way.
Thanks so much for the responses all. We have resubmitted using only the recycled percentages of all of the materials on the LEED Materials Calculator as regional materials, ignoring the raw materials. It still gives us in excess of 50% regional materials for the project. I will let you know how the GBCI responds. Thanks again.
I would like to know if there is some stardard template to compile the information regarding materials and resorces or even the rest of credit categories.
LEEDuser members can access the “Documentation Toolkit” tab at the top of this page. There, LEEDuser offers several forms. Among them is an “Environmental Materials Reporting Form,” a single-page PDF of “a materials tracking form that helps subcontractors record the environmental values of products they purchase” and that “can be distributed to each trade subcontractor and submitted to the GC for filing.” This form appears to be set up to track MRc3, MRc4, MRc5, MRc6, MRc7, & IEQc4.4. Since credit goals vary from project to project, the form may not match your project’s reporting needs exactly. However, the form might make a useful template upon which to develop your own, project-specific form.
Thank you Jon
Incidentally, although LEEDuser’s “Environmental Materials Reporting Form” makes a useful template, I have noticed a shortcoming to the MRc5 fields on the form. The form provides cells in which to enter the product name, the manufacturer, the cost, and the locations of and distances to harvest & manufacture sites, but it lacks cells for the “Regional Percentage,” which is a required entry in the LEED-Online MR Calculator Spreadsheet. Additionally, project’s using MRc5 Option 2 would need to adapt the form to account for modes of transportation.
in every LEED Project we do struggle in obtaining the material costs as many companies refuse to split their invoices in those for material and those for labour.
Question is whether the assumption of 45% default material cost in the total invoice of a contractor would be compliant with credits´ requirements.
Doreen – You can only use the “45% default” to calculate the “Default Total Material Cost” for use in the denominator of the MR Credit Calculations.
To calculate the credit contribution of an individual product or material, you must use the “actual material cost” of that material, which includes “all expenses to deliver the material to the project site” and “all taxes and transportation costs incurred by the contractor,” excluding “any cost for labor and equipment once the material has been delivered to the site.”
To reduce the struggle, make this kind of cost reporting a contractual requirement. If their contracts REQUIRE them to split out material costs on Applications for Payment, Payment Certificates, and other pay schedules, contractors MUST do so as a condition for payment.
Work with your Construction Manager to obtain the required information.
Within my LEED boundary are two buildings, One is a LEED building, the other is not .... these buildings are as follows:
a) An electrical Building ( A substation within the electrical building) - NON LEED Building
b) A commercial building - LEED Building
Now, my commercial building is a LEED building - My question to you is ..
Do I have to take into account or calculate all the regional materials that went into the electrical building (Non leed building) given that it falls within the LEED boundary ......???
As Kimberly noted in response to the PIf2 post (https://www.leeduser.com/credit/NC-2009/PIf2#comment-51027), “If the service buildings are in your LEED boundary, you do need to include the materials for constructing them in your MR calcs - just like it's an extension of your main building.”
If the electrical building is being built as part of your LEED project, you must include it in MR credit tallies, including MRc5 regional materials. You must include all energy loads, costs, materials, and activities within the LEED boundary consistently for all credits & prerequisites.
See LEED 2009 Minimum Project Requirements (MPR), particularly MPR3, to determine the appropriate LEED project boundary. See page 26 of the MPR Supplemental Guidance for specific instructions concerning Non-LEED-Certifiable Buildings within the LEED project boundary:
There is two methods of transport for the Cement I use for concrete in my project; It is coming by water to the port from an approximate distance of 2100 Km and then shipped by truck for 148 km to the concrete manufacture then to the project for another 25 km.
Can I Count the Cement as regional material for this case?
Your feedback is appreciated.
Which rating system are you using?
In the meantime you can use the LEED Reference Guide for Green Building Design and Construction with Global ACPs (Alternative Compliance Path) located here: http://www.usgbc.org/resources/leed-reference-guide-green-building-desig...
There is a formula which you can use to calculate the regional distance based on the mode of transport. Hope this helps.
The Global Compliance paths
Rezkar – The MRc5 Global Alternative Compliance Path that Amit cited has officially been incorporated into LEED-2009.
An Addendum issued in July 2012 added compliance OPTION 2. As noted in the “Birds-Eye View” at the top of this webpage, “This new option allows you to do a prorated calculation based on the lower relative impact of shipping materials by rail or water.” This option allows you to divide the distance shipped by sea by 15. Therefore, since
(2100km/15) + 148km + 25km = 313km < 800km (500mi),
you should be able to treat the cement as “regional” if it was shipped by sea.
For current LEED-2009-BD+C Addenda, follow this link:
Thanks for your Feedback. I am using LEED NC 2009, CAGBC. Is this calculation acceptable under Canadian LEED too?
I believe that LEED Canada has always had a distance calculation of its own that is similar but a bit different in the specifics—I would use that.
Rezkar - Just remember that, if you use the options that Amit & I sent, distances shipped by sea calculate differently than those by inland waterway. The calculation shown above assumes sea travel. If your cement travels 2100km via rivers & canals, rather than by sea, you may be out of luck.
Just curious…Does CAGBC treat the Great Lakes as seas or inland waterways?
I got a question today that I wasn’t sure of the answer of: Paint contains a large part of water. If the paint was manufactured regionally and the water was extracted where the product was manufactured, can we count the water fraction of the paint toward MRc5? To me it seems that water is not really a product, but on the other hand if we didn’t take the water from the manufacturing point, it would have to be transported, which is what this credit is all about. Thoughts?
This same question came up in the comment string below started by Dianne on March 24. In that string, the general conclusion was that water could count.
Here’s my reasoning:
1. In the MRc5 chapter of the LEED 2009 BD+C Reference Guide, Table 2 shows a “Sample Assembly Percentage Regionally Extracted Calculation for Concrete” that clearly includes water as a regionally extracted component. Therefore, water can count as a regional material, at least in concrete.
2. If water added to a product during manufacture is still there when it is delivered to the jobsite, it should be a part of MR calculations. Therefore, the water in paint should count.
3. If water used during manufacture has evaporated or been removed before the product is sent to the jobsite, it should NOT be a part of MR calculations. For example, most of the water used to make clay for ceramic tile burns off in the kiln, so it should not count.
4. Sometimes, water reacts chemically with other ingredients to become something else, changing state rather than evaporating. For example, in precast concrete or CMU, much of the hydrogen & oxygen from the water used in the “wet” concrete remains even after the concrete has “dried” or cured. In such cases, include the water that remains in the MR calculation.
In practice, it may not matter whether you count the water in paint as “Regional.” Since MRc5 is weighted by cost, and the amount spent on paint is often tiny compared to other major building components, the percentage gained from paint may be minute.
However, if you are teetering on the edge of a Credit threshold, every little bit might help.
Hi Jon and thank you so much!
I had missed that the discussion below had evolved into including water. I agree with your reasoning. But the thing that really makes me more certain that it would be ok is that they have included it in the table in the Reference guide.
consider this: in concrete the water is chemicaly binded and is "permanently installed" in the project as part of cocnrete. Water in paint is a solvent, which mostly evaporates from the final product that is applied on site, therefore, it is not "permanently installed".
See comments of Keith Lindemulder in the discussion bellow from April 03-04 2014.
Andrey—As far as I know, USGBC has not issued an official interpretation answering this question. Therefore, our musings on LEEDuser are just that—inconclusive.
Keith L. and several others offered various opinions during the discussion started by Dianne C. on March 24. You may have missed Keith’s most compelling point. His April 4 post (http://www.leeduser.com/comment/redirect/49122) notes that the biggest MR Credit contributions usually come from expensive structural elements. Paint’s value to a project is typically slight. Even if you include regional water content, coatings can contribute little appreciable MRc5 value to an overall project. Therefore, the answer to this question may be that it does not make much difference.
Sometimes, LEED Project Teams go overboard in their effort to gather “complete” documentation. When they require manufacturers to submit detailed regional extraction percentages for EVERY SINGLE PRODUCT used on their projects, they impose unnecessary burdens on manufacturers, on contractors, and, ultimately, on themselves. Experienced LEED teams soon discover that they can achieve their credit goals and reduce paperwork simply by focusing first on “Big-Ticket” products with greatest potential MR credit impact. Teams that use this strategy can avoid dwelling on minutia and focus their attention toward documentation that is TRULY critical to this and other LEED credits.
Streamlining MR documentation will become even more critical as we go forward. LEEDv4 adds new, more relevant reporting requirements, but combines the current MRc3-7 requirements into a single credit point. We will have to be smarter about what documentation we choose to gather.
Less is more.
Jon, sure I've read this comment, since we are at NC forum, the idea not to overcomplicate smth that could be achieved with much less effort is understandable, and you are totally right. But for CI consideration of water in high price paint can be very vital. Or even for NC - in Sweden, as I've heard, becomes common to build 5-7 or more floors wood buildings, so a lot of antiperenes, coatings, paints and so on can be reasonable part of material budget (specially for CS).
You are right. A project team might analyze its budget and determine that expenditures on paint (or some other water-bearing product) represent a significant percentage of overall construction costs—enough to affect MR credit achievement and enough to warrant researching extraction points for product ingredients. Please consider:
The intent of MRc5 is to reduce the environmental impact of transport. The volume, mass, and weight of the water in paint significantly increase this impact. The suggestion is that we should exclude paint’s water content because it evaporates after application. Chemical solvents and VOCsA volatile organic compounds (VOCs) is a carbon compound that vaporizes (becomes a gas) at normal room temperatures. VOCs contribute to air pollution directly and through atmospheric photochemical reactions (excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides and carbonates, and ammonium carbonate) to produce secondary air pollutants, principally ozone and peroxyacetyl nitrate. in paints also evaporate or dissipate after application. Should we exclude them too?
The term “Permanently Installed” has been taken out of context. It was never meant to exclude ingredients that evaporate after installation. This term simply distinguishes “Base Building” from “Furnishings” and from “Temporary Construction.” (See LI#10294 http://www.usgbc.org/leed-interpretations?keys=10294.)
The simplest rationale is to evaluate equally all ingredients present when the product arrives at the jobsite. Do not treat water any differently.
As I suggested above, one might be able to justify excluding the water and other solvents in shop-applied coatings and treatments (such as antiperenes). That water dissipates BEFORE shipment, reducing the environmental affect of its transport. Likewise, one could omit the water used to produce ceramics and similar product because that water is not part of the finished product delivered to the jobsite. However, I have never had need to attempt these justifications with LEED review teams.
Regarding regional materials do distributors facilities need to be counted within the 500 miles radius?. Here in Chile, many rebars manufacturers have authorized distributors that may be or may be not have their supply facilities located within the required distance to the job site. This distribution centers should be counted as the final regional point before the product being delivered to the project site?.
Thanks so much in advance.
For MRc5, only the percentage of a product that has been extracted, harvested, recovered, & manufactured within the required distance qualifies as “Regional”.
The Manufacturing Location is the point of final assembly. For rebar, manufacture would include fabricators that cut, bend, bend, galvanize, epoxy-coat, or otherwise modify the bar before shipping it to the construction site. However, if the “distributor” is simply a warehouse or supply facility that holds or ships the product without modifying it, you cannot count this as the “manufacturer”.
The intent of MRc5 is to reduce the impact of transporting materials long distances. Therefore, materials that pass through a distributor beyond the 500-mile (800-km) radius may not qualify as “Regional.”
On the other hand, considering Chile’s geography, it is likely that many building products travel by sea or rail. An Addendum issued in July 2012 added compliance OPTION 2. As noted in the “Birds-Eye View” at the top of this webpage, “This new option allows you to do a prorated calculation based on the lower relative impact of shipping materials by rail or water.” To use this option, you may be required to provide additional shipping documentation.
I´m studying for the AP test and have a question.
If I´m working on a major renovation project and reuse the bricks from a fireplace to create a sidewalk, can I account this as material reuse AND Regional material?
I remember reading somewhere that for regional material you can only count materials acquired off-site, but taking online exames this question came up and got me really confused about it.
Appreciate any help. Thanks
Henrique, see our guide to which credits you can double-count under MRc3.
Thanks Tristan. I´ll take a look
The Reference Guide states "materials costs should account for all taxes and transportation costs incurred by the contractor but exclude any cost for labor and equipment once the material has been delivered to the site."
The statement doesn't exactly state that you should include labor during the manufacture of the material. But we do include that cost in our materials costs correct?
In addition our projects are all based in Sweden therefore we don't use CSI divisions. We use something called AMA that can be viewed as an equivalent. But on review of these divisons to make sure we are covering everything in our materials total cost. I see that CSI division 03-10 should be included in the materials cost.
Why do we include CSI Division 10 00 00 Specialties? Some of the sections seem to be more of a furniture/furnishing use ?
Include all costs incurred prior to delivery on-site. This is the top-tier cost billed for the finished product before installation on-site.
The cost should include all labor and materials required to fabricate assemblies off-site. Such assemblies often comprise many components and sub-components that have been manufactured or extracted elsewhere. To determine the regional percentages of an assembly, use the method shown in MRc5 Table 2 of the Reference Guide.
Do include CSI Division 10 Specialties in your Materials & Resources calculation.
I agree. The distinction between Division 10 Specialties and Division 12 Furnishings can be hard to discern. In general, Division 10 includes prefabricated units that are permanently installed in fixed locations as part of the base building. Most Division 12 Furnishings are moveable or decorative items that are often added as part of fit-out after the base building has been completed.
If you choose to do so, LEED lets you include Division 12 in all MR calculations, but Division 10 is mandatory.
I hope that this helps.
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. LI# 10294 explains the distinction between "Furniture" and "Permanently Installed Building Products". This interpretation comes very close to my explanation above.
Another LEED Interpretation, LI# 10287, advises Project Teams using Specification formats other than CSI-MasterFormat-2004 to verify that the Spec divisions used for LEED correlate to those in MasterFormat-2004.
Both these Interpretations are dated October 1, 2013.
Compare your Spec format side-by-side to MasterFormat to ensure that you include the appropriate material in MR Credits 3-7. You should probably include that comparison in "Special Circumstances" narratives in the LEED-Online MR Credit forms.
We manufacture coating and adhesive products. Determining the point of extraction/harvest of our raw materials is becoming more and more difficult to "trace".
We may use anywhere from 10-20 raw materials in a specific formulation. Then, some of the raw mateirals we purchase may contain 10+ ingredients or raw materials in "that" product.
For an example, I'll use the following:
RM 1: Acrylic Emulsion
We may purchase" this emulsion from a company who "manufacturers" the acrylic emulsion in Chicago - but we have no idea where "their" raw materials are actually "extracted" from (that are used to manufacture the acrylic emulsion).
Do we report the "extraction/harvest" location as "Chicago" - or do we need to break THEIR product down into each of "their" raw material "extraction locations"?
Thanks in advance for any help with this one...
Based on my interpretation as a manufacturer, it is impossible to document extraction location for any raw materials derived from virgin petroleum.
They are excluded from my reporting.
Does water count as regionally raw material?
Lilian, I would be doubtful. What product is the water a part of?
Tristan and Lilian,
This is something we (as a manufacturer) have wondered about for a few years now. After review/comparison of the older USGBC CIRs (Credit Interpretation Rulings), Credit Addenda and the Credit Interpretation Database, we decided that water "could" contribute as a Regional Materlal; when "water" is added as a raw material to the product at the time it is manufactured; IF the actual manufacturing facility IS less than or = to 500 miles from the project/jobsite location.
For example, on the "sealersSealers are coatings applied to either block materials from penetrating into or leaching out of a substrate, to prevent subsequent coatings from being absorbed by the substrate, or to prevent harm to subsequent coatings by materials in the substrate." we manufacture, water may be added at our manufacturing facility in the amount of 47.0% (by weight) - to a product we manufacture. The remainder of the formula may be comprised of inert fillers, acrylic/urethane emulsions, surfactants, defoamers, etc.
The water that IS "counted" as a Regional Matieral is only the water that is added at "our" manufacturing facility, and does not include water that is "already contained" in any of the other raw materials in the formulation; such as water in the acrylic emulsions, urethane emulsions, surfactants, defoamers, etc.; that we purchase from other manufacturers/locations, etc.
NOTE: UNLESS their manufacturing locations ALSO just happen to be less than or equal to 500 miles from the project/jobsite location; in those cases, this "water" would also contribute.
Sorry for the "dissertation" - Just trying to provide a full explanation of how we arrived at our decision to "count" our local water AS a Regional Material. Feel free to contact me if you have any questions, or need any further clarification.
We have been successful counting water as part of concrete mixes on multiple projects. I tend to agree with Dianne's assessment in that if water is part of the raw material mix included in the last point of manufacture prior to the product getting to the job site, it counts - as long as it's an assembly product that you're breaking down into component parts.
Regarding how far back to go in the supply chain, I usually use changes of state/composition as my measuring stick. If a raw material(s) A is combined to create new product B that then goes into the final product C, I use the manufacturing location of product B. If, however, a major raw material such as steel is carried through the supply chain without combining with something else to become something new, I would count the original point of extraction. This has been successful on our LEED projects in terms of review comments, but I'd be interested in hearing other people's experiences as well.
The credit documents products which are "permanently installed" on a project. While I would initially agree with the "change of state" analogy, I would argue that water itself in a concrete mixture is neither 1) permanently installed nor has it 2) changed state in that concrete mixture. It's more of a catalyst to cause the mixture to harden to a certain specification.
Likewise, solvents or added water in products like coatings and paints are similar in that they ultimate evaporate or other wise aren't "installed" on the project.
If ingredients like added water are to be potentially considered "regional" then where is the incentive to REDUCE the amount of water used in the manufacturing process?
Stella, I'm surprise that you've had that success, but if that's how the review comments have been going, I guess that's the word.
To me I would ask whether including water is an incentive or disincentive to reduce environmental burden, and I would be quite surprised if counting water toward MRc5 influenced a project's choice of where they are getting their water.
It's still problematic to me for reasons given by Keith, but I would feel better about a credit like MRc4 being sought for water, if you are reusing wastewater to reduce demand for potable waterPotable water meets or exceeds EPA's drinking water quality standards and is approved for human consumption by the state or local authorities having jurisdiction; it may be supplied from wells or municipal water systems., for example.
Stella, Thank you for your comments-very much appreciated !!!
Tristan and Keith - thank you as well. You BOTH have brought up excellent points; regarding adding "regional water" to a product or formulation -- as actually INCREASING the environmental burden !!
Looking at the credit(s) in that way, had not even occured to me !!
(As a R & D Chemist, I sometimes (ok, ALL the time) get WAY too "caught-up" in documenting and reporting "the data", and unfortunately don't always see (or lose sight of) the "big picture".
Based on your comments, do you feel that for products such as coatings, sealersSealers are coatings applied to either block materials from penetrating into or leaching out of a substrate, to prevent subsequent coatings from being absorbed by the substrate, or to prevent harm to subsequent coatings by materials in the substrate., waterproofing sealers, adhesives, bonding agents, caulks, etc.... that the actual "carrier-solvent" for these product (could be water or a petroleum-based, etc. "sovlent") should NOT be "counted" --- as in "theory" -- these "carrier-solvents" will eventually evaporate from the product - once it is applied "in" the structure ??
As a product manufacturer, the Regional Material Credits have always been the most difficult for us to interpret, report and maintain databases for - as often times, one "product" may contain 20+ "raw materials/components".
In addition, we often make the same formulation/product at 10 or more of our company's multiple manufacturing locations/facilities. This then requires us to collect/record/maintain raw material/component composition "information" separately; due to the presence of "regional" raw material suppliers, etc.
Once again, thank you ALL for your input - it has been extremely informative and helpful !!!
I completely understand doing what you can to provide as much LEED value as possible to a project. I also understand that your products most likely apply to the IEQ credits so you're already providing significant documentation to a project team.
Another consideration is that the value contributed to this credit is based on mass of the installed product. To be technically accurate (as I read the credit language) the mass of the installed product would be whatever's left after any water or other solvent evaporates. In the scope of a building project, your products would have to be incredibly expensive to provide appreciable value to the project. Even if you use the full weight and price of the product it's not going to make a big difference ultimately.
That said if you can make it so simple (I.e. - "automatic") for a project team to add the entry for your products I suspect the effort to sort all this out is petty much in vain. Generally the larger structural products make or break this credit on most new construction projects.
There may be more value than see (commercial interiors?) and I certainly don't want to sound negative but my advice would be to spend your efforts on the more difficult task of getting solid documentation together for LEED v4 projects.
Keith - Thank you for taking the time to further help clarify all of this for me - it is very much appreciated !!!
No problem. I hope I didn't come off sounding like I'm discouraging you from working something out for your customer. But at some point it's about defining the value vs the cost. It's great that you're thinking the way you are and I hope you can find a simple, effective way to make it happen.
Not to worry Keith, I didn't take it as "discouraging" at ALL. This is something that I have "struggled with" for quite a while now. With the resources we have, how do we PROPERLY implement and maintain the necessary databases (for all of our products) for the various Green Rating Systems/Requirements; to be able to provide our customers with the data/information they are requesting ... (??) Definately not an easy task; without dedicated personnel, resources, etc. Thank you again !!
It’s great to hear manufacturers’ materials scientists putting so much thought into the documentation of raw material sources. Those of us in the trenches need your expertise to learn more about the materials we specify and track for LEED. This discussion sheds light on what it takes for manufacturers to come up with the data we demand.
1. In the MRc5 chapter of the LEED 2009 BD+C Reference Guide, Table 2 shows a “Sample Assembly Percentage Regionally Extracted Calculation for Concrete” that clearly includes water as a regionally extracted component. Therefore, water can count as a regional material, at least in concrete.
2. Whether or not the water in a product evaporates should be irrelevant. If water is in the product when it is manufactured, delivered, and installed, it should be a part of MR calculations.
3. MRc5 contributions are weighted by cost. When we build, we spend oodles on concrete, steel, and other major building components. By comparison, coatings & adhesives are a drop in the bucket. When adjusted by cost, whether a sealant is 47% regional or 0% may make a difference of less than 1/1000 % to the overall MRc5 tally.
I applaud your dedication and thoroughness, but we rarely choose coatings or adhesives based on its MRc5 contribution. Under LEEDv4, Environmental Product Declarations, Life Cycle Assessments, & other new forms of disclosure will provide new, more meaningful opportunities to evaluate the environmental impacts of material composition.
Are steel coils counted as recovered for this credit? I have several products where steel coils are used. Does this count?
Jennifer, a little more info would be helpful. Steel is recognized by LEED to having an default recyceled content of 25%. Documentation is genrally available for domestically produced steel (North American) usually is substaintially better than the 25% default.
"Steel Coils" are not generally a "job site ready" product and are usually made into something specific for the job. Are you ultimately trying to document steel studs/track for framing (walls, floors, roof systems), or something else?
I am working a LEED NC 2009 & Retail CI historic building MRc5. Apparently DIVISION 12 – FURNISHINGS include: ART, Murals and more specifically Ceramic Tile Murals etc....The my question is are all the items listed in "MasterFormat™ 2004 Edition – Numbers & Titles" DIVISION 12 section to be included in the MRc5 calculation? Would preserved historic protected decorative wall elements of the facade and internal walls (fresques) be included in this calculation as reused or salvaged on site elements? If so what $ value would be given to these elements?
Ian – Artwork cannot be included in Credit Calculations for MRc3 through MRc7.
A LEED-NC Addendum dated May 9, 2011, excludes artwork from MR calculations. Reference Guide Correction #100000953 added a sentence to Page 337 of LEED-BD+C, 1st Edition. The passage now reads, “A project team may include materials costs from Construction Specification Institute MasterFormat™ Division 12—Furniture and Furnishings as long as this is done consistently across all MR credits. EXCLUDE ARTWORK, INTERIOR PLANTS, AND MUSICAL INSTRUMENTS.”
However, the items you refer to may fall under MRc1.2.
On the other hand, new materials used to preserve or restore existing elements should be included in Credit Calculations for MRc3 through MRc7. These may include products for restoration & preservation of the following materials:
Division 4 – Masonry & Stone
Division 5 – Decorative Metals
Division 6 – Carpentry & Woodwork
Division 7 – Roofing & Sheet Metal
Division 8 – Windows & Doors
Division 9 – Plaster, Tile, Flooring, Paint, & Finishes
When using MRc5 Option 2 approach --> should we be using the direct distance between two locations? Or the nautical miles between two locations? Specifically, we are looking at materials shipped via barge to the island of Guam, therefore I would think we need to use nautical miles. We found this great tool that might help other people too = http://www.distancefromto.net/
Megan, the key term in the credit language is "travel distance," so I think you're on the right track with nautical miles.
Thank you Tristan! We also got more clarification from the website designer - based on Riemannian circle theory = the distance between a pair of points is defined to be the length of the shorter of the two arcs into which the circle is partitioned by the two points. Therefore anything shippped via Air or Barge should use the Nautical miles traveled. http://en.wikipedia.org/wiki/Riemannian_circle
Good Morning Megan,
Great website for checking distances! Thanks for posting this.
I’d like to share a clarification regarding nautical miles, as I understand them.
Distancefromto.net gives the direct distance over the earth’s surface (great circle or Riemannian circle), including the curvature of the earth, between two locations. Like you said, this is the shorter of the two arcs on the great circle containing the two points. A distance can be described using different units, and I like that the website displays the various units.
A nautical mile is approximately 6,076 feet , or roughly 15% longer than a statute mile which is 5,280 feet. Units of nautical miles are often used in the aviation and shipping businesses, so a shipping company might refer to sending something from, say, Seattle to Guam as 4,930 nautical miles. This is approximately 5,673 statute miles.
Based upon the USGBC’s credit language of “500 miles (800 kilometers)”, statute miles, which we commonly refer to as simply miles, are used for LEED distance calculations. I hope this helps!
The LEEDonline templates on LEEDonline have been changed. Now it includes a new table that needs to be completed. After having taken the time to fill the information which is also in the materials and resources calculator the information was not saved. A lot of time lost and the credit appears as incomplete !
anyone else who has had the same experience and managed to resolve it?
Devani, this seems odd to me. Typically LEED Online forms are only upgraded if you request an upgrade. If you did request an upgrade, you should expect that data will be lost. If you did not, then I would contact GBCI to ask why they upgraded your forms and lost your data without your say-so.
Thank you Tristan for your quick reply. I did not realise that they changed the format for the MRc 5 template with the table of materials being integrated into it. It makes it open to error and other loss of information. What was the reasoning behind this change?
I haven't come across this new table yet. But is it possible to complete the table with the bottom line numbers from the calculator, and upload the referenced calculator... rather than re-enter all the information?
I work with a commercial modular building fabricator preparing to construct an office facility on the east coast. In pre-construction planning for this project, the question of the "project site" has been raised. Is the project site where the modules are constructed, or where the final placement of the modules will be? Our facility is just within the 500 mile radius of the final site, so this leads to the potential issue. Our normal steel distributor is about 25 miles from our facility, but just outside of the 500 mile radius of the final site. So if the final site is considered the "project site," we will have to have steel shipped in from roughly 200 miles away from our manufacturing facility, instead of our typical supplier.
Have tried using MR5 option 2 to see if it works out better...depending on how it's traveling?
I am still confused about how to calculate the raw material distance for Option 2. I understand how to calculate the distance from the manufacturing facility to the job site. But how does one calculate the distance from where the raw materials are extracted to the job site? It is confusing since the ACTUAL ROUTE must be used for Option 2. But the only actual route for raw materials to the job site is via the manufacturing facility.
Steel beams manufactured 1000 miles from job site and delivered via train for 900 miles to a railhead and then by truck for the last 100 miles. Assume raw materials are 900 miles from job site since they are close to manufacturing facility where they are sent to be made into steel beams.
Distance from Manufacturer to Job Site Calculation:
(900 miles by train/3) + 100 miles by truck = 400 miles < 500 miles ...OK
Distance from Extraction to Job Site Calculation?
Charles, what your post makes me think is that manufacturing location is not really relevant in Option 2, in the sense that what needs to be tracked is the path of raw materials, with the factory(ies) being just one stop on their trip.
In other words, why not just take the example you gave and extend it backward into the origin(s) of the raw materials?
So if the raw materials in my example were extracted 150 miles from the manufacturing facility and delivered by truck, then would the calculation be:
150 miles raw material by truck + (900 miles by train/3) + 100 miles by truck = 550 miles
Yes, that's my read on it.
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