NC 2009 MRc5: Regional Materials

No. No need to include that info if you're not using it to try to earn the credit.

You're correct. That specialized equipment should not be included in your calculations for the MR credits. 

That could be labeled more explicitly as "Source of your information about the extraction and harvesting location(s)." example entries might be: Letter from manufacturer; email from sales rep; Supplier website; etc.

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?

I agree that most projects achieve the 20% wiht big ticket items. But if you are trying to get to an Exemplary PerformanceIn LEED, certain credits have established thresholds beyond basic credit achievement. Meeting these thresholds can earn additional points through Innovation in Design (ID) or Innovation in Operations (IO) points. As a general rule of thumb, ID credits for exemplary performance are awarded for doubling the credit requirements and/or achieving the next incremental percentage threshold. However, this rule varies on a case by case basis, so check the credit requirements. credit, you sometimes need to eke out everything you can. One project we had was less than one percent from the EP credit.

Thanks for your comments.

Tristan: I agree that the credit is primarily derived from the big ticket items. However, that doesn't change the fundamental accounting.

LEED project teams are paranoid for good reason. Given litigation on buildings that have failed to meet specified certification levels they will demand information on every building component. As Susan points out, they may be attempting to get every dollars worth of regional material to gain a credit.

The inquiry to the manufacturer passes through many hands and the intent (making sure the big ticket items gain the credit) is usually lost in the mix. It goes like this:

LEED AP or Specifier => Project team member => GC => Subcontractor => Distributor => Manufacturer Customer Service => Someone like me

By the time the demand for information on speciated percentage of raw materials from within 500 miles (on letterhead) gets to me, I have no idea how important the information is to the LEED AP at the beginning of the chain. Is it simply to fill out a massive spreadsheet? Are they borderline on an EP credit? Are they comparing my product to a competitor's?

Either way, between all the steps involved there is a whole lot of time spent handling documentation. On this particular project, we spent roughly 4 hours of staff time handling the inquiry, looking at formulations and raw materials and writing multiple letters.

Should generating electronic paper be credit worthy activity? Perhaps not, but ideally the LEED AP and GBCI reviewer would consider context when looking at raw materials.

I gave the 20% organic solvent containing product as a fair example of something that could actually conform to EQCr4.2. My three products under consideration for this Platinum project range from 70-85% water. When I started here 20 years ago, the same type of product would have been 60-90% organic solvent.

I appreciate your Devil's advocate question. Yes, I have emissions tested products, however, that isn't even relevant to LEED for Schools since availability issues caused USGBC to allow NC requirements as an out. IEQ Credit 4.2 is worth 1 point and I go beyond simple regulatory conformance.

My Devil's advocate question: Shouldn't plywood manufactures be satisfied with contributing to MR Credit 7? I'm looking at a trade association website promoting contribution to MR 7, MR 4.2 and EQ 4.4.

Note: I harbor no grudges against the plywood industry; this was a random example. I could have used any number of product categories as exhibit A.

As LEED 2012 moves towards emissions testing for IEQc4.2 (3 points total for all combined interior layers), interior finishes manufacturers will be looking for ways to differentiate themselves in the LEED market.

If I were a cynical person, I could suggest designing some coatings with soy oil substituted for water as the carrier solely for the purpose of maximizing biobasedGenerally, classification of products and materials derived from plant and animal sources as opposed to minerals. The U.S. Department of Agriculture has a program to promote the use of emerging biobased products that defines them more narrowly, to exclude products that already have established markets, such as food, animal feed, and lumber. credit contributions. But that entails water use (irrigation), contribution to watershed pollution (TSSTotal suspended solids (TSS) are particles that are too small or light to be removed from stormwater via gravity settling. Suspended solid concentrations are typically removed via filtration. and pesticides), particulate pollution (PM2.5 from farming operations), energy (transport from field to broker to processor and processing energy inputs) and general air pollution (diesel and processing).

Reformulating to water carried technology is not point grubbing. And yes, I would like a carrot for my employer's efforts.

Dwayne, this has been interesting. I don't know how GBCI will see it, but I don't see a reason why water should be treated differently than other ingredients as far as regional calculations go. I think it is more of a stretch when someone tries to get MRc4 credit for water. If anyone can provide verification of how GBCI has ruled on this, or if anyone gets 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 or Interpretation, please let us know.

You should just estimate what it would cost to get similar material from a supplier if you did pay fair market price for it.

The GBCI comments that I had received on my last review, was that I needed a letter from the steel mill indicating where the scrap came from or at least a distance range from the mill. I emailed the steel mills that provided the steel for my project and most replied back with a letter stating either the distance from their scrap source to the project or the distance range from their scrap source to the mill. In the case of the later, the extraction distance that I used was the distance to the mill plus the distance range of the scrap source. I will be re-submitting in a few weeks and we will see if this logic is acceptable.

Kendal, adding the distance from the project to the mill to the distance range of the scrap source is incorrect. According to the latest addenda for LEED2009, the "recovery location" can be EITHER the location of the steel mill OR other collection points in the recycling chain. If the steel mill AND all the subsequent steel fabrication locations are all within the 500 mile radius from the project then 100% of the total recycled material content may be assumed to also be regional material.

However, MR5 also allows for the scrap collection locations to be considered the "recovery location". In the case of recycled steel content, that means multiple locations and not just a single point on the map. As such, some steel producers collect this information and can provide an accurate 'snapshot' of the percentage of scrap (recycled content) collected within 500 miles of the project site. Therefore, if the "final point of manufacturing" is within 500 miles of the project, the percentage of recycled content considered to be "regional" per USGBC guidelines can also be collected.

Jeremy, to your original question, Vulcaft can provide project specific information for both steel joists and deck. As stated above either the mill of the scrap processor can be considered the "recovery location."

One important note, when referencing the "steel mill" what's really meant is the location where the scrap is melted into new steel - i.e. the "melt shop". The rolling mill may or may not be in the same location. The distinction is important since it's possible to import blooms, billets or slabs to a rolling mill for processing.

Kendal, I would have thought that you could have filled out the forms as you describe, but apparently GBCI has another idea. Have you been able to resolve this?

I did the due diligence of getting a letter from each of the suppliers that were in question even though they did not qualify as a regional material because they were further than 500 miles from the project site. I uploaded all of the letters in the final review and finally did get the credit. It is as though I had to prove that a material that was from a distance greater than 500 miles did not qualify as a regional material.

Hi Scott,

One of the key points behind this credit is to reward projects that reduce the environmental impacts of transporting materials, so I doubt you're proposed approach would fly. 

This is just one of those credits that are unlikely to work in your location. For better or worse, that's kind of how LEED works--it has things that work out for some projects and not others...

In LEED guide says that.....
"If only a fraction of a product or material is extracted, harvested, or recovered and manufactured locally, then only that percentage must contribute to the regional value..."

Should i just count the steel percentage of manufacturning ????

For a material to count towards this credit, it has to be extracted, harvested AND manufactured within 500 miles. I think the older versions of LEED only looked at manufacturing distance, but this is not the case now. The material must meet both characteristics. If a portion of a product (10% as an example) was both 500 miles for extraction and manufacturing, you would get credit for just that portion (10%) of the material.

Older versions of LEED (pre version 2.0) looked at extraction/recovery location (MR5.1) and manufacturing (MR5.2) separately. All the current versions require BOTH extraction/recovery AND manufacturing to take place within 500 miles of the project. Now MR5 is still two points but one point is if the total value equals 10% of materials costs and a second point is available if the regional material value exceeds 20% of total materials costs.

It's typical for a steel manufacturer to recover scrap steel from all over and return it to the mill to be recycled into new steel. It's also likely that a portion of that percentage of recycled content came from within 500 miles of the project site. In that case, the fraction that came from within 500 miles of the project AND the final point of manufacturing of the "finished" product was within 500 miles would qualify for this credit.

It sounds like you're project using steel from Japan would not qualify for any MR5 value at all.

Tom, there is no MRc5 certification for manufacturers of building materials. It works on a project by project basis, with individual projects tracking where their materials come from, and documenting compliance with the help of location data provided by mfrs.

I'll comment on my experience but others may have additional information.

In the steel manufacturing process there are two primary raw materials (yes there are others but in terms of mass) - iron ore and scrap. "Extraction" of iron ore is pretty simple to pin point. "Recovery" of scrap can be a bit more difficult since there are generally more locations where 'recovery' happens. As a side note, both of the two basic steel making processes - BOF and EAF - use scrap steel as a primary input. EAF can use other virgin iron units as well.

Some steel producers are able to track the "recovery" locations of scrap steel by zip code. These locations would be the scrap yards where scrap steel is processed just before it's sent to the steel mill to be melted and cast into new 'semi-finished' steel products. Other producers may not track that information (or have it available for calculations).

Further complicating this situation is the fact that some steel mills may produce billets, slabs or blooms which are shipped to other "rolling mills" for further processing into semi-finished materials. In both cases, semi-finished steel products are usually further manufactured or fabricated into the goods which are used on the jobsite.

So understanding where 'recovery' and/or 'extraction' takes place can make a huge difference in the end results.

The current LEED addenda (for NC at least - dated 7/19/2010) indicates that "The extraction point for recycled
materials is the location of the raw material prior to the manufacturing of the final building product. As such, the point of extraction could include a recycling facility, scrap yard, depository, stockpile, or any other location where the material was collected and packaged for market purchase before manufacturing." Unfortunately that can mean different things for different products.

For example, it's possible that items like rebar can be used on the jobsite directly from the rolling mill (final point of manufacture) without further processing at a fabricator. In that case, the "point of extraction" could be considered the "recycling center" (mill that melted the scrap and produced the bloom) OR the scrap recycling center that processed the scrap prior to the steel mill. What's important here is that the "point of extraction" is NOT the rolling mill (although it's possible and likely that the rolling mill and the bloom mill are located in the same place).

However, producers that are capable of tracking scrap collection by location can provide a percentage of their scrap usage that was recovered within a 500 mile radius of the project site. The calculation determines the ratio of their scrap usage that was recovered within 500 miles and multiplies that percentage by that same mills annual scrap usage. While it makes sense that scrap would be sourced close to the steel mill, location and shipping methods/costs can skew the data.

Hope this helped.

Keith

If they are specified as part of the builing project they would potentially be included. Into what CSI section do the materials you are thinking of fall?

A park bench is not a "building material" but would included, for example.

In genearl you should only upload what is requested. However, I'm not sure what you mean by the old versino of LEED Online 2009? Do you mean for a v2.2 project or 2009? For 2009, you are asked to upload 20% of cutsheets.

I meant LEED v.2.2! Whoops! There is no requested upload for this online.

Jason, I think LEED is clear that the point of harvest needs to be documented—for forest products that are virgin, that would be the forest they came from. Do you have colleagues from other companies that have successfully managed this process? The LEED requirements have become so common, I would think there is a way to handle this issue.

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 would definitely not apply to wood automatically.

No, I'm afraid not. For one thing, if it came from the site you didn't buy it, so you don't have a dollar value to put in the calculation. And it certainly doesn't meet the definition of "recycled".

Art,
My understanding from NC 2.2 is that crushed concrete and asphalt (from existing site conditions) may be reused for site fill and contribute to both MRc2 and MRc5, but not MRc3 or MRc4. Use the cost of new fill or 'replacement value' in the calculations for MRc5. We have successfully documented this method on numerous projects.
Nadav, Is this still true for 2009?

Hi Linda,
It's true that excavated concrete and asphalt were able to be used under NCv2.2 for MRc5 and MRc2, though I'm not sure that would hold up in version 2009.
In terms of MRc2, soils have been explicitly excluded because they throw of the weight calculations, though you should definitely be able to count asphalt and concrete that are recycled. I'd be cautious about claiming asphalt and concrete for local fill, and push to divert it to road bed construction, or something more specific than fill.
For MRc5, the new CSI sections call out Section 31.60.00 (foundations), 32.10.00 (paving), 32.30.00 (site improvements) and 32.90.00 (planting). These do not include Section 31.23.23 (Excavation and Fill). Thus, if you are reusing the material as fill it won't be included in your calculations. Paving is included though, so if it can be diverted to a paving specific use then it should be eligible for inclusion.
Hope that helps.

Anne,
I agree with your comments. I should have been more specific--we have documented crushed concrete/ asphalt for MRc2 & 5 for site fill under pavinge excluding soil (not recommended under building slab) -- not general site fill. We will continue to promote this approach.
Thanks.

"Manufacture" is defined under LEED v2.0 and v2.1 as "the final assembly of components into the building product that is furnished and installed by the tradesman.
Since the "manufacturer" is defined by LEED V2.1 as "final Assembly, the fabricator's shop should be used as the location of manufacture. The stone comes from Italy, however it is fabricated into your counter top locally. -
This is how they are making a claim that it contribute to your regional credit - so long as the fabricator is within 500 miles.

Kevin, I see your point about the manufacturing point, but the big, gaping hole in the claim here is the extraction being in Italy. How can they get around that? I don't see it.

I understand that this is posted under the NC 2009 section, but I am going to refer to other versions of LEED in this response.

The company is claiming that they can contribute to MR5 Regional Materials credit. This is a true statement - however misleading it ultimately might be.

SEE LEED CI 2009 - MR5 Credit. For one point this credit is based entirely on the Manufacturing point of the products - only if you want 2 points does the extraction point come into play. So based on this LEED standard, their claim is true.

LEED NC 2.1 requires that a minimum of 20% of the total value of the material and products used are manufactured regionally within a 500-mile radius. Of the 20% regionally manufactured materials requirement, at least 50% of the content is extracted regionally.
In the past we have been successful with the following approach - We reported all regional materials that were Manufactured within the 500 mile radius - Including Solid Surface. We also listed all of the materials that were extracted regionally. Putting all of these items in the collective pot we achieved the appropriate ratio to meet this credit.

So you have a list of all material costs - of that 20% is manufactured locally.
Now- Of that 20%- 50% is ALSO extracted regionally, not all items will be regionally extracted.
Note that the Credit Template states (equal to 10% of total materials). So this tells you that the other 10% of the materials will only be regionally manufactured, and not regionally extracted.

The credit does not state that 50% of each individual material must have a minimum content of regionally extracted material. Rather -by cost - the sum of all items must show that 10% is regionally extracted. So in this instance, the solid surface did indeed contribute to this credit as well. - With that being said, you should check that this will work with your project.

So, the company's products can contribute to LEED-NC v2.1 projects and LEED-CI projects, but not any others, including LEED-NC 2009.

Thank you for the reply. I did ask if he meant projects still seeking certification under 2.0 or 2.1, but was told it applied to the most recent versions of LEED. Perhaps he meant CI, but many solid surface sites claim it achieves both points 5.1 and 5.2. Its an unfortunate misrepresentation to say the least.

Ok, so this is the explanation I just received from the manufacturer. Is this possible? The factory is considered the extraction point? Doesn't this open the door for almost anything made in a factory to be considered a regional item?

"Regionally Manufactured Materials are defined by the USGBC as assembled as a finished product (fabrication point) within a 500-mile radius of the project site.

The harvest or extraction point in this case is the factory - Buffalo, NY, zip code 14207. Therefore, project site + fabrication point + manufacturer's location = must be within 500 mile radius."

Given the way Corian is made, petroleum based plastics, I could almost believe this, but when this same argument is made for Quartz, extracted from Italy, I don't see that as a parallel product?

Jennifer, the factory is definitely not considered the extraction point, and this product does not qualify under MRc5 for LEED-NC 2009.

I think if you read this thread closely you'll see that it does qualify for MRc5 but only under LEED-CI 2009 and LEED-NC v2.1, but not because the factory is the extraction point.

Hi Tim,

The logic would suggest that the materials you're asking about should be included, but LEED has not yet come up with a simple, fair way to distinguish what should and shouldn't be included at such a detailed level, so everything in those MasterFormat divisions gets excluded. Sorry.

In other words, can you take them at their word? Yes.

However, I would not simply rely on a cut sheet. I would also get a letter from the manufacturer stating the extraction distance, especially if they aren't giving you the location. This is based on documentation requested on LEED Online.

If they can attest to that in a letter to you for your documentation, I would accept it, based on what LEED Online asks for to document this credit.

You do need extraction location or distance, in addition to manufacturing.

No, there really isn't. This credit is intended to apply only to materials that can be tracked back to their place of origin. But you can claim recycled content value under MRc4, of course.

To elaborate a little, you can potentially claim that scrap metal is a regional material, but you have to be able to document that in some way. The junk vendors in Norma's situation may buy scrap from all over the world. If you can document that scrap came from a regional collection point or points, then you could count it as regional.

If you look at the 3rd item in the "Design Development" phase of the "Checklists" tab above, you'll see a list of MasterFormat sections that should be included, per the LEED BD&C Reference Guide. They don't list Division 31, but they DO list much of Division 32, and my reading of MF 04 suggests that the gravel you're talking about might well fit in those parts of Division 32.

I'll answer the question you DIDN'T ask first. In LEED-NC 2009, you don't get any credit for stuff that's manufacturered within 500 miles of the project site unless it's also extracted/harvested within that zone.

Now, about the question you did ask--there are a couple of ways of distinguishing materials cost from installation cost. One is by what happens on site (installing stuff) as opposed to what happens off-site (making the stuff). Another is by who does it--a supplier makes the stuff, and a contractor or subcontractor installs it. The latter is cleaner because you'll have invoices showing the value of the material as it is transferred from one entity to another. So I'd say that you can try to count the fabrication labor in your material cost, but be prepared to have it questioned and/or rejected.

We are assembling the end product and installing it at the job site. Just as the suppliers are including labor costs into the costs of the material so I would assume that our labor would be included as well.

I suppose you can do it this way but as Nadav suggested I would be prepared to have it questioned. In a sense the whole building is being assembled on the jobsite. Yet construction labor is not counted toward MR credits. This sounds like it has a lot in common with construction labor, rather than factory labor.

Rebar - Typically when we purchase rebar from a commercial rebar supplier/fabrictor embedded in their material price delivered to the job is fabrication cost of cutting and bending the rebar. When we hire a concrete subcontractor the rebar typically but they will buy straight bar lengths take it to their shop and cut and bend before bringing to the site. Are we correct to assume in both cases this cutting and bending cost should be included in the material cost?

Yes, but I would be consistent in applying this methodology to all of your MR documentation.