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.
Sample LEED Online forms for all rating systems and versions are available on the USGBC website.
Documentation for this credit is part of the Construction Phase submittal.
Has anyone taken a look at the new calculator (v06, Jan 4, 2016)? This version combines the BD+C and ID+C calculators and changes the way the data for Option 1 and Option 2 are entered.
The instructions confirm that you still need to enter manufacturing and extraction distances for Option 1, but there doesn't appear to be a place for those numbers to be entered.
I have also realized this with the material calculator, which we need to complete.
Have you managed to figure out how we include the extracted and manufactured distance?
GBCI replied and indicated they would develop a set of instructions for the new calculator, which does require the information be documented in a different way. (No, I haven't figured out how to document extraction and manufacturing distances OR the percentage of back-up documents provided.)
I responded and explained that wholesale changes in the documentation process for existing projects and existing rating systems was unfair to project team members for many reasons. They acquiesced and confirmed I could continue using the old version on a project-specific basis.
My suggestion to you is to send a feedback/contact question regarding this issue. If they receive feedback on the implications of a new v2009 calculator from several people, perhaps they will re-evaluate the need to make this type of change retroactively on v2009 projects.
Honestly, I'm at a loss as to the purpose of this change in v2009.
Can select fill mined within the LEED boundary be counted as a regional material? I have not been able to determine if the soil preparation below items included in specification sections 31.60.00 Foundations, 32.10.00 Paving, 32.30.00 Site Improvements, and 32.90.00 Planting can be counted for MRc5.
CSI MasterFormat puts soils & fill materials under Earth Moving in Section 31.23.00 “Excavation and Fill.” Since this is not one of the designated Spec Sections, fill should not figure into material tallies for Credits MRc3 through MRc7.
Clearly i know the project team should provide cutsheets for the materials to support regional materials claims,but i cannot get the meaning of "cutsheets".Which kind of information the cutsheets should contain?
Cutsheets is somewhat of a catch-all term that LEED uses to refer to manufacturer documentation. For MRc5 you will need proof from the manufacturer that confirms what percentage of the product, by weight, meets both of those criteria (i.e. manufactured within 500 miles of your LEED project and from raw materials which were harvested/extracted within 500 miles of your LEED project). So you would want documentation from the manufacturer to clearly state where the product is manufactured and where each of the raw materials are extracted/harvested. It is most helpful if the manufacturer also includes the percentage, by weight, that each raw material comprises within the final product.
Make sure to pay special attention to/note that it is where the raw materials are extracted/harvested, not where the supplier/vendor of those materials is/manufactured them.
Thanks for your answer,but i have a additional question.DO i need the manufacture's signature on it or stamp on it or both?Which way is qualified for the criteria?
Your supporting documentation must be clearly attributable to the manufacturer. USGBC does not accept claims from the contractor/subcontractor. There is not a single method/option - the important thing is to make sure all your supporting documents are clearly linked to the manufacturer so there are no questions about who provided the document/verified the product's contributions. Typically we want any verification to be on manufacturer letterhead or with the manufacturer logo printed on it.
I got it . Thank you very very much .
When calculating distances from location of extraction and location of manufacturing to project site, is it "as the crow flies" or actual travel distance?
Option 2 uses “travel distance”: http://www.usgbc.org/leed-interpretations?keys=100001265.
Compare the Option 2 language to that of Option 1, which defines regional as “within a 500-mile radius.” A radius is a straight-line distance (http://www.usgbc.org/leed-interpretations?keys=100001263). In other words, Option 1 is as-the-crow-flies, and Option 2 is actual travel distance. The different choice of words appears to be significant.
Thanks Jon. I have received conflicting answers on this so far.
Could anyone else take a stab at this?
Haley - I think Jon is correct. Under Option 2, you wouldn't use a radius (or as the crow flies) distance for rail, inland waterway, or trucking because that is not physically possible and this option relates to actual miles traveled. While total travel distance is not defined, I think its meaning is straightforward. See MRc5 under Key July 2012 Addenda in http://www.leeduser.com/blogs/guide-key-leed-nc-v2009-addenda.
Sometimes I receive a letter from a manufacturer stating that a material is harvested and manufactured within 500 miles of the project site however for proprietary reasons, they cannot disclose these locations.
Has anyone had experience in documenting this and whether or not USGBC has pushed back?
In lieu of a complete breakdown of all raw material extraction points, LI#2426 allows “a statement on the manufacturer's letterhead indicating that the point of extraction, harvest, recovery or manufacture is within 500 miles of the LEED project site.”
I do not know about LEED Reviewers, but I tend to be skeptical of such letters. They should not be “boilerplate” statements. I have required signed and dated letters that include the project’s name & address and the name of the product, explicitly stating the percentage of that product’s raw materials “mined, quarried, harvested, or recovered” within 500 miles of the project site. (The percentage is essential for entry into the MR Calculator spreadsheet.)
The point is that, if I must accept less that complete disclosure, I want to make sure that the authors of these letters understand their MRc5 claims and that they have exercised due diligence to ensure their accuracy.
Side Note: I have achieved MRc5 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. based on “big ticket” regional items like concrete, precast, masonry, paving, gypsum, stone, and steel, using complete material source data. I am not sure that I have ever actually had to fall back on data for lesser materials with less complete documentation.
I am fairly new to LEED so please bare with me on this one. We are a manufacturer and sell assembled products to the customer. Thus, when we sell the assembled product, it is our understanding that we would be the manufacturer.
However, we have had some issues with what our harvest location would be. We purchase the parts (typically wood based products such as solid lumber, veneer, plywood, etc.) from local distributors. Would the harvest location that we report be our distributors facility, or do we have to dig deeper and find out where they got their raw materials from?
One problem we continually run into is distributors telling us that the wood used came from multiple forests, or they provide me with an approximate location (i.e. Eastern Tennessee).
Our lives would be much easier if the distributors facility is deemed as the location of recovery of raw materials.
Can anyone provide me with information on this?
Sorry, but you cannot use the distributor’s facility, or even the lumber mill, as the extraction site for wood products. Under Credit MRc5, LEED-2009 Addenda define extraction points as the origin of the RAW MATERIAL. Here are some good rules of thumb:
. . Minerals: The mine, quarry, or well from which the material was drawn.
. . Agricultural (such as wood): The land where the material was harvested (so, for solid lumber, veneer, plywood, etc., the extraction site is the forest, not the distributor).
. . Reused: The place from which the material was salvaged.
. . Recycled: The scrap yard or reclamation facility from which the material was purchased before remanufacture into a useful product. (Wood composites like MDFMedium-density fiberboard (MDF): Panel product used in cabinets and furniture; generally made from wood fiber glued together with binder; similar to particleboard, but with finer texture, offering more precise finishing. Most MDF is made with formaldehyde-emitting urea-formaldehyde binder. of particleboard, which are often made using recycled wood chips, the extraction site would be the mill that produced the chips.)
One caveat: If the raw material passes through mills, distributors, or other intermediates on its way from the extraction to fabrication, each of these ALSO must be within 500 miles of the project site to count as regional.
For MRc5, these are the critical data for assemblies:
+ . The cost of the assembly (excluding on-site installation labor, but including any pre-delivery fabrication costs);
+ . The assembly’s manufacturing location; and
+ . If the manufacturer is within 500 miles of the Project site, the percentage (by weight) of raw materials in the assembly extracted within 500 miles of the Project site.
To address the other half of your question, sometimes the approximate harvest site of the trees will suffice.
For example, if your plant lies within 500 miles of a project in Indianapolis, you would tally up the weights of all the components in the assembly that they purchased. Next, identify which components have extraction sites within 500 miles of Indy, and report their percentages compared to the total weight of the assembly.
Reporting that 12% of the assembly is wood from trees grown in western Tennessee would be good enough for this project because all of Tennessee lies within the 500-mile radius from Indy. However, if the wood came from central Pennsylvania, right on Indy’s 500-mile boundary, you would need to be more specific, perhaps reporting which county or zip code of the forest.
While researching the requirements for MRc5 (NC-2009), I found information on the USGBC site that states there are a possible of two points for Regional materials.
Option 1 requires 20% (twenty %) of the material value be MANUFACTURED within a 500 mile radius of the site. It does NOT mention harvesting or extraction in option 1.
Option 2 requires that 10% (ten %) of the material value be extracted, harvested AND manufactured within a 500 mile radius of the site.
Is each option the equivalent of 1 point?
It looks like this has changed from v2, 2.0 which states 20% manufactured only.....
Which is different than v2, 2.2 which states 10% extracted and manufactured.
Am I understanding this correctly?
I think you must have been looking at the wrong set of requirements. What you're describing applies to LEED-NC 2.x, but NOT to LEED 2009 (except for the CI version). And might I suggest that you consider becoming a LEEDuser member? If you did that, you'd see the actual credit langauge right here, on this page, and not have that opportunity for confusion. ;-)
Thank You Nadav. I'm working on trying to get my boss to get a membership. I agree it would be helpful. However, I'm more of an inquiring mind that wants to understand everything. Especially when I get conficting info from two or three different sources. The manufacturers we buy from are the ones that really need the membership. We are basically the middle-man passing along the info the manufacturers provide to us.
The information I was describing is for LEED 2009 CI version (I can't attach a screen shot in this forum).
Is each option (1 and 2) worth 1 point?
Yes, LEED-CI 2009 does work as you described. There is a separate forum on LEEDuser for talking about that rating system and credit, so you might want to take your questions about that over there: www.leeduser.com/credit/CI-2009/MRc5
In our project, we decided to estimate real total material cost without equipments and labor for division 2-10. What kind of proof the contractor needs to present in this case? does a letter of subcontractor that indicates the material value will be sufficient? Do we need receipts or other documentations?
Thank you !
Sahar, I'm concerned that this approach doesn't have much rigor. Did you estimate costs item by item? GBCI typically doesn't get very detailed in looking at the cost accounting on items like this, but your approach could raise questions.
Has the point structure for this credit changed from 10% - 20% to 20% - 30%
No. USGBC has not changed credit thresholds for LEED-2009. BD+C Regional Material thresholds for MRc5 are still 10% for 1 point and 20% for 2 points. Also unchanged is the 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. threshold. Projects that document 30% Regional Materials may earn 1 additional Innovation in Design point under Credit IDc1.
This explains why a project might set its MRc5 goal at 30%.
[Note: Under LEEDv4, USGBC HAS significantly changed the way it addresses Materials & Resources in general and Regional Materials in particular, but that is an entirely different matter. See LEEDuser’s NCv4 MR forums for the Building Product Disclosure and Optimization credits.]
The LEED Canada - Reference Guide for Green Building Design and Construction 2009 shows the minimum percentage of regional materials for each point threshold as 20% - 1 point 30% - 2 points. This is a NC project.
Am I missing something here?
Robert—If you have access to the Canadian Green Building Council (CaGBC) LEED Reference Guide, you probably have most of what you need to answer any questions about LEED Canada 2009. Note that LEED Canada is very similar to the U.S. Green Building Council (USGBC) version of LEED-NC, but apparently, the credit thresholds for MRc5 may be one of the differences between the two systems. For questions about the distinctions, LEEDuser offers a special LEED Canada forum: http://www.leeduser.com/topic/leed-canada-forum-nc-cagbc.
For USGBC LEED-NC-2009, and for projects using the LEED-2009 BD+C Global Alternate Compliance Paths (ACPs), the MRc5 thresholds are still 10% & 20%. However, some Global ACPs offer an additional basis for MRc5 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..
Sorry if this is a rudimentary for all you LEED guru's out there, but I am hoping you can clarify the question I have on a number of items we are specifying for our first LEED project
We are specifying a Chair Lift which is manufactured within 10 miles of our project site. The manufacturer buys components from all over the country and in some cases other countries. As it turns out there are 10 major components, 6 come from within 500 miles, 4 come from outside the 500 mile radius.
How do I calculate the contribution toward this credit?
Are you sure that this product is included in the MRc5 calculations? You are only allowed to include items specified in Division 3-10 and a few very specific sections in Divisions 31 or 32. MEP and specialty equipment (including elevators) is excluded. I don't think this product should be included (in either your numerator or denominator).
If is was to be included, you would need to know the overall weight of the entire assembly as well as the individual weight of at least the 6 components that have their raw materials harvested/extracted within 500 miles of your job site. You could then claim that percentage as regional content. Note that the regional content must be calculated by weight, not cost, of the components. And you would need to be looking at the raw materials, not necessarily the supplier, of the components.
You are correct about the Division 14. I was working on the spec for that at the time and wanted to give simple example
Your explanation of the calculation process is helpful when applied to other examples. Thank you
IF the manufacturer's location is within 500 miles however fabricator's location is not, does it still have contribution to this credit OR not?
In another word, when manufacturer location is within 500 miles, for being eligible to contribute in this credit, should I chose from the local fabricators?
Answers to many questions can be found in LEED BC+C Reference Guide. In the MRc5 Chapter, the Implementation section states, “If the material contains components that were sourced from within 500 miles but the final assembly was farther away, the product cannot be counted toward the credit.” The intent of MRc5 is to reduce “the environmental impacts resulting from transportation.” Therefore, any part of production that occurs outside the regional radius disqualifies those goods from MRc5.
I feel like broken record on this topic, because I know I've been through this before. I received review comments on a project that have the potential to reduce the steel contribution significantly and I'm looking for some consistent information to help answer the questions.
Moving backwards through the process from the site, the fabricator cut, formed, welded, and prepared the components for final assembly and installation on site. That is the location the reported as the manufacturing location.
In reporting the extraction/harvest location, the report uses the next entity back in the chain which is typically a mill. For many of the larger steel shapes, the mill melts the scrap and can document where that scrap came from. The tube companies, however, receive coil from a different mill who actually melted the scrap. The tube company can tell me where they purchased their coil, but to find the scrap location for the mill that produced the coil is a much bigger task.
The fabricator has successfully achieved points by reporting the mill location as the extraction point on several projects in multiple rating systems, but the exact same documentation was rejected on the project I am currently working on.
Does anyone have insight on this aspect? If the steel has recycled content, are you required to go back to the scrap yard even if that is three layers away from the project? Can the coil used to make the tube ever be considered the "raw material"?
Tiffany – I understand your frustration. Thanks to its convoluted supply chain, getting reliable recycled regional and recycled content data for steel tube has been hard. I have had similar issues with sheet steel fabrications and other products manufactured from materials pre-processed by others using goods originally milled by yet another set of companies. It takes an extraordinary effort (and cooperation from the entire supply chain) for a manufacturer to track so many variables through so many layers and report valid percentages. For such items, I have had to settle, using the steel default for MRc4 and 0% regional for MRc5.
To your question, “Can the coil used to make the tube ever be considered the ‘raw material?’” No, not any more. Addenda issued July 2010 “clarified” when & how to count recycled as regional (see http://www.usgbc.org/leed-interpretations?keys=100000379). Before July 2010, the interpretation was a bit looser. An ancient 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 was often cited to allow just what you have asked to do. USGBC even issued addenda that seemed to support this interpretation, but they rescinded the guidance just three months later when they issued the addenda above.
This “about-face” may explain the inconsistencies that you have seen—why the fabricator’s data that worked in the past is no longer accepted by reviewers.
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.
Chris, Marcia, Khristine - My recommendation is to follow the calculation outlined above by Marcia and Kristine. It's correct that for many steel products produced in North America and destine for a construction project, tracking the virgin materials isn't worth the effort. For example, 100% of the rebar and 100% of the structural steel produced in North America are made from virtually (99%+/-) recycled content and in EAF furnaces. What's not scrap are alloy's and other minor components. Plate and sheet products however can be a wide mixture of scrap vs virgin depending on the producer and process.
Likewise, ANY imported steel product can be any ratio of scrap vs. virgin and can be made using any type of process. This can have a dramatic difference in the environmental footprint of the steel material/product. Never assume just because you bought it in North America that it was made in North America. Spell it out in the specs.
In terms of LEED documentation for most steel products, only expect to see claims referring to the recycled content percentage. At that point it is important to mulitply the recycled content times the regional percentage to caclulate the percentage of the total product cost that is applicable.
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.
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.
I think that your interpretaion is the most rational one. Thank you!
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.
Taking your example: 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. This manufacturer is the Final manufacturing location to project site. Is this right?
Assuming the above Final manufacturer purchases their rebar from say, Gerdau or Nucor. To claim regional distance compliance for the recycled scraps, it will be the Gerdau or Nucor [who also melts the scrap and manufacture it into billet to form the rebar]. Is this right?
LS you're correct. According to the adenda language, the "collection" point can be considered either melt shop pr the colleciton/processing location before the melt shop. Sometimes those locations are co-located.
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