-
Generally standard practice, anyway
In general, complying with this prerequisite is standard practice in most urban and suburban areas, where most or all of the EPA Construction General PermitEPA's Construction General Permit. Outlines the provisions necessary to comply with Phase I and Phase II of the National Pollutant Discharge Elimination System (NPDES) program. (CGPEPA's Construction General Permit. Outlines the provisions necessary to comply with Phase I and Phase II of the National Pollutant Discharge Elimination System (NPDES) program.) requirements have been adopted and implemented at the state or county level. Regulators at those levels often threaten heavy fines for not complying with CGP requirements, so most projects do so without the added incentive of the LEED prerequisite.
Early on in project planning, compare your local code requirements to the CGP to determine which is more stringent. If your local code is more stringent, then you will meet the prerequisite just by following that. If it is less stringent, follow the CGP to achieve the prerequisite.
Create an ESC plan
The CGP extends compliance with the National Pollutant Discharge Elimination System (NPDESThe National Pollutant Discharge Elimination System (NPDES) is a permit program that controls water pollution by regulating point sources that discharge pollutants into waters of the United States. Industrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters.) stormwater regulations to construction activities. It has three main categories that need to be addressed as you create an erosion and sedimentation control (ESC) plan:
- Prevent the loss of topsoil during construction. Proper staging of earth-moving activities and the preservation of mature vegetation can aid in preventing topsoil loss and controlling stormwater pollutant discharge. Stabilization methods such as seeding, mulching, and the use of geo-textiles should also be included in your plan.
- Prevent the sedimentation of receiving streams. Your plan should outline the placement of planned structural control measures such as silt fences, drainage swales, and storm drain inlet protection.
- Prevent air pollution by particulate matter. Your plan should describe measures to prevent the tracking of soil onto paved surfaces off-site and the generation of dust from construction vehicles—for example, gravel skirts at drive entries and exits, transit ways for heavy vehicles, and wash stations for trucks.
Simply put, your ESC plan implements good housekeeping on a site-wide basis, minimizing the impact of construction on local environmental resources and surrounding properties.
As written, the CGP applies to sites of one acre or larger. However, all projects pursuing LEED certification must meet the requirements of the CGP, regardless of size.
Often the civil engineer is responsible for creating the ESC plan, which is then implemented by the general contractor. Smaller projects may find the contractor is the one providing the plan, often one that is standard for their company.
Documenting your plan
The ESC plan may be submitted as documentation, in the form of a site plan or a narrative report.
Inlet protectionTo demonstrate that your ESC plan was implemented, your projects will also be required to provide one of the following: - An inspection check list―signed, and dated periodically.
- Date-stamped photos of the following:
- measures to prevent topsoil loss including staging of earth-moving activities and stabilization techniques;
- measures to prevent sedimentation of nearby streams including structural controls and inlet protection;
- measures to prevent air pollution including tracking control at entrances and exits.
- Description of corrective actions taken in response to problems with the performance of ESC measures.
Zero lot lines
Many urban projects have zero lot lines and, therefore, no associated “site.” If your project is like this, you are not exept from developing and implementing an ESC plan. However, strategies and BMPs will differ from those implemented on projects with site area. Inlet protection will still be required, even if storm drains are not immediately on site and within your LEED boundary. Tenting work areas and using temporary enclosures can prevent dust and airborne particulatesTotal suspended particulate matter found in the atmosphere as solid particles or liquid droplets. Chemical composition of particulates varies widely, depending on location and time of year. Sources of airborne particulates include: dust, emissions from industrial processes, combustion products from the burning of wood and coal, combustion products associated with motor vehicle or non-road engine exhausts, and reactions to gases in the atmosphere. (EPA) from leaving the project site. Vehicle tracking and concrete washout will also need to be addressed, and washout will likely have to be managed onsite somehow. Don't forget to include staging areas.
Concrete washoutDocument the plan with a narrative report explaining which CGP requirements don’t apply to your project conditions, which do, and how you plan to implement them.FAQs for SSp1
Am I exempt from this prerequisite if I have a zero-lot-line building? What if the site work is minimal due to the scope? What about a renovation? What if the excavation and foundation work is minimal due to the construction materials I am using?
No. You must always do an ESC plan according to the credit requirements. We have yet to hear of a project that didn't have some issues to address. See the above section titled "Zero lot lines."
What are BMPs for steep slopes?
BMPs for steep slopes should address soil retention, but not water retention. These could include silt fencing and straw wattles, hydro seeding and stabilized mulching, geotextiles and mats, and most importantly, preservation of natural vegetation.
I have a technical question about a specific control measure and whether LEED requires it. What guidance is available?
LEED does not offer specific requirements on ESC control measures, beyond the standards that it references, and the documentation requirements. LEEDuser recommends working with a civil engineer who understands the LEED and EPA requirements, and relying on the professional judgment of the engineer for specific technical questions. LEEDuser has not heard that LEED reviewers are deeply scrutinizing ESC plans and coming back with highly technical questions.
Is there a preferred method for documentation?
This prerequisite offers several options for documentation, including date-stamped photographs, a narrative describing the ESC plan implementation, or a builder declaration of periodic inspection and documentation of ESC implementation. You can rely on project specifics to choose the best option for you—LEED has no preference.
What suffices as far as a date-stamped photo?
Ideally, use your cameras to imprint a visible date on a corner of the image. Most cameras offer this option. Digital files also typically encode a date when the file was created, or encode that date in the file name, and while these methods aren't ideal, some project teams have reported success submitting this type of documentation.
Can I still earn the prerequisite if the project started considering LEED after work began?
As long as the project has been actively implementing an ESC plan during the current development of the project site, you should be okay. If that's not the case, then the outcome will depend on project specifics, and you will likely need official guidance from GBCI.
LEEDuser has advised teams that in multi-phase projects, it's okay to focus documentation of the ESC plan only on the current phase, when LEED became part of the project scope. In general, if there is some question about whether controls were in place during the LEED project, you may not be able to earn the prerequisite.
How do I know if my local code is more or less stringent than the EPA CGP?
USGBC has not identified specific standards for judging this, or defined certain codes as compliant with the credit, or not. The stringency of other codes relative to EPA's Construction General Permit is judged on a case-by-case basis.
Legend
- Best Practices
- Gotcha
- Action Steps
- Cost Tip
Pre-Design
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Review pages B-1 through B-4 of the EPA Construction General Permit (CGP) (see Resources) to determine if your state administers the CGP requirements for all projects.
In regions where the EPA CGP is not standard practice, compare the local code with the CGP and make adjustments, if necessary, to include all the CGP requirements.
Meeting the requirements of this prerequisite is standard practice in many regions and, therefore, no- or low-cost for LEED.
The materials cost to implement these measures is minimal and can potentially save money by preserving the vegetation and topsoil on-site.
Conduct a site evaluation to assess opportunities for minimizing the alteration of the natural stormwater runoff patterns of your site and the disruption of mature vegetation, especially trees. This will save money and time in terms of earth-moving and replanting vegetation.
Ask your civil engineer about soil types and what type of drainage you will have once the topsoil and vegetation are disturbed.
Schematic Design
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Establish who will create your ESC and stormwater pollution prevention plans. Usually, the civil engineer creates them, and the contractor is responsible for their onsite implementation.
It is best to include your ESC plan in both project drawings and project specifications so that the intention of the plan is clearly communicated to the project team, especially contractors and subcontractors.
Determine whether the 2003 EPA CGP or local erosion and sedimentation control standards are more stringent―and follow the more stringent standards. Often the state department of environmental protection or equivalent will have a written ruling on the comparison of the CGP standards and the local standards.
A good first step to determine which is more stringent is to review your local code to be sure it contains at minimum the general categories contained in the CGP. If not, you’ll know that you need to follow the CGP. If so, you’ll need to review your local code in detail to be sure that all of the requirements are included. The general categories are as follows:
- allowable stormwater discharges
- allowable non-stormwater discharges
- limitations on coverage
- a stormwater pollution prevention plan
- releases in excess of reportable quantities
- treatment of spills.
If local standards are equal to or more stringent than the CGP,you'll need to provide a narrative report detailing this. Write the narrative when you do the comparison, so that it's fresh in your mind.
Design Development
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Create a draft ESC plan drawing or a narrative report that outlines how your project will comply with the requirements of the CGP or the local standard. See the Documentation Toolkit for samples.
Make sure that you use the same LEED project boundary as all other LEED credits your project is attempting (this is particularly relevant with other Sustainable Sites credits).
A project drawing should include anticipated stormwater flows and indicate the location and type of any planned ESC measures.
All written ESC plans must include the following:
- an introduction describing the standard being followed, existing site conditions, and responsible parties
- a list of the temporary and permanent control measures that will prevent loss of topsoil, sedimentation of receiving streams and storm sewers, and air pollution by particulate matter
- details of the plan for implementation and ongoing maintenance to prove implementation, including one of the following measures:
- A checklist or inspection report demonstrating implementation of your ESC plan and providing sample dates, inspection frequency, at least three equally spaced inspections over the project timeline, and a description of any corrective actions taken. (For LEED documentation, you need to upload this document and have the builder or general contractor sign the LEED Online credit form.)
- Date-stamped photos of implementation and corrective actions, as applicable, including at least three photos from three different monthly inspections equally spaced over your project site's work timeline. (For LEED documentation, you need to upload these images, but there is no specific required signatory for this option.)
- A narrative outlining the implementation and corrective action taken to effectively implement your ESC plan. (For LEED documentation, you provide the narrative itself; there is no required signatory for this option.)
Determine which path your project will follow to demonstrate implementation compliance: inspection report, photos, or narrative report.
Photos are likely the easiest way to demonstrate compliance, unless an inspection report has already been completed.
Develop a site-wide, earth-moving schedule to minimize the impact on established vegetation and to stockpile topsoil and protect it from erosion. This can also complement your strategy to achieve SSc5.1: Site Development—Protect or Restore Habitat, by limiting site disturbance and maintaining native vegetation.
Proper scheduling and staging of earth-moving activities can lower the costs associated with sediment and erosion controls.
Retain as much of the existing vegetation as possible, not only to lower costs for replacements, but also to decrease the cost of structural controls.
Careful implementation of the stormwater pollution prevention plan (SWPPP) by the contractor should inform the design and installation of stormwater management systems onsite. This will enable those systems to be integrated to the greatest extent possible during construction, preventing unexpected stormwater discharges into receiving waterways.
If attempting one or both of the stormwater management credits SSc6.1 and SSc6.2 confirm with the contractor that the SWPPP accurately represents the hydrologic characteristics of the site and is performing as anticipated. Check on assumed infiltration rates, suspected rate and quantity of run-off to receiving streams, and discuss potential storage options. Make changes to the stormwater management system accordingly to improve its effectiveness and ensure that the credit calculations are accurate.
Construction Documents
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Review your ESC and stormwater pollution prevention plans to ensure adequate measures will be implemented to meet the CGP, or local requirements. A discussion between the contractor and the civil engineer on the schedule and implementation of planned measures should be part of this review.
Finalize your ESC plan drawings or narrative report. Verify that your plan is in compliance with the CGP or local standards.
Construction
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Review all ESC project drawings and construction specifications prior to construction activities.
Verify that all ESC measures are in place before any construction activities begin.
The general contractor implements the ESC plan until construction is completed and all disturbed areas have been stabilized.
Have a representative from the general contractor’s office onsite daily to monitor and implement necessary measures laid out in your ESC plan.
The civil engineer, contractor, or a third party should inspect your ESC plan measures on a weekly basis (bi-weekly if inspections are also conducted after any weather event involving more than 0.5 inches of rain), and submit status reports on ESC plan implementation. These reports should include labeled and dated photographs, an inspection log, or a narrative report describing the performance of the measures implemented.
Provide corrective actions immediately after any rain event.
Corrective actions can range from adjusting the placement of silt fencing and removing debris from stormwater catchment basins to replanting areas of temporary seeding and adding material to gravel skirts at entrances and exits.
Preserve existing vegetation, especially mature trees, whenever possible. This will decrease costs for temporary stabilization measures and erosion controls. In addition, the vegetation may also be used as part of your landscaping plan.
After completion of all construction activities, document credit compliance in LEED Online by uploading these documents:
- A narrative that declares the standard followed (2003 EPA CGP or local). If you used a local standard, write a narrative report detailing how it is equal to or more stringent than the CPG (Phases I and II, NPDES program).
- A written ESC plan or project drawings showing the control measures used.
- Proof of implementation with one of the following: an inspection report with the required signature, nine photos, or a narrative report.
Operations & Maintenance
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Implement an ongoing stormwater system maintenance plan with the landscape manager. This should include a regular schedule for monitoring the performance of the stormwater management system and guidelines for repairing or modifying site features that are causing problems. These guidelines could include replacing or increasing vegetation, redirecting runoff, and increasing storage.
USGBC
Excerpted from LEED 2009 for New Construction and Major Renovations
COPYRIGHT © 2009 BY THE U.S. GREEN BUILDING COUNCIL, INC. ALL RIGHTS RESERVEDSS Prerequisite 1: Construction activity pollution prevention
Required
Intent
To reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation.
Requirements
Create and implement an erosion and sedimentation control plan for all construction activities associated with the project. The plan must conform to the erosion and sedimentation requirements of the 2003 EPA Construction General PermitEPA's Construction General Permit. Outlines the provisions necessary to comply with Phase I and Phase II of the National Pollutant Discharge Elimination System (NPDES) program. OR local standards and codes, whichever is more stringent. The plan must describe the measures implemented to accomplish the following objectives:
- To prevent loss of soil during construction by stormwater runoff and/or wind erosion, including protecting topsoil by stockpiling for reuse.
- To prevent sedimentation of storm sewers or receiving streams.
- To prevent pollution of the air with dust and particulate matter.
The EPA’s construction general permit outlines the provisions necessary to comply with Phase I and Phase II of the National Pollutant Discharge Elimination System (NPDESThe National Pollutant Discharge Elimination System (NPDES) is a permit program that controls water pollution by regulating point sources that discharge pollutants into waters of the United States. Industrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters.) program. While the permit only applies to construction sites greater than 1 acre, the requirements are applied to all projects for the purposes of this prerequisite. Information on the EPA construction general permit is available at http://cfpub.epa.gov/ npdes/stormwater/cgpEPA's Construction General Permit. Outlines the provisions necessary to comply with Phase I and Phase II of the National Pollutant Discharge Elimination System (NPDES) program..cfm.
Potential Technologies & Strategies
Create an erosion and sedimentation control plan during the design phase of the project. Consider employing strategies such as temporary and permanent seeding, mulching, earthen dikes, silt fencing, sediment traps and sediment basins.
Publications
EPA – Construction General Permit
Referenced Standard.
Stormwater Pollution Prevention Plans for Construction Activities
Resources here include Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites, SWPPP Templates, Sample Inspection Form, Example SWPPPs, Key Resources, and Selected State BMPBest Management Practice/Guidance Manuals.
BMP Manual
BMPBest Management Practice Manual.
Organizations
International Erosion Control Association
Connect with worldwide member based erosion and sediment control community.
Certified Professional in Erosion and Sedimentation Control
Provides certification programs a list of qualified professionals.
Technical Guides
Canada Mortgage and Housing Corporation
A variety of Canadian resources on stormwater management and BMPs.
Photos
Take photos like these to document proper implementation of your ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation plan.
Erosion and Sedimentation Control Plan Drawings
Posted here are sample drawings for erosion and sedimentation control (ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation) plans from a LEED project.
LEED-NC Platinum Senior Housing Sample Documentation
Samples from this LEED Platinum project demonstrate how to document SSp1. This 8-story, 100-unit public senior housing development will use 50% less energy than a comparable code compliant building. Although on a tight urban site, the project also features innovative stormwater management plans, and a pilot graywaterGraywater is untreated household waste water which has not come into contact with toilet waste. Graywater typically includes used water from bathtubs, showers, bathroom wash basins, and water from clothes-washer and laundry tubs, though definitions may vary. Some states and local authorities also allow kitchen sink wastewater to be included in graywater. Project teams should comply with the graywater definition established by the authority having jurisdiction in the project area. reuse system—all on a tight budget under a major urban housing authority.
LEED Online Forms: NC-2009 SS
The following links take you to the public, informational versions of the dynamic LEED Online forms for each NC-2009 SS credit. You'll need to fill out the live versions of these forms on LEED Online for each credit you hope to earn.
Version 4 forms: (newest)
- SSp1: Construction Activity Pollution Prevention
- SSc1: Site Selection
- SSc2: Dev. Density & Community Connectivity
- SSc3: Brownfield Redevelopment
- SSc4.1: Alt. Trans.—Public Trans. Access
- SSc4.2: Alt. Trans.—Bicycle Storage
- SSc4.3: Alt. Trans.—Low-Emitting Vehicles
- SSc4.4: Alt. Trans.—Parking Capacity
- SSc5.1: Site Dev.—Protect or Restore Habitat
- SSc5.2: Site Dev.: Maximize Open Space
- SSc6.1: Stormwater Design—Quantity Control
- SSc6.2: Stormwater Design—Quality Control
- SSc7.1: Heat Island Effect—Non-Roof
- SSc7.2: Heat Island Effect—Roof
- SSc8: Light Pollution Reduction
Version 3 forms:
- SSp1: Construction Activity Pollution Prevention
- SSc1: Site Selection
- SSc2: Dev. Density & Community Connectivity
- SSc3: Brownfield Redevelopment
- SSc4.1: Alt. Trans.—Public Trans. Access
- SSc4.2: Alt. Trans.—Bicycle Storage
- SSc4.3: Alt. Trans.—Low-Emitting Vehicles
- SSc4.4: Alt. Trans.—Parking Capacity
- SSc5.1: Site Dev.—Protect or Restore Habitat
- SSc5.2: Site Dev.: Maximize Open Space
- SSc6.1: Stormwater Design—Quantity Control
- SSc6.2: Stormwater Design—Quality Control
- SSc7.1: Heat Island Effect—Non-Roof
- SSc7.2: Heat Island Effect—Roof
- SSc8: Light Pollution Reduction
These links are posted by LEEDuser with USGBC's permission. USGBC has certain usage restrictions on these forms; for more information, visit LEED Online and click "Sample Forms Download."
Construction Submittal
Documentation for this credit is part of the Construction Phase submittal.



144 Comments
Site Boundary, SWPPP and Erosion Control
My firm has built an Athletic Field house for a local school district. SWPPP and ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation plans were created and followed accordingly. Now here is where it gets complicated. The whole parcel of land (school building, parking lot and adjacent fields) prior to any demolition or construction was subdivided and all but 3.2 of the 8 acres was sold to the Town. Our LEED site is only our proposed building and a little bit of the surrounding grass areas on the 3.2 acres( this is documented in a separate drawing being uploaded for the credit). The Town has developed the rest of the parcel with athletic fields, a playground, parking (including parking on the school owned portion of the parcel)and a small maintenance building also housing small toilet rooms. The Town funded and built all of this including the parking lot for our LEED building since the parking lot served their portion of the parcel as well. The Town funded the design of the SWPP/ESC for the entire parcel of land including our LEED building. Therefore, all of the SWPPP/ESC plans are for the entire parcel of land not just our LEED site. Since there was an existing building on the Town's portion of the parcel there were several stages of SWPPP/ESC plans designed and implemented to suit which phase of demolition/construction was going on at that point in time. All calculations are also done for the parcel of land as a whole not just our LEED portion. My questions are as follows:
1. Can the SWPPP/ESC plans be submitted as they are with the whole parcel of land on them? Can it be as simple as just highlighting our LEED site area on their SWPPP/ESC plans but, leaving the whole document in tact otherwise?
2. If question #1 if the asnwer is yes they can be submitted as a whole parcel of land then for credit SS6.1 should we be entering water runoff calculations for just our LEED site (which contains no drainage wells etc. since the parking lot is not included in the site) or the site as a whole including the Towns portion?
Note: The Town did not fund any kind of LEED certification for their portion of the site. Only the school district is trying to achieve LEED certification for their building.
LEED after construction has begun
Hi all,My company received a request for proposal to work as LEED assessor for three office buildings under core and shell (Three different plots in different streets). The owner decided to achieve LEED after construction has already begun in the three buildings ( 1st excavation is done - 2nd 2 basements levels slabs are constructed - 3rd all structure skeleton is constructed). Sites awaiting all the LEED requirements in order for the contractor to make a variation for the modifications. Can we apply these buildings to achieve LEED certification, or due to construction start without the requirments of SSP1 we would not be able to proceed? as the constractor did not make any sedimentation or erosion procedures on the site. Did anyone face this situation before or passed through any reference regulating this? Thanks in advance.
Diaa, this is one of the frequently asked questions (FAQs) we get on this credit, and we have a good answer in the FAQ section of the BIrd's Eye View tab above. I'd recommend joining the site to get access to this and other guidance!
Compressed Natural Gas Excavation Equipment
Can anyone tell me if there is a LEED NC credit that would "reward" a project for using Compressed Natural Gas in excavation and other construction equipment? I can not decide what this might fall under other than this pre-requisite and I'm not sure it even helps here. Thank you.
Janna, I don't think this is relevant in helping you earn SSp1, although it doesn't hurt. I don't see another credit where it's relevant. However, you should check out the new pilot credit on clean construction, which you could use for an innovation point.
Thanks Tristan. PC 75 Clean Construction exactly addresses what the project wants to do. Looks more like requires writing a plan instead of actual tracking, though. It says to submit number of hours used (if available). *(no comments under LEEDuser PC 75 yet, so I may need to start a thread there.)
EPA guidelines applicable to KSA
We are working on a project in city riyadh of Saudi Arabia.There are no local codes available for the site. Further more i checked the CGPEPA's Construction General Permit. Outlines the provisions necessary to comply with Phase I and Phase II of the National Pollutant Discharge Elimination System (NPDES) program. guide lines its not mention anywhree if i can use the guide line of CGP for KSA. Please guide me which codes do we use.
Also, if we can use the CGP guidelines, for the implementation we only have to comply with the Sec 2 .
Thanks.
I came across CIRCredit Interpretation Ruling. Used by design team members experiencing difficulties in the application of a LEED prerequisite or credit to a project. Typically, difficulties arise when specific issues are not directly addressed by LEED information/guide for a project in Giza, Egypt where ruling says it is acceptable to limit the construction pollution prevention plan to best practices in dust control and wind erosion. Any how the precipitation in Doha is almost twice that Giza. So you need to calculate if there are potential runoff from the site and work out of the plan accordingly
Alternative for ESC plan in hot climate zones (Outside the US)
We're applying for LEED for New Construction in Doha, Qatar.
The question is: where can I find information about the alternative of ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation plan? since the rain in this zone -hot zone- is not a concern at all.
Is there any alternative path? Any similar cases? any Ideas?
Eyad, I would recommend starting with LEEDuser's guidance above (you'll need to log in as a paid member to view this content). Your specific question isn't answered, but after reading the guidance there and samples in the Documentation Toolkit, you'll have a deeper understanding of how to earn this prerequisites in non-U.S., non-conventional situations.
Dear Babar & Mehmood
I came across CIRCredit Interpretation Ruling. Used by design team members experiencing difficulties in the application of a LEED prerequisite or credit to a project. Typically, difficulties arise when specific issues are not directly addressed by LEED information/guide for a project in Giza, Egypt where ruling says it is acceptable to limit the construction pollution prevention plan to best practices in dust control and wind erosion. Any how the precipitation in Doha is almost twice that Giza. So you need to calculate if there are potential runoff from the site and work out of the plan accordingly
Thanks for the info Bazeeth. The averagre rain fall in giza is about 27 or 28mm approx. in August max and min is approx. 2 or 3 mm and all over the year average rain fall is approx. 6 mm (0-25mm) while in Riyadh the average rain fall all over the year goes to 9mm. In Case of Doha, the average rainfall throughout the year is apprxo. 78 mm ( 3mm-78mm). So, the average rain fall is 3 times the Doah's one. This means we dont have to care about the rainfall problem since it's very minimal in riyadh. Only have to do some soil stabilization solutions, i think. Need your advice. And one more thing. We will still use the CGPEPA's Construction General Permit. Outlines the provisions necessary to comply with Phase I and Phase II of the National Pollutant Discharge Elimination System (NPDES) program. guidelines or we are going to use 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 for this case. Thanks,
Regards,
Babar
Topsoil
Could anyone please advise, whether the project would fail to achieve the SSp1: Construction Activity Pollution Prevention, if approx. 10,000m3 of topsoil is removed off the site and replaced it by new topsoil (Purchased from other site and more nutrients for plants).
Or any other credit that may have impact due to replacement of topsoil?
I referred to below requirement which highlights on protection of topsoil for reuse but does not give any details in terms of above mentioned strategy.
"Prerequisite 1: Construction Activity Pollution Prevention
To prevent loss of soil during construction by stormwater runoff and/or wind erosion, including protecting topsoil by stockpiling for reuse"
Thanks & Regards
Ameet, site disturbance has an effect on other credits like SSc1, and SSc5, as you know. In terms of the technical question you're asking here, start with the third FAQ posted above and see if that helps.
Thank you Tristan, I received following reply from Green Building Certification Institute,
"Thank you for contacting the Green Building Certification Institute about SSp1 if removing soil and placing new
material. There is nothing preventing the project team from either removing unwanted soil from a site or purchasing
and placing new soil. The focus of SSp1 is on protecting soil on the property from being blown or washed away,
thereby causing dust or polluting nearby watercourses or sewer infrastructure"
Ameet, I realize this reply may be coming a little late...but if you have not already hauled this topsoil from your site, consider doing a soil ammendment or a blend, reusing the original topsoil.
It will probably save you some money on earthwork and the hauling.
I am not a soil scientist, but I've always been taught that soils are the most cohesive when they remain "where they came from."
Of course, I am assuming there is no contamination or other reasons to haul the existing topsoil off site.
Be sure to check local regs... most have provisions for removing sols from a site.
Thank you Michael.
Is the SWPPP required?
Dear All,
I am working on a project outside the US, where there are no local standards regarding ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation measures (the local codes are rather too general and do not address the requirements of this prerequisite).
I understand that we have to do an ESC plan. However, do all projects need to produce a StormWater Pollution Prevention Plan (SWPPP)?
What are the criteria to determine whether a SWPPP is required or not?
Thanks!
Sounds like your project will be following the path equivalent to "create and implement an Erosion and Sedimentation Control (ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation) Plan that conforms to the requirements of the 2003 EPA Construction General PermitEPA's Construction General Permit. Outlines the provisions necessary to comply with Phase I and Phase II of the National Pollutant Discharge Elimination System (NPDES) program. (CGPEPA's Construction General Permit. Outlines the provisions necessary to comply with Phase I and Phase II of the National Pollutant Discharge Elimination System (NPDES) program.)" for LEED, since you do not have a local code that is more stringent. There are resources that describe the CGP process (http://cfpub.epa.gov/npdes/stormwater/cgp.cfm),
and SWPPP templates that compliment compliance, as this is usually one element required by the permitting authority.
You may be in a gray area because LEED has not identified specific standards for judging compliance with CGP.
As long as the project is actively implementing an ESC plan during the development of the project site, you should be okay.
Thanks Lisa,
So in principle, if the local authority doesn't require a SWPPP, then the USGBC is fine with only implementing an ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation Plan. Correct?
LPE for QSD
In California can a Construction General PermitEPA's Construction General Permit. Outlines the provisions necessary to comply with Phase I and Phase II of the National Pollutant Discharge Elimination System (NPDES) program. Qualified SWPPP Developer (QSD)
sign a LPE instead of a registered civil engineer?
Ida, the LPE requirements are pretty specific, however, this seems reasonable. You'd need to get GBCI approval, though. I'm not aware of any guidance available for a question like this.
date stamped photos
LEED online requests the following: Provide date-stamped photos showing the measures taken, including any corrective action, to effectively implement the ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation plan. Include at least 3 photos from at least 3 inspections equally spaced over the site work period. Inspections must occur monthly, at a minimum.
Does the last sentence mean that you need date stamped photos once per month over the entire construction period?
It may become clear when comparing what is states when you check "builder or contractor declaration", which then brings up the following statements:
..................................
Upload SSp1-2. Provide a summary, sample log, checklist, inspection
report, or similar document that demonstrate periodic inspection of the
implemented measures. This documentation must include:
· Sample dates
· Inspection frequency (at least monthly, year-round)
· At least 3 inspections equally spaced over the site work period
· Descriptions of any corrective action taken.
........................
It seems to be adding "monthly" to the "site work period" only.
We are not checking "builder or contractor declaration", we are checking "The project team provides date-stamped photos which show the
implemented measures and any corrective action that was taken."
I was wondering if anyone has run into GBCI reviewers requesting monthly date stamped photos using this option, or what the frequency of the photos should be. Thanks for any input.
Michael,
This really depends on the length of construction, that's why there are no specific requirments for length of time between photos. I suggest evenly spacing them throughout construction (start, middle, end), so you end up with at least 3 different dates with photos.
We solved the issue of date stamping photos for ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation and IAQIndoor air quality: The quality and attributes of indoor air affecting the health and comfort building occupants. IAQ encompasses available fresh air, contaminant levels, acoustics and noise levels, lighting quality, and other factors. MP where our new camera did not offer the option of digital date stamping for JPEGs by an easy to use software program called Gena PhotoStamper that date stamps photos and photo batches.
You can find more information on this software at
http://gena-photostamper.software.informer.com/
documentation
Hi! Were in a beginning of documenting ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation measures, and we have to define what the constractor should provide as evidence. Do I understand right, that for documentation you need the ESC plan, and ETHER photo log, EITHER sample inspection reports, EITHER a narrative? Have you encountered a problem, where you provided one kind of evidence and some other was requested by the reviewers? thx
You have correctly listed the "or" options: a) builder/gc declaration and upload; b) date-stamped photos with min. of 3 equally spaced over site work period; c) narrative describing ESC implementation. If one option is documented adequately, the reviewer should not direct the team to take on another option also.
Requirements of this madatory credit for India based projects
I would like to understand how to approach this prerequisite for projects in India and other similar countries where EPA guidelines will not be applicable. Will USGBC accept the local norms and related documentation. The project will go for USGBC LEED NC 2009 certification.
Hurricane/Tropical Storm Damage
As most are fully aware, the east coast was severely hit by Tropical Storm Sandy. I am currently working on a LEED job that was completely flooded and damage was done. Has anyone else experienced a similar situation and how should it be addressed for LEED Documentation?
Hi Megan,
I'm sorry to hear this. It wasn't a project I worked on directly, but my co-workers at Lake/Flato Architects had a LEED project that was hit by Hurricane Rita while it was under construction (Shangri La Botanical Gardens). I believe they actually got an innovation credit by using all the felled trees on the property for structure and furniture. I'd be happy to put you in touch with the Project Manager and LEED Consultant from that project. My email is heather@greence.com
Megan, I'm sorry to hear about this. This kind of issue is not anticipated in any specific LEED requirements, but neither should it present any insurmountable obstacles that I can think of. Please post here or on specific credits if there are problems you're running up against.
ESC plan implemented after or at the commencement of excavation?
Hi All,
we are wondering if the general contractor should implement the ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation at the same time of the leveling and excavation works begin, or if it could done after? Or is it ok if only a few relevant strategies and solutions are used for this early phase, and then the remaining part of the ECS are implemented?
Thank you.
Valentin, it seems that something is going unsaid in your question. Is there some issue on the project with full implementation of the ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation? LEED asks you to create and implement an ESC. If there is some issue with that plan not being fully implemented, you might have an issue.
How long must we follow thru on erosion control log?
Our building and site is complete except for the grass. It was hydro-seeded last week but the grass that has taken is less than 75%. Can the CM stop logging in order to submit for Construction Review or must the grass be over 75% before we can submit?
Donald, I have more insight into the LEED process than I do into the specifics of the erosion control method here, but I hope the following helps.
In short, if watching grass grow is holding up the entirety of your LEED submission, then go ahead and move on. LEED wants to make sure that you have an ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation plan and are implementing it—there is no specific requirement to have it implemented to a certain degree before you can submit.
Zero lot line existing building renovation
This project is a re-skin, and interior re-fit. Complete preservation of the structure. There was no site soil distrubance. What is required for SSp1 documentation?
Kim, I am working on a project with a similar situation. Your ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation plan may be minimal, but you will need to create one in any case. It may be simply a matter of showing how you are dealing with dust etc during the re-skinning. In some cases with existing building renovations with no site work, we have seen teams focus the ESC plan on any exterior building cleaning activities, such as using non-toxic substances and high pressure washes on the exterior with protective rip-rap on the closest stormdrain to keep the wash from picking up debris. It might also be beneficial to mention in your ESC plan how the typical erosion, dust, and site work will not apply for your site type as an interior retrofit.
Add information on construction lay down / staging areas.
Contractor documentation of compliance
Construction of our project has been completed and ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation plan was followed. We have the superintendant's log reports for all the days silt fence was checked or fixed. The logs do not include much information other than "silt fence installed" and "silt fence checked".
Will this documentation be sufficient?
There is no place for a contractor's initials (as in other credits where constractor is verifying compliance). Can I upload the documents or does the contractor need to in order to document where they originated?
I hade recently posted a question and finally discovered my own answer, but I will first respond to yours as it is missing crucial information. If your project was on a relatively flat and geographically isolated lot, your reports may be just about all you need. There should be other related notes in there also that you may be overlooking. This assumes that a silt fence was the only control method sitted as required in your ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation.
Otherwise most standards require that your notes track or mention each of the critical control points (ie dust control, site runoff water/dirt/rock, and a few others.
On a minimum this should have included an entry and exit point with some method in place to reduce and prevent runoff. A perimeter fence with dust shield tarps applied and a silt fence at a min 3 ft offset. They should also mention dust control as being either temporary cover of rock or frequent water truck applications.
The site is not geographically isolated, but rather in a relatively urban area. It is a very flat previously developedPreviously developed sites are those altered by paving, construction, and/or land use that would typically have required regulatory permitting to have been initiated (alterations may exist now or in the past). Previously developed land includes a platted lot on which a building was constructed if the lot is no more than 1 acre; previous development on lots larger than 1 acre is defined as the development footprint and land alterations associated with the footprint. Land that is not previously developed and altered landscapes resulting from current or historical clearing or filling, agricultural or forestry use, or preserved natural area use are considered undeveloped land. The date of previous development permit issuance constitutes the date of previous development, but permit issuance in itself does not constitute previous development." site. Yes, our ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation also requires inlet protection, rocked construction entrance, and dust control. The inlet protection was also documented in the daily logs. The contractor actually chose to leave the existing asphalt entrance drive in place to use as their construction entrance. When it was finally removed, rock was placed back the very next day. As far as dust control, there really wasn't an issue as we had a very wet spring. Also, the scheduling of the earthwork and the placement of the base course aggregate was within a couple days of each other.
Should I write a summary of these other items not covered in the log reports?
Dust control - standards applicable in the US
Hello,
Concerning dust control, are there any standards applicable ?
The document "CGR2003 entire permit" mentions: "3.4 Pollution Prevention Plan Contents: Controls to Reduce Pollutants : G, The SWPPP must describe measures to minimize, to the extent practicable, off-site vehicle tracking of sediments onto paved surfaces and the generation of dust."
... or LEED requirements are only focusing in implementing BMPBest Management Practice without quantitative criteria regarding dust.
Thanks
Loic, I am not aware of any specific standards that LEED references regarding dust control.
What are the requirements for the inspectors?
We are completing a high-rise in Surfside, FL and we fall under the jurisdiction of FDOT, FDEP, and the EPA as this is a Beach side construction. But can anyone act as the inspector or are there minimum requirements? Where are these listed?
Well I answered my own ????. The FDOT standards indicate that a "qualified inspector" should be completing the inspection reports for onsite CAPP. They also define this persons requirements. Please keep this in mind as it is apparently a common place note that assigns this duty to a GC, which generally doesn't fall within these requirements. This can be confussing down the line..
Compromise between Dust Control by Watering & Water Consumption
The best way I experienced in dust control measures in construction roads is to cover these roads by crushed stone, compact it by the compactor, and finally water it frequently. This reduces dust generation occur by construction trucks and vehicles use these roads during construction.
The challenge you may face is how to compromise between the need of water for watering the roads and the rationalization of water consumption particularly when the project is located in a country has no recycling water system and the water connected to the project is potable.
Any alternative measures?
First of all plan well for it "construction sequencing and disturbing only small areas at a time can greatly reduce problematic dust from a site"
Then look at the control measures, to avoid using excessive water issues, you can go for strategies such as: " Vegetative Covers, Mulch, Wind Breaks, Stone and Spray-on Chemical Soil Treatments"
Hope this helps
Surely it helps. Thanks. But I am afraid that these other options you mentioned are not suitable for construction roads with heavy trucks, loaders, and tractors passing on it.
Date Stamped Photos
Dear all,
There are many cameras which do not print a datestamp on the photos (new cameras usually save the date in the photo properties).
Can the person who captures the photos, manually put the date on each photo? I know some people might be able to report a false date, but I do not see any other alternative..
Thanks!
Hi George,
It is possible that photographs without the date stamp from the camera may not be accepted during the review. The latest version of the form (v04) allows two alternative documentation options if you don't have date-stamped photographs: a) a narrative describing the ESC plan implementation, or b) a builder declaration of periodic inspection and documentation of ESC implementation.
Air Pollution Prevention
This week I have had two projects returned to me from the preliminary construction review with the same comment. I have never seen this comment before and am a little perplexed. The comment states that it is unclear if the plan includes the proper measures for the prevention of air pollution (dust and particulate matter) and the technical advice is to provide a detailed narrative describing the measures taken for the prevention of air pollution. In both instances, our plan included the gravel construction entrances/ exits, which used to be enough to satisfy this portion of the credit. What else do we need to prove compliance? There was also some watering of the site that happened that we will include in the narrative, but I'm wondering if there is something that I'm missing? Does anyone else know of strategies that the reviewers are looking for?
I received the exact comment on 8/12/11. The following information was added to the narrative and the prerequisite was earned:
During initial excavation and placement of the foundation a water truck was on site daily to keep all soils to be disturbed moist, preventing dust from entering the air. As soon as the foundation was placed, all parking lots were completed to stop dust from being generated on the project by future construction traffic. The water truck was used daily during parking lot construction. Landscape areas were not disturbed until final construction was completed and then grass sod and mulch were placed to stop any run-off of mud or dust generation.
Level of detail needed in ESC?
This is vaguely referenced in other posts, but I'm still confused: what is the level of detail we need to submit for our written Erosion & Sedimentation Control (ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation) plan? The example in the LEED Reference Guide shows a table with 6 strategies listed alongside their descriptions; the example SWPPP found through the EPA website is a 56 page document (http://www.epa.gov/npdes/pubs/exampleswppp_smallcommercial.pdf). That is a huge discrepancy! What is the level of detail that LEED is looking for in our submitted plans?
The civil engineer on our project put together a written plan complete with site drawings of silt fences, etc. and is expressing concerns about putting together a full SWPPP, which will understandably take up a great deal more of his time. Can we submit his one-page plan?
Patty, LEEDuser recommends an ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation plan like the examples posted above in our Documentation Toolkit.
LEED requires that you “Create and implement an erosion and sedimentation control plan…The plan must conform to the erosion and sedimentation requirements of the 2003 EPA Construction General PermitEPA's Construction General Permit. Outlines the provisions necessary to comply with Phase I and Phase II of the National Pollutant Discharge Elimination System (NPDES) program. OR local standards and codes, whichever is more stringent”.
This means that, at a minimum, you must develop a ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation, a "SWPPP", per EPA’s NPDESThe National Pollutant Discharge Elimination System (NPDES) is a permit program that controls water pollution by regulating point sources that discharge pollutants into waters of the United States. Industrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters. General Permit. SWPPP contents are listed in Part 3. See the link below:
http://www.epa.gov/npdes/pubs/cgp2003_entirepermit.pdf
You must check the State requirements, since many States have been granted the authority to issue individual permits (e.g. New York’s “SPDES” General Permit – an NPDES approved state program). Depending on the jurisdiction, the SPDES could be “more stringent” and therefore, take precedence when preparing the SWPPP.
Please note, regardless of LEED, you will need to prepare and submit an NOI with the Permitting Authority when your project exceeds the acreage reference in the General Permit.
A client with ongoing site works asks about LEED feasibility
The owner of a project is considering the possibility of the project to become LEED Certified. The current works on site include a excavation of a hill, and the works had been conducted following local codes that don't include many practices required by EPA CGPEPA's Construction General Permit. Outlines the provisions necessary to comply with Phase I and Phase II of the National Pollutant Discharge Elimination System (NPDES) program. / NPDESThe National Pollutant Discharge Elimination System (NPDES) is a permit program that controls water pollution by regulating point sources that discharge pollutants into waters of the United States. Industrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters. or good practices according with LEED.
As the project is in the very first stage, I found reasonable the position of the project owner to become LEED, as much of the work is yet to be done. Once he make his decission, a regular ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation plan will be in place, and will do the best corrective measures if needed.
In this point, I need some comment. This ESC Plan and corrective measures will be enough to be accepted by USGBC to the prerequisite SSp1, even if in the first months of work there have been less comprehensive control measures and not so much documentation? Considering that most of the works on site will be covered by the ESC Plan, I need to be sure that we won't have any problem complying with the Pre-requisite, as it's mandatory to gain LEED Certification. Any comment on former experiences will be much appreciated.
Same as below. I would begin to implement a plan immediately and follow-up with GBCI directly for confirmation. I would expect that you would be o.k., but that is something for the GBCI to confirm.
Thank you Steve.. To find this confirmation of GBCI, should be via 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 just ask by mail once the project is registered? What's the better way? Thank you in advance.
Mauricio, I would start with an email to GBCI as that won't cost you anything.
Late implementation no.2
Hello all,
I have another question regarding late implementation of the EPA’s requirements.
Our project is a shopping mall in Prague, Czech Republic. The client considers LEED certification; however demolition works have been already done (e.g. site clearance, trees removed) without required ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation plan and also without necessary photo documentation.
Considering that the major ground works will be done according ESC plan, it could be little odd not to be eligible for the whole LEED certification.
Thank you for any suggestion and help!
NC Major Renovation with minimal site disturbance
Dear LEEDUsers,
We are working towards certifying our own office building (an existing 50 year old, single story structure of ~7,000 sf on a 0.64 ac lot). We initially registered it as CI&D and now realized that we do not really fit into this category (miscommunication with our LEED AP consultant). We are now aware that we need to re-register as BD&C, which requires satisfying prerequisite 1 in Site Selection Section.
The project is 2-years old, because we are doing most of the work (design, drawings, and some installations) in-house, the progress has been slow. Site elements have been complete long ago, without implementing any sediment control measures. But, because the site is existing, there were only two instances of site disturbance that occurred:
1. Landscaping (pulling up some lawn, and placing flagstone, decorative plants, and mulch) - complete in a few days, during a dry weather period.
2. Pulling up a 15'x45' piece of paving, former parking area (waste was placed directly into the truck for removal) and filled it with organic soil for gardening. This portion was complete in early spring, which soon after was turned into a communal employee garden.
The question is, because of purely aesthetic site disturbances and the size of total property (less that 1 acre), is the erosion and sediment plan required? And how do we take on the satisfying prerequisite 1?
Thank you,
Monika
You will still need to have an ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation plan that addresses what measures were / will be taken when those minor site improvements take place, and any other site impacts from construction like vehicle traffic, etc. You may want to fill out the Special Circumstances narrative in the prerequisite form to describe how you dealt with ESC in this existing, major renovation project. However, you will not be exempt from the requirement.
SSp1 / ESC plan and the Multi-Building Campus Guidance
Hi there -
I'm working on a 4-building office campus that is being developed all in one phase. The current plan is to certify each building individually and use the Master Site documentation process. Does anyone know why, in the new Multi-Building Campus Guidance that was recently released, SSp1 is designated as an Individual building credit instead of eligible for the Master Site documentation? This project has just one campus-wide ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation plan, which is what the City required. I would think this is a perfect credit for the Master Site documentation process. Do I just upload the same site-wide ESC plan four times to the individual building LEED Online profiles? We wouldn't be required to create new, building-by-building ESC plans just for LEED, would we?
I can't speak to why the prerequisite was omitted from the new guidance, but I would expect that you could still use essentially the same plan and make minor adjustments to the plan for each building.
We have the same situation. It seems like the Campus guidance assumes that buildings will be built individually over a period of time by separate teams. If multiple buildings are being bid and constructed at once, it would seem logical that a general site ESCP (with building-specific details) would be appropriate. However, I have seen no formal information or ruling on this. Anyone else?
Late implementation due to temporary cancelation of project
Hi everyone! Here's a tricky one...
I am a little confused about the possibility of achieving SSp1 on a project. This project started grading activities on 2009 advancing about 50% of these activities. After that the project was cancelled and in 2011 the owner decided to continue the construction activities, making a lot of chages to the design of the project and deciding to certify it.
Is it possible to comply with SSp1 considering that no or minimum ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation activities were made from 2009 to 2011?
I would really appreciate your help.
Sounds like many things are interacting that may lead to the project being defined by some milestone after the redesign, or considering some portions of the site to be "developed". It is also important to understand the local regulations that have been in effect while this work was done, as they may be equivalent to the EPA requirements for erosion and sedimentation control since clean air and clean water acts influence many municipal policies.
As long as the project has been actively implementing an ESCAn Erosion and Sedimentation Control (ESC) plan is a collection of measures designed to reduce pollution from construction activities by controlling soil erosion, waterway sedimentation and airborne dust generation plan during the current development of the project site, you should be o.k. The history of the site shouldn't be an issue, just what has been done since LEED has been set as a project goal in the current phase of the project.
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