NC v2.2 MRc2: Construction Waste Management

Daniel, unfortunately this is not permitted by the LEED rating system. See a similar situation in LEED Interpretation ID#2316 by logging into the USGBC.org website.

You could still achieve the EP point with just the one building if you reach 95% diversion. In fact, adding another building wouldn't necessarily help you get there since the point is awarded based on percentage and not on absolute quantity diverted. Depending on your location in the country, some CW haulers/recyclers can achieve this level of diversion.

Having said all of that, I certainly don't want to discourage waste diversion on the adjacent project! It just won't contribute to your LEED project...

I would count it for this credit. It seems to meet the intent of diverting something from the landfill that might otherwise be a waste material. (In practice, of course, it's very unlikely that this would be a waste material—but the credit threshold is set pretty high.)

Kathy, I would propose that this is an acceptable method for tracking the asphalt. First, it is absolutely fine to re-use the asphalt off-site and still count it toward MRc2 (http://bit.ly/tHoTZe LEED Interpretation ID#2464).

Second, there are several indications in the reference guide that support a calculation like that you suggest. MRc1 allows building re-use to contribute to MRc2. The actual language on pg. 352 of the 2009 BD+C Reference Guide (sorry, didn't have my 2.2 handy) is "determine an approximate weight or volume for existing building elements." This establishes precedent in my mind for counting materials that cannot be physically measured for volume or weight. Also, as mentioned in the post below, each version of the Reference Guide has included a volume to mass conversion table which also supports this approach.

The only other idea that is out there would be to actually calculate the volume/weight of the asphalt using trucks with load cells or known volumes during transport. Please let us know how this gets resolved!

There is no specific conversion factor for materials that is accepted by LEED. In the LEED-NC v2.0 Reference Guide (blow the dust off that one!) solid waste conversion factorsEstimates are presented in customary U.S. units. Floorspace estimates may be converted to metric units by using the relationship: 1 square foot is approximately equal to 0.0929 square meters. Energy estimates may be converted to metric units by using the relationship: 1 Btu is approximately equal to 1,055 joules; one kilowatthour is exactly equal to 3,600,000 joules; and one gigajoule (109 joules) is approximately 278 kilowatthours (kWh). were listed:

Mixed waste 350 (lb/cy)
Wood 300
Cardboard 100
Gypsum 500
Rubble 1,400

Conversion rates are typically not questioned unless they seem outlandish. It also helps that you're citing reputable sources for your conversion factors.

Alicja, I tried to re-create your issue by entering figures in each category under “Disposed in Landfill” on the Tracking Sheet but I could not duplicate your error message. It is working well. Is there any pattern as to when it triggers the error, such as a particular month or way the figure is entered that is different from other entries?

Tristan from LEEDuser would be the one who could answer your request about making the unlocked version available.

In the meantime, if you don’t figure out what is creating your input error, you could always re-create the Tracking document in-house using this one as the template, which I know is not the quickest fix!

On our MRc2 credit we were asked to "Clarify". In the "Technical Advice" it reads: "Please provide documentation from the state regulating body stating the facility's average recycling rate. Alternatively, provide project-specific diversion rates".

The project we built is in Aliso Viejo, CA where it is mandatory that "CR&R" is used as the waste hauler. CR&R sorts and recylcles all the trash and construciton debris. I was getting quarterly reports from them listing the average diversion rate for each quarter. We submitted these but obviously these were'nt good enough. I have spent several days trying to find something from the State of California and have spoken to people at Calrecycle but no one seems to know where I can get "State Documentation" regarding the average recycling rate. Can I get some help on this?

Karen, if you have folks at the state cooperating with you, perhaps they could provide some sort of letter or inspection documentation backig up CR&R's numbers?

Does WA have a state wide manadate regarding minimum watse diversion rates that should be achieved by all contracted MRF and recycling facilities? In our experience, using the mandate to demostrate waste diversion rates has been successful though this number is much lower than what would have been the actual diversion rate for the project. On a different note, using the facility diversion rate number as reflection of construction waste diverted can be a problem expecially in cases where waste is commingled and sorted as the percentage of waste diversion can be from other commercial waste sources that is not typical to a construction site.

No, there is no state wide mandate just non-metric goals and priorities in the regulation. And yes, understood that monthly commingled diversion has its issues, but it is the predominant method on our sites.

We have 25+ certified projects representing every rating system, and all of them have achieved waste diversion points in the past based on this same documentation.

We are really struggling with how to deal with requirements that seem to change once they get in the reviewer's hands and end up penalizing projects that have been doing the "right thing" all along usually at some expense.

Obviously a project cannot change it's construction practices when it's already complete so we have to rely on the reference standards, manual and addenda to guide projects throughout design and construction. Can you point me toward where this regulatory requirement is spelled out so that we can advise ongoing and future projects?

Unfortantely there is no standard regulations unless the local goverment has something in place. Solid Waste is very much dependent on where you or your project is located and the rules there. In your situation where it is after the fact, the only option that may be of help is if some way you can track down records showing the MRF's average monthly diversion rates and attach with it a narrative that describes the MRF's sorting process and their partner recycling centers. It is unfrotunate that USGBC is using a blanket approach for documentation when the reality is that the whole solid waste industry is far from being a standard process.

I agree Michelle that more clarity is needed from USGBC on this regulatory requirement for comingledA process of recycling materials that allows consumers to dispose of various materials (such as paper, cardboard, plastic, and metal) in one container that is separate from waste. The recyclable materials are not sorted until they are collected and brought to a sorting facility. waste. We learned from a large national waste firm that they have attempted to get some interest in establishing industry standards that will meet this concern but have not received any support.
Just to make sure you are aware, the requirement itself is found on the v3 LEED Credit Form on LEED Online when you select "Comingled" in the data Table. That then triggers a new Comingled section to appear with this specific documentation upload requirement I have pasted below. It simultaneously triggers a new Comingled box to also appear in the Upload section with the same comingled upload requirements. It would be nice if this information did not take such sleuthing to find!
Below is the LEED credit form language:

Upload MRc2-2. For commingled waste provide documentation verifying the diversion rate of the waste. Documentation can be either a project specific diversion rate provided by the sorting facility or the average annual recycling rate for the sorting facility provided by the regulating local or state government authority.

I interpret the “project specific diversion rate” to be free of the regulating authority requirement, since it is actual separated waste weights or volumes specific to that project. Does anyone have reason to believe differently?

Hi Valerie,
Thanks for the response. Yes, I am aware of the template statement which echoes the 2005 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 they are using. It is, however, very unclear to me why such an "old" requirement has not been incorporated in the 2009 reference manual.

Like you, we advise clients during design and construction about LEED requirements, so we need to be able to rely on the reference materials published at the time of registration. Instead we are encountering more and more review comments that say "in future projects do this..." and requirements that appear only on templates. We actually didn't think that was possible in the "no precendent setting land of review comments and CIRs of old".

We understand that the online platform is more flexible than hardcopy resources, but we are getting the feeling that GBCI is out in front of USGBC rather than aligned. That's like trying to build a building when the code keeps changing along the way.

Yes, you are correct. The project specific diversion requirement is free of the regulatory issue. I have a project that just got reviewed that successfully took that approach. However, in WA 95% of our projects use commingled diversion rates. We have 8 projects currently in progress that will be penalized for doing the right thing that has been acceptable for others for the past 6 years.

Change and evolution of requirements are necessary and acceptable, but the rules of play need to be set at the beginning of the game or eventually there are going to be a lot of disgruntled players. The greatest value of LEED is that it creates a context in which green buildings can be compared apples to apples and encourages people to strive to implement sustainable measures they can quantify and understand. We are trying to raise all boats, right? These kind of midstream changes and surprise requirements that appear when it's too late to course correct are creating vast frustration and negative reinforcement for our clients, who then may not bother to attempt this next time.

Keith, is recycling into asphalt for roads an option? That's the best idea I can think of.

Katherine, I would say you could apply this to MRc2, but only if the paver blocks are diverted from the waste stream after construction. Perhaps through donation to a salvage store, another construction project, or take them to the GC"s next project?

Linda, you mention your CWM Plan but I am wondering what you provided for your uploaded backup documentation for the comingledA process of recycling materials that allows consumers to dispose of various materials (such as paper, cardboard, plastic, and metal) in one container that is separate from waste. The recyclable materials are not sorted until they are collected and brought to a sorting facility. waste. Did you include the verification document for the recycling facility the Contractor and hauler used that shows it is regulated by a local or state government with regards to the annual recycling rates being claimed? If not, perhaps that is the trigger. If the facility is not regulated but your recycled waste was sorted and weighed for your project specifically, I would certainly resubmit the credit and provide a spreadsheet from the sorting facility listing the recycling destinations for the various specific waste streams the project had. Sounds like the reviewer needs assurance that the waste ended up at appropriate recycling facilities following the facility sorting exercise.

None of the LEED reference guides provide guidance on comingling requirements or documentation. Can you upload a sample of the "verification document for the recycling facility the Contractor and hauler used that shows it is regulated by a local or state government with regards to the annual recycling rates being claimed" that you speak of?

Linda - Per your request, we are looking to find a comingledA process of recycling materials that allows consumers to dispose of various materials (such as paper, cardboard, plastic, and metal) in one container that is separate from waste. The recyclable materials are not sorted until they are collected and brought to a sorting facility. verification document sample for you that is not confidential. In the meantime, you might request it of a recycling facility that is accustomed to documenting this way, even if it is outside your region.
By the way, you mention that none of the LEED reference guides gave you the comingled verification guidance that I mentioned. It is found on the v3 LEED Credit Form on LEED Online when you select "Comingled" in the data Table. That then triggers a new Comingled section to appear with this specific documentation upload requirement. It simultaneously triggers a new Comingled box to also appear in the Upload section with the same comingled upload requirements. It would be nice if this information did not take such sleuthing to find!

Thanks, Valerie, a sample would be really helpful to provide to our Contractors.

I agree 'sleuthing' as become an integral part of LEED documentation! As part of our LEED process management, we are now advising all Team members to refer not only to the reference guides, but to the LEED Online forms, as they have additional criteria that does not appear in the reference guide and/ or addenda.

We advise the same. Prior to the v3 Reference Guides, documentation requirements were fairly well defined. It still required cross-checking with the LEED credit forms, but the documentation requirements section in the v3 Reference Guides are a clear departure from v2 and are very non-committal. I find it takes playing around with various scenarios in the v3 LEED credit forms to trigger all of the options to open to be able to get a fuller understanding of the documentation requirements.

Linda,
We have a lot of projects doing commingled diversion and have seen these comments before. It sounds like you have three issues rolled up together.
The CWM plan is supposed to list the intended receivers for each type of recycled material you anticipate. Generally, that info comes from the hauler, and we see it most often as a standard looking page that they provide the contractor with their proposal.

The commingled documentation issue has two components. You can only use a monthly diversion rate in the template for your commingled waste if the receiver has a solid waste permit. That's the "verification that it's regulated" they are looking for. Then in addition, you need to upload the report that receiver issues that indicates their monthly diversion rate. As Valerie indicates, these permits and reports shouldn't be so hard to get. I could provide a sample but don't know how to upload documents to this forum for that purpose.

And boy, do I agree with you both about requirements on the credit forms. It makes things a lot harder to have some things show up online and can screw up bidders who didn't anticipate a requirement until they can get online and start trying checkboxes. And to add insult to injury things can get changed online midstream, making requirements different for different concurrent projects. Can be frustrating.

We too are looking for further requirements relating to the comingling of construction waste. We have been unable to locate the LEED Online template related guidance identified by Valerie Walsh on May 4th, 2011. Has the template been revised? If so, is there anywhere else we can look?

Anne,

It seems Valerie is describing some information that opens up in the credit form when you select comingledA process of recycling materials that allows consumers to dispose of various materials (such as paper, cardboard, plastic, and metal) in one container that is separate from waste. The recyclable materials are not sorted until they are collected and brought to a sorting facility.. Are you using the most up-to-date version of the form. If it is any version prior to v03 you should have your form updated. (You may lose information that is not one-to-one, so make sure you save everything first.) 

Generally the credit forms only show minimal information until you make selections. You could try downloading the static form from the Sample Forms Download page. The static version of the form should show you everything, then you'll be able to see which items to select within the live form on LEED-Online to get the information you're looking for.

Hope that helps!

It seems that this issue has largely been cleared up. Just to add my two cents:

If the materials were weighed off-site (commingled-site specific), you should provide documentation from the sorting facility with the project specific diversion rate (most easily evidenced by uploading the weigh tickets from the hauler or recycler).

If the value of waste was calculated using the average annual recycling rate for a specific sorting facility (commingled-facility specific), it is acceptable as long as the facility's method of recording and calculating the recycling rate is regulated by a local or state government authority as previously mentioned. To document this approach, provide a letter from the state regulating body with the facility's average rate of recycling.

I have examples of both of these documentation methods, so I'll see what I can do to get them uploaded.

An example provided by Jeremy (thanks!) has now been posted under the Doc Toolkit tab above.

Could you try having the construction workers sign a form (like an invoice) stating the quantity and type of materials they took off-site, and provide photographs of the scrap wood to accompany it? Maybe also include on the form a clause that they are signing to not drive it to the landfill (you could ask them to state what they will use it for - such as future construction jobs, home improvement projects, donation to charity...).

Seems like you need a reliable way to measure weight or volume. How about devoting a dumpster or plywood box with known volume to reusable wood, and when it it is full, note the measurement and open it up for workers to take home. There should be some safeguard that they are going to build with it, not burn it—perhaps you could document all of this on a sheet with the overall quantity, guidelines, and then have everyone who participates sign their name.

Carrie, "alternative daily coverAlternative daily cover is material (other than earthen material) that is placed on the surface of the active face of a municipal solid waste landfill at the end of each operating day to control vectors, fires, odors, blowing litter, and scavenging." for landfills is allowed under MRc2. The use you're talking about seems to have higher value than ADC, so I would assume it's allowed.

I would start by asking GBCI to add more rows. They are often receptive to this kind of request.

If GBCI will add more rows to the template Lisa, that will be the best solution. In the meantime, however, depending on your entry types, you could combine some of your ‘like’ materials and haulers to consolidate the available entry lines. For the few consolidated entries, I would then provide a spreadsheet detail that gets uploaded under ‘Other Documentation’. It is a bit of a two-step process, but this way you get the end calculations you need without a full duplication effort.

Good question Mary Lea. The credit definition for land clearing debris and excavated soil suggests that these are materials of an organic nature, as the Reference Guide specifically sites the exclusion of “soil, vegetation, and rocks” from the waste calculations. If the soil has been modified with Portland cement as you have suggested, then it would seem to fall closer into the category that is counted as construction waste for diversion, which includes asphalt, concrete, and masonry.

This would be a simple answer if your tagged materials were technically “hazardous” waste. Then, yes, it would be omitted from all of your credit calculations. Class 2 landfill material however is not as clear cut with regards to being defined as truly hazardous, as you indicated. If you believe that these materials cannot be reused or otherwise diverted and doing so is out of your control legally, then you can always make your case for excluding them. This would then be communicated in the narrative as a special circumstance or condition. I would not upload the DEQ documentation disposal directives in your application, but definitely have it in your files should it be requested.

Lisa, I tend to agree with your instinct that if the portables could be sold and kept in service, then they were probably not diverted from the landfill. If you feel you have a compelling case that they were in fact tagged for the landfill and the team proactively diverted that action, then it is up to you to consider making the argument. Then there would be two levels of diversion to consider: 1) the portables are being kept in service for some purpose and have been fully diverted, or 2) they are being deconstructed for salvage. If they are being sold for “parts” so to speak, then I would divide the salvaged from the land-filled portions for your CWM numbers. If you decide to make the case and claim the diversion, I would not count on it to achieve the credit, since it is up for interpretation and could go the other way.

Maybe I'm missing something, but what's to stop you from ignoring the "tons" shown on the spreadsheet in the toolkit, and just enter your figures in kg? The volume-to-weight converter wouldn't work, but you don't need to use that.

Tristan, I am having the same issue. I managed to unprotect the dropdown sheet and change the volume to weight to metric by using the appropriate formulas but I cannot unprotect the remaining sheets without a password. Tons is not the same as metric tonnes and I am worried this might confuse the Recycling coordinator. It would be useful to be able to unprotect the sheet and change the headings. Can a you let us know the password?

Paul, I don't see any obstacle to your earning the credit with the combination of onsite and off-site sorting. You simply have to adequately plan and document.

Yes, this material should be included. I can't think of a reason to exclude it—did you have one in mind?

We wanted to allow that very thing with furniture, even though the plan was to donate it to the local Habitat for Humanity ReStore. We loaded up all the furniture into a tractor trailer and ran it over a scale and then brought it back to the project site for employees to select/unload and purchase items with payments made to HFH. We tracked individual purchases for Habitat, but we were able to track the total weight of the donation as part of our waste management. Our local landfill was very willing to volunteer the use of their scale for tracking material weights whenever needed.

MRc3–7 are purchasing credits, in which furniture would have to be included consistently. MRc2 is a waste management credit, which doesn't relate to purchases in the same way. All waste generated onsite, including furniture-related waste, comes under the MRc2 requirements.

Thanks very much for clarifying. We will have the shipping materials from the new furniture, but we also have existing furniture that is no longer going to be used, so we want to be sure that we track everything correctly.

Trees cleared from the property would be land-clearing debris, yes, and not eligible for consideration.

In general - is any site material like site rock crushed and used as select fill at the site or for aggreate in concrete or site trees used as mulching for site landcaping or site furnishing accounted for in ANY Materials and Resources credits? I don't find terms like "material" and "site debris" clearly defined in the credit language.

Any help is greatly appreicated.

is crushed rock used as fill a regional material?

Chris, that's a lot of questions packed into one sentence. The answer to some of these scenarios (but not all) would be "yes," they do count. Check out our guidance on MRc5 and other MR credits about which CSI sections are counted. In particular check the Checklists tab under MRc5.