You're right, the manufacturer is wrong.

Angela,

Part of the confusion is because of the addenda posted on 7/19/2010. It says, in part -

"The extraction point for
recycled materials is the location of the raw material prior to the manufacturing of the final building product. As such, the point of extraction could include a recycling facility, scrap yard, depository, stockpile, or any other location where the material was collected and packaged for market purchase before manufacturing."

In the case of semi-finished steel products, that "collection point" could be a mill. For example, it's possible for the 'steel mill' to collect the scrap and produce billets which are then shipped to another 'rolling mill' to be made into basic rebar. That rebar could be sent directly to the jobsite OR to a fabricator who then 'manufactures' various assembled frames ready for installation. In that case, the billet producer could be considered the "recovery location" and the rolling mill or fabricator the final point of manufacturing.

Part of the logic is how the market works, since there are "bar mills" and rebar fabricators spread out all over the country and the vast majority (almost all?) of the 'scrap' can come from within 500 miles of the mill.

I am aware of one producer who tracks incoming scrap by zip code of collection location and can provide a percentage of scrap collected within 500 miles of the jobsite. The locations (perhaps dozens or more) within the 500 mile radius of the jobsite will not be listed individually.

Unfortunately MR5 is one of those credits which don't do a good job incorporating how the market works. For some products the language is clear but for others it can be more complicated than what you see on the surface.

No, you don't. As long as you know your total materials budget (if you're using that method), you don't need to track non-compliant materials.

I love to hear if anyone has actually submitted them and discovered otherwise, but I'd say that the info you found is right on--given where the raw materials for aluminum come from, it's hard to make the case that it could be a regional material in the U.S.

In response to Nadav's comment,

It seems like your reply to Tony's question about recycled steel would apply here also. The original harvesting site of raw aluminum is mostly overseas, but from what I have been told, the location of the production of the billet (which will have a % from scrap) is accepted for the MR5 credit. Manufacturers of aluminum products can usually tell you where they get their billet from.
I work for Arcadia, inc. in the L.A. area and while I have only been here a short time, have been told by colleagues that we have successfully contributed to this credit on projects. We use a local extruder who produces the billet locally.
I have also seen mention of MR5 on Vistawall's website, and there may be other manufacturers who have had success with this.
I had a conversation with U.S. Aluminum similar to the one above, and it may be that they do not obtain their billet locally, or that their suppliers vary.
Does anyone know if there is an official word from the usgbc on this? Either a CI or just acceptance of a project?

Tongsu, materials qualifying for this credit must be both manufactured and extracted within the 500-mile radius.

That means that materials imported from China, if they are from farther than 500 miles, would not qualify. Sorry!

I can't guarantee that it will be accepted, but my experience suggests that it will be. The fill will figure into the calculations on a cost basis, so unless you're spending a lot on fill, it may not affect the end result all that much.

Keep in mind that including this for all credits could hurt your ability to earn points for recycled content (MRc4). .

Hi Tony,

This is covered pretty well in a "hot tip" in the "Checklists" section of LEEDuser, above. Basically, you do have to know where the scrap was collected prior to going to the manufacturer, but you don't have to track anything back to it's original, pre-recycling state. And no, there is no default value like the MRc4 25%.

My suggestion would be to include as many materials in the template as will fit, leaving one line open. Then put the rest in an attached spreadsheet, as you propose, and use the last line in the template to enter the total of the data from the spreadsheet, giving it a fictitious "product" and "company" name indicating that it's an aggregation from the attached file.

That should give you the right result in the template, while also giving GBCI all the data. What have others done in this situation?

I have just encountered the same issue and would like to know the proper protocol. Seems a bit odd that the template has such a limited number of fields. Stephen, did you have any luck with Nadav's suggestion?

I've seen people do a variety of things, from uploading additional letter template PDFs in the supplemental docs area, or using the one main letter template as a summary sheet and uploading a separate detailed excel spreadsheet for all the individual entries. It shouldn't really matter which method you use, as long as you provide the information and communicate clearly to the reviewer where to find it.
Also, remember it may not be neccessary to provide the regional material information on all materials - just the big ticket cost items needed to acheive the credit.

HI Greg,

Division 13 falls into the group of stuff that doesn't HAVE to be included, but also isn't specifically excluded, like MEP stuff. So you should be fine including it at your option, as long as you include it consistently in all applicable credits.

Green is often grey! You might try making a map with towns clearly marked that shows your 500 mile radius circle. Hopefully, the steel company would be able to indicate what % of their recovery sources are typically inside or outside that radius, even if they can't tell you exactly what percent is in your particular product.

They've said that their statement that 80% is recovered within 200 miles is the best that they can do. I will not be able to provide a map with specific locations marked. Other ideas?

Given the near-certainty that a significant amount of the steel product came from outside the radius, and the lack of information to know how much, I don't see a way the qualify the product for this credit, at least not without more info from the manufacturer.

I'd like to vent on this subject. I believe what April is saying is that the steel was fabricated 479 miles from her project site and that 80 % was havested within a 200 mile radius of the fabricator. The only way that she can get credit for this this material, is if the 200 miles is in her projects direction. If it happens to be 200 miles in the opposite direction, it doesn't count toward the credit. She would need to check with the fabricator to find the actual location of the havested material to get her 80%. This is a flaw in the LEED logic. Why would it matter if the material harvest location (200 miles from the fabricator) is within 500 mile of the project site or not? Either way it would have to travel 200 miles to the fabricator. If it happens to be within the projects 500 mile radius you get to include the costs and if it's not, you don't. The credit should read "Fabricated/manufactured within 500 miles of the project site and extracted/harvested within 500 mile of the fabricator/manufacturer." I can only hope this has been cleared up in NC 2009 or whatever new system they are currently working on. - I feel better.

Joseph,
Earning this credit can be frustrating due to the difficulty of getting good extraction information or realizing that what you thought was a regional material has extracted content that is considered 'proprietary'. I also understand your frustration with the calculations. I find it helps to remember the triple bottom line and that this principle is embedded in the LEED credits. The way I see it, the Regional credit has a strong 'social' component and your project should support the local/regional economy which wouldn't happen if extraction was outside the 500 radial miles as the project.

What I hear you saying is that the extraction should be within 500 miles of the manufacturing site and the final manufacturing site should be within 500 miles of the Project. You aren't the first to suggest this. But consider this. I'm looking at an image for a DC project with the 500 mile superimposed on the map. We lose a large section to the Atlantic, pick up a good section of Ontario, just miss Montreal Atlanta and Savannah, clip Indianapolis and incorporate 12 states fully. If the extraction were allowed to be 500 miles away from the plant and not the project, we would wind up including a lot of the country from the edge of the east coast. For example, if we're getting something made in Indianapolis, extraction could happen another 500 miles inTopeka Kansas. All along the edge of my 500 mile Project circle would be another 500 mile circle. It adds up! What influence do you have from a 1000 miles away? What influence do you have from 50 miles away?

Hi Susan, thank you for your input, but I think you missed my point. If a product is Manufactured 400 miles away from my project and the material is extracted within 200 miles of the manufacturing plant, it will need to travel 600 miles to my project. If the extraction point is in my projects direction, it is within my 500 mile radius and I get to include the costs, if it is in the opposite direction, it will be outside of my 500 mile radius and I cannot include the cost. Regardless, the product will still need to travel 600 miles in either scenario. I understand that we as LEED accredited professionals need to explore different options to avoid scenarios like this, but the availability of certain products can be limiting. I think a line must be drawn in the sand as well, but it should stop at the manufacturing plant, the extraction point is irrelevant (to a certain point).

In an extreme scenario, a product could be manufactured 400 miles from a project, yet extracted 1 mile from the project. In this example it would travel 800 miles before the finished product made it to the job, yet it would still be acceptable to count toward the Regional materials credit. It is a slight flaw in an otherwise well thought out program. Our influence can only go as far as the availability and diversity of products in our regions.

Hi Joseph, You make a good point. As former chair of the MR-TAGLEED Technical Advisory Group (TAG): Subcommittees that consist of industry experts who assist in developing credit interpretations and technical improvements to the LEED system., I can promise you we struggled with these questions quite a bit! And I would certainly not try to argue that this credit is perfect as it is. But I do have a couple of points to add.

1. As you may know, LEED used to have one point that was based just on point of manufacture, and a second point that included extraction location (LEED-CI still has this structure). The problem is that, if you ignore point of extraction, the raw materials (which are typically bulkier and more massive than the finished product) might be traveling thousands of miles. So your example of how it could travel 800 miles doesn't really counteract that issue. 

2. This credit is not just about transportation impacts, but also about the "connection to place" and local economic benefits of using indigenous materials. If your ore is being mined in your backyard, you might be more sensitive to the impacts of that mining process than if it's mined across the world. 

Just wanted to share this, in response to your thoughtful critique.

Thanks Nadav,
It can be frustrating when you cannot include costs due to the extraction point being in the wrong direction. I guess I lost site of the big picture. And Susan, I apologize to you as well, as this was the point you initially mentioned.

This is debated all over the place.
Here: http://www.areforum.org/forums/showthread.php?t=120429
Here: http://www.reallifeleed.com/2008/06/id-points-exemplary-performance-made...
And at my very own office. I had a LEED-NC v2.2 project that achieved 38% regional materials. I spoke to a USGBC staffer before submitting who stated that he was "pretty sure" that 40% was a typo. And lo and behold, the project did indeed receive an I&D credit for exemplary use of regional materials. It's frustrating nonetheless that USGBC never issued an official erratum, because I'd like to be able to refer my clients to something in writing.

Actually, there is no typo - the threshold was changed purposefully for 2009.

At this time to achieve 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. for MRc5 under the NCv2.2 rating system the required percentage is still 40%.

Here's the official response I have from the GBCI (Jeremy's post was not there yesterday when I was asking about it!)

"Even though NCv2009 only requires 30% to achieve 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. for the Regional Materials credit, MRc5, NCv2.2 still requires 40% as there have been no updates to the guide or a published 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. stating otherwise. It may be possible that the strategy of earning an exemplary performance point with having only 30% of materials purchased regionally could be approved for your project and therefore we recommend you have this strategy approved by either submitting 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 a LEED Interpretation. For more information about CIRs please refer to this link, http://www.gbci.org/Certification/Resources/cirs.aspx, while for more information about LEED Interpretations refer to this link https://www.usgbc.org/LeedInterpretations/LILanding.aspx?CMSPageID=1432."

is anyone aware of a published 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 a 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. for the above 30% Regional materials issue? I was not able to locate it on GBCI's database https://www.usgbc.org/LeedInterpretations/LILanding.aspx?CMSPageID=1432
We are in a similar situation as described above with 38% regional materials on a project however given the LEED interpretation response takes a few weeks to process our project timeline will not allow us to wait to submit for review until we hear back a response from the interpretation. Would appreciate if someone can let me know if a response is already available. Thanks.

Komal, the earlier comments on this topic are accurate. You need 40% regional for EP for a v2.2 project.