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LEED v2009
Core & Shell
Sustainable Sites
Construction Activity Pollution Prevention

LEED CREDIT

CS-2009 SSp1: Construction Activity Pollution Prevention Required

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KEMA Services
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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 Permit OR local standards and codes, whichever is more stringent. [India ACP: E&S Plan]. 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 (NPDES) 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/cgp.cfm.
Credit substitution available
You may use the LEED v4 version of this credit on v2009 projects. For more information check out this article.

Alternative Compliance Paths (ACPs)

India ACP: EPA Construction General Permit Equivalent
Projects in India may use the National Building Code of India 2005 (NBC 2005) Part 10, Section 1, Chapters 4 & 5 along with Section 3 of the EPA Construction General Permit[view:embed_resource=page_1=10039154]
SITES-LEED Equivalency
This LEED credit (or a component of this credit) has been established as equivalent to a SITES v2 credit or component. For more information on using the equivalency as a substitution in your LEED or SITES project, see this article and guidance document.
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Frequently asked questions

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?

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What are BMPs for steep slopes?

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I have a technical question about a specific control measure and whether LEED requires it. What guidance is available?

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Is there a preferred method for documentation?

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What suffices as far as a date-stamped photo?

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Can I still earn the prerequisite if the project started considering LEED after work began?

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Addenda

7/1/2015Updated: 3/29/2018
Regional ACP
Description of change:
After the second sentence of the first paragraph insert the following:
"Projects in India may use the National Building Code of India 2005 (NBC 2005) Part 10, Section 1, Chapters 4 & 5 along with Section 3 of the EPA Construction General Permit as a local equivalent."
Campus Applicable
No
Internationally Applicable:
No
11/3/2010Updated: 2/14/2015
Reference Guide Correction
Description of change:
At the end of the 3rd paragraph, add the following text:For major renovation projects whose scope of work includes onlyinterior renovation, identify areas of potential pollution fromconstruction activities including construction staging and access, anddevelop a plan that addresses these areas. Potential pollution couldinclude pollution of the site or air with dust and particulate matter.
Campus Applicable
No
Internationally Applicable:
No
9/10/2007
LEED Interpretation
Inquiry:

SSp1 calls for an Erosion and Sedimentation Control Plan that conforms to the requirements of the 2003 EPA Construction General Permit OR local erosion and sedimentation control standards and codes, whichever is more stringent. The project is located in Mississauga, Ontario, Canada and does not therefore require a U.S. EPA Construction General Permit. Instead the relevant city By-Law requires application for a permit that addresses erosion and sedimentation control and is obtained by submitting site drawings to the city for review and approval. The civil consultant on our project has obtained the City Permit, and has determined that the city By-Law measures are at least as stringent as the practices outlined in the LEED SSp1 Referenced Standard, EPA 832R92005 Chapter 3. The consultant will also be completing an Erosion and Sedimentation Control Plan in accordance with the Referenced Standard. Please confirm the following: The EPA Construction General Permit has no relevance as a Permit in Canada, and therefore the prerequisite can be met by demonstrating the measures taken to control erosion and sedimentation on site are consistent with the Referenced Standard, EPA 832R92005. AND As an ESC plan is not required for the city permit, and is not required for purposes other than LEED, it is acceptable to implement an ESC plan consistent with the Reference Standard, EPA 832R92005.

Ruling:

If, as stated, the City\'s By-Law measures are at least as stringent as the reference standard and the Erosion and Sedimentation Control Plan is also consistent with the reference standard and that supporting documentation can be provided to this effect, then prerequisite achievement is likely. Please be certain to provide appropriate supporting documentation and a narrative describing these equivalencies and how the measures undertaken have met credit intent. It should be noted that this reference standard has been selected by the Canadian Green Building Council for credit compliance. Applicable Internationally; Canada.

Campus Applicable
No
Internationally Applicable:
Yes
11/11/2006
LEED Interpretation
Inquiry:

The project is one of the first projects in Italy seeking a LEED certification. It has been completed in 2006 and the team and the investor is trying to certify the building within the Core & shell system with the building\'s as-built-documentation, since it is not yet capable of fulfilling the minimum program requirements of the LEED EB O&M system. The remaining Prerequisites of C&S seem likely to be achievable. Regarding the Sustainable Sites Prerequisite 1 we approach you today and kindly ask for your Credit interpretation. Since the site was a brownfield inner-city re-development, all of the excavation had to be hauled to an approved disposal facility, by local code. The documentation of the hauled earthwork volumes by the contractor that provided this service can be provided. Before the excavation works started a diaphragm wall has been installed to prevent erosion effects of the surrounding soils and to minimize the disturbance of the groundwater level. Due to the redevelopment of the site, the infrastructure of a canalization system of the community of Milan was already in place to treat possible stormwater rates. Furthermore the project created paved site logistic roads to minimize the effect of vehicle and foot traffic. The planned landscaping of the project was planted as early as possible to stabilize the surrounding soils. Due to the given infiltration quality of the soils there were hardly any stormwater amounts that were running of site and if they did they were flowing into the existing canalization system. According drawings with the existing canalization system can be provided. Due to the documentation on hand we can show pictures and drawings of the site in it\'s early stages. The erosion and sedimentation measures can only be described now, and proven through the scope of services contract with the earth work company that disposed the volumes and through pictures and drawings showing the site and the infrastructure of the early stages of the construction. We kindly ask you to review the points mentioned above and give us your feedback if the project can achieve this prerequisite based on the information given above.

Ruling:

From the project description given, it is not clear what standards were followed or whether an Erosion and Sedimentation Control Plan was developed for construction. More information will be required for prerequisite review. The strategies outline above do not address all of the areas for erosion and sedimentation control required to meet the prerequisite. The strategies implemented to control sedimentation and erosion should be implemented on the project site during construction. For certification, the project team must provide a copy of the Erosion and Sedimentation Control Plan. If an Erosion and Sedimentation Control Plan was not created, the project must demonstrate that erosion and sedimentation control measures implemented met or exceeded the requirements of the 2003 EPA Construction General Permit, and must address at a minimum: 1. Strategies implemented on the construction site to control soil loss from stormwater and wind during construction 2. Strategies implemented on the construction site to protect receiving storm sewers and receiving water ways 3. Strategies implemented on the construction site to prevent air pollution from dust and particulate matter. If the project can demonstrate that measures implemented conform to Construction General Permit requirements and the objectives identified in the prerequisite, the prerequisite may be achieved. Applicable Internationally; Europe; Italy.

Campus Applicable
No
Internationally Applicable:
Yes
1/29/2008
LEED Interpretation
Inquiry:

Erosion Control Plan:No erosion control plan was required by local erosion and sedimentation control standards and codes for this project, as the site was not sufficiently disturbed, nor impervious area increased, to require one. Therefore, no "Erosion and Sedimentation Control Plan" was shown on any construction drawings. However, because the project intends to earn LEED certification, much attention has been paid to preventing loss of soil to wind or water during construction. Our team plans to demonstrate compliance with this prerequisite by documenting, in narrative form, how it complied with the provisions of the 2003 EPA Construction General Permit requirements.Disturbed Site Area:The total site occupies 11, 446 square feet (.26 acres); this LEED project was a major renovation of one of two existing buildings and its immediate surrounding area sitting on 3,990 square feet of the total site. Within this work area, only 1,083 square feet of earth was disturbed (less than 10% of the total site area). Earthwork disturbance involved laying new sidewalk, repair of an existing retaining wall, installation of new drop inlets and installation of foundation waterproofing. A site plan will be provided in our LEED application.Work performed and measures taken:Approximately 750 cubic-feet of soil were removed to accomplish work described above. Said soil was deposited on tarps and covered to prevent wash-away or contamination. Following successful completion of below-grade work, some of the soil was returned as on-site fill. A large portion (approx 639 cubic-feet) was hauled away and used as clean fill by Renewable Resources, Inc. All soil was tested for lead content and shown to be safe for re-use.New Drop Inlets:Three new drop inlets were installed in the yard to facilitate drainage and prevent excess water from congregating around the foundations. Following installation, these inlets were covered for the remainder of construction to prevent soils from entering drainage system.New Plantings:All areas where soil was disturbed were planted with new landscaping suitable to stabilize soils. A Landscape Plan will be provided in our LEED application.Run-off:By virtue of the above listed measures it was observed that no soils washed off the site, wind erosion was minimized, and no contaminants were introduced into the aquifer.Question:Please confirm that our approach to documenting compliance with SSp1 through the narrative above will be acceptable to the USGBC. If not acceptable, please advise what documentation will be required to demonstrate compliance.

Ruling:

The applicant is requesting confirmation of compliance with SSp1 requirements, although the project did not have an Erosion and Sedimentation Control (ESC) Plan. The area of disturbance was relatively small and therefore the project was not required by local standards and codes to have an ESC Plan.

The requirement of the prerequisite is to create an Erosion and Sedimentation Control (ESC) Plan for all construction activities associated with the project. The ESC Plan should conform to the erosion and sedimentation requirements of the 2003 EPA Construction General Permit (see www.epa.gov/npdes/pubs/chap03_conguide.pdf for more information) or local erosion and sedimentation control standards and codes, whichever is more stringent. Where no local standards and codes are present, the plan must conform to the requirements of the 2003 EPA Construction General Permit ("While the Construction General Permit only applies to construction sites greater than 1 acre, the requirements are applied to all projects for the purposes of this prerequisite.") If the project can demonstrate that measures implemented conform with Construction General Permit requirements and the objectives identified in the prerequisite, the prerequisite may be achieved.

Campus Applicable
No
Internationally Applicable:
No
7/11/2006
LEED Interpretation
Inquiry:

Erosion and Sedimentation Control Plans and Narrative Reports have been submitted to the Centre County Conservation District who is empowered by PA Department of Environmental Protection to review and act on such plans via a "letter of delegation" between agencies. The Conservation District\'s recommendation of Erosion and Sedimentation Control approval and Stormwater Management Control Plans and Narratives have been reviewed and approved by the PA Department of Environmental Protection. The PA Department of Environmental Protection has issued a National Pollution Discharge Elimination System #PAI041406012 for project construction. Additionally, both Erosion and Sedimentation and Stormwater Management Controls comply with local "Spring Creek Watershed" protection design guidelines which have been adopted by the Municipality. Local requirements, PA State Act 167, and Erosion and Sedimentation Control and Stormwater Management Control requirements meet or exceed the EPA 832-R-92-005 requirements.

Ruling:

If local requirements meet or exceed the EPA requirements, the project has complied with the prerequisite. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
11/10/2006
LEED Interpretation
Inquiry:

Our project is one of four speculative office buildings that are being constructed on a newly developed subdivision. Although some sedimentation and erosion control measures were implemented during the development of the subdivision (which included installation of infrastructure and stripping of topsoil), it is not clear whether the measures met EPA requirements and the majority of measures have since been removed. Our project is to be designed and constructed to achieve LEED Core and Shell certification, including the implementation of a comprehensive sedimentation and erosion control plan consistent with prerequisite requirements. We wish to confirm that our LEED project, and hence the activities that must meet prerequisite requirements commence with the construction of the new building and parking lot only, and do not include the subdivision development work. This building is being developed by the same entity that created the subdivision. However, subsequent projects on the subdivision may be developed by others.

Ruling:

The building and surrounding site can be considered a "stand alone" project within the total development. However, site boundaries for the project must be consistent across all credits. Certain items may apply to the project site if it draws on or affects the greater total development, but the project is not required to consider the total development. Since the developer for the building project is the same entity as in the underlying subdivision, the developer is strongly encouraged to identify and remediate any deficiency in the underlying subdivision\'s Erosion and Sedimentation Control systems prior to seeking LEED Credit for the building project. The LEED-NC Application Guide for Multiple Buildings and On-Campus Building Projects is available through the USGBC\'s website and may serve as a resource for this project. Update April 15, 2011: Please note that all 2009 projects in multiple building situations must follow the 2010 Application Guide for Multiple Buildings and On-Campus Building Projects, located here: https://www.usgbc.org/ShowFile.aspx?DocumentID=7987. 2009 project teams should check this document for up to date guidance on all multiple building issues. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
9/2/2006
LEED Interpretation
Inquiry:

The HSBC Cairo Regional Processing Center is a new 18,000 square meter building located in Giza, Egypt, approximately 40 kilometers northwest of Cairo. Unlike Cairo, which is located in the fertile Nile Valley, Giza is sited in the desert climate that typifies most of Egypt. The site is previously undeveloped, and the geology of the site is several meters of sand sitting about 20 m above bedrock. The average annual rainfall in Cairo is 24 mm (0.95"), 75% of which occurs between December and March. Stormwater management is not considered an environmental issue in this climate, since the sandy soils allow for total absorption of all normal storm events. Thus, erosion control for stormwater is not a common practice in this climate. The dry climate, however, does make the site prone to wind-borne erosion and air pollution generation from dust. Constructing the building will require excavating approximately 80,000 cubic meters (104,000 cubic yards) of earth, of which approximately 20,000 cubic meters (26,000 cubic yards) will be stockpiled for backfill. The prerequisite requirements make mention of dust pollution control, but the referenced EPA Construction General Permit do not address dust control specifically. Egypt does not have an environmental law analogous to EPA Construction General Permit. The relevant Egyptian environmental regulations are delineated in Section II Article 41 of "Law #4 of 1994: Promulgating the Environmental Law" (see below). Thus, the local environmental law is the more stringent than the absent dust regulation from the EPA Permit, but it still relatively vague. To ensure compliance with this prerequisite above and beyond the requirements of the Environmental Law, the Cairo-based project architect ARCHIMID has included strict language in the project documents to ensure minimal erosion and wind-borne dust generation (see below). Please confirm that the design team\'s approach of not implementing stormwater measures but instead going to great lengths to minimize airborne dust pollution will meet the intent and requirements of the prerequisite, given the vastly different climate and challenges with which this project is grappling. We look forward to your response. -------------------------- Excerpt from HSBC CRPC Tender Documents (Design Development Documents) Project Manual - Section 01495 Health, Safety & Environment, Section 6.3 Air Pollution Prevention: The PM [Project Manager] will monitor the cumulative effect of simultaneous construction activities on air quality. In addition, the Contractor will take the following steps to protect air quality: a. Development of aggressive measures to reduce dust and air pollution during construction. b. Water sprays to treat excavated materials at major points of transfer (i.e. unloading onto conveyor belts or trucks). Water sprays shall be used on exposed soils and excavation to reduce dust. c. Dump trucks hauling loose material such as, but not limited to, sands, gravels, muck, excavation spoils and soils shall be covered with tarpaulins or other load covering that can be securely fastened and shall be equipped with tight fitting tailgates that can be securely fastened in the closed position and will not permit wet or dry materials being hauled to leak or trickle out. d. The Contractor shall implement appropriate measures to prevent deposition of material on public ways. Street sweeping service shall be provided as necessary to ensure that any material that is tracked onto public ways is immediately removed. e. Construction Sites will be fenced to reduce wind-borne dust. ------------------------- Excerpt from (Egypt) Law #4 of 1994: Promulgating the Environmental Law - Section II Article 41 All organizations and individuals shall be held, when carrying out exploration, excavation, construction or demolition works, or when transporting the resultant waste or debris, to take necessary precautions to secure the safe storage or transportation thereof. The authority granting the building or demolition license shall indicate these requirements in the license in the manner set forth below: That on-site storage of waste or debris be affected with due regard to the requirements of safety and the unobstructed movement of traffic and people. Waste liable to dispersal shall be covered to avoid air pollution. That waste or debris resulting from excavation, demolition and construction works be transported in special containers or receptacles on trucks equipped and licensed for this purpose and meeting the following conditions: Fitted with a special box or an air-tight cover to prevent loose particles of waste and debris from escaping into the air or dropping on the road. Provided with special loading and unloading equipment. In good condition according to the rules of safety, solidity and lights and fitted with all safety equipment.

Ruling:

The applicant is requesting confirmation of compliance with SSp1 requirements, although the project did not implement measures to protect against stormwater erosion, only measures to protect against wind erosion. The applicant\'s project is located in Giza, Egypt, a desert area with an average annual rainfall of approximately 0.95" and therefore an area with minimal stormwater erosion concerns, yet one that is prone to soil erosion due to wind. The referenced standard, Stormwater Management for Construction Activities (USEPA Document No. 832R92005), is a performance based standard that states, "your selection of the best soil erosion and sediment controls for your site should be primarily based upon the nature of the construction activity and the conditions which exist at the construction site." It is apparent from the description above that erosion due to stormwater is not a concern that needs to be addressed in the Erosion and Sedimentation Control Plan. Applicable Internationally; Egypt.

Campus Applicable
No
Internationally Applicable:
Yes
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KEMA Services
Sustainable Project Manager

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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 Permit OR local standards and codes, whichever is more stringent. [India ACP: E&S Plan]. 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 (NPDES) 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/cgp.cfm.
Credit substitution available
You may use the LEED v4 version of this credit on v2009 projects. For more information check out this article.

Alternative Compliance Paths (ACPs)

India ACP: EPA Construction General Permit Equivalent
Projects in India may use the National Building Code of India 2005 (NBC 2005) Part 10, Section 1, Chapters 4 & 5 along with Section 3 of the EPA Construction General Permit[view:embed_resource=page_1=10039154]
SITES-LEED Equivalency
This LEED credit (or a component of this credit) has been established as equivalent to a SITES v2 credit or component. For more information on using the equivalency as a substitution in your LEED or SITES project, see this article and guidance document.

XX%

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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?

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What are BMPs for steep slopes?

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I have a technical question about a specific control measure and whether LEED requires it. What guidance is available?

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Is there a preferred method for documentation?

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What suffices as far as a date-stamped photo?

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Can I still earn the prerequisite if the project started considering LEED after work began?

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7/1/2015Updated: 3/29/2018
Regional ACP
Description of change:
After the second sentence of the first paragraph insert the following:
"Projects in India may use the National Building Code of India 2005 (NBC 2005) Part 10, Section 1, Chapters 4 & 5 along with Section 3 of the EPA Construction General Permit as a local equivalent."
Campus Applicable
No
Internationally Applicable:
No
11/3/2010Updated: 2/14/2015
Reference Guide Correction
Description of change:
At the end of the 3rd paragraph, add the following text:For major renovation projects whose scope of work includes onlyinterior renovation, identify areas of potential pollution fromconstruction activities including construction staging and access, anddevelop a plan that addresses these areas. Potential pollution couldinclude pollution of the site or air with dust and particulate matter.
Campus Applicable
No
Internationally Applicable:
No
9/10/2007
LEED Interpretation
Inquiry:

SSp1 calls for an Erosion and Sedimentation Control Plan that conforms to the requirements of the 2003 EPA Construction General Permit OR local erosion and sedimentation control standards and codes, whichever is more stringent. The project is located in Mississauga, Ontario, Canada and does not therefore require a U.S. EPA Construction General Permit. Instead the relevant city By-Law requires application for a permit that addresses erosion and sedimentation control and is obtained by submitting site drawings to the city for review and approval. The civil consultant on our project has obtained the City Permit, and has determined that the city By-Law measures are at least as stringent as the practices outlined in the LEED SSp1 Referenced Standard, EPA 832R92005 Chapter 3. The consultant will also be completing an Erosion and Sedimentation Control Plan in accordance with the Referenced Standard. Please confirm the following: The EPA Construction General Permit has no relevance as a Permit in Canada, and therefore the prerequisite can be met by demonstrating the measures taken to control erosion and sedimentation on site are consistent with the Referenced Standard, EPA 832R92005. AND As an ESC plan is not required for the city permit, and is not required for purposes other than LEED, it is acceptable to implement an ESC plan consistent with the Reference Standard, EPA 832R92005.

Ruling:

If, as stated, the City\'s By-Law measures are at least as stringent as the reference standard and the Erosion and Sedimentation Control Plan is also consistent with the reference standard and that supporting documentation can be provided to this effect, then prerequisite achievement is likely. Please be certain to provide appropriate supporting documentation and a narrative describing these equivalencies and how the measures undertaken have met credit intent. It should be noted that this reference standard has been selected by the Canadian Green Building Council for credit compliance. Applicable Internationally; Canada.

Campus Applicable
No
Internationally Applicable:
Yes
11/11/2006
LEED Interpretation
Inquiry:

The project is one of the first projects in Italy seeking a LEED certification. It has been completed in 2006 and the team and the investor is trying to certify the building within the Core & shell system with the building\'s as-built-documentation, since it is not yet capable of fulfilling the minimum program requirements of the LEED EB O&M system. The remaining Prerequisites of C&S seem likely to be achievable. Regarding the Sustainable Sites Prerequisite 1 we approach you today and kindly ask for your Credit interpretation. Since the site was a brownfield inner-city re-development, all of the excavation had to be hauled to an approved disposal facility, by local code. The documentation of the hauled earthwork volumes by the contractor that provided this service can be provided. Before the excavation works started a diaphragm wall has been installed to prevent erosion effects of the surrounding soils and to minimize the disturbance of the groundwater level. Due to the redevelopment of the site, the infrastructure of a canalization system of the community of Milan was already in place to treat possible stormwater rates. Furthermore the project created paved site logistic roads to minimize the effect of vehicle and foot traffic. The planned landscaping of the project was planted as early as possible to stabilize the surrounding soils. Due to the given infiltration quality of the soils there were hardly any stormwater amounts that were running of site and if they did they were flowing into the existing canalization system. According drawings with the existing canalization system can be provided. Due to the documentation on hand we can show pictures and drawings of the site in it\'s early stages. The erosion and sedimentation measures can only be described now, and proven through the scope of services contract with the earth work company that disposed the volumes and through pictures and drawings showing the site and the infrastructure of the early stages of the construction. We kindly ask you to review the points mentioned above and give us your feedback if the project can achieve this prerequisite based on the information given above.

Ruling:

From the project description given, it is not clear what standards were followed or whether an Erosion and Sedimentation Control Plan was developed for construction. More information will be required for prerequisite review. The strategies outline above do not address all of the areas for erosion and sedimentation control required to meet the prerequisite. The strategies implemented to control sedimentation and erosion should be implemented on the project site during construction. For certification, the project team must provide a copy of the Erosion and Sedimentation Control Plan. If an Erosion and Sedimentation Control Plan was not created, the project must demonstrate that erosion and sedimentation control measures implemented met or exceeded the requirements of the 2003 EPA Construction General Permit, and must address at a minimum: 1. Strategies implemented on the construction site to control soil loss from stormwater and wind during construction 2. Strategies implemented on the construction site to protect receiving storm sewers and receiving water ways 3. Strategies implemented on the construction site to prevent air pollution from dust and particulate matter. If the project can demonstrate that measures implemented conform to Construction General Permit requirements and the objectives identified in the prerequisite, the prerequisite may be achieved. Applicable Internationally; Europe; Italy.

Campus Applicable
No
Internationally Applicable:
Yes
1/29/2008
LEED Interpretation
Inquiry:

Erosion Control Plan:No erosion control plan was required by local erosion and sedimentation control standards and codes for this project, as the site was not sufficiently disturbed, nor impervious area increased, to require one. Therefore, no "Erosion and Sedimentation Control Plan" was shown on any construction drawings. However, because the project intends to earn LEED certification, much attention has been paid to preventing loss of soil to wind or water during construction. Our team plans to demonstrate compliance with this prerequisite by documenting, in narrative form, how it complied with the provisions of the 2003 EPA Construction General Permit requirements.Disturbed Site Area:The total site occupies 11, 446 square feet (.26 acres); this LEED project was a major renovation of one of two existing buildings and its immediate surrounding area sitting on 3,990 square feet of the total site. Within this work area, only 1,083 square feet of earth was disturbed (less than 10% of the total site area). Earthwork disturbance involved laying new sidewalk, repair of an existing retaining wall, installation of new drop inlets and installation of foundation waterproofing. A site plan will be provided in our LEED application.Work performed and measures taken:Approximately 750 cubic-feet of soil were removed to accomplish work described above. Said soil was deposited on tarps and covered to prevent wash-away or contamination. Following successful completion of below-grade work, some of the soil was returned as on-site fill. A large portion (approx 639 cubic-feet) was hauled away and used as clean fill by Renewable Resources, Inc. All soil was tested for lead content and shown to be safe for re-use.New Drop Inlets:Three new drop inlets were installed in the yard to facilitate drainage and prevent excess water from congregating around the foundations. Following installation, these inlets were covered for the remainder of construction to prevent soils from entering drainage system.New Plantings:All areas where soil was disturbed were planted with new landscaping suitable to stabilize soils. A Landscape Plan will be provided in our LEED application.Run-off:By virtue of the above listed measures it was observed that no soils washed off the site, wind erosion was minimized, and no contaminants were introduced into the aquifer.Question:Please confirm that our approach to documenting compliance with SSp1 through the narrative above will be acceptable to the USGBC. If not acceptable, please advise what documentation will be required to demonstrate compliance.

Ruling:

The applicant is requesting confirmation of compliance with SSp1 requirements, although the project did not have an Erosion and Sedimentation Control (ESC) Plan. The area of disturbance was relatively small and therefore the project was not required by local standards and codes to have an ESC Plan.

The requirement of the prerequisite is to create an Erosion and Sedimentation Control (ESC) Plan for all construction activities associated with the project. The ESC Plan should conform to the erosion and sedimentation requirements of the 2003 EPA Construction General Permit (see www.epa.gov/npdes/pubs/chap03_conguide.pdf for more information) or local erosion and sedimentation control standards and codes, whichever is more stringent. Where no local standards and codes are present, the plan must conform to the requirements of the 2003 EPA Construction General Permit ("While the Construction General Permit only applies to construction sites greater than 1 acre, the requirements are applied to all projects for the purposes of this prerequisite.") If the project can demonstrate that measures implemented conform with Construction General Permit requirements and the objectives identified in the prerequisite, the prerequisite may be achieved.

Campus Applicable
No
Internationally Applicable:
No
7/11/2006
LEED Interpretation
Inquiry:

Erosion and Sedimentation Control Plans and Narrative Reports have been submitted to the Centre County Conservation District who is empowered by PA Department of Environmental Protection to review and act on such plans via a "letter of delegation" between agencies. The Conservation District\'s recommendation of Erosion and Sedimentation Control approval and Stormwater Management Control Plans and Narratives have been reviewed and approved by the PA Department of Environmental Protection. The PA Department of Environmental Protection has issued a National Pollution Discharge Elimination System #PAI041406012 for project construction. Additionally, both Erosion and Sedimentation and Stormwater Management Controls comply with local "Spring Creek Watershed" protection design guidelines which have been adopted by the Municipality. Local requirements, PA State Act 167, and Erosion and Sedimentation Control and Stormwater Management Control requirements meet or exceed the EPA 832-R-92-005 requirements.

Ruling:

If local requirements meet or exceed the EPA requirements, the project has complied with the prerequisite. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
11/10/2006
LEED Interpretation
Inquiry:

Our project is one of four speculative office buildings that are being constructed on a newly developed subdivision. Although some sedimentation and erosion control measures were implemented during the development of the subdivision (which included installation of infrastructure and stripping of topsoil), it is not clear whether the measures met EPA requirements and the majority of measures have since been removed. Our project is to be designed and constructed to achieve LEED Core and Shell certification, including the implementation of a comprehensive sedimentation and erosion control plan consistent with prerequisite requirements. We wish to confirm that our LEED project, and hence the activities that must meet prerequisite requirements commence with the construction of the new building and parking lot only, and do not include the subdivision development work. This building is being developed by the same entity that created the subdivision. However, subsequent projects on the subdivision may be developed by others.

Ruling:

The building and surrounding site can be considered a "stand alone" project within the total development. However, site boundaries for the project must be consistent across all credits. Certain items may apply to the project site if it draws on or affects the greater total development, but the project is not required to consider the total development. Since the developer for the building project is the same entity as in the underlying subdivision, the developer is strongly encouraged to identify and remediate any deficiency in the underlying subdivision\'s Erosion and Sedimentation Control systems prior to seeking LEED Credit for the building project. The LEED-NC Application Guide for Multiple Buildings and On-Campus Building Projects is available through the USGBC\'s website and may serve as a resource for this project. Update April 15, 2011: Please note that all 2009 projects in multiple building situations must follow the 2010 Application Guide for Multiple Buildings and On-Campus Building Projects, located here: https://www.usgbc.org/ShowFile.aspx?DocumentID=7987. 2009 project teams should check this document for up to date guidance on all multiple building issues. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
9/2/2006
LEED Interpretation
Inquiry:

The HSBC Cairo Regional Processing Center is a new 18,000 square meter building located in Giza, Egypt, approximately 40 kilometers northwest of Cairo. Unlike Cairo, which is located in the fertile Nile Valley, Giza is sited in the desert climate that typifies most of Egypt. The site is previously undeveloped, and the geology of the site is several meters of sand sitting about 20 m above bedrock. The average annual rainfall in Cairo is 24 mm (0.95"), 75% of which occurs between December and March. Stormwater management is not considered an environmental issue in this climate, since the sandy soils allow for total absorption of all normal storm events. Thus, erosion control for stormwater is not a common practice in this climate. The dry climate, however, does make the site prone to wind-borne erosion and air pollution generation from dust. Constructing the building will require excavating approximately 80,000 cubic meters (104,000 cubic yards) of earth, of which approximately 20,000 cubic meters (26,000 cubic yards) will be stockpiled for backfill. The prerequisite requirements make mention of dust pollution control, but the referenced EPA Construction General Permit do not address dust control specifically. Egypt does not have an environmental law analogous to EPA Construction General Permit. The relevant Egyptian environmental regulations are delineated in Section II Article 41 of "Law #4 of 1994: Promulgating the Environmental Law" (see below). Thus, the local environmental law is the more stringent than the absent dust regulation from the EPA Permit, but it still relatively vague. To ensure compliance with this prerequisite above and beyond the requirements of the Environmental Law, the Cairo-based project architect ARCHIMID has included strict language in the project documents to ensure minimal erosion and wind-borne dust generation (see below). Please confirm that the design team\'s approach of not implementing stormwater measures but instead going to great lengths to minimize airborne dust pollution will meet the intent and requirements of the prerequisite, given the vastly different climate and challenges with which this project is grappling. We look forward to your response. -------------------------- Excerpt from HSBC CRPC Tender Documents (Design Development Documents) Project Manual - Section 01495 Health, Safety & Environment, Section 6.3 Air Pollution Prevention: The PM [Project Manager] will monitor the cumulative effect of simultaneous construction activities on air quality. In addition, the Contractor will take the following steps to protect air quality: a. Development of aggressive measures to reduce dust and air pollution during construction. b. Water sprays to treat excavated materials at major points of transfer (i.e. unloading onto conveyor belts or trucks). Water sprays shall be used on exposed soils and excavation to reduce dust. c. Dump trucks hauling loose material such as, but not limited to, sands, gravels, muck, excavation spoils and soils shall be covered with tarpaulins or other load covering that can be securely fastened and shall be equipped with tight fitting tailgates that can be securely fastened in the closed position and will not permit wet or dry materials being hauled to leak or trickle out. d. The Contractor shall implement appropriate measures to prevent deposition of material on public ways. Street sweeping service shall be provided as necessary to ensure that any material that is tracked onto public ways is immediately removed. e. Construction Sites will be fenced to reduce wind-borne dust. ------------------------- Excerpt from (Egypt) Law #4 of 1994: Promulgating the Environmental Law - Section II Article 41 All organizations and individuals shall be held, when carrying out exploration, excavation, construction or demolition works, or when transporting the resultant waste or debris, to take necessary precautions to secure the safe storage or transportation thereof. The authority granting the building or demolition license shall indicate these requirements in the license in the manner set forth below: That on-site storage of waste or debris be affected with due regard to the requirements of safety and the unobstructed movement of traffic and people. Waste liable to dispersal shall be covered to avoid air pollution. That waste or debris resulting from excavation, demolition and construction works be transported in special containers or receptacles on trucks equipped and licensed for this purpose and meeting the following conditions: Fitted with a special box or an air-tight cover to prevent loose particles of waste and debris from escaping into the air or dropping on the road. Provided with special loading and unloading equipment. In good condition according to the rules of safety, solidity and lights and fitted with all safety equipment.

Ruling:

The applicant is requesting confirmation of compliance with SSp1 requirements, although the project did not implement measures to protect against stormwater erosion, only measures to protect against wind erosion. The applicant\'s project is located in Giza, Egypt, a desert area with an average annual rainfall of approximately 0.95" and therefore an area with minimal stormwater erosion concerns, yet one that is prone to soil erosion due to wind. The referenced standard, Stormwater Management for Construction Activities (USEPA Document No. 832R92005), is a performance based standard that states, "your selection of the best soil erosion and sediment controls for your site should be primarily based upon the nature of the construction activity and the conditions which exist at the construction site." It is apparent from the description above that erosion due to stormwater is not a concern that needs to be addressed in the Erosion and Sedimentation Control Plan. Applicable Internationally; Egypt.

Campus Applicable
No
Internationally Applicable:
Yes

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