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LEED v2009
New Construction
Materials and Resources

Construction Waste Management

LEED CREDIT

NC-2009 MRc2: Construction Waste Management 1-2 points

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Requirements

Recycle and/or salvage nonhazardous construction and demolition debris. Develop and implement a construction waste management plan that, at a minimum, identifies the materials to be diverted from disposal and whether the materials will be sorted on-site or comingled. Excavated soil and land-clearing debris do not contribute to this credit. Calculations can be done by weight or volume, but must be consistent throughout. The minimum percentage debris to be recycled or salvaged for each point threshold is as follows:

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Frequently asked questions

The waste management facility we are using is providing us with monthly documentation specific to our waste, showing 80% diversion. They also have a published, facility-wide rate of roughly 20%, and they have no published rate for construction waste. Will our diversion rate be accepted, or do we need to use a facility with an appropriate published rate?

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How is construction waste accounted for when utilizing off-site construction, like modular construction or pre-fabrication of assemblies?

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How does MRc2 work for projects pursuing a campus approach, or any project where waste management will be shared with other construction projects?

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Can materials that have been unused and returned to the manufacturer as part of a “take-back” program contribute to the credit?

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Should I include hazardous material such as lead-based paint in MRc2 calculations?

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Should household-type trash from workers' lunches and office use be included in MRc2 diversion and calculations?

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Can sending material to waste-to-energy plants count toward MRc2?

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The requirements of this credit say that land-clearing debris does not contribute to the percentage of materials diverted from the landfill. What exactly is considered "land clearing debris"?

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Oops! Our trash was measured by both weight and volume at different times. How do I standardize this?

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Addenda

5/9/2011Updated: 5/31/2017
Reference Guide Correction
Description of change:
Add the following to end of first paragraph:For commingled recycling the average annual recycling rate for a sorting facility is acceptable for recording diversion rates only when the facility\'s method of recording and calculating the recycling rate is regulated by a local or state government authority.
Campus Applicable
No
Internationally Applicable:
No
5/9/2011
LEED Interpretation
Inquiry:

A CS project is inheriting an existing building that still has furniture from the previous tenant. The project team is seeking clarification on how to account for this furniture in MRc2 and how to document the selling of this furniture to a re-seller.

Ruling:

Furniture may be included within its own category, without the need to breakdown the material composition unless components of the furniture are to be salvaged independently. In addition, diversion by re-sale is acceptable. The project team is required to document the receiving company (such as through a contract or sales receipt) and confirm that furniture is intended to be re-sold by that company. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
1/28/2008
LEED Interpretation
Inquiry:

When removing petroleum contaminated soils there are two options for disposal. One would be to haul the contaminated soils to a hazardous materials landfill. The other option is to incinerate the soil to burn off the petroleum and remediate the soil into a environmentally safe product. In the case of Biomed project we elected to have the contaminated soils recycled (incinerated). During the site cleanup WT removed 787.4 TONS of contaminated soils from the project site. We are currently applying for the "Brownfield Credit" which all of this documentation will be sent to document the cleanup. Also LEED specifically says that land clearing waste (soils) cannot be included in the waste management plan, but for this case we feel that because of the soils were recycled from a hazardous material that we should be able to apply the tonnage to our waste management calculations. Can we use this toward this credit too?

Ruling:

Incinerating soil to remove contamination can not be considered recycling and apply to MRc2. It is not clear that incinerating contaminated soil is environmentally preferable to landfilling. Both hazardous waste and soil must be excluded from calculations for MRc2, and incineration is not an allowable diversion method, per the LEED-NC v2.2 Reference Guide. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
7/8/2008
LEED Interpretation
Inquiry:

Within a LEED-ND Pilot registered neighborhood project, two buildings come into question: a LEED NCv2.2 registered hotel and a LEED CS registered mixed-use office building. The site is currently diverting over 50% of construction waste for the entire neighborhood and we feel that it would be wasteful to use additional independent dumpsters to individually collect and document 50% diversion of construction waste for these two specific buildings. In order to reduce the environmental effects of having multiple dumpsters and associated truck traffic for documenting diverted waste for each building, we propose using a combined recycling program and consolidated documentation for the entire site. Can these projects be eligible for the MRc2.1 point if the consolidated neighborhood debris diverted is above 50%? The project is currently diverting between 65-70% for the entire neighborhood and we anticipate this to continue for these two buildings as well.

Ruling:

The project team is requesting if it would be acceptable for LEED-NC and LEED-CS projects that are part of a LEED-ND application to achieve this credit using a "neighborhood wide" construction waste diversion tracking methodology. No, the project may not approach this credit with a neighborhood-wide formula, as individual buildings and spaces seeking certification need to be accountable for their individual construction waste management diversion rates and should be tracked and documented as such. It is at the discretion of the project team to utilize a single or comingled dumpster within the ND project, as long as the documentation and tracking requirements for achieving construction waste management diversions for the LEED-NC and LEED-CS portions of the project are met. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
11/1/2011
LEED Interpretation
Inquiry:

The proposed project site is located on a military base that has potentially unexploded ordnance on-site.Protection from potential detonation during construction is required by the federal government to shield pedestrians and existing housing across the street from the project site. As a part of the project, a detonation barrier is to be constructed prior to start of excavation. This barrier can be built using various material but must have substantial foundations and structural strength to withstand large explosion forces. After construction is completed, the detonation barriers would be deconstructed to allow access to the site.The project team is proposing to incorporate salvaged local material into the design of these barrier walls. May the salvaged material qualify for MR credit 2 Construction Waste Managementif recycled after deconstruction?

Ruling:

The project team has inquired whether materials used for a temporary (during construction) detonation barrier can be included within the construction waste management materials diverted since it is mandated to be built. If the temporary detonation barrier is recycled or salvaged after deconstruction, it meets the intent of MR Credit 2 (diversion from landfill and incineration) and may contribute towards construction waste management.

Campus Applicable
No
Internationally Applicable:
No
1/29/2009
LEED Interpretation
Inquiry:

Methodology #1 Each co-mingled load of construction debris is weighted at the MRF and visually inspected then the percentage of each recyclable material is tallied. The recyclable materials are then processed for sale on the secondary market. The tallied data is documented in a running monthly report created by either the MRF or the Hauler and is submitted to the contractor for the project. Methodology #2 The MRF\'s self-reported recycling percentage rate (for the entire facility) is applied toward specific LEED projects\' delivered co-mingled tonnage brought to that facility. We are aware of the CIR ruling dated 12.2.05 stating that a project can use this methodology if a facility has government oversight over a facility\'s recycling rate calculations. In our case we have government oversight of the MRFs overall recovery rates but the reporting methodology required by the oversight agency doesn\'t account for C&D debris - asphalt, gypsum wallboard, and concrete tonnage which is processed through those facilities. LEED NC v2.2 accepts and credits concrete towards MRc2 but this disconnect between how the oversight agency tracks materials versus what is actually processed in a facility doesn\'t allow for accurate reporting and subsequent award of LEED credit in our local market. Please let us know if one or both methods are acceptable for tracking and documenting co-mingled boxes for MRc2.

Ruling:

This CIR asks if the USGBC can advise if one or both of two listed methods for documenting the recycled content of commingled waste are acceptable. In Methodology #1, if the facility is giving project specific recycling rates, they need to document actual percentage of material recycled based on actual weight or volume of material. Visual inspection is not an acceptable method. For "Methodology #2," the facility must be able to document that the "method of recording and calculating the recycling rate is regulated by a local or state government authority" in accordance with CIR dated 12/2/2005. If the facility\'s reported recycling rate is regulated by a local or state government, then it can be used toward achievement of the credit. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
9/15/2008
LEED Interpretation
Inquiry:

Our LEED project consists of a 69,000 square foot addition to a 105,000 square foot University Athletic Center. The University will also partially renovate some portions of the existing Center, which consists of a series of buildings that date back to the 1930\'s. Although the renovation work in the existing Athletic Center will not seek LEED certification, the project team would like to implement as many sustainable strategies as possible on this work. For example, the construction team will be developing a Construction Waste Management Plan, consistent with the requirements of MRc2.1 (minimum 50% diversion from landfill), that will be utilized on both the Addition project and the renovation work. In order to streamline this waste management plan process, the project team would like to utilize a single set of dumpsters on site to sort the diverted and landfill materials. This will effectively commingle the materials for both projects, yet save the University the thousands of dollars it would cost to use and manage separate dumpsters. This will also eliminate any confusion as to which dumpster to use or not use as both the Addition project and the renovation work will be constructed within similar timeframes and in close location to each other. Thus, the project team is requesting USGBC clarification as to whether this streamlined approach is an acceptable means of complying with the intent of MRc2. The project team will ensure that at least 50% of the combined construction waste is diverted from landfill to comply with MRc2.1.

Ruling:

In the CIR above, the project team is seeking clarification on MRc2 as they are using LEED NC2.2 as the standard for a new addition to an existing athletic center. At the same time, unrelated renovation work is being done within the athletic center. The design team is requesting that material from a non-LEED project be allowed to commingle with the waste material from the LEED project. The CIR ruling dated 07/08/08 states that "individual buildings and spaces seeking certification need to be accountable for their individual construction waste management diversion rates and should be tracked and documented as such". Based on this CIR ruling, the project team should note that the material resulting from the renovation of the non-LEED project cannot be commingled with the material from the LEED NC addition project. This inclusion of material would lead to inaccurate calculations for MRc2.1. If the project team can devise and document a method that accurately assigns the waste from the two separate projects before combining, then this would be an acceptable compliance path. Please reference the CIR with a ruling date of 12/02/05 for guidance involving recognized commingling facilities and practices. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
1/1/2013
LEED Interpretation
Inquiry:

Is a campus-like approach for MRc2 acceptable for two LEED-NC v2009 registered projects each pursuing one-off certification? Space is limited on the urban site for recycling dumpsters, therefore the best approach for CWM may mean that waste and recycling for all LEED registered projects will need to be aggregated and tracked together. AGMBC Master Site / Campus is not utilized, yet we propose using the AGMBC precedent for MRc2 documentation. We propose to track together all demolition, construction waste/diverted, & land clearing material for the project and then apply a weighted average based on GSF to each LEED project.

Ruling:

The applicant has requested to use a weighted average approach for Materials and Resources Credit 2 Construction Waste Management for several buildings that are pursuing one-off LEED Certification under LEED BD&C. Yes, the project may utilize a weighted approach based on gross floor area to determine the total construction waste for each building pursuing certification. For each LEED BD&C Building, the project team will be required to identify the materials that are diverted from disposal and provide calculations documenting the diversion rate. Each building must meet the required threshold for waste diversion in order to earn the credit. In addition, the Construction Waste Management (CWM) Plan must outline goals for diversion for each building, not just as an aggregate across all projects. Note that if the waste is comingled and sorted offsite, the project may follow the requirements outlined in LEED Interpretation 3000 for determining and documenting the diversion rate. This ruling addresses only projects pursing LEED Certification under the BD&C Rating Systems and does not set any precedent or guidelines for projects pursuing certification under different LEED Rating Systems. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
2/6/2007
LEED Interpretation
Inquiry:

This CIR asks for further clarification of the ruling dated 3/23/2004 that states "Incineration cannot be used as an alternative method for diverting waste from the landfill for purposes of credit achievement." Our recycling facility processes construction and demolition (C&D) debris into numerous commodities. One of these products is Wood Derived Fuel (WDF) which is sold to local paper mills to replace virgin wood, natural gas and oil. While the product is burned, it is not incinerated. The USEPA has recently provided a category for such materials and defined them as Biofuel: A gaseous, liquid, or solid fuel that contains an energy content derived from a biological source. WDF has an energy content value of 8,500 Btus per pound of fuel and is derived from the collection, sorting and processing of C&D waste. The LEED Reference Guide defines recycling as "the collection, reprocessing, marketing and use of materials that are diverted or recovered from the solid waste stream." Before accepting co-mingled C&D debris for processing, the recycler we use demands that we provide Asbestos Hazard Emergency Response Act (A.H.E.R.A.) documentation proving the C&D loads have been inspected and abated. In addition, they maintain on-site testing equipment to detect lead & asbestos (such as XRF for lead and a polarized light microscope for asbestos). C&D debris that passes these tests is then accepted and sent through an elaborate sorting system where commodities ranging from LDPE plastic to Steel are separated and sold. Wood represents the largest volume of material they accept and is processed into 4-different commodities including WDF, Colorized Mulch, Pulp Furnish and Alternate Daily Cover. Facilities that purchase WDF have boiler permits that meet the requirements of 40 CFR Part 63 of the USEPA National Emission Standards (http://www.epa.gov/epacfr40/chapt-I.info/). Prior to the development of recycled WDF, most C&D wood waste was land filled and lumber mill saw dust was used as WDF. As the market for recycled WDF has developed, its use has resulted in lumber mill wood waste residuals traditionally consumed as fuel to be up-cycled into particle board, pulp and MDF, which is currently the highest use of this resource. . When C&D wood waste is land filled, the anaerobic conditions present in a landfill result in wood waste generating large quantities of methane gas. Methane gas has a global warming potential that is 23 times more hazardous than CO2 (http://www.rmi.org/sitepages/pid1215.php, November 08, 2006), where as consuming WDF in a modern industrial boiler is considered carbon neutral. The CIR ruling dated 3/23/2004 specifically denies diversion credit for C&D debris delivered to a mass-burn incinerator that uses excess heat to generate electricity, (Waste to Energy, WTE). The CIR recognized that the primary function of a WTE incinerator is to reduce the volume of waste placed in a landfill. The incinerator accepts everything that could be delivered to the landfill and they charge as much or more than is typically charged for landfill disposal. In contrast, our permitted recycling facility creates a recycled content commodity that is sold for profit. They manufacture WDF from a portion of the C&D debris they receive and they sell the WDF to paper mills that operate USEPA permitted industrial boilers to produce the heat energy needed to manufacture and recycle paper. Use of this product as a commodity is consistent with the LEED Reference Guides definition of recycling and with CIR dated 5/17/2004 for the production of Alternative Daily Cover. Audit documentation, such as receipts of sale of WDF to USEPA permitted facilities, can provide evidence of material diversion as WDF. For these reasons, we believe producing Wood Derived Fuel (WDF) meets the intent of the credit and seek to gain a ruling as such from the USGBC materials TAG.

Ruling:

Based on the process description provided, Wood Derived Fuel (WDF) meets the intent of this credit. The WDF process described differs from incineration processes that are not allowed in this credit because the recycling facility provides a value-added process; it is a service that exists to sort and distribute materials appropriate to the highest end uses possible. In addition, the revenue generated by the WDF commodity helps to make this business successful and thus facilitates recycling of wood to other end uses as well as recycling of other materials. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
4/22/2009
LEED Interpretation
Inquiry:

Our construction waste management plan includes collection of all cardboard, small wood scraps, and gypsum in a mixed container to be shipped to Martins Farm in Greenfield, MA, 36 miles from the construction site in Putney, VT. At Martins Farm, these waste products will be composted along with other waste materials. The resulting organic approved compost is sold, in bulk and in bags, to area organic farmers for use as a soil additive. Does this process satisfy the requirements of MRc2?

Ruling:

The project is seeking clarification that the processing of the cardboard, small wood scraps, and gypsum into soil amendment for use in agriculture is an acceptable form of material diversion from landfills and incinerators. Yes, the composting of construction material for reuse meets the credit requirements and can be included in the calculations for MRc2. Applicable Internationally.

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

Our LEED NC v2.2 registered project includes pursuit of MRc2 - Construction Waste Management credits and we would like to know if our strategy for compliance is acceptable. We have been actively sorting and recycling wood, concrete/masonry, metals, cardboard, paper and plastic in a region of the country which has severely limited available CDL recycling facilities, due primarily to the negative impacts of hurricane Katrina in 2005. To date, approximately 16,000CY of excavated soil from our project site has been removed and donated to a non-profit, private school to assist in preparing their site on campus facility expansions. The school site is located approximately 500 feet from our project site. If the excavated soil were to have been hauled off to a landfill, the travel distance would have been greater than 25 miles one-way. It is projected that an additional 1,000CY of excavated soil from the project site will also be made available to the school as our project progresses. We are aware the LEED NC v2.2 MRc2 - Construction Waste Management credit requirements indicate excavated soil does not contribute to this credit, however the excavated soil was donated to a neighboring school which the credit requirements make special note that ".diversion may include donation of materials to charitable organizations.". We believe we are meeting the intent of the credit by diverting construction and demolition debris from disposal in area landfills and in addition, we are significantly reducing environmental impact from transportation vehicle emissions and providing a non-profit organization with materials to provide site expansion.

Ruling:

While your strategy for handling excavated soil provides environmental benefit in reduced transportation of materials, it does not justify inclusion of excavated soil in MRc2. It is understood that many projects face challenges related to local market conditions for recycling. However, the weight of the soil would overwhelm the total amount of construction and demolition waste and enable credit achievement without addressing those impacts. As a result, the donated soil cannot be included in MRc2. You may want to consider evaluating the environmental benefits of the soil donation in the context of overall project emissions during construction and applying for an Innovation credit. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/9/2011
LEED Interpretation
Inquiry:

Is lead-based paint containing material considered hazardous for the purposes of LEED and therefore eligible for exclusion from the calculations of waste diversion?

Ruling:

Yes, teams may exclude lead-based paint contaminated drywall from your construction waste management calculations. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/17/2002
LEED Interpretation
Inquiry:

This project has contracted with the construction waste hauling company Richard S. Burns and Company, Inc. (here after known as RSBCO) who will take all construction waste from our project and recycle about 90% of it through a patented process that produce several products. These recycled construction waste products are unconventional and one of the products is sold for use in landfill operations. We would like the USGBC to confirm that these products made from construction waste meet the intent of the MR Credit 2 - the diversion of construction waste into the commercial products stream - thereby qualifying our project for MR credits 2.1 and 2.2. RSBCO has developed and patented a specific process of receiving, sorting, grinding, and blending construction waste materials to recover recyclable materials and produce desired products from the rest of the waste. The process begins with screening out fine particles for later use. The material then moves through a positive sorting process where individually recyclable materials like ferrous and non-ferrous metals, cardboard, masonry, and wood are recovered. RSBCO sells ferrous and non-ferrous metals and cardboard to secondary processing markets. On-site, RSBCO processes masonry and wood into a clean fill product used around pipes, in drainage trenches, or as substrate for road construction. We think the recovered recyclable materials and the clean fill product both clearly meet the intent of the MR credit 2.The process continues with negatively sorting the remaining construction material to remove undesirable materials such as plastic trash bags and clothing. This undesirable material represents less than 10% of total materials received and is continuously scrutinized for further recycling opportunities. The remaining material is then ground, screened again for metal recovery, and sized. The ground and crushed aggregate from all stages of the process are then blended in specific proportion to create a product called Barrier

Ruling:

This approach seems to meet the intent of MR Credits 2.1 and 2.2. Keep track of recycling rates according to credit requirements. The only clarification necessary is whether the Barrier product described is in fact used as a cover material with value to the landfill. Because the credit language requires the project to demonstrate recycling, salvage, and landfill rates, you will need to provide some documentation that the Barrier product is USED BY the landfill as described, and not just DISCARDED AT the landfill.

Campus Applicable
No
Internationally Applicable:
No
7/2/2008
LEED Interpretation
Inquiry:

The project team is seeking direction regarding Construction Waste Management. In order to minimize the environmental impact associated with construction waste, consistent with the Credit requirements, the team plans to prevent concrete washout waste from being transported to landfill by means of diversion to an on-site washout pit. This waste will be deposited on top of existing bedrock and then covered with soil from the project site. The existing bedrock in the area that we are proposing is 6\' to 8\' below the surface, and is under the new parking lot we are constructing. No future construction is planned in this area. By utilizing this method of diversion, the project team would eliminate the environmental impacts associated with fracturing, loading and transporting the concrete waste to a facility off-site for recycling. Additionally, in order to divert this material by means of removal to an off-site facility, the team would need to utilize heavy construction equipment to dig the hardened concrete material out of the pit. This method would consume a significant amount of energy and negatively impact the carbon footprint associated with this material and the project. In summary, the team is attempting to meet intent of this Credit in a manner that causes the least environmental impact by diverting construction waste on-site. Therefore, the construction team would like to measure the cubic yardage of concrete to be left in the wash-out pit and convert this volume to weight by using a solid waste conversion factor of 146 lbs/cubic foot as provided by the concrete supplier. The weight of this material, which will ultimately be diverted from the landfill in the most sustainable way possible, would then be applied toward the diverted material quantity for MRc2. We are requesting clarification as to whether USGBC believes this methodology is in compliance with the requirements of this Credit.

Ruling:

The project team is requesting that on-site burial of concrete from the wash out area be considered landfill diversion. No, the intent of this credit is to, "Divert construction, demolition and land-clearing debris from disposal in landfills and incinerators. Redirect recyclable recovered resources back to the manufacturing process. Redirect reusable materials to appropriate sites." The described actions are not much different than creating micro landfills. While there are environmental benefits to on-site disposal in the avoided vehicle miles, the described actions do not reuse or recycle this material. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/9/2011
LEED Interpretation
Inquiry:

In the waste diversion process many questions have come up regarding utilizing Waste-to-Energy as a landfill diverstion strategy. Can Waste-to-Energy be utilized as a landfill diversion strategy if; this effort ran parallel to sorting recyclable and reusable materials, and the power plant proposed has approved EPA pollution control devices. Alternatively, can paying additional cost to transport non recyclable trash to a Waste-to Energy power plant to be incinerated and converted into electrical energy count as diverted waste?

Ruling:

Only wood derived fuel can contribute to MRc2 in this manner. Incineration cannot be used as an alternative method for diverting waste from the landfill for purposes of credit achievement. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
6/8/2009
LEED Interpretation
Inquiry:

During construction while excavating for placement of compacted sub-grade and asphalt, limestone was found on our project site. Due to its location and interference with the parking surface elevation, the rock was removed and donated to the local county which was used for permanent erosion control on a different project site. Although the reference guide disregards excavated soil and land clearing debris from this credit, we propose that the limestone as a product differs from the "land clearing debris" because it is a material which can be recycled into another product that otherwise would have had to been extracted and manufactured. We believe that this attribute of the limestone allows it to count as a "reusable material". We also believe that the donation and redirection of the limestone as a reusable material for a different site, not only meets the intent of this credit by diverting waste, but is also an acceptable manner (as defined by the reference guide) by which to qualify for the credit as it is "redirecting reusable materials to appropriate sites". In keeping with the intent of this credit, can we include this rock in our MRc2 Construction Waste Management Calculations?

Ruling:

**Update October 1, 2013: This ruling is no longer valid. Please see LI 10062 for more information and an update ruling.
The project is proposing to include excavated limestone as diverted construction waste because it was given to another project to be used as permanent erosion control on another project. The LEED Reference Guide explicitly defines rock as land clearing debris and thus it can not be included in credit calculations. Previous CIR rulings dated 9/9/2008 and 3/4/2004 state the same conclusion.

Campus Applicable
No
Internationally Applicable:
Yes
8/2/2008
LEED Interpretation
Inquiry:

WCA Bondad Landfill has developed a plan for LEED-NCv2.2, MRc2, Construction Waste Management for a project in Western Colorado. Due to limited options for waste recycling in this rural region of Colorado, WCA Bondad Landfill has developed an alternate approach that we believe is consistent with the intent of MRc2 and with previous CIR rulings. Two waste bins will be placed on the job site. One bin will be placed for general refuse (commonly known as "MSW" or "Municipal Solid Waste"), which is non-recyclable trash (food waste, etc.). The other bin will be reserved for materials to be utilized as alternate daily cover ("ADC"), also known as "beneficial layer" at the landfill. This material will include large plastic, packaging material, non-contaminated soil that cannot be used on-site and any other clean trash or construction waste materials that there are no recycling options for in the area. All ferrous metals will be diverted and recycled. Masonry, concrete, and sheetrock will be reused on site as fill and soil amendment. Federal regulations require waste disposal facilities to cover the working face of a landfill at the end of each operating day with six inches of earthen material, or an approved ADC. As noted in a CIR for MR Credit 2.1 (Inquiry ID 0277-MRc21-041902) landfills typically use soil from the initial excavation of the pit as the daily cover material. However, landfills in southwestern Colorado - and around the country - run out of clean fill from their own excavation stocks. At times, WCA Bondad Landfill mines clean earth, or purchases soil which is routinely trucked from soil quarries at a distance. WCA\'s processing and use of this non-recyclable contractor waste as ADC will prevent the need for WCA to mine, purchase or transport ADC, thus effectively diverting materials from the waste stream by reusing them at the landfill. Our approach will be consistent with a CIR dated 5/17/2002 in which non-recyclable material is processed at the landfill and used as Alternate Daily Cover. The difference here is that the material processed to be used as ADC will not be marketed as a product for sale or for use elsewhere, as was the Barrier product referenced in the previous CIR. The environmental benefits will be the same however. Consistent with the CIR dated 5/17/2002, all quantities will be tracked and actual use at the landfill will be documented. Please confirm that our approach is compliant with NCv2.2, MRc2.

Ruling:

The project is inquiring whether the intent of MRc2 is met when project materials are used as alternative daily cover (ADC) at a landfill. Any construction debris processed into a recycled content commodity which has an open market value - e.g. alternative daily cover material, etc. - may be applied to the construction waste calculation. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/9/2011
LEED Interpretation
Inquiry:

Can waste diversion rates be documented as an average recycling rate for an integrated waste management operation serving a market area as opposed to the average for a single facility?Does the USGBC offer a prescriptive method for facilities to back-up commingle recycling percentage claims? Is visual inspection of project loads an acceptable method for documenting recycling rates? When calculating recycling percentages the USGBC does not seem to have a limit on how much ADC can be claimed as a "recyclable" commodity.

Ruling:

A system recycling rate is acceptable as long, as the recycling rate utilized is regulated by a local or state government authority as a closed system, in compliance with the LEED-NC 2.1 CIR dated 12/2/2005 (#3000).For project using a project specific diversion rate, visual inspection is not an acceptable method of inspection for purposes of documenting percentage of commingled waste diverted from landfill. Currently ADC is an acceptable method for compliance with this credit. ADC meets the intent of MRc2. At this time there is no limit as to how much ADC can be used to fulfill credit compliance. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
12/4/2006
LEED Interpretation
Inquiry:

Is it possible to achieve MR credits 2.1-2.2 by way of a construction management plan that utilizes a nearby waste recovery facility with a very high recycling rate that sorts and distributes wholly co-mingled debris from the construction site? Our project intends to work with a nearby waste recovery company, Taylor Recycling Facility, LLC, where a single container is provided for all the construction waste on site. Each full container is transported to their New York State Department of Environmental Conservation (DEC) Part 360 Permitted Construction & Demolition processing facility in which it is initially weighed by a certified NYS weigh master. The co-mingled debris is then screened, processed, and sorted manually into the various recycled product categories; if further processing is required at other facilities, names will be identified on the supplied monthly waste management reporting form. Any non recyclable materials are transported to a solid waste transfer station or landfill for legal disposal. The facility will intermittently provide a total weight of the removed co-mingled debris specific to our project, as well as general facility percentage rates of all waste that is recycled, reused, salvaged, or landfilled, based on the facility\'s monthly Construction and Demolition Plan. The intent of this credit is to "divert construction, demolition, and land-clearing debris from disposal in landfills; to redirect recyclable recovered resources back to the manufacturing process." By redirecting all of the waste created by our project to a facility that has made it their business and mission to transform the waste management industry into a sustainable process, it is made certain that the intent of this credit is performed correctly and efficiently. Furthermore, Taylor Recycling Facility, LLC has a very high recycling rate, typically greater than 97%: if the DEC documents this facility as attaining a 95% or higher salvage rate, does this also merit an additional ID credit? This is in reference to a previous CIR ruling dated January 11, 2005 which stated that the threshold for diverting construction waste is set at 95%.

Ruling:

Yes, tracking the amount of construction waste diverted from the landfill based on the weight of the removed co-mingled debris from a sorting facility is an acceptable method of documentation for this credit, as per NCv2.1 MRc2.1 CIR ruling dated 12/2/2005. A local or state government authority must regulate the facility\'s method of recording. 95% landfill diversion of construction waste (% = recycled quantity divided by total amount [recycled + waste quantity] times 100) is the established threshold for achievement of an innovation credit. Project must submit documentation that construction loads sent are respectably close to the recovery facility\'s average recycling rate in order to achieve this additional credit. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
1/30/2009
LEED Interpretation
Inquiry:

Our project is being built on what was once a City-owned asphalt parking lot. All the asphalt was removed, taken to a recycling plant, and crushed. We are not able to re-use the asphalt on our particular site for fill, however the asphalt will be used as fill on several other projects around town. The company that hauled the asphalt specializes in recycling and redistributing concrete, rock, and asphalt for use as fill in construction projects. Although the book states the asphalt needs to be crushed and re-used on site, we feel we are meeting the intent of the credit since we are diverting demolition debris from landfill and incinerators, and we are redirecting reusable materials to appropriate sites.

Ruling:

The credit intent has been met as demolition debris has been diverted from disposal in landfills and incinerators. In this instance, reusable materials have been redirected to appropriate sites. The credit does not require that crushed asphalt be reused on site, so long as it is diverted from landfills and incinerators. On-site reuse of crushed concrete, masonry or asphalt is also acceptable in the calculation for this credit. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/14/2007
LEED Interpretation
Inquiry:

Our project is located on a Washington State DSHS-JRA Juvenile Rehabilitation Administration (Detention) Campus in Chehalis called Green Hill School. The project consists of two new commercial buildings replacing two obsolete buildings (demolished in this project). Both new buildings, Heath Center/Administration (HCA) and Intensive Management Unit (IMU), will be placed on the same site area (building footprint) as one of the obsolete buildings (Building \'X\'). Each new building footprint covers approximately 1/2 the existing footprint of the obsolete Building \'X\'. After the demolition of the 2nd obsolete building (Building \'W\'), this area and other disturbed areas will be restored with native/adaptive landscaping to create a green space. Only the HCA building will be pursuing USGBC recorded status of LEED Silver. The HCA building consists of a Health Center including medical, dental, and mental health services on the first floor and Administration offices on the second floor. This project will be completed in 3 phases, two bid packages and two separate Contractors. We are proposing one consistent LEED boundary that we will use for all the LEED credit. The entire project will have 3 different construction and TESC boundaries that will be different from the LEED boundary due to the phasing of demolition and construction and the inclusion of the IMU bldg (which is not pursuing LEED) in the construction boundary. Bid Pack #1 - Site Utilities and Demolition of Building \'X\' summer \'07 Bid Pack #2 - Phase I - New Construction of HCA & IMU building (in footprint of demolished bldg \'X\') spring to winter \'08 Phase II - Demolition of Bldg \'W\' and restoration of native/adaptive landscaping winter \'08/spring \'09 We could include 1/2 of Bldg \'X\' within our LEED boundary OR exclude Building \'X\' demolition from the LEED scope of work. We are planning to divert this demolition waste from the landfill, but the paperwork may be confusing with only 1/2 the building counting towards our LEED credits and the paper work from demolition of Building \'X\' will be from a different Contractor. Bldg \'W\' will be included in the LEED boundary and is in the same Bid Pack #2 that includes the new construction, although this demolition and restoration of landscape will be Phase II. Prior to demolition, a full hazardous material abatement would be completed to abate asbestos, mercury, and lead based paints. Demolition of building \'X\' and \'W\' would mostly consist of grinding up concrete into a rocky base coarse which would be used as base material along the perimeter road of the secured campus. Temporary stockpiling of soils from demolition of Building \'X\' and preparation of the site will be used to fill-in area of demolition of Building \'W\'. We propose that the LEED boundary for our HCA building would include half of the footprint of the demolished Building \'X" and the entire footprint of the demolished building \'W\' (excluding the other new building - IMU building which in located over the other 1/2 of Building \'X\'). The inquiry is: Is our proposal for our LEED boundary acceptable? Based on the LEED site boundary described above, is it permissible to have 3 different phased TESC boundaries and Construction boundaries beyond the one consistent LEED boundary for the HCA building? Is it permissible to calculate only the portion of the demolition of Bldg \'X\' which is in the LEED boundary toward MRc2 with the paper work being provided from a different contractor?

Ruling:

The applicant is asking whether their proposed LEED boundary and allocation of demolition debris is acceptable. The proposed LEED boundary is acceptable as long is it is used consistently across all LEED credits. The allocation of only the portion of demolished Building "X" within the LEED boundary is also consistent with credit requirements. The allocation of the entire demolition of Building "W" is acceptable, as long as this is within the scope of the project seeking LEED certification. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
12/2/2005
LEED Interpretation
Inquiry:

Our project is located in Los Angeles, California. Construction waste is sorted at the jobsite into various boxes i.e. wood, metal, concrete/inert material, drywall/gypsum, co-mingled recycled waste (small wood scraps, wire cuttings, conduit, metal stud cut offs, etc.), and general trash boxes. A contracted hauler regularly collects these boxes. General trash is taken directly to the landfill where it is weighed and then buried. Separated recycling materials are taken to various certified City of Los Angeles recycling facilities where they are weighed and processed. Co-mingled recycled waste is taken to special certified recycling facilities where the co-mingled mix is weighed and then the recyclable materials are removed from the mix and sent to appropriate facilities for processing. This process does not allow for each recyclable material type from the co-mingled load to be weighed separately. The City of Los Angeles\' Department of Sanitation audits all of the co-mingled sorting facilities on a regular basis and establishes a yearly average recycling percentage rate for "each" facility. The certification recycling percentage rates vary. When calculating the construction waste recycling percentage for MRc2.1, will the USGBC accept the City of Los Angeles\' annual recycling percentage rate for the "specific" facility that accepts this LEED project\'s co-mingled component of the project\'s waste stream?

Ruling:

The average annual recycling rate for the specific sorting facility 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 is the case for your project). Applicable Internationally.UPDATE 10/1/12: Made applicable to LEED EB 2008 and 2009.

Campus Applicable
No
Internationally Applicable:
Yes
6/19/2008
LEED Interpretation
Inquiry:

Our major renovation project is a high-rise building in Germany. One of the recycling methods we apply is underground waste disposal, also called mine backfill (Bergversatz), a method which, in Germany, is governed by statutory provisions. Since with our project, a relatively large amount of material (gypsum waste, sheet glass, gypsum fiberboard panels, etc.) is disposed of in this manner, we would like to make sure that this way of recycling is acceptable in line with the Credit Intent. Underground waste disposal or mine backfill means that exploited deep mines are backfilled with liquid or solid mining or non-mining materials. Depending on their nature, the filling materials are stored in barrels or packed in big bags and their storage is controlled. The backfill may also consist of bulk material. Under the German Closed Substance Cycle and Waste Management Act (Kreislaufwirtschafts- und Abfallgesetz) and, in addition, under the German ordinance on the underground disposal of waste (Bergversatzverordnung) it is specified that if this disposal serves an economic purpose, e.g. if it prevents a mine from collapsing by filling it air-free, it is not considered as waste disposal but rather as waste recycling. Furthermore, for every 500 metric tons, analyses must be performed and submitted which confirm that the underground waste material is recognized as safe. As under the applicable German laws and regulations, underground waste disposal is recognized as recycling, we would like to know whether this recycling method complies with the requirements of the LEED Credit Intent and whether LEED also recognizes underground waste disposal as a means of recycling?

Ruling:

The applicant has requested acceptance of mine backfilling as an equivalent means of accomplishing construction waste management. Based on the description of the process, it does not appear that this practice will meet the intent of the credit. In addition to encouraging the diversion of debris from landfills, the credit intent includes an expectation that projects "redirect recyclable recovered resources back to the manufacturing process." While it is recognized that using clean waste material from construction rather than other potential materials to back fill deep mines may be environmentally preferable, this practice is not aligned with the intent of the credit. The waste is in essence going to a "landfill" and the specific materials noted (gypsum and glass) are known to be potential feed stocks for manufacturing processes. By using them as fill material, the proposed practice is burying potentially valuable raw materials. Underground waste disposal is not a recognized means of recycling for this credit. Applicable Internationally; Germany.

Campus Applicable
No
Internationally Applicable:
Yes
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Requirements

Recycle and/or salvage nonhazardous construction and demolition debris. Develop and implement a construction waste management plan that, at a minimum, identifies the materials to be diverted from disposal and whether the materials will be sorted on-site or comingled. Excavated soil and land-clearing debris do not contribute to this credit. Calculations can be done by weight or volume, but must be consistent throughout. The minimum percentage debris to be recycled or salvaged for each point threshold is as follows:

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The waste management facility we are using is providing us with monthly documentation specific to our waste, showing 80% diversion. They also have a published, facility-wide rate of roughly 20%, and they have no published rate for construction waste. Will our diversion rate be accepted, or do we need to use a facility with an appropriate published rate?

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How is construction waste accounted for when utilizing off-site construction, like modular construction or pre-fabrication of assemblies?

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How does MRc2 work for projects pursuing a campus approach, or any project where waste management will be shared with other construction projects?

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Can materials that have been unused and returned to the manufacturer as part of a “take-back” program contribute to the credit?

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Should I include hazardous material such as lead-based paint in MRc2 calculations?

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Should household-type trash from workers' lunches and office use be included in MRc2 diversion and calculations?

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Can sending material to waste-to-energy plants count toward MRc2?

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The requirements of this credit say that land-clearing debris does not contribute to the percentage of materials diverted from the landfill. What exactly is considered "land clearing debris"?

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Oops! Our trash was measured by both weight and volume at different times. How do I standardize this?

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5/9/2011Updated: 5/31/2017
Reference Guide Correction
Description of change:
Add the following to end of first paragraph:For commingled recycling the average annual recycling rate for a sorting facility is acceptable for recording diversion rates only when the facility\'s method of recording and calculating the recycling rate is regulated by a local or state government authority.
Campus Applicable
No
Internationally Applicable:
No
5/9/2011
LEED Interpretation
Inquiry:

A CS project is inheriting an existing building that still has furniture from the previous tenant. The project team is seeking clarification on how to account for this furniture in MRc2 and how to document the selling of this furniture to a re-seller.

Ruling:

Furniture may be included within its own category, without the need to breakdown the material composition unless components of the furniture are to be salvaged independently. In addition, diversion by re-sale is acceptable. The project team is required to document the receiving company (such as through a contract or sales receipt) and confirm that furniture is intended to be re-sold by that company. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
1/28/2008
LEED Interpretation
Inquiry:

When removing petroleum contaminated soils there are two options for disposal. One would be to haul the contaminated soils to a hazardous materials landfill. The other option is to incinerate the soil to burn off the petroleum and remediate the soil into a environmentally safe product. In the case of Biomed project we elected to have the contaminated soils recycled (incinerated). During the site cleanup WT removed 787.4 TONS of contaminated soils from the project site. We are currently applying for the "Brownfield Credit" which all of this documentation will be sent to document the cleanup. Also LEED specifically says that land clearing waste (soils) cannot be included in the waste management plan, but for this case we feel that because of the soils were recycled from a hazardous material that we should be able to apply the tonnage to our waste management calculations. Can we use this toward this credit too?

Ruling:

Incinerating soil to remove contamination can not be considered recycling and apply to MRc2. It is not clear that incinerating contaminated soil is environmentally preferable to landfilling. Both hazardous waste and soil must be excluded from calculations for MRc2, and incineration is not an allowable diversion method, per the LEED-NC v2.2 Reference Guide. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
7/8/2008
LEED Interpretation
Inquiry:

Within a LEED-ND Pilot registered neighborhood project, two buildings come into question: a LEED NCv2.2 registered hotel and a LEED CS registered mixed-use office building. The site is currently diverting over 50% of construction waste for the entire neighborhood and we feel that it would be wasteful to use additional independent dumpsters to individually collect and document 50% diversion of construction waste for these two specific buildings. In order to reduce the environmental effects of having multiple dumpsters and associated truck traffic for documenting diverted waste for each building, we propose using a combined recycling program and consolidated documentation for the entire site. Can these projects be eligible for the MRc2.1 point if the consolidated neighborhood debris diverted is above 50%? The project is currently diverting between 65-70% for the entire neighborhood and we anticipate this to continue for these two buildings as well.

Ruling:

The project team is requesting if it would be acceptable for LEED-NC and LEED-CS projects that are part of a LEED-ND application to achieve this credit using a "neighborhood wide" construction waste diversion tracking methodology. No, the project may not approach this credit with a neighborhood-wide formula, as individual buildings and spaces seeking certification need to be accountable for their individual construction waste management diversion rates and should be tracked and documented as such. It is at the discretion of the project team to utilize a single or comingled dumpster within the ND project, as long as the documentation and tracking requirements for achieving construction waste management diversions for the LEED-NC and LEED-CS portions of the project are met. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
11/1/2011
LEED Interpretation
Inquiry:

The proposed project site is located on a military base that has potentially unexploded ordnance on-site.Protection from potential detonation during construction is required by the federal government to shield pedestrians and existing housing across the street from the project site. As a part of the project, a detonation barrier is to be constructed prior to start of excavation. This barrier can be built using various material but must have substantial foundations and structural strength to withstand large explosion forces. After construction is completed, the detonation barriers would be deconstructed to allow access to the site.The project team is proposing to incorporate salvaged local material into the design of these barrier walls. May the salvaged material qualify for MR credit 2 Construction Waste Managementif recycled after deconstruction?

Ruling:

The project team has inquired whether materials used for a temporary (during construction) detonation barrier can be included within the construction waste management materials diverted since it is mandated to be built. If the temporary detonation barrier is recycled or salvaged after deconstruction, it meets the intent of MR Credit 2 (diversion from landfill and incineration) and may contribute towards construction waste management.

Campus Applicable
No
Internationally Applicable:
No
1/29/2009
LEED Interpretation
Inquiry:

Methodology #1 Each co-mingled load of construction debris is weighted at the MRF and visually inspected then the percentage of each recyclable material is tallied. The recyclable materials are then processed for sale on the secondary market. The tallied data is documented in a running monthly report created by either the MRF or the Hauler and is submitted to the contractor for the project. Methodology #2 The MRF\'s self-reported recycling percentage rate (for the entire facility) is applied toward specific LEED projects\' delivered co-mingled tonnage brought to that facility. We are aware of the CIR ruling dated 12.2.05 stating that a project can use this methodology if a facility has government oversight over a facility\'s recycling rate calculations. In our case we have government oversight of the MRFs overall recovery rates but the reporting methodology required by the oversight agency doesn\'t account for C&D debris - asphalt, gypsum wallboard, and concrete tonnage which is processed through those facilities. LEED NC v2.2 accepts and credits concrete towards MRc2 but this disconnect between how the oversight agency tracks materials versus what is actually processed in a facility doesn\'t allow for accurate reporting and subsequent award of LEED credit in our local market. Please let us know if one or both methods are acceptable for tracking and documenting co-mingled boxes for MRc2.

Ruling:

This CIR asks if the USGBC can advise if one or both of two listed methods for documenting the recycled content of commingled waste are acceptable. In Methodology #1, if the facility is giving project specific recycling rates, they need to document actual percentage of material recycled based on actual weight or volume of material. Visual inspection is not an acceptable method. For "Methodology #2," the facility must be able to document that the "method of recording and calculating the recycling rate is regulated by a local or state government authority" in accordance with CIR dated 12/2/2005. If the facility\'s reported recycling rate is regulated by a local or state government, then it can be used toward achievement of the credit. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
9/15/2008
LEED Interpretation
Inquiry:

Our LEED project consists of a 69,000 square foot addition to a 105,000 square foot University Athletic Center. The University will also partially renovate some portions of the existing Center, which consists of a series of buildings that date back to the 1930\'s. Although the renovation work in the existing Athletic Center will not seek LEED certification, the project team would like to implement as many sustainable strategies as possible on this work. For example, the construction team will be developing a Construction Waste Management Plan, consistent with the requirements of MRc2.1 (minimum 50% diversion from landfill), that will be utilized on both the Addition project and the renovation work. In order to streamline this waste management plan process, the project team would like to utilize a single set of dumpsters on site to sort the diverted and landfill materials. This will effectively commingle the materials for both projects, yet save the University the thousands of dollars it would cost to use and manage separate dumpsters. This will also eliminate any confusion as to which dumpster to use or not use as both the Addition project and the renovation work will be constructed within similar timeframes and in close location to each other. Thus, the project team is requesting USGBC clarification as to whether this streamlined approach is an acceptable means of complying with the intent of MRc2. The project team will ensure that at least 50% of the combined construction waste is diverted from landfill to comply with MRc2.1.

Ruling:

In the CIR above, the project team is seeking clarification on MRc2 as they are using LEED NC2.2 as the standard for a new addition to an existing athletic center. At the same time, unrelated renovation work is being done within the athletic center. The design team is requesting that material from a non-LEED project be allowed to commingle with the waste material from the LEED project. The CIR ruling dated 07/08/08 states that "individual buildings and spaces seeking certification need to be accountable for their individual construction waste management diversion rates and should be tracked and documented as such". Based on this CIR ruling, the project team should note that the material resulting from the renovation of the non-LEED project cannot be commingled with the material from the LEED NC addition project. This inclusion of material would lead to inaccurate calculations for MRc2.1. If the project team can devise and document a method that accurately assigns the waste from the two separate projects before combining, then this would be an acceptable compliance path. Please reference the CIR with a ruling date of 12/02/05 for guidance involving recognized commingling facilities and practices. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
1/1/2013
LEED Interpretation
Inquiry:

Is a campus-like approach for MRc2 acceptable for two LEED-NC v2009 registered projects each pursuing one-off certification? Space is limited on the urban site for recycling dumpsters, therefore the best approach for CWM may mean that waste and recycling for all LEED registered projects will need to be aggregated and tracked together. AGMBC Master Site / Campus is not utilized, yet we propose using the AGMBC precedent for MRc2 documentation. We propose to track together all demolition, construction waste/diverted, & land clearing material for the project and then apply a weighted average based on GSF to each LEED project.

Ruling:

The applicant has requested to use a weighted average approach for Materials and Resources Credit 2 Construction Waste Management for several buildings that are pursuing one-off LEED Certification under LEED BD&C. Yes, the project may utilize a weighted approach based on gross floor area to determine the total construction waste for each building pursuing certification. For each LEED BD&C Building, the project team will be required to identify the materials that are diverted from disposal and provide calculations documenting the diversion rate. Each building must meet the required threshold for waste diversion in order to earn the credit. In addition, the Construction Waste Management (CWM) Plan must outline goals for diversion for each building, not just as an aggregate across all projects. Note that if the waste is comingled and sorted offsite, the project may follow the requirements outlined in LEED Interpretation 3000 for determining and documenting the diversion rate. This ruling addresses only projects pursing LEED Certification under the BD&C Rating Systems and does not set any precedent or guidelines for projects pursuing certification under different LEED Rating Systems. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
2/6/2007
LEED Interpretation
Inquiry:

This CIR asks for further clarification of the ruling dated 3/23/2004 that states "Incineration cannot be used as an alternative method for diverting waste from the landfill for purposes of credit achievement." Our recycling facility processes construction and demolition (C&D) debris into numerous commodities. One of these products is Wood Derived Fuel (WDF) which is sold to local paper mills to replace virgin wood, natural gas and oil. While the product is burned, it is not incinerated. The USEPA has recently provided a category for such materials and defined them as Biofuel: A gaseous, liquid, or solid fuel that contains an energy content derived from a biological source. WDF has an energy content value of 8,500 Btus per pound of fuel and is derived from the collection, sorting and processing of C&D waste. The LEED Reference Guide defines recycling as "the collection, reprocessing, marketing and use of materials that are diverted or recovered from the solid waste stream." Before accepting co-mingled C&D debris for processing, the recycler we use demands that we provide Asbestos Hazard Emergency Response Act (A.H.E.R.A.) documentation proving the C&D loads have been inspected and abated. In addition, they maintain on-site testing equipment to detect lead & asbestos (such as XRF for lead and a polarized light microscope for asbestos). C&D debris that passes these tests is then accepted and sent through an elaborate sorting system where commodities ranging from LDPE plastic to Steel are separated and sold. Wood represents the largest volume of material they accept and is processed into 4-different commodities including WDF, Colorized Mulch, Pulp Furnish and Alternate Daily Cover. Facilities that purchase WDF have boiler permits that meet the requirements of 40 CFR Part 63 of the USEPA National Emission Standards (http://www.epa.gov/epacfr40/chapt-I.info/). Prior to the development of recycled WDF, most C&D wood waste was land filled and lumber mill saw dust was used as WDF. As the market for recycled WDF has developed, its use has resulted in lumber mill wood waste residuals traditionally consumed as fuel to be up-cycled into particle board, pulp and MDF, which is currently the highest use of this resource. . When C&D wood waste is land filled, the anaerobic conditions present in a landfill result in wood waste generating large quantities of methane gas. Methane gas has a global warming potential that is 23 times more hazardous than CO2 (http://www.rmi.org/sitepages/pid1215.php, November 08, 2006), where as consuming WDF in a modern industrial boiler is considered carbon neutral. The CIR ruling dated 3/23/2004 specifically denies diversion credit for C&D debris delivered to a mass-burn incinerator that uses excess heat to generate electricity, (Waste to Energy, WTE). The CIR recognized that the primary function of a WTE incinerator is to reduce the volume of waste placed in a landfill. The incinerator accepts everything that could be delivered to the landfill and they charge as much or more than is typically charged for landfill disposal. In contrast, our permitted recycling facility creates a recycled content commodity that is sold for profit. They manufacture WDF from a portion of the C&D debris they receive and they sell the WDF to paper mills that operate USEPA permitted industrial boilers to produce the heat energy needed to manufacture and recycle paper. Use of this product as a commodity is consistent with the LEED Reference Guides definition of recycling and with CIR dated 5/17/2004 for the production of Alternative Daily Cover. Audit documentation, such as receipts of sale of WDF to USEPA permitted facilities, can provide evidence of material diversion as WDF. For these reasons, we believe producing Wood Derived Fuel (WDF) meets the intent of the credit and seek to gain a ruling as such from the USGBC materials TAG.

Ruling:

Based on the process description provided, Wood Derived Fuel (WDF) meets the intent of this credit. The WDF process described differs from incineration processes that are not allowed in this credit because the recycling facility provides a value-added process; it is a service that exists to sort and distribute materials appropriate to the highest end uses possible. In addition, the revenue generated by the WDF commodity helps to make this business successful and thus facilitates recycling of wood to other end uses as well as recycling of other materials. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
4/22/2009
LEED Interpretation
Inquiry:

Our construction waste management plan includes collection of all cardboard, small wood scraps, and gypsum in a mixed container to be shipped to Martins Farm in Greenfield, MA, 36 miles from the construction site in Putney, VT. At Martins Farm, these waste products will be composted along with other waste materials. The resulting organic approved compost is sold, in bulk and in bags, to area organic farmers for use as a soil additive. Does this process satisfy the requirements of MRc2?

Ruling:

The project is seeking clarification that the processing of the cardboard, small wood scraps, and gypsum into soil amendment for use in agriculture is an acceptable form of material diversion from landfills and incinerators. Yes, the composting of construction material for reuse meets the credit requirements and can be included in the calculations for MRc2. Applicable Internationally.

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

Our LEED NC v2.2 registered project includes pursuit of MRc2 - Construction Waste Management credits and we would like to know if our strategy for compliance is acceptable. We have been actively sorting and recycling wood, concrete/masonry, metals, cardboard, paper and plastic in a region of the country which has severely limited available CDL recycling facilities, due primarily to the negative impacts of hurricane Katrina in 2005. To date, approximately 16,000CY of excavated soil from our project site has been removed and donated to a non-profit, private school to assist in preparing their site on campus facility expansions. The school site is located approximately 500 feet from our project site. If the excavated soil were to have been hauled off to a landfill, the travel distance would have been greater than 25 miles one-way. It is projected that an additional 1,000CY of excavated soil from the project site will also be made available to the school as our project progresses. We are aware the LEED NC v2.2 MRc2 - Construction Waste Management credit requirements indicate excavated soil does not contribute to this credit, however the excavated soil was donated to a neighboring school which the credit requirements make special note that ".diversion may include donation of materials to charitable organizations.". We believe we are meeting the intent of the credit by diverting construction and demolition debris from disposal in area landfills and in addition, we are significantly reducing environmental impact from transportation vehicle emissions and providing a non-profit organization with materials to provide site expansion.

Ruling:

While your strategy for handling excavated soil provides environmental benefit in reduced transportation of materials, it does not justify inclusion of excavated soil in MRc2. It is understood that many projects face challenges related to local market conditions for recycling. However, the weight of the soil would overwhelm the total amount of construction and demolition waste and enable credit achievement without addressing those impacts. As a result, the donated soil cannot be included in MRc2. You may want to consider evaluating the environmental benefits of the soil donation in the context of overall project emissions during construction and applying for an Innovation credit. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/9/2011
LEED Interpretation
Inquiry:

Is lead-based paint containing material considered hazardous for the purposes of LEED and therefore eligible for exclusion from the calculations of waste diversion?

Ruling:

Yes, teams may exclude lead-based paint contaminated drywall from your construction waste management calculations. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/17/2002
LEED Interpretation
Inquiry:

This project has contracted with the construction waste hauling company Richard S. Burns and Company, Inc. (here after known as RSBCO) who will take all construction waste from our project and recycle about 90% of it through a patented process that produce several products. These recycled construction waste products are unconventional and one of the products is sold for use in landfill operations. We would like the USGBC to confirm that these products made from construction waste meet the intent of the MR Credit 2 - the diversion of construction waste into the commercial products stream - thereby qualifying our project for MR credits 2.1 and 2.2. RSBCO has developed and patented a specific process of receiving, sorting, grinding, and blending construction waste materials to recover recyclable materials and produce desired products from the rest of the waste. The process begins with screening out fine particles for later use. The material then moves through a positive sorting process where individually recyclable materials like ferrous and non-ferrous metals, cardboard, masonry, and wood are recovered. RSBCO sells ferrous and non-ferrous metals and cardboard to secondary processing markets. On-site, RSBCO processes masonry and wood into a clean fill product used around pipes, in drainage trenches, or as substrate for road construction. We think the recovered recyclable materials and the clean fill product both clearly meet the intent of the MR credit 2.The process continues with negatively sorting the remaining construction material to remove undesirable materials such as plastic trash bags and clothing. This undesirable material represents less than 10% of total materials received and is continuously scrutinized for further recycling opportunities. The remaining material is then ground, screened again for metal recovery, and sized. The ground and crushed aggregate from all stages of the process are then blended in specific proportion to create a product called Barrier

Ruling:

This approach seems to meet the intent of MR Credits 2.1 and 2.2. Keep track of recycling rates according to credit requirements. The only clarification necessary is whether the Barrier product described is in fact used as a cover material with value to the landfill. Because the credit language requires the project to demonstrate recycling, salvage, and landfill rates, you will need to provide some documentation that the Barrier product is USED BY the landfill as described, and not just DISCARDED AT the landfill.

Campus Applicable
No
Internationally Applicable:
No
7/2/2008
LEED Interpretation
Inquiry:

The project team is seeking direction regarding Construction Waste Management. In order to minimize the environmental impact associated with construction waste, consistent with the Credit requirements, the team plans to prevent concrete washout waste from being transported to landfill by means of diversion to an on-site washout pit. This waste will be deposited on top of existing bedrock and then covered with soil from the project site. The existing bedrock in the area that we are proposing is 6\' to 8\' below the surface, and is under the new parking lot we are constructing. No future construction is planned in this area. By utilizing this method of diversion, the project team would eliminate the environmental impacts associated with fracturing, loading and transporting the concrete waste to a facility off-site for recycling. Additionally, in order to divert this material by means of removal to an off-site facility, the team would need to utilize heavy construction equipment to dig the hardened concrete material out of the pit. This method would consume a significant amount of energy and negatively impact the carbon footprint associated with this material and the project. In summary, the team is attempting to meet intent of this Credit in a manner that causes the least environmental impact by diverting construction waste on-site. Therefore, the construction team would like to measure the cubic yardage of concrete to be left in the wash-out pit and convert this volume to weight by using a solid waste conversion factor of 146 lbs/cubic foot as provided by the concrete supplier. The weight of this material, which will ultimately be diverted from the landfill in the most sustainable way possible, would then be applied toward the diverted material quantity for MRc2. We are requesting clarification as to whether USGBC believes this methodology is in compliance with the requirements of this Credit.

Ruling:

The project team is requesting that on-site burial of concrete from the wash out area be considered landfill diversion. No, the intent of this credit is to, "Divert construction, demolition and land-clearing debris from disposal in landfills and incinerators. Redirect recyclable recovered resources back to the manufacturing process. Redirect reusable materials to appropriate sites." The described actions are not much different than creating micro landfills. While there are environmental benefits to on-site disposal in the avoided vehicle miles, the described actions do not reuse or recycle this material. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/9/2011
LEED Interpretation
Inquiry:

In the waste diversion process many questions have come up regarding utilizing Waste-to-Energy as a landfill diverstion strategy. Can Waste-to-Energy be utilized as a landfill diversion strategy if; this effort ran parallel to sorting recyclable and reusable materials, and the power plant proposed has approved EPA pollution control devices. Alternatively, can paying additional cost to transport non recyclable trash to a Waste-to Energy power plant to be incinerated and converted into electrical energy count as diverted waste?

Ruling:

Only wood derived fuel can contribute to MRc2 in this manner. Incineration cannot be used as an alternative method for diverting waste from the landfill for purposes of credit achievement. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
6/8/2009
LEED Interpretation
Inquiry:

During construction while excavating for placement of compacted sub-grade and asphalt, limestone was found on our project site. Due to its location and interference with the parking surface elevation, the rock was removed and donated to the local county which was used for permanent erosion control on a different project site. Although the reference guide disregards excavated soil and land clearing debris from this credit, we propose that the limestone as a product differs from the "land clearing debris" because it is a material which can be recycled into another product that otherwise would have had to been extracted and manufactured. We believe that this attribute of the limestone allows it to count as a "reusable material". We also believe that the donation and redirection of the limestone as a reusable material for a different site, not only meets the intent of this credit by diverting waste, but is also an acceptable manner (as defined by the reference guide) by which to qualify for the credit as it is "redirecting reusable materials to appropriate sites". In keeping with the intent of this credit, can we include this rock in our MRc2 Construction Waste Management Calculations?

Ruling:

**Update October 1, 2013: This ruling is no longer valid. Please see LI 10062 for more information and an update ruling.
The project is proposing to include excavated limestone as diverted construction waste because it was given to another project to be used as permanent erosion control on another project. The LEED Reference Guide explicitly defines rock as land clearing debris and thus it can not be included in credit calculations. Previous CIR rulings dated 9/9/2008 and 3/4/2004 state the same conclusion.

Campus Applicable
No
Internationally Applicable:
Yes
8/2/2008
LEED Interpretation
Inquiry:

WCA Bondad Landfill has developed a plan for LEED-NCv2.2, MRc2, Construction Waste Management for a project in Western Colorado. Due to limited options for waste recycling in this rural region of Colorado, WCA Bondad Landfill has developed an alternate approach that we believe is consistent with the intent of MRc2 and with previous CIR rulings. Two waste bins will be placed on the job site. One bin will be placed for general refuse (commonly known as "MSW" or "Municipal Solid Waste"), which is non-recyclable trash (food waste, etc.). The other bin will be reserved for materials to be utilized as alternate daily cover ("ADC"), also known as "beneficial layer" at the landfill. This material will include large plastic, packaging material, non-contaminated soil that cannot be used on-site and any other clean trash or construction waste materials that there are no recycling options for in the area. All ferrous metals will be diverted and recycled. Masonry, concrete, and sheetrock will be reused on site as fill and soil amendment. Federal regulations require waste disposal facilities to cover the working face of a landfill at the end of each operating day with six inches of earthen material, or an approved ADC. As noted in a CIR for MR Credit 2.1 (Inquiry ID 0277-MRc21-041902) landfills typically use soil from the initial excavation of the pit as the daily cover material. However, landfills in southwestern Colorado - and around the country - run out of clean fill from their own excavation stocks. At times, WCA Bondad Landfill mines clean earth, or purchases soil which is routinely trucked from soil quarries at a distance. WCA\'s processing and use of this non-recyclable contractor waste as ADC will prevent the need for WCA to mine, purchase or transport ADC, thus effectively diverting materials from the waste stream by reusing them at the landfill. Our approach will be consistent with a CIR dated 5/17/2002 in which non-recyclable material is processed at the landfill and used as Alternate Daily Cover. The difference here is that the material processed to be used as ADC will not be marketed as a product for sale or for use elsewhere, as was the Barrier product referenced in the previous CIR. The environmental benefits will be the same however. Consistent with the CIR dated 5/17/2002, all quantities will be tracked and actual use at the landfill will be documented. Please confirm that our approach is compliant with NCv2.2, MRc2.

Ruling:

The project is inquiring whether the intent of MRc2 is met when project materials are used as alternative daily cover (ADC) at a landfill. Any construction debris processed into a recycled content commodity which has an open market value - e.g. alternative daily cover material, etc. - may be applied to the construction waste calculation. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/9/2011
LEED Interpretation
Inquiry:

Can waste diversion rates be documented as an average recycling rate for an integrated waste management operation serving a market area as opposed to the average for a single facility?Does the USGBC offer a prescriptive method for facilities to back-up commingle recycling percentage claims? Is visual inspection of project loads an acceptable method for documenting recycling rates? When calculating recycling percentages the USGBC does not seem to have a limit on how much ADC can be claimed as a "recyclable" commodity.

Ruling:

A system recycling rate is acceptable as long, as the recycling rate utilized is regulated by a local or state government authority as a closed system, in compliance with the LEED-NC 2.1 CIR dated 12/2/2005 (#3000).For project using a project specific diversion rate, visual inspection is not an acceptable method of inspection for purposes of documenting percentage of commingled waste diverted from landfill. Currently ADC is an acceptable method for compliance with this credit. ADC meets the intent of MRc2. At this time there is no limit as to how much ADC can be used to fulfill credit compliance. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
12/4/2006
LEED Interpretation
Inquiry:

Is it possible to achieve MR credits 2.1-2.2 by way of a construction management plan that utilizes a nearby waste recovery facility with a very high recycling rate that sorts and distributes wholly co-mingled debris from the construction site? Our project intends to work with a nearby waste recovery company, Taylor Recycling Facility, LLC, where a single container is provided for all the construction waste on site. Each full container is transported to their New York State Department of Environmental Conservation (DEC) Part 360 Permitted Construction & Demolition processing facility in which it is initially weighed by a certified NYS weigh master. The co-mingled debris is then screened, processed, and sorted manually into the various recycled product categories; if further processing is required at other facilities, names will be identified on the supplied monthly waste management reporting form. Any non recyclable materials are transported to a solid waste transfer station or landfill for legal disposal. The facility will intermittently provide a total weight of the removed co-mingled debris specific to our project, as well as general facility percentage rates of all waste that is recycled, reused, salvaged, or landfilled, based on the facility\'s monthly Construction and Demolition Plan. The intent of this credit is to "divert construction, demolition, and land-clearing debris from disposal in landfills; to redirect recyclable recovered resources back to the manufacturing process." By redirecting all of the waste created by our project to a facility that has made it their business and mission to transform the waste management industry into a sustainable process, it is made certain that the intent of this credit is performed correctly and efficiently. Furthermore, Taylor Recycling Facility, LLC has a very high recycling rate, typically greater than 97%: if the DEC documents this facility as attaining a 95% or higher salvage rate, does this also merit an additional ID credit? This is in reference to a previous CIR ruling dated January 11, 2005 which stated that the threshold for diverting construction waste is set at 95%.

Ruling:

Yes, tracking the amount of construction waste diverted from the landfill based on the weight of the removed co-mingled debris from a sorting facility is an acceptable method of documentation for this credit, as per NCv2.1 MRc2.1 CIR ruling dated 12/2/2005. A local or state government authority must regulate the facility\'s method of recording. 95% landfill diversion of construction waste (% = recycled quantity divided by total amount [recycled + waste quantity] times 100) is the established threshold for achievement of an innovation credit. Project must submit documentation that construction loads sent are respectably close to the recovery facility\'s average recycling rate in order to achieve this additional credit. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
1/30/2009
LEED Interpretation
Inquiry:

Our project is being built on what was once a City-owned asphalt parking lot. All the asphalt was removed, taken to a recycling plant, and crushed. We are not able to re-use the asphalt on our particular site for fill, however the asphalt will be used as fill on several other projects around town. The company that hauled the asphalt specializes in recycling and redistributing concrete, rock, and asphalt for use as fill in construction projects. Although the book states the asphalt needs to be crushed and re-used on site, we feel we are meeting the intent of the credit since we are diverting demolition debris from landfill and incinerators, and we are redirecting reusable materials to appropriate sites.

Ruling:

The credit intent has been met as demolition debris has been diverted from disposal in landfills and incinerators. In this instance, reusable materials have been redirected to appropriate sites. The credit does not require that crushed asphalt be reused on site, so long as it is diverted from landfills and incinerators. On-site reuse of crushed concrete, masonry or asphalt is also acceptable in the calculation for this credit. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/14/2007
LEED Interpretation
Inquiry:

Our project is located on a Washington State DSHS-JRA Juvenile Rehabilitation Administration (Detention) Campus in Chehalis called Green Hill School. The project consists of two new commercial buildings replacing two obsolete buildings (demolished in this project). Both new buildings, Heath Center/Administration (HCA) and Intensive Management Unit (IMU), will be placed on the same site area (building footprint) as one of the obsolete buildings (Building \'X\'). Each new building footprint covers approximately 1/2 the existing footprint of the obsolete Building \'X\'. After the demolition of the 2nd obsolete building (Building \'W\'), this area and other disturbed areas will be restored with native/adaptive landscaping to create a green space. Only the HCA building will be pursuing USGBC recorded status of LEED Silver. The HCA building consists of a Health Center including medical, dental, and mental health services on the first floor and Administration offices on the second floor. This project will be completed in 3 phases, two bid packages and two separate Contractors. We are proposing one consistent LEED boundary that we will use for all the LEED credit. The entire project will have 3 different construction and TESC boundaries that will be different from the LEED boundary due to the phasing of demolition and construction and the inclusion of the IMU bldg (which is not pursuing LEED) in the construction boundary. Bid Pack #1 - Site Utilities and Demolition of Building \'X\' summer \'07 Bid Pack #2 - Phase I - New Construction of HCA & IMU building (in footprint of demolished bldg \'X\') spring to winter \'08 Phase II - Demolition of Bldg \'W\' and restoration of native/adaptive landscaping winter \'08/spring \'09 We could include 1/2 of Bldg \'X\' within our LEED boundary OR exclude Building \'X\' demolition from the LEED scope of work. We are planning to divert this demolition waste from the landfill, but the paperwork may be confusing with only 1/2 the building counting towards our LEED credits and the paper work from demolition of Building \'X\' will be from a different Contractor. Bldg \'W\' will be included in the LEED boundary and is in the same Bid Pack #2 that includes the new construction, although this demolition and restoration of landscape will be Phase II. Prior to demolition, a full hazardous material abatement would be completed to abate asbestos, mercury, and lead based paints. Demolition of building \'X\' and \'W\' would mostly consist of grinding up concrete into a rocky base coarse which would be used as base material along the perimeter road of the secured campus. Temporary stockpiling of soils from demolition of Building \'X\' and preparation of the site will be used to fill-in area of demolition of Building \'W\'. We propose that the LEED boundary for our HCA building would include half of the footprint of the demolished Building \'X" and the entire footprint of the demolished building \'W\' (excluding the other new building - IMU building which in located over the other 1/2 of Building \'X\'). The inquiry is: Is our proposal for our LEED boundary acceptable? Based on the LEED site boundary described above, is it permissible to have 3 different phased TESC boundaries and Construction boundaries beyond the one consistent LEED boundary for the HCA building? Is it permissible to calculate only the portion of the demolition of Bldg \'X\' which is in the LEED boundary toward MRc2 with the paper work being provided from a different contractor?

Ruling:

The applicant is asking whether their proposed LEED boundary and allocation of demolition debris is acceptable. The proposed LEED boundary is acceptable as long is it is used consistently across all LEED credits. The allocation of only the portion of demolished Building "X" within the LEED boundary is also consistent with credit requirements. The allocation of the entire demolition of Building "W" is acceptable, as long as this is within the scope of the project seeking LEED certification. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
12/2/2005
LEED Interpretation
Inquiry:

Our project is located in Los Angeles, California. Construction waste is sorted at the jobsite into various boxes i.e. wood, metal, concrete/inert material, drywall/gypsum, co-mingled recycled waste (small wood scraps, wire cuttings, conduit, metal stud cut offs, etc.), and general trash boxes. A contracted hauler regularly collects these boxes. General trash is taken directly to the landfill where it is weighed and then buried. Separated recycling materials are taken to various certified City of Los Angeles recycling facilities where they are weighed and processed. Co-mingled recycled waste is taken to special certified recycling facilities where the co-mingled mix is weighed and then the recyclable materials are removed from the mix and sent to appropriate facilities for processing. This process does not allow for each recyclable material type from the co-mingled load to be weighed separately. The City of Los Angeles\' Department of Sanitation audits all of the co-mingled sorting facilities on a regular basis and establishes a yearly average recycling percentage rate for "each" facility. The certification recycling percentage rates vary. When calculating the construction waste recycling percentage for MRc2.1, will the USGBC accept the City of Los Angeles\' annual recycling percentage rate for the "specific" facility that accepts this LEED project\'s co-mingled component of the project\'s waste stream?

Ruling:

The average annual recycling rate for the specific sorting facility 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 is the case for your project). Applicable Internationally.UPDATE 10/1/12: Made applicable to LEED EB 2008 and 2009.

Campus Applicable
No
Internationally Applicable:
Yes
6/19/2008
LEED Interpretation
Inquiry:

Our major renovation project is a high-rise building in Germany. One of the recycling methods we apply is underground waste disposal, also called mine backfill (Bergversatz), a method which, in Germany, is governed by statutory provisions. Since with our project, a relatively large amount of material (gypsum waste, sheet glass, gypsum fiberboard panels, etc.) is disposed of in this manner, we would like to make sure that this way of recycling is acceptable in line with the Credit Intent. Underground waste disposal or mine backfill means that exploited deep mines are backfilled with liquid or solid mining or non-mining materials. Depending on their nature, the filling materials are stored in barrels or packed in big bags and their storage is controlled. The backfill may also consist of bulk material. Under the German Closed Substance Cycle and Waste Management Act (Kreislaufwirtschafts- und Abfallgesetz) and, in addition, under the German ordinance on the underground disposal of waste (Bergversatzverordnung) it is specified that if this disposal serves an economic purpose, e.g. if it prevents a mine from collapsing by filling it air-free, it is not considered as waste disposal but rather as waste recycling. Furthermore, for every 500 metric tons, analyses must be performed and submitted which confirm that the underground waste material is recognized as safe. As under the applicable German laws and regulations, underground waste disposal is recognized as recycling, we would like to know whether this recycling method complies with the requirements of the LEED Credit Intent and whether LEED also recognizes underground waste disposal as a means of recycling?

Ruling:

The applicant has requested acceptance of mine backfilling as an equivalent means of accomplishing construction waste management. Based on the description of the process, it does not appear that this practice will meet the intent of the credit. In addition to encouraging the diversion of debris from landfills, the credit intent includes an expectation that projects "redirect recyclable recovered resources back to the manufacturing process." While it is recognized that using clean waste material from construction rather than other potential materials to back fill deep mines may be environmentally preferable, this practice is not aligned with the intent of the credit. The waste is in essence going to a "landfill" and the specific materials noted (gypsum and glass) are known to be potential feed stocks for manufacturing processes. By using them as fill material, the proposed practice is burying potentially valuable raw materials. Underground waste disposal is not a recognized means of recycling for this credit. Applicable Internationally; Germany.

Campus Applicable
No
Internationally Applicable:
Yes

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