ADC is not recycling - Support the change

Mark - Thank you for your comment. Your comment reflects the intent the MR TAG had when drafting the updated langauge, which was aimed at changing the practices of this process. We look forward to more of your comments!

I wholehearted support this change to the MRc2! I am so glad the TAG recognized that this was an issue and took steps to address it in the current draft. I especially liked hearing in the MR webinar the reasons the TAG felt were important for this change – specifically that ADC was not achieving the holistic goals of diverting materials from the landfill and harvesting those materials to avoid extraction of new materials.

It is unfortunate that I am seeing this too late in the game to make a comment that USGBC will be able to factor in to their decision. Also, I am sorry that I was unable to get to all of you earlier as well. First point of information about me, a disclaimer if you will. I work for a MRF (Material Recovery Facility) in Portland, Oregon. In theory, we should be your partners in recovery and recycling, we are an integral part of the process of creating new commodities out of your waste stream. Keep in mind, we don't generate the waste, we are the processor who could benefit greatly by keeping every pound possible out of the landfill. We make our money by NOT taking stuff to the landfill. ADC, since it is the subject of this post, is something we recover here. ADC is also created in many legitimate recycling facilities, from dozens of different sources, so it is distressing to have it rejected out of hand because of the anecdotal reference to a few unscrupulous landfill operators in unnamed jurisdictions. At our facility, ADC is created from the fines left at the bottom of the dumpster, the loose material that is primarily small bits of concrete, drywall pieces, hard plastic and dust less than an inch in size. In Oregon, as in many other states, the ADC is regulated and authorized for use as cover by the State Department of Environmental Quality. They have recognized that since the EPA requires a minimum of 6 inches of cover every night for vector and odor control, and the cover previously used was clean soil, this represents a win-win for everybody. I am more than happy to provide samples of the material that we sift out of the waste stream. Yes, this would likely go to the landfill anyway but it would go as general garbage, mixed with other non-recoverables and hence have no beneficial use. Perhaps a better methodology would be to clearly define ADC to prevent abuse of the ruling. By the way, one of the chief impediments to recycling or diverting many of the materials that come through this facility is how inexpensive those materials are on the front end. If we had a true life cycle cost analysis on the variety of materials that go into construction and later end up in the dump, perhaps there would be more value at the back end. Last, certainly not least, is the issue of markets for the material that comes out of C&D. Without a viable market that is both accessible and cost effective, nobody in the chain of possession will have any reason or desire to make this all happen. An example of this is gypsum wall board. When it comes from demolition, it is often contaminated with paint or wallpaper. Yes, it is theoretically recoverable, however, nobody in our area has a facility or process that will recycle or reclaim this material because there are so few markets and it is expensive to reclaim. The only alternative is landfilling. When it is scraps from new construction, there is one possible vendor who will recover this material and the cost to do it is higher than landfill disposal as well as requiring full dumpster loads delivered 30 miles from the local Metro area. Green and sustainable works when all parties can share in the benefit or be responsible for the burden of the end result.

Great comment on ADC, and I can only applaud MRFs which primary goal is to recycle and to do it transparently. However, please keep in mind the intent of MRc2 is to divert waste from landfills. The waste and recycling industry currently suffers from a creditability issue, simply from too many “recyclers” taking short cuts, and the result have been amazingly high recycling rates of C&D and other material in the past few years. This is simply from the industry becoming more focused on how to create documentation for LEED projects, versus actually improving recycling rates. Here is what I would suggest: 1. Do not permit ADC to be counted as landfill diversion. This will lower many MRF recycling rates by as much as 25% or more. 2. Continue to permit material that is used as a fuel source/fuel pellets for waste-to-energy plants (incinerators pay for this material) and not to permit waste that is being burned up as waste only (incinerators charge for this). Currently, there are too many MRFs including all the material they toss into waste-to-energy plants as recycled material even though it is not pellets, since no one is checking. Some facilities are sending as much as 50% of their waste to incinerators and claiming it as recycled. 3. Develop a third-party verification system of actual recycling rates at MRFs and other recycling facilities. This would result in two things: a. It would quickly clean up the worst offenders in document fraud. These offenders are also driving the price down so that real deal MRFs cannot effectively compete in a fully transparent means. If 90% of the worst offenders were held accountable, then the real deals would be financially rewarded with increasing market share. I can safely say I am aware of facilities that have actual recycling rates around 10-20%, and are claiming 90% plus on documentation. This simply needs to be addressed in order to make MRc2 more creditable. b. The actual recycling rates reported of real deal facilities would likely substantially drop by a third party verification system. That is okay since, they would still be much higher than any other company that did not invest in facilities, equipment and labor to recycle C&D material. However, since they are going to have a much higher market share, they will be able to invest in newer technology and focus on stronger backend markets to slowly work their real recycling rates back up. Going from an actual 50% recycling rate back toward 100, is much more in line with the overall mission of USGBC, then just reporting 95% plus rates that are not accurate. We would submit a Pilot Credit for developing a third-party verification system, but we simply do not have the resources to do this in such short of a time. If anyone has any suggestions, I would love to know what they are.