It has come to my attention that in my local market, most if not all waste management companies use visual inspections to determine recycling rates for commingled loads. I am aware that this is not an acceptable method for meeting LEED requirements. Additionally, to the best of my knowledge, I do not believe that local or state governments regulate recycling facilities' method of recording and calculating their recycling rates. Fortunately, on a number of my projects, the waste hauler is delivering the commingled waste to a local facility that is RCI certified. Since the monthly average recycling rates for the facility are made available online on the RCI's website, my intention is to ignore the diverted weight percentage calculations that the waste hauler is providing (based on visual inspections), and to use the certified facility's recycling rates to calculate a diverted waste percentage in compliance with the requirements of MRpc87. Would this be an acceptable calculation for MRc2?
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RETIRED
LEEDuser Expert
623 thumbs up
January 12, 2016 - 6:10 pm
Marcia - Happy New Year! After we spoke at Greenbuild about this issue, I think you were headed to the GBCI Certification Work Zone to express your concerns with these visual inspections being passed off as true accounting of commingled materials. Did you get any help or guidance there?
I recently investigated MRpc87 for a client - yet I cannot say if USGBC would allow the Recycling Certification Institute's (RCI) certification rate in lieu of local or state government authority regulation (per LI ID #10060 - http://www.usgbc.org/leed-interpretations?keys=10060 and added to the Reference Guide per Correction ID #100000902 - http://www.usgbc.org/leed-interpretations?keys=100000902 ).
As I think all you will get is advice here, my recommendation is that you write a LEED Interpretation inquiry for this situation. I think you could make a good case for it and having an LI would allow other projects to benefit from RCI's efforts.
Marcia Weekes
LEED CoordinatorEcostrategic Consulting Services, LLC
27 thumbs up
January 13, 2016 - 9:59 am
Happy New Year to you as well, Michelle! Unfortunately, I was not aware of the fact that we had an RCI certified facility in the area before I spoke to the GBCI Rep at the Certification Work Zone, so I did not get to ask about that. I am open to submitting a LEED interpretation inquiry, as you suggested. However I cannot figure out how to go about doing that, and I have already spent the greater part of my morning trying to figure this out, with no luck. Do you have any experience with this?
RETIRED
LEEDuser Expert
623 thumbs up
January 13, 2016 - 11:46 am
As I understand it, inquiries are submitted via LEED Online - http://www.usgbc.org/help/how-do-i-submit-project-credit-interpretation-.... While I haven't used the system in the new LEED Online, here's what I see. After logging in, select a project that you will attribute the LI to. Once in that project, click Interpretations button in the grey menu bar. Click the Submit A New Inquiry button and follow the steps.
The sticky part is that there only seems to be an option for submitting Project CIR inquiries, and the fee schedule - http://www.usgbc.org/cert-guide/fees - only shows the price for Project CIRs, which are not precedent setting. It used to show that LIs cost $220 (Project CIR fee) plus $180 for Silver, Gold, and Platinum members…
However, there are numerous FAQs on both LIs and Project CIRs - http://www.usgbc.org/help/what-leed-interpretation - including the difference between the two - http://www.usgbc.org/help/what-difference-between-leed-interpretation-an....
Sounds like a call to Customer Service is needed. Yet the rep I spoke to could not provide additional information and said I should contact the certification team with my question via http://www.usgbc.org/contactus and selecting the Certification Question button.
Please let us know what you find.
RETIRED
LEEDuser Expert
623 thumbs up
January 13, 2016 - 12:14 pm
I found this document while trying to get a more definitive answer for you - http://www.usgbc.org/sites/default/files/How%20to%20Submit%20a%20Credit%... (accessed from http://www.usgbc.org/resources/how-submit-credit-interpretation-request-...). It outlines how to submit LEED Interpretations.
RETIRED
LEEDuser Expert
623 thumbs up
February 12, 2016 - 9:51 am
Marcia - While I was re-reading the LEED v4 Reference Guide for Construction and Demolition Waste Management (MRc5), I came across these sentences under Step-by-Step Guidance in regards to commingled and thought of you: "The waste-sorting facility provides a waste diversion percentage specific to the project’s waste based on measurement of each component waste material. Visual inspection is not an acceptable method of evaluation for documenting this percentage."
While this is not specifically in the v3/2009 Reference Guide, possibly there has been an issue with folks thinking visual inspections are acceptable and USGBC attempted to squelch this practice (or perception) in LEED v4.
Marcia Weekes
LEED CoordinatorEcostrategic Consulting Services, LLC
27 thumbs up
February 12, 2016 - 10:42 am
Michelle,
thanks so much for your constant follow-up and assistance with this. Visual inspections seem to be standard operating procedure for most waste haulers in this market and for some reason the majority of them seem to be unaware of the LEED requirements which state that this is unacceptable methodology. I have brought this to the attention of a few, and the response usually is that it is too costly to weigh each waste stream individually, and since they have not had any challenges by LEED reviewers on submitted reports based on visual inspections, there is not much incentive for them to make changes to comply. I would not be surprised to learn that other consultants would face similar issues, if they themselves understood that this procedure is what is being used. Most of the other consultants I have dealt with in my business are unaware and usually just assume that the waste reports they are receiving are compliant. I do intend to submit a LEED interpretation to get some feedback about using the RCI data, because it would benefit a number of my current projects, and it would allow me to know how to direct clients on future projects regarding this issue. I will provide some feedback after I have done this.
RETIRED
LEEDuser Expert
623 thumbs up
March 15, 2016 - 5:35 pm
Marcia - I was searching for something else in the Addenda Database when the term "visual inspection" caught my eye. There are 3 LEED Interpretations (LI ID #2383 (1/29/2009), 5171 (1/29/2009), and 10060 (5/9/2011)). All three at least say "Visual inspection is not an acceptable method..." Not sure if you have submitted an LI yet about this situation, but these 3 LIs make it clear that visual inspection is not acceptable for calculating the amount of commingled waste in LEED. And since LIs are precedent setting, teams are required to follow them.
Marcia Weekes
LEED CoordinatorEcostrategic Consulting Services, LLC
27 thumbs up
April 15, 2016 - 5:56 am
Hi Michelle,
I have an update on this issue to report. First, thanks for your help with the LEED interpretation submission process. I followed the information in the document you posted the link to and was successful. One interesting thing to note, after selecting pay by check as the document suggested, I still received an invoice for the CIR submission fee ($220). I then contacted the USGBC to follow up and let them know that I had made a LI submission, but received an invoice with the incorrect fee, and was informed by the rep that the fee for LEED interpretations is actually $0! I was expecting it to be $180. They then adjusted my invoice and I got a response soon after that. The response was provided as a response to a project CIR, stating that it was only applicable to the project, although I had not submitted it under any specific project, but it does indicate that if I elected in the LEED Interpretation process then I can expect the second ruling in 3-6 mths. I am guessing that this is when the ruling will be made available publicly as a LEED interpretation. While that part of it is still a bit confusing to me, the response was favorable, and I was granted the ability to use the RCI facility average data in lieu of the annual facility rates that are regulated by local or state government.