We recently received this clarification from a reviewer who expressed confusion about the monthly diversion rate backup that we supplied from our receiver for commingled diversion.
"Monthly commingled diversion rates from receivers are often project specific in the reviews I see on a regular basis. Multiplying the monthly percentage of diversion by the weight of the project loads for each month to get the diversion amount to be used for project is not the approach described in the reference guide and has not been called out an alternative compliance approach."
Our projects are mostly urban and rarely have the space for on site source separation, so we almost always use commingled diversion. It's my understanding over 50 certified projects that is exactly how we calculate commingled diversion. By soliciting the monthly diversion rate from the receiver, and then entering that percentage along with the total tonnage for that month to arrive at the percentage diverted for our project that we can claim based on what the receiving facility diverted that month overall.
Since the comment seems in direct opposition to what we've always done and the way we fill out the credit forms, can anyone shed any light on what this reviewer means?
RETIRED
LEEDuser Expert
623 thumbs up
May 9, 2013 - 11:53 am
My experience with commingled is on a per project basis - where the receiver gives us specific diversion percentage based on our project’s actual tonnage/volume. While I can't shed any light on this specific comment, I would suggest contacting GBCI via the contact form (http://www.gbci.org/org-nav/contact/Contact-Us/Project-Certification-Que...) and selecting “Questions about Review Comments.” GBCI is encouraging teams to contact them with questions.
Note: A 5/9/2011 addendum added this to page 359 of the first edition of the Reference Guide: “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.”
Michelle Rosenberger
PartnerArchEcology
523 thumbs up
May 9, 2013 - 12:31 pm
Thanks, Michelle. And I thought we had a well developed construction diversion industry in our area in Seattle! I've only encountered one receiver who would actually dump and sort a commingled project load individually, making it basically project specific.
Our receivers dump all commingled loads they receive together and sort them together, resulting in monthly diversion percentages. It's too expensive for them to sort each project load separately. This "specific" percentage is supplied to us in a monthly report for our "specific" project that we then use in the form and supply as backup, but it's a monthly rate for any project that used that receiver for commingled that month.
And thanks I've already been through the Feedback process and this was the "clarifying" comment.
We were denied this credit for the first time ever in part I believe because of this issue and in part because the receiving facility included diversion for biomass that they sold the resulting methane from. Biomass was not deemed acceptable despite the market because it's basically "landfilled". We could not however obtain a definition for how biomass is different from Alternate Daily Cover which is currently allowed in our diversion methodologies. The facility was government regulated, guaranteed at least 50% diversion and its use was actually mandated by the City our project was in.
I would very much like to understand both the commingled issue and the biomass issue for future projects. Since so far I haven't had any luck with GBCI, I thought I'd reach out. Thanks for the response.
RETIRED
LEEDuser Expert
623 thumbs up
May 9, 2013 - 4:03 pm
I’m sorry I can’t be more help but it is good you presented this information for other teams. It is unfortunate that the clarifying information from GBCI contradicted past experience.
Regarding the local recycler that sorts by load, the company did this because without any local or state regulation for recycling rates they were not able to figure out a way to account for LEED for commingled waste, which is their business model (one bin - no sorting). So they don’t do the separate analysis for all jobs just their LEED ones.
Regarding biomass vs. ADC, the situation seems very similar with ADC being landfilled. I am glad that in LEED v4 they are closing this loophole - http://www.usgbc.org/node/2601031?return=/credits/new-construction/v4-draft.
Michelle Rosenberger
PartnerArchEcology
523 thumbs up
May 9, 2013 - 4:28 pm
Thanks Michelle. I agree that biomass does seem very similar to ADC. Hence my confusion about one being okay in LEED 2009 and one not. Though I know v4 will address this, for the next dozen projects we have going through LEED 2009 we're still hoping for some clarity. I appreciate your thoughtfulness and the offered resource.
Michelle Rosenberger
PartnerArchEcology
523 thumbs up
May 20, 2013 - 10:19 am
For those intersted in biomass, I have received some further clarifications. Biomass basically differs from ADC in two ways - the biomass waste may not be entirely wood based fuel (LI 10061) AND the biomass waste does not have an open market value. It is possible that biomass made entirely from wood derived fuel would comply, but otherwise it does not.
With respect to the documentation issues, our commingled waste is not project specific. Our use of the monthly facility average is satisfactory. We were ultimately awarded the credit, but it can be very painful if there is a fundamental misunderstanding or miscommunication about the documentation during the review process.