Commingled waste as one or multiple material streams?

Janika - The Reference Guide states on page 480 under Further Explanation for the associated prerequisite: "Commingled waste may be considered only one material stream unless the facility can provide diversion rates for specific materials."

It seems like it should say "must be considered."

Hi,
Please can you clarify the following - if commingled waste is considered one waste stream and a project is targeting 75% diversion from landfill, but all waste from a project is in commingled skips, are the credit requirements for waste streams then unable to achieved? Our facility segregates timber and steel from the commingled waste and the remainder is sent to SRF. The facility can only provide an overall diversion figure and not a breakdown per material. Are the requirements therefore not being met?

Francis - It appears you are correct. Based on your information, you would have 3 streams identified (timber, steel, and commingled*) and hence only be able to meet the requirements of Path 1 - 50%. Have you considered looking at Option 2 - Reduction of Total Waste Material instead?

*Be sure to look at the Step-by-Step Guidance in the Reference Guide and the requirements for commingled to contribute as a valid stream.

I'd like to get a confirmation on this. We provide waste diversion for projects through bringing in commingled loads of debris and sorting out a minimum of 6 different types of materials. On the project side, are we only able to provide one material stream because it is commingled or can we claim the 6 streams we divert at our Facility. We are also in the process of getting our Facility independently certified by a third party - does this still provide an innovation credit, or 3rd point, in the MR credit?

Bruce - As a LEEDuser guest, you can't read the information contained in the Bird's Eye View for this forum that provides answers to some of your questions and provides additional tips to achieve this credit.
If you can provide specific recycling information itemizing the 6 streams for the specific LEED project, you can count them as separate streams.
While the Verified Construction & Demolition Recycling Rate pilot credit - http://www.usgbc.org/node/4717858?return=/credits/new-construction/v4/pi... - can be used for LEED v4 project as one of five available Innovation credits for LEED BD+C projects, I haven't investigated its interface with this credit before. This is a quick review: Having third-party verified facility-average recycling rates (vs. project-specific) is an acceptable way to document commingled waste under this credit. I just hope the third-party certification organization you are using meets the requirements of the pilot credit and you are aware of the ongoing commitment to them. And personally I would want to ensure you are getting verified rates for all your streams so that your facility can meet the minimum four streams (and 75% diversion)required to earn two points under this credit.
(FYI: Earning this pilot credit is not a third point under this MR credit. Typically an additional (in this case third) point would be exemplary performance for credit's requirements, which also would be an Innovation credit. Check out the LEED Rating System or the LEED Credit Library on usgbc.org, become a member of LEEDuser to read more above or hire a savvy LEED consultant who is also familiar with the recycling industry.)

If I have a multi-phase project for a building renovation, would Option 2 of this credit: reduction of total waste material (Do not generate more than 2.5 pounds of construction waste per square foot of the building's floor area) count towards the entire building's floor area or just the floor area of the phase being worked on? The entire project consists of 4-6 phases and is all within one building. 

Yasha - The area for Option 2 would be the entire renovated space area (which is the same area you use for the Gross Floor Area in Project Details in LEED Online (See the Details tab)).

You will save and submit all your documentation for this credit at the end of all phases. Your calculation will be based on the overall waste for all phases divided by the entire renovated space's area.

Can commingled waste still be counted as multiple streams when project-specific diversion rates for various materials are provided? I have submitted projects that successfully earned the credit using this strategy in the past, but on my latest project, the LEED reviewer commented that the commingled waste should only be counted as one stream. Note that I did submit documentation from the sorting facility indicating project-specific diversion rates for 6 different material streams.

I went to look at the reference guide to confirm my understanding that commingled waste can in fact be counted as multiple streams in the referenced scenario but could not find it. I also could not find a corresponding addenda or reference guide change that removed this language. Can anyone provide some up to date feedback on this? Is this no longer an option?

For LEED v4 and 4.1 projects we can count comingled materials as one material stream. Additionally we have only been allowed to count a material as a separate material stream if the stream has been separated and weighed as its own material stream. Materials can arrive to the recycling/solid waste plant as comingled but must be separated and weighed to be counted as separate material streams. Visual inspection and estimates of the weight of different material streams has not been accepted.  It is not difficult in practice to separate concrete and ashpalt (if any) on site as another material stream. The other option is to separate various material streams on site and have them weighed separately. 

Hi Marcia,

I believe the language you are thinking of is below. I received it as part of a CIR where the GC was asking to be able to count a commingled stream as separate waste streams by virtue of the receivers weighting and reporting process. It was denied. Please note that it sounds like you may have gotten lucky with the previous projects. Some hauler/receivers provide reporting that makes it appear that a commingled stream has been separated and if you report it that way to GBCI sometimes they don't realize the difference. 

I believe with this language they mean that you could haul a commingled bin offsite to a yard of your own, then sort the materials and send them on to a specific receiver.

"Additionally, the Beta Guide states (MRp Construction Waste Management Planning / Further Explanation), For a project to be able to count off-site sorted materials as multiple material streams, the following must be met:

• Project team collects multiple materials on the jobsite (often in one bin)
• The materials are taken to a location where they are separated prior to being processed or otherwise sent for recycling
• Each material that is sent to separate recyclers or processors are considered separate material streams. In other words, wood separated and sent to wood recycling directly can count as one unique stream. If mixed materials are sent to a commingled recycling processor, count those as one stream even if they are made up of multiple materials.
• Each material stream must be measured by weight or volume (and converted to a consistent format) and included in the Waste Management Plan.
• And mixed recyclable materials that are processed mechanically over the same recycling line are counted as one stream in LEED, even if the processing facility separates the output into multiple materials for recovery after processing."

In response to the last bullet point: We have been able to count separate material streams that arrive to the waste management plant as comingled IF they are separated at the plant and are weighed and tracked as materials from the specific project. However, in practice this is difficult for the plants to achieve.  Many say they do that but few do.  We have discussed this issue extensively with a certified comingled recycling facility and the GBCI.  Variations between LEED v4 and V4.1 should be explored to determine the best path to use in the Construction Waste Management Plan. We have found it useful to engage the Contractor/CM, before they commit to a "waste/recycling" processor, and to also engage the prospective processor(s) in the discussion.

Agreed. Most receivers can't do this. Unfortunately, I think lots of submitters are entering the data as if it is source separated, and reviewers simply don't know that because they aren't asking for backup that would show that. Unfortunately, I think this credit is now flawed. It's hard to hold the line when projects are getting through that aren't actually source separating as Marcia experienced. And the result of the requirement has been to encourage haulers and receivers to change their reporting formats to make source separation appear to be happening for their LEED clients.

My post was deleted on my last attempt to edit so I am trying this again.

When submitting this documentation on projects, even on ones where I have been successful, I have made always made it clear that the waste was commingled but we are couting separate waste streams because the receiving facility has provided documentation indicating break-out weights for the various waste streamsin the hauls. I previously had no reason to believe that this was unacceptable.

Below is language that I have copied directly from LEEDuser's overview of the credit, and that I also remember seeing in the guide itself until recently:

To count toward this credit, commingled recycling facilities must be able to provide project-specific diversion rates or an average diversion rate for the facility that is regulated by the local or state authority. Visual inspection is not an acceptable method of evaluating diversion rates.

If the commingled recycling facility can track and produce documentation of specific materials recycled for your project, you can count commingled waste as multiple waste streams. Otherwise, commingled waste that is the average diversion rate for a regulated facility is counted as a single waste stream regardless of how many different materials are included. The average recycling rate for the facility must exclude ADC.

Additionally, I had confirmed  that I was understanding this correctly with one of the GBCI reps at Greenbuild's Certification Workzone a few years ago, but unfortunately did not get written confirmation of that exchange. The facility we are using in this case, and who is providing the reports is RCI certified, so I was under the impression that this gives their method of computing diversion rates for various materials in the project's commingled hauls some credibility.

Note that using an RCI certified facility is no gurantee they are weighing separate material streams.  I am told by an industry insider they virtually all use visual inspection (which does not meet LEED criteria for classification of separate material streams).  That suggest most facilities are sweeping that fact under the rug and it is not apparent in the LEED submittals. That is harming the honest providers. Additionally the average rate for the facility is usually much lower than the rate for a LEED project.  For intsance we frequently see 90-95% recycling rates for LEED projects where the materials are run through and RCI certified facility.  As of 6 months ago we were consistantly seeing average facility rates in the 55-60% range.  Unfortunately international changes in recycling are affecting the US industry and we are seeing the average facility rates drop to a 50% or below rate as more typical. 

Ralph,

Thanks for the feedback about RCI facilities. I will plan to count the commingled waste as one stream according to the LEED reviewer's comments. The project will still be able to earn 1 point under the credit since 2 other materials were source separated. This will also help me understand what is feasible for other projects moving forward.

You might consider switching to LEED v4.1 to get 2 points.

Susan,

That was my initial thought until I realized that LEED v4.1 now only awards 1 point for waste diversion. 2 points can only be earned using the waste reduction pathway. It was a recent change made in November.

Okay, wow. Thanks for the heads up on the Addendum Marcia. Interesting response to the source separation issues. v4.1 is a moving target indeed. It's going to get complicated to keep track of which projects are pursuing which version of this credit. We may have to include the language of the requirement we are using with the submittal. 

Hopefully they clarified commingled as one stream because they realized (finally) how many people were submitting documentation and "made it clear that the waste was commingled but we are couting [sic] separate waste streams because the receiving facility has provided documentation indicating break-out weights for the various waste streams in the hauls." even though any reasonable person knew the breakouts weren't real. Every facility provides the spreadsheets making it look like materials are individually weighed but all they're doing is applying the annual or monthly rates to that load (most common) or doing a quick visual inspection - neither of which was allowed or met the intent. You can usually just compare load to load rates to see the percentages are the same (not actual) and if you visit a facility see there is no way for them to weigh the streams from your dumpster separately. This was a comical option from the start and if they're finally holding people a little accountable on this one it would be great. I don't have a strong preference for requiring the multiple waste streams (it hurts the industry) but if LEED is going to do it I was always bothered that the less honest teams would submit commingled as multiple streams and get away with it.

It seems like it should say "must be considered."