Construction Demolition Waste credit

Has anyone else checked the math on the MR Construction Demolition Waste credit? a) For one point in version 2009 recycling 100 tons of all material required 50% threshold which = 50 tons requirement. For one point in 2012 it depends on which rating system and whether you have demolition or not in your project....but it could be 40%, 50%, or 65% of Heavy materials to achieve 1 point. So if you only have 50 tons of concrete/asphalt/masonry/metal on your project out of 100 tons than you are only required to recycle 20, 25, 32.5 tons to achieve 1 point. Rarely will you ever have a project with 100% heavy materials so you are always requiring less tonnage than the version 2009. We need to be raising the recycling bar, not lowering it significantly where in less incentivized markets this material will be headed to the landfill. b) if you don't have heavy materials on your project or are restricted to only a comingled dumpster (without a current system to determine heavy vs. light) you may not pursue this point. Doesn't seem reasonable. c) 2.5#/sf option 3 has no reyccling/salvage requirement- you earn 2 points for a project that falls under this ratio and apparently you can landfill that 2.5#/sf. One of my past project met this ratio and had 160 tons of waste (we recycled), but other markets the landfill is a less expensive option for disposal. Close this loophole for the final version! d) there is no current method or a cost effective solution for identifying / tracking heavy materials from light materials in comingled loads. I believe the revision is due to concerns that the heavy materials were skewing the recycling %. I would recommend making some accomodation for wood structures or tenant improvements so they are not at a disadvantage and raise the recycling % for projects with heavy materials. Keep the same format as not to add costs or prevent projects from participating. Though honestly, I believe by eliminating ADC and Waste to Energy plants will make it hard to achieve the version 2009 calculation method of 50% minimum threshold even with heavy materials. So if we keep that 50% threshold of all materials, it will add the necessary vigor to the rating system. *Note that technically WTE plants are not eliminated, but I understand that no plant in the USA can meet these requirements (governmental regulation issues), so in effect these plants that process hog fuel (wood waste) have been eliminated.