LEED Interpretation: get recycled content figures by plant

Interesting change. According to the last sentence - "Note that this ruling does not apply to steel products, which have an established average recycled content of 25% and do not require documentation on a per product basis when that value is used in the LEED calculator." Does that mean that if I use the 25% default recycled content value for a steel product I don't need documentation (same as before) BUT if I choose to submit something other than the default value I can still use regional or national claims?

This ruling is ridiculous. Why did someone bother to ask this question. Everything worked okay before.

For recycled content, my approach for the last 10-years has been:

-- If the manufacturer does not provide plant specific data, use a multiple plant average if the average is a reasonable range, say +/- 10%.

-- If the manufacturer does provide plant specific data, use the data for the plant closest to the project site.

-- If the manufacturer does not provide plant specific data, and claims a wide range of content, DO NOT use the claim. (Use the minimum value --the USGBC says you can-- but I drop these type of wide range claims because it is clear to me they are not product specific.)

It is not worth the effort to try to get manufacturers to make plant specific claims. Yes, they should know what goes in and out of their process, but you'd be surprised how hard it is for the information to be obtained.

It is unreasonable to ask a manufacturer to claim 12.6% recycled content value. Many prefer to state a range, such as 10-15%, because the recycled content for a product can vary. One week the value might be 10%, next week 15%. Some manufacturers will not provide hard values because they think they are not being truthful.

It is not a LEED project consultant's job to verify claims made by a manufacturer. That is the manufacturer's job. The cost of following through is simply tremendous. No project owner will pay a consultant the additional cost to verify manufacturer claims.

The USGBC is off-the-mark. Averages have always been used for credits throughout LEED. A good average with a tight content range should be acceptable.

So will national or industry wide averages be acceptable?

I see Keith is with Nucor. Nucor has a very good recycled content claims letter; product type and plant specific recycled content claims.

The LEED default for steel is 25% post-consumer content, based on old Steel Recycling Institute (SRI) U.S. industry averages. The LEED Reference Guide authors used BOF averages for all steel.

Since the early years of LEED certifications, it has been acceptable to use new SRI published data. If you could prove BOE was the method of fabrication, the higher recycled content inherent in that manufacturing process, was accepted by the LEED reviewers.

If industry-wide and national averages are not acceptable, then the USGBC needs to post an official addenda to the recycled content LEED credit. This would be a mistake. The USGBC needs to re-clarify the interpretation to properly address how steel has been allowed to document recycled content since the early life of LEED.

Hmm, so we can no longer use newer SRI recycled content data for either BOF or BOE processes. A change like this would be better left to LEED v4.

Many steel manufacturers use SRI claims because they purchase steel from a large number of sources, and the sources are every changing. A company is always going to use the source with the best pricing.

If SRI data can no longer be used for claims I see continued controversy from the industry. Documenting the details for each vendor source is onerous because they have to get each vendor to make a proper claim. The effort is not worth the time, in my opinion.

LEED consultants should immediately start planning to achieve lower recycled content claims. The Recycled Content exemplary performance credit level of 30% is essentially unachievable.

It does not read like a change to the steel defaults or the way you can with specific documentation use a higher value for steel. To my reading, they took care of some of our concerns discussed earlier in the thread when the ruling first came out but left steel alone. If you can make a specific higher steel recycled content claim through documentation (and it sounds like you have) then it sounds like you can continue to do this.

What the revised ruling did was make things easier to document items like VCT with recycled content, ceiling tiles, etc. Where the recycled content jumps around a bit depending on recycled material availability. Instead of having to track your VCT to a particular plant for a particular run of product (old ruling), you can track your VCT to the plant and stop.

Manufacturers, not projects, have been allowed to use newer SRI data for the last 10 years; since LEED v2.0. Refer to LEED Interpretation #5519. The ruling does not preclude projects from using newer SRI data.

If SKU is now required documentation, many manufacturers will not be able to document that level of accuracy. The supply chains are not controlled by many manufacturers to feed only a specific SKU.

Let me give an example of a 0% to 70% range that should be accepted. A blue widget is made from multiple scrap sources. 33% of the purchases have 0% recycled content. 33% of the scrap has 70% recycled content, post-consumer. 33% of the scrap has 35% recycled content, post-consumer. The net content is 35% recycled, post-consumer.

Although a range is used, the above claim is specific. It should, and has been accepted, on my projects for more than 10-years. This is no longer the case.

As I stated before, projects should plan on documenting lower recycled content than is actually in their project because of this new "fix" the USGBC has developed. Assume one point lost, maybe two. Subcontractors and manufacturers will not be able to provide the level of detailed documentation demanded by the USGBC.