As a construction sustainability practitioner who is neck deep in LEED, C&D waste diversion, and circularity, I had the following comments/changes to this credit:

  1. Restore The C&D Waste Planning Prerequisite - the removal of this prerequisite is confusing and anti-progress. With the diversion credit only have 2 points in BD+C, and no prerequisite required, I don't believe LEED/USGBC fully understands the massive C&D waste problem in the U.S. and beyond. Please add an updated version of the v4/4.1 prerequisite that supports a focus on data transparency, proper planning, and waste minimization. If we make less waste altogether, it's infinitely better than finding the best disposal location.
    1. The prereq should make it clear projects need to first reduce (waste minimization), THEN reuse (donations, repurposing, upcycling), THEN recycle (downcycling, site separation and lastly commingled recycling).
    2. A site logistics plan for waste and lists of material streams with end use markets called out should be necessary for the prereq.
    3. Maybe include an option for a processor site visit to this prereq or make it an option so that project teams can tangibly see (and be sad about) how bad the waste problem is.
  2. Waste Diversion Percentages and Backup - When using non-third-party certified processors, 35% Diversion for 1 point is actually much more appropriate (for construction waste) yet still a reach for a majority of the U.S. The problem with setting static diversion numbers (aka the v4/4.1 C&D credit) is that when a piece of paper stating a facility average and nothing else is backup for a number, you will always see that number or higher (most waste processors make up these numbers and continually get away with it). I would ask the LEED tag for this credit to require backups for diversion %s such as broken out calculations, otherwise it's more made-up numbers that continue to worsen the climate crisis.
    1. If you are going to require a facility average, it should include total C&D waste tonnage in, broken up streams that list end markets and total tonnage of that stream, and include a number for ADC/BUD as well as tonnage sent to landfill/incineration.
    2. If it's just a diversion % requirement on the singular commingled loads that entered the facility, I don't know of many processors (that aren't third party certified) that can ACCURATELY break it down with that much specificity, most of them just weigh the total load then dump it onto a picking floor with other loads. The exception is for site separated materials, which can confirm they were either taken directly to a material recycler or were isolated at a commingled processor and never mixed with other loads.
  3. Verified Third Party Processors - I quite like the third party verified facility for 2+ points, but this can get tough as I can only think of RCI as an applicable verification body, and there are very few (relative to total number) processors that have RCI certification. I believe this requirement should be an "or" for 2 points via Table 1 on the credit page. It helps push the market but removes the requirement in case there are literally no certified facilities in your area.
    1. I would ask the LEED tag to not remove the site separation requirement for 1 point, as the "AND" requirement promotes better waste practices, but if made into an optional "OR" will regress the market. Site separating a load and giving it to a third-party certified facility only helps them, and many offer lower prices for separated loads. Simply commingling C&D waste and sending it out to processors has only made this waste crisis worse, and further incentivization of commingling is antithetical to sustainable progress in the built environment.
  4. Maximizing Waste Credit Points - I don't know if it's a typo or if I am reading it wrong, but Table 1 (for ID+C) shows no difference between 2 and 3 points (other than letters capitalized) on the v5 credit page. I think it would be a wonderful idea to allow for 3/4 points in C&D if you require: 50% diversion AND source separating AND third party verified facilities (denoting that projects without demo can achieve a maximum of 3 points, while projects with C&D can achieve a maximum of 4). For BD+C, make the maximum credit points 3 to make it attractive to projects.
    1. Maximum points should be harder to get but rewarding when you reach for it, especially to move the market towards more certified facilities and different certification bodies. Maybe make it exemplary performance or an innovation credit but make this credit worth pursuing and not easily avoidable.
  5. Site Separation of Materials – Performance metrics should be based on total tonnage of that generated material, with minimums required. This might be tricky from a documentation standpoint, but if I send out one separated load of cardboard at 1 ton but commingled 100 tons of the same material, that shouldn't be rewarded. Scrap metal, wood, clean GWB, cardboard/paper can be easily separated and should be prioritized streams.
    1. Table 1 should show that construction only projects need to source separate and recycle 3 (1 point) or 5 (2+ points) material streams, and that projects with demo can target the pick 2 of ACT, carpet, and furniture route.
  6. Closed Loop Recyclers - For demo waste closed loop recyclers, I would make it clear that carpet and ACT should be volume/sf based, and GWB and Furniture should be weight based. Also, I know of almost no GWB recyclers who take "dirty"/demo GWB except USA Gypsum in PA, and even they have strict paint and contamination requirements. Unless there are viable options for this in other areas, it's a bit confusing on where USGBC expects dirty GWB to as a site separated load.
    1. It might be good to add items like light fixtures or doors/frames/hardware to the list as options or for an exemplary performance point. Some lighting + door hardware manufacturers claim they can take their fixtures back, and supporting DFH circularity through donations can help grow upcyclers and refurbishes that already exist in the market.
  7. Waste Minimization Pathway - There should probably be an option/pathway for waste minimization (total lbs/sf of waste materials) for areas that do not have modern waste infrastructure, but I would be hesitant to make the numbers too high. While 2.5 lbs/sf in v4 was much too low, I think construction only projects being ~10 lbs/sf is appropriate. For projects that include demo, maybe make it ~15 lbs/sf.
    1. This option should only be worth a maximum of 1 point and needs to require a waste minimization summary (that isn't just "this is what the numbers calculated out to be"). Working in interiors, I see some large projects that only generate 6.5 lbs/sf and do almost nothing to minimize waste, while other projects/BD+C could implement better practices to hit the 10/15 numbers. This also pushes manufacturers to provide less packaging/take it back and field teams to try to reuse/repurpose typical waste.

Overall, I think this credit needs to retain it's prerequisite, have teeth, and truly incentivize better contractor waste practices. If USGBC's goal with LEED v5 is to push the market forward and be regenerative, then make this credit achievable at all scales, yet rewarding for those who reach for best practice.