A couple suggestions: There should be an option to qualify for 9 points (or the full number of points, if not 9) by completing TRUE Certification (at any level) since the certification requires 90% diversion. This is an opportunity to elevate and support the TRUE program.
I like that for projects that cannot achieve a 90% diversion rate there are points that show support for a diversion program. There are significant shortcomings to using a diversion rate as the only basis for sustainable materials management. For example, a site may have a high recycling rate, but may perform poorly on the higher tiers of the zero waste hierarchy: waste reduction and reuse. (For example, paper materials may be recycled, but were steps taken to reduce or reuse the materials first?)
Furthermore, in our experience, diversion rates have a way of incentivizing individuals to cheat or fudge numbers, glossing over contamination or including an organics program that is 'in place' but not effectively operational.
Understanding how much reusable, divertable material is ending up in the trash/landfill waste stream, and how much diverted material is contaminated are addressed in Option 2 under Paths 1 and 5. An equal number, if not more credits could be given to Option 2, provided sufficient documentation is requested, as a way of overcoming the shortcomings of the diversion rate. Or another possibility may be to require both Options be pursued in tandem. Require not just a diversion rate be provided but also evidence showing the steps that are continuously performed to maintain that diversion rate. Maybe there is a requirement contamination threshold for reporting at each div rate in option 1? Example, if you are reporting 90% div, you must also report less than 10% contamination in each div stream.
Anna Dengler
May 24, 2024 - 12:28 pm
Comments from my colleague, Cailin Dyer:
The methdology requirements for reporting Option 1 are quite vague and only require minimum 4 months and estimates are allowed. The minimum 4 months requirement seems low to me given we know waste generation can be seasonal. What does "The reporting period must provide a representative illustration of the annual material flows in and out of the building" mean? Does that mean the minimum 4 months cannot be consecutive in the year? Also, the way the methodology reads, I don't think a zero waste audit would be considered a valid form of methodology for Option 1. That discourages applicants to focus on contamination because often times volume calcs and hauler reports won't include contamination.
Additionally, I have specific comments regarding the following paths within Option 2:
Path 1. Is this applicable to multiple diverted streams such as organics recycling as well?
Path 3. Would food donation qualify for this category, obviously that is of higher preference than recycling so how would that be accounted for? I don't see mention of donation programs in any other paths. The closest thing would be path 9 but that implies the materials stay onsite after repair.