This comment applies to issues across several of the MR Materials Credits (recycled content, materials reuse, regional materials and biobased materials)

COMBINE THE CREDITS: This set of credits are just calling out to be consolidated into one combined credit where materials meeting any of these attributes may be added cumulatively toward the potential points. Too often these credits are bypassed entirely because getting the last couple of percentage points to reach a threshold is too hard. Or efforts stop short once the threshold is reached since there is no incentive to continue beyond the threshold except to use up a valuable innovation credits and even then only if the team can come up with enough materials to reach a new threshold. Pooling these credits together would encourage teams to maximize the amount of materials in each attribute category instead of just shooting for thresholds.

The new LEED for Healthcare 2009 has already demonstrated how this could work with a credit structure that has gone through substantive public comment (see MR Credit 3: Sustainably Sourced Materials and Products at http://www.usgbc.org/ShowFile.aspx?DocumentID=8257http://www.usgbc.org/S... page 57). In brief the concept is to add together the value of materials meeting any of the requirements (reused, recycled, regional, and certified wood (see comments below about biobased/rapidly renewable)), determine the combined percentage of the whole and give a point for each 10% of the total material bill. For full alignment with LEED this would be a 7 point credit, post industrial recycled content would get half credit and reuse would get double credit.

Most of these attributes are exclusive (only one attribute should apply – no double dipping). Regional materials may be the exception.

DON’T DROP STRUCTURAL: I understand the dilemmas that certain structural materials – particularly steel and to a lesser extent concrete - raise with their high volume and growing levels of standard practice recycled content. Use of structural materials can quickly consume the credits with standard practice materials and hence give credits too easily and eliminate pressure to address other product categories. There are other ways, however, to address these challenges without dropping all incentive for improving structural material performance. Again LEED for Healthcare addressed this (see above reference) by setting limits on the concrete and steel structural elements applicable to the credit and mandating a minimum percentage of other products: “If concrete or steel structural elements are applied toward this credit, the project must include at least two other materials or products from CSI MasterFormat Divisions (other than 03 and 05) to attain the first point. Of the total recycled content, no more than 75% may be steel or concrete.”

BIOBASED – CERTIFIED LEGAL HARVEST WOOD PREREQUISITE: Providing a credit for using 10% non structural wood in a project, is too easy for a leadership standard. I suggest dropping this credit and instead adding a prerequisite that all wood used in the project have a certification that it is legally harvested. For all the controversy about the benchmarking proposals in the forestry debate, this is one that I expect all sides should be able to agree upon.

BIOBASED – REQUIRE CERTIFICATION FOR RAPIDLY RENEWABLES: Rapidly renewable products can have serious health and sustainability problems depending upon how they are harvested. Good certification program exist that should be required for agricultural/rapidly renewable products just as they are for forest products.