my client had been practicing ISO 14000 for several years (over 5 years). as such, they already had in place a related waste management policy. their performance is normally based on constant annual improvements albeit gradual and not as high as LEED targets (50-70% depending on type of waste).
are we supposed to put in place a new policy or ammend existing ones to meet LEED targets in order to get this pre-requisite and related credits? how does this affect the performance period declaration? will LEED consider past/on-going practice leading to relatively 'higher' targets or will it impose the same targets regardless of what has been/is being implemented?
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Tristan Roberts
RepresentativeVermont House of Representatives
LEEDuser Expert
11474 thumbs up
July 12, 2010 - 9:08 pm
Your similar question is answered on the MRp1 forum. It's fine to amend the existing policy to meet the LEED targets. You will need to be in compliance for the performance period—the existing non-compliant policy won't work in this case.
Pablo Fortunato Suarez
Principal ESD Consultant/ArchitectGreenArc Sustainable Building & Architecture
253 thumbs up
July 14, 2010 - 5:28 am
Thank you Tristan.
The client actually has a policy for 100% diversion for durable goods, facility alterations/additions, batteries and mercury in lamps, and a target of 70-75% for total (including on-going consumables) which was actually exceeded in certain periods.
My other concern is that they lumped all items in a 'total target'. While mathematically this will in fact be higher than LEED targets, is it necessary that separate targets be created in a policy for on-going consumables? Will this target (70-75%) for all, including on-going consumables + 100% durable goods, facility alterations/additions, batteries and mercury lamps be sufficient?
Tristan Roberts
RepresentativeVermont House of Representatives
LEEDuser Expert
11474 thumbs up
July 19, 2010 - 3:23 pm
You do need specific, separate targets for each of the areas covered by MR credits 7 through 9.
SIG - Sustainability Main Account
Sustainability ConsultantsSustainable Investment Group (SIG)
86 thumbs up
August 22, 2011 - 3:34 pm
Just received comments (copied below) on an application where this prerequisite was pended because our goals were not high enough.
"However, the policy has a goal of recycling 95% of mercury-containing lamps. The Requirements section of MRp2 in the LEED Reference Guide for Green Building Operations and Maintenance, 2009 Edition (Updated April 2010) states that the policy must have a goal
of recycling 100% of mercury-containing lamps. TECHNICAL ADVICE: Please provide a revised Solid Waste Management Policy that includes a goal of recycling 100% of mercury-containing lamps."
I'm posting here because I cannot find this requirement stated anywhere in the reference guide, nor in any addenda. Even the sample policy published on page 248 (2009 edition-updated April 2010) quotes a 95% reduction for mercury-containing light bulbs.
I am revising the policy, because we need to earn the prereq. and a goal of 100% is a good idea, not very different from a goal of 95%. However, I feel that this comment is unfair and characteristic of LEED reviewers interpreting the rating system differently than the general public. Has anyone else has a similar experience?
To help out the rest of us, the following policy goals were approved:
Reducing the overall amount of waste generated for:
Ongoing consumables by 70%
Durable goods by at least 75%
Facility alterations/additions by 70%
Batteries by at least 80%
Jacob Arlein
Director of Energy ServicesEnvironmental Building Strategies
64 thumbs up
August 22, 2011 - 4:59 pm
Charlie,
I completely understand your frustration with this issue, and the easiest answer to this and other required documentation contradictions is to trust LEED Online as the final answer. The sample plan in the reference guide is very old, I think it may actually be from an earlier version of EB. I am not sure what version LEED Online form you used when submitting this project but I just checked a version 3 MRp2 LEED Online form and one of the required check boxes asked you to verify that the plan addresses the goal that all mercury containing lamps be recycled. The form version can be found at the bottom of each page of the credit form.
In general, when LEED rolls out new documentation requirements they do it via LEED Online updated forms, and don't necessarily note this in addenda. It is kind of a strange way to do it, but that has been my experience. I would also strongly suggest using the LEED User policy templates (you can download them in the documentation toolkit tab), which note that 100% of the lamps need to be recycled
Jessica Hawley
Sustainability Consultant62 thumbs up
August 23, 2011 - 10:35 am
Under the "requirements" section in the reference guide (p. 245), it does say that "all" lamps have to be recycled, "Have in place a solid waste management policy for the building and site addressing the requirements of the waste management credits listed below as well as recycling of all mercury-containing lamps." The example plan that references 95% is probably just a carry over from older version as Jacob noted above. I would suggest submitting a comment on LEED online so they are aware of the discrepancy. We have submitted other discrepancy feedback on the LEED online feedback button and they have been pretty quick to respond. Good Luck!