PC MRpc87 Feedback

This is great feedback Dan! To add on - I would also love to see increased verification requirements and regulations for the sub tiered recycling facilities as well as a push to get more facitilies verified. This Pilot credit is restricted to companies operating in a market where certified facilities are available, making it a difficult credit to pursue in some geographic regions. It will be interesting to see how the success of this Pilot credit impacts the number of certifiied facicilties and the mile radius that they choose to serve.

Interesting. We have one verified facility in our area and projects that have used them get monthly reports with cumulative total tonnage and recycled content data. I have not run into the issue of sub-facilities. I guess it is different per location.

I have to agree with Dan. This credit should really be moved from pilot to integrated into the formal scorecard and for more than 1 point. We are at a point where facilities incorporating the infrastucture for recycling is putting a bandaid on a bulletwound when our primary and sub facilities that are outside the boundary of the project are not handling or processing the materials appropriately. Admittedly, I come from an area where we no longer can recycle anything but cardboard any longer so I'm a bit bias.  Echoing Dan's third bullet point, while we continue to champion this pilot on our side, adding this as a formalized option with more weight would help drive the change needed by putting pressure just like the materials EPD credit initially did.

I have to agree with Dan and Randi. We have a few facilities in our State so projects close to them can easily achieve this pilot. However, there can be troubling differences in the RCI reporting facility numbers and the monthly diversion rate backup that these facilities provide for the primary CWM credit. I am also concerned that much is happening in this industry beneath the surface reporting that we know nothing about.