In all my 40 LEED projects I have never included labor and delivery to a material's cost total. I received the following comments and am at a loss as to how to respond:
Let me also be clear that this is for MRc4, not MRc7.
The LEED Form states that 23.7% of the total building materials content, by value, has been manufactured using recycled materials. However, in order to demonstrate compliance, the following must be addressed.
TECHNICAL ADVICE
1. It appears that the Plyboo Sierra Sahara Strand and Plyboo Dimensional Lumber were sold to Mission Bell rather than to the General Contractor or the Owner of the project (a.k.a. the end-user) which may indicate that these products are raw products that are part of an assembly and therefore it is unclear if the FSC Chain of Custody (COC) has been in place until the assemblies reached the project site. Entities which modify the products packaging or form (except as required for installation) must have a CoC Certification. It is unclear whether Mission Bell has and/or requires a Chain-of-Custody (CoC) certification.
2. It is unclear if the total cost of assemblies, instead of raw materials, have been included in the calculation, as required. Provide a narrative which describes the Chain-of-Custody for Plyboo Sierra Sahara Strand and Plyboo Dimensional Lumber including how the products were used in the project. Explain who manufactured, distributed, modified, and installed the products. Revise the calculation as necessary to include the cost of whole assemblies, including labor to construct the assembly and delivery to the project site. Ensure that this information is reported consistently throughout all MR credits. Provide additional invoices as necessary to confirm any revised costs. See LEED Interpretation 10296 for further information.
emily reese moody
Sustainability Director, Certifications & ComplianceJacobs
LEEDuser Expert
452 thumbs up
March 6, 2015 - 4:44 pm
I'm not the resident expert here, but we have had comments returned on many projects that were just flat wrong. We have had success contacting GBCI prior to returning our clarifications and shown them the comment, given our view on it with concrete reasoning or language from the Reference Guide, and asked for them to clarify.
I would try that here for sure.
Susan Walter
HDRLEEDuser Expert
1299 thumbs up
March 6, 2015 - 5:16 pm
First thought, can you lose this product and still hit your recycled content goals? If you're already past the finish line, quit running.
Second, the response seems consistent to me. it appears that the Plyboo was sold to a subcontractor who then supplied it to the job. If you reported the cost of the Plyboo to the subcontractor you have the wrong number. You need the number the contractor paid which would include any labor costs incurred by the subcontractor in changing the plyboo (assuming they did that). So the GBCI is asking you if you have all the costs included. You may or you may not, they want you to verify.
Here's hoping the link to the LI works: http://www.usgbc.org/leed-interpretations?keys=10296
Sarah Thompson
Sustainability CoordinatorXL Construction
March 6, 2015 - 6:28 pm
I don't have any of the products reporting any recycled content. That is what is frustrating. The price was the price from our Subcontractor, correct price from them.
Aren't all/most materials sold to the Subcontractor for installation through a GC? This isn't anything new, why they are calling out two products doesn't make sense.
Also, this isn't MRc7, it's MRc4. I don't HAVE TO HAVE a COC for the products. It is extremely trying to make sure you have the matching invoice once it meets our hands. This isn't a requirement for MRc4, nor LEED as a whole.
Charles Nepps
NH Green Consulting97 thumbs up
March 7, 2015 - 6:25 am
The only part of the reviewer's comments that make any sense in regards to MRc4, is to verify the total materials budget is correct. The FSC comments are only applicable to MRc7 (or 6) and the LEED interpretation they cite (10296) is a ruling on Certified Wood products. You definitely need to contact the GBCI for clarification, as the reviewer's technical advice is not applicable to the credit.
RETIRED
LEEDuser Expert
623 thumbs up
March 9, 2015 - 10:35 am
Sandy - It looks like you got a variety of good advice from Emily, Susan, and Charles' responses above. I would add that I gotten some really off-base review comments in the past but that that has not happened as much since GBCI began hiring qualified internal reviewers. That said, contracted review teams are still doing reviews and may not be as versed as internal reviewers...
I agree that the Technical Advice does not make sense for MRc4. I would contact GBCI via http://www.usgbc.org/contact and select the Certification Question button. Then select Questions about Review Comments from the Category List.
Lastly, I've always included delivery of materials to the jobsite as part of the cost of the material. Page 245 of the 2nd edition (May 2011 version) of the LEED Reference Guide for Green Interior Design and Construction states: "Materials costs include all expenses to deliver the material to the project site. Materials cost should account for all taxes and transportation costs incurred by the contractor but exclude any cost for labor and equipment once the material has been delivered to the site." I think that the labor that the review comment is referring to is the assembly labor, which should be included also as that labor would be to put the assembly together before it comes to the site. You should consider your methodology of excluding transportation (and maybe labor - depending on when it occurs) from the material costs.
emily reese moody
Sustainability Director, Certifications & ComplianceJacobs
LEEDuser Expert
452 thumbs up
March 9, 2015 - 10:11 am
The 2011 language is interesting...Do you think this is an instance, like Addenda, where it may depend on when your project was registered whether the later clarified language applies?
RETIRED
LEEDuser Expert
623 thumbs up
March 9, 2015 - 10:57 am
Emily - I believe this language was present in the first edition (April 2009) version of the ID+C Reference Guide but my first edition version is corrupted and I can't confirm that; however, this language is present in the April 2009 (first edition) LEED Reference Guide for Green Building Design and Construction. I don't think this is new info. I've always considered the cost of a material to be the cost that the project incurs, which would include delivery of the material.