The reporting that I have used for steel on all my projects has been successful and met the expectations of the reviewers in terms of the point of manufacture and extraction. However, I am currently working with a new steel fabricator that disagrees and I'm struggling to find a clear, concise answer for why I don't think the documentation they have been using will still be acceptable. There are several new threads on here with similar comments, which always makes me feel better. I like knowing I'm not alone in the fog.
I use the steel mill for manufacturing and the scrap yard as the extraction point. The fabricator has been using their location as manufacturing and the steel mill as the extraction point.
Technically, the addenda and other resources seem to support the use of their fabrication yard as the manufacturing location, but will the reviewers accept the steel mill as the point of extraction? My recent experience tells me no, but the actual verbiage of the addena says manufacturing is the point of final assembly and extraction is the point at which it is packaged for delivery to the manufacturer, which would be the steel mill.
Is there anything I can reference to clarify this issue as it relates to steel?
Tristan Roberts
RepresentativeVermont House of Representatives
LEEDuser Expert
11477 thumbs up
July 12, 2013 - 4:25 pm
I would reference the addenda that talks about this. I think we talk about it in our guidance on LEEDuser above and on MRc4.The fabrication point is fine as the manufacturing location, but I agree that the scrap yard is better as the extraction location. This is a bit of a gray area, however, as you have probably noticed from these forum discussions.
Tiffany Moore
Built Environment ProfessionalBuilt Kansas City LLC
35 thumbs up
July 12, 2013 - 4:42 pm
Thanks, Tristan. I have recently received review comments asking to clarify the scrap source vs. the mill location. Those comments have led me to believe this area is receiving more scrutiny by at least some review teams.
Keith Lindemulder
Environmental Business Development- LEED AP BD&CNucor Corporation
193 thumbs up
July 24, 2013 - 3:55 pm
Tiffany, I would suggest that the real answer is "it depends". Some steel products go directly from mill to jobsite without additional "manufacturing value" added to them. Stock lengths of rebar, many steel wire and wire mesh products and piling come to mind. In this case, the final point of manufacturing would in fact be the mill.
However, many other steel items DO make a pit stop at a fabricator/manufacturer along the path to the jobsite - Fabricated rebar assemblies, structural steel fabrications, cold-formed steel components, bar joist & metal deck to name a few. In this case the final point of manufacture would be the fabrcation factility which is rare at the same locatoin as the mill.
In terms of extraction or, in the case of scrap, recovery, that's a bit more complicated. For "extracted" raw materials, that point of extraction would be the mine (think iron ore). For "recovered" raw materials (scrap) the addenda that can "include a recycling facility, scrap yard, depository, stockpile, or any other location where the material was colleced and packaged for market purchase before manufacturing," That can mean lots of things since many mills which utilze scrap steel to produce new steel have "scrap yards, stockpiles and/or recycling facilities" on site.
To make maters more complicated, most mills using scrap steel as a raw material input are receiving scrap from many (dozens) of locations. The problem is these scrap yards are not in one locaiton and the LEED MR5 documentation only accepts a single location (zip) as input. So, in our case, we provide the percentage recovered "within 500 miles of the project site" and recommend the LEED team use the mill zip code as the "recovery location".
All that said, I'm seeing more and more inquiries or request to verify the data from GBCI reviewers.
Tiffany Moore
Built Environment ProfessionalBuilt Kansas City LLC
35 thumbs up
July 25, 2013 - 3:43 pm
Keith,
Thank-you for your comments. The process of keeping up with the ever-changing focus of review teams is a challenge, but I always appreciate suppliers and manufacturers that accept the fact that my inquiries are real and provide useful support. (I.e., don't kill the messenger.)
I was recently asked to validate that a particular mill received their scrap from a source in the same zip code to support the claim for that item. I used website information to document the street addresses of the mill and the car crushing yard in the same town. It was accepted by the reviewers.
To my original question, I still anticipate some issues using the actual mill as an extraction point, but I'm going to submit and see what happens. In this case, it doesn't affect the project goals and will be helpful to validate the various ways this credit can be reported.
Charline SEYTIER
CEO, Co-owner.ThemaVerde, France
15 thumbs up
October 22, 2013 - 11:51 am
Thanks for your insights.
Did any of you submitted this already and got feedbacks from the reviewers??
We are dealing with the same issue in one of our projects:
The manufacturing plant of the steel framework is within 500 miles.
But the scrap is collected from dozen of locations and from different suppliers in several countries in Europe.
The back-up letter from the manufacturer is providing a "weighted average distance" of 155 miles between all scrap collection locations and the manufacturing plant. The weighed average distance was based on the weight of scrap collected at each location.
We don't know if the reviewers would accept that type of back up even if this distance is well below the 500 miles.
Can anyone please advise?
Tiffany Moore
Built Environment ProfessionalBuilt Kansas City LLC
35 thumbs up
November 4, 2013 - 12:19 am
Charline,
My project has not yet been submitted, but I will update this thread when I get review comments.
Thanks!
Charline SEYTIER
CEO, Co-owner.ThemaVerde, France
15 thumbs up
November 4, 2013 - 8:00 am
Thanks Tiffany!