Structural Steel Backup Letters

We have seen letters that stated

"our product is manufactured through the Basic Oxygen Furnace; this process includes a 32.7% recycled content". 

OR

"our product is manufactured through the Electric Arc Furnace; this process includes a 93.3% recycled content".

Without the 30% enclosure cap imposed by LEED v4.0 we are able to achieve this. Be sure to sub in the v4.1 credit path.

Hope this helps, Good Luck!

At least with Nucor, I have found that their backup has always been accepted (at least for LEED v2009) because they weren't based on a generic Industry Average, it was the average recycled rates for their particular product from a previous year, from a particular mill.  Ex:  a Nucor product that derive from a particular bar mill is one recycled-content threshold, a product from a particular sheet mill is a different recycled-content threshold, etc..  I am wondering if it is a case of needing to drill down a bit more with the steel manufacturer's sustainability staff, to get the right documentation for v4.

Thanks to Michelle and everyone on this thread, for the headsup!

Hmm. Yeah, it used to be that as long as it was the specific product and/or mill it was accepted. The issue with average values was when the documentation was using company-wide averages for a variety of products from different mills.

I know some Nucor documentation had both general (company-wide) and mill-specific values. Did you use the company-wide value or the mill-specific (usually grouped together, but you'd just need to indicate which specific mill you used - Cartersville, GA for example).

Michelle, that is definitely alarming!  Can you clarify if you were using the letters available here: https://nucor.com/certifications (under LEED Certifications/Recycled Content, letters "Steel Mills Recycled Content" and "Product Groups Recycled Content".

That "must be product specific, not company/industry average" guidance was the case in v2009 too. I've seen similar review comments on v2009 steel docs and honestly I think whether those letters get questioned comes down to how stringent a particular reviewer is. (Outside of obvious issues, like a manufacturer letter saying "according to this steel industry study...") 

Michelle, i think you're right that a letter that says the same thing but doesn't use the word average will get accepted. It's a little like the conversation we were having earlier about site separated versus commingled waste, that we're using the best numbers we're given to work with, and we just need to avoid giving reviewers a reason not to take them at face value. And I know we're not doing this in bad faith to gain unearned points, just trying to fit industry reality into the LEED framework. I would expect:

"X is made using process Y, which has an industry average of 75% post consumer" = no

"X has a companywide average of 75% post-consumer" = no

"X contains 75% post-consumer" = yes...even if we don't know that 75% isn't derived from an industry or company average. 

I think I would send an email to GBCI in this case, questioning the comment and what changed to make the Nucor letter no longer compliant. The ref guide states "Project teams may use the average recycled content value provided by a single manufacturer for a single product" and it sounds like that is what Nucor is giving us (although specific products may be custom made the inputs are the same). 

With v4 experience still being new and reviewers having the same limited resources as project teams, I'm not surprised by some inconsistency but I hope that pointing it out at least gets some clarification as to what document WILL comply. 

I recently received a comment from a LEED reviewer similar to what was stated in Michelle's original post. The reviewer requested that we provide "product-specific" recycled content values or use the default 25% recycled content value. This comment was aimed at the recycled content documentation that Gerdau and Nucor provides. Note that I used the mill-specific recycled content percentages and not the company average which is also included in the beginning of Nucor's letter. Can Michelle provide an update as to if and how she was able to resolve this on her project? Also, if anyone else can provide some feedback about how they were able to successfully respond to this type of comment, that would be helpful.

Echoing Michelle's conclusion. The effort involved in pursuing this Credit is onerous, especially for large and complex projects. Better to look for less labor and/or cost-intensive strategies.
Having said that - and not to hijack the discussion - we are encountering the same obstacles for the Low-emitting materials credit as well.

I, too, have seen regular issues with this Credit on my NC and CS projects. Oddly enough, though, my CI projects are able to get just over the threshold needed for compliance, but barely. I assume this is b/c of the nature of the interiors product mix of the projects versus the scale of NC/CS.

Thanks for your feedback. I agree that the documenting this credit is a laborious undertaking, but most of my clients are Contractors and they are often required by project specifications to document the achievement of this credit. I have been able to achieve this credit on one other project, but that was an ID+C project that did not include a lot of steel or structural materials. Most of the recycled content contributions came from the furniture and we were actually able to document more than double the required threshold for the base credit to earn an exemplary performance point. For most NC projects though, it would likely be impossible to achieve the credit without being able to use the higher recycled content percentages for steel. That would be the case even when using the v4.1 substitute that eliminates the 30% cap on structural materials.

I did reach out to Gerdau and Nucor to try and get additional documentation that clarifies why the mill-specific percentages they are reporting can be considered "product-specific" in an attempt to salvage the credit. I will plan to update this forum about the outcome.

Marcia,

I just looked back at a recent project and we did include Vulcraft/Nucor structural steel (as well as other steel products from Clark Dietrich and Marino/WARE.)
We submitted a letter from Nucor that identified the specific product groups (like Vulcraft), mill locations and product types, and provided the calculated pre- and post-consumer recycled content. The letter appears fairly standard - we have used similar letters in LEED v2009 projects, so I would think it's not a difficult request for Nucor to provide. 
Good luck!

We have been successful achieving this credit on LEEDv4/4.1projects using this methodology and reccomend to attemp it in most cases. This includes interior projects depending on size (if the project is large enough where the economics of pursuing LEED certificaion are reasonable). For example: Nucore and Clark-Dietrich (metal stud materials) have been good in providing the inecessary info on product (and/or plant) specific material to the subcontractors and them to us. 

Marcia, we just encountered this comment on a project. Were you able to get anywhere with Nucor? Did you find any resolution?

Nash,

Thanks for the reminder to provide an update on the outcome. Nucor was responsive to my request and did provide me an updated letter, but I did not feel like it would address the LEED reviewer's comments sufficiently. Gerdau did the same, and I felt that their updated letter was more pointed. In the end, I resorted to using the default 25% recycled content value for the Nucor materials and I used Gerdau's newer letter to justify the higher percentages for their materials. That satisfied the LEED reviewer and it was enough to keep the project over the required threshold to earn the credit.

Were your submitted calculations already based on the newer credit requirements for LEED v4.1 that lowered the compliance threshold to 15%? Maybe consider using that if it can help your project.  

We did just receive feedback on a number of recent v4 projects and were successful in documenting steel backup - we followed our developed v2009 process which included utilizing the mill certs and developing a weighted average for the steel components. Even with this, it was more difficult to achieve the recycled content and we relied on the Q2 Addenda reducing Sourcing to 15% to achieve credits.

Marcia, thanks so much for the prompt follow up. I'll pass along your feedback to our team working on this specific item. It's discouraging that even Nucor couldn't provide sufficient data but I'm so glad you reached out and gave it a shot.