Recycling Facility Letters of Certification

John - I haven't had the opportunity yet to work on any overseas projects; however, I am not aware of any special requirements for international projects for MRc2. Does anyone else have experience on this who can share his/her insights?

I don’t have overseas experience either, but I have dealt with a couple regulatory issues that apply to ALL projects, but differently depending on locale: 1. Minimum Project Requirement MPR 1 requires all project work to “comply with applicable federal, state, and local building-related environmental laws and regulations in place where the project is located.” Therefore, all laws regulating waste disposal and recycling in you jurisdiction apply. Your waste handlers, recyclers, & disposal sites must comply with certifications, registrations, & any other qualifications required by local regulators. 2. Also, for commingled waste that is sorted at an off-site facility, LEED Interpretations #10060 & #3000 and Addenda Item #100000902 prescribe a method of calculating diversion rates base on annual averages, but this method only applies if the facility is regulated by local “government authority as a closed system.” See: http://www.usgbc.org/leed-interpretations?keys=10060 . and www.usgbc.org/leed-interpretations?keys=100000902. If local government does not regulate the sorting facility, each commingled load must be evaluated by weight as described by “Methodology #1” in the ruling for LI# 5171: http://www.usgbc.org/leed-interpretations?keys=5171.

Jon - Thanks for sharing your thoughts. I reached out to USGBC and a reviewer replied that there are no specific requirements for projects outside the U.S. She did highlight the same information that you mention regarding commingled waste verification. She pointed specifically to 5/9/2011 Reference Guide Correction ID #100000902 - http://www.usgbc.org/leed-interpretations?keys=100000902 - and if the annual average recycling rate of the sorting facility is used, then it must come from a regulating local or state government authority.

Incidentally, Construction Waste & Demo Specs that I have worked with include contract language requiring compliance with local regulations and licensing requirements. As a result, the submitted Construction Waste Management Plans (CWMPs) have included evidence of approval from local regulators. These attachments may become part of the LEEDonline submittal when we upload the CWMP, as required, to the MRc2 form. Also, if the waste table on your MRc2 form includes commingled entries, LEEDonline requires you to upload documentation to support the reported diversion rates. If using the “average annual” facility rated allowed above, that documentation must come from the local regulator. Review your waste contract language, research local requirements, and work with local regulators to obtain proper documentation.