We ran into a couple of questions with this credit for a project that used two haulers - one was RCI-certified and one was not. 90% of the overall waste was sent to the RCI-hauler and only 10% to the non-certified hauler. Both haulers are tracked/certified for average diversion rates by their local AHJ (in addition to the RCI-hauler being certified by RCI). It was not clear whether we could pursue this credit given a mix of haulers where not everyone is RCI-certified yet.
We ultimately are going to attempt the credit as we felt that we still met the intent of the credit as we prioritized the majority of waste going to the RCI-hauler (90%). We also could demonstrate that we still met the MRc2 minimum diversion rates even if we considered the non-RCI hauler to have diverted 0% (given that they are not RCI-certified).
We'll update with our review results in a few months.
Sofia Siegel
Verdical GroupMarch 20, 2018 - 3:14 pm
Out of curiosity, did your project achieve this credit with the two waste haulers used?
Kristina Bach
VP of InnovationSustainable Investment Group
151 thumbs up
March 21, 2018 - 2:39 pm
Sorry - forgot to do the update.
The pilot credit was rejected with the note that 100% of the waste was required to all go to the certified hauler. It didn't mater that it was only a single load/small amount that was sent to a non-RCI hualer. Nor did it matter that we still met the MRc2 minimum diversion rate even if you used the assumption that the non-RCI hauler landfilled all of their items (even though that also wasn't true). We strongly disagreed with this ruling as we felt it was holding projects to too high of a bar/allowed for no adjustments during construction. However, we did not push it further than the preliminary review/take it to an appeal as we had other credits we could substitute in its place to still ensure we got the point.
Joanna Switzer
Sustainability Project ManagerAtkins
59 thumbs up
July 12, 2018 - 5:26 pm
Thx for the feedback Kristina- this is a really important detail that the pilot credit language/posted requirements does not clearly stipulate. I tend to wonder if that was an isolated reviewer ruling or the true intent for the credit.
For example:
1) The overview indicates: "Recycle and/or salvage nonhazardous construction and demolition materials by sending the project’s TOTAL commingled waste materials to a mixed-recovery facility that has achieved third party verification of facility-average recycling rates", which suggests a qualified / high quality comingled waste recycling service facility must be employed to pursue this credit, but it does not seem to preclude source separated recycling practices.
2) Also- the credit specific submittal requirements include the note "Calculations that demonstrate that the REQUIRED PERCENTAGE of commingled construction waste is sent to a facility that has a current* third-party verified facility recycling rate", which seems to (perhaps vaguely) reinforce that 100% of comingled must meet this requirement, but again....it doesn't state that 100% of ALL C&D waste generated by a project must comply.
Hopefully GBCI will update the language to better clarify the overall CWM plan technical requirements.