LEED v4.1 makes changes for commingled waste in Option 1 - What do you think?

Hi Michelle,

Well I'm honestly not sure how much difference the new language makes. My issue has been a lack of understanding about why commingled waste is only considered one waste stream, when by definition it's composed of multiple types of waste and those separate waste types get diverted by the receiving facility.

With this language that issue has not changed. To get the benefit of less source separation on-site, you must use a certified recycling facility for the commingled waste. There are two such facilities in my entire state. So some projects will be able to consider that route cost effectively but many won't. And still projects will have to do some source separation also to get any points at all under these options. Overall it might be slightly better. I guess I feel like we were thrown a bone while I was hoping for a true rationale that supported their position.

The Option 2 increase to 7.5lbs / SF may actually be more beneficial, particularly for CI projects that don't have a lot of demo. We'll have to do some analysis.

I'll be interested to hear what others think. Thanks for asking.

Thanks for opening this topic! It hasn't been a huge sticking point for any of my projects so far, but so far all my v4 work has been in big cities with good waste diversion options. The main issue has been the cost (and inefficiency, and additional emissions...) of hauling waste to the one qualifying site in the metro area.

It looks like there are only 18 RCI-certified facilities listed on the RCI website (and 1/3 of those are in California, where code requires diversion in the first place...). So this simply won't be an option for many US projects until more facilities earn the certification. 

Overall, though, I'm just still not clear on why commingled waste is so restricted in LEED. Have there been issues with the accuracy of claimed recycling rates? Is pushing for site separation a priority for the TAG? It would be easier to understand the difficulty of the credit and explain these options to a project team if I knew the rationale behind them. 

Ha, I guess we were having the same thought at the same time about the rationale...it would also be great to know the reasoning to be able to submit a comment on v4.1 that addresses the credit intent as well as addressing how unrealistic this option is. 

During v4 development I was told that USGBC wanted to encourage commingled recycling AND increase additional single-stream recycling at the same time. I do not know where the TAG stood on this. My hunch is that the v4 version was just a well-intentioned, but misguided effort to increase credit stringency and that during v4.1 streamlining, instead of fixing the root issue, they used the approach of lowering the thresholds while leaving the requirements intact--as this was a successful formula for many other credits. Unfortunately, that leaves us with a LEED that has a significant number of credits that are simply not available to rural projects. 

GBCI has informed me that the reason for the 'multiple waste stream requirement' is due to previous projects where quite a bit of concrete was hauled off prior to the build. In this scenario, the concrete weight has been 75%+ when compared to the total construction waste. So project teams may not have been as motivated to find additional strategies for waste diversion.

So v4 comes along and requires multiple waste streams to keep teams motivated to find additional waste diversion strategies. 

Hi all,

I appreciate the comment David and I'm all for motivation and encouragement. Perhaps the points and thresholds could actually reflect that a little better. However, in our area there is robust commingled recycling, but no facilities that will provide off-site source separation for the many tight urban infill project sites in Seattle. And frankly if they did, it would be costly. These requirements are resulting in significant labor cost and logistic effort for these urban site project teams for what seems to be very little benefit.

In response to teams requests for "project specific reporting", I am seeing reporting from local receivers that is translating eye ball audit methodology into reported tonnage. This encourages the LEED documenter to then enter that tonnage into the CWM calculator as if it's actually source separated tonnage because that's what it "looks like" on the reporting. Since no backup is required for source separated materials, these entries are accepted by all parties at face value.

My projects need the CWM points to make their goals in a v4 rating system that is very tight for available points with no room for error or trying something that doesn't work.  I am having increasing difficulty penalizing my projects over this requirement when I am seeing this reporting and know that other projects are achieving this credit with the same commingled waste stream they have always used. If I could make a case for the intent that seemed to justify this effort, I and my project teams might feel differently but as it stands...

Sounds very familiar to me, the tight urban site + materials broken down by type by the waste processer is the norm for our projects as well. the RCI certified option still doesn't seem like a good alternative - in the metro areas we build in most often, I'm seeing two certified facilities in the Bay Area and only one in Chicago, so that affects cost & hauling distance. In those same areas, local law and standard practice require recycling even if that 75% is met with demolition concrete, so we'd be looking at a really marginal gain in recycled material.

So I agree, I feel less incentivized to push a construction team harder beyond the current norm than to just accept the numbers a contractor/waste hauler gives me. And I'd consider it overly stringent if I got review comments questioning that those materials were in fact site separated...Maybe there is more to be gained on different project types, but for these big urban projects I'm struggling to see the benefit. 

Hi all,

I know we've covered all this ground but I just wanted to add the following. I spoke to a hauler who told me that they interpret the reference manual statement "Commingled waste may be considered only one waste stream unless the facility can provide diversion rates for specific materials" to mean that they can use the monthly diversion rate of the facility that shows the percentages of specific materials being diverted from that facility that make up that monthly rate and apply those specific material percentages to their load for that month. So they are reporting to their LEED projects those percentages of materials as separate waste streams even though they are picking up one commingled box from the site and the percentages they are using are not project specific.

Most of the facilities around here do the same Michelle, even though they all know it is misleading / inappropriate for LEED documentation. GBCI has been clear that what you're describing is not allowed but reviewers always accept it.

Emily - We only have one RCI facility in the state so not a great solution for us either. Ironically, that facility has a very low recycling rate according to their RCI reporting (low 50's) so even if it is convenient to use them it becomes really difficult to get to 75%. If you're not counting them as an RCI facility you can get a letter from them that gives a higher recycling rate :-)

Thanks, Nathan. I guess that I will just take the reporting at face value and not worry about it.

Only one RCI certified facility here in New York City (Cooper Recycling), so we're not seeing any benefit from the v4.1 modifications.

Thanks for posting guys.

What happens to International projects(in my case Saudi Arabia) where there is'nt any recycling facility approved by RCI? But there are facilities approved by local authority.Will they be counted as equivalent to RCI approved?

Ragesh, I think a case could definitely be made for the facilities approved by the local authority as an approved equivalent to an RCI facility. Depending on what the identified rates are for the facility, project-specific diversion rates might still be more ideal, but I think that if you have supporting documentation verifying the facility recycling rate, you definitely have a viable case.

Thanks a lot Tiffany.

I can't imagine many local authorities (Saudi Arabia or elsewhere) would be equivalent to RCI. LEED already requires state regulation just to use the annual diversion rate. To be able to reduce your number of waste streams you need to have the pretty rigorous audits / reporting required by RCI. Unless you can show the local authority is equivalent (super unlikely) I doubt this would be OK. 

Nathan, that is, of course, always a possibility, but as LEED has indicated "approved equivalent," I think it is worth making the case depending on the documentation available, until GBCI has made an official ruling one way or the other on this specific project request.  Ragesh, you can always reach out to a LEED coach (leedcoach@usgbc.org) or your review team to discuss it further detail as it applies to your specific project.