We have the opportunity to use several different processors, all who claim to be able to recycle in excess of 90% of the materials typically found in Construction & Demolition (C&D) debris; however they are using significantly different methods for determining the recyclability of the loads they accept. Facility A: Has a processing facility staff member look at the loads when they come in to visually estimate the recycling percentage. We are concerned with the potential for "Green Washing" as many of these facilities are reporting very high LEED recycling rates despite overall facility rates that remain low. The business model of these facilities is typically focused on land filling waste and / or using C&D debris as Alternate Daily Cover (ADC) and calling it "recycling". Facility B: Is one of the co-mingled recycling facilities in our region that consistently achieves high recycling rates that are based upon the total tonnage shipped out of their facility on a monthly basis. All materials at their facility are accounted for in their recycling percentage, including the waste they generate from their own lunchrooms and offices while they process the co-mingled debris. They also generate detailed annual reports supporting their monthly calculations and provide them to the Washington State Department of Ecology and the Tacoma-Pierce County Health Department for third party review. We are confident in the recycling capability and the accuracy of the reports generated by facility B; however economics make it more advantageous to utilize the other facilities like Facility A when they are closer to our jobsites. 1.) Does the USGBC offer a prescriptive method for facilities to back-up commingle recycling percentage claims? 2.) Which of the two methodologies above are acceptable reporting methodologies? Both example facilities above sell varying percentages of ADC. When calculating recycling percentages the USGBC does not seem to have a limit on how much ADC can be claimed as a "recyclable" commodity. In a recent CIR dated 07/16/08 the response stated "Any construction debris processed into a recycled content commodity which has an open market value - e.g. alternate daily cover material, etc. - may be applied to the construction waste calculation". This ruling implies a waste facility can take C&D debris and simply process it as ADC and give a 95% recycling rate on a project. 3.) Can the USGBC define a limit on how much ADC can be applied to the waste recycling calculation (example: no more than 20% of the C&D stream can go to ADC on any given project)?