Our major renovation project is a high-rise building in Germany. One of the recycling methods we apply is underground waste disposal, also called mine backfill (Bergversatz), a method which, in Germany, is governed by statutory provisions. Since with our project, a relatively large amount of material (gypsum waste, sheet glass, gypsum fiberboard panels, etc.) is disposed of in this manner, we would like to make sure that this way of recycling is acceptable in line with the Credit Intent. Underground waste disposal or mine backfill means that exploited deep mines are backfilled with liquid or solid mining or non-mining materials. Depending on their nature, the filling materials are stored in barrels or packed in big bags and their storage is controlled. The backfill may also consist of bulk material. Under the German Closed Substance Cycle and Waste Management Act (Kreislaufwirtschafts- und Abfallgesetz) and, in addition, under the German ordinance on the underground disposal of waste (Bergversatzverordnung) it is specified that if this disposal serves an economic purpose, e.g. if it prevents a mine from collapsing by filling it air-free, it is not considered as waste disposal but rather as waste recycling. Furthermore, for every 500 metric tons, analyses must be performed and submitted which confirm that the underground waste material is recognized as safe. As under the applicable German laws and regulations, underground waste disposal is recognized as recycling, we would like to know whether this recycling method complies with the requirements of the LEED Credit Intent and whether LEED also recognizes underground waste disposal as a means of recycling?
The applicant has requested acceptance of mine backfilling as an equivalent means of accomplishing construction waste management. Based on the description of the process, it does not appear that this practice will meet the intent of the credit. In addition to encouraging the diversion of debris from landfills, the credit intent includes an expectation that projects "redirect recyclable recovered resources back to the manufacturing process." While it is recognized that using clean waste material from construction rather than other potential materials to back fill deep mines may be environmentally preferable, this practice is not aligned with the intent of the credit. The waste is in essence going to a "landfill" and the specific materials noted (gypsum and glass) are known to be potential feed stocks for manufacturing processes. By using them as fill material, the proposed practice is burying potentially valuable raw materials. Underground waste disposal is not a recognized means of recycling for this credit. Applicable Internationally; Germany.