Hello everyone!
We're working on a project based in Japan and this is the first time we're doing the v4 version of the prerequisite "Construction Activity Pollution Prevention."
Our plan covers all the points in section 2 of the U.S. Environmental Protection Agency (EPA) Construction General Permit (CGP) (e.g. providing natural buffers, installing perimeter controls, etc.). However, some questions have come up in our discussions with the builder on the level of detail to which certain points must be applied or documented and what is feasible.
Does anyone have experience on applying section 2 of the CGP outside of the United States? Did you receive any feedback from USGBC? Any advice?
We believe our policy is generally aligned with the CGP, but certain things work a bit differently, so it may not be feasible to exactly align with certain aspects.
For example:
From 2.3.2 General Maintenance Requirements -> "All pollutant-generating activities and pollution prevention controls will be inspected every 14 days, and within 24 hours of the occurrence of a storm event of 0.635 cm or greater, to avoid situations resulting in leaks, spills and other releases of pollutants in stormwater discharges."
-> Inspections will take place every day or at least once per week, but not necessarily with date stamped photo. Date stamped photos will be taken once per month at least. Would this be OK? Or should we make sure to take date stamped photos every 14 days?
For Part 2.2: Stabilization Requirements -> "Earth-disturbing activities have temporarily ceased when clearing, grading, and excavation within any area of the site that will not include permanent structures will not resume (i.e., the land will be idle) for a period of 14 or more calendar days, but such activities will resume in the future."
-> Is it necessary to align with the 14-day period here? There will be stabilization, but local timing may not align exactly.
Thank you for your help!!
Gina
Emily Purcell
Sustainable Design LeadCannonDesign
LEEDuser Expert
371 thumbs up
April 18, 2022 - 9:49 am
Hi Gina, I haven't had this experience personally, but I can say as far as LEED reviews of this prereq go, the reviewer will not look at every single report. They expect to see reports from throughout the job (beginning, middle, end) but it's more of a spot-check than a comprehensive review of the inspections - submitting 3-5 reports from the total duration of the job is typical. And those reports can be narrative OR date-stamped photos. Since it sounds like timing rather than the best practices themselves is the main concern, I don't think you'll have an issue generating the LEED documentation you need by following local practice.
Gina Anderson
Lendlease JapanApril 21, 2022 - 4:32 am
Thanks Emily, very helpful!