Suggested LEEDv5 Comment Draft for Waste Credits

I think the LEED v5 Constrution and Demolition Waste Diversion credit is a huge improvement to getting real and accurate information from C&D waste processors while encouraging teams to focus on creating reliable feedstocks for gypsum board and a few other target materials. More projects participating is more valuable for improving the industry than having fewer 'flagship' projects. I can appreciate and agree with the intent of the comments, however I disagree that LEED v5 should introduce (or re-introduce) that level of complexity into the LEED credit. Simplify the credit now. Raising the thresholds in a simple credit would be the next logical step IMO if the thresholds are nationally determined to be too low. Raising the thresholds could occur in either an addendum or LEED v6.

Conor—can you be more specific about what complexity you’re concerned about? Is it the re-introduction of the Planning pre-req? There seemed to be pretty strong alignment in the room that separate rates for demo waste and construction waste made sense (although we didn’t test that with actual polling or voting). What do others think? The deadline has now been pushed out to 5/24, so we have a week get aligned and get comments in…

Hi All- Have been speaking with more of the CDRA and also some SCL folks that have reached out on this over the past week, and have made further adjustments based on some great insights. The updated draft of comments I plan to submit by this Friday 5/24 is re-linked here, in case it's useful for others. Still interested in continued improvement to these comments, if others have suggestions. Cheers, Amanda

A few suggestions from the Consigli Sustainability team: * Agree separate rates should exist for demo and construction * We should include lbs/sqft * 15 lbs/sqft including demo, 10 lbs/sqft for construction only * Third party verified facilities should be required for 2 point option. There should be an alternative compliance for projects in locations with zero 3rd party verified facilities (states or countries that they simply do not exist) Thanks, Kena Kena David (she/her) LEED AP ID+C, WELL Faculty Director of Sustainability m: 585.350.5594 consigli.com

Public Service Announcement: Submit your comments before the holiday weekend! I wonder if the lack of comments here is due to: 1. Everyone being too busy 2. Many people already discussing the topic at the summit 3. A general distaste for trying to work through something complex in an open-ended written forum (See item A) 4. Most people being good with these drafted comments 5. All the above I’m sorry to have missed the waste discussion at the summit. I’m personally quite pleased to see the recommendation that we offer distinct diversion targets for construction vs. demolition. As it should be, in my opinion. I echo Conor’s previous comments RE: a favoring of simplicity as opposed to complexity. To Nadav’s questioning, however, he asked Conor for specifics and didn’t receive any feedback. From what I see, the proposed added complexity is in: 1. Addition of Site visits to processing facilities (suggested prereq) 2. Addition of waste minimization plan and results briefing 3. Addition of separate goals for demo vs. construction 4. Addition of multiple pathways with 3rd party facilities My thoughts on those, in order: 1. To me, requiring a processing facility visit on every project is pie in the sky. Britannica Dictionary definition of PIE IN THE SKY. [noncount] : “something good that someone says will happen but that seems impossible or unlikely : a very unlikely or unrealistic goal, plan, etc.” I.e. borderline insanity. I love the idea, but from a practical standpoint, will never happen. 1. I like the intent of a waste minimization plan. But, again, in practice, I’m ambivalent as to its efficacy. When I think of things like maximizing prefab to minimize waste generated, there are many other factors influencing what makes sense to prefab. Minimizing waste is a great metric to achieve, but very difficult to control. And if it stays it should exclude demo. (See item 3). 1. No comments, very much agree. 1. I personally like the advocacy piece. I feel like it forces an important conversation. Maybe some of this language could be streamlined. I didn’t add a “number 5” related to the general added detail in the draft comments vs. the LEED v5 draft language because I imagine the final LEED v5 language will eventually add in a similar level of additional details. I really appreciate having this resource to pull from in submitting my final comments. Would love to have the same thing for the other materials credits, although you can bet your bottom dollar that I’ll be telling them to get rid of the fractions of points for product contributions. Whole numbers only please. Steven Burke Senior Director, Sustainability D | +1 (617) 654 0691 C | +1 (617) 581 3644 suffolk.com From: Amanda Kaminsky <

After eagerly awaiting for nearly seven minutes and forty five seconds for my note to the group to arrive in my inbox, I was disappointed upon its receipt to see my formatting of bolds, underlines, and italics stripped from my message. Also, for whatever strange reason, my thoughts on the added complexity of our draft language - which I bucketed into 4 items – changed the list ordering in my commentary section as 1., 1., 1., 1., when it should have been 1., 2., 3., 4.. Of course, all of this is likely unnecessary to tell you, as it is probably already intuitive enough for the reader to piece the basics of the information together, but I don’t want the SCL to think I’m shortcutting the finer points of my message details. A final parting thought: If the suggestion is that we are somehow submitting these draft comments as a collective, I would personally not want to have my name attached (directly or indirectly) to saying we are suggesting the owner, designer, and builder have to visit a waste processing facility to start every job. Although it does say recycling and not processing, so I guess there’s a small distinction there, but either way. I don’t want to be the green guy that says if you don’t come stand and look at a pile of trash with me on every project then you can’t get certified. Steven Burke Senior Director, Sustainability D | +1 (617) 654 0691 C | +1 (617) 581 3644 suffolk.com From: Steven

I didn't see the request for a follow up from me until just now. That said, the complexity of the sample comment seems self-evident to me so i'm not going to copy and paste it here. I stand by my former comment and I prefer the simpler credit being proposed in LEEDv5 and if we can help the industry increase it's rates collectively, that is a worthy ambition, IMO. Simple credit, hard targets (but achievable targets, without facilities fudging numbers). I agree with the intent of separate rates for C&D, but I don't see how the C&D waste processing industry would be improved by adding this complexity to overloaded project teams. I'm not sure how MRFs would distinguish diversion rates from demo cans and construction cans. The earth doesn't care what phase of construction a project is in. Lastly, I've visited every MRF that my company uses, many of them multiple times. I'm on first name basis with some of the facility managers. I've brought interested team members, too. but making that a prereq is just one example of unnessary complexity. Just because something is good to do doesn't mean that it should be a prereq or a credit requirement.

one more example (dang it, i said i wasn't going to copy and paste the whole document) :) "Define a source separated material stream as one material type separated onsite and carted separately, with <5% contamination rate maintained." I've already stated that I agree with the intent of most of the comments, but intent aside, how would "<5% contamination rate maintained" be enforced, tracked, and verified as accurate in reality? and presuming you could actually get an accurate number on that, projects that hit 5.1% contamination rate would fail to achieve the point?

Conor, I always appreciate hearing your thoughts. We both agree that simpler is better. I would say having different targets for construction vs demo waste isn’t targeted at the facilities, it’s at the project teams. Making this adjustment would be similar to when LEED v4 capped how much your structure could contribute to recycled content. Prior to that, project teams with a bunch of steel were just getting the credit by default. It’s the same here: Projects with substantial demo can hit the overall diversion rate without trying or doing anything differently, so it distorts the field. But, your point is well-taken… If we weighed the drawbacks of the added complexity here against the value of giving more accurate targets to the two types of waste projects generate, maybe the complexity brings people down more than accurate goals bring people up. I’m not sure that’s the case, but it’s worth discussing Steven Burke Senior Director, Sustainability D | +1 (617) 654 0691 C | +1 (617) 581 3644 suffolk.com From: Conor M

Hi Amanda, Firstly, thank you for all your work on developing these proposals for the C&D waste requirements. We think its a great improvement to what is currently in the LEED v5 draft. We only had a few comments regarding the objective and required outcome of the recycling facility tour if you wanted to include it in the submittal from SCL today (if I am not too late):  Recycling Facility Visit:  The intent of the visit is to provide education to the OAC team on the C&D waste disposal and segregation process including data on current recycling rates and environmental impacts in the project's region.  Requirements:  - A detailed tour of the C&D recycling facility where the waste management process, current recycling and diversion rates are explained.  - A report on the types and quantities of materials processed, recycled and landfilled from the specific recycling facility (within the last 30 days of hauling/facility contract award) must be provided for compliance. 

Super helpful insights here. To be really clear (+ I've revised the intro. statement on the Google Doc comments to reflect this), I've only shared my draft comments with intent to reflect back some great ideas I heard from the SCL group, plus strong perspective from CDRA recyclers on what they've experienced firsthand can improve diversion. These comments have evolved since I first shared the Google Doc, based on feedback from both groups. Obviously, these two groups have some differing perspectives, and each one of us individually also brings an (awesomely) unique perspective too; it's what makes every project fun and interesting. What's included in my final draft are the suggestions I believe will provide for a well-planned process and outcome for less waste created + more waste diverted, as seen through my own experience lens. Really appreciate all of your lenses that you'll comment through as well. On reinstating + "bolstering" the planning prereq- Might some of the planning take more time than current waste management takes? Yes! But, I think it should. In my experience, there is not currently enough time/thought put into the opportunities for waste diversion in the early stages of a project. Many of our folks on sites then often have a visceral negative reaction to wasting recyclable material when they see it accruing in real time on a project, but it's often challenging to instate the necessary supporting logistics and reverse supply chain in those moments when they weren't planned for, and amidst all the other moving parts and pieces at that stage.  Kena, on including lbs./sf targets, I totally agree with you! I honestly just don't know firsthand what these numbers should be! So, hoping you include your suggestion in your comments. My hope is that via waste minimization planning in early prereq. documentation and then an actual results briefing at end of work in the credit documentation, USGBC learns more, shares back, and appropriately hones those targets as we move forward. But maybe they/we can start with good data from you and others. On recycling facility visits, believe these are important for 1) understanding the differences between third-party verified facilities and those that are not, incenting increased use of third-party verified, and 2) developing a critical eye on honest capabilities for truly creating less waste and diverting more of the waste we do generate. Our teams visit manufacturing facilities, quarries, etc. when we procure products. If we are facilitating an increasingly circular economy, our recycling facilities are initial harvest sites in current and potential improved manufacturing. I'm always learning more from what materials we see in separated piles with robust endmarkets as well as in the piles often being loaded onto railcars to landfills in Ohio that can inform what materials we buy now/next, how these are made, where we make them, how we package them, and how they are managed on site.  Happy Commenting, and Happy Memorial Day, All. :) -Amanda

Hello friends, As procrastination followed by hyperfocus is my forte, I kept planning on making comments and then getting pulled to other responsibilities. I uploaded my comments on LEEDuser for this credit, but wanted to try to be concise (almost impossible) in my response to this thread. Like/agree:

1. The prereq needs to be reinstated. Without it, LEED/USGBC is neglecting a huge problem and taking their eye off actually supporting necessary industry progress.
2. Goals (and points) need to be logically different for just construction vs. demo + construction
3. Advoacy is important, should be pushed

"Disagree"/Opinions:

1. Requiring a visit to a processor for projects is eye-opening, but challenging to the degreeⁿ to actually pull off consistently. I can only imagine the cost and pushback for each unique project to do this. Plus, if you tell the processor "we will be visiting on this day at this time", I'd bet dollars to donuts that you'll see some great waste practices that weren't there the day before and won't be there tomorrow.
2. There should be more points given to projects that enact better contractor waste practices. Site separation of streams should be consistent throughout ALL point thresholds, as I think that is best practice and moves the industry forward. It also helps processors raise their own rates, especially if they are a commingled recycler and *claim* to divert differnent material streams.
3. Waste minimization (lbs/sf) can be an alternate compliance pathway, but should be worth minimal (1) points. If you can't hit a ~10/15 lbs/sf threshold, you can still choose to site separate material at least 3 streams if you actually plan for it. Rewarding full points for this will just allow larger projects to get by without any changes and small projects/demo included projects to suffer.
4. Third party facilities should be an "OR" option for 2 points, but an "AND" requirement for 3 points (ID+C). If you don't have one in the area, perhaps an advoacy innovation credit can support looking to bring one into your area.

On that last point, it's bewildering to me that the BD+C waste credit only gives a possible 2 points. With no planning prereq, I would prepare to see BD+C projects simply abandon this credit and focus on others. Lastly (I said I "try" to be concise, not "will" be), something needs to be done about diversion % reporting. I suggested creating a template form for annual rates that has the processor fill out total C&D haul tonnage in, list material streams and end use markets as well as lines for ADC/BUD and landfill/incineration. If all that is required is a letter, and the processor is not third party certified, the plague of "99.6% diversion just trust this single piece of paper" will only persist. I'll attempt to use the attach feature to link a word doc version of my comments, feel free to roast me if I am being too optimistic/left(ist) field.

Every LEED Credit and respective requirements should have 3 impacts:

1. Improve preformance on that specific project.
2. Inspire non-LEED project clients and project teams to want to register and be LEED projects too.
3. Have a positive impact on the AEC industry so that non-LEED projects benefit too.

Requirements that don't hit on all three aspects fail to scale and therefore fail to make the necessary positive impact we all want. I prefer elevating goals rather than mircomanaged processes. The existing LEED v5 language may encourage more participation in LEED and argueably would have a more positive impact on the industry than the perfect credit language for a tiny fraction of building sqft work. If you're reading LEED credit language and commenting and not thinking "Scale, scale, scale", i think you're missing the mark.

1. I rely on the relationships I have built with c&d waste haulers to complete this credit and keep track of the trash and recycled waste. I require them to complete the Excel doc monthly and email it to me when they submit their invoices and pick tickets. Being located in Wisconsin, my waste haulers take the recyclables to multiple facilities and the trash to a landfill. I will NOT require them to go tour every facility they use and have likely already been to. I will also NOT be wasting my time to drive around the state and visit landfills or recycling facilities. No one has time for this, and time a resource. Not to mention, driving around the state to go on tours is anti-sustainable. We don't drive around and tour material manufacturing facilities. Whoever thought this nonsense up clearly doesn't work in the fast paced world of construction and doesn't understand that we have to trust our subs and suppliers. 2. If the intent is to minimize waste, then things that happen in the planning phase like virtual construction (aka BIM) to do clash detections, which saves an enormous amount of waste - time, rework, RFIs, change orders/money - should be a requirement. During the entire design/build process enable project teams to take credit for implementing "lean construction." During the planning and preconstruction phases, enable project teams to take credit for methods like prefab that minimize waste generated, which is standard practice for steel components, precast, ductwork, light fixtures, and numerous other building components. Minimizing waste is a great metric to achieve in all aspects, not just c&d waste.  3. Regarding demo waste, at some point it needs to be understood that time and money are resources, and there is no owner that is going to pay a contractor to deconstruct every component being demolished. Yes, they are going to recycle concrete, masonry, steel, etc., but are not going to deconstruct other components that are super tedious and time consuming. Additionally, the ceiling tile and carpet manufacturers will not take these products back regardless of what they falsely advertise and if they are forced to, they charge an exorbitant amount of money that the client could spend elsewhere.
  LEED should perhaps view the quantity of dollars and time wasted to achieve certain nonpracrical requirements as equally as they do the quantity of materials. LEED needs to have some reality, practicality and common sense associated with it to encourage people to use it, or at a minimum implement the requirements regardless of certification, in the spirit of transforming the industry. It needs to be a practical approach to get everyone to want to implement a CWM Plan. That means that this should require a narrative that talks about how they achieved the waste minimized of the overall project in general as well as how and what waste was diverted, and not try to micromanage the material waste generated in demo or construction via the quantity of waste per sf.  Additionally as I have stated in every version of the comments, projects need to be identified as urban, suburban or rural, and be given alternates for achieving credit/prequisite requirements. For example, not every single location recycles drywall at "certified" facilities, but rather farmers take it, crush it and use it as lime for their farm fields, so we truck it across the state, creating carbon emissions, to a "certified" facility so they can crush it, and then sell it to the farmers, which they have to  truck the crushed drywall back across the state. Again, very unsustainable.