CDRA Submits Comments on LEEDv5 Recycling Credits

For nearly 15 years, CDRA has been working with the U.S. Green Building Council (USGBC) on improving the LEED credits related to construction waste management, recycling, and reuse. Our goals have been to ensure that credits stayed grounded in reality, help push the construction material recycling market forward, and ensure they effectively promote sustainable practices.

After a long delay, the USGBC recently unveiled LEEDv5, the fifth complete version of the extensive rating program for green building. Unfortunately, this version left almost intact the issues previous versions of LEED had, including the ease with which false recycling rates could be claimed and undeserved points awarded for recycling and reusing little or nothing.

Fortunately, USGBC allowed comments on this iteration of LEED before implementation. CDRA formed a small member group that worked diligently over a two-week period to reach consensus on this important program, and comments were submitted May 24th, which was the deadline for doing so. Following is a summary of the submission.

Identified Challenges with LEED Recycling Credits

CDRA identified several significant issues with the current LEED recycling credits that need addressing to ensure the credibility and effectiveness of sustainable practices in the industry:

1. Lack of Quantitative Measures: There is no clear definition of what constitutes a “material stream.” Apart from ceiling tiles and gypsum board, source separation does not offer clear benefits, allowing firms to claim source separation without substantial evidence.
2. Verification Mechanisms: The absence of robust verification methods enables manipulation and abuse of recycling rates and source separation practices, undermining the integrity of LEED recycling credits.
3. Global Applicability vs. Regional Realities: While LEED is an international system, CDRA proposes a North America-only carve-out to maintain the integrity of the LEED standard, as recycling infrastructure varies significantly across regions.

Data Manipulation and Integrity Issues

CDRA highlighted the pervasive issue of data manipulation in the C&D recycling industry. Without stringent verification, contractors can inflate recycling rates, compromising the environmental goals of the LEED program. Reports from CDRA members indicate instances where contractors misreport the amount of material recycled or use dubious recycling facilities, thus distorting the true environmental impact of projects.

Before providing USGBC with proposed credit language, the CDRA's comments closed with its "proposed approach aims to strengthen LEED recycling credits by emphasizing rigorous verification, clear definitions, and equitable access to certified recycling facilities, while incentivizing those facilities who are not certified to become so. It also provides motivation for recycling facilities to train or hire employees with LEED accreditation. These measures are essential for upholding LEED credibility and advancing sustainable construction practices. By implementing these changes, the LEED program can ensure that construction projects are genuinely contributing to environmental sustainability, rather than merely appearing to do so."

Proposed Solutions and Improvements

To address these challenges, CDRA recommended revisions to the draft LEED v5 Materials & Resources Credits:

1. Reinstate Construction, Deconstruction, and Demolition Waste Minimization Planning Prerequisite:
1. Recycling Facility Visit: Require project teams to visit recycling facilities prior to awarding contracts.
2. Minimized Waste Plan: Develop a comprehensive Construction, Deconstruction, and Demolition Waste Minimization Plan (CDD WMP) based on project design and site logistics.
3. Design Phase Submission: Include documentation of recycling facility visits and the CDD WMP in the design phase submission, with quarterly check-ins to ensure adherence.
2. Enhance Diversion Rates and Source Separation Requirements:
1. Separate Diversion Rates: Establish minimum diversion rates for demolition (50% for 1 point, 75% for 2 points) and construction (35% for 1 point, 50% for 2 points).
2. Source Separation: Define source separation more precisely and ensure it constitutes a significant portion of total debris.
3. Third-Party Verified Recycling Facility Advocacy:
1. Regional/Local Priority Credit: Add credits to encourage third-party verification of recycling facilities, especially in regions with few certified facilities.

Proposed Revisions to Table 1

• 1 Point for C&D Diversion:
• Divert 35% of all construction waste materials; or 50% of all deconstruction and demolition waste materials; and
• Source-separate and recycle three materials; or
• Use an ISO 14000 standard-level third-party verified commingled recycling facility.
• 2 Points for C&D Diversion:
• Divert 50% of all construction waste materials; or 75% of all deconstruction and demolition waste materials; and
• Source-separate and recycle targeted materials, such as gypsum board for new construction, and carpet, ceilings, gypsum board, and furniture for deconstruction and demolition; or
• Use an ISO 14000 standard level third-party verified commingled recycling facility.

Thank you to the passionate members from across the country who represented both recyclers and contractors, who spent countless hours to ensure we got this right!