CMRA Illinois Comments on LEED Changes

Editor’s Note: The CMRA chapter in Illinois also submitted comments on the proposed changes to the latest version of LEED from the U.S. Green Building Council. They are reprinted below.

Comments to Green Building Guidelines to the U.S. Green Building Council—The Construction Materials Recycling Association of Illinois (CMRA-Illinois) is greatly concerned for the negative impact the proposed revisions would have on building and construction projects, and on the construction materials recovery businesses. The proposed changes are not in the best interests of establishing new or expanding current recovery and recycling activities.

The changes in calculating green building credits will have a significant impact on many of our clients who are now relying upon construction and demolition recyclers to help them attain a LEED Certification. Current LEED credit under Construction Waste Management Category, Potential Technologies and Strategies allows: “Construction debris processed into a recycled content commodity that has an open market value (e.g., wood derived fuel, alternative daily cover materials, etc.) may be applied to the construction waste calculation.”

One of the key revisions proposed in the new version of the guidelines would eliminate the use of the processed construction debris known as alternate daily cover (ADC) from consideration as materials diverted from disposal.

Building demolition and materials recovery processes yield a certain amount of a materials mix that are small in size and have few end markets. This processed material (fines) has intrinsic value that warrants its application in lieu of gravel, stone or soil as a landfill ADC, or as a road base material at landfills. Using fines in lieu of otherwise required materials conserves virgin materials that may be required for other purposes and the energy to extract and transport gravel, stone or soil is avoided.    

Under current LEED guidelines, if a construction project can divert or re-use 50% of its discards, the project earns 1 point. If a construction project can divert or re-use 75% of its discards, the project earns 2 points. If a portion of these discards is used as ADC, it is currently counted toward the point evaluation. If the ADC is removed from the guidelines, no portion of the processed mix will be accounted in the LEED certification process. A typical construction site yields 25%-35% of the materials collected for recovery or disposal as fines, which can be used as ADC. A typical construction site can yield as much as 25% non-recyclable materials, which is disposed at landfills as waste. If the material used as ADC cannot be counted in a LEED assessment, many projects will be unable to attain the desired LEED Certification.

State of Illinois permit requires C&D recyclers to recover 75% of materials received. Construction fines sent to landfills specifically for use as ADC or road construction base are recovered materials and are not disposed as waste. Construction fines used in landfill operations are meeting the goal of finding an alternative use for an otherwise discarded material and conserving resources and energy. As a part of sustainable and energy efficient building practices, this recovery of fines should continue to be considered as part of the credit for conservation of resources and energy.

De-constructing, sorting and re-manufacturing construction materials from existing buildings resulted in an extensive network of industries. These industries use their own unique recovery technologies to re-use or re-direct materials that can yield products marketed as equal to or superior to a product made from new or virgin materials.

Demolition and recovery of existing building materials to meet sustainability goals and ensure energy efficiencies requires its own unique approach which is different from those used in constructing a new building. An array of materials, depending upon the building’s age, potential upgrades or remodeling can yield a mix that must be identified and sorted to determine its markets or re-uses. Materials removed from construction sites are collected in single roll-off containers and transported to facilities for sorting and shipping on to markets for re-use or re-manufacture. The proposed guidelines would affect collection at construction sites to maximize the recoverable value of construction materials to meet LEED certification goals.  

The most effective means to reduce or eliminate contamination of marketable discards and reduce the impact of additional processing at recovery facilities would require roll-off boxes designated for specific materials at each construction site.

Urban areas and smaller construction sites would be affected, having limited available space for additional roll-offs. The amount of material that could be recovered, increased cost to provide roll-offs, and additional transportation and labor costs associated with disposing in multiple containers would reduce the attainment of green building practices.

CMRA Illinois supports the following:

• Guidelines for going into the future need to appreciate the challenges of recovering building materials and construction practices from the past. Demolition and recovery activities are related to construction of new, more efficient buildings. The downstream impacts of demolition and re-direction of materials to various uses should not be dismissed as unconnected or irrelevant.
• Recognize the challenges in recovering materials from buildings that span decades of building and trades development and construction practices. Demolition and building materials recovery play a vital role in the quest to conserve resources and construct efficient buildings. The materials recovery presents greater challenges but have value and can have even greater re-use potential.  
• Continue to encourage the integrated process of building performance. Emphasize new construction and rehabilitation to highest levels of green building, but do not discredit the value of the materials recovered that can be put to alternative use. Support efforts to sort, transform and develop markets for all building materials and construction by-products.
• Do not eliminate the LEED credit for fines destined for use as ADC. Some end uses are not traditional, yet, replace use of virgin materials, conserve energy and resources and meet expected performance requirements. The use of processed construction and demolition materials is a key element to avoid waste and consumption of mined or manufactured materials otherwise required in landfill operations.

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