Regional Materials Credit

Recommended Changes to Credit Language

Intent

To support local communities by increasing demand for building materials and products that are extracted and manufactured within the region.

Requirements

NC, CS, SCHOOLS, RETAIL, DATA CENTERS, WAREHOUSE & DISTRIBUTION CENTERS, HOSPITALITY ,

Use non-structural building materials and products that were both manufactured and extracted, harvested or recovered within 500 miles of the project site for a minimum of 10% or 20%, based on cost, of the total materials value. If only a fraction of a product or material was regionally manufactured or extracted, harvested, or recovered, count only that percentage (by weight).

Exception to Credit:  For building materials or products shipped in part by rail or water, the total distance to the project shall be determined by weighted average, whereby that portion of the distance shipped by rail or water shall be multiplied by 0.25 and added to that portion not shipped by rail or water, provided that the total does not exceed 500 mi (800 km).

Points are awarded according to Table 1.

Commentary

These comments represent the consensus of The Structural Engineering Institute (SEI) Sustainability Committee.  This committee, the only national structural engineering committee focused on sustainability, is comprised of over 40 informed members who represent a diverse cross section of the structural engineering community.  More information about the committee can be found at www.seisustainability.org.

A serious problem with the proposed exclusion of structural materials from three MR credits is that there is no definition for a “structural” material.  One of the hallmarks of sustainability is doing more with less, and frequently LEED buildings incorporate exposed structure to help reduce consumption of finish materials.  If a timber roof truss, concrete floor, or steel column is left exposed, is that a “structural” material or a “finish” material?  Furthermore the proposed language creates an unintended incentive for teams to use more finish materials to achieve credits.  If they cannot get the credits using structural materials, they will need to get them using materials which may not be essential to the functioning of the building. Thus a project that might otherwise use exposed concrete floors and exposed roof structure will instead add recycled content carpeting and regionally available dropped ceilings just to get the materials credits. In the end, the project could have a better LEED score, but also a larger environmental impact, damaging LEED’s credibility.

Structural material optimization and selection plays a vital role in the sustainability path of any new structure.  Excluding structural materials from the regional material credit should not be incorporated into a standard when structural materials represent the major and often only permanent portion of a building.  While we understand the intent is to encourage local purchasing of non-structural materials, this new credit should not exclude structural materials from the credit.  We propose that this credit be reformatted to similar adopted language of ASHRAE 189.1 and language that has been proposed to the IgCC on this same issue. 

We advocate that this credit, revised as we have written above, is a great improvement from the proposed language and that of past versions of LEED in which true confusion and problems arose in interpretation of the regional material requirement and the (manufactured or extracted, harvested, or recovered) terms. 

Different materials can be manufactured more efficiently in different locations in the US based on locally available sources or already in-place systems.  However, while the stated intent of the credit is to support local economies, the credit also intends to reduce the environmental impacts of transporting materials.  While some materials may be produced sustainably in excess of the stated 500-mile radius, it is the type of transportation utilized to deliver the materials that determines the environmental impact.  Therefore, the best improvement that can be made, based off the proposed language and intent of this credit, is to take into account the various methods of transporting materials (truck/ship/rail) and apply different factors to the project materials, based on those factors.  Again, this is similar to the consensus-based approach that was concluded upon for the language of ASHRAE 189.1 and similar language in the IgCC respective section.

General SEI Sustainability Committee Comments on Proposed Changes to LEED MR Credits

By weight or volume, structural materials account for a large percentage of the materials used in a building. Although it is true that the majority of energy-related impacts associated with a building occur during the use phase, it does not make the embodied environmental impacts in the building materials insignificant. In fact, as we continue to make buildings more energy efficient, the embodied environmental impacts in building materials will become a greater percentage of the building’s life-cycle impacts. Any reduction in embodied impacts is real and immediate, and not dependent on operations or a model. When considering climate impacts, these initial embodied impacts carry even greater weight, since to avoid catastrophic global temperature increases we need to massively reduce carbon emissions in the near-term, which for buildings means the construction phase.

While the LCA into LEED initiative is an excellent step forward, the exclusion of structural materials from this credit is a step backwards. LEED should keep moving towards a flexible LCA approach that includes all building materials and permits structural engineers to creatively design for environmental impact reductions through approaches such as selection of low-impact materials, materially efficient design, and design for adaptability and deconstruction. But until these tools are available and required by LEED, project teams will be using the standard LEED MR credits to evaluate their projects. To maintain credibility during this transition, structural materials must not be excluded from the base credits.

Minimum Recycled Content Prerequisite

Recommended Changes to Prerequisite Language

Intent

To avoid the environmental consequences of extracting and processing virgin materials and increase demand for buildings products that incorporate recycled content, thereby reducing impacts resulting from extraction and processing of virgin materials.

Requirements

NC, CS, SCHOOLS, RETAIL, DATA CENTERS, WAREHOUSE & DISTRIBUTION CENTERS, HOSPITALITY

Use building products that contain the minimum percentages of recycled material as a percentage of total building costs as specified below.

The recycled content value of a material assembly is determined by weight. The recycled fraction of the assembly is then multiplied by the cost of the assembly to determine the recycled content value. Include only materials permanently installed in the project. Furniture may be included if it is included consistently in Materials and Resources credits. Exclude mechanical, electrical, and plumbing components and specialty items, such as elevators.

NC, SCHOOLS, RETAIL, DATA CENTERS, WAREHOUSE & DISTRIBUTION CENTERS, HOSPITALITY

Use materials with recycled content such that the sum of the postconsumer recycled content plus the preconsumer (post-industrial) recycled content constitutes at least 10% of the total materials cost.

CS

Use materials with recycled content such that the sum of the postconsumer recycled content plus the preconsumer (postindustrial) recycled content constitutes at least 5% of the total materials cost.

Commentary

These comments represent the consensus of The Structural Engineering Institute (SEI) Sustainability Committee.  This committee, the only national structural engineering committee focused on sustainability, is comprised of over 40 informed members who represent a diverse cross section of the structural engineering community.  More information about the committee can be found at www.seisustainability.org.

The ASCE Structural Engineering Institute (SEI) Committee on Sustainability has the following public comments on both the MR Prerequisite and Credit for Recycled Content:

1)    There should be no distinction between “structural” and “non-structural materials,” and no attempt made to separate them from each other in recycled content calculations for many reasons, such as:

a)     Materials with higher recycled content often have fewer environmental impacts than materials without recycled content, no matter whether they are structural or non-structural. The environmental impact of structural materials can be greatly reduced by increasing recycled content materials. For example, fly ash can be used in place of portland cement in concrete and CMU, dramatically lowering carbon impacts. Great potential also exists for the development of recycled content structural wood products. Designers need incentive to use existing recycled-content structural materials and manufacturers need incentive to develop new recycled-content structural materials. Removing structural materials from the recycled content credit will reduce these incentives.

b)    Structural materials often represent the majority of the cost of construction materials so leaving them out of the computation seems to ignore a large percentage of the actual triple bottom line.

c)     Distinguishing between structural and non-structural materials will be extremely difficult because these terms are colloquially used in structural engineering, architecture, and civil engineering in several different ways that overlap and may conflict.

2)    The intent of the credit should match the prerequisite, allowing the credit to build upon the prerequisite. Therefore, wording and definitions should be identical across the two sections, such as:

a)     Maintaining or deleting the distinction between pre-consumer and post-consumer recycled content.

b)    The incorporation of CS (core and shell), similar to the other construction types and LEED rating systems.

3)    If the concern is that it has been too easy for projects to attain the existing recycled content credit using structural materials, then we suggest that raising the threshold percentage will be a much better incentive for sustainability rather than attempting to specifically define and exclude the structural materials.

a)     In addition to the same intent, the prerequisite and credit should have complementary thresholds and both would need to be adjusted accordingly.  For example, we suggest raising the credit threshold 5% to 10% beyond the prerequisite. 

General SEI Sustainability Committee Comments on Proposed Changes to LEED MR Credits

By weight or volume, structural materials account for a large percentage of the materials used in a building. Although it is true that the majority of energy-related impacts associated with a building occur during the use phase, it does not make the embodied environmental impacts in the building materials insignificant. In fact, as we continue to make buildings more energy efficient, the embodied environmental impacts in building materials will become a greater percentage of the building’s life-cycle impacts. Any reduction in embodied impacts is real and immediate, and not dependent on operations or a model. When considering climate impacts, these initial embodied impacts carry even greater weight, since to avoid catastrophic global temperature increases we need to massively reduce carbon emissions in the near-term, which for buildings means the construction phase.

Another serious problem with the proposed exclusion of structural materials from these three credits is that there is not a definition for a “structural” material.  One of the hallmarks of sustainability is doing more with less, and frequently LEED buildings incorporate exposed structure to help reduce consumption of finish materials.  If a timber roof truss, concrete floor, or steel column is left exposed is that a “structural” material or a “finish” material?  Furthermore the proposed language creates an unintended incentive for teams to use more finish materials to achieve credits.  If they cannot get the credits using structural materials, they will need to get them using materials which may not be essential to the functioning of the building. Thus a project that might otherwise use exposed concrete floors and exposed roof structure will instead add recycled content carpeting and regionally available dropped ceilings just to get the materials credits. In the end, the project could have a better LEED score, but also a larger environmental impact, damaging LEED’s credibility.

While the LCA into LEED initiative is an excellent step forward, the exclusion of structural materials from this credit is a step backwards. LEED should keep moving towards a flexible LCA approach that includes all building materials and permits structural engineers to creatively design for environmental impact reductions through approaches such as selection of low-impact materials, materially efficient design, and design for adaptability and deconstruction. But until these tools are available and required by LEED, project teams will be using the standard LEED MR credits to evaluate their projects. To maintain credibility during this transition, structural materials must not be excluded from the base credits.

Recycled Content Credit

Recommended Changes to Credit Language

Intent

To avoid the environmental consequences of extracting and processing virgin materials and increase demand for building products that incorporate recycled content, thereby reducing impacts resulting from extraction and processing of virgin materials.

Requirements

NC, CS, SCHOOLS, RETAIL, DATA CENTERS, WAREHOUSE & DISTRIBUTION CENTERS, HOSPITALITY

Use building products that contain recycled material as a percentage of total non-structural building costs as specified below.

The recycled content value of a material assembly is determined by weight. The recycled fraction of the assembly is then multiplied by the cost of assembly to determine the recycled content value.

Include only materials permanently installed in the project. Furniture may be included if it is included consistently in relevant Materials and Resources credits Exclude mechanical, electrical, and plumbing components and specialty items, such as elevators

OPTION 1. Nonstructural Materials

Use non-structural materials with recycled content such that the sum of postconsumer recycled content plus one-half of the preconsumer (post-industrial) recycled content based on cost, of the total value of the non-structural materials in the project as shown in Table 1. Points are awarded according to Table 1.

Table 1. Points for percentage of recycled content

OR

OPTION 2. Closed Loop manufacturing

Meet the requirements of Option 1 and demonstrate that at least 5% of the materials qualifying for MR Credit: Recycled Content for Non-Structural Materials are purchased from a manufacturer that has a closed-loop product recycling and take-back program.

CS

OPTION 1. Nonstructural Materials

Use non-structural materials with recycled content19 such that the sum of the postconsumer20 recycled content plus 1/2 of the preconsumer21 (post-industrial) recycled content constitutes at least 5% or 10%, based on cost, of the total value of the non-structural materials. Points are awarded according to Table 2.

Table 2. Points for percentage of recycled content, non-structural

OR

OPTION 2. Closed Loop Manufacturing

Meet the requirements of Option 1 and demonstrate that at least 5% of the materials qualifying for MR Credit: Recycled Content for Non-Structural Materials are purchased from a manufacturer that has a closed loop product recycling and take-back program.

Commentary

These comments represent the consensus of The Structural Engineering Institute (SEI) Sustainability Committee.  This committee, the only national structural engineering committee focused on sustainability, is comprised of over 40 informed members who represent a diverse cross section of the structural engineering community.  More information about the committee can be found at www.seisustainability.org.

The ASCE Structural Engineering Institute (SEI) Committee on Sustainability has the following public comments on both the MR Prerequisite and Credit for Recycled Content:

A serious problem with the proposed exclusion of structural materials from three MR credits is that there is no definition for a “structural” material.  One of the hallmarks of sustainability is doing more with less, and frequently LEED buildings incorporate exposed structure to help reduce consumption of finish materials.  If a timber roof truss, concrete floor, or steel column is left exposed, is that a “structural” material or a “finish” material?  Furthermore the proposed language creates an unintended incentive for teams to use more finish materials to achieve credits.  If they cannot get the credits using structural materials, they will need to get them using materials which may not be essential to the functioning of the building. Thus a project that might otherwise use exposed concrete floors and exposed roof structure will instead add recycled content carpeting and regionally available dropped ceilings just to get the materials credits. In the end, the project could have a better LEED score, but also a larger environmental impact, damaging LEED’s credibility.

1)    There should be no distinction between “structural” and “non-structural materials,” and no attempt made to separate them from each other in recycled content calculations for many reasons, such as:

a)     Materials with higher recycled content often have fewer environmental impacts than materials without recycled content, no matter whether they are structural or non-structural. The environmental impact of structural materials can be greatly reduced by increasing recycled content materials. For example, fly ash can be used in place of portland cement in concrete and CMU, dramatically lowering carbon impacts. Great potential also exists for the development of recycled content structural wood products. Designers need incentive to use existing recycled-content structural materials and manufacturers need incentive to develop new recycled-content structural materials. Removing structural materials from the recycled content credit will reduce these incentives.

b)    Structural materials often represent the majority of the cost of construction materials so leaving them out of the computation seems to ignore a large percentage of the actual triple bottom line.

c)     Distinguishing between structural and non-structural materials will be extremely difficult because these terms are colloquially used in structural engineering, architecture, and civil engineering in several different ways that overlap and may conflict.

2)    The intent of the credit should match the prerequisite, allowing the credit to build upon the prerequisite. Therefore, wording and definitions should be identical across the two sections, such as:

a)     Maintaining or deleting the distinction between pre-consumer and post-consumer recycled content.

b)    The incorporation of CS (core and shell), similar to the other construction types and LEED rating systems.

3)    If the concern is that it has been too easy for projects to attain the existing recycled content credit using structural materials, then we suggest that raising the threshold percentage will be a much better incentive for sustainability rather than attempting to specifically define and exclude the structural materials.

a)     In addition to the same intent, the prerequisite and credit should have complementary thresholds and both would need to be adjusted accordingly.  For example, we suggest raising the credit threshold 5% to 10% beyond the prerequisite. 

General SEI Sustainability Committee Comments on Proposed Changes to LEED MR Credits

By weight or volume, structural materials account for a large percentage of the materials used in a building. Although it is true that the majority of energy-related impacts associated with a building occur during the use phase, it does not make the embodied environmental impacts in the building materials insignificant. In fact, as we continue to make buildings more energy efficient, the embodied environmental impacts in building materials will become a greater percentage of the building’s life-cycle impacts. Any reduction in embodied impacts is real and immediate, and not dependent on operations or a model. When considering climate impacts, these initial embodied impacts carry even greater weight, since to avoid catastrophic global temperature increases we need to massively reduce carbon emissions in the near-term, which for buildings means the construction phase.

While the LCA into LEED initiative is an excellent step forward, the exclusion of structural materials from this credit is a step backwards. LEED should keep moving towards a flexible LCA approach that includes all building materials and permits structural engineers to creatively design for environmental impact reductions through approaches such as selection of low-impact materials, materially efficient design, and design for adaptability and deconstruction. But until these tools are available and required by LEED, project teams will be using the standard LEED MR credits to evaluate their projects. To maintain credibility during this transition, structural materials must not be excluded from the base credits.

Bio-Based Materials Credit

Recommended Changes to Credit Language

Intent

To reduce the use and depletion of non-renewable materials by substituting bio-based materials.

Requirements

NC, CS, SCHOOLS, RETAIL, DATA CENTERS, WAREHOUSE & DISTRIBUTION CENTERS, HOSPITALITY

OPTION 1.

Use non-structural bio-based materials and products for 10% of the total value of all materials and products used in the project.

Bio-based materials are defined by the Farm Security and Rural Investment Act of 2002 (FSRIA), Section 9001. Acceptable animal-based products are those whose harvesting does not kill, abuse, or cause harm to the animals. Materials must also be harvested in a legal manner.

The bio-based content of a material assembly is determined by weight. Multiply the bio-based fraction of the assembly by the cost of assembly to calculate the bio-based content value.

Wood products purchased for temporary use on the project (e.g. formwork, bracing, scaffolding, sidewalk protection, and guardrails) may be included in the calculation at the project team’s discretion. If any such materials are included, all such materials must be included in the calculation.

OR

OPTION 2.

Meet the requirement of Option 1.

All materials included in Option 1 must have third-party certifications, as defined by the LEED Standard for Standards.

Commentary

These comments represent the consensus of The Structural Engineering Institute (SEI) Sustainability Committee.  This committee, the only national structural engineering committee focused on sustainability, is comprised of over 40 informed members who represent a diverse cross section of the structural engineering community.  More information about the committee can be found at www.seisustainability.org.

A serious problem with the proposed exclusion of structural materials from three MR credits is that there is no definition for a “structural” material.  One of the hallmarks of sustainability is doing more with less, and frequently LEED buildings incorporate exposed structure to help reduce consumption of finish materials.  If a timber roof truss, concrete floor, or steel column is left exposed, is that a “structural” material or a “finish” material?  Furthermore the proposed language creates an unintended incentive for teams to use more finish materials to achieve credits.  If they cannot get the credits using structural materials, they will need to get them using materials which may not be essential to the functioning of the building. Thus a project that might otherwise use exposed concrete floors and exposed roof structure will instead add recycled content carpeting and regionally available dropped ceilings just to get the materials credits. In the end, the project could have a better LEED score, but also a larger environmental impact, damaging LEED’s credibility.

The stated intent of the proposed credit is to reduce the use and depletion of non-renewable materials by substituting bio-based materials and the requirements indicate that it applies to non-structural materials only. However, one of the most effective means of achieving this intent is to use a wood-framed structural system, since the wood framing can be used in place of non-renewable materials such as steel, concrete, and masonry. We can see no rational basis for excluding structural framing from this credit.

LEED should be encouraging designers to select wood framing for smaller buildings due to the many environmental benefits of wood relative to alternative materials, including lower carbon footprint, renewability, biodegradability, and potential for reuse. Furthermore, for North American projects, most of the wood used to frame buildings is sourced from the United States and Canada, whereas wood used for non-structural applications is often sourced from overseas and from tropical regions where harvesting practices and worker conditions are often less favorable than in North America. Many LEED “commercial” projects are of a scale that would permit the use of a wood framing system. If structural materials are included, this credit may be extended to CS projects.

The suggested exclusion of structural materials would also introduce the complication of distinguishing between structural and non-structural wood framing. Is a non-load-bearing wood stud wall “non-structural,” while the wood stud bearing wall next to it is “structural”? Such distinctions are artificial and confusing, and the natural environment that we are all striving to protect and enhance cannot tell the difference anyway.

We feel that LEED’s credibility would be threatened if it rewarded the use of non-structural bio-based materials only. If necessary, the threshold for credit achievement could be raised beyond 10% to account for the greater potential for wood use if structural materials contribute to achievement.

General SEI Sustainability Committee Comments on Proposed Changes to LEED MR Credits

By weight or volume, structural materials account for a large percentage of the materials used in a building. Although it is true that the majority of energy-related impacts associated with a building occur during the use phase, it does not make the embodied environmental impacts in the building materials insignificant. In fact, as we continue to make buildings more energy efficient, the embodied environmental impacts in building materials will become a greater percentage of the building’s life-cycle impacts. Any reduction in embodied impacts is real and immediate, and not dependent on operations or a model. When considering climate impacts, these initial embodied impacts carry even greater weight, since to avoid catastrophic global temperature increases we need to massively reduce carbon emissions in the near-term, which for buildings means the construction phase.

While the LCA into LEED initiative is an excellent step forward, the exclusion of structural materials from this credit is a step backwards. LEED should keep moving towards a flexible LCA approach that includes all building materials and permits structural engineers to creatively design for environmental impact reductions through approaches such as selection of low-impact materials, materially efficient design, and design for adaptability and deconstruction. But until these tools are available and required by LEED, project teams will be using the standard LEED MR credits to evaluate their projects. To maintain credibility during this transition, structural materials must not be excluded from the base credits.