Landfill Cover-up

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Changes to LEED will affect how demolition contractors and C&D recyclers report alternative daily cover.

November 7, 2013
Curt Harler

After November, C&D recyclers are expected to have a new, and rather different, set of guidelines for the use of alternative daily cover (ADC) for construction or demolition projects using the Leadership in Energy and Environmental Design (LEED) Scorecard to earn certification.

ADC usage is a relatively common practice with landfills, and the material from construction or demolition projects is actually generated from the recycling process. Most facilities screen ADC from the mixed loads that enter the facility. This is quite different than just grinding up all C&D materials and creating high levels of ADC.

That, however, presents a question. Should ADC be considered toward LEED recycling rates? Just because it has “always been done that way” does not mean it is right. The topic is very controversial. And, some in the industry fear the open interpretation of figures, which could taint an otherwise good idea.

The U.S. Green Building Council (USGBC), with those concerns in mind, spent more than a year updating LEED standards, including those for ADC. The new rules, known as LEED v4, will affect every recycler who processes material for a LEED project.

Under LEED v4, “Alternative Daily Cover no longer contributes toward diverted waste,” says Jacob Kriss, media associate for USGBC, Washington, D.C.

LEED v4 is expected to launch in November at the Greenbuild conference, Nov. 20-22 in Philadelphia.

“LEED v4 will open for registration at Greenbuild 2013 in Philadelphia,” Kriss says. “Projects will have until June 1, 2015, to choose whether to register for LEED 2009 or LEED v4.”

This presents challenges to the property owner and to the C&D recycler. “Depending on the strategies that particular projects use to meet the thresholds of the C&D Waste Management credit (i.e., they have historically relied heavily on ADC), they may find it more difficult to meet the threshold to earn this credit,” Kriss acknowledges.

However, there is now a performance-based approach to earning the credits, where a project may earn two points for generating less than 2.5 pounds per square foot of waste.

“We expect this to have a positive impact on C&D Waste Credit achievement,” Kriss says. He adds that a project’s LEED goals should not be affected. “Projects are encouraged to pursue credits that meet a variety of environmental goals, into which waste reduction continues to play significantly.”

Jason Haus, chief executive officer of Dem-Con Cos., Shakopee, Minn., points out, “The screened materials that are used as ADC are generated from the project and, based on geography, truly do provide value to a site that has limited access to soils.”

In addition, there are some facilities that move their fines materials through a series of screens to produce multiple useable materials based on their local construction needs. “ADC must be managed appropriately at sites as well, as it does have some side effects at landfills by producing higher levels of hydrogen sulfide gases,” he says.

At one California plant that reports its figures to an auditing program, the recycling rate with ADC is about 97 percent on a material like roofing shingles. Without ADC, its rate falls to 30 percent. That is a huge difference.

Facilities across the country have noted increased levels when they started using ADC, but with appropriate controls, this can be mitigated. The fines materials are a function of the job site, and if purely source separation occurs, most of the remaining soils, fines, small glass fractions and other de minimis materials would have remained on the job site.

Is ADC even valuable?
“I do not think ADC is the ‘highest and best use’ of material,” says Michael Deane, vice president and chief sustainability officer for the giant Turner Construction Co., New York City. He notes one can crush and grind a lot of things and call it ADC. “But what is it really?” he asks.

Turner has followed previous versions of LEED when ADC has been acceptable. The advent of LEED v4 means Turner and others may have to find other uses for this material or increase recycling of other materials to remain in compliance.

‘Fine’ for Now

Many state and local governments allow fines from construction and demolition (C&D) recycling facilities to be used as alternative daily cover (ADC) at landfills. But the newest version of the Leadership in Energy and Environmental Design (LEED) certification program, LEED v4, does not allow ADC to be counted toward a project’s recycling rate. Whether individual states will reconsider their policies on ADC as a result remains to be seen.

Currently, use of C&D fines as ADC have been allowed in states such as California, where, according to California Department of Resources Recycling and Recovery (CalRecycle), the following materials are acceptable for use and can be reported for diversion:

  • Ash and cement kiln dust;
  • Treated auto shredder waste;
  • C&D waste;
  • Compost;
  • Green material;
  • Contaminated sediment;
  • Sludge; and
  • Shredded tires.

ADC does provide some value in its beneficial use applications. Still, Haus has his doubts. “I am not sure if ADC is the most environmentally responsible solution either,” Haus says. “To call it recycling is a challenge for me, but the USGBC should at a minimum recognize the material—if it is a screened material from the projects—as having some beneficial use value and not just disregard the material.”

Haus surmises, “It is my opinion that the USGBC is truly pushing on-site source separation and deconstruction versus the use of mixed facilities, which is unfortunate.” Haus points out that mixed C&D facilities provide value and push the envelope on finding new uses for materials such as gypsum drywall, shingles and glass. This look into innovation is not done when the low-hanging fruit—such as concrete, wood and metals—are source separated at the job site, he contends.

Some C&D operations, such as Broad Run Recycling, Manassas, Va., exclude the ADC from its diversion calculations. While the company does produce ADC, Kevin Herb, Broad Run Recycling managing partner, does not count it toward diversion. “We can count it today, but ADC is not in the new numbers,” he states.

“The latest documents for the LEED v4 show that ADC is removed from the calculation and that can be argued right or wrong,” Haus continues. “But the bottom line is if that material is removed from the calculation, which many would not argue —me being one of them—the thresholds for awarding points should be adjusted.”

Haus argues that removal of ADC eliminates 20 to 30 percent of the material that was formally counted, yet the thresholds for points did not change. “In most cases, with the removal of ADC, in a mixed C&D facility environment, it is mathematically impossible to achieve a 75 percent recycling rate,” Haus says. “I don’t think that is the intent of the USBGC, but it is an unintended consequence.”

Herb agrees that ADC is not sustainable because he is susceptible to an agency being able to tell him what counts and what does not for compliance. Whether it is an organization or a government group, he says, he doesn’t want to build a business model on something that he has no control over or that is subject to change.

“Anyway, medium-grade topsoil is a far better use, in my opinion, than landfill cover,” Herb says.

In LEED v4, if a project’s waste is commingled, then the project must provide verification of the diversion rate. If it is not commingled (being source separated on site) then the project need not provide the additional documentation, only the totals of those separated materials.

Some are concerned that, at least in the short term, the numbers will be fudged, either intentionally or accidentally.

“There is always a risk of false reporting across this credit and a variety of others across the rating system,” Kriss says. “LEED is a leadership standard that encourages innovative best practices, and we expect the market to help police and point out issues such as those.

“Recyclers would be taking a significant risk by falsifying documents if it put a project’s certification in jeopardy; projects, therefore, have the incentive to support facilities that are truly operating under best practices,” Kriss adds.


The author is a freelance writer living in the Cleveland area. He can be contacted at