Comment on the New LEED Rating System Draft to be Released in 2012

My question is when will we be required to use the new 2012 version of the rating systems? And is there a grace period during which we can continue to use 2009 versions or choose to upgrade to a 2012 version?

Here is the reason for this question: we do a lot of campus guidance credit work with local campuses. We are required to submit both the campus credits and the individual project reviews under the same version of the rating system. Thus, we are trying to figure out how to help campuses plan ahead for submission of campus credits and individual facilities. An easy way to do this would be to register all of their proposed projects now. Then they could use the same previously approved campus credit submittal for all of these projects. This would create the greatest efficiency in time and money. Alternatively, if the individual project would rate better under LEED 2012, then we could choose to upgrade just that project to not use campus guidance and/or begin working on the 2012 campus guidance upgraded submittal.

The only slight answer to this question that I have found is from the "LEED Rating System Development FAQ" document:

Q: "I have projects using a current or older version of LEED. Will these projects be required to follow this proposed updates?"

A: "Projects currently registered with LEED should follow the version under which they are currently registered. Project teams will not be required or able to register for the updated rating system until it has undergone a ballot vote by USGBC membership. Prior to ballot, the proposed rating system will go through at least two public comment and response periods. Projects that have not yet certified at the time of launch will still be able to certify under the rating system which they are registered."

I literally get dozens of calls a week from people either looking to take one of the LEED exams or trying to understand the credential maintenance process. There are two components:

1. I completely agree with the need for a continuous raising of the bar. How can we expect teams to design better buildings if they're not learning about the newest technologies, processes, etc? It's like expecting increasingly efficient businesses without online project management tools, time sheets and workplans. It's simply absurd.

2. I completely agree that USGBC and GBCI could have done more to prepare people for the transition. It was really a matter of time before this credit came to pass (or at least be considered). Not only did they do a poor job communicating the requirements, but they did a great job making the life of LEED AP's a nightmare. Why not give numbers and enable providers to submit credits? Why no maintain the one-time-a-year CEU deadline? AIA and other organizations do this, and it makes life easier for people. At some point in the near future, LEED will not be as dominant as it currently is, and USGBC could have used this as an opportunity to address this criticism. It was a serious missed opportunity for them.

SS Credit: Heat Island Reduction
Please change
"Use open-grid pavement system (at least 50% pervious)"
to read:
"Use open-grid pavement system (at least 30% pervious)"
There are very few concrete grid paving units with 50% open surface area or 50% pervious materials at the surface that meet ASTM C1319, the product standard for concrete grids. Most concrete grids are 30-40% open surface area as the remainder needs to be concrete for structural support of vehiccles.
As written, the 50% percentage excludes all concrete grid systems and I don't think that was the intention of the writers. 30% minimum pervious materials at the surface allows for sufficient grass to grow and provide cooling as intented by this credit.
Concrete grid systems can be completely covered with topsoil (not just openings) and sodded or planted with grass seed such that the entire surface is grass. That is not typically done, but it is a design option that can help further achieve this credit.

SS Credit: Rainfall Management
Please clarify "Manage onsite the runoff from...." I understand the 95th percentile event. However, one could interpret "manage onsite" as a means (or excuse) to detain and slowly release the 95th percentile rain event with a large detention pond when a permeable pavement might be more cost-effective and consume less land. I don't think encouraging detention ponds is the intention of this credit. I am respectfuly requesting to please find words that encourage volume reduction on site which of course directly helps pollutant reduction. This suggests a greater emphasis on onsite infiltration whenever possible. Thank you.

Thanks for your response Tristan. I definitely will.
Kr.
Nicolas

I also agree with what Tom Lent has posted above.

Combining Credits – If the materials credits are combined then teams would pursue materials with the best attributes instead of what they need to get to a certain percentage and not investigate alternate materials further.

Keep Structural Elements – Materials credits should keep some portion of structural material that can count toward the overall percentage. You could consider limiting the amount of structural materials that can count toward the overall percentage rather than eliminating them altogether. For some projects in very remote or island type settings, structural materials may be the only way to achieve regional materials for example. I also agree with Linda Smithe’s comment that it may become very difficult to delineate what materials are structural vs. non-structural and increase the complexity of documentation.

Prerequisite – The idea of a prerequisite is good but if it remains just for recycled materials this may actually be difficult for some projects to achieve depending on their geographic location, what materials are readily available, and what the structure and interior consist of.

I agree with above as well.
I would like to add I do not suggest a prerequisite for recycled material.
From the on line webinar it was discussed that the Recycled Content points are always being achieved, the market has transformed itself which is good. So just raise the percentage to continue the market transformation.

The MRc 4, 5, 6, 7, points are very time consuming (expensive) for contractors to document and some teams think they are not worth the effort. By making it a prerequisite you force them to do the documentation for what was in the past very few points and again if it is understood almost every project gets this because of market transformation, why are you making the contractors document it?

Also changing the way you document certain materials structural vs non structural just adds to complexity and confusion. Keep it consistent. Where would you put structural door frames? Is the block wall a structural shear wall or load bearing wall or just a fire proof partition? I believe, drywallon the underside of trusses adds shear stability.

I agree with above as well.
I would like to add I do not suggest a prerequisite for recycled material.
From the on line webinar it was discussed that the Recycled Content points are always being achieved, the market has transformed itself which is good. So just raise the percentage to continue the market transformation.

The MRc 4, 5, 6, 7, points are very time consuming (expensive) for contractors to document and some teams think they are not worth the effort. By making it a prerequisite you force them to do the documentation for what was in the past very few points and again if it is understood almost every project gets this because of market transformation, why are you making the contractors document it?

Also changing the way you document certain materials structural vs non structural just adds to complexity and confusion. Keep it consistent. Where would you put structural door frames? Is the block wall a structural shear wall or load bearing wall or just a fire proof partition? I believe, drywallon the underside of trusses adds shear stability.

Just wanted to chime in here and second what Tom said here, especially combining the credits and keeping the structural in the MR credits. Maybe combining the credits is something that has to be pushed to the next set of revisions, but please find a fair way to keep some of the structural material in the MR credits.

I am writing this from Beijing, where I am one of two U.S. advisors to a government research team developing a low-emitting furniture standard and certification program. Therefore I unfortunately have little time to respond in detail just yet.

The technical issues raised in Josh's comments are complex, and include some valid concerns worthy of legitimate debate. However, these comments also reiterate and expand on the inflammatory and inaccurate claims available at www.greenguard.org/pledge that may unnecessarily instill fear and confusion.

These claims include:

“The proposed IEQc4 fails to make product emissions requirements more stringent.” And “…the proposed changes—if accepted—could result in the creation of unhealthy interiors in all LEED Certified buildings, including schools.” And “Rather than raising the bar on indoor air quality and requiring rigorous, comprehensive chemical emissions limits, the proposed IEQc4 encourages adherence to weak product emissions criteria and insufficient test methods. This is alarming, given that the intent of IEQc4 is to safeguard against poor indoor environmental quality. Moreover, the proposed revisions to IEQc4 all but ignore the serious concerns with indoor air quality that were raised in the April 2010 report, LEED Certification: Where Energy Efficiency Collides with Human Health." And now ”...manufacturers can simply pick the path that shows their product is low-emitting when in actuality it may not be."

These claims are categorically false.

The proposed IEQc4 credit significantly strengthens the USGBC requirements for indoor environmental quality. Notably, it adds VOC emissions requirements from the California Department of Public Health (CDPH) to paints, coatings, adhesives, and sealants where only VOC content was previously addressed. It expands the scope to address more VOC sources within a building (thermal and acoustic insulation, all individual furniture items, all layers of ceilings, floors, and walls, and built-in cabinetry). Previously ceilings were not addressed in all rating systems and emissions from insulation, individual furniture items, and built-in cabinetry were not addressed at all. It adds CDPH Chronic Reference Exposure Level (CREL) based requirements for furniture. If you are not aware, CDPH requirements include one of the toughest formaldehyde emissions criteria in the world.

Continued legitimate debate about the credit content is vital to this process. The good news here is that the proposed credit is stimulating this debate, even if some participants may be motivated in part by keeping their proprietary programs written into the credit language. I encourage others, especially members of the USGBC IEQ TAG and the USGBC IEQ working group who participated in the 1.5 year effort to draft the proposed credit, to participate in this discussion.

Josh has posted his comments on two forums; this one focused on all LEED 2012 proposed revisions, and the one focused on Pilot Credit 21 Low-Emitting Interiors. I will post my initial response on both, but I suggest we shift the detailed commentary to the Pilot Credit 21 page, as it focuses specifically on the credit under discussion.

I plan to post additional responses to the specific concerns as I can make time available while traveling. A detailed FAQ document that addresses many of these issues is available on the LEEDuser.com pilot credit 21 page, or at this link: http://www.leeduser.com/system/files/sites/default/files/EQc4-PC21_FAQ_3....

These issues are not simple nor easy. Good people are struggling with these all over the world, and there is certainly room for improvement in the proposed credit. I am confident that this debate will help us to make the LEED program even better.

Thanks Tristan - as soon as we have our suggested credit language I will post here.

Sorry - thought my title came through with my name. I am Technical Information & Public Affairs Manager with GREENGUARD Environmental Institute. Actually we are working on our full comments right now, but we have posted some initial comments that people can look at on our website.

Also, as currently written GREENGUARD Children & Schools would still qualify any product certified to it to comply with the credit - so our concern is not about whether GREENGUARD will be impacted or not.

We are very concerned with the impact that the credit could have on sustainably certified building . This credit will get used even less then it does now; it gives different criteria to different products (under the same credit) and it opens up the possibility that people could be exposed to more chemicals - which shouldn't happen in any circumstance, but especially not in a sustainably certified building.

Erik, thank you for reviewing my comments and posting a response. Our firm is proactive and will meet the requirements. That being said, roles and responsibilities are very important when trying to train and hire staff to meet the requirments. The more information the better. Tristan, how/when should I expect to hear the committies response to my questions? Thanks.

Doug- I agree that the new requirements will significantly effect the cost of commissioning. Given that the general population of owners do not understand Cx today, the price tag on Cx will blow them away. Specifically the requirements for, 1.) A water vapor transmission analysis of all exterior envelope types used in the building, and 2.) Confirm building envelope materials and their installation are in compliance with the contract documents.

Not only do these activities increase cost, in labor, they present a much greater level of liability to the CxA. Higher liability=higher cost. Given these cost implications, I don't believe Cx can be considered cost effective for most projects.

I also agree that many Cx firms do not have the expertise to perform envelope testing. But we too have to learn and take the next step.

Our concerns are many, but I will list the major ones. There are many new items added to the "Commissioned Systems": Building envelope, testing of air flows, Roofing materials and installation, water systems including irrigation. This will add to the scope of the CxA, and greatly increase cost for an owner, but my concern is who is intended to perform these test and verifications? The CxA typically will witness the tests and do the paper work. The addition of the data center sections in the sections need definition. The NEC defines a data center. In this section a "data center" is defined as a space of 20 watts/square foot or more. Is this active or passive? this could be any telecom room. This is a very short summary, considering the review items filled three pages, but in conclusion, our concerns are two fold. Since cx is a prerequisite, the customer will now be paying triple the cost. Are CxA firms expected to absorb all of these new responsibilities? Also, I still can not find the "Online comment form" required by usgbc. See below.

Guidelines for submitting comments:

•Comments are only accepted via the "online comment form."
•Each respondent may submit only one set of comments on any individual credit.
•Comments may not be edited once submitted.
•Representatives of USGBC member and non-member organizations are encouraged to submit comments collectively.

It appears as if the site removed the spaces between the letters and number of the format I suggested. Without proper spacing, number, ittalics, etc, it will be almost impossible to read my comments.

So where do I submit my concerns for the commissioning sections? I have them in word form, and they are somewhat specific. I can certainly put them here in a generic statement, if necessary. The USGBC site says that there is an online comment form, that I can not find. If you could direct me to that document, that would be great. Thanks.

Format:
A.
1.
a.
B. 1
a.
b.
2.
etc.
That way it would be easier to comment on a single word or sentence.
The copy of the BD&C Redline that I downloaded was sectioned, but no numbers or letters. I will paste my comments in the next post. Thanks for your quick reply.

Tristan, how would I go about uploading my firms review comments? Also, for future reference, it would probably be easier to review and make comments if the document was arranged in an outline format with numbers and letters. Thanks for your time.

Yes, Randy you are correct - it is January 14th, 2011 for the close of 1st public comment. I accidently typed the incorrect date to Tristan for this forum.

I think the deadline is January 14, 2011, at least according to a Dec. 3rd note sent to the corresponding committees for the TAGs. If anyone confirms differently please post a response. Thanks.