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LEED 2012 – 2nd Public Comment – LT (Location and Transportation) Section

Key changes in the the LT section of LEED-NC (part of LEED BD&C) in the second public comment draft of LEED 2012 are discussed below.
August 1, 2011

Do you have comments or questions on this draft? Discuss them below with your fellow LEED professionals. Substantive comments submitted here during USGBC's second public comment period here will be submitted to USGBC and considered "official" public comments.

More information on LEED 2012 certification and the second public comment

The new Location and Transportation (LT) category still consists mostly of credits from the old Sustainable Sites category that aren’t so much about the site itself as where it’s located.

Major Changes

The biggest overall change to this draft is the new LEED for Neighborhood Development Location credit (5–17 points). If you’re wondering how building in a LEED-ND pre-certified Stage 2, or certified Stage 3 project can be worth that many points—this credit would become an alternate compliance path for the whole LT section.

There have been some big changes in the rest of the LT section since the first public comment. Apparently a "Bicycle Storage" prerequisite didn’t go over big with commenters (too many projects would have been ineligible?), and has been removed completely.

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What had been the "Site Selection" credit has morphed into a prerequisite and a credit. The prereq, Sensitive Land Protection (required), is structured very much like the current SSc1, but as a prerequisite, those requirements would have bumped a lot of projects out of LEED consideration. Accordingly, each of the requirements for greenfield sites now has “mitigation requirements.” For example, if you must build some or all of your project on prime farmland, you can purchase or donate conservation easements for similar land elsewhere.

A credit titled Enhanced Site Protection (1 point) offers a higher bar. There are three options: locate on an infill location within a historic district; locate on a brownfield; or locate on a site listed for preferential development by one of seven federal programs, such as the EPA National Priorities List. This new approach appears to have allowed for a raising of the bar on brownfield remediation (see the SS section), and a new credit for historic buildings that appeared in the first public comment period has been rolled in here.

The old Development Density credit (SSc2) is now titled Development Density and Diverse Uses (1–8 points). The basic intent has still not changed, but as with the first public comment draft, there are some changes to the documentation requirements. Pedestrian-friendly streets are now a key part of the credit, and credit for locating in a LEED-ND project has been moved to its own credit (see above).

The Low-Emitting and Fuel-Efficient Vehicles credit (1 point for Schools) had already been tightened up significantly for the first public comment, and it has been tightened again. Actually, it has disappeared for most projects: only schools and warehouses are eligible for it now, and the requirements are to provide a low-emitting vehicle fleet for the facility.

Minor Changes

The new Reduced Automobile Dependence credit is now Quality Transit and Reduced VMT (1–4 points)—with “VMT” meaning vehicle miles traveled. Other than the name change, and a change to intent that matches it (a more positive focus on mass transit options), and some changes to point thresholds, this is mostly consistent with the first draft.

There have been only minor changes to the Bicycle Network, Storage, and Shower Rooms (1 point), including the credit name (they’re not “changing” rooms anymore). Notably, the credit now defines minimum requirements for a bike rack: that it allow use of a U-lock, have a two-point support system, be accessible without moving other bikes, and that it be securely anchored.

Walkable Streets is now Walkable Project Site (1 point), with requirements that have been simplified since the first draft. The requirements focus on designing the building frontage to be friendly to pedestrians, with features like entry off of a public space, and continuous sidewalks that connect to public sidewalks.

The new Parking Reduction credit is now Reduced Parking Footprint (1–2 points). The key requirement remains from the first draft: reduce capacity over a “base ratio” given in the Institute of Transportation Engineers’ Parking Planning Handbook. The requirements are tougher for transit-served projects. A change is that the language codifies the long understanding that fleet and inventory vehicles are excluded from parking credit calculations.

What do you think of these proposed changes to the LT section? Please post your comments and questions below.


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September 14, 2011 - 10:21 pm

Option 3 is titled "Dense and Accessible Location" which implies handicap accessibility, which does not appear to be the intent of the credit. Additionally this credit calls for "sidewalks that are at least six feet wide," which would be difficult to document, and certainly difficult for a project team to affect. Adequate pedestrian provisions are made through the remainder of this credit, which makes this prescriptive requirement feel redundant. Recommendation: Change title of Option 3 to "Dense and Pedestrian-oriented Location." Remove bullet point 2 which provides a prescriptive requirement for sidewalk widths.

September 12, 2011 - 2:07 pm

I really disagree that a LEED ND project needs to have achieved Stage 2 certification for a building on the project to get the point. I think that Stage 1 certification should be adequate, as the Stage 1 credits related to location (the SLL credits) are unlikley to change between the various stages for a particular project. Furthermore, infill determination is made in Stage 1, which I believe to be the most important distinguising attribute of sustainable neighborhood development. Yes, I know that there can be LEED ND projects that are not infill, but I think a LEED ND infill project should automatically get all points in this new LEED 2012 credit. I understand that the NPD and GIB credits can can change between Stage 1 and 2 as Stage 1 requires just letters of intent for many of them, but the aspect of the certification most relevant to a particular building will remain the same.

Perhaps a compromise: some points are available under this credit for Stage 1, more for Stage 2, and all for Stage 3?

September 14, 2011 - 3:01 pm

Hi Sara. I appreciate the points you make on how Stage 1 certification could do just as well for the LT-related criteria as Stages 2 and 3. From the Location and Planning TAG's perspective, Stage 1 needs to provide as much assurance of achieving that LT criteria as the latter stages do. TAG members and staff will need to do a credit-by-credit analysis is Stage 1 projects can give that assurance. Your points are well-taken and worth considering as we review the feedback from this second public comment period.

September 5, 2011 - 2:09 pm

lproviding a "fleet" of fuel effcicient vehicles might be a practical strectch. recommend keeping the fuel efficient vehicle credit for all projects and not just schools and warehouses.

September 14, 2011 - 5:49 pm

Walkable Project Site: I thought the Daylight Calculation was complicated... this makes that look like single digit multiplication. I love the intent of this credit. I think this is one of the most important concepts of making a walking community. However, there has got to be a better way of communicating this than the 7 headed monster I just read. They all have good intentions, but documenting these very simple concepts the way that you have described them would take a week. I am not sure why you would have to do all 7 either. For 1 point, it seems like getting 4 of these 7 would be a logical improvement over the current system. I would also like to see one addition that if a 'form based code' is implemented for the community of the development that is designed to increase walkability, that development would automatically earn this point. This is a basically a form based code anyway, but without the cool diagrams.
Reduced Parking Footprint: Again, very important, but how do you reduce parking below code? It seems like you should get one point for not exceeding code and another point for going below code and exemplary if you go further below code. Many owners don't even want to meet code, they want as much parking as they have space for, so that would still be note worthy.
LOW-EMITTING AND FUEL-EFFICIENT VEHICLES: I side with those that say this is an important credit. Encouraging the improvement electric vehicles is important if we are ever to go 100% renewable. Secondly, it is at least noteworthy, especially in LA, Atlanta, and Houston to shift and reduce emissions away from the city street and to the centralized source, in my opinion.

September 14, 2011 - 5:38 pm

CREDIT: DEVELOPMENT DENSITY AND Diverse Uses: This credit is one of the few that seems to have been made simpler. Which is good, because it should not be difficult to prove either of these cases for your sites location. I am not sure about how it is currently counted, can you get 2 of the first 2 points for option 1 and still get 2 and 1 for options 2 and 3... this adds complication for what I personally do not see as much added benefit.

Credit: Quality Transit and Reduced VMT - This credit is the opposite. It takes what used to be a straight forward simple credit and turns it into a documentation heavy quagmire. I agree not all sites with buses are created equal, but what we used to be able to say in a sentance is now 2 pages of rules. Option 2 is practically unreadable by a non-traffic engineer. My brain exploded just trying to think about the VMT of my TAZ for non-homebased employees even if it is in a MPO. How do you count a VMT and what if my MPO only has 8 years of surveys? Seems like it could be a lot simpler and prove the same point.

CREDIT: BICYCLE NETWORK, STORAGE AND CHANGING SHOWER ROOMS - I do like the enclusion of the Bicycle network, I hate projects putting a bike rack and shower in just to get a point that never get used. However, if you can be 1/4 mile from a bus route and have that count it seems that 1/4 mile from a bike 'network' could also suffice. Biking a quarter mile 'off network' is not a big deal. (its only 237 yards more, but makes more sense). I like the simplification of how many showers you need. I am not sure the need for the 'both cases section, those are all common sense and just extra documentation. Example" Why do i need to spend time providing that the bike storage does not interfere with universal access?? It is illegal to do that anyway! I realize not all bike racks are created equal, but you can simply state these phyical construction qualities if you need all 4 which I don't think you do, in the above section after the word secure. Example: Secure, anchored, two point supported, U-Lockable, storage that can be accessed without moving another bike. Done. finally, I disagree with 'Enclosed'. Secure and Covered should suffice.

September 14, 2011 - 5:37 pm

This section, upon first reading is pretty scary. Compared to the last version, documentation of these fairly easy concepts seems to have increased 10 fold and I am not sure that the results will be different unfortunately. Believe it or not, people do not pick sites to earn LEED points, and while I do believe that in order for a building to be sustainable it has to be in a proper location...simply making the 'proving' of the 'properness' of that location very difficult does not really effect either the decision to put a building there or the actual nature of the site.

That being said, here are my comments on the specific credits...

PreReq: Sensitive Land Protection, Agree with this, I have always thought you should not be able to build a certifiable building on a wetland or in a flood plain. This is a good development.

Credit: LEED ND Location, Agree that Phase 1 should be good enough. Like this credit as it makes all of the difficult documentation a mute point if you can find one of these projects to tell your client about.

Enhanced Site Selection: This is tough, while I like the additional emphasis on brownfeilds, I fear that there are too few options. I think that if you are reusing a building (Environmentally preferable Structure) you should get this point, or if you are earning a couple of the other LT points this one should kick in for added emphasis, urban infill that has not been used in 10+ years. At any rate, there should be more than 3 options, (I am not even sure Houston even has a historical district :P) And whatever you do, make it simple to show/prove.

September 14, 2011 - 4:56 pm


Thank you for your consideration and comments.

All of the literature that I've read says that the jury is no longer out on whether EVs are the way to go. I don't recall the source, but my recollection is that an EV plugged into a 100% coal fired power plant electric source would be only a minor improvement over a gasoline engine vehicle (don't know what mpg this study used). Whereas, any power grid source that had a percentage of renewable or net carbon neutral power such as hydroelectric or nuclear, would see a significant decrease in overall carbon footprint from an EV. The newer NIMh batteries used in EVs are more efficient, last longer, and store more charge, and the grid power sources are becoming increasingly cleaner. This is the next major transportation innovation, and government, car manufacturers, the public, the military, and the suppliers of charging stations are all behind it.

Most of the charging stations can operate on a credit card, so the building owner does not need to give free power to the vehicle owner, however if the building has PV panels on the roof, then the building can provide free power for the transportation needs of the building's EV owners.

The website www.pluginamerica.org has lots of useful information on EVs including data on every electric vehicle manufactured, every company that makes EV charging stations and their features, seminars, PSAs, issues for building owners to consider when installing charging stations, and links to other relevant websites.

September 14, 2011 - 2:42 pm

Hi all. I wanted to acknowledge receipt of these suggestions. They're very strong and worth considering, especially the note about the increasingly wide-spread use of electric cars. The Location and Planning TAG currently has concerns about the life cycle-impact of plug-in electric vehicles versus that of hybrid or low-emitting vehicles. Their research leading up to second public comment indicated that the "jury's out" on whether an electric vehicle plugging into a dirty energy source has better overall environmental performance.

Ultimately, though, the TAG and staff are very eager to put that consideration alongside your points and those collected during this public comment period. Your comments here will be shared with the TAG as they continue their research.

September 12, 2011 - 3:56 pm

I agree with Julie, and think this credit could be made somewhat better than the 2009 SSc4.3. My comment to USGBC is the following:

Numerous states including California, Oregon, and Washington are building infrastructure to accommodate electric vehicles (EVs) and plug-in-hybrid electric vehicles (PHEVs). Interstate freeways, urban areas, airports, public parking structures, and civic buildings are installing EV charging stations. California's 2010 Green Building Standards Code includes mandatory and voluntary requirements for EV charging stations. And every major auto company is racing to produce an EV or a PHEV by 2012. To facilitate the most rapid acceptance and adoption of these vehicles, all vehicular parking areas should include spaces for EV charging stations.

USGBC needs to encourage building owners to build the infrastructure to encourage the adoption of EVs and PHEVs throughout the country.
My recommendation to USGBC follows what California has already incorporated into our CALGreen Building Code:

"In addition to the existing Credit requirements for Schools and Warehouses and Distribution Centers, add to the credit a requirement for preferred parking at all parking areas for "CLEAN AIR VEHICLES", AND a requirement for Electric Vehicle charging stations. This should apply to all LEED BD&C rating systems. The California Green Code uses the following formula: 1-50 parking spaces = 1 EV charge station, 51-200 parking spaces = 2 EV charge stations, and 201 and over parking spaces = 4 EV charge stations. There are 3 Levels of EV charge stations: Level 1 - 120 VAC 20amp = slow charging, Level 2 = 208/240 VAC 40 amp = intermediate speed charging, and Level 3 = fast charging. Suggest all parking areas give preferred parking to "Clean Air Vehicles", and require Level 1 and Level 2 charging stations for EVs. Definitions and standards are available from California Air Resources Board, US EPA Fuel Efficiency Standards, California's CALGreen Code, and the California Building Code, Section 406.7 (Electric Vehicle)."

September 7, 2011 - 3:33 pm

I absolutely agree that it should be extended to all projects. I also think that Option 2 of the Low-Emitting and Fuel Efficient Vehicle credit from 2009 should be retained and should apply to all projects. Option 2 allows for alternative-fuel stations for 3% of vehicle parking. I think it's a mistake to remove the incentive for putting in electric charging stations now-- right when a wide-scale network of stations is so needed! 2011 has been a huge year for electric cars, and more charging stations are absolutely necessary to make ownership of electric cars feasible for regular people. I think if this remains part of LEED, building owners are more likely to install these stations now than they ever have been before. i.e., I think his credit would do real good.