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LEED 2012 – 2nd Public Comment – Materials & Resources (MR) Section

Key changes in the the Materials & Resources (MR) 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 posted here during USGBC's second public comment period  will be submitted to USGBC and considered "official" public comments.

More information on LEED 2012 certification and the second public comment

Materials and Resources (MR)

Major Changes

A Recycled Content prerequisite that was introduced in the first LEED 2012 draft is now gone. It would have required recycled content at 10% of the materials budget, with post-consumer and pre-consumer content valued equally.

Another prerequisite that is new to LEED 2012, Construction and Demolition Debris Management Planning, survived the first public comment period, but has some changes. It includes basic construction waste management requirements, including having a management plan in place, and targeting 20% diversion. Alternative Daily Cover (ADC) would not qualify as diverted debris.

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A new credit, Environmentally Friendly Construction and Enclosure (1–3 points), would replace the former Building Reuse credit, as well as incorporate aspects of the former recycled content and regional materials credits. This lengthy credit includes four options summarized in Table 1, and would move LEED toward more holistic, life-cycle-based materials evaluations rather than single-attribute credits.

Table 1

Table 1

This move toward multi-attribute materials considerations is reinforced throughout the new draft of the MR section, with the new credits Non-Structural Materials Transparency (1–2 points), Environmentally Preferable Non-Structural Products & Materials—Prescriptive Attributes (1 point), Responsible Sourcing of Raw Materials (1 point), and Avoidance of Chemicals of Concern in Building Materials (1 point). These credits are summarized in Table 2.

Table 2: LEED Materials Credits, LEED 2012 Second Public Comment


These credits represent a complete overhaul of the MR section since the first public comment, with the old Certified Wood, Regional Materials, Recycled Content, and Materials Reuse credits, along with the new Biobased Materials credit all being jettisoned in this draft.

This MR overhaul is sure to spark debate. Proponents of an “FSC or better” (for the Forestry Stewardship Council) policy for LEED will be pleased that FSC is the only forestry or biobased certification recognized under the Responsible Sourcing credit, and that the Materials Transparency credit has shifted away from Pilot Credit 43’s approach to recognizing other forestry certifications. Opponents of FSC-only, on the other hand, will be pleased that this draft maintains recognition of biobased materials without certification, something introduced with the first draft. Forestry industry leaders who have argued that LEED singles out wood for such stringent attention, making it “anti-wood,” should take note of new requirements for responsible sourcing of mined and extracted materials applying to concrete, steel, and other materials. Major certifications for those materials aren’t as available yet, but USGBC hopes to help spur their development.

Another noteworthy MR change is a shift away from the simple 500-mile radius defining “regional materials,” to use of a more targeted metric, the Core Based Statistical Area, as defined by the U.S. Census Bureau. According to the Census, this concept refers to “a metropolitan or micropolitan statistical area containing a substantial population nucleus, together with adjacent communities having a high degree of economic and social integration with that core.”

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


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September 15, 2011 - 12:57 am

Sorry, I didn't get a chance to read all of your comments before posting so I am sure you covered this, but since the USGBC is weighting these comments I figured the redundancy would be important.

MR PREREQUISITE: STORAGE AND COLLECTION OF RECYCLABLES: I like the addition of batteries, mercury containing lamps, and would petition to eliminate the glass requirement. Glass is dangerous, inert in a land fill, and even in houston were we have the world's largest glass recycler they don't want to pick it up.
MR PREREQUISITE: CONSTRUCTION AND DEMOLITION DEBRIS MANAGEMENT PLANNING: This is needed, and easy to get. Every project can get at least 20%
MR CREDIT: ENVIRONMENTALLY PREFERABLE STRUCTURE AND ENCLOSURE: (Why do you keep changing the names of all of the credits? it seems arbitrary and will just add thousands of conversations over the next two years) These are some of the rarest credits to get already, I like the addition of the additional options that are more in keeping with the goals of these intents. Also, they focus on different scenarios differently which is important. I am concerned about the amount of documentation required for Option 1, it seems to be very different from the others and the most cumbersome to document. It will need a lot of explanation.
MR CREDIT: CONSTRUCTION AND DEMOLITION DEBRIS MANAGEMENT: I like the division into projects with Demolition and projects without. I am not sure that you need a cap for 'heavy materials', recycling is recycling. If you want to reward gypsum recycling, and other more difficult recycling then you could divide the credit in to 75% of heavy debris recycled, and another point for say 35% of 'non' heavy materials that are more difficult to recycle.
MR CREDIT: NON-STRUCTURAL MATERIALS TRANSPARENCY: It is interesting that MEP items are now included. How are you calculating what the 20% is out of, cost, a consistent number of products??
MR CREDIT: ENVIRONMENTALLY PREFERABLE NON-STRUCTURAL PRODUCTS AND MATERIALS – PRESCRIPTIVE ATTRIBUTES: This is good that it excludes structural items because of the cost shift. What CSI divisions? Some MEP items are included so this will be tougher to know what to count and what not to count. Also, what the heck is this? - Core Based Statistical Area as defined by the U.S. Office of Management and Budget statistical area definition updated December 1, 2009. Can't you just specify a distance?
MR CREDIT: RESPONSIBLE SOURCING OF RAW MATERIALS - No comment other than, this is going to be a lot of paper pushing by contractors and vendors. I do like the combination of these points into one credit, but 1 point is not nearly enough for these. Especially considering you are giving one for the next credit. These used to be 5 easy credits to get, now you get one measly point for doing a ton of work.
MR CREDIT: AVOIDANCE OF CHEMICALS OF CONCERN IN BUILDING MATERIALS: Beginning of a red list credit, which we needed. However, because this is such a labor intensive credit in the early stages of this. It would seem that a 20% threshold is high… not that it would be tough to get 20%, but it would be tough to prove this. But it is a start. I have heard it takes 7 hours to track down this information for one material on one job, so you could spend two weeks easy verifying 20%.

September 15, 2011 - 1:28 am

I am also very confused about the "Core Based Statistical Area" basis for the materials prescriptive attributes credit. I tried researching it, but it seems that I might not even live in a "Core Based Statistical Area" (Fairbanks, Alaska). Is that possible?

I am very glad that multiple attributes can be combined to meet the threshold since it is more aligned with the intent of this type of credit, but I think this credit should have 2 or 3 threshold levels for 1-3 points (ex. 25% = 1pt., 50% = 2 pts., 75% = 3pts.). I am very surprised to see this credit get reduced to 1 pt. (these attributes are worth 5 pts. now, aren't they?), and I think materials' impact justifies more points. On the other hand, I think the transparency credit is over-weighted at 1-2 pts.

September 14, 2011 - 12:35 am

I just wanted to reiterate my support for eliminating ADC as "recycling." I operate a co-mingled construction waste recycling facility and I am fully aware that ADC is a nice tool to get projects above 75% when the recovery rates are borderline. Getting rid of it will be a challenge for me and other recyclers but it is one that we can overcome.
The big problem that needs to be addressed is that some landfills are burying 100% of a project's construction waste but claiming a 90% recycling rate since anything that doesn't blow away in the wind can be considered ADC. "Processing" in this case becomes running over the material with a compactor, the same thing they do with regular waste. This ADC loophole has made a mockery of the system and it needs to be fixed. Getting rid of ADC altogether is the best approach as it is clean, simple, and in line with what people expect when they hear the word "recycling." Burying wood, metal and concrete in a landfill on top of regular trash instead of mixing it in is not recycling -- ADC should not be considered recycling.

September 13, 2011 - 5:13 pm

First - PLEASE bring back some kind of number system like MR4, MR5, whatever...these credit names are too difficult to remember and differentiate.

Case in point, under Option 2 of the Environmentally Perferable Structure and Enclosure credit there are options for "Structure and Enclosure Product Attributes" including "recycled content". However if you read the text under "recycled content" is specifically states to use "non-structural materials with recycled content". I'll assume this is a typo or it will effectively eliminate recycled content materials from being used in the structural and enclosure assemblies in lieu of materials with other attributes.

September 15, 2011 - 3:35 pm

I'd like to agree that it is a typo Nadav and generally would think the same however if you look at the MR Credit - Environmentally Preferable Non-Structural Products and Materials - Perscriptive Attributes (whew....MR 5."whatever" would be a LOT easier....) you'll notice that Bio-Based materials are specifically designated as "Structure and Enclosure" and NOT Non-Structural. Certainly could be two typo's from careless copy/paste but they're not the same. (Incidently the same "typo" appears in the ID&C version too!)

Certainly typos can occur and be rectified but this IS a public comment draft in which the language matters (in both cases). I sincerely hope the plan includes a third public comment period so the comments can better focus on the intent and mechanics rather than spelling and semantics!

September 14, 2011 - 10:26 pm

I suspect that the "non-structural" qualifier IS a typo--it was probably copied carelessly from the Non-structural materials credit.

September 14, 2011 - 10:51 am

Good point - I was wondering if they intend to attach numbers once the dust settles from the review period. As an Architectural specification writer, I've always incorporated both the Credit number AND the Credit name in my specifications when referencing Credits. Remembering only the numbers is just as challenging as remembering only the names, especially for the folks in the field trying to build our projects, who may not be as dialed in to all things LEED.

September 13, 2011 - 4:38 pm

I already submitted my comments on this credit to USGBC but just noticed the following that needs to be addressed. Option 2 states: “Do not generate more than 2.5 pounds per square foot of total waste from the project.” This seems unclearly written to me. How about: “Do not generate more than 2.5 pounds of total waste per gross square foot of floor area from the project.”? I think this was the intention of the statement.

September 13, 2011 - 5:03 pm

I agree, Michelle. Your statement is better, for two reasons (grammar, and specifically stating "gross" floor area).

September 13, 2011 - 12:26 pm

Thanks to Tom Lent for his commentary on the subject of ingredient disclosure. I also note the stated preference to focus first on interior finishes. As the person responsible for product environmental certification and hazard communication for a coatings and sealants company, I have concerns about the actual potential for manufacturer buy-in and outcomes for the credit language as written. This comment is specific to ingredient disclosure requirements and I would appreciate anyone adding their perspectives.

The (abbreviated) stated intent of the credit is to increase disclosure on chemical ingredient data and reduce the concentrations of chemical contaminants. As written, the former is to be accomplished by requiring 100% public ingredient disclosure and the latter involves banning any quantity of certain chemicals from a prescriptive list; the starting point being the California Proposition 65 list of chemicals.

Ingredient disclosure is a particularly sensitive topic for the coatings and sealants industry. In many manufactured processed materials, the chemicals utilized in intermediate steps as well as equipment utilized, chemical transformations, and heat and pressure applied represent the true intellectual property of a manufacturer. Disclosure of end of process components may or may not give away any business sensitive information.

In the formulated products industry, the ingredient list itself is the intellectual property of the manufacturer and has intrinsic value in a competitive market place. Formulators take risks on new technologies in order to be superior competitors. Within the context of commercial and institutional construction, that means creating high-performance products with lower environmental and health risks. Ideally, our products also must contribute properties that enhance building performance and assure substrates and assemblies don’t fall apart.

Without protection of bona fide trade secrets, my industry has no incentive to innovate. Why should a company invest intellectual capital if we’re just going to hand our formulations to competitors? Would a consultant or architect willingly hand out their Outlook client contact lists? Should Google open source/free share its algorithms? This is the same level of critical business information that my industry works to protect.

Certainly, a LEED Credit is an honor system designed to reward certain behaviors. No entity is intrinsically entitled to contribute to every LEED credit. My concern is that an excessively stringent ingredient disclosure standard has the very real potential to cause coatings and sealants manufacturers to simply opt out of helping attain the credit. If, as Tom suggests, future iterations of LEED were to mandate disclosure for all materials, manufacturers will react in the only way possible to assure protection of critical business assets: offer the LEED market commodity products using older formulary technologies and depend on marketing to increase the product profile.

I agree with Tom’s concerns that a 20% project threshold will simply reward bulk materials. As an example, concrete mix design is specified by consultants at the behest of the design team. Absent spectrographic analysis of every mineral component, the ingredient list is part of the building specification.

I contend that ingredient disclosure requirements that do not respect intellectual property rights represent a lost opportunity for additional, substantive transparency efforts that can lead to selection of lower impact formulated products. I believe there are certain ingredients that should always be disclosed, but that will need to be a subject of more in depth stakeholder discussions.

Tom suggests the use of the Design for the Environment (DfE) ingredient disclosure requirements as a model. I think this is a better starting point than the current generic credit language as DfE at least attempts to address trade secrecy and intellectual property rights. The DfE program requirements are currently designed around a relatively limited product universe. It’s very much focused on household and janitorial products found in the EBO&M standard. It is not a perfect fit for coatings and sealants, but it is a positive starting point for discussion.

I appreciate Tom’s concern regarding the cost of third-party certifications to small companies. However, I think a more basic question is how we resolve fundamental trust issues. From my perspective, any company engaged in environmental marketing is essentially putting their brand equity on the line. Reputable companies that are interested in long term survival do not engage in self-certifications lightly. Conversely, third-party review does not guarantee absolute conformance. A bad actor can cheat with those programs as well. Third-party certification requires good faith efforts on the part of all participants.

However, I believe we have an opportunity to discuss streamlined third-party reviews with entities that can be trusted to impartially examine ingredient information within the framework of confidential business information protection agreements.

I want to clarify information regarding the degree to which third party certifiers are entitled to, and demand, ingredient information. From personal experience, I can say that SCS and NSF require 100% ingredient disclosure. NSF, for its registrations and acting as a DfE reviewer, also requires full ingredient disclosure from each raw material supplier which it obtains under separate confidentiality agreements as necessary. I can’t speak from direct experience on Greenguard and Green Seal certifications, but as I recall they also require 100% ingredient disclosure as part of their reviews.

September 9, 2011 - 8:53 pm

I have been reviewing the 2012 Credit modifications over the last week or so, and I will try to produce some coherent and constructive comments in the official comment feedback before the 14th. But, I must say here that I'm deeply disappointed in the USGBC. These modifications to the MR Credits appear to have been developed and written by industry, either directly or via their consultants, rather than by qualified sustainable design professionals. I mean no insult to industry and I greatly value their participation in the process of evolving LEED, but I DO want to see it EVOLVE, not get dumbed down so that it provides an huge opportunity to greenwash, and get the stamp of USGBC approval for doing so!

LCA: Great idea, and I would LOVE it if there were a magic LCA tool that I could use and trust. But, that magic tool hasn't been invented yet for designers/specifiers to utilize. And, "Manufacturer-declared LCA" = "Bad Joke."
Biobased: Without requiring biobased materials to be sustainably managed and harvested and 3rd Party Certified, what is the point of allowing this? I'm sure SFI is thrilled that even though the USGBC membership voted down this biobased scam to get non-FSC wood into LEED, and yet, like a bad penny, here it is again!
Chemicals of Concern: I bow to Tom Lent and his commentary on this issue, and I remind you that we are not scientists and whatever is done with this Credit it should be realistic and credible.

I would like to see the MR Credits enhance the sustainable value of my projects, to stand above the same ol' same ol', to move the market forward and upward, and to know that I, and my clients, can trust in the LEED's credibility.

I apologize if all this sounds harsh, but this is truely, truely disappointing.

September 12, 2011 - 5:01 pm

I agree with Peggy's assessment of the state of affairs within the MR Credits. Here's another example of a basic structural problem within USGBC that I just uncovered in the LEED Homes rating system:

In LEED Homes, MR Credit: Environmentally Preferable Products, in their chart they list Concrete/Cement & Aggregate with an asterisk. The asterisk footnote says: “at least 30% fly ash or slag used as a cement substitute, and 50% recycled content or reclaimed aggregate OR 100% recycled content or reclaimed aggregate”

To anyone who knows anything about “green concrete” this description sounds like it was written by the cement industry at the request of someone at USGBC who was so naïve that they believed the industry’s greenwash. 30% fly ash or slag substitution is “business as usual”. I don't know a single batch plant on the West Coast that doesn't automatically substitute 30% fly ash for Portland cement in order to save money on the mix. And using recycled or reclaimed aggregates is more likely to require more cement usage to make the large dirty aggregates stick together properly. Everyone who has ever been involved in a green project knows that Portland cement is the biggest GHG culprit, emitting 1 lb of GHGs per every 1 lb of cement manufactured. And using recycled or reclaimed aggregates in lieu of virgin aggregates is a red herring, having little to no environmental impact whatsoever. For footings and slabs on grade, which is where concrete is used in Homes, there is no reason why a 50% or 60% Portland cement replacement cannot be used. I suspect that no one knowledgeable in sustainable concrete mixes was consulted.

This pattern of behavior is consistent with the ENGO community’s experience with the FSC wood issue, where USGBC has allowed the timber industry to do everything they can to marginalize responsible forest management and timber harvesting. This includes the use of LCA to "prove" the superiority of wood over steel or concrete - a ridiculous claim. This is a classic greenwashing technique to divert attention away from a product's major shortcoming by focusing attention on another less important or irrelevant feature. Remember how The Vinyl Institute, about 6 years ago, tried to divert attention away from the toxic materials in their product by producing an LCA that showed that vinyl had a low carbon footprint? Now the timber industry is following the same greenwashing diversionary tactic, except this time USGBC appears to be buying it.

I think USGBC staff is allowing industry to write the rules for them, and they are either so naïve that they are believing the greenwash that industry is feeding them, or they are unwilling or unable to stand up to industry pressure. Either way, the watering down of the MR Credits to become essentially meaningless is very disturbing. There appears to be a lack of oversight from design professionals, and/or poor communication with the TAG committees, or else USGBC has given up on market transformation and has caved in to industry pressure.

September 8, 2011 - 2:34 pm

At the URL below are recommendations from forest activists in the environmental community for commenting on LEED 2012. If you care about maintaining high standards for wood and forests in LEED, please draw on this guidance as you see fit.


September 12, 2011 - 4:16 pm

I agree strongly with the attached document. "Bio-based" alone does not guarantee any environmental benefit. LEED Interpretations or future addenda can adjust the Certified Wood credit (if it is kept) to incorporate other TRULY SUSTAINABLE wood certification vehicles, if they arise (I am assuming there is a concern that FSC should not be the only 3rd-party allowed).
These proposed changes certainly seem to weaken the protection of our forests and could have devastating consequences.

September 2, 2011 - 2:59 pm

I continue to think this credit is a good step forward. There are six issues I would suggest we discuss to strengthen it and make sure it meets the intent.
- Disclosure requirements: This credit will need a precise definition to insure that product manufacturers get a clear signal of what is required to be disclosed in the list of ingredients. I suggest aligning it with the requirements for participation in the US EPA’s Design for the Environment - full disclosure of all intentionally added ingredients regardless of percentage and of all residuals present at greater than 100 ppm.
- Red List selection: There is no perfect list of chemicals short enough to be reasonable to put in a credit or spec and also comprehensive enough to avoid regrettable substitutions. I suggest that the credit be designed to use tools that reflect evolving knowledge on chemical hazards and to point users and manufacturers toward tools for continuous improvement and substitution toward inherently safer chemistry. The Green Screen for Safer Chemicals (developed by Clean Production Action in partnership with the Business NGO Working Group for Safer Chemicals and Sustainable Materials) provides clear benchmarks towards inherently safer chemistry that can be used with a list of lists and a variety of tools available from Pharos and various MSDS providers.
- Focus of materials required – The current draft language requiring that “20% of all building products and materials” meet the criteria could potentially be met by a single set of bulk structural elements like cement or steel which wouldn’t meet the real intent of the credit. Let’s make sure there is a focus on disclosure and avoidance of chemicals of concern in materials used in the interior finishes of the project as the pathways for human exposure are most direct there. Either split the structural and non-structural products and materials into separate credit points (as in some other LEED 2012 MR credits) or focus the first phase of the credit on building interior materials (as in EQ Low-Emitting Interiors) and phase in other areas later.
- Verification: the current credit weights self-declared and certified declarations equally. Third party certifications should probably get more weight (double credit?). At the same time, we should be aware of the burden we are adding for small innovative companies with the costs of increasing numbers of certifications. I suggest the USGBC convene discussions on how to help small businesses deal with increasing certification burdens.
- Make it worthwhile: This credit will take some work and could have huge impact and teams should be encouraged to go beyond 20% of products. It certainly warrants at least a second point. And consider giving half credit for the disclosure and full credit for the avoidance of chemicals of concern.
- Full life cycle: It makes sense to start with the contents and use phase concerns. But we need to avoid chemicals of concern upstream and downstream as well. This may be more complex than LEED is ready to tackle in 2012 but let’s at least signal we are going there and start a committee discussion on this. Pharos tackles the manufacturing toxics in its scoring protocols and there are some LCA practitioners doing some interesting work to apply hazard assessment to LCA inventories as well.
Thanks for taking this step USGBC. Now let’s make it work.

September 14, 2011 - 6:31 pm

Tom, While I think the idea of avoiding certain chemicals is admirable, the way this credit is written may include some unintended consequences.

Referencing CA Prop 65 as "the list" is an inappropriate place to start. First, Prop 65 (as I understanding) was developed to address drinking water standards (i.e. - ingested) and had nothing to do with building materials. Also, many of these chemicals have an associated "specificed level of exposure" in other documentation/regulations which are not referenced in the LEED credit.

I'm not sure if steel or concrete would potentially meet the threshold requirements as written. This credit needs to be better thought through and edited to only apply to products and materials which represent a potential risk to the occupants.

September 12, 2011 - 6:56 pm

I too generally agree with Tom Lents comments, but I remain concerned about the definition of "Non-structural" Interior materials. Many times, particularly where we are trying to reduce and simplify materials use, we see materials intended as structure, such as concrete, used as interior finishes. As an example, the requirement to drill a core in an exposed concrete floor can expose both construction workers and occupants to toxic materials.

September 8, 2011 - 1:17 pm

Not in this round but signalling for LEED 2014 and beyond, I would suggest that the USGBC move over time toward requiring disclosure of an increasing level of the product budget as a prerequisite. disclosure would be prerequisite, performance (avoiding chemicals of concern) would be rewarded with points.

September 7, 2011 - 8:08 pm

I second the following points that Tom makes above.

This credit should:

- precisely define disclosure requirements
- ensure that there's a focus on disclosure and avoidance of chemicals of concerns in materials that are in direct exposure pathways (interior finishes come to mind first)
- incentivize 3rd party certified declarations
- match the credit weighting with the effort required - at least 2 points

September 1, 2011 - 1:33 pm

Yesterday I attended a great workshop on a new life cycle impact assessment ANSI standard currently in development. The LEED 2012 draft was discussed, and Brendan Owens (USGBC’s VP of LEED development) spoke about the new proposed MR credit on Non-Structural Materials Transparency, which is often referred to as the Environmental Product Declaration (EPD) credit. There’s been a lot of industry concern about this credit because it doesn’t require a product to actually be environmentally preferable – just for it to declare some or all of its environmental impact, and it’s possible for a product to get partial credit with no third party verification of the stated impacts. Furthermore, some types of third party certification gets double credit, even if that certification is meaningless. (Example: we all know SFI is worthless, but I think it would count for double credit. EPDs are justifiably complicated, so I may be misinterpreting.)

Yesterday I finally heard a good argument from Brendan on the EPD credit. He said something to the effect that this is a critical first step to growing a body of knowledge about environmental impacts that might lead to the creation of better third party certifications, and for extracting info that manufacturers currently refuse to disclose. Wouldn’t it be great if we had the equivalent of FSC for other materials?

Given that logic, it seems like this credit could potentially transform the market for product categories for which there is currently little information available. It’s less relevant, though, for areas where we already have robust, trustworthy certifications for environmentally preferable products. If I were rewriting this credit, I would exclude wood, bamboo, and other products that have the potential to FSC certify. That way we could push the rest of the industry forward without shooting ourselves in the foot on the wood issue.

Given the current weaknesses of the EPD credit, I am disappointed to see that it has up to two points available, whereas other credits that actually require environmental performance often have only one. (The transparency ideas in the EPD credit also overlap with the intent of a similar credit for raw materials, but that one also requires environmental performance.)

Any thoughts on this?

September 12, 2011 - 4:33 pm

I agree whole-heartedly with Tom's concerns about generic EPDs. If the EPDs are not generated by independent (not industry-based) organizations, they are nothing more than greenwashing vehicles. We've already seen the timber industry's devious representation of the environmental benefits of current logging practices ("clearcuts create habitat"), and therefore they say "wood is good". If this becomes a credit, will we see the plastics, mining and agricultural industries try to out-greenwash each other in the construction of their respective generic EPDs? What incentive is there for industry-generated EPDs to be at all factual?

September 8, 2011 - 2:24 am

Thanks to Steve Baer for clarifying the credit for us. He affirmed that my interpretation is correct. The 1X value Generic EPD credit is indeed for an assessment of an industry average for a product category and only the 2X value Product EPD credit is for an EPD of a specific manufacturer’s product or product line. He further explained that the USGBC has designed the credit to encourage transparency not performance but with hopes that worst performers will learn of their relative positions by participating in the study and be encouraged to improve and that a buyer will also be able to compare different product solutions, such as carpet to linoleum to ceramic for flooring.

I appreciate the potential value of EPDs (e.g., we need them to assess climate change impact of products and address the 2030 Product Challenge) but I have deep concerns about the Generic EPDs and the potential for the worst performers to use them for greenwash and to actually avoid pressure to improve. Specifically, I expect that:
a) Some worst performers will not participate (leaving the industry average looking better than it really is) but will try to take advantage of the easy credit for the industry EPD anyway.
b) Participants in the study will not necessarily learn about their individual performance and how to improve it.
c) Those that do find out (or even just suspect) that they are worst performers will have more incentive to just stick with the easy marketable full credit for the industry generic average (particularly if it makes them look better than a competing product type) rather than to do a product specific EPD that shows how much worse they are and could hurt sales.
Furthermore, comparing Generic industry average EPDs can be a very deceptive way of making a choice between product selections. Unless you know not only the industry averages but also the minimum and maximum and which manufacturer and products were included in the survey, there will be no way to know whether an apparent difference between product type averages (such as between linoleum and ceramic) is likely to play out in the actual purchase. And if the two different product type averages were done under different product category rules (likely) with different boundaries, then even with ranges the comparison between product types will not be meaningful. They will only be useful as benchmarks *within* their product category (to answer the question of whether a specific linoleum product is better than the average linoleum product) not between categories (linoleum versus ceramic).

This credit will require some careful thinking about rules for the PCRs and the industry studies to make the resulting generic EPDs comparable and greenwash resistant. Can they be made comparable across different product types and designed to avoid rewarding worst performers with lots of LEED credit with little incentive to improve? Frankly I'm still skeptical of whether the Generic product EPD can be made meaningful enough – with enough protections to avoid its use for greenwash - to warrant LEED credit. I suggest just sticking with one point for real product specific EPDs.

September 7, 2011 - 12:47 pm

Can anyone clarify the difference between the upper two levels in the Non-Structural Materials Transparency credit? The three read as follows:
• Manufacturer declared LCA42 (contributing value = 0.5 x product cost)
• Third-party Certified Type III Environmental Product Declaration (EPD) based on Generic Product Family Product Category Rules (contributing value = 1.0 x product cost)
• Third-party Certified Type III EPD based on Product or Brand Specific Product Category Rules45 (contributing value = 2.0 x product cost)

Does this mean that a product gets full 1.0X credit if that manufacturer's industry has generated an industry average EPD? This has some hazardous unintended consequences. The industry could have a wide spread of performance and this would mean that the worst performing product in the industry can contribute toward a point in a project at full credit.

September 2, 2011 - 2:24 pm

I think Mara's idea is intriguing and worth exploration. Focus the EPD credit on the areas where we need more information of the type that current LCAs can provide. Unless you can do a much more ambitious LCA of the type that SCS is proposing, and expand LCA into the land use/extraction issues it appears that LCA's aren't providing much useful differentiation between wood products and may be missing the most important differentiating impacts between wood and non-wood products.
I share the concern that the weighting feels high on this one - most particularly giving full value for a product with only a generic product family LCA. This gives full credit weight to a product whose environmental performance is not even disclosed yet, only its industry's average.

August 17, 2011 - 5:29 pm

Intent: "To protect ecosystems, respect cultural and community values, and improve land use through responsible sourcing of raw materials used for building products."

The requirement for mined or quarried materials in this credit requests a signed letter from the owner of a manufacturing/extraction company that declares a “public commitment to responsible mining.” I am concerned that since "responsible mining" certification does not yet exist, such a letter won't carry much weight. Since non-mined/bio-based materials ARE required to meet 3rd party certification requirements, shouldn't mined/quarried be encouraged to do so as well?


August 10, 2011 - 2:25 pm

I have noticed in the table above that a bio-based raw material must be FSC Certified, however, in the second draft of LEED 2012 it is mentioned that bio-based products must be "FSC PURE". Can somenone confirm if this rules out using "FSC MIXED" materials for compliance with this credit?

September 12, 2011 - 4:20 pm

Aaron, I understand that the same would hold true for assemblies and non-assemblies.

USGBC's intention is to raise the bar, but I agree it may not work as intended.

August 30, 2011 - 3:21 pm

Tristan Roberts, you commented that, "Yes, the proposed change would, if incorporated into LEED 2012, rule out use of FSC Mixed."

My question is around products that are manufactured from wood sub-assemblies, like wood doors for example.

Would FSC Pure rule out the use of FSC Mixed in the component sub-assemblies or the entire door as an assembly?

If the entire door assembly needs to be FSC Pure going forward, this credit will be very difficult, and expensive for the industry.

Your thoughts?

August 10, 2011 - 5:44 pm

I commented that this draft lowers the bar for wood in general, offering numerous credits for barely legal wood through the new LCA-based credits as well as the new bio-based attribute.

The irony is that while it does this, it simultaneously raises the bar on FSC. It does this by only allowing in FSC Pure, which does represent a tiny fraction of what's available from FSC-certified manufacturers, and also layering on a bunch of bureaucratic "disclosure" requirements.

So you can run the olympic mile, use FSC Pure, and compile a phone book worth of submittals, or you can take a leisurely stroll in the park, use wood products that have EPDs (industry is rushing to produce these), or you can simply use wood that is "legal." And for the former, you earn a single point, and for the latter you can earn up to five.

Who is writing this stuff?

August 10, 2011 - 5:07 pm

Yes, the proposed change would, if incorporated into LEED 2012, rule out use of FSC Mixed.

Jason Grant, I'm curious—you commented earlier that this draft lowers the bar for certified wood. USGBC is promoting this change, at least, as raising the bar. What's your take on it?

August 10, 2011 - 4:22 pm

I wouldn't sweat this too hard - I'll bet this gets changed before we're through, as FSC Pure accounts for a very small fraction of the FSC certified products available. No one has the data, but it is probably less than 1%.

August 8, 2011 - 12:46 pm

When it comes to maintaining high standards for wood and forests, the second iteration of LEED 2012 presents a confusing picture. But overall, it must be said that this draft lowers the bar on wood and forests in fundamentally unacceptable ways. If this were implemented, it would undermine the movement toward forest conservation and more sustainable forestry and result in major damage to USGBC's reputation.

Fortunately, as it relates to wood alone, this version of LEED 2012 is rife with errors and inconsistencies. Assuming that this pattern of rather sloppy work runs throughout, there will certainly need to be a third iteration and comment period before LEED 2012 is balloted. This means that there is still time to get this right, provided (and this, of course, is a big proviso!) that those making the calls in the LEED revision process are disposed to listen to reason.

For detail, see this link:


August 10, 2011 - 6:59 pm

Wow, clap, clap,clap, well said. I am in the wood business and even I have to agree that it seems that we are taking a precarious step back if this does in fact become gospel. I am a huge proponent of responsible forestry, and want to see wood replace other non regenerative materials as much as possible, but this "unlocking" of the FSC grading, could hurt the responsible forest initiatives that currently exist. Let me know how I can help... More wood is good, if it's good wood...

August 3, 2011 - 3:07 pm

I had commented on the Credit about mercury content in lamps. The response I got said, "...The Reduced Mercury in Lamps credit is no longer a stand alone credit, the Technical Advisory Group is also in the process of revising the performance thresholds."

In both the clean and redlined version of this 2nd draft I see this Reduced Mercury in Lamps credit still as a stand alone credit worth 1-point. Was this response incorrect or is the new draft an outdated version?

August 10, 2011 - 3:33 pm

I think you intended to link me to EB:O&M https://www.usgbc.org/ShowFile.aspx?DocumentID=9795

I was looking at the BD+C document
Page 120 still shows this as an independant Credit. Either way, both versions still show this Mercury in lamp reduction as being worth 1 point. The purpose of my comment was to eliminate this point since less than 10% of the mercury pollution in the lamp's life cycle cost comes from inside of the lamp. A sizable reduction in lamp mercury content is a miniscule reduction in mercury pollution. It would be more benefitial to use this point somewhere else.

20 years ago I would have agreed with this Credit, but fluorescent technology is about maxed out. The market has already changed itself and there is very little mercury in the lamps today. Better to focus on energy reduction to reduce mercury pollution.

August 10, 2011 - 12:04 pm

Hi Bill -

In the link to the clean version of the rating system (http://www.usgbc.org/DisplayPage.aspx?CMSPageID=1750), Reduced Mercury in Lamps has indeed been removed as an individual credit. It is now Option 2 of the credit titled MR Credit Purchasing - Ongoing Consumption. The option is worth 1 point. The overall threshold has been lowered and lamps complying with the NEMA Guidelines are no longer exempt from credit calculations.

August 3, 2011 - 1:31 am

The MR Credit for Environmentally Preferable Non-structural materials is confusing to me. It says it is "1 point" but in the text it says a credit can be obtained for each attribute met. If the former, it looks like instead of being able to obtain credits for each of these different product attributes, it is an OR rather than an AND now? How does this encourage multi-attribute thinking for products? It seems to me that you would be able to cherry pick throughout your products to find a single attribute that qualifies for each material and tally them all up to see what you get.

September 13, 2011 - 6:21 pm


According to your comment above each attribute should be reviewed separately and combined to determine the aggregate perferable perscriptive value. So it's possible for a product to provide more than its actual value to the total.

For example, lets say you purchase $10,000 worth of a product which is made from 100% recycled content AND is sourced (manufactured and purchased) locally AND is part of an extended producer take back program. That product/material would have an aggregate value of $30,000 ($10,000 recycled + $10,000 local + $10,000 take back)?

Or am I missing something in the fine print?

August 10, 2011 - 9:10 pm

I am looking at this from the perspective of interior products manufacturers like countertops, carpets, wall panels, tile etc. I think the current structure may be premature in putting requirements in place that are costly (3rd party cert. or EPD) which require a lot of resources. Smaller companies may not be able to take on those costs and survive, so this favors large companies with the resources to meet the requirements. It is unfortunate for the innovative, smaller companies who may have better products. Based on your response, my understanding is correct in that the four single credits for Materials Reuse, Recycled Content, Rapidly Renewable and Regional Materials have been consolidated into a single credit. So products that used to promote contributing to "multiple credits" in these areas (ex. a recycled product within 500 miles of project) would now contribute to a single credit, but through multiple channels. The only conceivable way to contribute to more than one credit category in Materials and Resources (as a non-structural building material) would be through the Transparency credit, obtaining third party certification, and the avoidance of chemicals of concern. Most product companies will need to completely reposition their products. I think this is aspirational and a good long term plan, I am just concerned that most product manufacturers today would not meet this requirement and may not be able to shoulder potentially substantial costs involved.

August 10, 2011 - 12:14 pm

Hi Jessica -

Thank you for pointing out a line we will need to clarify. The MR Credit for Environmentally Preferable Non-Structural Materials is worth one point total. What we mean by "credit can be obtained by each attribute met" is that each attribute can contribute to the 50% of non-structural materials by cost regardless of the attribute. Using a matrix approach to product attributes removes the threshold for each individual attribute (as in past versions of LEED) so products that do not meet a minimum threshold will still contribute toward the meeting the credit requirements. Think of each attribute as being separated by an AND/OR. You have the option of meeting the requirements by meeting the threshold in one of the attribute categories or many.

August 2, 2011 - 4:44 pm

"Establishes contractual requirements with responsible waste and recycling haulers, including waste reporting requirements for involved parties."

We have found that the recycling programs in our area are constantly evolving. We have found ourselves altering waste/recycling haulers during projects when a better program becomes available. This requirements seems that it would require the contractor to be locked into a contractual relation with the initial choices that they made with no ability to alter that selection if a better program comes along. In the case of one of our current projects, that means that we would be sending GWB and styrofoam to the landfill rather than a recycler just because we were unaware of the proper recycling programs at the beginning of construction. It seems that we would be punished by LEED for making the environmentally responsible choice.

September 12, 2011 - 1:19 pm

My name is Tom Gray, Beth is a colleague. All jobs around here are now done co-mingled. The contractors put everything in one container and it goes off to who knows where for sure and evry month or so we get a poorly written spreadsheet stating that 96% or something is being recycled. Some of these processors are legit and I know some just do whatever is cheapest. We need some teeth in this credit to force these operators to at least lie on letterhead and tell us exactly how they process all the materials, how they estimate loads, photos of sorting areas, etc. This method has removed any incentive for the contractor to sort on site, even when there are large amounts of same material being generated. (High value items sometimes the exception) I see us trucking co-mingled loads 65 miles to sorter, right past a 5 mile away wood recycler for example.

August 10, 2011 - 12:23 pm

Hi Jon -

Thanks for your comments. The goal of the prerequisite is to set up performance expectations regarding waste diversion early in the project. What do you think about a documentation path that allows for flexibility in instances where project teams have made contractual changes resulting in improved environmental decision making?

We'll continue to consider this comment as we further refine the language. Thanks!

August 1, 2011 - 1:54 pm

I'm very pleased to see this credit (the last one in Table 2 above) added to the mix. I think it represents an important advance for the LEED system in bringing healthy materials to building projects, encouraging both content disclosure and screening for chemicals of concern. It rewards building projects with one point toward LEED certification if 20% of all building products and materials, by cost, have a publicly available list of ingredients and do not include California Proposition 65 chemicals in their contents.

This is a great start. In the next few weeks I'll be suggesting ways to refine it (definitions for what it means to fully disclose contents, some other red lists to consider beyond Prop 65, etc) and will be interested to see more discussion here.


August 22, 2011 - 5:29 pm

I agree with Tom. I am very pleased to see that LEED is starting to address this important issue.

I have been working on a number of projects where we've attempted to obtain ingredient lists for building products and avoid Chemicals of Concern. This pursuit requires A LOT of time and effort. I am concerned that one credit alone does not honor the effort required to fulfill this credit. Considering this, I am also concerned that this does not provide enough of an incentive to participate, which effects the market transformation aspect of the credit's intent.

Can someone explain the thinking behind the credit weighting?

August 10, 2011 - 12:14 pm

Hi Tom -

Thank you so much for your support. We look forward to seeing your comments.