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LEED 2012 – 3rd Public Comment – EA (Energy & Atmosphere) Section

Discussion of key changes
March 1, 2012

Key changes in the the EA section of LEED-NC (part of LEED BD&C) in the third public comment draft of LEED 2012 are discussed below. Do you have comments or questions on this draft? Discuss them below with your fellow LEED professionals. Substantive comments submitted here during USGBC's third public comment period here will be submitted to USGBC and considered "official" public comments.

More information on LEED 2012 certification and the third public comment.

Fundamental Commissioning and Verification, a prerequisite, has been moved back to the head of the EA section with the removal of the dedicated Performance section. The most significant change in this draft is softening of a building envelope commissioning (BECx) requirement that would have made this prerequisite much more demanding (and expensive). Commissioning of the enclosure is only included at the design phase (through the Basis of Design and Owners Project Requirements documents, as well as a commissioning agent’s review of project design). In another return to the LEED 2009 scope, domestic hot water must be commissioned, but not all plumbing systems.

While several wording changes to the Minimum Energy Performance prerequisite relate to compliance for non-U.S. projects, a major change from previous drafts is that a hybrid metric of energy savings based on reductions in energy cost and in source energy use intensity reductions has been abandoned in favor of the old metric of cost savings over an ASHRAE 90.1 baseline—now 90.1–2010.

The new prerequisite, Building-Level Energy Metering, is largely unchanged from the first and second drafts of LEED 2012. Among other things, this prerequisite inserts directly into the rating system what has in LEED 2009 been a requirement found in the Minimum Program Requirements: that projects share energy data with USGBC for at least five years.

Eliminated in the first LEED 2012 draft, the Fundamental Refrigerant Management prerequisite came back in the second and remains in the third draft. The actual credit language is fundamentally unchanged.

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Option 1 in the Enhanced Commissioning credit has had its scope limited in the same way as the prerequisite, but Option 2 offers additional points for commissioning the thermal envelope. Option 3 incorporates what had been a confusing entry in the second draft: a monitoring-based commissioning credit. Now it’s simply an option offering points on top of what’s offered with Option 1, by requiring the development of monitoring-based procedures to be incorporated into the commissioning scope. Among other things, the plan would require a list of points to be trended with associated frequency and duration for trending, and limits of acceptable values for tracked points. Maximum points in this credit are achieved through Option 4—“all of the above.”

The Optimize Energy Performance credit reflects similar changes as the prerequisite: the new hybrid metric is gone from this draft, as is the prescriptive compliance path using the Advanced Buildings Core Performance Guide. 

Advanced Energy Metering is a vastly simplified credit from previous drafts. It requires whole-building energy sources and energy end-uses comprising more than 10% of total consumption to have “advanced energy meters,” defined as permanently installed meters recording data in 1-hour-or-less intervals and able to transmit data. The gist of these requirements has not changed from previous drafts, but complicated prescriptive and performance paths have been dropped.

After overhauling a new Demand Response credit in the second draft, USGBC mostly left it alone here, although it has been simplified, with the removal of an option incentivizing semi- or fully-automated demand-response systems. 

There are minimal new changes to the On-Site Renewable Energy credit, with the biggest change from LEED 2009 still being the allowance of “solar gardens” or community renewable energy systems as long as they are in the same utility service area.

The Refrigerant Management credit appears at first glance to be rewritten, but the changes are apparently simply the addition of metric versions of compliance equations.

A new credit called Reconcile Design and Actual Energy Performance, which built on the LEED 2009 M&V credit, has been dropped from this draft, with its overall intent and some of its methods apparently folded into the other energy-efficiency and energy metering credits.

As in previous drafts, Green Power and Carbon Offsets now applies to total energy use, not just electricity use. Projects may use RECs, carbon offsets, or other sources of “green power” to offset project energy use by quantity consumed, not cost.

What do you think of the proposed changes? Post your public comments below!


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March 26, 2012 - 8:36 pm

With USGBC's comment period closing in 12 hours, LEEDuser must close this EA forum as of now as an official place to comment. Please visit USGBC directly to make an official comment in the next 12 hours. Thanks for the great discussion!

March 27, 2012 - 7:28 am

Based on the USGBC homepage, I had been telling people last night
that the comment period closes today at 9 a.m. EDT. However, I received
the following communication thiis morning from USGBC. Despite the time change, we must still keep this LEEDuser forum closed for official comments.

Despite our efforts to widely communicate the one-week extension for
third public comment, overnight we heard from a few folks who  thought
they had all of Tuesday, rather than the 9 am EST cut-off we had
communicated.  Since it won’t materially affect the schedule, we’re
extending the cut-off until 5 pm EST today, March 27, 2012.

March 21, 2012 - 11:50 am

There were some subtle changes to the prerequisite requirement for fundamental commissioning that can have some profound effects. As written, the commissioning agent must be on board during the design phase. The exact wording is:" Engage a Commissioning Authority (CxA) by the end of the design development phase. " This would mean that a project that decided to become LEED certified after the beginning of CDs would no longer be eligible for LEED since it does not meet the requirement of the prerequisite. I am assuming this is put in because of another change to the requirements which requires the commissioning agent to conduct a review of OPR, BOD and the design documents (drawings and specs). This is new on 2012, previously the CX agent had to ensure there was a BOD and OPR for Fundamental Cx.
Additionally, Fundamental Cx now requires the CX agent to "Prepare and maintain a Current Facilities Requirements and Operations and Maintenance Plan documenting information necessary for efficient building operations." While I think this is a great document to be produced it might be better served in the enhanced CX credit since the inclusion of all of these items will significantly drive up the cost of LEED certification to meet this prerequisite. I believe this will force many owners, developers and government agencies to reevaluate what green building rating systems they will use and will result in a decrease in market share and impact.

March 26, 2012 - 5:58 pm

Hi Marcus--It's a bit of both. I know from personal experience that we are often asked to bid on projects already out of the schematic design phase and often deep into CDs, if not out of the ground. As noted, though obvious to us, the IDP process is "radical" to 99% of the market.

I'd be comfortable with a 15-20 % loss of current share, but when you add the Cx PR to the ASHRAE PR, I'd have to say 2/3 might even be conservative. The EAPR2 (apologies for cross-contaminating the thread) threshold is the 8-point level in 2009 and only about 30% of LEED projects that certified in 2011 went above that. Currently only one state—Maryland—has adopted the 2010 version, 5 states have energy codes that predate 2007 and 10 states have no commercial code at all. The fact is that 'just' meeting ASHRAE 2010 for all intents and purposes IS a leadership position and one that has been driven in large part by the influence of LEED, influence that I do not want squandered.

I really don't want us to be looking backward saying 'coulda, woulda, shoulda'.

March 26, 2012 - 5:48 pm

Hey Rob,

I am not sure if your comment is directed toward the specific Cx issue being discussed (above your comments), the EA section in BD+C (this page), the LEED 2012 effort in general or my very general comment regarding market share above. I guess I am not sure specifically where you feel the de-coupling of the market and LEED is being proposed.

I certainly agree that we can't go too far as LEED develops or we could leave the market behind. I was just suggesting that in order to affect market transformation over time LEED needs to change. How much and how fast are the difficult part to judge when evaluating LEED changes at both the individual credit and holistic impact levels. I agree that the level of market share loss you suggest would result if LEED went too far, too fast. However, as a market transformation tool I could see a period of time when new versions of LEED come out that the trajectory of projects levels off as the market adjusts. If we don't change we become the status quo and LEED loses all meaning.

March 26, 2012 - 4:59 pm

If the definition of "lose market share" is "cut by 2/3 and kill it dead outside of the US" then I'd say go ahead and enjoy your tete a tete with the Green Building Challenge folks.

The sad reality is that the market is changing less rapidly than some of us who have been in the game for awhile would like. However, once you de-couple the LEED engine from the market train as is being threatened here, it is profoundly dangerous to think that the train, with no other engine to drive it, will somehow magically catch up with LEED.

March 23, 2012 - 2:30 pm

I agree with your review Robert. This appears to move peer review (without really saying that) and a reduced scope Systems Manual from Enhanced to Fundamental. I do not agree with this move, they should remain in Enhanced as part of a third party involvement.

If it remains, much better definition of what is meant by “review” of the OPR, BOD, and Construction Documents is needed. The Cx industry is plagued by a lack of definition and enforcement leading to a lot of low cost, low scope providers.

I would support improved definitions of scope with associated documentation requirements to show compliance. Followed by increased review.

Also, while the bulk of the envelope commissioning has been removed in this draft, the requirement for “review” here will lead to great confusion.

March 21, 2012 - 3:28 pm

The balance between market share, transformation and impact is a tough one to judge sometimes. I would gladly trade market share in the short run for market transformation in the long run. The two are certainly not mutually exclusive but if you are trying to drag the market in a direction sometimes you will have to give up some market share.

March 20, 2012 - 7:14 pm

According to the draft, it appears that the commissioning investigation credit now requires both a Level II Audit and commissioning, as opposed to one or the other like the previous version. Both a Level II audit and commissioning are good practices; however they are also good practices independently of one another. Many properties cannot afford the pricey endeavor of Retrocommissioning, or it may not make sense for a building to undergo Retrocommissioning if it is a building with an Energy Star rating of a 98, or if the building was built within the last couple years.

March 20, 2012 - 7:13 pm

The draft is proposing making the prerequisite for your Energy Star rating to be a minimum of 75. That is a 6 point jump from the previous requirement of a 69. That is very drastic, and a little extreme in our mind. We are working with many properties right now that are struggling to try and achieve LEED with ratings around 68-74. This would eliminate thousands of buildings, and we feel that this would greatly damage the LEED system. We understand that energy is a very large aspect of the LEED rating system, however it already greatly outweighs any other section of the rating system. Many properties’ energy star ratings are being affected by tenants installing large data centers that are beyond property control. Ratings have dropped, and properties are struggling to maintain high ratings. Not only that, but the Energy Star rating system is currently making changes, whereas effective in June 2012, properties can no longer claim data centers as a space type in an office building unless the data center is properly submetered, and actually energy data is input. Therefore, any buildings without proper submetering may be facing a dramatic drop in rating in June 2012. A building could be perfectly sustainable in every other way (great recycling rate, great water savings, etc.), but could be completely disqualified solely based on not having a high enough rating, or because they have a tenant with a large data center. Prerequisites are supposed to be considered reasonable to obtain. The points are where the real challenges should come into play, not the prereqs.

March 21, 2012 - 3:23 pm

Great idea Rob. You could also lower the prerequisite but start the points at 75 for the credit. Not being able to get any of the 20 or so points available is a big penalty to begin with.

March 21, 2012 - 2:52 pm

Instead of eliminating 75% of the potential buildings that can become LEED certified (meaning minimum Energy Star rating of 75 as proposed) Why don't we institute a program like is done in LEED Homes for the home size adjustment. In Homes, if your house is over a certain number of square feet for the number of bedrooms you have, you actually are penalized with negative points that need to be made up somewhere else in order to get certified. We could allow a building with an Energy Star of 50, for example, to meet the prerequisite requirement but then require them to start with a deficit of 10 Points(we can argue about what the correct penalty should be) so that they would have to be substantially more sustainable in other areas in order to reach their certification level. This would go a long way to draw in more buildings to the program and have them be sustainable, just in a different way. Maybe there is a stipulation that they have to also show a certain percent improvement over last years performance (a Hybrid of the other option that was dropped with 3rdPC.

March 21, 2012 - 10:49 am

I agree Chris this is a huge barrier to the more widespread use of EBOM. Perhaps we should lower the entry barrier even further (50?) and start the points at 75.

There is more discussion on this issue over at the EBOM 2012 page.


March 14, 2012 - 8:44 am

From my reading of the Fundamental Commissioning credit, it now includes a peer review (but with very little detail) and a Peer Review (Current Facilities Requirements and Operations and Maintenance Plan). I disagree with moving this scope from Enhanced, but if it is going to stay, the peer review needs more detail on what is accepted. Our industry is plagued by “what will get by the review” versus value added. Some level of rigor must be defined so firms can compete on qualifications and experience.

March 1, 2012 - 8:29 pm

I would also note that the credit referencing the IPMVP, which has been in LEED for at least a decade, was removed.

March 14, 2012 - 8:38 am

I saw that two Marcus. It would appear that a combination of the Option 3 in Enhanced Commissioning and the Advanced Metering kind of looks like M&V, or could look like it.