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LEED 2012 – Second Public Comment – Guide and Open Forum

Please review the new draft of LEED 2012 and share your thoughts
August 1, 2011

USGBC has opened the second public comment period on LEED 2012, the next version of the LEED rating systems. This public comment period is scheduled to run from August 1st to Sept. 14th.

As with the first public comment period, which opened in Nov. 2011, LEEDuser is here to provide guidance on key changes to LEED 2012 certification, and to provide an open forum for members of the LEED community to understand the changes and weigh in on them.

At USGBC's request, LEEDuser has set up a series of forums on the LEED 2012 draft. These forums are both a chance to register a public comment or comments on the draft, and a place to publicly discuss the draft. Questions and dialogue are welcome and encouraged! (If you prefer to send your comment to USGBC directly, see the link below.)

Please review the new draft of LEED 2012  and share your thoughts with the LEEDuser community and USGBC below!

LEEDuser's guide to key changes in LEED 2012, second comment

• Integrated Process (IP)  (see below)

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• Location and Transportation (LT)• Sustainable Sites (SS)• Water Efficiency (WE)• Energy & Atmosphere (EA)• Materials & Resources (MR)• Indoor Environmental Quality (IEQ)• Performance (PF)• Innovation (see below)

• Regional Priority (see below)

Key USGBC links

Download LEED 2012 Rating Systems DraftsOfficial Summary of Changes in LEED 2012 Draft

And now, our guide to key changes in the new LEED 2012 draft, starting with Integrated Process.

LEEDuser's Guide to the Integrated Process (IP) Section

The entire Integrated Process category remains as a new section (the first section of LEED—move over, SS). So does the first IP credit. The name of that credit has changed in this round, from “Integrated Process” to the more cumbersome Discovery – Analyses to Support Integrative Process (1 point). The new version of this credit is much more cleanly worded, and is organized by topic—Energy Load Reduction, Water Systems, and Site Assessment—instead of phase (for example, “Iterative Analysis during Conceptual Design). Teams would have to complete analyses in all three categories, and identify ways to reduce environmental burdens.

A new credit has been added to this section for the second public comment: Implementing Strategies (1 point). This credit appears to have been birthed when the lengthy requirements for the previous IP credit (now Discovery) were slimmed down. This credit focuses on two key requirements. The first is an analysis of synergies based on assessments performed during “discovery,” and comparison of at least two alternate designs. The second is a commitment to use of ongoing feedback mechanisms during building occupancy.

Despite a lot of feedback against the change during the first comment period, a relevant specialty is still required in the new language for the LEED Accredited Professional credit (1 point)—a change from LEED 2009. However, a new requirement that additional team members be LEED credentialed has been dropped.

Innovation (IN)

The Innovation credit isn’t significantly changed in the new LEED 2012 draft, although it is allotted 1–6 points rather than 1–5 as in LEED 2009. Even with that increase in emphasis, the Exemplary Performance path is allocated only 1–2 points (down from 1–3), while the Innovation path retains 1–5 points.  A Pilot Credit Library option, which was not included in the first draft, is reintroduced and given 1–5 points.

As with the first draft, the LEED AP credit has been moved to the new Integrated Process section (see above).

Regional Priority

The draft includes some minor wording changes to the Regional Priority credit, but the overall intent and requirements are the same. As with LEED 2009, this draft allocates 1–4 points to Regional Priority.

[See the links above for similar guidance to changes in the other sections.]

What do you think of these changes to LEED 2012? Discuss below!


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November 4, 2011 - 12:20 am

Have USGBC published an updated time-line for LEED 2012? I have searched without luck.

March 1, 2012 - 1:31 am

The 3rd public comment is opening today, March 1, with LEEDuser covering it here.

January 18, 2012 - 11:59 am

Perhaps I simplified the timeline, although I think I answered the original question. In reality they will try out contracted suppliers and then give more work to those who do the best. As most of the credits are actually not controversial they should be able to leave those until later in the process.

January 18, 2012 - 11:55 am

Which is alarming since there are several credits that simply cannot go forward without serious revision. Jumping away from the hard fought battles to get structural building material suppliers to document their attributes and even re-locate production facilities means LEED will have very tough credibility battles - the little boy crying "WolF!" is just one example. And there are several more that we hope another public comment period will impact. In short - how can they hire folks and get them started next month unless they intend to go with what's on paper now and the next review comments are for show?

January 18, 2012 - 11:27 am

The RFP for drafting the reference guides gave a timeline which may be of some use. USGBC intend to award contracts in February and indicate that the work should be complete within 10 months. That suggests they will have final reference guides will be finalized in December 2012.

January 18, 2012 - 12:35 am

I could also be wrong, but I don't see the third public comment happening in January. If you're wondering whether you missed something... not yet.

January 18, 2012 - 1:22 pm

It seems my initial guess was wrong about this coming out in early January. Now I'm hearing a rumor that it may not be issued until March. But I've been wrong before.

November 11, 2011 - 9:30 am

Just baseing this off of past history with other versions. I'm not "in the know" but love to speculate like the next person.

Expect the 3rd public comment to come out early January and the public voting next summer so that LEED 2012 can be released at GreenBuild next year.

September 14, 2011 - 11:32 pm

I don't get the use of the word "integrative" in any of these EBOM credits. Integrative is very vague and open to broad interpretation.

The calibrated modeling sounds nice but isn't something a building owner would be able to do on their own. Consider reworking this to work for owner operators without requiring a consultant. It's an Operations and Maintenance credit.

If modeling must stay....at least make it reference something meaningful other than master meter data. "Conduct building performance modeling calibration against utility data" is not going to be a useful model for decision making. You're asking for bad calibrated energy models. Use IPMPV and ASHRAE G.14

September 14, 2011 - 9:50 pm

This is a fantastic credit. Really focuses on ongoing performance optimization. Disappointing this is only considered one point, as monitoring systems can be a substantial investment, particularly for smaller projects. This credit should include monitoring of carbon dioxide levels. The intent lists IEQ but the credit never addresses that. Seems to be a disconnect there.

September 14, 2011 - 9:32 pm

This is the IP thread, but I see others have posted general comments here so I'll do that as well.

I happened to be talking to Chris Marshall (USGBC staff member) today, and he said something about LEED generally that was so succinct I'd like to repeat it: namely, that LEED consists of some slam dunk credits that you always get, some impossible credits that you virtually never get, and a section of credits in the middle where you normally work. My overall impression of 2012 is that the majority of the slam dunk credits are gone. Which means we'll all have to start looking a lot harder at those "impossible" credits. To an appropriate degree, this is a good thing, and part of transforming the market. But there's only so much "impossible" we can all tackle in a single LEED upgrade, especially in a down market. I think this may be a step too far, one that will add more costs than my clients can live with.

Just as an example, looking at the PF category: Cx may more than double in cost because of significantly increased scope; M&V has gone up quite a bit in cost now that a signed contract is required; most projects will also require several water meters.

Another thing is increased complexity of credits (e.g. in LT, MR and EQ) that will result in higher fees needed for documentation. Another result will be that teams will feel they must hire a LEED consultant to manage it all-- a plus if you are a LEED consultant, like me, but not so great for owners! Also, in the case of MR and EQ at least, the added complexity doesn't seem to be adding environmental benefit. It would be nice if LEED documentation could be simplified with each version, not made more complex.

January 18, 2012 - 12:28 pm

Karen I'm going to assume you do not understand how the versions of LEED are formed and who initially comes up with the credit language. It is volunteers who work in the industry, who tackle the design process all day, that volunteer their time to write the language. So your assumption that it is all LEED staff is not correct and its a bunch of people disconnected from the industry is incorrect.

Secondly, if you look at the differences between 2.2 and 2009 there is not that much difference in the majority of the credits. The market has caught up and it really is nothing to achieve Gold in project nowadays.

Thirdly, LEED is about market transformation and maybe the material credits went too far, maybe they didn't. But if you compare the requirements in many of the credits they are also the same as other industry standards.

LEED is voluntary (except for states that require public buildings to meet certain levels.) Not every project can earn every credit. I believe it was time for a big jump to push the industry to the next level.

January 18, 2012 - 12:11 pm

Perhaps I simplified the timeline, although I think I answered the original question. In reality they will try out contracted suppliers and then give more work to those who do the best. As most of the credits are actually not controversial they should be able to leave those until later in the process.

That said, the "L" in LEED is for "Leadership." I appreciate the feeling that LEED 2012 goes too far, too fast - my first reaction was that there are more than a few credits which will not be achievable for the first 12-24 months after the rating system is introduced. But unless LEED makes the requirement the industry will not provide it - ever. If we feel the intent is right then we should be willing to sacrifice credits now. If we believe that the intent is wrong then we should make our voices heard.

January 18, 2012 - 11:59 am

Julie I could not agree with all of your observations more! We want Chris and the other staff who do not tackle the design process all day every day to get the message that this 2012 is just too far, too fast, without any chance to transition our clients and the industries involved. You give me hope that we can turn the tide before we lose the toehold LEED finally had with institutions, developers, building owners...

September 14, 2011 - 11:19 pm

Just to clarify, I didn't mean to implicate Chris in any of my rambling opinions above. Those are all mine.

September 14, 2011 - 6:23 pm

Review contractor submittals and witness training should be in fundamental commissioning, then enhanced focuses on O&M and ongoing.

September 14, 2011 - 6:14 pm

The layout of commissioning is based around design-bid-build model and not an integrative design or design-build delivery. This creates either a loophole or exception for achieving the prereq. Consider addressing different delivery methods up front in LEED.

The credit seems to encourage hiring the Cx earlier in the project and keeping them on later. Consider requiring an executed contract before the end of programming phase to ensure this message gets to the client. Similar to the contract being required through post-acceptance.

Qualifications should consider certification bodies that are trying to ensure quality commissioning agents such as ASHRAE, BCA, ACG, TABB, NEBB, etc.

September 14, 2011 - 5:54 pm

Add a process chart to explain the simulations that have to be performed, the time they have to be performed in design, and if they can be used to satisfy IPc1 - Discovery. It's not clear if from this wording if the two credits can be tied together.

The energy target by schematic design is a good thing.

Consideration of design-build projects should be addressed somewhere in LEED to clarify required timelines, otherwise there is a large loop hole there. Most contractors consider design-build integrative delivery.

September 14, 2011 - 5:40 pm

This credit should be required to be documented in fundamental commissioning Basis of Design document.

September 14, 2011 - 5:31 pm

This credit is a very good addition. A lot of LEED projects today aren't doing these types of studies and they are very valuable.

Consider associating a time frame for this credit. Big picture scenarios should be performed during conceptual (e.g. massing, orientation, etc.), parametric simulations (e.g. insulation, glazing, etc.) are best performed in schematic design phases of a project. It should be presented that not all of these simulations have to be done at one time, but where it best fits the project.

Consider clearer definition of what is intended by two scenarios. That doesn't allow for much discovery.

September 14, 2011 - 11:28 am

I am pretty intrigued by how the first two IP credits have evolved to require setting of performance areas for consideration and then setting up tracking of that performance (in the Implementing Synergies credit). The most intriguing part to me, is that attention is given to environmental performance beyond energy and water, and that there is an assumption that such things as habitat health, soil health, and human performance are trackable.

This is very exciting, and could lead to creation of some real knowledge about extended environmental and human impact of our built environment.

My only concern is that it is unclear, as of yet, how this sort of tracking can be aggregated to be more useful to practitioners.

September 14, 2011 - 9:41 am

We are concerned that the 3-17 points that go to this credit may be too steep. Are there numbers on how many LEED ND's exist? As a transition to pushing to LEED ND use we would suggest pushing the Enhaced Site Selection with more than 1 credit. Possibly adding more credits (3) for developing a project in an urban core as designated by the census.

September 13, 2011 - 6:38 pm

Can the USGBC formalize and/or make a consistent option for excluding the USDA prime farmland requirement for cases of previously urbanized areas? We get mixed responses from the review teams at BGCI from projects that attempt to exclude the USDA farmland label from previously urbanized areas. Case in point: if a 40 acre hospital campus in a downtown setting still has prime farmalnd listed on site on the USDA map, shouldn't this be excluded since you would have to demolish several billion dollars in hospital facilities in order to farm that 40 acres of land again?

September 13, 2011 - 6:39 pm


September 12, 2011 - 1:59 pm

I am in favor of requiring that LEED APs have a specialty in order to get an additional point in a certification. I coordinate LEED projects for a living, and far, far too often I have to work with other LEED APs who are just not familiar with current LEED requirements because they have never been compelled to keep their knowledge up to date. I hear, 'Oh, I took that test years ago right before the test switched to the harder version, I actually don't know what the new requirements are at all. Do you?' Requiring a specialty would help mitigate this problem. I would also be willing to keep retesting to maintain my credential, though I understand that I'm likely in the minority on that.

September 11, 2011 - 12:32 pm

Here's a suggestion for the nice people at USGB / GBCI: for international projects using the SI system (International System of Units- metric system), it would be great to have LEED Reference Guide version using SI, as ASHRAE does. That would be a great help for both contractors and consultants.
A step beyond that would be to have this version translated into Spanish. That would accelerate the use of LEED in Spanish-speaking countries. Adios!

September 13, 2011 - 10:45 am

SI units would be a time saver.

At the moment we run our energy models twice, using SI units because it's easy for us to input the data and we understand what we are seeing, and then we convert it all for a final run in Imperial for submission to LEED..

One hopes that LEED Online would do all the conversions necessary ? It seems thay are going that way ?

September 12, 2011 - 3:39 pm

Great news! I wonder when this International is going to be finished.
About the SI issue, yes you are right about the LEED-Online forms but, to my knowledge, in many Latin American countries most of the forms are filled in off-line, and then the LEED-AP or team administrator fills them online, since most contractors and consultants are not familiar with English, let alone IP system.

September 12, 2011 - 3:00 pm

Hi Andres,

Good news here! An international version not just of the Reference Guide, but of the entire LEED Rating System, is in the works. 

I'm not sure how useful it would be to have an SI Reference Guide while the LEED-Online forms are still US-centric. Do you think that would be worthwhile?

September 8, 2011 - 6:17 pm

I'd like to have a clear understanding of which specialty will be considered 'most' appropriate for any given project. Can a LEED AP+BD&C 'count' for a project pursuing LEED CI certification? What about a project pursuing LEED O&M certification?

September 8, 2011 - 11:07 am

"Consensus decision-making is a group decision making process that seeks not only the agreement of most participants but also the resolution or mitigation of minority objections"

If LEED is updated by consensus why does the AP credit require the specialty? It seemed from the first public comment phase that a majority of people did not want the change to require AP's with specialty. This appears to be contrary to the intent of this process.

How do public comments fit into the Consensus process? Are the TAG members the only one's whos views are considered during consensus? Or does a single public comment have the same weight as a TAG member's opinion?

September 15, 2011 - 9:17 am

I would still argue that it is consensus based as various constituencies get to have their say and then the ultimate decision is put to a vote of the membership. I suppose we could vote on every issue but that does not seem practical.

There is a conflict of interest policy and as I recall committee members are required to read it and sign. Here is the committee policy.


September 14, 2011 - 1:40 pm

I understand that majority rule can be stacked by a company. I just hear USGBC toute this process as consensus based so often when it really isn't. I'd rather it was science based and a good idea can be adopted regardless of source or quantity of voices. Just don't call it consensus if it's not.

But I also think that manufacturing companies have been stacking regulatory boards and having Code updates that cost building owners millions. (Why would the existing roof insulation have to be removed when doing an EPDM reroof? Why does an above countertop receptacle need to be childproof.) I'm am concerned that LEED has become the newest target. Reading comments in the MR sections seems to show others feel that way too. Is there any sort of contract that volunteers are required to sign that when working on LEED business they're actions are for the benefit of LEED and not their employeer?

September 12, 2011 - 5:27 pm

Consensus decision-making and the number of public comments on a particular issue is not necessarily the same thing. Suppose that a particular company doesn't like how LEED treats their product. They could flood the public comments with many "votes". If we gave everyone a vote I would guess that LEED would barely change at all as inertia is a very powerful thing.

The public comments are taken into account as the credit language evolves. Many public comments have had significant impact on specific credit language and intent. The TAGs and other USGBC committees will spend the next two or three months reviewing them and revising the credit language.

In some cases a TAG member’s opinions do carry more weight than a public comment as they are the ones spending hundreds, or in some case thousands of volunteer hours working on these issues as vetted subject matter experts. Like all human deliberations consensus-making results from innumerable influences and the public comments are just one of those means for influencing the development of LEED. Other influences and opinions include USGBC Board, staff, other (non-TAG) USGBC committees, influential users, writers of standards adopted by LEED, and many, many others. Of course there are politics, both internal and external, at play until every committee and the USGBC Board signs off; then the USGBC membership votes.

As in almost all human enterprises of any size not all voices carry the same weight. Consensus decision-making simply means that everyone is given an opportunity to voice their opinion and a consensus develops through the process weighing all those influences.

September 12, 2011 - 5:14 pm

Hi Bill,

If they let a majority of comments dictate the results, any group with the ability to rally a large number of followers would be in control of LEED. Committees have to weigh in and make decisions, I believe. 

September 8, 2011 - 8:00 am

I saw Chrissy Macken make several comments on August 10th, but I haven't seen anything from USGBC since then. It's been a month, and the comment window is almost closed. Will anyone from USGBC be responding to questions raised by posters on this site? There was a lot more feed-back during the first public comment phase. I would still like to know why some portions of LEED are not open for public comments and who decided which areas were locked.

September 2, 2011 - 11:09 am

In LT Walkable project site, the term "woonerf" is used, but in the Glossary section the definition of this term was apparently erased. Shouldn't it be taken back, to help clarify it?

August 28, 2011 - 8:11 am

LTprerequisite1- Case 1- What happens is the new development footprint exceeds the previously developed portions of the site?

August 5, 2011 - 8:59 am

Although integrated process may lead to more sustainable solution, I don't believe it should be awarded points for the building design. These two credits should be deleted. I would contend that you could have an integrated process that does not create better buildings as well as a non-integrated process that creates sustainable designed buildings. At worst, these points will result in teams creating documentation for an integrated process that may or may not have occurred. How the design process occurs does not necessarily creat better buildings.

September 14, 2011 - 4:52 pm

First off, sorry I am late to this, but billable work always seems to take precedent some how. I will leave my general posts, but not expect comments as today is the last day of commenting. Nonetheless, I would like to hear others takes even if it is just for our own edification.

In terms of integrative process, you pretty much have to have one in order to achieve many LEED credits as it stands. You cannot earn very many credits in silos, and while integrative processes do not generate green buildings, you can't really have a truly green building without an integrated process.

My first problem with Integrative Process is I fear it will just become too "documentation heavy, result lite" credits that everyone will do because so many of the other 'easy' credits have been taken away. Sure, it will just be 1 credits out of 110, but seems

I do think that it will provide good foder and deliverables for charrettes, but I am not sure you should get a point for having a productive charrette and follow up.

I would like to know others opinions on how onerous they think performing a water balance study will be for a site, seems like a several thousand dollar in fee undertaking.

September 14, 2011 - 2:22 am

I think points for ID / IP will work. As a related example :-

In South Africa the commissioning of buildings is mostly unheard of, is not understood at all, and is seen as an extravagance.

We therefore battled with the LEED Commissioning prerequisite. Finally our entire team of 5 Engineers ( Clients included ) resolved to go across to the University of Wisconsin at Madison to do their Commissioning course – what an absolute eye opener !

In the end, commissioning has had a major impact on the quality of the delivered project, and in some cases has required that we revisit the design too. This LEED prerequisite, initially seen as frivolous, paid for itself and more.

The Client tells us he won’t build any other way in future.

So, if the intention is to kick-start integrated design then it may well work much like the example above.

I can see it, at the very least, forcing the design team to start talking together. Then, If they have any sense, they will investigate how to use something like the AIA approach or the ASHRAE approach and that will be a large step forward ?

I refer you to Lynn Bellenger, Past ASHRAE President :-
“ …. It is going to require a cultural shift in our industry to transform the design process, and it is a shift that has to occur if we are going to reach our goal of net zero energy buildings.”

September 12, 2011 - 6:19 pm

Of course they do, just like everyone builds green and energy efficient buildings! :-)

September 12, 2011 - 5:48 pm

Most of the folks who tell me they "use Integrated Design already", don't.

August 18, 2011 - 8:17 am

It may not get rid of the checklist mentality completely, hopefully it will get those that are just doing that, to look at the process as a whole. In the statement of those who already use the integrated process don;t need change, I would say that it is not about change, but it is to look at one's process for improvement. That credit is not about market transformation, as i had noted it is about mentality transformation.
I ask, have you viewed the link posted by Chrissy? Have you looked at this from the standpoint that the bar has been raised in this version and these are points that for most are the easy ones to get since there are now credits that are pushing the bar?

August 18, 2011 - 8:02 am

To your point on energy modelling, LEED awards points based on the outcome of the energy model, not just because you performed an energy model. The Integrated Process credits provide points for merely going through the process whether or not they have an outcome on the final project. I would disagree that the other credits are similar in nature. For example commissioning is a process, but you can't get the end result without going through the process and it will likely improve the building performance.

I am concerned about the integrity of the LEED rating system and would prefer it moves toward performance measure system. In reality, if we are not measuring performance than what are we trying to accomplish?

August 18, 2011 - 7:55 am

I don't believe adding points for integrated process will change checklist mentality or help market transformation. Those who use integrated process already don't need change and those who don't will go through the motions to get the points. USGBC seems to be awarding 2 points to nearly every project and will open itself up to criticism that it's system is onerous and not really awarding high performing buildings.

August 10, 2011 - 5:45 pm

Thanks everyone for the lively discussion! Much of what we took away from the 1st Public Comment period relative to the Integrative Process credit category is that the credits were overly prescriptive with regard to the process teams must use, rather than focusing on the outcomes that can come from an integrative process.

The 2nd Public Comment draft credits are attempting to be much more outcome oriented without prescribing specifics of the process (number of meetings, people who must be present at meetings, etc) because, as our experts discussed during the revisions of these credits, those aspects may not guarantee improved outcomes. Whenever possible, LEED credits are written in a performance based way without dictating the specific strategy; the attempt here is to make credits about a process as performance-based as possible. I'm really interested in everyone's thoughts about how we might continue to focus more on the outcomes but still get those in the market who are unfamiliar or unlikely to use integrative design process thinking about the concept and the benefits.

I'd also like to put in a plug for an Integrative Process Webinar hosted by USGBC on September 8th, with guest experts Joel Todd, John Boecker, and Bill Reed. The Webinar will explain how and why the evolution of LEED 2012 rating systems are further incorporating the integrative process into credits, discuss how the inclusion of integrative process standards into LEED 2012 credits will impact your professional practice, and illustrate case studies and best practices from the field. More information can be found here: https://video.webcasts.com/events/pmny001/viewer/index.jsp?eventid=38183

August 10, 2011 - 2:29 pm

Michael, I agree that in this case LEED is giving points for process rather than for outcomes, but I would agree with USGBC that process is important and worth rewarding. As you point out, integrated process is no guarantee of a better-performing building; however, it greatly increases the chances of a better outcome. Energy modeling is no guarantee of performance either, yet it is widely regarded as an essential process tool towards making better-performing buildings.
It's also worth noting that LEED already has other credits related to processes, rather than outcomes, include commissioning and measurement & verification. And in the EBO&M rating system there are even more points awarded for good management practices rather than just outcomes - have water meters and energy submeters, and conducting a waste audit, for instance.
In general, one benefit of rewarding a good process is that it helps to educate the team members so that their future projects will probably also be greener. I agree that it's no guarantee, but I think it's worthy of encouragement via LEED points as well.
If you're interested only in performance, EnergyStar and Living Building Challenge are both structured more that way than LEED.

August 10, 2011 - 8:19 am

Michael, if you read the daylighting credit, you get more points for simulation than measurements and you are correct that simulation is the best means for daylighting design.

Lets let look at what LEED was originally for, market transformation, which i would have to say that it has done this. So the intention or idea behind the integrated credit is that projects were designing buildings by the checklist method. I see it and here, projects base their decisions solely on whether they get a point or not. That is not what LEED is about or is to be about. So these credits will hopefully start to TRANSFORM (key word) project teams mentallity that by using integrated design, the LEED points come automatically and that the overall goal is better building, not a plaque.

August 5, 2011 - 1:10 pm

One other point.
Under the same logic as this credit, shouldn't USGBC provide a credit for using a computer simulation for daylighting, which arguably is better at designing daylighting for rooms than empirically. Or if USGBC finds out that one energy modelling software is better than others, provide a credit for using that.