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LEED v4 Public Comment Forum - LEED Takes a New Direction

USGBC has opened the fifth—and, it expects, final—public comment period on LEED v4, the next version of the LEED rating system.
October 2, 2012

USGBC has opened the fifth—and, it expects, final—public comment period on LEED v4, the next version of the LEED rating system. The system was referred to as "LEED 2012" for most of its development, but after the fourth public comment period (see discussion on that comment period and draft) ended with a sense among USGBC membership that the system was not ready for a member ballot, USGBC changed the rollout schedule and the name.

The public comment period is open from October 2, 2012 through Dec. 10, 2012, with the ballot planned for June 1, 2013. Anyone can submit public comments on the LEED v4 draft here or on the USGBC website, where you can also see the proposed language, credit by credit. Please post your comments on LEED v4 below!

Now that the final form of LEED v4 is taking shape and the direction that it is taking is clear, the team here at LEEDuser has written a special report to guide you through potentially confusing new concepts like EPDs, REACH, BUG ratings, and their place in LEED certification.

If you're already a LEEDuser member, look for the download link in the sidebar to the right.

Not yet a LEEDuser member? You can get the LEED v4 report for free with a 30-day trial subscription to LEEDuser.

Think you already know all there is to know about LEED v4? Test your knowledge with this quiz. We'll reveal the answers next week (hint: some of them are not what you'd expect).

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An environmental product declaration (EPD) is a shortened version of a:

a.    life-cycle inventory (LCI)

b.    product category rule (PCR)

c.    life-cycle analysis (LCA)

d.    corporate sustainability report (CSR)

LEED v4 includes a new credit for:

a.    avoiding certain dangerous chemicals

b.    using products whose ingredients have been reported by manufacturers, even if they contain dangerous chemicals

c.    both of these

d.    neither of these

LEED’s certified wood credit helped bring FSC into the mainstream. Which of the following lesser-known programs is NOT similarly poised to gain in stature through inclusion in LEED v4?

a.    Sustainable Agriculture Network (SAN)

b.    Framework for Responsible Mining

c.    GreenScreen

d.    American High-Performance Buildings Coalition

e.    Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH)

Which of the following would LEED v4 require under a Building Envelope Commissioning (BECx) option for Enhanced Commissioning?

a.    Implement a project specific plan that includes testing.

b.    Review construction document details for continuity, performance, constructability and value.

c.    Perform site observations to coordinate with specific installation of enclosure details.

d.    Verify mock up construction in the field to demonstrate workmanship has been completed.

e.    None of the above

Why would you want to get a BUG rating number if you were working on a LEED v4 project?

a.    You’d want to know how well your seed mixture is rated to perform in providing insect and wildlife habitat.

b.    You’d want to increase the number of Bicycle User Groups you were serving with bicycle racks and routes.

c.    You’d want to know how well an exterior luminaire does in relation to prescriptive requirements for light pollution reduction.

d.    Everyone wants to avoid a Big Ugly Goof—especially when verifying your energy modeling results.

Why has California Section 01350 been removed from the LEED v4 drafts?

a.    Because VOC emissions testing is no longer part of the rating systems.

b.    Because Section 01350 is an inaccurate name for the required VOC testing method.

c.    Because the credit for “no added urea formaldehyde” in certain materials has been removed.

d.    Because wet-applied materials must now be tested for VOC emissions as well as VOC content.

Spatial daylight autonomy is a sophisticated way to model daylighting because:

a.    it looks at available daylight over the course of an entire year.

b.    it includes protection against glare.

c.    it accounts for occupant behavior.

d.    it measures actual daylight levels after construction.

What’s the key difference in the LEED v4 rainwater requirements, versus LEED 2009’s stormwater management?

a.    It’s all in the name: rainwater is a natural phenomenon; stormwater is a management problem.

b.    There’s an emphasis on infiltration through use of onsite hydrology.

c.    There isn’t much of a difference—just updated language.

d.    Swales are preferred over rain gardens.

Acoustic Performance is a new credit in all the LEED v4 BD&C rating systems, but Minimum Acoustic Performance is also a prerequisite in:

a.    LEED for Schools

b.    LEED for Healthcare

c.    LEED for Hospitality

d.    All of the above

What is the big-picture thinking behind LEED v4’s Demand Response credit?

a.    It’s just a big typo—was meant to be “Demand Repose” in support of office employees getting access to nap rooms (two points for recumbent bike racks).

b.    LEED has a long history of paying attention to how buildings fit into their surrounding infrastructure when it comes to location, transportation, and wastewater—but not energy.

c.    Improving bottom-line issues for green buildings.

d.    Bringing LEED buildings up to speed with where a majority of commercial office buildings already are.

How do you think you did? Post your thoughts below as well as your comments on LEED v4! Need to bone up on some of these key concepts? Check out Key Concepts in LEED v4.


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June 17, 2013 - 5:47 pm

The new LEED v4 is intended to be fully applicable in projects outside the US.
I have navigated through the new LEED for Homes v4 credits but I have not found yet how the new rating system will be applicable to foreign countries.
Might there be a guide that explains theses issues and that I have not read yet?

June 17, 2013 - 10:03 am

I have been searching and cannot find when this begins (if there is even a date) I am mostly interested in EBOM. My building is up for recertification and want to know when the cutoff day will be to use 2009?

June 17, 2013 - 11:06 am

From all the information I have researched and from online Webcasts via USGBC the change over will occur in June 2015. So there are (2) full years before v4 would be required. LEED v 4 is still in the voting stage and has yet to be confirmed/instituded for public use.

May 21, 2013 - 2:17 am

I've been wondering about what could be main reasons of the change made in LEED v4 regarding rainwater. If anyone could enlighten me, please share your expertise. As a non-expert, this is my wild guess.
LEED v3 is using 1,2-year 24hr design storm (worst case). It assumes that it's inevitable for runoff to occur. As long as, it maintains or reduces existing condition's runoff volume/rate, it's fine.
LEED v4 is using 95th/98th percentile. Excluding worst cases, project is required to make sure that all of the rainwater should be managed within the site. (what about rainwater falling on the edge of a project boundary?). This requires installation of natural practices such as bio-retention, and for urban projects that can't accommodate such features, it will be hard to satisfy the credit, since building owners don't like dirty ground water to be collected and sent to the water tank in the building.

May 21, 2013 - 11:55 am

Hi Jim,
Building on what Mike describes above, LEED is moving towards the “percentile of rainfall events” methodology because we feel that it paints a more realistic picture of a project’s rainfall conditions. This method is equally effective at managing runoff and controlling TSS, and it has been suggested that it may actually be more cost-effective. Also, the industry has been moving in this direction for some time now.

The v4 draft includes a special path for zero lot line, urban projects. We realize that these projects may have fewer opportunities for onsite LID/ green Infrastructure, thus the threshold is lower.

May 21, 2013 - 9:22 am

Good comment, Mike.

Jim, this is just the kind of thing that LEEDuser sought to elucidate in our report on Key Concepts in LEED v4. I'd recommend it.

May 21, 2013 - 8:38 am

Your 90% storms are generally referred to as your water quality storms. There has been significant research down over the past decade which supports the thought that this is the storm you want to match pre>post. It is becoming more and more common through local regs to infiltrate or retain this delta volume on site as well.

The implementation of the credit will be easy for some jobs, a little more difficult for others, but it is certainly not asking above what is becoming more and more standard practice in the SWM industry.

March 28, 2013 - 3:26 pm

MR credits need to be radically simplified. Below is an example simplification:

"Combine MRcr2, MRc3 and MRcr4 into one credit. Create Option #1: Disclosure (3pts) and Option #2: Material Improvement (3pts).

Option #1 = 10% by cost (at least 5 materials) - Materials have EPD, HPD and/or Cradle to Cradle v2/v3 Silver. (Materials are weighted at 50% if EPD / HPD is not third party certified.)

Option #2 = 50% by cost (at least 10 materials) - Materials are: certified biobased material, certified wood, reused materials, recycled content, certified to have no Benchmark 1 GreenScreen v1.2 hazards, and/or Cradle to Cradle v3 Gold or Platinum certified. (Materials manufactured, extracted and sourced within 100 miles count as 150%.) "

This will eliminate many of the problems with the current writing of these credits such as mixed metrics, requiring certifications that do not exist yet, the vague and contentious "USGBC approved program" language, complicated credit tracking, etc. etc.

March 13, 2013 - 3:32 pm

LEEDuser is hosting a forum devoted to the LEED v4 sixth public comment period, with key links, here. Let's take the v4 discussion there!

March 13, 2013 - 9:41 am

Hey all,

I have been doing a review of the 6th Public Comment Draft of v4 for BD+C and noticed something that seems a bit strange to me. The last sentences in these two credits reads "Commit to sharing with USGBC the resulting whole-project water usage data for a five-year period beginning on the date the project accepts LEED certification or typical occupancy, whichever comes first.This commitment must carry forward for five years or until the building changes ownership or lessee." The part that is confusing to me is the release from the commitment to having to share data if the building is sold or the lessee changes. As most, if not all, of our CS buildings will change ownership once the building is built this commitment really means nothing.

Am I reading this wrong or is it meant to give CS a way out of sharing on-going metering?

February 19, 2013 - 10:48 am

I have read that in order to achieve the LEED AP credit within LEED v4, the project will be requiring APs to be accredited with a "specialty appropriate for the project". My question is whether the format of the AP accreditation will be the same in v4 as v3, or if the specialties will be broken down further, ie. within BD+C into Healthcare, School, Data Centres, etc. I am doubting that this is the case but as I am preparing to write an AP in the next few months I am wondering if there would be any benefits or dangers in waiting for the v4 test to come out.

I could see having a LEED v4 specialist on a project being an asset, but I wouldn't want to do that at the expense of being pigeon-holed into a specialty within a specialty.


March 13, 2013 - 10:27 am

There is a LEED v4 webinar this Friday, March 15 - https://usgbc.webex.com/usgbc/onstage/g.php?d=752827730&t=a - that is supposed to be recorded for those of us who can't attend. Maybe multiple folks can ask the question about when the LEED Professionals exams will switch over so that we can get an answer on the timing.

March 13, 2013 - 10:18 am

I'm sure there will be a switchover at some point, but it has not been announced how that will be handled, or when.

March 13, 2013 - 10:17 am

Has there been any talk about when one must be accredited under v4? Ie. If someone were to wait until December to get accredited do we know if they could still do so under v3, or if they would have to do so under v4.

February 19, 2013 - 11:58 am

Tristan, I agree with your comment. The discussions I have had with USGBC National all point to just having a specialty. Here is what the draft standard says; “At least one principal participant of the project team must be a LEED Accredited Professional (AP) with a specialty appropriate for the project.” So at most I would interpret this to mean that if the project is NC, you should have BD+C specialty, etc. There are no tests to give further specialty ratings other than BD+C, ID+C, EBOM, ND, or Homes. Hopefully someone from USGBC will comment.

Since we will be using v2009 for at least three more years, I would not hesitate to take the test now.

February 19, 2013 - 11:16 am

Tim, I doubt that would be the case.

As far as waiting for the new test, I'd decide that based on whether you are already familiar with LEED 2009 or want to be, and want to be tested on that, or want to study and be tested on the v4 content.

December 13, 2012 - 4:13 pm

Is there a high-level scorecard or graphic that summarizes the updates/changes from LEED 2009 to LEED v4.

We're most interested in EB and NC/CS.

Thanks in advance.

December 13, 2012 - 5:05 pm

Kieran, I believe USGBC had something like this posted on its LEED v4 5th public comment page.

December 10, 2012 - 4:00 pm

It seems the section that my organization wishes to comment on is not open for comment, although that certainly was not clear in our review of the draft. I would also note that trying to submit comments via the USGBC site has been a dreadful experience. See input from the North American Metals Council below:

December 10, 2012

Via Online Submission

The North American Metals Council (NAMC) provides these comments on the latest version of the Leadership in Energy and Environmental Design (LEED) Green Building document, specifically the chapter “PBT SOURCE REDUCTION—LEAD, CADMIUM, AND COPPER.” The title and intent of this chapter should be modified to remove the reference to persistent, bioaccumulative, and toxic (PBT) as a descriptor for the metal substances listed.

Metals exhibit unique characteristics that make it inappropriate to evaluate or characterize metal substances using the general hazard evaluation principles, such as PBT, that are applied to organic chemicals. For this reason, the stated intent of the draft LEED document -- “To reduce the release of persistent, bioaccumulative, and toxic (PBT) chemicals associated with the life cycle of building materials” -- is inaccurate and not scientifically justified if it is to be applied to metals or metal substances.

Characterization of persistence for metals is problematic because all metals and other elements on the periodic table are conserved and hence, persistent -- although the form and availability of the metal can change (thereby affecting its potential bioavailability and toxicity) depending on the environmental conditions. Applying persistence criteria designed for organics to metals, therefore, can result in misleading assessments of potential hazard. A more discriminating approach is needed.

The same is true of bioaccumulation. Unlike organic substances, the bioaccumulation potential of metals cannot be estimated using octanol-water partition coefficients (Kow). For metals, bioconcentration and bioaccumulation factors (BCF and BAF) are inversely related to the concentration of the metal in the surrounding environmental medium and are not reliable predictors of chronic toxicity, food chain accumulation, or hazard. The inverse relationship between exposure concentration and BCF means that organisms from the cleanest environments (i.e., background) have the largest BCF or BAF values, even though they are least at risk of toxic insult. This inverse relationship does not exist for organic substances. Thus, it is counterintuitive to use BCF/BAF and log Kow -- which were originally derived for hazard evaluation of organic substances -- to evaluate hazard and risk for metals.

The U.S. Environmental Protection Agency (EPA) has recognized this and related points in its Framework for Metals Risk Assessment, noting that metals and metal substances must be assessed differently than organic chemicals. Thus, as EPA states in its Fact Sheet on Framework for Metals Risk Assessment, “the latest scientific data on bioaccumulation do not currently support the use of bioconcentration factors and bioaccumulation factors when applied as generic threshold criteria for the hazard potential of metals.”

To avoid confusion and incorrect or inappropriate references to PBT, NAMC recommends that the title of this section simply refer to the chemicals listed, and the intent of the section be removed.

Thank you for the opportunity to provide this input.

December 10, 2012 - 1:59 pm

I was confused to see that I could not post comments for LEED v4 for all of the credits and prereq's I had assembled comments for. Why are some available and some not?

December 10, 2012 - 2:46 pm

Joseph, USGBC is considering some credits more or less final based on previous rounds of comments and revisions having banged them into shape, and doesn't have them all open for commenting. (They are working behind the scenes  to clean up some errors in some of them, though, and I would encourage you to email USGBC with your thoughts, in case they are helpful.)

December 9, 2012 - 5:58 pm

My short answer is “Yes, the current approach to the materials credits is hurting LEED.”

Now that I’ve got people’s blood up, let me explain.

The changes from the fourth to fifth comment draft of LEED on energy and water prerequisites, which were the areas of most concern for me during the 4th comment period, have been pushed into the barest reaches of acceptable.

However, I think the current approach to materials is a train wreck waiting to happen.

I say ‘train wreck’ NOT because of the substance and direction, both of which I think USGBC has correct.

Rather, I believe that the problems will be in terms of administering the system and in terms of market uptake.

If I'm not mistaken, it is the (warranted) wholesale change of the materials section that is principally driving the excessively long (in my opinion) overlap between V4 and V3.

As I have noted in other comments, I believe that fear of losing all credit in the materials categories—even if it is a perceived loss—will keep people locked into V3 until the bitter end of the sunset. If people stay with V3 because of the wholly new materials credits—on top of everything else—then we will have lost out on all of the other V4 benefits: 100% of nothing is nothing.

If the USGBC simply allowed a bit of "backwards compatibility"—just like any smart software company would do—for materials credits, I believe that the whole process could be accelerated significantly.

By backwards compatibility, I mean that the current LEED credits – perhaps with a threshold tweak or two – would continue to be creditable in version 4, but at some fraction, say 50%, of the point credit given in version 3. This allows projects a "pressure relief valve" to begin using V4 and all of the other improvements and increased requirements without having to do everything different at once.

What this might look like:

EPD, Option 3—1 point for Recycled content -- 30% by value

Sourcing, Option 3—1 point for regional materials – 30% by value

December 10, 2012 - 1:28 pm

But why would it 'drive project teams away from LEED'. If the building can't get the credit, or there is no product info to currently support the credit then don't do the credit. The USGBC will soon sort a credit that doesn't get picked up by teams on a regular basis..ACP's being a case in point. (What ever happened to the excel spreadsheet that used to be on-line showing the list of most completed credits against least completed credits) Back in the beginning of LEED we spent half the time reading a credit’s requirements and the asking the USGBC .."..what the devil did you mean by that request". Soon the marketplace picked up...Haworth as ONE example started producing all the details we needed...fluorescent light bulb manufactures dragged their heels…now look what info is available. Things have to change..we have to lead..will it be easy?...no.

December 10, 2012 - 1:13 pm

I am also very concerned about the ultimate willingness and ability of the design and construction industry to be able to meet the new credits. Materials with the required designations are not easily or broadly available now. Unless we see a lot more materials approved and simple and free databases that will allow for easy sourcing of these materials without a massive amount of research, I am afraid that these changes will drive project teams away from LEED.

Architects and owners will not be happy with an extremely limited palette or options to choose from, which will also reduce competitive pricing and drive up costs. While I am totally in agreement with the goals of transforming the materials industry I am very concerned that the USGBC's core constituency is not being sufficiently considered and may pull back.

It also seems a big risk to me, given the economic difficulties that many companies are facing now, to expect that they will pay to have all or even most of their products certified in the next three years. It will not be cheap.

December 9, 2012 - 5:48 pm

What I think would be better for the transition would be to allow an alternative compliance pathway for the materials credits ("Backwards compatibility"-a bit more on this in a separate post) and have an earlier transition date for the whole system.

If we allowed some variation on just a couple of points worth of the current materials credits as alternative compliance pathways in the materials section (I think that the building lifecycle and construction waste credits are enough like the current credits to be recognizable), I believe that we could cut 6-12 months worth of transition time and accelerate the uptake of V4. (Naturally, this presumes that there is aggressive training for ASHRAE 90.1/62.1-2010 and other key new elements of the new system. Ironically, the EQp1 requirements are still stuck in 2004, rather than incorporating all the work on the IAQ procedure done in 2010.)

The ballot could go ahead in June 2013 as planned, the final adoption could happen late 2013/early 2014 & the V3 sunset would happen 2Q/3Q of 2014.

December 9, 2012 - 3:43 pm

Currently, the proposal is to have a very long uptake period for V4: June 2013 for the ballot and end-of-2013/early-2014 for the launch. I understand that early-to-mid 2015 is being talked about as the sunset for V3. I can understand the idea to have a ‘soft start,’ where more and more people are expected to move to the V4 system, resulting in a phase-out of the V3 system.

However, I think that having such a long overlap will be very confusing for the market and will prolong the time where people have to keep two different rating systems in their heads simultaneously.

While the hoped-for scenario might happen, what I think actually WILL happen is that a relatively small fraction of the market (maybe 15-20 percent of the current users, representing 3-4 percent of the market overall) will take up V4, while the vast majority of the market continues to cling to V3 as long as it can.

When the final deadline for adopting V4 looms, there will be a giant pulse of V3 buildings registering at the last second, which will enable people to continue using it for years into the future. This behavior has been exhibited EVERY time there has been a major transition, whether it's a LEED version change or modifications to the AP exam. There is no evidence that this time around it will be any different. Under this likely scenario, we easily could see projects certifying to V3 as late as 2018, which I don’t think will support USGBC’s aims for market transformation.

An alternative way forward will be proposed in the next post...

December 12, 2012 - 11:09 am

Rob, I share your concerns, but understand this may be a by-product of the success of LEED in some ways. It really is already happening. Right now our firm has nearly 80 projects certified, and yet only a few are v2009 right now. There are many in the process of course, but there are many v2.2 projects in the process as well. So in the near future, we will have to keep track of v2.2, v2009, and v4 projects.

We already deal with this a little with building codes, since projects span several years. The big difference there is the codes tend to change slowly. However I clearly remember commissioning a high-rise with a very complex smoke control system while we were designing a very similar building that did not have that kind of system because the codes had changed dramatically.

My hope is two things, first that there are some ways to move up and down in the versions…to try out things like you said in another of your posts. This was done between v2.1 and v2.2. Second, there will be more materials available to help guide teams. The new credit library is a wonderful example of USGBC listening to users and addressing a real need.

So, I do not think you are going to be able to avoid the rush to register you describe, but maybe there are some ways that USGBC can facilitate and encourage migration once that rush occurs.

December 10, 2012 - 11:56 am

OK Rob...time to switch to De-caffeinated coffee…
Your main comment here (long time lag for V3) really has no answer. IF the USGBC put a hard date of January 1 2013..or June 1 2013, there will still be a crush of registrations especially those buildings that are going to recertify within the next 3 to 4 years. That’s good business sense. However running V4 now as a pilot in as many varied buildings as possible is a positive move, there are plenty of companies out there that can absorb the extra over costs to get v4 in-line and are reasonably happy to be the guinea pigs...again.
Another of you’re posts links up with reference guides…here I do believe that the production of reference guides is a ‘dark hole’ that only sees light with the printing of the reference guides…a ‘tough-out, here it is, live with it’. Hopefully the TAG’s will get a chance to review the content before print date to make certain that what is printed actually ties up with what the TAG’s meant to say.
Finally, your comment re ACP’s doesn’t make a lot of headway…I can’t see the point of asking for ACP’s now until credits have actually had a chance to run…after all if the credit isn’t going to fit the building…then don’t attempt it.

December 9, 2012 - 9:54 am

I believe that "The What" (credit requirements) is less important to the success of Version 4 in the market compared to “The How."

By “the How,” I mean the submittal requirements and the tools for delivering them which, as of yet, remain unknown. On some level, it will be impossible to adequately vote on the rating system without a good deal of the "how" being made public.

Since it's unlikely that there are any major substantive changes in approach to the credits in version 4, the argument that "we can't list the submittals until we know what the requirements are" doesn't make any sense.

If you know the basic approach, then you know what the submittal requirements are and the degree to which the credit is met is largely irrelevant when it comes to the tools and support given to project teams try to meet the system.

USGBC and GBCI should include information about the submittal requirements and the upcoming certification support tools in materials released in conjunction with the future V4 ballot.

December 9, 2012 - 9:47 am

In order for successful ballot, I believe that it will be imperative for USGBC and GBCI to let users know in a fair amount of detail how they're planning to address the existing shortcomings in the online tools and other applications being used to submit to LEED.

In my conversations with people at USGBC there is a strong awareness of the shortcomings of the existing tools and ample promises that fixes are in the works. However, I say that it is now imperative that these fixes be made public regarding their nature and the ultimate goal. Even if the fixes not finally ready, it will be really important for people to know sooner rather than later the types of fixes that are being proposed so that the market understands that USGBC understands.

December 8, 2012 - 5:18 pm

For warehouse and distribution centers, SSc8 an Option 3 should be introduced such that if a firm has an established logistics optimization system in place that will be implemented at a new facility, the demonstrated reductions from this logistics optimization program should be recognized.

Such measures could include scheduling optimization, packing material optimization to increase product volume shipped per truck and other such measures.

December 7, 2012 - 3:31 pm

Can anyone tell me how LEED is defining "in a manner best replicating natural site hydrology processes using low impact development and green infrastructure?" In an earlier version it was defined as a "soil and vegetation-based approach." If that is still so, is there a way to achieve the credit in zero lot line buildings in an area such as Manhattan where there is virtually no soil or vegetation or in Miami where the water table is so high it is impossible to infiltrate?

December 11, 2012 - 8:28 am

I had a similar concern about rainwater harvesting for the water efficiency credits, but in the last draft there was a change made that allowed alternative water sources for the WE credits. The WE prerequisites must be through reduction however. So there is something to use your harvested water for. I agree that this can be expensive, especially on larger projects, but can make a dramatic improvement in older urban areas where there is intense pressure on the infrastructure due to combined sewer and storm systems. Using rainwater harvesting systems in these applications in a distributed manor can reduce the need for huge wastewater treatment plants to serve surges during rain events.

December 10, 2012 - 12:38 pm

I still think that it would be helpful to make it clearer that rainwater harvesting is acceptable in the credit language rather than forcing people fo figure it out based on the glossary language. It is particularly confusing because i don't see how rainwater harvesting replicates "natural site hydrology processes" but I am happy to hear that it is acceptable since many projects will find it difficult, if not impossible, to infiltrate. That said, it will be an more expensive proposition for that type of project..

December 7, 2012 - 4:32 pm

Yes, it is listed as an example approach in the LID definition:
"low-impact development (LID): an approach to managing stormwater runoff that emphasizes on-site natural features to protect water quality, by replicating the natural land cover hydrologic regime of watersheds, and addressing runoff close to its source. Examples include better site design principles such as minimizing land disturbance, preserving vegetation, minimizing impervious cover, and design practices like rain gardens, vegetated swales and buffers, permeable pavement, rainwater harvesting, and soil amendments. These are engineered practices that may require specialized design assistance."

December 7, 2012 - 4:21 pm

So to be clear are you saying that it will be acceptable to capture water for reuse (rainwater harvesting) as a way to meet the credit? I don't see that anywhere in the definition of LID or green infrastructure.

December 7, 2012 - 3:59 pm

Hi Pamela,
It is defined the same way as in the previous versions; the definitions have just moved to the online Glossary (while viewing each credit, you can "toggle" the glossary on or off). You can also view the full Glossary here:

A path was actually created specifically for zero lot line projects in urban areas (3 points). The percentile of rain events threshold was lowered to the 85th percentile. The definition you mention above is for "green infrastructure," but projects can also use other engineered practices such as rainwater harvesting.

The v4 Rainwater Management credit language can be found here:

Thank you for your question! I hope this helps.

December 7, 2012 - 1:34 pm

I will be submitting more detailed comments directly to the USGBC. The following are just for LEEDUser feedback:


SS: Heat Island Reduction
Has the USGBC considered making this credit climate zone-specific? In some climate zones, a darker roof actually reduces gross annual energy consumption at the individual building level. It is recognized that this credit has more to do with reducing heat islands than it does with reducing heating/cooling loads on individual buildings. However, there is something to be said for the aggregate, global effect of reduced heating/cooling loads on many individual buildings. A full LCA may even reveal that highly reflective roofs in heating dominated climate zones (e.g. CZ’s 6 and above) may actually contribute more to global warming than the heat island effect of less reflective roofs would. To my knowledge, such an LCA has not been performed to date. It is also recognized that the USGBC may desire to keep the heat island effect separate from the issue of energy efficiency/global warming within the LEED rating system. For example, the USGBC may see the increased energy consumption in individual buildings associated with this credit as a “trade-off” with EAp2/c1 in terms of contributing to global warming. Either way, it would be good to know that the USGBC has considered this issue and has made a deliberate decision.

WE: Indoor Water Use Reduction
Does anyone know why the rating system does not recognize ENERGY STAR as an option for commercial clothes washers?

MR: General Comment
It seems that the shift of using regional materials as a multiplier (instead of a "stand-alone" contributor) does not sufficiently encourage regional materials that do not also contribute to other sustainable product attributes listed in the MR credits. For example, a project using locally quarried stone floors could not receive credit for the "regionality" of the stone for the "Sourcing of Raw Materials" credit as it is currently written.

As an aside, I think that the common complaint about "too much documentation" for these credits deserves attention, but needs to be balanced. For those around when LEED 2.0 came out, how many manufacturers were making recycled content data available? 5%, 10% at most? LEED always has been a market driver and manufacturers will respond as they have in the past (hopefully!).

MR: Construction and Demolition Waste Management
"Option 2. Reduction of Total Waste Material" should make it more clear that diversion from landfills is not a requirement for fulfilling this option (I assume it is not as 2.5 lbs/SF is a very small amount of waste for most projects).

EQ: Interior Lighting
We are concerned about requirement of three lighting levels for individual occupant spaces. Of particular concern are open office spaces with individual workspaces—a growing trend in commercial offices. It is already a challenge to provide individual-controlled lighting for these spaces (often in the form of task lighting at the desk level). It is not clear how multi-level lighting would be beneficial for individual spaces in an open office where task lighting is already available. Moreover, if task lighting is used, the space is, in effect, already employing three levels of lighting (off, ambient overhead lighting, and task lighting). It is proposed that an exception be made to the requirement for multi-level lighting for individual occupant spaces where task lighting is employed as a strategy.

August 26, 2014 - 5:24 am

Hey Jeremy Kuhre I am here to know about EPDM Roofing? Is white form of EPDM is also good for the warmer climate? Like they guys http://www.epdmcoatings.com/index.php say that while form of Liquid EPDM is perfect for the warmer climate to control the temperature? What is your opinion on it?

December 8, 2012 - 1:02 pm

It sounds like LEED is a tough fit for Alaska! Regarding a dark roof's potential to reduce heating loads, you may want to check out: http://www.epdmroofs.org/3.3_Supplement_section_of_An-EPDM-Roof-for-Ever.... Be warned it is an industry whitepaper and high on anecdotal evidence. It does cite one study that used DOE's Cool Roof Calculator that may be worth a look. The paper does reference the fact that roof insulation values have increased by so much, roof color plays a reduced role in energy efficiency (as you also mentioned). Bottom line, I still haven't seen a comprehensive study performed on this question. The concept you suggested of an SRI-based approach to exterior walls is a very interesting one. Again, I'm not sure what all the USGBC has considered in this area...

December 7, 2012 - 9:44 pm

I agree that the heat island credit should be climate-zone specific, as well as other credits (Cooling tower water, for example). I think USGBC should keep the heat island effect separate from the issue of energy efficiency, as you pointed out may be USGBC's desire. The separation of issues and potential synergies and trade-offs are, in my opinion, a very valuable component of LEED.

However, I have to question the idea of using solar gain through the roof for heating load reduction. Unless it is a pitched roof, are you really getting sufficient insolation during the low-angle winter months to use solar gain on the roof instead of a better enclosure? And is that solar gain making it's way through your roof insulation? Maybe it's because my winter solstice noon solar altitude is only 2 degrees, but it seems to me that in heating-dominated climate zones, if you are getting solar gain through the roof in the winter months, then you simply don't have enough insulation in the roof. Am I wrong? (Again, I think I may be very skewed by my zone 8 location).

My climate-zone concern for this credit is that it makes no sense at Latitude 65 to be concerned about SRI values of roof assemblies but not wall assemblies. The solar noon elevation at summer solstice is only 49 degrees in Fairbanks. Well over 90% of the time, the sun is more perpendicular to the walls then the roof (the sun is less than 45 degrees above the horizon). For heat island reduction in the far north, shouldn't the wall SRI values be more of a concern than the roof? I know that we are in a very unique situation, and the reviewers I've spoken with seem very reasonable. I think a clear explanation in the narrative may allow for a wall SRI alternate compliance path, but some credits are simply not applicable to my location.

Can there be a heating-only climate alternative to the Cooling Tower Water use credit? Can LTc4 and LTc5 (Density and Transit) be assessed differently for urban and rural areas? About 10% of the rating system is contained in those two credits, and they are simply unattainable in many rural areas. I support smart growth, but someone has to work on the farms, parks, factories and military bases. There is no reason that the buildings that these people live and work in shouldn’t be high-performing, healthy, sustainable buildings, driven by the LEED process. But the automatic 10% reduction in point potential (among other unique obstacles in rural areas) can be a barrier to LEED uptake in these areas . Yes, some credits are easier in urban environments and some are easier in rural environments. But that only means that we’re missing opportunities to push the envelope in both locations!

Instead of breaking up the rating systems by building type (Retail, Hospitality, Health Care, etc.), I think refinement efforts should be focused on fine-tuning the systems based on climate and urban/rural differences. I understand these are difficult boundaries to define (and climate change and urban sprawl make these group boundaries change through time), but there seems to be much more potential for addressing sustainability needs, realizing market potential, and accurately assessing the "greenness" of a building if you take into account climate and population density.

And the RP credits simply don't cut it! - especially when they are applied across the whole chapter (which in my case spans over 3,200 miles and 5 different ASHRAE climate zones)

December 7, 2012 - 4:44 am

What happened to "Documenting Sustainable Building Cost Impacts"? I don't see it on the latest checklists or on the USGBC website. I may have missed the discussion in earlier drafts - what was the problem with that credit? I think it has the potential to be of great value to both the project stakeholders and the green building community, as a whole.

December 5, 2012 - 4:17 pm

This comment pertains to the LEED ID+C rating system, which still seems to be the little brother left at the grocery store in all this new rating system development.

In credits marked final that we cannot comment on anymore, there are obvious confusing errors such as listing requirements for Schools and Healthcare projects (which are not rating systems in ID&C). Another error that can be found sporadically throughout ID&C is requirements for buildings instead of commercial interior spaces (e.g. MRpr: Storage and Collection of Recyclables – try providing dedicated areas accessible to waste haulers and building occupants for the collection and storage of recyclable materials for the entire building when your LEED project is an office space that constitutes 1% of a skyscraper in Hong Kong…. It’s laughable AND scary because this is a prerequisite.)

My understanding was that v4 was supposed to be simplified and stream-lined, which I am all for. Launching a system with obvious confusing errors is not simplified or stream-lined. I feel very uncomfortable voting “yes” for an ID&C system that will require addenda on day #1 to make sense.

December 6, 2012 - 9:33 pm

Thank you for the feedback in this chain - this is a helpful list of where there are substantive corrections to be made during copy edit. I will note - the PDF documents reviewed as rating system families (BD&C, ID&C, EBOM, ND, Homes) are created only for public comment periods and the base content itself will go through several more reviews prior to balloting next year. Issues like building v. project and tables having additional requirements will be addressed.

While Healthcare and Schools are not part of the ID&C rating system, Retail and Hospitality are so you should expect to see additional requirements called out for them. Extraneous language will be addressed through forthcoming copy edit.

Finally, I'm happy to report that we have a number of CI projects (both within and outside the U.S.) who have enrolled and begun working with the CI (and all other) rating systems through the LEED v4 Beta Program. The purpose is to ensure that substantive issues with the v4 support tools and resources are resolved and that v4 will be of highest quality when launched.

We are excited to share the outcome of this work as well as the work of our internal technical team on the significant documentation streamlining and improvements to the reference guide content.

Thank you for being engaged with the 5th public comment draft of v4 - the comment period is open until the 10th, so please do provide your feedback!

December 6, 2012 - 10:30 am

Hi Susan,

I think that's an optimistic look at things. :) Here are some of the incorrect listings. There are probably more I didn't catch!

LT: Access to Quality Transit - All Options section has requirements for Schools.

WE: Indoor Water Use Reduction - Appliance and Process Water use section has requirements for Schools and Healthcare.

EA: Green Power and Carbon Offsets - Under requirements it lists Healthcare along with the other CI systems.

EQ: Low-Emitting Interiors - In Table 1 there are requirements listed for Healthcare and Schools Projects.

If the USGBC is trying to provide better guidance for HC projects using ID+C guidance - I hope that they will clarify that this is what they are doing. Right now it seems to me that they forgot to copy edit BD+C credits for the ID+C system.

December 5, 2012 - 5:03 pm


What credits reference the HC program? I haven't found any but I have been forgetting my ID+C guide at the grocery store. :) One thought however on what may be going on with the HC references. Hospital renovation work is often directed to use the ID+C guide instead of the HC guide due to definitions of complete building, project boundaries, limited mechanical impact, etc. It may be that LEED is trying to provide better guidance for a HC project using the ID+C guide. Let me know what credits and I'll be happy to read them and offer any of my limited insight.

December 4, 2012 - 2:13 pm

Is this where I should comment on LEEDv4 EBOM changes?

Also, I'm not sure where the best place is to post this comment, but there is an error in the new EBOM checklist. In the EBOM hospitality tab, the MR total does not include MRc5, so it shows only 6 possible MR points, and a total of only 108 points in the rating system. Fortunately, the spreadsheet is not locked, so it is an easy fix.

December 4, 2012 - 2:21 pm

Lyle, yes, you can post comments here or on the USGBC website.

November 29, 2012 - 10:35 pm

This credit signifies a huge step in a positive direction for the building industry. It endorses a hazard-based approach to product improvement, rewards targeted transparency to inform product selection and implicitly acknowledges that EPDs do not satisfactorily address health impacts. However, the credit must be adjusted in order to be implementable by project teams. Suggestions for improvement fall into one of two general categories: procedure or substance.

As noted by Carly Ruggieri elsewhere here, the MR credits are getting quite disparate in their tracking requirements. As it is written, this credit has disparate processes applying to each point for this credit and the point allocation is unclear. The second point should build on the foundational effort by project teams to complete the requirements of the first point. Instead of necessitating a different information set for each, the credit should expand by going deeper with the data already in-hand. The metrics must be identical to standardize communication with manufacturers and allow for clear and uniform tracking procedures by project teams.

The current requirement to document 25% of all permanently installed products used (by cost) is a gargantuan task, and would necessitate researching a majority of specified products to achieve the stated goal. The volume of effort is out of scale with the reward, and beyond what is possible within current market limitations.

Instead, the second portion of the credit should build on the requirements of the first portion of the credit. Since 1 point can be earned for inventorying 20 products, the second point should reward project teams that either document ingredient inventories of more products or demonstrate that a portion of the products already inventoried avoid worst-in-class chemicals. Both of these avenues yield the desired result to “encourage the use of products and materials for which life-cycle information is available and that have environmentally, economically, and socially preferable life-cycle impacts”.

For example, the credit could be restructured as follows:
1 point (total): Inventory the content of 20 products to at least 0.1% (1000 ppm).
2 points (total): Inventory the content of 40 products to at least 0.1% (1000 ppm), OR Inventory the content of 20 products to at least 0.1% (1000 ppm) AND demonstrate that at least 10 of these products avoid worst-in-class chemicals.

One major limitation of this credit is the varying degrees of transparency in the approved compliance paths. As it stands, the credit equally values reporting to the end user (such as with the Health Product Declaration) and reporting to a third party assessor (Cradle to Cradle v2). For project teams to make informed and comparative decisions, it is their right to know the so-called reported information. Fractional contribution of products to credit achievement presents another significant concern from the perspective of quantifying hazard and exposure. Comments are organized by compliance path below:

Cradle to Cradle (C2C):
• C2C Version 2 is not transparent about the standards for its protocol; Version 3 appears much more transparent. The credit should recognize compliance with C2C v3 – not v2.
• With respect to the first point (reporting), C2C v2 certification at the Silver level does not share product inventory information with the end user and has few absolute limits on hazardous content. The credit should require C2C v3 certification at the Silver level together with a published report card that indicates (at minimum) the optimization status of the specific product for each category evaluated.

Health Product Declaration (HPD) Open Standard:
• The HPD supports a range of levels of disclosure and is a good fit as a compliance path for this credit. However, the credit needs to more specifically define the threshold level within the HPD Open Standard that meets the credit intent. As such, the credit language should indicate that the documentation should be a “Complete HPD, with (at minimum) a Full Disclosure of Known Hazards”.

Manufacturer Inventory:
• Since the HPD Open Standard offers a template that mirrors the credit requirements and facilitates manufacturer disclosure in a consistent fashion, it is redundant to include “Manufacturer Inventory” as a separate compliance path.

• The technical requirements for GreenScreen List Translator Benchmark 2 are far greater than those of GreenScreen Benchmark 1. This compliance path should also include an intermediate, more attainable, option. Add GreenScreen List Translator Possible Benchmark 1 as an intermediary valued at 150% of cost. Increase the full GreenScreen Benchmark 2 value to 200% of cost. Under the simpler product count approach outlined above, this would mean that a product whose ingredients all pass GreenScreen Benchmark 2 would count as 2 products toward the 10 product total requirement.
• The credit language should mention that the HPD can document a product’s compliance with this performance-based path.

• This compliance path is highly problematic – it gives international projects a virtually “free ride” compared to those manufactured domestically. This is because the REACH Authorization and Candidate lists are included within and are only a very small subset of the GreenScreen List Translator, (noted as a parallel compliance path for this point). There is no material reason why international projects and products should be exempt from the additional requirements outlined in this credit. To the favor of international project teams, most European manufacturers have already eliminated all of the REACH Authorization chemicals and are also avoiding the REACH Candidate list chemicals if they can.

Fractional Contributions:
• It is imperative that the allowance for fractional product contributions is removed as a compliance path from this credit. Hazard from a toxic ingredient is not necessarily a function of the percentage of content. Consider, for example, that an insulation product with a halogenated flame retardant may only contain 1% or less of that ingredient. The fractional contribution approach results in 99% applied value towards the credit, even though 100% of the product is ‘contaminated’ with a serious potential health hazards for end users.

December 11, 2012 - 10:30 am

The Cradle to Cradle Products Innovation Institute supports the revised structure of the MR section in LEED v4. The improved structure demonstrates a balanced approach to EPDs and encourages transparency, while introducing the concept of optimization.

Our comments focus on edits for the credit language related to Cradle to Cradle Certification as listed in MR CREDIT: BUILDING PRODUCT DISCLOSURE AND OPTIMIZATION – MATERIAL INGREDIENTS options 1 and 2. The recommended edits capture the newly released Cradle to Cradle CertifiedCM v3 standard and clarify aspects of the v2 standard.

The new standard was released in November and is available on our website in its entirety. We will begin certifying under v3 January 1, 2013. Products currently certified under v2 will have two years to continue certifying under v2 but must recertify under v3 beginning in 2015. Newly certified products must be certified using v3 beginning January 1, 2013.

Given the timing of LEED v4, it is recommended that credits related to Cradle to Cradle Certified provide language for both versions.

Option 1: Material Ingredient Reporting

To reward project teams for selecting products for which the chemical ingredients in the product are inventoried using an accepted methodology and for selecting products verified to minimize the use and generation of harmful substances.

Cradle to Cradle v2
The first step of certification in the Material Health attribute is for the manufacturer to provide a complete inventory of chemicals in the product. The bill of materials is then reviewed by an assessor and screened for chemicals on the banned list. Banned list chemicals are not allowed in C2C Certified products at any level of certification. At this stage in the certification process, the product achieves Basic Certification.

For a product displaying the C2C v2 Basic label or above, a specifier can be assured that the product has been fully inventoried, reviewed by an assessor, and screened for banned list materials. The rigor of the C2C inventory process even at the Basic level meets the spirit of the credit. Therefore, we recommend that all v2 Certified levels (Basic, Silver, Gold, Platinum) be recognized in this credit.

Cradle to Cradle v3
In C2C v3, the standard has been modified to recognize the challenges in identifying chemicals throughout the supply chain and to encourage broader participation in the entry levels of certification. The fist step is an inventory of ingredients.

To receive a Basic C2C in v3, the product is 100% characterized by its generic material and does not contain any Banned List substances based on supplier declarations. The C2C Banned List in v3 is much more extensive than the Banned List in v2. Chemicals on the v3 Banned Lists correlate well to GreenScreen Benchmark 1 chemicals. However, the product is not characterized by individual chemical ingredients to the 1000 ppm.

As a product progresses to higher levels of certification, the extent of chemical identification and assessment increases:
• BRONZE: Meets BASIC level requirements + The product is at least 75% assessed (by weight) using A, B, C, X ratings. Products that are entirely biological nutrients in nature (e.g., cosmetics, personal care, soaps, detergents, etc.) are 100% assessed. Assessment includes identification of chemicals that are present at 100 ppm or higher in the product’s materials.
• SILVER: Meets BRONZE level requirements + The product is at least 95% assessed (by weight) using A, B, C, X ratings. Products that are entirely biological nutrients in nature (e.g., cosmetics, personal care, soaps, detergents, etc.) are 100% assessed. Assessment includes identification of chemicals that are present at 100 ppm or higher in the product’s materials.
• GOLD and PLATINUM: Meets SILVER level requirements + The product is 100% assessed and contains only non-X materials. Assessment includes identification of chemicals that are present at 100 ppm or higher in the product’s materials.

For a product displaying the C2C v3 Bronze label or above, a specifier can be assured that at least 75% of the materials in the product have been inventoried, chemicals that are present at 100 ppm or higher in those materials have been reviewed by an assessor, and those chemicals are not present on the banned lists. Suppliers will have also signed declarations stating that chemicals on the banned lists are not present in the material above the designated threshold. Therefore, we recommend that v3 Certified levels Bronze, Silver, Gold, Platinum be recognized in this credit.

Specific Credit Revision Language:
Cradle to Cradle Certified. The end use product has been certified at the following levels:
• Cradle to Cradle Certified v2, all levels Basic, Silver, Gold, Platinum
• Cradle to Cradle Certified v3, Bronze, Silver, Gold, Platinum

Note: Cradle to Cradle Certified products are recertified every year under v2 and every two years under v3. The recertification requirement recognizes that formulations and suppliers change, new research on chemicals may come to light, and that new and safer ingredient options may become available. We recommend adding a requirement that the other paths available in this credit option have a similar re-screening time period.

Option 2: Material Ingredient Optimization

Intent: Use products that document their material ingredient optimization.

The banned list in v2 of Cradle to Cradle was minimal and optimization was achieved through various levels of certification. At the Gold and Platinum levels, products are 100% assessed and there are no x-assessed chemicals in the product. Therefore, we recommend that both Gold and Platinum be recognized at 150%.

In Cradle to Cradle v3, the bar for Material Health optimization has been raised with a more extensive list of banned chemicals that are not allowed at any level of certification. It would be consistent with the intent of the credit to recognize optimization achieved at the Bronze through Platinum certification levels:
• BRONZE: Meets BASIC level requirements + The product is at least 75% assessed (by weight) using A, B, C, X ratings. Products that are entirely biological nutrients in nature (e.g., cosmetics, personal care, soaps, detergents, etc.) are 100% assessed. Assessment includes identification of chemicals that are present at 100 ppm or higher in the product’s materials.
• SILVER: Meets BRONZE level requirements + The product is at least 95% assessed (by weight) using A, B, C, X ratings. Products that are entirely biological nutrients in nature (e.g., cosmetics, personal care, soaps, detergents, etc.) are 100% assessed. Assessment includes identification of chemicals that are present at 100 ppm or higher in the product’s materials. The product contains no substances known or suspected to cause cancer, birth defects, genetic damage, or reproductive harm after the A, B, C, X assessment has been carried out. A phase out/optimization strategy has been developed for those materials with an X rating (X substances may still be present but none considered CMR).
• GOLD and PLATINUM: Meets SILVER level requirements + The product is 100% assessed and contains only non-X materials. Assessment includes identification of chemicals that are present at 100 ppm or higher in the product’s materials.

Specific Credit Revision Language:
Cradle to Cradle Certified. End use products are certified Cradle to Cradle. Products will be valued as follows:

Version Bronze Silver Gold Platinum
V2 N/A 0% 150% 150%
V3 100% 150% 200% 200%