LEED v4 Public Comment Forum - LEED Takes a New Direction

I find a lot to like in the new LEED MR Credits (MRc2, 3 & 4 Building product disclosure and optimization). The credits take new important steps to encourage EPR (Extended Producer Responsibility), responsibility for resource extraction practices, CSR reports (Corporate Social Responsibility), certification of the sustainability of agricultural based materials and content disclosure and toxics reduction. These begin to fill what have been some important gaps in LEED’s approach to materials.

The Material Ingredients credit (MRc4) addressing content disclosure and toxics reduction represents a critical leap in forward LEED attention to health issues in materials. The USGBC deserves strong support for this important credit and will need reinforcement against the ongoing American Chemistry Council attacks on this point.

That said there are many devils in the details, including some greenwash loopholes big enough to drive a project through and we need the USGBC to go further. I’ll cover my questions and suggestions for the #2 EPD and #3 Sourcing credits in this comment and follow up in the next day or so with a comment just on #4 the Material Ingredients credit

MRc2 – EPDs: Option 1 Published EPD credits the industry average EPDs (1/2 credit for products that participate in an industry wide (generic) EPD) that look to me like a great opportunity for greenwash – with poor performing products being able to hide behind the industry average. Recommendation: Put a short one year limit on receiving the ½ credit for participation in the industry average EPD exercise. After that you’ve got to disclose the product specific EPD.
I am also very concerned about whether PCRs for EPDs are being developed in a consistent fashion and are actually going to be comparable. I’d welcome commentary from others who are watching the PCR process development closer than I am.
Option 2 Multi-Attribute Optimization gives credit for certifications that verify impact reduction below industry average in at least three of six EPD categories. More room for greenwash. This needs boundaries and more explicit guidance! A product could benchmark slightly below the industry average in three relatively inconsequential categories (where the industry has generally low impact already) and be a worst performer in the industry in the other three and still get the credit.
Extended producer responsibility – I support the inclusion of this in LEED but think this would make more sense in MRc3, the sourcing of raw materials credit, as EPR is an important part of making recycling programs work.

MRc3 - Sourcing of Raw Materials: Option 1 – raw material source and extraction reporting - Yes we need attention to environmental impacts of extraction operations and beyond, but there is much more room for greenwash here. This credit needs lots of work to insure that meaningful and applicable CSR reporting requirements are referenced. Recommendation: add specific language about what kinds of commitments are acceptable and about the applicable CSR formats. At minimum they should encompass consensus principles that have been developed. (i.e. the Framework for Responsible Mining). This credit could use more scrutiny from someone who knows a lot more about CSR reporting formats.

Option 2 - leadership extraction practices: Keeps FSC only, and rewards recycled content, reuse, and certified biobased materials (but only with one program). I guess they haven’t been able to find any leadership in mining either. Suggestion: Stay firm on FSC! And add more agricultural standards to the mix for the biobased. Working Landscapes, Global Organic Textile Standard and even USDA Organic should be in the credit along with any other program that meets ISEAL or IFOAM standards. And lets include EPR here.

I would like to comment on Fundamental and Enhanced Commissioning…again. While these are similar to what I said for the 3rd and 4th drafts, since they were not addressed, I would like to make them again and hope some will make additional comments here to show either support or critique of the prerequisite and credit.

Fundamental Commissioning:

1. The design review should not be moved into the Prerequisite, as it needs to be completed by a third party, while retaining the ability for a lower scope Cx process for the prerequisite.

2. Requiring envelope information in both the OPR and BOD are very good steps as a requirement in fundamental, but the design review of same should be moved to Enhanced.

3. Please make sure that a more complete description of who can be the CxA is developed for the reference guide. The language of Fundamental appears to exclude hiring an Enhanced CxA that might use portions of the design team to do field testing, something that does happen as long as the independent CxA direct the whole process.

4. The document titled Current Facilities Requirements and Operations and Maintenance Plan appears reasonably defined, and I assume replaces the old Systems Manual required in Enhanced Cx.

Enhanced Commissioning:

5. The design review for both energy using systems and envelope should be moved to Enhanced.

6. Why would the Systems Manual still be required under Enhanced while it is described under Fundamental? This seems to be a duplication of the Fundamental document, and makes it unclear who does this work.

I agree with Jeff @ Tahoe that the EPA radon zone maps are so out of date and misleading that they should only be used as a last resort. Many municipalities, and states have much more current maps that are based on two decades of testing and are much better guides. All that needs to be emphasized is wording such as that below for a much more useful credit requirement.

"SECTION 1201

RADON POTENTIAL ZONES

1201.1 EPA established zones.

The radon potential of a building site shall be estimated from the United States environmental Protection Agency radon potential map as shown in Figure 1201.1 or from United States Environmental Protection Agency radon potential by county listing as shown in Table 1201.2. Where state or local jurisdictions have published radon potential data, such data shall supersede the information in Figure 1201.1 and Table 1201.2."

The USGBC should use current, local and accurate radon maps in determining areas of high radon risk. Just because the EPA published a national radon map by county 20 years ago, does not mean it is the final authority on radon risk potential today. Many states and localities have produced more accurate and more recent radon risk maps and they should be used by the USGBC when and where available.

The American Association of Radon Scientists and Technologist (AARST) a leading radon industry professional group, states in it's recent revision of the Radon Resistant New Construction RRNC 2.0 consensus document:

"SECTION 1201

RADON POTENTIAL ZONES

1201.1 EPA established zones.

The radon potential of a building site shall be estimated from the United States environmental Protection Agency radon potential map as shown in Figure 1201.1 or from United States Environmental Protection Agency radon potential by county listing as shown in Table 1201.2. Where state or local jurisdictions have published radon potential data, such data shall supersede the information in Figure 1201.1 and Table 1201.2."

I can't speak for all states, but I know that in California, one has only to look at the California Geologic Survey's radon web site (http://www.conservation.ca.gov/cgs/minerals/hazardous_minerals/radon/Pag...) to find 18 localized radon maps either completed or under development. These readily available radon maps and surveys should be used (where and when available) by the USGBC in establishing high radon risk areas and the 20 year old EPA national radon map should only be used where these more recent maps do not exist.

The LEED Certified Wood Credit, with its preference for FSC, has been a part of LEED since the beginning and has been one of the most important drivers for market transformation to sustainability in the forest products industry. For those of us interested in maintaining that driver, the most recent draft of LEED v4 presents a mixed picture, with both positive and problematic elements.

First, this draft retains exclusive recognition of FSC among forest certification systems. USGBC is to be strongly commended for maintaining its commitment to the leadership standard in forestry in the face of ongoing pressure from the mainstream forest products industry and its allies.

However, major portions of the MR section, including the principal credit affecting FSC-certified wood, has been rewritten, picking up elements of previous drafts but also venturing into new territory. The scope of change is surprising given USGBC’s stated wish to go to ballot in the summer of 2013 without making further substantive modifications (which would necessitate a sixth draft and comment period).

The problems with the current draft are substantial and should in fact require a sixth draft.

Positives:

1) FSC remains the only reference standard for new wood.

2) A placeholder remains for encouraging the development of FSC-style standards for non-bio-based materials.

3) The exemption from responsible extraction requirements for materials that are sourced locally (within 100 miles) in the previous draft, which created a loophole for concrete, has been removed.

4) Preliminary analysis suggests that many paths to achieving the performance-related point in the new “Building Product Disclosure and Optimization – Sourcing of Raw Materials” will need to include FSC-certified wood along with recycled-content materials, and that there will be an incentive to go beyond 50% of the wood being FSC-certified, rather that arbitrarily stop there, as some teams do currently.

Negatives:

1) FSC-certified products now qualify for only 1 point, and the award threshold is so high that projects are unlikely to earn it without also incorporating large quantities of recycled-content and/or reused products.

2) Because there are fewer points available overall (2 in the previous draft, 1 in the current) and reference to an audited checklist of the leading edge issues in the Framework for Responsible Mining has been eliminated, the incentive for developing FSC-style standards for non-bio-based materials is less powerful and specific than before.

3) FSC products, which meet a rigorous, multi-attribute performance standard with third-party auditing and chain of custody across the value chain, are weighted the same as products backed only by manufacturer claims for single environmental attributes like recycled content.

4) The new “Building Product Disclosure and Optimization” credits place as much emphasis on disclosure as on performance, awarding 1 point for products that have Environmental Product Declarations, 1point for products whose manufacturers develop Corporate Sustainability Reports that may or may not meaningfully address responsible materials extraction, and 1 point for products backed by Health Product Declarations. Half of the available points reward disclosure of certain environmental impacts related to products (no matter how bad the impacts are) rather than rewarding products that are verified as meeting high performance thresholds.

The intent of LEED-ND’s Location and Transportation Credit “Access to Quality Transit” (I will call it "AQT" for short - this is formerly SLL Credit 3: “Reduced Automobile Dependence”) is to “encourage development in locations shown to have multi-modal transportation choices or otherwise reduced motor vehicle use”. This seems a clear directive, but based on commonly understood transit route planning priorities for effective service, the methodology of the credit is at odds with this intent.

This credit will award LEED-ND developments for locating at least half of their dwelling units and nonresidential building entrances within a quarter mile walk distance to existing local transit stops or a half mile distance to rapid transit or commuter service stations (effectively). It is noteworthy to notice, first of all, that while the walking distances, or “pedsheds”, are in line with commonly held transit planning standards established to help effectively space stops for these route types in urban areas, the stop spacing itself is not a concern of the credit. Many transit planners will find the omission surprising.

What ultimately awards the project points are not the actual number of dwellings and building entrances within walking reach of the stops, but the percentage of them as a proportion of the total provided by the development. Shouldn’t awarding projects for putting adequate density of dwellings and uses in existing coverage areas be rewarded straightforwardly to meet the intent of the credit? Note that projects with extensive areas outside of the walking distances will therefore be incentivized to lower density in those areas. The past provision to lower the qualifying overall coverage percentage for large projects has also been removed and is now rigidly set at 50% of the total. The actual numbers of dwellings and uses placed within the coverage area is therefore not as important as the coverage percentage, a somewhat dubious priority in meeting the intent of the credit.

What determines the amount of points earned for AQT is the total number of daily trips serving each of the stops. While this can reward the proficiency of the service in terms of its frequency and/or span, these daily trips are summed in aggregate for all the stops. It does not matter at all if all or some of the stops are serving the same route. Thus, the more stops in or near the development, the more the number of “daily trips” you amass, regardless the number of actual distinct transit trips serving the development. In effect, what is predominantly being rewarded here is not frequency and span but coverage.

Of course, I do believe the number of distinct daily trips serving the development is appropriate to enter into the point value calculation, but this should be measured in terms of actual numbers of daily transit trips serving the development, thus rewarding a transit line’s frequency (short headways) and/or span (service duration, another critical aspect of transit’s usefulness).

While the points can only be awarded in AQT for the stops of existing service lines, apparently, there is nothing to prevent a project team from seeking to divert existing routes and/or adding more stops to them than necessary. My talks with technical experts in this forum make all too evident the coverage fixated priorities in the thinking behind AQT. The credit requirement to locate near existing service in the first place, for instance, has surprisingly little to do with the need prevent a project team from plotting to introduce ad hoc and poorly planned service lines designed to just benefit the development. According to Eliot Allen’s findings, the LEED-ND Core Committee primarily wanted to ensure that habitual use of transit formed immediately from the outset of occupation (apparently it is a worry that people will not otherwise discover en masse the benefit of transit when it comes to them).

In effect, AQT does not appropriately value the diverse goals that are important to transit’s usefulness and that are actually all-important in changing the habitual transport choices of the occupants of the LEED-ND development. Ultimately, the mobility of all the users of the routes passing through the development (not just the mobility of the LEED-ND development’s transit users) is at stake here, threatening the healthy operation of a high quality urban transit network. The latter in particular is what is needed more than anything to support habitual use of transit.

In short, AQT’s fixation is all in the coverage of the service, not the effective service and the effective density of population and uses within walking distance. Sadly, the system still does not reward transit service effectiveness apart from coverage and amenities. This focus on the amenity of transit (versus a respect placed on the purposes of transit service) betrays an often unnoticed preoccupation among urban designers and architects that detracts from efforts to plan the high quality transit services needed to actually replace auto trips. Such things that a development could help implement, such as signal prioritization, Kiss and Ride or bikeshare stations near transit stops, dedicated lanes, and convenient connections are very important to transit utilization.

Instead, think of the actual incentives presented to the project team. To achieve LEED-ND credit for AQT, the more stops they manage to include the better also their prospects will be to reach at least 50% of the project’s dwelling units and building entrances within the stated walk distances. It’s all or nothing to get to that 50% qualifying threshold, however, before the project can rack up points. If it means adding a stop or tweaking a line to do so, the development team is going to strategize for a way to do that, especially as they plan or rework the street grid. The potential for diluting an infrequent service by expanding its coverage area throughout the development is nearly inevitable. Routes like that would erode the overall quality of the transit service and thus dis-incentivize auto use reduction in the end not just among the development’s potential ridership base but for the existing users of the entire transit line or greater transit system! Unfortunately, those are exactly the kind of routes that can get LEED-ND developments lots of points.

What this means is that only an alert transit agency can prevent a LEED-ND project from mucking with existing transit service! While I would hope transit agencies are competent enough to prevent project teams from doing so, my experience suggests that some agencies are either far too accommodating to development teams or don’t value transit network effectiveness as much as they should. Granted, depending on the areas served, some agencies will want to reward coverage goals as much as LEED-ND does, and in those cases this credit may be a benefit to them (even though in all cases the agency should value effective stop spacing – as I mentioned above, this is not necessarily an incentive presented by AQT). But in other cases, if not the majority of cases, agencies will have the integrity of the transit network and other service goals in mind that will require them to prevent coverage expansion. As a matter of fairness, the project located in such locations should truly be rewarded for putting adequate development density within walking reach of existing transit. That development should under no circumstance be penalized for the percentage of its development that is developed in locations outside the walking distance coverage area.

My recommendations for improving the credit are as follows:

(1) Remove or greatly lower the 50% percent minimum dwelling unit / building entrance walking distance coverage requirement. This threshold is, in truth, meaningless at such a high percentage. For the purposes of satisfying the intent of AQT, NPD Prerequisite 2, Compact Development, will ensure adequate density near all existing stops. Removing the 50% coverage threshold (or lowering it to no greater than 20%) will largely remove the great incentives presented to project teams to muck with existing service lines. If the goal is increasing the density in the coverage area beyond NPD Prerequisite 2, then increase the minimum density totals required or enter density levels into the point calculation methodology used in AQT.

(2) Do not allow the summation of daily transit trips to be summed in aggregate for all the stops but reward the total number of distinct daily trips serving the development, thus rewarding number, frequency and span of routes directly and thereby not disproportionately rewarding coverage.

As an alternate strategy to no. 1 above, keep the 50% coverage requirement but require project teams to provide documentation from the local transit agency that states that the routes are not only conforming to but improving that agency’s service goals for the routes serving the development. Here you will be better ensuring that LEED-ND rewards transportation planning strategies and plan layouts that actually improve transit route performance. As well, consider allowing project teams to expand the coverage area beyond the walking distances by adding amenities near stops that address the “last mile problem” such as adequate secure bike parking facilities, vehicle share or Kiss-and-Ride parking, and bikeshare stations. Since these amenities actually augment the ridership base of transit service without impacting the performance of the existing service itself, allow project teams to consider these coverage augmentation strategies in lieu of the 50% coverage requirement. For example, if 50% of dwelling units and building entrances are within a one mile bikeable distance of a stop with bike lockers and a bikeshare station, then the coverage area calculation of that stop is allowed to include the dwellings and/or building entrances in the bikeable distance area.

NSF recently accepted a claim by Celceram that their fly ash product - widely used in carpets is post consumer recycled content. I think this is outrageous as do several other certifying bodies and at least one carpet manufacturer. Looks like LEED will need to tighten up their definition of post consumer recycled content to stop this greenwash. See more on this at http://www.pharosproject.net/blog/detail/id/144/from-smokestack-to-floor...

This comes at an interesting time just as USGBC has added significant new material credits to LEED V4 that address toxic content and that highlight responsible sourcing of raw materials. The sourcing credits start to put the kind of spotlight on the impacts of agricultural and mining practices that the FSC credit has long put on forestry practices. An excellent move IMHO. I've got critiques of how they are structured now that I'll post soon, but the direction is great.

Maybe it is also time to take a close look at the sustainability of recycling practices too and adjust LEED credits to incent those products that facilitate true closed loop recycling and avoid the production and recirculation of toxic materials.

Based on two previous discussions elsewhere on this forum, I've recently become aware of a facet of SLL Credit 3 that may be harmful to transit service outcomes, and I am wondering if there is an opportunity to comment. While I can't speak for transit planners, I'm pretty sure many will take issue with the methodology employed by the credit and regard it problematic from several vantage points.

I realize this credit is closed to public comment for the fifth round, but I'm wondering if there is any opportunity to do so. I regret missing out on the opportunity to comment and suggest potential ways to improve the credit.

First, I want to congratulate the USGBC on all the progress it has made in developing a more complete tool that more-than-ever reflects what it takes to make a green building. This clearly was not an easy process.

Nonetheless, for any such process to work, it must be used by those who will have the most impact on making our current building inventory more green. I wish to focus my remarks on existing buildings, as they represent well over 90% of the current building inventory, and with the economy being what it is, the number will increase.

The people who will make existing buildings more green are both the building owners and their facilities managers. The owners must pay for any changes, and the FMs must find a way to make them happen; they also must identify which changes they will find most practical.

It is clear to me that some with FM experience were likely to have served on the committee that developed the new LEED v4. But was the FM community adequately represented so that a betting person would gamble that the FM community will embrace the new LEED v4 enough to make a serious impact on energy consumption and the environment? Are the changes such that FMs will be willing to take the time and money to understand them and even implement what is necessary to earn LEED certification?

The answers to these questions will depend on how the FM community has been involved in developing the new LEED v4. in my opinion, the group is important enough to warrant a special focus group dedicated to FMs to address these types of questions. Besides having such a focus group, it is essential that such a group be comprised of those who have the right blend of knowledge and experience. All too often, I have seen such groups contain members who have had some FM experience or who have consulted or offered other services to FMs. For purposes of this discussion, these experiences are not the FM experiences that is needed, as these people are not in a position to have to find the time and money to implement these initiatives. For that to happen, the group needs to be served by those who actually manage buildings (and their budgets), and have done so for many years; even better are those who have managed multiple buildings, as they can offer the experience of what it takes to many different building types, not just one.

Has the USGBC had such a dedicated committee? If not, I plead with it to seriously consider it, even if it pushes the timeline back a bit. Because without the strong support of the FM community and their probable willingness to seek new LEED certification, the new LEED v4 will have been a very imformative exercise, but will not succeed as fully as intended in terms of making a major positive impact on the environment.

Hi,

Have a wondering regarding the LT credit, Green Vehicles within the 5th Public Comment periode.
Does the project need to fulfill both the requirements regarding 7 % for green vehicles and one of the option, for example Electric Vehicle Recharging.

Thanks in advance!
Best
Tanja

I am an architect who has been building super sustainable houses since well before LEED existed. I have 2 LEED Homes under my belt and many others that could have been LEED but were either built before LEED Homes or the clients did not want to pay for certification.

I have not begun to review v4 But I have so many comments about the USGBC that I would love them to address before they even get to 'points'.

About a year or 2 ago I reached my tolerance limit in dealing with the USGBC and I emailed everyone of importance at the USGBC (I figured out emails after hours of investigation). I got a flurry of emails and very concerned phone calls after that but nothing has changed. Here are my complaints:

1. The web-site world of LEED is a nightmare. It takes hours to find what you need, get where you need to go or even comprehend the overall organization. I have created websites and am very computer literate and I find it an absolute field of chaos. Are we seriously paying for this? If the USGBC were a small non-profit I would forgive them. This however is unforgivable.

2. The USGBC refuses to credit Architects in their data base and in general. Architects! we are the USGBC's biggest constituency by far! Please help me out by getting pissed at this. When you go to search a LEED certified project in the data base, you can search by location, Contractor or LEED Provider. NeEver is the architect mentioned. When I finally got the ear of the 'big wigs' at LEED 2 years ago they asked 'Why would we mention the architect?' OMG. I was flabbergasted. Do they have literally zero comprehension of what is going on in their own building industry? Are they truly clueless to the fact that most building projects are guided and steered and conceived by architects?!?!? On most of my super green projects I have to TRAIN my contractors and cajole them into doing things right and then THEY get recognition with the USGBC. UN-BE-LIEVABLE.

3. The last LEED home I did which got LEED platinum -one of 2 or 3 in CT- has all of the wrong info logged in its data base!!!!!!!!!!!!!!!!!!! Wrong architect. Wrong address, Wrong points. I have tried very hard to get someone on the phone to correct this and NO ONE WILL CALL ME BACK OR DEAL WITH THIS. Again!!!! I AM PAYING FOR THIS!!!!!!!??????????

WHY bother with LEED on any level if not for the bragging/ marketing rights. I am not a charity. I am not here to feed money into a huge marketing machine that brings in billions for the ownership and makes their own employees pay an exorbitant amount (for example) to go to the annual conference- never mind the fees we all have to pay to be a member or become a LEED AP. (Which at this point I refuse to do.)

I do not think LEED certification is a joke (like many of my fellow super sustainable old school green building industry peers do.) I find it a totally excellent tool to help train my residential building clients in sustainable design and to ensure that basic aspects of the project are met to get the best results possible. I applaud it for that.

I am - quite obviously- not impressed with the rest. I am appalled honestly at the half-assed, slipshod nature of the organization. And I am not renewing my membership until someone calls me and until my project is fixed in the database and until architects are acknowledged.

I don't see responses to the 4th Draft. Anyone know where to find them?

good stuff tristan - thanks for making this more fun!