LEEDuser’s Guide to Key Changes in LEED-EBOM 2012 – 3rd Public Comment
Several key changes are proposed for a new structure for the LEED-EBOM Rating System in 2012. Most significantly, prerequisites and credits now have an Establishment component and a Performance component. In the Establishment portion of the credit, project teams are asked to establish a foundation that the credit will rely on, for example, to develop a policy. The Performance part will request that project teams show evidence of an activity (i.e. a survey, audit, or testing) or ongoing tracking. The intention behind this new structure is to simplify and clarify the recertification process.
In addition to the usual upgrade with the latest standards and higher compliance thresholds, LEED-EBOM 2012 will include a handful of new prerequisites.
Additionally, there is now a suite of LEED-EBOM rating systems with requirements that are tailored to specific project types, including Schools, Retail, Data Centers, Hospitality, and Warehouse & Distribution Centers.
Some new credit categories have been proposed through the various versions of public comment. However, some have not made the cut in the third version. The proposed Integrative Process and Performance categories are no longer part of the rating system. The new credit category that did stick is Transportation and Location. The category includes only one credit, Alternative Transportation Commuting (a credit previously in the Sustainable Sites category). Also, in an attempt to streamline the credits, several related credits have been combined.
Location & Transportation (LT)
The new LT category for EBOM consists only of a lonesome relocation of Alternative Commuting Transportation (1-14 points) from SS to LT. The credit is mostly recognizable from its v2009 form, but there are some significant changes highlighted below.
Major Changes in LT
The biggest change with this credit is that the baseline is no longer 100% single-occupant vehicle (SOV) commuting trips. Instead, the baseline is based on the national average of SOV trips for the specific building type. For example, the baseline for office buildings is 85% SOV, whereas at the other end of the spectrum, the baseline for college classrooms and administration is 40% SOV.
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So this credit just got more stringent for all buildings and particularly for buildings like hotels, schools and colleges. In addition to the modified baseline, the alternative commuting trip types are no longer weighted equally. The most highly weighted alternatives are human-powered trips and public transportation, and low-emitting, fuel-efficient vehicles are the lowest-weighted alternative trips.
Minor Changes in LT
As for minor changes, the performance (point) thresholds have been modified slightly, and you can earn a point just for conducting the survey. But the net difficulty related to the point thresholds is still more or less the same as v2009. Also, note that there is an alternative compliance path specific to retail projects.
Currently, the credit language does not outline specific steps for the Establishment and Performance phases, so it’s a bit unclear how often the survey will need to be conducted after the initial certification.
Sustainable Sites (SS)
You’ll be familiar with most of the SS section, as it retains many of its familiar faces, including heat island, light pollution, and site management, although some areas have been combined into single credits. Also, we see the introduction of a sustainable sites prerequisite with the Site Management Policy outlined below.
Major Changes in SS
The most notable change with the SS section is the establishment of a new prerequisite and the departure of SSc4 Alternative Commuting Transportation (v2009) over to the LT section. The prerequisite involves establishing a Site Management Policy that more or less covers the same components of SSc2 and SSc3 from v2009. Project teams in the past struggled with the build-your-own metrics aspect of the v2009 credits, and this version attempts to put clear parameters on what performance is required and how it is evaluated. One addition to the mix of maintenance equipment, cleaning chemicals, fertilizer, etc. is maintenance practices to ensure optimal operations of irrigation equipment. The site management policy is adopted in the Establishment period, and there is no Performance activity or tracking associated with the prerequisite. Performance requirements for site maintenance activities are now in the associated credit for site maintenance.
Another big change with the sites credits is that Stormwater Management is re-branded as Rainwater Management (1–3 points) and comes fresh with new performance criteria for managing rainwater on the site. Specifically, the credit requires implementation of 2 of 5 available strategies ranging from low-impact development (LID) practices to rainwater capture and reuse to a rainwater filtering system. The new credit criteria appear to be more stringent than their v2009 precursors and may prove to be more meaningful measurements of environmental performance.
Lastly, Site Improvement Plan (1 point) has been added as a new credit that investigates and establishes a five-year plan to improve the hydrology, vegetation, and soils on the project site. All low-cost and no-cost measures must be implemented for the Performance component of the credit.
Minor Changes in SS
Protect or Restore Habitat (1–2 points) has been modified a bit and will be more stringent now that native and adaptive vegetation is required for 20% of the entire site area (including the building footprint). The off-site option has been re-framed to provide financial support to an off-site area equal to the total site area with some additional stipulations to require for the first time that off-site locations be within a certain geographic range of the project building (within the same EPA Level III Ecoregion or state as the project building).
Heat Island Reduction (2 points), including both roof and non-roof strategies, has been combined into a single credit but is pretty much the same as in v2009. A couple small changes: the non-roof hardscape surfaces are assessed by their solar reflectance (not SRI), and the SRI requirements for the roofing material now include criteria for the 3-year aged SRI value in addition to the initial SRI value.
The Light Pollution Reduction (1 point) credit remains mostly the same as v2009 with some slight modification to the shielding option for exterior lighting. But if you were watching the changes through the second round of public comments, there is no longer an option for “appropriate personnel” to turn off the interior lighting at night. The only option now is for automatic controls, like with v2009. In practice, this has usually meant that teams skip this credit and don’t add exterior shielding even if they can, unless they happen to already meet the interior criteria (it is easy for new buildings that were built to code that require automation, but expensive and impractical for a lot of older buildings).
The Site Improvement Plan (1 point) credit brings the concept of energy auditing to the building site, with components of documenting conditions, evaluating options for improvement, and prioritizing low-cost and no-cost measures. The idea here is to get project teams to take a longer view of site sustainability, given that the typical EBOM project might last a year or less and revitalizing site infrastructure is a long-term project.
Water Efficiency (WE)
The Water Efficiency category has upped the ante with a new prerequisite, Building-Level Water Metering. The previously proposed third water prerequisite requiring Outdoor Water Use Reduction has been dropped in the third draft for public comment. Other increased thresholds and additional requirements make the WE category credits slightly more difficult than they were to achieve before. A proposed prerequisite and credit for Appliance and Process Water Use Reduction have officially been done away with in the third round of public comment.
Major Changes in WE
The addition of the new prerequisite, Building-Level Water Metering, stresses the importance LEED-EBOM places on knowledge of a project building’s water consumption. Under this version of the rating system, project buildings are required to install permanent water meters to measure total potable water for the project building and grounds. This is most likely to present a challenge to buildings located on a campus. Points can still be achieved by metering of water subsystems via the Water Metering credit (2 points). Both the prerequisite and the credit require that the whole-building and subsystem meter data be shared with USGBC for at least five years.
The new, more difficult baseline criteria for the Indoor Water Use Reduction prerequisite and credit (4 points) will increase the required amount of cost and work associated with retrofitting and replacing new plumbing fixtures and fittings. This version of the rating system establishes the water use baseline by the date the building received a certificate of occupancy: for projects with a certificate of occupancy from 1995 or later (increased from 1993 in v2009), the baseline is 120%, whereas for buildings older than 1995, the baseline water use is 150%. These seemingly minor changes can add up to many thousands of additional dollars in required retrofits for older buildings to comply.
According to our analysis of one real project building (Class A urban high-rise built before 1995), changing the baseline from 160% of EPAct to 150% only increases the water savings by 10%, but increases the costs of complying with the prerequisite by 33%. Given that fixture water use is by no means the main source of consumption in most commercial buildings, LEEDuser wonders if this ratcheting up of the threshold makes as much sense as a cooling tower water use prerequisite would. Consider running your current projects through a scenario that uses a 150% baseline instead of 160% to see the impact on costs and savings, and comment to USGBC accordingly.
If you are going for Option 2, which calls for a baseline based on actual metered data, and then a reduction from that, it is now required that the baseline be reset every ten years for recertification purposes.
The Indoor Water Use Reduction prerequisite also now requires that all existing fittings and fixtures be inspected to confirm they are operating properly, and that a fixture and fitting replacement and retrofit policy is implemented that specifies WaterSense-labeled products are actually installed (versus the v2009 requirement for an economic assessment policy). Older piping can sometimes restrict the fixtures that may be installed. We expect that project teams will experience challenges in the implementation of this credit with the new baseline for older buildings.
Also notable are the new requirements for Cooling Tower Water Use (1–3 points) requiring a one-time potable water analysis measuring at least a specified list of five control parameters and then calculating the number of cooling tower cycles to determine the level of compliance.
Minor Changes in WE
The proposed requirements for Outdoor Water Use Reduction (2 points) have not changed significantly, except that fewer points are available (5 points were available under v2009).
Energy & Atmosphere (EA)
Changes to the v2012 EA section include a familiar but more stringent energy performance prerequisite, the inclusion of a new demand-response credit, and the departure of the building automation and emissions credits. Also, energy-related credits like commissioning that were located in the PF section for round 2 public comment have been moved back to the EA section.
Major Changes in EA
The changes to Minimum Energy Efficiency Performance solidify this prerequisite’s status as the gatekeeper for the LEED-EBOM program. The prerequisite requirements have been beefed up to a minimum Energy Star rating of 75 for ratable buildings or better than 75% of similar buildings for those not eligible for an Energy Star rating. The basic mechanics of documenting compliance appear to be the same as those in v2009, and maybe what’s most notable about the prerequisite is that an option included in the 2nd round of public comments that offered an alternative compliance path for buildings to demonstrate a 20% improved performance over their historic baseline has been removed. Removal of that option plus the heightened minimum Energy Star rating guarantees that the maximum total market share for LEED in the existing building arena is limited to just about a quarter of all buildings.
New to the EA section is Demand Response (1–3 points) This credit has been piloted with v2009 projects and appears to be very similar to the pilot credit.
Minor Changes in EA
The Existing Building Commissioning credits (investigation & analysis – 1 point, implementation – 2 points, and ongoing commissioning – 3 points) are similar to what we’ve seen with v2009, except that it appears that the energy audit path and the commissioning path have been merged so that you have to conduct both commissioning activities and an ASHRAE Level II audit in the investigation & analysis phase. The implementation is mostly the same as v2009 with the addition of seemingly firmer requirements around tracking and verification. The ongoing commissioning plan credit also provides more prescriptive documentation required for the Performance component.
The Advanced Energy Metering (1 point) credit has been simplified a bit and now requires that all end-uses that consume at least 20% of the annual energy use (minus plug loads) have to be metered and logged continuously. Also new are requirements related to tracking peak demand in the building over time.
The Green Energy Production and Utilization (1–5 points) credit (formerly on- and off-site renewable energy) remains mostly the same except that off-site renewable energy offers fewer point opportunities, and now carbon offsets can cover both electricity and fuels. Also, Refrigerant Management is nearly the same for both the prerequisite and the credit, with the exception that there is a new and potentially simplified path for the enhanced refrigerant management credit in addition to the old v2009 option.
Materials and Resources (MR)
Most of the changes in the new Materials and Resources credit category are due to restructuring and the new materials requirements that have evolved with LEED 2012 across all rating systems.
Major Changes in MR
An Ongoing Consumption Policy has taken the place of the v2009 Sustainable Purchasing Policy and the Solid Waste Management Policy. It requires that the policy address the purchases covered in both Purchasing – Ongoing Consumption and Purchasing – Facility Alterations and Additions, where new requirements and standards reside. Notably, in addition to addressing target goals for Solid Waste Management, it also requires that an audit be conducted of the building’s entire waste stream (this is no longer a choice!). Performance is confirmed by either pursuing Solid Waste Management – Ongoing Consumption, or by conducting a waste audit annually.
The first step to achieving the new Purchasing – Ongoing Consumption (1–4 points) credit is to identify the to five ongoing consumable products that are purchased consistently. Then at least 60% of the total ongoing consumables (defined as the top five products purchased consistently as well as paper, toner cartridges, binders, batteries, and desk accessories) must meet the established criteria.
However, the new established criteria make this credit a bit trickier to achieve. For one thing, food purchases are now included in this credit (but would only be relevant if a food item were a top-five consistent purchase). Additionally, many of the new materials criteria align with those in the new BD&C rating systems, which now address issues such as where and how raw materials are mined, quarried, grown, and harvested. These new materials requirements are a departure from the structure of the last few versions of LEED. The credit also requires that at least 40% of electric-powered equipment purchases meet EPEAT Silver (higher than previously required Energy Star), or if not covered by the EPEAT standard, Energy Star. The tracking of an already-difficult-to-track credit seems to be getting even harder.
The requirements for Purchasing – Facility Alterations and Additions (1–2 points) have been completely overhauled to align with the new BD&C materials purchasing criteria. A second point can now be earned for purchasing furniture that meets the prescribed standards, such as BIFMA.
Minor Changes in MR
Although a new prerequisite, the new requirement to develop a Facility Alterations and Additions Policy seems less difficult than others. The policy addresses construction waste management, indoor air quality guidelines during construction, and creating a plan to evaluate whether a flush-out or air quality testing is needed.
Solid Waste Management – Ongoing Consumption (2 points) now includes ongoing consumables as well as office equipment, appliances, and audiovisual equipment (electronics waste). It also requires that a waste audit is conducted at least every five years, or if occupancy changes are greater than 20% of the gross floor area.
Solid Waste Management – Facility Alterations and Additions (2 points) has not changed significantly, except that furniture now must be included in this credit.
Indoor Environmental Quality (EQ)
The EQ section includes most of the same basic content as with v2009, but there have been some notable mergers and acquisitions, including the long-awaited union between the green cleaning policy and the formerly separate high-performance green cleaning program. Also, the walk-off mat, CO2 outside air monitoring, and MERV 13 filtration credits have all been grouped into a single credit, Enhanced Indoor Air Quality Strategies.
Major Changes in EQ
No major changes to the EQ prerequisites have been made, but some smaller modifications include the updated ASHRAE 62.1-2010 ventilation standard, a couple of minor additions to the green cleaning policy, an option to demonstrate ongoing performance by contracting with a third-party-certified cleaning contractor, and required signage for the smoking prerequisite. Also, some happy news for multifamily and hospitality projects: air leakage testing will not be required for non-smoking residential or hotel guest units.
Other important changes are that the Interior Lighting (1–2 points) credit has been expanded to include an additional point for projects meeting lighting quality requirements. LEEDuser’s take on the lighting quality criteria is that evaluating them in an existing building, especially with multiple tenants, will be beyond the ken of the typical project team, and that bringing in a lighting designer to retroactively evaluate lighting design won’t be an attractive proposition.
The Daylight and Quality Views (2–4 points) credit has been modified to include “quality of views” criteria. In the Green Cleaning credits, there are now additional standards, including Design for the Environment (DfE), and ionized water has been added to the old Green Seal and Environmental Choice standards. The cleaning product purchasing performance threshold has also been raised to 75%. Also, the green cleaning equipment and custodial effectiveness audit credits have been modified with higher performance thresholds.
Minor Changes in EQ
Many of the EQ credits remain substantially unchanged, including the Thermal Comfort, Indoor Air Quality Management Program (IBEAM), Integrated Pest Management, and Occupant Comfort Survey.
The point allocation for the Innovation credit is confusing. It’s hard to tell exactly how many points can be earned for what. However, in addition to Innovation and Exemplary Performance strategies in the previous LEED-EBOM Rating System, LEED Pilot Credits from the LEED Pilot Credit Library can now officially be pursued.
For the LEED Accredited Professional credit, only one LEED AP is required; however, the LEED AP must have a specialty most appropriate for the project type.