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Review Comments with Phantom Requirements

"Often required by reviewers" is not an appropriate response to a direct question about where this language appears in credit requirements.
Michelle Rosenberger
February 13, 2012

We are seeing more and more review comments with requirements cited that don't seem to exist specific to our project's registration date and/or rating system. Generally, we are able to pose a further question about these comments that reveals that fact. Last week we got a clarification request on our EQpr2 Environmental Tobacco Smoke documentation for a v2.2 residential project. The comment denied our no smoking lease language and referred to 5 bullet points that must be included in a residential lease. We have never seen these 5 bullet points before. They do not exist in the reference manuals for either NC v2.2 or LEED 2009 NC, neither do they appear in any addenda. So we queried the reviewers on this comment so that they could cite the source of these requirements and confirm they apply to our project.

This is the answer that we received. "The five bullet points included in the review comment for EQp2 are often required by a review team when a residential (or mixed-use with residential) project pursues Option 1 instead of Option 3. The intent of the requirements is to, in the absence of the tests and requirements of Option 3 to minimize leakage and exposure in the event of smoking within a residential unit, ensure that smoking does not occur in residential units."

I'm making this posting not just because of the frustrating nature of the issue but because of the quality of this answer. "Often required by reviewers" is not an appropriate response to a direct question about where this language appears in credit requirements. Apparently the reviewer is not able to cite the requirement but still seems to feel it applies to our project. Somehow.     

This is a Prerequisite. And we are left unsure how to respond to the clarification comment. Are we actually supposed to go back to our client, the project owner, and tell them they have to spend time and money to amend their residential lease to satisfy requirements that we can't point to as applying to our project or our rating system? 


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February 13, 2012 - 2:22 pm

Michelle - see the reply to your post at EQp2:

February 15, 2012 - 7:29 am

Yes, Michelle's queston on IEQp2 is addressed on that forum. I am going to leave this forum open, though, and ask if anyone else out there is facing "phantom requirements"? If so it would be great to hear about them in this forum. Perhaps GBCI will tune in and take some feedback on its approach.

April 7, 2012 - 10:47 am

I have a good one for you...I have a CI project in a Hospital that I am told by the reviewer shouldn't be considered a Hospital when submitting my LPD calculations. The review says that since there are no operating or Emergencyyy Rooms included I should consider it a Health Care Clinic...last I checked Nursing Stations and Nurseries and spaces like that are used in Hospitals as well...the big sign on the buildinng says its a Hospital...I guess the reviewers know more than the Department of Health

April 12, 2012 - 10:33 am

Although this is well known on the forum, another Phantom requirement is 8'-0" minimum for Bike paths which applies to SSc4. Why don't they just state that as a minimum?

April 12, 2012 - 11:09 am

They do not state these type of Phantom requirements because they want you to fail in the review. The GBCI claims they are standardizing the reviews but they have so far failed to provide addenda to the Reference Guides to make any of them official.

I am one of the first five LEED APs, helped the USGBC develop LEED NC and CI, was the vice chair of the USGBCs EQ Technical Advisory Group, and have complete several LEED Platinum projects. Still, I have no access to a list of these phantom requirements.

If I was able to crowbar such a list out of the GBCI I would post it so everyone had access to it. It is incredibly unfair to have unpublished requirements that some LEED Consultants seem to have access to but vast majority do not. That provides a business advantage to a few people at the expense of everyone else.

April 12, 2012 - 12:36 pm

Hi Neil -

On the part of the USGBC staff, we appreciate you raising this issue, as it appears, based on your description of the project, that this most likely was a reviewer error. Should this happen in the future, please contact us through the LEED Certification Contact Us form, http://www.gbci.org/org-nav/contact/contact-us/project-certification-que..., with the project number and name so that we can resolve this issue for you. In this instance, I will contact you offline so that we can resolve directly.

Please note that the option to use the LEED Certification Contact Us form is always available to all project teams who have any concerns or requested clarifications regarding any LEED Certification review comments that are made. We strive to provide a fair review that is consistent with published LEED rating system requirements, the referenced standards, reference guides, and LEED Interpretations. At any time you feel the basis for a requirement has not been adequately referenced in the LEED review comments, or that the reviewer comment was in error, we welcome your feedback, and will provide clarification and correct any errors that may have been made.

Megan R/S

April 12, 2012 - 2:20 pm

Neil, that GBCI comment is getting added to my LEED review wall of shame. *awesome*

I do almost exclusively healthcare work, and it's quite clear that many LEED reviewers simply don't understand what our projects are all about. They've frequently told us that strategy X is required for LEED that would be prohibited by code. Your comment, however, takes the cake. I hope you pushed back on that one! (As you probably know, office spaces inside hospitals are still office spaces, but nurse stations and nurseries are definitely hospitals!)

[Follow up note - I must have posted my comment at exactly the same time as Megan did. In response to hers, I will say that all or nearly all of GBCI's wall of shame comments were corrected through communication with GBCI. Most of them were fixed easily, but since the burden of proof is on the team, sometimes this process can be really onerous.]

April 12, 2012 - 1:27 pm

Mara and Neil, We are having the same problems. We do exclusively healthcare work and the USGBC/GBCI does not understand Hospitals, especially ones doing renovation work of existing buildings. I'm currently trying to define a project boundary on the ground/concourse floor of a large suburban hospital. If I strictly apply the LEED definition of separation then the entire conglomeration of 15 buildings, multiple additions and renovations on that level would be in the project boundary. When I look at 2 hour walls as the separation, I can cut it down to half which is only an amount of space equal to the tower above or about 300,000 sf. The original building boundary has been obliterated due to additions and renovations which is common. I'm so frustrated right now, I'm ready to tell the owner to pay the penalty fee to the country for not doing LEED and building it green anyways.

Do not get me started on how lousy the AGMBC guide is for these large Hospital facilities.

Here's my challenge USGBC: you, my projects and myself are all located in the DC area, how about a few building tours and a good plan/code review session. Mara and Neil, you are invited.

April 12, 2012 - 1:37 pm

Susan, I definitely feel your pain on this one. Amorphous growth and evolution of hospital buildings/spaces are pretty unusual across most building types, and the MPRs are not currently written to clearly support that situation. Are you working on an ID+C or a BD+C project?

I have had some success in receiving at least somewhat reasonable feedback from GBCI on complex campus issues via email and/or conference call.

April 12, 2012 - 2:11 pm

I've got a BD+C project that I may go into ID+C soon so I can separate the lowest 2 levels from the upper 11 levels. It may be the least painful way to get it through LEED but the Owner is not understanding why a completely renovated space with new mechanical, windows and roof is not BD+C. The project ticks off all the boxes for BD+C except for establishing a project boundary per LEED. I can make one based on the building and mechanical but can't support it with LEED and MPRs. I've been working through emails and am trying to get a conference call set up (with limited luck right now).

April 12, 2012 - 2:47 pm

Susan, you need to refer to the LEED Guidelines for which system to register under. The 60-40 rule.


If the owner owns or controls 90% of the building and is renovating more than 40% or more of the gross floor area of the interior floor area then LEED NC must be used.

If less than 40% of the area is renovation then you must use LEED CI. Under this case some parts of the project outside the scope-of-work must be included as part of the certification. Energy use using an energy model is the one outside the scope LEED CI credit. If an HVAC system serves and entire floor but only half of a floor that is renovated the entire HVAC system must be considered in the submittal.

Good Luck.

April 12, 2012 - 3:18 pm

Check and check. The problem is drawing the LEED boundary on the lower two levels. LEED requires that the building 'in its entirety' be included in the project boundary for BD+C. My problem is defining the entire building and the project boundary on the very large, contiguous levels.

Imagine a college campus with all the buildings pushed together and being able to walk from one building to the next without reaching a party wall or going outside. That is a Hospital. And we aren't talking about a small amount of space either. The current facility is over 2 million contiguous SF and we're adding on a million more SF and renovating a quarter million SF.

My LEED gut and experience tells me that this is an BD+C project and to draw the project boundary as close to the original project boundary as I can using a combination of 2 hour and 1 hour walls. (Luckily, my smoke compartments are aligning with these rated walls.) I can only find LEED guidance that says no to this approach.

The other thing I would like to propose is a master planning approach to existing Hospital campuses which would allow the Owner to use a combination of BD+C, ID+C and EB+OM to bring their structures up to LEED certification over time. This would require the ability to rate buildings over different versions (ie v2.2 and v3) under a master building/block/what ever.

April 12, 2012 - 6:00 pm

Dear Hernando –

LEED Reviewers, like project teams, are end-users of LEED and access the same publically available guidance documents and databases that are published by USGBC. Their goal is to provide a fair review that is consistent with the published rating system requirements, referenced standards, reference guides, LEED Interpretations and all other USGBC LEED publications. If at any time you feel the basis for a requirement has not been adequately referenced in the LEED Review comments, or that the reviewer comment was in error, we welcome your feedback and will fully investigate the issue in order to provide further clarification or an immediate correction if a reviewer error or oversight has been made. The best way to do this is via our Contact Us page (http://www.gbci.org/org-nav/contact/Contact-Us/Project-Certification-Que...), selecting “Questions about Review Comments” from the drop down menu.

Hernando – while I know that you have already been in touch with us – for other LEEDusers out there, please note that should you also have additional questions after having already contacted us via email (i.e. the ‘Contact Us’ page), we are available for phone calls and/or conference calls. We welcome the opportunity to discuss LEED technical issues with project teams directly, and this can be arranged via our Contact Us page (http://www.gbci.org/org-nav/contact/Contact-Us/Project-Certification-Que...), selecting “Follow Up to Prior GBCI Reply” and checking the “By Phone” option.

Megan R/S

April 12, 2012 - 6:39 pm


I know the process. I am way ahead of you on this issue. I have already discussed the issue directly with GBCI upper management.

LEED Reviewers are not supposed to be end-users if you mean consultants working to certify LEED projects while also doing reviews of their competitors LEED work. GBCI executive management confirmed that consultants working on LEED projects are not LEED reviewers, at least in the last few years. I know that is not exactly true because I have evidence of a business competitor of mine who tried to get a client of mine to fire me and hire them about two years ago. the client turned them down. That same competitor reviewed a project of mine slightly more than one year ago.

I do not know what is true about reviewers and what is not true. I am told one thing when I have evidence of something else is actually going on. Maybe there were too many projects to review at one time for the non-end-user reviewers? Either way an unhappy competitor of mine reviewed my LEED project in the recent past.

June 29, 2012 - 6:45 pm

Hi all,

I really enjoyed some of the stories in this thread. Michelle's in particular. We've had many of the same or similar challenges over the last few years. Generally we've found that if we are positive we are right, we eventually get approved. However, although not always clear at first, we've also found out they (GBCI and reviewers) were right and backed off. By "right," I mean the requirement was buried somewhere we could have found, not that it was clear or obvious.

I am curious if anyone has tracked the review teams that provide the sometimes phantom requirements? I don't want to create a place to complain about reviewers in discriminently, more to share observations about where some teams might need more guidance that we can pass on to GBCI or to be best prepared for teams that are just particularly good at knowing every last detail.

I also wanted to put in a plug for Megan Ritchie. I knew her when she was at Paladino and she is great. I believe her when she says that they (she at least) welcome feedback and are trying to fix inconsistencies.

July 9, 2012 - 5:19 pm

Thanks Elizabeth! Providing consistent, high-quality reviews is of our utmost concern. To ensure that we are always maintaining or improving our quality, we track feedback at both the individual and team level, and use this data to direct targeted training and, as necessary, termination. So yes: please do continue to provide us with your feedback so that we may continue to identify our weaknesses and improve upon them. Megan R/S

May 29, 2013 - 10:21 am

I am regularly being asked in preliminary reviews to provide "optional" signatures. What is the meaning of "optional" if my credits are marked "pending" when I opt to not get the "optional" signatures?

This adds time and thus cost to my projects.

Are LEED reviewers following a check list for a previous version of the form?

February 16, 2012 - 8:45 am

Some commentors are stating that regarding SSc8, Reviewers are asking for vertical calculation points spaced 5' apart. The Reverence Guide specifically states 10'x10' grid spacing for the site calculations. It's a bit vauge about the vertical calculations.

April 13, 2012 - 1:09 pm

Hi Bill -

Thanks for bringing this up.

Regarding grid spacing: The requirement for a 5 foot x 5 foot calculation grid is specific to a submittal requirement listed in the LEED-Schools 2007 Reference Guide which on Page 114 indicates calculations must be done at a 5 foot grid interval. GBCI is aware of this discrepancy between the Submittal Requirements section (page 114) and Calculations section (page 112) of the LEED-Schools 2007 Reference Guide and we are working to resolve this discrepancy. Meanwhile, please note that according to the LEED Reference Guide for Building Design and Construction, 2009 edition, and the LEED Reference Guide for New Construction v2.2, third edition, the calculation grid spacing should be at a maximum of 10 feet x 10 feet (both for horizontal and vertical illuminance calculations).

Regarding vertical illuminance calculations: Often, the vertical illuminance calculations are not requested from project teams as the information provided in a horizontal photometric plan is sufficient to determine light trespass compliance. As a result, the LEED Online SSc8 Form for LEED 2009 only includes exterior photometric site plan(s) as a required upload to demonstrate light trespass compliance. However, the LEED reviewer may request the vertical photometric if for some reason it is not possible to determine compliance based on only the horizontal photometric plan. For example, if there are exterior light poles near the LEED project boundary and the footcandle levels are high near the boundary, the reviewer may request a vertical photometric as additional documentation to ensure compliance is achieved. Please note that the LEED Reference Guide for Building Design and Construction, 2009 edition, requires that the photometric analysis measure both the horizontal and vertical footcandle levels, and as such, the request for a vertical photometric by GBCI reviewers is appropriate. Refer to page 136 in the Reference Guide for additional information.

Hope that helps -

April 13, 2012 - 1:44 pm

Hi Megan,

Thanks for replying. I hope you can understand the confusion and frustration that can occur when a team works on one project and the Credit is approved and then the next project gets a request for additional documentation that is not listed nor previously required.

Vertical calc grids are not simple. Grids are planar while calculation boundaries are often irregular. Each segment of a curved boundary is a separate grid. A project may have 100 vertical grids to cover the whole boundary. And there is zero guidance on what is expected. Or how to display all of these grids so the data is legible. And the pressure to get this correct on the first try since it was requested during the final project review.

And for what benefit? The Reviewers don't seem to understand lighting. I've seen approved submittals with the fixtures oriented 180° from how they were obviously installed and because the boundary showed 0.0 fc no questions were asked. I can make any site show 0.0 fc on every vertical grid at the boundary. So why ask for something that the Reviewers can't interpret anyways? It's only adding paperwork for the sake of paperwork.

February 21, 2012 - 10:56 am

Recently, IEQp2 for EBO+M projects are also requiring additional documentation that is not clearly requested in reference guide or on LEED Online. The issue is that most existing buildings already have 'no smoking'' signage on doors at exterior entries. This used to be acceptable to use existing signage. Now, the reviewers are requesting that we show photos of EVERY entry and that the signs MUST state 'No smoking with 25 feet of building.'

I'm glad to see that this is explicit in the draft rating system for 2012. Even going so far as to specify the sign must be posted within 1- feet of entry.

April 12, 2012 - 5:35 pm

Hi again -

This prerequisite requires a smoking policy and a method of communicating that policy to all building occupants, both FTEs and visitors. The most comprehensive way of demonstrating prerequisite compliance would be a written policy that is provided to FTEs and signage at all entries roughly stating “No smoking within 25 feet.” However, existing signage that only says “No Smoking” - with no specification of distance – does meet current prerequisite requirements. Similarly, while signage can be at main entrances and any exits where the building management has observed violations, there is not an explicit requirement that signage be placed at every entrance. If your projects appears to have been assessed by more stringent standards, please let us know by selecting “Questions about Review Comments” on our Contact Page: http://www.gbci.org/org-nav/contact/Contact-Us/Project-Certification-Que.... In this instance though, I will contact you offline to follow up.

And thank you for noting that project teams should be aware that these requirements may become more strict in the next version of the rating system!

Megan R/S

February 21, 2012 - 11:07 am

Another issue with existing buildings is with previously existing permanently installed walk-off surfaces. This strategy (permanently installed) cannot be earned without manufacturer's documentation demonstrating that the material is designed to effectively capture fine particles. However, it is not requested anywhere on LO; you just have to know to upload it.

Be warned--even if you install this new, you must submit a cut sheet of the product. Also, this facility alteration DOES NOT meet the EBO+M definition of a 'facility alteration' (per introduction of reference guide) and you cannot claim the purchase or new material or recycle of old material in the materials credits. This is disappointing because one building recently went through the effort to install new walk-off carpet but it did not contribute to MRc3, MRc9, nor IEQc3.5 (because the reviewer asked for cut sheet in final review). Clearly a disappointment to project team.

Really there is no standard for 'carpet performance' and removable mats are never questioned. It seems that a regular cleaning schedule is more important than the type of carpet, but that information is not requested either.

April 12, 2012 - 5:31 pm

Hi Alyson -

Thanks for bringing up these several points. I've tried to address them each separately, in hopes of not missing anything...

Statement: Another issue with existing buildings is with previously existing permanently installed walk-off surfaces. This strategy (permanently installed) cannot be earned without manufacturer's documentation demonstrating that the material is designed to effectively capture fine particles. However, it is not requested anywhere on LO; you just have to know to upload it. Be warned--even if you install this new, you must submit a cut sheet of the product.

Response: This credit requires entryway systems that are capable of capturing dirt and other particulates as users enter the building. Depending on the project’s climate, some mats may not provide capture dirt and particulates year round, due to reaching a saturation point with heavy rains or snow. Page 454 of the 2009 LEED EOBOM Reference Guide provides criteria for appropriate mats in the second, third, and forth paragraph of Section 4. Implementation. While there is no prohibition on using existing systems - and manufacturer’s documentation is not a required submittal - if a project team submits documentation that appears to show a mat that does not meet these criteria (i.e. a photo that appears to show a standard carpet mat for project in a very wet climate), the Reviewer may request additional information demonstrating that the entryway systems are capable of meeting the credit requirements of capturing dirt and particulates.

Statement: Also, this facility alteration DOES NOT meet the EBO+M definition of a 'facility alteration' (per introduction of reference guide) and you cannot claim the purchase or new material or recycle of old material in the materials credits. This is disappointing because one building recently went through the effort to install new walk-off carpet but it did not contribute to MRc3, MRc9, nor IEQc3.5 (because the reviewer asked for cut sheet in final review). Clearly a disappointment to project team.

Response: A minimum quantity of facility alteration or addition is required in order to attempt MRc3 and MRc9, to ensure that achieving these credits has a meaningful environmental benefit. Once that minimum is met though, any and all materials used for facility alterations - including the installation of walk-off grates - can be included in these credits.

Statement: Really there is no standard for 'carpet performance' and removable mats are never questioned. It seems that a regular cleaning schedule is more important than the type of carpet, but that information is not requested either.

Response: Please see above and note that the Credit Submittal Form does request a narrative on the cleaning strategies used by the building.

I hope that helps -
Megan R/S

April 12, 2012 - 11:26 am

A new unpublished mandatory requirement for LEED NC is that if the project includes any lease spaces non-mandatory Tenant Green Guidelines must be provided to the future tenants.

The above occurred on a project with less than 10% lease spaces. The spaces included HVAC VAVs and were core and shell spaces. The worst case occupancy and usages were assumed when the spaces were included in the LEED points submitted: Bikes, Parking, Energy with No Efficiency Claimed for Lighting, Ventilation, Water Use, Construction IAQ Practices and Testing. Everything was covered for what is in the scope-of-work for the project.

Evidently, the above is not enough. The LEED NC v2.2 and 2009 Reference Guide make no mention of a mandatory requirement to provide Tenant Green Guidelines. During a conference call with Sarah Alexander of the GBCI, she confirmed that this a clear requirement for any project with any amount of core and shell space. She based the requirement on LEED interpretations from 2004 and 2005 that were for Core and Shell projects using LEED NC as the rating system rather then LEED CS.

It doesn't seem to matter that our project is LEED NC. Evidently these guidelines have been required of all LEED NC projects, apparently since 2004. I have worked on over 100 LEED NC projects and this has never been demanded.

Tenant Green Guidelines are an optional credit for LEED CS. To earn the credit the Guidelines must be part of a lease agreement. For LEED NC the phantom requirement is for Tenant Green Guidelines is not optional and they are not mandatory.

Has any one else been subject to this new phantom requirement? I want to find out if the GBCI has forced ALL LEED NC projects with any amount of CS space to provide Tenant Green Guidelines.

April 12, 2012 - 12:04 pm

Hi Hernando,

LEED Interpretation 5232 supports this requirement and is applicable to NCv2.2 and v2009 projects. By applicable I mean that the LI database indicates that project teams and reviewers may refer to the ruling for projects using NCv2.2 and v2009, if reasonable and appropriate.

April 12, 2012 - 12:23 pm

Yes, that interpretation is about how to earn an Innovation Credit using Mandatory Green Tenant Guidelines. It was posted in 2009 long after the project I discussed was registered. The project did not apply for an ID credit at any time.

We were told by the GBCI that an ID credit can not be earned based on an interpretation from 2004. The interpretation you listed states otherwise.

Regardless of whether you pursue an ID credit, it is now mandatory, per the GBCI, to include non-mandatory Tenant Green Guidelines for any LEED NC project with any amount of Core and Shell space. Earning and ID credit is not possible according to the GBCI per a conference call I had with them on 04/11/2012.

April 12, 2012 - 12:51 pm

Yes I'm aware that's its mandatory now, and I'm not sure why the LEED Interpretation 5232 was filed under the Innovation in Design section. The inquiry states "This is a general guidance Credit Interpretation Request, not specifically addressing ID credit." Anyway, this particular LEED Interpretation applies to all NC v2.2 projects registered on or after 9/2/2009 with unfinished tenant spaces, and the reviewer can choose/is supposed to apply it to all NC v2009 projects. There may be other LIs published earlier that established the same or a similar requirement. Check the Applicability tab under the LEED Interpretations the GBCI has referred you to. The tab indicates which rulings were written specifically for projects using a particular rating system and therefore must be applied based on the project's registration date.

April 12, 2012 - 1:14 pm

Looks like you have a mistake that you are trying to impose without correcting the mistake.

There are no LIs with a mandatory requirement to provide non-mandatory Tenant Green Guidelines for LEED NC projects. If you can find one please post it and the applicable date.

Please make sure the LI you look for is not the infamous parking structure that was 100% core and shell and was certifying under LEED NC. In that odd case, yes Tenant Green Guidelines should have been required, should have been mandatory, and an ID credit should not have been earned. That project should have been LEED CS with an option to provide the guidelines as allowed by that system. LEED CS evidently was not available to that project when it was registered. So, the LI properly stated what that odd project needed to do for a LEED NC rating.

That project is infamous because it appears to be one of the reasons that there is a new special rule to prevent such a project for earning any LEED rating unless the amount of occupied space meets specific requirements.

April 12, 2012 - 1:17 pm

As stated above, LEED Interpretation 5232 (9/2/09) requires, for LEED-NC projects, that for unfinished tenant spaces, tenant guidelines must be established ensure that future build-outs will meet the prerequisites and credits that have been pursued. The ruling was written for projects using LEED-NC v2.2 and must be applied based on the project's registration date. Project teams and reviewers may refer to the ruling for projects using LEED v2009 system, if reasonable and appropriate. This is a general guidance LEED Interpretation, not intended for Innovation in Design credit.

April 12, 2012 - 1:31 pm

All v2.2 CIR were voided after being incorporated into the v2009 Reference Guide. This CIR would only be applicable to v2.2 projects registered after 9-2-09.

April 12, 2012 - 1:47 pm

The project was registered long before 2009. The LI would not apply. Yet is incorrectly being applied to this project.

The LEED NC 2009 Reference Makes no mention of tenant guidelines except for core and shell projects.

It is interesting to read the defense provided by a LEED project reviewer for a requirement that is being imposed that is not properly documented.

April 12, 2012 - 2:05 pm

Hi Bill,

LEED Interpretation 5232 may also be applied to v2009 projects at the reviewer's discretion, as indicated by the single check mark under the Applicability tab. Many of the v2 CIRs were 'recycled' as LEED Interpretations that 2009 project teams and reviewers can apply to their projects. In some cases LEED Interpretations (formerly known as CIRs) may not be applicable to a project depending on the rating system used, but this will be noted in Applicability tab under each LI.

April 12, 2012 - 2:09 pm

At the reviewer's discretion? What are the rules for reviewer's discretion?

April 12, 2012 - 2:13 pm

Hi Hernando,

Your first post states that GBCI based the requirement for your project on LEED interpretations from 2004 and 2005 that were for Core and Shell projects using LEED NC as the rating system rather then LEED CS. My suggestion to you was to check the Applicability tab associated with the LEED Interpretations the GBCI has referred you to. The tab indicates which LI rulings were written specifically for projects using a particular rating system and therefore must be applied based on the project's registration date. I have referenced LEED Interpretation 5232 as an example in an attempt to dispel the belief that tenant design and construction guidelines are a 'phantom' requirement. :)

April 12, 2012 - 2:19 pm

Hi Hernando,

A single check mark under the Applicability tab for a particular LEED Interpretation indicates that "Project teams and reviewers may refer to the ruling for projects using this rating system, if reasonable and appropriate." In the case of LEED Interpretation 5232, a reviewer will apply this ruling to NC projects registered after 9/2/09 if s/he discerns from the submittal documentation that an NC project has unfinished tenant space.

April 12, 2012 - 2:40 pm

This is a LEED NC v2.2 project not a LEED 2009 project. There is no applicability tab for LIs.

The 5232 LI was not applied to the project. The old LEED CS as LEED NC CIRs (LIs) were applied to a project that is not LEED CS. More than 90% fully built out than has 100% of the project is included in all of credits as required: Lighting with no efficiency claim, ventilation and water use at maximum spaces type occupancy. Everything was included to certify 100% of the building.

You haven't made a good case why a project that includes everything that is required to certify 100% of a LEED NC project plus a small amount of LEED CS spaces must provide non-binding tenant guidelines. The non-binding is meaningless, and the GBCI staff acknowledge that is meaningless yet it must be provided because a reviewed used their "discretion" to create a review issue.

April 13, 2012 - 11:27 am

I received confirmation this morning from Sarah Alexander of the GBCI that non-binding Green Tenant Guidelines are required for all LEED NC projects with CS areas regardless of when the project was registered. Any amount of CS space triggers the requirement.

The GBCI stated they ary considering adding this requirement as an MPR for LEED 2009. If it doesn't get added as an MPR it will still be enforced.

There you have it, straight from the GBCI management: A requirement that will likely remain an unpublished requirement.

April 13, 2012 - 12:01 pm

Green Tenant Guidelines are non-binding, but...

To earn the water efficiency credits the a mandatory requirement must be enforced on the tenants to either not install any plumbing fixtures related to the LEED water use credit, or if stub outs are included a mandatory lease requirement must be provided to install plumbing fixtures at least as efficient as what is installed in the base building.

This phantom requirement continues to evolve as I write this.

April 30, 2012 - 3:32 pm

I heard from Sarah Alexander, and she was concerned about being misquoted here. She provided the following information to me.

Just to clarify, the issue of unfinished spaces within LEED 2009 projects has been addressed by LEED Interpretation #10102 that was published on 11/1/2011 for MPR#2 which incorporates guidance on how to treat unfinished spaces in LEED 2009 projects, into the Minimum Program Requirements.For information purposes, you can see the following historic CIRs/LEED Interpretations that reference the need for non-binding tenant guidelines for NC v2.2/v2.1/v2.0  projects that include unfinished spaces (note this is not an exhaustive list of LEED Interpretations, merely illustrative examples):

LI 3900 (historic NCv2.0/NCv2.1 admin CIR of 2/22/2005)

LI #2595 (NC v2.2 7/29/2009) and LI#5216 (NC v2.2 7/29/2009)

LI #10027 (NC v2.2 5/9/2011)

LI #5255 (NC v2.2 4/20/2007)

LI #1868 (NC v2.2 8/27/2007)

LI#1968 (NCv2.2 12/19/2007)

LI#5232 (NC v2.2 9/2/2009)

April 30, 2012 - 5:34 pm

To further clarify what happened and my quoting of Sarah Alexander.

All of the LIs are dated after the registration date of the project in question. Every single one.

The GBCI did provide any clearly documented reference that Tenant Guideline were required for all NC projects registered before 2/22/2005.

For the first LEED review (combined design and construction) no LIs were referenced. Only a requirement without a foundation basis. The LIs were not identified until the second review. No opportunity was provided to refute the source of the TI guideline "requirement."

The only applicable reviewer basis made was LI 30013 (2004 vintage) which is in regards to a 300k SF parking structure, with 20k of CS space, evidently 0k of NC space and was certifying under LEED-NC. A very odd LEED project. Not at all related to a project more than 90% occupied by the owner with the TI spaces fully accounted for in the submitted documentation.

The reviewer also quoted LI 3900 but not until the second review where it was impossible to claim the applicable date was after-the-fact.

The GBCI ended up with tenant guidelines that required non-efficient, code minimum plumbing fixtures. It is odd to earn LEED WEc3 points for NC-v2.2 and enforce green tenant guidelines, encouraging tenants to pursue LEED-CI, that would prevent a tenant from meeting a prerequisite under LEED-CI 2009.

This oddity has to do with the fixtures a tenant could install, kitchen sinks, and not what the base building provides (full restrooms). Only the restroom fixtures were water efficient for the project, not kitchen sinks.

April 12, 2012 - 3:56 pm

In another thread on this page, a LEED Reviewer mentioned being able to apply v2.2 "LEED Interpretations" to v2009 projects. That did not make sense to me. After digging around for a bit it appears to be allowed. And this may be a source of many phantom requirements.

I'm wondering why? There was suppose to be a clean break in LEED Interpretations between v2 projects and v3 projects. USGBC came up with the "addenda" thing to issue offical changes for v3 updates and modifications. Now we seem to be back to having to hunt thru Interpretations for any possible applicability to the current project.

The example given was #5232. Issued 9/2/09. When I search the GBCI database it shows up. And apparently there is a tab called "Applicability", (that doesn't look like a tab until after you click on it). And sure enough it says it may apply to New Construction v2009 projects.

But I don't know it exists unless I'm told it exists. If I do my due dillagence and search for the key word "Tenant" and filter the search to the rating system "New Construction v2009" and the category "Energy and Atmosphere" I only get (15) results that show up. Not one of them is this #5232. (Only 3 are dated after July 1, 2009 so the other 12 should not have even shown up in a search)

If USGBC wants to use the "addenda" format for updating v2009 requirements then only use addenda. Let's try to keep everyone playing from the same rule book.

April 13, 2012 - 11:40 am

In December of 2010 a LEED project that was certified as Gold was denied the Lighting Controls credit because task lighting was not provided at copy and fax machines.

The reviewer claimed that the machines were work areas that required task lights. The machines were provided in a internet room provided by the owner for temporary use by residential tenants. Regardless, the reviewer stuck with their demand and denied the credit.

I helped write the task lighting requirements for this LEED credit when I was the vice-chair of the LEED EQ Technical Advisory Committee. I know what was and what was not intended. Only one project of mine out of 100 has every had this demand made.

Has anyone else ever run into this?

May 5, 2012 - 9:51 pm

I have documented LEED projects since the dawn of time. Well, at least since the first certified NC v2 project that was not a special test case: Ford Premier Automotive Group NA vs. PNC Firstside Center. I also helped develop LEED CI and was vice-chair of the LEED IEQ Technical Advisory Group for several years; unpaid volunteer positions.

At least back when I was helping develop LEED NC v2.2 I can state for an absolute fact, that what the Technical Advisory Groups develop for LEED had no bearing on the final requirements that somehow appear in the LEED Reference Guides, the Forms (Templates), and the reviewer cheat sheets. The rating systems yes, but not the details below.

I also tell you that I was told by the USGBC VP of LEED (long gone), when I complained that requirements the Technical Advisory Group had drafted had been tossed and haphazardly been rewritten without the following the LEED development rules, something to the effect: "You are an Advisory Group only. We (the USGBC) do not need to use what the Groups develop. We have outside consultants paid to develop technical content."

Figure out who those outside consultants are and I am certain you will find them heavily involved today inventing new LEED requirements. Some of those consultants likely still work on certifying their own LEED buildings. LEED Consultants were working on their own LEED projects, writing Reference Guides, developing Forms and Templates, and reviewing their competitors LEED projects. In the past this was the case, and it appears to still be the case with the exception of reviewing LEED projects.

Unfortunately, if my thoughts about how these hidden requirements get invent are true, then we don't get to find out about them until the LEED Review. Others know about them, and use them to their advantage, long before you learn they even exist.

July 6, 2012 - 1:24 pm

We are being required to prove that adjacent buildings will not use our bike racks. This is not a LEED requirement. I can see where the reviewer is coming from because the building is located on a campus, but the building is still and individual project, with individual certification. It seems unfair to arbitrarily add LEED requirements. I could not find this requirement anywhere in LEED guidance.

This requirement is applicable to all projects where it appears that the facilities may be shared. We regret an inconvenience that documenting this requirement may cause, but would like to remind you that there are two options for demonstrating compliance. 1) A statement, signed by the building/property Owner or manager, may be provided to verify that the use of the bicycle storage facilities is exclusive to the occupants of the project buildings and signage provided to so indicate. Or, 2) Documentation, such as revised site plans and supplemental calculations, may be provided to demonstrate that sufficient bicycle storage facilities have been provided to serve all occupants, including occupants that are not part of the project, with access to the amenities.

July 6, 2012 - 1:46 pm

Just more new review nonsense from the reviewers.

It appears that the reviewers are insisting that the multiple-building rules (AGMBC) must be used for any standalone LEED project on a campus.

What if the campus is a large university? Are the reviewers demanding that a LEED building more than 200 yards from a non-LEED building prove that the non-LEED building occupants do not use the bike racks provided for the LEED building? Oops, "reviewer discretion" used to justify this type of demand seems to have missed a major part of the requirement; bicycle storage and showers must be within a certain distance to be claimed.

Previously, I have seen new demands about LEED NC is a "whole building rating system" which is being taken as a demand to document parts of a project not only outside the scope of work, but that are inconsistent with the LEED 40:60 certification rules which helps determine which rating system should be used to certify a project that could be under two LEED systems.

The 40:60 rule means of a project is 40% one LEED system type (NC, CI, CS, etc) and 60% another system type, then the project is free to use whichever LEED rating system they choose. But, what is happening is if you pick LEED NC and are partially LEED CS you are required to follow optional credits in CS as mandatory in LEED NC. The reviewers shoe-horn the CS credits into LEED NC credits the project is pursuing.

This review nonsense absolutely has to stop. There are no published rules provided by the USGBC for the GBCI and LEED users to follow. The Reference Guides have become useless. You now have to guess what the project requirements are, and worse, could possibly be.

July 6, 2012 - 3:03 pm

To be fair, there is another campus building (probably within 200 yrds) of our bike racks. That project is also going for LEED certification, but they are under a different design contract, we are not part of their design or LEED pursual.

Regardless, it is still not a LEED requirement for an individual building to accommodate other buildings outside its scope. What is even more frustrating is discovering these additional requirements late in the game after design work is done and construction started. Maybe the owner would have been willing to accomodate this requirement or have picked a different location for the racks, or whatever. If we could just have known about this early in the design before submitting for certification.

July 6, 2012 - 3:27 pm

The text below is from the AGMBC, dated October 31, 2011. This was more than likely released after your project was registered for LEED. To invoke the AGMBC you have to create a Master Site as defined by that document.

You haven't created a AGBMC LEED Master Site. You are not required to. Yet, the requirements are being imposed on your projects. Worse, these requirements were created late last year, meaning they shouldn't be applicable.

LEED campus boundary:
The site area defined as the LEED project boundary for all campus credits. This may be the legal limits of the shared site (e.g. property boundary) or an alternative boundary for LEED purposes. The LEED campus boundary must be a single unbroken site, unless the non‐contiguous parcels meet the conditions stated in the MPR Supplemental Guidance.

LEED Project Boundary:
The portion of the project site submitted for LEED certification. For single building developments, this is the entire project scope and is generally limited to the site boundary. For multiple building developments, the LEED project boundary may be a portion of the development as determined by the project team.

July 6, 2012 - 4:35 pm

While I agree with Hernando that the AGMBC does not have to be implemented just because your project is on a campus, I also see the poorly stated review comment EH's project received. When it comes to site amenities like bike racks, i believe that the GBCI is trying to ensure that they are not counted twice. This has forced me into understanding our clients overall sites and accounting for things repeatedly. For example, I have a bike rack in front of a non LEED building with a capacity of say 8 slots. This non LEED building would take 5 slots if it were LEED (yes, running FTE calcs for a non LEED project). For my adjacent LEED project, that left 3 slots I can count for that project. For the third project that is also LEED, I'm out of racks and have to add them into the project site. But when I document, I run them through the math all over again including FTE information for all 3 projects. It is a pain but now that i know, it is done and done consistently.

July 6, 2012 - 5:05 pm


I am doing something similar for a complex campus project. There are four primary buildings. One is not LEED. Two are LEED NC v2.2 which are my LEED projects. One is LEED NC 2009 by a different LEED Consultant. We cannot use the LEED Online AGMBC documentation path because it is restricted to LEED v2009 only. Instead I am providing common LEED documentation for all three projects, making sure the most strict requirements for the two versions of LEED NC are met.

Long ago --about 2-years-- I decided that the right thing to do to get around the ever changing reviews was to document the entire campus.

We have a total campus occupancy FTE count, with visitors as well as retail customers. We have distributed the bike slots based on estimated usage of each of the four primary buildings.

Not only have we included bikes, but did the same distribution and allocation for carpool parking for SS Credit 4.4 and similar for low-emitting vehicles.

I expect to run into trouble for the location of parking for green cars for SS Credit 4.3. The vehicles are owned by the owner and are parking in an interior secure parking lot. The vehicles are in closest parking spaces to the three LEED buildings but there are closer parking spaces to the the non-LEED building. The trouble with the closer spaces is that they are intended for employee parking which are outside the secure lot.

The two projects will be submitted for review in the next month. I will fill you all in on the results. The owner is pushing for three LEED Platinum projects. We'll see how it goes.