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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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May 17, 2017 - 10:10 am

There appears to still be confusion on the differences between the Project Boundary and the Lighting Boundary.

The Project boundary is the same as shown in every other credit. All lighting within the project boundary must show compliance with this credit's requirements.

The Lighting boundary often has a lot of overlap with the project boundary. But they are separate. The Lighting boundary can be moved out at roadways or to the entire campus. The lighting boundary exists for a single purpose. As a line to measure spill light at.

People who should know better are confusing the terms. Both the LEED Reviewer and now GBCI want "ALL" lights within the lighting boundary to show compliance. For a campus project, this is problematic and against official LEED Interpretations.

Created on October 1, 2012
LEED Interpretation
ID# 10236

"If the LEED project boundary is smaller than the property line, projects can use the lighting boundary to meet the light trespass requirements of this credit. Buildings that are part of campuses or shared properties can use the "campus boundary", i.e. the campus property line, to comply with the light trespass requirements of this credit. All LEED projects attempting SSc8 should continue to meet all exterior requirements (LPD, uplight, trespass) based all of the exterior luminaries within the LEED project boundary. The lighting boundary is only for the purposes of the trespass calculation, based on the light emitted by the luminaires within the LEED project boundary. Project teams should take note that the LEED project boundary must be appropriately defined and comply with Minimum Program Requirement (MPR) #3- "Must be a reasonable site boundary"."

GBCI Case 01680820

"The fundamental principle we are enforcing here is that ALL energy use within the LPB (or lighting boundary in this case) must be considered for LEED.

"We recommend that you revise your documentation such as to account for ALL luminaries contained within the lightning boundary established for your project, or to revise the lighting zone accordingly, and to provide proper justification for the same."

May 17, 2017 - 12:45 pm

Bill, let me describe three Phantom Requirements related to Project vs Lighting boundary. These were enforced before LI#10236. The reviewer and GBCI-USGBC insisted they were 100% correct and the credits were denied.

-- The lighting levels exceeded the "requirements" on top of a parapet of a parking structure. The parapet was 100-feet from the property line. The project and lighting boundary lighting level limits were complied with. The claim was the the "requirements" for the difference between max and min levels was exceed on top of the parapet.

-- An 80-year-old high school that renovated a building was denied because the lighting levels at of the project boundary --smaller than the campus boundary-- over illuminated a walkway between the renovated building and existing buildings. The claim was that the walkway did not qualify as an exemption --meaning would be required to not meet IESNA requirements-- because there was no guarantee the school district would not at some point sell the existing buildings.

-- Point-of-entry special lighting was being rejected many years ago. That has now been fixed. What was appalling about one older rejection was the person they told did not understand site lighting was lighting expert Dave Nelson. Dave happened to write both the LEED credit language and the LEED reference guide (v2.0) section for site lighting. The reviewer --who the USGBC refused to name-- insisted Dave misunderstood the requirements he wrote.

So, Phantom Requirements do exist and have existed. The USGBC has improperly denied credits that they would now allow. I have yet to see anything from the USGBC that claims they ever make errors. The GBCI will admit that but they are hamstrung having to follow strict rules invented by the USGBC's LEED Department.

PS. The USGBC has monitored my posting on LEED User and used them against me. I expect the same will happen with my comments above. The review process has been in long need of a massive overhaul. But that will never happen.

January 20, 2017 - 3:17 pm

Been awhile since this thread has been used.

This has come up on a project and we lost on appeal so I'm sharing this information with everyone.

Any area being claimed in the wattage baseline calculation must be illuminated to a minimum light level of 0.2 fc.

In the past, if there was a section of a parking lot that the Owner didn't want lights installed I would still claim the square footage of that hardscape because it created a higher baseline wattage. The reviewers will not permit this practice anymore. An area must be illuminated in order to claim any reduction for it. Meaning wattage must be added if you want to show an energy savings.

The actual comment from the reviewer.
"The energy savings reported for exterior lighting do not appear to be substantiated because it is unclear if only surfaces that are provided with exterior lighting have been included. Note that the uploaded site photometric plans include areas which have as low as 0.01 and 0.02 footcandles. Areas should receive at least 0.2 footcandles of lighting to be considered illuminated. Review the exterior lighting calculations and ensure that only surface area with sufficient lighting has been included. Provide sufficient information regarding the energy inputs in the Section 1.4 Tables and an accompanying narrative to justify the reported energy savings."

Why 0.2 fc as a minimum? Excellent question. It is a phantom rule. There is no mention of this in any USGBC document. I did some searching when this came up and it seems an early draft of the MLO noted a minimum light level of 0.2 fc. The final version of the MLO does not have any mention of a minimum light level. That is the only source I can find. And now LEED has adopted this obsolete language.

June 9, 2017 - 2:58 pm

Yup, clear as mud.

I read this as, if the edges of the parking lot are a little dark, no problem. But the parking lot has to have a reasonable attempt at illumination. And no idea where the line gets drawn.

I'm sure in a year or two some review team will reject a project's credit because the light levels are too low. The design team will ask what "too low" means. And no answer can be provided other than, "please refer to industry standards, good design practice, and client desires".

And they'll claim they did. "Client desires" is a broad enough area to use as supporting evidence of anything.

Either this is not an enforceable requirement or it has continued frustration for teams.

June 9, 2017 - 9:59 am

Oh geeze. Sorry but this is a pretty ridiculous and wishy-washy response. You asked should projects have to meet industry standards for illumination? The answer was no. The comments then state that the intent of the standard is that project should meet industry standards for illumination. Anyone else see a clear contradiction in this response?

If the intent of the standard is to meet industry standards for illumination, why would this interpretation say that projects don't have to meet industry standards? SMH

So what we have is clear as mud and basically unenforceable.

June 7, 2017 - 2:45 pm

Thanks Marcus Sheffer for the recommendation to pursue an ASHRAE Interpretation on this issue. ASHRAE Interpretation 90.1-2010-33 clarifies this topic:


Interpretation 1: The qualifier “…designed to be illuminated…” does not specify lighting design criteria. However, it was the intent of the Standard that spaces, areas, or applications that claim Lighting Power Density for compliance or performance rating have been designed to some reasonable lighting design criteria that meets industry standards, good design practice, and client desires.

This interpretation also applies to the 2013 and 2016 versions of Standard 90.1.

Interpretation No.2: For tradable surfaces, only the area that is designed to be illuminated may be included in the exterior lighting power allowance (ELPA). For example, if 50,000 square feet on the West Side of a parking lot has lighting fixtures designed to illuminate that area, and 50,000 square feet on the East side of the parking lot has no lighting fixtures designed to
illuminate that area, a parking lot area of 50,000 square feet shall be used to calculate the ELPA.

Question No.2: Is this interpretation correct?

Answer No.2: Yes.

As noted by Megan Ritchie-Saffitz above:

"To support the claim that the surface is “designed to be illuminated”, a project team may optionally reference these IESNA values. Other justification supporting the claim that the surface is “designed to be illuminated” will also be accepted."

The ASHRAE Interpretation above provides other justification that can be used to support the claim that the surface is "designed to be illuminated":

* Published minimum recommended illumination levels for the surface type (such as the IESNA Handbook, Zumtobel – the Lighting Handbook, EN
1264-2, local code regulations, etc.).

* Some reasonable lighting design criteria that meets industry standards, good design practice, and client desires.

February 2, 2017 - 11:59 am

It sounds like there just needs to be some sort of defensible position. But then this is gray area.

Maybe something to remember for the next version of LEED to actually have the 0.2 fc written to make it official. Having a 0.2 fc limit is reasonable to me, I just want it published officially.

February 2, 2017 - 10:22 am

I agree that the 0.2 fc is not a definite requirement. But it begs the question about what is considered designed to be illuminated? Any amount of lighting no matter how small? What if I take my photometrics to 0.00000000000001 fc, it that illumination? I checked 90.1-2016 to see if this has been addressed yet and could not find anything. It seems to me that it would be useful to submit an ASHRAE 90.1 interpretation to ask this question and get some definitive answer. Right now USGBC is leaving this wide open to interpretation by individual projects.

It is clearly wrong, and always has been, to claim energy savings for surfaces that are not adequately illuminated. That is like adding building area to the baseline and heating/cooling it as a means to claim additional savings. It is simply not a reasonable or fair comparison.

February 2, 2017 - 12:22 am


Thanks for reaching out to us in regards to this.
Per ASHRAE 90.1 and LEED requirements, tradable exterior lighting surfaces must be designed to be illuminated in order to be counted in the Baseline exterior lighting power allowance:

For LEED v4 EA Prerequisite: Minimum Energy Performance submittals, ASHRAE 90.1-2010, Section states: “The total exterior lighting power allowance for all exterior building applications is the sum of the base site allowance plus the individual allowances for areas that are designed to be illuminated and are permitted in Table 9.4.3B for the applicable lighting zone."

Similarly for LEED 2009 EA Prerequisite: Minimum Energy Performance submittals, the ASHRAE 90.1-2007 User’s Manual, Section 9.4.5 – Determining Exterior Building Lighting Power Compliance, indicates that the exterior lighting power allowance (ELPA) “is calculated by multiplying each lighted area or width of door opening by the appropriate exterior lighting unit power allowance.”

However, if the LEED ASHRAE 90.1 Exterior Lighting Power documentation confirms that each surface where the exterior lighting power allowance is applied is “designed to be illuminated” or “lighted”, there is no defined minimum threshold that the project must adhere to in order to be counted in the Baseline lighting power allowance. A minimum 0.2 footcandle requirement does not apply.

Note that the IESNA Lighting Handbook recommends a minimum horizontal illuminance level of 0.2 footcandles for basic parking lot lighting applications. To support the claim that the surface is “designed to be illuminated”, a project team may optionally reference these IESNA values. However, this minimum footcandle level is a recommendation only, and is not stipulated by ASHRAE 90.1. Other justification supporting the claim that the surface is “designed to be illuminated” will also be accepted.

We are following up with you offline to ensure this reference to a “0.20 footcandle” requirement is corrected for your project.


January 20, 2017 - 5:05 pm

Thanks Bill, good to know. I can see where they are coming from, and you too, but seems like they should issue an addenda with this immediately. To change interpretation mid-stream without notice is not fair.

August 7, 2014 - 5:14 pm

What is the ruling on when a LEED interpretation is effective?? We specified a vegetative roof in 2011 for a project registered in 2011 & completed the submittal for SSc5.1, which is a Construction credit. In October 2012, LEED Interpretation #10231 was published. Now that the building is complete, our construction credits have been reviewed & our vegetative roof is being 'disallowed' due to a LEED interpretation written after construction began. Is this correct ??

August 8, 2014 - 12:36 pm

I have certified a lot of high level LEED projects, meaning I am the person who has responed to the review comments. This is what I have learned:

- RG revisions and addenda up to the registration date can be overridden by the person doing the review.

This is not right, of course. How is this allowed? Well, if the reviewer makes an error, or decides to give you a hard time, the review comment stands as written. You must respond to the comment regardless of whether the reviewer properly followed the rules or not. I have been forced to comply with a change to LEED that occurred as late as after the project was under construction.

Here is another observation:

- Claiming an ECM (Exceptional Cost Measure) for EAc1 can completely undo a project's certification process.

The above happened to a project of mine where the energy savings for a highly-specialized process load (aquatic life support for medical treatment and isolation) where challenged by some "unidentified" expert who was evidently hired by the LEED reviewer (the GBCI used an outside reviewer firm) to conduct a "special" review.

The special review challenged things such as the working schedule. The schedule was identical in both energy use cases, so the argument was about proving when the process loads were actually used during a year. In other words, we were forced to "accurately" predict unknown future illnesses of different aquatic species, and to backup the proper water temperatures of the medical life support tanks.

The real undoing of the life support challenged project was a demand to have other engineers of similar systems, that were designed locally, provide letters stating what the standard non-energy efficient design was. It made no difference to the GBCI that there are only two qualified firms in the U.S. who can design such a system for large aquariums.

It is essentially impossible, for liability reasons, to get another engineer to provide a letter stating their design is not "that good," and the owner will have to spend more money on energy. It is unreasonable to get a letter from your only direct competitor, especially when the two companies are challenging each other, for marketing reasons, of using as many energy saving techniques as they can fit into a project.

August 8, 2014 - 12:02 pm

I also thought some of the comments were 'canned responses' however evidently not, since the credit was denied & we are now in appeal. I have found the conference call method prudent(essential) prior to final clarifications.
Again, thanks for your insight.

August 8, 2014 - 10:13 am

I have to say that many of those frustrating comments seem to be "canned responses" meaning they just put them there from the get go to give you some sort of grief during the first design review. Its a pain point for sure.

August 8, 2014 - 9:57 am

Thank you for the additional info.....appreciate it greatly & I already have the manual.
What is very frustrating is the trend expressed in this forum....almost every project I have is experiencing something like this. And, if we didn't follow-up & involve GBCI, the credits would be denied. This particular project has had 4 credits re-reviewed and approved. Granted the projects are not office buildings, but adaptive reuse of historic properties in hotels, etc. This level of QA is not what I expect from the experts. It appears many are applying their opinions rather than follow the specifics required in the reference guide/documents. I have 3 projects involved in 'reasonable proof of standard practice'.
What happened to the commitment for 'less detailed documentation' ??
Unfortunately, this is also driving the 'cost of LEED' higher, which is not a good trend.

August 8, 2014 - 8:59 am


Also the LEED Certification Policy Manual, For Use With All LEED Rating Systems published January 1, 2012 states this in section 6.2:

" GBCI requires compliance with the version of the reference guide including all published addenda, that was in place at the time of the project registration. Project teams may voluntarily elect to pursue certification by demonstrating compliance with a revised version of the reference guide rather than the version that existed at the time such a project was registered."

For some reason the link isn't working but if you email me I can send you the document: eduran@dagherengineering.com

August 7, 2014 - 5:35 pm

You are a godsend.....THANK YOU !!!

August 7, 2014 - 5:34 pm

Yep, it's published . . . http://www.usgbc.org/leed/tools/interpretations

"Project teams must follow rating system addenda based on their project’s registration date."
and . . .
"All project teams are required to adhere to all LEED Interpretations posted before their registration date. This also applies to other addenda. Adherence to rulings posted after a project registers is optional, but strongly encouraged."

August 7, 2014 - 5:21 pm

Thanks....is this your opinion or the process? I have not been able to find anything on this topic on their websites, either USGBC or GBCI.

August 7, 2014 - 5:18 pm

GBCI reviewers should only make projects accountable to LIs and addenda published at the time your project was registered, not after.

July 31, 2014 - 8:34 am

On the submittal form for SSc8 there is some new language that was added on the 4.0 Version of the document. Right before Table SSc8-2 there is text that says, "Include only surfaces that are provided with lighting. Unlit surfaces cannot be claimed for additional lighting power allowance."

This is not part of the credit language and is not even mentioned in the Reference Guide. I would think it can be ignored.

July 31, 2014 - 9:55 am

The "added" language is there to provide clarity. A number of projects are attempting to include unlit areas. This adds to the baseline LPD without adding anything to the proposed LPD and therefore overstates the savings. It is just not a fair comparison. The description of how to do the LPD calculations is contained in the ASHRAE 90.1-2007 User's Manual. It clearly states that the "lighted area" is to be used. In addition to the credit language and the Reference Guide, the referenced standard comes into play as well.

July 31, 2014 - 9:38 am

Table SSc8-2 is for untradeable surfaces. I guess if you don't have a light over an ATM then it's not like there is any benefit gained. It's still adding words that are not part of the credit language.

April 11, 2014 - 10:37 am

Anybody know where LEED obtained the definition of standard practice or non standard practice? I just got review comments on a credit where they are requiring me to cite three similar project constructed within the past 5 years as reasonable proof that a measure is not standard practice.

April 11, 2014 - 9:05 pm

Agreed Marcus. The USGBC's LEED Department has created some review rules that are unreasonable. The GBCI tries to enforce the rules that are often misinterpreted by the reviewers.

There were no other similar, newly constructed, facilities in the project location, region, the State, and in the majority of the U.S. The comments were received were extraordinary in breathe. And, they took much longer than three hours to write. I don't know how the cost of the review that was done was justified.

April 11, 2014 - 6:14 pm

I agree that if this was the only option offered it is unreasonable.

I think USGBC should provide better baseline guidance for projects pursuing process savings in general so project teams have a better idea of what will and will not be acceptable before it gets to the reviewer.

April 11, 2014 - 6:07 pm


Below is a small part of the very long response we received in the second review. The demand was made over three years ago.

"a listing of several other newly constructed, similar facilities with the design properties used for those facilities along with a statement from the engineer of record stating that these designs are standard practice for newly constructed facilities in the project location."

The demand made is entirely unreasonable.

April 11, 2014 - 5:50 pm

Marcus wrote, in part: "I do agree that USGBC could do a much better job of providing project team guidance on this subject..."

The problem I experienced was no guidance was provided. Being told to conduct an industry survey is entirely unreasonable. There is no statement in any of the mass of LEED documentation that justifies such a demand being made by a reviewer.

Later, we learned that the reviewer did have non-LEED-based guidance they could have provided, but they chose to keep the name of the guidance document a secret.

The solution is simple: If published LEED requirements do not exist the reviewers are not allowed to create their own requirements.

For process loads the two most important things to do are: first, establish a reasonable baseline based on the design phase of the project. Second, make sure the operational schedules are identical between the baseline and proposed case.

April 11, 2014 - 5:23 pm

The generalities discussed here make it very difficult to develop a reasonable response to help you deal specifically with this issue but I will try to deal with it in general terms.

It sounds like you are claiming energy savings related to an energy saving exceptional calculation. In this scenario the establishment of the baseline is up to the project team. The reason for this is that quite often establishing a reasonable baseline for very specific strategies is a significant research project in and of itself and the reviewer cannot be expected to do so within the confines of the time we are allowed to spend on an individual review. If whatever industry has not done so, then LEED has no reference or established baseline. Also reasonable baselines vary by location and strategy as well as changing over time. For example, parking garage CO ventilation control is required by some codes in some areas and is not required by others. So in Oregon it is the law and projects cannot claim savings for doing something they are required to do anyway. Projects that did so before the law took effect could reasonably claim savings but afterward it is not reasonable savings. So requirements, laws and the standardization of specific strategies change and the project's registration date has always been the date that establishes precedence. I understand this is frustrating as I have been on both sides of this issue. I tried to claim energy savings related to infiltration reduction in about 2004 and 90.1-2013 has not yet established a defined reasonable baseline for a commercial building. These things apparently take time.

Some baselines are well established for things like food service equipment (LEED Retail), boiler efficiency and premium motors (both 90.1). I have long advocated for USGBC to provide more guidance on this baseline issue but it has not risen to the top of the pile yet apparently.

So back to your original post in this thread. Did the reviewer comment offer any other options for you to defend your baseline? The standard review comment typically includes additional options for establishing a reasonable baseline. Can you share the strategy for which you are claiming savings?

It is often very hard to determine a reasonable baseline for a project team spending many hours evaluating options and trying to determine reasonable savings. For a reviewer to do so within the 3 hours or so they get to evaluate it can be impossible. I do agree that USGBC could do a much better job of providing project team guidance on this subject so the best advice I can give anyone is to submit an Interpretation to get some feedback before you go to the review phase.

April 11, 2014 - 2:57 pm

Everyone is giving really great answers - honestly never thought of referencing other projects of ours that were inefficient to support my "more efficient" project claims. Not sure if we have any of those. Didn't think people did that but I bet they have and I wouldn't blame them (this is such a pain)

My frustration stems from what Hernando is saying where other similar projects using a similar strategy were approved and now new items are being brought up with different supporting requirements.

It's like if you were playing basketball and every time you got on the court, the rules have changed.

I get that the system is constantly being updated and revised to address items that were missed or not addressed. However, it really makes you wonder how much you can trust a rating on any building when it doesn't seem to be held to the same standard year after year.

We are constantly uncertain of what will be approved or not approved even if based on prior projects. If your project gets approved this time around but not then next time around; and you think about all the other millions of square feet that are LEED certified and how "compliant" they were.

The comment is with regards to EAp2 and we are going back and forth on a 90.1 exception - the project is NCv2009 and the review team is referencing the Technical Manual for v2.0 but even this manual states "...it is not considered a precedent setting document. The rating system supersedes the content of this manual in case of any conflicts."

Again looping back to the original argument. We are discussing with the review team and really focusing on the language of what the required referenced standard indicates.

To a certain extent I feel like you have to demonstrate that you are playing by the rules that were set forth and not by what the players of the game are dictating because they have revised their strategy to deal with what that team or other review teams have requested. If that makes any sense.

April 11, 2014 - 1:07 pm

I disagree with you E H.

What the "standard" practice and 5-year rule fail to take into account is the actual design, construction and LEED certification process.

If a small, fast-track, project completes LEED before a multi-phase, many year, project, which started design long before the small project, then than later project sets the LEED standard.

ASHRAE has no established baseline for process loads analysis. Process loads analysis and setting a baseline is entirely subjective.

April 11, 2014 - 1:00 pm

Well, we did punt back to the reviewers for the LEED v2.2 project with special life support systems I mentioned. We responded by telling the reviewers that at the time the design decisions were made that standard equipment could be purchased that was not as efficient as the equipment that was designed into the project. The reviewers claimed that "recent" unnamed LEED projects had previously document similar efficient equipment, and therefore the project could not earn innovation credit since other projects had already done so. The project DID NOT apply for a LEED innovation credit of these special process load system. All efficiency claims weer included only as part of EAc1.

The reviewers had the gall to demand that an industry survey be provided with the first review comments. With the second review comments they made reference to an industry survey and conveniently failed to name the survey. Why the GBCI was forced this comment from the LEED reviewer is a real mystery. If they want a particular survey used, then the reviewers should have named it up front.

What was really ugly about that project was that these external loads represented more than 97% of the EAc1 loads. The building and its loads were less than 3% of the energy use total. Both the building and process loads were between 38-39% more efficient, very close to the same performance. The building included internal process loads that were well above the 25% minimum requirement.

The building on its own was accepted by the reviewers meeting all LEED requirements. The same number of EAc1 points would have been claimed if the life support systems were entirely removed from LEED. But, were not allowed to remove the systems by the GBCI and go through a appeal process.

Even more odd, we had evidence of a LEED certified project that earned a similar 38% efficiency for the same type of life support systems. We also had evidence of a similar LEED certified project the excluded the life support system, and this systems were internal to the building, and not external loads.

The end result was the the the owner of the project abandoned the USGBC and LEED. They committed to doing all their project using LEED and backed out. The owner was one of the most committed green organizations I have every worked with. Sustainability was integrated into their everyday practices. The food served in the on-site cafeteria was sustainable. They offer regular environmental educational programs free to the general public.

April 11, 2014 - 12:58 pm

What prereq/credit is the comment in regard to? It sounds like the reviewer is referencing LI#10291 for EAp2. If you are taking credit for energy savings that fall outside ASHRAE established baselines you will need to justify how you arrived at the standard to compare your project to.

I can see where the reviewer is coming from. If you are doing something innovative you will need to back up those claims as to how your approach is quanitively better than an established baseline. The point of the 5 year limit is to ensure that your claim is indeed a current standard and that you are not inflating the level of innovation by comparing it to an outdated standard of practice.

April 11, 2014 - 12:26 pm

If there's a GBCI/USGBC person lurking on this forum, now would be a great time for you to comment.

This is a very common comment/request for 2009 projects. If you receive this for a v2.2 or other pre-2009 system, punt it back to the reviewer. Sometimes reviewers have their 2009 hat on when reviewing v2.2 projects.

"Innovative" is a subjective concept, which is why they ask you to demonstrate that it is innovative by explaining how it goes beyond "standard" practice - although also subjective, standard practice is easier to demonstrate. Think of your strategy as "standard until proven innovative". It's a hassle, but *in theory* it prevents gaming the system. In reality it creates an advantage to people who certify a lot of projects and have a lot of experience with ID credits. (Please note that this is an explanation - it doesn't mean that I agree with the approach.)

You should try to engage in an email dialog with the reviewers if you're unclear how to do this for your specific issue. However, they are unlikely to drop the request.

April 11, 2014 - 12:00 pm


The problem is that the GBCI has to follow rules invented by the USGBC's LEED Department. The rule making body is divorced from the reviewing body. The USGBC's LEED Department is filled with policy developers who have no real experience with designing buildings, and who have little experience with what is actually required to certify a LEED building.

Ten years ago I proposed to the LEED Steering Committee that LEED needed a public advocacy group (aka, ombudsmen team) to intervene when the LEED reviewers made unreasonable demands. The proposal was instantly criticized by the then VP of LEED. No one on the Steering Committee was allowed to make a comment before the VP of LEED finished his concentrated attack on the proposal. The Steering Committee decided it was best to leave things as they were to not further upset the VP of LEED. Why was the VP so upset, they were horrified that someone they would have no control over would be looking over their shoulder.

April 11, 2014 - 11:36 am

This does seem very weird. My assumption is you are proposing something and an improvement that you feel is not standard practice, and they are pushing back, wanting PROOF that it is not standard practice. That is really hard to prove, I agree with Hernando. What if your firm does something that has not caught on or picked up by others yet…so if you compare to your work, it is standard, but not to the industry.

This concerns me that GBCI does not have enough practitioners in its ranks, or they are not being deployed correctly. Anyone with experience would know what is standard for this time and place, and if they don’t for some reason, they can call someone they know and trust to find out. I know those professionals exist in GBCI, I have met many and find them quite knowledgeable and helpful.

Maybe there needs to be access to a panel of professionals for things like this, as advisors to the reviewers. I would volunteer for that kind of role.

April 11, 2014 - 11:23 am

This is reviewer nonsense. I have run into this before. In my case the reviewer demanded that an industry survey be conducted for process loads for a very complex life-support system. The system has only two qualified engineering firms in the U.S. that can design it. Well, you cannot survey yourself and your competitor. Worse, if design standard is to go beyond the minimum, to give you an green-edge over your competitors, you are deemed to not be green at all.

There is no way you will be able to get documentation to the level necessary to satisfy the LEED reviewers, for projects other than your own. This because those business competitors will not share that level of data with you. You are stuck referencing your own projects, and the reviewers will fault you for not documenting detailed supporting data from other firms. Pure Catch-22.

Ugly as it is, the is USGBC basically telling you to "design your systems for non-LEED projects to be energy inefficient, so that when you do a LEED project you can claim how efficient your project is by comparing it to your non-efficient projects."

October 1, 2012 - 9:11 am

I am working on a CI project and have recently received a design review which has requested that I modify my credit submission for SS C2. The reviewer states "However, the listing of community services counts the medical or dental office service two times (NS Dental Center, and NS University Hospital). Please note that with the exception of restaurants, no service may be counted more than once in the calculation"

I find this an interesting comment on 2 fronts...for one, I have had this exact same credit approved on 2 other projects located in the same building...


The sample Map for Community Connectivity on page 71 of the ID + C Reference Guide indicates a Medical office # 6 AND a Dental office # 7...

Did I miss the memo changing this credit somewhere along the way???

April 11, 2014 - 11:29 am

I have to agree with Marcus, perhaps you should ask for a conference call to see if this can get resolved before you have to appeal. That has worked for us on a couple of issues.

October 1, 2012 - 10:33 am

Prior approval on a project does not mean it gets approved the next time. Reviewers are human and miss things sometimes.

Sometime even the examples in the Reference Guide are not correct but in this case I think it is correct.

I do think you are right and the reviewer is mistaken to question this issue. A medical and dental facility are two separate and distinct services. The whole idea of the credit is that people in the building can easily access a variety of services. I think you could pretty easily make the case that people would visit the dentist and the doctor separately.

The reviewer seems to be hung up on the "or" in the credit language. One could interpret that as "one or the other" as well as "either one". I would certainly view it as the later.

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.

April 11, 2014 - 10:33 am

I inquired about citi bike being able to contribute to this credit and it was denied although it does meet the intent. There should be more options or flexibility with this.

July 12, 2012 - 4:39 pm

On my middle and high school projects -- more than 10-- bike racks are rarely used. Bike riding is not cool. Skateboards are cool.

Skateboards wind up stuffed in lockers, much to the unhappiness of school officials.

I created a LI asking for an equivalence to bike spaces for kids that to securely store their skate boards. Seems logical. Anybody who has kids knows that skateboarding is a preferred method of getting to school, unless a kid is lucky enough to have a car.

Well, the USGBC decided that skateboards were not a preferred mode transportation for kids. They stated that a usage study must be conducted to prove kids would actually use skateboards to get to school. How the usage study was to be conducted was not defined by the USGBC. A study certain to be rejected as inadequate by the reviewers based on some criteria only they have access to.

We dropped pursuit of this option, and now have LEED accepted bicycle parking that is mostly unused. Skateboards continue to be stuffed in lockers.

July 12, 2012 - 4:20 pm

My comment was intended as sarcasm. Seems I was beaten to the punchline.

Don't all of these signs start reducing the sense of community? Regardless, this is scope creep. There is no mention of restricting access in the Credit language. And what's the point, it's not like any of this signage gets enforced. Why be so super strict in documenting something that is so fluid? I love the fail photo here.

July 12, 2012 - 3:44 pm

Bill Swanson: Yes. I just got a review back saying that the reserved parking spaces need to be for building occupants only. I don't think the rest of the spaces would need to be designated LEED building-only.

July 12, 2012 - 1:23 pm

This "rule" would force every LEED project on a campus to use the AGMBC regardless of the owner's intent to certify only one building.

The LEED Project Boundary needs to be selectively expanded, based on the credits pursued, to comply with this new demand, and worse, there are no rules about exactly what the USGBC/GBCI wants you to do.

We are left to guess and make up our own rules and wait until the reviewers tell us we were wrong, because new requirements were published just the week before, long after your project was registered, and even after it was submitted for review. Amazing...

July 12, 2012 - 1:16 pm

Do we similarly require parking lots to have signs that say spaces may only be used by occupants of this building?

July 12, 2012 - 1:13 pm

But, "of all LEED project users" means your LEED project only and nothing outside of the project boundary. LEED Project boundary is clearly defined in the LEED MPRs and certification requirement documents.

LEED Project boundary is how projects have been certified since day 1 of LEED. This is something "new" and undocumented.

This is a new requirement that was recently "invented" and is now being enforced without the USGBC/GBCI bothering to update the LEED Reference Guides via an appropriate addenda.

July 12, 2012 - 12:06 pm

I recieved a reply back that clarifies the intent of this requirement. It is a requirement that I was not aware of, or did not undestand, until now. And, it is definitely a requirement that all projects should be aware of as is affects how buildings chose to locate their racks.

Response: The intent of SSc4.2 is to reduce pollution and land development impacts from automobile use by providing bicycle racks for 5% or more of all LEED project users, and shower and changing facilities for 0.5% FTE of the LEED project building. This means that bicycle racks for 5% of all LEED project users must be available to the LEED project occupants at all times.

So, if there is potential for the racks to be used by people outside the project, you must account for that increase in use, locate them in a secure location where only building occupants can access them, or install signage to deter others from using them. I could see this being a problem in campus projects (like ours) or urban settings where you may want to locate racks out front near the building entrance.

July 9, 2012 - 5:17 pm

Dear E.H. - We'll contact you offline to review your concerns specific to your project. For anyone else, if you ever have any questions or concerns relative to your review comments, you can always get in touch with us - including your LEED Reviewer - by selecting "Questions About Review Comments" from http://www.gbci.org/org-nav/contact/Contact-Us/Project-Certification-Que.... If we aren't able to resolve your issue by email - or you just want to talk through it - selecting "Follow Up to Prior GBCI Reply" from the same url will give you the option to request a phone call with your LEED Reviewer. Hope this helps - MRS