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Sixth Comment Period for LEED v4 Won't Delay Member Ballot

USGBC has announced a 6th public comment period for LEED version 4, the newest version of the LEED rating systems, but it says that there will be no delay in the member balloting and launch of the system.
February 20, 2013

Update: It's March 1st, and the 6th public comment period is open. USGBC has posted information on how to get involved at usgbc.org/leedv4. As usual, LEEDuser is hosting an open forum where you can not only post public comments but also share your thoughts, reactions, and questions on the latest draft of LEED v4. The biggest change from the 5th public comment draft is a new Option 3 of the Building Product Disclosure and Optimization—Material Ingredients credit. This option recognizes manufacturer programs that are third party verified and provide relevant information on environmental and health impacts to decision-makers throughout the manufacturing process. What do you think of this and other changes in this draft? Please comment below.

USGBC has announced a 6th public comment period for LEED version 4, the newest version of the LEED rating systems, but it says that there will be no delay in the member balloting and launch of the system, if approved by members.

The new comment period will run from March 1–31, according to an announcement on the USGBC website. Selina Holmes, LEED marketing and communications manager at USGBC, told LEEDuser that the new comment period, which was not previously scheduled, is intended to focus specifically on refinements to credit calculations and documentation. Most basic credit requirements will not be up for review, but USGBC wants to make sure that the LEED v4 draft that goes to member ballot June 1st reflects the most straightforward requirements.

Complicated credit requirements and documentation have been a theme of comments from the LEED community through the development of LEED v4, and during the 5th public comment period in Fall 2012, that complaint was raised by some commenters. LEED's consensus-based, member-driven process requires substantive changes in rating system development to go through public comment. That means that without a 6th public comment, USGBC would have had to put the 5th public comment draft out to ballot with only minor tweaks. The organization apparently decided, based on comments received, that enough changes were called for to make a 6th public comment period worthwhile.

Holmes told LEEDuser that not all credits would be open for comment, noting that the new Materials & Resources credits, which have been particularly contentious, would be part of the focus of this comment period.

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The member ballot remains scheduled for June 1-30, and  Holmes says a launch of LEED v4 is targeted for Greenbuild 2013.


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June 14, 2013 - 1:46 pm

Hello - Does a 'abstain' vote on the LEED v4 ballot contribute to the quorum count?

June 18, 2013 - 2:29 pm

18. A ballot is approved by the consensus body if:
a. A majority (more than 50%) of the members of the consensus body casts a vote, including abstentions; and
b. A minimum of two-thirds of votes cast are affirmative votes; and
c. A majority of votes cast by members of the consensus body in each interest category (producer, user, general interest) are affirmative votes.

June 14, 2013 - 3:17 pm

I would assume so.

May 30, 2013 - 2:26 pm

M&V seems to have completely disappeared from LEEDv4. Advanced metering has moved from Pilot Credit 26 to EAc3 in v4, but this only requires metering, not a review of the actual building energy use compared to what was predicted. It seems as though Pilot Credit 27 "Reconcile Projected and Actual Energy Performance" was meant to be the next step after EAc3 (providing the metering) but where is it in v4? As noted in the Pilot Credit 27 background information "Data must not simply be gathered, but gathered and processed in a manner that allows meaningful comparison between predicted and actual energy performance."
Is this an oversight or what is USGBC’s reason for removing the credit for an M&V Plan?

May 31, 2013 - 4:27 pm

maybe you're the one who asked this on the phone call with Brendan Owens- for everyone else it might be good to hear his response:

He basically said v2009 projects that pursued this credit were "all about the M (Measurement) and very little about the V (Verification)"

He said the implementation plan is more the purview of LEED EBOM and USGBC put heavy emphasis on it there. LEED NC focusses on putting in the infrastructure (meters). Using the data from the meters to make informed operating decisions will fall under the purview of LEED EBOM.

May 10, 2013 - 12:03 pm

I am unclear on the timing of v4 implementation ( assuming approval in June) and the phase out of 2009.

December 1, 2013 - 2:35 pm

LEED v4 launched at Greenbuild last month.

Registration for LEED 2009 will be open through June 1, 2015. See http://www.usgbc.org/help/how-long-will-leed-2009-be-open-registration.

May 10, 2013 - 1:36 pm

Barry, the member ballot is June 1 to June 30 (or until a quorum is reached). After that, things are a little sketchier, but if approved I'd look for a launch by November, and a phase-out of v2009 that will take a couple years.

March 31, 2013 - 4:19 pm

Why not use the word disclosure again or transparency rather than reporting in the title? The more you can reinforce the meaning of the credit by repeating words rather than using new ones the more you will help clarify meaning.

Why are manufacturer-declared inventories given the same weight as a Health Product Declaration or Cradle to Cradle. Why is manufacturer-declared information credited as 25% in MRc2 and 50% in MRc3 and 100% here?.

Define manufacturer inventory, health product declaration, cradle to cradle, material ingredient optimization, GreenScreen List Translator, Green Screen v1.2 Benchmark, full GreenScreen Assessment, Cradle to Cradle Certified v2 and v3 in the glossary.

Please clarify If the International Alternative Compliance Path – REACH Optimization is only available to international and not US-based projects.

March 31, 2013 - 4:22 pm

Under Option 1, It is not clear where the information that is being requested exists. After a quick review of all the acceptable frameworks, we were not able to find any reporting that listed:
• Raw material supplier extraction locations (especially for all the different products most companies produce)
• A commitment to long-term ecologically responsible land use
• A commitment to reducing environmental harms from extraction and/or manufacturing processes
• A commitment to meeting applicable standards or programs voluntarily that address responsible sourcing criteria. (Could you at least provide some examples of the types of programs to which you refer?)

It is unclear how one would ensure the commitments above are real or where one would be able to find them without having to spend an unreasonable amount of time researching companies and their individual products. It is also unclear from the credit language whether every raw material component of say steel (iron, carbon, manganese, phosphorus, sulfur, silicon and traces of oxygen, nitrogen and aluminum) will have to have these reports from every raw material supplier they use in every factory for every product.

If the approach provided under the structure and enclosure section (i.e. by weight) is to be applied across the board, it should be put somewhere so it is clear it applies to all materials not just structure and enclosure.

In Option 2, Why not call it "improvement of" rather than "leadership extraction practices" Please define extended producer responsibility, bio-based materials and ASTM Test Method D6866 in the glossary

The Sustainable Agriculture Standard standard seems primarily oriented around food products at the moment. It is not clear how will they be able to gear up and certify enough building materials in the next two years to make this option viable. How will we know if the raw material has been legally harvested, as defined by the exporting and receiving country?

It seems as though this approach would be more viable if the USGBC were certifying the materials that meet their criteria once and making a data base of acceptable materials available to LEED project teams for specification and documentation purposes. It would be great to be able to enter a material into a database with its cost and the total amount of materials and have all the green attributes automatically calculated. It would also engage the USGBC more directly with the manufacturers that they want to influence and avoid the duplication and waste of effort that will be required if every team has to do the research independently. Also with this approach, the USGBC could promise compliant products access to the broader LEED community not just a single project. and simplify the documentation process enormously..

March 31, 2013 - 3:56 pm

When I went in to make my comments the other day, I got kicked out before I could finish and since it is impossible to go back and edit on the USGBC website, I will complete my comments here.

Please define in the glossary the following terms: life-cycle analysis, environmental product declarations,cradle to gate, program operator and third party certification with external verification (I thought third party verification was external verification.) The current definition of verification refers to M&V.

Please improve the credit language to clarify the distinctions between the three options in Option I so that is clear to those unfamiliar with this jargon what the differences are.

The use of the words multi-attribute optimization in Option 2 is very confusing. You should define it if you are going to use it, but in general, the word optimize is overused in LEED v4. Simpler language like improve or improvement would be better

50% seems a very high level given that is not clear that these certifications exist at the moment. Why did the USGBC make this 50% and the option that includes recycled content only 25%

We have not been able to find certifications that "verify impact below industry average" for the credit criteria. It seems premature to vote in favor of a system that relies on information that does not currently exist in the marketplace?

The language relating to valuation factor is very confusing. It doesn't help that Option 1 is number of products and Option 2 is percentage by cost.

March 28, 2013 - 3:32 pm

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

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

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

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

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

March 21, 2013 - 1:48 pm

While I haven't done an in-depth review of the Credits available for input in the 6th comment period, there are a few items that, if left as is, will be dealbreakers for me. Dealbreaker meaning I will either vote 'no' for v4, or not vote at all.

1. USGBC Approved Program: As currently written in the MR Credits, this implies that changes to a Credit may be made after the Credit is approved and in play - i.e., a 'program' that comes up after v4 approval and is deemed acceptable and 'as approved by the USGBC'. No answers to my questions about this issue in this forum thread yet, so I can only quess what they have in mind.

This is a significant change in the LEED development protocol and the LEED approval process. They do not indicate whether qualified professionals will be vetting these programs, whether the general memberhip will have any input as to what might be considered to be acceptable and (oh by the way - achieveble), or whether we be able to vote on these new programs. Hmmmm...... scratching my head.....

SO, if this item stands as is, I'm reading a 'yes' vote on v4 as being a vote to give up my right to have the input that WAS the cornerstone of LEED development until the last couple of years, and potentially giving up my right to vote. Really, why would I do such a thing?!? That would be silly! So, if the 'programs approved by USGBC' after the fact concept remains, in any form, in the LEED v4 that goes to ballot - thumbs down for me.

2. LEED v4 MR Credit 4 - Material Ingredients - Disclosure and Optimization, Option 3: I was so excited and hopeful about this Credit in the last go-round. Transparency - yay! That's what this Credit was originally about. It's not about banning products, its about understanding exactly what is in various building products and thereby having a clearer choice and the ability to incorporate healthier materials. But, no more, with mucked up mess of Option 3 now on the table. Discussion on this Option 3 debacle is going on in another thread, but if it remains (in any form) in this Credit in the LEED v4 that goes to ballot - thumbs down for me.

I'll be interested to hear what others might consider to be dealbreakers, and I may pipe up again on more dealbreaker items upon further review.

March 27, 2013 - 12:06 pm

Peggy, I'm glad you posted this comment. I have been bogged down in the technical aspects of this change - the complexity is truly a dealbreaker for me. As a practitioner and as a state employee involved in policy discussions, simplicity is key - what do we want to achieve and what's the simplest manner in which to get there? This confusion and complexity doesn't make this credit more likeable or useable, it only gives nay-sayers more toeholds from which to fight against the work at hand.

But you have brought up an even more fundamentally important factor, that all of us MUST pay attention to.

The process from the start of LEED system work has been transparent and inviting, and the startling implications of decisions being made without stakeholder input slipped right by me. This cannot be allowed to occur because it will undermine the greatest strenght and frankly, selling point of the system. If important decisions (on acceptable review or certification programs for example) are made by a restricted group after the public input and vote, then the true power of transformation is negated and the system ownership/control becomes dominent over the end goals.

Never good.

March 19, 2013 - 3:59 pm

I posted an article in its own LEEDuser forum going into more depth on what MRc4 Option 3 is all about. Please read it here and post your thoughts!

End of 6th public comment is coming up March 31st!

March 19, 2013 - 12:07 am

There is some very good in this credit, plus some bad that could completely moot the value of the good. On the good side, the intent is excellent. The credit continues to support a virtuous cycle of disclosure and assessment and product improvement. And the language describing the HPD and GreenScreen is good and the Cradle to Cradle language is good enough.

On the bad side the credit has two big problem areas that could totally undo it:

1) Complexity: With three options that include ten nonparallel paths for compliance, each with several different percentages, benchmarks and languages, this credit is getting more complicated with each comment period and communicates the impression to project teams that this is a very difficult credit to achieve and confuses manufacturers trying to determine how to comply. This is not necessary. The credit must be simplified to insure that teams don’t just walk away in frustration.

2) Easy out options that undermine the credit: Three of the ten paths in the credit language pose a serious threat to industry adoption of the HPD and more broadly to the goal of providing standardized, comparable disclosure and assessment of product contents – encouraging manufacturers to provide incomplete, misleading information in a variety of formats that make it more difficult for their customers to compare products and make informed choices instead of using the standardized HPD. And rewarding regulatory compliance instead of meaningful avoidance of chemicals of concern.

The “Manufacturer Inventory” allows products to contribute to the inventory point if the manufacturer posts an unstructured non-standard incomplete inventory of ingredients without disclosure of hazard instead of doing an HPD.
The “International Alternative Compliance Path” allows products to contribute to the optimization point that are only avoiding a small fraction of the chemicals that the other paths (GreenScreen or Cradle to Cradle) require – and these are chemicals that every EU company is already avoiding to meet EU regulatory requirements so there is no leadership.
The “Product Manufacturer Supply Chain Optimization” sounds a lot like current regulatory requirements on the industry. It needs a lot of work to be meaningful.

This credit needs radical simplification. The ten divergent complex pathways can be boiled down to two Options with a clear standardized single documentation track for each.
1) Health Product Declaration (for disclosure) plus GreenScreen (for optimization_
2) Cradle to Cradle certification

Drop the confusing Manufacturer inventory and the way too easy International path and send the Supply Chain optimization off to the Credit Library for work. This credit does not need to be complicated.

March 27, 2013 - 11:18 am

Peggy, Tom and Pamela have already pointed out may of my questions and concerns. I am also concerned that there are inconsistencies within the reporting requirements, which will create frustration and confusion for all involved - project teams, manufacturers, LEED Reviewers, GBCI, etc.

Option 1 requires teams to document a certain number of products (20), whereas Options 2 & 3 require a % by cost - why aren't the documentation requirements consistent across all Options?

Option 1 requires manufacturers to report to at least 1,000ppm, but Option 3 allows manufacturers to report to 99% by weight of ingredients - why aren't the ingredient reporting requirements consistent across all Options?

March 19, 2013 - 3:49 pm

MR c2-4 should be combined and simplified into one or two credits for six points using only EPDs, HPDs, Green Screen and Cradle to Cradle. There is no reason to believe that the market will be able to respond in a timely manner to the credits as written. If you truly want to transform the product industry you need to make these credits achievable (so that people will not avoid them) and support the fledgling tools that exist rather than undercut them and confuse the market place with too many ill-defined options. The proposed credit structure should not be used until there are many products to choose from and well defined FREE tools and resources to help project teams meet the criteria and/or find compliant products.

March 18, 2013 - 4:08 pm

I've just begun my review of the newly revised MR Credits, and I keep seeing the following as a potential path for achieving some of these Credits:
"USGBC approved program: Products that comply with ---------- approved by USGBC"

Please clarify exactly what that means.
1. This phrase reads as if these approvals by the USGBC are done after this LEED version is approved by the members - is that correct?
2. Who exactly would be determining whether the proposed program is acceptable? Staff? TAG?
3. Will the USGBC solicit input from the general membership when they are evaluating these new programs?
4. Will there be a member vote on new program acceptability? Or does it just get incorporated into the Credit after approval by the USGBC?

Thanks in advance for your input on this issue.

March 27, 2013 - 11:09 am

I was wondering the same thing.

March 14, 2013 - 4:47 am

Hey all,

I was wondering if there was any notion on whether there were thoughts to award points to those who do not have a negative aspect on their project. Ie. in Sweden we don't use Cooling Towers in our buildings as they are not required, however we lose out on 2 points within the system for omitting them, rather than achieve 2 points for not needing them. It seems like the wrong message to send to builders, that it is better to put in a highly-efficient cooling tower in a building that doesn't need it. I imagine others have experienced similar frustrations with other credits for omitting other negatives from their projects.

Do we know if the USGBC has looked into this?

March 20, 2013 - 4:56 am

Hey Susan,

Thanks for the reply, and I think I agree with you that not all LEED points work for all projects, but I disagree in the reasoning for it. I think that if you are able to remove the negative environmental impact that the credit is worried about and are not creating potentially other environmental impacts at the same time, then you should be eligible for the credit.

As you bring up the MRc7 credit, I guess I will discuss this further. If a project is to build with FSC certified wood, they are using a well-maintained renewal resource to build their building. However if they decide to build with concrete, brick or some other building material, they likely aren't using a renewable resource in the same way, and thus potentially causing other negative environmental impacts.

On the other hand, by reducing your requirement to use a cooling tower, however efficient it is, is reducing both energy and water consumption and is not replacing it with another negative environmental impact. I see these as two separate issues and would compare the cooling tower elimination more to eliminating parking or refrigerants, as it completely eliminates the negatives without adding other potential negatives.

March 19, 2013 - 1:44 pm

In general, getting points by not doing something hasn't been rewarded in the LEED system. For example, if I design and build a structure without wood, I won't be able to earn MRc7 Certified Wood. If I have no exterior lighting and an exempted interior lighting situation, I won't earn SSc8.

It's the old, not all credits are right for all projects thing.

March 14, 2013 - 4:39 am

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

March 13, 2013 - 3:21 pm

Can anyone tell me what certifications exist that "verify impact reductions below industry average" for the following?

• global warming potential (greenhouse gases), in CO2e;
• depletion of the stratospheric ozone layer, in kg CFC-11;
• acidification of land and water sources, in moles H+ or kg SO2;
• eutrophication, in kg nitrogen or kg phosphate;
• formation of tropospheric ozone, in kg NOx or kg ethene; and
• depletion of nonrenewable energy resources, in MJ.

March 18, 2013 - 4:33 pm

My question is more focused on understanding how we would find these certifications and document this credit. Since I am not familiar with any certifications that currently exist that document three or more of the listed attributes or furthermore how one would be able to "verify impact reductions below industry average." I don't understand how industry averages will be determined for all the different green building products we typically see on a project.

Since no current programs are listed, it seems optimistic to think they will be developed and approved in two years. Also, "50% by cost of the total value of permanently installed products" seems extremely high and impossible to meet.

March 18, 2013 - 3:40 pm

Good question! I would add that credible certifications and standards must be incorporated to give this Credit some teeth and effectively move things forward. Self-reporting manufacturer policies may work for marketing products and may be well intentioned, but for benchmarking and metrics that bring value and credibility to LEED - not so much.

March 11, 2013 - 2:31 pm

To achieve the ID&C EApr1 – Fundamental commissioning and verification, per version 6 of the LEEDv4 draft of this prerequisite a project team must “prepare and maintain a current facilities requirements and operations and maintenance plan that contains the information necessary to operate the building efficiently. The plan must include the following: a sequence of operations for the building; the building occupancy schedule; equipment run-time schedules; setpoints for all HVAC equipment; set lighting levels throughout the building; minimum outside air requirements, any changes in schedules or setpoints for different seasons, days of the week, and times of day; a systems narrative describing the mechanical and electrical systems and equipment, a preventative maintenance plan for building equipment described in the systems narrative; and a commissioning program that includes periodic commissioning requirements, ongoing commissioning tasks and continuous tasks for critical facilities.”

This may prevent the majority of potential ID&C projects from registering to attempt LEED certification because they will not be able to obtain this level of info about the base building.

Is the idea of this new prerequisite requirement to only certify ID&C projects that choose to locate in buildings with comprehensive commissioning programs? This would be a HUGE change from v2009.

March 11, 2013 - 2:32 pm

For the BD+C Building product disclosure and optimization MR credits (MRc2, MRcr3, MRcr4), can someone please clarify:

1.) Between the three credits, are there 6 or 7 points available?
2.) Can the same material be used to satisfy the requirements for more than one of the 6 or 7 points? (If not, it is mathematically virtually impossible to achieve all 6 or 7 points.)
3.) In MRcr2, Option 1, 80 "products" can equal 20 "products", why is the same metric used to describe two different things? This is confusing.

We have been reaching out to members of the LEED practitioner community to get their thoughts on these credits. The consensus is that the way the credits are written is OVERWHELMINGLY too complex. It is in everybody's interest (clients, practitioners, LEED Online designers, GBCI reviewers) for the language of these credits to be rethought and simplified down to about 50%-75% of the original credit length.


March 6, 2013 - 5:41 pm

Because I can't comment directly, I just would like to suggest the change on the language for the IPc1. it uses "energy modeling analysis".I would think "building performance analysis" is more suitable because the requirement is not only about the energy.

March 5, 2013 - 2:32 pm

Few to none of my comments seem to actually get an answer. I'm trying to be as clear and straight forward as possible and the response I get is a copy/paste answer to a different question.

Example question on the FSC credit: "Will Members be allowed to vote on any future "USGBC-approved equivalent" or will this be something added by addenda next time Congress threatens to block government LEED spending?"

Answer: "Thank you for your comment. USGBC conducted a ballot process that concluded in 2010 which would have allowed for the recognition of forest certification systems aside from FSC. The USGBC membership voted down that initiative in favor of recognizing only FSC. LEED v4 currently references the Forest Stewardship Council for new wood products, but, along with all other referenced standards in the LEED program, USGBC may approve other appropriate referenced standards that are deemed equivalent by the LEED Steering Committee."

This is the same answer that 57 people got. I'd be a little more okay with that if we all asked the same question, but we didn't. And this answer is irrelevant to my question. This happens very often.

March 5, 2013 - 2:12 pm

It appears that if I commented on a Credit during the 5th Comment Period I am unable to comment during this 6th Period. All I see is a message saying, "Thanks for your comment!
You submitted the following comment on 2 October 2012. USGBC will post responses to all comments after the public comment period has ended."

March 28, 2013 - 3:23 pm

I think the answer to the questions about the USGBC adopting as-yet-unnamed standards is provided in the introduction to this blog: "LEED's consensus-based, member-driven process requires substantive changes in rating system development to go through public comment." It would be helpful if someone from the USGBC confirmed this. Batya, can you address this issue, or find someone who can?

March 6, 2013 - 1:00 pm

This is fixed now

March 5, 2013 - 4:00 pm

Hi Bill - we're working on fixing this issue and hope to have it corrected very soon - I'll post again when it's been fixed.