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

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

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?

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

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.

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..

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.

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.

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.

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_
OR
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.

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.

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?

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?

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.

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.

Questions:
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.

Comment:
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.

Thanks,
Melissa

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.

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.

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."