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Comment on the New LEED Rating System Draft to be Released in 2012

USGBC staff will be monitoring this forum, and we will submit all comments on the new LEED draft as public comments, on your behalf.
November 5, 2010

Update: Learn about the LEED 2012 3rd public comment period, March 1–20, 2012.


USGBC has released complete revisions of its LEED rating systems, and has opened a first public comment period, going from Nov. 8 to Jan. 14, 2011 (extended from Dec. 31, 2010).

USGBC asked us at LEEDuser to consider ways in which we could encourage members of our community to give feedback on the revisions to LEED, and we offered to set up this forum. USGBC staff will be monitoring this forum, and we will submit all comments on the new LEED draft as public comments, on your behalf.

So please review the LEED revisions and share your thoughts with the LEEDuser community and USGBC below!


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May 9, 2011 - 7:42 am

Could project currently registered under a rating system such as LEED NC 2009 opt to the new rating system such as LEED Data Centre at the time when the new rating system is available in 2012? If possible, how does it work?

August 1, 2011 - 6:20 am

April, there are still projects using LEED-NC v2.1, even though there have since been releases of LEED-NC v2.2 and v2009. GBCI did announce earlier this year that v2.1 projects would be required to complete certification or re-register with a newer rating system, but just to give you some idea, there is a long grace period.

You will have until the release of the LEED  2012 rating system, currently projected for Nov. 2012, to register under LEED 2009, so you have some time to see how the new rating system is developing and make your choice as to which is better for the projects.

LEEDuser has a guide to the second public comment draft of LEED 2012, and a forum for posting thoughts and questions.

July 6, 2011 - 2:28 pm

My question is when will we be required to use the new 2012 version of the rating systems? And is there a grace period during which we can continue to use 2009 versions or choose to upgrade to a 2012 version?

Here is the reason for this question: we do a lot of campus guidance credit work with local campuses. We are required to submit both the campus credits and the individual project reviews under the same version of the rating system. Thus, we are trying to figure out how to help campuses plan ahead for submission of campus credits and individual facilities. An easy way to do this would be to register all of their proposed projects now. Then they could use the same previously approved campus credit submittal for all of these projects. This would create the greatest efficiency in time and money. Alternatively, if the individual project would rate better under LEED 2012, then we could choose to upgrade just that project to not use campus guidance and/or begin working on the 2012 campus guidance upgraded submittal.

The only slight answer to this question that I have found is from the "LEED Rating System Development FAQ" document:

Q: "I have projects using a current or older version of LEED. Will these projects be required to follow this proposed updates?"

A: "Projects currently registered with LEED should follow the version under which they are currently registered. Project teams will not be required or able to register for the updated rating system until it has undergone a ballot vote by USGBC membership. Prior to ballot, the proposed rating system will go through at least two public comment and response periods. Projects that have not yet certified at the time of launch will still be able to certify under the rating system which they are registered."

May 19, 2011 - 11:55 pm

William, that should be possible, yes. You would simply register a new project under LEED 2012.

April 6, 2011 - 4:51 pm

I am please to see the draft LEED reference the EPA WaterSense fixture specification, but I have concern -- the current use of WaterSense for urinals and commercial (flushvalve) toilets, does not take into account the manufacturer effort to "Universalize" the fixture and establish flow-rate from the flush-valve volume.

A single urinal that we manufacture, like our Washbrook, will operate effectively at a range of .125gpf - 1.0gpf. This simplifies inventory, eliminates duplication of packaging and technical documents, and allows selection of multiple flush options depending on the facility requirements.

But today, this same urinal exceeds the maximum of WaterSense of .5gpf. The system of Flush-valve and fixture is what should be considered, or only the flush-valve upon which we base the system flush volume.

The WaterSense guideline does not yet address specialty fixtures for children, hospitals, prisons, clinical application.

January 14, 2011 - 12:17 pm

Requirements referrers to Appendix A. Provide Appendix A in next round.

January 31, 2011 - 8:08 pm

I literally get dozens of calls a week from people either looking to take one of the LEED exams or trying to understand the credential maintenance process. There are two components:

1. I completely agree with the need for a continuous raising of the bar. How can we expect teams to design better buildings if they're not learning about the newest technologies, processes, etc? It's like expecting increasingly efficient businesses without online project management tools, time sheets and workplans. It's simply absurd.

2. I completely agree that USGBC and GBCI could have done more to prepare people for the transition. It was really a matter of time before this credit came to pass (or at least be considered). Not only did they do a poor job communicating the requirements, but they did a great job making the life of LEED AP's a nightmare. Why not give numbers and enable providers to submit credits? Why no maintain the one-time-a-year CEU deadline? AIA and other organizations do this, and it makes life easier for people. At some point in the near future, LEED will not be as dominant as it currently is, and USGBC could have used this as an opportunity to address this criticism. It was a serious missed opportunity for them.

January 14, 2011 - 2:06 pm

SS Credit: Heat Island Reduction
Please change
"Use open-grid pavement system (at least 50% pervious)"
to read:
"Use open-grid pavement system (at least 30% pervious)"
There are very few concrete grid paving units with 50% open surface area or 50% pervious materials at the surface that meet ASTM C1319, the product standard for concrete grids. Most concrete grids are 30-40% open surface area as the remainder needs to be concrete for structural support of vehiccles.
As written, the 50% percentage excludes all concrete grid systems and I don't think that was the intention of the writers. 30% minimum pervious materials at the surface allows for sufficient grass to grow and provide cooling as intented by this credit.
Concrete grid systems can be completely covered with topsoil (not just openings) and sodded or planted with grass seed such that the entire surface is grass. That is not typically done, but it is a design option that can help further achieve this credit.

SS Credit: Rainfall Management
Please clarify "Manage onsite the runoff from...." I understand the 95th percentile event. However, one could interpret "manage onsite" as a means (or excuse) to detain and slowly release the 95th percentile rain event with a large detention pond when a permeable pavement might be more cost-effective and consume less land. I don't think encouraging detention ponds is the intention of this credit. I am respectfuly requesting to please find words that encourage volume reduction on site which of course directly helps pollutant reduction. This suggests a greater emphasis on onsite infiltration whenever possible. Thank you.

January 14, 2011 - 12:11 pm

Clarify Option 2: " Meet the requirement of Option 1." If you meet Option 1 why would you consider Option 2 with the addition of All materials must have 3rd party certifications....

January 14, 2011 - 11:58 am

Bicycle Network: Coordinate speed limit miles per hour with LT Walkable Streets and LT Alternative Transportation. At least in our area 25 MPH is as low as speed limits go unless at a school zone, prefer the target speed of 25 MPH for residential and target speed of 30 MPH for commercial or mixed use.

January 14, 2011 - 11:47 am

'The figures above may be used to determine occupancy for the following Credits: ' This is obvious, the following credits all need to be redefined to the new rating system. Example: There is no longer an SSc 4.2 it will be a LT something.
Please don't define Gross Square footage in a text. Move definition to glossary.

January 14, 2011 - 11:24 am

Under Bicycle Network: Define "all-weather route".
Also, "....designated for completion within the fiscal year that the constructing organization finalizes plans." Consider making this 2 years to be consistent with LT Reduced Automobile Dependence, Option 1 and LT Alternative Transportation, Path 1.
Under Bicycle storage, Case 1: Define "enclosed".

January 14, 2011 - 11:08 am

Under Concept Design Integrated Workshop: This indicates ‘at least 4 of the following skill sets..’.Which seems fair. Consider adding Landscape Architect, and Commissioning Agent to the list. Clarify, does MEP only count once, or do the electrical engineer count and the plumbing engineer, and the Mechanical Engineer count if they are separate entities?
Under Construction & Operations Trades and Building Operations Team Training: Consider the 'at least four of the following skill sets..." like above. Consider adding Finishing Contractor- Painter. Clarify Building Envelope. Do you want the exterior painter or the waterproofing contractor?

January 14, 2011 - 10:07 am

Hi all,

I've been working mainly on LEED projects outside the US (AUS+DK). I'm afraid I have to say we have met numerous problems not directly connected to the level of Energy and Environmental Design quality requirement but related to the LEED national approach.

Numerous future sustainable building ratings will occur outside the US, and if the USGBC does not take that soon into consideration, the owners, builders and consultants will start (or continue) using other rating systems.

More and more clients ask us which sustainable building rating system should they go for. And it seems, that LEED is the only one that has not started to work more locally.

LEED needs to be adapted for each country / region and not just through regional priorities. I advise acutely the USGBC to work more closely with the other national GBC or local partners.

January 14, 2011 - 10:43 am

Thanks for your response Tristan. I definitely will.

January 14, 2011 - 10:31 am

Nicolas, you should check out the "LEED International" effort that USGBC is actively engaged in. There is more info on that on their homepage. There might be a way to get involved in supporting it, too.

January 12, 2011 - 11:13 am

Am I to understand correctly that energy reduction will now be based on not only site energy (by cost), but also the source EUI? It seems that source EUI is based almost entirely on what geographic region the project is located in (i.e. energy mix from eGrid). I understand the desire to pull in this important factor of energy efficiency, but it raises a whole slew of issues:
1. This is more a Location and Linkages credit since it is based on geographic location of project. Even then, most LL credits can be earned by moving a project across town, but to make a significant change in primary EUI, would mean a move across the state or even nation.
2. This isn't something the project team really has control over.
3. The difference between the source and site energy has nothing to do with the efficiency of the building.

Any thoughts?so

January 10, 2011 - 8:39 pm

This comment applies to issues across several of the MR Materials Credits (recycled content, materials reuse, regional materials and biobased materials)

COMBINE THE CREDITS: This set of credits are just calling out to be consolidated into one combined credit where materials meeting any of these attributes may be added cumulatively toward the potential points. Too often these credits are bypassed entirely because getting the last couple of percentage points to reach a threshold is too hard. Or efforts stop short once the threshold is reached since there is no incentive to continue beyond the threshold except to use up a valuable innovation credits and even then only if the team can come up with enough materials to reach a new threshold. Pooling these credits together would encourage teams to maximize the amount of materials in each attribute category instead of just shooting for thresholds.

The new LEED for Healthcare 2009 has already demonstrated how this could work with a credit structure that has gone through substantive public comment (see MR Credit 3: Sustainably Sourced Materials and Products at http://www.usgbc.org/ShowFile.aspx?DocumentID=8257http://www.usgbc.org/S... page 57). In brief the concept is to add together the value of materials meeting any of the requirements (reused, recycled, regional, and certified wood (see comments below about biobased/rapidly renewable)), determine the combined percentage of the whole and give a point for each 10% of the total material bill. For full alignment with LEED this would be a 7 point credit, post industrial recycled content would get half credit and reuse would get double credit.

Most of these attributes are exclusive (only one attribute should apply – no double dipping). Regional materials may be the exception.

DON’T DROP STRUCTURAL: I understand the dilemmas that certain structural materials – particularly steel and to a lesser extent concrete - raise with their high volume and growing levels of standard practice recycled content. Use of structural materials can quickly consume the credits with standard practice materials and hence give credits too easily and eliminate pressure to address other product categories. There are other ways, however, to address these challenges without dropping all incentive for improving structural material performance. Again LEED for Healthcare addressed this (see above reference) by setting limits on the concrete and steel structural elements applicable to the credit and mandating a minimum percentage of other products: “If concrete or steel structural elements are applied toward this credit, the project must include at least two other materials or products from CSI MasterFormat Divisions (other than 03 and 05) to attain the first point. Of the total recycled content, no more than 75% may be steel or concrete.”

BIOBASED – CERTIFIED LEGAL HARVEST WOOD PREREQUISITE: Providing a credit for using 10% non structural wood in a project, is too easy for a leadership standard. I suggest dropping this credit and instead adding a prerequisite that all wood used in the project have a certification that it is legally harvested. For all the controversy about the benchmarking proposals in the forestry debate, this is one that I expect all sides should be able to agree upon.

BIOBASED – REQUIRE CERTIFICATION FOR RAPIDLY RENEWABLES: Rapidly renewable products can have serious health and sustainability problems depending upon how they are harvested. Good certification program exist that should be required for agricultural/rapidly renewable products just as they are for forest products.

January 19, 2011 - 8:01 pm

I also agree with what Tom Lent has posted above.

Combining Credits – If the materials credits are combined then teams would pursue materials with the best attributes instead of what they need to get to a certain percentage and not investigate alternate materials further.

Keep Structural Elements – Materials credits should keep some portion of structural material that can count toward the overall percentage. You could consider limiting the amount of structural materials that can count toward the overall percentage rather than eliminating them altogether. For some projects in very remote or island type settings, structural materials may be the only way to achieve regional materials for example. I also agree with Linda Smithe’s comment that it may become very difficult to delineate what materials are structural vs. non-structural and increase the complexity of documentation.

Prerequisite – The idea of a prerequisite is good but if it remains just for recycled materials this may actually be difficult for some projects to achieve depending on their geographic location, what materials are readily available, and what the structure and interior consist of.

January 14, 2011 - 10:51 am

I agree with above as well.
I would like to add I do not suggest a prerequisite for recycled material.
From the on line webinar it was discussed that the Recycled Content points are always being achieved, the market has transformed itself which is good. So just raise the percentage to continue the market transformation.

The MRc 4, 5, 6, 7, points are very time consuming (expensive) for contractors to document and some teams think they are not worth the effort. By making it a prerequisite you force them to do the documentation for what was in the past very few points and again if it is understood almost every project gets this because of market transformation, why are you making the contractors document it?

Also changing the way you document certain materials structural vs non structural just adds to complexity and confusion. Keep it consistent. Where would you put structural door frames? Is the block wall a structural shear wall or load bearing wall or just a fire proof partition? I believe, drywallon the underside of trusses adds shear stability.

January 14, 2011 - 10:51 am

I agree with above as well.
I would like to add I do not suggest a prerequisite for recycled material.
From the on line webinar it was discussed that the Recycled Content points are always being achieved, the market has transformed itself which is good. So just raise the percentage to continue the market transformation.

The MRc 4, 5, 6, 7, points are very time consuming (expensive) for contractors to document and some teams think they are not worth the effort. By making it a prerequisite you force them to do the documentation for what was in the past very few points and again if it is understood almost every project gets this because of market transformation, why are you making the contractors document it?

Also changing the way you document certain materials structural vs non structural just adds to complexity and confusion. Keep it consistent. Where would you put structural door frames? Is the block wall a structural shear wall or load bearing wall or just a fire proof partition? I believe, drywallon the underside of trusses adds shear stability.

January 12, 2011 - 11:31 am

Just wanted to chime in here and second what Tom said here, especially combining the credits and keeping the structural in the MR credits. Maybe combining the credits is something that has to be pushed to the next set of revisions, but please find a fair way to keep some of the structural material in the MR credits.

January 6, 2011 - 5:56 pm

How can I contact Avkash Patel who was willing to share her review comments?

January 6, 2011 - 12:58 pm

This is more of a structural comment. It is a little confusing that there are two options listed, but option 2 requires option 1 to be met. I'm assuming this would be 2 credits and option 1 would be one credit? Why wouldn't this just be structured to have 2 credits available, one for the first set of requirements and the second for meeting all?

December 21, 2010 - 1:27 pm

IEQ Prerequisite 2 Environmental Tobacco Smoke (ETS) Control - Prevent or minimize exposure of building occupants, indoor surfaces and ventilation air
distribution systems to environmental tobacco smoke (ETS). Weather-strip all doors in the residential units leading to common hallways to minimize air leakage into the hallway.

Demonstrate acceptable sealing of residential units by a blower door test conducted in accordance with ANSI/ASTM-E779-03, Standard Test Method for Determining Air Leakage Rate By Fan Pressurization. Use the progressive sampling methodology defined in Chapter 4 (Compliance Through Quality Construction) of the Residential Manual for Compliance with California's 2001 Energy Efficiency Standards. Residential units must demonstrate less than 1.25 square inches leakage area per 100 square feet of enclosure area (i.e., sum of all wall, ceiling and floor areas).

One intent of this credit is to weather-strip doors, to prevent cross-contamination to non-smoking units. While there are 2 options for room assembly requirement and testing, there are no requirements for the standard that door gasketing and weather-strip must meet - this will make it difficult for architects to specify the correct gasketing and insure that the room assembly tests to the standard.

I propose to USGBC that we use perimeter gaskets and seals that have been tested in accordance with UL 1784-2001 Air Leakage Tests of Door Assemblies, and meet the performance criteria for allowable air
leakage as specified in NFPA 105-99 Installation of Smoke Control Door Assemblies. Gaskets and seals meeting these standards should meet the intent of IEQp2.
This standard may benefit IEQc5 as well!

December 16, 2010 - 1:08 pm

As mentioned above in November the USGBC began a public comment period on an updated version of the LEED Rating system and EQc4.0 is updated within it.

According to the USGBC, it is expected that this comment period will lead to substantial changes and improvements to the proposed draft credit revisions. As someone who works with LEED on an ongoing basis you want it to not only represent the best in sustainable building, but also be understandable and easily implemented.

Unfortunately there are some problems with the draft credit language for IEQ Credit 4.0 (and therefore the above Pilot Credit) and if not fixed they could have a negative effect on the indoor environment in these high-performance green buildings. These issues include:

• The proposed low-emissions credit fails to make product emissions requirements more stringent. They still only look at 35 individual chemicals and then only certain products do that many chemicals. Some product types look at the total chemicals emitting from a product and others don't. Yet there are 10,000 individual chemicals that can come off man-made products. Only 10 of the top 100 that are most commonly seen coming off of products are in the 35 individual limits. This is not protective enough for a sustainable building.

• At a time when pollutant source control is desperately needed to protect human health, the proposed credit introduces a layer of complexity that will likely discourage project teams from pursuing it. Instead of simply telling you what standard a product should follow it is asking you to do complex calculations. We have been told by numerous LEED professionals that due to this complexity they are likely to skip this point altogether.

• Differing product emissions requirements within the proposed credit mean that LEED Certified buildings in North America could have worse indoor air quality than those constructed outside of North America. There are different standards allowed for buildings outside North America - standards that look at hundreds of individual chemicals for many products, yet within North America the limit is only 35 individual chemicals.

• Poorly defined and inconsistent product emissions criteria and test methods within the proposed IEQc4 mean that some qualifying products could emit higher levels of chemicals than others, posing a significant exposure risk. Different products are held to different chemical emission criteria - this would be like having different chain of custody rules for wood used on the floor and wood used on the wall. All products in our indoor environment should have to meet the same chemical emission criteria.

• A lack of direction, appropriate reference methods, and verification requirements in IEQc4 will lead to confusion, misapplication, and abuse of the credit, which will have a detrimental effect on indoor air quality. Some of the current reference methods have 6 different pathways to show compliance. These different pathways will likely lead to completely different outcomes – leaving the system easy to manipulate, as manufacturers can simply pick the path that shows their product is low-emitting when in actuality it may not be.

All comments must be submitted to the USGBC by January 14th!

Please help protect the health of LEED building occupants by submitting your comments today. For more information on the proposed language, sample comment language and instructions on how to submit comments to the USGBC, please visit www.greenguard.org/pledge

Thank you again for your commitment to good indoor air quality in green buildings .

December 17, 2010 - 7:48 am

Further discussion of this credit will be limited to the PIlot Credit 21 forum on LEEDuser. Please read and discuss there.

December 16, 2010 - 10:57 pm

I am writing this from Beijing, where I am one of two U.S. advisors to a government research team developing a low-emitting furniture standard and certification program. Therefore I unfortunately have little time to respond in detail just yet.

The technical issues raised in Josh's comments are complex, and include some valid concerns worthy of legitimate debate. However, these comments also reiterate and expand on the inflammatory and inaccurate claims available at www.greenguard.org/pledge that may unnecessarily instill fear and confusion.

These claims include:

“The proposed IEQc4 fails to make product emissions requirements more stringent.” And “…the proposed changes—if accepted—could result in the creation of unhealthy interiors in all LEED Certified buildings, including schools.” And “Rather than raising the bar on indoor air quality and requiring rigorous, comprehensive chemical emissions limits, the proposed IEQc4 encourages adherence to weak product emissions criteria and insufficient test methods. This is alarming, given that the intent of IEQc4 is to safeguard against poor indoor environmental quality. Moreover, the proposed revisions to IEQc4 all but ignore the serious concerns with indoor air quality that were raised in the April 2010 report, LEED Certification: Where Energy Efficiency Collides with Human Health." And now ”...manufacturers can simply pick the path that shows their product is low-emitting when in actuality it may not be."

These claims are categorically false.

The proposed IEQc4 credit significantly strengthens the USGBC requirements for indoor environmental quality. Notably, it adds VOC emissions requirements from the California Department of Public Health (CDPH) to paints, coatings, adhesives, and sealants where only VOC content was previously addressed. It expands the scope to address more VOC sources within a building (thermal and acoustic insulation, all individual furniture items, all layers of ceilings, floors, and walls, and built-in cabinetry). Previously ceilings were not addressed in all rating systems and emissions from insulation, individual furniture items, and built-in cabinetry were not addressed at all. It adds CDPH Chronic Reference Exposure Level (CREL) based requirements for furniture. If you are not aware, CDPH requirements include one of the toughest formaldehyde emissions criteria in the world.

Continued legitimate debate about the credit content is vital to this process. The good news here is that the proposed credit is stimulating this debate, even if some participants may be motivated in part by keeping their proprietary programs written into the credit language. I encourage others, especially members of the USGBC IEQ TAG and the USGBC IEQ working group who participated in the 1.5 year effort to draft the proposed credit, to participate in this discussion.

Josh has posted his comments on two forums; this one focused on all LEED 2012 proposed revisions, and the one focused on Pilot Credit 21 Low-Emitting Interiors. I will post my initial response on both, but I suggest we shift the detailed commentary to the Pilot Credit 21 page, as it focuses specifically on the credit under discussion.

I plan to post additional responses to the specific concerns as I can make time available while traveling. A detailed FAQ document that addresses many of these issues is available on the LEEDuser.com pilot credit 21 page, or at this link: http://www.leeduser.com/system/files/sites/default/files/EQc4-PC21_FAQ_3....

These issues are not simple nor easy. Good people are struggling with these all over the world, and there is certainly room for improvement in the proposed credit. I am confident that this debate will help us to make the LEED program even better.

December 16, 2010 - 1:35 pm

Thanks Tristan - as soon as we have our suggested credit language I will post here.

December 16, 2010 - 1:28 pm

Thanks for the additional background. You can edit your profile with a title and company so that that info appears, under "my account" in the top right of the screen.

December 16, 2010 - 1:25 pm

Sorry - thought my title came through with my name. I am Technical Information & Public Affairs Manager with GREENGUARD Environmental Institute. Actually we are working on our full comments right now, but we have posted some initial comments that people can look at on our website.

Also, as currently written GREENGUARD Children & Schools would still qualify any product certified to it to comply with the credit - so our concern is not about whether GREENGUARD will be impacted or not.

We are very concerned with the impact that the credit could have on sustainably certified building . This credit will get used even less then it does now; it gives different criteria to different products (under the same credit) and it opens up the possibility that people could be exposed to more chemicals - which shouldn't happen in any circumstance, but especially not in a sustainably certified building.

December 16, 2010 - 1:16 pm

Josh, what is your suggestion on how the credit should be written?

I noticed you're with Greenguard, which would be directly impacted by the proposed revisions. We appreciate it when people on our forum disclose connections like this when posting. It will help us  focus on the principles of your suggestions rather than be concerned about potential biases. Can you comment on how this affects Greenguard and your thoughts on that?

December 13, 2010 - 11:34 am

Your analysis of the draft is great, but few comments on Cx. There are many major changes to the Cx requirements. These changes will greatly affect the commissioning process, scope, schedule, and cost. Has there been any response on the Cx portion, and if so where are they located. Thanks.

January 17, 2011 - 6:06 pm

Doug, regarding a response to your comments, I don't think specific  comments necessarily receive a response from the technical committees. Over 3,000 public comments are expected in all for this round. Also, I need to reiterate that our organization is not a part of the USGBC and we are simply facilitating this conversaton with USGBC's cooperation.

January 17, 2011 - 5:59 pm

Erik, thank you for reviewing my comments and posting a response. Our firm is proactive and will meet the requirements. That being said, roles and responsibilities are very important when trying to train and hire staff to meet the requirments. The more information the better. Tristan, how/when should I expect to hear the committies response to my questions? Thanks.

January 12, 2011 - 12:55 pm

Doug- I agree that the new requirements will significantly effect the cost of commissioning. Given that the general population of owners do not understand Cx today, the price tag on Cx will blow them away. Specifically the requirements for, 1.) A water vapor transmission analysis of all exterior envelope types used in the building, and 2.) Confirm building envelope materials and their installation are in compliance with the contract documents.

Not only do these activities increase cost, in labor, they present a much greater level of liability to the CxA. Higher liability=higher cost. Given these cost implications, I don't believe Cx can be considered cost effective for most projects.

I also agree that many Cx firms do not have the expertise to perform envelope testing. But we too have to learn and take the next step.

December 22, 2010 - 5:28 pm

Doug, if you scroll down just below the text you pasted ("Guidelines") you'll see three buttons to the lower right—"Expand." Click on these and proceed.

December 22, 2010 - 5:17 pm

Our concerns are many, but I will list the major ones. There are many new items added to the "Commissioned Systems": Building envelope, testing of air flows, Roofing materials and installation, water systems including irrigation. This will add to the scope of the CxA, and greatly increase cost for an owner, but my concern is who is intended to perform these test and verifications? The CxA typically will witness the tests and do the paper work. The addition of the data center sections in the sections need definition. The NEC defines a data center. In this section a "data center" is defined as a space of 20 watts/square foot or more. Is this active or passive? this could be any telecom room. This is a very short summary, considering the review items filled three pages, but in conclusion, our concerns are two fold. Since cx is a prerequisite, the customer will now be paying triple the cost. Are CxA firms expected to absorb all of these new responsibilities? Also, I still can not find the "Online comment form" required by usgbc. See below.

Guidelines for submitting comments:

•Comments are only accepted via the "online comment form."
•Each respondent may submit only one set of comments on any individual credit.
•Comments may not be edited once submitted.
•Representatives of USGBC member and non-member organizations are encouraged to submit comments collectively.

December 22, 2010 - 4:52 pm

I'd be delghted if you can share your comments in general form here. Here is a link to USGBC"s page, but you might not like the format they provide any better.

December 22, 2010 - 4:48 pm

It appears as if the site removed the spaces between the letters and number of the format I suggested. Without proper spacing, number, ittalics, etc, it will be almost impossible to read my comments.

So where do I submit my concerns for the commissioning sections? I have them in word form, and they are somewhat specific. I can certainly put them here in a generic statement, if necessary. The USGBC site says that there is an online comment form, that I can not find. If you could direct me to that document, that would be great. Thanks.

December 22, 2010 - 4:40 pm

I see. That's up to USGBC—seems like a good public comment fo them!. LEEDuser is an independent publication. We are trying to provide a forum to foster dialogue about and improvement of LEED.

December 22, 2010 - 4:38 pm

B. 1
That way it would be easier to comment on a single word or sentence.
The copy of the BD&C Redline that I downloaded was sectioned, but no numbers or letters. I will paste my comments in the next post. Thanks for your quick reply.

December 22, 2010 - 4:29 pm

Doug, you can post your comments right here on the forum in any organizational form you prefer.

I'm not totally sure I understand your comment about the outline format, sotTo be clear—what's being commented on are USGBC's new drafts of LEED, not my own commentary posted on the top of this section. Those drafts are quite well organized in the way you note.

This forum is simply organized by threads that people post—so it's up to them.

December 22, 2010 - 2:08 pm

Tristan, how would I go about uploading my firms review comments? Also, for future reference, it would probably be easier to review and make comments if the document was arranged in an outline format with numbers and letters. Thanks for your time.

December 13, 2010 - 12:00 pm

Doug, I would love to see someone like yourself who really knows the subject to expound on what the key changes are, and what you think of them. Any takers?

December 7, 2010 - 3:49 pm

I just got word that the comment period has been extended! Please post your comments on the new draft of LEED here, or on USGBC"s form.

December 7, 2010 - 4:07 pm

Yes, Randy you are correct - it is January 14th, 2011 for the close of 1st public comment. I accidently typed the incorrect date to Tristan for this forum.

December 7, 2010 - 4:07 pm

You're right, it's 1/14. I guess 1/11/11 just looked too exciting.

December 7, 2010 - 4:04 pm

I think the deadline is January 14, 2011, at least according to a Dec. 3rd note sent to the corresponding committees for the TAGs. If anyone confirms differently please post a response. Thanks.

November 29, 2010 - 3:46 pm

Are there any portions of LEED not open for comment? In another thead I got the impression that LEED tries to align with other systems. And that desire for alignment might trump public comment. I'd prefer to make comments relating to the LEED system when LEED is open for public comments. Not having to chase after other rating systems and try to change those to have an affect on LEED. The extreme example is, if someone has a better way for energy modeling buildings (either a tweak or whole scale change) than ASHRAE 90.1 Appendix G. will their public comment be giving the time of day? Or be dismissed with a "not enough information is known" comment?