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

I haven't read the new draft yet, but what Bill was mentioning above does sound a lot like the USGBC finally does make their requirements more independent from third party systems.
I work a lot on no US based projects and I'm all for this kind of change. Because third party ratings systems, which are for the most part US-systems, put a big burden on non US projects. So far we had to use US products even though regional products would meet the intent of the credit also, but do not have the US label. Another example is the green-e power. There are barely any green power provider in Europe with this US-based label, but indisputable much more green power production in Europe than there are in the US. So why shouldn't I be able to take credit for it. I know I could always try to use special circumstances or CIRs to work around it, but this should be the exception not the rule. With a largely growing market for LEED outside the US and the need of international companies to rate and compare their buildings across the world this is overdue and I'm all for it.
In regards to the FSC certified wood same thing, there are other ratings out where. Why should the USGBC favor one over the other, if it can prove to be as good as FSC.

Hi Bill and Tristan -

Every credit and prerequisite that is new or has been modified in some way (including deletion) is open for comment. All aspects of those credits are open for comment, including the referenced standards. We are trying to evolve LEED in a way that moves toward more absolute performance metrics wherever possible - giving project teams the performance goal to reach without dictating how projects get there. If you have information that can show us additional standards that will move the LEED requirements toward more absolute performance metrics, we would encourage you to proivde us with that information. Please suggest it though public comment.

I was not referring to alignment across LEED rating systems. But alignment between non-LEED systems
- light pollution credit is aligned with the Model Lighting Ordinance (MLO) draft by the IES.
- energy saving credit is aligned with ASHRAE 90.1.
- low VOC credit is aligned with Rule 1113 by SCAQMD.
- water saving credit is aligned with EPAct 1992.
- acoustic performance is aligned with ANSI S12.60.
- thermal comfort is aligned with ASHRAE Standard 55.
- green power is aligned with Green-e.
- fuel efficient vehicles are aligned with the ACEEE rating guide.
- certified wood is aligned with FSC practices.

If someone has an idea to modify or change one of these items would they have a chance? What level of supporting information is expected for its consideration? We are limited to only non-formated text in our submittals. Are the TAG members from some of these other organizations and we'd have to convince them not to use their own idea in favor of ours?

I don't have a problem using existing systems from other organizations if they work. But if I'm convinced that it doesn't work and want to offer an alternative solution I'd like to know the time I put into the public comment won't be wasted.

Great comment on ADC, and I can only applaud MRFs which primary goal is to recycle and to do it transparently. However, please keep in mind the intent of MRc2 is to divert waste from landfills. The waste and recycling industry currently suffers from a creditability issue, simply from too many “recyclers” taking short cuts, and the result have been amazingly high recycling rates of C&D and other material in the past few years. This is simply from the industry becoming more focused on how to create documentation for LEED projects, versus actually improving recycling rates. Here is what I would suggest:
1. Do not permit ADC to be counted as landfill diversion. This will lower many MRF recycling rates by as much as 25% or more.
2. Continue to permit material that is used as a fuel source/fuel pellets for waste-to-energy plants (incinerators pay for this material) and not to permit waste that is being burned up as waste only (incinerators charge for this). Currently, there are too many MRFs including all the material they toss into waste-to-energy plants as recycled material even though it is not pellets, since no one is checking. Some facilities are sending as much as 50% of their waste to incinerators and claiming it as recycled.
3. Develop a third-party verification system of actual recycling rates at MRFs and other recycling facilities. This would result in two things:
a. It would quickly clean up the worst offenders in document fraud. These offenders are also driving the price down so that real deal MRFs cannot effectively compete in a fully transparent means. If 90% of the worst offenders were held accountable, then the real deals would be financially rewarded with increasing market share. I can safely say I am aware of facilities that have actual recycling rates around 10-20%, and are claiming 90% plus on documentation. This simply needs to be addressed in order to make MRc2 more creditable.
b. The actual recycling rates reported of real deal facilities would likely substantially drop by a third party verification system. That is okay since, they would still be much higher than any other company that did not invest in facilities, equipment and labor to recycle C&D material. However, since they are going to have a much higher market share, they will be able to invest in newer technology and focus on stronger backend markets to slowly work their real recycling rates back up. Going from an actual 50% recycling rate back toward 100, is much more in line with the overall mission of USGBC, then just reporting 95% plus rates that are not accurate.
We would submit a Pilot Credit for developing a third-party verification system, but we simply do not have the resources to do this in such short of a time. If anyone has any suggestions, I would love to know what they are.

It is unfortunate that I am seeing this too late in the game to make a comment that USGBC will be able to factor in to their decision. Also, I am sorry that I was unable to get to all of you earlier as well. First point of information about me, a disclaimer if you will. I work for a MRF (Material Recovery Facility) in Portland, Oregon. In theory, we should be your partners in recovery and recycling, we are an integral part of the process of creating new commodities out of your waste stream. Keep in mind, we don't generate the waste, we are the processor who could benefit greatly by keeping every pound possible out of the landfill. We make our money by NOT taking stuff to the landfill.

ADC, since it is the subject of this post, is something we recover here. ADC is also created in many legitimate recycling facilities, from dozens of different sources, so it is distressing to have it rejected out of hand because of the anecdotal reference to a few unscrupulous landfill operators in unnamed jurisdictions. At our facility, ADC is created from the fines left at the bottom of the dumpster, the loose material that is primarily small bits of concrete, drywall pieces, hard plastic and dust less than an inch in size. In Oregon, as in many other states, the ADC is regulated and authorized for use as cover by the State Department of Environmental Quality. They have recognized that since the EPA requires a minimum of 6 inches of cover every night for vector and odor control, and the cover previously used was clean soil, this represents a win-win for everybody.

I am more than happy to provide samples of the material that we sift out of the waste stream. Yes, this would likely go to the landfill anyway but it would go as general garbage, mixed with other non-recoverables and hence have no beneficial use. Perhaps a better methodology would be to clearly define ADC to prevent abuse of the ruling. By the way, one of the chief impediments to recycling or diverting many of the materials that come through this facility is how inexpensive those materials are on the front end. If we had a true life cycle cost analysis on the variety of materials that go into construction and later end up in the dump, perhaps there would be more value at the back end.

Last, certainly not least, is the issue of markets for the material that comes out of C&D. Without a viable market that is both accessible and cost effective, nobody in the chain of possession will have any reason or desire to make this all happen. An example of this is gypsum wall board. When it comes from demolition, it is often contaminated with paint or wallpaper. Yes, it is theoretically recoverable, however, nobody in our area has a facility or process that will recycle or reclaim this material because there are so few markets and it is expensive to reclaim. The only alternative is landfilling. When it is scraps from new construction, there is one possible vendor who will recover this material and the cost to do it is higher than landfill disposal as well as requiring full dumpster loads delivered 30 miles from the local Metro area. Green and sustainable works when all parties can share in the benefit or be responsible for the burden of the end result.

I wholehearted support this change to the MRc2!

I am so glad the TAG recognized that this was an issue and took steps to address it in the current draft. I especially liked hearing in the MR webinar the reasons the TAG felt were important for this change – specifically that ADC was not achieving the holistic goals of diverting materials from the landfill and harvesting those materials to avoid extraction of new materials.

Mark -

Thank you for your comment. Your comment reflects the intent the MR TAG had when drafting the updated langauge, which was aimed at changing the practices of this process.

We look forward to more of your comments!

Dear All,

I am in the process of reviewing the changes (their are tons) to the reference guide and will do my best to have a report out to everyone soon. Beyond the addition of schools, retail, hospitality and data centers which are all new to the reference guide, the USGBC has also decided to increased percentages and cut many of sections out. In order to make my report short and not very lengthy, I will give be giving brief overviews of each section and major changes. I will not go into credit-by-credit analysis, as that would be extensive.
I appreciate everyone patience and I look forward to hearing your thoughts.

Best,

Avkash Patel
LEED AP O+M
Aspiring Sustainability Specialist.

Avkash - I would also like to see the link to your analysis once it's complete.

This, and many other questions can be answered within our Frequent Asked Questions document, located here: https://www.usgbc.org/ShowFile.aspx?DocumentID=8447

Each rating system will go through a weightings process similar to LEED 2009. In LEED 2009, the U.S. Environmental Protection Agency’s Tool for the Reduction and Assessment of Chemi-cal and Other Environmental Impacts (TRACI) categories were used to determine a relative weight of each credit as compared with the others within a given rating system. For the update to LEED, USGBC has developed a number of impact categories more closely aligned with our mission that will inform the point allocation across the rating system. This process will take place between the first and second public comment periods.

Bill, I know I may be commenting on this late.
Just really started reading this board today.
Your comment "I'm sure if we asked every LEED AP who tested before June 2009 if they thought when they took their test that their AP would ever become obsolete I doubt we'd find anyone who would say they knew it was just temporary. They took it before the deadline because they didn't want the temporary AP from testing later. We didn't just convince ourselves of this."
is right on.
In 2.2 or 2009 my LEED AP status gave the same relevance as a LEED with Specialty.
The comment above that it's easy to convert is a little misleading.
There is no reason to convert under 2009.
By the time this draft become reality in 2012 the conversion option will be gone and basically you can only retest.
My office makeup has more than half the staff holding an AP, with only two individuals converting to the NC Specialty.
Many of us were taking some training to stay current a week or so ago when the discussion about the LEED Accredited Professional credit came up as it relates to the draft 2012.
It's caused quite a stir. Many thinking of converting now before the 2011 deadline utilizing the training option were surprised to find out from USGBC (by phone this week) that any training taken before converting will not count.
Thus each will be looking at 30 hours of prescriptive training after converting and before August or October.
As basically an organization/building owner with over $2,000,000,000.00 in design or construction over the next several years, registered or expected to be based on LEED principles to the maximum extent, it was not what most of us were looking forward to.

I agree with the idea of dropping the IP Credit: LEED AP.

The IP Credit: Integrated Process for EBOM could be modified to include a recommendation to use an integrated team including LEED APs to develop and implement policy regarding building operations and maintenance…since the intent of the Credit states, "Engage all key project team members for the purpose of making cost- and environmentally-effective integrated decisions throughout the design and construction process."

Tristan, I am going to agree with you. This credit should be dropped from the standards. Frankly, I did not get my AP or decide to proceed with the AP+ due to being able to get a client this credit...as an engineer about the only time we got be the person for this credit was our own building addition!

The reason we have the number of AP's and AP+'s is to show our prospective clients (owners and architects) that we care about sustainablity, and took the time and effort to gain some level of certification to that end. It also gives some credibility as you make comments since you made that effort.

Then I'd suggest that USGBC be a whole lot more up front about what's temporary. How does anyone know that 10 years from now the AP is only a stepping stone and LEED requires Fellows working on projects? Just to keep the credits advancing.

I'm sure if we asked every LEED AP who tested before June 2009 if they thought when they took their test that their AP would ever become obsolete I doubt we'd find anyone who would say they knew it was just temporary. They took it before the deadline because they didn't want the temporary AP from testing later. We didn't just convince ourselves of this.

I don't think this credit has ever been about improving the building. There is no evidence that an AP provides buildings on average better built, healthier to be in, or are more efficient. I've always viewed this credit as a carrot for people to earn the AP.

If the AP is worth their weight they would be able to earn more points on the project from their participation and knowledge. The score of a building should be based on the result, not the process.

I view this credit as different then the others simply because of statements made by USGBC outside of LEED. If they started out by saying v2.0 AP's could only count on v2.0 projects and v2.1 AP's towards v2.1 projects then I would agree. But they marketed the AP as universally applicable to all versions and all tracks because they wanted it attractive to people thinking about taking the test. They've dug their own hole by trying to develope cross-marketing brands. LEED and the AP. I don't see how their gaffe makes me the bad person for not agreeing to it.

I think a person with a CEM certificate from AEE on the design team and another on the maintenance staff would be more benefitial. Is there a chance to open this credit to other professional certification programs? The AP is no longer part of USGBC domain. GBCI took it over. I don't see why this can't be opened to other organizations if the two truely are separate.

It would be a whole lot easier if this credit went away. Not a prereq or credit. Let the value of a LEED AP stand on it's own. The cynic in me doubts they would ever give that carrot up. I'd give up any anger towards this change if the whole credit went away. Even though I wouldn't be able to earn my promised point anymore. See, I'm offering a compromise.

A couple of design workshops aren't enough. In my view sustainable projects need an advocate all the way through the process, while integrated design is absolutely required, a value engineering exercise could wipe away all of that good design work later. If the LEED AP credit goes away then the currently proposed integrated design section needs to be toughened up.

As an example I think the BREEAM criteria has a nice process with two stages.
First credit
1. BREEAM performance objectives are agreed, (and must be achieved at final certification – see Compliance Notes below) no later than the end of the design brief stage (e.g. RIBA Stage B or equivalent procurement stage).
2. The appointed BREEAM Accredited Professional or SQA is given the opportunity to attend key design team meetings (see Compliance Notes below) held from the start of RIBA Stage B (Design Brief) up to and including Stage E (Technical Design) or equivalent, and is to be included on the circulation list for minutes from all meetings.
3. A Design stage assessment report is submitted to BRE for interim certification.

Second credit
4. The first credit is achieved.
5. The project is reviewed against BREEAM performance objectives by the appointed BREEAM Accredited Professional or Suitably Qualified BREEAM Assessor (SQA) no later than the end of the Pre-Construction stage (e.g. RIBA Stage H (Tender Action) or equivalent procurement stage).
6. The appointed BREEAM Accredited Professional or SQA is given the opportunity to attend key design team meetings held from the start of RIBA Stage F (Production Information) up to and including Stage K (Construction to Practical Completion) or equivalent, and is to be included on the circulation list for minutes from all meetings.
7. A Post Construction stage assessment report is submitted to BRE for final certification.

I can see the point about the credit not being relevant; however I also don't think just because 99% of projects achieve the credit it should be discarded. Perhaps the requirement should be increased? (I think back to the water efficiency requirements, everyone was earning the points so it became as prerequisite and increased in difficulty) As I mentioned before I like some elements of the BREEAM AP. In order to earn the point the AP has to be a part of the project from a very early and clearly defined stage and the role / expectations are clear on what that person should do.

The following submittal doesn't really require added value to a project:
1. Provide the name of the LEED AP
2. Provide the name of the LEED AP's company
3. Provide a brief description of the LEED AP's project role(s)
4. Provide a copy of the LEED AP certificate

once on the USGBC website, "You do not need to pass more than one exam track in order to become a LEED Accredited Professional. All LEED APs are eligible to earn one point towards certification under ID/IU Credit 2 by serving as a principal participant on a project team regardless of which exam track was achieved."

What promise was made, because I seemed to have missed it?
It doesn't take much effort to become a non-legacy LEED AP......

Why? Because I have a pulse and care about the outcome. "Dissent is the highest form of patriotism." "As you gain experience, you'll realize that all logical questions are considered insubordination." Just going with the flow should be a crime.

I thought I've been very cordial in this topic and have been offering practical solutions.

I don't see how BREEAM relates. I'm discussing the promises that USGBC has made to the AP's who helped build the LEED name-brand over the last 10 years. The idea of treating legacy AP's as worthless does anger me.

oh!
1... 2... 3... 4... 5... 6... 7... 8... 9... 10
USGBC please don't break your promise. Darn, it's still coming out. Any other ideas?

Pete,

To put the LEED exam cost in perspective the BREEAM AP costs ~ $1,300 and travel plus a nice ~ $250 per year directory fee. I would say they are both worth the cost if you're serious about the sustainability business.

Bill,
Why are you so angry? Try to count to ten, slowly.

How about we copy BREEAM again and use some of their methodology again? They seem to have went through all of the same issues raised above also.
"BREEAM APs provide the design team with expert advice on built environment sustainability, environmental design and environmental assessment. They will facilitate the team's efforts to successfully schedule activities, set priorities and negotiate the trade-offs required to achieve a target BREEAM rating when the design is formally assessed.
Up to two BREEAM credits are available if a BREEAM AP is engaged from an appropriate point in the project."
Read all about it at http://www.breeam.org/filelibrary/BREEAM_AP_FAQs_12_Nov_2009.pdf

Hi Michelle -

That's a very interesting suggestion - thank you.

Thank you everyone for the feedback on this credit so far. We will continue to evolve this credit for the next version based on your feedback. Please keep in mind that regardless of how the LEED AP is recognized and incentivized in the version we are targeting to release in Q4 2012, updates will NOT change the current requirements in version 2.2 or version 3.

Often, the LEED AP on a project is an employee of the architectural or engineering firm during new construction/retrocommissioning. One of the issues I see to the integrated process is once the construction/commissioning is complete, the owner of the building has no "on-site" resource to go to for the maintenance and up-keep on the original design standards or intent of LEED.

If USGBC wants to encourage evolution of the standards by adding credits for additinal AP's on a project, then I recommend the additional credit only being applicable if the 2nd AP on a project team is an accredited LEED AP O&M that is an employee of the building owner.

This demonstrates full-cycle integration, which USGBC supports, but can not police. Having the continuity of a new construction project team member on-site after construction, in my opinion, is the evolution of higher value for LEED buildings.

Owners should be encouraged, possibly through this additional credit, to have a LEED AP O&M professional on their staff post construction. It may be the best way to ensure that the building is being properly maintained post construction and it is a great segway to applying for LEED O&M certification once the building has been occupied for 12 months.

Unless the second AP on a project provides on-going value to the building, I see no value to the building owner to have a 2nd AP from the architectural firm on a new construction project just to get an extra credit.

Michelle Jones, Ithaca College, Energy Manager, LEED GA

I’m not sure how many people remember, but there was a time when there was an ID credit for project team members in addition to the LEED AP (owner, engineer and architect) to become LEED APs. Over time that ID credit disappeared, but the credit is still a gimme. I see the proposed change as an attempt to evolve the credit (and green design in general) and make the credit less of a gimme…which I think is good.

I think the important thing to remember is the intent of the credit and of a LEED AP. The LEED AP, among other things is supposed to guide the process and manage LEED online, while being an advocate and “expert” in sustainable design and green principles.

The biggest problem I see with the credit is that almost anyone involved with the project can claim that credit, regardless of what level of involvement they have and what benefit they bring to the LEED/Sustainability/Green process. I’ve seen a number of projects go through certification and earn that point, while an inexperienced person does the documentation and manages the LEED process.

I’ve been giving a lot of thought to this proposed change, since I first saw it. I’d like to see the credit change, and possibly even a prerequisite added…something like:

PF prereq. 1 – LEED/Green Design Leadership

Intent: To encourage and educate green design principles and sustainability throughout the project.

Requirements:
1.) The LEED Project Administrator or person designated by them, will serve as the “champion” for green design principles, throughout the project.
2.) The “champion” will:
a. Be accredited as a LEED AP (with or without specialty) or
b. Be accredited as a LEED Green Associate or
c. Be accredited under a comparable different rating
d. Complete a minimum of ## (8?) hours continuing education during the project, ## (3?) of which must be LEED specific to the project rating system (these hours can be concurrent with other projects completed during the same timeframe)
3.) The “champion” will document and report information about the project including:
a. A summary of green design principles employed for major building elements and systems (site, envelope, HVAC, plumbing, electrical)
b. A description of team organization and how it fostered integrated design and green principles
c. “Lessons learned” derived from input from each key discipline and provide a report of these findings to all project members including:
i. Documentation process and requirements
ii. Summary of GBCI review
iii. Methods for improvement

PF Credit 2 – LEED Accredit Professional

Intent: To support and encourage the project team integration required by a LEED project and to streamline the application and certification process.

Requirements:
1.) The LEED Project Administrator or person designated by them, will:
a. Be accredited as:
i. A LEED AP (with a specialty applicable to the project)
ii. A LEED AP (without specialty) under the supervision of a LEED AP (with specialty applicable to the project)
iii. A LEED AP (without specialty) that completes a minimum of ## (8?) hours continuing education during the project, ## (3?) of which must be LEED specific to the project rating system (these hours can be concurrent with other projects completed during the same timeframe)
b. Provide a minimum ## (two?) hours of instruction or training to at least ## (two?) project members who are not accredited as a LEED AP (with or without specialty), LEED Green Associate or accredited under another rating system (Hours will be for each project member, not total)
i. Instruction shall include at a minimum:
1. Overview of LEED rating system
2. LEED documentation requirements and process
3. Role of the LEED AP
4. Etc.
2.) The Project Administrator will:
a. Identify and document inconsistencies, required clarifications and other information regarding MPR, LEED guidance documents, prerequisites/credit requirements, documentation, LEED Online, etc. for inclusion in LEED’s continuous improvement process

I know there’s a lot there, and many probably don’t agree, but…thoughts?

I don't think half points help. The original promise was that the AP could earn a point. It's already been diminished since it used to be 1 out of 69 possible. Now it's 1 out of 110 points. That's 63% of it's original value. Two points out of 110 for AP's is closer to it's original value.

Yes this point has always been a gimme. But how much can USGBC devalue the AP's. One AP used to be worth 3.8% of the points towards a certified project. With the current proposal, one AP is worth 0.8% of the points towards a certified project. With the increased burden of being an AP and it's decreased value, is it still worth being an AP?

I think USGBC has created themselves a problem with the original desire to get as many people accredited as possible. Their current proposal is not too bad if they were starting from scratch. But since they have the luggage of their old promises I think the best of a bad situation is not pretty. LEED AP's would be worth a total of 2 points rather than just one.

IPc2.1: 1-point:
The inclusion of any LEED AP as an integral member of the design team.

IPc2.2: 1-point:
The inclusion of a LEED AP with relevant specialty as an integral member of the design team. And a second project team member who can either be an AP with specialty (any) or a GA. (Neither of these two individuals can be the person claiming the point in IPc2.1.)

Has there been any clarification if you need 2 or 3 people now for this point?

And what are the legal repercussions for invalidating legacy AP's? Wasn't there some sort of promise/contract that AP's would always be able to earn a point towards LEED? Won't this lead to another time consuming lawsuit?

Somehow this is yet another step in devaluing what an experienced LEED AP brings to a project - owners are still so clueless about the experience rather than passing the test. Design firms who have loads of AP's on staff and then assign an entry level designer or intern to actually manage the project are probably to blame for this increased and ridiculous threshold. If we stopped marketing the letters and got around to marketing the experience of the specific individual who will be managing the entire LEED strategy this might not be happening - but that is probably asking way too much.

@Bill: Ouch

@Todd: I'm not convinced this isn't about increasing dues. I am also not sure the market has caught up. Speaking with people who are outside the green building community tends to not go far. I do appreciate aggressive regulations, but I'm not sure this is the credit to be aggressive with. Daylighting, for one, should be needs more credits/recognition as more and more people are using solar energy to power light bulbs. But yes - pushing innovation is very, very important in this business.

Well, I see requiring LEED AP+ is a step forward. It makes the LEED professional contribution current and valuable to the project. Besides it is a credit and if the team does not have enough LEED APs the project does not have to pursue this credit.

I agree that 3 might be a bit much, perhaps 1 LEED AP+ and 1 LEED AP GA will be more reasonable.

It's actually 3 people. One AP with relative specialty, + 2 others who can have any AP specialty or be GA's.

So legacies are worthless now? I'm sure that will go over well.

It is not a blatant attempt by the USGBC to increase its numbers, it is the next step in LEED by improving the rating system and moving the requirements to the next level. Remember, it is all about market transformation, once the market has caught up, you push it to the next level.