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LEED 2012 – 2nd Public Comment – Performance (PF) Section

Key changes in the the Performance (PF) section of LEED-NC (part of LEED BD&C) in the second public comment draft of LEED 2012 are discussed below.
August 1, 2011

Do you have comments or questions on this draft? Discuss them below with your fellow LEED professionals. Substantive comments posted here during USGBC's second public comment period  will be submitted to USGBC and considered "official" public comments.

More information on LEED 2012 certification and the second public comment

Performance (PF)

As with the first draft, the second draft of LEED 2012 retains a new Performance section, which is a mix of new and old credits.

Major Changes

There are numerous specific changes to the new Water Metering prerequisite (required), but the gist remains the same: all water conveyed to the project—regardless of source—must be metered. Water consumption must also be submetered in five specific cases, with the common thread being applications using over 100,000 gallons annually, or 1,000 gallons daily in the case of process uses. Any reclaimed water source would also have to be metered. Finally, reporting of metering data, including submeters, to USGBC would be required for five years.

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Advanced Water Metering (1 point) builds on the prerequisite, not only requiring metering but also that meters and submeters be able to report data remotely, and be part of a management system that tracks performance and generates alerts for leaks or operational anomalies. In a change since the first draft, this credit includes submetering requirements that had been part of the prerequisite, notably submetering for any freestanding building using over 100,000 gallons annually, submetering of any tenant space, submetering of HVAC systems, and submetering of ornamental water bodies.

Fundamental Commissioning and Verification, a prerequisite, was moved here from the EA section in the first LEED 2012 draft. As with that first draft, the detailed requirements have numerous changes. The changes most notably make the credit language here more simple and straightforward, although the requirements remain lengthy. For example, the “Building Envelope” is a required system in this draft—a big change from LEED 2009—but this is a change from the first draft, in which “roofing assemblies and systems” and  “thermal, air, and vapor transmission properties of walls, roofs, windows and doors” were required. How much these wording changes are just wording changes, and how much they reflect a change in scope, may not become clear until LEED 2012 documentation requirements are developed. “Plumbing” also falls under the prerequisite’s scope, a change from LEED 2009, which only required commissioning of domestic hot water systems.

Enhanced Commissioning (3 points) would get increase emphasis, getting one more point than in LEED 2009. Similarly to the changes under Fundamental Commissioning, the language of this credit is much simplified since the first draft, but it may not be clear until later in the development of LEED 2012 whether the scope is also simplified.

This draft adds a third commissioning item not seen in the first LEED 2012 draft: Monitoring Based Commissioning (1 point). This credit would require both Fundamental and Enhanced Commissioning as prerequisites, and in addition, would require the development of monitoring-based procedures to be incorporated into the commissioning scope. Among other things, the plan would require a list of points to be trended with associated frequency and duration for trending, and limits of acceptable values for tracked points.

After the Occupant Experience Survey credit replaced and greatly expanded upon the LEED 2009 Thermal Comfort—Verification credit, in the first LEED 2012 draft, this new draft eliminates the credit entirely. The first draft would have required surveying of not only thermal comfort, but also air quality, lighting quality, acoustics, building cleanliness and maintenance, ergonomics, and opportunities for improvement. Results would have been reported to USGBC.

Minor Changes

The new prerequisite, Building-Level Energy Metering, is not significantly changed from the first draft of LEED 2012. Among other things, this prerequisite inserts directly into the rating system what has in LEED 2009 been a requirement found in the Minimum Program Requirements: that projects share energy data with USGBC for at least five years.

Advanced Energy Metering (1 point) partly replaces the seldom-pursued LEED 2009 measurement and verification (M&V) credit (see below for the other part). It includes prescriptive and performance-based paths revolving around installing permanent meters for whole-building energy sources. The meters would have to record data at least hourly, transmit data remotely, and be integrated with a data storage and management system. The credit has been reorganized in this second draft, particularly in terms of which project types must follow which requirements, but its overall requirements are not significantly different.

Reconcile Design and Actual Energy Performance (1 point) essentially builds on the “verification” part of the LEED 2009 measurement and verification credit. An M&V plan would be required—as it is in LEED 2009—but the M&V provider would also have to “prepare and submit a final report to the project design team and the building owner that describes the M&V program and its outcomes,” including actual energy use compared to the projected use defined by the Optimize Energy Performance credit (EAc1). There are only minor wording revisions to this draft of the credit.

What do you think of the changes proposed for LEED 2012? Questions? Post your thoughts below.


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September 12, 2011 - 12:34 pm

I already submitted my comments on this prerequisite to USGBC but just noticed the following that needs to be addressed. The revised language for reporting mentions only the submeters – not the “permanently installed water meters… for the building and associated grounds.” Was it an oversight that USGBC does not want the project wide meter data reported in addition to the submeters for 5 years?

September 11, 2011 - 9:04 pm

Overall, the prerequisites in this category are going to add significant cost to a base LEED certification over LEED 2009. I'd like to hear from commissioning agents out there as to what you think the fee increase for Fundamental Cx will be with the addition of envelope, all electrical, and plumbing to the commissioning scope.

In addition, most projects will be adding several extra water meters for the Water Metering pre-req.

September 16, 2011 - 9:23 am

Julie, you are correct, this is going to add cost to fundamental. For mechanical systems, it would be shifting some costs from enhanced to fundamental.

Electrical is too vague in this version, leading to uncertainty, which just like our financial markets, leads to wide variations in price and service. You can required anything you want, and good firms will follow those requirements, but there will be low cost providers that will submit just about anything and if there is no enforcement, there will be no accountability.

The envelope component is the most worrisome for me, in that there is a huge variety in scope for this service. We do not provide this service, but we work with several firms that do, sometimes as sub-consultants to us. They do extremely good work, and the service is extremely valuable. But I have learned that the scope is extremely important, and must match the owners concerns and budget; just like commissioning really.

I do not want to come off as totally negative, but I would like to see more definition to the Cx process, mostly to help providers to compete on qualifications and abilities, instead of who can get away with the least. It is also interesting that as we have been documenting v2009, GBCI is asking for less and less documentation for fundamental…which means less and less oversight to me. Yet they want to increase the rigor in v2012? Will they also increase the submittal requirements. As others have probably seen in some of my posts, we tend to submit everything…why not? We want to show a complete process and the documentation we develop for the owner anyway.

September 10, 2011 - 5:40 pm

In the Water Metering prerequisite it says:
"If reclaimed water is used for any water credit, that reclaimed water component must be provided with a meter (regardless of rate). If the reclaimed water system has a makeup water connection it shall be metered as well to facilitate the determination of the true reclaimed water component. In the Advanced Water Metering credit "on-site water reclamation systems plumbed to receive supplemental water (reclaimed, raw, or potable) from a municipal supply or a groundwater well must meter the supplemental makeup water and discharge from the system, if the projected amount of water is 50 gallons/day." These sound almost exactly the same to me, with tougher requirements for the prerequisite than the credit.

I think the language should exist only in the credit, and not the prerequisite, because it adds further required cost to a reclaimed water system, making it a less attractive option. (It's tough enough to interest my clients in water re-use!)

September 8, 2011 - 11:35 am

Following are some comments I would like to make to USGBC related to Fundamental Commissioning (and by reference to Enhanced):

1. The definitions seem very vague related to systems, by mentioning just Mechanical and Electrical. What about emergency generation? Electrical distribution? Many of these are important to Cx, but many clients already balk at the Cx fees required, and this would dramatically expand that scope. Perhaps this will be expanded in the reference guide, but it needs to be fairly specific. There are a lot of Cx providers out there that are using very minimal scopes to get projects from those that try to provide good service.

2. The systems manual seems to have been moved from Enhanced to Fundamental. Again, this is an increase in scope of Fundamental that does not feel appropriate.

3. The language related to envelope has been simplified, but could cause confusion. This is a new service for most projects, and the scope needs better definition. Fundamental Cx does not fully implement ASHRAE Guideline 0 or 1, but requires a subset of those tasks.

4. The path for “late” projects appears to have been closed in this draft…requiring early design. Of course this is the optimum and the best practice. However, since this is a prerequisite, it would preclude any project from entering the LEED process if decided after SD or DD. That does not seem appropriate for the prerequisite. Being more structured for Enhanced may be more affective…ie allowing a project to proceed, but not allowing additional credits.

5. It appears that peer review has been added to Fundamental at DD and CD. This should not be part of Fundamental, and should remain in Enhanced. I support more reviews, but as part of the Enhanced process.

6. There is mention of construction checklists being required in the CD phase. We typically do not include them, because the lists should be created for the equipment actually purchased, and that is only known after award and submittals are issued. Even in Fundamental, we still gather submittals, because they are required for the Pre-Functional Checklists and to write the Functional Performance Tests.

I do not wish to sound unsupportive of changes and enhancements to the Cx portions of LEED, but the addition of envelope while laudable and needed, it will be a sea change for many projects and perhaps should be either its own credit or part of enhanced (perhaps credits staged for inclusion) for 2012, then move portions to Fundamental in the next version.


April 19, 2012 - 12:45 pm

Does anyone think we would be able to apply for a LEED ID credit, for performing Building Envelope Commissioning on just the Mockup of the building as compared to the entire building for a LEED v3 NC project? We would then have a field team verify the installation during the course of the project, but what interval (monthly, bi-monthly, weekly) of inspections would be required?

September 13, 2011 - 3:06 pm


I posted this elsewhere but consensus decision-making and a majority of "votes" in public comment are not the same thing. The public comments are just one aspect of the consensus decision-making. See my comments in the EA section for more detail.

September 13, 2011 - 2:33 pm

Fundamental Commissioning Scope
Commissioning activities for envelope (a passive system) are significantly different in kind than for active energy-affecting systems. Inclusion of building envelope systems and assemblies in systems commissioned adds greatly to complexity and cost of implementation of prerequisite, for only marginal environmental benefit. In my experience with projects that have done commissioning with the scope of the proposed prerequisite, the cost of commissioning would be about double that of the scope as it currently stands in LEED 2009. Owners already balk at the cost of commissioning. This proposed scope will provide too much fuel to critics who charge that LEED certification is too onerous and costly. It may even be a deal-killer for many owners who are considering LEED certification.

In addition, most current commissioning authorities have little direct expertise with building envelope. This will require commissioning authorities to be multi-disciplinary firms or partnerships. This will also create additional liability for the CxA and will potentially eliminate or restrict current commissioning authorities, who do not have this multi-disciplinary expertise, from performing this work on LEED 2012. This shift in expertise and additional liability will cause many current CxA’s (including me) to get out of the business. This will have the opposite effect on the industry to that intended by USGBC, that is it will reduce the pool of competent people available and reduce the amount of commissioning performed.

This is much too broad if this is intended to include transformers, switch gear, wiring distribution and terminals, data closets and wiring and other non energy-affecting electrical equipment. This addition to scope would add greatly to cost, time and complexity for marginal environmental benefit. It would also add significant liability to the Cx scope and, like envelope, may cause many current CxA’s (including me) to get out of the business.

Recommendations to the USGBC
Delete building envelope from prerequisite and make building envelope durability the subject of a separate credit as LEED Canada does.
Restrict scope of electrical commissioning to lighting and lighting controls systems.

September 12, 2011 - 1:27 pm

Thank you Scott. I completely agree with all of your comments above. In particular, the addition of envelope Cx in the prereq. is too big a leap. Agreed that it is a move in the right direction but it is costly and there are few providers of the service in the market now. Moving the envelope Cx to the enhanced credit, or a credit of it's own, would be a better option. As pointed out by many response sent to USGBC on the 1st draft, envelope Cx will be very costly. Small projects are already losing on the cost/benefit of Cx. This added cost will likely turn owner's away from LEED.

I fully support raising the bar for LEED certification. However, it should not be a cost issue. Make credits tougher, not prerequisites more costly.

Also the new language in the draft refers to commissioning systems for "durability". This is part of the typical Cx process, but this term will need to be defined to avoid confusion.

Lastly, many comments have been posted about LEED no longer updated by "consensus". Although USGBC is putting the drafts out for comment, it doesn't appear they are acting on the majority opinion. Of the comments submitted on the 1st draft regarding envelop Cx 14 of 20 suggested it not be part of the prereq.