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International Projects - alternative compliance path

A guideline for alternative compliance paths
Susann Geithner
October 24, 2011

According to the USGBC about 40% of the newly registered projects are now non-US projects. So finally the USGBC provides new guidelines for international projects.

A guideline for alternative compliance paths for the following credits:

LEED NC 2009

SS c1, SS c3, SS c4.1, SS c4.4, SS c6.1, SS c8

WE c1

MR c5

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IEQ P1, IEQ P2, IEQ c1, c2, c3.2, c4.3, c5, c6.2, c7.1, c7.2

Sorry nothing for EA P2 or c1. But I have heard at the Greenbuild that they are working on it. Also if you are using LEED CS, NC Retail, Schools or Healthcare you might still find these helpful.

You can find the draft of those guidelines here. http://bit.ly/tTjUr5

Also new a conversion tool kit and supplemental forms: http://bit.ly/tvnQHT

I haven't read through it yet, but I would like to heard what your think and please also post what else you'd like to see. The USGBC likes to read through your posts, too.

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Comments

January 31, 2012 - 2:47 pm

I have received a couple of emails and inquiries from especially European project teams in regards to the standards referenced in LEED EBOM for Green Cleaning.
So here is the current situation. In order to meet the requirements of "Green Cleaning—Purchase of Sustainable Cleaning Products and Materials" your cleaning products will have to meet either Green Seal or environmental choice CCD standards. Both are certification common in North America, but uncommon international.
This results in the fact the international projects (non US, or Canada) can not apply any of those credits (I know that from talking to colleges in Europe and my own projects). I have checked the new ACPs as well as LEED Interpretations and there is nothing to help with this issue. Also the draft of LEED 2012 does not address that issue. So at the moment there is no solution.
However I have found one work around for projects with ionized tap water in lieu of chemical cleaning solutions. see credit interpretation ruling 11/1/2011 ID# 10141 This is also incorporated in the new LEED 2012 draft.

Nevertheless there is a growing demand for LEED EBOM on the international market and for quiet a few credits there is no alternative approach for international projects. So now you may say, how about showing equivalence of European standards like Ecolabel, Blauer Engel, ... with Green Seal or CCD. or even the products itself. This is very comprehensive, expensive and for a certification of operations and maintenance also something that can change very quick with products selection. This is the reason I keep hearing, when asking why do you not do that.

Here is another problem often mentioned by the US-certification representatives, the requirements in Green Seal do not translate one to one into for instance the European Eco Label. Some contents are not covered, others are measured differently. This is also due to the fact that Europe as a lot of regulations already that prohibit the use of certain chemicals or limit others.

My personal opinion in this matter is that this needs a solution proposed by the USGBC written in the LEED 2012. It's costly and not maintainable for project teams to work on showing compliance of one standard vs another.

I hope to hear more from other projects teams in regards to this matter or even solutions and ideas.

February 1, 2012 - 10:59 am

Hi Susann,

Thanks for your comment. As Deon mentioned below, we are currently seeking feedback on the LEED 2009 ACPs for Projects Outside the U.S. via a quick feedback form on our website. It would be wonderful if you could also make your comments in the forms!

You can view the feedback forms on the LEED NC, CS, Schools & EB:O&M rating system pages through this link: http://www.usgbc.org/DisplayPage.aspx?CMSPageID=222 or through the LEED International Program page here: http://www.usgbc.org/DisplayPage.aspx?CMSPageID=2346.

Using the feedback forms allows us to more easily track user comments and suggestions, enabling us to integrate your feedback more efficiently. Thanks again!

January 30, 2012 - 10:19 am

Hello everyone! As promised, we finally have feedback forms for the LEED 2009 ACPs for Projects Outside the U.S. available for you on the USGBC website. LEED is built on the input and feedback we receive from the green building community, and this dialogue allows LEED to remain flexible and responsive.

You can view the feedback forms on the LEED NC, CS, Schools & EB:O&M rating system pages through this link: http://www.usgbc.org/DisplayPage.aspx?CMSPageID=222 or through the LEED International Program page here: http://www.usgbc.org/DisplayPage.aspx?CMSPageID=2346. We hope to hear from you soon!

December 12, 2011 - 1:11 pm

Am i right to assume that all non-US projects registered under the LEED 2009 version (rating systems: NC, C&S, Schools, EBOM), before October 2011, have the option to comply either with the original credit requirements or the ACP?

December 12, 2011 - 1:45 pm

Many thanks for your prompt reply Deon.

This approach will help us a lot for a project we have in Europe and struggling a bit with the floorscore....

December 12, 2011 - 1:40 pm

Hello Eirini,

You are correct. All non-US projects registered under the LEED 2009 rating systems with ACPs for projects outside the US may use either the original credit requirements or the ACPs. Because ACPs are alternative compliance paths they are merely additional options for projects and not required for use. If the original credit language is more applicable a project may use that path.

November 15, 2011 - 2:30 pm

Hello everyone,

After working at USGBC for the past 5 1/2 years, I have recently transitioned into a role overseeing the LEED 2009 ACPs for Projects Outside the U.S. and am happy to see such great dialogue going on in this LEEDuser forum.

We are currently working on creating a feedback form so that we get input from practitioners like you on what is working with these ACPs and what we need to improve going forward. I will provide a link for you all as soon as we get it finalized - we'd love to hear from you.

April 10, 2015 - 1:41 pm

If someone wants to cheat (or cut corners) in any system it can be done (See many real world examples beyond green building certifications). Maybe I've been lucky but every project I've worked on the people involved really wanted to create a more sustainable project and do it the right way, that's one of the great things about working in this space.

April 10, 2015 - 1:13 pm

Unfortunately I have a feeling that many international projects just "bluff" their way through the LEED quality assurance reviews for certain credits; notably credits that involve electronic signatures and that are never reviewed by the USGBC a second time in the construction review.
EAp2 is a perfect example; a design stage electronic signature and no review at the construction as we say is pretty "easy-peasy".

April 10, 2015 - 12:47 pm

You could try Bureau Veritas? I believe EU air leakage standards are generally much harder than US requirements.

April 10, 2015 - 12:42 pm

Thank-you for your comments.
From what I understand to date is that the alternative methods are acceptable for NFRC 100, 200 & 300 if they comply with the LEED requirements.

The procedure that I am most "concerned" with the is NFRC 400 "Procedure for Determining Fenestration Product Air Leakage".

In France we do air leak tests but they are quite different (temperature, pressure, flow rates etc..) from the NFRC 400.

Are there any instances where we can use the standard European / France air-leak tests?

Regards,

April 10, 2015 - 12:28 pm

A little old but perhaps helpful-IEA-Issues paper for Policy pathway for windows and other glazed areas
This voluntary program has over 21,000 approved projects; however, limited NFRC ratings exist for commercial projects. This implies LEED applicants are using alternative methods to comply with the LEED energy and atmosphere requirement.
The USGBC’s LEED program requires numerous measures to ensure good environmental and energy performance. Window energy policy is embedded in the energy and atmosphere requirement by referencing ASHRAE 90.1-2004. As described in this document, ASHRAE 90.1 references NFRC 100/200 for window energy performance rating and requires maximum U-factors and SHGCs by climate zone. This is a mandatory requirement and the user may also achieve a higher LEED rating or score by exceeding the ASHRAE 90.1 minimum criteria.

April 10, 2015 - 9:18 am

As an energy modeller, I would say the manufacturer should supply this information. The NFRC norms contain more than just how to deturmine the rating values.

Now if the manufacturer won't supply this information, I can painstakingly construct the frame and window in THERM and WINDOW and produce the NFRC rating values, but I would still require engineering drawings in dxf/dwg and sections in the same of the element. As I don't do this often, it's probably going to take 1-2 days for me to do it and like I said, I'll need quite a bit of info on the individual elements constituting the assembly.

April 7, 2015 - 3:36 am

Ian,
Your energy modeler should be able to confirm the proposed envelope elements meet/exceed the NFRC procedures.

April 3, 2015 - 8:22 am

Hello Deon Glaser & welcome to International World of LEED!
Do you know of any equivalencies for the NFRC 100,200,300 & 400 procedures for International / European projects?
Regards,
Ian

January 27, 2012 - 3:22 pm

Happy Friday everyone! As promised, we finally have feedback forms for the LEED 2009 ACPs for Projects Outside the U.S. available for you on the USGBC website. LEED is built on the input and feedback we receive from the green building community, and this dialogue allows LEED to remain flexible and responsive.

You can view the feedback forms on the LEED NC, CS, Schools & EB:O&M rating system pages through this link: http://www.usgbc.org/DisplayPage.aspx?CMSPageID=222 or through the LEED International Program page here: http://www.usgbc.org/DisplayPage.aspx?CMSPageID=2346. We hope to hear from you soon!

November 15, 2011 - 3:36 pm

Thanks a lot for sharing the information.

Many users will love to here that they are being heard. I know Jean and I have had many headaches applying an US rating system to projects in another country.
I personally will be more than happy to share experiences, suggestions and improvement idea from past and future projects.
Please also feel free to ask us questions. Many user here are dealing with the LEED documentation of international project every day and know what will or will not help them.

November 15, 2011 - 3:03 pm

Deon,
Welcome to the international market. It's great to hear there will be a feedback form for us to provide input on the ACP's. For the most part the items I have reviewed are a good step forward.

November 15, 2011 - 10:20 am

Here are the ACP Documentation Guidance for Projects outside the U.S. for LEED CS 2009 projects http://bit.ly/rXfh1q

November 15, 2011 - 10:18 am

Here are the ACP Documentation Guidance for Projects outside the U.S. for Schools http://bit.ly/tIWT0i

November 15, 2011 - 10:16 am

In case you don't know where to find the ACP Documentation Guidance for Projects outside the U.S.:
http://bit.ly/uabXDm
Also available there are supplemental forms and the conversion tool kit.

November 15, 2011 - 10:38 am

Alternative compliance paths are included for the following credits/prerequisites:
SS c4, SSc6,
WEc3, WEc4.1-4.2,
EAp2, EAc1, EAc6,
MRc1, MRc2.1, MRc2.2, MRc3, MRc4, MRc5,
IEQp1, IEQp2, IEQc1.2, IEQc1.3, IEQc1.4, IEQc1.5, IEQc2.3

November 15, 2011 - 1:07 am

Are there any plans to do the same sort of thing with EAp2? The problem areas here are things like NFRC 100,200,300,400 measurement protocols (for everything from "leakiness" of doors to visible light transmittance of windows). Some things are easy to prove equivalency, others not so easy.

April 3, 2015 - 8:15 am

Hello,
I know this is an old post but has the USGBC found local equivalencies for the NFRC 100,200,300 & 400 procedures for International / European projects?
regards,
Ian

November 15, 2011 - 10:01 am

Not yet, but they did say they are working on it and it is about time. These issues have been very time consuming and cost prohibitive for no good reason. It would be nice if the USGBC starts rethinking it's requirement for cooling in a building. If I even have an IT closet in the building or a big conference room with cooling I have to consider the whole building to be cooled even though it is not and never will be. There are a lot of things under EA P2, which I think need to be critical revisit with an international view of building practice.

November 13, 2011 - 7:58 am

Has anyone else noticed that some of the ACP documents state that international projects can't use Energy Star for energy benchmarking or energy performance? This is like changing the rules to the game in the middle of the game. The change will have major impacts on market transformation and the time, cost, and ability of international (in my case European) projects to earn any level of certification.

March 6, 2012 - 2:14 am

Just to say, I've completed the process now with Energy Star for an EBOM project in Vietnam. A few small bumps but I received my rating and the energy intensity score as required. I did get confused due to some aspects of the Energy Star site. They said that my project could apply for the Energy Star Rating, but following that link, I quickly found that it is really only possible with US projects, or US Government-owned projects. It must be signed off by a US-registered architect or engineer. LEED on-line reponses clarified: What you need for LEED is only to generate the energy intensity and the comparison with other projects and that is done automatically and can be documented in a PDF format called an SEP, which is provided via another link on the Energy Star summary page for your project. This SHOULD also show the carbon emissions, but like others I found that it didn't show up on the SEP so I used a screen shot of the relevant part of the summary page to record the CO2 data. By sharing data with the GBCI I assume the rest is straightforward. The only other quirk I noted was that for some reason choosing my final data month didn't work (February), I had to choose January as my end month. I still don't know why, but this allowed me to generate the report as required. I have no idea if that last quirk was temporary/to do with my data/or otherwise, but its effect was minor. Hope that helps.

November 15, 2011 - 10:47 am

Sean,
Thanks for the quick response.

November 15, 2011 - 9:40 am

Thanks for posting that response, Eric. Also, thank you for noticing that the language is still included for EAc1. We will work to remove that language as soon as possible and update the rating system to reflect this.

November 14, 2011 - 5:44 pm

Good news. Looks like it was just a mix up.
"Thanks for your question about EAp2 and EAc1 for EB projects outside of the U.S. The language stating that Case 1 was not available to projects outside of the U.S. was erroneously included in the Rating System with ACPs. The case IS available to projects outside of the U.S. and the box stating otherwise has been removed from the Rating System."

November 14, 2011 - 7:20 am

Jutta,
I plan on submitting a rather lengthy document to the USGBC once I review all of the conflicting documentation detailing my view on the impacts.
The current ACP document is totally different from the previous form. It would be nice if they would put version numbers on documents rather than October 2011.

November 14, 2011 - 6:44 am

thanks for the posting and this doesn't sound very encouraging at all!

i hadn't seen these and hadn't actually delved into these, since from all i heard at toronto and from all i read in the documentation guidance and on the usgbc website is that following the ACP remains optional: we may either use the ACP or the original credit requirement. maybe a formal clarification from international@usgbc.org would help sort this out?

November 14, 2011 - 6:23 am

The problem with Options 2B and 2C is the following:
"Enter at least 3 consecutive years of historical energy use data into Portfolio Manager, in addition to the current year's data."
ACP Problems:
OPTION 1. Benchmark Against Comparable Typical Building CASE 1. National Energy Data Available - No Data available
OPTION 1. Benchmark Against Comparable Typical Building CASE 2. National Energy Data Not Available - Finding three typical, comparable buildings with permission to use their energy bills. Requires 12 months of data.
OPTION 2. Demonstrated Energy Efficiency Improvement-The building must have at least four consecutive years of site energy data.
The certification process for some buildings just jumped from 12 months to 48 months or longer for buildings that are a few years old but didn't LEED certify previously....

November 14, 2011 - 6:05 am

Jutta,
The documentation is constantly changing and conflicting, but the original ACP EBOM documentation released around October 9th states the following:
CASE 1. Projects Eligible for Energy Star Rating-This CASE is not available to Projects outside the U.S.
CASE 2. Projects Not Eligible for Energy Star Rating OPTION 1-This CASE is not available to Projects outside the U.S.
CASE 2. Projects Not Eligible for Energy Star Rating OPTION 2-Note for Projects Outside the U.S. - Projects outside the U.S. can use Option 2 but are limited to Option 2B or 2C, as outlined in the LEED Reference Guide for Green Building Operations & Maintenance, 2009 Edition.
The original LEED EBOM manual states this:
"For building types covered by ENERGY STAR but located outside the United States, use Case 1 to obtain an ENERGY STAR rating. The Portfolio Manager tool provides a list of locations outside the United States, but it is not complete. If the location for an international project is not listed, consult ASHRAE 90.1-2007 Appendices B and D to determine a comparable US city."
The issue is that there is no national energy data available outside the US, like CBECS. See the excerpt from an EU energy research committee.
"Breakdown of Energy Consumption
Information on the average breakdown of total energy consumption for different end-uses in nonresidential buildings is not available for most countries or is limited for the other countries. In cases when information is available, most of the data refer to the last decade.
Breakdown of Energy Consumption in Different End-Use Buildings
Information on the average breakdown of total energy consumption for different end-uses in nonresidential buildings is not available for most countries or is limited for the other countries."

November 14, 2011 - 5:48 am

i haven't seen this per se - where is this documented? would be very keen to see this, since this would potentially affect us as well (haven’t run the numbers yet).

my understanding so far has rather been that international projects are now ALLOWED to use Option 2 to demonstrate compliance, which may make it a whole lot easier for some projects, while maybe not for others? international projects have never been able to use the ES PM other than for benchmarking, providing a score rather than a certificate.

November 3, 2011 - 3:01 am

There are two major drawbacks on page 25/26:

The text only refers to equivalency with Carpet and Rug Institute Green Label Plus, not to equivalency with FloorScore - there is no reason to see wha that.

On top of page 26 the document requires to address the VOC content of a list of chemicals, while the referenced CRI GLP is about VOC emissions of those chemicals.

As this is for international projects, the same wording about alternative pathways as in draft LEED 2012 could have been selected.

This deserves improvement, I should say.

November 15, 2011 - 10:25 am

Hi Reinhard,

It appears as though you are referring to the ACP Documentation Guidance Document. To be clear, this document is designed to assist project teams using ACPs to prove credit compliance in LEED Online. To view the ACPs themselves, please visit our website at www.usgbc.org/leed.

I hope this clears things up a bit!

October 28, 2011 - 2:12 am

In Germany we use the DIN 276, in the UK I think it is SMM7. As almost all MR credits are based on percentage cost with the cost denominator calculated as per the CSI categories, these credits are major headaches and usually abandoned. This issue needs addressing.

November 15, 2011 - 7:30 am

Jean,

You can contact me through LEEDuser if you want and I'll get back to you.

November 15, 2011 - 1:13 am

Could you post me a web-link please? I'll follow it up. Thanks.

November 11, 2011 - 4:38 am

Jean,

I know a European QS firm who would be happy to provide you the costing service. :)

November 11, 2011 - 3:34 am

I disagree. Usually costing is done by a Qualified Quantity Surveyor. I'm not one of them, and the architectural firm doesn't have one that is familiar with the costing splits. Yes, a carpet remains a carpet, but into which category it falls is a problem. We in Europe simply have big problems with this. Architects working for the client often want as little to do with LEED as possible and are often downright unwilling to cooperate. If I, the LEED AP can't do it, it doesn't get done. That is the real life situation.

November 8, 2011 - 9:20 am

I agree, translating ASHRAE standards to other standards does seem more difficult. But the MR discussion reminds me of the early days of LEED (2001 - 2002) and calling every manufacturer, explaining LEED and asking questions. I know I wasn't the only one. But now we have manufacturers who understand the program and address it up front.

Here is a link to the MasterFormat sections names by Division. It is a long document and it is only in English but maybe it starts to help with the MR problem.
http://www.csinet.org/Home-Page-Category/Formats/MasterFormat/About-MF/n...

November 8, 2011 - 8:56 am

However the costs are categorized for a building they still all have the same material elements. Carpet is carpet in Germany, the UK, or the US. Revising the material cost budget may be an additional step that seems unnecessary, but it doesn't seem as difficult as completing an energy model or convincing the project to go greener?

October 31, 2011 - 11:36 am

It starts with CSI categories being different from European categories, it goes on with contractors being unfamiliar with the process and definition of for instance post vs pre consumer recycled content and translation into English. For the regional materials, it's more so the level of detail for documentations, which makes projects shy away from it. Most projects have no problem using materials within 500 miles. The majority does that anyway.
Looking at LEED 2012 this isn't getting any easier.

October 31, 2011 - 10:45 am

Jean,

This is the opposite situation here in the US, the MR credits are fairly easy. How are these credits major headaches? Is it a lack of alignment with the CSI formats?

October 28, 2011 - 2:04 am

EN 15251 + ISO 7730, combination is almost identical to ASHRAE 55...doesn't make this credit any easier.

October 28, 2011 - 1:57 am

There you have it folks. It's official.

October 28, 2011 - 1:56 am

All ACP for international projects allow Metric Unit submittals...if I understand the impact properly.

June 18, 2012 - 4:31 am

Hello Sean,

Thanks for your answer, actually i have sent this question to GBCI and waiting the answer.