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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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April 2, 2013 - 10:56 am

how much historical data are you looking at for your average? weather can vary drastically from year to year. CDD and HDD can vary up to 40% from one year to the next. This is the point of TRY weather data. It is not actual weather data AMY. The available set of international TRY weather data from ASHRAE is usually good enough. if you need more info or explanation in this regard, contact the folks at whitebox technologies or weather analytics.

April 2, 2013 - 9:26 am

Hi John,
thank you for your reply!
There is weather data available for Helsinki but when I compare average monthly temperature data to our project location it sometimes differs up to 10 degrees (Celcius). Also average rainfall differs. Does that count already as "similar weather data"?
If not how would I find a U.S. location with more similar climate?

March 31, 2013 - 7:13 am

We recently completed certification for LEED EBOM large banking & finance office building in Hong Kong, using Energy Star. This is possible because ES has the weather file data for Hong Kong. Our project include small data centers so is relatively energy intensive, yet with the right building data, including number of PCs, the ES score was reasonable.
My understanding is that ES compares with comparable CBECs buildings, defined by type and size, rather than across the whole range.
If no weather file for your project's location, try a similar US location. This will give you an indication of EUI and EAp2 compliance.

March 25, 2013 - 10:23 am

Hi Tristan,

I did post it to the EAp2 forum already and talked about it with a couple of people. But it wasn't helpful because no one had experience with international projects so I thought I'll try it again here.

March 21, 2013 - 3:07 pm

Stefanie, could you please post this question to our EAp2 forum? Thanks.

January 30, 2013 - 11:00 am

USGBC said in a FAQ document that it is not needed to translate all documents in english but the important part of them.
I would like to have exemples of documents that reviewers asked to translate completely and other not.
For exemple in EAc3 we have to upload the systems manual that covers the commissioned systems. Do we need to translate it in english ? And the contract between the CxA and the owner will not be in english does a markup considered as enough ?

June 3, 2013 - 5:50 pm

Hi Jean,

I would recommend you use the Metric Conversion tool, available on our website to convert the units needed in PI2 and PI3. The tool can be found on our resources page at http://www.usgbc.org/resources/metric-conversion-tool-october-2012.

As for the required uploads in the PI forms, it is generally best to convert the most pertinent information that relates to LEED credits in these documents. As with the example above, not all information in these documents needs to be converted.


June 3, 2013 - 9:50 am

What should we do about PIfs. They are not credits. They do not have a ACP, but, for example, the mechanical schedules and plans may only contain metric units. Reworking all plans to include imperial units is not feasable.

February 22, 2013 - 2:41 pm

Hi Saliha,

I was referring to EAc3 when mentioning the full list of credit requirements. As for updates to the reference content, I recommend using the LEED Addenda and Interpretations database, available at https://www.usgbc.org/leedinterpretations/LILanding.aspx to search for any reference guide addenda for this and any other credit. Search the database for the appropriate credit (in this case, EAc3) and it will provide you with all updates that have been made via reference guide addenda.


February 5, 2013 - 9:48 am

Thanks Sean.
When you said to refer to the full list of credit requirements, I assume that you are talking about the EAc3 credit.
Because I have only the first edition of LEED 2009 guide. Does the Reference guide updated in 2010 have additional information related with the documentation langage?

January 31, 2013 - 3:35 pm

Thank you for your question. As the FAQ guidance suggests, entire documents do not need to be translated into English, only the portions that are relevant to ensuring that the project has met the requirements of a given credit or prerequisite. In your example for Enhanced Commissioning (EAc3), the entire systems manual would not need to be translated. Please see the LEED 2009 Reference Guide for Green Building Design and Construction (updated 2010) for the full list of credit requirements. Additionally, it is required that any information found in the Project Information Forms is also translated into English. Mark-ups of these documents and any contracts (as long as they are easily legible) are considered sufficient translation for the purposes of a review. It is noted that the reviewer may ask for additional translations to portions of these documents in the effort to confirm credit compliance.

Please let us know if you have any additional questions.


October 31, 2012 - 6:34 am

We have a Commercial Interiors project (office refurbishment) in germany.

Specifically, we wonder if we can apply the ACP for IEQc4.3 flooring systems to a CI project?
Generally, are the ACP's applicable to CI projects?

October 31, 2012 - 9:27 am

Hi Alexander,

Eric is correct. The global ACPs are available for CI projects (as well as the other rating systems mentioned). The global ACPs for these rating systems were developed to align with those already created for NC, CS, Schools and EB:O&M. No new ACPs were developed in this process. To view the available resources for all global ACPs, please visit the resources page of the USGBC website: https://new.usgbc.org/resources?title=Global%20ACP.


October 31, 2012 - 7:45 am

From the USGBC website -
"Batya Metalitz, U.S. Green Building Council
The ACPs can be downloaded in the resources section and include both the July 6th releases and the new releases (Healthcare, Commercials Interiors, Retail - CI and Retail - NC), dated October 1. The language has also been incorporated into the credit library."

August 1, 2012 - 3:13 am

Could anyone please guide me to the current ACP forms and the documentation guidance? I think there were available in the rating system - resources - international section but it seems they are gone (or I can't find them).
Thanks, Jens

August 3, 2012 - 9:44 am


Good question, I browsed around LEED Online and if you download the excel file named "LEED Online v3 Form Fix Log" and filter to 2012 you can see that there are indeed version 5 forms listed there. It would be nice if they updated the release notes in the Help section.... If you read the help section for LOv3 Form updates you will also find that you need to request new forms if you want them. "The latest version of the form is automatically provided to all projects registered after the release date and any other projects that have not yet saved data on the specific form. Projects with an older version of the form may request the latest version (see instructions below)."

August 2, 2012 - 2:03 am

Thanks Eric. Maybe both the forms and offline calculators are available in newly registered projects or after a project form update by the GBCI.
If the ACPs are in the forms, shouldn't there be new sample forms (v05?).

August 1, 2012 - 5:26 am


Try here - http://www.usgbc.org/DisplayPage.aspx?CMSPageID=2628
According to the webinar last week the "The Global ACPs have been fully integrated into LEED Online forms for added functionality." and "Offline calculators have been added and modified to include the Global ACPs. These are available in the Credit Resources page in LEED Online."

July 25, 2012 - 12:11 pm

As of the 7/6/12 LEED addenda release, USGBC has integrated the International ACPs into the regular LEED credit language—so rather than reviewing the standalone document, you can see the ACP options within the main LEED credit language on this site and in other USGBC outlets.

I provide an overview of key changes associated with the ACPs in my regular LEED addenda update.

July 5, 2012 - 5:08 am

Hi everybody,

I see that many of you here have extensive experience with international projects. How have you handled the MR Calculator for regional, recycled content with the part of the cost? We have all costs in EUR and we want to keep it this way to ensure consistency.
What is has been your experience so far?

July 5, 2012 - 10:58 am

We have submitted a few projects. You will be asked by the reviewer to submit in dollar. However there is no requirements for a certain conversion rate. So we applied 1 EUR = 1 Dollar, which is reasonable if you compare the buying power of EUR to dollar (That's actual a more realistic value anyway). Also as Jean was pointing out the percentage stays the same either way. However you are required to provide it in dollar. Some reviewer may not have an issue with you using EURO, but we did have review comments asking us to provide dollar values.

July 5, 2012 - 8:41 am

It's worth a try submitting in EUR. If the review team objects then you can always do the conversion for the final submission. I just submitted the cost analysis for an EBOM project (IOc3) in EUR - let's see how that is met. Be sure to note that you have submitted in EUR rather than USD.

July 5, 2012 - 6:56 am

As the end results are in %, it really doesn't matter...to be consistant I would stick to dollars.

April 17, 2012 - 3:24 pm


I haven't seen if someone has already asked this, so if someone has done it, I'm sorry to be questioning again.

When we choose the alternative compliance, it's also needed to complete the original form to confirm the credit or simply make the upload of the ACP form is enough?

For example, the ACP form for C&S SS Credit 6.1 it's very different from the original form. Is it ok if I only complete the ACP form?


April 18, 2012 - 4:23 pm

Hi Sean!

Thanks for your answer. I've read this document and I saw that some credits require filling the original form and others don't, that's why I've had this question.

But your answer just confirm what we actually thought!

Thanks again!

April 18, 2012 - 1:56 pm

Hi Angela,

Thank you for your question. When completing the documentation for all credits, please be sure to follow the directions given in the "ACP Guidance for Projects Outside the U.S." document located on the USGBC website at https://www.usgbc.org/ShowFile.aspx?DocumentID=10341.

Generally, you will need to fill out at least part of the original form in order to properly document compliance with the credit.

I hope this helps.


March 16, 2012 - 7:50 am

We are working on an 32.980 m2 (354.862 sqf) core an shell office project in Frankfurt, Germany. We plan 20% green areas (roof and external areas) in relation to the site area and therefore comply to SS Credit 5.1. Case 2.

Can you please inform us on the headline in SS Credit 5.1. Case 2. It states ' this case is not available to projects outside the US'. We assume that refers to the text below and the option to donate offsite land?

March 16, 2012 - 8:29 am

Hi Tobias,

Maria is correct. The box does refer to the text below, and that case is absolutely available to projects outside the U.S. Good luck with your project!

March 16, 2012 - 8:08 am

Hi Tobias
I agree with you that it is a bit fuzzy in this text: http://www.usgbc.org/ShowFile.aspx?DocumentID=8870 But case 2 is definately a case you can use. It's whats in the full version of the Reference Guide. I use it in Sweden!
However it is not an ACP. There is no ACP for SSc5.1 that I can see. You can see at the top of this page which credits have ACP's. Good luck!

February 20, 2012 - 7:34 am

In order to show compliance with CEN standard for IEQp1, what exactly do I upload? Is it sufficient with a homemade tool that has the exact same parameters as the VRP calculator with the only difference that I swap the required ventilation rates for the ones in CEN? In CEN there are eight different areas: single office, landscaped office, conference room, auditorium, restaurant, classroom, kindergarten and department store. Only the first five of CEN are applicable to an office building. Compare this with ASHRAE’s sixty-three different types of areas! And for IEQc2 I will still go 30 % above ASHRAE since otherwise I’d be over-ventilating a building which leads to unnecessary use of energy. Right? Anyone outside the US who has tried the ACP with CEN standard? Please give me guidance!

June 4, 2012 - 10:09 am

While the vehicle emissions might be lower in Europe every time I leave a parking garage here I always seem to take with me a cough, teary eyes, and "eau de exhaust" on my clothes. Maybe it's just my allergies?

June 4, 2012 - 9:51 am

Loïc, in this case we used CEN on both. The problem with garages is that ASHRAE uses four times higher exhaust rates than we do here. We have lower emissions, and in a cold country we can’t over-ventilate. This is the only reason we use CEN instead of ASHRAE. Since we have 100 % outside air in our offices it is no problem complying with ASHRAE in all other senses.

Jean, in another of my projects we said that we comply with everything in ASHRAE, except for in the garage, where we instead install CO-monitors, (which we always have). This was also ok according to reviewers.

So we are just testing options for the same problem that I have in all my inner city projects and that has caused us a lot of concern

June 4, 2012 - 9:42 am

Thanks for this prompt answer Maria,

So you use ASHRAE for both IEQ P1 and IEQ C2 or only CEN standard ? i didn't quite understand your last sentence : "Of course we comply with the whole of ASHRAE too, except for exhaust rates in the garage, which we refuse to alter"


June 4, 2012 - 9:22 am

The known get-around for exhaust rates in the parking garage has been to install a CO2 Demand Ventilation System. Usually those axial "jet" fans are part of the smoke exhaust scheme.

June 4, 2012 - 9:02 am

Review Response to ACP for IEQp1

I have received response for my project now. The home made tool was accepted! The only comment we got, that resulted in “pending”, is that they wanted the Ventilation Systems Designer sign the ASHRAE-box although we are not using ASHARE. I have no idea why. So we are going to sign, but write in special circumstances that our signature means that we comply with CEN and not ASHRAE as far as we are concerned. (Of course we comply with the whole of ASHRAE too, except for exhaust rates in the garage, which we refuse to alter).

Just wanted to let you all know.

June 4, 2012 - 8:49 am

Hello Sean,

I am currently working with LEED certification in France for an office building.

It is mentioned in the ACP guidance for IEQ P1 :
“For “Upload IEQp1-1”, upload the ventilation rate calculations for all applicable spaces including the design
outdoor ventilation rate based on the requirements of Annex B of Comité Européen de Normalisation (CEN)
Standard EN 15251 ».

As Maria said before, CEN standard has 8 areas where ASHRAE 62.10 has more than sixty ; therefore is it compliant to provide an homemade tool with same parameters as the VRP calculator (based on this 8 areas) ?

Morever, do we need to comply with the entire ASHRAE 62.10 or just with the ventilation rate ?
(as mentioned in the ACP guidance for IEQ P1 : “Under “Mechanical Ventilation”, check the box with the declaration of “Mechanical ventilation systems are designed
using local code, which is more stringent than the ASHRAE Standard 62.1-2007 Ventilation Rate Procedure”.” ; this sentence is quite disturbing…)

Thanks for your answer,

March 28, 2012 - 2:16 pm

Yes. If your system can handle 0.75 cfm per sf even if the CO2 sensors make it run at much lower levels all the time, it is OK for ASHRAE. Just make sure to set CO2 levels triggering the sensor appropriately.

March 23, 2012 - 8:09 am

Hi Susann,

Did I got this right: If my underground parking has demand controlled ventilation with maximum exhaust rate over 3.7 l/s,m2 it would fulfill the requirements of ASHRAY, even though the average exhaust rate would be much lower?

March 16, 2012 - 10:10 am

We had that issue also in some projects. First thing you want to look at is, if your garage is open to the surroundings, because it is a bit different if that the case. We have had projects with no exhaust but jet vans to move the air through the garage to the outside.
Another way is to include the volume of the smoke exhaust system in the garage in the equation, which you can do if it's triggered by CO2 (not just CO) sensors. That basically a two stage demand controlled ventilation.
It's really a common problem and mostly results from the big differences in car emissions in the US vs. Europe. In Europe there is no need for that much exhaust, because the emissions aren't that high. In the US you really need that kind of exhaust rate. I hope that helps.

March 16, 2012 - 3:43 am

Sean, thank you. Looking forward to that!
Susann, we have 100 % outdoor air throughout the building. No problem complying with CEN standard as it is has the status of a Swedish standard. The problem with using ASHRAE for IEQp1, for several of my projects, is that they have garages. And by checking the box that we comply with ASHRAE sections 4 through 7 we would say that we have exhaust rates of 3,7 l/s and m2 in the garage. No Swedish project that I know of would have exhaust rates that high. The rest of ASHRAE is not that hard for our projects to comply with. So we want to use CEN for that reason.
Also see my thread on: http://www.leeduser.com/credit/NC-2009/IEQp1 from sep 27, 2011.

March 15, 2012 - 10:41 am

Maria, If you are planing on using ASHRAE for IEQ c2 than you might as well use ASHRAE for IEQ P1 also, because you will determine minimum compliance for ASHRAE 62.1-2007 for IEQ P1 and than show how much you are exceeding it.
Some critical items are toilets / restrooms, waste rooms and operating rooms, which require lower outside air rates/exhaust rates in CEN vs ASHRAE, so pay attention to that.
If you are using a lower air quality class in the building for CEN compliance than you certainly have to look at more space types and increase their air supply.
Good luck with your project.

March 15, 2012 - 9:02 am

Hi Maria,

We are currently working on integrating the ACP language into our existing LEED Online forms. We will be sure to update you here on LEED User when those forms are available. Thanks for your question!

March 15, 2012 - 4:12 am

Eric, thank you for showing me where the forms are. Unfortunately there are no forms for IEQp1 and c2, which we need. The step-by-step guidance I had already. The problem with the guidance is that it is unclear how to show compliance. It says "upload, as needed, alternative tables or calculations". We have now made our own calculator. However ASHRAE and CEN have a very different way of showing things so it's a bit fuzzy what they want. We will just have to submit and get feedback.
Does anyone know if there will be "real" LEED Online forms for all ACPs? Like a button or check box in the current form if you want the ACP for international projects?

March 15, 2012 - 3:40 am

The ACP forms can be found at the USGBC web site under each rating system information page.

For example see: Resources-International-ACP Documentation Guidance for Projects outside the U.S. (PDF) -- Step-by-step guidance on documenting compliance with the Alternative Compliance Paths (ACPs) for each credit.


If you review the Submittal Guidance for using Alternative Compliance Paths for projects Outside the U.S. it will tell you how to document compliance with the CEN standards.

March 15, 2012 - 1:44 am

Susann, How would you do regarding IEQc2? We want to do that one according to ASHRAE.
And where can I find the LEED Online forms for ACPs? I have never seen one of those and have no idea where to find them. If there was one for IEQp1 it would really help. Currently we are making our own tables. Thanks!

March 14, 2012 - 2:58 pm

You will probably be one of the first to try this. Have you looked at the LEED Online forms for ACPs in regards to what's required?
I know that the USGBC is working really hard to give you all more guidance in that regards. I have done a lot of projects in Europe and dealt with the US vs Europe differences and am helping the USBGC to figure out a good way of comparing the standards.
If I were you I would document CEN compliance in regards to the same criteria, which ASHRAE is looking at such as outside air supply per room. Use the CEN room types. But pay also close attention to the other requirements in 62.1. such as toilet exhausts and controls.

Good luck with your project.

February 8, 2012 - 11:12 am

Dear all,
Do you know if we can use these alternative compliance paths also for the CI projects??
Thanks a lot!!

February 9, 2012 - 4:39 am

Thanks a lot!
I knew that CI was not included, but just in case someone had heard anything about ACPs for CI.
Thanks again!

February 8, 2012 - 3:11 pm

Eric is right, but if the credit is very similar to the NC/CS credit and the standard approach doesn't work then I would encourage you to at least try it.

There doesn't seem to be too much international customization in the LEED 2012 documentation yet, but I saw a few things (particularly related to VOC testing) that could prove useful. Again, not guaranteed, but if you are following their rules and fulfilling the credit intent then you should have a strong case.

February 8, 2012 - 11:17 am

If you go to the USGBC site. http://www.usgbc.org/DisplayPage.aspx?CMSPageID=2346 it looks like CI is not included yet.
See below
Learn more about ACPs for specific rating systems:
New Construction
Existing Buildings: Operation & Maintenance
Core & Shell