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LEEDuser’s Guide to Key Changes in LEED-EBOM 2012 – 3rd Public Comment

A review of major and minor changes
March 1, 2012

Several key changes are proposed for a new structure for the LEED-EBOM Rating System in 2012. Most significantly, prerequisites and credits now have an Establishment component and a Performance component. In the Establishment portion of the credit, project teams are asked to establish a foundation that the credit will rely on, for example, to develop a policy. The Performance part will request that project teams show evidence of an activity (i.e. a survey, audit, or testing) or ongoing tracking. The intention behind this new structure is to simplify and clarify the recertification process. 

In addition to the usual upgrade with the latest standards and higher compliance thresholds, LEED-EBOM 2012 will include a handful of new prerequisites.

Additionally, there is now a suite of LEED-EBOM rating systems with requirements that are tailored to specific project types, including Schools, Retail, Data Centers, Hospitality, and Warehouse & Distribution Centers.

Some new credit categories have been proposed through the various versions of public comment. However, some have not made the cut in the third version. The proposed Integrative Process and Performance categories are no longer part of the rating system. The new credit category that did stick is Transportation and Location. The category includes only one credit, Alternative Transportation Commuting (a credit previously in the Sustainable Sites category). Also, in an attempt to streamline the credits, several related credits have been combined.

Location & Transportation (LT)

The new LT category for EBOM consists only of a lonesome relocation of Alternative Commuting Transportation (1-14 points) from SS to LT. The credit is mostly recognizable from its v2009 form, but there are some significant changes highlighted below.

Major Changes in LT

The biggest change with this credit is that the baseline is no longer 100% single-occupant vehicle (SOV) commuting trips. Instead, the baseline is based on the national average of SOV trips for the specific building type. For example, the baseline for office buildings is 85% SOV, whereas at the other end of the spectrum, the baseline for college classrooms and administration is 40% SOV.

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So this credit just got more stringent for all buildings and particularly for buildings like hotels, schools and colleges. In addition to the modified baseline, the alternative commuting trip types are no longer weighted equally. The most highly weighted alternatives are human-powered trips and public transportation, and low-emitting, fuel-efficient vehicles are the lowest-weighted alternative trips.  

Minor Changes in LT

As for minor changes, the performance (point) thresholds have been modified slightly, and you can earn a point just for conducting the survey. But the net difficulty related to the point thresholds is still more or less the same as v2009. Also, note that there is an alternative compliance path specific to retail projects.

Currently, the credit language does not outline specific steps for the Establishment and Performance phases, so it’s a bit unclear how often the survey will need to be conducted after the initial certification.

Sustainable Sites (SS)

You’ll be familiar with most of the SS section, as it retains many of its familiar faces, including heat island, light pollution, and site management, although some areas have been combined into single credits. Also, we see the introduction of a sustainable sites prerequisite with the Site Management Policy outlined below.

Major Changes in SS

The most notable change with the SS section is the establishment of a new prerequisite and the departure of SSc4 Alternative Commuting Transportation (v2009) over to the LT section. The prerequisite involves establishing a Site Management Policy that more or less covers the same components of SSc2 and SSc3 from v2009. Project teams in the past struggled with the build-your-own metrics aspect of the v2009 credits, and this version attempts to put clear parameters on what performance is required and how it is evaluated. One addition to the mix of maintenance equipment, cleaning chemicals, fertilizer, etc. is maintenance practices to ensure optimal operations of irrigation equipment. The site management policy is adopted in the Establishment period, and there is no Performance activity or tracking associated with the prerequisite. Performance requirements for site maintenance activities are now in the associated credit for site maintenance.

Another big change with the sites credits is that Stormwater Management is re-branded as Rainwater Management (1–3 points) and comes fresh with new performance criteria for managing rainwater on the site. Specifically, the credit requires implementation of 2 of 5 available strategies ranging from low-impact development (LID) practices to rainwater capture and reuse to a rainwater filtering system. The new credit criteria appear to be more stringent than their v2009 precursors and may prove to be more meaningful measurements of environmental performance.

Lastly, Site Improvement Plan (1 point) has been added as a new credit that investigates and establishes a five-year plan to improve the hydrology, vegetation, and soils on the project site. All low-cost and no-cost measures must be implemented for the Performance component of the credit.

Minor Changes in SS

Protect or Restore Habitat (1–2 points) has been modified a bit and will be more stringent now that native and adaptive vegetation is required for 20% of the entire site area (including the building footprint). The off-site option has been re-framed to provide financial support to an off-site area equal to the total site area with some additional stipulations to require for the first time that off-site locations be within a certain geographic range of the project building (within the same EPA Level III Ecoregion or state as the project building).

Heat Island Reduction (2 points), including both roof and non-roof strategies, has been combined into a single credit but is pretty much the same as in v2009. A couple small changes: the non-roof hardscape surfaces are assessed by their solar reflectance (not SRI), and the SRI requirements for the roofing material now include criteria for the 3-year aged SRI value in addition to the initial SRI value.

The Light Pollution Reduction (1 point) credit remains mostly the same as v2009 with some slight modification to the shielding option for exterior lighting. But if you were watching the changes through the second round of public comments, there is no longer an option for “appropriate personnel” to turn off the interior lighting at night. The only option now is for automatic controls, like with v2009. In practice, this has usually meant that teams skip this credit and don’t add exterior shielding even if they can, unless they happen to already meet the interior criteria (it is easy for new buildings that were built to code that require automation, but expensive and impractical for a lot of older buildings).

The Site Improvement Plan (1 point) credit brings the concept of energy auditing to the building site, with components of documenting conditions, evaluating options for improvement, and prioritizing low-cost and no-cost measures. The idea here is to get project teams to take a longer view of site sustainability, given that the typical EBOM project might last a year or less and revitalizing site infrastructure is a long-term project.

Water Efficiency (WE)

The Water Efficiency category has upped the ante with a new prerequisite, Building-Level Water Metering. The previously proposed third water prerequisite requiring Outdoor Water Use Reduction has been dropped in the third draft for public comment. Other increased thresholds and additional requirements make the WE category credits slightly more difficult than they were to achieve before. A proposed prerequisite and credit for Appliance and Process Water Use Reduction have officially been done away with in the third round of public comment.

Major Changes in WE

The addition of the new prerequisite, Building-Level Water Metering, stresses the importance LEED-EBOM places on knowledge of a project building’s water consumption. Under this version of the rating system, project buildings are required to install permanent water meters to measure total potable water for the project building and grounds. This is most likely to present a challenge to buildings located on a campus. Points can still be achieved by metering of water subsystems via the Water Metering credit (2 points). Both the prerequisite and the credit require that the whole-building and subsystem meter data be shared with USGBC for at least five years.

The new, more difficult baseline criteria for the Indoor Water Use Reduction prerequisite and credit (4 points) will increase the required amount of cost and work associated with retrofitting and replacing new plumbing fixtures and fittings. This version of the rating system establishes the water use baseline by the date the building received a certificate of occupancy: for projects with a certificate of occupancy from 1995 or later (increased from 1993 in v2009), the baseline is 120%, whereas for buildings older than 1995, the baseline water use is 150%. These seemingly minor changes can add up to many thousands of additional dollars in required retrofits for older buildings to comply.

According to our analysis of one real project building (Class A urban high-rise built before 1995), changing the baseline from 160% of EPAct to 150% only increases the water savings by 10%, but increases the costs of complying with the prerequisite by 33%. Given that fixture water use is by no means the main source of consumption in most commercial buildings, LEEDuser wonders if this ratcheting up of the threshold makes as much sense as a cooling tower water use prerequisite would. Consider running your current projects through a scenario that uses a 150% baseline instead of 160% to see the impact on costs and savings, and comment to USGBC accordingly.

If you are going for Option 2, which calls for a baseline based on actual metered data, and then a reduction from that, it is now required that the baseline be reset every ten years for recertification purposes.

The Indoor Water Use Reduction prerequisite also now requires that all existing fittings and fixtures be inspected to confirm they are operating properly, and that a fixture and fitting replacement and retrofit policy is implemented that specifies WaterSense-labeled products are actually installed (versus the v2009 requirement for an economic assessment policy). Older piping can sometimes restrict the fixtures that may be installed. We expect that project teams will experience challenges in the implementation of this credit with the new baseline for older buildings.

Also notable are the new requirements for Cooling Tower Water Use (1–3 points) requiring a one-time potable water analysis measuring at least a specified list of five control parameters and then calculating the number of cooling tower cycles to determine the level of compliance.

Minor Changes in WE

The proposed requirements for Outdoor Water Use Reduction (2 points) have not changed significantly, except that fewer points are available (5 points were available under v2009).

Energy & Atmosphere (EA)

Changes to the v2012 EA section include a familiar but more stringent energy performance prerequisite, the inclusion of a new demand-response credit, and the departure of the building automation and emissions credits. Also, energy-related credits like commissioning that were located in the PF section for round 2 public comment have been moved back to the EA section.

Major Changes in EA

The changes to Minimum Energy Efficiency Performance solidify this prerequisite’s status as the gatekeeper for the LEED-EBOM program. The prerequisite requirements have been beefed up to a minimum Energy Star rating of 75 for ratable buildings or better than 75% of similar buildings for those not eligible for an Energy Star rating. The basic mechanics of documenting compliance appear to be the same as those in v2009, and maybe what’s most notable about the prerequisite is that an option included in the 2nd round of public comments that offered an alternative compliance path for buildings to demonstrate a 20% improved performance over their historic baseline has been removed. Removal of that option plus the heightened minimum Energy Star rating guarantees that the maximum total market share for LEED in the existing building arena is limited to just about a quarter of all buildings.

New to the EA section is Demand Response (1–3 points) This credit has been piloted with v2009 projects and appears to be very similar to the pilot credit.

Minor Changes in EA

The Existing Building Commissioning credits (investigation & analysis – 1 point, implementation – 2 points, and ongoing commissioning – 3 points) are similar to what we’ve seen with v2009, except that it appears that the energy audit path and the commissioning path have been merged so that you have to conduct both commissioning activities and an ASHRAE Level II audit in the investigation & analysis phase. The implementation is mostly the same as v2009 with the addition of seemingly firmer requirements around tracking and verification. The ongoing commissioning plan credit also provides more prescriptive documentation required for the Performance component.

The Advanced Energy Metering (1 point) credit has been simplified a bit and now requires that all end-uses that consume at least 20% of the annual energy use (minus plug loads) have to be metered and logged continuously. Also new are requirements related to tracking peak demand in the building over time.

The Green Energy Production and Utilization (1–5 points) credit (formerly on- and off-site renewable energy) remains mostly the same except that off-site renewable energy offers fewer point opportunities, and now carbon offsets can cover both electricity and fuels. Also, Refrigerant Management is nearly the same for both the prerequisite and the credit, with the exception that there is a new and potentially simplified path for the enhanced refrigerant management credit in addition to the old v2009 option.

Materials and Resources (MR)

Most of the changes in the new Materials and Resources credit category are due to restructuring and the new materials requirements that have evolved with LEED 2012 across all rating systems.

Major Changes in MR

An Ongoing Consumption Policy has taken the place of the v2009 Sustainable Purchasing Policy and the Solid Waste Management Policy. It requires that the policy address the purchases covered in both Purchasing – Ongoing Consumption and Purchasing – Facility Alterations and Additions, where new requirements and standards reside. Notably, in addition to addressing target goals for Solid Waste Management, it also requires that an audit be conducted of the building’s entire waste stream (this is no longer a choice!). Performance is confirmed by either pursuing Solid Waste Management – Ongoing Consumption, or by conducting a waste audit annually.

The first step to achieving the new Purchasing – Ongoing Consumption (1–4 points) credit is to identify the to five ongoing consumable products that are purchased consistently. Then at least 60% of the total ongoing consumables (defined as the top five products purchased consistently as well as paper, toner cartridges, binders, batteries, and desk accessories) must meet the established criteria.

However, the new established criteria make this credit a bit trickier to achieve. For one thing, food purchases are now included in this credit (but would only be relevant if a food item were a top-five consistent purchase). Additionally, many of the new materials criteria align with those in the new BD&C rating systems, which now address issues such as where and how raw materials are mined, quarried, grown, and harvested. These new materials requirements are a departure from the structure of the last few versions of LEED. The credit also requires that at least 40% of electric-powered equipment purchases meet EPEAT Silver (higher than previously required Energy Star), or if not covered by the EPEAT standard, Energy Star. The tracking of an already-difficult-to-track credit seems to be getting even harder.

The requirements for Purchasing – Facility Alterations and Additions (1–2 points) have been completely overhauled to align with the new BD&C materials purchasing criteria. A second point can now be earned for purchasing furniture that meets the prescribed standards, such as BIFMA.

Minor Changes in MR

Although a new prerequisite, the new requirement to develop a Facility Alterations and Additions Policy seems less difficult than others. The policy addresses construction waste management, indoor air quality guidelines during construction, and creating a plan to evaluate whether a flush-out or air quality testing is needed.

Solid Waste Management – Ongoing Consumption (2 points) now includes ongoing consumables as well as office equipment, appliances, and audiovisual equipment (electronics waste). It also requires that a waste audit is conducted at least every five years, or if occupancy changes are greater than 20% of the gross floor area.

Solid Waste Management – Facility Alterations and Additions (2 points) has not changed significantly, except that furniture now must be included in this credit.

Indoor Environmental Quality (EQ)

The EQ section includes most of the same basic content as with v2009, but there have been some notable mergers and acquisitions, including the long-awaited union between the green cleaning policy and the formerly separate high-performance green cleaning program. Also, the walk-off mat, CO2 outside air monitoring, and MERV 13 filtration credits have all been grouped into a single credit, Enhanced Indoor Air Quality Strategies.

Major Changes in EQ

No major changes to the EQ prerequisites have been made, but some smaller modifications include the updated ASHRAE 62.1-2010 ventilation standard, a couple of minor additions to the green cleaning policy, an option to demonstrate ongoing performance by contracting with a third-party-certified cleaning contractor, and required signage for the smoking prerequisite. Also, some happy news for multifamily and hospitality projects: air leakage testing will not be required for non-smoking residential or hotel guest units.

Other important changes are that the Interior Lighting (1–2 points) credit has been expanded to include an additional point for projects meeting lighting quality requirements. LEEDuser’s take on the lighting quality criteria is that evaluating them in an existing building, especially with multiple tenants, will be beyond the ken of the typical project team, and that bringing in a lighting designer to retroactively evaluate lighting design won’t be an attractive proposition.

The Daylight and Quality Views (2–4 points) credit has been modified to include “quality of views” criteria. In the Green Cleaning credits, there are now additional standards, including Design for the Environment (DfE), and ionized water has been added to the old Green Seal and Environmental Choice standards. The cleaning product purchasing performance threshold has also been raised to 75%. Also, the green cleaning equipment and custodial effectiveness audit credits have been modified with higher performance thresholds.

Minor Changes in EQ

Many of the EQ credits remain substantially unchanged, including the Thermal Comfort, Indoor Air Quality Management Program (IBEAM), Integrated Pest Management, and Occupant Comfort Survey.


The point allocation for the Innovation credit is confusing. It’s hard to tell exactly how many points can be earned for what. However, in addition to Innovation and Exemplary Performance strategies in the previous LEED-EBOM Rating System, LEED Pilot Credits from the LEED Pilot Credit Library can now officially be pursued.

For the LEED Accredited Professional credit, only one LEED AP is required; however, the LEED AP must have a specialty most appropriate for the project type.


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March 22, 2012 - 1:18 am

Green building rating systems need to balance performance requirements against market acceptance. For existing buildings (excluding refurbishments) getting the balance right is critical for market penetration and improvements to the building stock overall.
Quoting from Rob Watson’s 2011 green building market report “The EBOM standard is the key to the ability of LEED to transform the building sector, yet we know very little about why projects are not certifying, let alone not registering.”
In our experience for buildings outside the US the main barrier to take up is meeting the whole building (landlord + tenant) energy performance prerequisite. Tenant consumption can exceed 50% and relationship between parties not conducive to co-operating on overall improvements. Excluding older buildings, where upgrading of main plant is economically viable, energy targets need to be achieved within modest O&M budgets and within the aforementioned constraint.
Setting ‘elitist’ entry levels simply deters certification. Increasing the Energy Star entry level to 75 is not helpful. Alternatives, such as the 20% savings (maybe even lower!) should be retained. Saving even 10% on a EUI of 400 is a gain for the building stock equal to 20% on a EUI of 200.
Besides energy, many LEED EBOM credits requiring tenant participation do not reflect the effort or cost to achieve compliance.
LEED should look at the potential for a LEED EBOM equivalent to LEED CS, focusing on what building operators/landlords can achieve without tenant participation.

March 14, 2012 - 5:00 pm

I know this is not a change from the 2nd Version to the 3rd, but has anyone else been concerned about the wording in the EBOM Retail MR prerequisite (Ongoing Consumption Policy) to promote environmentally responsible sourcing of retail merchandise? It gives options to 1. establish procedures and resources for implementing a supply chain survey (but does not explicitly require that the survey be implemented, nor have a separate MR credit to incentivize implementation), 2. establish procedures and resources for implementing an education program (but does not explicitly require nor have subsequent credit for it to be implemented), 3. establish criteria for encouraging an environmentall preferable supply chain strategy (but does not explicitly require nor have subsequent credit for it to be implemented), or 4. provide an educational display in the retail project (which is the only option that seems to include implementation). There are no MR credits further down the list that address sourcing of retail merchandise. This is all new language since V2009. Was this concern addressed earlier in the process? Am I missing something?

March 15, 2012 - 9:26 am

Looks like the intent is to get companies to start thinking about these issues.

Is your concern that EBOM Retail does not go far enough in rewarding (with points) a company with good performance in this area?

March 14, 2012 - 4:29 pm

We have an interesting situation in that from June 2010 – August 2011, we had a fuel cell pilot on our building. We had to have a gas meter installed specifically to feed this fuel cell. The gas meter is still on our building, but is inactive.

As interpreted, in order to comply with the Option 3 Pilot, we would need to have both the performance period and baseline periods take place in the past five years, meaning that we would have to include some portion of the time period that the fuel cell was on the building. It would not be possible to start a Performance Period before August 2012.

The Option states the following: “Confirm Energy meter(s) that measured the entire energy use of the project building have been in place from the start of the baseline period, and that this was the data used to establish the project building's energy efficiency performance.”

How would our unique situation be treated? The gas meter was installed in what would be the middle of our third year of data, but it was for a specific purpose: to pilot a new energy technology. If the gas meter is included for the time that it is active, would this affect our ability to move forward with this Option?

March 15, 2012 - 4:50 pm

Hi Marcus,
We've set up several meters in Portfolio Manager (PM): 1 for the gas, 1 for the fuel cell output, and our main meter (general electricity, supplies the whole building). As I am sure you know, meters can be active or inactive. If we "turn on" both the gas meter data and fuel cell output data, that seems to be the most accurate scenario in terms of what we actually consumed at that time. But we cannot accurately account for the fuel cell because PM has no option for fuel cells like they do for solar and wind. We've discussed this issue with the folks at Energy Star and other than that they are working on including more forms of alternative energy, that issue is probably neither here nor there for our project. The fuel cell did certainly help our environmental impact, but in terms of what we consumed during that time, I am thinking it makes the most sense to include the meters for both the gas and the fuel cell to get the most accurate, fair picture of what our foot print actually was, despite the inherent flaws in PM?

March 15, 2012 - 9:41 am

Hi Elizabeth,

How does the fuel cell affect the results? Since the measurement is made on Source EUI I would assume that it lowers the energy use (fuel cell uses gas to make electric so more gas use and less electric use should increase source EUI). Is that the case?

I think that this could probably be one of the adjustments that you would make to normalize the data similar to a change in occupancy or schedule. Portfolio Manager can't do that so you would have to take the data outside of it to make the adjustment.

There is no way to know for sure without signing up for the pilot credit. In order to do so you will need to register the project. Then sign up for the pilot and you can ask these questions directly to those who will be deciding how to handle your situation.

There is a pilot credit forum in LEED User and hopefully they add this one to the list and we can take our discussions over there.

March 1, 2012 - 3:22 pm

Jenny's summary of the major changes is really insightful - thanks for sharing this. From my perspective, two items worth particular attention (both of which Jenny has highlighted quite thoroughly) are the changes to the alternative transportation credit and the institution of the establishment/performance split. The alt transport changes are substantive and profound - I'm not sure I agree with all of them, but many of the ideas there are worthwhile. And the E/P split is something I strongly support - I think it will facilitate recertification enormously. Mostly I'd just encourage folks to give those two areas a bit of added attention as they think about 2012. Thanks again Jenny.

March 1, 2012 - 1:59 pm

Getting rid of the 3rd option is such a huge mistake. I can't believe that the USGBC let the vocal minority win on this one...really disappointed. The 20% option would have brought us closer to the mission: market transformation. Others have brought up that they think that the 20% option "watered down" the rating system...I don't think that this could be further from the truth. The average office building consumes 17 kWh per sq foot. The average office space is 14,000 sq feet. This means that if just 100 buildings cut their consumption by 20%, we'd be looking at about 2.5 million kWh - and that's just a starting point. What happened between the second draft and this draft?

September 24, 2012 - 11:30 am

I am certain that the pilot is still open.

September 24, 2012 - 10:59 am

Does anyone know if the 500 project max for this pilot option has been hit yet? I can't readily see anything that indicates that the option has yet closed out, but before I bring this possible pilot option to my client, I want to make sure it is still available.

We have been struggling mightily with a building in Boston built in the 1840s that has made significant strides in terms of energy efficiency, and we have done significant work in all other areas of EBOM, but we are very unsure that we can hit the min 69 Energy Star score. This pilot may be the answer for us. I echo all of the great comments above on keeping this 20% option in for the 2012 version of EBOM. I agree that it is key to give the less energy efficient buildings a chance at LEED if they show substantial improvement over baseline.

July 11, 2012 - 6:00 pm

We have one of the projects in the handful and are planning to submit in early 2013, so we'll let you all know how it goes...we are glad it's an option - it's allowed us to do some great things in the name of LEED so far!

July 11, 2012 - 5:36 pm

It can only be an open issue if it goes back in the rating system for the next round of public comment.

It probably needs to "prove" itself in the pilot library. I have not seen any significant promotion of it yet but maybe some things are happening behind the scenes. I have talked to several staffers about promoting it. Last I heard there were only a hand-full of projects using it.

July 11, 2012 - 3:14 pm


So with the postponement of LEED 2012, what happens now, is this an open issue once again?



March 22, 2012 - 11:43 am


One other thing worth mentioning is the issue of barrier to entry across rating systems.

Regarding BD&C
We've never had an instance in which (assuming it's not too late in the design and construction process) we've had to tell a client interested in LEED-BD&C that it simply isn't an option. In fact, the single largest barriers to entry associated with BD&C are usually the costs associated with energy modeling and commissioning; which are usually marginal relative to total project budgets.

Studies have also shown that while many LEED BD&C buildings do perform better than national AVERAGES (Energy Star score equivalence of 50), some don't. Certainly not all LEED BD&C certified facilities perform in the top 25% of operational energy performance.

This is not to suggest LEED BD&C doesn't require a thoughtful approach to design and construction and that a proactive team isn't essential. Just pointing out what we perceive as a significant difference. In many ways this is a credit to LEED BD&C system as the 2012 GBIR suggested 20% of all new construction starts in 2011 were registered under LEED.

We should be asking what is the best way to reach that kind of market penetration--in a much much bigger market--in our existing and operational buildings. Even if this credit were to change, we're not talking about every building, but a goal of 20% uptake would certainly be inline with USGBC mission, no?

Lets also remember that energy efficiency upgrades in buildings represents the single biggest wedge or opportunity in terms of reducing national carbon emissions. We should leverage LEED's brand recognition to engage more owners in meaningful environmental performance improvement discussions. Many operators and facility managers do want to improve performance, but when going to the CFO for financing the associated potential to pursue LEED certainly doesn't hurt.

Even if we were to limit the total points available to option 3 that would be fine, perhaps it would be inherently harder to reach gold of platinum if each EAc1 option were weighted correctly. However let's not forget that LEED is also an aggregate of environmental performance across categories and that there are plenty of facilities that might illustrate both great energy performance improvement over time and high performance in other operational areas.

All the best to everyone,


March 21, 2012 - 11:17 pm

Elizabeth raises a good point: Energy Star is far from perfect, and that's an improtant part of this conversation. Though I think it is a really valuable program and wish it continued growth and improvement, I can't say I have loads of faith in its accurate comparison of one building to the next. It's nowhere near as straightforward as pitting two Olympic runners against each other and seeing who fairs best. Frankly, it's also super easy to game if you know which levers to push, so I guess Barry's reference to doping is applicable here too. I think its main utility, actually, is in helping an individual buildings see how it's trending over time.

Another thing to consider: Does setting a high bar in for energy prerequsites in LEED drag the entire market forward, or does it create a binary of those close enough to pursue LEED and those not? In my experience, having barriers to entry that put basic certification out of reach for the great majority of buildings is not going to bring them along...they'll turn away from sustainability altogether or turn to Green Globes or something else, I'd guess. There are four tiers of certification. If we think we need to create an elite upper crust here, why not reserve it for Gold and Platinum and still find a way to include the other 75%?

Finally, we aren't talking about raising a kbtu/sf threshold, but a percentile threshold. This makes increases in the EAp2 threshold a zero sum game, where allowing a smaller percentage of buildings in means locking a larger percentage of buildings out, regardless of how much energy the save, or if they cut enough to be at the level of last years' elite.

Maybe I'm just addled by all the 80+ degree March weather here in Chicago, but this just doesn't seem useful in the larger sceme of the environmental issues we're trying to solve.

March 21, 2012 - 9:22 pm

To echo Marcus, if there are those who feel that being true to the USGBC’s mission somehow degrades their accomplishments, then there is a fundamental disagreement present about what LEED does and who it serves. My understanding is that LEED is foremost a blueprint with which to change the world, to solve serious environmental issues that face humankind. It is not, however, a tool with which to inflate brands or to establish an sustainability superiority matrix.

I do not speak for all APs/ AP O+Ms, but it would seem that LEED wants to help at the grassroots level, not sit on high in self-proclaimed greeness, waiting on the others to come along...If LEED is to reach its market transformation potential, then it must adapt to be as effective as it can - despite what short-term hits its green street cred may take.

As someone who has been working on a LEED EB project for nearly four years, and has painstakingly spent that time cultivating a LEED culture, creating momentum, working to reach this a goal of 69...and try as we might, we can’t. Our building was built for long term growth, it has an atrium, it has a complex data center, even a fuel cell for a period of time...what do all these things have in common? They are not accurately accounted for in Energy Star Portfolio Manager. I write this with all the respect in the world for Energy Star - we are proud partners in fact - but this means that EA PR 2 is not perfect as is. In this respect, LEED is, unfortunately, inadequate to serve the needs of its mission. In our effort to attain EBOM certification, we have cut our consumption significantly, the environmental equivalent about 4 railroad cars full of coal. There are other things we’d like to do too - and we can justify them more effectively if they can be packaged under the banner of LEED.

When this path came out, and was in two drafts, we hit the gas pedal. A cross functional team was formed; we set pieces in motion; a green team was organized - members got ‘LEEDing the Way” stickers on their workstation walls. We had a democratic process in which the people in the building chose the credits they most wanted to pursue - modeled after how LEED, in theory, reaches its standards.

It was shocking to see the Option removed. I am thankful only that our potential project may still benefit, but all of the others - and I know of several - that may not move forward because of this dramatic shift is unconscionable.

I hope that those with the authority to do so will restate the Option. More than I hope, I am asking and stating why it must be done. I would concede that not allowing as many points in Energy Efficiency is perfectly reasonable (no points is pushing it).

On a more personal note, with respect to LEED’s market transformation ability, I have seen it in my city with my own eyes. Green materials that were hard to find or services that were hard to nail down are now available with ease. Costs have come down in many credits, such as green office materials. And isn’t that what matters? I have believed that LEED was about the democratization of sustainability. And this belief is what has kept me focused for so long. I have spent most of my career so far on this. I was the first LEED AP at my company, an electric and communications utility in the southeast. I have devoted countless hours to learning these standards, working consistently to bring them to fruition. If LEED bypasses its opportunity to include leaders like our building, I will be disappointed not only on a professional level, but also on a values driven personal level. And I know that I will not be the only one. Please make the decision that best serves the mission; it is what best serves the organization long term as well.

March 21, 2012 - 9:18 pm

I too love a good metaphor and I think Barry's is illustrative. The question is about what EBOM is trying to accomplish - is it a program to promote top performance and recognize excellence among a relative elite (the Olympics) or is it a national health and fitness program targeting obesity and diabetes in the general population (the 20% reduction option). Right now it IS the Olympics but the 20% option redirects to a very different end goal. And I agree that if EBOM wants to continue to promote emissions reduction, helping those buildings is important. Is LEED the vehicle? It seems like it should be, but its an open question.

I also think Barry's point about the increasing technical sophistication of EBOM is a valid concern unrelated to the 20% reduction option. The rating system keeps getting better from a technical rigor standpoint but at the same time less and less accessible to the layperson. In some ways this is an inevitable trend as the plaque becomes more valuable in the marketplace, but boy. . . counting bike racks sure was easier than this latest SSc4 revision. . .


March 21, 2012 - 7:59 pm

Olympics NOT about medals?...wait until 2012 in London...the only thing the media will be concerned about is the medal table followed shortly by..who took what drug!
Ok, seriously if we're looking to change the marketplace then raising the bar of compliance is the perfect way to do that. In 2002 when the EB core committee was founded we talked a long time about what level of E* should be required and eventually picked 65...even though by EPA standards that wasn't a 'green building'. EB V3 stands at 69 with 2012 jumping again.
Now suddenly with Option 3 we are allowing high energy consuming buildings into the race..all this does is undermine the hard work that low energy consuming buildings have undertaken to gain their E* score.

March 21, 2012 - 7:26 pm

Barry we should continue this conversation over a beer. But I can't help myself.

If USGBC and LEED are not about market transformation then their respective mission statements are lying and I am wasting my time working with it. Perhaps we have a different understanding of the term. To me it implies market change over time. So if certain LEED credits are not about transforming the market then they should be removed.

LEED has not fundamentally changed since 2005 for BD+C and 2008 for EBOM. Not exactly high speed in my way of thinking and in my experience plenty of time for the status quo to catch up. Virtually every BD+C project we work now on gets LEED Gold without even trying. The market has caught up and when that happens LEED frankly doesn't mean anything. It just becomes a passer-out of expensive plaques. Maybe EBOM projects are not quite there yet. You know that market better than I. My read is that 2012 EBOM has not changed nearly as much as 2012 BD+C in recognition of the degree of market penetration and the need for more consistency in the O&M market.

As I recall it was a group of elites in this field, including yourself, that developed LEED in the first place. Maybe I am just naive and idealistic. I have always thought that LEED's fundamental purpose is to change the way buildings are designed, constructed and operated. Then again I have always thought that the Olympics were about using "sport at the service of the harmonious development of humankind" (quote from the Olympic Charter) not winning medals.

March 21, 2012 - 6:17 pm

That would be true if the REST of the LEED credits were based on market transformation...and they're not. Too many have been side tracked by insider and outsider forces that have split hairs to the nth degree.
Two Greenbuilds' ago Mike Optiz stopped me and asked "What changes should we be making to LEED EB"...I answered "Nothing!, we need a period of status quo so that the marketplace can catch up and understand what the devil we are trying to do'.
LEED are making changes so drastic and so high speed that by the time we've get the narrative down to a reasonable length..the whole thing changes...nothing can keep up (LEED-on-Line, GBCI, Reference guides, etc)
The only people who are going to 'gain' from this 2012 version are the marketleaders and those with the cash to throw at it....that's not market transformation..that's the begining of elitism.

March 21, 2012 - 5:57 pm

Hey Barry,

We are not saying that every buildings should be able to earn LEED certification, nor are we saying that every building should earn LEED certification based on potential. To get in the EBOM game significant improvers would need to show a 20% reduction in energy use. This requires a significant effort.

The fundamental question is this - is the purpose of LEED to recognize top performers or market transformation? The two are not the same. One is simply a strategy for achieving the other.

I'll send you my full rational for the inclusion of Option 3 in EBOM, then let me know what you think.

March 21, 2012 - 5:31 pm

Perhaps I could make a comment from a different angle....why is there such a push to get EVERY building into LEED. It's never going to happen, some buildings will make it and some won't. Is that such a big deal? If we want to have buildings in LEED that can stand the accolade of 'high performance buildings' then they better be "High Performance'...not some lowest common denominator that gets the plaque. (We'll leave aside the potential problem that many credits in 2012 are so expensive/so drill down that many buildings won't get the number of required points for a plaque!)
Those buildings that CAN'T make E* really should be classed as huge potentials for upgrades and upgrades that payback like crazy! Or great case studies about how to make improvements in buildings that have low E* scores....What is wrong with that?
As responders above have used analogies, here's another...we don't pick 2012 Olympic athletes and give them a gold medal for their potential, we pick them because they are the best of the best and they perform to that Olympic standard.

March 21, 2012 - 4:34 pm

Great analogy Bill!

Some folks want to see the numbers on this issue but I am assuming that it should be so obvious as to cross the line into just plain common sense.

March 21, 2012 - 3:54 pm

Some times inverting numbers can make things more revealing. When the cash 4 clunkers Federal program first came out I thought it was a joke. Who cares if a car goes from 10 mpg to 14 mpg. We need the whole country average to move from 20 mpg to 40 mpg.

Low hanging fruit.
10-14 mpg is 28.6 gallons saved per 1,000 miles.
20-40 mpg is 25.0 gallons saved per 1,000 miles.

Yes, it would be great if everyone had cars with at least 40 mpg just like it would be great if every building could earn at least 75 Energy Star rating.

But if our goal is to reduce total national energy usage it would be unwise to ignore the energy hogs. Give them a realistic stepping stone. Their small step can still be a big energy savings.

March 21, 2012 - 3:16 pm

Great to have you on board Marc! Option 3 for all!!

I agree with your EBOM assessment Dan and that is a big part of the attitude shift that needs to occur to make EBOM an effective agent of market transformation instead of a reward for the already there.

If anyone is interested and has not yet received the opinion piece I wrote on this subject (written in part to get Dan on board) that was distributed last week via email I would be happy to send it to anyone who wishes to receive it. Just send me an email at sheffer@sevengroup.com

Since the public comment period was extended there is still time to register your opinion if you haven't already done so.

March 21, 2012 - 2:30 pm

Glad you've come around, Dan. I support the inclusion of this option as well.

To your point about the methodological problems, I'd suggest that they may not be any lesser or greater with this option than with others. I actually think any methodology developed to go with this option would likely be more transparent than the ENERGY STAR methodology since it would be USGBC developed, and no less or more subject to abuse.

Also, another interesting thing to note - the 2012 draft includes a few new offerings to earn points based on a demonstrated improvement over a historic baseline:

WE - Outdoor Water Use Reduction Case 2, allows showing a reduction over a 1 year historic baseline

WE - Indoor Water Use Reduction Option 2, allows showing a reduction over a 1 year historic baseline

So, the pivot has already happened in the WE section. Why for water but not for energy?

March 21, 2012 - 1:19 pm

This debate has been both fascinating and enlightening to me - thanks to everyone who has shared their thoughts. I have largely come around to the conclusion shared by most folks here - the 20% reduction option is a good move and the methodological problems it poses are manageable. That being said, I feel like its worthwhile to explain why I think its not a no-brainer for USGBC to embrace this option.

EBOM has always been a recognition program for outstanding performers. The entire rating system is predicated on performance relative to peers rather than improvement. SSc4, WEp1, WEc3, everything (although the word 'reduction' is used liberally it is almost always used as a 'reduction from baseline' rather than historical reduction). The one exception, as Marc notes, is the Case 2, Option 2 path; this path exists because there was basically no other way to handle buildings that were ineligible for all the preceding paths. Rather than simply tell those buildings "Sorry, EB isn't for you." this path became the last resort.

The point I am trying to make is simply that opening a 20% reduction compliance path for what we all agree is the key gatekeeper prerequisite to the rating system would represent a profound change to what EB currently is and does.

I happen to agree with Marcus (OK, Marcus convinced me) and Elizabeth that the change is worthwhile, the only way to broaden market participation, and the right choice for achieving the fundamental mission, but I also understand why USGBC might be reluctant to make such a pivotal shift without being very confident in the consequences.


March 21, 2012 - 1:15 pm


Thanks and got it. We still feel there should be an actual option within the EA credit structure and potential achievement of resulting points, and will continue to, along with other such as yourself, advocate for that option. A pilot credit is not enough.



March 21, 2012 - 1:11 pm


We hope to get a bit of clarification from others regarding the questions outlined above, but wanted to share what we posted to USGBC comment RE: EA Pre1 Credit 2 as well.




This prerequisite represents the single largest barrier to widespread market uptake. Per a recent LEED review comment we received on a recent project "Additionally, note that the intent of this prerequisite is to reward documented energy efficiency over time, rather than just a reduction in energy consumption due to other factors."

However as past and current LEED guidelines are written the credit is structured so that the historical improvement option is limited to specific non energy star eligible building types (and a small overall percentage of the market.) If market transformation is the goal then a percentage improvement over time (20-25%) should be available to ALL building types.

Three specific issues:

We've had a number of client specific instances where the current Energy Star score and associated uncertainty around the potential for capital improvement to impact the Energy Star score to level needed to pursue LEED (and yes we used tools to estimate projected savings and future Energy Star scores) have actually retarded investment or willingness to pursue the rating system.

Buildings with the worst operational energy performance (lowest 25-50%) often are the best suited for operational and capital investment and can best illustrate performance improvement over time.

In our region, people are just beginning to see the value associated with baselining/benchmarking facilities as an operational best practice, are becoming more interested in closing the gap between high performance design, construction and operations, and are now seriously considering LEED EBOM and other building performance standards.

However also consider this, regionally, we are already behind in terms of EBOM and Energy Star uptake. As the bell curve shifts and a rating of 75 equates to even less kbtu per square foot usage over time, will certain regions who are already behind simply find compliance impossible? I know that the PM tool normalizes for efficiency across the country, but it cannot account for regional or state initiatives, progressive culture, or regional advancement.

Make Case 2 Option 2 or (now eliminated Option 3) use of historical data and incremental improvement of a minimum of 20-25% the LEED performance threshold available to all building types. If an absolute must be applied then perhaps moving the minimum performance threshold to 50 or even 25 in terms of energy Star score or similar benchmark would have HUGE implications for potential market uptake, and resulting building energy efficiency investment.

Rob Watson wondered why there wasn't more EBOM uptake in 2011 in his most recent Green Buildings Impact Report, we suggest the barrier to entry plays a significant role.

If we want to see widespread market uptake then we need to make the system available to the whole market.

Thanks for all of your hard work.

March 21, 2012 - 12:59 pm

Hi Marc,
The Option IS available to only buildings that can be rated by Energy Star...

From the Pilot text:
Eligibility: The pilot ACP is only available to projects from ENERGY STAR-eligible
building types.
Bank/Financial Institution
Data Center
Hospital (General Medical and Surgical)
House of Worship
K–12 School
Medical Office
Municipal Wastewater Treatment Plant
Residence Hall/Dormitory
Retail Store
Senior Care Facility
Warehouse (refrigerated and non-refrigerated)

Unfortunately, you cannot earn any points under energy efficiency, and it's still not open to buildings that are not eligible for an Energy Star rating. But if you building falls in to one of those categories, you should be able to use the ACP...please correct me if I am wrong, however -

March 21, 2012 - 12:48 pm


Under EA Pre 2 Credit 1: Case 2 Buildings Not Eligible for an Energy Star Rating

Regarding the elimination of Case 2 Option 3, can anybody describe how this option differs significantly from Option 2? We're not seeing the significance as this option only applies to buildings already not eligible to receive an Energy Star score. Isn't elimination of Option 3, really a conflation into option 2?

If something like Case 2 Option 3 were available to ALL building types- that could be transformational concerning potential market uptake.

Are we missing something here? How we can we help to advocate that Case 2 Option 3 might be available to all building types looking to improve? We couldn't agree more that the number one barrier to entry for LEED EBOM has been the restrictions associated with this prerequisite and credit.


March 9, 2012 - 5:28 pm

Hi Marcus, I think that we figured it out...believe that the baseline was set incorrectly, but after speaking with you, I just deleted a couple meters and started all over...and am pretty sure the disconnect was found. Just being able to discuss out loud helped immensely. We now show three different baselines, and a resulting decrease of 35%, an amount much more in line with our drastic decrease in overall energy consumption. Thanks again for the encouragement and support!

March 2, 2012 - 5:32 pm

It is odd that your EUI is identical each year. What is the variation in the actual energy use year-to-year? May have something to do with the way Portfolio Manager treats the baseline year. Perhaps have PM look at the past five years individually (not as the baseline) and see what the EUI calculates for each year. Then do the calculations outside PM. I would need to play around with PM to figure out exactly how to do this.

As I said Elizabeth you are the test subject in a pilot prerequisite. Let me know if you can't figure it out - I'd be willing to help.

March 2, 2012 - 3:33 pm

Ditto the comments about the 20% Improvement option. Taking this out drastically limits the market impacts of LEED-EBOM - many projects that could be motivated to generate big energy savings will never participate without a compliance path based on percent improvement.

March 2, 2012 - 1:24 pm


March 2, 2012 - 1:30 pm

Been playing around in Portfolio Manager...have 5 years and one month of data in there (01/2007 - 01/2012). Our Baseline Source Energy Intensity is as follows: Year 1 (02/2007 - 01/2008) 330.4; Year 2: 02/2008 - 01/2009) 330.4; Year 3: (02/2009-01/2010) 330.4. This is an obvious 3 year average of 330.4...not sure why they are all the same, doesn't seem correct, but this is what PM is spitting out. The current "Performance Period" would be 02/2011 - 01/2012. The source energy intensity for this time period is 269.3...this leaves us with a frustrating % drop of 18.49%...does this seem correct? It doesn't seem possible considering that our building has shed a total of about 39% (in kWh consumption) of its electric load during this time...any insight would be so appreciated!

March 2, 2012 - 9:21 am

You are correct and even LEED 2009 projects can sign up and use it.

March 2, 2012 - 8:33 am

Hi Marcus,
Thanks so much for this reply...I really needed to read something like this! So, if what I am reading is correct, the first 500 buildings to register for this pilot credit may move forward with LEED certification, and the 20% reduction will suffice for EA PR 2? This is excellent news - and we will need to move quickly! Is my understanding correct? Just want to be completely sure...and yes, for my part, I will not give up in working to ensure that Option 3 is restored. Eyes on the prize: Market Transformation. And here on the front line in the Southeast, where efficiency is not top of mind for most, the idea of placing "brand" over "mission" seems just incredulous...seems very out of touch with the reality we are dealing with on a daily basis.

March 1, 2012 - 8:24 pm

I am sorely disappointed with the outcome here as well Elizabeth. Still licking my wounds from fighting for this Option on the LEED Committee calls leading up to this round of public comment. The mission connection here is beyond obvious in my opinion.

As a consolation prize a prerequisite was introduced into the pilot credit library that will allow projects to test the 20% improvement path. See http://www.usgbc.org/ShowFile.aspx?DocumentID=18563 The good news about that is that projects can test it starting now! The bad news are the what I consider to be severe restrictions being placed on the pilot (no EAc1 points available and an unprecedented limiting of the certification level).

There has been some talk of introducing a pilot credit so projects can earn EAc1 points but that is still being discussed.

So apparently a small but influential group within USGBC/LEED feels that "brand" integrity is only defined as a recognition of top performers. For me brand integrity is being true to the mission of market transformation. Maybe some other organization will jump in and create a recognition program that really does something to address climate change in existing buildings. In my opinion LEED just dropped the ball on that issue.

I will echo Tristan's suggestion and urge anyone who feels strongly on this issue to flood the USGBC with third round public comments to restore this Option and to sign up for the pilot to demonstrate demand for this option.

March 1, 2012 - 11:51 am

Eliazabeth, it's a not a done deal! This is the 3rd round of comments--please take a couple minutes and make your point here about why you think it should change.