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LEED 2012 – 3rd Public Comment – IEQ (Indoor Environmental Quality) Section

Key changes in the the third public comment draft of LEED 2012
March 1, 2012

Key changes in the the IEQ section of LEED-NC (part of LEED BD&C) in the third public comment draft of LEED 2012 are discussed below. Do you have comments or questions on this draft? Discuss them below with your fellow LEED professionals. Substantive comments submitted here during USGBC's third public comment period here will be submitted to USGBC and considered "official" public comments.

More information on LEED 2012 certification and the third public comment.

Minimum IAQ Performance, a prerequisite still references minimum ASHRAE-62.1–2010 requirements. In a change, outdoor air delivery monitoring requirements that had been folded into a consolidated credit are included as a prerequisite for all BD&C projects, not just CS.

Environmental Tobacco Smoke Control sees additional fine-tuning of requirements rather than any major change (such as absolute prevention of smoking). Non-smoking requirements extend to outdoor spaces used for business purposes, like patio seating.

The new Enhanced Indoor Air Quality Strategies credit retains its repackaging of key requirements from eliminated credits—Outdoor Air Delivery Monitoring, Increased Ventilation, and Indoor Chemical and Pollutant Source Control. With some minor language tweaks in this round, including adjustments for international projects, Option 1 in this new credit includes the key track-off, exhaust, and filtering requirements from LEED 2009’s IEQc5, and includes the key natural ventilation requirements that are part of IEQc2: Increased Ventilation in LEED 2009. Option 2 for this credit requires meeting Option 1, plus requirements that are similar to LEED 2009 requirements for increased ventilation over ASHRAE 62.1 and for outdoor air delivery monitoring. Those requirements are a bit more sophisticated, however, incorporating use of modeling (with new details in this draft such as specific mention of Computational Fluid Dynamics) to show that air contaminants will be below key exposure levels.

The third draft of LEED 2012 brings us a third major overhaul of Low-Emitting Interiors, although the overall systems approach introduced in the first draft remains. The system has changed, and now references seven relevant systems: paints and coatings; adhesives and sealants; flooring; composite wood; ceilings, walls, thermal and acoustic insulation; furniture (if in scope); and exterior-applied products, which is only relevant in Healthcare and Schools. In a change that is more like the first 2012 draft and LEED 2009, projects will now have to earn points by being compliant in one or more of these systems. A more sophisticated total percentage compliant score, more akin to the second draft, is available for projects that want to use a budget method. There are more specific requirements regarding manufacturers’ claims and standards for testing laboratories. As with the previous draft, product compliance is based on exposure limits defined in California Department of Public Health (CDPH) Standard Method V1.1-2010, often referred to as California Section 01350.

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Construction IAQ Management Plan is back as a credit, not a prerequisite. It is unchanged from the last draft except for a European-friendly filtration reference, and what amounts to an enhanced environmental tobacco smoke credit for construction: “Prohibit the use of tobacco products inside the building and within 50 feet (15 meters) (or greater, if local jurisdiction requires) of the building entrance during construction.”

Indoor Air Quality Assessment is the new name for Construction IAQ Management Plan—Before Occupancy, and it hasn’t changed a lot sine the previous draft, in which the Option 1 flush-out path preferred by most LEED projects would be downgrade to one point, versus two points for Option 2: Air Testing. Changes in this draft appear to be minor and involve specifying ASTM and EPA test methods for various contaminants. Carbon monoxide has been added as a chemical to be tested.

The Thermal Comfort credit, which folds in the old design and control credits that were separate, has been updated with some wording changes and a new reference to ISO 7730, a more international-friendly standard.

The new Interior Lighting credit covers the scope of the LEED 2009 “Controllability of Lighting” credit, which falls under Option 1, while Lighting Quality can optionally be pursued for a separate point under Option 2. The changes in this draft are mostly minor, retaining specific emphasis on providing three lighting levels (or “scenes”) for individual and multi-occupant spaces: on, off, and mid-level. For lighting quality, projects would have a choice of meeting four quality measures, which are now in two categories: hardware and design. These measures include color rendering index (CRI) requirements and use of bright surfaces.

The Daylight credit, overhauled in the first draft of LEED 2012, is overhauled again here. The focus of the first of two simulation options is providing a new metric, Spatial Daylight Autonomy, defined as “the percent of aggregate floor area of regularly occupied spaces which achieves a minimum hourly illuminance value of 300 lux at task level for at least 50% of the hours between 8 a.m. and 6 p.m., local clock time, after accounting for typical weather conditions, exterior obstructions, attached furniture systems, and after blinds have been operated hourly to block direct sun predicted to enter the space that would fall on more than 2% of the calculation grid.” The second simulation option is not changed as significantly, whiel the third option, for measurement,  has gained specifics on how measurement should be performed, such as measuring twice, at diverse times of year. The first simulation option provides the most points in this draft, up to three, the second option offers up to two, while measurement provides only one.

The LEED 2009 credit on views became Quality Views in the first LEED 2012 draft, and thus it remains. The credit has wording changes in this draft, but nothing that appears significant. Occupants should be able to discern objects at least 25 feet outside the vision glazing; flora, fauna, or sky; and movement for quality views.

An Acoustic Performance credit was previously only available to Schools projects remains available to NC projects in this draft. Pprojects would have to achieve four specific acoustical objectives defined in the credit language, although one of these has been removed from the last draft: requirements for speech privacy. Vague language allowing historic renovation projects to justify design decisions outside of the credit requirements has been made more specific: three of four requirements must still be met, with a narrative explaining design decisions.

What's your take on the proposed changes? Please post your public comments below.


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March 26, 2012 - 9:50 pm

With USGBC's comment period closing in 12 hours (according to its homepage -- the only place I could find the 9 a.m. EDT time noted), LEEDuser must close this forum as of now as an official place to comment so that we have time to put these comments in the form required by USGBC. Please visit USGBC directly to make an official comment in the next 12 hours. Thanks for the great discussion, and keep it going, even if it isn't "officlal"!

March 27, 2012 - 7:28 am

Based on the USGBC homepage, I had been telling people last night
that the comment period closes today at 9 a.m. EDT. However, I received
the following communication thiis morning from USGBC. Despite the time
change, we must still keep this LEEDuser forum closed for official

Despite our efforts to widely communicate the one-week extension for
third public comment, overnight we heard from a few folks who  thought
they had all of Tuesday, rather than the 9 am EST cut-off we had
communicated.  Since it won’t materially affect the schedule, we’re
extending the cut-off until 5 pm EST today, March 27, 2012.

March 26, 2012 - 8:22 pm

I’m the Guest Expert for several of the EQ4 pages on LEED User, so it seemed like a good idea to comment on this credit. (Disclaimer – I haven’t read the detailed dialog below because I didn’t want to be swayed in one direction or the other, so I apologize if some of this is repetitive.)

First of all, YIKES! This has gotten so complex that I may feel compelled to step down from my Guest Expert post. How many PhDs does it take to calculate this one?

Here’s what I like, in comparison with 2009:
• The categories now more closely reflect the 2009 ones, which makes the change just a little less crazy.
• The thresholds for paints, coatings, adhesives and sealants doesn’t require 100% compliance by volume for emissions criteria. This helps to ease in the transition to this new requirement. However, as per my discussion below I think 90% may be too high of a bar the first time out of the gate.
• Budget method compliance is still available.

What I don’t like:
• Way more documentation for fewer points and not necessarily much (IMHO) improved performance over 2009.
• The standards are very confusing. Most people won’t understand how to even begin pursuing this credit. Please cite compliant standards, as previous versions have done.
• I have concerns that there may be quite a few product types that will have no products available that meet the requirements here, given that some of these requirements are relatively new to the industry. It takes manufacturers a while to catch up with the requirements for testing, even if the products already comply. I’d like to hear the opinions of leading manufacturers in this area, e.g. PPG or Johns Manville.
• Why don’t all projects need to comply with the no added formaldehyde requirement for batt insulation? Formaldehyde is arguably nastier than some of the other things addressed in this credit.

It’s very possible that this uncertainty, combined with the big price tag of documentation, will cause teams to ignore these credits for others that are better understood and/or perceived to be more achievable. I think these credits are extremely important but am concerned that they won’t be easily implementable – or even understandable – as they currently stand.

March 27, 2012 - 7:36 pm

Dwayne, thanks for your comments. That's very interesting and very useful. I especially agree (from my limited info) that the market will move quickly and easily in some sectors and for some product types, but not others. I even occassionally face manufacturers that make specialty products and have a more limited market who say that the cost, time and effort for testing simply isn't worth it. I hope this changes, but in the meantime we're left trying to deal with specifications, contractors, etc. My biggest concern at the moment is that teams will revert to standard practice instead of trying to pursue these complicated points. In hindsight I wish I could have added the comment that LEED could alternatively offer just one point for pursuing three of the four or all of the 2009 requirements (or something like that). That way there's still a little incentive to use low VOC products. Much of LEED 2012 feels like we're destroying the good in search of the perfect.

March 27, 2012 - 1:18 pm

Mara: I wanted to share some thoughts with you even though this forum is now past the LEED 2012 PC3 formal deadline. In the interest of disclosure, I am the Regulatory Affairs Director for a coatings and sealants manufacturer, PROSOCO. I serve as the primary subject matter expert for coatings and sealants on the EQ TAG. However, these comments are not presented on behalf of the TAG or USGBC.

I had informal discussions with some of the primary coatings producers exhibiting at Green Build last year and follow-up discussions this year with some American Coatings Association member companies. Many of these companies were early adopters of CDPH testing due to LEED for Schools and CHPS credit potential. If I had to summarize the opinions of this snapshot of producers in one word, I would say "conflicted".

In general, this producer sector realizes we are headed down the road towards indoor emissions evaluation as being a primary determinant of suitability for interior use in sustainable construction. Some of the producers are confident in creating large surface area/volume coatings that meet the current CDPH requirements. There is an equal level of concern that the specialty and low volume products may not get there or that the economics don’t add up to support direct testing cost and staff overhead. Improving formulations and driving down mass VOC content is second nature as we approach the 40th anniversary of the first coatings VOC regulations. The point we hit the wall is when formulary technology doesn’t keep up with performance demands. First and foremost, designers and owners expect coatings to fulfill their primary function in protecting building materials from premature degradation.

As a producer sector that has been brought into the emissions testing realm 20 years late, we’re still feeling our way. There are many questions regarding product grouping and space modeling yet to be resolved in ongoing consensus standard work. There are hundreds of coatings companies with tens of thousands of interior use products. The current number of tested products barely scratches the surface of the market as a whole. On the other hand, as PROSOCO approaches its fifth year of having third party tested products, I know that we have brought some of our competitors along. That is the nature of market transformation.

I share your concern on where we set the boundaries for this phase of market transformation. Can coatings and sealants producers help design professionals hit the 90% threshold?

Personally, I am comfortable that certain building types can get there. Offices and standard retail finish out are probably there and competition will bring more producers along. Hospitality might be there depending on how exotic the substrate selection is and whether they need protection. I would be interested in your perspectives on healthcare as those facilities require coatings that have to stand up to sanitization abuse. I am confident that some schools can get there, but others may be problematic due to swimming pool facilities and specialty gymnasium flooring required for conference rule conformance. For high rise buildings, I have concerns about specialized fire resistive coatings for structural steel components. I’ve heard concerns from one major manufacturer about the ability to produce CDPH conformant dry fall coatings for ceilings and steel truss components.

LEED is well beyond office buildings and schools at this point. PROSOCO’s floor finishes are also in hospitals, retail, big box and grocery stores, high rise residential, warehouses, manufacturing plants and data centers – many of which are designed to LEED or “LEED equivalent”. I think we need to be mindful of LEED building diversity as we move the market forward.

Thanks for your thoughtful comments on the credit and feel free to contact me directly as needed.

March 26, 2012 - 8:25 pm

I will add that, even as an expert in this area from the practitioner's perspective, it will take quite a lot of serious research to determine all the ifs, ands and buts involved with the various requirements, standards, calculations, etc. discussed here. I appreciate the comments of my colleagues below - especially Josh, Reinhard, and a few from Nicole.

March 20, 2012 - 7:17 pm

Based on the way this credit appears in the draft, you get one point for having the 10 feet of matting, and then an additional point if you have either 1) MERV-13 filtration in place, 2) Carbon Dioxide Monitoring, or 3) Outdoor Air Monitoring. We highly disagree with the point allocation and credit breakout for this credit. First off, most of the properties we work with can’t meet the matting requirement due to construction restraints or other reasons. Therefore, the credit is often dismissed. The way the credit reads, it appears that if you had outdoor air delivery monitoring and MERV-13 filtration in place, you still wouldn’t get a point unless you achieve the entryway mat credit first. This seems ludicrous. Although the matting aspect is a good IAQ strategy, filtration and outdoor air delivery monitoring both have their own independent positive aspects, and should be rewarded as such. Outdoor air monitoring is becoming a great energy savings measure as well, and should be additionally rewarded due to the overall positive impacts of its implementation. All of these aspects should not be reliant on the building’s capability to meet the entryway mat credit. The matting credit has proved to be more challenging than it appears on paper. Also, the combination of these strategies should be worth more than 2 points total if you are able to achieve all four.

March 20, 2012 - 6:39 pm

I corresponded with our audio designers (Fred/Richard) and here is a summary of their comments. Since I submitted my comment already, I was not able to add their thoughts to the public comment. So this is the only place I thought to go.

(Fred Schafer's comments)
Sound Systems:
1. Large conference rooms seating 50 or more people should also have a distance between the talker and the farthest listener as part of the criteria. In a theater the rule of thumb is 50ft. It may be beneficial to include that a sound system should be considered if the farthest listener is >50ft from the person talking.
2. I agree with Richard’s comment (below) with the addition that these representative points should be defined. STI+0.60 and CIS=0.77 are at the upper end of the “Fair” intelligibility rating. This may be acceptable for a mass notification system or fire alarm system. However, I would like to see an audio system for voice and other programming have at least an STI of 0.75 or a CIS of 0.88 which are at the top of the “Good” range as their minimum. NFPA-72_2010 calls for measurement points on 40ft centers. Using this criteria in typical church (40x90) we could get away with only two measurements. A number of measurements per SF would potentially be a better metric.
3. I also agree with Richard (below) regarding the issue of distortion. The sound system, at its maximum output level should not exhibit a distortion level greater than 1% and at a point 3 to 6 dB above that point a distortion level in excess of 5%. While a minimum performance sound level is nice (70dBA) it would seem that this is referenced from some other document (such as NFPA-72) where they are referencing paging or voice notification levels. The sound coverage at the 2K octave band should also be noted as being measured with a slow meter rather than fast meter setting. This will discriminate against the narrow band filtering that would be caused by the interference pattern between the HF elements of two speakers covering the same area.

Masking Systems:
1. Items 1 & 2 are reasonable.
2. Item 3 should have a spectrum reference either from the ANSI masking system document or some other generally accepted reference.

Richard's Comments:
STI of 0.6 or better corresponds to "good" or "excellent", meaning 95% or better sentence intelligibility (87% or better word intelligibility). Appropriate.

Sound level spec should include some sort of peak factor, and a distortion criterion at the specified level, such as "capable of providing average levels of 70 dBA using speech signals, with harmonic distortion not to exceed 5% on peaks of 80 dBA." Otherwise, this could be interpreted as permitting a system to only provide pink noise at a 70 dBA clipping point. Radio Slack would love it! "Minimum" standards have a way of morphing into design-center goals, so one has to be careful.

A tolerance of + 3 dB is pretty tight for what will likely wind up being low-budget systems, but then they're only looking at the 2 kHz octave band -- the one most critical to intelligibility. (Just a comment).

No comments on the masking criteria.

March 20, 2012 - 2:33 pm

If someone else has not submitted a comment, I have more than I submitted (one per credit per person and cannot edit!)

1. suggests a noise range must be met. The 'range' was meant to be a range of design goals (maximum noise level to meet in design) for the type of space. It was not meant as a performance spec for noise measurements, or a minimum noise level. The idea was that for some projects higher design goals are acceptable, and others quieter goals are required than the stated goal. Thus +/- 5 dB. I submitted a comment on this.
2. Not clear if room sound levels have to be measured or merely designed and calculated. My view is one or the other but not both.
"Measurements for room sound levels shall be measured using a sound level meter that..." could be interpreted you have to measure noise levels, but I think it was intended to tell you how you have to do it if you do it to show compliance. I also think compliance should be no more than 5 dB above the stated maximum design goal. It is also not clear on what type of measurement technique must be used (room sampling, background noise, different flow conditions etc...).
3. It appears it is specific that you need to show you meet the HVAC noise level via path calculations, but again I wonder if this was one of two ways to comply.
4. work is underway in 189.1 and international green building code for similar requirements... I am sure this will continue to develop as this is the first time such an extensive effort has been made to add acoustics to all building types.

March 19, 2012 - 7:40 pm

The revisions in the proposed EQ credit Low-Emitting Interiors will strengthen the requirements, heighten the level of transparency, and increase the value of 3rd party certification. Overall, SCS encourages supporting the changes made to the proposed LEED 2012 EQ credits and most notably recognizes the following improvements and progress:

• While the credit does not recognize a specific certification program, it most notably does not exclude any specific program. This position clearly demonstrates an effort to ensure the credit’s initial intent to reduce concentrations of chemical contaminants impacting human health and the environment.
• The standards and criteria referenced in the credit are all publicly available and verification may be performed by any clearly defined qualified laboratory and certification body.
• For building products, the credit now references the stringent requirements of CA 01350, which was developed through a multi-stakeholder process to establish baseline criteria for health based emission limits. The standard continues to evolve its stringency via a diverse reviewing body consisting of industry, non-governmental organizations, government, academia and other interested parties. On January 1, 2012 the standard integrated its most stringent VOC emissions criteria for Formaldehyde: 9ug/m3.
• In addition to CA 01350, the new credit references the rigorous ANSI/BIFMA Furniture Emissions Standard and ANSI/BIFMA Furniture Sustainability Standard, which have both met ANSI verification requirements for due process and consensus. The standards were developed and publically reviewed by a balanced group of multi-stakeholders, non-governmental organizations, industry members, and other interested parties, including third-party certification bodies..
• For furniture, the new credit provides a weighted calculation for compliance based on the emissions criteria from the ANSI/BIFMA e.3-2011e credit 7.6.1 (also equivalent to the ANSI/BIFMA Furniture Emissions Standards criteria) and from credit 7.6.2, which is comparable to the emissions criteria within CA 01350. This credit places more significance on furniture systems meeting credit 7.6.2 than products meeting credit 7.6.1, much like recycled content calculations place more emphasis on post-consumer recycled materials. This will drive further improvement in the indoor air quality performance of furniture products.

SCS has one concern about the current proposed 2012 changes. The new credit reduces the point allocation from four to three, reducing the incentive for LEED users to spend the time and effort to include lower-emitting products in LEED buildings. It is of SCS’s opinion that the USGBC should maintain the original 4 points associated with this credit to ensure its initial intent of establishing a high value to human health criteria.

March 20, 2012 - 9:25 am


Is there a comprehensive list of products that meet the new standards above?

While the new standards sound greener (we're all for greener here!) - and I'm sure will be good business for 3rd party certifiers - from a LEED Management perspective this credit sounds like a nightmare. If there was a large comprehensive list of products that met these new standards that any contractor / architect / engineer could choose products from - I'm sure they would love to try and meet these new standards. If on the other hand, for each product they have to try and figure out all of the standards listed above - forget it.

This is the only credit that covers low-VOC paints/flooring/adhesives/etc. If it is so complicated that teams won't even touch it - there might be a lot of backward movement in the LEED green building industry in regards to low-VOCs.

Josh - thanks for your comment below!

March 8, 2012 - 5:04 pm

As currently written, the proposed low-emitting interiors credit fails takes some small steps forward and, in my opinion, takes some steps back on protecting building occupants from indoor air pollution associated with product emissions. Rather than simplifying the credit (which would align with the USGBC’s publicly stated goal of simplifying the entire LEED rating system) and increasing stringency, the revised credit adds a thick layer of complexity and fails to raise the bar on indoor air quality across the board. This is somewhat alarming, given that the intent of the low-emitting interiors credit is to help protect the health of LEED certified building occupants.

Additionally, the proposed revisions all but ignore the serious concerns with indoor air quality raised in the report, LEED Certification: Where Energy Efficiency Collides with Human Health. Compiled by Environment and Human Health, Inc. (EHHI), the report concludes that LEED fails to protect human health because it allows and, in fact, rewards the use of high-emitting products during the construction, build-out, and furnishing of LEED certified buildings.

The primary problems within the proposed revisions to the low-emitting interiors credit are as follows:
• The new credit requires LEED users to analyze complex data and sift through eight pages of complicated mathematical formulas just to calculate a product’s eligibility to satisfy the credit. Additionally, the number of awardable points has been reduced from four to three. As a result, LEED users will likely skip the credit altogether in favor of pursuing credits that involve less work and reward a greater number of points. This will hurt the indoor air quality of LEED buildings.

• Furniture is held to different and less stringent emissions standards than other products.

• The industry-backed BIFMA test method is the only test method specifically cited in the credit for furniture, which may cause LEED users to believe—mistakenly—that this is the only qualified furniture test method in LEED. Particularly an issue because the test method uses a less stringent and less restrictive test model than other credible testing methods in the marketplace.

• The GREENGUARD Test Method (GGTM), the most widely-used and referenced product emissions testing method in North America, uses a much stricter modeling scenario and has adopted the new lower formaldehyde emissions level, as established by the California Department of Public Health for use in CA 01350. It is also what is currently used, alongside the BIFMA test method, in the current LEED Rating Systems for furniture.

To remediate these problems, the USGBC should:

• Make LEED simpler and easier to use, not more complex. The USGBC should make the low-emitting interiors credit easier to achieve by recognizing—by name— the third-party certifications that are known to comply with the testing requirements specified in the credit as they have done in other credits the rating systems.

• Reference and recognize the GREENGUARD Test Method by name, as well as other, stringent emissions test methods.

• Restore the maximum number of awardable points to four instead of three.

March 8, 2012 - 1:43 pm

Outside the US several industries are surprised to see less options of how to demonstrate low VOC emissions inside than outside the US: Only US-based low VOC programs are accepted in North America. But some very sustainable products are sold all over the world; if these products are manufactured outside North America then they will need additional testing for LEED projects in the US, even if these products had demonstrated very low VOC emissions under very stringent programs outside the US, being compliant with the "outside the USA" requirements of draft LEED 2012 language. The other way round, products tested by US programs would be regarded LEED compliant all over the world (with the only exception of paints, coatings, adhesives and sealants meeting different requirements just in one country - for LEED Italy).

Nevertheless, these alternative compliance paths will make available many additional well documented low-emitting products for LEED projects outside North America.

March 20, 2012 - 6:07 pm

The USGBC is working on that. LEED 2012 will have more option in the rating system to address international projects. I know that because they are reaching out to international project teams and experts to get their input on what would be an equivalent for any of the US standards in the rating system. So if you have suggestions as to what would be equivalent and how, please post them here.

March 8, 2012 - 1:38 pm

Some communications during public discussion left the impression that individual private low VOC programs would like to be referenced in LEED 2012 low-emitting interiors credit, such as UL Greenguard. What their recent pledge really goes for is to expand the number of referenced test methods, including their own UL Greenguard test method.

But if such a change would be made, then US GBC could influence competition between available private labels in several regions. Today draft LEED 2012 does not reference to any private low VOC programs or VOC testing methods. It references to public programs (CDPH, AgBB), and to consensus-based standards (ANSI/BIFMA). If LEED would change that approach then LEED could be urged to reference all of these methods, meaning besides UL Greenguard test method also the methods applied with programs such as ISO 16000, CEN TC 351, GUT, EMICODE, Blue Angel, Austrian ecolabel, EU ecolabel, M1, Indoor Advantage, Indoor Air Comfort, Floor Score, Natureplus, DICL, and more. All or nothing :-)

March 1, 2012 - 12:24 pm

Thanks for the summary, Tristan!
I wanted to point out one big difference in the IEQ section, as compared to LEED BD&C 2009, which is that the Thermal Comfort Verification credit (for occupant surveying) has been removed entirely. I'm not sure if there are other removals of entire credits that don't show up in the summary documents that have been published, but it seems to me that this would be an important area to provide some comment on.

It can't even be seen in the red-lined documents.

I feel like I must be missing something here, so please tell me if I'm mistaken in some way!

March 26, 2012 - 7:56 pm

I fully support Lindsay's comments - thanks for posting them more articulately than I would have. I see the disappearance of the POE as a big loss to LEED. In some ways the POE credit was one of the most powerful ones in BD+C (along with M&V, which has also tanked in 2012) because it actually tied design to construction.

Sure, it wasn't ever a perfect credit (were any of them?) but it has really helped my clients to think about occupant comfort in a different way than they might have otherwise. Sure, this is what EBOM is great for -- but while I encourage most of my projects to pursue EBOM, this effort is often in vain. Do we want to risk the loss of the POE for projects that don't pursue EBOM?

March 25, 2012 - 8:26 pm

I've submitted this comment through the official form, but wanted to post to LEEDUser, in the hopes of sharing this issue with others. Happy to start discussion, with the little time we have left:

This comment is to urge the re-placement of the Thermal Comfort Verification credit, more commonly known as the occupant survey credit, in the BD&C rating system. I appreciate that it is in EBOM, and I appreciate the theoretical construct of the USGBC staff in believing that it should be removed from the BD&C rating systems. But I respectfully disagree. For three major reasons:

1. Procedurally. It was not highlighted as a change in the 2nd or 3rd drafts of LEED 2012. This is a procedural anomaly, or, one might argue, a violation. Typically, changes are highlighted to the commenting public, so that we can decide as a community if we agree with the suggested changes. This change was not noted anywhere. One would have to sit with the 2012 draft next to the 2009 rating system to see the difference.

2. For the sake of market transformation. Sure, occupant surveying doesn't fit conveniently in the schedule of a BD&C project. However, it is still of utmost importance that architects, engineers, and the rest of the design team hear about the outcomes of their designs, NOT JUST THE OWNERS. If this credit only exists in EBOM, it will mean that we have eliminated this feedback loop for designers.

3. Because it's the best solution we have right now. I know we're all working on better, more streamlined ways to measure buildings, and occupant satisfaction, and happiness, and all of these wonderful lofty goals. But let's not eliminate the credit we have now, with nascent plans for the future. I would have loved to have seen this credit get better in LEED 2012, as so many other credits have. And I certainly attempted to do so. But worst case scenario, I'd rather see the 2009 version stay in, than nothing at all. It WILL continue to have a noticeable positive impact on the building industry- it is not wasted space, nor wasted credit allocation. Nor does it seem to be 'worth' considerably less than other process-related credits. I trust that it will be better than nothing. I urge you to trust with me. More architects and engineers will start making occupant feedback a part of their practice, if we keep this in. More surveys will be conducted, helping us to learn from our successes and mistakes.

And I think it goes without saying that the new phrase "Validate that the design criteria have been met..." in the Thermal Comfort credit will be pretty ineffective, as written. I mean, I'm sure I'm not alone on that opinion. That's got CIRs written ALL over it. Verify how? And with how many people? And analyze how? and what variables? Hard to believe that's a final draft.
Suggestion: Re-instate the Thermal Comfort Verification credit in the final, balloted version of LEED 2012. Then we can work together to improve the practice of occupant surveying, as a community, to improve the effectiveness of this practice in our industry. This would be, at least, not a step backwards.

March 1, 2012 - 1:19 pm

Thanks, Tristan! I didn't see that phrase in the Thermal Comfort credit about validation, so that's a consolation. I agree, I'm not sure what it means, and it's not very robust, given that you could likely interpret it as permission to ask 1-2 people whether they feel comfortable enough or not, and call it a day!

I think part of the issue here is that it was replaced in the 1st public comment draft with an Occupant Survey credit, which was then taken out in the 2nd public comment draft, so it was really in the 2nd phase that this occurred.

Either way, I hope that folks are able to see clearly where credits have been removed entirely. I'm unclear about why the official LEED documents don't do this for this credit (in any of the drafts), so I'll check in with someone at USGBC about it. Thanks!

March 1, 2012 - 12:39 pm

Lindsay, since we're now in the 3rd draft, I haven't compiled all the changes from the first  two drafts in this summary. You could see my other summaries on LEEDuser for that.

However, in Option 1 of the current Thermal Comfort draft, there is the following: "Validate that the design criteria have been met by either surveying occupants or analyzing environmental variables." Not sure what that means, exactly. Is anyone?