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LEED 2012 - 4th Public Comment and Ballot Forum

Although it carries relatively few points, among the most noteworthy changes in LEED 2012 are those in the MR category.
May 11, 2012

Editor's note: USGBC has taken your comments and opened the fifth public comment period with the new draft of LEED v4 (note the name change from LEED 2012). Please post your thoughts on our LEED v4 fifth public comment forum!

The LEED 2012 fourth public comment period will be open from May 11 to May 28 (11:59 p.m. ET).

Information on the 4th public comment draft of LEED 2012 is available on the USGBC website.

LEEDuser's analysis of the current draft is below, and we encourage the LEED user community to post your analyses and opinions here in this forum. Here are some useful links:

Under USGBC's process for development of the rating systems, any substantive changes must be followed by a comment period. This 4th comment period had not been planned—indicating that there are some noteworthy changes from the 3rd public comment period. However, any changes between now and the version that wil go out to ballot on June 1st are going to be superficial, making this comment period a warm-up for the balloting process.

LEEDuser's Analysis of the 4th Public Comment Draft

By Nadav Malin – LEEDuser

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With a special fourth public comment period, USGBC is now—through May 28—seeking input on the latest changes to the LEED 2012 family of rating systems. Only credits that have changed significantly since the 3rd public comment draft are open for comments this time. If you haven’t been paying attention, it’s time to wake up, because LEED 2012 is by far the most fundamental revamping of LEED in its history.

LEED has been through several iterations since it was originally launched in March 2000. It has also spawned additional rating systems over the years—the LEED that started things off in 2000 was just for “New Construction and Major Renovations” (NC); LEED for Existing Buildings, Commercial Interiors, Schools, Retail, Healthcare, Neighborhood Developments, and Homes all came later. But most of those changes trickled in: one rating system at a time, and relatively minor changes to credit requirements from one version to the next. LEED 2009 gave LEED a new point structure, with all the rating systems on a 100-point scale (plus bonus points), but the actual credit requirements didn’t change all that much.

LEED 2012 includes a fresh look at credits across the board, and introduces the first more specialized versions of LEED for Existing Buildings: Operations and Maintenance (EBOM), with EBOM for Schools, Retail, Data Centers, Hospitality, and Warehouses. While many in the LEED community have complained that the changes are too much too fast, few would argue that most of the old requirements have gotten old and tired.

Responding to those concerns, however, the fourth public comment draft continues a trend of backing off on some of the proposed changes:

  • The credit for electric vehicle charging stations and preferred parking has been reinstated in this draft, with minor adjustments.
  • A distinction between heavy and non-heavy construction and demolition waste was deemed too difficult to track on the job site and has been removed from this draft.
  • A requirement in the commissioning prerequisite to include building envelope commissioning was removed in an earlier draft, and now applies only to the credit.
  • Minimum energy performance over ASHRAE 90.1-2010 was lowered from 10% to 5%, recognizing that 90.1-2010 is already about 20% tougher than 90.1-2007, making the cumulative change too challenging.
  • An “angle of view” requirement that would have greatly restricted the indoor spaces that could count towards the views credit was eliminated.

Among the biggest changes in LEED 2012 are those in the Materials and Resources (MR) category. Even though this category carries relatively few points (about 10% of the total in most Building Design & Construction rating systems), it has the most direct impact on major building material markets with their associated economic and ecological impacts, so this category is a lightening rod for commentary.

USGBC has stuck with its strong commitment to the Forest Stewardship Council as the minimum standard for wood product certification. It has, however, backed off in this draft from a credit that included PVC—the plastic most widely used in buildings—among the substances to be avoided. That’s a function of a decision to reference the European REACH list for that credit. PVC remains among the substances that would have to be disclosed, based on the lists in Clean Production Action’s Green Screen Benchmark.

LEED 2012 introduces a more sophisticated approach to many of the materials credits, replacing simple proxies for environmental benefit, such as recycled content and rapidly renewable materials, with requirements that call for life-cycle assessment, disclosure of ingredients, and avoidance of problem chemicals.

These new approaches are challenging because tools and protocols for meeting these requirements are not yet widely available. USGBC is responding to this situation in several ways:

  • Introducing a pilot projects program and extended phase-in period for all of LEED 2012, so that only project teams that want to knock themselves out pioneering these new practices have to do so;
  • Pointing out that building commissioning and energy modeling were also not widely used when LEED began requiring them in 2000, so there is precedent for LEED creating this kind of infrastructure; and, to support that process,
  • Offering credit in some cases for merely reporting on ingredients and LCA results, regardless of how good those results are. This approach amounts to a big vote for transparency and support for developing data sources and tools, in the hopes that future versions of LEED will be able to make use of widely available data to set rigorous thresholds.

While the methods are far from perfect, moving to include mining impacts in the mix, and introducing some filters to the old blanket endorsement of any rapidly renewable material, are clearly big steps forward. Similarly, in the arena of indoor pollutants from materials, USGBC has determined that the market is finally ready to move from documenting VOC content to measuring VOC emissions. An attempt to do that when LEED for Schools was released in 2008 proved premature, but I think we’re ready now.


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May 23, 2012 - 11:41 am

I have heard from several people that the recent USGBC Webinar included that startling statement that projects certified under LEED would be required to undertake re-certification on some unspecified schedule. I cannot find that anywhere in the draft - did I miss it? Can anyone point me there? If this is, as it seems, showing up at the last minute, wouldn't it be better if this were a topic for discussion and debate, resulting in inclusion in the balloted version?

I believe that mandatory re-certification will have ramifications in the marketplace and that we should vote on it.


May 25, 2012 - 4:22 pm

This just landed in my in-box (5/25):

"Dear LEED 2012 Consensus Body Members:

Recently, several of you participated in the first of our LEED 2012 Consensus Body webinar updates. During the webinar, the comment we made about recertification caused confusion and was not accurate. Recertification is a component of LEED for Existing Buildings: Operations and Maintenance. Developing a performance-based recertification program for all LEED project types is a concept at this time and is not connected to LEED 2012. LEED 2012 contains new prerequisites for energy and water metering. Metering is fundamental to building performance, and we believe these metering requirements will help LEED projects maintain excellence in operations over the long term. As USGBC begins its work on a performance-based recertification program we will keep you informed of our developments.

Thanks to those of you who participated in our recent webinar; we look forward to continuing our dialog with you in the coming weeks.


The LEED 2012 Team @ USGBC"

May 24, 2012 - 1:50 pm

Thanks, Mara. Generally, the 'product development' process for LEED could use some improvement so that the TAGs are at least aware of important administrative issues.

May 23, 2012 - 12:24 pm

I didn't mean that recertification would back-apply to prior versions of LEED - more that they did not seem to be open about this (or I missed it?) during the 2+ years we've spent developing "V4".

May 23, 2012 - 12:21 pm

I seriously doubt that this would be done retroactively. That WOULD be 'backhanded,' but the idea that makes the most sense substantively and politically is that it would apply to V4 and beyond.

May 23, 2012 - 12:16 pm

I couldn't agree more. There's been talk of recertification since forever (as Rob points out) so it's no surprise - but this raises the issue that the MPRs can have a far more reaching impact than many of the technical issues. "Program administrative issue" or not, determination of these in a black box can be problematic. I wouldn't mind the recertification issue so much if they were open about it from the beginning. It feels a bit backhanded.

May 23, 2012 - 12:12 pm

Hi Rus--I too heard that statement in Monday's webinar. I have yet to get the details. As you may remember from the early steering committee days, I felt that there should be a 5-year 'use-by' date before a LEED certification becomes 'stale'. I understand that there are also reasons not to do so for a design-oriented standards, but I think the pros outweigh the cons. Perhaps a separate forum for that... Anyway WRT your point about this being a ballotable issue, it seems to me that this would fall under a program administration issue, rather than a substantive technical issue, which is where the line is typically drawn for what gets balloted or not.

You are 100% correct that this is a huge issue affecting the market. I think that USGBC would be well advised to undertake a parallel discussion--not tied up with the V4 ballot--of the implications of this step.

May 23, 2012 - 8:37 am

The FSC Standard that certificate holders are certified to and follow, allow FSC claims to be based on either weight or volume. LEED 2012 appears to restrict the calculation to weight only. Why doesn't LEED align with the FSC Standard and allow calculations to be based on either weight or volume? Restricting the calculations to weight only will cause confusion in the documentation of FSC products through the supply chain, as many manufacturers have chosen the volume option in lieu of weight to qualify their claims. Companies that take ownership of the manufactured goods that are certified to the FSC Standard under the Transfer System are required by FSC to "transfer" the exact same claim from their vendor’s invoice to their invoice and shipping papers. Manufacturers and distributors of certified goods must be consistent in their claims and cannot base a given FSC claim on both weight and volume. I can only guess that the documentation of the certified wood content will not be accurate if LEED needs does not align with the FSC Standard and allow calculations to be based on weight or volume.

May 22, 2012 - 9:05 pm

I have a vocab question regarding the raw materials credit. It says under option 2: "Calculate compliant building products and materials for 50% of one material type (1 point) or two material types (2 points)." What is a material type? Is it concrete vs steel vs wood, or biobased vs. non-biobased, or something different? Am I missing an explanation somewhere? That differentiation is really important.

May 18, 2012 - 11:51 am

The 2nd draft had a fine print note prohibiting the use of fly ash in the concrete on HC projects. The 3rd draft removed this note.

Comment #3488 from the 3rd draft still asked to remove this fly ash restriction. Then the response from USGBC was that the fly ash restriction on HC projects will remain. I don't see this in the 4th draft.

Was this just an 'oops' or will this fly ash restriction show up in the Reference Guide?

May 23, 2012 - 9:50 am

I have commented to have this removed as well. I understand the need to not use products with certain chemicals. But I see the fly ash as a by-product and in Maryland/West Virginia/Virginia we aren't going to stop burning coal for a long time. Wish that wasn't the case but it is reality. I would much rather use that by-product to replace a manufactured product.

In HC the issue is that there is a MR pre-requisite to eliminate mercury and the fly ash from coal plants does contain mercury. Until the MR pre-req migrates to other LEED programs, the fly ash restriction will likely stay with HC.

May 23, 2012 - 9:01 am

I actually commented in the 2nd Draft to have this note removed. From my own 10 minute search on Google I found a study showing that after 2 months of curing there is no difference in emission from portland cement vs fly ash cement.

My concern was that this was being used as a foot hold into LEED and that the next version would "align" the systems and ban the use of fly ash completely.

Just want to make sure this ban doesn't slip in thru the back door via the Reference Guide.

May 22, 2012 - 9:01 pm

I hadn't noticed this fine print - thanks for raising the issue. Having done a fair bit of research into the flyash and health question I find it a little odd that USGBC take an inconsistent stand between rating systems. I understand the health logic, but why forbid a product in one rating system but award it in another. With other substances of concern addressed in LEED HC (e.g. heavy metals), it's not as though LEED NC actively gives you points for using them.

May 16, 2012 - 11:40 am

Speaking as a manufacturer and someone who has been involved with LEED since its original version of NC, I commend the USGBC for trying to move things forward, but in my own experience, true life cycle assesments are done by very few manufacturers, partly because almost nothing is built with one single component and so you have to rely on many suppliers to be able to give you information that they may not even have. Materials are what make buildings.....until the majority of manufacturers are able to complete acurate LCA's this version will be very difficult to validate. Even when LCA's are done they are not conclusive and you can read them a variety of ways. There is rarely a definative answer. Very few manufacturers have the means to complete an expensive LCA, especially, in this economy. The elite 1% will win out over smaller start-ups which is what the country needs at the moment. I believe in the idea, but timing is bad and accessment tools for material selection ( LCA's) are not quite as far along as everyone would believe them to be.

May 15, 2012 - 2:15 pm

Anyone planning on taking USGBC up on the offer to be a beta tester? Why or why not? 

Here's the note from USGBC with the call for testers:

  1. Beta testing: Once LEED 2012 has successfully passed ballot, applications will be accepted allowing a limited number of project teams to "test drive" the new rating system prior to the launch at Greenbuild. We're looking for projects across a variety of rating systems and market sectors to engage with USGBC for this beta test. Project teams will be armed with a finalized rating system, documentation requirements and limited reference material in draft form. In addition, you'll have USGBC staff working alongside you every step of the way. Your leadership engagement with this effort will help us fine tune the system and will pave the way for successful use of LEED 2012 in the years to come.

To apply, email LEED2012@usgbc.org with the information below. Interested project teams will be contacted with further details after the successful ballot of LEED 2012.

  • Applicant name and contact information
  • Project team members
  • Owner contact information
  • Project description
  • Desired certification level (platinum, gold, silver or certified)
  • Also, please include why your project is especially suited to this opportunity, and why you want to be part of this effort.

May 31, 2012 - 11:22 am

Cannot under any circumstance even think I would discuss piloting any part of LEED 2012 to any of my 20+ LEED clients. Each time a rating system has opened it has already been a BETA with really harsh consequences for all of my teams - until the system, forms, resources, and LEED Online all actually work (it would be the first time in history) - I will oppose any rollout and so will the several large institutions and private corporations I serve.

May 16, 2012 - 11:20 pm

My understanding is that projects now pursuing LEED 2009 certification are exactly what they're looking for to participate in the Beta test. I doubt that they would charge you participate--I certainly haven't heard anything about a fee. And yes, I believe that if they achieve certification via this beta program that would be no different from any other certification. But I'm just making informed guesses here--you should confirm these answers with USGBC before committing.

May 16, 2012 - 10:09 am

My owners are going to be fearful about signing up for LEED 2012 before someone else cuts them a pathway.

I'm not going to push them because I simply do not have the time to work through the new forms between now and Greenbuild. Plus, I think a few of our engineering consultants would shoot me for suggesting yet another LEED program for them to work in.

May 15, 2012 - 11:21 pm

Could projects that is undergoing LEED 2009 application now join the Beta Test ? Can they be granted with a certificate if they are qualified for certain certification level after the pilot assessment ? Any fees for such a test ?

May 15, 2012 - 1:50 pm

Some folks have expressed concerns that the release of LEED 2012 this november is a foregone conclusion.

It isn't.

No doubt there is a great deal of hope/wishful thinking in the statement 'when LEED 2012 launches in November' released by USGBC's communications department.

If the proposed LEED 2012 standard does not pass membership ballot LEED 2009 will remain the active standard until such time as a new standard can be successfully balloted.

However, you must register today (15th) if your vote is to be counted!
http://www.usgbc.org/DisplayPage.aspx?CMSPageID=2602 is the URL to join the consensus body. Any individual who is belongs to a member company can sign up.

May 31, 2012 - 11:55 am

Thanks Karen. Sometimes, to go forward you have to stop what you're doing.

May 31, 2012 - 11:26 am

Rob - I don't always agree with you regularly, but have to say I'm THRILLED to hear your view on hitting pause and making the darn thing work right before bringing it to market. Your voice is much better respected (and heard) than some of ours, regardless of the success and longevity of our practices, so thank you for stating the obvious - and sticking to your guns.

May 24, 2012 - 6:38 pm

Any prospect that they'll reopen registration for the Consensus, now that they've postponed the balloting?

May 24, 2012 - 1:47 pm

Hi Rus--
See my new thread above. Right now, for technical, market and political reasons, I'm a 'no-with comments' and unlikely to change.

but don't worry you'll get your matrix...

May 24, 2012 - 1:37 pm


Some number of days ago, your post suggested that you were planning to do the killer analytical matrix that would make this all clear. I've been checking every day to see what you came up with. Did you have time? Can you share your conclusions?



May 24, 2012 - 1:33 pm


I sincerely hope that the beta period PRECEDES the ballot, as you suggest. What we will find is that some of what has been posited doesn't work, some of what looks scarey is pretty easy and some of the market transformations will fall into place. Unfortunately, if we have already balloted, we are stuck with the stuff that doesn't work for three years unless we want to undertake single attribute balloting on fixes. That sounds like a nightmare.


May 24, 2012 - 1:15 pm

Yea, as it stands now, v4 IS a bit a 'shakedown' by certain segments of the construction industry, who are trying to shake it down even further. ;o)

May 24, 2012 - 1:06 pm

Forget the vote. Let's just call V4 a beta and make it really clear that the next year is shakedown.

May 24, 2012 - 12:37 pm

Great string of comments.
While I have always considered like Rob that the changes are radical the latest comment period documents for EB do NOT cause me great concern (perhaps I've just been beaten down)...but we've carefully gone through each of the credits and for EB don't believe that V4 is unworkable in the marketplace. Do I absolutely LOVE it...no, but we can live with it and make it work. I've got three buildings sentup into the 'call for pilots' as detailed above..and hope that we get this thing underway.
In answer to the comments in 'MPR's'...we've always had mid version changes that have helped to clarify certain operations of the MPR's...having a mandatory re-cert would get my vote.

May 24, 2012 - 12:58 pm

I heard the same as Tom - hopefully we'll hear more soon. Although USGBC will be required to respond to comments, we still are still not likely to see significant change unless there's enough uproar to cause a 5th draft - but I haven't hear a push for this (yet).

May 24, 2012 - 12:32 pm

A delay might be advisable, as long as it is used to consider some of the issues and member concerns more intelligently and carefully. Forcing it to a vote because of the PR timetable will likely result in compromising the integrity of LEED and our consensus process for decision making.

May 24, 2012 - 8:55 am

I have it on pretty good staff authority that the opening vote date listed on the website is likely to change soon and that there WILL be a reasonable period for USGBC review of comments and adjustment of credit language before the final goes out to ballot. Phew. Of course there is also high pressure to get this to ballot so I'm sure they are going to be looking for how to tweak the language and stay under the "significant" change rule. Stay tuned for a revised notice.

May 22, 2012 - 9:18 pm

Bill and Pat, my (admittedly limited) understanding is that USGBC must have a public comment for any "significant" change to the rating system in advance of ballot as per ANSI (?) rules. Apparently there is no requirement that they listen to the comments. Given that there are still some goofs I certainly hope that minor changes still may be feasible.

May 22, 2012 - 2:49 pm

Per USGBC website:
"The LEED 2012 fourth public comment period is open from May 11 - May 28 (11:59 pm ET). Fourth public comment is an opportunity for stakeholders to review what we consider to be a final version of the rating system that will move forward to ballot. A number of key changes have been made to address the technical and market issues voiced throughout the course of previous comment periods. This version is intended to show the technical requirements up for ballot, short of any clarifications or non-substantive changes that come up during fourth public comment."

May 22, 2012 - 2:46 pm

Response to Bill Swanson's comment above:
That means this isn't a comment period....just an FYI for review before voting ?? So we really cannot affect any more change....just vote YES or NO ??

I agree with comments above that it looks much improved from 3rd comment period info, however there is still huge, substantive change which is expected with a new full version. With the slow-down from the economy & therefore construction starts, we're all still trying to get 2009 interpreted & LOv3 to work. So the concept of a new version, V4 implemented 6 months after Greenbuild is not one which will be easily embraced by the decision-makers, i.e. developers nor easily sold by us, the LEED professionals. I agree it will setup more projects following Best Practices or LEED-certifiable, unless LEED is required by local jurisdiction mandate.

May 22, 2012 - 1:29 pm

Recently attended a seminar on changes and I can assure you adding prerequisites will prohibit participation. The greater the complexity - the greater the cost and the lesser value in using LEED. Most attendees agreed that they would utilize Best Practices and forego the LEED convolution. I'm all for raising the standards - but the goal should be challenging upward from a base rather than being exclusionary.

May 18, 2012 - 11:43 am

This public comment phase ends just a couple days before the voting begins. What you see in this 4th draft is what we are voting on.

May 17, 2012 - 3:51 pm

I'm wondering if there isn't anyway to comment on credits for which there were no changes following the last public comment.

I'm still very concerned about the LEED ND NPD Prereq 3 on Open and Accessible Communities. The 2012 addition requires that no more than 10% of a ND site be in gated communities. This requirement seems to me to be double-dipping with the number of intersections required outside of gated communities (which is a perfectly fair prerequisite requirement). If I can pass the intersections prerequisite for an open and accessible community, then why is there now proposed to be a catch-all and arbitrary 10% cap on top of it? That requirement will disqualify many international projects, especially in cities where significant and real security issues exist, where single family homes, townhomes and rowhouses cannot afford private unit-level manned security.

Many neighborhoods developed under such conditions in fast-growing countries like Brazil, Indonesia, South Africa, etc, in cities with high crime rates, are done with combinations of single family and multi-unit residential buildings. Larger apartment buildings can potentially still pass the minimum intersections test, because multi-unit buildings - which have sufficient scale for manned-building-level security - don't need to be behind a neighborhood or block/cluster-level gate, but single family homes with separate street entrances (such as row-houses and town-houses) don't have that option. Effectively, the 2012 change will bias development toward multi-unit buildings and away from equivalently dense town-house/row-house configurations, in those locations. That cannot be the USGBC's intention.

I am hoping there is still some scope for consideration of this issue between LEED ND 2012 is finalized. Despite previous comments entered on this issue (my understanding), I do not feel that all of the relevant issues have been fully addressed, and, as it is, I believe that enacting 2012 as-is, with this changed prerequisite, will disqualify quite a few otherwise sustainable projects from considering LEED ND.

May 15, 2012 - 2:45 pm

Hi Nadav--
I am still concerned, but somewhat less so than before. I'm going to be doing a matrix of changes and my perception of what they add in terms of green benefit, clarity, cost, complexity and see how things balance out. I agree that that the materials credits are overdue for a change, but I'm pretty sure that 'cold turkey' is not the way to go in terms of a transition. I could see pulling off much of what V4 wants to do in Europe, but here in the US a LOT of people are going to be hanging. Manufacturers (and I think all but the most elite users) will need longer than 6 months to make the adjustment & my guess is that it will be easier to not play than to adjust. Frankly they are STILL trying to get V3/2009 work and V4 (trying to get off the date label) is WAY more complex. Maybe we'll be saved by a bunch of 'killer apps' being developed in the USGBC 'AppLab' that I'm not familiar with, but that's placing a pretty big bet on something USGBC has no control over.

I continue to be concerned that V4 makes a pretty big divergence from BD&C and EBOM, right at the time they should be moving much closer, with EBOM driving BD&C, NOT the other way around. Anyway, more later.

May 15, 2012 - 2:12 pm

Hi Rob,

Are you still concerned that the changes are too great? They have backed out changes with each new draft, so it's not nearly as extreme as it was originally. I agree that the changes will be a lot for teams to take on, but I think that the benefit of retiring some of those old requirements outweighs the downsides.

I think that we've gotten so used to rapidly renewable and recycled content and photochemical VOC content as metrics in LEED that we've forgotten just how bad those things are at measuring the things we really care about. 

And I think that an extended phase-in period is a great move to ease the transition. I like that 6 months is a minimum, but they have left the door open to extending it longer if necessary. It will be interesting to see how the decision gets made about whether or not to extend it.

May 15, 2012 - 2:05 pm

There doesn't seem to be a confirmation screen acknowledging a successful opt-in. There should be a virtual "I registered to vote" sticker, followed next month by an "I voted" pin!

Wait.. okay, I did get a confirmation email, complete with the lovely quote from Scot.