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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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June 5, 2012 - 10:24 pm


Well, it looks like we'll have plenty of time to get this hashed out. I do want to counter a few misunderstandings.

You mention an "obsession with matching the MLO". If such an obsession existed then what you call the "alternative" - which is basically the current method - would have been deleted altogether. I think the consensus was that it would be too radical to convert exclusively to a new method that had not been widely tested with real-world projects, even though that method (BUG) had been developed over a 6-year period with tons of work from lighting and light pollution experts and the endorsement of the IDA and the IES. The current method is still there just for people like you who are more comfortable with it, or prefer a performance rather than a prescriptive method. Because of the two options, the new credit "looks" very complicated, and we received flack for that, but stuck with the two optional methods.

You may not like the BUG method, but it has the huge advantage of not requiring any computer modeling. Some have argued that the current method is flawed because it requires lighting computer modeling and significant lighting expertise to comply with, and this discourages projects from pursuing the credit.

The IES does not "control the credit" - they have zero involvement with credit development and have not been pushing for use of the MLO in LEED. And you are NOT wasting your time commenting. I encourage you to submit constructive and clear comments the next time around. And please participate in “beta testing”.

And you are right-on about the reference guide. It is key, and has been a weak link in the past. The new light pollution credit will fall on its face without a good ref guide.

June 4, 2012 - 10:39 am

I think we are fundamentally not understanding each other.

I still do not like the BUG system and plan to use the alternative. I want the alternative to work, and not used to push people into using the BUG system. It seems the IES is trying to control and unify all definitions of light pollution and ignores dissent. I am trying to improve LEED, not the IES.

A plan can be perfect in design but if it's not functional then it is useless. I have lots of issues with vertical calculation grids on a site. Promises keep getting made to show an example but if the past is an indicator then the Reference Guide will be confusing and vague in how to show compliance. If you can't show compliance to a rule then the rule does not work.

There are lots of problems with how spill light is controlled by this Credit. Yes, it's better than it was (though past efforts to improve that fell on deaf ears.) but that doesn't mean it's good now. If you care about the light on the ground then measure horizontal, not vertical. If you care about glare then measure vertical at the eye, not at the ground.

I was trying to express that an exemption for life safety lighting could be limited to only spill light and that glare and uplight for these fixtures would still be controlled.

The health effects that you reference are for our 24-hour life style. Indoor lighting, not the low levels from a parking lot. And all of the harm to wildlife can be mitigated by full cutoff lighting and a curfew shutoff for rural areas. Nothing relating to measuring 0.4 fc at my toes on the property line.

If the building owner is adding a parking lot and a drive to access that parking lot then I say it is absolutely the responsibility of the building owner to light the new intersection where pedestrians and cars cross.

I'm not trying to shoot the messenger, I'm just trying to be heard. The obsession with matching the MLO means this credit is not open for comment. That the IES controls this credit and we are wasting our time commenting.

I compare sound pollution with light pollution often. You can't draw a simple line and expect sound to stop. Light also doesn't stop so easily. Your example about your backyard and the neighbor's motorcycle is a bit exagerated since we're talking about full cutoff wall packs. It's more like the neighbor's Ford Focus starting up.

June 3, 2012 - 3:53 pm


So, should we just conclude that we should use the BUG method for your exit discharge example? Meets credit requirements and you can use the 2x26-watt fixture? No problems?

Regarding the "need" for darkness, I refer you to the following:



And personally I believe that you should ideally be able to sit in your backyard and enjoy the darkness, and just the light from the moon and stars. It's like noise pollution. I should be able to sit in my backyard and enjoy the quiet and just the sounds of nature. I don't think it is right to assume that if someone is outdoors at night they are going to have the lights on, any more than you would assume that if they are outdoors they will be making so much noise they don't mind the neighbor across the street revving his motorcycle.

I'm not sure if you are saying that light trespass is not a problem, or if you are just questioning how it should be defined and where the "line" should be set where trespass is measured. If the later, then you have hit upon a complex issue. In general, the approach with light pollution control standards has been to use the property line, with the idea of protecting the private property rights of the owner or the neighboring property regardless of their uses of their property. But with, for example, a commercial office building, where no one is sleeping or spending anytime outdoors except going to their cars, you could argue that light trespass causes no problems. Of course to write a standard that takes all kinds of property types and uses into consideration would be very complex. The LZ concept does sort of address this - you can't expect darkness on your apartment roof-deck in the middle of the city, but in the backyard of your farmhouse, you can.

Regarding the issue we have been discussing when you have a public roadway between two private properties, it is certainly debatable where the lighting boundary should be placed. The consensus of the SMEs was that it should be in the middle of the roadway, but I recall there was some discussion of placing it at the property line of the property across the street. Either way, it is certainly an improvement over SS8 in LEED-2009. (also note that the lighting boundary definition is consistent with MLO, IgCC, 189.1 - there is something to be said for consistency)

The 30ft. above highest fixture requirement is based on the idea that you could have a tall building adjacent to the subject property that would be looking down on the site. This comes from the performance method in the MLO. I agree that it is unlikely that you are going to get higher levels on the grid above the highest fixture, but there are probably some scenarios where it could happen. It really isn't any more work to run the grid up higher. Or just use the BUG method.

Regarding your comments on pedestrian/vehicle conflict safety, I believe that in principle the credit should not prevent the lighting of sidewalks and driveways according to IES recommended practices. (Note that the BUG method and the "lighting boundary" are in the MLO which is a document jointly developed by the IES and the IDA, so the assumption is that the IES isn't going to write light pollution control standard that prevents you from meeting their own recommendations.) The tricky area has always been where a private drive intersects a public roadway and there are sidewalks and pedestrian activity. But I contend that It is not the LEED project's responsibility to light the intersection, rather it is the municipalities. It would be great to run some models of this condition for various LZs and sizes/types of roadways, lighting the driveway and roadway and intersection to IES minimum recommend levels and uniformities.

The SMEs and staff worked very hard to IMPROVE the credit - to make compliance much simpler (BUG method) and to fix quirks in the credit that prevented perfectly good designs from meeting the credit requirements - but still have a credit that would control light pollution, and a credit that did not inadvertently allow excessive light pollution. In this conversation I'm just trying to explain the concepts and background behind the credit as best as I understand them. So please don't shoot the messenger.

June 1, 2012 - 9:29 am

How long do you want to keep dancing back and forth? I said the 26W is the smallest standard lamp. The number just above zero is how many full-cutoff wall packs you'll find with (2) 13W lamps as an option.

This 2-26W fixture has a glare rating of G1. I could go all the way up to a 150W MH lamp with forward throw optics and still get a G1 rating which makes this fixture perfectly acceptable per your BUG rating system with the boundary 10' away. So I'm sorry but I'm not seeing the puritan line of limiting spill light.

"Everyone has the right to, and need for, darkness at night." What need? Either no one is using that space at night or they are and they're lighting it themselves. I asked what harm is done? Especially if the neighbor has already chosen to light their site.

And why measure vertical light at the ground? (Who's laying on their belly worrying about light coming off from the property?) Why 30' above the highest fixture? (Doesn't requiring most of the lights to be cutoff already limit this?) I'd rather just a single line drawn at 5' above grade measured at the neighbors' building or building set back line. (Or 15' past property line if there are no neighbors.) Keep the light out of their windows which is a concern.

I see you are a Guest. I don't think you have access to the files on this site for download.

My goal is to keep people safe while doing good design. That includes getting people out of a building safely in the event of an emergency. That also includes trying to reduce the 4,000 deaths and 70,000 injuries to pedestrian by cars each year in the US. Providing adequate light where the two paths cross is important to doing this. And saying it is more important to block light onto another property that is usually also lit does not make sense to me.

May 31, 2012 - 10:44 pm


All I was saying is that if you have 2.38fc VERTICAL at 10ft. from the door, then you probably have WAY more than 1fc HORIZONTAL on the sidewalk, which is generally what you would need for egress code at the discharge. So I don't think you'd need a 2x26watt fixture to meet code. That's all I'm saying. FYI, there are CFL lamps as small as 7-watts, although typically the smallest you might use in a fixture like this would be 13-watts. Or maybe a small LED fixture.

I hunted around for the sample site plan you mentioned but can't find it. Maybe you can post a link. The 100-watt fixture 60ft. from the center of the road on a 20ft. pole seems arbitrary. The exercise should be to light your driveway to minimum IES recommended levels and then either run the calc or look at the BUG rating of the fixture. Then see if you pass, and if not, see if you can by adjusting pole location, height, fixture output, etc.

Spill light in the public roadway IS OK. That is the whole reason that the Lighting Boundary concept was developed and why it can be in the centerline of the road (you get half the road, the guy across the street gets the other half - that's the idea). It's certainly a lot more sensible than the way the credit is now in 2009, right?

Spill light into private property or protected natural areas IS a problem and something the credit controls. Everyone has the right to, and need for, darkness at night.

The issue of code requirements conflicting with credit requirements being contradictory with the USGBC mission statement is something best answered by USGBC staff. Speaking for myself, I'd say that the credit is designed to encourage the minimization of light pollution. If the credit allows excessive light pollution then it is not serving its purpose. The intent was that projects should, in general, be able to simultaneously meet credit requirements and life safety code requirements. But some projects just aren't going to be able to get the credit, and if they don't control light pollution, then they shouldn't. Isn't this the way it should be with all LEED credits?

May 31, 2012 - 10:52 am

Regarding the drive entrance just look at the sample site plan I have available on this site under the SSc8 documentation examples.

A 20' tall, 100W MH, type-III, full cutoff mounted 60' away from the centerline of the road is too much light per this credit. (0.4 fc vertical)

It's a road, it is okay if there is some extra light. I haven't heard an answer yet to the harm caused by spill light if we still control uplight and glare.

I also don't think it matters if this is an optional credit. Any credit being unavailable because a life safety code was followed is the opposite of USGBC's mission statement.

"To transform the way buildings and communities are designed, built and operated, enabling an environmentally and socially responsible, healthy, and prosperous environment that improves the quality of life."

May 31, 2012 - 10:13 am

A (2) lamp, 26W full-cutoff wall pack is in no way excessive.

And per the National Electrical Code (700.16) the failure of any single lamp cannot cause a space to be in complete darkness. So I need two lamps. And these are the smallest standard CFL available.

May 31, 2012 - 10:09 am

Nice analysis, but if I may critique it I'd say this. If the objective is to meet life safety code required minimum light levels to light the exit discharge, which in this case would be the area of the sidewalk in front of what we assume is an exit door with the fixture above it, then I'd say that you have much more light than is needed. So reduce the output of your fixture and you will probably meet the trespass limits. Granted, when the lighting boundary is 10ft. from the face of the building, it is going to be tough. The other way to approach this would be to use the BUG option. No one is saying that light trespass control is more important than life safety. There may be extreme cases where it is impossible to meet life safety code requirements and meet the credit requirements. So in that case life safety trumps and you don't get the point.
The credit is optional, it is not a prerequisite, and LEED is not mandatory code. Or you write a narrative and make the case that you have done everything practically possible to control light pollution and meet life safety code requirements.

Regarding your second comment: Are you saying that if the lighting boundary is the centerline of the public roadway, you can’t properly light the of the driveway? I don’t see that. Can you explain?

May 29, 2012 - 9:38 am

What do I do when a city ordinance requires a 1fc average and a max:min ratio of 15:1 in all parking lots and drives? I still say there is a concern with this Credit not allowing me to properly light the drive entrance.

May 29, 2012 - 9:10 am

Off the top of my head. In LZ2 with a zero lot line an egress door with a full cutoff wall pack, (2) 26W lamps, mounted at 8' above grade.
@ 10' away from building I'm measuring 2.38 fc max vertical.
@ 15' away (with 5' parking lot bonus) 0.89 fc max vertical.
@ 25' away (centerline of road bonus) 0.12 fc max vertical.

All three situations violate the calculated method for light trespass. I'm sure others will manage to find other situations.

This goes back to my question of what's the harm? Why is spill light control more important than life safety?

May 26, 2012 - 1:06 pm


I'm to sure I really understand your questions and comments, but I'll give it a shot.

The thought was that you should be able to meet the lighting requirements of life safety codes, specifically exit discharge lighting, AND meet the requirements of the credit. The lack of the exemption does not prevent meeting life safety code requirements or providing lighting for the "safety and comfort of building occupants".

For previous versions of this credit this exemption may have been needed because on projects with project boundaries at the curb and building exits directly onto the sidewalk it might be impossible to provide code required exit discharge lighting without violating the credit trespass limits. With the new "Lighting Boundary" approach, this is unlikely to be a problem.

May 24, 2012 - 6:25 pm

Hi folks,

Just learned that the ballot has been postponed. Not sure yet what this means in terms of whether or not more changes can be made. Here's the announcement on USGBC.org: http://www.usgbc.org/DisplayPage.aspx?CMSPageID=2360

June 1, 2012 - 3:26 pm

Great points, Melissa, regarding the EPDs and chemicals of concern. My preliminary sense of the raw materials credit, though, is that it can be easily gamed by manufacturers who are a bit less committed (and perhaps less honest) than Interface - you all are true leaders. Can I expect the same commitment from suppliers in Asia? I'm not convinced. Also, the notion that a product can get credit if it's extracted within 100 miles of the site but meets no environmental criteria is a bit bothersome. Most aggregate, for example, would comply... not exactly an industry known for its environmental stewardship.

Peggy, FSC is well supported in the current draft but there are definitely loopholes and other issues that could make FSC a less appealing option.

One big concern with the MR section for BD+C is that most of the credits would initially be perceived as either too hard, too much work or (in some cases) simply not possible to implement and/or document - so projects will just revert to standard practice. This is one reason why the beta and long overlap with 2009 are so important.

June 1, 2012 - 2:57 pm

Peggy - I must differ with your earlier comment regarding MR development resulting in: "Credits that appear to serve industry rather than sustainability."
As a member of industry, I have to say that the new MR section will not be easy for a majority of industry. The credits are making strides toward a more holistic analysis of our building materials, and should be viewed as a stepping stone to future versions of LEED that will be able to evaluate products based on their overall environmental impact.

I feel fortunate that at Interface, we are one of a handful of manufacturers that has a product specific EPD. Meeting the new Material Disclosure and Optimization credit will be a long road for many others as Product Category Rules need to be created and that process takes time on time of the time to complete the EPD. We are fortunate to have in-house LCA expertise and have been tracking internal metrics for 15+ years. Others will have to pay and outsource creation of an LCA and the 3rd party verification required.

We are lucky to have chemists on staff that can navigate the new Material Ingredient Reporting credit and assess our products against Green Screen. Others are likely not to have the expertise. Maximum credit is only offered for 3rd party verified information.

Avoidance of Chemicals of Concern, and the new requirements of meeting REACH, may be brand new to manufacturers that don't export to the EU. 3rd party verification again is required.

Responsible Extraction of Raw Materials - we must get our raw material suppliers for mined and quarried materials to agree to the Framework for Responsible Mining. While they may agree in spirit, there is a 155 page doument describing the Framework. The lawyers are going to go crazy over every line item. Product manufacturers must make publicly available a 3rd party verified corporate sustainability report that includes a long list of commitments and practices. While many manufacturers do publish sustainabilty report, there will be an additional cost for the 3rd party verification.

Overall, the 4th draft of the MR section is a drastic change from LEED 2009's MR credits with simple, single attribute contributions, none of which required 3rd party verification.
We are excited to see USGBC pushing towards greater transparency, as access to the data is required in order to make performance based decisions, and therefore work towards holistic reductions in environmental impacts.
The new credits are going to be incredibly challenging and costly for industry, except for the few of us leaders. Those in the verification industry should staff up for a significant increase in business.

June 1, 2012 - 12:34 pm

Mara - the MR Committee was disbanded, not the MR TAG. Last fall myself and several others met with the staff working on the MR Credits and the chair of the MR TAG at GreenBuild. My question was "who's writing this stuff?" and the reply was that staff was writing the MR Credits with "some input" from the TAG, and then the Credits were reviewed by other staff folks at USGBC. Staff also mentioned that they had met with some folks from the wood industry and they then expressed some sympathy for the non-FSC position.

My concerns are: 1. The exclusion of the general membership from the conversation during development. 2. The lack of experience and expertise of staff, however well intentioned and smart they may be. 3. The cumulative effect of the influence of 2 members of the MR Committee who were on the Board of Green Globes (SFI) and members of the MR Committee simultaneously for YEARS without ever declaring a conflict of interest during discussions of wood issues. 4. One of these Green Globes Board members is also the developer of an LCA database.

So here we are with LEED 2012, with non-FSC wood being backdoored into LEED via the definition of biobased including wood, and the foisting of LCA on us before it is ready for prime time.

June 1, 2012 - 12:33 pm

Mara raises another excellent point. Just reading the outcome without being privy to the hundreds of hours of discussions that led up to it is like reading the last page of a book.

I agree that USGBC could do a better job of communicating the rational behind the outcome but that would be a massive undertaking. For example, on this page the issue of Title 24 equivalency was raised. Amy Boyce from staff very thoroughly explained the rational behind the outcome. Imagine the time it would take to address every issue in LEED so i understand why USGBC has not been written the book just yet!

June 1, 2012 - 12:25 pm

It happened to me yesterday too Karen regarding my second long rant. Unfortunately I had to try and remember what I said and repost.

June 1, 2012 - 12:10 pm

Karen--I've lost posts before. Definitely a PITA but don't think there's anything nefarious.

June 1, 2012 - 12:06 pm

Peggy, I've spent a lot of time discussing MR with staff and the TAG over the last few months. One of the interesting revelations was that the motivations behind some of the major changes weren't at all what I had assumed just by reading the rating system. After learning the logic behind some of the credits they made much more sense (though I didn't always agree) - I don't think staff has done a good job in communicating this publicly, but we should see improvements in coming months. Also the MR TAG wasn't disbanded, it was just less involved than it had been. Their process for credit development was more inclusive but to Marcus's point also more time consuming. At that time they were still trying for a June 1 ballot.

June 1, 2012 - 11:57 am

Karen, there has been absolutely no censorship on this forum. I apologize for what was apparently a technical issue that lost your post. Our IT team is now looking at how to prevent this kind of thing in the future. Again, I'm sorry and I hope you'll repost!

June 1, 2012 - 11:50 am

Karen, I don't know if this is your issue, but a few times my responses don't make it up when I inadvertently try to post something at the same time that someone else does. I've learned to copy/paste my longer responses before hitting submit for this reason. If this is an ongoing problem you should contact the site admin.

June 1, 2012 - 11:47 am

Truly unfortunate that my serious and detailed reply yesterday was not posted - feeling a little censored right about now!

June 1, 2012 - 11:34 am

From Marcus: "Yep MR is very new and I think staff felt the need to take over LEED development in the interest of getting it done faster so they could deliver the necessary support materials (LEED Online, Reference Guides, exams, education, etc.)."

Faster? Methinks there may have been other reasons. Removing the general membership from the development of the new MR Credits and disbanding the MR committee, and then leaving MR development to 'staff' has resulted in something less than desirable, Credits that appear to serve industry rather than sustainability. Curious conundrum we're in now.

June 1, 2012 - 9:25 am

Great point about the points and certification levels. All things being equal that would help even it out.

I have worked on a couple of projects lately that received Platinum certification without even pushing the envelop. Built at or below market rates, no renewables, no beyond code strategies to address rainwater or on-site treatment, nothing particularly innovative about them but all in urban locations. In my opinion neither of them deserved Platinum certification but were able to earn it pretty easily. Just my anecdotal experience.

May 31, 2012 - 10:47 pm

Actually, much of what's in V4 reminds me of what we discussed at Wingspread in 2001. It just shows that the 1 percentile is pretty far ahead of the 20-25th percentile.

Indeed, a simple 'administrative' change would significantly raise the bar without changing a comma in LEED.

This would be going back to the original point distributions for the different certification levels: 50-59% for Certified (or Bronze, as it was known back then in the Bronze age...), 60-69% for Silver, 70-79% for Gold and 80%+ for Platinum, which is still getting way less than 10% of the certifications, which indicates to me that the market is not as far along as everyone would like to think.

May 31, 2012 - 7:57 pm

I'll definitely agree that the EA section feels more refined and in many cases better tested than some of the others.

May 31, 2012 - 7:50 pm

Not sure about rushed (we have been working on v3 since about 2003 or 2004) but certainly untested to a significant degree.

Of course the EA section is perfect! :-)

May 31, 2012 - 7:31 pm

My sense is that at least the MR section has been overly rushed, which would lead to all sorts of unintended market and technical consequences if not vetted more thoroughly.

May 31, 2012 - 7:23 pm

Yep MR is very new and I think staff felt the need to take over LEED development in the interest of getting it done faster so they could deliver the necessary support materials (LEED Online, Reference Guides, exams, education, etc.).

The Market Advisory Committee has been almost completely out of the loop since last fall with the vast majority of our calls cancelled by staff. Taking its place have been some of those special interest market forces you alluded to in your previous post. At least that is what it appears like to me.

May 31, 2012 - 6:34 pm

Marcus, that staff/committee assessment is relatively in line with what I've been hearing/experiencing. The main issue is that we've gotten more or less a whole new MR approach since last fall. Other than construction waste, the credits in the current draft are pretty untested.

May 31, 2012 - 4:18 pm

Rob as it is written - "let he who is without sin cast the first stone". I think this leaves you out brother. :-)

Mara - It has been my experience (as chair of the EA TAG during the first part of 2012 development and as a current member of the Market Advisory Committee during the latter parts) that the volunteer committees were leading the development up until last fall and after that the staff took over.

I do not necessarily disagree with many of the concerns expressed here (beside the obvious compulsion to defend my fellow LEED committee members). LEED development is full of examples of unintended consequences related to untested requirements. The market sends a clear message when that happens and so far LEED has been nimble enough to adjust. I do agree that a reactionary approach is inferior to a precautionary one so testing new requirements is a no brainer. The latest version of 2012 has removed virtually all of these untested requirements from the prerequisites in an effort to lower the entry point for projects while raising the bar on many of the optional credits. The whole point behind the pilot credit library is to test these new requirements before including them in the system. So no need to test drive the full LEED 2012 beta, you can test it in small pieces without risking your client's certification desires. I do understand that this is not the same as testing the whole.

My personal proclivity is to set my goals very high and fall short as opposed to setting them low and exceeding them, as you usually end up in a better place in the long run. To a significant degree the market has caught up with LEED BD+C 2009. Around 50% of BD+C projects obtain LEED Gold certification and the vast majority of credits have not fundamentally changed since 2005. So how far and how fast is enough to sufficiently and continually transform the market? I would suggest that that is impossible to answer (at least not with my feeble brain) with any significant degree of accuracy. LEED 2012 development has been reigned in considerably to date and will likely be reigned in some more before ballot.

Rob I look forward to seeing your analysis, perhaps it can answer my impossible question.

May 31, 2012 - 2:45 pm

I admit I'm not a member of any LEED committees at present, so I can only guess at what goes on, on them. My engagement here is just as somebody who has worked on more than a few LEED certified projects over the years.

What I wanted to note here is that developing and writing standards is difficult work under the best of circumstances. By their nature, standards must be universal, whilst their applications are, by definition, project and situationally specific. Precisely as Rob noted above, the dedicated people who work on creating standards can only represent their own experience with complete effectiveness, experience that is, by definition, project and situationally specific. They are tasked with the difficult task of generalizing the specific, and that task inevitably requires a long, iterative process of review, feedback, testing and adjustment, since nobody can conceivably anticipate every possible project and situation.

I care about greenbuilding, and so I'm greatful that so many dedicated and talented people are working on creating standards for them, whether LEED or otherwise. In the future, I even hope to help.

What is needed here is some type of trial or beta period to get the inevitable kinks out of a good system, while hopefully, in the interim (in, what will hopefully be an extended interim), allowing projects to continue to move forward under 2009.

May 31, 2012 - 2:11 pm

Marcus, your position is very well stated. Having been on and off of LEED committees and serving as an advisor to LEED committees over the years, I agree that everyone is on the same team, so to speak, and that there are relatively few special interests. (The latter does influence LEED in other ways, however.)

The challenge that I have experienced, both from being inside the fold and from the outside looking in, is that the process can feel fragmented, and we don’t always have enough opportunity to step back and take stock of the impact of the cumulative level of change across the entire rating system. The overarching committees, e.g. Market Advisory, are intended for this, but my sense in speaking with members is that they are more reactive than proactive. Also, despite the thousands of person-hours by practitioners, this version of LEED is also more staff-driven than past versions have been. Does this ring true to you too? (My experience is that this has been the case with USGBC committees across the board before vs. after the big change-up in 2007 or 2008 when they disbanded and reformed most/all committees. I’m not complaining – it’s been nice to have more staff support! – but I wonder about unintended consequences.)

I wouldn’t be concerned if we had only a handful of major changes – the individual items (e.g. 90.1 2010) on their own are not a big deal, but the holistic set of changes is a different story. There’s been *tons* of work put into this version of LEED – probably more than any other – but so much is new that it will be hard for both USGBC and the industry to keep pace. I’m excited to dive in and use it, but the glitches in past releases of LEED that Karen points out are unfortunately quite real. There are sectors of the market – possibly very large sectors – that will become very frustrated and drop out completely. My hope is that the beta period will be extensive and effective enough to prevent this. We’ll see.

May 31, 2012 - 10:50 pm

I think Marcus' points are correct. My experience is that the three biggest 'sins' committed by committee members is 1) their belief that their experience is much more representative than it in fact is, 2) a willingness to forgive flaws large and small in the mechanics of the system due to their incontestable devotion to the cause of greening the built environment and 3) not appreciating that the market will turn on a dime and devour anything--including LEED--that is not sufficiently alert to its fickle nature.

There is all of the extremism and bare-knuckle politics Karen rightly abhors, but they occur less at the committee level and more in various state and national political and media forums.

The question "too far, too fast?" is not an academic one. It is a 'you-bet-your-certification-program' proposition. Unfortunately, the market is 'slippery down/sticky up', meaning that once customers jump ship, it will be versions/cycles before they come back, not a matter of months or years.

May 31, 2012 - 1:10 pm

Karen - I have been working on LEED development since 1997 and have been one of those folks working on this like Chris. In my experience your "take" is completely inaccurate relative to reality. The vast majority of those folks are and have been working directly on LEED project delivery including innumerable contractors, architects, engineers and consultants like yourself. Very few represent special interests beyond a strong desire to improve building performance relative to the environment and human health. Very few representing any environmental groups serve on the LEED development committees (actually Rob used to represent any environmental group, NRDC, that some may consider extreme!). Almost no folks promoting particular standards serve on the LEED committees due to an inherent conflict of interest.

In my experience everyone working as a volunteer on LEED development is keenly interested in the long term sustainability of the green building movement. LEED is just a means to perpetual improvement in this field. The issue at hand is how far and how fast to change LEED to continue a steady pace of market transformation. That is obviously subject to debate and is a very difficult balancing act. The market is full of status quo extremists opposed to the pace of change or even any change on particular issues. This is counter to the fundamental reason for being of LEED to transform the market regarding the issues LEED addresses. I can tell you from personal experience that finding the right balance between two extremes is hard work which has been undertaken by thousands of well-informed, practical-minded, and mission dedicated professionals who volunteer their time to enable LEED to deliver market transformation.

Too far, too fast - maybe, maybe not. However, I would personally vouch for the dedication and integrity of the professionals involved in LEED development. In my experience those folks are the reason that LEED has risen to the point where the status quo cares enough to even have these discussions.

May 31, 2012 - 11:15 am

Chris I have to completely disagree - my take on who has been "working" on this is lots of special interests, narrowly focused practitioners, and a whole bunch of environmental extremists, with some industry folks who want "their" standards to be just as important as those referenced in LEED already. Definitely not folks who have to deliver projects either as LEED experts, architects or engineers. And definitely not those realistically interested in the long term sustainability of the LEED systems.

May 30, 2012 - 1:16 pm

Given that several states, cities and the District of Columbia all have mandatory LEED building policies in place, we can't say that LEED is purely voluntary anymore. While LEED was not initially set up to be a de facto code, it has effectively become that in many localities with the USGBC celebrating every adoption.

As for the definition of 'solid experience', I have to reject the notion that it must include 'overseas practice'. I think you can have a lot of great knowledge without ever stepping a professional foot outside of the US. Not every building professional using LEED has the opportunity to work in a different country outside of their country of origin. This does not diminish their capacity to think critically, apply knowledge and push LEED forward. Most professionals with solid experience would be able to grasp that a US standard applied outside of the US will have problems and will require that professional to understand the US standard, the other country's standard and interpolate the difference while working actively with the GBCI to get the job done correctly.

However, I do agree that every job is a sell and opportunity to educate.

May 29, 2012 - 11:32 pm

Well, Barry. There's one lesson I hope we never learn from the market: 'You shouldn't have gone so far so fast'.

May 29, 2012 - 11:13 pm

Rob, not going to argue with your numbers. Certainly any new version of LEED is going to be a numbers game somewhere or other, but in the past we have had good take up with LEED basically because there are plenty of people out there who REALLY want it to work….and that includes you.
LEED has gained traction not just because of what (or in some cases not) the USGBC has done…it’s worked because ‘we all’ have made it work….HOK, Gensler, Lynn Simon, Chris, you, me. (and many, many others) Many of us work abroad where we have had to ‘manipulate LEED to make it work’, and the bottom line has been education.
Leaving aside the fact that USGBC are ‘changing faculty’ and the USGBC educational piece is going to change…in reality the majority of the great education has come from the practitioners in the industry, we have sold it into the marketplace, our companies have put the program on the line and made it work in each building…building by building.
Those fighting to understand outside of the core practitioners have made use of LEED User and their great team to understand the information to help the uptake.
LEED is not a mandatory/must do program as ASHRAE can be in some circumstances…even you said it’s a ‘voluntary standard’…we ALL know that, including the clients…each job is a sell and an opportunity to educate.
Is V4 perfect..no..IT NEVER WILL BE….just as V3 wasn’t…nor the reviewers, nor LEED on Line…nor…well whatever, we can all find fault somewhere, but at some point we have to take V4…and use it. Now would be a really sensible time to do so.

May 29, 2012 - 10:51 pm

My turn to differ...1/2 of 1% of the US market does not "tested" make--I'll even throw in Maryland and make it an even 2%.

In today's LEED, "solid experience" requires overseas practice where a soon-to-be majority of our projects will be originating. Right now, I promise you that only a tiny fraction of them even know that 90.1-2010 even exists. In addition, LEED as a totality should be at least theoretically accessible to the top quartile of the domestic market.

Right now, just to play, let alone get any points, in LEED V4 you're talking the 6-7 point range under 2009, which by itself will eliminate close to 35% of the projects certifying under V3. When you add that to the raft of un-tested water and materials prerequisites and credits, I believe you are talking about eliminating a minimum of another 15-25% of the market that's gone after LEED to date. This is just over 20% of new construction but a low single-digit percentage of the eligible EB stock.

Oh, and have the reviewers been trained on this? Practitioners with solid experience doubtless understand that the certification chain breaks at its weakest link.

Which brings me to my final point: the Massachusetts example is irrelevant: if the 118 cities mentioned have adopted the stretch standard as code, that means that if developers (even them!) want to build in that jurisdiction, they don't have a choice but to comply if they want to build there. Since the "estimates" are that the MA stretch code is equivalent to 2010 (BCAP seems to think not) it would be interested to see how far beyond the code these complying buildings go. As I'm sure we've all learned the hard way, a couple of percent one way or another makes a BIG difference in LEED, particularly with prerequisites.

LEED is a voluntary standard and there's nothing forcing people from not using it if they want to build.

The job of USGBC (including its staff and dedicated volunteer and kibitzing pissant members) is to keep LEED close enough to the market train so that the standard can continue acting as an engine for transformation. Easiest thing to do would be to decouple the engine from the train and make it go faster. And then what would you have?

May 29, 2012 - 10:27 pm

Yes Mara - that is an accurate interpretation of my comment. It's not personal, although unfortunately Chris seems to have taken it that way. It's business. We can, and should do better with v4 before it goes live, or we risk LEEDs reputation and future (IMO).

May 29, 2012 - 10:00 pm

Chris, if some of the other credits were as thoroughly tested as that one, I would totally agree with you, and I suspect others would too.

Also, if I'm reading Peggy's original post correctly, I don't think she's saying that there weren't solid practitioners involved over the last three years, but rather that she'd like to see that involvement continue and possibly grow as 2012 comes to market.

May 29, 2012 - 9:24 pm

I beg to differ. Here in Massachusetts, 118 cities and towns including Boston and Cambridge have adopted the Massachusetts Stretch Energy Code. The Stretch Code requires large projects to be 20% better than ASHRAE 90,1-2007. According to estimates, ASHRAE 90.1-2010 is about 19% better than 90.1-2007. So in Massachusetts we have several years worth of field experience with these types of requirements. And guess what? - even the developers can meet this code. The sky isn't falling. In fact, we're having a building boom - cranes are all over the downtown skyline.

Disagree with the requirements if you like. Make you comments heard. But to say that the problem with LEED 2012 is that we haven't involved "green building practitioners with some solid experience" is absurd.

May 29, 2012 - 6:13 pm

And the cumulative field experience with mandatory features such as ASHRAE 90.1-2010 is exactly zero.

May 29, 2012 - 4:51 pm

"serious technical expertise and green building practitioners with some solid experience" have been working on this for the last 3+ years.

May 29, 2012 - 12:39 pm

Hopefully they will bring in some serious technical expertise and green building practitioners with some solid experience to pull this v4 LEED package together to refine and coordinate the Credits. We all want it to be successful, and we all want the market to be nudged forward as much as possible. Fingers crossed!

May 24, 2012 - 2:15 pm

Here's my take on what the credits are doing and some reactions from the HBN POV:
The USGBC is taking very significant important steps forward with the Chemicals of Concern credits in LEED 2012. We laud them and urge support for this effort while noting some significant fixes still to be made to insure effectiveness.

The Material Ingredient Reporting credit requires disclosure of content or health hazard at minimum for any content meeting the criteria of the Green Screen Benchmark One, including residuals to 100ppm. One point is provided for meeting this requirement for 20% of interior materials.

While we would prefer a simple full disclosure requirement, this requirement to encourage disclosure of highest concern Benchmark One contents is significant and we think will support the movement toward even more complete disclosure of the complete range of significant hazards. We share concerns raise by others that

The Avoidance of Chemicals of Concern credit takes a modest forward on actual avoidance and a potentially larger step forward on the gathering of chemical safety information. This credit has been reworked in this version to parallel chemical legislation that is already in force in Europe, rewarding avoidance of chemicals on the REACH Substances of Very High Concern list and REACH or equivalent registration for all ingredients. The credit is optional and gives projects one point for demonstrating compliance with both the SVHC avoidance and reporting requirements for 20% of all products in the building and a second point if they can reach 30%.

The SVHC avoidance requirement is more modest than we would like as it only includes 14 substances, just a few of which regularly appear in building materials. Those few are, however, a set of phthalates and flame retardants which have been part of the credits initiated in health care and are a good first step forward.

The registration requirement is quite interesting, requiring that companies demonstrate that all ingredients have either had chemical safety reports submitted into the European REACH process or an equivalent third party system outside of Europe. Stimulating registration and reporting on chemical safety is an important step forward and can act to reinforce and amplify the data gathering that is happening in Europe under REACH here, align with and build on OSHA’s effort to institute Globally Harmonized System (GHS) for Safety Data Sheets (SDS) reporting in the US over the next few years and accelerate the industry’s ability to more fully report as required by the Health Product Declaration (HPD).

The credit has some significant bugs still to work out to be effective – most notably that exempt products may be able to fulfill the 20 & 30% requirements without stimulating any additional registration or avoidance, providing a path to essentially bypass the intent of the credit. Additionally, getting the mechanisms in place for third party REACH equivalence and engaging enough of the supply chain in the US could take some time and leave many manufacturers with no pathway to participate for many years.

We support what the USGBC is attempting to do with this credit and encourage them to continue to move forward in this direction. Many of the concerns will only be able to be sorted out through implementation in credits. That said we strongly encourage the USGBC to implement some critical fixes to make this credit work
- Require certain product categories with known health hazards to be included within the minimum 20%, OR eliminate certain typically benign product categories from being included in the 20%. The USGBC should also be prepared to ratchet the threshold up as the level of usage of inherently benign materials is identified to insure this is a leadership standard.
- Provide an alternative avoidance only pathway – such as avoidance of the SVHC Candidate list to facilitate immediate implementation of the credit while the larger registration system is being developed .

May 26, 2012 - 10:03 am

Here's my take on the avoidance credit as I submitted:
The concept of avoidance of chemicals of concern in building materials is very important and we strongly support the retention of this credit while noting some serious concerns with specific language in this version. The current V4 language based solely on REACH regulatory language does not meet the intent of the USGBC to avoid the substances that the REACH process has identified as of highest concern. In the previous public comment version, LEED correctly identified the REACH Substances of Very High Concern (SVHC) Candidate List as the operative REACH list. Referring simply to REACH regulation adds a later of European interpretation of which of those chemicals is covered by other European regulations and European sunset dates that are not relevant to projects in the US and elsewhere. In fact you will find that leadership European manufacturers are avoiding the entire Candidate list. Leadership companies are also well along the path of avoiding the other chemicals identified in previous LEED drafts derived from the work of LEED for Healthcare. The net result of the credit as currently written will not be any actual avoidance as only a very small number of chemicals are avoided which are not relevant to far more than the 20-30% required. Furthermore, benign materials that are exempted from REACH will likely provide a pathway for projects to avoid even the registration part of the credit requirements.

- Restore earlier LEED language requiring avoidance of the entire REACH SVHC Candidate List for attainment of this credit.
- Restore earlier LEED language for chemicals to avoid based upon LEED Healthcare credit development.
- Require certain product categories with known health hazards to be included within the minimum 20%, OR eliminate certain typically benign product categories from being included in

May 24, 2012 - 1:44 pm

I'd like to start a bit of a straw polling process here predicated on the idea that delaying the ballot significantly (6 months or more) is in the best interests of USGBC, LEED and the environment. To do this, could folks who agree hit 'thumbs up' & feel free to comment. If folks disagree, a simple reply with "Disagree" would server the straw poll purposes. Any substantive reasons pro and con would be welcome. If we can show some DATA that V4 is a non-starter at the present time, then we have a good chance of avoiding the likely donnybrook that I see emerging from the fogs of the future.

Although the LEED2012 (henceforth V4) process has been going on for quite awhile, If you look at each of the drafts, it is clear that we really haven't been discussing the same document: each one is hugely different from the other, as well as very different from LEED 2009.

Tom Lent has suggested that we call the 4th draft a beta, which is a similar concept, but the most important thing here is to delay the ballot, which would hem USGBC--and us--into something that we all could regret down the line. I will be trying to get my matrix together, but it's a big lift...thanks for folks' patience.

June 4, 2012 - 5:12 pm

Yea Scott I could see some of the data skewing due to familiarity coupled with motivation. The last time we were in balance with the market was 2005. That year Certified 37.3%, Silver 33.8%, Gold 25.4% as one would expect. In 2007 Silver passed certified and in 2009 gold passed silver. Evening up the point scale so gold does not have the bigger band-width would help too.

Outside data I see undeserving Gold and Platinum projects earning those levels everyday.