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
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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