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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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October 15, 2012 - 4:49 pm

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!


October 15, 2012 - 3:49 pm

Hi Tristan,

Above you mention "The credit for electric vehicle charging stations and preferred parking has been reinstated in this draft, with minor adjustments".

Can you provide more information on that topic or point me to where I can learn more?


October 15, 2012 - 4:53 pm

Rudy, what in particular are you looking for more information on?

There is now a newer draft of LEED v4 (for the 5th public comment period) that would be your best source of information on where LEED is going on this topic—see the link I posted above.

June 11, 2012 - 5:08 pm

All of the links that I can find to the most current draft of O+M (and NC, as well) dead-end at Rick's letter or lead me to the 2nd public comment draft. Can someone please provide a link to the latest draft of O+M and NC?

Thank you in advance.

June 20, 2012 - 3:55 pm

Thank you Bill and Hernando.

June 12, 2012 - 11:08 am

Other Versions & Redlines:

BD+C (4th Draft) Redline Version

EBOM (4th Draft) Redline Version

ID&C (4th Draft)

ID&C (4th Draft) Redline Version

BD&C (4th Draft) Substantive Changes

EBOM (4th Draft) Substantive Changes

ID&C (4th Draft) Substantive Changes

June 12, 2012 - 9:28 am

BD+C (4th Draft)

O+M (4th Draft)

June 11, 2012 - 5:11 pm

Hello -

We're in the process of updating the titles to the documents to reflect the name change of the program. The docs will be back up in the next couple days.


June 4, 2012 - 7:11 pm

From Rick:

"In response to overwhelming feedback from our members, core LEED users and engaged stakeholders, USGBC announced today that it will delay ballot on LEED 2012 until June 1, 2013. Because of this date change LEED 2012 is being renamed LEED v4."



2009 stays open for 3 more years
v4 beta will be open through June 1, 2013 (yes, 2013)
v4 vote will be on June 1, 2013 (yes, 2013)
There will be another public comment spanning GreenBuild (October 2 – December 10)

June 4, 2012 - 7:11 pm

Thanks for posting, Mara!

LEEDuser just posted an article on this change, with a bit more background and context.

June 1, 2012 - 12:36 pm

LEED Users, what are your thoughts and experiences with LEED Documentation?
I've seen a couple of posts from Karen Joslin about LEED 2012 likely not being "ready" for the marketplace based on experience with 2009 forms and reviews. LEED User has been great in the tips & resources available and the forum discussions. Yet it reveals much confusion, even among "elite users" about satisfying requirements and responding to reviewers.
What confidence can we have for new versions in terms of ease of use and ability for the building industry to continue transformation? (In our state the IGCC is no where near being adopted.)

June 1, 2012 - 2:55 pm

I would never suggest dumping GBCI! I am suggesting that we come up with better ideas on how to do reviews and pilot several options to see what works best. We need to maintain the integrity of the system so it needs to be somewhat rigorous but in a more streamlined, effective and positive manner.

Barry your idea is just what I am talking about, lets pilot a process where teams which have submitted successful, accurate documentation on multiple projects can utilize a more streamlined approach.

June 1, 2012 - 2:31 pm

Marcus...are you suggesting 'dump GBCI' and take the BREEAM route? It bares discussion. Certainly I see no reason for the top teams not to be able to ‘self certify’ Certified and maybe Silver projects…with GBCI stepping in and doing reviews on an ad hoc basis. (al la BREEAM). But Gold and Platinum should take the GBCI route. This self certifying route would take a lot of pressure off of GBCI. Another option could be to reassess the points level and reduce Certified to 35 points or maybe 30 points…this would help to bring in more buildings.

June 1, 2012 - 2:20 pm

Marcus, well put. I think a place to begin is with the MPRs. LEED boundaries have been a sticking point in all our LEED projects. A "simple site" it the exception to the rule in our office. Early interaction (and cost friendly) to work out a logical boundary with your reviewer on which to base future calculations (or decide to part ways with LEED) would be a great step. I do not think this should be a pay-per one-way communication void of graphics that are CIRs.
Suggestions for others?

June 1, 2012 - 2:00 pm

Marcus...are you suggesting 'dump GBCI' and take the BREEAM route?

June 1, 2012 - 1:54 pm

To address the original issue - the documentation and review process I think is the Achilles heel of LEED. It is currently pretty much a punitive process that is viewed negatively by customers as something to endure to get your reward. We need to change the process to make it a mostly positive and value-added experience.

We need to consider and test alternative certification review methods including a greater degree of reviewer-customer interaction including possible site visits. I recently went through a Green Globes certification (the project failed to meet a LEED prerequisite and the client was expecting monies tied to LEED or GG certification) which was far more positive in nature.

So I think the specific tools and requirements are actually the least of our worries. It is the fundamental process which needs to change IMO.

June 1, 2012 - 1:15 pm

Peggy...I'm shocked...Rick didn't rant did he?...OK, OK...so it was a little pointed and at a major public event.
But remembering Rick's comment about being the highest LEED ever got me thinking that the Platinum bar needs to be a lot harder to achieve

June 1, 2012 - 1:11 pm


A followup from Rick's plaque cermony at Integral last week and NCC's GreenSuper hero's (you missed a great evening)...Integral got the highest LEED CI certification on the Planet (or so Rick says)...now that's great...we loved being part of that...but if we continue to push the bar in point numbers higher and higher...what does that prove? The parrallel to that is Energy Star...once the score reaches 98...what does 99 prove?
Others have mentioned that with point reduction in credits that 'high scores' are not achievable...if that is correct then Platinum in V4 would REALLY mean something

June 1, 2012 - 1:11 pm

Yea Barry - do tell! :o) Was it anything like his entertaining rant at the NCC Gala last week?

June 1, 2012 - 1:03 pm

Which letter is this, Barry?

May 31, 2012 - 3:09 pm

I do not fully agree with Nadav’s analysis above that Envelope Cx was moved to the credit. There are still some serious issues with the v2012 commissioning that I have commented on at every opportunity, including this one.

First, they are requiring that the envelope be included in the OPR and BOD, which I agree with. Kind of like reporting chemicals as a start, making sure that design teams fully outline and narrate the envelope is great. However, it continues to require a “design review” of the envelope to be included in the fundamental commissioning, but it can be by the design team. I just do not agree that the “design review” should be part of fundamental commissioning…that should always be third party, and it should be part of enhanced.

So I continue to assert that the design review should be part of enhanced for all systems, not part of fundamental. Also, the design review as currently mentioned in the standard is not well defined, of course it was not well defined in v2009 either, and means different things to different people. You only have to look to LinkedIn conversations on the topic to know that. This is where a well written Reference Guide will be helpful.

Lastly, there is a weird typo (hopefully) that could be read that the CxA should develop the OPR and BOD…and that is just plain wrong.

June 1, 2012 - 10:11 am

I understand your having to compete with low scope, low cost providers. We just choose not to and are small enough to have that luxury. So that being the case if the design review comes into the prerequisite than the scope remains the same for all providers, somewhat evening the playing field.

The issue with endorsement is a lack of documentation required in the submission. Generally not much to look at or comment on.

There is a separate working group on Cx issues full of CxAs under the EA TAG who primarily worked on the 2012 credit language.

June 1, 2012 - 9:51 am

I agree that it must be a typo Marcus, there are so many edits, I know your suggestion is the intent.

I also agree that a design review is valuable…but we have to compete with very low scope, low cost providers. And I have seen little enforcement from GBCI on Cx (although I just read in another part of LEEDuser someone being denied the Enhanced credit due to an inadequate Systems Manual). So we also work to provide high value to our clients.

There are other places to debate scope and definition of commissioning, and if you look on LinkedIn and other places on LEEDuser you will find that I am not just a whiner on this topic. A well written Reference Guide would help our clients and the market to stabilize on the level of service deserved. For a long time I have advocated for a separate Cx TAG, as EA is so focused on energy efficiency and simulation (as it should) that I do not feel Cx is getting the attention it should. I would love to volunteer for that TAG, as I have been turned down for the EA TAG several times now (ok, now I am whining).

May 31, 2012 - 8:04 pm

As you well know there are many different approaches to commissioning. The folks who do this in our shop will not commission a project without doing a design review. So within the current requirements we do not separate the credit requirements from the prerequisite requirements. We will do it the way we think is right or we just won't do it.

Where does the prerequisite language say that the CxA should develop the OPR and BOD? The language indicates that the OPR and BOD must be developed but the CxA scope of work includes review of the OPR and BOD, not development.

Perhaps it would be clearer if it said:

The owner and project design team must do the following:
- Develop the OPR
- Develop a BOD

Fun writing credit language isn't it? :-)

May 28, 2012 - 2:47 pm

It is my understanding that the proposed version of LEED 2012 does not include an "equivalency" between ASHRAE 90.1-2010 and California's Title 24-2008 energy code.

Accordingly, I just posted the following comment.


Simply put, to discontinue the long precedent and tradition of allowing projects in California to use Title 24 - and instead, force these projects to demonstrate compliance with two different energy codes, will most likely:
a) increase costs for projects in California, which will...
b) discourage projects from using LEED 2012, which will...
c) result in fewer projects using LEED in the future...and thereby reduce the probability of the USGBC Vision from being achieved.

Accordingly, we implore you to reconsider this choice.

If not, we respectfully request that GBCI demonstrate complete transparency in this decision-making process, as follows.

1. Please provide access to all the specific backup documentation that GBCI relied on to substantiate the statement that "Title 24-2008 is generally not as stringent as ASHRAE 90.1-2010".

2. Please provide access to all the specific backup documentation that USGBC/GBCI relied on to substantiate the conclusion that the difference between 90.1-10 and T24-08 is *substantially greater* than the differences between *prior versions* of these respective energy codes, specifically 90.1-04 compared to T24-01, and 90.1-07 compared to T24-05 (which were all previously deemed substantially equivalent, of course).

3. Please provide the proposed timeline for evaluating the Title 24-2013 energy code for equivalency with ASHRAE 90.1-2010, and clarify what month and year this determination is expected to be complete.

Thank you in advance for your consideration of this feedback, and we look forward to your response.


If you agree that forcing California projects to be modeled using two different energy codes is redundant, does not follow previous LEED precedents, and most likely will result in fewer LEED projects, then I encourage you to submit a comment stating your concerns.

Thank you for reading,

June 11, 2012 - 6:01 pm

Well, the reason Title 24 2008 was not given a percentage bump compared to ASHRAE 90.1-2004 was the the EA Technical Advisory Group deemed it was too hard to determine a percentage for the bump. The two codes would be equal with no zero bump.

In LEED v2 the USGBC provided an average bump for all Title 24 projects, regardless of type of project. Yes, some types of building would get a percentage bump they did not deserve, and others not enough of a bump.

For LEED v3 (was 2009?) it appears, from meeting minute notes that used to be provided to EA TAG corresponding members, that the EA TAG did not want to use a single percentage for all Title 24 2008 projects. A breakdown by building type seems to have been the desire, and it was deemed too hard to do.

For my LEED v3 projects the energy analyst do a both 2008 and 2005 analysis. Not the intent of saving analysis effort, but that is the best way to efficiently document a California Title 24 project and not leave points on the table.

On one of my projects, nearly 15% more on-site renewables would have been required if the model was not run under the prior code. The added cost was significant to the owner.

May 31, 2012 - 3:35 pm

Great summary Amy! It is very hard for those who just see the result to understand the discussions and research that goes into these decisions. It is wonderful when USGBC shares the rational behind the decision.

May 29, 2012 - 2:17 pm

Hello all -
I am the LEED subject matter expert for EA at USGBC, and I just wanted to clarify some of the discussion regarding Title-24 equivalency.

USGBC's information regarding stringency has always been provided by third party studies, such as those commissioned by the DOE. The USGBC does not itself conduct analysis of energy codes to determine relative stringency. The latest comparison provided on the DOE website between T24-2008 and 90.1-2007, indicated that T24 was more stringent that 90.1-2007, but no percentages for relative stringency were provided. (http://www.energycodes.gov/states/state_info.php?stateAB=CA).

DOE has determined that the quantitative analysis of the energy consumption of buildings built to Standard 90.1-2010, as compared with buildings built to Standards 90.1-2007, indicates national source energy savings of approximately 18.2%. (http://www.energycodes.gov/status/documents/Standard_901-2010_Final_Dete...). There have been no studies to suggest that the energy consumption of buildings built to California Title-24 2008, as compared with buildings built to Standard 90.1-2007, indicate average source energy savings up to that level.

Per the DOE website, each state is expected to submit certification that demonstrates that the provisions of the State's commercial building energy code regarding energy efficiency meet or exceed Standard 90.1–2010 and be filed by October 18, 2013 (http://www.energycodes.gov/status/determinations_com.stm). Once the state of California submits this study to the DOE and it is approved, it is probable that an alternative compliance path will be approved that will allow Title-24 2013 to be used in lieu of ASHRAE 90.1-2010 Appendix G to document compliance with EA prerequisite: Minimum Energy Performance and EA credit: Optimize Energy Performance.

The current software developers who offer Title-24 2008 compliance (and the software developers who are preparing software to offer Title-24 2013 compliance) have offered modules that include some ASHRAE 90.1-2007 Baseline modeling functionality. It is expected that the software developers will also update their software to include the capability to model ASHRAE 90.1-2010 Baseline modeling functionality. Therefore, during the interim period before Title-24 2013 takes effect (currently scheduled for January 2014), it is probable that there will be software available that will allow dual compliance to be documented with California Title-24 2008 and ASHRAE 90.1-2010.

I hope that clears things up a bit. It is not USGBC's intention to make compliance with the Energy prerequisite/credit overly difficult, but we also want to make sure that buildings are demonstrating comparable performance. Please feel free to follow up if there are more questions!

May 29, 2012 - 2:16 pm

Hi, Mara - Yes, in earlier versions of LEED, there was an equivalency letter or notice that was written after the fact. Usually, long after the fact, and hard to find for many teams. You will notice that in LEED 2009, it is written right in to the language for EA-p2 and EA-c1 at the conclusion of OPTION 1. "Projects in California may use Title 24-2005, Part 6 in place of ANSI/ASHRAE/IESNA Standard 90.1-2007 for Option 1."
hi, Peggy - FYI- Even when CA projects use the Title 24 energu use baseline, it must still be mapped into LEED project energy costs. This has always been true and is not the issue here.

May 29, 2012 - 12:57 pm

Peggy, the first comment above suggests that T-24 would not be permitted at all, and that separate ASHRAE 90.1 modeling would need to be done. I doubt that will be the case with 2013 but the language (usually a reference guide supplement thing) isn't in place yet. Prior versions of T-24 and 90.1 weren't closely equivalent enough to be treated the same for LEED.

May 29, 2012 - 12:59 pm

Hi Mara, and thanks for your response! And yes, I neglected to state that USGBC's response to several LEED 2012 comments related to the desired ASHRAE / Title 24 equivalency was, "Title 24-2008 is generally not as stringent as ASHRAE90.1-2010. When T24-2013 is released, equivalency will be evaluated." So, it appears they have made up their mind regarding the current version of T24, and will consider T24-2013 some time in the future.

May 29, 2012 - 12:53 pm

I understand that. Since we are required by Code to comply with T-24 and it is equal to or exceeds LEED, it seems redundant and complicated to me that we would continue to have to then translate T-24 results into LEED. (...so NOT an engineer, but I am a logical thinker!).

May 29, 2012 - 12:42 pm

No, this is the path that most CA projects use to achieve EAc1. It's fundamental to our ability to efficiently (in terms of time and money) pursue LEED.

May 29, 2012 - 12:32 pm

This is the type of issue/strategy that would best be covered by a Regional Credit, yes?

May 29, 2012 - 11:55 am

Drew, if I remember correctly the Title 24 equivalency values came shortly after the release of prior versions of LEED, not in advance of them... I have fond memories of the printed out equivalency chart taped into my Reference Guide. Unless you see language that explicitly forbids an equivalency (have I missed that?) I would hope that USGBC would do this as soon as possible, but given the extent of their work on this new system I'm not surprised that it isn't complete yet.

May 25, 2012 - 9:11 am

In this draft SSc8 has removed the exemption...
"lighting that is specifically designated as required by a health or life safety statute, ordinance, or regulation."

I understand this was a loop hole for designers to drive trucks thru but I'm curious how lighting required by a health or life safety statute, ordinance, or regulation can be outside of the scope of LEED's goals and principals.

LEED has gone thru great efforts to add prerequisits and credits for the safety and comfort of building occupants. Why does none of that matter in regards to this credit? Why would a project be excluded from any credit for doing something that is for a person's safety?

If the main problem with safe lighting is the spill light onto a public street or neighbor's parking lot, then I would say so what. Can anyone explain to me the harm this spill light would cause? We can still limit uplight, and glare, but I don't see any reason why this spill light is a concern.

June 13, 2012 - 11:54 am

The TAGs and SMEs don't invent things like vertical grid calculations. Those get invented either as part of the Reference Guides or the Certification Review process.

The inventor appears to be the USGBC's LEED Department, and the outside consultants they hire to assist with rules development.

At some point in time, one of the rules writers decided to change the requirements and the LEED Department rubber stamped it. The reason for a change like this is, "oops, we forgot something." In this case that something was to limit light pollution to the exceptions were allowed.

Uplighting is controlled by the requirements. Check!

Boundary footcandles are controlled by the requirements. Check!

The a discussion between rules inventors occurs, something to the effect:

"Opps, what about the boundary envelop?"

"The What?"

"The boundary envelop implied by the credit."

"There is nothing about a boundary envelop in the credit."

"It is implied. We must control all light in the envelope. What if someone points a laser light above the ground level and below horizontal? They would be cheating the credit."

"Okay, I see. Yes, lets add it. The envelop restriction is implied. We do not need TAG, Steering Committee or Membership approval."

"Okay, a vertical calculation grid is now required, and should have been required since LEED v2. Now we can enforce on all projects. Those that have ignored the new requirement can slide. Everyone else must immediately be held responsible for the new requirement that has always been there."

June 12, 2012 - 10:15 pm

What you describe sounds very impressive, and very confusing. How do the people doing that work interpret it? The article written by Glenn said they accept "improvements" and reject everything else. What's an improvement?

If my suggestion increases light pollution, that's not an "improvement" so it can be rejected and the group can move onto the next item? This would limit comments to error checking essentially.

USGBC has a list of requirements that credits have to be, one of them is that it must be "documentable". I keep saying that vertical calc grids are not documentable and should go back to being a single line at the boundary. A single line is less coverage, and allows more light pollution so this is not an "improvement" so it gets rejected.

I am trying to find out what the TAGs or SMEs or who ever, what do they think their instructions are?

June 12, 2012 - 5:22 pm

Subject Matter Expert (SME). Technical Advisory Group (TAG). Core-Committee Members. Take your pick. The final control over the LEED development is none of these.

What many people do not realize about LEED is that once a requirement is "invented" it is nearly impossible to remove it. Regardless of whether the requirement is an error in interpretation.

Any uplight is bad. Surface reflected light you can have all you want.

Flag lighting was not the specific issue as it was ZERO uplighting being determined as the hard requirement for SSc8 in LEED v2.0. Ever since then, the uplighting restriction has been hardcast in LEED. Flags, everygreen trees, facades, anything.

Flag lighting has been a sore point since it was "invented" by the Reference Guide authors. It was not developed by the person responsible for the development of SSc8 for LEED v2.1, David Nelson (SME). For LEED v2.0 there were mo SME's. There was a single firm that read standards and made up the rules.

Although, flag lighting was deemed okay, it was deleted by the the v2.1 Reference Guide authors as contradicting what they originally developed. If the requirement was there in 2.0 then it must remain for v2.1, etc. Ten years later and still, flag lighting is a sore point.

June 12, 2012 - 5:06 pm

Hi Bill -

I can answer your question - I assist in the management of the overall LEED v4 program , with particular focus on ensuring consistent development through the consensus process, which involves our volunteer committees, public comment, consensus body and ballot.

Our development process is simple and completely overwhelming at the same time. We open our substantive changes up for public comment, consolidate that feedback based on credits and expertise areas, and provide it to our technical experts (internal to staff and external volunteers) to review. These small groups (sometimes loosely referred to as SMEs) discuss in the context of a number of issues [technical feasibility, market acceptance, organizational mission, international applicability, relation to our LEED Impact Categories, cost & time to implement, simplicity for the user, appropriate for inclusion in rating system vs. ref guide, credit achievement, and so on], and provide responses, making a change to the rating system language only if appropriate. Multiply this by the over 20,000 comments received over the course of the past four comment periods, and you've got more than enough work to go around. :)

All of our proposed changes - which are provided to our users for a subsequent public comment period - as well as the responses to all of our public comments are approved by our LEED Steering Committee. The Steering Committee is an integrated group of staff and volunteers who ensures the integrity of the LEED system and - in the case of rating system development - ensures that the changes proposed over time are consistent with the direction provided to each group in terms of objectives and priorities for the v4 update to LEED.

June 12, 2012 - 4:45 pm

I have the feeling that the USGBC and you are under different opinions on what the development process is. Can you explain the instructions given by USGBC for responding to Public Comments?

June 8, 2012 - 10:31 am

When I see a response to a Public Comment that says this it seems otherwise.

"Thanks, Lee. The changes have been made per SME discussions."

June 8, 2012 - 9:35 am


In my experience, SME's do not have the kind of authority or unified opinion that you attribute to them. Although influential on the content (isn't that the idea?) we are not "in charge of developing this credit". I appreciate your frustration with the development process, but it’s the USGBC that defines and controls the process, not me. Please address your concerns with the development process to the USGBC, not me.

June 7, 2012 - 9:53 pm

Glenn, I have been responding the the comment above me. The last one was to USGBC, the one before was to you. You were appointed as a Subject Matter Expert (SME) and in charge of developing this credit. The two paragraphs I quoted were from an article you wrote two years ago. It seems the only role the public has during public comments is to error check the draft. The sole source for content ideas comes from the SME group.

June 7, 2012 - 9:28 pm


I'm assuming that your last two comments were directed to USGBC staff, not me. I don't work for the USGBC.

June 7, 2012 - 4:12 pm

1. Thank you for allowing National flag lighting. Why was something so simple like pulling teeth?

2. You updated from a draft MLO to the final MLO and changed a sub-note to reference a newer standard. I doubt that wouldn't have happen without me.

3. The first draft had grid heights called out. I don't know what you are refering to.

4. This hasn't changed. It still says cd/m2.

June 7, 2012 - 3:42 pm

Hi Bill,
We actually have modified the Light Pollution Reduction credit in response to your comments (submitted through both the USGBC Public Comment process and LEED User). Specifically:
1. We did not have an exemption for National Flag lighting, but in response to your comment, we included this exemption starting in the 3rd Public Comment draft; 2. We revised the BUG tables to fix errors, per your suggestions; 3. We provided a height for the boundary calculation grid, as you suggested in the 1st public comment period; and 4. We clarified signage requirement compliance (how luminance data is to be provided for conventional backlit signs) based on the issue you raised in September of last year.

We take the public comments very seriously, and we do respect and value the expertise of our stakeholders. We have not simply rejected comments because they don't help our "opinion." Rather, we have had multiple long discussions as a group over the last year+ about the comments and considered all of them when writing the credit. And as you can see above, we have revised the credit based on your input.
Thank you!

June 7, 2012 - 11:21 am

You can marginalize me as much as you'd like but I will keep squeaking. You had your mind made up what this credit was going to be 2 years ago and seem to feel entitled to reject comments that don't help your opinion.

"The LEED-2012 Public Review Draft is expected to be published for public comment in September, and USGBC responses to these comments will be published thereafter. If the USGBC follows its previous procedure, comments that are deemed to be an improvement will be incorporated into a new draft and other comments rejected, but without any formal dialog with commenters. The final draft of the new version of the rating systems will be voted on by USGBC member organizations, with a target release date of January 2012.

"The public review draft of LEED-2012 will provide an indication of what the next version will look like. The credit that addresses light pollution control will be significantly revised to resolve some of the quirks that can prevent very sensitive designs from meeting the requirements. It also will likely adopt the BUG (backlight, uplight, and glare) system developed for the International Dark-Sky Association (IDA) and Illuminating Engineering Society (IES) Model Lighting Ordinance (MLO)."

June 6, 2012 - 10:04 pm


You seem to be seeing a conspiracy where there wasn't one. And even if there was, what you say doesn't make sense to me. IES is also one of the developing organizations of ANSI/ASHRAE/USGBC/IES Standard 189.1.

June 6, 2012 - 10:35 am

During development of LEED-ND I suggested matching the current draft of ASHRAE 189. This was rejected because it was only a DRAFT. Another person suggested adopting the current DRAFT of the MLO. This was completely adopted. And ASHRAE 189 was later revised to match the MLO. What would that look like other than IES control?

My first post in this thread is as constructive and clear as I can be. The minimum lighting needed to meet life safety Codes should not exclude compliance with this Credit. What I hear in response is that your need not to "hear the neighbor's car" is more important to earning this Credit. It just seems to discourage this Credit in urban locations where we're all very close to each other.

If this still won't be considered then can we raise the height of the calc grid to start at eye level rather than at the toes?