I have come across this on more than one occasion and different projects (CI and EBOM). If a client wants to repaint and recarpet more than 50% (usually throughout for a new tenant), is this considered a "real" alteration under the definitions of more than 50% of floor space? As in the EBOM case, we have other minor repairs that meet the extra criteria:
• Changes must affect usable space in the building.
• Include construction activity by more than one trade specialty.
• Require isolation of the work site from regular building occupants for the duration of construction.
• make substantial changes to at least one entire room (kitchen - cabinetry, minor sheetrock, new cabinetry and countertops, remove dishwasher, replace VCT flooring, paint.)
For CI, I have a client that is just doing carpet/paint for 70% and she thinks this makes it a CI candidate. No other trades are included aside from one door removed/replaced).
Any clarity would be helpful.
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Barry Giles
Founder & CEO, LEED Fellow, BREEAM FellowBuildingWise LLC
LEEDuser Expert
338 thumbs up
April 27, 2012 - 11:07 am
Michelle. This question has been a thorn in the side of operations teams since we wrote the credit in 2002. In practice the GBCI required at least two trades to be involved and that 'substantial' changes had to be made...as you point out. However after a couple of years use of EB and numerous credit reviews by GBCI it soon became apparent that the word 'substantial' had not been defined either by us on the core committee nor by GBCI/USGBC. This was exacerbated by GBCI requiring larger and larger contracts to be undertaken to ‘prove the credit’. In defence of GBCI they were concerned that credit manipulation would result if they allowed one carpet tile and a pint of paint to constitute credit approval…they are quite right…in some cases that could well happen in the 3 month initial performance period, but in reality what are we trying to achieve with LEED EB…isn’t the focus that every piece of material that passes into the building should meet the standards created, regardless if it weigh a pound or weighs 1000 lb. If we link this MR C3 with MRc9, then the same should apply to waste disposal. In reality if you want to game the system in the 3 month performance period…you WILL game the system, but for those of us (at that’s the vast majority of us) we’re trying to do the right thing and follow the core LEED requirements…even down to the one carpet tile and the one pint of paint.
I assure you that recent phone calls have indicated that GBCI would like to clear up this need for clarification in 2012, however I’m not certain that this can be made retro active right now. Put the paperwork in…articulate clearly not just by what you say but with supporting photos…don’t give in….good luck
John McFarland
Director of OperationsWorkingBuildings, LLC
LEEDuser Expert
42 thumbs up
August 2, 2012 - 2:52 pm
Well, GBCI has finally come up with the requirement. In response to an appeal that we filed, GBCI denied the credit stating that "Substantial alterations typically involve the relocation of walls or affect greater than 5% of the gross floor area." So, your alteration has to be at least 5% of the building. Of course, USGBC never stated this so it's technically not a credit requirement, but as we have all seen GBCI is making up their own requirements and since tthey control the reviews we have to abide by their rules, not those developed during the consensus-based USGBC rating system development. I wish USGBC would step up and take back control of the rating system.
Jason Franken
Sustainability ProfessionalLEEDuser Expert
608 thumbs up
August 2, 2012 - 3:01 pm
Hi John,
I share your frustration on this issue. Did GBCI provide any other details in their appeal review? The criteria for a facility alteration used to be defined as one that utilized more than one trade specialty. So hypothetically, painting a couple of rooms wouldn't qualify, but painting and installing new carpet could earn you the credit. This was the primary reason that GBCI started to think about ways to make the credit threshold more stringent - they didn't like that projects could earn a point by purchasing a can of paint and a couple hundred square feet of carpeting.
So, did they provide any details on the level of activity or types of activity that need to occur in at least 5% of the building in order to qualify?
Michelle Rosenberger
PartnerArchEcology
522 thumbs up
August 2, 2012 - 3:24 pm
John,
We couldn't agree more with your comments! And we share your frustration. Requirements have become a moving target. It is becoming more and more difficult to provide guidance to our clients or to anticipate the comments we are going to get back.
We've been doing this for a decade now and have a passion for this work. Even we are having trouble dealing with this day in and day out. And at least one high profile incredibly committed sustainable client has told us in the past week, they are turning away from LEED. I honestly can't blame them.
What's a consensus driven membership to do?
John McFarland
Director of OperationsWorkingBuildings, LLC
LEEDuser Expert
42 thumbs up
August 2, 2012 - 3:40 pm
Hi Jason,
In answer to your question, no other details on what level of activity would be required. GBCI did state, "Specifically, an alteration that consists of painting and carpeting a single room is considered to be routine maintenance." So I guess USGBC should state that the work must consist of at least two (2) rooms, not just one. It seems that a project team has to at least move a wall (that would affect 2 rooms). As usual for GBCI at the end of the response they said, "please ensure that the facility alterations or additions meet the requirements for inclusion in LEED-EBOM as described in section IX Facility Alterations and Additions of the LEED Reference Guide for Green Building Operations and Maintenance, 2009Edition (Updated April 2010)." Funny, nowhere in that document does it say "5% of the gross floor area" or "relocation of walls".