Appropriate time for submitting the Preliminary Design Review

I can tell you that my design submissions on NC projects are happening later and later. This is mostly because of the Energy Model. On many projects, we are asked for things like window assembly information related to the submittals and we do not get those until the project has been awarded and construction starts. We are waiting to receive those from the contractors and they need to be included and accounted for.

In relation to the energy model related credits, I like to submit them once and make sure they are very complete and we know about where we are falling point-wise, so we are waiting until the submittal process begins. It is also so that we don't have to spend a lot of time working on clarifications/narratives during review because we are missing information that the reviewers are looking for.

Submitting the design review (deferring those credits until the construction submittal) without the energy model and related credits complete is just not worth it to me as the bulk of the design points is often tied up in those energey model credits. And that does not give you a clear picture on the points you are earning heading into construction.

It still works out ok if you have a long duration for construction of a project as you will still get final design review complete and a good picture of what credits/points you are earning very early in construction.

There is no documented LEED requirement to provide submittals for review. Why start this now?

I don't see how the USGBC can justify having reviewers doing reviews of A&E submittals. The assumption seems to be that LEED projects have been cheating, and that must be stopped.

LEED certification fees will have to increase to cover these types of submittals.

Consulting fees will have to increase, or the cost has to be eaten at a loss.

I don't see anyone winning here. I also don't see how this helps green buildings in any way.

I agree with Hernando, there is nothing that says construction submittals are required for a design credit. Now, I might understand asking to see the specification for the window assembly, which is a design task. EAp2 and EAc1 continue to generate the most comments requiring answer…that is for sure! Many seem to be of the kind that require a modeler to show that they did something the right way, almost like a QA comment, not a real fault found in the model. Others are legitimate or at least arguable points on choices made or processes followed.

I still feel that the energy modeling is so important, and so contentious, that there should be one more round of questions and comments, and maybe even an automatic conference call. This could save everyone’s time.

I hear what you both are saying and I agree. However, that is not the reality that I have seen in the last year or so with reviews. I have been asked more than once to provide the window specification information separately, above and beyond from what is shown in the project information uploaded as well as the information included in/utilized for the energy model. Our engineers have been waiting for the submittal process to finish the Energy Model credits once we receive and upload the submittals from the contractor on the window assembly info for this very reason... we got tired of getting the credit bounced back with this comment/clarification multiple times.

The energy review comments affect everyone. No one can get through the system.

People now working for the GBCI who were previously LEED Energy Consultants, and some of the best energy analysts in the field, could not get through a LEED energy review without comments.

In California, the people who wrote the approved Title 24 energy software, and also do energy modeling consulting, cannot get thorough a LEED project without comments.

What purpose would be a call with an energy code super-expert, and software author? To tell them they did not know how to model their building properly?

The burden of submittal proof does not fall on the energy analyst. They run their model based on the final design. They do not do Construction Administration. The burden falls on the LEED Project Administrator to do the work, review the modeling assumptions and request modeling updates prior to final LEED submittal.

Regarding the issues raised about the timing of a design submission and how that relates to the energy model - EAp2/EAc1 is listed as a design credit, however, once your design credits are approved you must indicate that nothing changed to affect this credit during construction prior to your construction submission. The ultimate final model must be based on what was built as a result. Typically we do not have the budget to do the final model twice and we have no way of knowing the extent of the likely changes during construction. So we almost always defer the final model until the construction review phase or we do the final model based on the design with the clear understanding that any changes during construction are outside our scope of work.

Valerie, we do quite a bit of LEED and energy modeling ourselves, and we track the comments we get from the GBCI reviewers, and we try to always address that list before submission, if appropriate. They always come up with more! Seems like no matter what, you are going to get some comments to answer, just as a matter of course.

To your specific instance on the window submittals, I have looked at our listing (which is a little behind) and some recent v09 review comments, and we have had questions related to glazing and window systems, but none specifically asked for submittals. I did see where we used the submittals in our response, but it is unclear if that was just because we had them, or that we needed them.

I wonder if you have a particular reviewer that is going beyond what should be asked? Have you ever pushed back or asked for a conference call to justify their request? Have they ever justified their request in writing?

Marcus, there is a huge difference with confirming the installed products were per specifications because no substitutions were allowed. That is not difficult to check for.

It is an extreme effort to package parts of multiple A&E submittals to prove the products match the energy model. In most case the submittals do not provide the required information.

It seems you are supporting the reviewers new requirement to demand these types submittals. Are you prepared to actually provide what is required? If you are, then how do you justify the cost of LEED consulting doing that type of construction administration review?

I did not even comment on the specific submittals issue as it relates to the LEED submission Hernando so please don't put words in my mouth. Submittals are generally not required but can be helpful in a review response.

We do not review the submittals as the energy modeling or LEED consultant. We ask for information from the project team near the completion of construction to enable us to do the final model based on the construction. Sometimes we get as-builts or approved submittals or other documentation. Sometimes we just go over the project's energy modeling inputs with the designers and ask if anything has changed. It is really not that complicated to get the information we need. It is all readily available on the projects we work on, might take a little digging but that has not proven to be a major problem for the teams we work with.

Here is an excerpt from recent v2.2 Design Application review of the EAc1 energy model:

"... Provide additional information to confirm that the framed assembly U-value was used for the Proposed case fenestrations (e.g. showing that the whole fenestration assembly has been tested by NFRC, or verifying that LBNL Window v6.3 calculations have been provided for the whole assembly, or verifying that the frame effects are captured within the energy modeling software), or revise the model referencing ASHRAE Standard 90.1-2004, Table A8.2, if needed."

While it does not specifically ask for construction submittals, it would be tricky to answer this without an actual product. In our case, we had received the window submittals, and chose to upload them as supporting documentation. If we didn't have those yet, I guess we could have indicated that the Design was based on a specific product that was in the specifications. Don't know if that would have been enough to satisfy the reviewers.

Shivani there are advantages and disadvantages to both approaches. Submit it with the design review if you want earlier feedback on your LEED score so you can do something about it during construction and if you are pretty certain that there will be minimal changes that occur during construction to affect the modeling results. Wait until the construction review if you are uncertain about construction changes affecting the model.

Muscoe that review comment has always created some confusion. It goes back to Table 1.4.1B asking for the glazing U-value and not the whole assembly U-value. All the reviewer wants to know is that the frames have been accounted for in the Proposed model. The reviewers know a reasonable range to expect for a typical window whole assembly U-value. Quite often this comments is provided when it appears as if a center-of-glass U-value was reported.

In your case this is a good example where the actual submittals would be helpful and perhaps save some explaining. If you don't have them there are other ways to address the reviewer's concerns.

Marcus wrote: "you must indicate that nothing changed to affect this credit during construction prior to your construction submission."

Construction submission implies submittals. Submittals are the basis required to confirm material credits. Logic holds the same would be applied to any other LEED credits.

I didn't put words in your mouth. You certainly don't seem to approve of expanded review demands. But you provided a defense for a demand, regardless of what the demand is.

Unfortunately, there is no way to stop the ever increasing review demands. Even the top management of the GBCI can't stop them. The real question is why not? Who is actually running the development of the LEED process? It's not the GBIC people.

You are correct Marcus, and in this case, we were using high-performance windows with pretty low U-values, which might have flagged this comment. Still, the wording certainly implies some finality about what the documentation they are asking for.

Marcus, when you say you defer the energy model, does this mean that you do not mark add EAp2 and EAc1 at the final design submittal and do not submit it? Do you usually submit these points at preliminary or final construction?

Many thanks,
Adrienn

Hernando you accused me of "supporting the reviewers new requirement to demand these types submittals". Just because the LEED rules indicate that the final credit submissions must be based on the final construction does not mean I agree with requiring the submission of a bunch of submittals in the review process. I was not defending the demands, I was merely stating what the requirements are currently because that are many folks who may not realize that the final model is supposed to be based on the final construction.

Regarding the specific window submittal in this thread I have already stated that particular one can be helpful to provide. That also does not mean that I support the submission of all the possible submittals for all credits.

Adrienn - You can defer a credit(s) from the design review phase to the construction review phase in a split submission. So you can either submit EAp2/EAc1 in the design preliminary or wait until the construction preliminary. If you do a combined submission you have to wait until near the end of construction anyway.

Marcus, you are reading too much into the comment. Don't take it personally.

The problem with LEED is that statements made such as, "final credit submissions must be based on the final construction," are a blank check for making up new LEED rules. It is open ended. Word game playing is an unfortunate part of LEED, and it was invented by the original Reference Guide authors.

"Final credit submissions must be based on the final construction" can mean anything the USGBC decides it wants it to mean, and the definition can change whenever the USGBC wants it to. The basis for redefining the definition is that LEED says "based on final construction." The definition of what that means is variable. It shouldn't be that way, but that is what the USGBC has been doing to justify new requirements for LEED.

I can say the same thing about your comments Hernando. You seemed to me to read into my comment something I did not say. Just making sure I was clear about what I was saying, nothing personal about it.

Basing the final submission on the final construction has always been a requirement. It is not a new rule. Word game playing has been around far longer than the original Reference Guide. In my opinion it is a limitation of the written nature inherit in the Review process. As you and I have demonstrated in our exchange above, written words can be interpreted in different ways by different parties.

As someone involved with doing LEED Reviews for 10 years now I will be the first to admit the process is not perfect and that it often appears as if "new requirements" are included in Review comments. Often however, the additional documentation asked for in a review comment is just provided to give project teams an idea of what the acceptable documentation might be in a given situation. Usually project teams are given options (like the review comment Muscoe mentioned above) and a submittal might be one of the options suggested. That is not a new requirement but rather providing project teams with suggestions on the documentation that might provide the clarification being sought. GBCI is well aware of this situation and believe it or not they do try and bend over backward to give project teams the benefit of the doubt in the final (or appeal) review. They are not trying to make stuff up to make it harder for the sake of it being harder, that would be counter to their long term interest.

It seems that what you view as new requirements is just GBCI trying to ensure the integrity of the system (did you do what you said you did). The whole point of certification is to prove to a third-party that you did what you said and sometimes that just means projects need to clarify what they did. Given the current system this means a response in writing. Hopefully in the future project teams will be able to talk to their reviewer (something I have been advocating for many years) to provide some clarifications and engender a more positive experience as opposed to the largely punitive nature of the current process.

I basically volunteer my time in these forums to help project teams to understand and navigate the system so that we get better submissions that generate fewer comments.

.....And that's a wrap. Time for a new topic.