Hi all,
I have several California projects (that are all LEED 2009) and thought that getting this credit via BUG ratings would be a slam dunk since these projects all have CALGreen requirements that include BUG rating compliance. As far as I can tell, the requirements overlap completely with the LEED requirements. And yet, on every one of these projects, I am struggling to get any BUG rating documentation out of the project teams. I am being told with a shrug that BUG ratings come from the suppliers (as if the mounting height and orientation play no part) and some provide it and some don't. If I were pursuing CALGreen based alternate compliance on these projects via LEED v4, I would get this credit outright without having to demonstrate anything.
So what's the deal? Am I missing something? I'm getting the impression that CA municipalities are not actually enforcing CALGreen so teams aren't actually having to demonstrate compliance and that GBCI is therefore giving them credit through alternate compliance for things they aren't actually doing. Can anyone with CA projects confirm how they are going about this?
Bill Swanson
Sr. Electrical EngineerIntegrated Design Solutions
LEEDuser Expert
730 thumbs up
September 20, 2018 - 3:45 pm
I have no experience with California and hope someone chimes in.
The BUG rating (usually IES file) comes from the manufacturer's website. I consider it the responsibility of the Engineer of Record to show compliance with Code when the Authority Having Jurisdiction (AHJ, aka Code official) wants documentation. This is often me. I don't do it unless asked. But if the city official asks for documentation for site lighting compliance, I will make a sheet to show compliance with that City's ordinance. Same with Emergency Egress lighting, same with ComCheck for Energy Code compliance. I put my stamp on the drawing and I take responsibility for Code compliance issues related to design.
If I am working on a LEED project I have added extra hours for LEED documentation. Having Code required documentation align perfectly with LEED documentation sounds like a dream.
Are these projects Design-Build? No one ever seems to want responsibility for Design-Build projects. And if a city official is not enforcing it, they won't do it. By contract, who was responsible to document LEED for this credit? You or the Engineer? If you, I understand you'd want the Engineer to do their job and document Code compliance and you can just copy it for LEED. But they won't do it if they don't have to. And if LEED documentation wasn't in their bid, and no AHJ is asking for it, they won't do it.
It often takes a while for Building Code Officials (AHJ) to start enforcing new laws. It is usually the result of them attending a training seminar explaining everything to them. And then they often just ask for the paper, scan the paper briefly to verify the numbers are where they are required to be, and then file the papers away. I have never experienced any AHJ review lighting related documents the way LEED reviewers do.
Michelle Rosenberger
PartnerArchEcology
519 thumbs up
September 20, 2018 - 4:44 pm
Hi Bill,
Thanks for the prompt and comprehensive response. Yes, the projects are Design-Build so you're right the responsibility gets shunted between the design engineer and the subcontractor. Responsibility for documenting the LEED credit can also be unclear when projects didn't have LEED in their sights right from the start and given the fact that specific credits being pursued are often determined after design scopes are set or are not understood by the bidders. That's why I inflected compliance toward the BUG rating thinking I was minimizing any additional cost/effort above and beyond code. But you've put your finger on it. The AHJ is apparently not asking for it so a lot of projects simply aren't doing it.
It's frustrating that after establishing this incredibly stringent v4 rating system, the USGBC is okay with an alternate compliance path that takes all the CALGreen requirements at face value and doesn't require the projects to demonstrate they are actually doing what it takes to reach them.
Bill Swanson
Sr. Electrical EngineerIntegrated Design Solutions
LEEDuser Expert
730 thumbs up
September 20, 2018 - 4:51 pm
Yeah. I'm still amazed that the USGBC website has language like this.
"At USGBC, we stand for accountability, and we translate that accountability through the LEED third-party certification process."
If the building has occupancy, they assume it complies with everything in the Code. For ease of documentation it helps a lot. But it's definitely not third-party certification for everything.