Thank you for the opportunity to submit comments the draft version (v.5) of the Leadership in Energy and Environmental Design (LEED) certification criteria. First off, I would like to commend the efforts to move the Bird Collision Deterrence credit from the innovation credit section to the New Construction and Existing Buildings sections. This is an oportune moment for U.S. Green Building Council to look at the entirety of harm reduction and innovation to reduce energy consumption and protect wildlife. 

Critical context:

  1. 1 billion to 5.6 billion birds die annually due to building collisions in North America (Loss et al. 2014, Klem et al. 2024).
  2. Due to habitat loss and direct mortality, nearly 3 billion birds have permanently disappeared from the North American landscape since the 1970s (Rosenberg et al. 2019). This includes many species highly susceptible to building collisions, such as the Black-capped Chickadee and White-throated Sparrow.
  3. Building collisions are the second leading cause of direct bird mortality in North America.
  4. Mitigating the risk of bird building collisions deserves high priority when defining and ranking “sustainable building practices,” because of the very real risk of extinction for several birds susceptible to collisions, such as Bicknell’s Thrush and Grasshopper Sparrow.
  5. Unfortunately, some buildings with the highest number of documented collisions are LEED certified. This affects the reputation of LEED and gives a false impression of what constitutes an environmentally responsible building.

Many conservation partners in ornathology find that LEED v.5 has a critical gap in adequately safeguarding bird populations at and around green buildings. With needed changes, the US Green Building Council has a powerful opportunity to make a difference for bird populations and biodiversity conservation in North America. 

It is recommended to: 

  1. That LEED’s Bird Collision Deterrence credits should each be worth at least 3 points because of the significant and direct bird mortalities that could potentially be caused by “green buildings” and the associated risk of extinction for some affected bird species
  2. Any credit intended to reduce bird collisions at existing and new buildings must include the use of bird-friendly design and materials, specifically, materials with a Threat Factor (TF) of 30 or less. 
  3. The mitigation of building materials (glass or reflective metal) should never be optional to earn a “bird collision reduction” or “biodiverse habitat” credit.
  4. The subsections within these two credits should be reversed, so that Building Material mitigation is always listed before lighting requirements and other standards, to recognize that glass and reflective materials are the direct cause of mortality in building collisions and that mitigation of these materials is a critical priority for saving bird life.  
  5. The height measurement wording includes typos. It should read: 50 feet ABOVE grade; and From the first 20 feet ABOVE a green roof or terrace.
  6. Add glass railings, sky bridges/pedestrian overpasses and other glass architectural structures to the requirements for building strike mitigation. In self reported monitoring studies, sky bridges tend to be hot spots for collisions.
  7. We commend the new proposed credits for including native plants on building sites and green roofs and plazas, but with a serious and urgent caution. Because birds will be highly attracted to such habitat features, they risk becoming fatal “ecological traps” if collision hazards at these building sites are not simultaneously mitigated. Therefore:
  8. We strongly recommend that one of LEED’s new Bird Collisions Deterrence credits be a mandatory prerequisite to earning points for greening and soil-related credits, in both the new and existing criteria.  

We are confident that developers and designers would never intentionally seek to cause harm to birds or wildlife through their building design choices; however, this is unfortunately what is happening in the absence of robust LEED bird-strike standards. The US Green Building Council has an opportunity with v.5 to correct this, as the global definitions of “Sustainability” and “Green Building” have now expanded to rightly account for not just energy-efficiency and better natural resource management but also the co-occurring ecological crisis of biodiversity loss.

We believe that no building should be LEED certified as Gold or Platinum without earning a bird collision deterrence credit, because a sustainable building should not reduce the population of endangered or at-risk birds.

Again, thank you for the opportunity to review this credit and make it such that it benefits birds, people, and the planet.