EA PR 2

Eliazabeth, it's a not a done deal! This is the 3rd round of comments--please take a couple minutes and make your point here about why you think it should change.

I am sorely disappointed with the outcome here as well Elizabeth. Still licking my wounds from fighting for this Option on the LEED Committee calls leading up to this round of public comment. The mission connection here is beyond obvious in my opinion.

As a consolation prize a prerequisite was introduced into the pilot credit library that will allow projects to test the 20% improvement path. See http://www.usgbc.org/ShowFile.aspx?DocumentID=18563 The good news about that is that projects can test it starting now! The bad news are the what I consider to be severe restrictions being placed on the pilot (no EAc1 points available and an unprecedented limiting of the certification level).

There has been some talk of introducing a pilot credit so projects can earn EAc1 points but that is still being discussed.

So apparently a small but influential group within USGBC/LEED feels that "brand" integrity is only defined as a recognition of top performers. For me brand integrity is being true to the mission of market transformation. Maybe some other organization will jump in and create a recognition program that really does something to address climate change in existing buildings. In my opinion LEED just dropped the ball on that issue.

I will echo Tristan's suggestion and urge anyone who feels strongly on this issue to flood the USGBC with third round public comments to restore this Option and to sign up for the pilot to demonstrate demand for this option.

You are correct and even LEED 2009 projects can sign up and use it.

Ditto the comments about the 20% Improvement option. Taking this out drastically limits the market impacts of LEED-EBOM - many projects that could be motivated to generate big energy savings will never participate without a compliance path based on percent improvement.

It is odd that your EUI is identical each year. What is the variation in the actual energy use year-to-year? May have something to do with the way Portfolio Manager treats the baseline year. Perhaps have PM look at the past five years individually (not as the baseline) and see what the EUI calculates for each year. Then do the calculations outside PM. I would need to play around with PM to figure out exactly how to do this.

As I said Elizabeth you are the test subject in a pilot prerequisite. Let me know if you can't figure it out - I'd be willing to help.

All,

Under EA Pre 2 Credit 1: Case 2 Buildings Not Eligible for an Energy Star Rating

Regarding the elimination of Case 2 Option 3, can anybody describe how this option differs significantly from Option 2? We're not seeing the significance as this option only applies to buildings already not eligible to receive an Energy Star score. Isn't elimination of Option 3, really a conflation into option 2?

If something like Case 2 Option 3 were available to ALL building types- that could be transformational concerning potential market uptake.

Are we missing something here? How we can we help to advocate that Case 2 Option 3 might be available to all building types looking to improve? We couldn't agree more that the number one barrier to entry for LEED EBOM has been the restrictions associated with this prerequisite and credit.

Marc

All,

We hope to get a bit of clarification from others regarding the questions outlined above, but wanted to share what we posted to USGBC comment RE: EA Pre1 Credit 2 as well.

Cheers,

Marc

---

This prerequisite represents the single largest barrier to widespread market uptake. Per a recent LEED review comment we received on a recent project "Additionally, note that the intent of this prerequisite is to reward documented energy efficiency over time, rather than just a reduction in energy consumption due to other factors."

However as past and current LEED guidelines are written the credit is structured so that the historical improvement option is limited to specific non energy star eligible building types (and a small overall percentage of the market.) If market transformation is the goal then a percentage improvement over time (20-25%) should be available to ALL building types.

Three specific issues:

We've had a number of client specific instances where the current Energy Star score and associated uncertainty around the potential for capital improvement to impact the Energy Star score to level needed to pursue LEED (and yes we used tools to estimate projected savings and future Energy Star scores) have actually retarded investment or willingness to pursue the rating system.

Buildings with the worst operational energy performance (lowest 25-50%) often are the best suited for operational and capital investment and can best illustrate performance improvement over time.

In our region, people are just beginning to see the value associated with baselining/benchmarking facilities as an operational best practice, are becoming more interested in closing the gap between high performance design, construction and operations, and are now seriously considering LEED EBOM and other building performance standards.

However also consider this, regionally, we are already behind in terms of EBOM and Energy Star uptake. As the bell curve shifts and a rating of 75 equates to even less kbtu per square foot usage over time, will certain regions who are already behind simply find compliance impossible? I know that the PM tool normalizes for efficiency across the country, but it cannot account for regional or state initiatives, progressive culture, or regional advancement.

Suggestion
Make Case 2 Option 2 or (now eliminated Option 3) use of historical data and incremental improvement of a minimum of 20-25% the LEED performance threshold available to all building types. If an absolute must be applied then perhaps moving the minimum performance threshold to 50 or even 25 in terms of energy Star score or similar benchmark would have HUGE implications for potential market uptake, and resulting building energy efficiency investment.

Rob Watson wondered why there wasn't more EBOM uptake in 2011 in his most recent Green Buildings Impact Report, we suggest the barrier to entry plays a significant role.

If we want to see widespread market uptake then we need to make the system available to the whole market.

Thanks for all of your hard work.

Elizibeth,

Thanks and got it. We still feel there should be an actual option within the EA credit structure and potential achievement of resulting points, and will continue to, along with other such as yourself, advocate for that option. A pilot credit is not enough.

Thanks,

Marc

This debate has been both fascinating and enlightening to me - thanks to everyone who has shared their thoughts. I have largely come around to the conclusion shared by most folks here - the 20% reduction option is a good move and the methodological problems it poses are manageable. That being said, I feel like its worthwhile to explain why I think its not a no-brainer for USGBC to embrace this option.

EBOM has always been a recognition program for outstanding performers. The entire rating system is predicated on performance relative to peers rather than improvement. SSc4, WEp1, WEc3, everything (although the word 'reduction' is used liberally it is almost always used as a 'reduction from baseline' rather than historical reduction). The one exception, as Marc notes, is the Case 2, Option 2 path; this path exists because there was basically no other way to handle buildings that were ineligible for all the preceding paths. Rather than simply tell those buildings "Sorry, EB isn't for you." this path became the last resort.

The point I am trying to make is simply that opening a 20% reduction compliance path for what we all agree is the key gatekeeper prerequisite to the rating system would represent a profound change to what EB currently is and does.

I happen to agree with Marcus (OK, Marcus convinced me) and Elizabeth that the change is worthwhile, the only way to broaden market participation, and the right choice for achieving the fundamental mission, but I also understand why USGBC might be reluctant to make such a pivotal shift without being very confident in the consequences.

Dan

Glad you've come around, Dan. I support the inclusion of this option as well.

To your point about the methodological problems, I'd suggest that they may not be any lesser or greater with this option than with others. I actually think any methodology developed to go with this option would likely be more transparent than the ENERGY STAR methodology since it would be USGBC developed, and no less or more subject to abuse.

Also, another interesting thing to note - the 2012 draft includes a few new offerings to earn points based on a demonstrated improvement over a historic baseline:

WE - Outdoor Water Use Reduction Case 2, allows showing a reduction over a 1 year historic baseline

WE - Indoor Water Use Reduction Option 2, allows showing a reduction over a 1 year historic baseline

So, the pivot has already happened in the WE section. Why for water but not for energy?

Great to have you on board Marc! Option 3 for all!!

I agree with your EBOM assessment Dan and that is a big part of the attitude shift that needs to occur to make EBOM an effective agent of market transformation instead of a reward for the already there.

If anyone is interested and has not yet received the opinion piece I wrote on this subject (written in part to get Dan on board) that was distributed last week via email I would be happy to send it to anyone who wishes to receive it. Just send me an email at sheffer@sevengroup.com

Since the public comment period was extended there is still time to register your opinion if you haven't already done so.

Some times inverting numbers can make things more revealing. When the cash 4 clunkers Federal program first came out I thought it was a joke. Who cares if a car goes from 10 mpg to 14 mpg. We need the whole country average to move from 20 mpg to 40 mpg.

Low hanging fruit.
10-14 mpg is 28.6 gallons saved per 1,000 miles.
20-40 mpg is 25.0 gallons saved per 1,000 miles.

Yes, it would be great if everyone had cars with at least 40 mpg just like it would be great if every building could earn at least 75 Energy Star rating.

But if our goal is to reduce total national energy usage it would be unwise to ignore the energy hogs. Give them a realistic stepping stone. Their small step can still be a big energy savings.

Great analogy Bill!

Some folks want to see the numbers on this issue but I am assuming that it should be so obvious as to cross the line into just plain common sense.

Perhaps I could make a comment from a different angle....why is there such a push to get EVERY building into LEED. It's never going to happen, some buildings will make it and some won't. Is that such a big deal? If we want to have buildings in LEED that can stand the accolade of 'high performance buildings' then they better be "High Performance'...not some lowest common denominator that gets the plaque. (We'll leave aside the potential problem that many credits in 2012 are so expensive/so drill down that many buildings won't get the number of required points for a plaque!)
Those buildings that CAN'T make E* really should be classed as huge potentials for upgrades and upgrades that payback like crazy! Or great case studies about how to make improvements in buildings that have low E* scores....What is wrong with that?
As responders above have used analogies, here's another...we don't pick 2012 Olympic athletes and give them a gold medal for their potential, we pick them because they are the best of the best and they perform to that Olympic standard.

Hey Barry,

We are not saying that every buildings should be able to earn LEED certification, nor are we saying that every building should earn LEED certification based on potential. To get in the EBOM game significant improvers would need to show a 20% reduction in energy use. This requires a significant effort.

The fundamental question is this - is the purpose of LEED to recognize top performers or market transformation? The two are not the same. One is simply a strategy for achieving the other.

I'll send you my full rational for the inclusion of Option 3 in EBOM, then let me know what you think.

That would be true if the REST of the LEED credits were based on market transformation...and they're not. Too many have been side tracked by insider and outsider forces that have split hairs to the nth degree.
Two Greenbuilds' ago Mike Optiz stopped me and asked "What changes should we be making to LEED EB"...I answered "Nothing!, we need a period of status quo so that the marketplace can catch up and understand what the devil we are trying to do'.
LEED are making changes so drastic and so high speed that by the time we've get the narrative down to a reasonable length..the whole thing changes...nothing can keep up (LEED-on-Line, GBCI, Reference guides, etc)
The only people who are going to 'gain' from this 2012 version are the marketleaders and those with the cash to throw at it....that's not market transformation..that's the begining of elitism.

Barry we should continue this conversation over a beer. But I can't help myself.

If USGBC and LEED are not about market transformation then their respective mission statements are lying and I am wasting my time working with it. Perhaps we have a different understanding of the term. To me it implies market change over time. So if certain LEED credits are not about transforming the market then they should be removed.

LEED has not fundamentally changed since 2005 for BD+C and 2008 for EBOM. Not exactly high speed in my way of thinking and in my experience plenty of time for the status quo to catch up. Virtually every BD+C project we work now on gets LEED Gold without even trying. The market has caught up and when that happens LEED frankly doesn't mean anything. It just becomes a passer-out of expensive plaques. Maybe EBOM projects are not quite there yet. You know that market better than I. My read is that 2012 EBOM has not changed nearly as much as 2012 BD+C in recognition of the degree of market penetration and the need for more consistency in the O&M market.

As I recall it was a group of elites in this field, including yourself, that developed LEED in the first place. Maybe I am just naive and idealistic. I have always thought that LEED's fundamental purpose is to change the way buildings are designed, constructed and operated. Then again I have always thought that the Olympics were about using "sport at the service of the harmonious development of humankind" (quote from the Olympic Charter) not winning medals.

Olympics NOT about medals?...wait until 2012 in London...the only thing the media will be concerned about is the medal table followed shortly by..who took what drug!
Ok, seriously if we're looking to change the marketplace then raising the bar of compliance is the perfect way to do that. In 2002 when the EB core committee was founded we talked a long time about what level of E* should be required and eventually picked 65...even though by EPA standards that wasn't a 'green building'. EB V3 stands at 69 with 2012 jumping again.
Now suddenly with Option 3 we are allowing high energy consuming buildings into the race..all this does is undermine the hard work that low energy consuming buildings have undertaken to gain their E* score.

I too love a good metaphor and I think Barry's is illustrative. The question is about what EBOM is trying to accomplish - is it a program to promote top performance and recognize excellence among a relative elite (the Olympics) or is it a national health and fitness program targeting obesity and diabetes in the general population (the 20% reduction option). Right now it IS the Olympics but the 20% option redirects to a very different end goal. And I agree that if EBOM wants to continue to promote emissions reduction, helping those buildings is important. Is LEED the vehicle? It seems like it should be, but its an open question.

I also think Barry's point about the increasing technical sophistication of EBOM is a valid concern unrelated to the 20% reduction option. The rating system keeps getting better from a technical rigor standpoint but at the same time less and less accessible to the layperson. In some ways this is an inevitable trend as the plaque becomes more valuable in the marketplace, but boy. . . counting bike racks sure was easier than this latest SSc4 revision. . .

Dan

Elizabeth raises a good point: Energy Star is far from perfect, and that's an improtant part of this conversation. Though I think it is a really valuable program and wish it continued growth and improvement, I can't say I have loads of faith in its accurate comparison of one building to the next. It's nowhere near as straightforward as pitting two Olympic runners against each other and seeing who fairs best. Frankly, it's also super easy to game if you know which levers to push, so I guess Barry's reference to doping is applicable here too. I think its main utility, actually, is in helping an individual buildings see how it's trending over time.

Another thing to consider: Does setting a high bar in for energy prerequsites in LEED drag the entire market forward, or does it create a binary of those close enough to pursue LEED and those not? In my experience, having barriers to entry that put basic certification out of reach for the great majority of buildings is not going to bring them along...they'll turn away from sustainability altogether or turn to Green Globes or something else, I'd guess. There are four tiers of certification. If we think we need to create an elite upper crust here, why not reserve it for Gold and Platinum and still find a way to include the other 75%?

Finally, we aren't talking about raising a kbtu/sf threshold, but a percentile threshold. This makes increases in the EAp2 threshold a zero sum game, where allowing a smaller percentage of buildings in means locking a larger percentage of buildings out, regardless of how much energy the save, or if they cut enough to be at the level of last years' elite.

Maybe I'm just addled by all the 80+ degree March weather here in Chicago, but this just doesn't seem useful in the larger sceme of the environmental issues we're trying to solve.

All,

One other thing worth mentioning is the issue of barrier to entry across rating systems.

Regarding BD&C
We've never had an instance in which (assuming it's not too late in the design and construction process) we've had to tell a client interested in LEED-BD&C that it simply isn't an option. In fact, the single largest barriers to entry associated with BD&C are usually the costs associated with energy modeling and commissioning; which are usually marginal relative to total project budgets.

Studies have also shown that while many LEED BD&C buildings do perform better than national AVERAGES (Energy Star score equivalence of 50), some don't. Certainly not all LEED BD&C certified facilities perform in the top 25% of operational energy performance.

This is not to suggest LEED BD&C doesn't require a thoughtful approach to design and construction and that a proactive team isn't essential. Just pointing out what we perceive as a significant difference. In many ways this is a credit to LEED BD&C system as the 2012 GBIR suggested 20% of all new construction starts in 2011 were registered under LEED.

We should be asking what is the best way to reach that kind of market penetration--in a much much bigger market--in our existing and operational buildings. Even if this credit were to change, we're not talking about every building, but a goal of 20% uptake would certainly be inline with USGBC mission, no?

Lets also remember that energy efficiency upgrades in buildings represents the single biggest wedge or opportunity in terms of reducing national carbon emissions. We should leverage LEED's brand recognition to engage more owners in meaningful environmental performance improvement discussions. Many operators and facility managers do want to improve performance, but when going to the CFO for financing the associated potential to pursue LEED certainly doesn't hurt.

Even if we were to limit the total points available to option 3 that would be fine, perhaps it would be inherently harder to reach gold of platinum if each EAc1 option were weighted correctly. However let's not forget that LEED is also an aggregate of environmental performance across categories and that there are plenty of facilities that might illustrate both great energy performance improvement over time and high performance in other operational areas.

All the best to everyone,

Marc

All,

So with the postponement of LEED 2012, what happens now, is this an open issue once again?

Thanks,

Marc

It can only be an open issue if it goes back in the rating system for the next round of public comment.

It probably needs to "prove" itself in the pilot library. I have not seen any significant promotion of it yet but maybe some things are happening behind the scenes. I have talked to several staffers about promoting it. Last I heard there were only a hand-full of projects using it.

Does anyone know if the 500 project max for this pilot option has been hit yet? I can't readily see anything that indicates that the option has yet closed out, but before I bring this possible pilot option to my client, I want to make sure it is still available.

We have been struggling mightily with a building in Boston built in the 1840s that has made significant strides in terms of energy efficiency, and we have done significant work in all other areas of EBOM, but we are very unsure that we can hit the min 69 Energy Star score. This pilot may be the answer for us. I echo all of the great comments above on keeping this 20% option in for the 2012 version of EBOM. I agree that it is key to give the less energy efficient buildings a chance at LEED if they show substantial improvement over baseline.

I am certain that the pilot is still open.