I will be submitting more detailed comments directly to the USGBC. The following are just for LEEDUser feedback:

BD+C

SS: Heat Island Reduction
Has the USGBC considered making this credit climate zone-specific? In some climate zones, a darker roof actually reduces gross annual energy consumption at the individual building level. It is recognized that this credit has more to do with reducing heat islands than it does with reducing heating/cooling loads on individual buildings. However, there is something to be said for the aggregate, global effect of reduced heating/cooling loads on many individual buildings. A full LCA may even reveal that highly reflective roofs in heating dominated climate zones (e.g. CZ’s 6 and above) may actually contribute more to global warming than the heat island effect of less reflective roofs would. To my knowledge, such an LCA has not been performed to date. It is also recognized that the USGBC may desire to keep the heat island effect separate from the issue of energy efficiency/global warming within the LEED rating system. For example, the USGBC may see the increased energy consumption in individual buildings associated with this credit as a “trade-off” with EAp2/c1 in terms of contributing to global warming. Either way, it would be good to know that the USGBC has considered this issue and has made a deliberate decision.

WE: Indoor Water Use Reduction
Does anyone know why the rating system does not recognize ENERGY STAR as an option for commercial clothes washers?

MR: General Comment
It seems that the shift of using regional materials as a multiplier (instead of a "stand-alone" contributor) does not sufficiently encourage regional materials that do not also contribute to other sustainable product attributes listed in the MR credits. For example, a project using locally quarried stone floors could not receive credit for the "regionality" of the stone for the "Sourcing of Raw Materials" credit as it is currently written.

As an aside, I think that the common complaint about "too much documentation" for these credits deserves attention, but needs to be balanced. For those around when LEED 2.0 came out, how many manufacturers were making recycled content data available? 5%, 10% at most? LEED always has been a market driver and manufacturers will respond as they have in the past (hopefully!).

MR: Construction and Demolition Waste Management
"Option 2. Reduction of Total Waste Material" should make it more clear that diversion from landfills is not a requirement for fulfilling this option (I assume it is not as 2.5 lbs/SF is a very small amount of waste for most projects).

EQ: Interior Lighting
We are concerned about requirement of three lighting levels for individual occupant spaces. Of particular concern are open office spaces with individual workspaces—a growing trend in commercial offices. It is already a challenge to provide individual-controlled lighting for these spaces (often in the form of task lighting at the desk level). It is not clear how multi-level lighting would be beneficial for individual spaces in an open office where task lighting is already available. Moreover, if task lighting is used, the space is, in effect, already employing three levels of lighting (off, ambient overhead lighting, and task lighting). It is proposed that an exception be made to the requirement for multi-level lighting for individual occupant spaces where task lighting is employed as a strategy.