We project 90+% of the credits will cost more to implement in LEED 2012 than the current cost in LEED 2009 and that is not including additional design team fees or LEED documentation. We feel strongly that our clients will not pursue LEED under the proposed 2012 systems. Most of our clients had not previously drunk the kool-aid and only recently have come to the space that LEED is the 'right thing to do'. Absorbing a 30-40% change would be very difficult, especially given the current economic conditions and quantity of construction starts. The impact of this level of change will significantly alter the perception of LEED.

There should be a standard that USGBC do a cost study or life cycle analysis of LEED 2012 compared to LEED 2009 so that owner/developers will understand the impact ?? Cost studies & life cycle analyses are included in many credits, so why not one of each new version ?? It appears that the benefits are out of balance with the cost to achieve many of the new or renovated credits. Understanding the intention to raise the bar, it still should be balanced with a cost-effective, sustainable rating system. Sustainability is defined with 3Ps, people, planet & profitable, right ?? To be sustainable, it has to be profitable.

We did an analysis of an NC 2009 project which should easily attain Gold-level and it will likely not achieve Certified-level under 2012 without significant additional cost, excluding design firm & LEED fees.

Understandably these are general comments so thankfully we have another week to supply credit specific comments & recommendations.