I was under the impression from Chrissy Macken from USGBC during the first public comment phase that all aspects of LEED were up for comments.
My suggestion to revise the BUG lighting system in the Light Pollution credit was responded to with the comment that the BUG classification system (TM-15) is a referenced standard and cannot be changed.
I am less than satisfied with this Public Comment phase.
Christina Macken
Assistant Project Manager, LEED v4U.S. Green Building Council
141 thumbs up
August 10, 2011 - 5:30 pm
Hi Bill -
To clarify the sentence noted above, TM-15 is a standard we reference (and not a standard we write) and therefore we cannot change the standard itself; the reference we choose could be changed. The issues associated with the BUG calculation in the 1st Public Comment Draft have been corrected. While the option exists for something to be referenced other than the BUG rating, our experts working on the requirements for this credit determined that the BUG rating is a more accurate measure to use for determining backlight, uplight and glare than what is in the requirements for LEED 2009, while allowing steps toward simplification of the credit. Comments and recommendations about the Light Pollution Credit on a whole did not suggest something besides the BUG system.
Bill Swanson
Sr. Electrical EngineerIntegrated Design Solutions
LEEDuser Expert
731 thumbs up
August 10, 2011 - 9:06 pm
By clarify are you meaning to change completely? Because in December I specifically asked if we can try to change part or all of a referenced standard to which you said, "All aspects of those credits are open for comment, including the referenced standards."
I have tried to change referenced standards and they point back to LEED saying that if it's good for LEED then they feel no need to change. It's circle logic. And how can I know which standard LEED will reference next cycle to try and preempt them?
I agree, the available standards out there are garbage. I have tried numerous times to offer an alternative compliance path. It's my creation, given freely to USGBC. Backed up with as much support information as can fit into a blob of text. Only to be told that "such-n-such" reference standard is all that they'll consider. Or, X% of projects are able to earn the credit as is so we feel no need to change it.
So maybe I could tweak that Standard to make it less terrible. Apparently not.
It's a USGBC sandbox and my toys are not welcome. Just wanted to clarify.
Bill Swanson
Sr. Electrical EngineerIntegrated Design Solutions
LEEDuser Expert
731 thumbs up
August 11, 2011 - 8:01 am
I know USGBC cannot directly change 3rd Party standards. But you can change your use of them. It's like modifying a car after you buy it. I know you can't make the factory change what they do but the car in your hands you can change however you want. All I wanted was for you to put different shocks on the car that you're driving which we're passengers in.
Tristan Roberts
RepresentativeVermont House of Representatives
LEEDuser Expert
11475 thumbs up
August 11, 2011 - 9:58 am
Bill, for those of us reading this forum who get the car metaphor, but don't know anything about BUG ratings, is there any chance you could summarize your key suggestions here in easy-to-grasp terms? Maybe if you win over a few observers, USGBC will be more inclined to listen.
Bill Swanson
Sr. Electrical EngineerIntegrated Design Solutions
LEEDuser Expert
731 thumbs up
August 11, 2011 - 10:57 am
BUG stands for Backlight-Uplight-Glare. It was made by IES and now being used by Darksky as a basis for cities to use as ordinance language. The IES does not accept public comments.
- Uplight should only include uplight.
- Glare should be measured at our eyes, not as some total output from half of the fixture.
- Glare should have 2 levels, city and rural. The 5 makes this system confusing.
- Spill light should be measured where it's annoying, at the neighbor's window, not in their parking lot, lawn or on the public street.
- If you control uplight most of the spill light will also be controlled.
- Ignore the 50W MH lamp used to light the flag pole. It's not that big of a deal.
- There's nothing in the BUG rating that prevents multiple "compliant" fixtures from being installed on a single pole, creating a non-compliant situation.
- Use absolute values to define lighting zones. Fluffy text allows the Reviewer to say you're in LZ2 this year, regardless if it was LZ3 last year. We have to know what the design limits are before things are bid, not halfway thru construction.
- The best ordinance I've seen to limit light levels in an urban area said no more than 10.0 fc at any point on the ground in the project. While it seems high, the average light level was typical. And I could tell the Owner no more lights can be added to these poles or we'll violate the ordinance. A simple rule is much more effective then a complex system that can be gamed. But you need to know what is typical and what is reasonable. Picking numbers out of the sky helps no one.
- Make the handbook useful. It does nothing but make test questions for the AP exam. Look how long some of these threads are with people's questions. LEED is getting too complex even for a several hundred page handbook to manage. KISS
Bill Swanson
Sr. Electrical EngineerIntegrated Design Solutions
LEEDuser Expert
731 thumbs up
August 12, 2011 - 9:22 am
Chrissy,
After fishing around the web for a couple hours I finally figured out what you’re referring with the uplight. In the late Spring of this year, IES issued a revision to this TM-15 standard that changed the uplight rating to only include uplight. Wonderful.
However, LEED is still referencing the old 2007 version of TM-15. So the uplight problem has not been corrected. The problem is that we’re in the 2nd phase of comments. If I submitted a comment saying the new 2011 version of TM-15 should be referenced I can predict the response.
“Thank you. The proposed change is not within the scope of this phase of development.”
Since that text hasn’t changed between Public Comment 1 and 2 it is not open for discussion any more.
The format of these Public Comments doesn’t work. Errors are being ignored. Legitimate comments are dismissed. This is just one item on one Credit. These problems are rampant thru the entire LEED system. Everyone is racing around doing busy work but hole keeps getting deeper. The system for updating LEED needs to change. Maybe it should be something like this where it’s a dialog.
Glenn Heinmiller
PrincipalLam Partners
96 thumbs up
August 21, 2011 - 6:04 pm
Bill,
A few comments. (I'm not speaking for the USGBC, but as an Subject Matter Expert who was involved with SS8 development.)
The referenced standard for the credit will be revised to be IES TM-15-11 and the BUG values will be checked and adjusted if necessary to match the published version of the IES/IDA Model Lighting Ordinance 15 June 2011. This "final" version of the MLO and the revised TM-15 were not available at the time the 2nd PRD version of SS8 was being put together.
The BUG system was included in order to start to bring SS8 closer to the IES/IDA Model Ordinance. The MLO is now the benchmark standard for light pollution control from those two organizations, Lighting designers would prefer to have one consistent standard to comply with if possible. The other advantage of the BUG system, and perhaps most important, is that it allows compliance without any computer modelling. The LEED 2009 methods still exist as an optional path for those who prefer this method.
To your comment: "Glare should have 2 levels, city and rural. The 5 makes this system confusing."
In practice, amost all LEED projects will fall into LZ 2 and 3 if zones are applied correctly. The LZ definitions we are using are from ASHRAE/IES 90.1-2010 because we use 90.1 LPDs to limit exterior light output, thus avoiding an additional separate calculation (you have to do it already for EA prerequisite compliance). Since 90.1-2010 is the energy performance reference standard for LEED and part of the EA prerequisite, we need to use those definitions.
Your comment: "There's nothing in the BUG rating that prevents multiple "compliant" fixtures from being installed on a single pole, creating a non-compliant situation."
Correct, nor is there anything that prevents you from putting 20 poles 2 ft. apart. BUT remember that your LPDs are going to limit you at some point, plus of course the economics of having more poles than you need. And common sense. The advantage of BUG is its simplicity, but that does lead to this quirk.
Bill Swanson
Sr. Electrical EngineerIntegrated Design Solutions
LEEDuser Expert
731 thumbs up
August 22, 2011 - 8:24 am
I am frustrated because this entire credit is not open for comments. Because we have to align with a brand new, untested system. As a LEED user I'd rather have input as USGBC swears we all do. USGBC should highlight this entire Credit and others during Public Comments saying "No comments accepted" so I and other don't waste our time.
ASHRAE 90.1-2010
LZ2: Areas predominately consisting of residential zoning, neighborhood business districts, light industrial
with limited nighttime use and residential mixed use areas.
LZ3: All other areas.
This is confusing for a definition, and will lead to much frustration. LZ2 could be twisted to mean 90% of locations. At least Title 24 has this based on population data from the US Census. No gray area there. I'd rather have that if you must align with something. LZ4 is also vauge, nothing to stop a local official in a town of 10,000 people from granting written permission that this site is acceptable as LZ4.
Glenn Heinmiller
PrincipalLam Partners
96 thumbs up
August 22, 2011 - 3:08 pm
Bill,
I agree that LZ definition is critical and I think that USGBC needs to enusre that these definitions are elaborated and clarified in the Ref Guide and in instructions to GBCI reviewers. There is some mismatch between the 90.1 definitions and the MLO defintions (see MLO user guide on left side pages) and I think that this needs to be looked at for SS8. But I', concerned about not using the 90.1 defintions as a base. It would be very confusing to have two different sets of definitions for LZs in LEED, one in SS and a different one in EA (90.1-2010), wouldn't it?.
Personally I think the T24 definitions are bogus. You can have a city of 100,000 that can have quiet residential areas or park and within it. In fact the old LEEd 2.2 LZ definitions had pop size in the LZ4 definition of + 100,000. I had a reviewer tell me that my university project (clearly LZ3) could be LZ4 because it was in a City of +100K !!
Thanks for bringing this issue of LZ defintions up. It's alwasy been lurking there and probably needs some more work.
Bill Swanson
Sr. Electrical EngineerIntegrated Design Solutions
LEEDuser Expert
731 thumbs up
August 29, 2011 - 11:02 am
If something needs work then let's fix it now. And if we fix it in SSc8 then we can fix it in EAc1. Who says we are beholden to the MLO or 90.1? Let's be an example and make the MLO play catch-up. Are the TAG members serving the best interest of USGBC or of the IES?