My name is Richard Curry, and my comments represent the views of ST Facility Maintenance Consulting, LLC, a facility service consultant to owners and operators of commercial cleaning companies. My comments are in regard to the Proposed LEED O+M: Existing Buildings v5 draft. Specifically, my comments address the Green Cleaning and the Equity Within Operations and Maintenance Staff elements. I am deeply concerned after having 31 years of direct management experience of large cleaning systems with two of the largest Facility Maintenance companies in the world that the standards are being diluted and the work of many years is being devalued in respect to the LEED certification platform. In addition, I am concerned that the impact of COVID-19 on the industry and to real estate is not being properly considered and I am equally concerned that the standards proposed in these revised elements are a setback for the entire global cleaning industry and understates the importance of cleaning to protect occupant health and wellbeing. (Consider COVID-19, again). My recommendations are as follows:
- Restore the Prerequisite: • The draft has deleted the prerequisite and has not integrated those critical program management requirements elsewhere into the Rating System. Appropriately managing the cleaning process, use of products and equipment, strategies to reduce energy and other resources, training and contingency planning for workers, education on handwashing and other issues are essential to protecting occupant health and wellbeing.
• Recommendation: We recommend the Prerequisite be restored to ensure that organizational, planning and training standards be required of all facilities seeking LEED certification. These requirements are particularly critical to successful cleaning programs. Weighting – Cleaning is undervalued • Overall, too few points are allotted to Green Cleaning programs, particularly in comparison to other program/building attributes. While 3 points may be appropriate during construction, it undervalues the importance of cleaning (after the building is occupied) and the need to protect occupant health and wellbeing.
Recommendation: We recommend increasing the credits for Green Cleaning to 10 points and using the additional points to incentivize a level of thorough cleaning that will reduce risks to occupant health while improving their productivity and wellbeing We respectfully request that USGBC seriously consider these comments and update the proposed standard to better meet the needs of the global cleaning industry.
- In Regard to the Equity within Operations and Maintenance Staff Section. First observation - The social equity element is not tailored to the needs and working conditions of cleaning personnel, landscapers, pest applicators, parking attendants, and other employees and contract workers in the building. Second observation – There are few Industries in the world that have practiced egalitarianism, social equity and workplace integration than the commercial cleaning business. The industry has provided opportunities for disparate migrant, ethnic, marginalized and lower economic status individuals for decades and this fact is not acknowledged by this revised standard.
Recommendation: The social equity requirements in the Prerequisite should be better tailored to address the needs of cleaning teams, including but not limited to fair wages, gender discrimination, working conditions, injury and illness prevention, opportunities for advancement, etc.
Recommendation: The social equity requirements should also encompass safety provisions for cleaning personnel and be more effectively tailored to meet the needs of cleaning and other contracted workers. This includes addressing wages, production rates, hours, benefits, injury rates including ergonomic injuries, tenure of frontline workers, worker insurance, immigration status, encouraging the hiring of people with disabilities and other marginalized people, etc.; in addition to the typical social equity concerns (e.g., no child or slave labor). We respectfully request that USGBC seriously consider these comments and update the proposed standard to better meet the needs of the global cleaning industry
Tendered Respectfully
Richard Curry
Principal – ST Facility Maintenance Consulting, LLC.
Elliott Meadow
May 21, 2024 - 3:33 am
Richard Curry, representing ST Facility Maintenance Consulting, LLC, expresses concern over the Proposed LEED O+M: Existing Buildings v5 draft, particularly focusing on Green Cleaning and Equity Within Operations and Maintenance Staff elements. With 31 years of experience in managing large cleaning systems, Curry believes the standards are being diluted, devaluing years of work. He asserts that the impact of COVID-19 isn't adequately considered, and the proposed elements may setback the global cleaning industry. He recommends restoring the Prerequisite and increasing points for Green Cleaning. Regarding Equity Within Operations and Maintenance Staff, Curry suggests tailoring social equity requirements to address the needs of cleaning personnel and other contracted workers. He urges the USGBC to seriously consider these comments to better meet the industry's needs.
Brent Ward
May 21, 2024 - 1:47 pm
These comments represent the observations of Left Coast Facilities Consulting, a firm that helps businesses become sustainable, helps them get green certifications for their existing building and partner with firms that help get green certification for new construction.
This is supposed to be a performance standard for existing buildings, but misses the mark on the operations of the building, focussing too much on non operational things. Transportation has nothing to do with the building of its operations. Green cleaning is a bigger factor, but has fewer points.
Comment 1:
Location and Transportation (LT) – Public Comment Draft, Page 10
Granted a maximum of 10 points, this credit category is overweight, given that an
existing building has no control over its location and minimal control over
transportation alternatives. The Transportation credit/points unfairly benefit urban
areas with robust public transportation infrastructure. Rural areas typically do not
yet have low-carbon transportation options or pervasive electric vehicle charging,
which puts these points out of reach. The most transient element of a building is its
occupants, so an Occupant Travel Survey has minimal longevity. As indicated, an
existing building has no control over its Location-efficiency Score. As transportation is
largely external to the actual subject of the rating, the building itself, this credit
category should be allocated no more than 5 to 7 points in total.
Comment 2:
Sustainable Sites (SS) – Public Comment Draft, Pages 14 & 8
There are no basic concerns with the Sustainable Sites credit category, as the
credit/points are all within the building sphere of control. The credit category may
be underweighted at 2 points. Rainwater Management, Heat Island Reduction and
Light Pollution Reduction all provide long-term benefits, and perhaps an increase in
points would provide a more significant incentive to pursue this credit/points. This
category fails to acknowledge the operation labor force required to maintain
stormwater systems and landscaping. Two (2) points allocated to prerequisites for
Equity Within Operations and Maintenance Staff is insufficient.
Comment 3:
Water Efficiency (WE) – Public Comment Draft, Page 17
From an operations perspective, we believe the Water, Energy, Waste and IEQ credit
categories should have a more balanced point allocation. With increasing concerns
over access to fresh water, the Water category should carry a higher point value to
incentivize greater water efficiency and performance. Many climate risks threaten
access to, or pollution of, available freshwater supplies – yet the resilience
strategies barely address freshwater access. The credit/points should emphasize
overall water efficiency rather than simply measuring wasted water. The
credit/points should be increased from 14 to 20 and reevaluated to provide more
recognition of water efficiency in addition to water use intensity.
Comment 4:
Energy and Atmosphere (EA) – Public Comment Draft, Page 19
While Energy is an important credit category, it is overweighted from an operations
perspective. Many points are allocated to transactional/one-time events such as
Decarbonization & Efficiency Plans or Renewable Energy. When measuring
performance year over year, why would we continue to allocate the same
credit/points to these items? Moving forward, decarbonization will become
increasingly dependent upon the adoption of circular economy principles (see:
Materials and Resources). Simply having policies and plans is no guarantee of
ongoing performance; so, LEED EB should emphasize actual performance over
policy intent. The prerequisites for Energy, Carbon and Operational Foundations are
acceptable, but the allocation of 37 points to this credit category is overweight. The
credit categories should be reevaluated to emphasize measurable performance
over documenting plans or future state activities, such as grid interactivity for which
no reliable timeline is available. The Energy Performance and Commissioning credit
should focus on rewarding continuous commissioning technologies (persistent,
real-time monitoring) over transactional, one-time events such as traditional
commissioning or retro-commissioning processes. While EA is a vital category from
a decarbonization perspective, it should be allocated no more than 25 points.
Comment 5:
Materials and Resources (MR) – Public Comment Draft, Page 42
This credit category is underweighted from an operations perspective. More
attention should be focused on adopting circular economy principles over simple
waste disposal strategies. The shift to a circular economy requires rethinking,
retraining, reframing and re-educating. The three main principles of the circular
economy are: 1) eliminate waste and pollution; 2) circulate products and materials
at their highest value; and 3) regenerate nature. The Embodied Carbon of Interior
Materials During Renovation points fail to recognize the substantial embodied
carbon associated with all materials/consumables used in day-to-day operations.
This category needs more incentives to address carbon and waste incurred in daily
operations. The 9 points allocated to this credit category should be increased to 20.
The credits should be reevaluated to incorporate more recognition for materials
and supply chain management in operations in addition to waste disposal.
Comment 6:
Indoor Environmental Quality (EQ) – Public Comment Draft, Page 45
While the total of 20 points for this category is adequate, it is overweighted toward
the Indoor Air Quality Performance and Occupant Satisfaction Survey. How much
weight should an occupant satisfaction survey place on indoor environmental
quality when most occupants do not have a solid understanding of the elements
that make up environmental quality? While Indoor Air Quality is certainly one of
those components, it is overweight for this category from an operations
perspective. More recognition is needed for Green Cleaning and Integrated Pest
Management as ongoing operational contributors to IEQ. Green Cleaning is an equal
contributor to IEQ by ensuring a pollution-free indoor environment and minimizing
bacterial, viral and other contaminants that threaten occupant health year over
year. Likewise, Integrated Pest Management minimizes threats from disease-bearing
rodents and insects. It is suggested that Indoor Air Quality be allocated 9 points,
Occupant Satisfaction Survey be allocated 1 point, Green Cleaning be allocated 5
points, and Integrated Pest Control be allocated 5 points. This leaves the category
point total unchanged at 20.
Comment 7:
Project Priorities & Innovation (IN) – Public Comment Draft, Page 59
The term “Project Priorities” implies transactional activities. There is no recognition
of operational activities. As this credit category represents an opportunity for an
additional 10 points, it should be balanced between Project and Operational
Innovations. As written, the credit/points give no acknowledgment or options for
innovations in operations. The options for this category should be reevaluated to
allocate at least half of the credit/points to operational innovations.
Krista Maylin
May 22, 2024 - 4:49 am
Richard Curry, from ST Facility Maintenance Consulting, LLC, is worried about the latest draft of LEED O+M: Existing Buildings v5. He's particularly concerned about the Green Cleaning and Equity Within Operations and Maintenance Staff sections. With over three decades of experience in managing large cleaning systems, Curry feels the proposed standards might undermine the value of years of hard work. He thinks the draft doesn't fully account for the impact of COVID-19 and could potentially harm the global cleaning industry. Curry suggests reinstating the Prerequisite and giving more points for Green Cleaning. As for Equity Within Operations and Maintenance Staff, he proposes tailoring social equity requirements to better support cleaning personnel and other contracted workers. He urges the USGBC to seriously consider his feedback to ensure the draft aligns more closely with the industry's needs.