LEED v5 O&M Existing Buildings public comments

In WE Credit: Water Performance, Path 3. Process Water Use, Case 2. Optimize Water Use for Cooling, " To be eligible for Case 2, the baseline system designated for the building using ASHRAE 90.1-2016 Appendix G Table G3.1.1 must include a cooling tower (systems 7, 8, 11, 12, and 13). " 
But the current implementation standard is ASHRAE 90.1-2022, Appendix G Table G3.1 (systems 7, 8, 10) is about HVAC systems, and need to update this section?

Did I miss something? 

Initial thoughts about the Green Cleaning requirement: It does not include the specific criteria for dusting, dust capture from routine processes, which is arguably one of the most important indicators of effective cleaning. Airborne dust contains a host of undesirable elements and so "effective dust capture methods" should be included as a separate line item.  Since air is the main path for harmful exposure, dust control methods should be primary and worthy of "points"...

Also, re: disinfection devices, dry steam vapor machines produced at "EPA registered establishments" have disinfection properties and should be included.

In LEED-OM v.5 (draft), no information was provided on re-certification. However, under LEED-OM v4.1, 10 "bonus points" were offered for recertifying previously certified projects. This has allowed a project's certification level to be bumped up from, say, Gold to Platinum even when its actual score has dropped. The result is a misleading score that inflates actual performance, and erodes the validity of the certification. What could possibly be the logic for that?

This comment pertains to LEED-OM Recertification.  In LEED-OM v.5 (draft), no information was provided on re-certification. However, the Feb 2024 version of LEED-OM v4.1 does provide guidelines for recertification and explain the scoring of recertification points. "4. Recertify" on page 8 states: "To keep your certification active... you will need to provide data annually. This data is entered in the same manner as your recertification, but it is not reviewed by GBCI." Apparently, the data is not reviewed by GBCI but outsourced to Arc, "the platform for managing recertification." Arc scores 5 categories of data: energy, water, waste, transportation and "human experience" - of which the last two categories are performed by surveying "all" occupants. How do Arc scores correlate with the 7 categories of LEED scores, especially "human experience", which does not correspond to any LEED category? What are Arc's data quality standards? Who conducts their surveys and vetts their results? In short, what quality control measures have been put in place to ensure that recertification is not just a rubber-stamping, fee-generating exercise for USGBC?

Regarding scoring for recertification, page 12 notes that "Prior LEED Certification" automatically qualifies for 10 points under the Innovation category. How is prior LEED certification an innovation? It is not. It is a sham - a calculated measure to award bloated scores and thus attract more recertification revenue. 

In conclusion: (a) Please consider removing the automatic 10 bonus points for prior LEED Certification; (b) please provide more transparency over LEED's partnership with Arc Scoru, correlation of Arc scores with LEED-OM recertifcation scores, Arc's scoring methodology, data quality standards, and oversight standards. 

Hello! 2 questions:

From the "LEED-v5-OM-Existing-Buildings-Public-Comment-1.pdf" file: 

1) will data centers be recognized as a Building Category Classification? (Appendix I)

2) when considering v5, will there be energy-related exemptions for on-site for fuel-combusting emergency power generators? (for routine maintenance, emergency operations, and factors related to government-declared states of emergency such as wildfire response). Such an exemption is mentioned in Appendix II for LEED Zero, but I could not find it elsewhere throughout the PDF. 

Thanks!

Project Priorities & Innovation (IN) – Public Comment Draft, Page 59 -  “Project Priorities” this seems to be transactional activities and there is no recognition of operational activities. Would like to have an equal credit for innovations in operations. New design aspirations are great, but O&M is the daily responsibility that tends to get overlooked. Point opportunity will help to get the exposure and funding necessary to innovate.  

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.

I’m very disappointed to STILL see no LEED credit address moisture management in building envelope design.  As our industry is adding continuous insulation (for good reasons), there are more and more buildings suffering from the unintended consequences of trapped moisture due to a lack of proper hygrothermal analysis during design.  This is especially common for energy retrofit projects, often associated with LEED O+M. This impacts energy efficiency (wet insulation = bad insulation), material durability (wet material gets replaced more frequently), and indoor air quality (mold), and yet LEED is still completely silent on the topic of good building enclosure design.

Managing moisture through good BE design is not covered in other credits (wet insulation is not accounted for in energy models, material credits or IEQ – construction moisture management is different than what I’m talking about). 

To address this critical issue, there should be a credit (in MR or IEQ) that simply requires compliance with ASHRAE 160 for all above-grade wall and roof assemblies that cover at least 10% of their respective assembly type’s total surface area. ASHRAE 160 assesses the Mold Index value (predicted mold growth) of the critical material layers in a building enclosure assembly, and is considered the industry standard for hygrothermal analysis. It is very possible to meet IECC/ASHRAE 90.1 U-factor requirements and IBC 1404.3 vapor retarder requirements but still grow mold in walls - this is where ASHRAE 160 comes in to play, and it is also where LEED should come in to play.

EA Grid Interactive Credit - Option 1, Path 2, Air Tightness:

(1) Table 2, footnote 1: There's been some confusion in the industry regarding (a) "building envelope" vs. "air barrier" and (b) the test boundaries of a whole building air leakage test (WBALT). WBALT is testing the airtightness of the complete air barrier system, which is on all "6 sides" of the building, including the roof and base floor/slab.
(a) The "building envelope" is an assortment of connected layers of materials embedded in assemblies that enclose the entire building and control air, water, thermal and vapor diffusive flows through the enclosure. These assemblies are often thick and sometimes have control layers that are widely separated from one another (eg. water control at the roof, air/thermal control at the ceiling in traditional attic construction). Since the WBALT is testing only the air control layer (air barrier) and not the entire "envelope," it is important to specify that the surface area to be measured is the "air barrier," not the "building envelope."
(b) Since the air barrier needs to be designed and constructed to control air leakage across the entire building enclosure (all six sides), it should be clarified that the surface area to be used in airtightness calculations is all six sides of the enclosure (including base floor/slab). There's some historical confusion about whether or not to include the slab, so it is worth explicit inclusion in the reference guide.
In order to avoid confusion and reinforce the intent of air leakage testing, I recommend the following changes to this footnote:
"Air leakage per ft^2 or m^2 of air barrier surface area, including "all six sides" of the building (roof, exterior walls, and base floor/slab)"

(2) Table 2, buildings < 5,000 ft^2: It's not clear why smaller buildings would be required to use the ACH50 testing metrics. For commercial designers, contractors, testing agencies, and institutional owners, cfm/sf @ 75 Pascals is the common metric. Can the standard commercial metric be added as an option for these smaller buildings to maintain a consistent standard of airtightness in the commercial construction industry?

EA Grid Interactive Credit - Option 1, Path 2, Low Envelope Thermal Conductance, second bullet point:
Is the "historical total building envelope UA" based on the latest version of ASHRAE 90.1 at the time that the existing building was designed (but no more than three years prior to project registration)?
Does this credit require any alterations, or can it be achieved if the existing building envelope UA is already 30% better than some "historical" standard?