It has always been my understanding, underscored by the LEEDuser LEED EBOM reference above in the Birdseye narrative, that an NC project could achieve an ID credit by complying with an EBOM credit. We have done so in the past by complying with the MR4 EBOM credit for low mercury lamps.
The compliance threshold used to be 90 picograms of mercury per mean lumen hour. Then it was lowered to 70 picograms to reflect v4 thresholds. Now when I look at the Innovation catalog for my LEED 2009 project, it says that to get an ID credit via EBOM MR4 we would have to not just comply but meet the Exemplary Performance level of 35 picograms per mean lumen hour.
It seems unreasonable to me to require not only compliance but Exemplary Performance compliance with a LEED v4 credit for my LEED 2009 project. And it breaks with the rationale that the project is achieving an ID credit for complying with a credit borrowed from another system. Is it now the case that a project needs to reach an Exemplary Performance threshold of a borrowed LEED v4 credit to achieve 1 ID pt? If true, when did that happen? If only true of EBOM MR4, why? Can anyone explain this?
Helen Kessler
PresidentHJKessler Associates
51 thumbs up
October 31, 2017 - 12:11 pm
This is not only a great question, I find it curious that they even require this for LEEDv3 projects that were registered years ago.
emily reese moody
Sustainability Director, Certifications & ComplianceJacobs
LEEDuser Expert
475 thumbs up
October 31, 2017 - 12:31 pm
I'm not sure of the exact date that they moved it to the innovation catalog and updated the requirements, but it has been there for a little while now, anyway. I have earned this credit numerous times in the past b/c so many of our projects now are all LED anyway, or pretty close to it. Yes, you do have to meet the exemplary threshold to earn it as an ID credit, and yes, they do expect this level of compliance even for super old v3 projects. I don't agree with it; I think it should be held to whatever requirement was in place at the time of registration. It means you have to be psychic with all ID credits to just know that certain strategies have changed, or you have to go through the pain of submitting it using the former version and be told by reviewers that it has changed. This is how I first found out.
The good news is that I have submitted this version twice now and had it approved with no comments, and they no longer require that you submit cut sheets for comparable fluorescent fixtures to prove that your LED ones are better. That made an enormous difference in the amount of time it took to document this strategy.
Courtney Royal
Sr. Sustainability ConsultantTaitem Engineering
50 thumbs up
October 31, 2017 - 12:49 pm
hi emily, your comment was very helpful to me. i am about to submit a LEED-CI v3 project ID credit using all LEDs in the project. I was under the assumption i was going to deal with the comparable flurorescent fixtures cut sheets, etc., but seems you've had success otherwise. What did you include in your submittal? - LED cutsheets, lighting schedule? Thanks!
Helen Kessler
PresidentHJKessler Associates
51 thumbs up
October 31, 2017 - 6:59 pm
Emily, thanks for your comments - very helpful. For everyone else, I have long submitted LEDs without all the back-up - I have actually not even included them in the calcs since the LEDs only make the calcs look better. It appears that a current reviewer may be asking for it, and I am hoping to be able to sway them away from that requirement. I also did not realize that we are now required to use the EB-OM exemplary performance criteria for ID credits. The comments I received only said 35 picograms without saying where that number came from. Thank you everyone for your comments!
emily reese moody
Sustainability Director, Certifications & ComplianceJacobs
LEEDuser Expert
475 thumbs up
October 31, 2017 - 7:07 pm
Hi Courtney,
Our most recent submittal included our lighting plan, schedules, and submittals (our project timeline was extreme, and a few changes occurred between the drawings and construction), and the purchasing calculator provided in the "Resources" section of the Innovation Catalog page for this credit. For the calculator, we only filled in the "Lamps" tab, since we were not an EBOM project, and the rest of the tabs did not apply.
Brian Salazar
President, LEED AP, WELL APEntegra Development & Investment, LLC
56 thumbs up
February 21, 2018 - 9:22 pm
Hi all - I recently have come across this new threshold and documentation requirement as well. The LEED OM Resource Calculator is the tool that the reviewers are now requiring that we submit in order to meet this credit. I have found that with a little research, the LED lumens, life span, and mercury content (usually 0) can be plugged into this form with a favorable result.
I do have two of my own questions, however:
1) Is this credit still viable under LEED v4?
2) Does a project still have to have at least one mercury containing bulb/lamp in order to qualify?
Thanks!
emily reese moody
Sustainability Director, Certifications & ComplianceJacobs
LEEDuser Expert
475 thumbs up
February 22, 2018 - 12:42 pm
Hi Brian,
1) Yes, you can find the criteria in the credit library under NC v4: https://www.usgbc.org/credits/new-construction/v4/innovation-catalog
2) Nope. I've submitted a few projects now that were entirely LED.
Michelle Rosenberger
PartnerArchEcology
522 thumbs up
February 22, 2018 - 5:17 pm
Hi all,
FYI, I've been told by reviewers that projects with 100% LED lamps can just submit the lighting schedule and do not have to fill out the calculator.
emily reese moody
Sustainability Director, Certifications & ComplianceJacobs
LEEDuser Expert
475 thumbs up
February 22, 2018 - 5:28 pm
Oooohhhh, sweet.
Roxanne Button
Architect & Sustainable Design Consultant, AIA, MRAIC, LEED APDesign Synergies Architecture
65 thumbs up
December 5, 2018 - 11:37 am
I'm just about to submit this for an ID credit on an NC-V2009 project. Glad I found these comments. Thanks, Emily!
Edgar Arevalo
Associate19 thumbs up
September 27, 2019 - 10:22 am
Real quick, does anyone have a sample or template for just the lamp purchasing plan? I feel like the plan shown in the environmental purchasing policy isn't enough.
Edgar Arevalo
Associate19 thumbs up
October 1, 2019 - 10:11 am
Hi Emily,
What should typically be included in the lamp purchasing plan? I used the lamp section from the environmental purchasing policy found in the EB-OM resources, but I feel it may not be enough. Did you use a certain template to generate the plan?
emily reese moody
Sustainability Director, Certifications & ComplianceJacobs
LEEDuser Expert
475 thumbs up
October 1, 2019 - 9:25 pm
Hi Edgar,
Look under the Innovation Catalog for this strategy here: https://www.usgbc.org/node/5318467?return=/innovationcatalog/new-construction/v2009
Click on the Resources button at the top under the credit name. The tool provided there is the only calculator you have to submit, and you only need to populate the "Lamps" tab within the file.
You don't have to submit an actual purchasing plan, only show with your uploads what the design has via a lighting schedule / cut sheets and fill out the calculator as appropriate.
Edgar Arevalo
Associate19 thumbs up
October 2, 2019 - 9:54 am
Ohh, ok. Well that's a relief to not provide the purchasing plan. If the cutsheets with the completed calculator are enough for compliance that's even better cause the lighting schedule does not cover every luminaire, only the base building lighting fixtures. Thank you so much Emily!!
Lyle Axelarris
Building Enclosure ConsultantBPL Enclosure
64 thumbs up
July 7, 2021 - 6:16 pm
Since we now have to meet the exemplary performance threshold from EBOM, does it count as one of the 2 allowable exemplary performance points (when you use this credit on an NC project) ?
emily reese moody
Sustainability Director, Certifications & ComplianceJacobs
LEEDuser Expert
475 thumbs up
July 8, 2021 - 12:42 am
Hi Lyle,
Nope, still just a regular Innovation credit, so it doesn't take up one of the two allowed EP spots.
Catarina Costa Goncalves
2 thumbs up
May 7, 2024 - 4:50 am
Is there any exemptions? For example emergency lights?
Justin Southwick
BuildingsGreened9 thumbs up
June 19, 2024 - 5:43 pm
Catarina,
I've had 2 scenarios where reviewers have not rejected my analysis of weighted mercury content in lamps where I excluded some "special use" lamps: 1) excluding all Exit signs, and 2) excluding a single mercury-containing light fixture in an elevator sump area (this light would only be used when someone was servicing the elevator sump area) among ~100 other fixtures in the building. So, the definition of "emergency" and/or the function of your lights during an "emergency" might be operative here.
For example, my design teams usually specify some of the lights in a space with an "E" suffix and with emergency backup power. During a power outage the battery backup will keep this subset of fixtures on for a safer "emergency" exit of the space. During normal power conditions these light fixtures are also powered on for normal use of the space. Because of the dual function of the same light fixture, I would think you could NOT exempt those fixtures even if they have an "emergency" function.
The intent of the Credit is a "reduction program to reduce the amount of mercury brought into the building". So, intentionally bringing in or keeping existing lamps containing mercury seems to contradict the Intent, whatever their function.
The v4 Reference Guide only allows the following Lamp Exclusions for the "Healthcare: PBT Source
Reduction—Mercury Credit": "Operating rooms, dental treatment rooms, dental labs, and other spaces in medical military facilities may require lamps with very high CRI and color temperature to comply with UFC 4-501-01. If the prerequisite criteria and UFC 4-501-01 conflict, affected lamps may be excluded from the prerequisite. If the prerequisite criteria and local code or regulations conflict, affected lamps may be excluded from the prerequisite. Retain a copy of the local code that conflicts with the prerequisite criteria."
Additionally, the chance that the mercury presents a risk as a biocumulative toxin may be a factor. For example, in the same Healthcare Credit "lamp" is defined as "a device emitting light in a fixture, excluding lamp housing and ballasts. Light-emitting diodes packaged as traditional lamps also meet this definition." It's my estimate that any mercury in a housing or ballast (e.g. mercury vapor lamp systems) is much less likely to escape into atmosphere while mercury inside a lamp (e.g. Tx linear fluorescent) can easily escape if the lamp glass breaks. Relatedly, I would estimate the v4/v4.1 Storage and Collection of Recyclables requirement to provide safe disposal of mercury-containing lamps is targeting the same potential of release of the mercury from broken lamp glass.
I'm not suggesting that a reviewer won't allow some exemptions, but I would think you would need to explain how the Intent is not compromised by the exemption.
Good luck.