In my opinion, LEED 2009 incorrectly categorizes primers. I know that the table issued with the 4/14/10 addendum clearly lumps primers into the GS-11 requirements. This I don’t understand. In fact GS-11 makes no reference to primers at all. The only place that regulates primers in the LEED-referred material is SCAQMD Rule 1113.

Clearly primers are formulated for a different purpose than topcoats, which is abundantly clear in GS-11 topcoat requirements. R-1113 defines primers quite adequately as “coatings applied to a surface to provide a firm bond between the substrate and subsequent coats”.

So why has LEED removed it from the R1113 "primers, sealers, and undercoaters" category and forced it into the GS-11? This also then bases their VOC limit on whether they flat or non-flat, which has nothing to do with the function of a primer.

Has anyone challenged the USGBC about this?