In response to growing concerns from the market, USGBC is postponing plans to ballot the next version of LEED until 2013.

In a surprise move, the U.S. Green Building Council (USGBC) announced today that it is postponing plans to ballot the next version of LEED until as late as June 2013. With this announcement, USGBC promises to keep LEED 2009 available for a full three years from now, although it intends to gradually ramp up incentives for teams to move to the new version of LEED during that time.

The move came in response to a growing outcry from architects and other building industry professionals—including many who have been core supporters of LEED since its inception—who had three related concerns:

• The proposed changes in the rating system were too much, too fast, especially in a weak real estate market.
• Some of the changes needed more refinement , especially in the Materials & Resources category, where whole new approaches to material selection had been introduced and had changed significantly with each public comment draft.
• Tools and resources needed to achieve the credits would not be widely available by the time the new system was slated to launch in November 2012.

Compounding these concerns were doubts about the ability of USGBC’s sister organization, the Green Building Certification Institute (GBCI) to develop an effective certification process in such a short timeframe—fears that linger after the release of LEED 2009, which was marked by an ill-fated attempt to outsource the certification process to third-party certification bodies and glitches that marred the usability of LEED Online.

LEED users conveyed their concerns directly to USGBC staff and board members, expressed them in formal comments on the various drafts, and debated them on the LEEDuser forums, where Robert Watson of EcoTech International, founding chair of the LEED Steering Committee, argued vehemently for a more measured approach to changes in LEED.

No longer tied to a particular year, USGBC is also reverting to a version naming system for the rating system, so the new version will be called “LEED v4” instead of “LEED 2012.”

Even as it frustrated the many volunteers on the LEED committees who have labored for years on many credits in the proposed draft and are anxious to see them introduced to the market, the new announcement was celebrated by many practitioners in the industry.

”It is gratifying to see that an organization that is nearly twenty years old with 15,000 member organizations still can as be nimble and responsive as the start-up we remember,” noted Russell Perry, FAIA, vice president and office director at SmithGroupJJR. “The Council heard many of its members when we said that we were going to need some time to test out the new ideas and make sure they worked in our markets.”

The committees have been anticipating these changes for a long time, after the decision with LEED 2009 to minimize technical changes and focus on the reorganization and weighting of the credit structure. As a result, the credit requirement changes in the proposed LEED v4 rating system are the most extensive in LEED’s twelve-year history.

The new announcement comes just a few weeks after USGBC had tried, with limited success, to allay these concerns by postponing the planned ballot from May 2012 to August and by promising to keep LEED 2009 available to project teams for at least six months after the introduction of LEED v4. At that time, USGBC had also announced plans for a “beta test” of the new rating system, but critics had questioned how such a test would be useful if the changes it purported to test were already locked in by member ballot.

The new plan gives time for that beta test to proceed while allowing for its results to inform a fifth public comment draft, which is scheduled to run from October 2 to December 10, 2012. That timeframe encompasses the annual Greenbuild Conference and Expo, allowing for in-person interaction among USGBC members and other stakeholders about the proposed changes.

USGBC asserts that language in LEED supporting the highest standards of forest certification and pushing for transparency and avoidance of chemicals of concern will not be watered down during this extended process, despite unprecedented attacks from the chemical industry, which recently joined the mainstream forest products industry in seeking to undermine LEED by pushing Congress to prohibit the federal government from using it.

Editor's note: USGBC has taken your comments and opened the fifth public comment period with the new draft of LEED v4 (note the name change from LEED 2012). Please post your thoughts on our LEED v4 fifth public comment forum!

The LEED 2012 fourth public comment period will be open from May 11 to May 28 (11:59 p.m. ET).

Information on the 4th public comment draft of LEED 2012 is available on the USGBC website.

LEEDuser's analysis of the current draft is below, and we encourage the LEED user community to post your analyses and opinions here in this forum. Here are some useful links:

• Summary of changes from 3rd to 4th comment draft - BD&C
• Summary of changes from 3rd to 4th comment draft - EBOM
• Summary of changes from 3rd to 4th comment draft - ID&C
• Summary of changes from 3rd to 4th comment draft - ND
• Summary of changes from 3rd to 4th comment draft - Homes

Under USGBC's process for development of the rating systems, any substantive changes must be followed by a comment period. This 4th comment period had not been planned—indicating that there are some noteworthy changes from the 3rd public comment period. However, any changes between now and the version that wil go out to ballot on June 1st are going to be superficial, making this comment period a warm-up for the balloting process.

LEEDuser's Analysis of the 4th Public Comment Draft

By Nadav Malin – LEEDuser

With a special fourth public comment period, USGBC is now—through May 28—seeking input on the latest changes to the LEED 2012 family of rating systems. Only credits that have changed significantly since the 3rd public comment draft are open for comments this time. If you haven’t been paying attention, it’s time to wake up, because LEED 2012 is by far the most fundamental revamping of LEED in its history.

LEED has been through several iterations since it was originally launched in March 2000. It has also spawned additional rating systems over the years—the LEED that started things off in 2000 was just for “New Construction and Major Renovations” (NC); LEED for Existing Buildings, Commercial Interiors, Schools, Retail, Healthcare, Neighborhood Developments, and Homes all came later. But most of those changes trickled in: one rating system at a time, and relatively minor changes to credit requirements from one version to the next. LEED 2009 gave LEED a new point structure, with all the rating systems on a 100-point scale (plus bonus points), but the actual credit requirements didn’t change all that much.

LEED 2012 includes a fresh look at credits across the board, and introduces the first more specialized versions of LEED for Existing Buildings: Operations and Maintenance (EBOM), with EBOM for Schools, Retail, Data Centers, Hospitality, and Warehouses. While many in the LEED community have complained that the changes are too much too fast, few would argue that most of the old requirements have gotten old and tired.

Responding to those concerns, however, the fourth public comment draft continues a trend of backing off on some of the proposed changes:

• The credit for electric vehicle charging stations and preferred parking has been reinstated in this draft, with minor adjustments.
• A distinction between heavy and non-heavy construction and demolition waste was deemed too difficult to track on the job site and has been removed from this draft.
• A requirement in the commissioning prerequisite to include building envelope commissioning was removed in an earlier draft, and now applies only to the credit.
• Minimum energy performance over ASHRAE 90.1-2010 was lowered from 10% to 5%, recognizing that 90.1-2010 is already about 20% tougher than 90.1-2007, making the cumulative change too challenging.
• An “angle of view” requirement that would have greatly restricted the indoor spaces that could count towards the views credit was eliminated.

Among the biggest changes in LEED 2012 are those in the Materials and Resources (MR) category. Even though this category carries relatively few points (about 10% of the total in most Building Design & Construction rating systems), it has the most direct impact on major building material markets with their associated economic and ecological impacts, so this category is a lightening rod for commentary.

USGBC has stuck with its strong commitment to the Forest Stewardship Council as the minimum standard for wood product certification. It has, however, backed off in this draft from a credit that included PVC—the plastic most widely used in buildings—among the substances to be avoided. That’s a function of a decision to reference the European REACH list for that credit. PVC remains among the substances that would have to be disclosed, based on the lists in Clean Production Action’s Green Screen Benchmark.

LEED 2012 introduces a more sophisticated approach to many of the materials credits, replacing simple proxies for environmental benefit, such as recycled content and rapidly renewable materials, with requirements that call for life-cycle assessment, disclosure of ingredients, and avoidance of problem chemicals.

These new approaches are challenging because tools and protocols for meeting these requirements are not yet widely available. USGBC is responding to this situation in several ways:

• Introducing a pilot projects program and extended phase-in period for all of LEED 2012, so that only project teams that want to knock themselves out pioneering these new practices have to do so;
• Pointing out that building commissioning and energy modeling were also not widely used when LEED began requiring them in 2000, so there is precedent for LEED creating this kind of infrastructure; and, to support that process,
• Offering credit in some cases for merely reporting on ingredients and LCA results, regardless of how good those results are. This approach amounts to a big vote for transparency and support for developing data sources and tools, in the hopes that future versions of LEED will be able to make use of widely available data to set rigorous thresholds.

While the methods are far from perfect, moving to include mining impacts in the mix, and introducing some filters to the old blanket endorsement of any rapidly renewable material, are clearly big steps forward. Similarly, in the arena of indoor pollutants from materials, USGBC has determined that the market is finally ready to move from documenting VOC content to measuring VOC emissions. An attempt to do that when LEED for Schools was released in 2008 proved premature, but I think we’re ready now.

Key changes in the the IEQ section of LEED-NC (part of LEED BD&C) in the third public comment draft of LEED 2012 are discussed below. Do you have comments or questions on this draft? Discuss them below with your fellow LEED professionals. Substantive comments submitted here during USGBC's third public comment period here will be submitted to USGBC and considered "official" public comments.

More information on LEED 2012 certification and the third public comment.

Minimum IAQ Performance, a prerequisite still references minimum ASHRAE-62.1–2010 requirements. In a change, outdoor air delivery monitoring requirements that had been folded into a consolidated credit are included as a prerequisite for all BD&C projects, not just CS.

Environmental Tobacco Smoke Control sees additional fine-tuning of requirements rather than any major change (such as absolute prevention of smoking). Non-smoking requirements extend to outdoor spaces used for business purposes, like patio seating.

The new Enhanced Indoor Air Quality Strategies credit retains its repackaging of key requirements from eliminated credits—Outdoor Air Delivery Monitoring, Increased Ventilation, and Indoor Chemical and Pollutant Source Control. With some minor language tweaks in this round, including adjustments for international projects, Option 1 in this new credit includes the key track-off, exhaust, and filtering requirements from LEED 2009’s IEQc5, and includes the key natural ventilation requirements that are part of IEQc2: Increased Ventilation in LEED 2009. Option 2 for this credit requires meeting Option 1, plus requirements that are similar to LEED 2009 requirements for increased ventilation over ASHRAE 62.1 and for outdoor air delivery monitoring. Those requirements are a bit more sophisticated, however, incorporating use of modeling (with new details in this draft such as specific mention of Computational Fluid Dynamics) to show that air contaminants will be below key exposure levels.

The third draft of LEED 2012 brings us a third major overhaul of Low-Emitting Interiors, although the overall systems approach introduced in the first draft remains. The system has changed, and now references seven relevant systems: paints and coatings; adhesives and sealants; flooring; composite wood; ceilings, walls, thermal and acoustic insulation; furniture (if in scope); and exterior-applied products, which is only relevant in Healthcare and Schools. In a change that is more like the first 2012 draft and LEED 2009, projects will now have to earn points by being compliant in one or more of these systems. A more sophisticated total percentage compliant score, more akin to the second draft, is available for projects that want to use a budget method. There are more specific requirements regarding manufacturers’ claims and standards for testing laboratories. As with the previous draft, product compliance is based on exposure limits defined in California Department of Public Health (CDPH) Standard Method V1.1-2010, often referred to as California Section 01350.

Construction IAQ Management Plan is back as a credit, not a prerequisite. It is unchanged from the last draft except for a European-friendly filtration reference, and what amounts to an enhanced environmental tobacco smoke credit for construction: “Prohibit the use of tobacco products inside the building and within 50 feet (15 meters) (or greater, if local jurisdiction requires) of the building entrance during construction.”

Indoor Air Quality Assessment is the new name for Construction IAQ Management Plan—Before Occupancy, and it hasn’t changed a lot sine the previous draft, in which the Option 1 flush-out path preferred by most LEED projects would be downgrade to one point, versus two points for Option 2: Air Testing. Changes in this draft appear to be minor and involve specifying ASTM and EPA test methods for various contaminants. Carbon monoxide has been added as a chemical to be tested.

The Thermal Comfort credit, which folds in the old design and control credits that were separate, has been updated with some wording changes and a new reference to ISO 7730, a more international-friendly standard.

The new Interior Lighting credit covers the scope of the LEED 2009 “Controllability of Lighting” credit, which falls under Option 1, while Lighting Quality can optionally be pursued for a separate point under Option 2. The changes in this draft are mostly minor, retaining specific emphasis on providing three lighting levels (or “scenes”) for individual and multi-occupant spaces: on, off, and mid-level. For lighting quality, projects would have a choice of meeting four quality measures, which are now in two categories: hardware and design. These measures include color rendering index (CRI) requirements and use of bright surfaces.

The Daylight credit, overhauled in the first draft of LEED 2012, is overhauled again here. The focus of the first of two simulation options is providing a new metric, Spatial Daylight Autonomy, defined as “the percent of aggregate floor area of regularly occupied spaces which achieves a minimum hourly illuminance value of 300 lux at task level for at least 50% of the hours between 8 a.m. and 6 p.m., local clock time, after accounting for typical weather conditions, exterior obstructions, attached furniture systems, and after blinds have been operated hourly to block direct sun predicted to enter the space that would fall on more than 2% of the calculation grid.” The second simulation option is not changed as significantly, whiel the third option, for measurement,  has gained specifics on how measurement should be performed, such as measuring twice, at diverse times of year. The first simulation option provides the most points in this draft, up to three, the second option offers up to two, while measurement provides only one.

The LEED 2009 credit on views became Quality Views in the first LEED 2012 draft, and thus it remains. The credit has wording changes in this draft, but nothing that appears significant. Occupants should be able to discern objects at least 25 feet outside the vision glazing; flora, fauna, or sky; and movement for quality views.

An Acoustic Performance credit was previously only available to Schools projects remains available to NC projects in this draft. Pprojects would have to achieve four specific acoustical objectives defined in the credit language, although one of these has been removed from the last draft: requirements for speech privacy. Vague language allowing historic renovation projects to justify design decisions outside of the credit requirements has been made more specific: three of four requirements must still be met, with a narrative explaining design decisions.

What's your take on the proposed changes? Please post your public comments below.

Key changes in the the MR section of LEED-NC (part of LEED BD&C) in the third public comment draft of LEED 2012 are discussed below. Do you have comments or questions on this draft? Discuss them below with your fellow LEED professionals. Substantive comments submitted here during USGBC's third public comment period here will be submitted to USGBC and considered "official" public comments.

More information on LEED 2012 certification and the third public comment.

With this third draft, USGBC delivers yet another gut rehab of the MR section. First, the more minor changes.

The Storage and Collection of Recyclables prerequisite now adds collection of batteries, mercury-containing lamps, and electronic waste.

Another new prerequisite, Construction and Demolition Waste Management Planning, gets a shift in focus. Rather than a 20% diversion minimum, the credit calls for a process shift in which a project would establish diversion goals, identify at least five materials targeted for diversion, detail diversion strategies, put in place specific contractor processes, and require reporting at the end. Alternative Daily Cover (ADC) would not qualify as diverted debris.

A new credit, Resource Reuse (changed from Environmentally Friendly Construction and Enclosure in the previous draft), would replace the former Building Reuse credit and incorporate Life Cycle Assessment (LCA). This lengthy credit includes four options, summarized in the table.

In general, credits for transparency and performance have been broken up since the last draft. The new credit Non-Structural Materials Transparency is gone, along with Environmentally Preferable Non-Structural Products & Materials—Prescriptive Attributes. Responsible Sourcing of Raw Materials has been renamed Responsible Extraction of Raw Materials, and the Avoidance of Chemicals of Concern in Building Materials now offers two points. Disclosure of Chemicals of Concern has been broken out of that credit into its own category. The overall aim appears to be to balance forward-looking transparency incentives with incentives for performance leadership in the here and now. These credits are summarized in the table.

These credits represent a second complete overhaul of the MR section since the first public comment period, with the old Certified Wood, Regional Materials, Recycled Content, and Materials Reuse credits, along with the new Biobased Materials credit all being jettisoned.

What do you think of the proposed changes? Make your public comments below.

Key changes in the the EA section of LEED-NC (part of LEED BD&C) in the third public comment draft of LEED 2012 are discussed below. Do you have comments or questions on this draft? Discuss them below with your fellow LEED professionals. Substantive comments submitted here during USGBC's third public comment period here will be submitted to USGBC and considered "official" public comments.

More information on LEED 2012 certification and the third public comment.

Fundamental Commissioning and Verification, a prerequisite, has been moved back to the head of the EA section with the removal of the dedicated Performance section. The most significant change in this draft is softening of a building envelope commissioning (BECx) requirement that would have made this prerequisite much more demanding (and expensive). Commissioning of the enclosure is only included at the design phase (through the Basis of Design and Owners Project Requirements documents, as well as a commissioning agent’s review of project design). In another return to the LEED 2009 scope, domestic hot water must be commissioned, but not all plumbing systems.

While several wording changes to the Minimum Energy Performance prerequisite relate to compliance for non-U.S. projects, a major change from previous drafts is that a hybrid metric of energy savings based on reductions in energy cost and in source energy use intensity reductions has been abandoned in favor of the old metric of cost savings over an ASHRAE 90.1 baseline—now 90.1–2010.

The new prerequisite, Building-Level Energy Metering, is largely unchanged from the first and second drafts of LEED 2012. Among other things, this prerequisite inserts directly into the rating system what has in LEED 2009 been a requirement found in the Minimum Program Requirements: that projects share energy data with USGBC for at least five years.

Eliminated in the first LEED 2012 draft, the Fundamental Refrigerant Management prerequisite came back in the second and remains in the third draft. The actual credit language is fundamentally unchanged.

Option 1 in the Enhanced Commissioning credit has had its scope limited in the same way as the prerequisite, but Option 2 offers additional points for commissioning the thermal envelope. Option 3 incorporates what had been a confusing entry in the second draft: a monitoring-based commissioning credit. Now it’s simply an option offering points on top of what’s offered with Option 1, by requiring the development of monitoring-based procedures to be incorporated into the commissioning scope. Among other things, the plan would require a list of points to be trended with associated frequency and duration for trending, and limits of acceptable values for tracked points. Maximum points in this credit are achieved through Option 4—“all of the above.”

The Optimize Energy Performance credit reflects similar changes as the prerequisite: the new hybrid metric is gone from this draft, as is the prescriptive compliance path using the Advanced Buildings Core Performance Guide. 

Advanced Energy Metering is a vastly simplified credit from previous drafts. It requires whole-building energy sources and energy end-uses comprising more than 10% of total consumption to have “advanced energy meters,” defined as permanently installed meters recording data in 1-hour-or-less intervals and able to transmit data. The gist of these requirements has not changed from previous drafts, but complicated prescriptive and performance paths have been dropped.

After overhauling a new Demand Response credit in the second draft, USGBC mostly left it alone here, although it has been simplified, with the removal of an option incentivizing semi- or fully-automated demand-response systems. 

There are minimal new changes to the On-Site Renewable Energy credit, with the biggest change from LEED 2009 still being the allowance of “solar gardens” or community renewable energy systems as long as they are in the same utility service area.

The Refrigerant Management credit appears at first glance to be rewritten, but the changes are apparently simply the addition of metric versions of compliance equations.

A new credit called Reconcile Design and Actual Energy Performance, which built on the LEED 2009 M&V credit, has been dropped from this draft, with its overall intent and some of its methods apparently folded into the other energy-efficiency and energy metering credits.

As in previous drafts, Green Power and Carbon Offsets now applies to total energy use, not just electricity use. Projects may use RECs, carbon offsets, or other sources of “green power” to offset project energy use by quantity consumed, not cost.

What do you think of the proposed changes? Post your public comments below!

Key changes in the the WE section of LEED-NC (part of LEED BD&C) in the third public comment draft of LEED 2012 are discussed below. Do you have comments or questions on this draft? Discuss them below with your fellow LEED professionals. Substantive comments submitted here during USGBC's third public comment period here will be submitted to USGBC and considered "official" public comments.

More information on LEED 2012 certification and the third public comment.

A renamed Outdoor Water Use Reduction prerequisite (not “Landscape Water”) has simplified requirements that do not appear to represent significant changes from the second draft. Projects can avoid irrigation entirely or reduce water use for the peak watering month 30% below a baseline established by the WaterSense Water Budget Tool.

The fundamental 20% water reduction baseline is unchanged, but the name is now Indoor Water Use Reduction. As with the second draft, only fixtures in the project scope are covered, not all fixtures in the building, and water-efficiency baselines remain the same from that draft. A new Appliance and Process Water Use Reduction prerequisite has been folded into this prerequisite, bringing minimum performance requirements for some appliances and processes. For example, residential clothes washers and dishwashers must be Energy Star and  commercial clothes washers must be CEE Tier 3A.

The Building-Level Water Metering prerequisite has been moved here from the Performance category, which did not stick in this draft. The gist remains the same: all water conveyed to the project—regardless of source—must be metered. Reporting of metering data, including submeters, to USGBC would be required for five years. Submetering requirements, like those for projects with significant irrigation, have been dropped.

The Outdoor Water Use Reduction credit remains similar to the prerequisite in its use of the WaterSense Water Budget Tool. The basic 50% and 100% reduction thresholds remain unchanged from LEED 2009 and from the first two drafts, but other requirements have been simplified since the last round. For example, not only can playgrounds and athletic fields be excluded from the credit calculations, but best management practices such as metering are no longer required for them.

The Indoor Water Use Reduction credit builds on the prerequisite in a straightforward fashion, while also similarly folding in the Additional Appliance and Process Water Use Reduction credit that had been introduced in a previous draft. This portion of the credit creates a menu of choices. Commercial washing machines, commercial kitchen equipment, commercial laboratory and medical equipment, commercial vehicle washing systems, and municipal steam systems all fall under this credit. Earning it means establishing eligibility for a given category (being connected to a municipal steam system, for example), and then meeting specified requirements for all of the given equipment within the project scope. In most cases, that entails meeting efficiency standards; in the case of municipal steam, projects would recover and reuse steam condensate.

The Sustainable Wastewater Management credit (Innovative Wastewater Technologies in LEED 2009) has been dropped from this draft. While USGBC had been developing the credit toward recognizing nutrient recovery from wastewater, it apparently decided that new water-related requirements included elsewhere raise the LEED 2012 bar enough.

One of those places is Cooling Tower Water Use, which is mostly intact from the previous draft, with some simplifications. Requirements for drift eliminators and control of blowdown with conductivity meters are eliminated, for example, while retained requirements focus on control of scale and corrosion in the system.

A Water Metering credit is retained from previous drafts and moved to the WE category from Performance. The current version is a simplification, removing a requirement for remote reporting of data while retaining requirements for submetering that have been jettisoned from the prerequisite, notably submetering for any reclaimed water, domestic hot water, and any boiler with aggregate projected annual water use of 100,000 gallons or more.

What do you think of the proposed changes? Please post your public comments below.

Key changes in the the SS section of LEED-NC (part of LEED BD&C) in the third public comment draft of LEED 2012 are discussed below. Do you have comments or questions on this draft? Discuss them below with your fellow LEED professionals. Substantive comments submitted here during USGBC's third public comment period here will be submitted to USGBC and considered "official" public comments.

More information on LEED 2012 certification and the third public comment.

The Construction Activity Pollution Prevention prerequisite remains the same after seeing minor changes for the first draft. The only revision is that the 2008 EPA Construction General Permit is now referenced—not 2003.

For schools, the Environmental Site Assessment prerequisite maintains a minor but important change: the blanket exclusion of sites on former landfills has been removed. The wording now also allows non-U.S. standards for site assessments.

The Site Assessment credit, new in the second draft, remains and only gets mild tweaks here. The credit requires a “site survey/assessment,” taking into consideration topography, hydrology, climate, vegetation, soils, and human uses. The credit appears to be a nudge toward integrative design, requiring a narrative on how each topic influenced the project design. A greater social element has been added in this draft: a “human health impacts” assessment, looking at proximity of vulnerable populations, adjacent physical activity opportunities, and proximity to large sources of air pollution.

Brownfield Redevelopment is now Brownfield Remediation, but it has become a LEED-ND credit and is not being offered to building design and construction projects, having essentially been folded into the High Priority Site credit.

With minor changes, Site Development—Protect or Restore Habitat keeps similar requirements that go back to the first 2012 draft, with a focus on protecting portions of the site from development. The most significant change in this draft is to the option for financial support of offsite protection. Instead of committing $1 per square foot for 20% of the total site area, projects would have to commit only $0.05 per square foot—but for the whole site area.

Since being simplified for the first public comment, Site Development—Open Space again has only minor wording changes. Projects must provide outdoor space equal to 30% of the total site area, including building footprint—stricter than LEED 2009’s comparable Case 3. A minimum of 25% of the outdoor space must have ground or overhead vegetation, not and overhead vegetation. Urban food production is explicitly encouraged.

After the two stormwater credits from LEED 2009 became one credit in the first draft, Rainwater Management, we get more minor wording changes this time. The two options now have names: 95th Percentile and 98th Percentile, with the second option earning an extra point.

Heat Island Reduction remains one credit, not two as in LEED 2009, and in this draft the requirements have narrowed after broadening in the last draft. The building façade is not considered part of the relevant surface area in this draft. Three-year aged SRI values are now referenced, but only as an option, not a requirement.

The requirements behind the Light Pollution Reduction credit have been tweaked, on contrast with the ovehauls of the last two rounds of drafts. The wording of uplight and light trespass requirements have changed, but key metrics have not.

What do you think of the proposed changes? Register your public comment below.