Low-Emitting Interior Credit: Positive Improvements

The revisions in the proposed EQ credit Low-Emitting Interiors will strengthen the requirements, heighten the level of transparency, and increase the value of 3rd party certification. Overall, SCS encourages supporting the changes made to the proposed LEED 2012 EQ credits and most notably recognizes the following improvements and progress: • While the credit does not recognize a specific certification program, it most notably does not exclude any specific program. This position clearly demonstrates an effort to ensure the credit’s initial intent to reduce concentrations of chemical contaminants impacting human health and the environment. • The standards and criteria referenced in the credit are all publicly available and verification may be performed by any clearly defined qualified laboratory and certification body. • For building products, the credit now references the stringent requirements of CA 01350, which was developed through a multi-stakeholder process to establish baseline criteria for health based emission limits. The standard continues to evolve its stringency via a diverse reviewing body consisting of industry, non-governmental organizations, government, academia and other interested parties. On January 1, 2012 the standard integrated its most stringent VOC emissions criteria for Formaldehyde: 9ug/m3. • In addition to CA 01350, the new credit references the rigorous ANSI/BIFMA Furniture Emissions Standard and ANSI/BIFMA Furniture Sustainability Standard, which have both met ANSI verification requirements for due process and consensus. The standards were developed and publically reviewed by a balanced group of multi-stakeholders, non-governmental organizations, industry members, and other interested parties, including third-party certification bodies.. • For furniture, the new credit provides a weighted calculation for compliance based on the emissions criteria from the ANSI/BIFMA e.3-2011e credit 7.6.1 (also equivalent to the ANSI/BIFMA Furniture Emissions Standards criteria) and from credit 7.6.2, which is comparable to the emissions criteria within CA 01350. This credit places more significance on furniture systems meeting credit 7.6.2 than products meeting credit 7.6.1, much like recycled content calculations place more emphasis on post-consumer recycled materials. This will drive further improvement in the indoor air quality performance of furniture products. SCS has one concern about the current proposed 2012 changes. The new credit reduces the point allocation from four to three, reducing the incentive for LEED users to spend the time and effort to include lower-emitting products in LEED buildings. It is of SCS’s opinion that the USGBC should maintain the original 4 points associated with this credit to ensure its initial intent of establishing a high value to human health criteria.