There is an interpretation - not that new but recently enforced - that has come to my attention on the Core & Shell page that I wanted to share over here on NC. According to interpretation #10202, it is no longer acceptable to split up preferred parking spaces among levels of a parking garage - even if they are closest to the vertical circulation. Now, all preferred parking must be on the closest level to the building entrance unless it can show that the walking distance is greater than the driving distance to these spaces. Does anyone else think that this is just nit-picky to the point of ridiculous? I really don't see how forcing all of the preferred parking spaces to be on the ground level adds value to a project. It seems just as logical to break them up and have them closest to the stairs/elevators. This is going to lead to a lot of irritated owners who will have the first level of their parking garage mostly empty on any given day. Not to mention that this is yet another example of changing the rules in the middle of the game.
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Susan Walter
HDRLEEDuser Expert
1296 thumbs up
April 29, 2013 - 9:46 am
It is more short sighted than nit picky to me. I can see how in many cases the ground floor is preferred (convenience, less driving). But I'm dealing with sick patients who would much prefer to be close to a building entrance on the floor that they are getting treatment. This will take me out of a credit rather than put me into a credit.
David Posada
Integrated Design & LEED SpecialistSERA Architects
LEEDuser Expert
1980 thumbs up
April 29, 2013 - 1:09 pm
It's surprising, as ADA spaces are typically distributed at all levels of a multi-level garage and not all placed on the level closest to the entrance. As much as the criteria for "preferred" is not going to be identical to the criteria for accessibility, observations suggest that most people prefer to drive one more level to park closer to an elevator or stair, whether its because they are carrying things, concerned about safety, or trying to minimize their walking distance. "Preferred" is a fairly subjective term, and while it's helpful to get more clarity on what GBCI is looking for, it seems overly prescriptive.
Lindsey Evans
Architectural DesignerPGAV, Inc.
19 thumbs up
April 29, 2013 - 2:44 pm
Take note that the LI states, "The location of preferred parking for structures with multiple entrances can be further evaluated during project review. For LEED submission purposes, the project team should provide a narrative with a detailed description of the building." I believe they understand there are specifics of each project that would make it more appropriate for the spaces to be distributed throughout the levels. The project that was asked about in the LI had everyone traveling to the first floor of the garage and then traveling to the main entrance of the building. It doesn't seem to have completely ruled out the option of distributing across levels as long as a project specific narrative describes why this is more appropriate for the project.
Ellen Mitchell
331 thumbs up
April 30, 2013 - 10:50 am
To me, the way that it is worded just sets the stage for inconsistency and uncertainty when attempting to locate preferred spaces somewhere other than the level closest to the main entrance. It seems that this ruling has recently been cited consistently on projects that have tried to break up preferred parking among levels, so I can't help but assume that it has become a standard rule. The most important thing to me as the LEED administrator is that I can't say with any degree of confidence that this approach will work any more. Waiting to just submit and see is not the best option when you are counting on getting this credit and not being able to provide a concrete direction makes me look like I don't know what I'm doing. This also sets the stage for one reviewer approving a strategy that another denied, which makes us all look bad.
emily reese moody
Sustainability Director, Certifications & ComplianceJacobs
LEEDuser Expert
476 thumbs up
June 5, 2013 - 12:50 pm
I must agree with Ellen about the Admin role. I am in the SD phase of a CS building, and we are trying to solidify the parking arrangements. Our building will be a typical office, commercial building with multi-level underground parking. It seems most logical to the team to locate the preferred parking in the same locations of the ADA spaces.
While it may seem like space designations can be easily changed, that is not always the case. The building owner is in negotiations with a major tenant. Parking availability is one of the items in negotiations. If the owner promises the tenant spaces that will have to be changed later based on a LEED review comment, it could negatively impact all parties, and additionally reflect poorly on the LEED competency of my and my project team.
Any additional clear guidance on preferred parking locations would be much appreciated.
Ellen Mitchell
331 thumbs up
June 7, 2013 - 10:34 am
I have a great example of how this is problematic....we have a big developer client who is very upset about this change. They will now have to put all 62 preferred parking spaces on ground level, which is not only inconvenient for employees who will actually have to walk farther to get to the building entrance, but it also means that the entire first level is dedicated to preferred parking for LEFEVs, which is a tough sell when you are trying to attract potential tenants. We had a call with GBCI to address this issue and they cited the caveat that each project will be evaluated on a case by case basis and suggested a detailed narrative explaining our approach. So that is exactly what we did when submitting our design review. To no one's suprise, the credit was questioned citing LI #10202 and we were told that we must adhere to the formula of driving plus walking distance. It was very clear that the reviewer was not evaluating on a practicallity standpoint, but was just checking a box on a list. This LI is ridiculous - it is making the credit harder for the sake of being harder and is adding zero value from a sustainability standpoint.
Michelle Rosenberger
PartnerArchEcology
523 thumbs up
July 11, 2013 - 5:10 pm
Hi Ellen,
Thanks for the headsup on this one and porting it over to NC. We have done this countless times in the past on C&S office, on NC residential and even on CI projects. I agree with all of you that this makes no sense and is definitely a big deal to our developers who like to spread the spaces out for various reasons.
In addition to the other arguments above, if elevator vestibules are primary or main entrances with respect to EQcr5 and we have to put entryway systems or mats down at every level, I fail to see how this is any different.
And I agree 110% about the credibility issue for all of us as LEED consultants when we can't rely on the consistent interpretation of requirements when trying to provide guidance for our clients. We have 5 separate apartment projects with the same client and you can imagine the song and dance when we have to try and explain why it was fine for 3 projects before but not for #4 & 5. It does make us look bad, and case by case doesn't handle this part of the issue even if reviewers were receptive to it. And we still get challenged even with proactive narrative explanations.
At a time when LEED is facing many challenges to its continued standing in the marketplace, this kind of issue makes it hard for us long time supporters and adherents to feel that the USGBC/GBCI are as committed to us practitioners as we are to them.
Ellen Mitchell
331 thumbs up
July 11, 2013 - 6:16 pm
Well said. I did make one last-ditch effort to challenge this ruling by citing a real life situation where locating the preferred parking on the first level of the garage was not a practical and straightforward solution. I have copy/pasted this exchange below - unfortunately we were not able to make much headway in getting this interpretation reversed though I understand there has been much discussion behind the scenes.
Question:
Our Core/shell project is a typical spec office building with some ground level retail, garage on Levels 01 through 08 and office space starting on Level 09. In total, there are 394 parking spaces, 20 of which will need to be reserved for low-emitting and fuel-efficient vehicles. Normally my approach would have been to provide preferred parking for 5% of the Level 01 retail spaces (1 space) and then divide the remaining 19 spaces among the levels of the garage that are closest to the elevators. However, I am not sure what the reviewers will be looking for now.
Specifically, my questions is if we need to account for vertical distance traveled in the elevator/stairs in the (driving distance + walking distance) formula? The driving distance (@ 350 feet per level) by far trumps any distance that a person must walk to get to the vertical circulation on any given level, so it seems that the lowest levels with the least amount of driving come out ahead no matter what – even if they are farthest away from the entrance to the office spaces vertically. So would you advise that all of my preferred parking spaces be located on Level 02? What if the office employees needed to take the stairs? Walking up from Level 02 to the first level of office space on Level 09 is approximately 280 feet. While this is not nearly enough to offset the 350 foot circular driving distance per level, I would hesitate to consider it “preferred” if I were the one that had to climb seven flights of stairs.
Response:
LEED Interpretation 10206 was developed to simplify the analysis required of project teams to demonstrate that the preferred parking layout in multi-level parking structures would result in the shortest path from garage entry to the occupant's space for drivers of low-emitting, fuel-efficient vehicles. Preferred spaces may be located on the entry level, or they may be divided between the entry level and the next level.
Prior to the publication of LI 10206, a project team might submit an evaluation that would identify the parking spaces that would entail the least amount of distance for LEV/FEV drivers to reach the main entrance of the project from their preferred space. The LI was developed to define a presumptive condition, to relieve both project teams and review teams of the need to consider project-specific conditions.
If the project team considers a specific project situation to differ from the presumptive condition described by the LI, a project-specific analysis may be submitted through the CIR process. This analysis would logically be based on the amount of distance required from a LEV/FEV parking space to the main entrance of the project.
Michelle Rosenberger
PartnerArchEcology
523 thumbs up
July 11, 2013 - 6:39 pm
Wow. Thanks for the added detail. I went to the cited CIR. Interesting new definition of what the main entry of a building is "the first elevator vestibule that is encountered upon entering the garage, as the elevator vestibule represents the main entrance to the building." I don't believe I've ever seen or heard that before. Where do you suppose that comes from?
Karen Joslin
principalJoslin Consulting
216 thumbs up
July 18, 2013 - 1:38 pm
This is utter insanity and I am getting tired of inexperienced reviewers (probably interns no less) applying only what they can find in writing somewhere to submissions rather than being true to the LEED training and experience so many of us have had. Every workshop/seminar/training session for LEED has always emphasized that when we meet the "intent" of a particular credit we should earn it. Most of what we genuine, sincere LEED consultants present is not found in a manual somewhere - and certainly should not be penalized for others not thinking of it first! This issue of constantly moving the line must STOP! Do you hear us GBCI?????????????
Kris Phillips
Arcadis10 thumbs up
September 4, 2013 - 9:18 pm
I share Karen's frustration and sentiments. Even worse, on my most recent project review, the reviewers are holding a v2.2 project to this new v2009 CIR ruling. In my experience, if your project is registered under an earlier version, any addenda or updates to the newer version do not apply to your project - unless you (the Design/LEED team) decide by your own choosing to update to the latest. Am I wrong?
We designed the building to the requirements listed in the LEED NC v2.2 Reference Guide and the online Templates provided. Now, we are supposed to go back and move all preferred parking spaces to the first level based on a 2012 ruling? The client is unable to do this and will hold us accountable if the certification goal is not met. Furthermore, this is discouraging the owner from providing ANY preferred parking and may even discourage them from pursuing LEED certification on future projects.
We've met the intent and prescriptive requirements. Anything left to "interpretation" should be as much left to the interpretation of the Design team as the GBCI reviewers.
Equally frustrated with the incessantly moving line....
Michelle Rosenberger
PartnerArchEcology
523 thumbs up
September 5, 2013 - 12:03 pm
Hi Kris,
We all share your frustration with the moving line as you can tell. And you are right in your contention that your project should not be subject to this issue. Per the USGBC "All project teams are required to adhere to all LEED Interpretations and Addenda posted before their registration date. Adherence to rulings posted after a project registers is optional, but is strongly encouraged."
To all in the string, if the project in question is a residential, mixed use project, it might be possible to get an LI to claim that residents are indifferent to driving distance and only care about being closest to the elevator closest to their unit. That way the preferred spaces could be distributed around multiple bays on multiple floors based on the percentage of residents vs. commercial users. I have an indication that might work but have not put in the paperwork.
Kris Phillips
Arcadis10 thumbs up
September 23, 2013 - 12:22 pm
Hi Michelle (and anyone following this string),
A brief update on my particular situation: I submitted a formal inquiry through GBCI and received a response indicating that a project registered prior to the ruling date could not be held to that ruling. The response content is copied below for your reference. Note that no comment was made with regards to this issue going forward, unfortunately:
---------------------------------------------------------
Dear Kris,
Your understanding is correct: the requirements of LEED Interpretation 10202 apply to projects registered after April 1, 2012. In your response to review comments, you may use this email to support your explanation that LI 10202 provisions do not apply to your project.
If you have any further questions or concerns, please feel free to use the contact form at http://www.gbci.org/contactus and select "Follow up to GBCI Response," inputting your case number from this email's subject line.
Best Regards,
**** (GBCI Rep)