Hi All,
I recently received LEED construction phase comments on a LEED v4 project. I am confused and concerned about the comments and wanted to share it with the LEED experts here to understand how to go about addressing these:
1) We are pursuing Low Emitting Materials category by showing 100% compliance. The main reason is to avoid the cumbersome budget method. Here is the comment made by the LEED reviewer about that. Why is budget calculation demanded when there is 100% product compliance.
"1. The actual volume used / surface area / cost has not been entered in the calculation for every product. Note that omitting this
data is only acceptable when 100% of the products meet the allowable VOC content and VOC emissions evaluation
requirements.
Provide a revised calculation that includes the actual volume used / surface area / cost for every product. Even if documenting
100% compliance in a category, it is strongly suggested that the actual units of measure are provided to enable recalculations
by the Reviewer, if necessary, to determine compliance.
2) Some manufacturers have provided us a summary letter for VOC emission. Where they mention the CDPH std and the TVOC for applicable scenario. The reference number for the UL CDPH test report is also noted. The reviewer is calling this letter 'insufficient documentation'.
The manufacturer would only release the complete CDPH test report if we sign an NDA, which I am not comfortable signing.
Has any one else received such comments from LEED reviewer recently. I am dissapointed to say the least.......these types of review comments will made it very difficult to pursue Low Emitting Material credit.
Renee Shirey
Stantec422 thumbs up
October 21, 2020 - 11:06 am
Vandita, since you have the product names and a reference # for the UL CDPH test report, have you tried to look them up and download the required compliant certificates here: https://spot.ul.com/.
Sophie Kerr
Sustainability ConsultantStantec
13 thumbs up
October 21, 2020 - 11:12 am
Hello Vandita,
I think they are expecting some products do not meet the requriements therefore you would need to calcualte % compliance and require cost, volume, or surface area.
As noted in their second comment, the manudafacturer summary is not sufficient, it needs to be a document from the testing authority, like a Greenguard certificate. The full report is not required but it cannot be a document published by the manufacturer. Since these products are deemed non compliant because the manufacturer summary is not sufficient, the reviewers can predict not all your products will comply and therefore you will need to use the budget tool. If you switch to LEEDv4.1 for the low-emitting credit, you will see it's easier to meet the requirements since the % compliance is lower.
Jeff Wiedmeyer
Facility Leaders in Architecture1 thumbs up
October 21, 2020 - 11:20 am
Our team recently observed a paint product that would be non-compliant with reguards to SCAQMD Rule 1113 VOC limits. I asked LEEDCoach about what we should / could do. The response I got back read:
"Option 1: Product category calculations can be used even if some wet-applied products are not compliant. Note, 100% of the products in the Adhesives and Sealants or Paints and Coatings category will need to meet the VOC content requirements. If the project is pursuing either of this category, and if a high VOC product is unintentionally used, the team can still use Option 1 in LEED v4, but the team will need to complete the VOC Content Budget Method (NOT the same as Option 2: Budget calculation method) to demonstrate that compliance with the VOC content requirements can be achieved nevertheless. This VOC Content Budget Method is described in the LEED v4 Reference Guide under Step by Step Guidance > Option 1 > Step 1 > 6th bullet."
The team must document the actual quantities and actual VOC (g/L) for ALL the non-compliant products and enough compliant products in the product category to demonstrate that actual total VOC content is within permissible total VOC limits. You may request the manufacturer to provide a statement of product compliance to determine the VOC content. If the actual VOC content of a non-compliant product is not known, the project will not be able to pursue the product category for this credit. If the threshold requirements cannot be met for a particular category, the project can choose to not pursue that product category. You can always choose from among the other product categories to meet the credit point threshold requirements."
I was not aware of this option and we have not submitted this approach yet so I cannot shed any light on how the USGBC reviewer would repsond but it is in fact included in the Reference Guide.