Based upon the LEED-NC Version 2.2 (dated December 2004) draft, we would like for the USGBC to interpret whether or not fulfilling the second submittal option in SS Credit 4.3: Alternative Transportation - Low Emitting and Fuel Efficient Vehicles, would fulfill the requirements and intent of LEED Version 2.1 credit for Alternative Fuel Vehicles. The proposed revision to the requirement notes, ". . . that preferred parking for low emitting and fuel efficient vehicles is being provided for at least 5% of the total vehicle parking capacity of the site." We believe that this option will satisfy all intents of this credit as described in the CIR Ruling dated 9/20/02, which is to "reduce the use of crude-oil fuel-based vehicles." In our proposed project submittal, we would include site drawings/a parking plan, and a parking management plan as described in the LEED-NC Version 2.2 submittal option. Our reasoning is as follows: Since LEED-NC Version 2.1 was authored, the automobile industry has shifted design & production efforts from electrically powered vehicles, to self-sustaining gas/electric hybrids. Resultantly, the intent and requirements of Version 2.1 does not appear to be amenable with industry production and market-based availability; rendering this requirement functionally unachievable for integration and application. As it is the intent of the requirement to limit fossil-fuel consumption, promoting and benefiting such, we contend LEED-NC Version 2.2 SS: Credit 4.3 adopts this very strategy, and fulfills the intent of the Version 2.1 credit; encouraging use of hybrid & highly fuel-efficient vehicles. Does the USGBC deem this alternative approach satisfactory to fulfill the requirements of LEED-NC Version 2.1 SS Credit 4.3? If the USGBC does not feel this approach meets the requirements of the Credit, would it reasonably qualify for a Innovative Design Credit?
LEED-NC Version 2.2 draft requirements cannot be utilized as a means for achieving credit equivalence. These proposed revisions constitute changes to the current LEED requirements and thereby must be balloted by the USGBC membership before they can be applied to earning credits. SSc4.3 CIR Rulings dated 9/8/2004 and 1/9/2002 clarify the current requirements. These CIRs specifically prohibit achieving this credit via a preferred parking approach, by stating: "To capture the point requires implementation steps that put the technology on site in a definitive manner." . . . LEED currently recognizes hybrid gas/electric vehicles as compliant alternative transportation technology, but "preferred parking does not result in the technology being implemented on site, it rewards others that initiate the implementation. No credit will be given for the preferred parking approach for this credit." The described approach would not earn an innovation credit. Innovation credits are reserved for exceptional performance above current credit requirements or for innovative performance in green building categories not specifically addressed by LEED; this approach qualifies as neither.