LEED v5 BD+C/ID+C Materials and Resources public comments

I’m very disappointed to STILL see no LEED credit address moisture management in building envelope design.  As our industry is adding continuous insulation (for good reasons), there are more and more buildings suffering from the unintended consequences of trapped moisture due to a lack of proper hygrothermal analysis during design.  This impacts energy efficiency (wet insulation = bad insulation), material durability (wet material gets replaced more frequently), and indoor air quality (mold), and yet LEED is still completely silent on the topic of good building enclosure design.

Managing moisture through good BE design is not covered in other credits (wet insulation is not accounted for in energy models, material credits or IEQ – construction moisture management is different than what I’m talking about). 

To address this critical issue, there should be a credit (in MR or IEQ) that simply requires compliance with ASHRAE 160 for all above-grade wall and roof assemblies that cover at least 10% of their respective assembly type’s total surface area. ASHRAE 160 assesses the Mold Index value (predicted mold growth) of the critical material layers in a building enclosure assembly, and is considered the industry standard for hygrothermal analysis. It is very possible to meet IECC/ASHRAE 90.1 U-factor requirements and IBC 1404.3 vapor retarder requirements but still grow mold in walls - this is where ASHRAE 160 comes in to play, and it is also where LEED should come in to play.

Posted in wrong category.

My name is Paul Sambanis, and I am the Vice President of Sustainability at Sloan, a manufacturer of commerical restroom solutions. Sloan supports the improvements to the building and materials reuse category in LEED v5, however we recommend that LEED consider the following: Consider how to craft language the langague related to reuse carefully.  Certain products like plumbing fixtures are not alway backwards compatibility for reuse in place and then conflict with other parts of the standard (e.g. water efficiency) and give consideration that manufacturer take back programs don't alway makes sense to be implemented if product needs to be shipped across the country (lot of carbon emissions) versus just donating to local habitat for humanity.

Comments from a few of us at Wight & Company:

• Building and Material Reuse - in ID&C - 'Reuse Interiors and Reduce Embodied Carbon' should be renamed 'Materials Reuse' to align with the BD&C credit and to avoid confusion with the Assess and Reduce Embodied Carbon
• Optimized Building Products - need to include structural materials as well! Also - number of manufacturers required is okay for large buildings, but for smaller projects with fewer finishes - it will be increasingly more difficult to achieve. For option 2 - provide a sample calculation - how does one product category have 200% of optimized products?

The credit 'Optimized Building Products' only considers NON-STRUCTURAL building products in the optimization process.

Why have structural building products been excluded from the optimization process?

Structural materials outweigh non-structural materials by far in a building mass balance, and the stewardship of building products is an important aspect beyond carbon emissions. I suggest all building products be included.

Concrete Sustainability Council (CSC) responsible sourcing certification for concrete pertains to sustainable sourcing and manufacturing practices for concrete. It addresses similar attributes like Cradle to Cradle or FSC certification.

I suggest the credits be provided for CSC certification as follows:

• Bronze CSC Label:
  • Climate Health=0.5;
  • Human Health=0.5;
  • Ecosystem Health=0.5;
  • Social Health=0.5;
  • Circular Economy=0.0
• Silver CSC Label:
  • Climate Health=0.5;
  • Human Health=1.0;
  • Ecosystem Health=1.0;
  • Social Health=0.5;
  • Circular Economy=0.5
• Gold or Platinum CSC Label:
  • Climate Health=1.0;
  • Human Health=1.0;
  • Ecosystem Health=1.0;
  • Social Health=1.0;
  • Circular Economy=1.0

The Wallcoverings Association (WA) is an organization representing wallcovering manufacturers, distributors, and associate suppliers in North America and abroad. The WA is committed to sustainability and transparency and the ability for designers and specifiers to select products that align with their project goals.  

The WA developed NSF/ANSI 342 a multiattribute standard as a tool to evaluate manufacturers, distributors and the products they sell. As a consensus-based standard, it is a living document designed to be amended as the subject of sustainability continues to evolve. 

There is a common misunderstanding in our industry around the language of the documents we use on our products. Following the lead of Mindful Materials’ mission of aligning our language, we recommend clarification of the evaluation tools listed in “Figure 1. Optimized Product Valuation by Eligible Product Documentation”. 

In the table of Figure 1, documentation options listed have been identified as single and multi-attribute standards without distinguishing between declarations and certifications and, in some cases, erroneously listed. Defining the three options for documentation would be beneficial to the users, see below. 

• The most often misunderstood definition is regarding product ‘declarations’. These are not certifications, as in they do not have a pass/fail “qualifier” but are rather a simple statement of transparency which can be 3rd party verified. (Examples of Declarations are EPDs and HPDs). 

• A single-attribute standard is proof of a product’s verification of one aspect of sustainability. (An example of a single-attribute would be Greenguard, which verifies indoor air quality)

• A multi-attribute standard is an evaluation of a set of metrics recognizing a product’s performance based on a wide range of criteria across many lifecycle stages including: environment, health, and social responsibility efforts among others. (An example of a multi-attribute would be BIFMA e3 / level). These standards rely upon single attribute standards and certifications to verify the claims of a product. 

The current version of NSF/ANSI 342 is in the process of a rewrite and will include new areas of prerequisites and additional areas of evaluation around human health and social responsibility. The top priority of the standard will be a requirement of a publicly available scorecard (of which many are currently published on the WA website). The rewrite will also align language and evaluation criteria with the Mindful Materials 5 “buckets” of sustainability.

We want to point out that ANSI standards, such as the WA NSF/ANSI 342,  BIFMA e3/LEVEL, facts NSF/ANSI 336, and Affirm NSF/ANSI 332 do not involve for-profit middlemen. These standards are developed by a joint committee consisting of public health and user members along with industry representatives. They are tasked with ensuring the standard properly addresses public health, safety and environmental issues. 

We were disappointed to see WA NSF/ANSI 342, facts NSF/ANSI 336, and Affirm NSF/ANSI 332 omitted from LEED v5. We recommend the inclusion of these standards within an updated version of LEED v5. 

We have included comments on the specifics of the MR Optimized Building Products credit in greater detail. Please view the specifics here. 

MR Credit: Reuse Interiors and Reduce Embodied Carbon

Option 1: Reuse Existing Interior and Minimize Renovation, Path 1: Furniture and Interior Nonstructural Elements Reuse - suggest including doors, cabinetry, plumbing fixtures, piping, lighting, wiring, cable, mechanical equipment and ductwork, among the elements that would be reused when minimizing renovation.

Option 1, Path 2: Furniture Reuse - suggest naming the path Onsite Furniture Reuse to avoid confusion.  Which leads to another question: can this be expanded to include a commercial tenant's reuse of furniture when moving to a new location.

MR Credit: Assess and Reduce Embodied Carbon, Option 2: Interiors Life-Cycle Assessment - The several paths are unclear, we look forward to reviewing the corrected draft.

MR Credits: Low-Emitting Materials and Optimized Building Products - with the Low-Emitting Materials now part of MR not EQ, can we look forward to a consolidated calculator to cover both credits?  More important:  it is essential that LEED provide reliable and user-friendly calculator(s).  The present system of macro-powered spreadsheets is obsolete, overly burdensome, and unsuitable for today's standards of digital security.

MR Credit: Construction and Demolition Waste Diversion, Option 1: Diversion of targteted materials prior to demolition - please clarify how this relates to MR Credit: Reuse Interiors, and to manufacturer take-back programs.  Also, suggest adding wall panels and demountable partitions to the list of materials that can be diverted. 

EQ Prerequesite: Fundamental Air Quality, Entry Systems requirement - Please provide a way for a commercial interior tenant projects to work around this part of the prerequisite if the landlord will not provide such systems at building entrances. 

Where should subflooring be included for Low-Emitting Materials in Flooring or Composite Wood - seems to be in conflict in the language provided under Flooring, listed both under flooring and explicitly excluded.