Operational Carbon Projection and Decarbonization Plan – project-specific modeling of energy use should be a minimum requirement; there is too much uncertainty introduced by allowing simplified surrogates for actual or modeled energy use.  Also, it appears that USGBC will use the submitted energy use data to determine carbon emission projections for the project using a “business as usual” assumption.  It would seem appropriate to clarify that marginal emission rates will be used for the project’s grid location and also to characterize projected emissions based on Cambium projections for a high-, mid-, and low-case for future renewable energy costs.  This would better bracket what might or might not occur in the future. Also, clarify which of these cases the “business as usual” assumption best aligns with.

Minimum Energy Efficiency – a minimum number of credits (above minimum efficiency) appears to only be required for platinum certification.  Using current minimum codes and standards (like 90.1) as basis for minimum LEED certification seems insufficient for a standard that intends to recognize above-code “green” construction and emphasize decarbonization.  Improved energy efficiency is a hallmark of decarbonization plans and is often considered the first and most broadly effective resource to decarbonize.  Suggest requiring a minimum number of points (using the enhanced energy efficiency credit) for all LEEDv5 certification levels (e.g., 2 pts certified, 4 points sliver, 6 points gold, 10 points platinum).