By: Barbara A. Campagna, FAIA, LEED AP BD+C
The fifth and final public comment period for the US Green Building Council’s (USGBC) draft of LEED v4 is now out for public comment. As with the public comment periods for the first, second and third drafts of LEED 2012 (renamed LEED v4 after public comment period 4), we’re offering suggestions on how to comment on the documents to help make the guidelines and credits more preservation friendly.
How Do I Comment?
As with previous comment periods, we’ve prepared a list of credits that preservationists should consider carefully and comment (comment suggestions below) on if possible (unlike previous comment periods, we’re suggesting nine comments this go-round instead of ten.) Comments for the fifth public comment can be submitted through USGBC's new credit library - https://new.usgbc.org/leed-v4
Every comment submitted is reviewed and evaluated. Take a look at the chart on the USGBC website that identifies every comment that was received in the fourth public comment period as well as USGBC’s responses. It makes for some very interesting reading! You must submit your comments online through the official comment process. More details on how to comment are included in our comment recommendation list.
The beauty of USGBC’s online comment process is the ability to comment by credit. You can pick and choose the ones that have the most impact on you or your organization. Don’t be scared by the technical nature of all of this. We’ve been commenting since 2009 and have seen important positive changes for preservation in LEED. We still have a way to go but have found that participation in the process is the key way to make those changes.
All comments must be posted to the USGBC website by December 10.
How and When to Vote on LEED v4
It is expected that the final version of LEED v4 will be ready for membership ballot in summer 2013. If you want your voice heard make sure that your company is a member in good standing by March 1.
The final draft for LEED v.4 is out for public comment from October 2 to December 10, 2012. This is the fifth public comment and intended to be the final one. In keeping with past public review periods, the National Trust for Historic Preservation has put together a list of the top credits preservationists should review and comment on. Please note that this final comment period has been identified as a “finessing” period and as such, many credits have been closed for public comment. However, there are two credits we believe still warrant public comment (discussed in #4 and #10) and we have suggested how to provide those comments. General comments are also not allowed in this comment period.
1. Sensitive Land Protection, LTc2 (2 points), (New Construction Rating System)
The previous draft of LEED required that development only be located on previously developed land. In v4, a second option has been added that identifies various ecologically sensitive lands that cannot be developed on, such as prime farmland, floodplains, ecologically sensitive habitats, water bodies or wetlands.
We had recommended in the last comment period that the definition of sensitive lands should include “the development footprint does not consist of a local, state or federally designated historic or cultural landscape.” This recommendation was rejected as being included in a different credit - High Priority Site. One of the ongoing concerns we have with LEED is the compartmentalization of themes into specific credits, rather than being comprehensively addressed throughout the rating system. We suggest that this credit would be stronger with the removal of option #2 (various ecologically sensitive land that cannot be developed) and reverting to Draft #4’s requirement that “development should only be located on previously developed land.”
2. Surrounding Density and Diverse Uses, LTc4 (up to 5 points), (New Construction Rating System)
This credit has been clarified to “promote livability, walkability and transportation efficiency…” and now allows up to 5 points for locating on a site with sufficient density within a ¼ mile radius of the project boundary and/or is a new or renovated building within walking distance of up to eight existing and publicly diverse uses. The clarification and support of locating projects in existing buildings in diverse neighborhoods is appreciated. We recommend applauding USGBC for the clarifications to this credit which support social, preservation and cultural metrics of dense urban neighborhoods.
3. Advanced Energy Metering, Eac4 (1 point), (New Construction Rating System)
The earlier versions of LEED v.4 (previously called LEED 2012) included much more stringent performance requirements. It is unfortunate that those requirements were almost wholly removed. This credit however, retains some of that effort to encourage better operations and monitoring of the designed systems. This credit now requires monitoring for any uses that represent 10 percent or more of the total annual consumption of the building. We recommend that consideration be given to reward uses less than 10 percent of the total annual consumption since several of those together could be significant toward a building’s energy use. We also recommend that future versions of LEED return to the more comprehensive performance requirements that the earlier drafts were attempting.
4. Building Product Disclosure and Optimization – material ingredients, MRc4 (up to 2 points), (New Construction Rating System) INCORPORATE comments regarding Materials & Resources: Building Life Cycle Impact Reduction in credit MRc4’s comments since this credit is no longer open for comments
Since “Building Life Cycle Impact Reduction Credit” is not officially open for comments, we chose to add our Materials & Resources Comments in this credit.
The Building Life Cycle Impact Reduction Credit has gone through several iterations since LEED 2009, and we therefore believe it warrants additional comment during this comment period. We appreciate that this credit has been expanded to 5 points for the reuse of historic buildings – now historic buildings will just automatically receive 5 points (up two points from the earlier comment periods) without having to go through what has been a very complex process to document the reused percentages of structure, walls, etc. However, while this credit looks better for historic buildings than any of the previous versions, it still falls short of where we believe it should be.
Over the last several years we have been working to make the case that building reuse (whether the building is historic or not) should be better valued under the LEED rating systems, and that the reuse of historic buildings has added positive impacts and should receive some sort of additional credit. Several studies now suggest and document, including the National Trust's recently released "The Greenest Building: Quantifying the Environmental Value of Building Reuse," that it can take decades for a new building to compensate through efficient operations the carbon impacts expended through the construction process.
At a minimum, the LEED rating system ought to provide a healthy point premium to projects that make use of existing buildings and thereby reduce the initial outlay of carbon normally associated with a new construction project. The existing draft does not provide such a point premium for reuse. While the precise number of points that should be allocated for reuse deserves more discussion, the incentive should be sufficient to communicate to the development community the environmental costs exacted by new construction relative to the choice to reuse a building.
As a step in the right direction, we had recommended in the past comment period that minimally a site should be able to receive points for both Option 1 (Historic Building Reuse) and Option 2 (Renovation of Abandoned or Blighted Buildings) if relevant (total points available for both of these options would now be up to 10 or 12 points in this fifth draft). Rehabilitating an abandoned building is not mutually exclusive from being historic nor should they be treated as equivalent. The USGBC response that allowing this is not possible because there are only 100 points in the rating system, which defeats the holistic purpose of LEED. We recommend a more comprehensive review of the points across the board rather than just within credit categories. We understand that this is likely not possible for LEED v.4 but believe it needs to be addressed in future review.
5. Building Product Disclosure and Optimization – Environmental Product Declarations, MR c2 (up to 2 points)
We applaud the inclusion and the clarification of the requirements in this credit. It rewards teams and owners for choosing products with environmentally, economically and socially preferable life-cycle impacts, products with publicly available environmental product declarations and products that are sourced from at least five different manufacturers. This credit could be a game changer in rating systems by encouraging the use and development of products with transparent, peer-reviewed environmental declarations. This credit has evolved significantly and for the better since it was introduced in comment period one.
6. Site Development – Protect or Restore Habitat, SSc1 (up to 2 points), (Existing Buildings rating system)
The intent of this credit is “to conserve existing natural areas…through protection or restoration of watersheds, habitat, soils and urban green space.” In our efforts to suggest that the rating systems more holistically acknowledge both existing and historic buildings and landscapes, we recommend that “urban green space” be expanded to include “urban cultural landscapes” as well.
7. Facility Maintenance and Renovations Policy, MRp2 Required, (Existing Buildings rating system)
This prerequisite credit has been substantially revised and clarified to incorporate maintenance and renovation terminology and guidelines. This is an excellent rethinking and retooling of this credit and better represents the importance of maintenance and operations in all buildings. We applaud USGBC’s alterations to this credit and its intent and recommend that future rating system updates apply the holistic thinking now present in this credit across the entire system.
8. Occupant Comfort Survey, EQc10, (I point), (Existing Buildings rating system)
We applaud the added requirement in this credit that an occupant comfort survey must be performed every two years. The previous draft did not identify a required schedule. One of the best things LEED can do is improve actual monitoring of building operations and maintenance. Requiring surveys every two years will help to incorporate better performance expectations.
9. Wastewater Management, GIBc14, (up to 2 points), (Neighborhood Development Rating System) INCORPORATE comments regarding Building Reuse, GIBc5 (1 point) in credit GIBc14’s comments since this credit is no longer open for comments
In an effort to better represent the impact of building reuse on the environment, we request that USGBC evaluate the points being assigned to various activities in the Green Infrastructure & Buildings category. If Wastewater Management can receive up to 2 points, then Building Reuse should be able to receive at least 2 points as well. While we acknowledge that wastewater management applies to an entire neighborhood, the life cycle impact of the reuse of an entire building would likely meet or exceed the life cycle impact of wastewater management, outdoor water use (up to 2 points), and certified green buildings (up to 5 points).
Comments for fifth public comment can be submitted through USGBC’s new credit library.
Barbara has worked for the past 25 years as an architect, planner and historian – reinventing and restoring historic and existing buildings. From 2006-2011 she was the Chief Architect for the 29 historic sites operated by the National Trust for Historic Preservation, and now runs her own firm BAC/A+P, which occupies a unique niche in both the historic preservation and green building fields.