Key LEED Interpretations
There are hundreds of LEED Interpretations, so which ones might be really useful to your projects? The following are some notes of key Interpretations from the latest quarterly release—for July 2014. We hope to keep updating this page, and invite you to note Interpretations that you find noteworthy. Please add your thoughts in the comments section below.
We'll start off with some basics:
- Project teams are required to adhere to rating system addenda and LEED Interpretations based on LEED registration date.
- LEED Interpretations are applicable for all projects. If relying on them to earn a credit, particularly if you are using them in an Alternative Compliance Path, it's helpful (and often required) to cite them in your documentation.
- There are two places to access all Interpretations: the Interpretations database, and the LEED credit library. (As of this posting, the credit library doesn't have the latest round of Interpretations, unfortunately.)
- For a deeper look that goes further back in time and covers many issues related to Interpretations, including key addenda, see LEEDuser's Missing Manual.
July 1, 2014 Release
USGBC published 10 LEED Interpretations (10388-10397). Here are quick summaries of all the interpretations. Several of these involve considerable detail; reviewing the full text in the Interpretations database if the ruling applies to your project is recommended.
- 10244: Revisions to LEED Interpretation 10244 clarify how the commissioning agent (for EAc3) can be included in single-entity contracting methods. The "ruling has been reversed and revised to allow the CxAThe commissioning authority (CxA) is the individual designated to organize, lead, and review the completion of commissioning process activities. The CxA facilitates communication among the owner, designer, and contractor to ensure that complex systems are installed and function in accordance with the owner's project requirements. to be contracted to the general contractor or a subcontractor of the general contractor in limited circumstances."
- 10388: For all LEED 2009 and v4 rating system, the environmental tobacco smoke (ETSEnvironmental tobacco smoke (ETS), or secondhand smoke, consists of airborne particles emitted from the burning end of cigarettes, pipes, and cigars, and is exhaled by smokers. These particles contain about 4,000 compounds, up to 50 of which are known to cause cancer.) prerequisite applies to e-cigarettes as well as conventional cigarettes. USGBC cites the World Health Organization, stating that "e-cigarettes should be prohibited anywhere where the use of conventional cigarettes is prohibited."
- 10389: To sum this one up, directed biogas is off-site renewable energy—not onsite. If purchasing biogas to comply with LEED-EBOM EAc4, purchasing biogas that is fed into utility pipelines that also serve other buildings does not qualify as onsite renewable consumption.
- 10390: How should purchased renewable energy fuels be treated in the energy model for BD&C EAp2? In short, the energy source may not be modeled as "free," because it is purchased.
- 10391: In LEED Healthcare and Schools for v4 SSp Environmental Site Assessment, ASTMVoluntary standards development organization which creates source technical standards for materials, products, systems, and services E1527-13 (or local equivalent) can be substituted for ASTM E1527-05.
- 10392: Provides clarification on leakage rateThe speed at which an appliance loses refrigerant, measured between refrigerant charges or over 12 months, whichever is shorter. The leakage rate is expressed in terms of the percentage of the appliance's full charge that would be lost over a 12-month period if the rate stabilized. (EPA Clean Air Act, Title VI, Rule 608). calculations for LEED-EBOM EAp3.
- 10393–4: Guidance on LEED for Homes and load sizing calculations.
- 10395–6: Clarifies for LEED for Homes projects in California how to handle Title-24 2013.
- 10397: Introduces a new compliance path for EAc2 under LEED 2009, to encourage onsite renewables for facilities that have high process loads (over 60%) but not enough space to install adequate renewable energy equipment. The Interpretation introduces new targets for these facilities, while also requiring optimizing energy performance under EAc1.
April 2, 2014 Release
USGBC published 20 new LEED Interpretations (10368–10382), mainly for Homes and Multifamily Midrise, which represented 15 of them. We don't see anything groundbreaking here, but individual projects will find these Interpretations useful. Here are the highlights:
- 10368: How residential projects can achieve LEED-CI SSc3.2: 1) Completely residential building? Provide covered bicycle parking for 15% residential users. 2) Mixed use building? Provide 15% covered bicycle parking for residents and 5% for users of commercial space, including the required showers.
- 10369: New construction projects in California can use CALGreen’s “Clean Air Vehicle” signage as a substitute LEV/FEV signage and the carpool/vanpool signage requirements. Must use a 10% threshold to cover all vehicle classifications.
- 10370: Identifies a 90% threshold for exemplary performanceIn LEED, certain credits have established thresholds beyond basic credit achievement. Meeting these thresholds can earn additional points through Innovation in Design (ID) or Innovation in Operations (IO) points. As a general rule of thumb, ID credits for exemplary performance are awarded for doubling the credit requirements and/or achieving the next incremental percentage threshold. However, this rule varies on a case by case basis, so check the credit requirements. for donating offsite land to a land trust when pursuing case 2 under SSc5.1.
- 10371: Defines conditions under which projects can claiming energy savings for demand-controlled garage ventilation by modeling it as an ECMEnergy conservation measures are installations or modifications of equipment or systems intended to reduce energy use and costs..
- 10372: This clarifies something that has been a point of confusion for many project teams. What to do about wood products that may have overlapping claims under MRc4 (recycled content) and MRc7 (certified woodWood from a source that has been determined, through a certification process, to meet stated ecological and other criteria. There are numerous forest certification programs in general use based on several standards, but only the Forest Stewardship Council's standards, which include requirements that the wood be tracked through its chain-of-custody, can be used to qualify wood for a point in the LEED Rating System.)? "Products identified as FSCIndependent, third-party verification that forest products are produced and sold based on a set of criteria for forest management and chain-of-custody controls developed by the Forest Stewardship Council (FSC), an international nonprofit organization. FSC criteria for certifying forests around the world address forest management, legal issues, indigenous rights, labor rights, multiple benefits, and environmental impacts. Mix Credit or FSC Mix [NN] % also have pre- or post-consumerWaste generated by end users (households or commercial, industrial and institutional facilities) of a product no longer able to be used for its intended purpose that is recycled into raw material for a new product. recycled content, the latter of which is commonly reported separately by the product manufacturer. In these instances the project team must choose whether to classify the product (or some fraction of the assembly) as FSC certified or as recycled content; the material cannot contribute to both claims simultaneously." (See more discussion of this on our MRc7 page.)
Six Interpretations were modified with new notes and updated rulings:
- 2432: Is not consistent with #10370, so it was clarified that this interpretation, which disallows off-site conservation for SSc5.1, is not applicable to LEED 2009.
- 10004: and 10005: Superseded; out of date advice on use of a shuttle line for SSc4. This interpretation no long applicable to LEED 2009.
- 10236: Clarifies what aspects of this key Interpretation on lighting boundaries apply to LEED-ND.
- 10204: Addresses "use of non-least toxic pesticides or rodenticides as pest control in areas requiring frequent treatment on a permanent basis" and has been updated to include LEED-EBOM 2009.
We're not going to go into detail with the Homes-related Interpretations here, but a couple we thought were interesting are:
- 10377: An internationally applicable list of invasive plants, at ISSG.org.
- 10378: Projects outside the U.S. can use non-Energy Star certified products if they meet the criteria.
January 1, 2014 Release
USGBC published 71 new LEED Interpretations on 1/1/2014, numbering 10292, and 10298-10367). Almost all of them are for Homes and Mid-rise (10303–10367). Let's look at the Interpretations of significant to commercial projects:
- 10292: States how EBOM MRc7 can be achieved by individual building projects on a campus where there is no tracking of ongoing consumablesOngoing consumables have a low cost per unit and are regularly used and replaced in the course of business. Examples include paper, toner cartridges, binders, batteries, and desk accessories. waste at the building level. "The credit may be earned at individual buildings if both the campus-level diversion rate and the building-level diversion rate revealed in a waste audit exceed the minimum threshold."
- 10298: Rejects a proposed strategy for O+M projects to comply with light pollution reduction requirements in which certain light meter readings would be excluded due to uncertainty about the accuracy of those readings.
- 10299: With relevance to BD+C EAp2, this Interpretation approves the use of ASHRAE Interpretation “ASHRAE/IES IC 90.1-2007-14,” which states that the baseline pump power cited in Section G22.214.171.124 was developed as 22 W/gpm total for all baseline chilled water pumps.
- 10300: "Can the definition of renewable energy sources [for EAc2] be modified to include all clean urban wood waste, invasive species, habitat restoration programs, clean industrial wood waste (pallets), and tree tops left over from logging operations?" The answer is "yes," with certain conditions, including documentation that the wood waste would have otherwise been landfilled or burned.
- 10301: Allows plastic trash can liners to count as sustainable under EBOM IEQc3.3 even without recycled content, if they are truly compostable according to FTC Green Guides.
- 10302: For LEED-ND, emphasizes the importance of connectivity at ground level, not through multiple levels such as skywalks.
USGBC also modified several Interpretations with new notes, updated rulings, etc. These inquiry numbers are: 2777 (Homes), 2778 (Homes), and the following with commercial relevance:
- 3300: What's new here is recogntion of advanced air sealing: "Projects wishing to claim energy savings from advanced air sealing may do so given they... Utilize Addendum ag to Standard 90.1-2010 to document savings," and several other requirements.
- 2045 and 5061: These Interpretations have basically been updated to reflect what has been in the IEQc5 credit language for a long time: MERVMinimum efficiency reporting value.-13 filtration is not required on recirculated air.
- 10097: This Interpretation was rescinded because it is redundant with #2467.
October 1, 2013 Release
USGBC published 13 new LEED Interpretations (#10283-10291, 10293-10296).
- 10284: Desalinated seawater that is not treated to potable drinking water standards may be applied as a non-potable waterPotable water meets or exceeds EPA's drinking water quality standards and is approved for human consumption by the state or local authorities having jurisdiction; it may be supplied from wells or municipal water systems. source in the following credits: WEc1, WEc2, WEc4 (EBOM), WEc4.2 (Healthcare), WEc4 (Schools), but not WEp1/WEc3, the basic indoor water efficiency credits, because the focus of these is efficiency and onsite reuse. Projects wishing to apply seawater to WEp1 may do so by meeting additional thresholds, including the seawater being "Municipally supplied or explicitly approved by the municipality for on-site treatment systems."
- 10285: For EAp2, answers the question, "What is considered 'hybrid' heating?" In other words, when a building heat source in Table G3.1.1A should be identified as "Fossil/Electric Hybrid" versus "Electric."
- 10286: When in Brazil, and using a centrifugal chiller that is not AHRI-certified, and there are no labs capable of performing that certificaiton, what to do in EAp2? This Interpretation gives several options, including testing to an equivalent standard, or conducting testing during commissioning.
- 10287: MasterFormat 2010 is accepted. "It is acceptable to use new or updated versions of CSI Master Format editions."
- 10288: Bottled water is by definition not a sustainable purchase under EBOM MRc5, and you must include it in your food and beverage calculations. Use tap water instead! (Bottle fillers are great.)
- 10290: Under EBOM SSc4, "Ethanol fueled vehicles can count towards as a portion of a qualifying alternative transportation trip equivalent to the percentage of ethanol that is in the ethanol fuel blend." For example, 10 trips using E85 would count as 8.5 alternative transportation trips.
- 10291: For EAp2, provides conditions for considering the unregulated process load separately from the ASHRAE 90.1 energy model.
- 10293: If unable to track durable goodsDurable goods have a useful life of 2 years or more and are replaced infrequently or may require capital program outlays. Examples include furniture, office equipment, appliances, external power adapters, televisions, and audiovisual equipment. at the building level, outlines a campus approach to durable waste goods diversion for EBOM MRc8.
- 10294: Clarifies what items are considered casework and built-in millwork that must be included in the base building documentation (in MRc3-7 and IEQc4.4), rather than furniture.
- 10295: Under IEQc4.2, paints and coatings that comply with the California Air Resources Board (CARBThe California Air Resources Board, part of the state government, is charged with maintaining clean air. This agency is unique at the state level: California was the only state that had such an agency before the passage of the federal Clean Air Act, and was allowed to keep it.) 2007, Suggested Control Measure (SCM) for Architectural Coatings meet the requirements of this credit, as an alternative to Green Seal GS-11 1993, Green Seal GC 03 2nd Edition 1997, and SCAQMD Rule 1113 2004.
- 10296: Clarifies FSC documentation under MRc7 when CoC claims cannot be passed on the final invoice to the project team.
Numerous Interpretations were also updated to apply to more credits. The following updates are more substantive:
- 2021 and 5177: The exterior entrances to loading docks and garages are not required to have entryway systems. Regularly used entrances from these areas into adjacent spaces in the building (typically office areas of the building) must have entryway systems.
- 10039: Clarified that walk-in coolers can only be excluded if not in scope of work.
- 10024: Ruling reversed: a data center may not be excluded from the EAp2 energy simulation if it is in the LEED boundary.
- 5222: Revoked and aligned with 10062: rocks are land-clearing debris and can't contribute to MRc2, etc. "Materials found on site that are not part of a previous construction (raw materials like clay, limestone, and rock) that are not reused or re-processed for beneficial or an open market product are considered land clearing debris and are excluded from credit calculation."
- 10279: Relative to IEQc7.1, subtle "clarifications" to this Interpretation which deals with spaces that fall outside of the scope of ASHRAE 55-2004 because the physical activity levels result in a time-averaged MET above 2.0.
- 10256: Rescinded: you may not earn ID credit simply for being in a LEED-ND neighborhood. Strategies are similar and would result in double-counting.
- 10220: Elaborates on this EBOM EAp2 ruling, which deals with "projects where process loads associated with manufacturing or industrial processes comprise more than 60% of the total project energy consumption, AND where the project is not eligible for an ENERGY STAR rating, AND where comparable building data is not available."
- 10212 and 10211: Updated to align with #10284, on seawater.
- 10091: For EAp2, projects are eligible to claim more than 4 points from process energy efficiency savings. This guidance supersedes CIR 2/9/2009 which placed 4 point maximum limit on process energy savings.
April 1, 2013 Release
Eight new LEED Interpretations were published 4/1/2013, #10275–10282. Here are highlights:
- 10276: Clarifies that campus projects may utilize a wastewater treatment facility located outside of the LEED project boundary as long as it is within the campus boundary, and treated water must be infiltrated or used onsite by the project. It also notes that nonpotable waterNonpotable water: does not meet EPA's drinking water quality standards and is not approved for human consumption by the state or local authorities having jurisdiction. Water that is unsafe or unpalatable to drink because it contains pollutants, contaminants, minerals, or infective agents. supplied to a project by such a campus system would be considered like a municipally supplied source for other WE credits.
- 10279: Disallows excluding high-activity spaces like gyms, or spaces that normally are not conditioned like warehouses from IEQc7, but offers an alternative calculation method for gyms, and an alternate compliance method for warehouses based on design alternatives such as radiant flooring; circulating fans; passive systems, such as nighttime air, heat venting, or wind flow; and localized active cooling. We asked our LEEDuser expert Chris Schaffner of The Green Engineer what he thought about this Intepretation. He says it clarifies things, but doesn't help where help is needed: '95% of the people struggling with this are public schools with gyms. They should just make the gyms exempt,'" he opined.
USGBC also modified 6 Interpretations with new notes and applicability. Those numbers are: 1956, 5819, 10062, 10117, 10217, and 10250. Here are some highlights that we noticed:
- 10250: This ruling on melamine formaldehyde1. Formaldehyde is a naturally occurring VOC found in small amounts in animals and plants but is carcinogenic and an irritant to most people when present in high concentrations, causing headaches, dizziness, mental impairment, and other symptoms. When present in the air at levels above 0.1 ppm, it can cause watery eyes; burning sensations in the eyes, nose, and throat; nausea; coughing; chest tightness; wheezing; skin rashes; and asthmatic and allergic reactions. 2. A known carcinogen with no known safe exposure level. Formaldehyde occurs naturally, but appears in unnaturally high concentrations in many buildings because it is an ingredient in binders used in many building materials and furnishings. has been updated—we have more detail here about the New Rules for Formaldehyde in IEQc4.4.
- 10217: This ruling was updated on 4/1/13. It states that all LEED projects can choose to include or exclude athletic fields at the project teams discretion from BD&C WEc1 and EBOM WEc3, but that this should be done consistently with other credits. The 4/1/13 update specifies that they should be included or excluded consistenlty with other WE credits.
- 5819: Originally issued 8/31/2004, this Interpretation has been made applicable to NC-v2.2 and NC-v2009 projects, and thereby gives clear direction on how to earn an Exemplary Performance point under IDc1 for process waterProcess water is used for industrial processes and building systems such as cooling towers, boilers, and chillers. It can also refer to water used in operational processes, such as dishwashing, clothes washing, and ice making. use reduction. A process is described for demonstrating a "process water savings that is equal to or greater than 10% of the regulated water usage as calculated in WEc3.
January 1, 2013 Release
See all 16 new 1/1/2013 LEED Interpretations: #10259–10274. (note: you may need to sign in to USGBC.org for this link and other links below to work). Here are some highlights from the 1/1/2013 quarterly release: (not mentioned here are a couple with limited applicability, and a couple less-interesting Homes and ND interpretations)
- 10246: A confusing Interpretation on using national averages for recycled content claims has been clarified, and is less restrctive than it immediately appeared.
- 10259: Allowance for LEED-EBOM Residential projects with non-master metered units to collect a statistically significant sample of utility data from the residential unit space.
- 10261: Clarification that the LEED project boundary may be different than the boundary drawn for ENERGY STAR for LEED-EBOM projects.
- 10263: Applicable under CI EAc1.3, a proposal to expand an exemption for active controls for small temporary use office spaces is turned down—with considerable detail.
- 10264: Applicable to EBOM EAc4, points for cannot be achieved based on PV system specifications in lieu of actual solar system performance monitoring during the performance period.
- 10265: Guidance on using shared dumpsters for one-off LEED projects for MRc2. It's allowed, with some conditions.
- 10267: When claiming a mineral-based flooring exemption under IEQc4.3, mark an ACP and enter product details in the narrative (rather than entering the product in the main credit form).
- 10268: Details on the A/V dual-mode lighting requirement for Schools IEQc6.1. Any strategy that allows easy switching to an A/V friendly lighting environment, i.e. with reduced illumination on a projection screen, is acceptable.
- 10270: How to earn an ID credit under BD&C systems for construction energy use related to lighting and temporary heat. Detailed requirements.
- 10271: A "green team" strategy to recognize individuals for commitments to environmental awareness actions is not a viable Innovation credit unto itself—proven innovation credits relative to education focus on multiple strategies relative to the building. (Applicable to EBOM, but a good lesson more generally.)
- 10274: CC&R (Covenants, Conditions & Restrictions) exemption for existing residential properties in ND projects that are not 100% newly developed.
- Also, 28 Interpretations have been modified with new notes, applicability matrices, etc. Those 28 inquiry numbers are: 808, 1547, 1622, 1741, 1898, 2342, 3105, 5033, 5115, 5272, 5819, 5847, 5986, 10080, 10114, 10120, 10146, 10202, 10215, 10216, 10223, 10236, 10239, 10241, 10243, 10246, 10250, 10252.
Have you seen any notable LEED Interpretations, or any implications of this release? Please comment below.
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