USGBC Engages Chemical Supply Chain with New LEED v4 Option

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LEED AP BD+C, Editorial Director – LEEDuser BuildingGreen, Inc. Mar 19 2013 LEEDuser Moderator Post a Comment

Plastic resinPlastic resin – part of the upstream supply chain of many products used in LEED buildings.

A surprise addition to LEED v4’s MR credit category could be seen as an olive branch to a chemicals industry that has been on the attack. Will it play along?

One of the main reasons USGBC unexpectedly opened a sixth public comment period on LEED version 4 is to gather market feedback on a new option for recognition of sustainability efforts not at the product level, where LEED project teams usually work, but up the supply chain.

“Product Manufacturer Supply Chain Optimization” is a new Option 3 in LEED v4’s Building Product Disclosure and Optimization—Material Ingredients credit. (The credit is slated to be labeled MRc4 and worth two points.)

Option 3: Product Manufacturer Supply Chain Optimization

As currently drafted, the option would reward projects for using building products sourced from manufacturers who procure raw materials from suppliers following health, safety, and environmental standards, with third-party verification.

Like the other options within this credit, the requirements focus on chemical ingredients. But unlike the other credit options, which rely on standards like Cradle to Cradle and formats like the Health Product Declaration to minimize and communicate about ingredient hazards, there are no specific standards named in the current draft. Rather, it calls for verification of general practices along the manufacturer supply chain, such as:

  • Communication on health, safety, and environmental characteristics of chemical ingredients.
  • Managing the health, safety, and environmental hazard and risk of chemical ingredients.
  • Optimizing health, safety, and environmental impacts when designing and improving chemical ingredients.

Transcending the building products industry

In explaining the intent behind Option 3, Brendan Owens, vice president of LEED technical development, told LEEDuser, “I hope it accomplishes a much more systemic engagement with the raw materials and components that end up being the things that we make our buildings out of.” Aside from the new Option 3, Owens explained, “All the credits are targeting the end of the supply chain”—that is, the finished-product end of it—by rewarding projects for using products with certain green labels.

Green specifications have encouraged building product manufacturers to work with their supply chains to provide the necessary products and components to meet LEED requirements. But according to Owens, such credits haven’t directly engaged companies whose businesses are largely or completely about supplying materials to product manufacturers.

By engaging those suppliers more directly, Owens hopes that the new option could increase “the availability of the types of materials that we are encouraging end-use manufacturers to use.” Owens also thinks the credit “has the potential to transcend the building products industry” by introducing LEED’s values and processes into companies that supply multiple industries, such as the automotive or textile industries, to name a couple.

A working group to define specific requirements

Owens acknowledged to LEEDuser that the credit requirements are quite general but that USGBC is now convening a working group to figure out how they would translate to specific industry practices.

Pressed by LEEDuser on the wisdom of introducing a new and poorly defined option into a fraught credit category so late in the LEED v4 development process, especially when other vehicles are open such as the Pilot Credit Library or future introduction as an alternate compliance path, Owens emphasized the statement that USGBC was hoping to make in including Option 3 in the rating system.

“It was an opportunity to say that this is something that we value,” he said. USGBC is “taking advantage of all the different opportunities that exist to leverage LEED as broadly as we can as a transformation mechanism,” he told LEEDuser. According to Owens, while alternate compliance paths and standards are regularly added to LEED without controversy, or member balloting, a member ballot could be used to seek USGBC member approval for specific Option 3 requirements.

LEEDuser also asked Owens if the option is an olive branch to the chemical industry, which has been stirring up trouble for USGBC and LEED. “It’s not very cynical to think that it would be,” Owens said, but “I don’t think it is. We didn’t go down this path trying to find a solution that would mollify the chemical industry, but a good idea came up, and it’s a win for everybody, potentially.”

Not everyone is so enthusiastic about Option 3, however—or the whole makeup of the MR category, for that matter.

“I do appreciate that they’re trying to go up the supply chain,” Eden Brukman, principal with Concenter Solutions, told LEEDuser, but “It adds yet another level of complexity to a credit that’s already fairly complex.” Brukman points out that just within MRc4, there are three options with ten total pathways to earning the credit.

“At the end of reading it, the intent is lost,” she said. Brukman supports a vast simplification of the credit with a focus on Health Product Declarations, GreenScreen, and Cradle to Cradle while putting Option 3 in the Pilot Credit Library for testing and development. Tom Lent, policy director at the Healthy Building Network, makes similar points in a comment on LEEDuser’s LEED v4 forum.

Sizing up the papal candidates

Owens says that it will be up to the working group to define where the rubber meets the road in terms of standards and processes defining MRc4 Option 3. However, LEEDuser has heard the following programs mentioned as being under consideration.

  • The Responsible Care program is a condition of membership in the American Chemistry Council (ACC). The program focuses on environmental, health, and safety programs as well as energy efficiency. This year, on the 25th anniversary of Responsible Care in the U.S., ACC announced plans to “enhance” and strengthen the program. The idea of an ACC program becoming a part of LEED has a fox-in-the-henhouse quality to some onlookers. Owens told LEEDuser that Responsible Care has come up in some conversations, and while “it could on its face do some of what we’re after, whether it is sufficient is too soon to tell.”
  • The Occupational Safety and Health Administration (OSHA)’s revised Hazard Communication Standard (HCS 2012) covers at least some aspects of Option 3, such as “comprehensive hazard communication programs.” As a basic law of the land, and not a leadership standard, OSHA shouldn’t be seen as a serious contender here, but it could help define the parameters that a leadership program is expected to exceed.
  • NSF/GCI/ANSI 355: Greener Chemicals and Processes Information Standard is, to quote NSF, “the only standard available with which to document information on sustainability-related attributes of chemical products and processes, thus allowing manufacturers and formulators to easily compare the hazards and process impacts of chemical products.” NSF, which has other credible sustainability-related standards, could be seen as a more credible benchmarking group for Option 3, but NSF-355 hasn’t been evaluated yet for this credit.
  • Various ISO standards.

What do you think of the new Option 3, the MR category in general, and the LEED v4 process? How do you think the industry might adapt to these new requirements? Please post your comments below.

38 Comments

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Paola Moschini Architect LEED AP BD+C, ID+C MACRO DESIGN STUDIO
Jun 19 2013
LEEDuser Member
151 Thumbs Up

LEED v4-Credits MR-USGBC approved program

Dear all,
about MRc3 in LEED v4, could I have more information or links where can I find more information especially about USGBC approved program?
Thank you in advance!

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Tristan Roberts LEED AP BD+C, Editorial Director – LEEDuser, BuildingGreen, Inc. Nov 03 2013 LEEDuser Moderator

Paola, we have a page dedicated to v4 MRc3 on LEEDuser. We are currently building the content out.

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Tristan Roberts LEED AP BD+C, Editorial Director – LEEDuser BuildingGreen, Inc.
Apr 05 2013
LEEDuser Moderator

about that working group....

USGBC is now taking volunteers for that working group to figure out how to implement this option. The option is also available as a pilot credit, MRpc79.

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Peggy White White + GreenSpec Apr 05 2013 LEEDuser Member 1513 Thumbs Up

Hahaha - too funny! Perhaps they could have considered value and implementation when they developed Option 3.

It will be interesting to see what the LEED v4 ballot looks like.

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Peggy White White + GreenSpec May 06 2013 LEEDuser Member 1513 Thumbs Up

I hope that the 'Working Group' is taking a good look at how the ACC is really approaching transparency:

http://blogs.edf.org/nanotechnology/2013/05/06/why-cant-acc-tell-the-tru...

I honestly don't see how any program the ACC develops for reporting on chemical content will enhance the healthy qualities of building materials. Their talent seems to be obfuscation, not transparency.

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Marian Keeler Senior Associate, Thornton Tomasetti / Sustainability May 13 2013 LEEDuser Member 3320 Thumbs Up

This is an excellent blog entry! Thanks for posting it.

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Wes Sullens Program Manager StopWaste.Org (Alameda County, CA JPA)
Mar 20 2013
LEEDuser Member
54 Thumbs Up

Make your voice heard: Comment now!

As a member of the LEED MR TAGLEED Technical Advisory Group (TAG): Subcommittees that consist of industry experts who assist in developing credit interpretations and technical improvements to the LEED system., I have to say that much of the healthy discussion taking place here and in the article also happened within our TAG. That's why we are seeking input from everyone from this 6th public comment period. So make your voice heard! Participate in the public comment period that ends March 31st. We do read them (and LEED User) and listen.
http://new.usgbc.org/node/2616399?return=/credits/new-construction/v4-draft

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Tristan Roberts LEED AP BD+C, Editorial Director – LEEDuser, BuildingGreen, Inc. Mar 20 2013 LEEDuser Moderator

Wes, thanks for chiming in here. I also want to note that people can make their public commenting public on LEEDuser's v4 forum.

Clearly there are a lot of questions about this language, so if you were able to add anything here based on your perspective, it would be quite welcome!

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Hernando Miranda Owner, Soltierra LLC Mar 21 2013 Guest 6759 Thumbs Up

One of the interesting things I noticed, and continue to notice is, when I was a developer of LEED and vice-chair of the EQ TAGLEED Technical Advisory Group (TAG): Subcommittees that consist of industry experts who assist in developing credit interpretations and technical improvements to the LEED system., was that I was one of the few members who actually worked certifying projects, and did the work myself. The majority of developers had never documented a LEED credit themselves.

Unless you actually do the hard work yourself, you do not understand the level of effort it takes to properly document a credit, and experience the every changing review rules that require you to revise and update completed work after the fact.

LEED TAGs have good intentions, not always, but most of the time. What they do not understand is the language interpretations of what they write by others who are not part of the TAGs.

I cannot even count then number of times, for credit requirements I wrote myself, the LEED reviewers have told me I did not understand what I wrote. Just amazing.

With this case, as with most of LEED v4, the same thing will happen as before. The actual rules and requirements will be written others who are not members of the consensus committee TAGs.

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Wes Sullens Program Manager, StopWaste.Org (Alameda County, CA JPA) Mar 21 2013 LEEDuser Member 54 Thumbs Up

Thanks Tristan. I can't speak for the TAGLEED Technical Advisory Group (TAG): Subcommittees that consist of industry experts who assist in developing credit interpretations and technical improvements to the LEED system., but I will say that Option 3 was not without controversy, nor was it a unanimous decision by the TAG to put it into 6th PC.

The MR section is doing some of the heaviest lifting of all credit categories, yet we have the fewest points to work within. Hence the complexity of individual credits. But I for one think that, regardless of the complexity, the trajectory for the LEED MR credits is the right one, and we are taking on very timely and important issues. Though not perfect or pretty -- I feel we are taking the right path ... at the right time. If it were easy, it wouldn't be leadership.

And I empathize with the practitioner point of view - I did LEED consulting for 6 years before working where I am now (where I do LEED policy), and had to battle those treacherous LEED Letter Templates and LOLv1. Let's hope we've all learned from those early days!

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Bill Swanson PE, LEED AP, Integrated Architecture Mar 21 2013 LEEDuser Expert 14487 Thumbs Up

Sorry to be cynical, but what are the odds that any substantial change will occur at this time? They're not going to delay the vote again and miss the planned launch at GreenBuild. (Unless Rob Watson speaks up again.) There is an inherent problem with creating schedules before the work is done. We force the work to fit the schedule.

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Peggy White White + GreenSpec Mar 21 2013 LEEDuser Member 1513 Thumbs Up

I agree, odds of substantial change are slim to none, but I plan on commenting anyway. Many of us long time practioners who are paying close attention are getting tired of the games from HQ and losing hope that LEED will continue to actually lead, and most people are not paying any attention at all. Industry must be licking their chops!

There are a couple of dealbreakers in the MR Credits for me that, if they are not resolved, will force me to vote 'no' or to not vote at all.

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Tristan Roberts LEED AP BD+C, Editorial Director – LEEDuser, BuildingGreen, Inc. Mar 21 2013 LEEDuser Moderator

Peggy, I'd be curious to see your list of dealbreakers.

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Peggy White White + GreenSpec Mar 21 2013 LEEDuser Member 1513 Thumbs Up

Maybe I'll start a dealbreaker discussion on the main v4 discussion thread. I'm sure others are feeling the same.

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Melissa Wrolstad Senior Project Manager, CodeGreen Solutions Mar 21 2013 LEEDuser Member 1799 Thumbs Up

Are there any current GBCI reviewers or current LEED practitioners on the TAGLEED Technical Advisory Group (TAG): Subcommittees that consist of industry experts who assist in developing credit interpretations and technical improvements to the LEED system.? It seems like the TAG is out of touch with the current state of LEED Online templates and the LEED review process (which has grown increasingly - to put it lightly - stringent over the past year and a half.) I cannot see how the GBCI will be able to review documentation for the new MR credits with their current level of complexity and lack of clear requirements.

As an example - in Option 3, the requirement for Manufacturers includes: "Document at least 99% by weight of the ingredients used to make the building product or building material are sources from companies with independent third party verification of the following along the manufacturer supply chain…" First off - what constitutes acceptable "independent third party verification"? When you turn on the glossary function, verification is "the range of checks and tests carried out to determine whether components, subsystems, systems, and interfaces between systems operate in accordance with the contract documents." I am confused – are you confused? Secondly, how will the GBCI reviewer check that 99% materials by weight used to make the building material meet the requirements? The GBCI reviewer will need to be familiar with the supply chains for ALL building products, or they will not be able to ensure that requirements are being met.

I hope that the TAG can go through an exercise to tighten up their requirements and language before the next version is posted. GBCI Reviewers and current LEED Project Administrators will be a big help with this (if they can be engaged.)

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Bill Swanson PE, LEED AP, Integrated Architecture Mar 21 2013 LEEDuser Expert 14487 Thumbs Up

Materials & Resources Technical Advisory Group (MR TAGLEED Technical Advisory Group (TAG): Subcommittees that consist of industry experts who assist in developing credit interpretations and technical improvements to the LEED system.) Members
Chair: Steve Baer, Five Winds International
Vice-Chair: Brad Guy, Material Reuse
Paul Bierman-Lytle, IMCC Management Consulting
Amy Costello, Armstrong World Industries
Barry Giles, BuildingWise, LLC
Rick Levin, Kahler Slater
Joep Meijer, The Right Environment Ltd. Co.
Xhavin Sinha, CH2M HILL
Wes Sullens, StopWaste.Org

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Peggy White White + GreenSpec Mar 21 2013 LEEDuser Member 1513 Thumbs Up

Thanks Bill - do you and/or someone else have a list of the mystery 'working group' members who make the final decisions on Credits based on recommendations by the TAGLEED Technical Advisory Group (TAG): Subcommittees that consist of industry experts who assist in developing credit interpretations and technical improvements to the LEED system.?

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Bill Swanson PE, LEED AP, Integrated Architecture Mar 21 2013 LEEDuser Expert 14487 Thumbs Up

This is all the info I have on Groups and members.
http://new.usgbc.org/about/committees/leed

The whole process itself is confusing with TAGLEED Technical Advisory Group (TAG): Subcommittees that consist of industry experts who assist in developing credit interpretations and technical improvements to the LEED system., SME, Working Groups.

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Hernando Miranda Owner, Soltierra LLC Mar 21 2013 Guest 6759 Thumbs Up

The USGBC will never tell you who their outside SME and Working Group consultants are. They want them to remain independent.

It is very obvious to me, as some who reads LEED review comments and writes responses, that the people writing the rules and changing the requirements after the fact are consultants who work certifying LEED projects. If you actually work on LEED projects details like I do this will make sense to you.

Unfortunately, these outside LEED consultants instead of making up rules that a reasonable percentage of practitioners can get through, make up rules that almost no one can get through. A legal A&E standard-of-care is not a goal of the rule writers. The rules are written to make the process as hard as possible. The harder LEED is the more it costs to certify. The more it costs to certify, the higher the consulting fees that can be charged. Wrong, in my opinion.

Green building works better when a greater number of projects can get through the process, than a smaller number can. Harder rules means fewer LEED projects. Fewer LEED projects means less business for the USGBC. This is why the USGBC is losing market share. It is not difficult to figure out.

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Marian Keeler Senior Associate, Thornton Tomasetti / Sustainability Mar 21 2013 LEEDuser Member 3320 Thumbs Up

To Melissa's point: I agree, the requirements are burdensome. Like you, I'm a long time architect/LEED practitioner, I envision a steep learning curve in obtaining access to resources and in performing documentation in an efficient way. As mentioned previously, this will translate to higher costs and--also quite significant and troubling--lower levels of certification. The undercurrent of feeling here among our client base in Northern California is that LEED is just not worth pursuing anymore because the rewards are not appreciable to them. This is especially true in California since CALGreen folded in LEED measures into our state building code. LEED's unreasonable (at times) and shifting burden of proof requirements eclipse what to me is the major issue getting lost in the fuzziness and controversy: we are doing this work because we believe that green building is a significant way to improve the planet! We need an efficient, functioning tool in order to do so.

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Hernando Miranda Owner, Soltierra LLC Mar 21 2013 Guest 6759 Thumbs Up

The outside consultant making up the LEED rules do not want to hear what we have to say. I do realize that simplified rules would mean fewer higher fee projects, and likely, to remain in business, having to work on a much larger number of projects to make enough money to stay in business.

Personally, I believe the fear of the outside consultants —the ones who are active LEED consultants— is they will lose market share. Well that is the way it should be. Project teams should be able to do much of the work themselves. When errors are made they should be held to a normal standard of care applicable to the A&E and construction industry. Not a standard of care not even the most experienced LEED consultants can meet.

Unfortunately, LEED rules were developed by someone with the mind set of "It isn't LEED unless they prove it to us." That is an fairly accurate quote, from GreenBuild, made by the owner of the only LEED review team the USGBC had at the time. "It isn't LEED unless they prove it to us" is still hardwired into LEED.

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Marian Keeler Senior Associate, Thornton Tomasetti / Sustainability Mar 21 2013 LEEDuser Member 3320 Thumbs Up

By "outside LEED consultants" who do you mean: GBCI review teams (most are outside consultants) or do you mean USGBC, the ones who develop LEED?

I'm hoping that there will still be a platform, including here at LEEDUser, where we can be heard, and our concerns conveyed, outside the ballot process.

Yes, LEED should continue to set the bar higher, but the developers should absolutely make the documentation easier and more fluid, so that we can navigate efficiently and serve our clients with agility. Tristan, what do you see as an improved path of communicating these concerns?

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Hernando Miranda Owner, Soltierra LLC Mar 21 2013 Guest 6759 Thumbs Up

The LEED Review teams do not develop review requirements. They have "canned" responses they are supposed to provide to maintain review consistency.

LEED Review teams are not supposed to be LEED Consultants.

The USGBC has outside consultants who help them develop LEED review rules. Some rules are developed in-house. Most are not, at least that is my experience for my projects. The only way some of the rules could have come about is from someone actively working on LEED projects. If you actively document a project this will make sense to you. The requirements are not coming from someone not working on LEED projects. They are coming from someone who is and has a job to try to fill any holes they thin exist, and are being paid to develop consistent rules. My observation is this can only be done if someone is actively working on LEED projects.

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Melissa Wrolstad Senior Project Manager, CodeGreen Solutions Mar 22 2013 LEEDuser Member 1799 Thumbs Up

Who is actually making money off of the credit language being complex and written unclearly? As a LEED practitioner, I get paid to finish projects. The client doesn't pay more for the extra 10 hours I spend figuring out how LEED Reviewers will most likely interpret vague and complex LEED language in the reference guide. I don't see how the USGBC makes more money off these extra 10 hours of project team agony. The GBCI reviewers (I assume) get paid per project they review and make less money off of reviews that are riddled with errors because the project team was understandably confused on the requirements. On top of all this, clients get irritated when project progress is held up because LEED requriements are complicated and unclear.

Who is the winner here? LEED v4 should be written as clearly, simply and concisely as possible for everyone's sake.

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Peggy White White + GreenSpec Mar 22 2013 LEEDuser Member 1513 Thumbs Up

Melissa - I would guess that Industry benefits the most from the lack of stringent and clear requirements within LEED. They can continue to do business as usual, and not have to invest in sustainable practices.

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Hernando Miranda Owner, Soltierra LLC Mar 22 2013 Guest 6759 Thumbs Up

Fees are set at the start of a project. Every project I am working on is at a time lose, and it gets worse as time goes on. I have been actively documenting LEED for projects since 1999. I know what the effort required used to be, and know what the effort required is today.

My fees haven't gone up. Instead I find to remain competitive I have to reduce fees for new proposals. And, I find I have to take on tasks for the A&E team to reduce their costs, such as outside air ventilation analysis, site lighting design assistance, storm water reduction calculations, and more.

A company that develops the review rules knows in advance something I will not learn until a project gets reviewed. That forces me to do work twice. And if changes are required, such as revising outdoor air flows, my clients become very unhappy I did not properly advise them.

A company that develops the review can market themselves as the better consultant. They are better prepared to make adjustments to their projects because they make them before everyone else gets to find out what the rules are.

LEED reviewers do not interpret the LEED Reference Guide. They follow review rules developed by someone else. The USGBC and outside consultants they feel necessary to write consistent review rules.

The charter of the GBCI is provide reviews and try to remain consist. They also have a charter that any review comment asked, regardless of the question being incorrect, must be answered. The GBCI is an enforcement group, not a rules development group. Rules development belongs to the USGBC and what they call the LEED Department.

LEED v4 needs to table about 2/3rds of the credit changes. That is how we developed LEED v2 and v2009. Not too many changes at one time. We also believed the standard of care for LEED would work as it does for a normal A&E project. That means the typical architects, engineers and contractors could do the work themselves. But, because the rules are ever changing and hard, a typical project for a high level LEED building must hire a LEED specialist, if they want to succeed. A LEED specialist is someone who can take a project with a goal of Certified or Silver and increase the rating one or two levels at minimal cost to the owner. The only way to achieve that is by working on LEED full-time and learning, or being a rules developer. If you are both a full-time consultant and rules developer you have a major business advantage over everyone else.

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Hernando Miranda Owner, Soltierra LLC Mar 22 2013 Guest 6759 Thumbs Up

"Industry benefits the most from the lack of stringent and clear requirements within LEED."

The charter of LEED is not to enforce codes. That problem is a separate issue that should be left to code officials. That is their job. It should not be the job of LEED to tell code officials they did not apply their codes properly.

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Bill Swanson PE, LEED AP, Integrated Architecture Mar 22 2013 LEEDuser Expert 14487 Thumbs Up

I have a problem with that. LEED keeps claiming to be a 3rd party reviewer. But they're not checking to make sure ASHRAE 90.1 is followed. This came up with the challenge to the LEED rating for the school in Wisconsin. No one did a 3rd party check to make sure the minimum requirements of 90.1 were done. What added value is LEED providing if they're just assuming everyone else does their job?

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Peggy White White + GreenSpec Mar 22 2013 LEEDuser Member 1513 Thumbs Up

Hernando - you may have misunderstood my statement. I was referring to sustainable requirements relating to building material content, not code requirements. For example, VOC levels - not code driven, but some manufacturer's are adjusting them downward in order to play in the sustainable marketplace.

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Hernando Miranda Owner, Soltierra LLC Mar 22 2013 Guest 6759 Thumbs Up

LEED has essentially become an ASHRAE 90.1 code reviewer. They have also become in California a Title 24 reviewer. That they review is not the problem, it is how they review.

Is it really the USGBC's job to tell someone who wrote the Title 24 code analysis software be told they do not understand the code, and made errors modeling a building?

Should a person who is a national energy expert analyst, good enough to be a LEED energy reviewer, and good enough to manage LEED reviews, be told they modeled their project incorrectly by another reviewer?

The above has happened on projects I have been involved with. A top expert who can get though a LEED energy review without comments does not exist.

I know of only a single case where no energy review questions were asked, and that case was related to the person going to work for the USGBC before the LEED review occurred.

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Dwayne Fuhlhage Sustainability and Environment Director, PROSOCO, Inc. Mar 22 2013 LEEDuser Member 1433 Thumbs Up

I'm enjoying this back and forth - I may not need to submit my own comments! I have a few observations on this discussion for now (I guess they count as formal comments):

1. Manufacturers are not over-represented inside the MR and IEQ TAGLEED Technical Advisory Group (TAG): Subcommittees that consist of industry experts who assist in developing credit interpretations and technical improvements to the LEED system. structures. There is no conspiracy. The membership lists are transparent and posted on USGBC's website. There is one manufacturer from the flooring sector on the MR TAG. There are three manufacturer members on the IEQ TAG from the furniture, gypsum and coatings and sealantsA sealant has adhesive properties and is formulated primarily to fill, seal, or waterproof gaps or joints between 2 surfaces. Sealants include sealant primers and caulks. (SCAQMD Rule 1168. )Sealants are used on wood, fabric, paper, corrugated paperboard, plastic foam and other materials with tiny openings, often microscopic, that may absorb or discharge gas or fluid. sectors. I am the coatings and sealants guy and cover a broad range of technologies and applications beyond what my employer makes. A few, but not all, of the manufacturer members were involved in a Cross-TAG discussion on the early MR disclosure and avoidance credit drafts over a year ago. I can assure you that we were not a majority voice.

2. A clarification: In coatings and sealants, VOC content is highly regulated and has been since the 1970s. Some states are more stringent than others. VOCsA volatile organic compounds (VOCs) is a carbon compound that vaporizes (becomes a gas) at normal room temperatures. VOCs contribute to air pollution directly and through atmospheric photochemical reactions (excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides and carbonates, and ammonium carbonate) to produce secondary air pollutants, principally ozone and peroxyacetyl nitrate. are now regulated by code, CalGreen, in California as incorporated by reference. The same 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. regulation is incorporated by reference in the IgCC and the NAHB ICC-700 2012. At least in my industry sector, VOCs are covered by code. Incidentally, those regulations apply to specifiers, purchasers and applicators as well. So in addition to not getting an occupancy certificate if you don't specify compliant products, you can be cited by state regulatory authorities if you cross their regulatory lines as well.

LEED V4 goes several steps beyond regulatory compliance and LEED project specifiers tend to reward manufacturers that have done the best job of eliminating VOCs and other priority chemicals of concern. Keep picking the best, and not necessarily the cheapest, products. We appreciate it and will put some profits back into innovation. It is a virtuous cycle.

3. The MR Building product disclosure and optimization - material ingredients credit structure is far too complex. That is partly due to the reasons that Tom Lent and Eden Brukman have mentioned. But at a fundamental level, I believe it is unworkable. Option 2 requires 25% of the building value to be documented and conformant with GreenScreen Benchmark 1. I work with multiple Living Building Challenge projects and they have trouble sourcing Red List conformant materials. Benchmark 1 incorporates a list of lists far longer than the LBC V2 Red List. I have products that can thread the needle, but they are a relatively low cost percentage for a project and likely will have no reward even if a project team were to reach 25%. The system is dependent on the demand side from practitioners and use of the reward side from manufacturers. I know of a handful of manufacturers that actually understand how this is supposed to work. Will the credit as written reach critical mass and help transform the materials market?

4. Option 3: Product Manufacturer Supply Chain Optimization: As others have stated, the devil is in the details. Who can you trust? USGBC is an organization with more internal and external factions and tensions than the House Democrats. We collectively have to live within the confines of hard political realities. As a small manufacturer (less than 100 employees), Option 3 is simply irrelevant as I have no means to participate. I am not overly optimistic about the 25% threshold, either.

If you choose to trust USGBC and large and vertically integrated multinational corporations to do less bad, this is a positive start. But only the largest producers can participate. Small producers don't have the buying power to force change up the supply chain. Even the largest coating manufacturers have trouble doing that.

I'm not defending the large companies, but I suspect documentation is along the lines of using ISO 14000 and ISO 9000. Those are tough documentation requirements and outside the reach of the vast majority of small and medium sized companies. We don't have the money to hire consultants or the staff to support that level of documentation.

And yes, USGBC is probably responding to external pressures. Life and politics are one and the same at this level of play. We've gone from zero to sixty percent of the commercial building market in in a decade.

5. This is strictly a personal opinion, but based on my interactions with project teams and the many LEEDUser inquiries on LEED 2009, I'd say we collectively need to do a better job of making LEED 2009 work while we wait for LEED V4 to kick in. There is a lot of friction in the system that is causing frustration all the way around.

In the last two weeks, I've dealt with submittal and form requests for LEED projects, two LBC projects, a Florida hybrid version of LEED and an owner's request for information. They all use different forms and documentation requirements. I'm not sensing a lot of love for manufacturers at the moment, but given consistent direction and a little less red tape, you would be surprised what some of us can accomplish to help make your buildings better.

End soapbox discussion...for now.

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Hernando Miranda Owner Soltierra LLC
Mar 20 2013
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6759 Thumbs Up

USGBC as Code Officials

The USGBC has been a code and rules enforcement organization for some time now. They are mush less about green, and more about policy, making up rules, following rules, and then revising the rules when the rules don't work out quite right.

The LEED Foundations Documents require that changes to LEED go through a specific vetting process. That did not occur with this latest enhancement. Instead the change is incomplete. The membership is expected to approve the change. The rules will be made up later by an unspecified committee. Only then will the membership find out what they voted on to approve.

Personally, it seems to me, that the USGBC's release of this latest enhancement is that they see another failed public review comment period coming. They evaluated where the highest resistance was coming from and decided MRc4 Option 3 might get them the votes they needed to pass LEED 4.

LEED v4 is all about getting the votes needed, with the previously proposed massive changes remaining in place. What they USGBC management needs to do, is what we did when we developed LEED v2 and v3--which I helped develop. That is, DO NOT impose a large number of changes with major LEED version changes. Limit the changes to something manageable by owners and teams. Table for future development new ideas that need to be carefully thought out. DO NOT write credits that parrot requirements that should be left to local code enforcement groups.

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Tom Lent Policy Director Healthy Building Network
Mar 19 2013
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1070 Thumbs Up

No pope yet

This credit needs a good rest in the Pilot Library! Let's look at the "papal options":
Regardless of whether they are any good or not, a system that is a condition of membership in the trade association (Responsible Care) or the law of the land (OSHA) have no business being rewarded with points in LEED. Its; supposed to be about Leadership not standard practice or obeying the law.

As for NSF 355, despite the name this standard is not really a "greener chemicals and processes" document as it does not offer metrics or a method (e.g., GreenScreen) to evaluate any of the chemicals reported by the standard and determine their relative health or sustainability anywhere along the life cycle. It does provide standardized data about the chemicals addressed which could facilitate comparisons between chemicals, albeit only "gate to gate" excluding all extraction information. It is quite controversial in the environmental health community as it does not require reporting of endocrine disrupting chemicals. I do not know of a published disclosure under 355 yet.

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Peggy White White + GreenSpec Mar 20 2013 LEEDuser Member 1513 Thumbs Up

What he said...... ;o)

Who exactly framed Option 3? According to the description in Tristan's commentary, Brendan seems to be saying it just fell out of the sky all by itself! Don't be shy Brendan - tell us who created it! Looks like a chemically infused toxic smoke screen to me! I thought this Credit was about transparency.

"Working group" is studying it - who is on the working group? List of names/organizations please!

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Melissa Wrolstad Senior Project Manager, CodeGreen Solutions Mar 20 2013 LEEDuser Member 1799 Thumbs Up

I also agree with Tom. Most of the Option 3 requirements are covered by OSHA. Is the idea of this option that organizations like OSHA should begin to third party certify products where the parties in the product supply chain have no OSHA violations? It's not clear to me how this is "green".

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Max Zahniser Owner, Praxis | Buildings Solutions, LLC Mar 20 2013 Guest 24 Thumbs Up

Something to consider: my understanding is that OSHA is NOT the law of the land in many of the places our building products come from. Many of our products are coming from places without standards, or at least without ENFORCED standards. American and other companies are going to these places to produce there products in part for that very reason (cost avoidance).

LEED has a long track record of not just rewarding leadership, but also incentivizing the spread of the best base standards (codes), to places that haven't yet adopted those standards. I see a lot of potential benefit in driving better practices into those places, and maybe LEED can extend its track record of doing a better job than protestors in picket lines have, at transforming business behaviors.

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Hernando Miranda Owner, Soltierra LLC Mar 20 2013 Guest 6759 Thumbs Up

I am a very long-time proponent of green. I managed green, and documented much of the work myself, for the first ever, not test case, LEED v2 building. I have also certified several LEED Platinum and Gold projects, again by documenting much of the work myself.

LEED used to have a good track record of rewarding green leadership. That is no longer the case.

I find the USGBC arguing with the developers of California's Title 24 energy code, that the developers of the code do not understand the code as well as the LEED reviewers. They also argue with ASHRAE developers that the LEED reviewers know more about ASHRAE standards than they do. I will say, the LEED reviewers do not actually develop the review rules. Those rules are developed by someone else. As Mr. Owens noted, an unspecified "working group" will figure it all out.

As one of the developer of LEED, and vice-chair of the EQ Technical Advisory Group (TAGLEED Technical Advisory Group (TAG): Subcommittees that consist of industry experts who assist in developing credit interpretations and technical improvements to the LEED system.) for several years, as well as a member of other LEED committees, I will only say that after the consensus committees developed LEED credits and basic requirements, the control of rewriting the work we did was given over to some unknown "working group." The working groups had final say. They were not part of the consensus development required by the LEED Foundations Documents. The membership did not get to vote on what the "working groups" came up with. That is still the case as noted by the comments from the USGBC made for this article.

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Marian Keeler Senior Associate, Thornton Tomasetti / Sustainability Mar 20 2013 LEEDuser Member 3320 Thumbs Up

I'll second Peggy's sentiment: Much is made of transparency in materials development, but what about transparency in USGBC's decision-making? Who, what, where, when and why? We need to be fully-informed voters. Better practices are a matter of interpretation and we need to understand why, or even if, these new options are in fact "better" and what led to their inclusion in LEED v4.

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