Review Comments with Phantom Requirements

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Partner ArchEcology, LLC Feb 13 2012 LEEDuser Member
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We are seeing more and more review comments with requirements cited that don't seem to exist specific to our project's registration date and/or rating system. Generally, we are able to pose a further question about these comments that reveals that fact. Last week we got a clarification request on our EQpr2 Environmental Tobacco Smoke documentation for a v2.2 residential project. The comment denied our no smoking lease language and referred to 5 bullet points that must be included in a residential lease. We have never seen these 5 bullet points before. They do not exist in the reference manuals for either NC v2.2 or LEED 2009 NC, neither do they appear in any addenda. So we queried the reviewers on this comment so that they could cite the source of these requirements and confirm they apply to our project.

This is the answer that we received. "The five bullet points included in the review comment for EQp2 are often required by a review team when a residential (or mixed-use with residential) project pursues Option 1 instead of Option 3. The intent of the requirements is to, in the absence of the tests and requirements of Option 3 to minimize leakage and exposure in the event of smoking within a residential unit, ensure that smoking does not occur in residential units."

I'm making this posting not just because of the frustrating nature of the issue but because of the quality of this answer. "Often required by reviewers" is not an appropriate response to a direct question about where this language appears in credit requirements. Apparently the reviewer is not able to cite the requirement but still seems to feel it applies to our project. Somehow.     

This is a Prerequisite. And we are left unsure how to respond to the clarification comment. Are we actually supposed to go back to our client, the project owner, and tell them they have to spend time and money to amend their residential lease to satisfy requirements that we can't point to as applying to our project or our rating system? 

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Bill Swanson PE, LEED AP Integrated Architecture
Jan 20 2017
LEEDuser Expert
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v4 SSc6 - Hardscape requires a minimum of 0.2 fc to be counted

Been awhile since this thread has been used.

This has come up on a project and we lost on appeal so I'm sharing this information with everyone.

Any area being claimed in the wattage baseline calculation must be illuminated to a minimum light level of 0.2 fc1. A footcandle (fc) is a measure of light falling on a given surface. One footcandle is defined as the quantity of light falling on a 1-square-foot area from a 1 candela light source at a distance of 1 foot (which equals 1 lumen per square foot). Footcandles can be measured both horizontally and vertically by a footcandle meter or light meter. 2. The non-metric measurement of lumens per square foot, one footcandle is the amount of light that is received one foot from a light source called a candela, which is based on the light output of a standardized candle. A common range for interior lighting is 10 to 100 footcandles, while exterior daytime levels can range from 100 to over 10,000 footcandles. Footcandles decrease with distance from the light source. The metric equivalent of a foot candle is 10.76 lux, or lumens per square meter..

In the past, if there was a section of a parking lot that the Owner didn't want lights installed I would still claim the square footage of that hardscapeThe inanimate elements of the building landscaping. It includes pavement, roadways, stonewalls, wood and synthetic decking, concrete paths and sidewalks, and concrete, brick, and tile patios. because it created a higher baseline wattage. The reviewers will not permit this practice anymore. An area must be illuminated in order to claim any reduction for it. Meaning wattage must be added if you want to show an energy savings.

The actual comment from the reviewer.
"The energy savings reported for exterior lighting do not appear to be substantiated because it is unclear if only surfaces that are provided with exterior lighting have been included. Note that the uploaded site photometric plans include areas which have as low as 0.01 and 0.02 footcandles. Areas should receive at least 0.2 footcandles of lighting to be considered illuminated. Review the exterior lighting calculations and ensure that only surface area with sufficient lighting has been included. Provide sufficient information regarding the energy inputs in the Section 1.4 Tables and an accompanying narrative to justify the reported energy savings."

Why 0.2 fc as a minimum? Excellent question. It is a phantom rule. There is no mention of this in any USGBC document. I did some searching when this came up and it seems an early draft of the MLO noted a minimum light level of 0.2 fc. The final version of the MLO does not have any mention of a minimum light level. That is the only source I can find. And now LEED has adopted this obsolete language.

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Scott Bowman LEED Fellow, Integrated Design + Energy Advisors, LLC Jan 20 2017 LEEDuser Expert 10984 Thumbs Up

Thanks Bill, good to know. I can see where they are coming from, and you too, but seems like they should issue an addenda with this immediately. To change interpretation mid-stream without notice is not fair.

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Megan Ritchie Saffitz Director of LEED Support, U.S. Green Building Council Feb 02 2017 Guest 1023 Thumbs Up

Bill,

Thanks for reaching out to us in regards to this.
Per ASHRAE 90.1 and LEED requirements, tradable exterior lighting surfaces must be designed to be illuminated in order to be counted in the Baseline exterior lighting power allowance:

For LEED v4 EA Prerequisite: Minimum Energy Performance submittals, ASHRAE 90.1-2010, Section states: “The total exterior lighting power allowance for all exterior building applications is the sum of the base site allowance plus the individual allowances for areas that are designed to be illuminated and are permitted in Table 9.4.3B for the applicable lighting zone."

Similarly for LEED 2009 EA Prerequisite: Minimum Energy Performance submittals, the ASHRAE 90.1-2007 User’s Manual, Section 9.4.5 – Determining Exterior Building Lighting Power Compliance, indicates that the exterior lighting power allowance (ELPA) “is calculated by multiplying each lighted area or width of door opening by the appropriate exterior lighting unit power allowance.”

However, if the LEED ASHRAE 90.1 Exterior Lighting Power documentation confirms that each surface where the exterior lighting power allowance is applied is “designed to be illuminated” or “lighted”, there is no defined minimum threshold that the project must adhere to in order to be counted in the Baseline lighting power allowance. A minimum 0.2 footcandle requirement does not apply.

Note that the IESNA Lighting Handbook recommends a minimum horizontal illuminance level of 0.2 footcandles for basic parking lot lighting applications. To support the claim that the surface is “designed to be illuminated”, a project team may optionally reference these IESNA values. However, this minimum footcandle level is a recommendation only, and is not stipulated by ASHRAE 90.1. Other justification supporting the claim that the surface is “designed to be illuminated” will also be accepted.

We are following up with you offline to ensure this reference to a “0.20 footcandle” requirement is corrected for your project.

Best,
MRS

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Marcus Sheffer LEED Fellow, 7group Feb 02 2017 LEEDuser Expert 69144 Thumbs Up

I agree that the 0.2 fc1. A footcandle (fc) is a measure of light falling on a given surface. One footcandle is defined as the quantity of light falling on a 1-square-foot area from a 1 candela light source at a distance of 1 foot (which equals 1 lumen per square foot). Footcandles can be measured both horizontally and vertically by a footcandle meter or light meter. 2. The non-metric measurement of lumens per square foot, one footcandle is the amount of light that is received one foot from a light source called a candela, which is based on the light output of a standardized candle. A common range for interior lighting is 10 to 100 footcandles, while exterior daytime levels can range from 100 to over 10,000 footcandles. Footcandles decrease with distance from the light source. The metric equivalent of a foot candle is 10.76 lux, or lumens per square meter. is not a definite requirement. But it begs the question about what is considered designed to be illuminated? Any amount of lighting no matter how small? What if I take my photometrics to 0.00000000000001 fc, it that illumination? I checked 90.1-2016 to see if this has been addressed yet and could not find anything. It seems to me that it would be useful to submit an ASHRAE 90.1 interpretation to ask this question and get some definitive answer. Right now USGBC is leaving this wide open to interpretation by individual projects.

It is clearly wrong, and always has been, to claim energy savings for surfaces that are not adequately illuminated. That is like adding building area to the baseline and heating/cooling it as a means to claim additional savings. It is simply not a reasonable or fair comparison.

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Bill Swanson PE, LEED AP, Integrated Architecture Feb 02 2017 LEEDuser Expert 23513 Thumbs Up

It sounds like there just needs to be some sort of defensible position. But then this is gray area.

Maybe something to remember for the next version of LEED to actually have the 0.2 fc1. A footcandle (fc) is a measure of light falling on a given surface. One footcandle is defined as the quantity of light falling on a 1-square-foot area from a 1 candela light source at a distance of 1 foot (which equals 1 lumen per square foot). Footcandles can be measured both horizontally and vertically by a footcandle meter or light meter. 2. The non-metric measurement of lumens per square foot, one footcandle is the amount of light that is received one foot from a light source called a candela, which is based on the light output of a standardized candle. A common range for interior lighting is 10 to 100 footcandles, while exterior daytime levels can range from 100 to over 10,000 footcandles. Footcandles decrease with distance from the light source. The metric equivalent of a foot candle is 10.76 lux, or lumens per square meter. written to make it official. Having a 0.2 fc limit is reasonable to me, I just want it published officially.

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Pat Thomas Principal Sustainability Services
Aug 07 2014
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LEED Interpretation: Effective Date

What is the ruling on when a LEED interpretationLEED Interpretations are official answers to technical inquiries about implementing LEED on a project. They help people understand how their projects can meet LEED requirements and provide clarity on existing options. LEED Interpretations are to be used by any project certifying under an applicable rating system. All project teams are required to adhere to all LEED Interpretations posted before their registration date. This also applies to other addenda. Adherence to rulings posted after a project registers is optional, but strongly encouraged. LEED Interpretations are published in a searchable database at usgbc.org. is effective?? We specified a vegetative roof in 2011 for a project registered in 2011 & completed the submittal for SSc5.1, which is a Construction credit. In October 2012, LEED Interpretation #10231 was published. Now that the building is complete, our construction credits have been reviewed & our vegetative roof is being 'disallowed' due to a LEED interpretation written after construction began. Is this correct ??

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E H Sustainability Architect Aug 07 2014 Guest 4207 Thumbs Up

GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). reviewers should only make projects accountable to LIs and addenda published at the time your project was registered, not after.

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Pat Thomas Principal, Sustainability Services Aug 07 2014 Guest 595 Thumbs Up

Thanks....is this your opinion or the process? I have not been able to find anything on this topic on their websites, either USGBC or GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC)..

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E H Sustainability Architect Aug 07 2014 Guest 4207 Thumbs Up

Yep, it's published . . . http://www.usgbc.org/leed/tools/interpretations

"Project teams must follow rating system addenda based on their project’s registration date."
and . . .
"All project teams are required to adhere to all LEED Interpretations posted before their registration date. This also applies to other addenda. Adherence to rulings posted after a project registers is optional, but strongly encouraged."

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Pat Thomas Principal, Sustainability Services Aug 07 2014 Guest 595 Thumbs Up

You are a godsend.....THANK YOU !!!

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Erika Duran Sustainability Consultant, Dagher Engineering Aug 08 2014 LEEDuser Member 2053 Thumbs Up

Pat,

Also the LEED Certification Policy Manual, For Use With All LEED Rating Systems published January 1, 2012 states this in section 6.2:

" GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). requires compliance with the version of the reference guide including all published addenda, that was in place at the time of the project registration. Project teams may voluntarily elect to pursue certification by demonstrating compliance with a revised version of the reference guide rather than the version that existed at the time such a project was registered."

For some reason the link isn't working but if you email me I can send you the document: eduran@dagherengineering.com

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Pat Thomas Principal, Sustainability Services Aug 08 2014 Guest 595 Thumbs Up

Erika,
Thank you for the additional info.....appreciate it greatly & I already have the manual.
What is very frustrating is the trend expressed in this forum....almost every project I have is experiencing something like this. And, if we didn't follow-up & involve GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC)., the credits would be denied. This particular project has had 4 credits re-reviewed and approved. Granted the projects are not office buildings, but adaptive reuseAdapted reuse is the renovation of a space for a purpose different from the original. of historic properties in hotels, etc. This level of QA is not what I expect from the experts. It appears many are applying their opinions rather than follow the specifics required in the reference guide/documents. I have 3 projects involved in 'reasonable proof of standard practice'.
What happened to the commitment for 'less detailed documentation' ??
Unfortunately, this is also driving the 'cost of LEED' higher, which is not a good trend.

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Erika Duran Sustainability Consultant, Dagher Engineering Aug 08 2014 LEEDuser Member 2053 Thumbs Up

I have to say that many of those frustrating comments seem to be "canned responses" meaning they just put them there from the get go to give you some sort of grief during the first design review. Its a pain point for sure.

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Pat Thomas Principal, Sustainability Services Aug 08 2014 Guest 595 Thumbs Up

I also thought some of the comments were 'canned responses' however evidently not, since the credit was denied & we are now in appeal. I have found the conference call method prudent(essential) prior to final clarifications.
Again, thanks for your insight.

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Hernando Miranda Owner, Soltierra LLC Aug 08 2014 Guest 13801 Thumbs Up

I have certified a lot of high level LEED projects, meaning I am the person who has responed to the review comments. This is what I have learned:

- RG revisions and addenda up to the registration date can be overridden by the person doing the review.

This is not right, of course. How is this allowed? Well, if the reviewer makes an error, or decides to give you a hard time, the review comment stands as written. You must respond to the comment regardless of whether the reviewer properly followed the rules or not. I have been forced to comply with a change to LEED that occurred as late as after the project was under construction.

Here is another observation:

- Claiming an ECMEnergy conservation measures are installations or modifications of equipment or systems intended to reduce energy use and costs. (Exceptional Cost Measure) for EAc1 can completely undo a project's certification process.

The above happened to a project of mine where the energy savings for a highly-specialized process load (aquatic life support for medical treatment and isolation) where challenged by some "unidentified" expert who was evidently hired by the LEED reviewer (the GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). used an outside reviewer firm) to conduct a "special" review.

The special review challenged things such as the working schedule. The schedule was identical in both energy use cases, so the argument was about proving when the process loads were actually used during a year. In other words, we were forced to "accurately" predict unknown future illnesses of different aquatic species, and to backup the proper water temperatures of the medical life support tanks.

The real undoing of the life support challenged project was a demand to have other engineers of similar systems, that were designed locally, provide letters stating what the standard non-energy efficient design was. It made no difference to the GBCI that there are only two qualified firms in the U.S. who can design such a system for large aquariums.

It is essentially impossible, for liability reasons, to get another engineer to provide a letter stating their design is not "that good," and the owner will have to spend more money on energy. It is unreasonable to get a letter from your only direct competitor, especially when the two companies are challenging each other, for marketing reasons, of using as many energy saving techniques as they can fit into a project.

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Bill Swanson PE, LEED AP Integrated Architecture
Jul 31 2014
LEEDuser Expert
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Site lighting and unlit surfaces

On the submittal form for SSc8 there is some new language that was added on the 4.0 Version of the document. Right before Table SSc8-2 there is text that says, "Include only surfaces that are provided with lighting. Unlit surfaces cannot be claimed for additional lighting power allowance."

This is not part of the credit language and is not even mentioned in the Reference Guide. I would think it can be ignored.

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Bill Swanson PE, LEED AP, Integrated Architecture Jul 31 2014 LEEDuser Expert 23513 Thumbs Up

Table SSc8-2 is for untradeable surfaces. I guess if you don't have a light over an ATM then it's not like there is any benefit gained. It's still adding words that are not part of the credit language.

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Marcus Sheffer LEED Fellow, 7group Jul 31 2014 LEEDuser Expert 69144 Thumbs Up

The "added" language is there to provide clarity. A number of projects are attempting to include unlit areas. This adds to the baseline LPDLighting power density (LPD) is the amount of electric lighting, usually measured in watts per square foot, being used to illuminate a given space. without adding anything to the proposed LPD and therefore overstates the savings. It is just not a fair comparison. The description of how to do the LPD calculations is contained in the ASHRAE 90.1-2007 User's Manual. It clearly states that the "lighted area" is to be used. In addition to the credit language and the Reference Guide, the referenced standard comes into play as well.

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Erika Duran Sustainability Consultant Dagher Engineering
Apr 11 2014
LEEDuser Member
2053 Thumbs Up

Reasonale Proof that a measure is not Standard Practice

Anybody know where LEED obtained the definition of standard practice or non standard practice? I just got review comments on a credit where they are requiring me to cite three similar project constructed within the past 5 years as reasonable proof that a measure is not standard practice.

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Hernando Miranda Owner, Soltierra LLC Apr 11 2014 Guest 13801 Thumbs Up

This is reviewer nonsense. I have run into this before. In my case the reviewer demanded that an industry survey be conducted for process loads for a very complex life-support system. The system has only two qualified engineering firms in the U.S. that can design it. Well, you cannot survey yourself and your competitor. Worse, if design standard is to go beyond the minimum, to give you an green-edge over your competitors, you are deemed to not be green at all.

There is no way you will be able to get documentation to the level necessary to satisfy the LEED reviewers, for projects other than your own. This because those business competitors will not share that level of data with you. You are stuck referencing your own projects, and the reviewers will fault you for not documenting detailed supporting data from other firms. Pure Catch-22.

Ugly as it is, the is USGBC basically telling you to "design your systems for non-LEED projects to be energy inefficient, so that when you do a LEED project you can claim how efficient your project is by comparing it to your non-efficient projects."

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Scott Bowman LEED Fellow, Integrated Design + Energy Advisors, LLC Apr 11 2014 LEEDuser Expert 10984 Thumbs Up

This does seem very weird. My assumption is you are proposing something and an improvement that you feel is not standard practice, and they are pushing back, wanting PROOF that it is not standard practice. That is really hard to prove, I agree with Hernando. What if your firm does something that has not caught on or picked up by others yet…so if you compare to your work, it is standard, but not to the industry.

This concerns me that GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). does not have enough practitioners in its ranks, or they are not being deployed correctly. Anyone with experience would know what is standard for this time and place, and if they don’t for some reason, they can call someone they know and trust to find out. I know those professionals exist in GBCI, I have met many and find them quite knowledgeable and helpful.

Maybe there needs to be access to a panel of professionals for things like this, as advisors to the reviewers. I would volunteer for that kind of role.

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Hernando Miranda Owner, Soltierra LLC Apr 11 2014 Guest 13801 Thumbs Up

Scott,

The problem is that the GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). has to follow rules invented by the USGBC's LEED Department. The rule making body is divorced from the reviewing body. The USGBC's LEED Department is filled with policy developers who have no real experience with designing buildings, and who have little experience with what is actually required to certify a LEED building.

Ten years ago I proposed to the LEED Steering Committee that LEED needed a public advocacy group (aka, ombudsmen team) to intervene when the LEED reviewers made unreasonable demands. The proposal was instantly criticized by the then VP of LEED. No one on the Steering Committee was allowed to make a comment before the VP of LEED finished his concentrated attack on the proposal. The Steering Committee decided it was best to leave things as they were to not further upset the VP of LEED. Why was the VP so upset, they were horrified that someone they would have no control over would be looking over their shoulder.

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Mara Baum Healthcare Sustainable Design Leader, LEED Fellow, HOK Apr 11 2014 LEEDuser Member 9916 Thumbs Up

If there's a GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC)./USGBC person lurking on this forum, now would be a great time for you to comment.

This is a very common comment/request for 2009 projects. If you receive this for a v2.2 or other pre-2009 system, punt it back to the reviewer. Sometimes reviewers have their 2009 hat on when reviewing v2.2 projects.

"Innovative" is a subjective concept, which is why they ask you to demonstrate that it is innovative by explaining how it goes beyond "standard" practice - although also subjective, standard practice is easier to demonstrate. Think of your strategy as "standard until proven innovative". It's a hassle, but *in theory* it prevents gaming the system. In reality it creates an advantage to people who certify a lot of projects and have a lot of experience with ID credits. (Please note that this is an explanation - it doesn't mean that I agree with the approach.)

You should try to engage in an email dialog with the reviewers if you're unclear how to do this for your specific issue. However, they are unlikely to drop the request.

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E H Sustainability Architect Apr 11 2014 Guest 4207 Thumbs Up

What prereq/credit is the comment in regard to? It sounds like the reviewer is referencing LI#10291 for EAp2. If you are taking credit for energy savings that fall outside ASHRAE established baselines you will need to justify how you arrived at the standard to compare your project to.

I can see where the reviewer is coming from. If you are doing something innovative you will need to back up those claims as to how your approach is quanitively better than an established baseline. The point of the 5 year limit is to ensure that your claim is indeed a current standard and that you are not inflating the level of innovation by comparing it to an outdated standard of practice.

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Hernando Miranda Owner, Soltierra LLC Apr 11 2014 Guest 13801 Thumbs Up

Well, we did punt back to the reviewers for the LEED v2.2 project with special life support systems I mentioned. We responded by telling the reviewers that at the time the design decisions were made that standard equipment could be purchased that was not as efficient as the equipment that was designed into the project. The reviewers claimed that "recent" unnamed LEED projects had previously document similar efficient equipment, and therefore the project could not earn innovation credit since other projects had already done so. The project DID NOT apply for a LEED innovation credit of these special process load system. All efficiency claims weer included only as part of EAc1.

The reviewers had the gall to demand that an industry survey be provided with the first review comments. With the second review comments they made reference to an industry survey and conveniently failed to name the survey. Why the GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). was forced this comment from the LEED reviewer is a real mystery. If they want a particular survey used, then the reviewers should have named it up front.

What was really ugly about that project was that these external loads represented more than 97% of the EAc1 loads. The building and its loads were less than 3% of the energy use total. Both the building and process loads were between 38-39% more efficient, very close to the same performance. The building included internal process loads that were well above the 25% minimum requirement.

The building on its own was accepted by the reviewers meeting all LEED requirements. The same number of EAc1 points would have been claimed if the life support systems were entirely removed from LEED. But, were not allowed to remove the systems by the GBCI and go through a appeal process.

Even more odd, we had evidence of a LEED certified project that earned a similar 38% efficiency for the same type of life support systems. We also had evidence of a similar LEED certified project the excluded the life support system, and this systems were internal to the building, and not external loads.

The end result was the the the owner of the project abandoned the USGBC and LEED. They committed to doing all their project using LEED and backed out. The owner was one of the most committed green organizations I have every worked with. Sustainability was integrated into their everyday practices. The food served in the on-site cafeteria was sustainable. They offer regular environmental educational programs free to the general public.

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Hernando Miranda Owner, Soltierra LLC Apr 11 2014 Guest 13801 Thumbs Up

I disagree with you E H.

What the "standard" practice and 5-year rule fail to take into account is the actual design, construction and LEED certification process.

If a small, fast-track, project completes LEED before a multi-phase, many year, project, which started design long before the small project, then than later project sets the LEED standard.

ASHRAE has no established baseline for process loads analysis. Process loads analysis and setting a baseline is entirely subjective.

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Erika Duran Sustainability Consultant, Dagher Engineering Apr 11 2014 LEEDuser Member 2053 Thumbs Up

Everyone is giving really great answers - honestly never thought of referencing other projects of ours that were inefficient to support my "more efficient" project claims. Not sure if we have any of those. Didn't think people did that but I bet they have and I wouldn't blame them (this is such a pain)

My frustration stems from what Hernando is saying where other similar projects using a similar strategy were approved and now new items are being brought up with different supporting requirements.

It's like if you were playing basketball and every time you got on the court, the rules have changed.

I get that the system is constantly being updated and revised to address items that were missed or not addressed. However, it really makes you wonder how much you can trust a rating on any building when it doesn't seem to be held to the same standard year after year.

We are constantly uncertain of what will be approved or not approved even if based on prior projects. If your project gets approved this time around but not then next time around; and you think about all the other millions of square feet that are LEED certified and how "compliant" they were.

The comment is with regards to EAp2 and we are going back and forth on a 90.1 exception - the project is NCv2009 and the review team is referencing the Technical Manual for v2.0 but even this manual states "...it is not considered a precedent setting document. The rating system supersedes the content of this manual in case of any conflicts."

Again looping back to the original argument. We are discussing with the review team and really focusing on the language of what the required referenced standard indicates.

To a certain extent I feel like you have to demonstrate that you are playing by the rules that were set forth and not by what the players of the game are dictating because they have revised their strategy to deal with what that team or other review teams have requested. If that makes any sense.

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Marcus Sheffer LEED Fellow, 7group Apr 11 2014 LEEDuser Expert 69144 Thumbs Up

The generalities discussed here make it very difficult to develop a reasonable response to help you deal specifically with this issue but I will try to deal with it in general terms.

It sounds like you are claiming energy savings related to an energy saving exceptional calculation. In this scenario the establishment of the baseline is up to the project team. The reason for this is that quite often establishing a reasonable baseline for very specific strategies is a significant research project in and of itself and the reviewer cannot be expected to do so within the confines of the time we are allowed to spend on an individual review. If whatever industry has not done so, then LEED has no reference or established baseline. Also reasonable baselines vary by location and strategy as well as changing over time. For example, parking garage CO ventilation control is required by some codes in some areas and is not required by others. So in Oregon it is the law and projects cannot claim savings for doing something they are required to do anyway. Projects that did so before the law took effect could reasonably claim savings but afterward it is not reasonable savings. So requirements, laws and the standardization of specific strategies change and the project's registration date has always been the date that establishes precedence. I understand this is frustrating as I have been on both sides of this issue. I tried to claim energy savings related to infiltration reduction in about 2004 and 90.1-2013 has not yet established a defined reasonable baseline for a commercial building. These things apparently take time.

Some baselines are well established for things like food service equipment (LEED Retail), boiler efficiency and premium motors (both 90.1). I have long advocated for USGBC to provide more guidance on this baseline issue but it has not risen to the top of the pile yet apparently.

So back to your original post in this thread. Did the reviewer comment offer any other options for you to defend your baseline? The standard review comment typically includes additional options for establishing a reasonable baseline. Can you share the strategy for which you are claiming savings?

It is often very hard to determine a reasonable baseline for a project team spending many hours evaluating options and trying to determine reasonable savings. For a reviewer to do so within the 3 hours or so they get to evaluate it can be impossible. I do agree that USGBC could do a much better job of providing project team guidance on this subject so the best advice I can give anyone is to submit an Interpretation to get some feedback before you go to the review phase.

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Hernando Miranda Owner, Soltierra LLC Apr 11 2014 Guest 13801 Thumbs Up

Marcus wrote, in part: "I do agree that USGBC could do a much better job of providing project team guidance on this subject..."

The problem I experienced was no guidance was provided. Being told to conduct an industry survey is entirely unreasonable. There is no statement in any of the mass of LEED documentation that justifies such a demand being made by a reviewer.

Later, we learned that the reviewer did have non-LEED-based guidance they could have provided, but they chose to keep the name of the guidance document a secret.

The solution is simple: If published LEED requirements do not exist the reviewers are not allowed to create their own requirements.

For process loads the two most important things to do are: first, establish a reasonable baseline based on the design phase of the project. Second, make sure the operational schedules are identical between the baseline and proposed case.

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Hernando Miranda Owner, Soltierra LLC Apr 11 2014 Guest 13801 Thumbs Up

Erika,

Below is a small part of the very long response we received in the second review. The demand was made over three years ago.

"a listing of several other newly constructed, similar facilities with the design properties used for those facilities along with a statement from the engineer of record stating that these designs are standard practice for newly constructed facilities in the project location."

The demand made is entirely unreasonable.

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Marcus Sheffer LEED Fellow, 7group Apr 11 2014 LEEDuser Expert 69144 Thumbs Up

I agree that if this was the only option offered it is unreasonable.

I think USGBC should provide better baseline guidance for projects pursuing process savings in general so project teams have a better idea of what will and will not be acceptable before it gets to the reviewer.

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Hernando Miranda Owner, Soltierra LLC Apr 11 2014 Guest 13801 Thumbs Up

Agreed Marcus. The USGBC's LEED Department has created some review rules that are unreasonable. The GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). tries to enforce the rules that are often misinterpreted by the reviewers.

There were no other similar, newly constructed, facilities in the project location, region, the State, and in the majority of the U.S. The comments were received were extraordinary in breathe. And, they took much longer than three hours to write. I don't know how the cost of the review that was done was justified.

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Neil Rosen Director of Sustainability Northwell Health
Oct 01 2012
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717 Thumbs Up

CI V3 - SS Credit 2 - Community Connectivity

I am working on a CI project and have recently received a design review which has requested that I modify my credit submission for SS C2. The reviewer states "However, the listing of community services counts the medical or dental office service two times (NS Dental Center, and NS University Hospital). Please note that with the exception of restaurants, no service may be counted more than once in the calculation"

I find this an interesting comment on 2 fronts...for one, I have had this exact same credit approved on 2 other projects located in the same building...

AND

The sample Map for Community Connectivity on page 71 of the ID + C Reference Guide indicates a Medical office # 6 AND a Dental office # 7...

Did I miss the memo changing this credit somewhere along the way???

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Marcus Sheffer LEED Fellow, 7group Oct 01 2012 LEEDuser Expert 69144 Thumbs Up

Prior approval on a project does not mean it gets approved the next time. Reviewers are human and miss things sometimes.

Sometime even the examples in the Reference Guide are not correct but in this case I think it is correct.

I do think you are right and the reviewer is mistaken to question this issue. A medical and dental facility are two separate and distinct services. The whole idea of the credit is that people in the building can easily access a variety of services. I think you could pretty easily make the case that people would visit the dentist and the doctor separately.

The reviewer seems to be hung up on the "or" in the credit language. One could interpret that as "one or the other" as well as "either one". I would certainly view it as the later.

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Scott Bowman LEED Fellow, Integrated Design + Energy Advisors, LLC Apr 11 2014 LEEDuser Expert 10984 Thumbs Up

I have to agree with Marcus, perhaps you should ask for a conference call to see if this can get resolved before you have to appeal. That has worked for us on a couple of issues.

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E H Sustainability Architect
Jul 06 2012
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4207 Thumbs Up

Bike Rack requirements for buildings outside project scope

We are being required to prove that adjacent buildings will not use our bike racks. This is not a LEED requirement. I can see where the reviewer is coming from because the building is located on a campus, but the building is still and individual project, with individual certification. It seems unfair to arbitrarily add LEED requirements. I could not find this requirement anywhere in LEED guidance.

Reviewer:
This requirement is applicable to all projects where it appears that the facilities may be shared. We regret an inconvenience that documenting this requirement may cause, but would like to remind you that there are two options for demonstrating compliance. 1) A statement, signed by the building/property Owner or manager, may be provided to verify that the use of the bicycle storage facilities is exclusive to the occupants of the project buildings and signage provided to so indicate. Or, 2) Documentation, such as revised site plans and supplemental calculations, may be provided to demonstrate that sufficient bicycle storage facilities have been provided to serve all occupants, including occupants that are not part of the project, with access to the amenities.

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Hernando Miranda Owner, Soltierra LLC Jul 06 2012 Guest 13801 Thumbs Up

Just more new review nonsense from the reviewers.

It appears that the reviewers are insisting that the multiple-building rules (AGMBC) must be used for any standalone LEED project on a campus.

What if the campus is a large university? Are the reviewers demanding that a LEED building more than 200 yards from a non-LEED building prove that the non-LEED building occupants do not use the bike racks provided for the LEED building? Oops, "reviewer discretion" used to justify this type of demand seems to have missed a major part of the requirement; bicycle storage and showers must be within a certain distance to be claimed.

Previously, I have seen new demands about LEED NC is a "whole building rating system" which is being taken as a demand to document parts of a project not only outside the scope of work, but that are inconsistent with the LEED 40:60 certification rules which helps determine which rating system should be used to certify a project that could be under two LEED systems.

The 40:60 rule means of a project is 40% one LEED system type (NC, CI, CS, etc) and 60% another system type, then the project is free to use whichever LEED rating system they choose. But, what is happening is if you pick LEED NC and are partially LEED CS you are required to follow optional credits in CS as mandatory in LEED NC. The reviewers shoe-horn the CS credits into LEED NC credits the project is pursuing.

This review nonsense absolutely has to stop. There are no published rules provided by the USGBC for the GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). and LEED users to follow. The Reference Guides have become useless. You now have to guess what the project requirements are, and worse, could possibly be.

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E H Sustainability Architect Jul 06 2012 Guest 4207 Thumbs Up

To be fair, there is another campus building (probably within 200 yrds) of our bike racks. That project is also going for LEED certification, but they are under a different design contract, we are not part of their design or LEED pursual.

Regardless, it is still not a LEED requirement for an individual building to accommodate other buildings outside its scope. What is even more frustrating is discovering these additional requirements late in the game after design work is done and construction started. Maybe the owner would have been willing to accomodate this requirement or have picked a different location for the racks, or whatever. If we could just have known about this early in the design before submitting for certification.

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Hernando Miranda Owner, Soltierra LLC Jul 06 2012 Guest 13801 Thumbs Up

The text below is from the AGMBC, dated October 31, 2011. This was more than likely released after your project was registered for LEED. To invoke the AGMBC you have to create a Master Site as defined by that document.

You haven't created a AGBMC LEED Master Site. You are not required to. Yet, the requirements are being imposed on your projects. Worse, these requirements were created late last year, meaning they shouldn't be applicable.

LEED campus boundary:
The site area defined as the LEED project boundary for all campus credits. This may be the legal limits of the shared site (e.g. property boundary) or an alternative boundary for LEED purposes. The LEED campus boundary must be a single unbroken site, unless the non‐contiguous parcels meet the conditions stated in the MPR Supplemental Guidance.

LEED Project Boundary:
The portion of the project site submitted for LEED certification. For single building developments, this is the entire project scope and is generally limited to the site boundary. For multiple building developments, the LEED project boundary may be a portion of the development as determined by the project team.

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Susan Walter Specifications Director, Populous Jul 06 2012 LEEDuser Expert 22591 Thumbs Up

While I agree with Hernando that the AGMBC does not have to be implemented just because your project is on a campus, I also see the poorly stated review comment EH's project received. When it comes to site amenities like bike racks, i believe that the GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). is trying to ensure that they are not counted twice. This has forced me into understanding our clients overall sites and accounting for things repeatedly. For example, I have a bike rack in front of a non LEED building with a capacity of say 8 slots. This non LEED building would take 5 slots if it were LEED (yes, running FTEFull-time equivalent (FTE) represents a regular building occupant who spends 8 hours a day (40 hours a week) in the project building. Part-time or overtime occupants have FTE values based on their hours per day divided by 8 (or hours per week divided by 40). Transient Occupants can be reported as either daily totals or as part of the FTE.

Residential occupancy should be estimated based on the number and size of units. Core and Shell projects should refer to the default occupancy table in the Reference Guide appendix.

All occupant assumptions must be consistent across all credits in all categories.
calcs for a non LEED project). For my adjacent LEED project, that left 3 slots I can count for that project. For the third project that is also LEED, I'm out of racks and have to add them into the project site. But when I document, I run them through the math all over again including FTE information for all 3 projects. It is a pain but now that i know, it is done and done consistently.

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Hernando Miranda Owner, Soltierra LLC Jul 06 2012 Guest 13801 Thumbs Up

Susan,

I am doing something similar for a complex campus project. There are four primary buildings. One is not LEED. Two are LEED NC v2.2 which are my LEED projects. One is LEED NC 2009 by a different LEED Consultant. We cannot use the LEED Online AGMBC documentation path because it is restricted to LEED v2009 only. Instead I am providing common LEED documentation for all three projects, making sure the most strict requirements for the two versions of LEED NC are met.

Long ago --about 2-years-- I decided that the right thing to do to get around the ever changing reviews was to document the entire campus.

We have a total campus occupancy FTEFull-time equivalent (FTE) represents a regular building occupant who spends 8 hours a day (40 hours a week) in the project building. Part-time or overtime occupants have FTE values based on their hours per day divided by 8 (or hours per week divided by 40). Transient Occupants can be reported as either daily totals or as part of the FTE.

Residential occupancy should be estimated based on the number and size of units. Core and Shell projects should refer to the default occupancy table in the Reference Guide appendix.

All occupant assumptions must be consistent across all credits in all categories.
count, with visitors as well as retail customers. We have distributed the bike slots based on estimated usage of each of the four primary buildings.

Not only have we included bikes, but did the same distribution and allocation for carpool parking for SS Credit 4.4 and similar for low-emitting vehiclesLow-emitting vehicles are classified as zero-emission vehicles (ZEVs) by the California Air Resources Board..

I expect to run into trouble for the location of parking for green cars for SS Credit 4.3. The vehicles are owned by the owner and are parking in an interior secure parking lot. The vehicles are in closest parking spaces to the three LEED buildings but there are closer parking spaces to the the non-LEED building. The trouble with the closer spaces is that they are intended for employee parking which are outside the secure lot.

The two projects will be submitted for review in the next month. I will fill you all in on the results. The owner is pushing for three LEED Platinum projects. We'll see how it goes.

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Megan Ritchie Saffitz Director of LEED Support, U.S. Green Building Council Jul 09 2012 Guest 1023 Thumbs Up

Dear E.H. - We'll contact you offline to review your concerns specific to your project. For anyone else, if you ever have any questions or concerns relative to your review comments, you can always get in touch with us - including your LEED Reviewer - by selecting "Questions About Review Comments" from http://www.gbci.org/org-nav/contact/Contact-Us/Project-Certification-Que.... If we aren't able to resolve your issue by email - or you just want to talk through it - selecting "Follow Up to Prior GBCI Reply" from the same url will give you the option to request a phone call with your LEED Reviewer. Hope this helps - MRS

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E H Sustainability Architect Jul 12 2012 Guest 4207 Thumbs Up

I recieved a reply back that clarifies the intent of this requirement. It is a requirement that I was not aware of, or did not undestand, until now. And, it is definitely a requirement that all projects should be aware of as is affects how buildings chose to locate their racks.

Response: The intent of SSc4.2 is to reduce pollution and land development impacts from automobile use by providing bicycle racks for 5% or more of all LEED project users, and shower and changing facilities for 0.5% FTEFull-time equivalent (FTE) represents a regular building occupant who spends 8 hours a day (40 hours a week) in the project building. Part-time or overtime occupants have FTE values based on their hours per day divided by 8 (or hours per week divided by 40). Transient Occupants can be reported as either daily totals or as part of the FTE.

Residential occupancy should be estimated based on the number and size of units. Core and Shell projects should refer to the default occupancy table in the Reference Guide appendix.

All occupant assumptions must be consistent across all credits in all categories.
of the LEED project building. This means that bicycle racks for 5% of all LEED project users must be available to the LEED project occupants at all times.

So, if there is potential for the racks to be used by people outside the project, you must account for that increase in use, locate them in a secure location where only building occupants can access them, or install signage to deter others from using them. I could see this being a problem in campus projects (like ours) or urban settings where you may want to locate racks out front near the building entrance.

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Hernando Miranda Owner, Soltierra LLC Jul 12 2012 Guest 13801 Thumbs Up

But, "of all LEED project users" means your LEED project only and nothing outside of the project boundary. LEED Project boundary is clearly defined in the LEED MPRs and certification requirement documents.

LEED Project boundary is how projects have been certified since day 1 of LEED. This is something "new" and undocumented.

This is a new requirement that was recently "invented" and is now being enforced without the USGBC/GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). bothering to update the LEED Reference Guides via an appropriate addenda.

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Bill Swanson PE, LEED AP, Integrated Architecture Jul 12 2012 LEEDuser Expert 23513 Thumbs Up

Do we similarly require parking lots to have signs that say spaces may only be used by occupants of this building?

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Hernando Miranda Owner, Soltierra LLC Jul 12 2012 Guest 13801 Thumbs Up

This "rule" would force every LEED project on a campus to use the AGMBC regardless of the owner's intent to certify only one building.

The LEED Project Boundary needs to be selectively expanded, based on the credits pursued, to comply with this new demand, and worse, there are no rules about exactly what the USGBC/GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). wants you to do.

We are left to guess and make up our own rules and wait until the reviewers tell us we were wrong, because new requirements were published just the week before, long after your project was registered, and even after it was submitted for review. Amazing...

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Maura Adams Environmental Stewardship Manager Jul 12 2012 Guest 2716 Thumbs Up

Bill Swanson: Yes. I just got a review back saying that the reserved parking spaces need to be for building occupants only. I don't think the rest of the spaces would need to be designated LEED building-only.

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Bill Swanson PE, LEED AP, Integrated Architecture Jul 12 2012 LEEDuser Expert 23513 Thumbs Up

My comment was intended as sarcasm. Seems I was beaten to the punchline.

Don't all of these signs start reducing the sense of community? Regardless, this is scope creep. There is no mention of restricting access in the Credit language. And what's the point, it's not like any of this signage gets enforced. Why be so super strict in documenting something that is so fluid? I love the fail photo here.
http://www.reallifeleed.com/2008/10/leed-and-parking-lessons-learned.html

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Hernando Miranda Owner, Soltierra LLC Jul 12 2012 Guest 13801 Thumbs Up

On my middle and high school projects -- more than 10-- bike racks are rarely used. Bike riding is not cool. Skateboards are cool.

Skateboards wind up stuffed in lockers, much to the unhappiness of school officials.

I created a LI asking for an equivalence to bike spaces for kids that to securely store their skate boards. Seems logical. Anybody who has kids knows that skateboarding is a preferred method of getting to school, unless a kid is lucky enough to have a car.

Well, the USGBC decided that skateboards were not a preferred mode transportation for kids. They stated that a usage study must be conducted to prove kids would actually use skateboards to get to school. How the usage study was to be conducted was not defined by the USGBC. A study certain to be rejected as inadequate by the reviewers based on some criteria only they have access to.

We dropped pursuit of this option, and now have LEED accepted bicycle parking that is mostly unused. Skateboards continue to be stuffed in lockers.

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Erika Duran Sustainability Consultant, Dagher Engineering Apr 11 2014 LEEDuser Member 2053 Thumbs Up

I inquired about citi bike being able to contribute to this credit and it was denied although it does meet the intent. There should be more options or flexibility with this.

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Hernando Miranda Owner Soltierra LLC
May 05 2012
Guest
13801 Thumbs Up

Where do special review requirements come from?

I have documented LEED projects since the dawn of time. Well, at least since the first certified NC v2 project that was not a special test case: Ford Premier Automotive Group NA vs. PNC Firstside Center. I also helped develop LEED CI and was vice-chair of the LEED IEQ Technical Advisory Group for several years; unpaid volunteer positions.

At least back when I was helping develop LEED NC v2.2 I can state for an absolute fact, that what the Technical Advisory Groups develop for LEED had no bearing on the final requirements that somehow appear in the LEED Reference Guides, the Forms (Templates), and the reviewer cheat sheets. The rating systems yes, but not the details below.

I also tell you that I was told by the USGBC VP of LEED (long gone), when I complained that requirements the Technical Advisory Group had drafted had been tossed and haphazardly been rewritten without the following the LEED development rules, something to the effect: "You are an Advisory Group only. We (the USGBC) do not need to use what the Groups develop. We have outside consultants paid to develop technical content."

Figure out who those outside consultants are and I am certain you will find them heavily involved today inventing new LEED requirements. Some of those consultants likely still work on certifying their own LEED buildings. LEED Consultants were working on their own LEED projects, writing Reference Guides, developing Forms and Templates, and reviewing their competitors LEED projects. In the past this was the case, and it appears to still be the case with the exception of reviewing LEED projects.

Unfortunately, if my thoughts about how these hidden requirements get invent are true, then we don't get to find out about them until the LEED Review. Others know about them, and use them to their advantage, long before you learn they even exist.

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Hernando Miranda Owner Soltierra LLC
Apr 13 2012
Guest
13801 Thumbs Up

Task Lighting Required at Copy and Fax Machines

In December of 2010 a LEED project that was certified as Gold was denied the Lighting Controls credit because task lighting was not provided at copy and fax machines.

The reviewer claimed that the machines were work areas that required task lights. The machines were provided in a internet room provided by the owner for temporary use by residential tenants. Regardless, the reviewer stuck with their demand and denied the credit.

I helped write the task lighting requirements for this LEED credit when I was the vice-chair of the LEED EQ Technical Advisory Committee. I know what was and what was not intended. Only one project of mine out of 100 has every had this demand made.

Has anyone else ever run into this?

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Bill Swanson PE, LEED AP Integrated Architecture
Apr 12 2012
LEEDuser Expert
23513 Thumbs Up

v2.2 CIR applied to v2009

In another thread on this page, a LEED Reviewer mentioned being able to apply v2.2 "LEED Interpretations" to v2009 projects. That did not make sense to me. After digging around for a bit it appears to be allowed. And this may be a source of many phantom requirements.

I'm wondering why? There was suppose to be a clean break in LEED Interpretations between v2 projects and v3 projects. USGBC came up with the "addenda" thing to issue offical changes for v3 updates and modifications. Now we seem to be back to having to hunt thru Interpretations for any possible applicability to the current project.

The example given was #5232. Issued 9/2/09. When I search the GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). database it shows up. And apparently there is a tab called "Applicability", (that doesn't look like a tab until after you click on it). And sure enough it says it may apply to New Construction v2009 projects.

But I don't know it exists unless I'm told it exists. If I do my due dillagence and search for the key word "Tenant" and filter the search to the rating system "New Construction v2009" and the category "Energy and Atmosphere" I only get (15) results that show up. Not one of them is this #5232. (Only 3 are dated after July 1, 2009 so the other 12 should not have even shown up in a search)

If USGBC wants to use the "addenda" format for updating v2009 requirements then only use addenda. Let's try to keep everyone playing from the same rule book.

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Hernando Miranda Owner Soltierra LLC
Apr 12 2012
Guest
13801 Thumbs Up

Tenant Guidelines Now Required for all NC projects

A new unpublished mandatory requirement for LEED NC is that if the project includes any lease spaces non-mandatory Tenant Green Guidelines must be provided to the future tenants.

The above occurred on a project with less than 10% lease spaces. The spaces included HVAC VAVs and were core and shell spaces. The worst case occupancy and usages were assumed when the spaces were included in the LEED points submitted: Bikes, Parking, Energy with No Efficiency Claimed for Lighting, Ventilation, Water Use, Construction IAQIndoor air quality: The quality and attributes of indoor air affecting the health and comfort building occupants. IAQ encompasses available fresh air, contaminant levels, acoustics and noise levels, lighting quality, and other factors. Practices and Testing. Everything was covered for what is in the scope-of-work for the project.

Evidently, the above is not enough. The LEED NC v2.2 and 2009 Reference Guide make no mention of a mandatory requirement to provide Tenant Green Guidelines. During a conference call with Sarah Alexander of the GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC)., she confirmed that this a clear requirement for any project with any amount of core and shell space. She based the requirement on LEED interpretations from 2004 and 2005 that were for Core and Shell projects using LEED NC as the rating system rather then LEED CS.

It doesn't seem to matter that our project is LEED NC. Evidently these guidelines have been required of all LEED NC projects, apparently since 2004. I have worked on over 100 LEED NC projects and this has never been demanded.

Tenant Green Guidelines are an optional credit for LEED CS. To earn the credit the Guidelines must be part of a lease agreement. For LEED NC the phantom requirement is for Tenant Green Guidelines is not optional and they are not mandatory.

Has any one else been subject to this new phantom requirement? I want to find out if the GBCI has forced ALL LEED NC projects with any amount of CS space to provide Tenant Green Guidelines.

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Samantha Harrell LEED Project Reviewer certificate holder Apr 12 2012 Guest 3161 Thumbs Up

Hi Hernando,

LEED InterpretationLEED Interpretations are official answers to technical inquiries about implementing LEED on a project. They help people understand how their projects can meet LEED requirements and provide clarity on existing options. LEED Interpretations are to be used by any project certifying under an applicable rating system. All project teams are required to adhere to all LEED Interpretations posted before their registration date. This also applies to other addenda. Adherence to rulings posted after a project registers is optional, but strongly encouraged. LEED Interpretations are published in a searchable database at usgbc.org. 5232 supports this requirement and is applicable to NCv2.2 and v2009 projects. By applicable I mean that the LI database indicates that project teams and reviewers may refer to the ruling for projects using NCv2.2 and v2009, if reasonable and appropriate.

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Hernando Miranda Owner, Soltierra LLC Apr 12 2012 Guest 13801 Thumbs Up

Yes, that interpretation is about how to earn an Innovation Credit using Mandatory Green Tenant Guidelines. It was posted in 2009 long after the project I discussed was registered. The project did not apply for an ID credit at any time.

We were told by the GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). that an ID credit can not be earned based on an interpretation from 2004. The interpretation you listed states otherwise.

Regardless of whether you pursue an ID credit, it is now mandatory, per the GBCI, to include non-mandatory Tenant Green Guidelines for any LEED NC project with any amount of Core and Shell space. Earning and ID credit is not possible according to the GBCI per a conference call I had with them on 04/11/2012.

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Samantha Harrell LEED Project Reviewer certificate holder Apr 12 2012 Guest 3161 Thumbs Up

Yes I'm aware that's its mandatory now, and I'm not sure why the LEED InterpretationLEED Interpretations are official answers to technical inquiries about implementing LEED on a project. They help people understand how their projects can meet LEED requirements and provide clarity on existing options. LEED Interpretations are to be used by any project certifying under an applicable rating system. All project teams are required to adhere to all LEED Interpretations posted before their registration date. This also applies to other addenda. Adherence to rulings posted after a project registers is optional, but strongly encouraged. LEED Interpretations are published in a searchable database at usgbc.org. 5232 was filed under the Innovation in Design section. The inquiry states "This is a general guidance Credit Interpretation Request, not specifically addressing ID credit." Anyway, this particular LEED Interpretation applies to all NC v2.2 projects registered on or after 9/2/2009 with unfinished tenant spaces, and the reviewer can choose/is supposed to apply it to all NC v2009 projects. There may be other LIs published earlier that established the same or a similar requirement. Check the Applicability tab under the LEED Interpretations the GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). has referred you to. The tab indicates which rulings were written specifically for projects using a particular rating system and therefore must be applied based on the project's registration date.

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Hernando Miranda Owner, Soltierra LLC Apr 12 2012 Guest 13801 Thumbs Up

Looks like you have a mistake that you are trying to impose without correcting the mistake.

There are no LIs with a mandatory requirement to provide non-mandatory Tenant Green Guidelines for LEED NC projects. If you can find one please post it and the applicable date.

Please make sure the LI you look for is not the infamous parking structure that was 100% core and shell and was certifying under LEED NC. In that odd case, yes Tenant Green Guidelines should have been required, should have been mandatory, and an ID credit should not have been earned. That project should have been LEED CS with an option to provide the guidelines as allowed by that system. LEED CS evidently was not available to that project when it was registered. So, the LI properly stated what that odd project needed to do for a LEED NC rating.

That project is infamous because it appears to be one of the reasons that there is a new special rule to prevent such a project for earning any LEED rating unless the amount of occupied space meets specific requirements.

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Samantha Harrell LEED Project Reviewer certificate holder Apr 12 2012 Guest 3161 Thumbs Up

As stated above, LEED InterpretationLEED Interpretations are official answers to technical inquiries about implementing LEED on a project. They help people understand how their projects can meet LEED requirements and provide clarity on existing options. LEED Interpretations are to be used by any project certifying under an applicable rating system. All project teams are required to adhere to all LEED Interpretations posted before their registration date. This also applies to other addenda. Adherence to rulings posted after a project registers is optional, but strongly encouraged. LEED Interpretations are published in a searchable database at usgbc.org. 5232 (9/2/09) requires, for LEED-NC projects, that for unfinished tenant spaces, tenant guidelines must be established ensure that future build-outs will meet the prerequisites and credits that have been pursued. The ruling was written for projects using LEED-NC v2.2 and must be applied based on the project's registration date. Project teams and reviewers may refer to the ruling for projects using LEED v2009 system, if reasonable and appropriate. This is a general guidance LEED Interpretation, not intended for Innovation in Design credit.

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Bill Swanson PE, LEED AP, Integrated Architecture Apr 12 2012 LEEDuser Expert 23513 Thumbs Up

All v2.2 CIRCredit Interpretation Ruling. Used by design team members experiencing difficulties in the application of a LEED prerequisite or credit to a project. Typically, difficulties arise when specific issues are not directly addressed by LEED information/guide were voided after being incorporated into the v2009 Reference Guide. This CIR would only be applicable to v2.2 projects registered after 9-2-09.

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Hernando Miranda Owner, Soltierra LLC Apr 12 2012 Guest 13801 Thumbs Up

The project was registered long before 2009. The LI would not apply. Yet is incorrectly being applied to this project.

The LEED NC 2009 Reference Makes no mention of tenant guidelines except for core and shell projects.

It is interesting to read the defense provided by a LEED project reviewer for a requirement that is being imposed that is not properly documented.

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Samantha Harrell LEED Project Reviewer certificate holder Apr 12 2012 Guest 3161 Thumbs Up

Hi Bill,

LEED InterpretationLEED Interpretations are official answers to technical inquiries about implementing LEED on a project. They help people understand how their projects can meet LEED requirements and provide clarity on existing options. LEED Interpretations are to be used by any project certifying under an applicable rating system. All project teams are required to adhere to all LEED Interpretations posted before their registration date. This also applies to other addenda. Adherence to rulings posted after a project registers is optional, but strongly encouraged. LEED Interpretations are published in a searchable database at usgbc.org. 5232 may also be applied to v2009 projects at the reviewer's discretion, as indicated by the single check mark under the Applicability tab. Many of the v2 CIRs were 'recycled' as LEED Interpretations that 2009 project teams and reviewers can apply to their projects. In some cases LEED Interpretations (formerly known as CIRs) may not be applicable to a project depending on the rating system used, but this will be noted in Applicability tab under each LI.

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Hernando Miranda Owner, Soltierra LLC Apr 12 2012 Guest 13801 Thumbs Up

At the reviewer's discretion? What are the rules for reviewer's discretion?

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Samantha Harrell LEED Project Reviewer certificate holder Apr 12 2012 Guest 3161 Thumbs Up

Hi Hernando,

Your first post states that GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). based the requirement for your project on LEED interpretations from 2004 and 2005 that were for Core and Shell projects using LEED NC as the rating system rather then LEED CS. My suggestion to you was to check the Applicability tab associated with the LEED Interpretations the GBCI has referred you to. The tab indicates which LI rulings were written specifically for projects using a particular rating system and therefore must be applied based on the project's registration date. I have referenced LEED Interpretation 5232 as an example in an attempt to dispel the belief that tenant design and construction guidelines are a 'phantom' requirement. :)

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Samantha Harrell LEED Project Reviewer certificate holder Apr 12 2012 Guest 3161 Thumbs Up

Hi Hernando,

A single check mark under the Applicability tab for a particular LEED InterpretationLEED Interpretations are official answers to technical inquiries about implementing LEED on a project. They help people understand how their projects can meet LEED requirements and provide clarity on existing options. LEED Interpretations are to be used by any project certifying under an applicable rating system. All project teams are required to adhere to all LEED Interpretations posted before their registration date. This also applies to other addenda. Adherence to rulings posted after a project registers is optional, but strongly encouraged. LEED Interpretations are published in a searchable database at usgbc.org. indicates that "Project teams and reviewers may refer to the ruling for projects using this rating system, if reasonable and appropriate." In the case of LEED Interpretation 5232, a reviewer will apply this ruling to NC projects registered after 9/2/09 if s/he discerns from the submittal documentation that an NC project has unfinished tenant spaceTenant space is the area within the LEED project boundary. For more information on what can and must be in the LEED project boundary see the Minimum Program Requirements (MPRs) and LEED 2009 MPR Supplemental Guidance. Note: tenant space is the same as project space..

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Hernando Miranda Owner, Soltierra LLC Apr 12 2012 Guest 13801 Thumbs Up

This is a LEED NC v2.2 project not a LEED 2009 project. There is no applicability tab for LIs.

The 5232 LI was not applied to the project. The old LEED CS as LEED NC CIRs (LIs) were applied to a project that is not LEED CS. More than 90% fully built out than has 100% of the project is included in all of credits as required: Lighting with no efficiency claim, ventilation and water use at maximum spaces type occupancy. Everything was included to certify 100% of the building.

You haven't made a good case why a project that includes everything that is required to certify 100% of a LEED NC project plus a small amount of LEED CS spaces must provide non-binding tenant guidelines. The non-binding is meaningless, and the GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). staff acknowledge that is meaningless yet it must be provided because a reviewed used their "discretion" to create a review issue.

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Hernando Miranda Owner, Soltierra LLC Apr 13 2012 Guest 13801 Thumbs Up

I received confirmation this morning from Sarah Alexander of the GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). that non-binding Green Tenant Guidelines are required for all LEED NC projects with CS areas regardless of when the project was registered. Any amount of CS space triggers the requirement.

The GBCI stated they ary considering adding this requirement as an MPR for LEED 2009. If it doesn't get added as an MPR it will still be enforced.

There you have it, straight from the GBCI management: A requirement that will likely remain an unpublished requirement.

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Hernando Miranda Owner, Soltierra LLC Apr 13 2012 Guest 13801 Thumbs Up

Green Tenant Guidelines are non-binding, but...

To earn the water efficiency credits the a mandatory requirement must be enforced on the tenants to either not install any plumbing fixtures related to the LEED water use credit, or if stub outs are included a mandatory lease requirement must be provided to install plumbing fixtures at least as efficient as what is installed in the base buildingThe base building includes elements such as the structure, envelope, and building-level mechanical systems, such as central HVAC, and materials and products installed in the project (e.g., flooring, casework, wall coverings)..

This phantom requirement continues to evolve as I write this.

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Tristan Roberts LEED AP BD+C, Executive Editor – LEEDuser, BuildingGreen, Inc. Apr 30 2012 LEEDuser Moderator

I heard from Sarah Alexander, and she was concerned about being misquoted here. She provided the following information to me.

Just to clarify, the issue of unfinished spaces within LEED 2009 projects has been addressed by LEED InterpretationLEED Interpretations are official answers to technical inquiries about implementing LEED on a project. They help people understand how their projects can meet LEED requirements and provide clarity on existing options. LEED Interpretations are to be used by any project certifying under an applicable rating system. All project teams are required to adhere to all LEED Interpretations posted before their registration date. This also applies to other addenda. Adherence to rulings posted after a project registers is optional, but strongly encouraged. LEED Interpretations are published in a searchable database at usgbc.org. #10102 that was published on 11/1/2011 for MPR#2 which incorporates guidance on how to treat unfinished spaces in LEED 2009 projects, into the Minimum Program Requirements.

For information purposes, you can see the following historic CIRs/LEED Interpretations that reference the need for non-binding tenant guidelines for NC v2.2/v2.1/v2.0  projects that include unfinished spaces (note this is not an exhaustive list of LEED Interpretations, merely illustrative examples):

LI 3900 (historic NCv2.0/NCv2.1 admin CIR of 2/22/2005)

LI #2595 (NC v2.2 7/29/2009) and LI#5216 (NC v2.2 7/29/2009)

LI #10027 (NC v2.2 5/9/2011)

LI #5255 (NC v2.2 4/20/2007)

LI #1868 (NC v2.2 8/27/2007)

LI#1968 (NCv2.2 12/19/2007)

LI#5232 (NC v2.2 9/2/2009)

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Hernando Miranda Owner, Soltierra LLC Apr 30 2012 Guest 13801 Thumbs Up

To further clarify what happened and my quoting of Sarah Alexander.

All of the LIs are dated after the registration date of the project in question. Every single one.

The GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). did provide any clearly documented reference that Tenant Guideline were required for all NC projects registered before 2/22/2005.

For the first LEED review (combined design and construction) no LIs were referenced. Only a requirement without a foundation basis. The LIs were not identified until the second review. No opportunity was provided to refute the source of the TI guideline "requirement."

The only applicable reviewer basis made was LI 30013 (2004 vintage) which is in regards to a 300k SF parking structure, with 20k of CS space, evidently 0k of NC space and was certifying under LEED-NC. A very odd LEED project. Not at all related to a project more than 90% occupied by the owner with the TI spaces fully accounted for in the submitted documentation.

The reviewer also quoted LI 3900 but not until the second review where it was impossible to claim the applicable date was after-the-fact.

The GBCI ended up with tenant guidelines that required non-efficient, code minimum plumbing fixtures. It is odd to earn LEED WEc3 points for NC-v2.2 and enforce green tenant guidelines, encouraging tenants to pursue LEED-CI, that would prevent a tenant from meeting a prerequisite under LEED-CI 2009.

This oddity has to do with the fixtures a tenant could install, kitchen sinks, and not what the base buildingThe base building includes elements such as the structure, envelope, and building-level mechanical systems, such as central HVAC, and materials and products installed in the project (e.g., flooring, casework, wall coverings). provides (full restrooms). Only the restroom fixtures were water efficient for the project, not kitchen sinks.

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Asa Posner Senior Sustainability Consultant Sustainable Investment Group (SIG)
Feb 21 2012
LEEDuser Member
1386 Thumbs Up

IEQc3.5 - EBO+M

Another issue with existing buildings is with previously existing permanently installed walk-off surfaces. This strategy (permanently installed) cannot be earned without manufacturer's documentation demonstrating that the material is designed to effectively capture fine particles. However, it is not requested anywhere on LO; you just have to know to upload it.

Be warned--even if you install this new, you must submit a cut sheet of the product. Also, this facility alteration DOES NOT meet the EBO+M definition of a 'facility alteration' (per introduction of reference guide) and you cannot claim the purchase or new material or recycle of old material in the materials credits. This is disappointing because one building recently went through the effort to install new walk-off carpet but it did not contribute to MRc3, MRc9, nor IEQc3.5 (because the reviewer asked for cut sheet in final review). Clearly a disappointment to project team.

Really there is no standard for 'carpet performance' and removable mats are never questioned. It seems that a regular cleaning schedule is more important than the type of carpet, but that information is not requested either.

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Megan Ritchie Saffitz Director of LEED Support, U.S. Green Building Council Apr 12 2012 Guest 1023 Thumbs Up

Hi Alyson -

Thanks for bringing up these several points. I've tried to address them each separately, in hopes of not missing anything...

Statement: Another issue with existing buildings is with previously existing permanently installed walk-off surfaces. This strategy (permanently installed) cannot be earned without manufacturer's documentation demonstrating that the material is designed to effectively capture fine particles. However, it is not requested anywhere on LO; you just have to know to upload it. Be warned--even if you install this new, you must submit a cut sheet of the product.

Response: This credit requires entryway systems that are capable of capturing dirt and other particulates as users enter the building. Depending on the project’s climate, some mats may not provide capture dirt and particulates year round, due to reaching a saturation point with heavy rains or snow. Page 454 of the 2009 LEED EOBOM Reference Guide provides criteria for appropriate mats in the second, third, and forth paragraph of Section 4. Implementation. While there is no prohibition on using existing systems - and manufacturer’s documentation is not a required submittal - if a project team submits documentation that appears to show a mat that does not meet these criteria (i.e. a photo that appears to show a standard carpet mat for project in a very wet climate), the Reviewer may request additional information demonstrating that the entryway systems are capable of meeting the credit requirements of capturing dirt and particulates.

Statement: Also, this facility alteration DOES NOT meet the EBO+M definition of a 'facility alteration' (per introduction of reference guide) and you cannot claim the purchase or new material or recycle of old material in the materials credits. This is disappointing because one building recently went through the effort to install new walk-off carpet but it did not contribute to MRc3, MRc9, nor IEQc3.5 (because the reviewer asked for cut sheet in final review). Clearly a disappointment to project team.

Response: A minimum quantity of facility alteration or addition is required in order to attempt MRc3 and MRc9, to ensure that achieving these credits has a meaningful environmental benefit. Once that minimum is met though, any and all materials used for facility alterations - including the installation of walk-off grates - can be included in these credits.

Statement: Really there is no standard for 'carpet performance' and removable mats are never questioned. It seems that a regular cleaning schedule is more important than the type of carpet, but that information is not requested either.

Response: Please see above and note that the Credit Submittal Form does request a narrative on the cleaning strategies used by the building.

I hope that helps -
Megan R/S

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Asa Posner Senior Sustainability Consultant Sustainable Investment Group (SIG)
Feb 21 2012
LEEDuser Member
1386 Thumbs Up

IEQp2 - EBO+M

Recently, IEQp2 for EBO+M projects are also requiring additional documentation that is not clearly requested in reference guide or on LEED Online. The issue is that most existing buildings already have 'no smoking'' signage on doors at exterior entries. This used to be acceptable to use existing signage. Now, the reviewers are requesting that we show photos of EVERY entry and that the signs MUST state 'No smoking with 25 feet of building.'

I'm glad to see that this is explicit in the draft rating system for 2012. Even going so farFloor-area ratio is the density of nonresidential land use, exclusive of parking, measured as the total nonresidential building floor area divided by the total buildable land area available for nonresidential structures. For example, on a site with 10,000 square feet (930 square meters) of buildable land area, an FAR of 1.0 would be 10,000 square feet (930 square meters) of building floor area. On the same site, an FAR of 1.5 would be 15,000 square feet (1395 square meters), an FAR of 2.0 would be 20,000 square feet (1860 square meters), and an FAR of 0.5 would be 5,000 square feet (465 square meters). as to specify the sign must be posted within 1- feet of entry.

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Megan Ritchie Saffitz Director of LEED Support, U.S. Green Building Council Apr 12 2012 Guest 1023 Thumbs Up

Hi again -

This prerequisite requires a smoking policy and a method of communicating that policy to all building occupants, both FTEs and visitors. The most comprehensive way of demonstrating prerequisite compliance would be a written policy that is provided to FTEs and signage at all entries roughly stating “No smoking within 25 feet.” However, existing signage that only says “No Smoking” - with no specification of distance – does meet current prerequisite requirements. Similarly, while signage can be at main entrances and any exits where the building management has observed violations, there is not an explicit requirement that signage be placed at every entrance. If your projects appears to have been assessed by more stringent standards, please let us know by selecting “Questions about Review Comments” on our Contact Page: http://www.gbci.org/org-nav/contact/Contact-Us/Project-Certification-Que.... In this instance though, I will contact you offline to follow up.

And thank you for noting that project teams should be aware that these requirements may become more strict in the next version of the rating system!

Megan R/S

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Bill Swanson PE, LEED AP Integrated Architecture
Feb 16 2012
LEEDuser Expert
23513 Thumbs Up

SSc8 vertical grid points

Some commentors are stating that regarding SSc8, Reviewers are asking for vertical calculation points spaced 5' apart. The Reverence Guide specifically states 10'x10' grid spacing for the site calculations. It's a bit vauge about the vertical calculations.

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Megan Ritchie Saffitz Director of LEED Support, U.S. Green Building Council Apr 13 2012 Guest 1023 Thumbs Up

Hi Bill -

Thanks for bringing this up.

Regarding grid spacing: The requirement for a 5 foot x 5 foot calculation grid is specific to a submittal requirement listed in the LEED-Schools 2007 Reference Guide which on Page 114 indicates calculations must be done at a 5 foot grid interval. GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). is aware of this discrepancy between the Submittal Requirements section (page 114) and Calculations section (page 112) of the LEED-Schools 2007 Reference Guide and we are working to resolve this discrepancy. Meanwhile, please note that according to the LEED Reference Guide for Building Design and Construction, 2009 edition, and the LEED Reference Guide for New Construction v2.2, third edition, the calculation grid spacing should be at a maximum of 10 feet x 10 feet (both for horizontal and vertical illuminance calculations).

Regarding vertical illuminance calculations: Often, the vertical illuminance calculations are not requested from project teams as the information provided in a horizontal photometric plan is sufficient to determine light trespass compliance. As a result, the LEED Online SSc8 Form for LEED 2009 only includes exterior photometric site plan(s) as a required upload to demonstrate light trespass compliance. However, the LEED reviewer may request the vertical photometric if for some reason it is not possible to determine compliance based on only the horizontal photometric plan. For example, if there are exterior light poles near the LEED project boundary and the footcandle levels are high near the boundary, the reviewer may request a vertical photometric as additional documentation to ensure compliance is achieved. Please note that the LEED Reference Guide for Building Design and Construction, 2009 edition, requires that the photometric analysis measure both the horizontal and vertical footcandle levels, and as such, the request for a vertical photometric by GBCI reviewers is appropriate. Refer to page 136 in the Reference Guide for additional information.

Hope that helps -
MRS

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Bill Swanson PE, LEED AP, Integrated Architecture Apr 13 2012 LEEDuser Expert 23513 Thumbs Up

Hi Megan,

Thanks for replying. I hope you can understand the confusion and frustration that can occur when a team works on one project and the Credit is approved and then the next project gets a request for additional documentation that is not listed nor previously required.

Vertical calc grids are not simple. Grids are planar while calculation boundaries are often irregular. Each segment of a curved boundary is a separate grid. A project may have 100 vertical grids to cover the whole boundary. And there is zero guidance on what is expected. Or how to display all of these grids so the data is legible. And the pressure to get this correct on the first try since it was requested during the final project review.

And for what benefit? The Reviewers don't seem to understand lighting. I've seen approved submittals with the fixtures oriented 180° from how they were obviously installed and because the boundary showed 0.0 fc1. A footcandle (fc) is a measure of light falling on a given surface. One footcandle is defined as the quantity of light falling on a 1-square-foot area from a 1 candela light source at a distance of 1 foot (which equals 1 lumen per square foot). Footcandles can be measured both horizontally and vertically by a footcandle meter or light meter. 2. The non-metric measurement of lumens per square foot, one footcandle is the amount of light that is received one foot from a light source called a candela, which is based on the light output of a standardized candle. A common range for interior lighting is 10 to 100 footcandles, while exterior daytime levels can range from 100 to over 10,000 footcandles. Footcandles decrease with distance from the light source. The metric equivalent of a foot candle is 10.76 lux, or lumens per square meter. no questions were asked. I can make any site show 0.0 fc on every vertical grid at the boundary. So why ask for something that the Reviewers can't interpret anyways? It's only adding paperwork for the sake of paperwork.

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David Posada Integrated Design & LEED Specialist SERA Architects
Feb 13 2012
Guest
21447 Thumbs Up

Re: Review Comments with Phantom Requirements

Michelle - see the reply to your post at EQp2:
https://www.leeduser.com/credit/NC-v2.2/EQp2#comment-22021

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Tristan Roberts LEED AP BD+C, Executive Editor – LEEDuser, BuildingGreen, Inc. Feb 15 2012 LEEDuser Moderator

Yes, Michelle's queston on IEQp2 is addressed on that forum. I am going to leave this forum open, though, and ask if anyone else out there is facing "phantom requirements"? If so it would be great to hear about them in this forum. Perhaps GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). will tune in and take some feedback on its approach.

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Neil Rosen Director of Sustainability, Northwell Health Apr 07 2012 Guest 717 Thumbs Up

I have a good one for you...I have a CI project in a Hospital that I am told by the reviewer shouldn't be considered a Hospital when submitting my LPDLighting power density (LPD) is the amount of electric lighting, usually measured in watts per square foot, being used to illuminate a given space. calculations. The review says that since there are no operating or Emergencyyy Rooms included I should consider it a Health Care Clinic...last I checked Nursing Stations and Nurseries and spaces like that are used in Hospitals as well...the big sign on the buildinng says its a Hospital...I guess the reviewers know more than the Department of Health

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Heather Alley Architect, Ralph Tyler Co Apr 12 2012 Guest 138 Thumbs Up

Although this is well known on the forum, another Phantom requirement is 8'-0" minimum for Bike paths which applies to SSc4. Why don't they just state that as a minimum?

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Hernando Miranda Owner, Soltierra LLC Apr 12 2012 Guest 13801 Thumbs Up

They do not state these type of Phantom requirements because they want you to fail in the review. The GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). claims they are standardizing the reviews but they have so farFloor-area ratio is the density of nonresidential land use, exclusive of parking, measured as the total nonresidential building floor area divided by the total buildable land area available for nonresidential structures. For example, on a site with 10,000 square feet (930 square meters) of buildable land area, an FAR of 1.0 would be 10,000 square feet (930 square meters) of building floor area. On the same site, an FAR of 1.5 would be 15,000 square feet (1395 square meters), an FAR of 2.0 would be 20,000 square feet (1860 square meters), and an FAR of 0.5 would be 5,000 square feet (465 square meters). failed to provide addenda to the Reference Guides to make any of them official.

I am one of the first five LEED APs, helped the USGBC develop LEED NC and CI, was the vice chair of the USGBCs EQ Technical Advisory Group, and have complete several LEED Platinum projects. Still, I have no access to a list of these phantom requirements.

If I was able to crowbar such a list out of the GBCI I would post it so everyone had access to it. It is incredibly unfair to have unpublished requirements that some LEED Consultants seem to have access to but vast majority do not. That provides a business advantage to a few people at the expense of everyone else.

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Megan Ritchie Saffitz Director of LEED Support, U.S. Green Building Council Apr 12 2012 Guest 1023 Thumbs Up

Hi Neil -

On the part of the USGBC staff, we appreciate you raising this issue, as it appears, based on your description of the project, that this most likely was a reviewer error. Should this happen in the future, please contact us through the LEED Certification Contact Us form, http://www.gbci.org/org-nav/contact/contact-us/project-certification-que..., with the project number and name so that we can resolve this issue for you. In this instance, I will contact you offline so that we can resolve directly.

Please note that the option to use the LEED Certification Contact Us form is always available to all project teams who have any concerns or requested clarifications regarding any LEED Certification review comments that are made. We strive to provide a fair review that is consistent with published LEED rating system requirements, the referenced standards, reference guides, and LEED Interpretations. At any time you feel the basis for a requirement has not been adequately referenced in the LEED review comments, or that the reviewer comment was in error, we welcome your feedback, and will provide clarification and correct any errors that may have been made.

Thanks,
Megan R/S

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Mara Baum Healthcare Sustainable Design Leader, LEED Fellow, HOK Apr 12 2012 LEEDuser Member 9916 Thumbs Up

Neil, that GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). comment is getting added to my LEED review wall of shame. *awesome*

I do almost exclusively healthcare work, and it's quite clear that many LEED reviewers simply don't understand what our projects are all about. They've frequently told us that strategy X is required for LEED that would be prohibited by code. Your comment, however, takes the cake. I hope you pushed back on that one! (As you probably know, office spaces inside hospitals are still office spaces, but nurse stations and nurseries are definitely hospitals!)

[Follow up note - I must have posted my comment at exactly the same time as Megan did. In response to hers, I will say that all or nearly all of GBCI's wall of shame comments were corrected through communication with GBCI. Most of them were fixed easily, but since the burden of proof is on the team, sometimes this process can be really onerous.]

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Susan Walter Specifications Director, Populous Apr 12 2012 LEEDuser Expert 22591 Thumbs Up

Mara and Neil, We are having the same problems. We do exclusively healthcare work and the USGBC/GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). does not understand Hospitals, especially ones doing renovation work of existing buildings. I'm currently trying to define a project boundary on the ground/concourse floor of a large suburban hospital. If I strictly apply the LEED definition of separation then the entire conglomeration of 15 buildings, multiple additions and renovations on that level would be in the project boundary. When I look at 2 hour walls as the separation, I can cut it down to half which is only an amount of space equal to the tower above or about 300,000 sf. The original building boundary has been obliterated due to additions and renovations which is common. I'm so frustrated right now, I'm ready to tell the owner to pay the penalty fee to the country for not doing LEED and building it green anyways.

Do not get me started on how lousy the AGMBC guide is for these large Hospital facilities.

Here's my challenge USGBC: you, my projects and myself are all located in the DC area, how about a few building tours and a good plan/code review session. Mara and Neil, you are invited.

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Mara Baum Healthcare Sustainable Design Leader, LEED Fellow, HOK Apr 12 2012 LEEDuser Member 9916 Thumbs Up

Susan, I definitely feel your pain on this one. Amorphous growth and evolution of hospital buildings/spaces are pretty unusual across most building types, and the MPRs are not currently written to clearly support that situation. Are you working on an ID+C or a BD+C project?

I have had some success in receiving at least somewhat reasonable feedback from GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). on complex campus issues via email and/or conference call.

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Susan Walter Specifications Director, Populous Apr 12 2012 LEEDuser Expert 22591 Thumbs Up

I've got a BD+C project that I may go into ID+C soon so I can separate the lowest 2 levels from the upper 11 levels. It may be the least painful way to get it through LEED but the Owner is not understanding why a completely renovated space with new mechanical, windows and roof is not BD+C. The project ticks off all the boxes for BD+C except for establishing a project boundary per LEED. I can make one based on the building and mechanical but can't support it with LEED and MPRs. I've been working through emails and am trying to get a conference call set up (with limited luck right now).

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Hernando Miranda Owner, Soltierra LLC Apr 12 2012 Guest 13801 Thumbs Up

Susan, you need to refer to the LEED Guidelines for which system to register under. The 60-40 rule.

http://www.usgbc.org/ShowFile.aspx?DocumentID=6667

If the owner owns or controls 90% of the building and is renovating more than 40% or more of the gross floor areaGross floor area (based on ASHRAE definition) is the sum of the floor areas of the spaces within the building, including basements, mezzanine and intermediate‐floored tiers, and penthouses wi th headroom height of 7.5 ft (2.2 meters) or greater. Measurements m ust be taken from the exterior 39 faces of exterior walls OR from the centerline of walls separating buildings, OR (for LEED CI certifying spaces) from the centerline of walls separating spaces. Excludes non‐en closed (or non‐enclosable) roofed‐over areas such as exterior covered walkways, porches, terraces or steps, roof overhangs, and similar features. Excludes air shafts, pipe trenches, and chimneys. Excludes floor area dedicated to the parking and circulation of motor vehicles. ( Note that while excluded features may not be part of the gross floor area, and therefore technically not a part of the LEED project building, they may still be required to be a part of the overall LEED project and subject to MPRs, prerequisites, and credits.) of the interior floor area then LEED NC must be used.

If less than 40% of the area is renovation then you must use LEED CI. Under this case some parts of the project outside the scope-of-work must be included as part of the certification. Energy use using an energy model is the one outside the scope LEED CI credit. If an HVAC system serves and entire floor but only half of a floor that is renovated the entire HVAC system must be considered in the submittal.

Good Luck.

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Susan Walter Specifications Director, Populous Apr 12 2012 LEEDuser Expert 22591 Thumbs Up

Check and check. The problem is drawing the LEED boundary on the lower two levels. LEED requires that the building 'in its entirety' be included in the project boundary for BD+C. My problem is defining the entire building and the project boundary on the very large, contiguous levels.

Imagine a college campus with all the buildings pushed together and being able to walk from one building to the next without reaching a party wall or going outside. That is a Hospital. And we aren't talking about a small amount of space either. The current facility is over 2 million contiguous SF and we're adding on a million more SF and renovating a quarter million SF.

My LEED gut and experience tells me that this is an BD+C project and to draw the project boundary as close to the original project boundary as I can using a combination of 2 hour and 1 hour walls. (Luckily, my smoke compartments are aligning with these rated walls.) I can only find LEED guidance that says no to this approach.

The other thing I would like to propose is a master planning approach to existing Hospital campuses which would allow the Owner to use a combination of BD+C, ID+C and EB+OM to bring their structures up to LEED certification over time. This would require the ability to rate buildings over different versions (ie v2.2 and v3) under a master building/block/what ever.

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Megan Ritchie Saffitz Director of LEED Support, U.S. Green Building Council Apr 12 2012 Guest 1023 Thumbs Up

Dear Hernando –

LEED Reviewers, like project teams, are end-users of LEED and access the same publically available guidance documents and databases that are published by USGBC. Their goal is to provide a fair review that is consistent with the published rating system requirements, referenced standards, reference guides, LEED Interpretations and all other USGBC LEED publications. If at any time you feel the basis for a requirement has not been adequately referenced in the LEED Review comments, or that the reviewer comment was in error, we welcome your feedback and will fully investigate the issue in order to provide further clarification or an immediate correction if a reviewer error or oversight has been made. The best way to do this is via our Contact Us page (http://www.gbci.org/org-nav/contact/Contact-Us/Project-Certification-Que...), selecting “Questions about Review Comments” from the drop down menu.

Hernando – while I know that you have already been in touch with us – for other LEEDusers out there, please note that should you also have additional questions after having already contacted us via email (i.e. the ‘Contact Us’ page), we are available for phone calls and/or conference calls. We welcome the opportunity to discuss LEED technical issues with project teams directly, and this can be arranged via our Contact Us page (http://www.gbci.org/org-nav/contact/Contact-Us/Project-Certification-Que...), selecting “Follow Up to Prior GBCI Reply” and checking the “By Phone” option.

Best,
Megan R/S

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Hernando Miranda Owner, Soltierra LLC Apr 12 2012 Guest 13801 Thumbs Up

Megan,

I know the process. I am way ahead of you on this issue. I have already discussed the issue directly with GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). upper management.

LEED Reviewers are not supposed to be end-users if you mean consultants working to certify LEED projects while also doing reviews of their competitors LEED work. GBCI executive management confirmed that consultants working on LEED projects are not LEED reviewers, at least in the last few years. I know that is not exactly true because I have evidence of a business competitor of mine who tried to get a client of mine to fire me and hire them about two years ago. the client turned them down. That same competitor reviewed a project of mine slightly more than one year ago.

I do not know what is true about reviewers and what is not true. I am told one thing when I have evidence of something else is actually going on. Maybe there were too many projects to review at one time for the non-end-user reviewers? Either way an unhappy competitor of mine reviewed my LEED project in the recent past.

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Elizabeth Powers Principal, O'Brien & Company Jun 29 2012 LEEDuser Member 542 Thumbs Up

Hi all,

I really enjoyed some of the stories in this thread. Michelle's in particular. We've had many of the same or similar challenges over the last few years. Generally we've found that if we are positive we are right, we eventually get approved. However, although not always clear at first, we've also found out they (GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). and reviewers) were right and backed off. By "right," I mean the requirement was buried somewhere we could have found, not that it was clear or obvious.

I am curious if anyone has tracked the review teams that provide the sometimes phantom requirements? I don't want to create a place to complain about reviewers in discriminently, more to share observations about where some teams might need more guidance that we can pass on to GBCI or to be best prepared for teams that are just particularly good at knowing every last detail.

I also wanted to put in a plug for Megan Ritchie. I knew her when she was at Paladino and she is great. I believe her when she says that they (she at least) welcome feedback and are trying to fix inconsistencies.

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Megan Ritchie Saffitz Director of LEED Support, U.S. Green Building Council Jul 09 2012 Guest 1023 Thumbs Up

Thanks Elizabeth! Providing consistent, high-quality reviews is of our utmost concern. To ensure that we are always maintaining or improving our quality, we track feedback at both the individual and team level, and use this data to direct targeted training and, as necessary, termination. So yes: please do continue to provide us with your feedback so that we may continue to identify our weaknesses and improve upon them. Megan R/S

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Kathryn West LEED AP BD+C, O+M, Green Globes Professional, JLL May 29 2013 LEEDuser Member 7286 Thumbs Up

I am regularly being asked in preliminary reviews to provide "optional" signatures. What is the meaning of "optional" if my credits are marked "pending" when I opt to not get the "optional" signatures?

This adds time and thus cost to my projects.

Are LEED reviewers following a check list for a previous version of the form?

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