EB Comment Period 1-Responses edits
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EB Comment Period 1-Responses edits

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Responses to Public Comments Received on First Coment Draft of LEED-EB Comment Period was Open: 03/01/04 - 03/30/04)Document Date: June10, 2004Proposed Changes to Category Comment # Issue Summaries Credit Likes and Dislikes Ways To Improve Language Changes Response LEED-EB for Second Type of ChangeComment DraftToo many "sustainability" teams do not involve the actual managers and staff who will be operating the buildings. This is more of a problem with new building construction, but The consultant facilitating the sustainability evaluation Buildings and other systems only work as well as the staff operate Credit 1.1-1.4 should also be addressed for existing building sustainability credits. Without operations will provide information to building owners, managers, Give credit for them. Having ownership by operations staff is crucial for success The LEED-EB Reference Guide will provide information the IDc1.1-1.4- (Innovation in staff involvement in the evaluation to make a building more sustainable and their and operations staff, but the decisions for the buildings ID building operations of any process, including building systems. Give credits for need for a team approach that includes active involvement of No Changes NoneCom1 Operation & "ownership" of the decisions, the sustainability achievements will not be as great as they will be made by the owner and their staff. Building staff involvement meaningful involvement of the building operations staff in the ...

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Responses to Public Comments Received on First Coment Draft of LEED-EB
Comment Period was Open: 03/01/04 - 03/30/04)
Document Date: June10, 2004
Category
Comment #
Issue Summaries
Credit
Likes and Dislikes
Ways To Improve
Language Changes
Response
Proposed Changes to
LEED-EB for Second
Comment Draft
Type of Change
ID
IDc1.1-1.4-
Com1
Give credit for
building operations
staf involvement
Credit 1.1-1.4
(Innovation in
Operation &
Upgrades)
Too many "sustainability" teams do not involve the actual managers and staf who wil be
operating the buildings. This is more of a problem with new building construction, but
should also be addressed for existing building sustainability credits. Without operations
staf involvement in the evaluation to make a building more sustainable and their
"ownership" of the decisions, the sustainability achievements wil not be as great as they
could had been. My recommendation is to include a credit for having a process to give the
actual people managing and operating the building systems significant involvement in the
sustainability evaluation.
Buildings and other systems only work as wel as the staf operate
them. Having ownership by operations staf is crucial for success
of any process, including building systems. Give credits for
meaningful involvement of the building operations staf in the
sustainability evaluation.
The consultant facilitating the sustainability evaluation
wil provide information to building owners, managers,
and operations staf , but the decisions for the buildings
wil be made by the owner and their staf . Building
operations staf wil be given a significant voice in the
sustainability evaluation.
The LEED-EB Reference Guide wil provide information the
need for a team approach that includes active involvement of
building staf .
No Changes
None
ID
IDc1.1-1.4-
Com2
Expand IOU credit
options
Credit 1.1-1.4
(Innovation in
Operation &
Upgrades)
The draft does not mention other topics like safety for the occupants or fire safety
products or systems; nor security systems; nor productivity increase due to products.
The rating systems should use and diverse group to develop/
suggest other topics that lead to "sustainability" in a more holistic
view.
See above.
Fire safety systems are not addressed because they are
covered by code.
No Changes
None
ID
IDc1.1-1.4-
Com3
Recertification
poorly scaled for
energy IOU points
Credit 1.1-1.4
(Innovation in
Operation &
Upgrades)
I was told I could not receive my energy related innovation points if I did not show I
increased my Energy Star rating by 3 points for each. My energy star rating is 96, how can
I get it to 105. When I resubmit, if I do not get these points, they were very out of the box
innovations, you can count me out of any further involvement with this process.
You can see I'm quite angry regarding this. I see so many other
properties get ing points for innovations that are not even close to
ours, but I feel we are being punished for being so green and
someone does not want us to achieve platinum.
NA
The 10 points are included for energy savings regards the
energy benefits of al actions that increase energy ef iciency.
Actions can be recognized as wel as for increased
environmental benefits.
No Changes
None
ID
IDc1.1-1.4-
Com4
Include credit for
ful -scale product
life-cycle
assessment
Credit 1.1-1.4
(Innovation in
Operation &
Upgrades)
We understand that the EB Commit ee recommended giving an innovation credit for the
use of products that had a publicly disclosed Life Cycle Assessment (LCA). More
specifical y, we understand that the commit ee proposed several additional innovation
credits for building owners who used materials with publicly disclosed LCAs for portions
of their purchases in a category and overal above some percentage threshold. This
would generate tremendous benefits driving materials producers to reduce the
environmental impacts of their products from raw materials to end-of-life. The road to
having LCA wel -integrated into LEED and the green building process is long, but this is a
necessary first step.
Please reinstate the innovation credits for LCA, which were
apparently in the earlier drafts of the EB Standard.
We have not seen the specific language for innovation
credits for using materials with publicly-disclosed LCAs
that was in previous drafts of the EB Standard, but that
is presumably available for inclusion in the final version.
We have also been told that this language has been
moved to the Reference Guide for the EB Standard, but
this document is not part of the standard itself. As such,
we have no opportunity to comment on its existence or
the actual language used.
This is being addressed by the USGBC for al LEED Products. No Changes
None
ID
IDc1.1-1.4-
Com5
Include credit for
ful -scale product
life-cycle
assessment
Credit 1.1-1.4
(Innovation in
Operation &
Upgrades)
The current credits do not encourage building professionals to look holistical y at
products and consider their environmental impacts from raw materials sourcing through
product disposal. This approach could be encouraged by adding credits for any ISO
14040 compliant ful life-cycle assessment or streamlined life cycle assessment used to
select a product.
Innovation credits for the use of a ful -scale LCA or streamlined
LCA for selection of a product are the most ef ective way of adding
to the LEED system a means of measuring the environmental
impacts of products using a widely respected scientific
methodology. Therefore, the International Design Center for the
Environment supports LEED EB. In particular, IDCE supports
LEED EB LCA Based Credit Intents for inclusion in the Reference
Guide for (1) ISO Compliant LCA for cleaning products, (2) ISO
Compliant LCA for any products, (3) MTS Consensus Sustainable
Textile or equivalent for carpet & fabric. Further, IDCE supports a
fourth credit intent for streamlined LCA, based on a
recommendation from the SETAC North American Streamlined
LCA Workgroup, that “Over time, there has been growing
recognition that “ful -scale” LCA and “streamlined” LCA are not
two separate approaches but rather are points on a continuum.”
IDCE recommends the fol owing language be included
in the LEED EB Reference Guide for Intent #4: “LEED-
EB encourages the use streamlined LCA tools which
are ISO 14,040 compliant and incorporate economic
al ocation. An Innovation credit is to be al owed for the
selection of a product using a streamlined LCA,
documenting that product’s “key at ributes” from cradle-
to-disposition. Key at ributes are defined as those life-
cycle stages that drive the majority of the environmental
impacts for a product throughout its ful life cycle.
See response to IDc1.1-1.4-Com4
See response to IDc1.1-1.4-
Com4
See response to IDc1.1-
1.4-Com4
ID
IDc1.1-1.4-
Com6
Include credit for
ful -scale product
life-cycle
assessment
Credit 1.1-1.4
(Innovation in
Operation &
Upgrades)
Wasn’t there, at one time, a credit for the use of products with ful y disclosed Life Cycle
Assessment (LCA) data? This type of credit would provide leadership in the inclusion of
LCA in the rating system. LEED addresses the life cycle of the building –addressing the
life cycle of its components should be equal y important.
Add a credit for the use of products with ful y disclosed Life Cycle
Assessment (LCA) data
None
See response to IDc1.1-1.4-Com4
See response to IDc1.1-1.4-
Com4
See response to IDc1.1-
1.4-Com4
ID
IDc1.1-1.4-
Com7
Car Sharing
Credit 1.1-1.4
(Innovation in
Operation &
Upgrades)
There needs to be an innovative credit (or additional credit under Alternative
Transportation) for car sharing. Shared cars are a means to provide transportation choice
while lessening the impacts of pol ution and land development from single occupancy
vehicles.
Car sharing companies estimate that each shared car replaces as
many as 6 automobiles. However, car sharing programs require
highly visible and easily accessible parking spots. In order to take
credit, building owners must provide the “infrastructure” for car
sharing programs to boost success, and the resulting
environmental benefits of these programs. In addition, car-poolers
could have an additional option if a shared car is available on site.
Al ow a credit for a developer who supplies a highly
visible, easily accessible parking space and/or an
incentive program.
Future revisions of LEED-EB wil consider addition of car
sharing programs for transportation impact reduction.
No Changes
None
ID
IDc2-Com1
Al ow credit for
Sustainability
continuing
education
Credit 2 (LEED-EB
Accredited
Professional)
Satisfactory
Somewhere there needs to be a means for continuing education
on the process of Sustainability like it is done for the AIA and PE
societies.
In the submit als add some wording to show the LEED
AP has a current accreditation and has maintained this
accreditation through at ending Chapter Meetings,
Short Courses, and Seminars in order to keep current
The USGBC provided education programs on LEED products
s an accreditation programs for professions. In the future the
accreditation programs for LEED professionals may include a
continuing education component for retaining accreditation.
No Changes
None
ID
ID-c2-Com3
Integrate LEED-EB
into LEED
accreditation exam
Credit 2 (LEED-EB
Accredited
Professional)
Comment: While it is completely appropriate to require the LEED accredited
professional to have LEED EB training in order for the project to be granted this credit, a
separate accreditation exam for LEED EB may not be the best path forward.
- The new version of the LEED accreditation exam could incorporate the common and
key elements of the total LEED rating system. Documentation of a ful day LEED EB
training should suf ice to show familiarity with the LEED EB program.
- Separate exams wil be both costly for the U.S. Green Building Council to
develop/administer and for professionals to take. There may be resistance to multiple
fees and exams that may drive project teams away from pursuing LEED certification.
- Integration is a major focus of sustainable building practices, and it should be the same
for LEED accreditation. Al LEED accredited professionals should have basic knowledge
of the interrelationships of the LEED products.
- A LEED NC building wil eventual y turn to LEED EB for re-certification. The initial
project team should be wel versed in both systems. Consider LEED EB training as a requ
Okay to require the LEED accredited professional to have LEED
EB training in order for the project to be granted this credit but
integrate LEED EB into a new version of the LEED accreditation
exam that incorporates the common and key elements of the total
LEED rating system.
No decision has been made yet on the issue of separate or
combined accreditation for the various LEED products. See
response to IDc1.1-1.4-Com4 on LCA.
No Changes
None