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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 LEED-Issue Date Type of Category Comment # Credit Likes and Dislikes Ways To Improve Language Changes Responses EB for Second Comment Summaries Submitted ChangeDraftLEED-EB like LEED-NC primarily addresses owner occupied or No Change NonePrereq 1.1 (Source Wastes, other than building single tenant buildings. In the future a guideline on how to apply Reduction and Waste maintenance materials, are a function LEED-EB to multi tenant/non-owner-occupied buildings will be MR MRp1.1-Com1 - - 2/12/2004Management, Waste of occupancy, not the building. Will developed. Stream Audit ) be difficult for the owner to control.All types of waste reduction including food waste are included in the No Change Nonewaste reduction prerequisite and credit. This will be described in the LEED-EB Reference GuideCould this Credit benefit from addressing Food Waste? As part of broader views of Sustainability, Community Gardening, and relationships of building waste to site plantings. Might there be guidelines for Composting facilities, to allow for compostable food wastes to be used instead of making it to the landfill or the incinerator? This could engender better food waste cycle habits, encouraging use of whole foods instead of processed foods(which are less Prereq 1.1 (Source compostable), and could result in ...
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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
Date
Submitted
Responses
Proposed Changes to LEED-
EB for Second Comment
Draft
Type of
Change
MR
MRp1.1-Com1
Prereq 1.1 (Source
Reduction and Waste
Management, Waste
Stream Audit )
Wastes, other than building
maintenance materials, are a function
of occupancy, not the building. Wil
be dif icult for the owner to control.
-
-
2/12/2004
LEED-EB like LEED-NC primarily addresses owner occupied or
single tenant buildings. In the future a guideline on how to apply
LEED-EB to multi tenant/non-owner-occupied buildings wil be
developed.
No Change
None
MR
MRp1.1-Com2 Food waste
Prereq 1.1 (Source
Reduction and Waste
Management, Waste
Stream Audit )
I like the way this Credit is worded.
Could this Credit benefit from addressing Food
Waste? As part of broader views of
Sustainability, Community Gardening, and
relationships of building waste to site plantings.
Might there be guidelines for Composting
facilities, to al ow for compostable food wastes
to be used instead of making it to the landfil or
the incinerator? This could engender bet er food
waste cycle habits, encouraging use of whole
foods instead of processed foods(which are less
compostable), and could result in the use of
foods that have less packaging, which adds to
the stream of waste. This would of course have
the greatest impact for Foodservice Facilities,
but in smal er ways could benefit any project.
The fundamental thought, is that nature is our
best exemplar of recycling, and it is especial y
clear when it comes to plant food wastes, and
how environments eventual y 'breathe' these
back into the cycle of energy. Human activities
should be symbiotic to this and not discontinue
the cycle by 'dead-ending' foods into landfil s.
This Credit might also be tied into site material
composting, (i.e. leaves, grass clippings, trimming
The suggested title for
this Credit would be:
Organic Composting
2/12/2004
Al types of waste reduction including food waste are included in the
waste reduction prerequisite and credit. This wil be described in the
LEED-EB Reference Guide
No Change
None
MR
MRp1.1-Com3 Editorial
Prereq 1.1 (Source
Reduction and Waste
Management, Waste
Stream Audit )
Satisfactory
No comments
Change the orientation of
the sentences in the
Submit als LEED EB Re-
Certification and place
the fol owing first:
Provide. . .then add the
"if statement. . ) To
bet er show the
requirement and
encourage a positive
response.
2/12/2004
Make the suggested editorial changes
Make proposed editorial
change
Editorial
MR
MRp1.1-Com4 Documentation
Prereq 1.1 (Source
Reduction and Waste
Management, Waste
Stream Audit )
Easy points! Occupant recycling
programs are typical y incorporated
as part of the facilities environmental
measurement systems programs
such as ISO 14001. This type of MR
credit is a standard practice for
companies that have implement ISO
14001 programs. ISO14001 requires
independent 3rd party certification
and verification on a periodic basis to
be re-certified for ISO14001.
Occupant recycling should be incorporated into
the Owner’s Program under the Materials &
Resources section. Provide credit for facilities
which have occupant recycling as part of their
ISO14001 certification. (1 point). Benchmark
recycling improvements against pass
performance (annual). Plan should provide
means of making building occupants aware of
environmental benefits of recycling (i.e., energy
savings, reduced emissions, etc. )
2/12/2004
Waste reduction and recycling are important parts of sustainability
so these are included in LEED-NC and LEED-EB. Documentation
of waste reduction is required for the waste reduction prerequisite
and credits.
No Change
None
MR
MRp1.1-Com5
What should
audit cover.
Prereq 1.1 (Source
Reduction and Waste
Management, Waste
Stream Audit )
Ø In “Requirements”, “upgrade
CONSTRUCTION waste” instead of
“upgrade project waste”.
Ø Should waste stream audit of
hazardous waste and household
chemicals be included?
For waste disposal as with al other activities, building owners and
operators must comply with applicable codes, regulations and laws.
The waste stream audit should address how these are being dealt
with. This issue wil be clarified in the LEED-EB Reference Guide
No Change
None
MR
MRp1.2-Com1
Prereq 1.2 (Source
Reduction and Waste
Management,
Storage & Col ection
of Recyclables)
Should be a point not a prerequisite.
-
-
2/12/2004
This credit requires the development and implementation of a plan
to maintain a weighted average mercury content of the mercury
containing lamps purchased over time below the specified mercury
content per lumen hour. This wil be clarified in the LEED-EB
Reference Guide. MRp1.3 wil be renumbered MR Prerequisite 2
No Change
None
MR
MRp1.2-Com2 Editorial
Prereq 1.2 (Source
Reduction and Waste
Management,
Storage & Col ection
of Recyclables)
Satisfactory
No comments
In the Submit als--LEED
EB re-Certification
section move the
"Provide. . portion of the
sentences to the
beginning and then add
the "If. . portion to bet er
show the response
required.
2/12/2004
Make the suggested editorial changes
Make proposed editorial
change
Editorial
MR
MRp1.2-Com3
Prereq 1.2 (Source
Reduction and Waste
Management,
Storage & Col ection
of Recyclables)
--
Since not al items listed can be recycled in al
parts, consider limiting to products that are
col ected by a processing facility within 20 miles
of the building.
--
2/12/2004
An exception wil be granted for recycling requirement for individual
materials for which there is no recycling pick up available within 50
miles.
Make changes included in
Responses Column.
Clarificatio
n
MR
MRp1.3-Com1
Prereq 1.3 (Source
Reduction and Waste
Management,
Reduced Mercury in
Light Bulbs)
1.) The formula established
should be based on lamps/bulbs in
use and not purchased in a given
year. Due to the longer life of lamps
in use today, the formula could
produce deceptive results when an
organization purchases more
compact fluorescent rather than
tubes in a particular time period. This
would definitely impact those
organizations desiring to recertify
every year.
The requirement is to have a plan to maintain an weighted average
mercury content of the mercury containing lamps purchased over
time below the specified mercury content per lumen hour. This wil
be clarified in the LEED-EB Reference Guide. MRp1.3 wil be
renumbered MR Prerequisite 2
Make changes included in
Responses Column.
Editorial
MR
MRp1.3-Com2 Approach
Prereq 1.3 (Source
Reduction and Waste
Management,
Reduced Mercury in
Light Bulbs)
Please remove the problematic
picogram-per-lumen-hour proposal.
There are many unintended
consequences to the picogram
approach: 1. Despite achieving al
other environmental qualifications,
many existing buildings wil not
qualify for LEED solely on the
picogram-per-lumen-hour
requirement. 2. Existing buildings
cannot easily modify their existing
lighting systems as lighting systems
are driven by application needs. For
example, buildings requiring a high
wat age metal halide system could
never qualify for LEED solely
because of the picogram
requirement. 3. The picogram
proposal heavily penalizes smal ,
highly ef icient, low-mercury, low-
wat age, low-lumen sources. Even if
the lighting design uses state-of-the-
art, highly ef icient, low-mercury, low-
wat age sources, and is far below
ASHRAE/IESNA 90.1 wat s-per-
square-foot limits, it wil fail to achieve
LEED solely on the picogram-per-
lumen-hour issue. 4. Ironical y,
reducing lumen-per-wat levels to
achieve very low ambient light levels
in super ef icient buildings requires
an increasing use of low-wat age, low-
The objective of source prevention can be
ef ectively achieved by providing points for
maximizing the use of low-mercury lamps and
simply defining low mercury lamps. As there is
an interest in the International promotion of
LEED, this approach would match wel with the
current European RoHS (Restriction on
Hazardous Substances) directive. The RoHS
directive essential y defines low mercury lamp
categories. Al of the RoHS defined low-mercury
lamp categories would fal within a range of
lamps not exceeding 10 mg of mercury content.
There are additional lamp categories defined in
RoHS that would include lamps containing
considerably more than 10 mg, but these are
not general y thought of as low mercury lamps.
Defining low mercury lamps as lamps not
exceeding 10 mg, and then providing points for
maximum use of these lamps, would achieve
LEED’s stated goal of source prevention, while
avoiding al of the issues associated with the
picogram proposal. For example, the LEED
standard can provide 1 point if 80 percent of the
lamps used in the existing building did not exceed
Remove al references to
PPM or Picograms-per-
Lumen-Hour. Change
Prerequisite to a “Lamp
Recycling” prerequisite
for al mercury-containing
lamps. Develop Point
System to encourage
use of Low-Mercury
Lamps, defined as lamps
not exceeding 10 mg.
Provide 1 Point if 80
percent of the lamps
used in the existing
building are low mercury.
Provide 2 Points if 90
percent of the lamps
used in the existing
building are low mercury.
Rationale The current
picogram-per-lumen-hour
proposal is flawed and
has many unintended
consequences. The
proposed alternative is
easy for commit ee
members, building
owners, and designers to
understand and calculate
and can easily achieve
stakeholder consensus.
It would also work within
international concepts of
2/12/2004
Response to MRp1.3: Comment 2
Sub Comment: Please remove the problematic picogram-per-lumen-
hour proposal. There are many unintended consequences to the
picogram approach:
Response: The picogram per lumen hour requirement appears to
be an ef ective means to drive source reduction for mercury brought
into buildings in light bulbs. The requirement wil be retained as it
addresses the three factors that af ect how much mercury is
brought into buildings in light bulbs: lamp life, light output and
mercury content. Source reduction is the top tier of the US EPA’s
hierarchy approach to waste reduction.
Sub Comment: 1. Despite achieving al other environmental
qualifications, many existing buildings wil not qualify for LEED
solely on the picogram-per-lumen-hour requirement.
Response: Al prerequisites must be met to earn LEED
Certification. Meeting the 90 picogram prerequisite requirement in
LEED-EB has not been technical y dif icult for building owners
participating in the LEED-EB Pilot. A recent LEED-EB Certified
Pilot achieved a level of 76 picograms using light bulbs from GE, Sylv
Mercury is a bio-accumulating toxic material. Building owners have a
The 90 picogram per lumen hour requirement gives building owners a
Sub Comment: 2. Existing buildings cannot easily modify their existin
Response: In the commercial building market of lighting: tubular fluor
In the industrial building market, tubular fluorescent lamps are 81% of
In the majority of commercial buildings the tubular fluorescent lamp n
For buildings where HID lamps do dominate the mix of lamps used, th
Make Changes included in
Responses Column.
Clarificatio
n
MR
MRp1.3-Com3 Level
Prereq 1.3 (Source
Reduction and Waste
Management,
Reduced Mercury in
Light Bulbs)
I like the addition of mercury
reduction to consideration in the
rating system. I wonder however if it
is appropriate as a prerequisite. The
documentation process for this
prereq is extremely onerous,
particularly for large, multi-building
projects which use a lot of lamps.
The lamp manufacturers do not
consistently have al the data readily
available and do not seem able to
respond very quickly to requests.
The USGBC should work with the lamp
manufacturers to make the required lamp data
readily accessible. Until such time, consider
making this a credit rather than a prerequisite. It
took more time to document this one prereq
than any other prereq or credit.
Make it a credit.
2/12/2004
See response to MRp1.3-Com11 on mercury content.
See responses to MRp1.3-
Com 2, 6, 9 & 11
See
responses
to MRp1.3-
Com 2, 6,
9 & 11
MR
MRp1.3-Com4 Complexity
Prereq 1.3 (Source
Reduction and Waste
Management,
Reduced Mercury in
Light Bulbs)
WAY too complicated.
Just require preferred purchasing and recycling
of spent bulbs.
-
2/12/2004
See response to MRp1.3-Com11 on mercury content.
See responses to MRp1.3-
Com 2, 6, 9 & 11
See
responses
to MRp1.3-
Com 2, 6,
9 & 11
MR
MRp1.3-Com5 Approach
Prereq 1.3 (Source
Reduction and Waste
Management,
Reduced Mercury in
Light Bulbs)
We are in strong support of this
prerequisite for LEED-EB. We
believe in a balanced approach of
source reduction, energy ef iciency,
long life, light output and recycling
which are al components of
sustainable lighting. We feel this
prerequisite should be part of al
LEED products moving forward.
Improvements that would al ow for more
specificity and clarification are provided below
#3:
MR Prerequisite 1.3
Source Reduction and
Waste Management-
Reduced Mercury in
Light Bulbs Intent:
Establish a source
reduction program to
reduce creation of waste
and a recycling program
to reduce waste stream.
Requirements Maintain
mercury content of al
mercury containing light
bulbs below 90
picograms per lumen
hour of light output
(pictogram/lumen hour),
on weighted score, for al
mercury containing light
bulbs instal ed for the
existing building and
associated grounds.
Potential Technologies
and Strategies Engage in
a waste stream audit that
studies and documents
the material that enters
the building that result in
the generation of waste.
Establish materials and
supplies purchasing
policies that include
source reduction which
2/12/2004
See response to MRp1.3-Com11 on mercury content.
See responses to MRp1.3-
Com 2, 6, 9 & 11
See
responses
to MRp1.3-
Com 2, 6,
9 & 11
MR
MRp1.3-Com6
Prereq 1.3 (Source
Reduction and Waste
Management,
Reduced Mercury in
Light Bulbs)
Technical and Calculation Issues 1.
Instant start bal asts: The instant
start fluorescent bal ast language
appears to be a T8 lamp specification
only. The newest generation of high-
lumen, high ef icacy fluorescent
lamps are the T5 types. It is wel
known that these lamps do not
operate on instant start bal asts;
rather, they are global y designed
lamps designed to operate on
programmed rapid start bal asts that
extend lamp life. As proposed, this
prerequisite excludes T5 fluorescent
systems. It also excludes many
compact fluorescent systems, since
there are a variety of these lamp
types that are designed either for
rapid start or electronic pre-heat
operation. 2. Power factor vs. bal ast
factor: The requirement for
fluorescent lamps cal s for instant
start bal asts with a power factor of
1.0. Since that is virtual y impossible,
the commit ee likely intended to
require a bal ast factor of 1.0, which
would translate to “100% of rated
lumen output.” Assuming this is the
case, bal ast factor (BF) would be
complex to incorporate, because in
the real world, BFs range from approxi
Suggestions 1. Prerequisite status: Unlike other
LEED products, LEED-EB incorporates a
replaceable commodity into the prerequisites. If
the USGBC truly wishes to eliminate mercury as
an environmental hazard, then it needs to be
addressed on the emissions side, not on the
product content side, measured in tril ionths of a
gram. And ironical y, one key to reducing
emissions is the widespread intel igent use of
mercury-containing, energy ef icient lighting. Per
the EPA, five times more mercury is released
annual y into the atmosphere by coal-burning
utilities than is used by the entire U.S. lamp
manufacturing industry per year. Since releases
into the atmosphere are an important mercury-
related environmental issue, the environment
would benefit by holding lamp/bal ast systems to
strict energy performance levels.
ASHRAE/IESNA Standard 90.1-2001 is an ANSI
approved document that is already in place,
chal enging building designers to use advanced
lighting systems that severely reduce energy
use. We suggest removing the current MR
mercury content prerequisite for lamps and addin
Remove this prerequisite
altogether, for reasons
stated above.
2/12/2004
Response to MRp1.3, Comment 6
Sub Comment: Technical and Calculation Issues 1. Instant start
bal asts: The instant start fluorescent bal ast language appears to
be T8 lamp specification only. The newest generation of high-
lumen, high ef icacy fluorescent lamps are the T5 types. It is wel
known that these lamps do not operate on instant start bal asts;
rather, they are global y designed lamps designed to operate on
programmed rapid start bal asts that extend lamp life. As proposed,
this prerequisite excludes T5 fluorescent systems. It also excludes
many compact fluorescent systems, since there are a variety of
these lamp types that are designed either for rapid start or
electronic pre-heat operation.
Response: Language wil be added to the requirements section
stating that the life of T-5 lamps should be rated using the
programmed start bal asts.
Language wil be added to the requirements section stating that for
compact fluorescents the rated life and lumens reported in the lamp
catalogs of al the manufacturers should be used.
Sub Comment: Technical and Calculation Issues 2. Power factor vs
Response: The requirements section wil be changed to specify a ref
Sub Comment: Technical and Calculation Issues 3. Longest life lam
Response: The requirements section wil be changed to remove this
Sub Comment: Technical and Calculation Issues 4. Lamp life: It is w
Make changes included in
Responses Column.
Clarificatio
n
MR
MRp1.3-Com7 Editorial
Prereq 1.3 (Source
Reduction and Waste
Management,
Reduced Mercury in
Light Bulbs)
Satisfactory
No comments
In the section Submit als--
LEED EB Re-
Certification move the
"Provide. . portion to the
front and the "If. .portion
to the end To bet er
show what is required
2/12/2004
Make the suggested editorial changes
Make changes included in
Responses Column.
Editorial
MR
MRp1.3-Com8
Data
availability
Prereq 1.3 (Source
Reduction and Waste
Management,
Reduced Mercury in
Light Bulbs)
I was unable to find picogram data in
the current catalogs of any of the
major lamp manufacturers. It seems
inappropriate to have a prerequisite
include data that is not readily
available.
There needs to be a reference to where to get
the data.
See #2 above.
2/12/2004
It is appropriate from a risk reduction as wel as a waste source
reduction perspective for building owners to know how much toxic
materials like mercury they are bringing into their buildings. See
response to MRp1.3-Com11 on mercury content.
None
MR
MRp1.3-Com9
Prereq 1.3 (Source
Reduction and Waste
Management,
Reduced Mercury in
Light Bulbs)
This let er is presented as a Public
Comment on the proposed LEED –
EB rating system. I am a lighting
designer in Troy NY, with experience
with designing one LEED rated
building in Vermont, and hope to work
on many more. I support the goals of
the USGBC, and have concentrated
in energy-ef icient design for 25
years. My specific comments are
regarding the weighted average
mercury limits in picograms per
lumen-hour as a prerequisite for
LEED-EB ratings. Onerous metric to
calculate I have gone through a
sample calculation for compliance on
this issue, and am concerned that
this calculation is onerous for both
designers to calculate as an initial
value, and even more dif icult for
owners to calculate in future years. If
a building has only one or two lamp
types, it is not an issue, but many of
my projects have 30 lamp types in an
ef ort to get the absolute best energy-
ef icient lamp for the space or
application. I would have to know
exactly which manufacturer provided
each lamp type on the job (this is
dif icult for a multiple bidder project),
look up the picograms of mercury per l
***
See Section 2
2/12/2004
MRp1.3, Comment 9, Response
See responses to MRp1.3, Comment 2 & Comment 6
Sub Comment: (1) This let er is presented as a Public Comment
on the proposed LEED – EB rating system. I am a lighting designer
in Troy NY, with experience with designing one LEED rated building
in Vermont, and hope to work on many more. I support the goals of
the USGBC, and have concentrated in energy-ef icient design for
25 years. My specific comments are regarding the weighted
average mercury limits in picograms per lumen-hour as a
prerequisite for LEED-EB ratings. Onerous metric to calculate I
have gone through a sample calculation for compliance on this
issue, and am concerned that this calculation is onerous for both
designers to calculate as an initial value, and even more dif icult for
owners to calculate in future years. If a building has only one or two
lamp types, it is not an issue, but many of my projects have 30
lamp types in an ef ort to get the absolute best energy-ef icient
lamp for the space or application. I would have to know exactly
which manufacturer provided each lamp type on the job (this is dif icu
Response: Achieving sustainable building performance is al about in
Sub Comment: (2) One of the techniques I commonly use to trim ligh
Response: The LEED-EB picogram calculations use the lamp perform
Sub Comment: (3) Lighting design issues I’m concerned that this pre
See responses to MRp1.3-
Com 2, 6 & 11
See
responses
to MRp1.3-
Com 2, 6
& 11
MR
MRp1.3-
Com10
Prereq 1.3 (Source
Reduction and Waste
Management,
Reduced Mercury in
Light Bulbs)
--
Requirements need a lit le clarification; most of
the explanation is provided under the Submit al
requirements.
--
2/12/2004
The requirements wil be clarified
Make changes included in
Responses Column.
Editorial
MR
MRp1.3-
Com11
Prereq 1.3 (Source
Reduction and Waste
Management,
Reduced Mercury in
Light Bulbs)
MRPR1.3: I am VERY nervous that
the PR may have the undesired ef ect
of driving projects to use more
incandescents instead of CFLs.
Even the very best CFLs have a
picogram per lumen-hour mercury
content of nearly 140. Granted, there
is some countervailing pressure from
the energy ef iciency credits, and
people can use more linears. BUT,
most existing fixtures, bal asts
designs, etc. are not set up for the T-
5s and other thin-profile, lower
mercury lamps, so for the mid-term
that addition to the market mix is
unlikely to make much of a
dif erence. There are also stil a ton
of T-12 fluorescents out there going
into retrofits of existing buildings and
they have a pret y high content,
certainly at or over 120
picograms/lumen-hour.
We're talking a PREREQUISITE
here. So, for projects wanting to
play, the decision would be a no-
brainer: sacrifice some energy
ef iciency to get into the LEED
program. The resulting mercury
emissions from incandescent energy
use would be far greater and
distributed in a much more harmful
way (smokestack aerosols) than from
MRp1.3-Com11, Response
Mercury is a bio-accumulating toxic material. Building owners have
the right and responsibility to know how much toxic material they
are bringing into their buildings in products they purchase. The
picogram per lumen hour requirement in prerequisite MRp1.3 gives
building owners a framework for fulfil ing this responsibility.
Meeting the 90 picogram prerequisite requirement in the pilot
version of LEED-EB has not been technical y dif icult for building
owners.
A requirement that al mercury containing lamps be recycled was
included in the Comment Draft of LEED-EB and this wil be
retained. Recycling of mercury containing lamps is required in
points MR Credit 5.1, 5.2, 5.3of the comment draft of LEED-EB and
this requirement wil be retained.
There are strong incentives for building owners to select lamps that
provide energy savings: the first is the cost of electricity and the
second is the LEED-EB minimum energy ef iciency prerequisite and
the 10 points available for improved energy ef iciency.
See also responses to MRp1.3, Comment 2, Comment 6, & Commen
Make changes included in
Responses Column.
Clarificatio
n
MR
MRc1-Com1
Credit 1 (Construction
Waste Management)
Al ows for point(s) if no renovation
work is done and therefore no waste
generated.
Clarify that if this is the basis for the credit that
the applicant only receives 1 point not the 2 that
are possible under this credit.
None
2/12/2004
This clarification wil be made. LEED-EB keeps the same
thresholds for this credit (50% & 75%) as LEED-NC.
No Change
None
MR
MRc1-Com2
Credit 1 (Construction
Waste Management)
The credit is a good objective.
We need more of an incremental approach to
succeed in an evolving process.
Change Construction
Waste Management
scoring from an al or
nothing single point for
75% to a graduated
scoring such as 1 point
for 60%, 2 points for 70%
and 3 points for 80%.
This would be similar to
Occupant Recycling
scoring and provide more
opportunities for
achieving improvements.
The al or nothing
approach is not as strong
an incentive to try.
2/12/2004
There are two level of achievement in LEED-EB now. In the future,
an integrated approach for al waste reduction and recycling
activities wil be considered to provide a more graduated approach
to earning waste reduction points.
No Change
None
MR
MRc1-Com3
Reuse
Credit 1 (Construction
Waste Management)
The value of reducing the amount of
construction waste generated by
building demolition and selective
demolition during the rehabilitation
process cannot be emphasized
enough.
The rating system should acknowledge the
value rehabilitation of an existing or historic
building actual y represents. Not only does
conservation of existing buildings eliminate
construction waste, it reduces the loss of
natural resources used to produce more
construction materials. Projects should be rated
highly for their ability to meet the chal enge of
providing sustainable buildings without
demolishing existing building fabric.
A significant number of
additional points should
be awarded for the
conservation of existing
building fabric.
2/12/2004
Staying is existing buildings does preserve most or al of the
building and this clearly reduces construction waste. This credit
was removed from LEED-EB because retaining the building shel is
a given for continued occupation of existing buildings. In the future
when the relative environmental benefits of LEED-NC and LEED-EB
are evaluated, recognizing this benefit of existing buildings may be
reconsidered.
No Change
None
MR
MRc1-Com4
Reuse
Credit 1 (Construction
Waste Management)
The section on Continued Existing
Building use is missing: The
reference to 100% of shel is
confusing. They are dif icult to assess
as to the components of the shel are
being addressed. In the event the
existing building shel is al glass or a
windowless building the criteria
should reflect advantages of the
change if desired.
The shel may be structural or skin and separate
criteria may be utilized in the application of
improved sustainability of the EB.
. . reusing on an ongoing
basis 100% of shel and
more than that 50% of
non-shel or altered/
replaced towards
comparative
improvement of
sustainability. .
2/12/2004
See response to comment MRc1-Com3 on continued use of most
or al of building shel .
No Change
None
MR
MRc1-Com5
Editorial
Credit 1 (Construction
Waste Management)
Satisfactory
No comments
In the Submit als LEED
EB section move the
"provide. . section to the
front and the "If section
to the end to bet er show
what is required
2/12/2004
Make the suggested editorial changes
Make proposed editorial
change
Editorial
MR
MRc1-Com6
Credit 1 (Construction
Waste Management)
--
Clarify that CWM Plan need only be submit ed if
a renovation was undertaken over the last year.
--
2/12/2004
The construction waste management plan needs to be in place to
address al future construction project in buildings
No Change
None
MR
MRc1-Com7
Credit 1 (Construction
Waste Management)
Ø In this credit, it may help users if
you keep language consistent to
either “waste management policy” or
“waste management plan”. It is
somewhat confusing when you switch
between the two.
Ø In determining recycling/salvage
rates by weight or volume, how do
users determine when to use each
unit? Is there an occasion when
weight is preferable to volume, or vice
versa? Should users be consistent
or can they switch when convenient?
Language wil be made consistent using "waste management
policy". The LEED-EB Reference Guide wil explain how to get al
waste numbers into either weight or volume.
Make proposed editorial
change
Editorial
MR
MRc2.1-2.5-
Com1
Credit 2.1-2.5
(Optimize Use of
Alternative Materials)
FSC Certified wood requirement is
very limiting. It is not available
throughout the US. This should be a
more general requirement for
sustainable harvested wood
products. In Colorado, for example,
we would have to purchase a ful
truck load of FSC certified wood from
Oregon when we might only need a
lit le bit of the wood. Is that
sustainable? We could just go to
Home Depot and obtain Sustainable
Forestry Initiative certified wood in
the amount that we need.
Encourage the purchase of sustainable
harvested wood by al owing more types of
sustainable harvested wood suppliers.
"Is wood from a
sustainable harvested
forest"
2/12/2004
This credit is consistent with similar credits in other bal oted LEED
rating systems.
No Change
None
MR
MRc2.1-2.5-
Com2
Credit 2.1-2.5
(Optimize Use of
Alternative Materials)
A note under the requirements says
items satisfying more than one
criteria can only receive one credit.
?? Why? Meeting more than one
criteria is a valid environmental
impact reduction.
Al ow credits for al criteria satisfied.
-
2/12/2004
If at least one criterion is met, the dol ars go in the column of having
been spent in an environmental y positive way. Once experience is
gained with the current approach, consideration wil be given to
al owing more credit for dol ars spent in ways that provide multiple
environmental benefits.
No Change
None
MR
MRc2.1-2.5-
Com3
Credit 2.1-2.5
(Optimize Use of
Alternative Materials)
The calculation is problematic and
potential y counter-productive. And
easy to misunderstand. As an
example of counterproductivity,
suppose that 50% of the purchases
happen to be wood, of which 1/5 is
FSC certified wood. That 1/5 is 10%
of the total, so the site gets the point,
even though only 20% of the wood is
FSC certified.
It is more logical that the percentages apply to
al products in that category, and that overlaps
are acceptable.
Drop the note and the
10% wording. Replace
by: Up to 5 points can be
awarded if the fol owing
criteria are met by
purchases that are
applicable to those
criteria. . Section d and e
need to be reworded
along the lines of LEED-
NC,
2/12/2004
Yes if 10% of the total dol ar purchases of materials in a given year
are materials that meet one of the criteria would earn 1 point. A
clarifying explanation wil be added in Reference Guide.
No Change
None
MR
MRc2.1-2.5-
Com4
Historic
Buildings
Credit 2.1-2.5
(Optimize Use of
Alternative Materials)
Particular danger to historic sites and
properties.
Refer to and require consultation with The
Secretary of the Interior's Standards for
Rehabilitation and Treatment of Historic
Properties.
2/12/2004
Please see response to General Comment 5.
No Change
None
MRc2.1-2.5-
Com5
Credit 2.1-2.5
(Optimize Use of
Alternative Materials)
This credit, while more compatible
with the operations of an existing
building, wil require a finer
coordination between an
organization's Purchasing, Finance
and Facilities departments. Wil their
software support the desired
verification requirements?
A template wil be provided for gathering this information.
No Change
None
MR
MRc2.1-2.5-
Com6
Credit 2.1-2.5
(Optimize Use of
Alternative Materials)
There are several issues with this
credit. The comments for the credit is
broken down by sub-let er. C: This
requirement wil push a lot of
products that have worked hard to
get recycle content into their
products out of the buying process
therefore reducing the volume of
recycled materials being used. It is
extreme dif icult for a lot of materials
to accept recycle material loading in
the 20% or higher levels with some
being control ed presently by
standard that limit the amount of
recycle content for "first class"
material. With this being the case, a
lot of manufactures wil stop pursuing
recycle content for the targets are
unrealistic at this time. The recycled
content credit should be more aligned
with the present LEED-NC. f: The
objective of the credit category f is to
minimize the energy required to
deliver a product to the job site. The
original standard focused on the
manufacturing process giving credit
when the last manufacturing step for
the product was within 500 miles of
the site. This standard seem to focus
on the heavy components such as bric
C:contains 5% minimum recycle content (post-
consumer + .5 post-industrial) f:One example,
the base standard in roofing is Built Up Roofing
which weights 400 pounds a square. This is a
good candidate for regional materials credit
when one looks at just the weight factor (it is not
"harvested" local y). In comparison since we are
looking at weight, a single ply system wil weight
about 70 pounds a square. This means that the
mode of transportation can carry 4-times the
square footage of single ply material on the
same truck or ship the same square footage
from farther away at the same energy use. Also,
this standard does not look at smal local
operations for overhead, ef iciency and pol ution
that cost both energy and the environment. The
harvest term is not relevant to most man made
materials. There are many materials that have
specific ingredients added in very smal
amounts that are extracted in far away location
yet they cost (including energy) is very smal .
With out them, the material wil not function as
intended.
c: See Point 2. f:
Remove the "harvested"
term. If one credit is to
be used for this item, the
basic distance should be
1000 miles radius with
2000 miles when rail or
water transportation is
included in the
transportation mode.
Another recommendation
would be to have several
credits. One credit would
target the heavy
traditional materials with
the distance of 300 and
1000 miles being stated.
The credit would spel
out these materials. A
second credit would be
developed for synthetic
materials stating travel
distances of 1000 and
2000 miles respectful y
when the specific gravity
is less than 1.5 or the
instal ed weight is equal
to or less than 1 psf.
2/12/2004
No Change
No Change
None
MR
MRc2.1-2.5-
Com7
Credit 2.1-2.5
(Optimize Use of
Alternative Materials)
With regards to the requirement for
50% of the purchases to be from
"rapidly renewable materials, the term
"rapidly" is relative and undefined. In
wood products, it is unclear which
"short rotation" products would be
eligible. "Short rotation" relative to
what? This makes no sense from an
environmental perspective since
there are dif erent age classes and
rotations in managed forests. Long
rotations are desirable for some
benefits while shorter rotations are for
others. This credit could have a
negative impact by encouraging the
use of short-rotation plants without a
requirement for sustainable yield.
Specifying only FSC certified wood is
inappropriate and discriminates
unfairly against other certification
systems. FSC requirements are not
designed to accommodate private
landowners and the political system
in the US. Private landowners own
60% of the productive forest land in
the US and specifying only FSC
discriminates against them. The
requirement to purchase materials
harvested/processed/extracted/proce
ssed within 500 miles of the project
ignores basic economics. Purchasing
50% from rapidly renewable resources: The
critical issue should be yields and not rotation
length, as improved yields translate into more
stored carbon and less overal land disturbance.
FSC Certified Wood: A credit should be given
for the use of materials derived from other
credible certified sources, including the SFI
program and the American Tree Farm System.
Independent comparisons have shown both
serve to expand the practice of sustainable
forest management. Question: Why is it not
"green" to use wood from land conversions,
etc.? Is it bet er that the wood go to land fil s or
be buried? It is always bet er to use the
resource than to waste it! 50% of the materials
from within 500 miles: This credit has lit le to do
with environmental impacts and more to do with
moving mass over distance.
50% rapidly renewable
resources: credit should
be given for using
renewable resources
from intensively managed
resources such as
planted forest stands.
"Rapidly" should be
defined as within 100
years. FSC certified
wood: In addition to FSC,
add the Sustainable
Forestry Initiative, the
Canadian Standards
Association, and the
American Tree Farm
System as recognized
certification programs.
50% materials from with
500 miles: DELETE
2/12/2004
This credit is consistent with credits in other bal oted LEED
products. Appropriate changes wil be considered in the future.
No Change
None
MR
MRc2.1-2.5-
Com8
Credit 2.1-2.5
(Optimize Use of
Alternative Materials)
It is myopic to reserve credits for use
of only FSC certified wood. FSC
certification in US comprises a tiny %
of timberland and discriminates
against the 10 mil ion smal non-
industrial forest landowners that own
60% of the productive forest land in
the U.S. Furthermore, other
certification programs such as SFI
and American Tree Farm provide
equal y as wel as, if not bet er than,
FSC for forest sustainability.
Give credits for use of wood from these other
qualified certification programs, mentioned
above, such as American Tree Farm and SFI
Private forest plantations
provide rapidly renewable
resources. therefore an
added credit should be
given for using these
renewable resources
from planted forest
stands.
2/12/2004
This credit is consistent with credits in other bal oted LEED
products. Appropriate changes wil be considered in the future.
No Change
None
MR
MRc2.1-2.5-
Com9
Credit 2.1-2.5
(Optimize Use of
Alternative Materials)
Criteria 2d: Using the word "rapidly"
to modify renewable is inappropriate
when considering wood or fiber
products. The key issue is
sustainability. Whether the wood or
fiber comes from a short rotation
plantations or from wel managed,
ecological y sustainable forests is not
important. What is important is that
the land, water and air resources
support sustained yields of the
products. Many public and private
forests are being managed for longer
rotation and selective harvest in
sensitive areas. These management
regimes produce economic yields for
the owner while maintaining broad
ecological value for the pubic and
future generations. LEEDS should
not discriminate against these
producers and the products that are
made from harvesting these trees.
Criteria 2d: Base the standard on sustainable
yields not on length of growing cycle.
Criteria 2d: Contains at
least 50% renewable
material produced from
certified sustainable
sources.
2/12/2004
This credit is consistent with credits in other bal oted LEED
products. Appropriate changes wil be considered in the future.
No Change
None
MR
MRc2.1-2.5-
Com10
Editorial
Credit 2.1-2.5
(Optimize Use of
Alternative Materials)
Satisfactory
No comments
In the Submit als LEED
EB Re-Certification
section the first
paragraph move the
"Provide. . to the front
the "If statement to the
end To bet er show what
is required
2/12/2004
Make the suggested editorial changes
Make proposed editorial
change
Editorial
MR
MRc2.1-2.5-
Com11
Credit 2.1-2.5
(Optimize Use of
Alternative Materials)
a.Recycled content presumes that
recycled materials wil automatical y
result in reduced environmental
burdens. Recycling saves landfil
space but as demonstrated by life
cycle assessment the process of
recycling is energy intensive. The
ef ects on the environment of
recycling such as toxic releases to
water are thus not taken into
consideration yet the ef ects are very
significant. b. The assertion that a
single forest certification system is
the only means of achieving
sustainability is counterproductive to
achieving environmental goals. To
disregard wood products that come
from third-party verified wel managed
forests because they carry the
"wrong" label is an arbitrary decision.
Both the U.S. and Canada are
commit ed to the importance of
sustainable forest management and
Canada is a world leader and has the
largest area of certified forests of any
country in the world. c. By promoting
rapidly renewable products you make
the assertion that rapidly renewable
building materials did not result in
significant biodiversity loss, did not
increase soil erosion, did not impact th
Life cycle assessment (LCA) and embodied
ef ects during the extraction and manufacturing
stages and their ef ects on the environment
must be taken into account. To foster
sustainable building design, construction and
operations we must first understand what are
the impacts. LCA studies from al over the world
indicate that wood building products are
relatively benign compared to other major
building products. Give credits for LCA and low
embodied energy. Take an inclusive approach
to forest certification and include CSA and SFI
standards.
Include scientific
measurements such as
life cycle assessment so
that you can move from a
prescriptive-base to
performance-base
criteria. Take into
consideration the
embodied energy of
building materials.
Environmental impacts
associated with any
building products
including global warming
should take into account
the entire life of that
product and consider the
environmental burdens of
each step along the way.
Take an inclusive
approach to forest
certification. Provide
credits for long term
rotation. In the case of
wood products take into
consideration that wood
and wood products
sequester carbon thus
reducing greenhouse
gases responsible for
global warming. Give
credits for the facts that
wood is renewable
2/12/2004
This credit is consistent with credits in other bal oted LEED
products. Appropriate changes wil be considered in the future.
No Change
None
MR
MRc2.1-2.5-
Com12
Credit 2.1-2.5
(Optimize Use of
Alternative Materials)
2d - Contains at least 50% rapidly
renewable resources: What is the
definition of rapidly renewable
materials? Trees are harvested at
dif erent ages which produce a
variety of products. i.e.: first thinnings
at ages 13-15 years old wil produce
pulpwood for paper or fiber from
Oriented Stand Board(OSB). At a
second thinning smal sawlogs along
with pulpwood and OSB wil be
merchandized from the harvest. The
final cut wil include sawtimber,
plywood logs along with the
previously mentioned uses. The ages
and management styles vary
according to the objectives of the
landowners which provides diversity
in our forest resource. The definition
needs to recognize the Sustainable
Forestry Initiative program. 2e - Is
FSC certified wood: If preference is
given to FSC wood it wil place an
added cost on private landowners
which wil be a disincentive to
growing trees. The Sustainable
Forestry Initiative program is but one
of several certification systems that
should also be recognized.
Preference to a single certification
system is inappropriate and discrimina
2d- Contains at least 50% rapidly renewable
resources: Management of our forest resource
should be recognized instead of how rapidly we
grow our resource. Credit should be given for
products from the SFI program and or the
American Tree Farm System. 2f - Contains at
least 50% materials harvested and processed or
extracted and processed within 500 miles of the
project: This requirement should be deleted. 3d -
Composite panels and agrifiber products shal
meet the requirements set forth in LEED NC
Credit: The requirements should reference and
recognized national y recognized standards that
provide acceptable limits for formaldehyde
emissions.
2d - Contains at least
50% rapidly renewable
resources: Credit should
be given for the use of
renewable resources
from intensively managed
resources such as forest
stands under a
management plan. 2e -
Is Certified Wood: The
standards should also
recognize the
Sustainable Forestry
Initiative (SFI) program
along with the American
Tree Farm System. 2f -
Contains at lest 50%
materials harvested and
processed or extracted
and processed within
500 miles of the project:
Delete language 3d -
Composite panels and
agrifiber products shal
meet the requirements
set forth in LEED NC
Credit 4.4: Under the
subsection heading
"Requirements," replace
the current sentence
with, "Composite wood
and agrifiber products
must be third party
2/12/2004
This credit is consistent with credits in other bal oted LEED
products. Appropriate changes wil be considered in the future.
No Change
None
MR
MRc2.1-2.5-
Com13
Credit 2.1-2.5
(Optimize Use of
Alternative Materials)
· (2d) Contains at least 50% rapidly
renewable resources: · "rapidly" is a
relative term and "rapidly renewable
materials" is dif icult to define. · In the
case of wood products, it is uncertain
which "short-rotation" products would
be eligible. "Short-rotation" relative to
what? · This makes lit le sense from
an environmental perspective, since
there are various environmental
benefits that derive from dif erent age
classes and rotation lengths in
managed forests. For example, forest
stands of longer rotations are
desirable as habitat for some
species, but not for others that might
prefer less cover and more
disturbance. · This credit can have
the negative impact of encouraging
the harvest of short-rotation plants,
i.e. bamboo, without a requirement
for sustainable yield. (2e) Is FSC
certified wood: · Preference for a
single certification system
discriminates unfairly and
inappropriately. · Many credible
certification systems have evolved to
meet the demands of the
marketplace for independent
certification of conformance to a
recognized sustainable forestry manag
(2d) Contains at least 50% rapidly renewable
resources: · The critical element should be
yields and not rotation lengths, as improved
yields translate into more stored carbon and
less overal land disturbance. (2e) Is FSC
certified wood: · A credit should be given for the
use of materials derived from other credible
certified sources, including the SFI program and
the American Tree Farm System. · Independent
comparisons of the SFI and FSC programs by
the Meridian Institute and the Pinchot Institute
demonstrate that both programs serve to
expand the practice of sustainable forest
management. (2f) Contains at least 50%
materials harvested and processed or extracted
and processed within 500 miles of the project. ·
A study by the National Institute of Standards
and Technology (NIST) points out that the
calculation method for this credit bears lit le
relationship to environmental impacts that are
more a function of mass and transport distances
than cost and distance. · This credit is proposed
for revision in LEED NC 2.2. The discussion on
this credit states that it has "dubious environment
(2d) Contains at least
50% rapidly renewable
resources: · An
additional credit should
be given for using
renewable resource from
intensively managed
resources such as
planted forest stands
(2e) Is FSC certified
wood: · In North America,
recognized sustainable
forestry management
programs include the
Sustainable Forestry
Initiative® (SFI),
Canadian Standards
Association (CSA),
American Tree Farm
System, along with the
FSC. (2f) Contains at
least 50% materials
harvested and processed
or extracted and
processed within 500
miles of the project. · As
there is no verifiable
environmental
justification for a
regional/local criterion of
this kind, this credit as
currently formulated
2/12/2004
This credit is consistent with credits in other bal oted LEED
products. Appropriate changes wil be considered in the future.
No Change
None
MR
MRc2.1-2.5-
Com14
Credit 2.1-2.5
(Optimize Use of
Alternative Materials)
(2d) Contains at least 50% rapidly
renewable resources: "rapidly" is a
relative term and "rapidly renewable
materials" is dif icult to define. In the
case of wood products, it is uncertain
which "short-rotation" products would
be eligible. "Short-rotation" relative to
what? This makes lit le sense from an
environmental perspective, since
there are various environmental
benefits that derive from dif erent age
classes and rotation lengths in
managed forests. For example, forest
stands of longer rotations are
desirable as habitat for some
species, but not for others that might
prefer less cover and more
disturbance. This credit can have the
negative impact of encouraging the
harvest of short-rotation plants, i.e.
bamboo, without a requirement for
sustainable yield. (2e) Is FSC
certified wood: Preference for a single
certification system discriminates
unfairly and inappropriately. Many
credible certification systems have
evolved to meet the demands of the
marketplace for independent
certification of conformance to a
recognized sustainable forestry manag
(2d) Contains at least 50% rapidly renewable
resources: The critical element should be yields
and not rotation lengths, as improved yields
translate into more stored carbon and less
overal land disturbance. (2e) Is FSC certified
wood: A credit should be given for the use of
materials derived from other credible certified
sources, including the SFI program and the
American Tree Farm System. Independent
comparisons of the SFI and FSC programs by
the Meridian Institute and the Pinchot Institute
demonstrate that both programs serve to
expand the practice of sustainable forest
management. (2f) Contains at least 50%
materials harvested and processed or extracted
and processed within 500 miles of the project. A
study by the National Institute of Standards and
Technology (NIST) points out that the
calculation method for this credit bears lit le
relationship to environmental impacts that are
more a function of mass and transport distances
than cost and distance. This credit is proposed
for revision in LEED NC 2.2. The discussion on
this credit states that it has "dubious environment
(2d) Contains at least
50% rapidly renewable
resources: An additional
credit should be given for
using renewable
resource from intensively
managed resources such
as planted forest stands
(2e) Is FSC certified
wood: In North America,
recognized sustainable
forestry management
programs include the
Sustainable Forestry
Initiative® (SFI),
Canadian Standards
Association (CSA),
American Tree Farm
System, along with the
FSC. (2f) Contains at
least 50% materials
harvested and processed
or extracted and
processed within 500
miles of the project. As
there is no verifiable
environmental
justification for a
regional/local criterion of
this kind, this credit as
currently formulated
should be eliminated.
2/12/2004
This credit is consistent with credits in other bal oted LEED
products. Appropriate changes wil be considered in the future.
No Change
None
MR
MRc2.1-2.5-
Com15
Credit 2.1-2.5
(Optimize Use of
Alternative Materials)
CPA likes the opportunity the credit
provides producers of particleboard,
MDF and hardboard to show that
they are using recycled materials.
However, the requirement is not
explicit enough in suggesting
methods by which specifiers can
obtain certified materials. CPA has
developed a program for this exact
need (see below.
The credit would be improved by referencing
ANSI accredited certification programs for
recycled materials. For particleboard, MDF and
hardboard, CPA has an Environmental y
Preferable Product certification that requires that
the raw material be 100% recycled or
recovered. The program requires participating
plants to provide an audited list of raw material
suppliers and the raw material they provide and
participating plants must undergo a quarterly
audit to show ongoing compliance with the
ENVIRONMENTALLY PREFERABLE
PRODUCT SPECIFICATION CPA 1-02. LEED
EB should reference the CPA Environmental y
Preferable Product certification as one avenue
architects and specifiers can use to show
certified recycled content. This is important to
the sustainability of existing buildings because it
encourages architects and specifiers to look for
the highest level of recycled content - 100% - in
the particleboard, MDF and hardboard products
they may specify.
The comments provided
in section 2 reinforce the
intent of the credit - to
encourage the use of
recycled products.
2/12/2004
This credit is consistent with credits in other bal oted LEED
products. Appropriate changes wil be considered in the future.
No Change
None
MR
MRc2.1-2.5-
Com16
Credit 2.1-2.5
(Optimize Use of
Alternative Materials)
This is too specification oriented.
These are nice things but without
quantifying metrics you do not know if
these actual y reduce or add to the
environmental impacts and burdens.
Life cycle metrics for energy must be
used to determine if distance or
recycle content etc real y makes a
dif erent.
Item c is confusing. Suppliers need to provide
life cycle data that at a minimum shows that the
total system energy is equal or less with the
recycled content than without it. Life cycle is
very credible for energy metrics. The %
numbers are arbitrary. Sam comment for rapidly
renewable. This assumes that RR is bet er for
the environment but that may not be true.
Please refer to Scientific American article - "How
green are green plastics" - T. Gerngross August
2000 pages 37-41. We are very concerned with
the 500 mile limit. The energy from
transportation is always much less than the
manufacturing and use processes. The key
metric should be a life cycle energy not miles
from end use. Companies can cheat by making
product in developing nations and then shipping
close and assembling the final product.
The term post industrial
is misleading.
Companies can easily
cheat. Companies must
show that the material
was actual y diverted
from the waste stream
and that the life cycle
shows the embodied
energy is now less than
without it. While I like
FSC - I see no reason
why it is preferred over
other certification
systems that have third
party verifications of their
forestry process.
2/12/2004
See response to comment MRc2.1-2.5-Com24 on LifeCycle
assessment. See response to comment MRc2-Com1 on FSC
wood.
No Change
None
MR
MRc2.1-2.5-
Com17
Credit 2.1-2.5
(Optimize Use of
Alternative Materials)
n/a
This credit should apply to purchases over $500
or $1,000. The $100 trigger point is too minimal
for construction purchasing.
n/a
2/12/2004
LEED-EB is trying to capture almost al purchases, as such, this
low dol ar threshold is appropriate.
No Change
None
