EB Comment Period 1-Responses edits

Shana

Description

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, 2004Issue Proposed Changes to LEED-EB for Second Category Comment # Credit Likes and Dislikes Ways To Improve Language Changes Responses Type of ChangeSummaries Comment DraftHVAC system maintenance as it relates to cleanliness is a major problem in After IEQ Prerequisite 1, the heading should read, “HVAC Systems”. nearly all existing buildings. This issue has not been addressed in any part of Though outside air and exhaust systems are important considerations for IEQ, the cleanliness of HVAC The Intent can remain the same. Under Requirements, another bullet Prereq 1 the EB draft document. It seems that it should be mentioned in the IEQ In future revisions of LEED-EB, consideration HVAC system systems is equally if not more important. We believe that IEQ Prerequisite 1, should encompass the should read, “Conduct HVAC system inspections in accordance with IEQ IEQp1-Com1 (Outside Air and section. The current prerequisite is very narrow and only addresses the outside will be given to having prerequisites or credits on No Change Nonemaintenance entire HVAC system and not only outside air and exhaust. We further believe that HVAC system ACR 2004, (Assessment, Cleaning and Restoration of HVAC systems), Exhaust) air and exhaust systems. As it now stands, assuming that all other cleanliness of dust systems.cleanliness ...

Informations

• Publié par: Zazak
• Nombre de lectures: 78
• Langue: English

Extrait

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

Responses

Proposed Changes to LEED-EB for Second

Comment Draft

Type of Change

IEQ

IEQp1-Com1

HVAC system

maintenance

Prereq 1

(Outside Air and

Exhaust)

HVAC system maintenance as it relates to cleanliness is a major problem in

nearly al existing buildings. This issue has not been addressed in any part of

the EB draft document. It seems that it should be mentioned in the IEQ

section. The cur ent prerequisite is very nar ow and only addresses the outside

air and exhaust systems. As it now stands, assuming that al other

performance criteria of the HVAC system is met, a building with severe HVAC

microbial contamination problems could actual y receive LEED certification.

Though outside air and exhaust systems are important considerations for IEQ, the cleanliness of HVAC

systems is equal y if not more important. We believe that IEQ Prerequisite 1, should encompass the

entire HVAC system and not only outside air and exhaust. We further believe that HVAC system

cleanliness inspections should be of ered as a credit for IEQ.

After IEQ Prerequisite 1, the heading should read, “HVAC Systems”.

The Intent can remain the same. Under Requirements, another bul et

should read, “Conduct HVAC system inspections in accordance with

ACR 2004, (Assessment, Cleaning and Restoration of HVAC systems),

a standard published by the National Air Duct Cleaners Association,

(NADCA)”.

In future revisions of LEED-EB, consideration

wil be given to having prerequisites or credits on

cleanliness of dust systems.

No Change

None

IEQ

IEQp1-Com2

Measure

delivered

performance to

occupant

Prereq 1

(Outside Air and

Exhaust)

I have some concerns about this Prereq because the introduction of potential y

suf icient outdoor air into the building does not guarantee the delivery of this

outdoor air for ventilation to where the people are in the building. Reasons for

this include such aspects of the supply air delivery system as the operation of

variable air volume systems, blocked return plenums, closed fire dampers, and

leaks.

This Prereq could be rewrit en to require demonstration that the intended amount of outdoor air for

ventilation was being delivered to the occupied spaces, and not merely "to al ow the appropriate amount

of outside air introduction."

This Prereq could be rewrit en to require demonstration that the

intended amount of outdoor air for ventilation was being delivered to

the occupied spaces.

This is addressed in the LEED-EB EA

commissioning prerequisite.

No Change

None

IEQ

IEQp1-Com3

Measure

delivered

performance to

occupant

Prereq 1

(Outside Air and

Exhaust)

Delivered performance is the desired outcome of measured mechanical

performance and is most directly related to occupants.

Repeat of comments on EA credit 3.2- 1: Measuring the delivered performance of systems is an important

part of recognizing the changes in a building lifecycle. For example buildings designed less than 2

decades ago considered the cooling load (range) at more than 2 times today’s levels. Load reductions

have been realized by several items including the prevalence of LCD monitors, and more ef icient lighting.

As a building turns greener, the mechanical performance of its systems may remain at peak levels; but

the delivered performance of the systems may no longer match changed building conditions. Even short

time frame changes, such as overal tenant occupancy and building use, can have an ef ect on the

changes needed to delivered performance in order to meet the goals of this rating system.

1. In “Requirements” section, first bul et: remove “10 CFM” and replace

it with “the appropriate CFM for the building type as established by

ASHRAE.” REASON: building types have various ventilation

requirements 2. In “Requirements” section, last bul et after the word

“operation” add the words “ and delivered results” REASON: equipment

operating properly that is not designed cor ectly for the space wil

qualify for points – the “Intent” of the segment focuses on IAQ which is

a product of HVAC performance and design. 3. Add a second

paragraph under “Potential Technologies & Strategies”: “Measure the

delivered performance of the system to determine if equipment design

is an adequate match for cur ent building use and activity levels by

periodical y measuring IAQ parameters set forth in the “Owner’s

Operational Requirements” at times of peak occupancy or major

tenant/use change.” REASON: Building conditions change and

matching both design peak loads and actual peak loads provides an

opportunity to optimize both IAQ and ventilation energy savings. 4. Add

See response to IEQp1-Com2

See response to IEQp1-Com2

See response to IEQp1-Com2

IEQ

IEQp1-Com4

Require greater

measurement of

parameters

Prereq 1

(Outside Air and

Exhaust)

None

Issue #1 You should require them to submit measurement data showing supply air temps (drybulb and

wet bulb) on a design day when the maximum OA is being brought in. That way you know that the

system can actual y dehumidify al the OA that it's bringing in on a DESIGN day, not just the day the

inspector is there. Otherwise, bringing in large quantities of OA with an old existing air handler that was

not designed to handle the latent load can cause problems. Without properly dehumidifying the air, it wil

cause DIFFERENT indoor air problems, such as mold, claminess, and discomfort. Issue #2 High rise

building central exhaust systems (such as bathrooms) should be required to have a means of

counteracting the chimney ef ect to ensure an accurate and consistent amount of exhaust from each

space no mat er how much pul the chimney ef ect is exerting on the building at dif erent times of the year

due to temperature dif erences. This may mean an air measuring station and damper at the outlet at the

top of the building. The chimney ef ect operating through central exhausts or elevator shafts with

None

These issues are addressed by the EA

commissioning prerequisite, the EA

measurement credit and IEQ Credits 1, 7.1 , 7.2

and 9

No Change

None

IEQ

IEQp1-Com6

Prereq 1

(Outside Air and

Exhaust)

No link to Owner's Program, functional tests or system monitoring required to

document OA & EA system operations. The monitoring of OA & EA should be

included in Monitoring building systems operations and 'Best Practices' for

maintenance provides recommended procedures for maintaining OA & EA

systems. The number of inspections should be dictated by maintenance 'best

practices' at minimum or the Owner's requirements which ever is more

stringent. 'Best Practices' for maintenance should be based on some

recognized protocol, such as ASHRAE Guidelines or NIST.

LEED-EB Reference Guide wil include

recommendation that IEQ prerequisite 1 action

be included in building operating plan.

No Change

None

IEQ

IEQp1-Com7

10 cfm/person

set too low

Prereq 1

(Outside Air and

Exhaust)

IEQ prerequisite 1 is an important requirement for any green building.

The language under the requirements for the ventilation rate should be improved to encourage a

ventilation rate higher than 10cfm/person. For your information, the Indoor Environments Division at the

Environmental Protection Agency has been developing green building guidance as it relates to Indoor

Environmental Quality, “Indoor Environmental Quality Guidance for Green, High Performance, and

Sustainable Buildings.” The purpose of this guidance is to establish robust and comprehensive criteria

that would serve as the foundation for the development of requirements for federal buildings, and help

inform other green building entities. The guidance covers both new building construction, and existing

buildings. An internal review of this guidance has just begun. We wil send our internal review draft for

your consideration to the EB commit ee e-mail address. We hope that this document, although draft, wil

help you as you develop LEED EB. See Part 2 (Existing Buildings) Section 3 (HVAC Operations) of this

document for more information about ventilation rates.

Suggested language is something along the lines of: “Maintain existing

building outside-air (OA) ventilation distribution to meet or exceed the

outdoor air flow ventilation rate requirements of ASHRAE Standard 62-

(latest version) during al modes of operation during occupied hours,

or, if system capacity is a limiting factor, the highest outdoor air

ventilation rate feasible, but not less than 10 cfm per occupant.

Increase the capacity of the HVAC system if necessary to meet this

criterion. Additional y, Meet the outdoor air flow ventilation rate

requirements of ASHRAE Standard 62 (latest version) for any

renovations or additions where the standard applies. {E.g., See

ASHRAE Standard 62-2001 (Addendum k)}”

The first bul et under the Requirements wil be

changed to : "Maintain existing building outside-

air (OA) ventilation distribution to meet or exceed

the outdoor air flow ventilation rate requirements

of ASHRAE Standard 62-(latest version) during

al modes of operation during occupied hours,

or, if system capacity is a limiting factor, the

highest outdoor air ventilation rate feasible, but

not less than 10 cfm per occupant. Increase the

capacity of the HVAC system if necessary to

meet this criterion. Additional y, meet the

outdoor air flow ventilation rate requirements of

ASHRAE Standard 62 (latest version) for any

renovations or additions where the standard

applies." This recognizes that some older

buildings have system limitations that limit OA

intake and encourage existing buildings to meet

the standards for new buildings where this is

feasible. Requirements bul et 2 wil be changes

to: " Meet the EPA IAQ guidelines in "Building

ir Quality Action Plan", (EPA 402-k-98-001),

Make changes included in the Response Column Clarification

IEQ

IEQp1-Com8

10 cfm/person

set too low

Prereq 1

(Outside Air and

Exhaust)

Requirements - ". . not less than 10 cfm/person. ." of outside air is only 50% of

cur ent code. This is inadequate, even for an existing building. The prerequisite

should be cur ent code as a minimum. - "Meet the EPA IAQ guidelines or

SMACNA IAQ guidelines for HVAC system maintenance. . " Please state the

specific guideline and where it can be found on the www. - "test and maintain

the operation of al building exhaust . . " This statement is specific about

requiring a "test" but it is not clear what type of "test" is intended. Also the

submit als for initial certification do not ask for test results. This seems quite

ambiguous and possibly inconsistent.

n/a

The Potential Technologies and Strategies paragraph should be

reworded. The visual inspection and removal process should be

specific about bird and rodent nests which are a significant hazard.

Also relocation of OA intakes and exhausts which are closer than 15

feet of each other. Both of these issues cause more problems with IAQ

than "obstructions." Also in this paragraph . ." conduct airflow

monitoring to document OA . ." is not specific enough relative to

monitoring period. Is the intent periodic testing or continuous

monitoring? In this paragraph and in the submit als, the applicant is

asked to compare measured flow to designed flow. Care should be

taken here because the cur ent use of the building may (and usual y

does) require flows dif erent than the original design because the

cur ent use is dif erent! This is the essence of retrocommissioning.

Submit als - Require the engineer or HVAC systems specialist to be a

Registered Engineer, certified test and balance technician (AABC or

NEBB), or certified building commissioning professional (BCA or AEE).

See response to IEQp1-Com7.

See response to IEQp1-Com7.

IEQ

IEQp1-Com11

Clarify and

delineate

between

inspection and

testing

requirements

Prereq 1

(Outside Air and

Exhaust)

Overal the premise of having an outside air distribution and exhausts systems

in proper working order is fundamental y sound. However, it is unrealistic to

expect most building owners to al ocate enough O&M staf ing resources and/or

budget for a mechanical engineer/HVAC testing specialist to “test”, and verify

that “al ” of these systems operate cor ectly on a quarterly basis. The language

in this prerequisite doesn’t clearly delineate between inspecting and testing.

Clearly delineate between the inspection and testing requirements. To meet the prerequisite, require that

outside airflow be measured by a mechanical engineer or HVAC system specialist to verify 10 CFM per

person airflow. Also require inspection of al air handling and exhaust air system components by this

consultant or building operation staf . Ongoing requirements would include annual measurement of

outside airflows and quarterly “inspections” of al fan and exhaust systems.

Submit als-initial Provide a let er and backup information from

mechanical engineer or HVAC system specialist demonstrating that the

outside airflow serving the building is operating as designed and

delivering a minimum of 10CFM per person. Provided information and

records indicating al air handling and exhaust air systems have been

inspected are operating as intended. Submit als-Re-certification

Provide a let er and backup information from mechanical engineer or

HVAC system specialist demonstrating that the outside airflow system

serving the building is operating as designed and delivering a minimum

of 10CFM per person. Provide information and records indicating al air

handling and exhaust air systems have been inspected on a quarterly

basis and continue to operate as intended.

See response to IEQp1-Com7.

See response to IEQp1-Com7.

IEQ

IEQp2-Com1

Broaden

al owable

performance

verification

method

Prereq 2

(Environmental

Tobacco Smoke

(ETS) Control)

I like the optional methods available for compliance, but do not like the limited

method of performance verification al owed. Performance verification must be

prescriptive to establish standards and limitations, if scientific validity and

consistency of the results are desired.

Performance verification should be limited to the use of measurement instruments that have been

calibrated to a national reference standard or verified as "cur ent" (e.g. NIST). Methods of performance

verification can be either by dif erential pressure or dif erential airflow measurement (which is a more

stable method of control). Performance can be verified by either handheld devices, when used in

compliance with ASHRAE Standard 111 for Test and Balance, or, by means of permanently instal ed

sensors for control. Permanently instal ed velocity or dif erential pressure sensors must be calibrated to a

national reference standard, either permanently or within the previous 6 months. The number of sensors

used or the number of measurements taken in an opening or duct should be more than one, and

suf icient for the cross-sectional area to reduce the sampling er or to an acceptable level.

In place of the 4th para of Option #2: Dif erential airflow/pressure

performance shal be verified periodical y in accordance with the

recalibration recommendations of the instrument manufacturer used for

testing or control. Performance verification should be limited to the use

of measurement instruments that have been calibrated to a national

reference standard, permanently or within the previous 6 months (e.g.

NIST). Methods of performance verification can be by dif erential

pressure or dif erential airflow measurement (which is a more stable

method of control). Performance shal be verified by either handheld

devices, when used in compliance with ASHRAE Standard 111 for Test

and Balance, or, by means of permanently instal ed sensors for control.

Permanently instal ed velocity or dif erential pressure sensors must be

calibrated to a national reference standard, either permanently or within

the previous 6 months. Permanently calibrated sensors can only be

microprocessor-based designs and car y the manufacturer's

certification of this feature and of the calibration reference standards used

LEED-EB is fol owing the lead of LEED-NC, the

IEQ TAG, and the LEED-EB Commit ee on the

approach to this credit. If this credit is changed

for LEED-NC, LEED-EB wil incorporate these

changes in an appropriate way for existing

buildings,

No change

None

IEQ

IEQp2-Com2

Credit instead of

prereq

Prereq 2

(Environmental

Tobacco Smoke

(ETS) Control)

This requires a great deal of ef ort on the owners/operators part. IT SHOULD

BE A CREDIT !

GIVE 'EM A POINT FOR PROHIBITING SMOKING !

-

See response to comment IEQp2-Com1 on

ETS.

No change

None

IEQ

IEQp2-Com3

Eliminate

residential path

language

Prereq 2

(Environmental

Tobacco Smoke

(ETS) Control)

IEQPR2: Do we real y need to keep the residential path in here. Are we real y

contemplating come sort of high-rise or low-rise residential EB program???

Seems to me that’s a good place to draw the line. If so, there’s no point in

clut ering up the standard with the residential requirements.

See response to comment IEQp2-Com1 on

ETS. Various residential applications wil show

up.

No change

None

IEQ

IEQp3-Com2

CIH audited

report

Prereq 3

(Asbestos

Removal or

Encapsulation)

1.) A formal CIH audited report can be time consuming and expensive

depending on the size of the organization's facility applying for certification. Is

their an acceptable alternative that would achieve the desired objective (spot

checking or let ers from a project's architect and general contractor stating that

no asbestos containing materials were used or specified on the project seeking

certification )?

For older buildings it is important to establish

that the asbestos has either been removed or

appropriately encapsulated. It appears that the

only way to conclusively establish this is to have

the building inspected by a CIH.

No change

None

IEQ

IEQp3-Com3

Exclude exterior

asbestos from

credit

Prereq 3

(Asbestos

Removal or

Encapsulation)

Ø Exterior asbestos, such as roof flashing, is real y not a concern for IEQ and

should not be included

LEED-EB addresses the overal environmental

impacts of buildings and IEQ is only part of the

overal impact. Exterior asbestos is also part of

the overal environmental impact.

No change

None

IEQ

IEQc1-Com1

Al ow DCV or OA

airflow measure

for al

applications and

clarification

Credit 1 (Outdoor

Air Delivery

Monitoring)

Not sure what “densely occupied spaces” is. This should be a more explicit

definition. DCV should be acceptable for al mechanical systems, especial y

of ice buildings where space occupancy can vary widely in the course of a day.

Al ow DCV or OA airflow measure for al applications.

Al ow DCV or OA airflow measure for al applications, combine the two

paragraphs.

Densely occupied space wil be defined as

occupant densities of more than __ people per

thousand square feet. This wil be added to the

Technologies and Strategies section. The push

for CO2 monitoring is to move to using actual

feedback on the delivered indoor environment as

it is af ected by occupancy to drive building

Make Changes included in the Response

Columns

Clarification

IEQ

IEQc1-Com2

Shorten submit al

period

Credit 1 (Outdoor

Air Delivery

Monitoring)

Submit al requirements require 4 quarters worth of data.

Does this result in the certification process taking over a year to comply with? Possibly only 6 months and

commitment in a plan for continue quarterly reporting.

None

See response to Comment Gen-Com1 on

amount of performance data needed for initial

certification under LEED-EB.

No change

None

IEQ

IEQc1-Com3

Credit 1 (Outdoor

Air Delivery

Monitoring)

Use of CO2 to control ventilation actual y reduces IAQ since it can results in

outdoor air rates below design minimums. Therefore it should not be given a

credit in EQ. DCV is more properly addressed in EA Credit 1. This credit

cannot be entirely performance-based without losing its ability to provide

dependable and consistent results. If retained in this credit, it should be strictly

limited in application and function. I like: the at empt to make this similar to the

credit requirements for LEED-NC, the shift in titles away from a specific control

method and sensor type, and with more on-going performance verification. I do

not like the large measurement er or rate al owed from design set point. It

appears like an al owance for the limited ability of some measurement

technologies or methods. It is also a duplication of the references to CO2-

based DCV already required under ASHRAE 90.1 for specific spaces and not a

reliable method of building ventilation control (thus the energy saving potential,

references available on request). Most older designs include only 20% ef icient

intake filtration. I am concerned that the requirement for MERN 13 (80% ef icient

1. Add more prominent indication that this credit is intended for "mechanical y ventilated systems only"

and that natural y ventilated spaces should be addressed elsewhere. 2. The credit should be limited to

structures with automated ventilation controls or complete DDC control systems. (The results intended by

the credit cannot be obtained by unverified and uncontrol ed manual testing process with hand

instruments). 3. Delete references to specific methods (DCV) and sensor types (CO2) when the end

result can be generical y stated as: " dynamic ventilation rate control with reset based on occupancy

changes". Leave the determination of sensor type to the mechanical design engineer. The credit intention

and consistency are bet er served with a concentration on those elements that ensure reliable and

repeatable control. 4. If retained, the credit must define the application limitations for CO2-based DCV.

"Densely occupied" is insuf icient. "Variable and intermit ent occupancy only" should be added, as wel as

specific structure type limitations. 5. Add a requirement for regular performance verification. Without it,

owners wil mot see benefits from their first-cost investment. 6. Intake filtration ef iciency should be left to the

I wil not at empt to rewrite the entire credit, but should include sections

or statements with the fol owing: Intent Provide mechanical y ventilated

systems the capacity for dynamic intake rate monitoring and control,

plus increased filtration ef iciency to help sustain long-term occupant

comfort and wel being. Requirements Instal permanent monitoring

and control systems that provide continuous feedback on ventilation

system performance to ensure that ventilation systems maintain

minimum ventilation rates during al operating and environmental

conditions, and utilize increased ef iciency air filters in redesigns or

renovations, as determined by the design engineer. Potential

Technologies & Strategies For dedicated mechanical ventilation

systems that specifical y serve densely, variable and intermit ently

occupied spaces, provide the fol owing: . . . • For each densely,

variable and intermit ently occupied space, provide a dedicated

ventilation system control ed by CO2 sensor(s) located in the breathing

zone of each variable occupancy space, and instal ed as prescribed for

See response to Comment IEQc1-Com1

See response to Comment IEQc1-Com1

See response to Comment IEQc1-Com1

IEQ

IEQc1-Com4

Specify shared-

sensor as

alternative CO2

monitoring

approach

Credit 1 (Outdoor

Air Delivery

Monitoring)

I like this Credit because the delivery of adequate or generous amounts of

ventilation is critical to the achievement of healthy and productive

environments. Since ventilation is so important, it needs to be monitored to

manage it ef ectively.

This Credit could be improved by modifying its wording to reflect the fact that there are TWO techniques

for monitoring CO2 concentrations in the occupied spaces. In addition to the use of distributed individual

sensors, there is the use of the shared-sensor approach that of ers considered advantages to the building

owner in terms of sustainability. Not only is the ventilation rate inherently more accurate with one CO2

sensor reading both the indoor and outdoor values, its Life Cycle Costs are lower due to reduced costs

for the calibration of sensors. Specifical y the first point under Technologies & Strategies could be

therefore reworded to say: For each densely occupied space provide a CO2 sensor or sampling location

in the breathing zone of the room.

Specifical y, the first point under Technologies & Strategies could

therefore be reworded to say: For each densely occupied space

provide a CO2 sensor or sampling location.

Change the first bul et under Technologies &

Strategies to "For each densely occupied space

provide a CO2 sensor or sampling location"

Make changes in Response Column

Editorial

IEQ

IEQc1-Com6

Require outdoor

air delivery

monitoring

Credit 1 (Outdoor

Air Delivery

Monitoring)

I do not like the fact that some buildings can get this credit without outdoor air

delivery monitoring.

The credit should require ALL systems to measure outdoor airflow rate. Densely occupied spaces should

not be exempt. Otherwise it wil not be possible to verify that systems get at least the area-based

requirement of Standard 62. The term "densely occupied space" should be defined. What if a space is

sometimes densely occupied, but not always densely occupied?

Replace "For mechanical ventilation systems that predominantly serve

densely occupied spaces, provide the fol owing:" with "Provide the

fol owing:" and delete the sentence: "For al other mechanical

ventilation systems, provide the fol owing:"

See response to Comment IEQc1-Com1

IEQ

IEQc1-Com7

MERV 13 rating

requirement too

high

Credit 1 (Outdoor

Air Delivery

Monitoring)

The use of MERV 13 appears to be excessive filtration and wil cause the HVAC

units to use more energy due to the pressure drops. These fine filters wil plug

up sooner and need more replacements. Suggest a lower MERV as a

compromise.

see above

see above

Change the end of the requirements sentence

from " and utilize Merv 13 air filters in ventilation

system" to: "and utilize MERV 13 air filters in

large ventilation systems and MERV 6 air filters

in smal ventilation systems.

Make changes included in the Response Column Clarification of Requirement

IEQ

IEQc1-Com9

MERV 13 rating

requirement too

high

Credit 1 (Outdoor

Air Delivery

Monitoring)

-

Al ow lower MERV rated filters for equipment that cannot accommodate MERV 13 filters.

-

See response to IEQc1-Com7

See response to IEQc1-Com7

See response to IEQc1-Com7

IEQ

IEQc1-Com11

MERV 13 rating

requirement too

high for smal

ventilation

systems and

editing

Credit 1 (Outdoor

Air Delivery

Monitoring)

In the potential technologies & strategies, the definition of serve densely

occupied spaces is undefined. ASHRAE 62 defines the density that can be

used here.

It indicates to use MERV 13 filter but fail to address what types of equipment need to comply with it.

Existing equipment with direct drive fans wil be dif icult to upgrade to accommodate MERV 13 filter.

Products such as smal unit ventilators are not economical y justifiable using MERV 13 filter.

The intent is fine. For the requirements, instal permanent monitoring

systems that provide feedback on ventilation system performance to

ensure that ventilation systems maintain minimum ventilation rates and

utilize MERV 13 air filters in large ventilation systems and MERV 6 air

filters in smal ventilation systems.

See response to IEQc1-Com7

See response to IEQc1-Com7

See response to IEQc1-Com7

IEQ

IEQc1-Com12

MERV 13 rating

requirement

prohibitive

Credit 1 (Outdoor

Air Delivery

Monitoring)

We agree with the changes made to this credit to clarify the CO2 sensor

requirements. However, we do not agree with requiring Merv 13 air filters as a

part of this outdoor air monitoring measure. Filtration requirements should be

separated out from outdoor air monitoring and CO2 control. If the existing

system is not designed for the pressure drop of these Merv 13 filters, this

should not preclude them from this credit.

Our recommendation is to create a separate credit for high ef iciency, low pressure drop filtration

(extended surface air filters) instead of including filtration requirements with the outdoor air monitoring

credit. Extended surface filters provide very high particle capture ef iciencies with very low initial static

pressure drops. In addition, their useful lives are extended and prefilter use may be eliminated. Al of

these factors add up to a more sustainable filter application – one that saves energy compared to typical

filter designs and results in less waste in the landfil .

We suggest that al filtration requirements be removed from the IEQ

Credit 1 language.

See response to IEQc1-Com7

See response to IEQc1-Com7

See response to IEQc1-Com7

IEQ

IEQc1-Com8

Monitoring versus

testing

Credit 1 (Outdoor

Air Delivery

Monitoring)

The USGBC should consider of ering 1 point for quarterly testing of indoor air

quality (CO, CO2, Ozone, IVOC's and particulates) for each space zone served

by an air handler (minimum of one zone per air handler), or as a minimum one

test per every 10,000 ft2 of building floor space. These tests should trend a

minimum of a 24 hour period (capturing occupied and unoccupied) for each

space. In the event that concentrations exceed acceptable limits, cor ective

actions should be taken and documented. A second point should be given for

permanently instal ed monitoring systems. The USGBC should consider that

CO2 is only an indication of IAQ and other pol utants can exist in spite of low

CO2. Also, CO2 measurement should be monitoring a dif erential between

outside ambient and inside CO2 in order for the control system to maintain a

maximum dif erential of 700 ppm. This interpretation of ASHRAE Standard 62,

is often misunderstood. Also, "densely populated" should be defined.

n/a

n/a

In technologies and strategies and at the end of

the first bul et: " and compare with outdoor

ambient CO2 measurements".

Make changes included in Response Column.

Clarification

IEQ

IEQc1-Com10

Consolidate with

IEQ Prerequisite

1 and EA credit

3.3- 1

Credit 1 (Outdoor

Air Delivery

Monitoring)

This may be similar to IEQ Prerequisite 1 and EA credit 3.3- 1 and might

possibly benefit from consolidation. The CO2 sensor requirements may be

unrealistic based on technology cur ently available

none

none

See response to Comment IEQc1-Com1.

See response to Comment IEQc1-Com1.

See response to Comment IEQc1-Com1.

IEQ

IEQc1-Com13

Emphasize credit

as ventilation

measurement not

CO2 control

Credit 1 (Outdoor

Air Delivery

Monitoring)

2) This question incor ectly assumes that IEQ Credit #1 is for implementing

CO2 Control. As I understand it, having been on the Pocantico IEQ Commit ee

that drafted the original wording, the INTENT of this Credit is diagnostic and its

purpose it to provide feedback to the operators on the amount of ventilation

actual y provided. After al , if it's not being measured, how can it be managed

ef ectively. Therefore, I suggest that the answer to this question be expanded

to help clarify this distinction, and al too frequent misunderstanding. For

additional information there is ASTM Standard D6245 on Using CO2 to

Evaluate IAQ and Ventilation that states specifical y, in Section 1.7, that "This

guide does not address the use of indoor CO2 to control outdoor air intake

rates."

This credit is for gathering this information and

using it to improve control of the IEQ of the

building. Descriptions of how this can be done

wil be added to the LEED-EB Reference guide.

No Change

None

IEQ

IEQc2-Com1

Credit wastes

energy (30%

ventilation

ef ectiveness

level too high)

Credit 2

(Increased

Ventilation)

The proposed solution of 30% more outdoor air runs counter to an energy

saving approach for the building and of ers no guarantee that it wil improve

IAQ. If there is a poor air distribution system, you wil waste a lot of energy and

stil have poor air quality.

Revise to a proper ventilation ef ectiveness level. This wil push for bet er system design, without

excessive energy use

Verify that an air change ef ectiveness (ACE) of 1.0 is achieved. ACE as

defined by ASHRAE Standard 129. Air Change Ef ectiveness (ACE) is a

measure of how wel air is delivered to a space and should remain a

valid goal for a credit.

This credit is encourage increase ventilate of the

buildings. The Energy prerequisites and credits

provide major incentives for maintaining energy

ef iciency.

No Change

None

IEQ

IEQc2-Com2

Credit wastes

energy (30%

ventilation

ef ectiveness

level too high)

Credit 2

(Increased

Ventilation)

There should be a balance between providing adequate ventilation and

increasing energy usage with too much ventilation. ASHRAE has determined

adequate ventilation needs in ASHRAE-62-2001. Meeting this standard should

be enough to meet this credit. Exceeding this standard wil just serve to

increase energy usage more than necessary.

Meeting the ASHRAE-62-2001 standard should be enough to meet this credit.

"Increase outdoor ventilation rates to the minimum rates required by

ASHRAE 62-2001."

See response to IEQc2-Com1

See response to IEQc2-Com1

See response to IEQc2-Com1

IEQ

IEQc2-Com3

Credit wastes

energy (30%

ventilation

ef ectiveness

level too high)

Credit 2

(Increased

Ventilation)

This could greatly increase energy costs and resulting air pol ution.

Only require when additional heating /cooling / humidification is not required for outdoor air.

-

See response to IEQc2-Com1

See response to IEQc2-Com1

See response to IEQc2-Com1

IEQ

IEQc2-Com4

Credit wastes

energy (30%

ventilation

ef ectiveness

level too high)

Credit 2

(Increased

Ventilation)

This credit is of questionable value and conflicts with reducing energy

consumption. There is no evidence that increasing outside air above 20

cfm/person improves indoor air quality beyond that provided by 20 cfm/person.

This credit wil increase energy resources unnecessarily and should be

dropped from consideration.

n/a

n/a

See response to IEQc2-Com1

See response to IEQc2-Com1

See response to IEQc2-Com1

IEQ

IEQc2-Com5

Credit wastes

energy (30%

ventilation

ef ectiveness

level too high)

Credit 2

(Increased

Ventilation)

-

We are concerned that this credit may not improve IAQ that much, while increasing building energy use

significantly. We suggest defer ing this credit to a later LEED EB version after more data has been

col ected on this topic.

-

See response to IEQc2-Com1

See response to IEQc2-Com1

See response to IEQc2-Com1

IEQ

IEQc2-Com6

Credit wastes

energy (30%

ventilation

ef ectiveness

level too high)

Credit 2

(Increased

Ventilation)

Many existing buildings are already over-ventilated because of infiltration

problems. Arbitrarily increasing ventilation rates in a building doesn’t always

result in improved occupant comfort or bet er indoor air quality. Increasing

ventilation rates above an original system design leads to additional cooling or

heating requirements. If the systems were not designed to meet this additional

peak summer or peak winter load, then occupant discomfort may result. In

humid climates, excessive introduction of outside air can result in high indoor

humidification levels and increase the risk of mold or mildew growth. Raising

ventilation rates wil lead to higher levels of energy usage from the increased

mechanical cooling and dehumidification loads and increased heating loads.

This credit directly conflicts with the goals of LEED-EB’s Energy and

Atmosphere requirements. ASHRAE 62 was designed to keep buildings wel -

ventilated – going beyond this standard reduces the sustainability of the

building operations without a commensurate increase in benefits.

We suggest that if the USGBC wishes to promote analysis of proper ventilation requirements, using

ASHRAE 62-99 as the actual requirement (IEQ Credit 9-LEED-EB EB Pilot 7/22/03) is more reasonable

approach.

See above comments and adapt the requirements

See response to IEQc2-Com1

See response to IEQc2-Com1

See response to IEQc2-Com1

IEQ

IEQc2-Com7

Credit wastes

energy (30%

ventilation

ef ectiveness

level too high)

Credit 2

(Increased

Ventilation)

The energy use impacts of this credit do not seem to have been considered.

Also, is more outside air always bet er?

This credit should not be al owed unless the applicant can show that the additional energy required to

heat/cool the outside air has been of set by an equal amount of energy savings. Otherwise the IEQ

benefits may be of set by air pol ution damage, leaving overal sustainability worse than before.

I'm not sure if the intent of this credit is valid, but assuming for the

moment that it is, then I would suggest altering the requirement to

read, ". .at least 30% above those required by ASHRAE Standard 62-

2001 without a net increase in building energy use". If that doesn't

seem feasible, then reduce from 30% to 20% or whatever is feasible to

of set with improved energy ef iciency.

See response to IEQc2-Com1

See response to IEQc2-Com1

See response to IEQc2-Com1

IEQ

IEQc2-Com8

Credit wastes

energy (30%

ventilation

Credit 2

(Increased

Ventilation)

IEQ2: Have you-al run this by EA TAG to ascertain the energy impacts of

this?

See response to IEQc2-Com1

See response to IEQc2-Com1

See response to IEQc2-Com1

IEQ

IEQc2-Com9

Credit is too

contentious and

should be

removed

Credit 2

(Increased

Ventilation)

This is not a valuable Credit to of er. There is too much contentious issue over

the amount of outside air that is a meaningful measure of performance, either

from the occupant comfort or productivity viewpoint. Checking with a member

of the ASHRAE 62 commit ee, it would behoove this credit to be left out of the

LEED EB requirement at this time. It would just open Pandora's box to

interpretation or misinterpretation and possible future litigation.

This credit cannot be improved.

This Credit is not important to a sustainable building

See response to IEQc2-Com1

See response to IEQc2-Com1

See response to IEQc2-Com1

IEQ

IEQc2-Com10

Consider outdoor

air quality,

dehumidification,

and air exhaust

levels

Credit 2

(Increased

Ventilation)

Providing additional outdoor air ventilation may not provide the best interest/

comfort to the building occupants.

Outdoor air quality, dehumidification, exhaust right amount of air should be considered at the same time.

Intent: Provide good outdoor air quality, dehumidification, and exhaust

right amount of air to improve indoor air quality for improved occupant

comfort, wel being and productivity.

See response to IEQc2-Com1

See response to IEQc2-Com1

See response to IEQc2-Com1

IEQ

IEQc2-Com11

30% ventilation

ef ectiveness

level too low to

decrease short-

term

absenteeism

Credit 2

(Increased

Ventilation)

While studies have shown reduced short-term absenteeism associated with

increases in ventilation, I wonder if additional Credit could be given to

ventilation rates that are 60% greater than the minimum recommended in

ASHRAE 62

Since the most definite method for determining the amount of ventilation provided is with in space carbon

dioxide (CO2) monitoring throughout the day, perhaps this Credit could be improved by including specific

mention of the indoor to outdoor dif erential in CO2 concentration that should not be exceeded.

I suggest that under the Submit als for Certification there be the

requirement that CO2 monitoring data be provided to demonstrate that

the desired ventilation rates are being achieved. Just as the ASHRAE

Of ice minimum of 20 cfm/person can be demonstrated if the indoor to

outdoor CO2 dif erential never exceeds 530 ppm, the achievement of

26 cfm/person is demonstrated if the indoor to outdoor dif erential never

exceeds 400 ppm.

See response to IEQc2-Com1

See response to IEQc2-Com1

See response to IEQc2-Com1

IEQ

IEQc2-Com12

30% ventilation

ef ectiveness

level too low to

decrease short-

term

absenteeism

Credit 2

(Increased

Ventilation)

While there appear to be benefits to productivity in increasing the ventilation

rate over the ASHRAE minimum, I am concerned that a 30% increase may not

be enough. In the paper by Milton et al, Risk of Sick Leave Associated with

Outdoor Air Supply Rate, Humidification, and Occupant Complaints (Indoor Air

2000; 10: 212-221), it was reported that short-term absenteeism decreased in

going from moderate ventilation to high ventilation. In this study moderate

ventilation was defined as 25 cfm/person and high ventilation was 50

cfm/person.

This Credit could be improved by requiring that ventilation rates be increased by at least 100% above

those required by ASHRAE Standard 62. This Credit could also be improved by mentioning that the most

accurate way of demonstrating the actual ventilation rates is with CO2 monitoring of the air in the space,

at least 2 meters from the nearest person.

The other option would be for one Credit for a 50% increase in the

ventilation rate and a second Credit for an increase of 100% over the

ASHRAE 62 minimum recommended level. Words could also be added

to mention that one technique for demonstrating that these generous

ventilation rates were being achieved would be by the submit al of CO2

monitoring plots.

See response to IEQc2-Com1

See response to IEQc2-Com11

See response to IEQc2-Com11

IEQ

IEQc3-Com1

Issues with 2-

week flush out

Credit 3

(Construction

IAQ Management

Plan)

Again, there is a balance between providing good indoor air quality and energy

usage. Providing a minimum of two week building flush-out with 100% outside

air should not be done in certain climates because energy wil increase

significantly.

Perhaps there could be minimum and maximum limits on outdoor temperatures and humidity ranges?

-

The measurement based alternative to the

building flushout from LEED-NC wil be included

in the requirements as an option. The LEED-EB

Reference Guide wil also address issues to

consider in car y out the flushout including

filtrating, moisture and use of bar iers during

demolition and flushouts. This is a credit not a

prerequisite so some buildings may not be able

to earn this credit.

Make changes included in Response Column.

Alignment with LEED-NC

IEQ

IEQc3-Com2

Issues with 2-

week flush out

Credit 3

(Construction

IAQ Management

Plan)

Two weeks is too long, expensive. May not be feasible during hot or cold

weather.

Two days would be adequate(during seasonable weather).

-

See response to IEQc3-Com1

See response to IEQc3-Com1

See response to IEQc3-Com1

IEQ

IEQc3-Com3

Issues with 2-

week flush out

Credit 3

(Construction

IAQ Management

Plan)

Under the Requirements paragraph, "conduct a minimum 2 week building

flush out with new filtration media with 100% outside air. . " The USGBC

should consider restating 100% outside air to maximum outside air capable of

being delivered by building systems." This wil al ow for adequate flush out

without needing to bring fans to deliver 100% outside air. Also, it should be

noted that a problem occurs in commissioning buildings in humid climates

when the air conditioning system is used to dry out or "flush out" the building

prior to occupancy. The problem is created by using air conditioning control ed

by temperature. The compressors cycle of because there is no internal load in

the building and the fan keeps running, introducing untreated humid air into a

cold space. This humidity then condenses out on construction surfaces and

becomes part of the nutrients necessary for mold growth! I am concerned that

the USGBC flush out may cause IAQ problems if not properly described.

n/a

n/a

See response to IEQc3-Com1

See response to IEQc3-Com1

See response to IEQc3-Com1

IEQ

IEQc3-Com4

Issues with 2-

week flush out

Credit 3

(Construction

IAQ Management

Plan)

A 2-week flush out is rarely practical for operators of existing buildings who are

managing multiple smal remodeling, retrofit or restack construction projects

simultaneously under tight time schedules. This model does not fit the reality

of facility management and other acceptable alternative methods of proving

acceptable IAQ post-construction are available and practicable.

Include the option of sampling the air space for acceptable levels of common contaminants prior to

occupancy. Such as particulates, formaldehyde, etc.

Specific wording has been provided elsewhere to the Commit ee.

See response to IEQc3-Com1

See response to IEQc3-Com1

See response to IEQc3-Com1

IEQ

IEQc3-Com5

Issues with 2-

week flush out

Credit 3

(Construction

IAQ Management

Plan)

-

A two-week flush out is very long for an occupied building. Consider breaking IAQ Plan from flushout to

award credit for the first when the lat er is impossible. Also, consider the one-week flush out criteria

required by the New York State Green Building Tax Credit regulations as an alternative approach.

-

See response to IEQc3-Com1

See response to IEQc3-Com1

See response to IEQc3-Com1

IEQ

IEQc3-Com6

Issues with 2-

week flush out

Credit 3

(Construction

IAQ Management

Plan)

The requirement “conduct a two week building flush out” wil be dif icult for any

smal renovation project to comply with. Building owners with central air

handler or even packaged rooftop units supply air to more then one room wil

be reluctant to pursue this credit. How can they justify supplying 100% outdoor

air to an entire service area for one smal renovation project? The energy

penalty to heat or cool the air could be dramatic.

The wording for this credit needs to be revised to accommodate smal er renovation projects. Perhaps

adding the wording “whenever possible” would be appropriate for smal renovation projects in which the

air handler serves other areas/rooms in the building.

(see above)

See response to IEQc3-Com1

See response to IEQc3-Com1

See response to IEQc3-Com1

IEQ

IEQc3-Com7

Issues with 2-

week flush out

Credit 3

(Construction

IAQ Management

Plan)

IEQ3: I see lots of potential unfortunate fal out the last bul et point requiring a

flush-out. Cur ently writ en/constructed as “and” language, whereas in NC it’s

a separate credit with alternative “or” language. Keep working on it. War &

Peace submit al language, too.

See response to IEQc3-Com1

See response to IEQc3-Com1

See response to IEQc3-Com1

IEQ

IEQc3-Com8

Add physical or

pressure bar iers

language and/or

requirements

Credit 3

(Construction

IAQ Management

Plan)

Some excel ent ideas. I see only a couple of holes.

There is no mention of needed physical (visqueen) or pressure bar iers (control ed airflow rate and

direction) to prevent the migration of contaminants. Al return gril s cannot accept filters and air system

designs may not be able to handle the added pressure without an large energy penalty.

Requirements If air handlers must be used during construction,

filtration media with a Minimum Ef iciency Reporting Value of MERV 8

must be used in the return air duct, preferably at each return air gril ,

as determined by the most cur ent version of ASHRAE 52.2. Those

areas unable to support or justify return gril designs with filters should

have the return ducts thoroughly cleaned just prior to occupancy.

Potential Technologies & Strategies Specify containment control

strategies including protecting the HVAC system, control ing pol utant

sources, inter upting pathways for contamination, providing physical

and air pressure bar iers to restrict contaminant movement to occupied

areas, enforcing proper housekeeping and coordinating schedules to

minimize disruption. . .

See response to IEQc3-Com1

See response to IEQc3-Com1

See response to IEQc3-Com1

IEQ

IEQp3-Com4

CIH audited

report too time

consuming and

expensive

Credit 3

(Construction

IAQ Management

Plan)

1.) A formal CIH audited report can be time consuming and expensive

depending on the size of the organization's facility applying for certification. Is

their an acceptable alternative that would achieve the desired objective (spot

checking or let ers from a project's architect and general contractor stating that

no asbestos containing materials were used or specified on the project seeking

certification )?

See response to comment IEQp3-Com2.

See response to comment IEQp3-Com2.

See response to comment IEQp3-Com2.

IEQ

IEQc3-Com9

Add dust bar iers

as renovation

requirement

Credit 3

(Construction

IAQ Management

Plan)

good idea

Suggest adding a requirement for dust bar iers to be instal ed during demolition phase of a renovation

project in a partial y occupied building. This wil reduce migration of dust to occupied parts of the

building.

see item 2.

See response to IEQc3-Com1

See response to IEQc3-Com1

IEQ

IEQc4.1-Com1

Al ow low-

emit ing materials

Credit 4.1

(Documenting

Productivity

Impacts,

Absenteeism and

Healthcare Cost

Impacts)

No comment

No comment

I believe the low-emit ing materials should be included in LEED-EB and

low emit ing materials scoring should be the same for both LEED-EB

and NC; either 4 separate points or 1 point for al for portions.

Low emit ing materials are addressed in LEED-

EB MR Credits 3.1-3.2.

No Change

None

IEQ

IEQc4.1-Com2

Establish minimal

levels of

improvement /

record keeping

period too long

Credit 4.1

(Documenting

Productivity

Impacts,

Absenteeism and

Healthcare Cost

Impacts)

There is a requirement to track absenteeism and claims but nothing that

indicates some minimal level of improvement. Also the 12 months of records

may be hard to document and again the owner would wait 12 months before

potential certification.

Establish some minimal levels of improvement, say 10%.

None

The goal is to gather data on impact of

sustainable buildings on absenteeism. There is

no need to specify a level of improvement. See

Comment Gen-Com1 on period of performance

data needed for certification.

No Change

None

IEQ

IEQc4.1-Com3

Record keeping

period too long

Credit 4.1

(Documenting

Productivity

Impacts,

Absenteeism and

Healthcare Cost

Impacts)

-

To encourage broader use of this important credit, consider reducing requirement from 5 years of data

col ection to 1 year.

-

See response to IEQc4.1-Com2

See response to IEQc4.1-Com2

See response to IEQc4.1-Com2

IEQ

IEQc4.1-Com4

Credit not

feasible for non-

owner occupied

facility / record

keeping period

too long

Credit 4.1

(Documenting

Productivity

Impacts,

Absenteeism and

Healthcare Cost

Impacts)

This documentation may not be available in multi-tenant non-owner occupied

buildings. Also, 5 years of records in unnecessary and too long of a historical

period. Two years should be adequate.

n/a

n/a

See Comment Gen-Com1 on period of

performance data needed for certification. This

is workable for owner occupied and single

tenant buildings. LEED-EB cur ently primarily

targets owner occupied and single tenant

buildings so this is appropriate. In the future, an

application guide for using LEED-EB in multi-

tenant buildings wil be developed - when this

happens, the issue how to apply this credit in

that circumstance wil be addressed. This is a

credit not a prerequisite so it can have bigger

stretch goals than would be appropriate for a

No Change

None

IEQ

IEQc4.1-Com5

Credit not

feasible for non-

owner occupied

facility

Credit 4.1

(Documenting

Productivity

Impacts,

Absenteeism and

Healthcare Cost

Impacts)

You almost have to have an owner occupied facility to do this credit. It would

require personnel information for the data. Maybe it would be available for

tenant spaces but doubtful and would be hard to obtain. The data is needed

for future planning and understanding of performance as it is related to a

buildings performance.

no comments

No comments

See response to IEQc4.1-Com4

See response to IEQc4.1-Com4

See response to IEQc4.1-Com4

IEQ

IEQc4.1-Com6

Credit not

feasible,

restructure or

exclude

Credit 4.1

(Documenting

Productivity

Impacts,

Absenteeism and

Healthcare Cost

Impacts)

This credit requires the owners/representatives to track healthcare costs which

are going to be dif icult for some facilities to provide. Every health care plan is

dif erent. Some plans wil include spouses and children who do not work in the

facility. Every insurance company and human resources department wil dif er

in how the information is presented. Then there are facilities with multi-tenancy.

How is a building owner going to provide information regarding numerous

tenants? While we respect the intent of this credit we feel that few facilities wil

try to pursue it. This credit needs to be restructured or removed from LEED-EB.

While we respect the intent of this credit we feel that few facilities wil try to pursue it. This credit needs to

be restructured or removed from LEED-EB.

(see above)

See response to IEQc4.1-Com4. Absenteeism

and health care costs are already being tracked

for most building occupants for other reasons.

This credit creates an incentive to draw out this

information so it is available for use in evaluating

sustainability impacts. Yes there wil be

variations in the data col ected but as the size of

the data set grows it wil be possible to make

statistical comparisons between buildings with

ongoing sustainability performance ratings

under LEED-EB and buildings that are operated

in the conventional way.

No Change

None

IEQ

IEQc4.1-Com7

Credit not

feasible, exclude

Credit 4.1

(Documenting

Productivity

Impacts,

Absenteeism and

Healthcare Cost

Impacts)

It wil be nearly impossible to relate absenteeism and health costs to building

performance.

Not feasible.

Exclude.

See response to IEQc4.1-Com6.

See response to IEQc4.1-Com6

See response to IEQc4.1-Com6

IEQ

IEQc4.1-Com8

Clarification

needed

Credit 4.1

(Documenting

Productivity

Impacts,

Absenteeism and

Healthcare Cost

Impacts)

IEQ4.1: Good concept in need of much more work. In 4.1, given the huge cost

forces at work in the insurance industry, it’s hard to imagine a reduction in

premiums resulting from actions taken at an individual building or even

company level, as opposed to a reduction in growth of premiums. May need to

innovate until 3.0 unless you put a much finer point on it.

A reduction in health care expenditures from

what they would other wise have been counts

as a reduction. See response to IEQc4.1-Com6

See response to IEQc4.1-Com6

See response to IEQc4.1-Com6

IEQ

IEQc4.2-Com1

Include self-

assessed

productivity as a

metric for

knowledge

workers and

other commercial

building

occupants.

Credit 4.2

(Documenting

Productivity

Impacts, Other

Impacts)

It is good to include measures of productivity other than absenteeism and

healthcare cost impacts, as addressed in IEQ credit 4.1. However, why are the

other measures for productivity limited to ‘amount of work done’ and ‘amount of

er ors made’? These measures are valid only for certain job tasks and are not

useful for evaluating knowledge work.

We propose that self-assessed productivity be included as a metric for knowledge workers and other

commercial building occupants. A perceived productivity scale was ef ectively used in the large UK Probe

study of energy-conserving buildings (Leaman A. and Bordass W., Productivity in Buildings: the kil er

variables, Workplace Comfort Forum, London, 1997, October 29-30). The CBE core occupant survey

could be used as a consistent method of measuring occupant satisfaction and self-assessed productivity

by addressing factors that directly af ect IEQ such as Thermal comfort, Air quality, Lighting, Acoustics,

and Cleanliness (please see www.cbesurvey.org). Productivity impacts over a period of sustainable

building improvement can be traced by the self-assessed scores in the survey, which are easy to acquire

and document.

We propose that the language be changed like this: Requirements:

Document other productivity impacts of sustainable building

performance improvements for building occupants by doing (where

applicable) objective measurements of productivity impacts such as

amount of work done and amount of er ors made, or subjective

measurements such as occupant IEQ satisfaction surveys, in which self-

assessed productivity is related to associated IEQ factors in the

workplace.

Change second half of last sentence in

requirements section to: "and track changes in

the impact on the amount of work done, the

amount of er ors made or other productivity

impacts for building occupants over the

performance period relative to sustainable

building performance improvements." Also self

assessment surveys wil be suggested in the

LEED-EB Reference Guide as one possible

approach.

Make changes included in the Response Column Clarification

IEQ

IEQc4.2-Com2

Record keeping

period too long

Credit 4.2

(Documenting

Productivity

Impacts, Other

Impacts)

To encourage broader use of this important credit, consider reducing requirement from 5 years of data

col ection to 1 year.

-

See Comment Gen-Com1 on period of

performance data needed for certification.

See Comment Gen-Com1 on period of

performance data needed for certification.

See Comment Gen-Com1 on period of

performance data needed for certification.

IEQ

IEQc4.2-Com3

Clarification

needed

Credit 4.2

(Documenting

Productivity

Impacts, Other

Impacts)

Comment: In order to get a good set of consistent data that wil truly help the

U.S. Green Building Council study and document the benefits of sustainable

building practices through the use of LEED certification, consider the fol owing:

- Measures of productivity wil vary for dif erent market segments. Consider

rol ing this credit, with the addition of more specific guidelines regarding the

measurement of productivity, into the application guides as they are

developed. For example, productivity in healthcare can include a reduction in

medical er ors by type. Education can report on test scores, etc.

- If this credit remains in LEED EB, consider developing additional guidelines

for clarification – OR - encourage this documentation request as an Innovation

credit and let each team define “productivity” for their business type.

See response to IEQc4.1-Com6. See response

to Comment IEQc4.2-Com1,

See response to IEQc4.1-Com6. See response to

Comment IEQc4.2-Com1,

See response to IEQc4.1-Com6. See response to

Comment IEQc4.2-Com1,

IEQ

IEQc4.2-Com4

Credit not

feasible, exclude

Credit 4.2

(Documenting

Productivity

Impacts, Other

Impacts)

Same as 4.1 (See IEQc4.1-Com7)

Same as 4.1 (See IEQc4.1-Com7)

-

See response to IEQc4.1-Com6 .

See response to IEQc4.1-Com6.

See response to IEQc4.1-Com6.

IEQ

IEQc5.1-Com1

Quarterly records

are excessive.

Credit 5.1 (Green

Cleaning,

Entryway

Systems)

Quarterly records are excessive.

Go to annual documentation.

-

See response to Comment Gen-Com3 on

quarterly reporting.

See response to Comment Gen-Com3 on

quarterly reporting.

See response to Comment Gen-Com3 on

quarterly reporting.

IEQ

IEQc5.2-Com1

Specify a specific

negative

pressure in the

requirements

section

Credit 5.2 (Green

Cleaning,

Isolation of

Chemical Mixing

& Storage )

Air and pol ution flows in rooms with major indoor sources of pol ution is an

important aspect of IEQ.

This credit could be improved by specifying a specific negative pressure in the requirements section

rather than the general language now used that there needs to be negative pressure. In our judgment

something like specifying a negative pressure relative to the sur ounding space of 7 Pa (0.028 w.g.)

would be appropriate. Additional y, the pol utant source should be between the exhaust outlet and the

occupant. For your information, the Indoor Environments Division at the Environmental Protection Agency

has been developing green building guidance as it relates to Indoor Environmental Quality, “Indoor

Environmental Quality Guidance for Green, High Performance, and Sustainable Buildings.” The purpose

of this guidance is to establish robust and comprehensive criteria that would serve as the foundation for

the development of requirements for federal buildings, and help inform other green building entities. The

guidance covers both new building construction, and existing buildings. An internal review of this

guidance has just begun. We wil send our internal review draft for your consideration to the EB

In the requirements section specify a specific negative pressure (such

as the example above) and add language similar to the fol owing: "the

pol utant source should be between the exhaust outlet and the

occupant."

The LEED-EB commit ee looks forward to

receiving the review draft of your new document.