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

Informations

• Publié par: Nofog
• Nombre de lectures: 13
• 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

Response

Proposed Changes to

LEED-EB for Second

Comment Draft

Type of Change

ID

IDc1.1-1.4-

Com1

Give credit for

building operations

staf involvement

Credit 1.1-1.4

(Innovation in

Operation &

Upgrades)

Too many "sustainability" teams do not involve the actual managers and staf who wil be

operating the buildings. This is more of a problem with new building construction, but

should also be addressed for existing building sustainability credits. Without operations

staf involvement in the evaluation to make a building more sustainable and their

"ownership" of the decisions, the sustainability achievements wil not be as great as they

could had been. My recommendation is to include a credit for having a process to give the

actual people managing and operating the building systems significant involvement in the

sustainability evaluation.

Buildings and other systems only work as wel as the staf operate

them. Having ownership by operations staf is crucial for success

of any process, including building systems. Give credits for

meaningful involvement of the building operations staf in the

sustainability evaluation.

The consultant facilitating the sustainability evaluation

wil provide information to building owners, managers,

and operations staf , but the decisions for the buildings

wil be made by the owner and their staf . Building

operations staf wil be given a significant voice in the

sustainability evaluation.

The LEED-EB Reference Guide wil provide information the

need for a team approach that includes active involvement of

building staf .

No Changes

None

ID

IDc1.1-1.4-

Com2

Expand IOU credit

options

Credit 1.1-1.4

(Innovation in

Operation &

Upgrades)

The draft does not mention other topics like safety for the occupants or fire safety

products or systems; nor security systems; nor productivity increase due to products.

The rating systems should use and diverse group to develop/

suggest other topics that lead to "sustainability" in a more holistic

view.

See above.

Fire safety systems are not addressed because they are

covered by code.

No Changes

None

ID

IDc1.1-1.4-

Com3

Recertification

poorly scaled for

energy IOU points

Credit 1.1-1.4

(Innovation in

Operation &

Upgrades)

I was told I could not receive my energy related innovation points if I did not show I

increased my Energy Star rating by 3 points for each. My energy star rating is 96, how can

I get it to 105. When I resubmit, if I do not get these points, they were very out of the box

innovations, you can count me out of any further involvement with this process.

You can see I'm quite angry regarding this. I see so many other

properties get ing points for innovations that are not even close to

ours, but I feel we are being punished for being so green and

someone does not want us to achieve platinum.

NA

The 10 points are included for energy savings regards the

energy benefits of al actions that increase energy ef iciency.

Actions can be recognized as wel as for increased

environmental benefits.

No Changes

None

ID

IDc1.1-1.4-

Com4

Include credit for

ful -scale product

life-cycle

assessment

Credit 1.1-1.4

(Innovation in

Operation &

Upgrades)

We understand that the EB Commit ee recommended giving an innovation credit for the

use of products that had a publicly disclosed Life Cycle Assessment (LCA). More

specifical y, we understand that the commit ee proposed several additional innovation

credits for building owners who used materials with publicly disclosed LCAs for portions

of their purchases in a category and overal above some percentage threshold. This

would generate tremendous benefits driving materials producers to reduce the

environmental impacts of their products from raw materials to end-of-life. The road to

having LCA wel -integrated into LEED and the green building process is long, but this is a

necessary first step.

Please reinstate the innovation credits for LCA, which were

apparently in the earlier drafts of the EB Standard.

We have not seen the specific language for innovation

credits for using materials with publicly-disclosed LCAs

that was in previous drafts of the EB Standard, but that

is presumably available for inclusion in the final version.

We have also been told that this language has been

moved to the Reference Guide for the EB Standard, but

this document is not part of the standard itself. As such,

we have no opportunity to comment on its existence or

the actual language used.

This is being addressed by the USGBC for al LEED Products. No Changes

None

ID

IDc1.1-1.4-

Com5

Include credit for

ful -scale product

life-cycle

assessment

Credit 1.1-1.4

(Innovation in

Operation &

Upgrades)

The current credits do not encourage building professionals to look holistical y at

products and consider their environmental impacts from raw materials sourcing through

product disposal. This approach could be encouraged by adding credits for any ISO

14040 compliant ful life-cycle assessment or streamlined life cycle assessment used to

select a product.

Innovation credits for the use of a ful -scale LCA or streamlined

LCA for selection of a product are the most ef ective way of adding

to the LEED system a means of measuring the environmental

impacts of products using a widely respected scientific

methodology. Therefore, the International Design Center for the

Environment supports LEED EB. In particular, IDCE supports

LEED EB LCA Based Credit Intents for inclusion in the Reference

Guide for (1) ISO Compliant LCA for cleaning products, (2) ISO

Compliant LCA for any products, (3) MTS Consensus Sustainable

Textile or equivalent for carpet & fabric. Further, IDCE supports a

fourth credit intent for streamlined LCA, based on a

recommendation from the SETAC North American Streamlined

LCA Workgroup, that “Over time, there has been growing

recognition that “ful -scale” LCA and “streamlined” LCA are not

two separate approaches but rather are points on a continuum.”

IDCE recommends the fol owing language be included

in the LEED EB Reference Guide for Intent #4: “LEED-

EB encourages the use streamlined LCA tools which

are ISO 14,040 compliant and incorporate economic

al ocation. An Innovation credit is to be al owed for the

selection of a product using a streamlined LCA,

documenting that product’s “key at ributes” from cradle-

to-disposition. Key at ributes are defined as those life-

cycle stages that drive the majority of the environmental

impacts for a product throughout its ful life cycle.

See response to IDc1.1-1.4-Com4

See response to IDc1.1-1.4-

Com4

See response to IDc1.1-

1.4-Com4

ID

IDc1.1-1.4-

Com6

Include credit for

ful -scale product

life-cycle

assessment

Credit 1.1-1.4

(Innovation in

Operation &

Upgrades)

Wasn’t there, at one time, a credit for the use of products with ful y disclosed Life Cycle

Assessment (LCA) data? This type of credit would provide leadership in the inclusion of

LCA in the rating system. LEED addresses the life cycle of the building –addressing the

life cycle of its components should be equal y important.

Add a credit for the use of products with ful y disclosed Life Cycle

Assessment (LCA) data

None

See response to IDc1.1-1.4-Com4

See response to IDc1.1-1.4-

Com4

See response to IDc1.1-

1.4-Com4

ID

IDc1.1-1.4-

Com7

Car Sharing

Credit 1.1-1.4

(Innovation in

Operation &

Upgrades)

There needs to be an innovative credit (or additional credit under Alternative

Transportation) for car sharing. Shared cars are a means to provide transportation choice

while lessening the impacts of pol ution and land development from single occupancy

vehicles.

Car sharing companies estimate that each shared car replaces as

many as 6 automobiles. However, car sharing programs require

highly visible and easily accessible parking spots. In order to take

credit, building owners must provide the “infrastructure” for car

sharing programs to boost success, and the resulting

environmental benefits of these programs. In addition, car-poolers

could have an additional option if a shared car is available on site.

Al ow a credit for a developer who supplies a highly

visible, easily accessible parking space and/or an

incentive program.

Future revisions of LEED-EB wil consider addition of car

sharing programs for transportation impact reduction.

No Changes

None

ID

IDc2-Com1

Al ow credit for

Sustainability

continuing

education

Credit 2 (LEED-EB

Accredited

Professional)

Satisfactory

Somewhere there needs to be a means for continuing education

on the process of Sustainability like it is done for the AIA and PE

societies.

In the submit als add some wording to show the LEED

AP has a current accreditation and has maintained this

accreditation through at ending Chapter Meetings,

Short Courses, and Seminars in order to keep current

The USGBC provided education programs on LEED products

s an accreditation programs for professions. In the future the

accreditation programs for LEED professionals may include a

continuing education component for retaining accreditation.

No Changes

None

ID

ID-c2-Com3

Integrate LEED-EB

into LEED

accreditation exam

Credit 2 (LEED-EB

Accredited

Professional)

Comment: While it is completely appropriate to require the LEED accredited

professional to have LEED EB training in order for the project to be granted this credit, a

separate accreditation exam for LEED EB may not be the best path forward.

- The new version of the LEED accreditation exam could incorporate the common and

key elements of the total LEED rating system. Documentation of a ful day LEED EB

training should suf ice to show familiarity with the LEED EB program.

- Separate exams wil be both costly for the U.S. Green Building Council to

develop/administer and for professionals to take. There may be resistance to multiple

fees and exams that may drive project teams away from pursuing LEED certification.

- Integration is a major focus of sustainable building practices, and it should be the same

for LEED accreditation. Al LEED accredited professionals should have basic knowledge

of the interrelationships of the LEED products.

- A LEED NC building wil eventual y turn to LEED EB for re-certification. The initial

project team should be wel versed in both systems. Consider LEED EB training as a requ

Okay to require the LEED accredited professional to have LEED

EB training in order for the project to be granted this credit but

integrate LEED EB into a new version of the LEED accreditation

exam that incorporates the common and key elements of the total

LEED rating system.

No decision has been made yet on the issue of separate or

combined accreditation for the various LEED products. See

response to IDc1.1-1.4-Com4 on LCA.

No Changes

None