In November 2010, the USGBC issued a LEED Rating System Draft scheduled to go into effect in 2012. 

In November 2010, the USGBC issued a LEED Rating System Draft scheduled to go into effect in 2012. This is a major overhaul of LEED rating systems for New Construction and Major Renovations, Core and Shell, Schools, Retail, Data Centers, Warehouse and Distribution Centers and Hospitality. Several credits remain largely unaltered but there are some significant changes proposed, including some new credits, which warrant this draft version a must read for anyone involved with LEED. Although you may have missed the first deadline for public comment (at the time of this writing January 14), there is still plenty of time to get your thoughts organized and comments submitted; a second round is scheduled to occur sometime in June.

To more fully engage the public in the process, the USGBC has teamed up with in establishing a forum for public comment. LEEDuser, in its opening statement on the forum’s Web page, promises to “submit all comments on the new LEED draft as public comments, on your behalf.”

One advantage in using the LEEDuser forum is that USGBC employees administering the 2012 draft are monitoring the forum and occasionally respond to commenters’ posts. This is a major departure from the ultra-complicated, “black box” comment procedures employed by the USGBC in the past and offers commenters a rare opportunity for open dialogue with the rating system administrators, in real time. While not all comments receive attention, the responses that have been posted are encouraging and valuable. Below is one that I found particularly helpful from Chrissy Macken, associate, LEED Technical Development in response to a general question about what credits are fair game for comments:

“Every credit and prerequisite that is new or has been modified in some way (including deletion) is open for comment. All aspects of those credits are open for comment, including the referenced standards. We are trying to evolve LEED in a way that moves toward more absolute performance metrics wherever possible - giving project teams the performance goal to reach without dictating how projects get there. If you have information that can show us additional standards that will move the LEED requirements toward more absolute performance metrics, we would encourage you to proivde us with that information.”

So, let’s get to some of the significant changes being proposed!

Farewell LEED AP Legacy?

Currently, a single rating system point is available if a LEED Accredited Professional is involved at some point in the project’s design and construction. This can be anyone (owner, architect, contractor, etc.) with any type of LEED AP credential. The proposed credit devalues LEED AP Legacy holders, barring the credential from being used to satisfy the credit requirements, and instead requires three LEED APs be certified under the new GBCI-run accreditation exams. Lots of people are going to have plenty to say about this, and will regard this as an overt move by the USGBC to make more money by requiring LEED Legacy AP holders to pay for another exam. I know of no other professional registration body that invalidates registrations in the way this proposed change will effectively do to LEED Legacy APs. At the time of this writing, more than half of the comments posted on the LEEDuser forum have to do with this proposed change. 

Points for Bike Racks

LEED has taken a pretty good beating on this one, the perception being that points are awarded by the simple act of installing a bike rack on the building site. Detractors of the LEED rating system have brought this up over and again as proof of how out of whack the rating system is in rewarding points equally for this as, for example, installing an energy producing PV solar array on the roof. Never mind that this is a gross misrepresentation of the actual rating system requirements! LEED 2012 proposes no points for installing bike racks. Instead, bike racks have become a prerequisite, in an amount meeting a minimum percentage of the building’s occupants (2.5 percent of all building users in most cases as currently written). 

Recycled Content

In a previous article I wrote about the relative ease in which a steel framed building would be awarded LEED recycled content points considering only materials made of steel used in the calculation. A minimum amount of recycled content material equal to the first credit threshold is a now being proposed as a prerequisite. For points to be awarded above and beyond the prerequisite threshold, only “non-structural” materials will be allowed to contribute.

This change will have little impact on teams for proposed prerequisite, since nearly all LEED certified buildings easily achieve the first recycled content point threshold. The change will have a profound effect on a team’s ability to get any points, however, in removing structural materials from the calculation. Non-structural materials are not defined in the proposed rating system but it seems likely that “structural” materials will include concrete aggregate, steel reinforcement in concrete, cold-formed metal framing, steel beams and columns, and steel decks. Removing these materials from the calculation will put pressure on design teams to focus on non-structural materials like interior finishes, gypsum board, ceiling panels, and non-structural metal framing.

Bio-Based Materials

The former rapidly renewable credit has been replaced with a Bio-Based Materials credit that allows any renewable material, defined by the Farm Security and Rural Investment Act of 2002, to count toward achievement. This includes wood-non-FSC certified wood. This is sure to stick in the craw of FSC supporters, especially since the membership failed to adopt a recent proposed change to the FSC Certified Wood credit by allowing non-FSC certified wood to contribute. The credit proposes that only non-structural bio-based materials count toward the credit. For wood-framed projects, this will be a hard pill to swallow; trusses, beams, columns, laminated timber, and structural wood sheathings will all be excluded from the calculation as proposed.

Low-Emitting Interiors

This new credit lumps all of the former low-emitting materials credits (paints and coatings, sealants, adhesives, carpet systems, and furniture) into a single, spreadsheet-like format. In addition to the previous LEED low-emitting materials, built-in casework and architectural woodwork, thermal insulation, and acoustic insulation have been added to the list. Points are awarded for a percentage of these materials that are tested in accordance with the California Department of Public Health Method V1.1-2010.

The big deal about this credit, in the way it is currently presented, is that fractions of points from different material categories can be combined with one another to make full points. The current rating system is an all or nothing approach-if one product or material is less than the required allowable emission threshold, all is lost. This is one of the best ways to kill incentive to pursue a credit. The proposed credit will hopefully pave the way for this revision to be made to all other credits, eliminating the arbitrary thresholds and incentivize teams to pursue as much of every credit possible, and be rewarded for the effort.


The proposed changes to the LEED rating system are generally good, and generally moving in the right direction. LEED 2012 in its first draft is unrefined and loosely written. This is a good thing, I think, because it provides an opportunity for public comments to better shape the rating system into a highly refined, well-crafted document. And it couldn’t be easier to do so with the establishment of the LEEDuser forum. I will be submitting my comments soon and I encourage you to do the same.