LEED 2.2 Public Comment Submission
Deadline - February 1, 2005
Preparing to submit comments to the US Green Building Council for
LEED-NC version 2.2
USGBC is accepting public comments on LEED-NC 2.2 through an on-line process
.The process of submitting comments will take approximately 1 hour. However, a user
name and password is required to make your submission and it generally requires a
day to receive a password back from them.
This document contains instructions, text copied from the USGBC submission forms and
text to be cut and pasted into the submission forms.
Text from the submission form is in bold, green Ariel text.
Important instructions are in bold, red Ariel text.
For ease of use, the text to be inserted into the submission forms will be in bold, black
Times Roman font.
HOW TO GET A USGBC USER NAME & PASSWORD
o
Go to the US Green Building web site: www.usgbc.org
o
Under News, click on : LEED-NC v2.2 Public Comment Period Open
o
Go to the last sentence on this page:
If you would like to participate in this comment period, click here for more
information.
o
Go to the last sentence on this page:
LEED-NC version 2.2 (Open 12/3/04 – 2/1/05) Submit Comments
o
Create User Account from the Login page. If you want to logon as a member,
you can include your corporate ID number in the online form you complete for a
username. (You will need your corporate ID if you are not the primary contact for
your organization with USGBC. If you do not know your corporate ID you can
email USGBC at leedinfo@usgbc.org and they can tell you; it takes a day or
longer.) However, you do not need to be a member and you do not need a
corporate ID to submit comments.
o
Activation may take one day.
LEED NC v2.2
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LEED NC v2.2
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January 17, 2005
HOW TO SUBMIT COMMENTS
o
Go to the US Green Building web site: www.usgbc.org & navigate to the
login screen.
o
Or go directly to the Login screen:
https://www.usgbc.org/login.asp?REFERRER=https%3A%2F%2Fwww%2Eusgb
c%2Eorg%2FLEED%2FDrafts%2Fdrafts%5Fleed%5Fsystem%2Easp&SYSTEM
_ID=7
o Submission Deadline: 5 p.m. PST, Feb. 1, 2005. Late comments are not
accepted.
o Click on a  Category to see each list of Credits
o Click on  Make Comments to open the comment screen for a Credit
Cut the applicable content from this document, and paste into the online form.
Three boxes are provided where you can submit comments answering the three
specific questions for which we have provided answers. Use each box provided
for your response. You may cut and paste the text from this from or you
may use your own wording.
o
When you are finished – check for accuracy (you cannot change later!)
o
Click SUBMIT
o
Repeat process for the next Credit
The following are copies of sample screen shots you will see when submitting
comments.
Thank you for your diligence in this process, and working with our industry
to facilitate change.
LEED NC v2.2
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January 17, 2005
LEED NC v2.2
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LEED NC v2.2
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LEED NC-V2.2 CHANGES RELATED TO CONCRETE, MASONRY,
AND RELATED INDUSTRIES
SCOPE
The scope of version 2.2 is to revise existing credits within the current category structure
(no addition or removal of credits is permitted in this version). The intent of version 2.2 is
to incorporate credit interpretation rulings, fix credits, take out credits without
environmental value, and improve clarity. Some credits have increased stringency
consistent with USGBC’s intent of market transformation.
If changes are made to the draft after this first comment period, a second, 15-day public
comment period will be held for any changes made. The resulting draft will go before the
USGBC membership for balloting. The official public release of the rating system is
expected by fall 2005.
COMMENTS ON CONCRETE-RELATED CREDITS WITHIN LEED-NC V2.2
The following is a list of concrete-related credits within LEED where LEED-NC version
2.2 has a significant effect on concrete and related industries compared to version 2.1.
WE RECOMMEND SUBMITTING COMMENTS FOR THESE CREDITS:
Sustainable Sites
SS Credit 6.1 Stormwater Design – Volume/Treatment
SS Credit 6.2 Stormwater Design – Channel Protection / Flood Control
SS Credit 7.1 Heat Island Effect: Non-Roof
Materials and Resources
MR Credit 4.1 Recycled Content – 10% (post-consumer + ½ pre-consumer)
MR Credit 4.2 Recycled Content – 20% (post-consumer + ½ pre -consumer)
Indoor Environmental Quality
IEQ Credit 4.2 Paints and Coating
IEQ Credit 4.3 Low Emitting Materials
General Comment
MR Credit 8 Durable Building
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SS Credit 6.1 Stormwater Design – Volume/Treatment
The method of calculating compliance has changed but the strategy still suggests
permeable paving. However, their language now calls this product “permeable pavers.”
Previously the term used was “pervious paving.” We recommend they use the language
“pervious pavement or grid pavers.” This is a clarifying comment rather than a comment
in requirements.
We recommend this wording as a comment:
1. Please provide a brief description of the strengths or weaknesses of this
prerequisite or credit and why this is important to the environmental
performance of a project:
This requirement provides benefits to a project by reducing stormwater runoff.
2. Please provide a brief description of how this prerequisite or credit could be
improved and why this is important to the environmental performance of a
project:
We recommend the use of the phrase “pervious pavement or grid pavers”
instead of “permeable pavers.” Pavers are discrete, relatively small products
that are set side by side to form a pavement. This requirement can also be met
using pervious pavement, which is placed in large sections and allows water
infiltration.
3. Please provide specific language changes you would suggest for the intent or
requirements of this prerequisite or credit and how it relates to the
environmental performance of a project:
Change the first sentence under “Potential Technologies and Strategies” to read:
Use alternative surfaces (e.g., green roofs, pervious pavement, or grid pavers)…
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January 17, 2005
SS Credit 6.2 Stormwater Design – Channel Protection / Flood Control
Our comment is similar to the one for SS Credit 6.1. The method of calculating
compliance has changed but the strategy still suggests permeable paving. However,
their language now calls this product “permeable pavers.” We recommend they use the
language “pervious pavement or grid pavers.” This is a clarifying comment rather than a
comment in requirements.
We recommend this wording as a comment:
1. Please provide a brief description of the strengths or weaknesses of this prerequisite
or credit and why this is important to the environmental performance of a project:
This requirement provides benefits to a project by reducing stormwater runoff.
2. Please provide a brief description of how this prerequisite or credit could be improved
and why this is important to the environmental performance of a project:
We recommend the use of the phrase “pervious pavement or grid pavers”
instead of “permeable pavers.” Pavers are discrete, relatively small products
that are set side by side to form a pavement. This requirement can also be met
using pervious pavement, which is placed in large sections and allows water
infiltration.
3. Please provide specific language changes you would suggest for the intent or
requirements of this prerequisite or credit and how it relates to the environmental
performance of a project:
Change the first sentence under “Potential Technologies and Strategies” to read:
Use alternative surfaces (e.g., green roofs, pervious pavement, or grid pavers)…
LEED NC v2.2
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January 17, 2005
SS Credit 7.1 Heat Island Effect: Non-Roof
This credit has many changes and we recommend comments on the first three noted
below. Lionel Lemay of NRMCA has prepared proposed comments noted below. If you
have additional questions, he can be reached at llemay@nrmca.org or by phone: at 847918-7101).
The major changes are:
1. It now requires a field test that requires a large surface area, a sunny day, and
high sun angle. Previously an inexpensive laboratory test was sufficient.
2. It now requires measurement of emittance or reference to a non-existing table.
Emittance of opaque, nonmetallic surfaces is relatively constant and the
requirement for a test is unduly burdensome. Typical values cited in the literature
for concrete are 0.88 or 0.90.
3. It now requires the calculation of Solar Reflectance Index rather than reflectance
values. This is more burdensome but probably more accurate because it takes
into account reflectance as well as emittance.
4. It now requires 50% rather than 30% of the surfaces meet the high albedo
requirement. USGBC is looking for ways to raise the bar on credits to continue to
lead market transformation. (We are NOT commenting on this.)
We recommend this wording as a comment:
1. Please provide a brief description of the strengths or weaknesses of this prerequisite
or credit and why this is important to the environmental performance of the project.
This credit is important to the environmental performance of a project since it
attempts to reduce the temperature increases caused by the use of dark colored
(low reflectivity) pavements. Research shows that using high albedo pavements
can reduce temperatures in urban and sub-urban areas thus reducing the effect
of development on human and wildlife habitat. This credit provides incentive for
designers and owners to minimize the environmental impact of pavements by
providing several options for achieving the intent of the credit. A weakness is the
proposed wording, which adds unnecessary and undue burden to obtaining this
point using concrete pavement.
2. Please provide a brief description of how this prerequisite or credit could be improved
and why this is important to the environmental performance of a project.
1 Suggested Change: Requirements, first sentence should read: Provide shade
within 5 years of pavement installation...
Reason: As currently written the building owner could wait months or years
before installing shade trees and still meet the requirements of the credit which
is not the intent.
2 Suggested Change: Submittals, bullet point 1 should read: The SRI shall be
selected from table 1 or calculated in accordance with ASTM E1980-01.
Reason: The reference to ASTM E1989-98 is incorrect. This standard has
nothing to do with calculating SRI. In addition, for the purposes of calculating
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SRI, the values in table 1 are sufficient since the values were obtained from a
sufficiently large sample and are consistent with published values.
3 Suggested Change: Submittals, bullet point 2 should read: Solar Reflectance
values used to calculate SRI shall be based on Table 1 (below) or laboratory
measurements using ASTM C1549-04. Samples shall be made from materials
representative of those used for the actual pavement and made at time of
construction or in advance of construction. Similarly, bullet point 3 should read:
Emissivity values used to calculate SRI shall be based on Table 1 (below) or
laboratory measurements using ASTM E408-71. Samples shall be made from
materials representative of those used for the actual pavement and made at time
of construction or in advance of construction.
Reason: ASTM E1918-97 is not a practical solution for this application. The test
method requires a 10-meter square section of unshaded pavement (Section 7.1 of
the standard) for every project and the test can only be conducted when the sun
is shining (no clouds or haze) and the sun is 45 degrees or less from normal. This
means the test can only be conducted between 9 am and 3 pm in the summertime
on a clear day (Sections 9.2 and 9.3 of the standard). In northern regions it
cannot be conducted during the winter, spring, or fall seasons. In addition, there
are only few labs in the U.S. that can conduct the ASTM E1918 test. The cost of
conducting the test could run between $1,500 and $1,800 for a local test to
upwards of $5,000 when travel by lab technicians is required (which is likely).
There aren’t many labs that conduct ASTM C1549 or E408 either but you can
ship samples to the lab for testing. ASTM C1549 can be done in a lab for $75$150 (plus shipping of the samples). ASTM C1549 provides good results for solar
reflectivity so there is no reason to require expensive field testing. A similar
argument can be made for ASTM E408 in that laboratory tests are more
practical and cost effective. Furthermore, the emissivity of all opaque, nonspecular, non-metallic surfaces ranges from 0.88 to 0.90 with little variation.
Testing for emissivity of concrete should not be required since test methods will
have more variation than the value itself. For the purposes of this credit, Table 1
values are sufficient for calculating SRI. However, if someone wants to use tests
to determine solar reflectance and emissivity for other pavement surfaces then
ASTM C1549 and E408 laboratory tests are sufficient.
4 Suggested Change: Table 1 is missing and should be included. Based on
earlier versions of Table 1, I suggest the following changes: List values for Initial
Solar Reflectance for Ordinary (Gray or Buff) Portland Cement Concrete and
White Portland Cement Concrete from American Concrete Pavement
Association, “Concrete Pavement Research & Technology Update” Number 3.05
June 2002 listed in the footnote. This reference lists Solar Reflectance (new) for
Grey Portland Cement Concrete as 0.35 – 0.40 and for White Portland Cement
Concrete as 0.70 – 0.80. These values were obtained from a significant sample
size of different concrete mix designs and should be sufficient for purposes of
this calculation. Also note that a ruling on June 27, 2003 stated in part, “Include
reflectance documentation from the American Concrete Paving Association,
making sure to indicate the original source of the research data and the
reflectivity category that relates to your concrete mix…and it is acceptable to use
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the reflectivity rate for new concrete on this credit…” In Table 1, list 0.35 for
ordinary concrete and 0.70 for white portland cement concrete since these values
are conservative. Listing one value will avoid ambiguity for users. In addition,
eliminate the columns for 3-year Solar Reflectance and 3-year Solar Reflectance
Index (SRI).
Reason: Three-year solar reflectance need not be listed since these values are not
relevant to the submittal calculation.
3. Please provide specific language changes you would suggest for the intent or
requirements of this prerequisite or credit and how it relates to the environmental
performance of a project.
SS Credit 7.1: Heat Island Effect – Non-Roof
1 Point
Submittals
Provide the LEED-NC Letter Template, signed by the civil engineer or
responsible party, referencing the site plan to demonstrate areas of hardscape
(including paving, walkways, plazas, fire lanes, etc.), landscaping (list species)
and building footprint, and declaring that:
•
A least 50% of the site’s hardscape has an SRI of a least 29 and/or at least
50% of the hardscape is comprised of open grid pavement and/or at least
50% of the hardscape will be shaded with trees within five years of
hardscape installation.
o The SRI shall be based on Table 1 (below) or calculated in accordance
with ASTM E1980-01.
o Solar reflectance values used to calculate SRI are based on Table 1
(below) or laboratory measurements using ASTM C1549-04. Samples
shall be made from materials representative of those used for the actual
pavement and made at time of construction or in advance of construction.
o Emissivity values used to calculate SRI are based on Table 1 (below) or
laboratory measurements using ASTM E408-71. Samples shall be made
from materials representative of those used for the actual pavement made
at time of construction or in advance of construction.
LEED NC v2.2
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Table 1
Material
January 17, 2005
Solar Reflectance
Emissivity
Solar Reflectance Index
Asphalt Paving
0.05
0.9
8.7
Chip-Seal (w 0.28
albedo aggregate a)
0.28 a
0.9
29
Gray Portland
Cement Concrete
0.35 b
0.88
37
White Portland
Cement Concrete
0.7 b
0.88
85
a. Reflectance of aggregate must be verified field or laboratory verified using ASTM
C1549.
b American Concrete Pavement Association, “Concrete Pavement Research &
Technology Update.” Number 3.05 June 2002. These values are from the
conservative end of the range reported.
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MR Credit 4.1: Recycled Content – 10% (post-consumer + ½ preconsumer)
The percentage requirement has changed from 5 to 10%, otherwise this credit
remains essentially the same. The word “pre-consumer” has replaced “postindustrial” although for our purposes the meaning is the same. For example, fly
ash and slag cement are post-industrial and pre-consumer materials. LEED
Canada-NC v1.0 requires a 7.5% recycled content.
We recommend that the calculation procedure be changed to be consistent with
LEED Canada-NC v1.0, which allows greater weighting of pre-consumer
supplementary cementitious materials. The use of the proposed procedure
should allow using fly ash and slag cement in conventional proportions the same
benefit as using recycled steel.
Lionel Lemay of NRMCA (previously mentioned) has prepared comments that
are incorporated into the text below.
Maggie Wojtarowicz of EcoSmart has also prepared a proposed comment that
can be viewed at
http://www.ecosmart.ca/documents/leed_comment_template.pdf (Email:
maggie@ecosmart.ca, Phone: 604-689-4023).
Brief description of the strengths or weaknesses of this prerequisite or credit and why this
is important to the environmental performance of the project.
The MR Credit 4.1 and 4.2 in the proposed LEED-NC version 2.2 does not
adequately account for the environmental benefit of partially replacing Portland
cement with supplementary cementing materials (SCMs) such as fly ash, slag,
and/or silica fume. The credit does not provide adequate incentive to use these waste
products to reduce the energy and green house gas intensity of concrete. It is
suggested that the calculation methodology for SCMs in concrete be changed to
provide additional incentive for the use of SCMs as described below. This
calculation methodology is similar to the MR4 implemented in LEED Canada-NC
version 1.0.
Brief description of how this prerequisite or credit could be improved and why this is
important to the environmental performance of a project.
Suggested change: The intent of the credit should address the impact of using
recycled content materials on the energy and GHG intensity of building
products. To provide additional incentive for using SCMs in concrete, recycled
content for cementing materials would be calculated by dividing the weight of
SCMs by the weight of total cementing materials (rather than the weight of
concrete, which includes the low embodied energy materials of aggregate and
water) and multiplying this value by the total cost of concrete on the project
(including formwork). In addition, this value should be multiplied by two (2) to
emphasize the environmental benefit of using SCMs in concrete.
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Reason: Using SCMs (fly ash, slag, and/or silica fume) to partially replace
Portland cement is the primary and most effective method for reducing the
energy and GHG intensity of concrete. However, the current method for
calculating recycled content provides very little incentive to use SCMs. Because
SCMs are so light compared to concrete, expressing SCMs as a percentage of
total weight of concrete does not give adequate incentive to increase the levels of
SCMs (and hence reduce the amount of Portland cement in concrete and the
energy and GHG signature of concrete). Dividing the weight of SCMs by the
weight of total cementing materials gives more emphasis to recycling cementing
materials. Including the cost of formwork for concrete in the calculation brings
the cost of concrete in line with the cost of other structural materials, such as
structural steel and precast concrete, both of which already include the cost of
prefabrication and/or formwork. The recycled content value should be
multiplied by two since the environmental benefit of using SCMs in concrete is
as great as or greater than those products that use post-consumer recycled
content. SCMs are by-products of processes not related to concrete production.
SCMs are waste products from other industries that would otherwise end up in
land fills. This is a significant distinction from other post-industrial (or preconsumer) recycled content where a manufacturing process recycles its own
waste back into the same manufacturing process.
1. Specific language changes you would suggest for the intent or requirements of this
prerequisite or credit and how it relates to the environmental performance of a project.
MR Credit 4.1: Recycled Content – 10% (post-consumer + ½ pre -consumer)
1 Point
Intent
Increase demand for building products that incorporate recycled content materials,
therefore reducing impacts resulting from extraction and processing of new virgin
materials and by-passing energy and greenhouse gas intensive manufacturing
processes.
Requirements
Use materials with recycled content such that the sum of post-consumer recycled
content plus one-half of the pre-consumer content constitutes at least 10% of the
total value of the materials in the project. The value of the recycled content portion
of material or furnishing shall be determined by dividing the weight of recycled
content in the item by the total weight of all material in the item then multiplying
the resulting percentage by the total value of the item. The value of recycled content
for cementing materials shall be determined by dividing the weight of
supplementary cementing materials (fly ash, slag, silica fume) by the total weight of
cementing materials (supplementary cementing materials plus portland cement)
then multiplying the resulting percentage by the total value of concrete on the
project and then multiplying this value by two (2). Mechanical and electrical
components shall not be included in this calculation.
Submittals
• Provide the LEED-NC letter Template, signed by the architect, owner or other
responsible party, declaring that the credit requirements have been met and listing
the recycled content products used. Include details demonstrating that the project
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incorporates the required percentage of recycled content materials and products
and showing their cost and percentage(s) of post-consumer and/or preconsumer
content, and the total cost of all materials for the project.
Potential Technologies & Strategies
Establish a project goal for recycled content materials and identify material
suppliers that can achieve this goal. During construction, ensure that the specified
recycled content materials are installed and quantify the total percentage if recycled
content materials installed.
MR Credit 4.2: Recycled Content – 20% (post-consumer + ½ pre-consumer)
The percentage requirement has increased from 10 to 20%, otherwise this credit
remains essentially the same. The word “pre-consumer” has replaced “postindustrial” although for our purposes the meaning is the same. We suggest
essentially the same comment as for MR Credit 4.1.
Brief description of the strengths or weaknesses of this prerequisite or credit and why this
is important to the environmental performance of the project.
The MR Credit 4.1 and 4.2 in the proposed LEED-NC version 2.2 does not
adequately account for the environmental benefit of partially replacing Portland
cement with supplementary cementing materials (SCMs) such as fly ash, slag,
and/or silica fume. The credit does not provide adequate incentive to use these waste
products to reduce the energy and green house gas intensity of concrete. It is
suggested that the calculation methodology for SCMs in concrete be changed to
provide additional incentive for the use of SCMs as described below. This
calculation methodology is similar to the MR4 implemented in LEED Canada-NC
version 1.0.
Brief description of how this prerequisite or credit could be improved and why this is
important to the environmental performance of a project.
Suggested change: The intent of the credit should address the impact of using recycled
content materials on the energy and GHG intensity of building products. To provide
additional incentive for using SCMs in concrete, recycled content for cementing
materials would be calculated by dividing the weight of SCMs by the weight of total
cementing materials (rather than the weight of concrete) and multiplying this value by
the total cost of concrete on the project (including formwork). In addition, this value
should be multiplied by two (2) to emphasize the environmental benefit of using SCMs
in concrete.
Reason: Using SCMs (fly ash, slag, and/or silica fume) to partially replace Portland
cement is the primary and most effective method for reducing the energy and GHG
intensity of concrete. However, the current method for calculating recycled content
provides very little incentive to use SCMs. Because SCMs are so light compared to
concrete, expressing SCMs as a percentage of total weight of concrete does not give
adequate incentive to increase the levels of SCMs (and hence reduce the amount of
Portland cement in concrete and the energy and GHG signature of concrete). Dividing
the weight of SCMs by the weight of total cementing materials gives more emphasis to
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January 17, 2005
recycling cementing materials. Including the cost of formwork for concrete in the
calculation brings the cost of concrete in line with the cost of other structural materials,
such as structural steel and precast concrete, both of which already include the cost of
prefabrication and/or formwork. The recycled content value should be multiplied by
two since the environmental benefit of using SCMs in concrete is as great as or greater
than those products that use post-consumer recycled content. SCMs are by-products of
processes not related to concrete production. SCMs are waste products from other
industries that would otherwise end up in land fills. This is a significant distinction from
other post-industrial (or pre-consumer) recycled content where a manufacturing
process recycles its own waste back into the same manufacturing process.
Specific language changes you would suggest for the intent or requirements of this
prerequisite or credit and how it relates to the environmental performance of a project.
MR Credit 4.2: Recycled Content – 20% (post-consumer + ½ pre -consumer)
1 Point in addition to MR 4.1
Intent
Increase demand for building products that incorporate recycled content materials,
therefore reducing impacts resulting from extraction and processing of new virgin
materials and by-passing energy and greenhouse gas intensive manufacturing processes.
Requirements
Use materials with recycled content such that the sum of post-consumer recycled
content plus one-half of the pre-consumer content constitutes at least 20% of the total
value of the materials in the project. The value of the recycled content portion of
material or furnishing shall be determined by dividing the weight of recycled content in
the item by the total weight of all material in the item then multiplying the resulting
percentage by the total value of the item. The value of recycled content for cementing
materials shall be determined by dividing the weight of supplementary cementing
materials (fly ash, slag, silica fume) by the total weight of cementing materials
(supplementary cementing materials plus portland cement) then multiplying the
resulting percentage by the total value of concrete on the project and then multiplying
this value by two (2). Mechanical and electrical components shall not be included in this
calculation.
Submittals
Provide the LEED-NC letter Template, signed by the architect, owner or other
responsible party, declaring that the credit requirements have been met and listing the
recycled content products used. Include details demonstrating that the project
incorporates the required percentage of recycled content materials and the total cost of
all materials for the project.
Potential Technologies & Strategies
Establish a project goal for recycled content materials and identify material suppliers
that can achieve this goal. During construction, ensure that the specified recycled
content materials are installed and quantify the total percentage if recycle d content
materials installed.
LEED NC v2.2
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January 17, 2005
EQ Credit 4.2 Low-Emitting Materials – Paints and Coatings
Indoor Environmental Quality Credits 4.1 through 4.4 are for using sealants,
paints, carpet, and wood products with low VOCs. We propose adding concrete
exposed to the interior to EQ Credit 4.2 to recognize the low VOC value of
exposed concrete in lieu of paints and coating for walls. We recommend using
the following wording or your own.
1. Please provide a brief description of the strengths or weaknesses of this prerequisite or
credit and why this is important to the environmental performance of a project
The intent of EQ Credit 4.2 is to “reduce the quantity of indoor air contaminants
that are odorous or potentially irritating and/or harmful to the comfort and wellbeing of installers and occupants”. We propose that consideration be given to
concrete and masonry exposed to the interior (interior walls and other decorative
and structural elements). This would lead to improved indoor air quality by
avoiding high VOC interior finishes (wall finishes and coverings, and ceiling tiles or
finishes), as well as the subsequent chemicals for cleaning and
refurbishment/replacement of these finishes.
2. Please provide a brief description of how this prerequisite or credit could be improved
and why this is important to the environmental performance of a project
EQ Credit 4.2 “Low-Emitting Materials – Paints and Coatings” identify materials
that emit low amounts of VOCs. Concrete is a product that has an extremely low
VOC emission level. The document prepared by the Environmental Council of
Concrete Organizations, (www.ECCO.org Catalog Item EV20, download for free)
“What’s Your IAQ I.Q.?”, on page 3, contains a table of VOC levels for different
construction materials. The VOC level for concrete is the lowest of all the materials
on the chart. Quality concrete and masonry are constructed for use as floors, walls,
and ceilings. The design and construction of concrete and masonry is governed by
specifications depending on the use and type of concrete or masonry. These include
“American Concrete Institute (ACI) 302, Guide for Concrete Floor and Slab
Construction,” “ACI 318, Building Code Requirements for Structural Concrete,”
and “ACI 530.1, Specification for Masonry Structures.”
3. Please provide specific language changes you would suggest for the intent or
requirements of this prerequisite or credit and how it relates to the environmental
performance of a project:
EQ Credit 4.2: Low-Emitting Materials – Paints, Coatings and Exposed Concrete
1 Point
Intent
Reduce the quantity of indoor air contaminants that are odorous, potentially
irritating and/or harmful to the comfort and well-being of installers and occupants.
Requirements
Add the following sentence:
LEED NC v2.2
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January 17, 2005
Use concrete or masonry exposed to the interior of the building for at least 30% of
the floors, exterior walls, or ceilings. Paints or coatings used on the interior surfaces,
if any, must comply with EQ Credit 4.2: Low-Emitting Materials – Paints and
Coatings.
Submittals
Add the following bullet:
Provide the LEED-NC Letter Template, signed by the architect or responsible
party, referencing the building plan to demonstrate the areas of exposed concrete or
masonry, and declaring that (1) at least 30% of the wall surfaces, or ceilings are
constructed of concrete exposed to the interior, and (2) the concrete or masonry
floor, wall, and/or ceiling (underside of floor) were constructed using the applicable
code or specification (“American Concrete Institute (ACI) 302, Guide for Concrete
Floor and Slab Construction,” “ACI 318, Building Code Requirements for
Structural Concrete,” and “ACI 530.1, Specification for Masonry Structures.”), and
(3) sealants or coatings used on these interior concrete or masonry surfaces, if any,
comply with EQ Credit 4.2: Low-Emitting Materials – Paints and Coatings.
Potential Technologies & Strategies
Add the following: Use concrete surfaces exposed to the interior and do not apply
additional materials such as carpet, interior finish materials, or suspended ceiling
tiles.
EQ Credit 4.3 Low-Emitting Materials – Carpet Systems
Indoor Environmental Quality Credits 4.1 through 4.4 are for using sealants,
paints, carpet, and wood products with low VOCs. We propose adding concrete
exposed to the interior to EQ Credit 4.3 to recognize the low VOC value of
exposed concrete in lieu of carpeting for flooring. We recommend using the
following wording or your own.
1. Please provide a brief description of the strengths or weaknesses of this prerequisite or
credit and why this is important to the environmental performance of a project
The intent of EQ Credit 4.3 is to “reduce the quantity of indoor air contaminants
that are odorous or potentially irritating and/or harmful to the comfort and wellbeing of installers and occupants”. We propose that consideration be given to
concrete exposed to the interior (interior floors, stair treads and landings). This
would lead to improved indoor air quality by avoiding high VOC interior finishes,
as well as the subsequent chemicals for cleaning and refurbishment/replacement of
these finishes.
2. Please provide a brief description of how this prerequisite or credit could be improved
and why this is important to the environmental performance of a project
EQ Credit 4.2 “Low-Emitting Materials – Carpet Systems” identify materials that
emit low amounts of VOCs. Concrete is a product that has an extremely low VOC
emission level. The document prepared by the Environmental Council of Concrete
LEED NC v2.2
Page 19
January 17, 2005
Organizations, (www.ECCO.org Catalog Item EV20, download for free) “What’s
Your IAQ I.Q.?”, on page 3, contains a table of VOC levels for different
construction materials. The VOC level for concrete is the lowest of all the materials
on the chart.
In many instances, concrete is constructed for use as floors below, on and above
grade as a structural element. Selecting a decorative concrete surface would
preclude the manufacturing, use and disposal and associated transportation of
additional materials. The design and construction of concrete is governed by
specifications depending on the use and type of concrete. These include “American
Concrete Institute (ACI) 302, Guide for Concrete Floor and Slab Construction,”
and “ACI 318, Building Code Requirements for Structural Concrete,”
3. Please provide specific language changes you would suggest for the intent or
requirements of this prerequisite or credit and how it relates to the environmental
performance of a project:
EQ Credit 4.2: Low-Emitting Materials – Carpet Systems and Decorative Exposed
Concrete
1 Point
Intent
Reduce the quantity of indoor air contaminants that are odorous, potentially
irritating and/or harmful to the comfort and well-being of installers and occupants.
Requirements
Add the following sentence:
Use concrete exposed to the interior of the building for at least 30% of the floors.
Sealers or coatings used on the exposed surfaces, if any, must comply with EQ
Credit 4.2: Low-Emitting Materials – Paints and Coatings.
Submittals
Add the following bullet:
Provide the LEED-NC Letter Template, signed by the architect or responsible
party, referencing the building plan to demonstrate the areas of exposed concrete,
and declaring that (1) at least 30% of the floors are constructed of concrete exposed
to the interior, and (2) the concrete floor was constructed using the applicable code
or specification (“American Concrete Institute (ACI) 302, Guide for Concrete Floor
and Slab Construction,” and “ACI 318, Building Code Requirements for Structural
Concrete”), and (3) sealants or coatings used on these interior concrete floors, if any,
comply with EQ Credit 4.2: Low-Emitting Materials – Paints and Coatings.
Potential Technologies & Strategies
Add the following: Use concrete surfaces exposed to the interior and do not apply
additional materials such as carpet.
MR Credit 8 Durable Building
LEED NC v2.2
Page 20
January 17, 2005
Although USGBC has indicated they will not accept new credits in this comment
period, a new credit for durability was added to LEED Canada-NC version 1.0. I
have attached the Canadian language, the rationale, and the referenced table.
We recommend this credit be added to LEED-NC v2.2 using this wording or your
own.
Submit this as a General Comment.
1. Please provide a brief description of the strengths or weaknesses of this prerequisite
or credit and why this is important to the environmental performance of a project:
LEED-NC does not offer credit for durability and longevity of materials,
products, and buildings. The intent of Materials & Resources Credit 8 is to
“minimize materials use and construction waste over a building’s life resulting
from premature failure of the building and its constituent components and
assemblies.” We propose that a durable building credit, Materials & Resources,
Credit 8, LEED Canada-NC 1.0, be considered for LEED-NC 2.2.
2. Please provide a brief description of how this prerequisite or credit could be improved
and why this is important to the environmental performance of a project:
The Canadian Green Building Council responded to the omission of any credits
for durability in LEED-NC 2.1 and added a new single point for a durable
building.
The credit applies to the whole building, with a focus on the exterior elements
that are most exposed to environmental loads. The durability credit is based on
the requirement that the building Predicted Service Life exceed the Design
Service Life. Table 2 from CSA S478 provides categories of Design Service Life,
such as 50 to 99 years for Long Life buildings such as most residential,
commercial and office buildings. CSA S478 requires that the predicted service
life of components or assemblies be assessed by: demonstrated effectiveness,
modeling or testing. Demonstrated effectiveness may be applied where identical
assemblies have been used successfully in the same environments.
3. Please provide specific language changes you would suggest for the intent or
requirements of this prerequisite or credit and how it relates to the environmental
performance of a project: (from LEED Canada-NC v1.0)
Durable Building
Intent
Minimize materials use and construction waste over a building's life
resulting from premature failure of the building and its constituent
components and assemblies.
Requirements
LEED NC v2.2
Page 21
January 17, 2005
Develop and Implement a Building Durability Plan, in accordance with the
principles in CSA S478-95 (R2001) - Guideline on Durability in Buildings,
for the components within the scope of the Guideline, for the construction
and preoccupancy phases of the buildings as follows:

Design and construct the building to ensure that the predicted service
life exceeds the design service life established in Table 2 in CSA S47S95 (R2001) - Guideline on Durability in Buildings.

Where component and assembly design service lives are shorter than
the design service life of the building, design and construct those
components and assemblies so that they can be readily replaced, and
use a design service life in accordance with Table 3 in CSA S478-95
(R2001) - Guideline on Durability in Buildings, as follows:
o For components and assemblies ,whose Categories of Failure
are 6, 7 or 8 in Table 3, use a design service life equal to the
design service life of the building.
o For components and assemblies whose Categories of Failure
are 4 or 5 in Table 3, use a design service life equal to at least
half of the design service life of the building.

Demonstrate the predicted service life of chosen components or
assemblies by documenting demonstrated effectiveness, modeling of
the deterioration process or by testing in accordance with Clause 7.3,
7.4 or 7.5 and by completing Tables A1. A2 & A3.from CSA S478-95
(R2001) - Guideline on Durability in Buildings.

Document the elements of quality assurance activities to be carried
out to ensure, the predicted service life is achieved, in the format
contained in Table 1, Quality Assurance and the Building Process, of
CSA S478-95 (R2001) - Guideline on Durability in Building.

Develop and document the quality management program for the
project that ensures the quality assurance activities are carried out, in
accordance with the elements identified in Clause 5.3, Elements of
Quality Management, CSA S478-95 (R2001) - Guideline on Durability
in Buildings.
Submittals


Provide the LEED Letter Template, signed by the professional
responsible and the general contractor, declaring that a Building
Durability Plan has been developed and implemented.
Document the building science qualification certification or training
qualifications of the professional(s) responsible for the building
envelope design of the building.
LEED NC v2.2
Page 22
January 17, 2005