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Green Building Curmudgeon

LEED-H and Retrofit Guidelines Released for Public Comment

Get ready to slog through the documents and tell the USGBC and the DOE what you don’t like

LEED for Homes is undergoing its first major revision. Time to look it over and tell them what you like and don't like about it.

With some interesting timing, the first drafts of the new LEED for Homes rating system and the DOE’s Residential Retrofit Guidelines were both released for review and public comment in the same week. I suppose it’s a coincidence, but it sure seems like someone up there wants everyone involved in residential green building and renovation to drop what they are doing and spend their entire holiday season reviewing the obscure minutiae in these documents. Since I work more with LEED than weatherization, I spent more time with the new rating system, although I hope to take some time to review all the DOE documents soon. I will have to set aside even more time for that project, as the two documents together total over 600 pages!

In case you haven’t noticed…

For anyone new to my blog, I have dedicated a significant portion of my posts on this site to complaining about the LEED for Homes program, among other things. Although I usually like to start out complaining, I will take a different route today and begin with what I like. (But first, because he asked for it, a shout-out to my friend Tom Flanagan at the USGBC, who emailed me the rating system documents that I had trouble downloading from their website.) I may be misinterpreting some of the intent in this draft, and I hope that the USGBC will join in this discussion to correct any misunderstandings.

First, what’s right

Based on my initial review of the new rating system, it appears to me that the USGBC has been listening to me, and others, who have been voicing opinions on the existing program. It does appear to me that they will be eliminating the practically pointless (and required) “Letter to Vendors” stating a preference for FSC-certified wood. Good move, guys. Even more important, the project-specific, extremely subjective “Durability Inspection Checklist,” always a burden for project teams to assemble, has been replaced with the ENERGY STAR Water Management System Builder Checklist, part of the new set of inspection reports for ENERGY STAR version 3. Again, good move. New credits are available for universal design features and flexible construction methods that allow for easier modification and disassembly of buildings.

While I have minor complaints about some of these last items, overall they are a positive move. There is now an easy-to-understand backdraft potential test for fireplaces and woodstoves, replacing the practically indecipherable formula in the current version. Thanks again, folks. Finally, the USGBC has added a credit for proximity to a job center. If the project is within 10 miles of a job center (yet to be defined), it gets points; if it is within 3 miles, it gets more points. To me, this is a very simple, straightforward, and appropriate connectivity concept that makes sense. (Maybe they’ll take it out now!)

Next, what I think is wrong

Just in case any of you thought I wasn’t going to complain—plenty of things in this draft make me a little crazy, and I’m not shy about letting the USGBC know. To start, the program still uses Air Changes per Hour @ 50 Pascals (ACH50) to determine credits for air infiltration. This particular measure, while one of several standards, tends to penalize small homes. I believe LEED should switch to the Envelope Leakage Ratio (ELR) that uses the amount of air leakage per square foot of the building envelope, which more accurately balances small and large homes.

Credits are available for installing ERVs and HRVs, which, in my opinion, don’t always provide an energy benefit, particularly in moderate climates. I would like to see this credit limited to extreme climates. Points are now available for heat-pump water heaters, currently the child star of the green building industry—but again, in my opinion, somewhat overrated. They are most effective when installed in unconditioned space in hot climates, and actually add to the heating load when installed inside a house. I think this one deserves a closer look. Under the high-efficiency appliances category, points are available for installing ENERGY STAR ceiling fans. Now, I can’t tell you how many times I see ceiling fans running in rooms (and on front porches) with no one sitting below them. This credit should be removed, or at least require occupancy sensor or timer-operated switches to eliminate wasted energy from fans being left on.

Other minor concerns include credit under the Design for Adaptability section for putting ducts in the attic. This works if you insulate the roofline, but overall it’s just not a great design idea. There are also credits for installing zoned HVAC systems, something that again seems to favor larger homes, which almost always have them, while compact homes often don’t need zoning. I would like to see some of these issues that penalize smaller homes be reconsidered and changed to instead favor them.

Finally, things I just don’t understand

Probably just because most of us are now fully comfortable and familiar with the various credit categories, the USGBC has decided to change the names of some of them and add new ones. Innovation and Design (ID) is now Integrated Process (IP). Locations and Linkages (LL) is now Location and Transportation (LT). Energy and Atmosphere (EA) is now Performance (PF). New categories include Innovation (IN) and Regional Priority (RP), which are supposed to have details listed on the USGBC website, but I cannot find anything there yet.

Another curious change is the credit for having a LEED AP Homes credentialed member on the project team. Previously, if a team member (excluding the rater) had this designation, the team got this point. Now, in addition to the AP, the team must have two additional designees, although they can be other LEED specialties or Green Associates. To me, this looks like nothing more than a ploy by the USGBC to build their revenue stream from individual designations. Come on, folks, give it a rest. You have enough money already.

Overall, I am reasonably satisfied with the changes proposed thus far. I am smart enough to realize that I will never be fully satisfied with this program, but I do get the feeling that the USGBC has been listening, at least a little. Hopefully they will continue to do so, and we will see a much better program roll out in 2012—although my ADD-addled mind can’t understand why it can’t be sooner.

Get on the stick, everyone. Download the files, read them, and make your comments on the first draft before the end of the year.


  1. Sean @ SLS | | #1

    Nice Recap
    Great recap & I can't wait to look at them - sorry, I haven't had a chance to review them yet but they have been downloaded

    I can't wait for you to hit the "voluntary" retrofitting guidelines, because they are a mess. When I first attended the webinar, I went from this sounds pretty good, to this is going to be a nightmare - After reading through most of the 632+ pages, I think I understated how much of a mess this will be & how skewed the document really is.

    Good luck & enjoy

  2. Michael | | #2

    About those Ceiling Fans...
    Good article, Carl.

    I haven't had time to sit and read through either the new LEED draft or the DOE draft so thanks for giving those of us out here in drone land an assessment. I do have to pick a nit with your suggestion about getting points for attaching motion sensors to ceiling fans, however.

    Ceiling fans aren't just for cooling room occupants. In fact, I see that as the worst use of one. Their main benefit, in my opinion, is to assist in distributing single point hot or cold air throughout the floor of the building. In mind climates it's not uncommon for the only heating source to be something like a monitor heater, installed in the largest room of the house. Coupled with a ceiling fan running in "updraft" mode, that one small heater can keep a 2,000 SF house comfortable throughout. In "downdraft" mode, the same is true for a small, in window AC unit. Again, I'm talking mild climates, here -- and smaller houses and/or office building, too -- not a panacea solution for all applications. But still...

    -Michael @TheGreenBuilder

  3. Expert Member
    Carl Seville | | #3

    RE Ceiling fans
    Good point on the fans, Michael, but I have been putting up with those cold climate guys ignoring warm climates for so many years that I just need to get back at them. Perhaps this should be a climate based point - where the primary purpose is cooling, fans are used in the downdraft mode, in heating updraft, and come up with a suitable way to provide credit for best practices. It just makes me crazy to see fans running 24/7 in warm weather with no one sitting below them.

  4. John Brooks | | #4

    heat pump water heaters
    I thought it was diserable for heat pump water heaters to be located in the conditioned space for hot climate homes.

  5. Anonymous | | #6

    "Come on, folks, give it a rest. You have enough money already. "

    probably my biggest complaint about USGBC. that and a lack of oversight.

  6. Expert Member
    Carl Seville | | #7

    Heat pump heaters
    John - You are correct about the heater location, I was not quite clear in my post. Most climates require some heating during the year, and any house that uses heating with a heat pump water heater will have additional load when the heat pump is operating. That is why they have several settings including standard resistance heat for cold weather. One of my concerns is that most homeowners will at some point switch to the resistance mode then forget to switch it back, ending up with a very expensive standard electric heater.

  7. Edward Palma | | #8

    Although I agree that the
    Although I agree that the USGBC paved the way in the education of architects, designers and builders of high efficiency buildings I feel that they have grown to such size that they have morphed into a corporation that needs to generate massive amounts of capitol to grow and survive. Through their definitions of the professional credential programs that they offer they exclude anyone who has not been involved in a LEED certified project to qualify for the various AP credentials even if they have a solid knowledge base, extensive experience in green building, and an understanding of the LEED rating system. Those that want to achieve certification without prior involvement in LEED need to complete their training program in order to qualify to sit for their exam. I am not arguing the merits of LEED or their educational programs. I support their merits and personal education I am just trying to point out the fact that a major portion of their revenue stream comes from education, certification and processing fees, maintenance of certification credential fees, and membership fees. The LEED Green Associate has been added to their list of certifications to allow those who have experience and education in non LEED based programs to possibly qualify for the exam thusly adding more to their revenue stream. Most will still have to enroll and complete the GA training in order to be allowed to take the exam, adding more to the revenue stream. In making my point about corporate control and funding I strayed from my intent, which is to point out that there are other choices in residential green building. The NAHB National Green Standard is an example which I feel is as good or maybe better for residential designers and builders of green homes. I attended a seminar yesterday in Sustainable Building Construction and the Building Codes. It was offered as part of the continuing education for architects, designers, builders, teachers and code officials in our state and moderated by a LEED Certified AP. They felt that the National Green Standard was better suited for designers and builders in the residential green building market. Their comment came from the fact that they saw that a few of us had our copies of the Standard in our materials. Obviously they were there to promote LEED so there were no slides in their presentation regarding this. It was a personal comment and that was all that was acknowledged. I am aware that all of the organizations that have developed rating systems need the revenue that they generate from training, certification, maintenance of certification and membership in order to survive and grow. Business is business. Each one has their niche in the green building market whether it be commercial or residential. Each one provides excellent education and support for the individual that chooses them. LEED is the obvious "grandaddy" of them all. Hopefully the competition with the "grandkids" will keep each of these programs on their feet and in tune with the requests and commentary offered by their members whether they be architects, designers, raters, builders, students, graduates or just educated critics. Supervision of projects, periodic scheduled follow up on built projects, and support for their users in the field are the key issues for all of them.

  8. Asa Foss | | #9

    Public Comment

    I appreciate you starting this discussion here. I want to point out two official forums for you and your readers to provide feedback on the next version of LEED. The official USGBC Public Comment page is here:

    Also, LEEDuser will be submitting all comments that they receive on the following page to USGBC as official comments, and I believe USGBC staff are responding to comments as well on the forum:

    I personally am interested to hear thoughts specifically on the new proposed absolute energy metric - which replaces the current Home Size Adjuster and HERS metric - that requires all homes to use less energy than a reference home. The reference home is essentially a moderately sized home built to ENERGY STAR v3 standards.

  9. Brett Moyer | | #10

    No HSA??
    So we are going to see more LEED certified McMansions with PV?

  10. Expert Member
    Carl Seville | | #11

    LEED is not the granddaddy & Absolute Energy Metric
    Edward - It does a disservice to the more than 100 local green home building programs out there to call LEED the granddaddy of them. LEED for Homes built on a lot of excellent work by ENERGY STAR and local programs, ultimately spurring NAHB to create their own program in response, but many local programs are extremely successful and will continue to be, although it is likely that a single national program will ultimately take the lion's share of the market.

    Asa - Please explain the energy metric. I couldn't figure it out from the draft version, which is why I made no comments on it.

  11. Edward J. Palma | | #12

    Everyone, it was not my
    Everyone, it was not my intention to disservice any of the local green building programs by referring to LEED as the "grandaddy of them all". It was meant to describe the size and market share of the USGBC corporate interests in the green building market. I am a strong proponent of locally driven programs and feel that they create more continuity educationally and service wise to the communities and areas that they are located in. It was only to point out that the USGBC was there in the beginning when a rating system for high performance buildings was under development and they have dominated the green building movement since. That being said the USGBC seems to have a major control of the contemporary market and influences much of the policy in the green building movement. Bretts' comment falls more in line with my feelings. I don't feel that being the "grandaddy" makes them the best and most practical rating program. It only serves to make them the largest. There is a definite need for all of the rating programs to compete with LEED and keep them grounded in the reality that McMansions do not "LEED' us on the path to a sustainable future. Carl, I apologize if my intent to offer the USGBC respect for their longevity, was misconstrued as disservice to other programs. I was actually trying to point out the value, viability and need for the other programs to contribute their ideas and methods to the process.

  12. ROY HARMON | | #13

    What does LEED stand for? I,m trying to understand the real need for an additional regulating force that seems to cater to a greed driven corporate materials market by design. Maybe the answer is in the term LEED? Being rewarded or awarded points or fiat precious metal standard seems a little odd to me. The creation of lofty and for the most part expensive project goals will ultimately further confuse the masses. LEED seems to be aquiring a "big government" stigma that will no doubt limit it's intent. Keep it simple.

  13. Dave Robinson | | #14

    Keep it simple. Strive for Zero....
    I agree with Roy's last word ... Keep it simple. IF the builder-renovator knows the right thing to do, And wants to do the right thing, ... what's to stop him or her? Two things at least. 1. The budget of the owner, and 2. The banking, appraisal combination. It is very frustrating to my Home Performance Contracting friends, to wind up performing half or less of the scope of work that would really "fix the house"
    There is one area where you can go ahead and do the right thing to your heart's content. As an investor, buying & renovating foreclosed homes ... there is no one telling you what you can and cant do. No one requires this rating or that certification either. Just do the right thing that is in your heart and head & spend all the money you would have contributed to all these rating infrastructures on more good building.
    Contrary to the party line of the rating systems, buyers can be educated in your sales process and will spend money for the value you've added. Free enterprise really does work at this level. It's a wonderful thing.

  14. Melisa Camp | | #15

    ReGreen Program
    I would like to see some sort of certification/rating system for the ReGreen program. New building is not where it's at- existing homes being retrofitted is key! http://
    -Melisa Camp, LEED Green Associate & Realtor, GREEN

  15. Expert Member
    Carl Seville | | #16

    Melisa - Everything I have heard indicates that there is no plan for ReGreen to become a certification program anytime soon, regardless of the demand. There are several local residential green renovation certification programs, including EarthCraft House ( which I worked on, Minnesota Greenstar, among others. The NAHB program also includes certification for renovations. I am not sure why USGBC is avoiding this market, but I suspect that they see the best opportunity for LEED for Homes in multifamily projects and affordable housing and that is where they are putting their effort. Sometimes it seems very silly that so much effort is put into certifying new homes to green standards when they represent only a tiny fraction of the total housing stock, most of which is very deficient and sorely in need of sustainable upgrades.

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