From Mike Jackson, FAIA, Illinois Historic Preservation Agency
The process for changing the U.S. Green Building Council LEED Rating Systems is now open for public comments. The comment period ends on Jan 14, 2011 so act fast. The majority of comments will come from the design, manufacturing and building communities so it is extremely important for the preservation community make its voice heard. In many ways, the preservation community is the only voice for building re-use as a green approach. The comments below will help you address the credit topics that seem most critical to the discussion of historic resources and the benefits of building re-use. If you only have a limited amount of time, please comment on the credits about building re-use and materials. Both of these areas will strengthen the viability of historic rehabilitation as a green action. Ideally, you should take the time to look at the whole LEED rating system drafts and comment on other areas within your areas of expertise. Also keep in mind that there are separate comment areas for different LEED rating systems that broadly cover buildings, homes and neighborhoods. You can end up making the same comment several different times so that they are applied to individual ratings systems as well as the pilot credits.
Material Credit 1 (Pilot Credit # 19) – Whole Building Re-use
Discussion: The proposed credit is the first time the LEED building rating system will recognize historic buildings and cultural landscapes. (LEED for Neighborhood Development was the first LEED product to include historic resource identification.) This is a much needed recognition for the LEED system. Let the USGBC know you approve. Comments don’t have to be limited to items that you feel need to be changed. This credit also has language about the retention of historic windows, which is another item worthy of positive reinforcement. This credit has not been specifically targeted towards residential buildings, and it should be applied to the LEED for Homes rating system as well as all others.
This credit also includes language about blighted buildings. The intent of providing special incentives for historic and blighted properties is good, but it would be better if these were separate items. Historic buildings have a working definition that includes listed and eligible properties and a strong constituency that can apply these definitions. The social benefits of investing in blighted areas as well as buildings is a good value system, but is not really that related to historic buildings.
Proposed Comment: The recognition of historic buildings is a welcome addition to the LEED criteria.
Proposed Recommendation: The category of “blighted buildings†should be given a separate category from “historic building.â€
Material Reuse Credits #2 and 3
Discussion: These two credits have been used to provide a material value to building re-use. The preservation community has long concluded that green building rating systems have undervalued building re-use. Keep in mind that this comment period is NOT about the allocation of points, which will be handled at a later stage. For now, it is important to comment on the need for a more equitable method of allocating the value of “in-situ†materials re-use other than the simplified two-part formula. For example, the BREEAM Ecohome rating system from England divides a house into seven major components and allows all materials credits to be claimed when 80% of the existing materials are retained in each category. As stated in BREEAM, “the environmental impact of replacing an element is far greater than reusing the element already in place.” The expanded use of Life Cycle Assessment tools would also provide a more equitable comparison of in-situ, recycled content, re-used or new materials.
Proposed Comment: The two-part credit allocation for materials reuse is too narrow and should have a stronger Life Cycle Assessment protocol to provide a better measure of building reuse.
Proposed Recommendation: The BREEAM Ecohomes rating system should be investigated as a better model of building re-use scoring. It divides a building into a larger number of major components/systems and allocates the full material credit for each component when 80% of that component is retained “in situ.†This system is much fairer in providing a positive benefit to in-situ material re-use. . As stated in BREEAM, “the environmental impact of replacing an element is far greater than reusing the element already in place.”
LEED for Homes
Discussion: The LEED for Homes system is primarily designed for new construction but it can also apply to renovation. The system does not include the category of building re-use or any materials credits for in-site materials use. There is some credit available for using reclaimed materials. This system is so biased towards new construction, that one gets the feeling that it should only be allowed for new construction. Having said that, it would be worth commenting on the building re-use and materials credits.
LEED for Homes: Location and Transportation Credit: Preferred Locations
Proposed Comment: The site location criteria should include the identification of historic area and those with the longest pattern of development. The use of historic and age criteria would provide a positive reinforcement of traditional patterns of development.
Proposed Recommendation: The retention and re-use of historic buildings should be encouraged just as brownfield development is encouraged. The retention of historic buildings should be a pre-requisite unless their demolition has been approved by the preservation authority having jurisdiction, as is stated in LEED for Neighborhood Development.
The redevelopment of existing locations could have an expanded value based upon the age of the settlement, with the most credit provided to the oldest settlement areas.
LEED for Homes: MR Credit: Environmental Preferable Products
Discussion: (See proposed comment)
Proposed Comment: This credit has been written from the perspective of a new building and is devoid of any environmental benefit from the in-site use of materials when buildings are renovated. The in-situ use of materials in renovated buildings needs to be added to this LEED for Homes rating system.
Proposed Recommendation: The BREEAM Ecohomes rating system should be investigated as a better model of building re-use scoring. It divides a building into a larger number of major components/systems and allocates the full material credit for each component when 80% of that component is retained “in situ.†This system is much fairer in providing a positive benefit to in-situ material re-use. . As stated in BREEAM, “the environmental impact of replacing an element is far greater than reusing the element already in place.”
LEED for Neighborhood Development
GIB Credit: Existing Building Reuse
Proposed Comment: The retention and re-use of existing buildings is a very important strategy for the long-term environmental benefit. The overall percentage of building retention in this category is extremely low. Retaining just 20% of the buildings except for 50% of the structure means that only 10% of the existing building stock needs to be retained for this credit. These means that 90% of the materials could be demolished as a green approved project.
Proposed Recommendation: The retention of existing building stock should be at least 80% and the retention of materials within buildings should be based upon an LCA approach such as the English BREEAM Ecohomes. The BREEAM Ecohomes rating system divides a building into a larger number of major components/systems and allocates the full material credit for each component when 80% of that component is retained “in situ.†This system is much fairer in providing a positive benefit to in-situ material re-use. As stated in BREEAM, “the environmental impact of replacing an element is far greater than reusing the element already in place.” The building retention test should also be subject to mitigation for when much higher density of re-use is proposed, except for the case of historic buildings.
GIB Credit: Historic Resource Preservation and Adaptive Reuse
Discussion: This is a credit that is allocated for the preservation of historic buildings and landscapes.
Proposed Comment: The recognition and credit for the retention and historic rehabilitation of historic buildings is an important addition to the LEED system. Retain and strengthen this credit.
Proposed Recommendation: This credit should be a prerequisite. The demolition of historic buildings should not be a permitted action approved through the LEED for Neighborhood Development rating except for the currently approved exceptions.
How to make comments: (This will require you to have a USGBC log-in.)
1. Click on the following link: http://www.usgbc.org/LEED/LEEDDrafts/RatingSystemVersions.aspx?CMSPageID=1458
2. Click on the Expand button next to “LEED Rating System Draft: BD & C , ID &C, and EB:O&Mâ€
3. Open the “BD&C Document†and look for the following sections
a. MR CREDIT: WHOLE BUILDING REUSE p. 112
b. MR CREDIT: MATERIALS REUSE p.116
4. Once you have read the documents, click on the “Comment†button (Note: You must sign in to the USGBC to submit a comment. You do not have to be a member, but you do have to submit information about who you are to get full access to make the comments.)
a. Select the category “Materials and Resourcesâ€
b. Select the Whole Building Reuse section
c. Make comments
d. Repeat these steps for Materials Reuse
5. Repeat the process for LEED for Homes
6. Repeat the process for LEED for Neighborhood Development
More Guidance on the LEED Ratings Systems:
Barbara Campagna, FAIA has compiled a more complete list of changes to the LEED system and posted these on the National Trust web site.
Preservationists, Let’s Mobilize! Comment on the Next Version of LEED
Top Ten List of LEED Credits related to Preservation
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