Largest Owner of Buildings in North America Considering LEED v4

The General Services Administration is seeking public input on its analysis of LEED v4 and other questions related to the Federal Government's use of LEED v4.

Given that the Federal Government is, by far, the largest owner of buildings in North America, and is also the owner or more green buildings and more LEED certified buildings than anyone else, this is significant.    

The Energy Independence and Security Act of 2007 requires the GSA to review existing green building certification systems every 5 years to identify a system and certification level “deem[ed] to be most likely to encourage a comprehensive and environmentally sound approach to certification of green buildings.”

The Director of GSA’s Office of Federal High-Performance Green Buildings provides the findings of that review to the Secretary of Energy who, in consultation with the Department of Defense and GSA, formally identifies the system(s) to be used across the federal government. Such a review was undertaken in 2006 and 2012.

After an evaluation process that spanned several years, and after agency, public, and private sector input, GSA recommended in October 2013 that agencies use one of two green building certification systems that best suit agency missions and portfolio needs: the Green Building Initiative’s Green Globes 2010 and the U.S. Green Building Council’s LEED 2009.

GSA completed a supplemental review of the U.S. Green Building Council’s LEED v4 in November 2014 to determine its alignment with Federal green building requirements. And while some have suggested that v4 generally aligns, there are very real and large gaps in the robustness of the new LEED version credits with respect to energy and materials where the v4 credits are not aligned with Federal statutes, regulations and Executive Orders.

On January 21, 2015, GSA published a request for information in the Federal Register seeking additional public input on its analysis of LEED v4 and several other questions related to the Government's use of LEED v4 and future GSA reviews of green building certification systems.  

GSA is soliciting comments for 60 days, ending on March 23, 2015 and those active in the environmental industrial complex are urged to comment.  

GSA is also holding an online public listening session on March 2, 2015 from 1 - 3 p.m. EST to hear comments from stakeholders.  Information on the public listening session can be found at:

Once the comment period closes, GSA will be using this input to augment its 2013 recommendation as it relates to LEED v4. 

“GSA elected not to re-review the Green Globes rating systems at this time with .. changes looming.”

On a closely related matter, it is important to note that on October 14, 2014, the U.S. DOE published a final rule that formally identifies criteria that green building certification systems must meet in order to be used by the Federal Government. This GSA request for information is not for the purposes of that final rulemaking, but to inform GSA on its related responsibilities to study green building certification systems and recommend ones to the DOE that may fit within the framework of the final rule. DOE's final rule is worthy of your reading.  

GSA Selects Both Green Globes And LEED For Federal Buildings

Last Friday, the U.S. General Services Administration announced that it has issued its recommendation on the federal government’s use of third party green building certification systems.

In its recommendation to the Department of Energy, GSA recommended both the Green Building Initiative's Green Globes 2010 and the U.S. Green Building Council’s LEED 2009 as the third party certification systems that the federal government will use.

This recommendation, if accepted, portends a green building world (which has always been dominated by LEED) turned upside down. 

Section 436 of Energy Independence and Security Act requires the Director of GSA’s Office of Federal High-Performance Green Buildings to evaluate green building certification systems every 5 years to identify a system and certification level that will be most likely to encourage a comprehensive and environmentally sound approach to certification of green Federal buildings. EISA requires the GSA Administrator to provide his recommendation to the Secretary of Energy, who then consults with the Secretary of Defense and the GSA Administrator, to identify the system appropriate for use in the Federal sector to certify green buildings.

GSA first evaluated certification systems in 2006 focusing on new construction. Based on this 2006 review, GSA recommended LEED and today the Federal sector uses LEED. GSA’s most recent evaluation of green building certification systems focused on certification systems for new construction, major renovations, and existing buildings. That Green Building Certification System evaluation can be found at

 “We’ve found two tools that allow us to measure how federal buildings of all kinds can best save energy, improve overall performance, and cut down utility costs,” said Kevin Kampschroer, Director of GSA’s Office of Federal High-Performance Green Buildings.  

GSA recommended the Green Globes 2010 and LEED 2009 as the third party certification systems that the Federal government can use to gauge performance in its construction and renovation projects. Additionally, under the recommendation, GSA indicates it will conduct more regular reviews in order to keep up with the latest green building tools that the market has to offer. Such is significant given that the newly released versions of both Green Globes and LEED were not evaluated and are not recommended.

Agencies can use one of the two certification systems for new construction and one for existing buildings, recognizing that the Federal building portfolio ranges from office buildings, to laboratories, to hospitals, to airplane hangars.

Federal construction and modernization projects must also adhere to the government’s own green building requirements, including the Guiding Principles as mandated by Executive Order 13514. No one of the certification systems reviewed addresses all of the Guiding Principles. However, the latest version of Green Globes now includes the ability to certify new construction for compliance with the Guiding Principles. LEED v4 does not have such a feature, but USGBC has been working on a “crosswalk” to address the Guiding Principles.

While the final Federal policy has yet to be determined, there can be no dispute that this shift by GSA is a victory for Green Globes. But LEED has all but certainly won the bigger battle because allowing Federal agencies to choose between the two rating systems will take the wind out of the sails of the coterie that want to ban LEED from government projects.

Be aware that the GSA recommendation as not available at the time this post was prepared. This post is based upon information released from GSA and interviews with key policy making officials.

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A Green Building Game of Thrones

"Winter is coming."  

This is the common refrain in the popular book, Game of Thrones, in which kings vie to take over lands.  As I thought about the green building policy mess of 2012, I couldn't help but draw comparisons to Game of Thrones. 

This was supposed to be the year of the USGBC's new green building rating system, LEED 2012.  But somewhere along the way, the plan went awry and the USGBC had to retreat. 

In assessing the battlefield, I have concluded that the USGBC overextended itself, choosing to fight a two front war without the necessary resources. This is a common tactical mistake and one that has proven costly for the USGBC. Just how costly is yet to be seen. 

The Assault on Chemicals of Concern

Before being pulled, the proposed LEED 2012 rating system went through a lengthy, unexpected vetting process, culminating in a fourth draft.  One particular section of the fourth draft set the green building world on fire: 

New credit for avoidance of chemicals of concern – this credit encourages LEED project teams to specify materials that do not contain chemicals that are known to negatively impact human health (specifically in regards to cancer and reproductive toxicity).

New credit for Environmental Product Declarations - The new EPD credit encourages product manufacturers to engage in disclosure activities that provide specifiers with consistent and complete information about their products enabling specifiers to make more informed decisions.

The negative reaction to this credit was fast and furious. 

The timing of these lobbying efforts coincided with the GSA's release of a preliminary report  indicating that the Green Globes rating system was better suited for new federal construction.  While the report was not tied to the issue of chemicals in LEED 2012, it provided an opportunity for anti-LEED lobbying to push for a new federal green building rating system. 

With a pending final report from GSA this winter, and massive lobbying efforts against LEED at the federal level, don't be surprised if other rating systems are adopted by federal agencies going forward. 

The Wood Siege

The USGBC has also been stuck in a long standing siege with the wood industry. 

On the one side, you have two allies -- the USGBC and the Forest Stewardship Council (FSC).  The USGBC long ago selected FSC wood as the anointed certification for wood products.  On the other side is the non-FSC timber industry -- those wood providers that can't attain FSC certification.  This side prefers the Sustainable Forestry Initiative (SFI) certification.

In July 2011, it appeared the USGBC was willing to negotiate with SFI.  In a LEED Pilot Credit, the USGBC recognized SFI as one of four wood certifications.  

Then the USGBC shifted its tactics.  In the last version of LEED 2012 that was released this past year, the USGBC declared that "(n)ew wood products must be certified by the Forest Stewardship Council or better." 

The "Wood Wars" has left the USGBC bloodied.  In 2011, Congress passed a Department of Defense Reauthorization bill that effectively banned LEED Gold or Platinum certification.  One Senator indicated the LEED ban was in response to the USGBC's failure to adopt non-FSC wood certification. 

USGBC Retreats on LEED 2012

As the two battles on chemicals and wood have raged, the unthinkable happened: the USGBC had to retreat on its latest proposed version of its rating system, LEED 2012, before putting it up for a vote.  I had been tweeting for a number of weeks that things were looking grim for LEED 2012.  If you want to follow the drama, I highly recommend perusing the commentary at the LEED User forum.  

It's hard not to draw a correlation between the chemical industry's negative reaction to LEED 2012 and the USGBC's decision to pull it back.  USGBC CEO Rick Fedrizzi addressed this issue in an open letter to USGBC members:  "To be clear… this change is 100% in response to helping our stakeholders fully understand and embrace this next big step."  

Who Will Win the War?  

This winter, many decisions will be made that will determine the fate of the USGBC for years to come.

  • Will the next proposed version of the LEED rating system include similar Chemicals of Concern and FSC-only credits? 
  • What will be the GSA's final recommendations regarding green building rating systems? 
  • How will the presidential and congressional elections impact green building policy? 

I hope everyone is ready for a long, interesting winter. 

GSA Stimulus Bids Far Lower Than Expected

I have previously speculated that stimulus green building projects will be at risk of underbidding.  Now we have real evidence.  Remember the $5.5 billion that the General Services Administration received from the stimulus to fund green building construction and retrofits?

"Bids came in far lower than we expected, but the upside is that because of that, we have been able to fund more projects," said Paul Prouty, acting administrator for the General Services Administration.

You may recall that the GSA requires that all new construction projects achieve LEED certification and prefers that its projects achieve LEED Silver certification.  With the fierce competition for GSA projects, you can bet that the winning bids will include LEED Silver certification promises. 

Underbidding these GSA projects with promises of LEED certification is bound to lead to problems.  Underbidding makes it more difficult to deal with changes to the design and construction.  Underbidding makes it more difficult for contractors to deal with changes in design and construction plans:

[Paul Shaughnessy, president of BSI Constructors in St. Louis] warned that some contractors are bidding so low they could find themselves unable to cover even the slightest unexpected construction costs.

"The risky side is you're seeing some very thinly capitalized companies making low bids out of desperation," he said. "Their bids are so thin that should something go wrong, they would have very little capital to fix things."

Simply put, the stage is set for LEEDigation.   

Photo:  Our Hero