Let's Just KISS: The LEED 6th Public Comment Period
Bill Walsh - March 26, 2013
The KISS principle (Keep It Simple Stupid) is one of the fundamental design principles of the industrial age. It holds that simple systems generally work more effectively than complex systems, and therefore, unnecessary complexity should be avoided in good design. The latest version of the LEED Material Ingredients Credit (MRc4) kisses this notion goodbye. At the behest of the chemical industry, the USGBC has taken a credit that would reward meaningful chemical disclosure and avoidance in building products and embellished it with complex documentation pathways, opt-out options, and an inscrutable “supply chain” option. These turn the intent of the credit on its head, by effectively rewarding the status quo. Taken together, they make the new credit unattractive to design teams who have been pleading for less complexity in LEED V4, and create a launch pad for new greenwash initiatives.
My colleague, Tom Lent, has prepared a comprehensive analysis of the new language along with recommendations for improving the credit. Please consider these when submitting your comments by March 31st. Consider too an example from LEED’s history of how a simple, straightforward credit can both improve occupant health and impact the supply chain.
One of the most successful LEED chemical reduction credits dates back to the very beginning: a credit for use of composite wood products with no added urea formaldehyde. The credit helped catalyze market demand for a range of formaldehyde-free products, undermining the standard industry arguments that healthier building materials cost too much and won't be accepted by consumers.
The LEED formaldehyde-free credit was clear and straightforward and never diluted by poison pills from the chemical industry. This is significant because the market's favorable response to LEED's formaldehyde-free credit laid the groundwork for new formaldehyde regulations by the California Air Resources Board (CARB). Industry trade associations fought against the CARB regulations. Reinforced by the LEED-inspired market support for their products, however, one composite wood manufacturer and several cabinet makers bucked their trade associations and joined HBN in a campaign with health care professionals and organizations, California cities and ordinary citizens to tip the balance, reinforcing the CARB to pass a strong regulation. That regulation has since been incorporated into federal law. Strong, clear LEED standards transform markets and protect health far beyond the green building footprint.
MDF / Particleboard Trends
Graph by J. Vallette / Healthy Building Network.
MDF/Particleboard production and formaldehyde emission rates indexed to the year 2005.
The results are impressive, to say the least. Based on data for eighteen MDF and particleboard plants, formaldehyde emissions from manufacturing facilities declined by over eighty percent between 2005 and 2010.
This experience shows that we know how to create effective LEED credits that reduce the use of hazardous chemicals in building products. We should learn from these and strive to replicate this success. The latest proposals in LEED v4 KISS it goodbye.
For more information & discussion & to comment:
You may read the actual credit language on the LEED website at: http://new.usgbc.org/node/2616399
Links to submit comments are on that page as well. You do not need to be a USGBC member to comment.
More discussions of this credit can be seen at http://www.leeduser.com/blogs/sixth-comment-period-leed-v4-wont-delay-member-ballot and http://www.leeduser.com/blogs/usgbc-engages-chemical-supply-chain-new-leed-v4-option
 MDF/particleboard production rates based on FAO Complete Database on Forest Products Production and Trade. Formaldehyde emissions rates obtained via US EPA Toxics Release Inventory data for sample set of eighteen MDF/particleboard plants.
This analysis shows that most of the decline in formaldehyde emissions since 2005 is attributable to factors other than declining production. In 2010, formaldehyde emissions from the facilities studied were about 20% of the 2005 levels, while production was at 70% of 2005 values. Therefore, we can reasonably estimate that non-production related factors caused formaldehyde emissions from MDF and particleboard manufacturers to drop by 50% from 2005 to 2010. For the 18 plants we surveyed, this amounts to an estimated 600,000 fewer pounds per year of formaldehyde air emissions.
The California Air Resources Board (CARB) signaled its interest in regulating formaldehyde in composite wood products with a report in 2005, and started formal hearings in 2006. In 2007, CARB approved a mandate to reduce formaldehyde emissions from all composite wood products made or sold in the state. CARB Phase 1 became effective in 2009. Phase 2, which dropped allowed emissions even lower, became effective in 2011 for particleboard and MDF.