HALAA Final Memo-LEED

To: White House Liaison Reginald H. Cordozo
From: HALAA Sustainability Consulting Agency
Re: National Adoption of LEED Certification System
Date: December 4, 2013
Introduction:
Going green has become a new revolution in America. Everyone from business
corporations to the everyday citizens have begun to participate in the movement. One of the
forerunners in this “green” revolution is LEED, or Leadership in Energy and Environmental
Design, which is green building certification system created by the U.S. Green Building Council.
LEED has standards to certify residential, commercial, and industrial buildings and can therefore
be applied to many situations.
When approaching LEED from a policy standpoint there are several issues to be solved.
Should the federal government adopt LEED as its standard for green buildings or should LEED
be kept as a separate entity to encourage competition and growth in the green building industry
in the future? LEED has many positive aspects that include standardizing green buildings across
the country as well as defining what it means to be green. LEED buildings utilize many green
building tools to help improve the quality of the lives of those who reside and work in these
buildings. However, LEED faces several problems that require attention in order for it to become
a more successful program. Green washing has arisen as a huge issue in the corporate world;
LEED has become another way to convince consumers that a company is “green” without
putting in true effort to being more eco-friendly.
In order to be a successful policy, several things must be adjusted. It must be ensured that
certified buildings are putting forth genuine effort to become eco-friendly and not just doing the
bare minimum regarding building regulations. This paper will propose several policy suggestions
to remedy these issues, the most important of these suggestions being a longer time period prior
to building certification. This time will be used to determine whether LEED buildings are saving
energy once they are actually in operation and using more repurposed materials in the
construction process. Also, stricter requirements will be suggested for the five certification
categories that LEED has already developed.
Overview:
LEED is an acronym for Leadership in Energy & Environmental Design and it is a Green
Building Rating System designed by the U.S. Green Building Council. According to their
website, “the U.S. Green Building Council (USGBC) is a nonprofit organization committed to a
prosperous and sustainable future for our nation through cost-efficient and energy-saving green
buildings.”1 The USGBC’s History section of their website stated that it was established in
1993 by Rick Fedrizzi, David Gottfried and Mike Italiano. The LEED program came into being
in March 2000, and has since then established itself as the leading green building certification
system in the U.S. The LEED program rewards residential, institutional, and commercial
1 U.S. Green BuildingCouncil.(2013). PurposeStatement. Retrieved from http://www.usgbc.org/

building projects around the U.S. and abroad for various environmental and health performance
levels that go above and beyond the norm in building standards in reference to their
sustainability.2 A building can obtain credits for innovations such as water efficiency, material
and resource use, and indoor environmental quality, among others. If a building accrues enough
credits, these can amount to four different levels of certification: Certified, Silver, Gold, and
Platinum.
Our policy suggestion is in reference to the new governmental recommendation that
LEED become a federal program, which would put it under the same umbrella as it’s only
current competition, the EPA’s Energy Star Program.
ResearchMethods:
We at HAALA used various resources in creating our policy memo. We utilized a
number of peer-reviewed journal articles, many government, non-governmental organization,
and non-profit websites, and a few news articles (mostly online), as our resources. For our
fieldwork, we conducted two interviews.
The first interview was a phone interview with Professor Tom Carter, who is a New
Century College faculty member at George Mason University, and teaches the Smart Growth
course, as well as the courses Environmental Justice, and Environmental Law and Policy.
Professor Carter earned a Bachelor of Science in Business Administration and a Juris Doctor
from the University of North Carolina. He has worked as an executive for clean energy and
green construction companies, and is an expert in state, federal, and international governmental
affairs with a focus on environmental policy and regulation. 3 Professor Carter worked with
LEED first-hand when he worked for Colera, a concrete company that employed the tool of
biomimicry to make concrete that instead of creating carbon pollution, actually sequestered
carbon dioxide and cleaned the air.4 We consulted Professor Carter in order to gain some insider
insight from someone who has not only worked with LEED professionally, but has a background
in policy making. We used information gathered in this interview in crafting the policy
suggestions, especially the second suggestion entitled Long Term Investment in the Certification
Process. We also used that information in the section titled Positive Effects on Sustainable
Design, and in the Greenwashing section.
The second interview was conducted in person at the EPA headquarters in Washington
D.C. with Ed Fendley. Fendley has worked within the US government for over 25 years, during
which time he has specialized in environmental policy with a focus on global climate change. He
advised President Barack Obama and other senior White House officials on the 2009
Copenhagen Climate Conference as the White National Security Staff Director for
Environmental Affairs. He also worked as a policy advisor and climate change negotiator for the
US Department of State handling affairs within the UN Framework Convention on Climate
2 USGBC. (2013). History. Retrieved from http://www.usgbc.org/about/history
3 Carter, Thomas B. (2013).GMU Faculty and Staff. Retrieved from http://ncc.gmu.edu/people/tcarte14
4 Carter, Thomas B. (2013,Nov. 20). [Interview by Aileen Dierigand Ashley Strobridge].

Change. At the EPA’s Office of Smart Growth, Fendley currently promotes sustainable
development within American communities as the Policy Advisor and Program Manager in the
Office of Sustainable Communities.5 We chose to interview Fendley because of his extensive
experience with policy-making in the realm of environmental issues, and due to his department’s
close associations with LEED. We used information gathered in this interview within the section
entitled Positive Effects of Sustainable Design, and broadly within our policy recommendation.
Positive Effect on Sustainable Design:
The LEED certification process standardizes what it means to be green. It advertises how
creating a sustainable building can be economically beneficial, for example in the cost reduction
of heating and cooling. The reduction of water consumption is also standardized by the LEED
certification process, which will assist in reserving water for future generations. Through LEED,
indoor air quality is improved, creating better air quality for the tenants, which not only upgrades
the quality of the environment but the quality of living. The materials used to construct the
buildings are more sustainable, such as repurposed and recycled materials. With the LEED
certification, there is an incentive for innovation. It creates an ideal for sustainable design,
creating a market for being environmentally friendly.
These positive effects on sustainable design create a positive environmental impact, and
the sustainable operation of the building will have a beneficial economic impact. Engineer Jeff
Ihnen states in his research study, “Initial land and construction costs account for only 2% of a
20-year life-cycle cost of a building. Combine a 2% green premium on 2% of the life cycle cost
of a building, and LEED® costs a tiny, almost insignificant 0.04% of the life cycle cost of a
building.” 6 None of these achievements could be possible without the LEED certification
process in effect. It is an efficient procedure that is necessary in order to create a starting point
for the design industry. In our interview with Tom Carter, he said that at first the builders didn’t
want to be green, but now the builders know LEED is good for industry because of things like
the need for LEED upgrades and construction of LEED buildings that generate more work for
them. Also, owners of the buildings can charge more for rent for apartments in LEED buildings.7
These are key economic benefits that are associated with LEED. To build on that statement, Ed
Fendley commented that there are marketing benefits to having a LEED Certified building in a
green location, such as business improvements for district, including the ones listed above, as
well as just a generally renewed interest in the area where the green building is, which draws in
new businesses to the area. This in turn leads to neighborhood efforts to encourage green
buildings, as well as business policies to encourage green buildings and these things are not only
good for business, but good for the environment as well.8 Finally, the LEED certification process
5 Bren School of Environmental Science and Management, University of CA, Santa Barbara.(2010). Events and
Media. In A Community Colloquium. Retrieved from http://www.bren.ucsb.edu/events/ed_fendley.htm
6 Ihnen, Jeff. (2013).LEED: Added Cost or Sound Investment? Michael’s Engineering. Retrieved from
https://www.lorman.com/newsletters/article.php?article_id=792&newsletter_id=174&category_id=3
8 Fendley, Ed. (2013,Nov. 20). [Interview by Aileen Dierigand Ashley Strobridge].

creates a universal standard for sustainable design, and is useful for when comparing sustainable
design principles.
Green-washing:
Green-washing→ “disinformation disseminated by an organization so as to present an
environmentally responsible public image.”9
As a result of the growing sustainability movement, “going green” has become a major
tactic that many corporations and organizations are using to build their desired reputation.
Naturally, then, LEED has become a pawn in this game of publicity. “Green-washing” is the
presentation of a company or an organization that makes it appear eco-friendly. This projected
image is more often than not a false representation of the institution’s practices; green-washing is
often used to be misleading of the company’s products or missions.
A program like LEED, which is a public acknowledgment for making efforts to be
environmentally friendly, greatly appeals to a wide range of corporations. The recognition is
rewarding in that they will gain potential customers that are more inclined to support them
because of the fact that one or two of their buildings are LEED certified. Making a business more
ecologically compatible has become so commonplace in the market that businesses are
practically forced to go green in order to keep up with their business rivals.10 There are also tax
incentives for LEED that drive this rush to get qualified. The competition to gain the
certification—basically a golden ticket to eco-consumer support—has led to the depreciation of
the value of LEED. Industries are taking shortcuts in order to receive the credit without
expending themselves too much.
Because of the fervently sought domination of this ever-growing sector of consumers,
businesses are looking for the easiest way to obtain their goal of getting the LEED certification
stamped onto their buildings. And because LEED is comprised of a points system, this isn’t hard
to do. Companies are finding that implementing the cheapest, easiest sustainable materials and
functions can still earn then the same amount of LEED points. In our interview with Tom Carter,
he was asked the question, “USA Today did a case study on industrial buildings that are LEED
certified. They found that many of the companies that are in charge of constructing these
buildings have learned how to work the system to their advantage, using only the cheapest and
easiest building methods to gain points. How would you suggest addressing this issue?” He
replied that it was his “...number one complaint about LEED.” 11 Taking advantage of the points
system defeats and cheapens LEED, and it is a huge problem that LEED is currently facing.
While examining a recently opened hotel during a LEED case study that USA Today
conducted, they found that many of the features for which the hotel gained LEED points
“required no work at all.” These included being located in a densely populated and accessible by
9 Definition of greenwash in English.(n.d.). Greenwash: definition of greenwash in Oxford dictionary. Retrieved
from http://www.oxforddictionaries.com/us/definition/american_english/greenwash?q=greenwash
10 Recent Posts.(n.d.). Energy Corps at Cornell University. Retrieved November 28, 2013,from
http://www.rso.cornell.edu/energycorps/index.php/leed-certification-and-greenwashing/

public transit. They also earned points for using cement and steel because they are categorized as
recycled material.12 In our interview with Tom Carter, he concurred with this sentiment, saying,
“A lot is determined by the manufacturing of the materials used. If you use a drywall that is
recycled, you get a lot of points, but it doesn’t affect the efficiency of the running of the
buildings. LEED is great at measuring how greenly a building is built; it is not as good at
measuring how greenly a building operates. This makes it easier for builders to game the
system.”13 Unfortunately, when the businesses only do the bare minimum, their impact on energy
and the environment barely changes.
Energy Models and Reality:
Along with using only the easiest and cheapest qualifications, the discrepancy between
predicted energy savings and the actual outcome can be explained by the fact that certifications
are awarded during the planning period of the building. Therefore, the models that are used to
calculate the energy that the building will use are strictly predictive. Until put into practice, there
is no possible way to forecast every single influence that will go into running a building. When
LEED certified buildings are based on theories that are not tested out, there are bound to be
issues with the performance of LEED buildings.
The Green Building Council hired physicist from Oberlin College, John Scofield, to
calculate energy use in LEED buildings compared to buildings that do not use LEED. Scofield
was expected to show that LEED buildings conserve energy. The general conclusion that he was
given was that LEED buildings use 25-30% less energy than normal buildings. When analyzing
the data for himself, he found that primary energy use was actually no different between normal
buildings and LEED buildings.14 This can be explained by the shortcuts being taken and the fact
that practices are being implemented before they are proven successful.
Policy Suggestion:
The current application of LEED Certification falls short on the promise USGBC
proposes for sustainable design. However, there are achievable policy changes that could make
LEED a desirable national standard to adopt.
In short, LEED needs to adopt the four following policy changes:
1. Stricter requirements for certification
2. Long-term Investment in the Certification Process
3. Specialized Certifications
12 Schnaars,Christopher and Hannah Morgan.(2013, June 13). In U.S. BuildingIndustry,Is Ittoo Easy to Be Green?
USA Today. Retrieved from http://www.usatoday.com/story/news/nation/2012/10/24/green-building-leed-
certification/1650517/
14 Schnaars,Christopher and Hannah Morgan.(2013, June 13). In U.S. BuildingIndustry,Is Ittoo Easy to Be Green?
USA Today. Retrieved from http://www.usatoday.com/story/news/nation/2012/10/24/green-building-leed-
certification/1650517/

4. Specified Incentives for Program Participants.
As technologies grow more accessible and affordable for construction companies, so
must the standards for sustainable design adjust. The best and simplest suggestion for USGBC is
for it to hold its applicants to stricter standards for each of its five main categories.15 By making
the qualifications more competitive and challenging the LEED buildings will not only be of
higher value, but operate with greater efficiency. However those measures alone will not result
in a positive policy effects.
The involvement with LEED, although positive for construction companies and building
owners, has produced dubious results on efficiency in the long-run.16 Long-term standards
should be implemented on top of the LEED Maintenance requirement. An initial construction
certification following the stricter metrics of qualifications can be given to buildings pursuing
certification, but full certification and subsequent tax-benefits should only be given after a 3-5
year progress report has been analyzed. In that way, the LEED certified buildings will be
sustainable in design conception and in daily use.
Along the same vein of a tiered certification process, LEED and US Tax Commission
could adopt a program of tiered tax alleviation. With this program, the farther along the
certification process the building is, the greater tax break they would receive; the building’s
owners would only achieve the full benefit of the tax break until the five year checkup.
The LEED certification system should continue the specifications it uses to distinguish
type of buildings as well as the credit categories, however the tendencies for clients to
accumulate easy credits within each category for accreditation remains an issue. Raising the
minimum requirements as well as offering specific certification for specialty buildings would
remedy the free rider issue. If USGBC offered Specialized Certifications such as “Platinum
Certified; Concentration in Recycled Building Materials” and others like it, it would not only
bring more buildings into the program, but it would also incentivize companies to achieve higher
standards by encouraging companies to acquire each type of certification for their buildings. The
title certification given is a hypothetical example of how USGBC could capture a broader market
base by expanding their certification system.
As the USGBC is a non-profit, private organization that in many ways directly competes
with the EPA’s Energy Star program, there are some strategic advantages to both appropriating
the LEED and to working with USGBC as a separate entity. USGBC and Energy Star, if kept as
separate certification organizations, will keep each other competitive, which will perpetuate
positive action in sustainable design. In the same vein, transitioning LEED certification into a
public entity would stagnate performance of the buildings due to lack of competition. The
instituting of LEED as a federal certification program would also cause duplicitous spending, as
Energy Star is already underway. Therefore, it cannot be recommended that LEED be annexed
into a federal program, even if the recommended policy alterations are incorporated and proven
15 USGBC. (n.d.). Leed rating system . Retrieved from http://www.usgbc.org/leed/rating-systems
16 Keith, D. W. (2011). LEED, Energy Savings,and Carbon Abatement; Related but Not Synonymous. Environmental
Science and Technology, (45), 1757-1759.Retrieved from
http://pubs.acs.org.mutex.gmu.edu/doi/ipdf/10.1021/es1041332

successful. The sustainable construction industry will achieve greater prosperity if LEED
remains private, but in close cooperation with the EPA. Likewise, Energy Star will not suffer
from the competition, but rather be regarded as the cornerstone standard for all other companies.
Conclusion:
We advise the federal government to not adopt LEED as a standard for green building. The main
reason for this is the amount of policy adaptation that would be needed for it to be successfully
enacted. The USGBC would need to develop a stricter certification system within LEED in order
to increase building efficiency. This would include delaying full building certification and tax
benefits over a 3-5 year wait period to ensure that each building operates as regulations require.
USGBC would also need to raise credit requirements for certification to rid the system of green
washers. Competition is also an important aspect in this discussion. If the federal government
adopted LEED as a standard it would reduce competition within the already limited market of
green building certifiers with the only other major competitor being the EPA’s Energy Star
program. In order for these programs to grow, develop, and improve their buildings, competition
is needed as a motivator. In the near future, it would be advisory to avoid adopting LEED into a
federal program. While LEED does contain many positive aspects for the economy and the
environment, there are many improvements to be made. Until these weaknesses are addressed
and strengthened, LEED should remain within the USGBC. Sustainable development and design
is relatively new to the market and therefore has room to grow in the future.

HALAA Final Memo-LEED

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