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Horton Hears an Outcry

July 18, 2012
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“I meant what I said, and I said what I meant. An elephant’s faithful one hundred percent.”
— Horton the elephant, Horton Hatches the Egg, Dr. Suess, 1940

As my children have gotten older, one of things I miss most is reading to them before bedtime. There’s a lot of wisdom to be gained from a Dr. Suess book, and I recently couldn’t help but think about this nugget from Horton, the lovable elephant, while trying to decipher some of the recent activities in the development of green building standards.

Saying what you mean and meaning what you say is always good practice, and bringing together all concerned parties to address any conflict generally closes with successful results. The Adhesive and Sealant Council and its members have, for some time, recognized the importance of providing materials to the building construction industry that will contribute to making buildings of the 21st century “greener” and more energy efficient. We also believe that to accomplish this goal, all parties involved in the process must come together to develop rating systems and standards in a data-driven, performance-based consensus process that is supported by science.

Using an American National Standards Institute (ANSI) process to develop any rating system or standard should seem to be just the right approach. Interestingly, the U.S. Green Building Council (USGBC) is proud to proclaim that it has been accredited as an official Standard Developing Organization by ANSI. It would seem logical that with this accreditation, the USGBC would use the ANSI process when developing revisions to the LEED (Leadership in Energy and Environmental Design) rating system. After all, why spend the time and expense of becoming a standards developing organization if you are not going utilize the process?

Unfortunately, as witnessed this spring in the most recent efforts to revise the LEED 2009 rating system, an ANSI process approach was never in the cards. By the USGBC’s own admission, the LEED 2012 proposal generated more than 18,000 comments, yet I would guess that a handful, if any, of those comments or criticisms have been directly addressed by the NGO. Rather than actually undertaking an ANSI standards development process that calls for explanation and negotiation when confronted with negative comments, it seems the USGBC would rather obfuscate, backfill, or just throw a “Hail Mary pass” in the hope that everyone will just go away and let them get back to saving the planet one green building at a time.

Here’s one example. When LEED 2012 was initially proposed this spring, there was no hint that the USGBC was considering a material credit linked to the de-selection of certain chemicals in products. A second version of the proposal was introduced in March that mysteriously included an Avoidance of Chemicals Concern credit that effectively placed an arbitrary restriction on the use of a wide range of chemicals, including every chemical listed in California’s Prop 65 Rule. Understandably, this generated a groundswell of criticism, so the USGBC shifted gears once again at the 11th hour and incorporated the European Union’s REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) regulations as a benchmark tool for determining whether a chemical should be delisted. The USGBC had never referenced the REACH regulation in the LEED rating system, yet it seemed willing to grab at this last-minute straw in the hope of quelling criticism.

The USGBC has apparently recognized that this approach to standards development has left a lot of those impacted dissatisfied with the results. It recently announced it had renamed the rating system revision (LEED v.4) and delayed the final vote until next year; a fifth revision is due in October. Maybe this time, in getting to that version, the USGBC will try to incorporate the kind of consensus approach that is expected of a real ANSI Standard Developing Organization. I know Horton and I will be watching.

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