LEED Certification Conspiracy Scam Exposed! Three Things to Consider before Pursuing LEED

LEED bashing seems to be very fashionable today.It is inevitable, and predictable, that once a company or organization achieves a certain size and influence it attracts more criticism.Indeed, LEED is getting its fair share.

Much of the recent criticism of LEED is rooted in a class action lawsuit brought against the U.S. Green Building Council by Mr. Henry Gifford, a New York mechanical contractor we first wrote about here in 2008. Mr. Gifford raised questions about the energy efficiency claims of LEED certified buildings and USGBC’s methods for making those claims.Perhaps because of his high profile lawsuit, now more often than ever before, I see articles with over-generalized, inflammatory titles like “The LEED Conspiracy” or “LEED exposed!” or “LEED is a Scam!” that go on to say that LEED buildings don’t deliver and/or that non-LEED buildings are just as efficient (or more efficient) than their LEED certified counterparts.

Everyone needs to calm down… To me this rhetoric boils down to a lack of appreciation for what LEED is and what the systems are intended to do. Let’s be specific, even if we’re being vague… The fact of the matter is that every building is different and that building green is a complex process involving many trade-offs and potential conflicts… One LEED certified, silver, gold, or platinum building is not the same as another, nor is one non-LEED building the same as another non-LEED building.

Indeed, I would submit that the entire Gifford lawsuit stems from the following single sentence in a 2008 NBI study that USGBC touted as proof of LEED’s value:

“For all 121 LEED buildings, the median measured Energy Use Intensity (EUI) was 69 kBtu/sf, 24% below (better than) the CBECS national average for all commercial building stock. Comparisons by building activity type showed similar relationships. For offices, the single most common type, LEED EUIs averaged 33% below CBECS.”

This sentence, because it compares median to mean numbers (an apples to oranges comparison), so pissed Mr. Gifford off that he couldn’t keep himself from suing just to call out the lack of care when making such sweeping claims.

While it’s ridiculous to claim “LEED is not sustainable” or “LEED is crap” as I’ve seen some people write, it’s equally silly to say, as USGBC has learned in the past, that “LEED buildings are more efficient than non LEED buildings”, without being incredibly specific.

Every building and its systems and parts needs to be evaluated individually and considered on its own. Some LEED buildings will perform and others may not… Building efficiency is an iterative constantly changing concept and inevitably conflicts and tradeoffs bubble to the surface that may not have been properly addressed or that lead to poor performance.

The following are three tradeoffs that may lead to unintended consequences in LEED projects:

Daylighting: Daylighting and increased glazing (i.e. windows vs. walls) is proven to save energy by reducing the amount of artificial light that must be produced by electricity. It also can increase employee productivity. It’s a fact, however, that windows do not insulate as well as walls, which can reduce efficiency, unless additional steps are taken (such as adding low-e window films to windows) to offset a high window to wall ratio. As such, buildings with lots of windows may use more energy than buildings with fewer windows.

Occupancy rates: Buildings that are newer and/or well-designed may have higher occupancy rates and/or longer operating hours than outdated buildings that are not well designed. LEED buildings are all required to be designed with Indoor Environmental Quality aspects applied to them, which are aimed at increasing occupant well-being and improving productivity. Some LEED IEQ credits require increased mechanical conditioning of outdoor air… the more occupants in a building, the greater amount of Co2 in a building, demanding more fresh air. Obviously, all else being equal, a building that has a higher occupancy rate than another will use more energy and electricity as those things will increase along with the number of occupants in that building and the number of hours that those employees are working.

Natural vs. Mechanical Ventilation and Indoor Comfort: Natural ventilation provides a high level of indoor comfort and is very energy efficient because power sources are not required to operate natural ventilation systems. However, with the new glass facade designs preferred by many architects, operable windows are not made available. This requires powerful mechanical HVAC systems to maintain indoor comfort to ASHRAE levels required by LEED. While the light levels indoors may be greater thanks to increased glazing, greater reliance on mechanical systems can lead to increased energy usage, even if occupants are more comfortable (and productive) as a result. Conversely, older buildings may not provide the same level of indoor environmental quality and natural light, but offer some operable windows.

What are the impacts of these small differences on occupant comfort, productivity and performance? The answer is it depends on the particular building, its occupants and their behavior in the building.

IMHO, LEED is an excellent system not only for understanding sustainability, but also for evaluating and applying the concepts of sustainability to buildings. More importantly, it is a system that will continue to evolve and improve over time… that’s the beauty of LEED!

 

LEED Green Associate – The Green Building Industry is one of the fastest growing industries in America. To learn more about becoming a LEED Green Associate and take our free practice test, visit Green-Buildings.com

 

Aircraft Certification

Aircraft modification

The move now is for aircraft maintenance organisations who have traditionally carried out aircraft modification to STC to seek from the FAA what they term Organisation Designation Approval ODA. After approval, the company receives Supplemental Type Certificate (STC) Organization Designation Authorization (ODA). This designation enables a company to approve design data, tests, and analysis and allows the company to sign an STC on behalf of the Federal Aviation Administration (FAA) for aircraft alterations. In practice, it is a means of self-certifying their own work.

As part of this ODA, a company uses a team of experienced engineers, pilots and other aero industry professionals to provide design and certification services. They can then issue STCs for alterations and modifications on a broad range of aerospace products. These include complete aircraft interiors, aero engine retrofits, airframe modifications, cabin in flight entertainment systems, glass cockpits and other major avionics upgrades.

The benefit to the operator of the aircraft is that of saving downtime, because STC certification can now be delivered so much quicker, in from 45 to 60 days. The new ODA is not tied to an FAA Repair Station, and certification work can be done on aircraft in approved facilities anywhere around the world.

EASA Part M CAMO

This is echoed by a similar approach in Europe where an EASA Part M continuing airworthiness management organisation CAMO can certify from general aviation through corporate aircraft maintenance to large aircraft and airline fleet requirements. An approved company under EASA Part M Subpart G Continuing Airworthiness Management Organisation (CAMO) gets its approval through their national aviation authority, in the UK, CAA. This approval permits an organisation to manage the continuing airworthiness of EASA aircraft ranging from GA through to large aircraft. This work can be carried out independently or through sub-contract support. The CAMO approval includes Airworthiness Review Certificate (ARC / Subpart I) privileges and the ability to indirectly approve aircraft maintenance programmes and amendments for customers on behalf of the UK CAA.

Supplemental Type Certificates STCs

Supplemental Type Certificates (STCs) are documents issued by the Federal Aviation Administration approving a product (aircraft, engine, or propeller) modification. The STC defines the product design change, states how the modification affects the existing type design, and lists serial number effectivity. It also identifies the certification basis listing specific regulatory compliance for the design change. Information contained in the certification basis is helpful for those applicants proposing subsequent product modifications and evaluating certification basis compatibility with other STC modifications.

The FAA denies its new Organisation Designation Approval ODA, could compromise safety standards, but claims the new self-certification process will transform how aircraft interior companies and even aircraft manufacturers like Cessna, Gulfstream and Boeing, go ahout the all-important business of making sure their products and processes are safe.

Although the FAA set up the self-certification programme in 2006, ODA is not an easy thing to obtain. The successful applicant is acting as the FAAs agent, on behalf of the FAA, to issue type certificates and to certify everything from seats, galleys, lavatories and in flight entertainment systems to production, aircraft design and even airworthiness. Gulfstream was the first aircraft manufacturer to win ODA authority. It is seen as a logical step on from existing organisational delegation programmes, optimising those existing programmes. Sometimes, aircraft modification will require structural strengthening of the cabin floor. Engineering teams must design the new configuration and carry out stress and flammability testing of everything that will go on the aircraft, ensuring, for example, that the seats meet the latest 16g requirements and the lavatories meet 9g requirements. As the overall interiors integrator, a company with ODA brings in all the other suppliers, from the seat maker to the IFE provider.

In the past, all the data involving the installation process of a new aircraft interior would have to be submitted in stages to the FAA for approval. The FAA has managed this process by using Designated Airworthiness Representatives DARs and Designated Engineering Representatives DERs. These inspectors. appointed by the FAA, may be employees of the company or outside contractors, but they represent the ears and eyes of the FAA Within that company. These representatives of the FAA have the authority to certify particular items and processes as safe on behalf of the agency. Former in-house inspectors are now part of an ODA organisation, and instead of the FAA signing off on the data, its all done in-house.

Under the old FAA-managed system delays were common and estimates of when the interiors work might be accomplished or when the customer would be able to return an aircraft to service a stumbling block. An eight-week reduction in a modification project and a week to 10 days in issuing the STC is a significant saving. From an operator’s point of view, the contractor is also more accountable.

Equally, for someone in the FAA to go out and inspect a Boeing brake system, for example, when Boeing could do it themselves is in many ways not logical. In practice, operating as a DOA, Boeing could have more FAA audits and more supervisory visits on a recurring basis than ever before.

aviation-database.com has lots of resources for the aircraft industry. The web is a vast source of information. Aviation-database collects the industry into one huge database of contacts.