Review of LEED v4.1 draft EPD creditsA valiant attempt with serious casting flaws - and how to fix them
LEED v4.1 draft EPD credits – what’s changed and what needs to changeEdited April 2019 to reflect that a number of US EPDs include statement of critical review on the cover leaf (though no mention of ISO 14071 compliance of reviewer). LEED v4.1 introduces a number of changes which make materials credits more accessible for projects. One particular focus area of the updates are the material credits. This is our take on the changes introduced to the EPD credits, being MR credit 2: Building Product Disclosure and Optimization – Environmental Product Declarations – Option 1. Environmental Product Declaration, and Option 2. Multi-Attribute Optimization. They are defined identically in BD+C and ID+C manuals. This review is as much a review of the text to date, as a how-to guide for fixing the credits, and it follows our earlier review of the MRc1 Building Life-Cycle Impact Reduction credit. The review is based on the text as written and does not prejudge on intentions. One purpose of this review is to highlight a potential mismatch between intentions and the actual language to allow adjusting the latter for the final version v4.1 Considering these supposedly minor version updates impact significantly all manufacturers and consultants, we chose to publish our analysis on the credits.
Overview of the changesThe draft lowers the thresholds for the credit achievement, which is a benefit for most projects. At the same time, changes in Option 1 invalidate most product-specific EPDs on the market today (excluding some US-based ones) and generates substantial workload for consultants who will have to perform to do critical reviews on already verified EPDs. This is easily fixed by reverting the problematic definition back to LEED v4 text. The text for industry-average EPDs was not changed, so those are not adversely affected by v4.1. The changes in the Option 2 multi-attribute optimization are generally positive. Yet, some improvement is clearly needed to ensure plants and comparisons are relevant for the purpose and the entire process does not fall prey to paper pushing. When every document requires a critical review or a third-party verification, a consideration for the actual benefit needs rigorous analysis. Outside these credits, healthcare projects now have the option to use EPDs as one of the options for MR credit Furniture and Medical Furnishings.
MRc2: Environmental product declarations – changes in Option 1, EPDsSummary of changes:
- Core and Shell, Warehouses & Distribution Centers are able to get the credit with 10 permanently installed products with EPDs from 3 suppliers. Other project types still need 20 permanently installed products with EPDs from 5 suppliers.
- All types of LCAs and EPDs count as ‘one product’ for the purposes of this credit, except the last category that counts as 1,5 products.
- Credit language introduces non-typical market practices such as ‘external critical review’ and ‘internally critically reviewed LCA in accordance with ISO 14071’ for product-specific EPDs.
|Remains the same between v4 and v4.1||Product-specific Type III EPD. Environmental Product Declarations which conform to ISO 14025, 14040, 14044, and EN 15804 or ISO 21930 and have at least a cradle to gate scope.|
|LEED v4 – product-specific||Products with third-party certification (Type III), including external verification in which the manufacturer is explicitly recognized as the participant by the program operator.|
|V4.1 draft, internally reviewed||Product-specific Type III EPD — Internally Reviewed. Products with an internally critically reviewed LCA in accordance with ISO 14071.|
|V4.1. draft, external critical review||Products with third-party certification (Type III), including external verification and external critical review in which the manufacturer is explicitly recognized as the participant by the program operator.|
LEED v4.1 Building Design and Construction DraftWe also took the liberty to give our indicative estimate for the number of product-specific EPDs complying below. We have sent requests for detailed figures to some of the larger construction product manufacturers and will update the article based on the responses in the very near future.
|Requirement||Estimated share of product-specific EPDs complying||Basis of the estimate|
|v4 “external verification”||Over 95 %, nearly all||All EPD programs require verification, and almost all require it to be external. This can be easily seen on the reviewer signature, visible on the EPD itself.|
|v4.1 “internally critically reviewed LCA in accordance with ISO 14071.“||None at all||The EPD process, as set out in ISO 14025, is based on independent verification. This makes other reviews needless. No critical reviews have been done as per ISO 14071.|
|v4.1 “external critical review”||Below 1 %||As stated above, the independent verification is the norm, so further critical reviews are very, very rare.|
Consequences, and how to fix themThere are two approaches to fix this. Manufacturers can start to write up internal critical reviews, or more likely, as they’re short of specialist staff, they contract the jobs to consultants or become ineligible. Boon to some, paperwork to many, no environmental benefits of any kind achieved. It could also be worked around by adding a statement of such critical review on the cover leaf of EPDs. Or USGBC could fix the manual text. The way it was written in LEED v4 is fine: external verification. This is the industry norm. The changes are very simple, too – revert the text back to LEED v4.
|LEED v4 text||Current v4.1 text||Fixed v4.1. text|
|Product-specific Type III EPD — Products with third-party certification (Type III), including external verification in which the manufacturer is explicitly recognized as the participant by the program operator.||Product-specific Type III EPD — Internally Reviewed. Products with an internally critically reviewed LCA in accordance with ISO 14071.||Product-specific Type III EPD — Products with third-party certification (Type III), including external verification in which the manufacturer is explicitly recognized as the participant by the program operator.|
MRc2: Environmental product declarations – changes in Option 2, Multi-attribute optimizationIn this credit the following changes were introduced:
- Multi-attribute optimization threshold is lowered to 10 % of the cost of permanently installed products in the building (from former 50%), or alternatively use at least 10 qualifying products from at least three different manufacturers.
- Multi-attribute optimization can now be shown using life-cycle impact reduction action plan (value is halved) or life-cycle impact reductions in embodied carbon, or several categories.
- The life-cycle impact reduction approach requires demonstrating how the reductions were achieved and showing the performance with third-party verified published comparisons. The weigh of a product showing improvement can be increased with more reductions.
- There is no longer a cap on how much structure and enclosure can contribute to this.
LEED v4.1 Building Design and Construction Draft
Changes needed in Option 2, Multi-attribute optimization – avoid paper-pushing exerciseWhile Option 2 is generally an improvement over the v4, several improvements are still needed. As written today, the credit could be largely accomplished with a paper-pushing exercise. Life Cycle Impact Reduction Action Plan needs the following additions to be an effective measure:
- Impact reduction plans must set a numeric impact reduction target for the global warming potential of the product that is targeted to be achieved during the timeline of the plan.
- Impact reduction plans must not be older than 4 years at the time of specification of the product.
- If the impact reduction plan is updated, the update must also contain targets, achievements, and non-achievements from past plans.
- Critical review is not necessary for the first plan issued by a manufacturer, however, for any updates it is required (this is optional).
- Comparative analysis must not be older than 4 years
- Comparative analysis must be relevant for the region of the project
- Comparative analysis must attempt to include all relevant comparable products for which information is publicly available at the time of comparison
- The published comparisons must be third-party verified, or the comparison must provide all the publicly available data points used in the comparison as EPDs
About the authorPanu Pasanen is the CEO and founder of Bionova, developers of the world leading construction LCA software One Click LCA. He’s consulting regulators, government agencies, standardization bodies, and certification organizations on LCA-based regulations and policies and has authored several studies on the topic, including the Embodied Carbon Review. Presently, he’s involved in International Energy Agency embodied carbon task force, European standardization via CEN/TC 350 and carbon benchmarking via Carbon Heroes program. He supports the Finnish government in the development of embodied carbon regulations and the Norwegian government with carbon reduction software tools. To discuss further: write to firstname.lastname@example.org or call +358 44 2871 722.
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