The cost for LEED is also reasonable an estimated 2 percent cost premium for silver LEED certification, 4-6 percent for gold and more for platinum (very hard to achieve). If the estimate is accurate that half the cost of LEED certification is USGBC's fee, this is very high compared with other certification programs, where the bulk of the cost is for meeting higher standards. The certification cost should drop by the end of 2009 as more certifiers are accredited. Some of the backlog should also start to get cleared up.
But, as I will show, USGBC's use of the terms "accreditation" and "certification" is mixed up in USGBC announcements. This does not inspire confidence either in USGBC's understanding of the process or in its current compliance with the related international standards. So just two cheers.
New York City Lots of Claims, Few Certificates
The basic problem with the Leadership in Energy and Environmental Design (LEED) program in New York City has been that so many are named but few are certified, making for a long queue. In December 2007, I prepared a Snapshot for the Sallan Foundation on the LEED system, later published on Huffington Post, that was mostly positive.
I congratulated LEED on the growth of its certifications nationally, as of the end of 2007, to 1,129. I noted how much consumers and builders are scrambling to meet LEED standards and LEED's impressive revenue (about $11 million) for USGBC ($40 million revenue in 2007). Also, I praised the USGBC committees that set the LEED standards because they do the job and are continuing to refine the ratings. Although not as stringent as the Architecture 2030 standards, which seek a 50 percent energy saving, the LEED standards can achieve half of that savings or more and, most important, they are easy to understand and presently dominate the marketplace.
The City of New York in 2006 recognized LEED standards by requiring adherence to them for most NYC buildings that cost at least $2 million or more to build or renovate, or for privately owned buildings that get $10 million or more of NYC subsidy. The Mayor's Office of Environmental Coordination did this by adding a new chapter 10 to Title 43 of the Rules of the City of New York.
My main concern about LEED in New York City is the big gap between claims and reality. Billboards give new buildings a boost to their brand by claiming "pursuing LEED gold", but very few certifications have actually been issued, just 15 at the end of 2007 according to the USGBC NYC Chapter website (click on FAQs):
How Long the Pursuit? The Wannabe LEED Gold CRBE Macklowe Building at 510 Madison last week.
The first certification was in 2004, for the Solaire at 20 River Terrace. The Battery Park City Authority had its own green building standards and the Solaire was planned green from the beginning, with all-EnergyStar appliances, wood certified to FSC standards and solar panels that generate 5 percent of its energy. It was therefore a cinch for the Solaire to get certified to LEED Gold in April 2004.
· One in 2005.
· Eight in 2006.
· Six more in 2007 (this list adds up to 16, although the USGBC Chapter website shows 15).
Pursuing LEED Platinum. The Visionaire.
By the end of 2007, 294 NYC buildings were registered with LEED, a ratio of certificates to registrations of one in 20. Clearly, the certification process has not been keeping pace.
UK 100,000 Buildings Certified and Half a Million Being Processed
The green-buildings backlog in New York City may be contrasted with the situation in the UK, where 100,000 buildings have been certified to the Building Research Establishment Environmental Assessment Method ( BREEAM) and more than half a million more are in the registration pipeline. BREEAM won the "Best Program" Award at the 2005 Tokyo World Sustainable Building Conference for having "the most successfully executed program for promoting sustainable practices, and influencing other initiatives, worldwide."
BREEAM from the beginning opened up certification to licensed assessors, which means they are competing for business and their numbers can expand and contract along with demand. The assessors work within a rigorous quality assurance framework. BRE examines organizations that are trained to do the assessments and licenses the ones that are qualified. BREEAM coverage includes courts, EcoHomes, industrial, international, multi-residential, offices, prisons, retail and schools. Headquartered in Watford, BRE is continuing to expand its network of licensed assessors.
The Big News from USGBC
The big USGBC news last week was that as of January 2009 it will concentrate on standard-setting and its sister organization, the Green Building Certification Institute (GBCI), will no longer certify buildings. Instead, GBCI will become de facto an accreditation institution. Since the beginning of 2008, GBCI has administered the LEED Accredited Professional program. To conform to international standards, GBCI should become the Green Building Accreditation Institute (GBAI) and it should be moved up to a status coequal with USGBC comparable with the Forest Stewardship Council and its new Accreditation Services International.
GBCI is effectively becoming an Accreditation Agency in 2009. The problem with USGBC's announcement and chart is that the terms "certification" and "accreditation" are mixed up, leading to a question about its full understanding of the difference between them. On its website, USGBC describes itself as a "third-party" certification body but USGBC is only ANSI-accredited as, and is best described as, a standard-setting body. It was never itself a properly accredited third-party certification body.
International standards are evolving and it is forgivable that USGBC should lag behind this evolution. The ISO/IEC 17011:2004 standard for agencies that accredit conformance assessment bodies, aka certification bodies or certifiers, tightens up the previous ISO Guide 61 language and requirements for accreditation. In a word, it is unacceptable for an accreditation agency to be subordinate to or part of an organization that sets standards or certifies conformance to the standard. This requirement was not so clear before 2004. It is crystal clear now.
USGBC Is a Standard-Setting Body
Since USGBC and LEED ultimately depend for their credibility on compliance with international standards, it's worth getting into the detail. Measurement of anything requires standards, such as units of weight, money and temperature. Ideally an independent group convenes with representation from different stakeholders (e.g., buyers, sellers, government) and definitions of standards are agreed upon.
USGBC is such a standard-setting body. It created the LEED ratings of levels of green buildings (basic certification, silver, gold and platinum), for different types of buildings or groups of buildings. The new plan for outsourcing certification does not affect USGBC's committee-based process for developing LEED standards. USGBC is accredited by the American National Standards Institute (ANSI) as a standards developer and the LEED Accredited Professional program is ANSI-compliant. ANSI is a national member of the International Organization for Standardization, ISO, a network of national standards member institutes in 157 countries, based in Geneva, Switzerland.
ISO attempts to harmonize among national governmental standards institutes the standards for products or services in different business or industry sectors. These standards define specifications to be applied consistently in the classification of materials, in the manufacture and supply of products, in testing and analysis, in terminology and in the provision of services. ISO also provides guides for conformity assessment for suppliers, third-party certification and accreditation. ISO does not carry out certification itself, nor does it control the verifications used in the business sector of ISO 9000 and ISO 14000 management system standards. Some international groups have an advisory function such as the International Electrotechnical Commission, There are regional intercountry standards groups and each country or economy usually has a single national standards institute that is the core member of ISO.
Separating USGBC from the certification process will bring LEED into alignment with norms established by ISO that require standard-setting bodies to remain distinct entities, not combined with certification bodies in the same area. USGBC is not the only organization addressing the conflicting roles of standard-setting, certification and accreditation. The Forest Stewardship Council sets the standards for Rainforest Alliance Smartwood certification and its sister organization ASI accredits the Rainforest Alliance to certify that wood meets these standards. Separation of functions is crucial for USGBC because it won't be long before USGBC, like FSC, has watchdogs, investigative reporters and bloggers questioning the validity of some of its ratings. Separation of institutions makes it easier to identify problems and fix them. FSC and LEED are linked by the "points" that LEED standards allow for buildings using certified wood products. The problem for everyone is that the supply of certified wood is limited, an estimated 2 percent of the the U.S. lumber market and 8-10 percent of the world lumber market. This in turn could mean a long waiting time for lumber, higher prices or worst of all for FSC and USGBC counterfeit certifications. FSC seeks to capture 20 percent of the market by 2012. Wood vendors try to make it easy for buyers (builders or do-it-yourself homeowners) to buy certified wood by providing copies of fact sheets like this or this, which is best practice according to the International Social and Environmental Accreditation and Labeling ( ISEAL ) Alliance, the equivalent to ISO for global multi-stakeholder standard-setting initiatives like FSC.
Third-party certification bodies, also called registrars, are auditing organizations that issue certificates of conformance to a standard. The certificates can be issued to individuals (as in academic degrees or professional licenses), to companies, to facilities or to products, to show compliance with standards. Certification bodies derive their own credibility, consistency and quality by being subject to renewable accreditation.
Hundreds of certification bodies with staff literally in the hundreds of thousands stand ready (for a fee) to audit and certify against standards of all kinds. Their fees are justified by their long experience and the training that their auditors must undergo in order to qualify for certification work. By tapping into these bodies, USGBC will be able to clear the backlog in its certification pipeline when enough certifiers are trained to LEED standards. It could speed things up even more by licensing other organizations to accredit and train certification bodies. The economies of scale in accreditation are substantial and accreditation, like auditing, is labor-intensive and less profitable than consulting.
Standards for accredited certification bodies are set out in ISO/IEC Guide 17021:2006 and the earlier ISO/IEC Guide 65:1996 . Both these guides are surprisingly expensive ($112 for 26 pages, $58 for 8 pages). Consult at no charge a guide to the guide on accreditation by the International Accreditation Forum, an association of national accreditation agencies. A list of IAF members may be found on the website of the European Cooperation of Accreditation.
Accreditation is another word for licensing of qualified certification bodies. An accrediting authority private or governmental assesses the certification body on a regular basis to verify that the certification body is qualified to do its job, i.e., is objective, independent, with appropriately skilled personnel operating quality systems, so that the certification body will be able to determine reliably whether or not applicants for certification comply with the relevant standards.
Why is accreditation so important? Certification bodies need to be watched like the companies or products or buildings that they certify. Accreditation agencies are the answer to Juvenal's question quis custodiet ipsos custodes?
Remember the bankruptcies of Enron in 2001 and WorldCom in 2002? They were the two largest bankruptcies in world history. Both these companies were being audited by Arthur Andersen, which was not accredited. It was peer-reviewed by other accounting firms, but this clearly was and is inadequate. Andersen was benefiting from lucrative consulting contracts at the same time as it was auditing the two companies' financial statements. It was even then conventional wisdom that auditing suffers when consulting business is being conducted or under consideration at the same time. Andersen gave up its life as this message was hammered home after the WorldCom bankruptcy. Since July 2002, under the Sarbanes-Oxley Act, accounting firms that wish to audit public companies must be registered with the Public Company Accounting Oversight Board, which thereby serves as an accreditation agency (the PCAOB can always decide to revoke a firm's registration).
The International Accreditation Forum and ILAC are both aggregations of national bodies. The ISEAL Alliance is not. It is the specialized organization for environmental and social global standard-setters and accreditation bodies, of which the oldest is the U.S.-based International Organic Accreditation Service. IOAS is the sister organization to the organic agriculture standard-setting body, the International Federation of Organic Agriculture Movements (IFOAM), which has created both organic-agriculture norms and accreditation norms. ISEAL accreditation members, including the Forest Stewardship Council's ASI accreditation agency, are committed to compliance with the ISO standard ISO/IEC 17011 :2004 ($105 for 21 pages) for accreditation bodies. ISEAL has its own member code of good practice, which is downloadable from its website. To comply with ISO and ISEAL standards for accreditation agencies, the Forest Stewardship Council and Social Accountability International have each been separating out its accreditation function into a new organization ASI for FSC and Social Accountability Accreditation Services for SAI.
ISEAL has pioneered some innovations that are applicable to LEED standards. Interesting national and local recognitions of ISEAL member accreditation have been provided by governments. For example, in Italy, several regions (e.g., Venetia, Umbria, Lecce, Tuscana) and municipalities (Rome) have programs to encourage adherence to the SA8000 workplace sustainability standard. Regione Toscana (Tuscany, around Florence) was the first. Tuscany provides public education on SA8000 and provides grants to small businesses to enable them to implement SA8000 and to be certified for their compliance. These government-assisted programs have directly helped 300 Italian facilities become certified. Local governments have a stake in the branding of companies located within their borders. Regione Umbria (around Perugia) gives preference to otherwise qualified and cost-competitive bidders for government contracts that are certified to SAI's SA8000.
USGBC's move to open up its certification process to outside certification bodies, and to focus on accreditation, is a very good sign that the green-buildings program is going to catch up on its backlog and to be credible, so that the public will know whether or not the claimed standards are actually met. USGBC helps builders brand their buildings and co-branding organizations can have four different kinds of functions:
- Set standards.
- Certify against these standards.
- Accredit certification bodies.
- Provide consulting or training.
The USGBC plan seems to make it #1. GBCI's name implies #2, but it is morphing into #3, ceding #2 to qualified independent bodies. An accreditation agency, #3, should not be mixed with any of the other functions. Although USGBC and GBCI are legally distinct and have separate boards of directors , they share for the time being two senior managers. Ideally, all staff should be separate and all relationships between USGBC and GBCI should be arms-length and contractual.
USGBC is moving in the direction it needs to go. Another cheer when it moves closer to global norms.
John Tepper Marlin, Ph.D. is Principal at CSRNYC and CityEconomist. He blogs on sustainability issues for Huffington Post, is an Adjunct Professor of Business Ethics at NYU's Stern School of Business and teaches in the CSR Certificate Program at the University of Geneva.