Nigel Howard

The issue of green building rating tools has become increasingly controversial. In recent articles we covered a major new challenge to LEED in the US by Green Globes and the Green Buildings Initiative.

In this article Nigel Howard spells out his views, including his 10 golden rules for green building rating tools.

I believe there are 10 golden rules for establishing successful green building rating tools:

1. Change

To promote change, green building rating tools must differentiate the market and create the basis for competition. They must be well promoted so that they become indispensable to their target markets.

2. One Definition

Green building rating tools must define a single, unambiguous interpretation of what a green building really is. If there is more than one interpretation of “green building” in any market, then users will flock to the easiest, cheapest version that gives them the best rating. When this happen, ratings quickly becomes discredited as “greenwash” and no longer promote real change.

3. Engagement

To achieve a single definition of green building, a broad range of stakeholders needs to be engaged in the development of green building rating tools – even the opponents’ arguments need to be heard and considered, and a formal governance structure is required to define the process.

4. Leading edge

Green building rating standards need to be set at the leading edge (say 25 per cent) but not the bleeding edge of change, and continually improved as the market innovates and responds – a platinum building today may perform like a silver building in 10 years’ time. If a rating standard is set too high, then only a tiny percentage of the market can engage – the standard becomes marginalised. If the standard is set too low then little differentiation occurs, market transformation is too slow and stakeholders lose interest.

5. Leadership

If a rating system is to reward just the best 25 per cent of the market, then the majority of the market (the other 75 per cent) are going to be disadvantaged. This means that an effective green building rating organisation is going to face tough and relentless opposition. Green building rating organisations need strong, committed and inspirational leadership to keep a broad range of stakeholders unified in support of the rating tool and the change they promote. Factional interests must be encouraged to support the common goal ahead of their particular interests.

6. Regulation

Green building rating standards must not be adopted as regulation, because this means that they become a minimum standard (below which you are breaking the law). Raising the bar on regulated standards to promote change becomes almost impossible. Rather, green building ratings should promote best practice, giving premium value to successful performance. This incentivises suppliers and practitioners to achieve better performance, builds capability and experience, and promotes economies of scale in production. Costs come down as more of the market moves to higher standards, making it now much easier for regulation to be tightened. Green building ratings pull the market forward and create the space for tighter regulation to ratchet forward and enforce higher standards on the laggards.

7. Technically robust

Green building rating system credits must be technically robust, otherwise opponents can prove objective grounds for opposition and unfair treatment of segments of the market. Unfortunately, buildings’ environmental impacts are often complex and sometimes perverse – as the US Green Building Council’s technical scientific advisory committee discovered, objective technical findings may be at odds with stakeholder opinion and this spells trouble for environmental rating.

8. Focus

Green building rating systems need to remain focussed on the 10 per cent of issues that cause 90 per cent of impacts. If this is done successfully, then credits are simpler to understand and document, the bureaucracy and costs of assessing performance are dramatically reduced and the rating system is affordable and accessible to a wider range of projects. Stakeholders participating in the development of rating tools find it much easier to add new issues than to cut anything out, and this leads to mushrooming complexity, overlapping and conflicting credits and perverse outcomes. Broadening the agenda to wider sustainability issues means reduced focus on critical issues.

9. Enforcement

Green building standards must be enforced fairly, fearlessly and helpfully with the minimum of essential bureaucracy – in LEED we tried to work to an ethos of “helping projects to gain all of the credits that they deserved” and not just policing them.

10. Performance based

Green building rating credits should as far as possible be performance based rather than proscriptive and reward achievement and not effort (or cost). The measures that achieve most performance improvement with least effort and cost (win wins) should be the measures that gain most credit and expensive or difficult measures of marginal benefit should not be greatly encouraged.

The challenges LEED faces aren’t as extreme as portrayed

From the media it is easy to get the impression that the challenges facing LEED are extreme, and the USGBC is in trouble, but that impression was true 10 years ago also. Looking at this objectively, after 10 years in the market, Green Globes appears to have less than 350 certified projects, LEED has 60,000 plus across at least 10 countries.

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Challenges to the exclusive adoption of LEED by the US General Services Administration and to the adoption of LEED by state and local administrations have also been the subject of many social media threads. This was true 10 years ago also. What is new, though, is the challenge coming from inside the USGBC where the Cascadia region have launched their own Living Building Challenge rating system.

Although LEED has gone through two iterations of reinvention and automation through V3 and now V4, the challenges remain stubbornly the same. The media exaggerates these problems and this is just the grinding, business-as-usual challenges that any successful building rating system that differentiates the market must always endure. LEED and BREEAM are the two most phenomenally successful rating systems internationally. So what lessons can we draw for LEED from the 10 golden rules.

Firstly the opponents of LEED know golden rule 2 really well – they know that confusing the market with multiple definitions of green building is one of the key ways to stall the success of LEED (and all other building rating tools). So, Green Building Initiative pulled off a real coup when they brought out Green Globes from Jiri Skopek and started to promote it aggressively as an alternative to LEED with federal and state administrations. Moreover, since Green Globes claims to be more closely aligned to life cycle assessment, GBI were also able to claim that Green Globes was more technically robust (golden rule 7). On this LEED has responded with LCA based credits in V4 but these need to be more integrated throughout LEED, permit tradeoffs between energy and materials implications and use weighted impact categories to keep it simple and practical to apply.

More worrying for me is the challenge from the Cascadia Chapter of USGBC in launching its Living Buildings Challenge rating system. This plays right into the hands of the opponents of LEED by further confusing the market about the definition of green building (GBI must be delighted). It also splits the allegiance of green building supporters into factions backing LEED or backing Living Buildings Challenge. USGBC can no longer count on the unified support of its own members.

Secondly, successful rating systems rely on the support and patronage of major government clients – in the US the GSA and military are the biggest, followed by state governments. Some of the biggest achievements of LEED and USGBC have come from state support and leadership, and LEED opponents have put a great deal of attention (and money) behind eliminating the influence of LEED with state and federal government agencies. If opponents can objectively demonstrate that LEED is not technically robust and unjustifiably penalises an industry or sector then it is very difficult for a government agency to continue to support LEED as its only rating tool. If governments’ support for LEED as the single definition of green building is undermined, then LEED’s ability to promote change is also undermined.


The two issues of greatest contention remain forest certification, and chemicals and their toxicity.

Forest certification is an extremely difficult issue both technically and politically. Arguably the Sustainable Forestry Initiative certification program has moved much closer technically to the requirements of the Forest Stewardship Certification program and LEED recognition of SFI would make far greater volumes of more sustainable timber available (at lower cost) to LEED projects. On the other hand, the passionate support of USGBC’s membership for the FSC program and the repercussions of this decision on support for the FSC certification program internationally make this an intractable problem for USGBC. BREEAM, in contrast, has put more focus on what is considered the biggest issue of all – tropical forest exploitation rather than the management of plantation forest and have avoided such ferocious opposition on this issue (to date). I don’t think anything significant has changed on this issue in recent years.


On chemicals and toxicity, USGBC has faced opposition both from the industry – the American Chemistry Council – and internally from the many USGBC members who support the Healthy Building Network’s position on toxic chemical ingredients. Ingredients may indicate an occupational health risks to a supplier’s employees but will usually be hopelessly misleading indicators of the toxicity of the products that result – almost all plastics arise from the reaction of toxic chemicals (with themselves or others) and the plastics that results are usually non-toxic (we keep our food in plastic containers, we cook with plastic utensils etc.). A technically robust assessment considers a toxic material’s emissions, the pathway from production to human (or ecotoxic) exposure to absorption and then to toxic effect (on the exposed species) together with any synergistic or antagonistic effects between other chemicals. Doing this right is complex and expensive.

This issue was sparked by a credit for avoidance of PVC in the V1 pilot version of LEED for Commercial Interiors. A detailed technical study by USGBC’s own panel of top US experts concluded that across the main classes of use PVC products were no more damaging to human health or ecotoxicity than the alternatives, and this credit was not technically defensible.

USGBC has struggled with this issue ever since – member consensus passionately opposes the use of PVC (and other chemicals), but best science does not justify this position. Through LEED V2 and V3 no credits were given for avoiding toxic ingredients. No doubt the frustration felt by those passionate to oppose the use of PVC (and other chemicals) will have contributed to Cascadia Chapter’s launch of the Living Building Challenge with its red list as a prominent requirement. In LEED V4, USGBC has responded to member consensus by also including credits for reporting chemical ingredients and has now perhaps broken golden rule 7 and given its opponents technical grounds for opposition with state and federal agencies.

Industry change

Despite all of the criticism, LEED has promoted innovation and achieved phenomenal change in the property industry across the US and internationally. Green building councils internationally rely significantly on the leadership and support shown by the USGBC. USGBC needs to re-affirm its leadership position of defining the US green building agenda with LEED. LEED V5 needs to be accelerated to move past the misleading use of red lists of ingredients to use health impact assessment and life cycle assessment running to consider the supply chain, emissions exposures and resulting health impacts. Federal and state agencies need to reaffirm their support for LEED as the single standard definition of green building for the US.

The factional interests within the USGBC membership supporting different methods of health impact assessment, different forestry standards or any other strand of interest must recognise that their collective support for the green building mission is much more important than their factional interest. USGBC needs to reconvene its technical scientific advisory committee and all factions should submit to resolving their issues with the best possible scientific outcome arbitrated by expert technical groups.

No doubt many will disagree with these views and may have better suggestions to solve these problems.

Whatever path is taken we all need it to succeed and any path that succeeds has my full support.

Nigel Howard is managing director of Clarity Environment. He was involved in the development of BREEAM in the UK and later moved to US in 2000 as vice president of the USGBC, where he presided over the development of LEED from pilot to five new versions implemented across the US, Canada and India.

One reply on “Nigel Howard: the 10 golden rules of green building rating”

  1. This is a really interesting topic of discussion and, as stated at the beginning, a rather controversial one!

    Personally I think “golden rule” number 2 (Definition) should be number 1. Not saying that it is more important than the other “rules”, but without a clear definition it’s near on impossible to get the remaining “rules” going in the right direction.
    Having said that establishing a “clear” definition, and one that we all agree on, might take a while. In the mean time everyone in this industry should stop saying they are right and everyone else is wrong. From an outsiders perspective (the most important group we need to convince of the benefits of green building) all they are seeing is a bunch of infighting. It doesn’t provide a lot of confidence….
    If we don’t totally agree with someone else’s approach we need to say “We are all pushing in the same general direction and what they are doing is good, it’s just that what we are doing is better”. Do we realise how much joy the detractors of sustainability get when reading about the controversy in green building?
    When BP destroyed the Gulf of Mexico did you see Shell or Chevron jumping in and giving them a kick? We need to take a leaf out of the book of super successful and mature industries when it comes to promotion (definitely not the exploitation though!).
    It’s great to have healthy debate and discussion around how to improve what we do but we need do it in a constructive fashion. Furthermore anyone looking into the green building space should see a united front of positivity.
    Speaking of healthy debate, if anyone (in Perth) wants to come along to discussion regarding trying to define what a sustainable building is, then join us next Friday for a bit of fun

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