2026 Green Communities Criteria Draft

I am curious if any consideration has been given to connecting projects with afforestation/reforestation efforts. On some of our more recent development projects, we have partnered with an organization that plants trees and/or implements forestry management practices to help increase the planet's ability to sequester carbon. Awarding points to developers pursuing this seems like a good way to enhance carbon capture goals.

This last sentence seems to only be applicable if the whole house mechanical ventilation system relies on exhaust, however a system that relies only on supply fans should not need these controls on the bathroom exhaust fan.

Suggest adding language that also required air-tight door sweeps to be installed at these locations. Gasketing and weatherstripping is typically seen as being around the top and sides of the door and does not necessarily always include the door sweep.

Does this testing apply to Moderate rehabs that have existing ventilation systems (systems not being replaced)? If enforced as a mandate for testing existing ventilation in moderate rehabs this may add additional unwanted costs for the affordable housing projects.

On older projects substantial rehab developments, it may not be possible to create a new whole house mechanical ventilation system or ERVs, but instead bath exhausts can be sized to run as per whole house rates. Is it possible to make that edit here to make it clear?

If bath exhausts can act as whole house providing minimum required whole house rates and run continuously, that would solve problems in older developments instead of adding burden.

Can we add or (3) MF HERCC COMBUSTION SAFETY TESTING PROTOCOLS. These protocols are also rigorous and require a BPI professional.

Only substantial rehab is mentioned here, does Radon testing apply to moderate rehabs as well where there is no gutting involved?

ensure labeling convention is consistent

Please address active and senior-friendly/aging in place design (like HPD). Keep the exercise room as an option. It's very achievable and very meaningful. For example, from my experience as the daughter of a client living in a multifamily assisted living facility, both the exercise room and the pool were heavily utilized by the senior population. It's also positive and additive for life quality.

Generally, criteria 7.14 - 7.20 except for 7.15 Biophilia feel heavy handed and not truly applicable enough to be mandatory. Would be very helpful to keep the 2020 structure of requiring the team to select one but leaving the selection up to the team.

This is not appropriate as a mandatory requirement unless it's applicable to the resident population.

This is not appropriate as a mandatory criterion for projects unless it's directly applicable to the resident population.

This should be an option for points. Having management manage expectations for all residents makes a major statement.

Is this requiring an acoustics consultant to specify and test post construction?

Very happy to see this as a mandatory requirement for NC.

Something is cut off here.

And smoke

These notes are a good addition.

Rather than throwing it back on teams to find this can EGC provide a chart of the available limits for different categories at the time of publication of the Criteria?

Aren't these a fire hazard or they would need to be coated with something toxic not to be a fire hazard?

define "lightweight"?

The higher the compressive strength of concrete, the higher the GWP. Can "specify concrete" be clarified or is this intentionally loose for the team to define? For instance, a project may require both lower or higher compressive strengths in the concrete. The team could seek optional points for using a lower compressive strength concrete mix with more fly ash that would have a lower GWP than a higher compressive strength. But may not be able to avoid using higher compressive strength concrete with higher GWP. Is the intention they would still be able to get points for using the higher fly ash mix where feasible? Are points applicable to ready mix or also precast?

Is this the link to the tool for finding the regional average? Helpful to provide a specific link. link

Is 90% a realistic target for most projects?

Maybe separate this into two bullet points to visually distinguish content from emissions in a really clear way

Good clarification

The risk from wildfires is underreported and is becoming a major problem. there is the physical risk from heat because you live in an area prone to fires, which is what this risk map depicts. Then there is the risk of wildfire smoke blown your way from a distant area. Can EGC find a way to incorporate smoke drift risk into the risk map? or address this in the ventilation category?

The risk map does not accurately depict this threat. Apparently there is a reason for this "...local regulators were increasingly asking the EPA not to count air pollution caused by wildfires when deciding if their regions are meeting federal standards, and industry groups have worked with some of those local regulators to get the exemptions....we find that wildfire smoke is the fastest-growing source of dirty air in the country by far, and... it’s unregulated by our key air quality regulation...“So jurisdictions can be in compliance with the Clean Air Act, but still have their air getting dirtier due to wildfire smoke. link

As you can imagine there aren't actual wildfires in NYC. But since Canadian wildfires went out of control in 2023 there has not been a summer where the AQI is consistently breathable during the summer in the region.

Then there is the impact of indoor air concentrating the smoke pollutants. NYC made headlines for having triple digit AQI and among worst pollution in the world on one of the first wildfire days in 2023. But at the same time a team went down into the subway with professional equipment and measured AQI that was double that of the outdoor air, as reported by WNYC at the time.

"As warmer temperatures and drier conditions fuel more frequent and severe wildfires, an emerging field of research is uncovering the pernicious threat of poor indoor air quality from wildfire smoke... The “dirty secret” of outdoor air pollution is that you are breathing most of it when you’re inside...As climate change continues and fires worsen, a growing number of individuals could be exposed to wildfire smoke. One study found that from 2006 to 2020, there was a 27-fold increase in the number of people experiencing unhealthy air at least one day per year." link

CNN
link
One-two punch of wildfire smoke is wrecking air quality in the US

Study Reveals Canadian Wildfires Are Affecting U.S. Air Quality and Raising Health Concerns
link

I hate to suggest something that makes more of a barrier to entry for EGC but perhaps something to think about is creating a "prerequisite" category for the Criteria. The prerequisite would be integrative design 1.1, 1.2, 1.5. 1.5 should actually be prioritized as 1.1. This way teams cannot bypass this exercise.

Please include the links to specific document(s). I was unable to locate the documents for the mandatory requirements related to the multifamily rehabs.

A chart of how this requirement compares to the requirements already in place - ADA, Section 504, UFAS, etc. would be helpful.

Many of these requirements are difficult to quantify and the back up data required is not defined clearly.

For a substantial rehabilitation, this would be helpful to discuss with existing residents. For new construction projects, finding potential residents is difficult depending on the funding sources utilized. The information is difficult to quantify. Could this be moved under one of the community meetings sections to be a separate meeting or an agenda item to allow residents to provide input?

While this is a step in the right direction, the difficult to document multiple strategy options will lead to a lot of confusion with mandatory requirements. This should be one required until better documentation guidelines can be provided.

The "screening" materials need to have more details and definitions for better understanding.

The trainings should be explained or defined in more detail.

I think EGC should really consider moving away from requiring teams to refer to the most recent version of SCAQMD standards and just provide a chart in the Criteria of acceptable limits for different categories based on the most recent SCAQMD version at the time of publication of the EGC criteria. Those SCAQMD requirements aren't really updated that often anyway. I suggest updating the Appendix E chart on EGC's website and just put that front and center in 6.5 (old 6.4) for VOC content limits and expanding it to include more of SCAQMD's subcategories. It would be much less of an administrative burden both for teams trying to comply and for EGC reviewers.

This should be an optional category since the data of electric car ownership across the United States varies especially within the affordable housing population. For example, in September 2024, only 8,150 registrations in Louisiana of all electric vehicles (link). There is a significant cost of installation and maintenance to end up with low or no use in some areas of the country. Another option is to lower the percentage to 10% or 1 space whichever is greater. This allows there to be the option regardless of the electricity service availability.

The plan chart template should align with what documentation is being required for backup. Essentially apples to apples data inputs of what the energy models or EGC consultants require for review/data input for audits

Thank you for this clarification.

Also TallyCAT a free plug in for Revit

How are properties supposed to eliminate scope 2 GHG?

Thank you for editing this requirement for clarity.

This includes solar arrays.

I think this list of impacts should be fleshed out a bit more. Artificial Light At Night (ALAN) has more serious consequences than are listed here. It has been demonstrated to reduce the quality and quantity of sleep (in birds and humans), time spent foraging (in beach mice, bats), movement and orientation (in turtle hatchlings, nocturnal insects and birds) and reproductive investment (masking bio-luminescent sexual signals of firefly species and shifting the dawn and dusk chorusing of birds and frogs). Its presence can also shift community structure and dynamics. At a global scale, ALAN’s capacity to attract and disorient has been linked to recent declines in invertebrate (particularly pollinators) biodiversity and changes to avian migratory patterns. Physiologically, ALAN-induced changes to melatonin cycling and circadian function is linked to a range of pathologies in animals, including humans, such as increased risk of disease, obesity, immunosuppression, and associated changes in development, fertility, and survival. The effect of ALAN on hormonal or chemical pathways can have downstream effects. In the Tammar wallaby, it can desynchronise seasonal reproduction. Disruption to seasonal breeding may result in a potential mismatch between offspring birth and required resources (Figure 2D). In plants, ALAN can induce nocturnal photosynthesis and, in deciduous trees, can affect seasonal leaf fall. link