2026 Green Communities Criteria Draft

This is great. Keep it as is.

Please restore the Sizing of Heating and Cooling Equipment as a standalone credit and dissociate it from Energy Star. Why? The first energy star allows for significant oversizing, and this oversizing is based on Manual J 8 calculations, which are already generally oversized. By having the sizing requirement as a standalone, as you have in the past, this enforces projects to right-size their equipment. Please avoid approving any waiver requests that ask for the Energy Star sizing waiver. Ensure the requirement provides further guidance on how to verify that Manual J v8 or ASHRAE handbook data is accurate and matches the information on the plans. In addition, moderate rehabs allow an alternative pathway that allows utility bills to be used for sizing. Here are more details and a tool on that. link

Smoking areas are required by the City of Chicago in permanent supportive housing. This requirement would exclude those projects.

These suggested design strategies would not be applicable to all tenant populations. Suggest this not be mandatory.

Units will have drinking water, so I am not sure if drinking fountains are of much benefit. What would be meant by "readily available food"? Access to a grocery store?

Door undercuts are frequently required for mechanical ventilation. Suggest reconsidering.

Future residents are commonly unknown and cannot be engaged in this type of collaboration. The local jurisdiction and developer may be able to offer the best insight based on previous experience in the community and in similar developments.

Clarify, is this required in wall assemblies that do not required a WRB, such as insulated concrete form walls? Adding a WRB may be unnecessary and contradictory to Criterion 6.3 Reduction of Materials and Waste.

Smoking areas are required by the City of Chicago at permanent supportive housing. Making this mandatory will exclude those projects with tight sites, where smoking cannot be accommodated 25' away from the building.

While I appreciate this working toward the AIA 2030 commitment, I agree with others, this adds a requirement for energy modelling to every project and adds significant long-term costs to development.

If in-unit plumbing is pressurized by public supply, does that count?

Clarify, are the 5 feet around the perimeter to have NO vegetation, groundcover or fencing? What if the fencing is non-combustible? Is groundcover intended to mean vegetated groundcover? Are decorative groundcovers such as cobblestone acceptable?

Agreed with other commenters. Complying with criterion 2.5 does not necessarily address heat-island impacts.

Clarify, do these requirements apply to renovation projects that do not include site work in their scope of work?

Requiring a pick-up/drop-off area on a public street requires approval by local authorities having jurisdiction and may not always be approved.

Where is "Urban/Suburban" and "Rural/Tribal/Small Town" defined?

Why were food access and post office removed? Consider including frequently visited neighborhood amenities like grocery store, library, post office and/or mailing center. Note, the developer may not always be able to find a site that fits these criteria, so making this mandatory may exclude some projects.

Suggest that the resident and community member engagement not be mandatory. When the project is zoned by right, these meetings can introduce delays and cost prohibitive changes to a developer's project goals. Future residents are commonly unknown.

Agree with many of the other comments that this will be difficult for rehabs. Considering that rehabs inherently have a lower embodied carbon impact, maybe this credit should be optional for projects that retain X% of the existing building.

It may be reasonable to offer Option 2 as a pathway to achieve EGC+ now that electrification is also separately required for EGC+. While I understand ZERH to be less stringent than PHIUS, it is more popular among projects seeking EGC+ certification. The electrification requirement alone may be enough of a stringency improvement for EGC+ for the 2026 rating system. Of the projects that have pursued EGC+ under the 2020 rating system, have you seen a big disparity in the performance of those using ZERH vs PHIUS? Is there a specific element of ZERH that is inferior to PHIUS? If so, maybe Option 2 can allow ZERH with modifications.

Include batteries, light bulbs, and electronics such as computers, monitors, televisions, etc.

Good idea.

Can MAS certified green be included?

Good idea.

Is there a reason CDPH-emission is not required? Many gypsum suppliers do meet it.

Please also update the excel checklist, it's useful in beginning planning but cumbersome graphically (too long), could be condensed and include bullets of requirements rather than narratives and a live link to relevant page in online manual; also needs an Overlay edition.

We can further refine the resident connection strategy beyond simply incorporating a place of refuge. Perhaps applicants can help residents identify emergency contacts within the building and beyond – particularly for risky hazards to resident health.

In general, this feels like a burdensome set of requirements for a mandatory criterion. Community design charettes alone are a several week process, adding to soft costs and time on property. Enterprise used to have a tool, Enterprise 360, which helped us pull some of this data. It is now much more onerous to gather.

I thought 1.6 is mandatory as of 2026...? Please clarify this.

You could call it a Resilience Hub here

Please remove this resource, as it is outdated and we won't be updating it.

ADD: Power outages (which are happening more frequently in many places). Criteria with positive influence can be a Resilience Hub with access to battery backup power, water, cooling.

Expecting survey questions dedicated to specific outcomes (i.e. childhood obesity) is difficult because of low survey response rates and lack of representative samples. The monitoring plan also must be realistic but it is especially difficult to prove correlation between interventions and health outcomes. On that basis, it makes more sense for the monitoring to report on the consistency of the chosen intervention being implemented, rather than putting a burden on property staff to evaluate if their specific intervention is resulting in some broader, macro-level public health outcome.

Not just access to open space, but access to SHADE. Open space can be just as hot as inside the building with asphalt, etc.

We have serious concern about the proposed additional requirements to the manuals. The scope and complexity of these new requirements raise significant concerns about feasibility, cost, and labor intensity. Several of the proposed elements—such as the development of supporting materials including magnets, equipment stickers, QR codes, and short videos—require specialized resources and coordination that extend well beyond traditional documentation practices, such as specialized design, coordination, and production. These are not standard deliverables and would necessitate additional consultants or subcontractors, adding both time and cost to already tight project budgets. The hours to complete one set of manuals under the 2020 regime created at least 17 hours of work for our consulting team, and an at least 17 hours of work for the client.

The requirement to develop the O+M Manual throughout design development and construction, including an accountability plan and project-specific amendments post-integrative design, introduces a level of ongoing documentation that is difficult to sustain without dedicated personnel and places an undue demand on the client to provide information. Similarly, mandatory topics such as the Zero Over Time Plan, which is in and of itself seems very time consuming to produce, and detailed summaries from the Resilience and Emergency Manual add layers of complexity that may not be proportionate to the benefits they offer, and seem duplicative.

Additional concerns include:
• Community Portal Access Instructions: While useful, these are often platform-specific and subject to change, and an additional burden on the client to produce.
• Backup Power Configuration Guidance: This is highly technical and varies widely by system, requiring input from engineers and vendors.
• Detailed Dwelling Unit Equipment Documentation: This level of granularity is typically handled by subcontractors and may not be feasible to consolidate into a single manual.
• Regarding the Emergency and Resident manual enhancements, it is unclear whether these are mandatory or optional. If mandatory, the requirement for an up-to-date Building Readiness Report and detailed instructions for accessing online tools and maintenance plans again introduces significant administrative overhead.
We suggest the following:
• Scalable Requirements based on project size and resources; i.e. what is required at a minimum and optional for points, such as stickers.
• Streamlined Templates and Support Tools to reduce the burden on project teams, i.e. EGC O+M manuals don’t typically replace what a client will use for O+M. Intead, consider requiring an EGC Appendix manual for teams to include with their existing O+M manuals that does not duplicate the information in a more formal O+M manual.
• Revert to 2020 phased Implementation (i.e, outline prebuild, complete manual postbuild) to allow teams to adapt gradually and allocate resources appropriately.
• Take the client’s time into account, because requiring more documentation and tools make EGC potentially less competitive.

ENERGY STAR and the certifications/ratings it relies on generally allow buildings using combustion equipment to use more energy than all-electric buildings may use. The EGC Criteria could include provisions to level the playing field, with emphasis on allowing high-efficiency heat pump equipment to earn full credit toward compliance for their excellent energy efficiency. This would be consistent with the 2026 Criteria's ZOT and electric-ready requirements. I will follow up separately on this.

Most of the strategies under this subheading "Material Reduction Through Design" will not be feasible for moderate rehabs.