COVID-19 Impact to Program Requirements

We realize COVID-19-related complications may impact the ability to meet our program requirements. Please see our guidance below for common scenarios. If you have further questions not listed here, please contact us at lbc.support@living-future.org.

We were going to comply with X program requirements, but then COVID-19 happened. What do we do?

Document what you can! Describe how your compliance efforts were affected, and your approach as a result, providing as much detail (and data when applicable) as you can. Propose a solution. We'll review and either approve, suggest changes to your approach, or deny. Proposals may be sent to lbc.support@living-future (or our other program inboxes as appropriate).

We are on the verge of construction and some Red List-compliant products that we specified earlier now can’t be supplied within our construction window. What do we do?

Document your process! Project teams that had specified a Red List-compliant product which can’t be supplied in time for construction because of COVID-19 manufacturing and supply issues, may source a non-compliant product, if necessary. Teams are encouraged to seek a Red List compliant alternative as feasible, given the project timeline. Teams substituting a non-compliant product for a previously specified Red List-compliant product will need to include in their documentation:

  • Red List compliance documentation for the originally specified product,
  • Documentation that the Red List-compliant product could not be provided when needed,
  • Both the originally specified product and the substitute product on the Materials Tracking Table, with clear indication that the substitute was procured as an alternative to the Red List-compliant product, and
  • A copy of a letter to the manufacturer of the alternative product advocating ingredient transparency and Red List compliance.

I'm trying to vet products to ensure they are Red List compliant, but manufacturers are unresponsive. What do I do?

Document your vetting process! Use the General Red List Exception. The team should first consider designing the product out of the project or substituting, if the current design/construction phase of the project allows. Then, if a manufacturer is unresponsive after a minimum of two outreach attempts one week or more apart, the team may document the product as non-compliant and consider other products. Once the team has attempted to vet products from a minimum of three manufacturers, if a compliant product cannot be identified, the team may use the product that is the best fit for the project given the available information.

Our project was on track to meet the requirements for Living Economy Sourcing, but now we are unable to meet the zone requirements. What do we do?

Document your procurement process! ILFI recommends that each project team start with a design phase calculation for all major (cost impacting) products within the LBC scope of work demonstrating the design team’s efforts to identify products to meet the Living Economy Sourcing Imperative. If products that were originally identified as available within a specific zone are no longer available from within the estimated sourcing zone or pricing has changed significantly, the team should document the change in zone or product pricing that negatively skewed the calculation. This record should be kept on a product by product basis. Teams should also be prepared to submit a narrative outlining efforts to identify new products from closer sourcing zones in an attempt to correct the overall Living Economy Sourcing calculation.

If a manufacturer is only able to fill a portion of the order from the originally identified manufacturing facility, and the remaining product order is being shipped from a farther facility, the team does not need to adjust the Living Economy Sourcing calculation. In these cases the team may track the full product value from the closer facility and will not be penalized for manufacturer fulfillment or capacity issues at local facilities.

Our project is experiencing/experienced a period of significantly decreased occupancy. How does this impact our ability to demonstrate zero/net positive energy for 12 consecutive months?

Continue to gather data. You may not need to restart your 12 consecutive month performance period. Proposals for an alternative to 12 consecutive months of performance will be reviewed on a per project basis; acceptance of proposals is not guaranteed. Here are a few alternative options we may consider to demonstrate zero/net positive energy:

  • If your project was occupied for 9 (or more) months, and was then not occupied for 3 (or fewer) months at the end of the targeted performance period, you may provide a model for consideration as a substitute for performance data. As part of this model, you'll need to provide either actual renewable production data, or if that's not available, an estimate of production via renewable sources; ideally, the estimate will be based on actual meteorological data for the unoccupied period, and will take into consideration production data from the occupied period. You will also need to estimate loads for the unoccupied period; ideally, this will be based on actual meteorological data, account for any previously planned events that would have significantly impacted loads for the unoccupied period, and will take into consideration use data from the occupied period, as well as any available use data for the unoccupied period. Use a calibrated energy model that assumes the actual, measured occupancy from the 9 months persists through the entire year.
  • If your project has at least 9 months of performance data under normal occupancy conditions, you may provide calculations to demonstrate that the loads during the period of atypical occupancy would have to have been unreasonably high in order to put overall performance below 100%/105%. This would have to be shown on an individual end use basis (projections for each).
  • If your project experiences/experienced an occupancy decrease of less than 15%, you may consider the project occupied as intended, and include any such periods in the 12 consecutive month performance period. Estimated demand for the occupancy decrease must be proportionally estimated and included in the overall energy demand. 
  • If your project is unoccupied/has atypical occupancy for an extended period, you may "pause" the performance period for this period, and resume the performance period once occupancy returns to normal only if the "paused" period has a lower net impact than the period following the pause. That is, you cannot pause the performance period if doing so unfairly skews performance towards net positive. If pausing the performance periods results in inclusion of periods that are high use/low production (and are generally more detrimental than beneficial to the overall performance of the project), this option may be acceptable. You must provide calculations to justify.

Our project is experiencing/experienced a period of significantly decreased occupancy. How does this impact our ability to demonstrate net positive water for 12 consecutive months?

Continue to gather data. You may not need to restart your 12 consecutive month performance period. Proposals for an alternative to 12 consecutive months of performance will be reviewed on a per project basis; acceptance of proposals is not guaranteed. Here are a few alternative options we may consider to demonstrate net positive water:

  • If your project was occupied for 9 (or more) months, and was then not occupied for 3 (or fewer) months during the targeted performance period, you may provide a model for consideration as a substitute for performance data. As part of this model, you'll need to provide actual collection data from all water sources (potable and non-potable). If that's not available, you may provide an estimate of sourced water; ideally, this will be based on actual meteorological data and will take into consideration sourcing data from the occupied period. You will also need to estimate demand for the unoccupied period; ideally, this will take into consideration use data from the occupied period as well as any available use data for the unoccupied period, and will account for any previously planned events that would have significantly impacted demand during  the unoccupied period.
  • If your project has at least 9 months of performance data under normal occupancy conditions, you may provide calculations to demonstrate that the demand during the period of atypical occupancy would have to have unreasonably exceeded the established demand estimates in order to put overall performance below the required threshold.
  • If your project experiences/experienced an occupancy decrease of less than 15%, you may consider the project occupied as intended, and include any such periods in the 12 consecutive month performance period. Estimated demand for the occupancy decrease must be proportionally estimated and included in the overall water demand.   
  • If your project is unoccupied/has atypical occupancy for a period extending beyond the three months noted above, you may "pause" the performance period for this period, and resume the performance period once occupancy returns to normal only if the "paused" period has a lower net impact than the period following the pause. That is, you cannot pause the performance period if doing so unfairly skews performance towards net positive, especially if the water demand and sources are skewed by seasonality. If pausing the performance periods results in inclusion of periods that are high demand/low sourcing (and are generally more detrimental than beneficial to the overall performance of the project), this option may be acceptable. You must provide calculations to justify.

We were planning to perform an IAQ test, but then we missed the opportunity to perform the IAQ test within the required timeframe. What do we do?

Document your process! Describe your anticipated testing schedule, then explain how that plan changed. Perform testing when you are able.

We are unable to host an in-person biophilic design charrette. What do we do?

Do it remotely!

We are unable to host an in-person open day. What do we do?

Do it remotely/virtually! Be sure to advertise the virtual tour to the greater community to allow others who would not typically have a chance to visit the project an opportunity to participate and learn about the project and its features.

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