Comment on FR Doc # 2013-02408

As a design/build and design/bid/build contractor that has constructed numerous Military facilities under contract with the US Army Corps of Engineers we have seen significant inefficiency in allowing LEED to dictate the entire facility and process to the point that would be considered cost prohibitive in the private sector. The primary issue we encounter is that the initial purpose and mission of a Military facility is diminished due to a budgeted amount for an awarded project being consumed by new and unproven "Green" technologies and procedures rather than spending those funds on functional characteristics and mission critical equipment. We have seen facilities designed and constructed to meet LEED Silver but at the sacrifice of additional tactical equipment vehicle work-bays because the budget was eaten up with ultra high efficiency mechanical equipment and light fixtures. Another issue we have run up against in utilizing LEED is the ever changing requirements and often times proprietary nature of important scoring criteria. We can go into a project with solid LEED Silver based on a scorecard then at such time that we are ready to re-tally the score card some of the credit requirements have changed. This causes time and cost growth, which often translates to Contractor responsibility and cost, with no good reason from a construction management standpoint. Additionally, we have run across numerous credits that unofficially require proprietary equipment to meet. For instance, there is a highly desirable credit that reads as though it is open to any equipment but the unspoken rule is that the only way to achieve is to use one mechanical manufacturer's equipment or you will never achieve the credit. This is not, in my personal opinion, a wise use of the funds of the people of the United States of America. In my opinion a separate set of compliance criteria for Military/Federal Facility construction is justified. The Green Globes system is preferred.