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EB Comment Period 1-Responses edits

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LEED SYSTEM DRAFT: LEED-EB (Open: 03/01/04 - 03/30/04)LEED-EB - Draft Responses to Comment Draft Comments - Updated April 21, 2004Proposed Response Proposed Changes Type of to LEED-EB for ChangeCateg Comment # Issue SummariesBallot Draftory Credit Likes and Dislikes Ways To Improve Language ChangesBased on results from the LEED-EB pilot, it appears No Changes Nonethat a minimum standard for fixture water use that is 20% above the water use level for all EPACT Seems like this should be a credit, not a prerequisite. If a building is more than 15 compliant fixtures is the right balance between Prereq 1 (Minimum years old, and it doesn't do a whole building plumbing retrofit, it will not be able to WE WEp1-Com1 Level Make it a credit to encourage more buildings to obtain LEED-EB status. -- recognizing that old buildings are likely to have older Water Efficiency)meet this prerequisite, and therefore not be able to use LEED-EB. It may have fixtures that use more water and the need for LEED-EBmade improvements in many other areas though.certified building to represent exemplary performance. DuPont supports the intent, requirements and technology and strategies as stated See response to WE Comment # WEp1-Com1. See response to WE See response Prereq 1 (Minimum for this credit. The program should consider whether it might be appropriate to hold Comment # WEp1- to WE WE WEp1-Com2 Level see above see aboveWater Efficiency) buildings constructed prior to ...

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Publié par	Nuching
Nombre de lectures	20
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LEED SYSTEM DRAFT: LEED-EB (Open: 03/01/04 - 03/30/04)

LEED-EB - Draft Responses to Comment Draft Comments - Updated April 21, 2004

Categ

ory

Comment #

Issue Summaries

Credit

Likes and Dislikes

Ways To Improve

Language Changes

Proposed Response

Proposed Changes

to LEED-EB for

Ballot Draft

Type of

Change

WEp1-Com1

Level

Prereq 1 (Minimum

Water Efficiency)

Seems like this should be a credit, not a prerequisite. If a building is more than 15

years old, and it doesn't do a whole building plumbing retrofit, it wil not be able to

meet this prerequisite, and therefore not be able to use LEED-EB. It may have

made improvements in many other areas though.

Make it a credit to encourage more buildings to obtain LEED-EB status. --

Based on results from the LEED-EB pilot, it appears

that a minimum standard for fixture water use that is

20% above the water use level for al EPACT

compliant fixtures is the right balance between

recognizing that old buildings are likely to have older

fixtures that use more water and the need for LEED-EB

certified building to represent exemplary performance.

No Changes

None

WEp1-Com2

Level

Prereq 1 (Minimum

Water Efficiency)

DuPont supports the intent, requirements and technology and strategies as stated

for this credit. The program should consider whether it might be appropriate to hold

buildings constructed prior to some specific year (e.g., 1980 or 1970) to a less

stringent minimum requirement.

see above

See response to WE Comment # WEp1-Com1.

See response to WE

Comment # WEp1-

Com1.

See response

to WE

Comment # 1.

WEp1-Com3

Level

Prereq 1 (Minimum

Water Efficiency)

The baseline of 120 percent of the water use that would occur if al of the fixtures

were 1992 EPACT compliant seems overly generous.

I suggest reducing the baseline to 105% or 110% at the most to

accommodate those few fixtures that would be prohibitively costly to

retrofit.

"...calculated as 105 percent of the water usage that would result..."

Water efficiency at least as good as that required by a decade-old law

seems like a minimum requirement for sustainability.

See response to comment WEp1-Com1 on fixture

water use base line for LEED-EB.

See response to WE

Comment # WEp1-

Com1.

See response

to WE

Comment # 1.

WEp1-Com4

Low Flow Showers

Prereq 1 (Minimum

Water Efficiency)

The control and limitation of the temperature of water supplied to a shower is a

critical health and safety issue that the Plumbing Manufacturers Institute (PMI)

takes very seriously. The Plumbing Manufacturers Institute (PMI) does not support

and specifical y advises against, setting water efficiency criteria for showerheads in

existing buildings without careful consideration of the health and safety issues

surrounding their use. PMI is concerned about the increased thermal shock and

scald risks associated with reducing showerhead flow rates in existing buildings.

Over the years, PMI has played a major role in the development and

implementation of product standards and plumbing code requirements that provide

protection against water temperature-related injuries in showers. As a result, hot

water supply systems are much safer because the vast majority of plumbing codes

throughout the United States and Canada now require thermal shock and scald

protection in the shower.

The U.S. Green Building Council has the responsibility of alerting

building owners to the potential health and safety concerns associated

with reducing showerhead flow rates in order to comply with water

efficiency measures established in the LEED-EB. As such, PMI urges

that information be included in the requirement paragraph of the Water

Efficiency section of the LEED-EB that addresses such concerns.

Thermal shock and scald protection took hold as a national requirement

in the early 1990’s and is accomplished by instal ing an automatic

compensating valve of the balance pressure, thermostatic or combination

balanced pressure/thermostatic type. Although protective shower valves

are required in new and renovated plumbing systems, mil ions of

unprotected showers built prior to the early 1990’s exist today. Thermal

shock is the physical reaction of a person to a rapid and uncomfortable

change in shower water temperature. The temperature change can be

either toward colder or hotter water. Any person may have had the

experience, at home, or even in a hotel, of being in the shower when a qu

With regard to showers, showerheads having a flow rate of 2.5 gpm

(maximum flow rate established in the Energy Policy Act of 1992) shal

only be instal ed where supplied by an individual protective shower or tub

shower combination valve of the pressure balance, thermostatic or

combination balanced-pressure/thermostatic type. Additional y,

showerheads with flow rates below 2.5 gpm should only be utilized after

sufficient research and testing has been conducted to determine the

extent to which reductions in flow rates can be achieved without

increasing the thermal shock and scalding risks.

Like al existing building owners, LEED-EB participants

are responsible for meeting al applicable code

requirements. A paragraph wil be added to the LEED-

EB Reference Guide alerting building owners to the

benefits of shower thermal shock and scald protection

which is accomplished by instal ing an automatic

compensating valve of the balance pressure,

thermostatic or combination balanced

pressure/thermostatic type.

No Change

None

WEp1-Com5

Editorial Changes

Prereq 1 (Minimum

Water Efficiency)

Satisfactory

No comments

Change emphasis for the "If...." to "Provide...." in the Submittals-LEED

EB Re-Certification section To better direct a positive response to action

needed

A clarification along the lines of the proposed language

wil be added to the LEED-EB introduction.

A clarification along

the lines of the

proposed language

wil be added to the

LEED-EB

introduction.

Editorial

WEp1-Com6

Level

Prereq 1 (Minimum

Water Efficiency)

This prerequisite sets an appropriate baseline of water use for an existing building.

Annual reporting seems more appropriate for this credit than quarterly,

since the measures to be implemented would be permanent.

None.

This prerequisite can be met by annual fixture water

use meter data or calculated fixture water use data.

The quarterly review of fixture water usage is

encouraged to al ow increases in consumption to be

identified and corrected in a timely way.

Clarify as describe in

response.

Clarification

WEp1-Com7

Level

Prereq 1 (Minimum

Water Efficiency)

Reduced water demand is crucial in almost every part of the country. However,

setting goals for reductions can be tricky. The pre-requisite is written for a building

that wil be reused with the same use(s). However, around the country, many

developers are converting old buildings and adding or changing uses. These

different uses have vastly different water needs.

The pre-requisite must take into account that redevelopment may add or

change uses. Thus - there needs to be a flexible baseline. Even the most

efficient residential units may not be able to meet the same or reduced

water use of a commercial building that uses very little water.

DCED proposes that this prerequisite be prefaced on maintenance of the

same use for the building - OR for developers who are changing uses,

some percentage of average water use per capita for that region.

LEED-EB does not use an historic baseline. LEED-EB

uses a calculated baseline that is based on the numbe

and types of water using fixtures in the building. If the

number and types of water using fixtures in an existing

building changes the calculated base line changes as

wel .

No Change

None

WEp1-Com8

Method

Prereq 1 (Minimum

Water Efficiency)

The method of compliance for these prerequisite and subsequent credits WEc3.1

and 3.2 has a major fault. The submittal requirements are to provide water meter

data and compare this to a calculated baseline. This compares a hard number

(meter data) to a theoretical number (calculated baseline). These two numbers are

incommensurable. There is simply too much room for error. With a slight over-

estimation of building occupants and/or uses per day on the baseline a facility can

achieve the prerequisite both credits and even file for an Innovation Credit for

exemplary performance.

We suggest that the submittal requirements be changed to fol ow the

requirements of LEED-NC. This would require that the calculated

baseline and calculated existing condition use the same number of

occupants and same number of daily fixture uses. In addition to these

two calculations the submittal wil stil need to submit water meter data

and compare this value to the calculated existing condition. If the water

meter data is greater then the calculated existing condition then the

applicant would need to submit an additional narrative to explain the

deviation.

(see above)

In the comment draft of LEED-EB: (1) The WE

prerequisite 1 can be earned using calculations of the

water use as wel as the baseline, and (2) The WE

credits 3.1 & 3.2 can only be earned with metered

fixture water use data which is compared to the

calculated baseline.

No Change

None

WEp1-Com9

Metering

Prereq 1 (Minimum

Water Efficiency)

Require separate meters for different applications, interior fixtures, exterior, and

cooling.

Requiring this would disqualify many older buildings.

LEED-EB encourages more metering by providing

points (EA credit 4.1-4.3) for having metering of

different types of water usage.

WEp1-Com10

Prereq 1 (Minimum

Water Efficiency)

Ø In the calculations required for initial submittal, comparing the actual water use

to a model baseline doesn’t always work wel . For example, in buildings that use

process water or have a random influx of visitors, etc. which cannot be separately

metered, water use wil be inconsistent when compared to modeled water use.

Process water use can be separated out . While

measuring the actual water used can be complicated

by many factors, actual water use is what affects the

environment not model water use.

No Change

None

WEp1-Com11

Prereq 1 (Minimum

Water Efficiency)

WEPR1: I’m glad that there is a minimum efficiency threshold, but I’m concerned

that a 10-year old building (built after ’92 EPACT) could in theory rip out its fixtures

and instal il egal fixtures and stil comply with the PR.

Al building owners that participate in LEED are

required to comply with al applicable codes,

regulations and laws affecting buildings.

No Change

None

WEp2-Com1

Editorial Changes

Prereq 2 (Discharge

Water Compliance)

Satisfactory

no comments

Change emphasis for the "If.... to "Provide...." in the section LEED-EB

Re-Certification to provide a positive action for requirements to be taken

Make proposed

editorial change

Editorial

WEp2-Com2

Required level of performance

Prereq 2 (Discharge

Water Compliance)

We do not understand the intent of this prerequisite. Are we correct to interpret the

criteria as projects regulated by the NPDES permit must comply and those that

are not regulated need not comply? Is compliance not code-minimum?

This requirement is seen as an important part of the

minimum sustainable performance for an existing

building.

No Change

None

WEp2-Com3

Flexibility

Prereq 2 (Discharge

Water Compliance)

DuPont supports the intent, requirements and technology and strategies as stated

for this credit. We note that the requirements should be crafted to take into

account that the wastewater discharge may be subject to a permit or ordinance

from a publicly owned treatment works or sewer authority rather than an NPDES

permit.

see above

Make proposed

clarification

Clarification

WEc1.1-Com1

Irrigation Reduction Level

Credit 1.1 (Water

Efficient

Landscaping,

Reduce by 50%)

What ia "potable water"? Does it include wel water? Surface water? Al owing

credit for watering pots and gardens seems insignificant in many cases.

Define "potable water". Put a minimum gal ons/year of savings to qualify.Minimum savings per year of 10,000gals.

LEED-EB needs to address a broad range of building

types and sizes. As a result, setting a fixed minimum

number of gal ons of water usage would not be

appropriate. Potable water is water that meets the

standards for drinking which can come from municipal

water supplies, wel water, lake water or other sources.

No Change

None

WEc1.1-Com2

Editorial Changes

Credit 1.1 (Water

Efficient

Landscaping,

Reduce by 50%)

Satisfactory

No comments

Change emphasis of the "If.... " to "Provide...." in the section Submittals--

LEED EB Re-Certification

Make proposed

editorial change

Editorial

WEc1.1-Com3

Who Verifies

Credit 1.1 (Water

Efficient

Landscaping,

Reduce by 50%)

I like this credit because it recognizes the need to audit the existing irrigation

systems and verify the operating efficiency or inefficiency of the irrigation system.

A qualified individual who has specific training with auditing irrigation

systems should certify the operating condition of the project and report

the data to the LEED representative. The Irrigation Association has

created programs that certify individuals with a designation of Certified

Landscape Irrigation Auditor (CLIA) that specializes in irrigation water

auditing. If a system is to qualify to meet the requirements for the water

efficient point, it should be certified by and individual holding a (CLIA)

certificate from the IA.

Al existing buildings should retro-fit their control systems to utilize ET

based control ers with a rain-sensor override. Al irrigation systems

seeking to meet LEED level certification should have a dedicated

irrigation meter (Analog or Digital) at al points of connection to the

system as a prerequisite. An Irrigation Association Certified Irrigation

Designer (CID) or Certified Landscape Irrigation Auditor (CLIA) should

certify with a seal that the system qualifies to meet LEED standards.

Rather than adopt a regulatory/prescriptive approach to

environmental performance, LEED-EB, where

practical, sets performance benchmarks al owing

project teams to demonstrate credit/prerequisite

achievement in numerous ways. Keeping

environmental goals in mind but al owing building

owners, managers and competition in the market to

identify increasingly cost effective ways to achieve

these goals has been and wil continue to be a driving

force behind the development of LEED-EB.

No Change

None

WEc1.1-Com4

Define Conventional

Credit 1.1 (Water

Efficient

Landscaping,

Reduce by 50%)

Please define “conventional means” for clarity. Annual reporting seems

more appropriate for this credit than quarterly, since the monitored

system is permanent and not likely to change throughout the year.

Consider eliminating the need for a narrative in addition to the system

schematics, photographs and calculations. Would it be acceptable for

older buildings to submit rough schematics of their irrigation plan, or does

it need to be an official design document?

None.

"Conventional means" is defined as typical practice in

the area the building is located.

No Change

None

WEc1.1-Com5

Definition of Potable

Credit 1.1 (Water

Efficient

Landscaping,

Reduce by 50%)

In general DuPont supports the intent, requirements and technology and strategies

as stated for this credit. We note that the requirements and technologies do not

completely coincide. For example, the technology and strategies mention the use

of water-efficient plantings, which is not described in the requirements. Rather than

adding to the requirements, it is suggested that they be made more general with

the 50% criterion being the performance basis. Thus the requirements section

might simply state: "Demonstrate that technologies and/or strategies are being

utilized that should reduce potable water consumption by 50% compared with

conventional means." Technologies and strategies should be expanded to mention

the use of composting, Class A biosolids or mulch to hold moisture for plantings. It

may also be appropriate to discourage use of groundwater wel sources. Although

this may be implicit in the term "potable water", many might consider this term in

reference to water distributed by a water utility for potable use.

see above

"Potable water" includes potable water from any

source. In the LEED-EB Reference Guide description

of technologies and strategies, the use of composting,

Class A biosolids or mulch to hold moisture for

plantings wil be added.

None

WEc1.1-Com6

Required level of performance

Credit 1.1 (Water

Efficient

Landscaping,

Reduce by 50%)

The method of compliance for the credit WEc1.1 has a major fault. The submittal

requirements are to provide irrigation meter data and compare this to a calculated

baseline. This compares a hard number (meter data) to a theoretical number

(calculated baseline). These two numbers are incommensurable. There is simply

too much room for error. With a slight over-estimation of uses per day on the

baseline, a facility can achieve this credit.

We suggest that the submittal requirements be changed to fol ow the

requirements of LEED-NC. This would require that the calculated

baseline and calculated existing condition use the same numbers of uses

etc. In addition to these two calculations the submittal wil stil need to

submit water meter data and compare this value to the calculated

existing condition. If the water meter data is greater then the calculated

existing condition then the applicant would need to submit an additional

narrative to explain the deviation.

(see above)

The objective in LEED-EB is to evaluate actual

measured performance of buildings relative to fixed

(not relative) performance standards. For water use,

just like each other aspect of measured performance,

this involves comparison of measured performance

with fixed performance standard. The suggested

approach of using expected performance based on

design does not address actual water usage.

No Change

None

WEc1.1-Com7

Credit 1.1 (Water

Efficient

Landscaping,

Reduce by 50%)

Ensure that this credit cannot be met by the elimination of non-permeable surfaces

or by having al paved exteriors.

LEED-EB must have the flexibility to address a wide

range of urban, suburban and rural buildings. There are

a number of credits that encourage increased

perviousness of the site.

No Change

None

WEc1.1-Com8

Credit 1.1 (Water

Efficient

Landscaping,

Reduce by 50%)

WE1.1 & 2 The “Note” seems to be better placed in the RG. Similarly, the

submittals seem to be legislating; we should remove the bul et points. Why not

al ow using native plants or xeriscaping to achieve potable water use reduction in

WE1.1 or high-efficiency irrigation to stretch captured rainwater supplies for

WE1.2, for example?

The note in the requirement section wil be moved to

the LEED-EB Reference Guide. The methods in the

three bul ets in the submittal section wil be moved to

the LEED-EB Reference Guide.

Make changes

included in the

proposed response

Editorial

WEc1.2-Com1

Quarterly reporting

Credit 1.2 (Water

Efficient

Landscaping, No

Potable Use or No

Irrigation)

Quarterly records seem excessive.

Semiannual or annual records.

#VALUE!

Quarterly reporting addresses two important

sustainability issues:

1. Tracking of ongoing performance so that

performance degradation is promptly identified so it

can be corrected

2. Supporting the institutional commitment needed to

ensure sustainability actions are maintained

successful y over the long term.

Periodic consultation with the individuals responsible

for successful achievement of credits and prerequisites

and the people affected helps ensure that activities

meant to reduce the environmental footprint of a

building continue to occur. An electronic template for

quarterly reporting wil be provided to users of the post

pilot versions of LEED-EB initial y in spreadsheet form

and eventual y online.

Provide LEED-EB

users with a

template for tracking

quarterly

performance.

Include in

supporting

materials for

LEED-EB

users

WEc1.2-Com2

Editorial Changes

Credit 1.2 (Water

Efficient

Landscaping, No

Potable Use or No

Irrigation)

Satisfactory

No comments

Change emphasis from "If ...." to "Provide... in the Submittals--LEED EB

Re-Certification section More positive action shown for what is required

Make the suggested editorial changes

Make proposed

editorial change

Editorial

WEc1.2-Com3

Number of points

Credit 1.2 (Water

Efficient

Landscaping, No

Potable Use or No

Irrigation)

A sustainable water supply is necessary for any building or community to be

sustainable. Landscape irrigation consumes a large amount of potable water when

non-potable water sources could provide this water. This credit should carry more

points. Also, this credit is too restrictive on the type of non-potable water to be

used.

The points should be increased to possibly 5 points to reflect the

importance of water for sustainability of our communities. Include credit

for use of water reuse and raw water from the utility as non-potable water

sources.

Use only captured rain, recycled site water, reclaimed water from a

utility, or raw water to eliminate al potable water use for site irrigation.

The two points available seem to motivate significant

efforts to reduce water use for irrigation.

None

WEc1.2-Com4

Performance metric

Credit 1.2 (Water

Efficient

Landscaping, No

Potable Use or No

Irrigation)

Please define “conventional means” for clarity. Annual reporting seems

more appropriate for this credit than quarterly, since the monitored

system is permanent and not likely to change throughout the year.

Consider eliminating the need for a narrative in addition to the system

schematics, photographs and calculations. Would it be acceptable for

older buildings to submit rough schematics of their irrigation plan, or does

it need to be an official design document?

None

While "conventional systems" is not very precise it

al ows the flexibility to deal with the wide range of what

is "conventional practice" in different climactic regions.

It also is providing significant reductions in water use

for irrigation. Over time perhaps numerical values for

the water use of conventional systems can be

developed for different climactic regions so that in the

future, numerical values for water usage in each

climactic region can be provided. On the quarterly

reporting issue, see response to comment see

response to comment WEc1.2-Com1.

None

WEc1.2-Com5

Grey water

Credit 1.2 (Water

Efficient

Landscaping, No

Potable Use or No

Irrigation)

In general DuPont supports the intent, requirements and technology and strategies

as stated for this credit. We recommend that the technologies and strategies

section include a caution about the use of gray water for landscape irrigation.

Some state or local codes may have a prohibition against such use. In addition,

permitting may be required in order to use wastewater treatment effluent for

irrigation.

see above

OK, this language wil be added to the LEED-EB

Reference Guide.

No Change

None

WEc1.2-Com6

Avoid absolutes

Credit 1.2 (Water

Efficient

Landscaping, No

Potable Use or No

Irrigation)

A precedent has been set in a LEED-NC CIR in which Zero irrigation does not

mean Zero. 1/3/2002 - Credit Interpretation Request We are taping a stormwater

culvert near our site and treating the water for use as non-potable irrigation water.

We are providing water to 51,330 s.f. of landscaped area and have a planter

designed for a 6th floor balcony/plaza area which is 123 s.f. Our question is this, In

your Design Approach section you use the term "site landscape" can we assume

that our planter is not site landscape and use potable water for this area only?

1/3/2002 - Ruling Yes, you can exclude the planter area from the site landscape,

as it represents only 0.25% of the total irrigated area. The water use for the planter

should be included in the calculations for Water Use Credit 3.1 and 3.2 that apply

to water use within buildings.

We propose that LEED-EB adopts a refined version of this CIR and

includes the description either in the credit or in the LEED-EB reference

guide. The 1/3/2002 Ruling did not clearly set the maximum limit. It only

states that 0.25% is acceptable. We propose that there be a definition on

what the maximum limit shal be, whether it be 0.25%, 0.5%, 1.0% and

so on. Setting a maximum limit wil al ow similar future projects to submit

without going through the CIR process. If this is adopted the reference

guide needs to state that any potable water use needs to be added to the

calculations for WEc3.1 and 3.2. Further clarification would be needed to

determine if the benefit of any high efficiency system can be transferable

to the WEc3.1 and 3.2.

(see above)

OK, the standards wil be set so that elimination of

97.5 percent or more of the irrigation water use

qualifies for the second point.

The standard wil be

set so that elimination

of 97.5 percent or

more of the irrigation

water use qualifies for

the second point.

Clarification

WEc1.2-Com7

Credit 1.2 (Water

Efficient

Landscaping, No

Potable Use or No

Irrigation)

Ø The intent says to “limit” use of potable water…isn’t the intent to eliminate

potable water use?

The same intent cover both credits 1.1 &1.2

No Change

None

WEc2-Com1

Cooling tower water and chemical

use

Credit 2 (Innovative

Wastewater

Technologies)

For comfort cooling of a building, the designer is often faced with choosing

between lower energy use with an evaporative water-based system, or less water

use with an air-cooled system. However, water savings with air-cooling is

il usionary since the effect is to simply push the water consumption to the power

generator. Data show that the average consumptive water use for power

generation in the US is 2 gal ons/ kWh. Air-cooled systems not only consume

more energy, they force the power plants to consume more water. The real issue i

that traditional y treating cooling water on site requires the use and release of toxic

chemicals though drift, spil s, air emissions, and blowdown. There are proven

environmental y sustainable and energy-savings alternatives available.

This credit is available to al open, water-cooled systems that are treated

and maintained without the use of added chemicals. Up to two points are

available for a water-cooled system that does not use added chemicals.

One point for water treatment that uses only "green" chemicals, and

another point for water treatment that uses no chemicals at al .

Chemical water treatment probably has the second highest negative

environmental impact over the life cycle of a building. Literal y tons of

chemicals can be added and released in cooling tower operation. These

releases affect indoor air quality, storm water quality, outdoor air quality,

and municipal sewage operations. Chemical-free systems would also

al ow cooling tower blowdown water to be used for irrigation or other non-

potable water needs, which are addressed in other areas. The issue of

“Green Chemicals” should be addressed. As an example, ozone may be

considered a green chemical since it lasts a short time and its daughter

product is just oxygen; however, if improperly administered, it can be

released into the environment in a hazardous manner. This problem with

improper administration is an issue for al “green’ chemicals used in

cooling tower applications.

Cooling tower chemical issues wil be considered for

inclusion in LEED-EB in a future revision of LEED-EB.

No Change

None

WEc2-Com2

Cooling tower water and chemical

use

Credit 2 (Innovative

Wastewater

Technologies)

None

Under potential technologies, I think you should list: Reduce or eliminate

cooling tower water blowdown through non-chemical water treatment and

filtering of cooling tower water. Systems like the Dolphin water treatment

system should be encouraged. It not only eliminates the need for water

treatment chemicals and their subsequent dumping, it precipitates the

minerals out of the cooling tower water so that they can be filtered out,

instead of blowing them down in water every so often. I think this is a

great technology that people should be given the "heads-up" to look into.

None

Cooling tower chemical issues wil be considered for

inclusion in LEED-EB in a future revision of LEED-EB.

No Change

None

WEc2-Com3

Editorial Changes

Credit 2 (Innovative

Wastewater

Technologies)

Satisfactory

No comments

Change emphasis of the "If...to "Provide....." in the section Submittals--

LEED EB Re-Certification to better show the requirement is a positive

format

Make proposed

editorial change

Editorial

WEc2-Com4

Water treatment to tertiary

standards

Credit 2 (Innovative

Wastewater

Technologies)

Although the first requirement of this credit is good, inclusion of the second part of

the requirement is unnecessary and is not necessarily beneficial for the

sustainability of our communities. Reducing potable water use in buildings is good

for a sustainable future. However, treating 100% of wastewater on-site to tertiary

standards is not, in itself, a benefit for sustainability, and has many negative

potentials. Centralized wastewater treatment has been encouraged by water

professionals for decades due to the improved control of water quality and more

efficient use of resources. On-site wastewater treatment systems have less

efficient use of operations staff, and also have less operator attention of effluent

quality. Treatment to tertiary levels is not warranted unless there is a water use or

water quality requirement for higher quality effluent. Use of tertiary treatment when

it is not warranted wastes energy and other resources. Final y, none of the

treatment technologies listed in the credit would achieve tertiary water quality

without additional treatment steps.

Keep the requirement for reducing potable water use of the building, and

increase the points assigned to this credit. Eliminate the alternative

requirement of treating 100% of wastewater on-site to tertiary standards.

Reduce use of potable water in buildings by 50%, based on water use

baseline calculated for WE Prerequisite 1.

This credit is consistent with credits in other bal oted

LEED products. Appropriate changes wil be

considered in the future.

No Change

None

WEc2-Com5

Required level of achievement

Credit 2 (Innovative

Wastewater

Technologies)

Reducing the use of potable water for sewage conveyance is important, but

strategies need to be proposed for existing buildings that were not built with a

greywater system.

Reducing the use of potable water for sewage conveyance is important,

but the overhaul of a plumbing system to al ow for greywater toilet

flushing is a major undertaking (something for a major LEED NC

renovation rather than a minor LEED EB renovation). Could an alternativ

compliance path involving waterless urinals and no or low-water toilets be

included for existing buildings that were not initial y built with greywater

system? (The 50% criteria may need to be reduced to 40% to al ow for

this latter compliance route).

There are a number of options for reducing water use

for sewage conveyance. While it may be more difficult

to earn this credit in LEED-EB than LEED-NC it is stil

something that can be achieved.

No Change

None

WEc2-Com6

Compatibility with code

requirements

Credit 2 (Innovative

Wastewater

Technologies)

In general DuPont supports the intent, requirements and technology and strategies

as stated for this credit. As with Credit 1.2, the technologies and strategies may be

stated too simplistical y. Caution needs to be expressed with respect to the use of

non-potable water in toilets, a practice that is prohibited in some codes. Further,

decentralized wastewater treatment may or may not be a sustainable practice.

There are issues that must be considered such as energy use, impacts on local

receiving waters, qualifications of operators to provide consistently high quality

treatment, and others.

see above

Language to address the issues raised wil be added to

the LEED-EB Reference Guide.

No Change

None

WE3.1&3.2-

Com1

Drinking water quality

Credit 3.1-3.2

(Building Water Use

Reduction)

Would it be beneficial to add some language for drinking water quality issues?

LEED addresses reducing dependence on potable water use for non-

necessary functions, where rainwater, greywater, reclaimed water, or site

processed black water could be substituted, but not much is mentioned

about drinking water quality. This wil be a big Sustainability issue in the

near future. I imagine LEED currently assumes high quality drinking

water is typical y available. Should there be Credit for providing any on-

site purification of water? What about tie-ins to other building systems

whose by-product may include pure water? Such systems possibly could

be used to process rainwater for drinking as wel , adding further grid

independence. Addressing water quality issues such as: toxins, chlorine,

flouromine, mineral content, col oidal level, taste, purity, etc...

The title of such a Credit could be: Drinking Water Quality

Drinking water quality issues wil be considered for

inclusion in LEED-EB in a future revision of LEED-EB.

No Change

None

WE3.1&3.2-

Com2

Editorial Changes

Credit 3.1-3.2

(Building Water Use

Reduction)

Satisfactory

No comments

Change emphasis of the "If.... to "Provide...in the section Submittals--

LEED EB Re-Certification To better show what is required

Make proposed

editorial change

Editorial

WE3.1&3.2-

Com3

Quarterly Reporting

Credit 3.1-3.2

(Building Water Use

Reduction)

Annual reporting seems more appropriate for this credit than quarterly,

since the measures to be implemented would be permanent.

See response to comment WEc1.2-Com1 on quarterly

reporting.

See response to

comment WEc1.2-

Com1 on quarterly

reporting.

See response

to comment

WEc1.2-Com1

on quarterly

reporting.

WE3.1&3.2-

Com4

Format of credits and points

Credit 3.1-3.2

(Building Water Use

Reduction)

Credit 3.1 Building Water Use Reduction, 10% Reduction DuPont supports the

intent, requirements and technology and strategies as stated for this credit. Credit

3.2 Building Water Use Reduction, 20% Reduction It is not clear why this is a

separate credit. It does not seem to al ow for additional credits for further

reductions. The program should consider a single "Credit 3" that provides a point

for each 10% reduction documented (or 0.5 point for each 5% reduction

documented).

see above

The credit numbering scheme for LEED-EB breaks out

each sub point that can be earned under a given credit

No Change

None

WE3.1&3.2-

Com5

Standard required performance

Credit 3.1-3.2

(Building Water Use

Reduction)

The method of compliance for these prerequisite and subsequent credits WEc3.1

and 3.2 has a major fault. The submittal requirements are to provide water meter

data and compare this to a calculated baseline. This compares a hard number

(meter data) to a theoretical number (calculated baseline). These two numbers are

incommensurable. There is simply too much room for error. With a slight over-

estimation of building occupants and/or uses per day on the baseline a facility can

achieve the prerequisite both credits and even file for an Innovation Credit for

exemplary performance. An additional issue that needs to be mentioned is the

threshold percentages. The credit states a 10%/20% reduction from baseline. Is

the baseline 100% of EPA or 120% of EPA? This needs to be clarified in the

wording.