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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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
WE
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
WE
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 above
See response to WE Comment # WEp1-Com1.
See response to WE
Comment # WEp1-
Com1.
See response
to WE
Comment # 1.
WE
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.
WE
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
WE
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
WE
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
WE
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
WE
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
WE
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.
WE
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
WE
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
WE
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
OK
Make proposed
editorial change
Editorial
WE
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
WE
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
see above
OK
Make proposed
clarification
Clarification
WE
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
WE
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
OK
Make proposed
editorial change
Editorial
WE
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
WE
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
WE
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
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
None
WE
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
WE
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
WE
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
WE
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
WE
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
WE
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
None
WE
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
None
WE
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
see above
OK, this language wil be added to the LEED-EB
Reference Guide.
No Change
None
WE
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
WE
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
WE
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
WE
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
WE
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
OK
Make proposed
editorial change
Editorial
WE
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
WE
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
WE
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
see above
Language to address the issues raised wil be added to
the LEED-EB Reference Guide.
No Change
None
WE
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
WE
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
OK
Make proposed
editorial change
Editorial
WE
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.
WE
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
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
WE
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.
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. If the intent is to provide a 10%/20% reduction from 100% of
EPA then we feel that this is a reasonable threshold for an Existing
Building. If the intent is to provide a 10%/20% reduction from 120% of
EPA then we feel that this is not acceptable in that the requirements are
not stringent enough. We understand that for the prerequisite, retrofitting
an existing building to meet 100% of EPA may be cost prohibitive. From
this the 120% is an acceptable baseline. However, to award 1 or 2 points
r reducing 10%/20% from 120% is not acceptable This requirement ne
(see above)
See response to comment WEc1.1-Com6. The water
use baseline is defined in the minimum water use
performance prerequisite as 120% of the water use
that would occur if al the fixtures in the building were
EPACT compliant.
See response to
comment WEc1.1-
Com6.
See response
to comment
WEc1.1-
Com6.
WE
WE3.1&3.2-
Com6
Credit 3.1-3.2
(Building Water Use
Reduction)
WE3.1: Let me see if I can paraphrase this credit… “Don’t bother doing much to
save water, even though it’s 12 years after EPACT was passed and a whole host
of cost- and resource-effective technologies are available today for an easy retrofit.
We’l just give LEED credit to a building that would be il egal to build today.” If you
explicitly include cooling towers, I’l shut up.
WE3.2: How about this one… “Okay, okay, we’l give you TWO points if you just
promise not to be il egal by today’s standards.” Ditto for cooling towers above.
Having fixtures that do not meet EPACT in buildings is
not il egal if they were instal ed before EPACT went
into effect. As a result, many older buildings stil have
pre EPACT fixtures. LEED-EB gets older building on
board by providing a doable baseline for water usage
and provides incentives (points for reducing water
usage and moving to EPACT compliant fixtures.
Meeting the LEED-EB baseline can be a chal enge for
older buildings.
No Change
None