WE Credit NRDC 158 NRDC. 159 Zentox Corporation. 160 Cahill Associates. 161 ZGF Partnership. 162 [none] 163 Keen Engineering Inc.
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- Ethan Armstrong
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1 WE Credit 1.1 Consolidated Issue I'm wondering if the following language is a more concise and clear way of stating the requirement. "Reduce water consumption for irrigation by 50% from a calculated mid-summer baseline case derived from the landscape area, plant species factor, and irrigation efficiency." Put this in a footnote: The same month must be used for both the design and baseline case. Details of the calculation can be found in the Reference Guide. [parenthetical note: July is winter in the southern hemisphere] Under the "Requirements" and "Potential Technologies and Strategies" sections, "chemical free cooling water from cooling towers or evaporative condensors" should be added to the list of water sources like rain water, waste water etc. High efficiency irrigation is not required if the other credit requirements are met with captured rainwater or onsite greywater. Specify whether a combination of approaches can be used. "The baseline consumption is derived from the landscape area, plant species... is used for both the design and baseline case" - this applies to both parts of the "OR" so it should not be located in the paragraph before the "OR". We recommend deleting the reference to water supplied by a public agency. The focus of this credit should look at on-site solutions such as high efficiency irrigation systems and on-site water collection. Allow natural surface waters (which are clearly non-potable - I mean would you drink out of an untreated river?) to be used for compliance to save energy, materials, and cost of constructing water treatment plants. Rainwater collection in Colorado and other states is illegal unless you possess water rights to receiving water bodies; it makes achieving this credit without using untreated water next to impossible. There needs to a clearer definition of how to determine what a baseline is. The credit reads that factors to consider in this are landscape area, plant species factor and irrigation efficiency. Plant density needs to also be factored. Also, the baseline case areas should correspond with the design case - this prevents projects taking a baseline with extensive turfgrass areas and with a significant reduction in turfgrass area for the design case. This tends to skew the calculations. 158 NRDC 158 NRDC 159 Zentox Corporation 160 Cahill Associates 161 ZGF Partnership 162 [none] 163 Keen Engineering Inc. 164 Earthly Ideas LLC 164 Earthly Ideas LLC 165 Green Building Services The format of the credit requirements has been revised for clarity, taking this into account. This issue is a calculation detail and is described in the Reference Guide. Condensate water has been added to the PT&S section for credit 1.2, where there is a list of potential alternative sources of water. The requirements read that any combination of demand reduction, efficiency, or alternative sources may be used to get to the 50% reduction. The requirements language has been revised to make this point. The format of the credit requirements has been revised to address this issue. Reclaimed or recycled water conveyed by a public agency can provide many, if not all, of the benefits of on-site reused water and meets the intent of reducing the use of potable water for irrigation. Natural surface waters are excluded to prevent the negative impacts of depleting local surface water or groundwater. Projects are rewarded for diverting water that would otherwise be discharged or for using municipally provided reclaimed water that is generated from wastewater treatment processes. This credit can be achieved by using low-waterusing plants and efficient irrigation systems. Alternative water sources are not required to reach a 50% reduction. Consistent with other credits, the calculations methodology is explained in the Reference Guide. The Requirements language has been revised to address the eligible measures for claiming a reduction in water use.
2 Adapted' vegetation needs to be defined. Adaptive might be misconstrued as plantings that have established well and are imported but are invasive and destroy natural eco-systems. I believe this may not be the intent here so this needs to be specified. This credit could only give 1 point if the water consumption for irrigation is reduced by 50%, whether using potable or non-potable water. This would guarantee that the system is using less water than a traditional system and would enhance the sustainability of a project/building. Eliminate the second paragraph under requirements (everything after "OR"). Add "water from building sub drainage systems" as another source water to be used in landscaping. 165 Green Building Services 166 Rain Bird 186 Schnabel Engineering "Native or adapted plants" is defined in the Reference Guide, consistent with SSc5. This issue was addressed in the first round of s, under Issue WEc Water pumped from building drainage systems is generally not eligible under the criteria of this credit and is not appropriate for listing in the PT&S section.
3 Consolidated Issue The option to not install permanent landscape irrigation should be removed or reworded, as it encourages behavior contrary to that being promoted by LEED and the USGBC. I also encourage the use of a landscape architect or irrigation consultant to approve the design. 167 Rain Bird "Temporary irrigation systems" should be more clearly defined. The one-year requirement for plant establishment is not realistic. Successful plant establishment is dependant on the weather and seasons. A drier season would slow the growth of the plants and therefore removing the system after one year would likely result in plant failure. 168, 169 While the reduction of potable water use is laudable, most of the criteria for meeting this credit are currently illegal in Colorado, and possible other western states. Thus, the viability of this credit is beyond the owner/builder's control, which would suggest a regional option or exception. 170, 171 Re-include combination language. Allow natural surface waters (which are clearly non-potable - I mean would you drink out of an untreated river?) to be used for compliance to save energy, materials, and cost of constructing water treatment plants. WE Credit 1.2 Green Building Services, [none] City of Boulder, Earthly Ideas LLC 171 Earthly Ideas LLC Comment period. This issue has not changed between v2.1 and the previous versions of 2.2. Comment period. This issue has not changed between v2.1 and the previous versions of 2.2. The establishment period must be quantified to provide a reasonable degree of consistency in this credit. This credit may be achieved by selecting a plant palette that does not require permanent irrigation or recycling greywater generated within the building for irrigation use. These strategies do not conflict with water laws that prohibit stormwater capture. Natural surface waters are excluded to prevent the negative impacts of depleting local surface water or groundwater. Projects are rewarded for diverting water that would otherwise be discharged or for using municipally provided reclaimed water that is generated from wastewater treatment processes. Potential Technologies & Strategies - "Consuider using stormwater, greywater, and/or condensate water for irrigation" - this is equally applicable to WEc1.1, WEc2 and WEc [none] Clarify how the removal of the irrigation system can be documented? I wonder whether this one year removal requirement can be enforced. 173, 176 ZGF Partnership, NRDC Potential alternative sources of water are noted in each of the WE credits, where most appropriate and applicable. Removal of the irrigation system need not be documented for the purposes of LEED certification. The 1-year criteria is documented via the site plan and narrative describing how the plants were selected and installed to enable longterm success with only temporary irrigation during the establishment period. Extend length of time for temporary irrigation system to 2 or 3 years. Allow a minimal irrigation system for trees and shrubs with a limited amount of water to supplement natural rainfall. Under the "Requirements" and "Potential Technologies and Strategies" sections, "chemical free cooling water from cooling towers and evaporative condensors" should be added to the list of water sources like stormwater, greywater, etc. Define potable, and be more explicit about sources of water (buying, and selling aside from sourced from local utility). 174 DHM Design 175 Zentox Corporation 177 Sustainable Design Consulting Comment period. This issue has not changed between v2.1 and the previous versions of 2.2. The establishment period must be quantified to provide a reasonable degree of consistency in this credit. Extensions to the 1- year establishment period will be evaluated on a project-by-project basis. Condensate water has been added to the list to represent these potential sources. The eligible alternative sources of water have been more clearly defined in 1.1 and 1.2.
4 I believe if some credit were given for rainwater harvesting more clients would participate and they amount of potable water used for irrigation would be greatly reduced. 178 Dan Pope Irrigation consultant Rainwater harvesting counts towards the achievement of both credits (1.1 and 1.2).
5 Consolidated Issue Can the building owner sell or give away the treated water rather than use it on site? WE Credit Sustainable Design Consulting This approach is not allowed in the credit requirement. Projects have the option of submitting a CIR if they believe they can meet the credit intent with an alternate approach. Under the "Potential Technologies and Strategies" need to add after dry fixtures such as composting toilets, "water saving technologies for cooling water treatement, like ozone". Also in same section, after Considering reusing stormwater, add "chemical free cooling water discharge" Potential Technologies & Strategies - also include "Consider using condensate water for sewage conveyance" The requirement that "treated water must be infiltrated and used on site" seems to run contrary to district or regional solutions. 180 Zentox Corporation 181 [none] 182 OWP/P Architects Cooling tower water is considered process water and not included in the calculations for WEc2 and WEc3. The PT&S section is not intended to be a comprehensive listing of technologies; condensate water is listed in WEc1, as it is most frequently applied to irrigation uses as opposed to sewage conveyance. The credit intent includes increasing local aquifer recharge; furthermore, simply moving wastewater treatment from central plants to distributed plants does not automatically generate environmental benefit.
6 WE Credit 3 Consolidated Issue Is the fixture limited to those listed, or can others be listed as well? 183 OWP/P Architects Fixtures are limited to those listed. Per CIR, strike "janitor/service sinks" from the list. 184 Earthly Ideas LLC These fixtures have been removed, per this. Add fixtures to include: washing machine, dishwasher, ice machines. Add cooling towers to the list. Water-based cooling towers use at least 50% less energy than air-cooled HVAC systems. Innovative water treatment technologies can save Grumman/Butkus Associates, 20% or more in water use savings. 185, 187, 192[none], NRDC The proposed fixtures/appliances are considered process equipment within LEED and not eligible to achieve this credit. Projects have achieved an ID point for process water reduction by addressing these equipment types. Add a commissioning requirement as an assurance of achieving use reduction targets. 188 NW Energy Efficiency Alliance Comment period. Commissioning has not been included in this credit to date. Negtive credit should be given for specifying toilet/urinal flushing sensors (unless WEc2 is achieved) - No matter how well they are adjusted, they still lead to multiple flushes because every person moves around differently in the stall (and it's affected by motion, clothing color, etc.) How do occupancy numbers relate to credit? How does LEED template accomodate these calculations? Consider water saving technologies such as ozone for Requirements and Potential Technologies and Strategies. 189 [none] 190 ZGF Partnership 191 Zentox Corporation Comment period. The credit language cannot replace effective engineering design and operating practices. These calculation details are provided in the Reference Guide. Because process equipment is not eligible in this credit, the proposed language has not been added.
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