NC-v4 WEc3: Cooling tower water use

  • All about condenser water cycles

    Cooling tower | Photo – YR&GThis credit focuses on achieving an appropriate number of condenser water cycles in a cooling tower based on the concentrations of various water quality criteria, such as dissolved solids.

    The credit has been a part of LEED-EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating systems. for some time, but is a new addition to the BD&C rating systems.

    What do cycles have to do with saving water?

    The key parameter used to evaluate cooling tower operation is cycles (sometimes referred to as cycles of concentrationConcentration ratio is the ratio of the level of dissolved solids in the recirculating water to the level found in the entering makeup water. A higher concentration ratio results from a lower bleed-off rate; increasing the ratio above a certain point, however, leads to scaling, and water savings diminish after a certain level. This ratio is also called the cycles of concentration. Cycles refers to the number of times dissolved minerals in the water are concentrated compared with makeup water, not to water flow over the tower or to on-off cycles. or concentration ratioConcentration ratio is the ratio of the level of dissolved solids in the recirculating water to the level found in the entering makeup water. A higher concentration ratio results from a lower bleed-off rate; increasing the ratio above a certain point, however, leads to scaling, and water savings diminish after a certain level. This ratio is also called the cycles of concentration. Cycles refers to the number of times dissolved minerals in the water are concentrated compared with makeup water, not to water flow over the tower or to on-off cycles.).

    For a well-managed condenser water system, a cycle represents the extent to which water is used efficiently before being discharged via blowdownAlso referred to as bleed-off; the removal of makeup water from a cooling tower or evaporative condenser recirculation system to reduce concentrations of dissolved solids that can cause mineral buildup. (where water is drained from cooling equipmentThe equipment used for cooling room air in a building for human comfort. in order to remove mineral build-up). A cycle is calculated as the ratio of the concentration of dissolved solids (or conductivity) in the blowdown water compared to the make-up water.

    From a water efficiency standpoint, you want to maximize cycles as this will reduce the amount of waste blowdown water and reduce make-up water consumption. The trick, however, is that dissolved solids increase as cycles of concentration increase, which can cause scale and corrosion problems unless carefully controlled. So this LEED credit sets a cap for five control parameters that typically play the biggest role in scale and corrosion.

    Calculating the maximum cycles

    Your team’s job is to measure the level of each control parameter in the cooling tower make-up water and then achieve the maximum number of cycles without exceeding the maximum concentration level for any of the control parameters.

    The example in the Documentation Toolkit from the LEED v4 Reference Guide shows how to calculate the maximum cycles for your system.

    The maximum cycles of concentration will vary depending on your system and the concentration of solids in the makeup water serving the cooling tower. That said, it is common for cooling towers to operate in the range of 5–7 cycles.

    If you can, leverage your building’s future cooling tower or water treatment vendor to assess the control parameters and implement a plan to meet the maximum cycles of concentration. These vendors can also help determine if additional chemical treatments can be employed in order to reach the 10 cycles required to qualify for an additional LEED point. If you don’t have a vendor on board yet you can engage another water treatment professional to perform the analysis. Alternatively, the cooling tower or evaporative condenser manufacturer may offer a water test kit.

    What does each of the control parameters mean?

    Here’s how each of the parameters can affect the performance of your cooling tower. 

    Ca (as CaCO3): Calcium (as Calcium carbonate)

    Cooling towerCooling towers chill buildings by evaporating water. A 100-ton chiller evaporates about three gallons of water per minute (11 lpm), with additional water loss from drift and blowdown. In a typical office building, HVAC equipment accounts for about a third of total water use. Photo – Advance Cooling Towers Calcium carbonate is a very common form of scale found in cooling towers. Scale reduces a cooling tower’s heat exchange efficiency by insulating equipment. Because of this, a major goal of most cooling tower chemical treatment programs is to prevent scale build-up.

    Total alkalinity

    Alkalinity is an indicator of acid neutralizing or acid buffering minerals in the water. High concentrations can lead to scale build up.

    SiO2: Silica

    Silica is one of the impurities that frequently play a big role in limiting the maximum cycles of concentration for a cooling tower. As concentrations increase past maximum levels, silica is likely to form scale deposits and insoluble sludge in the cooling tower.

    Cl: Chloride

    Chloride can be corrosive to most metals, which decreases the performance or longevity of the cooling tower.

    Conductivity

    Conductivity is a measurement of the water’s ability to conduct electricity. It’s also an indicator of the total dissolved mineral content of the water, since higher conductivity levels correlate to more dissolved salts in the water. By this logic, water with very little minerals present (think purified water) has very low conductivity.

    High conductivity levels indicate increased risk of scale build up and lower performance for the cooling tower.

    Preventing Legionnaires Disease

    Legionnaires Disease is a serious disease, and it's worth taking a minute to learn about it and how to prevent it. The disease is caused by bacterium found in potable and nonpotable waterNonpotable water: does not meet EPA's drinking water quality standards and is not approved for human consumption by the state or local authorities having jurisdiction. Water that is unsafe or unpalatable to drink because it contains pollutants, contaminants, minerals, or infective agents. systems, such as cooling towers. Outbreaks in 2015 occurred in New York and California, serving as a reminder that proper management of biological growth should be an ongoing priority.

    When Legionnaires develops in a cooling tower, it is transmitted to people as small droplets of water that contain the bacteria are released into the air. The bacterium is spread by water vapor only; it cannot be transmitted by infected individuals. When contracted, Legionnaires is a very a serious illness that can be lethal if left untreated.

    In order to prevent contamination of your cooling tower, the Occupational Safety and Health Administration (OSHA) recommends the actions below. Note that these activities represent best practice strategies for maintaining your cooling towers; the LEED v4 credit doesn’t require that teams implement these actions.

    • Add chemical biocides to control Legionnaires growth. Obtain information on appropriate biocide selection and use from equipment manufacturers or from companies experienced with the particular system used.
    • Treat circulating water for control of microorganisms, scale, and corrosion. This should include systematic use of biocides and rust inhibitors, preferably supplied by continuous feed.
    • Clean and disinfect cooling towers quarterly or at least twice a year if the unit is not used year round. Do this before initial start-up at the beginning of the cooling season and after shutdown in the fall.
    • Any system that has been out of service for an extended period should be cleaned and disinfected.
    • New systems require cleaning and disinfecting because construction material residue can contribute to Legionnaires bacteria growth.
    • Design features that minimize the spray generated by these systems are desirable.

    In addition, we recommend locating your cooling towers away from air intakes and operable windows to minimize unnecessary exposure risks.

    How cooling tower materials affect cycles of concentration

    Owners and design teams should know that the material used to construct a cooling tower can determine the maximum concentration levels a given manufacturer allows without voiding the warranty. Stainless steel typically costs more than galvanized steel but allows for higher concentration levels of certain parameters.

    Reviewing the options from this perspective is prudent when considering a new tower. Manufacturers can provide recommended concentration levels for galvanized and stainless steel. Keep in mind that recommended concentrations would be specific to the particular manufacturer and piece of equipment that is installed in your building

    FAQs for WEc3

    What if my building doesn’t use a cooling tower?

    A pilot credit is available that outlines an alternative compliance path for buildings without cooling towers. To see if you qualify, determine whether your building falls under System 7 or System 8 as outlined in ASHRAE 90.1–2010 Appendix G Table G3.1.1. If it does—and if you don’t have a cooling tower—you can use the pilot credit to achieve this credit. 

  • WE Credit 3: Cooling tower water use

    Intent

    To conserve water used for cooling tower makeup while controlling microbes, corrosion, and scale in the condenser water system.

    Requirements

    For cooling towers and evaporative condensers, conduct a one-time potable waterWater that meets or exceeds U.S. Environmental Protection Agency drinking water quality standards (or a local equivalent outside the U.S.) and is approved for human consumption by the state or local authorities having jurisdiction; it may be supplied from wells or municipal water systems. analysis, in order to optimize cooling tower cycles. Measure at least the five control parameters listed in Table 1.

    Table 1. Maximum concentrations for parameters in condenser water

    Parameter Maximum level
    Ca (as CaCO3) 1000 ppmParts per million.
    Total alkalinity 1000 ppm
    SiO2 100 ppm
    Cl- 250 ppm
    Conductivity 2000 µS/cm





    ppm = parts per million

    µS/cm = micro siemens per centimeter

    Calculate the number of cooling tower cycles by dividing the maximum allowed concentration level of each parameter by the actual concentration level of each parameter found in the potable makeup water. Limit cooling tower cycles to avoid exceeding maximum values for any of these parameters.

    Table 2. Points for cooling tower cycles

    Cooling tower cycles Points
    Maximum number of cycles achieved without exceeding any filtration levels or affecting operation of condenser water system (up to maximum of 10 cycles) 1
    Achieve a minimum 10 cycles by increasing the level of treatment in condenser or make-up water

    OR Achieve the number of cycles for 1 point and use a minimum 20% recycled nonpotable waterNonpotable water: does not meet EPA's drinking water quality standards and is not approved for human consumption by the state or local authorities having jurisdiction. Water that is unsafe or unpalatable to drink because it contains pollutants, contaminants, minerals, or infective agents.
    2



    Pilot Alternative Compliance Path available

    A pilot alternative compliance path is available for this credit to certain project types without cooling towers. For more information, please visit the Pilot Credit Library

    Pilot ACPs:
    No Cooling Tower - alternative compliance path (BD+C)
    No Cooling Tower - alternative compliance path (O+M)
    No Cooling Tower - alternative compliance path (O+M: Data Centers)




Design Submittal

PencilDocumentation for this credit can be part of a Design Phase submittal.

Potable Water Analysis Report

Here's an example potable waterWater that meets or exceeds U.S. Environmental Protection Agency drinking water quality standards (or a local equivalent outside the U.S.) and is approved for human consumption by the state or local authorities having jurisdiction; it may be supplied from wells or municipal water systems. analysis report, which indicates the level of each control parameter present the cooling tower makeup water for the example building. You'll need to get an analysis like this in order to complete the table on the credit form. The highlighted values correspond to the parameters tracked by this credit.

Analysis of Makeup Water

This sample calcuation from the LEED Reference Guide demonstrates how to calculate the maximum cycles of concentrationConcentration ratio is the ratio of the level of dissolved solids in the recirculating water to the level found in the entering makeup water. A higher concentration ratio results from a lower bleed-off rate; increasing the ratio above a certain point, however, leads to scaling, and water savings diminish after a certain level. This ratio is also called the cycles of concentration. Cycles refers to the number of times dissolved minerals in the water are concentrated compared with makeup water, not to water flow over the tower or to on-off cycles. for makeup water.

30 Comments

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Kristina Pobre Architect
Jun 02 2017
Guest
16 Thumbs Up

No Cooling Tower - Alternative Compliance Path

Project Location: Philippines

My project does not have a cooling tower. One of the ACP eligibility condition is: "the baseline system designated for the building using ASHRAE 90.1-2010 Appendix G Table G3.1.1 includes a cooling tower (systems 7 & 8)"

1. I would like to confirm if my project is no longer viable for this as ASHRAE 90.1-2010 Appendix G dictates that my baseline should be system 4.
2. Am I allowed to change my baseline to system 8 to be eligible to this credit?

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Rita Haberman Brightworks
Dec 20 2016
LEEDuser Member
415 Thumbs Up

Campus Cooling Tower

My project is not installing a cooling tower, but they will utilize the shared existing campus cooling tower. Can we achieve this credit with the campus-wide cooling tower, if it complies with the requirements? Thanks

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Trista Little Sustainability Manager, YR&G Jan 17 2017 LEEDuser Expert 6037 Thumbs Up

Hi Rita, I believe you can achieve this credit with a shared campus-wide cooling tower. There's nothing in the Reference Guide that I see that says otherwise.

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Theresa Backhus Sites Technical Specialist, LEED, USGBC Jan 24 2017 LEEDuser Member 1061 Thumbs Up

Rita, generally, yes, a shared campus cooling tower can be applied here, as long as it meets the credit requirements. Without knowing project details, it's hard to say how this applies in your particular situation. Consider who has ownership over, and manages, the cooling tower. Is it the same entity as the LEED project? You may also want to consider submitting this question to GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). for a more detailed answer that is specific to your project.

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Risto Beatty Feb 03 2017 LEEDuser Member 18 Thumbs Up

If non-potable waterWater that meets or exceeds U.S. Environmental Protection Agency drinking water quality standards (or a local equivalent outside the U.S.) and is approved for human consumption by the state or local authorities having jurisdiction; it may be supplied from wells or municipal water systems. is being sent to a campus cooling tower, do you need to offset 20% of the total potable water demand of the central plant or just the water attributed to the building?
We can use hourly data from the energy model to calculate the water demand attributed to our building alone. If we use site stormwater to offset >20% of this amount, can the credit still be met?

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Sara Johansson LEED® AP O+M Sweco Systems
Oct 27 2016
Guest
41 Thumbs Up

Dry cooling tower

Hi,

If a project has dry cooling, a type of cooling tower, can it than get this point? It is my understanding that there are several types of cooling towers, in Sweden we normally use dry cooling (cooling tower) with air and not water.

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Theresa Backhus Sites Technical Specialist, LEED, USGBC Jan 24 2017 LEEDuser Member 1061 Thumbs Up

Hi Sara, A dry cooling system typically falls under the "No Cooling Tower" Alternative Compliance Path (http://www.usgbc.org/node/5586086?return=/pilotcredits/New-Construction/all), and not this credit. You can use the ACP as long as your dry cooling system meets all of the conditions listed under Requirements. The general goal is to focus on reduction in water use through elimination of wet strategies like evaporative cooling.

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Apoorv Goyal Sustainable Design Specialist HOK Architects
Oct 11 2016
LEEDuser Member
2 Thumbs Up

Maximum Number of Cycles

Hi, based on a water test report, if the number of cycles already exceed 10, does that mean that both points are achievable? The calculations for the project indicate the lowest number of cycles (max. allowed / Test Number) to be 20.

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Trista Little Sustainability Manager, YR&G Oct 21 2016 LEEDuser Expert 6037 Thumbs Up

Yes, 2 points are earned if your project achieves at least 10 cycles based on the calculations outlined in the credit

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Manuel Martin Delgado Buro Happold Polska Sp. z o.o
Mar 30 2016
LEEDuser Member
160 Thumbs Up

Cooling tower cycles

Hi,

I am a bit confused with the credit requirements for achieving 1 point.
We have already the make-up water parameters and we have calculated the cycles of concentrationConcentration ratio is the ratio of the level of dissolved solids in the recirculating water to the level found in the entering makeup water. A higher concentration ratio results from a lower bleed-off rate; increasing the ratio above a certain point, however, leads to scaling, and water savings diminish after a certain level. This ratio is also called the cycles of concentration. Cycles refers to the number of times dissolved minerals in the water are concentrated compared with makeup water, not to water flow over the tower or to on-off cycles. for each one (lowest value is 1).

Do we just need to set the cooling tower to supply make-up water every cycle? is it required to have a minimum number of cycles for 1 point?

In case the fewest calculated cycle is less than 1, would it be accepted to supply make-up water every cycle?

Thanks.

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Trista Little Sustainability Manager, YR&G Apr 24 2016 LEEDuser Expert 6037 Thumbs Up

Hi BH, the Reference Guide doesn't appear to state a minimum number of cycles that's required to earn the credit. It sounds like your maximum number of cycles is 1 or less, which seems low. Is this number of cycles typical where the project is located? Are you confident in the results of the water analysis? You might want to reach out to GBCIThe Green Building Certification Institute (GBCI) manages Leadership in Energy and Environmental Design (LEED) building certification and professional accreditation processes. It was established in 2008 with support from the U.S. Green Building Council (USGBC). / USGBC if you're sure about the water composition and the max cycles. They might be willing to clarify if there's a minimum since v4 is still so new.

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Jade Deltour Engineer B4F
Oct 22 2015
Guest
19 Thumbs Up

Which parameters of the cooling tower?

Which parameters/performances of the cooling tower need to be checked/optimised to limit tower cycles to avoid exceeding maximum values?

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Trista Little Sustainability Manager, YR&G Nov 03 2015 LEEDuser Expert 6037 Thumbs Up

Hi Jade, the five parameters are listed in the credit requirements, and are Calcium (as Calcium carbonate), Total alkalinity, Silica, Chloride, and Conductivity.

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Gregory Martin
Sep 10 2014
LEEDuser Member
39 Thumbs Up

Is there a timeframe for the minimum number of cycles?

I am working on a presentation to educate my office on Lv4. This being a new credit I don't think I am totally understanding the requirements. The guidebook states "limit tower cycles to avoid exceeding maximum values". What is the timeframe you need to limit the tower cycles to in order to achieve the credit? It seems 24 hours would be applicable, but not being an engineer I really don't know how often a water tower cycles.

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Ashwini Arun Sustainability Manager, YR&G Apr 08 2015 LEEDuser Expert 224 Thumbs Up

Hi Gregory,

Water cycle or cycles of concentrationConcentration ratio is the ratio of the level of dissolved solids in the recirculating water to the level found in the entering makeup water. A higher concentration ratio results from a lower bleed-off rate; increasing the ratio above a certain point, however, leads to scaling, and water savings diminish after a certain level. This ratio is also called the cycles of concentration. Cycles refers to the number of times dissolved minerals in the water are concentrated compared with makeup water, not to water flow over the tower or to on-off cycles. for a cooling tower is basically the number of times the water can be recirculated before the dissolved chemicals become so concentrated that they cause scaling, thereby reducing the efficiency of the cooling tower system. A higher number of cycles indicate better water efficiency of the cooling tower since it less water is required. At the same time, if the water is recirculated too many times, the concentration of chemicals might increase beyond the acceptable limit. In order to be efficient as well as prevent a high concentration of chemicals in the water it is best to optimize the number of cycles and this what the guide refers to when it says "limit tower cycles to avoid exceeding maximum values". It is just best practice to limit the number of cycles to avoid high concentration of chemicals and hence there is no real timeframe to achieve this.
I hope that answers your question.

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Maria Porter Environmental Certification Engineer Skanska Sweden
Nov 26 2013
LEEDuser Member
3446 Thumbs Up

No cooling tower

If you have no cooling tower, do you automatically get the point or you are not eligible for the credit?

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Susan Walter Specifications Director, Populous Nov 26 2013 LEEDuser Expert 22894 Thumbs Up

Generally in LEED you have to do something in order to earn a point rather than avoid doing something to earn the point. Since this is v4, it really is a general statement. If you are conserving water in such a way that your project avoided the cost of a cooling tower, it would likely help you in an Innovation in Design credit.

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Tristan Roberts LEED AP BD+C, Executive Editor – LEEDuser, BuildingGreen, Inc. Nov 26 2013 LEEDuser Moderator

Susan is correct. I know that this point was debated in the development of this credit for v4, but you do have to have a cooling tower to be eligible for the credit.

As Susan notes, if you are avoiding a cooling tower you may be demonstrating good energy efficiency or innovation that would earn you points elsewhere.

If the credit rewarded simply not having a cooling tower, then unless it was worded carefully (and perhaps with some complexity) it would potentially be incentivizing other mechanical systems that would not be as good a fit.

On the other hand, it could be argued that simply avoiding a cooling tower should earn the point, because no one in their right mind would choose the wrong mechanical system simply to earn a LEED point.

Nonetheless, the requirement is clear—you must have a cooling tower.

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Maria Porter Environmental Certification Engineer, Skanska Sweden Dec 18 2013 LEEDuser Member 3446 Thumbs Up

Thanks guys for giving me clarification on the topic! Thing is though, none of my projects ever have cooling towers (we live in a cool climate and cooling towers are not used here at all in that sense). Are cooling towers always the best way to cool a building? Otherwise this credit seems that if you do it the best way you can, using the wrong strategy, then you will earn credit… If you on the other hand use free cooling or district cooling then you can’t earn credit.

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Tristan Roberts LEED AP BD+C, Executive Editor – LEEDuser, BuildingGreen, Inc. Dec 18 2013 LEEDuser Moderator

Maria, I sympathize with your point but I think it's simply a case where this credit was written to address a massive issue for thousands of buildings, and for some buildings it's simply not the best fit.

A farFloor-area ratio is the density of nonresidential land use, exclusive of parking, measured as the total nonresidential building floor area divided by the total buildable land area available for nonresidential structures. For example, on a site with 10,000 square feet (930 square meters) of buildable land area, an FAR of 1.0 would be 10,000 square feet (930 square meters) of building floor area. On the same site, an FAR of 1.5 would be 15,000 square feet (1395 square meters), an FAR of 2.0 would be 20,000 square feet (1860 square meters), and an FAR of 0.5 would be 5,000 square feet (465 square meters). bigger credit in terms of points available is LEED"s energy efficiency point. I don't see that it's likely that someone would use a less efficient cooling system to earn points here, while sacrificing points under energy efficiency, not to mention increased costs of ownership.

For the many projects that do typically use a cooling tower this credit gets them to think about reducing its impact.

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Maria Porter Environmental Certification Engineer, Skanska Sweden Jan 23 2014 LEEDuser Member 3446 Thumbs Up

I understand Tristan, thank you for your comments!

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Kathryn West LEED AP BD+C, O+M, Green Globes Professional, JLL Jan 23 2014 Guest 7601 Thumbs Up

Tristan, it would be helpful if you ask technical specialists this question Maria asks --just to confirm. You said you're meeting with them next week.

At Greenbuild some folks who participated in the Beta test for LEEDv4 said they got this credit even though they had a geothermal system with no cooling tower. They provided calculations showing how much water their geothermal system saved.

I am not sure if that was just giving them the benefit of the doubt because they were going through the beta test or if that could count on non-beta projects. Or maybe the person I spoke with as referring to an old rule. The rules were in flux as the beta-test went on, after all.

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Tristan Roberts LEED AP BD+C, Executive Editor – LEEDuser, BuildingGreen, Inc. Mar 07 2014 LEEDuser Moderator

I have re-confirmed with USGBC that simply not having a cooling tower does not earn you this credit.

They are working on some language that might be used as an alternative compliance path in the future, but it will be pretty stringent in having you show that you would have had a cooling tower in a baseline energy system, and managed to avoid it through a smarter design.

Regarding precedents for earning this credit, I was only able to confirm one project that has an open loop cooling system with a nearby water body, and did NOT earn the credit.

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Bazeeth Ahamed K M Conserve Green Building and MEP Solutions WLL Apr 30 2015 LEEDuser Member 111 Thumbs Up

It would be better to address the case of District Cooling, Can the project earn the point if District Cooling provider demonstrates compliance of the requirement?

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Ashwini Arun Sustainability Manager, YR&G May 04 2015 LEEDuser Expert 224 Thumbs Up

Bazeeth,

You should be able to pursue this credit even with the District Cooling System. As long as the District Energy Provider is able to demonstrate compliance, I think it still meets the intent of the credit.

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Trista Little Sustainability Manager, YR&G Nov 03 2015 LEEDuser Expert 6037 Thumbs Up

I wanted to jump in here and mention that a pilot credit is currently available for certain project types that do not have cooling towers. See the "Pilot Alternative Compliance Path Available" section above / check out the pilot credit on USGBC's website (www.usgbc.org/node/5586086?return=/pilotcredits/all/v4).

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Carmen Mielecke CEO, LCEE Life Cycle Engineering Experts Jan 12 2017 Guest 11 Thumbs Up

Hallo Trista,
does the mentioned "Pilot Alternative Compliance Path" above allow to replace the credit "Cooling Tower Water Use" so that the related points can be achieved in the category Water Effieciency or does the achievement of this credit only conbtribute to the category "Innovation"? Thanks in advance for your answer!

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Trista Little Sustainability Manager, YR&G Jan 12 2017 LEEDuser Expert 6037 Thumbs Up

Hi Carmen, in this case the pilot credit takes the place of the standard cooling tower WE credit (it's basically a different path for compliance for that credit). The points would be earned under the WE category, not under the Innovation category. This is confirmed by the USGBC link I posted before at the top of the page directly under the Requirements section. Thanks!

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Carmen Mielecke CEO, LCEE Life Cycle Engineering Experts Jan 13 2017 Guest 11 Thumbs Up

Hi Trista! Thank you very much! This is really good to know!

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Martina Salonen Consultant, Ramboll Jul 19 2017 LEEDuser Member

Hello, related to the previous comments: We have project which would be applicable for the 'no cooling tower' alternative complience credit. However, the client is now considering connection to the district cooling system. Do I understand correctly that this would make the project automaticaly uneligible for the credit? Can someone explain me the intent behind this requirement : 'the project does not receive any cooling from a District cooling system' ? Is it that district cooling would use higher amount of water? Also Ashwini previously mentioned that : You should be able to pursue this credit even with the District Cooling System. As long as the District Energy Provider is able to demonstrate compliance. -> What does this mean in practice? That district energy provider is not using water tower nor evaporative condensers? Thanks for the help!

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