Schools 2009 WEc4: Process Water Use Reduction

Do Cooling Towers Count for LEED for Schools WEc4?

The credit language says to avoid "once-through refrigeration" equipment, which could mean chillers, I suppose, but from the context seems more likely to be about food refrigeration. The Reference doesn't say anything at all to clarify this, except that it shows a cooling tower in the "examples" section.

I guess, since there are no calculations for this credit but just a list of fixture types to prefer/avoid, you'd have to avoid once-through cooling towers as well to claim the point. Does that seem right?

What about if no-use at all of 4 of the 5 mentioned equipments?

If in the school kitchen there is a dishwasher with the required performance and no one of the other 4 water consuming equipments listed in the requirement, together with the compliance to the other requirements, can we get the credit?
The best "process waterProcess water is used for industrial processes and building systems such as cooling towers, boilers, and chillers. It can also refer to water used in operational processes, such as dishwashing, clothes washing, and ice making. use reduction" is no-use at all process water, isn't it?

GBCI rules it is 4 Categories, not 4 Items, and denies credit

I recently had this credit denied by GBCI and the logic they used was unsettling.

Our clarification request stated: stated: “The LEED Submittal Template has been provided stating that the project has maximized water efficiency within the building through the installation of ice machines, dishwashers, and pre-rinse spray valves. The Submittal Template indicates that no refrigeration equipment was used in the project that uses once-through cooling with potable waterPotable water meets or exceeds EPA's drinking water quality standards and is approved for human consumption by the state or local authorities having jurisdiction; it may be supplied from wells or municipal water systems., and that no garbage disposals are installed on the project. The Template also indicates that all process waterProcess water is used for industrial processes and building systems such as cooling towers, boilers, and chillers. It can also refer to water used in operational processes, such as dishwashing, clothes washing, and ice making. use equipment is less than or meets the maximum water use LEED allowable limits.

However, per the requirements listed in the LEED for Schools v2.0 Reference Guide for WEc4, the project must include at least 4 process items. Please note that while the project has listed 5 pieces of process equipment that meet the water use levels, only 3 categories of process equipment are listed. Each category of process equipment may only be counted once towards the credit requirements, because it is assumed that each piece of process equipment in each category meets the water use level requirements in full. This same implication requires that all process equipment included in the project under each category must meet the water use level requirements.

TECHNICAL ADVICE: Please provide a revised Template demonstrating that the project includes at least 4 categories of process water equipment in which all equipment in each category meets the water level use requirements for this credit."

I contacted Christopher Davis at GBCI who then contacted the WE TagLEED Technical Advisory Group (TAG): Subcommittees that consist of industry experts who assist in developing credit interpretations and technical improvements to the LEED system.. He wrote: “I have confirmation from the Water Efficiency Technical Advisory Group that “item” in the credit requirements is intended to refer to a category of items. This is intended to prevent, for example, projects that may have 5 dishwashers when only one meets the credit requirements. Note that the credit also allows you to propose your own benchmark against which to compare equipment that could be used to meet the requirements...”

We attempted to build a case around this and even contacted USGBC Schools staff who believed we had made a good case and said they would go to bat for us on this. We wrote in our clarification response memo: “While we both acknowledge and agree with the logic of this clarification to avoid unintended consequences, we designed the project under the assumption that we needed 4 process items. In addition, we worked hard to design the project’s kitchen to meet the requirements of this credit including no garbage disposals and no refrigeration equipment using once-through cooling with potable water. We then followed guidance in the Reference Guide to assess all processes in the building that used water to identify opportunities for selecting high-efficiency equipment. All items in the categories of commercial dishwashers, ice machines (both classes), and pre-rinse spray valves at XXXX meet the credit requirements. We do not have any commercial clothes washers on the project. We do not have any food steamers on the project and purposefully eliminated this equipment category due to its water intensive nature. As far a commercial water using equipment goes, we do have a combination oven that does both convection cooking, steaming, and a combination of both but since it is not just a “food steamer” we would have to come up with another water use benchmark. Upon investigation we learned from our Food Service Consultant that we could not find a water efficient model although our combi oven is boilerless. So unfortunately we cannot propose a benchmark for that piece of equipment. We do not have any other new commercial process water using equipment on the project.

In order to meet the reviewer’s request to have another category, we looked throughout the school for water using equipment. We do a have a residential dishwasher in the Family and Consumer Services classroom. In light of our water conserving ethic for the school, we went to great lengths to specify this residential dishwasher as energy and water efficient earlier in the project. We utilized BuildingGreen’s GreenSpec category of residential dishwashers when specifying it. It states: “Most of the energy consumed by dishwashers is used to heat the water; therefore, water-efficient dishwashers are also energy-efficient. As with other home appliances, national energy standards have catalyzed the development of more efficient dishwashers. As a measure of efficiency, the Energy Factor (EF) describes energy performance under carefully defined conditions, and provides a basis of comparison among different models. The national energy standard requires all regular size dishwashers to have an energy factor of at least 0.46. The Energy Star program qualifies dishwashers exceeding that standard by at least 25% (EF of 0.58)….”

GBCI responded when they denied our credit: “The project team has provided a revised Template demonstrating that the project has included 3 categories of process water equipment (ice machines, dishwashers, and pre-rinse spray valves). A supplemental narrative has also been provided to describe the project's strategy for attempting this credit.

However, while the Template and narrative demonstrate that all six process water equipment items meet the water level use requirements for this credit, the project has not demonstrated that at least 4 categories of process water equipment have been included on the project, as required. Please note that the Residential Dishwasher is not considered a category separate from "dishwashers." Please also note that while the project's strategy for attempting this credit is commendable, not all credits apply to all projects. The documentation does not demonstrate credit compliance.”

They had no idea how much effort we went to get the district to remove garbage disposals in the kitchen and well as the lengths we went to adhere to all the credit requirements and then they changed the requirements on us. I hope no one else has this experience. Our team decided to not pay the $500 to appeal this because we felt it was a waste of money.