USGBC and LEED 2009

Comments Sought on Ratings and Credits for Water Efficiency

The Alliance for Water Efficiency wants to call your attention to the opportunity to express your views regarding the U.S. Green Building Council’s LEED (Leadership in Energy and Environmental Design), LEED 2009, rating system and its water efficiency related credits.  The various LEED products are available for comment  and now is the time “to speak up, or forever hold your peace”. There are many issues related to the Water component of LEED that need input and recommendations from the water community.

Most of you are somewhat familiar with the U.S. Green Building Council’s LEED  Program.  LEED was conceived to foster the implementation of “green” design and practices into new and existing buildings of the most common types.  But, water efficiency has been a relatively minor component of the various LEED products since the inception of the Program.  As the Program has matured, much has been learned and achieved with its execution in the marketplace. During this time, though, the water efficiency provisions in LEED have not progressed significantly.  The time has come to bring the LEED products “up to date” such that they recognize the significant evolution of water use efficiency practices, products, and technologies since EPAct of 1992.

The USGBC’s recent call for comments (http://www.usgbc.org/DisplayPage.aspx?CMSPageID=1849) on proposed changes to LEED (known as LEED 2009) was timely and very welcome.  This opening to offer our suggestions for changes to LEED is our opportunity to express our ideas and concerns to the organization about water efficiency and its importance to both new construction and existing buildings of all types.  Therefore, the AWE encourages you to visit the link above, review the documentation provided, develop your ideas and recommendations, and submit formal comments within the prescribed comment process.

There are many documents available for download from the site and most of us will not have the time to carefully examine all of them.  Therefore, we strongly suggest that you visit the LEED primary website and read the following:

  • For an excellent overview of the entire proposal, click on and read the LEED 2009 Vision & Executive Summary: www.usgbc.org/ShowFile.aspx?DocumentID=41211  
  • Next, for an understanding of specific elements of and proposed changes to the two dominant LEED products, examine the ratings system changes for New Construction and Existing Buildings by:
    • Clicking on New Construction on the primary website & reviewing pages 30-35 of document titled LEED 2009 - New Construction Redlined Rating System.pdf    
    • Clicking on Existing Buildings on the primary website & reviewing pages 23-28 of document titled LEED 2009 - Existing Buildings- O&M Redlined Rating System.pdf
  • Finally, if you have time, then also review and comment on the proposed ratings system changes for Core and Shell, Commercial Interiors, and Schools, each of which may be accessed from the primary website.

Water efficiency within the LEED process is addressed on a technical detail level by the Water Efficiency Technical Advisory Group (WETAG), appointed in 2003 by the USGBC to bring the necessary water expertise into that process.  The WETAG currently consists of 11 members and is soon to be expanded by USGBC to include another 4 or 5 members, all of whom are specialists in the areas of water-efficient practices and technologies.  The AWE is represented on the WETAG and has been active in seeking changes to the water efficiency chapters in all of the LEED products since January 2004.  The primary goals of those changes are (1) to bring LEED current in terms of best-available technologies and (2) to improve the “coverage” of the water efficiency chapters to embrace more areas of water use within a building or project.  Unfortunately, such improvements have been minimal and, as such, most of the indoor water use calculations in LEED have been relying solely upon plumbing fixtures covered in EPAct 92, largely ignoring or minimizing the other elements of potential indoor water use.  We hope that your comments (and those of the AWE) will serve to “open the door” to needed changes.

One of the most significant and overdue changes that has already been proposed for LEED 2009 by the WETAG is that of the WE Credit Prerequisite 1, which would now require that projects achieve a minimum 20 percent reduction in water use (over EPAct and codes).  Previously, meeting this criteria was optional.

Other specific items that are not currently addressed or minimally addressed that need to be considered as comment areas are: 

  • Increasing the credits for the use of municipally reclaimed water for landscape irrigation and selected indoor processes where reclaimed water is approved for such use.
  • Incorporating prohibitions against once-through cooling on all equipment, processes and appliances where alternative technologies exist.
  • Specifying maximum water use thresholds for residential appliances where such do not currently exist, such as clothes washers, dishwashers, drinking water treatment systems, water softener systems, and ice-makers.  This is particularly important for the LEED-EB and -NC products that cover large mixed use projects with a residential component.
  • Adding a specific requirement for WaterSense-certified products as the only option for credit (where those products are available).  For example, in spite of WETAG insistence, LEED-Homes does not mandate WaterSense HETs, which means that non-WaterSense HETs could be selected that may, in fact, be inferior performers and result in poor customer satisfaction.
  • Adding specifications that incorporate ETo for landscape irrigation design.
  •  Incorporating limitations on turfgrass and its irrigation with potable water, crediting the use of alternate sources of water for all irrigation.
  • Incorporating credits for the use of weather-based irrigation controllers should be encouraged where regionalization indicates that landscape irrigation systems are prevalent.
  • Incorporating specifications covering water features (pools, spas, ornamental fountains) regarding backwash water filtration and reuse.
  • Providing specifications for cooling tower design and operation should be incorporated into LEED, encouraging those measures and technologies that have been proven as viable water use reduction practices.
  • Specific water use requirements should be incorporated for specialty medical and laboratory equipment, including vacuum systems, sterilizers, X-ray systems, and other water-using equipment.
  • Adopting specifications for water use maximums for food service equipment and fittings, such as ice-makers, steamers, combination ovens, and pre-rinse spray valves.
  • With the goal of eliminating or reducing the impact of our wastewater on treatment and the environment, encouraging the removal of waste from wastewater flows before it leaves the project site.
  • In credits calling for percentage reductions of indoor water use (e.g., 20%, 30%, 40% and 50%), basing calculations upon real world measurements to establish baseline water use.  Currently, these calculations are entirely based upon engineering estimates, because real world water use data for non-residential applications are not readily available. A concerted effort to gather this data is critical to the veracity of the savings claims made by project applicants.
  • Requiring water sub-metering of tenant and sub-tenant spaces, cooling towers, and selected process operations meeting selected minimum size thresholds. Given that little reliable data is available about the actual consumption of the many types of fixtures and fittings in non-residential buildings, the recording of this consumption by individual submeters is necessary.