We have been turned down by GBCI for our documentation for an ID credit for the documentation we presented. Does anyone have advice on how to document and earn and ID credit for chemical free treatment of water for process water? See the narrative we put together below.

Technical advise given from reviewer: Please provide the following.
1. Evidence of the quantitative performance improvements (establishing and comparing a baseline to the final design case) of this strategy.
2. Evidence of a comprehensive strategy. Note that in order for a strategy to be comprehensive, it must incorporate more than one product or process.

Narrative from our template: The magnetic water treatment system described here is being used to treat water from the blow-down from the (2) 73-ton packaged HVAC units which are evaporatively cooled.

In order to treat process water without toxic chemicals, a safe low DC current (like that of several flashlight batteries) is passed through a set of copper and silver alloy anodes. As the water passes through the sealed chamber, metallic ions are generated to purify the water. The microscopic action of the ions with the algae and bacteria are twofold. First, the algae and bacteria are destroyed through a change in their enzyme processes. Second, all these charged particles flock together and then they are discharged with the blow-down of cooling towers or pulled out by a filter. The ions maintain a stable sanitizer residual in the water. See uploaded document titled "Descal_A_Matic.pdf" for more information as well as letters from several previous clients (including the Army Corps of Engineers) documenting that their equipment is operating successfully. It is estimated that this alternate process water treatment is saving 70 gallons of chemicals, such as Sanacor 2605 C Inhibitor, each year in 41,000 gallons of water discharge at the Zion facility. The list of benefits over conventional chemical treatment also include:

-Prevents scale build up - molecules that cause scale tend to remain in fluid suspension instead of attaching to pipe walls and other surrounding surfaces, thereby decreasing or eliminating the need for chemical flushing agents
-Reduced corrosion and increased durability on water conveyance equipment - NASA tested magnetically vs chemically treated water and found that magnetically treated water did not contribute to corrosion at all while chemically treated water produced corrosion rates of up to 50 mils per year. Therefore, magnetically treated water drastically increases the life of piping.
-Reduced energy costs - the US Bureau of Standards has found that just a 1/16th of an inch of scale build-up in piping results in a 15% increase in additional energy to convey water. Magnetically treated water creates no scaling/build-up and therefore reduces energy costs in comparison to chemically treated water.