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 water, and that no garbage disposals are installed on the project. The Template also indicates that all process water 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 Tag. 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.
Andrea Traber
Director, Sustainable Buildings and OperationsKEMA
62 thumbs up
February 5, 2010 - 7:58 pm
How very unfortunate. Your team clearly had a solid grasp of the intent of the credit, met it (in my opinion) and documented it adequately. It is very frustrating when nuanced interpretations are made and appeal is the only remedy. Though you understandably chose not to appeal the decision, there may be value in forwarding this experience back to the TAG and USGBC staff for informational purposes, as it would at least suggest that this credit requires clarification. In my view this is one reason why the current CIR process (not posting them) is not satisfactory; It does not allow for "daylighting" difficult issues or provide a method for educating future users. Thank you for sharing your painful experience with other interested LEED users.
Patricia Brezny
Project DesignerSfL+a Architects
5 thumbs up
November 8, 2010 - 1:43 pm
Michelle,
This info may be too late to act on, but I was looking for info about GPM vs. GPH for WEc4 and downloaded the latest (Nov. 3 2010) addenda for LEED for Schools v.3.
The Addenda Item that would help you was posted on 7/19/2010 well after your credit was rejected and states for WEc4: In the first line of the third bullet item, replace "At least 4 process items" with "All appliances within at least 4 equipment types"
The USGBC Addenda website states "Project teams are required to adhere to the Rating System addenda based on registration date." That requirement should not apply to your project which was submitted prior to the addenda. I would make a big deal about it. GBCI should be required to follow the rules established by USGBC and not make up the rules as they go.
RETIRED
LEEDuser Expert
623 thumbs up
December 8, 2010 - 10:43 am
Patricia – Thanks for directing me to this resource (and thanks Tristan for pointing me back to Patricia’s comment).
I just realized that my inquiry was posted under LEED 2009 but the credit was actually denied under LEED for Schools v2.0. Sorry I did not make that clear at the top of the post. The language of the credits was the same in both versions until the 7/19/10 addendum item for WEc4 (http://www.usgbc.org/ShowFile.aspx?DocumentID=6392 (see page 21)).
That addendum item is a great clarification for LEED for Schools 2009 teams; however, I don’t think that this would change the situation for my project (even if I could utilize an addendum item from another version of the rating system to set precedent). Maybe they even used our project as a reason to change the language?
I think USGBC has greatly improved the requirements and made it clearer for other teams though and this will help them avoid a situation like we had (we only had 3 equipment types – not the now required 4 – but we had addressed all appliances within those 3 equipment types for a total of 5 process items). I still think we got a raw deal but we’ve moved on and I’m glad other teams won’t have to have this credit denied thanks to the new language.