We are pursuing this pilot credit as ACP for a Swedish Project. We Think it is fair that Projects without cooling Towers can achieve the no cooling Tower credit too, since you do not use any water for cooling Towers if you do not have them.
We however Think the requirement that the building cannot be connected to district cooling needs to be changed since most Swedish district cooling nets do not utilise cooling Towers, instead they use backside of heat pumps, seawater-cooling, chillers etc so no water is used. The language should say that district cooling nets that do not have cooling Towers are allowed and that district cooling nets with cooling Towers can get the cooling Tower credit if they fullfill the credit requirements.