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Credit Interpretations

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WATER EFFICIENCY: Water Efficient Landscaping () 3/18/2009 Credit Interpretation Request Our landscape design on a major university campus utilizes exclusively native and adapted plantings. The university does not use permanent irrigation systems for the bulk of its campus landscapes. Accordingly, the project will incorporate a temporary system designed to support the needs of plantings during the initial establishment period. Aware that the USGBC allows temporary irrigation systems to operate for one year only, the maintenance staff have expressed serious concerns that this will not allow enough time for adequate plant establishment. It has been their experience that the soil, weather and seasonal extremes in this location require a minimum 2-year establishment period. The facility manager has used 1 year temporary systems in the past which led to the death of large plant material quantities and the loss of substantial economic resources. Upon reviewing previous CIRs, the design team noticed another project description which mentioned the use of temporary irrigation systems for a 2 year duration (see CIR for WEc1.2 dated 08.29.2005). In light of the direct experience of the maintenance staff, the language used in the ruling of the CIR mentioned above, and in the interests of conserving material and economic resources, the design team would like to attempt to satisfy WEc1.2 with a two year, temporary system. The design team would like to install the most cost-effective, environmentally sound and resource conservative irrigation system possible for the duration of the proposed 2 year plant establishment period. As such, we see significant economic and environmental disadvantages to using drip irrigation exclusively. Drip irrigation systems apply water to plant material more efficiently than spray heads and impacts but require more investment in labor and plastic tubing that will ultimately end up in a landfill. The proposed system will be a combination of impact heads and drip tubing where they are appropriate for the landscape type, surrounding site programming and character of the landscape aesthetic. While this practice will conserve more water than a traditional system because its short term use, it is unlikely to achieve 50% water use reduction compared to a baseline case. To clarify, are the temporary irrigation system allowed by credit WE1.2 subject to the 50% reduction in irrigation water use specified in WEc1.1? In addition, while it may be implied, we can find no place in the reference manual where it explicitly states that a temporary system can be run using potable water. Is this allowed? 4/22/2009 Ruling The project team is asking 3 questions concerning their temporary irrigation to be used for plant establishment. The first question is concerning the length of the plant establishment period. The LEED-NC 2.2 rating system states that temporary irrigation is allowed for plant establishment only if removed within one year. The CIR referenced is for a previous version of LEED-NC and is therefore not applicable to a LEED-NC 2.2 project. The second question is asking if the temporary irrigation system is required to meet the 50% water use reduction required by WEc1.1. There is no efficiency requirement for the temporary irrigation system, however a more efficient system that reduces the water consumption during the establishment period is of course encouraged. However, the project team should note the irrigation system installed must be temporary and easily removed. All or substantial portions of the irrigation system must be removed so as to disable the irrigation system after the one year establishment period. However, the strategies proposed are laudable and encouraged. The third question asked by the project is whether or not potable water is acceptable for temporary irrigation during the performance period. Potable water is allowable for the temporary irrigation within the plant establishment period. Any irrigation beyond the first year of establishment must be non-potable to meet the credit requirements of WEc1.2. 3/6/2009 Credit Interpretation Request The mechanical systems for this project are geothermal in design. Non-domestic use well water is supplied via a closed loop to an isolated heat pump heat exchanger to provide climate control of the building. The uncontaminated well water is then returned to the ground via a separate well, at a location different from where it was extracted. We would like to use a portion of this discharge well water for site irrigation. Our question is; will this water be considered a non-potable source to help achieve WE Credit 1.2? Our opinion is that this returned well water should be considered non-potable since its use in the irrigation system is secondary to the use of the geothermal system. Also, in using this water in the irrigation system, it is being applied to the landscape and provides a positive impact on the ground water table in the fact that it will replace soil moisture that would have been evaporated from the soil surface and therefore diminishing the moisture levels deeper within the soil profile. A certain portion of this water will also migrate through the soil profile back into the water table. 4/8/2009 Ruling The applicant is requesting approval to use water extracted from the outlet of an open-loop ground source heat pump for irrigation. The proposed approach does not satisfy the intent of the credit. The irrigation water would be provided indirectly from natural subsurface water to provide a condensing/heating source for the ground source heat pump. The LEED-NC v2.2 Reference Guide states that the credit intent is to limit or eliminate the use of potable water, or other natural surface or subsurface water resources available on or near the project site, for landscape irrigation. This issue has also been addressed by CIRs dated 1/13/2003, 10/23/2001, and 6/9/2008. 2/23/2009 Credit Interpretation Request The project is a office building in Long island. We are planning to apply for credit WE 1.1. The project site is 2,295,612 SF. The planted areas on the site is 1,511,942 SF. A portion of this planted area will be left natural and the rest will include landscape design . We are planning to install irrigation in a 112,221 SF area planted with grass and shrubs. It is not clear to the design team which areas may be

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included in the calculation. Can we use all of 1,511,942 SF of planted area including the natural untouched areas to earn a point for this credit? 4/8/2009 Ruling A project may not include planted areas in the irrigation calculations if these areas are intended to be left in a natural state, and not therefore require irrigation. Only landscaped areas can be included in the calculations for this project. Please refer to LEED-NC v2.1 CIR ruling dated 3/23/2004 for additional guidance. 10/23/2008 Credit Interpretation Request Our project is a large 22,000 acre master plan located in Saudi Arabia. The entire master plan will not be seeking LEED Certification, however, the 4.5 million square foot University located within the master plan will be seeking LEED NC Multi-Building Certification. All condensate, gray water, black water and storm water from the entire Master Plan and the University is being collected and sent to a waste water treatment plant built for the Master Plan. The Waste Water Treatment Plant is designed to handle a daily flow of 9500 M^3/ day. The waste water is treated to tertiary standards. All the waste water from the plant is then used to provide irrigation for the Master Plan. The daily production of waste water is not large enough to handle all the irrigation needs of the master plan, however, through the reuse of this University waste water, the project is eliminating the use of potable water, or other natural surface or subsurface water resources, for specific portions of the master plan. We feel that this meets the intent of the Credit. The waste water plant output will provide all the irrigation needs for a nearby golf course, thereby eliminating the use of potable water for the golf course. This golf course uses the entire output from the waste water treatment plant. Implementing local water reuse treatment for each master plan building was a non-cost effective, non-efficient strategy. Waste Water reuse plants at a larger scale are more efficient for a development of this type. If the University landscaping consists of native plantings that allow for a 50% reduction in potable water use from the baseline, does this strategy allow for the University to achieve WE Credit 1.2: No potable water use? 2/10/2009 Ruling The CIR is inquiring whether the University project would achieve WE credits 1.1, 1.2 and 2 if wastewater from the site was treated to tertiary standards at an offsite Waste Water Treatment Facility (WWTF) and is then used to irrigate a golf course within the overall master plan community (but not within the LEED project boundary of the University). The WE credit 2 compliance path that this project is suggesting requires that wastewater be treated onsite to tertiary standards, which the project is not doing. While it is commendable that the project is treating contaminated water sources to tertiary standards offsite, the project cannot achieve WEc1.1 and 1.2 for the University project since the LEED project itself is not utilizing the treated wastewater. While certain campus credit compliance paths have been allowed in previous CIRs, please note that CIRs may not set precedent and are decided upon on an individual project basis. Campus approaches tend to apply to those projects incorporating sustainability practices campus-wide, but which are unable to document those practices on a individual project basis. If the project were to use water from the WWTF on the University campus for all irrigation purposes, and the water from this WWTF was conveyed specifically for non-potable uses, this would meet the requirement for one WEc1 credit. In addition to using only non-potable water for irrigation, if the University project can demonstrate a 50% reduction in total irrigation water consumption from a baseline case, it will be eligible to earn both WEc1.1 and WEc1.2. If the project can eliminate potable water use for all the landscape then project will comply with WEc1.2. 6/4/2008 Credit Interpretation Request The project is a renovation of a part of a student residence hall, which is part of a large university campus facilities program. Thus, drip irrigation is not proposed due to its higher maintenance requirements. The Reference Guide provides only two methods of irrigation in order to calculate efficiency: spray and drip. Spray irrigation is rated at 62.5% efficient while drip irrigation is rated at 90.0%. We feel there are more than just two options to calculate irrigation efficiency (IE) as it pertains to this credit. Not all at-grade irrigation equipment should be generalized as "spray" irrigation. There are fixed-arc spray heads, which have efficiencies as suggested by USGBC, and there are rotary heads that are more efficient. Rotary heads can provide a greater radius of coverage and dispense water at a lower precipitation rate. For the larger turf areas at this site, rotary heads provide higher uniformity. We can prove with credit submittal documentation that the IE of rotating sprinkler heads at a minimum is 75.0%. Rotary heads will not cover all turf areas; the remainder will have to be covered by fixed-arc spray heads. We are partitioning water consumption calculations in the design case by irrigation method and assigning the appropriate IE to each. Shrub areas are proposed with fixed-arc spray heads. The fixed-arc spray heads proposed have a pressure-regulating feature that reduces pressure at the nozzle to an optimum level. Fixedarc spray head nozzles are designed to dispense a certain amount of water over a given area. A properly pressurized spray head and nozzle issues water droplets that are sized so as to not be affected by wind and sun and throw the proper distances. When pressure is too high, water droplets become finer (mist) and the spray patterns become distorted from slight breezes. This effect decreases efficiency, requiring longer irrigation times and more water to be dispensed in order to obtain the proper net result. Not all heads have the pressure-regulating feature. Heads that do contain this feature regulate pressure to their optimum of 30 psi. 60-psi pressure at the spray heads is available. Per the manufacturer's data (to be submitted), water consumption with pressure regulation is 71.0% of

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standard fixed-arc designs. Rotary heads do not have this feature and require the full 60-psi available. Irrigation controls are intended to automatically adjust watering times based on local climate conditions. Conventional controllers are set to turn irrigation on at the same time everyday for the same duration. The campus utilizes a central control system with weather station to manage irrigation duration. Evapotranspiration (ET)-based controllers receive central control signals and adjust irrigation times based on daily weather. Rain sensors enhance water savings further by suspending the daily irrigation cycle depending on how intense rainstorms are. The irrigation engineer calculates that an ET-based controller dispenses only 61.1% of the water used by a system with typical controls in the month of July at our location (to be submitted). In the spirit of controller efficiencies as suggested in the Reference Manual, we request that the USGBC allow us to expand the credit calculation analysis to include the efficiencies and reductions expected by specifying rotating heads, pressure-regulating heads, and ET-based controlling. Our project will have at least a 53.6% reduction in potable water consumption during the month of July compared to typical irrigation system with the same landscaping scheme. 6/19/2008 Ruling The project is requesting clarification on whether or not efficiencies other than those associated with spray and drip irrigation heads (0.625 and 0.9 respectively) can be used in the calculations to determine total water applied. The use of alternate efficiencies for different types of irrigation heads is acceptable. However, similar to the percent reduction in water use attributed to ET-based controllers, the reported efficiencies of alternate irrigation head types must be supported by manufacturer documentation or detailed calculations by the landscape designer or irrigation engineer. The supporting calculations for the design irrigation head efficiency cannot simply be based on a comparison to the usage rate seen in a less efficient standard or baseline irrigation head as suggested by the CIR. The reported efficiency of any irrigation head type must be a measure of the amount of water that actually reaches and is used by the plant materials and must address both evaporation and drift losses. ET-based controllers are already accounted for in Equation 3 as detailed on page 121 of the LEED-NC v2.2 Reference Guide. Further, the percent reduction in water use attributed to any weather-based controller or moisture sensor-based systems must be supported by manufacturer documentation and detailed calculations by the landscape designer or irrigation engineer. Partitioning the project into areas by irrigation type is acceptable. However this does not exempt the project from demonstrating compliance with the water use calculation methods detailed in the Reference Guide. For example, the areas that are partitioned by irrigation type must obviously also take into account sub-areas with specific plant types, microclimates and densities. These sub-areas will have distinct evapotranspiration rates which should be calculated using the appropriate landscape coefficient (KL) for that area. 6/4/2008 Credit Interpretation Request Our project includes a college dormitory in eastern Washington, a climate with summer droughts. Significant areas will be densely planted with drought tolerant native plants, and a the project includes a small lawn. Reclaimed roof water will be used to irrigate the lawn. At the native planting areas most likely to be impacted by humans, larger installation sizes are planned, requiring more than one year of irrigation, so a permanent but seldom used system will be installed, mostly just to establish plants. At several other areas, plants will be installed at small enough sizes to allow establishment using temporary irrigation for one year. We have reviewed relevant CIRs related to temporary irrigation and have the following questions: QUESTION #1: Do the following meet the requirements for removal of temporary irrigation after one year? Contractor will be required as part of the contract to remove all temporary irrigation zones at end of one year, including all pipes, valves and sprinklers. Owner will also certify in writing that temporary system will be removed. QUESTION #2: Do the following installation techniques meet the requirements for temporary irrigation? All PVC pipes and valves will be pinned directly to the surface of soil. Sprinkler bodies will be buried, but immediately attached to pipes on the surface. RATIONALE FOR THE ABOVE PROPOSED TEMPORARY IRRIGATION SYTEM: System will be drained during winter (November to April), thus no soil cover is needed. Surface piping is less likely to be retained after establishment than underground systems, because of undesirable appearance. Surface piping causes less disturbance to remove than drip tubing because there are so few pipes involved. Large radius spray heads/rotors will be used, because they can be spaced widely, resulting in a bare minimum of piping and quantity of sprinkler heads. Due to high density of our plantings, drip irrigation would require much more total material to irrigate all plants, would be more difficult to remove, and would cause more disturbance to planting areas at removal. For example, one large planting area will contain native plants spaced 16" apart, with seed applied between. A large quantity of dripline would be required to irrigate this, and disturbance would be significant at removal.

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Pop-ups will be used (vs. fixed, rigid risers), to protect from vandalism -- heads will be tucked into soil, disappearing from sight when not in operation, even though attached immediately to surface mounted pipes. Vandalism is a significant problem on this college campus. The university does not want the liability of above ground spray heads attached to stakes and the danger that can pose to careless students. QUESTION #3: Would any of the options below also meet the requirements for temporary irrigation? Covering mainline and lateral lines with mulch to help prevent vandalism. OR Painting surface mounted pipes a dark color, to help prevent vandalism. Burying mainlines but not laterals lines. At end of one year, laterals would be removed, but mainlines remain so that quick couplers may be used later for hand watering during periods of extended drought. 6/19/2008 Ruling The project would like to permanently bury the mainline of a temporary irrigation system and remove the rest of the irrigation system within one year of installation. The mainline would remain in place so that quick couplers could be used for hand watering. Although the applicant is proposing to only remove a portion of the irrigation system, the portions that will be removed can be removed easily and this removal will then completely disable the automated irrigation system. Therefore, this strategy meets the intent of the requirement. The mulch covering and the pipe color do not affect this ruling. Please provide a letter from the owner verifying that the entire system, with the exception of the main lines, can be easily removed and will be removed within one year. A contract for removal is not necessary although it would be desirable. 5/21/2008 Credit Interpretation Request This question is regarding the applicability of a process water re-use and treatment system for WE credits 1.1-3.2. Our coastal project is proposing the use of a ground-coupled open-loop heat rejection system with a side-stream desalination plant. The system draws non-potable brackish water from the ground, rejects heat from cogeneration and HVAC systems into the water and returns the rejected process water to the ground. The water is not potable source water (e.g. sourced from potable watersheds such as lakes and rivers) and stringent environmental regulations are in place with regard to pumping rates / volume, and quality of the return water. Approximately 10% of the rejected process water flow is diverted for re-use in the building. The diverted water is treated using a reverse osmosis desalination system. The treated water will be used onsite for irrigation and conveyance. Benefits of this system include a reduced impact on the already taxed local potable water supply, reliability of water source, and environmental benefit due to on site treatment and re-use. We believe we should be able to take credit for the municipal water savings resulting from this system, provided that energy use from the system is included in energy calculations. Please provide guidance for credit applicability. 6/9/2008 Ruling The applicant is inquiring as to acceptability of a process water re-use and treatment system for WE credits. In previous CIRs, recycled on-site water (such as water from a cooling tower) has been accepted for credit compliance. However, in this case, the portion of brackish water not returning to the ground from the ground-coupled open loop rejection system, which would be diverted for re-use on site, can not be used as is. Before this water could be put to any use, it would require going through Reverse Osmosis (RO) treatment which is an energy intensive process. The applicant is correct in suggesting that using this water would reduce/eliminate the need to use municipal potable water for landscape irrigation. In order to take credit for using non-potable water the energy use to desalinate the water must also be included in the EAc1 calculations. In addition, it should be noted that the intent of this credit is to encourage water efficient or xeriscape landscaping practices, which require little to no irrigation and/or use no potable water for irrigation. Hence, the project team should be ready to document the overall approach towards meeting the intent of the credit. 4/14/2008 Credit Interpretation Request This project is seeking a ruling in regards to using the pond water on site for irrigation. The pond is feed by both storm water run-off and partially spring fed. The Owner wants to use the water (less than or equal to 50% of the amount of storm water dumped into the pond)to irrigate some of the vegetation on the property. The Owner will consult with the projects civil engineer to calculate this amount and we can submit if necessary. 9/5/2008 Ruling The project would like to use a pond, which is fed by both stormwater and a spring, for on-site irrigation. The strategy of using an existing pond for stormwater management and irrigation provides many benefits including reduced stormwater management expenses and decreased use of potable water. In order to demonstrate credit compliance with WEc1.1, the project must demonstrate a 50% reduction in total water applied (TWA). As long as there is a 50% reduction, this credit will be earned regardless of the irrigation source. WEc1.2 provides an additional point when no potable water is used for irrigation. The definition of potable water for these purposes includes natural surface or subsurface water sources. However, WEc1.2 can be awarded provided the following three conditions are met: 1) The total volume of water drawn from the pond combined with the amount of water that is lost to infiltration and evaporation shall not

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exceed the amount of stormwater that enters the pond on a monthly basis. Document the stormwater coming in and going out (infiltration, evaporation & irrigation) on a monthly basis to confirm that the pond can meet the irrigation demand. If the pond cannot fill that need, the credit cannot be earned. 2) In every month of the year, the projected level of the pond shall not drop below historical average pond levels. 3) If there is a discharge out of the pond (into another water body), provide documentation that the removal of water from this pond does not compromise the integrity of the downstream water flow. Provide calculations to demonstrate compliance with each of the three conditions. 11/19/2007 Credit Interpretation Request Credit Interpretation Request regarding: Re-use of nuisance ground water flows for the benefit of WE Credit 1.2: Water Efficient Landscaping-No Potable Water Use and WE Credit 2: Innovative Wastewater Technologies

Background & Existing Situation: On the Washington University campus in St. Louis, several existing buildings--including the existing building directly adjacent to this project--currently pump groundwater seepage from their basements directly into the existing storm sewer system. This pre-existing campus-wide condition, along with the Geotechnical Investigation Report for this project's new building site, recommend similar subsurface drainage systems around this project's foundations due to the present levels of nuisance groundwater.

Proposed Sustainable Solution: Instead of pumping or channeling the nuisance groundwater flow directly into a storm sewer system where it will serve no purpose, the project team would like to add this nuisance groundwater into the designed storm water collection cistern where it will mix with collected storm water for re-use in the landscape and other building grey water systems. This additional water volume is considered incidental and will not be allowed to affect the storm water capacity of the cistern in the event of a storm surge. Water level sensors will be used to control the inflow of the nuisance water into the cistern.

Summary: The nuisance groundwater is unavoidable and has to be removed from the basements of each building. The current solution, which requires continual pumping of additional water flows to the existing storm sewer system is wasteful and simply adds unnecessary water flows to the sewer system. By utilizing this dewatering byproduct resource to supplement collected storm water, the overall sustainability of the site is enhanced by potentially reducing the storm sewer infrastructure and getting a double benefit from the pumping energy already in place. The utilization of these flows even out the seasonal effects of a storm water collection system and allow for landscape and building grey water systems to be used year round.

Request: Please confirm that this approach, which proposes to include and utilize nuisance ground water flows, will achieve these credits. 1/31/2008 Ruling The applicant is inquiring whether groundwater, which needs to be collected and pumped from the exterior of the foundation, can be used for irrigation to achieve both points for WEc1.1 and WEc1.2. This use would comply with the intent of the credit, as long as the pump only draws water from the immediate vicinity of the slab and foundation. The applicant intends to pump the groundwater to a cistern, which also serves the function of collecting stormwater. Include with the LEED submission calculations to show that the cistern has the capacity to serve the relevant stormwater management functions as well as meet the irrigation demands in July. The calculations need to allow for the drawdown of the cistern between storm events for the design storage volume to be available. 11/13/2007 Credit Interpretation Request Our project is a 9 million SF Graduate University located in Saudi Arabia dedicated to the research of alternative fuels and renewable

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energy. The entire campus will be New Construction on a Greenfield site and will consist of research labs, lab support areas, administration buildings, a library, a commons building, food service, an auditorium, conference rooms, lecture halls, offices and public areas. All condensate, gray water, black water and storm water from the Campus is being collected and sent to a waste water treatment plant off-site and outside of the project boundary. The water goes through the following process and is then used to irrigate a nearby golf course: WWTP A. Introduction WWTP is an advanced WWTP that is designed to treat an average daily sewage flow of 9500 M3/d. B .Processes used in the design of the WWTP. The Processes used designs are: 1. Fine screen, 2mm. 2. Grit removal system. 3. In line equalization tanks. 4. Anoxic reactor. 5. Aeration tanks. 6. MBR Tanks (KUBOTA membrane is used) 7. Effluent Tanks. 8. Centrifuge dewatering system. 9. Chemical dosing units. 10. Emergency storage ponds. C. Very high effluent quality produced The effluent quality produced form the WWTP is as follow: BOD = 10 mg/L S.S = 10mg/L NH3 = 1.0mg/L TKN = 2.0mg/L The effluent produced will be used to irrigate the Golf coarse area.

Through the reuse of this Campus waste water, the project is eliminating the use of potable water, or other natural surface or subsurface water resources available on or near the project site for landscaping irrigation of an adjacent site. The interpretation needed is twofold: Would this process result in a gray water effluent that in keeping with the Credit Intent, would comply with this Credit by irrigating a nearby site? And if the irrigation of a nearby site is not acceptable, would the project comply if effluent water from the WWTP was piped back to the campus for all irrigation purposes? 12/13/2007 Ruling The CIR is inquiring whether their contribution to an off-site wastewater treatment plant (WWTP), which provides non-potable water for irrigation of a nearby site, would comply with the credit. In addition, the applicant inquires whether using water from this plant on site for all irrigation would comply with the credit requirements. Contributing condensate, gray, black, and storm water to the off-site WWTP would not be enough to earn WEc1. This strategy, while positive, does not adequately address the intent of the credit to limit or eliminate the use of potable water resources for landscape irrigation. Contributing to a non-potable source does not necessary encourage its use. The fact that this water may be used by a nearby golf course does not figure into the decision. If the project were to use water from the WWTP on the campus for all irrigation purposes, and the water from this WWTP was conveyed specifically for non-potable uses, this would meet the requirement for one WEc1 credit. It should be noted that, in addition to using only non-potable water for irrigation, the project must demonstrate a 50% reduction in total irrigation water consumption from a baseline case in order to earn both WEc1.1 and WEc1.2. 6/29/2007 Credit Interpretation Request Municipally provided recycled water is available to the project site and the intent of the irrigation design is to use this recycled water to the fullest extent possible. A portion of the park will be a swimming pool/aquatics complex. The San Diego County Department of Environmental Health (DEH) does not permit the use of recycled water for irrigation within pool areas due to health concerns regarding

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cross contamination of potable water systems as stipulated in the San Diego County Rules and Regulations for Recycled Water Use. Therefore we are required by DEH to use potable water for the irrigation within the pool complex. The total irrigated landscape area within the park limits is 786,877 SF. Of that, 756,210 SF will utilize recycled water and 30,667 SF (pool area) will utilize potable water. This equates to over 96% of the total site utilizing recycled water. Every effort has been made to use recycled water to the fullest extent possible while remaining in compliance with local codes and regulations. Please confirm that this approach, which utilizes 100% reclaimed water in all areas allowed by code, will achieve this credit. 7/12/2007 Ruling The project is inquiring whether it may achieve both Water Efficiency credits for the use of municipally-provided reclaimed water for irrigation purposes despite the fact that certain areas of the project utilize potable water for irrigation. Although this credit indicates that projects must use 100% reclaimed water for all project irrigation purposes, it is permissible for this project, in this circumstance, to exclude the areas nearest the swimming pool as reclaimed water may prove to be a public health hazard. For project Submittal, the team should be prepared to provide documentation from the San Diego County DEH demonstrating the code requirement. 9/1/2006 Credit Interpretation Request I am the LEED administrator for a Water Treatment Plant project (currently registered on LEED On-line, v2.2) We are not pursing LEED certification for the entire treatment facility. We are only pursuing LEED Certification for the primary building on the site (Administration/Operations Center). We have established a reasonable and consistent boundary for the subject building (including Sustainable Site considerations). As a water treatment facility, the project involves accessing water rights from the adjacent river for processing, treatment, and distribution of water to the public. In order to meet the criteria for WE Credit 1.1, 1.2 - Water Efficient Landscaping - we are considering: 1. Plant species factor 2. Use of captured rainwater - when available from the proposed on site stormwater retention basin and 3. Use of raw water - directly from the river For item 3 above, I have noted previous CIR's on this subject which deny the use of river water for this credit. I have also noted in the Reference Guide that the intent is to limit or eliminate the use of natural surface or subsurface resources for irrigation purposes. Yet, in the Reference Guide, page 115, under Requirements, "Use of water treated and conveyed by a public agency specifically for nonpotable uses" is noted as a consideration. Most water (potable or non-potable) conveyed by a public agency is ultimately sourced from surface or subsurface resources. Therefore, it seems that an office building project, for example, could use non-potable water conveyed by our agency and that project would be eligible to gain the LEED credit. Whereas if our agency uses the same water for itself, the credit would not be granted. This raw, un-treated water, which would normally be processed through the treatment plant, will be diverted from the processing and treatment stream (saving energy and use of chemicals) and will be used directly for irrigation for the landscaping within the proposed LEED boundary surrounding the subject building on the water treatment plant site. We would like to confirm that USGBC concurs with our interpretation that this proposed source for irrigation water from the river (nonpotable, raw water) will meet the intent of WE c1.1, 1.2. We believe that in essence, this raw water is equivalent to (is actually environmentally better than) "Use of water TREATED and conveyed by a public agency specifically for non-potable uses" as indicated on page 115 of v2.2 Reference Guide). 9/19/2006 Ruling Plant species factor and onsite captured rainwater are qualifying strategies to achieve this credit. Based on v2.1 WEc1.2 CIR rulings dated 1/20/04 and 11/5/2005, the use of surface water or water drawn from receiving waters is not an acceptable way to meet the credit intent. LEED-NC v2.2 WEc1 allows the, Use of water treated and conveyed by a public agency specifically for non-potable uses, however, these sources are not typically sourced from surface or subsurface resources. Common sources include effluent from treatment plants and recycled graywater harvested from within the region. If this water treatment plant supplies water to offsite customers specifically for non-potable uses AND the raw water proposed for irrigation would otherwise be processed for this non-potable system, then the intent of the credit has been met. While the avoided energy and chemical inputs for this raw water are laudable, this is not a deciding factor

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WATER EFFICIENCY: Innovative Wastewater Technologies () 12/15/2008 Credit Interpretation Request This CIR seeks clarification on what fixtures and systems are covered in WE Credit 2. The credit specifically mentions water closets and urinals as fixtures for conveying building sewage. The subject project is a 35,000 sf office building for dentists and orthodontists. A typical office of this kind uses a water-intensive vacuum system for conveyance of human biological waste in the form of blood, saliva and mucous. A number of the doctors are considering using "waterless" vacuum systems that drastically cut the demand for potable water for purposes of conveying human biological waste. We seek guidance on the following: Should the fixtures that comprise a dentists' vacuum system for wastewater (blackwater) conveyance be considered when calculating WE Credit 2. 2/10/2009 Ruling The applicant is requesting clarification whether fixtures that comprise a dentists vacuum system for wastewater conveyance should be considered in the WEc2 calculations. Water use from dentists vacuum systems is considered process water use and is not eligible for consideration under WEc2 and WEc3. Previous CIRs dated 2/21/2007 and 3/9/2004 contain additional clarification regarding process water use. 3/28/2008 Credit Interpretation Request Our project is a 9 million SF Graduate University located in Saudi Arabia dedicated to the research of alternative fuels and renewable energy. The campus will consist of research labs, lab support areas, administration buildings, a library, a commons building, food service, an auditorium, conference rooms, lecture halls, offices and public areas. We will be seeking LEED NC Multi-Building / Campus Certification. An adjacent residential area is planned as part of the Master Plan, but will not be included in our LEED boundary for obvious LEED Certification system conflicts. The Campus will utilize efficient fixtures to reduce waste water conveyance and potable water use by 42%, shy of the 50% requirement for fixtures. All the remaining gray water and black water from the Campus is being collected and sent to a new local waste water treatment plant just outside of the LEED boundary for the Campus. The WWTP is being constructed as a local treatment system for the Campus and the surrounding residential areas, but is located just outside of the Campus LEED boundary. This WWTP is being constructed in close proximity to the Campus and residential area to avoid the extension of existing infrastructure. We are seeking compliance through Option #2 for this Credit: Treat 50% (100% for an Innovation in Design Point) of wastewater onsite to tertiary standards. Treated water must be infiltrated or used on-site. Although the WWTP is just outside our LEED boundary for Master Plan reasons, the intent of treating the Campus water and infiltrating it on-site is being met. The water is treated to tertiary standards at the WWTP and is then piped back to the Campus for all irrigation purposes. The Campus will use 100% recycled water from the WWTP for all irrigation needs and per the intent of the Credit, this will "increase the local aquifer recharge." The Campus will discharge 29,215,330 liters of water annually to the WWTP. 84,479,311 liters, from the Campus and the residential area will be treated and returned to the Campus boundary and infiltrated on-site as irrigation. Therefore, 100% of the waste water being generated within the project boundary is being treated to tertiary standards and infiltrated on-site, which in turn, increases the local aquifer recharge. Please advise if the project strategy meets the intent of the Credit. 4/14/2008 Ruling The project team is inquiring as to whether or not they can use water treated to a tertiary standard from a wastewater treatment plant located just off-site of their campus to achieve potable water savings for wastewater use. Yes, the project can achieve this credit by using non-potable water from either on-site or municipally treated wastewater as stated in the LEED NCv2.2 Reference Guide. The water being used for this would need to be considered reclaimed water, so therefore the term tertiary standards indicated in your request would need to be qualified with data showing that it meets the requirements stated in the LEED NCv2.2 Reference Guide defining Tertiary Treatment as; the highest form of wastewater treatment that includes the removal of nutrients, organic and solid material, along with biological or chemical polishing (generally to effluent limits of 10 mg/L BOD plant. All other terms, conditions and requirements of the credit would need to be met upon submittal. Please note that gray water is not and does not come from any sewer wastewater treatment plant. Gray water by definition is raw, fresh, unfiltered, wastewater from specific human activities using potable water that does not and has not been in contact with black water or a toilet or urinal fixture. 11/30/2007 Credit Interpretation Request Our LEED NC v2.2 registered project includes additions and major renovations to an existing office/laboratory building. We wish to pursue WEc2 - Innovative Wastewater Technologies on the project and would like to know if our strategy for compliance is acceptable and 10 mg/L TSS), but would not be considered potable or drinking quality water. The plant itself can be considered a municipal treatment

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in pursuit of OPTION 1. Within the new additions, we plan to install high-efficiency fixtures including high efficiency dual flush and low flow water closets and urinals for all new addition flush fixtures to contribute towards wastewater reduction. Within the existing building, the flush water closet fixtures are 3.5 gallons/flush rated and the urinals are 1.5 gallons/flush rated. We plan to replace a combination of the water closet fixtures with high efficiency low flow type and upgrade the urinal flush valves with new, high efficiency low flow type to reduce the sanitary discharge. The combination of new addition fixtures and modifications to the existing fixtures will reduce the total site sewage conveyance by greater than 50% below the current sewage conveyance of conventional fixture standards in the new buildings and no modifications to the existing fixtures. However, this credit references the Energy Policy Act of 1992 baseline water quantity flow requirements. We would like to use the gallons/flush ratings of the existing water closets and urinals as the baseline discharge for the existing fixtures in our calculations for WEc2 - Innovative Wastewater Technologies. We believe we are meeting the intent of the credit by significantly reducing the generation of wastewater and the potable water demand. 12/13/2007 Ruling No, existing fixtures cannot be used as the baseline for calculations for WEc2. For LEED calculations, the baseline case is defined as the building with fixtures that meet the Energy Policy Act requirements, NOT the actual fixtures existing prior to retrofit. The design case is defined as the building with the actual fixtures installed. This ensures that there is a consistent baseline across all LEED projects. Please refer to the LEED calculation methodology under WEc2 in the LEED-NC v2.2 Reference Guide and LEED-NC v2.1 WEc3 CIR ruling dated 4/19/2004 for additional information and guidance. 9/21/2007 Credit Interpretation Request The project has a subterranean parking garage for 49 vehicles (19,247 sqft) that is within a mile of the Napa River. With this close proximity to the river and a high water table, the parking garage has ground water infiltration that is being pumped out at 1000 gallons per day. The captured ground water is being filtered (e.g. motor oil, fuels, paints/stains and solvents, asphalt products, concrete, herbicides, pesticides, and TSS, etc.) and pumped out of the garage to the city storm drain system, according to city code and San Francisco Bay Area Storm Water Management Agency Standards. The question is, could this captured ground water be used in the building as graywater for flushing toilets and urinals to offset potable water use and thereby qualify for LEED NC v2.2 Water Efficiency credits? 10/22/2007 Ruling The applicant is proposing to use groundwater that has been pumped to prevent flooding to reduce potable water demand by using it for flushing toilets and urinals for WEc2. This strategy is acceptable as long as the water is only being pumped to keep the building dry; sinking a well or pumping more water than is necessary are not acceptable strategies. If the water that the project team is using is water that would be produced and discharged anyway, then the project team may use include the reused water in the calculations for the credit. The water quality of the water being used in toilets and urinals should be addressed in cases of recycled water that is untreated or minimally treated. States and regulatory agencies tend to require the water to be up to potable water standards before it goes into the toilet or sink. Note that the water quality should meet local standards and consult manufacturer recommendations for compatibility of parts with greywater use. As a point of clarification, captured groundwater is different than greywater; the term should be changed to alternate on site water sources in this CIR. 3/8/2007 Credit Interpretation Request Our project is a full service car dealership that includes a staff operated car wash. The proposed design will utilize a closed-loop recycled car wash system that will reduce the amount of potable water required to wash a vehicle from 25 gallons to 6 gallons as compared to a conventional car wash system. A conventional carwash system uses 25 gallons of potable water that is 100% evacuated to the sanitary sewer. The proposed design will utilize 25 gallons of reclaimed water from reclaim holding tanks for the soap and wash process and only 6 gallons of potable water for the final rinse. (Note: the proposed system is the most efficient technology currently available).

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It is our position that carwashes are an integral part and a standard component in automotive dealerships. Additionally, car washes are the largest consumers of potable water in automotive dealerships and as such should be considered in the calculations for this project. This request is to confirm that the water efficient car wash equipment system can be considered towards Innovative Waste Water Technology which sites " water conserving fixtures (water closets, urinals)" as being the fixtures allowed to be considered under this point. 3/22/2007 Ruling The project is inquiring if it is possible to achieve WEc2 through the use of a water efficient car wash system. WEc2 deals with wateruse reduction as it relates to sewage conveyance, thus it doesnt pertain to this request. The projects petition is more appropriately suited for an Innovation in Design (ID) point for process water use reduction. As indicated in CIR Ruling 8/31/2004, a project may be eligible for an ID point for reducing process water if a whole building approach is used (dish washers, drinking fountains, cooling towers, etc., in addition to the car wash). The project will need to demonstrate a 10% savings in process water use as compared against the regulated water use calculated in WEc3. Please refer to CIR Ruling 8/31/2004 for details on how the project should document this credit. 2/2/2007 Credit Interpretation Request We have assumed a 50%-50% calculation for men's restroom for the following reasons: The use of the facility is retail therefore we anticipate more users in the restroom at one time when compared to a similar size facility for office use. The bulk of the users are transient with a temporary use of the restroom mainly for liquid waste versus solid waste. This increases the chances for the low flow water closet to be used more often for liquid waste. On Table 2.1 of the LEED-NC form indicated the use of "Dual-Flush" water closet to be at 50% (solids) for male and 50% for non-water urinal. Using this approach, we'll save 51.3% of water. This approach may not be realistic in terms of the daily usage of the plumbing fixtures as being 50/50, but this will be the worst case scenario. In reality, urinals will be used more often compare to toilets, more like 60%-70% more than the toilets. In the event when urinals are going to be used 100%, the dual-flush toilets will be used for liquid waste and still conserve water due to the low-flow of 0.8 gpf which is not shown as an alternate factor in the LEED form Table 2.1 Design Case. 2/26/2007 Ruling For the purposes of LEED water use calculations, modifications such as a change to the male/female ratio, or daily use per person, or frequency of use of fixture types can be made provided clear justification is provided, with all assumptions noted in the LEED submission and corresponding calculations

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WATER EFFICIENCY: Water Use Reduction () 1/12/2009 Credit Interpretation Request Our project is a 120 bed hospital addition which includes 28 operating rooms, an expansion of the emergency department, a radiation/oncology department with 8 linear accelerators, and additional support functions. Some of the added spaces include process loads for instrument, cart, and equipment washing and sterilization which we know is to be excluded from the baseline and projected use calculations. The LEED-NC Reference Guide clearly address the usage of water for traditional functions of using water closets, hand washing related to the use of water closets or urinals, and showering. The Guide does not specifically address the usage of water at the multitude of other fixtures that occur throughout a hospital of a possible non-process nature. Due to the inherent nature of using surgical scrub sinks, flushing rim service sinks, housekeeping service sinks, and similar fixtures, the usage of water is more dependent on volume or a combination of volume and time used so identifying a savings, it there is one, is not practical and we would also place these fixtures into the category of process loads. What remains is a large number of sinks that are in exam rooms, patient rooms, and similar clinical spaces that are continuously used by staff for additional hand washing and would account for significant water usage and a corresponding reduction in usage if fitted with faucets that use less water than the base line 2.5 GPM allocated for lavatories and kitchen sinks. The Guide appears to be silent on applying usage factors to these types of fixtures so is it the intent for all of them to be considered process loads, or should we be developing a concept for usage that would permit calculating base line and reduced water usages towards a credit? Since the obvious goal is the real reduction in water usage, it would be appropriate to have a criteria that permits applying additional reductions to achieving a credit. 2/10/2009 Ruling The applicant is requesting clarification regarding what water use fixtures may be considered process water use in a medical environment. Per several CIRs (3/9/2004, 7/8/2004, and 7/19/2005), all fixtures not regulated by the EPAct of 1992 are considered process water fixtures and are not to be included in calculations for WEc3. The EPAct of 1992 only regulates lavatory faucets, kitchen faucets, and metering faucets. Additionally, the LEED-NC v2.2 Submittal Template for WEc3 includes housekeeping service sinks. Therefore, flushing rim service sinks may be considered process water use fixtures. 2/1/2008 Credit Interpretation Request This CIR describes our methodology for developing baseline and design water use for a LEED NCv2.2 project. This project includes one existing, renovated building with a large new addition. It will be occupied by the General Assembly and will include committee rooms for internal or public meetings, offices, press room, cafeteria. The general assembly is only in session for 4 months, which is when the highest occupancy will occur. The other 8 months will be a reduced count. First we have determined the average building occupancy based on visitors and full/part time staff in session and out of session per the following assumptions

1) In session: a) New addition Offices will be used 100% during session at 100% capacity. The number of regular building occupants is based on desk count per the preliminary drawings. The four large committee rooms will be used 100% during session at 100% capacity. There will be 30 elected officials (building occupants already accounted for in the number of regular building occupants) and the rest visitors. Meeting rooms and small committee rooms will be used only for internal meetings. Single occupant toilets adjacent to the large committee rooms will be used during session only by committee members. Other employees and visitors will use the core toilets. b) Existing building Offices will be used 100% during session at 100% capacity. The number of regular building occupants is based on desk count per the preliminary drawings. The ballroom will be used 100% during session at 100% capacity. There will be 30 elected officials (building occupants already accounted for in the number of regular building occupants) and the rest visitors. Journalists will be using the pressroom only during session, approx. 2hours per day. Meeting rooms and small committee rooms will be used for internal meetings. Single occupant toilets adjacent to the ballroom will be used during session only by committee members. Other employees and visitors will use the core toilets. 2) Off session: a) New addition Offices will be used 50% of the time off session at 10% capacity. The four large committee rooms will be used 50% of the time off session, with 50% capacity. We assume building occupants, visitors. Meeting rooms and small committee rooms will be used for internal meetings.

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Employees and visitors will use the core toilets. b) Existing building Offices will be used 50% of the time off session at 25% capacity. The ballroom will be not used off session. Meeting rooms and small committee rooms will be used for internal meetings. Employees and visitors will use the core toilets We have differentiated use of core toilets and single occupant toilets because two different flush rates are applied. Single occupant toilets are low-flow single flush (1.3 gpf) while the core toilets are dual-flush (1.1/1.6 gpf). We have multiplied the full-time equivalent building occupants and visitors during session by 1/3 and out of session by 2/3 to finally get the aggregate total FTE occupants and visitors for WEc3. We have considered the peak FTE occupants and visitors during session to calculate the minimum number of secured bicycle racks and showers to comply with SSc4.2. Please advise if this methodology is acceptable. 2/29/2008 Ruling The CIR is requesting verification that the presented method of calculating FTE occupants is acceptable. In general this approach seems reasonable for what is a relatively complex occupancy pattern. When this project is submitted for review, be sure to include an explanation with at least this level of detail. It would also be beneficial to explain if the single occupancy restrooms are only accessible by certain users (i.e. key access) or if the assumption was that only certain occupants would be likely to use them. Please note that the LEED Submittal Template allows for the applicant to input a custom occupancy type (in addition to the standard FTE/Student/Vistior/etc. categories. This may allow for a simpler calculation than trying to lump together multiple occupancy types to create a single FTE value. The water savings of dual flush toilets in commercial and public settings has not yet been proven; there is a need to verify that dual flush toilets are in fact used as intended by consumers, and further research is necessary. 12/19/2007 Credit Interpretation Request The subject property of this CIR is a new, 135,000 SF, 140-unit, mixed-use residential building on a previously developed infill site. The project targets a minimum 40% water use reduction and has purposefully selected low-flow fixtures as the primary means to achieve this goal. The kitchen sink fixture is the focus of this CIR. The kitchen sink selected for the residential units was chosen for its low-flow performance, cost, ease of installation and compatibility with the unit design. The sink comes equipped with a flow rate limiter that can be adjusted to reduce the flow rate by 50%. The maximum flow rate is 2.5 gpm so, once adjusted, the flow will be reduced to 1.25 gpm. The product cut sheet provides detailed, stepby-step instructions and a diagram on how to make this adjustment. The adjustment requires removal of the sink lever and fixing screw and use of an allen wrench to adjust an internal screw, so it is highly unlikely that tenants would override any adjustment made during initial installation. This adjustment will be sufficient to exceed the overall project goal of minimum 40% water use reduction when coupled with the other selected low-flow fixtures. The architect and owner have mandated that the kitchen sink flow rate is adjusted to the minimum in each of the units during installation to reduce water use and earn an innovation point for exemplary performance of WEc3. To ensure that this flow-rate is realized, the architect will integrate these instructions, plus the product cutsheet, into Part 3 ("Execution") of Division 15 ("Mechanical") of the project specifications (we can send the USGBC the cutsheet to faciliate review if desired). As the project's LEED consultant, we will also review this requirement and installation procedure at our scheduled contractor kickoff meeting, which will take place prior to the start of construction. Lastly, if the USGBC desires, the owner may provide a written commitment to verify that the adjustment was made through post-installation sampling and to provide corrective measures if the sampling fails. Are these mechanisms sufficient to verify to the USGBC that the kitchen sinks will perform at 1.25 gpm, rather than 2.5 gpm, and to enable this performance as the entry in the WEc3 LEED-NC 2.2 Submittal Template? If so, what documentation is required in addition to the product cutsheet to supplement the LEED Submittal Template? 2/5/2008 Ruling The method described to document water-flow restrictors is in general appropriate, however, in this case, the WE TAG does not feel that this strategy is worthy of an innovation credit for exemplary performance beyond WEc3. Kitchen sink faucets are used to fill pots among other things. Expecting tenants to use 1.25 gpm faucet flows to fill pots will cause frustration and lead to tenant attempts to readjust to higher flow rates. Earning LEED points should not result in dissatisfaction and frustration which will reflect back on the LEED product. It is strongly recommend to keep the kitchen faucets at 2.5 gpm and to use alternate strategies., such as foot pedal operated faucets to reduce water use without causing dissatisfaction.

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8/9/2007 -

Credit Interpretation Request It is unclear whether it is the intent of this credit to include commercial kitchen sinks in the calculations. While the reference guide states, "Calculations are based on estimated occupant usage and shall include only the following fixtures: water closets, urinals, lavatory faucets, showers and kitchen sinks," the definition of "kitchen sink" is a bit unclear. Our hospital project includes a commercial kitchen and dining room to serve the entire hospital population. There are two kinds of sinks in this commercial kitchen: hand sinks primarily used for hand washing, and commercial sinks used in the preparation of food. We believe that the hand sinks within the kitchen clearly fall within the fixture group that is to be used in this calculation. Our question lies with the commercial sinks and whether or not they should be included in the calculation. Our initial interpretation is that the commercial sinks in the kitchen are used for process loads: filling pots, washing vegetables, etc. We came to this conclusion partially based on a credit interpretation ruling dated 3/9/2004, "Process water includes, but is not limited to, water use from cooling towers, dishwashers and clothes washers." Process water fixtures and equipment are not included in the calculation for this credit, therefore our understanding is that we should not include the commercial kitchen sinks in this calculation. We found further guidance on this decision by looking at Table 2 on page 141 of the LEED for New Construction Version 2.2 Reference Guide. This table titled, "Standard Fixture Uses by Occupancy Type" states that for a non-residential kitchen sink, the usage is 1-15 second duration from each FTE per day. While this is a reasonable estimate for each of the hand sinks, the commercial sinks are likely to be used for much longer periods of time to, for example, fill a pot or rinse vegetables. Please advise on our initial interpretation that the commercial sinks are process load fixtures.

12/3/2007 -

Ruling The inquiry is asking if process water fixtures and equipment (such as commercial kitchen sinks) should be excluded from the calculations for WEc3. The project teams interpretation is correct commercial sinks are considered process loads and are not included in the water use calculations for WEc3. WE TAG recommends that the applicant consider use of a special use pot filler in addition to the regular use faucet at 2.2 and 60 psi, as commercial sinks are not process water in the same sense as cooling towers and commercial dishwashers.

1/25/2007 -

Credit Interpretation Request We are currently designing a new County Justice Center. The project consists of 193,338 gsf and will house the county jail, Courts and office space for the County Attorney, Community Corrections, Sheriff and Court Administration. The facility comprises an occupant load of 1,879 - 587 of which are attributable to the jail portion of the facility including the inmate population, staff and visitors. During the design development process, the project team has determined that the project will be able to achieve over 40% water efficiency for the project in the courts and office space of the project. However, due to the product availability, maintenance requirements and the behavioral nature of the inmate population we have determined that the project will be unable to use low flow fixtures for the jail portion of the building. Use of low flow fixtures will place an unreasonable burden on the construction project and negatively impact the ongoing operations and maintenance of the project. Not being able to use these fixture types will negate the water efficiency achieved in other portions of the building. We respectfully request that the jail portion of the facility be exempt from the water efficiency calculations and that these strategies be applied only to the Courts and Offices areas of the project.

2/12/2007 -

Ruling In the definitions section of EPAct 1992 (Section 123, B) water closet and urinal fixtures installed in prisons are excluded. Also, the definition of showerhead excludes safety showerheads. Thus, these fixtures do not fall in the scope of this credit, and do not need to be included in the calculations for WEc3.

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