Professional Documents
Culture Documents
Waste Water, Want Water
Waste Water, Want Water
TM
W
ALK INTO ALMOST ANY HIGH- the disposal of human pee and poop, where Harmed By Classroom
way rest area bathroom in the do those toilets flush to? Design
U.S., and what do you hear? The • Sprout Space: A Healthier
Our wastewater infrastructure is largely
constant whine of hand dryers and an Choice for “Temporary”
invisible and little understood. Most of us Classrooms
equally constant drone of high-pressure
never question the wisdom of polluting
flush after flush after flush. Before you grab • Newsbriefs
pristine drinking water, losing valuable
that cuppa and get back in your car, stop
nitrogen and irreplaceable phosphorus in Product Reviews ......... 6
and think: from this building in the middle
the process, just so we can make our poop
of nowhere, devoted almost exclusively to • BioBarrier Offers New
disappear. Our own waste Approach to Treating Waste-
is a classic SEP—Somebody water Onsite
Else’s Problem.
• Sika: Submetering Water at
The result? “Aging pipes and the Fixture Level
inadequate capacity lead ....
BackPage Primer ...... 16
to the discharge of an esti-
mated 900 billion gallons of • Water Budgets: A Holistic
Look at Efficiency
untreated sewage each year,”
warns the American Soci-
ety of Civil Engineers in its
report Failure to Act. “Water Earn CEUs
infrastructure in the Unit-
ed States is clearly aging, Get AIA and LEED credit
and investment is not able with EBN feature articles at
to keep up with the need.” BuildingGreen.com/Learn
(For more, see “Failing Water
Infrastructure Drains Econ-
omy, Report Warns,” EBN
Feb. 2012.) Though most rest
Quote of the month:
areas still use one-way water
cycling (onsite septic fields “What small-scale projects
or long-distance connections do is break down the
with centralized systems), a number one impediment
few throughout the U.S. are to reuse of wastewater:
incorporating constructed the fear factor.”
wetlands and other natural – Pete Muñoz, P.E.,
filtration systems that close senior engineer at
the loop, permitting safe Biohabitats, on onsite
Photo: Eckert & Eckert
and sustainable wastewater wastewater projects
This Living Machine at the ZGF-designed Port of Portland headquarters
treats all the wastewater for the building and made better financial treatment and reuse right on
(page 11)
sense than rainwater collection, say the designers. the site. (continued on p. 8)
What’s Happening
design parameters, each measured Of the ten environmental factors in- quality to be “universally poor”
with multiple indicators and calcula- vestigated, eight were correlated at a based on spot checks of carbon diox-
tions (see table). Students were even- level greater than 10% with learning ide levels. The authors hypothesize
ly spread across the schools, were progress. However, a central feature that air quality, along with sound
evenly divided between genders, of the study was the application of a and temperature, varied little be-
and spent 50%–80% of their time in type of regression analysis that helps tween classes in the study and thus
their fixed classrooms, providing unravel the relationships among didn’t account for variations in stu-
some assurance that an individual several variables. That model shows dent progress between classrooms.
classroom could affect learning. The that two of the variables initially They also suggest that those factors
researchers weren’t able to obtain found significant—air quality and may be quickly acted upon if they
government assessments of teachers texture—were not significant in ex- become a problem—for example,
at all the schools and so didn’t fac- plaining the variations in learning. by turning up the heat or opening
tor this in; however, they note that That result was surprising to the a window—while the color of each
the data they did obtain showed a researchers, especially considering classroom was a less changeable
consistent level of teaching. that they found the classroom air influence.
PROJECT FOCUS
offer fresh food but are often virtu- made up the majority of new home in energy use compared to the 2003
ally inaccessible on foot. construction in New York City and International Energy Conservation
several California cities. Infill devel- Code (IECC); this has been changed
opment takes advantage of existing to reference the 2006 IECC. This is
Deaths Related to Air Pollution infrastructure and increases a com- not a substantial change to efficiency
Increase Worldwide—A new study munity’s tax base; most metropolitan requirements, as the 2006 IECC up-
in The Lancet shows air pollution con- areas, however, are still expanding date largely focused on simplifying
tributing to an increasing number of outward faster than they are gaining compliance; properties qualifying
deaths worldwide, with 3.2 million density of housing. For more on the for the credit based on the previous
premature deaths in 2010 attribut- study, see www.epa.gov. version are likely to meet the new
able to outdoor air pollution. Part of standards. SS25C is an individual tax
the Global Burden of Disease Study credit of 10% of the cost of efficient
2010, the article tracks changes in Energy-Efficiency Tax Credits Re- appliances or property improve-
risk factors since 1990. While com- instated—The American Taxpayer ments, such as insulation. The credit
municable diseases and malnutrition Relief Act of 2012, passed on January is capped at $500 and is applicable to
cause fewer deaths than they did 1, 2013, to avoid the so-called fiscal all improvements from Decemeber
two decades ago, deaths attribut- cliff includes the reinstatement of 31, 2011, to December 31, 2013.
able to air pollution have increased two tax credits for energy-efficient
fourfold. Overall, non-communi- residences and appliances. Title 26
cable diseases such as cancer and subsections (SS) 45L and 25C are in EBie Awards Submissions Due in
heart disease have become the lead- effect through December 31, 2013, February—The 2013 EBie Awards
ing causes of death, and many of and retroactively to their previous will be announced in June, with
them are caused at least in part by expiration on December 31, 2011, project submissions due by Febru-
pollutants. Much of the increase in making them applicable to both ary 26. The national awards, from
pollution-related mortality is in Asia, 2012 and 2013 projects. SS45L is a Urban Green, the New York City
where rising numbers of vehicles business tax credit of up to $2,000 for chapter of the U.S. Green Building
result in more soot and other ambi- contractors or developers building or Council, recognize professionals
ent particulate matter from diesel renovating dwelling units of up to working to bring existing buildings
exhaust. Indoor air pollution, espe- three stories, including multifamily into line with standards such as
cially from coal- and wood-burning properties; the credit may be claimed LEED for Existing Buildings: Op-
stoves, has decreased since 1990— for each unit. The previous version erations & Maintenance. The EBies
but it still caused approximately 3.5 of SS45L required a 50% reduction may be awarded to building owners,
million premature deaths, largely in
India and parts of Africa.
Percentage of New Homes Built in Infill Areas
between the filter membranes. The Effluent Criteria Under NSF 350
bubbling action and added oxygen
keep the membrane clean and help Class R (Residential) Class C (Commercial)
bacteria break down organic solids Carbonaceous biochemical
10 mg/l (25)
and other contaminants. According oxygen demand (CBOD5)
to James Bell of Bio-Microbics, the Total suspended solids (TSS) 10 mg/l (25)
MBR uses “a flat sheet membrane Turbidity 5 NTU (10) 2 NTU (5)
that is sort of like a sandwich.” The
E. coli 14 MPN/100 ml (240) 2.2 MPN/100 ml (200)
water is filtered from the outside in:
a small, submersible pump triggered pH 6.0–9.0
by a float switch pulls water through Chlorine 0.5–2.5 mg/l
the membrane, into the center, and Source: NSF
erstein, but does fixture- Waste Water, Want Water (from page 1)
level water metering
make sense? Once an ef-
ficient fixture is installed, We’re seeing more wastewater recla-
he worries that the sav- mation in building types that aren’t
ings available from addi- devoted primarily to human waste
tional monitoring won’t disposal too, even in cities: com-
add up to much, and, he mercial offices, multifamily build-
says, the installation costs ings, and even hospitals have been
and ongoing monitoring experimenting with these systems
of dozens or hundreds of for more than a decade, producing
submeters “sounds like a not only clean water but also impor-
nightmare.” tant lessons that can be applied in
the buildings we’re designing today.
Fixtures may be the most
feasible place to attack Whether onsite wastewater treat-
the problem, though, ment is a good choice for your next
Photo: Sika USA
counters Buchanan. He project will depend on a lot of differ-
Sika's threaded, fixture-level water meters communicate notes that while most ent factors, from local codes to an-
wirelessly with a central receiver, providing fine-grained buildings may have a sin- nual rainfall to the age of municipal
submetered data for tenant spaces or residential units gle water main feeding infrastructure. If your project team
without cutting into pipes for installation. in, that might give way does choose to treat and reuse waste-
to a “spaghetti of pipes” water on the site, different types of
to control its water usage—any- inside the building lead- systems can have broad implications
thing from a single-family home to ing in all different directions, with- for energy consumption and other
multifamily residential, hotels, of- out any mapping. If the goal were aspects of the project—but decen-
fices, or any other building type. At to submeter a single tenant space, tralized treatment and reuse can also
$100 per unit, plus $300 for a central bathroom, floor, or apartment, that contribute to improvements in cen-
data receiver, the units are relatively might not be feasible, and certainly tralized infrastructure, sometimes
affordable, but the cost could add not without cutting into pipes. By in more ways than one.
up for an entire floor or building. going all the way down to the fix-
Larger buildings might also need ture level, Sika meters and monitor- An Integrated Water Plan
$200 signal repeaters—one per floor ing software allow an aggregation
is likely—to bridge the gap in wire- of data to serve the same purpose Fifteen years ago, “it seemed like a
less communication from the meters as submetering of an entire space. great idea, every chance we had, to
to the central receiver. The receiver Buchanan also noted that there is treat wastewater onsite,” says Rus-
includes a software package that nothing preventing installation of sell Perry, FAIA, corporate sustain-
allows for data collection, trend spot- the meters upstream of individual ability director at SmithGroupJJR.
ting, and usage alarms. fixtures. “It’s not that clear anymore.”
The submeters fill a distinct gap for The Sika meters have an expected During his time with William Mc-
monitoring water use inside build- lifetime of 20 years, although the Donough + Partners, Perry helped
ings. Whether it’s the right gap to standard lithium battery that pow- design the intensive natural filtration
fill is up for debate, however. “The ers them will require replacement system in the Adam Lewis Cen-
biggest sticking point in water me- after 10 years. Installation of the ter at Oberlin College, one of the
tering is the installation cost of the threaded meters should be a minor first so-called living machines to
meters; people hate cutting pipe to plumbing job, while installing and be built. (Living Machine is a regis-
stick one of these things in there,” tered trademark owned by Worrell
setting up the wireless data receivers
Dan Ackerstein, a consultant and Water Systems; the more general
will require someone with wireless
expert in sustainability for existing term is simply “natural treatment
Internet expertise.
facilities, told EBN. On that point, system”.) Perry isn’t convinced that
Sika’s threaded connections make a While Buchanan said that Sika USA
every building needs to do its own
lot of sense—they allow installation could make the meters available for
wastewater treatment, though: “The
without cutting into pipe—assum- individual projects, the company is
deeper you get into this, the more
ing there is room in the plumbing still looking for a partner to facilitate
you realize certain decisions that
configuration for them. U.S. distribution.
solve one set of problems cause other
That’s all well and good, says Ack- – Tristan Roberts problems.”
Conservation first these regulations change (see side- seem like a logical solution for a
bar, “Net-Zero Nutrients”). Energy given project may not make sense
Even by usual standards of green on paper. Common sense dictates
use from pumping wastewater over
building, the considerations around
long distances also “represents a that the Pacific Northwest is rainy,
projects considering onsite treat-
significant portion of the overall but “Portland [Oregon] is a little dif-
ment can be remarkably specific to
impacts” of centralized wastewater ficult in that we have eight months of
the climate, the site, and the local
treatment, according to a Cascadia a lot of rain—39 inches total is nor-
infrastructure.
Green Building Council life-cycle mal—and then four months when it
“Salt Lake City has a sophisticat- analysis, detailed in its report Clean hardly rains at all,” explains Doug
ed wastewater system, including Water, Healthy Sound. Composting Sams, AIA, of ZGF Architects. While
wetlands,” says Perry, describing toilets use relatively little energy and working on new headquarters for the
discussions his firm has had with do not pollute water, making them Port of Portland, ZGF realized that,
the University of Utah about a new the most sustainable choice, accord- to span the dry period, the size of a
building that will eventually house ing to the analysis. proposed rainwater collection tank
the Wallace Stegner Center for Land, would be so large that the approach
Resources and the Environment. Rainwater harvesting simply “didn’t pencil out.” Waste-
The project team is open to onsite Most sites have plenty of rainwater water treatment was a better option
wastewater treatment because of the that can be harvested and used not in this case, and Sams oversaw the
client’s environmental mission, but only in toilets but also as make-up design and installation of a Living
it’s not necessarily the most sensible Machine in the building.
water for cooling towers and to ir-
choice due to the exemplary munici-
rigate landscaping (see “Alternative Additionally, many sites do not even
pal infrastructure, Perry said. De-
Water Sources: Supply-Side Solu- have rights to the water that comes
spite the region’s minimal rainfall,
tions for Green Buildings,” EBN May off their own roofs, particularly in
by using ultra-low-flow plumbing
2008). Again, though, what might the West and Southwest.
fixtures and collecting rainwater and
graywater to flush toilets, the build-
ing will already have more water Centralized Water Infrastructure
than it needs and can use the excess
for irrigation. “In a certain way of
looking at it, you’re solving a prob-
lem that doesn’t exist,” Perry notes.
Project teams looking to address wa-
ter consumption and sewer loads—
whether for sustainability reasons
or financial ones—will want to de-
fault to low-flow plumbing fixtures,
look holistically at conservation (see
“Water Budgets,” page 16), and then
consider other options, usually in the
order discussed below.
Composting toilets
They’re not for every client, but they
do warrant consideration for almost
every project. Composting toilets
use very little or no water, depend-
ing on the model, thus avoiding pol-
lution of potable water just to move
human waste around. Although the
humus and liquids generated by
composting toilets cannot legally be
used to amend soil in some places, Source: KMD Architects
composting toilets could eventually U.S. water infrastructure is a poorly designed, centralized system that devalues our most
help us recover valuable nitrogen precious non-renewable resource by using it to move pollution and waste from place to place.
"Sometimes I hope that water will get more expensive to force us to find solutions," says Megan
and phosphorus in the future if
Koehler of KMD, which developed this diagram.
Overtaxed municipal system Expensive sewer fees ing water and sewer fees. Because
of this incentive, onsite wastewater
Even in urban settings, there may be Potable water remains remarkably treatment has become “relatively
environmental advantages to treat- inexpensive even in regions where common” in the city, particularly
ing and reusing wastewater on your it’s scarce, but municipal wastewater for project teams that are also seek-
site. treatment can represent a major cost ing deep potable-water-use reduc-
for commercial buildings in some tions for green building certification,
A full 3% of total energy in the U.S.
places, potentially creating a busi- according to Edward Clerico, P.E.,
is consumed by piping water and
ness case for onsite wastewater treat- president of Natural Systems Utili-
waste from place to place, according
ment for certain projects. Some cities ties and a co-designer of the pioneer-
to the U.S. Environmental Protection
may waive considerable sanitation ing wastewater treatment system at
Agency—just one reason the port-
hookup charges if owners choose The Solaire high-rise in Battery Park.
manteau word watergy is increasing
to treat their water on the site, and
in popularity (see “The Water-En- ongoing sewer fees are also avoided. Education and research
ergy Connection,” EBN Oct. 2010). On the other hand, energy use will
Although small-scale wastewater One of the most compelling rea-
offset cost savings, as will system
treatment typically consumes more sons to treat wastewater onsite is to
maintenance.
energy per gallon than centralized educate building occupants, visitors,
treatment, it does greatly reduce the In New York City, sewer connections students, and professionals about
use of potable water, which typically aren’t optional, but there is a finan- freshwater scarcity and wastewater
has a massive energy footprint even cial incentive for water reuse: build- treatment. “What small-scale proj-
before we contaminate it with hu- ings that replace at least 25% of their ects do is break down the number
man waste. potable water with reclaimed water one impediment to reuse of waste-
receive a 25% reduction in remain- water: the fear factor,” explains Pete
And although centralized systems
can boast economies of scale, many
Net-Zero Nutrients
are aging, leaky, and overtaxed, and
older ones combine stormwater and The aim of wastewater treatment is to protect us from exposure to disease pathogens. In
the process, we remove nitrogen—and, more rarely, phosphorus—to reduce biochemical
wastewater, which can lead to “com-
oxygen demand (BOD) before releasing effluent. These biological nutrients can damage
bined sewer overflow”—the release ecosystems and are very much a part of the “problem” that wastewater treatment is “solv-
of raw sewage into waterways. Treat- ing.” They are rarely viewed as a valuable resource.
ing your own wastewater makes
At the same time, we’re facing global shortages of the fertilizer we use to grow most of
your waste your own problem in- humanity’s food. Peak phosphorus is the term now being used to describe this looming
stead of someone else’s. Keeping it problem: people used to replenish phosphates in soil by applying manure and “nightsoil”
onsite may also encourage occupants (composted human waste), explains Craig Briscoe, Assoc. AIA, director of integrated
to think twice before putting haz- design at Glumac. Nowadays we make industrial fertilizer out of rock phosphate, a
ardous or nonbiodegradable waste nonrenewable resource that is rapidly being depleted, and by using an energy-intensive
process to harvest nitrogen gas from the air. It’s time we added net-zero nutrients to our
down the drain, a common problem list of sustainable design goals, argues Briscoe, right alongside net-zero energy and
in municipalities. net-zero water.
“You’d be amazed how much we There are some promising techniques for recovering nutrients from human waste for
let flow off our sites that then goes agricultural use without compromising public health, explains Harold Leverenz, Ph.D., a
on to cause another problem,” says researcher at the University of California–Davis. Centralized treatment plants near very
sensitive ecosystems like the Chesapeake Bay and the Florida Everglades have developed
Erin English, P.E., associate engineer a process for precipitating phosphorus out of wastewater using metal salts or by encour-
at ecological restoration and regen- aging bacteria to do similar work. A few plants even sell the concentrated phosphorus
erative design firm Biohabitats. “If as an industrial fertilizer, says Leverenz.
you’re harvesting your water onsite, “Nitrogen removal is a bit more complicated,” he concedes. Nitrogen is abundant, and
you’re disconnecting yourself from letting nitrogen evaporate out of wastewater is much simpler than recovering it. The
that whole cycle. That’s a pretty ideal solution would be catch the nitrogen before it gets mixed into wastewater in the
profound thing to do.” English char- first place—through urine separation, which works best in decentralized systems. (Urine-
acterizes potable water as “almost separating toilets are a niche product, more common in Europe.)
criminally cheap” and argues that Mindful of existing infrastructure, Leverenz is pushing toward other options. “We could
once we begin to pay the true cost have facilities that don’t even have a biological treatment process,” he argues. “You would
of water, “the whole [decentralized] separate all the solids and all the organics and take them to an energy recovery process.
Then you could strip out the ammonia, precipitate out the phosphorus, and bring it back
approach is going to make a lot more to drinking-water quality. It recovers all the nutrients, all the water, and all the energy.” In
sense.” practice, it might be hard to implement, he says, but “on paper, at least, the energetics
are favorable,” he told EBN.
these systems may include lagoons, and endocrine disruptors in addi- and rainwater harvesting, and it
indoor or outdoor constructed wet- tion to reducing BOD and removing produces non-potable water that’s
lands, and a variety of gravel or contaminants that are more conven- reused to flush toilets; this system
sand filtration beds (along with less tionally removed from municipal is commensurately more complex
attractive pumps and polishing and wastewater. and includes a trickling filter in
disinfection tanks). Other onsite sys- addition to the wetland, making it
Recent Biohabitats projects include
tems enclose the bacteria in a tank a hybrid of natural and enclosed.
a very simple system for the Dixon
and cycle water relatively quickly; English provides a cautionary tale
Water Foundation in partnership
the bacteria are doing all the heavy about the project, though: “There
lifting here, too, so in a sense these with designer Lake|Flato Architects. were some issues with quality of
systems are just as “natural” as the The remote, rural building will be construction. If you’re going to do
kind that involve showy plantings used only a few times a month, and this as an architect, make sure con-
and water features. In general, the the system involves a septic tank tractors are getting things like liners
more compact the system, the more that meters out about a hundred and planting media down correctly;
energy it will require. gallons of wastewater per day into a it’s really essential. Make sure it’s not
constructed wetland, which slowly just overlooked as ‘some landscape
Natural filtration treats and polishes the water; it will component.’”
be used only for irrigation. “These
There’s not a sharp difference be- One of the advancements since the
are ranchers who are committed
tween the simplest natural systems days of tropical greenhouse Living
to rotational grazing and have a
and the more intensive ones: it’s Machines is that not every “natural”
profoundly pragmatic approach to
more of a spectrum from the most treatment method needs plants—al-
watershed management,” explains
basic constructed wetland to an en- though most use them anyway. Some
English. “The system is almost en-
ergy- and space-intensive indoor recent projects, like the San Fran-
tirely hands-off, as it should be.”
natural filtration system. This is part- cisco Public Utilities Commission
ly because, in general, the industry The system at KieranTimberlake building, involve very deep plant-
has moved away from tropical plant- Associates-designed Sidwell Friends ers, explains Pete Muñoz. Although
ings (at least in temperate climates) School, by contrast, is urban and the systems are being called tidal
that require greenhouse conditions intensively occupied during most of wetlands, he argues, “plants don’t
and lots of water aeration. “Our Liv- the year. It’s also one small portion of grow ten feet deep,” so their root
ing Machine was built in 2000,” says an onsite water management system systems don’t have a major role to
Sean Hayes at Oberlin. “There’s been that includes wastewater recycling play, making the systems more like
a lot of improvement to the design.”
Erin English of Biohabitats confirms The Living Machine System
that natural filtration technology
has advanced considerably since
the earliest Living Machines were 1 Office building:
piloted; her firm uses “a range of dif- toilet, sink &
ferent approaches,” employing natu- shower
ral treatment that’s characterized by 2 Primary &
longer retention times and a variety equalized tanks
of “different ecologies” that may
3 Tidal flow wetland
include septic tanks, wetlands, and
biofilm systems. “That way you have 4 Polishing vertical
flow wetland
a variety of opportunities for differ-
ent microorganisms to access waste 5 UV sterilization
in the water,” English explains. And disinfection
for systems that go through soil, 6 Clean effluent tank
“that additional step tends to help
7 HVAC office
things get broken down.” Although cooling tower
she cautions that all systems are
different and that there are fairly
few to study so far, preliminary Source: ZGF Architects
Intensive natural filtration, which is used in systems like the Living Machines designed by
evidence suggests that constructed
Worrell Water Technologies, relies on the bacteria in a constructed ecosystem to treat both
wetlands can “substantially reduce” graywater and blackwater. The processed water can then be used for cooling towers, for flush-
compounds like pharmaceuticals ing toilets, or for irrigation.
BackPage Primer
Water Budgets: A Holistic Look at
Efficiency
Have we been focusing on the wrong water-efficiency
measures all along? Even though low-flow and low-flush
fixtures have become common over the years, fewer
project teams have been aware of the water savings
that could be realized by looking at cooling towers,
commercial kitchen equipment, medical equipment, and
even municipal steam systems. The water consumption Illustration: Peter Harris
from these can dwarf that of bathroom fixtures.
not being aware that the cooling tower planned by the
Fortunately, there are tools available to help look holisti- mechanical engineer will consume tens of millions of
cally at how to get the biggest—and most cost-effective— gallons per year—a lot of toilet flushes.
water savings in a building. A “water budget” is a frame-
By talking about these and other uses in the same con-
work that has long been used to look at the relationship
versation (likely as part of an integrative design process),
of input and output of water flows in a region. By looking
a team might explore opportunities to reduce or reuse
at the interplay of precipitation and evapotranspiration,
cooling tower blowdown water; use another mechani-
planners and hydrologists can understand when an area
cal system, paired with energy-efficiency measures, to
has a water deficit or surplus.
reduce the size of the cooling tower (thus making energy
Applying the water budget concept at the building level efficiency gains as a water conservation effort—a dual
is similar but puts a focus on identifying and quantifying “watergy” approach); or look at rainwater catchment to
water uses in plumbing fixtures, irrigation, mechanical provide cooling tower water while reducing stormwater
systems, and any processes in the facility—and in turn runoff.
identifying possible water supply sources other than the
The water budget can also be used to look at landscape
conventional municipal source or onsite well that might
irrigation, aiding landscape design based on an amount
be used to meet some of those needs. Those might
of water appropriate for the region and the site. There is
include collected rainwater, mechanical system conden-
even a tool that does most of this work for you: using a
sate, graywater, or treated wastewater.
project’s zip code, the WaterSense Water Budget Tool
If done at a time when a lot of options are on the table, automatically looks up rainfall and evapotranspiration
such as early in design, the water budget exercise can data and then provides a menu of appropriate plantings
illuminate water conservation opportunities that might and irrigation technologies for each landscape zone.
otherwise go unnoticed. For example, the water use Although developed for single-family homes, the Water-
represented by a cooling tower can often come as a Sense tool works for landscapes around other building
surprise; members of the project team could be debating types and is referenced in LEED v4’s proposed irrigation
specifying 1.0 versus 1.2 gallon-per-flush toilets while efficiency credit.