CI 2009 EAp3: Fundamental Refrigerant Management

Steve, have you reviewed the last three paragraphs above, under the Bird's Eye View tab?

Kathy, thanks for noting that—you are correct and I have updated our LEEDuser guidance.

For projects already registered, adherence to new addenda is optional.

Michelle, I do think that sums it up, yes.

I would think not—these seem like pretty superficial modifications.

Kathy, I've asked around and haven't gotten a response.

I don't think there are any official guidelines on this, or enough precedent to track a clear course. I thin you simply have to show that you've done a defensible job. The credentials of  CPA would certainly help. Seems reasonable to include ductwork and other systems that would be affected by a retrofit.

Tristan:

Our Owner will be going about obtaining a 3rd part economic audit, however, they have already planned to replace the existing units by 2020 (it is planned for in their long-term capital plan).

You have commented above that there is a 10-year consideration in that if it is determined to have a longer payback than 10 years that there is then an exemption to having to replace/retrofit the units but that the calculations/audit will need to be included in our credit submission.

Does the fact that our units will be replaced by 2020 (less than 10 years from the time that we'll submit) complicate our situation? Should we even aknowledge this fact in our narrative?

Seems like a Catch-22. If they will be updating the systems within 10 years one would think they consider it economically justifiable. Given that, do you think you can get an audit that supports the exemption?

Not mentioning the capital plan is certainly an option, although I couldn't comment on its advisability.

The problem is that they don't have the financing now and it's not on their horizon until 2020. They concede it needs to be done, but that it just inside the 10-year criteria for their capital plan.

It waits to be seen whether the audit will support this notion, but considering the extent to which the unit serves other tenant spaces, I suspect that it would show a payback well beyond 10-years.

From our understanding, the economic feasibility study is a recommendation but not a credit requirement. The base building systems are called out for best practice to undertake an audit. As stated above, they are not subject to the credit requirements if the project chooses to not discuss them.

I've had dialogue with several people, including on the technical staff at USGBC about this question, since as you point out it is a bit unclear in the Reference Guide and other materials.

As best I can tell, for LEED-CI EAp3, fire suppression systems and CFC prohibition are only in effect if those systems are within the tenant scope of work. If those systems ARE within the scope of work, CFCsChlorofluorocarbons (CFCs) are hydrocarbons that are used as refrigerants and cause depletion of the stratospheric ozone layer. may not be used.

If a project team has an ambiguous situation relative to this requirement, it is recommended that they get a CIRCredit Interpretation Ruling. Used by design team members experiencing difficulties in the application of a LEED prerequisite or credit to a project. Typically, difficulties arise when specific issues are not directly addressed by LEED information/guide.

CIRs are no longer officially precedent setting, but they do provide a useful data point.

In any case, both R-22 and R-134a should be fine for thie prerequisite, since they are not CFCsChlorofluorocarbons (CFCs) are hydrocarbons that are used as refrigerants and cause depletion of the stratospheric ozone layer..

Hey Daniel,

Thanks so much for the response! I appreciate your take on the credit interpretation and will err on the side of caution as well and advise the building owner (whose equipment is 20 yrs old) to develop a CFC phase out program.

If you hear anything definitively from the USGBC regarding and official ruling - please pass it on. I will do the same. Thanks again.

Where in any LEED Reference Guide and/or addenda is there discussion of the payback period?

I cannot find any reference to a 10-year payback being the defining timeline for exemption from this prerequisite exept for the discussion of this credit here on LEEDuser.

I will double-check on this, but the 10-year period is specified in the LEED-EBOM EAp3 credit language. Even though this isn't specified in LEED-CI, with the alignment process that took place for LEED 2009, this kind of definition typically carries across LEED rating systems.

Tristan: Thank you so much for checking into that...it's confusing enough without having to consider cross-pollination of rating systems!

Daniel: some additional thoughts I have on the confusion of existing HVAC&R equipment which use CFC-based refrigerants:

The root cause of the confusion, as noted by Robin above, seems to lie on page 148 of the LEED ID+C Reference Guide under heading 4. Implementation, which reads: “Use only non-CFC-based refrigerants in all base building HVAC&R equipment built for the project; only HVAC systems built for the project are within the scope of work.”

I humbly believe that the last clause in this sentence refers to NEW equipment. NEW equipment which serves the tenant space must use non-CFC based refrigerants.

For clarity, it might have been better had this read "the scope of work includes only (NEW) HVAC systems built for the project AND any existing HVAC&R equipment which serves the tenant space must phase-out CFC-based refrigerants or otherwise demonstrate that it is not economically feasible to do so".

District Energy Systems would still follow the technical guidance as referenced on page 149)

To support the contention that the credit intent is to address existing building HVAC&R equipment that serves the CI tenant, read on the same page 148 the discussions under Economic Issues: “…existing buildings may have CFC-based refrigeration equipment. Energy, demand, and maintenance systems, If savings offset costs, a CFC phase-out plan must be implemented to earn this prerequisite. If savings do not offset costs, detailed calculations and the results of a qualified third-party audit must confirm that CFC conversion or replacement is economically infeasible.”

Similarly, read the discussion on page 149 under 5. Timeline and Team: “Consult with a mechanical engineer or HVAC&R specialist to confirm the presence of CFC-based refrigerants in the base building HVAC&R systems, If CFC-based refrigerants are located, the building owner should develop a phase-out plan and convert to less environmentally harmful refrigerants. Do not install any systems with CFC-based refrigerants."

Lastly, read the statements under 6. Calculations: “There are no calculations associated with this prerequisite unless a third-party economic audit is conducted to determine feasibility of retrofitting existing equipment”.

It seems to me that this credit intent is very clear that new equipment must not use any CFC-based refrigerants and that existing equipment THAT SERVES THE TENANT SPACE that contains CFC-refrigerants must be shown by a third party analysis to be economically feasible (in which a phase-out plan is required) or not economically feasible (in which case there may be an exemption to this prerequisite).

I also believe that existing HVAC&R equipment that might contain CFC-based refrigerants that do NOT serve the tenant space would NOT be in the scope of this prerequisite. (If the building Owner could be persuaded to change ALL equipment that was not compliant but which did not serve the tenant space in question, might this be a possible ID credit opportunity since it would fall without the LEED boundary/scope of work?)

That one sentence on page 148 causes so much confusion when everything else seems very clear.

I would like to point out here that the 'Implementation' section in the Reference Guide is generally an explanation of the credit suggesting possible strategies of complying with it. It is not the same as the 'Requirements' of a credit. The base building systems are called out for best practice and recommend an audit. As state above, the base building systems and those serving other tenants are not subject to the credit requirements.

Can you provide a bit more context about the systems installed and the review? That would be helpful.

I have the same fuzziness as Robin, the reference guide is unclear about base building systems. Please help.
If our project is providing most of the HVAC from dedicated units but the restrooms and hallway have base building HVAC from uncertain equipment....what do we do?

Hi Sue, I think this question is answered below under the heading "help with interpretation." Let us know if you still have questions after reading this.

Well not really- I still read the LEED CI 2009 Reference Guide to exclude the base building HVAC.....if it is not in the LEED Scope of Work. I'd like to know if I'm understanding it correctly because your answers indicate that everyone thinks the base building needs to be CFC free. Or in my case- the district heating and cooling system....

This has not been update for LEED 2009, but you may find it helpful to review the LEED guidelines for district energy.

Based on that it seems pretty clear that you are off the hook here.

Kristin, thanks, I read the Distrit Energy document you referenced, but unfortunately I could not find any addiional clarity on the question and if existing equipment and its refrigerant is exempt ofrom EAp3, or do we need to develop a phase out plan. It sems like a straightforward question that should be crystal clear for any prere. I also don't see how LEED could justify not excluding equipment in one prereq. if exisitng equipment is excluded anywhere else such as in EAp2-- for the sake of consistency of thought process across credits if nothing else. Thoughts? John

John, I had dialogue with a USGBC contact about this, and confirmed that  the requirement is, as the language (see above) states, “Zero use of … within the LEED project scope of work.”  Under Implementation, the Reference Guide states, “only HVAC systems built for the project are within the scope of work,” even though base building systems are mentioned above that.

If the tenant does anything to influence the base building system, then it becomes part of the tenant scope of work, but would appear to otherwise be outside of it.

See my related comment below about fire suppression systems.