We are writing this CIR to propose an alternate method for calculating the energy efficiency due to the limitations we see in the new LEED-EBOM for Semiconductors. We are considering going with Option C2 because of following reasons but still encountering unclear direction in the RG for calculating the historical baseline. Offline calculator for Option C2 is not available in LEED-EBOM RG & LEED-Online template. The Option C2 instruction is in a way similar to the old LEED-EBv2 instruction. As such, we are proposing to use the methods & calculations defined in the LEED-EBv2 in calculating our energy efficiency based on kwhr/space actual utilization (excluding idle spaces). Reasons: Our project covers a semiconductor assembly & test facilities, it caters for various & multiple type's semiconductor products that changes from time-to-time. Our operation started in 2001 & the total area of the building was 301ksf. Manufacturing & office spaces represent 60% & 26% of the total area respectively. The manufacturing floor spaces were not occupied completely when its operation started, over the years the manufacturing space had gradually been occupied & made some minor space conversion to cater for the growing demand. The space utilization varies dynamically as the products converts from one technology to another - that normally last for a couple of months; manufacturing equipment layout will require changes that will induce temporary idle spaces. We performed manufacturing tool compaction activities to allow producing more products on the same floor space with the intention to prevent building more structures & facilities. It was done without sacrificing the air ventilation & ergonomic concerns of the employees working in the production area. Despite the efforts done to reduce consumption & improve plant efficiency, the plant faces problems in meeting EAc1 of the LEED-EBOM RG. Under Option A, obtaining an Energy Star Rating in the Portfolio Manager is not possible for semiconductor plants for the reasons that said "building type" is not available in the EPA system. Also, our semiconductor manufacturing floor areas categorized as "others space type" in the Portfolio Manager exceeded the allowable percentage space limit in the system, thus making it un-ratable. In Option B, the RG provides two options either by demonstrating 19% efficiency as benchmarked against a national median or use USGBC LEED-Online supplementary offline calculator. In comparing our buildings energy usage with other buildings of similar space types & similar climate, we're experiencing problems in conducting the benchmarking due to the fact that we don't have similar processes & products even within our company; most of our other plants are not located within the same geographical region. Our manufacturing plants are not alike when it comes to production mix, each sites produces different products. Today, there is no energy benchmark available for semiconductor facilities. Under the Eligibility tab of the offline calculator Question C-4, it states that "If the Energy Star rating was unavailable because of building characteristics or activities is over 10% of the project building's space, as entered on Portfolio Manager, classified as "data center", "Service", or other unclassified - then it directs us to use the general option C instructions in the RG & don't use the offline calculator. Our manufacturing space accounts to 60% of the total area & prohibits us from using the offline calculator. Option C1 requires applicants to obtain its weather-normalized EUI in the Portfolio Manager and compare it to a national EUI average source in CBECS. Similar to EPA, CBECS doesn't have any modeled data that represents semiconductor EUI, as such comparative benchmarking is again not possible.
The project team request clarification on the EA Prerequisite 1 option appropriate to a semiconductor facility. Because the facility is 60% manufacturing space, the project team is not eligible to use Option A or Option B. Additionally, the team indicates that data from comparable buildings is not available, making Option C3 unviable for this particular facility. The below paths can be utilized for project buildings in this situation, with different point levels available based on the path chosen. Option C1 - Up to two points available Show a percent reduction from the baseline during the performance period using the EA Credit 1 Options B & C Calculator, Option C1 Streamlined Approach. The path is based on total consumption within the project building and associated grounds, including all manufacturing process loads, compared to Adjusted National Average Source EUI (manufacturing spaces would be classified as "All Other - not classified). Up to two points can be achieved based on this path. An expanded version of the EA Credit 1 Options B & C Calculator is now available in LEED Online and on the Registered Projects Tools web page to facilitate this calculation. Please follow the instructions for Option C in the offline calculator and the LEED for Existing Building: Operations & Maintenance Reference Guide. Option C2 - Up to seven points available Show a percent reduction from the building's historic energy use baseline during the performance period as using the EA Credit 1 Options B & C Calculator, Option C2 Historic Data. The path is based on total consumption within the project building and associated grounds, including all manufacturing process loads, compared to Adjusted National Average Source EUI (manufacturing spaces would be classified as "All Other - not classified). Up to seven points can be achieved based on this path. An expanded version of the EA Credit 1 Options B & C Calculator is now available in LEED Online and on the Registered Projects Tools web page to facilitate this calculation. Please follow the instructions for Option C in the offline calculator and the LEED for Existing Building: Operations & Maintenance Reference Guide. Option D, New Compliance Path - Up to four points available This path is available in facilities that meet the following conditions: - The facility includes manufacturing process load spaces as well as other spaces uses - The manufacturing process load space is not more than 2/3rds of the square footage of the building - At least ¬ of the building is ratable via Energy Star Portfolio Manager The applicant should isolate energy consumption associated with manufacturing from the rest of the building and separately show compliance for each. This can be accomplished in one of three ways: 1) Separate the building into distinct spaces, and submeter all loads associated with the manufacturing space (including process, HVAC, and lighting loads), 2) measure all manufacturing process loads using permanent submetering, or 3) spot measure all manufacturing process loads for a representative sample of time every year to demonstrate consumption rate associated with manufacturing processes. Normalize at least 3 months of submetering or spot metering data from the manufacturing loads based on the product output to show that energy per product unit is stable or trending down. This trending analysis must be performed for at least two consecutive years (one of which can be the year of the LEED:EB&OM performance period). For the non-manufacturing portion of the building, show compliance using the regular protocol for that space type. For example, office spaces would be expected to receive an Energy Star rating. Based on the energy performance in the non-manufacturing portion of the building, up to four points can be achieved.
Related Addenda (Corrections & Interpretations)