ID#10127 made on
EAp3 - Refrigerant management - ozone protection
LEED O+M: Existing Buildings, LEED O+M: Schools, LEED O+M: Retail
Page 218 of the LEED for Existing Buildings Reference Guide, v2009, states that all base building equipment containing greater than 0.5 lbs of refrigerant that is permanently installed must be documen...
Page 218 of the LEED for Existing Buildings Reference Guide, v2009, states that all base building equipment containing greater than 0.5 lbs of refrigerant that is permanently installed must be documented for this credit. The term "base building" is a term of art in the real estate industry that is generally understood to exclude tenant owned equipment. For instance, lease language frequently defines base building responsibilities as items pertaining to the owner or management agent of the building, specifically excluding tenant responsibilities.
Base building elements of a new construction build-out are generally defined to mean core and shell elements and would also exclude tenant furniture, fixtures and equipment (FF&E). Tenant owned HVAC equipment would be covered under FF&E. The LEED for Commercial Interiors and LEED for New Construction v2.2 Public Guides provide a definition:
"Materials considered fit-out, furniture, and equipment (FF&E) are not considered base building elements"
Tenant owned refrigeration equipment, which often consists of small package refrigeration units installed for supplemental cooling in data rooms, are not core and shell elements, are not owned by the building owner and are typically not the maintenance responsibility of the owner or their agent. For this project, there are 3 base building chillers which serve the comfort cooling needs of occupants. Tenants own and maintain more than 100 small package HVAC units for supplemental cooling in data rooms and LAN closets within their suites. Individual tenants, not the building owner or manager, are responsible for the maintenance and refrigerant leakage tracking for these units.
The project team is aware of other LEED EB certified projects that have achieved EAc5 by excluding tenant-owned equipment by applying the definition from the NC Public Guide above. Clarification of this issue would be valuable for both individual projects and to ensure consistency across all LEED EB projects.
We ask for USGBC guidance on the following points:
1. Define "base-building" equipment as it relates to EAp3 and EAc5
2. Clarify if leakage rates must be established for all 100+ tenant-owned units within the project building, or if only the base building chillers must be analyzed to achieve EAc5
3. If EAc5 is not being pursued, clarify if tenant owned HVAC units must comply with the requirements of EAp3 as the term "central system" is used on page 146 of the EBOM 2009 Ref. Guide and further confuses these issues.
The requirements of EAp3: Fundamental Refrigerant Management and EAc5: Enhanced Refrigerant Management as they pertain to tenant-owned HVAC equipment for EB:O+M certification are as follows:
1. As stated on page 146 and 218 of the LEED for Existing Building Operations and Maintenance Reference Guide, 2009, base building systems are those that contain 0.5 pounds of refrigerant or more. Small HVAC&R units, standard refrigerators, small water coolers, and any other cooling equipment that contains less than 0.5 pound of refrigerant are not considered part off the base building system and are exempt from this prerequisite; all other equipment must be included. Note that if it is not possible to gather the necessary tenant data for these credits, or the applicant does not have control over the required element, the project team can exempt up to 10% of the building's gross floor area. In other words, HVAC equipment serving such space would be exempt from the requirements of EAp3 and EAc5 if this exemption applies.
2. Refrigerant leakage rates shall be calculated separately for each piece of equipment in the project building containing at least 0.5 pounds of refrigerant; therefore, this applies to all tenant-owned packaged HVAC units and building chillers included for compliance of EAp3 and EAc5. Note that the refrigerant leakage rate for each piece of equipment must be based on actual leakage rates experienced in the project building. If actual leakage rates have not been tracked, EAc5 cannot be earned. Please see page 221 of the LEED for Existing Building Operations and Maintenance Reference Guide, 2009 for information on calculating refrigerant leakage rates. Please also note that according to page 215 of the LEED for Existing Building Operations and Maintenance Reference Guide, 2009, the minimum refrigerant leakage rate allowable in credit calculations is 0.5%.
3. Regardless of whether EAc5 is being pursued, all base building systems, those containing at least 0.5 pounds of refrigerant, shall be included for compliance of EAp3.
Related Addenda (Corrections & Interpretations)