CIR EAc4 Ozone Depletion Scenario: Lewis and Clark is building a new building, the Social Sciences Building, that will link into a central plant, which currently has a system that uses HCFC-123. Argument: LEED 2.0 Reference Guide: "For building operations (such as university and government buildings with centrally located heating systems), all equipment in the central plant must be HCFC-free and halon-free." (p. 153) "While HCFCs are more environmentally friendly than CFCs, HCFCs still have ozone depletion potential (ODP)" (p. 152) Table 1 (p. 153) shows the ODP of HCFC-123 to be 0.02 and the global warming potential (GWP) to be 93. HCFC-123 has the lowest GWP compared with all of the HFCs in this table, which range from 140 to 6,300. Although the ODP for all the HCFs is 0, compared to 0.02 for HCFC-123, still a very low amount. LEED EB: "For equipment that already exists in the building, CFC/HCFC emissions must be reduced to less than 5% of the total charge on an annual basis as determined by USEPA Clean Air Act, Title VI, Rule 608 governing refrigerant management and reporting." (p. 22) The USGBC TSAC is currently conducting a review of the LEED 2.0 standards for the overall environmental costs and benefits for using CFC/HCFC-based refrigerants. The documentation requirements for LEED EB are 1.) To provide a written statement that you have not installed any new equipment that uses CFC/HCFC-based refrigerants or Halons, AND 2.) For existing equipment containing CFCs or HCFCs: provide documentation of CFC and HCFC inventory in HVAC&R systems, and losses and any additions and provide calculation showing that the annual releases of each CFCs or HCFCs meet the release minimization standard of no more than 5% and comply with other aspects of EPA Clean Air Act, Title VI, Rule 608 governing refrigerant management and reporting. With the addition of the Lewis & Clark Social Sciences building there will be no new chiller equipment installed. Lewis & Clark performs an annual audit of the central chiller, which on 1/20/03 showed that there was no sign of any leaks and that the refrigerant charge is OK. This successfully meets the requirements of LEED EB Eac4. Other Supporting Evidence: The Alliance for Responsible Atmospheric Policy states that HCFC Ozone impact is less today then what was projected in 1994. According to the Scientific Assessment of Ozone Depletion, 1998 Executive Summary, "The rate of decline in stratospheric ozone at mid-latitudes has slowed; hence, the projections of ozone loss made in the 1994 Assessment are larger than what has actually occurred." Ozone depletion is less than projected when current Montreal Protocol control measures were agreed. Therefore, further HCFC use limitation action is unjustified. (www.arap.org.docs/hcfc-hfc.html) Alternative Fluorocarbons Environmental Acceptability Study (AFEAS)- Results indicate that HCFCs and HFCs often provide substantial improvements in total energy efficiency over other CFC alternatives. (www.afeas.org/about.html) Fluorocarbons and Sulphur hexafluoride- In 1991, the fluorcarbon industry instigated a research program to ascertain basic environmental and toxicological data. It was found that the risk from the future environmental levels of trifluoroacetic acid from future emissions of HCFCs and HFCs does "not pose a threat to the environment." In the same assessment, the toxicity of trifluoroacetic acid to algae, higher plants, fish, animals, and humans was evaluated. It was found to be of very low toxicity to all of these organisms, a finding verified in a recently reported work. (www.fluorocarbons.org/chfamilies/HFCs/environ/relative.htm) Ozone depletion is only one of the global ecological crises facing Earth''s atmosphere today. The other is climate change, caused by global warming. Scientific opinion is now clear that human activity is linked to the global warming of the atmosphere. (New York Times, 9/10/95) We know that greenhouse gases trap heat, and we know that the concentrations of these gases are rising in our atmosphere. The debate now is over how severe and where the impacts will be - an experiment on a global scale. Disturbingly, several models have predicted that as climate change accelerates, it could also exacerbate ozone depletion. Ironically, HFCs, a major replacement chemical for CFCS, are also potent global warming gases. (http://archive.greenpeace.org/~ozone/holes/5hole.html) Question: Although the Lewis and Clark Social Sciences building will be connected to a central plant that has a system that uses HCFC-123, we believe that we are meeting the intent of the credit to "reduce ozone depletion and support early compliance with the Montreal Protocol" while also seeking to reduce the overall global warming potential. While the balance of these two potentially conflicting concerns was not addressed in LEED 2.0, we are aware that the USGBC is working to address those concerns as evidenced by the language in the LEED for Existing Buildings draft. The project owner recognizes these concerns and has made every effort to reduce the potential impacts in both areas by selecting arguably the most well balanced refrigerant of those available and maintaining a system free of refrigerant leakage. The project architect has also gone to great lengths to acquire architectural products such as rigid insulation that contains no HCFC blowing agents. Can this project receive the point for this credit based on the above evidence?
No. The fact that the requirements set forth in the pilot version of LEED for existing buildings are more lenient on HCFC's than LEED 2.0 for New Construction (LEED-NC) does not justify reducing the requirements for achievement underLEED-NC, which are very clear. LEED-NC sets a clear standard which must be met to achieve this credit. The USGBC's Technical and Scientific Advisory Committee is currently deliberating the ODP verus GWP issue described in this CIR, but has not yet reached a conclusion. No alternative path for compliance is acceptable.
Related Addenda (Corrections & Interpretations)