Innovation Credit Inquiry for ODS Intent: To eliminate the use of ozone-depleting substances to the extent possible. Description: One of the program goals for this project was to eliminate the use of ozone-depleting substances (ODS) to the extent possible. In the project Statement of Work, the Pentagon Renovation Program required that ODS should be eliminated unless: a. There was not an alternate product b. Alternate product selection compromised performance c. Alternate product selection had an unacceptable impact to budget or schedule (note that the program did pay more for some non-ozone depleting substances). LEED Prerequisite EAp3 requires the elimination of ozone-depleting chlorofluorocarbons (CFCs) as refrigerants and LEED Credit EAc4 provides a strategy to eliminate ozone-depleting HCFCs and Halons from HVAC&R equipment. However, the use of CFCs, HCFCs and Halons are not limited to refrigerants. There are many building materials that employ the use of these substances, and it is important to extend the prohibition of ODS to these products as well. They include, but are not limited to, extruded polystyrene, polyurethane and most polyisocyanurate insulations; aerosols, fire extinguishers and fire protection systems; solvents, many chlorine-based compounds and cleaning products. In fact, while refrigerants account for 30% of ODS, solvents account for 36%, and foam insulations account for 14%. As a result of the Montreal Protocol agreements, the United States has developed regulations and directives to phase out ODS. The United States has enacted Title VI of the Clean Air Act Amendments of 1990 (CAAA) to implement elements of the Montreal Protocol. Directives related to the Montreal Protocol such as ODS production phase out schedules and other applicable state and local laws have been developed. Furthermore, Executive Order 12843, Procurement Requirements and Policies for Federal Agencies for Ozone-Depleting Substances, states that all federal agencies must "implement cost-effective programs to minimize the procurement of materials and substances that contribute to the depletion of stratospheric ozone." Could an innovation credit be achieved for the elimination of ozone-depleting substances to the extent possible on this project? The only time ODS were used is where there was not an alternative product; the alternative product was significantly higher; or if performance was compromised by using an alternative product.
Ozone protection is a recognized goal of the LEED program, and the project has identified ozone depleting substances not currently recognized in existing LEED credits. It is conceivable that exemplary performance on ozone protection could be demonstrated by a project to achieve an innovation point in this category. However, the credit inquiry above suggests a number of caveats that seem to back away from this achievement. Exceptions b) and c) above suggest that the commitment to eliminate ODS may have been tempered significantly by other considerations. To achieve a point for elimination of ODS, the project would need to provide good documentation of the ODS identified for use in the project, what alternatives were considered and implemented, and what the overall significance of the ODS reduction was for this project. This should be compared to the significance of refrigerant use already identified by LEED to demonstrate that the adopted measures are as significant to ozone protection as ODS goals already established. Credit would not be granted for a reduction in ODS use that represented only a tiny fraction of the ozone impact of refrigerants. Nor would a point be granted for demonstrating that the project avoided a host of detrimental materials that were never seriously considered for use in the project in the first place. Credit would be subject to demonstration that there are no significant additional upstream ozone-depleting consequences of the selected materials.