EBOM-2009 EAc4: On-Site and Off-Site Renewable Energy 1-6 points

Our community college campus includes an existing 1.06mW solar field that backfeeds two existing metered services. Additional metered services on the campus are serviced by the utility company campus \'loop\', but are not fed directly by the solar array. The solar array currently accounts for 25% of power provided to the existing campus (documentation available). Two new buildings are under construction on campus. Building A is a new 60,000 s.f., 3-story Office and Administration building, which is fed by one of the two metered electrical services tied directly to the solar array. Building B is a 77,000 s.f., two-story Fine Arts facility, which will require a new metered service from the utility company campus \'loop\', but are not fed directly by the solar array. A CIR Ruling dated 08/13/2007 implies that an existing PV array may be applied to new construction on a campus, therefore we would like to pursue EA credit #2 for both projects. Our intent is to provide documentation to express the anticipated annual energy use of each new building as a percentage of the overall energy use on campus, and to apply the same percentage of the power generated by the solar array towards this credit.

Our project is installing a photovoltaic system that will be directly connected to the building\'s energy system, and which will be net-metered with the utility grid. The system is being financed through a power purchase agreement, which requires selling of the RECs to the public utility. A number of Credit Interpretation Rulings have been issued regarding the conditions which must be met for a project to qualify for renewable energy credits under EAc2. These CIRs seem to provide conflicting language. We are seeking clarification regarding these conditions for LEED-NCv2.2 and LEED-CSv2.0 projects. - CIRs dated 10/3/2006 and 5/16/2006 state that the sale of RECs is allowed from an on-site renewable energy system that claims credit under EAc2 if the building owner or energy system owner purchases a total amount of RECs equal to 200% of the system\'s annual rated energy output each year from another source, which must be Green-e eligible. Per the CIRs, the seller of the on-site RECs must also follow all established guidelines for the sale of RECs and not claim any of the environmental attributes for the on-site system. - An administrative ruling dated 7/19/2007, which updates conditions for on-site renewable systems to achieve EAc2 points, does not make reference to the purchase of 200% RECs as an acceptable method of credit achievement. - However, the same 200% REC purchase compliance path is also outlined in the new LEED 2009 BD&C Reference Guide. - A CIR dated April 15, 2009 rules that a project that hosts a PV system, which does not use the PV and/or the PV is fully financed, owned and sold to third parties, can achieve EAc2 by purchasing a total amount of RECs equal to 100% of the system\'s annual rated energy output. Please confirm that a project pursuing EAc2 under LEED-NC v2.2 (or LEED-CSv2.0) can achieve EAc2 points by utilizing the 200% REC purchase methodology as outlined in the 2006 CIRs and 2009 BD&C Reference Guide, or the 100% REC purchase methodology outlined in the 2009 CIR. We are also seeking clarification regarding the length of time for which RECs must be purchased. The 5/16/2006 CIR states that RECs must be purchased "each year." Does this mean that RECs must be purchased each year that the system\'s RECs are sold, indefinitely? Alternatively, the 10/3/2006 CIR states that RECs must be purchased for at least ten years. Please clarify if the REC purchase is required for 10 years, or for the entire length of the utility REC purchase agreement.

The project owner wishes to purchase a green power product that is not Green-e certified, but is asserted to comply with the technical aspects of the standard. How do we document equivalence?

Are Ecoenergy labeled electricity products applicable for LEED EB O&M EA credit 4: Renewable energy?

The project team is planning on installing a Cogeneration System that will take Biogas and turn it into Electricity to be used wholly on-site. The heat produced by this Cogeneration system will also fully be used on-site to preheat heating hot water and domestic hot water via a heat exchanger and potentially to power an absorption chiller.The building will receive the Biogas from a local Biogas provider and plans to enter into at least a 10 year contract with this provider to supply enough Biogas to the building to fully power the planned Cogeneration system. The contract will stipulate both that enough Biogas will be fed into the pipeline to meet required demands of the Cogeneration system and that the Biogas will be metered to prove that the actual amount of Biogas supplied meets the contracted requirements at all times.Though the Biogas is not being piped exclusively to the site (contractually it is supplied exclusively via project ownership funds), it is transported directly to the site in the existing natural gas pipeline. This approach achieves the exact same net result on the Natural Gas grid as piping Biogas exclusively to the project site in its own dedicated pipeline and allows the project to avoid having to dig up 100s of miles of land and lay a brand new pipeline to the project, something that would have a significantly detrimental effect on the local environment. In an urban environment like where the project is located, there is little or no option to be able to refine and extract Biogas on-site or even very close to a site, so the approach the project team is suggesting is the best and most reasonable alternative.Is this approach acceptable in accordance with the Reference Guide and Addendum 100001081 (November 1, 2011)?

Energy and Atmosphere Credit 6 - Green Power requires energy from renewable sources, defining renewable sources by the Centre for Resource Solutions Green E products certification requirements. In Canada, the CAGBC uses the Ecologo certification from Environment Canada Environmental Choice program for certification of their Green Power credit. This project which is located in Canada, is using the USGBC Core and Shell as there is no Core and Shell through the Canadian Green Building Council as of yet. While Green E certification exists in a small amount of Canadian distributors, most of the Canadian market uses Ecologo. In order to pursue the Green Power credit through the USGBC can the Ecologo certification be used in place of the Green E certification requirements? Will the submittal of the Ecologo certification replace the need to prove equivalency with the Green E certification requirements?

Our Campus has a 780 kW PV system installed as a joint venture with a Utility, which was made possible by partial funding from the sale of the REC\'s. The system is installed on 10 existing random building rooftops, with another 136 kW phase nearly commissioned on/near a sports field. We pay a small kWh premium, and will take full ownership after 20 years. PV output is dedicated for campus use, utilizing a combination of direct building connections and connections to the campus owned grid. We would like to apply for EAc2 on a campus basis for approximately 9 separate building projects that do not include their own individual PV installations. The cost to buy REC\'s for 10 years for the entire campus system is prohibitive under our current construction budgets. We propose that individual LEED Building Projects apply for EAC2 using the existing onsite PV renewable source, and buy 10-year REC\'s for 100% of the power claimed on the Template, as qualifying on-site renewable energy. The project REC\'s would be redeemed and solely retained by the individual Building Projects, and would not be shared for use on any other projects. Would purchasing REC\'s then restore the "associated environmental benefit" to the on-site generated renewable project energy claimed; and meet the sustainable intent of the credit as indicated in the CIR Ruling dated 7/20/2009?

LEED Energy and Atmosphere Green Power Credit Interpretation Request A CIR Ruling dated November 2003, allows the portion of Seattle City Light\'s Low Impact Hydropower Institute (LIHI) certified electrical production to be credited towards satisfying the requirements of LEED-NC v2.1 EA Credit 6.0 Green Power. Since May 2003 when the Skagit Hydropower Project received LIHI certification, Seattle City Light began offering green tags to all retail customers through its Green Up program. Customers have the option to purchase a portion or all of their electricity supply from the Stateline Wind Power Project. Stateline began producing electricity in December 2001. Seattle City Light would now like to provide one renewable power program to LEED and other retail electrical customers that combines the portion of generation certified through LIHI, with the balance of renewable power provided with Seattle City Light green tags, in order to allow projects to meet the requirements needed to satisfy the Green Power Credits available across all LEED products. To define the portion of LIHI provided generation, the following table shows the annual contributions of the LIHI certified Skagit Hydroelectric Project (Gorge, Diablo and Ross facilities), total annual generation, annual averages, and three year averages for the first three years of LIHI certification. (Read in table format) MWH | 2003 | 2004 | 2005 | 3 Year Average (Headings) Ross MWh | 673,558 | 674,640 | 465,810 | 604,669 Gorge MWh | 854,491 | 855,132 | 644,060 | 784,561 Diablo MWh | 736,778 | 737,626 | 542,715 | 672,373 Total LIHI Certified MWh | 2,264,827 | 2,267,398 | 1,652,585 | 2,061,603 Total Seattle City Light MWh | 9,440,301 | 9,561,757 | 9,711,154 | 9,571,071 Percentage LIHI | 23.99% | 23.71% | 17.02% | 21.54% City Light proposes that LEED Green Power credits within the Seattle City Light service area can be satisfied through a two year contract with Seattle City Light in which 21.54% of the renewable energy requirement is met by LIHI certified power from the Skagit Hydropower Project and the balance provided by green tags from the Stateline Wind Project.

For two new buildings being constructed on a campus with an existing solar farm, is it acceptable to submit both these buildings for EAc2, provided that the total amount of energy for which credit is being sought is less than the amount produced by the farm?

APPROACH As a firm representing several projects seeking LEED certification, we respectfully submit the following Credit Interpretation Request (CIR). In an effort to achieve EA Credit 6 (EAc60), our firm performed due diligence and has identified a wholesale provider of Green Power. Although retail renewable electricity certificate (REC) products exist in the marketplace, these products are not optimal for high-volume purchasers. Potential purchasers of high-volumes of Green Power should have the option to choose a wholesale certificate-based transaction. Such transactions provide the high-volume buyer flexibility to choose the type of generation it wishes to support, the market from which Green Power is purchased (regulated or competitive), the location of the generation facilities, transparent price discovery, a choice of fuel-mix, and most importantly, flexible pricing structures.

PROPOSED SUBMITTAL ELEMENT An element of LEED Version 2.1 EAc60 requires the submittal of "a copy of the two-year electric utility purchase contract for power generated from renewable sources." With respect to the Potential Technologies & Strategies described on page 32 of the LEED Green Building Rating System, it is our position that this Submittal's requirement of an "electric utility purchase contract" does not accurately reflect the type of contract, or financial agreement, entered into when utilizing the following certificate-based procurement strategies: a) "Green-e certified Tradable Renewable Certificates" b) "other power supply that meets the Green-e renewable power definition" Therefore, we request and propose that the following be added or deemed an acceptable EAc60 Submittal: "a copy of the two-year electric utility purchase OR renewable electricity certificate contract for power generated from renewable sources." The interim acceptability and/or inclusion of the proposed language, as part of EAc60 Submittals, is significant in that it accurately reflects the financial agreement between owner, tenant or responsible party, and the seller. Currently, the owner, tenant or responsible party can procure Green Power from sources other than an electric utility or power marketer, therefore we feel that the EAc60 Submittals should be adapted to clearly represent the distinction and to facilitate and encourage an open and competitive Green Power market.

ADDITIONAL INFORMATION It is our Intent to encourage the development and use of grid-source, renewable energy technologies on a net zero pollution basis through direct payment and/or support to renewable generation facilities. The direct payment will be outlined in a financial agreement between the project owner, tenant or other responsible party and the owner or operator of the renewable generation facility. We intend to employ the services of a wholesale renewable energy broker to facilitate and structure the financial agreement(s) so as to select the least-cost renewable electricity and /or REC provider(s). Our Green Power procurement strategy includes promoting the development of new capacity through the sourcing of renewable electricity certificates in both competitive and regulated electricity markets, with or without the availability of a green pricing program or retail certificate-based products. Moreover, the Requirements set-forth in EAc60 will be met and/or exceeded in a brokered certificate-based Green Power transaction. The wholesale renewable energy broker will provide documentation guaranteeing the renewable generation facility meets and/or exceeds the criteria and requirements set-forth by the Center for Resource Solutions as defined in \'Attachment C: Green-e National Tradable Renewable Certificate (TRC) Standard\' (http://www.green-e.org/pdf/trc_standard.pdf). In addition, the wholesale renewable energy broker will arrange independent, third-party verification to guarantee the renewable electricity was produced and sold as defined in the contract or transaction agreement. Furthermore, a year-end audit will be performed by an independent, third-party accountant verifying that no double counting of renewable generation has occurred. It is our continued position that the proposed language for the EAc60 Submittal Element will promote the growth and development of the renewable energy industry and related sustainable markets. Therefore, we respectfully request that the Project Manager accept the proposed language referenced above and/or grant EAc60 credit to the owner, tenet or responsible party who submits to USGBC a copy of a two-year renewable electricity certificate contract for power generated from renewable sources.

This is an administrative ruling posted by USGBC updating the conditions that must be met for a project to take credit for renewable energy under EAc2.