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LEED v2009
Existing Building Operations
Energy and Atmosphere
On-Site and Off-Site Renewable Energy

LEED CREDIT

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

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Credit language

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Requirements

During the performance period, meet some or all of the building’s total energy use with on-site or off-site renewable energy systems. Points are earned according to the following table, which shows the percentages of building energy use met by renewable energy during the performance period. Off-site renewable energy sources are defined by the Center for Resource Solutions Green-e Energy program’s products certification requirements, or the equivalent. Green power may be procured from a Green-e Energy-certified power marketer or a Green-e Energy-accredited utility program, or through Green-e Energy-certified tradable renewable energy certificates (RECs) or the equivalent [Europe ACP: Green-e Energy Equivalent] [India ACP: Green-e Energy Equivalent]. For on-site renewable energy that is claimed for LEED 2009 for Existing Buildings: Operations & Maintenance credit, the associated environmental attributes must be retained or retired and cannot be sold. If the green power is not Green-e Energy certified, equivalence must exist for both major Green-e Energy program criteria: 1) current green power performance standards, and 2) independent, third-party verification that those standards are being met by the green power supplier over time. Up to the 6-point limit, any combinations of individual actions are awarded the sum of the points allocated to those individual actions. For example, 1 point would be awarded for implementing 3% of on-site renewable energy, and 3 additional points would be awarded for meeting 50% of the building’s energy load with renewable power or certificates during the performance period. Projects must submit proof of a contract to purchase RECs for a minimum of 2 years and must also make a commitment to purchase RECs on an ongoing basis beyond that.

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Frequently asked questions

We are purchasing green power through the local utility but it is not able to provide or sign a two-year contract because of restrictions applied to the utility. Can we still meet the credit requirements with our current purchased green power covering the performance period and then a memo indicating our commitment to continue purchasing green power for the rest of the two-year term?

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We’d like to wait to pursue the option for off-site renewable energy until after the results of the preliminary review. Is it ok to pursue this credit after the preliminary review is complete or as an appeal should we need additional points?

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What time period do purchased RECs and offsets need to cover? Do we need to cover the performance period plus an additional two years after that?

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Addenda

10/1/2013Updated: 2/14/2015
Reference Guide Correction
Description of change:
**Update October 1, 2014: Correction was issued in error and is reversed effective October 1, 2014.

Revise first paragraph under "Off-site Renewable Energy" to read:
"Purchase renewable energy, renewable energy certificates (RECs), to meet some or all of the building’s energy requirements. Green power or renewable energy certificate purchases should be used to offset electricity and purchased steam/high temperature hot water and chilled water use only (Scope 2 emissions). Verified by Green-e Climate or equivalent, should be used to offset emissions from natural gas, propane, or fuel oil combusted on-site. Determine the annual energy needs of the building to identify the amount of green power necessary to satisfy the credit requirements. Purchase or commit to purchasing enough off-site renewable energy or carbon offsets to satisfy the building’s annual energy consumption for 2 years. At the time of application, off-site energy and offsets must have actually been purchased for at least the performance period. Contracts or commitments for future purchases can meet the remainder of the 2-year requirement. Renewable energy and carbon offsets that qualify for this credit must be Green-e certified or equivalent."

Revise first sentence under number 3. to read:
"If Green-e certified power cannot be purchased through a local utility, the tenant and project team can purchase Green-e certified renewable energy certificates to cover electricity or purchased steam/high temperature hot water and chilled water consumption and/or Green-e certified offsets to cover other types of energy consumption (e.g. natural gas, propane, or fuel oil combusted on site)."

***Update October 1, 2014: This addendum has been reversed and revised as of October 1, 2014. RECs may only be used to offset Scope 2 emissions associated with electricity. Carbon Offsets must be used for all other emissions.

Revise first paragraph under "Off-site Renewable Energy" to read:
"Purchase renewable energy, renewable energy certificates (RECs), to meet some or all of the building’s energy requirements. Green power or renewable energy certificate purchases should be used to offset electricity use only (Scope 2 emissions). Verified by Green-e Climate or equivalent, should be used to offset emissions from purchased steam or from natural gas, propane, or fuel oil combusted on-site. Determine the annual energy needs of the building to identify the amount of green power necessary to satisfy the credit requirements. Purchase or commit to purchasing enough off-site renewable energy or carbon offsets to satisfy the building’s annual energy consumption for 2 years. At the time of application, off-site energy and offsets must have actually been purchased for at least the performance period. Contracts or commitments for future purchases can meet the remainder of the 2-year requirement. Renewable energy and carbon offsets that qualify for this credit must be Green-e certified or equivalent."

Revise first sentence under number 3. to read:
"If Green-e–certified power cannot be purchased through a local utility, the tenant and project team can purchase Green-e–certified renewable energy certificates to cover electricity consumption and/or Green-e certified carbon offsets to cover other types of energy consumption (e.g., purchased steam, or natural gas, propane, or fuel oil combusted on-site)."
Campus Applicable
No
Internationally Applicable:
Yes
11/2/2009Updated: 2/14/2015
Reference Guide Correction
Description of change:
In the tenth line of the first paragraph, replace both instances of "25 MBtus" with "12.5 MBtus" so it becomes "...performance period is 12.5 MBtus for electricity and 12.5 MBtus for natural gas"
Campus Applicable
No
Internationally Applicable:
No
11/3/2010Updated: 2/14/2015
Reference Guide Correction
Description of change:
In the third line, insert "of" after "purchase" so the text becomes "The purchase of Green-e certified RECs..."
Campus Applicable
No
Internationally Applicable:
No
11/3/2010Updated: 2/14/2015
Reference Guide Correction
Description of change:
In the seventh line of the paragraph, replace "(1 MBtus/1,000 MBtus)" with "(10 MBtus/1,000 MBtus)"
Campus Applicable
No
Internationally Applicable:
No
4/1/2012
LEED Interpretation
Inquiry:

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?

Ruling:

The CIR Ruling dated 7/20/2009 (#2616), states that if the project sold renewable energy certificates associated with the on-site renewable energy system, the team may not take credit for the system under EAc2, since the system would have no associated environmental benefit. The project teams approach of purchasing 10-year REC\'s for 100% of the power claimed on the Template, to restore the associated environmental benefit is acceptable. The project must provide sufficient documentation to ensure the portion of the on-site renewable energy system designated for each building is not used on other projects. Additionally, the project team should provide documentation, including contractual terms, to verify the purchase of the necessary volume of REC\'s. The project team may not apply any of the REC\'s purchased to restore the associated environmental benefits of the on-site renewable energy system for the purposes of achieving EAc2 towards achieving EAc6, Green Power.

Campus Applicable
No
Internationally Applicable:
No
1/4/2016
LEED Interpretation
Inquiry:

We would like to confirm the applicability of a District Lake Source Cooling (LSC) operation as an eligible on-site renewable energy source for LEED NC 2009 and LEED v4 BD+C. This innovative Lake Source Cooling facility, which has been in operation since 2000, uses the deep cold waters of a large lake as a non-contact renewable cooling source for a campus chilled water system. At a depth of ~250ft the bottom of the lake maintains a steady year-round temperature of 39-41 F. The only energy used in the system is pumping energy and the system has demonstrated an 86% reduction in energy use over conventional water cooled chiller. Extensive environmental impact studies were carried out prior to and after operation and all have concluded that adverse environmental impacts have been minimized or avoided. It does not use any vapor compression cycle and no water is wasted.

The LEED 2009 Reference Guide states "geothermal energy systems using deep-earth water or steam sources (but not vapor compression systems for heat transfer) may be eligible for this credit." The project team proposes to account for the renewable energy credit by calculating savings between the proposed case model with LSC system and a proposed case model with conventional refrigeration system that complies with the ASHRAE 90.1 code requirements.

Ruling:

The applicant is requesting whether deep-water Lake Source Cooling that replaces the refrigeration cycle for the campus central plant system may be used to claim credit for on-site renewable energy for the project under EA Credit 2: Renewable Energy Generation. The proposed approach is not acceptable since the lake source cooling does not qualify as a geothermal energy source using deep water or steam sources. Furthermore, the resource would be depleted and would have a negative environmental impact if the cooling capacity were increased exponentially (i.e. the resource provides increasingly less environmental benefit for other/subsequent projects beyond this one); therefore it is not considered on-site renewable energy.

It is noted that the proposed approach is an extremely efficient form of cooling, and while no credit is allowed as an on-site renewable source, significant credit would be achieved for EA Credit 1: Optimize Energy Performance using the ASHRAE 90.1 Appendix G modeling processes.

Campus Applicable
Yes
Internationally Applicable:
Yes
1/7/2009
LEED Interpretation
Inquiry:

We are pursuing the Offsite Renewable Energy portion of this credit through the purchase of Green-e certified Renewable Energy Certificates (RECs). The intent of this credit is to "encourage and recognize increasing levels of on-site and off-site renewable energy in order to reduce environmental impacts associated with fossil fuel energy use." The USGBC\'s guidelines in LEED-EB are not in synch with policy standards from Center for Resource Solutions (CRS) for Green-e Energy, WRI\'s guidelines for addressing Scope 1, 2 and 3 emissions or general industry accepted best practices. The problem relates to USGBC in LEED-EB requiring the calculation of TOTAL LOAD from ALL ENERGY SOURCES(including natural gas, steam heat, propane, etc.) on the building energy use side to set the amount of offset; while Green-e Energy states that REC\'s cannot be used to offset anything other than direct electricity generation (scope 2 emissions). As stated on p. 15 of the Green-e Code of Conduct: B. Communicating the Emissions Avoidance Value of a Green-e Energy Certified Product Green-e Energy Certified renewable energy products must be denominated in megawatt-hours (MWh) or kilowatt-hours (kWh). Consistent with this policy, Participants can market their certified products as instruments to address the environmental impacts associated with the consumption of electricity. One aspect of these impacts is the indirect carbon dioxide emissions arising from the purchase of electricity generated through the combustion of fossil fuels, classified as "Scope 2" emissions by the World Resources Institute\'s Greenhouse Gas Protocol. The explicit marketing of Green-e Energy Certified renewable energy products as a means to reduce or offset emissions from anything other than the consumption of electricity purchased from the grid shall not be permitted. Additionally, every other LEED type (NC, CI, CS, etc.) only requires the project owner to offset some percentage of the building\'s electricity use. LEED EB 2.0 and LEED EB OM are the only versions that (mistakenly) include non-scope 2 emissions. We propose to earn EA Credit 2.1 by offsetting only our scope 2 (electricity) emissions, in the percentages outlined in the credit. This will provide consistency with other LEED types and, most importantly, align with Green-e and WRI guidance on the issue. Further, it would seem that fewer LEED EB projects are choosing to use green power than LEED NC, CI, or CS projects, due in large part to the higher costs associated with offsetting scope 1 and 3 emissions in addition to scope 2. Allowing projects to earn this credit by offsetting only scope 2 (electricity) emissions should actually increase the number of participating projects, thus encouraging increasing levels of off-site renewable energy (aligning with the intent of this credit).

Ruling:

The proposal to offset only electricity emissions in the percentages outlined in the credit would not be acceptable to earn EA Credit 2. In order for a building to be considered climate neutral, all fuel consumption by building uses must be addressed including direct fossil fuel use. Secondly, in addition to climate neutral considerations, the decision to include total load from all energy sources as a basis for LEED-EB v2.0 EAc2 offset level requirements was made during the lengthy LEED-EB pilot program process to help address thermal energy sources and provide a better fit with the U.S. EPA\'s ENERGY STAR Portfolio Tool utilized for LEED-EB EAp2 and EAc1. In regards to offsets, with the release of programs like Green-e climate to complement Green-e energy, the USGBC agrees that Green power or REC purchases or the equivalent should only be used to offset electricity use, Scope 2 emissions. Scope 1 & 3 emissions from natural gas, purchased steam, fuel oil, or propane use should use carbon offsets, verified through a program like Green-e climate or equivalent. Concerns raised above regarding the encouragement of greater participation rates for this credit are always addressed as part of new EB rating system versions and could be accomplished by making adjustments to the required minimum threshold levels as readily as through significant changes to the credit requirements. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
11/6/2006
LEED Interpretation
Inquiry:

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.

Ruling:

[Updated 12/21/2006] The applicant is requesting qualification of a Low Impact Hydropower Institute (LIHI) certified power for EAc6, Green Power. Renewable energy power sources are defined by the Center for Resource Solutions Green-e program. The proposed combination will be categorized as a Competitive Electricity and Utility Green Pricing Product. To demonstrate compliance with credit requirements any power supplied should demonstrate equivalence with the section IV of the Green-e Renewable Electricity Certification Program National Standard Version 1.3, as well as with all the requirements of CIR ruling dated 11/4/2002.

Campus Applicable
No
Internationally Applicable:
No
11/4/2002
LEED Interpretation
Inquiry:

ENERGY & ATMOSPHERE: Green Power (EA Credit 6.0) Credit Interpretation Request Washington State does not require electric utilities to provide retail open-access. The Seattle Justice is required to purchase electrical power from the local municipal utility, Seattle City Light. Seattle City Light (SCL) wants to prove a LEED electrical energy product that qualifies for the EA Credit 6.0 to any LEED project within SCL\'s service area and proposes the following approach: Seattle City Light estimates that the current resource mix includes 25-28% renewable generation as defined by Green-e, composed of low impact hydro and possibly wind and other renewables. The utility will certify the low impact hydro component, estimated at 25% of the total mix, through the Low Impact Hydropower Institute. SCL will assist projects to "green up" the remaining 25% balance in order to achieve 50% renewable energy content by facilitating the purchase of Green Tags for participating LEED projects. Projects may elect to purchase green tags from existing or new renewable resources from SCL, the Bonneville Power Administration or other providers of green tags. As a part of the Credit documentation, the Seattle Justice Center will write a letter attesting that the mix or renewables serving the LEED project meets the following criteria: 1. SCL supplied renewable power plus Green Tags are equal to 50% of the project\'s energy consumption. 2. The energy and green tag sources meet the Green-e definition of renewable energy, which includes wind, solar, low impact hydro, methane recovery, etc., and, 3. Green Tags purchased have not been double sold, as verified by contract or purchase agreement.

Ruling:

Per LEED Interpretation 0214-EAc60-122101, if Green-e rated power is not available in the project\'s region, other sources of green power may be eligible for consideration. The alternative source must satisfy the criteria of the Green-e program, which is detailed on page 163 of the LEED Reference Guide (formatted version of June 2001). Of the five listed criteria, one is based on renewable content of 50% of more. The alternative energy source must also meet the other four criteria. If the SCL product contains 25% low impact hydropower, certifies its low impact hydro power through the Low Impact Hydropower Institute, as required in the Green-e program, AND meets the other Green-e criteria, SCL energy could be considered \'equivalent\' to half of the green power benefit associated with Green-e products. The rest of the green power benefit would need to be purchased in the form of Green Tags for half of the building load. In summary, in order to achieve a Green Power credit for SCL product the following is required: 1. SCL must certify its low impact hydropower with the Low Impact Hydropower Institute. 2. SCL must write a letter stating what percentage of its product is comprised of renewable energy (including certified low impact hydropower). 3. SCL product must also confirm that the remaining green-e criteria are met (addressing emissions, \'new renewable\' power and nuclear power) and state this in their letter. 4. The project must purchase Green Tags to meet the difference between SCL\'s product renewable % and green-e renewable content of 50%. (i.e.. if SCL contains 25% renewable content, this meets half the requirement and Green Tags would be required for the equivalent of half the building load over two years to meet the other half of the requirement.) Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/9/2011
LEED Interpretation
Inquiry:

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?

Ruling:

The proposed methodology is acceptable as long as the documentation is provided verifying what percentage of the solar farm is supporting each building and as long as the projected project cost for each project is consistent with the percentage of the solar farm that would need to be installed to support that building. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
3/28/2007
LEED Interpretation
Inquiry:

What is required in order to document equivalence with Green-e certified power

Ruling:

Using a formal third-party verification program is not required, but projects are required to document to USGBC that their renewable supplier has 1) met the Green-e criteria, and 2) properly accounted for the eligible renewable resources sold. This documentation to USGBC must include some type of meaningful verification work performed by a qualified, disinterested third party. Example documentation methods to USGBC that meet this requirement include: a) providing a state-mandated power disclosure label from the renewable supplier in states with meaningful regulatory requirements for renewable energy disclosure and accounting practices, as well as meaningful penalties for violations; b) providing a green power scorecard or rating from a credible, independent entity that performs meaningful verification of green power characteristics and accounting practices. In either case projects must confirm that the third-party entity\'s regulatory or verification programs are meaningful, summarizing those programs to USGBC as part of their certification application and highlighting any auditing or other independent checks the program performs. Other documentation methods will be considered on a case-by-case basis. This ruling applies to all the LEED Rating Systems having a similar "green power" credit. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/5/2003
LEED Interpretation
Inquiry:

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.

Ruling:

The proposed power resale marketing strategy appears to meet the intent of encouraging the use of grid-source renewable energy, but the description of how this strategy encourages the development of new renewable energy sources is unclear. A project submitting for this credit would need to clearly document that the power purchased under this arrangement meets or exceeds the Green-e Certification requirements. Provision of a "renewable electricity contract for power generated from renewable sources" is acceptable provided the contract represents purchase of at least 2 years worth of renewable electricity for 50% for the building's energy load. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/9/2011
LEED Interpretation
Inquiry:

For a project that is obtaining its energy from a small hydro-electric plant, the energy from which is classified as renewable by the local government, is the use of renewable energy from small hydroelectric plant an acceptable approach to obtain the possible points of the EA Credit 4: On-site and Off-site Renewable Energy?

Ruling:

In order to claim energy from small-scale offsite hydroelectric plants as renewable, the project team must demonstrate equivalency to (or actual) Green-E certification of the energy. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
7/19/2007
LEED Interpretation
Inquiry:

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.

Ruling:

A previous ruling (EAc2.1 CIR Ruling 10-03-2006), defined conditions that must be met for projects to qualify for renewable energy credits under EAc2. This ruling updates the previous ruling defining alternative conditions for projects to qualify for EAc2 renewable energy credits. A project will be eligible to achieve points under EAc2 and qualify for renewable energy credits for the system under EAc1 if the project meets the following conditions: 1 The renewable energy system is installed within the boundaries of the project or on the project site. 2 The renewable energy system is connected immediately adjacent to the utility meter. 3 A 10-year (minimum) contract for on-site generation with the owner of the Energy System is established. 4 The RECs associated with the renewable energy system are not sold. 5 The Energy System owner does not count the RECs associated with the renewable energy system to meet a mandated renewable portfolio standard goal or provides the RECs to the project owner. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
11/1/2011
LEED Interpretation
Inquiry:

The LEED EB:O&M Reference Guide does not specify precisely when during the LEED application review process Renewable Energy Credits (RECs) must be purchased, it only requires that the RECs meet specific percentages of the building\'s total energy use from the performance period.Our project team would like to wait until after the final review to file an appeal in order to purchase RECs and have EAc4 points included in the project\'s total before accepting certification.Can EAc4 thresholds be met by RECs purchased after the final review when filed through the appeal process?

Ruling:

A project team may elect to add and pursue EA c4 as part of an appeal after the project building\'s performance period has ended and after the Final Review has been completed and purchase RECs at that time, as long as the RECs purchased are based on the total annual site energy usage value reported for EAp2 and are allocated to the project building only. Note that at the time of appeal submittal, the project must have entered into a contract or commitment for future purchases to meet the 2-year requirement. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
10/1/2014
LEED Interpretation
Inquiry:

The project has a contract in place for carbon offsets as related to credit EAc4 On-site and Off-site Renewable Energy. The project team would like to show these carbon offsets are the equivalent as being verified by Green-e Climate. The Climate Action Reserve has verified the carbon offsets. These offsets are high quality and the Climate Action Reserve is usually referred to as the best offset protocol. Since CAR has been endorsed by Green-e, is retirementment of the offsets in the name of the project sufficient to demonstrate equivalency?

Ruling:

It appears that the process of retiring the carbon offsets in the name of the project may be one means of confirming that emissions reductions come from verified and certified supply, and from projects validated and registered under high-quality project standards. Alternative means of demonstrating equivalency would also include documentation of an annual 3rd party audit performed for the provider's sales of carbon offsets that demonstrates all five criteria below.
When using retirement of carbon offsets to demonstrate equivalency, submit a narrative describing how the offsets comply with the following five criteria:
- A verifiable chain of custody
- A verifiable age of renewable energy
- Tracking of GHG reductions from eligible sources
- A mechanism to prevent double counting
- Third-party verified retail transactions.
The contract provided must include language confirming all five criteria have been implemented by the retailer. Proof of certification by a Green-e Endorsed Program (such as The Climate Action Reserve) satisfies the first three criteria have been met.
In addition, provide documentation that the offsets have been retired in the project's name (screen captures, PDFs of database pages, etc.). For example, the "Retirement Reason Details" in the registry for The Climate Action Reserve could include either the LEED Project ID or the registered project name.

Campus Applicable
No
Internationally Applicable:
Yes
8/26/2008
LEED Interpretation
Inquiry:

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.

Ruling:

The project team is requesting clarification on whether or not EAc2 can be pursued for new campus projects when a solar PV array previously exists. Under the LEED Application Guide for Multiple Buildings and On-Campus Building Projects (https://www.usgbc.org/ShowFile.aspx?DocumentID=1097) it states: In the case where the renewable energy equipment is not physically located on the applicant building(s), provide data for each building showing the projected energy consumption and the percentage to be met with their prorated or dedicated share of renewable energy. The owner should also submit a certification letter acknowledging that the renewable energy from a central system will apply only to the submitted project(s) and will not be applied to subsequent buildings for any future LEED certifications. Thus, both projects can pursue EAc2, provided a previously undedicated share of renewable energy generated is allocated to each building project. Update April 15, 2011: Please note that all 2009 projects in multiple building situations must follow the 2010 Application Guide for Multiple Buildings and On-Campus Building Projects, located here: https://www.usgbc.org/ShowFile.aspx?DocumentID=7987. 2009 project teams should check this document for up to date guidance on all multiple building issues. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
1/1/2013
LEED Interpretation
Inquiry:

In preparation for LEED certification over a year of energy monitoring has been conducted to establish energy usage and achieve EnergyStar certification. The owner is considering installing a PV system that will generate over 12% of its energy use (comprehensive evaluation of gas + electric). However, O&M states that the system must offset power during the performance period. Can EAc4 points be achieved based on system specifications that utilize performance period data for sizing rather than actual solar system performance monitoring?

Ruling:

Points for EAc4 cannot be achieved based on system specifications that utilize performance period data for sizing in lieu of actual solar system performance monitoring during the performance period. Unlike the LEED Rating Systems for New Construction, Core & Shell and Schools, the LEED 2009 Rating System for Existing Buildings: Operations and Maintenance is a whole building rating system designed to certify the sustainability of the ongoing daily operations of existing commercial and institutional buildings. As such, EB O&M is comprised of a planning, implementation and performance period measurements for each of the prerequisites and credits. EAc4: On-site and Off-site Renewable Energy, as its name implies, has two pathways to obtain up to six points. During the performance period some or all of the buildings energy may be met with On-site and Off-site Renewable Energy. If the solar PV system is not installed and operating during a portion of the performance period to confirm performance, the project team may consider the purchase of renewable energy certificates (RECs) to demonstrate credit compliance. In lieu of the commitment to purchase RECs on a continuing basis, a commitment to provide a percentage of the buildings total energy consumption generated on-site at the conclusion of the RECs purchase may be considered. That would allow additional time to complete the design and installation of the solar PV array. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
8/21/2009
LEED Interpretation
Inquiry:

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.

Ruling:

The applicant is asking for clarification on the quantity and length of time for which RECs need to be purchased in order to achieve credit for On-Site Renewable energy that is sold to the grid. Most of the various CIRs referenced by the applicant are relevant; some of these rulings appear to add confusion to the quantity of RECs that are needed. It has been determined that the project can achieve EAc2 by purchasing a total amount of RECs equal to 100% of the system\'s annual rated energy output. There must be at least a 10-year contract for the purchase of the energy output. This CIR supersedes the 200% requirement set by the CIR Ruling dated 5/16/2006. Please note this CIR only dictates the quantity of RECs and the duration and other requirements related to documentation and green-e stay valid as stated in the 5/16/2006 and other CIRs.

Campus Applicable
No
Internationally Applicable:
No
5/9/2011
LEED Interpretation
Inquiry:

Is it acceptable to use a mix of 10% biofuel and 90% natural gas to meet the requirements of EAc2, and is there a minimum time period for which the biofuel must be purchased from the utility company?

Ruling:

For biofuels to qualify, the bio-gas system must meet the requirements as per table 3 of EAc2 as per the LEED-NC v2.2 Reference Guide and a signed declaration from the provider that clearly shows the source must be provided. The intent is for a portion of the building\'s energy to come from biofuel for the duration of its existence. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
3/28/2007
LEED Interpretation
Inquiry:

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?

Ruling:

Using a formal third-party verification program is not required, but projects are required to document to USGBC that their renewable supplier has 1) met the Green-e criteria, and 2) properly accounted for the eligible renewable resources sold. This documentation to USGBC must include some type of meaningful verification work performed by a qualified, disinterested third party. Example documentation methods to USGBC that meet this requirement include: a) providing a state-mandated power disclosure label from the renewable supplier in states with meaningful regulatory requirements for renewable energy disclosure and accounting practices, as well as meaningful penalties for violations; b) providing a green power scorecard or rating from a credible, independent entity that performs meaningful verification of green power characteristics and accounting practices. In either case projects must confirm that the third-party entity\'s regulatory or verification programs are meaningful, summarizing those programs to USGBC as part of their certification application and highlighting any auditing or other independent checks the program performs. Other documentation methods will be considered on a case-by-case basis. This ruling applies to all the LEED Rating Systems having a similar "green power" credit. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
2/9/2009
LEED Interpretation
Inquiry:

Question: Are perforated metal wall solar air heating systems eligible for credit under LEED CS EAc2?" Background: The intent of the credit is to "encourage and recognize increasing levels of on-site renewable energy self-supply in order to reduce environmental and economic impacts associated with fossil fuel energy use." "Renewable Energy Systems Eligible for EA Credit 2", "Solar Thermal Systems" (p. 224) states "Active solar thermal energy systems that employ collection panels; heat transfer mechanical components such as pumps or fans, and a defined heat storage system, such as a hot water tank are eligible for this credit." "Systems Not Eligible for EA Credit 2" (p. 224) states excludes "architectural passive solar and daylighting strategies provide savings that are chiefly efficiency related". Perforated metal wall solar air heating systems include a collector panel (the wall) and a heat transfer mechanical component (fan or fans) but typically do not include a defined thermal storage component. Natural Resources Canada considers these to be active systems ("Total energy savings result from four different mechanisms: [including] active solar heating of ventilation air" http://www.canren.gc.ca/renew_ene/index.asp?CaID=50&PgID=347)

Ruling:

The perforated metal wall solar air heating system described is considered an active system and therefore can contribute toward EA Credit 2. The applicant should note that there are no previously approved calculators for the amount of energy offset by such a system and therefore, the applicant must provide detailed calculations, including all assumptions and applicable weather data, during the review process. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/9/2011
LEED Interpretation
Inquiry:

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

Ruling:

Ecoenergy-labeled electricity products can qualify for EAc4 provided that equivalency with Green-e certification is demonstrated by the project team. The Green-e standard is located on their website: http://wee.green-e.org

Campus Applicable
No
Internationally Applicable:
No
6/15/2007
LEED Interpretation
Inquiry:

Our project is a 238,000 SF brick manufacturing facility in Terre Haute, Indiana. The project consists of 5,000 SF of office space and 233,000 SF of manufacturing area, including extrusion, drying, and kiln equipment. The energy required for the manufacturing process exceeds 90% of the facility\'s total energy load. We are submitting a separate CIR to address quantifying energy savings for the manufacturing process. In the brick industry, the typical manufacturing process (specifically the kiln) utilizes natural gas as a primary energy source. To maximize energy savings and reduce the environmental and economic impact of brick-making, our Client has selected a site that is directly adjacent to a municipal landfill, with plans to fuel the kiln with methane off-gassing from the landfill. Currently, the methane is collected, burned, and flared directly into the atmosphere; however, it can be contained, cleaned and pressurized so that it may be used constructively in lieu of natural gas. Our Client has obtained permission from the landfill to tap into this energy source. As part of our project scope, we will install compressors and an underground pipeline to transport the landfill gas to the manufacturing facility. This will replace the majority of natural gas that powers the kiln and vastly reduce the amount of on-grid energy required by the facility. Our Client will install and maintain all equipment required to prepare, transport, and apply this methane to the manufacturing process. Other than allowing us to tap into this un-used resource, the operator of the landfill will have no involvement or responsibility in this venture. Please verify that landfill off-gassing qualifies for credit under EA credit 2 in this case, even though the landfill itself is not owned by our client or located within our project site. We will calculate renewable energy as a percentage of the total building annual energy cost, including process energy.

Ruling:

Yes, the system described meets the requirements needed to achieve credit under EAc2, despite the fact that the source of the energy (here, the landfill gas) is not directly on site. Because the project owner will install and maintain the equipment for the land fill gas extraction, and be the sole user of the gas, the renewable energy system falls under the LEED scope of the project and can effectively be considered "on-site." However, in order for this project to achieve LEED-NC v2.2 EAc2 credits, the following conditions need to be met: 1) Because the landfill gas will be used to in lieu of natural gas in a manufacturing process, the full process loads must be included in all energy cost and use estimates, whether or not the project is attempting to earn any credits under EAc1 (it is not clear from the CIR if full energy modeling will be performed for this credit). As per LEED-NC v2.2 EAc1 CIR ruling dated 5/13/2007, a full description will need to be provided of how the baseline and proposed energy usage were estimated for the project, as industrial energy usage does not fall under the purview of ASHRAE 90.1-2004. Because of the nature of this project, the EAc2 compliance path using CBECS data to estimate annual energy costs is not appropriate. 2) As per the LEED-NC v2.2 EAc2 Reference Guide language, the method used to predict the quantity of energy generated by on-site renewable systems should be clearly stated in the LEED submittal narrative... Cost savings from renewable energy systems\' shall be reported exclusive of energy costs associated with system operation (i.e., deduct energy costs of pumps, fans, and other auxiliary devices). 3) Because the landfill is on municipal property, but the gas extraction system will be privately owned by the project owner, a clear chain of custody for rights to the gas and the associated Renewable Energy Credits (RECs) needs to be documented. Based on the documentation requirements outlined in the LEED-NC v2.1 EAc2.1CIR ruling dated 10/3/2006 (which specifically addressed third party ownership of a renewable energy system) the following requirements need to be met: A. There is a minimum 10-year contract with the local municipality to secure the rights to the landfill gas that will be used in the project. B. There must be clear documentation for accounting purposes whether the purchase includes the RECs or just the landfill gas. C. If the purchase does not include the RECs, the building owner or energy system owner must make the 200% offset REC purchase described in the first portion of the CIR for at least 10 years. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/9/2011
LEED Interpretation
Inquiry:

Can a waste-to-energy generation facility qualify for EAc2?

Ruling:

Combustion of municipal solid waste is excluded from eligibility of this credit. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
7/1/2014
LEED Interpretation
Inquiry:

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)?

Ruling:

Directed Biogas purchase is not considered on-site renewable energy based on the current EAc2 credit requirements, addenda and LEED Interpretations, because the gas consumed on-site is not the same as the biogas that the project purchased. Please note that the referenced Addendum 100001081 does not allow for the fuel used on site to be different than the fuel that was purchased for the project. The referenced addendum applies for situations such as landfill gas piped directly to the project from a nearby landfill, or wood pellets from wood mill residue that are trucked to the project. In either case, it would not be acceptable for the landfill gas or pellets generated from wood mill residue to be "purchased" by the project, used in another project, and replaced in the project with natural gas or wood pellets produced from tree tops. Also, note that NREL refers to directed biogas as off-site renewable energy.

Campus Applicable
Yes
Internationally Applicable:
Yes
10/3/2008
LEED Interpretation
Inquiry:

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?

Ruling:

The project team is asking if its renewable energy certified by Ecologo will comply with the credit requirements for its project located in Canada. If the renewable energy is not Green-e certified, then the project team must prove equivalency to the Green-e technical requirements or pursue certification through LEED Canada. Applicable Internationally; Canada.

Campus Applicable
No
Internationally Applicable:
Yes
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Requirements

During the performance period, meet some or all of the building’s total energy use with on-site or off-site renewable energy systems. Points are earned according to the following table, which shows the percentages of building energy use met by renewable energy during the performance period. Off-site renewable energy sources are defined by the Center for Resource Solutions Green-e Energy program’s products certification requirements, or the equivalent. Green power may be procured from a Green-e Energy-certified power marketer or a Green-e Energy-accredited utility program, or through Green-e Energy-certified tradable renewable energy certificates (RECs) or the equivalent [Europe ACP: Green-e Energy Equivalent] [India ACP: Green-e Energy Equivalent]. For on-site renewable energy that is claimed for LEED 2009 for Existing Buildings: Operations & Maintenance credit, the associated environmental attributes must be retained or retired and cannot be sold. If the green power is not Green-e Energy certified, equivalence must exist for both major Green-e Energy program criteria: 1) current green power performance standards, and 2) independent, third-party verification that those standards are being met by the green power supplier over time. Up to the 6-point limit, any combinations of individual actions are awarded the sum of the points allocated to those individual actions. For example, 1 point would be awarded for implementing 3% of on-site renewable energy, and 3 additional points would be awarded for meeting 50% of the building’s energy load with renewable power or certificates during the performance period. Projects must submit proof of a contract to purchase RECs for a minimum of 2 years and must also make a commitment to purchase RECs on an ongoing basis beyond that.

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We are purchasing green power through the local utility but it is not able to provide or sign a two-year contract because of restrictions applied to the utility. Can we still meet the credit requirements with our current purchased green power covering the performance period and then a memo indicating our commitment to continue purchasing green power for the rest of the two-year term?

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We’d like to wait to pursue the option for off-site renewable energy until after the results of the preliminary review. Is it ok to pursue this credit after the preliminary review is complete or as an appeal should we need additional points?

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What time period do purchased RECs and offsets need to cover? Do we need to cover the performance period plus an additional two years after that?

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10/1/2013Updated: 2/14/2015
Reference Guide Correction
Description of change:
**Update October 1, 2014: Correction was issued in error and is reversed effective October 1, 2014.

Revise first paragraph under "Off-site Renewable Energy" to read:
"Purchase renewable energy, renewable energy certificates (RECs), to meet some or all of the building’s energy requirements. Green power or renewable energy certificate purchases should be used to offset electricity and purchased steam/high temperature hot water and chilled water use only (Scope 2 emissions). Verified by Green-e Climate or equivalent, should be used to offset emissions from natural gas, propane, or fuel oil combusted on-site. Determine the annual energy needs of the building to identify the amount of green power necessary to satisfy the credit requirements. Purchase or commit to purchasing enough off-site renewable energy or carbon offsets to satisfy the building’s annual energy consumption for 2 years. At the time of application, off-site energy and offsets must have actually been purchased for at least the performance period. Contracts or commitments for future purchases can meet the remainder of the 2-year requirement. Renewable energy and carbon offsets that qualify for this credit must be Green-e certified or equivalent."

Revise first sentence under number 3. to read:
"If Green-e certified power cannot be purchased through a local utility, the tenant and project team can purchase Green-e certified renewable energy certificates to cover electricity or purchased steam/high temperature hot water and chilled water consumption and/or Green-e certified offsets to cover other types of energy consumption (e.g. natural gas, propane, or fuel oil combusted on site)."

***Update October 1, 2014: This addendum has been reversed and revised as of October 1, 2014. RECs may only be used to offset Scope 2 emissions associated with electricity. Carbon Offsets must be used for all other emissions.

Revise first paragraph under "Off-site Renewable Energy" to read:
"Purchase renewable energy, renewable energy certificates (RECs), to meet some or all of the building’s energy requirements. Green power or renewable energy certificate purchases should be used to offset electricity use only (Scope 2 emissions). Verified by Green-e Climate or equivalent, should be used to offset emissions from purchased steam or from natural gas, propane, or fuel oil combusted on-site. Determine the annual energy needs of the building to identify the amount of green power necessary to satisfy the credit requirements. Purchase or commit to purchasing enough off-site renewable energy or carbon offsets to satisfy the building’s annual energy consumption for 2 years. At the time of application, off-site energy and offsets must have actually been purchased for at least the performance period. Contracts or commitments for future purchases can meet the remainder of the 2-year requirement. Renewable energy and carbon offsets that qualify for this credit must be Green-e certified or equivalent."

Revise first sentence under number 3. to read:
"If Green-e–certified power cannot be purchased through a local utility, the tenant and project team can purchase Green-e–certified renewable energy certificates to cover electricity consumption and/or Green-e certified carbon offsets to cover other types of energy consumption (e.g., purchased steam, or natural gas, propane, or fuel oil combusted on-site)."
Campus Applicable
No
Internationally Applicable:
Yes
11/2/2009Updated: 2/14/2015
Reference Guide Correction
Description of change:
In the tenth line of the first paragraph, replace both instances of "25 MBtus" with "12.5 MBtus" so it becomes "...performance period is 12.5 MBtus for electricity and 12.5 MBtus for natural gas"
Campus Applicable
No
Internationally Applicable:
No
11/3/2010Updated: 2/14/2015
Reference Guide Correction
Description of change:
In the third line, insert "of" after "purchase" so the text becomes "The purchase of Green-e certified RECs..."
Campus Applicable
No
Internationally Applicable:
No
11/3/2010Updated: 2/14/2015
Reference Guide Correction
Description of change:
In the seventh line of the paragraph, replace "(1 MBtus/1,000 MBtus)" with "(10 MBtus/1,000 MBtus)"
Campus Applicable
No
Internationally Applicable:
No
4/1/2012
LEED Interpretation
Inquiry:

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?

Ruling:

The CIR Ruling dated 7/20/2009 (#2616), states that if the project sold renewable energy certificates associated with the on-site renewable energy system, the team may not take credit for the system under EAc2, since the system would have no associated environmental benefit. The project teams approach of purchasing 10-year REC\'s for 100% of the power claimed on the Template, to restore the associated environmental benefit is acceptable. The project must provide sufficient documentation to ensure the portion of the on-site renewable energy system designated for each building is not used on other projects. Additionally, the project team should provide documentation, including contractual terms, to verify the purchase of the necessary volume of REC\'s. The project team may not apply any of the REC\'s purchased to restore the associated environmental benefits of the on-site renewable energy system for the purposes of achieving EAc2 towards achieving EAc6, Green Power.

Campus Applicable
No
Internationally Applicable:
No
1/4/2016
LEED Interpretation
Inquiry:

We would like to confirm the applicability of a District Lake Source Cooling (LSC) operation as an eligible on-site renewable energy source for LEED NC 2009 and LEED v4 BD+C. This innovative Lake Source Cooling facility, which has been in operation since 2000, uses the deep cold waters of a large lake as a non-contact renewable cooling source for a campus chilled water system. At a depth of ~250ft the bottom of the lake maintains a steady year-round temperature of 39-41 F. The only energy used in the system is pumping energy and the system has demonstrated an 86% reduction in energy use over conventional water cooled chiller. Extensive environmental impact studies were carried out prior to and after operation and all have concluded that adverse environmental impacts have been minimized or avoided. It does not use any vapor compression cycle and no water is wasted.

The LEED 2009 Reference Guide states "geothermal energy systems using deep-earth water or steam sources (but not vapor compression systems for heat transfer) may be eligible for this credit." The project team proposes to account for the renewable energy credit by calculating savings between the proposed case model with LSC system and a proposed case model with conventional refrigeration system that complies with the ASHRAE 90.1 code requirements.

Ruling:

The applicant is requesting whether deep-water Lake Source Cooling that replaces the refrigeration cycle for the campus central plant system may be used to claim credit for on-site renewable energy for the project under EA Credit 2: Renewable Energy Generation. The proposed approach is not acceptable since the lake source cooling does not qualify as a geothermal energy source using deep water or steam sources. Furthermore, the resource would be depleted and would have a negative environmental impact if the cooling capacity were increased exponentially (i.e. the resource provides increasingly less environmental benefit for other/subsequent projects beyond this one); therefore it is not considered on-site renewable energy.

It is noted that the proposed approach is an extremely efficient form of cooling, and while no credit is allowed as an on-site renewable source, significant credit would be achieved for EA Credit 1: Optimize Energy Performance using the ASHRAE 90.1 Appendix G modeling processes.

Campus Applicable
Yes
Internationally Applicable:
Yes
1/7/2009
LEED Interpretation
Inquiry:

We are pursuing the Offsite Renewable Energy portion of this credit through the purchase of Green-e certified Renewable Energy Certificates (RECs). The intent of this credit is to "encourage and recognize increasing levels of on-site and off-site renewable energy in order to reduce environmental impacts associated with fossil fuel energy use." The USGBC\'s guidelines in LEED-EB are not in synch with policy standards from Center for Resource Solutions (CRS) for Green-e Energy, WRI\'s guidelines for addressing Scope 1, 2 and 3 emissions or general industry accepted best practices. The problem relates to USGBC in LEED-EB requiring the calculation of TOTAL LOAD from ALL ENERGY SOURCES(including natural gas, steam heat, propane, etc.) on the building energy use side to set the amount of offset; while Green-e Energy states that REC\'s cannot be used to offset anything other than direct electricity generation (scope 2 emissions). As stated on p. 15 of the Green-e Code of Conduct: B. Communicating the Emissions Avoidance Value of a Green-e Energy Certified Product Green-e Energy Certified renewable energy products must be denominated in megawatt-hours (MWh) or kilowatt-hours (kWh). Consistent with this policy, Participants can market their certified products as instruments to address the environmental impacts associated with the consumption of electricity. One aspect of these impacts is the indirect carbon dioxide emissions arising from the purchase of electricity generated through the combustion of fossil fuels, classified as "Scope 2" emissions by the World Resources Institute\'s Greenhouse Gas Protocol. The explicit marketing of Green-e Energy Certified renewable energy products as a means to reduce or offset emissions from anything other than the consumption of electricity purchased from the grid shall not be permitted. Additionally, every other LEED type (NC, CI, CS, etc.) only requires the project owner to offset some percentage of the building\'s electricity use. LEED EB 2.0 and LEED EB OM are the only versions that (mistakenly) include non-scope 2 emissions. We propose to earn EA Credit 2.1 by offsetting only our scope 2 (electricity) emissions, in the percentages outlined in the credit. This will provide consistency with other LEED types and, most importantly, align with Green-e and WRI guidance on the issue. Further, it would seem that fewer LEED EB projects are choosing to use green power than LEED NC, CI, or CS projects, due in large part to the higher costs associated with offsetting scope 1 and 3 emissions in addition to scope 2. Allowing projects to earn this credit by offsetting only scope 2 (electricity) emissions should actually increase the number of participating projects, thus encouraging increasing levels of off-site renewable energy (aligning with the intent of this credit).

Ruling:

The proposal to offset only electricity emissions in the percentages outlined in the credit would not be acceptable to earn EA Credit 2. In order for a building to be considered climate neutral, all fuel consumption by building uses must be addressed including direct fossil fuel use. Secondly, in addition to climate neutral considerations, the decision to include total load from all energy sources as a basis for LEED-EB v2.0 EAc2 offset level requirements was made during the lengthy LEED-EB pilot program process to help address thermal energy sources and provide a better fit with the U.S. EPA\'s ENERGY STAR Portfolio Tool utilized for LEED-EB EAp2 and EAc1. In regards to offsets, with the release of programs like Green-e climate to complement Green-e energy, the USGBC agrees that Green power or REC purchases or the equivalent should only be used to offset electricity use, Scope 2 emissions. Scope 1 & 3 emissions from natural gas, purchased steam, fuel oil, or propane use should use carbon offsets, verified through a program like Green-e climate or equivalent. Concerns raised above regarding the encouragement of greater participation rates for this credit are always addressed as part of new EB rating system versions and could be accomplished by making adjustments to the required minimum threshold levels as readily as through significant changes to the credit requirements. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
11/6/2006
LEED Interpretation
Inquiry:

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.

Ruling:

[Updated 12/21/2006] The applicant is requesting qualification of a Low Impact Hydropower Institute (LIHI) certified power for EAc6, Green Power. Renewable energy power sources are defined by the Center for Resource Solutions Green-e program. The proposed combination will be categorized as a Competitive Electricity and Utility Green Pricing Product. To demonstrate compliance with credit requirements any power supplied should demonstrate equivalence with the section IV of the Green-e Renewable Electricity Certification Program National Standard Version 1.3, as well as with all the requirements of CIR ruling dated 11/4/2002.

Campus Applicable
No
Internationally Applicable:
No
11/4/2002
LEED Interpretation
Inquiry:

ENERGY & ATMOSPHERE: Green Power (EA Credit 6.0) Credit Interpretation Request Washington State does not require electric utilities to provide retail open-access. The Seattle Justice is required to purchase electrical power from the local municipal utility, Seattle City Light. Seattle City Light (SCL) wants to prove a LEED electrical energy product that qualifies for the EA Credit 6.0 to any LEED project within SCL\'s service area and proposes the following approach: Seattle City Light estimates that the current resource mix includes 25-28% renewable generation as defined by Green-e, composed of low impact hydro and possibly wind and other renewables. The utility will certify the low impact hydro component, estimated at 25% of the total mix, through the Low Impact Hydropower Institute. SCL will assist projects to "green up" the remaining 25% balance in order to achieve 50% renewable energy content by facilitating the purchase of Green Tags for participating LEED projects. Projects may elect to purchase green tags from existing or new renewable resources from SCL, the Bonneville Power Administration or other providers of green tags. As a part of the Credit documentation, the Seattle Justice Center will write a letter attesting that the mix or renewables serving the LEED project meets the following criteria: 1. SCL supplied renewable power plus Green Tags are equal to 50% of the project\'s energy consumption. 2. The energy and green tag sources meet the Green-e definition of renewable energy, which includes wind, solar, low impact hydro, methane recovery, etc., and, 3. Green Tags purchased have not been double sold, as verified by contract or purchase agreement.

Ruling:

Per LEED Interpretation 0214-EAc60-122101, if Green-e rated power is not available in the project\'s region, other sources of green power may be eligible for consideration. The alternative source must satisfy the criteria of the Green-e program, which is detailed on page 163 of the LEED Reference Guide (formatted version of June 2001). Of the five listed criteria, one is based on renewable content of 50% of more. The alternative energy source must also meet the other four criteria. If the SCL product contains 25% low impact hydropower, certifies its low impact hydro power through the Low Impact Hydropower Institute, as required in the Green-e program, AND meets the other Green-e criteria, SCL energy could be considered \'equivalent\' to half of the green power benefit associated with Green-e products. The rest of the green power benefit would need to be purchased in the form of Green Tags for half of the building load. In summary, in order to achieve a Green Power credit for SCL product the following is required: 1. SCL must certify its low impact hydropower with the Low Impact Hydropower Institute. 2. SCL must write a letter stating what percentage of its product is comprised of renewable energy (including certified low impact hydropower). 3. SCL product must also confirm that the remaining green-e criteria are met (addressing emissions, \'new renewable\' power and nuclear power) and state this in their letter. 4. The project must purchase Green Tags to meet the difference between SCL\'s product renewable % and green-e renewable content of 50%. (i.e.. if SCL contains 25% renewable content, this meets half the requirement and Green Tags would be required for the equivalent of half the building load over two years to meet the other half of the requirement.) Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/9/2011
LEED Interpretation
Inquiry:

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?

Ruling:

The proposed methodology is acceptable as long as the documentation is provided verifying what percentage of the solar farm is supporting each building and as long as the projected project cost for each project is consistent with the percentage of the solar farm that would need to be installed to support that building. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
3/28/2007
LEED Interpretation
Inquiry:

What is required in order to document equivalence with Green-e certified power

Ruling:

Using a formal third-party verification program is not required, but projects are required to document to USGBC that their renewable supplier has 1) met the Green-e criteria, and 2) properly accounted for the eligible renewable resources sold. This documentation to USGBC must include some type of meaningful verification work performed by a qualified, disinterested third party. Example documentation methods to USGBC that meet this requirement include: a) providing a state-mandated power disclosure label from the renewable supplier in states with meaningful regulatory requirements for renewable energy disclosure and accounting practices, as well as meaningful penalties for violations; b) providing a green power scorecard or rating from a credible, independent entity that performs meaningful verification of green power characteristics and accounting practices. In either case projects must confirm that the third-party entity\'s regulatory or verification programs are meaningful, summarizing those programs to USGBC as part of their certification application and highlighting any auditing or other independent checks the program performs. Other documentation methods will be considered on a case-by-case basis. This ruling applies to all the LEED Rating Systems having a similar "green power" credit. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/5/2003
LEED Interpretation
Inquiry:

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.

Ruling:

The proposed power resale marketing strategy appears to meet the intent of encouraging the use of grid-source renewable energy, but the description of how this strategy encourages the development of new renewable energy sources is unclear. A project submitting for this credit would need to clearly document that the power purchased under this arrangement meets or exceeds the Green-e Certification requirements. Provision of a "renewable electricity contract for power generated from renewable sources" is acceptable provided the contract represents purchase of at least 2 years worth of renewable electricity for 50% for the building's energy load. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/9/2011
LEED Interpretation
Inquiry:

For a project that is obtaining its energy from a small hydro-electric plant, the energy from which is classified as renewable by the local government, is the use of renewable energy from small hydroelectric plant an acceptable approach to obtain the possible points of the EA Credit 4: On-site and Off-site Renewable Energy?

Ruling:

In order to claim energy from small-scale offsite hydroelectric plants as renewable, the project team must demonstrate equivalency to (or actual) Green-E certification of the energy. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
7/19/2007
LEED Interpretation
Inquiry:

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.

Ruling:

A previous ruling (EAc2.1 CIR Ruling 10-03-2006), defined conditions that must be met for projects to qualify for renewable energy credits under EAc2. This ruling updates the previous ruling defining alternative conditions for projects to qualify for EAc2 renewable energy credits. A project will be eligible to achieve points under EAc2 and qualify for renewable energy credits for the system under EAc1 if the project meets the following conditions: 1 The renewable energy system is installed within the boundaries of the project or on the project site. 2 The renewable energy system is connected immediately adjacent to the utility meter. 3 A 10-year (minimum) contract for on-site generation with the owner of the Energy System is established. 4 The RECs associated with the renewable energy system are not sold. 5 The Energy System owner does not count the RECs associated with the renewable energy system to meet a mandated renewable portfolio standard goal or provides the RECs to the project owner. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
11/1/2011
LEED Interpretation
Inquiry:

The LEED EB:O&M Reference Guide does not specify precisely when during the LEED application review process Renewable Energy Credits (RECs) must be purchased, it only requires that the RECs meet specific percentages of the building\'s total energy use from the performance period.Our project team would like to wait until after the final review to file an appeal in order to purchase RECs and have EAc4 points included in the project\'s total before accepting certification.Can EAc4 thresholds be met by RECs purchased after the final review when filed through the appeal process?

Ruling:

A project team may elect to add and pursue EA c4 as part of an appeal after the project building\'s performance period has ended and after the Final Review has been completed and purchase RECs at that time, as long as the RECs purchased are based on the total annual site energy usage value reported for EAp2 and are allocated to the project building only. Note that at the time of appeal submittal, the project must have entered into a contract or commitment for future purchases to meet the 2-year requirement. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
10/1/2014
LEED Interpretation
Inquiry:

The project has a contract in place for carbon offsets as related to credit EAc4 On-site and Off-site Renewable Energy. The project team would like to show these carbon offsets are the equivalent as being verified by Green-e Climate. The Climate Action Reserve has verified the carbon offsets. These offsets are high quality and the Climate Action Reserve is usually referred to as the best offset protocol. Since CAR has been endorsed by Green-e, is retirementment of the offsets in the name of the project sufficient to demonstrate equivalency?

Ruling:

It appears that the process of retiring the carbon offsets in the name of the project may be one means of confirming that emissions reductions come from verified and certified supply, and from projects validated and registered under high-quality project standards. Alternative means of demonstrating equivalency would also include documentation of an annual 3rd party audit performed for the provider's sales of carbon offsets that demonstrates all five criteria below.
When using retirement of carbon offsets to demonstrate equivalency, submit a narrative describing how the offsets comply with the following five criteria:
- A verifiable chain of custody
- A verifiable age of renewable energy
- Tracking of GHG reductions from eligible sources
- A mechanism to prevent double counting
- Third-party verified retail transactions.
The contract provided must include language confirming all five criteria have been implemented by the retailer. Proof of certification by a Green-e Endorsed Program (such as The Climate Action Reserve) satisfies the first three criteria have been met.
In addition, provide documentation that the offsets have been retired in the project's name (screen captures, PDFs of database pages, etc.). For example, the "Retirement Reason Details" in the registry for The Climate Action Reserve could include either the LEED Project ID or the registered project name.

Campus Applicable
No
Internationally Applicable:
Yes
8/26/2008
LEED Interpretation
Inquiry:

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.

Ruling:

The project team is requesting clarification on whether or not EAc2 can be pursued for new campus projects when a solar PV array previously exists. Under the LEED Application Guide for Multiple Buildings and On-Campus Building Projects (https://www.usgbc.org/ShowFile.aspx?DocumentID=1097) it states: In the case where the renewable energy equipment is not physically located on the applicant building(s), provide data for each building showing the projected energy consumption and the percentage to be met with their prorated or dedicated share of renewable energy. The owner should also submit a certification letter acknowledging that the renewable energy from a central system will apply only to the submitted project(s) and will not be applied to subsequent buildings for any future LEED certifications. Thus, both projects can pursue EAc2, provided a previously undedicated share of renewable energy generated is allocated to each building project. Update April 15, 2011: Please note that all 2009 projects in multiple building situations must follow the 2010 Application Guide for Multiple Buildings and On-Campus Building Projects, located here: https://www.usgbc.org/ShowFile.aspx?DocumentID=7987. 2009 project teams should check this document for up to date guidance on all multiple building issues. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
1/1/2013
LEED Interpretation
Inquiry:

In preparation for LEED certification over a year of energy monitoring has been conducted to establish energy usage and achieve EnergyStar certification. The owner is considering installing a PV system that will generate over 12% of its energy use (comprehensive evaluation of gas + electric). However, O&M states that the system must offset power during the performance period. Can EAc4 points be achieved based on system specifications that utilize performance period data for sizing rather than actual solar system performance monitoring?

Ruling:

Points for EAc4 cannot be achieved based on system specifications that utilize performance period data for sizing in lieu of actual solar system performance monitoring during the performance period. Unlike the LEED Rating Systems for New Construction, Core & Shell and Schools, the LEED 2009 Rating System for Existing Buildings: Operations and Maintenance is a whole building rating system designed to certify the sustainability of the ongoing daily operations of existing commercial and institutional buildings. As such, EB O&M is comprised of a planning, implementation and performance period measurements for each of the prerequisites and credits. EAc4: On-site and Off-site Renewable Energy, as its name implies, has two pathways to obtain up to six points. During the performance period some or all of the buildings energy may be met with On-site and Off-site Renewable Energy. If the solar PV system is not installed and operating during a portion of the performance period to confirm performance, the project team may consider the purchase of renewable energy certificates (RECs) to demonstrate credit compliance. In lieu of the commitment to purchase RECs on a continuing basis, a commitment to provide a percentage of the buildings total energy consumption generated on-site at the conclusion of the RECs purchase may be considered. That would allow additional time to complete the design and installation of the solar PV array. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
8/21/2009
LEED Interpretation
Inquiry:

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.

Ruling:

The applicant is asking for clarification on the quantity and length of time for which RECs need to be purchased in order to achieve credit for On-Site Renewable energy that is sold to the grid. Most of the various CIRs referenced by the applicant are relevant; some of these rulings appear to add confusion to the quantity of RECs that are needed. It has been determined that the project can achieve EAc2 by purchasing a total amount of RECs equal to 100% of the system\'s annual rated energy output. There must be at least a 10-year contract for the purchase of the energy output. This CIR supersedes the 200% requirement set by the CIR Ruling dated 5/16/2006. Please note this CIR only dictates the quantity of RECs and the duration and other requirements related to documentation and green-e stay valid as stated in the 5/16/2006 and other CIRs.

Campus Applicable
No
Internationally Applicable:
No
5/9/2011
LEED Interpretation
Inquiry:

Is it acceptable to use a mix of 10% biofuel and 90% natural gas to meet the requirements of EAc2, and is there a minimum time period for which the biofuel must be purchased from the utility company?

Ruling:

For biofuels to qualify, the bio-gas system must meet the requirements as per table 3 of EAc2 as per the LEED-NC v2.2 Reference Guide and a signed declaration from the provider that clearly shows the source must be provided. The intent is for a portion of the building\'s energy to come from biofuel for the duration of its existence. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
3/28/2007
LEED Interpretation
Inquiry:

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?

Ruling:

Using a formal third-party verification program is not required, but projects are required to document to USGBC that their renewable supplier has 1) met the Green-e criteria, and 2) properly accounted for the eligible renewable resources sold. This documentation to USGBC must include some type of meaningful verification work performed by a qualified, disinterested third party. Example documentation methods to USGBC that meet this requirement include: a) providing a state-mandated power disclosure label from the renewable supplier in states with meaningful regulatory requirements for renewable energy disclosure and accounting practices, as well as meaningful penalties for violations; b) providing a green power scorecard or rating from a credible, independent entity that performs meaningful verification of green power characteristics and accounting practices. In either case projects must confirm that the third-party entity\'s regulatory or verification programs are meaningful, summarizing those programs to USGBC as part of their certification application and highlighting any auditing or other independent checks the program performs. Other documentation methods will be considered on a case-by-case basis. This ruling applies to all the LEED Rating Systems having a similar "green power" credit. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
2/9/2009
LEED Interpretation
Inquiry:

Question: Are perforated metal wall solar air heating systems eligible for credit under LEED CS EAc2?" Background: The intent of the credit is to "encourage and recognize increasing levels of on-site renewable energy self-supply in order to reduce environmental and economic impacts associated with fossil fuel energy use." "Renewable Energy Systems Eligible for EA Credit 2", "Solar Thermal Systems" (p. 224) states "Active solar thermal energy systems that employ collection panels; heat transfer mechanical components such as pumps or fans, and a defined heat storage system, such as a hot water tank are eligible for this credit." "Systems Not Eligible for EA Credit 2" (p. 224) states excludes "architectural passive solar and daylighting strategies provide savings that are chiefly efficiency related". Perforated metal wall solar air heating systems include a collector panel (the wall) and a heat transfer mechanical component (fan or fans) but typically do not include a defined thermal storage component. Natural Resources Canada considers these to be active systems ("Total energy savings result from four different mechanisms: [including] active solar heating of ventilation air" http://www.canren.gc.ca/renew_ene/index.asp?CaID=50&PgID=347)

Ruling:

The perforated metal wall solar air heating system described is considered an active system and therefore can contribute toward EA Credit 2. The applicant should note that there are no previously approved calculators for the amount of energy offset by such a system and therefore, the applicant must provide detailed calculations, including all assumptions and applicable weather data, during the review process. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/9/2011
LEED Interpretation
Inquiry:

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

Ruling:

Ecoenergy-labeled electricity products can qualify for EAc4 provided that equivalency with Green-e certification is demonstrated by the project team. The Green-e standard is located on their website: http://wee.green-e.org

Campus Applicable
No
Internationally Applicable:
No
6/15/2007
LEED Interpretation
Inquiry:

Our project is a 238,000 SF brick manufacturing facility in Terre Haute, Indiana. The project consists of 5,000 SF of office space and 233,000 SF of manufacturing area, including extrusion, drying, and kiln equipment. The energy required for the manufacturing process exceeds 90% of the facility\'s total energy load. We are submitting a separate CIR to address quantifying energy savings for the manufacturing process. In the brick industry, the typical manufacturing process (specifically the kiln) utilizes natural gas as a primary energy source. To maximize energy savings and reduce the environmental and economic impact of brick-making, our Client has selected a site that is directly adjacent to a municipal landfill, with plans to fuel the kiln with methane off-gassing from the landfill. Currently, the methane is collected, burned, and flared directly into the atmosphere; however, it can be contained, cleaned and pressurized so that it may be used constructively in lieu of natural gas. Our Client has obtained permission from the landfill to tap into this energy source. As part of our project scope, we will install compressors and an underground pipeline to transport the landfill gas to the manufacturing facility. This will replace the majority of natural gas that powers the kiln and vastly reduce the amount of on-grid energy required by the facility. Our Client will install and maintain all equipment required to prepare, transport, and apply this methane to the manufacturing process. Other than allowing us to tap into this un-used resource, the operator of the landfill will have no involvement or responsibility in this venture. Please verify that landfill off-gassing qualifies for credit under EA credit 2 in this case, even though the landfill itself is not owned by our client or located within our project site. We will calculate renewable energy as a percentage of the total building annual energy cost, including process energy.

Ruling:

Yes, the system described meets the requirements needed to achieve credit under EAc2, despite the fact that the source of the energy (here, the landfill gas) is not directly on site. Because the project owner will install and maintain the equipment for the land fill gas extraction, and be the sole user of the gas, the renewable energy system falls under the LEED scope of the project and can effectively be considered "on-site." However, in order for this project to achieve LEED-NC v2.2 EAc2 credits, the following conditions need to be met: 1) Because the landfill gas will be used to in lieu of natural gas in a manufacturing process, the full process loads must be included in all energy cost and use estimates, whether or not the project is attempting to earn any credits under EAc1 (it is not clear from the CIR if full energy modeling will be performed for this credit). As per LEED-NC v2.2 EAc1 CIR ruling dated 5/13/2007, a full description will need to be provided of how the baseline and proposed energy usage were estimated for the project, as industrial energy usage does not fall under the purview of ASHRAE 90.1-2004. Because of the nature of this project, the EAc2 compliance path using CBECS data to estimate annual energy costs is not appropriate. 2) As per the LEED-NC v2.2 EAc2 Reference Guide language, the method used to predict the quantity of energy generated by on-site renewable systems should be clearly stated in the LEED submittal narrative... Cost savings from renewable energy systems\' shall be reported exclusive of energy costs associated with system operation (i.e., deduct energy costs of pumps, fans, and other auxiliary devices). 3) Because the landfill is on municipal property, but the gas extraction system will be privately owned by the project owner, a clear chain of custody for rights to the gas and the associated Renewable Energy Credits (RECs) needs to be documented. Based on the documentation requirements outlined in the LEED-NC v2.1 EAc2.1CIR ruling dated 10/3/2006 (which specifically addressed third party ownership of a renewable energy system) the following requirements need to be met: A. There is a minimum 10-year contract with the local municipality to secure the rights to the landfill gas that will be used in the project. B. There must be clear documentation for accounting purposes whether the purchase includes the RECs or just the landfill gas. C. If the purchase does not include the RECs, the building owner or energy system owner must make the 200% offset REC purchase described in the first portion of the CIR for at least 10 years. Applicable Internationally.

Campus Applicable
No
Internationally Applicable:
Yes
5/9/2011
LEED Interpretation
Inquiry:

Can a waste-to-energy generation facility qualify for EAc2?

Ruling:

Combustion of municipal solid waste is excluded from eligibility of this credit. Applicable internationally.

Campus Applicable
No
Internationally Applicable:
Yes
7/1/2014
LEED Interpretation
Inquiry:

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)?

Ruling:

Directed Biogas purchase is not considered on-site renewable energy based on the current EAc2 credit requirements, addenda and LEED Interpretations, because the gas consumed on-site is not the same as the biogas that the project purchased. Please note that the referenced Addendum 100001081 does not allow for the fuel used on site to be different than the fuel that was purchased for the project. The referenced addendum applies for situations such as landfill gas piped directly to the project from a nearby landfill, or wood pellets from wood mill residue that are trucked to the project. In either case, it would not be acceptable for the landfill gas or pellets generated from wood mill residue to be "purchased" by the project, used in another project, and replaced in the project with natural gas or wood pellets produced from tree tops. Also, note that NREL refers to directed biogas as off-site renewable energy.

Campus Applicable
Yes
Internationally Applicable:
Yes
10/3/2008
LEED Interpretation
Inquiry:

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?

Ruling:

The project team is asking if its renewable energy certified by Ecologo will comply with the credit requirements for its project located in Canada. If the renewable energy is not Green-e certified, then the project team must prove equivalency to the Green-e technical requirements or pursue certification through LEED Canada. Applicable Internationally; Canada.

Campus Applicable
No
Internationally Applicable:
Yes

LEEDuser expert

Ben Stanley

WSP - Built Ecology
Senior Sustainability Manager

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