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

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.

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)?

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.

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).

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?

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

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.

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?

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.

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?

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?