We have a project that is part of a campus and has a significant PV array that offsets about 35% of the building's energy costs. However, the generated electricity does not go directly to the building. Rather, the campus management has a sub group that holds the RECs. The intention here is to buy other RECs to replace the renewable energy produced by the on-site PV panel.

My question is, can I count the energy generated by the on-site panels towards EAp2 "Minimum Energy Performance" and EAc1 "Optimize Energy Performance"? If not, can the RECs purchased to replace that energy be counted towards these credits?

I found a CIR for EAc2 "On-Site Renewable Energy" explains that in a similar situation, it seems that we need to buy twice as much RECs in order to have the RECs count towards the project. In their explanation, LEED says this is due to the difference in costs/incentives of producing RECs across state borders (I don't really get it). A later CIR issued 8/21/2009 (http://www.usgbc.org/content/li-2594) backtracked and indicated buying RECs for 100% of the generated energy is enough. However, these CIRs aren't clear about using the energy for EAc1.