This credit provides 3 options to achieve a total of 12 points for GHG emissions reduction:

1. Option 1 (reduction of Scope 1 emissions): 1-6 points.

Comment/suggestion: none.

2. Option 2 (reduction of Scope 2 emissions through procurement of on-site [Tier 1] and off-site [Tier 2 and Tier 3] renewable energy): 1-5 points

Comment/suggestion: no comment on criteria for Tier 1 renewable energy; criteria for Tier 2 renewable energy (new off-site renewable electricity procured through contracts or PPAs) should additionally include hourly-matching*; criteria for Tier 3 renewable energy (off-site renewable electricity procured through EACs) should additionally include hourly-matching and sourcing from the same regional T&D market. (*Hourly-matching requires an EAC to be time-stamped when 1 MWh of carbon-free energy is generated and applied against grid energy that is consumed within one hour of the time stamp.)

Studies have shown that monthly or annual matching of EACs against grid energy consumed results in inflated claims of emissions reduction. For instance, during peak hours the supply of renewable energy may not be sufficient to meet demand, requiring the grid operator to make up the difference through fossil-fuel generators, resulting in higher actual emissions than that claimed. This contradicts the stated intent of this Credit "To reduce environmental and economic harm associated with greenhouse gas emissions from building energy use that disproportionately impacts frontline communities."  In other words, if the intent of this Credit is to reduce the harm associated with actual GHG emissions, then matching the generation and consumption of renewable energy in time and space will more closely achieve that intent.

In conclusion, the suggested "time-and-space contraints" will more closely align Tier 2 and Tier 3 renewable energy procured off-site with the grid energy consumed on-site.

3. Option 3 (reduction of total GHG emissions relative similar buildings or historical baseline): 1-4 points

Comment/suggestion: clarify that the calculation of GHG emissions should comply with the "time-and-space contraints" as suggested under Option 2.