Forum discussion

Tier 2 Renewable Energy & "Double Counting"

Some of you are aware of my ongoing saga of off-site renewable energy and a LEED certification we are pursuing. The short version is that there is a new-construction corporate headquarters office building (Building #2 on the attached graphic). This building is pursuing LEED certification. 

The company also just installed a 1 MW photovoltaic array at their manufacturing facility, offsite. I have all the calculations if anyone wants to get into the details, but this is enough to earn all 5 Renewable Energy points under Tier 2 for LEED BD+C v4.1

Problem is... I can't get my client's internal subject matter expert to agree with me that: despite the fact that they use all the electricity they generate at the Building #1 (manufacturing facility) meter, since the company in question owns all of the assets here they can choose to retire the environmental attributes of that power to either Building #1 (Option 1) or Building #2 (Option 2). 

I've spoken with EA TAG members (Alex Pennock, Bob Maddox, Jamy Bacchus) on this too, who confirmed I'm not crazy in my logic, and offered to have a call. That was in April, and I've gone back and forth on this with my client contact several times since then. (The most fun phase of a project where construction is complete but final LEED certificaiton isn't.)

And I just got the following reply, from my contact, via their 'SME':

With that said, regarding the Renewable Energy points, the concern is if [CEO] gets ask from a investor about our renewable energy at [Building #1]. From a subject matter expert standpoint, we already use 100% of the electricity from the solar field at the [Building #1] site and that is reflected in our external reporting. To assign a measurable benefit to any other site would fit the textbook definition of “double counting”. Double counting is considered questionable and could be easily discerned by external parties thus exposing [company] to risk.

Apparently I am not a Subject Matter Expert on this... unfortunately I think the internal SME thinks I'm biased to the point that my integrity is compromised because these points are the difference between Silver and Gold certification. 

But I feel that it's in the client's best interest to have BOTH a LEED Gold headquarters and a 1MW solar asset. AND that they're not wrong in the slightest to do so, as long as they don't assign the environmental attributes of that energy to both buildings. 

Anyway, does someone have a client who has achieved this LEED credit, with off-site Tier 2 renewable energy? Preferabily a Fortune 500 level company? In addition to the call with the EA TAG members, which I'm going to schedule, I'd love to have this client's 'SME' hear from a peer at a company instead of a consultant. 

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Thu, 09/22/2022 - 16:44

Sarah, I wasnt sure if you got any responses for this. I have two suggestions and you may have already considered this. I agree with your approach to get on a TAG call but something written is always good. Therefore here is my  2 cents. 1. Search for a LEED interpretation or submit a LEED Interpretation that will allow USGBC to weigh in and provide a response on this issue. If you have already consulted USGBC, then their response is likely to be inline with your thinking. This will provide you  leverage with your client. It is then, no longer "just" your professional advice. You are now backed with a formal response from USGBC that applies not just to your project but to all other projects. 2. The other way to approach this is for your client or building owner to set up a contract even though it is internal to the company that explicitely states the contractual terms/ number of years and how they are retiring their environmental benefits, renewable energy generated and the actual energy consumption. This is additional work for your client but this will ensure that they dont inadvertently double dip in any way or form. This is a formality that will ease their concerns, in my opinion. Hope you are able to resolve this soon!    

Thu, 09/22/2022 - 17:32

I agree with what Ramya suggested. Just to recap, the basic challenge here is that ‘energy’ and ‘environmental attributes’ are often sold separately. When I put solar on my house I inadvertently sold the RECs to the utility…I was paid well for the trade but wasn’t really aware that’s what I was selling. So I received the energy generated and hardly paid an electricity bill most months, but didn’t own the environmental attributes of the energy. It’s common, but it appears your client doesn’t think it’s a very credible approach since they have already made claims about Building 1. It’s incorrect to say that building 1 uses 100% renewable energy but also that building 2 uses the same renewable energy. I’m actually not sure what the correct claim is in this case, and perhaps that is the hang-up. There are numerous fortune 500 companies that buy off-site renewable energy, retaining the RECs and some ownership/lessorship over the solar asset and then assign the energy/RECs to buildings. -Kjell From: Ramya Shivkumar

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