Wood pellets as a Renewable energy source

Wood pellets usually do not qualify as renewable.To qualify they would have to be made from untreated wood waste generated on-site. There are some exceptions to the on-site part in the LEED Interpretations.

With regards to the same project Eng. Vassilev is asking about, just to add that a tail end chimney filter (exact technology not yet determined, but likely to be electrostatic) is being considered to reduce particulate matter related to the combination of the biomass fueled boiler plant. And a slight correction should be mentioned that the pellets would actually be made from agricultural waste rather than wood, although I am not sure this would influence anything.

We looked at a few LEED Interpretations as you suggested:
ID# 6041 (Interpretation - 2003)- appears to set precedent that locally produced and sourced renewable energy sources (biofuel in this case) that are purchased as a commercial product may be used to count toward credit compliance.
ID# 2591 (Interpretation, 2009) - appears to set the contrary precedent that the source of the material (wood in this case) must be from the site itself or a contiguous property with the same owner.
ID# 100001081 (Addenda, 2011) - appears to clarify this discrepancy by clearly stating credit may be awarded, "if the fuel source is not owned, and in cases where use of a substitute, non-renewable fuel is possible, projects must enter into a 2-year contract for purchase of the renewable fuel source, with an ongoing commitment to renew for a period of 10 years total."

As such, it would follow that purchasing pellets produced from agricultural waste that is off-site would contribute to credit compliance provided the proper contractual documents are in place. Could you confirm this Marcus?

Last question slightly related to EAp2: if we proceed with the boiler plant that uses pellets produced from agricultural waste, it is clear we would use the contracted value of the pellets as the cost in the design model, but what cost would we use in the base case, as LEED Interpretation ID#5332 states fuel switching is not allowed by ASHRAE 90.1 and diesel would be the other option? Does this mean no cost savings could be realized?

Agricultural waste makes a big difference as that tends to be a qualifying renewable. Based on ID#100001081 if you can meet that criteria it sounds like it may qualify relative to fuel source and purchase term. The other issue that comes up in these situation is distance from the site, since the credit is for On-Site renewables. LI #1789 and #5332 deal with this issue for wood and landfill gas. I have not seem anything that deals with this issue relative to agricultural waste pellets. You might consider submitting a CIR to determine if you need to address that issue.

Regarding EAp2 - see the exception to G2.4. This language has always been confusing to me but here is what I take it to mean. You count the cost of the pellets in your proposed model but subtract it off as a renewable.The baseline would be your back up fuel source or electricity. This is counter to LI#5332 which I think is an incorrect interpretation of G2.4. This is demonstrated in 90.1-2013 which changed this language to be more clear. To be certain you can count it the way I think you should be able to I would suggest you submit a project team inquiry or CIR or LI to USGBC. Let us know the result if you do.

Great questions as you seem to have uncovered some grey areas!

You might want to contact your reviewer, client manager or LEED coach with the specifics. We had a project using an agriculture waste pellet burner get dinged by a reviewer citing LI 10300, which adds extensive requirements to a project and/or its power provider.

We're planning on countering with the fact that LI 10300 only calls out additional requirements for projects using the expanded material list and not the original accepted biofuel list (specified by ID# 100001081).

If anyone has any thoughts on this, I'd appreciate it. Otherwise I'll let you know how it turns out.

Thanks for sharing Daniel! LI 10300 does not deal with agricultural waste specifically, but rather expanding the definition of renewable energy sources in general, as you mention. It appears to focus primarily on wood, as the project seems to be specifically related to an urban vegetation maintenance programs and logging operations as the energy source, which have both several other CIR/LI. The ruling does have merit, but it appears to be a far stretch as being applicable to agricultural waste that has a two year contract with a commitment to renew for 10 years, as per ID#100001081. Did the project you mention submit documentation demonstrating this purchasing commitment? If not, I would strongly encourage you to add this to your response.

As your project sounds like it is specifically related to agricultural waste, these ideas and additional documentation may also be useful arguments, but your planned argument hits very close to the heart of the issue, so please do let us know how this turns out!