We are considering submitting an innovation credit for shifting over 40% of our peak cooling load to off-peak generation through the utilization of a Thermal Energy Storage (TES) system. We are seeking clarification about USGBC\'s interpretation of the benefits of shifting peak demand via TES systems and the potential documentation needs for such a credit. One CIR (IDc1 - 2/19/01) recognizes one of the major known benefits of thermal energy storage - reduced need for additional power infrastructure [by shifting peak demand]. A second CIR (EAc1.1 - 06/27/2001) states that TES systems would be beneficial in a T&D Capacity Emergency, but does appear to exclude other TES systems from earning an innovation point. The third CIR (EAc1.1 - 02/04/2004) states that \'any attempt to demonstrate the environmental benefits must be comprehensive and quantifiable.\' It is not clear to us whether or not shifting peak demand would need to be located in a T and D Capacity emergency to qualify for an Innovation point. It seems to us that reduced need for infrastructure would be beneficial to all power districts, not just those in a T and D Capacity Emergency. In addition, source energy savings associated with shifting peak demand do not seem to be addressed in previous CIR\'s. It is our understanding that substantial source energy savings are realized with off-peak power production. A study by the California Energy Commission found that source energy savings for nighttime power generation ranged from 8% to 43%. This means that substantially less coal and other source energy is needed to create the same amount of electricity in the night than in the day. The source energy savings result in comparable reductions in emissions of pollutants such as CO2 and NOx. Our question is, "do the energy and environmental benefits of shifting peak demand through utilization of a TES system merit consideration for an innovation point and, if so, what would be acceptable documentation for achieving such a credit?" For more information on the environmental benefits of shifting peak demand and of TES systems, the California Energy Commission\'s Source Energy and Environmental Impacts of Thermal Energy Storage dated February, 1996 thoroughly explains source energy, emissions and infrastructure savings associated with shifting peak demand. We believe that this study reveals universal issues related to peak vs. off-peak generation. The complete document can be accessed on CEC\'s web site at http://www.energy.ca.gov/reports/500-95-005_TES-REPORT.PDF .
The project is inquiring whether an innovation credit can be earned for load shifting of peak energy loads to off-peak generation through thermal energy storage (TES). This has been established as an acceptable strategy (e.g. CIR 2/19/01). Verify that the shifted load accounts for at least 5% of total building energy use and prove that the type of installed TES technology causes less air emissions as compared to the system without TES. In addition, considering that the TES systems contribute to LEED-NC EAc1 points, the project team must demonstrate an additional environmental benefit beyond that which is recognized under EAc1 (based on energy cost). To do that, quantify the reduction of air emissions from your system and quote relevant results of the cited study. Applicable internationally.