Our project is a new 135,000 sf office and classroom building on the University of Iowa campus. The building is served by the University\'s combined heat and power plant. (UI-CHP) The project requires that we follow the LEED NC 2.2 CHP methodology Case 3. The CHP methodology document requires certain qualifications for the combined heat and power plants. Specifically, Qualification 2 requests a narrative addressing emissions and demonstrating that the environmental impact of the system is lower than if the building heating requirements are met with an 80% efficient gas boiler and cooling requirements are met with baseline cooling systems using electricity provided from the local grid. In this case, the University of Iowa measures the emissions and is required to file an annual emissions report every year with the Iowa DNR. This report details emissions for SOx, NOx, CO2, and particulates. These same emissions are available from the local utility that would otherwise provide power to the building. On-site gas firing emission data from The Climate Registry General Reporting Protocol Version 1.1. We propose to use the report required by the Iowa DNR that documents the emissions from the University plant as well as the emissions data provided by the Utility to evaluate the project with respect to LEED NC 2.2 CHP methodology Case 3, Qualification 2. UI-CHP emissions for the building will be calculated as: Cooling energy use BTUs from Proposed Model x UI-CHP emissions per BTU + Heating energy use BTUs from Proposed Model x UI-CHP emissions per BTU Utility and on-site heating and cooling related emissions will be calculated as: Cooling energy use BTUs from Proposed Model with baseline cooling system x Utility emissions per BTU of electricity at site + Heating energy use BTUs from Proposed Model with 80% efficient gas boilers x Emissions per BTU of gas firing We will compare the UI-CHP emissions with the Utility and on-site heating and cooling related emissions for each metric (SOx, NOx, CO2 and particulates) to determine that UI-CHP has a lower environmental impact. Is this approach acceptable?
The applicant wants verification for the process of calculating GHG Emissions. The process is based on mandatory reporting required by the Iowa DNR and therefore is acceptable. The applicant must provide the referenced emissions reports as part of the submittal. Please include a brief narrative to explain the process and cross reference this CIR ruling.