On-site combustion of natural gas releases climate-changing greenhouse gases (GHG) into the atmosphere, and Energy and Atmosphere Credit 6 (Green Power) only addresses electric power sources, not on-site natural gas use. GHG emissions are the largest environmental impact associated with burning fossil fuels, and purchasing high-quality greenhouse gas emissions offsets will significantly and quantifiably reduce greenhouse gas emissions beyond purchase of renewable power, further reducing the climate impact of a building\'s energy use. Therefore we propose an Innovation in Design Credit for balancing out the greenhouse gas impacts of a building\'s natural gas use as follows: Intent: Reduce climate impacts associated with a building\'s fossil fuel energy use. Requirement: Participate in a program with rigorous standards that balances out 100% of the climate impact of the building\'s actual natural gas use by purchasing an equivalent number of high-quality greenhouse gas emission reductions for a period of two years. Submittals: Provide a copy of the energy bill verifying enrollment in the program; provide a letter from the owner committing to participation in the program for a period of at least two years. Design Approach: Participate in Pacific Gas and Electric Company (PG&E)\'s ClimateSmartT program (http://www.pge.com/climatesmart), through which we achieve a greenhouse gas offset equal to 100% of the emissions from our building\'s natural gas use. 100% of our building\'s natural gas supply comes from PG&E, and the greenhouse gas emissions associated with our natural gas use are calculated based on the actual amount of natural gas our building uses each month, and the greenhouse gas intensity of PG&E\'s natural gas supply. The independently certified emission rate is 13.446 lbs carbon dioxide (CO2) per therm. We pay PG&E to purchase greenhouse gas emission reductions on our behalf from new projects (after December 14, 2006) that would not have otherwise occurred. The projects from which PG&E purchases reductions must demonstrate that they are real, additional, verifiable, and permanent, and the projects must not be counted towards any GHG emission reduction caps specified in any mandatory local, state, national or international GHG regulatory structure or cap-and-trade program, or in any voluntary cap-and-trade program. The projects are also independently verified, audited, and registered with the California Climate Action Registry ("Registry") and all emission reductions are permanently retired in the Registry\'s publicly accessible Climate Action Reserve tracking database. Projects must be based in California and meet the stringent requirements of one of the Registry\'s project protocols, which include capturing methane gas from dairy farms or landfills and conservation-based forest management. All projects that PG&E invests in absorb or reduce GHG emissions from the atmosphere; the amount of emission reductions purchased through the program on our behalf is equal to the actual amount of GHG emissions from our building\'s natural gas use. Purchasing a percentage of renewable energy under the Green Power credit lowers the climate impact of energy use only by the amount of green power purchased. This program goes further by offsetting 100% of the actual greenhouse gas emissions associated with our building\'s natural gas use, making our natural gas energy use "climate neutral."
Increasing the scope of greenhouse gas (GHG) offsets to include those emissions resulting from natural gas consumption is an acceptable innovation proposal. Consistent with CIR Ruling 9/20/02, projects that elect to offset GHG emissions associated with natural gas consumption must demonstrate that the total quantity of GHG emissions associated with natural gas offsets is greater than or equal to the total quantity of GHG emissions that could be offset through the purchase of green power for EAc6. For this particular project proposal, the ClimateSmarT program offered by the local utility is an acceptable provider of GHG offsets for natural gas based on the fact that the utility meets the following criteria: