Question on LEED v4 NC, OEP 2024 Update – eligibility of off-site solar PPA without EACs for Table 2, GHG, points

Hello all,

I am working as the LEED AP BD+C for the “Hotel” project, which will pursue LEED v4 BD+C: Hospitality and we plan to comply with the Optimize Energy Performance (OEP) – 2024 Energy Update requirements. We would like to confirm whether our proposed renewable electricity procurement structure can be counted toward Table 2 (GHG emissions) – GHG reduction points under the 2024 Update.

Project / procurement scenario (off-site solar)

• The hotel will procure renewable electricity from a solar power plant located in Türkiye.
• The solar plant holds a local generation license issued by the Turkish energy regulator (EPDK).
• The hotel will sign a direct renewable electricity purchase agreement (PPA) with the solar plant (the plant is affiliated/under the same parent group as the hotel, so the owner is the same person).
• Physical delivery: The solar plant will export electricity to the national grid, and the hotel will consume electricity from the grid at the project site (i.e., no private wire).
• Payment: The hotel will pay the solar plant under the PPA. The grid supply remains through the utility.
• Important limitation: The solar plant currently has no Green-e certification or equivalent third-party green power certification, and no Energy Attribute Certificates (EACs) are being issued/retired under the proposed structure (e.g., no I-REC / GO / YEK-G / REC mechanism in place at this time).

Our questions for LEED v4 NC OEP (2024 Update) – Table 2 (GHG)

1. Without EACs (no REC/GO/I-REC/YEK-G, etc.), can the above off-site solar PPA be counted as “renewable electricity” for the purpose of Table 2 (GHG emissions) GHG reduction points in the 2024 OEP update?
2. If the answer is “no,” would it become eligible if:
   • the PPA contract explicitly assigns all environmental attributes to the hotel and prohibits double counting, but still no formal EAC system (no certificate issuance/retirement) is used?
3. If the solar plant’s entire generation output is contractually dedicated to the hotel (100% of generation sold to the hotel under the PPA), does that change the requirement for EAC issuance/retirement for LEED compliance, given that the hotel will still consume from the grid?

Thank you in advance for your support.