ID#2594 made on
EAc2 - On-site renewable energy
LEED BD+C: New Construction, LEED O+M: Existing Buildings, LEED ID+C: Commercial Interiors, LEED BD+C: Core and Shell, LEED BD+C: Schools
Our project is installing a photovoltaic system that will be directly connected to the building's energy system, and which will be net-metered with the utility grid. The system is being financed throu...
Our project is installing a photovoltaic system that will be directly connected to the building's energy system, and which will be net-metered with the utility grid. The system is being financed through a power purchase agreement, which requires selling of the RECs to the public utility. A number of Credit Interpretation Rulings have been issued regarding the conditions which must be met for a project to qualify for renewable energy credits under EAc2. These CIRs seem to provide conflicting language. We are seeking clarification regarding these conditions for LEED-NCv2.2 and LEED-CSv2.0 projects. - CIRs dated 10/3/2006 and 5/16/2006 state that the sale of RECs is allowed from an on-site renewable energy system that claims credit under EAc2 if the building owner or energy system owner purchases a total amount of RECs equal to 200% of the system's annual rated energy output each year from another source, which must be Green-e eligible. Per the CIRs, the seller of the on-site RECs must also follow all established guidelines for the sale of RECs and not claim any of the environmental attributes for the on-site system. - An administrative ruling dated 7/19/2007, which updates conditions for on-site renewable systems to achieve EAc2 points, does not make reference to the purchase of 200% RECs as an acceptable method of credit achievement. - However, the same 200% REC purchase compliance path is also outlined in the new LEED 2009 BD&C Reference Guide. - A CIR dated April 15, 2009 rules that a project that hosts a PV system, which does not use the PV and/or the PV is fully financed, owned and sold to third parties, can achieve EAc2 by purchasing a total amount of RECs equal to 100% of the system's annual rated energy output. Please confirm that a project pursuing EAc2 under LEED-NC v2.2 (or LEED-CSv2.0) can achieve EAc2 points by utilizing the 200% REC purchase methodology as outlined in the 2006 CIRs and 2009 BD&C Reference Guide, or the 100% REC purchase methodology outlined in the 2009 CIR. We are also seeking clarification regarding the length of time for which RECs must be purchased. The 5/16/2006 CIR states that RECs must be purchased "each year." Does this mean that RECs must be purchased each year that the system's RECs are sold, indefinitely? Alternatively, the 10/3/2006 CIR states that RECs must be purchased for at least ten years. Please clarify if the REC purchase is required for 10 years, or for the entire length of the utility REC purchase agreement.
The applicant is asking for clarification on the quantity and length of time for which RECs need to be purchased in order to achieve credit for On-Site Renewable energy that is sold to the grid. Most of the various CIRs referenced by the applicant are relevant; some of these rulings appear to add confusion to the quantity of RECs that are needed. It has been determined that the project can achieve EAc2 by purchasing a total amount of RECs equal to 100% of the system's annual rated energy output. There must be at least a 10-year contract for the purchase of the energy output. This CIR supersedes the 200% requirement set by the CIR Ruling dated 5/16/2006. Please note this CIR only dictates the quantity of RECs and the duration and other requirements related to documentation and green-e stay valid as stated in the 5/16/2006 and other CIRs.
Related Addenda (Corrections & Interpretations)