We are pursuing the Offsite Renewable Energy portion of this credit through the purchase of Green-e certified Renewable Energy Certificates (RECs). The intent of this credit is to "encourage and recognize increasing levels of on-site and off-site renewable energy in order to reduce environmental impacts associated with fossil fuel energy use." The USGBC's guidelines in LEED-EB are not in synch with policy standards from Center for Resource Solutions (CRS) for Green-e Energy, WRI's guidelines for addressing Scope 1, 2 and 3 emissions or general industry accepted best practices. The problem relates to USGBC in LEED-EB requiring the calculation of TOTAL LOAD from ALL ENERGY SOURCES(including natural gas, steam heat, propane, etc.) on the building energy use side to set the amount of offset; while Green-e Energy states that REC's cannot be used to offset anything other than direct electricity generation (scope 2 emissions). As stated on p. 15 of the Green-e Code of Conduct: B. Communicating the Emissions Avoidance Value of a Green-e Energy Certified Product Green-e Energy Certified renewable energy products must be denominated in megawatt-hours (MWh) or kilowatt-hours (kWh). Consistent with this policy, Participants can market their certified products as instruments to address the environmental impacts associated with the consumption of electricity. One aspect of these impacts is the indirect carbon dioxide emissions arising from the purchase of electricity generated through the combustion of fossil fuels, classified as "Scope 2" emissions by the World Resources Institute's Greenhouse Gas Protocol. The explicit marketing of Green-e Energy Certified renewable energy products as a means to reduce or offset emissions from anything other than the consumption of electricity purchased from the grid shall not be permitted. Additionally, every other LEED type (NC, CI, CS, etc.) only requires the project owner to offset some percentage of the building's electricity use. LEED EB 2.0 and LEED EB OM are the only versions that (mistakenly) include non-scope 2 emissions. We propose to earn EA Credit 2.1 by offsetting only our scope 2 (electricity) emissions, in the percentages outlined in the credit. This will provide consistency with other LEED types and, most importantly, align with Green-e and WRI guidance on the issue. Further, it would seem that fewer LEED EB projects are choosing to use green power than LEED NC, CI, or CS projects, due in large part to the higher costs associated with offsetting scope 1 and 3 emissions in addition to scope 2. Allowing projects to earn this credit by offsetting only scope 2 (electricity) emissions should actually increase the number of participating projects, thus encouraging increasing levels of off-site renewable energy (aligning with the intent of this credit).
The proposal to offset only electricity emissions in the percentages outlined in the credit would not be acceptable to earn EA Credit 2. In order for a building to be considered climate neutral, all fuel consumption by building uses must be addressed including direct fossil fuel use. Secondly, in addition to climate neutral considerations, the decision to include total load from all energy sources as a basis for LEED-EB v2.0 EAc2 offset level requirements was made during the lengthy LEED-EB pilot program process to help address thermal energy sources and provide a better fit with the U.S. EPA's ENERGY STAR Portfolio Tool utilized for LEED-EB EAp2 and EAc1. In regards to offsets, with the release of programs like Green-e climate to complement Green-e energy, the USGBC agrees that Green power or REC purchases or the equivalent should only be used to offset electricity use, Scope 2 emissions. Scope 1 & 3 emissions from natural gas, purchased steam, fuel oil, or propane use should use carbon offsets, verified through a program like Green-e climate or equivalent. Concerns raised above regarding the encouragement of greater participation rates for this credit are always addressed as part of new EB rating system versions and could be accomplished by making adjustments to the required minimum threshold levels as readily as through significant changes to the credit requirements. Applicable Internationally.
Related Addenda (Corrections & Interpretations)