22-0610 I08 Net Positive Energy Offsite REC's

QUESTION

Our project is pursuing an innovative path to net zero energy, using a combination of an on-site and off-site array, due to site restrictions (we are a lot-line building, located in a historic district, and have maximized our rooftop PV). Our project has financed (and donated, with ILFI guidance) our off-site array on a local affordable housing project, allowing them to benefit from the (free) electricity from the array, as well as ultimate ownership of the array, while our project intends to retain the array's RECs for the 15-year period required by ILFI. However we've run into a small snag with the local utility incentives that contributed to this array, in that they require the array building owner to retain the PVs environmental attributes.

In order to navigate this conundrum, and ensure that we meet ILFI's intent to meet net positive energy imperative, expand renewable energy resources, and eliminate fossil fuel emissions associated with energy usage, what we propose:

1) The off-site affordable housing nonprofit will receive the RECs for the PV installation, and retire them on behalf of LBC project, ensuring that the total amount of renewable energy produced (and utilized at this location or sent to the grid) to the local-grid is new and additional, and also attributable to the LBC project, although technically owned by the local off-site property (thus meeting the requirements of the incentive program)

2) The LBC project's net-metering contract with the local utility will include participation in their Green Energy program, ensuring that any utility energy used on-site is renewable and carbon-free.

3) The net effect is that the LBC project's entire usage is attributed to new and additional PV resources procured by the project, with the RECs from the onsite portion retained by our project, and the offsite portion retired, so that they cannot be transferred or otherwise claimed. The offsite affordable housing project gets the benefit of free electricity of the array, and while they cannot claim the RECs, the electricity they use is clean and renewable.

ANSWER

ILFI agrees that the proposal as described meets the siting, additionality, attribution, and ownership requirements for offsite renewables. Further, the siting and disposition of the generated power constitute an excellent example of the offsite renewable pathway.

In addition to all other documentation required to demonstrate compliance with I08-Net Positive Energy, the project team will need to submit documentation addressing the specifics of its offsite renewables arrangement, including:

  1. metered generation data from the renewables located offsite; 
  2. a contract between the certifying project and the owner of the offsite location confirming that the REC's are being retired on behalf of the certifying project and that the power is being solely attributed to the certifying project for a minimum of 15 years; and
  3. prominent educational material at the certifying project site explaining the offsite arrangement, along with evidence that the meter at the offsite location is displaying both realtime and yearly energy output, and specifies that the energy is attributed to the certifying project.

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