All Exceptions require additional documentation; see the I07 Exception Documentation and Summary Table in Documentation Requirements for more information.
ENERGY USE EXCEPTIONS
EC-001 Industrial Peak Load
Industrial applications are allowed to use propane gas water heaters as a short-term peak load backup to the regular domestic and process hot water system. The team must provide a narrative describing the hot water requirements and alternatives explored in an effort to avoid this Exception, as well as demonstrate through sub-metering that the gas is used for only the short-term processing peak load (i.e., winery “crush,” which is approximately six weeks long) and not throughout the year.
EC-002 Specialized Combustion
In certain circumstances, use of this Exception requires ILFI approval in advance; see details below.
Combustion-based equipment used for process-specific applications that require high heat, such as Bunsen burners in a laboratory setting, are allowed. For any specialized applications that do not require high heat, electric-based alternatives must be explored and documented prior to requesting an Exception. Each Exception request must be submitted as a Request for Ruling for preapproval.
EC-003 Combustion in Commercial Kitchens
In commercial kitchens where electricity-based equipment will not adequately serve the cooking needs of the facility, and where efforts have been made to find alternative solutions and minimize combustion impacts, teams may use combustion-based equipment.
The project team must explain the proposed use, why electricity-based equipment is not functionally equivalent, and describe efforts both to source non-combustion and to minimize the impacts of combustion. In addition, the offset of combustion energy through on-site renewable production must be demonstrated through utility bills and BTU/ kWh calculations (using 1 kBTU = 0.293 kWh).
Teams using wood-fired cooking must also document air quality protection through the use of a CE and/or UL certified soot and smoke filter to minimize air quality impacts. Demonstration of renewable energy offset must include documentation of all wood used in the oven during the performance period, and calculations showing that the equivalent kBtu was offset by renewable energy production by the project over the course of that same time period.
EC-004 Ornamental Fireplace in Transects L1, L2, and L3
In the limited instances where development is allowed in Transects L1 and L2, it is acceptable to install a single indoor wood-burning stove or fireplace because of a strong cultural legacy of the “hearth in the wilderness.” The allowance for a single wood-burning stove or fireplace in Transects L1 and L2 assumes that it is merely ornamental and ceremonial and are not used for primary, day-to-day heating purposes. Therefore, it may be excluded from the project’s energy calculations. This Exception also allows one outdoor wood-burning fireplace in addition to the indoor wood-burning stove or fireplace. The use of a propane igniter is not allowed.
Fireplaces are also allowed in projects in Transect L3 under the following conditions:
The fireplace:
- Cannot be a primary heat source; and
- Must be closed and meet current Nordic Swan emission and efficiency standards (or prove equivalency) as developed by the Nordic Council of Ministers (see below).
In addition, the project must be in a region that is in compliance with the EPA 2013 PM2.5 primary annual fine particle standard of 12 μg/m3.
Nordic Swan Standards
Emissions criteria:
- Organic gaseous carbon (OGC): 100 mg/m3
- Carbon monoxide (CO): 1250 mg/m3
- Particles: 2.0 g/kg (for up to four loads); 5 g/kg (for each load)
- Efficiency criteria: 76% for manually operated stoves or inset fireplaces for intermittent use.
The project team must provide a narrative describing the functionality of the fireplace with regard to these requirements.
If fireplaces with Nordic Swan labels cannot be sourced from within a project’s country, the project team may prove equivalency by showing that the fireplace:
- Falls below the U.S. EPA’s particulate matter emissions level of 2.5g/hr for cord wood or 2.0g/hr for all other wood; and
- Meets the Nordic Swan’s efficiency requirement of at least 76%.
The project team must also advocate to the regional air quality regulatory body to require fireplace manufacturers to perform CO and OGC testing.
Regardless of whether or not a project team is pursuing any Health + Happiness Imperatives, the project must provide documentation showing the installation of carbon monoxide detector(s) within the building.
EC-005 Pre-existing Infrastructure
Projects can take advantage of pre-existing photovoltaic (PV) arrays in certain limited circumstances. The renewable energy system cannot predate the project unless the PV installation was intentionally sized with sufficient overcapacity in place to meet the project’s energy demand. For example, a PV array might be installed ahead of building construction or as part of a campus system to take advantage of certain incentives or efficiencies of scale. This is allowed as long as the team can demonstrate that the PV system was planned, designed, and installed with the intention to serve additional buildings in the future. The project team must provide:
- Photographs of the existing system;
- Metering data or other records documenting the amount of energy both produced by the existing PV array and used by the campus prior to the addition of the project; and
- A narrative signed by the owner confirming their approach and that the system was planned, designed, and installed specifically to service additional buildings.
Pre-Existing Campus Infrastructure
If the project will be served by a pre-existing array that serves an area larger than the project alone, the percentage of energy production that can be attributed to the project must be based on the following:
- The total energy use of the campus over the 12-month performance period, including the project;
- The production of the existing array during the same 12-month period; and
- The total energy use of the project
For example, if during that 12-month period the array provides 22% of the total energy for a larger campus, then the project may claim that 22% of its operating energy was supplied by the array.
To show compliance, the remaining energy required by the project will need to be supplied by new renewable sources dedicated solely to the project unless there is an intention to add renewables that will supply 100% of the entire campus’s energy. The new renewables could be located within the Project Area, elsewhere on the campus, or off site as part of a procurement associated with the project.
Existing Building Projects
If there is an existing PV array serving the building, that energy production may continue to be utilized for the project. The existing PV array must have been planned, designed, and installed with the intention to serve additional buildings in the future, and it may not be attributed to another building or entity via ownership or REC purchasing. In addition, no other current uses of the existing PV can be supplanted by the renovation project.
EC-006 Periodic Cultural Festivals
Periodic cultural festivals are allowed to use gas water heaters as a backup to the regular kitchen hot water. The team must provide a narrative describing the hot water requirements and alternatives explored in an effort to avoid this Exception, as well as demonstrate through sub-metering that the gas is only used during festivals and not during regular occupancy.
EC-014 Emergency Power Systems
If programmatic needs, basic project function, or code requirements mandate the inclusion of an emergency power system, the use of battery backup power is encouraged.
However, if backup needs exceed the capacity of the battery and sufficient battery power is not immediately feasible, diesel or equivalent (e.g., propane or LPG systems) backup generators may be used if the generator:
- Is not included in the project’s strategy for operation and any use during the 12-month performance period is included in the project’s energy consumption calculations; and
- Does not impact adjacent properties through noxious emissions or noise.
If storage tanks for emergency power pose a negative impact due to significant danger related to density or other factors (e.g., projects located in Transects L5 or L6), the project team may include a hard-piped natural gas service to the emergency power system, if the gas service:
- Is not connected to the project’s primary energy systems;
- Is sized exclusively for the emergency power system; and
- Includes a dedicated utility meter to account for any emergency use during the 12-month performance period.
Propane-based emergency backup boilers are acceptable in harsh climates for non-grid-tied projects.
The project team will need to provide a narrative explaining the need for backup power, particularly with regard to the project’s size and function, and illustrating how every effort has been made to reduce the size of the system and prevent its use.
EC-015 Industrial Emergency Backup
Diesel or natural gas backup power is allowed if the project team can demonstrate that they have minimized the amount of backup power required and that the alternative systems available will have a significant negative impact due to danger, inability to provide sufficient power, or significant environmental impacts. The project’s need for diesel or natural gas must be explained in the documentation narrative.
EC-016 Critical Infrastructure and Life Safety – Emergency Power
In certain circumstances, use of this exception requires ILFI approval in advance; see details below.
Critical infrastructure projects or projects in which emergency power is a life safety issue (e.g., hospitals, fire stations, transportation depots) may use combustion for emergency backup power. If combustion must be used, propane generators are preferred; diesel or natural gas backup generators are allowed only in situations where propane backup generators are unable to provide the functionality necessary to the facility, have a significant negative impact due to danger, or have a significant negative environmental impact. To use this Exception, the project team must get preapproval through a Request for Ruling describing their efforts to minimize the amount of backup power required.
RENEWABLE ENERGY EXCEPTIONS
EC-007 Government REC Sales
Project renewable energy certificates (RECs), or other similar production incentives, may be sold as part of a governmentally established or mandated program for achieving larger public policy objectives such as carbon reduction. In these cases, the RECs must be sold to a governmentally specified REC recipient, such as a utility, and the REC purchase contract must specify that the RECs will be held (not resold) by the governmentally established recipient for a minimum of 15 years in order to prevent double-counting of the energy and carbon benefits. Project teams must provide the REC contract and highlight the renewable attribute language of that contract.
EC-008 Arbitrage of Project-Generated RECs
Project-generated RECs and/or emissions-avoidance claims from on-site or off-site systems can be sold or transferred to a third party for their energy or emissions claims if the following conditions are met:
- The project procures, then retires or maintains possession for a minimum of 15 years, new RECs equal to the renewable energy capacity of the RECs being sold or transferred; and
- All newly procured RECs must:
- Be sourced from a comparable 100% non-combustion based renewable energy source, such as wind or solar.
- Be sourced from within the same regional grid, as defined by the electric power markets by the U.S. Federal Energy Regulatory Commission (or comparable international authority).
- Be exclusively attributed to the project.
- Be Green-e Certified (or international equivalent).
