ENERGY USE CLARIFICATIONS

Backup Systems for Emergency Power

If the programmatic needs of the project require an emergency power system, the use of battery backup power is encouraged. Combustion-based emergency backup power systems are discouraged but may be utilized if not included in the project’s strategy for operation and if any use during the 12-month performance period is compensated for through the project’s renewable energy generation. See EC-014 Emergency Power Systems for additional requirements.

Critical Infrastructure and Life Safety
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. Teams may only size the generator to cover the life safety loads defined and mandated by the Authority Having Jurisdiction (AHJ). 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.

Combustion

Bio-Based Combustion Sources
The use of biomass is not allowed due to concerns regarding the associated negative impacts to air quality, increasing demand for the non-sustainable production of biomass fuels that compete with food production, and the risk of systems being switched to fossil fuels in the future.

Building Systems, Heating and Cooling
The following project types may not have combustion-based heating and/or cooling building systems.

  • New Building
  • Building Renovation pursuing I08 – Net Positive Carbon
  • Interior pursuing I08 – Net Positive Carbon

Building Renovation and Interior projects not pursuing I08 – Net Positive Carbon may utilize existing combustion-based building systems in the project scope; however, new combustion-based equipment must not be installed where it previously did not exist. Projects that require renovations to an existing building or an interior tenant space are encouraged to convert existing combustion-based equipment to electric-based whenever possible. However, projects may directly replace or upgrade combustion-based components if a conversion to electric-based systems would require a significant increase in project scope. Examples of a significant scope increase include expansion of the base building footprint or a significant increase in the mechanical spaces to accommodate larger equipment (i.e., outside of an interior renovation scope).

Note that any replacement or upgrades to combustion-based equipment must not result in higher fuel consumption; the intent must be to increase efficiency and otherwise minimize combustion-based fuel use. Projects requiring replacement or upgrades to combustion-based equipment must provide additional documentation to describe investigation of electric-based alternatives and clearly outline the project scope boundaries or limitations that inhibit their use.

Where combustion is permitted, the energy consumed must be metered, included in the Energy Production and Demand Table, and documented as part of the total energy used, and compensated for by installed or procured renewable energy.

Interior-only projects may connect to combustion-based heating/cooling systems that are out of the project scope if formal advocacy to the building owner for a phase-out plan for combustion has been documented.

Combustion-Based District Energy Systems (DES)
New Building and Building Renovation projects pursuing I08 – Net Positive Carbon may not connect to combustion-based district energy systems for heating/cooling.

New Building and Building Renovation projects not pursuing I08 Net Positive Carbon may only use heating and cooling energy from combustion-based DES heating/cooling systems if a phase-out plan is established. The team needs to indicate phase-out plan actions that will be taken over the next 12 months and document completion during the performance period.

When a combustion-based DES is permitted and used, the project team must meter the energy derived from the system and include that energy in the Energy Production and Demand Table and show that the proportionate share of energy produced by the system is compensated for by the project’s installed or procured renewable energy. For projects that contribute thermal resources to a district system, the project must meter the amount of off-site thermal benefit and calculate the proportionate reduction in electrical usage from the contributing project system. Waste heat capture for the project from a DES is only allowed if the heat is not generated from combustion.

Interior-only projects may use heating and/or cooling energy from combustion-based DES systems that are out of the project scope if formal advocacy to the building owner for a phase-out plan for combustion has been documented.

All projects may connect to a combustion-based district energy system for electricity.

Municipal Grid
All projects are allowed to connect to a combustion-based municipal grid for electricity.

Table 7-4 Allowance for Connecting to Combustion-Based Systems in Scope

Table 7-4

Outdoor Stoves or Grills
Outdoor gas stoves and grills that are not permanently installed or hard-piped are considered furniture, fixtures and equipment (FF&E) and are therefore not governed by this certification. However, the use of non-combustion-based alternatives is encouraged.

Temporary Heat During Construction
There is no restriction on temporary heat sources during construction; however, project teams are encouraged to reduce energy demand as much as possible and to use fuel sources that are in alignment with ILFI’s combustion stance. Project teams must account for construction-related emissions (life cycle stage A5) within their embodied carbon analysis.

Efficiency Target

Buildings with a Mixed Typology
If a project has more than one Typology, for example a Building Renovation with an addition, the efficiency target is established by calculating a weighted average based on reductions required per Typology and the percentage of Project Boundary occupied by each Typology. See example under Calculations.

On-Site Net Positive
Projects achieving 105% net energy production (required for pursuing I08 Net Positive Carbon) using exclusively on-site renewables automatically achieve the energy efficiency requirement of this Imperative.

Fugitive Refrigerant Emissions

Project teams must have in place a maintenance plan for fugitive emissions addresses inventory and tracking, equipment inspection, system retrofit, and end-of-life disposal for all equipment with refrigerants present. The project’s systems design and maintenance plan must follow the procedures under Section 608 of the Clean Air Act governing refrigerant management and reporting. For project teams outside of the U.S. that cannot meet these procedures, a local equivalent must be preapproved through a Request for Ruling. A fugitive emissions maintenance plan is not required for existing to remain equipment that is both outside the project’s scope and not owned by anyone on the project team. For equipment not requiring a fugitive emissions plan, a formal phase-out advocacy letter must be sent to the building owner.

A member of the project team, preferably the team’s MEP engineer, must commit to reducing embodied and operational carbon within the MEP industry. The team member must establish and sign a company plan to reduce operational and embodied carbon of MEP systems, request low-GWP refrigerants during projects’ design phases, and request EPDs for MEP products. Alternatively, the team member may show company or individual commitment to the MEP 2040 Commitment.

See Resources for low-GWP refrigerant alternatives, maintenance plan templates, and guidance on managing and reporting refrigerants.

Heat Recovery

Waste heat from an adjacent building or a DES may be used to reduce the energy demand of a project if the recovered heat is not from a combustion-based source.

Project Energy Needs

All equipment and energy-using systems related to any part of the building program (including process energy) and used during building operations must be included in the energy budget for the project. The building must function as intended and meet the energy requirements over the 12-month performance period. Energy used during construction does not need to be included in the project’s operational energy budget.

Note that use of exception EC-014 Emergency Power Systems requires that any energy used by an allowed generator be included in the project’s energy consumption calculations.

In addition, certain optional strategies and exceptions within the Water Petal require that any energy consumption from pumps be accounted for in the project’s energy use calculation.