I think I asked this question a year ago or so, but wanted to see if
anyone had an update on this, as I believe there may have been a recent
CIR that addresses this issue (that I can't seem to find).

I'm modeling a building that is fed by an electric service that is
mostly demand based. The building Owner has decided to use gas-fired
fuel cells in conjunction with natural gas generators to reduce demand
via peak shaving.

Someone mentioned that this might be a no-no as it relates to Appendix G
- that I would need to model the fuel cells and natural gas generators
in the baseline building as well.

Does this make sense, and has anyone seen a CIR that confirms this?

The client is using fuel cells to reduce emissions, reduce the peak
demand seen by the utility company (thereby reducing their use of
inefficient diesel generators), etc...it doesn't seem fair not to award
a project that wants to do this.

Anyone have any input?

James Hansen, PE, LEED AP