ESPC Statute Does Not Recognize Sale of Solar Energy Certificates as Savings Revenue: ASBCA No. 57779, Honeywell International, Inc.

In the quantum phase of an appeal of the contracting officer’s final decision, the Armed Services Board of Contract Appeals held that revenues from the sales of Solar Renewable Energy Certificates were not cognizable energy savings under the Energy Savings Performance Contract statute, and therefore this revenue could not be counted as savings generated under the contract.