Phase I Ex Ante Review Findings

CPUC 2 NC0128969, X500

Measure Description

The project is a square foot new office building to be constructed in California. The following measures were evaluated for this project.

1. Variable refrigerant flow (VRF) heat pump system

2. Demand controlled ventilation in high density occupancy areas

3. Dedicated outdoor air systems with energy recovery

4. Reduced lighting power

5. High performance glazing

6. Improved exterior wall insulation

Summary of Review

The Investor-Owned-Utility (IOU) submitted the following documents for this Phase I review:

Check list for NC0128969 SBD.xlsx

128274-SBD Project Summary with Incremental Cost.doc

128274-SBD Util Forms.pdf

128274-SBD NRNC Technical Review Log.pdf

NC0128969 IMC analysis.docx

Standard and Proposed EnergyPRO input and output files

The CPUC staff has reviewed the submitted documents and makes the following observations.

1. Most of the savings for the project are a result of changing from a packaged VAV systemin the Standard case to a variable refrigerant flow heat pump system. A detailed reviewof the input files from the Standard case model revealed that the HVAC systems in thismodel did not have economizers or supply air temperature reset control, which are bothrequired by the 2008 Title 24 energy code for this type of system.

2. 2008 Title 24 does not allow trade-offs for VRF systems.

3. EnergyPRO is not approved by the CEC or CPUC for modeling of VRF systems forSavings By Deseign projects. The statewide group that is developing workpaper methodsfor VRF should be consulted for an appropriate analysis method.

4. The submitted analysis involves fuel switching. In order to comply with CPUCrequirements for fuel switching, the three pronged test must be followed. This involvesestablishing a secondary gas baseline that is equivalent to the proposed building in allaspects except the heating fuel. The other option is to establish the standard case as an

Phase I Ex Ante Review Findings

CPUC 3 NC0128969, X500

all-electric building, but with this approach it must be demonstrated that the design isplausible or typical for that location and building type.

5. There was nothing in the submitted documents to support the lighting power densityvalues used in the proposed building model. The submission needs to include lightingschedules from construction documents as well as spreadsheets developed to calculate theproposed lighting power densities.

6. There are upstream rebates for LED lighting and VRF, so if savings from these measuresare claimed for the Savings By Design program, then they cannot be taken as upstreamrebates as well. If the upstream rebates are claimed, then the lighting and HVAC systemsneed to be modeled as neutral in the Savings By Design analysis.

Review Conclusion

The ex ante savings are rejected. The inclusion of LED and VRF in Savings By Design isquestionable, and the analysis method for VRF is not approved.

Summary of CPUC Staff Requested Action by the IOU

CPUC Staff requests that the IOU undertake the recommended steps and submit the followinginformation by March 24, 2015, or within 2 weeks of the date of the posting of this Phase 1 ExAnte Review Findings document:

1. Determine whether VRF and/or LED lighting will be claimed for upstream rebates.Modify analysis to treat VRF and LED lighting as neutral if the upstream rebates will beclaimed.

2. If VRF is to be considered as a measure in Savings By Design, then an approvedcalculation method must be used, and the issue of fuel switching must be addressed.

3. If improved lighting is to be considered as a measure, then complete documentation ofproposed lighting power density must be submitted.