This document summarizes a presentation given by Jon Maxwell of ERS comparing baseline policy development procedures and content in Massachusetts and California. Some key similarities discussed include using code and standard practice as the baseline for commodity measures, applying logic flowcharts and dual baselines. Differences included Massachusetts having a single policy document focused on commercial/industrial measures while California's was regulatory-driven and involved implementers more directly. The presentation aimed to convince the audience of the value of baseline policies and highlight lessons learned between the two states.
Processing & Properties of Floor and Wall Tiles.pptx
Baseline Policy in MA and CA IEPEC slides
1. Headquarters: 120 Water Street, Suite 350, North Andover, MA 01845 With offices in: CA, CT, ME, NY, OR, TX, VT www.ers-inc.com
BASELINE POLICY ENHANCEMENT
IN MASSACHUSETTS & CALIFORNIA
August 8, 2017
1
2. ERS
≈90 energy efficiency & renewable experts
Offices in MA, ME, CT, NY, TX, CA, OR
Evaluation, studies, implementation, consulting
Presenter: Jon Maxwell, PE
Co-authors: Ralph Prahl, Sue Haselhorst
ABOUT ERS & AUTHORS
8/8/2017 IEPEC 2017 - Baltimore 2
3. Convince you to create a baseline policy
Share procedures lessons learned from MA, CA
Highlight technical similarities & differences
Get at least 5 people to look at the paper
PRESENTATION GOALS
8/8/2017 3IEPEC 2017 - Baltimore
6. BASELINE POLICY—WHY BOTHER?
(NY)
Category Description
This category accounts for typo
revisions, incorrect extraction of
This category accounts for a ba
(L050)
This category accounts for thos
clearly violate program tenets. (L
Administrative:
46 measures
Baseline:
33 measures
VFD screening method:
10 measures
Unsubstantiated savings
claims: 7 measures
This category accounts for savin
supported with site based analys
Inoperable Equipment: 1
measures
This category accounts for the e
described in the project docume
Quantity or size:
41 measures
This category accounts for the d
compared with the project docum
Technology:
27 measures
This category accounts for the d
observed by the evaluators versu
Applicant used deemed
value: 16 measures
This category accounts for diffe
operation) and the evaluated val
Interactivity:
38 measures
This category accounts for the i
interactivity is lighting which typ
Operation/Load Profile:
81 measures
This category accounts for the d
factor, part load profile, or temp
Other/Weather:
2 measures This category accounts for the w
Category Description
Negative
Impact
on RR
Positive
Impact
on RR
-8%
2%
-6%
1%
-8%
0%
-2%
0%
-2%
0%
-1%
0%
-1%
0%
-2%
3%
0%
1%
-8%
3%
-1%
0%
This category accounts for typographic errors, failure to update tracking with application
revisions, incorrect extraction of savings from spreadsheets and the like. (L126)
This category accounts for a baseline adjustment from early replacement to normal replacement.
(L050)
This category accounts for those VFD measures that did not meet program eligibility criteria or
clearly violate program tenets. (L077)
Administrative:
46 measures
Baseline:
33 measures
VFD screening method:
10 measures
Unsubstantiated savings
claims: 7 measures
This category accounts for savings estimates based on a claimed savings fraction which was not
supported with site based analysis, measurement, or evidence from an applicable study. (L097)
Inoperable Equipment: 1
measures
This category accounts for the equipment discovered to not be operational or controlled as
described in the project documents. (LR21)
Quantity or size:
41 measures
This category accounts for the differences in the quantity or size of an installed measure when
compared with the project documents. (L062)
Technology:
27 measures
This category accounts for the differences in the actual baseline and installed technologies
observed by the evaluators versus the project documented technologies. (L134)
Applicant used deemed
value: 16 measures
This category accounts for differences in the NYTM specified parameters (usually hours of
operation) and the evaluated value. (L134)
Interactivity:
38 measures
This category accounts for the interactive effects of measures. A good example of measure
interactivity is lighting which typically has interactive cooling and heating effects. (LR02)
Operation/Load Profile:
81 measures
This category accounts for the deviations in the projected equipment load profile (part load
factor, part load profile, or temperature profile) or the operational schedule. (L106)
Other/Weather:
2 measures This category accounts for the weather normalization applied by the evaluators. (L084)
Close to CA’s 13%
frequency, likely
similar hit on RR!
≈5% hit
on RR!
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7. BASELINE POLICY—WHY BOTHER?
Can these be fixed in advance?
Inoperability or facility shutdown issues?
Accidental errors?
Hours?
Predicted load factors?
Baseline?
× No
× Not really, maybe specify QC
× Not really, maybe deem
× Not really maybe deem
Yes, baseline can be
aligned, in advance,
through policy articulation
8/8/2017 IEPEC 2017 - Baltimore 7
9. Headquarters: 120 Water Street, Suite 350, North Andover, MA 01845 With offices in: CA, CT, ME, NY, OR, TX, VT www.ers-inc.com
PROCEDURES & CONTENT
COMPARISON
9
10. Stakeholder engagement
Significant development period
1 to 2 years
Longer than planned, extra iterations
Professional facilitation
DEVELOPMENT PROCEDURES – COMMON
IEPEC 2017 - Baltimore8/8/2017 10
11. Single document (MA)
C/I focus (MA)
Implementer engagement (CA)
Regulatory-driven (CA)
Final document authorship
CPUC in CA
Consultant team in MA
DEVELOPMENT PROCEDURES – DIFFERENCES
IEPEC 2017 - Baltimore8/8/2017 11
12. KEY TECHNICAL SIMILARITIES
IEPEC 2017 - Baltimore8/8/2017 12
Code and ISP basis
for commodity measures
Logic flowcharts (MA more)
Preponderance of evidence (POE) (CA more)
Dual baseline (new to MA eval)
Pre-installation evaluator engagement
Non-regressive baseline (MA 3 exceptions)
Tiers of rigor (CA more)
Industrial capacity expansion
New construction
Post-project production rate governs
13. TECHNICAL HIGHLIGHTS
(1 OF 2) – CORE BASELINE DEFINITION
IEPEC 2017 - Baltimore8/8/2017 13
MA: Baseline is “…condition absent the measure”
Not “absent the program”
Think: What if the technology didn’t exist
CA: Baseline is “Table 1”
Alteration
Type
Delivery
Savings
Determi-
nation
Shell, Bldg
System, Add-
On
Behavioral,
RCx,
Operational
Normal
replacement
Accelerated
replacement
and repair
eligible
Code Code
Code Code
Calculated Existing Existing Code Dual
Deemed Existing Existing Code Dual
Normalized
Metered
Existing Existing
Existing, Program
Design
Existing
RCT/ experi-
mental
Existing Existing Existing Existing
Existing
Standard
Practice
Dual
New
Up- Mid-stream
Non-Bldg, Ag, Process
Existing
Blgs
(incl.
major
altera-
tions)
Down-
stream
14. IEPEC 2017 - Baltimore8/8/2017 14
Free ridership questions must be relative to the
gross baseline
Especially vulnerable if ex post evaluator changes
baseline
MA spin-off working group to avoid overlap penalty
o “Absent the measure” vs. “absent the program” is tricky to
word
o New framework in pilot stage
CA evidence of free ridership guidance
CA ex ante binding free ridership assessment
TECHNICAL HIGHLIGHTS
(2 OF 2) – FREE RIDERSHIP
15. APPLICATION COMPARISON
IEPEC 2017 - Baltimore8/8/2017 15
Policy is binding for evaluators in MA, for
all in CA
CA ex ante review findings are binding to
implementers immediately
MA now evaluating lifetime savings RRs
Informational-only thru 2018
16. SUMMARY
IEPEC 2017 - Baltimore8/8/2017 16
Low realization rates? Baseline policy can help
Stakeholder process builds understanding,
buy-in
Use MA & CA for reference, but each
jurisdiction has different needs. Trade-offs:
Specificity vs. flexibility
Ideal theory vs. practicality
Guidance vs mandates
A worthwhile investment
17. TECHNICAL HIGHLIGHTS
INDUSTRY STANDARD PRACTICE
IEPEC 2017 - Baltimore8/8/2017 17
For new/replace on failure, ISP is baseline if no
code or standard
Not minimum efficiency commonly installed
What if code/std exists and ISP differs? MA:
If ISP exceeds code, use ISP. Careful of NTG
wording!
If ISP is below code:
o If a code compliance program, use code/std
o If no compliance program, use ISP
18. KEY TECHNICAL DIFFERENCES
IEPEC 2017 - Baltimore8/8/2017 18
Focus on principles (MA) vs. specifics (CA)
Free ridership in scope for CA ex ante review
process
MA emphasis on difference between
commodity & unique measures
CA emphasis on tiers of rigor
19. CONTACTS
Jonathan B. Maxwell, PE
VP, Energy & Evaluation
jmaxwell@ers-inc.com
979-978-2550 x205
8/8/2017 19IEPEC 2017 - Baltimore
Notes de l'éditeur
Probably 60 work on evaluations some of the time, probably 6 dedicated to it. Lots of interdisciplinary training that we believe keeps our staff grounded in both directions.
Take time to translate confusing graph
From CPUC 2013 Custom Impact Evaluation Industrial, Agricultural, and Large Commercial, Source cited in paper,
Study of 240 measures.
Baseline change is the 2nd most common reason for adjustment—13% of evaluated measures.
But! When adjusting, baseline removed an average of 79% of savings at each site.
Biggest single contributing factor to low RR. ~10% hit on baseline alone (unweighted rough approximation)
(FYI 44% to 76% gross RR overall in study, depending on PA & fuel)
So what? I’ve heard CA is a bunch of unreasonable hardacres…
From MA Lg CI Eval 2010-2013 Custom Gas
Okay, the paper’s about CA & MA. How about anywhere else?
From NYSERDA IPE 2012 and NCP 2012, respectively.
Again, common in frequency
(not shown) higher in energy impact
And with the progress made in MA and CA, you have hundreds of thousands of dollars as building blocks already invested, free for your use.
MA ~ 30 pages, CA 100s of pages b/t docs
CA: ALJ-ordered
Legislatively mandated interpretations, in some cases (AB-802)
CPUC staff white papers, drafts
Filings, filed comments, re-issuing
ISP = industry standard practice
MA of course has dozens of examples
Possible exceptions: (1) 2-year in failed mode; (2) kitchen equipment; (3) prior measure was funded EE measure
CA I couldn’t find a single statement of baseline
CA hot button issues: - What is a “building system”? Fundamental HVAC system type? Yes? Lamp? Most incl CPUC say No. Lighting system? Maybe
- Are EMS upgrades a BRO?
Table 1 is evolving
Last three months working groups continue to refine CA’s working definition. Would be pleased to yield the floor during Q&A for update in that regard.
In direct query
Provide quick simplified example:
94% efficiency condensing boiler is installed and runs as designed.
Code is 80% efficiency boiler
An ISP study concludes that standard practice is an 82% efficient boiler
Gross savings is evaluated with an 82% baseline. If tracking used an 80% code baseline, gross RR takes a hit.
The FR interview asks about program influence. It MUST be relative to an 82% ISP, not an 80% code or NTGR will take a hit also, for the same 2%. Bad!
Maybe mention ERS, DNV, Tetratech
CA will note that the ex ante consultants are not the program evaluation consultants, but for the PAs & implementers it is functionally the same.
CA will note that the ex ante consultants are not the program evaluation consultants, but for the PAs & implementers it is functionally the same.
ISP is not site-specific.
Stretch code digression only if time.
CPUC Decision 16-018-019 “Table 1” specifies baseline type by alteration type, delivery type, alteration type, program type
CA does not consider the ex ante review process to be impact evaluation but many view it as such.
More on free ridership in two slides. Hold off from discussion here.