C/I energy management systems that don’t fit in the category “add-on” C/I/Ag refrigeration Accelerated Public sector, including primary and secondary Replacement schools The pre-existing equipment is functional and its age is less than ½ of EUL The pre-existing equipment is broken and the Normal repair cost exceeds ½ of the replacement cost Replacement Measure associated with major alteration during tenant change-out The payback time after incentive exceeds the No Influence measure EUL (Free Rider) Note that this does not include Strategic Energy Management programs The guidance document also stipulates the following: a measure meets the to default’ criteria for accelerated “If ‘direct replacement, a simplified protocol may be used to demonstrate that the measure is in fact accelerated replacement. See the simplified POE protocol described in Section 6. A measure that does not meet the above criteria is not certain to be the opposite of the default baseline shown. It simply means it is not ‘direct-to-default’.“ Neither the descriptions in the table nor the text above address or define what is meant by a protocol” or what standards and requirement such a “simplified protocol would warrant, or how it would be applied. Whether the intention was to reduce the rigor level by one tier than would otherwise apply, or whether the intended meaning was to apply the lowest rigor tier to all cases, neither proposal is adopted. The assertion that any alternative baseline determination beyond what is noted in the table cannot be made without a higher burden of proof is similarly ambiguous. It is also inconsistent with our determination working group –and recommendations - that a normal replacement baseline is always an available
C/I energy management systems that don’t fit in the “add-on” category Accelerated Replacement C/I/Ag refrigeration Public sector, including primary and secondary schools The pre-existing equipment is functional and its age is less than ½ of EUL The pre-existing equipment is broken and the repair cost exceeds ½ of the replacement cost Normal Replacement Measure associated with major alteration during tenant change-out The payback time after incentive exceeds the measure EUL No Influence (Free Rider) Note that this does not include Strategic Energy Management programs The guidance document also stipulates the following: “If a measure meets the ‘direct to default’ criteria for accelerated replacement, a simplified protocol may be used to demonstrate that the measure is in fact accelerated replacement. See the simplified POE protocol described in Section 6. A measure that does not meet the above criteria is not certain to be the opposite of the default baseline shown. It simply means it is not ‘direct-to-default’.“ Neither the descriptions in the table nor the text above address or define what is meant by a “simplified protocol” or what standards and requirement such a protocol would warrant, or how it would be applied. Whether the intention was to reduce the rigor level by one tier than would otherwise apply, or whether the intended meaning was to apply the lowest rigor tier to all cases, neither proposal is adopted. The assertion that any alternative baseline determination beyond what is noted in the table cannot be made without a higher burden of proof is similarly ambiguous. It is also inconsistent with our determination –and working group recommendations - that a normal replacement baseline is always an available
179264220.docx