SCE Comments on DEER2016 Update Scope

Transcription

1 SCE Comments on DEER2016 Update Scope Submitted February 27, 2015 Below, please find a combination of proposed requests, queries, and technical feedback by Southern California Edison (SCE) pertaining to the scope of the CPUC s DEER2016 update. SCE would like to first note that since DEER is not expected to be fully updated until the third quarter of 2015, SCE is concerned that the EE program goals promulgated will be based on draft or not fully updated modeling methodology that may not be cost-effective, reliable, and feasible. Therefore, SCE requests that Commission staff allow an opportunity for DEER2016 to reflect the results of the Phase EE Potential and Goals update study, to help assure the EE program goals and the EE program requirements are reasonably updated, and in congruence with EE program policy and requirements. Prioritization of Updates Responses to Commission staff questions For DEER2016, these additional prioritization criteria should be considered: Measure uncertainty High Impact Measures: Lighting measures should be prioritized first, followed by HVAC, Appliances, and Refrigeration; see Figure 1. The work papers achieving the highest savings are shown in Table 1; they should be prioritized if they are within the update scope. More comprehensive data are available upon request.

2 Deemed Savings compared to Portfolio (Custom + Deemed), 2014 (Q1 Q3) Lighting HVAC Appliances Refrigeration Audits Pumping Building Envelope Office Equipment Process Food Service Whole Building Water Heating Consumer Electronics 5.14% 3.69% 1.63% 1.51% 0.96% 0.29% 0.26% 0.13% 0.05% 0.03% 0.02% 0.00% % of Portfolio kwh % of Portfolio kw 55.26% 0% 10% 20% 30% 40% 50% 60% Figure 1: Deemed Savings Ranked by End Use Table 1: Top 25 (by kwh) Work Papers in Portfolio Portfolio Totals, 2014 (Q1 Q3) 104,489 kw 622,362,675 kwh Work Paper % of Portfolio kw % of Portfolio kwh SCE13LG017 Upstream Interior Integral Non-Dimmable (Screw-in) CFLs 28.09% 33.62% SCE13LG106 Retrofit MR16, PAR30, and PAR38 Fixtures with LED Lamps 8.69% 7.67% SCE13LG087 Fluorescent Fixture to Fluorescent Fixture Retrofit 8.17% 6.09% SCE13LG086 Interior Linear Fluorescent Fixture 4.55% 2.96% SCE13AP007 Recycling of Appliances Preventing Continued Use 2.64% 2.31% SCE13MI001 Residential Audits 4.31% 1.51% SCE13AP001 Energy Efficient Refrigerators and Freezers 1.58% 1.36% SCE13RN009 Anti-Sweat Heat (ASH) Controls 0.92% 1.22% SCE13LG085 Interior Compact Fluorescent Fixture 0.50% 1.08% SCE13WP001 Residential Variable Speed Swimming Pool Pump 0.84% 0.95% SCE13HC043 Water Cooled Chillers 1.20% 0.80% SCE13HC035 Unitary Air Cooled AC Units 65 kbtuh and Larger 0.77% 0.74% SCE13HC039 VFD Retrofit to Central Plant Systems 0.80% 0.74% SCE13HC050 Variable Speed Drive on HVAC Fan Control 0.67% 0.74% SCE13LG098 Fluorescent to LED Retrofits in Reach-In Display Cases 0.95% 0.65% SCE13LG007 Pin Based Exterior Compact Fluorescent Lamp (CFL) Fixture 0.00% 0.62%

3 SCE13HC030 Air - Cooled Packaged Chillers 0.25% 0.61% SCE13LG072 Upstream Interior 3-way and Dimmable CFLs 0.52% 0.57% SCE13HC052 Efficient Fan Controller for Residential Air Conditioners 1.04% 0.46% SCE13LG103 Interior LED Downlight Fixtures 0.45% 0.41% SCE13LG076 Integrated Linear Fluorescent Occupancy Sensor 0.58% 0.40% SCE13LG025 Occupancy Sensors Wall or Ceiling Mounted 0.44% 0.31% SCE13HC036 Variable Refrigerant Flow Commercial Heat Pumps & Heat 0.68% 0.29% Recovery Systems >65kBtu/h SCE13OE001 Power Management Software for Networked Computers 0.02% 0.26% SCE13HC002 Reflective Window Film 0.70% 0.26% 2. SCE agrees with the order of importance (#1 4) that Commission staff have assigned to update priorities. SCE s recommendations for revisions to update areas are detailed in the sections below. 3. SCE s recommendations for additional resources and methods are detailed in the sections below. 4. These additional update areas should be considered: Revisit measures that were dropped during the development of DEER Create or update a detailed DEER reference document which describes each measure and includes sources used, analysis methods, and calibration methods. Create a document detailing DEER-approved methodologies for calculating work paper values. DEER building type characteristics Building type configurations Clarify which building types (if not all) will be included in the update scope. Lighting operating hours and usage profiles Request that the DEER2016 lighting operating hours reflect or supersede the content in all past lighting dispositions. Request a comprehensive document showing hours for all sectors and technology applications. DEER lighting dispositions have contradicted each other in some areas, including hours of operation. If PAs want to use DEER lighting and building schedules in simulation software besides equest, clarify which schedule libraries are appropriate for use. In R , Attachment A, Section SCE, Item 2 (pg A-3), SCE expressed a concern about the development methodology for residential lighting usage profiles. In Item 3 (pg A-3), SCE mentioned a misalignment between the coincident factor and the DEER peak demand definition. The Commission staff response to both Items was that recent metering results would be considered. Verify if these issues are in the scope of the DEER2016 update.

4 Installed lighting technology characteristics Additional sources to consider: o WO 54 LED Market Characterization o WO13 Lighting Market Characterization Building operating characteristics School buildings are assumed to be closed during much of the DEER peak period, and therefore currently no demand reduction is claimed. SCE requests that school operating schedules be reevaluated. Clarify if any additional high efficiency HVAC performance curves will be developed (beyond those already incorporated in DEER2015). For the recalibration of residential prototype characteristics, suggest that the NIST Technical Note Sensitivity Analysis of Installation Faults on Heat Pump Performance be considered. In R , Attachment A, Section SCE, Item 4 (pg A-4), SCE noted that the modeling of residential foliage was inconsistent across climate zones, and in reponse the Commission staff planned to consider recalibrating the residential heating and cooling energy use. Verify if this issue is in the scope of the DEER2016 update. Updated building weights Other comments Request that DEER publish all the data in this update area (building type configuration and characteristics, operating hours, technology characteristics, weights, temperature setpoints, etc.) on deeresources.com. This includes supplementation documentation describing how the data were developed. Request that DEER publish supporting documentation for all updates made to MASControl. Request that equest be able to provide DEER peak demand reduction as part of the simulation output report. SCE has had some concerns regarding the accuracy of modeling evaporatively pre-cooled condensers in equest and will request guidance on modeling. Technology and measure costs Requirements or guidelines for cost Regarding the language DEER does not include any cost data, and Program Administrators must develop costs for deemed measures using work papers : Previous Commission staff direction has instructed PAs to use DEER costs (e.g. DEER 2008). Clarify if this direction is still applicable, or if all existing DEER cost sources are being retired. In some cases, DEER 2008 has more comprehensive costs than the WO017 cost study. For example, DEER 2008 has costs for split system heat pumps from 14 to 18 SEER, but WO017 only has costs from 13 to 16 SEER. Provide guidance on what loading order to use in cases like these, and, if any, the DEER-approved method of determining missing costs.

5 Other comments Both cost areas should have an X under the Cross sector. Update savings values and definitions of current DEER measures Lighting measures This is a high priority update area Request the addition of LED measures offered by PAs but not in DEER, including: o LED tubes o LED menu boards Suggest that ex-post LED studies be used to inform the DEER LED methodology. Clarify if DEER2016 will include the screw-in CFL and T5 replacing metal halide measure updates mentioned in the DEER2015 Uncertain Measures presentation. Clarify if DEER2016 will include the updates mentioned in the 1/27/15 lighting disposition, affecting: o Screw-in CFLs, MR-16 LEDs and screw-in LEDs o Linear fluorescent retrofits o HID, induction, and LED technologies, high-bay linear fluorescent fixtures and hardwired exterior lighting Lighting should have an X under the Codes and ISP references. HVAC measures Request the addition of HVAC equipment efficiency tiers offered by PAs but not in DEER, including: o <55kBtuh Packaged Heat Pump: 18 SEER/14 EER o 55to65kBtuh Packaged Heat Pump: 18 SEER/14 EER o kbtu/hr Air Source Unitary Air Conditioner DX Equipment: 12.5 EER/14.8 IEER, 13.5 EER/19 IEER o kbtu/hr Air Source Unitary Air Conditioner DX Equipment: 13 EER/15.2 IEER, 13 EER or 17 IEER, 13 EER or 19 IEER o kbtu/hr Air Source Unitary Air Conditioner DX Equipment: 10.5 EER/11.1 IEER, 11.1 EER/13.1 IEER, 11.6 EER/15 IEER o 760 kbtu/hr Air Source Unitary Air Conditioner DX Equipment: 10 EER/10.9 IEER, 10.4 EER/14 IEER, 10.7 EER/16 IEER o <65kBtu/hr Water-Source Heat Pump: 15.0 through 18.0 EER o kbtu/hr Water-Source Heat Pump: 15.0 through 18.0 EER o kbtu/hr Water-Source Heat Pump: 14.0 and 15.0 EER o >240 kbtu/hr Water-Source Heat Pump: 13.0 and 14.0 EER Consider adding or updating measures for: o Variable refrigerant flow systems o Mini and multi-split ductless systems o Commercial Quality Maintenance: RCA, condenser and evaporator coil cleaning, air flow adjustment, economizer repair, economizer reprogramming, thermostat replacement

6 HVAC should have an X under the ISP reference. Residential Appliances Clarify if appliance recycling measures will be updated as mentioned in the DEER2015 Uncertain Measures presentation, and indicate the methodology and sources considered for the update. For appliances that may be fueled by electricity and/or gas, explain the methodology for measure development. For example, will there be separate electric and gas measures, or will savings be weighted by market share? Residential Appliances should have an X under the DHW tech group. EUL and RUL Updates Lighting Explain how the LED portfolio impact is affected by the EUL and RUL of CFLs. Verify if this CFL EUL update is the same one mentioned in the DEER2015 Uncertain Measures presentation. SCE recently completed an in-depth analysis of the CFL Lab Test, per agreement with the Commission. The survival analysis shows a more accurate picture of CFL lifetimes and should be used for updating DEER values instead of the initial CFL lab test report. Energy Upgrade California The current method of developing weighted EULs is based on CPUC direction. Clarify how this method will be updated. Develop packaged measure EUL guidelines that can be applied to non-euc areas, such as new construction whole building measures. Other comments Provide guidance on what reporting IDs to use for EUL and RUL. Net to Gross Updates General NTG updates NTG values updates are identified as to be conducted on a time permitting basis for DEER SCE believes that since NTGs are an important cost effectiveness input. These values are taken directly from impact evaluation studies and should not require additional time-consuming steps. While DEER typically provides a listed table of values to use for ex ante workpapers, all updated NTG values applicable for measures and programs and recommended by the evaluation study should be updated in DEER Gross Savings and Installation Rate Adjustments General GSIA updates Recommend incorporating GSIA values into DEER.

7 Request that the DEER team provide guidance on how GSIA values should be applied to measures. Review of Completed Work Ex Post Evaluation Measurement and Verification Work Market Research and Baseline Evaluations If known, comment on the granularity of the evaluation data. Will it have market saturation data down to individual wattages? Industry Standard Practice Studies Request that all ISP studies be publically vetted and reviewed through the EM&V process. Request that for lighting code or ISP, an equivalent technology be provided at the wattage level, not just at the technology level. Custom Project Reviews Workpaper Reviews Calculation Methodologies Provide a description and/or flowchart for the occupancy sensor methodology that will be used in DEER2016. Use of Available EM&V EM&V and other PA research sources that are reviewed for reasonableness to determine new new profiles, parking garage applications, or otherwise should generally be pre-determined for transparency and prevention of user bias in the selection of research data. SCE requests that related approaches be explicitly provided to stakeholders. Thank you for reviewing the above comments, and please let us know if there are any further questions by reaching out to the SCE ex ante review staff as needed.