Comments from Dan Wildenhaus
NEW Measure: The Northwest ENERGY STAR Homes program plans to submit a new measure in 2012. The intent is to submit a Standard Protocol Measure for a Multi Family Builder Option Package for structures 3 stories or less. The measure will be based on acheiving 15% reduction in energy use over the Washington State Energy Code.
Comments from Avista
Under the Work Scope section, specifically the bullets on page 3 of the Draft, I would suggest the modifications as noted below. These comments are consistent with my discussion points from the conference call this past Tuesday.
#1
Original: Maintain a process through which Bonneville, the region’s utilities, and system benefit charge administrators can demonstrate that different cost, savings, and cost-effectiveness findings should apply to their specific programs or service territories.
Modified: Maintain a process through which Bonneville affiliated utilities and system benefit charge administrators can demonstrate that different cost, savings, and cost-effectiveness findings should apply to their specific programs or service territories.
#2
Original: Review measurement and evaluation (M&V) plans and/or M&V results to assess their consistency with generally-accepted M&V practices
Modified: If requested by the utility, review its measurement and evaluation (M&V) plans and/or M&V results to assess their suitability for use as supporting studies for RTF-related measure evaluations.
Comments from Bob Ramirez
Regarding ELCAP data: During the call, someone mentioned that they thought the EPRI had taken over the ELCAP data. I have a bit of information (but not much) on that. In the 1990's, the ELCAP data was loaded into EPRI's CEED (Center for Electric End-Use Data) database (EPRI-CEED). We were managing the CEED data for EPRI for a few years during that time. It doesn't appear that this is available publicly, but it might be available to an EPRI member.
Comments from Bill Koran
The plan overall seems to cover most of the highest-priority items. However, there are some important items that may not be adequately covered in the draft plan.
First, a general issue is that the plan includes $85,000 in funding to complete Appendix D of the Guidelines for RTF Savings Estimation Methods, but there is a note that says this is “Optional pending desirability by funders.” (Appendix D is Program Impact Evaluation Protocols.) I believe it is very important that this is completed. The most important part is the connection between M&V and Program Impact Evaluation. Without this, it seems there is a risk that the M&V Guidelines and Protocols being developed will only be used for crediting program providers with savings, but the utilities’ savings numbers could be notably different.
Historically, because of a lack of M&V based on actual performance, but commonly just a review of engineering calculations, it was appropriate that evaluation would be based on entirely different methods (and conversely, when evaluation itself just used a review of engineering calculations, it may not have been appropriate or accurate. Assuming that the M&V protocols and guidelines have significant value, there should be synergistic ways to incorporate the knowledge from M&V into impact evaluation. M&V cannot replace evaluation, but it can and should be a component of it when M&V is based on sound, data-driven approaches, especially measured impacts at the meter. The development of Appendix D, and/or another project, should provide a regional approach for how M&V and evaluation can complement each other.
Second, there are budgets for a small variety of tools. However, the budget for features that calculators may often have in common with each other, and which may feed other tools (such as ProCost) seems thin. There is a budget of $27,500 to “Develop template, standards, & guidelines for RTF calculators.” If agreement on the standards and guidelines is instantly reached by the interested parties, and reviews of the completed work result in immediate approval, this budget may be sufficient. Note that this work should dovetail with other things such as the “Guidelines for the Development AND Maintenance of RTF Savings Estimation Methods” and ProCost, and output fields and formats should facilitate incorporation into EE Central. It seems odd that there is a separate budget of $14,000 to “Develop Conservation Load Shape Calculator Tool” unless there is specific intent to include this in the RTF calculator template.
There is not any budget for developing calculators based on developed protocols, but there is a line item to “Review High-Priority New Standard Protocols with Calculators,” which “Assumes proposers do most development work. Proposals come to RTF well-crafted.” For that to happen, the calculator “template, standards, & guidelines” must be solid and complete, so the budget must not be too thin.
Also, some calculators should be developed to test the template, but since there are no line items for protocol or calculator development, this can only happen over time.
Comments from Bonneville
Thank you for the opportunity to comment on the 2012 RTF work plan. We feel that this early engagement from regional stakeholders will result in a work plan that will provide even greater value to those throughout the region. Publicly posting this work plan for ongoing review would be beneficial as time passes, to keep regional stakeholders engaged and to re-prioritize research tasks as needed. The following are our specific comments broken out by the work plan categories:
Existing Measure Review & Updates
The detailed list within this category does not make a reference to transitioning measures to small savers. Given that the region has not yet pursued this path and does not yet understand the work that is needed to achieve this status, it would be helpful for the RTF to set aside some funding to take a first run at transitioning some measures identified as qualified candidates to small saver status. In addition, we want to make sure that some of the measures that were already voted as out of compliance are included in lists of measures to be worked on. Generally, we felt that this portion of the budget may be light, especially in 2012.
New Measure Development & Review of Unsolicited Proposals
It is difficult to have an understanding of what amount of funding is needed for the review and development of new measures and protocols is without having knowledge of what planned measures and protocols are likely to be brought to the RTF in 2012. Each utility is likely to have their own set of measures that are planning to take to the RTF, as well as work being developed by the RTF. It would be helpful to gather information from utilities to see how many and what kind of measures and/or protocols are planned on being taken to the RTF in 2012. This way, we can more accurately estimate the amount of funding needed for that task, as well as get a regional understanding of what is likely to come through the pipeline for utility planning purposes. BPA is currently working on a full list of items that might come before the RTF, but currently our list includes: Engine block heaters, Phase II green motors, VFD calculator, Res LEDs. Other measures may come through the E3T program.
What is the difference between ‘unsolicited New’ and ‘high-priority new’? Between those 2, the work plan is estimating that they will review 12 sets of UES or protocol measures.
The current work plan includes $84,000 to review standard protocols with calculators, estimated at 4 protocols. This number clearly expects that the protocols will come to the RTF and only need review. Yet, it is our understanding that the RTF has planned and is planning on developing protocols (e.g., lighting, fan vfds). Where is the line-item for protocol development? This also assumes that utilities will be the regional bodies bringing protocols to the RTF, something which we have not seen happen at a pace of 4 per year. We think some additional opportunities exist for protocol development in commercial HVAC and commercial envelope and commercial new construction.
Also, what type of measures or measure development work is included in the $72,000 for small/rural utility measures. Given the results of the Ecotope report and minimal recommendations that were applicable to the RTF, this amount of money seems high.
Tool Development
BPA strongly supports the update and adaption of ProCost to EE Central. This work is critical to getting all RTF approved measures calculated correctly and uploaded into the regional reporting system. Once these major changes are completed, it is likely that a smaller amount of funding will be needed in 2013 and 2014 to continue to maintain the updated tool.
Comments from Graham Parker
On the Work Plan, pages 2 and 3 where there is a bullet list. Recommend adding an additional bullet:
- Perform independent, 3rd party, review of all savings measures spreadsheets.
This task will ensure that these sometimes very complicated spreadsheets are of the highest quality and provide output that can be relied on by those who are using the spreadsheets to make economic and policy decisions.
Comments from Nicholas O'Neil
I didn’t quite understand the doubling of budget for RTF staff time in 2012 (from 240k to 480k) with the addition of 1.0 FTE, and a comparable increase again in 2013 (from 480k to 600k) with the addition of 0.5 FTE. Maybe it was just written in a way that made it sound like this was the primary reason. But when you dig into the numbers, it’s really because the council staff in-kind contribution is dropping significantly (around $70k worth from 2012-2013) while contract management by RTF staff is increasing. So I would opt to link this together more: that the increase is primarily because of more contract management and regional coordination, coupled with a reduction in council contribution time. At least, according to the budget, those areas see the largest fluctuations in funding from 2011-2013.
Although it may be assumed under database support, I didn’t see anything in the breakdown that calls out support for EE central (the new PTR). But maybe this is being solely managed by BPA now?
All the website development/maintenance appears in council staff time. The improvements made over the past year have been significant and incredibly valuable, and with the ongoing UES and protocol development work it will be important to keep this updated. Minor revisions will also likely emerge. Are we sure this should all be done by council staff time vs. allocating a small portion of RTF funding to it?
If you add up the new UES, new protocol development, updating existing UES estimates, and converting calculators to deemed, we’re looking at 4 approvals per meeting if we have 10 meetings a year. This seems incredibly aggressive given all the other non-measure specific work that is talked about at the RTF and our rate of approving things in the past on a first go-around. Unless there is an assumption that a lot more sub-committee work will happen than is previously going on, I think we might be expecting to get through more than we can handle. Maybe now that the guidelines are finalized and the other large RFP’s dealing with measure analysis will be completed by 2012, we’ll process UES and protocols faster than before. After 2012 we can see if this held up and adjust the expectations further. But it seems very aggressive to me.
Do we expect to update Procost and SEEM each year? Or just make minor modifications? I can agree on the funding needed for this effort, but expect that it’s perhaps a lower amount after it’s updated in 2012, rather than the proposed constant funding of 100k each year after the initial 134k effort.
Are we duplicating efforts if we’re spending funding to convert ELCAP data to a new format, and then going out to get more end-use load data in the near term? Also, in the previous 2011 workplan we assumed 300k for the development of an end-use load study in 2012 (related to study design, and not meant to capture costs related to actual data collection in the field) but that appears absent in this version. Have we dropped this from the list?