Appendix A. Review of DEER and Non-DEER Energy Saving Estimates...

This appendix is provided as supplementary information on the methodology used to review DEER and Non-DEER energy savings estimates provided by the utilities. In addition, it provides summary findings from the review of those savings estimates across all of the utilities.

Review of DEER Energy Savings Estimates

The information provided in the "measure lists" of the workbooks filed by the utilities on June 1, 2005, were used to identify the source for estimating per unit energy savings. For most of the utilities, only a small portion of their savings, in their primary fuel type, were estimated with reference to DEER (Table 62).

Table 62. Statewide - DEER Energy Savings Estimates

IOU	Number of Measures	% of Measures	Percent of IOU Savings
			kWh	Therms	kW
PGE	123	22%	43%	12%	35%
SCG	16	7%	85%	12%	68%
SDG&E	148	26%	51%	7%	45%
SCE	352	17%	15%		27%

All of the measures that were estimated using DEER were reviewed for accuracy and consistency with the DEER 2005 Database. The DEER data was downloaded format from http://www.rtf.nwppc.org/deer2005/# on May 13, 2005.

In the "measure list" tables of the utility workbooks, the "Measure ID" was typically a match with the "RUNID" field in the DEER data. In some cases averages across the DEER "Measure ID" were used instead of the more specific "RUN ID". Comparisons of the utility estimate and DEER estimate were made based on the information available in the filed workbooks. For example, if the utility noted that they used an average for all DEER refrigerators, the evaluation team attempted to replicate their calculations for a valid comparison.

The majority of the energy savings that were estimated with DEER, do logically match with the DEER database. Based on the available information, it looks like the utilities as a whole have been more conservative than DEER in estimating their kWh savings, but given the uncertainty in some of the relationships of the utilities' per unit savings estimates with those in DEER it is difficult to say.

Table 63. Statewide - Result of DEER Measure Savings Estimate Review (kWh)

Utility Over/Under Estimated	Reason for Difference with DEER	Net Energy Savings (kWh)	% of Portfolio Savings	DEER Estimated Savings (kWh)	% Difference
-	OK	1,540,841,755	21.1%	1,540,841,755	0.0%
- Total		1,540,841,755	21.1%	1,540,841,755	0.0%
Over	Close Enough	385,435,432	5.3%	377,904,504	2.0%
	Not Above Code	23,983,645	0.3%	4,327,667	454.2%
	Not Clear	76,974,172	1.1%	54,272,348	41.8%
	Not in DEER	560,510	0.0%	0	100.0%
	OK	8,915,772	0.1%	8,915,761	0.0%
	Not Above Code and Units*	494,734	0.0%	-5,192,750	-109.5%
Over Total		496,364,265	6.8%	440,227,531	12.8%
Under	Close Enough	22,796,430	0.3%	24,113,291	-5.5%
	Not Clear	79,431,753	1.1%	285,747,945	-72.2%
	OK	65,586,887	0.9%	65,587,275	0.0%
	Program Savings Estimate	29,412,654	0.4%	1,740,909,429	-98.3%
	Units	26,762,872	0.4%	1,129,679,498	-97.6%
Under Total		223,990,597	3.1%	3,246,037,438	-93.1%
Grand Total		2,261,196,618	30.9%	5,227,106,725	-56.7%

% Difference = [Utility - DEER] / DEER Estimate

Net Energy Savings = Utility Estimate * NTG * Number of Units Installed 2006-2008

DEER Estimated Savings = DEER Estimate * NTG * Number of Units Installed 2006-2008

*Three window measures cited by SCE showed negative kWh savings in DEER, there also appeared to be a problem with the comparability of units from SCE's workbook and DEER.

Only 11 percent of the statewide IOU portfolio's therm savings were estimated using DEER. A little over half of them were overestimated and a little under half were underestimated compared to DEER, and had unclear relationships to DEER or the utility and DEER units were not comparable.

Table 64. Statewide - Result of DEER Measure Savings Estimate Review (Therms)

Utility Over/Under Estimated	Reason for Difference with DEER	Net Energy Savings (Therms)	% of Total Portfolio Savings	DEER Estimated Energy Savings (Therms)	% Difference
-	OK	539,878	0.5%	539,878	0.0%
- Total		539,878	0.5%	539,878	0.0%
Over	Not Clear	6,310,023	6.0%	4,678,809	34.9%
	Not in DEER	673,675	0.6%	0
Over Total		6,983,698	6.6%	4,678,809	49.3%
Under	Close Enough	540	0.0%	564	-4.3%
	No Utility Estimate	0	0.0%	77,744	-100.0%
	Not Clear	147,157	0.1%	78,658,192	-99.8%
	OK	46,716	0.0%	46,770	-0.1%
	Units	4,283,223	4.1%	320,029,534	-98.7%
Under Total		4,477,636	4.2%	398,812,804	-98.9%
Grand Total		12,001,212	11.4%	404,031,491	-97.0%

For the kW savings, about 31 percent of the portfolio's demand savings claimed to be estimated using DEER. Unfortunately, the majority of these demand savings estimates did not have a clear relationship with DEER.

Table 65. Statewide - Result of DEER Measure Savings Estimate Review (kW)

Utility Over/Under Estimated	Reason for Difference with DEER	Net Energy Savings (kW)	% of Total Portfolio Savings	DEER Estimated Energy Savings (kW)	% Difference
-	OK	109,766	4.8%	109,766	0.0%
- Total		109,766	4.8%	109,766	0.0%
Over	Close Enough	1,648	0.1%	1,628	1.2%
	Not Above Code	8,225	0.4%	1,722	377.5%
	Not Clear	531,202	23.5%	176,584	200.8%
	Not in DEER	6,053	0.3%	0	100.0%
	Units	7	0.0%	1	616.5%
Over Total		547,134	24.2%	179,935	204.1%
Under	Close Enough	2,345	0.1%	2,351	-0.2%
	No Utility Estimate	51	0.0%	215,842	-100.0%
	Not Above Code	275	0.0%	4,709	-94.2%
	Not Clear	28,059	1.2%	423,404	-93.4%
	Units	12,537	0.6%	1,281,813	-99.0%
Under Total		43,268	1.9%	1,928,119	-97.8%
Grand Total		700,168	30.9%	2,217,820	-68.4%

Review of Non-DEER Energy Savings Estimates

The information provided in the "measure lists" of the workbooks filed by the utilities on June 1, 2005, were used to identify the source for estimating per unit energy savings. For most of the utilities, the majority of their savings in their primary fuel type were estimated without reference to DEER (see Table 66). In some cases, independent engineering evaluation or other reference documents were cited. All estimates that were not related to DEER were supposed to be documented in "workpapers" filed by each utility and should have been easily referenced for measure review. Unfortunately, it was these estimates were not clearly linked to documentation, and in reviewing the documentation, the savings calculations and assumptions used for these energy savings estimates were difficult to decipher, even with the provision of additional documentation from the utilities.

Table 66. Statewide - Non-DEER Energy Savings Estimates

IOU	Number of Measures	% of Measures	Percent of IOU Savings
			kWh	Therms	kW
PGE	441	78%	57%	88%	65%
SCG	217	93%	15%	88%	32%
SDG&E	431	74%	49%	93%	55%
SCE	1,670	83%	85%		73%

In lieu of reviewing all of the measures that were not DEER related, the team reviewed a portion of measures that made up the bulk of the remaining energy savings not accounted for with DEER. For example, of PGE's total estimated energy savings (based on the measure list data) 43 percent of the kWh savings were based on DEER estimates, while 57 percent of the kWh savings were not related to DEER. For the review of the Non-DEER estimates, we selected measures that represented 47 percent of the total energy savings, adding that to the 43 percent of DEER estimates, we attempted to review 90 percent of the portfolio's energy savings estimates.

Since the measure names are very specific for most of the utilities, this methodology had the effect of identifying multiple measures that individually to not make large contributions to the portfolio, or they cover a wide range of measures in a specific program. For example, "Lighting" or "HVAC" in the Standard Performance Contract program. This presents the additional problem of the difficulty of reviewing a "measure" that actually represents a whole program. Residential measures are also less likely to show up in this list, because of their small individual contributions to the portfolio's savings. Regardless, this review of measures still covers the bulk of the energy savings found in the portfolio.

The measures were organized by measure name and sorted by their percent contribution to the total portfolio, the workpapers were identified, and reviewed. In Figure 1, a high level review of the Non-DEER measure estimates is presented, by utility and general accuracy of the estimate. In cases where the documentation was not available, measure savings were categorized as "No Documentation". Measures savings estimates that appeared "Reasonable" were based on review of the available documentation and the experience of the evaluation team reviewers. Similarly measure savings estimates that caused "Concerns" were based on review of the available documentation and the experience of the evaluation team reviewers.

Figure 1. Statewide - Overview of Non-DEER Energy Savings Estimates

Since therm savings (shown in gray) were most commonly not estimated using DEER, these savings still make up a substantial savings that come under question. Several utilities still present concerns with how they estimated their kWh savings, either because of a lack of documentation or the clarity of the assumptions or calculations used.

Review of the measures that represented specific concerns are noted in Table 67.

Table 67. Statewide - Comments on Measures that Present Concern

Utility	Energy Type	Measure Name	Program	Workpaper Citation	Comments
SCG	kWh	316009-Single Family, Maximum Cooling Capacity, CZ 10	EED4-Advanced Home Program	See "Advanced Home Workpapers.xls" and "Advanced Home Measure Potential Study.doc"	As stated in workpapers, maximum sizing calculation is required by Title 24; how is this measure proposing to do better than what is required and for what amount of savings?
SCG	kWh	316012-Single Family, Maximum Cooling Capacity, CZ 15	EED4-Advanced Home Program	See "Advanced Home Workpapers.xls" and "Advanced Home Measure Potential Study.doc"	As stated in workpapers, sizing, duct sealing required by Title 24; no program reportable savings
SCG	Therm	312015-Gas Wtr Htr and/or Boiler Controller Digital Graphing (>= 20 units)	MFR4-Multi-Family Rebate Program	See Excel workbook "MFRCPNov26.xls".	I reviewed the Excel file and could not find the measure
SCG	Therm	312014-Gas Wtr Htr and/or Boiler Controller Non-Digital Graphing (>= 20 units)	MFR4-Multi-Family Rebate Program	See Excel workbook "MFRCPNov26.xls".	I reviewed the Excel file and could not find the measure
SDGE	kWh	234067-Refrigeration - Food Service -Auto Closer for Main Cooler Doors And 234068-Refrigeration - Food Service -Auto Closer for Main Freezer Doors	SBS-Small Business Super Saver	See "Express and SBS Workpapers.pdf" Page Exp-146	This measure has concerns: 1) The savings calculation for closers uses an ASHRAE base case that is impractically high. 2) Average walk-in may not have sufficient capacity to meet the calculated additional load, thus over-predicting energy use. 3) The door open fraction time was assumed to be 25% of the not-in-use hours, with no study references; this is greater than casual observations and experience would indicate; it is also greater than the 3 hours referred to for the strip curtains measure and extended periods of open door operation would result in a frosted over evaporator coil, resulting in less not greater consumption. Many freezers have door switches which inhibit the refrigeration unit from operating when the door is open, and supermarkets often have temperature alarms that indirectly indicate a door has been left open. M&V is needed to establish actual savings, if any, for this measure.
SDGE	kWh	234071-Refrigeration - Glass or Acrylic Doors-Medium Temperature Case	SBS-Small Business Super Saver	See "Express and SBS Workpapers.pdf" Page Exp-122	This measure has concerns: 1) The assumptions used for the display case load reduction calculations are not referenced. 2) The load used for one display case base is the manufacturers design load value used for selecting compressors; the actual average hourly load seen by the compressors will be less. 3) A 5,700 EFLH assumption is used; this value is not documented with a reference and will vary greatly based upon store location, refrigeration equipment mix and controls. Similarly, the compressor power assumption uses 95 F condensing, whereas this will also very by location, refrigeration equipment and controls. 4) The analysis does not address other equipment changes that may be required to implement this equipment measure to get a resultant compressor power reduction; other system components and controls may have a very large influence on actual savings. M&V is needed to establish actual typical savings.
PGE	Therm	Water Ht/Furnace/Boiler-NC-G Process-NC-G HVAC/AC-NC-G	AG & FOOD PROCESS FAB PRO H IND AG & FOOD PROCESS	2006-2008 Calculated Workpapers.xls	This measure has the following concerns: 1) The workpapers state "DOE2 computer simulation if applicable, or project specific engineering analysis is used for New Construction projects." No additional documentation is supplied. 2) It is expected, however, that these measures are part of the statewide Saving By Design (SBD) Program and will follow the same savings calculation requirements as outlined in the other IOU filings. However, none of the IOU filings have specific documentation on a "process" measure for SBD and how savings calculation will be done. 3) More specific documentation is needed on "project specific engineering analysis is used for New Construction projects."
PGE	Therm	Process-RETRO-G HVAC/AC-RETRO-G Water Ht/Furnace/Boiler-RETRO-G Water	AG & FOOD PROCESS FAB PRO H IND AG & FOOD PROCESS	2006-2008 Calculated Workpapers.xls	This measure has the following concerns: The workpapers state "For retrofit projects, PG&E provides estimating software that calculates energy savings based on site-specific information, or, if not applicable, other accepted engineering calculation procedures are used." Review of the SPC estimating software seems to indicate that incentives are calculated based upon modified assumptions and methods from the Express Efficiency workpapers; however, no documentation could be located that explains how the software does its calculations or how the Express Efficiency workpapers' methods may have been enhanced or augmented.
PGE	Therm	Duct Test and Sealing CZs 2, 4, 11, 12 & 13	Mass Market	2006-2008 residential deemed measure workpapers.xls	Use of DEER is reasonable, but assumption to target 150% of DEER savings is not reasonable: DEER assumption is for leakage (36% total leakage to outside - equiv. to about 54% total leakage) more than 150% higher than LBNL reported average leakage in CA homes (Sherman 2001/Jump 1998, 22% total leakage to outside with ~32% total leakage) with leakage reduced by two-thirds by DEER EEM; it is not explained how the program could target homes with 225% of the average leakage and seal 80% of all leaks in those homes - that level of average leakage reduction has not been shown to be possible even if these 225% of average cases could be identified. This issue is common throughout all the IOU filings for duct sealing measures and may overestimate savings by as much as a factor of two. Note that utility programs report total leakage measurements before and after sealing; the important measurement is total leakage to outside which LNBL reports, for CA homes, averages between 66% and 75% of total leakage, thus programs need to begin requiring the measurement of this more meaningful data. It is noted that other similar measures within PG&E and other IOU portfolios use a cooling savings percentage of 18% for this measure, based upon older studies; it should be noted that most of those studies perform duct sealing and insulation and the citations are using the these combined savings reported for short term measurements or are estimated not measured. M&V work is needed to better establish the typical leakage to outside before/after conditions and energy savings for this measure.
PGE	Therm	Gas Furnace - 90 AFUE	Mass Market	2006-2008 residential deemed measure workpapers.xls	This measure has the following concerns: 1) For "Energy Star Gas Furnaces with 90 AFUE": source of the assumptions for PG&E's UEC of 388 therms is not documented. 2) DEER is referenced, but this value cannot be duplicated from citation and appears high compared to DEER reference. 3) Calculation is not clearly outlined by formula and seems to contain algebraic errors; unable to duplicate the value. 4) IMC of $716 may be low; $1,000 may be closer for current units and if an acid-proof flue and condensate line installation is needed. 5) "Variable Speed (VS) motor for furnace" studies cited to obtain a differential kW are not for similar units and may not be comparable for variable speed savings calculations. 6) The calculation uses the peak watts differential as the basis of savings. This peak wattage differential may be a by-product of the SEER 14 vs. SEER 16 rating of the different units, not the use of a VS motor and does not capture any effect of the VS operation of the motor in the calculation. 7) The hours of cooling operation and hours of heating operation are not documented and will vary by climate. 8) IMC of $120 may not reflect current unit pricing differential; $1,000 may be a more appropriate value.
PGE	Therm	Process Boiler - Steam	Mass Market	Non-Residential Workpapers.doc	No documentation on savings calculation methods; GAS WP.doc states " Measure data for cost effectiveness modeling have been developed based on average characteristics among customer participants in the SoCalGas Process Energy Consumption boiler measure (those units with efficiencies of 82+%) during PY 2001." No further documentation, references, calculation methods or data are provided.
PGE	kWh	Process-RETRO-E	AG & FOOD PROCESS FAB PRO H IND HI-TECH F	2006-2008 Calculated Workpapers.xls	This measure has the following concerns: The workpapers state "For retrofit projects, PG&E provides estimating software that calculates energy savings based on site-specific information, or, if not applicable, other accepted engineering calculational procedures are used." Review of the SPC estimating software seems to indicate that incentives are calculated based upon modified assumptions and methods from the Express Efficiency workpapers; however, no documentation could be located that explains how the software does its calculations or how the express efficiency workpapers' methods may have been enhanced or augmented.
PGE	kWh	VSDs for HVAC Fans - 100 hp maximum	Mass Market	Non-Residential Workpapers.doc	This measure has the following concerns: 1) the calculation approach does not account for a wide range of building load profiles and their climate specific variation; 2) average fan power used may not represent current typical case; 3) average flow used may not represent current typical case; 4) factors used in the calculation, from 1991 study that is not supplied, may not be appropriate for current application; and 5) a more rigorous analysis should be performed using more current data, software and techniques.
PGE	kWh	Lighting-NC-E Lighting Controls-NC-E HVAC/AC-NC-E Refrigeration/ Appliances-NC-E Bldg Envelope-NC-E	AG & FOOD PROCESS FAB PRO H IND HI-TECH F LODGING F MEDICAL F OFFICE B RETAIL ST SCH & COLL	2006-2008 Calculated Workpapers.xls	This measure has the following concerns: 1) The workpapers state "DOE2 computer simulation if applicable, or project specific engineering analysis is used for New Construction projects." No additional documentation is supplied. 2) It is expected, however, that these measures are part of the statewide Saving By Design Program and will follow the same savings calculation requirements as outlined in the other IOU filings; if that is the case than there are no concerns on these measures; if that is not the case, further review may be needed.
PGE	kWh	HVAC/AC-RETRO-E	AG & FOOD PROCESS FAB PRO H IND HI-TECH F LODGING F MEDICAL F OFFICE B RETAIL ST SCH & COLL	2006-2008 Calculated Workpapers.xls	This measure has the following concerns: 1) The workpapers state "For retrofit projects, PG&E provides estimating software that calculates energy savings based on site-specific information, or, if not applicable, other accepted engineering calculation procedures are used." Review of the SPC estimating software seems to indicate that incentives are calculated based upon modified assumptions and methods from the Express efficiency workpapers; however, no documentation could be located that explains how the software does its calculations or how the express efficiency workpapers methods may have been enhanced or augmented. 2) The specific concerns outlined below are an example of the problems seen with the Express Efficiency methods used; an initial review of other HVAC EEMs raises similar concerns not listed here. 3) The assumptions for the base and retrofit HVAC system (such as DX AC units and chillers) kW used to calculate the reduction in HVAC system demand, the operating hours used to estimate kWh reduction, and the coincident adjustment factors may not be appropriate. 4) The kW reduction calculation is of the form (kWr-kWb)* CDF, where: kWb and kWr are the base and retrofit system kW, and CDF is a coincident diversity factor. The energy savings calculation takes the form of (kW1-kW2)*EFLCH, where: kW1 and kW2 are as just mentioned and EFLCH is an equivalent full load cooling hours. The base system kWb and kWr used to calculate the reduction in HVAC system kW are based upon a ARI rated performance and do not take into account the wide variation in peak demand conditions in different climate zones. 5) The CDF alone is not a sufficient multiplier to adjust the rated kW for peak conditions at the selected location. 6) The coincident factors are also based upon old data that may not be representative of current building load profiles; the coincident factors are based on pre-1990 survey, not measurement with minor adjustments from very small sample telephone interviews. 7) If CDF in the SPC software are being modified by location, as they should, there is no documentation on how this was done and the source of the data. The equivalent full load cooling hours assumptions used do not seem to take into account climate variation. The EFLCH, instead, are based upon older data from the 1990's that may over- or under-estimate hours of use depending on the building type. If EFLCH in the SPC software are being modified by location and using the users specified operating hours, as they should, there is no documentation on how this was done and the source of the data. 8) A more rigorous analysis should be undertaken, based on current/future field monitoring M&V work, to update these values or base the SPC and express efficiency savings on a more accepted approach to calculations for the measures.
PGE	kWh	Process-NC-E	AG & FOOD PROCESS FAB PRO H IND HI-TECH F	2006-2008 Calculated Workpapers.xls	This measure has the following concerns: 1) The workpapers state "DOE2 computer simulation if applicable, or project specific engineering analysis is used for New Construction projects." No additional documentation is supplied. 2) It is expected, however, that these measures are part of the statewide Saving By Design (SBD) Program and will follow the same savings calculation requirements as outlined in the other IOU filings. However, none of the IOU filings have specific documentation on a "process" measure for SBD and how savings calculation will be done. 3) More specific documentation is needed on "project specific engineering analysis is used for New Construction projects."
PGE	kWh	Lighting-RETRO-E	AG & FOOD PROCESS FAB PRO H IND HI-TECH F LODGING F MEDICAL F OFFICE B RETAIL ST SCH & COLL	2006-2008 Calculated Workpapers.xls	This measure has the following concerns: 1) The workpapers state "For retrofit projects, PG&E provides estimating software that calculates energy savings based on site-specific information, or, if not applicable, other accepted engineering calculational procedures are used." Review of the SPC estimating software seems to indicate that incentives are calculated based upon assumptions and methods from the Express Efficiency workpapers. The assumptions for the base lighting system used to calculate the reduction in lighting system power, the operating hours used to estimate kWh reduction, and the coincident and interactive adjustment factors may not be appropriate as they are based on out-of-date data. 2) The kW reduction calculation is of the form (kWr-kWb)*DIE*CDF, where: kWb and kWr are the base and retrofit fixture powers, DIE is a demand interactive effects factor and CDF is a coincident diversity factor. The energy savings calculation takes the form of (kW1-kW2)*EIE*AOH, where: kW1 and kW2 are as just mentioned, EIE is a energy interactive effects factor and AOH is an annual operating hours. 3) The base system kWb used to calculate the reduction in lighting system power do not seem to take into account T24 requirements. For example, incandescent lamps and T12 fluorescent lamps with magnetic ballasts are often referred to as the base systems in the workpapers; these base case systems may not correctly account for the Title 24 requirements, that include minimum lamp efficacy and maximum watts/sqft requirements. 4) Title 24 efficacy requirements take effect upon replacement of fixture indoors or outdoors while the more restrictive watts/sqft requirements are triggered upon replacement of 60% or more of the fixtures in a space. It is likely that a significant fraction of all lighting retrofit projects should be using a Title 24 minimum efficacy or watts/sqft as the base rather than the existing customer system or other workpapers noted base systems. 5) The annual hours of operation (AOH) assumptions used do not seem to take into account recent M&V studies results (that were used to update similar calculations for these measures in DEER). The AOH, instead, are based upon older data from the 1990's that may over- or under-estimate hours of use depending on the building type. Additionally, identical AOH assumptions for CFL and non-CFL lighting are used; this is known to be significantly high for occupancy types that are major participants in the program; for example recent CFL studies for hotel rooms, offices and industrial buildings AOL for CFLs are significantly lower than those workpaper values. 6) The coincident and interactive factors are also based upon old data that may not be representative of current building load profiles and HVAC efficiencies; the coincident factors are based on pre-1990 survey, not measurement, data, and the interactive factors are based mostly upon pre-1995 small sample modeling data with minor adjustments from very small sample telephone interviews. 7) All these factors can be strongly dependent on climate; that effect is ignored in the analysis. 8) A more rigorous analysis should be undertaken, based on current/future field monitoring M&V work, to update these values.
PGE	kWh	Refrigeration/ Appliances-RETRO-E	AG & FOOD PROCESS FAB PRO H IND RETAIL ST	2006-2008 Calculated Workpapers.xls	This measure has the following concerns: 1) The workpapers state "For retrofit projects, PG&E provides estimating software that calculates energy savings based on site-specific information, or, if not applicable, other accepted engineering calculational procedures are used." Review of the SPC estimating software seems to indicate that incentives are calculated based upon modified assumptions and methods from the Express Efficiency workpapers; however, no documentation could be located that explains how the software does its calculations or how the Express Efficiency workpapers' methods may have been enhanced or augmented. 2) For specific concerns on a subset of the refrigeration measure calculations used for Express Efficiency and the basis of the SPC software, see comments in this table on: "Strip Curtains for Walk-ins", "Main door Cooler Door Gaskets", "New Refrig Display Case with Doors - Low Temp", "" and "Insulate Bare Suction Pipes."
PGE	kWh	Lighting Controls-RETRO-E	AG & FOOD PROCESS FAB PRO H IND HI-TECH F LODGING F MEDICAL F OFFICE B RETAIL ST SCH & COLL	2006-2008 Calculated Workpapers.xls	This measure has the following concerns: The workpapers state "For retrofit projects, PG&E provides estimating software that calculates energy savings based on site-specific information, or, if not applicable, other accepted engineering calculational procedures are used." Review of the SPC estimating software seems to indicate that incentives are calculated based upon modified assumptions and methods from the Express Efficiency workpapers; however, no documentation could be located that explains how the software does its calculations or how the express efficiency workpapers methods may have been enhanced or augmented.
PGE	kWh	Bldg Envelope-RETRO-E	AG & FOOD PROCESS FAB PRO H IND HI-TECH F LODGING F MEDICAL F OFFICE B RETAIL ST SCH & COLL	2006-2008 Calculated Workpapers.xls	This measure has the following concerns. The workpapers state "For retrofit projects, PG&E provides estimating software that calculates energy savings based on site-specific information, or, if not applicable, other accepted engineering calculational procedures are used." Review of the SPC estimating software seems to indicate that incentives are calculated based upon modified assumptions and methods from the Express Efficiency workpapers; however, no documentation could be located that explains how the software does its calculations or how the express efficiency workpapers methods may have been enhanced or augmented.
PGE	kWh	Strip Curtains for Walk-ins	Mass Market	Non-Residential Workpapers.doc	This measure has concerns: 1) The savings calculations for strip curtains uses an ASHRAE base case known to be impractically high; the methodology is appropriate for an open door with fully developed flow, however, the resulting baseline load is several times larger than any supermarket freezer's design capacity, thus cannot reflect power use. Similarly, the calculated freezer savings is greater than the actual connected compressor kW for an "average" freezer. (Comments are for a typical chain supermarket.) 2) The door open fraction time was assumed to be 3 hours per day, with no study references; this time is greater than experience would indicate and moreover (for freezers in particular) extended periods of open door operation would result in a frosted over evaporator coil, resulting in less, not greater consumption. Many freezers have door switches which inhibit the refrigeration unit from operating when the door is open, and supermarkets often have temperature alarms that indirectly indicate a door has been left open. 3) The number of doors to be retrofitted with strip curtains appears to be several thousand across the IOUs whereas most chains and warehouses have specified strip curtains for many years, the number of doors available for retrofit may be lower. 4) This measure could often be used inappropriately to fund normal maintenance replacements due to wear and tear or intentional damage; the program materials don't preclude replacement of a previously installed, but removed, strip curtain. M&V is needed to establish actual savings and use patterns as well as free-ridership.

Utility	Energy Type	Measure Name	Program	Comments
SCE	kWh	Main door Cooler Door Gaskets (Walk-in) And Main Door Freezer Door Gaskets( Walk-in)	Non-Residential Business Installation And Business Incentive Program	This measure has concerns: 1) The savings calculations for gaskets uses an ASHRAE base case that is impractically high; while the calculation method appears valid for a fully open door, the key assumption for this measure - 3% of open door losses - is not referenced and requires further justification. 2) This measure proposes to provide a rebate for a "standard practice" maintenance item; door gaskets have a long life and often air leakage may result from misalignment or door damage caused by material handling equipment. Due to the frost and condensation that results from leaking doors, repairs are often made as part of routine maintenance or for safety reasons, resulting in a very high free rider faction or abuse of this measure. 2) The incremental cost does not appear to include the labor necessary to identify the select leaking doors, procure appropriate gaskets on a door-by-door basis, and install correctly - which often requires other repairs and alignment. M&V is needed to establish free-ridership, fraction of replacements that actually reduce consumption, and actual savings.
SCE	kWh	Exterior Fixture 65 Watt 3,600 to 4,599 Lumens Interior Fixture 30 Watt 2,000 to 2,599 Lumens	Residential EE Rebates	This measure has the following concerns: 1) No documentation on calculation of specific savings listed for this measure - just a narrative without formulas or calculation sequence used to produce this specific savings value. We cannot reproduce the number. 2) Replacement and new fixture is subject to new Title 24 minimum requirements for certain locations inside/outside the home. It does not appear this measure takes into account those minimums. Statement that "Those applications that require a building permit would not qualify as a retrofit under this program." Is not reasonable, since all lighting retrofits, other than lamp replacement/de-lamping, require a permit.
SCE	kWh	ES Exterior Fluorescent Fixtures 13 Watt	Multifamily EE Rebates	This measure has the following concerns: replacement and new fixture is subject to new Title 24 minimum requirements for certain locations inside/outside the home. It does not appear this measure takes into account those minimums. Statement that "Those applications that require a building permit would not qualify as a retrofit under this program." Is not reasonable, since all lighting retrofits, other than lamp replacement/de-lamping, require a permit.
SCE	kWh	Dimmable Interior Fluorescent Fixtures And Interior Fixture 40 Watt 2,000 to 2,599 Lumens	Residential EE Rebates	This measure has the following concerns: replacement and new fixture is subject to new Title 24 minimum requirements for certain locations inside/outside the home. It does not appear this measure takes into account those minimums. Statement that "Those applications that require a building permit would not qualify as a retrofit under this program." Is not reasonable, since all lighting retrofits, other than lamp replacement/de-lamping, require a permit.
SCE	kWh	Correct refrigerant charge and air flow (appears as several measures)	Comprehensive HVAC	This measure has the following concerns:: 1) refrigerant charge or TXVs are required by Title 24 in some CTZ's upon AC installation; this EEM should not be available for homes when required by Title 24. 2) Approach is reasonable but we have concerns about assumptions. This measure appears in many IOU filings and as multiple measures within each IOU filing, using different assumptions and calculation approaches. 3) Some cite Mowris & Associates older studies or other studies, which reported up to 18% EER improvements and 12.7% kW reductions, but recent studies show these values may overstate annual energy (due to short-term monitoring) and peak demand savings; current values of 7%, as used by PG&E for this measure, are more in agreement with current M&V work (but values will vary greatly by site.) Thus PG&E's kWh values for the RC measures look reasonable, but the other utility values may need to be reduced by 45%. 4) For residential kW savings, PG&E (and other IOUs) did not apply a "coincident diversity factor" to the peak unit kW/ton values or adjust the kW reduction to account for location having different peak conditions that the unit rated kW. The diversity factor accounts for the fraction of residential units that are not on during the IOU peak demand period and should additionally be adjusted (for this measure) to include climate effects; this factor could be set to between 50-80%, depending upon the climate zone for both climate and occupancy. Thus ,kW impacts should be reduced. SCE responded for residential programs: "RASS thermostats "off" percentages ... during the daytime hours for the combined CZ 14 and 15 is only 14%. Thus, the number of AC units that would be "on" during the on-peak would be closer to 86% and not 50%." Response to SCE comment: The RASS data provides "typical" behavioural data but cannot account for that fraction of empty houses due to alternate behaviour (vacations, shopping, events, etc.) or "off" AC due to other reasons (such as financial).This is why models using the RASS data need to be "calibrated" to billing data with the typical multiplier of 0.5. SCE responded for commercial programs:" Field measurement data from PECI was used to estimate this measure." Response to SCE comment: The document provided does not contain any references to published studies or reports; the northwest "technician" results from "field measurements" are not provided in any detail so as to allow the analysis of the data to determine if it was appropriate to use for the estimation of savings for this measure (by itself) in CA.
SCE	kWh	Single Family - 15%, Inland	CA New Homes	This measure has the following concerns: 1) No adequate documentation. 2) This programs savings analysis, including this measure, was based upon a study that appears to not have taken 2005 Title 24 requirements into account. This appears to have produced savings estimates for items that are required by Title 24. 3) The program proposal is not kWh savings but rather "TDV" savings; this is not directly related to energy but rather an hourly multiplier on energy. SCE responded: "Energy features were added to the base case home to meet ComfortWise standards and exceed 2005 Title 24 by 15%. These above code upgrades included mechanically designed HVAC system per ACCA Manuals J, D and S and stamped by a licensed CA mechanical engineer, tight HVAC ducts as defined by the CEC, 11.0 EER air conditioner, tight air infiltration, quality installation of insulation, and all upgraded features inspected by a HERS certified 3rd party inspector. These features saved 546 source kWh and 0.36 kW per home." Response to SCE comments: correctly sized (ACCA Manuals) HVAC and tight ducts are code requirements; SEER 13 requirement provides a market EER range of 10.75 to 12.50, so perhaps an EER of 12.1 (upper 25%) might be able to be justified as "above code" but not the value proposed; difficult to see much savings, relative to estimate, from the remaining items. TDV savings should not be used.
SCE	kWh	Air Source Unitary Air Conditioner Split or Packaged (10 variations of this measure appear for different size single/three phase units and levels of efficiency improvement)	Comprehensive HVAC	This measure has the following concerns about assumptions: 1) This measure references DEER as a base value, then applies an adjustment value, but it is not documented how the adjustment value was calculated. 2) Similar measures for the upstream HVAC for all the IOUs use a different calculation methodology that also has assumptions that concerns us: those assumptions seem to have high full load equivalent hours of operation values and diversity factors that are based upon old data and may substantially over estimate energy and demand impacts. SCE responded: "Once DEER values are available for this category, they will be used." Response to SCE comment: This value seems to be an acceptable "place holder" until the DEER values is available in August '05.
SCE	kWh	Auto-closer for Glass Doors for Walk-In Coolers	Non-Residential Business Installation	This measure has concerns: 1) The savings calculations for closers starts an ASHRAE base case that is impractically high. 2) Average walk-in may not have sufficient capacity to meet the calculated additional load, thus over-predicting energy use. 3) The door open fraction time was assumed to be 25% of the not-in-use hours, with no study references; this is greater than casual observations and experience would indicate; it is also greater than the 3 hours referred to for the strip curtains measure and extended periods of open door operation would result in a frosted over evaporator coil, resulting in less not greater consumption. Many freezers have door switches which inhibit the refrigeration unit from operating when the door is open, and supermarkets often have temperature alarms that indirectly indicate a door has been left open. M&V is needed to establish actual savings, if any, for this measure.
SCE	kWh	Infiltration Barrier for Walk-ins (strip curtains) And Strip Curtains	Non-Residential Business Installation And Business Incentive Program	This measure has concerns: 1) The savings calculations for strip curtains uses an ASHRAE base case known to be impractically high; the methodology is appropriate for an open door with fully developed flow, however, the resulting baseline load is several times larger than any supermarket freezer's design capacity, thus cannot reflect power use. Similarly, the calculated freezer savings is greater than the actual connected compressor kW for an "average" freezer. (Comments are for a typical chain supermarket.) 2) The door open fraction time was assumed to be 3 hours per day, with no study references; this time is greater than experience would indicate and moreover (for freezers in particular) extended periods of open door operation would result in a frosted over evaporator coil, resulting in less, not greater consumption. Many freezers have door switches which inhibit the refrigeration unit from operating when the door is open, and supermarkets often have temperature alarms that indirectly indicate a door has been left open. 3) The number of doors to be retrofitted with strip curtains appears to be several thousand across the IOUs whereas most chains and warehouses have specified strip curtains for many years, the number of doors available for retrofit may be lower. 4) This measure could often be used inappropriately to fund normal maintenance replacements due to wear and tear or intentional damage; the program materials don't preclude replacement of a previously installed, but removed, strip curtain. M&V is needed to establish actual savings and use patterns as well as free-ridership.
SCE	kWh	Variable Frequency Drives for HVAC Fans	Business Incentive Program	This measure has the following concerns: 1) the calculation approach does not account for a wide range of building load profiles and their climate specific variation; 2) average fan power used may not represent current typical case; 3) average flow used may not represent current typical case; 4) factors used in calculation, from 1991 study that is not supplied, may not be appropriate for current application; 5) a more rigorous analysis should be performed using more current data, software and techniques.
SCE	kWh	Attic & Wall Insulation - Quality Installation (appears several times)	CA New Homes	This measure has the following concerns: 1) not clear how this exceeds Title 24, or 2) how estimation of savings is for above the code requirements. SCE responded: "As described in the Program Implementation Plan, the application of this measure is not designed to exceed T-24. It is designed to improve the rate of compliance with the requirements of the code through a quality control inspection. Improved compliance will produce a greater number of quality installations and thus increased savings." SCE's response confirms that there is not "above code" savings; this appears to be a "code enforcement" program.
SCE	kWh	New Refrig Display Case with Doors - Low Temp	Business Incentive Program	This measure has concerns: 1) The assumptions used for the display case load reduction calculations are not referenced. 2) The load used for one display case base is the manufacturers design load value used for selecting compressors; the actual average hourly load seen by the compressors will be less. 3) A 5,700 EFLH assumption is used; this value is not documented with a reference and will vary greatly based upon store location, refrigeration equipment mix and controls. Similarly, the compressor power assumption uses 95 F condensing, whereas this will also very by location, refrigeration equipment and controls. 4) The analysis does not address other equipment changes that may be required to implement this equipment measure to get a resultant compressor power reduction; other system components and controls may have a very large influence on actual savings. M&V is needed to establish actual typical savings.
SCE	kWh	Design Assistance	Sustainable Communities	This measure has the following concerns: 1) Documentation is not clear: documentation references the Savings By Design, but it is not clear how this programs savings is calculated or how specific project savings will be calculated and attributed to the actions of this program. SCE responded: "This program offering is a non-traditional approach to the infrastructure opportunities for the new construction of communities. SCE expects that customized calculations will be submitted to the program by participants/consultants over time. The estimated forecast is based on SCE's experience and judgement to establish an initial savings placeholder for future studies and project proposals within this program." SCE's response does not provide any additional information on how this activity will directly result in attributable energy savings and how those savings will be calculated for each project. SCE responded: "This program offering is a non-traditional approach to the infrastruture opportunities for the new construction of communities. SCE expects that customized calculations will be submitted to the program by participants/consultants over time. The estimated forecast is based on SCE's experience and judgement to establish an initial savings placeholder for future studies and project proposals within this program." Comment to SCE response: this still does not offer a explanation of the methods or calculation that will be used to attribute project or activity specific savings for this measure. The methods that will be used to claim specific project savings need to be identified.
SCE	kWh	T-8 or T-5 Lamp and Electronic, 4-foot lamp removed	Multifamily EE Rebates	This measure has the following concerns: No documentation on calculation of specific savings listed for this measure, just a narrative without formulas or calculation sequence used to produce this specific savings value. We cannot reproduce the number. SCE responded: "This measure explicitly targets underground parking garages that require around the clock lighting." SCE's response does not provide a method to verify the savings estimates. SCE response: "This measure explicitly targets underground parking garages that require around the clock lighting." Response to SCE comment: Okay, but the program cannot allow this measure to be used for non-24-hour lighting.
SCE	kWh	T-8 or T-5 Lamp and Electronic, 8-foot lamp removed	Business Incentive Program	This measure has the following concerns: Annual hours of operation for major program participant appears high - offices are 25-30% percent above recent EM&V, and retail are 10-20% above recent EM&V
SCE	kWh	(4) 48" T-12 to (3) 48" T-8 Lamp with Elec. Bal.	Non-Residential Business Installation	This measure has the following concerns: No specific documentation on calculation of specific savings listed for this measure. We cannot reproduce the number - savings is above the range for all building types listed in documentation. SCE responded: "The demand savings (Watts) were obtained from the 1999 Small Business SPC Lighting Tables (Appendix E - Minimum Efficiency Standards). The base fixture was assumed to demand 44 Watts and the new fixture 76 Watts." SCE's response may provide the answer, but the documentation was not provided. Since the Express Efficiency lighting documents are referenced, the concerns outlined in "Lighting-RETRO-E" for PGE (on hours of operation, lighting base case, and other factors) may apply here.
SCE	kWh	Insulate Bare Suction Pipes	Business Incentive Program	This measure has concerns. The method for calculation of heat gain to uninsulated suction lines appears valid, however, the analysis ignores important factors that may invalidate the conclusions on energy savings: 1) If the lines are outside the refrigerated area the suction line heat gain does not change the refrigerant properties or mass flow requirements at the refrigerated space; the effect is not as direct as are gains to a chilled water line. Refrigeration compressor rating conditions are based on a fixed 65 F return gas temperature and neither of the major compressor manufacturers has explicit information on compressor pumping capacity and power as a function of return gas temperature, thus the effect on compressor energy for these suction line gains is not explicitly known. 2) Even with insulation, there is still heat gain, and with long suction lines, the return gas temperature at the compressor may approach the same temperature as an uninsulated line, resulting in the same impact on the compressor; since the suction lines tend to be very long in most commercial refrigeration applications, it is unlikely that there will be very many instances where this measure will produce significant savings. 3) For lines within a conditioned space, the base case assumption of no insulation is a very unlikely case, since suction lines normally have enough insulation to avoid condensation and dripping, both to avoid damage to the structure and for safety reasons. Lines located on roofs that are not insulated were probably originally insulated, but not jacketed, and the rubber insulation deteriorated rapidly with exposure to sunlight; this, then, is a maintenance item. M&V is needed to establish free-ridership, fraction of replacements that actually reduce consumption, and actual savings.