31 March 2015
Brookline Place; 14522
Stationary GHG Sources
Expanded Notice of Project Change (ENPC)
DOER Comments
P Ormond
The DOER recognizes the project for the quality and detail of the information submitted. The
project is also recognized for the numerous energy and GHG reduction measures either adopted
or discussed in the submission.
It is the intent of this review to: (a) ensure that the analysis submitted conforms to the application
of the MEPA GHG Policy and Protocol (the Policy) as have been agreed upon for this project,
and (b) point out potential opportunities for further reductions in both energy usage and GHG
emissions. Where these opportunities appear to exist, these comments also suggest measures
and/or approaches that the DOER hopes will be considered for adoption in achieving further
reductions in both energy and source GHG emissions.
Project Building Data
The following presents project data and benchmark energy use intensity, taken from the United
States Energy Information Agency (US EIA) “Commercial Buildings Energy Consumption
Survey”, table C10, dated 2003, referred to as the “CBEC” benchmark:
Conditioned Space
EUI (kBtus/sf)
Building
SF
Benchmark
CBEC Benchmark Label
One Brookline Place
2-4 Brookline Place
Parking Garage
Total Condition SF
47,000
182,500
178,000
229,500
101
114
-
Outpatient Medical Office
Office
Results of Energy Modeling:
The following summarizes the results of energy modeling for the two buildings and parking
garage, contained in Appendix E:
31 March 2015
Brookline Place; 14522
Stationary GHG Sources
Expanded Notice of Project Change (ENPC)
DOER Comments
P Ormond
One Brookline Place
Site Energy
Baseline
Proposed
%?
(proposed .vs
.base)
Site Path GHG
Emissions
TPY CO2
Baseline
Proposed
%?
(proposed .vs
.base)
47,000 sq ft
Electric
MWh/yr
382
333
-13%
-61%
Direct (Gas)
Combined
137
120
48
19
185
138
-13%
-61%
-25%
182,500
MWh/yr
1,764
1,338
Site Energy
Baseline
Proposed
%?
(proposed .vs
.base)
Site Path GHG
Emissions
TPY CO2
Baseline
Proposed
%?
(proposed .vs
.base)
-32%
Gas
kBTU/yr
6,018,768
4,565,256
-24%
Combined
kBTU
1,826,500
1,874,500
3%
Indirect (Electric)
Direct (Gas)
Combined
634
481
107
110
741
591
-24%
3%
-20%
Parking Garage
178,000
sq ft
Electric
MWh/yr
337
283
Combined
kBTU/yr
2,126,784
1,455,796
EUI (kBtu/sf)
45
31
Benchmark
?% Model .vs. CBECS
EUI (kBtus/sf)
-55%
101
-69%
-32%
sq ft
Electric
Site Energy
Site Path GHG
Emissions
TPY CO2
Baseline
Proposed
%?
(proposed .vs
.base)
Gas
kBTU/yr
823,400
319,600
Indirect (Electric)
2-4 Brookline Place
Baseline
Proposed
%?
(proposed .vs
.base)
kBTU/yr
1,303,384
1,136,196
kBTU/yr
1,149,844
965,596
-16%
kBTU
7,845,268
6,439,756
-18%
EUI (kBtu/sf)
43
35
Benchmark
EUI Weighted ?% Model .vs. CBECS
(kBtus/sf)
-62%
114
-69%
-18%
(area is estimated from reported EUI and energy consumption)
Gas
kBTU
Combined
kBTU
1,149,844
965,596
-
Indirect (Electric)
Direct (Gas)
Combined
121
102
0
0
121
102
-16%
-
-16%
-16%
2
EUI (kBtu/sf)
6
5
-16%
Benchmark
?% Model .vs. CBECS
EUI Weighted
-
31 March 2015
Brookline Place; 14522
Stationary GHG Sources
Expanded Notice of Project Change (ENPC)
DOER Comments
P Ormond
The proponent is including a comprehensive package of mitigation for the two buildings and the
parking garage which are documented in Appendix E. We’ve summarized key items below:
Measure/Area
Roof R-value
Area Window/Area Wall
Window U-value
Walls U-value
Chiller kW/Ton
Boiler (%)
LPD (W/sf)
2010 90.1
Prescriptive or
App.G, or Other
20
0.4
0.55
0.064
0.62
0.8
1.66
Proposed
% Improvement
45
0.58
0.33
0.039
0.923
0.95
0.75
125%
-45%
40%
39%
-49%
Comments
Baseline appears to use 25
Baseline appears to be near 100% glass
Baseline appears to be using U=.057
Baseline appears to be using 0.79
Baseline appears to use 0.9 to 1.66 in baseline
Discussion
Use of the ASHRAE 90.1 Appendix G Standard (Site energy only):
Brookline has adopted the Mass. Stretch Energy Code (SC). The proponent included models to
demonstrate compliance with 2007 ASHRAE 90.1 Appendix G (energy only), as required.
However, we have the following comments/questions on the baseline model (see summary table
above):

The Baseline model appears to contain near 100% glazing; this does not conform to
Appendix G, which does not allow more than 40%.

Some of the R and U values do not appear to conform to baseline requirements.

Some equipment efficiencies used do not appear to conform to baseline requirements.

Lighting power densities appear to conform to Appendix G in only some, but not all, the
building.
Incorporation of the above could potentially decrease the modeled improvement for the Proposed
case. We recommend these inputs be checked for conformance.
Benchmarks
The proposed buildings are well below benchmarks for similar buildings, which the proponent
also noted in their application. Although the DOER recognizes that it’s potentially possible to
vary from benchmarks, when large differences occur, it’s worthwhile to further check and
document model inputs, including: ventilation, equipment loads, schedules, set points, etc which
could affect the results.
3
31 March 2015
Brookline Place; 14522
Stationary GHG Sources
Expanded Notice of Project Change (ENPC)
DOER Comments
P Ormond
As-proposed Mitigation:
In addition to the above, the proponent is also considering (but has not yet committed to) solar PV
and combined heat and power. We recommend both remain as potential options pending further
analysis as described below.
Closing Summary
The project is proposing a wide variety of efficiency measures and included in-depth analysis
designed to demonstrate conformance with MEPA energy requirements. We recommend the
following be addressed in the next submission:

Recheck the Baseline and document compliance with Appendix G.

Document inputs and parameters to confirm that modeled results are accurate, in light of
large deviation from benchmark.

Build on the PV analysis provided to work out economics, including tax, third party, and
other financing incentives to support a go/no go for this option.

Provide a CHP analysis. Although this was referenced in the document, the analysis was
not attached. Include in the analyses the beneficial effect of incentives. MEPA allows
the use of a source energy path compliance with the stretch energy code. The principal
reason for this is to enable the quantification of mitigation to both the source energy
consumption by direct and indirect sources as well as the related GHG emissions
provided by including a CHP system in the as-proposed design. Given the very
substantial incentives offered in Mass. for CHP, the DOER strongly urges the proponent
include the CHP system as proposed and to contact the electric utility for which the site
will be a customer for further information on the utility administered CHP incentive. The
contact for the complimentary DOER administered benefit is John Ballam (617-6261070) Please add that eQUEST can produce a source energy EUI with a CHP system,
and that is the preferred method for complying with the MEPA Policy and Protocol.

If CHP is not elected, provide an analysis of a thermal solar option, including the
beneficial effect of Alternative Energy Credits (AECs). In Massachusetts, it’s now
possible to generate Alternative Energy Credits (AECs) for productive thermal energy
produced on site, including solar thermal. We recommend an in-depth cost-benefit be
developed, including beneficial potential effects of AECs. See (insert website) for more
information.

Have the benefits of exterior shading in the hotel provide been analyzed?

We recommend that a commissioning effort be performed, including equipment
optimization.
4
31 March 2015
Brookline Place; 14522
Stationary GHG Sources
Expanded Notice of Project Change (ENPC)
DOER Comments
P Ormond

Committed mitigation measures need to be articulated to a similar level of detail as above
in the Chapter 61.

For those committed mitigation measures that required tenant compliance (e.g. hours of
operation, lighting intensities, etc), the Chapter 61 should contain requirements which
obligate tenants to conform.
5