Brookline Place
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
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