COMNET Commercial Buildings Energy Modeling Guidelines and Procedures Comments Submitted

The following comments have been submitted:

Comment #1

Page Number: Entire COMNET Manual
Comment Type: General

Comment:

The COMNET Manual will serve an important function---in many respects "raising the bar" for energy simulation work. It will be, and already is, a valuable resource for modelers and simulation code developers. However, there is one very significant flaw in the approach that has been taken. Namely, the draft COMNET Manual is worded as a "standard" using phrases such as "...shall be..." to describe a simulation procedure, a performance curve, and other inputs and assumptions. This then leads to three significant issues:

1. While it often mirrors ASHRAE 90.1, it does not do so consistently. This introduces further complication and confusion in the interpretation of a standard that is already difficult for many energy modelers to interpret correctly. And, ultimately, ASHRAE 90.1 will continue to evolve. Therefore, unless updates to the COMNET Manual are perfectly synchronized with those of 90.1, with zero interpretive errors and typos, this will tend to lead to confusion about which one is correct and when.

2. The language of standards sets a "stake in the ground." While this has merit in many situations, that role is already covered by 90.1 with respect to what the modeling needs to account for. By extending this same approach to things like fit curves for modeling chiller and cooling coil performance, the COMNET Manual will force the adoption of modeling code that, in some cases, will be a step backward. This effectively puts a damper on development of anything more advanced than DOE-2 or the similar models described by COMNET. While still just as valid as it ever was, this is actually very old code and there are now many opportunities to do better. The last thing we need at this time is yet another means of anchoring the world of energy modeling to DOE-2, when there are so many innovative groups presently making real progress with more advanced approaches to modeling buildings and systems.

3. As the Federal EPAct Tax Credits associated with the Energy Policy Act are already suffering from being tied to an outdated version of ASHRAE 90.1, it will be counter-productive to add to this inertia with a detailed document that is rigidly reinforcing dated standards. Somehow, COMNET has to be more proactive and more forward-looking. At very least, the language should be revised so that it truly offers guidance on how to properly interpret a particular standard and how to appropriately model what that standard is calling for. So long as this is truly presented as "guidance" and not as rigid language to which one must conform, it will provide a springboard for moving forward rather than an anchor to hold us back.
 

 

Justification for Change:

The COMNET Manual is said to provide Energy Modeling Guidelines and Procedures. The word Guidelines is important here. The COMNET Manual needs to be very clear about four things:

  1. When it is simply duplicating a particular version of 90.1, and which version that is.
     
  2. When it is interpreting 90.1, and which version it is interpreting.
     
  3. When it is setting a minimum threshold for modeling rigor---i.e., stating which aspects of performance must be accounted for in the model.
     
  4. When it is describing a particular equation, algorithm, or method that does account for a particular aspect of performance, as an example of one particular means of accomplishing this.

In other words, COMNET should very decisively avoid inadvertently contradicting 90.1 or requiring the use of particular equations, algorithms, methods, models, or code that may be adequate but are by no means the end-all, be-all solution for optimal modeling of a particular aspect of either the building or HVAC systems.

COMNET should be about both raising the bar and encouraging the energy modeling community to go further.
 

Comment #2

Page Number: 6-142 and 6-144
Comment Type: Technical

Comment:

COMNET is inconsistent with the following in ASHRAE Standard 90.1, which states the following (this is taken from Appendix G in the 2007 version of 90.1, but nonetheless is the language that COMNET appears to be referencing, although with critical pieces missing):

G3.1.3.10 Chilled-Water Pumps (Systems 7 and 8)
The baseline building design pump power shall be 22 W/gpm. Chilled-water systems with a cooling capacity of 300 tons or more shall be modeled as primary/secondary systems with variable-speed drives on the secondary pumping loop. Chilled-water pumps in systems serving less than 300 tons cooling capacity shall be modeled as a primary/secondary systems with secondary pump riding the pump curve.

While the Draft COMNET Manual uses the terms “Baseline Building” and “Baseline Rules,” it is not consistent with ASHRAE 90.1 in all instances. Because it closely parallels 90.1, but does not do so consistently and is not a product of ASHRAE, this presents issues with respect to properly interpreting 90.1. Indeed, under General Modeling Procedures, COMNET page 2-6, Baseline Building step 7 states, “Create the baseline building following the COMNET rules.” It does not say, following the rules of a particular ASHRAE 90.1 version.

The “Baseline Rules” for Water Loop Design (p. 6-142) state, contrary to ASHRAE as quoted above, “Assume primary loops only for heating hot water and chilled water systems.” The poor placement of the word “only” is also grammatically incorrect and actually says that only these two types of systems should be permitted to have primary loops! Then the COMNET paragraph under Pump Control Type (p 6-144) first correctly addresses hot and condenser water loops but then contradicts the previous Water Loop Design statement with respect to chilled-water loops, and then (as quoted below) covers only the >300-ton piece of the picture more clearly and completely spelled out by ASHRAE (above):

Pump Control Type (COMNET p. 6-144)
The hot water and condenser water loops shall be primary loops only. When the hot water system serves more than 120,000 ft², the hot water pump shall be modeled as a variable speed pump on a primary loop. When the chilled water system has a capacity of 300 tons or more, the chilled water pumps shall be variable speed and modeled on a primary/secondary loop.
 

Comment #3

Page Number: 1
Comment Type: General

Comment:

Looks a lot like the Energy Star Buildings program. Have I missed something?

Ed Hegwood, LEED AP O+M
Special Projects, Energy Efficiency Advocate
American Mechanical Services
Cell 303-472-8496
Office 303-806-7300
www.amsofdenver.com

AMS excels at all types of Renewable Energy and Energy Conservation HVAC improvements. AMS has the knowledge to produce the results you need to meet your financial, up time and comfort goals. We also maintain what we install assuring a return on your green investment.

We have not inherited this land from our ancestors; rather we have borrowed it from our children. - Kenyan Proverb
 

Comment #4

Page Number: N/A
Comment Type: Technical

Comment:

The modelling software has to effectively model mass elements, especially walls that are massive that do not have an air space between it and the insulation in the case of exterior walls.

Please make sure that COMNET can model passive buildings correctly as well (i.e. solar, nightime cooling, earth-coupled, daylighting, etc. etc.). These are going to be the buildings of the future that function more like self-sustaining organisms, truly "eco-logical" structures that function with as little energy as possible.

Exterior, thick, massive walls that do have an inherent insulation value (i.e. rammed earth, adobe, pumicecrete) need to be modelled dynamically to account for the fact that in certain climates (desert southwest/west US) heat or cold never travels completely through the wall.

Yes, rammed earth is not your typical commercial construction wall system but not allowing for types of earthen construction to be modelled in COMNET is counterproductive to the whole idea of long term energy conservation (embodied and operational over the structure's lifecycle).

I have seen how RESNET does not address the above issues. Please do not let that happen to COMNET.

Attentively,

Jesús Bendezú

B. ARCH., LEED A.P.

Comment #5

Page Number: all
Comment Type: General

Comment:

What is the comment review process? Will commenters be contacted similar to ANSI/ASHRAE comment procedures? Will the RESNET COMNET Committee work with commenters to get satisfactory resolution(s) and if not will that be recorded in the committee decision or vote on comment repsonses?

Justification for Change:

Comments and commenters that do not have some type of feedback from the RESNET COMNET Committee will appear to have just been ignored. It will be difficult for commenters to tell if their comments have been implemented or not.

Proposed Change:

COMNET needs to follow ANSI/ASHRAE procedures for comments and commenters.

Comment #6

Page Number: 6-39
Paragraph / Figure / Table / Note: 6.4.8 Process, Gas
Comment Type: Technical

Comment:

Commercial gas equipment, especially those used for cooking, have a major impact on the internal space loads and conditions. Even with an exhaust hood in place mechanical cooling is still required since not 100% of the radiant load will be removed. Even a portion of the convective load will not be removed by the exhaust fan. Anyone who has been in even a fast food kitchen can personally testify to this.

Justification for Change:

Cooling design capacity will be greatly impacted for some building types if this is ignored as an internal space load. The actual mechanical cooling consumption for some building types will be greatly inaccurate to the actual operation.

Proposed Change:

Remove the following sentence in its entirety: “The commercial gas equipment shall be modeled as an exterior power load with no interaction with space conditions; due to the fact that most equipment will be located under a hood and much of the heat directly leaves the space.” Also revise the Input Restrictions for “Gas Equipment Schedule” to say “The schedule specified for the building should match the operation patterns of the building.” Revise the Input Restrictions for “Gas Equipment Location” to “Internal is prescribed.”

Comment #7

Page Number: 6-40
Paragraph / Figure / Table / Note: 6.5.1 Materials
Comment Type: Technical

Comment:

What is the reference or basis for the material layer properties found in Appendix D?

Justification for Change:

I don’t see necessarily anything wrong with any of the values or properties; I just think there needs to be some reference to where they come from or how they were derived.

Comment #8

Page Number: 6-42
Paragraph / Figure / Table / Note: 6.5.2 Construction Assemblies - Specification Mehod
Comment Type: Technical

Comment:

The Units list choice should be “Layers” only.

Justification for Change:

Specifying a construction assembly by U-factor only will not allow the program to account for thermal mass.

Proposed Change:

The Units list choice should be “Layers” only.

Comment #9

Page Number: 6-50
Paragraph / Figure / Table / Note: 6.5.5 Exterior Floors - Floor Name
Comment Type: Technical

Comment:

The Floor Name, Applicability section references not including slab-on-grade floors. Slab-on-grade floors needs to modeled in the baseline if they exist in the actual building design.

Justification for Change:

ASHRAE 90.1 Appendix G, Table G3.1, section 5 states that slab-on-grade floors must be modeled in the baseline if they exist in the proposed and the baseline must use the prescribed F-factor for that climate zone from section 5 of 90.1.

Proposed Change:

Revise to include slab-on-grade floors in the baseline building if they are apart of the proposed building design.

Comment #10

Page Number: 6-56
Paragraph / Figure / Table / Note: 6.5.7 Fenestration - Fenestration Geometry
Comment Type: Technical

Comment:

Total fenestration for the baseline must be based on gross above-grade wall area and not just gross exterior wall area.

Justification for Change:

ASHRAE 90.1 Appendix G, Table G3.1, section states “…gross above-grade wall area…”. Below-grade walls can not be included in the fenestration % determination.

Proposed Change:

If the gross area of all windows in the building exceeds 40% of the gross above-grade exterior wall area in the building, the dimensions of each window in the baseline building shall be reduced in size such that the window area in the baseline building is equal to 40% of the gross exterior wall area.

Comment #11

Page Number: 6-67
Paragraph / Figure / Table / Note: 6.6.1 Space Temperature Control - Throttling Range
Comment Type: Technical

Comment:

Under “Input Restrictions” the prescribed value is 2° F for throttling range. How Will COMNET ensure the user or program being used will not override the prescribed throttling range?

Justification for Change:

Of the 7 or 8 major modeling programs being used, some allow the user to enter or override the throttling range whereas other programs have the throttling range hard coded with no ability for the user to override it.

Proposed Change:

I’m not sure how to revise this section but I’m also not sure how COMNET will ensure a different throttling range is being used. It is well known that energy modelers with certain programs use large throttling range values in order to have their unmet hours “disappear.”

Comment #12

Page Number: 6-70
Paragraph / Figure / Table / Note: 6.6.5 Zone Level Air Flow - Design Airflow
Comment Type: Technical

Comment:

The Design Airflow, per ASHRAE 90.1, G3.1.2.8, is to be sized on supply-air-to-room-air temperature difference of 20° F. The baseline equipment capacity in G3.1.2.2 references the coil capacity only.

Justification for Change:

The ASHRAE 90.1 ECB subcommittee has ruled that the equipment over sizing in G3.1.2.2 is for coil capacity only. The Design airflow is not to be oversized and is strictly based on G3.1.2.8.

Proposed Change:

For systems 5 through 8, the software shall automatically size the airflow to meet the baseline building loads based on a supply-air-to-room-air temperature difference of 20°F or the required ventilation air or makeup air, whichever is greater.

Comment #13

Page Number: 6-72
Paragraph / Figure / Table / Note: 6.6.5 Zone Level Air Flow - Outdoor Air Ventilation
Comment Type: Technical

Comment:

Under “Definition” one of the sources of ventilation listed is “Natural (by operable openings).” I’m not aware of a generally accepted algorithm for calculating natural ventilation accurately.

Justification for Change:

This option may be desirably sustainable or green, but I’m not sure how any of the 7 or 8 major modeling programs handle natural ventilation. I’m not aware of any direct inputs or algorithms used to model this.

Proposed Change:

COMNET should provide a natural ventilation algorithm with required inputs that must be utilized by all programs/users or have no language allowing natural ventilation in the energy model.

Comment #14

Page Number: 6-141
Paragraph / Figure / Table / Note: 2
Comment Type: Technical

Comment:

Please define “thermal capacity per cell”

Justification for Change:

Capacity can be seen as the heat of rejection rate of the plant or as the actual tower capacity.

Proposed Change:

CTI defines this as: “The # of GPM a cooling tower will handle for a specific range, WB temperature and approach.

Comment #15

Page Number: 6-142
Paragraph / Figure / Table / Note: 3
Comment Type: Technical

Comment:

How do these curves relate to the tower performance charts used in DOE-2.1 calculations?

Justification for Change:

Clarification on the origin of the Default Capacity Coefficients for Cooling Towers.

Proposed Change:

Only clarification of calculations are needed.

Comment #16

Page Number: 6-144
Paragraph / Figure / Table / Note: 2
Comment Type: Technical

Comment:

Please define the Fluid Bypass, Fan Cycling and Pony Motor controls.

Justification for Change:

Each control type should be defined in more detail.

Proposed Change:

Each control type should be defined in more detail.

Comment #17

Page Number: 6-145
Paragraph / Figure / Table / Note: 1
Comment Type: Technical

Comment:

Please define how curve was derived.

Justification for Change:

Clarification on the origin of the Default Efficiency TWR-FAN-FPLR Coefficients for Cooling Towers.

Proposed Change:

Only clarification of calculations are needed.

Comment #18

Page Number: 6-146
Paragraph / Figure / Table / Note: 4
Comment Type: Technical

Comment:

Please define the Strainer cycle and Thermo-cycle (heat exchange internal to the chiller) type of water-side economizer.

Justification for Change:

Each mode should be defined in more detail and justification should be made as to why other types of water-side economizers may not be used.

Proposed Change:

Allow Fluid Coolers, Plate & Frame and Refrigerant Migration as well as define the mentioned economizers.

Comment #19

Page Number: 6-149
Paragraph / Figure / Table / Note: 3
Comment Type: Technical

Comment:

The Baseline Pumps are over specified

Justification for Change:

Pump energy can be calculated using the W/gpm value and the capacity and/or gpm seen by the equipment the pumps are assigned to. Specifying the pump head causes over specification of the pumps.

Proposed Change:

Remove the pump head rule for the Baseline and allow this to be calculated based on the values mentioned above.

Comment #20

Page Number: 6-151
Paragraph / Figure / Table / Note: 2
Comment Type: Technical

Comment:

Please define how curve was derived

Justification for Change:

Clarification on the origin of the Default Part-Load CIRC-PUMP-FPLR Coefficients for Pumps.

Proposed Change:

Only clarification of calculations are needed.

Comment #21

Page Number: 6-153
Comment Type: Technical

Comment:

The Standby and the On-Demand controls appear to be the same since maintaining the temperature in a chilled water or hot water loop is still a load to the plant. Please define the difference between the two.

Justification for Change:

Clarification is needed on the control scheme.

Proposed Change:

Only clarification is needed.

Comment #22

Page Number: 6-168
Comment Type: Technical

Comment:

Does the energy modeling software have to perform the calculations for On-Site Power Generations or can these be submitted separately?

Justification for Change:

Section 3 does not mention the requirement for the energy modeling software to model On-Site Power Generation. Usually, these calculations require much more detail than what is needed for HVAC modeling and thus will probably require specialized software.

Proposed Change:

Define the available / possible software that may be used for these calculations.

Comment #23

Page Number: 6-99
Paragraph / Figure / Table / Note: Table 66
Comment Type: Technical

Comment:

Section 6.7.4, Table 66 – Why is COMNET requiring the usage of enthalpy economizers in specific climate zones?

Justification for Change:

ASHRAE 90.1-2007 does not require the usage of enthalpy economizers yet.

Proposed Change:

COMNET should only require drybulb economizers to stay consistent with ASHRAE 90.1 and the given rules for baseline models.

Comment #24

Page Number: 6-100
Comment Type: General

Comment:

Section 6.7.5, Total Cooling Capacity – A formula for the adjusted cooling capacity is given. What is the source of this formula? How was it derived?

Justification for Change:

The source of the formula is unclear and it should be noted.

Proposed Change:

When using a formula, identify the source as well as the formula.

Comment #25

Page Number: 6-101
Comment Type: Technical

Comment:

Section 6.7.5, Total Cooling Capacity – There is a statement about unmet hours and having the software warn the user to resize the equipment. Unmet hours are the result of any number of control options, equipment specifications, or user-specified schedules. Simply resizing equipment may not address the issue.

Justification for Change:

COMNET should not provide guidance on how to deal with unmet hours because it is a complex process and there is no “magic bullet” to deal with unmet hours.

Proposed Change:

COMNET should only provide a maximum limit and allow the user to deal with the unmet hours in the most appropriate way on a project-by-project basis.

Comment #26

Page Number: 6-102
Comment Type: Technical

Comment:

Section 6.7.5, Total Cooling Capacity – Capacity curve functions and coefficients are provided for use for “all cooling systems” and the user is directed to “use default curves” for the baseline. Is it the intention for these curves to be applied to ASHRAE 90.1 minimally compliant equipment in a baseline model? What is the source of the current set of coefficients?

Justification for Change:

Currently, ASHRAE has no specified requirements for capacity adjustment within Section 6 of ASHRAE 90.1-2007.

Proposed Change:

To remain consistent with ASHRAE 90.1, capacity curves should not be required (but encouraged).

Comment #27

Page Number: 6-104
Comment Type: Technical

Comment:

Section 6.7.5, Direct Expansion Cooling Efficiency – Equation (21) is provided to convert values from the Seasonal Energy Efficiency Ratio (SEER) to Energy Efficiency Ratio (EER). There is no agreed upon procedure for converting SEER to EER.

Justification for Change:

No correlation can be drawn between EER and SEER energy ratios; EER is an instantaneous look at energy usage and SEER is continuous over a cooling season, including the degradation effects of starting and stopping, etc.

Proposed Change:

Since there is no correct way to derive EER from SEER due to operational hours, ambient conditions, geography, and a number of other factors, conversion equations for SEER should not be given.

Comment #28

Page Number: 6-83
Comment Type: Technical

Comment:

Section 6.7.2, Heating Supply Air Temperature – The baseline rules for heating supply air temperature are given, when leaving the air handler (70F). What about conditions that require simultaneous cooling and heating in different zones at a period with low ambient conditions?

Justification for Change:

ASHRAE 90.1 does not specify the leaving air temperature for a preheat coil in a VAV system.

Proposed Change:

COMNET should not specify a leaving air temperature beyond ASHRAE 90.1 to avoid confusion.

Comment #29

Page Number: 1-1
Paragraph / Figure / Table / Note: 1.1.1
Comment Type: Technical

Comment:

USGBC’s LEED rating system allows users to implement addenda in their analysis. How will addenda used in the green building rating system be addressed if it has not yet been incorporated into COMNET?

Justification for Change:

ASHRAE 90.1 addenda often clarify issues not addressed in the standard. It is possible an addenda item could conflict with COMNET guidance.

Proposed Change:

Incorporate wording similar to USGBC’s LEED rating system allowing users to use addenda if desired. If users incorporate addenda, they should apply them consistently throughout the analysis and will supersede any conflicting COMNET guidance.

Comment #30

Page Number: 2-9
Paragraph / Figure / Table / Note: 2.5.1
Comment Type: Technical

Comment:

Current COMNET language sets the level for determining proposed unmet hours at the thermal block level; “…the proposed design shall have no more than 300 unmet load hours in any thermal block.” ASHRAE 90.1-2007 states unmet hours are determined at the building level and not the thermal block level.

Justification for Change:

ASHRAE 90.1-2007 states, “Unmet load hours for the proposed design or baseline building designs shall not exceed 300 (of the 8760 hours simulated)…”

Proposed Change:

Change the level unmet hours are determined from the thermal block level to the building level.

Comment #31

Page Number: 2-9
Paragraph / Figure / Table / Note: 2.5.2
Comment Type: Technical

Comment:

Current COMNET language determines the allowable difference in unmet hours between the proposed and baseline at the thermal block level; “The criterion is that the unmet load hours in the proposed design may be no greater than 50 hours more than the corresponding thermal block in the baseline building.” ASHRAE 90.1-2007 states the difference should be determined at the building level and not the thermal block level.

Justification for Change:

ASHRAE 90.1-2007 states, “Unmet load hours for the proposed design or baseline building designs shall not exceed 300 (of the 8760 hours simulated), and unmet load hours for the proposed design shall not exceed the number of unmet load hours for the baseline building design by more than 50.”

Proposed Change:

Change the level at which the unmet hour difference is determined from the thermal block level to the building level.

Comment #32

Page Number: 5-1
Paragraph / Figure / Table / Note: 5.1
Comment Type: General

Comment:

It is not clear whether these utility rate structures are to be used instead of the rate structures mandated by ASHRAE 90.1-2007.

Justification for Change:

ASHRAE 90.1-2007 mandates, “Annual energy costs shall be determined using either actual rates for purchased energy or state average energy prices published by DOE’s Energy Information Administration (EIA) for commercial building customers, but rates from different sources may not be mixed in the same project.”

Proposed Change:

Incorporate wording clarifying when the rating authority mandates a rate structure, the mandated structure will be used. However, in the absence of a mandated rate structure, users may use the time-of-use rate schedules provided by COMNET.

Comment #33

Page Number: 6-112
Comment Type: Editorial

Comment:

In baseline rules there is a reference to “Figure 19”. However, there is no figure 19 anywhere.

 

Justification for Change:

n/a

Proposed Change:

Proposed Changes: Insert Figure 19.

Comment #34

Page Number: 6-112
Comment Type: Technical

Comment:

There is a reference to “..Design heating capacity of a preheating coil at ARI Conditions”. Which ARI conditions? Which standard #? Is the standards organization “ARI” or “AHRI”?

Justification for Change:

clarification

Proposed Change:

Clarify which organization and standard is referenced.

Comment #35

Page Number: 6-112
Comment Type: Technical

Comment:

There is a reference to “..Design heating capacity of a preheating coil at ARI Conditions”. Which ARI conditions? Which standard #? Is the standards organization “ARI” or “AHRI”?

Justification for Change:

clarification

Proposed Change:

Clarify which organization and standard is referenced.

Comment #36

Page Number: 6-113
Paragraph / Figure / Table / Note: Heating Coil Capacity – Input Restrictions
Comment Type: Technical

Comment:

Please clarify if the “number of unmet load hours..” refers to unmet heating load hours, or a combined total of unmet heating & cooling load hours. This comment applies to all references to unmet load hours.

Justification for Change:

Section refers to heating, implying that only heating unmet load hours are significant, however there are cooling unmet load hours also. This could cause confusion.

Comment #37

Page Number: 6-113
Paragraph / Figure / Table / Note: Furnace – Furnace Capacity
Comment Type: Editorial

Comment:

References made to Figures 2 & 3, however these figures are not displayed anywhere.

Justification for Change:

n/a

Comment #38

Page Number: 6-114
Comment Type: Editorial

Comment:

Does the expression “Fuel consumption at rated conditions..” mean equipment performance at full load? Any part-load performance data point is a “rated” point.

Justification for Change:

clarification

Proposed Change:

Substitute “rated” with “full-load”.

Comment #39

Page Number: 6-114
Paragraph / Figure / Table / Note: 6. Furnace Fuel Heating Part load Efficiency Curve – Table 78
Comment Type: Editorial

Comment:

Display the part-load curve in a graphic using the coefficients from table 78.

Justification for Change:

n/a

Comment #40

Page Number: 6-115
Paragraph / Figure / Table / Note: Electric Heat Pump Heating Capacity
Comment Type: Technical

Comment:

There is a relationship between Cooling and Heating performance in a heat pump. In reality, if the heating capacity is increased the cooling capacity will also increase. How does the 25% oversizing of heating capacity affect cooling capacity?

Justification for Change:

n/a

Comment #41

Page Number: 6-115
Paragraph / Figure / Table / Note: Electric Heat Pump Supplemental Heating Source
Comment Type: Technical

Comment:

When the supplemental heating source activates, can the compressor and the supplemental heat source run simultaneously? Or does the compressor turn off completely and only the backup heat source is activated?

Justification for Change:

Clarification as described above.

Proposed Change:

For simplicity, have the compressor stop operation and only the backup heat source operate below the Electric heating Control temp.

Comment #42

Page Number: 6-119
Paragraph / Figure / Table / Note: Coil Defrost
Comment Type: Technical

Comment:

What is the energy input or output for the coil defrost? For example, is it a 3 KW electric resistance coil? Should the coil defrost be capable of heating the design ventilation CFM from the design heating OADB to a specific temperature?
It is clear that the defrost will enable whenever the OADB is less than 40 deg F. To further clarify, does this mean that the defrost will activate regardless of the HP compressor being on or off?
 

Justification for Change:

clarification

Proposed Change:

define a KW capacity, possibly as a function of ventilation CFM.

Comment #43

Page Number: 6-128
Paragraph / Figure / Table / Note: Boiler Heat Loss
Comment Type: Technical

Comment:

Does this mean that an electric boiler with a full load efficiency of 100% would need to be simulated as being 98% efficient?

Justification for Change:

clarification

Comment #44

Page Number: 6-128
Paragraph / Figure / Table / Note: Boiler Efficiency Type
Comment Type: General

Comment:

Provide conversions for equipment whose efficiency rating doesn’t conform with the format prescribed in “Input Restrictions’. Ex., an oil-fired boiler between 300,000 and 2,500,000 btu/h rated in AFUE instead of Et.

Justification for Change:

n/a

Comment #45

Page Number: 6-128
Paragraph / Figure / Table / Note: Boiler Heat Loss
Comment Type: Technical

Comment:

Does this mean that an electric boiler with a full load efficiency of 100% would need to be simulated as being 98% efficient?

Justification for Change:

n/a

Comment #46

Page Number: 6-133
Paragraph / Figure / Table / Note: Chiller Rated Efficiency
Comment Type: Technical

Comment:

Provide conversion for NPLV or IPLV to units of KW/ton. Also, provide information for creation of part-load power consumption curve implied by NPLV and IPLV performance rating.

Justification for Change:

n/a

Comment #47

Page Number: page 6-6
Paragraph / Figure / Table / Note: Section 6.2.2 Baseline Standards
Comment Type: Editorial

Comment:

The denominator is “proposed building”

Justification for Change:

In 90.1, the baseline building is in the denominator

Proposed Change:

Use the same definition as is used in LEED buildings

Comment #48

Page Number: 6-17
Paragraph / Figure / Table / Note: all
Comment Type: Technical

Comment:

Please define the mass of the furniture.

Justification for Change:

This leaves the user with the very difficult job of entering the mass of the furniture in the space, since it is unknown, and my guess is that most user’s will waste a lot of time on this input.

Proposed Change:

Keep it simple, but give some examples of what to use for a furnished room both in terms of lb/sq ft and total sq ft of floor coverage. For example, lightly furnished, heavily furnished.

Comment #49

Page Number: 6-19
Paragraph / Figure / Table / Note: 6.4.3
Comment Type: Technical

Comment:

Please provide justification for the values (0, and .15 for fluorescent)

Justification for Change:

The values seem to be arbitrarily defined. This will likely cause an uproar among a small but vocal number of people. Lighting manufacturers are going to be put in a very tight place with these numbers arbitrarily defined.

Proposed Change:

Simply list where these values come from.

Comment #50

Page Number: 3-1
Paragraph / Figure / Table / Note: 3.1.2 Calculation Methods
Comment Type: Technical

Comment:

“ability to model schedules and other parameters uniquely for each hour of the year” -- Although this may be a desired feature for a very limited number of building models, this seems to be an excessive requirement. The wording “other parameters” also adds ambiguity to the requirement.

Justification for Change:

Most energy simulation programs that exist today do not allow the ability to modify schedules and “other parameters” uniquely for every hour of the year.

Proposed Change:

Remove the wording “other parameters” and replace with the specific parameters that will have functionality requirements. Adjust the wording such that schedules require unique definition ability for a minimum of 24 hours a day for at least 8 day-types (Monday through Sunday and Holidays) for every month of the year which would be more typical of the tools that exist on the market today.

Comment #51

Page Number: numerous
Comment Type: Technical

Comment:

The initial goals of COMNET are as follows:

• Establishing eligibility for federal tax deduction per 179D of the Internal Revenue Service (IRS)
• Calculating percent savings for point eligibility related to green and sustainable rating systems, and
• Estimating annual energy use for a building in the design phase for the purpose of energy labels

The web site for the Institute for Market Transformation (IMT) has a page that provides additional overview information for COMNET: http://www.imt.org/comnet.html. Towards the bottom of the page, under the subheading “Learn more,” are the following items:

• Two-page description of COMNET
• Introductory COMNET slide-show

The latter reference reveals the following goals for COMNET:

• EPACT 2005 Energy Efficient Commercial Buildings Tax Deduction
• USGBC’s LEED™ NC energy points
• Designed to Meet ENERGY STAR™ designation
• Producing EUI outputs specifically for ENERGY STAR’s Target Finder™
• Integration into ASHRAE technical specs (COMNET is already referenced by ASHRAE Building EQ)
• Performance-based energy code compliance
• Generating estimates of operating costs for commercial building appraisals
• Enabling comparison of “designed-performance” energy efficiency ratings among buildings

According to IMT’s home page, their “work addresses market failures that inhibit investment in energy efficiency and sustainability in the building sector.” This suggests a legislative agenda similar to that of RESNET (Residential Energy Services Network) for the residential sector.. Evidence of this includes references to RESNET within legislative proposals such as Home Star, ACES (H.R. 2454), etc. Under Section 304 of ACES, the Department of Energy (DOE) would be authorized to nationalize, modify and then mandate building energy efficiency codes. Assuming such language is passed into law and further assuming RESNET and COMNET are authorized to standardize building efficiency modeling, this would effective grant them control over how the structures Americans live in and work in are built and operated.

The direct use of natural gas has been on the losing end of a long war of energy efficiency policies since the mid 70’s. At the core of such problems is the fatally flawed conventional wisdom of site-based energy efficiency. As presently written, COMNET is neither site nor source based. Rather it is a derivative of a cost-based metric used in California’s energy efficiency codes termed “Time-Dependent Valuation” (TDV). In fact, much of COMNET is clearly patterned after California’s revised Title 24 polices and modeling practices contained within their Nonresidential Alternative Calculation Method (ACM) Approval Manual.

California’s movement towards TDV has meant a move away from conservation of energy resources and limiting the environmental aftermath of energy consumption overall. We understand that the conservation of peak energy has more economic value to utilities; especially electric utilities; but such value does not necessary follow through to environmental value.

We advocate for an approach whose objective is to balance least cost principals in terms of economics and environmental impacts on a basis that does not discriminate between energy alternatives. In short, COMNET should be based upon least-cost planning through full fuel-cycle analyses of all reasonable energy alternatives to let them compete on the basis of their overall merits or lack thereof. COMNET could start refocusing its efforts by reviewing the following:

• The National Academy of Sciences (NAS) report (see footnote 1 for hyperlink) “that the U.S. Department of Energy should consider gradually changing its system of setting appliance energy-efficiency standards to a full-fuel-cycle measurement.”


• Comments made by Dr. Chu, the Secretary of the Department of Energy (DOE) to a board meeting of the American Gas Association where he recognized the merits of full fuel-cycle analyses

.
• Correspondence between DOE's Deputy Assistant Secretary, Cathy Zoi and the White House indicated DOE’s intention to propose a policy initiative for public review and comment to develop and use estimates of full-fuel-cycle energy savings and greenhouse gas emissions as the basis for evaluating appliance energy conservation standards. This correspondence also proposed to use full-fuel-cycle estimates to better inform consumers of the impacts of appliance use.

Such an approach will better address energy efficiency market failures rather than add to them. Please let us know how we can provide you with any the above listed documentation as your capabilities for receiving comments precludes attachments.

This concludes our general concerns. Specific concerns are as follows:

  •  The term “Q” has different meanings at different locations in the draft. However the first excerpt (from page 6.6) is most interesting:

The same equation is used with both methods (see Equation (3)), however, the Q term only includes regulated energy for tax deductions, but total energy for green building ratings

In the case of “total energy for green building ratings” does that mean “source” or “full fuel-cycle” energy?

  • Under 1.1.1 Baseline Standards, it states:

the baseline for green building ratings is ASHRAE Standard 90.1-2007

According to “TABLE G3.1.1B Baseline System Descriptions” of the Proposed Addendum to Standard 90.1-2007, Energy Standard for Buildings Except Low-Rise Residential Buildings (see footnote 2 for hyperlink), electric resistance heat is still allowed as the baseline of ASHRAE 90.1. Such allowances do not address market failures, they create them.

  • Section 5.3 Use of Default TOU Tariffs with ENERGY STAR states:

A benefit of using the COMNET tariffs is that building features such as daylighting or thermal storage that reduce energy demand in periods when the utility grid is stressed and when more expensive generating sources are on-line are given more credit

This statement seems to be primarily designed to help promote off-peak TES; a so-called “electrotechnology.” TES has been shown to increase source energy use. It is also noteworthy that California regulators have previously and clearly discouraged TES. Accordingly, such statements indicate inappropriate preferences for the conservation of finite energy resources and mitigation of global warming. Technologies such as engine driven chillers with heat recovery to decouple sensible and latent heat reduction via desiccants provide much more fuel-cycle efficient options.

  • Section 5.1 states:

5.1 Overview
The COMNET valuation methodology provides default time-of-use rate schedules for electricity, gas, steam and chilled water. COMNET software shall incorporate these rates into the calculation procedure so that the default rate schedules are easily available to the user. The software shall have the capability to assign energy charges for different seasons, day types, and periods within the day. Percent savings calculations shall be performed using Equation (1) for tax deductions and Equation (2) for green building ratings. A procedure is provided at the end of this chapter to convert TOU energy costs to EPA source energy for use with the Target Finder and Portfolio Manager programs. Appendix F of this document describes the methodology used to create the TOU energy costs presented in this chapter.

Rather than moving away from the source efficiency basis within Portfolio Manager, we urge COMNET to move towards it.

Again, please let us know how we can provide you with any additional documentation as your capabilities for receiving comments preclude attachments.

Sincerely,


Mark Krebs


Footnotes:

http://www8.nationalacademies.org/onpinews/newsitem.aspx?RecordID=12670

 

https://osr.ashrae.org/sitepages/showdoc2.aspx/ListName/Public%20Review%20Draft%20Standards/ItemID/360/IsAttachment/N/90+1dn_2007__1stPPRDraft.pdf

Comment #52

Page Number: All
Comment Type: Technical

Comment:

COMNET procedures for calculating energy savings are highly flawed and misleading if COMNET’s goal is to equitably serve the 3 purposes stated on page 1-1 of the guideline:

• Establishing eligibility for federal tax deductions per §179D of the Internal Revenue Service (IRS) code;
• Calculating percent savings for point eligibility related to green building rating systems; and
• Estimating annual energy use for a building in the design phase for the purpose of energy labels.

As a minimum, COMNET needs to use the full fuel cycle, or source energy, (taking all energy forms to the point of extraction such as wellhead or minemouth) as the basis of its energy savings procedure and calculations. If an additional COMNET goal (not stated in the 3 shown above) is to shift loads, then and only then should it ADD a second requirement that incorporates time of use costs – as long as such strategies don’t increase annual source energy consumption associated with the building. If an additional goal is to reduce GHG emissions (not stated in the 3 shown above), an additional GHG compliance requirement can be added.

COMNET is also inherently flawed because it links directly to ASHRAE Standard 90.1-2001 and -2007, both of which are site energy based and permit tradeoffs only AFTER the fuel and technology choices are made.

As an example, when using ASHRAE Standard 90.1 criteria, a building design that includes an electric resistance water heater will comply, but will have much HIGHER full fuel cycle energy consumption and GHG emissions compared to a fully compliant gas, propane, or oil storage water heater (55% higher GHG emissions using national average values according to EPA http://www.aham.org/ht/a/GetDocumentAction/id/33223 ). This perversely incentivizes the designer to choose the less expensive qualifying technology, promoting fuel switching in the design decision away from more full fuel cycle energy efficient and lower GHG emitting technologies and providing an unfair and unearned market advantage to qualifying technologies such as electric resistance water heating that are lower cost/lower full fuel cycle efficient and higher GHG emitting. This is a key reason both ASHRAE in its Building Energy Labeling Program http://www.buildingeq.com/index.php/resources http://www.buildingeq.com/files/ABELFAQ.pdf and EPA in its full fuel cycle energy-based Energy Star Buildings rating system http://www.energystar.gov/ia/business/evaluate_performance/General_Overview_tech_methodology.pdf http://www.energystar.gov/ia/business/evaluate_performance/site_source.pdf http://www.energystar.gov/ia/business/tools_resources/new_bldg_design/2003_CBECSPerformanceTargetsTable.pdf http://www.energystar.gov/ia/business/evaluate_performance/Emissions_Supporting_Doc.pdf use a single statistically derived reference building by building category.

 

Justification for Change:

Time of Use cost by fuel type (TOU) is a technically flawed metric for energy use. It does not account for energy consumed in an equitable manner, but is only potentially useful as a demand management tool. For instance, TOU would strongly encourage strategies such as thermal energy storage (TES) to reduce peak demand. TES systems are widely acknowledged to INCREASE annual energy consumption while DECREASING peak demand. If the only goal is to shift load from peak to off-peak, TDV is a potentially valuable metric, but only if all factors are fairly derived and implemented. However, it is a very poor metric if the goal is to reduce the consumption of the nation’s primary energy sources (especially natural gas, coal, petroleum, and nuclear) associated with the building design and operation. To reduce the nation’s energy consumption associated with the building design and operation, it is imperative to include source energy as the compliance requirement, as EPA has done in its Energy Star Buildings program and ASHRAE has done in its Building Energy Labeling program.

TDV is also inappropriate if the goal is to reduce greenhouse gas (GHG) emissions (especially CO2, CH4, and N2O) associated with buildings. GHG emissions are directly related to annual energy consumption of fossil fuels, not time of use of energy.
 

Proposed Change:

Until ASHRAE fixes its flawed standard, COMNET will be flawed unless it chooses to shift its approach slightly but meaningfully from the ASHRAE approach. The following is offered as a way to address this flaw in an equitable manner by creating an efficient, achievable baseline building for source energy savings and GHG emission reduction comparisons in COMNET.

The heating system for the baseline building is as follows:
Fuel type: natural gas
Equipment type: System 11
Efficiency: Warm air furnaces, gas fired

The cooling system for the baseline building is as follows:
Fuel type: electricity
Equipment type: System 11
Efficiency: Air conditioners, Air cooled

The service water heating system for the baseline building is as follows:
Fuel type: natural gas
Efficiency: Storage water heaters, Gas

These 3 provisions effectively establish a single reference design building performance requirement for source energy calculations BEFORE making the technology and fuel choices for the proposed building. This then allows the designer to get the appropriate credit for putting innovative full fuel cycle energy efficient technologies that reduce GHG emissions into the proposed design (including equitable treatment of renewable energy options and waste heat recovery options).

The revised baseline building text is a rational approach to creating a “single reference building” concept for comparison of alternatives that is key to implementing both full fuel cycle energy and GHG emission savings calculations. The revised baseline allows flexible technology and fuel choice decisions as well as an equitable full fuel cycle energy-based treatment of advanced renewable and multi-fuel technology options to improve the full fuel cycle energy efficiency and GHG emissions of the proposed design. It eliminates the technically unsupportable equivalency in the ASHRAE tables currently provided to less full fuel cycle energy efficient and higher GHG emitting technologies such as electric resistance heating and water heating technologies and fossil-fueled single effect absorption cooling technologies. It provides more equitable treatment of CHP, distributed generation, and waste heat recovery, and renewables. It is the most technically defensible methodology when using full fuel cycle energy and GHG emissions as compliance requirements. Otherwise full fuel cycle energy and GHG emissions calculations are only conversion factors with very limited design and societal impact.

If COMNET is concerned about inappropriate tradeoffs between envelopes and equipment (i.e., short life high efficiency equipment resulting in a less energy efficient long life envelope), consider adding the following:

The total annual energy loss from the building thermal envelope shall be less than or equal to the total annual energy loss from a building thermal envelope that meets the requirements of Table 11.3.1 of ASHRAE Standard 90.1.

The added text provides a minimum overall envelope loss requirement for all proposed designs that is at least equivalent to the ASHRAE budget building design requirements. The proposed text also eliminates tradeoffs between mechanical or lighting system options and envelope options while still permitting design flexibility across opaque elements and fenestration. As long as the combined total energy loss from the thermal envelope meets the stringency of the prescriptive envelope in Table 11.3.1 of ASHRAE Standard 90.1, the designer can still trade off individual envelope components such as fenestration and roofs to meet the overall requirement. It decouples the envelope from the mechanical and electrical systems, acknowledging the significantly different service lives of these major building components.

If GHG emissions are of interest, then the following additional requirement is offered for consideration:

GHG emissions associated with the proposed building design ≤ GHG emissions associated with the baseline building design.

The added text establishes a rational basis for GHG emissions compliance requirements to make sure a proposed design that focuses on innovative energy efficient technologies does not have the unintended consequence of increasing GHG emissions relative to a the baseline building.
 

Comment #53

Page Number: 3-2
Paragraph / Figure / Table / Note: 3.1.2 Calculation Methods
Comment Type: Technical

Comment:

Adjusting Capacities section - Remove this section

Justification for Change:

If the user has made an input error that cannot easily be detected, the automatic capacity routine may not allow for a stable solution. Even if no input errors have been made, there may likely be an infinite number of solutions or none. There is no good way of knowing which the best and quickest solution is. This requirement could increase execution time exponentially. In addition, our significant experience with unmet load hours has clearly demonstrated that more often than not, the underlying issue behind unmet loads hours can not be resolved by simply increasing equipment capacity. In many cases increasing equipment capacity actually adversely impacts the results and causes additional confusion with in the model. This should be addressed by the Error Handling paragraph, i.e., the rating software should describe the error and offer remedies.

Proposed Change:

Remove the section

Comment #54

Page Number: 3-2
Paragraph / Figure / Table / Note: 3.1.2 Calculation Methods
Comment Type: Technical

Comment:

Error Handling Section - Adjust the wording in this section

Justification for Change:

Removal of the Adjusting Capacities section has been recommended above so this would require a change to this section.

Proposed Change:

The software shall identify error conditions when unmet loads exceed 300 hours, prevent completion of the rating analysis, and provide information to the user describing the error that has occurred and what steps the user should take to remedy the situation.

Comment #55

Page Number: 3-3 to 3-4
Paragraph / Figure / Table / Note: 3.1.9
Comment Type: Technical

Comment:

This section is not nearly detailed enough to ensure adequate accuracy in the load design process

Justification for Change:

Most of the current applications developed by the government are primarily focused solely on energy analysis and are not used by the industry for accurate load design analysis. Although the calculation methods are nearly identical, most industry standard design methods and assumptions are not typically accounted for in tools such as EnergyPlus and DOE2 without a 3rd party interface that automates the process and assumptions. Lack of clarification here could eliminate these tools from being used directly given their rudimentary interface and energy related focus.

Proposed Change:

Clearly define the assumptions that are necessary for proper load design. This section should also address design weather data and design ventilation.

Comment #56

Page Number: 3-4
Paragraph / Figure / Table / Note: 3.1.9
Comment Type: Technical

Comment:

Natural Ventilation - Remove this section

Justification for Change:

This option may be desirably "green", but there is no generally accepted algorithm for calculating natural ventilation accurately and with reasonable inputs and execution time. Results between programs vary too widely to be a part of the benchmarking process.

Proposed Change:

Remove the section. Alternatively, COMNET should provide a natural ventilation algorithm with required inputs that must be utilized by all rating software.

Comment #57

Page Number: 1-1
Comment Type: Technical

Comment:

COMNET procedures for calculating energy savings are highly flawed and misleading if COMNET’s goal is to equitably serve the 3 purposes stated on page 1-1 of the guideline:

 

·         Establishing eligibility for federal tax deductions per §179D of the Internal Revenue Service (IRS) code;

·         Calculating percent savings for point eligibility related to green building rating systems; and

·         Estimating annual energy use for a building in the design phase for the purpose of energy labels.

 

Time of Use cost by fuel type (TOU) is a technically flawed metric for energy use.  It does not account for energy consumed in an equitable manner, but is only potentially useful as a demand management tool.  For instance, TOU would strongly encourage strategies such as thermal energy storage (TES) to reduce peak demand.  TES systems are widely acknowledged to INCREASE annual energy consumption while DECREASING peak demand.  If the only goal is to shift load from peak to off-peak, TDV is a potentially valuable metric, but only if all factors are fairly derived and implemented.  However, it is a very poor metric if the goal is to reduce the consumption of the nation’s primary energy sources (especially natural gas, coal, petroleum, and nuclear) associated with the building design and operation.  To reduce the nation’s energy consumption associated with the building design and operation, it is imperative to include source energy as the compliance requirement, as EPA has done in its Energy Star Buildings program and ASHRAE has done in its Building Energy Labeling program. 

 

TDV is also inappropriate if the goal is to reduce greenhouse gas (GHG) emissions (especially CO2, CH4, and N2O) associated with buildings.  GHG emissions are directly related to annual energy consumption of fossil fuels, not time of use of energy. 

Justification for Change:

As a minimum, COMNET needs to use the full fuel cycle, or source energy, (taking all energy forms to the point of extraction such as wellhead or minemouth) as the basis of its energy savings procedure and calculations.  If an additional COMNET goal (not stated in the 3 shown above) is to shift loads, then and only then should it ADD a second requirement that incorporates time of use costs – as long as such strategies don’t increase annual source energy consumption associated with the building.  If an additional goal is to reduce GHG emissions (not stated in the 3 shown above), an additional GHG compliance requirement can be added. 

 

COMNET is also inherently flawed because it links directly to ASHRAE Standard 90.1-2001 and -2007, both of which are site energy based and permit tradeoffs only AFTER the fuel and technology choices are made. 

 

As an example, when using ASHRAE Standard 90.1 criteria, a building design that includes an electric resistance water heater will comply, but will have much HIGHER full fuel cycle energy consumption and GHG emissions compared to a fully compliant gas, propane, or oil storage water heater (55% higher GHG emissions using national average values according to EPA http://www.aham.org/ht/a/GetDocumentAction/id/33223 ).  This perversely incentivizes the designer to choose the less expensive qualifying technology, promoting fuel switching in the design decision away from more full fuel cycle energy efficient and lower GHG emitting technologies and providing an unfair and unearned market advantage to qualifying technologies such as electric resistance water heating that are lower cost/lower full fuel cycle efficient and higher GHG emitting.  This is a key reason both ASHRAE in its Building Energy Labeling Program http://www.buildingeq.com/index.php/resources  http://www.buildingeq.com/files/ABELFAQ.pdf  and EPA in its full fuel cycle energy-based Energy Star Buildings rating system http://www.energystar.gov/ia/business/evaluate_performance/General_Overview_tech_methodology.pdf  http://www.energystar.gov/ia/business/evaluate_performance/site_source.pdf http://www.energystar.gov/ia/business/tools_resources/new_bldg_design/2003_CBECSPerformanceTargetsTable.pdf http://www.energystar.gov/ia/business/evaluate_performance/Emissions_Supporting_Doc.pdf use a single statistically derived reference building by building category. 

 

Until ASHRAE fixes its flawed standard, COMNET will be flawed unless it chooses to shift its approach slightly but meaningfully from the ASHRAE approach. 

Proposed Change:

The following is offered as a way to address this flaw in an equitable manner by creating an efficient, achievable baseline building for source energy savings and GHG emission reduction comparisons in COMNET.

The heating system for the baseline building is as follows:

Fuel type: natural gas

Equipment type: System 11

Efficiency: Warm air furnaces, gas fired

 

The cooling system for the baseline building is as follows:

Fuel type: electricity

Equipment type: System 11

Efficiency: Air conditioners, Air cooled

 

The service water heating system for the baseline building is as follows:

Fuel type: natural gas

Efficiency: Storage water heaters, Gas

 

These 3 provisions effectively establish a single reference design building performance requirement for source energy calculations BEFORE making the technology and fuel choices for the proposed building.  This then allows the designer to get the appropriate credit for putting innovative full fuel cycle energy efficient technologies that reduce GHG emissions into the proposed design (including equitable treatment of renewable energy options and waste heat recovery options). 

 

The revised baseline building text is a rational approach to creating a “single reference building” concept for comparison of alternatives that is key to implementing both full fuel cycle energy and GHG emission savings calculations. 

 

The revised baseline allows flexible technology and fuel choice decisions as well as an equitable full fuel cycle energy-based treatment of advanced renewable and multi-fuel technology options to improve the full fuel cycle energy efficiency and GHG emissions of the proposed design.  It eliminates the technically unsupportable equivalency in the ASHRAE tables currently provided to less full fuel cycle energy efficient and higher GHG emitting technologies such as electric resistance heating and water heating technologies and fossil-fueled single effect absorption cooling technologies.  It provides more equitable treatment of CHP, distributed generation, and waste heat recovery, and renewables.  It is the most technically defensible methodology when using full fuel cycle energy and GHG emissions as compliance requirements.  Otherwise full fuel cycle energy and GHG emissions calculations are only conversion factors with very limited design and societal impact. 

 

If COMNET is concerned about inappropriate tradeoffs between envelopes and equipment (i.e., short life high efficiency equipment resulting in a less energy efficient long life envelope), consider adding the following:

 

The total annual energy loss from the building thermal envelope shall be less than or equal to the total annual energy loss from a building thermal envelope that meets the requirements of Table 11.3.1 of ASHRAE Standard 90.1. 

 

The added text provides a minimum overall envelope loss requirement for all proposed designs that is at least equivalent to the ASHRAE budget building design requirements.  The proposed text also eliminates tradeoffs between mechanical or lighting system options and envelope options while still permitting design flexibility across opaque elements and fenestration.  As long as the combined total energy loss from the thermal envelope meets the stringency of the prescriptive envelope in Table 11.3.1 of ASHRAE Standard 90.1, the designer can still trade off individual envelope components such as fenestration and roofs to meet the overall requirement.  It decouples the envelope from the mechanical and electrical systems, acknowledging the significantly different service lives of these major building components. 

 

If GHG emissions are of interest, then the following additional requirement is offered for consideration:

 

GHG emissions associated with the proposed building design ≤ GHG emissions associated with the baseline building design.

 

The added text establishes a rational basis for GHG emissions compliance requirements to make sure a proposed design that focuses on innovative energy efficient technologies does not have the unintended consequence of increasing GHG emissions relative to a the baseline building. 

Comment #58

Page Number: 3-4
Paragraph / Figure / Table / Note: 3.1.10 Systems Simulation
Comment Type: Technical

Comment:

Air Side Heat Recovery - Why not require other airside heat recovery methods be available such as heat pipes, solid and liquid desiccants, fixed plate heat exchangers, or other coil loop methods? Also suggest requiring the ability to multiple stages of heat recovery.

Justification for Change:

Please explain why these options were selected as the sole requirements when other airside heat recovery options are commonly used in the industry.

Comment #59

Page Number: 3-11
Paragraph / Figure / Table / Note: 3.1.11 Managing User Input
Comment Type: Technical

Comment:

Building Descriptor Inputs and Restrictions “provide a field of at least 500 characters for documentation of revised assumptions” - Why force the user interface to add a large text input section just for documenting specific requirements of the COMNET program?
 

Justification for Change:

The software tools used for COMNET will likely also be used for many other purposes. Forcing the tools to have large field entries such as this detracts from the software tools flexibility and is more restrictive than is necessary. Documentation of this type is best left for other areas of the submission process allowing the user to utilize tools that have word processing capabilities.

Proposed Change:

Move this requirement to a comments specific submission report that can utilize word processing capabilities and remove it as a software interface requirement.

Comment #60

Page Number: 4-1
Paragraph / Figure / Table / Note: 4.2 Electronic Format: XML
Comment Type: Technical

Comment:

COMNET should provide the XML schema to be used for each report.

Justification for Change:

This would ensure consistency across each application.

Proposed Change:

COMNET should provide the electronic XML schema file to be used for each report or combined into a single schema to cover all reports.

Comment #61

Page Number: 4-12
Paragraph / Figure / Table / Note: 4.3.4
Comment Type: Technical

Comment:

Remove the Representation Report from the list of required reports the software must provide.

Justification for Change:

The Representation Report has nothing to do with the software analysis and therefore makes little sense to require the software application to include this type of report.

Proposed Change:

Remove the representation report from the software requirements.

Comment #62

Page Number: Appendix E
Comment Type: Technical

Comment:

Standard 140 reference results - DOE-2 is the only energy analysis program common to all the Std 140 test suites. BLAST is no longer supported to my knowledge unless someone is going to volunteer to create and run the datasets for the missing test cases.

Justification for Change:

Consistency in the reference results

Proposed Change:

The Std 140 test results for TRNSYS and most certainly EnergyPlus should be added to all the Result spreadsheets where they are now missing.

Comment #63

Page Number: Appendix E
Comment Type: Technical

Comment:

Comment regarding: Establishing Acceptance Ranges
“Where reference results are very close together, such that the confidence interval maximum or minimum values could fall above or below the reference results maximum or minimum values respectively, a value of ±5% of the range between the minimum and maximum of the reference results, as applicable, is applied to the range”
Comment: This can be too restrictive, especially for the test cases when the number of reference energy analysis programs that provided data for an individual case is small.
 

Justification for Change:

The range will sometimes collapse to almost zero in this scenario which is unacceptable and too restrictive.

Proposed Change:

Add “however, in no case shall the (Mean - Minimum Value) or the (Maximum Value - Mean) be less than 2.5% of the Mean. If this should happen, the acceptance range shall be expanded to accommodate the wider threshold.”

Comment #64

Page Number: Appendix E
Comment Type: Technical

Comment:

Comment regarding: Step 3 and Step 4
Comment: This test should be modifed per the previous comment, i.e., in no case shall the (Mean - Minimum Value) or the (Maximum Value - Mean) be less than 2.5% of the Mean. If this should happen, the acceptance range shall be expanded to accommodate the wider threshold.
 

Justification for Change:

The range will sometimes collapse to almost zero in this scenario which is unacceptable and too restrictive.

Proposed Change:

See previous comment

Comment #65

Page Number: Appendix E
Comment Type: Technical

Comment:

Comment regarding: Using the Spreadsheets
Comment: It is unacceptable to base the statistics on a different number of reference energy analysis programs for each spreadsheet. What is used for one should consistently be used for all. There are 8 reference energy analysis programs used in Results 5-2, 6 in Results 5-3B, 10 in Results 5-3A, 3 in Results 5-4 -- and the software list is different in each one!!! The software used for the statistical analysis should include all those programs which are still in use today, not just the 4 mentioned in the first paragraph of this appendix.
 

Justification for Change:

Inconsistent test results basis

Proposed Change:

Use the same set of programs for all test spreadsheets.

Comment #66

Page Number: Appendix F TOU Costs Methdology
Comment Type: General

Comment:

 EPA Comments on COMNET Draft Commercial Building Energy Modeling Guidelines and Procedures

 

Thank you for the opportunity to provide comments on the COMNET draft modeling guidelines and procedures.  EPA’s comments will focus on the proposed application of time of use (TOU) energy costs.  We are not commenting on the overall proposed modeling protocols or schedules.

 

Below are EPA’s general comments on the TOU energy cost approach, followed by comments on COMNET’s stated intention to relate estimated TOU-based energy costs to ENERGY STAR.

 

General Comments

 

While the concept of a modeling approach that ensures appropriate valuation of daylighting, photovoltaics, thermal energy storage, and the like by incorporating TOU energy costs is appealing, there is not enough information in the draft documents to allow us to comment on the effectiveness of the proposed COMNET approach in achieving this goal.  We can, however, provide some lessons learned from our experience with the ENERGY STAR performance scale:

 

  • It appears that TOU calculations require significant inputs.  The task of regularly updating these inputs will not be trivial, particularly if values change frequently and/or substantially.  This may be a particularly important consideration for COMNET, as the documentation references many time-dependent inputs to the modeling. 
  • Related to the point above, it is important to understand how sensitive the results are to the inputs.  EPA regularly conducts sensitivity analyses for the models underpinning the ENERGY STAR performance scale, and has in some cases found unexpected results that caused us to re-examine our assumptions and models.  With so many inputs to the COMNET TOU modeling, this could be a critical and on-going effort.
  • As this approach requires training and possibly additional effort – and may provide results different than other types of modeling users are familiar with -- we encourage COMNET to provide data that backs up the claimed improvement it offers.  We have found that providing data on the impacts of a change to the ENERGY STAR performance scale, with detailed examples, helps users understand and accept the change.  We did not see any such examples in the COMNET documentation.

 


Justification for Change:

 General comments on methodology.

Proposed Change:

 No specific change proposed

Comment #67

Page Number: Appendix F TOU Costs Methdology
Comment Type: General

Comment:

 EPA Comments on COMNET Draft Commercial Building Energy Modeling Guidelines and Procedures

 

Thank you for the opportunity to provide comments on the COMNET draft modeling guidelines and procedures.  EPA’s comments will focus on the proposed application of time of use (TOU) energy costs.  We are not commenting on the overall proposed modeling protocols or schedules.

 

Below are EPA’s general comments on the TOU energy cost approach, followed by comments on COMNET’s stated intention to relate estimated TOU-based energy costs to ENERGY STAR.

 

General Comments

 

While the concept of a modeling approach that ensures appropriate valuation of daylighting, photovoltaics, thermal energy storage, and the like by incorporating TOU energy costs is appealing, there is not enough information in the draft documents to allow us to comment on the effectiveness of the proposed COMNET approach in achieving this goal.  We can, however, provide some lessons learned from our experience with the ENERGY STAR performance scale:

 

  • It appears that TOU calculations require significant inputs.  The task of regularly updating these inputs will not be trivial, particularly if values change frequently and/or substantially.  This may be a particularly important consideration for COMNET, as the documentation references many time-dependent inputs to the modeling. 
  • Related to the point above, it is important to understand how sensitive the results are to the inputs.  EPA regularly conducts sensitivity analyses for the models underpinning the ENERGY STAR performance scale, and has in some cases found unexpected results that caused us to re-examine our assumptions and models.  With so many inputs to the COMNET TOU modeling, this could be a critical and on-going effort.
  • As this approach requires training and possibly additional effort – and may provide results different than other types of modeling users are familiar with -- we encourage COMNET to provide data that backs up the claimed improvement it offers.  We have found that providing data on the impacts of a change to the ENERGY STAR performance scale, with detailed examples, helps users understand and accept the change.  We did not see any such examples in the COMNET documentation.

 


Justification for Change:

 General comments on methodology.

Proposed Change:

 No specific change proposed

Comment #68

Page Number: Appendix F TOU Costs Methdology (pg. 17)
Comment Type: Technical

Comment:

 EPA Comments on COMNET Draft Commercial Building Energy Modeling Guidelines and Procedures

 

Thank you for the opportunity to provide comments on the COMNET draft modeling guidelines and procedures.  EPA’s comments will focus on the proposed application of time of use (TOU) energy costs.  We are not commenting on the overall proposed modeling protocols or schedules.

 

Below are EPA’s  comments on COMNET’s stated intention to relate estimated TOU-based energy costs to ENERGY STAR.

 Use of Default TOU Tariffs with ENERGY STAR

 

We do not support the use of COMNET estimated energy costs to derive an ENERGY STAR score as outlined in the draft manual.  The basis for the ENERGY STAR performance scale is a set of regressions that relate building energy use – not costs -- to operational characteristics.  It is neither technically consistent nor desirable to apply the results of these regressions to calculations of energy cost.  EPA’s scale is and will continue to be source energy based.

 

We ask that you remove this section (5.3) from the document, as well as any other references to relating the COMNET energy costs to ENERGY STAR (such as the “Comparability with ENERGY STAR” section of Appendix F).

 

 

Justification for Change:

 EPA requires energy use values for both new and existing buildings in order to generate an ENERGY STAR score, and will not accept a Designed to Earn application based on energy costs. However, if the COMNET modeling protocol yields values for total energy use, these values can be entered into Target Finder to generate a score and apply for the Designed to Earn ENERGY STAR designation.

Proposed Change:

 Remove section relating COMNET to ENERGY STAR.

 

Alternately, COMNET documentation could instruct users to uses values for estimated total energy use from the modeling protocols that can be entered into Target Finder to generate an acceptable ENERGY STAR score.