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Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

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Page 1: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

Non-Residential Lighting: Status Update

Christian Douglass & Josh RushtonRegional Technical Forum

November 10, 2015

Page 2: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

2

Agenda

• Update on retrofit protocol – preliminary analysis of the protocol’s HOU/HOO ratio

method using BPA lighting evaluation data– discussion of where we want to steer protocol, with a CAT

recommendation

• Update on code compliant lighting– feedback from first meeting of the technical subcommittee– RTF discussion/CAT recommendation on next steps

Note that the retrofit protocol sunsets at end of year and will be back next month.

Page 3: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

3

Staff Highlighted Areas – Retrofit Protocol

• BPA research is in and the results of the RTF protocol’s HOU/HOO interview method look good, BUT– BPA/SBW wonder whether proving out the standard protocol will significantly

reduce long-term costs and program burden relative to existing impact evaluation methods (i.e. maybe we should just give impact evaluation guidance?)

– BPA questions whether formal interview is implementable by programs and contractors

• We’ve also received comments on the appropriateness of the retrofit protocol’s baseline– Current protocol largely assumes existing, “in-ceiling” baseline except for

“obsolete equipment” (e.g. T12s)– Primary concern is – do most systems being replaced under the “retrofit”

scenario have significant RUL or are they close to burn-out, in which case a current practice baseline would be more appropriate?

– Teeing this up today, but will require more discussion

Page 4: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

4

Staff Highlighted Areas – Code Compliant Lighting

• Subcommittee could not agree on a current practice definition

• Unclear whether parts of this measure can be standardized within a protocol

• Seeking guidance from the RTF on a path forward

Page 5: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

5

Update on provisional retrofit protocol research

Page 6: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

First: A Reminder of the RTF’s Non-Res Lighting Research Objectives

• Phase I: Determine simplified method to reliably estimate lighting Hours of Use (HOU). Protocol’s candidate method uses hours of occupancy (HOO) from a structured interview and compares this to metered lighting hours of use (HOU). The goal is find HOU/HOO ratios that can be used to adjust interview responses to estimate HOU.

• Phase II: Determine a simplified method to reliably estimate controls savings fractions (CSFs). May be able to take differences in HOU/HOO ratios, but not without some pre-/post- data to build confidence in the approach.

6

Page 7: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

7

A Reminder of the RTF’s HOU/HOO Interview Method

Hours of Occupancy (HOO) for a space• Time spanned by period(s) that typically include activity in the space• Easy to collect, often equals business hours, plus time for cleaning, etc. • HOO is gathered through site interviews

Hours of Use (HOU) for a lighting system • Burn time, full-power-equivalent hours (3 hours at 50% power is 1.5 HOU)• The thing we wish we could always know• HOU is measured with loggers and meters during research phase

HOU/HOO Ratio • Parameter for the mean, or typical value, of the ratio HOU/HOO• Estimated through provisional research • Values differ by control type (and probably space type)

Page 8: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

Phased research

Current research plan is only Phase I • Does not call for pre-/post- data• Sunset period (1-year) allows time to analyze data

from Phase I research currently in the field • Expect second research phase to include carefully

targeted pre-/post- data– Research questions (and sample targets) to depend on

phase-I results– Expectation of second phase stated in current research

plan but plan details not yet possible

8

Page 9: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

Phase I Research: Expectations

• Expect to get– HOU/HOO Ratios that are valid (proven-worthy) for

lots of scenarios where controls don’t change.– Clear understanding of further research needs and

reasonable research planning assumptions

• Don’t expect to get – Proven-worth values for cases where controls do

change (due to lack of pre-/post- data)– Proven-worthy values for every possible scenario

where controls don’t change (expect some strays).

9

Page 10: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

10

BPA Lighting Evaluation

• Recent BPA lighting evaluation collected data for the RTF research plan for non-res lighting retrofits

• A big thank you to BPA and SBW for lots of hard and great work

• Good-sized dataset– Over 3500 total project line items (i.e. sets of fixtures)– ~400 individual lighting systems with estimates of HOO,

using RTF’s non-res lighting standardized interview guide, and metered HOU (will refer to this as the “HOU/HOO sample”)

• Note: not many non-manual controls in the sample

Page 11: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

11

Completed HOU/HOO Sample: by Building Type

Assembly

Automotive repair

College or u

niversity

Hospita

l

Industrial p

lant

Lodging

Manufacturin

gOffice

Other

Other health

Retail

School K

-12

Street &

area lighting

Warehouse

0

5

10

15

20

25

Coun

t

Page 12: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

12

Completed HOU/HOO Sample: by Building Type

Assembly

Automotive repair

College or u

niversity

Hospita

l

Industrial p

lant

Lodging

Manufacturin

gOffice

Other

Other health

Retail

School K

-12

Street &

area lighting

Warehouse

0

5

10

15

20

25

Coun

t

• 5 one-shift plants• 3 two-shift plants• 9 three-shift plants

• 2 sm offices (<20k sq ft)• 2 med offices (20-100k) • 4 lrg offices (>100k)

• 3 boutique (<5k sq ft)• 8 small (5-50k sq ft)• 2 lrg one-story (>50k)• 3 lrg multi-story (>50k)• 2 mini-mart• 2 supermarket

Page 13: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

13

Completed HOU/HOO Sample: by Space Use Type and Control Type

Conference

Stora

ge

Restroom

Break r

oom

Private office

Other

Exterio

r

Kitchen

Open office

Lodging (g

uest ro

om)

Gymnasiu

mRetail

Technica

l are

a

Parking gara

ge

Hallway

Ware

house aisl

e

Proce

ss

Classroom

Libra

ryLo

bby

Computer room

Industrial

Dining

Public asse

mblyOffice

0

5

10

15

20

25

30

35

40

45

50

Manual switch Occ Sensor Daylight Occ w/Daylight Timeclock Other controls N/A

Num

ber

of L

ighti

ng S

yste

ms

Page 14: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

14

HOU/HOO Ratios – Spaces w/ Manual Switch

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

Series1

HO

U/H

OO

Rati

o

Page 15: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

15

HOU/HOO Ratios – Spaces w/ Manual Switch

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

Series1

HO

U/H

OO

Rati

o

Mean ratio: 1.13Precision @ 90% Confidence: 7%Completed Sample Size: 32 Revised CV: 0.23Revised Sample Target (90/10): 24

Page 16: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

16

HOU/HOO Ratios – Spaces w/ Manual Switch

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

Series1

HO

U/H

OO

Rati

o

Mean ratio: 0.65Precision @ 90% Confidence: 12%Completed Sample Size: 16 Revised CV: 0.29Revised Sample Target (90/10): 22

Page 17: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

17

HOU/HOO Ratios – Spaces w/ Manual Switch

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

Series1

HO

U/H

OO

Rati

o

Mean ratio: 1.15Precision @ 90% Confidence : 26%Completed Sample Size: 15 Revised CV: 0.61Revised Sample Target (90/10): 100

Page 18: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

18

HOU/HOO Ratios – Spaces w/ Manual Switch vs. Occ Sensor

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

Series1HO

U/H

OO

Rati

o

This slide shows HOU/HOO ratios for a subset of space use types where we have both manual switches and occ sensors.

Page 19: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

19

HOU/HOO Ratios – Spaces w/ Manual Switch vs. Occ Sensor

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

Series1HO

U/H

OO

Rati

o

Be careful not to read too much into difference between these two: nearly all manual switch spaces are K-12 classrooms and all OS spaces are college/university classrooms.

Page 20: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

20

How does HOU/HOO method perform versus other potential methods of estimating HOU?

• The results of the RTF protocol’s HOU/HOO ratio method look good, but is it better than other methods we can test?

• E.g., we also have estimates of hours of use from the program, i.e. not from the protocol’s standardized interview– These are estimated by contractors most of the time– There is not a standardized method of asking for this parameter

• We can create a separate ratio using the metered HOU and the program estimated HOU and compare its performance against the RTF protocol’s standardized interview ratio method

• In addition – we can also see if the RTF protocol’s standardized interview-based ratios explain away some of the variability in metered HOU itself– I.e. if there is as much variability in the HOU/HOO ratio as there is in HOU itself

for a given space type, there is no value in the ratio

Page 21: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

21

Open Office

0 2000 4000 6000 8000 100000

1000

2000

3000

4000

5000

6000

7000

8000

9000

10000

f(x) = 0.711253720329915 x + 601.392100066137R² = 0.602486785996615

HOO

HO

U

15002000250030003500400045005000550060000

1000

2000

3000

4000

5000

6000

7000

8000

9000

10000

f(x) = 0.643881600221149 x + 1033.4876564766R² = 0.109194110749656

HOO

HO

U

precision 14% 21%

revised CV 0.34 0.52sample target (90/10) 32 73

RTF Structured Interview HOO vs. Metered HOU

Program Estimated HOU vs. Metered HOU

Structured interview-based HOO more correlated to metered HOU than non-structured interview-based HOO.

Precision is better, CV is lower, and sample target is lower.

Page 22: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

22

Retail

precision 8% 11%

revised CV 0.30 0.39sample target (90/10) 24 41

RTF Structured Interview HOO vs. Metered HOU

Program Estimated HOU vs. Metered HOU

10002000

30004000

50006000

70008000

900010000

0100020003000400050006000700080009000

10000

f(x) = 0.878212449393959 x + 913.350286415565R² = 0.594596118739673

HOO

HO

U

2000 3000 4000 5000 6000 7000 8000 9000 100000

1000

2000

3000

4000

5000

6000

7000

8000

9000

10000

f(x) = 0.631759458103372 x + 1740.58597524944R² = 0.28250857349854

HOO

HO

U

Remember: these sample points are from 18 unique sites spanning small to large retail, mini marts, and supermarkets.

Page 23: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

23

Private Office

precision 19% 18%

revised CV 0.57 0.53sample target (90/10) 87 77

RTF Structured Interview HOO vs. Metered HOU

Program Estimated HOU vs. Metered HOU

01000

20003000

40005000

60007000

80009000

100000

1000

2000

3000

4000

5000

6000

7000

f(x) = 0.201386770348074 x + 1671.11851755548R² = 0.0964764527051325

HOO

HO

U

01000

20003000

40005000

60007000

80009000

100000

1000

2000

3000

4000

5000

6000

7000

f(x) = 0.273838168637097 x + 1288.54518559392R² = 0.174610062711103

HOO

HO

UFor a couple of space types, including private office, both methods perform poorly.

Page 24: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

24

Comparison of Various Methods: Precision at 90% Confidence

Space Type HOU

HOU/HOU Ratio Based on Program Estimate/Non-Standardized Interview

HOU/HOO Ratio Based on RTF Protocol's Standardized Interview

Retail 11% 11% 8%Classroom 29% 14% 10%Private Office 22% 18% 19%Open Office 24% 21% 14%Restroom 38% 32% 28%Warehouse 24% 36% 26%Break Room 29% 31% 21%

Page 25: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

25

Comparison of Various Methods: Est. Sample Size Using Updated CVs*

Space Type HOU

HOU/HOU Ratio Based on Program Estimate/Non-Standardized Interview

HOU/HOO Ratio Based on RTF Protocol's Standardized Interview

Retail 47 41 24Classroom 222 54 27Private Office 119 77 87Open Office 101 101 73Restroom 213 154 113Warehouse 87 190 100Break Room 90 109 47Total 880 727 470

* Assuming 90% confidence, 10% precision

Page 26: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

26

BPA Findings & Concerns Regarding Protocol’s Structured Interview Method

• Much time and money spent on this research and there are still many ratios that we would still need to figure out– Once we do figure out all of the ratios, will the market have shifted and we

need to find additional ratios?– Is this process going to be simpler and cheaper in the long run than doing

impact evaluation?• Structured interview still requires onsite work, similar to impact evaluation

– is there enough of a value proposition here?• Maybe building consistency in impact evaluation methods and parameters

would be more valuable

Open this up for discussion. Also, CAT recommends bringing straw man proposal back to the full RTF in December.

Page 27: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

27

Non-Res Lighting Retrofit Baseline

• The Power Plan looks at three different non-res lighting scenarios: retrofit, natural replacement, and code compliant/new construction

• Of these three scenarios, only retrofit uses a pre-conditions baseline while the others use current practice

• The RTF retrofit protocol uses a largely pre-conditions baseline; however, it does not disqualify projects that look more like natural replacement

• Need to determine how the RTF baseline can account for these two different scenarios

Discussion? CAT recommends taking this topic to a sub-group of the RTF and bringing findings back to the full RTF.

Page 28: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

28

Update on Code Compliant Lighting

Page 29: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

A refresh – what’s code compliant lighting?

• Any lighting project that is required to comply with building lighting codes. This includes…

Newly constructed facilities

Newly constructed addition to an existing facility

A major renovation or remodel of an existing building

A change in an existing building’s Space Use Type

Page 30: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

A refresh – what’s code compliant lighting?

• Any lighting project that is required to comply with building lighting codes. This includes…

Newly constructed facilities

Newly constructed addition to an existing facility

A major renovation or remodel of an existing building

A change in an existing building’s Space Use Type

Many utility programs generally refer to these

kinds of projects as “new construction”

Page 31: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

Technical Subcommittee• Reminder: RTF directed staff to look at this measure earlier

this year• Held technical subcommittee on 10/23 to discuss the possible

development of a code compliant lighting protocol• Key topics of discussion:

– Current program activity and methods• What measures are programs offering in this space?• How are savings being computed and what is the baseline?

– LPD baseline• Is the current practice for code compliant LPDs better than code?

– Controls baseline• Is the current practice for code compliant controls better than code?• Can we deal with code compliant controls in a standardized way?

Page 32: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

Technical Subcommittee• Reminder: RTF directed staff to look at this measure earlier

this year• Held technical subcommittee on 10/23 to discuss the possible

development of a code compliant lighting protocol• Key topics of discussion:

– Current program activity and methods• What measures are programs offering in this space?• How are savings being computed and what is the baseline?

– LPD baseline• Is the current practice for code compliant LPDs better than code?

– Controls baseline• Is the current practice for code compliant controls better than code?• Can we deal with code compliant controls in a standardized way?

Subcommittee Participants:Graham Parker, PNNLChristian Douglass, RTF CATJosh Rushton, RTF CATMichael Lane, PSERoger Spring, Evergreen Consulting GroupJoe Vaccher, EWEBTravis Reeder, EWEBChris Wolgamott, BPAJennifer Light, RTF ManagerJohn Wilson, BPAKelly Sanders, NEEACharlie Grist, NPCCRoger Peery, TacomaRebecca Blanton, PSEMike Bailey, ETOTom Lienhard, Avista*Carrie Cobb, BPA**couldn’t attend call, but provided comments offline

Page 33: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

33 What are the region’s programs doing for these kind of projects?

• Surveyed a number of the region’s lighting programs– BPA, EWEB, Avista, Idaho Power, PSE, ETO

• What I found:– All programs surveyed offer some kind of non-res code compliant

lighting measures– All programs use current building codes as the baseline; however, a

few programs require project savings exceed a threshold (typically 10-20% better than code) to receive incentives

– Most programs offer measures for LPD reductions on a prescriptive or calculated basis

– Code compliant controls measures handled very differently across the region: from prescriptive/calculated to custom to not offered at all

• Another important take away from the subcommittee call: most code compliant lighting projects are not going through utility programs

Page 34: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

34

How might an RTF protocol handle savings from reduction in LPD?

Page 35: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

35

Savings from Reduction in LPD

• These are savings attributable only to a reduction in fixture kW and not related to controls (e.g. dimming)

• An RTF protocol could allow savings to be computed using either building level LPDs or space level LPDs (but not whole building simulation)

• These savings are easy to standardize and straightforward to compute, as long as we know the baseline LPD (what is the baseline?)

Page 36: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

36

Regional compliance studies have found as-built LPDs consistently lower than code

Source: “Non-Residential Energy Savings from Northwest Energy Code Changes 2008-2010”. Prepared by Mike Kennedy for NEEA. 2011.

Page 37: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

37

Small sample of recent observations also showing lower than code interior LPDs

0.0

0.3

0.6

0.9

1.2

1.5

Lig

htin

g P

ower

De

nsity

(W

/SqF

t)

110

51

115

37

116

78

118

05

125

03

125

04

125

05

125

12

125

14

126

08

126

10

120

18*

Building ID

Allowance As Reviewed

* Site 12018 used performance trade-offs to meet overall compliance

Interior Lighting by Project

Source: From October 8, 2015 NEEA code compliance pilot study presentation. Note that this is a small sample set concentrated in the Puget Sound and Tacoma areas.

Page 38: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

38

Exterior lighting LPDs also lower than code, some by a wide margin

Source: From October 8, 2015 NEEA code compliance pilot study presentation. Note that this is a small sample set concentrated in the Puget Sound and Tacoma areas.

Page 39: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

39

Analyst baseline proposal for LPDs: use current practice baseline more efficient than code

• CAT straw man proposal for interior LPDs: 15% better than existing code LPDs

• Proposal for exterior LPDs: 20% better than existing code LPDs• For example, the table below shows what the current practice proposal

would look like for ID and MT. Note that if building codes changed the current practice LPDs would not necessarily change (e.g. we may determine that current practice is in line with the new code)

BuildingType

ID/MT Code LPD

Current Practice LPD

Retail 1.4 1.2Office 0.9 0.8Warehouse 0.6 0.5Hotels 1.0 0.9Restaurants 1.6 1.4School 1.2 1.0

Page 40: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

40

How might an RTF protocol handle savings from controls?

Page 41: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

41

Savings from Controls Upgrade

• Codes have already captured much of control savings: likely smaller savings opportunity compared to reductions in LPD

• There may also be some significant penetration of controls in non-code required spaces, i.e. the current practice may be better than code

• There are likely additional research questions here that are not captured in the RTF retrofit research plan– E.g. what are controls savings fractions relative to the controls in the existing building codes– This would take some understanding of what controls savings have already come from codes

Page 42: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

42

Like LPDs, there’s evidence that controls current practice is ahead of codes

RetailClassroom

Open OfficeCorridor

Enclosed Office (<300sf)Storage

Building Core/lobby/bathroomsOffice

Conference roomsWarehouses

Patient/hotel room/Dwelling UnitMechanical Mezzanine

KitchensEating areasMain Lobby

GymsRestroom/locker

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%0%

38%19%

16%21%

8%18%

13%27%

20%5%

18%15%

3%9%

14%29%

Manual

EMS-Sweep

EMS

Occupancy

Daylight

Manual Dim

Timeclock

Multiple

Other

Note: Other includes no control (continuous 24/7 operation), circuit breaker control, and any other controls not captured else-where.

Source: 2014 CBSA, filtered for buildings constructed in 2008-2013. n = 511.

Page 43: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

43

Analyst baseline proposal for controls: use mix of “at code” and “better than code” baseline

• For spaces with code-required occupancy sensors and/or automatic daylighting, assume code baseline

• For spaces without occupancy sensor code requirement, assume some penetration of current practice occupancy sensing (OS)– CBSA suggests OS penetration of ~ 5-20% even for spaces

where not code-required– Analysts proposed 20% OS penetration for warehouses*

and open offices and 15% OS penetration for all other spaces

*Except in WA where occupancy sensors are already required by code, in which case occupancy sensors would be the baseline.

Page 44: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

44

Subcommittee Feedback

• No consensus agreement on baseline definitions– Some supported current practice view, others thought

baseline should be code

• Concerns as to whether code compliant lighting is “protocolizable”, particularly controls savings– Knowing the code-required control can require an in-depth

knowledge of building codes– Same can go for LPDs where there are exemptions– Codes vary across states and contractors cover multiple

states

Page 45: Non-Residential Lighting: Status Update Christian Douglass & Josh Rushton Regional Technical Forum November 10, 2015

45

Discussion / Recommendation

• CAT recommends the same retrofit baseline sub-group discuss code compliant baseline question

• Then, CAT will bring back a straw man “standard protocol”

• Thoughts from RTF?