Our project is going for LEED v4 BD+C: NC so the energy model is based on ASHRAE 90.1-2010 in which the baseline HVAC system type is based on the proposed heating fuel type. However, this project is in climate zone 5A and has electric heat pumps coupled with heat recovery from an effluent system which is not typical but very efficient. This means that the baseline HVAC system type is also electric (System 4 PSZ-HP). We believe the project isn't seeing as much energy savings as expected because the baseline has to have the same heating fuel source as the proposed -- almost seems like the project is being penalized for going electric when the team chose this HVAC system because of its commitment to energy and GHG reduction. 

ASHRAE 90.1-2013 appears to address this issue by requiring the baseline system type to be based on the project's climate zone instead of the proposed fuel type so that the baseline would now be System 3 PSZ-AC. We looked into LEED interpretation 10481 which allows for the usage of ASHRAE 90.1-2013, but the wording seems to imply that only projects regulated by ASHRAE 90.1-2013 by code are allowed to use this interpretation. Does anyone know if this is true? This project isn't regulated by ASHRAE 90.1-2013 so it would be a shame if the project couldn't get more energy savings because of this baseline type issue.

Or is there any other interpretation or addendum that would allow for a project to use ASHRAE 90.1-2013 or use the baseline system type table from ASHRAE 90.1-2013?

Thank you!