Sounds like you'd really like to get a discussion going, so here goes...
How did the creators of this credit approach the issue of double-counting the benefits with the inherent EAc1 overlap?
Granted, the energy "saved" during the 12 month performance period would be negligible in EB, but the energy cost benefits could be modeled in NC, depending on the rate provided by the utility. [The NC model raises a few more questions, regarding whether to use the same rate in the baseline model - but I suppose that's for another post on the EAc1 forum.]
I'm intrigued at the prospect of pilot credits, and the potential for using this as a method to test new documentation requirements prior to widespread release (even for existing credits). However, I'd like to have easier access to the credit forms prior to registering projects for some pilot credits that don't seem to align quite as well.