This pilot credit includes a XL file with tables B through H to calculate savings in terms of GHGs, site energy, source energy, energy cost, peak demand and "if available": TDV and Primary Energy Factors (PEF).
My first question is: Are design teams able to cherry-pick the most impressive savings among tables B through H to determine percentage savings for EAc1? And can the same be said to show compliance with the April 8, 2016 increased EAp2 requirements?
For PEF in table G, it notes: This path is available for locations where public databases of the Primary Energy Factors calculated using ISO Standard 16346:2013 are available. Projects in all other locations must demonstrate a reasonable effort to obtain and advocate for availability of the data necessary to compute Primary energy.
For TDV in table H it notes: Projects in all other locations (outside CA) must demonstrate a reasonable effort to obtain and advocate for availability of the data necessary to compute TDV energy.
My second question is: What effort is required to show the team attempted to create its own TDV file apart from a draft proposal to E3 to do so? E3 and the CEC have published their methodology but even if an individual were to attempt to create their own, who would validate it?
Regarding PEF, TDV is hourly, so is a flat annual PEF for electricity acceptable or would the PEFs need to be hourly to account for grid loading at peak and accurately demonstrate when renewables are producing? Who would the project team lobby in order to try to get PEFs for its eGRID Subregion? Their local utility or the EIA? EIA data for a subregion already includes the basic components to calculate an annual PEF, but would omit imported electricity, which could be 20-25%. Similarly EIA has hourly emissions data for each subregion but only for a single day for each month. From that you might be able to determine the grid sources but only for 288 hours of the year.
Thanks in advance for any insight.