Hello,
We typically implement Option D of IPMVP and calibrate the model once one-year of actual energy data is obtained. 
The proposed model than becomes the baseline and the actual becomes the proposed.
We can use this data to facilitate an energy audit if the actual does not match the proposed, especially if the actual use is much higher than expected. 
In this instance sub-metering is not required. This method has been approved by GBCI on numerous occasions.
Recently GBCI provided technical advice that "sub-metering is required".
We are in the process of working with GBCI to better understand their concern.
Marcus, I am curious if you have anything to add or advise....although i am sure your are worn out by now when responding to "do we need sub-metering for EAc5 per IPMVP Option D?"
thanks!
Dave