The project consists of a consumer products manufacturing facility.The energy intensive manufacturing process exceeds an estimated 90% of the facility\'s total energy load. The Project Client has developed a new manufacturing process which consumes approximately 15% less energy per produced than the previous generation process.The new proprietary process has recently been installed at a similar facility and energy reduction has been demonstrated. Since industrial energy for manufacturing is not covered by ASHRAE 90.1-2007 and the building cannot be accurately modeled using the Appendix G method, project team is seeking to establish and obtain approval of an alternative compliance path.Following the Appendix G procedure would be very challenging because there are so many interacting process and non-process systems. Artificially segregating the systems in the model would not reflect energy consumption patterns accurately. Focusing on non-process components that represent less than 10% of the total energy consumption would not demonstrate the majority of the facility\'s energy savings. Manufacturing process improvements targeted at the other 90% of energy usage have a much greater impact on the entire facility\'s energy consumption. Instead of creating an energy model, baseline and proposed energy consumption will be compared by utilizing an Energy Consumption Index (ECI), which is recognized by the Association of Energy Engineers as an accepted methodology for calculating energy consumption in a manufacturing facility. The Project Client has tabulated historical overall site energy data and production at an existing facility which uses only the previous generation manufacturing platform and is also tabulating data from a site with new generation equipment. The energy data from both of these plants is not sub-metered between process and building loads because there is little economic benefit to meter the small building-only loads. An alternative compliance path will be established using the overall site ECI. Please verify that the following method may be used for determining the entire facility\'s energy cost savings.PROPOSED COMPLIANCE PATH:1. Baseline Building:The existing baseline site
Using the Energy Consumption Index instead of ASHRAE 90.1-2007 Appendix G to determine the annual cost savings of the building is not acceptable. The manufacturing process(es) should be calculated using the Exceptional Calculation methodology. A narrative should describe all Baseline and Proposed case assumptions included for this measure, and the calculation methodology used to determine the project savings. The narrative and energy savings should be reported separately from efficiency measures in the template Section 1.7. Additionally, documentation should be provided to verify that the manufacturing process is not standard practice for a similar newly constructed facility by including a recently published document, a utility incentive program that incentivizes the new process, or by documenting the systems used to perform the same function in other newly constructed facilities. While it is acceptable to use monitored data from a similar facility (constructed within the last five years) to document these exceptional calculation savings using a per product or per pound metric, sufficient information must be provided to document the nature of the efficiency improvements made, and to confirm that the data has been normalized appropriately. Specific product names are not required, and the specific details of the manufacturing process are not required; however, the description of the efficiency improvements to the manufacturing process must be adequate to allow the reviewer to confirm that improvements in energy consumption are tied to improved equipment or controls efficiency, and are not associated with decreases in building square footage, differing project locations, local climate data, quantity of shifts operating per day, etc. Any process energy differences related to local climate or weather (such as refrigeration energy, boiler energy, etc.) should be accounted for in the data normalization process, and the method used for normalizing must be clearly indicated. Ensure the same utility rate is used for the proposed case, baseline case, and exceptional calculation. Additionally, all mandatory requirements of ASHRAE 90.1-2007 must be met."