Exceptional Calculation for Process Loads Without Recent Conventional Practice

Hi all,

I'm working on the Minimum Energy Performance and Optimize Energy Performance credits for a specialized manufacturing facility where we've found that the ASHRAE 90.1-2012 baseline interior equipment load is 57% of the energy use, leaving only 43% of the building energy use as targetable for energy reduction. The process loads significantly limit the potential points from this credit unless an exceptional calculation is included to  show process energy reductions. Our client is confident that the manufacturing processes of their facility will include valuable energy reduction strategies, primarily by implementing economies of scale that will reduce the total number of cycles required for production. 

The problem is that the guide for exceptional calculations under this credit is clear about documenting that the process load reduction "represents a significant verifiable departure from documented conventional practice", but the facility manufactures a specialized product for which documentable conventional practice is very limited. As far as my team is aware, this client is the only company who does this work in the United States.

There are two possibilities I see for documenting a meaningful load reduction for this process:

1. The client has other facilities that could be used as a point of comparison for "conventional practice". However, the guide for exceptional calculations provides that potential documentation could include "A document showing the systems used to perform the same function in similar facilities built within the past five years". The problem here is, as far as we are aware, no facilities have been built for this application in the past five years- How likely is it that our documentation for conventional practice would be accepted if we compare to the client's most recently constructed existing facility available, even if it wasn't built in the past five years?
2. Since we're arguing based on economies of scale, we could possibly show proof of this with calculations showing how this larger facility has more efficient processes than the client's existing buildings which could not be employed in those spaces. Would this have a shot if we went for it?

Any other thoughts are welcome as well.

Thank you!