Many building owners in Philadelphia are looking for opportunities to significantly reduce energy use and costs and ensure the comfort and safety of their residents. The new Building Energy Performance Program, also referred to as “Building Tune-Ups”, is designed to help building owners identify low or no cost opportunities for savings.
A building tune-up is a review of energy systems, controls, and maintenance practices, along with minor tweaks to bring them up to a good state of performance. On average, these tweaks result in 10– 15% annual energy savings for a building. A building tune-up is essentially retrocommissioning, the process of ensuring that systems are operating and maintained as intended. The City released a Tune-Up Workbook which lists the building elements to be reviewed, corrected, and reassessed.
For those already working to improve the performance of their buildings, or looking to identify capital investments for large energy projects, they can pursue several different High Performance Pathways to comply with the program. With the High Performance deadline coming up on April 4th, we break down the different pathways and documentation requirements for each one below.
Retrocommisioning or Recommissioning Procedure
Retrocommissioning is the systematic process applied to existing buildings (that weren’t commissioned during design) to ensure that their systems can be operated and maintained according to the owner’s needs. Recommissioning is the term for applying this process to a building that has been commissioned previously (either during construction or as an existing building). If a building owner is already conducting full retrocommissiong or recommissioning procedures, they can submit documentation instead of following and completing the Tune-Up Workbook.
Documentation: High Performance Workbook; Evidence that the provider covered at least 75% of the Covered Building’s square footage; Evidence that it met the energy reduction requirements promulgated in Phase 3 of Act 129.
Timing: Must be completed within 3 years of the compliance deadline.
Utility retrocommissioning program
Building owners can also take advantage of PECO’s custom retro-commissioning program. PECO’s custom measures generally require pre/post upgrade trend data (either equipment level or whole building level) as the basis of savings. The International Performance Measurement and Verification Protocol (IPMVP) is typically used to qualify and quantify those savings. The custom savings analysis extrapolates savings to one year and those extrapolated kWh savings are incentivized at $0.10/kWh.
Documentation: High Performance Workbook; Evidence of completed whole building retrocommissioning approved by PECO
Timing: Must be completed within 3 years of the compliance deadline.
Ongoing Commissioning
Ongoing Commissioning is using monitoring equipment for continuous diagnostics. Depending on the building systems, there are two options to pursue: Manual Ongoing Commissioning or Automated Active Optimization (CCx)
Manual Ongoing Commissioning
Documentation: High Performance Workbook; Ongoing commissioning plan (with all the elements required in LEED Operations and Maintenance Ongoing Commissioning Energy and Atmosphere credit); One year of quarterly (or more frequent) reports that detail findings from efforts and corrections made.
Automated Active Optimization (CCx)
Documentation: High Performance Workbook; Description of the system(s); One year of quarterly (or more frequent) reports generated by the automated system that include:
- Faults/issues detected
- Date of each fault/issue was detected
- Date of correction/repair for each fault/issue, if corrected/repaired
- Staff/vendor notes on what was done to remedy each fault/issue (optional)
Timeline: One year of reports from the compliance deadline year. Note: Building owner may request an extension of no more than 2 years from the Compliance Deadline to implement the Active Optimization and collect relevant data.
Energy Audit
Like a Tune-Up, Energy Audit’s identify measures that, if implemented, will save energy. However, Energy Audits go beyond the review of existing systems and include measures that involve purchasing and installing new capital equipment, such as new chillers, pumps or boilers. To pursue this pathway, an ASHRAE level 2 audit should be performed. A cover letter and report will need to be provided by the energy audit lead verifying that low/no cost EE measures (defined as providing a simple payback of three years or less) have been implemented.
Documentation: High Performance Workbook; Energy Audit cover letter; Energy Audit Report listing all low/no cost EE measures that have been implemented.
Timing: Energy Audit must have been completed within 3 years of the compliance deadline. Note: Building owner may request a non-guaranteed extension of 1 year to submit the required documentation
LEED for Building Operations & Maintenance (Gold or Platinum)
LEED for Building Operations & Maintenance is a rating system issued by USGBC. In order to be in compliance, a LEED certificate and the LEED scorecard are required, which indicate what points the project received for categories such as Water Efficiency, Energy & Atmosphere, Material, Indoor Air Quality, and more.
Documentation: High Performance Workbook; LEED certificate for Building Operations and Maintenance; LEED scorecard
Timing: Certification needs to be awarded within 3 years of the compliance deadline.
Zero Energy Certification
Zero Energy Certification (ZE) is issued by the International Living Future Institute. The standard requires “one hundred percent of the building’s energy needs on a net annual basis must be supplied by on-site renewable energy. No combustion is allowed.”
Documentation: High Performance Workbook; Zero Energy Certification with any summary documentation.
Timing: Certification needs to be issued within 3 years of the compliance deadline.
ENERGY STAR Certification
Similar to appliances, ENERGY STAR offers Certification for Buildings. To earn an ENERGY STAR Certification, a building must earn a score of 75 or higher and the application must be verified and submitted by a licensed PE or RA.
Documentation: High Performance Workbook; A copy of the EPA-issued ENERGY STAR Certificate of Achievement (or the congratulatory email confirming certification); A copy of the application for Certification (or the Statement of Energy Performance (SEP) with the same year-ending date as the application).
Timeline: The year immediately preceding the Compliance Deadline (accepting 2019 certification in ‘21 and ’22)
15% Energy Savings
If a building can prove a 15% energy savings then this is also considered high-performance. This requires an ENERGY STAR Statement of Energy Performance (SEP) for the 3 calendar years prior to your compliance year. Note: This must be signed off by any person who meets the Tune-Up Specialist qualifications (PE or CEM; 7 years experience). The Tune-Up Specialist will need to prove that the reductions aren’t related to occupancy/use changes.
Documentation: High Performance Workbook; ENERGY STAR SEP for the 3 calendar years prior to compliance year; Cover letter verifying accuracy of the reports by a Tune-Up Specialist (this cover letter should demonstrate generated savings from completed ECMs on a high level and verify that all Portfolio Manager data has been adjusted due to COVID-19.)
Timing: ENERGY STAR SEPs should be generated for each year within 3 years of the Compliance Deadline. Note: Building owner may request a non-guaranteed extension of 1 year to submit the required documentation.
C-PACE Participation
Additionally, if a 15% energy reduction is achieved using Commercial Property-Assessed Clean Energy (C-PACE) financing, the C-PACE program administrator can verify these savings. This borrowing tool allows borrows to save money on utility bills while reducing the carbon footprint.
Documentation: High Performance Workbook; Cover letter from C-PACE Program Administrator
Timing: Within 3 years of compliance deadline
Low Site EUI
For the Low Site EUI, you’ll need to provide an ENERGY STAR Statement of Energy Performance demonstrating a weather normalized site EUI equal to or less than 20 kbtu/sq for at least two of the three preceding calendar years prior to the compliance deadline. This must be signed off by any person who meets the Tune-Up Specialist qualifications (PE or CEM; 7 years experience). The Tune-Up Specialist will need to prove that the low site EUI is not related to occupancy/use changes.
Documentation: High Performance Workbook; A copy of the Statement of Energy Performance (SEP) for each of the qualifying years demonstrating a weather-normalized site EUI equal to or less than twenty (20) kBTU/sq; Cover letter verifying accuracy of the reports by a Tune-Up Specialist (this cover letter should demonstrate generated savings from completed ECMs on a high level and verify that all Portfolio Manager data has been adjusted due to COVID-19.)
Timing: For at least 2 of the 3 preceding calendar years prior to the Compliance Deadline