Public Utility Commission of
Texas
Approach to Texas Technical Reference
Manual
Revised: June 12, 2013
Public Utility Commission of
Texas
Approach to Texas Technical Reference
Manual
Revised: June 12, 2013
Copyright © 2013 Tetra Tech, Inc. All Rights Reserved.
www.tetratech.com
ii
Approach to Texas Technical Reference Manual. June 12, 2013
TABLE OF CONTENTS
1. Overview ........................................................................................................... 1-1
2. Purpose and Audience for the Texas Technical Reference Manual ............ 2-1
3. Best Practices/Guiding Principles in Developing TRMs .............................. 3-1
3.1 Lesson 1: Clearly Define Organizational Roles for Developing and Maintaining
the TRM
3.2 Lesson 2: Do Not Strive for Perfection; Instead, Minimize Potential Systematic
Bias
3.3 Lesson 3: Provide Documentation of All of the Sources Used to Develop
Proposed Savings Values, Inputs, and Algorithms
3.4 Lesson 4: Publish a Schedule for Maintaining and Updating TRM Inputs and
Algorithms, and Resist Efforts to Change it
3.5 Lesson 5: Provide Clear Guidance About the Criteria and Levels of Savings
Documentation Required for New or Revised TRM Measure-Savings Estimates
3.6 Lesson 6: Provide Clear Definitions of How Peak Demand Savings will be
Estimated Within the TRM and How this Relates to Competing Definitions of
Peak Savings
3-1
3-3
3-3
3-4
3-4
3-5
4. TRM Version 1.0 Development and Scope..................................................... 4-1
5. TRM Content, Structure, and Format ............................................................. 5-1
5.1 TRM Outline
5.2 TRM Measure Template
5-1
5-3
6. Peak Demand Savings ..................................................................................... 6-1
6.1 Peak Demand Definitions
6-1
7. Maintaining and Expanding the TRM in Texas .............................................. 7-1
7.1
7.2
7.3
7.4
Overall Philosophy
TRM Update Frequency
Coordinating TRM Development with Evaluation Planning
TRM DEVELOPMENT Schedule
7-1
7-1
7-1
7-2
8. Summary of TRM Version 1.0 Content and Expectations for 2014 TRM
Updates ............................................................................................................. 8-4
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1.
OVERVIEW
In 2011, the Texas Legislature enacted SB 1125, which required the Public Utility
Commission of Texas (PUCT) to develop an Evaluation, Measurement, and Verification
(EM&V) framework that promotes effective program design and consistent and streamlined
reporting. The EM&V framework is outlined in P.U.C. SUBST. R. 25.181, relating to Energy
Efficiency Goal (Project No. 39674). The PUCT selected through the Request for Proposals
473-13-00105, Project No. 40891 an independent, third party (EM&V) contractor. The PUCT
selected an EM&V team led by Tetra Tech that includes Texas A&M Center for Applied
Technology, Texas Energy Engineering Services, Inc. (TEESI), The Cadmus Group, Itron,
and Johnson Consulting Group.
The objectives of the EM&V effort are to:
 Document gross and net energy and demand impacts of utilities’ individual energy
efficiency and load management portfolios
 Determine program cost-effectiveness
 Provide feedback to the PUCT, utilities, and other stakeholders on program portfolio
performance
 Prepare and maintain a state-wide Technical Reference Manual.
This document addresses the last objective summarizing the EM&V team’s proposed
approach to prepare and maintain a statewide Technical Reference Manual.
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2.
PURPOSE AND AUDIENCE FOR THE TEXAS TECHNICAL
REFERENCE MANUAL
The purpose of the Texas Technical Reference Manual (TRM) is to serve as a common
reference document for all stakeholders engaged in estimating energy and peak savings at
the measure or end-use level. The document will be designed to provide centralized access
to all of the pre-approved equations and inputs for estimating energy savings from one or
more energy-efficiency and demand-response program(s) approved by the Public Utility
Commission of Texas (PUCT). The data and algorithms housed in the TRM are to be used by
electric utilities who serve as program administrators (PA) for the following starting with
Program Year 2014:
1. The basis for forecasting projected program savings
2. Reporting claimed savings
The PUCT will distribute annually to the Energy Efficiency Implementation Project (EEIP) and
host a meeting to review and adopt all of the TRM inputs and algorithms used to estimate
savings. This will result in savings methods and the assumptions behind them, to the extent
possible, being uniformly applied across all program areas. This will ensure consistency in
estimating savings across programs and utility areas and estimating program-level cost
effectiveness. By establishing clear qualification criteria for the development of ex-ante1
claimed savings estimates, the TRM will provide transparency of claimed savings for all
interested stakeholders.
The TRM document will also provide guidance on the frequency that key inputs and/or
equations should be updated based on the vintage of the input parameters, as well as the
EM&V team’s assessment of the level of variability in likely savings estimates across the
range of likely applications. The intent is to help participants in the energy-efficiency market
save money and time by providing a single database of all deemed savings estimates and
equations. Finally, the TRM will provide clear criteria for deciding whether future efficient
technologies or systems are good candidates for being included in the TRM as a deemed
measure savings estimate, or a deemed algorithm with stipulated or variable parameters.
1
Ex-ante means before the event, ex-ante savings are forecasted savings expected from the measure
installation.
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3.
BEST PRACTICES/GUIDING PRINCIPLES IN DEVELOPING
TRMS
The EM&V team will take advantage of the lessons learned from developing deemed savings
manuals or TRMs from more than 15 other states and jurisdictions over the last two decades.
This section distills the key lessons the EM&V team learned from developing TRMs in other
states over the last decade and explains how these lessons apply to the unique
characteristics of the Texas energy-efficiency market.
3.1
LESSON 1: CLEARLY DEFINE ORGANIZATIONAL ROLES FOR
DEVELOPING AND MAINTAINING THE TRM
The first, and perhaps most important, lesson learned from previous TRM development
efforts is that failure to clearly define roles at the beginning of TRM development can lead to
delays. It can also hinder the opportunity to implement a uniform savings approach for new
measures as well as reduce the PAs’ motivation to introduce new measures or measure
updates because of the perceived difficulty of participating in the TRM review process. As
such, the EM&V team will clearly outline the respective roles of organizations interested in
developing, reviewing, and adopting TRM changes.
Table 3-1 identifies the key roles for developing, maintaining, and adopting TRM values and
equations and explains these responsibilities going forward compliant with the Rule. Phase 1
represents the approach to develop the first version of the TRM building on the existing
deemed savings practices, while Phase 2 represents organizational roles and responsibility
for annual updates going forward.
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3. Best Practices/Guiding Principles in Developing TRMs
Table 3-1. Summary of Organizational Roles
Organizations Responsible
Key Function
Deemed Savings and
Development of TRM
(Phase 1)
Annual Updates to TRM
(Phase 2)
Sponsor new measures for
deemed savings approval
and inclusion in the TRM
2
through the petition process
PAs and Energy
Efficiency Service
Providers (EESP)
identify and propose
measures
EM&V team develops criteria
for measures that are good
TRM candidates; PAs and
EESPs are still responsible for
proposing new measures to
the TRM through the petition
process
Propose savings algorithms,
tools, or measure values
PAs and EESPs for
new or existing
measures with EM&V
team review based on
experience in other
markets, EM&V team
for existing deemed
savings
PAs and EESPs provide input
on priority updates, EM&V
team revises/updates based
on evaluated savings results
and experience in other
markets
Provide technical review of
algorithms, inputs, and critical
assumptions
PUCT staff and the EM&V team
Review of petition(s) or
annual TRM by all
stakeholders
PUCT, Energy Efficiency Implementation Project (EEIP)
Adopt final savings algorithms
and values
PUCT staff
The advantages of the EM&V team’s role are briefly summarized next:
1. Establishing criteria for new measures increases the likelihood that candidate
deemed measures are identified early and that the necessary data to develop key
inputs can be integrated with on-going implementation and evaluation efforts, which
reduces program costs over time.
2. Being involved in the technical review process supports standardized savings
algorithms across service areas and deemed measures that conform to industry
standard practice.
3. The EM&V technical review function brings independence to the review process,
which could otherwise be perceived as biased toward the needs of specific
stakeholders.
2
Measures approved through the petition process would be available for program use and would not
have to wait for inclusion in a TRM update.
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3. Best Practices/Guiding Principles in Developing TRMs
4. Targeted analysis of the costs, benefits, and uncertainties associated with deeming
savings values provides information for the PUCT and other stakeholders to review
new measures and approved measure updates.
5. Recommending updated measure inputs and algorithms on a regular basis will
ensure that policy and planning decisions are made with the most recent and best
estimates of savings and will increase the accuracy of claimed savings.
The challenges of adding the EM&V team and TRM into the established deemed savings
process are twofold:
1. There is a short-term cost associated with hiring an outside team to develop a TRM
framework and a working relationship within the energy-efficiency community.
2. Evaluators may advocate for higher levels of confidence and precision in savings
estimates for Texas to confirm with industry best practice, which may in the short run
be difficult for PAs to support.
To proactively address these challenges, the EM&V team will work to establish a costefficient TRM process that provides objectivity while facilitating that measurement costs are
reasonably minimized. The end benefit of the changes in roles and responsibilities will be to
increase the value of existing deemed savings tools and templates and free the PA resources
to develop and launch new energy-efficiency programs.
3.2
LESSON 2: DO NOT STRIVE FOR PERFECTION; INSTEAD, MINIMIZE
POTENTIAL SYSTEMATIC BIAS
In some jurisdictions, there is much ongoing debate among the various parties in pursuit of
achieving a higher level of accuracy in savings estimates, which may be cost prohibitive or
unrealistic. Rather, the best practice, which we will use in Texas, is to ensure that the
evaluation method being used is based on actual data. The tendency to set unattainable
goals can be mitigated by first developing reasonable periods for reviewing and commenting
on proposed values in the TRM update process, and openly discussing the estimated costs of
adding more time to the review efforts without necessarily increasing the accuracy of savings
estimates.
The EM&V team will ensure that all parties understand that the pursuit of perfect or more
accurate savings estimates in a specific utility area or programs has a real cost. That cost
needs to be considered against the benefits of using a consistent approach to developing exante savings estimates, which may be less accurate but are reasonable and not
systematically biased up or down.
3.3
LESSON 3: PROVIDE DOCUMENTATION OF ALL OF THE SOURCES
USED TO DEVELOP PROPOSED SAVINGS VALUES, INPUTS, AND
ALGORITHMS
Many of the first generation TRMs developed in the late 1980s and early 1990s did not
properly cite the sources used to derive savings algorithms or simply cited the inputs as
“engineering judgment.” Surveys of TRM users have revealed that users and program
stakeholders tend to discount the value of TRMs when reference sources for each estimate
are not available.
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3. Best Practices/Guiding Principles in Developing TRMs
While in some cases, engineering judgment and stipulated values will be needed,
transparency and disclosure about a lack of information to support any particular input is a
better practice for two reasons:
1. Clearly identifying where savings sources are sparse or not available allows
evaluation teams to consider the need for primary data collection which can provide
a grounded and more accurate estimate within a short time period. Following this
best practice will allow the EM&V team to prioritize these parameters in their
evaluation work.
2. Failure to cite sources often leads to disputes on the usefulness of savings values
and creates challenges to reporting savings claims, which can cause additional
regulatory delays.
For both of these reasons, the EM&V team will clearly document all the sources used to
support its estimates, will state its confidence in the estimates, and will provide a plan to
update the values where no sources are available. The Texas TRM will maintain credibility by
including these details.
3.4
LESSON 4: PUBLISH A SCHEDULE FOR MAINTAINING AND UPDATING
TRM INPUTS AND ALGORITHMS, AND RESIST EFFORTS TO CHANGE IT
The EM&V team is aware of many TRM development efforts that have failed to meet
completion deadlines set by policymakers because of a desire by some stakeholder(s) for
special treatment and/or delays to allow for time for data collection or analysis. In most cases,
it is better to produce a revised TRM at regular intervals, because it increases the credibility
of the process itself and allows for economies of scale in updating a large batch of measures
at once as opposed to processing measure updates one at a time. The Texas TRM will be
updated annually on a schedule agreed to by the PUCT and PAs and provided to
stakeholders through EEIP notification.
3.5
LESSON 5: PROVIDE CLEAR GUIDANCE ABOUT THE CRITERIA AND
LEVELS OF SAVINGS DOCUMENTATION REQUIRED FOR NEW OR
REVISED TRM MEASURE-SAVINGS ESTIMATES
Of course, not every energy efficiency measure should be included in a TRM. The TRM
works best for providing estimates for prescriptive measures. It is not cost effective or prudent
to try to develop deemed savings estimates for custom measure installations or instances
where operating conditions may vary significantly across measure installations. PAs and
EESP measure sponsors should be provided with a set of criteria for deciding when the
savings for a measure should be:
 A deemed average energy savings value
 Only derived though the use of a savings algorithm (with a mix of fixed inputs and
inputs that require some form of data collection)
 Excluded from consideration as a TRM measure because of the high variability in onsite operating conditions or interactions with other energy-using systems.
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3. Best Practices/Guiding Principles in Developing TRMs
As presented under Table 3-1, Summary of Roles, the EM&V team will develop explicit
criteria to guide the PAs and EESP program designers’/developers’ identification of new
measures.
3.6
LESSON 6: PROVIDE CLEAR DEFINITIONS OF HOW PEAK DEMAND
SAVINGS WILL BE ESTIMATED WITHIN THE TRM AND HOW THIS
RELATES TO COMPETING DEFINITIONS OF PEAK SAVINGS
The use of multiple peak demand savings within a common TRM leads to user confusion. In
both California and Maryland, the existence of different definitions of peak demand used by
individual utilities versus the independent system operator has led to the need for developing
special tools to translate peak savings into alternative definitions3. California requires that PAs
develop 8,7604 hourly load profiles for each end use and building type application to ensure
that all possible definitions can be supported by the data. This requirement was ultimately
met, but at a significant cost, because annual load shapes had to be generated for over 200
measures.
The EM&V team suggests that the PUCT and stakeholders agree on a peak demand savings
definition and the rules for operationalizing the calculation of peak demand, as well as have
the underlying 8,760 data used to support each calculation available upon request. Given the
uncertainty around the calculated peak demand values (e.g., the diversity of operations
across the population, non-coincidence with system peak, weather), an average peak savings
value over a subset of the full peak period is likely to be a better estimate than an average
over the full period. Due to the importance of peak demand savings, peak demand issues are
fully discussed in a separate EM&V team memo, and only basic peak demand definitions are
provided in this document.
3
The electric utilities and the Electric Reliability Council of Texas (ERCOT) use the same definition of
peak demand, which is found in §25.181(C)(46).
4
There are a total of 8,760 hours in a year assuming that the measure is operated 365 days a year, 24
hours a day.
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4.
TRM VERSION 1.0 DEVELOPMENT AND SCOPE
Broadly speaking, the EM&V team intends to develop ex-ante savings estimates for approved
energy efficiency, solar, and load management (LM) deemed savings measures or systems.
The information needed to develop both first year and lifetime ex ante savings will eventually
be provided by the TRM. The savings from the TRM will then be used to report and calculate
incentives for those measures. For each measure or system, the ex-ante estimate will be
stipulated in a protocol as a deemed value (e.g., savings for measure X are 46 kWh5/year) or
as a deemed algorithm with partially or fully deemed variables (e.g., kWh/year = (A – B) * C,
where A, B, and/or C are variables based on a look-up table and/or site-specific data). The
look-up tables will be based on data from building simulations or may be commonly accepted
parameters. For example, the hours-of-use parameter may be based on building type and
assumed given typical operating conditions. The TRM document will not include guidance on
appropriate M&V plans at the site level for custom projects because this topic is best
addressed in the Texas EM&V guidelines and is not a part of the deemed savings review
process.
The EM&V team will include 50 measures in the 2013 TRM (v1.0), split approximately evenly
between nonresidential and residential applications. The team anticipates completing the
TRM draft in October 2013, allowing the utilities time to adopt the savings assumptions for the
2014 program year. Per §25.181(q)(6)(D), the savings estimates should not be retroactively
applied.
To determine which measures should be included in the first iteration of the TRM, the EM&V
team will prioritize measures based on several factors drawing on our experience with other
states’ TRMs, including whether the measures represent a significant portion of
portfolio/program claimed energy and demand savings; whether they are already present in
existing deemed savings databases; the volume of rebates processed; common measures in
other jurisdictions’ TRMs; the accuracy by which a deemed savings value can be determined,
primarily based on uncertainty or variance in operating conditions; and interest from utilities or
stakeholders in a given measure. Once the team has an initial list of measures, it will develop
TRM protocols. Through that process, the team may determine that a given measure will not
work well within the TRM framework and will propose an alternative.
The EM&V team will begin development of the TRM protocols by reviewing assumptions used
in the current deemed savings database. This review will incorporate as many of the current
assumptions as reasonable in order to minimize differences. Part of this review will account
for any baseline or efficiency changes that have occurred since origination of the database.
The EM&V team will also review other TRMs adopted around the country, focusing on
regions with similar climate zones and program maturity to Texas. It will also incorporate the
algorithms developed through the US Department of Energy’s Uniform Methods Project6, as
applicable, to help ensure consistency and transparency with the commonly accepted
approaches to EM&V. This review will inform which measures are best suited for savings
values and which require algorithms. In general, measures with weather variation and large
variance in building-specific hours of use or construction are best stipulated by algorithms.
5
6
Kilowatt hour.
http://www1.eere.energy.gov/office_eere/de_ump.html.
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4. TRM Version 1.0 Development and Scope
For example, commercial measures often require an algorithm rather than a simple deemed
value. The EM&V team will leverage existing TRMs to determine the best approaches for
estimating ex-ante savings.
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5.
TRM CONTENT, STRUCTURE, AND FORMAT
The purpose of the TRM will be to document deemed savings and deemed savings
algorithms for measures offered through Texas utility programs. A program measure is
defined as an installed piece of efficient equipment or system; a strategy intended to affect
consumer energy use behaviors; or modification of equipment, systems, or operation
schedules that reduces the amount of energy that would otherwise have been used to deliver
an equivalent or improved level of energy services. For the Texas TRM, a TRM measure
includes all attributes related to the measure, as well as the practical use and application of
the TRM Measure, which will be considered and specified in defining a TRM Measure and the
resulting savings estimates. The attributes to be considered include but are not limited to:
sector, building type, equipment type, technology type, physical configuration, size,
performance characteristics and/or categories, Federal efficiency standard categories,
operating hours, specialized locations/applications (i.e. high-bay), market condition (replace
on burnout or early replacement) and program delivery mechanism.
The TRM will be composed of a main document, supplemented by calculators for use in
determining savings values based on inputted parameters. The Microsoft Excel® workbooks
(calculators) developed for measures in Texas will be incorporated in the TRM. For example,
within the document, the template for commercial lighting will include the algorithm used to
estimate the savings, and the calculator will be included, which provides the means for
estimating the savings based on the given inputs (building type, bulb wattage, etc.).7 Other
formats will be explored, solicited, and considered during the development of the TRM.
The main document will have an overview of the TRM and will explain what it includes and
does not include and how it is used. Measure-specific templates will follow, divided into two
major sections for (1) energy-efficiency measures and (2) load management programs. Those
sections will be subdivided based on residential and nonresidential application. The energyefficiency section will be organized by end use categories (lighting, space heating, etc.). The
proposed outline is provided below, followed by the specific template to be used for each
measure.
5.1
TRM OUTLINE
The proposed TRM document outline is provided in Figure 5-1. Note that the list of measure
categories provided in this figure is meant to be illustrative and not exhaustive. The final,
actual list of measure categories will be determined through the TRM review process. Also
note that the TRM will include an extensive glossary of the terms used in the TRM.
7
This TRM database will also include savings calculations for the measures evaluated with the existing
calculators and deemed savings values.
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5. TRM Content, Structure, and Format
Figure 5-1. Proposed TRM Outline
I.
II.
III.
IV.
V.
VI.
VII.
TRM Purpose
Instructions for Using the TRM
TRM Update Process
Glossary
Energy-Efficiency Measure Categories
a. Residential
i.
Lighting
ii.
Space heating
iii.
Space cooling
iv.
Building envelope
v.
Water heating
vi.
Appliances
vii.
Plug load
viii.
Fuel switching
ix.
Renewable energy
b. Nonresidential
i.
Lighting
ii.
Space heating
iii.
Space cooling
iv.
Building envelope
v.
Water heating
vi.
Motors
vii.
Fuel switching
viii.
Renewable energy
Load Management/Demand Response Programs
a. Residential
i.
Critical peak pricing/Critical peak rebate
ii.
Direct load control
b. Nonresidential
i.
Time-of-use
ii.
Direct load control
iii.
Voluntary load control
Appendices
Although this document is intended to outline only the general TRM approach, two critical
components of the TRM are discussed in more detail. The first is the Measure Templates,
which provide the measure level detail and savings calculations, and will make up the
majority of the TRM. The second is a brief discussion of Peak Demand, and the issues that
need to be discussed and resolved in a separate peak demand memo.
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5. TRM Content, Structure, and Format
5.2
TRM MEASURE TEMPLATE
Each measure template will include the sections shown in Table 5-1. Each template is divided
into three key sections:
 Measure Identifier-Tracking Fields. This section includes data that will be used to
identify, characterize, and track the measure. The “Measure ID” field is a critical, key
parameter and should be used as a key index for referencing the source of measure
savings wherever it is used, such as in a tracking database, calculators, etc. An
example is “RS.LTG.INC-CFL. R2,” which would mean Residential, Lighting,
Incandescent to CFL, Revision 2.
 Measure Assumptions and Calculations. This section includes the measure
definition, savings assumptions and equations, measure life, tracking data
requirements, as well as an assessment from the EM&V team regarding the
confidence in the savings estimates. Eventually, both gross and net savings will be
included in the TRM. However, the first version of TRM will only have gross savings,
but the second version should contain a compendium on net-to-gross ratios by
program type and delivery mechanism after the first generation of evaluation studies
are completed.
 References, Efficiency Standards, and Revision History. This section will provide
a list of the primary references sources used for stipulated values and equation
approaches as well as petition numbers and other rulings. It will also include a
discussion of relevant efficiency standards, especially recent or impending changes
that can affect baseline assumptions. In addition, any changes and revisions to
specific measure templates will be tracked individually in the Revision History
section.
For each measure template, it is important to note that parameters such as measure
description, market sector, decision/action type, and other program features, are identified in
§25.181as “applicability requirements”. For utilities to be able to apply TRM deemed savings
to estimate total program savings, the program and measure must meet all of the applicability
requirements.
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5. TRM Content, Structure, and Format
Table 5-1. TRM Measure Template Sections
Section/Parameter
Description/Example
Measure Identifier-Tracking Fields
TRM Measure ID
This is a unique measure code for use in tracking each TRM
measure. Encoded characteristics could include: sector (residential
vs. nonresidential), end use, technology, version or date, program
type (SOP, MTP, solar, etc.), implementation type (prescriptive,
custom, direct install, upstream/downstream), decision type (early
replacement, retrofit, replace-on-burnout, new construction), etc. This
is a key field for the traceability of deemed measure claims. Lists of
alternate or enhanced TRM Measure IDs could also be provided in
this section.
TRM Measure
This represents the level at which an energy efficiency measure will
be addressed in the Texas TRM. In creating a TRM Measure, all
attributes related to the measure, as well as the practical use and
application of the TRM Measure results, will be considered and
specified in defining a TRM Measure and the resulting savings
estimates. The attributes to be considered include but are not limited
to, sector, building type, equipment type, technology type, physical
configuration, size, performance characteristics and/or categories,
Federal efficiency Standard categories, operating hours, specialized
locations/applications (i.e. high-bay), market condition (replace on
burnout or early replacement), program delivery
Measure Description
A brief description of the efficient measure, including the minimum
requirements for applying the deemed results.
Effective Date, Last
Revision Date, Sunset
Date
The Effective Date is when the measure can be used. The Last
Revision Date is the date of the last change; this will allow individual
measure templates to be changed without changing the TRM. The
Sunset Date is the recommended date for determining whether to
revise the savings value or approach.
Market Sector
This identifies whether the measure applies to the residential or
nonresidential sector
Measure Category(ies)
Examples of this are lighting, HVAC, space cooling, space heating. A
standardized list of Measure Categories will be generated that can be
used across the TRM and tracking data systems.
Fuels Affected
Electric or gas (including any interactive HVAC effects)
Decision/Action Type
Specifies whether the measure was installed as early replacement,
retrofit, replace-on-burnout, or new construction.
Other Program Features
Specifies direct install, prescriptive, low-income, etc.
Savings Methodology
Examples include: building simulation, metering study, billing analysis
study
Calculator Available
If a calculator that uses the underlying deemed equations and
stipulated values for the measure is available, this section will provide
the name and/or link to that calculator.
Measure Assumptions and Calculations
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5. TRM Content, Structure, and Format
Section/Parameter
Description/Example
Annual Energy Savings
Provides the values, calculations, assumptions, and primary
reference used to determine the stipulated values’ normalized annual
electric (and gas, if appropriate) savings. Interactive HVAC effects will
also be applied, if appropriate. Both gross savings and estimates of
net to gross ratios by program delivery mechanism will eventually be
included in the TRM, see note in body of report.
Seasonal Energy
Savings Pattern
This is also sometimes called time-of-use (TOU) energy percentages
or buckets, or incorrectly called load shapes. This table will present a
summary of the distribution of annual energy use across the four
primary TOU periods—summer peak, winter peak, on-peak, and offpeak. This information is also commonly used for cost-effectiveness
analysis—it can be easily generated from 8760 data and the TOU
period definitions.
Peak Demand Savings
This will include summer peak and winter peak estimates and will
explain the concept of claimed peak demand savings (based on
whichever peak the utility uses to meet goals) as well as the need to
report all three values in the tracking system. For LM programs, this
section of the template may outline a LM peak period savings and the
associated event times as well as outlining aspects specific to solar
impacts.
Confidence in Estimates
This will be a simple assessment of the EM&V team’s confidence in
the results, based on (1) the length of time since primary research
was conducted, (2) confidence in the secondary research supporting
results, (3) the rapidity of changes in underlying assumptions due to
changes in program implementation or changes in the market, and (4)
confidence in the stipulated parameters and the need for better
evaluation of those parameters.
Tracking Data
Requirements
This section will specify the recommended list of primary inputs and
contextual data needed for evaluation and proper application of the
savings. For example, the application of interactive HVAC factors
should require tracking the type of HVAC system (or at least
determining whether an air conditioning system is present) and
determining the fuel type of the heating system. Otherwise, the
interactive HVAC savings should not be applied.
Measure Life
This section will include the effective useful life (EUL) of the measure,
the relevant petition number, a citation of the reference source, and
any discussion related to remaining useful life and early replacement
applications. (All EULs are currently stored in a spreadsheet that uses
EndUse and Energy Efficiency Measure as primary fields.)
References, Efficiency Standards, and Revision History
Petitions and Rulings
This will contain a running list of the relevant petitions and rulings
related to deemed savings for the specific measure.
Relevant Standards
This section notes any applicable energy-efficiency standard (Federal
Appliance Standards, ASHRAE 90.1, etc.)
Reference Sources
Lists the sources used for inputs to savings, values, and deemed
savings equations, including the sample sizes used to develop
average inputs, if possible.
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5. TRM Content, Structure, and Format
Section/Parameter
Description/Example
Document Revision
History
Contains a running list of the relevant changes for each version. The
EM&V team will decide what constitutes the need for a version
change, but is related to confidence in estimates and sunset date
provided above.
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6.
PEAK DEMAND SAVINGS
The definition of peak demand savings reported by energy-efficiency programs should be as
consistent as possible with the peak demand basis used for the PUCT goals. As specified in
§25.181(e)(3)(B), peak savings goals are determined based on a rolling five-year average of
a utility’s growth in summer, weather-adjusted, annual system peak demand or by applying
the percentage goal to the summer weather-adjusted five year average peak demand.
However, in practice, this consistency may not be feasible, because the timing of the actual
summer or winter peak cannot be known a priori8 and integrated into peak savings
calculations at the measure level.
Furthermore, for energy-efficiency measures, it is not possible to determine the exact
coincidence of the maximum demand savings with the utility system peak period. The
definition of utility system peak is a single maximum peak demand value that occurs during
the entire summer peak period.9 The challenge is finding a calculation method that will yield
the best estimate of or proxy for expected system peak demand savings. Estimates of peak
demand for energy-efficiency measures are usually based on engineering estimates and
calculations of the likely average demand usage or savings over a preset time interval at the
site level, without reference to coincidence with the system peak.
Given the importance of peak demand savings, only basic definitions are provided in this
document, and peak demand issues are fully discussed in a separate EM&V team memo10.
6.1
PEAK DEMAND DEFINITIONS
Summer and winter peak demand periods are defined in §25.181 as:

“Summer Peak Period. The summer peak period is defined as 1 p.m. to 7 p.m. (6
hours), during the months of June, July, August, and September, excluding
weekends and Federal holidays.” (sic)
 “Winter Peak Period. The winter peak period is defined as 6 to 10 a.m. and 6 to 10
p.m. (8 hours total), during the months of December, January, and February,
excluding weekends and Federal holidays. Note that this is actually two distinct time
periods, one in the morning and one in the evening.” (sic)
Using only a winter peak demand value would not be consistent with the basis for determining
progress toward energy-efficiency peak savings goals. However, §25.181 contains additional
direction and definition of peak demand (bold added for emphasis):
 The direction states that: “Utilities may apply peak savings on a per project basis to
summer or winter peak, but not to both summer and winter peaks.” (sic)
8
a priori means being presumed without examination, presumed.
The following article mentions peak demand records set by ERCOT in June during the hours from
4:00 p.m. to 5:00 p.m., as well as those set in July and the all-time record high, which was set on
August 3, 2011: http://www.ercot.com/news/press_releases/show/26237.
10
Mike Messenger, Itron, Bryan Ward, Cadmus and Lark Lee, Tetra Tech. Peak Demand Savings:
Definitions, Calculations and Issues. Date TBD (June 2013)
9
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6. Peak Demand Savings
 “Peak Demand. Electrical demand at the times of highest annual demand on the
utility’s system. Peak demand refers to Texas retail peak demand and, therefore,
does not include demand of retail customers in other states or wholesale customers.”
(sic)
 “Peak Demand Reduction. Reduction in demand on the utility's system at the
times of the utility’s summer peak period or winter peak period.”
The definition of peak demand reduction being “at the times of the utility’s summer peak
period or winter peak period” does not provide any explicit guidance about whether peak
demand reduction or savings should be calculated as average savings over the entire peak
period or estimated as the maximum peak savings observed over the same time period. The
EM&V team concludes that it has the discretion to select the best peak savings definition for
both use in the TRM and for reporting peak savings to the PUCT.
Load management programs’ direct load control (DLC) event periods also need to be
considered for defining peak demand savings.11 It appears that DLC events are generally run
within the same peak period as defined in §25.181, although at least one utility is known to
have run a residential event from 4:00 p.m. to 8:00 p.m. However, the same issue of which
metric to use—the maximum or the average over the DLC event period—still needs to be
addressed. In addition, because DLC events may be defined differently (typically as a subset)
than the system peak demand period, a LM peak demand savings value and the associated
event times will likely also need to be tracked for DLC programs.
11
A variety of names and acronyms are used for these types of programs, so the EM&V team will
consider selecting a single reference label. In addition to those cited in the text, there are also
demand response (DR) and load control peak demand savings values.
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7.
MAINTAINING AND EXPANDING THE TRM IN TEXAS
7.1
OVERALL PHILOSOPHY
The EM&V team plans to assess the need for changes or updates to future TRMs based
primarily on (a) feedback from the organizations that use the TRM values and equations for
planning or reporting purposes and (b) the EM&V team’s assessment of changes in measure
technology and measure baselines due to changes in common practices, codes and/or
standards. The team will make a recommendation about the scope and detail needed for
future updates to savings algorithms and values based on input gathered from PAs, EESPs,
the PUCT staff and other stakeholders, and based on considering the uncertainties and
potential for bias in current TRM estimates.
7.2
TRM UPDATE FREQUENCY
The PUCT asked the EM&V team to provide an initial TRM (v1.0, to be completed in October
2013) and one annual TRM update (v2.0, to be completed in September 2014) as part of its
first contract scope. P.U.C. SUBST. R. 25.181(q)(6)(B) specifies the TRM is then to be
reviewed annually. Once the TRM becomes established, the PUCT and other stakeholders
may want to consider the need for update frequency based on the following factors: (1) the
number and complexity of new measures proposed annually by PAs; (2) the degree of
uncertainty of savings estimates determined in the initial review process; (3) the EM&V
team’s relative success updating saving inputs as part of the annual savings verification
process; (4) changes in baselines; (5) new data made available from site-based M&V
activities; and (6) the cost of updating the TRM annually.
7.3
COORDINATING TRM DEVELOPMENT WITH EVALUATION PLANNING
The EM&V team plans to identify specific inputs to energy-savings algorithms for new and
existing measures that require additional primary data collection in Texas as part of the initial
TRM development in the summer of 2013.12 At that time, the team will meet with PAs and
seek agreement on which stakeholder organization is best suited to collect and process the
data needed to increase the accuracy of savings estimates for the next TRM update. The
team will discuss this data collection plan with the PUCT, and incorporate it into the
evaluation plans for the 2014-2015 program year cycles. The intent of this process is to
ensure that an updated schedule is included for each measure and that the TRM includes at
least a description of the proposed data collection needs for utilities to integrate into their
future data collection efforts within the overall evaluation plan.
12
Mike Messenger, Itron, and Lark Lee, Tetra Tech. Deemed Savings and the Technical Reference
Manual. March 25, 2013.
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7. Maintaining and Expanding the TRM in Texas
7.4
TRM SCHEDULE
The EM&V team will submit a detailed schedule for TRM version 1.0 that includes draft
submission dates, comment due dates, EEIP meeting, and the date for submitting the final
version, which will be submitted within 30 days of the date this framework is finalized.
The application of the TRMs for program year (PY) planning and evaluation is indicated in
Table 7-1. The publication dates for each version of the TRM indicate the date that the TRM
is expected to be finalized and approved by PUCT staff. It will be submitted for review two
months prior to the publication date. An EEIP meeting will be held approximately one month
before the publication date for presentation of key changes, providing a forum for questions
and comments before each version is finalized.
The proposed schedule ensures that any changes in savings values from a TRM will first be
used in a program plan year filing and then the same TRM values will be used in the annual
claimed savings filed for that program year. This schedule results in consistently applying any
changes made to saving values in TRM updates to both the program year plan (or forecast of
savings) and the filed report of claimed savings for that program year.
For example, Table 7-1 below illustrates how changes in savings values proposed in the TRM
v2A in February of 2014 will first be used in the program year 2015 plan filing in April of 2014
and then later in the claimed savings for the 2015 program year filed in April 2016 . This
practice of using the deemed values in the same version of the TRM for estimating savings in
both the program plan year filing and the annual claimed savings ensures an apples to apples
comparison between projected and claimed savings. The existing process13 for establishing
deemed values for new measures will continue to be the mechanism for introduction of
deemed values for new measures. Any deemed values adopted by the PUCT through the
established petition process two weeks prior to the submission of the draft TRM will be
incorporated into the draft TRM. Any deemed values adopted by the PUCT at least two
weeks prior to the date of the final version of the TRM will be incorporated into the final
version of the TRM.
Table 7-1. TRM Rollout and Applicability to Utility Plans & Program Evaluation
TRM Version
and
Publication
Date
Program Year for
Which TRM is Used
(Program Year Plan
Filing Date)
TRM v1
Oct 2013
PY2014
(April 2013)
April 2015/May 2015
TRM v2A
Feb 2014
PY2015
(April 2014)
April 2016/May 2016
Annual Claimed
Savings/EM&V Report
Dates
Notes/Comments
Inventory/summary of current
deemed savings approaches and
differences; Foreshadowing of any
anticipated changes for TRM v2A.
First version with EM&V team
recommended changes,
intermediate/interim/accelerated
version for use with PY2015
13
With the recent modifications incorporating EM&V review of the deemed values to be submitted in
the petition outlined in the memo with the subject Deemed Savings and the Technical Reference
Manual. Submitted on March 25, 2013.
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7. Maintaining and Expanding the TRM in Texas
TRM v2B
Sep 2014
TRM v3
Sep 2015
PY2016
(April 2015)
PY2017
(April 2016)
April 2017/May 2017
April 2018/May 2018
program planning.
First full cycle version of TRM, new
measures and revisions.
Annual TRM update (not part of
current EM&V team workscope).
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8. Summary of TRM Version 1.0 Content and Expectations for TRM VERSIOn 2.0
8.
SUMMARY OF TRM VERSION 1.0 CONTENT AND
EXPECTATIONS FOR TRM VERSION 2.0
The objective of TRM 1.0, to be completed in 2013, is to provide a comprehensive and
consistently formatted summary of the existing deemed savings data currently used in Texas.
This TRM will also provide recommendations for any additional measures for the next version
(version 2.0) of the TRM. It will provide the rules for estimating peak impacts (winter and
summer), and it will foreshadow any changes that are anticipated for existing measures.
Version 2.0 of the TRM, completed in 2014, will be informed by evaluation activities
conducted up to the time it is submitted and will incorporate additional measures that have
been adopted by the PUCT through the petition process.
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