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Board debates energy-audit standard for alternative compliance plans
Summary
Evanston members debated whether ACP applicants should provide an ASHRAE Level 2 energy audit or a costlier strategic decarbonization plan for custom ACPs; IMT recommended limiting the higher-cost option to complex cases.
Members debated the level of technical documentation required for ACPs. Jessica described a three-tier approach: streamlined short-term extensions with limited paperwork, standard adjustments with defined documentation, and a custom path that would require more comprehensive analysis. She said IMT "was recommending... considering using the strategic decarbonization plan framework for the custom sort of target," arguing that a strategic plan captures capital and financial context that a Level 2 audit might miss.
Other members pushed to minimize the number of buildings required to complete the higher-cost strategic plan because it raises review burden and applicant costs. Several members and staff suggested a two-stage process: an ASHRAE Level 2 audit for many applicants, with the strategic decarbonization plan reserved for the most complex custom cases; the technical committee was asked to return with specific criteria identifying which applicants would need the higher-level plan.
