90.1-2007, Clean Filters for "Better" Energy Performance

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All,

I'm just playing devil's advocate here...

What is stopping me from scheduling a lower fan BHp that meets say a 66%
loaded filter, but providing a fan motor that can truly handle a fully
loaded filter (even with some safety), assuming I still comply with
section 6.5.3.1.2? Because the 90.1-2007 fan BHp baseline is not
tracking of the proposed fan BHp, this would give me a "better"
performing building.

Although I do not see the above approach as honest, nothing is
indicating in 90.1-2007 that this cannot be done. Unless I missed
something...

Again, I'm not supporting this be done, but am curious where in
90.1-2007 that it clearly calls out this is not to be done.

As a side note, I don't believe the 2008 CA Energy Code even offers a
limitation to the designer not scheduling a lower CFM. The baseline
building tracks the fan energy up to a defined W/CFM, not really
crediting a designer for real fan energy savings (i.e. larger ducts,
better duct design, larger coils (for lower face velocity), etc.).
Although a designer may not get credited for the "lower" fan energy with
scheduling an artificially low fan BHp for a cleaner filter, they may
not get penalized as much as if they scheduled a BHp for a fully loaded
filter.

Any thoughts on this? Anyone on the 90.1-2007 committee that could shed
some insight?

Thanks,

R. Ryan Hammond PE, HBDP, BEMP, LEED AP

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