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<br /> <br />unknowns as design continues to develop. There are opportunities for <br />greater efficiency that the team intends to pursue, such as lighting power <br />density reductions, but there are also potential increases to the energy <br />load as more information becomes available both regarding the process <br />loads of the tenant’s operations and the temperature and soil conditions <br />of the site for the Darcy well operation. The current design assumes that <br />the Darcy wells connected to the office & process loops can achieve the <br />full cooling needs of the project, but should the test well in the future <br />prove that is not possible, a supplementary chiller may need to be added <br />which would increase the electricity usage of the project above what the <br />current results represent. <br /> <br />For these reasons, we believe the proposed % target is a fair assessment <br />that reflects both the design team’s best efforts to achieve the goal of <br />the Sustainable Design Guidelines with real conditions factored in. <br /> <br />Full Waiver 2.2.2 <br />Electrification <br />Technological This waiver requests to substitute the full electrification goal to an <br />operational carbon reduction goal for the project, with a target of 65% <br />or greater reduction against the typical “cost base” system that would <br />have been proposed if the Guidelines were not in place. Energy modeling <br />conducted to date demonstrates that this is feasible with the proposed <br />design (currently showing 67%), and the team believes it prudent to <br />include a slight buffer for the same reasons described in the efficiency <br />narrative above. Additional efficiency measures to reduce interior loads <br />such as lighting, equipment, and processes will continue to be studied <br />through the Xcel EDA process and as the tenant interior design develops <br />further. <br /> <br />While all-electric designs were studied by the team and are reflected on <br />the Energy & Carbon Results table, the rough-order-of-magnitude pricing <br />that the team has provided based on real subcontractor estimates of <br />these conceptual systems demonstrate that the all-electric designs are <br />both out of the project’s budget and do not provide a feasible payback <br />period when IRA incentives are not included, as in the case of this deal <br />structure. The cost increase for the all-electric option (2B) compared to <br />its similar option which includes natural gas heating (1A) is due to both <br />slight premiums on equipment itself, but primarily the increased <br />requirements for electrical services to be supplied to the site for this <br />equipment. Substitution of air-source heat-pump rooftop units in lieu of <br />gas-fired DX rooftop units, for example, will require an additional <br />dedicated service, as will the substitution of gas boilers for electric boilers <br />of a similar efficiency. <br /> <br />Pursuit of the IRA incentives is not believed to be viable with Option 1-A <br />both due to the same deal structure limits mentioned above, but also <br />due to the lowered contribution of the ground-source system towards <br />the project’s overall energy load. The team will continue to review the <br />viability on both counts but at this time does not believe the IRA <br />incentives could be pursued in any option on this project.