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I would say no. ASHRAE addendum AU to 90.1-2010 (ASHRAE 90.1-2013) actually includes a deduction (negative pressure drop adjustment) for systems without any central heating or cooling device as well as systems with electric resistance heating vs HW coils. Link to addendum

Commentary from Foreword of Addendum AU:

Adds a deduction for systems without any central heating or cooling device. Since the base-level fan power allowances include the assumption that those components are present, the deduction is warranted for those systems that do not include those component.

I've had trouble with this myself, but the project had exhaust fans driving the ventilation (automotive repair bays) so the fan powers were much closer, but still over the 0.3w/cfm. The bays did have quite a few overhead fans for non-mechanical cooling. That is really the only credit the fan power calculation allows for system 10 & 11 (9 & 10 in 90.1-2010). As far as what I see anyway.