Doug,
Technically, this approach would not work, as the PERF-1 Report to which you refer to is in reference to the fact that an energy model is a "Performance" approach to achieving Title 24. In a "Performance" Approach, you DO have to comply with the mandatory requirements of the standard, but you do NOT need to comply with the prescriptive ones.
That said, EAc1 and EAp2 in NC (aka BD&C) have long accepted that a building that complies with a performance approach meets the requirements of the prescriptive approach. If you feel that this approach is your best option, submit it and if the reviewer says that it's inappropriate, you use the prescriptive approach as your Review Comment Response.