Are ASHRAE 62.1-2016 exhaust rates strictly mandatory for v4.1 O+M (EQp Minimum IAQ)?

Hello LEEDuser community,

I’m working on the feasibility phase for a LEED v4.1 O+M: Existing Buildings project and ran into a gray area regarding exhaust requirements.

Project Context: It’s a 5-story mixed-use building (retail, hair salons, cafes, offices) with a 400 m2 basement parking garage. Currently, the parking garage has no mechanical exhaust.

The Dilemma: The v4.1 O+M guide for EQp: Minimum Indoor Air Quality focuses heavily on measuring outdoor air and maintaining existing equipment (Table 8.2 of ASHRAE 62.1-2016). For exhaust, it specifically says: "For spaces with mechanical exhaust, test and confirm proper operation...". This language feels operational and doesn't explicitly mandate retrofitting spaces that lack exhaust or bringing existing exhaust up to current design codes.

My Questions:

1. Parking Garage: Are we required to install a new mechanical exhaust system in the basement parking to meet ASHRAE 62.1-2016 rates to achieve this prerequisite?
2. Bathrooms & Kitchens: Do we need to prove that the existing exhaust systems in bathrooms and kitchens meet the specific exhaust rates of ASHRAE 62.1-2016, or is it enough to just verify that the existing equipment is operating properly?
3. General Scope: Does v4.1 O+M strictly mandate complying with ASHRAE 62.1-2016 exhaust design rates across the board, or is the focus purely on O&M (maintaining what's there and guaranteeing OA to occupied spaces)?

Any insights or similar experiences with reviewers on this issue would be greatly appreciated! Thanks!