We are getting some comments from the reviewer that indicate 1) We must include surfaces of interior non-structural walls in our calcs (this is new from other versions guidance)  and 2) that we must account for existing/new interior finishes ( from ref guide - List the surface area of structural elements, enclosure materials, and interior finishes such as walls, doors, floor coverings, and ceiling finishes).

Some questions arise here:

1) for non-structural walls (up to three surfaces in an assembly so think drywall-frame-drywall) - in most uses/intentions this would literally make this credit approach impossible even if they gave you three roofs, three skins, and three floors) there is just porportionally a lot more of this SFA than the shell/roof/floor of the building.  This is counter-intuitive and against all principles of embodied carbon that we've learned over the past decade that you are saving the best portion of the building by re-using the skin, foundations, deck and roof and just re-positioning the interior for its intended or speculative use. 

2) if interior 'finishes' (by LEED ref guide...walls, doors, floor coverings and ceilings) do not exist nor are they in my plans to develop -- how would I be discounted in that we are buying an empty shell and delivering only slightly more on a core within that shell?  - Fully understand any partitions that are in my scope would be new and would be negative SFA (x3 mind you). But if no interior partitions exist when I purchase it because it was gutted...how would one even guess what the total vertical SF would be (x3) of previous?  Seems like if something doesn't exist and I'm not delivering it...that it is essentially neutral and in both the numerator and the denominator.  or...no impact to the calculation.  This would apply to ceiling and flooring as well.  It wasn't there...and I'm not delivering it...how would I need to account for it?  Do we just put all these items into the table or calc and just put them as ZERO existed anc ZERO replaced...just to show the reviewer we aren't addressing it in the calc?  Seems like if it isn't in the calculation in any way that one is already saying they don't have it and aren't delivering it.  if that is the approach here...happy to do those mechanics just to show this.

So, sorry for the thesis...but these two new guides from the review comments really change the approach or nature of this credit entirely....  as a CRE developer you'd literally be stuck with a building previous use and have no ability to repostion or repurpose the space without disqualifying you from the intent...which was to reduce impacts from new EC versus old.  Further, in the C/S system...why would we be looking at non-structual interiors anyway?  LEEC CI has specific re-use guidelines for interior non-structural assemblies.  if its in the TI/CI....then ....it should be addressed over in that rating system right?  Sorry....not meaning to rant...just looking for some advice from anyone facing this already.