Case 2 Option 2 (A, B, C)

Marc, In my experience there are some case when allowances are made for a lack of historic data, but this would need to happen through the CIR process.

Hello Marc & All, I have a similar situation with two other buildings that are not eligible for energy star (one is a sports arena, the other is an airport terminal). They both are part of larger complexes with a master electric meter and only started submetering recently. Their is the streamlined Option 2A, but in that case you are compared to the national average "other" buildings, which is not a good comparison for these high-use facilities. So having three years of historic data is a requirement, but it's not clear why, as in the case of these non-ratable buildings it just makes them wait for eligibility for EBOM without really making the process of measuring their energy consumption any more robust. In fact, if they wait until year 3 to improve energy efficiency, they would score better. Shouldn't they have the incentive to improve energy efficiency as soon as possible, and then to submit as soon as they want? Anyone else have thoughts on this?