In Bulgaria we have a project, which if using the Building Area Method of ASHRAE 90.1-2007 meets lighting requirements; however, using the Space by Space Method requires adjustments to be made to several small rooms. We would like to use the Space by Space method because this will give us a lower baseline in the energy model and allow us to achieve 2-4 points more than the other method. Problem is that local lighting standards require lighting levels higher than those allowed using the Space by Space method. Has anyone faced this issue before? Our planned approach is to claim Special Circumstances and show how local norms prevent compliance with the Space by Space method for