I've had dialogue with several people, including on the technical staff at USGBC about this question, since as you point out it is a bit unclear in the Reference Guide and other materials.As best I can tell, for LEED-CI EAp3, fire suppression systems and CFC prohibition are only in effect if those systems are within the tenant scope of work. If those systems ARE within the scope of work, CFCs may not be used.If a project team has an ambiguous situation relative to this requirement, it is recommended that they get a CIR.