I believe that once you enter the operational phase, then it would fall under EB.
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I agree with Todd in terms of logic, and in terms of making the LEED rating system useful—if you're applying it after a project is complete, it's not increasing the environmental performance of the project, which is the main point.However, as long as you can document everything, especially the prereqs, I'm not aware of any hard cutoff point when you can't pursue LEED for a completed project. I just don't recommend it, as discussed in this forum thread.
I had a similar question for a LEED-NC project, and the answer I received from USGBC was that the project could be registered up to one year after completion.
This was for a project designed and built in accordance with LEED requirements, but the client didn't decide to actually submit until after the project was complete.
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