If a 6,000,000 square foot hotel/casino is more than 50% hotel space, are they required to use Option 1 - Portfolio Manager to get an Energy Star rating?   If you look at most of the larger casino's in Las Vegas, they have multiple hotel towers and only a few hundred thousand square feet of casino space, the rest being spaces like convention, restaurant, office, etc. But over 50% is hotel for sure.

If they are not required to use Option 1, can they use the other options and show a dramatic decrease in energy over a few years or get data on other similar properties to show they are in the top 19% of similar properties?