It seems to me I read at some point in time that the CaGBC wanted to see a minimum measurable benefit for Innovative Strategies. (Note: I'm not asking about Exemplary Performance where you are achieving the next incremental threshold.) I'm thinking, for example if you were incorporating an innovative waste heat recovery system then they may require (or at least suggest) that it achieve at least the equivalent of one EAc1 point in energy savings.
This is a LEED 2009 project. The Reference Guide simply says that strategies are to have "significant, measurable environmental benefits...".