Multi-family - Energy Disclosure Requirement

Courtney, we have a similar situation to yours in that we do not have access to whole building utility data. We are currently in the process of certifying several large multi-family projects under LEED NC 2009. Requirement #6: Sharing Energy and Water Data requires that "all available actual whole-project energy and water usage data" be shared for a period of five years post-certification. This presents a serious challenge (if not impossibility) for our projects since the utility does not allow us to install a submeter on the incoming switchgear for dwelling units. On a side note, it is extremely disappointing that the utility does not allow this (we wanted to be prepared for ENERGY STAR Certification for existing multi-family buildings which is rolling out this year). The only other available option is to install a submeter on each dwelling unit which represents hundreds of submeters per project. The language also states that "I understand that if my project does not have meters in place that measure energy and/or water usage for the entire LEED certified gross floor area, I will not be required to supply energy and/or water usage data unless and until such meters are installed." Does this mean that we can avoid submetering each unit? At the very least, I would think that we could meet this requirement by requesting aggregated utility data from the utility.