M&V plan required for case 1, or not?

Dave - good question. It looks like you've caught one of the areas where LEED 2009 has subtly changed from older versions of LEED. Under LEED-CI v2.0 there was no requirement for a plan if your space was less than 75% of the building area. But under LEED CI 2009, the requirement is clearly there, right in the credit language. To make things more confusing, the reference guide goes on to describe what is required, but for Case 1, makes no further mention of a plan. But it's there in the credit template as well. I have to admit the requirement came as a surprise to me. I'm wondering where the new requirement came from, and if it was really the intention of the USGBC to get M&V plans for small CI projects. I am checking with a few sources, to see if I can get some insight. As soon as I know more, I'll post it here.

I have confirmed with USGBC staff that requirement for an M&V plan under Case 1 is an error in the reference guide. If you download the rating system itself, you'll see that the language is no longer in the requirements. So no M&V plan needed under Case 1. LEED Online will be updated eventually. In the meantime, you should just "check the box" so that you can submit.

Would this also hold true for LEED-CS EA 5.2: M&V Tenant Submetering? I have a large 12 storey medical office building project where there will never be a tenant larger than 75% of the space. We are trying for LEED-CS which has under the requirements: "Develop a tenant measurement and verification plan that documents and advises future tenants of this opportunity [to meet the LEED-CI EA Credit 3] and the means of achievement." But which M&V plan do we use, when none will be required to meet the CI credit?

This is another subtle, but confusing choice of language. What is required for CS EA 5.2 is not really an M&V "plan" in the way that it is used in other M&V credits, but rather a guidance document that advises the tenants of the metering opportunity, how it works, how to connect, etc. The requirement for corrective directives/action is also dubious given the context. I would suggest just ignoring it.