our building is really old (way older than me), contains ACM's, masonry walls with no insulation, construction of a by-gone era...... it seems unfair to compare it with EnergyStar (CBECS) database (those are predominantly modern era buildings). Plus, it has a combination of spaces unlike about any building I have ever seen. USGBC could argue that it is 50% office (by sf), but it only gets to 50% if all common spaces (closets, corridors, restrooms) are lumped into "offices". Who's to say those spaces serve only the offices in the building (in reality, those common spaces also serve the assembly, labs, other non-office spaces where people work in the building). We thought about the alternative approach of finding three "comparable" buildings, but we are not confident in what USGBC thinks "comparable" means - and we don't really think it's likely we could find anything comparable. The owner has made great strides in improving efficiency since about 2002; unfortunately, USGBC wants data no more than 6 years back (per the reference Guide). Changing envelope and major HVAC upgrades are really not feasible due to construction and (encapsulated) ACM's on airhandlers and ducts; so there is little more they can do to upgrade for energy efficiency that won't "break the bank".
We want to go for a CIR and ask exception to having to compare on Energy Star, ask exception to finding a comparable and, instead, be judged strictly on our own history of improvement since 2002 (gas and electric is all metered through local utility and all records are kept monthly). What do you all think our chances are? any advice?

When I do presentations on LEED and LEED GBOM for local trade orgs in Cinti, I often tell folks not to be discouraged if you have an old building - If I don't get "thumbs up" on this CIR, I may have to eat my words.

thank you

Tom Kennedy