We have a campus site site with areas, outside of construction limits, that contain many mature shade trees with turf grass underneath. The credit requirements on Page 177 state that a minimum of 25% of the required 30% open space "must be vegetated (turf grass does not count as vegetation) or have overhead vegetated canopy." However on Page 179 under the Design of Open Space Areas, the reference guide states: "turf areas, including turf areas under overhead tree canopies, can be counted in total open space but do not qualify as vegetated open space." Also on Page 179, overhead vegetation is described as "trees and shrubs."

This seems to indicate that the area of a tree's canopy can be counted toward the 25% vegetated space requirement, but limits it just to the tree's canopy, eliminating the counting of an entire area of a shaded lawn with areas of space open to the sky.

Is this correct?