Project Boundaries and New ROW

Hello, The project that I'm working on is going to involve construction of additional rights of way in the form of a collector street/woonerf running through the project and connecting to existing streets at both ends. In determining the project boundary for LEED ND, my understanding is that the boundary must be drawn along property lines or public-access rights of way. My question is: Can we use the boundary of our to-be-constructed right of way as the project boundary when applying for Stage 3 certification? Thanks