The credit requirements ask tenants to scale their carbon offsets / REC purchases based on CBECS data, if a tenant energy model is not available. Many jurisdictions have benchmarking laws for larger commercial buildings that make the building's actual consumption data a matter of public record.
One strategy to get the consumption data needed to purchase carbon offsets / RECs would be to use the base building's own consumption data, prorated based on the proportion of rentable square feet dedicated to the tenant project.
Has anyone seen this strategy before?
It may require an Interpretation to formalize it - does anyone see any obstacles to this strategy?
Seems like it could be more accurate than generic CBECS data, provided the tenant type for the LEED project was comparable to the past tenancy, and provided the building was not substantially unoccupied during the benchmarking period.