Our project is a Mall Building wherein the Owner of the Mall is trying for certification. There are 100's of retailers occupying the building. As per the preliminary review, we have been asked to use Option 2, Case-2 calculator. In this there are 2 further options which seems possible –
· Option 2B - comparing with historic data of the same building

· & Option 2C – comparing building energy data with other similar building.

The power supply in Mall building is such that each retailer gets an individual bill from the supply company. Summation of all retailer bills along with the Mall common area energy consumption will give total energy consumption of the building.
However the project is facing a typical challenge in collecting historical bills, particularly from all the retailers who occupy the building.
Energy Bills for the Mall common area along with energy figures of all the retailers is available with the project team.
We have collated energy data of the entire building backed by samples of retailer bills for current performance period. Also Historic energy consumption is available.
However historic energy bills of last 3-years of large number of retailer who occupy the building is not available.
Thus in such cases, is there any exempt available in documentation particularly submitting bills of the retailers.
Also is there an exemption from submitting Historical Bills for last 3-years of retailers?
Even using Option 2C will have same issues. Is Option 2C calculator without energy bills from the comparative buildings accepted?

Documents requirement in template is unclear where it is mentioned that energy bills of atleast 3-months of current performance period is required. But there is no mention of historic bill requirement.