Reactivating construction with ESC Plan, no ESC Plan before

Hello! We have a project that started construction some time ago, and stopped 1 yr ago, leaving only the foundation. At this time, they were not considering LEED as an objective. Now, the project has changed (scope and the proposed building itself), there are different investors (same owner, though) and they have a different commercial focus. They want to reactivate construction, and they are truly interested in pursuing LEED Certification and addressing environmental impact of their construction. The question is, if they start implementing the ESC Plan as soon as the construction process reactivates and through the rest of construction, is it acceptable to earn the prerrequisite, even though on the previous "phase" (foundation) they didn't implement it?? Thanks!!