As long as the project has been actively implementing an ESC plan during the current development of the project site, you should be okay. If that's not the case, then the outcome will depend on project specifics, and you will likely need official guidance from GBCI.

LEEDuser has advised teams that in multi-phase projects, it's okay to focus documentation of the ESC plan only on the current phase, when LEED became part of the project scope. In general, if there is some question about whether controls were in place during the LEED project, you may not be able to earn the prerequisite.