All projects (including urban projects with zero lot lines) must implement ongoing E&S controls on their sites, in addition to the controls employed during construction activities. Applications stating that ongoing E&S controls are not applicable to the site are routinely rejected during the LEED review process. Think about E&S in terms of what’s leaving your site and polluting receiving waters during both normal operations and construction projects. For normal operations, urban buildings with zero or minimal lot lines tend to focus on E&S controls that keep garbage, cigarette butts, and detritus from making their way from courtyard or sidewalk areas to storm drains.