Basement That Extends to Plot line

I suppose that yes - it can be considered, but under some conditions - it depends on how deep under the surface is the upper slab of the basement floor – am I right that all area that is not under building footprint is over the basement floor? If the ground over the slab is deep enough – for my opinion 1-1,5 metres (3-5 feet) from the “zero” level – it could be counted as thickness of soil that can provide almost as natural conditions to plants. So vegetation on such cover can be considered as “on ground”. If the depth is 20-30 centimeters (up to 1 feet) – it’s definitely not enough to provide normal vegetation of plants – but in such case, if all area above basement is considered as a huge planter, you can try to pursue 5 % rule (I suppose that area over the basement is more than 5 %). If the depth is between 0.3-1 metres (1-3 feet) – it depends on type of vegetation – for grass and bushes such thickness would be enough, for trees – not. If I were you I would try this strategy to convince reviewers, what you have to loose, and this credits are pretty simple and contributing good number of points in relation to the effort. Also, you can take a look at inquire (and answer) of Jens Apel (Jul 25 2014) – in her/his case they used “planting bed with a depth of approx. 1.5 meters”.