I'm working on a CI project (a San Francisco city pool) where the owner/occupant of the project (the city of San Francisco) is the same as the owner of the building (the city of San Francisco). As such, there is no lease involved. However, we believe we are meeting the intent because there is a long term commitment as the space will be used indefinitely as a pool. Do you think we are eligible for this point, and, if so, would we explain the situation in a Special Circumstance?
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