We are working on a Manufacturing Project in Vietnam with very high non-regulated loads (around 75% of the total energy consumption). It is designed without air conditioning, mechanical ventilation will provide adequate thermal comfort at a level acceptable in the tropics. I have a question related to the same project and credit but regarding the validity of this LEED Interpretation for LEED v4. I still would like to know if anyone has experience or insight on the following question in case we need to pursue this path. 

For this project, the Energy Modeling for EAc2 will require us to simulate cooling that is not part of the design to achieve the right indoor temperature and humidity as required by ASHRAE 90.1. As the volume of the spaces is large, a lot of equipment and an envelope designed to be light and open up for natural ventilation, the extra cooling load becomes particularly large (approximately 20GWh/year), about 200% more than the total actual expected consumption (approximately 10GWh/year). 

My question is, is there a case for us to use the actual naturally ventilated consumption simulation result for EAc5, considering that EAc2 consumption will give a result 3 times higher than what we actually expect? Has anybody faced this issue before?