There appears to be a confusing definition of the zoning requirement in reference to calculating whether or not a site exceeds the local zoning requirement for open space by 25% or not. It is clear that if there is NO zoning the default value for open space is 100%of building footprint. This seems very appropriate for buildings in park-like settings, such as a campus. However many downtown have zoning, but ZERO requirement for open space. It would appear that the spirit of this credit would be followed if the building were designed denser in order to create open space. A technical interpretation of this requirement would dictate that ANY outside space would qualify, since any square footage would be more than 25% bigger than zero, the zoning requirement. Our site allows a density of three stories for the entire site, with zero requirement for outside landscaped area. We are building 4 stories to allow for a small park-like public space, clearly meeting the intent of credit SS5.2. The total site is 54,000 square feet with 14,607 square feet or 27% of the site landscaped area. Discussion: For downtown sites with Zero requirement for open space credit should be given for efforts to create open space. A simple rule would be to give a credit if the open space required exceeds a certain percentage of the land, for instance 25%. A rule like that would be simple, but would not take into consideration how difficult this would be in a very high density zone such as Manhattan, so maybe there could be a formula that took the density of the building into account.