LEED Reference Guide 2.0 details the requirements for comparing the savings of regulated energy components per ASHRAE 90.1. The designed building is compared to a base building of similar characteristics. The reference guide also notes that the LEED Energy Performance Protocol (EMP) has some major differences from the Energy Cost Budget (ECB) method. The major difference between the LEED\'s EMP and ASHRAE\'s ECB method is the requirement to separate out regulated from non-regulated loads in the LEED method. Non-regulated loads are defined as "plug loads, process energy, garage ventilation, exterior lighting, elevators, and any other miscellaneous energy uses in the building." The mathematical equations and examples in the Reference Guide show that the energy consumption associated with these non-regulated loads are to be subtracted from the over-all building energy usage. The subtracted energy from the non-regulated energy loads includes any mechanical heating and cooling, lighting, fan and pump power, lighting, and domestic hot water used in meeting the demands of these loads. Only the ratio\'s of the regulated loads ("HVAC systems, building envelope, service hot water systems, lighting and other regulated systems as defined by ASHRAE.") are to be used in determining the percentage energy differences between the designed and base buildings. Separating out these non-regulated loads and the energy loads associated with their mechanical system support is difficult. If a watts per square foot value of non-regulated energy is assumed, than calculations must be made, as an example, to estimate the percentage of air handler fan energy that were required by these non-regulated loads. My question is rather than include these non-regulated loads in the calculations and then subtract them out, wouldn\'\'t it be easier and more accurate if these non-regulated loads were left out of the energy simulation? i.e. Perform the energy modeling on buildings "empty" of non-regulated loads, where the only loads analyzed are the ASHRAE regulated loads of building skin, ventilation, lighting, HVAC equipment, and heating hot water. In pursuing credits for energy performance optimization for our office building LEED design, I have done an annual energy consumption simulation using the Carrier HAP software. Our design was superior to the base design through the use of a heat recovery unit on the ventilation air, high efficiency air cooled condensers and boilers, lower air handler static pressure requirements through the use of underfloor plenums, high quality building glass and roof insulation, lower lighting loads per square foot, and daylighting controls in a top floor area with wall and clerestory windows that significantly decrease the lighting load for that area. In this energy simulation, I did not include in the analysis non-regulated loads, such as people or a watts per square foot load to simulate the plug loads associated with computers, copiers, coffee pots, etc. The resultant comparison showed an energy savings in excess of 25%. If I included the non-regulated loads in the analysis, than subtracted out their associated energy consumption, I would end up with the same result. Is this method acceptable for submitting on the Energy Optimization Credit?