A food manufacturing company has a total of (29) active manufacturing plants across North America. All sites currently measure BTU/Lb of product to identify energy use trends. One of our requests is to confirm the use of this ratio as our basis for indicating the energy use reduction at the individual sites. We cite a CIR dated 4/23/2008 that approved the BTU/lb of product for an oat by-product manufacturing process. We also request ruling on our approach for EA prerequisite 2 and EA Credit 1 under the LEED-EBv2.0 rating system. The specific items addressed in this CIR are(1) site specific energy use reduction and (2) a corporate baseline energy use reduction. Although the exact product mix and volume of snacks at each site varies, the overall energy use baseline created by combining 29 sites constitutes a viable "corporate" baseline to reference against similar sites. The reference guide details comparing a site to three similar sites, therefore we feel 29 would offer a further improved "corporate" baseline. For each site, energy use will be compared either against itself [site baseline] or against the company as a whole [corporate baseline]. Since manufacturing facilities are currently not addressed by EnergyStar, we have taken the alternative approach to determine our energy use reductions. Our proposed procedure is as follows: 1. Determine Historical Average energy use ratio - information is collected from a Resource Conservation [RC] Scorecard that records on a weekly basis all utility consumption. Information is provided for Natural Gas and Electricity in btu and kWh. Production volume is also recorded at the same frequency to calculate the btu/lb. ratio. This data is collected for each site and is also rolled up into an overall corporate energy use ratio for all (29) active manufacturing sites. 2. Determine Performance Period Energy use ratio - data is collected as part of the company\'s ongoing energy use monitoring and continuously updated during the performance period in the Energy Scorecard Summary. We propose to have a three (3) month performance period and extrapolate the full year energy use by calculating part year historical energy use ratios. The annualized energy use data will be included as part of the final LEED Submission. 3. Determine the Reduction in Site Energy Use Relative to Historical Average Baselines - [A] Site Specific or [B] Corporate Wide. Per the alternative method described in the LEED EBv2 reference guide, the baselines are determined by averaging the worst consecutive three year period within the past six years prior to the start of the performance period. The annual % reduction for energy use for the performance period will be determined by dividing the performance period btu/lb by the [A] site specific baseline btu/lb or the [B] corporate baseline btu/lb per the per eq. 1 on page 185 of the reference guide. In using the site-specific baseline option [A], the project should be eligible for 5 possible credit points for EA credit 1. Using the corporate baseline option [B], the project should be eligible for 10 possible credit points for EA credit 1. We feel this is consistent with the "complete procedure" described in the LEED-EBv2.0 reference guide pages 184-185.