We are proposing a 180,000 sf office building in Austin, TX that is tying into an existing Austin Energy District Cooling loop. This chiller plant is part of a larger campus that is being changed over from a manufacturing and office campus to a multi-use development. The was designed to achieve an Austin Energy Green Building (AEGB)commercial 2-star rating, but the goal was changed to LEED-CS since the AEGB program does not include provisions for Core and Shell projects. Upon switching over to LEED-CS, it was discovered that the energy efficiency minimum had changed. In modeling the building to determine if we could meet the revised minimum energy efficiency, we found that the baseline we are to compare to per ASHRAE 90.1-2004 Appendix G is the same as our proposed building: district cooling. As a result, the inherent efficiencies found in the district cooling system are lost, unless we construct our own chiller as part of this project. Given that lighting, process, and plug loads must also be equivalent in the baseline and proposed cases, it is very difficult to see reasonable efficiency percentage changes, even with the most efficient envelope and heating systems. Their overall percentage effect on the total energy use is too small to make the 14% reasonably achievable as a minimum efficiency. Based on discussions with similar project teams in the area, our situation is not unique. What we are requesting is either that: 1. The baseline is revised such that the use of an existing district chilling plant is not penalized. We feel that the intent of the current baseline is to encourage sustainable energy use on a holistic level, not to encourage individual projects to build their own chiller plants. 2. The minimum percentage be revised for such Core & Shell scenarios where areas in which there are opportunities for improvement in energy efficiency are minimal.