This CIR is to request approval for an alternative method of compliance with EAp1: Minimum Energy Performance in the LEED-EB:O&M program for a high-rise residential co-op building. As stated on page 13 of the LEED-EB:O&M reference manual, the program "is a set of performance standards for certifying the operations and maintenance of existing commercial or institutional buildings and high-rise residential buildings of all sizes, both public and private." This particular building has 75 residential units, each individually owned. There is no consolidated information available regarding the energy usage in the building as each tenant is responsible for their utility bill and pays directly to the provider for the energy used. These building characteristics make Option B the most feasible compliance path under EAc1: Optimize Energy Efficiency Performance. Option B is worded as follows: For buildings not eligible to receive an EPA rating using Portfolio Manager, demonstrate energy efficiency in at least the 19th percentile for typical buildings of similar type by benchmarking against national median source energy data provided in the Portfolio Manager tool or in USGBC\'s supplementary calculator as an alternative to EPA ratings. Follow detailed instruction in the LEED for Existing Building: Operations and Maintenance Reference Guide. Unfortunately, it has proven near impossible to collect energy bill data from all 75 residential units; however, the Co-Op board is dedicated to improving energy efficiency and pursuing a LEED certification for the building. Due to the difficult nature of collecting energy usage information from 75 different sources, we would like to propose to use a process of energy benchmarking that is employed by the local state authority - New York State Energy Research and Development Authority (NYSERDA) - and used to calculate state based incentives for multi-unit residential existing buildings. Information on this program can be found at: http://www.getenergysmart.org/MultiFamilyHomes/ExistingBuilding/Building... In assessing energy incentives for a building, NYSERDA allows that multi-unit residential buildings take a representative sampling of a minimum of 10% of all units to energy benchmark the building in response to the difficult nature of collecting energy data in a situation where each tenant pays directly for their energy usage. For this building we propose that the same methodology be accepted for benchmarking the building for use in determining compliance with EAp1: Minimum Energy Performance/EAc1: Optimize Energy Efficiency Performance. This project is proposing to take a sampling of a minimum of 10% of building units evenly distributed between apartment type (i.e., 1 bedroom, 2 bedroom, or 3 bedroom), solar exposure, and story. Using the representative selection the building would then extrapolate the data for the remaining units and add in the base building energy usage to then calculate the building\'s EUI for baseline comparison. If this specific sampling methodology is not appropriate, please indicate what if any approach USGBC would find appropriate in addressing this issue.