The intent of this credit is to reduce or eliminate water pollution by eliminating sources of contaminants and removing pollutants from stormwater runoff. To achieve this, a stormwater management plan must be implemented that captures and treats the stormwater runoff from 90% of the average annual rainfall (1-inch, part of a humid watershed) for the entire LEED Boundary using acceptable best management practices (BMPs) that are capable of removing 80% of the average annual post-development total suspended solids (TSS) load. The proposed site is part of a university located in an urban area and is approximately 6.75 acres with a building footprint of 5.94 acres. The project consists of a parking garage and mechanical space that are entirely underground, and four buildings at the surface. The four buildings that emerge at the surface are connected by the subsurface portion of the building and support both green and conventional roofs. Pedestrian walkways, landscaped open space and a water quality swale make up the balance of the site at the surface. The majority of the stormwater runoff from the site is treated by the large water quality swale at the southern end of the site and water quality units before being reused for irrigation on site. There is a proposed infiltration system in the southwest corner of the site, located in the small portion of the site not directly over the building footprint. Portions of the conventional roof areas (approximately 10% of the site area) cannot be directed towards the water quality swale or the infiltration system due to their location on site. Therefore these roof drains are proposed to be directly discharged to the city stormwater system north of the site. Sources of TSS are generally from automobiles, oil, grease, salt, sediment and debris. The major sources of TSS are paved areas and parking lots where the materials listed above are found. The Massachusetts Stormwater Policy from the Massachusetts DEP considers roof runoff clean, since roofs are presumed to be free of sediment and debris and therefore relatively free of pollutants or TSS. The Massachusetts DEP does not require treatment of roof runoff because it is expected to generate close to zero pounds of TSS. Thus, the 80% removal requirement is not applicable. It is understood that the USGBC requires stormwater runoff from the entire LEED Boundary to be treated, although the Massachusetts DEP allows roof runoff to be discharged directly without treatment. This project does meet the credit intent without treating roof runoff since the relatively clean roof runoff would not contribute to water pollution downstream. Previous LEED certified projects for this university have achieved a point for this credit while not treating roof runoff and stating that roof runoff is considered clean by the State of Massachusetts. We would like to confirm that this is the position that all USGBC reviewers will take when awarding this credit.