Our building is a 36 floor, 750,000 gross square foot (GSF) high rise commercial office building in a major metropolitan city. This CIR is in regards to the requirement to use vacuum cleaners that meet the Carpet & Rug Institute "Green Label" testing program - vacuum cleaner criteria, and are also capable of capturing 96% of particulates 0.3 microns in size and operate with a sound level less than 70dBA. Currently none of our vacuum cleaners meet these requirements. Due to the large size of our building, we own a large number of vacuum cleaners (approximately quantity 20 total in this building, plus another quantity 30 in another building we manage that is also pursuing LEED certification). It would be a major capital expenditure for us to replace all of the vacuum cleaners outright all at once. In order to meet the requirements for this credit, we are proposing the following: 1) Before the start of the performance period, we will replace 25% of the existing vacuums with models that meet the referenced requirements. The janitors will be trained on the proper use of these vacuums. 2) Before the start of the performance period, we will implement a low environmental impact janitorial policy that calls for the purchase of the required vacuum type whenever an existing vacuum is no longer serviceable and needs replacement. This policy will also meet the requirements for the current use of other janitorial equipment (hot water extraction equipment, etc) called for in this credit. 3) We will provide a record and vendor specifications of the janitorial equipment used in the building and a maintenance log for each piece of equipment over the performance period. Will this proposed strategy meet the requirements and intent of the credit? If not, please clarify how this proposal should be revised.