Our project is a large dedicated Data Center facility with 100,000 sq. ft. of raised floor, 100,000 sq. ft. of mechanical infrastructure equipment space, 80,000 sq.ft. of electrical infrastructure equipment space, and 10,000 sq. ft. of normally occupied office space. The annual electrical power consumption for the computing equipment of this dedicated data center is 82,820,000 KWH, which represents 78% of the annual total building energy cost at 105,630,000 KWH. In general the LEED rating system was not developed with a unique facility type, such as data centers, in mind. Some of the LEED credits do not apply, such as EQ C6.1, 6.2, 7.1, 7.2, 8.1 and 8.2, while other LEED credits are cost prohibitive to achieve, such as EA C3, EA C5 and EA C6. Under LEED NC2.1, after the entire electrical utility costs were calculated for the baseline and proposed energy modeling, the electrical utility costs of the process load were subtracted out for both models. The resulting energy savings percentage was used to calculate the LEED points. Under LEED NC2.2, the electrical utility costs for the process load cannot be subtracted out. For Data Center facilities, the process load is a very large percentage of the total energy consumption. The total energy savings from the HVAC and electrical systems with respect to the baseline model is far less than the identical building without a large data center. As a result, NC2.2 calculation method "dilutes" the savings gain from the building infrastructure systems and is not a fair comparison with respect to other typical commercial buildings. It also makes it more difficult for a high process load building to achieve credits in optimizing energy performance, on-site renewable energy and green power. Even ASHRAE 90.1-2004, section 2.3C, also indicates that the standard does not apply to the data processing area: "portions of building systems that use energy primarily to provide for industrial, manufacturing or commercial process." According to the CIR submitted 2/28/2007 and ruling on 3/23/2007, a 92,000 sqft office building with 5,000sqft data center project encountered a similar situation and requested a credit interpretation. The CIR cited the ASHRAE 90.1, appendix G and allowed the project to use system 3 or 4 (a packaged single zone system) as the modeling baseline. However, it is the industry standard of utilizing multiple single package, constant speed, cooling system (CRAC, Computer Room Air Conditioning Units) for data center cooling. The use of CRAC Units are widely accepted and published in various ASHRAE data center design guidelines, including "Design Consideration of DataCom Equipment Centers, ASHRAE, 2005" and "Thermal Guidelines for Data Processing Environments, ASHRAE, 2004" As a result, the CIR correctly set the modeling baseline to the industrial standard. But it does not necessary address the disadvantage that the high process load building experiences as compared to a typical commercial building. For our project, following the NC2.2 calculation in accordance with this CIR, we calculated only a 15.5% reduction using all commercially available strategies, including better walls, roof and windows, a higher efficient chiller, VFD AHUs, VFD pumps, VFD cooling towers, occupancy sensors and reduced lighting density. In order to fairly evaluate energy savings of the enhanced building envelope and infrastructure systems, the energy saving calculation should be focused on non-process building efficiency improvements. Therefore, we are requesting an interpretation of the credit that would allow us to exclude the energy consumed by the data center computing equipment from the energy simulation calculations. Our modeling would then use the baseline system as discussed in the 2/28/2007 CIR and our proposed system, a highly efficient, but much higher cost, central chilled water system.