Recertification With Incomplete Arc Data and a New Tenant
A 180,000 ft² Class B office building in a cold climate certified LEED O+M v4.1 three years ago is preparing to recertify. The deadline is 90 days away. Arc shows complete water data for 12 months, but energy data are missing for 2 of the last 12 months because the utility changed billing cycles and one bill is estimated. Waste data cover only 10 months; the hauler’s report mixes trash and recycling by volume. A new tenant occupying 25% of the floor area has separate electricity and gas accounts and has not shared data. The occupant satisfaction survey has not been repeated since initial certification. The property manager proposes submitting now with the available data and “filling in” missing months by averaging. The owner wants to avoid delays and is willing to sign an attestation that the missing data are not material.
1. How should the project team handle the performance period and the missing energy and waste data before submitting for recertification?
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The application needs a consistent, consecutive 12-month performance period that represents typical operations. A patchwork of available months will not do. First, see whether the period end date can move within the allowed recertification window so the missing utility bill and tenant accounts can be resolved with actual data. For the estimated bill, obtain the actual read or a documented utility estimate; if an estimate is unavoidable, record the method, dates, and why it is conservative, and do not silently average months. Waste must be reported by weight or by a documented volume-to-weight conversion used consistently for all streams; 10 months of hauler data cannot represent 12 months without an explicit estimator. An attestation that missing data are “not material” does not substitute for required performance data, especially where energy data drive prerequisite and credit calculations. Delaying submission briefly is usually safer than submitting an incomplete Arc record that triggers a prerequisite deficiency.
2. Does the separately metered new tenant change the project boundary, and can the project exclude that space?
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Generally no. The certification boundary is the whole building unless the project scope is formally changed through the rating system’s procedures. A tenant occupying 25% of floor area with separate utility accounts remains inside the boundary for whole-building energy performance. Excluding it would understate consumption and could make prerequisite and credit results indefensible. The team should obtain tenant authorization for data release, use landlord-provided aggregate data, or secure a utility data-sharing arrangement. If the tenant refuses and no aggregate is available, the project has a data-completeness problem, not a reason to shrink the boundary. Submetering can help allocate energy and identify savings, but it does not remove the tenant’s consumption from the building total.
3. What recertification strategy and documentation set would you recommend?
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I would reset the performance period to a clean 12 consecutive months, even if that means a short delay. Assemble actual utility bills for all energy sources, a tenant data-release authorization, hauler weight tickets or a documented conversion method, and a new occupant satisfaction survey. Reconcile the new tenant’s accounts with the whole-building total and document any estimation method in Arc. Check each prerequisite before submission, particularly energy and water metering and performance-related prerequisites, because missing data can cause a deficiency regardless of credit points. Then prepare the recertification application with a clear data-quality narrative: what was missing, how it was resolved, and why the period is representative. A defensible delay is better than a rushed submittal that requires correction later.