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64 Comments
Rule 3: Angle Exemption
Has anyone documented Rule 3: Angle Exemption?
I'm confused by the diagram in the reference guide. It is a plan view, correct? It seems like any recessed fixture should be exempt, but apparently this is not the case.
Does rule 3 mean that recessed lighting fixtures should be perpendicular to solid walls, or greater than 75 degrees separation from glass?
ie. if the lighting fixture is inline with a window, than it must meet rule 1 also. is that correct?
this is another credit that a year ago, reviewer passed with photos of recessed lighting and no diagrams, but now, they need calculations for distance of fixtures to glass.
if I prepare theses diagrams for a 14 story building, how many do I need to show? there are LOTS of lighting configurations.
I have not. And reading the text for this is confusing. It does look like plan view but the example they show doesn't make sense to me.
I understand if this was a can light. But they're showing a linear light. As long as the closest point to the window makes an angle greater than 75° it seems to make the whole fixture compliant. But if the fixture was shortened by 2 feet it's all of a sudden non-compliant even though there's less light in the room.
I think this was intended for small fixtures but was shown poorly in the reference guide. Sorry I can't help you.
Always good practice to double check the LEED Interpretations database
This credit had an addenda posted August 1, 2011 (#10000098) with a revised diagram for Rule #3 that clearly labels window and fixture.
Now that I understand the rules better, for existing buildings, it seems the only way to reasonably comply is automatic controls because most typical office buildings have lights in-line with windows that are closer than 150% of window height. And it is unreasonable to re-configure lighting plans for LEED without a larger facility alteration.
Stand alone exterior parking garage
A property considering this credit has a stand alone exterior parking garage with an open-air top. The lighting of the entire structure is on one control and the property is concerned about turning off the interior portion of the structure while doing the readings which require turning off the open-air portion. My first reaction is there is no way around this as leaving it on goes against the purpose of the credit, but I would love another opinion as to how they should handle this.
I have a couple ideas. All of the lighting might be on the same control but they may be fed from different circuits. Look at the construction drawings and see if each level is on a different circuit breaker. Maybe all you need to do is switch off the circuit breaker for the top floor.
You could hire an electrician to disconnect the lighting on the top floor for a few hours while the measurements are done. Be sure to keep the public from accessing this floor while the lighting is disabled.
Why are all lights on the same control? Does the open-air top have the lights on all day too?
Just spoke with the property and they were incorrect. The very top portion of the parking garage is controlled seperately from the rest of the structure. Some lower floors are below grade and others are open air. As this is an exterior structure, seperate from the building, do the lower levels of the structure that have a ceiling but are partially open need to be turned off for the second measurement or can the measurements be taken while the exterior lights including the top, open layer is off, but keep the lower level lights on for both measurements? I'm just not sure how reviewers would classify these levels requiring them to be on or off.
I hope this parking garage is not the only building in this LEED project. Refer to MPR #5 about minimum occupancy rates.
Lighting in the covered portion of the parking structure is considered interior lighting and must comply with the interior requirements of this credit. You should not have to consider them when doing the exterior perimeter measurements.
Per CIRCredit Interpretation Ruling. Used by design team members experiencing difficulties in the application of a LEED prerequisite or credit to a project. Typically, difficulties arise when specific issues are not directly addressed by LEED information/guide:
12/18/2007
The applicant is seeking clarification as to the interior/exterior area classification for a four level open air parking ramp building. For the purposes of SSc8, parking structure covered floor area is to be considered interior area and uncovered area is to be considered exterior area. Thus, any lighting within covered area must meet the interior lighting requirements of this credit and any lighting within uncovered area must meet the exterior lighting requirements of this credit, including being below specified foot candles horizontal and vertical at all locations outside the boundary of the propert
Have you run into projects trying to certify a parking garage alone? Interesting. No, this is an office building. Thank you very much for your help on how to address the levels of the garage. Incredibly helpful.
Option 2: 50 watts AND over, OR lights over 50 watts
From much of the threads in this topic, it appears that the requirement to meet option 2 of this credit is that you "Partially or fully shield all exterior fixtrues 50 watts and over so that they do not directly emit light to the night sky". This has always been my understanding as well.
However, later on in the reference guide (page 70), it states that you have to "Identify all exterior and site lighting fixtures greater than 50 watts and ensure that shields are in place to prevent light from being emitted to the night sky." Would this second statement imply that if you have a 50 watt exterior light, you would NOT have to shield it?
Has anyone submitted (and have achieved the credit) when you have had 50 watt exterior lamps that were not shielded (based on the page 70 description)?
I doubt the Reference Guide can overrule the Credit language.
Agreed, the credit language takes precedence over RG language.
Flag Pole Light & ASHRAE LPD calculations
ASHRAE/IESNA Standard 90.1-2007 does not specify on LPDLighting power density (LPD) is the amount of electric lighting, usually measured in watts per square foot, being used to illuminate a given space. Table for Building Exteriors the Flag Pole application. However we need to include it as we have received a LEED review comment to include the Flag Pole light on the exterior LPD calculations. Do you know how can we classify it in order to assign allowable LPD per ASHRAE?
There is no LPDLighting power density (LPD) is the amount of electric lighting, usually measured in watts per square foot, being used to illuminate a given space. category for flag lighting. You just add it to the project design total. The wattage of a flag light is usually small compared to the project as a whole and shouldn't have much impact on the ASHRAE 90.1 compliance for the site.
mechanical blinds outside the building
Hi there,
For interior lighting, the guide reference indicates that the direct beam illumination intersects solid or opaque surfaces and does not spill to the outside. My question is, the building of the project which I’m working counts with mechanical blinds, and they can be close at night a provide for sure a solid surface, is this possible to document compliance for this credit?.
in the other hand all lights inside the building are partially shieldedIn a partially shielded exterior light fixture, the lower edge of the shield is at or below the centerline of the lamp, to minimize light emitted above the horizontal plane. in order that light is conducted to the task desk but not to the sides. Is this compliant with the credit?
Or what is the best way to document interior light if I do not count whit automatic controllers?
Thanks in advance.
The blinds have to close automatically every night. Explain how they work and their long term reliability being exposed to the elements. If those all work well you should be able to earn the point.
The credit only says they have to be fully shieldedIn a fully shielded exterior light fixture, the lower edge of the shield is at or below the lowest edge of the lamp, such that all light shines down. or reduced light output by 50%. I don't think partially shieldedIn a partially shielded exterior light fixture, the lower edge of the shield is at or below the centerline of the lamp, to minimize light emitted above the horizontal plane. complies.
Without the automatic blinds the best way to document interior lighting is to have the lights on occupany sensors. If the space will be regularly used during night time hours then install two ballasts in each fixture and control with a photocell to keep half of the lighting off at night.
Thank you very much Bill,
Then will be complicated for our building to achieve this credit due the building concept is “passive building-active persons", even when we encourage people to turn off the lights and computers after hours, we have no automatic controls.
What if the ballast were changed for fully shieldedIn a fully shielded exterior light fixture, the lower edge of the shield is at or below the lowest edge of the lamp, such that all light shines down. in interiors, would this comply??
Unfortunately no. The interior lighting doesn't matter if uplight is shielded or not. No direct light from the interior fixtures can go outside of the building envelope. This is really difficult for all types of lighting along the building perimeter.
Interior Parking Garage Floors
Has anyone had any experience on how to document this credit for buildings that have parking garage space taking up the first several above-ground floors of a large office tower? The parking garage floors for this building are not open, but completely enclosed in the same glass facade and look as the office floors above. Would these garage floors have to meet the interior lighting requirement and be automatically controlled to shut off after hours, even despite life-safety issues of cars and people navigating the ramps and perimeter space in the dark? Or are garages always considered exterior space and subject to the shielded fixtures/under 50 watts options (which are also not possible in this situation)? The overall exterior perimeter lighting study already conducted does meet the credit requirements. Advice would be greatly appreciated! PS - I assume this decision would likely affect how this interior garage space would be treated relative to other credits such as ASHRAE 62 conformance, green cleaning, daylight and views, cleaning audit, etc.
I do not have experience with this situation but I understand the concerns about life-safey issues since stairwells for garages are specifically designed to be highly visible from the street or sidewalk.
Most garage lighting is installed above the low points of the concrete structure so cars or trucks don't clip them. This should prevent most from having a direct line of site to the exterior. You may have to create some sort of shield for the few that are visible outside. To add light to the stairwells and perimeter parking you will need to mount the lights on the exterior wall facing in and/or down. This is the only way I can think of to light the space and prevent the lights from being seen outside of the glass box. Lighting the corners will be tricky. I think it's possible but you'll be having to do a lot of things different. Expect to spend a lot of time proving your design to the reviewer too. Good luck.
Option 2 - exterior lighting
Our project site has a foutain/pond that has underwater lights. They are about 500 watts but down't really illuminate the surrounding areas. Do these need to be modified or can they stay since they are underwater?
If you follow option 3 for exterior lighting then your pond lighting should be irrelavant. It does not meet the intent of this credit but option 3 does not measure uplight.
We were following option 2 for everything- so what should we do with the underwater lights? they are only on at night for about 2 hours starting around sunset.
Are you able to change your strategy and comply with Option 3? A 500W flood light cannot comply with Option 2 for this credit. Either rethink if you want/need to uplight this fountain, or if you want/need to earn this Credit.
The only way to get everything you want is to install multiple fixtures around the fountain, each having a wattage of less than 50W. Wattage is based on lamp/ballast combo. The cost of so many fixtures and the burden of relamping them all is not worth the effort.
thanks Bill; can you recommend a device that can be used to measure the illumination around the project boundary? also, what time of night should we aim to take these measurements? (or does it just have to be dark out)
I don't have any preference. Even the cheapo ones did the job. Just do a websearch for "light meter" and you'll get a bunch of results. Prices will range from $100 - $300. Look for one that can measure low light levels of 0.1fc and has a button to lock/hold the display reading. This will push you up to $150 I think.
As long as it's dark it shouldn't matter what time. Maybe start 1 hour after sunset. If it's cloudy you should be able to start even earlier.
The Reference Guide says that measurements need to be taken after "civil twilight" in the evening or before civil twilight in the morning. This U.S. Navy site is the referenced tool for determining civil twilight for your location and date: http://aa.usno.navy.mil/data/docs/RS_OneYear.php.
Exceptions for flag pole lighting
We have a client with a flag pole and they would like to leave a flag pole light which shines from the ground up to the flag. Is there an exception to the light tresspass or night sky issue? If I stay below 50 watts am I ok?
If you are going to follow Option 2 for exterior lighting then keep the wattage below 50. And for HID, wattage is the combination of lamp and ballast. For incandescent, wattage is the largest rating of the socket.
If that's a proplem then Option 3 is another way. It only measures perimeter light levels.
Light trespass at Property Line
Does LEED-2009 EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. eliminate any requirements for shieldingShielding is a nontechnical term that describes devices or techniques that are used as part of a luminaire or lamp to limit glare, light trespass, or sky glow. exterior lighting fixtures at the property line? The only reference I see regarding this issue is listed on Page 72 of the Reference Guide, under "Light Pollution Reduction Strategies." Does this mean that as long as all the exterior light fixtures 50 watts and over are partially shieldedIn a partially shielded exterior light fixture, the lower edge of the shield is at or below the centerline of the lamp, to minimize light emitted above the horizontal plane. so that they do not emit light into the night sky, then this requirement is met?
It sounds like you're combining Option 2 and Option 3. You only need to comply with one of these for exterior lights.
v2 required light levels to be no more than 10% greater at the property line when the lights are on. v2009 increased that to no more than 20% greater. Any shieldingShielding is a nontechnical term that describes devices or techniques that are used as part of a luminaire or lamp to limit glare, light trespass, or sky glow. requirements for lights near the property line might be a little less strict but nothing specificly has been eliminated. This is Option 3.
I don't have that Reference Guide. If you have a question about the wording could you copy the sentence here.
The parts refering to shielding and lights less than 50 watts is about Option 2. If all light fixtures 50 watts and over are partially shieldedIn a partially shielded exterior light fixture, the lower edge of the shield is at or below the centerline of the lamp, to minimize light emitted above the horizontal plane. so that they do not emit light directly into the night sky, then you comply with Option 2 and can ignore the language in Option 3 about the boundary light levels.
Exterior lighting option 3
I registered a number of 0.0 footcandle locations, with lights both on and off. Will that be a concern or problem in submitting the data?
Light levels have not increased. Sounds good for submittal.
Exterior lighting - option 3
Our project boundary is one feet thick masonry wall with wall lamps. Kindly share whether the measurement points at the perimeter should be inside the project boundary or outside, to meet the intent of the credit?
You can have the calculation on the outside edge of the wall.
Since the credit is meant to reduce light trespass the wall will be very helpful. You'll probably get the same light level with your site lights on and off.
How tall is the wall? Where are the wall lamps? on top of the wall, inside surface, or outside surface?
Thank you Bill.
The wall is 3m tall and the wall lamps are installed on top of the wall.
You rightly guessed, same light level observed with the site lights on and off.
Performance Period
So would the minimum performance period for this credit be 1 week or is it 90 days?
For credits like light pollution reduction, which are largely about the equipment choices made for a building (shielded fixtures) or equipment setpointsSetpoints are normal operating ranges for building systems and indoor environmental quality. When the building systems are outside of their normal operating range, action is taken by the building operator or automation system. (programming time clocks to turn off lights at night), the expectation is that the equipment and program are in place for the entirety of the three-month performance period.
light pollution reduction for ' interiors of a resort building'
My project is a resort building where the public areas (lobby ,corridors etc )have automatic control panels to switch off lights after 11 pm.However,the remaining portion i.e. the guest rooms have lighting fixtures that might not be able to comply with the distance or angle exemption rules.
The guest rooms have a key card occupancy control as when there are no guests the room has no power supply.Can the guests rooms be counted under automated control areas?The survey shows that 90% of the guests switch off their lights before 12 PM.
CIRCredit Interpretation Ruling. Used by design team members experiencing difficulties in the application of a LEED prerequisite or credit to a project. Typically, difficulties arise when specific issues are not directly addressed by LEED information/guide from NCv2.2
9/25/2008 - Ruling
[3] Residential spaces may not be exempted from the interior lighting requirements. ... However, as an alternative for residential spaces, demonstrate that less than 10% of the total lumens emitted by each luminaire are not directly emitted out of the building through any fenestration.
Thank you Bill.Another doubt that I have is that my project building is 16 years old.We do not have any lighting plans for the common areas but all are 100% automatic control with fixed lighting schedule.For my submission is it mandatory to provide the lighting layout for areas which fall under automatic lighting control or would it be enough to mention or mark out the zones on a space layout plan?
I have never submitted for a LEED-EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. project so I'm not sure but just from reading the credit it seems you do not need a plan showing interior lighting. Just comment that all interior lights have automatic controls and the total programmed hours of after-hours time is 2,190 hours or less for the year.
Thank You.
Interior Light Fixture exemption - no direct line of site
Our building is a warehouse with only a single string of clerestory windowsPronounced and sometimes spelled "clear-story," these are vertical, or close-to-vertical, windows high in the wall of a building that bring daylight deeply into the building and, if operable, can help ventilate the space. at the peak of a gabled roof. All interior light fixtures are ceiling hung T-8s that are 10-12 feet below the bottom edge of the clerestory. I cannot determine how to execute this calculation, as the fixtures obviously have no direct line of site from the building. By changing the orientation of some of the calculations, this would work there were skylights, but in fact it a vertical clerestory window in the roof, not in the walls of the building. Could we show photos of the interior and sections of the building with as an alternative compliance method for Interior Lighting? Anyone have experience with this type of alternative compliance method?
For interior lights this credit is looking for a direct line of site to an opening in the building envelope, either wall or ceiling.
What type of ceiling hung T-8 fixtures are these? What does the photometric curve look like? I'm guessing that there's at least some up-light from these lights. If you were at the windows would you be able to see direct light from the T-8 fixtures?
I think a section of the building with light fixture location shown is good for showing compliance. Also attach a copy of the light fixture cutsheet showing what type of fixture this is. Usually the last page of the cutsheet shows the photometric output. If it shows no light coming out of the top of the fixture (between 90 and 180 degrees) then you're good.
If there is direct light going out the windows then automatic controls will need to be shown stating the lights are off 50% of the night hours. At least for the lights within site of the windows.
If this doesn't answer your question let me know.
City-owned streetlights within site boundary
Our project has exterior lighting that is fully shieldedIn a fully shielded exterior light fixture, the lower edge of the shield is at or below the lowest edge of the lamp, such that all light shines down., however a few streetlamps on the project boundary emit ample light to the night sky. These lamps are on the sidewalk, but technically within our site area. Since they are out of our control, is there any way to reconcile with this credit?
Well, the specifics here can be fairly important. If the lights are 'on' the boundary and owned by the city, they clearly fall outside of your sphere of responsibility. If they are, in fact, within your project boundary, I can imagine two options: the first would be to make the 'control' argument to the GBCI, which I think would be a fairly compelling argument. There's really nothing you can do about city-owned fixtures. Alternately, and perhaps more reliably, you could use the Option 3 approach (with the city-owned lights 'on' in both scenarios) to illustrate that the contribution of the lights you DO control to the nighttime lighting situation is marginal.
Limited Exterior Lighting Fixtures
Our project is an office space within a warehouse. The only exterior light fixture attached to our property is at the back entrance of our parking garage. Can we still achieve this credit if the scope is so limited? we will be replacing the exterior fixture for one with full cut-off, however, the rest of exterior lights are owned by others.
The main thing I want to respond to is about your whole project, not SSc8. Are you planning to certify just the office space within the warehouse? According to the LEED Minimum Program Requirements for EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems., "LEED projects must include at least one existing commercial, institutional, or high-rise
residential building in its entirety."
In principle, I don't know of an obstacle to achieving this credit if it just involves one exterior light fixture. Make sure to address the interior requirements as well.
Option 3 - Light Measurments vs Zone Requirements
When finding the difference between light measurements when fixtures are on and off, if the difference is above 20% but the footcandle measurement is below the Maximum Illumination Value for the type of lighting zone does it still comply? For example, if we were in LZ 4 where the maximum is .6 and we got a measurement of .3 with lights off and .4 with lights on (33% difference). Would it be acceptable if one of the requirements is met or does the compliance path have to follow one of the options?
It sounds like it does not comply. The credit states "The illumination
level measured with the lights on must not be more than 20% above the level measured with the lights off."
A couple ideas come to mind. Can you shift the measuring points? It states that you need at least 6 points and no more than 100' apart along the perimeter. Sometimes a 20-50' shift can show surprisingly different results.
If that doesn't work you have a small chance getting this by increasing your accuracy. Does you light meter measure hundredths? If the 0.3 fc1. A footcandle (fc) is a measure of light falling on a given surface. One footcandle is defined as the quantity of light falling on a 1-square-foot area from a 1 candela light source at a distance of 1 foot (which equals 1 lumen per square foot). Footcandles can be measured both horizontally and vertically by a footcandle meter or light meter. 2. The non-metric measurement of lumens per square foot, one footcandle is the amount of light that is received one foot from a light source called a candela, which is based on the light output of a standardized candle. A common range for interior lighting is 10 to 100 footcandles, while exterior daytime levels can range from 100 to over 10,000 footcandles. Footcandles decrease with distance from the light source. The metric equivalent of a foot candle is 10.76 lux, or lumens per square meter. value is 0.33 fc with lights off and the 0.4 fc is 0.39 fc with lights on it would be compliant. It's not likely but if you're looking for any ideas it's something to try.
Option 2: 50 Watt fixture or 50 Watt lamp?
Does the option 2 exemption for exterior lighting apply to fixtures with ratings greater than 50 watts but using lamps 50 watts or less? We have a project with unshielded exterior light fixtures, and our first thought was to make sure each lamp is 50 watts or less as an easy way to satisfy the exterior lighting demands of this credit.
I think your interpretation is consistent with the credit intent - the objective is to reduce illumination to the night sky, and reducing wattage certainly does so. Depending how much you reduce wattages, it may be more or less ultimately effective than shieldingShielding is a nontechnical term that describes devices or techniques that are used as part of a luminaire or lamp to limit glare, light trespass, or sky glow., but it does meet the requirements.
Exterior illumination measurement methodology
When peforming the exterior illumination measurements, do both horizontal and vertical foot-candle measurements need to be taken? Or just one or the other?
One or the other should be sufficient Kevin; in most instances my suspicion is that horizontal foot-candles are the right measurement, but I don't think either method is specifically required by the credit language, nor is it required that you perform both methods of measurement at each measurement point.
Sorry for chiming in, but I have a question that is along these lines...should the 100' measurement protocol be used as the standard for measuring light transmittal in an NC (warehouse) project where shading the windows are not an option, but the lighting is so high compared to the clerestory windowsPronounced and sometimes spelled "clear-story," these are vertical, or close-to-vertical, windows high in the wall of a building that bring daylight deeply into the building and, if operable, can help ventilate the space. that very little light will be emitted? Any ideas on how to measure the true affect? LEED does not specify in BD&C.
Sorry for chiming in, but I have a question that is along these lines...should the 100' measurement protocol be used as the standard for measuring light transmittal in an NC (warehouse) project where shading the windows are not an option, but the lighting is so high compared to the clerestory windowsPronounced and sometimes spelled "clear-story," these are vertical, or close-to-vertical, windows high in the wall of a building that bring daylight deeply into the building and, if operable, can help ventilate the space. that very little light will be emitted? Any ideas on how to measure the true affect? LEED does not specify in BD&C.
Using option (3) measuring lighting (%) percent
Using Option (3) it states under the LEED - EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. V3 2009 a minimum of 8 measurements at 100 feet spacing between mesuements must be peformed.
Question? We are a large Convention Center and would like to know how many measurements are actually required. Do we do one measurement every 100 feet until the entire perimeter has been completed. Or can we do a (Percent) measurement at certain locations which would be a representation of the total measurements? Please Advise....Thank You Rey
One measurement every 100 feet until the entire perimeter has been completed is the correct approach. Gaps of larger than 100 feet would allow for too large undocumented spaces, or at least that is the concern.
A re-visit to this question... Our convention center project site perimeter is 11,000 linear feet. In order to satisfy the credit, we would need to do 220 measurements (measuring every 100 ft with lights on and off). This would take over 7 hours of testing and the info would not be valid since we would still be testing at sunrise. Is submitting a CAD drawing with fc1. A footcandle (fc) is a measure of light falling on a given surface. One footcandle is defined as the quantity of light falling on a 1-square-foot area from a 1 candela light source at a distance of 1 foot (which equals 1 lumen per square foot). Footcandles can be measured both horizontally and vertically by a footcandle meter or light meter. 2. The non-metric measurement of lumens per square foot, one footcandle is the amount of light that is received one foot from a light source called a candela, which is based on the light output of a standardized candle. A common range for interior lighting is 10 to 100 footcandles, while exterior daytime levels can range from 100 to over 10,000 footcandles. Footcandles decrease with distance from the light source. The metric equivalent of a foot candle is 10.76 lux, or lumens per square meter. detail and confirming accuracy with spot testing acceptable? If not, what do you suggest? Thanks!
I have not heard of any variations of this option being accepted. A CIRCredit Interpretation Ruling. Used by design team members experiencing difficulties in the application of a LEED prerequisite or credit to a project. Typically, difficulties arise when specific issues are not directly addressed by LEED information/guide would be the only way to know for sure.
I don't see why you couldn't do this over two nights. Just try to make sure the start times, measurement points, and neighbor's lights are all the same.
That was our next option, BUT, Page 71 of the Ref guide says take them on the same night. Would you suggest explaining the obstacle in the survey report and submit?
It would seem silly for them to deny this credit because of the size of the site.
I was looking at the sample form for this credit and I don't see anything specifically asking that all measurements were taken on the same night. There was a box that you may want to mark.
"Special circumstances preclude documentation of credit compliance with the submittal requirements outlined in this form."
If you check this box and explain to them that due to the size of the project and the available night time hours for measurement that work was divided up over two nights. "We were unable to do all light level readings in a single night because of the 2 miles of perimeter of this site. Measurements averaged 2 minutes each and total time required would be over 7 hours when we only have 6 hours of full darkness available."
Then go out of your way to reassure them that all conditions between the two nights were identical. Just list everything that is the same. "All points has markers placed on the ground to make sure same location was used each night. The start time and path around the site were the same. All project interior lights were on. All surrounding neighbor lights were the same each night. The same person and meter were used." etc. etc.
Most reviewers seem to like knowing that you took a lot of effort to do it right. If the submittal allows for some exceptions and you can show you did your due diligence to comply then I don't see a reason you couldn't earn this credit. But that's just my opinion.
Sounds like a plan! Thank you for your help
Let us know how it goes.
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