One of our factory projects is planning on installing a CHP (combined heat and power) plant, with natural gas as the fuel source. Does this system require commissioning? We are speculating that the fuel source excludes this system as being defined as a "renewable energy system", and that the heating component would not necessitate commissioning as the steam is exclusively used for process loads.

While we believe that it would be prudent to commission the system, is it required by EAp1?