Today we received a clarification request for our Commissioning credit because our PV system has not yet been commissioned at the time of our submission. Our PV system has not yet been commissioned because it's not yet fully installed. It will be commissioned, though once it is installed, because the owner has a Commissioning Agent on-site devoted to this project who will be in charge of commissioning the system once it is installed.
I was under the impression that the PV did not have to be commissioned for the submission to the USGBC. My reasoning is that I was always told that EAc2 is a Design Submittal credit and therefore could be based on the design of the renewable energy system. Also, it does not seem reasonable to expect that our PV be fully installed at the time of our submission as PV always takes time to work out financing for as well as install and project schedules need to work faster than the time it takes to fully install the PV.
I am hoping that there might be an exception made if we provided a letter from the owner on their letterhead stating the guaranteed commissioning of our PV once it is installed. This would be a guarantee in much of the same way that guarantees are provided that in 8-10 months a commissioning review will be conducted on-site.
Please help advise. Has anyone else seen a CIR or tried another approach? If we were to wait until the final system was installed our certification could be delayed for more than a year.
thank you.
Lauren Sparandara
Sustainability ManagerGoogle
LEEDuser Expert
997 thumbs up
October 22, 2010 - 5:57 pm
Hello,
Was hoping someone might have some advise on this one. Also, I should mention that my project is a LEED-NCv2.2 project so probably should have been filed under that category on LEEDuser.
Regardless, I'm wondering if anyone has been able to submit their LEED documentation for EAp1 stating that their renewable energy systems would be commissioned at a later date. I was thinking that I could provide a contract from the solar sub as well as a contract from the commissioning agent guaranteeing that it would be commissioned.
It's the one prerequisite holding us up from our LEED Platinum certification.
Thank you,
Lauren
Lauren Sparandara
Sustainability ManagerGoogle
LEEDuser Expert
997 thumbs up
October 22, 2010 - 7:32 pm
The Reference Guide language states:
"the summary commissioning report should include the following:
executive summary of the process and the results of the commissioning program --including observations, conclusions and any outstanding items."
No where can I find language that says all aspects have to be completed before LEED is awarded. Further, I found a couple of CIRs that, while not directly related (it is related to Tenant buildout), talk about the "use of a binding contract" as proof of compliance.
What do folks think about using a binding contract as proof of compliance? Has anyone tried this?
Jean Marais
b.i.g. Bechtold DesignBuilder Expert832 thumbs up
October 24, 2010 - 4:05 am
Sorry Lauren, I personally haven't had this situation, but it's a very valid topic. There are some projects (not in my house) that are going to have similar problems soon, but I'll only be able to report back in January on those. Keeping an eye on your thread though. Best of luck.
Chris Ladner
PartnerViridian
261 thumbs up
October 25, 2010 - 8:08 am
Lauren, sorry for the late reply (out of town,again).
This is the first time I have seen this response from a review. There are many, if not most, projects where the Cx may not be complete at the time of LEED submission. As you state, per the requirements of enhanced commissioning the CxA will not have completed the seasonal review until 6-10 months after occupancy. We are often closing the loop on post-commissioning items when the LEED docs are submitted.
A signed contract has been the assurance that the CxA will complete the required commissioning scope and services. Is the PV system specifically stated in the uploaded documents? If so, I would question the reviewers on this issue.
Say "Hi" to Elaine Shea for me.
Lauren Sparandara
Sustainability ManagerGoogle
LEEDuser Expert
997 thumbs up
October 25, 2010 - 12:48 pm
Chris,
Thanks so much for your response. I'll make sure to tell Elaine Hsieh you say hello.
I'm wondering my best approach moving forward with this reviewer and all others really. I don't really want to just provide a clarification because I want zero chance that it'll go to appeal because I feel that this will be unfair.
I've also heard of many projects being able to move forward with obtaining the commissioning point without the PV being fully installed yet.
Can someone with the GBCI/USGBC help inform this discussion? I'd like to get this resolved and clarified for projects moving forward. Thanks!
Lauren
Scott Bowman
LEED FellowIntegrated Design + Energy Advisors, LLC
LEEDuser Expert
519 thumbs up
October 28, 2010 - 2:31 pm
I just saw this post as well. While not specific to PV, we have had several projects where the commissioning has not been complete at the time of submittal. Sometimes it has to do with project phasing, sometimes with seasonal testing reqiurements. We have always just noted this, and added a letter indicating we were under contract to do this work when appropriate (much like the warranty review).
We have never been questioned doing this.
Also, we recommend commissioning all energy using (or producing in this case) systems that are related to LEED, which would include on-site renewables. We also do any rainwater capture systems that might be part of the WE credits.
Scott...
Tristan Roberts
RepresentativeVermont House of Representatives
LEEDuser Expert
11477 thumbs up
November 10, 2010 - 1:50 pm
Lauren and others, I had an exchange with a LEED technical staff contact at USGBC. The following clarification questions came up:Was all Cx documentation for the PV system that could have been created at that point was included in the submission? Was there any explanation in the submission as to why full PV documentation was not included? In other words, was it fully apparent that the PV system was going to be commissioned but it just hadn’t occurred yet?
Lauren Sparandara
Sustainability ManagerGoogle
LEEDuser Expert
997 thumbs up
November 10, 2010 - 1:59 pm
Hi Tristan,
The PV wasn't installed at the time of submission. Our commissioning report included the PV. Hwever, we should have been more clear that the PV was going to be installled at a later date and that we could guarantee that it would be commissioned at that later date.
I think I'm learning that it is most likely acceptable with reviewers for you to commission your renewable energy systems at a later date so long as you provide assurance that it's under the same scope of work (not attributed to a later project), that it's being commissioned by the same person, and some form of a guarantee that the renewable energy system will be installed.
Clarity and transparency is generally good with submissions. :)
Thanks for everyone's help. We just yesterday submitted our final clarifications for EAc3 by providing the items noted above. I'll keep you posted as to if our credit is granted.
Lauren