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.