Completed scope of Cx cycle prior to date of application

Hi

We´d like to prove implementation of the EAc2.3 in an Office Tower according to LEED O+M v4. 

While EBOM 2009 clearly specified that at least half of the scope of work in the first commissioning cycle had to be completed prior to the date of application for LEED, the wording in the v4 is not very clear.

The online guide for v4 describes under step 5 the requirement for quarterly and annual Reports in the first and second year respectively, but does not specify the duration of the commissioning cycle required documentation for. If our Ongoing Commissioning Policy describes a Cx Cycle of  24 months, how long a performance period needs to be documented?

1: 3 months (as most other PP?)

2: one year (as in v2009)

3: three years

thanks in advance for any hints.

Christian