Many federal projects are design/build (DB) where the DB firm hires the Commissioning Authority (CxA).

The LEED requirements are that the CxA “Is not an employee of, or contracted through, a contractor or construction manager holding construction contracts”.

EAc3 template requires both a signature that the CxA is independent of the construction team and an uploaded commissioning contract.
With that being said, Federal Design/Build projects do get certified with enhanced commissioning.

My question goes to how to complete the LEED Template.

As a third party commissioning authority, contracted through the DB firm, how can we make the case that we are not contracted through a contractor or construction manager when we need to upload a copy of the commissioning contract?

Has there been “Alternate Approach” wording that has been successfully reviewed by GBCI??