District Energy System owned by Government vs. Owner

My question is in regard to both EAc3: Enhanced Commissioning and EAc5: Measurement and Verification credits in relation to a District Energy System. We are working on a project based in China where the District Energy System is not owned or controlled by the owner but rather by the government. Due to the strict and undisclosed nature of the government in China, obtaining information and specific numbers on the energy performance and maintenance of the DES equipment will be difficult, making the Enhanced Commissioning and Measurement and Verification of all District Energy System equipment unfeasible. The USGBC guidance entitled “Treatment of District or Campus Thermal Energy in LEED V2 and LEED 2009-Design & Construction” provide compliance paths on page 8, section 2.3.2 for EAc3: Enhanced Commissioning and on page 17, section 2.7 for EAc5 Measurement and Verification. However, the guidelines and interpretations it provides appear to apply only to owner-operated DES systems and does not seem to include an approach for utility and/or government-operated DES systems. For our project, can we assume all upstream equipment included in the District Energy System be excluded in the scope of both EAc3 and EAc5? Thanks so much!