The requirements language around EAc2.1 focuses on retro- and re-commissioning, and the Reference Guide states that retrocommissioning must be conducted during the performance period (p. 171).

It seems reasonable to assume that the initial building commissioning (for a new building) can also satisfy the requirements of this credit, if done within the performance period (which can be at maximum 2 years). This isn't clearly stated, but it seems reasonable. Thoughts?