All - looking for clarification to this para from the v4 BD+C Reference Manual (page 401):

"New DES:  if the DES is new......show that commissioning or recommissioining of all relevant DES equipment has taken place within three years of the date of the project building's substantial completion.  

A DES that is three years old or less at the date of the project buildings's substantial completion is considered "new" construction and should be commissioned in accordance with the requirements of EA Credit Enhanced Commissioning."

For our project, the DES will be constructed first, and is not pursuing LEED certification. By the time the DES is commissioned - probably at the same time as when we embark on Enhanced commissioning of our LEED project, we would have missed the window for "the CxA to be engaged before the design development phase [for the DES] is complete." 

Help...