Our project is located on a University campus with two separate DES buildings. One DES building houses all the chilled water equipment including chillers, pumps, cooling towers, etc. and only provides chilled water. There is a separate DES building which houses all the steam equipment. The DES Guidance indicates that for EAc3 we must commission all upstream equipment if "the DES supplies energy constituting more than 20% of the project building's annual energy cost, as determined using the Proposed Case energy modeling run of either the EAc1 Option 1 or Option 2." Should we be viewing the chilled water plant as one DES and the steam plant as a separate DES? In our case, the CHW plant accounts for 19% of the energy cost of the building and the Steam plant accounts for 9% of the energy cost of the building. Separately, these two plants are less than 20% of the energy cost but combined they would be greater than 20% and thus require commissioning of the DES. Because these are separate systems, should we be required to commissiong both even though separately they do not account for 20% of the cost? Is there a reason to commission the Steam Plant in this situation? The guidance document does not get detailed enough to answer this question nor are there any CIRs addressing this. Any thoughts? Also, even if the steam(or HHW) and CHW equipment are located in the same physical building, should they be viewed as separate plants?