It is possible to meet EAc2.3 if you conducted an ASHRAE Level II Audit to meet EAc2.1, but it is generally impractical and not cost-effective. In order to meet EAc2.3, the project team would need to develop an ongoing commissioning plan, which would be based on a commissioning process rather than auditing activities conducted with the ASHRAE Level II Audit. Then, the team would need to implement at least 50% of the scope of commissioning work prior to the LEED submittal. In effect, this would mean both performing an energy audit and making substantial progress on implementing a commissioning program.