Can an employee from contruction management firm be CxA

Hi According to the EAp1 Fundamental Commissioning and EAc3 Enhanced Commissioning' s requirements regarding the qualifications of the CxA as follows: - EAp1: The invidual serving as the CxA must be independent of the project's design and construction management, though the CxA may be an employee of any firms providing those services. The CxA may be a qualified employee or consultant of the owner. - EAc3: The invidual serving as the CxA * Must be independent of the work or design and construction * Must not be an employee of the design firm, through he or she may be contracted through them * Must not be an employee of, or contracted through, a contractor or construction manager holding construction contracts. * May be a qualified employee or consultant of the owner. For our project with gross floor area over 50,000 sq.ft, the owner hires a construction management firm to help the owner to supervise, monitor and control contractors' construction works. According to the EAp1's requirement, An employee of the construction management firm who is independent of the construction management activities is qualified as the CxA for the fundamental commissioning. However, the EAc3's requirement do not mention about this point. Please advise whether an employee of the construction management firm who is independent of the construction management activities is qualified as the CxA for the enhanced commissioning (EAc3). Thank you very much.