Separate CxA's for Fundamental and Enhanced Cx?

They can be split but the enhanced CxA has to have oversight of the fundamental CxA. Read through this thread as I've posted about the requirements before based on a CIR for a v3 project.

Susan is right (back from Greenbuild). The key is to have that oversight clear and obvious from the start, and that the contracts and narrative of the enhanced report show this. I have been involved in these relationships (in both roles by the way), and as long as the two firms work together and keep communication open and easy, it can work.

Hi everyone, We recently received a review comment from the GBCI stating we are NOT allowed to split Fundamental and Enhanced Commissioning tasks between two separate agents. I submitted a formal inquiry to the Technical Director of Energy at the GBCI, this is the response: The Commissioning authority must DIRECTLY complete the following tasks: • Review owner’s project requirements and basis of design during the early design phase. • Conduct commissioning design review prior to midconstruction documents • Review contractor submittals applicable to systems being commissioned • Verify installation and performance of commissioned systems (functional testing) • Develop or review systems manual for commissioned systems • Verify that requirements for training are completed • Complete a summary commissioning report. • Review building operation within 10 months after substantial completion. We have done a split FCx/ECx arrangement on projects before and have never received a review comment, perhaps the requirements have changed? Or maybe doing the split approach depends on the reviewer?

I agree with Susan and Scott, it can be split. Ultimately there needs to be "one keeper of the keys" with respect to commissioning -so the relationship and interaction between the two firms is important. We have been successful on past LEED certified projects where we were the CxA of record, did not do the preliminary reviews/Cx Plan, but verified it occured and ultimately we performed the functional testing and submitted the Cx Summary Report to LEED Online. (this was only for fund Cx) I know this doesn't exactly answer your question, but hopefully it provides you with some confidence when interacting with GBCI. Please post the outcome, I am curious. thank you.

I think the key is in defining for your project that the Enhanced CxA has oversight of the FCxA. In our case, the FCxA does the submittal review and the ECxA reviews their process and pulls out individual submittals for their review as they see necessary. They also meet regularly as a Cx team which also helps.

I have seen this arrangement many times, and been on both sides as well. There is a lot in how the relationship is defined and acted upon. The CxA Enhanced must be in control and oversee all activities, and perform specific tasks as defined by the standard. The item in the response you got "Verify installation and performance of commissioned systems (functional testing)" is not in the standard for EAc3. Also, for the systems manual, it says "CxA or other project team members must..." So the response is not accurate to the standard. The foundation of the oversight requirement comes from Table 2, the Commissioning Authority Qualifications. As you look at who can perform fundamental, it gives many options depending on size. The same for enhanced. No where does it say they have to be the same individual, BUT foot note 4 states that "The same CxA overseeing the enhanced commissioning tasks must also oversee the fundamental commissioning tasks." It does not say personally perform, that is covered in the standard language for which items must be directly done by the Enhanced CxA. Review LEED Interpretation 2496, which describes an even more complex relationship than two Cx firms. They clearly allow delegation of tasks, but also clearly require the enhanced firm to do specific tasks and have overall responsibility and authority. Note that this LI does apply to v09. LEED Interpretation 2340 is even more specific in this concept in the ruling, requiring that "...it is required that the independent CxA perform EA Credit 3 tasks 2, 3, and 6. Beyond these restrictions, it is the responsibility of he independent CxA to determine who shall perform each of the remaining tasks under both fundamental and enhanced commissioning." It goes on to say the independent CxA (really the enhanced portion) must "...provide leadership and oversight relating to the remaining tasks under this credit and under EAp1." Perhaps the language needs to be addressed. You only have one CxA, it is not "split", however different team members are assigned different tasks, and each is qualified for the portion they are responsible for AND the oversight and authority for the whole Cx process rests with the Enhanced CxA. Basically, I think your reviewer is wrong, but I do not know how you submitted the relationship either.

What happens if Commissioning Agent #1 that performed the following activities - - goes out of business: • Review owner’s project requirements and basis of design during the early design phase. • Conduct commissioning design review prior to midconstruction documents • Review contractor submittals applicable to systems being commissioned If the contractor hires a new Commissioning Agent #2 to complete the remaining activities, what needs to happen to bridge these two entities #1 & #2...to achieve this credit? If Agent #1 completes EAp1 & Agent #2 completes EAc3, will we be denied this credit?

This probably should have been a new topic. From your opening, it appears that most of the tasks completed so far have been for Enhanced Cx. That is good, because it is something difficult to catch up on. But in our next paragraph, you state "contractor hires a new Commissioning Agent" is a problem. The contractor cannot hold the contract for Cx except for very limited situations, and I have gone over that in many responses in this sections, so please read a few of them. My recommendation would be for the owner or design team to hire a new CxA to do both Enhanced and Fundamental Commissioning, and add that they should review the work already completed. This may add some cost, but a new agent needs the ability to review work they are in a way accepting as complete, and have a chance to bring any issues they see to the attention of the design team. Then in the submittal, describe the situation, and since you have to show the contract anyway for the Enhanced, it will show how the new agent is picking up from the one that went out of business.