Commissioning required for a CHP?

You might say "prudent", and I might say "vital." The magic of a CHP is the improved fuel to energy efficiency, so while still using fossil fuels, the conversion is more than twice the efficiency of conventional power production, so is still a great way to improve both energy efficiency and environmental impact. But the systems are complex, and require significant controls...that black box stuff that is terribly hard to see when you just look at it. The only way to know if it is working is to test it and test it. Enough lecture, but since I am old, I get to do that. In my opinion, this system is required to be commissioned under EAp1 because the electricity is being used by the building. Now, the downstream steam equipment from the CHP that is only supporting the process loads would probably not be required. There is another great reason for including the process loads, and I hope that one of Marcus Sheffer's incredibly talented colleagues will chime in. The CHP is a significant investment with a return precisely because it reduces source energy. It is reducing the overall fuel use of the plant. So, in the energy model for the facility, you can include savings in the process loads over a more conventional design where you consume electricity from the grid and make steam with the natural gas.