The purpose of this Credit Interpretation Request (CIR) is to define how the Validation and Commissioning department of Bala Consulting Engineers, Inc. (Bala) is structured within the organization so that we may be considered for work in pursuit of the Enhanced/Additional Building Commissioning credit (EA #3) for our LEEDT project, even though Bala (Engineering Group) is also responsible for the MEP systems Basis of Design document for this project. Bala\'s Validation and Commissioning department has successfully completed numerous projects in which various engineering firms, including Bala, have provided the engineering design services. For pharmaceutical validation and commissioning projects that also involve Bala\'s engineering design team, we have demonstrated to the satisfaction of the Owner that our Validation and Commissioning department operates as a separate, independent entity within the organization and serves as an objective advocate for the Owner. The principal reasons are as follows: 1. On this project, other engineering firms will serve as the Engineer of Record and will be responsible for the provision of sealed engineering drawings. 2. Our contract for Commissioning services with the Owner is independent from the contract for engineering services by Bala\'s engineering group. The role of Bala\'s engineering group has been to write the Basis of Design for the project only. 3. The Validation and Commissioning department is one of four profit centers within Bala. The four profit centers are Validation/Commissioning, Mechanical/Electrical/Plumbing, Structural, and Voice/Data Technologies. Validation projects are tracked separately through the accounting system. Some projects, however, may be linked to engineering services for accounting and billing purposes as requested by clients. 4. The organization shares a common structure for upper management but the core Validation and Commissioning staff directly reports to me. The Validation and Commissioning department staff are totally separate from Bala\'s other profit center staffs. As the Director of Validation and Commissioning, I am responsible for all aspects of project development and execution. Our intention is to complete services objectively and efficiently to the Owner without conflict of interest. Some advantages for providing design and commissioning services within one organization include good lines of communication between the design and commissioning groups. The ease of communication is particularly useful if the project requires that the commissioning group challenge certain aspects of the design intent. Finally, note that the original Additional Commissioning guideline for LEED-NC, Version 2.1 specifies "independent" commissioning authority throughout the requirements section. However, the revised LEED-NC, Version 2.2 (First Public Comment Draft) Enhanced Commissioning requirements deletes references to "independent" commissioning authority from the requirements section. It is our judgment that the relationship outlined above meets the intention of Commissioning Authority independence and impartiality central to this LEED credit. May we pursue this credit accordingly?