We seek clarification regarding the interpretation of "independent CxA" in a situation where the design firm, the contractor, and construction management firm are different divisions/departments of the same corporation which is also the Owner and end-user of the project. The intended CxA is a qualified employee of the Owner; he is employed in a different division/department of the corporation and has as such no involvement in the design, the construction, or construction management. He has direct and unhindered communication with the Owner. All involved being employed by the same corporation and ultimately working towards the best solution for the Owner should alleviate any doubts of mistaken loyalty. Based on these circumstances, we ask the USGBC to confirm that we can designate a qualified employee of the Owner as the independent CxA for EAc3 as well as EAp1 even though the Owner also controls the design, construction, and construction management.