Per the guidance given by the CIR ruling on 1/8/2007, it was affirmed that an independent third party commissioning authority (CxA) must provide commissioning process oversight and review of deliverables for the commissioning activities required for EAp1-Fundamental Commissioning and EAc3-Enhanced Commissioning. Since the CIR guidance allows projects "some flexibility" in fitting the Cx process to the project, we wish to ascertain whether the following proposed breakout of Cx tasks, responsibilities and oversight methodologies will meet the requirements of EAc3, if a project team chooses to not use an Independent 3rd party CxA to complete all EAp1 and EAc3 tasks but instead contracts with an Independent 3rd party to lead, oversee, and review selected tasks and uses the independent commissioning group of the project\'s design firm to complete many of the actual commissioning tasks. Much of this confusion arises from the use of the term "CxA" being used both in the 2.2 Reference Guide outline of EAp1 tasks as well as in the 2.2 Reference Guide\'s outline of the EAc3 tasks. Projects seeking the State of Oregon\'s LEED tax credit must achieve EAc3. As such, we are submitting this CIR to ensure that these scopes of work are accurately and clearly defined for the Independent CxA and the qualified commissioning group within the design firm (defined as "Other" below) involved in the commissioning process and that how we allocate these tasks will not be found deficient during certification review. Please review the following breakout of LEED EAp1 and EAc3 commissioning responsibilities and verify whether the scope of responsibilities assigned to the Independent 3rd party CxA meets the stated requirements to "lead, review, and oversee" the commissioning process for projects seeking EAc3. If any of the specific responsibilities within the individual tasks that are shown as assigned to the Independent 3rd party CxA below are insufficient to meet the leadership, process oversight and review responsibilities for this credit, please clearly define what changes should occur. EAp1 + EAc3 RESPONSIBILITY MATRIX for Projects Seeking EAc3 Independent Cx Authority- Per LEED NC 2.2 Guidance - Qualified Independent 3rd Party-not a member of the design or construction team firms. May be a member of the owner\'s team if qualified per LEED guidance. Other - Per LEED NC 2.2 Guidance - Non-design team member(s) of the Design Firm qualified to provide commissioning services. May be a member of the owner\'s team if qualified per LEED guidance. EAp1 Tasks - Task numbers correspond to LEED NC v2.2 Reference Guide Requirements (page 151) 1) Independent Cx Authority- Lead, review and oversee the completion of all commissioning process activities 1) Other - Perform commissioning tasks under the leadership, review and oversight of the Independent CxA 2) Independent Cx Authority- Review OPR & BOD documentation completed by ownership and design teams for clarity and completeness per LEED NC 2.2 guidance. 3) Independent Cx Authority- Review and verify that Cx requirements are incorporated into the construction documents. 3) Other -Develop and incorporate Cx requirements into Construction documents. 4) Independent Cx Authority- Review Cx Plan to ensure completeness per LEED NC 2.2 guidance. 4) Other -Develop a Cx Plan that defines the Cx process, participants, schedule, protocol, and deliverables per LEED NC 2.2 guidance. 5) Independent Cx Authority- Review testing schedule, relevant pre-functional inspections and final system performance testing reports to verify testing program is completed by the design team\'s commissioning authority per LEED NC 2.2 guidance. 5) Other -Verify Installation and performance of commissioned systems per LEED NC 2.2 guidance. 6) Independent Cx Authority- Review final draft of summary commissioning report to verify relevant sections and details are addressed as defined by LEED NC 2.2 guidance. 6) Other -Complete a summary commissioning report per LEED NC 2.2 guidance. EAc3 Tasks - Task numbers correspond to LEED NC v2.2 Reference Guide Requirements (page 205) 1) Independent Cx Authority- Lead, review and oversee the completion of all commissioning process activities 1) Other - Perform commissioning tasks under the leadership, review and oversight of the Independent CxA 2) Independent Cx Authority- Complete a detailed commissioning focused design review by mid-construction document phase to verify that designed systems and BOD meet OPR requirements. Back check the review comments in subsequent design submissions. 3) Independent Cx Authority- Review relevant contractor submittals for compliance with project\'s OPR and BOD. 4) Independent Cx Authority- Review completed systems manual to ensure it includes relevant sections and detail as defined by LEED NC 2.2 guidance 4) Other -Develop a systems manual for the project 5) Independent Cx Authority- Stay appraised with design team commissioning authority that training protocol review and building operator training has been completed. 5) Other -Verify training of building operators is completed per LEED NC 2.2 guidance 6) Independent Cx Authority- Per LEED NC 2.2 guidance, review building operations with O&M staff and occupants within 10 months of building completion and develop a plan for resolution of outstanding commissioning-related items.
The applicant is seeking an interpretation as to the acceptability of the delineation of commissioning tasks as outlined in the credit interpretation request. This inquiry appears to be attempting to define the minimum role of the independent commissioning authority (CxA) for projects seeking EAc3. For LEED projects pursuing EAc3, the third party commissioning authority must lead, oversee, and review all commissioning tasks. Per the USGBC document "Who Can Be the Commissioning Authority" (https://www.usgbc.org/ShowFile.aspx?DocumentID=1262), the same CxA must oversee the required tasks of both EA Prerequisite 1 and EA Credit 3. Per CIR ruling dated 1/8/2007, the independent CxA need not always formally review and approve each deliverable. However, it will be the responsibility of the independent CxA to determine the roles and responsibilities pertinent to each of the required tasks under both EA Prerequisite 1 and EA Credit 3. Note that the CxA individual must themselves do EA Credit 3 tasks 2, 3, & 6. Applicable Internationally.