Our client is a non-profit trade association which has leased space in a commercial office building in Washington, DC for 35 years. As part of an additional 10-year lease renewal and expansion, their interior space has been undergoing renovation. Upgrades to 124,000 of the 141, 000 square feet that the tenant occupies were completed in 2006 using a green approach. 10,000 square feet is currently being constructed, and 7,000 square feet is currently in design. The tenant occupies approximately 55% of the building in which they are located. Since the renovation began, the association has come to recognize LEED as an important performance benchmark of green building quality. The association is pursuing certification for its space in order to demonstrate the value of LEED CI certification to its employees and to educate its approximately 8000 corporate member organizations nationwide about LEED. The association\'s hope is to certify all 141,000 square feet of the space that they occupy. The association could limit the LEED CI site boundary to the 10,000 square feet that is currently under construction and the 7,000 square feet in which construction has not yet begun, and meet all LEED CI prerequisites and sufficient credit points to certify that portion of their space at a Silver or Gold level. They are interested, however, to undergo the additional effort and expense associated with including the 124,000 square feet of space that was renovated in earlier phase of renovation. We have confirmed that sufficient credit points could be documented for the whole space to be eligible for certification, however, the issue of how the EAp1 Fundamental Building Systems Commissioning prerequisite would need to be addressed. Alternatively we considered working with the association to pursue LEED OM for their entire space, however, LEED OM presents its own set of challenging issues given its current whole building approach and the fact that the association does not have direct control over the base building components or the activities of other building tenants. In order to include the previous phase of interior renovation in the LEED CI site boundary, we propose adapting LEED OM EAc1 requirements for commissioning the energy related systems in the tenant\'s scope whereby we would: 1. Develop a retro-commissioning, recommissioning or ongoing commissioning plan for the tenant\'s scope energy related systems, including the heating, ventilating, air conditioning and refrigeration (HVAC&R) systems and associated controls, lighting controls, including daylighting, domestic hot water systems, and renewable energy systems. 2. Conduct the investigation and analysis phase. Document the breakdown of energy use in the tenant space. 3. List the operating problems that affect occupants\' comfort and energy use, and develop potential operational changes that will solve them. 4. List the identified capital improvements that will provide cost-effective energy savings and document the cost-benefit analysis associated with each. Please let us know if this would be an acceptable alternate approach to meeting the LEED CI EAp1 Fundamental Commissioning prerequisite for the phases of the renovation already completed. The current and future phases of the project would follow the standard LEED CI EAp1 requirements.