Our company is a mechanical/electrical/plumbing & fire protection (MEP) engineering design firm. We are a fairly large company with over 400 employees and 8 independent offices (divisions) throughout the State of Florida and in Nashville. Over the past few years we have worked on many LEED Projects and as a result have developed an in-house expertise with regards to LEED and Sustainable Design. Because of the continued growth we see in this market, we have decided to offer our clients a specialty service that addresses the specific needs for LEED Projects. This service is offered through a dedicated and whole owned separate corporation, Green Guides, Sustainability for Architecture. In addition to overall LEED Administration services, this LEED group will offer more specialized services like energy modeling and commissioning. As the MEP Engineer, our company typically provides Fundamental Commissioning Services for LEED Projects but is excluded from offering Enhanced Commissioning. In order to better serve our clients, we would like to be able to offer Enhanced Commissioning through Green Guides. To address any concerns that this group can act as an independent third party, we have taken the following measures:
The inquiry is requesting clarification on whether or not a wholly owned subsidiary of a design firm may provide enhanced commissioning services for a project that was designed by the parent company. Per LEED-NC v2.1 CIR rulings dated 7/6/0225 and 3/11/2003, it is necessary to demonstrate that the two organizations involved function independently with respect to management, shared staff, and financial relationships. From the description provided within the inquiry, it appears that the two organizations function separately with respect to middle management and shared MEP staff, although no indication has been made as to any financial relationships, shared top management structure, or shared support staff that would allow for a definitive answer to this specific relationship. To qualify as an independent third party commissioning authority, it will be necessary to demonstrate that there is no shared management structure, there are no standing financial relationships, and that there is no shared staff between the two organizations. Applicable Internationally.