It doesn't appear possible, no. While previous LEED Interpretations permitted “fast track” fundamental commissioning beginning during the construction phase, the LEED v4 requirements explicitly state that the CxA must be engaged before the design development phase has been completed.

According to GBCI, any significant issues uncovered during the commissioning process should be noted in the required commissioning report. A narrative and/or supporting documentation must be provided to summarize the corrected issues and outline any outstanding issues, as well as include detailed information on the plan for correcting any outstanding issues. However, evidence that the follow-up was completed and systems corrected is not be required.

The CxA cannot directly authorize construction change orders or changes to the design documents. The commissioning authority’s responsibility is to inform the project owner of findings and their effect on building performance. It is the owner’s responsibility to choose a proper course of action. The CxA will document all issues and resolutions over the course of the project.

The CxA’s prior project experience should be similar to the project for which the CxA is being hired. Project size is one aspect to consider, but certainly not the most important or only consideration. The experience should include projects with similar (or more complex) system types or space types. For example, if your project involves the construction of a hospital with complex systems serving multiple critical zones with a vast array of controls, it would be most beneficial to employ a CxA with documented experience commissioning a project with similar characteristics.

USGBC does not require any certifications at this time. The commissioning agent must demonstrate experience on two prior projects.

For fundamental commissioning and project area less than 50,000 ft2, the commissioning agent can be an employee of the design or construction firm. For enhanced commissioning and projects larger than 50,000 ft2, CxA must be independent of both teams. The CxA must be appointed by the Owner.

ASHRAE Guideline 0 and 1 provides information about the use of sampling in such a case to balance commissioning rigor with cost-effectiveness. Past experience of the CxA should also factor in related to issues seen in similar systems or units.

Maybe. Consult Treatment of District of Campus Thermal Energy in LEED V2 and LEED 2009. Depending on the characteristics of your project, commissioning of upstream DES equipment may be required. Commissioning is required only for DES equipment utilized by the LEED project. For example, a project that utilizes district steam but not chilled water is only required to commission DES steam equipment. Commissioning of DES equipment can be performed by the owner of the DES equipment or by an independent third party.

Yes. Consultants who provide non-design services, such as LEED services or energy modeling, can also be the CxA for the project. However, if those firms have affected the design of the building, they should not be selected as the CxA. 

Generally, the CxA for Enhanced Commissioning must not have any connection to the design or construction of the building.  The CxA can be a subcontractor to the design team or construction manager, but the preferred option is for CxA to be directly contracted by the owner. For more details on who can be the CxA, see the Design Development section of the Checklists tab.