Module 7 — Construction management and commissioning

Section 1 · Pre-work (60 minutes)

Required reading

• Operations Manual §7.4 (Construction Management and Milestone Inspections). 15 minutes.
• Operations Manual §7.5 (Commissioning and Site Acceptance). 15 minutes.
• Operations Manual §7.6 (Post-Commissioning and Grand-Opening Readiness). 10 minutes.
• The trainee’s executed Master Services Agreement — commissioning and False Call-Out sections. 20 minutes.

Pre-session knowledge check

Submitted via Partner Portal at least 24 hours before the session.

1. Within how many Business Days must the franchisee report an OSHA recordable incident on the construction site?
2. May the franchisee open the HiON EV Facility to the public before HiON has issued written commissioning approval?
3. The franchisee requests commissioning. HiON arrives and finds the cabinet pad incomplete. What is the operational and contractual consequence?
4. Within how many calendar days of commissioning approval must the ribbon-cutting be executed?
5. A change order proposes shifting a bollard 3 feet to dodge an unmapped utility line discovered during trenching. Does this require HiON prior written approval?

Bring to session

• The trainee’s HiON-approved design package (M06 output)
• The trainee’s general contractor and electrical contractor agreements (or at minimum, evidence of §14 vendor qualification and confidentiality obligations)
• The trainee’s Designated Business Manager
• The trainee’s general contractor and electrical contractor, if available, for Section 4.1–4.4 of the live session

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Section 2 · Learning objectives

By the end of this module, the trainee can:

1. Qualify the general contractor and major subcontractors against §14 vendor-qualification standards, ensure HiON Engineering and Design Review pre-mobilization approval of the electrical contractor, and document insurance and written agreements with confidentiality and lien-waiver obligations.
2. Manage the 9-milestone inspection cadence (§7.4.2) from pre-construction meeting through punch-list close-out, logging every milestone in the Partner Portal with date, inspector, outcome, and follow-up actions.
3. Apply the §7.4.3 change-order discipline — any change affecting Site Design Manual standards, the cabinet pad, post placement, signage, accessibility, or the approved design package requires HiON prior written approval through the Partner Portal before contractor execution.
4. Maintain construction safety to OSHA standard and report any OSHA recordable or serious incident on the construction site to HiON within 1 Business Day through the Partner Portal.
5. Complete the 10-item pre-commissioning readiness checklist (§7.5.1) honestly before submitting the Commissioning Readiness Request — requesting commissioning for an unready site may trigger a False Call-Out under the MSA.
6. Cooperate with the §7.5.2 commissioning process — provide physical site access, ensure DBM presence at the walk-through, address site-side punch items in real time.
7. Never open the HiON EV Facility to the public before HiON has issued written commissioning approval. Opening to the public without commissioning approval is a material breach of the Franchise Agreement.
8. Execute the §7.6 post-commissioning handoff — Go-Live Notification submitted within 1 Business Day of commissioning approval; launch-toolkit materials ordered; ribbon-cutting date scheduled within 5 calendar days; Start-Up Advertising plan confirmed; Site Host briefed.

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Section 3 · Why this matters

Construction is the discipline that turns the franchisee’s authorized design into the franchisee’s operating asset. A clean build — to the Site Design Manual, on the contractor’s milestone cadence, with HiON’s milestone inspections logged, with change orders gated through HiON approval, with the safety baseline maintained — produces a site that passes commissioning on the first attempt and opens to the public on the schedule the franchisee committed to in §6.4 (M04).

A messy build produces a site that fails commissioning, triggers a False Call-Out under the MSA, slips the ribbon-cutting window, jeopardizes the Start-Up Advertising commitment, and creates a default-risk path the franchisee then has to operate against. The Manual is direct in §7.5.1: “Requesting commissioning for a site that is not ready may trigger a False Call-Out under the Master Services Agreement.” The franchisee does not earn standing with HiON by being “almost ready.” The franchisee earns standing by being ready when the Commissioning Readiness Request is submitted.

The §7.5.3 [MANDATORY] standard is the single highest-stakes rule in this Module: “You must not open the HiON EV Facility to the public until we have issued written commissioning approval. Opening to the public without commissioning approval is a material breach.” This rule exists because the Tesla Supercharger network and the HiON System are integrated systems that cannot be safely operated by a franchisee on their own — every charging session, every payment, every fault response depends on integration HiON performs at commissioning. A site that opens before commissioning is offering a service the franchisee is not authorized to deliver, on equipment HiON has not integrated, with a payment path that does not exist. The franchisee may have the lights on and the chargers visually installed — the operational reality is the site is not a HiON EV Facility until HiON has commissioned it.

The change-order discipline (§7.4.3) is where construction’s everyday pressure most often produces drift from the approved design. The contractor encounters an unmapped utility line, a soil condition, a delivery-truck turning radius. The contractor proposes a small adjustment. The franchisee accepts the adjustment to keep the project moving. The site is built to a configuration HiON has not approved. Commissioning surfaces the deviation; the franchisee either cures the deviation (rework) or files a §1.2.6 exception after the fact (which may or may not be granted). The right discipline: every change that touches Site Design Manual standards, the cabinet pad, post placement, signage, accessibility, or the approved design package routes through HiON Engineering and Design Review before contractor execution. Minor field adjustments that do not affect any required standard (a bollard shift to dodge an unmapped utility) may proceed; document in the as-built file. The dividing line is whether the change touches a required standard, not whether the change “looks small.”

The §7.6 handoff into launch is operationally fragile. The franchisee, having survived design and construction, often treats commissioning approval as the finish line. It is not. The 5-calendar-day ribbon-cutting window starts the moment commissioning approval issues; the 1-Business-Day Partner Portal confirmation of Go-Live + launch materials + ribbon-cutting date + advertising + Site Host briefing all happen in parallel. A franchisee whose launch toolkit materials are ordered the day after commissioning is racing against a clock that has already started. The franchisee who treated commissioning approval as the green-light for an immediate cascade of pre-staged actions passes the launch on schedule.

Acknowledged Elephant: contractors push. Site Hosts push. Lenders push. Everyone in the franchisee’s orbit during the build has a reason to ask the franchisee to “just open” — to recover schedule, to satisfy curiosity, to demonstrate progress. The franchisee’s discipline is to say no, every time, until HiON has issued written commissioning approval. The cost of opening one day early is the franchise. The cost of waiting one day extra is one day.

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Section 4 · Core content

4.1 — Contractor qualification (§7.4.1)

Three standards (§7.4.1) — two [MANDATORY] plus one [RECOMMENDED]:

1. [MANDATORY] General contractor and major subcontractors (civil, electrical, signage at minimum) meet §14 vendor-qualification standards, carry HiON-required insurance, operate under written agreements with confidentiality and lien-waiver obligations
2. [MANDATORY] Electrical contractor must be licensed in the state of the HiON EV Facility, have documented experience with commercial EV charging or similar medium- to high-voltage commercial service, and be approved by HiON Engineering and Design Review before mobilization
3. [RECOMMENDED] Use general contractors and electrical contractors from the Partner Portal preferred-vendor list where available

The pre-mobilization electrical-contractor approval is the most operationally significant qualification gate. The franchisee submits the electrical contractor’s qualifications through the Partner Portal Engineering and Design Review channel; HiON reviews; approval is written. A franchisee who mobilizes the electrical contractor on the basis of “we’ll get the approval done while they start grading” has put schedule ahead of standard — and exposed the build to rework if HiON does not approve the chosen contractor.

The §14 vendor-qualification standards (full detail in M12) cover licensing, insurance, written contract with confidentiality + indemnification + lien-waiver provisions, documented safety program, performance track record. Every vendor on the build clears these — the GC, the EC, the signage installer, the civil contractor, the landscape contractor, the striping vendor.

4.2 — Required construction milestones and inspections (§7.4.2)

Nine milestones — each logged in the Partner Portal with date, inspector, outcome, follow-up actions:

Milestone	Trigger	Inspector
Pre-construction meeting	Before mobilization. Contractor, franchisee, HiON Construction and Commissioning Support team walk the design, schedule, and communication plan	Franchisee leads; HiON participates
Trenching and rough-in inspection	Before backfill of any trench containing conduit, grounding, or service conductors	AHJ as required; HiON Construction and Commissioning Support as requested
Cabinet pad and structural	Before setting the cabinet	AHJ; HiON may request photos or brief video walkthrough
Equipment set	Coordinated with Tesla Supercharger equipment delivery and any crane scheduling	HiON participates (remote or in person)
Electrical final	After all electrical work complete; before utility energization	AHJ; HiON Construction and Commissioning Support
Utility energization	Meter set; service energized	Utility
Network commissioning	Performed by HiON under the MSA	HiON (full detail in §7.5 / Module 4.6 below)
Accessibility, striping, signage final	After all site improvements complete	AHJ and/or signage permit authority; HiON Construction and Commissioning Support
Punch list close-out	Before commissioning sign-off	Franchisee, contractor, HiON team

[MANDATORY] §7.4.2: the franchisee must log every milestone inspection in the Partner Portal with date, inspector, outcome, and any follow-up actions. Missing logs delay commissioning.

The trenching and rough-in inspection is the milestone most frequently mismanaged. Once a trench is backfilled, the work below it is invisible. AHJs typically require pre-backfill inspection; HiON expects the franchisee to coordinate that inspection on schedule. A franchisee who backfills without inspection has buried a defect that may surface at commissioning — at which point excavation, re-inspection, and rework are the only paths to compliance.

4.3 — Change orders and scope changes (§7.4.3)

Two standards (§7.4.3) — one [MANDATORY] plus one [RECOMMENDED]:

1. [MANDATORY] Any change order affecting Site Design Manual standards, the cabinet pad, post placement, signage, accessibility, or the approved design package requires HiON prior written approval through the Partner Portal before contractor execution
2. [RECOMMENDED] Minor field adjustments that do not affect any required standard (shifting a bollard by a few inches to dodge an unmapped utility) may proceed; document in the as-built file

The dividing line is the standard. A change that touches a required standard requires HiON approval — even if it is a 6-inch shift in cabinet orientation. A change that does not touch a required standard may proceed — even if it is a substantial schedule adjustment. The franchisee’s discipline: when in doubt, file the change order through Partner Portal Engineering and Design Review. The cost of an over-cautious change-order filing is HiON’s response time; the cost of an under-cautious unfiled change is rework at commissioning.

4.4 — Construction site safety (§7.4.4)

Three [MANDATORY] safety standards (§7.4.4):

1. General contractor and every subcontractor operate under an active, documented safety program — OSHA-compliant jobsite practices, appropriate PPE, lock-out/tag-out procedures during electrical work, trench-safety practices where applicable
2. General contractor’s safety plan specifically covers the hazards of trenching, service-entrance work, and EV charging equipment installation. The plan and any incident documentation are preserved in the site file.
3. Report any OSHA recordable or serious incident on the construction site to HiON through the Partner Portal within 1 Business Day

The 1-Business-Day reporting standard is the construction equivalent of the §3.2.2 SEV 1 ticket-within-30-minutes standard. An OSHA recordable incident is a §3.2 SEV 1 event in construction context. The franchisee opens a Partner Portal ticket immediately, preserves the scene, follows the §13 incident reporting framework (M14), and continues construction only after the safety review is complete.

Construction site safety is operationally outside the §13 [MANDATORY] frameworks the franchisee will apply to operating site safety (those start at commissioning). But the construction-period discipline mirrors the operating-period discipline — and a franchisee who builds a culture of reporting and documentation during construction carries that culture into operations.

4.5 — Pre-commissioning readiness (§7.5.1)

Ten items the franchisee must complete before submitting the Commissioning Readiness Request:

1. AHJ electrical final sign-off — every electrical inspection passed; permit closed
2. Utility service energized and metering configured — the utility has set the meter and energized the service
3. Cabinet, posts, and connectors installed to specification — every piece of EV Charging Equipment in place per the design package and Site Design Manual
4. Bollards, accessible striping and wayfinding, pavement markings, signage installed per the approved design
5. Lighting installed and functional at night — the franchisee has confirmed photometric compliance through a night walkthrough
6. Site-area cleanliness — all construction debris removed, landscape restored, pavement restored
7. Punch list reviewed with the contractor — any outstanding items documented and scheduled
8. As-built drawings and final electrical test reports prepared and uploaded to the Partner Portal
9. Insurance in force for an operating HiON EV Facility per §13 (M14)
10. Site Host relationship in good standing — the site is unconditionally accessible on the proposed commissioning date

[MANDATORY] §7.5.1: the franchisee submits a Commissioning Readiness Request through the Partner Portal. HiON verifies readiness and schedules commissioning. Requesting commissioning for a site that is not ready may trigger a False Call-Out under the Master Services Agreement.

The False Call-Out is the operational consequence of premature commissioning requests. The MSA defines the mechanics; the practical effect is that the franchisee absorbs liquidated damages for HiON’s wasted commissioning trip. The franchisee’s discipline: the 10-item checklist is an honest checklist. If any item is not complete, the Commissioning Readiness Request is not submitted. The franchisee does not request commissioning to “lock in a date” hoping to complete the remaining items in parallel — that approach is exactly what triggers a False Call-Out.

4.6 — What commissioning involves (§7.5.2)

Commissioning is performed by HiON (or HiON’s designated agent) under the MSA. The equipment-side commissioning tests are governed by the MSA and HiON’s test procedures. From the franchisee’s perspective, the process involves eight steps:

1. Arrival of HiON’s commissioning team (or authorized commissioning agent) on the scheduled date
2. Equipment verification — cabinet, posts, connectors, and associated hardware installed and operable per specification
3. Network integration — registration of the HiON EV Facility in the Tesla Supercharger network; configuration in the Tesla mobile application (site name, metadata, driver-facing information)
4. Acceptance testing — charging-session initiation, throughput verification, payment-path verification, fault/recovery testing
5. Brand and site checks — confirmation that §2.4 brand execution (M03) is complete and correct
6. Accessibility verification — walk-through of the accessible route and the accessible charging bay
7. Safety and operational review — emergency-disconnect functionality, lighting, signage, operational checklists
8. Commissioning report issued, identifying any conditions

Commissioning is the moment the site transitions from “the franchisee’s construction project” to “an operating node in the Tesla Supercharger network.” The §1.4 (M02) version-control discipline applies — the commissioning report is the authoritative record of the site’s operating baseline. Future audits compare against this baseline.

4.7 — Franchisee cooperation and the public-opening prohibition (§7.5.3)

Three [MANDATORY] cooperation standards (§7.5.3):

1. Provide physical site access on the commissioning date at the time scheduled, including any required contractor standby or equipment staging
2. The franchisee or the DBM must be present for the commissioning walk-through, prepared to address any site-side punch items in real time
3. Do not open the HiON EV Facility to the public until HiON has issued written commissioning approval. Opening to the public without commissioning approval is a material breach.

The third standard is the single highest-stakes rule in this Module. The pressure to open early can be substantial — a Site Host who has been told the site will be live by a date; a curious driver who pulls up before commissioning; a marketing campaign whose timing was set before the schedule slipped. The discipline is categorical: no public access, no charging sessions accepted, no driver-facing site activation until the commissioning report is issued and the approval is written.

The operational consequence of opening early is not just contractual. The Tesla Supercharger network integration is not complete until commissioning; drivers who attempt to charge at a non-commissioned site experience session failures, payment failures, and a broken customer-promise event (§2.2.2 / M03). The franchisee’s brand has just absorbed a §2.2.2 violation on the franchisee’s own initiative. The audit consequence — a §3.3 finding (M02) and likely Corrective Action Required.

4.8 — Commissioning outcomes (§7.5.4)

Three outcomes:

Outcome	Meaning	Next step
Commissioning Approved	Site passes all acceptance tests; authorized to open to the public	Activate in the Tesla application per HiON’s instructions; execute the §11 launch playbook (M08); conduct grand-opening ribbon-cutting within the FA’s required timeframe
Commissioning Approved with Conditions	Site is acceptable to open subject to specified conditions with cure dates (signage correction, landscape completion)	Cure each condition within the stated period and confirm closure with HiON in writing
Commissioning Deferred	Site is not ready. Specific readiness gaps identified. False Call-Out may apply.	Address readiness gaps; request re-commissioning

The middle outcome — Commissioning Approved with Conditions — is the most common for a build that has been competently managed. The franchisee can open to the public while curing minor conditions; the conditions become a structured cure plan with HiON-confirmed closure. The franchisee’s discipline: cure on the dates stated, document each cure, confirm closure in writing. Conditions left to drift become §3.3 audit findings.

4.9 — Post-commissioning handoff to launch (§7.6)

The Manual’s framing (§7.6 Purpose): “Commissioning is the operational green-light. The grand-opening ribbon-cutting and the Start-Up Advertising spend are the brand green-light.”

Four [MANDATORY] standards in §7.6:

1. Execute the grand-opening ribbon-cutting at each HiON EV Facility within 5 calendar days of commissioning approval, consistent with FA §12.1 and the launch toolkit on the Partner Portal
2. Execute the Start-Up Advertising spend required by the FA and FDD, on the schedule and in the scope required by §11 (M08)
3. No delay to the ribbon-cutting or Start-Up Advertising past required dates in connection with Site Host availability, contractor punch-list items, weather, or local scheduling preferences, without HiON prior written approval
4. Confirm in the Partner Portal within 1 Business Day of commissioning approval: Go-Live Notification submitted (§4.4 / M04); launch-toolkit materials ordered; ribbon-cutting date scheduled; Start-Up Advertising plan confirmed; Site Host briefed on the launch plan

The 5-calendar-day ribbon-cutting window is short. A franchisee whose launch toolkit materials are not pre-ordered, whose ribbon-cutting venue logistics are not pre-arranged, whose Site Host briefing has not been pre-staged, will not hit the 5-day window. The discipline is pre-staging — every element of the launch is queued behind the commissioning approval, ready to execute the moment approval issues.

The §7.6 Metrics audit posture:

• Commissioning approval obtained before opening to the public, with date on file
• Ribbon-cutting completed within 5 calendar days of commissioning
• Start-Up Advertising spend executed on schedule and at or above the required amount; documentation retained
• As-built drawings, test reports, permit records, utility records on file
• No instance of the HiON EV Facility operating before commissioning approval

The last metric is the §7.5.3 [MANDATORY] standard restated as an audit item. A finding here is not a Corrective Action; it is a material breach.

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Section 5 · Decision drills

Drill 5.1 — The electrical contractor mobilized without approval

The franchisee’s general contractor has mobilized the electrical subcontractor and started rough-in work to recover schedule after a utility delay. The electrical contractor’s pre-mobilization approval has not yet been issued by HiON Engineering and Design Review — the submission was made but is at Day 9 of the typical review.

State the response and the cited basis. State the next two actions.

Drill 5.2 — The trench backfilled before inspection

The franchisee’s GC, eager to complete site work before a forecasted weather event, instructs the crew to backfill the service-conductor trench Friday afternoon, planning to call the AHJ inspector Monday morning.

State the response and the cited basis. State the corrective action.

Drill 5.3 — The bollard shift change order

During trenching, the GC encounters an unmapped utility line that requires shifting one of the planned bollards 18 inches to the east. The change does not affect the cabinet pad, post placement, signage, accessibility path, or any standard from the Site Design Manual.

State whether this change requires HiON prior written approval. State the discipline (what the franchisee does).

Drill 5.4 — The cabinet location shift

During cabinet pad installation, the GC discovers that the original location conflicts with a previously-unmapped underground irrigation line. The GC proposes moving the cabinet pad 6 feet south. The cabinet’s new location is within the parking-bay envelope but is a deviation from the approved design.

State whether this change requires HiON prior written approval and the cited basis. State the next two actions.

Drill 5.5 — The OSHA-recordable incident

A subcontractor’s worker suffers a fall while installing the cabinet pad, resulting in a fracture. The incident is OSHA recordable. The GC reports the incident to the franchisee Monday morning; the incident occurred Friday afternoon.

State whether the franchisee has met the §7.4.4 [MANDATORY] reporting standard. State the corrective action.

Drill 5.6 — The premature Commissioning Readiness Request

The franchisee is at Day 145 post-Site-Authorization and feels pressure to lock in a commissioning date before the §6.4 18-month-from-lease boundary. The site has 9 of the 10 pre-commissioning readiness items complete; the landscape restoration is on a 10-day delivery. The franchisee considers submitting the Commissioning Readiness Request and completing landscape in parallel.

State the response and the cited basis. State whether the franchisee submits the Commissioning Readiness Request.

Drill 5.7 — The Site Host’s “soft opening” request

Two days before scheduled commissioning, the Site Host requests permission to do an “invitation-only soft opening” Friday evening — 30 to 50 invited guests, no charging sessions, just a brand walkthrough and a champagne reception around the cabinet.

State the response and the cited basis.

Drill 5.8 — The driver who pulls up before commissioning

Three days before scheduled commissioning, a driver pulls into the partially-completed HiON EV Facility, sees the cabinet and posts, and attempts to initiate a charging session through the Tesla app. The driver is confused when the session does not connect and asks the on-site contractor what’s happening.

State whether this constitutes a public-opening violation and the cited basis. State the franchisee’s response (verbatim) and the next two actions.

Drill 5.9 — Commissioning Approved with Conditions

The commissioning report comes back: Commissioning Approved with Conditions. The conditions are: (a) replace one faded wayfinding sign within 21 days, (b) complete landscape restoration on the southwest corner within 14 days, (c) confirm the night lighting photometric in the western corner within 30 days.

State whether the franchisee may open to the public, the cited basis, and the cure-tracking discipline.

Drill 5.10 — The 5-calendar-day launch window slipping

Commissioning approval issues Wednesday at 4pm. The franchisee’s chosen ribbon-cutting venue is unavailable until the following Wednesday — 7 calendar days post-commissioning. The Site Host has a corporate event scheduled at the property the Saturday after commissioning and would prefer the ribbon-cutting “settle in” before that.

State the response and the cited basis. State whether the franchisee files an extension request.

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Section 6 · Common operator errors

6.1 — Mobilizing the electrical contractor before HiON approval

The franchisee, under schedule pressure, instructs the GC to mobilize the electrical subcontractor while the pre-mobilization approval is pending.

• Consequence: §7.4.1 [MANDATORY] violation. If HiON does not approve the chosen contractor, the work performed has been done by an un-vetted electrical contractor — rework, audit finding, schedule cost.
• Discipline: electrical contractor pre-mobilization approval is a gate, not a parallel task. Submit the qualifications early in the build planning; wait for HiON’s written approval; mobilize after.

6.2 — Backfilling trenches before inspection

The GC backfills a service-conductor trench before AHJ inspection and before HiON’s optional inspection.

• Consequence: §7.4.2 violation (milestone log missing the inspection). AHJ will require excavation, re-inspection, and possibly re-permit. Schedule loss substantial.
• Discipline: the trenching and rough-in inspection is non-negotiable. The GC’s safety plan includes pre-backfill inspection as a hold-point. The franchisee verifies the inspection happened before authorizing backfill.

6.3 — Treating change orders as field decisions

The franchisee’s GC adapts to field conditions by adjusting the cabinet orientation, the post spacing, or the signage placement without filing a change order.

• Consequence: §7.4.3 [MANDATORY] violation. The as-built site differs from the HiON-approved design. Commissioning surfaces the deviation — cure (rework) or post-fact §1.2.6 exception with uncertain outcome.
• Discipline: the [MANDATORY]-touching change-order list (Site Design Manual standards, cabinet pad, post placement, signage, accessibility, approved design package) is memorized. Every such change is a Partner Portal Engineering and Design Review ticket before contractor execution.

6.4 — Late OSHA-recordable reporting

The franchisee’s GC reports an OSHA-recordable incident on Monday morning when the incident occurred Friday afternoon.

• Consequence: §7.4.4 [MANDATORY] violation (within 1 Business Day). Audit finding. Possible §13 (M14) compliance exposure.
• Discipline: the GC’s safety reporting protocol routes OSHA-recordable incidents to the franchisee immediately; the franchisee opens a Partner Portal ticket within 1 Business Day. Build this protocol into the pre-construction meeting safety review.

6.5 — Requesting commissioning for an unready site

The franchisee, under §6.4 schedule pressure, submits the Commissioning Readiness Request despite knowing one or more items on the 10-item readiness checklist are not complete.

• Consequence: §7.5.1 — False Call-Out may apply under the MSA. Liquidated damages. Audit-finding exposure. Commissioning Deferred outcome with new readiness gaps to address.
• Discipline: the readiness checklist is honest. If any item is incomplete, the request is not submitted. If schedule pressure forces a question of whether to request, escalate to FBC + Engineering and Design Review for guidance — do not submit and hope.

6.6 — Opening the site to the public before commissioning approval

The franchisee, with the cabinet visible and the lights on, allows a “soft opening,” a private event, or even a single driver session before HiON has issued written commissioning approval.

• Consequence: §7.5.3 [MANDATORY] violation. Material breach. §2.2.2 customer-promise event (M03). Audit finding likely a §3.3 Material Default (M02). Compounding consequences.
• Discipline: no public access of any kind — including private events, soft openings, single-driver “tests,” invitation-only walkthroughs — until commissioning approval is written. The site is fenced, signed “Not Open Yet,” and physically inaccessible to drivers until approval.

6.7 — Skipping the §7.6 1-Business-Day post-commissioning cascade

The franchisee receives commissioning approval and begins the launch cascade two days later, missing the 1-Business-Day Partner Portal confirmation window for Go-Live Notification, launch-toolkit ordering, ribbon-cutting scheduling, advertising plan, Site Host briefing.

• Consequence: §7.6 [MANDATORY] violation. Risks the 5-calendar-day ribbon-cutting window. Audit-finding exposure under §7.6 Metrics.
• Discipline: the launch cascade is pre-staged. The moment commissioning approval issues, every element of the §7.6 confirmation is executed. The franchisee treats commissioning approval as the trigger event for a pre-loaded sequence, not as the start of planning.

6.8 — Letting Commissioning Approved with Conditions cure dates drift

The franchisee receives Commissioning Approved with Conditions and opens to the public, then deprioritizes the cure dates because the site is operating.

• Consequence: §7.5.4 violation (cure within stated period). Audit finding. Possible escalation to material default if conditions persist.
• Discipline: the cure dates are tracked the same way [MANDATORY] standards are tracked. Each condition has an owner, a cure date, a documentation requirement, and a written closure confirmation to HiON.

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Section 7 · Competency assessment

Knowledge check (12 questions; 80% pass)

1. The franchisee’s electrical contractor must be approved by HiON Engineering and Design Review: (a) within 30 days of mobilization (b) before mobilization (§7.4.1 [MANDATORY]) (c) at the franchisee’s discretion (d) after the first milestone inspection

2. A change order shifting a bollard 6 inches to dodge an unmapped utility line, where the change does not affect any required standard: (a) requires HiON prior written approval (b) may proceed; document in the as-built file (§7.4.3 [RECOMMENDED]) (c) requires FBC verbal approval (d) requires an exception under §1.2.6

3. A change order shifting the cabinet location by 4 feet to dodge an unmapped utility line: (a) may proceed as a minor field adjustment (b) requires HiON prior written approval through the Partner Portal before contractor execution (§7.4.3 [MANDATORY]) (c) requires AHJ approval only (d) is acceptable if the engineer of record certifies the change

4. An OSHA recordable incident on the construction site must be reported to HiON: (a) within 24 hours (b) within 1 Business Day (§7.4.4 [MANDATORY]) (c) within 5 Business Days (d) at the next FBC touchpoint

5. The franchisee may submit the Commissioning Readiness Request: (a) anytime after lease execution (b) only after all 10 §7.5.1 pre-commissioning readiness items are complete (§7.5.1 [MANDATORY]) (c) when 8 of 10 readiness items are complete (d) immediately after Site Authorization

6. Requesting commissioning for a site that is not ready: (a) is acceptable to lock in a date (b) may trigger a False Call-Out under the Master Services Agreement (§7.5.1) (c) requires HiON to commission anyway (d) is acceptable with FBC verbal approval

7. The franchisee may open the HiON EV Facility to the public: (a) at the franchisee’s discretion after the lights are on (b) once the AHJ electrical final is signed (c) only after HiON has issued written commissioning approval (§7.5.3 [MANDATORY]) (d) at a private “soft opening” while awaiting commissioning approval

8. A “Commissioning Approved with Conditions” outcome means: (a) the franchisee may not open until conditions are cured (b) the franchisee may open subject to specified conditions with cure dates (§7.5.4) (c) the franchisee may open without conditions if the conditions are minor (d) the franchisee must re-submit the Commissioning Readiness Request

9. The grand-opening ribbon-cutting must be executed within: (a) 14 calendar days of commissioning approval (b) 10 calendar days of commissioning approval (c) 5 calendar days of commissioning approval (§7.6 [MANDATORY]) (d) 30 calendar days of commissioning approval

10. The franchisee may delay the ribbon-cutting or Start-Up Advertising past required dates: (a) at the franchisee’s discretion for legitimate business reasons (b) when the Site Host requests a delay (c) only with HiON prior written approval (§7.6 [MANDATORY]) (d) when weather prevents the event

11. Failure to log a milestone inspection in the Partner Portal: (a) is acceptable if the AHJ has signed the permit card (b) delays commissioning (§7.4.2 [MANDATORY]) (c) is acceptable if the franchisee has records elsewhere (d) is acceptable for non-electrical milestones

12. Opening the HiON EV Facility to the public without commissioning approval: (a) is acceptable if no driver attempts to charge (b) is acceptable for invitation-only events (c) is a material breach of the Franchise Agreement (§7.5.3 [MANDATORY]) (d) is acceptable if HiON has acknowledged the readiness gaps

Application demonstration — the commissioning readiness audit

A 60-minute live exercise. The trainer presents the trainee with a Commissioning Readiness Pack containing:

• A draft Commissioning Readiness Request the franchisee is considering submitting
• A construction milestone log with 2 gaps (missing trenching inspection log; missing equipment-set photo)
• A change-order log with 1 [MANDATORY]-touching change executed without HiON approval
• A safety incident report from 4 days ago (OSHA recordable) that has not yet been reported to HiON
• A pre-commissioning checklist with 2 of 10 items unchecked (lighting photometric night verification; insurance endorsement renewal)
• A Site Host email requesting a “VIP soft opening” the evening before scheduled commissioning
• The §6.4 schedule showing Day 168 of a 180-day window

The trainee must:

1. Identify whether the Commissioning Readiness Request can be submitted at this point — if not, identify every gap and the §7.5.1 [MANDATORY] basis
2. Identify the §7.4.2 milestone-log gaps and the corrective action (back-file? re-inspect?)
3. Identify the §7.4.3 unapproved change order and state the corrective action — including a §1.2.6 post-fact exception request if required
4. Identify the §7.4.4 [MANDATORY] violation on the OSHA-recordable incident reporting and state the corrective action
5. Respond to the Site Host’s VIP soft-opening request with the verbatim language and the cited basis
6. Plan the §6.4 schedule remediation given Day 168 and the gaps identified — does the franchisee request a §4.2.1 extension?

Pass criteria: trainee correctly identifies every readiness gap, every milestone log gap, the [MANDATORY]-touching unapproved change order, the safety reporting violation, the public-opening prohibition, and the schedule risk. Citation of section numbers preferred but not required if substantive actions are correct.

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Section 8 · Job aids

Job Aid 8.1 — Contractor qualification checklist

The §7.4.1 + §14 vendor-qualification standards as a checklist applied to the GC, EC, signage contractor, civil contractor, landscape, and striping vendors. Includes the pre-mobilization HiON Engineering and Design Review approval gate for the electrical contractor.

File: modules/M07-jobaids/M07-contractor-qualification.md

Job Aid 8.2 — The 9-milestone inspection tracker

A tracker for the §7.4.2 milestones. Each milestone has expected date, actual date, inspector, outcome, Partner Portal log reference, follow-up actions. Built to feed the Commissioning Readiness Request.

File: modules/M07-jobaids/M07-milestone-tracker.md

Job Aid 8.3 — Change-order routing decision card

Front: the 6-element [MANDATORY] list (Site Design Manual standards, cabinet pad, post placement, signage, accessibility, approved design package). Any change touching any of these requires HiON approval. Back: the [RECOMMENDED] field-adjustment path for non-touching changes — document in the as-built file.

File: modules/M07-jobaids/M07-change-order-card.md

Job Aid 8.4 — Construction safety protocol

A one-page safety protocol covering OSHA-recordable reporting (1 Business Day to HiON), serious-incident escalation, trench-safety hold-points, lock-out/tag-out, and PPE requirements. Reviewed at the pre-construction meeting with every contractor.

File: modules/M07-jobaids/M07-construction-safety-protocol.md

Job Aid 8.5 — The 10-item pre-commissioning readiness checklist

The §7.5.1 checklist as an audit-ready form. Each item has a completion date, the supporting documentation (AHJ permit card, utility energization letter, etc.), and a Partner Portal upload reference. The franchisee runs through this honestly — every item complete before submitting the Commissioning Readiness Request.

File: modules/M07-jobaids/M07-commissioning-readiness-checklist.md

Job Aid 8.6 — The post-commissioning 1-Business-Day cascade

A pre-staged checklist for the §7.6 launch cascade. Each item has a “trigger event = commissioning approval” status and an immediate execution path: Go-Live Notification submission; launch-toolkit materials order; ribbon-cutting date scheduling; Start-Up Advertising plan confirmation; Site Host briefing.

File: modules/M07-jobaids/M07-post-commissioning-cascade.md

Job Aid 8.7 — The “no public opening” signage protocol

A protocol for managing the pre-commissioning site presentation — physical barriers, “Not Open Yet” signage, contractor instruction on responding to driver inquiries, the verbatim response language for the on-site team when a driver attempts to access the site.

File: modules/M07-jobaids/M07-no-public-opening-protocol.md

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Section 9 · Facilitator notes

Pacing — 165 minutes (2h 45min, two 10-minute breaks built in)

Time	Section	Notes
0:00–0:10	Opening — the False Call-Out math	Read aloud a redacted version of a False Call-Out invoice from the MSA. Most operators have not encountered the dollar figure before; the visceral cost framing sets the tone for the readiness discipline in §4.5.
0:10–0:30	§4.1–4.2 (Contractor qualification + milestones)	Walk the §7.4.1 [MANDATORY] standards and the 9 milestones. If the franchisee’s GC is in the room, this segment is where they participate most. Distribute Job Aids 8.1, 8.2. Run Drill 5.1 (electrical contractor mobilization) and Drill 5.2 (backfilled trench).
0:30–0:55	§4.3 (Change orders)	Walk the [MANDATORY] / [RECOMMENDED] split and the 6-element [MANDATORY] list. Distribute Job Aid 8.3. Run Drills 5.3 (bollard shift — proceeds) and 5.4 (cabinet shift — requires approval).
0:55–1:05	§4.4 (Construction safety)	Walk the 3 [MANDATORY] standards. Distribute Job Aid 8.4. Run Drill 5.5 (late OSHA reporting).
1:05–1:15	BREAK
1:15–1:45	§4.5–4.6 (Pre-commissioning readiness + commissioning process)	Heaviest section. Walk the 10-item checklist and the 8-step commissioning process. Distribute Job Aid 8.5. Run Drill 5.6 (premature Commissioning Readiness Request) — heaviest emphasis on the False Call-Out math.
1:45–2:10	§4.7–4.8 (Cooperation + public-opening prohibition + outcomes)	Heaviest emphasis on §7.5.3 [MANDATORY] — no public opening without written approval. Distribute Job Aid 8.7. Run Drills 5.7 (Site Host soft opening) and 5.8 (driver pulls up). The two drills are designed to test the trainee’s discipline under different pressures — institutional (Site Host) and incidental (driver). Both decline categorically.
2:10–2:20	BREAK
2:20–2:40	§4.9 (Post-commissioning handoff)	Walk the 4 [MANDATORY] standards and the 5-calendar-day window. Distribute Job Aid 8.6. Run Drill 5.10 (5-day window slipping).
2:40–2:45	Close + application demonstration brief	Distribute the Commissioning Readiness Pack brief for the post-session 60-minute exercise.

SME handoffs

• §4.1–4.4 (Construction): Tony Cuomo (CX) on the build standard; Joe Frank (Ops) on construction-period discipline. The franchisee’s own GC adds the most ground-truth operational detail.
• §4.5–4.8 (Commissioning): Tony Cuomo (CX) per the Training Matrix on the commissioning-side rationale; HiON’s Construction and Commissioning Support team SME if available is the right SME for the actual on-site walkthrough simulation.
• §4.9 (Post-commissioning handoff into launch): Will Frank (Dev) bridges to M08 (Launch and Local Marketing) — content owner there.

Decision drill — model answers (abbreviated)

Drill 5.1 — Electrical contractor pre-approval. Stop work immediately on any electrical activity. §7.4.1 [MANDATORY] — electrical contractor must be approved before mobilization. Open Partner Portal ticket to Engineering and Design Review noting the mobilization gap and requesting expedited approval review. Until written approval issues, no further electrical work. The schedule cost of stopping is small relative to the cost of HiON disapproving the contractor and requiring rework.

Drill 5.2 — Backfilled trench. Document the gap in the Partner Portal milestone log. Notify the AHJ and request an alternative inspection method (some AHJs accept video documentation, partial excavation samples, or contractor-provided test reports under specified conditions). If the AHJ requires re-excavation, schedule it. Open a Partner Portal ticket under Construction and Commissioning Support documenting the situation. The forecast weather event is not a defense — the GC’s safety plan should have built in the inspection as a hard hold-point.

Drill 5.3 — Bollard shift. May proceed. §7.4.3 [RECOMMENDED] — the change does not affect cabinet pad, post placement, signage, accessibility, approved design package, or any Site Design Manual standard. Document the shift in the as-built file. No Partner Portal ticket required, but the franchisee notes the field decision in the construction log for transparency.

Drill 5.4 — Cabinet shift. Requires HiON prior written approval. §7.4.3 [MANDATORY] — change order affecting the cabinet pad / approved design package. Open Partner Portal ticket under Engineering and Design Review with the GC’s reasoning, the unmapped irrigation line documentation, the proposed new location, and the design implications. Halt cabinet pad installation until written approval. Communicate the schedule impact to the FBC.

Drill 5.5 — Late OSHA report. Manday-morning reporting of a Friday-afternoon incident is a §7.4.4 [MANDATORY] violation (within 1 Business Day means by end of Monday at the latest if Friday is Day 0 — but the spirit is “promptly”). Submit the Partner Portal ticket immediately with the incident details and the late-reporting acknowledgment. Document the corrective action: the GC’s safety reporting protocol updated to escalate OSHA-recordable incidents to the franchisee within hours, not days. The late report itself is a finding; the corrective action mitigates further exposure.

Drill 5.6 — Premature Commissioning Readiness Request. Do not submit. §7.5.1 [MANDATORY] — 10 of 10 readiness items must be complete. False Call-Out exposure under the MSA. The right path: complete the landscape restoration on the 10-day delivery; submit the Commissioning Readiness Request only after item 10 is complete. The franchisee is at Day 145 of a 180-day window — the 10-day landscape delay does not threaten the deadline. If the schedule actually threatens the §6.4 boundary, file a §4.2.1 Development Extension request — do not submit a premature Commissioning Readiness Request.

Drill 5.7 — Site Host soft opening. Decline. §7.5.3 [MANDATORY] — no opening to the public, including private events, soft openings, or invitation-only walkthroughs, before written commissioning approval. The “no charging sessions, just a brand walkthrough” framing does not cure the violation. The site is not a HiON EV Facility until commissioned; presenting it to 30–50 invited guests as an operational HiON site before commissioning misrepresents the operational status. Offer the Site Host the post-commissioning launch event (ribbon-cutting) as the appropriate venue.

Drill 5.8 — Driver pulls up. Yes, this is a §7.5.3 risk. The driver attempting to charge constitutes an attempt at public access. The on-site contractor’s response (verbatim): “This site isn’t live yet — we’re still in construction. The Tesla app should be showing it as offline; if it’s showing as available there’s a metadata issue we need to fix. The closest open Supercharger site is at [location]. We’re targeting opening by [approximate date].” Next two actions: (1) open a Partner Portal ticket to Construction and Commissioning Support to verify the site is correctly flagged as offline in the Tesla app metadata; (2) reinforce the physical “Not Open Yet” signage and any barriers preventing driver pull-ins.

Drill 5.9 — Commissioning Approved with Conditions. The franchisee may open to the public. §7.5.4 — the “Conditions” outcome authorizes opening subject to specified cure dates. Cure-tracking discipline: each condition has an owner on the team, the cure date logged in the Partner Portal, the cure work scheduled, and the cure closure documented in writing to HiON when complete. The franchisee does not let the conditions drift; failure to cure on schedule may escalate to a Commissioning Deferred outcome or a §3.3 (M02) audit finding.

Drill 5.10 — 5-day window slipping. §7.6 [MANDATORY] — no delay without HiON prior written approval. The Site Host’s preference for “settle in” is not a §7.6 ground for extension. The franchisee files an extension request through Partner Portal documenting (a) venue availability constraint, (b) Site Host corporate event scheduling, (c) proposed alternative date (Day 7 post-commissioning vs. Day 5 standard). HiON may grant, deny, or condition. The franchisee does not delay unilaterally — delay without written approval is the §7.6 [MANDATORY] violation. Note: the franchisee’s pre-staging should have identified the venue constraint before commissioning; this drill is teaching the consequence of inadequate pre-staging.

Recommended visual aids

• A real (redacted) MSA False Call-Out provision projected during §4.5
• The 10-item readiness checklist projected as the centerpiece of §4.5
• A real (redacted) commissioning report (Approved / Approved with Conditions / Deferred) during §4.8
• The §7.6 1-Business-Day cascade items as a visual countdown during §4.9

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Section 10 · Cross-references

Modules

• M02 (Governance, Manual, Support, Escalation) — §3.2 SEV system applies to construction-period safety incidents; §3.3 audit posture covers milestone logs and as-built drawings
• M03 (Brand Promise and Brand Execution — §2.4) — brand execution standards are commissioning items (§7.5.2 step 5); the 15-day signage remediation discipline from M03 carries into post-commissioning condition cure
• M04 (Site Acquisition and Feasibility — §6.4) — the §6.4 18-month-from-lease opening boundary is the schedule constraint this Module is building against
• M05 (Lease, Site Host Relationship — §5) — the lease’s 24/7/365 access provisions enable construction access; the §5.3 division of obligations frames the Site Host’s role during construction
• M06 (Design, Permitting, Utility Coordination — §7.1–§7.3) — picks up where M06 ends; the HiON-approved design package and the energized utility service are the inputs to this Module
• M08 (Launch and Local Marketing — §11) — the §7.6 post-commissioning handoff is the entry point to M08; the ribbon-cutting and Start-Up Advertising are fully detailed in M08
• M10 (Site-Area Maintenance, Monitoring, Fault Escalation — §9) — the operational rhythm begins the day commissioning approves; the as-built drawings and test reports from this Module are the operational baseline
• M14 (Compliance, Safety, Insurance, Risk — §13) — construction-period safety (§7.4.4) is a §13 framework applied to the build phase

External documents

• Operations Manual §7.4–§7.6 (Construction, Commissioning, Post-Commissioning)
• Master Services Agreement (commissioning + False Call-Out mechanics + Uptime Guarantee post-commissioning)
• HiON Site Design Manual (Partner Portal)
• HiON launch toolkit (Partner Portal — referenced; full detail in M08)
• Operations Manual Appendices B (Build Checklists)
• OSHA recordable-incident reporting standards (jurisdiction-specific)

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Section 11 · Source verification log

Claim	Manual reference	Status
§7.4.1 [MANDATORY] contractor qualification (GC + major subs per §14; insurance; written agreements with confidentiality + lien-waiver)	§7.4.1	verified
Electrical contractor licensed in state + commercial EV / high-voltage experience + HiON Engineering and Design Review pre-mobilization approval	§7.4.1 [MANDATORY]	verified
9 milestones (pre-construction meeting through punch list close-out)	§7.4.2	verified
Milestone log [MANDATORY] in Partner Portal	§7.4.2	verified
Change order [MANDATORY] approval gate for changes affecting standards, cabinet pad, post placement, signage, accessibility, approved design package	§7.4.3	verified
Minor field adjustments [RECOMMENDED] — document in as-built	§7.4.3	verified
3 [MANDATORY] safety standards (safety program, trench/service/EV-specific safety plan, 1-BD OSHA recordable reporting)	§7.4.4	verified
10 [MANDATORY] pre-commissioning readiness items	§7.5.1	verified
Commissioning Readiness Request [MANDATORY]	§7.5.1	verified
False Call-Out exposure for unready commissioning request	§7.5.1	referenced — MSA primary needed for actual mechanics [CONFIRM]
8 commissioning steps (arrival, equipment, network integration, acceptance, brand, accessibility, safety/operational, report)	§7.5.2	verified
3 [MANDATORY] franchisee cooperation standards (access, DBM presence, no public opening before approval)	§7.5.3	verified
Opening to public without commissioning approval is material breach	§7.5.3 [MANDATORY]	verified
3 commissioning outcomes (Approved / Approved with Conditions / Deferred)	§7.5.4	verified
5-calendar-day ribbon-cutting after commissioning approval	§7.6 [MANDATORY]	verified
Start-Up Advertising commitment material; failure is FA default	§7.6 [MANDATORY] + §2.4.5	verified (cross-confirmed with M03 §2.4.5)
4 [MANDATORY] §7.6 standards (ribbon-cutting timing, SUA, no unilateral delay, 1-BD post-commissioning cascade)	§7.6	verified

Outstanding unverified items

#	Claim	Primary source needed	Resolver
M07.OUT.01	MSA False Call-Out specific mechanics (amount, calculation, dispute path)	MSA primary	Jim Frank / Joe Frank (Ops)
M07.OUT.02	MSA acceptance testing procedure specifics	MSA primary	Joe Frank (Ops) / Engineering and Design Review
M07.OUT.03	HiON launch toolkit current contents (referenced; full detail in M08)	Partner Portal launch toolkit	Will Frank
M07.OUT.04	Operations Manual Appendices B (Build Checklists)	Manual Appendices	Joe Lewis (COO)

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Section 12 · Change log

Version	Date	Author	Changes
v0.1	2026-05-19	Claude (draft)	Initial draft against Operations Manual v1.0 Working Draft. All Manual citations verified. Four outstanding items defer to MSA / Partner Portal current contents. The §7.5.3 public-opening prohibition gets the heaviest pedagogical emphasis — material breach exposure is the single largest stakes in the Phase C build cycle.