The following article from 2022 has been revised to reflect the upcoming 2021 code changes where applicable. For most medium to large HVAC projects, and all lighting projects, commissioning is now a requirement. Code issues aside, startup and operational issues are typically found during the commissioning process, which can prevent operational issues, which are much more intrusive once the building is occupied. While this may sound like the hard sell for commissioning, Barton Associates does not offer commissioning services, but sees the clear value they provide.
With construction costs rising across the board, every dollar counts when planning for a project. Lately, many owners are getting surprised by a substantial cost that presents itself late in the project. Commissioning. Did you know that your project may require commissioning even though it is not a LEED or other green initiative project?
Starting with the 2012 International Energy Conservation Code (IECC), mechanical system commissioning has been required for all projects where cooling loads exceed 480,000 Btu/h (40 tons) and heating/service water heating loads exceed 600,000 Btu/hr, except unitary equipment serving dwelling and sleeping units in hotels, motels or similar units. This generally means that it may be a requirement in most facilities 10,000SF and above, and in almost all occupied facilities greater than 20,000SF, it is a foregone conclusion. The requirement for commissioning is tied to the final inspection and can prevent a certificate of occupancy being issued from the code official.
Lighting control testing was also added during the same code iteration, but without stringent verification requirements.
In the 2015 code cycle, the IECC broadened the exception for the mechanical commissioning requirement by removing the “hotel, motel or similar units” requirement, resulting in excluding unitary systems that serve individual sleeping or dwelling units. However, this same code cycle significantly strengthened the lighting commissioning requirements. There are now no exceptions for the lighting control system commissioning requirement. Furthermore, proof of commissioning is now required “prior to passing final inspection.”
The 2021 code does not significantly alter these requirements but do add a checklist that the owner must use to attest the work has been completed. This checklist includes the following items required to be performed by the commissioning authority and attested to by the owner, in addition to any standard reports.
✔ Commissioning Plan was used during construction and includes all items required by Section C408.2.1
✔ Systems Adjusting and Balancing has been completed.
✔ HVAC Equipment Functional testing has been executed. If applicable, deferred and follow-up testing is scheduled to be provided on: ___
✔ HVAC Controls Functional testing has been executed. If applicable, deferred and follow-up testing is scheduled to be provided on: ___
✔ Economizer Functional testing has been executed. If applicable, deferred and follow-up testing is scheduled to be provided on: ___
✔ Lighting Controls Functional testing has been executed. If applicable, deferred and follow-up testing is scheduled to be provided on: ___
✔ Service Water Functional testing has been executed. If applicable, deferred and follow-up testing is scheduled to be provided on: ___
✔ Manual, record documents and training have been completed or scheduled.
✔ Preliminary Commissioning Report submitted to owner and includes all items required by section C408.2.4
Who is doing this work? Is it the contractor? The Engineer? A third party?
The mechanical section for the commissioning plan requires that the plan be developed by a registered design professional, or approved agency. An approved agency is defined by the code as “An established and recognized agency regularly engaged in conducting tests or furnishing inspection services, when such an agency is approved by the code official.” While this does not preclude the Engineer of Record or the contractor performing this work, it does clarify that whoever does this work, must regularly perform this type of work.
The lighting controls section does not specify who does the commissioning, just that the “registered design professional shall provide evidence that the lighting control systems have been tested…” This statement leaves some ambiguity in the execution of the work.
One could argue that a contractor who regularly inspects work done by themselves or others meets the threshold of “approved agency.” It could be argued that a design professional that engages in inspections could also perform this work, even if they had designed the project. In any case, it is clear that commissioning takes time and money to complete.
The project team needs to be clear from the beginning as to what level of commissioning is required, who is documenting the requirements, and who will be expected to execute the work. These are only the requirements as related to the IECC, and do not reflect the more stringent ASHRAE 90.1 or LEED requirements. Feel free to contact Stephen Oskin, Director of Engineering (seo@ba-inc.com) at Barton Associates to help navigate these requirements.