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 2018 and 2021 codes do not significantly alter these requirements, but do add a checklist that the owner can use to attest the work has been completed.
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 us or Stephen E. Oskin, PE, LEED AP at 814-231-2180 or seo@ba-inc.com to help navigate these requirements.