May 20, 2016

Defining Commissioning Under the 2015 IECC

One of the most pressing issues I am running across lately is helping our clients understand how building commissioning is addressed in the 2015 International Energy Conservation Code (IECC). The new code—which requires commissioning— was recently adopted by the City of San Antonio. Because the City jumped from the 2009 version into the 2015 version, we bypassed the IECC 2012 code where commissioning was first required, and as a result, some members in our community may be seeing commissioning for the first time. To help get a handle on the changes, we have studied the code extensively as well as the City’s take on its requirements, and present our findings below.

How We Know Commissioning Currently

In our experience, commissioning has been a regular attribute in federal work, large Design-Build projects, and LEED certification, and typically follows accepted industry guidelines and procedures set forth by the NEBB and ASHRAE. In each of these standards, a full commissioning process identifies activities associated with the Design, Construction and Warranty phases, and typically includes the following: performing design reviews, writing and executing system installation checks and functional performance tests, preparing a final report, and assisting the Owner with Operations and Maintenance transition into the warranty phases. With regard to LEED certification, fundamental commissioning is associated with the construction phase, where enhanced commissioning adds the bookend phases of design and warranty to the base process.

What’s Different about 2015 IECC Commissioning?

When we studied the 2015 IECC, we found that the commissioning requirements are general in nature, but appear to follow a similar path to LEED fundamental commissioning. As mentioned above, this would indicate that commissioning is contained to just the construction phase and is not required in the design or warranty phases. That gives us the “when” of the 2015 IECC commissioning process. However, in order to understand the full implications of the IECC code language, it is important to understand the “what,” “how” and “who.”

Defining 2015 IECC Commissioning: What and How

The commissioning process—the “what”— has been studied and developed beginning as far back as the 1980s, most notably by the NEBB and ASHRAE organizations, though these entities have only recently begun to address the technical side of commissioning—the “how.” Currently, the IECC requirements only relate to the process and do not address any technical requirements, which would lead us to believe we should follow the more detailed requirements set by other organizations.

Defining 2015 IECC Commissioning: Who

Perhaps most important is to clearly define the qualification criteria for who is actually going to perform the work. Currently, the 2015 IECC requirements defining who can act as a commissioning agent indicate that “…the registered design professional or approved agency shall provide evidence of mechanical systems commissioning…” To further define this requirement, the City of San Antonio issued Information Bulletin (IB) #221 which defines the commissioning certification requirements for the “approved agency.”

In addition to these requirements, consider hiring a National Environmental Balancing Bureau (NEBB) certified commissioning firm and agent. One of NEBB’s proven processes requires integration of the firm and individual agent certification. This is the only training and certification organization that requires this ‘dual’ criteria be met in order to achieve certification. These requirements, combined with hands on training and examinations, and published process and technical commissioning procedures, help to ensure that NEBB certified firms and individuals possess the appropriate commissioning credentials for your project.

Make the Most of It

In my opinion, the best way to follow 2015 IECC commissioning requirements would be to make the most of the service you are enlisting. I would ask all of our owners and clients to better understand “who” is doing your work. Ask for qualification information beyond related project information, up to and including certifications, from your commissioning groups. The right certifications will not only give you assurance that your agent is qualified, but can also give you a glimpse into “how” that person will perform the work, and “what” field tests and reporting systems he or she will use, etc.

By Brian Keller, NEBB CP

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