Commissioning requirements have been in California’s building code for more than a decade, first in CALGreen in 2011, followed by the Energy Code in 2014. However, we still see a lack of consistency in both enforcement and delivery. This is particularly concerning since, according to the U.S. Department of Energy1, commissioning “remains a cost-effective way to improve building operations and mitigate risks associated with poor building performance”, including in the areas of energy savings, occupant health and comfort, and long-term maintenance.
Scope and Applicability
Commissioning is a systematic process of ensuring that building systems are designed, installed, tested, and capable of being operated and maintained according to the owner’s operational needs. Requirements cover the following building systems:
- Heating, Ventilation, and Air Conditioning (HVAC) systems
- Lighting and lighting controls
- Domestic hot water systems and controls
- Building envelope systems
- Renewable energy systems
- Irrigation controls
- Any other building equipment or system listed by the Owner
The most involved commissioning requirements apply to new non-residential construction projects greater than 10,000 square feet, but even smaller non-residential projects require some level of Title 24 commissioning.
The commissioning process involves several steps that begin with the initial design and continues through to start-up and operations. Whether you’re involved in design, construction, plan review, or inspection, we’ll highlight a few key processes and documents to keep you on track along the way. This article will cover the design phase requirements, and our next blog will finish up with the construction phase requirements.
Commissioning Requirements for a Building Permit
There are five components of commissioning required before a project can get a building permit.
- CEC-NRCC-CXR: This is the Title 24 Energy Code compliance form that walks you through the parts and pieces of commissioning and must be submitted with the building permit application for all non-residential new construction projects regardless of size.
- Owner Project Requirements (OPR): Energy-related expectations and requirements of the building are captured in the OPR, including energy efficiency goals, lifespan expectations, temperature and light levels required, training and maintenance objectives, etc.
- Basis of Design (BOD): A BOD is a written explanation of how the design of the building systems and components meet the OPR. It is completed during the design phase by the architect and engineers and covers system controls, design criteria, and operational specifics.
- Design Review: The design reviewer, who is sometimes the commissioning agent, coordinates the design review kickoff and reviews design documents to ensure they meet the owner’s project requirements and BOD. There are two brackets to the qualifications of the design reviewer defined by code. If a new construction project is 50,000 SF or larger, the designer review is required to be performed by third party. If less than 50,000 SF, the design reviewer can be from a firm designing the project, but the individual cannot be working on the project themselves.
- Commissioning Plan: A commissioning plan, which must be developed during the design phase, outlines the commissioning process, including the roles and responsibilities of the commissioning team, the scope of work, and the documentation requirements. This plan is developed by the Commissioning agent.
The OPR, BOD and Design Review can be word documents or can be completed within the fillable CRCC-CXR form. The commissioning plan is a separate document and can be incorporated into the contract documents.
Fewer Requirements for Projects Under 10,000 SF
For new, non-residential projects under 10,000 SF, only the CEC-NRCC-CXR form and Design Review are required. Note that for tenant improvement projects, the first build out in a commercial space is considered new construction, whether or not the shell was built separately. Subsequent tenant improvements in that same space are alterations and do not trigger commissioning.
Stay tuned for our next blog where we cover construction phase requirements.
For more information and in-person trainings, please check out our events calendar at 3c-ren.org/calendar-of-events-and-trainings
The on-demand webinar page is at 3c-ren.org/on-demand-trainings
And feel free to reach out to the Code Coach Hotline for more information or to have your Energy Code or CALGreen questions answered! 3c-ren.org/energy-code-coach
