e-News #96: Commissioning for Code Compliance

January 12, 2015
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Commissioning is an integral component of energy efficient building design, construction, and operation. The goal of commissioning is to ensure that the design and construction of building systems meets the owner’s needs, and that building equipment is functioning optimally during occupancy.

The California Commissioning Collaborative defines commissioning as, “The process of ensuring that systems are designed, installed, functionally tested and capable of being operated and maintained according to the owner’s operational needs.”
– California Commissioning Collaborative

The commissioning process was moved from CALGreen to the building energy code and now is required in part, or in whole, on all nonresidential newly constructed projects in California.

In California, commissioning was incorporated into the 2008 CALGreen building standards (Title 24, Part 11) to improve building operations and create a positive impact by reducing energy consumption. Recently, much of the commissioning process was moved to the building energy code (Title 24, Part 6) and now is required in part or in whole on all newly constructed nonresidential projects in California. The commissioning requirements, both in CALGreen and Title 24, Part 6, specifically exclude additions or alterations to existing nonresidential buildings.

Important Commissioning Documents

The commissioning process involves many components and deliverables implemented throughout the lifecycle of the project’s design, construction, and building turnover. Many of these key documents are required to meet the new Title 24, Part 6 commissioning requirements and to pull building permits.

The following Table summarizes which Part 6 commissioning requirements are required for nonresidential newly constructed buildings.

Table 1

All Code sections can be found here using the Reference Ace tool.

Table 1.  Commissioning Requirements in Part 6

Owner’s Project Requirements (OPR)

The purpose of the OPR is to define and document the owner’s energy-related expectations and requirements for the system designers prior to the beginning of design. The OPR should be developed early in the design process by the owner and/or the owner’s representative. It is typically semi-technical, and a building owner may need assistance developing the document if they do not have a basic level of building operations knowledge. The design reviewer, commissioning authority (CxA), or building operations manager often are called upon to provide this assistance. The contents of the OPR document are prescribed in Section 120.8 of the Standards and further outlined in the California Energy Commission’s Building Commissioning Guide.

  • Energy efficiency goals
  • Ventilation requirements
  • Project program, including facility functions and hours of operation, and need for after-hours operation; and
  • Equipment and system expectations

Basis of Design (BOD)

The BOD is essentially the system designer’s documented response to the requirements laid out in the OPR. The document serves to outline the approach for meeting the expectations communicated in the OPR and allows the designer and owner to work through design issues at an early stage. Typically, this document is developed within a month of the OPR’s issuance. In order to comply with Title 24, Part 6 requirements, the BOD must include the following systems if applicable (at a minimum):

  • HVAC systems and controls
  • Indoor lighting systems and controls
  • Water heating systems and controls

Design Review Kickoff Compliance Form (NRCC-CXR-01-E)

NOTE: This compliance form is required for all newly constructed nonresidential buildings.

All newly constructed nonresidential projects are required to complete the NRCC-CXR-01-E form at a design review kickoff meeting during the schematic design phase. Prior to the meeting, the OPR & BOD (if required), and blank Design Phase Review Checklists should be provided for

Design Phase Review Checklist Forms (NRCC-CXR-02-E, NRCC-CXR-03-E & NRCC-CXR-04-E)

NOTE: These compliance forms are potentially required for all newly constructed nonresidential buildings.

Completion of the basic design phase review checklist (form NRCC-CXR-02-E) is required for all newly constructed nonresidential buildings in California to pull a building permit. At least one additional checklist is required for “simple” mechanical systems (NRCC-CXR-03-E) or “complex” mechanical systems (NRCC-CXR-04-E). Table 2 describes how “simple” or “complex” systems are determined. The Standards require that a design reviewer, review the construction documents for Title 24, Part 6 compliance for all items on the applicable checklists. The design reviewer is required to complete the review prior to finalization of the design.

TIP: Although the CEC’s Building Commissioning Guide recommends this review occur at around 90 percent construction documents (CDs), generally this will be too late to make adjustments without impacting the project schedule or requiring redesign. Project teams should consider having the design reviewer perform a preliminary review much earlier (closer to 50 percent CDs), so there is still time to make adjustments if necessary. In this case, a final review would need to be conducted to complete the appropriate NRCC-CXR checklist form.


Table 2

Table 2. "Simple” and “complex” mechanical systems.

Design Review Signature Page Form (NRCC-CXR-05-E)

NOTE: This compliance form is required for all newly constructed nonresidential buildings.

Completion of the design review signature page form is required for all newly constructed nonresidential buildings in California to be able to pull a building permit. This form simply documents that a design review kickoff occurred, and that the design phase review checklists were completed. The Standards dictate who can complete these forms as the design reviewer. The appropriate party is determined by the building size, as shown in Table 3.

Table 3

Table 3. Who can act as the “design reviewer”.

*Commissioning requirements only apply to nonresidential newly constructed buildings.

Commissioning Specifications

Section 120.8(e) of the Standards requires that the commissioning measures (requirements) be included in the issued construction documents. For buildings less than 10,000 sf, the construction documents should include all necessary documentation for the design reviewer to perform the design review. This does not include “in-the field” testing requirements, as Section 120.8 does not require “in-the-field” testing for buildings < 10,000 sf. This does not exclude projects from acceptance testing requirements that are specified in other sections of Part 6.

For projects > 10,000 sf, this is typically done in the form of a Division 1 specification section provided by the CxA on behalf of the owner. The purpose of the Commissioning Specification is to inform bidding contractors of the commissioning requirements so they can include the effort to coordinate with a CxA within their bid, and be contractually obligated to participate. The specifications lay out the basic process for commissioning, which systems will be commissioned and roles and responsibilities of those involved. If commissioning specifications aren’t included in the bid set of drawings, the CxA will not have the necessary participation in the field to properly commission the systems.

According to the Standards, the following items should be included in the Commissioning Specification Section. Many example specification sections can be found using an internet search engine.

  • List of systems and assemblies commissioned
  • Testing scope
  • Roles and responsibilities of contractors
  • Requirements for meetings
  • Management of issues
  • The commissioning schedule
  • Operations and maintenance manual development
  • Training, and checklist and test form development
  • Execution and documentation

Commissioning Plan

The commissioning plan is vital to the commissioning process as it communicates to the owner, design, and construction teams what to expect from the CxA, what will be tested, and what role members of the teams must play. The commissioning plan typically is more detailed and project specific than the commissioning specifications, because the specifications often are written prior to the subcontractors being selected. The commissioning plan should include more detail on roles and responsibilities once the construction team (including subcontractors) has been identified. This may be challenging based on the requirement in Section 120.8(f) that the plan be written before permit application. If relevant subcontractors have not been selected at the time the commissioning plan is being drafted, the roles and responsibilities section may need to be updated once this information becomes available.

TIP 1: Although not required by Title 24, Part 6, the commissioning plan is usually reviewed with the owner, architect, design engineers, general contractor, and relevant subcontractors during a commissioning kickoff meeting led by the CxA. This meeting typically occurs during early construction and serves to establish expectations, deliverables, and timelines with all the parties that will be involved in construction phase commissioning activities.

TIP 2: Whether the commissioning plan is required as part of the plan check submittal package is at the discretion of the local building department. If you are unsure whether the building department having jurisdiction requires a copy of the commissioning plan, be sure to contact them prior to submitting for plan review.

The commissioning plan must contain the following to comply with Section 120.8(f) of the Standards:

  • General project information
  • Commissioning goals
  • Systems to be commissioned
  • Plans to test systems and components, which include:
    • An explanation of the original design intent
    • Equipment and systems to be tested, including the extent of tests
    • Functions to be tested
    • Conditions under which the test is performed
    • Measurable criteria for acceptable performance
    • Commissioning team staff and experience
    • Commissioning process activities, schedules, and responsibilities
    • Plans for the completion of commissioning requirements listed in Sections 120.8(g) through 120.8(i) shall be included

Functional Performance Tests (FPT)

Functional performance testing is used to demonstrate that the relevant equipment has been installed and is operating as designed. Where applicable, the functional performance tests and checklists are developed in accordance with the acceptance testing requirements as specified I n the Standards (for more information on acceptance testing, see sidebar). Compliance with the FPT requirement is fulfilled by developing and implementing test procedures for each piece of equipment and controls within the commissioning scope.

TIP: The commissioning scope may include equipment in addition to the equipment requiring acceptance testing by the Standards. The commissioning scope is determined during the design phase based on the OPR and BOD, and the equipment list should be included in the commissioning specification section and commissioning plan.

FPT requires coordination between the CxA and relevant subcontractors such as the mechanical, electrical, testing and balance (TAB), and controls contractors. The subcontractors must participate in the functional performance testing, as the CxA typically observes the tests while the subcontractors actually do the testing. Proper scheduling of the FPT are critical, as the equipment must be installed and operable, including controls being functional and TAB being completed.

TIP: Although not required by the Standards, commissioning authorities typically use “prefunctional checklists” to ensure the equipment is ready to be tested before coming onsite to observe FPT. These checklists are completed by subcontractors and often include verification of items, such as completed control point-to-point checklists and that the equipment will be accessible for testing.

Systems Manual and Operations & Maintenance (O&M) Training

Acceptance testing is required by the energy code to ensure that equipment, controls, and systems operate as required by the standards. Similar to commissioning, the acceptance testing process includes visual inspection of equipment and the functional testing of equipment per the prescribed testing procedures found in the standards. The systems covered by the acceptance testing requirement are detailed in Sections 120.5, 120.6, 130.4 and 140.9. While the acceptance testing requirements may overlap, the Commissioning requirements may go beyond the acceptance test requirements.

Per Section 120.8(h) of the 2013 Standards, the CxA is responsible for providing a systems manual and associated training to the owner’s building operation staff. This requirement is critical to realize the savings resulting from the energy-related capital investments in the building design and construction. If the building operation staff do not understand how to properly operate and maintain the building systems, energy savings will diminish drastically, and the owner will not see the expected return on investment (ROI).

The systems manual is typically a compilation of materials written by the CxA, design engineers, owner, contractors, and subcontractors. This manual is the basis for training the O&M staff and multiple copies, along with ‘as-built’ plans, are often left with staff for reference.

The Standards require the systems manual includes (at a minimum):

  • Site information, including facility description, history, and current requirements.
  • Site contact information
  • Instructions for basic operations & maintenance, including general site operating procedures, basic  troubleshooting, recommended maintenance requirements, and a site events log
  • Descriptions of major systems
  • Site equipment inventory and maintenance notes
  • A copy of all special inspection verifications required by the enforcing agency or the Standards

Commissioning Report

The Cx report is a culmination of all work done throughout the commissioning effort. The report documents the commissioning activities and reports recommendations to the owner for post-construction completion. Section 120.8(i) in the Standards outlines the minimum required content for the commissioning report.

TIP: Although not required by the Standards, commissioning often includes seasonal testing to verify systems are operating as designed during different seasons. This may only be relevant to select climate zones in California. If your commissioning scope includes seasonal testing, or end of warranty review, the commissioning report will not be completed until up to a year after building occupancy.

Overview of the Commissioning Process for 2013 Title 24, Part 6

As indicated above, the commissioning process starts in pre-design and continues into the occupancy phase. The following graphic outlines the basic process and where the documents described above fit into each phase.

Bolded items apply to all nonresidential newly constructed projects.

Table 4Table 4. The Commissioning Process


The building commissioning requirements for nonresidential projects in California have changed as of July 1, 2014, and require changes to the typical design and construction processes to which industry professionals are accustomed. These requirements are meant to ensure that permitted buildings are safe, deliver savings from good design decisions and energy reducing capital investments, and are operated by well-informed staff.

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