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Commissioning is a Legal requirement in California

• Skrevet af Thomas T. Jarløv
Working sun panel before commissioning test

– Did you know, that building commissioning is a legal requirement in California? No? Then read on! 👷

  1. Commissioning - a legal requirement
  2. What does California’s Energy Code 2019 cite?
  3. What are the key requirements of the commissioning plan (CxP) for a project?
  4. What benefits would you enjoy if large and complex projects are commissioned?
  5. How can an already built building be commissioned?
  6. Why does California make the commissioning process a legal requirement?

Commissioning - a legal requirement

Commissioning is a systematic quality assurance procedure that spans the entire design and construction process. It includes verification and documentation of building systems as well as the components of the building to be planned, installed, designed, operated, maintained, and tested as the project owner intended.

According to California’s Energy Code 2019, commissioning is a legal requirement for all newly established buildings as well as the already existing building in California.

It is necessary for the attainment of the certificates from the state for a new construction project in California. California’s Energy Code Manual 2019 has provided guidelines, steps, roles, jurisdictional requirements, and documents necessary for the process of commissioning.

The sole goal of commissioning is to fulfill Owner Project Requirements (OPR), ensure the success of the project, and attain the intended performance of the project.

The commissioning is implemented according to the client’s or project owner’s requirements.

Cx OPR in construction project flow

What does California’s Energy Code 2019 cite?

According to the Energy Code 2019, the building commissioning requirements are different for less than 10,000 square ft. and over 10,000 square ft. non-residential buildings.

Energy Code requires commissioning design review only at the time of permit submission for buildings under 10,000 square ft. area.

On-site commissioning of building systems is not undertaken as stated in Section 120.8(d).

A licensed professional architect, engineer, or contractor is usually required for the commissioning procedure of buildings under 10,000 square ft. area.

Commissioning on buildings larger than 10,000 square ft.

The commissioning process for buildings over 10,000 square ft. area starts at the stage of predesign of the building and thus includes many different parties performing different roles and undertaking different responsibilities.

The commissioning process includes i.e. Owner (It could be a representative or facility operator), Designers, Design Reviewers, Contractors, Subcontractors, Plan Examiner, Acceptance Test Technician, Building inspector, and Commissioning Authority.

Each of these roles is undertaken by the most appropriate person depending upon the expertise and experience of the project team.

When to start the commissioning process on buildings larger than 10,000 square feet in California.

Building types

All the mentioned requirements in Energy Code 2019 section 120.8 apply to non-residential buildings except for healthcare facilities.

In the buildings such as hotels/motels that include residents’ dwelling areas i.e swimming pools, gyms, laundry rooms, and lobby, these areas’ requirements are not subjected to commissioning.

If the building owner includes these areas in mixed occupancy then commissioning would be applied to these areas.

What is the Commissioning process?

Commissioning commences at project inception and ends at occupancy of the building. It is continued in every phase and has particular functions in each phase either through facility or system operations.

Verification of each system is handled during each phase according to the owner’s intended functionality, facilitation, and efficiency.

  • In the first phase, pre-design, the Owner’s Project Requirement (OPR) is developed along with the commissioning plan, a design team is established and a system manual for operation and maintenance is commenced.
    These tasks cannot be left for later because important factors like cost, the catalyst for dialog, quality tracking tools, and risk management necessary for the project will be lost.
  • In the second phase, Design, project design, and its details are organized and developed further for construction documentation.
  • The third phase is Construction in which a transition of the project from planning to application occurs. Construction schedules are developed and the commissioning schedules are integrated into it.
    According to the commissioning schedules, the commissioning team submits its reviews after observing and testing the functionality and performance requirements of system operations.
    Functional Performance Tests are conducted by the contractor along with the commissioning team member as a witness. A report is drafted by the owner based on FTPs results. Local Jurisdictions are considered when there’s a necessity.
  • Occupancy is the last phase of the commissioning which is only completed after off-season testing. The design team makes sure that the operational responsibility of the facility of the project has been fulfilled. A final commissioning report is submitted to the owner after including all of the final issue logs.
Consturction workers working on a solar panel during commissioning test

What are the key requirements of the commissioning plan (CxP) for a project?

These are the key project commissioning activities:

  • Establish goals for the project, and a commissioning scope as well as set a commissioning budget.
  • Assign responsibilities to the team members.
  • Establish a proper plan and schedule for the commissioning process.
  • Establish field observation and testing plans.
  • Develop a system manual requirements and format.
  • Plan the ongoing commissioning of the building.
  • Develop specified commissioning plans.
  • Complete required documentation with the scope of commissioning.
  • Define testing needs.

What benefits would you enjoy if large and complex projects are commissioned?

Commissioned buildings are proved to have 8-20% reduced operating costs than non-commissioned buildings.

Commissioned buildings ensure multiple benefits i.e. improved thermal comfort, improved air quality, improved operative systems and their maintenance, proper environmental control and persistent energy savings, consistent system function, proper project documentation, and planning as well as management of the whole construction process of non-residential buildings.

Quality Assurance is the priority of the project manager to be ensured through an integrated and systematic process.

Cx saved around 8-20 percentage of the operational costs.

How can an already built building be commissioned?

The existing building is a quality-focused process that is used for the attainment of current facility requirements (CFR).

The focus of the process includes planning, implementing, verifying, investigating, and documenting the facility as well as the systems.

CFR assesses the maintenance of the operating systems.

Commissioning of an already existing building that has never been commissioned before is called retro-commissioning.

If an owner requests for another commissioning after being commissioned once, then it is re-commissioned. It is usually requested when there is some onset in operational problems or because of some systematic need.

In large and complex projects, commissioning can be targeted and particular, required for some manuals, operating systems, or assemblies.

Why does California make the commissioning process a legal requirement?

Proper documentation of the whole commissioning process is a historical record that preserves the answers to “why, what, and how to”.

The decisions, plans, and strategies are followed by the delivery team throughout the process. This recorded documentation provides evidence of the performance standards required for the building projects.

It includes the verification that whether the constructed and designed work has met those standards. In these documents two supporting documents, the certificate of acceptance and compliance are included as well.

Skrevet af Thomas T. Jarløv


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