Cx in California Code – Title 24 Cx Re-Cycle!
The March 5th public comment deadline came and went. Lyn Gomes, BCxA California Chapter Board member, was informed by the California Energy Commission (CEC) that the BCxA’s comments recommending modifications to Title 24 Building Energy Efficiency Standards for commissioning will not be included in the upcoming code cycle. Disappointing, yes; but this gives the BCxA a chance to provide even more input!
The current (2016) Title 24 Standards do not require the individual performing commissioning on a project to be certified. In fact right now, in the state with the nation’s strictest building performance-based energy codes, anyone can provide commissioning services, with no requirements for experience, qualifications, or contractual role.
According to the California Building Commissioning Guide, Section 12 of the Nonresidential Building Compliance Manual, describing activities intended to fulfill mandatory standards, “The designated commissioning coordinator may be an independent third-party commissioning professional, a project design team member (e.g. engineer or architect), an owner’s engineer, contractor or specialty sub-contractor.” In essence, the individual responsible for overall quality assurance in project delivery and systems performance can be anyone, even if it presents a conflict of interest.
During the comment period, both BCxA and the California Energy Alliance submitted comments asking that ANSI-accredited certified commissioning providers be required for the commissioning of buildings over 50,000 SF or with complex HVAC systems. The CEC Committee met on April 11 to adopt the 2019 Title 24, Part 6, Section 120.8 Standard without this stipulation. Read the commissioning language for 2019-2022 on page 40 of 43, here.
It’s never too early to engage!
The CEC has asked that the BCxA remain involved as the next (2022-2025) cycle of the rulemaking process proceeds. Title 24, Part 6, Section 120.8 is all about new construction commissioning. The process for making changes for the next code cycle gets underway this year in August, and Codes and Standards Enhancement (CASE) Report development begins in late 2018/early 2019. The BCxA is gathering momentum and evidence to advocate for commissioning at its best.
What you can do now to champion the market shift for Cx best practices in codes.
- Provide justification for Cx code changes. Send your actual examples/stories of substandard commissioning, or issues that have arisen from a conflict of interest.
- Submit forward-looking Cx code language from your city or state. Send sample code language (other than Washington State and Seattle codes) for consideration.
Please submit your thoughts, comments, and examples here or to info@bcxa.org.
A similar issue can be found with the IECC 2015 which states ‘…the registered design professional or approved agency shall provide evidence of mechanical system commission …’ without further guidance for qualifications or any conflict of interest.