2019 Vermont Commercial Building Energy Standards

John Penney, BCxA International Board member, brought to our attention the standards activities of Public Service Vermont this year. Vermont, a leader in energy efficiency, undertook a sweeping review of its Commercial Building Energy Standards (CBES) and has produced proposed standards, significantly based on IECC 2018, that are expected to be adopted in March 2019, effective in January 2020. Other states currently reviewing the 2018 IECC include Iowa, Illinois, Minnesota, Delaware, Washington, Nevada, and New Hampshire (ACEEE October 4 State Scorecard Report). A higher level of prescriptive codes and standards is proliferating in various places around the country. Although all sections of Vermont’s proposed standards affect commissioning practices, Section 407 focuses on very specific action requirements for commissioning, including the roles of “registered design professionals” and “approved agencies” in the process:

The Cx Plan “shall be developed by a registered design professional or approved agency and shall include the following items:

  1. A narrative description of the activities that will be accomplished during each phase of commissioning, including the personnel intended to accomplish each of the activities.
  2. A listing of the specific equipment, appliances or systems to be tested and a description of the tests to be performed.
  3. Functions to be tested including, but not limited to, calibrations and economizer controls.
  4. Conditions under which the test will be performed. Testing shall affirm winter and summer design conditions and full outside air conditions.
  5. Measurable criteria for performance.”

“Thresholds are reduced for New buildings ≥ 50,000 ft2 (the minimum building size was deleted from the proposed standards document):

  • Mechanical & service water heating systems > 480,000 Btu/h cooling capacity
  • Mechanical & service water heating systems heating/cooling combined > 600,000Btu/h”

C407.3.1 Functional testing of lighting controls. “Prior to passing final inspection, the registered design professional shall provide evidence that the lighting control systems have been tested to ensure that control hardware and software are calibrated, adjusted, programmed and in proper working condition in accordance with the construction documents and manufacturer’s instructions.”

C407.3.1.1. Sampling. “For projects with more than seven occupant sensors, testing shall be done for each unique combination of sensor type and space geometry. Where multiple of each unique combination of sensor type and space geometry are provided, not less than 10 percent and in no case fewer than one, of each combination shall be tested unless the code official or design professional requires a higher percentage to be tested.” Or, perhaps, this language should specify the Owner?

  1. John D. Villani

    Thanks for the information John Penny! and highlighting some on the code requirements and specifics to what and how each state can tweak the IECC code. I encourage all of you to actively try to engage with your local and state officials regarding code adoption related to our industry.

    In the battle of commoditization of the commissioning industry, and the impact codes are having on it, I draw everyone’s attention to one of the items John lists above: “Conditions under which the test will be performed. Testing shall affirm winter and summer design conditions and full outside air conditions.”

    I encourage people to document in their proposals and scope, references to the code requirements such as those mentioned above and that these systems need to be tested under a loss and restoration of normal power. Through the identification of specific details in the commissioning scope, I think we have an opportunity to educate and demonstrate the expertise required in our industry and benefits to the built environment.

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