Public Comment 4:
Dave Hewitt, representing New Buildings Institute, Jessyca Henderson, representing American
Institute of Architects, Ron Majette, representing U.S. Department of Energy requests Approved
as Modified this Public Comment.
Modify the proposal as follows:
1. Delete Section 503.2.9.1.
503.2.9.1 System commissioning. The construction documents shall require commissioning and completion requirements in
accordance with this section. The construction documents shall be permitted to refer to equipment specifications for further
requirements. Copies of all documentation shall be given to the owner by the registered design professional. The building official
may request commissioning documentation for review purposes. At the time of plan submittal, the code official shall be provided, by
the permitee, a letter of intent to commission the building in accordance with this code.
503.2.9.1.1 Commissioning plan. A commissioning plan shall be prepared and shall include as a minimum the following items:
1.
2.
3.
4.
5.
6.
A detailed explanation of the building’s project requirements for mechanical design,
A narrative describing the activities that will be accomplished during each phase of commissioning, including guidance on
who accomplishes the activities and how they are completed,
Equipment and systems to be tested, including the extent of tests,
Functions to be tested (for example calibration, economizer control, etc.),
Conditions under which the test shall be performed (for example winter and summer design conditions, full outside air,
etc.), and
Measurable criteria for acceptable performance.
503.2.9.1.2 Systems adjusting and balancing. All HVAC systems shall be balanced in accordance with generally accepted
engineering standards. Air and water flow rates shall be measured and adjusted to deliver final flow rates within 10% of design
rates. Test and balance activities shall include as a minimum the following items:
1.
Air systems balancing: Each supply air outlet and zone terminal device shall be equipped with means for air balancing
in accordance with the requirements of Chapter 6 of the International Mechanical Code. Discharge dampers are
prohibited on constant volume fans and variable volume fans with motors 10 hp (18.6 kW) and larger. Air systems shall be
balanced in a manner to first minimize throttling losses then, for fans with system power of greater than 1 hp, Fan speed
shall be adjusted to meet design flow conditions.
Exception: Fans with fan motors of 1 hp or less.
2. Hydronic systems balancing: Individual hydronic heating and cooling coils shall be equipped with means for
balancing and pressure test connections. Hydronic systems shall be proportionately balanced in a manner to first
minimize throttling losses, then the pump impeller shall be trimmed or pump speed shall be adjusted to meet design flow
conditions. Each hydronic system shall have either the ability to measure pressure across the pump, or test ports at each
side of each pump.
Exceptions:
1. Pumps with pump motors of 5 hp or less.
2. When throttling results in no greater than 5% of the nameplate horsepower draw above that required if the impeller
were trimmed.
503.2.9.1.3 Functional performance testing
503.2.9.1.3.1 Equipment functional performance testing. Equipment functional performance testing shall demonstrate the correct
installation and operation of components, systems, and system-to-system interfacing relationships in accordance with approved
plans and specifications. This demonstration is to prove the operation, function, and maintenance serviceability for each of the
commissioned systems. Testing shall include all modes of operation, including:
1.
2.
3.
4.
All modes as described in the Sequence of Operation,
Redundant or automatic back-up mode,
Performance of alarms, and
Mode of operation upon a loss of power and restored power.
Exception: Unitary or packaged HVAC equipment listed in Tables 503.2.3 (1) through (3) that do not require supply air
economizers.
503.2.9.1.3.2 Controls functional performance testing. HVAC control systems shall be tested to document that control devices,
components, equipment, and systems are calibrated, adjusted and operate in accordance with approved plans and specifications.
Sequences of operation shall be functionally tested to document they operate in accordance with approved plans and specifications.
503.2.9.1.4 Preliminary commissioning report. A preliminary report of commissioning test procedures and results shall be
completed and provided to the building owner . The report shall be identified as “Preliminary Commissioning Report” and shall
identify:
1.
2.
3.
Itemization of deficiencies found during testing required by this section which have not been corrected at the time of report
preparation and the anticipated date of correction.
Deferred tests which cannot be performed at the time of report preparation due to climatic conditions.
Climatic conditions required for performance of the deferred tests, and the anticipated date of each deferred test.
503.2.9.2 Acceptance. Buildings, or portions thereof, required to comply with this section shall not be issued a final certificate of
occupancy until such time that the code official has received a letter of transmittal from the building owner that states they have
received the Preliminary Commissioning Report as required by Section 503.2.9.1.4. At the request of the code official, a copy of the
Preliminary Commissioning Report shall be made available for review.
503.2.9.3 Completion requirements. The construction documents shall require that within 90 days of system acceptance by the
code official, the documents described in Section 503.2.9 .3.1 and 503.2.9.3.2 shall be provided to the building owner or their
designated representative by the mechanical contractor.
503.2.9.3.1 Drawings. Construction documents shall include as a minimum the location and performance data on each piece of
equipment.
503.2.9.3.2 Manuals. An operating manual and a maintenance manual shall be in accordance with industry-accepted standards and
shall include, at a minimum, the following:
1. Capacity (input and output) and required maintenance actions for each piece of equipment.
2. Operation and maintenance manuals for each piece of equipment.
3. Manufacturer’s operation manuals and maintenance manuals for each piece of equipment requiring maintenance, except
equipment not furnished as part of the project. Required routine maintenance actions shall be clearly identified.
4. Names and addresses of at least one service agency.
5. HVAC controls system maintenance and calibration information, including wiring diagrams, schematics, and control
sequence descriptions. Desired or field-determined setpoints shall be permanently recorded on control drawings at control
devices or, for digital control systems, in programming comments.
6. A complete narrative of how each system is intended to operate, including suggested recommended setpoints.
503.2.9.3.3 System balancing report. A written report describing the activities and measurements completed in accordance with
Section 503.2.9.1.2
503.2.9.3.4 Final Commissioning Report. A complete report of test procedures and results identified as “Final Commissioning
Report” shall include:
1.
2.
3.
Results of all Functional Performance Tests.
Disposition of all deficiencies found during testing, including details of corrective measures used or proposed.
All Functional Performance Test procedures used during the commissioning process including measurable criteria for test
acceptance, provided herein for repeatability.
Exception: Deferred tests which cannot be performed at the time of report preparation due to climatic conditions.
2. Add New Section 508 as follows:
Section 508
SYSTEM COMMISSIONING
508.1 General. This section covers the commissioning of the building mechanical systems in Section 503 and electrical power and
lighting systems in Section 505.
508.2 Mechanical systems commissioning and completion requirements. Prior to passing the final mechanical inspection, the
registered design professional shall provide evidence of mechanical systems commissioning and completion in accordance the
provisions of this Section.
Construction document notes shall clearly indicate provisions for commissioning and completion requirements in accordance with
this section and are permitted to refer to specifications for further requirements. Copies of all documentation shall be given to the
owner and made available to the code official upon request in accordance with Sections 508.2.4 and 508.2.5
Exceptions: The following systems are exempt from the commissioning requirements:
1.
Mechanical systems in buildings where the total mechanical equipment capacity is less than 480,000 Btu/h cooling
capacity and 600,000 Btu/h heating capacity.
2.
Systems included in Section 503.3 that serve dwelling units and sleeping units in hotels, motels, boarding houses or
similar units
508.2.1 Commissioning plan. A commissioning 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.
A listing of the specific equipment, appliances or systems to be tested and a description of the tests to be performed.
Functions to be tested including, but not limited to calibrations and economizer controls.
Conditions under which the test will be performed At a minimum, testing must affirm winter and summer design
conditions and full outside air conditions.
Measurable criteria for performance.
2.
3
4.
5.
508.2.2 Systems adjusting and balancing. HVAC systems shall be balanced in accordance with generally accepted engineering
standards. Air and water flow rates shall be measured and adjusted to deliver final flow rates within the tolerances provided in the
product specifications. Test and balance activities shall include the following:
508.2.2.1. Air systems balancing: Each supply air outlet and zone terminal device shall be equipped with means for air
balancing in accordance with the requirements of Chapter 6 of the International Mechanical Code. Discharge dampers are
prohibited on constant volume fans and variable volume fans with motors 10 hp (18.6 kW) and larger. Air systems shall be
balanced in a manner to first minimize throttling losses then, for fans with system power of greater than 1 hp, fan speed shall
be adjusted to meet design flow conditions.
Exception: Fans with fan motors of 1 hp or less.
508.2.2.2 Hydronic systems balancing: Individual hydronic heating and cooling coils shall be equipped with means for
balancing and measuring flow. Hydronic systems shall be proportionately balanced in a manner to first minimize throttling
losses, then the pump impeller shall be trimmed or pump speed shall be adjusted to meet design flow conditions. Each
hydronic system shall have either the capability to measure pressure across the pump, or test ports at each side of each pump.
Exceptions:
1. Pumps with pump motors of 5 hp or less.
2.
When throttling results in no greater than five percent of the nameplate horsepower draw above that required if the
impeller were trimmed.
508.2.3 Functional performance testing. Functional performance testing specified in Sections 508.2.3.1 through 508.2.3.3 shall
be conducted.
508.2.3.1 Equipment. Equipment functional performance testing shall demonstrate the installation and operation of components,
systems, and system-to-system interfacing relationships in accordance with approved plans and specifications such that operation,
function, and maintenance serviceability for each of the commissioned systems is confirmed. Testing shall include all modes and
sequence of operation, including under full-load, part-load and the following emergency conditions:
1.
2.
3.
4.
All modes as described in the sequence of operation,
Redundant or automatic back-up mode,
Performance of alarms, and
Mode of operation upon a loss of power and restoration of power.
Exception: Unitary or packaged HVAC equipment listed in Tables 503.2.3 (1) through (3) that do not require supply air
economizers.
508.2.3.2 Controls. HVAC control systems shall be tested to document that control devices, components, equipment, and systems
are calibrated, adjusted and operate in accordance with approved plans and specifications. Sequences of operation shall be
functionally tested to document they operate in accordance with approved plans and specifications.
508.2.3.3 Economizers. Air economizers shall undergo a functional test to determine that they operate in accordance with
manufacturer’s specifications.
503.2.9.1.4 508.2.4 Preliminary commissioning report. A preliminary report of commissioning test procedures and results shall be
completed and certified by the registered design professional or approved agency and provided to the building owner . The report
shall be identified as “Preliminary Commissioning Report” and shall identify:
1
2.
3.
Itemization of deficiencies found during testing required by this section that have not been corrected at the time of report
preparation,
Deferred tests that cannot be performed at the time of report preparation because of climatic conditions.
Climatic conditions required for performance of the deferred tests.
508.2.4.1 Acceptance of Report. Buildings, or portions thereof, shall not pass the final mechanical inspection until such time as
the code official has received a letter of transmittal from the building owner acknowledging that the building owner has received the
Preliminary Commissioning Report.
508.2.4.2 Copy of Report. The code official shall be permitted to require that a copy of the Preliminary Commissioning Report be
made available for review by the code official
508.2.5 Documentation requirements. The construction documents shall specify that the documents described in this Section be
provided to the building owner within 90 days of the date of receipt of the certificate of occupancy.
508.2.5.1 Drawings. Construction documents shall include the location and performance data on each piece of equipment.
508.2.5.2 Manuals. An operating and maintenance manual shall be provided and include all of the following:
1.
2.
3.
4
5.
Submittal data stating equipment size and selected options for each piece of equipment requiring maintenance.
Manufacturer’s operation manuals and maintenance manuals for each piece of equipment requiring maintenance, except
equipment not furnished as part of the project. Required routine maintenance actions shall be clearly identified.
Name and address of at least one service agency.
HVAC controls system maintenance and calibration information, including wiring diagrams, schematics, and control
sequence descriptions. Desired or field-determined setpoints shall be permanently recorded on control drawings at control
devices or, for digital control systems, in system programming instructions.
A narrative of how each system is intended to operate, including recommended setpoints.
508.2.5.3 System balancing report. A written report describing the activities and measurements completed in accordance with
Section 508.2.2.
508.2.5.4 Final Commissioning Report. A report of test procedures and results identified as “Final Commissioning Report” shall be
delivered to the building owner and shall include:
1.
2.
3.
Results of Functional Performance Tests.
Disposition of deficiencies found during testing, including details of corrective measures used or proposed.
Functional Performance Test procedures used during the commissioning process including measurable criteria for test
acceptance, provided herein for repeatability.
Exception: Deferred tests which cannot be performed at the time of report preparation due to climatic conditions.
(Portions of the proposal not shown remain unchanged.)
Commenter=s Reason: Public Comment 4 of 6 on EC 147 EC 147 was developed by a collaborative effort between New
Buildings Institute, the American Institute of Architects and the U.S. Department of Energy. The proposal was developed in
response to many national goals of increasing the energy efficiency of new commercial construction by 30% and is designed to
modify the Chapter 5 requirements of the building envelope, mechanical and lighting systems to meet this goal. During the passage
of EC 147 at the ICC IECC Code Development Hearings in Baltimore, the proponents pledged to work with all interested and
affected parties and solicit their comments and input in order to improve on the code change proposal passed by the IECC
Committee. Numerous comments were received from parties representing industry and product groups, enforcement agencies and
the building and design industry. The comments helped to provide a consensus agreement on several issues raised during
testimony, clarified language, increased readability, and strengthened the proposal. The public comments submitted herein by NBI,
AIA and DOE are the result of this process. A series of six public comments have been submitted on EC 147 that each focus the
discussion on a particular portion of the original code change proposal. The proponents feel that this is necessary to ensure that the
voting members of ICC will have the opportunity to hear testimony on each section before voting on the proposal as a whole.
Additional information on EC 147 is available at http://newbuildings.org/iecc.htm.
These commissioning public comments are based on recommendations received from industry and from further study by
NBI/AIA and DOE into effective commissioning language included in the Washington State Nonresidential Energy Code and in the
ICC’s IgCC-PV1. These are identical to proposed changes to EC147 that were reviewed by the ASHRAE Standard 90.1
Mechanical Committee in addition to BOMA. Several changes are recommended in this public comment that will result in a clearer
understanding of the steps necessary for commissioning HVAC systems, who will oversee the process, the code official’s limited
responsibilities and when commissioning must occur. The following changes were made to language in EC 147.
Creation of Section 508. A new section in the IECC, Section 508, is proposed that will contain requirements that are more
process oriented versus those that apply to specific energy features in the building. Section 508 will also contain functional testing
language for lighting controls and will provide a place in the IECC for future process oriented requirements.
Minimum Equipment Size Threshold. Based on the new Washington State Energy Code, a minimum total mechanical
equipment capacity threshold was added that will focus the commissioning requirements on larger mechanical systems and on
buildings with multiple systems that result in a higher output capacity. This threshold will remove the requirement from smaller
commercial buildings e.g. tenant buildouts in strip shopping centers or small medical or dental offices. An exception was also
placed in the requirements that will exempt systems installed in hotel/motel and high-rise residential that meet the simple building
definition in Section 503.3. This will, for example, exempt packaged terminal heat pump (PTHP) systems commonly used in
hotel/motel sleeping rooms that are intermittently occupied and where there may be additional costs of commissioning multiple
small systems.
Clarified Process and Reduced the Code Official Involvement in Commissioning Process. The commissioning language
was restructured to provide clear direction on what is required, who is responsible and what documentation needs to be provided to
the code official. In addition, the code official’s identified responsibilities in the commissioning process all occur prior to the issuance
of the Certificate of Occupancy (see Section 508.2.5) The code official will receive an acknowledgement of the Preliminary
Commissioning Report and can review the Preliminary Report if desired. Before issuance of the Certificate of Occupancy, a code
official only needs to verify that the approved plans include a statement that the required construction documents and final
commissioning report will be delivered to the builder owner.