CI-2009 EAp1: Fundamental Commissioning of Building Energy Systems Required

The LEED Rating system requirements for Enhanced Commissioning establish that “an independent commissioning authority (CxA) must lead, review, and oversee the completion of all commissioning process activities.” What specific responsibilities does this entail in a case where more than one CxA from separate companies are engaged to complete commissioning tasks?

The purpose of this CIR is to request an alternate compliance path for fundamental systems commissioning for the major renovation of a 10,000 sq. ft., Texas office building which is nearing the end of construction (the tenants have moved in on a temporary occupancy certificate). It has been the intent of the project team from design onset to submit the project for LEED Certification. Accordingly, substantial efforts and monies have been committed to strengthening the building envelope (from an EA standpoint), to replacing the HVAC systems with high-efficiency equipment, to installing measurement and verification equipment and for several other sustainable measures outside of the EA category. Unfortunately, due to the inexperience of some of the team members and a fast-track construction schedule, the commissioning process did not occur through the design and early construction as outlined in the reference guide. The team asks the USGBC to review the alternate commissioning strategy outlined below and to advise on whether this approach fully meets the requirements of EA Prerequisite 1: 1. Designate an individual as the CxA: The Owner has designated an employee of the MEP design firm as the CxA. The selected individual for this role is part of a specialized commissioning group within the firm and has not been involved with the design or construction of the project. He has served as the commissioning agent for several projects of similar scope and technical complexity. 2. CxA shall review Owner\'s Project Requirements and Basis of Design: The Design Team and Owner will prepare the Owner\'s Project Requirements to include Owner and User Requirements, Environmental and Sustainability Goals, Energy Efficiency Goals, Indoor Environmental Quality Requirements, Equipment and System Expectations, and Building Occupant and O & M Personnel Requirements. The Design Team will prepare a Basis of Design narrative which explains the design of the HVAC&R systems, the project lighting, the domestic hot water system, associated controls, and any additional systems requiring commissioning. The CxA will review and comment on these documents and the documents will be updated by the owner and design team respectively. 3. Develop and Incorporate commissioning requirements into the construction documents: The CxA will develop commissioning specifications which will be incorporated into the construction documents via supplemental instructions to the construction team and will become part of the construction documents. 4. Develop and Implement commissioning plan: The CxA will develop the commissioning plan which will include the Commissioning Program Overview, the Commissioning Team, and the Description of the Commissioning Process Activities. The commissioning plan will take into account that the equipment has already been installed and started up. 5. Verify Installation and performance of systems to be commissioned and complete a commissioning report: CxA will still follow all credit requirements, including pre-functional and functional testing procedures even though equipment has already been started. Deficiencies will be reported, and contractors will correct any deficiencies found during commissioning activities via supplemental instructions or under warranty. CxA will complete a summary report.

This Seattle, Washington project is a residential, fast-track high-rise and is currently in the early stages of construction. While the project team recognizes that the decision to pursue LEED Certification would have been more appropriately made at the commencement of design, the team is proud of the many green features of the project and has chosen to seek LEED Certification at this time. Because the fundamental building systems commissioning process will begin after construction has started, the project team is suggesting the following alternate compliance path for the prerequisite. The team asks the USGBC to review the commissioning strategy outlined below and to advise on whether this approach fully meets the requirements of EA Prerequisite 1: 1. Designate an individual as the CxA: The Owner has designated an employee of the HVAC, design-build sub-contractor as the CxA. The selected individual for this role has not been involved with the design or construction of the project. He has served as the commissioning agent for several projects of similar scope and technical complexity and is a certified Testing, Adjusting and Balancing Bureau (TABB) Supervisor. 2. CxA shall review Owner\'s Project Requirements and Basis of Design: The Design Team and Owner will prepare the Owner\'s Project Requirements to include Owner and User Requirements, Environmental and Sustainability Goals, Energy Efficiency Goals, Indoor Environmental Quality Requirements, Equipment and System Expectations, and Building Occupant and O & M Personnel Requirements. The Design Team will prepare a Basis of Design narrative which explains the design of the HVAC&R systems, the project lighting, the domestic hot water system, associated controls, and any additional systems requiring commissioning. The CxA will review and comment on these documents and the documents will be updated by the owner and design team respectively. 3. Develop and incorporate commissioning requirements into the construction documents: The construction drawings and specifications include the commissioning requirements of the Seattle Energy Code: a Commissioning Plan, Systems Testing and Balancing, Equipment Functional Performance Testing, Controls Functional Performance Testing, a Preliminary Commissioning Report, Post Construction Documentation, and a Final Commissioning Report. The CxA will review the commissioning requirements outlined in the construction documents and if he finds that enhancements or additions are required, these changes will be issued as supplemental instructions to the construction team and will become part of the construction documents. 4. Develop and implement commissioning plan: The CxA will review the commissioning plan outlined in the construction documents and will use this as the basis for his project commissioning plan which will include the Commissioning Program Overview, the Commissioning Team, and the Description of the Commissioning Process Activities. 5. Verify installation and performance of systems to be commissioned and complete a commissioning report: Because the systems have not been installed, the CxA will follow the credit requirements outlined in the LEED-NC v2.2 reference guide for these two steps in the commissioning process.

Our client is a non-profit trade association which has leased space in a commercial office building in Washington, DC for 35 years. As part of an additional 10-year lease renewal and expansion, their interior space has been undergoing renovation. Upgrades to 124,000 of the 141, 000 square feet that the tenant occupies were completed in 2006 using a green approach. 10,000 square feet is currently being constructed, and 7,000 square feet is currently in design. The tenant occupies approximately 55% of the building in which they are located. Since the renovation began, the association has come to recognize LEED as an important performance benchmark of green building quality. The association is pursuing certification for its space in order to demonstrate the value of LEED CI certification to its employees and to educate its approximately 8000 corporate member organizations nationwide about LEED. The association\'s hope is to certify all 141,000 square feet of the space that they occupy. The association could limit the LEED CI site boundary to the 10,000 square feet that is currently under construction and the 7,000 square feet in which construction has not yet begun, and meet all LEED CI prerequisites and sufficient credit points to certify that portion of their space at a Silver or Gold level. They are interested, however, to undergo the additional effort and expense associated with including the 124,000 square feet of space that was renovated in earlier phase of renovation. We have confirmed that sufficient credit points could be documented for the whole space to be eligible for certification, however, the issue of how the EAp1 Fundamental Building Systems Commissioning prerequisite would need to be addressed. Alternatively we considered working with the association to pursue LEED OM for their entire space, however, LEED OM presents its own set of challenging issues given its current whole building approach and the fact that the association does not have direct control over the base building components or the activities of other building tenants. In order to include the previous phase of interior renovation in the LEED CI site boundary, we propose adapting LEED OM EAc1 requirements for commissioning the energy related systems in the tenant\'s scope whereby we would: 1. Develop a retro-commissioning, recommissioning or ongoing commissioning plan for the tenant\'s scope energy related systems, including the heating, ventilating, air conditioning and refrigeration (HVAC&R) systems and associated controls, lighting controls, including daylighting, domestic hot water systems, and renewable energy systems. 2. Conduct the investigation and analysis phase. Document the breakdown of energy use in the tenant space. 3. List the operating problems that affect occupants\' comfort and energy use, and develop potential operational changes that will solve them. 4. List the identified capital improvements that will provide cost-effective energy savings and document the cost-benefit analysis associated with each. Please let us know if this would be an acceptable alternate approach to meeting the LEED CI EAp1 Fundamental Commissioning prerequisite for the phases of the renovation already completed. The current and future phases of the project would follow the standard LEED CI EAp1 requirements.

This CIR is seeking clarification on the scope of Systems Performance Testing required for Commissioning. The project is a 300,000 square foot residential building located in New York City. As part of commissioning, the project intends to commission the HVAC and refrigeration systems, lighting and daylighting controls and domestic hot water systems as per the credit requirements of EA prerequisite 1 and EA credit 3. All major equipment in the building will be commissioned such as boilers, hot water pumps, roof top units (DX), supply and exhaust fans. However, for cooling, the residences use Packaged Terminal Air Conditioners (PTAC). The Project is seeking guidance on the representative sampling of PTAC for the systems performance testing. The project is intending to test 10% (industry standard) of the PTACs in the building for each size (7500 Btu, 9000 Btu, 12000 Btu etc.) subject to a minimum count of 10. For example, if there are 27 units of Type A, and 120 units of Type B and 400 units of Type C, the functional testing will be done for: 10 qty - Type A 12 qty - Type B 40 qty - Type C If failures are found in a group, in addition to the faulty units, an additional sample is tested. Is this approach of a 1 in 10 representative sampling acceptable to USGBC?