Following are some comments I would like to make to USGBC related to Fundamental Commissioning (and by reference to Enhanced):
1. The definitions seem very vague related to systems, by mentioning just Mechanical and Electrical. What about emergency generation? Electrical distribution? Many of these are important to Cx, but many clients already balk at the Cx fees required, and this would dramatically expand that scope. Perhaps this will be expanded in the reference guide, but it needs to be fairly specific. There are a lot of Cx providers out there that are using very minimal scopes to get projects from those that try to provide good service.
2. The systems manual seems to have been moved from Enhanced to Fundamental. Again, this is an increase in scope of Fundamental that does not feel appropriate.
3. The language related to envelope has been simplified, but could cause confusion. This is a new service for most projects, and the scope needs better definition. Fundamental Cx does not fully implement ASHRAE Guideline 0 or 1, but requires a subset of those tasks.
4. The path for “late” projects appears to have been closed in this draft…requiring early design. Of course this is the optimum and the best practice. However, since this is a prerequisite, it would preclude any project from entering the LEED process if decided after SD or DD. That does not seem appropriate for the prerequisite. Being more structured for Enhanced may be more affective…ie allowing a project to proceed, but not allowing additional credits.
5. It appears that peer review has been added to Fundamental at DD and CD. This should not be part of Fundamental, and should remain in Enhanced. I support more reviews, but as part of the Enhanced process.
6. There is mention of construction checklists being required in the CD phase. We typically do not include them, because the lists should be created for the equipment actually purchased, and that is only known after award and submittals are issued. Even in Fundamental, we still gather submittals, because they are required for the Pre-Functional Checklists and to write the Functional Performance Tests.
I do not wish to sound unsupportive of changes and enhancements to the Cx portions of LEED, but the addition of envelope while laudable and needed, it will be a sea change for many projects and perhaps should be either its own credit or part of enhanced (perhaps credits staged for inclusion) for 2012, then move portions to Fundamental in the next version.
Scott…
Erik Dyrr
Director, Sustainable Buildings and OperationsKEMA
80 thumbs up
September 12, 2011 - 1:27 pm
Thank you Scott. I completely agree with all of your comments above. In particular, the addition of envelope Cx in the prereq. is too big a leap. Agreed that it is a move in the right direction but it is costly and there are few providers of the service in the market now. Moving the envelope Cx to the enhanced credit, or a credit of it's own, would be a better option. As pointed out by many response sent to USGBC on the 1st draft, envelope Cx will be very costly. Small projects are already losing on the cost/benefit of Cx. This added cost will likely turn owner's away from LEED.
I fully support raising the bar for LEED certification. However, it should not be a cost issue. Make credits tougher, not prerequisites more costly.
Also the new language in the draft refers to commissioning systems for "durability". This is part of the typical Cx process, but this term will need to be defined to avoid confusion.
Lastly, many comments have been posted about LEED no longer updated by "consensus". Although USGBC is putting the drafts out for comment, it doesn't appear they are acting on the majority opinion. Of the comments submitted on the 1st draft regarding envelop Cx 14 of 20 suggested it not be part of the prereq.
Alex Zimmerman
PresidentApplied Green Consulting Ltd.
2 thumbs up
September 13, 2011 - 2:33 pm
Fundamental Commissioning Scope
Envelope:
Commissioning activities for envelope (a passive system) are significantly different in kind than for active energy-affecting systems. Inclusion of building envelope systems and assemblies in systems commissioned adds greatly to complexity and cost of implementation of prerequisite, for only marginal environmental benefit. In my experience with projects that have done commissioning with the scope of the proposed prerequisite, the cost of commissioning would be about double that of the scope as it currently stands in LEED 2009. Owners already balk at the cost of commissioning. This proposed scope will provide too much fuel to critics who charge that LEED certification is too onerous and costly. It may even be a deal-killer for many owners who are considering LEED certification.
In addition, most current commissioning authorities have little direct expertise with building envelope. This will require commissioning authorities to be multi-disciplinary firms or partnerships. This will also create additional liability for the CxA and will potentially eliminate or restrict current commissioning authorities, who do not have this multi-disciplinary expertise, from performing this work on LEED 2012. This shift in expertise and additional liability will cause many current CxA’s (including me) to get out of the business. This will have the opposite effect on the industry to that intended by USGBC, that is it will reduce the pool of competent people available and reduce the amount of commissioning performed.
Electrical:
This is much too broad if this is intended to include transformers, switch gear, wiring distribution and terminals, data closets and wiring and other non energy-affecting electrical equipment. This addition to scope would add greatly to cost, time and complexity for marginal environmental benefit. It would also add significant liability to the Cx scope and, like envelope, may cause many current CxA’s (including me) to get out of the business.
Recommendations to the USGBC
Delete building envelope from prerequisite and make building envelope durability the subject of a separate credit as LEED Canada does.
Restrict scope of electrical commissioning to lighting and lighting controls systems.
Marcus Sheffer
LEED Fellow7group / Energy Opportunities
LEEDuser Expert
5909 thumbs up
September 13, 2011 - 3:06 pm
Erik,
I posted this elsewhere but consensus decision-making and a majority of "votes" in public comment are not the same thing. The public comments are just one aspect of the consensus decision-making. See my comments in the EA section for more detail.
Dan Forino
Regional DirectorHorizon Engineering Associates
58 thumbs up
April 19, 2012 - 12:45 pm
Does anyone think we would be able to apply for a LEED ID credit, for performing Building Envelope Commissioning on just the Mockup of the building as compared to the entire building for a LEED v3 NC project? We would then have a field team verify the installation during the course of the project, but what interval (monthly, bi-monthly, weekly) of inspections would be required?