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Evolving Commissioning Requirements in Building Efficiency

With the building sector estimated to generate nearly 40% of annual global greenhouse gas emissions, it’s no mystery that energy codes have risen up the agenda to meet the ambitious goals set by the Paris Climate Agreement. But how do commissioning providers navigate and stay compliant with these evolving codes?

We asked our partners at the AABC Commissioning Group (ACG), the largest body of independent, certified commissioning professionals, for their input. This is a sneak peek of further information that will be provided in ACG’s upcoming CxEnergy 2021 Virtual webinar: “Evolving Commissioning Requirements in Building Energy Codes” by Scott West, PE, BCxP, LEED AP and Greg Schluterman, PE, CxA, LEED AP, HFA. 

Greg and Scott have contributed the following blog post to explore this issues.

This April, CxEnergy 2021 Virtual will deliver 16 live and pre-recorded technical presentations, covering case studies in commissioning and energy management in buildings and facilities, energy data analytics, critical updates to codes & standards, and more. Earn up to 16 CEUs/PDHs! Register today with promo code “BCSE10″ for a 10% discount.

Please note: This is independent advice from certified professionals in this sector and does not represent official technical, legal, or public health guidance from BCSE.

Evolving Commissioning Requirements in Building Energy Codes

The commissioning process has become familiar to most professionals in the building design and construction industry thanks to the popularity of beyond-code programs such as the LEED rating system1.  However, commissioning requirements have gradually been getting stronger in building energy codes and industry stakeholders need to be aware of how this impacts minimum code-compliant building projects.

The majority of building energy codes in the United States are based on either ASHRAE 90.12 or IECC3.  Each document is published on an asynchronous 3-year continuous maintenance cycle with numerous revisions being added for each publication.  This article explores the commissioning requirements in the energy codes since 2004 and how they’ve evolved to include robust commissioning programs over time.

The energy code started with test and balance requirements for HVAC air and hydronic distribution systems and compiling operations and maintenance manuals for installed equipment.  Since 2004, commissioning has emerged as a distinct function in guiding a project from design through to construction and operational handover.  With the increased emphasis on sensors and controls to provide higher levels of energy efficiency, functional performance testing has become a necessary result4,5.  Commissioning of building systems has a demonstrated track record in adding value to projects and helping to ensure systems perform as intended6,7.

Commissioning is particularly valuable when it evaluates systems that don’t come off-the-shelf in a nice, manufactured package.  Sometimes multiple construction trades and product manufacturers are involved in supplying and installing a single building system, and commissioning agents are the glue that can help ensure it functions when it’s time to perform.

Figure 1 shows a brief summary of how the commissioning technical requirements in the energy code have evolved from 2004 up to the present.  Figure 2 provides a similar summary of the commissioning documentation requirements.

Figure 1

Figure 2

As can be seen from the figures, commissioning requirements have been added piecemeal over the publication years and there are substantial differences between ASHRAE 90.1 and IECC.  Depending on the jurisdiction, adoption of the IECC typically allows ASHRAE 90.1 to be used as an alternative compliance path (according to the default IECC language).  Commissioning agents need to be attentive as the selected energy code compliance path is often chosen by the design team but has implications on the required commissioning scope.  Most projects end up on one compliance path or the other for reasons other than commissioning.  Different reasons include economizer requirements, envelope performance differences, window-to-wall ratio restrictions and whether a prescriptive or performance path is chosen.

Once a compliance path is chosen a commissioning agent usually has to get up to speed quickly in order to fulfill mandated technical and documentation requirements.  While the latest versions of ASHRAE 90.1 and IECC are approaching best practice commissioning scope, they are still short of beyond-code programs like LEED or the IgCC8.  Commissioning practitioners have to pay close attention to the energy code requirements in effect for a particular project and adjust their scope and fees accordingly.  Most commercial building owners want to get the most bang for their buck on commissioning and they want it done quickly and efficiently.

The differences in the commissioning requirements in the energy codes leave one to wonder what the core requirements of the commissioning process truly are.  The differences can make it challenging for a design team to know what exactly is required for their project.  Commissioning providers need to understand these differences and educate the owner and design team accordingly.  Being proactive on establishing the commissioning scope to be aligned with the code requirements will lead to a more successful project in the end.


  1. Leadership in Energy and Environmental Design (LEED), United States Green Building Council,
  2. ANSI/ASHRAE/IES Standard 90.1-2019, Energy Standard for Buildings Except Low-Rise Residential Buildings
  3. 2021 International Energy Conservation Code, International Code Council
  4. Are We Saving Energy from Code Controls Requirements in Real Buildings?, Energy Codes Webinar Series, 2017, Depart of Energy and Pacific Northwest National Laboratory
  5. Barriers to Energy Controls Delivering Real Savings, 2019; Hart, Reid; Rosenberg, Michael; ASHRAE Transactions, KC-19-A031
  6. Building Commissioning: A Golden Opportunity for Reducing Energy Costs and Greenhouse Gas Emissions, 2009, Lawrence Berkeley National Laboratory
  7. Building Commissioning Costs and Savings Across Three Decades and 1,500 North American Buildings, 2020, Lawrence Berkeley National Laboratory
  8. 2018 International Green Construction Code, International Code Council