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Make Commissioning and Your Buildings Better: Resolving Conflicts between Title 24 and Commissioning

I became a commissioning (Cx) provider because I believe it makes a difference in the quality and efficiency of buildings. Title 24 (part 6) has the same goals. Unfortunately, as it stands the goal of efficient buildings through commissioning isn’t being enforced as well as it could be.

As written, code allows almost anyone to do commissioning. The lack of standard decreases the quality of the effort. Furthermore, just requiring any certification does not help quality. There are at least 14 Cx certifications out there. Only ANSI-accredited Cx providers meet the rigid federal requirements for experience and qualifications.*

In addition, an independent third party is only required for design review for large (>50,000 SF) or complex systems (currently only mechanical, but should include lighting). Anyone can functionally test their systems (120.8(g)). Allowing anyone from the design team or the contractor to test their own systems is not only a conflict of interest, but reduces quality by allowing those without the specialized experience to properly test complex systems.

The CEC currently has no plans to change it. (Read the 45-day language here. Section 120.8 is on page 40.)

If you agree that we need quality in commissioning, write to the CEC! Send your comments by TUESDAY, FEBRUARY 20** to make the most impact. Here’s how:

Method 1 (Email)

  1. Attach a pdf of your letter to an email.
  2. Enter as the subject: Docket 17-BSTD-02, 2019 Energy Code, Comments on Section 120.8
  3. Email it to ;

Method 2 (Via the CEC Website)

  1. Go to the 17-BTSD-02 website
  2. Fill in the form
  3. Attach your letter
  4. Click “Submit your comment”

And remember to tell all your friends!

If you need it, here are a couple of examples:
Building Commissioning Association, California Chapter, letter:–ExeN
Bradley Brooks’ letter:

* The duo of ANSI-accreditation and national guidelines work together to ensure the bodies granting the certifications are nationally recognized, open, transparent, and credible and the people with the credential are qualified to do the work. ANSI/ISO/IEC 17024:2012 governs how certifications are granted and is a hallmark for a quality certification program – preventing pay for play or associations from turning their certifications into a cash cow. The Professional Engineering license is ANSI-accredited. The requirements for experience for commissioning providers are listed in the Better Buildings Workforce Guidelines Program. These national guidelines ensure consistency between certifications by defining competency. The Certified Commissioning Professional (CCP) certification was the first to be ANSI-accredited.

** March 5 at 5pm is the drop dead deadline, but comments made later will have less of an impact.

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