DENVER PUBLIC COMMENT FORM 1) Name: Matt … · DENVER PUBLIC COMMENT FORM 2015 International Codes . Instructions . ... IECC Sections C104.2.6, C202, C408.2, C408.2.1, C407.2.4,

Community Planning and Development Development Services

201 W. Colfax Ave., Dept. 205 Denver, CO 80202

p: 720.865.2705 www.denvergov.org/DS

DENVER PUBLIC COMMENT FORM 2015 International Codes

Instructions Public comments on the posted International Code amendments must be received by the end of the day on Monday November 16, 2015. Please email this form and any other relevant materials to [email protected].

1) Submitter Information Name: Matt Cooper Date: 8/25/15 Organization (if applicable): Group 14 Engineering Phone and Email: 720-221-1086, [email protected]

2) Provide the International Code name and section number for which you are submitting a public comment.

IECC Sections C104.2.6, C202, C408.2, C408.2.1, C407.2.4, C408.3, C408.3.1, C408.2.4.1, Figure C408.2.4.1 and C408.2.5.4

3) Provide your reasoning for the public comment and justification on why the Building or Fire Code Committee’s original action should be reconsidered. If you are proposing a language change to an approved amendment, please do so in underline and strikethrough format.

One proposal was originally provided and heard by the Building Code Review Committee regarding Section C408 Commissioning. During discussion by the committee, they felt like there were too many items contained within one proposal to be easily discussed. Therefore, I have provided seven separate proposals for the Task Force’s consideration to clarify the commissioning section of the 2015 IECC.

These clarifications should be considered individually, but the overall intent of these proposals is to better define terms based on industry practice, clarify submittal requirements and timing, proposes language changes to discuss the independence of commissioning authority, proposed a commission compliance checklist, and outlines credentials needed for those conducting building commissioning.

By breaking the one proposal up into seven different proposals they can be considered individually and allows changes to be made in one area and not others.

See the included individual proposals as follows:

mailto:[email protected]


a. Section C104.2.6 and C407.2.4.1 b. C202, C408.2, C408.2.1, C408.2.4 and C408.3.1 c. C408.1 d. C408.2.1 e. C408.2.4 and Figure C408.2.4.1 f. C408.2.4, C408.2.5.4 and C408.3 g. C408.2.4

- 2 -

DENVER AMENDMENT PROPOSAL 2015 INTERNATIONAL CODES

NOTE: Each proposed Denver amendment to the International Codes must be justified. In order to be considered, the amendment proposal must address climate, clarity and/or cost.

1) Submitter Information

Name: Matt Cooper Date: August 25, 2015

Organization (if applicable): Group14 Engineering, Inc.

Phone: 720.221.1086 E-mail address:

[email protected]

2) *Signature:

* I hereby grant and assign to City and County of Denver all rights in copyright I may have in any authorship contributions I make to City and County of Denver in connection with this proposal. I understand that I will have no rights in any City and County of Denver publications that use such contributions in the form submitted by me or another similar form and certify that such contributions are not protected by the copyright of any other person or entity. Note: electronic signatures are acceptable.

3) Indicate which International Code (I-Code) you propose to amend (please use acronym): _IECC______________

If your code proposal requires an amendment to another I-Code, please indicate which other I-Code and section(s) is impacted, and provide the necessary language within the proposal form. See section below for list of names and acronyms for the International Codes.

4) Be sure to format your proposal and include all information as indicated on pages 2-3 of this form.

5) Send your proposal to Community Planning and Development (CPD), attention: Jill Jennings Golich, via email at [email protected]. An e-mail submittal should include an electronic version saved with a file name as follows: 2015_public_amendment_proposal_Codname_SectionReference, where ‘Codename_SectionReference’ is replaced using the code and section being proposed (for instance ‘2015_public_amendmnet_proposal_IBC_Section312’). The only formatting necessary is BOLDING, STRIKEOUT AND UNDERLINING. Please do not provide additional formatting such as this will be done by CPD.

Please use a separate form for each proposal submitted unless as allowed in 3) above. Note: All amendment proposals received will receive an acknowledgment, and will be posted on the Building Code website to allow the public review. Please check here if a separate graphic file is provided. □ Graphic materials (graphs, maps, drawings, charts, photographs, etc.) must be submitted as separate electronic files in either PDF, JPEG or TIF format (300 DPI minimum resolution; 600 DPI or more preferred) even though they may also be embedded in your submittal.

Acronym Code Name DBC-AP Denver Building Code–Administrative

Provisions IBC International Building Code IECC International Energy Conservation Code IEBC International Existing Building Code IFC International Fire Code IFGC International Fuel Gas Code IMC International Mechanical Code

Acronym Code Name IPC International Plumbing Code IRC International Residential Code NEC National Electrical Code


AMENDMENT PROPOSAL Please provide all of the following items in your amendment proposal. Your proposal may be entered on the following form, or you may attach a separate file. However, please read the instructions for each part of the amendment proposal.

Code Sections/Tables/Figures Proposed for Revision: Note: If the proposal is for a new section, indicate (new). C104.2.6 C408.2.4.1

Revise as follows: C104.2.6 Final inspection. The building shall have a final inspection and shall not be occupied until approved. The final inspection shall include verification of the installation and proper operation of all required building controls, and documentation verifying activities associated with required building commissioning have been conducted and findings of noncompliance corrected. Buildings, or portions thereof, shall not be considered for a final inspection until the code official has received a letter of transmittal from the building owner acknowledging that the building owner has received the Preliminary Commissioning Report from the building owner or owner’s authorized agent as required in Section C408.2.4. C408.2.4.1 Acceptance of report. Buildings, or portions thereof, shall not be considered acceptable for a final inspection pursuant to Section C104.3C104.2.6 until the code official has received a letter of transmittal from the building owner acknowledging that the building owner or owner’s authorized agent has received the Preliminary Commissioning Report from the building owner or owner’s authorized agent.

Supporting Information: The following items are required to be included. Purpose: The proponent shall clearly state the purpose of the proposed amendment to climate and/or clarify that are specific to the City and County of Denver (e.g., clarify the Code; revise outdated material; substitute new or revised material for physical, environmental and customary characteristics; add new requirements to the Code; delete current requirements, etc to reflect physical, environmental and customary characteristics that are specific to the City and County of Denver.)

Commissioning Report submission to the code official o Provides definitive evidence and disposition of commissioning execution from the owner to the code

official prior to final inspection.

Correction in section C408.2.4.1 that references section C104.3 in lieu of C104.2.6.

Reasons: The proponent shall justify changing the current Code provisions, stating why the proposal is necessary to reflect physical, environmental and customary characteristics that are specific to the City and County of Denver. Proposals that add or delete requirements shall be supported by a logical explanation which clearly shows why the current does not reflect physical, environmental and customary characteristics that are specific to the City and County of Denver and explains how such proposals will improve the Code.

Commissioning Report submission to the code official: o Testing, Adjusting and Balancing reports are commonly required for Certificate of Occupancy. The Cx

Report is equally important in validating the building’s readiness for final inspection and as such should be submitted to the code official prior to final inspection. Additionally, the burden of transferring a preliminary commissioning report to the code official is no more burdensome that writing and delivery a letter of transmittal.

Section C104.2.6 directly references commissioning, the process of submitting a preliminary commissioning report and explicitly references section C408.2.4. This appears to be an obvious error in the code.

Substantiation: The proponent shall substantiate the proposed amendment based on technical information and substantiation. Substantiation provided which is reviewed and determined as not germane to the technical issues addressed in the proposed amendment shall be identified as such. The proponent shall be notified if the proposal is considered an incomplete proposal, and the proposal shall be held until the deficiencies are corrected. The burden of providing substantiating material lies with the proponent of the amendment proposal. A minimum of two copies of all substantiating information shall be submitted.

See responses in sections above. Bibliography: The proponent shall submit a bibliography when substantiating material is associated with the amendment proposal. The proponent shall make the substantiating materials available for review. None.

Referenced Standards: List any new referenced standards that are proposed to be referenced in the code and provide a minimum of one electronic copy. Should the amendment proposal be recommended for inclusion in the amendment package, you must provide two hard copies. None.

Impact: Discuss the impact of the proposed amendment and answer the three questions below on the impact of the amendment proposal. Effect of the proposed amendment on the cost of design: Increase Reduce No Effect

Effect of the proposed amendment on the cost of construction: Increase Reduce No Effect

Is the amendment proposal more or less restrictive than the I-Codes? More Less Same

Departmental Impact: To be filled out by CPD/DFD Note: The department shall indicate one of the following regarding the impact of the amendment proposal:

Effect of the proposed amendment on the time to review: Increase Reduce No Effect

Effect of the proposed amendment on the cost of enforcement/inspection: Increase Reduce No Effect


UPDATED DEADLINE: JANUARY 9, 2015






[email protected]

2) *Signature:












Code Sections/Tables/Figures Proposed for Revision: Note: If the proposal is for a new section, indicate (new). C202 C408.2 C408.2.1 C408.2.4 C408.3.1

Proposal: Show the proposal using strikeout or underline format. At the beginning of each section, include one of the following instruction lines: •Revise as follows •Add new text as follows •Delete and substitute as follows •Delete without substitution Add new text as follows:

SECTION C202 GENERAL DEFINITIONS

QUALIFIED COMMISSIONING AUTHORITY. The individual or agency identified by the owner or owner’s agent that serves as an objective and independent advocate for the owner and is responsible for the execution of the commissioning process. The individual or agency serving as the qualified commissioning authority shall have a building commissioning certification from an ISO/IES 17024 accredited agency, or shall have at least two years’ experience commissioning of projects of a similar scale and complexity and is a licensed professional engineer by the State of Colorado, Revise as follows: C408.2 Mechanical systems and service water-heating systems commissioning and completion requirements. Prior to the final mechanical and plumbing inspections, the registered design professional or approved agency qualified commissioning authority shall provide evidence of mechanical systems commissioning and completion in accordance with the provisions of this section. Revise and add new text as follows: C408.2.1 Commissioning plan. A commissioning plan shall be developed by a registered design professional qualified commissioning authority and shall include the following items: Revise as follows: C408.2.4 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 qualified commissioning authority and provided to the building owner or owner’s authorized agent. The report shall be organized with mechanical, and service hot water findings in separate sections to allow independent review. The report shall be identified as “Preliminary Commissioning Report,” and shall include a statement indicating the qualified commissioning authority’s qualifications in accordance with Section C202, and identify: Revise and add new text as follows: C408.3.1 Functional testing. Prior to passing final inspection, the registered design professional qualified commissioning authority shall provide evidence that the lighting control systems have been tested to ensure that control hardware and software are calibrated, adjusted, programmed and in proper working condition in accordance with the construction documents and manufacturer’s instructions. Functional testing shall be in accordance with Sections C408.3.1.1 and C408.3.1.2 for the applicable control type.


Replacement of the terms “Registered Design Professional” and “Approved Agency” with the single term of Qualified Commissioning Authority:

o Ensure higher quality commissioning execution through qualification of commissioning practitioners. o Eliminate confusion related to terminology not typically used in the Commissioning Industry.

Definition of Qualified Commissioning Authority o Commissioning is a specialized profession and the execution of commissioning should requirement a

level of competence. Reasons: The proponent shall justify changing the current Code provisions, stating why the proposal is necessary to reflect physical, environmental and customary characteristics that are specific to the City and County of Denver. Proposals that add or delete requirements shall be supported by a logical explanation which clearly shows why the current does not reflect physical, environmental and customary characteristics that are specific to the City and County of Denver and explains how such proposals will improve the Code.

Replacement of the terms “Registered Design Professional” and “Approved Agency” with the single term of Qualified Commissioning Authority:

o Registered Design Professional is confusing in that some may mistakenly believe that the project’s Design Engineer is being required to self-execute the commissioning of her design. As this presents a conflict of interest this terminology should be removed.

o Additionally, Approved Agency is not a common term used in the commissioning industry. Qualified Commissioning Authority is a more common term to the industry and requiring the Commissioning Authority to be qualified in the practice will ensure better execution of the process and in turn improve building energy performance.


IECC section C104.4 recognizes that third-party inspection agencies require “qualifications and reliability relevant to the building components and systems they are inspecting.” As commissioning is a specialized industry with skilled professionals, the Denver Amendments should recognize that qualifications are necessary to adequately execute this scope of work. There are currently multiple commissioning credentials from various organizations and identifying which credential best suits Denver is difficult at best. However, the International Accreditation Service, a subsidiary of the International Code Council and the Department of Energy are separately pursuing commissioning personnel accreditation processes using ISO/IEC 17024. As this effort is not fully developed, I also propose a combination of the professional engineering license and a minimum years of experience.

Bibliography: The proponent shall submit a bibliography when substantiating material is associated with the amendment proposal. The proponent shall make the substantiating materials available for review.

Chelednik, Michael. “TDBP Technique: July 2014 - IAS and DOE Cx Certifications.” The American Institute of Architects. 21 August 2015. <http://www.aia.org/akr/Resources/Documents/AIAB104356>

Referenced Standards:

List any new referenced standards that are proposed to be referenced in the code and provide a minimum of one electronic copy. Should the amendment proposal be recommended for inclusion in the amendment package, you must provide two hard copies. None.

Impact: Discuss the impact of the proposed amendment and answer the three questions below on the impact of the amendment proposal.

Effect of the proposed amendment on the cost of design: Increase Reduce No Effect












[email protected]

2) *Signature:












Code Sections/Tables/Figures Proposed for Revision: Note: If the proposal is for a new section, indicate (new). C408.1

Revise as follows: C408.1 General. This section covers the commissioning of the building mechanical systems in Section C403, service water heating systems in Section C404, and electrical power and lighting systems in Section C405.


C408.1 – Add reference to Service Water Heating Systems and associated section for clarification. Reasons: The proponent shall justify changing the current Code provisions, stating why the proposal is necessary to reflect physical, environmental and customary characteristics that are specific to the City and County of Denver. Proposals that add or delete requirements shall be supported by a logical explanation which clearly shows why the current does not reflect physical, environmental and customary characteristics that are specific to the City and County of Denver and explains how such proposals will improve the Code.

See responses in section above. Substantiation: The proponent shall substantiate the proposed amendment based on technical information and substantiation. Substantiation provided which is reviewed and determined as not germane to the technical issues addressed in the proposed amendment shall be identified as such. The proponent shall be notified if the proposal is considered an incomplete proposal, and the proposal shall be held until the deficiencies are corrected. The burden of providing substantiating material lies with the proponent of the amendment proposal. A minimum of two copies of all substantiating information shall be submitted.

See responses in section above. Bibliography: The proponent shall submit a bibliography when substantiating material is associated with the amendment proposal. The proponent shall make the substantiating materials available for review.










UPDATED DEADLINE: JANUARY 9, 2015






[email protected]

2) *Signature:












Code Sections/Tables/Figures Proposed for Revision: Note: If the proposal is for a new section, indicate (new). C408.2.1

Proposal: Show the proposal using strikeout or underline format. At the beginning of each section, include one of the following instruction lines: •Revise as follows •Add new text as follows •Delete and substitute as follows •Delete without substitution Add new text as follows: C408.2.1 Commissioning plan. A commissioning plan shall be developed by a registered design professional or approved agency Qualified Commissioning Authority 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.

2. A listing of specific equipment appliances or systems to be tested and a description of the tests to be performed.

3. Functions to be tested including, but not limited to, calibrations and economizer controls. 4. Conditions under which the test will be performed. Testing shall affirm winter and summer design conditions

and full outside air conditions. 5. Measurable criteria for performance. 6. Where the Qualified Commissioning Authority is an employee of one of the registered design professionals of

record or an employee or subcontractor of the project contractor, an In-House Commissioning Disclosure and Conflict Management Plan shall be included in the commissioning plan. This Plan shall disclose the Qualified Commissioning Authority’s contractual relationship with other team members and provide a conflict management plan demonstrating that the qualified commissioning authority is free to identify issues discovered and report directly to the owner.


Addition of an In-House Commissioning Disclosure and Conflict Management Plan o Help ensure that a conflict of interest does not arise when Design Engineers and Contractors self-

execute commissioning of their own designs and installations.


Requiring third-party independence of the Commissioning Authority is advocated by multiple building industry groups to avoid conflict of interest inherent in any process that permits self-execution of a quality control or verification process.


2015 IECC Section C104.4 o Section C104.4 does not speak directly to the independence of the commissioning authority, but

rather addresses the requirements for third-party inspection agencies to be not be affiliated with the building design and construction. The code clearly recognizes that potential conflict can arise when independence of quality control agencies is not required by the code.

o Furthermore, the IECC defines Building Commissioning as a “process that verifies” building systems installation and functionality according to number of minimum requirements including “code requirements.”

The Strategic Guide to Commissioning o This document was spearheaded by ASHRAE and presented on June 24, 2014. The following

participating organizations joined ASHRAE in the development of this document: SMACNA, AIA, NEBB, ICC, ACG, BOMA, USGBC, Building Commissioning Association (BCA), National Instituted of Building Sciences, and the Council of American Mechanical and Electrical Engineers.

o In Section 6: Commissioning Authority Characteristics, this document states, “In the selection of a commissioning authority it is important that it be based on the qualifications and experience of the proposed candidate… The Commissioning Authority is an objective and independent advocate for the owner. The Commissioning Authority should work directly for the owner, keeping the owner's objectives and best interests as the top priority… A conflict of interest may exist if the Commissioning Authority’s firm has other project responsibilities or function, and/or is not under direct contract to the owner. The commissioning authority needs to be a provider without any financial or business interests or potential conflicts of interest that would interfere with the faithful execution of his/her duties.”

Bibliography: The proponent shall submit a bibliography when substantiating material is associated with the amendment proposal. The proponent shall make the substantiating materials available for review.

ASHRAE; The Strategic Guide to Commissioning, 2014

Referenced Standards: List any new referenced standards that are proposed to be referenced in the code and provide a minimum of one electronic copy. Should the amendment proposal be recommended for inclusion in the amendment package, you must provide two hard copies.

None.














[email protected]

2) *Signature:












Code Sections/Tables/Figures Proposed for Revision: Note: If the proposal is for a new section, indicate (new). C408.2.4 Figure C408.2.4.1 (New)

Add new text as follows: C408.2.4 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 or owner’s authorized agent. The report shall be organized with mechanical, and service hot water findings in separate sections to allow independent review. The report shall be identified as “Preliminary Commissioning Report,” include the completed Commissioning Compliance Checklist (Figure C408.2.4.1) and shall identify: Add new Figure as follows:

Figure C408.2.4.1 COMMISSIONING COMPLIANCE CHECKLIST

Project Information

Project Name:

Project Address:

Commissioning Authority:

Commissioning Plan (Section C408.2.1)

Commissioning Plan was used during construction and includes all items required by Section C408.2.1

Systems Adjusting and Balancing

(Section C408.2.2)

Systems Adjusting and Balancing has been completed

Air and water flow rates have been measured and adjusted to deliver final flow rates within the tolerances provided in the produce specifications.

Functional Testing (Sections C408.2.3

and C408.3.1)

HVAC Equipment Functional Testing has been executed. If applicable, deferred and/or follow-up testing is scheduled to be provided on:________________

HVAC Controls Functional Testing has been executed. If applicable, deferred and/or follow-up testing is scheduled to be provided on:________________

Economizers Functional Testing has been executed. If applicable, deferred and/or follow-up testing is scheduled to be provided on:________________

Lighting Controls Functional Testing has been executed. If applicable, deferred and/or follow-up testing is scheduled to be provided on:________________

Service Water Heating System Functional Testing has been executed. If applicable, deferred and/or follow-up testing is scheduled to be provided on:________________

Supporting Documents

(Sections C408.1.3.2)

Manuals, record documents and training have been completed or are scheduled

System documentation has been provided to the owner or scheduled to be delivered to the owner on:___________

Record documents have been submitted to owner or scheduled to be delivered to the owner on:___________

Training has been completed or scheduled to be completed on:___________

Preliminary Commissioning

Report (Section C408.2.4)

Preliminary Commissioning Report submitted to Owner and includes all items required by Section C408.2.4 with Denver Amendments

Certification

I hereby certify that the commissioning provider has provided me with evidence of mechanical, service water heating and lighting systems commissioning in accordance with the 2015 IECC with Denver Amendments. ____________________________________________________________________ Signature of Building Owner or Owner’s Representative Date


Addition of a Commissioning Compliance Checklist: o Streamline the final inspection submission process as it relates to building system commissioning

execution. Reasons: The proponent shall justify changing the current Code provisions, stating why the proposal is necessary to reflect physical, environmental and customary characteristics that are specific to the City and County of Denver. Proposals that add or delete requirements shall be supported by a logical explanation which clearly shows why the current does not reflect physical, environmental and customary characteristics that are specific to the City and County of Denver and explains how such proposals will improve the Code.

Addition of a Commissioning Compliance Checklist: o To streamline the submission process to the code official for final inspections.


See responses in sections above. Bibliography: The proponent shall submit a bibliography when substantiating material is associated with the amendment proposal. The proponent shall make the substantiating materials available for review.















[email protected]

2) *Signature:












Code Sections/Tables/Figures Proposed for Revision: Note: If the proposal is for a new section, indicate (new). C408.2.4 C408.2.5.4 C408.3

Add new text as follows: C408.2.4 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 or owner’s authorized agent. The report shall be organized with mechanical, lighting controls and service hot water findings in separate sections to allow independent review. Add new text as follows: C408.2.5.4 Final commissioning report. A report of test procedures and results identified as “Final Commissioning Report” shall be delivered to the building owner or owner’s authorized agent. The report shall be organized with mechanical system, lighting controls, and service hot water system findings in separate sections to allow independent review. Add new text as follows: C408.3 Lighting systems functional testing. Controls for automatic lighting systems shall comply with this section. Prior to the final electrical inspection, the Qualified Commissioning Authority shall provide evidence of lighting systems functional testing in accordance with the provisions of this section and in accordance with Sections C408.2.4 and C408.2.5. Exception: Lighting systems are exempt from the functional testing requirements in section C408.3.1 in buildings where the total installed lighting load is less than 20 kW and less than 10 kW of lighting load is controlled by occupancy sensors or automatic daylighting controls.


C408.2.4 and C408.2.5.4 – Requiring lighting controls to be a specific part of the commissioning reports provides the Owner and Code Official a clear indication of commissioning performed and allows for an “independent review” of all the systems commissioning.

C408.3 – The IECC does not appear to explicitly state that lighting controls testing must be completed prior to the final electrical inspection.

C408.3 – The 2015 IECC provide system size exemptions for HVAC and Service Water Heating, but does not provide similar requirements pertaining to lighting systems commissioning.


C408.2.4 and C408.2.5.4 – see response above.

C408.3 – As lighting controls is a system required to be commissioned, it seems only logical to include this system be commissioned prior to the final electrical inspection

C408.3 – It would be absurd to require a project include lighting systems testing of a handful of devices. For example, there is little value in requiring lighting controls commissioning on a small coffee shop with a storage room and a single occupancy sensor.


None Bibliography: The proponent shall submit a bibliography when substantiating material is associated with the amendment proposal. The proponent shall make the substantiating materials available for review.

Referenced Standards: List any new referenced standards that are proposed to be referenced in the code and provide a minimum of one electronic copy. Should the amendment proposal be recommended for inclusion in the amendment package, you must provide two hard copies.














[email protected]

2) *Signature:












Code Sections/Tables/Figures Proposed for Revision: Note: If the proposal is for a new section, indicate (new). C408.2.4

Revise as follows: Revise and add new text as follows: C408.2.4 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 or owner’s authorized agent. The report shall be organized with mechanical, and service hot water findings in separate sections to allow independent review. The report shall be identified as “Preliminary Commissioning Report,” and shall identify: 1. Itemization of deficiencies found during testing required by this section that have not been corrected at the time of report preparation. 2. Deferred tests that cannot be performed at the time of report preparation because of climatic conditions. 3. Climatic conditions required for performance of the deferred tests. 4. Results of functional performance tests. 5. Functional performance test procedures used during the commissioning process including measurable criteria for test acceptance.


Additional Preliminary Commissioning Report requirements o Testing results and testing procedures are required for the final commissioning report. These

documents are also readily available when drafting the preliminary report. Not including this documentation in the preliminary commissioning report limits the transfer of valuable information in a timely manner.


Additional Preliminary Commissioning Report requirements o Testing results are valuable in understanding what the commissioning provider did, how they did it

and under what conditions the testing was executed. This can be especially helpful for contractors and building owners troubleshooting poor system operation.


See responses in sections above. Bibliography: The proponent shall submit a bibliography when substantiating material is associated with the amendment proposal. The proponent shall make the substantiating materials available for review.







