Commissioning Moves to the Front Row

Commissioning fog airflow testing
5 min read

Washington D.C.’s 2017 DC Construction Codes (2017 DCMR) went into effect on May 29, 2020. For those working in the DC construction market, there are several updates worth noting related to commissioning, especially in the new Energy and Green Construction Codes.

Overview of Changes Related to Commissioning

The first thing to note about the updates to the Energy and Green Codes is that energy-related elements that were previously part of the Green Code are now all part of the Energy Code. This makes following and working with energy-related requirements much easier. However, it also means that alternative compliance paths like performing commissioning (Cx) as part of a LEED certification are no longer in place. Since getting LEED-certified does not meet 2017 DCMR’s Cx requirements, a closer look at those requirements is in order. The following are the main items to note:

  • All projects must now include acceptance testing
  • Project Cx is now required for a wider range of projects
  • The commissioning Provider (CxP) cannot be part of the design or construction team
  • Code officials (DCRA) will monitor the Cx process more closely
  • The preliminary Cx report must be issued directly to DCRA and carries more weight
  • Building envelope commissioning (BECx) or whole-building pressurization testing is required
Supply Air Volume Verification
Supply air volume verification

Acceptance Testing

For all projects, no matter how small, the new code requires acceptance testing for all HVAC, lighting, renewable energy systems, fenestration control systems, and submetering devices. In addition to verifying that installed systems perform in accordance with construction documents, acceptance testing includes verification that a systems manual has been prepared and provided.

A project acceptance representative is to be assigned for each project and acceptance testing documentation is to be provided to the owner. Code officials do not review these documents for every project, but acceptance testing documentation must be made available upon request. Although the project acceptance representative does not have to be a CxP, this is a service that any CxP can fulfill because these are standard elements of project Cx.

Thermal Camera Identifying Open Duct
Thermal camera identifying open duct

Project Commissioning

Compared to the 2013 code requirements, 2017 DCMR requires more projects to complete project Cx. Once projects exceed certain sizes, the new code requires a project Cx plan to be created and followed. The code prescribes requirements from early design stages through occupancy and includes creating a Cx plan, design reviews, pre-start-up site visits, pre-functional testing, functional performance testing (FPT), and verification of training, among other things.

For new construction, all projects greater than 10,000 square feet must include Cx. The exemption for Group R-2 and R-4 residential buildings of three stories or less in height that was included in the 2013 code now appears to have been eliminated (since Cx is now only in the Energy Code supplement).

In the 2013 code, most alterations less than 50,000 square feet were exempt from the Cx requirement. In 2017 DCMR, Cx is required for Level III alterations down to areas of 10,000 square feet and all alterations of 20,000 square feet or greater.

Lastly, Cx for projects where replaced mechanical, electrical, or plumbing systems serve an area of 20,000 square feet or greater is now required. Also, Cx is required for projects where new, replaced, or relocated HVAC systems have heating equipment size of 480,000 BTU’s or greater, or have cooling equipment size of 600,000 BTUs or greater.

Qualifications of the Commissioning Provider

In the past, Cx could be done by a project’s engineering firm or an approved third-party CxP. The new code states that Cx cannot be done by a member of any construction or design firm involved in the design or construction of the project. So, Cx must now be done by a DCRA-approved third-party provider.

Commissioning Process Monitoring by DCRA

The next thing to take note of is that the 2017 DCMR Cx process is more prescriptive than before, and DCRA will more closely monitor the process. Concerning things the code requires that are new, it starts by requiring the creation of owner project requirements (OPR) and the basis of design (BOD) documents. These are to be used to complete prescribed design reviews at 50% design completion and final construction document issue. These all represent new requirements with respect to code but are not new for projects meeting LEED requirements. Later in the process, the code requires that the BOD be updated to include the approved permit drawings.

Whereas the 2013 code required a Cx plan to be provided during the permitting process, the code now requires that a Cx plan be submitted to DCRA before the building’s rough-in inspection is done. This plan is to include test plan details such as acceptance testing forms, functional performance test sequences, and criteria for performance pass.

Preliminary Commissioning Report and Certificate of Occupancy

One of the more notable changes in 2017 DCMR is that the preliminary Cx report must now be issued directly to DCRA. Under the 2013 code, the preliminary Cx report was submitted to the owner and available to DCRA upon request. As before, the issuance of the preliminary Cx report is a prerequisite for obtaining a certificate of occupancy. This change is made more significant because it is tied to the requirement that the CxP check the project against the permit drawings in the BOD, the Energy Conservation Code requirements, and the Green Construction code requirements. If any deficiencies relative to these documents are identified, they must be corrected prior to submitting the preliminary Cx report to DCRA for review.

Building Envelope Commissioning or Whole Building Pressurization Testing

For new construction or additions 50,000 square feet or greater and for alterations and additions for buildings over 50,000 square feet where at least 25 percent of the vertical, above-grade building envelope is being replaced, altered, and/or added, whole building pressurization testing or BECx is required. BECx must be done by a provider who is approved by DCRA and must follow ASTM-E2813-12 guidelines. Primary elements of the Cx process must include a design review, on-site inspections, testing, and reporting. Performance with respect to air infiltration, condensation resistance, thermal performance, and water penetrations are to be addressed by the BECx plan.

Commissioning Moves to the Front Row blog
Left: Mock-up installation process verification
Middle: Static water penetration acc. to ASTM E331-09
Right: Visual verification of water intrusion

When Does It Apply?

Finally, a word about timing with respect to which projects will fall under the new codes. Any wholly new project (except for first-time fit-out work) that is initiated after May 29, 2020 will fall under the new code. If a permit application was submitted before May 29, 2020 the project can continue under the 2013 DC Construction Codes (2013 DMCR). If the project design was under contract before May 29, 2020 and a permit is applied for before May 29, 2021, then the 2013 code can still be applied to the project. Finally, for first-time fit-out work, the code that the base building was built under applies.


At first glance, 2017 DCMR seems to add a lot of new Cx requirements to DC projects. However, the new code aligns well with LEED requirements. In fact, Cx that complies with the new code will meet the requirements for LEED fundamental Cx and many of the requirements for LEED enhanced Cx.

On balance, for those who have followed sound Cx practices in the past or followed the LEED certification alternative code compliance path, the main difference in meeting Cx requirements under 2017 DCMR will be in the interactions with DCRA and the weight that the preliminary Cx report carries with respect to project completion. While the direct costs for the new Cx requirements are not zero, experience shows that these efforts pay dividends. Commissioned projects have fewer issues at handover and typically are less expensive to operate.

Commissioning Moves to the Front Row