DENVER PUBLIC COMMENT FORM 2015 International Codes

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 jill.jenningsgolich@denvergov.org. 1) Submitter Information Name: Matt Cooper Date: 8/25/15 Organization (if applicable): Group 14 Engineering Phone and Email: 720-221-1086, mcooper@group14eng.com 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:

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: mcooper@group14eng.com 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 jill.jenningsgolich@denvergov.org. 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 DBC-AP IBC IECC IEBC IFC IFGC IMC Code Name Denver Building Code Administrative Provisions International Building Code International Energy Conservation Code International Existing Building Code International Fire Code International Fuel Gas Code International Mechanical Code Acronym IPC IRC NEC Code Name International Plumbing Code International Residential Code 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.

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

DENVER AMENDMENT PROPOSAL 2015 INTERNATIONAL CODES UPDATED DEADLINE: JANUARY 9, 2015 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: mcooper@group14eng.com 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 jill.jenningsgolich@denvergov.org. 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 DBC-AP IBC IECC IEBC IFC IFGC IMC Code Name Denver Building Code Administrative Provisions International Building Code International Energy Conservation Code International Existing Building Code International Fire Code International Fuel Gas Code International Mechanical Code Acronym IPC IRC NEC Code Name International Plumbing Code International Residential Code National Electrical Code

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.

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.) 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 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. 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. 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. 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 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

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.

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.) 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 selfexecute commissioning of their own designs and installations. 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. 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. 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. 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. 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

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 Commissioning Plan (Section C408.2.1) Systems Adjusting and Balancing (Section C408.2.2) Functional Testing (Sections C408.2.3 and C408.3.1) Supporting Documents (Sections C408.1.3.2) Preliminary Commissioning Report (Section C408.2.4) Certification Project Name: Project Address: Commissioning Authority: Commissioning Plan was used during construction and includes all items required by Section C408.2.1 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. 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: 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 submitted to Owner and includes all items required by Section C408.2.4 with Denver Amendments 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