Commercial Commissioning: When Is It Required Under Title 24?
Section 120.8 requires full commissioning for newly constructed nonresidential buildings with 10,000 square feet or more of conditioned space, and design review only for smaller ones. Healthcare facilities are excluded, and the Energy Commission's manual says commissioning and design review are not required for additions or alterations.
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The two size tiers
At 10,000 square feet or more, a project completes Section 120.8(a) to (i): owner's project requirements, basis of design, design review, commissioning measures on the drawings, a commissioning plan, functional performance testing, a systems manual with training, and a report. Below that, only the design review in 120.8(d) and the measures in 120.8(e) apply. Only the nonresidential spaces of a hotel, motel or high-rise residential building count. CALGreen commissioning is separate and additional.
Where alterations and fit-outs land
Part 6 does not require retrocommissioning, and the manual says neither commissioning nor design review is required for additions or alterations. The Section 141.0(a)1 and 141.0(b)2 lists of Part 6 sections each skip Section 120.8. When a first-time fit-out counts as new construction is on our alteration or new construction page.
Who may commission, and who signs
The Energy Code does not require any certification to commission a building, and "commissioning agent" is not a defined term. What Part 1 Section 10-103(a)1 fixes is the person who signs the design review kickoff and checklist forms: a licensed engineer or architect, or a licensed contractor working for or under one. Under 10,000 square feet that can be the engineer or architect of record. Between 10,000 and 50,000 it is a qualified in-house engineer or architect with no other project role, or a third party. Above 50,000 square feet, or with complex mechanical systems serving over 10,000, it must be a third party. These tiers use total project area, while the commissioning triggers use nonresidential conditioned space.
Documents and the owner's part
NRCC-CXR-E holds the forms. The owner or representative writes the project requirements before design starts: energy goals, ventilation, operating hours, equipment and envelope expectations. The owner joins the schematic-phase kickoff and files the kickoff form and checklist with the compliance documents. The owner receives a systems manual, staff training and a report. The plan is done before permit issuance. Functional tests follow the acceptance requirements, so the acceptance testing and NRCC work overlaps.
See also acceptance test timing and shell building permits. Commercial reports are quoted per project.
Common Title 24 Questions
- When does a commercial project need Title 24?
- Does an office tenant improvement need Title 24?
- Does a restaurant remodel need Title 24?
- Does a retail tenant improvement need Title 24?
- What plans are needed for a commercial Title 24 report?
- What is an NRCC certificate of compliance?
Frequently Asked Questions
Not as an alteration. The manual says neither commissioning nor design review is required for additions or alterations. A fit-out that counts as new construction is a different case.
Part 6 does not require one. It requires that a licensed engineer, architect or supervised contractor signs the design review forms, with a third party at the larger sizes.
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