Within the built world, and certainly the commissioning process (Cx) industry, there is a growing concern with owners and clients mistaking the commissioning process with installation and startup. Although this concern is primarily limited to one owner, that just happens to be the U.S. Department of Defense (DoD) with a purported 2022 military construction budget of roughly $6.7 billion1, the effect on the private sector adopting government policies is historically proven.
The commissioning process industry certainly didn’t invent the word “commissioning,” nor would it be beneficial attempting to gate keep a term spanning multiple industries. After all, commissioning defined as installation and startup can be an important step toward achieving client goals. The intent of this article is to distinguish the process for documenting owner goals throughout the course of total building commissioning, from a process for placing equipment into service for federal criteria. Possibly adding to the confusion is the use of the term commissioning by various trades within the construction industry. And, then, in turn, requirements for those installer and start-up trades having been incorrectly adopted as criteria for the commissioning process. This is evident with the Unified Facilities Guide Specifications (UFGS), which are the military services documents for specifying construction. More precisely, 01 91 00.15 Total Building Commissioning provides criteria for mechanical and electrical technical commissioning specialists.
It is this federal criteria, UFGS 01 9100.15 1.8.2.a, that provides mechanical technical commissioning specialist certifying qualifications, such as the National Environmental Balancing Bureau (NEBB), Associated Air-Balancing Council’s Commissioning Group (ACG), International Certification Board (ICB), Testing Adjusting and Balancing Bureau (TABB), Association of Energy Engineers (AEE), University of Wisconsin-Madison, ASHRAE, and the Building Commissioning Association (BCA). This list of qualified providers is extensive and inclusive with each sharing a common definition for the term commissioning. ASHRAE, an industry-leading resource for best practices of all indoor environments, defines the commissioning process as a method for documenting owners’ project requirements are met throughout the duration of a project. This process is applicable, regardless of discipline, to include mechanical and electrical applications. In UFGS section 1.8.2.b, which defines the certifying qualifications for an electrical technical commissioning specialist, identifies a difference in the criteria for such qualifications. The federal specification goes on to list the electrical specialist requirements as a technician certified by the InterNational Electrical Testing Association (NETA) only. NETA, which is widely accepted as an electrical testing company, defines commissioning as the process of placing into service electrical power equipment.
In the breath of one paragraph, the requirement has evolved from an inclusive requirement with multiple possible qualifications, congruent with one another in defining the term commissioning, to a single, exclusive qualification of an installer uniquely defining commissioning as startup procedures. With the exception to this one paragraph, the entirety of the UFGS document appears to harbor inclusive language, encouraging multiple solutions in achieving project success, while promoting competition among providers.
So, why the use of different language here? How should the industry address a federal client’s commissioning needs? The answers to these questions are the topic of an ongoing discussion.
This discussion was put on center stage at the CxEnergy 2022 event in Orlando, when a panel of ACG Building Systems Commissioning guideline committee members answered questions in a breakout session moderated by Jesse Felter, SSRCx, commissioning discipline manager, Smith Seckman Reid Inc.
Felter: So, why the use of different language in this particular section of UFGS (01 9100.15), inclusive versus exclusive?
Jim Magee, CxA, EMP, LEED AP, principal, Facility Commissioning Group: This occurred due to a misunderstanding between installer startup procedures and professional commissioning process services based on NETA’s unique definition of commissioning as startup requirements instead of a third-party quality assurance process based on owner/occupant advocacy as defined by ASHRAE STD 202 - 2018.
Felter: How can a Commissioning Provider address a Federal client’s commissioning needs?
Magee: Specification requirements for NETA testing, startup procedures, and readiness for placing gear into operation belong in installer specifications under Part 3, execution sections. Electrical commissioning specification language should inclusively contain ACG, ASHRAE, U. WS, BCA, IEEE, and other industry-based, third-party commissioning processes that includes professional verification of NETA testing, startup procedures, and readiness for placing gear into operation performed by installers.
Felter: When comparing UFGC 01 91 00.15, total building commissioning requirements, listed under 1.8.2, is there a disparity in what is required between electrical specialists and other disciplines?
Magee: Comparing the qualifications for technical commissioning specialists between mechanical technical commissioning specialists and electrical technical commissioning specialists presents a distinct contrast in both technical criteria and trade inclusivity. Whereas the mechanical technical commissioning specialist presents a wide range of qualifying certification options – NEBB, ACG, ICB/TABB, AEE, University of Wisconsin-Madison, ASHRAE, or BCA – the electrical technical commissioning specialist presents a singular certification qualifier –NETA. It is noteworthy, also, that InterNational Electrical Testing Association is written out in addition to being presented as an acronym, while the mechanical technical commissioning specialist qualifying certification options are presented as acronyms only, as if NETA receives special treatment in advertising its complete organizational name. This does not appear impartial and seems to promote NETA as an organization.This comparison also holds true for the building envelope technical commissioning specialist that allows multiple qualifying certification options — registered architect with five years of building envelope design or construction experience or a professional with training and certification as an air barrier installer from the Air Barrier Association of America (ABAA) or other third-party air barrier association. The electrical technical commissioning specialist permits only NETA without mention of other third-party associations.
It also stands out that the mechanical technical commissioning specialist and the building envelope technical commissioning specialist associations listed each institute training and certification for the comprehensive list of services shown in article 1.8.2.a and 1.8.2.c. NETA is not comprehensively proficient in, and, in fact, does not include training and certification for the entire range of listed services in article 1.8.2.b. NETA provides credentialing for installing contractor diagnostic inspecting, testing, and calibrating electrical distribution and generation equipment, systems, and devices. NETA certification does not cover professional engineering design review or comprehensive commissioning services required by Section 01 91 00.15. The mechanical technical commissioning specialist and the building envelope technical commissioning specialist associations are intentionally directed at building commissioning, but NETA’s certification is limited to diagnostic testing of power distribution and power generation equipment and components.
In contrast with 1.8.2.a and 1.8.2.c, 1.8.2.b includes services outside the scope of NETA diagnostic testing; namely, lighting controls, renewable energy systems, and utility metering. To be clear, NETA testing is valuable and preferable for contractor startup activities and presents safety and technical advantages important to every building systems commissioning project. However, compared to the scope of work listed in 1.8.2.b, NETA certification only covers a portion of the work.
Another delineator of the NETA requirement is that to maintain certification, the NETA provider must be a separate entity performing at least 80% of overall services as diagnostic electrical testing, a caveat making it impossible for a commissioning firm to either hire in-house or subcontract to the qualifying certified personnel. A 1.8.2.b must be hired separately from the other technical specialists, setting up an independent electrical technical commissioning specialist working outside of the commissioning firm. This dynamic increases cost and creates management complications because the commissioning firm can hire all the technical commissioning specialists except the electrical technical commissioning specialist.
A suggestive solution would be to incorporate the NETA diagnostic testing requirement into the electrical installation specification sections and create an article 1.8.2.b that follows the mechanical technical commissioning specialist and building envelope technical commissioning specialist criteria that are both comprehensive and inclusive. This change would create greater equity in the selection of qualified commissioning services providers for the overarching electrical systems commissioning without losing the value of NETA testing. It also offers an equitable solution providing both government procurement and commissioning firms with competitive selection in lieu of monopolizing the electrical technical commissioning specialist role for a single association that cannot demonstrate coverage of the full range of work requested.
Felter: How do you respond to a client requiring UFGC 01 91 00.15 1.8.2.b, electrical technical commissioning specialist, which states: “The technical work associated with electrical systems, including lighting systems electrical utility metering systems, must be performed by an engineering technician certified by the InterNational Electrical Testing Association (NETA) with five years of experience inspecting, testing, and calibrating electrical distribution and generation equipment, systems, and devices.”
Mark Gelfo, P.E., CxA, EMP, LEED Fellow, managing principal, TLC Engineering Solutions: There are two schools of thought when seeing a commissioning spec or request for proposal (RFP) requirement like this, essentially requiring the NETA-certified CxP, which doesn’t really exist.
Simply exclude the requirement in your proposal with clear, unambiguous language. That is risky and not something we like to do.
Or, the much better option is to talk to the procurement officer or client project manager. We try to explain exactly that what they are requiring doesn’t exist, try to understand what is driving the requirement (is it boilerplate language or is there really a need?), and, most importantly, offer an alternative solution.
Hopefully, after that discussion, the requirement will be waived or modified to allow truly competitive bids. And, if not, then at least we have the information we need to make an informed go/no-go decision.
Felter: Do current industry needs allow for a Cx provider to have 80% of his or her revenue from electrical commissioning and still be capable of performing other comprehensive commissioning services, such as HVAC and building enclosure work?
Gelfo: No. Only the most specialty, electrical-only commissioning firms would likely have more than 80% of their revenue coming from electrical commissioning projects, meeting the threshold NETA requires for a company to be NETA certified.
And, if an electrical-only commissioning firm met the requirements and chose to pursue NETA certification, the firm’s individual staff members would also have to meet the NETA training and experience requirements, which are similar to those of journeymen/licensed electricians, depending on the NETA certification level
I think, at the heart of this discussion, the fundamental difference between testing and commissioning is the specific differences between electrical testing and electrical commissioning. Commissioning of any building system, including electrical systems, starts at the earliest phases of the project and includes deliverables, such as design phase reviews, review of equipment submittals, preparation of the commissioning plan, witnessing equipment startup, and facilitation of acceptance testing as well as post-occupancy functions. Startup and acceptance testing are vital parts of the process, which should be conducted by a qualified testing firm and witnessed, facilitated, and documented by the commissioning provider.
Simply put, the electrical testing provider and the electrical commissioning provider are different people with different skill sets, different experiences, and different, but complimentary, responsibilities — both of whom play very important roles on any project.
Felter: Do ASHRAE Standards 90.1, 189.1, 202; Guidelines 0, 0.2, 1.1 or 1.2; the ACG Commissioning Guideline; NEBB; or AEE recognize NETA certification as a requirement for Cx providers of Cx services for electrical and/or mechanical systems?
Charles Jackson III, P.E., PMP, CxA, CEM, commissioning team manager, Sustainable Building Partners LLC: In reviewing the current ASHRAE, ACG, NEBB, and AEE standards and guidelines, the requirement for Cx providers of Cx services for electrical and mechanical systems to be NETA-certified does not exist. For electrical commissioning, specifically, the commissioning agent's role has traditionally been observing and documenting the results during electrical testing. NETA certification is geared toward the installing electrician or electrical practitioner who physically installs and operates the equipment. The fundamental role of commissioning is to provide an unbiased third-party view of the process and add a quality assurance component to the project. ASHRAE, ACG, NEBB, and AEE see the value of the commissioning agent qualifications are based on their understanding of the Cx process and subject matter expertise versus the requirement to be a hands-on practitioner.
Felter: Does the commissioning industry or a client benefit from distinguishing NETA Electrical Commissioning Specifications (ECS) ready-to-test conditions from ACG’s comprehensive commissioning process? If so, how?
Jackson: The commissioning industry benefits greatly from distinguishing NETA ECS ready-to-test conditions from ACG's comprehensive commissioning process. The NETA ECS focuses primarily on the testing portion of commissioning. Quite frankly, the term commissioning, industry-wide, is often misused to only describe the startup testing of systems. However, commissioning is a comprehensive process implemented from design through construction and testing and can go all the way through the warranty phase. From a client perspective, delineating between startup testing and commissioning allows all parties and potential proposals to be on the same page. NETA is necessary in the industry as a quality-control portion the installing contractor needs to perform to ensure the electrical system is ready for traditional commissioning. Having NETA-certified personnel performing that QC function helps ensure proper workmanship, safety, and quality.
*1 Construction Programs (C-1): Department of Defense Budget Fiscal Year 2022,
https://comptroller.defense.gov/Portals/45/Documents/defbudget/fy2022/fy2022_c1.pdf
