Draft Proposal CA-10 

This concept has been developed by the DOE Building Energy Codes Program (BECP) as a possible code

change proposal to the Commercial provisions of the 2012 International Energy Conservation Code

(IECC).   Interested parties are asked to submit any and all comments on DOE's initial concepts and draft

code change proposals. For instructions on submitting comments, visit:

www.energycodes.gov/development/commercial/codes/iecc/concepts/

Envelope Commissioning (CA-10) 

Objective: Add provisions covering commissioning of the building envelope. 

Suggested Code Change Proposal

Revise Sections C408 and C408.1 and add a new Section C408.2 as follows:  

C408 SYSTEM BUILDING COMMISSIONING 

C408.1 General. This section covers the commissioning of the building thermal envelope in Section 

C402, building mechanical systems in Section 403 and electrical power and lighting systems in Section 

C405. 

C408.2 Building thermal envelope commissioning and completion requirements. Prior to the 

conduct of the final inspection, a registered design professional shall provide evidence of building 

thermal envelope commissioning and completion in accordance with this section. 

 Construction documents and specifications shall clearly indicate the provisions for 

commissioning and completion of the building thermal envelope in accordance with this section. Copies 

of all documentation verifying those provisions have been carried out shall be given to the building owner 

by a registered design professional and made available to the code official upon request. 

C408.2.1 Commissioning plan. A commissioning plan shall be developed by a registered design 

professional and shall include the following items:

1. A narrative description of the activities that are to be accomplished during each phase of 

commissioning including the personnel intended to perform each activity.

2. A listing of the specific products, components, assemblies and conditions associated with the 

building thermal envelope to be evaluated as provided in Section C408.2.2 and the description of 

the means by which they will be evaluated.

3. Items to be tested, conditions under which the testing will be performed, the standards used as a 

basis for the tests and the measureable criteria for performance.
C408.2.2 Building thermal envelope commissioning and testing. The commissioning plan shall 

include the following items associated with the building thermal envelope.

1. Confirmation of the installation and application of foundation sub-soil drainage, damp-proofing 

and water proofing to ensure that below grade components of the building thermal envelope will 

not be adversely affected by water leaking intrusion from the building exterior.

2. Flashing and sealing at all locations where different products, components and assemblies 

associated with the building thermal envelope are connected or proximate to one another and 

provide sealing against the intrusion of snow, ice and rain.

3. Systems associated with diversion of snow, ice and rain from impacting the building thermal 

envelope and their ability to perform their intended function.

4. Protection of insulation products associated with the building thermal envelope that are exposed 

to natural or manmade conditions that can impact their long term performance.

5. The proper application, installation and operation of any required fenestration shading devices or 

systems.

6. Confirmation that the air barrier required by Section C402.4.1.2 exists in the building. Where 

confirmation is through an air leakage test of the building the results of the test, the conditions 

under which the test was conducted and who performed the testing shall be required as part of the 

plan.

C408.2.3 Preliminary commissioning report. A preliminary report of the means employed in 

commissioning the building thermal envelope and the observed results shall be completed by a registered 

design professional and provided to the building owner. This report shall be identified as “Preliminary 

Building Thermal Envelope Commissioning Report” and shall provide an itemization of deficiencies 

found during commissioning as required by this section that have not been corrected at the time of report 

preparation.

C408.2.3.1 Acceptance of report. Buildings, or portions thereof, shall not be eligible for final 

inspection until such time as the code official has received a letter of transmittal from the building 

owner acknowledging that the building owner has received the preliminary commissioning report. In 

carrying out this activity the code official shall be permitted to receive a copy of and review the report 

prior to conducting the final inspection.

C408.2.4 Documentation. The construction documents shall specify that the documents described in this 

section will be provided by a registered design professional to the building owner within 90 days of the 

date of receipt of the certificate of occupancy.

C408.2.4.1 Drawings. Construction drawings shall include the location of each component or 

assembly associated with the building thermal envelope, the manner in which they were constructed, 

performance data on the components and assemblies associated with the building thermal envelope, 

and the details to be applied in determining compliance with the air leakage requirements in the code.
C408.2.4.2 Manuals. An operating and maintenance manual shall be provided to the building owner 

by a registered design professional that provides a narrative about how the components of the 

building thermal envelope are intended to function and actions necessary to maintain those functions.

C408.2.4.3 Air leakage test report. A written report shall be provided to the building owner by a 

registered design professional describing the activities and measurements completed to verify 

compliance with Section C402.4.

C408.2.5 Final commissioning report. A “Final Building Thermal Envelope Commissioning Report” 

shall be delivered to the building owner by a registered design professional that includes the results of air 

leakage testing pursuant to Section C402.4, disposition of deficiencies found during air leakage testing 

and the manner in which they were corrected, and findings associated with the thermal integrity of the 

building thermal envelope based on an inspection by the registered design professional.

Reason:  The value of commercial building commissioning has been documented and was included for

mechanical and lighting systems during the prior code development cycle as a new Section 408 in the

IECC.  Those provisions are intended to ensure that the building has been “tuned” prior to occupancy, to

make sure it is properly operating and capable of continuing to operate properly.  This code change

proposal extends the value and validity of the code provisions because there is little value in requiring

something be provided in a building if it is not properly installed and ready to perform its intended

function.

The International Green Construction Code (IgCC) contains provisions for commissioning that include the

envelope of the building.  Those are intended to ensure that the components associated with the

envelope are installed in such a way that they can perform their intended function.  The commissioning

of the building thermal envelope is the next logical step in enhancing the value of the IECC.  As

previously noted, why require something in the code if there is no activity to make sure it is properly

installed and can perform its intended function?  This is a reasonable minimum requirement for all

buildings, not just green buildings.

This proposed code change is modeled on the provisions in the IECC for mechanical system

commissioning, the envelope‐related provisions in the IgCC, and the criteria in Section C402 of the IECC

that are considered important to ensure that the building thermal envelope will perform as intended

and, as such, addressed in any commissioning activity.

As with the provisions in Section C408.2 of the 2012 IECC for mechanical systems, the proposed change

provides criteria for development of a commissioning plan, a report on commissioning, acceptance of

the report, documentation, and then a final report.  Also included in proposed Section C408.2.2 are

those items covered in Section C402 that are considered important to address in a commissioning

activity (foundation wall moisture control, flashing and sealing against the elements, protection against

intrusion of water, snow and ice, protection of exposed insulation, proper installation and operation of

shading devices, and confirmation that air leakage issues have been addressed).  

Cost Impact:  There is a cost impact associated with this proposed change to the degree that the

commissioning activity is not now being performed anyway and would now have to be performed and
documented.  There should also be a decrease in costs to the degree that such commissioning reduces

the burden on state and local government in enforcement of the code as commissioning serves to

ensure and document compliance with the code.  Moreover, the operation and maintenance costs of a

building that is so commissioned would logically be less than one that is not commissioned.  Without

commissioning to ensure the code‐required insulation and infiltration reduction systems are in place,

the cost effectiveness of other energy code provisions is in jeopardy.  A study of 643 commissioned

building in 26 states found that new building commissioning had a median payback of 4.2 years

(http://cx.lbl.gov/2009‐assessment.html).