Comments on Washington report.
Opposition to the training and certification proposal has been largely based on misinformation. The April article perpetuates this misinformation by incorrectly reporting that the proposal would "prohibit engineers, commissioning agents, and other licensed professionals from performing acceptance tests...." To the contrary, the proposal would require individuals who perform acceptance testing to obtain certification and qualify themselves as competent to perform the test.
A report conducted by PECI (Evaluation of Title 24 Acceptance Testing Enforcement and Effectiveness--September 2011), demonstrates that the Commission's acceptance test requirements are not being properly performed by persons who have not been specifically trained to conduct these assessments. Regulations currently allow anyone to conduct these assessments regardless of training, knowledge or competency. TABB, NEBB and AABC have the infrastructure and ability to address the challenges of providing verification of comprehensive building system knowledge for technicians, supervisors and engineers.
Relying on the existing TAB industry to provide certification for acceptance testing just makes sense. After all, the TAB industry was created to meet similar needs back in the 1960s when architects and engineers needed qualified people to verify system performance to design.
Erik S. Emblem, Associate Member ASHRAE, Sacramento, Calif.
Mark Hydeman Responds
I was a lead author of the mechanical requirements and mechanical acceptance tests in California's Title 24, Part 6 Standard for both the 2005 and 2008 versions. Over the years I have provided dozens of trainings on these tests through public educational programs provided by the utility companies, for design build firms at in-house lunch and learns and, ironically, several times for the California and Hawaii NEBB Annual Member Recertification meetings. Although I am clearly qualified to teach these tests, and have run them on dozens of projects, under a proposal forwarded by the sheet metal contractors and electrical unions I would not be qualified to perform these tests in the future.
In January 2012, Commissioner Karen Douglas of the California Energy Commission received nearly identical letters from State Senator Christine Kehoe and Assembly Member Felipe Fuentes urging the Commission to require that "all HVAC related acceptance testing and documentation be performed by Testing, Adjusting and Balancing (TAB) technicians certified by the Associated Air Balance Council (AABC), National Environmental Balancing Bureau (NEBB) or the Testing Adjusting and Balancing Bureau (TABB)...." Further, both letters urged the Commission to require "all advanced lighting control related acceptance testing and documentation to be performed by California State certified general electricians who are also certified by the California Advanced Lighting Controls Training Program (CALCTP), and who are performing the work while employed by a California licensed C-10 electrical contractor who holds a CALCTP contractor certification ..."
A workshop was held at the California Energy Commission on Feb. 27, 2012, to take input on these proposals. Letters were submitted on both sides of this issue and are posted on the CEC website at: http://tinyurl.com/ct9wkah. This includes the original letters from the State Senator and Assembly Member. The opposition to these proposals included many consulting engineers, commissioning agents, design build contractors and Cal SMACNA. On the mechanical side the opposition letters had a common theme that these proposals would limit many qualified personnel from performing these tests simply because they were not certified by NEBB, AABC or TABB.
ASHRAE did not take an official stand on this issue. An email was sent to alert ASHRAE members in California to this issue, with a link to the CEC website where they could get more information on the workshop and proposals. Many ASHRAE members responded and their responses can be found at the link above. Although I support the underlying issues of improving enforcement by the building departments and providing training for individuals who are performing these tests, I opposed these proposals both in my written responses and at the workshop as they would limit the very small pool of people who actually know the requirements and have performed these test. Having a NEBB certification clearly doesn't make one qualified to perform these tests: the instructor wasn't NEBB certified.
Mark Hydeman, P.E., Fellow ASHRAE, Alameda, Calif.