Last Updated: July 15, 2025
Over the last five years, the greater Boston area has made long-term building sustainability a priority. While there is no single solution to create a sustainable community, there are several measures that can be taken to reduce the negative impact of built environments. The desire to mitigate these negative impacts is a shared long-term goal of both sustainable building and commissioning. Building commissioning benefits such as energy use reduction, material efficiency (through prolongation of equipment and building lifecycles), and improved occupant health and comfort enhance sustainable building practices in addition to satisfying local sustainability requirements.
Within construction and building operations alone, sustainability casts a wide net from rainwater management, energy reduction, and even solutions to local sustainability issues. The US Government, through Energy Star and organizations such a United States Green Building Council (USGBC), Passive House Institute US (PHIUS), and Enterprise Community Partners, are creating standardized guidelines in sustainability for the built environment. This is great news for local governments who may not want to divert valuable resources and time to research and outline every detail desired to make their cities and towns sustainable. Instead, they can focus on specific requirements each municipality finds valuable to their community and apply the sustainability guidelines that best fit their city or town.
In recent years, Boston, Newton, Cambridge, and Somerville have introduced (or, in Boston’s case, reiterated) sustainability goals for construction in their cities. In fact, Boston, Newton, and Cambridge have all adopted building emission reduction policies in a commitment to reduce their environmental impact from pollutant and greenhouse gas emissions. As of November 2024, a total of 297 out of Massachusetts’ 351 cities and towns have opted in to the Green Communities program led by the Massachusetts Department of Energy Resources (DOER). DOER subsidizes the implementation of energy-efficiency measures, renewable energy projects, or other strategies to reduce municipalities’ fossil fuel energy consumption.
With the rapid growth in the building sustainability field, it can be difficult to stay informed of changes and requirements buried in city ordinances, addendums, and updates. As of June 6, 2025, the information below highlights the commissioning requirements of building codes and ordinances for the four cities in the Boston area and Massachusetts state buildings that currently have such requirements. It should be no surprise that over the coming years, more municipalities will introduce sustainability requirements for both new and existing buildings.
Sustainability Organizations
Fundamental Commissioning (Required)
Requirements
Comply with ANSI/ASHRAE/IES Standard 90.1 commissioning requirements for building systems, controls, and the building envelope, with the following additional provisions:
- All projects shall provide fundamental commissioning. Section 4.2.5.2 exceptions shall not apply.
- The referenced version of Standard 90.1 with errata shall be:
- 2019 or later for projects registered before January 1, 2028.
- 2022 or later for projects registered on or after January 1, 2028.
- By the end of the design development phase, the owner shall designate a commissioning provider (CxP) with experience completing commissioning on at least two projects of equal or larger scope and complexity.
- In addition to the requirements of the applicable version of ASHRAE 90.1, the CxP shall:
- In predesign or as early as possible, assist in the development of the owner’s project requirements (OPR), reviewing and updating the OPR through design and construction. OPR must include HVAC, service water heating, power, lighting, other equipment (include on-site renewable energy), and envelope.
- During design, review the basis of design (BOD) for compliance with the OPR, perform a design review of the project design, and attend at least one meeting focused on mechanical, electrical, and plumbing, and one focused on envelope, which may be separate or combined, to discuss review comments and commissioning.
Notes
One of the most significant changes, as discussed in the LEED v5 Updates article, is the inclusion of building envelope commissioning into the prerequisites for LEED certification.
Requiring owners to designate the CxP by the end of the design document (DD) phase and requiring even one design review can avoid complications later in the construction process, too.
Enhanced Commissioning (Additional Points)
Requirements
Path 1. Enhanced Commissioning for MEP systems (2 POINTS)
- Comply with ANSI/ASHRAE/IES Standard 202-2024, Commissioning Process, for mechanical, electrical, plumbing, control, data center, process, building monitoring, and renewable energy systems.
- Comply with the following additional requirements:
- During the design phase, attend at least two coordination/design meetings to discuss review comments and commissioning.
- Prior to or during occupancy, review the training materials to confirm that they meet the training plan, and confirm that the training occurred.
Path 2. Enhanced Commissioning for Building Enclosure (1 POINT)
- Comply with all tasks and deliverables referenced with ASTM E2947-21a, Standard Guide for Building Enclosure Commissioning, except Sections 7.2.4 and 7.4.3.
- Comply with the following field-testing requirements:
- Building air leakage testing, as per ASTM E783, ASTM E779, ASTM E1186, or ASTM E3158.
- Water penetration testing, as per ASTM E1105 or AAMA 501.2.
- Infrared imaging, as per ASTM C1153 or ASTM C1060.
Notes
Path 1, Enhanced commissioning for MEP systems, has been made significantly more achievable in the LEED update from v4.1.
Other sustainability programs also require some of the field tests listed in Path 2. This means that tests like the building air leakage testing may already be included in the project scope.
Monitoring-Based Commissioning (Additional Points)
Requirements
Path 1. Basic Software (1 POINT)
- Process and communications
- Commit to implementing MBCx for a minimum of three years, through a contract with an MBCx provider or qualified monitoring-based commissioning provider (MBCxP) staff person. MBCx shall commence no later than building occupancy and shall be fully coordinated between the commissioning provider, facilities management, and MBCxP.
- Develop a monitoring-based commissioning plan summarizing the process.
- Energy information system (EIS)
- Provide a remotely accessible platform with software functionality to perform smart analytics and visually present all metered data referenced in EAp4: Energy Metering and Reporting.
- In addition, provide hourly monitoring and visualization of electric energy use
Path 2. Enhanced Software (2 POINTS)
- Comply with Path 1 AND provide the following enhanced monitoring and software technology functionality:
- Fault detection and diagnostics (FDD) for projects with large HVAC or refrigeration capacity.
- Energy information system (EIS)
Notes
Monitoring-based commissioning provides continuous review of building systems. In addition to having a qualified MBCxP, the additional information available to facilities staff can help quickly determine system faults as they inevitably arise during a building lifecycle.
Fundamental Commissioning and Verification (Required)
Requirements
The commissioning authority (CxA) must do the following:
- Review the OPR, BOD, and project design.
- Develop and implement a Cx plan.
- Confirm incorporation of Cx requirements into the construction documents.
- Develop construction checklists.
- Develop a system test procedure.
- Verify system test execution.
- Maintain an issues and benefits log throughout the Cx process.
- Prepare a final Cx process report.
- Document all findings and recommendations and report directly to the owner throughout the process.
- Prepare and maintain a current facilities requirements (CFR) and operations and Maintenance (O&M) plan.
Notes
The fundamental requirements for LEED certification are commonly referenced by local jurisdictions as the standard for green and sustainable building. These fundamental commissioning requirements generally reflect the ASHRAE Guideline 0 (The Commissioning Process) with some omissions and additions.
It is important to note that for any commissioning requirements that require design reviews, BOD review, or OPR development, the Commissioning Provider should be introduced into the project during the design phase to ensure that these activities are completed with time for the design team to reflect in the construction documents.
Enhanced Commissioning (Additional Points)
Requirements
Various Enhanced Commissioning paths allow for additional credits:
Enhanced Systems Commissioning
- Review contractor submittals.
- Verify inclusion of systems manual requirements in construction documents.
- Verify inclusion of operator and occupant training requirements in construction documents.
- Verify systems manual updates and delivery.
- Verify operator and occupant training delivery and effectiveness.
- Verify seasonal testing.
- Review building operations 10 months after substantial completion.
- Develop an on-going commissioning plan.
Enhanced Systems Commissioning & Monitoring-Based Commissioning
- Achieve above enhanced systems commissioning and:
- Additional commissioning-focused designs including requirements for trend data
- Monitoring-based commissioning plan
- Operator training in trend data analysis
Envelope Commissioning
- Review contractor submittals.
- Verify inclusion of systems manual requirements in construction documents for enclosure systems.
- For specialty enclosure systems with controls and automation:
- Verify inclusion of operator and occupant training requirements in construction documents.
- Verify systems manual updates and delivery.
- Verify operator and occupant training delivery and effectiveness.
- Verify seasonal testing.
- Review building operations 10 months after substantial completion.
- Develop an on-going enclosure commissioning plan for maintenance, renewal and revitalization cycles.
Notes
It is tough not to advocate for the Enhanced Systems Commissioning and Envelope Commissioning paths, independent of the additional credits received. Valuable aspects of this credit have been moved to the fundamental commissioning prerequisite in v5, an acknowledgment that building envelope commissioning, design reviews, and more are important to creating healthy and sustainable buildings.
The Enhanced Systems Commissioning & Monitoring-Based Commissioning path can be extremely valuable for buildings with more robust systems, significant numbers of equipment, and several types of equipment (think hospitals and university campuses). Trend analysis and monitoring-based commissioning can reveal issues that develop within the systems that can go undiscovered for years.
For projects like small apartment complexes, this may not be as valuable though, admittedly, adequately completing the LEED requirements would be significantly less intensive.
LEED has several programs in addition to Building Design + Construction (BD+C), such as Interior Design + Construction (ID+C), Operations and Maintenance (O&M), and LEED Residential. The requirements for each of these LEED programs can be found on the United States Green Building Council (USGBC) website.
5.1b Building Performance Standards (Required)
Requirements
Conduct commissioning for compartmentalization, insulation installation, and HVAC systems:
- Compartmentalization – testing of air infiltration into dwelling units
- Insulation – review of insulation installation based on climate zones and manufacturer guidelines
- HVAC – complete testing via an approved checklist from ENERGY STAR
Notes
These three requirements are the baseline to ensure energy is not wasted. These standards are a good start to create an efficient and sustainable building.
8.1 Building Operations & Maintenance Manual and Plan (Optional)
Requirements
The Building Operations & Maintenance Manual and Plan shall include:
- O&M guidance for all mechanical and electrical equipment and appliances (building level and dwelling unit level)
- HVAC specifications, and O&M schedules
- Refrigerant management
- Operations, maintenance, and replacement guidance for any other specialized systems (e.g., solar photovoltaics, solar water heating, ground source heating, cogeneration systems) within the project along with evidence of training completed for these systems
- Location of mechanical, electrical, gas, and water-system turnoffs
- Lighting equipment specifications and replacement guidance
- Landscaping and hardscaping specifications and maintenance plan, including any specific instructions for community gardens or growing spaces
- Green cleaning product specifications and cleaning schedules
- Integrated pest management protocol
- Maintenance of active recreation and play spaces (e.g., playgrounds, ground markings, exercise equipment)
- If the project is a multifamily building with either a cooling tower or a centralized hot water system, or is more than 10 stories in height, also include the Legionella water management plan developed via Criterion 4.3.
- Protocol for reviewing and responding to utility data consumption information
- An occupancy turnover plan that describes the dwelling unit turnover protocol, including all materials that are frequently replaced at turnover
Notes
Often O&M manuals and O&M plans (sometimes called preventative maintenance manuals) are not reviewed until they are needed, years after construction is completed, leaving vulnerability to missing information, excess information for systems that don’t apply to the specific facility, or as-built documentation that does not reflect the installed systems.
Having someone with competent knowledge of the installed systems reviewing these documents can prevent headaches when building systems begin to need more than just basic maintenance.
1.5.2 Multifamily Residential Projects (Required)
Requirements
Multifamily projects must complete ENERGY STAR MFNC (Multifamily New Construction) Checklists
Notes
Many local jurisdictions have commissioning-specific requirements in addition to PHIUS as there are so many tasks beyond functional testing that ensure buildings are healthy and sustainable not just through construction, but throughout the building lifecycle.
ENERGY STAR MFNC Checklists
Requirements
According to energystar.gov, the checklists must be completed by qualified individuals, which are mostly commissioning professionals with exceptions for specific sections of the checklists. These sections may be completed by qualified contractors and Original Equipment Manufacturer (OEM) Representatives.
Notes
Frequently referenced in sustainability programs, these checklists attempt to standardize the functional testing process. A good commissioning provider will go above and beyond these checklists as, although it is a good baseline, no system is the same and to achieve optimized building efficiency and operation, system-specific testing is the most effective method.
State and Local Requirements
The Massachusetts LEED Plus 2.0 Standard for New Construction, a part of Executive Order 594, was made effective in 2021 and last updated on June 20, 2024.
LEED Plus 2.0 Standard
Requirements
All state buildings over 20,000 square feet must be LEED Silver Certified or higher.
Notes
LEED “Certified” means that all the project will be submitted to the United States Green Building Council (USGBC) to receive the certification after the project completes all prerequisites, document submittals, and needed optional paths are satisfied.
BOSTON NEW CONSTRUCTION
Article 37 was originally inserted in 2007 and updated in 2024 to include a Climate Resiliency-Review Policy Update.
Boston Zoning Code Article 37-4 Green Building Requirements
Requirements
Any Proposed Project subject to the provisions of this article shall be LEED Certifiable under the most appropriate LEED building rating system.
Notes
LEED “Certifiable” means that all LEED prerequisites must be met and additional points achieved to meet LEED Certification standard, which is the lowest LEED credit.
MOH Design Standards (housing)
Requirements
All new construction projects must be designed to be LEED “certifiable” at the Silver level at minimum
Notes
LEED Certifications range from Certified to Platinum. Each step on the LEED scale requires a certain number of points through LEED’s optional credits, such as Enhanced Commissioning or Monitoring Based Commissioning
BOSTON BERDO
It is important to highlight the Building Emissions Reduction and Disclosure Ordinance, which requires commercial buildings to participate if they are greater than 20,000 square feet, residential buildings with at least 15 residences, or tax parcels with multiple buildings that sum to at least 20,000 square feet or 15 units. Starting in 2025, Boston will be requiring third-party verification of reported data by a commissioning provider or similar (a full list of approved qualifications can be found on the website, including a list of qualified professionals).
City of Boston Code, Ordinances, Chapter VII, Section 7-2.2, (h) Data Verification
Requirements
In the Building’s first year of reporting after this Subsection is enacted, Building Owners shall provide a third-party verification of their reporting data for the previous year. For every Verification Year thereafter, Building Owners shall provide a third-party verification for the five calendar years prior, but not including, the current year. Verifications must be performed by qualified Energy professionals, as defined by the Regulations, and submitted no later than the reporting deadline of the relevant year.
Notes
According to the Reporting How-To Guide, third party verification is required from 2025 and later. Third party verification of energy and water use, Renewable Energy Certificates (RECs), Power Purchase Agreements, and any additional CO2e (CO2 equivalent) factors is required and will be required every 5 years for applicable commercial and residential buildings, and every year for City buildings.
Emission requirements can be found in section (i) of the same section of ordinances with all building types having zero CO2e by 2050 with the fines for failing to submit or achieve the emissions reductions in section (r).
In 2023 Cambridge city council passed an amendment including Article 22.20 – Green Building Requirements.
22.23.1 Rating Programs
Requirements
Major new projects must comply with Leadership in Energy and Environmental Design (LEED), Passive House (PHIUS), or Enterprise Green Buildings rating systems.
Notes
Each rating system has slightly different requirements for commissioning. All require standard commissioning as required by ASHRAE Guideline 0: The Commissioning Process, typically with some additional requirements.
22.24.2 Green Commissioning
Requirements
The Owner of property on which a Green Building Project is proposed shall engage a Green Commissioning Authority as defined in Article 2.000 of this Zoning Ordinance to verify and document that all building systems and assemblies are planned, designed, installed, tested, operated, and maintained to meet the applicable Green Building Project requirements.
Notes
The sustainability requirements for 22.24.2 are the same requirements for Enhanced MEP Commissioning path from LEED v4.1. This means a project in Cambridge pursuing LEED is already required to achieve the Enhanced Commissioning points on the LEED scorecard.
Updated Newton City Ordinances in 2022 included several items, below are the commissioning-specific items.
5.13.4, A Sustainable Design Requirements
Requirements
A green building project must comply with Leadership in Energy and Environmental Design (LEED), Passive House (PHIUS), or Enterprise Green Buildings rating systems.
Notes
Each rating system has slightly different requirements for commissioning. All require standard commissioning as required by ASHRAE Guideline 0: The Commissioning Process typically with some additional requirements for additional sustainability benefits.
5.13.6 Building Permit Submittal Requirements
Requirements
B.1: Credentials of the Green Building Project’s Green Commissioning Agent
Notes
Submission of documentation with documented experience of at least 2 projects extending from early design phase through at least 10 months of post-occupancy.
5.13.6 Building Permit Submittal Requirements
Requirements
C.1: An affidavit signed by the Green Commissioning Agent, certifying that the pre-construction commissioning process requirements of the applicable Green Building Rating Program have been met and that the post-construction commissioning process requirements of this Section were included in the scope of work and will be met, including a schedule of when each commissioning requirement was or will be met.
Notes
The CxP will provide a legal document prior to the Certificate of Occupancy indicating that items including within the commissioning scope of work have been completed or that post-occupancy commissioning activities will be complete by estimated dates. These deliverables are determined by the sustainability program as well as any additional commissioning services.
The January 2, 2022 Somerville Zoning Ordinance states the requirements for sustainability programs in Somerville.
Somerville Zoning Ordinance 8.4, 8.a.i
Overlay Districts
Requirements
Laboratory buildings must be LEED Platinum Certifiable
Notes
Lab building commissioning is not only important for energy efficiency, but occupant safety. Engaging a commissioning provider with experience in commissioning and operation of laboratory systems such as building and space pressurization and fume hood exhaust systems is highly recommended independent of LEED certification.
Somerville Zoning Ordinance 8.4, 8.a.ii.c
Overlay Districts
Requirements
Master Planned Development Districts (except labs) and projects seeking residential density bonus by meeting Net Zero Ready standards must satisfy either PHIUS+ or the International Future Living Institute (ILFI) Zero Carbon sustainability programs.
Notes
PHIUS requires commissioning through the Energy Star program.
IFLI does not require commissioning as the emissions and energy use design requirements for the project in question. What is required is a 12-month performance period proving that the energy consumption design has been met. The period does not need to start directly after the building is occupied but if MEP and envelope commissioning are included in the project, the risk of failing the 12-month performance period requirements would be significantly reduced.
Somerville Zoning Ordinance 10.10.1
Sustainable Development
Requirements
a.: New construction or modification of any principal building type greater than twenty five thousand (25,000) square feet in gross floor area must be LEED Gold certifiable.
b.: New construction or modification of any principal building type greater than fifty thousand (50,000) square feet in gross floor area must be LEED Platinum certifiable.
Notes
While MEP and Building Envelope Commissioning are LEED prerequisites, Enhanced Building Commissioning and Monitoring-Based Commissioning are all optional paths for additional points.
About the Author:
Will Belke is a Commissioning Engineer serving SES’s Massachusetts and Rhode Island projects. His expertise spans system and whole building commissioning projects, with a keen eye for ensuring high performance and sustainability standards are met. Will is a LEED Accredited Professional and Certified Energy Manager.