Title 24 compliance is one of the most frequently misunderstood requirements in California construction permitting. It is mandatory for virtually all projects, it cannot be deferred to a later submittal, and building departments will not approve a permit application without it. Understanding what it requires and how it fits into the permit process prevents one of the most common sources of application delays.
What Title 24 Is
Title 24 is Part 6 of the California Code of Regulations, also known as the California Energy Code. It sets minimum efficiency standards for lighting, heating, cooling, water heating, and building envelope performance for new construction and certain alterations.
The code is updated on a two-year cycle and applies to all conditioned space in residential and nonresidential buildings. The current code is the most demanding version yet, reflecting California's ongoing push toward zero-net-energy construction.
What Requires Title 24 Documentation
Title 24 applies to:
- All new residential construction, including ADUs and JADUs
- Additions to existing residential buildings
- Residential alterations that add or replace HVAC, water heating, or lighting systems
- All new commercial construction
- Commercial tenant improvements that affect conditioned space
- Projects that add conditioned square footage to existing commercial buildings
It does not apply to minor repairs, like-for-like replacements that do not change the system configuration, or unconditioned structures like open carports and storage sheds.
If you are unsure whether a specific project requires Title 24, the answer is almost always yes. When in doubt, prepare the documentation.
What a Title 24 Compliance Package Contains
A Title 24 compliance package is prepared by a certified energy consultant using compliance software. The California Energy Commission approves the software tools used for compliance demonstration. The output is a set of compliance forms that document how the proposed building meets the code requirements.
For Residential Projects
A residential Title 24 package typically includes:
- CF-1R form: Project summary, climate zone, and compliance method
- CF-2R form: Installer certificate documenting how energy features will be installed
- CF-3R form: Field verification and diagnostic testing requirements
- Supporting energy calculations for the building envelope, HVAC system, water heating, and lighting
The compliance is calculated using either the prescriptive method (all components meet minimum specified values) or the performance method (the building as a whole meets an equivalent efficiency target). Performance compliance offers more flexibility for projects where prescriptive requirements are difficult to meet.
For Nonresidential Projects
Commercial Title 24 packages are more complex and typically include:
- Building envelope compliance documentation
- Lighting power density calculations
- HVAC system efficiency documentation
- Automatic controls and occupancy sensor requirements
- Energy monitoring requirements for larger buildings
How Title 24 Fits Into the Permit Set
Title 24 documentation is submitted alongside the architectural drawings as part of the permit application. The architectural drawings reference the compliance forms, and the compliance forms must match the building configuration shown on the drawings.
This coordination matters. If the HVAC system shown on the drawings differs from what the compliance report modeled, or if insulation values on the drawings differ from what the energy consultant specified, the plan checker will flag the inconsistency. The drawings and the Title 24 package need to be reviewed together before submittal to confirm they match.
The CF-2R installer certificates become field documents after permit issuance. The contractor is required to document that the installed systems match what was modeled in compliance. The CF-3R lists any field verification or diagnostic testing required before the building department will sign off on final inspection.
Common Issues That Delay Approval
Not submitting Title 24 with the application. Building departments will not deem a California permit application complete without Title 24 documentation. If the application is submitted without it, it will be returned as incomplete before plan check even begins.
Compliance documentation that does not match the drawings. Mismatches between the energy model and the architectural drawings are flagged during plan check and require both the drawings and the compliance package to be revised and resubmitted.
Prescriptive compliance with non-compliant components. If prescriptive compliance is used, every component must meet the minimum specified value. A single non-compliant element requires either a design change or a switch to performance compliance modeling.
Failing to update Title 24 after design changes. When the architectural design changes after the initial compliance run, the compliance package needs to be re-run to reflect the updated configuration. Submitting an outdated compliance report is a common source of plan check corrections.
How CADTRI Coordinates Title 24
CADTRI coordinates Title 24 documentation as part of every permit package for California projects. We work with certified energy consultants to ensure the compliance report is prepared alongside the architectural drawings, matches the proposed design, and is ready for submittal with the first application package.
If your project is in California and you need a permit set, request a proposal and we will confirm the energy compliance requirements for your specific project type and jurisdiction.