This past Monday, I went to an all-day Title 24 class with CABEC and didn’t fall asleep once! There were a few eye-openers worth sharing, since we’ve already been trumpeting the endless “Change is coming!” for months.
Title 24 has grown from a minor paperwork requirement into a PROCESS, with more forms, more steps, and more people involved. Bifurcating bureaucracy… what a surprise!
The Cliff Notes version is roughly:
- Title 24 documentation will become more expensive to do.
- And take four times as long.
- It will be harder to get your projects to pass.
- You’ll have more people to coordinate.
- Massive confusion first 6 months.
But the kicker? All of this depends entirely on how it’s enforced by local building departments.
So, what should design professionals be doing over the next 6 months?
Submit any upcoming projects before January 1 if you can.
Next, prepare your clients. They should expect that after January 1, the Title 24 process will become noticeably longer and it will be harder to meet the standards. The impact on the building may be substantial. Owners must choose their contractors wisely, because there is more onus on the builder now to cooperate with the Title 24 process all the way through the project.
This in turn will make it more challenging to make changes after certain decisions are made, particularly to core systems or overall sustainability goals. In addition, owners must plan ahead to qualify for the various incentives that are still available.
As a designer, you may need to educate the builder as well. The general contractor has a lot more forms to fill out now, including what used to be the old kitchen lighting form. Actions taken by the builder can end up having more of an impact, because the new Title 24 has an increasing emphasis on inspection, rather than simply relying on claims made on the initial proposed energy calculations. This means the builder needs to be conversant with Title 24, so they understand how their actions can have an impact on the process.
For example, there’s a credit for attic venting, i.e., using more vents and placing them in the proper spots. Either the architect needs to detail it exactly, or otherwise communicate to the builder that a compliance credit is being claimed for one or more of those building features. Builders must know the implications of field substitutions for things like roof shingles. The expanded credits for Cool Roofs means that only roofing products labeled as certified by the Cool Roof Rating Council are allowed. Since many manufacturers are now making Cool and non-cool versions of the same product, it’s extremely important to stick with certified products if a Cool Roof compliance credit is claimed.
In general, there is an increased need for coordination among the project team: designers, energy consultants, builder, subs, HERS raters, and other special inspectors all have to be apprised of changes. even those made very far down the road.
Finally, prepare yourself to design for the 2008 standards in 2010.
- Certain decisions must be made much earlier, at permit stages (heating, ventilation, windows, roof)
- Architect must specify everything a lot sooner down to the product detail level.
- Pay more attention to specifying only products approved or certified (rated windows, cool roofs, fire-rated products where required)
- Provide a lighting plan showing wattages and low/high efficacy fixtures for the builder so that project is built and lighting is documented as intended
- Pay more attention to efficient design for ductwork, pipes, and ventilation.
- Field substitutions will be more cumbersome, and may trigger another round of reporting if the new product labeling has different energy performance ratings than the old one.
- More reports to process
- It’ll be a lot harder to use metal framed windows and it’ll be harder to source them.
- Don’t treat the building’s energy performance as an afterthought. The day before a big permit submittal is not the time to find out that the house will need major system changes in order to pass.
What did people care about in the class?
Everyone asked over and over again about the new registration process. The upside is, we think it’ll work fine, but no one’s been able to test the process end to end yet.
No you don’t need to register every single project with a HERS provider – unless the project requires onsite HERS inspection. Progressively stricter energy codes will most likely require more verifications – it’s possible that most or all of the Title 24 projects that come through Green Compliance Plus will trigger one HERS inspection or another.
We spent considerable time in class on the whole-house ventilation requirement. A ventilation systems expert explained in great detail the different types of ventilation systems available and which ones were preferable. I’ll write a separate post on some of that information, very worthwhile.
Lighting requirements weren’t that different but LEDs have a place now, and there’s a way to “buy” additional incandescent watts for the kitchen by adding extra dimming and vacancy sensor controls. Which you already need to have anyway. Internal kitchen cabinet lighting is exempted. The old kitchen lighting form is gone, and is now part of the builder’s CF-6R form. (Another update on LEDs coming soon)
Some considerations apply only to production homes. There are details about HERS sampling and other such items, very relevant to builders and developers.
Everyone will have to pay close and constant attention to local green building ordinances, which may require exceeding Title 24. But then again, so do many incentive programs, so you might as well design for that 15% over. Local green building ordinances are NOT legally enforceable until they have been approved by the CEC.
There were some interesting possibilities in Marin County, which seem aimed at discouraging the construction of larger homes unless those homes are super-efficient. As far as I know, none of this has been enacted, but it’s under discussion. If all 12 Marin jurisdictions buy into this, then these would be in force throughout Marin County.
- Homes over 2,500 SF have to beat Title 24 by 15%
- Homes over 5,000 SF have to beat Title 24 by 30%
- Homes over 7,000 SF must be Net Zero Energy
About the author
Rebecca Firestone has been working in the Bay Area since 1998 as a technical writer, business content developer, architectural filing lady, marketing director, and sorcerer’s apprentice.