CALGreen, GreenPoints, and Title 24 – What’s the Deal?

CALGreen, GreenPoints, and Title 24 – What’s the Deal?

Posted on 31. May, 2011 by in Technical

California’s Green Building code went into effect this last January, and recently we had questions from another residential designer about CALGreen – how’s it different from GreenPoint Rating, how does it fit in with Title 24 energy standards, how it works. To answer his questions, I read through the code manual. In addition to the CALGreen code book itself, there’s a very handy cheat sheet that compares CALGreen, GreenPoints, and LEED, for low-rise residential projects. (This version’s probably a little out of date, being from 2010, but you get the idea.) The Q&A below is based partly on that conversation, with special thanks to Doug Hensel of the California Department of Housing and Community Development, who reviewed a draft of this article.

What is the intention of CALGreen?

To reduce environmental impact through better planning, design and construction practices. CALGreen addresses energy, water, material use, and environmental quality (mainly indoor toxicity and comfort).

How is CALGreen structured?

CALGreen is organized into chapters for residential and non-residential buildings. Within each of these, there are mandatory measures that apply  statewide, and voluntary measures, that can be adopted by local building departments.

  • Mandatory measures, in Chapters 4 and 5, apply to everyone statewide
  • Voluntary measures, located in the Appendices, have two tiers with prerequisite and elective measures
    • Tier 1 Prerequisites are a grouping of measures which set the base for that tier.
    • Tier 2 Prerequisites include all of Tier 1, plus some enhanced or additional measures.
    • Electives are an a la carte collection of additional measures not included elsewhere.

Each tier lists additional prerequisite measures that are mandatory in order to achieve that tier, plus a specified minimum number of electives. Sounds complicated, but it does allow for more flexibility.


California’s new Green Building code, which went into effect this past January, has a flexible, multi-tiered approach with both mandatory and elective measures.

What is the rationale behind CALGreen’s tiered requirements?

Voluntary tiers are just that: voluntary. Local authorities can adopt these tiers, thus making them mandatory – in that location only. There’s a note that local building officials can grant exemptions to these tiers in individual cases, in the case of “practical difficulties”. The tier concept was developed in order to allow some of the more progressive jurisdictions to go beyond the code minimum, while still maintaining a level of consistency throughout the state.

What parties, interests, or types of experts were involved in CALGreen’s creation and formulation?

Participants and stakeholders include various California state agencies, as well as model code organizations, building officials, and representatives from the construction industry, the environmental community, the green building industry, and the design community.  BuildItGreen, the private consortium that came up with the GreenPoint Rated system, is not named as a contributor to CALGreen in the official code book, but it can’t be coincidence that many measures are almost identical between GreenPoints and CALGreen.

Who owns CALGreen?

CALGreen is published by the Building Standards Commission, although they don’t determine all of the content by themselves. For residential projects, the CA Department of Housing and Community Development has the primary role in developing the regulations. Various other agencies are charged with determining CALGreen requirements based on the type of occupancy. The Building Standards Commission has the primary role in developing the green building regulations for non-residential projects with the exception of certain types of buildings such as public schools and hospitals.

How does CALGreen fit into other code requirements?

CALGreen goes along with all the other California building codes and standards: Building, Electrical, Mechanical, Plumbing, Fire, and Energy. Apparently CALGreen trumps them in places where they might differ. In general “the most restrictive requirements shall prevail.” Similar to these other codes, local agencies have a lot of freedom to make specific amendments to the CALGreen code – those amendments apply only within that jurisdiction.

Is CALGreen now mandatory everywhere in CA? Are there guidelines for its applicability to different types of projects (eg remodels vs new construction, etc)?

Yes, it’s now the law. Applicability is by major type of construction, for example low-rise residential vs hospital. Both the HCD and the BSC have guidelines on their web sites providing further assistance.

How will CALGreen be enforced? I see things like “Construction Materials Protected From Moisture Damage” which means frequent site inspections during construction. Who is in charge of enforcing it, and at what points in the project?

Local building officials and inspectors.

How does Title 24 energy compliance fit into CALGreen?

California’s “green building” code goes beyond energy performance to encompass all sorts of things like reduced construction waste, water conservation, non-toxic sealants, renewable materials, etc. By contrast the California energy standard (also known as Title 24, Part 6) is primarily on promoting more energy-efficient buildings, and only considers the fixed infrastructure: building envelope, heating and cooling, water heating, some lighting restrictions. So it’s more limited in scope than “green building” or “sustainability”. It’s one thing for a design client to say “I want it to be green” and quite another for them to decide HOW that will be accomplished. Creating energy-efficient buildings is part of green building, but green building encompasses a lot more than direct energy usage.

One thing to note about CALGreen is that the upper tiers insist on exceeding Title 24 by either 15% or 30%. That can be a huge “gotcha” if your house has a lot of glass.

These levels coincide with other energy incentives that are currently available. In any case, don’t wait until the day before submittal to run your Title 24 report. In order to beat Title 24 at all, you have to use the energy modeling method – which asks for specifics about things like mechanical systems, windows, and insulation. Beating Title 24 is getting harder and harder, often requiring additional tests and material substitutions. It’s not last-minute stuff.

Why does CALGreen want 15% over Title 24? Isn’t Title 24 already the code? How can a code require exceeding the code?

You will need a MENSA level IQ to understand the reasoning, but it looks like the California Energy Commission and the Department of Housing and Community Development are quibbling over the meaning of “green building”. So, CALGreen says meet Title 24, but the CEC (which develops the California energy code) thinks that the term “green building” should only apply to buildings that exceed Title 24 by 15% or more.

When people ask me how a building code can exceed itself, I feel like I need a MENSA-level IQ. Suffice it to say that different parts of the same overall building code can differ.

Another example of “code that exceeds the code” is water use. CALGreen has a mandatory measure saying that residential water use has to be 20% below the maximum allowable by the California Building Standards Code. It’s enough to drive one mad. The good news is that there will more work for code consultants, potentially reducing unemployment.

How do the following agencies (BSC, HCD, and CEC) interact in terms of exerting authority? Is one a subsidiary of the other or are they independent agencies?

State agencies are given various authorities by the California legislature. Similar to laws of Congress – once that law is passed, it’s out of the hands of the lawmakers, the mandate goes into the hands of the state agencies to interpret, then implement, this mandate. Then, local government enforces it. For CALGreen, local officials review the code to make determinations for each specific project and circumstance. Energy efficiency is a subsidiary or detail portion under overall CALGreen, but neither the Department of Housing and Community Development nor the Building Standards Commission has the authority to set mandatory energy policy in California. The CALGreen code doesn’t spell out the energy standards in detail; that is deferred to the California Energy Center. However, the BSC must approve all energy regulations adopted by the CEC prior to publication.

Do the residential requirements apply to remodels?

No. CALGreen only applies to newly constructed buildings. The definition of “newly constructed” does not include additions, alterations, or repairs.

How was it determined which items ended up in the CALGreen code and which were omitted?

The overall approach is to make it incremental, but state the long-term goals as well. This gives people a chance to learn the new ways and adapt, but they can see farther ahead and go beyond the requirements if they want.

Today’s futuristic dream is tomorrow’s baseline. For example, the CEC has a goal of all new homes being Net Zero by 2030. If you tried to enforce that one today, no one would be ready – costs would be prohibitive, and there would be a shortage of qualified designers and builders with the know-how to make it work. But, by incrementally tightening energy requirements, it gives time for new solutions and methods to be developed and tested.

Are there requirements for habitat conservation?

One area that seems to be omitted from CALGreen, and largely from GreenPoints as well, is overall habitat conservation where the natural state of the site is left pristine and undisturbed, as in a nature preserve. This would fall under construction (to build carefully and not destroy any more habitat than was necessary) and also under site planning. The closest both these systems come is a topsoil conservation feature, and some items about low-water landscaping with native species. GreenPoints does have points for unspecified “innovations”.

CALGreen says that it doesn’t want to restrict innovation, but there are no specifics. I think they’re deferring detailed habitat rules to local jurisdictions. CALGreen does have a completely voluntary site selection guideline encouraging the re-use of previously developed sites, which would promote the same goals.

What is the difference between CALGreen and GreenPoints?

CALGreen is a mandatory code, and it’s statewide law, with mandatory measures and additional prerequisites by tier. GreenPoints is 100% voluntary, unless a local jurisdiction decides to require it. The concept of “GreenPoint Rated” doesn’t exist in CALGreen. There’s no such thing as “CALGreen Rated”. Either you meet the requirements set forth in CALGreen at the level set by your local authority, or you don’t.

GreenPoint Rating encourages a project to achieve the highest score possible through the inclusion of a mostly voluntary list of electives. There are a few “required” items, but most of it’s discretionary. A local jurisdiction can require all projects to be GreenPoint Rated, and to meet a minimum score, but they usually don’t say beyond that which electives you must use. This allows a lot of flexibility.

The idea of GreenPoint Rating is that there’s some level of follow-up during construction by a certified independent GreenPoint Rater to verify that the measures are being followed correctly. In fact, you can’t complete the rating process until the house is completed. This makes the score more credible. CALGreen requirements, like other code requirements, are enforced by local building authorities at various points in the project: permit submittal, various inspections during construction for things like foundation, electrical, and final inspection.

Both GreenPoint Rating and CALGreen could be used during initial planning stages as an idea generator for someone who wanted a “green” project but didn’t know how to go about it. It seems that GreenPoints would be a little better for this – it goes more beyond the minimum, and is more specific in some areas, particularly landscaping. Working directly with a GreenPoint Rater as a consultant during initial planning stages can help identify which GreenPoint features are most acceptable, desirable, and feasible.

The GreenPoint Rated system is a bit more specific about water conservation measures available for landscaping. It’s not only water use, but whether plants are “native” that counts.

We haven’t mentioned LEED that much, but the LEED certification process also involves a special LEED certified consultant. It’s been criticized as being too expensive and cumbersome for single family residential projects. GreenPoints does add some cost for the consultant, but it’s a lot more reasonable.

Why do we need CALGreen if we already have GreenPoints, or vice versa?

Good question, especially if you’re building in a town that requires both GreenPoint Rating and some of the CALGreen voluntary tiers. I would guess that GreenPoint Rating was a bit quicker to develop, not being so encumbered by bureaucratic process, and it served as a warm-up to incent people to move ahead. GreenPoints is a good road map – the measures are simpler to understand, and clearly written.

Doug Hensel of the HCD rephrased this a bit more diplomatically, “CALGreen is mandatory in all cities and counties, and will thus capture many more buildings than GreenPoints alone. Contrary to GreenPoints, CALGreen is developed using protocols set forth in the Building Standards Law, which require an open and transparent process of public vetting and participation.”

How can a designer or homeowner reduce confusion if their project requires both CALGreen and GreenPoint Rating?

Best thing would be to work with a consultant who’s got dual credentials in both CALGreen training and as a GreenPoint Rater, and involve this person early in the project. They’re not the project manager, though. That would probably be either the owner, the designer (if used), or the builder.

Selecting a good builder is important – and not just going with the lowest cost bidder, either. Get someone who’s already bothered to get a Green Builder certification without being forced into it. If the project involves a licensed architect, the architect should also be familiar enough with local codes to stay within them. It helps if the major parties are already experienced with local issues, including working with the local building department.

How does the energy standard set forth in Title 24 fit into GreenPoint Rating?

GreenPoint Rating also has a mandatory requirement of exceeding Title 24 by 15% or more. Local authorities seem to have two levels of GreenPoint adoption. The first level requires a GreenPoint Checklist at submittal time, showing which features are included in the design. It’s for informational purposes only. The second level requires full GreenPoint Rating, and sometimes a minimum GreenPoint score. This is harder to do, and involves a lot of verifications – including beating Title 24 by 15%.

Again, plan ahead – check with the local building department that has authority over the project, and find out what all their green requirements are. Are they requiring any CALGreen tiers above the mandatory minimums? Are they using the GreenPoint Checklist? Do they require each project to be fully GreenPoint Rated? Do these requirements apply differently based on the project itself, i.e, its size? What other green building requirements do they have? There is no escape from reading the fine print, but we hope that it’ll make a bit more sense now, after reading this article.


I’d sent a draft of this article to Doug Hensel at the Department of Housing and Community Development for comment, not really expecting any response, but he called me right away and sent me a commented version. I incorporated most of his comments (but kept the comment about bureaucracy). He also pointed me to the page containing ALL the CALGreen documents: the CALGreen code itself, a user-friendly guide to CALGreen for low-rise residential buildings, and a slew of CALGreen compliance forms and worksheets for everything from construction waste management to finish flooring materials.

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