To help address California’s massive housing demands, state law was amended to streamline the approval process for Accessory Dwelling Units (ADU’s). The new, simpler process stimulated a surge of interest in ADU’s for income properties and extended family housing, which subsequently sparked new models for project delivery, including “pre-approved” or “permit-ready” construction drawings.
Whether developed by private design firms or offered free to the public by building departments, pre-approved plans help property owners with affordable, quick turnaround solutions at the front counter. However, the Title 24 Energy Code can gum up the process unless some detailed attention is given to both the Title 24 report and HERS measures, specifically for registration of the Title 24 documents.
Setting the Baselines: A typical process
The typical process for energy code compliance on a new construction residence is to have an architect design the home and hire an Energy Consultant as part of the design team. The Energy Consultant prepares the project’s CF1R (Title 24 Part 6 document) and registers with either CalCERTS or CHEERS, the two approved registries, to receive the watermarked copy. A watermarked copy is required for a building permit.
During construction, the homeowner or contractor will hire a HERS Rater to test and verify the project-specific HERS verifications. The HERS Rater will access the project that has been uploaded to the registry to complete their CF2R and CF3R compliance documents. The building inspector must then confirm that the compliance documents have been completed. The HERS documents must be completed in the registry in order to receive a certificate of occupancy.
Potential gaps for pre-approved drawings
An initial gap for the over-the-counter or purchased ADU sets is making sure they come with a compliant Title 24 for the climate zone and orientation of the project. Most companies and jurisdictions have remediated the gap by having Title 24 compliance forms completed for the design in all relevant climate zones and orientations, making it usable wherever the project’s site is located.
Another gap is that these projects still need to be registered with the actual project address, must receive the watermarked Title 24 report, and must have the project created in the registry so that the HERS Rater is able to complete their work.
If an owner or builder misses this step, they may not be aware of the required HERS measures. and the inspector reviewing the HERS requirements will not be able provide the final certificate because the project does not exist in the registry. Many of the HERS verifications must be completed at construction milestones (e.g., insulation), so the project team risks reopening finished work, failing aspects, and/or requiring the Title 24 to be redone with different compliance measures. Since the Title 24 is part of the purchased package for the generic floor plan, but is not pre-prepared for the specific project, there isn’t typically an Energy Consultant available; the homeowner would need to hire a consultant and start from scratch.
Have a Plan in Place
Potential strategies to address these gaps may include:
- Include an energy consultant on staff or on call to finalize the Title 24 documents for the specific address and upload the project to the registry;
- Develop a list of local consultants who are familiar with the ADU process and could be available to support Title 24 registry and/or HERS verification;
- Provide a Fact Sheet to the Builder or Owner when they pull the plans, outlining the process for hiring their own consultant and HERS Rater.
Whatever strategy is selected, having a process in place for registering each unique project will help private companies and building departments support their customers and continue successful ADU construction throughout our region. If you’d like to discuss ways to develop strategic options specific to your department, email info@3c-ren.org.
Specific ADU energy requirements will vary. The Energy Code views ADUs differently depending on if it’s a conversion or new construction. For additional information, see our prior blog: https://www.3c-ren.org/adus-and-solar
For more information and in-person trainings, please check out our events calendar at 3c-ren.org/calendar-of-events-and-trainings
The on-demand webinar page is at 3c-ren.org/on-demand-trainings
And feel free to reach out to the Code Coach Hotline for more information or to have your questions answered! 3c-ren.org/energy-code-coach
