Residential Mechanical Alterations: Recommendations for ...that “Heating, Ventilation, and Air...

California Energy Commission

CONSULTANT REPORT

Residential Mechanical Alterations: Recommendations for Building Departments to Improve Energy Code Compliance

California Energy Commission Edmund G. Brown Jr., Governor

September 2017 | CEC-400-2018-003

Prepared for: California Energy Commission Prepared by: Center for Sustainable Energy


Primary Authors:

Lindsey Hawes Marissa Spata

Center for Sustainable Energy 9325 Sky Park Court, Suite 100 San Diego, CA 92123 858-244-1177 www.energycenter.org Contract Number: 400-09-024

Prepared for:


Dan Johnson Contract Manager Joe Loyer Judy Roberson Project Managers William Dietrich Manager EXISTING BUILDINGS AND COMPLIANCE OFFICE Dave Ashuckian Deputy Director EFFICIENCY DIVISION Robert P. Oglesby Executive Director

DISCLAIMER

This report was prepared as the result of work sponsored by the California Energy

Commission. It does not necessarily represent the views of the Energy Commission, its

employees, or the State of California. The Energy Commission, the State of California, its

employees, contractors, and subcontractors make no warrant, express or implied, and

assume no legal liability for the information in this report; nor does any party represent

that the uses of this information will not infringe upon privately owned rights. This report

has not been approved or disapproved by the California Energy Commission nor has the

California Energy Commission passed upon the accuracy or adequacy of the information

in this report.

http://www.energycenter.org/

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ACKNOWLEDGEMENTS The following individuals and organizations collaborated in the development of this report.

Participating Jurisdictions: Survey

City of Anaheim

City of Burbank

City of Carlsbad

City of Chula Vista

City of Corona

City of Coronado

City of Costa Mesa

City of El Cajon

City of Encinitas

City of Escondido

City of Fontana

City of Fullerton

City of Garden Grove

City of Imperial Beach

City of Inglewood

City of Irvine

City of La Mesa

City of Lancaster

City of Long Beach

City of Moreno Valley

City of Murrieta

City of National City

City of Oceanside

City of Ontario

City of Orange

City of Oxnard

City of Poway

City of Rancho Cucamonga

City of Riverside

City of San Bernardino

City of San Diego

County of San Diego

City of San Marcos

City of Santa Clarita

City of Santa Ana

City of Santee

City of Simi Valley

City of Temecula

City of Thousand Oaks

City of Ventura

City of Victorville

City of Vista

Participating Jurisdictions: Working Groups

City of Beverly Hills

City of Carlsbad

City of Chula Vista

City of Coronado

City of El Cajon

City of Escondido


City of Lake Forest

City of Los Angeles


City of Murrieta

City of Rancho Cucamonga

City of San Diego

County of San Diego

Contributors

Accela, Inc.

Bay Area Regional Energy Network

California Contractors State License Board

Funders


Los Angeles County

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ABSTRACT From 2013-2016, the Center for Sustainable Energy (CSE) evaluated how local building

departments in Southern California process permits for residential mechanical system

alterations and recommended best practices for facilitating permit completion and improving

compliance with the Title 24, Part 6 Building Energy Efficiency Standards (Energy Standards).

The study began by administering a role-specific survey of public and private sector

stakeholders, followed by a series of in-person working group discussions with local

government personnel. After identifying common barriers to permit completion, CSE drafted

best practice recommendations and vetted them through local chapter meetings of

International Code Council members. These recommended four best practices involve local

government prioritization of resources to help building departments upgrade and streamline

their permitting process:

• Improve website information on permitting and HERS process • Prioritize online permitting • Hire Energy Standards specialists • Enable virtual inspections.

Keywords: California Energy Commission, residential, mechanical, alterations, change-outs,

Title 24, Part 1 and Part 6 Building Energy Efficiency Standards, compliance,

enforcement, Home Energy Rating System, local government, building department, chief

building official, building inspector, permitting, best practice, survey, Southern

California

Please use the following citation for this report:

Hawes, Lindsey, and Marissa Spata. 2017. Residential Mechanical Alterations:

Recommendations for Building Departments to Improve Energy Code Compliance.

Center for Sustainable Energy. California Energy Commission Publication Number: CEC-

400-2018-003.

iii

TABLE OF CONTENTS ACKNOWLEDGEMENTS ..................................................................................................................................... i ABSTRACT .......................................................................................................................................................... ii TABLE OF CONTENTS..................................................................................................................................... iii LIST OF FIGURES .............................................................................................................................................. iv LIST OF TABLES ................................................................................................................................................ iv EXECUTIVE SUMMARY ..................................................................................................................................... 1 CHAPTER 1: Background ................................................................................................................................. 5

Building Energy Efficiency Standards .................................................................................................. 5 Residential HVAC System Alterations ................................................................................................. 6 Role of the Home Energy Rating System ............................................................................................. 6 Nonpermitted Residential HVAC Alterations ..................................................................................... 8 Role of the Contractors State License Board ...................................................................................... 9 Role of the Homeowner ........................................................................................................................ 10 CSLB Consumer Affairs and Enforcement Resources.................................................................... 10 Building Department Enforcement .................................................................................................... 12 Statement of the Problem .................................................................................................................... 13

CHAPTER 2: Study Scope and Methods ..................................................................................................... 15 Stakeholder Survey ............................................................................................................................... 15 Building Department Working Groups and Discussion ................................................................ 19 ICC Chapter Feedback .......................................................................................................................... 19

CHAPTER 3: Survey and Working Group Results .................................................................................... 21 Implementation and Enforcement ..................................................................................................... 21 Building Department Resources......................................................................................................... 22 Permit Applicant Resources ................................................................................................................ 23 Building Department Processes ......................................................................................................... 25 Permitting Barriers ................................................................................................................................ 28

CHAPTER 4: Best Practice Recommendations ......................................................................................... 31 1: Improve Website Information on Permitting and HERS Process ............................................ 31 2: Prioritize Online Permitting ............................................................................................................ 33 3: Hire Energy Standards Specialists ................................................................................................. 34 4: Enable Virtual Inspections .............................................................................................................. 36 Summary ................................................................................................................................................. 37

GLOSSARY, ABBREVIATIONS ....................................................................................................................... 39 APPENDIX A: Permit Compliance Survey Results ..................................................................................A-1 APPENDIX B: Residential HVAC Alteration Permit Compliance Resources ...................................... B-1 APPENDIX C: Example ICC Scorecard ....................................................................................................... C-1

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LIST OF FIGURES

Figure 1: Local Permitting Process for Residential HVAC Alterations .................................................. 8 Figure 2: CSLB Permit Noncompliance Complaints and Citations ...................................................... 10 Figure 3: Number of Survey Responses by Jurisdiction in Southern California .............................. 16 Figure 4: Number of Survey Respondents by Role ................................................................................. 17 Figure 5: Responses to Survey Questions 13 and 14 ............................................................................. 21 Figure 6: Response to Survey Question 15 ............................................................................................... 22 Figure 7: Responses to Survey Question 25 ............................................................................................. 23 Figure 8: Responses to Survey Question 26 ............................................................................................. 23 Figure 9: Information Most Commonly Provided on Building Department Websites ..................... 24 Figure 10: Responses to Survey Question 31 ........................................................................................... 25 Figure 12: Responses to Survey Question 26 ........................................................................................... 28 Figure 14: Responses to Survey Question 7 ............................................................................................. 29 Figure 15: Responses to Survey Question 10 ........................................................................................... 30

LIST OF TABLES

Table 1: 2013 Title 24, Part 6 Requirements for HVAC Alterations in Existing Homes .................... 7 Table 2: CSLB HVAC Ambassador Program Fact Sheet: Do It Right! .................................................. 11 Table 3: Description of Survey Participant Roles .................................................................................... 18 Table 4: ICC Scorecard Results: Clear Website Information ................................................................. 32 Table 5: ICC Scorecard Results: Online Permitting ................................................................................. 34 Table 6: ICC Scorecard Results: HERS Raters as Third-Party Inspectors ........................................... 35 Table 7: ICC Scorecard Results: Virtual Inspections .............................................................................. 37

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EXECUTIVE SUMMARY

California’s Global Warming Solutions Act (Assembly Bill 32, Núñez, Chapter 488, Statutes of

2006) set a national precedent for addressing human causes of global climate change by

requiring the reduction of statewide greenhouse gas (GHG) emissions to 1990 levels by 2020. It

designated the California Air Resources Board (CARB) as the lead agency for coordinating a

Climate Action Team consisting of other state agencies, including the California Energy

Commission. AB 32 covers all aspects of the state’s economy and stimulated a series of

legislation and policies designed to integrate GHG reductions in major market sectors:

buildings, industry, agriculture, and transportation.

Existing residential buildings are a major target of California’s regulatory and policy goals to

increase energy efficiency and reduce GHG emissions. Assembly Bill 758 (Skinner, Chapter 470,

Statutes of 2009) required the Energy Commission to develop a comprehensive program to

implement energy savings and GHG emission reductions in the state’s existing residential and

nonresidential buildings.

The California Public Utilities Commission’s (CPUC) California Energy Efficiency Strategic Plan

Update (January 2011) announced four “Big Bold Energy Efficiency Strategies.” One strategy was

that “Heating, Ventilation, and Air Conditioning (HVAC) would be transformed to ensure that its

energy performance is optimal for California’s climate.” It also set more a specific goal to

increase energy efficiency in the HVAC sector by 50 percent by 2020. Additional goals included

(1) “consistent and effective compliance, enforcement, and verification of HVAC-related

building and appliance standards,” and (2) “quality installation and maintenance becomes the

industry and market norm.”

California’s Title 24, Part 6 Building Energy Efficiency Standards (Energy Standards) establish

minimum energy performance criteria for new construction and upgrades to existing buildings.

They also stipulate the process for ensuring Energy Standards compliance, in which local

building departments issue‒ and eventually close ‒permits for new buildings and alterations

that trigger Energy Standards requirements.

Residential forced-air conditioning systems are a major component of peak electrical demand,

and the related energy efficiency is significantly degraded by poor installation practices.

Therefore, the Energy Standards require third-party field verification and diagnostic testing in

addition to building department inspection. It is difficult for new construction projects to

bypass the permit compliance and enforcement process, but it is common for changes to HVAC

systems in existing homes to bypass the permit process. The industry estimates that only 10

percent of alterations to existing residential mechanical systems are permitted.

Permitting is a prerequisite for Energy Standards compliance documentation and is critical to

achieving California’s goals to improve the energy efficiency of HVAC systems in existing

buildings. However, even (the estimated 10 percent of) HVAC system alterations that are

permitted do not always complete energy compliance verification and documentation.

In 2013, with funding from the federal American Recovery and Reinvestment Act program, Los

2

Angeles County contracted with the Center for Sustainable Energy (CSE) in Southern California

to:

• Describe current practices for permitting HVAC system alterations in existing homes.

• Identify barriers to permit completion and Energy Standards compliance verification.

• Recommend best practices for local governments to simplify completion of permits.

CSE began by developing a role-specific online survey of permit process stakeholders, including

building department staff, HVAC contractors, and Home Energy Rating System (HERS) Raters.

Sixty-eight percent of 124 survey respondents were building department staff. The six counties

surveyed – Los Angeles, Orange, Riverside, San Bernardino, San Diego, and Ventura – include 54

city and county jurisdictions, of which 78 percent are represented. Appendix A lists all survey

questions, their target audience, and compiled responses.

The survey’s regional scope and low private sector participation limits the ability to broadly

extrapolate from these results. However, valuable information was obtained, for example:

• In order of priority, building departments need additional resources for (1) public

education, (2) enforcement of permitting requirements, and (3) field inspection staff.

• Homeowners who avoid pulling permits were more concerned about the additional time

required than the additional cost involved with permitting.

• According to HERS Raters and HVAC contractors, the top three barriers to pulling

permits were:

o Costs to the contractor.

o Complexity of Energy Standards compliance forms.

o Public understanding of the need for permitting and compliance verification.

In the fall of 2014, CSE discussed survey results and potential best practices for improvement

with local government staff (chief building officials, permit technicians, plans examiners,

building inspectors, and planners) during a series of in-person working groups. During these

activities, CSE developed four best practice recommendations for building departments to

improve permitting and Energy Standards compliance for residential HVAC system alterations:

1. Upgrade building department websites to provide organized and user-oriented

information about the Energy Standards requirements for HVAC system alterations and

the benefits of permitting.

2. Provide all-online permitting of nonplan-reviewed projects that trigger the Energy

Standards, particularly residential heating, ventilation, and air-conditioning (HVAC)

system alterations.

3. Consider hiring or contracting with HERS Raters to (a) conduct field verification and

diagnostic testing of residential HVAC system alterations, and (b) after obtaining

appropriate International Code Council certification(s), conduct final building

inspections.

3

4. Minimize the time and cost associated with building department inspections by enabling

inspectors to remotely guide contractors in real-time video inspections of completed

work.

Implementing any of these would require local governments to acquire additional resources.

From August 2015 to January 2016, CSE presented and discussed these recommendations at six

regional International Code Council (ICC) chapter meetings, during which building department

staff were asked – via a one-page “ICC Scorecard” questionnaire – to indicate the likelihood of

their building department adopting each recommendation. Appendix C provides an example

ICC Scorecard, and those collective responses are summarized in Chapter 3: Results.

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CHAPTER 1: Background

The California Building Standards Code is Title 24 of the California Code of Regulations. The 12

sections (or Parts) of the regulations govern the structural, electrical, mechanical, and plumbing

systems of buildings in the state, in addition to establishing minimum fire-safety and life-

safety, energy efficiency, historical building, green building, and accessibility measures. The

California Building Standards Commission (BSC) updates each section roughly every three

years. Title 24, Part 1 – Administrative Regulations, specifies permitting and enforcement

processes to ensure overall building compliance, and Title 24, Part 6 – Building Energy

Efficiency Standards (Energy Standards) establish additional processes for energy efficiency

compliance.

Building Energy Efficiency Standards Since California implemented its first building energy code in 1978, it has been a leader in

establishing cost-effective, climate-specific building energy efficiency measures for minimizing

energy waste. The California Energy Commission regularly updates minimum efficiency

requirements for new residential and nonresidential buildings and energy-related alterations to

existing buildings.

In addition to the Energy Standards, the California Public Utility Commission’s (CPUC)

California Long Term Energy Efficiency Strategic Plan (2008, with 2011 update) (strategic plan)

set goals for all newly constructed residential buildings to achieve zero net energy (ZNE) by

2020 and for all new nonresidential buildings to achieve ZNE by 2030. The strategic plan also

calls for transforming the residential heating, ventilation, and air-conditioning (HVAC) industry

to one that ensures that the energy performance of residential HVAC systems is optimal for

California’s climate.0F

1

Achieving the state’s building energy efficiency goals requires upgrades of existing buildings as

well as new building construction. Assembly Bill 758 (Skinner, Chapter 470, Statutes of 2009)

requires the Energy Commission, CPUC, and other stakeholders to develop a comprehensive

program to improve the energy efficiency of existing buildings. The resulting Energy

Commission’s Comprehensive Energy Efficiency Program for Existing Buildings (2012) states,

“There is no realistic path to achieving the state's aggressive energy efficiency targets and

carbon emissions goals without… large-scale improvements to the existing building stock.”1F

2 A

1 CPUC. Strategic Plan Update. 2011. http://www.cpuc.ca.gov/general.aspx?id=4125.

2 California Energy Commission. Comprehensive Energy Efficiency Program for Existing Buildings. 2012 http://www.energy.ca.gov/ab758/.

http://www.energy.ca.gov/ab758/

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key aspect of improving energy efficiency among existing homes is verifying that central HVAC

system replacements comply with the Energy Standards.2F

3

CSE’s report focuses on local building department processes for ensuring that alterations (also

called change-outs or replacements) to central HVAC systems in existing homes comply with the

Energy Standards, and identifies several strategies that can be used to improve compliance.

Residential HVAC System Alterations The Energy Standards require that additions, alterations, and repairs to existing homes meet

current codes. Requirements for residential HVAC alterations are similar to those for newly

constructed residential buildings. The equipment itself (gas furnace, air-conditioner, heat

pump) must meet federal minimum appliance efficiency standards and be properly sized to

meet the calculated heating and cooling loads of each building. In addition:

• The central system must be connected to a programmable setback thermostat.

• Refrigerant (coolant) lines must be properly charged and insulated.

• Leakage of altered or replaced ductwork must be within 15 percent of total system airflow, in cubic feet per minute, or cfm.

• For systems with replaced ductwork, cooling coil airflow must be at least 350 cfm/ton.

• In some cases, the power draw of the air handler fan must not exceed 0.58 Watt/cfm airflow.

Municipal (city or county) building departments are responsible for inspecting buildings to

ensure that HVAC system alterations comply with the Energy Standards. However, specific

performance metrics that require diagnostic testing must be verified by third-party Home

Energy Rating System (HERS) Raters.

Role of the Home Energy Rating System California’s HERS compliance process for residential HVAC alterations is separate from but

supplemental to the building departments’ compliance enforcement process. Each version of

the Energy Standards updates the energy measures that require HERS field verification and

diagnostic testing (FV&DT). In 1999, the Energy Standards began requiring HERS FV&DT, and it

became mandatory in all 16 California climate zones for alterations permitted after January 1,

2010.

3 “Residential HVAC” nominally includes mechanical ventilation, but the term typically refers to – and this report is limited to - central forced-air heating and air-conditioning systems.

7

Table 1: 2013 Title 24 Requirements for HVAC Alterations in Existing Homes

Source: CalCERTS, Inc. 2014 – V20140706

For example, Table 1 shows a simplified version of the HERS FV&DT criteria for residential

HVAC alterations that meet the Energy Commission’s definition of a minimally compliant

system.3F

4

California HERS FV&DT is performed by a HERS rater that is certified by an Energy Commission-

approved HERS provider according to requirements in the HERS Regulations.4F

5 For residential

HVAC alterations that are submitted to a building department, the installing mechanical

contractor typically applies for a permit and hires a HERS rater, who performs the appropriate

FV&DT and uploads completed HERS compliance documents to the HERS provider’s data

registry, which the building department can access.

The cost of HERS FV&DT of residential HVAC alteration usually ranges from $250 to $300 per

system, but prices vary among HERS raters. If an HVAC alteration project is submitted as part

of a multi-dwelling sampling group, the cost of FV&DT per system can be significantly lower

(subject to HERS sampling protocols that specify additional testing in cases of failures).

Figure 1 summarizes the typical permitting process for residential HVAC alterations.

4 California Energy Commission. Building Energy Efficiency Standards - Residential Compliance Manual. 2013. http://www.energy.ca.gov/title24/2013Standards/residential_manual.html.

5 HERS (Home Energy Rating System) Regulations. 2009. California Energy Commission.

http://www.energy.ca.gov/title24/2013standards/residential_manual.html

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Figure 1: Local Permitting Process for Residential HVAC Alterations

Source: Center for Sustainable Energy

The Energy Commission relies on local building departments and HERS Raters to ensure

compliance with the Energy Standards and associated energy savings in existing buildings.

However, local jurisdictions are responsible for enforcing all parts of the Title 24 Building Code

(including structural, electrical, mechanical, plumbing, and accessibility) – not just the Energy

Standards (Part 6). With limited time and resources, building department personnel are not able

to identify the (large majority of) contractors and homeowners who fail to apply for (or “pull”)

permits for residential HVAC system alterations. Therefore, their ability to enforce the Energy

Standards is limited to projects for which the contractor or homeowner pulls a permit.

Nonpermitted Residential HVAC Alterations This report refers to HVAC system alterations that do not receive permits as “nonpermitted

activity.” Statewide estimates are that 9 out of 10 HVAC alteration projects in existing homes

do not receive permits; 5F

6 therefore, neither the individual and collective energy performance of

these projects can be evaluated, nor the related compliance with the Energy Standards verified.

Nonpermitted residential HVAC system alterations are a missed opportunity for statewide

energy savings and greenhouse gas reductions. Nonpermitted systems are estimated to use 30

6 CPUC, California Energy Commission. 2010-2012 HVAC Action Plan. 2011

-Applicant registers HVAC system with HERS Provider; secures CF-1R-ALT with registration number.

-Applicant completes and submits permit application to building department; includes registered CF-1R-ALT.

-Counter tech reviews documentation and issues permit.

-Contractor installs system; completes and registers CF-2R-ALT Certificate of Installation.

-HERS rater performs FV&DT; completes, registers and signs CF-3R-ALT Certificate of Verification.

-Building inspector performs inspection for complete code compliance (energy efficiency and other Title 24 sections); verifies passing, registered, signed CF-3R-ALT Certificate of Verification; issues "PASS" and closes permit.

9

percent more energy than HVAC alterations that undergo the permitting process.6F

7 The Energy

Commission estimates that these nonpermitted alterations represent 130 megawatts of peak

electricity demand annually.7F

8 They are also a liability for homeowners and residents in terms of

potentially higher operating costs, reduced thermal comfort, and real estate property

devaluation resulting from alterations that were not permitted.

Role of the Contractors State License Board

The Professional and Vocational Regulations of Title 16, Division 8, Articles 1-8 of the

California Code of Regulations requires that anyone who bids on or performs work that meets

or exceeds $500 (labor and materials) must be licensed by the California Contractors State

License Board (CSLB).

Residential HVAC installers must obtain a C-20 Warm-Air Heating, Ventilation, and Air-

Conditioning Contractors license and maintain their license in “good standing” by performing

work legally and adhering to local permitting requirements.8F

9 A June 2010 letter issued by the

CSLB to C-20 contractors explains that if a licensed contractor fails to obtain a permit (for

HVAC installations and modifications), disciplinary action may include civil penalties of up to

$5,000 per citation and suspension or revocation of his or her license.9F

10 Thus, C-20 licensed

contractors who perform work for which there is no valid building permit are violating the law

and may face CSLB disciplinary actions, which can include:

• Administrative action and hearings.

• Fines up to $5,000; typically $500-750 for a first citation.

• An order of correction requiring payment of permit fees and any assigned penalties

imposed by the local building department.

• Suspension or revocation of license.

According to the CSLB Consumer Affairs Department, in 2010 the CSLB received only 82

complaints of contractors performing work without a building permit. In July 2011, the CSLB

unanimously voted to make HVAC permit enforcement a high priority by instituting a zero-

tolerance policy on HVAC permit violations in which contractors found guilty of performing

work without a permit are penalized on the first offense. Before that, contractors received only

a warning for their first permit violation.

After prioritizing enforcement in 2011, the CSLB saw a large increase in both complaints and

subsequent citations issued. In 2014 and 2015 combined, they received 564 complaints of

7 Ibid.

8 California Energy Commission. Strategic Plan to Reduce the Energy Impact of Air Conditioners. 2008. http://www.energy.ca.gov/2008publications/CEC-400-2008-010/CEC-400-2008-010.PDF.

9 As defined in California Code of Regulations, Title 16, Article 3. CCR Title 16, Division 8, Article 3, §832.20.

10 California Energy Commission. CSLB Permit Enforcement Letter. 2010. http://www.energy.ca.gov/title24/2008standards/changeout/documents/C-20_Permit_Enforcement_Letter.pdf.

http://www.energy.ca.gov/2008publications/CEC-400-2008-010/CEC-400-2008-010.PDF

http://www.cslb.ca.gov/About_Us/Library/Licensing_Classifications/C-20_-_Warm_Air_Heating_Ventilating_And_Air_Conditioning.aspx

http://www.energy.ca.gov/title24/2008standards/changeout/documents/C-20_Permit_Enforcement_Letter.pdf

10

270 294 254

222

2014 2015

# of Compliants # of Citations Issued

nonpermitted activity; about 85 percent of those complaints were determined to be citable, and

all of those received penalties.

Figure 2 shows the number of complaints received for nonpermitted activity in 2014 and 2015;

94 percent and 76 percent of these, respectively, received citations. According to the CSLB,

HVAC alterations are the largest category (roughly 25 percent) of nonpermitted activity.10F

11 This

corresponds to about 64 citations and penalties issued in 2014 and 56 in 2015. In 2016, CSLB

staff discussions were underway to increase fines for first-time offenses.

Figure 2: CSLB Permit Noncompliance Complaints and Citations


Role of the Homeowner

Home and building owners also have a responsibility in the permitting of HVAC alterations but

often do not understand their role in or the long-term value of obtaining building permits.

Like contractors, homeowners often want to avoid the time and cost involved with permitting

and inspections and do not understand or appreciate the longer-term value of hiring a licensed

contractor and pulling permits, which triggers HERS FV&DT of HVAC systems. However, owners

are legally responsible for permitting any additions or alterations to their property. In

California, most jurisdictions require a building permit for replacing or altering HVAC systems.

Failure to pull a permit can result in a legal violation or “flag” being placed on a property, which

can complicate a future home sale or homeowner insurance claim. Owners also risk financial

liability for poor quality work from contractors that are unlicensed, unskilled, o r unaware of

code requirements. Furthermore, many jurisdictions double (or triple) permit fees for

nonpermitted activity that has been reported, cited, and subsequently enforced.

CSLB Consumer Affairs and Enforcement Resources

In addition to license enforcement, the CSLB conducts outreach and education for licensed

contractors and consumers. Its website includes resources that emphasize the importance of

hiring a licensed contractor and the legal and ethical responsibilities of licensed contractors.11F

12

11 Interview with CSLB Consumer Affairs Department staff, January 29, 2016.

12 CSLB Guides and Publications for Consumers, http://www.cslb.ca.gov/About_Us/Library/Guides_And_Publications/.

http://www.cslb.ca.gov/About_Us/Library/Guides_And_Publications/

11

In 2014, the CSLB launched the HVAC Ambassador Program, which provides information on

proper installation of HVAC systems by C-20 contractors. It also advises consumers to obtain

competitive contractor bids and permits for HVAC projects.12F

13

Table 2 is an excerpt from an HVAC Ambassador Program Fact Sheet, which explains the value

of these practices and the energy efficiency benefits associated with quality installation.

Table 2: CSLB HVAC Ambassador Program Fact Sheet: Do It Right! RIGHT CONTRACTOR

Job Done Correctly

WRONG CONTRACTOR

Potential Risks

Hire a licensed contractor in good standing with the CSLB to

ensure recourse through the CSLB Complaint Process. “Check

the License” at www.cslb.ca.gov or by calling 800-321-2752

Hiring an unlicensed contractor or a licensed contractor not

in good standing may results in a poor or incomplete

installation and limits your ability to seek financial redress.

Be sure the contractor carries workers’ compensation insurance

when using employees so you won’t be financially responsible

for injuries sustained on the job.

Using a contractor who does not carry workers’

compensation insurance may subject you to liability for the

costs of medical care and rehabilitation for any worker(s)

injured on your property.

Obtain a building permit so the building department can confirm

proper installation through an inspection.

Forego a permit and there will be no third-party inspection

of the work and you may be charged fines and penalties.

Ensure that ducts are properly sealed and insulted to realize

energy savings of up to 20%.

Improperly sealed and insulated duct systems leak,

decreasing heating and cooling efficiency.

Receive a final inspection to confirm that your HVAC system is

operating properly to yield energy savings – up to 300% over the

life of the equipment.

HVAC units not subject to final inspection may reduce your

system’s efficiency by up to 30%.

Source: Contractors State License Board

The CSLB offers several online tools for building department staff and consumers to check a

contractor’s license status, report unlicensed activity, and identify previous violations. The

CSLB also maintains full-time Enforcement Representatives and a Statewide Investigative Fraud

Team (SWIFT) that responds to consumer complaints. Both efforts are designed to curb illegal

activity and promote the value of code compliance and permitting. The perceived lack of

enforcement for contractors who bypass the permit process is a long-standing problem.13F

14

Wider enforcement of CSLB requirements, combined with consumer educational campaigns like

the HVAC Ambassador Program, can reduce the rate of nonpermitted HVAC alterations.

Ultimately, the risks for contractors and homeowners who avoid licensing and permits must be

demonstrated to tangibly outweigh any perceived benefits of permit avoidance.

The CPUC’s Strategic Plan to Reduce the Energy Impact of Air Conditioners set a goal to increase

the permit compliance rate for residential HVAC alterations from (the industry estimated) 10

13 CSLB HVAC Ambassador Program WEB page, http://www.cslb.ca.gov/Contractors/HVAC_Ambassador_Program.aspx.

14 Pennington, William G. Underground Economy: Contractors Failure to Pull Permits for Residential HVAC Replacements. 2014. Testimony to the Little Hoover Commission. http://www.lhc.ca.gov/studies/226/March%20Testimony/Pennington%20Testimony.pdf.

http://www.cslb.ca.gov/

http://www.cslb.ca.gov/Contractors/HVAC_Ambassador_Program.aspx

http://www.lhc.ca.gov/studies/226/March%20Testimony/Pennington%20Testimony.pdf

12

percent to 90 percent by 2020.14F

15 Also, the Energy Commission’s 2016 Existing Buildings Energy

Efficiency Action Plan set a goal to develop a baseline Energy Standards compliance rate for

residential HVAC alterations by 2018, and to raise that compliance rate to 80 percent by

2021.15F

16

This report focuses on identifying best practices that building departments can use to improve

the Energy Standards compliance of permitted residential HVAC alterations. However, it also

describes barriers that discourage potential applicants from pulling permits, and suggests

opportunities for promoting a more comprehensible applicant-oriented permitting process.

Building Department Enforcement Part 1, Article 1, Section 10-103 of the Energy Standards requires installing contractors to pull

permits and abide by the enforcement agency’s requirements for HVAC system alterations.

Building department staff is responsible for reviewing permit applications, issuing permits,

reviewing plans (for projects that require plans) to verify inclusion of code requirements, and

physically inspecting building projects for completeness and conformity with all applicable

building codes. Each jurisdiction charges applicants fees to cover the cost of permitting.

Building department personnel are responsible for different parts of the permitting process.

Permit technicians (or counter technicians) initially review permit applications and determine

whether all required documentation has been provided by the applicant. If so, they issue a

permit; if not, they inform the applicant and request that they resubmit the necessary

documentation. Residential HVAC alterations usually do not require submittal of detailed

construction plans, but if so, they are reviewed by a plans examiner who identifies any missing

or conflicting details and requests corrections or clarifications until the plan review is

complete.

For HVAC alterations, after a permit is issued, the contractor completes the work, a HERS Rater

conducts FV&DT, and building inspectors are supposed to ensure that the system meets (or

exceeds) all applicable requirements. When the project passes final inspection, the permit is

closed, and the energy compliance documents are retained for the building department and

HERS Provider’s records.

While the overall permitting process is standardized by statewide administrative code, each

jurisdiction has its own method for classifying or categorizing permits and setting permit fees.

For example, it would be difficult (at best) to accurately determine the number of residential

HVAC alteration permits statewide annually, not only because each department classifies them

differently, but because individuals in each department classify similar permits differently.

15 CPUC. California Energy Efficiency Strategic Plan (January 2011 Update), http://www.cpuc.ca.gov/general.aspx?id=4125.

16 California Energy Commission. 2016 Existing Buildings Energy Efficiency Action Plan. http://docketpublic.energy.ca.gov/PublicDocuments/16-EBP-01/TN214801_20161214T155117.

http://docketpublic.energy.ca.gov/PublicDocuments/16-EBP-01/TN214801_20161214T155117

13

Local governments typically establish fees based on cost recovery, resulting in, on average, up

to $250 for a residential HVAC alteration permit.16F

17 Energy efficiency is a priority for many

stakeholders, but building departments in general, and building inspectors in particular, tend

to prioritize verification of life-safety measures over Energy Standards requirements. This is

partly because they have many projects to inspect and a small window of time at each site to

verify all code requirements. In addition, as the Energy Standards become more complex, it

becomes more difficult for building professionals to navigate and understand the Energy

Standards. As a result, state and local governments increasingly rely on HERS raters to confirm

that residential HVAC alterations comply with the Energy Standards. Energy compliance

documentation for HVAC alterations consists of three forms:

1. Permit applicants complete a CF-1R Certificate of Compliance form, with applicable

Energy Standards requirements, and submit it electronically to a HERS Provider

Registry.

2. The installing contractor or other responsible party completes a CF-2R Certificate of

Installation form stating that the installation complies with applicable Energy Standards

requirements, and submits it electronically to the same HERS Registry.

3. The HERS Rater performs applicable FV&DT, completes a CF-3R Certificate of

Verification form, and submits i5 to the same HERS Provider Registry.

Before final inspection by the building department, building inspectors consult the appropriate

HERS Registry to verify that the HERS Rater has completed and uploaded the CF-3R form. They

should also compare entries on the installation certificate (CF-2R) to those on the compliance

certificate (CR-1R) to confirm compliance with Energy Standards requirements that are not

HERS verified.

Statement of the Problem California has established a building permitting process designed to ensure that residential

HVAC alterations, which are a significant target for energy and peak electrical demand savings,

comply with Energy Standards requirements. In practice, however, these savings are often not

realized, for several reasons. Besides the estimated 90 percent of such projects that bypass the

permitting process altogether, many of those that are permitted do not always complete the

HERS FV&DT and compliance documentation process required for permit completion.

For example, many HVAC contractors do not contract in advance with a HERS Rater. Instead,

after the alterations are installed, contractors leave it to homeowners to schedule (and pay for)

HERS FV&DT, even though homeowners are not aware of the permit process, the need for HERS

FV&DT and final building inspection, or their own responsibility for permit completion.

It is beyond the scope of local building departments (and this report) to address the pervasive

problem of nonpermitted residential HVAC alterations. Instead, this study identifies best

17 Survey questions 56 and 57, Appendix A.

14

practices that building departments can use to improve the rate of Energy Standards

compliance among permitted residential HVAC alterations.

15

CHAPTER 2: Study Scope and Methods

The main phase of this study was implemented in three phases over a 14-month period from

October 2013 through November 2014 in six Southern California counties: Los Angeles, Orange,

Riverside, San Bernardino, San Diego, and Ventura. The target audience is primarily building

department personnel but also includes local government planners, residential HVAC

contractors, independent permit service providers, and HERS Raters.

The three phases consisted of:

1. Administering an online survey designed to characterize existing permit processes and

general approaches to Energy Standards compliance for residential HVAC alterations.

2. Sharing survey results with working groups of local government staff to discuss barriers

to and strategies for improving Energy Standards compliance documentation.

3. Identifying and vetting best practices that jurisdictions can use to generate a more

applicant-oriented permitting process and increase Energy Standards compliance.

Stakeholder Survey CSE developed and administered an online survey targeting residential HVAC permitting

stakeholders on both sides of the permit process (private sector applicants, local government

personnel, and third parties). Respondent groups included mechanical contractors, HERS

Raters, and independent permit service providers; local government planners; permit

technicians; plans examiners; building inspectors; and chief building officials (CBOs).

The survey was designed to present each respondent with, on average, 50 survey questions

specific to their role in the permitting process. At the time of CSE’s survey development, the

Bay Area Regional Energy Network (BayREN) conducted a similar survey in Northern California17F

18

and shared its survey questions and method with CSE in a cooperative effort to promote more

consistent data collection across the state.

CSE’s survey targeted 54 Southern California jurisdictions with the largest populations to

capture information on the largest number of residential HVAC alterations. This included all

San Diego jurisdictions, because that county expressed particular interest in and provided

supplemental funding for their collective participation. The resulting mix included jurisdictions

with large (≥ 250,000), medium (≤ 100,000), and small (≤ 50,000) populations.

Survey respondents included 104 local government employees from 42 of the 54 jurisdictions,

resulting in 78 percent of local governments being represented. Of the 90 contractors, HERS

18 BayREN’s survey focused on permitting processes for all measures triggering Energy Standards compliance, which included but was not limited to residential HVAC alterations.

16

Raters, and private permit service providers asked to complete the survey, 20 responded,

resulting in a 22 percent response rate from the private sector.

Figure 3 shows the geographic distribution of respondents by jurisdiction, and Figure 4 shows

the number of survey respondents by their role in the permitting process. Table 3 describes the

role of each permit participant in more detail. Appendix A contains the complete list of survey

questions, identifies the stakeholder roles targeted by each question, and presents the compiled

responses.

CSE’s survey was conducted in March and April 2014, near the end of the 2008 Energy

Standards code cycle, and before the 2013 Energy Standards took effect in July 2014. At that

point of the code cycle, stakeholders were presumably most familiar with 2008 Energy

Standards requirements.

Figure 3: Number of Survey Responses by Jurisdiction in Southern California


17


Figure 4: Number of Survey Respondents by Role

18

Table 3: Description of Survey Participant Roles

Source: BayREN Codes and Standards, 2013 Survey Report: Questions, Responses, Findings, and Recommendations,

Chief Building Official (CBO): A senior administrative, public-facing, supervisory, leadership position whose

responsibilities include managing building department activities within the broader context of city or county

government. Building officials work at the policy level with the city council or board of supervisors to ensure that the

client experience at the building department is satisfactory. He or she advises on permit process and classification,

including interpreting what types of permits are required, assigning fees to permits, permit review, and inspection

turn-around time and other issues. There is only one Chief Building Official per jurisdiction.

Building Inspector: A customer-facing position that generally requires International Code Council ( ICC)

certification as a building inspector and whose responsibilities include:

• Providing detailed information and answers to questions about building codes and Energy Standards.

• Field inspection of building activity to ensure compliance with the approved permit.

When assessing compliance with the Energy Standards, field inspectors must review CF-1R, CF-2R, and CF-3Rs.

Permit/Staff Technician: An administrative, customer-facing position whose responsibilities include managing

permit application payments and receipts, entering computer data, fielding customer questions, resolving

complaints, and verifying that all necessary documentation is provided with each permit application before accepting

and forwarding the application to other building department staff for technical review or inspection.

Planner:

The inclusion of planners in this survey is to identify the individuals most directly involved in developing and

influencing local government policy toward improving building energy efficiency and reducing greenhouse gas

emissions by improving compliance with energy, green building, and reach codes. Though not directly involved with

permitting or Energy Standards enforcement, they are in the best position to assist building department staff with

technical issues, plan review, training needs, and understanding why and how to enforce Energy Standards

measures.

Plans Examiner:

This technical position requires extensive knowledge of local, state, and federal building codes and ordinances,

including electrical, mechanical, plumbing, energy, historical, fire, and green building. It involves reviewing permit

applications and documentation to determine whether proposed building activity meets minimum code

requirements. When assessing Energy Standards compliance, plans examiners focus on Parts 3-5 of the CF-1R.

Contractor: A contractor licensed by the Contractors State Licensing Board performs work within the scope of his

or her license and has proper skills and knowledge related to the construction and operation of electrical equipment

and installations. The contractor has received safety training to recognize and avoid the hazards involved. HVAC

contractors must possess a C-20 license. For HVAC alterations, a contractor may also be the permit applicant as

well as uploader of all relevant HERS compliance documentation: CF-1R and CF-2R.

Permit Service Provider:

An independent stakeholder is hired by contractors to pull building permits from local jurisdictions. He or she

specializes in understanding the various submittal requirements across building departments.

HERS Rater (As defined in Title 20, Chapter 4):

A person who has been trained, tested, and certified by a HERS Provider to perform the field verification and

diagnostic testing required for demonstrating equipment/system compliance with the Energy Standards.

19

Building Department Working Groups and Discussion During September and October 2014, CSE presented the survey results at three half-day

regional stakeholder working groups held in San Diego, Los Angeles, and Rancho Cucamonga.

The purpose was to share and discuss survey results with local government staff, including

chief building officials (CBOs), building inspectors, and planners from the following

jurisdictions:

• City of Beverly Hills

• City of Carlsbad

• City of Chula Vista

• City of El Cajon

• City of Imperial Beach

• City of Los Angeles

• City of Moreno Valley

• City of Rancho Cucamonga

• City of San Diego

• County of San Diego

CSE staff limited working group participants to local government staff to encourage a more

open discussion of compliance process barriers and permitting best practices. Each group

included more than one jurisdiction, to encourage information sharing and collaboration.

At each working group, CSE staff presented answers to specific survey questions and asked

participants whether the results resonated with or mirrored their jurisdiction’s experiences.

Through this process, participants became more engaged and comfortable sharing candid

feedback. This enabled CSE to explore and corroborate survey findings and barriers, while

facilitating the conversation toward potential permitting solutions and best practices.

In November 2014, following the working group meetings, CSE held additional working sessions

with 10 building departments at their respective locations, which are listed below.

City of Chula Vista

City of Coronado

City of El Cajon

City of Escondido


City of Lake Forest


City of Murrieta

City of San Diego

County of San Diego

CBOs, building inspectors, permit technicians, plans examiners, and planners attended these

sessions. The purpose was to better understand each building department’s permit processes,

and explore which of the proposed best permitting practices are most feasible to implement in

jurisdictions of various sizes and with varying levels of available resources.

ICC Chapter Feedback Local International Code Council (ICC) chapters convene chief building officials and senior

building department staff monthly to discuss building codes and compliance issues. In general,

the meetings are well attended and offer an opportunity to share information and gather

feedback from a majority of building department leadership across Southern California.

While not part of the original study plan, the CSE authors decided to share their proposed best

practice recommendations (after they were identified based on the survey and working groups)

at several ICC monthly chapter meetings in Southern California. Between August 2015 and

20

January 2016, CSE representatives presented their best practice recommendations to these six

Southern California ICC chapters:

• Citrus Belt Chapter • Foothill Chapter • Los Angeles Basin Chapter

• Orange Empire Chapter • San Diego Region Chapter • Ventura Region Chapter

Discussions with ICC chapter members were critical in helping CSE vet these best practices and

determine which building departments were either already implementing best practices or

interested in learning more about best practices for future implementation. CSE documented

this information using the “HVAC Permit Compliance Best Practice Scorecard” (ICC Scorecard).

An example of a completed ICC Scorecard is in Appendix C.

Chapter members were encouraged to ask clarifying questions and to have an open dialogue

about the logistics of each best practice before completing their scorecards. Forty-five

attendees completed scorecards; again, results from this small sample are not conclusive.

Chapter 3 presents results from the stakeholder survey and working group discussions with

local government personnel. Scorecards were completed after CSE identified best practices, and

the compiled scorecard results can be found in Chapter 4, at the end of each best practice

discussion.

21

CHAPTER 3: Survey and Working Group Results

Of 80 survey questions, this section focuses on results of 11 questions that were selected

because they addressed key process-related compliance barriers identified by both permit

applicants and local government staff. Participant responses to these 11 questions collectively

pointed toward process-related best practices for permitting residential HVAC system

alterations and improving Energy Standards compliance. Those recommended best practices

are presented in Chapter 4, and survey results are in Appendix A.

Each section below presents the selected survey question(s), targeted respondent roles, answer

options, and results compiled from both the survey and working group/session discussions.

Implementation and Enforcement Q13) Does your building department have adequate resources to implement Title 24 Part 6

requirements?

Q14) Does your building department have adequate resources to enforce Title 24 Part 6

requirements?

Figure 5: Responses to Survey Questions 13 and 14


CSE’s survey did not define the terms “implementation” or “enforcement.” However, survey

results indicate that 74 percent of respondents think their building department has enough

resources for implementation, but only 40 percent think they have resources for enforcement.

During the working groups, and in an effort to better understand the different responses, CSE

explored the various interpretations of and distinctions between implementation and

enforcement. Here are several comments from participants:

22

• “Implementation and enforcement are two separate groups: Plan Checkers and

Inspectors. Implementation involves the plan check. Compliance is done by inspectors in

the field as they verify plans submitted to and approved by the building department.”

• “Enforcement means to us the licensing of contractors that is done by the CSLB.

Implementation is when field staff [and] building inspectors review plans and conduct

inspections.”

• “Enforcement means to us the licensing of contractors that is done by the CSLB.

Implementation is when field staff [and] building inspectors review plans and conduct

inspections.”

• “Enforcement is out of our range, this should be a state licensing board effort.”

• “Code enforcement is triggered by complaints; then the city investigates.”

Based on these responses, building department staffers tend to agree that (a) they are

responsible for code compliance of projects that come across their permit counter/desks, and

(b) they lack the authority or resources to ensure that all contractors and owners pull

appropriate permits. Working group discussions indicate that “implementation” is typically

viewed as the process of reviewing applications and inspecting permitted projects, while

“enforcement” is typically perceived as being beyond the building department’s purview and a

responsibility of the CSLB.

Building Department Resources Q15) What resources do building departments need most? Rank your answers 1-5, (1 = needed

most)

Figure 6: Response to Survey Question 15 Building Department Resources Most Needed Importance Average

Applicant education on requirements 1 2.13 Contractor code enforcement 2 3.29 Field staffing 3 3.37 Office staffing 4 3.68 Office technical knowledge 5 3.85 Field technical knowledge 6 4.37 IT services such as online scheduling 7 4.88


Responses from building department staff indicate that they are most in need of education for

permit applicants (primarily contractors) about HVAC alteration permit requirements. The

survey occurred at the end of a three-year code cycle, when contractors were most familiar with

the 2008 Energy Standards. This suggests that the complexity of the Energy Standards remains

a problem throughout each code cycle.

Responses from building department staff indicated that the second most needed resource was

help with contractor code enforcement (in other words, nonpermitted HVAC alterations). This

23

result reinforces the perception that building departments do not have enough resources to

identify and bring noncompliant contractors into the permit process.

Survey respondents indicated that field staffing is the next most needed building department

resource. Working groups observed that the perception of “adequate staff resources” differs

among jurisdictions of different sizes. Larger jurisdictions with higher project volume typically

have more staff, whereas smaller jurisdictions cannot support additional staff, regardless of

incoming project volume. In the latter case, staff members tend to play multiple roles in the

permit process, from counter technician to plans examiner to building inspector; in some cases,

the CBO serves many roles. One working group attendee from a medium-sized jurisdiction

stated, “A City of Los Angeles employee told us that LA has 800 plumbing inspectors. [I] …

handle several roles in addition to building inspections.”

Working group discussions indicate that permit applicants’ understanding of the Energy

Standards and knowledge of which energy compliance documents are required directly impacts

a building department’s ability to effectively enforce the Energy Standards. The less applicants

know about the Energy Standards, the more time staff must spend walking applicants through

the process before they can actually enforce them.

Permit Applicant Resources Q25) How often do you use these resources to access information on the residential permit

process? Rank your answers 1-5, with 1 = most often used

Figure 7: Responses to Survey Question 25 Resources Used by Applicants to Access Permit Information Rank Counter Visit 1 Jurisdiction Website 2 Call or Email Jurisdiction Staff 3 Permit Runner 4 Internal Database 5 Source: Center for Sustainable Energy

This survey question sought to identify where permit applicants go to find information about

the permit compliance process. The results in Figure 7 indicate that applicants rely on building

departments; their top three responses were the permit counter, website, and staff contacts.

Q26) Which resources does your building department make available online? Check all that

apply.

Figure 8: Responses to Survey Question 26


Resources Available on Building Department Websites % Designated Permit Point of Contact Information 51 Permit Process/Steps 82 Fee Schedule/ Permit Costs 80 Accessible Permit Applications 86

24

CSE wanted to determine if building departments were taking advantage of their jurisdiction

websites as a venue to share information with permit applicants. As Figure 8 shows, 51 percent

of respondents indicated their website included a designated point of contact at the building

department, and 82 percent indicated that they provided information about permit processes

and costs online. Eighty-six percent of departments made permit applications available online.

However, subsequent working group discussions indicated that applicants could only download

and print the PDF application but could not complete applications online.

One working group participant said that Energy Standards and permitting information was

posted to their city’s website in reaction to (increased) postrecession building activity that has

strained staff resources, stating, “While building permits are picking back up, this city does not

have the resources to hire new staff.” Posting permitting information online is an effective way

for jurisdictions to share information without needing additional staff resources.

CSE’s exploration of building departments’ website content identified the most to least

common types of HVAC and Energy Standards permit information, as shown in Figure 9.

Unfortunately, the quality and accessibility of this information varies widely. While many

building departments made the information available, it was typically not well organized,

buried behind too many clicks, or presented as a dense wall of text. User experience has a

distinct effect on a Web visitor’s ability to absorb and act on information provided; very few

building department websites hit the mark.

Figure 9: Information Most Commonly Provided on Building Department Websites


Permit fee schedules

Downloadable PDF permit applications

General building department contact information

“How to apply” instructions for permits

Building inspection scheduling instructions

How to qualify for expedited permits (where available)

Value and necessity of pulling permits

Actual code language

25

It is important to consider the way websites are updated with new information. Most working

group participants indicated they did not have direct access to the website; another department

in the jurisdiction controls the content, as well as the revision process and schedule. Energy

compliance information was often overlooked, unless managed by staff with strong Web

organization and content delivery skills.

Building Department Processes CSE sought to understand how building departments reviewed and assessed energy compliance

documentation, including that provided on the:

• Certificates of compliance (CF-1R-ALT) submitted with permit applications.

• Certificates of installation (CF-2R-ALT).

• Certificate of HERS FV&DT (CF-3R-ALT).

Responses in Figure 10 show that 70 percent of permit technicians and plan examiners do not

use a checklist or reference tool to ensure that the correct energy compliance documentation is

submitted as part of the residential HVAC alteration permit application.

Q31) Do you use a checklist or reference tool to ensure the appropriate compliance

documentation is provided with the residential permit application? Answer: yes, no, or unsure.



Of 14 jurisdictions that participated in CSE working groups or sessions, 5 indicated that

internally generated checklists, most addressing all building code elements, were used by some

plans examiners and building inspectors. One jurisdiction reported using Energy Code Ace™

checklists for new construction projects during plan review and found them to be helpful. None

reported the use of checklists by permit technicians at the time of permit submittal.

However, as shown in Figure 11, 52 percent of respondents indicated that residential permit

applications were frequently or always returned because the energy compliance documentation

was incomplete.

Q35) How often are initial residential permit applications not accepted or returned because of

incomplete Title 24 compliance documentation?

26



This question was asked toward the end of the 2008 code cycle, when the Energy Commission

and Energy Code Ace were on the verge of releasing checklists for the 2008 Energy Standards

and were gearing up for a release of tools to support the 2013 Energy Standards.18F

19 During both

rounds of working groups, CSE asked building departments if their staff were using Energy

Standards compliance checklists or reference tools after July 2014. Most jurisdictions were not,

and many were not aware of the Energy Code Ace tools.19F

20 Of those jurisdictions that were

aware of Energy Code Ace, some stated that the checklists were too lengthy or not useful to

support day-to-day counter functions. CSE’s research of the resources of Energy Code Ace

found that the two- and three-page checklists for the 2013 Energy Standards targeted plans

examiners and building inspectors. The checklists addressed residential and nonresidential

measures generally, as well as envelope, mechanical, and lighting projects, and could be used

for performance and prescriptive methods.20F

21

Figure 11 reveals that 52 percent of respondents (both building department staff and private

industry) indicated that permit applications are frequently or always returned; another 36

percent indicated that applications were sometimes returned. Returned applications resulted in

permit process delays. Applicants had to collect the missing information and resubmit the

application, increasing the time (and money) spent on the project. Clearly, incomplete energy

compliance documentation was a problem for stakeholders on both sides of the permit desk.

Perhaps more importantly, incomplete documentation was a problem because it increased the

risk that projects will not comply with the Energy Standards. For example, the CF-1R-ALT form

triggers the HERS FV&DT process and dictated what HERS tests are required. Incomplete or

inaccurate information can lead to improper HERS testing, incomplete building inspections,

inaccurate inspection results, and noncompliant HVAC systems. CSE’s survey was not designed

19 California Statewide Codes and Standards Program, http://www.energycodeace.com.

20 While these particular checklists are not designed for basic compliance of mandatory measures, Energy Code Ace provides a residential HVAC trigger sheet that is more ideal for permit counter staff to use during review of permit applications and CF-1Rs. http://www.energycodeace.com/content/resources-checklists/.

44 Energy Code Ace Resources, http://www.energycodeace.com/content/resources-checklists/

http://www.energycodeace.com/

http://www.energycodeace.com/content/resources-checklists/

http://www.energycodeace.com/content/resources-checklists/

27

to explore the frequency of errors on energy compliance forms. However, such documentation

errors were included as part of BayREN’s study.

In a similar compliance improvement effort in 2014, BayREN’s Codes and Standards program

collected Energy Standards compliance project data from 15 Bay Area jurisdictions using

surveys and in-house reviews of building department permit records. In April 2015, BayREN

published its findings in the Permit Resource Opportunity Program (PROP) Report.21F

22 Results

were similar to CSE’s findings that obtaining complete, error-free energy compliance

documentation from applicants was rare. Specifically, the PROP Report indicated the following

key findings associated with addition and alteration projects:

• Only 7 percent of reviewed projects correctly met all of the documentation

requirements of the Energy Standards at all stages of review (submittal, plan review, and

as-built conditions). Issues included failure to document energy components of

equipment, failure to post required forms at job sites, and incomplete and inaccurate

energy information in the documentation.

• Common documentation errors were conflicting information on forms and missing field

forms.

The PROP Report also revealed that “energy documentation missing in the field” was one of the

most common types of discrepancies among reviewed projects. On inspection, 67 percent of

projects performed worse than predicted by energy calculations. According to BayREN,

“common field errors affecting energy performance were the installation of measures that were

less efficient than those documented, and the failure to meet mandatory minimum measures as

required by the code for all projects.”22F

23

Q27) What are the options for submitting a permit application for residential HVAC alterations?

Responses indicate that all 42 jurisdictions surveyed issue residential HVAC alteration permits

over-the-counter, and the following 10 jurisdictions issuing these permits online:

Based on CSE's analysis of 2014 U.S. Census population data,23F

24 36 percent of the study

population lived in a jurisdiction that offered online permitting for residential HVAC

alterations.

22 BayREN. PROP Final Report, 2015, https://www.bayren.org/codes/prop-final-report.

23 Ibid.

24 U.S. Census, http://www.census.gov/population/projections/data/national/2014.html.

• Burbank

• Chula Vista

• El Cajon

• Long Beach

• Orange

• Rancho Cucamonga

• City of San Diego

• County of San Diego

• Simi Valley

• Ventura

https://www.bayren.org/codes/prop-final-report

http://www.census.gov/population/projections/data/national/2014.html

28

Q26) Which resources does your building department make available online? Check all that

apply.

The intent of this survey question was to identify how many building departments use the

Internet to process residential HVAC alteration permits from start to finish. While results show

that 86 percent of respondents said their department makes permit applications available

online, the discussion of responses to question 6 (Figure 10) revealed that in most of these

cases the applicant was only able to download and print a PDF application for fax, email, or in-

person submittal, rather than complete and submit the application online. Only 28 percent of

respondents reported accepting applications online.



Similarly, 90 percent of respondents report their building department uses a permit software

system. However, most of those jurisdictions use software for internal purposes only and do

not accept applications, issue permits, or allow applicants to track permits online.

Despite recent proliferation of online commerce across most industries and platforms, most

building departments do not offer online permitting. Based on working group discussions,

building departments are too limited in budget and staff resources to take full advantage of

online permitting systems.

Permitting Barriers This report focuses on the Energy Standards compliance of permitted residential HVAC

alterations. However, several survey questions and working group discussions also addressed

barriers associated with the estimated 90 percent of residential HVAC alterations that are not

permitted.

Q6) For residential HVAC alterations, how often do homeowners request that you not pull a

permit?

Figure 13 indicates that 17 percent of responding contractors were frequently asked to not pull

a permit, 44 percent were sometimes asked to not pull a permit, and 39 percent were rarely

asked to not pull a permit.

Resources Available on Building Department Websites % Make Permit Applications Accessible 86

Access Permit Applications Online 28

Have Permitting Software 90

Allow Applicants to Track Permits 32

29



Q7) When homeowners request to not pull a permit, what reasons do they give? Select all that

apply.



When customers requested that their contractor not pull a permit, the top reason (Figure 14)

was that the process was too time-consuming. Working groups agreed that this was especially

true for emergency change-outs, which do not allow time for pulling a permit, dealing with

potential delays at the permit counter, completing HERS FV&DT and building department

inspection process, and closing the permit. In any alteration, time spent on the permitting

process costs the homeowner, either in contractor and HERS Rater compensation or time away

from other activities (for example, work or family responsibilities). The second-most frequent

answer was “too expensive,” and the third most frequent was “bad experience in the past.”

Write-in answers included fears of penalties for discovery of previous unpermitted building

activity or code violations, increased property taxes, or “antigovernment” sentiment.

30

Q10) In your opinion, what are the biggest barriers to residential alterations permit compliance?

Figure 15 illustrates the relative frequency of perceived permit compliance barriers among

contractors and HERS raters. The most common barriers were (1) cost, (2) energy compliance

forms and paperwork, and (3) lack of knowledge and understanding of the Energy Standards.

These results summarize the data presented in this section, reinforcing a lack of applicant

understanding of the permitting process (Figure 6), issues around incomplete and inaccurate

energy compliance forms (Figure 11), and the high costs of energy compliance (Figure 15).



As described above in the Chapter 2, results from the subsequent ICC chapter meeting

discussions and scorecard questionnaires are presented after each recommendation below.

This concludes discussion of stakeholder surveys and working group and sessions. The next

chapter proposes and describes strategies for overcoming or at least mitigating the major

barriers to Energy Standards compliance of permitted residential HVAC system alterations.

31

CHAPTER 4: Best Practice Recommendations

During CSE’s working groups (discussed in Chapter 2), several jurisdictions wanted to know,

“How can enforcement occur in an educational and collaborative effort that fosters positive

relationships between building departments and industry?” From the 80 survey questions and

subsequent working groups, CSE developed best practice recommendations for building

departments to use to improve Energy Standards compliance rates for residential HVAC

alterations. This chapter presents four strategies identified by this study.

CSE recommends local governments prioritize enforcing Energy Standards measures for

residential HVAC alteration by considering the long-term benefits of adopting these practices:


information about the Energy Standards requirements for HVAC system alterations, and



Standards, particularly residential heating, ventilation, and air conditioning (HVAC)

system alterations.

3. Consider hiring or contracting with HERS Raters to (a) conduct field verification and

diagnostic testing of residential HVAC system alterations, and (b) after obtaining

appropriate International Code Council certification(s), conduct final building

inspections.



work.

Each of these best practice recommendations is discussed in detail below.

1: Improve Website Information on Permitting and HERS Process Building departments can save valuable staff time and resources by providing clear instructions

on the residential HVAC alteration permitting process on their websites. CSE’s survey results

indicated that applicants use building department websites to obtain information about the

Energy Standards and relevant permitting processes. Making this information more readily

accessible on their websites (not just at the permit counter) was an effective low-cost way to

increase applicant understanding of requirements, thereby reducing permit errors and

timelines. Clear website information also reduced time spent answering applicant questions.

Unfortunately, most building department websites are now poorly organized and outdated,

with key information missing, hard to find, or available as low-resolution documents. Better

website design enables users to access relevant information more readily, understand the

32

compliance process more clearly, and take appropriate action more quickly. CSE’s ICC

Scorecard results in Table 4 indicated that most responding ICC chapter members felt that their

website needed improvement.

Table 4: ICC Scorecard Results: Clear Website Information (Total Number of Scorecards Received: 45)

Yes No No answer My jurisdiction needs help with this 30 11 4

My jurisdiction provides clear website information on the permit process

13 27 5

My jurisdiction provides fillable forms online 11 31 3 Source: Center for Sustainable Energy

Local governments should objectively review their website content and organization to identify

opportunities to clarify and streamline the permit process, particularly for projects that trigger

Energy Standards requirements. This would likely involve expertise beyond the building

department, including a website design professional and Energy Standards compliance expert.

Key staff members should be assigned responsibility for their building department’s website.

These staff members would organize content with users in mind to promote intuitive website

navigation and discovery of relevant permit process and Energy Standards compliance

information.

Specifically, California building department websites need to prioritize permit process-related

information, and remove or relocate to supporting pages much of the information now there.

Following are examples of features that should be readily accessible on jurisdiction websites to

clarify permit processes and Energy Standards requirements:

1. An “apply for permit” link should be accessible on the website’s first page. One click

should take the user to an outline of clearly identifiable permit classifications,

preferably organized as residential or nonresidential; and new construction, building

addition, or alteration projects.

2. After an applicant finds the appropriate permit classification, a clickable link should

take her/him to a page with the relevant permit application form and energy compliance

documents. For residential HVAC alterations, this page would include the CF-1R-ALT

Certificate of Compliance form, and related permitting instructions. At this point in the

process, it should be clear to the applicant whether HERS FV&DT is required.

3. Permit application and Energy Standards compliance forms would ideally be active,

fillable PDFs rather than having applicants print them out, complete them by hand, then

33

deliver in person or scan and submit them electronically.24F

25 Websites should also provide

examples of completed applications and Energy Standards compliance forms for

applicants to reference.

4. Websites should accept electronic signatures for online applications and include

language asking the applicant to confirm that he or she understands and will abide by

necessary legal requirements.

5. If the online permitting platform requires applicants to preregister, the preregistration

process should also be electronic and allow forms to be submitted online using e-

signatures.

6. Websites should provide contact information for a building department point of contact.

7. Websites should link to the permit fee schedule and accept electronic fee payments

online.

8. Applicants need access to permit application review (if any) and other processing

timelines.

9. Websites should clearly explain the process for requesting and scheduling a building

inspection after installation, and that compliance forms that need to be completed at

the time of inspection.

Jurisdictions should also provide a convenient website link to information on the “value of a

permit and complying with HERS requirements.” (See Chapter 1.) Building departments should

consider providing links to relevant Energy Code Ace checklists for applicants to reduce the

rate of incomplete applications that must then be resubmitted.

2: Prioritize Online Permitting Online permitting involves the use of a Web-based platform to accept permit applications, track

permit progress, upload Energy Standards compliance forms, schedule inspections, and enable

fee payments. This best practice addresses several needs identified in this study, including staff

time constraints, permit applicant education, and permitting soft costs such as time spent

scheduling building inspections.

Considering the growing emphasis of state and local governments on Energy Standards

compliance and climate action plans, CSE recommends that jurisdictions prioritize their

implementation of online permitting by focusing on projects that do not require plans, but that

trigger the Energy Standards and associated compliance documentation, including HERS FV&DT

certificates. This would include HVAC system alterations, and perhaps other residential

alteration projects, such as window replacements.

An ideal online permit platform allows for:

25 Residential HVAC alteration compliance forms (CF-1R, CF-2R, and CF-3R) are located on the Energy Commission’s website. The Energy Commission does not provide fillable forms for residential HVAC alterations; however, HERS Raters can access electronically fillable HERS forms on HERS Provider websites.

http://www.energy.ca.gov/title24/2013standards/res_compliance_forms/CF1R/2013-CF1R-ALT-04-E-PaperVersionOfALT-HVAC-CZ%202,8-15.pdf

http://www.energy.ca.gov/title24/2013standards/res_compliance_forms/CF2R/

http://www.energy.ca.gov/title24/2013standards/res_compliance_forms/CF3R/

34

1. Permit application and energy compliance document submittal by applicant.

2. Electronic signature by applicant.

3. Payment of fees by applicant.

4. Permit issuance by the building department.

5. Permit tracking by the applicant, building department, and HERS Rater (if any).

6. Inspection requests from applicant.

7. Inspection scheduling by building department.

8. Confirmation of inspection results and permit closure by building department.

According to CSE’s 2014 survey, 90 percent of building departments had an internal software

platform to track permit activity.25F

26 However, 84 percent said their systems did not allow

applicants to submit permit applications online.26F

27 Table 5 below shows results of a similar

question that was included in the questionnaire presented to ICC members.

Table 5: ICC Scorecard Results: Online Permitting (Total Number of Scorecards Received: 45)

Yes No Don’t know No answer My jurisdiction has online permitting 11 29 0

5 Source: Center for Sustainable Energy

Adding online permit application capability has the potential to significantly reduce permitting

timelines. Online permitting of nonplan-reviewed projects that trigger Energy Standards

requirements can free up time for counter staff to process less complex permit applications.

Electronic application submittal is also more convenient, as applicants do not have to drive to

the permit counter, thereby eliminating wait time and reducing excuses for avoiding permits.

This also reduces vehicle miles traveled and transportation-related GHG emissions, potentially

bringing value to jurisdictions looking to achieve climate action plan (CAP) goals. Eliminating

time at the permit counter is a huge incentive for applicants when evaluating the time and costs

involved with pulling permits, which are ultimately passed on to the customer.

3: Hire Energy Standards Specialists CSE’s survey results listed field staff as one of building departments’ three biggest needs.27F

28 As

mentioned in Chapter 1, building inspectors have limited time for each inspection, and energy

is one of many aspects of the building codes that they enforce.

Most building departments strive to schedule inspections within one business day of a request.

However, CSE’s survey results show that if inspections were not scheduled within one day,28F

29 or

26 Survey question #46, see Appendix A.




35

if multiple inspections were required,2 9F

30 contractors were less likely to follow through with

inspection. After installing a permitted residential HVAC alteration, contractors often left it to

the (usually uninformed) homeowner to hire and schedule the HERS Rater’s visit and final

inspection. As a result, many HVAC alteration permits were never closed, and the associated

Energy Standards compliance was not evaluated or documented.

A potential option for addressing this permit completion barrier is for jurisdictions to hire

HERS Raters (trained and certified by an Energy Commission-approved HERS Provider) to

conduct HERS FV&DT and possibly building inspection of HVAC alterations, as either an outside

contractor or in-house staff. Although logistics were not specified, CSE survey results indicated

that 33 percent of responding CBOs would consider this option.30F

31 In any case, building

departments would need additional resources to pay HERS Raters.

Working group discussions revealed that building departments that hire HERS Raters as staff

would likely also need and expect them to obtain ICC (or equivalent) 31F

32 certification as a

building inspector. In that case, HERS Raters would be able to inspect a wider range of projects.

If independently contracted, they would be able to work with multiple jurisdictions.

For example, achieving residential mechanical building inspector certification in California

involves a series of tests that together cost less than the HERS Rater certification.32F

33 If a HERS

Rater also qualified as a building inspector and was able to conduct HERS FV&DT and building

inspection in the same visit, inspection timelines and costs could be reduced. CSE’s ICC

Scorecard feedback in Table 6 indicates mixed levels of comfort with this concept.

Table 6: ICC Scorecard Results: HERS Raters as Third-Party Inspectors (Total Number of Scorecards Received: 45)


In addition to or instead of HERS Raters, jurisdictions could consider hiring an “Energy

Standards coach”33F

34 to train and mentor internal staff and help review permit applications,

plans, and field inspections of projects that trigger Energy Standards requirements and

compliance documentation. For example, CSE administers “energy code coach” programs for

the City of Chula Vista and the City of San Diego, funded by Local Government Partnerships. An

energy code coach is an expert in Energy Standards requirements and has experience reviewing




33 http://www.iccsafe.org/Certification/Bulletins/Legacy_State_EIB.pdf, pp. 28-29.

34 City of Chula Vista Sustainable Communities Program, http://energycenter.org/programs/chula-vista-sustainable-communities-program.

Yes No No answer This concept would be considered in my jurisdiction 22 19 4

http://www.iccsafe.org/Certification/Bulletins/Legacy_State_EIB.pdf

http://energycenter.org/programs/chula-vista-sustainable-communities-program

36

plans and working with building department staff. Each energy code coach spends one or two

days a week with each building department:

• Assessing the current level of understanding of Title 24, Part 6, and Part 11 (California

Green Building Standards, or CALGreen) among jurisdiction staff and local building

professionals.

• Working collaboratively with staff to identify opportunities for learning and barriers to

energy (and green building) code implementation and enforcement.

• Directly providing specific, hands-on assistance to improve Energy Standards

enforcement.

• Developing custom tools and resources (for example, reviewing checklists and website

content) that address the needs of staff and the community to improve Energy Standards

compliance.

4: Enable Virtual Inspections Virtual building inspections are performed by building inspectors remotely guiding contractors

using video cameras at the site and using geolocation to confirm property addresses. In May

2015, the County of San Bernardino launched a virtual inspection program to reduce

inspectors’ travel time and permit applicants’ wait time.34F

35 This technology requires relatively

inexpensive tablets or smartphones with video calling capability, a geolocation application, and

possibly a data (fee) plan, as well as staff training. Similar to online permitting, virtual building

inspection has not yet been widely adopted in California but is a potential best practice worth

considering.

Building inspectors would schedule a “video chat” with a contractor to facilitate a real-time,

inspector-guided tour of the installed equipment and materials. Unlike photographs,

videography can capture physical tests of critical connections and proper installation of

equipment and ductwork. Virtual inspections can also address life-safety issues such as

adequate combustion appliance venting, carbon monoxide alarm functionality, and secured

caps on refrigerant lines. Virtual inspections save traveling time for inspectors and would be

particularly advantageous in county jurisdictions with remote unincorporated locales. This was

a major motivator for San Bernardino County, whose territory spans 20,105 square miles. Less

travel time also results in reduced GHG emissions, which helps to meet local CAP goals.

San Bernardino’s virtual inspection program included re-inspections and two-part inspections,

which involved separate site visits by building inspectors and applicants, often on the same

day. Furthermore, the program allowed inspectors to schedule a specific appointment time with

the applicant, instead of the standard three-hour window. This significantly reduced time

needed to complete the permit, with lower costs for the contractor, homeowner, and building

35 “San Bernardino County News Release: Virtual Inspections Are the County’s Next Innovation.” May 5, 2015. http://www.sbcounty.gov/uploads/CAO/pressreleases/content/Virtual_Inspections_PR_5-4-15-1.pdf.

http://www.sbcounty.gov/uploads/CAO/pressreleases/content/Virtual_Inspections_PR_5-4-15-1.pdf

37

department. ICC Scorecard feedback on this strategy, shown in Table 7, indicated relatively low

acceptance, although many respondents were unlikely to have had experience with virtual

inspections.

Table 7: ICC Scorecard Results: Virtual Inspections (Total Number of Scorecards Received: 45)


Summary CSE’s goal for the multiyear (2013-2016) study of residential HVAC alteration permitting

processes among Southern California building departments was to identify best practices for

local governments to improve compliance with the Energy Standards. This seemingly small

sector of the market is a significant target of statewide efforts to improve energy efficiency

because:

• Central air conditioning in homes is a major component of peak electrical demand in

the state.

• Regulations prescribe the process for ensuring the energy performance of these

systems, but it is much too common for homeowners and contractors to (knowingly or

otherwise) avoid Energy Standards compliance and documentation processes, even for

permitted projects.

Building departments are ultimately responsible for enforcing the Energy Standards, but energy

is one of many building codes they must enforce. As the Energy Standards become increasingly

complex and performance-oriented, building department resources tend to remain limited. In

short, their resources need to be increased and their processes made more efficient if they are

to successfully enforce them.

After surveying regional stakeholders and facilitating discussions among local government

staff, CSE developed four best practice recommendations for improvement, all of which require

local governments to prioritize additional resources for building departments:


information about the Energy Standards requirements for HVAC system alterations, and



Standards, particularly residential heating, ventilation, and air-conditioning (HVAC)

system alterations.

3. Consider hiring or contracting with Home Energy Rating System Raters to (a) conduct

field verification and diagnostic testing of residential HVAC system alterations and (b)

after obtaining appropriate International Code Council certification(s), conduct final

building inspections.

Yes No Maybe No answer

This concept would be considered in my jurisdiction 9 18 1 17

38



work.

Based on CSE staff interactions with stakeholders during this study period, local governments

were as keen as the state’s energy policy makers to successfully enforce the Energy Standards.

Meanwhile, local building departments did not have sufficient resources to significantly

increase Energy Standards compliance of permitted residential HVAC alterations.

The Energy Commission, CPUC, CSLB, local governments, and private sector stakeholders need

to collaboratively develop strategies for stimulating mutually beneficial market-based solutions

that ease the statewide market transformation that is expected by California energy policy.

Private stakeholders with a vested interest in the energy compliance of residential HVAC

systems include:

• Licensed mechanical contractors.

• Local Institute of Heating and Air Conditioning Industries (IHACI) chapters .

• Air-conditioning equipment manufacturers and distributors.

• Local International Code Council (ICC) chapters.

• California investor-owned utilities (IOUs) and publicly owned utilities (POUs).

• Developers of permitting software.

• HERS providers and raters.

As local governments in California continue to develop and implement their own CAPs to

reduce fossil fuel use and GHG emissions, they need to prioritize the enforcement of permitted

residential HVAC alterations by providing the additional staff and other resources needed by

their building departments to effectively address this critical need.

39

GLOSSARY, ABBREVIATIONS

AB 32 California Assembly Bill 32, Global Warming Solutions Act

AB 758 California Assembly Bill 758 (2013): Requires the Energy Commission, in

collaboration with the CPUC and stakeholders, to develop a comprehensive

program to achieve greater energy efficiency in the state’s existing

buildings.

BayREN Bay Area Regional Energy Network

BPI Building Performance Institute

BSC (California) Building Standards Commission

CABEC California Association of Building Energy Consultants

CALBO California Building Officials

CAP Climate Action Plan

CBO Chief Building Official

CPUC California Public Utilities Commission

CSE Center for Sustainable Energy

CSLB Contractors State Licensing Board

EBEE Existing Buildings Energy Efficiency Plan

FV&DT Field Verification And Diagnostic Testing

HERS Home Energy Rating System

ICC International Code Council

LEED Leadership in Energy and Environmental Design

PROP (BayREN) Permit Resource Opportunity Program

Energy Standards Building Energy Efficiency Standards (CA Title 24 Parts 1 and 6)

40

Strategic Plan (California) Long Term Energy Efficiency Strategic Plan

SWIFT Statewide Investigative Fraud Team

A-1

APPENDIX A: Permit Compliance Survey Results

CSE’s Residential HVAC Alterations Permit Compliance Survey was conducted during March and

April 2014. Of 124 survey respondents, 101 answered all questions, while 23 were incomplete.

Shaded boxes above each question indicate which respondents received that question. No

shaded box above a question indicates that question was asked of all respondents.

Q1) Please select the title that best describes your job role.

Count Percent (N=110)

Chief Building Official 26 24%

Plans Examiner 16 15%

Building Inspector 17 14%

Permit Staff/Technician 16 15%

Planner 15 14%

Contractor 17 15%

Rater 2 2%

Permit Service Provider 3 3%

Permit Compliance Barriers

Chief Building Official, Plans Examiner, Building Inspector, Permit Staff / Technician

Q2) How important is implementation of residential Energy Code (Title 24, Part 6) relative to

your other responsibilities?


Very Important 24 32.9%

Important 24 32.9%

Moderately important 17 23.3%

Not very important 6 8.2%

Not at all important 2 2.7%

Q3) How frequently do you think permits are pulled when one is required for residential

mechanical HVAC alterations?


Very common (76% or more) 18 16.5%

Common (51% - 75%) 30 27.5%

Somewhat common (26% - 50%) 26 23.8%

Not Common (25% or less) 28 25.7%

I don't know 7 6.4%

A-2

Contractor, Rater

Q4) For a residential energy upgrade/retrofit involving electrical, mechanical and plumbing

measures, what motivates you to apply for a permit?


Homeowner request 3 6.9%

Standard business practice 14 48.3%

Building code requirement 10 34.5%

Other* (please specify): 3 6.9%

Contractor, Rater

Q5) For a residential energy upgrade/retrofit involving electrical, mechanical and plumbing

measures, what would prevent you from applying for a permit? Please select all that apply.


Homeowner request 9 30.0%

Too expensive 4 13.3%

Too time-consuming 3 10.0%

I am not familiar with the process 0 0%

I did not think permits were required 2 6.7%

Lack of enforcement 4 13.3%


Contractor, Rater

Q6) For residential mechanical HVAC alterations, how often do homeowners request that you

do not pull a permit?

Count Percent (N=18) Always 0 0%

Frequently 3 17%

Sometimes 7 44%

Rarely 8 39%

Never 0 0%

A-3

Contractor, Rater

Q7) When homeowners request to not pull a permit for a residential energy upgrade/retrofit

involving electrical, mechanical or plumbing measures, what reasons do they give? Please select

all that apply.


Too expensive 11 30.6%

Too time-consuming 2 5.6%

Do not understand why a permit is required 3 8.3%

Bad experience in the past 10 27.8%


*No response provided.

Q8) For residential alterations, which permit types do you find most difficult to comply with?

Please check all that apply.


Electrical 22 18.3%

Mechanical 53 44.2%

Plumbing 45 37.5%

Q9) For residential alterations, which permit types do you find most difficult to understand?

Please check all that apply. Count Percent (N=117)

Electrical 24 20.5%

Mechanical 48 41.0%

Plumbing 45 38.5%

Q10) In your opinion, what are the biggest barriers to residential alterations permit compliance?

Please check all that apply. Count Percent (N=307)

Compliance forms/paperwork 52 16.9% Insufficient resources to inspect/verify energy measures 16 5.2% Determining applicable requirements 25 8.1% Process is too time-consuming 21 6.8% Additional inspections triggered by review process 17 5.6% Lack of knowledge/understanding about Energy Code 44 14.3% Lack of knowledge/understanding about permit process 27 8.8% Lack of training 15 4.9% Lack of enforcement 13 4.2% Cost to homeowner/contractor 60 19.5% Other* (please specify): 17 5.5%


A-4

Building Department Resources

Chief Building Official, Planner

Q11) Does anyone in your department have the following certifications? Please check all that

apply.

Count Percent (N=36) BPI Building Analyst or Building Envelope 2 5.6% CABEC Certified Energy Analyst – Residential 3 8.3% CABEC Certified Energy Plans Examiner – Residential 11 30.6% HERS Rater 0 0.0% GreenPoint Rater 1 2.8% ICC CALGreen 2 5.6% LEED Green Associate or Accredited Professional 4 11.1% I don't know 8 22.2% Other* (please specify): 5 13.9% *No response provided.

Chief Building Official, Plans Examiner, Building Inspector, Permit Staff/Technician, Planner

Q12) Do you have any of the following certifications? Please check all that apply.


BPI Building Analyst or Building Envelope 2 4.9% CABEC Certified Energy Analyst - Residential 2 4.9% CABEC Certified Energy Plans Examiner - Residential 5 12.2% HERS Rater 0 0.0% GreenPoint Rater 1 2.4% ICC CALGreen 2 4.9% LEED Green Associate or Accredited Professional 0 0.0% Other* (please specify): 29 70.7%



Q13) For residential alterations, do you feel your building department has adequate resources

to implement the Title 24 requirements?


Yes 63 74%

No 14 17%

I don't know 9 9%

A-5

Chief Building Official, Planner, Plans Examiner, Building Inspector, Permit Staff/Technician

Q14) For residential alterations, does your building department have resources specifically for contractor enforcement of the Title 24 requirements?


Yes 33 40%

No 31 37%

I don't know 20 23%


Q15) What resources do you feel your building department is in need of? Please rank your answers, 1 being the resource needed most.

Rank Average Ranking

Applicant education on requirements 1 2.13

Contractor code enforcement 2 3.29

Field staffing 3 3.37

Office staffing 4 3.68

Office technical knowledge 5 3.85

Field technical knowledge 6 4.37

IT services such as online scheduling 7 4.88

Other* (please specify): - -

* No response provided.


Q16) How active is your department in the following building code focused organizations?

Count Very Active Active Slightly Active Not Active

CALBO 80 37% 35% 14% 14%

ICC 81 41% 38% 14% 7%

Other* (please specify): 26 38% 31% 8% 23%

*Other organizations building departments are active in: American Institute of Architects (AIA) American Planning Association (APA) American Society of Civil Engineers (ASCE) American Society of Plumbing Engineers (ASPE) California Association of Building Energy Consultants (CABEC) California Association of Code Enforcement Officers (CACEO) Certified Access Specialist Program (CASP) International Association of Electrical Inspectors (IAEI) International Association of Plumbing and Mechanical Officials (IAPMO) Local International Code Council (ICC) Chapters National Fire Protection Association (NFPA) National Society of Professional Engineers (NSPE) Structural Engineers Sheet Metal & Air Conditioning Contractors’ National Association (SMACNA)

A-6

Chief Building Official

Q17) How many full time equivalent (FTE) employees does your building department have in each of the following roles? (Please enter a numerical answer)

Average

Building Inspector: 5.96

Permit Administrator/ Technician: 3.08

Plans Examiner: 2.46

Chief Building Official, Planner, Plans Examiner

Q18) How often do you utilize a contract service to conduct Title 24 plan reviews concerning residential alterations?


Always 9 16.7%

Frequently 5 9.3%

Sometimes 4 7.4%

Rarely 13 24.1%

Never 23 42.6%

Chief Building Official, Plans Examiner, Planner

Q19) What type(s) of residential projects do your contract services review? Please check all that apply.


Electrical 28 35.0%

Mechanical 26 32.5%

Plumbing 26 32.5%

Chief Building Official, Plans Examiner, Planner

Q20) Which of the following qualifications do you require of contracted plan review services?


CABEC Certified Energy Analyst 1 2.4%

CABEC Certified Energy Plans Examiner 7 16.7%


None 17 40.5%

*Other qualifications required: 11 of 17 indicated an ICC certified plans examiner or licensed engineer.

A-7

Chief Building Official, Building Inspector

Q21) How often do you utilize contract services to conduct residential field inspections?


Always 0 0.0%

Frequently 3 7.3%

Sometimes 8 19.5%

Rarely 12 29.3%

Never 18 43.9%


Q22) What type of residential field inspections do you use contract services for? Please check all that apply.


Electrical 17 33.3%

Mechanical 17 33.3%

Plumbing 17 33.3%


Q23) Which of the following qualifications do you require of contracted field inspector services?


CABEC Certification 0 0.0% CALBO Certification 6 18.8% CSLB Licenses 1 3.1% Other* (please specify): 21 65.6% None 4 12.5%

*Other qualifications required: 17 of 21 specified ICC certification.


Q24) Do your staff need help implementing any of the following residential alterations permit types?

Count Yes No I don't know

Electrical 80 13.8% 63.8% 22.5%

Mechanical 81 21.0% 60.5% 18.5%

Plumbing 77 13.0% 65.0% 22.0%

A-8

Contractor, Rater, Permit Service Provider

Q25) In general, how often do you use these resources to access information regarding the residential permit process for each jurisdiction. Please rank your answers, 1 being the resource used most.

Rank Average Ranking

Visit the counter 1 1.93

City website 2 2.27

Call or email a city staff contact 3 2.73

Ask permit-runner 4 3.42

Internal database/record 5 3.7

Other* (please specify): 0 - *No response provided.


Q26) Which of these resources does your building department make available online? Check all that apply.

Count Yes No I don't know

Office hours of operation 80 100% 0.0% -

Contact information 83 98.8% 1.2% -

Designated res. permit contact 70 51.4% 48.6% -

Permit process steps 74 82.4% 17.6% -

Fee schedule/permit costs 76 80.3% 19.7% -

Permit application 78 85.9% 14.1% -

Inspection requests 76 53.9% 46.0% -

Inspection results 70 32.9% 67.1% -

Project permit tracking 74 29.7% 70.3% -


Q27) What are the options for submitting a permit application for residential mechanical HVAC alterations? Please check all that apply.

Count Yes No

Email 110 11.8% 88.2%

In person 110 75.4% 24.6%

Mail 110 19.1% 80.9%

Online 110 15.4% 84.6%

Other* (please specify): 110 13.6% 86.4%


A-9


Q28) Do you have an accessible designated point of contact for questions about the residential

permitting process?


Yes 65 77.4%

No 14 16.7%

I don't know 5 6.0%


Q29) What methods do you use to improve and ensure the efficiency of your building

department's residential permit processes? Fill in answer(s).



Q30) List the top three jurisdictions you feel have the most efficient/easy to work with permit

processes.

Responses provided:

City of Brea County of Los Angeles City of San Diego

City of Chula Vista City of Ontario City of San Jacinto

City of Duarte City of Orange City of San Marcos

City of Encinitas City of Menifee City of Santa Clarita

City of Huntington Beach City of Mission Viejo City of Sierra Madre

City of Lake Elsinore City of Monrovia City of Tustin

City of Lake Forest City of Palmdale City of Temecula

City of Lakewood City of Rancho Cucamonga City of Villa Park

City of Los Angeles County of Riverside City of Westminster

Energy Compliance Documentation

Q31) Do you use a checklist or reference tool to ensure the appropriate compliance

documentation is provided with the residential permit application?

Count Percent (N=55) Yes, we use one we developed in-house 0 0.0% Yes, we use one provided by the CEC 13 23.6% Yes, other 3 5.5% No 22 40.0% I don't know 17 30.9%

A-10


Q32) Is a Homeowners Association letter of approval required prior to permit issuance for energy upgrades/retrofits involving electrical, mechanical, or plumbing measures?


Yes 11 13.6% No 54 66.7% I don't know 16 19.8%

Planner, Permit Staff/Technician

Q33) During your review of residential HVAC alterations permit applications, how often is the Certificate of Compliance (CF-1R-ALT) included in the initial submittal?


Always 8 38.1% Frequently 6 28.6% Sometimes 4 19.0% Rarely 2 9.5% Never 1 4.8%

Building Inspector, Contractor, Rater

Q34) For residential HVAC permits requiring HERS verification, is the completed, signed CF-4R form present at the final inspection?

Count Yes No

Additions 28 89.3% 10.7%

Alterations 31 80.7% 19.3%

Q35) How often are initial residential permit applications not accepted or returned because of incomplete (Energy Standards) compliance documentation?


Always 11 14.7%

Frequently 28 37.3%

Sometimes 27 36.0%

Rarely 9 12.0%

Q36) How often are plans required for residential heating & cooling equipment change-outs?


Always 8 8.2%

Frequently 7 7.2%

Sometimes 26 26.8%

Rarely 37 38.1%

Never 19 19.6%

A-11

Chief Building Official, Planner, Plans Examiner, Building Inspector, Permit Staff/Technician, Permit Service Provider

Q37) When required, how often do you find discrepancies between the mechanical HVAC

alterations information specified on residential plans and the energy documentation provided?


Always 1 1.3% Frequently 7 9.1% Sometimes 42 54.6%

Rarely 13 16.9% Never 1 1.3% N/A 13 16.9%

Chief Building Official, Planner, Plans Examiner, Building Inspector, Permit Staff/Technician, Contractor, Rater

Q38) If the compliance documentation specifies higher-than-prescriptive minimum energy

features (e.g., AFUE, SEER, R-value, HSPF, EF, etc.), are those highlighted for field inspection?


Yes 17 13.8% No 52 42.3% I don't know 27 21.9% Chief Building Official, Planner, Plans Examiner, Building Inspector, Permit Staff/Technician, Contractor, Rater

Q39) If you answered "Yes" to the previous question, what types of measures are highlighted

most often? Fill in answer(s)*. *No response provided.


Q40) When energy features change after the permit is issued, how often do you require

residential projects to re-submit (Energy Standards) compliance documentation?


Always 24 33.3% Frequently 4 5.6% Sometimes 10 13.9% Rarely 11 15.3% Never 13 18.1% N/A 10 13.9%

A-12

Chief Building Official, Plans Examiner, Building Inspector, Permit Staff/Technician, Contractor, Rater

Q41) When HERS verification is required, do you check the Certificate of Compliance for the

HERS registration number?


Yes 52 62.6% No 19 22.9% I don't know 12 14.4%


Q42) To how many departments does a contractor or homeowner have to submit separate

applications for a residential energy upgrade/retrofit involving mechanical HVAC alterations?


One 60 78.9% Two 14 18.4% Three or more 2 2.6%


Q43) Please indicate all the departments that need to review and approve a residential energy

upgrade/retrofit involving mechanical HVAC alterations.


Building 74 63.8% Engineering 2 1.7% Fire 4 3.4% Planning 32 27.6% Other 4 3.4% Contractor, Rater, Permit Service Provider

Q44) What resource(s) do you use to obtain residential mechanical HVAC alterations compliance

forms? Please check all that apply.

Count Percent (N= 41)

Building Department (website/counter) 6 14.6% Contractors 6 14.6% Ace Tools TM (Forms, Reference, Installation) 2 4.9% HERS Provider 16 39.0% Raters 7 17.1% Other* (please specify): 4 9.8%


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Permit Tracking

Planner, Plans Examiner, Permit Staff/Technician

Q45) Are you responsible for reviewing and approving over-the-counter permits that trigger the

residential Title 24 requirements?


Yes 18 42.9% No 24 57.1%


Q46) Does your Building Department use an integrated software system to track permit

activity?


Yes 68 86.1% Not currently, we are in the planning stages of adopting one 3 3.8% Not currently, but we are considering adopting one 2 2.5% No, we considered one but decided against it 1 1.3% No, we haven't considered it 5 6.3%


Q47) What software vendor are you currently using or considering?


Accela 16 23.5% CRW Systems TRAKiT 10 14.7%

Filemaker Pro 0 0.0% GreenVue Fusion 0 0.0%

PermitSoft 1 1.5% Permits Plus 12 17.6%

SunGard 5 7.4% Other* (please specify): 24 35.3%

*Other vendors used:

CDP (Count 2) In-House Program (Count 7)

Eden (Count 2) Project Tracking System (PTS) (Count 2)

Edgesoft (Count 1) ProjectDox (Count 1)

Energov (Count 2) SAPIN (Count 1)

Gov Partner Connect (Count 2) Tidemark (Count 2)

HANSEN or LMR (Count 2)

A-14


Q48) Does your integrated software system allow for inputting residential Title 24 measures?


Yes 18 22.8% No 33 41.8% I don't know 28 35.4%


Q49) How do you issue permits for the following measures? Please check all that apply.

* No response provided.

Chief Building Official, Plans Examiner, Permit Staff/Technician, Planner

Q50) Do you have a policy to issue or deny residential upgrade/retrofit mechanical HVAC alteration permits within a specified number of business days from submission of application?


Less than 1 day 15 22.1% 2-3 days 3 4.4% 4 days or more 6 8.8% No 28 41.2% I don't know 16 23.5%

Count Online Over-the-counter Plan review I don't know

HVAC change-outs 115 14.8% 62.6% 20.9% 1.7%

Insulation 86 4.6% 62.8% 16.3% 16.3%

Lighting 109 10.1% 57.8% 28.4% 3.7%

Re-roofing 98 11.2% 73.5% 12.2% 3.1%

Water heater replacement 99 22.2% 74.8% 0.0% 3.0%

Window replacements 101 8.9% 62.4% 23.8% 5.0%

Other* (please specify): 14 7.1% 28.6% 7.1% 57.1%

A-15

Chief Building Official, Plans Examiner, Permit Staff/Technician, Planner

Q51) What is the average number of business days between permit application submission and decision (i.e., permit issuance or denial) for residential mechanical HVAC alterations?


Less than 1 day 40 60.6% 2-3 days 6 9.1% 4-6 days 4 6.1% 7 days or more 2 3.0% We do not track this 3 4.6% I don't know 11 16.7%


Q52) Are there mechanisms in place for accelerating residential alterations permitting processes under certain conditions?


Q53) Would you be willing to consider altering review processes (for example, automatic approval, expedited plan check, etc.) for energy upgrades/retrofits involving electrical, mechanical or plumbing measures enrolled in a program where third party quality assurance is mandatory?


Yes 9 37.0% No 11 45.8% I don't know 4 16.7%


Q54) Would you be willing to forego or limit building inspections for energy upgrades/retrofits involving electrical, mechanical or plumbing measures enrolled in a program where third party quality assurance is mandatory?


Yes 8 33.3% No 12 50.0% I don't know 4 16.7%


Yes 26 32.1% No 41 50.6% I don't know 14 17.3%

A-16


Q55) In your experience, which of these online systems are the most helpful or easy to work with? Please check all that apply.


Accela 5 25.0% CRW Systems TRAKiT 0 0.0% Filemaker Pro 0 0.0% GreenVue Fusion 0 0.0% PermitSoft 0 0.0% Permits Plus 1 0.0% SunGard 0 0.0% I don’t know 14 70.0%


Q56) What is the average permit fee total for a typical residential HVAC installation?


Less than $250 54 67.5%

$251 - 500 6 7.5%

More than $500 0 0.0%

I don't know 17 21.2%




Q57) How are your residential permit fees structured?


Cost Recovery 30 37.5%

Flat 18 22.5%

Valuation Capped 3 3.7%

Valuation Open Ended 5 6.2%

I don’t know 18 22.5%



A-17

Chief Building Official, Plans Examiner, Building Inspector, Permit Staff/Technician

Q58) For a typical residential energy upgrade/retrofit involving mechanical HVAC alterations

measures, on average how many business days after the inspection request does the inspection

take place?


Less than 1 day 35 51.5% 2-3 days 5 7.4% 4-6 days 1 1.5% 7 days or more 1 1.5% I don't know 7 10.3% Other* 19 27.9%



Q59) Does the building department allow the contractor or homeowner to request time slots or

windows of time for the residential on-site inspection?


Yes, time slots may be requested 13 15.1% Yes, windows of time may be requested 40 46.5% Yes, both options are available 6 7.0% No 21 24.4% I don't know 6 7.0%


Q60) For a residential energy upgrade/retrofit involving electrical, mechanical or plumbing

measures, what is the average window of time given to the contractor or homeowner for the on-

site inspection?


2 hours 23 33.8% 3 - 4 hours 28 41.2% 5 - 8 hours 1 1.5% I don't know 7 10.3% Other* 9 13.2%


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Q61) How many separate inspection trips are required for a typical residential HVAC alteration?


Single comprehensive inspection 41 60.4% Two inspections 15 22.1% Three inspections 0 0.0% Four or more inspections 0 0.0% I don't know 8 11.8% Other* (please specify): 4 5.9%



Q62) How often do the building department and HERS Rater coordinate regarding on-site

inspection times for the permit inspection and (Energy Standards) measure verification?


Always 2 2.4% Frequently 2 2.4% Sometimes 6 7.1% Rarely 20 23.5% Never 36 42.4% N/A 19 22.4%

Q63) What do you think is the most effective way to increase permit compliance? Fill in

answer(s)*.


Reach Codes


Q64) Does your jurisdiction have a program or Standards in place to require building energy

efficiency above (Energy Standards)? If so, please indicate which program or Standards are in

place.


CALGreen 32 45.1% Climate Action Plan policy - 0.0% General Plan policy 2 2.8% Reach Code 3 4.2% I don't know 21 29.6% Other* (please specify): 13 18.3%


A-19

Chief Building Official, Planner

Q65) How does your jurisdiction measure the effectiveness of existing Reach Codes? Fill in

answer(s)*.


Chief Building Official, Planner, Plans Examiner

Q66) Does your jurisdiction plan to pursue any of the following approaches in 2014, in addition to the 2013 residential Energy Standards requirements? Please check all that apply.


CALGreen Tier I 5 11.6% CALGreen Tier II 2 4.6% Green Building Ordinance 4 9.3% Energy Reach Code 3 7.0% I don’t know 19 44.2% Other* (please specify): 10 23.3% *No response provided.

Training

Q67) From whom do you hear about residential energy code trainings? Check all that apply.


California Energy Commission 55 25.8% HERS Providers 14 6.6% Supervisor or colleagues 21 9.9% Trade Organizations (ICC, CALBO, CSLB, etc.) 64 30.0% Utilities 47 22.1% Other* (please specify): 12 5.6%

Q68) How do you hear about residential energy code training(s)? Please check all that apply.


Email 86 45.0% Flyer 23 12.0% Newsletters 33 17.3% Social media 5 2.6% Word of mouth 34 17.8% Other* (please specify): 10 5.2%

A-20

Q69) By which methods do you prefer to learn new aspects of the residential energy code? Please rank your answers, 1 being the most preferred method.

Rank Average Rank

Classroom training 1 2.16

Attending a conference 2 2.65

Attending a webinar/online course 3 3.46

Field training 4 3.81

Asking a peer or colleague 5 4.33

Reading a compliance manual 6 4.51

Calling the California Energy Commission hotline 7 5.40

Other* (please specify): 0 -

Q70) Which of the following factors (if any) prevent you from attending residential energy code

trainings? Please check all that apply.


Lack of interest 0 0.0% Low priority in the work place 14 11.3% No time 44 35.5% Too expensive/lack of resources to cover cost 29 23.4% Trainings do not apply to my job 18 14.5% Other* (please specify): 19 15.3%


Q71) Do contractors need training in any of the following residential energy code compliance

processes? Please check all that apply.


Basic building science 38 7.1% Compliance documentation 69 13.0% Electrical measures 44 8.3% Energy code navigation 47 8.8% Envelope measures 43 8.1% HERS requirements 62 11.6% Mechanical measures 58 10.9% Plans and specifications 46 8.6% Quality Installation 42 7.9% Title 24 requirements 74 13.9% Other* (please specify): 9 1.7%


A-21

Chief Building Official, Planner, Plans Examiner, Building Inspector, Permit Staff/Technician, Contractor, Permit Service Provider

Q72) What residential energy code training do you think raters/energy consultants need?

Q73) With what aspects of the residential energy code do Building Department staff need the

most targeted training? Please check all that apply. Please list other aspects of the energy code

that you think staff needs targeted training in:


Q74) Are you interested in learning more about solar photovoltaic permitting streamlining?


Yes 34 34%

No 58 66%

END OF SURVEY RESULTS

Count


Plans Examiner

Building Inspector

Permit Technician

Planner

Basic building

125 17.6% 20.0% 22.4% 28.0% 12.0%

Compliance

179 17.3% 25.1% 28.5% 24.0% 5.0%

Electrical measures 126 17.5% 28.6% 35.7% 15.1% 3.2%

Energy code

136 16.2% 30.2% 27.9% 21.3% 4.4%

Envelope measures 138 17.4% 29.7% 30.4% 16.7% 5.8%

HERS requirements 159 18.2% 28.9% 30.8% 17.6% 4.4%

Mechanical

147 17.7% 29.9% 33.3% 14.3% 4.8%

Plans &

136 15.4% 29.4% 24.3% 22.8% 8.1%

Quality Installation 99 20.2% 17.2% 45.4% 11.1% 6.1%

Title 24

175 20.6% 26.3% 26.3% 23.4% 3.4%

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APPENDIX B: Residential HVAC Alteration Permit Compliance Resources

Air Conditioning Contractors of America (ACCA):

• Quality Standards http://www.acca.org/standards/quality

• QA Contractor Directory http://www.acca.org/qa/qa-directory

• Existing Homes Program http://www.acca.org/qa/existing-homes

• Residential HVAC Quality Installation http://www.acca.org/certification/residential-design

Bay Area Regional Energy Network https://www.bayren.org/

• Codes and Standards Program https://www.bayrencodes.org/

CA Association of Building Energy Consultants (CABEC) https://cabec.org/

California Energy Commission:

• 2016 Building Energy Efficiency Standards

http://www.energy.ca.gov/title24/2016standards/

• 2013 Building Energy Efficiency Standards


• Online Resource Center http://www.energy.ca.gov/title24/orc/

• Energy Efficiency in Existing Buildings http://www.energy.ca.gov/ab758/

Center for Sustainable Energy (CSE) https://energycenter.org/

Contractors State Licensing Board (CSLB) http://www.cslb.ca.gov/

• For Building Officials

http://www.cslb.ca.gov/Consumers/Building_Officials/

Energy Code Ace http://energycodeace.com/

International Code Council (ICC) http://www.iccsafe.org/

SoCal Regional Energy Network http://www.theenergynetwork.com/

Western HVAC Performance Alliance (WHPA) http://www.performancealliance.org/

http://www.acca.org/standards/quality

http://www.acca.org/qa/qa-directory

http://www.acca.org/qa/existing-homes

http://www.acca.org/certification/residential-design

http://www.acca.org/certification/residential-design

https://www.bayren.org/

https://www.bayrencodes.org/



http://www.energy.ca.gov/title24/orc/

http://www.energy.ca.gov/ab758/

https://energycenter.org/

http://www.cslb.ca.gov/

http://www.cslb.ca.gov/Consumers/Building_Officials/

http://energycodeace.com/

http://www.iccsafe.org/Pages/default.aspx?usertoken=%7btoken%7d&Site=icc

http://www.theenergynetwork.com/

http://www.performancealliance.org/

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APPENDIX C – Example ICC Scorecard

Residential Mechanical Alterations: Recommendations for ...that “Heating, Ventilation, and Air...

Documents

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