Can the Same Company Prepare My CF1R and Do My ECC Test?
Yes, within limits. An ECC-Rater Company may prepare a CF1R or CF2R as documentation author, but it may not sign as the responsible person or installer. Design, permitting, construction management or responsible-person services on the same project need a Declaration of ECC-Rater Company Separation of Services filed with its ECC-Provider.
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The bundled offer, in plain terms
When a firm advertises Title 24 plus HERS testing in one package, the second half is ECC verification, the former HERS work, done by an ECC-Rater. Preparing the paperwork is allowed. Standing behind the design or the installation is not.
What the rater company may and may not sign
- It may be the documentation author of registered certificates of compliance and installation.
- It may not sign as the responsible person on a CF1R, or as the installing technician on a CF2R.
- It may sign a CF2R as authorized representative only if a written delegation from the installer is already on file with the provider.
- The compliance manual adds that the rater cannot sign the CF1R as the responsible designer or builder. The Commission has found that acting as CF2R author is not a conflict of interest.
The separation-of-services declaration
A rater company that also designs, manages construction, handles permits or supplies a responsible-person signer must file this declaration. It has to show that the people doing the extra work have no management, hiring, firing or payment authority over the rater, that they are qualified under Division 3 of the Business and Professions Code, and that the signer is legally responsible for the work. The provider keeps the declaration.
Money and family ties
The conflict rules go further. Unless that declaration is filed, a rater or company cannot own a stake worth 2,000 dollars or more in, or be employed by, the party signing as responsible person. A rater also cannot test for a business run by a close relative.
Questions for a bundled offer
- Who signs the CF1R as responsible person, and are they a different person from the rater?
- Is a separation declaration on file with the ECC-Provider?
- Can the preparer influence the rater's pay, schedule or results?
The program exists to protect consumers from poor construction. See rater independence, who completes CF3R forms, who can prepare a report and finding an ECC-Rater. Reports start on our residential page.
Common Title 24 Questions
- What is Title 24?
- Do I need a Title 24 report?
- How much does a Title 24 report cost?
- How long does a Title 24 report take?
- What is included in a Title 24 report?
- What plans do I need to upload?
Frequently Asked Questions
Preparing the CF1R as author is allowed. Acting as responsible person, or running design or permitting for the same project, requires the separation declaration. Ask to see that it is on file.
The manual expects the builder or building owner to hire the rater, and the rater must be independent of the installer. For an HVAC changeout, the installer may hire the rater only if the homeowner authorizes it. Check the rules on rater independence.
Explore Registration and Signatures
- Wet Ink or Electronic Signature: What Do Title 24 Forms Accept?
- What You Certify When You Sign a Title 24 Form
- Who Can Prepare a Title 24 Report?
- Who Signs a CF1R, and Who Is the Responsible Person?
- Why Did CHEERS Send Me a Signature Email?
View all Registration and Signatures guides → · CHEERS and ECC · Title 24 guide