Is an ECC-Rater a City Inspector? Who They Work For
No. The compliance manual calls ECC-Raters special inspectors, but for the project proponents, including the installing contractor, not for the local agency. A rater is an independent third party, normally hired by the builder or owner. The building department still decides at final inspection.
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Three people at your final
The installer tests their own work and signs the CF2R. The ECC-Rater, the role formerly called a HERS rater, verifies it independently and signs the CF3R. The city inspector checks the work against approved plans and looks at the certificates. Only the third is a public employee.
Whose agent the rater is
The single-family manual says enforcement agencies consider raters special inspectors, but warns this is not the local special inspector with ICC training. Raters are special inspectors for the project proponents, including the installer, and act as independent third-party agents. They operate independently of the providers, and some jurisdictions require a business licence. The Energy Commission expects a rater to contract with the builder, not with subcontractors, and to report straight into the registry where the builder opened the project.
What the city may still demand
- Proof of competence, to the satisfaction of the building official.
- A ban on one particular rater, or on practices it believes compromise independence.
- Its own inspector at the test, scheduled with the required inspections, to corroborate the CF2R and CF3R results.
- Independent testing arranged by the agency.
Why the city has the last word
Section 10-103(d)2 has the enforcement agency inspect the work and withhold the certificate of occupancy until compliance is verified. For a house, final inspection is not complete until then. The residential appendix adds that for a dwelling using a verified feature the agency may not approve until it holds the registered certificates. A rater’s pass is therefore evidence that the department weighs, not a ruling that binds it.
If the city questions your rater
Ask what the department wants in writing, then compare it with the manual. The Energy Commission refers independence questions to its hotline, described on the Title 24 hotline page. For the role, see what an ECC-Rater does; for the conflict rules, rater independence. Who enforces the code is covered under who enforces Title 24, and our residential reports name the tests that require a rater.
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
No. The rater is hired by the builder or building owner, and the manual expects the contract to be with the builder rather than a subcontractor.
The manual lets the building official require proof of competence and prohibit a particular rater whose independence is in question.
Explore ECC-Raters
- The Project Owner Report and Consumer Information Form: What the ECC-Rater Owes You
- What Is a Third-Party Quality Control Program, and Why Was My HVAC Final Approved Early?
- Title 24 vs the HERS Index
- What an ECC-Rater Must Do at Your Home: Be There, Measure, Photograph
- What Happens If the ECC-Rater Cannot Be Found?
View all ECC-Raters guides → · CHEERS and ECC · Title 24 guide