Title 24 vs LEED: How They Fit Together

Title 24 Part 6 is mandatory: the building department will not issue a permit until the design complies. LEED is a rating system a project chooses to pursue through the U.S. Green Building Council, and the Energy Commission's own manual confirms that a LEED building still has to meet the 2025 Energy Code.

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A requirement and a choice

Energy Code compliance is a condition of the permit. The building department checks the certificate of compliance against the drawings at plan check and the installation at inspection; Title 24 compliance walks through those steps.

LEED works the other way round. The project team registers, picks a rating system and version, completes every prerequisite and then earns points from the credits it chooses. GBCI reviews the documentation and awards a level: Certified at 40 to 49 points, Silver at 50 to 59, Gold at 60 to 79 and Platinum at 80 or more. The 2025 Nonresidential Compliance Manual settles the obvious question in Example 1-1. Does a LEED-certified building still need to meet the 2025 Energy Code? "Yes."

How USGBC uses California's codes

USGBC runs a pilot under which projects built to California's energy code and CALGreen are pre-approved for streamlining of fundamental LEED requirements, through a batch of alternative compliance paths for LEED v4. Its guidance document, version 2.0 of April 2018, sets the conditions for LEED v4 BD+C and ID+C:

  • the project is a nonresidential building that is subject to, and meets, the minimum requirements of Part 6 and Part 11;
  • the team registers its intent with USGBC and uploads the completed CALGreen checklist, signed by a licensed professional of record;
  • code compliance can then satisfy the Minimum Energy Performance prerequisite and one point under Option 1 of Optimize Energy Performance, alongside water, waste and indoor air quality items;
  • manufacturing facilities and restaurants are not eligible for the energy paths, and a project seeking more than one energy point documents it the standard LEED way.

For those extra points, USGBC published a conversion table so a team can use California compliance software results in place of the LEED v4 benchmark, which is ASHRAE 90.1-2010. That benchmark is part of why Title 24 and 90.1 are compared at all.

Check the version first

The guidance was written for LEED v4 and the 2016 California codes. USGBC now certifies under LEED v5, v4.1 and v4, and its California page describes the paths for v4 projects. Before counting on a 2025 Title 24 report to earn LEED energy credit, confirm with GBCI that the path applies to your rating system and code year.

What overlaps and what does not

LEED covers far more than energy: water, materials, waste and indoor environmental quality all carry credits. Part 6 is about energy alone. Much of LEED's other ground is closer to CALGreen, Part 11, which is why the California paths rest on the CALGreen checklist; see Title 24 vs CALGreen. The Energy Commission's manual also points out that window ratings under NFRC's Component Modeling Approach can help demonstrate above-code performance for programmes such as LEED.

Planning the work

Treat the Title 24 report as the permit document and the LEED submission as a separate deliverable that may reuse it. Settle early which LEED version you are registering, whether the California path applies, and whether the energy modelling for both can run in the same approved compliance software.

Common Title 24 Questions

  1. What is Title 24?
  2. Do I need a Title 24 report?
  3. How much does a Title 24 report cost?
  4. How long does a Title 24 report take?
  5. What is included in a Title 24 report?
  6. What plans do I need to upload?

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