Unpermitted HVAC or Water Heater Replacement: Getting It Permitted Now
A swapped furnace, air conditioner or water heater counts as an alteration, so you apply for the permit now and it is judged under the code in force on that application date. Expect an approved CF1R, the installer's CF2R and, for most HVAC swaps, an ECC-Rater's CF3R after tests on the equipment already installed.
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Why a like-for-like swap still counts
Part 6 defines a repair as maintenance and treats replacing any regulated component as an alteration. The manual lists water heaters, furnaces, air conditioners and ducts as alterations, so an unpermitted swap is an undocumented alteration. The repair or alteration test shows the line.
What the permit asks for now
Section 10-103(d)1 ties approval to the Part 6 in effect on the day the permit is applied for, not the day the equipment went in. The CF1R is approved before the permit or, if the department wants no plans for a changeout that needs verification, before final. The manual also lets a department accept an unregistered CF1R-ALT-03-E or CF1R-ALT-04-E to open an HVAC changeout permit, with the registered CF1R-ALT-02-E shown at final.
Tests on equipment already in place
- A new air handler, condensing unit or coil triggers a duct leakage test: 10 percent of airflow or less, or 7 percent or less to outside, or a smoke test by an ECC-Rater when neither is reachable. Ducts documented as already sealed, and runs under 40 linear feet, are excepted.
- New refrigerant-carrying parts add a setback thermostat, an airflow check at 300 cfm per ton for heat pumps and for air-cooled air conditioners in climate zones 2 and 8 to 15, and a refrigerant charge verification.
- A water heater must fit an option in Section 150.2(b)1H, such as gas, propane or a qualifying heat pump unit, with accessible piping insulated. A water heater swap needs no field verification, so the department may ask for little paperwork.
If a test fails
An alteration is tested on its own, never in a sample group, and the department cannot approve it without a registered CF1R, CF2R and CF3R. A failed duct test means sealing and a retest. The CF2R is signed by the person responsible for the installation, so ask early who may sign if the original installer is gone. Whether a retroactive permit exists is a local decision. See HVAC permits, water heater permits and the HVAC CF1R. Our residential reports cover alterations.
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
Usually not, because a water heater alone rarely needs field verification. The department may ask for a simplified form or none, and what it requires is its call.
Part 1 ties the department's written approval to the Part 6 in effect on the date the permit is applied for.
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