Who Can Prepare a Title 24 Report?

The legal position, stated plainly

California does not license Title 24 documentation authors. Anyone may prepare compliance documents, and the building department's test is whether the submittal is correct and complete — not who produced it.

That surprises people, and it is worth being straight about rather than implying a requirement that does not exist. What the absence of a licence means in practice is that the quality range among providers is wide, and the burden of judging that falls on the customer.

Do you need a Title 24 engineer?

Not to prepare the report. Section 10-103(a)1, in the administrative rules that accompany the Energy Code, gives every certificate of compliance two signatures, and only one of them depends on a licence:

• the documentation author, who prepared the documents and certifies that they are accurate and complete. The Energy Commission's nonresidential compliance manual states plainly that there are no requirements for this role.
• the responsible person, who must be eligible under Division 3 of the Business and Professions Code to accept responsibility for the design, and who certifies that it complies with Part 6. Where several people share the design, each signs for their own part, or the person with chief responsibility signs for all of it.

Who may take that responsibility is settled by the licensing laws for architects and engineers, not by the Energy Code, and Section 10-101(b) says the energy regulations take nothing away from those qualifications.

Houses and small residential work

Sections 5537 and 6737.1 of the Business and Professions Code let anyone prepare plans for woodframe single-family dwellings of up to two stories and a basement, woodframe buildings of up to four dwelling units of the same height, and their garages. Where no licensed designer is required, the Commission's single-family manual lets the builder sign the CF1R as the responsible designer. If part of such a structure departs from conventional woodframe construction, the building official must require that part to be prepared and stamped by a licensed architect or engineer.

Commercial and other nonresidential work

Each NRCC is signed by whoever is responsible for that part of the design. The manual's own example is the mechanical certificate: a technician may complete it, but only the engineer of record on the design team can sign it as the responsible person. A licensed contractor may instead design the mechanical or electrical systems it will install itself, within its licence classification (Section 6737.3).

New nonresidential buildings add one licensed signature: the commissioning design review is signed by a licensed engineer or architect, or a licensed contractor under their direct supervision. Below 10,000 square feet that can be the engineer or architect of record; larger buildings need a reviewer with no other role on the project, and the largest, or those with complex mechanical systems, a third party.

Where the stamp actually goes

Nothing in Section 10-103 asks for an engineer's stamp on the energy documents themselves. Stamps go on design drawings: mechanical and electrical plans an engineer prepares carry the engineer's signature and stamp once permitted. When a licensed architect or engineer signs a CF1R, the signature block carries their licence number. The pairing the manuals describe is an energy consultant as documentation author, with the designer, builder or engineer of record signing as responsible person.

What a CEA actually is

The Certified Energy Analyst credential is administered by CABEC, the California Association of Building Energy Consultants, which is recognised by the Energy Commission for this purpose. It is not a weekend course. It requires:

• a two-part examination — multiple choice, plus a practical ACM modelling component
• verified experience, education and/or related Title 24 certifications
• completion of the Professional Practices Workshop
• at least nine hours of continuing education annually

The modelling component is the part that distinguishes it. Answering questions about the code is one skill; building a compliant model that behaves correctly is another, and the certification tests both.

Where it stops being optional

Although the code does not require a CEA, many energy efficiency programmes do — some require an active certification for participation and others recommend it. A project intending to claim a utility incentive or enter a programme may find the credential is a condition of the money, even though it was never a condition of the permit.

The stated goal of the programme is that Title 24 Part 6 analysis and documentation be authored by a CEA, so the direction of travel is toward it rather than away.

The continuing education requirement is the real signal

Nine hours a year exists because the code changes on a three-year cycle and the compliance software changes with it. Someone who qualified two cycles ago and has not kept up is working from a superseded rulebook — which is a more useful thing to ask about than how long a provider has been trading.

What to ask, whoever you use

Which code cycle they are working to, which approved software they use, whether they will handle plan check comments if any come back, and whether registration with a data registry is included where the project needs it. Those four answers tell you more than a credential alone — and a good provider will answer all four without hesitating.

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?

Explore Registration and Signatures

1. Who Signs a CF1R, and Who Is the Responsible Person?
2. Why Did CHEERS Send Me a Signature Email?
3. Who Completes CF2R Forms on a Residential Project?
4. Who Completes CF3R Forms on a Residential Project?
5. Can I Do My Own Title 24 Report?

View all Registration and Signatures guides → · CHEERS and ECC · Title 24 guide