Rebuilding After a Wildfire: What Title 24 Asks

Rebuilding after a fire raises two energy questions before any drawing is final: which edition of the Energy Code the new house must meet, and how the fire rules for the site shape the products the energy report has to describe. This guide was checked in October 2026 against the Energy Commission, the Governor's office and Los Angeles County. Recovery rules change by executive order, so confirm the current position with your building department before relying on it. For the Eaton Fire in Pasadena and Altadena, Title 24 in Pasadena adds the local detail.

The general rule: the code in force today

The Energy Code does not grandfather a lost house. The Energy Commission's single-family compliance manual answers the question in Example 1-1: buildings destroyed or damaged by natural disasters must comply with the Energy Code requirements in effect when the builder or owner applies for a permit, for the portions being rebuilt. Since 1 January 2026 that has been the 2025 Energy Code, so a house rebuilt from the foundation is held to the same rules as any new home, including PV under Section 150.1(c)14 and the heat pump baseline. Section 100.0(a) does let a building department, at its discretion, not require compliance for structures erected in response to a natural disaster, but that exception sits beside temporary buildings, which must be removed when the permit's time limit expires. Treat it as the department's call, never as a design assumption.

Executive Order N-29-25 and the Los Angeles fires

In July 2025 the Governor signed Executive Order N-29-25 for the January 2025 fires in Los Angeles and Ventura Counties, among them the Palisades, Eaton, Hurst, Lidia, Sunset, Woodley and Hughes fires. As the Energy Commission describes it, the order:

• lets projects that repair, restore, demolish or replace residential structures substantially damaged or destroyed in those fires continue to meet the 2022 Energy Code after the 2025 code took effect;
• suspends the PV and battery storage requirements for those rebuilt homes;
• keeps the solar-ready requirements, "as applicable".

The Governor's announcement adds that the order retains updated fire safety requirements. Los Angeles County's implementation sheet extends the PV exemption to an ADU built as part of rebuilding the primary residence, again subject to solar-ready rules. The Energy Commission restated the arrangement in January 2026 when the 2025 code took effect, and the Governor's order of that month, N-1-26, revised other recovery orders without amending this one. The relief is tied to that emergency: a home lost in another fire is rebuilt under the general rule above.

Solar-ready is the part that stays

Skipping PV does not mean ignoring the roof. Los Angeles County's sheet lists what a rebuild shows where solar-ready rules apply: a reserved roof area of 250 square feet for a single-family home, wall space for a future inverter and metering equipment, a conduit pathway from the roof to the electrical service, and a service of at least 200 amps with space reserved for a two-pole breaker. Settle one point early. In the code text, Section 110.10(a)1 applies to single-family homes in subdivisions of ten or more homes with a tentative map, which is why the Energy Commission says "as applicable", while the County's sheet lists single-family homes generally. Ask the department which reading it applies to your lot. Under the 2025 code, a home in a Wildland-Urban Interface Fire Area with a whole house fan may reserve 150 square feet instead of 250 (Exception 3 to Section 110.10(b)1A). The general rules are in solar-ready requirements.

Windows and vents in a fire hazard zone

Since 1 January 2026 the wildfire construction rules have had their own volume, the California Wildland-Urban Interface Code, Title 24 Part 7. The Building Standards Commission describes it as relocating Chapter 7A of the Building Code, Section R337 of the Residential Code and Chapter 49 of the Fire Code, with its Chapter 5 setting construction standards for buildings in designated fire hazard severity zones or WUI areas. Those rules pick the products; the energy report has to describe the products actually picked.

• Windows. The window the fire rules call for is the window the CF1R must model, with its NFRC U-factor and SHGC. The 2025 Energy Code excepts fenestration in buildings that meet Part 7 in these zones from its mandatory maximum U-factor of 0.40 (Exception 3 to Section 150.0(q)), but the prescriptive values of Table 150.1-A, or a performance trade-off, still apply. The Energy Commission lists that exception among the changes new in 2025, so ask how a rebuild on the 2022 code treats it.
• Vents. The compliance manual notes that WUI regulations require vents tested to resist the intrusion of flames and burning embers. Their mesh reduces net free area, which has to be counted when attic ventilation is sized.
• Roof. Where a solar zone is reserved, vents, flues and roof equipment must stay out of it (Section 110.10(b)3), which has to be reconciled with the roof's fire detailing.

What a rebuild report needs

1. The code edition, settled first. Tell your consultant whether the department has accepted the rebuild under Executive Order N-29-25 and which edition the plans follow. A report is modelled to one edition, so switching later means modelling again.
2. The full street address, so the climate zone is right.
3. The actual window and vent products from the fire-zone specification, with their ratings.
4. Solar-ready details on the roof and electrical plans, if the department applies them.
5. Any ADU rebuilt with the house, so it is documented on the same basis.
6. Time for field verification before final, wherever the CF1R lists it; see preparing for the ECC-Rater. The order's energy relief covers the code edition, PV and batteries, not field verification.

More Title 24 Guides

1. What Every California Homeowner Should Know About Title 24
2. 12 Things to Know Before Ordering a Title 24 Report
3. Title 24 Checklist: What to Have Ready Before You Order
4. How to Read Your CF1R, Page by Page
5. 15 Title 24 Mistakes That Trigger Plan Check Corrections
6. How to Choose a Title 24 Consultant

Frequently Asked Questions

Does Executive Order N-29-25 apply to rebuilds after other wildfires?

If my rebuild skips solar under the order, does the roof need anything?

Does an ADU rebuilt with the house also skip solar?

Where are the wildfire construction rules now?