Can My HVAC Contractor Do the HERS (Now ECC) Test Himself?
Your contractor can run the first test but cannot be the verifier. The installer tests his own work and signs the CF2R, and an independent ECC-Rater, the former HERS rater, then tests it again and signs the CF3R. A rater who works for the contractor, or has a financial stake in the contractor, breaks the code’s conflict-of-interest rules.
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Two tests, two signatures
The rater first confirms the installer’s CF2R is registered, then tests and signs the CF3R. Only the ECC-Rater who performed or personally supervised a test may sign its certificate (Section 10-103.3(b)2C). Even inside a Commission-approved quality control program, the program’s staff and its contractors cannot sign a CF3R as an ECC-Rater.
What independent means
Section 10-103.3(b)1A bars a rater or rater company from:
- holding a financial interest in the builder, designer or subcontractor who signs the compliance documents, meaning an investment worth 2,000 dollars or more, an ownership or debt interest, or an employer-employee relationship;
- testing for a builder, designer or subcontractor owned or operated by the rater’s close relatives, such as a spouse, parent, sibling or child, or by anyone in the same household;
- doing construction work on a site where it will also test.
The compliance manual adds that raters cannot be employees of the contractor whose work they verify, and that the Commission expects the rater to be hired by the builder or owner rather than a subcontractor, except that a changeout installer may book one when the homeowner authorizes it.
Companies that sell other services
A rater company that also designs, manages construction or handles permits on the same project must file a Declaration of ECC-Rater Company Separation of Services with its provider. It must prove the people providing those services have no management, hiring, firing or payment authority over the rater (Section 10-103.3(f)2D).
The one place contractors test
In multifamily buildings of four or more habitable stories, the Commission’s counter sheet says installing contractors conduct the testing, except for indoor air quality. Houses and low-rise buildings use an ECC-Rater.
If you doubt a rater
A building official can bar a particular rater from the jurisdiction, and a provider must investigate complaints. Once a provider verifies that a rater’s data is conflicted, it must flag it and tell the homeowner, the building department and the Commission which tests it invalidates (Section 10-103.3(b)1Bvii). To choose a rater, see how to find an ECC-Rater; for the role, what an ECC-Rater does.
Common Title 24 Questions
- When is Title 24 required for a home?
- Does a remodel need Title 24?
- Does a room addition need Title 24?
- What plans are needed for a residential Title 24 report?
- How much does a residential Title 24 report cost?
- How long does a residential Title 24 report take?
Frequently Asked Questions
Yes. The Commission has determined a rater may act as documentation author for a CF2R without breaching the conflict rules. The rater may sign for the installer only under a written delegation held by the provider, and the installer stays responsible.
No. The compliance manual says the ECC-Rater is not eligible to sign the CF1R as the responsible designer.
That is his CF2R test, a required first step. The verification still has to come from a certified ECC-Rater, and the building department cannot finish a house that needs verification without the registered CF3R.
Explore ECC-Raters
- How Much Does HERS Testing (Now ECC Verification) Cost?
- What Is an ECC-Rater?
- Which Jobs Need HERS Testing (Now ECC Verification)?
- ECC-Rater vs the Former HERS Rater in 2026
- When Does a Residential Project Need an ECC-Rater?
View all ECC-Raters guides → · CHEERS and ECC · Title 24 guide