Repair or Alteration? When Fixing Something Does Not Trigger Title 24
A repair is reconstruction or renewal for maintenance that does not raise the component's existing energy use, and the Energy Code does not apply to it. Replacing any component the Standards regulate is an alteration instead. The one named carve-out is glass or a sash replaced in an existing frame with equal performance.
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Three questions, in this order
- Is the work maintenance of something that is already there? Adding a new component or enlarging a system is not maintenance.
- Will the part use more energy than before? Part 6 says a repair must not increase pre-existing energy consumption.
- Is the part one the Standards regulate? Replacing a regulated component, system or piece of equipment is an alteration, whatever the reason.
Where the test lands
Storm or fire damage is a fair example. The manual says the portions rebuilt after a natural disaster follow the code in force when the owner applies for the permit, and any swapped regulated part is an alteration. The rule for glass is written out: glass replaced in an existing sash and frame, or sashes in an existing frame, are repairs if the replacement is at least equivalent to the original in performance. A new window unit in the same opening does not get that pass; see window replacement permits.
The manual's alteration list makes the other side plain: replacing a water heater, furnace, air conditioner or ducts, reroofing, adding insulation, adding window film, and replacing hardwired lighting. A like-for-like coil swap or furnace swap still counts, even though nothing new is added.
Gray cases and what follows
The chapter that was meant to give repair examples points back to the 2022 manual, so the 2025 text on this topic is the Part 6 definition. The building department makes the call on a borderline job, so ask it before assuming. If the work is an alteration that needs no field verification, Section 10-103(a)1C lets the department require no certificate or a simplified one, but that waiver does not authorise anything that breaks the code. Anything else needs a CF1R; the residential CF1R page shows what it holds. The residential reports start at the alteration scope.
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, provided the new glass in the existing sash and frame performs at least as well as the original. That is the case Section 150.2(b)1B names.
No. The manual gives reroofing as its example of replacing a component the Energy Code regulates, which makes it an alteration.
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