Title 24 energy compliance on a multifamily set
The 2025 Energy Code for multifamily buildings, the certificate of compliance forms, who prepares and signs them, and how the drawing set and the forms are kept in agreement.
Title 24 and the Energy Code
Title 24 of the California Code of Regulations is the California Building Standards Code. Part 6 of it is the Energy Code, written and updated by the California Energy Commission. When a practice says a project needs "Title 24," it usually means the Part 6 energy compliance documents, though the building code (Part 2), the green building code CALGreen (Part 11) and the others are all parts of the same title.
The 2025 Energy Code took effect for new buildings on January 1, 2026 (California Energy Commission). A project's applicable edition follows the date its permit application is submitted, so a multifamily set filed in late 2025 and one filed in 2026 can sit under different editions.
One building type for every height
Since the 2022 edition, the Energy Code treats multifamily buildings as one building type, whatever their height. The 2022 code moved every multifamily requirement into its own sections: mandatory requirements in Sections 160.0 to 160.9, the performance and prescriptive paths in Sections 170.0 to 170.2, and additions and alterations in Sections 180.0 to 180.4 (Energy Code Ace, multifamily buildings). Before that, a three-story walk-up and a seven-story podium building followed different parts of the code.
Height still matters for the paperwork. The Energy Commission's 2025 Multifamily Compliance Manual sends buildings of three habitable stories or fewer to the LMCC certificate of compliance forms and buildings of four habitable stories or more to the NRCC forms (CEC 2025 Multifamily Compliance Manual). Most podium buildings land on the NRCC side.
The two compliance paths
A multifamily project meets the Energy Code in one of two ways:
- Prescriptive. Every component meets the listed requirement: wall, roof and floor insulation, window performance, lighting, mechanical equipment, water heating. The forms record each component.
- Performance. An approved compliance software models the proposed building and compares its energy use to a standard design of the same shape. Components can trade off, so better windows can offset a wall assembly, as long as the whole building meets the target.
Both paths sit on top of the mandatory requirements, which apply whichever path is chosen. The performance path gives the design the most room, which is why it is the common choice on larger buildings.
Who prepares and who signs the forms
The certificate of compliance is usually prepared by an energy consultant, and two signatures go on it. The person who prepares the documents is the documentation author and signs a declaration that the information is accurate and complete. The person eligible under the Business and Professions Code to take responsibility for the building design, the responsible person, signs to accept that responsibility (Energy Code Ace, Section 10-103). Where the document has to be registered with a data registry, the signatures are electronic.
The practice drawing the set does not prepare the forms, but it owns the half of compliance that most often fails at plan check: making the drawings agree with them.
What the drawings must show
Section 10-103 of the Energy Code ties the forms to the plans. Each building permit application includes the certificate of compliance, and where the enforcement agency requires plans and specifications, the plans have to conform to the features, materials, components and devices listed on the certificate (Energy Code Ace, Section 10-103). Plans and specifications also have to show any other feature Part 6 requires to be indicated on them.
On a multifamily set, that comes down to a short list of places where the drawings and the forms must say the same thing:
| On the forms | Where it lives on the set |
|---|---|
| Wall, roof and floor assemblies with insulation values | wall types, floor types, roof assemblies, wall sections |
| Window and door performance values | window schedule and storefront types |
| Window areas by orientation | elevations and the window schedule counts |
| Cool roof and roof assembly | roof plan and roof details |
| Heating, cooling and ventilation equipment | the mechanical drawings and schedules |
| Water heating system | the plumbing drawings |
| Lighting controls in common areas | the electrical drawings |
| Field-verified measures | notes on the general sheets, and the schedules that name them |
Where the department requires plans, Section 10-103(a)2 requires the certificate of compliance to be incorporated into the plans, so the forms are printed on sheets in the set and the plan checker reads them beside the drawings.
Where sets and forms drift apart
The usual causes of an energy correction on a multifamily set are the same few:
- a window type changed in the schedule after the energy model was built;
- an assembly drawn with less insulation than the forms list, or the reverse;
- a building's glazing area on the elevations differing from the area modeled;
- equipment selected late by the mechanical engineer that differs from the modeled equipment.
The cure is a single checkpoint: before each issue, the energy consultant and the person who updates the window schedule and wall types compare the two. On a Revit set, the window schedule and the wall types are live in the model, so the comparison is one schedule export and one form.
CALGreen touchpoints
CALGreen, Part 11 of Title 24, adds its own mandatory measures for residential buildings, and several of them land on the same sheets: electric vehicle charging spaces on the parking plans, plumbing fixture flow rates in the plumbing schedules, construction waste management in the general notes, and indoor environmental quality items in the specifications. Many jurisdictions also adopt local amendments that go beyond the state minimum, so the CALGreen sheet is often city-specific. The California location page covers how these sit alongside the rest of the California codes.
Timing in the project
Energy compliance is cheapest to get right in design development, when the assemblies and the window system are chosen. A practical sequence:
- Schematic design: confirm the compliance path and the target values with the energy consultant.
- Design development: fix the wall, roof and window types with their energy values; the first energy model is built on the DD set. The DD checklist includes this item.
- Construction documents: the final energy model is built on the near-complete set; the forms are printed on the sheets; the schedules and the forms are compared before the permit submittal.
- Plan check: energy corrections are answered by the consultant and the drawings together, so the response and the revised sheets match.
Field verification and inspection
Some Energy Code measures are verified in the field after installation. Depending on the measure and the building, that verification is done by a certified third-party rater or through acceptance testing of the installed systems, and the certificate of compliance names the measures that need it. For the drawing set, the effect is that every field-verified measure is described on the sheets the installer reads, with the performance value the rater will test.
What the energy consultant needs from the set
At each milestone the energy consultant needs the same short package, and sending it in one transmittal saves a round of questions:
- floor plans with room names and areas, and the conditioned and unconditioned zones marked;
- elevations with window sizes, so glazing area by orientation can be measured;
- the wall, floor and roof types with their insulation and layers;
- the window schedule with the selected system and its performance values;
- the mechanical, plumbing and electrical drawings at the same issue date;
- any change since the last model, listed.
Alterations and additions
The Energy Code also reaches existing multifamily buildings when they are altered or added to, under Sections 180.0 to 180.4. An adaptive reuse project, a conversion of an office building to apartments, or an addition of units on top of an existing building each brings its own compliance path, often partly prescriptive for the altered components. The drawings have to show which parts are existing and untouched, which are altered and which are new, because each group is treated differently on the forms.
Where the studio fits
TECTO Studio draws multifamily sets in your Revit model with the wall types, window schedules and assemblies kept in step with your energy consultant's forms, and checks them before each issue. The California location page and the construction documents page describe the work.