The 2008 Title 24 requirements, which will become effective in January of 2010, will now require both HERS verification and electronic document filing and registration for all Title 24 documents, including the following:

The CF-1R Certificate of Compliance, which completed and signed by both the Title 24 Document Author and the Architect
The CF-6R Installation Certificate, completed by the installing contractor
The CF-4R Certificate of Field Verification and Diagnostic Testing, completed by the HERS Rater

Any time any of the following HERS verifications are required, all these documents will now have to be registered and filed online with a HERS Provider who is certified through CalCERTS, CHEERS, or CBPCA. This means that, starting in 2010, designing architects will need to work with a HERS provider. As certified HERS raters through CalCERTS, we can verify the following:
Duct sealing (duct blaster test)
Supply duct location, surface area and R-value
Low leakage for ducts in conditioned spaces
Low leakage for air handling systems
Verify refrigerant charge in split system air conditioners with heat pumps
Cooling coil airflow
Air handler fan watt draw
High energy efficiency ratio (High EER)
Maximum rated total cooling capacity
Evaporatively cooled condensers
Ice storage air conditioners
Building envelope sealing (door blower test)
High-quality insulation installation
Photovoltaic field verification protocol

A HERS rater can verify that insulation is properly installed
It has become obvious that, on any project there are two players that make or break a project where energy is concerned:
The first is the Title 24 Documentation Author. This is the person who creates the inputs and runs the Title 24 performance calculation model and writes up the Title 24 documents. In some jurisdictions, it is mandatory that Title 24 documents be completed by a Certified Energy Plans Examiner (CEPE) or Certified Energy Analyst (CEA) certified by CABEC. By an astonishing coincidence, we happen to have those qualifications as well.

The second player is the HERS Rater, who must be certified by CalCERTS, CBPCA, or CHEERS. The HERS rater verifies the installation of energy-efficient measures and materials, and runs the diagnostic tests that are necessary to verify that the installation agrees with the Title 24 compliance calculations.
Both of these people have official sanctions and certifications from the State of California to actually file the necessary paperwork.
Original Post
Builders and sub contractors "hate" (understatement) the HERS system and try to get away or get around it at all costs.

Are there any apparent "loopholes" in the new code language? I know that many people will try anything once and again if successful prior.
Please note that it's not the sub contractors but usually the developers, property owners and general contractors that will typically try to skate the T-24 requirements whenever possible.
For them it is strictly a cost issue and what effect these additional requirements will have on the overall cost of their building!
We provide the Title 24 documentation as part of our HVAC design and spend a great deal of time and effort trying to explain all of these requirements for compliance which may or may not include upgraded insulation, glazing, controls, duct testing, etc. but almost always meet with resistance and the typical response is usually, how can we get by without doing this additional work and meet compliance?
We advise them that they can not any longer and most are irate when told they have to have pay for an independent HERS certification but we again try to explain why this is required and the benefits of this testing in the long run to the owner and the tenants.
Not sure what else we can all do at this time except continue to educate the owners and the end users on the benefits now and in the future and continue to provide more energy efficient installations and cost effective facilities.
Here's how I pitch my services to owners when they think they should be "free" or aren't important [especially supplemental services]:

1. I first say, I want to do the project right and I want to get them the project they want and need.
2. It will take time to do it right [with emphasis].
3. If it takes time, then it will cost money for me and my staff do the work.
4. Then I ask: "What would you like me to do?"

I haven't had a client yet officially tell me to do it wrong. I don't always get to do the work, but that's their call for their building, not mine. As long as it's safe in my professional opinion, [and that's the most important thing] that's the best we can do as professionals. And with all sincerity, owners often can do things themselves more easily or economically and I really don't have a problem with them doing that.
HERS Verification procedures is still a prescriptive compliance requirement.

You can go the performance route if you don't want to do the HERS verification. To read more on the Hers procedures, please see the link below: the mechanical requirements is contained in Chapter 4.

All other 2008 documents can be downloaded at the same URL.

Suzie Chan
California Energy Commission
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