2025 Update of the Field Verification and Diagnostic Testing Requirements: California Code of Regulations Title 24, Parts 1 and 6

The Warren-Alquist Act directs the California Energy Commission (CEC) to adopt and implement the Building Energy Efficiency Standards (Energy Code) as a primary means to reduce wasteful, uneconomical, and unnecessary uses of energy.

The CEC adopted provisions in the Energy Code to verify that installations (and others) are consistent with Energy Code requirements. Poor installation of air ducts and conditioning equipment in residential buildings have been a concern since the 1980s. In 1999, the CEC promulgated the Home Energy Rating System regulations in California Code of Regulations, Title 20, Sections 1670 through 1675. These regulations provided for and regulated raters to perform field verification and diagnostic testing services.

This report presents proposed changes to the field verification and diagnostic testing program to make the program more effective in ensuring compliance with the Energy Code. As California seeks to reduce greenhouse gas emissions and, among other efforts, decarbonize buildings by installing 6 million heat pumps in buildings by 2030, clear and effective program regulations are increasingly important.

The reliance of the field verification and diagnostic testing program on the Home Energy Rating System regulations located in Title 20 has made compliance difficult for stakeholders, who have requested simplification of the Energy Code. Other deficiencies addressed in this report include issues that staff identified through various efforts, investigation of complaints, submissions to Docket Number 12-HERS-01, and information collected from the order instituting an informational proceeding (Order Number 12-1114-6).

The scope of the changes proposed in this staff report focus on conduct, responsibility, and quality assurance for the field verification and diagnostic testing program, as well as increased oversight by the CEC to improve program performance and protect consumers. The CEC intends to update the Energy Code with these proposed changes to implement improvements to this program.