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katandvit

What is considered as a "remodel" for Cal Title 24

11 years ago
We are planning to renovate a home, changing mostly flooring, countertops, bathroom surfaces, and appliances. There may be two small internal wall changes to enlarge closets, but nothing that will actually change the functional layout of the house. Essentially we just plan to just refurbish it.

What changes to a home are considered a "remodel" in California when it comes to Title 24 compliance? If someone re-carpets a large area of a home (>50% of floor area), I assume it's not a "remodel". If someone swaps out or adds hardwood or (Kitchen/bathroom) countertops or even changes shower surfaces and fixtures - is this really a remodel? I cannot find any definition of what changes are considered remodeling that could trigger many unrelated title 24 changes to a home. Everywhere I look, remodels are described as triggering a Title 24 compliance, but remodel isn't defined. The lack of clarity makes it hard for us to decide what we want to change. Does anyone have information about this?

Comments (14)

  • 11 years ago
    last modified: 11 years ago

    Chapter 1

    R101.2 Scope. (Page 3)

    The provisions of the International Residential Code for One- and Two-family Dwellings shall apply to the construction, alteration, movement, enlargement, replacement, repair, equipment, use and occupancy, location, removal and demolition of detached one- and two-family dwellings and townhouses not more than three stories above grade plane in height with a separate means of egress and their accessory structures.

    R102.7 Existing structures. (Page 16)

    The legal occupancy of any structure existing on the date of adoption of this code shall be permitted to continue without change, except as is specifically covered in this code, the International Property Maintenance Code or the International Fire Code, or as is deemed necessary by the building official for the general safety and welfare of the occupants and the public.

    R102.7.1 Additions, alterations or repairs.

    Additions, alterations or repairs to any structure shall conform to the requirements for a new structure without requiring the existing structure to comply with all of the requirements of this code, unless otherwise stated. Additions, alterations or repairs shall not cause an existing structure to become unsafe or adversely affect the performance of the building.

  • 11 years ago

    I think I understand the need to make Title 24 upgrades if you change anything that affects the energy requirements of a house. But we are considering a project which will be extensive, but only affect the superficial aspects of the interior of the house (flooring, bathroom surfaces and fixtures, cabinetry). I can see if the kitchen appliances (along with flooring and cabinetry) are changed it would affect Title 24 compliance on the choice of appliances, etc. What I am still not clear on is whether this is considered a "remodel" or not.

    At least in our county in California - all "remodels" of $75K and above require Title 24 compliance. Does these "remodels" trigger Title 24 changes in other parts of the house - or just the items that are being changed? If you are not changing anything about the kitchen except the flooring, cabinetry, or appliances, do you have to change the lighting too? Even more, do the changes in this one room trigger the need to change things like lighting in all of the house? We are also changing the flooring or carpeting in the bedrooms and the single ceiling light fixture in each. I assume that the light fixture needs to comply with title 24, but what else could this possibly affect?

    It makes it hard to plan the changes if we don't know what other unrelated items the changes will force to be upgraded. That is why I have been searching for a definition of a "remodel." I don't want to spend $200K on flooring and surface upgrades only to find that it triggers a mandatory $100K in unrelated changes. So I still am not clear as how to plan these upgrades while avoiding being forced to change things that are totally unrelated.


  • 11 years ago

    Fred, thanks. The wording or R102.7.1 is in direct conflict with the following county guidelines ... http://www.marincounty.org/~/media/files/departments/cd/planning/sustainability/green-building/green_building_fact_sheet_02012014.pdf

    If I read Marin County's requirements referenced above, we have to go through Title 24 compliance for any remodel costing $50K and up. But the county document does not define what constitutes a remodel. If it is only for changes requiring a permit, then the requirements are small, but if we do $150K of cabinet and floor work (no permit needed), does this trigger "green building compliance" for the whole house - albeit to a lesser level than a new home? Again, in no document can I find a definition of a "remodel" - a very important descriptor of what all this entails. It is almost as if this is not defined on purpose. How can I possibly outline the scope of a project to a contractor before I know what all the "trigger" points will be? This seems to be a "catch-22".


  • 11 years ago
    last modified: 11 years ago

    Let's start with defining Title 24

    The 2013 Triennial Edition of Title 24, California Code of Regulations (CCR) consists of the following 13 parts:

    Part 1 - California Building Standards Administrative Code

    Part 2 - California Building Code

    Part 2.5 - California Residential Building Code

    Part 3 - California Electrical Code

    Part 4 - California Mechanical Code

    Part 5 - California Plumbing Code

    Part 6 - California Energy Code

    Part 7 - (No longer published in Title 24. See Title 8, CCR)

    Part 8 - California Historical Building Code

    Part 9 - California Fire Code

    Part 10 - California Existing Building Code

    Part 11 - California Green Building Standards Code

    My first post refers to ANY form of repair or remodel regardless of how much it costs. Title 24 is not just an energy code. It is not in direct conflict with the county guidelines because (1) it would be illegal for the county to do so, and (2) when you put them in context, the energy codes are "in addition to" the requirements of just any small remodel. They fall under the "unless otherwise stated" realm. I will see if I can find some links to get you a better understanding. In the meantime, I will leave THIS LINK for future reference.

  • 11 years ago

    Sorry, and I'm not trying to be difficult, but I really am getting more confused. We just purchased a home which is only a bit over 10 years old. There is actually nothing wrong with the house, and we could move in tomorrow but instead are making some changes which would not even affect the floorplan. All the things we are replacing are issues of style and either cosmetic or (in the case of appliances) we prefer new ones to the ones which have seen a bit of wear. This means new flooring - replacing carpet, removing other carpet and replacing with hardwood, taking two bathrooms and totally replacing the surfaces with new stone tiling and plumbing fixtures. There's also repainting the house inside and out and restoring the cabinetry. Easily 80% of these changes are totally cosmetic and would not even involve a building permit. Then there are a few minor modifications - enlarging two closets (the biggest change) and replacing all kitchen and bathroom counters and plumbing. Also replacing the water heater as it is will need replacing in a few years anyway. The plumbing and water heater would likely require a permit as well as the closet enlargement.

    So, as far as the county is concerned, it is up to code as it sits today. All these changes are not cheap, and some will require counter permits. All I really am wondering is if the overall scope of the project is large and greater than 50% of floor area - does this trigger changing everything to 2015 Title 14 compliance - or just the items or areas that we are changing? Also, I am wondering if the rooms that are getting really minor changes - flooring and a single light fixture - do they need to be upgraded in any other areas because the light fixture change would trigger title 14 change in the whole room, etc.?

    The county does not specify what they consider to be a remodel. Surely someone replacing a fully carpeted house with new carpet would not need a permit even if it were greater than 50% of floor area. If so, how are our changes any different other than they are using more expensive materials and labor? Finally, would changing the water heater in all of this trigger massive code changes all over the house? I just had a water heater changed in my present house about 2 years. It involved a quick counter permit. So the issue is simply what is a "remodel" in terms of code upgrades? If it means changing the light fixtures in 3 rooms instead of 6 (one per room), then they can be deferred. I can wait until the water heater dies, etc. I can't approach a contractor with a job until I have an idea of how involved this gets in terms of code compliance and red tape. Very little is being done that could possibly involve code compliance. At some point there is a trigger for all of this. I am just confused as to how far you can go without pulling that trigger? Am I missing something here? I really just want to simplify life as much as possible and avoid any massive wide-encompassing code changes if possible. That's all. Thanks.


  • 11 years ago
    Contractors deal with these issues every day. Why not go over with yours what you have in mind? Make a specific list, point by point.
    Marin County also likely has someone, or more than one person, or a FAQ site, who/that could help.
  • 11 years ago
    last modified: 11 years ago

    There is no official definition of the word "remodel". It is intended as a generic, all-inclusive word for "construction, alteration, movement, enlargement, replacement, repair, equipment, use and occupancy, location, removal and demolition" from my first post.

    Due to R102.7.1, you will most likely need a permit for changing from carpet to hardwood or tile even though section R105 says you don't need one for replacing tile. Tile to tile, or hardwood to hardwood is assumed to already have the required structural strenght of the joists and subfloor. Changing from carpet to hardwood will normally make the floor joist non code compliant on a track house designed for carpet. You need to get a consultation from a structural engineer in order to know what the scope of work will actually be before you can get any closer to answering your original question. THIS, by the way, is also under Title 24 and would trigger a mandatory compliance for the floor joists ONLY at that point. But it may also tip the scales in favor of having to do more improvements unrelated to the floor.

    You keep referring to Title 24 like it is something that only involves your house if you spend or remodel over a certain limit. The reality is that a 10 year old house should already comply with a great deal of Title 24 anyway. It sounds like you think Title 24 is just some newly created energy code. It is not for the most part. Much of it was already in the codes, and just restructured. Water consumption (low flow fixtures) may be more restrictive now, but you are remodeling the kitchen and bathrooms anyway. Most of the other stuff in parts 6 & 11 of Title 24 are not applicable on existing construction unless you physically tear into the part of the structure for which it applies even though the Marin document refers you to these parts of Title 24, it just says you don't need to do anything. The big thing that is new is the mandatory use of energy efficient lighting. It seams to me that in the case of the lighting, there is also a time deadline for complying with the energy codes regardless of whether or not you remodel. Therefore, the only thing Marin County is really doing is saying you need to do it while doing other remodeling instead of waiting for the deadline when code enforcement forces you to do it no matter what.

    When you get done sifting through all the runaround stuff in the codes, and do what is mandatory in the areas you are doing extensive work in anyway, like the kitchens and baths, you will probably find that all there is left is changing out a few more light fixtures and maybe replacing a few switches with motion sensors. Building departments are usually very accommodating to these questions if you have done some homework on your own first. Reading parts 6 and 11 of Title 24 will help. Call the building department and make an appointment to talk to a plans examiner at the building department, or call the building inspector before they leave the office in the morning to ask them the particulars or make an appointment at the house. Quit looking for the definition of "remodel" because it doesn't matter much in your case. The Marin document only seems to differ from just Title 24 if, for instance, you were remodeling extensively everything BUT the kitchen and bathrooms. In other words, actively trying to avoid being green. The building officials will generally work with you. They are not necessarily going to make you change to the more efficient water heater right now if it is already mandatory to replace it with something more efficient when it does need replacing 5 years from now. Once you figure out what will actually need to be done anyway within the scope of what you want to do, regardless of a "trigger", you will probably find there isn't much of a trigger left.

  • 11 years ago

    Thanks, and I understand where you are coming from, but basically I prefer not to sound like a total idiot when talking to a professional. I'd rather embarrass myself than avoid basic questions. But it's sometimes nice to avoid that if possible. I like to zero in on a subject rather than talk and talk and be totally misinformed about a central issue and have to start the discussion all over again. For instance, when you talk to your tax accountant it might be nice if you know what government agencies you were accountable to pay taxes to. Yes, contractors deal with these issues every day, but it can't hurt to know the basics surrounding your situation. This I have learned over the years and it applies to virtually any professional-client situation. The more informed you are, the more informed decisions you can make. I also learned many years ago that it helps to get information from more than one source. Many times that is not necessary, but there are times where it can be most efficient if you do. Isn't that what these discussions are all about? Thanks again.


  • 11 years ago

    "basically I prefer not to sound like a total idiot when talking to a professional" Exactly why I took the time to write that all down, to get you on the right page for when you go talk to the building department. Unless you are living in an original 1950 house and want to try to keep the original toilet, shower head, and light fixtures, the codes you are concerned with are mostly bark and very little bite, especially when it comes down to the dollar limits or square footage. They will get you coming or going even without the remodel cap. It really shouldn't kick in a bunch of other codes in your case just because you pass a dollar limit. You will have to follow most if not all of them even before you get to that limit.

  • 11 years ago

    Fred: I guess our posts crossed and I didn't notice until a bit later. In the interim I changed my login name to something that I can remember. I think I get the gist of what you are saying now. I now know what I need to know to know that I know nothing. No, that isn't a convoluted sentence - it makes perfect sense to me and is exactly the place I wanted to be before I proceeded with all of this. Thank you for your post as I think you have made sense in a way that I can understand! This is all way beyond anything that I have ever dealt with before - and I just need to feel comfortable that there is some reasoning behind all of it.

    Yes, they will get me coming and going - and I expected that. That isn't too big a concern because even Marin County isn't going to turn this into a mess. The home is in pretty good shape. Most people buying it would do nothing except perhaps change the paint colors inside. Even the carpet is perfect. It is not a custom home, but not a spec home either. I think it is a high end spec home that appealed to the higher end home buyers in the early 2000's. In this part of the Bay Area it was one of the last homes to be built that was of any quality and had a decent (over 1 acre) piece of land that went with it. I know the builder in that he build our current home as well (semi-custom) in about 2000. He doesn't build junk. So, as far as title 24 requirements go, the most the county can do is make us bring the open elements up to current code - those being plumbing and lighting. Most of the home is likely current with 2013 code, and likely even surpasses it in areas. And yes, they will nickel and dime me with fees and permits. That's the lifeblood of this state. When my wife and I went to buy a new home, we knew this would likely be our last one (we are in our early 60's). I promised her that, no matter what we found - she could have it fixed and changed any way she wanted. So I intend to make good on that promise. She deserves it.

    While most of what she wants are basic things like taking perfectly good hardwood floors and replacing them with better perfectly good hardwood floors, etc. She wants a perfectly nice bathroom or two completely resurfaced - and so she shall get them. That's why the changes are somewhat cosmetic. The floor plan worked well for us - and it took us 1 1/2 years to find one that fit our needs. Unfortunately the whole place is done in modern "California boring" so she wanted to spice that up a bit.

    So I am sure (as you said) much of the title 24 compliance will likely be already be there. Much of what my wife is proposing will likely just require that the new components be brought up to current code. The plumbing and fixtures are all to current code - but she wants to replace them all anyway. I expect that our drought emergency will dictate a lot of "Green" compliance measures also - which we can do. I gather it's all on a "point rating" system - so if we really got desperate, throwing in a solar array and a bunch of heating/cooling upgrades will get us more than enough points required for a remodel.

    I guess I kind of suspected what you just told me all along, but the way it had been laid out by the county was a bit confusing for me. Now I have a second opinion that reinforces my original impression. That's all I need to know. I think we have found an excellent company to do the work - and they are Green certified as well. I now have no problem placing this in their hands and just sit back as I know that I know nothing - actually a comfortable feeling when you finally figure it out. I don't have the temperament for this kind of business, and I am very much into delegation and letting people do what they do best. What I do best is to let everyone else do what they do best. It works. That's why they do what they do. And my gut feeling is that they will do a great job in a reasonably efficient time frame. Hopefully it will be of minimal frustration and all will be fun. I expect it will cost me almost $100K to get the studies and consultations done and put other things into compliance, but the rest is pretty basic. No wonder home building around here is at a standstill. A remodel like this requires so much red tape that a custom home is likely hideously expensive. A home is a refuge for us, not a showpiece. I derive no self worth from what I own or do not own. So it all seems doable and within the cost limits I had in mind. That's enough for me. It will be enough for my wife and that's all that really matters to me. It took a bit - but I think I am ready now to put it into the hands of someone who knows what they really need to do.

  • 11 years ago

    I like to think of it as insight versus oversight. You know enough to know you don't have the insight to manage the project, but will still perform oversight on the contractors you hire.

  • 11 years ago

    One more hypothetical example for you to discuss with your builder or building dept so that you can understand how this may work out in the end with this worrisome trigger. Let's say they have increased the energy efficiency requirements of ductwork in the attic for an AC system and require a little more insulation in the exterior walls since the house was built. The most you should be required to do would be to seal the ducts that are already exposed in the attic and cover them with more insulation. But they may already be sealed because it was considered a good idea back then even if the code hadn't caught up, which I have a hard time even considering that possibility in California. So the most you would need to do is add some insulation where it is easy to get to. As for a hypothetical lack of wall insulation on the exterior of the house, this is usually taken care of by alternate means. You simply add more insulation to the attic instead, but it is only required if you have an attic that you can add insulation to. Otherwise, you get a pass because of the exceptions in the code.

    To the point, I find that many LEED certified buildings are often less "green" than a standard well built house. It seems the program has become more about using the exceptions to get around stuff and get "points" rather than common sense conservation.

  • 11 years ago
    Boy, you must be a nocturnal west coast person like I am!

    Anyway, my biggest concern is that 2,5,10 or more years down the road I will have to have something replaced like an AC compressor and find that the County wants me to disrupt the whole house to do it. Call it "preventive code compliance." I replaced a water heater two years ago at my current house. It went after 14 years which considering the water around here was pretty good. All I had to have done is to have replace the water heater. Of course these things always break when you need them, and you are at the mercy of who will come by and save you.

    What I don't want is a compressor going out and be required to check all the ducting, etc to replace it. It would take weeks to clean up after something like that and given that it will likely happen on a summer day with 100 degree temps - I don't want them to take days or weeks to finish the job. I can't open windows as I have severe allergies. So now I have to try to predict what could easily break and deal with it now. If a single repair is merely just a repair, then I am OK. But it sounds like nothing is straightforward to have fixed given the maze of code compliance, etc. No wonder people can't afford to live anymore! There is too much regulation of everything. At least with an automobile smog check you have dollar limits on what you need to do to comply. The whole process is hardest on those who can least afford it.

    I guess I am not too crazy about the 21st century. It will historically be a time when man overburdened himself with rules and regulations in a futile attempt to control everything. Even this drought we have here falls in that category. Instead of long term measures to increase collection and infrastructure, we ration by the flush. A 1.2gal per flush just makes you flush a few times. 1.5Gpm shower heads make you take a longer shower. We can't force our homes to be energy efficient beyond a point, and that money could be perhaps better spent at designing ways to utilize it better and produce it cleaner and more efficiently. But we have to justify all the people we hire in all the city halls to push paper - so we regulate instead. I knew that even a 10-15 year old house would involve lots of red tape. I just wasn't sure how and where. And it will affect what we do beyond a point. It's not just money. Time is not to be wasted. After 60 I appreciate each and every day or month and do not want to waste them.

    It all boils down to the fact that to replace bathroom tiling takes piles of paper and inspections and additions. We're just replacing tile. Instead it becomes an assault on the planet. Even worse, someone if lesser means has to live with old stuff because of all the added costs to just replace something simple. If you step back and look at it, it really can make you laugh. I will live with it, as I have no choice. Thanks.