Title 24

The California Energy Commission (CEC) created strict regulations to reduce California’s energy consumption and provide Energy Efficiency Standards for residential and non-residential buildings. These regulations are formally titled “California Code of Regulations, Title 24, Part 6”. The Cool Roof Update adopted in 2005 further sets cool roof energy standards for design and construction of roofs in California. This new regulation added a prescriptive requirement for non-residential buildings with low slopes.

What does Title 24, Part 6 require today?
For new construction, builders must show energy compliance by either following Title 24 prescriptive requirements for building envelope, lighting and HVAC or show Title 24 compliance by running computer simulations that show the building performance exceeds that of an identical building with the prescriptive measures. For re-roofing, contractors must show energy compliance by either following Title 24 prescriptive requirements for cool roofs or by installing non-cool roofing plus roof insulation.

Title 24 prescriptive requirements include installation of roofing materials with an initial solar reflectance of 0.70 or greater and an initial thermal emittance of 0.75 or greater. Aged reflectance and emittance values will become the standard for compliance in the future.

What buildings are affected in Title 24?
All low-slope (<2:12) non-residential roofs over heated or cooled spaces are affected by Title 24 including new construction and existing buildings. Existing buildings with a re-roof area of 2,000 square feet or more as well as existing buildings with a re-roof area of more than 50% of the total roof area must all comply with the Cool Roof Prescriptive requirements. Please note that the rules are a little different for high-rise residential buildings and hotels.

Are there any exceptions?
Yes. If an existing non-residential building’s roof is a BUR or Modified Bituminous roof with a rock or gravel surface and no removal of existing layers or installation of insulation is contemplated AND there is no recoating with liquid applied coatings contemplated, then reflective roofing is not required.

How will Title 24 enforced?
Evidence of Title 24 compliance is determined by providing labels of the CRRC-rated products that are proposed when applying for a building permit. Non-complying roof systems will not be acceptable and will not be issued building permits..

What is a CRRC-rated product?
CRRC is the Cool Roof Ratings Council which is the independent and unbiased organization that establishes test criteria for compliance to Title 24. CRRC is also a clearing-house for verification and dissemination of this information. Specific labels showing compliance to Title 24 requirements are licensed to the manufacturers’ of materials that have undergone testing to CRRC protocols. These labels show the reflectivity and emissivity values for the tested roof products.

Can NIR provide CRRC-rated products?
Yes, we do use various TPO and PVC membranes that are Title 24 compliant materials. In addition, some of the white coatings used over SPF are also Title 24 compliant.

Besides CRRC-Rated Roof Products, does Title 24 have minimum insulation requirements?
Yes. Depending on the location of a building in California, minimum U-values have been established for compliance to Title 24.