Your city’s free ADU plan still needs a Title 24 report.
Nineteen California cities run a free or pre-approved ADU plan program — some with plans posted, a few with the shelf still empty. In all but one of them the energy report is still the applicant’s to produce, and most of them say so in writing. Here is the wording, city by city.
The building is pre-approved. The energy model is not.
A pre-approved ADU plan is a building the city has already plan-checked. It is not an energy model. Those are two different documents, and in almost every city that publishes a free or pre-approved ADU plan set, the second one is still yours to produce — usually spelled out in the city’s own handout, sometimes as two blank sheets sitting in the middle of the drawings. I went through the published program pages, brochures and submittal checklists for the cities below and pulled the wording verbatim.
The reason is structural rather than bureaucratic. The Energy Code carries no definition of an accessory dwelling unit at all; the CEC’s 2025 Single-Family Residential Compliance Manual says so directly, and classifies an ADU by what the construction actually is — a detached unit sharing no common walls is a newly constructed building, an attached one or a garage conversion is an addition, and one created inside existing conditioned space out of existing, altered and new components is an alteration. Every one of those depends on the site: the climate zone, the orientation, the shading, what the existing house already has. A plan set drawn once for the whole city cannot answer any of that, which is exactly why the cities keep saying so in writing.
Nineteen cities, in their own words
Quotes are from each city’s live program page, brochure or submittal checklist. Where a city posts nothing about energy documents at all, it is not in this table — see the note below it.
| City | The program | What the city says about the energy documents | Who supplies the CF1R |
|---|---|---|---|
| Huntington Beach | One free prototype, 490 sf, three styles | The plan set carries two blank sheets, G-301 and G-302, “ENERGY COMPLIANCE (SUPPLEMENTAL FORMS),” and the title sheet instructs: “APPLICANT TO PROVIDE ENERGY FORMS ON SHEETS G-301 & G-302. APPLICANT FORMS MUST FOLLOW THE PERFORMANCE METHOD AS DEMONSTRATED IN THE EXAMPLE FORMS ON SHEETS T24-101 & T24-102.” | You — performance method only |
| Garden Grove | ADU Go — four city-owned plans, free | The plans “include architectural plans only (i.e., they do not include structural and site specific Title 24 plan sheets).” The residential submittal guideline adds: “Title 24 – Energy forms are required to be incorporated into plans and shall be registered and signed.” | You |
| Anaheim | Four catalogue plans, all listed free | “Some of the pre-approved plans may still require a property owner to work with a design professional to finalize the plan set for a full submittal to the City (for example: site plan, Title 24, structural details, soils report).” | You |
| Burbank | BPAP — one Burbank plan plus one accepted LADBS plan | The 01/2026 BPAP plan-check correction list has a Section Q, “ENERGY CODE REQUIREMENTS,” calling for a complete energy calculation by the Performance or Prescriptive Method, and: “Forms CF-1R and MF-1R must be reproduced on the drawings and signed by the Designer or Owner and the Document Author.” The program page adds that the report “must be on the CHEERS.org website for verification” and is “to utilize All Orientation.” | You — registered, on the sheets, all orientations |
| Torrance | Four one-story plans from two design firms | “Energy calculations” is its own named line item on the Pre-Approved Detached ADU Minimum Submittal Requirements. | You |
| Downey | AB 1332 library still empty as of the city’s own July 2026 note | “TITLE 24 ENERGY ANALYSIS: Two (2) sets of 8 ½ x 11″ completed energy calculations is required for submittal and shall be made part of plans.” The city also warns that pre-approved plans, once posted, “are only about 80% complete and will always require property-specific modifications.” | You |
| Whittier | Four one-story plans, 311–800 sf | “Building Energy Analysis Report (Title 24 Compliance)” sits on the applicant’s Step 3 document list — not inside the plan set. | You |
| Moreno Valley | Seven city-owned plans, 306–988 sf | The submittal handout puts it under uploads: “Uploads required as SUPPORTING DOCUMENTS / 1. Title 24 Energy Calculations.” | You |
| Temecula | PRADU — five pre-designed plans; the city says they are “available for free” and that “there are fees for submitting and building your PRADU” | Handout CD-70 (rev. 07/2023), item 15: “Energy Calculations will need to be updated with site specific calculations… The T24.X sheets will need to be updated.” | You — update the T24 sheets in the set |
| El Cajon | Three free city-owned plans, 560 / 649 / 802 sf | Each 14-sheet set ends with T24.1 and T24.2, “ENERGY CALCULATIONS,” and the dependent notes are left as blanks: “1. WALL INSULATION (PER T24 REPORT):____________… 6. RADIANT BARRIER: Y or N (PER T24 REPORT).” The utility plan reads “WATER HEATER AS INDICATED IN CF1R FORMS (TITLE-24).” | You — the sheets are drawn but empty |
| San Diego | Accepts County, Chula Vista and Encinitas plans under AB 1332 | Preapproved plans “must meet the City of San Diego submittal guidelines for a Building Permit” — and that list includes “California Energy Code Documentation/Title 24 energy calculations.” | You |
| San Jose | Preapproved ADU program, same-day issuance possible | Bulletin #212 puts the report on both ends: the vendor master plan needs “4. Title 24 energy documents, as applicable,” and the homeowner’s site-specific application needs “6. Title 24 energy documents as reference (an updated document is needed for minor changes).” | You |
| Santa Clara | Two vendor plans; no extra plan-review fee | “You will still need to hire a designer to complete the site-specific requirements” — the site plan, utility plan, “Energy reports (if required), and Solar PV plans (if required).” | You |
| Fremont | Preapproved list wiped by the 2025 code; one plan currently listed | The city publishes a graphic titled “PREAPPROVED ADUs — WHAT’S PREAPPROVED, & WHAT’S NOT.” Floor plan, elevations and roof plan are preapproved. Under ITEMS STILL REQUIRED: CALGreen forms and “Title 24 forms.” | You |
| Chula Vista | City Standard ADU plans, plus a designer registry | The city posts 44 energy compliance PDFs across its plan library, split by climate zone 7 or 10, slab-on-grade or raised floor, and bedroom count — then says: “These calculations will need to be updated by an Energy Consultant specific to the location of your project prior to submittal.” | City posts a starting point; you update and submit |
| Stockton | Three free city plans — studio, 1-bed, 2-bed | On a City pre-approved ADU the permit documents handed over at issuance include “Registered Energy Calcs (provided by the City).” A vendor plan is the opposite: the applicant submits “site-specific energy forms” plus a letterhead authorization. The city plans are “electric power only (no gas service)” — the city’s stated reason is “to meet the latest energy code requirements.” | The city, on its own plans |
| Modesto | Uses the Stanislaus County regional plan set; none of its own | The County’s permit-submittal list says “Heating and Air Conditioning Plan and Title 24 Energy Calculations (not required with pre-plan checked ADU Plans).” Modesto’s own ADU package is four items — “Complete set of Plans; Energy Calculations; Truss Calculations; Structural Calculations” — and states no exception for pre-approved plans. | County counter says no; the city’s own list says yes — ask before you submit |
| Sacramento | Three free Shelf Ready Plans, 367–747 sf | “These free Shelf Ready Plans meet all the 2022 Residential Building Code requirements and are all-electric.” The claim is to the Residential Code and to a superseded cycle, not to a Part 6 certificate. The separate AB 1332 preapproved list is empty: “Check back for regular updates.” | You — and check the code cycle |
| Fresno | Five pre-approved plans, three elevations each | The program page says “Pre-approved plans include plans for solar panels” and claims no energy-report exemption. The city’s new-residential submittal handout still requires exhibit 3, “A complete set of Title 24 Energy calculations,” and Fresno lists Title-24 as its own plan-check discipline. | You |
Sources are listed with each claim at the foot of this page. Program contents change; check the city’s current handout before you submit.
The two cities that flip the pattern
Stockton is the exception worth knowing about. On the city’s own three plans, the permit documents handed over at issuance include “Registered Energy Calcs (provided by the City)” — registered, not just drawn. The moment you use a vendor’s pre-approved plan instead, the same checklist asks for “site-specific energy forms” from you. Chula Vista goes halfway: it posts 44 separate energy compliance PDFs covering both of its climate zones, slab-on-grade and raised floor, by bedroom count — and then tells you those calculations “will need to be updated by an Energy Consultant specific to the location of your project prior to submittal.” A starting point, not a deliverable.
And one city says nothing at all: Escondido runs four free city-owned PAADU plans, but the word energy does not appear anywhere in its January 2023 ADU Submittal Checklist — no Title 24, no CF1R, no energy calculations. Its separate Minimum Acceptable Plan Submittals guideline does carry a “Title 24 — Energy Regulations” section marked Y for every building project type. Silence in one handout is not an exemption in the other.
What this costs you in practice
Three things tend to bite. First, orientation: a pre-approved plan can be built facing any direction, so several cities want the CF1R run for all orientations rather than one — Burbank says so on the program page. Second, the method: Huntington Beach does not leave it open, it requires the performance method to match its example sheets, so a prescriptive shortcut is off the table on the city’s own prototype. Third, the code cycle. Pre-approval is tied to the cycle it was granted in — Fremont said outright that the January 1, 2026 code change made every plan approved under the 2022 rules unusable until the designers resubmitted. Sacramento’s free plans are still described against the 2022 Residential Building Code.
None of that is a reason to skip the free plan. The plan is worth having — it is the structural, architectural and life-safety review already done. It just means the energy report, the solar question, and the site-specific sheets are a separate, small piece of work that has to land before the counter will take the package. If the city bounces it anyway, the correction path is the same as any other energy comment. What that costs does not change because the plan was free.
Prices
Flat fees, in writing before I start. No hourly, no bid package, no change-order games — the number on the quote is the number on the invoice.
Your first report with me
One per client, homes under 3,000 square feet. Full energy model, CF1R and CHEERS registration. It’s a test run — send one job and see how it goes.
Every model after the first
The standard rate once you’re a client — the second building, ADU plus main house, the next project that walks in. Back in 3 business days.
Over 3,000 square feet
Quoted from the plans before any work starts, same day.
24×36 plan-sheet set
Your CF1R laid out full size, matched to your drawing set. Comes back as a PDF you drop straight in.
Revisions
Two revisions included, plus questions any time. Past two I quote first, before I touch it.
Commercial / tenant improvement
Send the plans and you’ll have a flat quote back the same day. No deposit, no minimum.
One honest note
I’m not a licensed engineer or architect, and I don’t stamp drawings. On the CF1R I’m the documentation author — you stay the responsible designer. Nothing about your role on the job changes.
That’s on purpose. I’m not after your scope or your clients. I do one piece of the permit set — the piece that usually holds it up — and I do it fast.
Pre-approved ADU plan questions
If yours isn’t here, see the full FAQ or call and ask.
If the plan is pre-approved, why does the city still want a Title 24 report?
Because the two reviews cover different things. Pre-approval is a check of the drawing set — structure, life safety, architecture. The energy report is a check of the building against Part 6 in a specific place, and place is the variable a citywide plan cannot fix: climate zone, orientation, shading, and what the existing house already has.
Several cities say this outright. Garden Grove writes that its ADU Go plans “include architectural plans only (i.e., they do not include structural and site specific Title 24 plan sheets).” Fremont publishes a graphic listing “Title 24 forms” under items still required.
Does the free plan set at least come with the Title 24 sheets drawn in?
Often the sheet exists and is empty. El Cajon’s three free plans each end with sheets T24.1 and T24.2 titled “ENERGY CALCULATIONS,” and the dependent notes are left as underscores — wall insulation per T24 report, radiant barrier per T24 report. Huntington Beach ships sheets G-301 and G-302 blank with an instruction to fill them using the performance method.
That is a good thing, structurally: the set already has the right size and place for the forms. It just needs the model run and the sheets populated.
Is there any city where the energy report is genuinely included?
Stockton, on the city’s own three plans. Its pre-approved ADU permit checklist lists “Registered Energy Calcs (provided by the City)” among the documents handed over at issuance. That is the only fully bundled case in this set, and the exemption does not travel — on a vendor’s pre-approved plan the same city asks the applicant for site-specific energy forms.
Chula Vista is the near miss: it posts pre-run calculations for its plans, then states they must be updated by an energy consultant for the project location before submittal.
Does modifying the pre-approved plan change the energy report?
Usually yes, and it can also cost you the fast lane. Huntington Beach permits no deviation from the approved set, though the set does carry a fixed menu of pre-drawn options to pick from — porch, roofing, a rear door in lieu of a window. Burbank says changes to the preapproved drawings void the approval, down to rearranged kitchen cabinets. Santa Clara says a modified plan “may disqualify it as a pre-approved ADU and expedited review cannot be provided.”
From the energy side, anything that moves glazing, changes the envelope, or changes the equipment changes the model. Send the marked-up set rather than the catalogue version.
Does the pre-approved plan stay valid when the code cycle turns over?
No, and this is the sharpest version of the problem. Fremont published it plainly: “As a result of code changes that took effect on January 1, 2026, all preapproved ADU plans designed under the 2022 code regulations are now invalid and unable to be used by homeowners.” Stockton states each preapproval “is only valid for the current code edition in effect at time of plan check approval,” and San Francisco says the same about its program.
So check the vintage of the plan you are handed against the permit application date. More on that in the 2025 code changes.
What do you need to fill the energy sheets on a pre-approved plan?
The plan number and the plan set PDF, the parcel address, and any option selections the city lets you make — porch, roofing, window package. If the program requires all orientations or the performance method, tell me and I will run it that way.
What comes back is the registered CF1R plus the forms laid out to fit the sheet the city left blank, so the set goes in as one document rather than a plan set with a report clipped to the back.
Send the plan number and the address.
I model the pre-approved plan on your parcel, register the CF1R, and lay the forms out to drop straight into the sheets the city left blank.