Why plan check rejects a CF1R.

Ten reasons a certificate comes back

Nothing in the Energy Code is called a rejection. What comes back is a correction list, and the energy line on it is usually not about the energy analysis at all. Title 24, Part 1, §10-103 makes the Certificate of Compliance a document the enforcement agency has to approve by stamp or authorized signature before the building permit issues, and it spells out what the certificate has to carry: the energy features and performance specifications required for compliance, a project name and location matching the rest of the submittal, the registration number where registration applies, a documentation author’s declaration, and the signature of the person eligible under Division 3 of the Business and Professions Code to accept responsibility for the design. Most energy corrections are a failure of one of those.

Ten of them below, each as the plan checker sees it and what actually clears it. The mechanics of how each city takes a submittal are on the plan-check hub; if a comment is already in hand, send the comment rather than reading the whole list.

1. The certificate is not on the plan sheets

What the checker sees: a loose CF1R PDF uploaded beside the drawings, and no energy sheets inside the plan set. This is the most common bounce, and designers usually read it as a local preference. It is not. §10-103(a)2A says that where the enforcement agency requires building design plans with the permit application, the applicable Certificate of Compliance documents shall be incorporated into the building design plans — and where registration is required, the copies incorporated into the plans have to be the registered ones from the data registry.

The fix: lay the registered CF1R out at sheet size and put it in the set with a sheet number, and keep the standalone report too where the city asks for both. Cities write this down in their own words, and the wording differs enough to matter:

Each line is that city’s published wording, read off its own handout. Cities revise these; the date is part of the fact.

2. It is not registered — or registered somewhere not approved for that cycle

What the checker sees: a CF1R with no registration number in the header. Under §10-103(a)1B, for low-rise residential buildings whose compliance requires field verification, the certificate and its compliance registration package have to be submitted electronically to an ECC-provider data registry, and only a registered certificate displaying the registry’s number is acceptable at plan check. The compliance manual puts the practical scope plainly: registration is required for all newly constructed homes, most additions and many alterations.

The fix: register before submitting, and check that the registry is approved for the cycle the job is on. The 2025 code replaced the HERS program’s field-verification provisions with the Energy Code Compliance program, and the CEC approves ECC-Providers separately. As of this writing the CEC’s ECC-Provider page lists CHEERS, approved November 12, 2025 for 2025-code single-family and multifamily new construction, additions, alterations and nonresidential mechanical measures, with an exclusion for prescriptive low-rise multifamily LMCC and LMCI forms; a second application, from Golden State Registry, was under staff review with no staff report posted. Cities have started writing the registry into their own checklists — Burbank’s pre-approved ADU page requires the energy compliance report and mandatory measures summary to be on the CHEERS site for verification. Who verifies what, and when, is on the HERS and ECC verification page.

3. The signature blocks are wrong, or empty

What the checker sees: a certificate signed only by the person who ran the model. The code splits the two roles. The documentation author signs a declaration that the documentation is accurate and complete; the responsible person — the one eligible under Division 3 of the Business and Professions Code to accept responsibility for the building design — signs to certify conformance with Part 6. Where registration applies, both have to be electronic signatures conforming to Reference Joint Appendix JA7. The compliance manual adds one exclusion worth knowing: the ECC-Rater is not eligible to sign the CF1R as the responsible designer.

The fix: get the responsible designer onto the registry and signed before the set goes in, and include the license number in the signature block where the designer is a licensed professional. On wood-framed single-family buildings of no more than two stories the Business and Professions Code allows an unlicensed designer, and the builder may sign in the responsible building designer block. Burbank asks for digital signatures from both the document author and the designer or owner on the reproduced forms; that is the state rule restated locally, not an extra.

4. The climate zone is wrong

What the checker sees: a zone that does not match the address. It is a fast catch and an expensive one, because the zone drives the prescriptive values and a re-run is also a re-registration. Two ways it goes wrong. A ZIP-based lookup on a ZIP that straddles zones or returns nothing at all — in Carlsbad, the CEC ZIP table has rows for 92008, 92009, 92013 and 92018 and no row for 92010 or 92011, while the city publishes Climate Zone 7 as its own design data. Or a stale city instruction: the LADBS standard-plan submittal bulletin for new single-family and ADU work tells applicants to produce compliance documents using Climate Zone 9, but that bulletin is 2019-Energy-Code vintage and still lists CBECC-Res 2019-1.1 as approved software.

The fix: resolve the zone from the address rather than the ZIP, and say so in the response when a city handout points somewhere else. The climate zone page has the lookup and the caveat that goes with it.

5. The report is on the wrong code cycle

What the checker sees: a 2022-cycle CF1R on an application filed in 2026, or a 2025 report on a job that has been sitting in plan check since 2025. §100.0(a)2 applies Part 6 to buildings for which an application for a building permit or renewal of an existing permit is filed on or after the effective date of the provisions — so a renewal filed in 2026 lands on the 2025 code even where the original application did not.

The fix: pin the cycle to the application date, in writing, before anything is re-run. What moved between the two cycles and what did not is laid out on the 2025 changes page. Applications from January 1, 2026 also need software approved for the 2025 code, which is a separate question from which version of the file happens to be open — see CBECC.

6. One orientation, on a plan that can face any way

What the checker sees: a performance CF1R run at the plotted orientation on a standard plan, a mirrored plan, or a tract model. The multiple-orientation alternative lets a plan comply regardless of orientation within the same climate zone, but only if annual energy use is calculated at all four cardinal orientations — a single CF1R showing results for north, east, south and west, with identical efficiency measures and levels complying in every one. The compliance manual says the plans examiner will verify the home complies facing all four compass points.

The fix: run cardinal compliance up front on anything that might be mirrored or repeated. Some cities require it by name: Burbank’s pre-approved ADU page states the energy compliance report is to utilize All Orientation, and the LADBS standard-plan bulletin says compliance documents shall be provided for all design orientations — noting again that the LADBS document is 2019 vintage. Only one CF1R per unique or reverse plan goes to the enforcement agency.

7. The pages came from different runs

What the checker sees: page one generated on one date and page six on another, because the model was tweaked and only some pages got re-plotted into the set. Two Santa Clara County cities police this in writing, in identical language: for the performance compliance method, all pages of the CF1R form must have the same “Report Generated” date and time, and where field verification is required the form must be registered with a provider. It is item 56 of San Jose’s ADU bulletin #211, dated 8/20/2024, and it is in Gilroy’s ADU handout, revised 03/13/2025.

The fix: re-plot the whole certificate from the final run, every page, and replace the sheets as a block. Never splice pages from two runs.

8. The drawings contradict the certificate

What the checker sees: a window schedule with U-factors that are not the ones modeled, a conditioned floor area that does not match, an equipment callout at a different efficiency. §10-103(a)2B requires the plans to conform to the specifications for the features, materials, components and devices identified on the Certificate of Compliance, and the compliance manual describes the plans examiner comparing the CF1R against the rest of the submittal item by item — envelope U-factors and SHGC, insulation and air sealing, roofing and radiant barrier, SEER2 and EER2 and AFUE, duct design and location, ventilation, water heater and piping, PV capacity and tilt.

The fix: reconcile the schedules against the certificate before submittal, and again after any design change — the same section requires that where a specification changes before construction such that the building may no longer comply, it be brought back into compliance and shown so on amended plans and an amended certificate. Some cities ask for the cross-reference explicitly: Temecula’s CD-18 wants glazing U-factor and SHGC on the finish schedule, insulation R-values in the cross-section, and the water heater, furnace and air conditioning locations shown with manufacturer, model and efficiency.

9. The field-verified measures are not carried onto the drawings

What the checker sees: a CF1R claiming duct sealing, quality insulation installation, verified airflow or refrigerant charge, and a plan set that never mentions any of it. The compliance manual lists the HVAC data the examiner expects on the plans and names mandatory, prescriptive and elective ECC measures among them. The list of features that trigger ECC field verification is long — duct sealing and duct location, low-leakage ducts and air handlers, return duct and air filter design, refrigerant charge, verified airflow and fan efficacy, verified EER2, SEER2 and HSPF2, heat pump rated heating capacity, whole-house fan, ventilation airflow, kitchen exhaust, envelope air leakage, quality insulation installation, and on the water side verified pipe insulation, the compact hot water distribution expanded credit, demand recirculation and drain water heat recovery.

The fix: put a verified-measures note on the mechanical sheet listing exactly what the certificate obliges a rater to test, and tell the contractor at bid rather than at inspection. Where verification is required, registered CF3Rs have to be in hand before the certificate of occupancy.

10. The wrong form for the scope — or a stale counter form

What the checker sees: a full performance CF1R on a water heater swap, or an obsolete over-the-counter form on a job that now needs a registered one. The 2025 forms are scope-specific: CF1R-NCB-01 for new construction, CF1R-ADD-01 and CF1R-ADD-02 for additions, CF1R-ALT-01 for alterations, CF1R-ALT-02 for HVAC changeouts, CF1R-ALT-05 for alterations needing no ECC verification. §10-103(a)1C is where counter forms come from: for alterations without field verification — the code names water heater and window replacements — and for additions under 300 square feet without field verification, agencies may at their discretion not require certificate documentation at all, or develop their own simplified version. That discretion is what puts a city form on a counter, and what lets it go stale.

The fix: ask which form the city wants for that exact scope before running anything, and treat a dated city form as a starting point rather than proof of the current rule. Whittier’s FAQ tells a homeowner replacing a water heater to submit a completed CF-1R-ALT form obtainable at the counter. Santa Cruz publishes a reach-code intake form stamped effective February 1, 2026 whose measure definitions still cite 2022 Energy Code sections, while its codified ordinance controls. El Cajon’s changeout form requires a registered copy of the CF1R-ALT-02-E plus the signed CF2R and CF3R forms to be left on site for final inspection and a copy given to the homeowner. And on HVAC changeouts specifically, §10-103 lets the registered CF1R-ALT-02 reach the agency at final inspection rather than before the permit — a genuine exception, and not a general one. The forms page has the whole family; CF1R vs CF2R vs CF3R covers who signs which.

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