HERS testing, ECC verification, and who does it
Some Title 24 measures have to be tested on the job by an independent third-party rater. Here’s what gets tested, who performs it, and where it lands in the permit.
Testing what actually got built
HERS field verification is third-party testing of specific energy measures in the building as it actually gets built — duct leakage, refrigerant charge, insulation quality, ventilation airflow and similar — carried out by an independent rater who had no hand in the construction. Under the 2025 Energy Code the same function is called ECC verification, short for Energy Code Compliance, and the person doing it is an ECC-Rater rather than a HERS Rater.
It exists because an energy model is a set of promises. The CF1R says the ducts will leak no more than a set amount, and the insulation will go in without gaps or compression. Nobody can tell that from a drawing, so the code puts a second party on site with instruments. The CEC states the purpose plainly: the program verifies that new residential buildings, additions and alterations comply with the standards, in order to protect consumers from poor construction and installations. Everything below is single-family work; three-plus-unit low-rise buildings run on the LMCC certificate instead.
HERS or ECC — which word applies to your permit
Both, depending on the code cycle. As of January 1, 2026 all HERS Providers are recognized as ECC-Providers and all HERS Raters as ECC-Raters, and field verification moved from the Title 20 HERS regulations into the Energy Code — Title 24, Part 1, Section 10-103.3. It is not retroactive: the version of the code that was in effect when the project was permitted stays the applicable version, so a 2022-cycle project is still rated to 2022 standards.
Compliance documents from earlier cycles keep saying HERS; only 2025-cycle documents say ECC. The HERS name survives with a narrower scope — whole-house ratings and home energy audits, which do not support Title 24 compliance — and rater companies may keep HERS in their business names. If you are looking for a rater, HERS is still the word most of the industry uses. The glossary has both terms in short form.
Which measures trigger it
The measures do, not the project type, and only what actually gets installed counts: a house with no ducts needs no duct leakage test. Some triggers are mandatory. Duct sealing and leakage testing is mandatory whenever a space-conditioning system uses forced-air ducts to supply conditioned air to an occupiable space, confirmed by field verification under Residential Appendix RA3.1, so a detached ADU with ducts is in the same boat as a new house. On an alteration that installs or replaces refrigerant-containing parts — compressor, condensing or evaporator coil, metering device, refrigerant piping — refrigerant charge and airflow verification applies to air-cooled air conditioners in Climate Zones 2 and 8 through 15, and to air-source heat pumps in every climate zone; on new construction, Table 150.1-A decides. Duct sealing on an alteration carries three exceptions: ducts already documented as sealed and verified, duct systems under 40 linear feet, and existing ducts constructed, insulated or sealed with asbestos. Most of that lands on change-outs.
The rest come from the performance path. When the model leans on performance better than the prescriptive minimum to pass, that has to be proven in the field. Section 150.1(b)2B lists what qualifies: SEER2, EER2 and HSPF2 ratings above the minimum, the variable-capacity heat pump option, low-leakage air handlers, heat-pump rated heating capacity at 47 and 17 degrees, whole-house fans, central fan ventilation cooling, building enclosure air leakage, and quality insulation installation. That is the part designers do not see coming: a model that squeaks by on a high-SEER2 condenser has bought a field test. The full list lives in Reference Residential Appendix RA2.2, in Tables RA2-1 through RA2-7; no fixed checklist fits every job.
How it shows up on the CF1R
The CF1R is where the list lives. It identifies the features and diagnostic results requiring verification, and the rater’s Certificate of Verification has to match it. On a 2025-cycle report the block is titled ECC FEATURE SUMMARY; on 2019 and 2022-cycle reports the same block reads HERS FEATURE SUMMARY. Blank block, nothing to test. Lines in it, somebody has to go test them.
One consequence at permit time: where compliance requires field verification, the CF1R handed to the building department has to be a registered document from an approved ECC registry, not a form filled in and printed on your own. That is in the flat fee here — I register through CHEERS, approved by the CEC as an ECC-Provider for the 2025 code on November 12, 2025. Not every permit needs a registered CF1R — the CEC still publishes non-registered fillable forms for projects that require no field verification at all.
Who performs it, and who arranges it
An independent third-party rater, and not this service. ECC-Raters are trained, tested and certified by an ECC-Provider, must operate independently, and may not hold a financial interest in the builder, designer or subcontractor signing as the Responsible Person. Nor may they do construction work on a site where they will perform the verification. The CEC calls them special inspectors for the project proponents, installing contractor included — not for the building department, which does not supply the rater.
Arranging one is the builder’s job: if the CF1R indicates ECC verification is required, the builder arranges for a certified ECC-Rater. A homeowner may hire their own rater instead, though contractors commonly offer to take that on. My end does not change either way — I am the documentation author on the CF1R and you stay the responsible designer. I do not do field verification and I do not sell it.
Where it lands in the build sequence
Three certificates, in a fixed order. The CF1R goes in at plan check, before the permit is issued. The installing contractor tests and reports on the CF2R during construction. The ECC-Rater independently verifies and submits the CF3R during the final inspection phase, before the certificate of occupancy — which the building department cannot issue until it has every required compliance document, CF3Rs included.
Some measures pull the rater out earlier. Quality insulation installation has its own framing-stage form, CF3R-ENV-21-H, so QII means a visit before drywall as well as after. Duct leakage can be tested at the rough-in stage too, before the interior finishes go on, and lands on CF3R-MCH-20-H either way. Refrigerant charge waits until the system is installed and running, on CF3R-MCH-25-H. On an HVAC change-out the front of the sequence relaxes: the registered CF1R-ALT-02 may be submitted at final inspection rather than before the permit is pulled.
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.
Field verification questions
If yours isn’t here, see the full FAQ or call and ask.
What does HERS or ECC testing cost?
The rater sets that fee, not me. The CEC says only that raters charge a variable fee, and points people to their rater or their contractor for rates — many contractors have already fixed rates with a rater company, and there can be further charges for added services such as permit processing. It is billed separately from the report either way. My flat fee covers the energy model, the CF1R and the registration, and nothing on the rater’s invoice.
Is Title 24 acceptance testing the same as HERS testing?
No. They are separate programs. Acceptance testing is the nonresidential side: Acceptance Test Technicians certified by an ATTCP perform required tests on lighting controls and mechanical systems, and the results go on a Certificate of Acceptance — which the code requires for nonresidential buildings, high-rise residential buildings, and hotels and motels. It runs on a different track from the residential CF1R, CF2R and CF3R chain, and it turns up on commercial and tenant-improvement work rather than on houses. A big enough mixed project can carry both.
Is there a HERS verification form I need to fill out?
Not one you fill out. The verification form is the CF3R, and only the rater completes and signs it — there is a separate one per measure, such as CF3R-MCH-20-H for the duct leakage diagnostic test or CF3R-ENV-22-H for QII insulation installation. The installer’s form is the CF2R. Registered CF3Rs get posted or otherwise made available at the site for the building department’s inspections, and copies are left in the dwelling for the owner at occupancy.
Does every project need field verification?
No. It depends on what gets installed and on how the model passes; verification is required only when those regulated efficiency requirements or equipment features are actually installed. The ECC feature summary on a 2025-cycle CF1R — the HERS feature summary on a 2019 or 2022-cycle one — is the list for your building. If that block is blank, there is nothing to test.
What happens if a test fails?
The builder or installer takes corrective action on the failed item, and the rater retests it to verify the fix worked. The failed result is recorded in the registry, and a failed CF3R carries a FAIL watermark. If the reason it failed is that the equipment actually installed is not what the model assumed, that is a CF1R revision rather than a rater problem — send it over and I will rerun the model.
Do you do the HERS or ECC testing yourself?
No. I build the energy model and produce the registered CF1R. Field verification is a separate trade with its own certification, performed by a rater who is independent of the builder or general contractor. When the CF1R calls for it I flag it in the email so it is not a surprise at final inspection, and the builder or the owner arranges the rater. My part stays the same either way: documentation author on the CF1R, with you as the responsible designer.
Find out what your CF1R will call for.
Send the plan set and the CF1R comes back registered, with any field verification listed on it and flagged in the email.