California - replacement of heat/light/fan combo - does T24 allow it?

[Yikes]

Existing senior housing apartments are getting bathrooms remodeled to meet ADA. We'd like to replace the existing fan+light+heat combination ventilator in the bathroom ceiling.
The seniors have become accustomed to having their electric resistance heat, and will be very grumpy if we take them away.

I understand that we can't do resistance electric heat for new construction, but is it acceptable under current Title 24 regulations for alterations to remove replace an existing fan/light/heat combo with another fan/ light/heat combo, "like for like"?

 

[ICE]

You might have to smuggle them across the border.

The following is LA County Green Building Code:

A5.207.2.2 Electric resistance heating. Electric resistance heating systems shall not be used for space heating.


Exceptions:
1. Where an electric-resistance heating system supplements a heating system in which at least 60 percent of the annual energy requirement is supplied by site-solar or recovered energy.

2. Where the total capacity of all electric-resistanceheating systems serving the entire building is less than 10 percent of the total design output capacity of all heating equipment serving the entire building.

3. Where an electric resistance heating system serves an entire building that is not a high-rise residential or hotel/motel building; and has a conditioned floor area no greater than 5,000 square feet; and has no mechanical cooling; and is in an area where natural gas is not currently available and an extension of a natural gas system is impractical, as determined by the natural gas utility.

 

[Joe.B]

2022 CA Energy Code 180.2 Alterations. Check out:

180.2(b)(2)(A)(v) Altered space-heating system. Altered or replacement space heating systems shall not use electric resistance as the primary heat source.

There are three exceptions, but I think the wording there has you covered. I assume it's not the primary heat source, so you're good.

 

[Joe.B]

180.2(b)(2)(A)(v)

Our energy code is so wonky, but I hear that's going to change on the 2029 cycle. A complete re-org to make it more like the other codes.

 

[Yikes]

Thank you!
Exception #1 also seems to cover it, as the typical combo unit is ducted only for purposes bathroom exhaust, and the heating portion is not ducted.

2022 CEC 180.2(b)(2)(A)(v) Altered space-heating system. Altered or replacement space-heating systems shall not use electric resistance as the primary heat source.

Exception 1 to Section 180.2(b)2Av: Nonducted electric resistance space heating systems, if the existing space heating system is electric resistance.​

Exception 2 to Section 180.2(b)2Av: Ducted electric resistance space heating systems, if the existing space heating system is electric resistance and a ducted space cooling system is not being replaced or installed.​

Exception 3 to Section 180.2(b)2Av: Electric resistance space heating systems, if the existing space heating system is electric resistance in Climate Zone 6, 7, 8 or 15.​