Help with Title 24 and condo remodel (heating)

[dhilbe]

We're doing a condo remodel. One item we would like to do is add recessed lighting throughout the condo. This condo was build in the 1960's and has radiant ceiling heat throughout. The act of installing the recessed lights will essentially kill the ceiling heat. We thought we would simply put electric wall heaters in the rooms that lost the ceiling heat. The permit dept didn't like that and I have since found out that electric wall heat cannot be the primary source of heat under title 24. So, I'm trying to figure out what options we might have. We live in the Santa Barbara area....so (for us) the heat really isn't that important...but we do need to have heat in the condo. Title 24 will not allow us to do floor heating either. In our condo building, gas is not an option. The HOA will not allow us to put anything outside...so I suspect a heat pump is out of the question. We are on the first floor and I'm thinking electric forced air heating might work - we have a 5 foot crawl space and I'm thinking ducting could be done - assuming the HOA will let me do that. Or, maybe we simply reinstall ceiling heat if that's OK with title 24, after we install the recessed lights, but I'm afraid that might involve tearing down all the existing ceiling drywall...ugh. I'm really at a loss and somewhat find it frustrating that a relatively simply thing as installing recessed lights is causing all this effort. Any thoughts/ideas? Thanks, Dave

 

[classicT]

Ceiling heat? Are you sure? Are you referring to electric resistance heaters with a fan unit?

If it is a radiant heat system, it is typically installed in the floor, as heat rises. If installed on the ceiling, it would be extremely ineffective.

Keep in mind, if this is a condo with stacked units, the ceiling may be fire-resistance rated. Poking holes in the rated ceiling for can lights may be a significant issue.

 

[dhilbe]

Ceiling heat? Are you sure? Are you referring to electric resistance heaters with a fan unit?

If it is a radiant heat system, it is typically installed in the floor, as heat rises. If installed on the ceiling, it would be extremely ineffective.

Keep in mind, if this is a condo with stacked units, the ceiling may be fire-resistance rated. Poking holes in the rated ceiling for can lights may be a significant issue.

Yes...radiant (electric resistance) heating in the ceiling. Apparently the California power companies incented builders in the 1960's to install electric heat - electricity was cheap and plentiful then. From what I have read, electric ceiling resistant heating is extremely efficient...yes hot air rises...but this is not hot air...its radiant heat - so it is very efficient at heating objects below it. Apparently just like sunlight radiants heat to asphalt. Anyway...the downside of ceiling radiant heat - you can't touch the ceiling - can't cut holes, put plant hangers in the ceiling all due the risk of damaging the wiring in the ceiling. On the can lights - we are using LED can lights - my licensed electrician says they are virtually heat free - therefore they pass all local code requirements. But, this ceiling heat issue has my remodel currently stopped dead in its tracks.

 

[Joe.B]

So you have a local zoning or land use code that says you can't mount anything on the walls. Read that carefully and look for your loop hole because a heat pump really should be your go to for energy efficiency. If the ordinance specifies "wall mounted" then put the outdoor unit on the ground. You should be able to find a non-offensive outdoor location, like your back yard. Depending on your house design maybe roof mounted?

 

[dhilbe]

In California it's called Title 24. Electric wall heaters are not allowed as a room's primary source of heat - wall heaters can be secondary heat, but not primary heat source. It's appears there is very little wiggle room around that - so loopholes are essentially not there. I would consider heat a pump...but I live in a condo and the HOA will not allow anything to be placed outside the condo. My understanding is a heat pump would require something outside...so that option is off the table. I'm thinking the only option I have might be to replace the ceiling resistive heat or add (from scratch) electric forced air heat. This is all kinda silly as I live n Southern California and will only turn the heat on maybe a half dozen times per year - so I'm not worried about the on-going costs to heat the condo....as I will rarely actually turn the heat on. I'm more focused on finding the least expensive heating method that meets the title 24 requirements (which I believe is basically keeping a room at 68 degrees for some specified time). But, I have to have some sort of heat - otherwise it may be difficult to sell someday or I can never rent it without a heat source. Thanks for the comments/ideas.

 

[Joe.B]

In California it's called Title 24. Electric wall heaters are not allowed as a room's primary source of heat - wall heaters can be secondary heat, but not primary heat source.

This is a common misconception in California. Title 24 of the California Code of Regulations is the Building Standards Code, Parts 1-12. The requirements you are referring to come from Part 2.5, the CA Residential Code, and Part 6, the CA Energy Code. The energy code is often referred to as "Title 24" but that is not a stand-alone code, it's a complete regulation, on top of that you have local zoning and land use codes, and on top of that you have your HOA requirements.

The entire CA Building Standards Code (Title 24) is available for viewing at:

Codes

www.dgs.ca.gov

The relevant sections that you are referring to come from Section R303 Light, Ventilation and Heating, specifically R303.10 Required Heating:

"Where the winter design temperature in Table R301.2(1) is below 60°F (16°C), every dwelling unit shall be provided with heating facilities capable of maintaining a room temperature of not less than 68°F (20°C) at a point 3 feet (914 mm) above the floor and 2 feet (610 mm) from exterior walls in habitable rooms at the design temperature. The installation of one or more portable space heaters shall not be used to achieve compliance with this section."

Which may lead to a plan-reviewer or designer to mistakenly believe that fixed electric-resistance heaters are allowed. They're not based on:

From the Energy Code (Title 24, Part 6) the relevant sections are: Subchapter 1 All Occupancies — General Provisions, Subchapter 7 Low-Rise Residential Buildings — Mandatory Features and Devices, Subchapter 8 Low-Rise Residential Buildings — Performance and Prescriptive Compliance Approaches, and Subchapter 9 Low-Rise Residential Buildings — Additions and Alterations to Existing Low-Rise Residential Buildings.

Specifically: 150.1(c)(6) Heating system type. Heating system types shall be installed as required in Table 150.1-A or B. Table 150.1-A 150.1 do not allow "Electric-Resistive" heat.

Existing buildings are allowed to remain as they are because they were built and approved under a previous code cycle. Presumably your condo was built to code, following the applicable codes adopted at that time. Be careful because if you do work that requires a permit you may end up having to modify to current code, and your HOA does not supersede or overrule the building codes. If your HOA will not allow you to install something that meets modern code then you're stuck between a rock and a hard place. I would recommend not touching your existing radiant heat at all in any way. Consider wall sconces, table/floor lamps, or any other ways to increase lighting without modifying your ceiling in any way. If in the process of cutting holes in your ceiling you damage the radiant heat you may not be able to repair it without completely replacing it, and current code will not allow a new install. Hopefully your AHJ is reasonable and may work with you, but that's completely their decision.

 

[Joe.B]

I just happened to talk to a local HVAC contractor who said that any "electric forced air heat" source would probably also have to be heat pump based, as if the heat elements are ""electric-resistance" they are not allowed.

Two follow up questions, is the 5 foot crawl space an open ventilated space? It's possible (with an approved design) that you might be able to install the "outdoor" part of the heat pump in that space. Also, is there natural gas available in your unit? If there is that may ultimately be the easiest/cheapest way to work around this regulatory issue.

 

[dhilbe]

This is a common misconception in California. Title 24 of the California Code of Regulations is the Building Standards Code, Parts 1-12. The requirements you are referring to come from Part 2.5, the CA Residential Code, and Part 6, the CA Energy Code. The energy code is often referred to as "Title 24" but that is not a stand-alone code, it's a complete regulation, on top of that you have local zoning and land use codes, and on top of that you have your HOA requirements.

The entire CA Building Standards Code (Title 24) is available for viewing at:

Codes

www.dgs.ca.gov

The relevant sections that you are referring to come from Section R303 Light, Ventilation and Heating, specifically R303.10 Required Heating:

"Where the winter design temperature in Table R301.2(1) is below 60°F (16°C), every dwelling unit shall be provided with heating facilities capable of maintaining a room temperature of not less than 68°F (20°C) at a point 3 feet (914 mm) above the floor and 2 feet (610 mm) from exterior walls in habitable rooms at the design temperature. The installation of one or more portable space heaters shall not be used to achieve compliance with this section."

Which may lead to a plan-reviewer or designer to mistakenly believe that fixed electric-resistance heaters are allowed. They're not based on:

From the Energy Code (Title 24, Part 6) the relevant sections are: Subchapter 1 All Occupancies — General Provisions, Subchapter 7 Low-Rise Residential Buildings — Mandatory Features and Devices, Subchapter 8 Low-Rise Residential Buildings — Performance and Prescriptive Compliance Approaches, and Subchapter 9 Low-Rise Residential Buildings — Additions and Alterations to Existing Low-Rise Residential Buildings.

Specifically: 150.1(c)(6) Heating system type. Heating system types shall be installed as required in Table 150.1-A or B. Table 150.1-A 150.1 do not allow "Electric-Resistive" heat.

Existing buildings are allowed to remain as they are because they were built and approved under a previous code cycle. Presumably your condo was built to code, following the applicable codes adopted at that time. Be careful because if you do work that requires a permit you may end up having to modify to current code, and your HOA does not supersede or overrule the building codes. If your HOA will not allow you to install something that meets modern code then you're stuck between a rock and a hard place. I would recommend not touching your existing radiant heat at all in any way. Consider wall sconces, table/floor lamps, or any other ways to increase lighting without modifying your ceiling in any way. If in the process of cutting holes in your ceiling you damage the radiant heat you may not be able to repair it without completely replacing it, and current code will not allow a new install. Hopefully your AHJ is reasonable and may work with you, but that's completely their decision.

Thank you Joe....very useful info. Unfortunately, I may already be stuck. We opened part of the ceiling to assess the removal of a load-bearing wall. That effort destroyed a number of the existing heating wires in the ceiling. Ugh. Between the HOA and Title 24 requirements..could I actually be in a position where I have NO option for heating? That to me would make no sense. It seems an option should exist for heating my condo. I'm doing a remodel - which is impacting the ceiling...but what if another home owner has a severe leak in the ceiling and they need to remove the existing ceiling to repair....that will destroy the existing heat...I have to believe there is an option for them to get some sort of heat.

 

[Joe.B]

Thank you Joe....very useful info. Unfortunately, I may already be stuck. We opened part of the ceiling to assess the removal of a load-bearing wall. That effort destroyed a number of the existing heating wires in the ceiling. Ugh. Between the HOA and Title 24 requirements..could I actually be in a position where I have NO option for heating? That to me would make no sense. It seems an option should exist for heating my condo. I'm doing a remodel - which is impacting the ceiling...but what if another home owner has a severe leak in the ceiling and they need to remove the existing ceiling to repair....that will destroy the existing heat...I have to believe there is an option for them to get some sort of heat.

See my last post, status of "crawl space" or presence of natural gas may be the answer.