What this code requires
Title 24 Section 150.0(m) is the California energy code requirement for duct sealing and insulation on residential HVAC systems. It sets minimum R-values for supply and return ducts located outside conditioned space and requires those ducts to be sealed to prevent conditioned air from leaking into attics, crawl spaces, and wall cavities. Compliance is verified by a certified ECC-Rater (Energy Code Compliance rater, formerly HERS) who performs a duct leakage test before walls are closed up. Single-family and multifamily projects with new or replaced duct systems nearly always trigger this section.
How to fix it
Add a duct insulation R-value note to the mechanical schedule
On your mechanical plans, update the duct schedule to explicitly state the R-value for all ducts in unconditioned space. Under Title 24 Part 6, supply and return ducts need at least R-6.0 (150.0(m)1B), and the prescriptive package (Table 150.1-A, Option B) calls for R-8 in most climate zones. Do not use a generic 'insulate per code' note. Write the actual number (e.g., 'Duct insulation: R-8 minimum on all attic supply runs'). If you're not sure which climate zone applies, look at the CF1R certificate or check the CEC's climate zone map for the project address.
Specify the sealing method by name on the plans
Plans need to call out how ducts will be sealed, not just that they will be sealed. Acceptable methods under CMC 603.1 and Title 24 150.0(m) include: mastic sealant (the most common field-applied option), fiberglass mesh tape with mastic, or UL 181-listed aluminum foil tape. Standard fabric duct tape does not qualify — it degrades over time. Add a note on the mechanical plan sheet: 'All duct joints and seams to be sealed with mastic sealant or UL 181 listed tape at all transverse joints, longitudinal seams, and connections.'
Include the ECC duct leakage test requirement on plan notes
Plan-checkers need to see that an ECC duct leakage test (the ECC program replaced HERS) is required as a condition of final. Add a note to your mechanical plans: 'Duct leakage testing by a certified ECC-Rater is required per Title 24 Section 150.0(m)11 prior to final inspection.' Confirm that the CF1R document on file with the building department lists the duct leakage test as a required verification measure. The CF1R is generated by your Title 24 energy compliance software. If the test isn't checked in the software, it won't show up on the certificate, and the plan-checker has no way to verify it.
Clarify the scope of new versus existing duct runs on the drawings
If you're adding duct runs to an existing system, your plans need to clearly show which duct segments are new and which are existing-to-remain. Mark new ductwork with a heavy solid line and existing ductwork with a dashed line (or use a legend). This lets the plan-checker confirm which sections are subject to 150.0(m). Ambiguous drawings are one of the fastest ways to trigger a second corrections round. The city can't assume what's new and what's not, so they'll default to flagging everything.
Schedule the ECC-Rater before drywall
Once your plans pass, coordinate with a certified ECC-Rater before you close up the walls and ceiling. The duct leakage test requires the ducts to be accessible. Some raters need to see the duct connections before insulation is blown in. Testing typically takes a few hours on a residential project. The rater registers the results on the Certificate of Verification (CF3R) with an ECC-Provider data registry, and the city checks the registered CF2R and CF3R at final. If you close up before the test, the city may require you to open the wall back up, which adds cost and days to the job.
Resubmit with corrected mechanical plans and an updated CF1R
When you're ready to resubmit, include: (1) updated mechanical plans showing R-values, sealing method, and ECC test note; (2) an updated CF1R from your energy compliance software reflecting the duct leakage test requirement; (3) a response letter listing each correction item and how it was addressed. Correction letters are numbered, so match your response to those numbers. A clean resubmittal with organized responses moves faster through the review queue.
Confirm climate zone R-value requirements with your energy consultant
Title 24 Part 6 duct R-value requirements vary by climate zone. California has 16 climate zones and the required R-value for attic ducts differs across them. If you're working in multiple jurisdictions, don't assume the same number applies everywhere. Your Title 24 energy consultant or the CEC's compliance software will give you the correct value for each project. Getting it wrong on the plans means a correction; getting it wrong in the field means a failed ECC test and a reopened wall.
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Why you got flagged
Here's why plan-checkers flag 150.0(m) corrections. It usually comes down to one of four scenarios.
The most common is a missing ECC verification note. Your mechanical plans show a new furnace and duct system, but there's no call-out on the plans or the CF1R certificate saying the ducts will be ECC-tested for leakage. Plan-checkers aren't going to assume the contractor will handle it. They need to see it committed on the drawings before they sign off. Without that note, the correction goes out and your job sits.
The second scenario is duct insulation underspecified. Ducts in unconditioned attics need to meet a minimum R-value under the current adopted edition of Title 24 Part 6. If your mechanical schedule just says "insulate ducts per code" with no R-value called out, that's a correction. Plan-checkers want the actual number on the plans, not a generic reference.
Third is duct sealing method not documented. Saying "seal ducts" is not enough. The plans need to specify that sealing will be done with mastic, mastic tape, or UL 181 listed tape — not standard cloth duct tape, which fails over time. If the sealing method is missing or vague, expect a correction citing 150.0(m) along with CMC 603.1.
Fourth is scope creep on existing systems. You're permitted for a bathroom addition, but you're extending the duct system to serve the new room. The moment new duct runs are added, 150.0(m) applies to the new runs, sometimes to the whole system depending on how the city reads the scope. This surprises a lot of contractors who didn't realize a small extension triggers ECC testing.
The official code
California Energy Commission — Title 24 Part 6 Building Energy Efficiency Standards
Read the source →