What the exemption actually covers
L&I's windows and doors standard spells it out: no permit is required to replace non-fire-resistance-rated windows or doors without structural change on one- and two-family dwellings, with no change in the location, shape or size of the existing opening (EZ Permit Standards: Windows and Doors).
That leaves out a few common rowhome jobs:
- Making an opening wider or taller, or turning a window into a door.
- Cutting a new opening in an exterior wall.
- Replacing a lintel or rebuilding brick around the window.
- Any building with more than two dwelling units or commercial space. Ask L&I which rules apply before you sign.
When a permit is needed and the job fits the City's standard, it can usually be an EZ permit, with no plans required. L&I says most of those applications are processed within 5 business days, and window permits may be issued right away when a licensed, insured contractor with a current tax account applies (L&I EZ permits).
Check historic status before you order windows
Historic designation is what most often turns a simple swap into a review. The Historical Commission requires project review for replacing windows, storm windows and doors on any property on the Philadelphia Register (Historical Commission project review). Don't assume a rear window is exempt; ask staff. Replacing clear window glass alone is listed as maintenance that doesn't need review.
- Look up the property with the Commission's find a historic property or district tool. It uses the Office of Property Assessment address, which can differ from your mailing address.
- Don't go by the neighborhood name. Ask staff whether the house is individually designated or inside a local historic district. The Philadelphia Register is separate from the National Register.
- If you've received a nomination notice, the Commission can review building permit applications starting on the notification date (nomination process).
- Non-historic windows put in before designation are grandfathered. You don't have to restore them, but replacing them needs approval (information for property owners).
Commission review itself costs nothing, it can be done through eCLIPSE, and in-person reviews need an appointment. Staff approve many applications directly and refer the rest to the Architectural Committee and the full Commission at public meetings. Our guide to checking historic-designation rules before exterior work walks through the lookup.
Rules that still apply with no permit
Skipping the permit doesn't skip the safety rules. Three come up a lot in older rowhomes:
- Lead paint. If the house was built before 1978, the contractor's firm needs EPA lead-safe certification. EPA notes that window replacement is always covered by the rule, no matter how little paint is disturbed (EPA RRP rule for contractors). Don't scrape or pull apart old sashes yourself before an estimate. See what Philadelphia lead rules mean for repairs.
- Escape openings. A bedroom or basement window that serves as an emergency exit has to stay large enough to climb through. Our guide to basement emergency escape openings covers the sizes.
- Low, operable windows. The City's standard calls for safety glazing in hazardous locations and opening-control devices on operable windows within 6 feet of the ground outside. The standard also sets a maximum U-factor of 0.32 for replacement units, which is a useful number to ask about even on a permit-free job (EZ standard).
What to get in writing from the installer
- Whether this is glass only, an insert in the existing frame, or a full tear-out to the brick.
- Confirmation that the opening stays the same size and location.
- Whether any lintel, masonry or framing work is included. If it is, ask L&I what plans are needed, and bring in a structural engineer for structural concerns.
- Who checks historic status and files with the Commission if it applies.
- The lead-safe firm certification number for pre-1978 homes.
For the installation side, see what a window replacement quote should say about flashing.