9c
25-88496
CITY OF GLENDALE, CALIFORNIA
REPORT TO THE CITY COUNCIL
AGENDA ITEM
Report: Residential Air Conditioner to Heat Pump Replacement (AC2HP) Reach Code.
1. Motion directing staff to prepare and return to introduce a reach code for existing single-family buildings that would require installation of a heat pump as the primary heating source, or other energy conservation improvements, in cases where an existing air conditioning system is altered or replaced, or where an air conditioning system is added.
COUNCIL ACTION
Item Type: Action Item
Approved for August 12, 2025 calendar
EXECUTIVE SUMMARY
The City of Glendale has developed and implemented a series of “Reach Codes” designed to advance building electrification, photovoltaic (PV) deployment, and electric vehicle (EV) infrastructure. These codes go beyond minimum state requirements and aim to reduce greenhouse gas (GHG) emissions, improve public health, and modernize building systems.
In 2022, Glendale adopted Reach Codes requiring all-electric construction for new buildings, including ADUs, with limited exemptions; PV systems for new non-residential and multifamily buildings; and EV charging infrastructure for a range of new residential and non-residential construction.
However, due to a 2023 federal court decision striking down Berkeley’s natural gas ban for violating the federal Energy Policy and Conservation Act (EPCA), Glendale suspended enforcement of the all-electric new construction requirement in June 2024 while continuing to enforce PV and EV provisions. In April 2025, the City Council directed staff to evaluate a new reach code referred to as the Air Conditioner to Heat Pump (AC2HP) Reach Code applicable to existing single-family homes. 9c2
25-88496
6 2
5 6
This proposed reach code specifies that when an air conditioning (AC) system is replaced or added, the homeowner must either:
1. Install a heat pump as the primary heating source; or
2. Implement alternative energy conservation upgrades, such as improved insulation, air sealing, and duct sealing.
The proposed reach code would not preclude mixed-fuel residential construction in violation of federal law.
Legal and Timing Considerations
Due to the passage of AB 130 in June 2025, commencing on September 30, 2025, AB 130 limits cities and counties from adopting local amendments (such as this reach code) to the residential building code through 2031, except under certain limited conditions. In light of these limitations, cities seeking to implement reach codes have the option of amending the existing 2022 Building Standards Code to add the new reach code before September 30, 2025, and later include the reach code in the 2025 Building Standards Code being adopted later this year based on the reach code being “substantially equivalent” to prior changes that were “in effect” as of September 30, 2025.
The second option is to include the proposed reach code in the 2025 Building Standards Code adoption process scheduled to occur before the end of 2025. The second option requires the City to show that the proposed changes are: i) “necessary to implement a local code amendment that is adopted to align with a general plan approved on or before June 10, 2025”, ii) that “permits mixed fuel residential construction consistent with federal law”, e.g. compliance with the federal Energy Policy and Conservation Act, and iii) incentivizes “all-electric construction as part of an adopted greenhouse gas emissions reduction strategy”.
Since AB 130 is new law, both these options are based on our current understanding of AB 130, but are untested. With respect to Option 1 (amending the 2022 Building Standards Code), there is time to introduce and adopt the reach code by August 26, 2025; however, if the reach code is scheduled for adoption after August 30, 2025, it would need to be adopted on an urgency basis in order to be effective before September 30, 2025.
9c3
25-88496
6 2
5 6
RECOMMENDATION
The City Council direct staff to prepare and introduce a reach code for existing single- family homes that would require installation of a heat pump as the primary heating source, or other energy conservation improvements, in cases where an existing air conditioning system is altered or replaced, or where an air conditioning system is added.
ANALYSIS
In 2022, the City hired Rincon Consultants to develop building electrification, photovoltaic (PV), and electric vehicle (EV) charging Reach Codes, which were adopted through a local amendment to the 2022 California Building and Energy Code.
The reach codes required the following:
1. Building Electrification: All new construction (including standalone accessory dwelling units (ADUs)) must be all-electric with limited exemptions and subject to an infeasibility waiver.
2. PV Infrastructure: Require non-residential and multifamily PV systems to be installed on all new buildings to offset 100 percent of projected electricity use or cover at least 50 percent of rooftop space and include an infeasibility waiver for projects unable to meet the requirement due to shading or other technical constraints.
3. EV Charging Infrastructure: Require EV charging infrastructure for new single- and multifamily dwellings, townhouses with attached private garages, multifamily dwellings with residential parking facilities, and new non-residential construction, with limited exceptions and subject to an infeasibility waiver.
At the November 1, 2022, City Council meeting, the ordinance was introduced with modifications to specific definitions and the EV infeasibility waiver process. The City Council subsequently adopted the Reach Code ordinance on November 15, 2022.
In 2019, the California Restaurant Association (CRA) sued the City of Berkeley over its ordinance banning the use of fuel gas piping in new buildings. A three-judge panel of the 9th Circuit Federal Appeals Court struck down Berkeley's ordinance in April 2023, agreeing with the CRA that the city overstepped the federal Energy and Policy Conservation Act when it passed the ban in 2019.
In 2024, the 9th Circuit declined to reconsider the decision rejecting the Berkeley, California, natural gas ban. As a result, several Cities that had natural gas bans or ordinances for new construction either halted the enforcement of the ordinance, considered alternatives, or continued with enforcement. 9c4
25-88496
6 2
5 6
In response to the 9th Circuit's decision, on June 4, 2024, the City Council directed staff to suspend enforcement of those portions of Ordinance No. 5999 that require all newly constructed buildings in Glendale to be "All-Electric." All other provisions of Ordinance No. 5999, including but not limited to those pertaining to photovoltaic requirements and EV charging, as well as all requirements in the California Building Code and/or the California Energy Code regarding electric readiness, continue to be enforced.
In April 2025, the City Council requested that staff prepare a report on the potential for adopting a reach code that requires installation of either a heat pump as the primary heating source or make other energy conservation improvements for existing single- family buildings in which an existing air conditioning system is altered or replaced, or where an air conditioning system is added.
State Law Requirements
The California Building Standards Code (CBSC), also known as Title 24 of the California Code of Regulations, is a comprehensive set of regulations that govern building design and construction in California (“Title 24”). It encompasses various parts that address different aspects, including building, residential, electrical, mechanical, plumbing, energy, fire, and green building standards. The CBSC is periodically updated, with the 2025 edition published on July 1, 2025, and effective January 1, 2026.
The code proposed by the State, or the base code, includes several provisions related to energy efficiency and electrification readiness for new single-family residential construction that will take effect regardless of any action by the City. These include:
Heat pumps for space conditioning and water heating
Solar requirements;
Battery readiness;
Electric vehicle (EV) charging readiness;
Pre-wiring for electric appliances when installing gas; and Higher minimum energy performance scores.
The California Health and Safety Code enables local jurisdictions to modify the base code and adopt different or more restrictive requirements with the caveat that the local modifications must be substantially equivalent to, or more stringent than, the building standards published in the CBSC; the local jurisdiction is required to make findings that such changes are reasonably necessary because of local geological, climatic or topographic conditions; and adopt a determination that the amendments will be cost- effective.
9c5
25-88496
6 2
5 6
Newly adopted State legislation (AB 130) and Critical Timing Impacting Adoption of Local Reach Code Amendments to the Residential Building Code On June 30, 2025, the Legislature adopted, and the Governor signed into law, Assembly Bill (AB) 130 (formerly AB 306); AB 130 became immediately effective.
Among other things, AB 130 restricts local jurisdictions from adopting local amendments to the residential building code for the next two code cycles, between October 1, 2025, and June 1, 2031, subject to six (6) limited exceptions, including changes related to home hardening and health safety, or where the changes are “substantially equivalent” to changes previously adopted that “were in effect” as of September 30, 2025, or where there is consistency with certain general plan policies.
The City Attorney's Office has reviewed the various implications of AB 130, including on how the City may proceed with adopting an AC2HP reach code. As indicated above, the City may as part of the 2025 Building Standards Code adopt a reach code that encourages the use of a heat pump or dual-fuel system, which includes a heat pump combined with a furnace, when an air conditioner is replaced or installed in existing single-family homes if the proposed local changes are “substantially equivalent to changes or modification that were previously filed [with the California Building Standards Commission] by the governing body of the city or county and were in effect as of September 30, 2025” (Emphasis added).(AB 130, Section 29, amending Health & Safety Code §17958(b)(1)). However, to meet the “substantially equivalent” standard, the City would first need to amend the existing 2022 Building Standards Code as follows:
Option 1: Amend the existing 2022 Building Standards Code to add the reach code so that it “will be in effect” before September 30, 2025. Then, when the City adopts the 2025 Building Standards Code later this year, the City can use an AB 130, exception (Health & Safety Code section 17958(b)(1)) to adopt the reach code as part of the 2025 Building Standards Code (Energy Code component) with a finding that “substantially equivalent” to the one in effect before September 30, 2025. (Exception No. 1)
Option 2: Adopt the 2025 Building Standards Code (or at least the Energy Code component) using the AB 130 exception (Health & Safety Code section 17958(b)(5)) that allows for changes or modifications that “are necessary to implement a local code amendment that is adopted to align with a general plan approved on or before June 10, 2025, and that permits mixed-fuel residential construction consistent with federal law while also incentivizing all-electric construction as part of an adopted greenhouse gas emissions reduction strategy.” (Exception No. 5) 9c6
25-88496
6 2
5 6
It is important to note that the reach code would be submitted simultaneously to both the CEC and CBSC. The reach code could not be enforced until CEC and CBSC approval is obtained. Typically, the California Energy Commission (CEC) would review and approve proposed amendments before they are submitted to the CBSC for review and approval. However, there is no statutory requirement that local energy standards must be first filed with and approved by the CEC, and there are no statutory regulations that appear to preclude filing the proposed local changes with the CEC and CBSC at the same time. Importantly, CBSC “approval” is not required in order for the CEC approved local changes to become effective, but the CBSC approval is required before the local jurisdiction can enforce the new local standards.
The AC2HP Reach Code Could Comply with two of the AB 130 Exceptions A “belt and suspenders” approach would be to amend the 2022 Building Standards Code to include the new reach code and “readopt” the reach codes as part of the 2025 Building Standards Code based on the “substantially equivalent” finding (Exception No. 1 discussed above), and also make findings in conjunction with the 2025 Building Standards Code adoption that the changes qualify for each of the three components of Exception No. 5 as follows:
1. The reach code will align with a general plan approved on or before June 10, 2025. The City adopted the current Safety Element of the General Plan on April 1, 2025. The 2025 Safety Element, Policy 5-2: Building Resilience, specifically states that the City shall amend the building code to increase the resiliency of existing and new buildings, thereby protecting residents from the impacts of extreme heat and poor air quality. The 2025 Safety Element, Program 5-2.3, specifies that the City shall consider amending the building code to require all newly installed HVAC units for existing buildings to have two-way air conditioning unit capability to provide heating and cooling by the next CBC update cycle. Adopting an AC2HP reach code is consistent with the 2025 General Plan Safety Element; it can help Glendale achieve its climate goals, improve public health, and modernize infrastructure.
2. The reach code is consistent with EPCA because it “permits mixed-fuel residential construction”. In other words, compliance with the AC2HP reach code does not preclude a residential property owner from using natural gas, which was the issue in the Berkeley case.
3. The reach code will incentivize all-electric construction as part of an adopted greenhouse gas emissions reduction strategy. The City adopted the Greener Glendale Plan in 2012. The Greener Glendale Plan has strategies to reduce GHGs which include reduction in citywide energy consumption by facilitating permitting and construction of alternative building structures, materials and site 9c7
25-88496
6 2
5 6
location; retrofitting existing development for increased energy and water efficiency, and promoting and supporting use of renewable energy. The AC2HP reach code are consistent with these strategies because they can reduce greenhouse gas emissions by replacing fossil fuel-based heating systems with electric heat pumps. Staff has reviewed studies that show AC2HP upgrades increase efficiency and are cost-effective over the system's lifecycle, especially when factoring in utility incentives and future energy savings. Electrification also reduces fire hazards associated with gas lines and appliances, enhancing community resilience.
How AC2HP works: Basic Principle
A two-way heat pump operates on the principle of the refrigeration cycle, utilizing a compressor, expansion valve, refrigerant, and two heat exchangers (one located indoors and one outdoors). It operates in two modes:
Cooling Mode (like an air conditioner)
1.Indoor Air is Warm: Warm indoor air is blown over the indoor coil, where the refrigerant absorbs heat.
2.Refrigerant is Compressed: The refrigerant is then compressed, raising its temperature and pressure.
3.Heat is Released Outside: The hot refrigerant travels to the outdoor coil, where it releases heat into the outdoor air.
4.Cooled Air Returned Indoors: The refrigerant cools down, flows back indoors, and the cycle repeats.
Result: Heat is removed from the inside and expelled outdoors, cooling a home.
Heating Mode (reverse operation). A reversing valve flips the direction of refrigerant flow.
1.Outdoor Air is Cool. Even in cold air, there's thermal energy. The refrigerant in the outdoor coil absorbs this heat.
2.Refrigerant is Compressed: The refrigerant is compressed, causing a significant increase in its temperature.
3.Heat is Released Indoors: The hot refrigerant flows to the indoor coil, releasing its heat to warm your home.
4.Cycle Repeats: Cooled refrigerant flows back outside to pick up more heat.
Result: Heat is extracted from outdoor air and transferred indoors, heating a home. 9c8
25-88496
6 2
5 6
Key Components
Compressor: Pressurizes the refrigerant to move heat.
Reversing Valve: Switches the direction of refrigerant flow between heating and cooling modes.
Expansion Valve: Reduces refrigerant pressure before it enters the evaporator coil.
Coils: Act as evaporators or condensers depending on the mode.
Diagram 1: Heat Pump Process
Ordinance Pathways
The ordinance structure is based on the voluntary requirements adopted in 2025 Title 24, Part 11, California Green Building Standards Code (CALGreen), Section A4.204.1.1 for heat pump space conditioning alterations in single-family homes (California Energy Commission, 2025). The heat pump path requires the heat pump as the primary heat source, with backup heating allowable, either provided by electric resistance or natural gas. In cases where the existing furnace remains, the heat pump is installed alongside the existing furnace, with integrated controls that allow the furnace to provide backup heating. In alignment with the 2025 Energy Code requirements, the heat pump must be sized to meet the heating load at the design heating temperature without requiring backup heat. The proposed ordinance provides alternative pathways for residents who prefer to replace their air conditioner with similar equipment, combined with additional efficiency measures, rather than migrating to a heat pump system.
The proposed ordinance applies to existing single-family homes and triggers when:
1. An existing A/C system is altered or replaced, or
2. A new air conditioning (A/C) system is installed where none previously existed.
9c9
25-88496
6 2
5 6
Projects meeting these criteria must either:
1. Install a heat pump system as the primary source of space heating, OR
2. Implement a set of alternative energy conservation measures, such as:
a. Sealing ductwork to limit air leakage
b. Establish Airflow requirements
c. Improving ceiling insulation (e.g., to R-49)
d. Performing refrigerant charge verification
e. Air sealing the building envelope
f. Installing energy-efficient fan systems and thermostats Exceptions are provided for circumstances such as:
Insufficient electrical panel capacity to support heat pump installation Oversized heating load that cannot be reasonably met with a heat pump Existing hazards such as asbestos or knob-and-tube wiring AC Pathways for Heat Pump Replacements
Figure 1 illustrates two AC pathways: one with an existing duct system and another with a new duct system, alongside the heat pump pathways. The figure presents the proposed efficiency upgrade measures that would be part of a reach code (solid blue) along with the relevant requirements from Title 24, Part 6 that are triggered as part of equipment replacements (white or gradient blue). A reach code that establishes requirements when an air conditioner is replaced or a new one is installed could allow for either a heat pump to be installed or an AC, as long as the performance measures listed below are met.
Diagram 2: Heat Pump Pathways
9c10
25-88496
6 2
5 6
Costs
The California Codes and Standards (C&S) Reach Codes program, also known as the Local Energy Codes program, provides technical support to local governments considering adopting a local ordinance (reach code) intended to support meeting local and/or statewide energy efficiency and greenhouse gas (GHG) reduction goals. The program facilitates adoption and implementation of the code when requested by local jurisdictions by providing resources such as cost-effectiveness studies, model language, sample findings, and other supporting documentation.
These studies aim to ensure that the requirements do not result in buildings consuming more energy than permitted by the State's minimum standards. The analysis includes scenarios of compliance packages, options, and cost-effectiveness for all California climate zones. It evaluates building prototypes to assess the cost-effectiveness of proposed changes to Title 24 requirements. Staff have provided the Local Energy Codes team with the GWP residential electric rates, L-1-A Standard Service Rates, to undertake a cost-effectiveness study.
Cost Effective Study Results
The study (exhibit 1) analyzes the cost-effectiveness of heat pump space heater measure upgrades in existing single-family buildings that exceed the minimum state requirements under the 2025 Building Energy Efficiency Standards.
9c11
25-88496
6 2
5 6
The Local Energy Codes Team assessed the incremental costs and savings of the packages over the lifecycle of 30-years. Incremental costs represent the equipment, installation, replacement, and maintenance costs of the proposed measure relative to the 2025 Energy Code minimum requirements or standard industry practices. The following scenarios were evaluated.
1.Dual Fuel Heat Pump (DFHP Existing Furnace): Replace existing ducted AC with an electric heat pump and install controls to operate the heat pump as the primary space conditioning source and to use the existing gas furnace (78 AFUE) for backup heat when heating demands cannot be met by the heat pump. In this report, dual fuel heat pumps were modeled to disable furnace operation above an outdoor temperature of 35°F in compliance with Energy Code Section 150.0(h)7, which requires this lockout for any heat pump with supplemental heating.
2.HPSH: Replace existing ducted AC and natural gas furnace with an electric heat pump and air handler. Minimum federal efficiency.
3.High Efficiency HPSH: Replace existing ducted AC and natural gas furnace with an electric heat pump and air handler. Higher efficiency.
The primary objective of the evaluation is to identify cost-effective energy upgrade measures at the time of air conditioner replacement in single family buildings, to support the design of local ordinances requiring upgrades, which may be triggered by different events, such as at the time of a significant remodel or at burnout of mechanical equipment. Table 10 shows the analysis results for Climate Zone 9 for the standard rate L-1-A rate.
Results Summary
This analysis evaluated the feasibility and cost-effectiveness of heat pump upgrades at time of air conditioner replacement in GWP territory for homes built before 2010. The Statewide Reach Codes Team used both On-Bill and LSC-based LCC approaches to evaluate cost-effectiveness and quantify the energy cost savings associated with
9c12
25-88496
6 2
5 6
energy efficiency measures compared to the incremental costs associated with the measures.
Conclusions and Discussion:
The heat pump installation alongside the existing furnace (DFHP Existing Furnace) was found to be cost-effective under the high gas escalation and LSC cost-effective in all vintages.
The complete heat pump system installation (heat pump and air handler – HPSH) was found to be cost-effective under the high gas escalation and LSC cost-effective in all vintages.
The complete heat pump system installation with high efficiency heat pump was found to be cost-effective under the high gas escalation in the pre-1978 vintage and LSC cost-effective in all vintages, with exception to the 1992-2010 vintage. Under the modest gas escalation scenario, only the DFHP Existing Furnace in the 1978-1991 and 1992-2010 vintages were found to be cost-effective. Challenges to On-Bill cost-effectiveness include higher first costs and higher first- year utility costs due to higher electricity tariffs relative to gas tariffs. However, On-Bill cost-effectiveness improves under GWP rates compared to SCE rates, primarily because GWP electricity rates are lower.
Estimated Greenhouse Gas Emissions Impacts
Assumptions: CA grid average emissions (0.25 kg CO₂/kWh), natural gas (5.3 kg CO₂/therm), usage based on average SFH demand.
Table 6: GHG Emissions Comparison
System Type Annual CO₂ Emissions 15-Year Total
Heat Pump (ASHP) 800 – 1,200 kg 12,000 – 18,000 kg
Gas Furnace + AC 2,000 – 3,200 kg 30,000 – 48,000 kg
Incentives available across the U.S., combining federal, and utility programs inclide:
Federal Incentives (2025) Inflation Reduction Act – High-Efficiency Electric Home Rebate Program. The Inflation Reduction Act (IRA) heat pump incentives are still available in 2025, though some parts are being phased out or reassessed Federal Tax Credit: Up to $2,000 for qualifying heat pump systems oMust meet ENERGY STAR Most Efficient certification
oAvailable through December 31, 2025
9c13
25-88496
6 2
5 6
GWP Incentives. Below are current electrification rebates provided by GWP.
However, GWP are reviewing the rebates and will be providing information to the City Council in the future.
Heat Pump Mini-Split or Central Heat Pump AC: $500/Unit (up to $2,500 total) Timeline and next steps
Staff are seeking the City Council’s authorization to prepare and introduce AC2HP reach code language and submit applications to the CEC and CBSC, based on amendment to the 2022 Building Code.
Staff recommend utilizing the model language prepared by the Local Energy Codes program (Exhibit 2). To meet the September 30, 2025, code effectiveness date, the reach code ordinance could be adopted on a non-urgency basis before September 1, 2025 (Introduced August 19 and Adopted on August 26, becoming “effective” on September 26, 2025), or depending on the timing, could be presented for adoption in September on an urgency basis.
Staff reviewed other California Geen Building Standards voluntary measures. However, at this time staff have not undertaken studies to determine the feasibility of mandating the voluntary measures outlined in the table.
Occupancy Event Topic Proposed Changes
Single
Family
New Performance
margins
Higher performance margins
(0.18 to 2.7, depending upon
climate zone)
All New Outdoor
lighting
standards
Downlit and shielded
Multi
Family/Non
Residential
Addition
&
Alteration
Pools and
spas
Heat pump (gas back up
allowed) or gas with 60%
solar thermal/recovered
energy fraction.
STAKEHOLDERS/OUTREACH
9c14
25-88496
6 2
5 6
Staff presented draft reach code language to the August 7, 2025, Sustainability Commission meeting and received recommendations and direction from the Commission.
Staff provided a copy of the reach code model language to the Community Development Building Official and the GWP Clean Energy Officer in June 2025.
FISCAL IMPACT
There is no fiscal impact associated with this report.
ENVIRONMENTAL REVIEW (CEQA/NEPA)
This item is not subject to CEQA as it is not a project approval.
CAMPAIGN DISCLOSURE
This item is exempt from campaign disclosure requirements.
ALTERNATIVES TO STAFF RECOMMENDATION
1. The City Council may recommend staff to not prepare an AC2HP reach code until after the AB130 6-year restrictions expire.
2. The City Council may consider any alternates not presented by staff.
ADMINISTRATIVE ACTION
Submitted by:
John Takhtalian, Assistant City Manager
Prepared by:
David Jones, Sustainability Officer
Approved by:
Roubik R. Golanian, P.E., City Manager
EXHIBITS/ATTACHMENTS
1. Custom Cost Effectiveness Analysis: City of Glendale Ac to Heat Pump Replacement.
2. Model Reach Code Language.