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CITY OF GLENDALE, CALIFORNIA
REPORT TO THE CITY COUNCIL
AGENDA ITEM
Report: Local Amendments to the 2026 Edition of the California Building and Energy Code to require projects in single-family homes, duplexes and townhomes involving replacement or alteration (but not repair) of an existing air conditioning system or installation of new air conditioning systems to include either a heat pump space conditioner as the primary heating system, or install specific energy efficiency measures in addition to a new air conditioner.
1. Intro. of Ordinance of the Council of the City of Glendale, California Amending the 2026 Glendale Building and Safety Code, Volume IX (Green Building Standards) to Require Energy Conservation Measures for Air Conditioner Alterations, Replacements and Installations in Existing Single-Family Residential Buildings, and Required Findings Related Thereto.
COUNCIL ACTION
Item Type: Action Item
Approved for November 4, 2025 calendar
EXECUTIVE SUMMARY
In 2022, the City of Glendale adopted local Reach Codes requiring all-electric new construction, photovoltaic (PV) systems, and electric vehicle (EV) charging infrastructure.
Enforcement of the all-electric requirement was suspended in June 2024 following the Federal 9th Circuit Court of Appeals ruling invalidating Berkeley’s natural gas ban, while PV, EV, and electric-readiness measures remained in effect.
On August 12, 2025, the City Council directed staff to begin developing an Air Conditioner to Heat Pump (AC2HP) Reach Code to reduce greenhouse gas emissions by encouraging electrification in existing single-family homes, duplexes, and townhomes.
The proposed ordinance is based on modified CALGreen voluntary provisions and would
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require that when a new or replacement air conditioning system (excluding repairs) is installed, property owners must either install a heat pump for heating and cooling; or, retain a gas furnace but implement additional energy-efficiency upgrades.
The ordinance aims to reduce greenhouse gas emissions, advance state and local climate goals, and align with Glendale’s General Plan Safety Element, Climate Action and Adaptation Plan (CAAP), and Greener Glendale Plan. Compliance provisions vary based on whether existing ducts are reused or replaced, with specific duct sealing, airflow, and insulation requirements.
City Council also directed staff to create a heat pump rebate program that provides direct payments—rather than utility bill credits—to offset the cost difference between a heat pump and a standard air conditioner.
The ordinance was originally introduced on August 19, 2025, but failed adoption on August 26, 2025. Consequently, it could not take effect before the new September 30, 2025, statutory deadline establish by AB 130 for local code amendments to existing Building and Safety Code. However, the City still has the option to pursue reach code adoption if the proposed amendments meet certain statutory conditions in AB 130, which includes the “General Plan Exception” (Health and Safety Code §17958(b)(5)). This exception allows building and safety code amendments that are aligned with a General Plan adopted before June 10, 2025, that permit mixed-fuel construction, and support greenhouse gas reduction. Glendale adopted its updated General Plan Safety Element in April 2025. The 2025 Safety Element provides a qualifying framework for the proposed AC2HP amendments under the General Plan Exception. Additionally, the ordinance permits mixed-fuel construction in compliance with federal law, and the ordinance aligns with the goals, policies, measures and actions in the City’s Greener Glendale Plan and Climate Action and Adaptation Plan. The proposed ordinance incorporates the necessary findings for adoption of local amendments to the newly adopted 2026 Building and Safety Code.
RECOMMENDATION
That the City Council introduce an ordinance adopting local amendments to the 2026 California Building and Safety Code in the form of the proposed AC2HP reach code and make findings in accordance with Health and Safety Code section 17958, et seq..
ANALYSIS
In 2022, Glendale adopted local Reach Codes requiring all-electric new construction, photovoltaic (PV) systems, and electric vehicle (EV) charging infrastructure. Following a 2023 court ruling overturning Berkeley’s natural gas ban, the City suspended enforcement of the all-electric requirement in June 2024 but continued PV, EV, and electric-readiness 9b3
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provisions.
In April 2025, the City Council directed staff to begin exploring an air conditioner to heat pump (AC2HP) reach code applicable to existing single-family homes, duplexes, and townhomes. On August 12, 2025, Council directed staff to introduce an ordinance based on modified CALGreen voluntary provisions that would require installation of a heat pump as the primary heating source; or permit the gas furnace to be retained, but require installation of additional energy-efficiency upgrades where an air conditioning system (not including repair of existing systems) is being replaced or added. The ordinance aims to reduce greenhouse gas emissions by promoting high-efficiency heat pump technology and aligns with state climate goals, the City’s General Plan Safety Element, recently adopted Climate Action and Adaptation Plan (CAAP), the City’s Greener Glendale Plan, and which allows for mixed-fuel alternatives consistent with federal law. Compliance requirements vary depending on whether existing ducts are reused or replaced, with specific duct sealing, airflow, and insulation standards.
Further, the Council also requested staff develop a heat pump rebate program with direct payments to eligible residents (as opposed to utility bill statement credits) designed to cover the cost difference between a heat pump and a standard air conditioner replacement, and that the rebate program be considered together with the reach code ordinance.
On August 19, 2025, the Council introduced an ordinance based on modified CALGreen voluntary provisions that would amend the 2022 Glendale Building and Safety Code to require projects in single-family homes, duplexes and townhomes involving replacement or alteration (but not repair) of an existing air condition system or installation of new air conditioning systems to either include a heat pump space conditioner as the primary heating system or install specific energy efficiency measures in addition to a new air conditioner. The ordinance would require installation of a heat pump as the primary heating source; or permit the gas furnace to be retained but require installation of additional energy-efficiency upgrades where an air conditioning system (not including repair of existing systems) is being replaced or added.
At its August 26, 2025, meeting, the proposed AC2HP ordinance did not receive the votes for passage, and it was too late to bring back for later adoption in sufficient time take effect by the AB 130 September 30, 2025 deadline for adoption of local amendments to state building codes applicable to residential units. However, AB 130 (Health & Safety Code section 17958(b)) allows cities to amend, add, or repeal ordinances or regulations in the adopted Building & Safety Code which impact new requirements if express written findings can be made based on meeting one of six conditions. Here, the proposed 9b4
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AC2HP ordinance is able to meet one of the following conditions to allow amendment:
“….(5) The changes or modifications are necessary to implement a local code amendment that is adopted to align with a general plan approved on or before June 10th 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.”
Staff refers to this exception as the “General Plan Exception”, which consists of three components. First, that the amendments are aligned with a general plan adopted before June 10, 2025. Second, that the amendments permit mixed-fuel residential construction consistent with federal law, and third, that the amendments incentivize electrification as part of a greenhouse gas reduction strategy. The following analysis demonstrates the proposed AC2HP reach code qualifies under all three components of the “General Plan Exception”.
First, Glendale adopted the General Plan Safety Element on April 1, 2025, before the June 10, 2025 deadline. The proposed AC2HP reach code aligns with the following 2025 Safety Element goals and policies:
Safety Element, Policy 5-2: Building Resilience, 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.
oThe AC2HP ordinance aligns with this Policy because the ordinance proposes an amendment to the 2026 Building Code that applies to existing and new residential buildings and increases climate resiliency because heat pumps can completely or partially replace natural gas powered HVAC that relies on fossil fuel. Heat pumps rely on electric power which power is increasingly generated by non- carbon power sources and therefore reduces GHGs.
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 a two-way air conditioning unit capability to provide heating and cooling by the next CBC update cycle (which is the current 2026 cycle).
oThe proposed AC2HP reach code aligns with this Program because it is a two-way air conditioning system and is being proposed to amend the Building and Safety code in the next CBC update cycle.
Second, the proposed AC2HP reach code permits mixed-fuel residential construction that is consistent with federal law in the following ways:
The AC2HP reach code does not preclude a residential property owner 9b5
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from using natural gas. The ordinance does not require installation of the heat pump; compliance may also be achieved by installation of energy efficiency upgrades when installing, replacing or altering an air conditioning system but relying on a gas furnace for space heating. See Reach Code Sections A4.204.1.1a and A4.2041.1b.
Third, the proposed AC2HP reach code incentivizes all-electric construction consistent with Glendale’s adopted 2012 Greener Glendale Plan and the Climate Action and Adaptation Plan (CAAP) adopted on August 12, 2025. 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 location, retrofitting existing development for increased energy and water efficiency, and promoting and supporting use of renewable energy. The following GGP strategies incentivize all-electric construction:
Objective Urban Design 3 – Consider expansion of the City’s Green Building Standards CAL Green provides for cities to adopt a wide range of green building standards in addition to the state requirement. In 2011, These requirements included Urban Design energy efficiency measures as:
oStrategy UD 3-A: Expand Green Building Standards to exceed the minimum requirements as set forth in the California Green Building Code (CALGreen) Projects must exceed California Energy Code requirements by 15%.
Objective Energy 4 – Encourage the reduction of energy consumption through City municipal codes and policies:
oStrategy EC 4: Facilitate permitting and construction of alternative building structures, materials, and site locations.
Further, Glendale’s CAAP includes specific measures and actions to reduce greenhouse gas emissions by incentivizing all-electric construction for new and existing buildings described below:
Measure BLD-2: Require healthy, safe, decarbonized and resilient new buildings by 2026:
oAction BLD 2.1: Based on available legal pathways, implement a new building electrification ordinance which limits the installation of new natural gas infrastructure to improve health, safety, and reduce costs associated with new construction.
oAction BLD 2.4: Amend the building code to require all newly installed HVAC units for new buildings to have two-way air conditioning capabilities to provide heating and cooling. 9b6
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Measure BLD-3: Retrofit 25% of existing buildings by 2030 and 95% by 2045 to be zero-carbon and resilient to extreme heat and wildfires:
oAction BLD 3.1: By 2026, complete an existing building electrification study to identify costs and benefits associated with retrofitting residential and commercial building systems, including long-term costs of transitioning fuel use. Based on the findings of the report, identify, and adopt additional cost effective, equitable, and implementable building electrification requirements for existing buildings.
oAction BLD 3.4: Adopt an electrification-on-replacement ordinance for residential hot water heaters and HVAC systems by 2027.
The AC2HP reach code is consistent with the GGP and CAAP objectives, strategies, measures and actions because implementation of the AC2HP reach code will reduce greenhouse gas emissions by replacing fossil fuel-based heating systems with electric heat pumps. The following studies: The California Energy Codes and Standards:
2025 Cost Effectiveness Study Single Family AC to Heat Pump Replacement and the 2025 Custom Cost Effectiveness Analysis City of Glendale Single Family AC to Heat Pump Replacement Study (Exhibit 2)) 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.
These facts and the analysis above support the finding that the proposed AC2HP reach code meets the “General Plan Exception”. Further, the proposed AC2HP reach code changes are, pursuant to Health & Safety Code sections 17958.5 and 17958.7, reasonably necessary because of local climactic conditions, specifically, Glendale sits in the Los Angeles Air Basin which is in “nonattainment” status for ozone (a greenhouse gas created by chemical reactions between nitrogen oxides and volatile organic compounds from automobiles, power plants and other sources in the presence of sunlight), and is in “serious non-attainment” for carbon monoxide, which greenhouse gas air pollutant is caused principally from burning fossil fuels for electricity or heat. (See, https://www.epa.gov/ghgemissions/global-greenhouse-gas- overview#:~:text=Carbon%20dioxide%20(CO2):,soil%20health%2C%20and%20other% 20activities. Adoption of the AC2HP reach code will reduce greenhouse gas pollutants and address these climactic conditions since the technology is all-electric. These findings are included in the proposed ordinance for the Council’s consideration.
Proposed Ordinance
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The proposed ordinance would amend the 2026 California Energy Code, Title 24, Part 6, as adopted on November 4, 2025, amended and codified under 2026 Glendale Building and Safety Code Volume IX and effective on January 1, 2026. The proposed ordinance would make mandatory, an amended version of the voluntary requirements of the 2026 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.
CALGreen includes both mandatory and voluntary measures. Jurisdictions may adopt the voluntary measures as mandatory requirements. If the requirements affect the California Energy Code, as the proposed ordinance does, they must be found to be cost effective and must require that buildings be designed to use less energy than the standard California Energy Code. The attached study commissioned by the California Codes and Standards Program (Exhibit 2) has found that the proposed requirements are both cost effective and will result in a reduction in Long-Term System Cost (LSC) energy relative to the existing building.
Staff has proposed a modified version of the CALGreen Code that would encourage the installation of a heat pump space conditioning system at the time an air conditioner is replaced or added to an existing home. The proposed ordinance is based on the CALGreen code but has been modified to facilitate implementation. As proposed, a project may comply with the ordinance by either installing a heat pump space conditioner and no other measures other than those that are required under the California Energy Code, or maintain a gas furnace as the primary heating source and install additional energy efficiency measures above what is required under the California Energy Code.
There are several different ways a project could comply. The simplest way would be to install a heat pump (an air conditioner that is also configured to function as a space heater). This could be done either by replacing the furnace with a heat pump system (with or without a furnace) to serve as the air handler for the heat pump, and as a back-up heating system. California Energy Code requirements would apply; these vary depending upon whether the duct system is replaced at the same time.
Alternatively, a project could comply by installing an air conditioner but rely on a gas furnace for space heating. Again, certain California Energy Code requirements would apply when replacing an air conditioner. In addition, this alternative would require other energy efficiency measures.
Table 1 presents compliance requirements for heat pump systems under two scenarios, one using the existing ducts, the other with new ducts. Table 2 presents compliance requirements for systems that still use furnaces as the primary heating source, under the same duct scenarios.
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Table 1. Summary of Requirements if Using a Heat Pump
(for both heating and cooling)
Ducts State Code Requirements Additional Local Code
Requirements
Existing
Duct sealing (10% leakage)
Airflow efficiency (300 CFM/ton)
Refrigerant charge verification
None
New
Duct sealing (5% leakage)
Airflow efficiency (350 CFM/ton)
Fan efficacy (0.58 W/CFM)
Refrigerant charge verification
Attic insulation (R-49)
Air sealing
R-8 Duct insulation
None
Note: When installing a heat pump, a homeowner may also opt to keep the existing furnace or install a new furnace to provide supplemental heating only (below 35°F) Table 2. Summary of Requirements if Using a Furnace
(for heating and an air-cooled air conditioner for cooling) Ducts State Code Requirements Additional Local Code
Requirements
Existing
Duct sealing (10% leakage)
Airflow efficiency (300 CFM/ton)
Refrigerant charge verification
Fan efficacy (0.45 watts/CFM)
Attic insulation (R-49)
Air sealing
New
Duct sealing (5% leakage)
Airflow efficiency (350 CFM/ton)
Fan efficacy (0.45 W/CFM)
Refrigerant charge verification
Attic Insulation (R-49)
Air sealing
R-8 Duct insulation
Fan efficacy (0.35 watts/CFM)
Impacts
There are some incremental costs associated with converting to a heat pump, but these costs are offset by utility bill savings over the lifetime of the equipment and the initial investment differential will be incentivized through the GWP rebate program. From a broader societal perspective, the incremental costs are more than offset by the savings that accrue to all utility billpayers (e.g., reductions in utility infrastructure costs). The incremental cost, that is the amount over what would otherwise be needed to just replace the air conditioner and comply with the 2026 California Energy Code, depends on whether the furnace is replaced at the same time as the air conditioner. The lifetime of a furnace and air conditioner are about the same, 10-15 years, so it often makes economic sense 9b9
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to replace both if the furnace is near the end of its life. In this scenario, the cost of the furnace replacement is assumed as part of the base project cost. Alternatively, a heat pump could be configured to operate as the primary heating source using the air handler in the existing furnace and using the furnace for supplemental heating on very cold days.
Table 3 below compares the incremental cost and lifecycle savings (net present value of utility bill savings less incremental cost) for each approach.
Table 3. Economic Costs and Savings
Approach Incremental Cost Lifecycle
Savings
Heat pump & new air handler (no furnace) $721 $1,909
Heat pump with existing furnace as backup $1,916 $2,949 Glendale Water and Power heat pump rebates are currently in effect and offer $500 per ton. The proposed and technically approved PBC plan would increase this to $1,000 per ton, better supporting the AC2HP reach code by covering incremental costs and offering up to $1,000 for panel upgrades.
In terms of greenhouse gas emissions, heat pumps can provide significant reductions because heat pumps are far more efficient than gas furnaces (and electric resistance heat) and because an ever-increasing amount of electricity in California is derived from low-carbon energy sources.
Exceptions
The proposed Ordinance offers several exceptions. The first is for situations where the electrical panel capacity is insufficient to meet the load of a heat pump. The second is where the heat pump would need to be sized more than 12,000 Btu/hr (1 ton) over the air conditioner that would be installed in order to meet the heating load. This exception would pertain to colder California climate zones and would not be normally utilized in Glendale.
There are also exceptions in the proposed ordinance to the duct sealing and airflow requirements that specify alternative methods of compliance, outlined in Table 4.
Table 4 Exceptions Summary - Table of exemptions for altered space-conditioning systems serving existing single-family dwelling units (Title 24, Part 11).
Reference
Section
Applies to systems with
existing duct distribution
system
Exception
No.
Exemption Description
A4.204.1.1bIA 1 If not possible to meet duct sealing
requirements, seal all accessible leaks
and verify visually and with a smoke
test by a certified HERS Rater per
RA3.1.4.3.5.
A4.204.1.1bIA
The duct system measured
air leakage shall be equal to
or less than 10 percent of the 2 Existing duct systems
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system air handler airflow
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constructed,
insulated, or
sealed with
asbestos.
A4.204.1.1bIB 1 Systems
unable to meet
airflow/fan
efficacy may
comply by
following
RA3.3.3.1.5,
installing
thermostat per
§110.12, and
meeting filter
grille/pressure
drop per
Tables 150.0-
B/C and
RA3.1.4.4–.5.
A4.204.1.1bIB 2 Multispeed or
variable speed
compressor
systems must
verify airflow
and fan
efficacy at
maximum
compressor
and fan speed.
A4.204.1.1bIB
Demonstrate, in every control mode, airflow greater than or equal to 300 CFM per ton of nominal cooling capacity
through the return grilles, and an air-handling unit fan efficacy less than or equal to 0.45 W/CFM
3 Gas furnace
air-handling
units
manufactured
before July 3,
2019 may
comply with
≤0.58 W/CFM
fan efficacy
verified per
RA3.3.
A4.204.1.1(b)ID 1 Dwelling units
with ≥R-38
existing ceiling
insulation.
A4.204.1.1(b)ID 2 Alterations
disturbing
asbestos are
exempt unless
asbestos
abatement is
performed.
A4.204.1.1(b)ID
Vented attics shall have insulation installed to achieve a U- factor of 0.020 or insulation installed at the ceiling level shall result in an insulated thermal resistance of R-49 or greater for the insulation alone
3 Dwelling units
with knob and
tube wiring in
vented attic.
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A4.204.1.1(b)ID 4 If attic space
cannot
accommodate
full R-value, fill
accessible
space with
insulation
without
violating
§806.3 (Title
24, Part 2.5).
A4.204.1.1bIE 1 Dwelling units
with ≥R-38
existing ceiling
insulation.
A4.204.1.1bIE 2 Alterations
disturbing
asbestos are
exempt unless
asbestos
abatement is
performed.
A4.204.1.1bIE
Air seal all accessible areas of the ceiling plane between the attic and the conditioned space including all joints,
penetrations and other openings that are potential sources of air leakage by caulking, gasketing, weather-stripping or otherwise sealing to limit infiltration and exfiltration 3 Dwelling units
with
atmospherically
vented space
or water
heating
combustion
appliances
inside pressure
boundary.
Reference
Section
Applies to entirely new or
complete replacement duct
systems
Exception
No.
Exemption Description
A4.204.1.1bIIE 1 Alterations disturbing asbestos
are exempt unless asbestos
abatement is performed.
A4.204.1.1bIIE 2 Dwelling units with knob and
tube wiring in vented attic.
A4.204.1.1bIIE
Vented attics shall have insulation
installed to achieve a U-factor of
0.020 or insulation installed at the
ceiling level shall result in an
insulated thermal resistance of R-49
or greater for the insulation alone
3 If attic space cannot
accommodate full R-value, fill
accessible space with insulation
without violating §806.3 (Title
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24, Part 2.5).
A4.204.1.1bIIF 1 Dwelling units with ≥R-19
existing ceiling insulation.
A4.204.1.1bIIF 2 Alterations disturbing asbestos
are exempt unless asbestos
abatement is performed.
A4.204.1.1bIIF
Air seal all accessible areas of the
ceiling plane between the attic and
the conditioned space including all
joints, penetrations and other
openings that are potential sources
of air leakage by caulking, gasketing,
weather-stripping or otherwise
sealing to limit infiltration and
exfiltration.
3 Dwelling units with
atmospherically vented space
or water heating combustion
appliances inside pressure
boundary.
Schedule and Next Steps
Should Council approve staff’s recommendations, work would proceed on the timeline provided in Table 5 below.
Table 5. Schedule and Next Steps
Task Timeframe
Ordinance Introduction (Attachment 1) 11/04/2025
Ordinance Adoption(Attachment 1) and submittal to the California Energy Commission and California Building Standards Commission 11/18/2025 Ordinance goes into effect 1/1/2026
Receive approval from the California Energy Commission and California Building Standards Commission approves for filing TBD
STAKEHOLDERS/OUTREACH
On August 7, 2025, Staff presented the draft reach code to the Sustainability Commission and received direction from the Commission to recommend the City Council adopt the AC2HP reach code. Staff provided a copy of the reach code model language to the City’s Building Official and the GWP Clean Energy Officer in June 2025. Staff presented the proposed ordinance to the City Council at the August 12, 2025, meeting.
FISCAL IMPACT
There is no fiscal impact associated with this report.
ENVIRONMENTAL REVIEW (CEQA/NEPA)
The City Council finds and determines that this Ordinance is exempt from review under the California Environmental Quality Act (California Public Resources Code §§15000, et seq., "CEQA"), and the regulations promulgated thereunder (14 California Code of Regulations §§15000, et seq., the "CEQA Guidelines") because it consists of revisions and clarifications to an existing code of construction-related regulations and specification 9b12
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of procedures related thereto being taken for enhanced protection of the environment and while there may be added infrastructure resulting from the implementation of the Reach Codes, it does not have the potential to cause significant effects on the environment; to the contrary, the transition from fossil fuel sources is part of the State of California’s overall plan to decrease GHG emissions from stationary and transportation sources. Adoption of the Ordinance is categorically exempt in accordance with CEQA Guidelines §15305 as a minor alteration in land use limitations which do not result in any changes in land use or density and is exempt under CEQA Guidelines §15308 as an action taken by a regulatory agency as authorized by California law to assure maintenance or protection of the environment.
CAMPAIGN DISCLOSURE
This item is exempt from campaign disclosure requirements.
ALTERNATIVES TO STAFF RECOMMENDATION
1. Not introduce the Ordinance Amending the 2026 Glendale Building and Safety Code, Volume IX, to Adopt Local Amendments to the 2026 Edition of the California Building and Energy Code after October 1, 2025, using the AB 130 General Plan Exemption.
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. 2025 Single Family AC to Heat Pump Cost-Effectiveness Study.