Los Altos City Council
October 14, 2025

Section 503.1.1 is amended to read as follows:
503.1.1 Buildings and facilities. Approved fire apparatus access roads shall be provided for every facility, building or portion of a building hereafter constructed or moved into or within the jurisdiction. The fire apparatus access road shall comply with the requirements for this section and shall extend to within 150 feet (45 720 mm) of all portions of the facility and all portions of the exterior walls of the first story of the building as measured by an approved route around the exterior of the building or facility.

Exceptions:

1. In other than R-3 or U occupancies, when the building is equipped throughout with an approved automatic sprinkler system, installed in accordance with Section 903.3.1.1 the dimension may be increased to a maximum of 300 feet when approved by the fire code official.

2. When there are not more than two Group R-3 or accessory Group U occupancies, the dimension may be increased to a maximum of 200 feet.

3. When apparatus roads cannot be installed because of topography, waterways, nonnegotiable grades or other similar conditions, an approved alternative means of fire protection shall be provided.

Section 503.2.1 is amended to read as follows:

Section 503.2.1 Dimensions. Fire apparatus accessroadsshall have an unobstructed width of not less than 20 feet (6096 mm) for engines, and 26 feet (7925 mm) for aerial fire apparatus exclusive of shoulders, except for approved gates or barricades in accordance with Sections 503.5.1 and 503.6. The unobstructed vertical clearance shall be a minimum of 13 feet 6 inches (4115 mm), or as determined by the fire code official.

Exception: When there are not more than two Group R, Division 3, or Group U parcels, the access road width may be modified by the fire code official.

Section 503.2.4 is amended to read as follows:
503.2.4 Turning radius. The required turning radius of a fire apparatus access road shall be determined by the fire code official a minimum of 30 feet (9144 mm) inside, and a minimum of 50 feet (15240 mm) outside.

Section 503.2.7 is amended to read as follows:

503.2.7 Grade. The maximum grade of a fire department apparatus access road shall not exceed 15-percent, unless approved by the fire code official.

Section 503.5 is amended to read as follows:
503.5 Required gates or barricades. The fire code official is authorized to require the installation and maintenance of gates or other approved barricades across fire apparatus access roads, trails, or other accessways, not including the public streets, alleys, or highways.

The minimum width for commercial applicationsis 20 feet (6096 mm), and 12 feet(4268mm) for single-family dwellings. Electric gate operators, where provided shall be listed in accordance with UL 325. Gates intended for automatic operation shall be designed, constructed, and installed to comply with the requirements of ASTM F2200.

Section 503.6 is amended to read as follows:
503.6 Security gates. The installation of security gates across a fire apparatus access road shall be approved by the fire code official. Where security gates are installed, they shall have an approved means of emergency operation. The security gates and the emergency operation shall be maintained operational at all times. Electric gate operators, where provided, shall be listed in accordance with UL 325. Gates intended for automatic operation shall be designed, constructed and installed to comply with the requirements of ASTM F2200. The minimum width for commercial applications is 20 feet (6096 mm), and 12 feet (4268 mm) for single-family dwellings.

Section 504 ACCESS TO BUILDINGS AND ROOFS
Section 504.5 is added to read as follows:

Section 504.5 Access control devices. When access control devices including bars, grates, gates, electric or magnetic locks or similar devices, which would inhibit rapid fire department emergency access to the building, are installed, such devices shall be approved by the fire code official. All electrically powered access control devices shall be provided with an approved means for deactivation or unlocking from a single location or otherwise approved by the fire code official.

Access control devices shall also comply with Chapter 10 Means of Egress.

Section 505 PREMISES IDENTIFICATION
Section 505.1 is amended to read as follows:
505.1 Address identification. New and existing buildings shall be provided with

approved address identification. The address identification shall be legible and placed in a position that is visible from the street or road fronting the property. Address identification characters shall contrast with their background. Address numbers shall be Arabic numbers or alphabetical letters. Numbers shall not be spelled out. Each character shall be not less than 6 inches (153 mm) high with a minimum stroke width of 1/2 inch (12.7 mm). Where required by the fire code official, address identification shall be provided in additional approved locations to facilitate emergency response. Where access is by means of a private road and the building cannot be viewed from the public way, a monument, pole or other sign or means shall be used to identify the structure. Address identification shall be maintained.

The following is a guideline for adequate address number dimensions:
a. The number posted up to 49 feet from the public street shall be of one solid color which is contrasting to the background and be at least six (6) inches high with a half (½) inch stroke.
b. The number posted from 50 to 100 feet from the public street shall be of one solid color which is contrasting to the background and be at least six (6) inches high with a one (1) inch stroke.
c. The number posted over 100 to 199 feet from the public street shall be of one solid color which is contrasting to the background and be at least ten (10) inches high with a one and a half (1½) inch stroke.
d. The number posted over 200 to 299 feet from the public street shall be of one solid color which is contrasting to the background and be at least eighteen (18) inches high with a two (2) inch stroke.
e. The number posted over 300 to 400 feet from the public street shall be of one solid color which is contrasting to the background and be at least ten twenty-four (24) inches high with a two and a half (2½) inch stroke.

Section 510 EMERGENCY RESPONDER COMMUNICATION COVERAGE
Section 510.1 is amended to read as follows:
510.1 Emergency responder communications enhancement systems in new buildings.

Approved in-building emergency responder communications enhancement system (ERCES) for emergency responders shall be provided within all new buildings meeting any one of the following conditions:

1. There are more than 3 stories above grade plane (as defined by the California Building Code Section 202);

2. The total building area is 30,000 square feet or more;

3. The total basement area is 5,000 square feet or more;

4. Where required by the fire code official and radio coverage signal strength levels are not consistent with the minimum levels set forth in Section 510.4.1 Exceptions:

1. Where approved by the fire code official, a wired communication system in accordance with Section 907.2.13.2 shall be permitted to be installed or maintained in lieu of an approved communications coverage system.

2. Where it is determined by the fire code official that the communications coverage system is not needed.

3. In facilities where emergency responder communications coverage is required and such systems, components or equipment required could have a negative impact on the normal operations of that facility, the fire code official shall have the authority to accept an automatically activated emergency responder communications coverage system.

4. Buildings and areas of buildings that have minimum radio coverage signal strength levels of the Silicon Valley Regional Interoperability Authority (SVRIA) P25 Phase 2 700 MHz Digital Trunked Radio System within the building in accordance with Section 510.4.1 without the use of an indoor radio coverage system.

The radio coverage system shall be installed and maintained in accordance with Sections 510.4 through 510.6.4 of this code and with the applicable provisions of NFPA 1225, Standard for Emergency Services Communications.

In-building ERCES within the building shall be based on the existing coverage levels of the public safety communications systems utilized by the jurisdiction, measured at the exterior of the building. The ERCES, where required, shall be of a type determined by the fire code official and the frequency license holder(s). This section shall not require improvement of the existing public safety communications systems. Section 510.1.1 is amended to read as follows:

Section 510.1.1 is added to read as follows:
510.1.1 Obstruction by new buildings. No obstruction of the public safety system backhaul shall be allowed without an approved mitigating plan.

Section 510.3.1 is amended to read as follows:
510.3.1 Permit required. A construction permit for the installation of or modification to inbuilding emergency responder communications enhancement systems and related equipment is required as specified in Section 105.6.5. Maintenance performed in accordance with this code is not considered a modification and does not require a permit. A frequency change made to an existing system is considered to be new construction and will require a construction permit.

Section 510.4 is amended to read as follows:
510.4 Technical requirements. Equipment required to provide in-building, two-way emergency responder communication coverage shall be listed in accordance with UL 2524 and the current Emergency Responders Communications Enhancement Systems Standard

Details & Specification enforced by the Santa Clara County Fire Department. Systems, components and equipment required to provide the emergency responder radio coverage system shall comply with Sections 510.4.1 through 510.4.2.8.

Section 510.4.2 is amended to read:
510.4.2 System design. The in-building emergency responder communications enhancement system shall be designed in accordance with Sections 510.4.2.1 through 510.4.2.8 and NFPA 1225, and the current Emergency Responder Communications Enhancement Systems Details & Specification enforced by the Santa Clara County Fire Department.

Section 510.5 is amended to read as follows:
510.5 Installation requirement. The installation of the emergency responder radio coverage system shall be in accordance with NFPA 1225 and the current Emergency Responder Communications Enhancement Systems Standard Details & Specification enforced by the Santa Clara County Fire Department.

Section 510.5.2 is amended to read as follows:
510.5.2 Approval prior to installation. Communications enhancement systems capable of operating on frequencies licensed to any public safety agency by the FCC or other radio licensing authority shall not be installed without prior coordination and approval of the fire code official and the agency FCC license holder or systems administrator.

Section 510.5.4 is amended to read as follows:
510.5.4 Acceptance test procedure. Where an in-building emergency responder communications enhancement system is required, and upon completion of installation, the building owner shall have the radio system tested to verify that two-way coverage on each floor of the building is not less than 95 percent. Final system acceptance will require ERRCS power level and DAQ testing with agency FCC license holder, systems administrators, or designee.

Chapter 7 FIRE AND SMOKE PROTECTION FEATURES
Section 703 PENETRATIONS

Section 703.3 is added to read as follows:
703.3 Fire-resistant penetrations and joints. In high-rise buildings, in buildings assigned to Risk Category III or IV, or in fire areas containing Group R occupancies with an occupant load greater than 100, and other occupancies as determined necessary special inspections for through-penetrations, membrane penetration firestops, fire resistant joint systems and perimeter fire containment systems that are tested and listed in accordance with CBC Sections 714.4.1.2, 714.5.1.2, 715.3.1 and
715.4 shall be in accordance with Section 1705.18.1 or 1705.18.2.

Chapter 9 FIRE PROTECTION AND LIFE SAFETY SYSTEMS
Section 901 GENERAL
Section 901.6.2 is amended as follows:
901.6.2 Integrated testing. Where two or more fire protection or life safety systems are interconnected, the intended response of subordinate fire protection and life safety systems shall be verified when required testing of the initiating system is conducted. In addition, integrated testing shall be performed in accordance with Sections 901.6.2.1 and 901.6.2.2. 901.6.2.1 High-rise buildings. For high-rise buildings, integrated testing shall comply with NFPA 4, with an integrated test performed prior to issuance of the certificate of occupancy and at intervals not exceeding 10 years, unless otherwise specified by an integrated system test plan prepared in accordance with NFPA 4. If an equipment failure is detected during integrated testing, a repeat of the integrated test shall not be required, except as necessary to verify operation of fire protection or life safety functions that are initiated by equipment that wasrepaired orreplaced. For existing buildings, the testing timeframe shall be specified by the integrated systems test plan prepared in accordance with NFPA 4 as approved by the fire code official.
901.6.2.2 Smoke control systems. Where a fire alarm system is integrated with a smoke control system as outlined in Section 909, integrated testing shall comply with NFPA 4, with an integrated test performed prior to issuance of the certificate of occupancy and at intervals not exceeding 10 years, unless otherwise specified by an integrated system test plan prepared in accordance with NFPA 4. If an equipment failure is detected during integrated testing, a repeat of the integrated test shall not be required, except as necessary to verify operation of fire protection or life safety functions that are initiated by equipment that was repaired or replaced. For existing buildings, the testing timeframe shall be specified by the integrated systems test plan prepared in accordance with NFPA 4 as approved by the fire code official.

Section 901.6.3 is amended to read as follows:
901.6.3 Records Information. Records of all system inspections, tests and maintenance required by the referenced standard shall be maintained on the premises for a minimum of five years. See 907.7 & 907.8 for fire alarm system inspection, testing and maintenance documentation requirements.

Section 903.2 Where required.

Section 903.2.18 Group U private garages and carports accessory to Group R-3 occupancies.

Section 903.2 is amended to read as follows:

Section 903.2 Where required. Approved automatic sprinkler systems in new and existing buildings and structures shall be provided in the locations described in this Section or in Sections 903.2.1 through 903.2.12 whichever is the more restrictive and Sections 903.2.14 through 903.2.21.

For the purposes of this section, firewalls and fire barriers used to separate building areas shall be constructed in accordance with the California Building Code and shall be without openings or penetrations.

1. An automatic sprinkler system shall be provided throughout all new buildings and structures, other than Group R occupancies, except as follows:
a. Buildings and structures not located in any Wildland-Urban Interface and not exceeding 1,200 square feet of fire area.
b. Buildings and structures located in any Wildland-Urban Interface Fire Area and not exceeding 500 square feet of fire area.
c. Group S-2 or U occupancies, including photovoltaic support structures, used exclusively for vehicle parking which meet all of the following:
i. Noncombustible construction.
ii. Maximum 5,000 square feet in building area.
iii. Structure is open on not less than three (3) sides nor 75% of structure perimeter.
iv. Minimum of 10 feet separation from existing buildings, or similar structures, unless area is separated by fire walls d. Canopies, constructed in accordance with CBC 406.7.2, used exclusively for weather protection of vehicle fueling pads per CBC
406.7.1 and not exceeding 5,000 square feet of fire area.

complying with California Building Code 706.

2. An automatic sprinkler system shall be installed throughout all new buildings with a Group R fire area.

Exception: Detached Accessory Dwelling Unit, provided that all of the following are met:
a. The unit meets the definition of an Accessory Dwelling Unit as defined in the Government Code Section 65852.2.
b. The existing primary residence does not have automatic fire sprinklers.
c. The accessory detached dwelling unit does not exceed 1,200 square feet in size.
d. The unit is on the same lot as the primary residence. e. The unit meets all apparatus access and water supply requirements of Chapter 5 and Appendix B ofthe 2022 California Fire Code.

3. An approved automatic fire sprinkler system shall be installed in new manufactured homes(asdefined inCaliforniaHealth andSafetyCodeSections 18007 and 18009) and multifamily manufactured homes with two dwelling units (as defined in California Health and Safety Code Section 18008.7) in accordance with Title 25 of the California Code of Regulations.

4. An approved automatic sprinkler system shall be provided throughout all existing buildings, when additions are made that exceed fifty (50) percent and/or seven hundred and fifty (750) square feet of existing floor areas (area calculations shall not include existing basement floor areas).

5. An approved automatic sprinkler system shall be provided throughout all new basements regardless of size and throughout existing basements that are expanded by more than 50%.

6. An approved automatic sprinkler system shall be provided throughout existing buildings and structures when alterations or additions are made that create conditions described in Sections 903.2.1 through 903.2.18.

7. Any change in the character of occupancy or in use of any building with a fire area equalto or greaterthan 3,600 square feet which, in the opinion ofthe fire code official or building official, would place the building into a more hazardous division of the same occupancy group or into a different group of occupancies and constitutes a greater degree of life safety1 or increased fire risk2, shall require the installation of an approved fire automatic fire sprinkler system.
1 Life Safety – Shall include, but not limited to: Increased occupant load, public assembly areas, public meeting areas, churches, indoor amusement attractions, buildings with complex exiting systems due to increased occupant loads, large schools/day-care facilities, large residential care facilities housing non-ambulatory clients.

2 Fire Risks – Shall include, but not limited to: High-piled combustible storage, woodworking operations, hazardous operations using hazardous materials, increased fuel loads (storage of moderate to highly combustible materials), increased sources of ignition (welding, automotive repair with the use of flammable liquids and open flames).

8. The obligation to provide compliance with these fire sprinkler regulations may not be evaded by performing a series of small additions and/or alterations undertaken over a three-year period and/or two code cycles. The permit issuance dates of past additions and/or alterations where these regulations were in effect shall be used for determining compliance.
a. Any submittal for building permits which exceed fifty (50) percent and/or seven hundred and fifty (750) square feet of existing floor areas (area calculations shall not include existing basement floor areas and any nonhabitable floor areas i.e., garages) during the three-year period shall comply with fire sprinkler regulations.
b. No waiver shall be granted from compliance with fire sprinklers.

Section 903.2.11.7 is added as follows:
903.2.11.7 Chemical Fume Hood Fire Protection. Approved automatic fire extinguishing systems shall be provided in chemical fume hoods in the following cases:

1. Existing hoods having interiors with a flame spread index greater than 25 in which flammable liquids are handled.

2. If a hazard assessment determines that an automatic extinguishing system is required for the chemical fume hood, then the applicable automatic fire protection system standard shall be followed.

SECTION 907 FIRE ALARM AND DETECTION SYSTEMS
Section 907.8 is amended as follows:
907.8 Inspection, testing and maintenance. The maintenance and testing schedules and procedures for fire alarm and fire detection systems shall be in accordance with Sections 907.8.1 through 907.8.4 and NFPA 72. Records of inspection, testing and maintenance shall be maintained documented using NFPA 72 record of inspection and testing forms.

Section 909 SMOKE CONTROL SYSTEMS
Section 909.22.1 Schedule
Section 909.22.1 is amended to read as follows:

909.20.1 Schedule. A routine maintenance and operational testing program shall be initiated immediately after the smoke control system has passed the acceptance tests. A written schedule for routine maintenance and operational testing shall be established and operational testing shall occur at least annually.

Chapter 12 ENERGY SYSTEMS SECTION
1202 DEFINITIONS
Section 1202.1 is amended as follows:
1202.1 Definitions. The following terms are defined in Chapter 2:

BATTERY SYSTEM, STATIONARY STORAGE. BATTERY
TYPES.

CAPACITOR ENERGY STORAGE SYSTEM. CRITICAL
CIRCUIT.

EMERGENCY POWER SYSTEM.

ENERGY STORAGE MANAGEMENT SYSTEMS. ENERGY
STORAGE SYSTEM (ESS).

ENERGY STORAGE SYSTEM, ELECTROCHEMICAL.

ENERGY STORAGE SYSTEM, MOBILE.

ENERGY STORAGE SYSTEM, WALK-IN UNIT. ENERGY
STORAGE SYSTEM CABINET.

ENERGY STORAGE SYSTEM COMMISSIONING. ENERGY
STORAGE SYSTEM DECOMMISSIONING. FUEL CELL
POWER SYSTEM, STATIONARY.

LARGE-SCALE FIRE TESTING
PORTABLE GENERATOR.

STANDBY POWER SYSTEM.

SECTION 1207 ELECTRICAL ENERGY STORAGE SYSTEMS (ESS)
Section 1207.1.7 is amended as follows:
1207.1.7 Large-scale fire test. Where required elsewhere in Section 1207, large-scale fire testing shall be conducted in accordance with NFPA 855 as amended, and UL 9540A. The testing shall be conducted or witnessed and reported by an approved testing laboratory and show that a fire involving one ESS will not propagate to an adjacent ESS, and where installed within buildings, enclosed areas and walk-in units will be contained within the room, enclosed area or walk-in unit for a duration equal to the fire-resistance rating of the room separation specified in Section 1207.7.4. The test

report shall be provided to the fire code official for review and approval in accordance with Section 104.2.2.

Section 1207.2.2.1 is amended as follows:
1207.2.2.1 Ongoing inspection and testing. Systems that monitor and protect the ESS installation shall be inspected and tested in accordance with the manufacturer’s instructions and the operation and maintenance manual. Inspection and testing records shall be maintained in the operation and maintenance manual and made available to the fire code official upon request.

Section 1207.5.2 is amended as follows:
1207.5.2 Maximum allowable quantities. Fire areas within rooms, areas and walk-in units containing electrochemical ESS shall not exceed the maximum allowable quantities in Table 1207.5. The allowable number of fire areas, maximum allowable quantity, and fireresistance rating of fire-barriers shall comply with Table 1207.5.1.

Exceptions:

1. Where approved by the fire code official, rooms, areas and walk-in units containing electrochemical ESS that exceed the amountsin Table 1207.5 shall be permitted based on a hazardous mitigation analysis in accordance with Section 1207.1.6 and large-scale fire testing complying with Section 1207.1.7.

2. Lead-acid and nickel-cadmium battery systems installed in facilities under the exclusive control of communications utilities and operating at less than 50 VAC and 60 VDC in accordance with NFPA 76.

3. Dedicated-use buildings in compliance with Section 1207.7.1.

TABLE 1207.5.1

DESIGN AND NUMBER OF ESS FIRE AREAS

STORY PERCENTAGE

OF MAXIMUM ALLOWABLE

QUANTITY PER FIRE AREA
NUMBER

OF FIRE

AREAS PER
STORY

FIRE-RESISTANCE

RATING FOR FIR

BARRIERS I HOURS
Above grade Higher than 9 25 1 3
plan 7-9 50 2 2
6 50 2 2
5 50 2 2
4 75 4 2
3 100 6 2
2 100 6 2
1 100 6 2
Below grade 1 100 4 3

plan 2 50 2 3
Lower than 2 Not Allowed Not Allowed Not Allowed
Section 1207.5.5 is amended as follows:
1207.5.5 Fire suppression systems. Rooms and areas within buildings and walk-in units containing electrochemical ESS shall be protected by an automatic fire suppression system designed and installed in accordance with one of the following:

1. Automatic sprinkler systems designed and installed in accordance with Section 903.3.1.1 for ESS units (groups) with a maximum stored energy capacity of 50 kWh, as described in Section 1207.5.1, shall be designed with a minimum density of 0.3 gpm/ft2 (1.14 L/min) based over the area of the room or 2,500 square-foot (232 m2) design area, whichever is larger, unless a lower density is approved based on largescale fire testing in accordance with Section 1207.1.7.

2. Automatic sprinkler systems designed and installed in accordance with Section 903.3.1.1 for ESS units (groups) exceeding 50 kWh shall use a density based on largescale fire testing complying with Section 1207.1.7.

3. The following alternative automatic fire-extinguishing systems designed and installed in accordance with Section 904, provided that the installation is approved by the fire code official based on large-scale fire testing complying with Section 1207.1.7:

3.1. NFPA 12, Standard on Carbon Dioxide Extinguishing Systems.

3.2. NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection.

3.3. NFPA 750, Standard on Water Mist Fire Protection Systems.

3.4. NFPA 2001, Standard on Clean Agent Fire-Extinguishing Systems.

3.5. NFPA 2010, Standard for Fixed Aerosol Fire-Extinguishing Systems.

Exception:

1. Fire suppression systems for lead-acid and nickel-cadmium battery systems at facilities under the exclusive control of communications utilities that operate at less than 50 VAC and 60 VDC shall be provided where required by NFPA 76.

2. Lead-acid and nickel-cadmium systems that are used for DC power for control of substations and control or safe shutdown of generating stations under the exclusive control of the electric utility, and located outdoors or in building spaces used exclusively for such installations, shall not be required to have a fire suppression system installed.

3. Lead-acid battery systems in uninterruptable power supplies listed and labeled in accordance with UL 1778, utilized for standby power applications, which is limited to not more than 10 percent of the floor area on the floor on which the

ESS is located, shall not be required to have a fire suppression system. (Material based on NFPA 855 2023 Ed.)
Section 1207.11.3 is amended as follows:
1207.11.3 Location. ESS shall be installed only in the following locations:

1. Detached garages and detached accessory structures.

2. Attached garages separated from the dwelling unit living space and sleeping units in accordance with Section R302.6.

3. Outdoors or on the exterior side of the exterior walls not less than 3 feet (914 mm) from doors and windows directly entering the dwelling unit and not below or above any emergency escape and rescue openings.

4. Enclosed utility closets, basements, storage, or utility spaces within dwelling units with finished or noncombustible walls and ceilings. Walls and ceilings of unfinished wood-framed construction shall be provided with not less than 5/8- inch (15.9 mm) Type X gypsum wallboard.

ESS shall not be installed in sleeping rooms, closets, spaces opening directly into sleeping rooms or in habitable spaces of dwelling units.

Section 1207.11.6 is amended as follows:
1207.11.6 Fire detection. ESS installed inGroup R-3and R-4 occupanciesshall comply with the following:

1. Rooms and areas within dwellings units, sleeping units, basements and attached garages in which ESS are installed shall be protected by smoke alarms in accordance with Section 907.2.11.

2. A listed heat alarm interconnected to the smoke alarms shall be installed in locations within dwelling units, sleeping units, and attached garages where smoke alarms cannot be installed based on their listing.

Exceptions:

1. A listed heat detector may be used in place of a heat alarm, so long as it is interconnected with devicesthat provide an audible alarm at allsleeping areas.

2. A fire sprinkler associated with an approved automatic sprinkler system that triggers an audible alarm upon activation of the waterflow switch, may be used in place of a heat alarm.

Chapter 33 FIRE SAFETY DURING CONSTRUCTION AND DEMOLITION Section 3305 PRECAUTIONS AGAINST FIRE
Section 3303.5 is amended to read as follows:

3305.5 Fire watch. Where required by the fire code official or the site safety plan established in accordance with Section 3303.1, a fire watch shall be provided for building demolition and for building construction. Fire watch is not intended to facilitate occupancy during ongoing construction in a new building.

Section 3303.7 is added to read as follows:

Section 3303.7 Fire Walls.

When firewalls are required in combustible construction, the wall construction shall be completed (with all openings protected) immediately after the building is sufficiently weather protected at the location of the wall(s).

Section 3307 FIRE DEPARTMENT SITE ACCESS AND WATER SUPPLY Section 3307.1.2 is amended to read:
3307.1.2 Stairways Required. Each level above the first story in multi-story buildings that require two exit stairways shall be provided with at least two usable exit stairways after the floor decking is installed. The stairways shall be continuous and discharge to grade level.

Stairways serving more than two floor levels shall be enclosed (with openings adequately protected) after exterior walls/windows are in place. Exit stairs in new and in existing, occupied buildings shall be lighted and maintained clear of debris and construction materials at all times.

Exception: For multi-story buildings, one of the required exit stairs may be obstructed on not more than two contiguous floor levels for the purposes of stairway construction (i.e., installation of gypsum board, painting, flooring, etc.).

Section 3307.1.4 is added to read:
3307.1.4 Required Means of Egress. All buildings under construction shall have at least one unobstructed means of egress. All means of egress shall be identified in the written site safety plan as required by Section 3303.1.

Add Section 3307.6 to read:
3307.6 Fire Department Access Roadways: All construction sites shall be accessible by fire department apparatus bymeans ofroadways having an all-weather driving service of not less than 20ft. of unobstructed width. The roads shall have the ability to withstand the live loads of fire apparatus and have a minimum 13ft. 6 in. of vertical clearance. Dead end fire access roads in excess of 150 ft. in length shall be provided with approved turnarounds.

When approved by the Fire Code Official, temporary access roadways may be utilized until such time that the permanent roadways are installed. As a minimum, the roadway shall consist of a compacted subbase and six (6) inches of road base material (Class 2 aggregate base rock) both compacted to a minimum 95% and sealed. The perimeter edges of the

roadway shallbe contained anddelineatedby curband gutter or other approved method. The use of geotextile reinforcing fabric underlayment or soils lime-treatment may be required if so, determined by the project civil engineer. Provisions for surface drainage shall also be provided where necessary. The integrity of the roadway shall be maintained at all times.

SECTION 3313 COMPLETION BEFORE OCCUPANCY.

Section 3313.1 is added to read:

Section 3313.1 Completion Before Occupancy. In buildings where an automatic sprinkler system is required by this code or the California Building Code, it shall be unlawful to occupy any portion of a building or structure until the automatic sprinkler system installation has been tested and approved.

In new buildings of combustible construction where, automatic fire sprinkler systems are required to be installed, the system shall be placed in service as soon as possible.

Immediately upon the completion of sprinkler pipe installation on each floor level, the piping shall be hydrostatically tested and inspected. After inspection approval from the Fire department, each floor level of sprinkler piping shall be connected to the system supply riser and placed into service with all sprinkler heads uncovered. Protective caps may be installed on the active sprinklers during the installation of drywall, texturing and painting, but shall be removed immediately after this work is completed. For system activation notification, an exterior audible waterflow alarm shall be installed and connected to the sprinkler waterflow device prior to installation of the monitoring system.

For buildings equipped with fire sprinkler systems that are undergoing alterations, the sprinkler system(s) shall remain in service at all times except when system modifications are necessary. Fire sprinkler systems undergoing modifications shall be returned to service at the end of each workday unless otherwise approved by the fire department. The General contractor or his/her designee shall check the sprinkler control valve(s) at the end of each workday to confirm that the system has been restored to service.

CHAPTER 41 TEMPORARY HEATING AND COOKING OPERATIONS
SECTION 4103 PORTABLE FUEL-FIRE HEATING APPLIANCES
Section 4103.1 is amended to read:
4103.1 Portable unvented heaters. Portable unvented fuel-fired heating equipment shall be prohibited in occupancies in Groups A, B, E, I, R-1, R-2, R2.1, R2.2, R-3, R3.1 and R-4 and ambulatory care facilities.

Exceptions:

1. Portable unvented fuel-fired heaters listed and labeled in accordance with UL 647 are permitted to be used in one and two-family dwellings, where operated and maintained in accordance with the manufacturer’s instructions.

2. Portable outdoor gas-fired heating appliances in accordance with Section 4103.1.2.

Section 4103.1.2.1.1 is amended to read:
4103.1.2.1.1 Prohibited locations. The storage or use of portable outdoor gas-fired heating appliances is prohibited in any of the following locations:

1. Inside of any occupancy where connected to the fuel gas container.

2. Inside of tents, canopies and membrane structures.

3. On exterior balconies, and rooftops.

SECTION 4106 IMMERSION HEATERS
Section 4106.1 is added to read:
4106.1 Immersion Heaters. All electrical immersion heaters used in dip tanks, sinks, vats and similar operations shall be provided with approved over-temperature controls and low liquid level electrical disconnects. Manual reset of required protection devices shall be provided.

Chapter 50. HAZARDOUS MATERIALS-GENERAL PROVISIONS
Chapter 50 of the 2025 California Fire Code and 2024 International Fire Code are amended as follows:

Section 5001 GENERAL
Section 5001.2.2.2 is amended as follows:
5001.2.2.2 Health Hazards The material categories listed in this section are classified as health hazards. A material with a primary classification as a health hazard can also pose a physical hazard.

1. Highly toxic and toxic materials.

2. Corrosive materials.

3. Moderately toxic gas.

4. Health hazards - Other.

Section 5002 DEFINITIONS
Amend Section 5002.1 to read:
5002.1 Definitions. The following terms are defined in Chapter 2:

BOILING POINT.

CEILING LIMIT.

CHEMICAL. CHEMICAL

NAME. CLOSED
CONTAINER.

CONTAINER. CONTROL
AREA.

CORROSIVE LIQUIDS
CYLINDER.

DAY BOX.

DEFLAGRATION. DESIGN
PRESSURE. DETACHED
BUILDING. DISPENSING.

EXCESS FLOW CONTROL.

EXHAUSTED ENCLOSURE.

EXPLOSION.

FLAMMABLE VAPORS OR FUMES. GAS
CABINET.

GAS ROOM.

HANDLING.

HAZARDOUS MATERIALS.

HEALTH HAZARD.

HEALTH HAZARD – OTHER. IMMEDIATELY
DANGEROUS TO LIFE AND HEALTH (IDLH).

INCOMPATIBLE MATERIALS.

LIQUID.

LOWER EXPLOSIVE LIMIT (LEL). LOWER
FLAMMABLE LIMIT (LFL).

MAXIMUM ALLOWABLE QUANTITY PER CONTROL AREA. MODERATELY TOXIC GAS.

NORMAL TEMPERATURE AND PRESSURE (NTP).

OUTDOOR CONTROL AREA.

PERMISSIBLE EXPOSURE LIMIT (PEL).

PESTICIDE.

PHYSICAL HAZARD.

PRESSURE VESSEL.

SAFETY CAN.

SAFETY DATA SHEET (SDS).

SECONDARY CONTAINMENT.

SEGREGATED.

SOLID.

SPILL CONTROL.

STORAGE, HAZARDOUS MATERIALS.

SYSTEM.

TANK, ATMOSPHERIC.

TANK, PORTABLE.

TANK, STATIONARY.

TANK VEHICLE.

UNAUTHORIZED DISCHARGE.

USE (MATERIAL).

VAPOR PRESSURE.

Section 5003 GENERAL REQUIREMENTS
Section 5003.1.3.1 is added as follows:
5003.1.3.1 Toxic, Highly Toxic, Moderately Toxic Gases and Similarly Used or Handled Materials. The storage, use and handling of toxic, highly toxic, and moderately toxic gasesin amounts exceeding Table 6004.2.1.4 shall be in accordance with this chapter and Chapter 60.

Any toxic, highly toxic, or moderately toxic material that is used or handled as a gas or vapor shall be in accordance with the requirements for toxic, highly toxic, or moderately toxic gases.

Section 5003.1.5 is added as follows:
5003.1.5 Health Hazards - Other. The storage, use and handling of materials classified as other health hazards including carcinogens, irritants and sensitizers in amounts exceeding 810 cubic feet for gases, 55 gallons for liquids and 5,000 pounds for solids shall be in accordance with Section 5003.

Section 5003.1.6 is added as follows:
5003.1.6 Additional Spill Control and Secondary Containment Requirements. In addition to the requirements set forth in Section 5004.2. An approved containment system is required for any quantity of hazardous materialsthat are liquids orsolids at normal temperature, and pressure (NTP) where a spill is determined to be a plausible event and where such an event would endanger people, property, or the environment. The approved containment system may be required to include a combination of spill control and secondary containment meeting the design and construction requirements set forth in Section 5004.2.

Section 5003.2.2.1 is amended as follows:
5003.2.2.1 Design and Construction. Piping, tubing, valves, fittings, and related components used for hazardous materials shall be in accordance with the following:

1. Piping, tubing, valves, fittings, and related components shall be designed and fabricated from materials that are compatible with the material to be contained and shall be of adequate strength and durability to withstand the pressure,structural and seismic stress, and exposure to which they are subject.

2. Piping and tubing shall be identified in accordance with ASME A13.1 and the Santa Clara County Fire Chiefs Marking Requirements and Guidelines for Hazardous Materials and Hazardous Waste to indicate the material conveyed.

3. Manual valves or automatic remotely activated fail-safe emergency shutoff valves shall be installed on supply piping and tubing and provided with ready access at the following locations:

1. The point of use.

2. The tank, cylinder, or bulk source.

4. Manual emergency shutoff valves and controls for remotely activated emergency shutoff valves shall be clearly visible, provided with ready access and identified in an approved manner.

5. Backflow prevention or check valves shall be provided where the backflow of hazardous materials could create a hazardous condition or cause the unauthorized discharge of hazardous materials.

6. Where gases or liquids having a hazard ranking of:

Health hazard Class 3 or 4
Flammability Class 4
Reactivity Class 4
in accordance with NFPA 704 are carried in pressurized piping above 15 pounds per square inch gauge (psig)(103 Kpa), an approved means of leak detection, emergency shutoff or excess flow control shall be provided. Where the piping originates from within a hazardous material storage room or area, the excess flow control shall be located within the storage room or area. Where the piping originates from a bulk source, the excess flow control shall be located as close to the bulk source as practical.

Exceptions:

1. Piping for inlet connections designed to prevent backflow.

2. Piping for pressure relief devices.

7. Secondary containment or equivalent protection from spills or leaks shall be provided for piping for liquid hazardous materials and for highly toxic and toxic corrosive gases above threshold quantities listed in Table 6004.2.1.4. Secondary containment includes but is not limited to double-walled piping.

Exceptions:

1. Secondary containment is not required for toxic corrosive gases if the piping is constructed of inert materials.

2. Piping under sub-atmospheric conditions if the piping is equipped with an alarm and fail-safe-to-close valve activated by a loss of vacuum.

8. Expansion chambers shall be provided between valves whenever the regulated gas may be subjected to thermal expansion. Chambers shall be sized to provide protection for piping and instrumentation and to accommodate the expansion of regulated materials.

Section 5003.2.2.2 is amended as follows:
5003.2.2.2 Additional Regulation for Supply Piping for Health Hazard Materials. Supply piping and tubing for gases and liquids having a health hazard ranking of 3 or 4 shall be in accordance with ASME B31.3 and the following:

1. Piping and tubing utilized for the transmission of highly toxic, toxic, or highly volatile corrosive liquids and gases shall have welded, or brazed connections throughout except for connections within an exhausted enclosure if the material is a gas, or an approved method of drainage or containment is provided for connections if the material is a liquid.

2. Piping and tubing shall not be located within corridors, within any portion of a means of egress required to be enclosed in fire- resistance-rated construction or in concealed spaces in areas not classified as Group H Occupancies.

3. All primary piping for toxic, highly toxic, and moderately toxic gases shall pass a helium leak test of 1x10-9 cubic centimeters/second where practical, or shall pass testing in accordance with an approved, nationally recognized standard. Tests shall be conducted by a qualified "third party" not involved with the construction of the piping and control systems.

Exception: Piping and tubing within the space defined by thewalls of corridors and the floor or roof above or in concealed spaces above other occupancies where installed in accordance with Section 415.11.7.4 of the California Building Code for Group H-5 occupancies.

Section 5003.5.2 is added as follows:
5003.5.2 Ventilation Ducting. Ducts venting hazardous materials operationsshall be labeled with the hazard class of the material being vented and the direction of flow.

Section 5003.5.3 is added as follows:
5003.5.3 “H" Occupancies. In "H" occupancies, all piping and tubing may be required to be identified when there is any possibility of confusion with hazardous materials transport tubing or piping. Flow direction indicators are required.

Section 5003.10.4 is amended as follows:
5003.10.4 Elevators utilized to transport hazardous materials. 5003.10.4.1 When transporting hazardous materials, elevators shall have no other passengers other than the individual(s) handling the chemical transport cart. 5003.10.4.1.1 When transporting cryogenic orliquefied compressed gases,there shall be no occupants in the elevator.
5003.10.4.2 Hazardous materials liquid containers shall have a maximum capacity of 20 liters (5.28 gal).
5003.10.4.3 Toxic, moderately toxic, and highly toxic gases shall be limited to a container of a maximum water capacity of 1 pound.
5003.10.4.4 When transporting cryogenic or liquefied compressed gases, meansshall be provided to prevent the elevator from being summoned to other floors.

Section 5004 STORAGE

Section 5004.2.1 is amended as follows:
5004.2.1 Spill Control for Hazardous Material Liquids. Rooms, buildings, or areas used for storage of hazardous material liquids shall be provided with spill control to prevent the flow of liquids to adjoining areas. Floors in indoor locations and similar surfaces in outdoor locations shall be constructed to contain a spill from the largest single vessel by one of the following methods:

1. Liquid-tight sloped or recessed floors in indoor locations or similar areas in outdoor locations.

2. Liquid-tight floors in indoor and outdoor locations or similar areas provided with liquid-tight raised or recessed sills or dikes.

3. Sumps and collection systems

4. Other approved engineered systems.

Except for surfacing, the floors, sills, dikes, sumps, and collection systems shall be constructedofnoncombustiblematerial, andthe liquid-tightsealshallbe compatible with the material stored. When liquid-tight sills or dikes are provided, they are not required at perimeter openings having an open-grate trench across the opening that connects to an approved collection system.

Section 5004.2.2.2 is amended as follows:
5004.2.2.2 Incompatible Materials. Incompatible materials shall be separated from each other in independent secondary containment systems.

Chapter 54 CORROSIVE MATERIALS
Chapter 54 of the 2025 California Fire Code is adopted with the following amendments:

Section 5402 DEFINITION
Section 5402.1 is amended as follows:
5402.1 Definition. The following term is defined in Chapter 2:

CORROSIVE.

CORROSIVE LIQUIDS.

Chapter 56 EXPLOSIVES AND FIRWORKS
Section 5601 GENERAL
Section 5601.1.3 is amended to read as follows:

Section 5601.1.3 Fireworks. The possession, manufacture, storage, sale, handling, and use of fireworks, including those fireworks classified as Safe and Sane by the California State Fire Marshal, are prohibited.

Exceptions:

1. Storage and handling of fireworks as allowed in Section 5604.

2. The use of fireworks for fireworks displays pyrotechnics before a proximate audience and pyrotechnic special effects in motion pictures, television, theatrical or group entertainment productions as allowed in Title 19, Division 1, Chapter 6 Fireworks reprinted in Section 5608 and Health and Safety Code Division 11.

Chapter 57 FLAMMABLE AND COMBUSTILE LIQUIDS
Section 5704 STORAGE
Section 5704.2.7.5.8 is amended to read as follows and the exception in the Section is deleted:

Section 5704.2.7.5.8 Overfill Prevention.

An approved means or method in accordance with Section 5704.2.9.7.5. shall be provided to prevent the overfill of all ClassI, II and IIIA liquid storage tanks. Storage tanks in refineries, bulk plants or terminals regulated by Sections 5706.4 or 5706.7 shall have overfill protection in accordance with API 2350.

Exception: Outside aboveground tanks with a capacity of 1320 gallons (5000 L) or less need only comply with Section 5704.2.9.7.5 (Item 1, Sub-item 1.1).

An approved means or method in accordance with Section 5704.2.9.7.5 shall be provided to prevent the overfilling of Class IIIB liquid storage tanks connected to fuel-burning equipment inside buildings.

Exception: Outside aboveground tanks with a capacity of 1320 gallons (5000 L) or less need only comply with Section 5704.2.9.7.5 (Item 1, Sub-item 1.1).

Section 5704.2.7.5.9 is added to read as follows:

Section 5704.2.7.5.9 Automatic and/or Remote Filling of Tanks. Systems that automatically fill flammable or combustible liquid tanks shall be equipped with overfill protection, approved by the fire code official,thatsends an alarmsignalto a constantly attended location and immediately stopsthe filling of the tank. The alarm signal and automatic shutoff shall be tested on an annual basis and records of such testing shall be maintained on-site for a period of five (5) years.

Section 5704.2.9.6.1 is amended to read as follows:
5704.2.9.6.1 Locations where above-ground tanks are prohibited. The storage of Class I and

II liquids in above-ground tanks outside of building is prohibited in all locations of the City of Los Altos which are residential or congested commercial areas as determined by the fire code official.

Section 5706.2.4.4 is amended to read as follows:
5706.2.4.4 Locations where above-ground tanks are prohibited. Storage of Class I and II liquids in above-ground tanks is prohibited in all locations of the City of Los Altos which are residential or congested commercial areas as determined by the fire code official.

Chapter 58 FLAMMABLE GASES AND FLAMMABLE CRYOGENIC FLUIDS.

Section 5806.2 is amended to read as follows:
5806.2 Limitations. The storage of flammable cryogenic fluids in stationary containers outside of buildings is prohibited in all location of the City of Los Altos which are residential or congested commercial areas as determined by the fire code official.

Chapter 60 HIGHLY TOXIC AND TOXIC MATERIALS
Chapter 60 of the 2025 California Fire Code and 2024 International Code is amended as follows:

Section 6001 GENERAL
Section 6001.1 is amended as follows:
6001.1 Scope. The storage and use of highly toxic, toxic, and/or moderately toxic materials shall comply with this chapter. Compressed gases shall also comply with Chapter 53.

Exceptions:

1. Display and storage in Group M and storage in Group S occupancies complying with Section 5003.11.

2. Conditions involving pesticides or agricultural products as follows:

2.1 Application and release of pesticide, agricultural products and materials intended for use in weed abatement, erosion control, soil amendment or similar applications when applied in accordance with the manufacturer’s instruction and label directions.

2.2 Transportation of pesticides in compliance with the Federal Hazardous Materials Transportation Act and regulations thereunder.

2.3 Storage in dwellings or private garages of pesticides registered by the US Environmental Protection Agency to be utilized in and around the home, garden, pool, spa, and patio.

SECTION 6002 – DEFINITIONS
Section 6002.1 is amended to read:
6002.1 Definitions.

The following terms are defined in Chapter 2:

CONTAINMENT SYSTEM.

CONTAINMENT VESSEL.

EXCESS FLOW VALVE.

HIGHLY TOXIC.

MODERATELY TOXIC GAS.

OZONE-GAS GENERATOR.

PHYSIOLOGICAL WARNING THRESHOLD.

REDUCED FLOW VALVE.

TOXIC.

SECTION 6004 HIGHLY TOXIC AND TOXIC COMPRESSED GASES
Section 6004 HIGHLY TOXIC, MODERATELY TOXIC, AND TOXIC COMPRESSED GASES Section 6004.1 is amended as follows:
6004.1 General. The storage and use of highly toxic, toxic, and moderately toxic compressed gases shall comply with this section.
6004.1.1Special limitationsforindoorstorageandusebyoccupancy. Theindoor storage and use of highly toxic, toxic, and moderately toxic compressed gases in certain occupanciesshall be subject to the limitations contained in Sections 6004.1.1.1 through 6004.1.1.3. 6004.1.1.1 Group A, E, I or U occupancies. Moderately toxic, toxic, and highly toxic compressed gases shall not be stored or used within Group A, E, I or U occupancies.

Exception: Cylinders not exceeding 20 cubic feet (0.566 m3) at normal temperature and pressure (NTP) are allowed within gas cabinets or fume hoods. 6004.1.1.2 Group R occupancies. Moderately toxic, toxic, and highly toxic compressed gases shall not be stored or used in Group R occupancies.
6004.1.1.3 Offices, retail sales and classrooms. Moderately toxic, toxic, and highly toxic compressed gases shall not be stored or used in offices, retail sales or classroom portions of

Group B, F, M or S occupancies.

Exception: In classrooms of Group B occupancies, cylinders with a capacity not exceeding 20 cubic feet (0.566 m3) at NTP are allowed in gas cabinets or fume hoods.

Section 6004.2 is amended as follows:
6004.2 Indoor storage and use. The indoor storage and use of highly toxic, toxic, and moderately toxic compressed gases shall be in accordance with Sections 6004.2.1 through 6004.2.2.10.3.

Section 6004.2.1 is amended as follows:
6004.2.1 Applicability. The applicability of regulations governing the indoor storage and use of highly toxic, and toxic, and moderately toxic compressed gases shall be as set forth in Sections 6004.2.1.1 through 6004.2.1.4.

Section 6004.2.1.4 is added as follows:
6004.2.1.4 Quantities exceeding the minimum threshold quantities but not exceeding the maximum allowable quantities per control area. The indoor storage or use of highly toxic, toxic, and moderately toxic gases in amounts exceeding the minimum threshold quantities per control area set forth in Table 6004.2.1.4 but not exceeding maximum allowable quantity per control area set forth in Table 5003.1.1(2) shall be in accordance with Sections 5001, 5003, 6001, 6004.1, and 6004.4
Add Table 6004.2.1.4 as follows:

Minimum Threshold Quantities for Highly Toxic, Toxic and Moderately Tox Gases for Indoor Storage and Use
Highly Toxic 20
Toxic 405 cubic feet
Moderately Toxic 405 cubic feet
Section 6004.4 is added as follows:
6004.4. General indoor requirements. The general requirements applicable to the indoor storage and use of highly toxic, toxic, and moderately toxic compressed gases shall be in accordance with Sections 6004.4 through 6004.4.8.2
6004.4.1 Cylinder and tank location. Cylinders shall be located within gas cabinets, exhausted enclosures, or gas rooms. Portable and stationary tanks shall be located within gas rooms or exhausted enclosures.

Exceptions:

1. Where a gas detection system is provided in accordance with 6004.4.8

6004.4.2. Ventilated areas. The room or area in which gas cabinets or exhausted enclosures are located shall be provided with exhaust ventilation. Gas cabinets or exhausted enclosures shall not be used asthe sole means of exhaust for any room or area. 6004.4.3. Piping and controls. In addition to the requirements of Section 5003.2.2, piping and controls on stationary tanks, portable tanks, and cylinders shall comply with the following requirements:

1. Stationary tanks, portable tanks, and cylinders in use shall be provided with a means of excess flow control on all tank and cylinder inlet or outlet connections.

Exceptions:

1. Inlet connections designed to prevent backflow.

2. Pressure relief devices.
6004.4.4 Gas rooms. Gas rooms shall comply with Section 5003.8.4 and both of the following requirements:

1. The exhaust ventilation from gas rooms shall be directed to an exhaust system.

2. Gas rooms shall be equipped with an approved automatic sprinkler system.

Alternative fire- extinguishing systems shall not be used. 6004.4.5 Treatment systems. The exhaust ventilation from gas cabinets, exhausted enclosures, and gas rooms, required in Section 6004.4.1 shall be directed to a treatment system. The treatment system shall be utilized to handle the accidental release of gas and to process exhaust ventilation. The treatment system shall be designed in accordance with Sections 6004.2.2.7.1 through 6004.2.2.7.5 and Chapter 5 of the California Mechanical Code.

Exceptions:

1. Highly toxic, toxic, and moderately toxic gases—storage. A treatment system is notrequired for cylinders, containers, and tanksin storage where all the following controls are provided:

1.1 Valve outlets are equipped with gas- tight outlet plugs or caps.

1.2 Hand wheel-operated valves have handles secured to prevent movement.

1.3 Approved containment vessels or containment systems are provided in accordance with Section 6004.2.2.3.

2. Highly toxic, toxic, and moderately toxic gases —use. Treatment systems are not required for highly toxic, toxic, and moderately toxic gasessupplied by stationary tanks, portable tanks, or cylinders where a gas detection system complying with Section 6004.4.8 and listed or approved

automatic-closing fail- safe valves are provided. The gas detection system shall have a sensing interval not exceeding 5 minutes. Automatic-closing fail- safe valves shall be located immediately adjacent to cylinder valves and shall close when gas is detected at the permissible exposure limit (PEL) by a gas sensor monitoring the exhaust system at the point of discharge from the gas cabinet, exhausted enclosure, ventilated enclosure, or gas room. 6004.4.5.1. Design. Treatment systems shall be capable of diluting, adsorbing, absorbing, containing, neutralizing, burning or otherwise processing the contents of the largest single vessel of compressed gas. Where a total containment system is used, the system shall be designed to handle the maximum anticipated pressure of release to the system when it reaches equilibrium.
6004.4.5.2. Performance. Treatment systems shall be designed to reduce the maximum allowable dis- charge concentrations of the gas to one-half immediate by dangerous to life and health (IDLH) at the point of discharge to the atmosphere. Where more than one gas is emitted to the treatment system, the treatment system shall be designed to handle the worst-case release based on the release rate, the quantity and the IDLH for all compressed gases stored or used.
6004.4.5.3. Sizing. Treatment systems shall be sized to process the maximum worst-case release of gas based on the maximumflow rate ofrelease fromthe largest vessel utilized. The entire contents of the largest compressed gas vessel shall be considered. 6004.4.5.4 Stationary tanks. Stationary tanks shall be labeled with the maximum rate of release for the compressed gas contained based on valves or fittings that are inserted directly into the tank. Where multiple valves or fittings are provided, the maximum flow rate of release for valves or fittings with the highest flow rate shall be indicated. Where liquefied compressed gases are in contact with valves or fittings, the liquid flow rate shall be utilized for computation purposes. Flow rates indicated on the label shall be converted to cubic feet per minute (cfm/min) (m3/s) of gas at normal temperature and pressure (NTP). 6004.4.5.5 Portable tanks and cylinders. The maximum flow rate of release for portable tanks and cylinders shall be calculated based on the total release from the cylinder or tank within the time specified in Table 6004.2.2.7.5. Where portable tanks or cylinders are equipped with approved excess flow or reduced flow valves, the worst-case release shall be determined by the maximum achievable flow from the valve as determined by the valve manufacturer or compressed gas supplier. Reduced flow and excess flow valves shall be permanently marked by the valve manufacturer

to indicate the maximum design flow rate. Such markings shall indicate the flow rate for air under normal temperature and pressure.
6004.4.6. Emergency power. Emergency power shall be provided for the following systems in accordance with Section 604:

1. Exhaust ventilation system.

2. Treatment system.

3. Gas detection system.

4. Smoke detection system.
6004.4.6.1. Fail-safe systems. Emergency power shall not be required for mechanical exhaust ventilation and treatment systems where approved fail-safe systems are installed and designed to stop gas flow.
6004.4.7. Automatic fire detection system. An approved automatic fire detection system shall be installed in rooms or areas where highly toxic, toxic, and moderately toxic compressed gases are stored or used. Activation of the detection system shall sound a local alarm. The fire detection system shall comply with Section 907. 6004.4.8. Gas detection system. A gas detection system complying with Section 916 shall be provided to detect the presence of gas at or below the PEL or ceiling limit of the gas for which detection is provided.

Exceptions:

1. A gas detection system is not required for toxic and moderately toxic gases when the physiological warning threshold level for the gas is at a level below the accepted PEL for the gas.

2. A gas detection system is not required for highly toxic, toxic, and moderately toxic gases where cylinders, portable tanks, and all non-continuously welded connects are within a gas cabinet or exhausted enclosures.
6004.4.8.1. Alarms. The gas detection system shall initiate a local alarm and transmit a signal to an approved location.
6004.4.8.2. Shut off of gas supply. The gas detection system shall automatically close the shut off valve at the source on gas supply piping and tubing related to the system being monitored for whichever gas is detected.

Exception: Automatic shutdown is not required for highly toxic, toxic, and moderately toxic compressed gas systems where all the following controls are provided:

1. Constantly attended/supervised.

2. Provided with emergency shutoff valves that have ready access.

Appendix 10
Chapter 61 LIQUEFIED PETROLEUM GASES
Section 6104.2 is amended to read as follows:
6104.2 Maximum capacity within established limits. The storage of liquefied petroleum gas is restricted in all locations of the City of Los Altos that are residential or congested commercial areas as determined by the fire code official.

Exception: LPG may be used for industrial operations or when natural gas would not provide a viable substitute for LPG. Portable containers for temporary heating and/or cooking uses may be permitted if stored and handled in accordance with this code.

Facilities in commercial areas for refueling portable or mobile LPG containers may be approved by the fire code official on a case-by-case basis.

Chapter 64 PYROPHORIC MATERIALS
Chapter 64 of the 2025 California Fire Code and 2024 International Code is amended as follows:

Section 6405 USE
Section 6405.3.1 is added to read:
6405.3.1 Silane distribution systems automatic shutdown. Silane distribution systems shall automatically shut down at the source upon activation of the gas detection system at levels above the alarm level and/or failure of the ventilation system for the silane distribution system.

Appendix B FIRE-FLOW REQUIREMENTS FOR BUILDINGS
Appendix B of the 2025 California Fire Code and 2024 International Code is amended as follows:

Section B105 FIRE=FLOW REQUIRED FOR BUILDINGS
Section B105.2 is amended as follows:

B105.2 Buildings other than one- and two-family dwellings, Group R-3 and R-4 buildings and townhouses. The minimum fire-flow and flow duration for buildings other than oneand two-family dwellings, Group R-3 and R-4 buildings and townhouses shall be as specified in Tables B105.1(2) and B105.2.

Appendix 10
Exceptions: [SFM] Group B, S-2 and U occupancies having a floor area not exceeding 1,000 square feet, primarily constructed of noncombustible exterior walls with wood or steel roof framing, having a Class A roof assembly, with uses limited to the following or similar uses:

1. California State Parks buildings of an accessory nature (restrooms).

2. Safety roadside rest areas (SRRA), public restrooms.

3. Truck inspection facilities (TIF), CHP office space and vehicle inspection bays.

4. Sand/salt storage buildings, storage of sand and salt.

The maximum fire flow reduction for all commercial buildings greater than 30,000 square feet and residential podium buildings shall not exceed 25 percent of the fire flow specified in Table B105.1(2). The maximum fire flow reduction for all other buildings shall not exceed 50 percent of the fire flow specified in Table B105.1(2).

Appendix C FIRE HYDRANT LOCATIONS AND DISTRIBUTION
Appendix C of the 2025 California Fire Code and 2024 International Code is amended as follows:

Section C102 NUMBER OF FIRE HYDRANTS
Section C102.1 is amended to read:

C102.1 Minimum number of fire hydrants for a building. The number of fire hydrants available to a building shall be not less than the minimum specified in Table C102.1, utilizing the base fire flow without fire sprinkler reduction.

Appendix D FIRE APPARATUS ACCESS ROADS
Appendix D of the 2025 California Fire Code and 2024 International Code is amended as follows:

Section D103 MINIMUM SPECIFICATION
Section D103.1 is deleted:

Section D103.2 is amended as follows:

D103.2 Grade. The maximum grade of a fire department apparatus access road shall not exceed 15-percent, unless approved by the fire code official.

Section D103.3 is amended as follows:

Appendix 10
D103.3 Turning radius. The required turning radius of a fire apparatus access roads shall be a minimum of 30 feet inside, and a minimum of 50 feet outside.

Section D103.4 is amended as follows:

D103.4 Dead ends. Dead-end fire apparatus access roads and/or driveways in excess of 150 feet (45 720 mm) shall be provided with width and turnaround provisions in accordance with the Santa Clara County Fire Department apparatus access and turnaround standards.

Section D103.6 is amended as follows:

D103.6 Signs. Where required by the Fire Code Official, fire apparatus access roads shall be designated and marked as a fire lane as set forth in Section 22500.1 of the California Vehicle Code and the Santa Clara County Fire Department A-6 Standard. Signs shall have a minimum dimension of 12 inches (305 mm) wide by 18 inches (457 mm) high and have red letters on a white reflective background. Signs shall be posted on one or both sides of the fire apparatus road as required by Section D103.6.1 or D103.6.2.

APPENDIX 11
Chapter 12.24 – California Existing Building Code

12.24.010 - Adoption of the California Existing Building Code.

There is hereby adopted by reference as if fully set forth herein, the 2025 California Existing Building Code, contained in the California Code of Regulations, Title 24, Part 10, published by the International Code Council, and each and all of its regulations and provisions. One (1) copy of said code is on file for use and examination by the public in the Development Services Department of the City of Los Altos.

APPENDIX 12
Chapter 12.26 – Green Building Standards Code
Section 12.26.010 Adoption of the California Green Building Standards Code Section 12.26.020 Amendments, Additions or Deletions
Section 12.26.010 Adoption of the California Green Building Standards Code There is hereby adopted by reference as if fully set forth herein, the 2025 California Green Building Standards Code, contained in the California Code of Regulations, Title 24, Part 11, published by the International Code Council, and each and all of its regulations and provisions.

Section 12.26.020 Amendments, Additions or Deletions
The 2025 California Green Building Standards Code referred to in Section 12.26.010 is adopted, together with Chapters 1 Administration, 4 Residential Mandatory Measures, and 5 Nonresidential Mandatory Measures, of the 2025 California Green Building Standards Code, with the following amendments as follows:

Chapter 1 Section 102.4 Scope and Mandatory Compliance is hereby added to read as follows:

Section 102.4 Scope and Mandatory Compliance
A. This code contains both mandatory and voluntary green building measures.

Mandatory and voluntary measures are identified in the appropriate chapters contained in this code. Compliance measures and methods shall be by one of the following measures approved by the Building Official.

The means by which compliance measures are achieved shall be mandatory measures with appendix sections voluntarily applied, building division mandatory check list, whole house Build it Green GreenPoint check list, LEED, other recognized point systems, Title 24 Part 6 Energy Efficiency Standards, or equivalent approved methods. Green Building Compliance measures in addition to checklists shall be incorporated into the project drawings approved by the Building Official prior to building permit submittal.

Prior to issuance of a building permit, the owner or responsible Registered Design Professional acting as the owner’s agent shall employ and/or retain a Qualified Green Building Professional to the satisfaction of the Building Official, and prior to final inspection shall submit verification that the project is in compliance with this ordinance.

APPENDIX 13
Chapter 12.28 – California Referenced Standards Code

12.42.010 - Adoption of the California Referenced Standards Code.

There is hereby adopted by reference as if fully set forth herein, the 2022 California Referenced Standards Code, contained in the 2025 edition of the California Code of Regulations, Title 24, Part 12, published by the International Code Council, and each and all of its regulations and provisions. One (1) copy of said code is on file for use and examination by the public in the Development Services Department of the City of Los Altos.

APPENDIX 14
Chapter 12.30 Penalty for Expired Permits

12.30.010 Application.

This chapter shall apply to all residential, non-residential, commercial, construction and demolition, including, but not limited to, all additions, alterations, modifications, repairs, and improvements, that require a building permit or demolition permit.

12.30.020 Timely renewal of expired permits.

In the event a permit expires under Chapter 12 of the Los Altos Municipal Code for suspension or abandonment of work, the property owner shall seek renewal of the permit within thirty (30) days following its expiration.

12.30.030 Penalty for expired permits.

A property owner shall be subject to the following penalties for violation of Section

12.30.020:

Time for Permit Expiration Penalty
0 to 30 days $0.00
31st day through 60th day $200.00 per day
61st day through 120th day $400.00 per day
121st day and every day thereafter $800.00 per day
A. For purposes of this section, if a renewed permit expires and the property owner has not advanced a project to the next level of required inspection, the calculation of penalties shall relate back to the date of the previous permit expiration.

B. The building official may reduce or waive a penalty accrued under this chapter upon finding that the property owner acted in good faith and either: (1) the delay was attributable to circumstances beyond the property owner's control; or (2) imposition of the full accrued penalty would harm the public interest, provided, however, that and reduction or waiver of more than ten thousand dollars ($10,000.00) must be approved by the development services director.

12.30.040 Appeal of assessed penalty.

A property owner may request a hearing to contest a citation issued under this chapter in accordance with Title 1 of the Los Altos Municipal Code.

12.30.050 Public nuisance declared.

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Any violation of this chapter shall constitute a public nuisance and, in addition to being subject to any other remedies allowed by law, may be abated as provided in Chapter 11.10 of the Los Altos Municipal Code.

APPENDIX 15
Chapter 12.32 – Property Maintenance Code

12.32.010 Title.

This chapter shall be known and may be cited as the "Los Altos Property Maintenance Code" or "LAPMC" and will be referred to in this chapter as "this code."

12.32.020 Adoption of the 2024 International Property Maintenance with Amendments.

The 2024 Edition of the International Property Maintenance Code as published by the International Code Council is adopted as the property maintenance code of the city of Los Altos, California, as if fully set out in this chapter, and is amended as provided in this chapter. One (1) copy of said code is on file for use and examination by the public in the Development Services Department of the City of Los Altos.

12.32.030 Amendment of 2024 IPMC Section 102 (Applicability).

Section 102 of the 2024 IPMC is amended as follows:
102.1-102.7 {IPMC text not modified}
102.8.1 Conflicts. Where conflicts occur between the provision of this code and the referenced standards, the provisions of this code shall apply. Where conflicts occur between the provisions of this code and California Statutes, the provisions of the latter shall apply.
102.8.2-102.11 {IPMC text not modified}

12.32.040 Amendment of 2024 IPMC Section 103 (Code Compliance Agency).

Section 103 Code Compliance Agency of the 2024 IPMC is amended as follows:
103.1 Creation of agency. The Code Enforcement Division of the Development Services Department shall be responsible for the implementation, administration, and enforcement of the provisions of this code. The building official in charge of the Los Altos Building & Safety Division of the Development Services Department shall be known as the code official in this chapter.
103.2 {IPMC text not modified}
103.3 Deputies. The code official shall have the authority to appoint 1 or more deputies.

Such employees shall have the powers as delegated by the code official.

12.32.050 Amendment of 2024 IPMC Section 105 (Duties and Powers of the Code Official).

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Section 105 of the 2024 IPMC is amended as follows:
105.1-105.2 {IPMC text not modified}
105.3 Right of entry. Where it is necessary to make an inspection to enforce the provisions of this code, or whenever the code official has reasonable cause to believe that there exists in a structure or upon a premises a condition in violation of this code, the code official is authorized to enter the structure or premises at reasonable times to inspect or perform the duties imposed by the code, provided that if such structure or premises is occupied the code official shall present credentials to the occupant and request entry. If such structure or premises is unoccupied, the code official shall first make a reasonable effort to locate the owner, owner's authorized agent, or other person having charge or control of the structure or premises and request entry. If entry is refused, the code official shall have recourse to the remedies provided by law to secure entry. 105.4-105.7.1 {IPMC text not modified}

12.32.060 Amendment of 2024 IPMC Section 107 (Means of Appeal).

Section 107 of the 2024 IPMC is amended as follows:
107.1 Application for appeal. Any person directly affected by a decision of the code official or a notice or order issued under this code may appeal that decision, notice or order by filing an appeal with the city clerk within fourteen (14) calendar days of the date of service of that decision, notice, or order. The appeal shall be based on a claim that the true intent of this code or the rules legally adopted thereunder have been incorrectly interpreted, the provisions of this code do not fully apply, or the requirements of this code are adequately satisfied by other means. The appeal shall identify the real property, state the grounds for the appeal, and state all material facts in support of the appeal. 107.2 Notice of hearing. Notice of hearing and the hearing shall be conducted as provided for in Chapter 1.12 of the Los Altos Municipal Code.
107.3 Court review. Judicial review of the hearing officer's decision shall be commenced in accordance with Cal. Code of Civil Procedure § 1094.6 no later than ninety (90) calendar days after the decision is signed. Cal. Code of Civil Procedure § 1094.6 is hereby adopted for purposes of this Title. Review shall be in accordance with Cal. Code of Civil Procedure § 1094.5.

12.32.070 Amendment of 2024 IPMC Section 109 (Violations).

Section 109 of the 2024 IPMC is amended as follows:

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109.1 Unlawful acts. It is hereby declared to be unlawful and a public nuisance for any person, firm or corporation to erect, construct, enlarge, alter, repair, move, improve, remove, convert or demolish, equip, use, occupy or maintain any premises, building, structure or building service equipment, or cause or permit the same to be done in violation of this code or this division.
109.2 Notice of violation. The code official shall serve a notice of violation in accordance with Section 111.4.
109.3 Prosecution of violation. Any person failing to comply with a notice of violation served in accordance with Section 111.4 shall be deemed guilty of a misdemeanor but may be charged with an infraction at the discretion of the city attorney, or civil infraction enforceable under Chapter 1.20 of the Los Altos Municipal Code as determined by the city and the violation shall be deemed a strict liability offense. If the notice of violation is not complied with, the code official shall institute the appropriate administrative, civil, or criminal proceeding to restrain, correct or abate such violation, or to require the removal or termination of the unlawful occupancy of the structure in violation of this code or of the order or direction made pursuant thereto.
109.4 Violation Penalties. Each day during any portion of which any violation of this ordinance is committed or continued by such person shall constitute a separate offense and shall be punishable as provided in this code and Title 1 of the Los Altos Municipal Code.
109.5 Abatement of violation. The city may abate a violation of this code pursuant to the abatement process set forth in the Los Altos Municipal Code.

12.32.080 Amendment of 2024 IPMC Section 110 (Stop Work Order).

Section 110 of the 2024 IPMC is amended as follows:
110.1 - 110.3 {IPMC text not modified}
110.4 Failure to comply. Any person who continues any work after having been served with a stop work order, except such work as that person is directed to perform to remove a violation or unsafe condition, shall be liable for civil penalties pursuant to the Los Altos Municipal Code Chapter 1.20.

APPENDIX 16
Chapter 12.34 – Abatement of Dangerous Buildings

12.34.010 - Adoption of the Uniform Code for the Abatement of Dangerous Buildings.

The 1998 edition of the California Code of Regulations, incorporating the Uniform Code for the Abatement of Dangerous Buildings, 1997 Edition, published by the International Conference of Building Officials, is hereby adopted. One (1) copy of said code is on file for use and examination by the public in the Development Services Department of the City of Los Altos.

APPENDIX 17
Chapter 12.36 – Housing Code

12.36.010 – Adoption of the Uniform Housing Code.

The 1998 edition of the California Building Standards Code, incorporating the Uniform Housing Code, 1997 edition, published by the International Conference of Building Officials, is hereby adopted. One (1) copy of said code is on file for use and examination by the public in the Development Services Department of the City of Los Altos.

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Chapter 12.38 – Undergrounding Utilities
Section 12.38.010 Purpose.

Section 12.38.020 Undergrounding utilities.

Section 12.38.010 Purpose.

The purpose of this chapter is to improve and maintain the visual quality and public and private views in the city, as well as to protect and enhance the health and quality of life of its citizens, by reducing hazards along with the visual blight created by overhead utilities.

Section 12.38.020 Undergrounding utilities.

It is the intent of the city to ensure that all new utility services and relocated existing utility services are placed underground, including additions exceeding fifty (50) percent of floor area and/or seven hundred and fifty (750) square feet or more, excluding basements and any non-habitable floor areas. For the purpose of this section, removal of roof framing with associated exterior walls down to, or below the subfloor/slab shall be included in the above calculations. Therefore, the following shall apply:
a. In areas served by existing overhead facilities, all new service drops shall be installed underground from the most convenient existing pole.
b. Relocations and extensions of existing overhead facilities shall be prohibited; provided, however, relocation of existing poles shall be permitted in some instances pursuant to Section 13.20.160 of this municipal code.
c. Residential properties that are served by utilities located in rear yards on standard lots with frontage on only one public right-of-way shall not be required to underground existing overhead services.
d. The obligation to provide compliance with these underground utility regulations may not be evaded by performing a series of small additions undertaken over a three-year period and/or two code cycles. The original addition permit issuance date where these regulations were in effect shall be used for compliance. i. Any submittal for building permits which exceed fifty (50) percent and/or seven hundred and fifty (750) square feet of existing floor areas (area calculations shall not include existing basement floor areas and any non-habitable floor areas i.e., garages) during the three-year period shall comply with undergrounding of utility regulations.
ii. No exception or waiver shall be granted from compliance with undergrounding utilities.

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e. The Building Official may only grant exceptions to these requirements in cases where access across adjacent property is necessary but is not legally or practically available.
i. To demonstrate an exception the property owner shall provide a plan showing the required utility design, communication with adjacent property owners indicating the lack of access allowed, and a letter from the utility company which indicates that no alternative configuration for undergrounding of utilities is possible.
f. Completion of Work. Undergrounding utilities shall be completed prior to Building Final Inspection, and issuance of Certificate of Occupancy. No exception or waiver shall be granted which allows for a property owner to evade compliance with this requirement.

APPENDIX 18
Chapter 12.40 – Floodplain Management
Article 1. General Provisions

12.40.010 Title.

These regulations, in combination with the flood provisions of California Code of Regulations Title 24, the California Building Standards Code (hereinafter "building codes," consisting of the Part 2 (building), Part 2.5 (residential), Part 10 (existing building), and related codes), shall be known as the Floodplain Management Regulations of the City of Los Altos (hereinafter "these regulations").

12.40.020 Statutory authority.

Legislature of the State of California has, in Government Code Sections 65302, 65560, and 65800, conferred upon local governments the authority to adopt regulations designed to promote the public health, safety, and general welfare of its citizenry.

12.40.030 Scope.

The provisions of these regulations, in combination with the flood provisions of the building codes, shall apply to all proposed development entirely or partially in flood hazard areas established in Section 12.40.110 of these regulations.

The purposes and objectives of these regulations and the flood load and flood resistant construction requirements of the building codes are to promote the public health, safety and general welfare and to minimize public and private losses due to flood conditions in specific flood hazard areas through the establishment of comprehensive regulations for management of flood hazard areas, designed to:

A. Minimize unnecessary disruption of commerce, access and public service during times of flooding.

B. Require the use of appropriate construction practices in order to prevent or minimize future flood damage.

C. Manage the alteration of natural floodplains, stream channels and shorelines to minimize the impact of development on the natural and beneficial functions of the floodplain.

D. Manage filling, grading, dredging, mining, paving, excavation, drilling operations, storage of equipment or materials, and other development which may increase flood damage or erosion potential.

E. Prevent or regulate the construction of flood barriers which will divert floodwater or increase flood hazards.

F. Contribute to improved construction techniques in the floodplain.

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G. Minimize damage to public and private facilities and utilities.

H. Help maintain a stable tax base by providing for the sound use and development of flood hazard areas.

I. Minimize the need for rescue and relief efforts associated with flooding.

J. Ensure that property owners, occupants, and potential owners are aware of property located in flood hazard areas.

K. Minimize the need for future expenditure of public funds for flood control projects and response to and recovery from flood events.

L. Meet the requirements of the National Flood Insurance Program for community participation as set forth in Title 44 Code of Federal Regulations, Section 59.22.

12.40.050 Coordination with California Building Standards Code.

Pursuant to the requirement established in State statute that the City of Los Altos administer and enforce the California Building Standards Code, the city council of the City of Los Altos hereby acknowledges that the building codes contain certain provisions that apply to the design and construction of buildings and structures in flood hazard areas. Therefore, these Regulations are intended to be administered and enforced in conjunction with the building codes.

12.40.060 Warning.

The degree of flood protection required by these regulations and the building codes is considered reasonable for regulatory purposes and is based on scientific and engineering considerations. Larger floods can and will occur. Flood heights may be increased by manmade or natural causes. Enforcement of these Regulations and the building codes does not imply that land outside the special flood hazard areas, or that uses permitted within such flood hazard areas, will be free from flooding or flood damage. The flood hazard areas and base flood elevations contained in the Flood Insurance Study and shown on Flood Insurance Rate Maps and the requirements of Title 44 Code of Federal Regulations, Sections 59 and 60 may be revised by the Federal Emergency Management Agency, requiring this community to revise these Regulations to remain eligible for participation in the National Flood Insurance Program. No guaranty of vested use, existing use, or future use is implied or expressed by compliance with these regulations.

12.40.070 Disclaimer of liability.

These regulations shall not create liability on the part of the City of Los Altos, the city council, any officer or employee thereof, the State of California, or the Federal Emergency Management Agency, for any flood damage that results from reliance on these regulations or any administrative decision lawfully made hereunder. The floodplain administrator and

APPENDIX 18
any employee charged with the enforcement of these regulations, while acting for the community in good faith and without malice in the discharge of the duties required by these regulations or other pertinent law or ordinance, shall not thereby be rendered liable personally and is hereby relieved from personal liability for any damage accruing to persons or property as a result of any act or by reason of an act or omission in the discharge of official duties. Any suit instituted against an officer or employee because of an act performed by that officer or employee in the lawful discharge of duties and under the provisions of these regulations shall be defended by a legal representative of the community until the final termination of the proceedings. The floodplain administrator and any subordinate shall not be liable for cost in any action, suit or proceeding that is instituted in pursuance of the provisions of these regulations.

12.40.080 Other laws.

The provisions of these regulations shall not be deemed to nullify any provisions of local, state or federal law.

12.40.090 Abrogation and greater restrictions.

These regulations supersede any ordinance in effect in flood hazard areas. However, these regulations are not intended to repeal, abrogate or impair any existing ordinances including land development regulations, subdivision regulations, zoning ordinances, stormwater management regulations, or building codes, nor any existing easements, covenants, or deed restrictions. In the event of an overlap or conflict between these regulations and any other ordinance, code, regulation, easement, covenant, or deed restriction, the more restrictive shall govern.

Article 2. Applicability

12.40.100 General applicability.

These regulations, in conjunction with the building codes, provide minimum requirements for development located in flood hazard areas, including the subdivision of land; filling, grading and other site improvements; installation of utilities; installation, placement and replacement of manufactured homes; placement of recreational vehicles; installation of tanks; temporary structures and temporary or permanent storage; utility and miscellaneous Group U buildings and structures; certain building work exempt from permit under the building codes; and flood control projects.

12.40.110 Establishment of flood hazard areas.

The flood insurance study for the City of Los Altos, Santa Clara County, California and Incorporated Areas dated January 1980, and all subsequent amendments and revisions, and

APPENDIX 18
the accompanying flood insurance rate maps (FIRM), and all subsequent amendments and revisions to such maps, are hereby adopted by reference as a part of these Regulations and serve as the basis for establishing flood hazard areas. Where the building code establishes flood hazard areas, such areas are established by this section. Additional maps and studies, when specifically adopted, supplement the FIS and FIRMs to establish additional flood hazard areas. Maps and studies that establish flood hazard areas are on file at the Community Development Department, One North San Antonio Road, Los Altos, CA 94022.

12.40.120 Interpretation.

In the interpretation and application of these regulations, all provisions shall be:

A. Considered as minimum requirements.

B. Liberally construed in favor of the governing body.

C. Deemed neither to limit nor repeal any other powers granted under state statutes.

Article 3. Duties and Powers of The Floodplain Administrator

12.40.130 Designation.

The Development Services Director, or his or her designee, is designated the floodplain administrator. The floodplain administrator shall have the authority to delegate performance of certain duties to other employees.

12.40.140 General authority.

The floodplain administrator is authorized and directed to administer and enforce these regulations. the floodplain administrator shall have the authority to render interpretations of these regulations and to establish policies and procedures in order to clarify the application of its provisions. Such interpretations, policies and procedures shall be consistent with the intent and purpose of these regulations and the flood provisions of the building code and shall not have the effect of waiving specific requirements without the granting of a variance pursuant to Article 7 of these regulations. The floodplain administrator is authorized to waive the submission of site plans, construction documents, and other data that are required by these regulations but that are not required to be prepared by a qualified California (CA) Licensed Land Surveyor or Civil Engineer when it is found that the nature of the proposed development is such that the review of such submissions is not necessary to ascertain compliance with these regulations.

12.40.150 Coordination.

The floodplain administrator shall coordinate with and provide comments to the building official to administer and enforce the flood provisions of the building code and to ensure

APPENDIX 18
compliance with the applicable provisions of these regulations. The floodplain administrator and the building official have the authority to establish written procedures for reviewing applications and conducting inspections for buildings and for administering and documenting determinations of substantial improvement and substantial damage made pursuant to Section 12.40.170 of these regulations.

12.40.160 Duties.

The floodplain administrator, in coordination with other pertinent offices of the community, shall:

A. Review all permit applications and plans to determine whether proposed development is located in flood hazard areas.

B. Review all applications and plans for development in flood hazard areas for compliance with these regulations.

C. Review, in coordination with the building official, required design certifications and documentation of elevations specified by the building code to determine that such certifications and documentations are complete.

D. Review applications and plans for modification of any existing development in flood hazard areas for compliance with these regulations.

E. Require development in flood hazard areas to be reasonably safe from flooding and to be designed and constructed with methods, practices and materials that minimize flood damage.

F. Interpret flood hazard area boundaries and provide available flood elevation and flood hazard information.

G. Determine whether additional flood hazard data shall be obtained from other sources or developed by the applicant.

H. Complete the appropriate section of the Department of Housing and Community Development Floodplain Ordinance Compliance Certification for Manufactured Home/Mobile home Installations when submitted by applicants.

I. Review requests submitted to the building official seeking approval to modify the strict application of the flood load and flood resistant construction requirements of the building code, to determine whether such requests require consideration as a variance pursuant to Article 7 of these regulations.

J. Coordinate with the building official and others to identify and investigate damaged buildings located in flood hazard areas and inform owners of the requirement to obtain permits for repairs.

K. Require applicants who submit hydrologic and hydraulic engineering analyses to support permit applications to submit to FEMA the data and information necessary

APPENDIX 18
to maintain the flood insurance rate maps when the analyses indicate changes in base flood elevations, flood hazard area boundaries, or floodway designations; such submissions shall be made within six months of such data becoming available.

L. Require applicants who propose alteration of a watercourse to notify adjacent communities and the NFIP State Coordinating Agency, and to submit copies of such notifications to the Federal Emergency Management Agency (FEMA).

M. Inspect development in accordance with Article 6 of these regulations and inspect flood hazard areas to determine when development is undertaken without issuance of permits.

N. Prepare comments and recommendations for consideration when applicants seek variances for development other than buildings in accordance with Article 7 of these regulations.

O. Cite violations in accordance with Article 8 of these regulations.

P. Notify FEMA when the corporate boundaries of the City of Los Altos have been modified and provide a map and legal description of the changes in the corporate boundaries.

12.40.170 Substantial improvement and substantial damage determinations.

For applications for building permits to improve buildings and structures, including alterations, movement, enlargement, replacement, repair, additions, rehabilitations, renovations, substantial improvements, repairs of substantial damage, and any other improvement of or work on such buildings and structures, the floodplain administrator, in coordination with the building official, shall:

A. Estimate the market value, or require the applicant to obtain an appraisal of the market value prepared by a qualified independent appraiser, of the building or structure before the start of construction of the proposed work; in the case of repair, the market value of the building or structure shall be the market value before the damage occurred and before any repairs are made.

B. Compare the cost to perform the improvement, the cost to repair the damaged building to its pre-damaged condition, or the combined costs of improvements and repairs, when applicable, to the market value of the building or structure.

C. Determine and document whether the proposed work constitutes substantial improvement or repair of substantial damage.

D. Notify the applicant when it is determined that the work constitutes substantial improvement or repair of substantial damage and that compliance with the flood resistant construction requirements of the building code is required and notify the

APPENDIX 18
applicant when it is determined that work does not constitute substantial improvement or repair of substantial damage.

12.40.180 Department records.

In addition to the requirements of the building code and these regulations, and regardless of any limitation on the period required for retention of public records, the floodplain administrator shall maintain and permanently keep and make available for public inspection all records that are necessary for the administration of these regulations and the flood provisions of the building codes, including flood insurance studies and flood insurance rate maps; documents from FEMA that amend or revise FIRMs; records of issuance of permits and denial of permits; determinations of whether proposed work constitutes substantial improvement or repair of substantial damage; required certifications and documentation specified by the building codes and these regulations; notifications to adjacent communities, FEMA, and the State related to alterations of watercourses; assurance that the flood carrying capacity of altered waterways will be maintained; documentation related to variances, including justification for issuance or denial; and records of enforcement actions taken pursuant to these regulations and the flood resistant provisions of the building codes.

Article 4. Permits for Floodplain Development

12.40.190 Permits required.

Any person, owner or authorized agent who intends to conduct any development in a flood hazard area shall first make application to the floodplain administrator and shall obtain the required permit for floodplain development. No permit shall be issued until compliance with the requirements of these regulations and all other applicable codes and regulations has been satisfied. No building permit shall be issued based on conditional letters of map revision issued by FEMA. Depending on the nature and extent of proposed development that includes a building or structure, the floodplain administrator may determine a permit for floodplain development is required in addition to a building permit.

12.40.200 Application for permit.

The applicant shall file an application in writing on a form furnished by the floodplain administrator. The information provided shall:

A. Identify and describe the development to be covered by the permit.

B. Describe the land on which the proposed development is to be conducted by legal description, street address or similar description that will readily identify and definitely locate the site.

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C. Indicate the use and occupancy for which the proposed development is intended.

D. Be accompanied by a site plan and construction documents as specified in Article 5 of these regulations, including grading, excavation and filling plans and other information deemed appropriate by the floodplain administrator.

E. State the valuation of the proposed work.

F. Be signed by the applicant or the applicant's authorized agent.

G. Include such other data and information required by the floodplain administrator to demonstrate compliance with these Regulations.

12.40.210 Validity of permit.

The issuance of a permit for floodplain development under these regulations or the building codes shall not be construed to be a permit for, or approval of, any violation of these regulations, the building code, or any other ordinance of the community. The issuance of a permit for floodplain development based on submitted documents and information shall not prevent the floodplain administrator from requiring the correction of errors and omissions.

The floodplain administrator is authorized to prevent occupancy or use of a structure or site which is in violation of these regulations.

12.40.220 Other permits required.

The applicant shall obtain all other required state and federal permits prior to initiating work authorized by these regulations and shall provide documentation of such permits to the floodplain administrator. Such permits include but are not limited to the California State Water Resources Control Board for activities that affect wetlands and alter surface water flows, in conjunction with the U.S. Army Corps of Engineers; Section 404 of the Clean Water Act.

12.40.230 Expiration.

A permit for floodplain development shall become invalid when the proposed development is not commenced within one hundred eighty (180) days after its issuance, or when the work authorized is suspended or abandoned for a period of one hundred eighty (180) days after the work commences. Extensions shall be requested in writing and justifiable cause demonstrated. The floodplain administrator is authorized to grant, in writing, one or more extensions of time, for periods not more than one hundred eighty (180) days each unless FEMA has issued notification of revision to the flood insurance rate study and flood insurance rate maps that alter the flood hazard area or floodway boundaries, flood zones, or base flood elevations, in which case the permit is invalid.

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12.40.240 Suspension or revocation.

The floodplain administrator is authorized to suspend or revoke a permit for floodplain development issued under these regulations wherever the permit is issued in error or on the basis of incorrect, inaccurate or incomplete information, or in violation of these regulations or any ordinance or code of this community.

12.40.250 Appeals of decisions.

When it is alleged there is an error in any decision or determination made by the floodplain administrator in the interpretation or enforcement of these regulations, such decision or determination may be appealed to the city manager by filing a written appeal setting forth the reasons of the appeal.

Article 5. Site Plans and Construction Documents

12.40.260 Information for development in flood hazard areas.

The site plan or construction documents for any development subject to the requirements of these regulations shall be drawn to scale and shall include, as applicable to the proposed development:

A. Delineation of flood hazard areas; floodway boundaries and flood zone(s); base flood elevation(s); ground elevations; proposed filling, grading, and excavation; and drainage patterns and facilities when necessary for review of the proposed development.

B. Where base flood elevations or floodway data are not included on the FIRM or in the flood insurance study, they shall be established in accordance with Section

12.40.270 or Section 12.40.280 of these regulations.

C. Where the parcel on which the proposed development will take place will have more than fifty (50) lots or is larger than five acres and base flood elevations are not included on the FIRM or in the flood insurance study, such elevations shall be established in accordance with Section 12.40.270.B of these regulations.

D. Location of the proposed activity and proposed structures; locations of water supply, sanitary sewer, and other utilities; and locations of existing buildings and structures.

E. Location, extent, amount, and proposed final grades of any filling, grading, or excavation.

F. Where the placement of fill is proposed, the amount, type, and source of fill material; compaction specifications; a description of the intended purpose of the fill areas; and evidence that the proposed fill areas are the minimum necessary to achieve the intended purpose.

G. Existing and proposed alignment of any proposed alteration of a watercourse.

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12.40.270 Information in flood hazard areas without base flood elevations (approximate Zone A).

Where flood hazard areas are delineated on the FIRM and base flood elevation data have not been provided, the floodplain administrator is authorized to:

A. Require the applicant to include base flood elevation data prepared by a qualified CA Licensed Civil Engineer in accordance with currently accepted engineering practices.

Such analyses shall be performed and sealed by a qualified CA Licensed Civil Engineer. Studies, analyses and computations shall be submitted in sufficient detail to allow review and approval by the floodplain administrator. The accuracy of data submitted for such determination shall be the responsibility of the applicant.

B. Obtain, review, and provide to applicants base flood elevation and floodway data available from a federal or state agency or other source or require the applicant to obtain and use base flood elevation and floodway data available from a federal or state agency or other source.

C. Where base flood elevation and floodway data are not available from another source, where the available data are deemed by the floodplain administrator to not reasonably reflect flooding conditions, or where the available data are known to be scientifically or technically incorrect or otherwise inadequate:

1. Require the applicant to include base flood elevation data in accordance with Section 12.40.270.A of these regulations; or

2. Specify that the base flood elevation is two feet above the highest adjacent grade at the location of the development, provided there is no evidence indicating flood depths have been or may be greater than two feet.

D. Where the base flood elevation data are to be used to support a request for a letter of map change from FEMA, advise the applicant that the analyses shall be prepared by a qualified CA Licensed Civil Engineer in a format required by FEMA, and that it shall be the responsibility of the applicant to satisfy the submittal requirements and pay the processing fees.

12.40.280 Additional analyses and certifications.

As applicable to the location and nature of the proposed development activity, and in addition to the requirements of these Regulations, the applicant shall have the following analyses signed and sealed by a qualified CA Licensed Civil Engineer for submission with the site plan and construction documents:

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A. For development activities proposed to be located in a floodway, a floodway encroachment analysis that demonstrates that the encroachment of the proposed development will not cause any increase in base flood elevations; where the applicant proposes to undertake development activities that do increase base flood elevations, the applicant shall submit such analysis to FEMA as specified in Section

12.40.290 of these regulations and shall submit the conditional letter of map revision, when issued by FEMA, with the site plan and construction documents.

B. For development activities proposed to be located in a riverine flood hazard area where base flood elevations are included in the flood insurance study or on the FIRM but floodways have not been designated, hydrologic and hydraulic analyses that demonstrate that the cumulative effect of the proposed development, when combined with all other existing and anticipated flood hazard area encroachments, will not increase the base flood elevation more than one foot at any point within the community. This requirement does not apply in isolated flood hazard areas not connected to a riverine flood hazard area or in flood hazard areas identified as Zone AO or Zone AH.

C. For alteration of a watercourse, an engineering analysis prepared in accordance with standard engineering practices that demonstrates the flood-carrying capacity of the altered or relocated portion of the watercourse will not be decreased, and certification that the altered watercourse shall be maintained in a manner which preserves the channel's flood-carrying capacity. The applicant shall submit the analysis to FEMA as specified in Section 12.40.290 of these regulations. The applicant shall notify the chief executive officer of adjacent communities and the California Department of Water Resources. The floodplain administrator shall maintain a copy of the notification in the permit records and shall submit a copy to FEMA.

12.40.290 Submission of additional data.

When additional hydrologic, hydraulic or other engineering data, studies, and additional analyses are submitted to support an application, the applicant has the right to seek a letter of map change from FEMA to change the base flood elevations, change floodway boundaries, or change boundaries of flood hazard areas shown on FIRMs, and to submit such data to FEMA for such purposes. The analyses shall be prepared by a qualified CA Licensed Civil Engineer in a format required by FEMA. Submittal requirements and processing fees shall be the responsibility of the applicant. Provided FEMA issues a conditional letter of map revision, construction of proposed flood control projects and land preparation for development are permitted, including clearing, excavation, grading, and

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filling. Permits for construction of buildings shall not be issued until the applicant satisfies the FEMA requirements for issuance of a letter of map revision.

Article 6. Inspections

12.40.300 Inspections, in general.

Development for which a permit for floodplain development is required shall be subject to inspection. Approval as a result of an inspection shall not be construed to be an approval of a violation of the provisions of these regulations or the building code. Inspections presuming to give authority to violate or cancel the provisions of these regulations or the building code or other ordinances shall not be valid.

12.40.310 Inspections of development other than buildings and structures.

The floodplain administrator shall make or cause to be made, inspections of all development other than buildings and structures that is authorized by issuance of a permit for floodplain development under these regulations. The floodplain administrator shall inspect flood hazard areas from time to time to determine when development is undertaken without issuance of a permit.

12.40.320 Inspections of manufactured homes installations.

The floodplain administrator shall make or cause to be made, inspections of installation and replacement of manufactured homes in flood hazard areas authorized by issuance of a permit for floodplain development under these regulations. Upon installation of a manufactured home and receipt of the elevation certification required in Section 12.40.580 of these regulations the floodplain administrator shall inspect the installation or have the installation inspected.

12.40.330 Buildings and structures.

The building official shall make or cause to be made, inspections for buildings and structures in flood hazard areas authorized by permit, in accordance with the building code:

A. Lowest floor elevation. Upon placement of the lowest floor, including the basement, and prior to further vertical construction, certification of the elevation required in the building code shall be prepared by a CA Licensed Land Surveyor or Civil Engineer and submitted to the building official.

B. Final inspection. Prior to the final inspection, certification of the elevation required in the building code shall be prepared by a CA Licensed Land Surveyor or Civil Engineer and submitted to the building official.

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Article 7. Variances

12.40.340 Nature of variances.

The considerations and conditions for variances set forth in this article are based on the general principle of zoning law that variances pertain to a piece of property and are not personal in nature. A variance may be issued for a parcel of property with physical characteristics so unusual that complying with the requirements of these regulations would create an exceptional hardship to the applicant or the surrounding property owners. The characteristics must be unique to the property and not be shared by adjacent parcels. The unique characteristic must pertain to the land itself, not to the structure, its inhabitants, or the property owners. The issuance of a variance is for floodplain management purposes only. Federal flood insurance premium rates are determined by the National Flood Insurance Program according to actuarial risk and will not be modified by the granting of a variance.

It is the duty of the City of Los Altos to promote public health, safety and welfare and minimize losses from flooding. This duty is so compelling and the implications of property damage and the cost of insuring a structure built below flood level are so serious that variances from the elevation or other requirements in the building codes should be quite rare. The long term goal of preventing and reducing flood loss and damage, and minimizing recovery costs, inconvenience, danger, and suffering, can only be met when variances are strictly limited. Therefore, the variance requirements in these regulations are detailed and contain multiple provisions that must be met before a variance can be properly issued. The criteria are designed to screen out those situations in which alternatives other than a variance are more appropriate.

12.40.350 Variances; general.

The city manager shall hear and decide requests for variances from the strict application of these regulations.

12.40.360 Limitations on authority.

The city manager shall base its determination on technical justifications submitted by applicants, the considerations and conditions set forth in this article, the comments and recommendations of the floodplain administrator and building official, as applicable, and has the right to attach such conditions to variances as it deems necessary to further the purposes and objectives of these regulations and the building code.

12.40.370 Records.

The floodplain administrator shall maintain a permanent record of all variance actions, including justification for issuance.

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12.40.380 Historic structures.

A variance is authorized to be issued for the repair, improvement, or rehabilitation of a historic structure upon a determination that the proposed repair, improvement, or rehabilitation will not preclude the structure's continued designation as a historic structure, and the variance is the minimum necessary to preserve the historic character and design of the structure. When the proposed work precludes the structure's continued designation as a historic building, a variance shall not be granted and the structure and any repair, improvement, and rehabilitation shall be subject to the requirements of the building code.

12.40.390 Restrictions in floodways.

A variance shall not be issued for any proposed development in a floodway when any increase in flood levels would result during the base flood discharge, as evidenced by the applicable analyses required in Section 12.40.280.A of these regulations.

12.40.400 Functionally dependent uses.

A variance is authorized to be issued for the construction or substantial improvement necessary for the conduct of a functionally dependent use provided the criteria in Section 1612 of the building code (CCR Title 24 Part 2) or Section R322 of the residential code (CCR Title 24 Part 2.5) are met, as applicable, and the variance is the minimum necessary to allow the construction or substantial improvement, and that all due consideration has been given to use of methods and materials that minimize flood damages during the base flood and create no additional threats to public safety.

12.40.410 Considerations for issuance of variances.

In reviewing applications for variances, all technical evaluations, all relevant factors, all other requirements of these Regulations and the building code, as applicable, and the following shall be considered:

A. The danger that materials and debris may be swept onto other lands resulting in further injury or damage.

B. The danger to life and property due to flooding or erosion damage.

C. The susceptibility of the proposed development, including contents, to flood damage and the effect of such damage on current and future owners.

D. The importance of the services provided by the proposed development to the community.

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E. The availability of alternate locations for the proposed development that are not subject to flooding or erosion and the necessity of a waterfront location, where applicable.

F. The compatibility of the proposed development with existing and anticipated development.

G. The relationship of the proposed development to the comprehensive plan and floodplain management program for that area.

H. The safety of access to the property in times of flood for ordinary and emergency vehicles.

I. The expected heights, velocity, duration, rate of rise and debris and sediment transport of the floodwater and the effects of wave action, if applicable, expected at the site.

J. The costs of providing governmental services during and after flood conditions including maintenance and repair of public utilities and facilities such as sewer, gas, electrical and water systems, streets and bridges.

12.40.420 Conditions for issuance of variances.

Variances shall only be issued upon:

A. Submission by the applicant of a showing of good and sufficient cause that the unique characteristics of the size, configuration or topography of the site limit compliance with any provision of these regulations or renders the elevation standards of the building code inappropriate.

B. A determination that failure to grant the variance would result in exceptional hardship due to the physical characteristics of the land that render the lot undevelopable.

C. A determination that the granting of a variance will not result in increased flood heights, additional threats to public safety, extraordinary public expense, nor create nuisances, cause fraud on or victimization of the public or future property owners, or conflict with existing local laws or ordinances.

D. A determination that the variance is the minimum necessary, considering the flood hazard, to afford relief.

E. When the request is to allow construction of the lowest floor of a new building or substantial improvement of a building below the base flood elevation, notification to the applicant in writing over the signature of the floodplain administrator specifying the difference between the base flood elevation and the proposed elevation of the lowest floor, stating that issuance of a variance to construct below the elevation required in the building code will result in increased premium rates for federal flood insurance up to amounts as high as twenty-five dollars ($25.00) for one hundred

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dollars ($100.00) of insurance coverage, and that such construction below the required elevation increases risks to life and property.

F. Written agreement signed by the recipient of a variance to allow construction of the lowest floor below the required elevation to record the variance in the Office of the Santa Clara County Recorder in a manner so that it appears in the chain of title of the property.

Article 8. Violations

12.40.430 Violations.

Any development in any flood hazard area that is being performed without an issued permit or that is in conflict with an issued permit shall be deemed a violation. A building or structure without the documentation of the elevation of the lowest floor, other required design certifications, or other evidence of compliance required by these regulations or the building code, is presumed to be a violation until such time as required documentation is submitted.

Violation of the requirements shall constitute a misdemeanor.

12.40.440 Authority.

The floodplain administrator is authorized to serve notices of violation or stop work orders to owners of property involved, to the owner's agent, or to the person or persons doing the work for development that is not within the scope of the building codes, but is regulated by these regulations and that is determined to be a violation.

12.40.450 Unlawful continuance.

Any person who shall continue any work after having been served with a notice of violation or a stop work order, except such work as that person is directed to perform to remove or remedy a violation or unsafe condition, shall be subject to penalties as prescribed by law.

Article 9. Definitions

12.40.460 General.

The following words and terms shall, for the purposes of these regulations, have the meanings shown herein. Where terms are not defined in these regulations and are defined in the building code (CCR Title 24 Part 2) and used in the residential code (CCR Title 24 Part

2.5), such terms shall have the meanings ascribed to them in those codes. Where terms are not defined in these Regulations or the building code, such terms shall have ordinarily accepted meanings such as the context implies.

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12.40.470 Definitions.
"Accessory structure" means a structure on the same parcel of property as a principal structure and the use of which is incidental to the use of the principal structure. For floodplain management purposes, the term includes only accessory structures used for parking and storage.
"Agricultural structure" means a walled and roofed structure used exclusively for agricultural purposes or uses in connection with the production, harvesting, storage, raising, or drying of agricultural commodities and livestock, including aquatic organisms. Structures that house tools or equipment used in connection with these purposes or uses are also considered to have agricultural purposes or uses.
"Alteration of a watercourse" means a dam, impoundment, channel relocation, change in channel alignment, channelization, or change in cross-sectional area of the channel or the channel capacity, or any other form of modification which may alter, impede, retard or change the direction and/or velocity of the riverine flow of water during conditions of the base flood.
"ASCE 24" means the standard Flood Resistant Design and Construction, referenced by the building code, developed and published by the American Society of Civil Engineers, Reston, VA. Where cited, ASCE 24 refers to the edition of the standard that is referenced by the building code.
"Base flood" means the flood having a one-percent chance of being equaled or exceeded in any given year. [Also defined in CCR Title 24 Part 2.]
"Base flood elevation" means the elevation of the base flood, including wave height, relative to the National Geodetic Vertical Datum (NGVD), North American Vertical Datum (NAVD) or other datum specified on the flood insurance rate map (FIRM). [Also defined in CCR Title 24 Part 2.]
"Basement" means, for the purpose of floodplain management, the portion of a building having its floor subgrade (below ground level) on all sides. [Also defined in CCR Title 24 Part

2.]
"Building code" means California Code of Regulations Title 24, the California Building Standards Code, the family of building codes specifically adopted by the State of California and composed of:
1) Part 2, applicable to buildings and structures other than dwellings within the scope of this part.

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2) Part 2.5, applicable to one- and two-family dwellings and townhouses not more than three stories, and accessory structures.
3) Part 10, applicable to existing buildings (as defined in that code). 4) Other specified codes.
"Design flood" means the flood associated with the greater of the following two areas: [Also defined in CCR Title 24 Part 2.]
1) Area with a flood plain subject to a one-percent or greater chance of flooding in any year.
2) Area designated as a flood hazard area on a community's flood hazard map, or otherwise legally designated.
"Design flood elevation" means the elevation of the "design flood," including wave height, relative to the datum specified on the community's legally designated flood hazard map. In areas designated as Zone AO, the design flood elevation shall be the elevation of the highest existing grade of the building's perimeter plus the depth number (in feet) specified on the flood hazard map. In areas designated as Zone AO where a depth number is not specified on the map, the depth number shall be taken as being equal to two feet (610 mm). [Also defined in CCR Title 24 Part 2.]
"Development" means any manmade change to improved or unimproved real estate, including but not limited to, buildings or other structures, temporary structures, temporary or permanent storage of materials, mining, dredging, filling, grading, paving, excavations, drilling operations, flood control projects, and other land-disturbing activities. "Encroachment" means the placement of fill, excavation, buildings, permanent structures or other development into a flood hazard area which may impede or alter the flow capacity of riverine flood hazard areas.
"Exceptional hardship" means, for the purpose of variances from these regulations or the building code, the exceptional difficulty that would result from a failure to grant a requested variance. Mere economic or financial hardship is not exceptional. Inconvenience, aesthetic considerations, physical handicaps, personal preferences, or the disapproval of one's neighbors do not, as a rule, qualify as exceptional hardships. All of these circumstances can be resolved through other means without granting variances, even when the alternatives are more expensive or require the property owner to build elsewhere or put the parcel to a different use than originally intended.
"Existing manufactured home park or subdivision" means a manufactured home park or subdivision for which the construction of facilities for servicing the lots on which the manufactured homes are to be affixed (including, at a minimum, the installation of utilities,

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the construction of streets, and either final site grading or the pouring of concrete pads) was completed before July 24, 1980.
"Expansion to an existing manufactured home park or subdivision" means the preparation of additional sites by the construction of facilities for servicing the lots on which the manufactured homes are to be affixed (including the installation of utilities, the construction of streets, and either final site grading or the pouring of concrete pads). "Flood or flooding" means a general and temporary condition of partial or complete inundation of normally dry land from:
1) The overflow of inland or tidal waters.
2) The unusual and rapid accumulation or runoff of surface waters from any source. 3) Mudslides (i.e., mudflows) which are proximately caused by flooding. "Flood control project" means a dam or barrier design and constructed to keep water away from or out of a specified area, including but not limited to levees, floodwalls, and channelization.
"Flood damage-resistant materials" means any construction material capable of withstanding direct and prolonged contact with floodwaters without sustaining any damage that requires more than cosmetic repair. [Also defined in CCR Title 24 Part 2.] "Flood hazard area" means the greater of the following two areas: [Also defined in CCR Title 24 Part 2.]
1) The area within a floodplain subject to a one-percent or greater chance of flooding in any year.
2) The area designated as a flood hazard area on the community's flood hazard map, or otherwise legally designated.
"Flood insurance rate map (FIRM)" means an official map of a community on which the Federal Emergency Management Agency (FEMA) has delineated both the special flood hazard areas and the risk premium zones applicable to the community. [Also defined in CCR Title 24 Part 2.]
"Flood insurance study" means the official report provided by the Federal Emergency Management Agency containing the flood insurance rate map (FIRM), the flood boundary and floodway map (FBFM), the water surface elevation of the base flood and supporting technical data. [Also defined in CCR Title 24 Part 2.]
"Floodplain administrator" means the Development Services Director or his or her designee, to leave in administer and enforce the floodplain management regulations.

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"Floodway" means the channel of the river, creek or other watercourse and the adjacent land areas that must be reserved in order to discharge the base flood without cumulatively increasing the water surface elevation more than a designated height. [Also defined in CCR Title 24 Part 2.]
"Fraud or victimization" means, for the purpose of variances from these regulations or the building code, the intentional use of deceit to deprive another of rights or property, making a victim of the deprived person or the public. As it pertains to buildings granted variances to be constructed below the elevation required by the building code, future owners or tenants of such buildings and the community as a whole may bear the burden of increased risk of damage from floods, increased cost of flood insurance, and increased recovery costs, inconvenience, danger, and suffering.
"Functionally dependent use" means a use that cannot perform its intended purpose unless it is located or carried out in close proximity to water, including only docking facilities, port facilities necessary for the loading or unloading of cargo or passengers, and shipbuilding or ship repair facilities. The term does not include long-term storage, manufacture, sales or service facilities.
"Highest adjacent grade" means the highest natural elevation of the ground surface prior to construction next to the proposed walls or foundation of a structure. "Historic structure" means any structure that is:
1) Listed individually in the National Register of Historic Places (a listing maintained by the Department of Interior) or preliminarily determined by the Secretary of the Interior as meeting the requirements for individual listing on the National Register; 2) Certified or preliminarily determined by the Secretary of the Interior as contributing to the historical significance of a registered historic district or a district preliminarily determined by the Secretary to qualify as a registered historic district; 3) Individually listed on the inventory of historic places maintained by the California Office of Historic Preservation; or
4) Individually listed on a local inventory of historic places in communities with historic preservation programs that have been certified by the California Office of Historic Preservation.
"Letter of map change (LOMC)" means an official determination issued by FEMA that amends or revises an effective flood insurance rate map or flood insurance study. Letters of map change include:
1) Letter of map amendment (LOMA): An amendment based on technical data showing that a property was incorrectly included in a designated special flood hazard area. A

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LOMA amends the current effective Flood Insurance Rate Map and establishes that a specific property, portion of a property, or structure is not located in a special flood hazard area.
2) Letter of map revision (LOMR): A revision based on technical data that may show changes to flood zones, flood elevations, special flood hazard area boundaries and floodway delineations, and other planimetric features.
3) Letter of map revision based on fill (LOMR-F): A determination that a structure or parcel of land has been elevated by fill above the base flood elevation and is, therefore, no longer located within the special flood hazard area. In order to qualify for this determination, the fill must have been permitted and placed in accordance with the community's floodplain management regulations. 4) Conditional letter of map revision (CLOMR): A formal review and comment as to whether a proposed flood protection project or other project complies with the minimum NFIP requirements for such projects with respect to delineation of special flood hazard areas. A CLOMR does not revise the effective flood insurance rate map or flood insurance study; upon submission and approval of certified as-built documentation, a letter of map revision may be issued by FEMA to revise the effective FIRM.
"Light-duty truck" means, as defined in 40 C.F.R. 86.082-2, any motor vehicle rated at eight thousand five hundred (8,500) pounds Gross Vehicular Weight Rating or less which has a vehicular curb weight of six thousand (6,000) pounds or less and which has a basic vehicle frontal area of forty-five (45) square feet or less, which is:
1) Designed primarily for purposes of transportation of property or is a derivation of such a vehicle, or
2) Designed primarily for transportation of persons and has a capacity of more than twelve (12) persons; or
3) Available with special features enabling off-street or off-highway operation and use. "Lowest floor" means the lowest floor of the lowest enclosed area, including basement, but excluding any unfinished or flood-resistant enclosure, usable solely for vehicle parking, building access or limited storage provided that such enclosure is not built so as to render the structure in violation of the non-elevation requirements of the building codes. [Also defined in CCR Title 24 Part 2.]
"Manufactured home" means a structure that is transportable in one or more sections, built on a permanent chassis, designed for use as a single-family dwelling with or without a permanent foundation when connected to the required utilities, and constructed to the Manufactured Home Construction and Safety Standards promulgated by the U.S.

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Department of Housing and Urban Development. Also see definitions in Health and Safety Code Sections 18000(a)(2) and 18001(a). For the purposes of floodplain management, the term also includes mobile homes and recreational vehicles, park trailers, travel trailers and similar transportable structures that are placed on a site for one hundred eighty (180) consecutive days or longer.
"Manufactured home park or subdivision" means a parcel (or contiguous parcels) of land divided into two or more manufactured home lots for rent or sale. "Market value" means the price at which a property will change hands between a willing buyer and a willing seller, neither party being under compulsion to buy or sell and both having reasonable knowledge of relevant facts. As used in these regulations, the term refers to the market value of buildings and structures, excluding the land and other improvements on the parcel. Market value may be established by one of the following methods: (1) Actual Cash Value (replacement cost depreciated for age and quality of construction), (2) tax assessment value adjusted to approximate market value by a factor provided by the property appraiser, or (3) a qualified independent appraiser.
"New manufactured home park or subdivision" means a manufactured home park or subdivision for which the construction of facilities for servicing the lots on which the manufactured homes are to be affixed (including at a minimum, the installation of utilities, the construction of streets, and either final site grading or the pouring of concrete pads) was completed on or after July 24, 1980.
"Nuisance" means that which is injurious to safety or health of an entire community or neighborhood, or any considerable number of persons, or unlawfully obstructs the free passage or use, in the customary manner, of any navigable lake, or river, bay, stream, canal, or basin.
"Permit for floodplain development" means an official document or certificate issued by the community, or other evidence of approval or concurrence, which authorizes performance of specified development activities that are located in flood hazard areas and that are determined to be compliant with these Regulations.
"Recreational vehicle" means a vehicle that is built on a single chassis, 400 square feet (37.16 m2 ) or less when measured at the largest horizontal projection, designed to be selfpropelled or permanently towable by a light-duty truck, and designed primarily not for use as a permanent dwelling but as temporary living quarters for recreational, camping, travel or seasonal use. A recreational vehicle is ready for highway use when it is on its wheels or jacking system, is attached to the site only by quick disconnect type utilities and security

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devices and has no permanently attached additions. Also see definitions in Health and Safety Code section 18010.
"Riverine" means relating to, formed by, or resembling a river (including tributaries), stream, brook, etc.
"Special flood hazard area (SFHA)" means the land area subject to flood hazards and shown on a Flood Insurance Rate Map or other flood hazard map as Zone A, AE, A1-30, A99, AR, AO, AH, V, VO, VE, or V1-30. [Also defined in CCR Title 24 Part 2.] "Substantial damage" means damage of any origin sustained by a structure whereby the cost of restoring the structure to its before-damaged condition would equal or exceed fifty (50) percent of the market value of the structure before the damage occurred. [Also defined in CCR Title 24 Part 2.]
"Substantial improvement" means any repair, reconstruction, rehabilitation, alteration, addition or other improvement of a building or structure, the cost of which equals or exceeds fifty (50) percent of the market value of the structure before the improvement or repair is started. When the structure has sustained substantial damage, any repairs are considered substantial improvement regardless of the actual repair work performed. The term does not, however, include either: [Also defined in CCR Title 24 Part 2.] 1) Any project for improvement of a building required to correct existing health, sanitary or safety code violations identified by the building official and that are the minimum necessary to assure safe living conditions.
2) Any alteration of a historic structure provided that the alteration will not preclude the structure's continued designation as a historic structure. "Utility and miscellaneous Group U" means buildings and structures of an accessory character and miscellaneous structure not classified in any special occupancy, as described in the building code.
"Variance" means a grant of relief from the requirements of these Regulations which permits construction in a manner otherwise prohibited and where specific enforcement would result in exceptional hardship.
"Violation" means a development that is not fully compliant with these regulations or the flood provisions of the building code, as applicable.
"Watercourse" means a river, creek, stream, channel or other topographic feature in, on, through, or over which water flows at least periodically.

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Article 10. Buildings and Structures

12.40.480 Requirements for buildings and structures in flood hazard areas.

Applications for building and structures within the scope of the building code that are proposed in flood hazard areas shall comply with the applicable requirements of the building code and local amendments to the building code specified in Title 12 Buildings and Construction.

12.40.490 Detached garages and accessory storage structures.

Detached garages and accessory storage structures used only for parking or storage (and cannot be attached to any structure used for human habitation or converted to a use for human habitation) are permitted below the base flood elevation provided the garages and accessory storage structures:

A. Are one story and not larger than four hundred (400) square feet in area when located in special flood hazard areas.

B. Are anchored to resist flotation, collapse or lateral movement resulting from flood loads.

C. Have flood openings in accordance with the building code.

D. Have flood damage-resistant materials used below the base flood elevation.

E. Have mechanical, plumbing and electrical systems, including plumbing fixtures, elevated to or above the base flood elevation.

12.40.500 Utility and Miscellaneous Group U.

Utility and miscellaneous Group U includes buildings that are accessory in character and miscellaneous structures not classified in any specific occupancy in the building code, including, but not limited to, agricultural buildings, aircraft hangars (accessory to a one- or two-family residence), barns, carports, fences more than six feet (1829 mm) high, grain silos (accessory to a residential occupancy), greenhouses, livestock shelters, private garages, retaining walls, sheds, stables, and towers. In addition to the building code requirements for fire and life safety, the following shall apply to utility and miscellaneous Group U buildings and structures in flood hazard areas:

A. New construction and substantial improvement of such buildings and structures shall be anchored to prevent flotation, collapse or lateral movement resulting from flood loads, including the effects of buoyancy, during conditions of the design flood.

B. New construction and substantial improvement of such buildings and structures, when fully enclosed by walls, shall be elevated such that the lowest floor, including

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basement, is elevated to or above the design flood elevation in accordance with ASCE 24 or shall be dry floodproofed in accordance with ASCE 24.

C. Unless dry floodproofed, fully enclosed areas below the design flood elevation shall be constructed in accordance with ASCE 24 and limited to parking, storage, and building access.

D. When fully enclosed by walls, flood openings shall be installed in accordance with ASCE 24.

E. Flood damage-resistant materials shall be used below the design flood elevation.

F. Mechanical, plumbing and electrical systems, including plumbing fixtures, shall be located or installed in accordance with ASCE 24.

Article 11. Subdivisions

12.40.510 Minimum requirements.

Subdivision proposals in flood hazard areas, including proposals for manufactured home parks and subdivisions, shall be reviewed to determine that:

A. Such proposals are consistent with the need to minimize flood damage and will be reasonably safe from flooding.

B. All public utilities and facilities, such as sewer, gas, electric, communications, and water systems are located and constructed to minimize or eliminate flood damage in accordance with Section 12.40.540 and Section 12.40.550 of these regulations, as applicable, and appropriate codes.

C. Adequate drainage is provided to reduce exposure to flood hazards; in Zones AH and AO, adequate drainage paths shall be provided to guide floodwater around and away from proposed structures.

12.40.520 Subdivision requirements.

In addition to the requirements of Section 302-1 of these regulations, where any portion of proposed subdivisions, including proposals for manufactured home parks and subdivisions, lies within a flood hazard area, the following shall be required:

A. The flood hazard area, including floodways, as appropriate, shall be delineated on preliminary subdivision plats.

B. Where the subdivision has more than fifty (50) lots or is larger than five acres and base flood elevations are not included on the FIRM, the base flood elevations determined in accordance with Section 12.40.270.A of these regulations.

C. When, as part of a proposed subdivision, fill will be placed to support buildings, the fill shall be placed in accordance with the building code and approval of the

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subdivision shall require submission of as-built elevations for each filled pad certified by a licensed land surveyor or registered civil engineer.

Article 12. Site Improvements, Utilities and Limitations

12.40.530 Minimum requirements.

All proposed development in flood hazard areas shall be reviewed to determine that:

A. Such proposals are consistent with the need to minimize flood damage and will be reasonably safe from flooding.

B. Where the proposed development has more than fifty (50) lots or is larger than five acres and base flood elevations are not included on the FIRM, the base flood elevations determined in accordance with Section 12.40.270.A of these regulations.

C. All public utilities and facilities, such as sewer, gas, electric, communications, and water systems are located and constructed to minimize or eliminate flood damage.

D. Adequate drainage is provided to reduce exposure to flood hazards; in Zones AH and AO, adequate drainage paths shall be provided to guide floodwater around and away from proposed structures.

12.40.540 Sanitary sewer facilities.

All new and replaced sanitary sewer facilities, private sewage treatment plants (including all pumping stations and collector systems) and on-site waste disposal systems shall be designed in accordance with Chapter 7, ASCE 24, to minimize or eliminate infiltration of floodwaters into the facilities and discharge from the facilities into flood waters, and impairment of the facilities and systems.

12.40.550 Water supply facilities.

All new and replaced water supply facilities shall be designed in accordance with the provisions of Chapter 7, ASCE 24, to minimize or eliminate infiltration of floodwaters into the systems.

12.40.560 Development in floodways.

Development, site improvements and land disturbing activity involving fill or regrading shall not be authorized in the floodway unless the floodway encroachment analysis required in Section 12.40.280.A of these regulations demonstrates the proposed work will not result in any increase in the base flood level during occurrence of the base flood discharge.

12.40.570 Limitations on placement of fill.

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Subject to the limitations of these Regulations, fill shall be designed to be stable under conditions of flooding including rapid rise and rapid drawdown of floodwaters, prolonged inundation, and protection against flood-related erosion and scour. In addition to these requirements, when intended to support buildings and structures, fill shall comply with the requirements of the building code. The placement of fill intended to change base flood elevations, change floodway boundaries, or change boundaries of flood hazard areas shown on FIRMs shall be subject to the requirements of Section 12.40.290 of these regulations.

Article 13. Installation of Manufactured Homes

12.40.580 Installation.

All manufactured homes installed in flood hazard areas shall be installed by an installer that is licensed pursuant to the Business and Professions Code and shall comply with the requirements of the Department of Housing and Community Development (HCD) and the requirements of these regulations. In addition to permits pursuant to these regulations, permits from the HCD are required where the HCD is the enforcement agency for installation of manufactured homes. Upon completion of installation and prior to the final inspection by the floodplain administrator, the installer shall submit certification of the elevation of the manufactured home, prepared by a licensed land surveyor or registered civil engineer, to the floodplain administrator.

12.40.590 Foundations.

All new and replacement manufactured homes, including substantial improvement of manufactured homes installed in flood hazard areas shall be installed on permanent, reinforced foundations that are designed in accordance with the foundation requirements of Section R322.2 of the residential code (CCR Title 24 Part 2.5) and these regulations.

Foundations for manufactured homes subject to Section 12.40.620 of these regulations are permitted to be reinforced piers or other foundation elements of at least equivalent strength.

12.40.600 Anchoring.

All new and replacement manufactured homes to be placed or substantially improved in a flood hazard area shall be installed using methods and practices which minimize flood damage and shall be securely anchored to an adequately anchored foundation system to resist flotation, collapse and lateral movement. Methods of anchoring are authorized to include, but are not limited to, use of over-the-top or frame ties to ground anchors. This requirement is in addition to applicable State and local anchoring requirements for resisting wind loads and seismic loads.

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12.40.610 General elevation requirement.

Unless subject to the requirements of Section 12.40.620 of these regulations, all manufactured homes that are placed, replaced, or substantially improved on sites located:
(a) outside of a manufactured home park or subdivision; (b) in a new manufactured home park or subdivision; (c) in an expansion to an existing manufactured home park or subdivision; or (d) in an existing manufactured home park or subdivision upon which a manufactured home has incurred "substantial damage" as the result of a flood, shall be elevated such that the lowest floor, or bottom of the lowest horizontal member of the lowest floor, as applicable to the flood hazard area, is at or above the base flood elevation.

12.40.620 Elevation requirement for certain existing manufactured home parks and subdivisions.

Manufactured homes that are not subject to Section 12.40.610 of these regulations, including manufactured homes that are placed, replaced, or substantially improved on sites located in an existing manufactured home park or subdivision, unless on a site where substantial damage as a result of flooding has occurred, shall be elevated such that either the:

A. Lowest floor, or bottom of the lowest horizontal structural member, as applicable to the flood hazard area, is at or above the base flood elevation.

B. Bottom of the frame is supported by reinforced piers or other foundation elements of at least equivalent strength that are not less than thirty-six (36) inches in height above grade.

12.40.630 Flood damage-resistant materials.

Materials below elevated manufactured homes shall comply with the flood-damage resistant materials requirements of Section R322 of the residential code (CCR Title 24 Part

2.5).

12.40.640 Enclosures.

Fully enclosed areas below elevated manufactured homes shall comply with the enclosed area requirements of Section R322 of the residential code (CCR Title 24 Part 2.5).

12.40.650 Protection of mechanical equipment and outside appliances.

Mechanical equipment and outside appliances shall be elevated to or above the lowest floor or bottom of the lowest horizontal structural member of the manufactured home, as applicable to the flood hazard area.

APPENDIX 18
Exception. Where such equipment and appliances are designed and installed to prevent water from entering or accumulating within their components and the systems are constructed to resist hydrostatic and hydrodynamic loads and stresses, including the effects of buoyancy, during the occurrence of flooding up to the elevation required by Section 12.40.610 or Section 12.40.620, as applicable, the systems and equipment shall be permitted to be located below that elevation. Electrical wiring systems shall be permitted below the design flood elevation provided they conform to the provisions of NFPA 70 (National Electric Code).

Article 14. Recreational Vehicles

12.40.660 Temporary placement.

Recreational vehicles in flood hazard areas, shall be placed on a site for less than one hundred eighty (180) consecutive days or shall be fully licensed and ready for highway use.

Ready for highway use means the recreational vehicle is on wheels or jacking system, is attached to the site only by quick disconnect type utilities and security devices, and has no permanently attached additions, such as rooms, stairs, decks and porches.

12.40.670 Permanent placement.

Recreational vehicles that do not meet the limitations in Section 12.40.660 for temporary placement shall meet the requirements of Article 14 for manufactured homes.

Article 15. Other Development

12.40.680 General requirements for other development.

All development, including man-made changes to improved or unimproved real estate for which specific provisions are not specified in these regulations or the building code, shall:

A. Be located and constructed to minimize flood damage.

B. Meet the limitations of Section 12.40.560 of these regulations when located in a regulated floodway.

C. Be anchored to prevent flotation, collapse or lateral movement resulting from hydrostatic loads, including the effects of buoyancy, during conditions of the design flood.

D. Be constructed of flood damage-resistant materials.

E. Have mechanical, plumbing, and electrical systems above the design flood elevation or meet the requirements of ASCE 24, except that minimum electric service required to address life safety and electric code requirements is permitted below the design flood elevation provided it conforms to the provisions of the electrical part of the building code for wet locations.

APPENDIX 18

12.40.690 Tanks.

Tanks that serve buildings shall comply with the requirements of the building code.

Underground and above-ground tanks that serve other purposes shall be designed, constructed, installed and anchored in accordance with ASCE 24.

12.40.700 Requirements for temporary structures and temporary storage in flood hazard areas.

Temporary structures shall be erected for a period of less than one hundred eighty (180) days and temporary storage of goods and materials shall be permitted for a period of less than one hundred eighty (180) days. Extensions may be granted in accordance with Section

12.40.230 of these regulations. In addition, the following apply:

A. Temporary structures shall be anchored to prevent flotation, collapse or lateral movement resulting from hydrostatic loads, including the effects of buoyancy, during conditions of the design flood. Fully enclosed temporary structures shall have flood openings that are in accordance with ASCE 24 to allow for the automatic entry and exit of flood waters.

B. Temporary stored materials shall not include hazardous materials.

C. The requirements of Section 12.40.560 of these regulations, when located in floodways.

12.40.710 Fences in floodways.

Fences in floodways that have the potential to block the passage of floodwaters, such as stockade fences and wire mesh fences, shall meet the limitations of Section 12.40.560 of these regulations.

12.40.720 Oil derricks.

Oil derricks located in flood hazard areas shall be designed in conformance with flood loads required by the building code.

12.40.720 Retaining walls, sidewalks and driveways in floodways.

Retaining walls and sidewalks and driveways that involve placement of fill in floodways shall meet the limitations of Section 12.40.560 of these regulations and the requirements for site grading in Chapter 18 of the building code.

12.40.730 Roads and watercourse crossings in floodways.

Roads and watercourse crossings that encroach into floodways or riverine waterways with base flood elevations where floodways have not been designated, including roads, bridges,

APPENDIX 18
culverts, low-water crossings and similar means for vehicles or pedestrians to travel from one side of a watercourse to the other side shall meet the limitations of Section 12.40.560 of these regulations. Alteration of a watercourse that is part of work proposed for a road or watercourse crossing shall meet the requirements of Section 12.640.280.C of these regulations.

12.40.740 Swimming pools.

Above-ground swimming pools, on-ground swimming pools, and in-ground swimming pools that involve placement of fill in floodways shall meet the requirement of Section 12.40.560 of these regulations.

Article 16. Flood Control Projects

12.40.750 Flood control projects; general.

In addition to applicable Federal, State and other local permits, a permit for floodplain development is required for construction of flood control projects. The purpose for the permit is to examine the impact on flood hazard areas, floodways, and base flood elevations shown on the FIRM. Unless otherwise authorized by separate regulations, issuance of this permit does not address the sufficiency of the structural elements of the proposed flood control project. Permits for floodplain development and building permits in areas affected by proposed flood control projects shall not be issued based on conditional letters of map revision issued by FEMA.

12.40.760 Flood control projects; applications.

Applications for permits for flood control projects shall include documentation including but not limited to:

A. Site plan or document showing the existing topography and the boundaries of the flood hazard areas, floodway boundaries, and base flood elevations shown on the FIRM.

B. Site plan or document showing the proposed topography and the proposed changes to the boundaries of the flood hazard areas, floodway boundaries, and base flood elevations.

C. The documentation submitted to FEMA for a conditional letter of map revision (CLOMR) and, if issued, the conditional letter of map revision. Submittal requirements and processing fees shall be the responsibility of the applicant. A CLOMR is required when a proposed flood control project alters a floodway and increases base flood elevations more than greater than 0.00 feet, or alters a watercourse a riverine flood hazard area for which base flood elevations are included

APPENDIX 18
in the flood insurance study or on the FIRM and floodways have not been designated and increases base flood elevations more than 1.0 foot.

Summary of Compliance Requirements
Table 1. Summary of Requirements if Using a Heat Pump
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
Table 2. Summary of Requirements if Using a Furnace
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)
• Attic Insulation (R-49)
• Air sealing
• R-8 Duct insulation
• Refrigerant charge verification
• Fan efficacy (0.35 watts/CFM)

2025 CostEffectiveness Study:

Single Family AC to Heat
Pump Replacement
Prepared by:

Ada Shen, Alea German, Keith
Saechao, & Marc Hoeschele,
Frontier Energy, Inc
Misti Bruceri, Misti Bruceri &
Associates, LLC
Prepared for:

Kelly Cunningham, Codes and
Standards Program, Pacific Gas
and Electric
Revision: 1.0
Last modified: 2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 1 Legal Notice
This report was prepared by
Pacific Gas and Electric Company
and funded by the California utility
customers under the auspices of
the California Public Utilities
Commission.

Copyright 2025, Pacific Gas and
Electric Company. All rights
reserved, except that this
document may be used, copied,
and distributed without
modification.

Neither PG&E nor any of its
employees makes any warranty,
express or implied; or assumes
any legal liability or responsibility
for the accuracy, completeness or
usefulness of any data,
information, method, product,
policy or process disclosed in this
document; or represents that its
use will not infringe any privatelyowned rights including, but not limited to, patents, trademarks or
copyrights.

Table 1. Summary of Revisions
Date Description Reference (page or section)
6/09/2025 Original Release N/A
2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 2 Acronym List
AC – Air conditioner
ACH50 – Air Changes per
Hour at 50 pascals pressure
differential
AFUE – Annual Fuel
Utilization Efficiency
B/C – Lifecycle Benefit-toCost Ratio
BSC – Building Standards
Commission
CA IOUs – California
Investor-Owned Utilities
CARE – California Alternate
Rates for Energy
CASE – Codes and
Standards Enhancement
CBECC-Res – Computer
program developed by the
California Energy
Commission for
demonstrating compliance
with the California
Residential Building Energy
Efficiency Standards
CFM – Cubic Feet per
Minute
CO2 – Carbon Dioxide
CPAU – City of Palo Alto
Utilities
CPUC – California Public
Utilities Commission
CZ – California Climate
Zone
DFHP – Dual Fuel Heat
Pump
DHW – Domestic Hot Water
DOE – Department of
Energy
EDR – Energy Design
Rating
EER – Energy Efficiency
Ratio
EF – Energy Factor
GHG – Greenhouse Gas
HPWH – Heat Pump Water
Heater
HSPF – Heating Seasonal
Performance Factor
HVAC – Heating,
Ventilation, and Air
Conditioning
IOU – Investor Owned
Utility
kBtu – kilo-British thermal
unit
kWh – Kilowatt Hour
LCC – Lifecycle Cost
LLAHU – Low Leakage Air
Handler Unit
VLLDCS – Verified Low
Leakage Ducts in
Conditioned Space
NEEA – Northwest Energy
Efficiency Alliance
NEM – Net Energy Metering
NPV – Net Present Value
PG&E – Pacific Gas and
Electric Company
PV – Photovoltaic
SCE – Southern California
Edison
SDG&E – San Diego Gas
and Electric
SEER – Seasonal Energy
Efficiency Ratio
SF – Single Family
SMUD – Sacramento
Municipal Utility District
SoCalGas – Southern
California Gas Company
TDV – Time Dependent
Valuation
Therm – Unit for quantity of
heat that equals 100,000
British thermal units
Title 24 – Title 24, Part 6
TOU – Time-Of-Use
UEF – Uniform Energy
Factor
2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 1 Table of Contents
Executive Summary............................................................................................................4 1 Introduction..................................................................................................................7 2 Methodology and Assumptions ..................................................................................9

2.1 Modeling............................................................................................................... 9

2.2 Prototype Characteristics.....................................................................................10

2.3 Cost-Effectiveness Approach..............................................................................13

2.3.1 Benefits ...........................................................................................................13

2.3.2 Costs ...............................................................................................................13

2.3.3 Metrics.............................................................................................................15

2.3.4 Utility Rates .....................................................................................................16

2.4 Measure Details and Cost....................................................................................18

2.4.1 Lifecycle Cost Assuming Zero-NOx Standards for Space Heating After 2030 ..20 3 Results........................................................................................................................22

3.1 Cost-Effectiveness Results ..................................................................................22

3.1.1 Cost Effectiveness Results Using Standard Tariffs...........................................23

3.1.2 Cost Effectiveness Results Using CARE Tariffs ...............................................26

3.2 Zero-NOx Scenario Results.................................................................................28

3.3 AC Pathways for Heat Pump Replacements........................................................30 4 Recommendations and Discussion..........................................................................33 5 References .................................................................................................................36 6 Appendices ................................................................................................................38

6.1 Map of California Climate Zones..........................................................................38

6.2 Cost-Effectiveness Results ..................................................................................39

6.2.1 Standard Rates................................................................................................39

6.2.2 CARE tariffs.....................................................................................................45

6.3 Utility Rate Schedules..........................................................................................51

6.3.1 Pacific Gas & Electric.......................................................................................51

6.3.2 Southern California Edison ..............................................................................60

6.3.3 Southern California Gas...................................................................................64

6.3.4 San Diego Gas & Electric ................................................................................65 2025/06/09
Attachment 1

10 20
30 40
50 Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 2

6.3.5 City of Palo Alto Utilities ...................................................................................72

6.3.6 Sacramento Municipal Utilities District (Electric Only) ......................................74

6.3.7 Fuel Escalation Assumptions ...........................................................................76 List of Tables
Table 1. Summary of Revisions............................................................................................ 1 Table 2. Residential Prototype Characteristics ....................................................................

Table 9. HVAC Measure Cost Assumptions – 4-Ton Electric Replacements........................

Table 11. Lifecycle Incremental Cost Breakdown for 4-Ton System with no Gas Furnaces Table 19. DFHP Existing Furnace LSC Savings (Zero-NOx Rule).......................................

Table 23. [Pre-1978] Standard Efficiency HPSH..................................................................

Table 33. [1978-1991] High Efficiency HPSH CARE............................................................

Table 3. Efficiency Characteristics for Three Vintage Cases................................................12 Table 4. System Sizing by Climate Zone .............................................................................15 Table 5. Investor-Owned Utility Tariffs Used Based on Climate Zone ..................................16 Table 6. Publicly Owned Utility Tariffs Used Based on Climate Zone...................................17 Table 7. Lifecycle Incremental Cost Breakdown for a 4-Ton DFHP Existing Furnace...........19 Table 8. Lifecycle Incremental Cost Breakdown for 4-Ton HPSH ........................................19 Table 10. SCAQMD Rule 1111 Proposed Manufacturer Compliance Targets.......................20 after 2030............................................................................................................................21 Table 12. [1992-2010] DFHP Existing Furnace....................................................................23 Table 13. [1992-2010] Standard Efficiency HPSH ...............................................................24 Table 14. [1992-2010] High Efficiency HPSH ......................................................................25 Table 15. [1992-2010] DFHP Existing Furnace CARE.........................................................26 Table 16. [1992-2010] Standard Efficiency HPSH CARE ....................................................27 Table 17. [1992-2010] High Efficiency HPSH CARE............................................................28 Table 18. DFHP Existing Furnace On-Bill NPV (Zero-NOx Rule).........................................29 Table 20. New AC Only Path Cost Estimates ......................................................................32 Table 21. New AC/Furnace and New Ducts Path Cost Estimates........................................32 Table 22. [Pre-1978] DFHP Existing Furnace......................................................................39 Table 24. [Pre-1978] High Efficiency HPSH.........................................................................41 Table 25. [1978-1991] DFHP Existing Furnace....................................................................42 Table 26. [1978-1991] Standard Efficiency HPSH ...............................................................43 Table 27. [1978-1991] High Efficiency HPSH ......................................................................44 Table 28. [Pre-1978] DFHP Existing Furnace CARE ...........................................................45 Table 29. [Pre-1978] Standard Efficiency HPSH CARE.......................................................46 Table 30. [Pre-1978] High Efficiency HPSH CARE..............................................................47 Table 31. [1978-1991] DFHP Existing Furnace CARE.........................................................48 Table 32. [1978-1991] Standard Efficiency HPSH CARE ....................................................49 Table 34. PG&E Baseline Territory by Climate Zone............................................................51 Table 35. PG&E Monthly Gas Rate ($/therm)......................................................................52 2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 3 Table 36. SCE Baseline Territory by Climate Zone ..............................................................60 Table 37. SoCalGas Baseline Territory by Climate Zone .....................................................64 Table 38. SoCalGas Monthly Gas Rate ($/therm)................................................................65 Table 39. SDG&E Baseline Territory by Climate Zone.........................................................65 Table 40. SDG&E Monthly Gas Rate ($/therm) ...................................................................66 Table 41. CPAU Monthly Gas Rate ($/therm) ......................................................................72 Table 42. Real Utility Rate Escalation Rate Assumptions, CPUC En Banc and 2022 TDV Basis...................................................................................................................................77 Table 43. Real Utility Rate Escalation Rate Assumptions, 2025 LSC Basis.........................78 List of Figures
Figure 1. AC vs. Heat Pump Pathway Requirements ..........................................................31 Figure 2. AC vs. Heat Pump Energy Comparison................................................................31 Figure 3. Map of California climate zones. ..........................................................................38 2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 4 Executive Summary
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.

It is important to note that there is a voluntary measure in the 2025 CALGreen for replacing an air conditioner with a heat pump at time of air conditioner replacement, which can be adopted as is. This report seeks to provide options to modify the heat pump measure, and demonstrate the cost-effectiveness of these options.

This analysis used two different metrics to assess the cost-effectiveness of the proposed upgrades for a 1,665 square foot single family home prototype with an attached garage.

Both methodologies require estimating and quantifying the incremental costs and energy savings associated with each energy efficiency measure over a 30-year analysis period. OnBill cost-effectiveness is an occupant-based lifecycle cost (LCC) approach that values energy based upon estimated site energy usage and customer utility bill savings using today’s electricity and natural gas utility tariffs. To reflect how natural gas prices fluctuate with seasonal supply and demand, a normalized curve was used to estimate the cost for the remaining months relative to today’s rates. Long-term Systemwide Cost (LSC) is the California Energy Commission’s metric for determining cost-effectiveness of efficiency measures in the 2025 Energy Code. This metric is intended to capture the long-term projected cost of energy including costs for providing energy during peak periods of demand, carbon emissions, grid transmission and distribution impacts.

Local jurisdictions may adopt ordinances that amend different parts of the California Building Standards Code or may elect to amend other state or municipal codes. The decision regarding which code to amend will determine the specific requirements that must be followed for an ordinance to be legally enforceable. For example, reach codes that amend Part 6 of the California Building Code (the Energy Code) and require energy performance beyond state code minimums must demonstrate the proposed changes are cost-effective and obtain approval from the Energy Commission as well as the Building Standards Commission (BSC). Amendments to Part 11, such as requirements for increased water efficiency or electric vehicle infrastructure only require BSC approval and do not require the Energy Commission approval. Although a cost-effectiveness study is only required to amend Part 6 of the California Building Code, this study provides valuable context for jurisdictions pursuing other ordinance paths to understand the economic impacts of the policy decision.

This study documents the estimated costs, benefits, energy impacts and greenhouse gas emission reductions that may result from implementing an ordinance based on the results to help residents, local leadership, and other stakeholders make informed policy decisions. 2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 5 The following summarizes key results:

1. Heat pumps are significantly more efficient than gas furnaces, requiring less than half the energy to meet the heating load. However, despite this reduction in heating energy use, the cost of heating a home using electricity (heat pump) could be higher than the cost to heat that same home with natural gas (furnace), depending on the electricity tariffs relative to the gas tariffs. Therefore, while a heat pump measure could be deemed as cost-effective over its lifecycle, installing a heat pump could result in a decrease or an increase in utility costs in the first years relative to a gas furnace and AC system.

2. The study assumes utility rates escalate over time. Because it is very difficult to predict how the rates will change, the analysis presents two escalation scenarios (modest and high gas escalation) to represent a range of outcomes.

3. The LSC metric most often produces more favorable cost-effectiveness results relative to the results produced using actual utility costs (On-Bill). When the analysis assumes a higher escalation rate for natural gas costs relative to electricity in future years (high gas escalation), the On-Bill results are more favorable in some cases. a. In the oldest (pre-1978) vintage, all three measures (dual fuel heat pump with existing furnace, standard heat pump space heater, and high efficiency heat pump space heater) are cost-effective using the LSC metric in all climate zones. When using the On-Bill metric, the measures remain cost-effective in most climate zones.
b. In the newer (1978-1991 and 1992-2010) vintages, the dual fuel heat pump (DFHP Existing Furnace) and the standard efficiency HPSH are cost-effective based on LSC in all cases except for Climate Zone 15 when using both the standard and California Alternate Rates for Energy (CARE) tariff.

4. Using the CARE tariff results in higher cost savings and cost-effectiveness relative to standard rates, with almost all cases yielding first year utility cost savings. The DFHP Existing Furnace is On-Bill cost-effective based on the high gas escalation scenario in all cases in the pre-1978 vintage, and almost all cases in the 1978-1991 and 1992-2010 vintage. It is also On-Bill cost-effective in most climate zones for the modest gas escalation scenario across all vintages. In Climate Zones 5, 8, 9, 10, 14, and 15, cost-effectiveness declines relative to other areas, and in some cases is not cost-effective from an On-Bill perspective. This is the case for both the CARE tariff and the standard rate.

5. The analysis also modeled the cost impact of using a standard time-of-use electricity tariff versus switching to a newer electrification tariff, designed to reduce costs in homes with heat pumps and/or electric vehicles. Older homes tend to be the least efficient and achieve the most savings from improving equipment efficiency. In most of the state, because older homes tend to use more electricity than a similarly sized, newer vintage home, they realize more costs savings under the electrification tariff.

Newer homes tend to use less electricity and therefore do not realize the same cost 2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 6 savings from switching tariffs; they generally perform better under the standard tariff.

This trend is different in milder climate zones in SCE territory (excluding CZ 15), where newer homes realize more cost savings. Both the standard and electrification tariffs in SCE territory include a daily allocation of lower-cost baseline electricity and a second, higher-priced tier when the baseline is exceeded. In many newer homes, a higher percentage of overall electricity use is within the baseline allocation, resulting in greater cost savings.

6. Higher efficiency equipment reduces utility costs in all cases and improves costeffectiveness in many climate zones in the oldest vintage relative to standard efficiency equipment. However, in more efficient newer homes, where costeffectiveness is generally lower, the savings are insufficient to offset the roughly $3,000 increase in incremental cost.

7. Given the adopted Bay Area Air Quality Management District (BAAD) Zero NOx rule, and the proposed California Air Resource Board or South Coast Air Quality Management District (SCAQMD) Zero-NOx rules, and gas furnaces are no longer available or less available to be installed in 2030, a sensitivity analysis was performed for the Zero NOx scenario and found that cost-effectiveness declines in many cases except in Climate Zones 8-10, some results improve enough to become cost-effective. The improved cost-effectiveness in Climate Zones 8-10 is due to the higher baseline cost when a HPSH must be installed at year 10 when the furnace must be replaced. However, the overall magnitude of 30-year On-Bill costeffectiveness is lower because there are only 10 years of utility cost savings. After year 10 the base case and upgrade measures are both heat pumps.

This report documents the key results and conclusions from the Reach Codes Team analysis. A full dataset of all results can be downloaded at https://localenergycodes.com/content/resources. Results alongside policy options can also be explored using the Cost-effectiveness Explorer at https://explorer.localenergycodes.com/.

Model ordinance language and other resources are posted on the C&S Reach Codes Program website at LocalEnergyCodes.com. Local jurisdictions that are considering adopting an ordinance may contact the program for further technical support at [email protected].
2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 7 1 Introduction
The California Codes and Standards Reach Codes program, also known as the Local Energy Codes program, provides technical support to local governments considering adopting a local ordinance 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.

Local jurisdictions may adopt ordinances that amend different parts of the California Building Standards Code or may elect to amend other state or municipal codes. The decision regarding which code to amend will determine the specific requirements that must be followed for an ordinance to be legally enforceable. For example, reach codes that amend Part 6 of the California Building Code (the Energy Code) (CEC, 2025) and require energy performance beyond state code minimums must demonstrate the proposed changes are cost-effective and obtain approval from the Energy Commission as well as the Building Standards Commission (BSC). Amendments to Part 11, such as requirements for increased water efficiency or electric vehicle infrastructure only require BSC approval and do not require the Energy Commission approval. Although a cost-effectiveness study is only required to amend Part 6 of the California Building Code, this study provides valuable context for jurisdictions pursuing other ordinance paths to understand the economic impacts of the policy decision. This study documents the estimated costs, benefits, energy impacts and greenhouse gas emission reductions that may result from implementing an ordinance based on the results to help residents, local leadership, and other stakeholders make informed policy decisions.

This report is an update to the 2022 Single Family Retrofit Cost-effectiveness Study (Statewide Reach Codes Team, 2024) focused on an ordinance structure that encourages air conditioner (AC) to heat pump replacement. The methodology, prototype characteristics, and relevant measure packages are retained from the main study referenced above. The study includes updated utility rates, revised costs based on the TECH Clean California1 incremental cost study data, estimated costs for the AC path, updated and expanded AC path options, and a new cost-effectiveness scenario that considers upcoming proposed zero-NOx emission regulations (SCAQMD, 2025) (California Air Resources Board, 2022) (BAAD, 2025).

Local jurisdictions in California may consider adopting local energy ordinances to achieve energy savings beyond what will be accomplished by enforcing building efficiency requirements that apply statewide.

Local jurisdictions may also adopt ordinances that amend different parts of the California Building Standards Code or may elect to amend other state or municipal codes. The 1 https://techcleanca.com/
2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 8 decision regarding which code to amend will determine the specific requirements that must be followed for an ordinance to be legally enforceable. Although a cost-effectiveness study is only required to amend Part 6 of the CA Building Code, it is important to understand the economic impacts of any policy decision. This study documents the estimated costs, benefits, energy impacts and greenhouse gas emission reductions that may result from implementing an ordinance based on the results to help local leadership, residents, and other stakeholders make informed policy decisions.

This report was developed in coordination with the California Statewide Investor-Owned Utilities (IOUs) Codes and Standards Program, the California Energy Commission (CEC), key consultants, and engaged cities—collectively known as the Statewide Reach Codes Team. Model ordinance language and other resources are posted on the C&S Reach Codes Program website at LocalEnergyCodes.com. Local jurisdictions that are considering adopting an ordinance may contact the program for further technical support at [email protected].
2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 9 2 Methodology and Assumptions
This study evaluates a potential reach code that encourages a heat pump or dual fuel system that includes a heat pump combined with a furnace when an air conditioner is replaced or installed new in existing single family homes. The ordinance structure and this analysis 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 proposed reach code also defines pathways for air conditioning equipment to be installed combined with additional efficiency measures. 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 to allow for the furnace to provide backup heating. In alignment with the 2025 Energy Code requirements the heat pump must be sized to satisfy the heating load at the design heating temperature without the use of backup heat.

All methodology and assumptions are consistent with prior statewide analysis (Statewide Reach Codes Team, 2024) with the following exceptions:

1. Updated utility rates to January 2025

2. Equipment costs based on TECH data where available; the original report was based on Statewide contractor survey costs

3. Cost estimates were obtained for the AC path

4. Expanded AC path options

5. Cost-effectiveness results for the scenario if gas furnaces are no longer available for sale in California in 2030

2.1 Modeling
The Reach Codes Team performed energy simulations using the 2025 research version of the Residential California Building Energy Code Compliance software (CBECC). The 2025 version of CBECC includes updated weather files, metrics, and the weather stations were changed in Climate Zones 4 and 6 from San Jose to Paso Robles and Torrance to Los Angeles International Airport, respectively. Note that at the time of this report, the Energy Commission was working on integrating a new heat pump model into the CBECC-Res software to better reflect the actual energy use of heat pumps. The updated model results in lower heating energy use than is currently estimated. Once the revised software is released, the reach codes team plans to update this analysis.

Three unique building vintages are included: pre-1978, 1978-1991, and 1992-2010. The vintages were defined based on review of historic building code requirements and defining periods with distinguishing features. The proposed measures were modeled to determine the projected site energy (therm and kWh), source energy, GHG emissions, and long-term systemwide cost (LSC) impacts. Annual utility costs were calculated using hourly data 2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 10 output from CBECC, and updated (as of 1/1/2025) electricity and natural gas tariffs for each of the investor-owned utilities (IOUs) as appropriate for that climate zone.

Site energy results are similar between CBECC-Res 2022 and 2025. The 2025 compliance metrics include assumptions that more appliances will be electric in the future. This is predicted to result in higher natural gas retail rates as a result of gas utilities continuing to maintain safe and reliable infrastructure amidst declining natural gas use.

Equivalent CO2 emission reductions were calculated based on outputs from the CBECCRes simulation software. Electricity emissions vary by region and by hour of the year.

CBECC-Res applies two distinct hourly profiles, one for Climate Zones 1 through 5 and 11 through 13 and another for Climate Zones 6 through 10 and 14 through 16. Natural gas emissions do not vary hourly. To compare the mixed-fuel and all-electric cases side-by-side, GHG emissions are presented as pounds of CO2-equivalent (CO2e) emissions.

The Statewide Reach Codes Team designed the approach and selected measures for evaluation based on the 2019 existing building single family reach code analysis (Statewide Reach Codes Team, 2021) and supporting analysis used in the 2025 Energy Code development cycle as well as from outreach to architects, builders, and engineers.

2.2 Prototype Characteristics
The Energy Commission defines building prototypes which it uses to evaluate the costeffectiveness of proposed changes to Energy Code requirements. Average home size has steadily increased over time, and the Energy Commission single family new construction prototypes are larger than many existing single family homes across California. For this analysis, a 1,665 square foot prototype was evaluated. Table 2 describes the basic characteristics of the single family prototype. Additions are not evaluated in this analysis as they are already addressed in Section 150.2 of the Energy Code. In the 2025 Energy Code heat pumps are prescriptively required for space and water heating for additions (California Energy Commission, 2023).

Table 2. Residential Prototype Characteristics
Climate Zone Specification
Existing Conditioned Floor Area 1,665 ft2
Num. of Stories 1
Num. of Bedrooms 3
Window-to-Floor Area Ratio 13%
Attached Garage 2-car garage
Three building vintages were evaluated to determine sensitivity of existing building performance on cost-effectiveness of upgrades. For example, it is widely recognized that adding attic insulation in an older home with no insulation is cost-effective, however, newer homes will likely have existing attic insulation reducing the cost-effectiveness of an incremental addition of insulation. The building characteristics for each vintage were 2025/06/09
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 11 determined based on either prescriptive requirements from the building code that were in effect or standard construction practice during that time period. For example, homes built under 2001 Title 24 are subject to prescriptive envelope code requirements very similar to homes built under the 2005 code cycle, which was in effect until January 1, 2010.

Table 3 summarizes the assumptions for each of the three vintages. Additionally, the analysis assumed the following features when modeling the prototype buildings. • Efficiencies were defined by year of the most recent equipment replacement based on standard equipment lifetimes.
• Individual space conditioning and water heating systems, one per single family building.
• Split-system air conditioner with natural gas furnace. • Gas cooktop, oven, and clothes dryer.

The methodology applied in the analyses begins with a design that matches the specifications as described in Table 3 for each of the three vintages. Heat pump space conditioning measures were modeled to determine the projected energy performance and utility cost impacts relative to the baseline vintage.
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 12 Table 3. Efficiency Characteristics for Three Vintage Cases Building Component Efficiency
Feature Pre-1978 Vintage 1978-1991 Vintage 1992-2010 Vintage Envelope
Exterior Walls 2x4, 16-inch on center wood frame,
R-02
2x4 16 inch on center wood frame,
R-11
2x4 16 inch on center wood frame,
R-13
Foundation Type & Insulation Uninsulated slab (CZ 2-15) Raised floor, R-0 (CZ 1 & 16)
Uninsulated slab (CZ 2-15)
Raised floor, R-0 (CZ 1 & 16)
Uninsulated slab (CZ 2-15)
Raised floor, R-19 (CZ 1 & 16)
Ceiling Insulation & Attic Type
Vented attic, R-5 @ ceiling level for CZ
6 & 7,
Vented attic, R-11 @ ceiling level
(all other CZs)
Vented attic, R-19 @ ceiling level Vented attic, R-30 @ ceiling level Roofing Material & Color Asphalt shingles, dark
(0.10 reflectance, 0.85 emittance)
Asphalt shingles, dark
(0.10 reflectance, 0.85 emittance)
Asphalt shingles, dark
(0.10 reflectance, 0.85 emittance)
Radiant Barrier No No No
Window Type: U-factor/SHGC3 Metal, single pane: 1.16/0.76 Metal, dual pane: 0.79/0.70 Vinyl, dual pane Low-E: 0.55/0.40 House Infiltration at 50 Pascals 15 ACH50 10 ACH50 7 ACH50 HVAC Equipment
Heating Efficiency 78 AFUE (assumes 2 replacements) 78 AFUE (assumes 1 replacement) 78 AFUE Cooling Efficiency 10 SEER (assumes 2 replacements) 10 SEER (assumes 1 replacement) 13 SEER, 11 EER Duct Location & Details Attic, R-2.1, 30% leakage at 25 Pa Attic, R-2.1, 25% leakage at 25 Pa Attic, R-4.2, 15% leakage at 25 Pa Whole Building Mechanical
Ventilation None None None
Water Heating Equipment
Water Heater Efficiency 0.575 Energy Factor (assumes 2
replacements)

0.575 Energy Factor (assumes 1
replacement) 0.575 Energy Factor
Water Heater Type 40-gallon gas storage 40-gallon gas storage 40-gallon gas storage Pipe Insulation None None None
Hot Water Fixtures Standard, non-low flow Standard, non-low flow Standard, non-low flow 2 Pre-1978 wall modeled with R-5 cavity insulation to better align wall system performance with monitored field data and not overestimate energy use. 3 Window type selections were made based on conversations with window industry expert, Ken Nittler. If a technology was entering the market during the time period (e.g., Low-E during 1992-2010 or dual-pane during 1978-1991) that technology was included in the analysis. This provides a conservative assumption for overall building performance and additional measures may be cost-effective for buildings with lower performing windows, for example buildings with metal single pane windows in the 1978-1991 vintage
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 13

2.3 Cost-Effectiveness Approach

2.3.1 Benefits
This analysis used two different metrics to assess the cost-effectiveness of the proposed upgrades. Both methodologies require estimating and quantifying the incremental costs and energy savings associated with each energy efficiency measure. The main difference between the methodologies is the way they value energy impacts:
• On-Bill: Customer-based lifecycle cost approach that values energy based upon estimated site energy usage and customer On-Bill savings using electricity and natural gas utility rate schedules over a 30-year duration, accounting for a three percent discount rate and energy cost inflation per Appendix 6.3.7. • Long-term Systemwide Cost (LSC): Formerly known as Time Dependent Valuation (TDV) energy cost savings, LSC reflects the Energy Commission’s current lifecycle cost (LCC) methodology, which is intended to capture the total value or cost of energy use over 30 years. This method accounts for the hourly cost of marginal generation, transmission and distribution, fuel, capacity, losses, and cap-and-tradebased CO2 emissions (California Energy Commission, 2023). This is the methodology used by the Energy Commission in evaluating cost-effectiveness for measures in the 2025 Energy Code.

Energy simulations were completed using the 2025 research version of the Residential California Building Energy Code Compliance software (CBECC).

2.3.2 Costs
The Reach 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.

In February 2024, the TECH Clean California statewide program completed an incremental cost study from cost data collected from 64 contractor participants (Opinion Dynamics, 2024). This report directly uses the TECH costs for all the scenarios for which there was TECH cost data available. These costs were supplemented with measure costs the Reach Codes Team obtained from a contractor survey conducted in the summer of 2023. Additional detail on the contractor cost survey is available in the prior existing building statewide study (Statewide Reach Codes Team, 2024). The following summarizes key assumptions in this costing approach.
• Average statewide costs from the TECH Study were used, no regional specific costs were applied.
• Costs for 3-ton and 4-ton units were scaled for smaller and larger systems based on linear interpolation between the 3-ton and 4-ton costs. 2025/06/09
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 14 • The TECH study provided cost for a minimum efficiency 60,000 Btu/h gas furnace.

However, beginning in 2028, newly installed residential gas furnaces must comply with updated federal efficiency standards requiring a minimum of 95% AFUE4 .

Because the TECH study did not include cost estimates for a 95% AFUE condensing furnace, an adjustment was made using data from the statewide contractor cost survey. For systems requiring larger furnace capacities, cost estimates were derived as follows:
o 80,000 Btu/h furnaces (serving systems sized 3 tons): The cost difference between the minimum efficiency and 95% AFUE versions of the 80,000 Btu/h furnace and the cost difference between the minimum efficiency 80,000 Btu/h furnace and the minimum efficiency 60,000 Btu/h furnace, as reported in the contractor survey, was added to the TECH cost for the 60,000 Btu/h unit. o 100,000 Btu/h furnaces (serving systems 4 tons and larger): The same method was applied using the corresponding cost differential for 100,000 Btu/h units.
• At time of replacement for the heat pump, based on heating loads and contractor feedback it is assumed an electric resistance backup coil would be installed with the air handler for Climate Zones 1 and 16. The CBECC-Res software applies back up electric resistance heating for all climate zones whenever it is assumed that the heat pump cannot meet the heating load based on the performance of currently available products (Heinemeier, 2025).The TECH costs did not include this option. The $819 incremental cost from the statewide study was added in this case. • At the time of replacement for a furnace when it fails, the statewide study assumed a fan motor replacement. The TECH costs did not include this option. A $1,200 incremental cost was added to the TECH cost.
• At time of replacement for high efficiency heat pump, the sum of the TECH cost for standard efficiency heat pump and the incremental cost difference from the statewide study for high efficiency and standard efficiency heat pump was applied.

Costs were applied based on the system capacity from heating and cooling load calculations in CBECC-Res as presented in Table 4. Air conditioner nominal capacity was calculated as the CBECC-Res cooling load, rounded up to the nearest half ton. Heat pump nominal capacity was calculated as the maximum of either the CBECC-Res heating or cooling load, rounded up to the nearest half ton. In both cases a minimum capacity of 1.5- ton was applied as this represents the typical smallest available split system heat pump equipment. Load calculations revealed that Climate Zones 2 through 15 were coolingdominated, whereas Climate Zones 1 and 16 were heating-dominated. In these heating4 https://www.energy.gov/articles/doe-finalizes-energy-efficiency-standards-residential-furnaces-saveamericans-15- billion#:~:text=These%20furnace%20efficiency%20standards%20were,heat%20for%20the%20living %20space.
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 15 dominated zones, the heat pump was upsized compared to an air conditioner designed solely for cooling to ensure adequate heating performance.

Table 4. System Sizing by Climate Zone
Climate
Zone
Air Conditioner
Capacity (tons)
Heat Pump
Capacity (tons)
1 1.5 3.0
2 3.5 3.5
3 2.5 2.5
4 3.5 3.5
5 3.0 3.0
6 3.0 3.0
7 3.0 3.0
8 4.0 4.0
9 4.0 4.0
10 4.0 4.0
11 4.5 4.5
12 4.0 4.0
13 4.5 4.5
14 4.0 4.0
15 5.0 5.0
16 3.5 4.0

2.3.3 Metrics
Cost-effectiveness is presented using net present value (NPV). • NPV: The Reach Codes Team uses net savings (NPV benefits minus NPV costs) as the cost-effectiveness metric. If the net savings of a measure or package is positive, it is considered cost effective. Negative net savings represent net costs to the consumer. A measure that has negative energy cost benefits (energy cost increase) can still be cost effective if the costs to implement the measure are even more negative (i.e., construction and maintenance cost savings).

Improving the energy performance of a building often requires an initial investment. In most cases the benefit is represented by annual On-Bill utility or LSC savings, and the cost by incremental first cost and replacement costs. However, some packages result in initial construction cost savings (negative incremental cost), and either energy cost savings (positive benefits), or increased energy costs (negative benefits). In cases where both construction costs and energy-related savings are negative, the construction cost savings are treated as the benefit while the increased energy costs are the cost. In cases where a measure or package is cost-effective immediately (i.e., upfront construction cost savings and lifetime energy cost savings).
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 16

2.3.4 Utility Rates
In coordination with the CA IOU rates team (comprised of representatives from Pacific Gas and Electric (PG&E), Southern California Edison (SCE) and San Diego Gas and Electric (SDG&E)) and two Publicly-Owned-Utilities (POUs) (Sacramento Municipal Utility District (SMUD) and City of Palo Alto Utilities (CPAU)), the Reach Codes Team determined appropriate utility rates for each climate zone to calculate utility costs and determine On-Bill cost-effectiveness for the proposed measures and packages. The utility tariffs, summarized in Table 5 and Table 6 with details in Section 6.2.26.2.2, were determined based on the appropriate rate for each. Utility rates were applied to each climate zone based on the predominant IOU serving the population of each zone, with a few climate zones evaluated multiple times under different utility scenarios. Climate Zones 10 and 14 were evaluated with both SCE for electricity and Southern California Gas Company (SoCalGas) for gas and SDG&E tariffs for both electricity and gas since each utility has customers within these climate zones. Climate Zone 5 is evaluated under both PG&E and SoCalGas natural gas rates. Two POU or municipal utility rates were also evaluated: SMUD in Climate Zone 12 and CPAU in Climate Zone 4.

First-year utility costs were calculated using hourly electricity and natural gas output from CBECC-Res and applying the utility tariffs summarized in Table 5 and Table 6. Homes with a heat pump in IOU territory are eligible for either the electrification or the standard tariff. Utility costs were calculated under both tariffs with results presented using the one that yielded the lower annual utility cost. The electrification tariff resulted in better utility costs savings when there was high kWh usage, typically in older, less efficient homes. Conversely, newer homes which are more efficient, tend to benefit more under the standard tariff. However, in SCE’s milder climate zones, older homes benefit more under the standard tariff. Annual costs were also estimated for IOU customers eligible for the CARE tariff discounts on both electricity and natural gas bills.

Table 5. Investor-Owned Utility Tariffs Used Based on Climate Zone Climate
Zones
Electric / Gas
Utility
Electricity
Tariff:

Standard
Rate
Electricity
Tariff:

Electrification
Rate
Natural Gas
Tariff
1-5,11-13,16 PG&E / PG&E E-TOU-C E-ELEC G1
5 PG&E / SoCalGas E-TOU-C E-ELEC GR
6, 8-10, 14, 15 SCE / SoCalGas TOU-D-4-9 TOU-D-PRIME GR 7, 10, 14 SDG&E / SDG&E TOU-DR-1 EV-TOU-5 GR
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 17 Table 6. Publicly Owned Utility Tariffs Used Based on Climate Zone Climate
Zones
Electric / Gas Utility
Electricity Tariff: Standard
Rate
Electricity
Tariff:

Electrification
Rate
Natural Gas
Tariff
4 CPAU / CPAU E-1 G1
12 SMUD / PG&E R-TOD G1
Utility rates are assumed to escalate over time. Because it is very difficult to predict how rates will change, two escalation scenarios are presented in this study to represent a range of outcomes. See Appendix 6.3.7 Fuel Escalation Assumptions for details. 1) Modest Gas Escalation: This scenario is based on assumptions from the CPUC 2021 En Banc hearings on utility costs through 2030 (California Public Utilities Commission, 2021a). Escalation rates throughout the remainder of the 30-year evaluation period are based on the escalation rate assumptions within the 2022 Energy Code TDV factors developed by the Energy Commission (California Energy Commission. 2021b).
2) High Gas Escalation: This scenario is based on escalation rates developed by the Energy Commission and used within the 2025 Energy Code LSC factors (LSC replaces TDV in the 2025 Energy Code) which assumed steep increases in gas rates in the latter half of the analysis period.

Electricity tariff structures will evolve over time. Most recently, the CPUC approved an income-graduated fixed charge intended to benefit low-income customers and support electrification measures.5 The IOUs are currently developing tariffs that meet the direction given by the CPUC in this proceeding. These tariffs were not available at the time of this study, but this analysis may be re-evaluated later in 2025 once the rates are finalized. 5 https://www.cpuc.ca.gov/industries-and-topics/electrical-energy/electric-costs/demand-responsedr/demand-flexibility-rulemaking 2025/06/09
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 18

2.4 Measure Details and Cost
This section describes the details of the measures and documents incremental costs. All measure costs were obtained from the TECH cost survey and contractor survey unless otherwise noted. These surveys reflect the cost to the customer and include equipment, labor, permit fees, and required HERS testing.

The following heat pump space heater (HPSH) measures were evaluated as described below. All included HERS verified refrigerant charge, 10% duct sealing, and 300 CFM/ton airflow, aligned with the proposed code requirements for the 2025 Title 24 code. 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. A minimum federal efficiency (14.3 SEER2, 11.7 EER2, 7.5 HSPF2) heat pump was evaluated.

Savings are compared to a new AC (14.3 SEER2, 11.7 EER2) alongside the existing furnace (78 AFUE). A new evaporator coil is assumed to be installed with the AC system.
2) HPSH: Replace existing ducted AC and natural gas furnace with an electric heat pump and air handler. Minimum federal efficiency (14.3 SEER2, 11.7 EER2, 7.5 HSPF2) heat pumps were evaluated. Savings are compared to a new ducted natural gas furnace and AC (14.3 SEER2, 11.7 EER2, 80 AFUE).
3) High Efficiency HPSH: Replace existing ducted AC and natural gas furnace with an electric heat pump and air handler. Higher efficiency (17 SEER2, 12.48 EER2, 9.5 HSPF2) heat pumps were evaluated. Savings are compared to a new ducted natural gas furnace and AC (14.3 SEER2, 11.7 EER2, 80 AFUE).

Over the 30-year analysis period, certain changes are assumed when the equipment is replaced that impact both lifetime costs and energy use. Table 7 and Table 8 present the lifetime scenario for the DFHP Existing Furnace and HPSH measures, respectively. The analysis assumed a 20-year effective useful lifetime (EUL) for a furnace, a 15-year EUL for an air conditioner and a 15-year EUL for a heat pump. Lifetimes are based on the Database for Energy Efficient Resources (DEER) (California Public Utilities Commission, 2021b). The existing furnace is assumed to be halfway through its EUL at the beginning of the analysis period. After 10 years when the furnace reaches the end of its life and needs to be replaced, it will be subject to new federal efficiency standards for residential gas furnaces that go into effect in 2028 requiring 95 AFUE6
. Five years later the air conditioner reaches the end of its life and is replaced with a new air conditioner.
6 https://www.energy.gov/articles/doe-finalizes-energy-efficiency-standards-residential-furnaces-saveamericans-15- billion#:~:text=These%20furnace%20efficiency%20standards%20were,heat%20for%20the%20livin g%20space.
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 19 For the DFHP upgrade case, after 10 years when the furnace fails it’s expected that the furnace is abandoned in place since the heat pump serves primary heating and was sized to provide the full design heating load. In this case it is assumed that the fan motor is replaced with a new aftermarket unit and operates another five years until the heat pump fails and is replaced with a new heat pump and air handler. Table 7 through Table 8 present the lifecycle incremental cost breakdown for a 4-ton system. The heat pump is sized for each climate zone based on the heating and cooling load as shown in Table 4, and the 4-ton system was selected as an example to show the lifecycle cost breakdown.

Table 7. Lifecycle Incremental Cost Breakdown for a 4-Ton DFHP Existing Furnace Calendar
Year
Baseline AC
Replacement
Schedule
Baseline
Future
Cost
Baseline
Present
Value
Cost
Heat Pump
Heat
Pump
Future
Cost
Heat
Pump
Present
Value
Cost
2026 AC fails, install new
AC, keep existing
furnace
$10,431 $10,431 AC fails, install new
HP, keep existing
furnace
$12,347 $12,347
2036 Furnace fails, install
new 95AFUE
furnace
$7,476 $5,563 Furnace fails,
replace fan motor
$1,200 $893
2041 AC fails, install new
AC
$10,431 $6,695 HP fails, install new
HP and air handler
$14,529 $9,326
Total $22,689 $22,566
Incremental Cost -$123
Table 8. Lifecycle Incremental Cost Breakdown for 4-Ton HPSH Calendar
Year
Baseline AC
Replacement
Schedule
Baseline Future
Cost
Baseline
Present
Value
Cost
Heat Pump
Heat Pump
Future
Cost
Heat
Pump
Present
Value
Cost
2026 AC fails, install
new AC &
furnace
$13,808 $13,808 AC fails,
install new

HP & AHU
$14,529 $14,529
2041 AC fails, install
new AC
$10,431 $6,695 HP fails,
install new

HP & AHU
$13,529 $8,684
2046 Furnace fails,
install new
95AFUE
furnace
$7,476 $4,139
- - -
2056 Remaining
useful life for
furnace
-
-$1,540
- - -
Total $23,103 $23,213
Incremental Cost $110
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 20 Table 9 presents estimated first and lifetime costs for the baseline and heat pump scenarios for 4-ton equipment. Costs include all material and installation labor including providing new 240 V electrical service to the air handler location for all new air handler installations and decommissioning of the furnace for the cases where the furnace is removed. DFHP costs incorporate controls installation and commissioning to ensure the heat pump and the furnace communicate properly and don’t operate at the same time. Future replacement costs do not include any initial costs associated with 240V electrical service or furnace decommissioning.

Table 9. HVAC Measure Cost Assumptions – 4-Ton Electric Replacements Measure Case
AC +
Evaporator
Coil
Gas
Furnace
/AC
DFHP Existing
Furnace HPSH
High
Efficiency
HPSH
Base Case - - AC +
Evaporator Coil
Gas
Furnace
/AC
Gas
Furnace
/AC
First Cost $10,431 $13,808 $12,347 $14,529 $17,506
Replacement Cost
(Future Value) $17,907 $17,907 $15,729 $13,529 $16,506
Replacement Cost
(Present Value) $12,258 $11,639 $10,219 $8,684 $10,594
Remaining Value at
Year 30 $0 -$1,540 $0 $0 $0
Total Lifecycle Cost $22,689 $23,103 $22,566 $23,213 $28,100 Incremental Cost - - -$123 $110 $4,997

2.4.1 Lifecycle Cost Assuming Zero-NOx Standards for Space Heating After 2030
The California Air Resource Board proposed a strategy for reducing emissions in their 2022 Scoping Plan for Achieving Carbon Neutrality that includes a zero-emission standard for space and water heaters sold in California that would go into effect in 2030 (California Air Resources Board, 2022).

The South Coast Air Quality Management District (SCAQMD) proposed Rule 1111 for the Reduction of NOx Emissions from Natural Gas-Fired Furnaces. This rule applies to furnaces less than 175,000 Btu/hr and sets compliance goals for manufacturers with the proposed dates in Table 10. The sale of gas furnaces above the compliance target will incur a mitigation fee (SCAQMD, 2025).

Table 10. SCAQMD Rule 1111 Proposed Manufacturer Compliance Targets Target Dates 2027-2028 2029-2032 2033-2035 2036 and after NOx Emitting Units (e.g. gas) 70% 50% 25% 10%
Zero-Emission Units 30% 50% 75% 90%
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 21 The Bay Area Air Quality Management District (BAAD) adopted Rule 9-4 that similarly requires zero NOx standards for space heating systems sold in the Bay Area.

Implementation for residential furnaces will begin January 2029 (BAAD, 2025).

The BAAD Rule 9-4 has been adopted, but both the California Air Resources Board and SCAQMD Rule 1111 are proposed rules that have not yet been adopted, but given the implications these rulings would have on the 30-year cost-effectiveness if gas furnaces were very limited or no longer available in 2030, a sensitivity analysis for this scenario is included in this study for the DFHP Existing Furnace scenario. The other heat pump measures would also be impacted by this ruling; however, for simplicity the team selected one measure to give a sense of the impact on the results. The following costs reflect the scenario where gas furnaces are not available in 2030. This 30-year lifecycle analysis assumes that in 10 years when the furnace reaches the end of its useful life and needs to be replaced, it will be subjected to the SCAQMD Rule 1111 or California Air Resources Board proposal and will be replaced with a heat pump.

Table 11. Lifecycle Incremental Cost Breakdown for 4-Ton System with no Gas Furnaces after 2030
Calendar
Year
Baseline AC
Replacement
Schedule
Baseline
Future
Cost
Baseline
Present
Value
Cost
Heat Pump
Heat
Pump
Future
Cost
Heat
Pump
Present
Value
Cost
2026
AC fails, install new
AC, keep existing
furnace
$10,431 $10,431
AC fails, install new
HP, keep existing
furnace
$12,347 $12,347
2036 Furnace fails, install
new HP $14,529 $10,811 Furnace fails, replace fan motor $1,200 $893 2041 - - - HP fails, install new
HP and air handler $14,529 $9,326
2051 HP fails, install new
HP $13,529 $6,462 - - -
2056 Remaining useful
life for HP - -$4,459 - - -
Total $23,244 $22,566
Incremental Cost -$679
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 22 3 Results
The primary objective of the evaluation is to identify cost-effective HPSH upgrade measures for existing single family buildings, to support the design of local ordinances encouraging installation of a heat pump when replacing an air conditioner. While this section focuses primarily on the results of the cost-effectiveness analysis, it is important to highlight that the associated greenhouse gas (GHG) emissions savings are significant – averaging a 25% annual reduction across the climate zones and vintages. A full dataset of all results, including site energy, source energy, LSC and GHG emissions, can be downloaded at https://localenergycodes.com/content/resources. Results alongside policy options can also be explored using the Cost-effectiveness Explorer at https://explorer.localenergycodes.com/.

3.1 Cost-Effectiveness Results
Table 12 through Table 14 present results across the 16 climate zones for the 1992-2010 vintage using standard tariffs and Table 15 through Table 17 present results across the 16 climate zones and three vintages using CARE tariffs. Results show the incremental cost and utility bill savings for the first year along with cost effectiveness results for LSC and On-Bill under both the modest and high gas escalation scenarios. Results for additional vintages using standard tariffs are in Appendix 6.2 Cost-Effectiveness Results. 2025/06/09
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 23

3.1.1 Cost Effectiveness Results Using Standard Tariffs Table 12. [1992-2010] DFHP Existing Furnace
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025

LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $2,405 $60 $10,843 $5,471 $21,616
CZ02 PGE $1,670 ($86) $8,387 $2,238 $12,692
CZ03 PGE $1,178 $15 $8,383 $4,891 $13,958
CZ04 PGE $1,670 ($68) $7,322 $1,880 $10,049
CZ04 CPAU $1,670 ($9) $7,322 $2,132 $7,104
CZ05 PGE $1,424 ($12) $6,848 $3,425 $11,150
CZ05 PGE/SCG $1,424 ($195) $6,848 ($1,864) $2,099
CZ06 SCE/SCG $1,424 ($34) $2,647 $675 $1,468
CZ07 SDGE $1,424 ($36) $2,691 $599 $1,734
CZ08 SCE/SCG $1,916 ($65) $1,879 ($811) $162
CZ09 SCE/SCG $1,916 ($90) $2,600 ($1,186) $288
CZ10 SCE/SCG $1,916 ($79) $2,295 ($982) $394
CZ10 SDGE $1,916 $54 $2,295 $2,201 $4,708
CZ11 PGE $2,162 $68 $7,597 $4,639 $14,675
CZ12 PGE $1,916 $44 $8,317 $4,702 $15,222
CZ12 SMUD/PGE $1,916 $353 $8,317 $11,622 $22,364
CZ13 PGE $2,162 $76 $5,244 $3,897 $11,138
CZ14 SCE/SCG $1,916 ($179) $4,654 ($2,364) $1,340
CZ14 SDGE $1,916 ($22) $4,654 $1,282 $7,058
CZ15 SCE/SCG $2,408 ($133) ($271) ($3,438) ($3,209)
CZ16 PGE $2,243 ($66) $8,842 $1,260 $11,982
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 24 Table 13. [1992-2010] Standard Efficiency HPSH
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025

LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $3,067 ($145) $10,949 ($34) $17,899
CZ02 PGE $652 ($229) $9,362 ($702) $11,825
CZ03 PGE $514 ($62) $8,244 $2,373 $11,665
CZ04 PGE $652 ($205) $8,680 ($572) $10,753
CZ04 CPAU $652 ($85) $8,680 $556 $7,194
CZ05 PGE $583 ($113) $6,957 $752 $9,206
CZ05 PGE/SCG $583 ($316) $6,957 ($5,101) ($811)
CZ06 SCE/SCG $583 ($37) $2,134 ($63) $716
CZ07 SDGE $583 ($39) $2,156 ($149) $981
CZ08 SCE/SCG $721 ($79) $1,812 ($1,356) ($371)
CZ09 SCE/SCG $721 ($118) $2,589 ($2,038) ($524)
CZ10 SCE/SCG $721 ($103) $2,311 ($1,723) ($259)
CZ10 SDGE $721 $34 $2,311 $1,533 $4,218
CZ11 PGE $790 ($35) $8,817 $2,833 $14,504
CZ12 PGE $721 ($94) $9,199 $1,812 $13,563
CZ12 SMUD/PGE $721 $363 $9,199 $12,027 $24,107
CZ13 PGE $790 $6 $5,948 $2,558 $10,687
CZ14 SCE/SCG $721 ($412) $6,635 ($6,964) ($1,073)
CZ14 SDGE $721 ($107) $6,635 $166 $10,249
CZ15 SCE/SCG $859 ($139) ($112) ($3,434) ($3,186)
CZ16 PGE $2,095 ($385) $13,600 ($2,842) $19,424
2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 25 Table 14. [1992-2010] High Efficiency HPSH
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025

LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $5,998 $56 $9,783 ($350) $17,727
CZ02 PGE $3,606 ($94) $7,527 ($2,544) $10,080
CZ03 PGE $3,422 $59 $5,701 $312 $9,692
CZ04 PGE $3,606 ($61) $6,961 ($2,193) $9,235
CZ04 CPAU $3,606 $0 $6,961 ($2,389) $4,310
CZ05 PGE $3,514 $4 $4,176 ($1,450) $7,088
CZ05 PGE/SCG $3,514 ($199) $4,176 ($7,303) ($2,929)
CZ06 SCE/SCG $3,514 ($14) ($2,162) ($4,367) ($3,567)
CZ07 SDGE $3,514 ($12) ($2,090) ($4,312) ($3,191)
CZ08 SCE/SCG $3,698 $13 ($1,660) ($4,217) ($3,149)
CZ09 SCE/SCG $3,698 ($26) ($750) ($4,883) ($3,284)
CZ10 SCE/SCG $3,698 ($4) ($844) ($4,418) ($2,864)
CZ10 SDGE $3,698 $132 ($844) ($1,068) $1,587
CZ11 PGE $3,789 $186 $7,738 $2,845 $14,675
CZ12 PGE $3,698 $88 $7,575 $996 $12,879
CZ12 SMUD/PGE $3,698 $422 $7,575 $8,459 $20,580
CZ13 PGE $3,789 $208 $4,419 $2,165 $10,439
CZ14 SCE/SCG $3,698 ($219) $5,760 ($7,575) ($1,506)
CZ14 SDGE $3,698 $77 $5,760 ($424) $9,604
CZ15 SCE/SCG $3,881 $50 ($2,144) ($4,209) ($3,786)
CZ16 PGE $5,071 ($97) $14,557 ($1,291) $21,181
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 26

3.1.2 Cost Effectiveness Results Using CARE Tariffs
Table 15. [1992-2010] DFHP Existing Furnace CARE
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025

LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $2,405 $153 $10,843 $6,436 $19,266
CZ02 PGE $1,670 $18 $8,387 $3,842 $12,159
CZ03 PGE $1,178 $73 $8,383 $5,574 $12,777
CZ04 PGE $1,670 $14 $7,322 $3,143 $9,641
CZ04 CPAU $1,670 $0 $7,322 $711 $711
CZ05 PGE $1,424 $47 $6,848 $4,198 $10,337
CZ05 PGE/SCG $1,424 ($98) $6,848 $23 $3,191
CZ06 SCE/SCG $1,424 ($18) $2,647 $967 $1,600
CZ07 SDGE $1,424 ($16) $2,691 $1,000 $1,887
CZ08 SCE/SCG $1,916 ($38) $1,879 ($285) $495
CZ09 SCE/SCG $1,916 ($52) $2,600 ($450) $731
CZ10 SCE/SCG $1,916 ($45) $2,295 ($331) $771
CZ10 SDGE $1,916 $51 $2,295 $1,998 $3,963
CZ11 PGE $2,162 $115 $7,597 $4,993 $12,965
CZ12 PGE $1,916 $103 $8,317 $5,287 $13,643
CZ12 SMUD/PGE $1,916 $418 $8,317 $12,339 $20,922
CZ13 PGE $2,162 $100 $5,244 $3,939 $9,686
CZ14 SCE/SCG $1,916 ($98) $4,654 ($849) $2,119
CZ14 SDGE $1,916 $23 $4,654 $2,007 $6,528
CZ15 SCE/SCG $2,408 ($88) ($271) ($2,456) ($2,260)
CZ16 PGE $2,243 $33 $8,842 $2,737 $11,267
2025/06/09
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 27 Table 16. [1992-2010] Standard Efficiency HPSH CARE
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025

LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $3,067 $33 $10,949 $2,703 $16,973
CZ02 PGE $652 ($59) $9,362 $2,211 $12,188
CZ03 PGE $514 $25 $8,244 $3,685 $11,074
CZ04 PGE $652 ($53) $8,680 $2,048 $11,067
CZ04 CPAU $652 $0 $8,680 $255 $255
CZ05 PGE $583 ($13) $6,957 $2,389 $9,117
CZ05 PGE/SCG $583 ($173) $6,957 ($2,232) $1,208
CZ06 SCE/SCG $583 ($20) $2,134 $249 $872
CZ07 SDGE $583 ($18) $2,156 $279 $1,161
CZ08 SCE/SCG $721 ($47) $1,812 ($728) $62
CZ09 SCE/SCG $721 ($70) $2,589 ($1,094) $122
CZ10 SCE/SCG $721 ($61) $2,311 ($892) $281
CZ10 SDGE $721 $39 $2,311 $1,509 $3,612
CZ11 PGE $790 $60 $8,817 $4,141 $13,421
CZ12 PGE $721 $22 $9,199 $3,592 $12,940
CZ12 SMUD/PGE $721 $471 $9,199 $13,622 $23,292
CZ13 PGE $790 $61 $5,948 $3,234 $9,693
CZ14 SCE/SCG $721 ($241) $6,635 ($3,632) $1,098
CZ14 SDGE $721 ($5) $6,635 $1,996 $9,885
CZ15 SCE/SCG $859 ($91) ($112) ($2,414) ($2,201)
CZ16 PGE $2,095 ($92) $13,600 $2,163 $19,892
2025/06/09
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 28 Table 17. [1992-2010] High Efficiency HPSH CARE
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025

LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $5,998 $164 $9,783 $813 $15,177
CZ02 PGE $3,606 $28 $7,527 ($683) $9,357
CZ03 PGE $3,422 $104 $5,701 $674 $8,120
CZ04 PGE $3,606 $41 $6,961 ($703) $8,383
CZ04 CPAU $3,606 $0 $6,961 ($4,595) ($4,595)
CZ05 PGE $3,514 $62 $4,176 ($727) $6,056
CZ05 PGE/SCG $3,514 ($98) $4,176 ($5,348) ($1,853)
CZ06 SCE/SCG $3,514 ($5) ($2,162) ($4,219) ($3,583)
CZ07 SDGE $3,514 ($0) ($2,090) ($4,112) ($3,235)
CZ08 SCE/SCG $3,698 $15 ($1,660) ($4,248) ($3,401)
CZ09 SCE/SCG $3,698 ($8) ($750) ($4,603) ($3,330)
CZ10 SCE/SCG $3,698 $6 ($844) ($4,300) ($3,065)
CZ10 SDGE $3,698 $103 ($844) ($1,892) $191
CZ11 PGE $3,789 $203 $7,738 $2,425 $11,808
CZ12 PGE $3,698 $141 $7,575 $1,351 $10,784
CZ12 SMUD/PGE $3,698 $471 $7,575 $8,735 $18,405
CZ13 PGE $3,789 $192 $4,419 $1,255 $7,809
CZ14 SCE/SCG $3,698 ($111) $5,760 ($5,632) ($783)
CZ14 SDGE $3,698 $115 $5,760 ($98) $7,755
CZ15 SCE/SCG $3,881 $36 ($2,144) ($4,549) ($4,220)
CZ16 PGE $5,071 $95 $14,557 $1,460 $19,324

3.2 Zero-NOx Scenario Results
This section presents cost-effectiveness results for the DFHP Existing Furnace under the scenario where proposed air quality district zero-NOx rules go into effect over the next 10 years. In the base case, at time of replacement of the gas furnace at year 10 a heat pump is installed. The energy profile between the base case and the heat pump upgrade case are subsequently identical for the remaining 20 years of the 30-year analysis period. As a result, energy and cost savings only persist for the first 10 years.

Table 18 shows the On-Bill NPV cost-effectiveness results and Table 19 the LSC costeffectiveness results for all three vintages. 2025 LSC savings were calculated using individual year multipliers for the first 10 years, 2026 through 2035. 2025/06/09
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 29 Table 18. DFHP Existing Furnace On-Bill NPV (Zero-NOx Rule) Climate
Zone
Electric/
Gas Utility
On-Bill NPV
Pre-1978 1978-1991 1992-2010
CZ01 PGE $5,473 $4,136 $2,349
CZ02 PGE $1,785 $1,031 $1,101
CZ03 PGE $2,863 $2,097 $2,052
CZ04 PGE $2,133 $1,162 $1,019
CZ04 CPAU $2,340 $1,599 $1,213
CZ05 PGE $1,918 $1,486 $1,576
CZ05 PGE/SCG ($1,308) ($834) ($491)
CZ06 SCE/SCG $401 $605 $635
CZ07 SDGE $1,473 $999 $641
CZ08 SCE/SCG ($125) $99 $195
CZ09 SCE/SCG ($563) ($183) $22
CZ10 SCE/SCG ($259) $53 $110
CZ10 SDGE $2,985 $2,261 $1,430
CZ11 PGE $3,287 $2,866 $2,279
CZ12 PGE $2,935 $2,578 $2,202
CZ12 SMUD/PGE $7,877 $5,978 $5,040
CZ13 PGE $2,927 $2,556 $2,053
CZ14 SCE/SCG ($864) ($943) ($543)
CZ14 SDGE $2,204 $1,655 $1,064
CZ15 SCE/SCG $1,338 $396 ($688)
CZ16 PGE $1,192 $1,071 $1,096
2025/06/09
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 30 Table 19. DFHP Existing Furnace LSC Savings (Zero-NOx Rule) Climate
Zone
Electric/
Gas Utility

LSC NPV
Pre-1978 1978-1991 1992-2010
CZ01 PGE $3,019 $2,510 $1,558
CZ02 PGE $1,256 $1,025 $1,006
CZ03 PGE $1,460 $1,120 $1,036
CZ04 PGE $1,242 $949 $887
CZ04 CPAU $1,242 $949 $887
CZ05 PGE $1,127 $816 $820
CZ05 PGE/SCG $1,127 $816 $820
CZ06 SCE/SCG $545 $318 $251
CZ07 SDGE $639 $403 $314
CZ08 SCE/SCG $428 $279 $244
CZ09 SCE/SCG $608 $424 $372
CZ10 SCE/SCG $469 $320 $293
CZ10 SDGE $469 $320 $293
CZ11 PGE $1,871 $1,475 $1,263
CZ12 PGE $1,924 $1,539 $1,356
CZ12 SMUD/PGE $1,375 $1,090 $939
CZ13 PGE ($206) ($186) $50
CZ14 SCE/SCG ($206) ($186) $50
CZ14 SDGE $127 $60 $38
CZ15 SCE/SCG ($185) ($12) $77
CZ16 PGE $3,019 $2,510 $1,558

3.3 AC Pathways for Heat Pump Replacements
Many jurisdictions are interested in seeing alternative pathways for residents who may prefer to replace an air conditioner with similar equipment, rather than migrating to a heat pump system. Alternative packages analyzed to support this request include air conditioning equipment combined with additional efficiency measures resulting in options that are reasonably energy or LSC cost equivalent to a heat pump system, to the extent feasible.

Figure 1 shows two AC pathways, one with an existing duct system and another path 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 installed new could allow for either a heat pump to be installed or an AC as long as the performance measures listed below are met. 2025/06/09
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 31 Figure 1. AC vs. Heat Pump Pathway Requirements
The heat pump only and two AC pathways are presented in Figure 2 comparing total LSC energy use relative to the existing home for the 1992-2010 vintage. The heat pump path is represented by the DFHP Existing Furnace scenario. In most climate zones, the heat pump path results in higher energy savings, in the milder climates the AC and new ducts and New AC Only paths save marginally more energy.

Figure 2. AC vs. Heat Pump Energy Comparison
2025/06/09
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 32 Though the AC path does not need to meet cost-effectiveness criteria to be adopted as a reach code since it’s an alternative path, in order to understand the implications of the AC path on the customer, Table 20 and Table 21 present estimated costs for the new AC only and the new AC + new ducts paths respectively.

Table 20. New AC Only Path Cost Estimates
New AC Only Path Pre-1978 1978-1991 1992-2010
Fan Efficacy: 0.45 W/CFM - - -
Refrigerant Charge Verification $100 $100 $1007
R-49 Attic Insulation $5,483 $3,612 $1,827
Air Sealing $1,963 $1,963 $1,963
Total $7,546 $5,675 $3,790
Table 21. New AC/Furnace and New Ducts Path Cost Estimates New AC and New Ducts Path Pre-1978 1978-1991 1992-2010
New R-8 Ducts $6,311 $6,311 $6,311
Furnace $5,951 $5,951 $5,951
Fan Efficacy: 0.35 W/CFM $500 $500 $500
Refrigerant Charge Verification $100 $100 $100
Total $12,862 $12,862 $12,862
7 This is an incremental cost and in some climate zones, refrigerant charge verification is required so there is no incremental cost added.
2025/06/09
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 33 4 Recommendations and Discussion
This analysis evaluated the feasibility and cost-effectiveness of AC to heat pump measures in California existing homes built before 2010. To meet the needs of jurisdictions evaluating this option, Statewide Reach Codes Team used both On-Bill and LSC-based lifecycle cost approaches to evaluate cost-effectiveness and quantify the energy cost savings associated with energy efficiency measures compared to the incremental costs associated with the measures.

Conclusions and Discussion:

1. Heat pumps are significantly more efficient than gas furnaces, requiring less than half the energy to meet the heating load. However, despite this reduction in heating energy use, the cost of heating a home using electricity (heat pump) could be higher than the cost to heat that same home with natural gas (furnace), depending on the electricity tariffs relative to the gas tariffs. Therefore, while a heat pump measure could be deemed as cost-effective over its lifecycle, installing a heat pump could result in a decrease or an increase in utility costs in the first years relative to a gas furnace and AC system. For example, the heat pump space heater measure in climate zone 12 in the newest vintage results in the customer saving money on their utility bill in SMUD territory but paying more on their utility bill in PG&E territory. Both PG&E and SMUD territory use PG&E gas rates, but SMUD has lower electricity rates than PG&E. With fuel switching measures like the AC to HP measure, the electricity to gas ratio has a significant impact on the savings or costs the customer will see by switching from gas to an electric heat pump space heater.

2. The LSC metric most often produces more favorable cost-effectiveness results relative to the results produced using actual utility costs (On-Bill). When the analysis assumes a higher escalation rate for natural gas costs relative to electricity in future years (high gas escalation), the On-Bill results are more favorable in some cases. a. In the oldest (pre-1978) vintage, all three measures (dual fuel heat pump with existing furnace, standard heat pump space heater, and high efficiency heat pump space heater) are cost-effective using the LSC metric in all climate zones. When using the On-Bill metric, the measures remain costeffective in most climate zones. b. In the newer (1978-1991 and 1992-2010) vintages, the dual fuel heat pump (DFHP Existing Furnace) and the standard efficiency HPSH are cost-effective based on LSC in all cases except for Climate Zone 15 when using both the standard and California Alternative Rates for Energy (CARE) tariff.

3. Using the CARE tariff results in higher cost savings and cost-effectiveness relative to standard rates, with almost all cases yielding first year utility cost savings. The DFHP Existing Furnace is On-Bill cost-effective based on the high gas escalation scenario in all cases in the pre-1978 vintage, and almost all cases in the 1978-1991 and 1992-2010 vintage. It is also On-Bill cost-effective in most climate zones for the 2025/06/09
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 34 modest gas escalation scenario across all vintages. In Climate Zones 5, 8, 9, 10, 14, and 15, cost-effectiveness declines relative to other areas, and in some cases is not cost-effective from an On-Bill perspective. This is the case for both the CARE tariff and the standard rate.

4. The analysis also modeled the cost impact of using a standard time-of-use electricity tariff versus switching to a newer electrification tariff, designed to reduce costs in homes with heat pumps and/or electric vehicles. Older homes tend to be the least efficient and achieve the most savings from improving equipment efficiency. In most of the state, because older homes tend to use more electricity than a similarly sized, newer vintage home, they realize more costs savings under the electrification tariff.

Newer homes tend to use less electricity and therefore do not realize the same cost savings from switching tariffs; they generally perform better under the standard tariff.

This trend is different in milder climate zones in SCE territory (excluding CZ 15), where newer homes realize more cost savings than older homes. Both the standard and electrification tariffs in SCE territory include a daily allocation of lower-cost baseline electricity and a second, higher-priced tier when the baseline is exceeded.

In many newer homes, a higher percentage of overall electricity use is within the baseline allocation, resulting in greater cost savings.

5. Higher efficiency equipment reduces utility costs in all cases and improves costeffectiveness in many climate zones in the oldest vintage relative to standard efficiency equipment. However, in more efficient newer homes, where costeffectiveness is generally lower, the savings are insufficient to offset the roughly $3,000 increase in incremental cost.

6. Given the adopted Bay Area Air Quality Management District Zero NOx rule, and the proposed California Air Resource Board or South Coast Air Quality Management District (SCAQMD) Zero-NOx rules, and gas furnaces may not be available to be installed in 2030, a sensitivity analysis was performed for the Zero NOx scenario and found that cost-effectiveness decreases in many cases except in Climate Zones 8- 10, some results improve enough to become cost-effective. The improved costeffectiveness in Climate Zones 8-10 is due to the higher baseline cost when a HPSH must be installed at year 10 when the furnace must be replaced. However, the overall magnitude of 30-year On-Bill cost-effectiveness is lower because there are only 10 years of utility cost savings. After year 10 the base case and upgrade measures are both heat pumps.

7. While not evaluated in this report, the 2022 Single Family Retrofit Cost-effectiveness Study (Statewide Reach Codes Team, 2024) shows it is beneficial to combine a heat pump space conditioning system with photovoltaics (PV) because the additional electricity required by the heat pump can be met by the PV system and result in reduced utility bills.

8. In this study the dual fuel heat pump is evaluated with an existing furnace, however the homeowner could choose to replace the existing furnace with a new furnace at 2025/06/09
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 35 this time as well. This measure (DFHP New Furnace) was evaluated in the 2022 Single Family Retrofit Cost-effectiveness Study (Statewide Reach Codes Team, 2024) but found to be less cost-effective than the DFHP Existing Furnace case. 2025/06/09
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 36 5 References
BAAD. (2025, May 7). Rules 9-4 and 9-6 Building Appliances. Retrieved from Bay Area Air District: https://www.baaqmd.gov/en/rules-and-compliance/ruledevelopment/building-appliances California Air Resources Board. (2022, August 12). 2022 State Strategy for the State Implementation Plan (2022 State SIP Strategy). Retrieved from California Air Resources Board Web site: https://ww2.arb.ca.gov/sites/default/files/2022- 11/Proposed_2022_State_SIP_Strategy.pdf
California Energy Commission. (2017). Rooftop Solar PV System. Measure number: 2019- Res-PV-D Prepared by Energy and Environmental Economics, Inc. Retrieved from https://efiling.energy.ca.gov/getdocument.aspx?tn=221366 California Energy Commission. (2021b). Final Express Terms for the Proposed Revisions to the 2022 Energy Code Reference Appendices. Retrieved from https://efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=21-BSTD-01 California Energy Commission. (2023). 2025 Energy code Hourly Factors. Retrieved from https://www.energy.ca.gov/files/2025-energy-code-hourly-factors California Energy Commission. (2023). Draft 2025 Energy Code Express Terms. Retrieved from
https://efiling.energy.ca.gov/GetDocument.aspx?tn=252915&DocumentContentId=88 051
California Energy Commission. (2025). Final Express Terms for the Proposed Revisions to 2025 Title 24, Part 11 (CALGreen). Retrieved from
https://efiling.energy.ca.gov/GetDocument.aspx?tn=261229&DocumentContentId=97 592
California Public Utilities Commission. (2021a). Utility Costs and Affordability of the Grid of the Future: An Evaluation of Electric Costs, Rates, and Equity Issues Pursuant to P.U. Code Section 913.1. Retrieved from https://www.cpuc.ca.gov/-/media/cpucwebsite/divisions/office-of-governmental-affairs-division/reports/2021/senate-bill-695- report-2021-and-en-banc-whitepaper_final_04302021.pdf
California Public Utilities Commission. (2021b). Database for Energy-Efficient resources (DEER2021 Update). Retrieved April 13, 2021, from
http://www.deeresources.com/index.php/deer-versions/deer2021 Department of Energy. (2023). DOE Finalizes Energy Efficiency Standards for Residential Furnaces to Save Americans $1.5 Billion In Annual Utility Bills. Retrieved from www.energy.gov: https://www.energy.gov/articles/doe-finalizes-energy-efficiencystandards-residential-furnaces-save-americans-15-billion 2025/06/09
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 37 E-CFR. (2020). https://www.ecfr.gov/cgibin/retrieveECFR?gp=&SID=8de751f141aaa1c1c9833b36156faf67&mc=true&n=pt1

0.3.431&r=PART&ty=HTML#se10.3.431_197. Retrieved from Electronic Code of Federal Regulations: https://www.ecfr.gov/cgibin/retrieveECFR?gp=&SID=8de751f141aaa1c1c9833b36156faf67&mc=true&n=pt1

0.3.431&r=PART&ty=HTML#se10.3.431_197
Heinemeier, K. (2025). Residential HVAC Performance. Retrieved from https://title24stakeholders.com/wp-content/uploads/2025/03/Residential-HVACPerformance.pdf SCAQMD. (2025). Proposed Amended Rules (PAR) 1111 and 1121. Retrieved from aqmd.gov.

SCAQMD. (2025, February 21). Space and Water Heating Building Appliances. Retrieved from South Coast AQMD: https://www.aqmd.gov/docs/defaultsource/Agendas/ssc/ssc-agenda-2-21-2025.pdf Statewide CASE Team. (2023). Multifamily Domestic Hot Water. Retrieved from https://title24stakeholders.com/wp-content/uploads/2023/08/2025_T24_CASEReport-_MF-DHW-Final-1.pdf Statewide CASE Team. (2023). Residential HVAC PErformance. Retrieved from https://title24stakeholders.com/wpcontent/uploads/2023/11/Revised_2025_T24_Final-CASE-Report-RES-HVACPerformance.pdf Statewide Reach Codes Team. (2021). 2019 Cost-Effectiveness Study: Existing Single Family Residential Buidling Upgrades. Retrieved from
https://localenergycodes.com/content/resources
Statewide Reach Codes Team. (2024). 2022 Cost-Effectiveness Study: Existing Single Family Building Upgrades. Prepared by Frontier Energy. Retrieved from https://localenergycodes.com/download/1222/file_path/fieldList/Single%20Family%2 0Retrofits%20CostEff%20Report.pdf
2025/06/09
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 38 6 Appendices

6.1 Map of California Climate Zones
Climate zone geographical boundaries are depicted in Figure 3. The map in Figure 3 along with a zip-code search directory is available at:
https://ww2.energy.ca.gov/maps/renewable/building_climate_zones.html Figure 3. Map of California climate zones.
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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 39

6.2 Cost-Effectiveness Results

6.2.1 Standard Rates
The following tables present results across the16 climate zones for the pre-1978 (Table 22 through Table 24) and the 1978-1991 (Table 25 through Table 27) vintages supplementing the results in Section 3.

Table 22. [Pre-1978] DFHP Existing Furnace
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025

LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $2,405 $155 $25,223 $14,524 $51,831
CZ02 PGE $1,670 ($81) $11,551 $4,316 $20,806
CZ03 PGE $1,178 $39 $11,680 $7,248 $21,906
CZ04 PGE $1,670 ($7) $10,574 $4,948 $18,321
CZ04 CPAU $1,670 $63 $10,574 $5,177 $14,531
CZ05 PGE $1,424 ($29) $9,462 $4,574 $16,955
CZ05 PGE/SCG $1,424 ($314) $9,462 ($3,674) $2,838
CZ06 SCE/SCG $1,424 ($70) $4,223 $179 $1,795
CZ07 SDGE $1,424 $41 $4,278 $2,725 $5,055
CZ08 SCE/SCG $1,916 ($111) $3,216 ($1,507) $375
CZ09 SCE/SCG $1,916 ($168) $4,238 ($2,500) $125
CZ10 SCE/SCG $1,916 ($133) $3,755 ($1,774) $774
CZ10 SDGE $1,916 $201 $3,755 $6,175 $10,683
CZ11 PGE $2,162 $93 $11,970 $7,593 $24,951
CZ12 PGE $1,916 $46 $12,302 $6,948 $24,190
CZ12 SMUD/PGE $1,916 $584 $12,302 $18,997 $36,626
CZ13 PGE $2,162 $112 $8,180 $6,374 $18,740
CZ14 SCE/SCG $1,916 ($244) $6,646 ($2,926) $3,332
CZ14 SDGE $1,916 $65 $6,646 $4,203 $13,297
CZ15 SCE/SCG $2,408 $80 $401 $1,506 $2,532
CZ16 PGE $2,243 ($199) $17,538 $2,333 $25,276
2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 40 Table 23. [Pre-1978] Standard Efficiency HPSH
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025

LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $3,067 ($127) $27,155 $7,800 $48,445
CZ02 PGE $652 ($242) $13,342 $1,420 $21,282
CZ03 PGE $514 ($46) $11,946 $4,614 $19,670
CZ04 PGE $652 ($139) $13,059 $3,274 $21,888
CZ04 CPAU $652 ($48) $13,059 $3,194 $15,372
CZ05 PGE $583 ($131) $9,998 $2,045 $15,648
CZ05 PGE/SCG $583 ($449) $9,998 ($7,152) ($94)
CZ06 SCE/SCG $583 ($76) $3,860 ($652) $931
CZ07 SDGE $583 $35 $3,876 $1,901 $4,218
CZ08 SCE/SCG $721 ($128) $3,305 ($2,112) ($199)
CZ09 SCE/SCG $721 ($219) $4,415 ($3,839) ($1,141)
CZ10 SCE/SCG $721 ($188) $3,982 ($3,168) ($483)
CZ10 SDGE $721 $166 $3,982 $5,200 $10,049
CZ11 PGE $790 ($74) $14,045 $4,727 $24,836
CZ12 PGE $721 ($179) $13,850 $2,374 $21,622
CZ12 SMUD/PGE $721 $601 $13,850 $19,845 $39,654
CZ13 PGE $790 ($14) $9,394 $3,998 $17,858
CZ14 SCE/SCG $721 ($450) $10,103 ($6,294) $4,015
CZ14 SDGE $721 ($66) $10,103 $2,757 $18,994
CZ15 SCE/SCG $859 $68 $643 $1,364 $2,430
CZ16 PGE $2,095 ($484) $27,492 $2,918 $49,419
2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 41 Table 24. [Pre-1978] High Efficiency HPSH
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025

LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $5,998 $249 $30,518 $11,401 $52,316
CZ02 PGE $3,606 ($24) $13,354 $1,431 $21,449
CZ03 PGE $3,422 $100 $10,768 $3,122 $18,282
CZ04 PGE $3,606 $118 $13,537 $4,185 $22,984
CZ04 CPAU $3,606 $101 $13,537 $1,665 $13,950
CZ05 PGE $3,514 $10 $8,416 $384 $14,087
CZ05 PGE/SCG $3,514 ($308) $8,416 ($8,814) ($1,654)
CZ06 SCE/SCG $3,514 $3 $380 ($3,709) ($2,052)
CZ07 SDGE $3,514 $114 $430 ($1,063) $1,230
CZ08 SCE/SCG $3,698 $31 $1,065 ($3,478) ($1,420)
CZ09 SCE/SCG $3,698 ($40) $2,358 ($4,759) ($1,897)
CZ10 SCE/SCG $3,698 $6 $2,191 ($3,746) ($882)
CZ10 SDGE $3,698 $344 $2,191 $4,481 $9,276
CZ11 PGE $3,789 $283 $15,614 $7,801 $28,167
CZ12 PGE $3,698 $152 $14,490 $4,899 $24,385
CZ12 SMUD/PGE $3,698 $708 $14,490 $17,350 $37,236
CZ13 PGE $3,789 $326 $10,164 $6,697 $20,802
CZ14 SCE/SCG $3,698 ($173) $11,876 ($5,041) $5,522
CZ14 SDGE $3,698 $244 $11,876 $5,111 $21,254
CZ15 SCE/SCG $3,881 $335 $393 $2,323 $3,635
CZ16 PGE $5,071 $45 $34,043 $9,856 $56,737
2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 42 Table 25. [1978-1991] DFHP Existing Furnace
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025

LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $2,405 $99 $20,184 $10,746 $40,368
CZ02 PGE $1,670 ($114) $9,142 $2,185 $14,361
CZ03 PGE $1,178 $3 $9,033 $5,101 $15,624
CZ04 PGE $1,670 ($68) $8,160 $2,319 $11,818
CZ04 CPAU $1,670 $18 $8,160 $3,161 $9,418
CZ05 PGE $1,424 ($32) $7,070 $3,268 $11,902
CZ05 PGE/SCG $1,424 ($238) $7,070 ($2,666) $1,747
CZ06 SCE/SCG $1,424 ($39) $2,941 $614 $1,557
CZ07 SDGE $1,424 $1 $3,046 $1,512 $2,837
CZ08 SCE/SCG $1,916 ($78) $2,145 ($1,026) $145
CZ09 SCE/SCG $1,916 ($116) $2,978 ($1,655) $122
CZ10 SCE/SCG $1,916 ($89) $2,606 ($1,096) $571
CZ10 SDGE $1,916 $139 $2,606 $4,321 $7,320
CZ11 PGE $2,162 $103 $9,118 $6,239 $18,777
CZ12 PGE $1,916 $60 $9,604 $5,770 $18,506
CZ12 SMUD/PGE $1,916 $430 $9,604 $14,059 $27,062
CZ13 PGE $2,162 $111 $6,237 $5,242 $14,247
CZ14 SCE/SCG $1,916 ($230) $4,931 ($3,277) $1,039
CZ14 SDGE $1,916 $35 $4,931 $2,793 $9,271
CZ15 SCE/SCG $2,408 ($17) ($99) ($807) ($310)
CZ16 PGE $2,243 ($161) $14,397 $1,740 $20,318
2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 43 Table 26. [1978-1991] Standard Efficiency HPSH
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025

LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $3,067 ($128) $21,427 $5,043 $37,346
CZ02 PGE $652 ($235) $10,428 ($90) $14,711
CZ03 PGE $514 ($67) $8,999 $2,767 $13,608
CZ04 PGE $652 ($164) $9,984 $1,062 $14,605
CZ04 CPAU $652 ($66) $9,984 $1,535 $9,914
CZ05 PGE $583 ($132) $7,290 $703 $10,264
CZ05 PGE/SCG $583 ($361) $7,290 ($5,939) ($1,104)
CZ06 SCE/SCG $583 ($43) $2,450 ($151) $775
CZ07 SDGE $583 ($3) $2,539 $747 $2,065
CZ08 SCE/SCG $721 ($96) $2,111 ($1,658) ($472)
CZ09 SCE/SCG $721 ($152) $3,022 ($2,659) ($831)
CZ10 SCE/SCG $721 ($121) $2,672 ($2,017) ($239)
CZ10 SDGE $721 $114 $2,672 $3,568 $6,801
CZ11 PGE $790 ($46) $10,682 $3,545 $18,156
CZ12 PGE $721 ($110) $10,747 $2,278 $16,574
CZ12 SMUD/PGE $721 $445 $10,747 $14,697 $29,392
CZ13 PGE $790 $1 $7,141 $3,112 $13,232
CZ14 SCE/SCG $721 ($398) $7,556 ($6,191) $1,058
CZ14 SDGE $721 ($53) $7,556 $1,909 $13,834
CZ15 SCE/SCG $859 ($25) $71 ($848) ($322)
CZ16 PGE $2,095 ($445) $22,236 $708 $37,873
2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 44 Table 27. [1978-1991] High Efficiency HPSH
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025

LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $5,998 $169 $23,092 $6,895 $39,412
CZ02 PGE $3,606 ($75) $9,242 ($1,370) $13,547
CZ03 PGE $3,422 $53 $6,872 $675 $11,602
CZ04 PGE $3,606 $26 $9,114 $463 $14,143
CZ04 CPAU $3,606 $43 $9,114 ($868) $7,590
CZ05 PGE $3,514 ($16) $4,859 ($1,522) $8,122
CZ05 PGE/SCG $3,514 ($246) $4,859 ($8,164) ($3,246)
CZ06 SCE/SCG $3,514 ($1) ($1,546) ($4,024) ($3,059)
CZ07 SDGE $3,514 $47 ($1,407) ($2,879) ($1,576)
CZ08 SCE/SCG $3,698 $37 ($828) ($3,608) ($2,300)
CZ09 SCE/SCG $3,698 ($17) $232 ($4,573) ($2,623)
CZ10 SCE/SCG $3,698 $20 $82 ($3,764) ($1,856)
CZ10 SDGE $3,698 $251 $82 $1,869 $5,060
CZ11 PGE $3,789 $259 $10,685 $5,452 $20,283
CZ12 PGE $3,698 $138 $10,023 $2,954 $17,430
CZ12 SMUD/PGE $3,698 $525 $10,023 $11,609 $26,363
CZ13 PGE $3,789 $289 $6,612 $4,624 $14,951
CZ14 SCE/SCG $3,698 ($188) $7,697 ($6,429) $1,012
CZ14 SDGE $3,698 $182 $7,697 $2,525 $14,378
CZ15 SCE/SCG $3,881 $193 ($1,111) ($992) ($267)
CZ16 PGE $5,071 ($30) $26,407 $5,118 $42,581
2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 45

6.2.2 CARE tariffs
Table 28. [Pre-1978] DFHP Existing Furnace CARE
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025

LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $2,405 $364 $25,223 $16,641 $46,300
CZ02 PGE $1,670 $64 $11,551 $6,432 $19,553
CZ03 PGE $1,178 $128 $11,680 $8,248 $19,898
CZ04 PGE $1,670 $90 $10,574 $6,198 $16,835
CZ04 CPAU $1,670 $0 $10,574 $711 $711
CZ05 PGE $1,424 $69 $9,462 $5,901 $15,746
CZ05 PGE/SCG $1,424 ($157) $9,462 ($613) $4,598
CZ06 SCE/SCG $1,424 ($37) $4,223 $776 $2,067
CZ07 SDGE $1,424 $42 $4,278 $2,609 $4,434
CZ08 SCE/SCG $1,916 ($63) $3,216 ($595) $911
CZ09 SCE/SCG $1,916 ($97) $4,238 ($1,132) $972
CZ10 SCE/SCG $1,916 ($75) $3,755 ($660) $1,379
CZ10 SDGE $1,916 $160 $3,755 $4,963 $8,500
CZ11 PGE $2,162 $183 $11,970 $8,415 $22,212
CZ12 PGE $1,916 $152 $12,302 $8,126 $21,834
CZ12 SMUD/PGE $1,916 $686 $12,302 $20,080 $34,172
CZ13 PGE $2,162 $160 $8,180 $6,595 $16,418
CZ14 SCE/SCG $1,916 ($126) $6,646 ($779) $4,233
CZ14 SDGE $1,916 $101 $6,646 $4,530 $11,652
CZ15 SCE/SCG $2,408 $60 $401 $982 $1,788
CZ16 PGE $2,243 $34 $17,538 $5,963 $24,236
2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 46 Table 29. [Pre-1978] Standard Efficiency HPSH CARE
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025

LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $3,067 $205 $27,155 $12,440 $44,777
CZ02 PGE $652 ($16) $13,342 $5,095 $20,910
CZ03 PGE $514 $76 $11,946 $6,319 $18,293
CZ04 PGE $652 $41 $13,059 $6,031 $20,843
CZ04 CPAU $652 $0 $13,059 $255 $255
CZ05 PGE $583 $12 $9,998 $4,285 $15,110
CZ05 PGE/SCG $583 ($240) $9,998 ($2,978) $2,679
CZ06 SCE/SCG $583 ($42) $3,860 ($7) $1,259
CZ07 SDGE $583 $37 $3,876 $1,837 $3,652
CZ08 SCE/SCG $721 ($75) $3,305 ($1,076) $457
CZ09 SCE/SCG $721 ($131) $4,415 ($2,095) $72
CZ10 SCE/SCG $721 ($110) $3,982 ($1,649) $504
CZ10 SDGE $721 $139 $3,982 $4,305 $8,106
CZ11 PGE $790 $94 $14,045 $7,108 $23,108
CZ12 PGE $721 $20 $13,850 $5,506 $20,829
CZ12 SMUD/PGE $721 $772 $13,850 $22,326 $38,189
CZ13 PGE $790 $89 $9,394 $5,347 $16,369
CZ14 SCE/SCG $721 ($241) $10,103 ($2,418) $5,836
CZ14 SDGE $721 $62 $10,103 $4,832 $17,541
CZ15 SCE/SCG $859 $52 $643 $930 $1,769
CZ16 PGE $2,095 $16 $27,492 $10,883 $47,907
2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 47 Table 30. [Pre-1978] High Efficiency HPSH CARE
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025

LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $5,998 $450 $30,518 $13,096 $45,609
CZ02 PGE $3,606 $126 $13,354 $3,405 $19,322
CZ03 PGE $3,422 $172 $10,768 $3,678 $15,720
CZ04 PGE $3,606 $209 $13,537 $4,926 $19,859
CZ04 CPAU $3,606 $0 $13,537 ($4,595) ($4,595)
CZ05 PGE $3,514 $103 $8,416 $1,521 $12,412
CZ05 PGE/SCG $3,514 ($148) $8,416 ($5,742) ($19)
CZ06 SCE/SCG $3,514 $11 $380 ($3,634) ($2,319)
CZ07 SDGE $3,514 $89 $430 ($1,774) $25
CZ08 SCE/SCG $3,698 $33 $1,065 ($3,586) ($1,955)
CZ09 SCE/SCG $3,698 ($10) $2,358 ($4,304) ($2,027)
CZ10 SCE/SCG $3,698 $21 $2,191 ($3,628) ($1,354)
CZ10 SDGE $3,698 $255 $2,191 $2,127 $5,893
CZ11 PGE $3,789 $327 $15,614 $7,382 $23,549
CZ12 PGE $3,698 $236 $14,490 $5,437 $20,914
CZ12 SMUD/PGE $3,698 $772 $14,490 $17,439 $33,302
CZ13 PGE $3,789 $310 $10,164 $5,378 $16,558
CZ14 SCE/SCG $3,698 ($54) $11,876 ($3,161) $5,265
CZ14 SDGE $3,698 $263 $11,876 $4,651 $17,300
CZ15 SCE/SCG $3,881 $232 $393 ($35) $970
CZ16 PGE $5,071 $360 $34,043 $13,682 $50,953
2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 48 Table 31. [1978-1991] DFHP Existing Furnace CARE
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025

LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $2,405 $273 $20,184 $12,619 $36,168
CZ02 PGE $1,670 $12 $9,142 $4,166 $13,857
CZ03 PGE $1,178 $76 $9,033 $6,011 $14,375
CZ04 PGE $1,670 $23 $8,160 $3,702 $11,261
CZ04 CPAU $1,670 $0 $8,160 $711 $711
CZ05 PGE $1,424 $40 $7,070 $4,285 $11,150
CZ05 PGE/SCG $1,424 ($122) $7,070 ($400) $3,130
CZ06 SCE/SCG $1,424 ($21) $2,941 $952 $1,705
CZ07 SDGE $1,424 $9 $3,046 $1,631 $2,667
CZ08 SCE/SCG $1,916 ($45) $2,145 ($395) $544
CZ09 SCE/SCG $1,916 ($67) $2,978 ($712) $712
CZ10 SCE/SCG $1,916 ($50) $2,606 ($357) $976
CZ10 SDGE $1,916 $110 $2,606 $3,472 $5,826
CZ11 PGE $2,162 $155 $9,118 $6,542 $16,502
CZ12 PGE $1,916 $128 $9,604 $6,434 $16,553
CZ12 SMUD/PGE $1,916 $506 $9,604 $14,879 $25,269
CZ13 PGE $2,162 $135 $6,237 $5,170 $12,318
CZ14 SCE/SCG $1,916 ($128) $4,931 ($1,351) $2,112
CZ14 SDGE $1,916 $65 $4,931 $3,123 $8,195
CZ15 SCE/SCG $2,408 ($9) ($99) ($653) ($256)
CZ16 PGE $2,243 $28 $14,397 $4,676 $19,471
2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 49 Table 32. [1978-1991] Standard Efficiency HPSH CARE
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025

LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $3,067 $146 $21,427 $8,941 $34,641
CZ02 PGE $652 ($47) $10,428 $3,076 $14,864
CZ03 PGE $514 $33 $8,999 $4,259 $12,882
CZ04 PGE $652 ($10) $9,984 $3,558 $14,338
CZ04 CPAU $652 $0 $9,984 $255 $255
CZ05 PGE $583 ($18) $7,290 $2,586 $10,196
CZ05 PGE/SCG $583 ($199) $7,290 ($2,659) $1,219
CZ06 SCE/SCG $583 ($24) $2,450 $215 $956
CZ07 SDGE $583 $6 $2,539 $898 $1,929
CZ08 SCE/SCG $721 ($57) $2,111 ($896) $57
CZ09 SCE/SCG $721 ($91) $3,022 ($1,455) $13
CZ10 SCE/SCG $721 ($71) $2,672 ($1,035) $390
CZ10 SDGE $721 $96 $2,672 $2,939 $5,474
CZ11 PGE $790 $74 $10,682 $5,209 $16,830
CZ12 PGE $721 $30 $10,747 $4,418 $15,794
CZ12 SMUD/PGE $721 $573 $10,747 $16,567 $28,332
CZ13 PGE $790 $72 $7,141 $4,003 $12,047
CZ14 SCE/SCG $721 ($224) $7,556 ($2,880) $2,930
CZ14 SDGE $721 $42 $7,556 $3,476 $12,809
CZ15 SCE/SCG $859 ($13) $71 ($639) ($219)
CZ16 PGE $2,095 ($25) $22,236 $7,529 $37,120
2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 50 Table 33. [1978-1991] High Efficiency HPSH CARE
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025

LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $5,998 $339 $23,092 $8,460 $34,300
CZ02 PGE $3,606 $57 $9,242 $547 $12,409
CZ03 PGE $3,422 $111 $6,872 $1,228 $9,907
CZ04 PGE $3,606 $113 $9,114 $1,472 $12,340
CZ04 CPAU $3,606 $0 $9,114 ($4,595) ($4,595)
CZ05 PGE $3,514 $58 $4,859 ($544) $7,120
CZ05 PGE/SCG $3,514 ($124) $4,859 ($5,789) ($1,857)
CZ06 SCE/SCG $3,514 $5 ($1,546) ($3,963) ($3,196)
CZ07 SDGE $3,514 $39 ($1,407) ($3,143) ($2,122)
CZ08 SCE/SCG $3,698 $32 ($828) ($3,800) ($2,766)
CZ09 SCE/SCG $3,698 ($0) $232 ($4,336) ($2,784)
CZ10 SCE/SCG $3,698 $25 $82 ($3,803) ($2,290)
CZ10 SDGE $3,698 $184 $82 $124 $2,631
CZ11 PGE $3,789 $272 $10,685 $4,725 $16,488
CZ12 PGE $3,698 $191 $10,023 $3,148 $14,639
CZ12 SMUD/PGE $3,698 $573 $10,023 $11,680 $23,445
CZ13 PGE $3,789 $259 $6,612 $3,262 $11,441
CZ14 SCE/SCG $3,698 ($82) $7,697 ($4,629) $1,311
CZ14 SDGE $3,698 $195 $7,697 $2,166 $11,452
CZ15 SCE/SCG $3,881 $133 ($1,111) ($2,349) ($1,794)
CZ16 PGE $5,071 $245 $26,407 $8,685 $38,470
2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 51

6.3 Utility Rate Schedules

6.3.1 Pacific Gas & Electric
The following pages provide details on the PG&E electricity and natural gas tariffs applied in this study. Table 34 describes the baseline territories that were assumed for each climate zone. A net surplus compensation rate of $ 0.03396/ kWh was applied to any net annual electricity generation based on a one-year average of the rates between February 2024 and January 2025.

Table 34. PG&E Baseline Territory by Climate Zone
Climate Baseline
Zone Territory
CZ01 V
CZ02 X
CZ03 T
CZ04 X
CZ05 T
CZ11 R
CZ12 S
CZ13 R
CZ16 Y
The PG&E monthly gas rate in $/therm was applied on a monthly basis according to the rates shown in Table 35. The gas rates were developed based on the latest available gas rate for January 2025 and a curve to reflect how natural gas prices fluctuate with seasonal supply and demand. The seasonal curve was estimated from PG&E’s monthly residential tariffs between 2015 and 2024. 12-month curves were created from monthly gas rates for each of the ten years. The ten annual curves were then averaged to arrive at an average normalized annual curve. The baseline and excess transmission charges were found to be consistent over the course of a year and applied for the entire year based on January 2025 rates. The costs presented in Table 35 were then derived by establishing the baseline and excess rates from the latest January 2025 tariff as a reference point, and then using the normalized curve to estimate the cost for the remaining months relative to the January rates.

Corresponding CARE tariffs reflect the 20 percent discount per the GL-1 tariff. 2025/06/09
Attachment 1

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 52 Table 35. PG&E Monthly Gas Rate ($/therm)
Month Total Charge
Baseline Excess
January $2.63 $3.15
February $2.64 $3.16
March $2.41 $2.94
April $2.24 $2.77
May $2.21 $2.74
June $2.23 $2.77
July $2.26 $2.80
August $2.36 $2.90
September $2.42 $2.98
October $2.52 $3.07
November $2.63 $3.17
December $2.70 $3.23
2025/06/09
Attachment 1

ial
GAS
Baseline Territories and Quantities 11
Effective A ril 1, 2022 • Present
BASELINE QUANITTIES (Therms Per Day Per Dwelling Unit)
lndividualli Metered
Baseline Summer Winier Off-Peak
Territories (April-October) (Nov, Feb, Mar)
Effective Al!r, 1, 2022 Effective Nov. 11 2022
p 0.39 1.88
Q 0.56 1.48
R 0.36 1.24
s 0 39 1.38
T 0.56 1.31
V 0.59 1.51
w 0.39 1.14
X 0.49 1.48
y 0.72 2.22
Master Metered
Baseline Summer
Territories (April-October)
Elfecllve Apr. 1, 2022
p 0.29
Q 0.56
R 0.33
s 0.29
T 0 56
V 0.59
w 0 26
X 0.33
y 0.52
Summer Season: Apr.Oct
Winter Off-Peak: Nov, Feb, Mar
Winier On.Peak: Dec, Jan
Advice Leiter: 4589-G
Decision 21 -1 1-016
GRC 2020 Ph II [Application 19-11 -019]
Filed: Nov 22. 2019
Winter Off-Peak
(Nov, Feb, Mar)
Effective Nov. 1, 2022

1.01 0.67

0.87 0.61

1.01 1.28

0.71 0.67

1.01 Winter On-Peak
(Dec, Jan)
Effective Dec. 11 2022

2.19 2.00

1.81 1 94

1.68 1.71

1.68 2.00

2.58 Winter On-Peak
(Dec, Jan)
Effective Dec. 1, 2022

1.1 3

0.77 1.16

0.65 1. 10

1.32 0.87

0.77 1.13
Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 53 2025/06/09
Attachment 1

Gas and
Electric Compa.ny·
U 39 Oekland, Gafifomia
Revised
cancelling Revised
Gal. P.UC. Sheet No.

Gal. P.U.C. Sheet No.
5912().E
58758-E
EIUECTRIC SCHEDULE E-TOU-C Sheet 2
RESIDENTIAL TIME-OF-USE (PEAK :PRICING 4 - 9 p.m. EVERY DAY) RATES: (Cont'd} E-TOU-CTOTAL BUNDLED RATES
Total Energy Rates ($ per kWh)
Summer
Total Usage
Baseline Credlt (Applied to Baseline Usage Only)
\Mnter
Total Usage
Base1tne Credit (Applied to Baseline Usage Only)
Delivery Minimum Bill Amourrt ($ per meter per day)
California Climate Credit (per household, per semi­ annua1 payment occurring in the Apnl and October bill cycles}

PEAK OFF-PEAK
ro.oong (R ) S0.50429 (R)
($0.10135) (R ) (SO 10135) (R)
$0.49312 (R ) S0.46312 (R )
($.0.10135) (R ) (S0.10135) (R )
$,0.39167
($58.23) ,(R)
Total bund ed: service charges shO'Wll on customer s bills are unb 111dled according to the component rates shOWTil, below. lMlere the del1very minimum bi[I ammmt appr es, the ,customer's bill wi[I equal tile sum of (1 ) lhe delivery minimum bill amount plus (2) for bundled service, the generation rate times the number of kWh used. For revenue aroounling purposes, tile revenues from the delivery minimum bi[I amount wm be assigned to the Transmission, Transmission Rate Adj;ustments, Reliability Services, Public Purpose Programs, Nuclear Derommissiontng,, Competition Transition Charges, E111ergy Cost Recovery Amount, Wil'.dfire Fund Ciharg:e, arnd New System Generation Charges based on kWh usage times the correspmding unbundled rate compo111ent per kWh, with any residual revenue assigned to Distribution.

Advice 7469-E
Dedsion
Issued by
Shi/pa Ramaiya
Vice President
Regulatory Proceedings ana Rates
Submitted
Effective
Resolution
(Continued)
December 30, 2024
January 1, 2025
Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 54 2025/06/09
Attachment 1

Gas and
Elec.tric Company" Revised
Cancelling Revised
Gal. P.U.C. Shee.t No.

Gal. P.U.C. Shee.t No.
u 39 Dakland, Galifomia
ElJECTRIC SCHEDULE E-TOU-C Sheet 3
IRESIDENT AL TIME-OF-USE (PEAK PRICING 4 - 9 p.m. EVERYDAY) RATES: (Cont'd.) UNBUNDLING OF E-TOU-C l OTAL RAlES
5nergy Rates by Com,ponent (S pe:r kWh)
Generation:

Summer (a'II usag.e)
Wi:nter (al l usage)
Distribution••.:

Summer (a'II usage)
Wi:nter (all u,sage)
PEAK
$0.24730
$0.18725
$0.24056
$0.HIM 5
Conservation Incentive Adj'u,stment (Basel ine Usage)
Conservation Incentive Adjlllstment (OYer Baseline Usage) T,ransm·ission* (all u.sage)
Transmission Rate Adjustments• {am usage)
Reliability Services•· (a us age)
Publ'lc Purpose Programs (all usage)
Nuc,lear Decommissioning (all usage)
Competition Transition Charges (all usage)
Energy Cost Recov-e:ry Amou rrt (all usage)
Wfldlire Fund Charge (all usage)
New System, Generation Charge (all usage)""
Wrldlire Hardening Charge (a I usage)
Recove.ry IBond Charge-(a'II usa,9e)
Recove.ry IBond Credit (all usage)
Bundled Power Charge I ndifferem:e Adjus1ment (al usage)~ .. (I)
(I)
(I)
(I)

OFF-PEAK
$0. 16430
$0. 16057
$0.22056
$0.18313
(S0.03733) (I}
S0.06402 (I)
S0.051 22 (I)
(S0.0 1509) (R )
S0.00032 (I}
S0.02tl44 (R )
(SO.OC>D•13) (I}
(S0.000 172) (R )
so.0000 1 (I)
S0.00595 (I)
S0.005,74 (R )
S0.00494
SO.OC>650
(SO.OC>650)
(S0.02327) (R )
(I)
(I)
(IJ
(I)
.. Transmission, Transmission Rate Adjustments and Reliability Service charges are combined tor pFesentation on customer bills, H Distribution andl Mew System Generation Oharges are combi ed for presentation on customer lbfllls . • ,.. Direct Access, Commu ity Choice AggreQ!iltion and Transilional Bundled Service customers pay th.e .applicable Vintaged Power Chafge lnoifference Adjustment. Generation and BuncUed PCIA aFe combined for presentation on bundled customer bills. 59121-E
58759-E
(Continuecl)
Advice
Decision
7469-E Issued by
Shilpa Ramaiya
Vice President
Regulatory Proceedings and Rates
Submitted
Effective
Resolution
December 30. 2024
January 1. 2025
Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 55 2025/06/09
Attachment 1

Gas and
Electric ,Company·
Revised
Cancelling Revised
Caf. P.U.C. Sheet No.

Caf. P.U.C. Sheet No.
59109-E
58755-E
U 3.9 Oakland, Ga!ifomia
ELECTRIC SCHEDULE E-ELEC Sheet 2

RESIDENTIAL TIME-OF-USE (ELECTRIC HOME)

SERVICE FOR CUSTOMERS WITH QUALIFYING ELECTRIC TE CHNOLOGIES RATES :{Con.t'd .)
Direct Access (DA) and Community Choice Aggregation {CCA) charges s ha~ be calrula!ed in accordance with the paragraph in this rate schedul e 1i!i1ed Bi ling.

TOTAL BU NDLED RATES
Base Services Charge ($ pe, me er per day) $0.4Q2S1
Total Em,.-QiY Rates ($ per kWh) PEAK PP.RT-PEAK OFF-PEAK Summ er Usage $0.60728 (R) ll0.44540 (R ) $0.38872 (1R) Win er Usage $0.375n {R) $0.35368 (R ) $0.33982 {R )
Cs i omia Cfima e Credit (per hou ,;e'hold, per
semi-annual paym ent occurring in the Apri l an,d
October bill cycles)
($58.23) (R)
Total trundled service ch arges shown on a. custome,'s bi Is are un bundlied according to lhe co111ponen.t rates sh own below.

UNBUINDLING OF TOTAL RATES
En ergy Rates by Compone:nl ($ per· kW h) PEAK PP.RT-PEAK OFF-PEAK Gene.ration:

Summer Usag,e- $0.3 165-ll (I) $0-21748 (I) $0.17238
Winter 'Usage $0.15446 (I) $0. 13449 (I) $0.12 114
Distribution••:

Summer Usagoe- $0.23528 (I) $0. 1725 1 (I) $0.16093
Winter IIJsa.ge $0.1651l0 (I) $0. 16378 (I) $0.16327
Transm ission,• (all usa.g:e) $0.05 1122 (I) $0.05122 (I) $0.05 122 Transm ission, Rate Adj u,stm ents• (s I usage) ($0.0 1501l) (R) ($0.01 509) (R ) ($0.0 1501l) Reli ab il ity Services• {all usagoe) $0.00032 (I) $0.00032 (I) $0.00032 Public Pu rpose Programs ,(all usag e) $0.02644 (R) $0.02644 (R ) $0.02644 Nluc lear Decommission ing (all usage} ($0.00013~ (I) ($0.000 13~ (I) ($0.00013~ Competition Transition Charges (all usagoe") {$0.00072 (R) ($0.00072 (R ) ($0.00072 IEner g;y Cost Recover;y A mou nt {all usage) $0.00001 (I) $0.0000 1 (I) $0.00001 Wildfire Fund Charge (al usage) $0.005Q5 (I) $0.00595 (I) $0.005g5 Nlew Syst em Generation Char ge (a I usage}" $0.00574 {R) $0.00574 (R ) $0.00574 Wildfire Ha:rder,ing Charge (all usage) $0.0049'4 $0.00494 $0.00494 IRecov er;y Bond Charge (all usage) $0.00650 S0.00650 $0.00650 IRecover;y Bond Credit (all ,usage) ($0.00650l ($0.00650~ ($0.00650~ Bundled Power C harge Indifference {$0.023-27 {R) ($0.02327 (R ) ($0.02327 Adjustmen t (al l usage}"'
Transmissiom. Transmission Rale Adjustments and Rel" ·1ity Se.rvice ch~ are combined for p,esen ation on cusAorner bills.

Dis ·bulioo and N,ew System Generation Ciharges e combined fur presentation on ru~torner bills.

Direcl Access. Community Cboice Aggregation amd Transition Bum.med Se<Vice Customers pay 1tte applicabl.e Vimiaged P.ower Charge Indifference Adjus1ment. Gemeration ar>d Bundled PC IA are combined for presentation oo bundl'.e,d custcmer bills.
(I)
(I)
{I)
(I)
(I)
(R }
{I)
(R }
(I)
(R }
(I)
{I)
(R }
(R }
{Continued)
AcMce
Decision
7469-E Issued by
Shi/pa Ramaiya
Vice President
Regulatory Proceedings and Rates
Submitted
Effective
Resoiutfon
December 30, 2024
January 1, 2025
Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 56 2025/06/09
Attachment 1

Gas and
Electric ,Compan(
Original ca,: P.UC. Sheet No. 54738-E
U 39 San FrancisC(); Cafitomia
ELECTRIC SCHEDULE E-ELEC Sheet 3 (N)

RESIDENTIAL TIME-OF-USE (ELECTRIC HOME) (N)
SERVICE FOR CUSTOMERS WITH QUA!LIFYING ELECTRIC TECiHNOLOOllES SPECIA L 1. TIME PERIODS: Tim es ofli'le year and ( mes of !he day are defined as fol ows:

CON DITIION S:

Advice
Decision
All Year:

Pee : 4 :00 p.m. to Q:00 p.m. ~ery day in:cludin,g weekends and lu:J idays.

Partial-Peak: 3:0D p.m . to 4 :00 p.m. an d Q:00 p.m. to 12:00 a.m. e·very day includin11 weekends .end oo 1d!sys .

Olf-Pes_ : All olhe.r hours.

2. SEASONAL CHANGES: T1he summ er season is Ju:ne 1i 1hrough Septem ber 30 and t he ~,inter s,a-ason is October 1 lhroug'h May 3,1. When b·lrng include.s use ·n both lhe summer and winter periods, charges will be pra-ated based u:pon t he num be.r of days in e<acli pe.iod.

3. A DD ITIONAL METERS: If a re.siden ·s1 dwelling unit is served by more t han -o.ne electric meter. t he cuslomer must desilJnat,a-whl ch meter is lhe primary me er an.d which is (are) he addition.al meter(s).

4. Bl LLING : A custo:mer"s b.11 is csJculs.ted based on lhe oplion applicable to the custo:mer.

Bundled Servi.Ce Cu.stomers receive generation and delivery seniice.s solely from PG&E. The custo:mer"s b.11 is based on the U nbun.dling o Total Rates set orth .above.

Tr-ansiliona Bund ed Service (TBS) Customers take TBS as p:rescribed in Rules 22 .. 1 and 23,. 1. or tak•e PG&E bundled service prior to the end oi li'te· six (6) m on1h advance notice period required to eleci PG&.E bundled service as prescn."bed in Rules 22 .. 1 and 23,.1. TBS ,cust arners shall pay all charges soown in !he Unbundling ,of Total Raf es -excep or ·lne-Bund d Power Charge In.difference Adj ustme.nt andl !he gen eralion charge. TBS cuslomers shall also pay fo:r their a,pplica'ble Vi:n aged lf>,ower Charge Indifference Adj,:,isbn-e,nt provided in the table bel ow. a:nd t he short.term comm odity prices as set forth in Schedule TBGC.
(N)
(Oontim.100)
6768-E
D.21-11"0116
Issued by
Meredith Allen
Vice President, Regufato,y Affairs
Submitted
Effective
Resolution
November 18, 2022
December 1i. 2022
Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 57 2025/06/09
Attachment 1

cific Gas and
Electtic Companf Revised
Cam;e/11119 Revised
Cal. P_U'..C. Sheef MJ_
Cal. P_LJ'..C. Sheet MJ_
59329-E
50086-E
U 39 Oakland. CalifDmia
ELEC11RIC: SCHEDULE O.CAR!E Sheet 1
LI.NEJITEM DISCOUNT FOR CAUFORiNIA. Al TEIRiNA TE RA TES FOR EJNERGY (CAR;E)

CUSTOMBRS
AW,llCABILITY: This sched is applicable to singl~ese and pol~se re-sidential .service in single-famiJy dK'Elinga and i111 flalll and apeltmEti lll separatEfy rnelefed by PG&E and domeslic i;;:ub1111eterad tenants r,es.iding -n ul 1ila rmyaccom1111odal 11.S . mohileh□1111e perks and to q,u ifying recraa □n al vehide ?SllB and mSJ!Das ,BIil! 11D fBrm servi.ae on lhe premise5i opa-ated by me person Ml se re-sidence is i;;:uppied llrurc!qjh lh.e same 1111e er. Where ·Ille applicant qu: es for California Alternate Raisa or Enet'QIY (CA.RE) ul!lder lhe ,eligibiity and celtifica!io111 ,c::ritetria set forth in l:!lectllicRuie 19.L CARiE ser,,ice is avai le on SclriedUlea E-1. E-TOU-B.

E-TOLJ-C. E-TOLJ-0. EV2. E-ELEC. EIM\ IES. ESR. ET &11d IEM-TOU_ TERiRITORY: This rate schedute ,applies eVEl"'J!Nhetre PG&E j!rowles electric seMCB..

RAT1ES: Cusllllrnars takimg ear.ice oo 1lili5i rale schedule whose 01Jrleiwisa BJ1pliceille rate sched h.as no IDeivetry inmum Bill Amounl (Scln.ecMe IE-ELEC) wil reoaiYe a CAIRE petraelllege dioootnt of 38.351% (IR) on lheir at.al bundled ,charges (exoepl for the Califolllllia Climate Cradi . id! ·will not be discoonted) .. Customers tIDamg SEHrvioe oo lhia rate 6-Chedule whose olherwise appica}!je rate .schedule has a Oeivet!)' Minimum Bill Amount (al other sched'ule!i) will receive ,e CAIRE percentage discount r p;: or "C" below) on llrles at.al bundled ,charges less charges from wtach they are e:,;e!11lt (Wildm,e IFumd Cherg/31, IRE!CO'o'BI'}' Sood Cl1arge.

ReGOYB[)' B«ld Credit, and he C/!IRJE i;;:urdlerge poltion of the p.iblic purpose i-ogram charge used o fund Iha CAIRE diSCOO!it) oo ·lfle.ir odrlEtwise .eppliceille rate scli,edule (e,ooept ·for Iha C oonia Cli1111ete Cre,:f • l!lhim will nal be disoou111.ted) 811d also wil reoaive a ~ disoounl ("iB" or "O' below) oo he deli'le.ry 1111inimum ~ B11T1 u111.t. if applicable_ The CARE dis.couni wil be calcueted for direct acoesa and com1111unity choice e,ggregatio111 aJSlomers based on 1lne tot.al charges es if lhey were i;;:umjecl o, bundl seMOe rales. Oioootnlll will be applied as ,e reduction o, disiribuiioo ,merges. These oondi ions also ,eppl:;o to maslBrmeier-ed oustorne1E and lo, quali 1ed Elm-metered IBnants wlrLetre he master-meter customer is jcintly seNe<I ul!lder PG&E'a Ra e Sdnedule D-CAIRE ,end either Scl!,edule EM, ES. ESR. ET. or EIM-TOU.

Adwoe 7"516-E
Oecision
For 1111estE!t'-me ered oost 1111ers where one or more of the subme ered tenenlls qualifies ror CAIRE rste!l uJ!ldEJ he eligibiJJly and aertificati n critetlia .set forth in Rule 119.. 1. 19.2. or 19.3. lln.e CARiE disooulll is equal ·to a perae1111!ege (~c· below) m the otal bundled merges. 1111Ultiplied by he nurmer of CARiE units cf"IVide<I D')' lln.e to1BI 11UJJT1ber of unilll. In add , 1111ester-m.eterad customera eligible for O'-C.ARE wil reoaiYB a pernetlltag;e disoounl or below) on lhe deli,YBI)' millWllUIITl bill am001t, if .ep,pliceille.

II is lhe r~pa11.Sibility of he master-me ered wstomer ID ,advise PG&E within 15 days ·follwmg any dtlange in lhe nu1111bet' of d'welq units and/or any decrease in me nu1111iletr of q,ualifyi1119 CARiE applicants ltiat resullll wf:ten sud! ewlicants move out of heir swmetef8d or ooo-subrnetered dwellq unit. or i;;:ub1111eterad permane1111-reaide11oe RV or per1111enent-msidence ooa.t lssuedby
Shi tpa Ramaiya
Vice F:re.sidertl:

Regulalo,:y ProoeadingB and Rales
S-ubmitted
l!:tfecm,a
ili!esal!Jtioo
(Con.ti111Ued}
Fe'brue!)' 26, 2025
Meroh 1, .2025
Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 58 2025/06/09
Attachment 1

Gas and
Electdc Campanv· Cancel/frig
Revise
Revise
Cal. P.IJ..C. S'heeJ MJ.

Cal. fi'.U.C. S'heeJ MJ.
50087-E
58198-E
U 39 OaMand, California
Ei1LEC11RIC SCHEDULE D.CARiE Sheet 2
LINE-ITEM DISCOUNT FOR CAUFO~IA Al T18RJNA TE RA TES FOR ENERGY (CAR!E)

CUSTO BRS
A. D-CARE Disooullll:

B. Deiveqr Miwnim Bill Disooulll:

C. taster-Meter 0-C.ARIE Discoont:

D. t.1.asl er-Meter Delivery MiJlli,mu,m
Bill Discount:
3!lu000
S0..000
as..,ooo
so.,ooo
% (Percent} (II
% ~P,erc:ent)
% ~P,erc:ent} (I)
% (Percent}
SPECIAL 1. OTI-IERWISE APiPLICA.filE SCHEDULE: Th.e Speci Candi iall1.8 of ·the CO DJTIONS: Customer's. otherwis.e ewlicable rate schedule Ml apj!ly to this. sr:hedula Advioe 7'469-E
Oeci.s-ioo

2. BLIGIBILITY: To be efigible to receive D-CARE the applicant lillllSt qualify undE!lf 1he criteria s.et ·fol1lrl in PG&E's IBlecillic Rules 1 Q_ 1. 19-2. aJl1d 19.3 .ellld meet llne oertifica - n requirements hereof l.o 1he selisfactioo of PG&E ,Quatifying Daect Aooes5!., Community Chai.OB Aggreg,;Uioo Setl'llioe, BM TrsnsiliooSI Bundled Servioe custo,me1a are also ,eligiNe in, im:s s.ervica on Sdnedule D-CA.RE Af1plice11J 1, rnay qµaify fur D-CAIRE .el their primary residence ol!lly. Cu'Sl arnera or au , l'lllll1.a-ed anBlll1!i panicipating in lln.e Famiy Electric Rate A.ssistanoe (FERA,\ pragll'Bm ,cannot ooncurrsruly panicipale m he CARE J]fOgl'am. (B,, /Jedby
S-bilpa Rameiya
VH:e PTesidellt
Regulalt:Ny Proaeeding,s and Rates
Svbmitted Deoernbe.r 30, .2024
f':.fmctivs Janu811V 1 . . 2025
"1eoolution
Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 59 2025/06/09
Attachment 1

Summer Daily Allocations (June through September) Winter Daily Allocations (October through May) AllDaily kWh Electric
Baseline Region Number Allocation Allocation Baseline Region Number 5 6
8 9
10 13
14 15
16 17.2 17.9

11.4 8.8

12.6 9.8

16.5 12.4

18.9 15.8

22.0 24.6

18.7 18.3

46.4 24.1

14.4 13.5

SPECIAL CONDITIONS
5 6
8 9
10 13
14 15
16 Schedule TOU-D

TIME-OF-USE

DOMESTIC
(Continued)

1. Applicable rate time periods are defined as follows:

Option 4-9 PM. Option 4-9 PM-CPP. Option PRIME. Option PRIME-CPP :

Sheet 12
TOU Period Weekdays Weekends and Holidays
Summer Winter Summer Winter
On-Peak 4 p.m. - 9 p.m. NIA NIA NIA
Mid-Peak NIA 4 p.m. - 9 p.m. 4 p.m. - 9 p.m. 4 p.m. - 9 p.m.

Off-Peak All other hours 9 p.m. - 8 a.m. All other hours 9 p.m. - 8 a.m.

Super-Off-Peak NIA 8 a.m. - 4 p.m. NIA 8 a.m. - 4 p.m.

CPP Event 4 p.m. - 9 p.m. 4 p.m. - 9 p.m. NIA NIA Period AllDaily kWh Electric
Allocation Allocation

18.7 29.1
11 .3 13.0

10.6 12.7

12.3 14.3

12.5 17.0

12.6 24.3

12.0 21 .3

9.9 18.2

12.6 23.1
(T)
(T)
Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 60

6.3.2 Southern California Edison
The following pages provide details on the SCE electricity tariffs applied in this study. Table describes the baseline territories that were assumed for each climate zone. A net surplus compensation rate of $ 0.01532/ kWh was applied to any net annual electricity generation based on a one-year average of the rates between February 2024 and January 2025.

Table 36. SCE Baseline Territory by Climate Zone
Climate
Zone
Baseline
Territory
CZ06 6
CZ08 8
CZ09 9
CZ10 10
CZ14 14
CZ15 15
2025/06/09
Attachment 1