Cities Index.
Agenda packet

Los Altos Hills City Council
November 20, 2025

Document
Agenda packet
Meeting
November 20, 2025
Body
Los Altos Hills City Council
Pages
775
Original file
149.3 MB
Text extracted from the city's file for reading and search. Open the original on losaltoshillsca.api.civicclerk.com. That file is the official record.

ITEM 5I ATTACHMENT 5

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ITEM 5I ATTACHMENT 5

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ITEM 5I ATTACHMENT 5

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Permit Inspections
Town of Los Altos Hills

LIST OF INSPECTIONS
SEQ

ID SCHEDULED DATE COMPLETED DATE TYPE INSPECTOR RESULT REMARKS

UNDERGROUND
SEWER
ROBERT

JOHNSON
Notes:
1/25/2023 1/25/2023 FOUNDATION CSG INSPECTOR PARTIAL Live Babak Notes:

Needs letter from Engineer, soils engineer and survey letter. 2/7/2023 2/8/2023 UNDERSLAB
PLUMBING CSG INSPECTOR PASS Live Babak
Notes:

NEEDS TO SUBMIT CHANGES TO LAYOUT. ( MOVED SINK FROM WALL TO ISLAND, REMOVED WASHER/DRYER) 2/14/2023 5/23/2023 FOUNDATION CSG INSPECTOR PASS Live Babak Notes:

RECEIVED LETTER FROM SURVEYOR, SOILS AND EOR
2/15/2023 2/16/2023 SLAB STEEL CSG INSPECTOR PARTIAL Live - PM Notes:

NEEDS EOR LETTER
2/20/2023 5/23/2023 SLAB STEEL CSG INSPECTOR PASS Live Babak Notes:

RECEIVED LETTER FROM EOR
5/23/2023 5/23/2023 EXTERIOR SHEAR
WALL HOLDOWNS CSG INSPECTOR PARTIAL Live Babak
Notes:

PENDING LETTER FROM EOR
5/23/2023 5/23/2023 ROOF NAILING CSG INSPECTOR PASS Live Babak Notes:

Permit Number: BLD22-0204
Site Address: 25975 ALICANTE LANE
City, State Zip Code: LOS ALTOS HILLS, CA
Applied: 5/5/2022 Approved: 11/23/2022
Issued: 11/23/2022
Parent Permit:

Parent Project:

Applicant: ÇAGATAY GÖKSEL
Owner: FRANK ILAN
Contractor: VIA BUILDERS INC
Description: REPLACE EXISTING ADU WITH NEW ADU
Finaled:

Status: EXPIRED
Details:

Printed: Wednesday, 12 November, 2025 1 of 3
ITEM 5I ATTACHMENT 5

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Permit Inspections
Town of Los Altos Hills
11/9/2023

GRADING

MORATORIUM

INSPECTION

ASTHA KHANAL CORRECTIONS
Notes:
11/21/2023

GRADING

MORATORIUM

INSPECTION

ASTHA KHANAL PASS
Notes:
11/28/2023 1:30
PM 11/28/2023 ROUGH ALL TRADES CSG INSPECTOR PASS Live - PM - Jenny 650-948-1077 Notes:
need EOR letter for framing
12/6/2023 2:00
PM 12/6/2023 ROUGH FRAME BABAK MADANI CSG PASS PM Jen 650-948-1077 Notes:
1/9/2024 PM 1/9/2024 627 BLD STUCCO
LATH

BABAK MADANI
CSG NOT READY Jen 650-948-1077
Notes:
1/17/2024 1/17/2024 602 BLD

PROGRESS

BABAK MADANI

CSG PASS PM
Notes:

Insulation
2/1/2024 1:00
PM 2/1/2024 627 BLD STUCCO LATH Chris Brown PASS PM Jenny 650-948-1077 Notes:
2/5/2024 8:30
AM 2/5/2024 622 BLD DRYWALL NAILING 4Leaf Inspector CANCELED PM Jenny 650-948-1077 Notes:
2/12/2024 01:00
PM 2/12/2024 622 BLD DRYWALL NAILING Chris Brown NOT READY PM Jenny 650-948-1077 Notes:
2/15/2024 01:00
PM 2/15/2024 622 BLD DRYWALL NAILING Chris Brown PASS PM Jenny 650-948-1077 Notes:
2/21/2024 01:00
PM 2/21/2024 629 BLD TUB SHOWER PAN Chris Brown PASS PM Jenny 650-948-1077 Notes:

Printed: Wednesday, 12 November, 2025 2 of 3
ITEM 5I ATTACHMENT 5

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Permit Inspections
Town of Los Altos Hills
6/13/2024 PM 6/13/2024 602 BLD
PROGRESS Chris Brown PASS
Notes:
1/29/2025 AM 1/29/2025 PM
204 ENG GRADING

MORATORIUM

INSPECTION

SAL BISSADA PARTIAL
Notes:

Grading Moratorium Inspection.

Printed: Wednesday, 12 November, 2025 3 of 3
ITEM 5I ATTACHMENT 5

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TOWN OF LOS ALTOS HILLS November 20, 2025
Staff Report to the City Council
SUBJECT: RESOLUTION GRANTING REQUEST FOR EXTENSION OF THE

EXPIRATION DATE FOR A BUILDING PERMIT FOR ENTIRE HOME

RENOVATION AND ATTACHED OFFICE ROOM, LANDS OF EUGENE
AND SHIRLEY, 23475 CAMINO HERMOSA DRIVE, BLD22-0322
PREPARED BY: Tim McBirney, Community Development Analyst FROM: Jay Bradford, Community Development Director
APPROVED: Cody Einfalt, Acting City Manager
RECOMMENDATION: That the City Council:

Adopt the resolution (see Appendix 1) approving the extension request for Building Permit #BLD22-0322 with a new expiration date of November 20, 2026.

DISCUSSION:

The property owner is requesting an extension of Building Permits #BLD22-0322 at 23475 Camino Hermosa Drive that was originally issued on November 29, 2022. See Appendix 2 for a copy of the request.

The applicant notes, this project experienced delays due to longer than expected finalization of interior design. New residence construction is limited to 18 months following the issuance of the building permit if the estimated value of the project is between $0 to $250,000. See Los Altos Hills Municipal Code, Title 8, Section 10.04 (https://ecode360.com/43997785), which shows the time limitations set by project type and value. Since the estimated value of the project is between $0 to $250,000, the building permits expired on May 29, 2024.

The Construction Time Limits Ordinance does allow the extension of time limit by two six- month extensions if the extension request is made in the allotted time as described in Section 8-10.04. For this request, however, the City Council must consider the extension as all other extension options have been exhausted. The applicant has submitted a request for an extension for up to a year to complete the work, which is their first extension request. A copy of the inspection record for the project is attached as Appendix 3 to help give a better understanding of the project progress.

Staff recommends granting an extension to allow for additional inspections necessary for project closeout.

With this approved permit extension, the applicant will have a year from City Council’s approval of this request to complete the project. Following a year, if the remaining scope of work and inspections have not been completed, the applicant will have to pay the final deposit bond in an amount equal to the lesser of 10% of the estimated cost to complete the project, as determined by the Building Official, or $50,000 for which if they exceed the extension’s time limit, the applicant will face penalties again. In addition, they will be required to apply for another permit extension.

The above project, if approved, would result in a one-year extension from the date of the City Council’s approval. The approved permit extension resolution would supersede any related conditions of approval in the planning entitlements and permitting compliance dates.

ITEM 5I ATTACHMENT 6

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City Council
23475 Camino Hermosa Drive
November 20, 2025

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ENVIRONMENTAL REVIEW:

The proposed request is exempt from the provisions of the California Environmental Quality Act (CEQA) pursuant to Section 15061(b)(3), which exempts actions that can be seen with certainty will not cause significant environmental impacts.

FISCAL IMPACT:

There is no fiscal impact associated with these time extension requests as the applicant pays a fee for service covering the Town’s costs.
2024-25 CITY COUNCIL WORK PLAN:

This is not part of the 2024-25 City Council Work Plan as extensions are, depending on applicability, part of the standard site development approval process.

APPENDIX:

1. Resolution Approving Time Extension for 23475 Camino Hermosa Drive, Building Permit #BLD22-0322

2. Building Permit Extension Request

3. #BLD22-0322 Inspection Record
ITEM 5I ATTACHMENT 6

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City Council
23475 Camino Hermosa Drive
November 20, 2025

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RESOLUTION ____-25

A RESOLUTION OF THE CITY COUNCIL OF THE TOWN OF LOS ALTOS HILLS

APPROVING A TIME EXTENSION OF AN APPROVED BUILDING PERMIT FOR

CONSTRUCTION OF DETACHED ADU
WHEREAS, Mariani Eugene E & Shirley F Trustee (“Owner”) owns the property commonly known as 23475 Camino Hermosa Drive, Los Altos Hills, California (APN 336-37-001); and WHEREAS, the building permits #BLD22-0322 for a new main residence basement and a new pool house conversion to an ADU were issued on November 29, 2022, with reasonable conditions of approval; and
WHEREAS, the permits expired on May 29, 2024, as the Town has adopted a Construction Time Limits Ordinance and, pursuant thereto, sets an expiration date for Building Permits for new dwellings and remodels with additions with a project valuation between $0 and $250,000 at eighteen (18) months; and
WHEREAS, pursuant to the Construction Time Limits Ordinance, the City Council has the authority to grant reasonable extensions of time for Building Permits that have expired; and WHEREAS, the Town generally grants time extensions of one (1) calendar year; and NOW, THEREFORE, BE IT RESOLVED the City Council of the Town of Los Altos Hills does hereby approve on behalf of the Owners, a one (1) year Time Extension of approved Building Permit #BLD22-0322, subject to the originally adopted conditions.

The above and foregoing Resolution was passed and adopted by the City Council of the Town of Los Altos Hills at a regular meeting held on the 20th day of November 2025 by the following vote:

AYES:

NOES:

ABSTAIN:

ABSENT:

BY: _______________________________
Kavita Tankha, Mayor
ATTEST: ______________________________
Arika Miller, City Clerk
ITEM 5I ATTACHMENT 6

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Permit Inspections
Town of Los Altos Hills

LIST OF INSPECTIONS
SEQ

ID SCHEDULED DATE COMPLETED DATE TYPE INSPECTOR RESULT REMARKS 1/26/2023 1/26/2023 FOUNDATION
STEEL CSG INSPECTOR PASS Live Babak
Notes:

PASS W/ SPECIAL INSPECTION LETTER
4/27/2023 4/27/2023 EXTERIOR SHEAR
WALL HOLDOWNS CSG INSPECTOR PASS Live Babak
Notes:
11/21/2023 3:00
PM 11/21/2023 ROUGH ALL TRADES

BABAK MADANI
CSG CORRECTIONS Live - PM - May 650-678-3230
Notes:

Upper bedroom window needs to have 44" emergency escape clearance. Electrical boxes need to be properly set up. Exterior door over steps has bifolding doors with no landing. Floor appears to have been and reduced below sill plate. Fdn vent above floor line; needs to be addressed and have structural EOR of record address sill plates not attached to floor. Needs Exterior Doors and windows installed and weather proof before electrical can be signed off.

Underfloor Frame still yet to be inspected.
11/29/2023 11:00
AM 11/29/2023 ROUGH ELECTRICAL CSG INSPECTOR PASS AM May 650-678-3230 Notes:
corrections ok
11/29/2023 AM 11/29/2023 ROUGH

INSULATION CSG INSPECTOR PASS
Notes:
close cell in ceiling batts in walls
5/23/2024 AM 5/23/2024 622 BLD DRYWALL
NAILING CSG INSPECTOR PASS Steve Davis
Notes:
8/12/2024 PM 8/12/2024 629 BLD TUB
SHOWER PAN Chris Brown PASS PM MAY 650-678-3230
Notes:
5 showers
Permit Number: BLD22-0322
Site Address: 23475 CAMINO HERMOSO
City, State Zip Code: LOS ALTOS HILLS, CA
Applied: 7/22/2022 Approved: 11/29/2022
Issued: 11/29/2022
Parent Permit:

Parent Project:

Applicant: AIM CONSOLUTIONS INC.

Owner: MARIANI EUGENE E AND SHIRLEY F TRUSTEE
Contractor: AIM CONSOLUTIONS INC.

Description: RENOVATION ENTIRE HOUSE ATTACHED OFFICE ROOM AT

MAIN HOUSE
Finaled:

Status: EXPIRED
Details:

Printed: Wednesday, 12 November, 2025 1 of 2
ITEM 5I ATTACHMENT 6

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Permit Inspections
Town of Los Altos Hills
9/5/2024 PM 9/5/2024 622 BLD DRYWALL
NAILING CSG INSPECTOR PASS pm mai 650-678-3230
Notes:
concrete board for bathroom
Printed: Wednesday, 12 November, 2025 2 of 2
ITEM 5I ATTACHMENT 6

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TOWN OF LOS ALTOS HILLS November 20, 2025
Staff Report to the City Council
SUBJECT: RESOLUTION GRANTING REQUEST FOR EXTENSION OF THE

EXPIRATION DATE FOR A BUILDING PERMIT FOR

CONSTRUCTION OF NEW SINGLE-FAMILY RESIDENCE,
LANDS OF SIDDHARTH AND KALPANA, 26429 PURISIMA ROAD,
BLD22-0414
PREPARED BY: Tim McBirney, Community Development Analyst FROM: Jay Bradford, Community Development Director
APPROVED: Cody Einfalt, Acting City Manager
RECOMMENDATION: That the City Council:

Adopt the resolution (see Appendix 1) approving the extension request for Building Permit #BLD22-0414 with a new expiration date of November 20, 2026.

DISCUSSION:

The property owner is requesting an extension of Building Permits #BLD22-0414 at 26429 Purisima Road that was originally issued on November 22, 2022. See Appendix 2 for a copy of the request. The projected started in winter 2022 and took 6 months for grading and foundation work. Delays due to low water flow and psi, requiring a tank and pump system to be designed and approved by Santa Clara County Fire District. The project is scheduled for completion in November 2026. New residence construction is limited to 36 months following the issuance of the building permit if the estimated value of the project is over $1,000,001. See Los Altos Hills Municipal Code, Title 8, Section 10.04 (https://ecode360.com/43997785), which shows the time limitations set by project type and value. Since the estimated value of the project is over $1,000,001, the building permits expired on November 22, 2025. The Construction Time Limits Ordinance does allow the extension of time limit by two six- month extensions if the extension request is made in the allotted time as described in Section 8-10.04. For this request, however, the City Council must consider the extension as all other extension options have been exhausted. The applicant has submitted a request for an extension for up to a year to complete the work, which is their first extension request. A copy of the inspection record for the project is attached as Appendix 3 to help give a better understanding of the project progress.

Staff recommends granting an extension to allow for additional inspections necessary for project closeout. With this approved permit extension, the applicant will have a year from City Council’s approval of this request to complete the project. Following a year, if the remaining scope of work and inspections have not been completed, the applicant will have to pay the final deposit bond in an amount equal to the lesser of 10% of the estimated cost to complete ITEM 5I ATTACHMENT 7

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City Council
26429 Purisima Road
November 20, 2025

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the project, as determined by the Building Official, or $50,000 for which if they exceed the extension’s time limit, the applicant will face penalties again. In addition, they will be required to apply for another permit extension.

The above project, if approved, would result in a one-year extension from the date of the City Council’s approval. The approved permit extension resolution would supersede any related conditions of approval in the planning entitlements and permitting compliance dates.

ENVIRONMENTAL REVIEW:

The proposed request is exempt from the provisions of the California Environmental Quality Act (CEQA) pursuant to Section 15061(b)(3), which exempts actions that can be seen with certainty will not cause significant environmental impacts.

FISCAL IMPACT:

There is no fiscal impact associated with these time extension requests as the applicant pays a fee for service covering the Town’s costs.
2024-25 CITY COUNCIL WORK PLAN:

This is not part of the 2024-25 City Council Work Plan as extensions are, depending on applicability, part of the standard site development approval process.

APPENDIX:

1. Resolution Approving Time Extension for 26429 Purisima Road, Building Permit #BLD22-0414

2. Building Permit Extension Request

3. #BLD22-0414 Inspection Record
ITEM 5I ATTACHMENT 7

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City Council
26429 Purisima Road
November 20, 2025

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RESOLUTION ____-25

A RESOLUTION OF THE CITY COUNCIL OF THE TOWN OF LOS ALTOS HILLS

APPROVING A TIME EXTENSION OF AN APPROVED BUILDING PERMIT FOR

CONSTRUCTION OF NEW SINGLE-FAMILY RESIDENCE
WHEREAS, Sheth Siddhardth C & Krishnamurthy Kalpana Trustee (“Owner”) owns the property commonly known as 26429 Purisima Road, Los Altos Hills, California (APN 175-47-002); and WHEREAS, the building permits #BLD22-0414 for a new main residence basement and a new pool house conversion to an ADU were issued on November 22, 2022, with reasonable conditions of approval; and
WHEREAS, the permits expired on November 22, 2025, as the Town has adopted a Construction Time Limits Ordinance and, pursuant thereto, sets an expiration date for Building Permits for new dwellings and remodels with additions with a project valuation of $1,000,001 and over at thirtysix (36) months; and WHEREAS, pursuant to the Construction Time Limits Ordinance, the City Council has the authority to grant reasonable extensions of time for Building Permits that have expired; and WHEREAS, the Town generally grants time extensions of one (1) calendar year; and NOW, THEREFORE, BE IT RESOLVED the City Council of the Town of Los Altos Hills does hereby approve on behalf of the Owners, a one (1) year Time Extension of approved Building Permit #BLD22-0414, subject to the originally adopted conditions.

The above and foregoing Resolution was passed and adopted by the City Council of the Town of Los Altos Hills at a regular meeting held on the 20th day of November 2025 by the following vote:

AYES:

NOES:

ABSTAIN:

ABSENT:

BY: _______________________________
Kavita Tankha, Mayor
ATTEST: ______________________________
Arika Miller, City Clerk
ITEM 5I ATTACHMENT 7

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ITEM 5I ATTACHMENT 7

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ITEM 5I ATTACHMENT 7

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TOWN OF LOS ALTOS HILLS November 20, 2025
Staff Report to the City Council
SUBJECT: RESOLUTION GRANTING REQUEST FOR EXTENSION OF THE

EXPIRATION DATE FOR A BUILDING PERMIT FOR

CONSTRUCTION OF SWIMMING POOL, LANDS OF ROBERT,
27772 LUPINE ROAD, BLD23-0027
PREPARED BY: Tim McBirney, Community Development Analyst FROM: Jay Bradford, Community Development Director
APPROVED: Cody Einfalt, Acting City Manager
RECOMMENDATION: That the City Council:

Adopt the resolution (see Appendix 1) approving the extension request for Building Permit #BLD23-0027 with a new expiration date of November 20, 2026.

DISCUSSION:

The property owner is requesting an extension of Building Permits #BLD23-0027 at 27772 Lupine Road that was originally issued on July 12, 2023. See Appendix 2 for a copy of the request.

Project was delayed due to homeowners being super busy to permit works at the time. Now they need to finish for insurances purposes. New residence construction is limited to 24 months following the issuance of the building permit if the estimated value of the project is between $250,001 to $500,000. See Los Altos Hills Municipal Code, Title 8, Section 10.04 (https://ecode360.com/43997785), which shows the time limitations set by project type and value.

Since the estimated value of the project is between $250,001 to $500,000, the building permits expired on July 12, 2025. The Construction Time Limits Ordinance does allow the extension of time limit by two six- month extensions if the extension request is made in the allotted time as described in Section 8-10.04. For this request, however, the City Council must consider the extension as all other extension options have been exhausted. The applicant hassubmitted a request for an extension for up to a year to complete the work, which is their first extension request. A copy of the inspection record for the project is attached as Appendix 3 to help give a better understanding of the project progress.

Staff recommends granting an extension to allow for additional inspections necessary for project closeout. With this approved permit extension, the applicant will have a year from City Council’s approval of this request to complete the project. Following a year, if the remaining scope of work and inspections have not been completed, the applicant will have to pay the final deposit bond in an amount equal to the lesser of 10% of the estimated cost to complete the project, as determined by the Building Official, or $50,000 for which if they exceed the ITEM 5I ATTACHMENT 8

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City Council
27772 Lupine Road
November 20, 2025

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extension’s time limit, the applicant will face penalties again. In addition, they will be required to apply for another permit extension.

The above project, if approved, would result in a one-year extension from the date of the City Council’s approval. The approved permit extension resolution would supersede any related conditions of approval in the planning entitlements and permitting compliance dates.

ENVIRONMENTAL REVIEW:

The proposed request is exempt from the provisions of the California Environmental Quality Act (CEQA) pursuant to Section 15061(b)(3), which exempts actions that can be seen with certainty will not cause significant environmental impacts.

FISCAL IMPACT:

There is no fiscal impact associated with these time extension requests as the applicant pays a fee for service covering the Town’s costs.
2024-25 CITY COUNCIL WORK PLAN:

This is not part of the 2024-25 City Council Work Plan as extensions are, depending on applicability, part of the standard site development approval process.

APPENDIX:

1. Resolution Approving Time Extension for 27772 Lupine Road, Building Permit #BLD23-0027

2. Building Permit Extension Request

3. #BLD23-0027 Inspection Record
ITEM 5I ATTACHMENT 8

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City Council
27772 Lupine Road
November 20, 2025

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RESOLUTION ____-25

A RESOLUTION OF THE CITY COUNCIL OF THE TOWN OF LOS ALTOS HILLS

APPROVING A TIME EXTENSION OF AN APPROVED BUILDING PERMIT FOR

CONSTRUCTION OF SWIMMING POOL
WHEREAS, Klein Robert N II Trustee & Et Al (“Owner”) owns the property commonly known as 27772 Lupine Road, Los Altos Hills, California (APN 182-09-022); and WHEREAS, the building permits #BLD23-0027 for a new main residence basement and a new pool house conversion to an ADU were issued on July 12, 2023, with reasonable conditions of approval; and
WHEREAS, the permits expired on July 12, 2025, as the Town has adopted a Construction Time Limits Ordinance and, pursuant thereto, sets an expiration date for Building Permits for new dwellings and remodels with additions with a project valuation between $250,001 to $500,000 at twenty-four (24) months; and
WHEREAS, pursuant to the Construction Time Limits Ordinance, the City Council has the authority to grant reasonable extensions of time for Building Permits that have expired; and WHEREAS, the Town generally grants time extensions of one (1) calendar year; and NOW, THEREFORE, BE IT RESOLVED the City Council of the Town of Los Altos Hills does hereby approve on behalf of the Owners, a one (1) year Time Extension of approved Building Permit #BLD23-0027, subject to the originally adopted conditions.

The above and foregoing Resolution was passed and adopted by the City Council of the Town of Los Altos Hills at a regular meeting held on the 20th day of November 2025 by the following vote:

AYES:

NOES:

ABSTAIN:

ABSENT:

BY: _______________________________
Kavita Tankha, Mayor
ATTEST: ______________________________
Arika Miller, City Clerk
ITEM 5I ATTACHMENT 8

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ITEM 5I ATTACHMENT 8

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ITEM 5I ATTACHMENT 8

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TOWN OF LOS ALTOS HILLS November 20, 2025
Staff Report to the City Council
SUBJECT: RESOLUTION GRANTING REQUEST FOR EXTENSION OF THE

EXPIRATION DATE FOR A BUILDING PERMIT FOR HOUSE

REMODEL AND ADU ADDITION, LANDS OF LINGLING
INTERNATION LLC, 24985 ONEONTA DRIVE, BLD23-0122
PREPARED BY: Tim McBirney, Community Development Analyst FROM: Jay Bradford, Community Development Director
APPROVED: Cody Einfalt, Acting City Manager
RECOMMENDATION: That the City Council:

Adopt the resolution (see Appendix 1) approving the extension request for Building Permit #BLD23-0122 with a new expiration date of November 20, 2026.

DISCUSSION:

The property owner is requesting an extension of Building Permits #BLD23-0122 at 24985 Oneonta Drive that was originally issued on September 19, 2023. See Appendix 2 for a copy of the request. Project was delayed due encroachment permit work has encountered some requested changes by engineering dept regarding firetruck turnaround. New residence construction is limited to 18 months following the issuance of the building permit if the estimated value of the project is between $0 to $250,000. See Los Altos Hills Municipal Code, Title 8, Section 10.04 (https://ecode360.com/43997785), which shows the time limitations set by project type and value.

Since the estimated value of the project is between $0 to $250,000, the building permits expired on March 19, 2025. The Construction Time Limits Ordinance does allow the extension of time limit by two six- month extensions if the extension request is made in the allotted time as described in Section 8-10.04. For this request, however, the City Council must consider the extension as all other extension options have been exhausted. The applicant has submitted a request for an extension for up to a year to complete the work, which is their first extension request. A copy of the inspection record for the project is attached as Appendix 3 to help give a better understanding of the project progress.

Staff recommends granting an extension to allow for additional inspections necessary for project closeout. With this approved permit extension, the applicant will have a year from City Council’s approval of this request to complete the project. Following a year, if the remaining scope of work and inspections for the project have not been completed, the applicant will have to pay the final deposit bond in an amount equal to the lesser of 10% of the estimated cost to complete the project, as determined by the Building Official, or $50,000 for which if they exceed the ITEM 5I ATTACHMENT 9

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City Council
24985 Oneonta Drive
November 20, 2025

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extension’s time limit, the applicant will face penalties again. In addition, they will be required to apply for another permit extension.

The above project, if approved, would result in a one-year extension from the date of the City Council’s approval. The approved permit extension resolution would supersede any related conditions of approval in the planning entitlements and permitting compliance dates.

ENVIRONMENTAL REVIEW:

The proposed request is exempt from the provisions of the California Environmental Quality Act (CEQA) pursuant to Section 15061(b)(3), which exempts actions that can be seen with certainty will not cause significant environmental impacts.

FISCAL IMPACT:

There is no fiscal impact associated with these time extension requests as the applicant pays a fee for service covering the Town’s costs.
2024-25 CITY COUNCIL WORK PLAN:

This is not part of the 2024-25 City Council Work Plan as extensions are, depending on applicability, part of the standard site development approval process.

APPENDIX:

1. Resolution Approving Time Extension for 24985 Oneonta Drive, Building Permit #BLD23-0122

2. Building Permit Extension Request

3. #BLD23-0122 Inspection Record
ITEM 5I ATTACHMENT 9

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City Council
24985 Oneonta Drive
November 20, 2025

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RESOLUTION ____-25

A RESOLUTION OF THE CITY COUNCIL OF THE TOWN OF LOS ALTOS HILLS

APPROVING A TIME EXTENSION OF AN APPROVED BUILDING PERMIT FOR

HOUSE REMODEL AND ADU ADDITION
WHEREAS, Lingling Internation LLC(“Owner”) owns the property commonly known as 24985 Oneonta Drive, Los Altos Hills, California (APN 336-29-018); and WHEREAS, the building permits #BLD23-0122 for a new main residence basement and a new pool house conversion to an ADU were issued on September 19, 2023, with reasonable conditions of approval; and
WHEREAS, the permits expired on September 19, 2025, as the Town has adopted a Construction Time Limits Ordinance and, pursuant thereto, sets an expiration date for Building Permits for new dwellings and remodels with additions with a project valuation between $0 and $250,000 at eighteen (18) months; and
WHEREAS, pursuant to the Construction Time Limits Ordinance, the City Council has the authority to grant reasonable extensions of time for Building Permits that have expired; and WHEREAS, the Town generally grants time extensions of one (1) calendar year; and NOW, THEREFORE, BE IT RESOLVED the City Council of the Town of Los Altos Hills does hereby approve on behalf of the Owners, a one (1) year Time Extension of approved Building Permit #BLD23-0122, subject to the originally adopted conditions.

The above and foregoing Resolution was passed and adopted by the City Council of the Town of Los Altos Hills at a regular meeting held on the 20th day of November 2025 by the following vote:

AYES:

NOES:

ABSTAIN:

ABSENT:

BY: _______________________________
Kavita Tankha, Mayor
ATTEST: ______________________________
Arika Miller, City Clerk
ITEM 5I ATTACHMENT 9

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LOS ALTOS HILLS

CALIFORNIA

BUILDING DIVISION
Construction Time Limit Review and
Extension Request Form

RECEIVE
JUL 22 2025

TOWN OF LOS ALTOS HILLS
Permit Extension Request Date: 7/10/25
Permit No: BLD23-0122
Address: 24985 Oneonta Drive
Permit Description: House remodel & ADU addition
Initial Permit Issuance Date: 9/19/2023
3/19/2025 Permit Expiration Date:

List any previous extensions granted (include dates): None Last Extensions Approved by: Building Official
City Council
Total Number of Extensions Granted for this Permit: 0
Expiration Dates for Previous Extensions: N/A
I would like to request a Permit Extension for the above project. Construction on this project was delayed due to the following circumstances (provide documentation regarding delays):

Encroachment permit work has encountered some requested changes requested by Engineering Dept. Firetruck turnaround needs to be shifted Name: Mike Ma
Signature: P
Title (if applicable): Project Architect
Business name (if applicable): MArch Design
Phone number: (650) 302-1987
Email: [email protected]
Permit Extension Request Application Checklist:
• Completed application form and petition letter
이
이
Documentation of original permit
Documentation of project delays
• Original inspection record
• Planned timeline for project completion
Email completed form to:

[email protected]
Staff Approval : M.Guzules
Print Name
7/22/25
Date
Director Approval :

Print Name Date
Signature Signature
ITEM 5I ATTACHMENT 9 ITEM 5I Attachment 9

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Permit Inspections
Town of Los Altos Hills

LIST OF INSPECTIONS
SEQ

ID SCHEDULED DATE COMPLETED DATE TYPE INSPECTOR RESULT REMARKS 10/19/2023 10/25/2023 ROOF NAILING CSG INSPECTOR PASS Live Babak Notes:
10/30/2023 10/31/2023 UNDERGROUND
SEWER CSG INSPECTOR PARTIAL Live Babak
Notes:
from ADU to main house line.
10/31/2023 10/31/2023 EXTERIOR SHEAR
WALL HOLDOWNS CSG INSPECTOR PASS Live - PM
Notes:
11/22/2023 1:00
PM 11/22/2023 ROUGH ALL TRADES

BABAK MADANI
CSG NOT READY Live - PM 917-536-3024
Notes:

Live - PM
11/29/2023 2:00
PM 11/29/2023 ROUGH ALL TRADES CSG INSPECTOR PASS PM David 917-536-3024 Notes:
corrections ok
12/6/2023 1:30
PM 12/6/2023 ROUGH INSULATION CSG INSPECTOR PASS PM David 917-536-3024 Notes:
1/8/2024 1/8/2024 611 BLD SLAB BABAK MADANI

CSG PASS
Notes:

WATER PROOF LIQUID MEMBRANE - PASS.

Permit Number: BLD23-0122
Site Address: 24985 ONEONTA DRIVE
City, State Zip Code: LOS ALTOS HILLS, CA 94022
Applied: 3/9/2023 Approved: 9/19/2023
Issued: 9/19/2023
Parent Permit:

Parent Project:

Applicant: Mike Ma, MArch Design
Owner: LINGLING INTERNATION LLC
Contractor: GOLDEN BRICK INC
Description: MAIN HOUSE TOTAL REMODEL
Finaled: 10/22/2025
Status: FINALED
Details:

Printed: Thursday, 06 November, 2025 1 of 2
ITEM 5I ATTACHMENT 9

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Permit Inspections
Town of Los Altos Hills
3/5/2024 08:00
AM 3/5/2024
605 BLD

UNDERGROUND

UTILITIES
Chris Brown PASS
Notes:

Water line and gas line under pressure Pass
6/4/2024 PM 6/4/2024
634 BLD ELECTRIC
METER

AUTHORIZATION
Chris Brown PASS PM David 917-536-3024
Notes:
200 amps
9/30/2025 PM 9/30/2025 999 BUILDING
FINAL** Chris Brown CORRECTIONS PM GUO YUN 408-930-2520 Notes:
fix receptacles
check smoke detectors
bond water heaters with solid copper
planning inspection first
10/22/2025 PM 10/22/2025 999 BUILDING
FINAL** Chris Brown PASS PM GUO YUN 408-930-2520
Notes:

Printed: Thursday, 06 November, 2025 2 of 2
ITEM 5I ATTACHMENT 9

Page 453 of 775 ends

TOWN OF LOS ALTOS HILLS November 20, 2025
Staff Report to the City Council
SUBJECT: RESOLUTION GRANTING REQUEST FOR EXTENSION OF THE

EXPIRATION DATE FOR A BUILDING PERMIT FOR A MINOR

ADDITION AND FULL INTERIOR REMODEL, LANDS OF OCAMPO
JOHN AND SUSAN TRUSTEE; 28013 ARASTRADERO ROAD,
PERMIT #BLD21-0408
PREPARED BY: Tim McBirney, Community Development Analyst FROM: Jay Bradford, Community Development Director
APPROVED: Cody Einfalt, Acting City Manager
RECOMMENDATION: That the City Council:

Adopt the resolution (see Appendix 1) approving the extension request for Building Permit #BLD21-0408 with a new expiration date of November 20, 2026.

DISCUSSION:

The property owner is requesting an extension of Building Permits # BLD21-0408 at 28013 Arastradero Road that was originally issued on August 26, 2021. See Appendix 2 for a copy of the request. This request is for a kitchen and bathroom remodel, work is completed, so applicant is requesting permit extension to complete final inspections. New residence construction is limited to 18 months following the issuance of the building permit if the estimated value of the project is between $0 to $250,000. See Los Altos Hills Municipal Code, Title 8, Section 10.04 (https://ecode360.com/43997785), which shows the time limitations set by project type and value.

Since the estimated value of the project is between $0 to $250,000, the building permits expired on February 26, 2023. The Construction Time Limits Ordinance does allow the extension of time limit by two six-month extensions if the extension request is made in the allotted time as described in Section 8-10.04. For this request, however, the City Council must consider the extension as all other extension options have been exhausted. The applicant has submitted a request for an extension for up to a year to complete the work, which is their first extension request. A copy of the inspection record for the project is attached as Appendix 3 to help give a better understanding of the project progress.

Staff recommends granting an extension to allow for additional inspections necessary for project closeout. With this approved permit extension, the applicant will have a year from City Council’s approval of this request to complete the project. Following a year, if the remaining scope of work and inspections for the project have not been completed, the applicant will have to pay the final deposit bond in an amount equal to the lesser of 10% of the estimated cost to complete the project, as determined by the Building Official, or $50,000 for which if they exceed the ITEM 5I ATTACHMENT 10

Page 454 of 775 ends

City Council
28013 Arastradero Road
November 20, 2025

Page 2 of 3 ends

extension’s time limit, the applicant will face penalties again. In addition, they will be required to apply for another permit extension.

The above project, if approved, would result in a one-year extension from the City Council’s approval. The approved permit extension resolution would supersede any related conditions of approval in the planning entitlements and permitting compliance dates.

ENVIRONMENTAL REVIEW:

The proposed request is exempt from the provisions of the California Environmental Quality Act (CEQA) pursuant to Section 15061(b)(3), which exempts actions that can be seen with certainty will not cause significant environmental impacts.

FISCAL IMPACT:

There is no fiscal impact associated with these time extension requests as the applicant pays a fee for service covering the Town’s costs.
2024-25 CITY COUNCIL WORK PLAN:

This is not part of the 2024-25 City Council Work Plan as extensions are, depending on applicability, part of the standard site development approval process.

APPENDIX:

1. Resolution Approving Time Extension for #BLD21-0408 at 28013 Arastradero Road

2. Building Permit Extension Request

3. BLD21-0408 Inspection Record
ITEM 5I ATTACHMENT 10

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City Council
28013 Arastradero Road
November 20, 2025

Page 3 of 3 ends

RESOLUTION ____-25

A RESOLUTION OF THE CITY COUNCIL OF THE TOWN OF LOS ALTOS HILLS

APPROVING A TIME EXTENSION OF AN APPROVED BUILDING PERMIT FOR A

MINOR ADDITION AND INTERIOR REMODEL
WHEREAS, Ocampo John and Susan Trustee (“Owners”) owns the property commonly known as 28016 Arastradero Road, Los Altos Hills, California (APN 182-32-039); and WHEREAS, the building permits #for a new main residence basement and a new pool house conversion to an ADU were issued on August 26, 2021, with reasonable conditions of approval; and
WHEREAS, the permits expired on February 26, 2023, as the Town has adopted a Construction Time Limits Ordinance and, pursuant thereto, sets an expiration date for Building Permits for new dwellings and remodels with additions with a project valuation between $0 and $250,000 at eighteen (18) months; and
WHEREAS, pursuant to the Construction Time Limits Ordinance, the City Council has the authority to grant reasonable extensions of time for Building Permits that have expired; and WHEREAS, the Town generally grants time extensions of one (1) calendar year; and NOW, THEREFORE, BE IT RESOLVED the City Council of the Town of Los Altos Hills does hereby approve on behalf of the Owners, a one (1) year Time Extension of approved Building Permit # BLD21-0408, subject to the originally adopted conditions.

The above and foregoing Resolution was passed and adopted by the City Council of the Town of Los Altos Hills at a regular meeting held on the 20th day of November 2025 by the following vote:

AYES:

NOES:

ABSTAIN:

ABSENT:

BY: _______________________________
Kavita Tankha, Mayor
ATTEST: ______________________________
Arika Miller, City Clerk
ITEM 5I ATTACHMENT 10

Page 456 of 775 ends

LOS ALTOS HILTS

CALIFORNIA

BUILDING DIVISION
Construction Time Limit Review and
Extension Request Form
RECEVED JUL 25 2025

TOWN OF LOS ALTOS HILLS
Permit Extension Request Date: 7/25/25
BLD21-0408 Permit No:
28013 Arstardero Address:

Kitchen Remodel
Permit Description:
08/26/21 Initial Permit Issuance Date:02/26/23
Permit Expiration Date: $150K val= 18 months
List any previous extensions granted (include dates):

Last Extensions Approved by: Building Official
City Council 이
Total Number of Extensions Granted for this Permit:

Expiration Dates for Previous Extensions:

I would like to request a Permit Extension for the above project. Construction on this project was delayed due to the following circumstances (provide documentation regarding delays): The Kitchen was completed long ago. I think it may have been included with a multi roon remodel permit that was then changed. I would like to close out this permit Name: Jay Chapman
Signature:

Giulia Construction Business name (if applicable):
650 291 7474 Phone number:

Email: [email protected]
Permit Extension Request Application Checklist:
• Completed application form and petition letter
• Documentation of original permit
• Documentation of project delays
이
이
Original inspection record
Planned timeline for project completion
Email completed form to:

[email protected]
Staff Approval: M. Guzules
Print Name _
Signature
7/25/25 Date
Director Approval:

Print Name Date
Signature
ITEM 5I ATTACHMENT 10

Page 457 of 775 ends

TRAKIT
Permit Number: BLD21-0408
Applied: 7/26/2021 Approved: 8/26/2021
Issued: 8/26/2021 Finaled:

Status: EXPIRED
Parent Permit:

Parent Project:

Details:

Description: REMODEL 890 SQ FT KITCHEN AND BATHROOM (N)

CABINETRY, ELECTR
Site Address: 28013 ARASTRADERO ROAD
City, State Zip Code: LOS ALTOS HILLS, CA
Applicant: GIULIA CONSTRUCTION
Owner: OCAMPO JOHN AND SUSAN TRUSTEE
Contractor: GIULIA CONSTRUCTION

LIST OF INSPECTIONS
SEQ
ID SCHEDULED DATЕ COMPLETED DATE TYPE INSPECTOR RESULT REMARKS 8/30/2021 02:00
PM 8/30/2021 ROUGH ALL
TRADES
ROBERT

JOHNSON PARTIAL
Notes:

Test gas piping, bond metal box for kitchen range, install UL 181 metal foil tape for a kitchen exhaust duct, Metal support straps required for kitchen exhaust duct, draft stop and fire blocking required from wall to ceiling cavities, Verify with mechanical contractor intake air is sufficient for existing mechanical furnace and exhaust for kitchen range equipment warranty will be covered with extensive horizontal venting, verify with mechanical contractor fresh air intake is sufficient for heating system due to the new kitchen range exhaust, OK to install sheet rock everywhere except not in the kitchen.
10/6/2021 03:00
PM 10/6/2021
Notes:

GAS PRESSURE
TEST
ROBERT
JOHNSON PARTIAL Live
Sheet rock passes inspection. Gas pressure test required before final. Pictures acceptable for minor insulation that was needed. All previous corrections have been repaired inspected and approved.
03:00 10/8/2021 10/8/2021 PM

GAS PRESSURE
TEST
ROBERT

JOHNSON PASS
Notes:

Live
10/27/2022 10/28/2022 **FINAL CSG INSPECTOR CORRECTIONS Live Babak Notes:

Needs CO detector outside of bedroom
Printed: Friday, 25 July, 2025 1 of 1 CENTRALSQUARE
ITEM 5I ATTACHMENT 10

Page 458 of 775 ends

Permit Inspections
Town of Los Altos Hills

LIST OF INSPECTIONS
SEQ

ID SCHEDULED DATE COMPLETED DATE TYPE INSPECTOR RESULT REMARKS 8/30/2021 02:00
PM 8/30/2021 ROUGH ALL TRADES
ROBERT

JOHNSON PARTIAL
Notes:

Test gas piping, bond metal box for kitchen range, install UL 181 metal foil tape for a kitchen exhaust duct, Metal support straps required for kitchen exhaust duct, draft stop and fire blocking required from wall to ceiling cavities, Verify with mechanical contractor intake air is sufficient for existing mechanical furnace and exhaust for kitchen range equipment warranty will be covered with extensive horizontal venting, verify with mechanical contractor fresh air intake is sufficient for heating system due to the new kitchen range exhaust, OK to install sheet rock everywhere except not in the kitchen.
10/6/2021 03:00
PM 10/6/2021 GAS PRESSURE TEST
ROBERT
JOHNSON PARTIAL Live
Notes:

Sheet rock passes inspection. Gas pressure test required before final. Pictures acceptable for minor insulation that was needed. All previous corrections have been repaired inspected and approved.
10/8/2021 03:00
PM 10/8/2021 GAS PRESSURE TEST
ROBERT
JOHNSON PASS Live
Notes:
10/27/2022 10/28/2022 **FINAL CSG INSPECTOR CORRECTIONS Live Babak Notes:

Needs CO detector outside of bedroom
Permit Number: BLD21-0408
Site Address: 28013 ARASTRADERO ROAD
City, State Zip Code: LOS ALTOS HILLS, CA
Applied: 7/26/2021 Approved: 8/26/2021
Issued: 8/26/2021
Parent Permit:

Parent Project:

Applicant: GIULIA CONSTRUCTION
Owner: OCAMPO JOHN AND SUSAN TRUSTEE
Contractor: GIULIA CONSTRUCTION
Description: REMODEL 890 SQ FT KITCHEN AND BATHROOM (N)

CABINETRY, ELECTR
Finaled:

Status: EXPIRED
Details:

Printed: Thursday, 13 November, 2025 1 of 1
ITEM 5I ATTACHMENT 10

Page 459 of 775 ends

2025 CostEffectiveness Study:

Single Family AC to Heat
Pump Replacement
Prepared by:

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

Kelly Cunningham, Codes and
Standards Program, Pacific Gas
and Electric
Revision: 2.0
Last modified: 2025/08/08

Page 460 of 775 ends

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 1 2025/08/08
Table 1. Summary of Revisions
Date Description Reference (page or section)
6/09/2025 Original Release N/A
8/08/2025 The following issues were corrected in this report. Note that none of the issues flipped cost-effectiveness results from costeffective to not cost-effective or vice versa in any climate zone except for the DFHP in the 1978-1991 vintage in CZ 15 is now LSC cost-effective.

1. 30-year DFHP results for all sizes except the 3-ton
system have been impacted. Increase in costeffectiveness for Climate Zones 2,4,8-15, decrease in cost effectiveness in Climate Zone 3.

Table 7, Table 8, Table 9,
Table 12, Table 15, Table 22,
Table 25, Table 28, Table 31,
Section 4: Recommendations
and Discussion
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.

Page 461 of 775 ends

Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 2 2025/08/08

2. Incremental cost tables 7-9 had incorrect condensing furnace costs.

3. Zero NOx discussion in the recommendations and
discussion section was based on the high gas
escalation rates but were compared against the
modest escalation standard results. The discussion
has been corrected to compare against the high gas
escalation standard results instead.

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 3 2025/08/08
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

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 1 2025/08/08
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

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 2 2025/08/08

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 ....................................................................10 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 9. HVAC Measure Cost Assumptions – 4-Ton Electric Replacements........................20 Table 10. SCAQMD Rule 1111 Proposed Manufacturer Compliance Targets.......................20 Table 11. Lifecycle Incremental Cost Breakdown for 4-Ton System with no Gas Furnaces 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 with High Gas Escalation (Zero-NOx Rule) 29 Table 19. DFHP Existing Furnace LSC Savings (Zero-NOx Rule).......................................30 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 23. [Pre-1978] Standard Efficiency HPSH..................................................................40 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 33. [1978-1991] High Efficiency HPSH CARE............................................................50 Table 34. PG&E Baseline Territory by Climate Zone............................................................51 Table 35. PG&E Monthly Gas Rate ($/therm)......................................................................52

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 3 2025/08/08
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

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 4 2025/08/08
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.

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 5 2025/08/08
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

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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].

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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/

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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].

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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

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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

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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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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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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.

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• 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%20livin g%20space.

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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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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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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

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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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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
$7,879 $5,863 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 $22,989 $22,566
Incremental Cost -$424
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
$7,879 $4,363
- - -
2056 Remaining
useful life for
furnace
- -$1,623
- - -
Total $23,243 $23,213
Incremental Cost -$30

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 20 2025/08/08
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) $18,310 $18,310 $15,729 $13,529 $16,506
Replacement Cost
(Present Value) $12,558 $11,058 $10,219 $8,684 $10,594
Remaining Value at
Year 30 $0 -$1,623 $0 $0 $0
Total Lifecycle Cost $22,989 $23,243 $22,566 $23,213 $28,100 Incremental Cost - - -$424 -$30 $4,857

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 2025/08/08
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 2025/08/08
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.

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 23 2025/08/08

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) $8,462 $2,312 $12,767
CZ03 PGE $1,178 $15 $8,302 $4,810 $13,877
CZ04 PGE $1,670 ($68) $7,396 $1,955 $10,123
CZ04 CPAU $1,670 ($9) $7,396 $2,207 $7,179
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) $2,028 ($662) $311
CZ09 SCE/SCG $1,916 ($90) $2,749 ($1,037) $437
CZ10 SCE/SCG $1,916 ($79) $2,444 ($833) $543
CZ10 SDGE $1,916 $54 $2,444 $2,350 $4,857
CZ11 PGE $2,162 $68 $7,672 $4,713 $14,750
CZ12 PGE $1,916 $44 $8,466 $4,851 $15,371
CZ12 SMUD/PGE $1,916 $353 $8,466 $11,771 $22,513
CZ13 PGE $2,162 $76 $5,318 $3,972 $11,212
CZ14 SCE/SCG $1,916 ($179) $4,803 ($2,215) $1,489
CZ14 SDGE $1,916 ($22) $4,803 $1,431 $7,207
CZ15 SCE/SCG $2,408 ($133) ($122) ($3,289) ($3,060)
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 2025/08/08
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

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 25 2025/08/08
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 2025/08/08

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 $8,462 $3,916 $12,233
CZ03 PGE $1,178 $73 $8,302 $5,493 $12,696
CZ04 PGE $1,670 $14 $7,396 $3,217 $9,716
CZ04 CPAU $1,670 $0 $7,396 $786 $786
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) $2,028 ($136) $644
CZ09 SCE/SCG $1,916 ($52) $2,749 ($301) $879
CZ10 SCE/SCG $1,916 ($45) $2,444 ($182) $920
CZ10 SDGE $1,916 $51 $2,444 $2,147 $4,112
CZ11 PGE $2,162 $115 $7,672 $5,068 $13,039
CZ12 PGE $1,916 $103 $8,466 $5,436 $13,792
CZ12 SMUD/PGE $1,916 $418 $8,466 $12,488 $21,071
CZ13 PGE $2,162 $100 $5,318 $4,013 $9,760
CZ14 SCE/SCG $1,916 ($98) $4,803 ($700) $2,268
CZ14 SDGE $1,916 $23 $4,803 $2,156 $6,677
CZ15 SCE/SCG $2,408 ($88) ($122) ($2,307) ($2,111)
CZ16 PGE $2,243 $33 $8,842 $2,737 $11,267

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 27 2025/08/08
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

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 28 2025/08/08
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 assuming high gas escalation.

The high gas escalation was used for the zero-NOx analysis because the high gas escalation is built on the assumption that gas furnaces are no longer available to be installed due to zero-NOx regulations or similar policies. Table 19 shows 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.

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 29 2025/08/08
Table 18. DFHP Existing Furnace On-Bill NPV with High Gas Escalation (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

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 30 2025/08/08
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.

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 31 2025/08/08
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

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 32 2025/08/08
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.

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 33 2025/08/08
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 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 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

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 34 2025/08/08
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 Zone 15.

The improved cost-effectiveness is due to the higher baseline cost when HPSH must be installed at year 10 when the furnace must be replaced. It is also important to note that Climate Zone 15 is the only climate zone that utilizes a 5-ton HPSH, which has a much higher cost than the smaller sized systems, resulting in costeffectiveness improvements under the Zero-Nox rules.

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 this time as well. This measure (DFHP New Furnace) was evaluated in the 2022

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Single Family Retrofit Cost-effectiveness Study (Statewide Reach Codes Team, 2024) but found to be less cost-effective than the DFHP Existing Furnace case.

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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

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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

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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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6.2 Cost-Effectiveness Results

6.2.1 Standard Rates
The following tables present results across the 16 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) $11,625 $4,391 $20,880
CZ03 PGE $1,178 $39 $11,599 $7,167 $21,825
CZ04 PGE $1,670 ($7) $10,648 $5,023 $18,395
CZ04 CPAU $1,670 $63 $10,648 $5,251 $14,605
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) $3,365 ($1,358) $524
CZ09 SCE/SCG $1,916 ($168) $4,387 ($2,351) $274
CZ10 SCE/SCG $1,916 ($133) $3,904 ($1,625) $923
CZ10 SDGE $1,916 $201 $3,904 $6,324 $10,832
CZ11 PGE $2,162 $93 $12,045 $7,668 $25,025
CZ12 PGE $1,916 $46 $12,451 $7,097 $24,339
CZ12 SMUD/PGE $1,916 $584 $12,451 $19,146 $36,775
CZ13 PGE $2,162 $112 $8,254 $6,448 $18,815
CZ14 SCE/SCG $1,916 ($244) $6,795 ($2,777) $3,481
CZ14 SDGE $1,916 $65 $6,795 $4,352 $13,446
CZ15 SCE/SCG $2,408 $80 $550 $1,655 $2,681
CZ16 PGE $2,243 ($199) $17,538 $2,333 $25,276

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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

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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

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 42 2025/08/08
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) $9,216 $2,259 $14,435
CZ03 PGE $1,178 $3 $8,952 $5,020 $15,543
CZ04 PGE $1,670 ($68) $8,234 $2,394 $11,893
CZ04 CPAU $1,670 $18 $8,234 $3,236 $9,492
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) $2,294 ($877) $294
CZ09 SCE/SCG $1,916 ($116) $3,127 ($1,506) $271
CZ10 SCE/SCG $1,916 ($89) $2,755 ($947) $720
CZ10 SDGE $1,916 $139 $2,755 $4,470 $7,469
CZ11 PGE $2,162 $103 $9,192 $6,313 $18,851
CZ12 PGE $1,916 $60 $9,753 $5,919 $18,655
CZ12 SMUD/PGE $1,916 $430 $9,753 $14,208 $27,211
CZ13 PGE $2,162 $111 $6,312 $5,317 $14,322
CZ14 SCE/SCG $1,916 ($230) $5,080 ($3,128) $1,188
CZ14 SDGE $1,916 $35 $5,080 $2,942 $9,420
CZ15 SCE/SCG $2,408 ($17) $50 ($658) ($161)
CZ16 PGE $2,243 ($161) $14,397 $1,740 $20,318

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 43 2025/08/08
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

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 44 2025/08/08
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

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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 $11,625 $6,507 $19,628
CZ03 PGE $1,178 $128 $11,599 $8,167 $19,817
CZ04 PGE $1,670 $90 $10,648 $6,273 $16,909
CZ04 CPAU $1,670 $0 $10,648 $786 $786
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) $3,365 ($446) $1,060
CZ09 SCE/SCG $1,916 ($97) $4,387 ($983) $1,121
CZ10 SCE/SCG $1,916 ($75) $3,904 ($511) $1,528
CZ10 SDGE $1,916 $160 $3,904 $5,112 $8,649
CZ11 PGE $2,162 $183 $12,119 $8,564 $22,361
CZ12 PGE $1,916 $152 $12,451 $8,275 $21,982
CZ12 SMUD/PGE $1,916 $686 $12,451 $20,229 $34,321
CZ13 PGE $2,162 $160 $8,329 $6,744 $16,567
CZ14 SCE/SCG $1,916 ($126) $6,795 ($630) $4,382
CZ14 SDGE $1,916 $101 $6,795 $4,679 $11,801
CZ15 SCE/SCG $2,408 $60 $550 $1,131 $1,937
CZ16 PGE $2,243 $34 $17,538 $5,963 $24,236

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 46 2025/08/08
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

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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

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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 $9,216 $4,240 $13,931
CZ03 PGE $1,178 $76 $8,952 $5,930 $14,293
CZ04 PGE $1,670 $23 $8,234 $3,777 $11,336
CZ04 CPAU $1,670 $0 $8,234 $786 $786
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) $2,294 ($246) $693
CZ09 SCE/SCG $1,916 ($67) $3,127 ($563) $861
CZ10 SCE/SCG $1,916 ($50) $2,755 ($208) $1,125
CZ10 SDGE $1,916 $110 $2,755 $3,621 $5,975
CZ11 PGE $2,162 $155 $9,192 $6,617 $16,577
CZ12 PGE $1,916 $128 $9,753 $6,583 $16,702
CZ12 SMUD/PGE $1,916 $506 $9,753 $15,028 $25,418
CZ13 PGE $2,162 $135 $6,312 $5,245 $12,393
CZ14 SCE/SCG $1,916 ($128) $5,080 ($1,202) $2,261
CZ14 SDGE $1,916 $65 $5,080 $3,272 $8,344
CZ15 SCE/SCG $2,408 ($9) $50 ($504) ($107)
CZ16 PGE $2,243 $28 $14,397 $4,676 $19,471

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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

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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

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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
Zone
Baseline
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.

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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

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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

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6.3.3 Southern California Gas
Following are the SoCalGas natural gas tariffs applied in this study. Table 37 describes the baseline territories that were assumed for each climate zone.

Table 37. SoCalGas Baseline Territory by Climate Zone
Climate
Zone
Baseline
Territory
CZ05 2
CZ06 1
CZ08 1
CZ09 1
CZ10 1
CZ14 2
CZ15 1
The SoCalGas monthly gas rate in $/therm applied in this analysis is shown in Table 38. 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 SoCalGas’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.

Long-term historical natural gas rate data was only available for SoCalGas’ procurement charges.8 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 38 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. CARE tariffs reflect the 20 percent discount per the GR tariff.
8 The SoCalGas procurement and transmission charges were obtained from the following site:
https://www.socalgas.com/for-your-business/energy-market-services/gas-prices RES2023.xlsx (live.com)

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Table 38. SoCalGas Monthly Gas Rate ($/therm)
Month Procurement
Charge
Transportation Charge Total Charge
Baseline Excess Baseline Excess
January $0.45 $0.98 $1.40 $1.43 $1.85
February $0.31 $0.98 $1.40 $1.29 $1.71
March $0.26 $0.98 $1.40 $1.24 $1.66
April $0.21 $0.98 $1.40 $1.19 $1.62
May $0.22 $0.98 $1.40 $1.20 $1.62
June $0.25 $0.98 $1.40 $1.23 $1.65
July $0.26 $0.98 $1.40 $1.24 $1.66
August $0.29 $0.98 $1.40 $1.27 $1.70
September $0.27 $0.98 $1.40 $1.25 $1.67
October $0.26 $0.98 $1.40 $1.24 $1.66
November $0.29 $0.98 $1.40 $1.27 $1.69
December $0.33 $0.98 $1.40 $1.31 $1.73

6.3.4 San Diego Gas & Electric
Following are the SDG&E electricity and natural gas tariffs applied in this study. Table 39 describes the baseline territories that were assumed for each climate zone. A net surplus compensation rate of $ 0.01837/ 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 39. SDG&E Baseline Territory by Climate Zone
Climate
Zone
Baseline
Territory
CZ07 Coastal
CZ10 Inland
CZ14 Mountain
The SDG&E monthly gas rate in $/therm was applied on a monthly basis according to the rates shown in Table 40. 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 SDG&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 40 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.

CARE tariffs reflect the 20 percent discount per the G-CARE tariff.

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Table 40. SDG&E Monthly Gas Rate ($/therm)
Month Total Charge
Baseline Excess
January $2.07 $2.36
February $2.01 $2.30
March $1.93 $2.22
April $1.86 $2.16
May $1.88 $2.18
June $1.94 $2.24
July $1.95 $2.25
August $2.02 $2.32
September $1.97 $2.27
October $1.94 $2.24
November $1.97 $2.27
December $2.07 $2.37

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6.3.5 City of Palo Alto Utilities
Following are the CPAU electricity and natural gas tariffs applied in this study. The CPAU monthly gas rate in $/therm was applied on a monthly basis according to the rates shown in Table 41. 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 CPAU’s monthly residential tariffs between 2018 and 2024. 12-month curves were created from monthly gas rates for each of the seven years. The seven 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 41 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. The monthly service charge applied was $16.93 per month per the January 2025 G-1 tariff.

Table 41. CPAU Monthly Gas Rate ($/therm)
Month G1 Volumetric
Total Baseline
G1 Volumetric
Total Excess
January $1.74 $3.02
February $1.33 $2.53
March $1.24 $2.43
April $1.21 $2.39
May $1.21 $2.39
June $1.23 $2.42
July $1.31 $2.64
August $1.37 $2.71
September $1.36 $2.71
October $1.38 $2.72
November $1.45 $2.80
December $1.57 $2.96

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6.3.6 Sacramento Municipal Utilities District (Electric Only) Following are the SMUD electricity tariffs applied in this study. The rates effective January 2025 were used.

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6.3.7 Fuel Escalation Assumptions
The average annual escalation rates in Table 42 and Table 43 were used in this study. Table 42 rates are based on assumptions from the CPUC 2021 En Banc hearings on utility costs through 2030 (California Public Utilities Commission, 2021a). Escalation rates through the remainder of the 30-year evaluation period are based on the escalation rate assumptions within the 2022 TDV factors. No data was available to estimate electricity escalation rates for CPAU and SMUD, therefore electricity escalation rates for PG&E and statewide natural gas escalation rates were applied. Table 43 rates are based on the escalation rate assumptions within the 2025 LSC factors from 2026 through 2055.9 These rates were developed for electricity use statewide (not utility-specific) and assume steep increases in gas rates in the latter half of the analysis period. Data was not available for the year 2026 and so the CPUC En Banc assumptions were applied for those years using the average rate across the three IOUs for statewide electricity escalation.
9https://www.energy.ca.gov/files/2025-energy-code-hourly-factors. (California Energy Commission, 2023). Actual escalation factors were provided by consultants E3.

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 77 2025/08/08
Table 42. Real Utility Rate Escalation Rate Assumptions, CPUC En Banc and 2022 TDV Basis Statewide Natural
Gas Residential
Average Rate
(%/year, real)
Electric Residential Average Rate
(%/year, real)

PG&E SCE SDG&E
2026 4.6% 1.8% 1.6% 2.8%
2027 4.6% 1.8% 1.6% 2.8%
2028 4.6% 1.8% 1.6% 2.8%
2029 4.6% 1.8% 1.6% 2.8%
2030 4.6% 1.8% 1.6% 2.8%
2031 2.0% 0.6% 0.6% 0.6%
2032 2.4% 0.6% 0.6% 0.6%
2033 2.1% 0.6% 0.6% 0.6%
2034 1.9% 0.6% 0.6% 0.6%
2035 1.9% 0.6% 0.6% 0.6%
2036 1.8% 0.6% 0.6% 0.6%
2037 1.7% 0.6% 0.6% 0.6%
2038 1.6% 0.6% 0.6% 0.6%
2039 2.1% 0.6% 0.6% 0.6%
2040 1.6% 0.6% 0.6% 0.6%
2041 2.2% 0.6% 0.6% 0.6%
2042 2.2% 0.6% 0.6% 0.6%
2043 2.3% 0.6% 0.6% 0.6%
2044 2.4% 0.6% 0.6% 0.6%
2045 2.5% 0.6% 0.6% 0.6%
2046 1.5% 0.6% 0.6% 0.6%
2047 1.3% 0.6% 0.6% 0.6%
2048 1.6% 0.6% 0.6% 0.6%
2049 1.3% 0.6% 0.6% 0.6%
2050 1.5% 0.6% 0.6% 0.6%
2051 1.8% 0.6% 0.6% 0.6%
2052 1.8% 0.6% 0.6% 0.6%
2053 1.8% 0.6% 0.6% 0.6%
2054 1.8% 0.6% 0.6% 0.6%
2055 1.8% 0.6% 0.6% 0.6%

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Cost-effectiveness Analysis: Single Family AC to Heat Pump Replacement 78 2025/08/08
Table 43. Real Utility Rate Escalation Rate Assumptions, 2025 LSC Basis Year
Statewide Natural
Gas Residential
Average Rate
(%/year, real)
Statewide
Electricity
Residential
Average Rate
(%/year, real)
2026 4.6% 2.1%
2027 4.2% 0.6%
2028 3.2% 1.9%
2029 3.6% 1.6%
2030 6.6% 1.3%
2031 6.7% 1.0%
2032 7.7% 1.2%
2033 8.2% 1.1%
2034 8.2% 1.1%
2035 8.2% 0.9%
2036 8.2% 1.1%
2037 8.2% 1.1%
2038 8.2% 1.0%
2039 8.2% 1.1%
2040 8.2% 1.1%
2041 8.2% 1.1%
2042 8.2% 1.1%
2043 8.2% 1.1%
2044 8.2% 1.1%
2045 8.2% 1.1%
2046 8.2% 1.1%
2047 3.1% 1.1%
2048 -0.5% 1.1%
2049 -0.6% 1.1%
2050 -0.5% 1.1%
2051 -0.6% 1.1%
2052 -0.6% 1.1%
2053 -0.6% 1.1%
2054 -0.6% 1.1%
2055 -0.6% 1.1%

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TOWN OF LOS ALTOS HILLS November 20, 2025
Staff Report to the City Council
SUBJECT: WAIVER OF READING AND ADOPT AN ORDINANCE FOR THE 2025 CALIFORNIA BUILDING STANDARDS CODE ADOPTION FOR
THE TOWN OF LOS ALTOS HILLS. THE ORDINANCE AMENDS
TITLE 8 (BUILDING REGULATIONS) OF THE LOS ALTOS HILLS

MUNICIPAL CODE TO ADOPT BY REFERENCE ALL TWELVE
PARTS OF THE 2025 CALIFORNIA BUILDING STANDARDS CODE,

INCLUDING THE ADMINISTRATIVE, BUILDING, RESIDENTIAL,

ELECTRICAL, MECHANICAL, PLUMBING, ENERGY, WILDLAND

URBAN INTERFACE, HISTORICAL BUILDING, FIRE, EXISTING

BUILDING, GREEN BUILDING STANDARDS (CALGREEN), AND

REFERENCED STANDARDS CODES, TOGETHER WITH LOCAL

AMENDMENTS AND ADOPT A RESOLUTION OF THE TOWN OF

LOS ALTOS HILLS CONFIRMING CITY POLICY ON GREENHOUSE

GAS EMISSION REDUCTIONS EMANATING FROM BUILDINGS
FROM: Jay Bradford, Community Development Director
APPROVED: Cody Einfalt, Acting City Manager
RECOMMENDATION: That the City Council:

Adopt by title only, and waive second reading of an ordinance introducing the 2025 California Building Standards Code adoption for the Town of Los Altos Hills. The ordinance amends Title 8 (Building Regulations) of the Los Altos Hills Municipal Code to adopt by reference all twelve parts of the 2025 California Building Standards Code, including the Administrative, Building, Residential, Electrical, Mechanical, Plumbing, Energy, Wildland Urban Interface, Historical Building, Fire, Existing Building, Green Building Standards (CALGreen), and Referenced Standards Codes, together with local amendments (see Attachment 1) and adopt a Resolution of the town of Los Altos Hills confirming city policy on greenhouse gas emission reductions emanating from buildings (See Attachment 2).

BACKGROUND:

As noted in the September 18th (See Attachment 3) and October 16th (See Attachment 4) including the CEC specific staff report (See Attachment 5). The International Code Council (ICC) publishes model codes for building, fire, and other related standards on a triennial basis. From these model codes, the California Building Standards Commission, along with the State Fire Marshall and other state agencies, amend and adopt these model codes to create the California Code of Regulations Title 24, also known as the California Building Standards Code (CBSC). The 2025 CBSC was adopted by the California Building Standards Commission on July 1, 2025 and becomes effective statewide on January 1, 2026. Local jurisdictions are required to adopt the new code and may adopt more restrictive standards when justified by findings of local climatic, geologic, and topographic conditions in addition to aligning with regulation introduced July 1, 2025, as part of SB 130.

ITEM 5J STAFF REPORT

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City Council
California Building Standard Code Ordinance Staff Report November 20, 2025
DISCUSSION:

The first reading of proposed local amendments to the 2025 California Building Standards Code City Council made the following motion approving the technical amendments proposed and asked that the administrative sections in sections 2 and 24 be reviewed by the Finance and Investment Committee and Planning Commission before they return to City Council.

City Council October 16, 2025 Motion:
“Waive of reading and introduction of an ordinance for the 2025 California Building Standards Code adoption for the Town of Los Altos Hills. The ordinance amends Title 8 (Building Regulations) of the Los Altos Hills Municipal Code to adopt by reference all twelve parts of the 2025 California Building Standards Code, including the Administrative, Building, Residential, Electrical, Mechanical, Plumbing, Energy, Wildland Urban Interface, Historical Building, Fire, Existing Building, Green Building Standards (CALGreen), and Referenced Standards Codes, together with local amendments. excluding Sections 2 and 24 of the proposed ordinance.” Based on Councils directions and as is practice between the first and second reading of the ordinance, staff has incorporated minor, non-substantive refinements to correct typographical errors, clarify wording, and ensure internal consistency within the local code amendments. These adjustments are part of the Town’s standard ordinance-preparation process and do not alter the intent or effect of the proposed local amendments. The refinements simply improve readability, accuracy, and alignment with the language presented to the City Council at first reading. These modifications are shown in Attachment 1 using the following conventions:
• Deletions → red, strikethrough
• Additions → blue, underlined
• Unchanged lines → normal text
These changes relate to the modification identified by the Santa Clara County Fire Department and representatives for TRC on behalf of Silicon Valley Clean Energy and affect the fire standards in the residential code for residential sprinklers and energy storage systems, and the energy code for prior reach code amendments.

With the adoption of 2025 California Building Standards Code and proposed local amendments to the 2025 California Building Standards Code will go into effect on January 1, 2026.

ENVIRONMENTAL REVIEW:

Adoption of this Ordinance and related building standards codes/local amendments are exempt from review under the California Environmental Quality Act (CEQA) under the general rule that CEQA applies only to projects that have the potential for causing a significant effect on the environment (CEQA Guidelines § 15061(b)(3).). In this case, it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment ITEM 5J STAFF REPORT

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City Council
California Building Standard Code Ordinance Staff Report November 20, 2025
because the proposed code adoption and amendments to not approve any project or grant any entitlements, and so not make any physical alterations to the environment, but rather are regulatory actions taken by the Town and to implement state law, and consist of adopting state-mandated building standards with limited local amendments that either maintain existing requirements or enhance life-safety, fire-resilience, and sustainability provisions. Each project subject to building code/building permit review will have obtained independent environmental review as a part of their entitlements.

FISCAL IMPACT:

The Town is obligated to adopt the 2025 Building Standards and costs in adopting the ordinance are staff time related to ordinance preparation and nominal related publication costs. Costs related to implementing the 2025 Standards, including providing the related building services will be funded with the proposed and existing service fees for the Building Divisions.

ATTACHMENTS

1. Ordinance - Adoption of 2025 CBSC with Local Amendments including Exhibit A Local amendments to the Fire Code

2. Resolution - Confirming Greenhouse Gas Reduction Policy (for CEC submittal)

3. September 18, 2025, Council Study Session Staff Report

4. October 16, 2025, Council Study Session Staff Report

5. October 16, 2025, Supplemental Staff Report (CEC Submittal: Two-Way AC / Heat Pump Transition) including Attachment 3 2025 Single-Family AC-to-Heat-Pump CostEffectiveness Study ITEM 5J STAFF REPORT

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ORDINANCE NO. XXX
AN ORDINANCE OF THE TOWN OF LOS ALTOS HILLS AMENDING TITLE 8 (BUILDING REGULATIONS) OF THE LOS ALTOS HILLS MUNICIPAL CODE TO ADOPT BY REFERENCE AMENDMENTS TO THE 2025 CALIFORNIA BUILDING

STANDARDS CODE AND LOCAL CODE AMENDMENTS
WHEREAS, the Town of Los Altos Hills is responsible for local enforcement of the California Building Standards Code, also known as Title 24 of the California Code of Regulations; and
WHEREAS, a triennial edition of the California Building Standards Code is published by the California Building Standards Commission approximately every three years based upon model codes specified in the California Health and Safety Code; WHEREAS, local jurisdictions responsible for enforcement of the California Building Standards Code must enact local administrative regulations in order to implement the California Building Standards Code; and
WHEREAS, on July 1, 2025, the California Building Standards Commission published the 2025 California Building Standards Code; and
WHEREAS, on January 1, 2026, the building standards and regulations contained in the 2025 California Building Standards Code become effective and applicable throughout the State of California; and
WHEREAS, Government Code section 50022.2 authorizes cities to enact ordinances adopting any code by reference; and
WHEREAS, local amendments may be adopted by the Town of Los Altos Hills to the California Building Standards Code pursuant to the California Health and Safety Code due to climatic, geological, or topographical local conditions; and WHEREAS, California Health and Safety Code section 17958 requires that cities adopt building regulations that are substantially the same as those adopted by the California Building Standards Commission and contained in the 2025 California Building Standards Code; and WHEREAS, the 2025 California Energy Code is Part 6 of the 2025 California Building Standards Code which implements minimum energy efficiency standards in buildings through mandatory requirements, prescriptive standards, and performance standards; and WHEREAS, California Health and Safety Code Sections 17958.5, 17958.7 and 18941.5 provide that the Town of Los Altos Hills may make changes or modifications to the building standards contained in the 2025 California Building Standards Code based upon express findings ITEM 5J ATTACHMENT 1

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that such changes or modifications are reasonably necessary because of local climatic, geological or topographical conditions; and
WHEREAS, human activities that release greenhouse gases into the atmosphere contribute to the increase of the worldwide average temperature, drought conditions, and duration of fire seasons; and
WHEREAS, according to the California Department of Forestry and Fire Protection, nine of the ten largest wildfires in California history have occurred since 2017, destroying nearly 10,000 structures and burning of more than 4.5 million acres; and WHEREAS, the Town of Los Altos Hills is situated along a wildland-urban interface and as a result is extremely vulnerable to wildfires and firestorms; and WHEREAS, these amendments are reasonably necessary because of health and safety concerns as Town of Los Altos Hills residents suffer from asthma and other health conditions associated with poor indoor and outdoor air quality exacerbated by the combustion of methane gas; and
WHEREAS, removing gas appliances from indoor environments reduces the risk of asthma associated with gas appliances, and removing combustible gas from structures aids in fire hardening and removes a known hazard during firefighting efforts; and WHEREAS, on or about September 20, 2016, the State of California enacted Senate Bill (SB) 32, which added Health and Safety Code Section 38566 to require greenhouse gas emissions to be reduced to 40 percent below 1990 levels by no later than December 31, 2030; and WHEREAS, consistent with federal law stated in the Energy Policy and Conservation Act, the standards contained within this ordinance permit mixed fuel residential construction; and WHEREAS, consistent with Assembly Bill (AB) 130, the standards contained within this ordinance permit mixed fuel residential construction consistent with federal law while also incentivizing all-electric construction; and
WHEREAS, consistent with AB 130, the standards imposed by this ordinance incentivize electric equipment through the cost-effective installation of electric appliances while preserving energy-equivalent pathways for mixed-fuel residential appliances; and WHEREAS, pursuant to Sections 17958.5 and 17958.7 of the Health and Safety Code, the proposed amendments meet the following conditions to demonstrate local amendments are necessary, the changes are substantially equivalent to 2022 code amendment changes, and the changes are necessary to implement the standards contained in this ordinance; and WHEREAS, pursuant to Sections 17958.5 and 17958.7 of the Health and Safety Code, the proposed amendments meet the following conditions to demonstrate local amendments are necessary: the changes are necessary to align local building codes with General Plan and Climate ITEM 5J ATTACHMENT 1

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Action Plan goals while permitting mixed-fuel residential construction and incentivizing electric construction, and the changes are necessary to implement the standards contained in this ordinance; and
WHEREAS, on April 26, 2007, the City Council adopted the Town of Los Altos Hills’ General Plan which includes Air Quality, Energy Conservation and Environmental Integrity Goals that aligns with the emissions reduction goals in the proposed amendments; and WHEREAS, on December 15, 2016, the City Council adopted the Town of Los Altos Hills’ Climate Action Plan or Greenhouse Gas Emissions Reductions Strategy which includes Green Housing Gas reduction strategies that aligns with the emissions reduction goals in the proposed amendments; and
WHEREAS, on Feb 20, 2020, the City Council found and determined that amendments to the 2019 Energy Code were cost effective, would result in buildings designed to consume less energy than permitted by previous editions of the Energy Code, and were necessary because of local climatic, geological, or topographical conditions, and City Council finds and determines the conditions persist and it is necessary to adopt substantially equivalent amendments to the 2025 Energy Code with no material change in regulatory effect to the existing standards; and WHEREAS, in alignment with the Climate Action Plan and Greenhouse Gas Emissions Reduction Strategies, the local amendments to the 2025 California Energy Code establish requirements for single-family and multifamily structures which will reduce demands for local energy resources, reduce regional pollution, and promote a lower contribution to greenhouse gas emissions; and
WHEREAS, Public Resources Code Section 25402.1(h)2 and Section 10-106 of the 2025 California Administrative Code establish a process which allows local adoption of energy standards that are more stringent than the statewide Standards, provided that a determination that the standards are cost effective is adopted at a public meeting and subsequently filed with the California Energy Commission, and the California Energy Commission finds that the standards will require buildings to be designed to consume less energy than permitted by the 2025 California Energy Code; and
WHEREAS, City Council of Town of Los Altos Hills has determined the cost effectiveness studies prepared by the California Statewide Codes and Standards Reach Code Program and associated study data are sufficient to illustrate that the standards contained in this ordinance are cost effective and will require buildings to be designed to consume less energy than permitted by the 2025 California Energy Code; and
WHEREAS, based upon these analyses, the City Council of the Town of Los Altos Hills finds that the local amendments to the California Energy Code contained in this ordinance have at least one cost effective pathway; and
ITEM 5J ATTACHMENT 1

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WHEREAS, scientific evidence has established that methane gas combustion, procurement and transportation produce significant greenhouse gas emissions that contribute to global warming and climate change; and
WHEREAS, using electric appliances in buildings fueled by less greenhouse gas intensive electricity is linked to significantly lower greenhouse gas emissions and is cost competitive because of the cost savings associated with avoiding new gas infrastructure; and WHEREAS, the most cost-effective time to integrate electrical infrastructure is in the design phase of a building project because building systems and spaces can be designed to optimize the performance of electrical systems and avoid costs and space requirements from the mitigating of gas piping and venting; and
WHEREAS, the most cost-effective time to improve the energy efficiency of existing buildings is during significant alterations and additions, allowing for electrical infrastructure that is installed alongside other significant improvements; and WHEREAS, the local amendments support Town of Los Altos Hills’ compliance with Bay Area Air District’s amendments to Rule 9-4 and Rule 9-6, which limit[s] the sale of nitrous oxide emitting water and space heating appliances; and
WHEREAS, because of the Town of Los Altos Hills’ unique local climatic, geological and topographic conditions, the City Council of the Town of Los Altos Hills finds and determines that amendment and additions to the code are reasonably necessary.

NOW THEREFORE, THE CITY COUNCIL OF THE TOWN OF LOS ALTOS HILLS, CALIFORNIA, does hereby ordain as follows:

SECTION 1. FINDINGS.

The City Council finds that:

A. The Town is authorized and required to adopt the California Building Standards Code by reference pursuant to Health and Safety Code sections 17922 and 17958, and has taken all actions required to do so pursuant to Government Code Section 50022.2.

B. Town of Los Altos Hills is along a wildland-urban interface which experiences more fire fueled by greenhouse gas emissions from humans.

C. The Town of Los Altos Hills has a history of wildfire disasters and near-miss events in 1985, 2008, and 2020, each of which threatened lives, property, and infrastructure within and adjacent to the Town’s boundaries. The Lexington Fire (1985) burned over 14,000 acres in the nearby Santa Cruz Mountains, leading to large evacuations in western Los Altos Hills; the Summit Fire (2008) and CZU Lightning Complex Fire (2020) generated regional smoke impacts and evacuation advisories for hillside neighborhoods. Decreasing greenhouse-gas emissions and transitioning to non-combustion building systems will help ITEM 5J ATTACHMENT 1

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mitigate the climatic conditions contributing to longer, more severe fire seasons.

Therefore, these findings support the imposition of measures to increase the efficiency and electrification of existing buildings in Los Altos Hills to reduce greenhouse-gas emissions and improve fire safety.

D. The Town’s steep terrain, narrow and winding roads, and limited secondary access routes require clear street identification, address visibility, and adequate fire apparatus access because long driveways and private roads frequently exceed standard response distances and grades.

E. The Town is located entirely within or adjacent to locally designated High and Very High Fire Hazard Severity Zones. The combination of steep slopes, dense vegetation, and seasonal winds creates extreme fire behavior potential, requiring ignition-resistant construction, ember-resistant vents, and noncombustible fencing and decking materials.

F. The Town lies within an area subject to strong ground motion and potential rupture from the nearby San Andreas, Monte Vista, and Hayward fault zones. Local soils are prone to liquefaction, landslide, and lateral spreading; therefore, enhanced structural inspection and foundation design standards are needed to mitigate seismic risk.

G. The Town’s soils are characterized by highly expansive clay and colluvium on sloping terrain, which can cause differential settlement and structural movement. Additional geotechnical and foundation drainage requirements are necessary to prevent structural damage and slope instability.

H. The Town relies on two separate water service providers—the Purissima Hills Water District and California Water Service Company—with limited pressure zones and supply capacity. Topographic variability reduces flow capacity and pressure reliability, requiring on-site water storage and enhanced hydrant spacing standards.

I. The Town’s overhead electrical distribution system is vulnerable to wind and wildfire exposure, and public safety power shutoff events occur frequently during red-flag conditions. Enhanced service disconnect accessibility and backup power capabilities are necessary to maintain water supply and emergency systems.

J. Hillside development in the Town requires specialized backflow and drainage provisions to prevent contamination or surcharge of private systems during high rainfall events.

K. The Town experiences a Mediterranean climate with hot, dry summers and wet winters, averaging approximately 24 inches of annual rainfall. Storm events can trigger erosion, debris flow, and shallow landslides on steep slopes, while prolonged dry periods and seasonal winds heighten wildfire risk. Local amendments are necessary to address site drainage, vegetation clearance, and structure hardening requirements consistent with regional conditions in the Santa Cruz Mountains foothill environment.

L. Failure to address and substantially reduce greenhouse gas emissions creates an increased risk to the health, safety, and welfare of Los Altos Hills residents.

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M. The standards imposed by this ordinance permit mixed-fuel residential construction consistent with federal law while also incentivizing all-electric construction as part of an adopted greenhouse gas emissions reduction strategy.

N. The standards imposed by this ordinance incentivize electric equipment through the costeffective installation of electric appliances while preserving energy-equivalent pathways for mixed-fuel residential appliances.

O. Pursuant to Sections 17958.5 and 17958.7 of the Health and Safety Code, the proposed amendments meet the following conditions to demonstrate local amendments are necessary: the changes are substantially equivalent to 2022 code amendment changes, the changes are necessary to align local building codes with General Plan and Climate Action Plan goals while permitting mixed-fuel residential construction and incentivizing electric construction, and the changes are necessary to implement the standards contained in this ordinance.

P. The standards imposed by this Ordinance are substantially equivalent to changes or modifications that were previously passed by the Town Council of the Town of Los Altos Hills on November 17, 2022 through Ordinance No. 611, which adopted local amendments to the 2022 California Energy Code and Green Building Standards Code (the Town’s 2022 Reach Code). Those amendments were filed with the California Energy Commission on December 19, 2022 and were in effect as of September 30, 2025.

The provisions of this Ordinance maintain substantially equivalent regulatory requirements—updated for cross-references to the 2025 California Energy Code—and therefore will have no material change in regulatory effect from the prior Reach Code standards.

Q. The standards imposed by this Ordinance are necessary because they align with the Los Altos Hills General Plan, adopted November 10, 2007, which establishes the Town’s long-term policies on sustainability and resource conservation. The Conservation and Open Space Element includes the following relevant policies:
• Goal 1: “Conserve, protect and enhance the natural environment to maintain the rural character and ensure a high quality of life.”
• Policy 1.2: “Encourage the use of energy-efficient building design and alternative energy sources.”
• Policy 1.4: “Encourage efforts to reduce the Town’s contribution to greenhouse gas emissions.”
R. These General Plan provisions explicitly direct the Town to promote energy efficiency and low-carbon building practices. Accordingly, the standards contained in this Ordinance—requiring heat pump installation in place of traditional air-conditioning systems and incentivizing electrification—are necessary to implement these adopted General Plan policies.

S. The standards imposed by this Ordinance are substantially equivalent to changes or modifications that were previously passed by the Town Council of the Town of Los Altos ITEM 5J ATTACHMENT 1

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Hills on November 17, 2022 (Ordinance No. 611) and filed with the California Energy Commission on December 19, 2022, which established local reach code amendments requiring all-electric design standards and promoting low-NOx equipment. These provisions were in effect as of September 30, 2025, and this Ordinance will have no material change in regulatory effect but instead maintains substantially equivalent standards updated to the 2025 California Energy Code
T. The standards imposed by this Ordinance are necessary because these standards align with the Los Altos Hills General Plan, adopted November 10, 2007 and subsequently amended, which includes Conservation and Open Space Element Policy 1.2— “Encourage the use of energy-efficient building design and alternative energy sources”— and Energy Conservation Goal 1—“Promote conservation and efficient use of energy and natural resources within the community.” These General Plan policies direct the Town to advance sustainable building practices that reduce greenhouse gas emissions, improve air quality, and enhance community resilience.

U. Pursuant to the Public Resources Code section 25402.1(h)(2) and Section 10-106 of the 2025 California Administrative Code, the City Council of Los Altos Hills finds and determines the following: (1) The locally adopted energy efficiency standards contained in this ordinance are cost-effective, and (2) the efficiency standards in this ordinance will require buildings to be designed to consume less energy compared to the 2025 California Energy Code.

V. The standards imposed by this Ordinance are necessary because of local climatic, geological, or topographical conditions evidenced above and are cost-effective, as supported by the 2025 Statewide Cost Effectiveness Study prepared by the California Energy Codes and Standards Statewide Utility Program. Specifically, the Los Altos Hills finds that there are at least [three] cost effective measure packages:
a. Package 1, installing the efficiency measure of R-30 Floor Insulation would save energy relative to the base code and would achieve a benefit to cost ratio of 2.3 on an on-bill basis.
b. Package 2, installing the efficiency measure of R-19 Floor Insulation would save energy relative to the base code and would achieve a benefit to cost ratio of 2.3 on an on-bill basis.
c. Package 3 Package 3 to installing a Heat Pump Water Heater (HPWH), would save energy relative to the base code and would achieve a benefit to cost ratio of

1.6 on a “Long-term System Cost” (LSC basis).

W. A first reading introducing the proposed amendments to the Municipal Code was held by the City Council on October 16, 2025.

X. In accordance with CEQA Section 15061(b)(3), this is not a project subject to CEQA in that there is no possibility that the activity in question may have a significant effect on the environment.

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Y. This ordinance is enacted pursuant to Health & Safety Code Sections 17958.5 and 17958.7 and Government Code Section 50022.2 to make local amendments to the California Building Standards Code.

Z. As required Health and Safety Code 17958.7(a), the amendments to the California Building Standards Code adopted by this ordinance and as described in Chapters 8-1.0 through 8-

1.12 of the Los Altos Hills Municipal Code are necessary for the protection of the public health, safety and welfare due to the local climatic, geologic or topographical conditions as described in findings 1 through 4 below.

1. The amendment to the California Residential Code Section R313.2, California Fire Code Part 9, California Plumbing Code Section 1211.0 and California Electrical Code 230.27(E) is necessary to address an imminent threat to the health and safety of the public by ensuring that local construction and building standards adequately mitigate hazards posing immediate or significant risks to residents, first responders, and public infrastructure.

2. The amendment to California Wildland-Urban Interface Code Section [A]101.1, [A]101.2, [A]101.3, 101.3.1, 101.3.1.1, [A]101.5, and 705.11 is necessary to reduce wildfire ignition potential and enhances structural protection from fire through strengthened home-hardening provisions, ignition-resistant construction requirements, and vegetation management standards appropriate for high and very high fire hazard severity zones.

3. The amendment to the California Energy Code Part 6 and California Green Building Standards Code Part 11 is consistent with the Town’s General Plan and Climate Action Plan, both adopted prior to June 10, 2025, which include greenhouse-gas reduction and energy-efficiency strategies requiring implementation through updated local construction and building standards.

4. The amendment to California Residential Code Section R328.7, California Plumbing Code Section 719.1, and California Fire Code Part 9 continues and clarifies existing local provisions adopted prior to September 30, 2025, maintaining substantially equivalent protections and performance standards necessary to address the Town’s unique climatic, geologic, and topographic conditions.

While the adoption of the amendments to the California Building Standards Code and the adoption of Ordinances may not prevent the incidence of fire, seismic, or potential building hazards, it is noted the implementation of these various amendments will reduce the severity and potential loss of life and loss of property.

The following revisions to the Los Altos Hills Municipal Code are made based on the findings set forth above and the record of proceedings for consideration of this Ordinance.

SECTION 2. Chapter 8-0, “GENERAL PROVISIONS AND PENALTIES” of the Los Altos Hills Municipal Code is added as follows:

Chapter 8-0, “General Provisions and Penalties
§ 8-0.01 - References to prior code.

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Unless superseded and expressly repealed, references in the City’s forms, documents and regulations to the Chapters and Sections of the past adopted regulations of the Los Altos Hills Municipal Code, Title 8 - Building Regulations and any prior versions of the California Building Standards Code shall be construed to apply to the corresponding provisions contain within the currently adopted Los Altos Hills Municipal Code, Title 8 - Building Regulations and the 2025 California Building Standards Code.
§ 8-0.02 - Adopted - Administrative provisions.
“2025 California Building Code, Part 1, Chapter 1, Division II - “Scope and Administration,” adopted in its entirety:

The provisions of the 2025 California Building Code, Part 1, Chapter 1, Division II - Scope and Administration is adopted by reference, subject to the following additions and amendments to certain sections thereof which shall read and provide as set forth in this Chapter and shall apply to all locally enforced parts of Title 24 of the California Code of Regulations."
§ 8-0.03 Amended sections of adopted codes.

Notwithstanding the provisions of Section 8-0.02, the Administrative provisions is amended as follows:

Section 104.10.2 -Added- Permit Extensions – Construction Time Limits. (A) In addition to the provisions of Sections 105.5 and 110.6 of the California Building Code relating to permit expiration, suspension, and revocation, the duration and extension of any building, grading, or other construction permit issued under this Code shall be governed by the provisions of Chapter 8-10, “Construction Time Limits,” of the Los Altos Hills Municipal Code.
(B) No permit shall be extended, renewed, or reinstated in a manner that would conflict with the time limits, extension criteria, or penalties set forth in Chapter 8-10. The Building Official shall ensure that all requests for extension comply with the administrative procedures and findings required by that Chapter.
(C) Where a conflict exists between this Code and Chapter 8-10, the provisions of Chapter 8-10 shall govern.
(D) Nothing in this section shall limit the authority of the Building Official to require updated plans, code compliance, or payment of fees as a condition of extension or renewal, consistent with current code requirements.

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Section 107.2.9 - Added - Additional Documentation.

The Building Official may require photographic evidence, a physical inspection or similar documentation of existing conditions at time of building permit application for residential alterations and repairs to ensure compliance with local grading, drainage, vegetation management, and slope stability requirements.

Section 109.6 - Amended - Refunds.

Refunds of fees paid may be made, subject to the following:

A. Applications for refunds must be made in writing to the building official within one hundred eighty (180) days of the date the fee is paid. All applicants made after one hundred eighty (180) days will be rejected.

B. One hundred per cent (100%) of a fee erroneously paid or collected may be refunded.

C. Ninety percent (90%) of the plan review fee may be refunded when an application for a permit for which a plan review fee has been paid is withdrawn or cancelled or expires or becomes void before any plan review effort has been expended. No portion of the plan review fee shall be refunded when any plan review effort has been performed.

D. Ninety percent (90%) of the building, plumbing, electrical, and/or mechanical permit fee may be refunded when a permit for which some or all of these permit fees have been paid is withdrawn or cancelled or expires or becomes void before any work was done and before any inspections are performed. No portion of these fees shall be refunded when any work was done and/or any inspections have been performed.

E. The building official may authorize the refund of all or part of a fee in order to correct an error by the department. The details of such a refund shall be retained in project file.

Section 109.7 - Added - Fee adjustments.

Any adjustments to fees are subject to the following:

A. Application for a fee adjustment must be made in writing to the building official within thirty (30) days of the date the fee is issued.

B. The building official may authorize the adjustment of all or part of a fee in order to correct an error by the department. The details of such an adjustment shall be retained in project file.

Section 109.8 - Added - Fee collections.

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Any unpaid fees shall be subject to the same collection measures outlined in Chapter 1.15 of the Los Altos Hills Municipal Code.

Section 110.7 - Added - Concealed construction.

Any and all portions of work covered or concealed without authorization by the building official shall be uncovered or unconcealed to allow for inspections set forth in Sections 110.3.1 - 110.3.10. The Town’s “Concealed Construction Verification Guidelines” shall be used to determine compliance with this section.

Section 113.3 - Amended - Appeals applications.

All applications for appeals of orders, decisions or determinations made by the building official relative to the application and interpretation of this code shall be subject the Town’s “Building Appeals Board Guidelines” and fees as outlined in the Building Plan Check, Inspection and Permit Fees Schedule as established or amended by Town Council resolution.

Section 114.2 - Amended - Notice of violation.

The building official is authorized to serve a notice of violation or order on the person responsible for the erection, construction, alteration, extension, repair, moving, removal, demolition or occupancy of a building or structure in violation of the provisions of this code, or in violation of a permit or certificate issued under the provisions of this code. Such order shall direct the discontinuance of the illegal action or condition and the abatement of the violation. Method of service shall be subject to Section 116.4.

Section 114.3 - Added - Prosecution of violation.

Added after first paragraph.

In addition if the notice of violation is not complied with within thirty (30) days the Town may deem the structure unsafe and subject to the terms of Section 116.

Section 114.4 - Amended - Violation penalties.

All persons and construction shall be subject to the following:

A. Any and all portions of work shall be complete and free of correction notices and or violations prior to the expiration of the permit or certificate authorizing said work or occupancy. The Town’s Outstanding Correction Notifications and Expired Permits or Certificates Guidelines shall be used to determine compliance with this section and the applicability of fines for non-compliance.

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B. Any and all portions of work completed without required permits shall be charged a fine of twice the cost of the plan review and inspection fee.

C. Any person who violates a provision of this code or fails to comply with any of the requirements thereof or who erects, constructs, alters or repairs a building or structure in violation of the approved construction documents or directive of the building official, or of a permit or certificate issued under the provisions of this code, shall be subject to penalties as prescribed by law.

Section 114.5 - Added - Fee or fine adjustments.

Any adjustments to fines are subject to the following:

A. Application for a fine adjustment must be made in writing to the building official within thirty (30) days of the date the fine is issued.

B. The building official may authorize the adjustment of all or part of a fine in order to correct an error by the department. The details of such an adjustment shall be retained in project file.

Section 114.6 - Added - Fine collections.

Any unpaid fines shall be subject to the same collection measures outlined in Chapter 1-2.04 of the Los Altos Hills Municipal Code. ([added current code adoption])
SECTION 3. Chapter 8-1, “CALIFORNIA ADMINISTRATIVE CODE” of the Los Altos Hills Municipal Code is repealed and replaced as follows:
§ 8-1.01 Adoption of the 2025 California Administrative Code. (a) The 2025 California Administrative Code, Part 1, a portion of the California Building Standards Code, Title 24 of the California Code of Regulations, as defined in the California State Health and Safety Code Section 18901 et seq., (hereinafter referred to as the "Administrative Code"), and any rules and regulations promulgated pursuant thereto are hereby adopted and incorporated by reference herein.
(b) One copy of the Administrative Code shall be kept on file at the Town of Los Altos Hills.
(§ 2, Ord. 558, eff. February 15, 2015; § 1, Ord. 568, eff. March 16, 2017; § 1, Ord. 585, eff. January 18, 2020; § 1, Ord. 604, eff. November 17, 2022, [added current code adoption])
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SECTION 4. Chapter 8-1.1, “CALIFORNIA BUILDING CODE (VOLUMES 1 AND 2)” of the Los Altos Hills Municipal Code is repealed and replaced as follows:
§ 8-1.1.01 Adoption of 2025 California Building Code (Volumes 1 and 2). (a) The 2025 California Building Code, Part 2, Volumes 1 and 2, a portion of the California Building Standards Code, Title 24 of the California Code of Regulations, as defined in the California State Health and Safety Code Section 18901 et seq., (hereinafter referred to as the "Building Code"), including all Appendices and any rules and regulations promulgated pursuant thereto are hereby adopted and incorporated by reference herein.
(b) One copy of the Building Code shall be kept on file at the Town of Los Altos Hills.
§ 8-1.1.02 Amended sections of adopted codes.
§ 8-1.1.03 Amended sections of adopted codes.

Notwithstanding the provisions of Section 8-1.1.01, the California Building Code is amended as follows:

Section 1705.13.5 - Added - Special seismic inspector.

Third-Party Inspection. All new structures consisting of Group R Occupancies or Group A, B, E, F, H, I, l, or M Occupancies with an occupant load of fifty or greater, shall employ a third-party inspector for the purpose of inspecting the components of the lateral load system. Third-party inspectors, similar to special inspectors as required elsewhere in Chapter 17, shall be approved by the building official. All costs associated with the special seismic inspection process shall be borne by the developer. § 8-1.1.04 -Added- Conflicts between the Fire Code and Building Code All 2025 California Building Code standards including fire protection systems must comply with the requirements specified in Chapter 8-1.9 of this title. To the extent there is any conflict between the provisions of Chapter 8-1.9 of this title and the provisions of 2025 California Building Code and specifically Chapter 9, the provisions of Chapter 8-1.9 of this title shall govern. (§ 1, Ord. 558, eff. February 15, 2015; § 1, Ord. 568, eff. March 16, 2017; § 1, Ord. 585, eff. January 18, 2020; § 1, Ord. 604, eff. November 17, 2022, [added current code adoption])
SECTION 5. Chapter 8-1.2, “CALIFORNIA RESIDENTIAL CODE” of the Los Altos Hills Municipal Code is repealed and replaced as follows:
§ 8-1.2.01 Adoption of 2025 California Residential Code.

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(a) The 2025 California Residential Code, Part 2.5, Title 24 of the California Code of Regulations, a portion of the California Building Standards Code, as defined in the California State Health and Safety Code Section 18901 et seq., (hereinafter referred to as the "Residential Code"), including all Appendices and any rules and regulations promulgated pursuant thereto are hereby adopted and incorporated by reference herein.
(b) One copy of the Residential Code shall be kept on file at the Town of Los Altos Hills.
§ 8-1.2.02 Amended sections of adopted codes.

Notwithstanding the provisions of Section 8-1.2.01, the Residential Code is hereby amended to read as follows:

Section R31309.2 is amended to read:

R313.2 One- and two-family dwellings automatic sprinkler systems. An automatic sprinkler system shall be installed in all new one- and two-family dwellings and existing one- and two-family dwellings when additions are made that increase the fire area to more than 3,600 square feet.

Exceptions:

1. Detached Accessory Dwelling Unit, provided that all of the following are met:

1.1. The unit meets the definition of an Accessory Dwelling Unit as defined in the Government Code Section 65852.2.

1.2. The existing primary residence does not have automatic fire sprinklers.

1.3. The accessory detached dwelling unit does not exceed 1,200 square feet in size.

1.4. The unit is on the same lot as the primary residence.

1.5. The unit meets all apparatus access and water supply requirements of Chapter 5 and Appendix B of the 2025 California Fire Code, as amended.

2. When additions are made to existing structures, causing the fire area to exceed 3,600 square feet, and all of the following are met:

2.1. Building addition does not exceed 500 square feet.

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2.2. The resultant structure meets all water supply requirements of Chapter 5 and Appendix B of the 2022 California Fire Code, as amended.

Section R328.7 is amended to read:

R328.7 Fire detection. Rooms and areas within dwelling units, basements and attached garages in which ESS are installed shall be protected by smoke alarms in accordance with Section R314. A heat detector, listed and interconnected to the smoke alarms, shall be installed in locations within dwelling units and attached garages where smoke alarms cannot be installed based on their listing.
[SFM] ESS installed in Group R-3 and townhomes shall comply with the following:

1. Rooms and areas within dwelling units, sleeping units, basements and attached garages in which ESS are installed shall be protected by smoke alarms in accordance with Section R314.

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 devices that provide an audible alarm at all sleeping 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.

Section R330.3.1 is amended to read:

Individual ESS units shall be separated from each other by at least 3 feet (914 mm) except where other separation distances are specified by the ESS listing and the manufacturer’s installation instructions separation distances are documented to be adequate based on large-scale fire testing complying with Section 1207.1.7.

Section R330.4 is amended to read:

ESS shall be installed only in the following locations:

1. Detached garages and detached accessory structures.

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

3. Outdoors or on the exterior side of exterior walls located not less than 3 feet (914 mm) from doors and windows directly entering the dwelling unit, except where smaller separation distances are permitted by the UL 9540 listing and manufacturer’s installation instructions and shall not be located below or above any emergency escape and rescue openings.

4. Enclosed utility closets, basements, and storage or utility spaces within dwelling units and sleeping 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. Openings into the dwelling shall be equipped with solid wood doors not less than 1-3/8 inches (35 mm) in thickness, solid or honeycombcore steel doors not less than 1-3/8 inches (35 mm) in thickness, or doors with a 20-minute fire protection rating. Doors shall be self-latching and equipped with a self-closing or an automatic-closing device. Penetrations through the required gypsum wallboard into the dwelling shall be protected as required by Section R302.11, Item 4.

ESS shall not be installed in sleeping rooms, or in closets or spaces opening directly into sleeping rooms. (Material based on NFPA 855 2023 Ed.) Section R330.7 is amended to read:

Rooms and areas within dwelling units, basements and attached garages in which ESS are installed shall be protected by smoke alarms in accordance with Section R310. A heat detector, listed and interconnected to the smoke alarms, shall be installed in locations within dwelling units and attached garages where smoke alarms cannot be installed based on their listing. [SFM] ESS installed in Group R-3 and townhomes shall 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 R314.

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 devices that provide an audible alarm at all sleeping areas.

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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.
(§ 2, Ord. 558, eff. February 15, 2015; § 1, Ord. 568, eff. March 16, 2017; § 1, Ord. 585, eff. January 18, 2020; § 1, Ord. 588, eff. January 18, 2020; § 1, Ord. 604, eff. November 17, 2022; § 1, Ord. 607, eff. January 6, 2023, [added current code adoption]) SECTION 6. Chapter 8-1.3, “CALIFORNIA ELECTRICAL CODE” of the Los Altos Hills Municipal Code is repealed and replaced as follows:
§ 8-1.3.01Adoption of 2025 California Electrical Code.
(a) The 2025 California Electrical Code, Part 3, Title 24 of the California Code of Regulations, a portion of the California Building Standards Code, as defined in the California State Health and Safety Code Section 18901 et seq., (hereinafter referred to as the "Electrical Code"), and any rules and regulations promulgated pursuant thereto are hereby adopted and incorporated by reference herein. (b) One copy of the Electrical Code shall be kept on file at the Town of Los Altos Hills.
§ 8-1.3.02 Amended sections of adopted codes.

Notwithstanding the provisions of Section 8-1.3.01, the Residential Code is hereby amended to read as follows:

Sections 230.79(E) - Amended - One- or Two-Family Dwelling or Townhomes.

For existing one- or two-family dwellings and townhomes, the service disconnecting means may require upgrades when any of the following requirements are exceeded:

1. When any other permit is applied for and the existing main service enclosure was manufactured by Federal Pacific or Zinsco, including such panels that have been rebranded.

2. When any other permit is applied for and the enclosure contains disconnecting mean on the load side of the service disconnect manufactured by Federal Pacific or Zinsco, including such panels that have been rebranded.

3. When Five (5) or more circuits are modified.

4. When any secondary power source is added.

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Note: The rating requirements of the bus bar and enclosure for the service disconnecting means do not require the main service entrance conductors to be upgraded as long as the main service disconnect is rated to match the rating and sizing of the existing main service entrance conductors. (§ 2, Ord. 558, eff. February 15, 2015; § 1, Ord. 568, eff. March 16, 2017; § 1, Ord. 585, eff. January 18, 2020; § 1, Ord. 604, eff. November 17, 2022, [added current code adoption])
SECTION 7. Chapter 8-1.4, “CALIFORNIA MECHANICAL CODE” of the Los Altos Hills Municipal Code is repealed and replaced as follows:
§ 8-1.4.01Adoption of 2025 California Mechanical Code.
(a) The 2025 California Mechanical Code, Part 4, Title 24 of the California Code of Regulations, a portion of the California Building Standards Code, as defined in the California State Health and Safety Code Section 18901 et seq., (hereinafter referred to as the "Mechanical Code"), and any rules and regulations promulgated pursuant thereto are hereby adopted and incorporated by reference herein. (b) One copy of the Mechanical Code shall be kept on file at the Town of Los Altos Hills.
(§ 2, Ord. 558, eff. February 15, 2015; § 1, Ord. 568, eff. March 16, 2017; § 1, Ord. 585, eff. January 18, 2020; § 1, Ord. 604, eff. November 17, 2022, [added current code adoption])
SECTION 8. Chapter 8-1.5, “CALIFORNIA PLUMBING CODE” of the Los Altos Hills Municipal Code is repealed and replaced as follows:
§ 8-1.5.01Adoption of 2025 California Plumbing Code.
(a) The 2025 California Plumbing Code, Part 5, Title 24 of the California Code of Regulations, a portion of the California Building Standards Code, as defined in the California State Health and Safety Code Section 18901 et seq., (hereinafter referred to as the "Plumbing Code"), and any rules and regulations promulgated pursuant thereto are hereby adopted and incorporated by reference herein. (b) One copy of the Plumbing Code shall be kept on file at the Town of Los Altos Hills.
§ 8-1.5.02Amended sections of adopted code.

Notwithstanding the provisions of Section 8-1.5.01, the Plumbing Code is amended as follows:

Section 719.1 - Amended -Locations.

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Cleanouts shall be placed inside the building near the connection between the building drain and the building sewer or installed outside the building at the lower end of the building drain and extended to grade.

Additional building sewer cleanouts shall be installed at intervals not to exceed 100 feet in straight runs, for each aggregate horizontal change in direction exceeding 135 degrees, and at the property line where the private sewer system connects to the publicly-maintained sanitary sewer lateral. All such cleanouts shall be extended to grade with materials and according to specifications approved by the sewer agency and shall terminate with a concrete box.

Section 1211.0 –Added- Earthquake-Activated Gas Shutoff Valves (A) In addition to the requirements of this section, an earthquake-activated gas shutoff valve shall be installed downstream of the gas utility meter or at the service regulator for all new buildings and for existing buildings at the time of any gas piping permit or appliance replacement that alters the gas system. (B) The device shall be certified by the State Architect and installed per manufacturer specifications.
(C) The requirement shall apply to all occupancies within the Town of Los Altos Hills.
(D) This section supplements the California Plumbing Code, Part 5, Title 24, and is adopted pursuant to Health and Safety Code §§ 17958.5 and 17958.7 based on local seismic conditions.

Note: Property Owners Opting to install Earthquake-Activated Gas Shutoff Valves may apply for a not fee permit.
(§ 2, Ord. 558, eff. February 15, 2015; § 1, Ord. 568, eff. March 16, 2017; § 1, Ord. 585, eff. January 18, 2020; § 1, Ord. 604, eff. November 17, 2022, [added current code adoption])
SECTION 9. Chapter 8-1.6, “CALIFORNIA ENERGY CODE” of the Los Altos Hills Municipal Code is repealed and replaced as follows:
§ 8-1.6.01 Adoption of 2025 California Energy Code.
(a) The 2025 California Energy Code, Part 6, Title 24 of the California Code of Regulations, a portion of the California Building Standards Code, as defined in the California State Health and Safety Code Section 18901 et seq., (hereinafter referred to as the "Energy Code"), and any rules and regulations promulgated pursuant thereto are hereby adopted and incorporated by reference herein. (b) One copy of the Energy Code shall be kept on file at the Town of Los Altos Hills.

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§ 8-1.6.02 Amended sections of adopted code.

Notwithstanding the provisions of Section 8-1.6.01, the Energy Code is amended as follows:

Section 100.0 Scope under subsection (e)(2)(D) Low-rise residential buildings is amended to read as follows:
i. Sections applicable. Sections 150.0 through 150.1 apply to newly constructed low-rise residential buildings. In addition, all newly constructed residences, newly constructed detached accessory dwelling units, and other newly constructed detached habitable structures shall be electrically heated mixed-fuel buildings as defined in Section 100.1(b).

Section 100.1(b) Definitions is amended by adding or amending the following definitions to read:

All-electric building is a building that has no natural gas or propane plumbing installed within the building, and that uses electricity as the source of energy for its space heating, water heating, cooking appliances, and clothes drying appliances.

Certified energy analyst is a person registered as a Certified Energy Analyst with the California Association of Building Energy Consultants as of the date of submission of a Certificate of Compliance as required under Section

10.103.

Electrically heated mixed-fuel building is a mixed-fuel building that uses electricity as the source of energy for its space heating and water heating appliances.

Free standing accessory dwelling unit is a detached building that is not intended for sale separate from the primary residence, on a lot that is zoned for single-family or multi-family use, located on the same lot as an existing dwelling, and does not exceed 1,200 square feet of total living area.

Mixed-fuel building is a building that is plumbed for the use of natural gas or propane as fuel for space heating, water heating, cooking appliances and/or clothes drying appliances.

Section 150.0 Mandatory features and devices is amended to read as follows:

Low-rise residential buildings shall comply with the applicable requirements of Sections 150(a) through 150.0(s).

NOTE: The requirements of Sections 150.0(a) through 150.0(s) apply to newly constructed buildings. Sections 150.2(a) and 150.2(b) specify which ITEM 5J ATTACHMENT 1

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requirements of Sections 150.0(a) through 150.0(s) also apply to additions or alterations.

Section 150.0(h) Space-conditioning equipment is amended by adding the following:
5 C. Systems using gas or propane space heating equipment to serve new residences, new detached accessory dwelling units, and new detached habitable structures are not permitted.

Section 150.0(n) Water heating system is amended by adding the following:

1.4. Systems using gas or propane water heaters to serve new residences, new detached accessory dwelling units, and new detached habitable structures are not permitted.

Section 150.0(s) is added to read as follows:
(s) Clothes Drying and Cooking. Buildings plumbed for natural gas or propane clothes drying or cooking equipment shall include the following components for each gas terminal or stub out:

1. Clothes Drying.

A. A dedicated 208/240-volt, 30-amp or greater electrical receptacle that is connected to the electric panel with conductors of adequate capacity, within 3 feet of the
appliance and accessible with no obstructions;
B. Both ends of the unused conductor shall be labeled with the words "For Future Electric Clothes Dryer" and be
electrically isolated;
C. A double pole circuit breaker in the electrical panel labeled with the words "For Future Electric Clothes Dryer"; and
D. Other electrical components, including conductors,
receptacles or blank covers, related to this section shall be installed in accordance with the California Electrical Code.

2. Cooktop.

A. A dedicated 208/240-volt, 50-amp or greater electrical receptacle that is connected to the electric panel with conductors of adequate capacity, within 3 feet of the
appliance and accessible with no obstructions;
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B. Both ends of the unused conductor shall be labeled with the words "For Future Electric Range" and be electrically isolated;
C. A double pole circuit breaker in the electrical panel labeled with the words "For Future Electric Range"; and D. Other electrical components, including conductors,
receptacles or blank covers, related to this section shall be installed in accordance with the California Electrical Code.

3. Stand Alone Cooking Oven.

A. A dedicated 208/240-volt, 20-amp or greater or greater receptacle within 3 feet of the appliance and accessible with no obstructions;
B. Both ends of the unused conductor shall be labeled with the words "For Future Electric Oven" and be electrically isolated;
C. A double pole circuit breaker in the electrical panel labeled with the words "For Future Electric Oven"; and
D. Other electrical components, including conductors,
receptacles or blank covers, related to this section shall be installed in accordance with the California Electrical Code.

Section 150.2(b)1C is hereby amended to read:

C. Entirely new or complete replacement space-conditioning systems installed as part of an alteration, shall include all the system heating or cooling equipment, including but not limited to: condensing unit cooling or heating coil, and air handler for split systems; or complete replacement of a packaged unit; plus entirely new or replacement duct system (Section 150.2(b)1Diia). Entirely new or complete replacement space-conditioning systems shall meet the requirements of Sections 150.0(h), 150.0(i), 150.0(j)1, 150.0(j)2, 150.0(m)1 through 150.0(m)10; 150.0(m)12; 150.0(m)13, 150.1(c)7, 150.2(b)1Fii, 150.2(b)1G, and TABLE 150.2-A.

Additionally, where an entirely new or complete replacement space conditioning system includes a new or replacement air-cooled air conditioner in Climate Zones 1 through 14 and 16, it shall meet the applicable requirements of Section 150.2(b)1Fiv. Where an entirely new or complete replacement space conditioning system includes a new or replacement heat pump, it shall meet the applicable requirements of Section 150.2(b)1Fv.

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Section 150.2(b)1F is hereby amended to read:

F. Altered space-conditioning system - mechanical cooling. Alterations which install new or replacement air-cooled air conditioners shall meet the applicable requirements of subsections i and iv. Alterations which install new or replacement heat pumps shall meet the applicable requirements of subsections i, ii, iii, and v. All other alterations to refrigerant containing components such as the compressor, condensing coil, evaporator coil, refrigerant metering device, or refrigerant piping, shall meet the applicable requirements of subsections i, ii, and iii.
i. All thermostats associated with the system shall be replaced with setback thermostats meeting the requirements of Section 110.2(c). ii. Air-cooled air conditioners in Climate Zones 2 and 8 through 15 and airsource heat pumps in all climate zones, including but not limited to ducted split systems, ducted package systems, small duct high velocity air systems, and mini-split systems, shall comply with Subsections a and b, unless the system is of a type that cannot be verified using the specified procedures.

Systems that cannot comply with the requirements of 150.2(b)1Fii shall comply with Section 150.2(b)1Fiii.

Exception to Section 150.2(b)1Fii: Entirely new or complete replacement packaged systems for which the manufacturer has verified correct system refrigerant charge prior to shipment from the factory are not required to have refrigerant charge confirmed through field verification and diagnostic testing. The installer of these packaged systems shall certify on the Certificate of Installation that the packaged system was pre-charged at the factory and has not been altered in a way that would affect the charge.

Ducted systems shall comply with minimum system airflow rate requirement in Section 150.2(b)1Fiia, provided that the system is of a type that can be verified using the procedure specified in RA3.3 or an approved alternative in RA1.
a. Minimum system airflow rate shall comply with the applicable Subsection I or II below as confirmed through field verification and diagnostic testing in accordance with the procedures specified in Reference Residential Appendix Section RA3.3 or an approved alternative procedure as specified in Section RA1.

I. Small duct high velocity systems shall demonstrate a minimum system airflow rate greater than or equal to 250 cfm per ton of nominal cooling capacity; or
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rate greater than or equal to 300 cfm per ton of nominal cooling capacity; and
Exception 1 to Section 150.2(b)1Fiia: Systems unable to comply with the minimum airflow rate requirement shall
demonstrate compliance using the procedures in Section
RA3.3.3.1.5; and the system's thermostat shall conform to the specifications in Section 110.12.

Exception 2 to Section 150.2(b)1Fiia: Entirely new or
complete replacement space conditioning systems, as
specified by Section 150.2(b)1C, without zoning dampers may comply with the minimum airflow rate by meeting the applicable requirements in Tables-150.0-B or 150.0-C as confirmed by field verification and diagnostic testing in accordance with the procedures in Reference Residential Appendix Section RA3.1.4.4 and RA3.1.4.5. The design
clean-filter pressure drop requirements of Section
150.0(m)12C for the system air filter device(s) shall conform to the requirements given in Tables150.0-B and 150.0-C. b. The installer shall charge the system according to manufacturer’s specifications. Refrigerant charge shall be verified according to one of the following options, as applicable.

I. The installer and rater shall perform the standard charge verification procedure as specified in Reference Residential Appendix Section RA3.2.2, or an approved alternative
procedure as specified in Section RA1; or
II. The installer shall perform the weigh-in charging
procedure as specified by Reference Residential Appendix Section RA3.2.3.1 provided the system is of a type that can be verified using the RA3.2.2 standard charge verification procedure and RA3.3 airflow rate verification procedure or approved alternatives in RA1. The ECC-Rater shall verify the charge using RA3.2.2 and RA3.3 or approved
alternatives in RA1.

Exception 1 to Section 150.2(b)1Fiib: When the outdoor
temperature is less than 55° F and the installer utilizes the weigh-in charging procedure in Reference Residential
Appendix Section RA3.2.3.1to demonstrate compliance, the installer may elect to utilize the verification procedure in Reference Residential Appendix Section RA3.2.3.2. If the verification procedure in Section RA3.2.3.2 is used for compliance, the system's thermostat shall conform to the ITEM 5J ATTACHMENT 1

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specifications in Section 110.12. Ducted systems shall
comply with the minimum system airflow rate requirements in Section 150.2(b)1Fiia.
iii. Air-cooled air conditioners in Climate Zones 2 and 8 through 15 and airsource heat pumps in all climate zones, including but not limited to ducted split systems, ducted package systems, small duct high velocity, and minisplit systems, which are of a type that cannot comply with the requirements of 150.2(b)1Fiib shall comply with subsections a and b, as applicable.
a.The installer shall confirm the refrigerant charge using the weighin charging procedure specified in Reference Residential Appendix Section RA3.2.3.1, as verified by an ECC-Rater according to the procedures specified in Reference Residential Appendix RA3.2.3.2; and
b. Systems that utilize forced air ducts shall comply with the minimum system airflow rate requirement in Section 150.2(b)1Fiia provided the system is of a type that can be verified using the procedures in Section RA3.3 or an approved alternative procedure in Section RA1.

Exception to Section 150.2(b)1Fiii: Entirely new or complete replacement packaged systems for which the manufacturer has verified correct system refrigerant charge prior to shipment from the factory are not required to have refrigerant charge confirmed through field verification and diagnostic testing. The installer of these packaged systems shall certify on the Certificate of Installation that the packaged system was pre-charged at the factory and has not been altered in a way that would affect the charge. Ducted systems shall comply with minimum system airflow rate requirement in Section 150.2(b)1Fiiib, provided that the system is of a type that can be verified using the procedure specified in Section RA3.3 or an approved alternative in Section RA1.
iv. New or replacement air-cooled air conditioners in Climate Zones 1 through 14 and 16 shall meet the requirements of Section 150.2(b)1Fiva or 150.2(b)1Fivb.
a. Systems with existing duct distribution systems shall meet the following requirements:

I. In all climate zones, meet the airflow and fan efficacy requirements of Section 150.0(m)13B, 150.0(m)13C, or
150.0(m)13D.

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Exception 1 to Section 150.2(b)1FivaI: Single zone central forced air systems and zonally controlled central forced air systems may demonstrate compliance with an airflow
greater than or equal to 300 CFM per ton of nominal cooling capacity.

II. In all climate zones, meet the refrigerant charge
verification requirements of Section 150.2(b)1Fii; and
III. In all climate zones, vented attics shall have insulation installed to achieve a U-factor of 0.020 or insulation installed at the ceiling level shall result in an insulated thermal resistance of R-49 or greater for the insulation alone; luminaires not rated for insulation contact must be replaced or retrofitted with a fireproof cover that allows for insulation to be installed directly over the cover; and
Exception 1 to Section 150.2(b)1FivaIII: Dwelling units with at least R-38 existing insulation installed at the ceiling level.

Exception 2 to Section 150.2(b)1FivaIII: Dwelling units where the alteration would directly cause the disturbance of asbestos unless the alteration is made in conjunction with asbestos abatement.

Exception 3 to Section 150.2(b)1FivaIII: Dwelling units with knob and tube wiring located in the vented attic.

Exception 4 to Section 150.2(b)1FivaIII: Where the
accessible space in the attic is not large enough to
accommodate the required R-value, the entire accessible space shall be filled with insulation provided such
installation does not violate Section 806.3 of Title 24, Part

2.5. Exception 5 to Section 150.2(b)1FivaIII: Where the attic space above the altered dwelling unit is shared with other dwelling units and the requirements of Section
150.2(b)1FivaIII are not triggered for the other dwelling units.

IV. In all climate zones, air seal all accessible areas of the ceiling plane between the attic and the conditioned space in accordance with Section 110.7.

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Exception 1 to Section 150.2(b)1FivaIV: Dwelling units
with at least R-38 existing insulation installed at the ceiling level.

Exception 2 to Section 150.2(b)1FivaIV: Dwelling units
where the alteration would directly cause the disturbance of asbestos unless the alteration is made in conjunction with asbestos abatement.

Exception 3 to Section 150.2(b)1FivaIV: Dwelling units
with atmospherically vented space heating or water heating combustion appliances located inside the pressure boundary of the dwelling unit.
b. Systems with entirely new or complete replacement duct systems shall meet the following:

I. R-8 duct insulation shall be installed for all new ducts located in unconditioned space; and
II. In all climate zones, meet the airflow requirements of Section 150.0(m)13B, 150.0(m)13C, or 150.0(m)13D and
demonstrate an air-handling unit fan efficacy of less than or equal to 0.35 W/CFM.

III. In all climate zones, meet the refrigerant charge
verification requirements of Section 150.2(b)1Fii;
Exception 1 to Section 150.2(b)1Fiv: Where the capacity of the existing main electrical service panel is insufficient to supply the electrical capacity of a heat pump and where the existing main electrical service panel is sufficient to supply a new or replacement air conditioner, as calculated
according to the requirements of California Electrical Code Article 220.83 or Article 220.87, systems shall comply with the applicable requirements of Sections 150.2(b)1Fi,
150.2(b)1Fii, and 150.2(b)1Fiii. Documentation of electrical load calculations in accordance with Article 220 must be submitted to the enforcement agency prior to permitting for both the heat pump and proposed air conditioner.

Exception 2 to Section 150.2(b)1Fiv: Where the required capacity of a heat pump to meet the system selection
requirements of Section 150.0(h)5 is greater than or equal to 12,000 Btu/h more than the greater of the required capacity of an air conditioner to meet the design cooling load OR the capacity of the existing air conditioner, systems shall comply with the applicable requirements of Sections 150.2(b)1Fi, ITEM 5J ATTACHMENT 1

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150.2(b)1Fii, and 150.2(b)1Fiii. Documentation of heating and cooling load calculations in accordance with 150.0(h) must be submitted to the enforcement agency prior to
permitting for both the heat pump and proposed air
conditioner.
v. In all climate zones, heat pumps with supplementary heat, including, but not limited to, electric resistance heaters or gas furnace supplementary heating, shall comply with Section 150.0(h)7 and shall lock out supplementary heating above an outdoor air temperature of no greater than 35°F.

Section 150.2(b)2 is hereby amended to read:

2. Performance approach.

The energy budget for alterations is expressed in terms of Long-term System Cost (LSC), and the altered component(s) and any newly installed equipment serving the alteration shall meet the applicable requirements of Subsections A, B, and C below.

A. The altered components shall meet the applicable requirements of Sections 110.0 through 110.9, Sections 150.0(a) through (l), Sections 150.0(m)1 through 150.0 (m)10, and Sections 150.0(p) through (q). Entirely new or complete replacement mechanical ventilation systems as these terms are used in Section 150.2(b)1L, shall comply with the requirements in Section 150.2(b)1L. Altered mechanical ventilation systems shall comply with the requirements of Section 150.2(b)1M. Entirely new or complete replacement space-conditioning systems, and entirely new or complete replacement duct systems, as these terms are used in Sections 150.2(b)1C and 150.2(b)1Diia, shall comply with the requirements of Sections 150.0(m)12 and 150.0(m)13.

B. The standard design for an altered component shall be the higher efficiency of existing conditions or the requirements stated in Table 150.2-G. For components not being altered, the standard design shall be based on the existing conditions. When the third party verification option is specified as a requirement, all components proposed for alteration for which the additional credit is taken, must be verified by a certified ECC-rater.

Table 150.2-G is hereby amended to read:

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Table 150.2-G Standard Design for an Altered Component
Altered
Component
Standard Design Without Third
Party Verification of Existing
Conditions Shall be Based On
Standard Design With Third Party
Verification of Existing Conditions
Shall be Based On
Ceiling
Insulation,
Wall
Insulation,
and Raisedfloor
Insulation
The requirements of Sections 150.0(a),
(c), and (d).

The requirements of Section 150.2(b)1J
for altered ceilings and for entirely new
or complete replacement duct systems
where the air handler and ducts are
located within a vented attic.

The requirements of Section
150.2(b)1Fiv for alterations which
include new or replacement air-cooled
air conditioners.

The existing insulation R-value
Fenestration The requirements of Section
150.1(c)3A.

The existing fenestration U-factor and
SHGC values as verified.

Window
Film
The requirements of Section
150.1(c)3A.

The existing fenestration in the
alteration shall be based on TABLE
110.6-A and TABLE 110.6-B.

Doors The U-factor of 0.20. The door area
shall be the door area of the existing
building.

If the proposed U-factor is < 0.20, the
standard design shall be based on the
existing U-factor value as verified.

Otherwise, the standard design shall be
based on the U-factor of 0.20. The
door area shall be the door area of the
existing building.

SpaceHeating and
SpaceCooling
Equipment
Table 150.1-A for equipment
efficiency requirements;
Section 150.2(b)1C for entirely new or
complete replacement systems;
Section 150.2(b)1F for refrigerant
charge verification, airflow, and fan
efficacy requirements.

The existing efficiency levels.

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Section 150.2(b)1Fiv for new or
replacement air-cooled air conditioners
Air
Distribution
System –
Duct Sealing
The requirements of Sections
150.2(b)1D and 150.2(b)1E
The requirements of Sections
150.2(b)1D and 150.2(b)1E
Air
Distribution
System –
Duct
Insulation
The proposed efficiency levels.

The requirements of Sections
150.2(b)1D, and for new or
replacement air-cooled air
conditioners, Section 150.2(b)1Fiv.

The existing efficiency levels.

Water
Heating
Systems
The requirements of Section
150.2(b)1Hii
The existing efficiency level.

Roofing
Products
The requirements of Section
150.2(b)1I.

The requirements of Section
150.2(b)1I
All Other
Measures
The proposed efficiency levels. The existing efficiency levels.

C. The proposed design shall be based on the actual values of the altered components.
(§ 1, Ord. 558, eff. February 15, 2015; § 1, Ord. 568, eff. March 16, 2017; § 1, Ord. 585, eff. January 18, 2020; § 1, Ord. 589, eff. March 19, 2020, § 1, Ord. 604, eff. November 17, 2022, [added current code adoption])
SECTION 10. Chapter 8-1.7, “CALIFORNIA HISTORICAL BUILDING CODE” of the Los Altos Hills Municipal Code is repealed and replaced as follows:

Chapter 8-1.7, “CALIFORNIA WILDLAND-URBAN INTERFACE CODE” § 8-1.8.01 Adoption of 2025 California Wildland-Urban Interface Code. (a) The 2025 California Wildland-Urban Interface Code, Part 7, Title 24 of the California Code of Regulations and specifically [A]101.5 additions or Alterations, a portion of the California Building Standards Code, as defined in the California State Health and Safety Code Section 18901 et seq., (hereinafter referred to as the " Wildland-Urban Interface "), and any rules and regulations promulgated pursuant thereto are hereby adopted and incorporated by reference herein.

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(b) One copy of the Historic Building Code shall be kept on file at the Town of Los Altos Hills.
§ 8-1.9.02 Amended sections of adopted code.

Section [A]101.1 Title.

These regulations shall be known as the California Wildland-Urban Interface Code of Los Altos Hills, hereinafter referred to as “this code.” Section [A]101.2 -Repeal and Replace- Scope.

This code applies to building materials, systems and/or assemblies used in the exterior design and construction of new buildings, and additions or alterations to existing buildings, located within a wildland-urban interface (WUI) area and contains minimum requirements to mitigate conditions that might cause a fire originating in a structure to ignite vegetation in the wildland-urban interface (WUI) area, and conversely, a wildfire burning in vegetative fuels to transmit fire to buildings and threaten to destroy life, overwhelm fire suppression capabilities or result in large property losses.

Section [A]101.3 -Repeal and Replace- Purpose.

The purpose of this code is to establish minimum regulations for the safeguarding of life and for property protection. Regulations in this code are intended to mitigate the risk to life and structures from intrusion of fire from wildland fire exposures and fire exposures from adjacent structures and to mitigate structure fires from spreading to wildland fuels. The extent of this regulation is intended to be tiered commensurate with the relative level of hazard present.

The unrestricted use of property in wildland-urban interface areas is a potential threat to life and property from fire and resulting erosion.

Safeguards to prevent the occurrence of fires and to provide adequate fire protection facilities to control the spread of fire in wildland-urban interface areas shall be in accordance with this code.

This code shall supplement the jurisdiction’s building and fire codes, if such codes have been adopted, to provide for special regulations to mitigate the fire- and life-safety hazards of the wildland-urban interface areas.

Section 101.3.1 -Repeal and Replace- Application.

New buildings located in any Fire Hazard Severity Zone or Wildland-Urban Interface (WUI) Fire Area designated by the enforcing agency constructed after the application date shall comply with the provisions of this code. This shall include all new buildings with residential, commercial, educational, institutional or similar occupancy type use, which shall be referred to in this ITEM 5J ATTACHMENT 1

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code as “applicable buildings,” as well as new buildings and structures accessory to those applicable buildings. Exceptions have been removed.

Section 101.3.1.1 -Repeal and Replace- Application date and where required.

New building located in any Fire Hazard Severity Zone or Wildland-Urban Interface Area shall comply with this code, including all of the following areas:

1. All incorporated lands of the Town of Los Altos Hills.

2. All unincorporated lands designated by the State Board of Forestry and Fire Protection as State Responsibility Area (SRA) including:
• Moderate Fire Hazard Severity Zones.
• High Fire Hazard Severity Zones.
• Very High Fire Hazard Severity Zones.

3. Land designated as a Very High Fire Hazard Severity Zone by cities and other local agencies.

4. Land designated as a wildland-urban interface area by cities and other local agencies.

Section 705.11 -Added- Noncombustible Fencing Adjacent to Structures Fencing, gates, and similar perimeter or privacy screening installed within five (5) feet of any building exterior wall, accessory structure, or attached deck shall be constructed exclusively of noncombustible materials, or materials tested and approved to be ignition-resistant to flames, embers, and radiant heat in accordance with ASTM E84 Class A or equivalent.

Exception: Where a noncombustible barrier (e.g. masonry wall) separates the structure and the fence, the portion of fencing behind that barrier may use alternative materials if separated by at least three (3) feet of noncombustible surface.
([added current code adoption])
SECTION 11. Chapter 8-1.8, “CALIFORNIA FIRE CODE” of the Los Altos Hills Municipal Code is repealed and replaced as follows:

Chapter 8-1.8, “CALIFORNIA HISTORICAL BUILDING CODE”
§ 8-1.8.01Adoption of 2025 California Historical Building Code. (a) The 2025 California Historical Building Code, Part 8, Title 24 of the California Code of Regulations, a portion of the California Building Standards Code, as defined in the California State Health and Safety Code Section 18901 et seq., (hereinafter referred to as the "Historical Building Code"), and any rules and regulations promulgated pursuant thereto are hereby adopted and incorporated by reference herein.

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(b) One copy of the Historic Building Code shall be kept on file at the Town of Los Altos Hills.
(§ 2, Ord. 558, eff. February 15, 2015; § 1, Ord. 568, eff. March 16, 2017; § 1, Ord. 585, eff. January 18, 2020; § 1, Ord. 604, eff. November 17, 2022, [added current code adoption])
SECTION 12. Chapter 8-1.9, “CALIFORNIA EXISTING BUILDING CODE” of the Los Altos Hills Municipal Code is repealed and replaced as follows:

Chapter 8-1.9, “CALIFORNIA FIRE CODE”
§ 8-1.9.01 Adoption of 2025 California Fire Code.
(a) The 2025 California Fire Code, Part 9, Title 24 of the California Code of Regulations, a portion of the California Building Standards Code, as defined in the California State Health and Safety Code Section 18901 et seq., and also the 2021 International Fire Code, published by the International Code Council, including Appendix B-Fire Flow Requirements, Appendix C-Fire Hydrant Locations and Appendix O-Temporary Haunted Houses (hereafter referred to as the Fire Code or CFC) and any rules and regulations promulgated pursuant thereto are hereby adopted and incorporated by reference herein.
(b) One copy of the Fire Code shall be kept on file at the Town of Los Altos Hills. § 8-1.9.02 Amended sections of adopted code.
2025 California Fire Code as amended in Exhibit A, “Santa Clara County Fire Department 2025 California Fire Code Local Amendments”.

The provisions contained in this Exhibit A reflects the mandatory requirements inclusive of local amendments to the 2025 California Fire Code and are included as an attachment to this title.
(§ 2, Ord. 558, eff. February 15, 2015; § 1, Ord. 568, eff. March 16, 2017; § 1, Ord. 585, eff. January 18, 2020; § 2, Ord. 588, eff. January 18, 2020; § 2, Ord. 607, eff. January 6, 2023, [added current code adoption])
SECTION 13. Chapter 8-1.10, “CALIFORNIA GREEN BUILDING STANDARDS CODE” of the Los Altos Hills Municipal Code is repealed and replaced as follows:

Chapter 8-1.10, “CALIFORNIA EXISTING BUILDING CODE”
§ 8-1.10.01 Adoption of 2025 California Existing Building Code. (a) The 2025 California Existing Building Code, Part 10, Title 24 of the California Code of Regulations, a portion of the California Building Standards Code, as defined in the California State Health and Safety Code Section 18901 et seq., ITEM 5J ATTACHMENT 1

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(hereinafter referred to as the "Existing Building Code"), and any rules and regulations promulgated pursuant thereto are hereby adopted and incorporated by reference herein.
(b) One copy of the Existing Building Code shall be kept on file at the Town of Los Altos Hills.
(§ 1, Ord. 558, eff. February 15, 2015; § 1, Ord. 568, eff. March 16, 2017; § 1, Ord. 585, eff. January 18, 2020; § 1, Ord. 604, eff. November 17, 2022, [added current code adoption])
SECTION 14. Chapter 8-1.11, “CALIFORNIA REFERENCED STANDARDS CODE” of the Los Altos Hills Municipal Code is repealed and replaced as follows:

Chapter 8-1.11, “CALIFORNIA GREEN BUILDING STANDARDS CODE § 8-1.11.01 Adoption of 2025 California Green Building Standards Code. (a) The 2025 California Green Building Standards Code, Part 11, Title 24 of the California Code of Regulations, a portion of the California Building Standards Code, as defined in the California State Health and Safety Code Section 18901 et seq., (hereinafter referred to as "CALGreen"), and any rules and regulations promulgated pursuant thereto are hereby adopted and incorporated by reference herein.
(b) Appendix Chapter A4, Section A4.106.8, Electric Vehicle (EV) Charging for New Construction, is adopted.
(c) One copy of the CALGreen shall be kept on file at the Town of Los Altos Hills.
(d) The requirements of this chapter may be adjusted or waived if the property owner demonstrates that applying this chapter would take property in violation of the United States and/or California Constitutions, or would violate applicable Federal law.
§ 8-1.11.02 Amended sections of adopted code.

The Green Building Standards Code is amended as follows:
(a) Chapter 2, Definitions, is amended by adding with the following definitions to read:

ADDITION. An extension or increase in floor area of an existing building or structure.

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ALTERATION OR ALTER. Any construction or renovation to an existing structure other than repair for the purpose of maintenance or addition.

NITROGEN OXIDES (NOx). The sum of nitrogen oxide (NO) and nitrogen dioxide (NO2), collectively expressed as nitrogen dioxide.

NOx EMITTING EQUIPMENT. Any equipment or appliance used for space heating, water heating, cooking, clothes drying and/or lighting that emits more than 0.0 nanograms of nitrogen oxides expressed as NOx per joule of heat and/or light output.

REPAIR. Reconstruction, replacement, or renewal of any part of an existing building for the purpose of its maintenance or to correct damage, as defined in the California Existing Building Code.

SUBSTANTIALLY ALTERED STRUCTURE. Any structure that is
voluntarily altered such that more than 50% of the structure's permitted floor area is altered, or more than 50% of the permitted exterior wall area is altered, or 50% of the structure's combined wall and floor area is altered, or more than 50% of existing structure's permitted floor area is added.

TECHNICALLY INFEASIBLE. With respect to an alteration of a building or a facility, there is a low probability of successfully completing the alteration because existing building or site constraints prevent the modification or addition of elements, spaces, or features that would fully and strictly comply with the minimum requirements for new construction and are necessary for compliance. Examples include, but are not limited to, utility conflicts, service capacity constraints, or construction limitations due to environmental conditions.

ZERO-NOx EMISSION BUILDING. A building with zero NOx emissions that utilizes zero NOx equipment or appliances.

ZERO-NOx EMITTING EQUIPMENT. Any equipment or appliance that emits no more than 0.0 nanograms of nitrogen oxides (expressed as NOx) per joule of heat and/or light output. Equipment and appliance uses include, but are not limited to, space heating, water heating, cooking, clothes drying, and lighting.
(b) Chapter 4, Residential Mandatory Measures, is amended by amending the following sections to read:

DIVISION 4.1 PLANNING AND DESIGN
SECTION 4.106 SITE DEVELOPMENT
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4.106.5.1. New construction. All newly constructed buildings, newly constructed detached accessory dwelling units, and other newly constructed detached habitable structures shall be Zero-NOx Emission Buildings.

Exemptions:

1. Outdoor cooking equipment, outdoor fireplaces, portable space heaters, generators, and pool/spa heaters for
residential building projects are exempt from the
requirements of 4.106.5.1, or

2. Indoor cooking equipment for residential building
projects is exempt from the requirements of 4.106.5.1. The applicant shall comply with Section 4.106.5.3.

4.106.5.2. Substantially Altered Structures. All Substantially Altered Structures shall be Zero-NOx Emission Buildings.

Exemptions:

1. Outdoor cooking equipment, outdoor fireplaces, portable space heaters, generators, and pool/spa heaters for
residential building projects are exempt from the
requirements of 4.106.5.2, or

2. Indoor cooking equipment for residential building
projects is exempt from the requirements of 4.106.5.1. The applicant shall comply with Section 4.106.5.3, or

3.Substantially Altered Structures are exempt from the
requirements of 4.106.5.2 if the electrical utility service is underground and the installation of Zero-NOx Emitting
Equipment is technically infeasible as determined by the Building Official per 4.106.5.4, or

4.Substantially Altered Structures are exempt from the
requirements of 4.106.5.2 if the primary electrical utility customer of record at the residence is enrolled in the PG&E California Alternate Rates for Energy Program (CARE) and Family Electric Rate Assistance Program (FERA) Programs.

4.106.5.3 Requirements for indoor cooking equipment. Where NOx Emitting Equipment is allowed for indoor cooking per exemption #2 under 4.106.5.1 or 4.106.5.2, the construction drawings shall provide for the infrastructure and physical space needed to ITEM 5J ATTACHMENT 1

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accommodate the future installation of a Zero-NOx Emitting cooking appliance in the following ways, as certified by a registered design professional or licensed electrical contractor.

4.106.5.3.1 A dedicated 240-volt branch circuit wiring shall be installed within 3 feet from the cooktop and accessible to the cooktop with no obstructions. The branch circuit conductors shall be rated at 50 amps minimum. The blank cover shall be identified as "240V ready." All electrical components shall be installed in accordance with the California Electrical Code.

4.106.5.3.2 The main electrical service panel shall have a reserved space to allow for the installation of a double pole circuit breaker for a future electric cooktop installation. The reserved space shall be permanently marked as "For Future 240V use."

4.106.5.4 Technical Infeasibilities. For technical infeasibilities, the property owner shall submit a request to use alternate means and methods. The property owner shall provide any additional information required by the Building Official to make a determination on the request per the 2022 CALGreen, Section 101.8. The determination of the Building Official may be appealed to the City Council, as provided in LAHMC, Section 1-4.01.

Section 4.106.6 -Added- Multifamily Construction.

All newly constructed residential occupancies, newly constructed detached accessory dwelling units, and other newly constructed detached habitable structures shall be Zero-NOx Emission Buildings.

Exception:

1. Group R-3 Occupancies
(§ 1, Ord. 558, eff. February 15, 2015; § 1, Ord. 568, eff. March 16, 2017; § 1, Ord. 585, eff. January 18, 2020; § 1, Ord. 605, eff. December 17, 2022; Ord. 611, eff. 3/16/2024, [added current code adoption])
SECTION 15. Chapter 8-1.12, “CALIFORNIA REFERENCED STANDARDS CODE” of the Los Altos Hills Municipal Code is added as follows:
§ 8-1.12.01Adoption of 2025 California Referenced Standards Code. (a) The 2025 California Referenced Standards Code, Part 12, Title 24 of the California Code of Regulations, a portion of the California Building Standards Code, as defined in the California State Health and Safety Code Section 18901 et seq., (hereinafter referred to as "Referenced Standards Code"), and any rules and ITEM 5J ATTACHMENT 1

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regulations promulgated pursuant thereto are hereby adopted and incorporated by reference herein.
(b) One copy of the Referenced Standards Code shall be kept on file at the Town of Los Altos Hills.
(§ 1, Ord. 558, eff. February 15, 2015; § 1, Ord. 568, eff. March 16, 2017; § 1, Ord. 585, eff. January 18, 2020; § 1, Ord. 604, eff. November 17, 2022, [added current code adoption])
SECTION 16. Chapter 8-2, “SAFETY ASSESSMENT PLACARDS” of the Los Altos Hills Municipal Code is unchanged.

SECTION 17. Chapter 8-3, “MOVING OF BUILDINGS” of the Los Altos Hills Municipal Code is unchanged.

SECTION 18. Chapter 8-4, “GREEN BUILDING REGULATIONS” of the Los Altos Hills Municipal Code is repealed.

SECTION 19. Chapter 8-5, “BUILDING CONSTRUCTION STANDARDS” of the Los Altos Hills Municipal Code is unchanged.

SECTION 20. Chapter 8-6, “SIGNS AND ADVERTISING STRUCTURES” of the Los Altos Hills Municipal Code is unchanged.

SECTION 21. Chapter 8-7, “BUILDING CONSTRUCTION AND STRUCTURAL ADDITION CHARGES” of the Los Altos Hills Municipal Code is unchanged.

SECTION 22. Chapter 8-8, “CODE ADMINISTRATION AND ENFORCEMENT” of the Los Altos Hills Municipal Code is unchanged.

SECTION 23. Chapter 8-9, “SMALL RESIDENTIAL ROOFTOP SOLAR EXPEDITED PERMITTING” of the Los Altos Hills Municipal Code is unchanged.

SECTION 24. Chapter 8-10, “CONSTRUCTION TIME LIMITS” of the Los Altos Hills Municipal Code is amended as follows:
§ 8-10.01 Application.

This chapter shall apply to all new construction including, but not limited to, all new structures, additions, alterations, modifications, repairs, and improvements, that require a building permit.

Except as follows:

1. Projects involving only interior work within an existing occupied structure where there is no exterior evidence indicating that construction is incomplete and provided there are no neighborhood complaints related to construction on the property.

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§ 8-10.02 Construction completion defined.

For the purposes of this chapter, construction shall be complete upon the final performance of all construction work, including, but not limited to, exterior repairs and remodeling, total compliance with all conditions of application approval, installation of all required landscaping, and the clearing and cleaning of all construction-related materials and debris from the site. Final inspection and approval of the construction work by the Town shall mark the date of construction completion for purposes of this chapter only. § 8-10.03 Construction completion estimate.

As part of any application for a Site Development Permit, the applicant/owner shall file a reasonable estimate of the cost of the proposed construction which shall be certified by the Building Official, and based thereon, a construction time limit shall be established for the project in accordance with the guidelines set forth in Section 8-10.04. Compliance with such construction time limit shall become a condition of the Site Development or Conditional Development Permit approval. For all other projects requiring only a building permit, the Building Official shall determine the estimated time of construction based on Table 1 below.
§ 8-10.04 Construction completion time limit guidelines.

New Dwellings and Remodels with Additions. Where a permit extension is approved pursuant to Section 8-10.05, the maximum time for completion of approved new dwellings or remodels with additions, following issuance of the building permit, shall not exceed the following time limits listed in Table 1:

The construction time limit period shall commence on the date the building permit is issued.

Every building permit issued by the Town under the provisions of the building code shall expire and automatically become null and void upon reaching the construction time limit unless a time extension is granted under Section 8-10.05. Said time extension shall be granted prior to the expiration of the building permit.

The time limits stated in Tables 1 are the maximum time limits allowed and lesser time periods may be allocated to a project depending on the status of previously issued building permits or code enforcement actions.
§ 8-10.05 Extension of construction time limit.

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In the event a project has not passed a final inspection in the allotted time period as prescribed by Table 1 under Section 8-10.04, the applicant/owner may be entitled to (2) one-year extensions to complete the work. An application for an extension of the construction time limit shall be accepted at any time within the extension period and shall be accompanied by a written explanation of the reasons for the requested except that the Building Official may deny an extension of a nuisance complaint is received. All extensions shall expire one year of the original time limit expiration. Extension past the time limit for construction do not relieve property owners of applicable penalties covered in Section 8-10.07.

Time limits shall not be increased through the issuance of subsequent building permits for the same project or for modifications to the original permit unless authorized by the City Council.
§ 8-10.06 Construction completion deposit.

Upon permit issuance, the property owner or representative shall deliver to the Building Division a refundable construction completion deposit equal to 1% of the project value as established by City Council resolution. The deposit shall be retained until the final inspection is completed and shall be refunded with 90 days of the final inspection. Should penalties accrue due to failure to complete the project within the time limits granted, said penalties may be deducted from the construction completion deposit.

If a building permit issued prior to the date of adoption of the construction time limit ordinance expires, the property owner or representative shall deliver to the Building Department a construction completion deposit prior to the issuance of a new building permit for that project and will be give one year to complete the project before the permit expires.
§ 8-10.07 Penalty for failure to comply with construction time limits. (a) If an applicant/owner fails to complete construction by the applicable time limits set forth in this chapter, including any extensions granted under Section 8-10.05, the property owner shall be subject to the following penalties payable to the Town which shall accrue daily up to the maximum established by this section:

Note: Penalties, fees and costs due to the Town pursuant to this chapter are due each day as the penalties accrue.

Except as follows:

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Projects involving only interior work within an existing occupied structure where there is no exterior evidence indicating that construction is incomplete and provided there are no neighborhood complaints related to construction on the property no penalties shall apply. (b) 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. (c) The Planning Director 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 any reduction or waiver of more than $5,000 must be approved by the City Council.
§ 8-10.07Appeals.

Any party aggrieved by the determination of the Building Official regarding the applicable time limit or by the denial of an extension, may appeal the Building Official's determination in writing to the Planning Director within 10 days of the Building Official's decision. Upon making a determination on the appeal, the Planning Director shall notify the appellant in writing within 30 days of the filing of the appeal. If the appellant feels aggrieved by the determination of the Planning Director, then the appellant may appeal the decision to the Planning Commission. If the appellant feels aggrieved by the determination of the Planning Commission, then the appellant may appeal the decision to the City Council. The appellant shall pay a hearing appeal fee at the time of filing an appeal in an amount as shall be established from time to time by resolution of the City Council. The Planning Director shall notify the appellant in writing of the date of the hearing on the appeal, and such notice shall be sent at least 10 days before the date of the hearing, which shall be held no later than 30 days after the filing of the appeal.
§ 8-10.09 Public nuisance declared.

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 for in Title 6, Chapter 5 of the Los Altos Hills Municipal Code.
(§ 1, Ord. 555, eff. February 15, 2015, [added current code adoption]) SECTION 25. Chapter 8-11, “STREAMLINED PERMITTING PROCESS FOR ELECTRIC VEHICLE CHARGING STATIONS” of the Los Altos Hills Municipal Code is unchanged.

SECTION 26. SEVERABILITY
Should any section, subsection, paragraph, sentence, clause, or phrase of this ordinance be declared unconstitutional or invalid for any reason, such declaration shall not affect the validity of the remaining portions of this ordinance.

SECTION 27. EFFECTIVE DATE
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In accordance with Health and Safety Code section 18941.5, this ordinance shall take effect on January 1, 2026. However, where applications and plans for building have been filed and are pending for building permits prior to the effective date of this Ordinance, such permits may be issued, and the applicant may proceed with construction in strict compliance with the California Building Standards Codes, 2022 Editions, California Code of Regulations, Title 24, as previously adopted and amended by any applicable ordinance of the Town of Los Altos Hills, but only to the extent that the issuance of such permit is required by Health and Safety Code section 18938.5 and any other applicable law.

SECTION 28. PUBLICATION
The Clerk shall cause this ordinance to be published in the manner required by law.

SECTION 29. FILING WITH BUILDING STANDARDS COMMISSION
The Clerk shall cause a certified copy of this Ordinance to be filed with the California Building Standards Commission in the manner required by law.

This ordinance was introduced by the City Council of the Town of Los Altos Hils on October 16, 2025 and DULY AND REGULARLY ADOPTED this November 20, 2025 by the following vote:

AYES:

NOES:

ABSTAIN:

ABSENT:

BY:
_______________________________
Kavita Tankha, Mayor
ATTEST:
______________________________
Arika Miller, City Clerk
APPROVED AS TO FORM:
___________________________________
Steve Mattas City Attorney
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1 of 37
Ordinance December xx, 2022

EXHIBIT A

SANTA CLARA COUNTY FIRE DEPARTMENT
2025 CALIFORNIA FIRE CODE LOCAL AMENDMENTS
CHAPTER 9 FIRE PREVENTION AND PROTECTION
The 2024 International Fire Code (IFC) as amended by the State of California Building Standards Commission and known as the 2025 California Fire Code (CFC), California Code of Regulations Title 24, Part 9, with Appendices B, C, D, and P is adopted by reference and amended as follows.

CHAPTER 1, DIVISION II Administration
Amend Chapter 1, Division II of the 2025 California Fire Code as follows:

Table 105.5.9 is amended to read:

TABLE 105.5.9

PERMIT AMOUNTS FOR COMPRESSED GASES

TYPE OF GAS AMOUNT
(cubic feet at NTP)
Carbon dioxide used in carbon dioxide
enrichment systems
875 (100lb)
Carbon dioxide used in insulated liquid
carbon dioxide beverage dispensing
applications
875 (100 lb)
Corrosive 200
Flammable (except cryogenic fluids and
liquefied petroleum gases)
200
Highly toxic Any Amount
Moderately toxic Any Amount
Other Health Hazard Materials Any Amount
Inert and simple asphyxiant 6,000
Oxidizing (including oxygen) 504
Pyrophoric Any Amount
Toxic Any Amount
Table 105.5.22 is amended to read:

TABLE 105.5.22

PERMIT AMOUNTS FOR HAZARDOUS MATERIALS

TYPE OF MATERIAL AMOUNT
Combustible liquids See Section 105.5.18
Corrosive materials
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2 of 37
Ordinance December xx, 2022
Gases See Section 105.5.9
Liquids 55 gallons
Solids 500 pounds
Explosive materials See Section 105.5.16
Flammable materials
Gases See Section 105.5.9
Liquids See Section 105.5.18
Solids 100 pounds
Highly toxic materials
Gases See Section 105.5.9
Liquids Any Amount
Solids Any Amount
Moderately toxic materials
Gases See Section 105.5.9
Other health hazard materials
Gases See Section 105.5.9
Liquids 55 gallons
Solids 500 pounds
Oxidizing materials
Gases See Section 105.5.9
Liquids
Class 4 Any Amount
Class 3 1 gallona
Class 2 10 gallons
Class 1 55 gallons
Solids
Class 4 Any Amount
Class 3 10 poundsb
Class 2 100 pounds
Class 1 500 pounds
Organic peroxides
Liquids
Class I Any Amount
Class II Any Amount
Class III 1 gallon
Class IV 2 gallons
Class V No Permit Required
Solids
Class I Any Amount
Class II Any Amount
Class III 10 pounds
Class IV 20 pounds
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3 of 37
Ordinance December xx, 2022
Class V No Permit Required
Pyrophoric materials
Gases Any Amount
Liquids Any Amount
Solids Any Amount
Toxic materials
Gases See Section 105.5.9
Liquids 10 gallons
Solids 100 pounds
Unstable (reactive) materials
Liquids
Class 4 Any Amount
Class 3 Any Amount
Class 2 5 gallons
Class 1 10 gallons
Solids
Class 4 Any Amount
Class 3 Any Amount
Class 2 50 pounds
Class 1 100 pounds
Water-reactive materials
Liquids
Class 3 Any Amount
Class 2 5 gallons
Class 1 55 gallons
Solids
Class 3 Any Amount
Class 2 50 pounds
Class 1 500 pounds
For SI: 1 gallon = 3.785 L, 1 pound = 0.454 kg.
a. 22 gallons when Table 5003.1.1(1) Note k applies and hazard identification signs in accordance with Section 5003.5 are provided for quantities of 22 gallons or less. b. 220 pounds when Table 5003.1.1(1) Note k applies and hazard identification signs in accordance with Section 5003.5 are provided for quantities of 220 pounds or less.

Section 105.5.60 is added to read:
105.5.60 Institutions. An operational permit is required to operate any health facility as defined in Section 1250 of the California Health and Safety Code, with an occupant load of more than six (6) persons, or to operate any jail or facility where personal liberties of the occupants are restrained. See California Code of Regulations Title 24 Part 2.

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Section 105.5.61 is added to read:
105.5.61 Residential care facility. An operational permit is required to operate any residential care or service facility, as described in the California Building Code, accommodating more than six (6) persons.

Section 105.6.4 is amended to read:
105.6.4 Cryogenic fluids. A construction permit is required for installation of or alteration to outdoor stationary cryogenic fluid storage systems where the system capacity exceeds the amounts listed in Table 105.5.11. Maintenance performed in accordance with this code is not considered to be an alteration and does not require a construction permit.

Section 109.5 is added to read:
109.5 Final inspection. No final inspection asto all or anyportion of a development shall be deemed completed until the installation of the required fire protection facilities and access ways have been completed and approved. No final certificate of occupancy maybe granted untilthe Fire Department issues notice of final clearance of such fire protection facilities and accesswaysto theBuildingDepartment.

Section 113.4 is deleted.
[A] 113.4 Violation penalties. Persons who shall violate a provision of this code or shall fail to comply with any of the requirements thereof or who shall erect, install, alter, repair or do work in violation of the approved construction documents or directive of the fire code official, or of a permit or certificate used under provisions of this code, shall be guilty of a [SPECIFY OFFENSE], punishable by a fine of not more than [AMOUNT] dollars or by imprisonment not exceeding [NUM-BER OF DAYS], or both such fine and imprisonment. Each day that a violation continues after due notice has been served shall be deemed a separate offense.

CHAPTER 2 DEFINITIONS
Amend Chapter 2 of the 2025 California Fire Code as follows:
202 GENERAL DEFINITIONS
Section 202 is amended to amend and add the following definitions:

CORROSIVE LIQUID. Corrosive liquid is:
1) any liquid which, when in contact with living tissue, will cause destruction or irreversible alteration of such tissue by chemical action; or
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3) any liquid classified as corrosive by the U.S. Department of Transportation; or 4) any material exhibiting the characteristics of corrosivity in accordance with Title 22, California Code of Regulations §66261.22.

HEALTH HAZARD – OTHER. A hazardous material which affects target organs of the body, including but not limited to, those materials which produce liver damage, kidney damage, damage to the nervous system, act on the blood to decrease hemoglobin function, deprive the body tissue of oxygen or affect reproductive capabilities, including mutations (chromosomal damage), sensitizers or teratogens (effect on fetuses).

LARGE-SCALE FIRE TESTING. Testing a representative energy storage system that induces a significant fire into the device under test and evaluates whether the fire will spread to adjacent energy storage system units, surrounding equipment, or through an adjacent fire-resistancerated barrier.

MODERATELY TOXIC GAS. A chemical or substance that has a median lethal concentration (LC50) in air more than 2000 parts per million but not more than 7500 parts per million by volume of gas or vapor, when administered by continuous inhalation for an hour, or less if death occurs within one hour, to albino rats weighing between 200 and 300 grams each.

SECONDARY CONTAINMENT. Secondary containment is that level of containment that is external to and separate from primary containment and is capable of safely and securely containing the material, without discharge, for a period of time reasonably necessary to ensure detection and remedy of the primary containment failure.

SPILL CONTROL. That level of containment that is external to and separate from the primary containment and is capable of safely and securely containing the contents of the largest container and prevents the materials from spreading to other parts of the room.

WORKSTATION. A defined space or an independent principal piece of equipment using HPM within a fabrication area flammable or unstable (Class 3 or 4 as ranked by NFPA 704) hazardous materials where a specific function, laboratory procedure or research activity occurs. Approved or listed hazardous materials storage cabinets, flammable liquid storage cabinets or gas cabinets serving a workstation are included as part of the workstation. A workstation is allowed to contain ventilation equipment, fire protection devices, detection devices, electrical devices and other processing and scientific equipment.

CHAPTER 5 FIRE SERVICE FEATURES
Amend Chapter 5 of the 2025 California Fire Code as follows:

SECTION 503 FIRE APPARATUS ACCESS ROADS
Section 503.1 is amended to read:

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503.1 Where required. Fire apparatus access roads shall be provided and maintained in accordance with Sections 503.1.1 through 503.1.3 and in accordance with the fire department’s access standards.

Section 503.1.1 is amended to read:
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.The fire code official is authorized to increase the dimension of 150 feet (45 720 mm) where any of the following conditions occur:

1.1. The building is equipped throughout with an approved automatic sprinkler system installed in accordance with Section 903.3.1.1, 903.3.1.2 or 903.3.1.3.

1.2. Fire apparatus access roads cannot be installed because of location on property, topography, waterways, nonnegotiable grades or other similar conditions, and an approved alternative means of fire protection is provided.

1.3. There are not more than two Group R-3 or Group U occupancies.

2.Where approved by the fire code official, fire apparatus access roads shall be permitted to be exempted or modified for solar photovoltaic power generation facilities.

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:

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503.2.1 Dimensions. Fire apparatus access roads shall 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. and an 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 residential parcels, having only Group R, Division 3, or Group U occupancy structures, the access road width may be modified by the fire code official.

Section 503.2.4 is amended to read:
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 as follows:
503.2.7 Grade. The grade of the fire apparatus access road shall be within the limits established by the fire code official based on the fire department’s apparatus. 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:
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 applications is 20 feet (6096 mm), and 12 feet (4268 mm) 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:
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 singlefamily dwellings.

SECTION 504 ACCESS TO BUILDING OPENINGS AND ROOFS
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Section 504.5 is added to read:
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 within and throughout 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 must also comply with Chapter 10.

SECTION 505 PREMISES IDENTIFICATION
Section 505.1 is amended to read:
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 4 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:
• 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. • 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.
• 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.
• 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.
• 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 twenty-four (24) inches high with a two and a half (2½) inch stroke.

SECTION 510 EMERGENCY RESPONDER COMMUNICATION COVERAGE
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Section 510.1 is amended to read:
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 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. One-story buildings not exceeding 12,000 square feet (1115 m2) with no below-ground area(s).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.

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