CITY OF PACIFICA
COUNCIL AGENDA SUMMARY REPORT
9/22/2025
1 SUBJECT:
Study session to discuss future adoption of local amendments to the 2025 Edition of the California Building Standards Code and Fire Code, including local amendments RECOMMENDED ACTION:
Receive a presentation and provide direction regarding further analysis of options regarding future adoption of local amendments to the 2025 Edition of the California Building Standards Code and Fire Code.
STAFF CONTACT:
Samantha Updegrave, LEED AP, Community Development Director [email protected]
Greg McFann, Certified Building Official
CSG Consulting
[email protected]
Craig Wittner, Acting Deputy Fire Chief
North County Fire Authority
[email protected]
BACKGROUND/DISCUSSION:
The standards for construction of buildings are contained in Title 24 of the California Code of Regulations, Building Standards Code, more commonly known as the “California Building Code” (CBC). The CBC includes 12 parts addressing a range of regulations that comprehensively address building safety, energy efficiency, and other factors.1 State law requires local agencies including the City of Pacifica to adopt updated versions of the CBC every three years, which is referred to as the “triennial code updates.” The City of Pacifica must adopt the next triennial CBC update (2025 CBC) so that it can be effective as of January 1, 2026. State law also allows local agencies to amend the CBC, which is standardized across the state of California, to make changes that are reasonably necessary because of local climatic, geological, or topographical conditions.2
This study session is structured to provide information about the 2025 triennial code updates and enable City Council to consider recent State law that prohibits changes to the residential building code between October 1, 2025, to June 1, 2031, and to provide direction on future research related to Reach codes in conjunction with annual goal setting and the preparation of the local ordinance.
1 Twelve parts include the (1) Administrative Code, (2) Building Code, (2.5) Residential Code, (3) Electrical Code, (4) Mechanical Code, (5) Plumbing Code, (6) Energy Code, (7) Wildland-Urban Interface Code, (8) Historical Building Code, (9) Fire Code, (10) Existing Building Code, (11) Green Building Standards Code, and (12) Referenced Standards Code.
2 State law also allows for local amendments to the California Historical Building Code due to local seismic conditions. Health & Safety Code § 18959(f).
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September 22, 2025
Title 24, Part 7: California Wildland-Urban Interface Code3 The CBC contains wildfire requirements that establish minimum standards for the protection of life and property by increasing the ability of buildings to resist the intrusion of flames or burning embers projected by a vegetation fire and reducing structure losses. Once located throughout the CBC, the 2025 CBC consolidated these requirements and referenced performance-based test standards for building construction into Title 24, Part 7: California Wildland-Urban Interface Code (CWUIC).
The City Council has expressed interest in the Fire Hazard Severity Zones (FHSZ) and local WUI regulations, and the following is a general summary of existing fire-related maps and the new CWUIC, provided for reference.
The term Wildland-Urban Interface Area, often referred to as WUI, is defined in the new CWUIC as “geographical areas identified by the State as a “Fire Hazard Severity Zone” … and other areas designated by the enforcing agency to be at a significant risk from wildfires4.” There are no “other areas” designated as WUI in Pacifica, however, there are FHSZ in Pacifica as mandated by the State of California. These FHSZ regulate and drive building standards for new construction, property development standards such as road widths, water supply and signage, and defensible space requirements. Cal Fire convened fire ecologists, fire engineers, climate scientists, and other subject matter experts and used the best available science and data to develop and field test a model that served as the basis of zone assignments; Moderate, High and Very High FHSZ’s. The model evaluated the probability of the area burning and potential fire behavior in the area.
The US Department of Agriculture (USDA) created a WUI map that is a broad, national concept that describes any area where human developments meet or intermingle with undeveloped wildland vegetation. The USDA WUI designation helps guide national policy, research and mitigation planning for federal agencies like the U.S. Forest Service and is used to focus on human-environment conflicts such as wildfires, habitat fragmentation, invasive species, and biodiversity decline. While it is used by federal agencies to guide mitigation, the federal WUI is less prescriptive for individual property owners than state-level zones and does not determine the applicability of State codes.
The requirements and regulations in the CWUIC apply based on designated FHZS, established by State Fire Marshal and/or local ordinance5, or location within a WUI designated by local ordinance. Specifically:
3 The new California Wildland-Urban Interface Code (CWUIC), based on the International Wildland-Urban Interface Code, was created by relocating chapters, sections and language from several parts of Title 24, including the California Building Code (Chapter 7A), California Residential Code (Section R337) and the California Fire Code (Chapter 49). Additionally, it incorporates other provisions from Title 24 (not relocated), and sections from Title 14 (Natural Resources) and Title 19 (Public Safety) of the California Code of regulations, and sections from the Government Code, the Health and Safety Code, and Public Resources Code. (Summary of California Building Code Changes in the 2025 Edition of Title 24, published by California Building Standards Commission, July 2025)
4 Section 202—Definitions: Wildland-Urban Interface Area. Geographical areas identified by the State as a “Fire Hazard Severity Zone: in accordance with the Public Resources Code Sections 4201 through 4204 and Government code Sections 51175 through 51189, and other areas designated by the enforcing agency to be at a significant risk from wildfires.
5 Ordinance No. 900-C.S., Fire Hazard Severity Zones Map Pacifica City Council 3
September 22, 2025
• Chapter 4 Wildland-Urban Interface Area Requirements apply within any FHSZ in the State Responsibility Areas (SRA), Local Responsibility Areas (LRA), or locally adopted WUI6.
o Fire service access, premises identification, key boxes, fire protection water supply, fire department access to equipment
• Chapter 5 Special Building Construction Regulations apply within any FHSZ in the SRA, LRA, or locally adopted WUI
o Mitigate unique hazards posed to buildings by wildfire and reduce hazards of building fires spreading to wildland fuels
• Chapter 6 Fire Protection Requirements apply within any FHSZ in the SRA, and Very High Fire Hazard Severity Zones (VHFHSZ) in the LRA
o Fire protection plans, landscape plans and long-term vegetation management, and defensible space
During recent code development, conflicting language caused confusion as to the intended application of the CWUIC within the various FHSZ’s. North County Fire Authority (NCFA) staff contacted the Office of the State Fire Marshal and received clarification as to the intended application. California Health & Safety Code Section (HSC) 13108.5 (b)(2) states:
“Upon identification by the Director of Forestry and Fire Protection pursuant to Section 51178 of the Government Code of High FHSZ and by a local agency pursuant to Section 51179 of the Government Code, the Office of the State Fire Marshal and the Department of Housing and Community Development shall propose, and the California Building Standards Commission shall adopt, expanded application of the building standards adopted pursuant to this section to High FHSZ during the next triennially occurring code adoption cycle.” The code development team from the Office of the State Fire Marshal informed NCFA staff that emergency regulations have been submitted to clarify conflicting language and make clear the intended application of the CWUIC, that it will apply to and be enforceable within the Very High and High FHSZ’s within the LRA as of Jan 2026.
Within the City of Pacifica, all three Fire Hazard Severity zones; Very High, High and Moderate have been identified by the State Fire Marshal. The Very High FHSZ is located where no development currently exists. The practical effect of the CWUIC is that by Jan 2026, new construction within the LRA High FHSZ is required to comply with the CWUIC requirements.
The regulations will not be required within the LRA Moderate FHSZ or elsewhere out of any FHSZ.
Other Fire Code Changes
No changes affecting the existing Chapter 3 Fire Protection, of Title 4 Public Safety of the Pacifica Municipal Code (PMC) are anticipated, however, staff recommends readoption of all local amendments. Please refer to Attachment A for a list of current local amendments found in PMC Title 4, Chapter 3.
State Law Changes Related to Building Code Regulations for Residential Uses Governor Gavin Newsom signed Assembly Bill (AB) 130, a budget trailer bill, on June 30, 2025.
It became effective immediately and made significant changes to a city or county’s ability to 6 The City of Pacifica does not have a local ordinance WUI Ordinance Pacifica City Council 4
September 22, 2025
adopt amendments to the California Building Standards by essentially placing a moratorium on the adoption or modification of new state and local building standards affecting residential units.
AB 130, among other changes, amends Health and Safety Code sections 17958 and 17958.5, 17958.7, and 18941.5 to prohibit a city or county, from making changes or adopting more restrictions (e.g., Reach Codes) to the State Building Standards applicable to residential units from October 1, 2025 to June 1, 2031, unless one of the following conditions is met:
• The changes or modifications are substantially equivalent to changes or modifications previously filed by the city/county and were in effect as of September 30, 2025; • The Commission deems the change or modification necessary as an emergency standard to protect health and safety;
• The changes or modifications relate to home hardening7; • The building standards relate to home hardening and are proposed for adoption by a fire prevention district;
• The changes or modifications are necessary to implement a local code amendment that is adopted to align with a general plan approved on or before June 10, 2025, and that permits mixed-fuel (i.e., electric and natural gas, etc.) residential construction consistent with federal law while also incentivizing all-electric construction as part of an adopted greenhouse gas emissions reduction strategy; or
• Where the changes or modifications are related to administrative practices, are proposed for adoption during the time between Building Code updates, and exclusively results in any of the following:
o Reductions in time for a local agency to issue a post-entitlement permit; o Alterations to a local agency’s post-entitlement fee schedule; o Modernization of, or adoption of, new permitting platforms and software utilized by the local agency;
o Reductions in cost of internal operation for a local agency; or o Establishment, alteration or removal of local programs related to enforcement of building code violations or complaints alleging building code violations.
Pacifica General Plan 2040 – Energy and Greenhouse Gas Emissions As noted above, the recent passage of AB 130 amended Sections 17985, 17958.5 and 17985.7 of the Health and Safety Code to prohibit changes applicable to residential units, except under limited conditions (e.g., changes are substantially equivalent to changes or modifications that were previously filed by the governing body of the city or county and were in effect as of September 30, 2025; the Commission deems those changes or modifications necessary as emergency standards to protect health and safety; the changes relate to home hardening, etc.).8
One potential condition that may apply is subsection (c)(5) in Health and Safety Code section 17958.7, which states: “The changes or modifications are necessary to implement a local code 7 Home hardening is generally used to describe vegetation management compliance and building materials used to resist the intrusion of flames or embers projected by a wildland fire. 8 Health & S C § 17958(b)(1-6), 17958.5(c)(1-6) and 17958.7(c)(1-6).
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amendment that is adopted to align with a general plan approved on or before June 10, 2025, and that permits mixed-fuel residential construction consistent with federal law while also incentivizing all-electric construction as part of an adopted greenhouse gas emissions reduction strategy.”
Assembly Bill 130 was not in effect during Council goal setting in March 2025 or adoption of the budget in June 2025. Although AB 306, the originating bill for AB 130, was introduced in January 2025, it was in a preliminary form and the exception related to adopted general plans was added at a much later date. While the triennial code update was anticipated and noted as a department work item, the in-depth study that would be needed to analyze changes under this exception was not accounted for, nor budgeted for. Council could consider whether to pursue additional analysis during their next annual goal setting in the spring of 2026 and include in the Fiscal Year 2026-2027 budget.
Table 1 provides the guiding goals and implementing policies related to air quality, energy, and greenhouse gas (GHG) emissions from Pacifica’s General Plan 2040, which was adopted in 2022.
Table 1: General Plan 2040, Goals and Policies Related to Air Quality, Energy, and GHG Conservation Element (CO)
Guiding Policies
7.4 CO-G-13
Improve Air Quality. Reduce emissions of ozone-producing pollutants and particulate matter to improve regional air quality and protect the health of Pacifica and Bay Area residents.
7.5 CO-G-14
Renewable Energy. Support the use and development of renewable energy through City purchasing, and facilitation of local renewable energy generation.
7.5 CO-G-15
Energy Conservation. Support efforts to reduce energy use by increasing energy efficiency in buildings and promoting awareness of energy use.
Implementing Policies
7.4 Air Quality
7.4 CO-I-48
Regional Cooperation. Cooperate with the Bay Area Air Quality Management District (BAAQMD) and other public agencies in implementing plans to achieve State and Federal Ambient Air Quality Standards.
7.4 CO-I-49
Impact Guidelines. Use the BAAQMD's Air Quality Guidelines, to determine and mitigate project air quality impacts.
The City consults with the BAAQMD during CEQA review for projects that require air quality impact analysis and BAAQMD is on the distribution list for CEQA documents.
7.4 CO-I-50
Sensitive Receptors. Work with BAAQMD to develop and implement a Community Risk Reduction Plan to address the exposure of sensitive populations to toxic air contaminant emissions in Pacifica.
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7.4 CO-I-51
Construction Equipment. Require all construction equipment to be maintained and tuned to meet appropriate EPA and CARB emission requirements.
7.4 CO-I-52
Dust Abatement. Require contractors to use best management practices to reduce particulate emissions and dust associated with construction activities.
BMP's include, but are not limited to: regular materials and vehicle tire watering; covering of stockpiles; phasing or extension of grading operations; suspension of grading during high wind periods; and revegetation of grading areas.
7.4 CO-I-53
Transportation Control Measures. Ensure compliance with the most current Bay Area Clean Air Plan by implementing the Plan’s recommended Transportation Control Measures.
The 2017 Clean Air Plan identifies 17 TCMs aimed at reducing vehicle trips and vehicle miles traveled; increasing access to and support of alternative modes of transportation; promoting compact, walkable land use patterns; and increasing public education and awareness.
Energy and Greenhouse Gases
7.5 CO-I-54
Climate Action Plan for Greenhouse Gas Reductions. Maintain and update the Climate Action Plan that focuses on feasible actions the City can take to reduce greenhouse gas emissions from government, businesses, and residents in Pacifica.
The CAP should:
• Establish a baseline inventory of all known or reasonably discoverable sources of GHGs that currently exist in Pacifica and that existed in 1990;
• Projected GHG emissions expected in 2040 under this General Plan and foreseeable municipal operations;
• Set a target for the reduction of GHG emissions, in line with targets established by the California Air Resources Board;
• Present a list of feasible—and to the greatest extent possible, quantifiable—GHG reduction measures to meet the reduction target, in the areas of energy use (in all sectors), transportation and land use, solid waste, water, and education/outreach; and
• Establish an implementation plan, including strategies and funding for monitoring and making improvements, and carrying out existing plans such as those for electric vehicle (EV) charging infrastructure.
7.5 CO-I-55
Green Building. Monitor the effectiveness of the California Green Building Code in bringing about energy efficiency in architectural design and building construction.
7.5 CO-I-56
Solar Orientation. When possible, require buildings to be oriented such that the use of passive and active solar strategies is maximized, in order to promote energy efficiency.
To achieve ideal solar orientation conditions, the long axis of the building should be oriented east-west, within 15 degrees.
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7.5 CO-I-57
Encourage Solar Power Generation. Promote use of passive and active solar devices such as solar collectors, solar cells, and solar heating systems in buildings and parking areas by incentive programs and streamlining review.
7.5 CO-I-58
Clean City Fleet. Establish City budget for clean fuels and electric or hybrid vehicles to replace and improve the existing fleet of gasoline and diesel powered vehicles.
7.5 CO-I-59
City Purchasing of Renewable Energy. Pursue opportunities for the City to lower the cost of purchasing and producing renewable energy, such as through Peninsula Clean Energy or other energy provider at the best value to the City.
7.5 CO-I-60
Waste Collection. Periodically evaluate the City's waste collection contract to ensure that Pacifica residents and businesses receive high-quality and cost effective service.
7.5 CO-I-61
Waste Reduction and Diversion. Seek to continually reduce Pacifica’s output of solid waste and increase the proportion of waste diverted from landfills, setting targets and monitoring progress.
7.5 CO-I-62
Energy Efficiency in Public Buildings. Prepare and implement a plan to increase energy efficiency in existing public buildings.
Measures may include:
• Conduct energy audits for all municipal facilities;
• Retrofit municipal facilities for energy efficiency where feasible and when remodeling or replacing components, including increased insulation, installing green or reflective roofs, installing automated lighting controls, and retrofitting heating and cooling systems. • Require that any newly constructed, purchased, or leased municipal space meet minimum standards, such as exceeding Title 24 energy efficiency by 20 percent;
• Educate employees on energy conservation.
7.5 CO-I-63
Wastewater and Water System Efficiency. Maximize the efficiency of City-operated wastewater treatment, water treatment, pumping, and distribution equipment.
7.5 CO-I-64
Outdoor Lighting. Establish outdoor lighting performance standards to minimize energy use while ensuring appropriate light levels. These can be met by :
• Greater use of photocells or astronomical time switches; • Directional and shielded LED lights;
• Security lights with motion detectors; and
• Prohibitions against continuous all-night outdoor lighting unless needed for security reasons.
The City Council also recently adopted the Climate Action and Resiliency Plan (CARP). Goal E1, Reduce GHG emissions from the building sector by 24 percent below 2021 levels by 2030, contains actions related to buildings and energy. Action E1.6 is to “adopt Green Building standards which reduce methane use in new and existing construction by 2028.” The General Plan goals and implementing policies, as well as the CARP goals, are part of a larger strategy to address climate change and air quality and encourage greenhouse gas reduction and electric construction.
Potential options for further study related to Reach Codes permissible under the general plan condition noted might include the following. Additional research, studies, and legal analysis Pacifica City Council 8
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would be required to evaluate these options. Council could direct the newly formed Climate Action and Resiliency Program to conduct some of the initial research. • New Construction:
o All-electric requirements
o Incentives for all electric
o Electric readiness in mixed-fuel buildings
• Existing Buildings: Flex Path9
o Install efficiency, renewable, or electrification measures in existing building o Weighted menu of efficiency, renewable, or electrification measures required for additions or alterations of an existing building
Pacifica Reach Codes – Considerations for Adopted Codes Local agencies may amend the CBC, which is standardized across the state of California, to make changes that are reasonably necessary because of local climatic, geological, or topographical conditions. These types of local amendments are commonly known as “Reach Codes” because they exceed CBC requirements.
Pacifica is directly affected by climate change in terms of the impacts of sea level rise, drought, increasing temperatures, and other impacts. The City Council adopted Reach Codes during both the 2019 and 2022 CBC update process, making an important statement about the City’s priority to require energy-efficient development in order to reduce greenhouse gas (GHG) emissions and mitigate the adverse impacts of climate change.
Although recent State laws limit the City’s ability to adopt new or substantially alter existing Reach Codes, as discussed above, the City may readopt its existing Reach Codes that were in effect prior to September 30, 2025. Pacifica’s existing Reach Codes include provisions for the following:
• All-electric requirement for new construction, with exceptions • Photovoltaic panels installation for new:
o Nonresidential buildings with three habitable stories or fewer, with exceptions; o Hotels/Motel occupancies; or
o High-rise multifamily buildings with 10 habitable stories or fewer • Electric vehicle readiness parking standards for single- and two-family dwelling units • Electric vehicle readiness and charging station parking standards for multi-family dwellings and nonresidential uses
In addition to the limitations imposed under AB 130, Pacifica’s all electric Reach Codes would likely be preempted under the Ninth Circuit’s holding in California Restaurant Association v. City of Berkeley (CRA). In that case, the Ninth Circuit expressly struck down Berkeley’s Reach Code prohibiting the installation of natural gas piping in all new buildings because it determined that the ordinance as written regulates “energy use” of gas appliances via a circuitous route by rendering gas appliances effectively useless. The Ninth Circuit further noted that the Energy Policy and Conservation Act (“EPCA”) preempts regulations that relate to the quality of natural gas directly consumed by certain consumer appliances at the place where those products are 9 California Energy Codes & Standards: Reach Code Paths Pacifica City Council 9
September 22, 2025
used. As a result, the City stopped enforcement of PMC Sections 8-7.04 and 8-7.06 that refer to all electric buildings for new construction of the City’s Municipal Code10 because they are analogous to Berkeley’s Reach Code as they impose an “All-Electric Building”11 requirement on all “New Construction Buildings.”12 These Municipal Code sections specifically require various appliances such as water heaters, cooking appliances and clothes dryers to be all electric and prohibits the piping and prohibits the installation of natural gas or propane plumbing within the building. Since they are unenforceable, staff recommends rescinding these local amendments.
Based on a comparative analysis of Pacifica’s adopted Reach Codes and the California Green Building Standards Code (CGBSC), staff recommend the re-adoption of the local amendments, except the three sections as noted in the table below. For full analysis, please refer to Attachment B.
10 Amended Section 4.106 and Section 5.106.13 of the California Green Building Standards Code, respectively.
11 “All Electric Building” is defined as “[a] building that has no natural gas or propane plumbing installed within the building, and that uses electricity as the source of energy for all purposes, including, but not limited to, space conditioning (including heating), water heating, pool and spa systems, and appliances (including cooking appliances and clothes drying appliances). An All-Electric Building may include solar thermal pool heating.”
12 “New Construction Buildings” is defined as “[a] building constructed pursuant to a building permit issued on or after January 1, 2023.”
Pacifica City Council 10 September 22, 2025
Table 2: Staff Recommendation to Rescind Pacifica Reach Code Sections Action / Reason Pacifica Municipal Code
(PMC) Adopted Reach Code
CGBSC Section
Rescind: superseded by a
more restrictive State
Code or State code now
matches the reach code
language
PMC 8-7.03 EV Ready
Requirements for all new
housing including EV Ready
signage
CGBSC Section 4.106.4-1
New one- and two-family
dwellings and townhouses
with attached garages
CGBSC Section 4.106.4-2
New multi-family dwellings
CGBSC Section 4.106.4.2.1
and 4.106.4.2.5 Electric
Vehicle Ready Space
Signage
Rescind: State code now
matches the reach code
language
PMC 8-7.06 Regarding Use of
automatic load management
system, accessible EVCS and
bicycle parking
CGBSC Section Use of
automatic load management
systems (ALMS)
CGBSC Section 5.106.5.3.3
and 5.106.5.3.4 Accessible
EVCS
Rescind: Ninth Circuit,
California Restaurant
Association v. City of
Berkeley (natural gas ban
ordinance)
PMC 8-7.04 and 8-7.06 All
Electric Buildings
CGBSC Section 4.106.5 and
Section 5.106.13 All Electric
Buildings
Other Local CBC Amendments – Recommend Readoption
Pacifica also has a host of local amendments to the CBC that are not part of the Reach Codes.
Please refer to Attachment C for a list of current local amendments found in PMC Title 8 Building Regulations. These include requirements for undergrounding utilities and geotechnical hazard assessments that were adopted in the 2022 code updates. No changes are needed based on the 2025 CBC, and staff recommends readoption of all local amendments, accept as noted above under Reach Codes.
ALTERNATIVE ACTION:
This is a study session for City Council to provide direction. Any decision to adopt local amendments would be considered by the City Council at a future public hearing.
RELATION TO CITY COUNCIL STRATEGIC GOALS:
Adoption of the triennial 2025 building standards update, including re-adoption of local amendments and Reach Codes would support the following Council-adopted goals:
Goals
Pacifica City Council 11 September 22, 2025
• Goal 2: “Improve and steward City infrastructure, streets, and facilities;” and • Goal 4: “Pursue climate change adaptation and mitigation.” FISCAL IMPACT:
The Fiscal Year 2025-2026 adopted budget included $15,000 for costs associated with the 2025 California Building Code update. Staff estimate that the budgeted amount should be sufficient for analysis and adoption given the limitations imposed by AB 130. Although there will likely be remaining budget, Council direction to analyze additional Reach Codes has the potential to incur additional costs that were not anticipated in the adopted budget. Accordingly, staff will need to prepare an updated fiscal impact analysis once City Council provides direction on the extent of Reach Code analysis that is desired, if any.
ORIGINATED BY:
Community Development Department
ATTACHMENT LIST:
ATT A_Pacifica Fire Code Adoption 2025 CHAPTER_3_FIRE_PROTECTION-DRAFT (PDF) ATT B_2025-08-04_Consultant Analysis_Pacifica Reach Codes (PDF) ATT C_Pacifica Title 8-TOC_Pacifica, CA Code of Ordinances (PDF)