Overview of Proposed
Local Code Amendments
for Immediate Adoption
September 8, 2025 Acting Now for a Resilient Future
George Hoyt, Chief Building Official
Tim Scott, Resource Planner
Building Standards Code Update Process
California updates its Building Standards Code every
three years.
• Current 2022 code update took effect January 1, 2023
• 2025 code update will take effect January 1, 2026
Local jurisdictions may adopt local amendments to
the 2025 model code once the model code is
published.
• Must be more restrictive/stringent than the state code • Must make express findings that each amendment is
reasonably necessary due to local geographic,
topographical, climatic or environmental conditions
2 Legislative Updates & Urgency
AB 130 (formerly AB 306) passed on June 30, 2025
Includes language that will limit the ability of
jurisdictions to adopt new residential local
amendments to California Building Standards code
starting Oct 1, 2025 through 2031
Today: City Council to consider new residential
proposals for immediate adoption
October 6, 2025: City Council to consider new non-
residential proposals for adoption and prior local
amendments for readoption
3 Proposed Local Building Code
Amendments to 2022 Code
4 2022 Building Code Administrative Amendments
paloalto.gov/GreenBuildingCodeRequirements 5
• Certificate of Occupancy Requirements –
Clarifying when a certificate of occupancy is
required.
• Definitions – Clarifying applicability of
certain definitions, such as net floor area
and gross floor area.
Proposed Local Energy Code
Amendments to 2025 Code
6 Background
paloalto.gov/GreenBuildingCodeRequirements
Reach codes consist of local amendments that go
beyond the requirements of state code
• Updated every 3 years
Energy code - addresses building energy use
• Local amendments must show cost-effectiveness
Green building code (CALGreen) - non-energy
environmental impact in areas of:
• Water Conservation
• Material Conservation
• Environmental Quality
• EV Infrastructure
7 Green Building and Energy Amendment Timeline
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Adoption Date Local Code Amendments
Green Building Reach Code Energy Reach Code
September 2025
• None • Air Conditioner Time of
Replacement
• FlexPath
October 2025
• Carry forward previous local Green
Building Code amendments (including
CALGreen Tier 1 & 2 adoption)
• LEED Certification Alternative
Compliance Pathway
• Embodied Carbon Threshold
• EV Readiness
• Carry forward previous local
Energy Code amendments, as
supported by cost effectiveness
studies
Spring 2026
• None • Potential additional Energy Code
amendments as supported by
newly available cost
effectiveness studies and model
code language. e.g., Gas Water
Heater Time of Replacement
Proposal: Beginning 2027, require air
conditioner replacement projects to either:
• implement additional energy efficiency
measures (e.g. attic insulation, air sealing)
OR
• install a heat pump at time of
replacement/upgrade of an AC unit
Objective
: Energy efficiency and GHG
reduction.
Exceptions: Insufficient electric panel
capacity or if capacity of the heat pump
would need to be one ton greater than AC
unit to meet cooling load
Time of Replacement: AC to Heat Pump
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Picture
FlexPath
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Picture
Proposal: Remodel/renovation projects
over 1,000 sq. ft. must achieve 12 points
installing energy-related measures from a
provided list of options.
Objective: Energy efficiency and emissions
reduction.
FlexPath Measure List
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Measures Building Vintage
Pre-1978 1978-1991 1992-2010
Water Heating Package 1 1 1
Air Sealing 2 1 1
R-38 Attic Insulation 7 3 1
R-49 Attic Insulation 7 3 1
Duct Sealing 6 4 1
New Ducts, R-6 Insulation + Duct Sealing 10 7 2
New Ducts, R-8 Insulation + Duct Sealing 11 8 3
Windows 6 5 3
Wall Insulation 6 -- --
R-19 Raised floor insulation 8 8 --
R-30 Raised floor insulation 9 9 --
Radiant Barrier Under Roof (when re-roofing) 3 2 1
Heat Pump Water Heater Replacing Gas 12 12 12
High Eff. Heat Pump Water Heater Replacing Gas 13 13 13 Heat Pump Water Heater Replacing Electric 4 4 4
High Eff. Heat Pump Water Heater Replacing Electric 5 5 5 Heat Pump Space Conditioning System 21 16 13
High Eff. Heat Pump Space Conditioning System 23 18 15
Dual Fuel Heat Pump Space Conditioning System 15 11 10
Heat Pump Clothes Dryer 1 1 1
Induction Cooktop 1 1 1
Solar PV 17 17 15
Measure
Point Values
Other Jurisdictions Adoption
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AC to Heat Pump:
• Menlo Park (2026)
• Sunnyvale (2026)
• Mountain View (2026)
• Glendale (2026)
• San Jose (2026)
FlexPath:
• Menlo Park
• Ojai
• Carlsbad
• Corte Madera
• Encinitas
• Fairfax
• Marin County
• Piedmont
• San Luis Obispo
• San Rafael
• San Anselmo
Existing
Amendment
Community Feedback
paloalto.gov/GreenBuildingCodeRequirements
Staff hosted two community feedback sessions on August
12th and 13th
Feedback included:
• FlexPath – Suggestions to add new measures or adjust
point values
• Water Heaters – Questions on aligning future time of
replacement requirement with Air District Zero NOx
standards
• Water Conservation – Suggestion for new elective
measures to satisfy CALGreen requirements
• Other feedback that staff is considering for the future includes gas stove time of replacement, adopting
passive housing standards, adjusting EV readiness
requirements, and updating electric load calculations
13 CASC Feedback
paloalto.gov/GreenBuildingCodeRequirements
• Discussed pushing AC to Heat Pump enforcement date
forward to 2026
• Determined that 2027 start date makes sense to learn
from utility programs and other jurisdiction
implementation
• Discussed additional AC to Heat Pump exceptions
• Included additional information on current exceptions • Included additional information on FlexPath measure list • Voted 3 – 0 to recommend City Council adoption of the proposed Energy Code amendments
14 Staff Recommendation
paloalto.gov/GreenBuildingCodeRequirements
Staff recommends that the City Council:
1. Adopt, by a four-fifths majority, the emergency
ordinance to incorporate administrative
amendments into Palo Alto Municipal Code
16.04, which implements the California Building
Code, and
2. Adopt, by a four-fifths majority, the emergency
ordinance amending PAMC Chapter 16.17 to
incorporate the 2025 Edition of the California
Energy Code with local amendments related to
energy efficiency.
15 Next Steps
paloalto.gov/GreenBuildingCodeRequirements
If the proposed amendments are adopted by the Council,
next steps would be:
• Administrative amendments to Building Code would
take effect immediately
• Staff would submit Energy Code amendments to the
California Energy Commission (CEC) and the California
Building Standards Commission (CBSC) for review
• Review process typically takes ~2 months
• If approved by the CBSC and CEC:
• Palo Alto’s FlexPathamendment would be effective starting Jan 1, 2026 (effective date of the 2025 state code)
• AC to Heat Pump time of replacement standards would
become effective January 1, 2027
16 George Hoyt
Chief Building Official
Planning & Development Services
[email protected]
Tim Scott
Resource Planner
Utilities
[email protected]