Attachment I - Evaluation of CALGreen vs. LEED for Palo Alto Nonresidential Projects

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TO: George Hoyt and David Chung, City of Palo Alto
FROM: Melanie Jacobson, Michelle Mann, and Leila Silver, ID360 CC: Jonathan Abendschein, Timothy Scott, Christine Luong, Evon Ballash, Julia Knight, City of Palo Alto
DATE: July 3, 2025
SUBJECT: Evaluation of CALGreen vs. LEED for Palo Alto Nonresidential Projects

BACKGROUND
At the request of the City of Palo Alto Staff Reach Code Team, ID360 conducted an evaluation comparing the performance and
requirements of nonresidential projects subject to the City’s Green Building Ordinance with the Leadership in Energy and Environmental Design Version 5 (LEED v5) rating system.

This memo evaluates three completed nonresidential construction projects in Palo Alto, examining how each aligns with LEED v5 criteria.

Each project received approval of the Building 101 Final Inspection during the current 2022 code cycle, which became effective January 1, 2023.

The goal of this study is to assess the extent to which current local building practices meet or exceed LEED standards and to identify opportunities for enhancing the City’s green building ordinance. For the 2025 building code update, staff is exploring the benefits and challenges of allowing LEED certification as an alternative compliance pathway to the City’s CALGreen Tier 1 and Tier 2 requirements. In the surrounding region, it is common for neighboring jurisdictions to require LEED certification for various building types.
1 The findings aim
to inform policy discussions and guide potential updates to strengthen environmental performance requirements for new and renovated commercial buildings.
1 Appendix C includes a comprehensive table of LEED certification requirements for 9 neighboring jurisdictions in the San Francisco Peninsula. 1

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CALGreen Tiers and LEED Overview
Both CALGreen Tier standards and LEED certification systems establish mandatory baseline requirements (prerequisites) that each project must meet. In addition, they offer a flexible framework that allows project teams to select optional measures (electives or credits) that best align with the specific scope and goals of the project. While both systems aim to promote sustainable building practices, they differ significantly in terms of scope, intent, structure, category coverage, certification criteria, and verification processes.

It is important to note that a project that pursues LEED will have to comply with the mandatory requirements of the California Green Building Code (Title 24, Part 11), California Energy Code (Title 24, Part 6), and the City's local amendments (PAMC).

Scope and Intent
• CALGreen Tiers
o Part of California’s mandatory building code (Title 24, Part 11). o Focuses on minimum sustainability standards for energy efficiency, water conservation, material conservation, indoor air quality, and site development. o Tier 1 and Tier 2 are voluntary enhancements beyond the base CALGreen code:
2 § Tier 1 = moderate increase in performance.
§ Tier 2 = higher level of performance.
• LEED v5
o A voluntary national/international rating system administered by the U.S.

Green Building Council (USGBC).
o Broad scope that covers site selection, innovation, social equity, and operational performance.
o Offers certification levels (Certified, Silver, Gold, Platinum) based on point accumulation.

Structure and Flexibility
• CALGreen Tier 1 & Tier 2

2 The City of Palo Alto has continued to adopt CALGreen Tier 1 and Tier 2 standards for both residential and nonresidential construction projects. The level of CALGreen Tier depends on the project’s scope of work. 2

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o Prescriptive and performance-based options but less flexible. o Limited ability to substitute measures (projects must choose specific number of electives from each category).
o Tier 1 and 2 require specific checklists and documentation for compliance. • LEED v5
o Prerequisite measures must be met based on project type. o Flexible credit-based system allowing project teams to choose how they earn points. Many options and paths available for each credit. o Encourages innovation and trade-offs across categories.

Mixed Occupancy Buildings
• CALGreen Tier 1 & Tier 2
o In a mixed occupancy building, each portion must follow the green building rules that apply to its specific use. (CALGreen Section 302.1). 3 • LEED v5
o The entire gross floor area of a LEED project must be certified under a single rating system and is subject to all prerequisites and attempted credits in that rating system, regardless of mixed construction or space usage type. o The “40/60” rule is used to determine which rating system and credits apply.

If 60% or more of the project’s gross floor area consists of a specific project type, the project must meet the requirements for that type.

Green Categories
Table 1 includes a brief summary of the general green building categories across CALGreen and the LEED v5 rating system. The LEED categories aim to drive high- performance, sustainable, and resilient buildings by addressing environmental and human health priorities. The newly released LEED v5 also emphasizes carbon tracking, equity, and climate resilience, which are not included in CALGreen. The 2022 CALGreen categories continue to focus on green building standards for sustainability, health, and resource efficiency.

3 For example, retail spaces on the first floor would comply with the nonresidential requirement of Chapter 5 and the residential dwelling units on the second and third floor would comply with the residential requirements of Chapter 4.
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Table 1: Green Building Categories
Green Category CALGreen Tiers LEED v5
Water Focuses on indoor/outdoor
efficiency, submetering
Comprehensive, including Water
Balance Table and lifecycle thinking
Materials Emphasizes VOC limits, recycled
content
Emphasizes embodied carbon, EPDs,
circularity
Indoor Air
Quality
Filtration, ventilation, low-emitting
materials
More comprehensive IAQ plans and
monitoring
Site/Location Minimal (stormwater, bike parking,
heat island)
Strong focus on location efficiency,
connectivity, resilience
Operations Cx, O&M, Not addressed post-
occupancy
Includes commissioning, metering,
ongoing performance

Certification and Verification
• CALGreen Tiers
o Verified by local code officials or third-party reviewers as part of the building permit and inspection process.
o The City of Palo Alto requires third-party Green Building Special Inspectors (GBSIs) to support the plan check and inspection compliance process for each green building project.
• LEED v5
o Third-party verified by GBCI (Green Business Certification Inc.), requiring rigorous documentation and sometimes additional modeling or commissioning.

METHODOLOGY
To conduct the evaluation, the project team analyzed existing building permit data to select three representative nonresidential projects that reflect a variety of building types and demonstrate different levels of compliance with the City’s current Green Building Ordinance. • Case Study 1: NR Tenant Improvement (Tier 1) - A nonresidential tenant improvement project subject to CALGreen Tier 1 requirements. The scope of work includes modifications of an existing 37,150 sq ft 2-story building with a one level basement, including expansion of an existing café, a new restroom block, reorganizing the existing large medium room into smaller meeting rooms, and finish updates.
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• Case Study 2: NR New Construction (Tier 2) - A two-story nonresidential core and shell construction project subject to CALGreen Tier 2 requirements. The scope of work includes a 21,933 sq ft office building over one level basement garage, site improvements, surface parking, outdoor landscape amenities, and plaza areas. The building is designed for a single tenant’s occupancy.
• Case Study 3: NR Mixed Use New Construction (Tier 2) - A three-story mixed-use new construction project subject to CALGreen Tier 2 requirements. The scope of work includes 6,995 sq ft commercial office, 19 residential dwelling units, and one level below grade parking. The project includes relevant site work, including excavation, grading, paving, landscaping, and utility connections.

Each project was evaluated using construction documents, permit records, and relevant compliance materials available in the City’s permitting software system, Accela. The team then conducted a comparative assessment of how each project would perform if it were evaluated using the LEED v5 rating system for Building Design and Construction (BD+C) or Interior Design and Construction (ID+C)
4, as appropriate.

The analysis focused on identifying which LEED prerequisites and credits would likely be met by each project based on documented compliance with the City's ordinance, and which would not. The comparison was used to assess both the stringency and the scope of the City’s green building requirements relative to LEED v5.

LEED Scorecard
As part of the evaluation of the CALGreen and LEED rating systems, the project team prepared LEED v5 Scorecards for each of the three projects included in this analysis. These scorecards reflect the most current published versions of the LEED v5 Building Design and Construction (BD+C) and Interior Design and Construction (ID+C) rating systems. The completed scorecards are provided in Appendix A for reference. Appendix B is also included for reference and outlines each prerequisite and elective measure the project

4 The U.S. Green Building Council (USGBC) launched the latest version, LEED v5, of the Leadership in Energy and Environmental Design (LEED) green building program on April 28, 2025. LEED v5 registration is now available for new construction, interior and existing commercial building projects through USGBC’s ARC platform.
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pursued to demonstrate compliance with CALGreen and the Palo Alto Municipal Code (PAMC).

The key sections of the LEED Scorecards used in the analysis are summarized below:
• LEED Credit Categories: The LEED rating system organizes the prerequisites and credits into eight categories: Integrative Process, Planning, and Assessments (IP), Location and Transportation (LT), Sustainable Sites (SS), Water Efficiency (WE), Energy and Atmosphere (EA), Materials and Resources (MR), Indoor Environmental Quality (EQ), and Project Priorities (PR).
• LEED Prerequisite/Credit: Each LEED prerequisite and credit for each credit category is listed on the scorecard.
• Yes, Maybe, No Columns: Each prerequisite and credit in the LEED Scorecards was labeled as “Yes” (Y), “Maybe” (M), or “No” (N) based on a review of the project’s approved plans, supporting documentation, GB-1 Sheet, and applicable CALGreen and Palo Alto Green Building/Energy Reach Code requirements. The assumptions informing these determinations are detailed in the “Assumptions” section of this memo.
• Notes: Brief notes have been included to provide additional context for each prerequisite and credit. Assumptions were necessary in some cases due to discrepancies between the LEED rating systems and the applicable code cycles. • Points: The scorecard summarizes the total number of “Yes” (Y), “Maybe” (M), and “No” (N) responses for each credit category. These totals are also provided at the bottom of the scorecard for overall reference. For the purpose of this evaluation, both “Yes” and “Maybe” points are counted toward estimating the project’s potential LEED certification level. LEED does not award points for prerequisites, which are mandatory for certification. However, the project team labeled prerequisites as “Yes” or “Maybe” based on information from the GB-1 Sheet and assumed compliance in alignment with LEED’s prerequisite requirements.

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ASSUMPTIONS
Several assumptions were made during the analysis in order to standardize comparisons and account for variations in project documentation and code cycles:
• Code Cycle Alignment: Two of the projects analyzed were originally permitted under earlier editions of the California Building Standards Code (Title 24, California Code of Regulations).
5 For the purpose of this study, the project team assumed these projects would comply with the most current applicable code requirements, including the 2022 Title 24 standards, CALGreen, and relevant local amendments to the Palo Alto Municipal Code (PAMC), to better align the analysis with the City’s current policy framework and regulatory environment.
• LEED Version: LEED v5 rating systems were applied based on project type:
o LEED v5 BD+C: New Construction for ground-up new buildings o LEED v5 ID+C: Commercial Interiors for tenant improvement projects Assumptions were made about standard compliance approaches (e.g., modeled performance for energy credits, prescriptive pathways for water and materials) where documentation was incomplete.
• Documentation and Credit Estimation: In cases where documentation did not explicitly demonstrate compliance with a specific LEED credit, credit achievement was estimated based on known building practices, required code compliance, or typical strategies used for similar project types.
• Standardized Interpretation: To ensure consistency across case studies, a standardized LEED v5 compliance checklist was developed and used for all three projects. The checklist reflects commonly used pathways and default thresholds unless project-specific evidence suggested otherwise.

5 Case Study 2 submitted under the 2019 building code cycle and was required to meet the City’s Green Building Ordinance 5485 and Energy Reach Code Ordinance 5481. Case Study 3 submitted under the 2016 code cycle and was required to meet the City’s Green Building Ordinance 5383 and Energy Reach Code Ordinance 5393. Case Study 1 is subject to the current 2022 code cycle and relevant local PAMC requirements.
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• Project Priorities Credit Category: At the time of this evaluation, the "Project Priorities” credit category was not yet made available to the public. Therefore, the ID360 team conservatively assumed each case study would earn 5 out the 9 credits available to each project. This assumption is based on our experience on similar projects in the region and the previous Regional Priority credit category.

These assumptions were necessary to provide a consistent and fair evaluation framework across all selected projects, especially given varying levels of documentation and the evolving nature of the City's green building requirements.

RESULTS
Case Study #1: Tenant Improvement (Tier 1)
Project Type: Nonresidential Tenant Improvement
Code Cycle: 2022
CALGreen Compliance Tier: Tier 1
LEED Rating System Used for Comparison: LEED v5 ID+C: Commercial Interiors

Scope of Work
Case Study 1 is a tenant improvement within an existing, single-tenant building. The scope includes demolition and reconstruction of non-load-bearing partitions, as well as updates to lighting and ceilings. On Level 1, the work expands the existing café, including the front-of- house seating area, back-of-house kitchen, and service line, and adds two manually operated sliding partitions. A new restroom block has also been added to meet the City of Palo Alto’s plumbing fixture requirements. On Level 2, the updates are limited to refreshing the existing pantry and converting a large meeting room into smaller ones, along with general finish upgrades throughout. The total area of work is 37,150 sq ft.

Key Findings
• Based on the submitted permit information, the project is anticipated to meet 8 of the 14 LEED prerequisites. The project would be required to pursue additional design and construction elements to meet the minimum standards which are not included in the local building code. Several of these prerequisite elements include owner-related policies and operational standards not typically associated with the building code.

These are marked as “Yes” (Y) on the LEED project scorecard. The remaining 6 8

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prerequisites are designated as “Maybe” (M), as they are either not required under the CALGreen code or would require the applicant to undertake additional efforts not mandated by CALGreen Tiers or the Palo Alto Municipal Code (PAMC). Because all prerequisites must be met for LEED certification, none were marked as “No” (N) in the scorecard.
• The potential LEED rating for the project is based on the combined total of credits identified as “Yes” (Y) and “Maybe” (M). In total, the project includes 27 points classified as “Yes” and 35 points classified as “Maybe.” For a conservative estimate, assuming the project achieves 75% of the “Maybe” credits, the projected total is 53 points—qualifying the project for a potential LEED Silver rating. If all “Maybe” credits are ultimately achieved (100%), the project is anticipated to earn approximately 62 points, aligning with a potential LEED Gold rating.
• The following LEED credit categories are strongly aligned with the City’s ordinance:
o Location and Transportation (LT)
o Water Efficiency (WE)
o Materials & Resources (MR)
o Indoor Environmental Quality (EQ)

• Gaps were observed in the following LEED credit areas:
o Integrative Process, Planning, and Assessments (IP)
o Energy and Atmosphere (EA)
o Project Priorities & Innovation (PR)

Case Study #2: New Construction (Tier 2)
Project Type:

Nonresidential New Construction
Code Cycle: 2019
CALGreen Compliance Tier: Tier 2
LEED Rating System Used for Comparison: LEED v5 BD+C: Building Design & Construction

Scope of Work:

Case Study 2 is a 21,933 sq ft two-story office building over one level basement garage.

Site improvements include new access drive, surface parking and outdoor landscape 9

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amenity / plaza areas. Existing ground water extraction treatment facility toward rear of site to remain.

Key Findings:
• Based on the submitted permit information, the project is anticipated to meet 12 of the 16 LEED prerequisites. The project would be required to pursue additional design and construction elements to meet the minimum standards which are not included in the local building code. Several of these prerequisite elements include owner-related policies and operational standards not typically associated with the building code.

These are marked as “Yes” (Y) on the LEED project scorecard. The remaining 4 prerequisites are designated as “Maybe” (M), as they are either not required under the CALGreen code or would require the applicant to undertake additional efforts not mandated by CALGreen Tiers or the Palo Alto Municipal Code (PAMC). Because all prerequisites must be met for LEED certification, none were marked as “No” (N) in the scorecard.
• The potential LEED rating for the project is based on the combined total of credits identified as “Yes” (Y) and “Maybe” (M). In total, the project includes 33 points classified as “Yes” and 28 points classified as “Maybe.” For a conservative estimate, assuming the project achieves 75% of the “Maybe” credits, the projected total is 54 points—qualifying the project for a potential LEED Silver rating. If all “Maybe” credits are ultimately achieved (100%), the project is anticipated to earn approximately 61 points, aligning with a potential LEED Gold rating.
• The following LEED credit categories are strongly aligned with the City’s ordinance:
o Location and Transportation (LT)
o Sustainable Sites (SS)
o Water Efficiency (WE)
o Energy and Atmosphere (EA)
o Materials and Resources (MR)

• Gaps were observed in the following LEED credit areas:
o Integrative Process, Planning, and Assessments (IP)
o Indoor Environmental Quality (EQ)
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o Project Priorities & Innovation (PR)

Case Study #3: Mixed Use New Construction (Tier 2)
Project Type: Mixed-Use New Construction
Code Cycle: 2016
Compliance Tier: Tier 2
LEED Rating System Used for Comparison: LEED v5 BD+C: Building Design & Construction

Scope of Work:

Case Study 3 is a 47,074 sq ft three-story mixed-use building with one level of below-grade parking commercial office spaces on the first and second floor, as well as 19 residential dwelling units. The project includes relevant site work, including excavation, grading, paving, landscaping, a covered courtyard and utility connections.

Key Findings:
• Based on the submitted permit information, the project is anticipated to meet 11 of the 16 LEED prerequisites. The project would be required to pursue additional design and construction elements to meet the minimum standards which are not included in the local building code. Several of these prerequisite elements include owner-related policies and operational standards not typically associated with the building code.

These are marked as “Yes” (Y) on the LEED project scorecard. The remaining 5 prerequisites are designated as “Maybe” (M), as they are either not required under the CALGreen code or would require the applicant to undertake additional efforts not mandated by CALGreen Tiers or the Palo Alto Municipal Code (PAMC). Because all prerequisites must be met for LEED certification, none were marked as “No” (N) in the scorecard.
• The potential LEED rating for the project is based on the combined total of credits identified as “Yes” (Y) and “Maybe” (M). In total, the project includes 39 points classified as “Yes” and 18 points classified as “Maybe.” For a conservative estimate, assuming the project achieves 75% of the “Maybe” credits, the projected total is 52 points—qualifying the project for a potential LEED Silver rating. If all “Maybe” credits are ultimately achieved (100%), the project is anticipated to earn approximately 57 points, aligning with a potential LEED Silver rating.
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• The following LEED credit categories are strongly aligned with the City’s ordinance:
o Location and Transportation (LT)
o Sustainable Sites (SS)
o Water Efficiency (WE)
o Energy and Atmosphere (EA)
o Materials and Resources (MR)

• Gaps were observed in the following LEED credit areas:
o Integrative Process, Planning, and Assessments (IP)
o Indoor Environmental Quality (EQ)
o Project Priorities & Innovation (PR)

Notable Gaps, Risks and Opportunities:
• CALGreen Tier Prerequisites: To achieve CALGreen Tier 1 or Tier 2 status, a project must comply with all applicable prerequisite measures for the selected tier and select the required number of elective measures from each CALGreen division. Most CALGreen and Palo Alto Municipal Code (PAMC) prerequisites do not have direct equivalents in the LEED rating system.
6, 7 Notable CALGreen Tier prerequisites without
LEED prerequisite counterparts include:
o Designated parking for clean air vehicles
o Cool roof requirements to reduce the heat island effect o Minimum recycled content in building materials
o Enhanced construction waste reduction
o VOC limits for resilient flooring systems
o Formaldehyde limits for thermal insulation
o Electric vehicle charging infrastructure requirements

While these measures are not LEED prerequisites, projects may still earn LEED credits if they meet relevant criteria aligned with these CALGreen requirements.

6 See Appendix E for a comparison of the LEED v5 BD+C and CALGreen Tier 1 and Tier 2 prerequisites. 7 See Appendix F for a comparison of the LEED v5 ID+C and CALGreen Tier 1 and Tier 2 prerequisites. 12

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• LEED Prerequisites: If a project elects to pursue LEED certification, all LEED prerequisites must be fully addressed and integrated into the project's design and construction phases. For the purpose of this evaluation, all measures referenced are assumed to comply with the mandatory LEED prerequisite requirements. New prerequisites and credits introduced in LEED v5 are not required by CALGreen and go further than the statewide requirements. Most of these prerequisites and credits are tied to decarbonization strategies, embodied carbon of building materials, health, comfort and community impact.
8 • Embodied Carbon: The City’s ordinance does not currently address whole building embodied carbon or life-cycle impact reductions, which are encouraged in LEED v5.

CALGreen Embodied Carbon requirements currently impact new nonresidential buildings 100,000 sq ft or more.
9 • Commissioning: Enhanced commissioning and performance verification practices go beyond the City’s current Tier 1 requirements. These additional measures may require substantial effort, particularly for nonresidential tenant improvement projects or smaller nonresidential alterations. The California Energy Code (Title 24, Part 6, Section 120.8) mandates building commissioning for new nonresidential buildings (excluding healthcare facilities) with conditioned floor areas of 10,000 sq ft or more.

CALGreen (Section 5.410.2) adopts the same 10,000 sq ft threshold for full-scope commissioning. For new buildings under 10,000 sq ft or new systems serving additions or alterations, CALGreen requires system testing and adjusting, similar to the Energy Code.
10 However, these requirements are less rigorous than full building commissioning, which state code requires for new construction only.

8 In particular, a climate resilience assessment (IPp1), human impact assessment (IPp2), and an embodied carbon assessment (IPp3), are now prerequisites for all projects pursuing LEED certification. 9 The threshold for triggering the CALGreen Embodied Carbon requirements will lower to 50,000 sq ft in the 2025 code cycle, effective January 1, 2026.
10 Energy-related systems including heating, ventilation, air conditioning (HVAC) systems and controls, indoor lighting system and controls, as well as water heating systems and controls, refer to California Energy Code Section 120.8 for commissioning requirements and Sections 120.5, 120.6, 130.4, and 140.9(b)3 for additional testing requirements of specific systems. CALGreen requires a written plan for testing and adjusting of renewable energy systems, landscape irrigation systems, and water reuse systems if applicable to the project (Section 5.410.4).
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• LEED Platinum: A new standard for LEED Platinum Certification was introduced in LEED v5. In addition to achieving 80 or more points, projects will also need to demonstrate compliance with additional performance benchmarks, such as zero operational emissions, full electrification, and a comprehensive embodied carbon analysis. Although setting LEED Platinum as an alternative compliance route is likely to not conflict with federal law, through the evaluation, the ID360 team is not recommending setting LEED Platinum as the alternative compliance threshold.

However, it is worth noting the significant level of effort and commitment this level of LEED certification would reflect of a project if achieved. • CPAU Carbon-Free: Since 2013, City of Palo Alto Utilities (CPAU) provides 100% carbon-neutral electricity and since 2017 offers 100% carbon-neutral gas services.

CPAU is also a certified Green‑e® Energy participant as of 2023 and was the first Green‑e Climate certified gas offset program offered by a municipal utility. 11 Due to
this, projects that receive off-site renewable energy and fuels are eligible for points under LEED’s Tier 3 Renewable Energy (EAc3) pathway. For the purposes of this evaluation, the project team assumes the project meets these criteria. • Regional Alignment: Jurisdictions across California—including those neighboring the City of Palo Alto—require LEED certification or LEED equivalency for certain project types, particularly larger commercial, institutional, and municipal developments.

There is an opportunity for Palo Alto to align with these regional standards, which would provide a more consistent permitting experience for applicants already pursuing LEED in nearby cities. This alignment would reduce duplication of effort, support sustainability objectives, and reinforce Palo Alto’s commitment to high- performance building practices. Appendix C provides a summary of LEED requirements adopted by neighboring jurisdictions.
• Noncompliance and Noncertified Results: One risk of pursuing the LEED Certification Compliance pathway is that a project may ultimately fail to achieve formal LEED certification, despite choosing that route. This could lead to delays in obtaining the final certificate of occupancy, depending on the City’s enforcement

11 CRS 2024 Green-e Verification Report. https://resource-solutions.org/g2024/ and City of Palo Alto Utilities. https://www.paloalto.gov/Departments/Utilities/Customer-Service/About-CPAU/Carbon-Neutral-Electricity-and- Natural-Gas/FAQs. Accessed June 25, 2025.
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mechanisms. Additionally, the project applicant may incur LEED design review and construction fees without receiving certification. A potential way to mitigate this risk is to adopt a model like San Francisco’s, where building permit closeout is contingent upon obtaining the LEED certificate.
• Third-Party Review Limitations: If a project fails to achieve LEED certification and no mitigating measures are in place, the City has no control over the outcome, as certification is solely at the discretion of GBCI.

RECOMMENDATION
Based on the ID360 team’s analysis, the findings support allowing permit applicants to use LEED certification as an alternative compliance pathway for CALGreen Tier 1 and Tier 2 requirements. The team recommends establishing LEED Silver as the minimum acceptable level for this alternative, with LEED Gold as the maximum. Additionally, the team suggests considering a tiered approach aligned with project scope—requiring LEED Silver for CALGreen Tier 1 projects and LEED Gold for Tier 2 projects.

The CALGreen Tiers and the LEED v5 rating systems are both green building standards that support the design and construction of high-performance buildings, but the standards differ significantly in scope, stringency, flexibility, and intent. 12 In certain areas, LEED v5 includes
more stringent and additional requirements, particularly in the areas of commissioning, carbon tracking, equity, and climate resilience strategies. In other ways, the CALGreen Tiers require certain prerequisites that can typically be claimed under optional credits in the LEED rating system. A summary table of the potential options outlined below is provided in Appendix D.

Potential Options for Palo Alto
• Option 1 – LEED Certification as a Standalone Compliance Pathway: Allow LEED Gold Certification to serve as an alternative compliance pathway for nonresidential projects in lieu of CALGreen Tier 1 and Tier 2 requirements, provided the project

12 See Appendix E for a comparison of CALGreen Tier prerequisite requirements against the LEED v5 BD+C rating system and Appendix F for a comparison of CALGreen Tier prerequisite requirements against the LEED v5 ID+C rating system. The CALGreen Tiers and LEED Overview section of this memo highlights and compares the intent, scope, structure, and green building categories between CALGreen and LEED v5. 15

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complies with all CALGreen Mandatory Measures (Chapter 5) and applicable local amendments (e.g., energy reach codes, low-carbon concrete requirements). o Reasoning: This option streamlines the compliance process for project teams already pursuing LEED certification by removing the additional burden of Tier 1 and Tier 2 prerequisites and electives. It leverages a well-established third- party certification system—administered by Green Business Certification Inc. (GBCI)—to verify sustainability outcomes, while ensuring that local baseline standards remain enforced.
o Benefits:
§ Simplified Compliance: Removes additional CALGreen requirements for projects already pursuing LEED Gold, reducing administrative burden and additional design/construction considerations. § Third-Party Verification: Relies on GBCI’s established review process to assess and verify sustainability performance.
§ Voluntary LEED Compliance: Discussions with City staff highlighted that many projects that pursue LEED Certification on their own are typically driven by owner sustainability goals, design team strategies, and marketability of the building as LEED certified.
o Considerations:
§ Exemption from Tier Prerequisites: Projects utilizing this pathway would not be required to meet CALGreen Tier 1 or Tier 2 prerequisite measures.
§ Third-Party Oversight: Certification and compliance would be determined by GBCI, outside of City control.
§ City Verification Mechanism: A system for confirming LEED certification must be established. Options used by other jurisdictions include:
• Temporary Certificate of Occupancy: Conditional occupancy granted pending verification of LEED certification (e.g., San Francisco).
• LEED AP Verification Letters: Require pre-permit and pre- occupancy letters from a LEED Accredited Professional
confirming compliance (e.g., Mountain View).
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• Green Building Refundable Deposit: Require a deposit at permit issuance, refunded upon verification of certification achievement (e.g., San José).

• Option 2 – LEED Certification with CALGreen Tier Prerequisites: Allow LEED Gold Certification to serve as an alternative compliance pathway for nonresidential projects subject to CALGreen Tier 1 or Tier 2 requirements, with the stipulation that all applicable CALGreen Tier prerequisite measures must still be incorporated into the project’s design and construction.
o Reasoning: This approach maintains alignment with the City’s environmental goals by ensuring that projects meet the baseline CALGreen mandatory requirements and integrate the minimum sustainability measures required under Tier 1 or Tier 2. It offers project teams greater flexibility, particularly those already pursuing LEED certification, while preserving the integrity of the CALGreen tiered framework.
o Benefits:
§ Consistency and Accountability: Ensures all projects meet the City’s and CALGreen’s identified mandatory sustainability standards, regardless of the compliance pathway.
§ Efficiency and Synergy: Many CALGreen Tier prerequisites support specific LEED credits, creating an opportunity for streamlined documentation and reduced duplication of effort.
§ Incentivizes High Performance: By recognizing LEED Gold as a valid compliance route, the City can encourage broader adoption of third- party verified green building practices.
§ Flexibility for Project Teams: Provides an alternate route for compliance that may align better with the project’s sustainability strategy or certification goals.
o Considerations:
§ Documentation: Documentation must clearly demonstrate that all applicable CALGreen Tier 1 or Tier 2 prerequisites are met within the LEED-certified project.
§ City Verification Mechanism: Project teams must submit some form of documentation (e.g., GB-1 Sheet, compliance form) showing how 17

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CALGreen prerequisites are satisfied under the LEED framework and incorporated into the design. Additionally, a system for confirming LEED certification must be established as mentioned under Option 1 (e.g., TCO, green building deposit, verification letter). § Evaluation of Requirements: Periodic review of LEED equivalency should be conducted to ensure continued alignment with evolving CALGreen standards.

• Option 3 – Tiered LEED Standards Differentiated by Project Scope: Permit LEED Gold Certification as an alternative compliance option for nonresidential CALGreen Tier 2 projects involving new construction or substantial remodels. For CALGreen Tier 1 projects, City staff would determine one of the following pathways: 1) Require LEED Silver Certification as the minimum standard; or 2) Exclude CALGreen Tier 1 projects from the LEED alternative compliance pathway entirely.
o Reasoning: This tiered approach provides flexibility for larger-scope projects (Tier 2) to leverage LEED Gold certification while maintaining oversight of Tier 1 projects or providing a lower threshold for smaller projects. By establishing differentiated requirements, the City can ensure that sustainability outcomes remain robust and consistent with the intent of the CALGreen tiers. o Benefits:
§ Flexible Compliance for Tier 2: Supports streamlined compliance for complex projects already pursuing LEED Gold.
§ City Control over Tier 1 Approach: Allows the City to decide whether to permit LEED Silver as a sufficient alternative or to require full CALGreen Tier 1 adherence in lieu of an alternative pathway. § Aligns Effort with Project Scope: Differentiates between the scale and impact of Tier 1 and Tier 2 projects, applying more rigorous certification standards to larger or more intensive developments. o Considerations:
§ City Decision Point: City staff must select the preferred approach for Tier 1 (LEED Silver or no alternative pathway).
§ Documentation and Verification: LEED-certified projects must still demonstrate compliance with all applicable CALGreen Mandatory Measures and relevant local code amendments.
18

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300S 1st St. Suite 300A San Jose, CA 95113 | 650.830.0042 650.830.0042
§ Enforcement Mechanism: The City should implement a verification process to confirm that LEED certification is achieved, consistent with practices used in other jurisdictions (e.g., deposits, third-party confirmation, temporary occupancy permits).
§ Tier 1 Project Scopes: Under PAMC, nonresidential Tier 1 projects are defined as alterations or tenant improvements (TIs) over 5,000 sq ft that include the replacement of at least two systems— HVAC, building envelope, hot water, or lighting. For smaller TIs, the limited scope may make it difficult to meet LEED prerequisites or earn enough credits, particularly for requirements like commissioning. The cost of LEED registration, the design and construction review fees may deter project teams from selecting LEED as a viable alternative.

Recommended Next Steps
If the City chooses to move forward with offering LEED Certification as an alternative compliance pathway, the project team recommends the following next steps.

Policy Development Next Steps

1. Select preferred policy option based on City priorities, administrative capacity, and staff feedback.

2. Present to the community and City Council to gather feedback and ensure alignment with broader sustainability goals and priorities.

Post-Policy Adoption Next Steps

1. Choose verification mechanism(s) aligned with existing permitting processes.

2. Develop implementation timeline and staff training, community training, and GBSI training requirements.

3. Establish periodic review process for policy effectiveness and LEED-CALGreen alignment during each building code cycle or new cycle of the LEED Rating System. 13 4. Coordinate with Planning and Building Division staff on permitting workflow integration, procedures, and implementation of enforcement requirements.

13 The LEED program has recently moved to a five-year development cycle starting with the 2025 release of the balloted LEED v5 rating systems. https://www.usgbc.org/leed/v5. Accessed June 23, 2025. 19 Appendix A
This page is left intentionally blank.

See next page for Appendix details.
20

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LEED ID+C® v5.0 SCORECARD
PROJECT: DATE:6/20/25 LEED for Interior Design and Construction INTEGRATIVE PROCESS, PLANNING & ASSESSMENTS (IP) 1 / 1 Points Possible Y M N PTS Prerequistie/Credit
0 0 Prerequisite
0 0 Prerequisite
0 0 Prerequisite
1 1 Credit
1 0 0 1
LOCATION AND TRANSPORTATION (LT) 5 / 14 Points Possible Y M N PTS Prerequistie/Credit
4 4 8 Credit Public Transportation/Walkable Location
1 3 4 Credit
2 2 Credit EV parking shown on plans, not in scope
5 7 2 14
WATER EFFICIENCY (WE) 2 / 10 Points Possible

Y M N PTS
0 0 Prerequisite
1 1 2 Credit Permanent water meters/submeters
1 7 8 Credit 25% reduction fixture and fittings
2 0 8 10
ENERGY AND ATMOSPHERE (EA) 3 / 31 Points Possible

Y M N PTS
0 0 Prerequisite
0 0 Prerequisite Meet Title 24 Energy Code
0 0 Prerequisite Fundamental Commissioning
0 0 Prerequisite Energy Metering and Reporting
0 0 Prerequisite Fundamental Refrigerant Management
5 5 Credit Electrification
4 8 12 Credit Enhanced Energy Efficiency
2 3 5 Credit Renewable Energy
4 4 Credit Enhanced Commissioning
1 2 3 Credit Grid Interactive
2 2 Credit
3 4 24 31
MATERIALS & RESOURCES (MR) 9 / 26 Points Possible

Y M N PTS
0 0 Prerequisite Planning for Zero Waste Operations
0 0 Prerequisite Quantify and Assess Embodied Carbon
1 4 4 Credit Interior Materials Reuse
1 3 4 Credit Reduce Embodied Carbon
2 2 4 Credit Low-Emitting Materials
2 8 10 Credit Building Product Selection and Procurement No project specifications included 3 4 Credit Construction and Demolition Waste Diversion
9 17 0 26
INDOOR ENVIRONMENTAL QUALITY (EQ) 1 / 18 Points Possible

Y M N PTS
0 0 Prerequisite Construction Management
Initial project analysis by applicant
Initial project analysis by applicant
Initial project analysis by applicant
Meeting early in design
Case Study 1
Tier 1 TI
Minimum Energy Efficiency
D
D/C
D
D
D
D
D/C
D/C
Climate Resilience Assessment
Human Impact Assessment
Carbon Assessment
Integrative Design Process
Minimum Water Efficiency
Des/Con Notes
D
D/C
D
Existing building reuse, recycled content
Low emitting flooring, insulation, base code
80% diversion rate / CWM
Enhanced Refrigerant Management
Reduce harmful refrigerants
C
Requires enhanced refrigerant calcs.

Construction plan for air quality
No indication of enhanced cs efforts
D/C
D/C
D
D/C
D/C
D
C
Initial project analysis by applicant
Initial project analysis by applicant
D
Des/Con
D
D/C
CALGreen low flow and flush fixtures
D
D/C
D/C
Water Metering and Leak Detection
lighting contol system / controlled receptacles DR
Advanced lighting, HVAC
No solar PV; Carbon Free CPAU
Estimated Energy Use/Operational Carbon Projection D
D/C
D
D
Compact and Connected Development
Transportation Demand Management
Electric Vehicles
Enhanced Water Efficiency
Installed meters and reports
Initial project analysis by applicant
Meet Title 24 Energy Commissioning
Reuse of existing buildings
Mixed fuel building
21

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0 0 Prerequisite Fundamental Air Quality
0 0 Prerequisite No Smoking
1 1 2 Credit Enhanced Air Quality
1 6 7 Credit Occupant Experience
1 1 2 Credit Accessibility and Inclusion
3 3 Credit Resilient Spaces
4 4 Credit Air Quality Testing and Monitoring
1 3 14 18
PROJECT PRIORITIES & INNOVATION (PR) 6 / 10 Points Possible

Y M N PTS
5 4 9 Credit Project Priorities
1 1 Credit LEED AP
6 4 0 10
LEED Rating System Point Requirements
N
48 110
C
Y M
C
D/C
D
D

POSSIBLE POINTS
D 1 project team must be LEED AP w/ specialty
D
27 35
D
CALGreen equivalent
No smoking signs & policy
Mech ventilation complies w/ CEC
Possible for windows or lighting or acoustics
Complies with CBC Chp 11B ADA
No indication of testing and monitoring
D
Multiple pathways for points
LEED Certified LEED Silver LEED Gold LEED Platinum
40-49 Pts 50-59 Pts 60-79 Pts 80+ Pts
22

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LEED BD+C® v5.0 SCORECARD
PROJECT: DATE: 6/27/25 LEED for Building Design + Construction INTEGRATIVE PROCESS, PLANNING & ASSESSMENTS (IP) 1 / 1 Points Possible Y M N PTS Prerequistie/Credit
0 0 Prerequisite Climate Resilience Assessment
0 0 Prerequisite Human Impact Assessment
0 0 Prerequisite Carbon Assessment
1 1 Credit Integrative Design Process Meeting early in design 1 0 0 1
LOCATION AND TRANSPORTATION (LT) 5 / 15 Points Possible Y M N PTS Prerequistie/Credit
1 1 Credit Sensitive Land Protection Infill site
1 2 Credit Equitable Development
1 6 Credit Compact and Connected Development
2 2 4 Credit Transportation Demand Management Bicycle network/storage/shower 2 2 Credit Electric Vehicles 4 EVSE, 6 EV Ready
5 2 2 15
SUSTAINABLE SITES (SS) 5 / 11 Points Possible

Y M N PTS
0 0 Prerequisite
2 2 Credit Project restoring disturbed areas
1 1 Credit Landscape/outdoor area not 30%
2 1 3 Credit 85th percentile rainwater management
1 1 2 Credit
2 2 Credit SRI included for 2 roof products
1 1 Credit BUG ratings per Tier 2 prerequisite
5 1 5 11
WATER EFFICIENCY (WE) 2 / 9 Points Possible

Y M N PTS
0 0 Prerequisite
0 0 Prerequisite
1 1 Credit
2 6 8 Credit 31% indoor water use reduction; app.
2 0 7 9
ENERGY AND ATMOSPHERE (EA) 9 / 33 Points Possible

Y M N PTS
0 0 Prerequisite
0 0 Prerequisite Meet Title 24 Energy Code
0 0 Prerequisite
0 0 Prerequisite
0 0 Prerequisite
5 5 Credit
1 4 5 Credit Reduce Peak Thermal Loads
1 9 10 Credit
3 2 5 Credit
4 4 Credit FPT: BMS, HVAC, plumbing, electrical
2 2 Credit No DR or BAS in plans
Case Study 2
Tier 2 New Construction
D
D/C
D
D/C
D/C
Installed meters and reports
Reduce harmful refrigerants
Permanent water meter on site
Solar ready area/ CPAU Green-e Certified
Accessible Outdoor Space
Rainwater Management
Enhanced Resilient Site Design Climate/natural hazard design Meter only, not included for all uses
CALGreen low flow and flush fixtures
D/C
D
D
D
D
Initial project analysis by applicant
Initial project analysis by applicant
Initial project analysis by applicant
All-electric building design
Meet Title 24 Energy Commissioning
Energy Recovery Ventilator (ERV)
Core and shell, all-electric building
No on-site combustion
D
D
D
D/C
D
D/C
Electrification
Enhanced Energy Efficiency
Renewable Energy
Enhanced Commissioning
Grid Interactive
D/C
D/C
D/C
D
Light Pollution Reduction
Water Metering and Reporting
Minimum Water Efficiency
Water Metering and Leak Detection
Carbon Projection and Decarbonization Plan
Minimum Energy Efficiency
Fundamental Commissioning
Energy Metering and Reporting
Fundamental Refrigerant Management
Des/Con
D
D
Erosion control/site assessmentD/C
D
Des/Con
D
D/C
D
D/C
D
Heat Island Reduction
Enhanced Water Efficiency
D
D/C
Minimize Site Disturbance
Biodiverse Habitat
23

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2 2 Credit
9 9 15 33
MATERIALS & RESOURCES (MR) 5 / 18 Points Possible

Y M N PTS
0 0 Prerequisite
0 0 Prerequisite
3 3 Credit
6 6 Credit
1 1 2 Credit
2 3 5 Credit Choice materials CALGreen elective
2 2 Credit 80% C&D diversion
5 3 10 18
INDOOR ENVIRONMENTAL QUALITY (EQ) 0 / 13 Points Possible

Y M N PTS
0 0 Prerequisite
0 0 Prerequisite
0 0 Prerequisite
1 1 Credit
7 7 Credit
1 1 Credit
2 2 Credit
2 2 Credit
0 9 4 13
PROJECT PRIORITIES & INNOVATION (PR) 6 / 10 Points Possible

Y M N PTS
5 4 9 Credit Project Priorities
1 1 Credit LEED Accredited Professional
6 4 0 10
LEED Rating System Point Requirements
Initial project analysis by applicant
New construction
No WBLCA, EPD, or carbon tracking
1 pt for C/S, CALGreen categories
D
Requires enhanced refrigerant calcs.

Recyclables & ZW Operations Plan
D Enhanced Refrigerant Management
D 1 project team must be LEED AP w/ specialty
C
Construction and Demolition Waste Diversion
Construction Management
Fundamental Air Quality
Planning for Zero Waste Operations
Quantify and Assess Embodied Carbon
Building and Materials Reuse
Reduce Embodied Carbon
Low-Emitting Materials
Building Product Selection and Procurement
D
D/C
C
D/C
D
D
D/C
D
No Smoking or Vehicle Idling
Enhanced Air Quality
Occupant Experience
Accessibility and Inclusion
Resilient Spaces
D/C
C
C
Multiple pathways for points
No IAQ testing indicated
Project team develop CM practices
ASHRAE 62.1, MERV 13
CALGreen tabacco requirements/ No idle
Increased outdoor air rates or IAQ limits
Project analysis by team required
Additional accessibility strategies
No operable windows or passive technique

Y M N POSSIBLE POINTS
33 28 43 110
D
Air Quality Testing and Monitoring
D
D
LEED Certified LEED Silver LEED Gold LEED Platinum
40-49 Pts 50-59 Pts 60-79 Pts 80+ Pts
24

Page 1 ends

LEED BD+C® v5.0 SCORECARD
PROJECT: DATE: 6/27/25 LEED for Building Design + Construction INTEGRATIVE PROCESS, PLANNING & ASSESSMENTS (IP) 1 / 1 Points Possible Y M N PTS Prerequistie/Credit
0 0 Prerequisite Climate Resilience Assessment
0 0 Prerequisite Human Impact Assessment
0 0 Prerequisite Carbon Assessment
1 1 Credit Integrative Design Process
1 0 0 1
LOCATION AND TRANSPORTATION (LT) 8 / 15 Points Possible Y M N PTS Prerequistie/Credit
1 1 Credit Sensitive Land Protection
2 2 Credit Equitable Development
3 6 Credit Compact and Connected Development
1 3 4 Credit Transportation Demand Management
3 2 Credit Electric Vehicles
8 0 5 15
SUSTAINABLE SITES (SS) 9 / 11 Points Possible

Y M N PTS
0 0 Prerequisite
2 2 Credit Biodiverse Habitat
1 1 Credit Accessible Outdoor Space
2 1 3 Credit Rainwater Management
2 2 Credit Enhanced Resilient Site Design
1 1 2 Credit Heat Island Reduction
1 1 Credit Light Pollution Reduction
9 0 2 11
WATER EFFICIENCY (WE) 2 / 9 Points Possible

Y M N PTS
0 0 Prerequisite Water Metering and Reporting
0 0 Prerequisite Minimum Water Efficiency
1 1 Credit Water Metering and Leak Detection
1 2 8 Credit
2 2 0 9
ENERGY AND ATMOSPHERE (EA) 6 / 33 Points Possible

Y M N PTS
0 0 Prerequisite Carbon Projection and Decarbonization Plan 0 0 Prerequisite Minimum Energy Efficiency
0 0 Prerequisite Fundamental Commissioning
0 0 Prerequisite Energy Metering and Reporting
0 0 Prerequisite Fundamental Refrigerant Management
5 5 Credit Electrification
2 2 5 Credit Reduce Peak Thermal Loads
3 10 Credit Enhanced Energy Efficiency
3 2 5 Credit Renewable Energy
Enhanced Water Efficiency
Des/Con
D
D
Erosion control/site assessmentD/C
D
Des/Con
D
D/C
D
D/C
D/C
D
D
D/C
D
D
D
D
D
D
D/C
D
Minimize Site Disturbance
D/C
D/C
D/C
D
Indoor plumbing, irrigation systems
D/C
1 point for 30% reduction
Initial project analysis by applicant
Meet Title 24 Energy Code
Cx not requied per CALGreen/CEC
Installed meters and reports
Reduce harmful refrigerants
Project includes on site combustion.

Permanent water meter on site
CALGreen low flow and flush fixtures
ASHRAE 90.1 Building Envelope
Initial project analysis by applicant
Solar Ready only, CPAU Green-e certified
Case Study 3
Tier 2 Mixed Use
D
D/C
D
Assessment provided by applicant.

Assessment provided by applicant.

Meeting early in design
Infill site
Area with developmental challenges
Walk Score is 92
Bicycle network and storage
CPA EV requirements > LEED requirements
D
Project restoring disturbed areas
30% Open/Outdoor Space
LID - 85th percentile rainfall
Climate/natural hazard design
SRI 78 required in specs 07 54 23
Met through compliance with CALGreen
25

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4 4 Credit Enhanced Commissioning
2 2 Credit Grid Interactive
1 2 Credit Enhanced Refrigerant Management
6 7 11 33
MATERIALS & RESOURCES (MR) 4 / 18 Points Possible

Y M N PTS
0 0 Prerequisite Planning for Zero Waste Operations
0 0 Prerequisite Quantify and Assess Embodied Carbon
3 3 Credit Building and Materials Reuse
6 6 Credit Reduce Embodied Carbon
2 2 Credit Low-Emitting Materials
2 3 5 Credit Building Product Selection and Procurement 2 2 Credit Construction and Demolition Waste Diversion
4 2 12 18
INDOOR ENVIRONMENTAL QUALITY (EQ) 3 / 13 Points Possible

Y M N PTS
0 0 Prerequisite Construction Management
0 0 Prerequisite Fundamental Air Quality
0 0 Prerequisite No Smoking or Vehicle Idling
1 1 Credit Enhanced Air Quality
2 5 7 Credit Occupant Experience
1 1 Credit Accessibility and Inclusion
1 1 2 Credit
2 2 Credit
3 3 7 13
PROJECT PRIORITIES & INNOVATION (PR) 6 / 10 Points Possible

Y M N PTS
5 4 9 Credit Project Priorities
1 1 Credit LEED Accredited Professional
6 4 0 10
LEED Rating System Point Requirements
Resilient Spaces
D/C
D
D

Y M N POSSIBLE POINTS
39 18 37 110
D/C
C
C
D
D/C
C
D
D/C
D
D
D
C
1 project team must be LEED AP w/ specialty
Air Quality Testing and Monitoring
D
D
D
D/C
No WBLCA, EPD, or carbon tracking
D/C
No IAQ testing indicated
Project team develop CM practices
ASHRAE 62.1, MERV 13
CALGreen tabacco requirements/ No idle
Increased outdoor air rates or IAQ limits
Additional accessibility strategies
Quality Views 75%
Operable windows included
Multiple pathways for points
No Commissioning in plans
No DR or BAS in plans
Requires enhanced refrigerant calcs.

Recyclables & ZW Operations Plan
Initial project analysis by applicant
New construction
CALGreen VOC limits
Choice materials CALGreen (2022)
80% C&D diversion
LEED Certified LEED Silver LEED Gold LEED Platinum
40-49 Pts 50-59 Pts 60-79 Pts 80+ Pts
26 Appendix B

1 CALGreen Tier Prerequisite and Elective Measures by Project The following is a list of the prerequisite and elective measures marked “Yes” (Y) on the project’s approved GB-1 Sheet.

Case Study #1: Tenant Improvement (Tier 1)
Planning & Design
A5.105.1.1 Existing Buildings Structure (75%)
A5.105.1.2 Existing non-Structure elements (50%)
Water Eﬃciency & Conservation

5.303.1.2 Excess consumption (submeters for additions that consume over 1,00 gal/day) A5.303.2.3.1 Water reduction - 12% (Table A5.303.2.3.1)

5.303.3.1 Indoor Water Use: Water closets (1.28 gpf)

5.303.2.1 Indoor Water Use: Wall mounted Urinals 0.125 gpf

5.303.3.4.1 Indoor Water Use: Nonresidential lavatory faucets (0.5 gpm at 60 psi)

5.303.4.2 Indoor Water Use: Kitchen faucets (1.8 gpm at 60 psi)

5.303.4 Commercial kitchen equipment

5.303.4.1 Food waste disposers

5.303.5 Indoor water use: areas of addition or alteration

5.303.6 Indoor water use: Standards for plumbing fixtures and fittings (2022 CA Plumbing Code) A5.303.2.3.3 Water reduction - 25%
A5.303.3 Appliances and fixtures for commercial application Material Conservation & Resource Eﬃciency

5.408.1 Construction waste management

5.408.1.1 Construction waste management plan

5.408.1.2 Waste management company

5.408.1.3 Waste stream reduction alternative

5.408.1.4 Documentation - CWM, Waste management company, waste stream reduction alternative

5.408.2 Universal Waste [AA]

5.408.3 Excavated soil and land clearing debris (100% reuse or recycle) PAMC 16.14.410/
A5.408.3.1
Enhanced construction waste reduction (80% diversion w/ job valuation >$25,000)

5.410.1 Recycle by occupants (with exceptions)

5.410.1.1 Recycle by occupants: Additions (with exceptions) 27 Appendix B

2 5.410.4.3 Testing and adjusting: Procedures

5.410.4.3.1 Testing and adjusting: HVAC balancing

5.410.4.4 Testing, adjusting and balancing: Reporting for HVAC balancing

5.410.4.5 Operation and maintenance (O&M) Manual

5.410.4.5.1 Inspection and reports
PAMC 16.14.360/

5.410.4.6
ENERGY STAR Portfolio Manager profile setup (for projects >$100,000 in value) PAMC 16.14.370/

5.4.10.4.7 Performance Review. - Energy (For projects over 10,000 SF) PAMC 16.14.070 &

16.14.080/ A5.405.4
Recycled content of the total material cost: 10%
A5.405.3 Reused materials (5% of total value)
Environmental Quality

5.504.1 Temporary ventilation (MERV 8)

5.504.3 Covering of duct openings and protection of mechanical equipment during construction

5.504.4.4.1 Adhesives, sealants, caulks: Comply with VOC limits (Table 5.504.4.1 & 5.504.4.2 for VOC limits)

5.504.4.4.3 Paints and Coatings: Comply with VOC Limits (Table 5.504.4.3)

5.504.4.4.1 Carpet systems: carpet cushion

5.504.4.4.2 Carpet systems: carpet adhesive (Table 5.504.4.1 for VOC Limits)

5.504.4.5 Composite wood products: Formaldehyde limits (Table 5.504.4.5)

5.504.4.5.3 Composite wood products: Documentation

5.504.4.6.1 Verification of compliance, for resilient flooring systems PAMC 16.16.070/

16.14.080/ A5.504.4.7
Resilient flooring system - 90%
PAMC 16.16.070 /

16.14.808 / A5.504.4.8
Thermal insulation - Tier 1 requirement

5.504.5.3 Filters: Labeling (MERV 13, with exceptions)

5.504.7 Environmental tobacco smoke (ETS) control

5.505.1 Indoor moisture control

5.506.1 Outside air delivery (For Indoor Air Quality)

5.506.2 Carbon dioxide (CO2) monitoring (For Indoor Air Quality) PAMC 16.14.390/

5.506
Indoor Air Quality Management Plan (locally amended)

5.507.4 Acoustical control (STC Values per ASTM E90 and ASTM E413) 28 Appendix B

3 5.507.4.3 Interior sound transmission (with note)

5.508.1 Ozone depletion and greenhouse gas reductions

5.508.2 Supermarket refrigerant leak reduction

5.508.2.1 Refrigerant piping

5.508.2.2 Refrigerant piping valves

5.508.2.2.2 Refrigerant piping access valves

5.508.2.3 Refrigerated service cases

5.508.2.4 Refrigerant receivers

5.508.2.5 Pressure testing

5.508.2.6 Evacuation after pressure testing
A5.504.4.9 Entryway systems
A5.507.1.2 Lighting and thermal comfort controls: Multi-occupant spaces A5.601.2.4 Acoustic ceiling/ Panels

Case Study #2: New Construction (Tier 2)
Planning & Design
PAMC 16.14.209/

5.106.1
Storm water pollution prevention for projects that disturb < 1 acre of land PAMC 16.14.2090/

5.106.1.1
Local storm water pollution prevention

5.106.1.2 Best management practices

5.106.4.1.1 Short term bicycle parking

5.106.4.1.2 Long term bicycle parking

5.106.5.2.1 Parking stall markings
A5.106.5.1.2 Designated parking - 12% of parking capacity PAMC

16.14.430/A5.106.5.3
EV Charging for Nonresidential Structures - New Construction - Provide Conduit Only, EVSE-Ready Outlet or EVSE Installed for 25% of parking spaces, 5% shall be 5% EVSE Installed PAMC 16.14.295/

5.106.8
Light Pollution Reduction

5.106.10 Grading and paving
A5.106.11.2 Cool roof for reduction of heat island effect A5.103.2 Brownfield or greyfield site redevelopment or infill area development A5.106.2 Storm water design
A5.106.3 Low Impact Development (LID)
29 Appendix B

4 A5.106.4.3 Changing rooms
A5.106.6 Parking capacity
Energy Reach Code
PAMC 16.17.080 All-electric design
PAMC 16.14.380/

5.410.4.6
Energy STAR Portfolio manager
PAMC 16.14.390/

5.410.4.7
Performance review - for projects over 10,000 SF
PAMC 16.14.400/

5.410.4.8
Performance review (For sites > 1 acre)
Water Eﬃciency & Conservation

5.303.1 Meters, separate submeters or metering devices
A5.303.2.3.2 Water Reduction - 20%

5.303.1 Indoor water use: Water closets (not exceed 1.28 gpf)

5.303.3.2.1 Indoor water use: Wall-mounted urinals (0.125 gpf)

5.303.3.2.2 Indoor water use: Floor-mounted urinals (0.5 gpf)

5.303.3.3.1 Indoor water use: Single showerhead (1.8 gpm at 80 psi)

5.303.3.4.1 Indoor water use: Nonresidential lavatory faucets (0.5 gpm at 60 psi)

5.303.3.4.2 Indoor water use: kitchen faucets (1.8 gpm at 60 psi)

5.303.3.4.4 Indoor water use: Metering faucets (0.2 gallons/cycle)

5.303.6 Indoor water use: standards for plumbing fixtures and fittings

5.304.1 Outdoor potable water use in landscape areas (MWELO) PAMC 16.12.030 Recycled water supply systems
PAMC 16.14.360/

5.304.2
Invasive species prohibited
A5.303.2.3.3 Indoor water use: 25% reduction
A5.304.6 Outdoor water use: Restoration of areas disturbed by construction A5.305.2 Irrigation system: Recycled water
Material Conservation & Resource Eﬃciency
A5.405.4 Recycled content: 15%

5.407.1 Weather protection

5.407.2.1 Moisture control: sprinklers

5.407.2.2 Moisture control: Entries + Openings
30 Appendix B

5 5.407.2.2.1 Moisture control: Exterior door protection

5.407.2.2.2 Moisture control: Flashing

5.408.1 Construction waste management

5.408.1.1 Construction waste management plan

5.408.1.2 Waste management company

5.408.1.4 Documentation: Construction WMP, waste management company, waste stream reduction alternative

5.408.3 Excavated soil and land clearing debris (100% reuse or recycle) PAMC 16.14.370/
A5.408.3.1.1
Enhanced construction waste reduction (80% diversion)

5.410.1 Recycling by occupants

5.410.2 Commissioning (≥ 10,000 SF)

5.410.2.3 Commissioning plan

5.410.2.4 Functional Performance Testing

5.410.2.5.1 Documentation and Training: Systems manual

5.410.2.5.2 Documentation and Training: Systems operations training

5.410.2.6 Commissioning Report

5.410.4 Testing and adjusting for [N] buildings < 10,000 SF or new systems serving addition or alterations

5.410.4.2 Testing and adjusting for systems: renewable energy, landscape irrigation, water reuse

5.410.4.3 Testing and adjusting procedures

5.410.4.3.1 Testing and adjusting: HVAC balancing

5.410.4.4 Testing, adjusting, and balancing: Reporting for HVAC balancing

5.410.4.5 Operation and maintenance (O&M) manual
PAMC 16.14.400/

5.410.4.8
Performance reviews. - water (sites > 1 acre)

5.410.4.5.1 Inspection and reports [AA} + [N] < 10,000 SF A5.405.2.1 Bio-based materials: certified wood
A5.406.1.1 Choice of materials: Service life
A5.406.1.2 Choice of materials: Reduced maintenance
A5.406.1.3 Choice of materials: Recyclability
Environmental Quality

5.504.1 Temporary ventilation (MERV 8)
31 Appendix B

6 5.504.3 Covering of duct openings and protection of mechanical equipment during construction

5.504.4.1 Adhesives, sealants and caulks: Comply with VOC Limits (Table 5.504.4.1 and 5.504.4.2 for VOC limits)

5.504.4.3 Paints and coatings: comply with VOC limits (Table 5.504.4.3)

5.504.4.3.1 Aerosol paints and coatings

5.504.4.3.2 Verification for paints and coatings

5.504.4.5 Composite wood products: Formaldehyde limits (Table 5.504.4.5)

5.504.4.5.3 Composite wood products: Documentation
PAMC 16.14.070/
A5.504.4.7.1
Resilient Flooring system, 100%
A5.504.4.8.1 Thermal insulation: No added formaldehyde

5.504.7 Environmental tobacco smoke (ETS) control

5.506.1 Outside air delivery (For Indoor Air Quality)
PAMC 16.14.410 Indoor Air Quality Management Plan

5.507.4 Acoustical control (STC Values per ASTM E90 and ASTM E413)

5.507.4.1 Exterior noise transmission, prescriptive method (with exceptions)

5.507.4.1.1 Noise exposure where noise contours are not readily available

5.507.4.2 Exterior noise transmission, performance method

5.507.4.2.1 Site features

5.507.4.2.2 Documentation of compliance

5.507.4.3 Interior sound transmission (with note)

5.508.1 Ozone depletion and greenhouse gas reductions

5.508.1.1 Chlorofluorocarbons (CFCs)

5.508.1.2 Halons
A5.504.1.2 Indoor Air Quality during construction: Additional IAQ measures A5.504.5.1 Entryway systems (to control pollutants)
A5.504.5.2 Isolation of pollutant sources (to control pollutants) A5.508.1.3 Hydro-chlorofluorocarbons (HCFCs) (for HVAC and refrigeration equipment)

32 Appendix B

7 Case Study #3: Mixed Use New Construction (Tier 2)
Planning & Design
PAMC 16.14.290/

5.106.1
Stormwater pollution prevention for projects that disturb < 1 acre of land PAMC 16.14.290/

5.106.1.1
Local storm water pollution prevention

5.106.1.2 Best management practices (BMP's)
PAMC 18.54.060/

5.106.4
Bicycle parking for additions or change of use that results in increased parking PAMC 18.54.060/

5.106.4.1.1
Short term bicycle parking (exception for additions or alterations which add nine or less visitor vehicular parking spaces)
PAMC 18.54.060/

5.106.4.1.2
Long term bicycle parking
PAMC

16.14.295/5.106.8
Light pollution reduction

5.106.10 Grading and paving (exception for additions and alterations not altering the drainage path) PAMC 16.16.070 &

16.14.080/ A5.106.11.2
Cool roof for reduction of heat island effect
A5.103.1 Community connectivity
A5.106.3 Low impact development (LID)
A5.106.6 Parking capacity
Energy Reach Code
PAMC 16.17.050 Mixed-fuel design 10%
PAMC 16.14.3980/

5.410.4.6
Energy STAR Portfolio Manager
Water Eﬃciency & Conservation

5.303.1 Meters, separate submeters or metering devices installed as follows:

5.303.1.1 New buildings or additions in excess of 50,000 square feet

5.303.1.2 Excess consumption (Submeters for additions that consume over 1,000 gal/ day) A5.303.2.3.2 Indoor Water Use Reduction- 20% savings over the "water use baseline" Table A5.303.2.3.1

5.303.3.1 Indoor Water Use: Water closets (shall not exceed 1.28 gallons per flush)

5.303.3.2.1 Indoor Water Use: Wall-mounted urinals (0.125gpf)

5.303.3.2.2 Indoor Water Use: Floor-mounted urinals (0.5 gpf)

5.303.3.3.1 Indoor Water Use: Single showerhead (1.8 gpm at 80 psi)

5.303.3.3.2 Indoor Water Use: Multiple showerheads serving one shower (flow rate of 1.8 gpm at 80 psi)

5.303.3.4.1 Indoor Water Use: Nonresidential lavatory faucets (0.5 gpm at 60 psi)

5.303.3.4.2 Indoor Water Use: Kitchen faucets (1.8 gpm at 60 psi) 33 Appendix B

8 5.303.3.4.3 Indoor Water Use: Wash fountains (1.8 gpm at 60 psi)

5.303.3.4.4 Indoor Water Use: Metering faucets (0.2 gallons/ cycle)

5.303.3.4.5 Indoor Water Use: Metering faucets for wash fountains (0.2 gallons/ cycle)

5.303.4 Commercial kitchen equipment

5.303.4.1 Food waste disposers

5.303.5 Indoor water use: Areas of addition or alteration [AA] PAMC 16.12.035 Dual plumbing (locally amended)

5.303.6 Indoor Water Use: Standards for plumbing fixtures and fittings (2022 California Plumbing Code)

5.304.1 Outdoor potable water use in landscape areas (MWELO) PAMC 16.12.030 Recycled water supply systems
PAMC 16.14.330
Section 5.304.2
Invasive species prohibited
PAMC 16.14.340
Section 5.306
Non-residential enhanced water budget required when use > 1,000 gal/day PAMC 16.14.350
Section 5.307
Cooling Tower Water Use (locally amended)
A5.303.2.3.3 Indoor water use: 25% reduction
A5.303.2.3.4 Nonpotable water systems for indoor water use A5.303.3 Appliances and fixtures for commercial application A5.303.4.1 Nonwater supplied urinals
A5.304.6 Outdoor Water Use: Restoration of areas disturbed by construction A5.304.7 Outdoor Water Use: Previously developed sites: restore or protect 50 % of site area A5.304.8 Outdoor Water Use: Graywater irrigation system A5.305.1 Nonpotable water systems
A5.305.2 Irrigation system: Recycled water
Material Conservation & Resource Eﬃciency
A5.405.4 Recycled content: 15% of materials based on estimated total cost or use two products from Table A5.405.4 for at least 75% by cost

5.407.1 Weather protection

5.407.2.1 Moisture control: Sprinklers

5.407.2.2 Moisture control: Entries + Openings

5.407.2.2.1 Moisture control: Exterior door protection
34 Appendix B

9 5.407.2.2.2 Moisture control: Flashing

5.408.1 Construction waste management

5.408.1.1 Construction waste management plan

5.408.1.2 Waste management company

5.408.1.3 Waste stream reduction alternative

5.408.1.4 Documentation: Construction waste management plan, waste management company, waste stream reduction alternative

5.408.2 Universal Waste [AA]

5.408.3 Excavated soil and land clearing debris (100% reuse or recycle)

5.409.2 Whole building life cycle assessment

5.409.3 Product GWP compliance—prescriptive path
PAMC 16.14.430/
A5.408.3.1.1
Enhanced construction waste reduction
(80% Diversion w/ job valuation >$25,000, less than $25,000 must meet state standards of 65%)

5.410.1 Recycling by occupants (with exceptions)

5.410.2 Commissioning (≥ 10,000 SF) [N]

5.410.2.3 Commissioning plan [N]

5.410.2.4 Functional performance testing [N]
PAMC 16.14.360 /

5.410.4.6
ENERGY STAR Portfolio Manager profile setup (for projects exceeding $100,000 in value) PAMC 16.14.370 /

5.410.4.7
Performance Review- For projects over 10,000 SF
PAMC 16.14.380/

5.410.4.8
Performance Review (For sites > 1 acre)

5.410.2.5.1 Documentation and Training: Systems manual

5.410.2.5.2 Documentation and Training: Systems operations training [N]

5.410.2.6 Commissioning report [N]

5.410.4 Testing and adjusting for new buildings < 10,000 SF or new systems that serve additions or alterations [N] [AA]

5.410.4.2 Testing and adjusting for systems: Renewable energy, landscape irrigation, and water reuse

5.410.4.3 Testing and adjusting: Procedures

5.410.4.3.1 Testing and adjusting: HVAC balancing

5.410.4.4 Testing, adjusting and balancing: Reporting for HVAC balancing

5.410.4.5 Operation and maintenance (O&M) manual
PAMC 16.14.380/ Sect

5.410.4.8
Performance reviews- Water (sites > 1 acre)
35 Appendix B

10 5.410.4.5.1 Inspection and reports (new buildings / additions and alterations < 10,000 SF) [AA] + [N] A5.404.1.1 Wood Framing: Structural or fire-resistance integrity A5.404.1.2 Wood Framing: Framing specifications
A5.406.1.3 Choice of materials: Recyclability
Environmental Quality

5.504.1 Temporary ventilation (MERV 8)

5.504.3 Covering of duct openings and protection of mechanical equipment during construction

5.504.4.1 Adhesives, sealants and caulks: Comply with VOC limits (Table 5.504.4.1 and 5.504.4.2 for VOC limits)

5.504.4.3 Paints and Coatings: Comply with VOC Limits (Table 5.504.4.3)

5.504.4.3.1 Aerosol paints and coatings

5.504.4.3.2 Verification, for paints and coatings
PAMC 16.16.070 &

16.14.080/ A5.504.4.8.1
Thermal Insulation: No added formaldehyde

5.504.5.3 Filters: Labelling (MERV 13, with exceptions)

5.504.7 Environmental tobacco smoke (ETS) control

5.506.2 Carbon dioxide (CO2) monitoring (For Indoor Air Quality) PAMC 16.14.390 Indoor Air Quality Management Plan

5.507.4 Acoustical control (STC Values per ASTM E90 and ASTM E413)

5.507.4.2 Exterior noise transmission, performance method

5.507.4.3 Interior sound transmission (with note)
A5.504.1.1 Indoor air quality (IAQ) during constructions: Temporary ventilation A5.504.1.2 Indoor air quality (IAQ) during constructions: Additional IAQ measures A5.507.3.1 Views: Direct line of sign to outdoors: interior office spaces

36 Appendix C
1 LEED Certiﬁcation Requirements by California Jurisdiction Jurisdiction Trigger
Belmont • Residential alteration projects adding less than 400 SF with a construction valuation of 0 to $50,000: One Build It Green (BIG) Green Building Practice from the Existing Home Checklist • Residential alteration projects adding less than 400 SF with a construction valuation of $50,001.00 to $99,999: Three BIG Green Building Practices from the Existing Home Checklist • Residential alteration projects adding less than 400 SF with a construction valuation of $100,000.00: 25 BIG points Elements or 50 BIG points Whole House • New residences and residential alteration projects adding 400 SF or greater: 70 BIG points Whole House
• Tenant improvement or new construction commercial projects 10,000 SF or greater: LEED Silver Certiﬁcation
Cupertino • New SF and MF (greater than 9 homes): GPR Certiﬁed at min. 50 points or LEED Silver or Alternate Reference Standard
• NR Mid-size (25,000-50,000 SF): LEED Certiﬁed or Alternate Reference Standard • NR Large (> 50,000 SF): LEED Silver or Alternate Reference Standard • MF Renovations/Additions (w/ FAR increase 50% and at least 35,000 SF and replace or substantially alter the HVAC system and at least two systems - building envelope, hot water system, and lighting system): GPR min. 50 pts, LEED Certiﬁed or LEED EBOM Certiﬁed, or Alternative Reference Standard
• NR Renovations/Additions (35,000 SF or more and replace or substantially alter the HVAC system and two systems - building envelope, hot water system, and lighting system): LEED Certiﬁed (applicable only to the area of renovation/addition), LEED EBOM Certiﬁed, or Alternative Reference Standard
Menlo Park • LEED: Project applicants will have the option to select whether they wish to pursue LEED certiﬁcation or demonstrate LEED-equivalent performance through the LEED performance program (LPP).
• New NR 10,000 sq. ft.—25,000 sq. ft: Designed to meet LEED Silver BD+C • New NR 25,001 sq. ft.—100,000 sq. ft.: Designed to meet LEED Silver BD+C • New NR 100,001 sq. ft. and above: Designed to meet LEED Gold BD+C1 • NR Additions/Alterations 10,000 sq. ft.—25,000 sq. ft. of conditioned area, volume or size:

Designed to meet LEED Silver ID+C1 or update core and shell of entire building to current California Energy Code and meet Section 16.43.140 (Local GB and Energy Standards) • NR Additions/Alterations 25,001 sq. ft. and above of conditioned area, volume or size:

Designed to meet LEED Gold ID+C1 or update core and shell of entire building to current California Energy Code2 and meet Section 16.43.140 (Local GB and Energy Standards) Mountain
View
• The MVGBC does not require formal certiﬁcation from a third-party organization. Instead, projects will be required to be designed and constructed to “meet the intent” of a third-party rating system.
• New Multi-Family 3 Units +: Meet the intent of LEED Gold • New Mixed Use: Meet the Intent of LEED Gold
• New Hotel: Meet the Intent of LEED Gold
• New Commercial: Meet the Intent of LEED Gold

37 Appendix C
2 LEED Certiﬁcation Requirements by California Jurisdiction Jurisdiction Trigger
San
Francisco
• New Large Commercial ≥ 25,000 SF: LEED v4 Gold
• New Res All Sizes: GreenPoint Rated or LEED v4 Silver • Major Res Alterations ≥ 25,000 SF AND significant structural upgrade AND mechanical, electrical, or plumbing: GreenPoint Rated or LEED v4 Silver • Large First-Time Commercial Interiors ≥ 25,000 SF: LEED v4 Gold • Major Nonres Alterations ≥ 25,000 SF: LEED v4 Gold
• Municipal New Construction, Additions/Alterations ≥10,000 square feet, including leasehold improvements: LEED v4 Gold
San José • Municipal projects 10,000 SF or more: LEED Gold certiﬁcation • Large commercial industrial building or a large residential project or high-rise MF: Green building refundable deposit.
• Municipal buildings 15,000 SF or more and Privately-owned Residential or Nonresidential Buildings 20,000 SF or more: Energy and Water Building Performance Ordinance.

Commercial/Industrial - Tier 1 < 25,000 square feet: LEED Applicable NC Checklist Commercial/Industrial - Tier 2 ≥ 25,000 square feet: LEED Silver • Residential < 10 units Tier 1: GreenPoint or LEED Checklist • Residential ≥ 10 units Tier 2: GreenPoint Rated 50 points or LEED Certiﬁed • High Rise Residential (75' or higher): LEED Certiﬁed
Saratoga • Public buildings 5,000 SF or more: LEED Silver and City maintains LEED AP list Foster City • LEED Silver for individual projects (Gilead Sciences, Pilgrim Triton Master Plan and Chess/Hatch Oﬃces)
Sunnyvale • Bonus and Max FAR for Nonresidential Development: LEED BD+C Platinum and whole building life cycle assessment
• New NR and Initial TIs > 5,000 sq. ft. 30,000 sq. ft. CALGreen Mandatory Measures and LEED Gold Level with veriﬁcation by a LEED AP
• New NR and Initial TIs > 30,000 sq. ft. CALGreen Mandatory Measures and LEED Gold Level with USGBC Certiﬁcation, including Design Phase Credits reviewed and approved by USGBC:
• All Major Alterations CALGreen Mandatory Measures and LEED Silver with veriﬁcation by a

LEED AP
• New Public Facility ≤ 5,000 sq. ft.: CALGreen Mandatory Measures as applicable to the scope of work. Reviewed by City staﬀ.
• New Public Facility > 5,000 sq. ft.: CALGreen Mandatory Measures and LEED Gold Level with veriﬁcation by a LEED AP --
• All Major Alterations: CALGreen Mandatory Measures and LEED Silver with veriﬁcation by a

LEED AP

38 Appendix D
LEED Certiﬁcation Alternative Compliance Policy Options Summary Table Policy Option Scope LEED Level CALGreen Requirements Key Beneﬁts Implementation Considerations Option 1:

Standalone
LEED
Pathway
Allow LEED Gold
Certiﬁcation as a
complete alternative
to CALGreen Tier 1
and Tier 2
requirements. Projects
still must comply with
CALGreen Mandatory
and local PAMC code
amendments.

LEED Gold
Certiﬁcation
• Mandatory Measures
(Chapter 5)
• Local amendments
• Tier prerequisites/electives
do not apply
• Simpliﬁed compliance for
LEED projects
• Third-party veriﬁcation via
GBCI
• Reduced administrative
burden
• Industry alignment
• Third-party oversight outside
City control
• Requires City veriﬁcation
mechanism
• No Tier prerequisite
compliance
Option 2:

LEED + Tier
Prerequisites
Allow LEED Gold
Certiﬁcation as an
alternative pathway
only if all CALGreen
Tier 1 or Tier 2
prerequisite measures
are still incorporated
into the project design
and construction.

LEED Gold
Certiﬁcation
• Mandatory Measures
(Chapter 5)
• Local amendments
• All applicable Tier 1 or
Tier 2 prerequisites apply
• Maintains CALGreen
baseline standards
• Leverages LEED-
CALGreen synergies
• Preserves City
environmental goals
• Flexible compliance
pathway
• Requires documentation of
Tier prerequisite compliance
• More complex veriﬁcation
process
• Need for periodic LEED-
CALGreen alignment review
Option 3:

Diﬀerentiate
by Project
Scope
Allow LEED Gold
Certiﬁcation as an
alternative only for
Tier 2 projects. For Tier
1, the City selects one
of the following: 1)
Require LEED Silver, or
2) Exclude from LEED
option.

Tier 2:

LEED Gold

Tier 1:

LEED Silver
OR no
alternative
pathway
• Mandatory Measures
(Chapter 5)
• Local amendments
• Tier requirements as
applicable and
determined by City staﬀ
• Tailored approach by
project complexity
• City control over Tier 1
pathway
• Aligns certiﬁcation level
with project scope
• Requires City decision on Tier
1 approach
• Diﬀerentiated enforcement
mechanisms
• More complex policy
framework

39 Appendix E

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See next page for Appendix details.
40 CALGreen / LEED BD+C v5 Comparison: Nonresidential Projects CALGreen/ PAMC Requirement LEED Equivalent Analysis
• Designated parking for clean air
vehicles - 35% (CALGreen A5.106.5.1.1)
No LEED BD+C equivalent prerequisite. LEED credit Electric Vehicles (LTc5) requires that 5% of all parking spaces (or min. 2) for 1 pt or 10% (or min. 4) for 2 pts have electric vehicle supply equipment (EVSE) installed. Alternatively, nonres projects can install 10% EV Readiness (or min. 10 spaces) for 1pt. LEED does not enhance this PAMC requirement. Projects would be subject to local amendments and Tier 1 requirements.
• Cool roof for reduction of heat island
effect - Tier 1 standards (CALGreen
A5.106.11.2)
No LEED eBD+C equivalent prerequisite. LEED credit Heat Island Reduction (SSc5) includes Option 1 Nonroof and Roof strategies, Option 2 100% Parking under cover, Option 3: Tree Equity. For roof areas, CALGreen Tier 1 requires an aged SRI value of 75 for low-sloped roofs (≤ 2:12), and 16 for steep-sloped roofs (> 2:12), and LEED requires an aged SRI value of 64 for low-sloped roofs (≤ 2:12), and 32 for steep-sloped roofs (> 2:12).

Tier 1 Water
Prerequisites
• Indoor water use reduction - 12%
(CALGreen A5.303.2.3.1)
LEED BD+C equivalent prerequisite. LEED prerequisite (WEp2) requires minimum efficiency for indoor and outdoor water use, prescriptive and performance pathways are available.

Performance path requires 20% indoor water use reduction and no irrigation for outdoor water use or 30% reduction from the baseline.

CALGreen: Tier 1 only requires 12% reduction in indoor water use. CALGreen sets maximum prescriptive flow rates for kitchen faucets, wash fountains, metering faucets and metering faucets for wash fountains. Further, CALGreen Tier 2 and LEED requires 20% indoor water use reduction on all applicable water use fixtures compared to base case water consumption calculations as a prerequisite. CALGreen is more stringent than LEED at a fixture level in some cases, but LEED is a performance based calculation and projects could meet or exceed the reduction rates of CALGreen prescriptive rates. • Recycled content: 10% of materials
(CALGreen A5.405.4)
No LEED BD+C equivalent prerequisite. CALGreen Tier 1 requires projects to use materials, equivalent in performance to virgin materials with a total (combined) recycled content value (RCV) of 10% by cost.

LEED does not have a requirement for installing products or using building materials with recycled content. Recycled content can be a strategy used for the Quantify and Assess Embodied Carbon (MRp2) and Building Product Selection and Procurement (MRc4).
• Enhanced construction waste
reduction - 80% (PAMC

16.14.410/CALGreen A5.408.3.1)
No LEED BD+C equivalent prerequisite. LEED credit Construction and Demolition Waste Diversion (MRc5) requires C&D Materials Management Plan and awards points based on diversion achieved: 1 pt for 50% diversion and at least 10% of diverted materials must be salvaged or source-separated or 2pts for 75% diversion and at least 25% salvaged or source-separated. Projects would be subject to locally amended C&D diversion rate.
• Resilient flooring system - 90%
(CALGreen A5.504.4.7)
No LEED BD+C equivalent prerequisite. LEED credit Low-Emitting Materials (MRc3) focuses on VOC limits for materials on the building interior (flooring is part of the Path 1 product categories).

LEED does not enhance this PAMC requirement. Projects would be subject to local amendments.
• Thermal insulation - no added
formaldehyde (CALGreen A5.504.4.8)
No LEED BD+C equivalent prerequisite. CALGreen requires projects to use composite wood products approved by the California Air Resources Board (ARB) with no-added formaldehyde (NAF) based resins or ultra-low emitting formaldehyde (ULEF) resins.

LEED credit Low-Emitting Materials (MRc3) includes insulation as an option to choose under Path 2. LEED does not enhance this PAMC requirement.

Projects would be subject to local amendments.

CALGreen/ PAMC Requirement LEED Equivalent Analysis
• Designated parking for clean air
vehicles - 50% (CALGreen A5.106.5.1.1)
No LEED BD+C equivalent prerequisite. LEED credit Electric Vehicles (LTc5) requires that 5% of all parking spaces (or min. 2) for 1 pt or 10% (or min. 4) for 2 pts have electric vehicle supply equipment (EVSE) installed. Alternatively, nonres projects can install 10% EV Readiness (or min. 10 spaces) for 1pt. LEED does not enhance this PAMC requirement. Projects would be subject to local amendments and Tier 1 requirements.

Tier 2 Site
Prerequisites
Note: The following table includes PAMC locally amended provisions from the 2022 code cycle based on 2025 express terms. Similar to Tier 1 and Tier 2 projects, any project pursuing LEED certification need to comply with all state and local building requirements.1, 2, 3 Tier 1 CALGreen/ PAMC Requirements
Tier 1 Site
Prerequisites
Tier 1
Material
Prerequisites
Tier 1
Environmental
Quality
Prerequisites
Tier 2 CALGreen/ PAMC Requirements
41 CALGreen / LEED BD+C v5 Comparison: Nonresidential Projects Note: The following table includes PAMC locally amended provisions from the 2022 code cycle based on 2025 express terms. Similar to Tier 1 and Tier 2 projects, any project pursuing LEED certification need to comply with all state and local building requirements.1, 2, 3 Tier 1 CALGreen/ PAMC Requirements
• EV Charing Infrastructure
º parking areas 10-20 spaces - 20%
EVSE or 20% EV Capable or EVSE Ready
º parking areas ≥ 20 spaces - 15%
EVSE and 15% EV Capable or EVSE
Ready (PAMC 16.14.400/ CALGreen
A4.106.5.3)
No LEED BD+C equivalent prerequisite. LEED credit Electric Vehicles (LTc5) requires that 5% of all parking spaces (or min. 2) for 1 pt or 10% (or min. 4) for 2 pts have electric vehicle supply equipment (EVSE) installed. Alternatively, nonres projects can install 10% EV Readiness (or min. 10 spaces) for 1pt. PAMC currently requires 20% EV Capable or EV Ready, 20% EVSE Installed (10-20 parking spaces) and 15% EV Capable or EV Ready and 15% EVSE Installed (over 20 parking spaces).

CALGreen requires 10% for existing when electrical/lighting or panel upgrade is included in scope, PV added, or alterations trigger CALGreen.

LEED does not enhance this PAMC requirement. Projects would be subject to local amendments.
• Cool roof for reduction of heat island
effect Tier 2 standards (CALGreen
A5.106.11.2)
No LEED BD+C equivalent prerequisite. LEED credit Heat Island Reduction (SSc5) includes Option 1 Nonroof and Roof strategies, Option 2 100% Parking under cover, Option 3: Tree Equity. For roof areas, CALGreen Tier 2 requires an aged SRI value of 82 for low-sloped roofs (≤ 2:12), and 27 for steep-sloped roofs (> 2:12) and LEED requires an aged SRI value of 64 for low-sloped roofs (≤ 2:12), and 32 for steep-sloped roofs (> 2:12).

Tier 2 Water
Prerequisites
• Indoor water use reductions - 20%
(CALGreen A5.303.2.3.1)
LEED BD+C equivalent prerequisite. LEED prerequisite (WEp2) requires minimum efficiency for indoor and outdoor water use, prescriptive and performance pathways are available.

Performance path requires 20% indoor water use reduction and no irrigation for outdoor water use or 30% reduction from the baseline.

CALGreen: 20% reduction required for Tier 2. CALGreen sets maximum prescriptive flow rates for kitchen faucets, wash fountains, metering faucets and metering faucets for wash fountains. Further, CALGreen and LEED require 20% water use reduction on all applicable water use fixtures compared to base case water consumption calculations. CALGreen is more stringent than LEED at a fixture level in some cases, but LEED is a performance based calculation and projects could meet or exceed the reduction rates of CALGreen prescriptive rates.
• Recycled content: 15% of materials
(CALGreen A5.405.4)
No LEED BD+C equivalent prerequisite. CALGreen Tier 2 requires projects to use materials, equivalent in performance to virgin materials with a total (combined) recycled content value (RCV) of 15% by cost.

16.14.410/CALGreen A5.408.3.1)
No equivalent LEED BD+C prerequisite. LEED credit Construction and Demolition Waste Diversion (MRc5) requires C&D Materials Management Plan and awards points based on diversion achieved: 1 pt for 50% diversion and at least 10% of diverted materials must be salvaged or source-separated or 2pts for 75% diversion and at least 25% salvaged or source-separated. Projects would be subject to locally amended C&D diversion rate.
• Resilient flooring system - 100%
(CALGreen A5.504.4.7)
No LEED equivalent BD+C prerequisite. LEED credit Low-Emitting Materials (MRc3) focuses on VOC limits for materials on the building interior (flooring is part of the Path 1 product categories).

LEED does not enhance this PAMC requirement. Projects would be subject to local amendments.
• Thermal insulation - no added
formaldehyde (CALGreen A5.504.4.8)
No LEED equivalent BD+C prerequisite. CALGreen requires projects to use composite wood products approved by the California Air Resources Board (ARB) with no-added formaldehyde (NAF) based resins or ultra-low emitting formaldehyde (ULEF) resins.

LEED credit Low-Emitting Materials (MRc3) includes insulation as an option to choose under Path 2. LEED does not enhance this PAMC requirement.

Projects would be subject to local amendments.
1 Projects that pursue LEED Certification would still be subject to CALGreen Mandatory requirements (Chapter 4 for residential and Chapter 5 for nonresidential), as well as any applicable locally amended building requirements in PAMC 16.14 (CALGreen) and PAMC 16.17 (Energy Code). 3 LEED v5 BD+C includes the following prerequisites: IPp1 Climate Resilience Assessment, IPp2 Human Impact Assessment, IPp3 Carbon Assessment, IPp4 Tenant Guidelines (C&S), SSp1 Minimized Site Disturbance, WEp1 Water Metering and Reporting, WEp2 Minimum Water Efficiency, EAp1 Operational Carbon Projection and Decarbonization Plan, EAp2 Minimum Energy Efficiency, EAp3 Fundamental Commissioning, EAp4 Energy Metering and Reporting, EAp5 Fundamental Refrigerant Management, MRp1 Planning for Zero Waste Operations, MRp2 Quantify and Assess Embodied Carbon, EQp1 Construction Management, EQp2 Fundamental Air Quality, EQp3 No Smoking or Vehicle Idling.

Tier 2 Site
Prerequisites
Tier 2
Material
Prerequisites
2 CALGreen Divisions A4.6 and A5.6 outline the Tier 1/Tier 2 prerequisites a project must meet to achieve CALGreen tier status. In addition the divisions specify the number of electives from each CALGreen Division Category a project must choose. PAMC does not require Tier 1 and Tier 2 projects to comply with the CALGreen Energy Efficiency Tier requirements due to the local Energy Reach Code requirements.

Tier 2
Environmental
Quality
Prerequisites
42 Appendix F

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See next page for Appendix details.
43 CALGreen / LEED ID+C v5 Comparison: Nonresidential Projects CALGreen/ PAMC Requirement LEED Equivalent Analysis
• Designated parking for clean air
vehicles - 35% (CALGreen A5.106.5.1.1)
No LEED ID+C equivalent prerequisite. LEED credit Electric Vehicles (LTc3) requires that 5% of all parking spaces (or min. 2) for 1 pt or 10% (or min. 4) for 2 pts have electric vehicle supply equipment (EVSE) installed. LEED does not enhance this PAMC requirement.

Projects would be subject to local amendments and Tier 1 requirements. • Cool roof for reduction of heat island
effect - Tier 1 standards (CALGreen
A5.106.11.2)
No LEED ID+C equivalent prerequisite. There is no LEED v5 ID+C cool roof requirement.

Tier 1 Water
Prerequisites
• Indoor water use reduction - 12%
(CALGreen A5.303.2.3.1)
LEED ID+C equivalent prerequisite. LEED prerequisite (WEp2) requires minimum efficiency for indoor and outdoor water use, prescriptive and performance pathways are available.

Performance path requires 20% indoor water use reduction and newly installed appliances must meet additional water use requirements.

CALGreen: Tier 1 only requires 12% reduction in indoor water use. CALGreen sets maximum prescriptive flow rates for kitchen faucets, wash fountains, metering faucets and metering faucets for wash fountains. Further, CALGreen Tier 2 and LEED requires 20% indoor water use reduction on all applicable water use fixtures compared to base case water consumption calculations as a prerequisite. CALGreen is more stringent than LEED at a fixture level in some cases, but LEED is a performance based calculation and projects could meet or exceed the reduction rates of CALGreen prescriptive rates.
• Recycled content: 10% of materials
(CALGreen A5.405.4)
No LEED ID+C equivalent prerequisite. CALGreen Tier 1 requires projects to use materials, equivalent in performance to virgin materials with a total (combined) recycled content value (RCV) of 10% by cost.

16.14.410/CALGreen A5.408.3.1)
No LEED ID+C equivalent prerequisite. LEED credit Construction and Demolition Waste Diversion (MRc5) requires C&D Materials Management Plan and awards points based on diversion achieved: 1 pt for 35% diversion and at least 10% of diverted materials must be salvaged or source-separated, 2 points for 50% diversion and at least 20% of diverted materials must be salvaged or source-separated, 3 points for 65% diversion and at least 30% of diverted materials must be salvaged or source-separated.

Additionally, 1 point may be achieved if the project exceeds 10% of all salvaged or source separated and recycled clean gypsum, carpet, ceiling and furniture.

Projects would be subject to locally amended C&D diversion rate. • Resilient flooring system - 90%
(CALGreen A5.504.4.7)
No LEED ID+C equivalent prerequisite. LEED credit Low-Emitting Materials (MRc3) focuses on VOC limits for materials on the building interior (flooring is part of the Path 1 product categories). LEED does not enhance this PAMC requirement. Projects would be subject to local amendments.
• Thermal insulation - no added
formaldehyde (CALGreen A5.504.4.8)
No LEED ID+C equivalent prerequisite. CALGreen requires projects to use composite wood products approved by the California Air Resources Board (ARB) with no-added formaldehyde (NAF) based resins or ultra-low emitting formaldehyde (ULEF) resins.

LEED credit Low-Emitting Materials (MRc3) includes insulation as an option to choose. LEED does not enhance this PAMC requirement. Projects would be subject to local amendments.

CALGreen/ PAMC Requirement LEED Equivalent Analysis
• Designated parking for clean air
vehicles - 50% (CALGreen A5.106.5.1.1)
No LEED ID+C equivalent prerequisite. LEED credit Electric Vehicles (LTc3) requires that 5% of all parking spaces (or min. 2) for 1 pt or 10% (or min. 4) for 2 pts have electric vehicle supply equipment (EVSE) installed. LEED does not enhance this PAMC requirement.

Projects would be subject to local amendments and Tier 1 requirements.

Tier 2 Site
Prerequisites
Note: The following table includes PAMC locally amended provisions from the 2022 code cycle based on 2025 express terms. Similar to Tier 1 and Tier 2 projects, any project pursuing LEED certification need to comply with all state and local building requirements.1, 2, 3 Tier 1 CALGreen/ PAMC Requirements
Tier 1 Site
Prerequisites
Tier 1 Material
Prerequisites
Tier 1
Environmental
Quality
Prerequisites
Tier 2 CALGreen/ PAMC Requirements
44 CALGreen / LEED ID+C v5 Comparison: Nonresidential Projects Note: The following table includes PAMC locally amended provisions from the 2022 code cycle based on 2025 express terms. Similar to Tier 1 and Tier 2 projects, any project pursuing LEED certification need to comply with all state and local building requirements.1, 2, 3 Tier 1 CALGreen/ PAMC Requirements
• EV Charing Infrastructure
º parking areas 10-20 spaces - 20%
EVSE or 20% EV Capable or EVSE Ready
º parking areas ≥ 20 spaces - 15%
EVSE and 15% EV Capable or EVSE
Ready (PAMC 16.14.400/ CALGreen
A4.106.5.3)
No LEED ID+C equivalent prerequisite. LEED credit Electric Vehicles (LTc5) requires that 5% of all parking spaces (or min. 2) for 1 pt or 10% (or min. 4) for 2 pts have electric vehicle supply equipment (EVSE) installed. PAMC currently requires 20% EV Capable or EV Ready, 20% EVSE Installed (10-20 parking spaces) and 15% EV Capable or EV Ready and 15% EVSE Installed (over 20 parking spaces). CALGreen requires 10% for existing when electrical/lighting or panel upgrade is included in scope, PV added, or alterations trigger CALGreen.

Tier 2 Water
Prerequisites
• Indoor water use reductions - 20%
(CALGreen A5.303.2.3.1)
LEED ID+C equivalent prerequisite. LEED prerequisite (WEp2) requires minimum efficiency for indoor and outdoor water use, prescriptive and performance pathways are available.

Performance path requires 20% indoor water use reduction and and newly installed appliances must meet additional water use requirements.

CALGreen: 20% reduction required for Tier 2. CALGreen sets maximum prescriptive flow rates for kitchen faucets, wash fountains, metering faucets and metering faucets for wash fountains. Further, CALGreen and LEED require 20% water use reduction on all applicable water use fixtures compared to base case water consumption calculations. CALGreen is more stringent than LEED at a fixture level in some cases, but LEED is a performance based calculation and projects could meet or exceed the reduction rates of CALGreen prescriptive rates.
• Recycled content: 15% of materials
(CALGreen A5.405.4)
No LEED ID+C equivalent prerequisite. CALGreen Tier 2 requires projects to use materials, equivalent in performance to virgin materials with a total (combined) recycled content value (RCV) of 15% by cost.

16.14.410/CALGreen A5.408.3.1)
No equivalent LEED ID+C prerequisite. LEED credit Construction and Demolition Waste Diversion (MRc5) requires C&D Materials Management Plan and awards points based on diversion achieved: 1 pt for 35% diversion and at least 10% of diverted materials must be salvaged or source-separated, 2 points for 50% diversion and at least 20% of diverted materials must be salvaged or source-separated, 3 points for 65% diversion and at least 30% of diverted materials must be salvaged or source-separated.

Additionally, 1 point may be achieved if the project exceeds 10% of all salvaged or source separated and recycled clean gypsum, carpet, ceiling and furniture.

Projects would be subject to locally amended C&D diversion rate. • Resilient flooring system - 100%
(CALGreen A5.504.4.7)
No LEED ID+C equivalent prerequisite. LEED credit Low-Emitting Materials (MRc3) focuses on VOC limits for materials on the building interior (flooring is part of the Path 1 product categories). LEED does not enhance this PAMC requirement. Projects would be subject to local amendments.
• Thermal insulation - no added
formaldehyde (CALGreen A5.504.4.8)
No LEED ID+C equivalent prerequisite. CALGreen requires projects to use composite wood products approved by the California Air Resources Board (ARB) with no-added formaldehyde (NAF) based resins or ultra-low emitting formaldehyde (ULEF) resins.

LEED credit Low-Emitting Materials (MRc3) includes insulation as an option to choose under Path 2. LEED does not enhance this PAMC requirement.

Projects would be subject to local amendments.
1 Projects that pursue LEED Certification would still be subject to CALGreen Mandatory requirements (Chapter 4 for residential and Chapter 5 for nonresidential), as well as any applicable locally amended building requirements in PAMC 16.14 (CALGreen) and PAMC 16.17 (Energy Code). 3 LEED v5 ID+C includes the following prerequisites: IPp1 Climate Resilience Assessment, IPp2 Human Impact Assessment, IPp3 Carbon Assessment, WEp1 Minimum Water Efficiency, EAp1 Estimated Energy Use and Operational Carbon Projection, EAp2 Minimum Energy Efficiency, EAp3 Fundamental Commissioning, EAp4 Energy Metering and Reporting, EAp5 Fundamental Refrigerant Management, MRp1 Planning for Zero Waste Operations, MRp2 Quantify and Assess Embodied Carbon, EQp1 Construction Management, EQp2 Fundamental Air Quality, EQp3 No Smoking.

Tier 2 Site
Prerequisites
Tier 2 Material
Prerequisites
2 CALGreen Divisions A4.6 and A5.6 outline the Tier 1/Tier 2 prerequisites a project must meet to achieve CALGreen tier status. In addition the divisions specify the number of electives from each CALGreen Division Category a project must choose. PAMC does not require Tier 1 and Tier 2 projects to comply with the CALGreen Energy Efficiency Tier requirements due to the local Energy Reach Code requirements.

Tier 2
Environmental
Quality
Prerequisites
45

Palo Alto City CouncilOctober 6, 2025

Palo Alto City Council
October 6, 2025