OCTOBER 6, 2025 PaloAlto.gov
Local Amendments to
the 2025 Building
Standards Code
George Hoyt, Chief Building Official
Tim Scott, Resource Planner
Building Standards Code Update Process
California updates its Building Standards Code every
three years.
• Current 2022 code update took effect January 1, 2023
• 2025 code update will take effect January 1, 2026
Local jurisdictions may adopt local amendments to
the 2025 California Building Standards Code once
the state code is published.
• Must be more restrictive/stringent than the state code • Must make express findings that each amendment is
reasonably necessary due to local geological,
topographical, climatic or environmental conditions
2 Legislative Updates
AB 130 (formerly AB 306) passed on June 30, 2025
Includes language that limits the ability of
jurisdictions to adopt new residential local
amendments to California Building Standards Code
from Oct 1, 2025 through 2031
Code adoption timeline was modified this year to
pass new residential local amendment ahead of
October 1, 2025.
3 Code Adoption Timeline
• September 8, 2025: City Council approved select
new residential proposals for immediate adoption
• Proposals have been submitted to CEC for review
• October 6, 2025 (tonight): City Council to consider new non- residential proposals for adoption and prior local
amendments for re-adoption
• November 3, 2025: City Council to consider potential local amendments to the California Fire Code on consent
• Spring 2026: City Council to consider energy reach codes for multi-family and non-residential projects (delayed to align with availability of cost effectiveness studies)
4 California Building Standards Codes New Local
Amendments
Renewed Local
Amendments
Council Consideration, Discussion & Action
Part 1: CA Administrative Code No No N/A
Part 2: CA Building Code Yes Yes October 2025
Part 2.5: CA Residential Code No Yes October 2025
Part 3: CA Electrical Code No Yes October 2025
Part 4: CA Mechanical Code No Yes October 2025
Part 5: CA Plumbing Code Yes Yes October 2025
Part 6: CA Energy Code Yes Yes September & October 2025 (& Spring 2026) Part 7: Wildland-Urban Interface Code No N/A November 2025 Part 8: CA State Historical Building Code No Yes October 2025 Part 9: CA Fire Code Yes Yes November 2025
Part 10: CA Existing Building Code No Yes October 2025 Part 11: CA Green Building Standards Code Yes Yes October 2025 Part 12: CA Reference Code Standards No No N/A
International Swimming Pool & Spa Code No Yes October 2025 Summary of Local Code Amendments
5 New local
amendments
are proposed
to 5
of the
13 parts of
the CA
Building
Standards
Code.
New Local Amendments to
Energy and Green Building
Standards Code (CALGreen)
6 Green Building and Energy Amendment Timeline
paloalto.gov/GreenBuildingCodeRequirements 7
Adoption Date Local Code Amendments
Green Building Reach Code Energy Reach Code
September 2025
• None • Air Conditioner Time of
Replacement
• FlexPath
October 2025
• Carry forward previous local Green Building
Code amendments (including CALGreen
Tier 1 & 2 adoption)
• LEED Certification Alternative Compliance
Pathway
• Embodied Carbon Threshold
• EV Readiness
• Carry forward previous local Energy
Code amendments, as supported by
cost effectiveness studies
Spring 2026
• None • Potential additional Energy Code
amendments as supported by newly
available cost effectiveness studies
and model code language. e.g., Gas
Water Heater Time of Replacement,
Source Energy Compliance Margin
• Adopted by Palo Alto in October 2024 as
part of the “One Margin” effort after the all-
electric new construction requirements
were reversed
• Requires new construction to meet stricter
source energy compliance margins that
exceed the state requirement levels
• Must be supported by cost-effectiveness
studies, which are not expected to be
published until late 2025 or early 2026
• Staff will propose new source energy
requirements after the new cost-
effectiveness studies are completed in 2026
Source Energy Compliance Requirement
paloalto.gov/GreenBuildingCodeRequirements 8
Picture
LEED Certification Compliance Pathway
paloalto.gov/GreenBuildingCodeRequirements
Proposal: Allow LEED certification as an
alternative to CALGreen Tier 1 and Tier 2
standards for non-residential buildings.
Objective: Simplify code compliance for
projects interested in pursuing LEED
certification and align codes more closely
with other local jurisdictions.
State Code
: CALGreen Mandatory
requirements.
Existing Local Amendment
: Enforce
CALGreen Tier 1 and Tier 2 requirements
for qualifying remodel/addition projects
and new construction.
9 CALGreen
Tier 2
CALGreen
Tier 1
LEED Certification Compliance Pathway - Cont.
paloalto.gov/GreenBuildingCodeRequirements
Details:
• LEED Silver certification as an alternative
compliance pathway for Tier 1 projects
• LEED Gold certification as an alternative
compliance pathway for Tier 2 projects
• Projects must still comply with a couple
key Tier 1/2 prerequisites
• EV charging infrastructure
• Construction & demolition waste
10 CALGreen
Tier 2
CALGreen
Tier 1
LEED Certification Compliance Pathway - Cont.
paloalto.gov/GreenBuildingCodeRequirements 11
Changes in Prerequisites: LEED vs. CALGreen Tier 1 and Tier 2 CALGreen Tier
Prerequisites
• Designated parking for clean air vehicles
• Cool roof requirements to reduce the heat island
effect
• Minimum recycled content in building materials
• Enhanced construction waste reduction
• VOC limits for resilient flooring systems
• Formaldehyde limits for thermal insulation
• Electric vehicle charging infrastructure requirements LEED
Prerequisites1
• Climate Resilience Assessment
• Human Impact Assessment
• Carbon Assessment
• Operational Carbon Projection and Decarbonization
Plan
• Fundamental Commissioning
• Planning for Zero Waste Operations
• Quantify and Assess Embodied Carbon
1 This table shows select key LEED prerequisites met by using LEED as an alternative compliance path.
* Certain mandatory CALGreen and PAMC provisions would also achieve LEED credits (e.g. enhanced C&D waste diversion, EV Charging).
CALGreen
Tier 2
CALGreen
Tier 1
Proposal: Lower the threshold for
embodied carbon compliance to 25,000 sf.
Objective: Promote GHG emissions
reduction in more Palo Alto construction.
State Code
: 2025 CALGreen drops the
embodied carbon compliance threshold
from nonresidential buildings from
100,000 sf to 50,000 sf.
Existing Local Amendment
: No change
beyond 2022 state code.
Embodied Carbon
paloalto.gov/GreenBuildingCodeRequirements 12
Picture
Proposal: Replace the existing nonresidential local code with the CALGreen Tier 2 requirements calculated using
either the standard methodology (Table A5.106.5.3.3 Tier 2) or the Power Allocation Method (Table A5.106.5.3.4 Tier 2) Objective: Simplify code compliance and promote GHG
emissions reduction through EV charger availability.
State Code
: Comply with charger infrastructure
requirements using either the standard methodology
(Table 5.106.5.3.1) or the Power Allocation Method (Table
5.106.5.3.6)
Existing Local Amendment:
• 10 to 20 parking spaces: 20% EV Capable Spaces AND
20% Level 2 EV Chargers Installed
• Over 20 parking spaces: 15% EV Capable Spaces AND
15% EV Chargers Installed
Nonresidential EV Readiness
paloalto.gov/GreenBuildingCodeRequirements 13
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All Other New Local
Amendments
Limited New Local Amendments
In addition to the Energy and CALGreen codes, the
City is only proposing new local amendments to the
California Building, Plumbing and Fire Codes.
Staff recommends the City readopt prior local
amendments, as applicable, for all other parts of the
code.
Prior local amendments that have been incorporated
into the model code have been removed and
applicable references updated.
15 California Building and Plumbing Codes
California Building Code: New local amendments to
identify triggers for automatic sprinkler systems and
require more intense fire sprinkler design for
different types of new and existing nonresidential
buildings
California Plumbing Code: New local amendments
to update requirements for the management of fats,
oils, and grease as outlined in PAMC Chapter 16.13.
16 California Fire Code
New local amendments to the fire code will be reviewed by Council in November on consent and may include:
• Administrative updates to definitions and code standards • Fire apparatus access: turning radius, security gates, and minimum widths (county recommendations)
• Address identification requirements
• Regulations related to enclosed garages, including requiring a Knox Box • Revised sprinkler requirements for trash enclosures
• Sprinkler requirements for indoor energy storage systems • Smoke alarm maintenance and replacement requirements
• Regulations related to the number of energy storage systems in enclosed areas • Fire flow requirements during construction
17 Staff Recommendation
Staff recommends that the City Council:
1. Adopt the ordinances in Attachments A through H that amend chapters of the Palo Alto Municipal Code (PAMC) related to the 2025 California Building Standards Codes (Cal. Code of Regulations Title 24) and proposed local amendments; and
2. Direct staff to return to Council on the Consent Calendar with ordinances adopting the 2025 editions of the California Wildlands- Urban Interface Code and California Fire Code and local amendments thereto; and
3. Approve an amendment to the Fiscal Year 2026 Budget appropriation in the General Fund (requires a 2/3 majority vote) by:
a. Increasing the Planning and Development Services expenditure appropriation by $96,000; and
b. Decreasing the Budget Stabilization Reserve by $96,000. 18 George Hoyt
Chief Building Official
Planning & Development Services
[email protected]
Tim Scott
Resource Planner
Utilities
[email protected]