City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Planning and Development Services
Meeting Date: October 6, 2025
Report #:2506-4898
TITLE
Adoption of Eight Ordinances Amending Various Sections of the Palo Alto Municipal Code (PAMC) Related to the 2025 California Building Standards Code (CA Code of Regulations Title 24) Update, including: (1) Chapter 16.04 Incorporating the 2025 CA Building Code With Local Amendments; (2) Chapter 16.05 Incorporating the 2025 CA Mechanical Code With Local Amendments; (3) Chapter 16.06 Incorporating the 2025 CA Residential Code With Local Amendments; (4) Chapter 16.08 Incorporating the 2025 CA Plumbing Code With Local Amendments; (5) Chapter 16.14 Incorporating the 2025 CA Green Building Standards Code with Local Amendments; (6) Chapter 16.16 Incorporating the 2022 CA Electrical Code With Local Amendments; (7) Chapter 16.18 Incorporating the 2024 International Swimming Pool and Spa Code With Local Amendments; (8) Chapter 16.17 Incorporating the 2025 CA Energy Code With Local Amendments; Direction to 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 with Local Amendments; Approve a Budget Amendment in the General Fund . CEQA Status: Exempt Under CEQA Guidelines Sections 15061(b)(3) and 15308.
RECOMMENDATION
Staff recommends that 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.
EXECUTIVE SUMMARY
Every three years, California updates its Building Standards Code, Title 24, to incorporate the latest technology, best practices, and policy goals for safe, efficient, and sustainable buildings.
Jurisdictions may adopt the model code as-is or adopt local amendments that are more stringent than the model code. If new local amendments are not adopted and/or prior local amendments readopted before the new code cycle begins, the jurisdiction may only enforce the model code.
This staff report provides an overview of proposed new and renewed local amendments to the California Building Standards Code for the 2026-2028 cycle, which begins January 1, 2026. All local amendments for the upcoming 2026-2028 code cycle are discussed herein, except for:
Select new local amendments to the California Energy Code that were considered and adopted by Council as part of an emergency ordinance on September 8, 2025, in response to recent changes in state law;
The California Energy Code amendments for which the statewide working group has not yet completed the required cost-effectiveness studies (these are expected to be considered by Council in the first half of 2026); and
Local amendments to the California Fire Code and Wildlands Urban Interface Code, which staff recommends Council consider on consent by the end of 2025.
The majority of local amendments included in the attached ordinances are substantially similar to or the same as local amendments Palo Alto has adopted in the past. However, the attached ordinances do include new local amendments to the California Building Code, California Plumbing Code, California Energy Code (new amendments adopted 9/8), and CALGreen.
BACKGROUND
Every three years, California updates its Building Standards Code, Title 24, to incorporate the latest technology, best practices, and policy goals for safe, efficient, and sustainable buildings.
Jurisdictions may adopt the model code as-is or, if reasonably necessary based on local conditions, may adopt local amendments that are more stringent than the model code adopted by the State.
If no local amendments are adopted before the beginning of the new code cycle, in this case January 1, 2026, then the model code adopted by the state automatically applies. If prior local amendments are not readopted before the new code cycle begins, they expire and can no longer be applied or enforced at the local level.
The California Building Standards Code is organized into 13 parts, as shown below. Note that there are both Parts 2 and 2.5, creating a total 13 parts. Part 7 is a new addition to the code this cycle.
Part 1: CA Administrative Code
Part 2: CA Building Code
Part 2.5: CA Residential Code
Part 3: CA Electrical Code
Part 4: CA Mechanical Code
Part 5: CA Plumbing Code
Part 6: CA Energy Code
Part 7: CA Wildlands-Urban Interface Code
Part 8: CA State Historical Building Code
Part 9: CA Fire Code
Part 10: CA Existing Building Code
Part 11: CA Green Building Standards Code
Part 12: CA Reference Code Standards
State law imposes certain requirements when jurisdictions adopt local amendments to any of these 13 parts, including that the jurisdiction make express findings that each amendment is reasonably necessary because of local climatic, geological, topographic or environmental conditions. Additionally, a new state law, Assembly Bill (AB) 130 (2025) limits jurisdictions’ authority to adopt new local amendments that affect residential units until 2031. To the extent that the local amendments proposed are not substantially equivalent to those currently in effect, they do not affect residential units and are therefore exempt from the AB 130 moratorium.
ANALYSIS
Staff is proposing new local amendments this cycle to the California Building Code, California Plumbing Code, California Energy Code (approved 9/8), and CALGreen. Staff proposes the City adopt no local amendments to the California Administrative Code or California Reference Code Standards this cycle, consistent with past practices. Staff proposes the City readopt prior local amendments, with some minor edits to account for updates in the base codes, to all other codes addressed in the attached ordinances.
The below ordinances are recommended for adoption and described below; the letters correspond to the attachment list:
A.Ordinance repealing PAMC Chapter 16.04 and 16.19 and adopting a new Chapter
16.04 and 16.19, incorporating California Building Code, California State Historical Building Code, California Existing Building Code (2025 Editions), and local amendments and related findings - This ordinance re-adopts previously adopted local amendments and adopts a new local amendment that defines triggers for automatic sprinkler systems and more intense fire sprinkler design for different types of new and existing nonresidential buildings. It also removes prior 2022 local amendments related to Wildland-Urban Interface that will now be addressed in the Wildland-Urban Interface Code (2025 Edition) as Part 7 of Title 24.
B.Ordinance repealing PAMC Chapter 16.06 and adopting a new Chapter 16.06, incorporating the California Residential Code (2025 Edition), and local amendments and related findings - This ordinance re-adopts previously adopted local amendments and removes prior 2022 local amendments related to Wildland-Urban Interface that will now be addressed in the new Wildland-Urban Interface Code (2025 Edition) as Part 7 of Title 24 .
C.Ordinance repealing PAMC Chapter 16.16 and adopting a new Chapter 16.16, incorporating the California Electrical Code (2025 Edition), and local amendments and related findings - This ordinance re-adopts previously adopted local amendments. It does not adopt any new local amendments.
D.Ordinance repealing PAMC Chapter 16.05 and adopting a new Chapter 16.05, incorporating the California Mechanical Code (2025 Edition), and local amendments and related findings - This ordinance re-adopts previously adopted local amendments. It does not adopt any new local amendments.
E.Ordinance repealing PAMC Chapter 16.08 and adopting a new Chapter 16.08, incorporating the California Plumbing Code (2025 Edition), and local amendments and related findings – This ordinance re-adopts previously adopted local amendments and adopts new local amendments related to grease interceptors in food facilities. These changes implement the City‘s updated requirements for the management of fats, oils, and grease as outlined in PAMC Chapter 16.13 associated regulations (first reading passed unanimously September 15, 2025; second reading tentatively scheduled for September 29, 2025).
F.Ordinance amending PAMC Chapter 16.17, incorporating the California Energy Code (2025 Edition), and renewed local amendments and related findings – This ordinance supplements the ordinance passed on September 8, 2025, adopting the 2025 edition of the California Energy Code with local amendments to adopt FlexPath and Air Conditioner Time-of-Replacement requirements. It removes prior local amendments that have been incorporated into the 2025 State code and readopts all other prior local amendments for which required cost-effectiveness studies are currently available. One notable exception is that the local amendments to the source energy compliance margins that were adopted as part of the "One Margin" effort in 2024 will not be readopted at this time and will revert to the state code requirement levels. The reason for this is that the necessary cost-effectiveness studies have not yet been completed by the Statewide Reach Codes Program working group. The studies are currently anticipated for completion in late 2025 or early 2026. Once the studies are available Staff will develop new source energy compliance margin local amendments for adoption, likely in spring 2026. This delay and subsequent lapse in local source energy margin reach codes has happened in past code cycles due to the complex process for developing the cost-effectiveness studies and the necessary tools to complete those studies. Other jurisdictions with similar source energy margin reach codes will also be unable to re-adopt them until the necessary studies are complete.
G.Ordinance repealing PAMC Chapter 16.18 and adopting a new Chapter 16.18, incorporating the International Swimming Pool and Spa Code (2024 Edition), with local amendments – To regulate private residential pools and spas, Palo Alto adopts and modifies the International Swimming Pool and Spa Code (ISPSC). This ordinance adopts the 2024 edition of the ISPSC and re-adopts previously adopted local amendments. It does not adopt any new local amendments. An ordinance adopting and amending the ISPSC does not amend the California Building Standards Code and is not required to be filed with the California Building Standards Commission or justified by local findings.
H.Ordinance repealing PAMC Chapter 16.14 and adopting a new Chapter 16.14, California Green Building Standards Code (2025 Edition), and local amendments and related findings – This ordinance re-adopts previously adopted local amendments and removes those that have been incorporated into the updated 2025 State Code. It also adopts the following new local amendments:
1. Leadership in Energy and Environmental Design (LEED) Certification Compliance Pathway
LEED certification is a worldwide rating system developed by the U.S. Green Building Council (USGBC) to evaluate the environmental performance of buildings. It is awarded based on a point system, with projects earning points for meeting specific sustainability criteria. The certification levels are: Certified, Silver, Gold, and Platinum. This amendment would allow nonresidential buildings to utilize LEED certification as an alternative compliance pathway to the currently enforced CALGreen Tier 1 and Tier 2 requirements. Projects that meet the Tier 1 criteria could opt to achieve LEED silver certification instead of complying with the Tier 1 requirements. Projects that meet the Tier 2 criteria could opt to achieve LEED gold certification instead of complying with the Tier 2 requirements.
To help determine what the appropriate LEED certification level would be, staff worked with a consultant, ID360, to analyze recently permitted Tier 1 and Tier 2 nonresidential projects in Palo Alto to evaluate their respective compliance levels.
That analysis is summarized in Attachment I in a memo that also includes additional context on CALGreen Tier versus LEED certification requirements and how other jurisdictions have implemented LEED certification requirements in their local code amendments.
One of the key considerations for this amendment was to ensure that a project choosing a LEED certification compliance option would not allow them to avoid specific CALGreen prerequisites requirements that are important to Palo Alto’s sustainability objectives. For that reason, staff included an additional requirement that projects opting for LEED certification ensure that they also meet the enhanced construction waste reduction and electric vehicle charging infrastructure requirements from the CALGreen Tier prerequisites. A summary of the prerequisite differences between the two compliance pathways is included in Table 1 below.
Table 1. 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
2. Embodied Carbon
The State code has embodied carbon requirements for nonresidential new construction, additions, and alterations. These requirements focus on carbon emissions reduction through either reuse of at least 45% of building structure, whole building lifecycle assessment (WBLCA) demonstrating 10% lower embodied carbon emission than a baseline project design, or documentation environmental product 1 This table shows select key LEED prerequisites met by using LEED as an alternative compliance path. declarations (EPDs) for listed materials (steel, glass, mineral wool, concrete) that are on average lower than a specified threshold of global warming potential. In the 2022 State code, these requirements were limited to projects over 100,000 square feet, and in 2025 the State code is lowering that threshold to 50,000 square feet. This amendment would lower the threshold for the State embodied carbon requirements to projects 25,000 square feet and above. Previously, very few projects had qualified to comply with the 100,000 square foot threshold, and staff anticipates that even the State’s reduced 50,000 square foot threshold would only impact a small number of Palo Alto projects. Based on a review of recent Palo Alto project data, it is expected that the threshold reduction to 25,000 square feet would cover around five additional projects annually on top of the five projects that would meet the 50,000 square foot state code threshold. Because there are three available compliance pathways as described above, it is not expected that projects on buildings in the 25,000-50,000 square foot range would have difficultly complying with these embodied carbon requirements. This proposal was presented to nonresidential building professionals at a public outreach meeting and did not receive any feedback.
3.Adopting CALGreen Tier 2 EV Charging Infrastructure Requirements for Nonresidential New Construction
The existing Palo Alto Municipal Code (PAMC) EV charging infrastructure requirements for nonresidential new construction mandate 20 percent EV capable or EV ready spaces and 20 percent EV charger installed spaces for buildings with 10-20 parking spaces.
Those percentage requirements both drop to 15 percent for buildings with over 20 parking spaces. This proposal would replace the existing local code with the CALGreen Tier 2 requirements that include both EV capable spaces and actual charging stations, 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). By adopting the CALGreen methodology, this amendment will help designers streamline the design process by eliminating the need to navigate two separate methodologies—the base building code requirements and the current PAMC requirements—thereby simplifying compliance while achieving enhanced EV infrastructure outcomes that support the City's sustainability and transportation decarbonization goals.
To illustrate the requirements, staff analyzed different project scenarios with varying number of parking spaces. For example, a nonresidential project with 51 total parking spaces was considered. Under current City requirements, this project would provide 8 EV Capable or EV Ready spaces and 8 EVSE installed spaces (15% each of the 51 total parking spaces, totaling 30% of all spaces). Under the proposed CALGreen Tier 2 requirements, the same project would provide: 28 EV capable spaces plus 14 actual Electric Vehicle Charging Stations (EVCS) for non-office/retail buildings, or 21 EVCS for office and retail buildings. The Tier 2 requirements results in 55% of the total parking spaces having EV infrastructure installed (a combination of EV Capable and EV Charging Stations).
Fire and Wildlands Urban Interface Codes
Staff recommends that Council consider proposed local amendments to the California Fire Code and Wildlands Urban Interface (WUI) Codes on consent before the end of 2025. Staff anticipate the below summarized amendments at this time. Most of these amendments serve to clarify prior local amendments or implement amendments recommended by the Santa Clara County Fire Marshals’ working group.
Anticipated Fire Code and WUI Amendments
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
Possible exemptions in the WUI areas to protect habitat for threatened or endangered species
FISCAL/RESOURCE IMPACT
Consultant funding of $116,000 to complete the triennial code updates were included in the FY 2026 budgets – this funding was sufficient for the outlined scope of work that included a streamlined and lightweight process for a fall and spring cycle of code updates. However, due to timing needs, this funding was used for the emergency ordinance in September and follow- up work to conclude the Green Building Ordinance and the Energy Reach Code Ordinance through this report and discussion. These efforts have involved multiple revisions, meetings with Council committees, meetings with stakeholders, and internal coordination. Through this Council discussion, approximately $77,500 of the allocated $116,000 will have been spent on this effort.
The balance of funding (approximately $38,500) is available for the necessary spring cycle of Energy Reach Code review. Staff recommends an additional allocation of $96,000 to augment this funding and ensure there are sufficient resources for a comprehensive round of Energy Reach Code review in Spring 2026. This funding will allow staff and the consultant to work through simultaneous development of local municipal code amendments for new single-family, new multi-family, and new non-residential construction. This would be streamlined through a unified stakeholder engagement and community outreach strategy. This would include a single coordinated City Council process to adopt the corresponding ordinances.
The total for the Spring update would be approximately $134,500, and more accurately reflects the costs of the work to provide policy support in this critical area that requires multiple public discussions. Should the City Council choose to increase the number of cycles of code review, additional resources may be required.
STAKEHOLDER ENGAGEMENT
Staff hosted two community engagement meetings as part of the Building Standards Code update process for the 2026-2028 Cycle. The first was a focus group with 10 local design professionals held on August 12, 2025, that covered all Title 24 updates. The second was a hybrid community meeting held on August 13, 2025, with four virtual and nine in-person attendees (excluding staff and consultants) that focused on reach codes. The September 5, 2025, Climate Action and Sustainability Committee and September 8, 2026, City Council staff reports on these topics for a detailed summary of these outreach events.
Both engagement opportunities were listed on the City website. The community meeting was advertised in the July 31, 2025, Uplift Local newsletter and included as events on the City calendar, NextDoor, and Facebook. Staff also sent targeted email notice to approximately 100 environmental advocates, design professionals, and community members to increase awareness for these events and promote attendance.
ENVIRONMENTAL REVIEW
The recommended action in this report is exempt from the California Environmental Quality Act (CEQA) in accordance with CEQA Guidelines section 15308 as an action by the City for the protection of the environment, and under section 15061(b)(3) on the grounds that the proposed standards are more stringent than the State standards, there are no reasonably foreseeable adverse environmental impacts and there is no possibility that the activity in question may have a significant adverse effect on the environment.
ATTACHMENTS
Attachment A: Ordinance repealing PAMC Chapter 16.04 and 16.19 and adopting a new Chapter 16.04 and 16.19, incorporating California Building Code, California State Historical Building Code, California Existing Building Code (2025 Editions), and local amendments and related findings
Attachment B: Ordinance repealing PAMC Chapter 16.06 and adopting a new Chapter 16.06, incorporating California Residential Code (2025 Edition), and local amendments and related findings
Attachment C: Ordinance repealing PAMC Chapter 16.16 and adopting a new Chapter 16.16, incorporating California Electrical Code (2025 Edition), and local amendments and related findings
Attachment D: Ordinance repealing PAMC Chapter 16.05 and adopting a new Chapter 16.05, incorporating California Mechanical Code (2025 Edition), and local amendments and related findings
Attachment E: Ordinance repealing PAMC Chapter 16.08 and adopting a new Chapter 16.08, incorporating California Plumbing Code (2025 Edition), and local amendments and related findings
Attachment F: Ordinance amending PAMC Chapter 16.17 , incorporating California Energy Code (2025 Edition), and renewed local amendments and related findings Attachment G: Ordinance repealing PAMC Chapter 16.18 and adopting a new Chapter 16.18, incorporating Private Swimming Pool and Spa Code (2024 Edition), and local amendments and related findings
Attachment H: Ordinance repealing PAMC Chapter 16.14 and adopting a new Chapter 16.14, incorporating California Green Building Standards Code (2025 Edition), and local amendments and related findings
Attachment I: Evaluation of CALGreen vs. LEED for Palo Alto Nonresidential Projects APPROVED BY:
Jonathan Lait, Planning and Development Services Director