HomeMy WebLinkAboutOrdinance 56651
0290179_20250826_ms29
Ordinance No. ϱϲϲϱ
Emergency Ordinance of the Council of the City of Palo Alto Amending Chapter
16.17 (California Energy Code, California Code of Regulations, Title 24, Part 6) of
the Palo Alto Municipal Code to Adopt the 2025 California Energy Code, Along
With Local Amendments Thereto, to Add FlexPath and Air Conditioner Time-of-
Replacement Requirements.
The Council of the City of Palo Alto does ORDAIN as follows:
SECTION 1. Findings and Declarations.
A. The City of Palo Alto adopted a Sustainability and Climate Action Plan, or S/CAP, to meet
the City's stated goal of "80 x 30": reducing greenhouse gas emissions 80% below 1990
levels by 2030.
B. The S/CAP outlines goals and key actions in eight areas, one of which is energy and more
specifically, energy efficiency and electrification. The goals for the energy area of the
S/CAP are to reduce GHG emissions from the direct use of natural gas in Palo Alto’s
building sector by at least 60% below 1990 levels (116,400 MT CO2e reduction) and to
modernize the electric grid to support increased electric demand to accommodate state-
of-the-art technology.
C. One key action the City is taking to accomplish those goals is to use codes and ordinances
- such as the energy reach code, green building ordinance, zoning code, or other
mandates - to facilitate electrification in both existing buildings and new construction
projects where feasible.
D. The purpose of this ordinance is to formally adopt California Code of Regulations, Title 24,
Part 6, 2025 California Energy Code, with local amendments in furtherance of the City of
Palo Alto’s S/CAP goals and other sustainability-related goals included in the City’s 2030
Comprehensive Plan. The amendments adopted herein are more restrictive than the
building standards in Title 24, Part 6.
E. Recent legislation, Assembly Bill (AB) 130 (2025), limits local jurisdictions’ authority to
amend the California Building Standards Code beginning October 1, 2025, and ending
June 1, 2031. The Council desires to adopt these amendments before the AB 130
moratorium begins. The Council may in the future adopt additional amendments to the
2025 California Energy Code that are not subject to, or are exempt from, the AB 130
moratorium.
2
0290179_20250826_ms29
F. The Council declares that this emergency ordinance is necessary as an emergency
measure to preserve the public peace, health, or safety by ensuring that the City may
enforce its local amendments to the California Energy Code during the AB 130
moratorium. These local amendments are necessary to mitigate the public health and
safety impacts of GHG emissions from natural gas usage by incentivizing energy efficiency
and electrification.
G. Additionally, the Council finds that these changes or modifications to the California
Energy Code are necessary to implement a local code amendment that is adopted to align
with a general plan approved on or before June 10, 2025, and that permits mixed-fuel
residential construction consistent with federal law while also incentivizing all-electric
construction as part of an adopted greenhouse gas emissions reduction strategy. The City
of Palo Alto’s Comprehensive Plan was adopted on November 13, 2017, and amended on
December 19, 2022. The relevant policies and goals in the Comprehensive Plan include,
but are not limited to: Goal N-7 (“A clean, efficient energy supply that makes use of cost-
effective renewable resources”) and Goal N-8 (“Actively support regional efforts to
reduce our contribution to climate change while adapting to the effects of climate change
on land uses and city services”) contained in the Natural Environment Element and
associated policies and programs. These include Policy N-7.4 (“Maximize the conservation
and efficient use of energy in new and existing residences and other buildings in Palo
Alto”), Program N-7.4.1 (“Continue timely incorporation of State and federal energy
efficiency standards and policies in relevant City codes, regulations and procedures and
higher local efficiency standards that are cost-effective”), Policy N-7.7: (“Explore a variety
of cost-effective ways to reduce natural gas usage in existing and new buildings in Palo
Alto in order to reduce associated greenhouse gas emissions”), and especially Policy N-
8.2 (“With guidance from the City’s Sustainability and Climate Action Plan (S/CAP) and its
subsequent updates and other future planning efforts, reduce greenhouse gas emissions
from City operations and from the community”).
H. California Health and Safety Code sections 17958.5 and 17958.7 require that the City, in
order to make changes or modifications in the requirements contained in the California
Building Standards Code on the basis of local conditions, make express finding that such
modifications or changes are reasonably necessary because of local climatic, geological
or topographical conditions. The required findings are attached to this ordinance as
Exhibit A.
SECTION 2. Chapter 16.17 (California Energy Code, California Code of Regulations,
Title 24, Part 6) of the Palo Alto Municipal Code is hereby amended by repealing in its
entirety existing Chapter 16.17 and adopting a new Chapter 16.17 to read as follows:
3
0290179_20250826_ms29
CHAPTER 16.17
CALIFORNIA ENERGY CODE,
CALIFORNIA CODE OF REGULATIONS, TITLE 24, PART 6
Sections
16.17.010 2025 California Energy Code, Title 24, Part 6 adopted.
16.17.020 Cross - References to California Energy Code
16.17.030 Local Amendments
16.17.040 Administration & Enforcement of 2025 California Energy Code
16.17.050 Violations – Penalties
16.17.060 Subchapter 1 All Occupancies – General Provisions
16.17.070 Reserved
16.17.080 Reserved
16.17.090 Reserved
16.17.100 Reserved
16.17.110 Reserved
16.17.120 Subchapter 7 Single-family Residential Building – Mandatory Features
and Devices
16.17.130 Reserved
16.17.140 Subchapter 9 Single-Family Residential Buildings—Additions And
Alterations To Existing Residential Buildings
16.17.150 Reserved
16.17.160 Reserved
16.17.170 Infeasibility Exemption
16.17.180 Appeal
16.17.010 2025 California Energy Code, Title 24, Part 6 adopted.
The California Energy Code, 2025 Edition, Title 24, Part 6 of the California Code of
Regulations together with those omissions, amendments, exceptions and additions
thereto, is adopted and hereby incorporated in this Chapter by reference and made a part
hereof the same as if fully set forth herein. Except as amended herein, all requirements of
the California Energy Code, 2025 Edition, Title 24, Part 6 of the California Code of
Regulations shall apply.
4
0290179_20250826_ms29
Unless superseded and expressly repealed, references in City of Palo Alto forms, documents and
regulations to the chapters and sections of the former editions of the California Code of Regulations,
Title 24, shall be construed to apply to the corresponding provisions contained within the California
Code of Regulations, Title 24, 2025. Ordinance No. 5627 of the City of Palo Alto and all other
ordinances or parts of ordinances in conflict herewith are hereby suspended and expressly repealed.
One copy of the California Energy Code, 2025 Edition, has been filed for use and examination of the
public in the Office of the Chief Building Official of the City of Palo Alto.
16.17.020 Cross - References to California Energy Code
The provisions of this Chapter contain cross-references to the provisions of the California Energy
Code, 2025 Edition, in order to facilitate reference and comparison to those provisions.
16.17.030 Local Amendments
The provisions of this Chapter shall constitute local amendments to the cross-referenced
provisions of the California Energy Code, 2025 Edition, and shall be deemed to replace the cross-
referenced sections of said Code with the respective provisions set forth in this Chapter.
16.17.040 Administration & Enforcement of 2025 California Energy Code
Administration and enforcement of this code shall be governed by Chapter 1, Division II of the
2025 California Building Code as amended by Palo Alto Municipal Code Chapter 16.04.
16.17.050 Violations - Penalties
It is unlawful for any person to violate any provision or to fail to comply with any of the
requirements of this Chapter or any permits, conditions, or variances granted under this Chapter.
Violators shall be subject to any penalty or penalties authorized by law, including but not limited
to: administrative enforcement pursuant to Chapters 1.12 and 1.16 of the Palo Alto Municipal
Code; and criminal enforcement pursuant to Chapter 1.08 of the Palo Alto Municipal Code. Each
separate day or any portion thereof during which any violation of this Chapter occurs or
continues shall be deemed to constitute a separate offense.
When the chief building official determines that a violation of this Chapter has occurred, the chief
building official may record a notice of pendency of code violation with the Office of the County
Recorder stating the address and owner of the property involved. When the violation has been
corrected, the chief building official shall issue and record a release of the notice of pendency of
code violation.
16.17.060 Subchapter 1 All Occupancies – General Provisions
Section 100.0 – SCOPE is amended to add new subsections (i) and (j) as follows:
(i) Single Family Building Remodel Energy Reach Code - Purpose and Intent.
In addition to all requirements of the California Energy Code applicable to Single Family
building additions and alterations, the energy efficiency, renewable energy, and electric
readiness measures specified in Sections 150.0(w) and 150.0(x) shall be required for
5
0290179_20250826_ms29
certain single-family additions and alterations.
(j)SUBSTANTIAL REMODEL (or “50-50-50” RULE) Any project that affects the
removal or replacement of 50% or more linear length of the existing exterior walls of
the building, 50% or more linear length of the existing exterior wall where the plate
height is raised, or 50% or more of the existing roof framing area is removed or
replaced, over a 3-year period is considered a substantial remodel.
a. Any permit(s) applied for will trigger a review of a 3-year history of
the project. This review will result in determining if a substantial
remodel has occurred.
b. The Chief Building Official or designee shall make the final determination
regarding the application if a conflict occurs.
Section 100.1(b) of Subchapter 1 of the California Energy Code is amended by adding the
following definitions:
COVERED SINGLE FAMILY PROJECT shall mean any project in a Single-Family residential
building originally permitted for construction before 2011 that meets any of the
following criteria:
1. All residential building additions and/or alterations exceeding 1000 square feet,
as amended by this Chapter and as applicable to the scope of work.
For Covered Single Family Projects, the area of alterations will include any
construction or renovation to an existing structure other than repair or addition.
Alterations include raising the plate height, historic restoration, changes or
rearrangements of the structural parts or elements, and changes or
rearrangement of bearing walls and full height partitions.
Normal maintenance, reroofing, painting or wall papering, floor finishes,
replacement-in-kind of mechanical, plumbing and electrical systems, or replacing
or adding new kitchen counter and similar furniture, plumbing fixture to the
building are excluded for the purposes of establishing scope of Covered Single-
Family Projects.
The area of alteration should be limited to the footprint of element(s) being
altered.
The sum of the footprint of the elements being altered with respect to
Covered Single Family Projects, shall be calculated using the following
methodology:
1. Raising the plate height: The calculation with respect to raising
of the plate height will be based on the area of the footprint in
which the plate height is being increased. Plate height means
the vertical distance measured from the top of the finished
floor to the top of the plates.
2. Historic restoration: The calculation with respect to historic
6
0290179_20250826_ms29
restoration will be based on the area of work covered in the
California Historical Building Code (Title 24, Part 8).
3. Structural parts or elements: The calculation with respect to
changes or rearrangements of the structural parts or elements
will be based on the sum of the individual footprints of each
structural change or rearrangement. The footprint shall be
calculated based on the proposed design and inclusive of any
demolished structural parts or elements.
4. Bearing walls and full height partition: The calculation with
respect to changes or rearrangement of walls and full height
partitions will be based on the footprint of any demolished wall
or full height partition and any new wall or new full height
partition.
Exception: Attached and detached Accessory Dwelling Units, ADU
conversions of existing structures shall meet the California Energy
Code Mandatory measures only.
CERTIFIED ENERGY ANALYST is a person registered as a Certified Energy Analyst with the
California Association of Building Energy Consultants as of the date of submission of a
Certificate of Compliance as required under section 10-103 of Building Energy Efficiency
Standards for residential and nonresidential buildings.
ELECTRIC EQUIPMENT OR APPLIANCE means one or more devices that use
electric energy to serve the needs for heating and cooling, water heating, cooking,
and electric vehicle charging. In addition, ancillary equipment such as an electric
panel, photovoltaic equipment, and energy storage systems that are deployed to
support such devices shall be considered Electric Equipment or Appliance.
ELECTRIC HEATING APPLIANCE is a device that produces heat energy to create a
warm environment by the application of electric power to resistance elements,
refrigerant compressors, or dissimilar material junctions, as defined in the
California Mechanical Code.
SUBSTANTIAL REMODEL (or “50-50-50” RULE) Any project that affects the removal
or replacement of 50% or more linear length of the existing exterior walls of the
building, 50% or more linear length of the existing exterior wall where the plate
height is raised, or 50% or more of the existing roof framing area is removed or
replaced, over a 3-year period is considered a substantial remodel. (Refer to Section
100.0 (j).
16.17.070 Reserved
16.17.080 Reserved
7
0290179_20250826_ms29
16.17.090 Reserved
16.17.100 Reserved
16.17.110 Reserved
16.17.120 SUBCHAPTER 7 SINGLE-FAMILY RESIDENTIAL BUILDING –
MANDATORY FEATURES AND DEVICES
Section 150.0 MANDATORY FEATURES AND DEVICES
Section 150.0 of Subchapter 7 of the California Energy Code is amended to read as follows
(additions underlined, deletions struck through):
Single-family residential buildings shall comply with the applicable requirements
of Sections 150(a) through 150.0(x).
NOTE: The requirements of Sections 150.0 (a) through (v) apply to newly
constructed buildings. Sections 150.2(a) and 150.2(b) specify which requirements
of Sections 150.0(a) through 150.0(v) also apply to additions or alterations. The
electric readiness requirements of Sections 150.0 (n), (t), (u) and (v) apply to
residential remodels or additions when the applicable system is included in the
remodel. In addition, Covered Single Family Projects shall also be required to
comply with Section 150.0(w) and certain additions and alterations shall also be
required to comply with Section 150.0(x).
Subsections 150.0 (a) – (s) are adopted without modification.
(t) Heat pump space heater ready. Systems using gas or propane
furnace to serve individual dwelling units shall include the
following:
1. A dedicated 240 volt branch circuit wiring shall be installed within 3
feet from the furnace and accessible to the furnace with no
obstructions. The branch circuit conductors shall be rated at 30 amps
minimum. The blank cover shall be identified as “240V ready.” All
electrical components shall be installed in accordance with the California
Electrical Code.
2. The main electrical service panel shall have a reserved space to
allow for the installation of a double pole circuit breaker for a
future heat pump space heater installation. The reserved space
shall be permanently marked as “For Future 240V use.”
3. A designated exterior location for a future heat pump compressor
unit.
8
0290179_20250826_ms29
Subsections 150.0 (u) – (v) are adopted without modification.
A new Subsection, (w), is added to Section 150.0 as follows:
(w) A Covered Single-Family Project shall install a set of measures based on
the building vintage from the Measure Menu Table, Table 150.0-J, to
achieve a total Measure Point Score that is equal to or greater than the
Target Score in Table 150.0-I. In addition, all mandatory measures listed
in Table 150.0-J shall be installed. Measure verification shall be
explicitly included as an addendum to the Certificate of Compliance to
be filed pursuant to 2025 Title 24, Part 6, Section 10-103.
Installed measures shall meet the specifications in Table 150.0-K.
Building vintage is the year in which the original construction permit for
the building was submitted, as documented by building department
records, or the permit issue date of an addition or alteration that
satisfied the Performance Standards (California Energy Code, Title 24,
Part 6, Section 150.1(b)) that were in effect at that time. Unless
otherwise specified, the requirements shall apply to the entire dwelling
unit, not just the additional or altered portion. Measures from the
Measure Menu table that are to be installed to satisfy requirements
under the California Energy Code, Title 24, Part 6, may not count
towards compliance with these requirements. Where these
requirements conflict with other California Energy Code requirements,
the stricter requirements shall prevail.
Exception 1 to Section 150.0(w): Creation of a new accessory dwelling
unit or junior accessory dwelling unit that is within the existing space of
a single family dwelling or accessory structure and include an expansion
of not more than 150 square feet beyond the same physical dimensions
as the existing accessory structure. An expansion beyond the physical
dimensions of the existing accessory structure shall be limited to
accommodating ingress and egress. Or, if the project would not
otherwise be a Covered Single Family Project were it not for the inclusion
of an accessory dwelling unit or junior accessory dwelling unit that meets
the criteria above.
Exception 2 to Section 150.0(w): Mobile Homes, Manufactured Housing,
or Factory-built Housing as defined in Division 13 of the California Health
and Safety 12 Code (commencing with Section 17000 of the Health and
Safety Code).
Exception 3 to Section 150.0(w): Emergency Housing pursuant to
Appendix P of the California Building Code.
9
0290179_20250826_ms29
Exception 4 to Section 150.0(w): An alteration that consists solely of roof
and/or fenestration projects.
Exception 5 to Section 150.0(w): If the project includes circumstances
which constitute hardship or infeasibility, the applicant may request an
exemption. In applying for an exemption, the burden is on the applicant
to show hardship or infeasibility. Circumstances that constitute hardship
or infeasibility shall include one or more of the following:
(a) That the cost of achieving compliance exceeds 20% of the
valuation of cost of the project;
(b) That it is technically infeasible to achieve compliance through all
packages due to conditions specific to the project;
(c) That strict compliance with these standards would create or
maintain a hazardous condition(s) and present a life safety risk to
the occupants.
Applicants shall follow the Infeasibility procedures in PAMC
16.17.170.
Exception 6 to Section 150.0(w): If the applicant demonstrates, using
Commission-certified compliance software as specified by Section 10-
109(c) and Section 10-116, that the Energy Budget of the Proposed
Building Design would be less than or equal to the Energy Budget of the
building under the project if it included any set of measures that would
achieve compliance under this Section 150.0(w).
Certificate of Compliance. The Certificate of Compliance shall be
prepared and signed by a Certified Energy Analyst and the energy
budget for the Proposed Design shall be no greater than the
Standard Design Building.
Exception 7 to Section 150.0(w): If the dwelling unit has previously
installed measures from the Measure Menu, Table 150.0-J, and
compliance can be demonstrated to the building official, then these
measures shall not be required to be newly installed, and appropriate
credit shall be included in the applicable compliance calculations.
Exception 8 to Section 150.0(w): A measure that is necessary for
compliance is prohibited because of a covenant or other deed restriction
on the property, such as a homeowners association covenant.
Exception 9 to Section 150.0(w): A Covered Single-Family Project, other
than an addition, that would not otherwise be subject to this section
150.0(w) but for installation of solar PV, solar water heating, EV charging,
electrical upgrades for solar PV or EV charging, or energy storage.
10
0290179_20250826_ms29
Exception 10 to Section 150.0(w): The project is solely related to a repair,
as defined by Title 24 Part 2 Section 202.
Exception 11 to Section 150.0(w) and 150.0(x): A Covered Single Family
Project that consists solely of medically necessary improvements or solely
of seismic safety improvements.
TABLE 150.0-I: TARGET SCORES
Building Vintage Pre-1978 1978-1991 1992-2010
Climate Zone 4 12 12 12
TABLE 150.0-J: MEASURE MENU, CLIMATE ZONE 4
ID Measures Building Vintage
Pre-
1978
1978-
1991
1992-
2010
E1 Lighting Measures Mandatory
E2 Water Heating Package 1 1 1
E3 Air Sealing 2 1 1
E4.A R-38 Attic Insulation 7 3 1
E4.B R-49 Attic Insulation 7 3 1
E5 Duct Sealing 6 4 1
E6.A New Ducts, R-6 Insulation + Duct Sealing 10 7 2
E6.B New Ducts, R-8 Insulation + Duct Sealing 11 8 3
E7 Windows 6 5 3
E8 R-15 Wall Insulation 6 -- --
E10.A R-19 Raised floor insulation 8 8 --
E10.B R-30 Raised floor insulation 9 9 --
E11 Radiant Barrier Under Roof (when re-roofing) 3 2 1
FS1 Heat Pump Water Heater Replacing Gas 12 12 12
FS2 High Eff. Heat Pump Water Heater Replacing Gas 13 13 13
FS3 Heat Pump Water Heater Replacing Electric 4 4 4
FS4 High Eff. Heat Pump Water Heater Replacing Electric 5 5 5
11
0290179_20250826_ms29
TABLE 150.0-K: MEASURE SPECIFICATIONS
ID Measure Specification
Energy Efficiency Measures
E1 Lighting Measures – Install lighting with an efficiency of 45 lumens per watt or greater in all interior and
exterior screw-in fixtures. Install photocell, occupancy sensor or energy management system controls
that meet the requirements of 150.0(k)3 in all outdoor lighting permanently mounted to a residential
building or to other buildings on the same lot.
E2 Water Heating Package: Insulate all accessible hot water pipes with pipe insulation a minimum of ¾
inch thick. This includes insulating the supply pipe leaving the water heater, piping to faucets
underneath sinks, and accessible pipes in attic spaces or crawlspaces. Upgrade fittings in sinks and
showers to meet current California Green Building Standards Code (Title 24, Part 11) Section 4.303
water efficiency requirements.
Exception: Upgraded fixtures are not required if existing fixtures have rated or measured flow rates of
no more than ten percent greater than 2025 California Green Building Standards Code (Title 24, Part
11) Section 4.303 water efficiency requirements.
E3 Air Sealing: Seal all accessible cracks, holes, and gaps in the building envelope at walls, floors, and
ceilings. Pay special attention to penetrations including plumbing, electrical, and mechanical vents,
recessed can light luminaires, and windows. Weather-strip doors if not already present. Verification
shall be conducted following a prescriptive checklist that outlines which building aspects need to be
addressed by the permit applicant and verified by an inspector. Compliance can also be demonstrated
with blower door testing conducted by a certified ECC Rater no more than three years prior to the
permit application date that either: a) shows at least a 30 percent reduction from pre-retrofit
conditions; or b) shows that the number of air changes per hour at 50 Pascals pressure difference
(ACH50) does not exceed ten for Pre-1978 vintage buildings, seven for 1978 to 1991 vintage buildings
and five for 1992-2010 vintage buildings. If combustion appliances are located within the pressure
boundary of the building, conduct a combustion safety test by a certified ECC Rater or a professional
certified by the Building Performance Institute, in accordance with the BPI Technical Standards for the
Building Analyst Professional.
E4.A R-38 Attic Insulation: Attic insulation shall be installed to achieve a weighted assembly U-factor of 0.025
or insulation installed at the ceiling level shall have a thermal resistance of R-38 or greater for the
insulation alone. Recessed downlight luminaires in the ceiling shall be covered with insulation to the
same depth as the rest of the ceiling. Luminaires not rated for insulation contact must be replaced or
fitted with a fire-proof cover that allows for insulation to be installed directly over the cover.
FS5 Heat Pump Space Conditioning System 21 16 13
FS6 High Eff. Heat Pump Space Conditioning System 23 18 15
FS7 Dual Fuel Heat Pump Space Conditioning System 15 11 10
FS8 Heat Pump Clothes Dryer 1 1 1
FS9 Induction Cooktop 1 1 1
PV Solar PV 17 17 15
12
0290179_20250826_ms29
Exception: In buildings where existing R-30 is present and existing recessed downlight luminaires are
not rated for insulation contact, insulation is not required to be installed over the luminaires.
E4.B R-49 Attic Insulation: Attic insulation shall be installed to achieve a weighted assembly U-factor of 0.020
or insulation installed at the ceiling level shall have a thermal resistance of R-49 or greater for the
insulation alone. Recessed downlight luminaires in the ceiling shall be covered with insulation to the
same depth as the rest of the ceiling. Luminaires not rated for insulation contact must be replaced or
fitted with a fire-proof cover that allows for insulation to be installed directly over the cover. Exception:
In buildings where existing R-30 is present and existing recessed downlight luminaires are not rated for
insulation contact, insulation is not required to be installed over the luminaires.
E5 Duct Sealing: Air seal all space conditioning ductwork to meet the requirements of the 2025 Title 24,
Part 6, Section 150.2(b)1E. The duct system must be tested by a ECC Rater no more than three years
prior to the Covered Single Family Project permit application date to verify the duct sealing and confirm
that the requirements have been met. This measure may not be combined with the New Ducts and
Duct Sealing measure in this Table.
Exception: Buildings without ductwork or where the ducts are in conditioned space.
E6.A New Ducts, R-6 insulation + Duct Sealing: Replace existing space conditioning ductwork with new R-6
ducts that meet the requirements of 2025 Title 24 Section 150.0(m)11. This measure may not be
combined with the Duct Sealing measure in this Table. To qualify, a preexisting measure must have
been installed no more than three years before the Covered Single Family Project permit application
date.
E6.B New Ducts, R-8 insulation + Duct Sealing: Replace existing space conditioning ductwork with new R-8
ducts that meet the requirements of 2025 Title 24 Section 150.0(m)11. This measure may not be
combined with the Duct Sealing measure in this Table. To qualify, a preexisting measure must have
been installed no more than three years before the Covered Single Family Project permit application
date.
E7 Windows: Replace at least 50% of existing windows with high performance windows with an area-
weighted average U-factor no greater than 0.27 in Climate Zones 4.
E8 R-15 Wall Insulation: Install wall insulation in all exterior walls to achieve a weighted U-factor of 0.095
or install wall insulation in all exterior wall cavities that shall result in an installed thermal resistance of
R-15 or greater for the insulation alone.
E9 Reserved for future use
E10.
A
R-19 Floor Insulation: Raised-floors shall be insulated such that the floor assembly has an assembly U-
factor equal to or less than U-0.037 or shall be insulated between wood framing with insulation having
an R-value equal to or greater than R-19.
E10.
B
R-30 Floor Insulation: Raised-floors shall be insulated such that the floor assembly has an assembly U-
factor equal to or less than U-0.028 or shall be insulated between wood framing with insulation having
an R-value equal to or greater than R-30.
E11 Radiant Barrier: A radiant barrier that meets the requirements of Section 150.1(c)2 shall be installed
under at least 50% of the roof surface.
Fuel Substitution and Solar PV Measures
FS1 Heat Pump Water Heater (HPWH) Replacing Gas: Replace existing natural gas water heater with a heat
pump water heater that meets the requirements of Sections 110.3 and 150.2(b)1.H.iii.b.
13
0290179_20250826_ms29
FS2 High Efficiency Heat Pump Water Heater (HPWH) Replacing Gas: Replace existing natural gas water
heater with heat pump water heater with a Northwest Energy Efficiency Alliance (NEEA) Tier 3 or higher
rating that also meets the requirements of Sections 110.3 and 150.2(b)1.H.iii.c.
FS3 Heat Pump Water Heater (HPWH) Replacing Electric: Replace existing electric resistance water heater
with a heat pump water heater that meets the requirements of Sections 110.3 and 150.2(b)1.H.iii.b.
FS4 High Efficiency Heat Pump Water Heater (HPWH) Replacing Electric: Replace existing electric resistance
water heater with heat pump water heater with a Northwest Energy Efficiency Alliance (NEEA) Tier 3 or
higher rating that also meets the requirements of Sections 110.3, and 150.2(b)1.H.iii.c.
FS5 Heat Pump Space Conditioning System: Replace all existing gas and electric resistance primary space
heating systems with a heat pump system that meets the requirements of Sections 110.3, 150.2(b)1.C,
150.2(b)1.E, 150.2(b)1.F, and 150.2(b)1.G.
FS6 High Efficiency Heat Pump Space Conditioning System: Replace all existing gas and electric resistance
primary space heating systems with an electric-only heat pump system that meets the requirements of
Sections 110.3 and 150.2(b)1.C, 150.2(b)1.E, 150.2(b)1.F, and 150.2(b)1.G and one of the following:
A. A ducted heat pump system with a SEER2 rating of 16.5 or greater, an EER2 rating of 12.48 or
greater and an HSPF2 rating of 9.5 or greater; or
B. A ductless mini-split heat pump system with a SEER2 rating of 14.3 or greater, an EER2 rating of
11.7 or greater and an HSPF2 rating of 7.5 or greater
FS7 Dual Fuel Heat Pump Space Conditioning System: Install a heat pump space conditioning system that
meets the requirements of Sections 110.3 and 150.2(b)1.C, 150.2(b)1.E, 150.2(b)1.F, and 150.2(b)1.G
and either:
A. Replaces all existing gas and electric resistance primary heating systems with a hybrid gas and
electric heat pump system, or
B. Is an electric-heat pump system in tandem with a gas furnace and controls to use the gas furnace
for backup heat only.
FS8 Heat Pump Clothes Dryer: Replace existing electric resistance or gas clothes dryer with heat pump dryer
with no resistance element and cap gas line.
FS9 Induction Cooktop: Replace all existing gas and electric resistance stove tops with inductive stove top
and cap the gas line.
PV.A Solar PV: Install a solar PV system that meets the requirements of Section 150.1(c)14.
A new Subsection, (x), is added to Section 150.0 as follows:
(x) Electric Readiness for Alterations
1. Electric range. Where branch circuits or receptacles are added or
altered in a kitchen and the work requires a building permit, install
electrical components in accordance with the California Electrical
Code. The electrical components shall include either of the
following:
A. A 125 volt, 20 amp electrical receptacle that is connected to
the electric panel with a 120/240 volt 3 conductor branch
circuit rated at 50 amps minimum, within 3 feet from the
appliance and accessible to the appliance with no
obstructions. Both ends of the unused conductor shall be
14
0290179_20250826_ms29
labeled with the word “spare” and be electrically isolated.
Space shall be reserved for a single pole circuit breaker in the
electrical panel adjacent to the circuit breaker for the branch
circuit and labeled with the words “Future Use”.
B. A pathway for a future 240 volt 50 amp minimum branch
circuit that shall consist of either conductors or raceway from
the main electrical service panel. The main electric panel shall
have space reserved to allow for the installation of a double
pole circuit breaker for a future electric range installation. The
reserved space shall be permanently marked as “For Future
240V use”. The raceway or conductors shall terminate at a
junction box within 3 feet of the appliance. The blank cover
shall be identified as “240V ready”.
2. Electric dryer. Where a branch circuit is added or altered within 3
feet of a gas or propane clothes dryer and the work requires a
building permit, install electrical components in accordance with
the California Electrical Code. The electrical components shall
include either of the following:
A. A dedicated 125 volt, 20 amp electrical receptacle that is
connected to the electric panel with a 120/240 volt 3
conductor branch circuit rated at 30 amps minimum, within 3
feet from the appliance and accessible to the appliance with
no obstructions. Both ends of the unused conductor shall be
labeled with the word “spare” and be electrically isolated.
Space shall be reserved for a single pole circuit breaker in the
electrical panel adjacent to the circuit breaker for the branch
circuit and labeled with the words “Future Use”; or,
B. A pathway for a future 240 volt 30 amp minimum branch
circuit that shall consist of either conductors or raceway from
the main electrical service panel. The main electric panel shall
have space reserved to allow for the installation of a double
pole circuit breaker for a future heat pump dryer installation.
The reserved space shall be permanently marked as “For
Future 240V use”. The raceway or conductors shall terminate
at a junction box within 3 feet of the appliance. The blank
cover shall be identified as “240V ready”.
3. Heat pump water heater.
A. If wall framing is removed or replaced within 3 feet of a gas or
propane water heating appliance, space suitable for the future
installation of a heat pump water heater (HPWH) shall be
provided. The space shall be at least 2.5 feet by 2.5 feet wide
and 7 feet tall and shall include a condensate drain that is no
more than 2 inches higher than the base of an installed water
heater and allows natural draining without pump assistance or
installed piping or tubing within 3 feet of the water heater
15
0290179_20250826_ms29
location to a condensate drain or exterior location. If pump
assistance is needed, a receptacle on a 120 volt, minimum 15
amp branch circuit for a condensate pump must be available
within 3 feet of the water heater location.
B. Where branch circuits are altered or added within 3 feet of an
existing gas or propane water heater or within 10 feet of the
designated future location of a heat pump water heater as
required under Section 150.0(x)3A, and the work requires a
building permit, install electrical components in accordance
with the California Electrical Code. The electrical components
shall include either of the following:
i. A dedicated 125 volt, 20 amp electrical receptacle that is
connected to the electric panel with a 120/240 volt 3
conductor, 10 AWG copper branch circuit rated at 30 amps
minimum, within 3 feet from the water heater and
accessible to the water heater with no obstructions. Both
ends of the unused conductor shall be labeled with the
word “spare” and be electrically isolated. Space shall be
reserved for a single pole circuit breaker space in the
electrical panel adjacent to the circuit breaker for the
branch circuit and labeled with the words “Future 240V
Use”; or
ii. A pathway for a future 240 volt 30 amp minimum branch
circuit that shall consist of either conductors or raceway
from the main electrical service panel. The main electric
panel shall have space reserved to allow for the
installation of a double pole circuit breaker for a future
HPWH installation. The reserved space shall be
permanently marked as “For Future 240V use”. The
pathway shall terminate at a junction box within 3 feet of
the appliance. The blank cover shall be identified as “240V
ready”.
Exception 1 to Section 150.0(x): The project is the result of a
repair as defined by Title 24 Part 2 Section 202.
Exception 2 to Section 150.0(x): If a building permit, is not
otherwise required for the project other than compliance with
this section.
Exception 4 to Section 150.0(x): The project is the result of a
safety improvement to remove a known hazard.
Exception 5 to Section 150.0(x): Mobile Homes, Manufactured
Housing, or Factory-built Housing as defined in Division 13 of the
16
0290179_20250826_ms29
California Health and Safety 12 Code (commencing with Section
17000 of the Health and Safety Code).
Exception 6 to Section 150.0(x): Emergency Housing pursuant to
Appendix P of the California Building Code.
Exception 7 to Section 150.0(x): Creation of a new accessory
dwelling unit or junior accessory dwelling unit that is within the
existing space of a single family dwelling or accessory structure
and includes an expansion of not more than 150 square feet
beyond the same physical dimensions as the existing accessory
structure. An expansion beyond the physical dimensions of the
existing accessory structure shall be limited to accommodating
ingress and egress. Or, if the project would not otherwise be a
Covered Single Family Project were it not for the inclusion of an
accessory dwelling unit or junior accessory dwelling unit that
meets the criteria above.
16.17.130 Reserved
16.17.140 SUBCHAPTER 9 SINGLE-FAMILY RESIDENTIAL BUILDINGS—ADDITIONS
AND ALTERATIONS TO EXISTING RESIDENTIAL BUILDINGS
The requirements of PAMC 16.17.140 shall apply to building permit applications
submitted to the City on or after January 1, 2027 and shall apply to all building permit
applications submitted to the City on or after that date.
Section 150.2 – ENERGY EFFICIENCY STANDARDS FOR ADDITIONS AND ALTERATIONS
TO EXISTING SINGLE-FAMILY RESIDENTIAL BUILDINGS – of Subchapter 9 of the 2025
California Energy Code is adopted without amendment, except as follows (additions
underlined, deletions struck through):
Section 150.2(b)1C is hereby amended to read:
C.EnƟrely new or complete replacement space-condiƟoning systems installed
as part of an alteraƟon, shall include all the system heaƟng or cooling
equipment, including but not limited to: condensing unit cooling or heaƟng
coil, and air handler for split systems; or complete replacement of a packaged
unit; plus enƟrely new or replacement duct system (SecƟon 150.2(b)1Diia).
EnƟrely new or complete replacement space-condiƟoning systems shall meet
the requirements of SecƟons 150.0(h), 150.0(i), 150.0(j)1, 150.0(j)2,
150.0(m)1 through 150.0(m)10; 150.0(m)12; 150.0(m)13, 150.1(c)7,
150.2(b)1Fii, 150.2(b)1G, and TABLE 150.2-A. AddiƟonally, where an enƟrely
new or complete replacement space condiƟoning system includes a new or
replacement air-cooled air condiƟoner in Climate Zones 1 through 14 and 16,
17
0290179_20250826_ms29
it shall meet the applicable requirements of SecƟon 150.2(b)1Fiv. Where an
enƟrely new or complete replacement space condiƟoning system includes a
new or replacement heat pump, it shall meet the applicable requirements of
SecƟon 150.2(b)1Fv.
Section 150.2(b)1.F. is hereby amended to read:
F.Altered space-conditioning system - mechanical cooling. Alterations which
install new or replacement air-cooled air conditioners shall meet the
applicable requirements of subsections i and iv. Alterations which install new
or replacement heat pumps shall meet the applicable requirements of
subsections i, ii, iii, and v. All other alterations to refrigerant containing
components such as the compressor, condensing coil, evaporator coil,
refrigerant metering device, or refrigerant piping, shall meet the applicable
requirements of subsections i, ii, and iii. When a space-conditioning system is
an air conditioner or heat pump that is altered by the installation or
replacement of refrigerant-containing system components such as the
compressor, condensing coil, evaporator coil, refrigerant metering device or
refrigerant piping, the altered system shall comply with the following
requirements:
i. All thermostats associated with the system shall be replaced with
setback thermostats meeting the requirements of Section 110.2(c).
ii. Air-cooled air conditioners in Climate Zones 2 and 8 through 15 and air-
source heat pumps in all climate zones, including but not limited to
ducted split systems, ducted package systems, small duct high velocity
air systems, and minisplit systems, shall comply with Subsections a and
b, unless the system is of a type that cannot be verified using the
specified procedures. Systems that cannot comply with the
requirements of 150.2(b)1Fii shall comply with Section 150.2(b)1Fiii.
Exception to Section 150.2(b)1Fii: Entirely new or complete
replacement packaged systems for which the manufacturer has
verified correct system refrigerant charge prior to shipment from the
factory are not required to have refrigerant charge confirmed through
field verification and diagnostic testing. The installer of these packaged
systems shall certify on the Certificate of Installation that the packaged
system was pre-charged at the factory and has not been altered in a
way that would affect the charge. Ducted systems shall comply with
minimum system airflow rate requirement in Section 150.2(b)1Fiia,
provided that the system is of a type that can be verified using the
procedure specified in RA3.3 or an approved alternative in RA1.
a. Minimum system airflow rate shall comply with the applicable
Subsection I or II below as confirmed through field verification and
diagnostic testing in accordance with the procedures specified in
Reference Residential Appendix Section RA3.3 or an approved
18
0290179_20250826_ms29
alternative procedure as specified in Section RA1.
I. Small duct high velocity systems shall demonstrate a
minimum system airflow rate greater than or equal to 250
cfm per ton of nominal cooling capacity; or
II. All other air-cooled air conditioner or air-source heat
pump systems shall demonstrate a minimum system
airflow rate greater than or equal to 300 cfm per ton of
nominal cooling capacity; and
Exception 1 to Section 150.2(b)1Fiia: Systems unable to comply
with the minimum airflow rate requirement shall demonstrate
compliance using the procedures in Section RA3.3.3.1.5; and the
system's thermostat shall conform to the specifications in Section
110.12.
Exception 2 to Section 150.2(b)1Fiia: Entirely new or complete
replacement space conditioning systems, as specified by Section
150.2(b)1C, without zoning dampers may comply with the
minimum airflow rate by meeting the applicable requirements in
Tables-150.0-B or 150.0-C as confirmed by field verification and
diagnostic testing in accordance with the procedures in Reference
Residential Appendix Section RA3.1.4.4 and RA3.1.4.5. The design
clean-filter pressure drop requirements of Section 150.0(m)12C
for the system air filter device(s) shall conform to the
requirements given in Tables150.0-B and 150.0-C.
b. The installer shall charge the system according to
manufacturer’s specifications. Refrigerant charge shall be verified
according to one of the following options, as applicable.
I. The installer and rater shall perform the standard charge
verification procedure as specified in Reference Residential
Appendix Section RA3.2.2, or an approved alternative
procedure as specified in Section RA1; or
II. The installer shall perform the weigh-in charging procedure as
specified by Reference Residential Appendix Section RA3.2.3.1
provided the system is of a type that can be verified using the
RA3.2.2 standard charge verification procedure and RA3.3
airflow rate verification procedure or approved alternatives in
RA1. The ECC-Rater shall verify the charge using RA3.2.2 and
RA3.3 or approved alternatives in RA1.
Exception 1 to Section 150.2(b)1Fiib: When the outdoor
temperature is less than 55° F and the installer utilizes the weigh-
in charging procedure in Reference Residential Appendix Section
RA3.2.3.1to demonstrate compliance, the installer may elect to
utilize the verification procedure in Reference Residential
19
0290179_20250826_ms29
Appendix Section RA3.2.3.2. If the verification procedure in
Section RA3.2.3.2 is used for compliance, the system's thermostat
shall conform to the specifications in Section 110.12. Ducted
systems shall comply with the minimum system airflow rate
requirements in Section 150.2(b)1Fiia.
iii. Air-cooled air conditioners in Climate Zones 2 and 8 through 15 and
air-source heat pumps in all climate zones, including but not limited
to ducted split systems, ducted package systems, small duct high
velocity, and minisplit systems, which are of a type that cannot
comply with the requirements of 150.2(b)1Fiib shall comply with
subsections a and b, as applicable.
a. The installer shall confirm the refrigerant charge using the weigh-
in charging procedure specified in Reference Residential Appendix
Section RA3.2.3.1, as verified by an ECC-Rater according to the
procedures specified in Reference Residential Appendix RA3.2.3.2;
and
b. Systems that utilize forced air ducts shall comply with the
minimum system airflow rate requirement in Section
150.2(b)1Fiia provided the system is of a type that can be verified
using the procedures in Section RA3.3 or an approved alternative
procedure in Section RA1.
Exception to Section 150.2(b)1Fiii: Entirely new or complete
replacement packaged systems for which the manufacturer has
verified correct system refrigerant charge prior to shipment from
the factory are not required to have refrigerant charge confirmed
through field verification and diagnostic testing. The installer of
these packaged systems shall certify on the Certificate of
Installation that the packaged system was pre-charged at the
factory and has not been altered in a way that would affect the
charge. Ducted systems shall comply with minimum system
airflow rate requirement in Section 150.2(b)1Fiiib, provided that
the system is of a type that can be verified using the procedure
specified in Section RA3.3 or an approved alternative in Section
RA1.
iv. New or replacement air-cooled air conditioners in Climate Zones 1
through 14 and 16 shall meet the requirements of Section
150.2(b)1Fiva or 150.2(b)1Fivb.
a. Systems with existing duct distribution systems shall meet the
following requirements:
I. In all climate zones, meet the airflow and fan efficacy
requirements of Section 150.0(m)13B, 150.0(m)13C, or
150.0(m)13D.
20
0290179_20250826_ms29
Exception 1 to Section 150.2(b)1FivaI: Single zone central
forced air systems and zonally controlled central forced air
systems may demonstrate compliance with an airflow greater
than or equal to 300 CFM per ton of nominal cooling capacity.
II. In all climate zones, meet the refrigerant charge verification
requirements of Section 150.2(b)1Fii; and
III. In all climate zones, vented attics shall have insulation
installed to achieve a U-factor of 0.020 or insulation installed
at the ceiling level shall result in an insulated thermal
resistance of R-49 or greater for the insulation alone;
luminaires not rated for insulation contact must be replaced
or retrofitted with a fireproof cover that allows for insulation
to be installed directly over the cover; and
Exception 1 to Section 150.2(b)1FivaIII: Dwelling units with at
least R-38 existing insulation installed at the ceiling level.
Exception 2 to Section 150.2(b)1FivaIII: Dwelling units where
the alteration would directly cause the disturbance of
asbestos unless the alteration is made in conjunction with
asbestos abatement.
Exception 3 to Section 150.2(b)1FivaIII: Dwelling units with
knob and tube wiring located in the vented attic.
Exception 4 to Section 150.2(b)1FivaIII: Where the accessible
space in the attic is not large enough to accommodate the
required R-value, the entire accessible space shall be filled
with insulation provided such installation does not violate
Section 806.3 of Title 24, Part 2.5.
Exception 5 to Section 150.2(b)1FivaIII: Where the attic space
above the altered dwelling unit is shared with other dwelling
units and the requirements of Section 150.2(b)1FivaIII are not
triggered for the other dwelling units.
IV. In all climate zones, air seal all accessible areas of the ceiling
plane between the attic and the conditioned space in
accordance with Section 110.7.
Exception 1 to Section 150.2(b)1FivaIV: Dwelling units with at
least R-38 existing insulation installed at the ceiling level.
Exception 2 to Section 150.2(b)1FivaIV: Dwelling units where
the alteration would directly cause the disturbance of
asbestos unless the alteration is made in conjunction with
asbestos abatement.
Exception 3 to Section 150.2(b)1FivaIV: Dwelling units with
atmospherically vented space heating or water heating
21
0290179_20250826_ms29
combustion appliances located inside the pressure boundary
of the dwelling unit.
b. Systems with entirely new or complete replacement duct systems
shall meet the following:
I. R-8 duct insulation shall be installed for all new ducts located
in unconditioned space; and
II. In all climate zones, meet the airflow requirements of Section
150.0(m)13B, 150.0(m)13C, or 150.0(m)13D and demonstrate
an air-handling unit fan efficacy of less than or equal to 0.35
W/CFM.
III. In all climate zones, meet the refrigerant charge verification
requirements of Section 150.2(b)1Fii;
Exception 1 to Section 150.2(b)1Fiv: Where the capacity of the
existing main electrical service panel is insufficient to supply the
electrical capacity of a heat pump and where the existing main
electrical service panel is sufficient to supply a new or replacement air
conditioner, as calculated according to the requirements of California
Electrical Code Article 220.83 or Article 220.87, systems shall comply
with the applicable requirements of Sections 150.2(b)1Fi,
150.2(b)1Fii, and 150.2(b)1Fiii. Documentation of electrical load
calculations in accordance with Article 220 must be submitted to the
enforcement agency prior to permitting for both the heat pump and
proposed air conditioner.
Exception 2 to Section 150.2(b)1Fiv: Where the required capacity of a
heat pump to meet the system selection requirements of Section
150.0(h)5 is greater than or equal to 12,000 Btu/h more than the
greater of the required capacity of an air conditioner to meet the
design cooling load OR the capacity of the existing air conditioner,
systems shall comply with the applicable requirements of Sections
150.2(b)1Fi, 150.2(b)1Fii, and 150.2(b)1Fiii. Documentation of heating
and cooling load calculations in accordance with 150.0(h) must be
submitted to the enforcement agency prior to permitting for both the
heat pump and proposed air conditioner.
v.In all climate zones, heat pumps with supplementary heat, including,
but not limited to, electric resistance heaters or gas furnace
supplementary heating, shall comply with Section 150.0(h)7 and shall
lock out supplementary heating above an outdoor air temperature of
no greater than 35°F.
Section 150.2(b)2 is hereby amended to read:
2. Performance approach.
The energy budget for alterations is expressed in terms of Long-term
System Cost (LSC), and the altered component(s) and any newly installed
22
0290179_20250826_ms29
equipment serving the alteration shall meet the applicable requirements
of Subsections A, B, and C below.
A. The altered components shall meet the applicable requirements of
Sections 110.0 through 110.9, Sections 150.0(a) through (l), Sections
150.0(m)1 through 150.0 (m)10, and Sections 150.0(p) through (q).
Entirely new or complete replacement mechanical ventilation
systems as these terms are used in Section 150.2(b)1L, shall comply
with the requirements in Section 150.2(b)1L. Altered mechanical
ventilation systems shall comply with the requirements of Section
150.2(b)1M. Entirely new or complete replacement space-
conditioning systems, and entirely new or complete replacement duct
systems, as these terms are used in Sections 150.2(b)1C and
150.2(b)1Diia, shall comply with the requirements of Sections
150.0(m)12 and 150.0(m)13. New or replacement air-cooled air
conditioners in Climate Zones 1 through 14 and 16 shall meet the
applicable requirements of Section 150.2(b)1Fiv.
B.The standard design for an altered component shall be the higher
efficiency of existing conditions or the requirements stated in Table
150.2-G. For components not being altered, the standard design shall
be based on the existing conditions. When the third party verification
option is specified as a requirement, all components proposed for
alteration for which the additional credit is taken, must be verified by
a certified ECC-rater.
Table 150.2-G is hereby amended to read:
Table 150.2-G Standard Design for an Altered Component
Altered
Component
Standard Design Without Third Party
Verification of Existing Conditions Shall
be Based On
Standard Design With Third Party
Verification of Existing
Conditions Shall be Based On
Ceiling
Insulation,
Wall
Insulation,
and Raised-
floor
Insulation
The requirements of Sections 150.0(a),
(c), and (d).
The requirements of Section 150.2(b)1J
for altered ceilings and for entirely new or
complete replacement duct systems
where the air handler and ducts are
located within a vented attic.
The requirements of Section 150.2(b)1Fiv
for alterations which include new or
replacement air-cooled air conditioners.
The existing insulation R-value
Fenestration The requirements of Section 150.1(c)3A. The existing fenestration U-factor
23
0290179_20250826_ms29
and
SHGC values as verified.
Window Film The requirements of Section 150.1(c)3A. The existing fenestration in the
alteration shall be based on
TABLE 110.6-A and TABLE 110.6-
B.
Doors The U-factor of 0.20. The door area shall
be the door area of the existing building.
If the proposed U-factor is < 0.20,
the standard design shall be
based on the existing U-factor
value as verified. Otherwise, the
standard design shall be based on
the U-factor of 0.20. The door
area shall be the door area of the
existing building.
Space-
Heating and
Space-
Cooling
Equipment
Table 150.1-A for equipment efficiency
requirements;
Section 150.2(b)1C for entirely new or
complete replacement systems;
Section 150.2(b)1F for refrigerant charge
verification, airflow, and fan efficacy
requirements.
Section 150.2(b)1Fiv for new or
replacement air-cooled air conditioners
The existing efficiency levels.
Air
Distribution
System –
Duct Sealing
The requirements of Sections 150.2(b)1D
and 150.2(b)1E
The requirements of Sections
150.2(b)1D and 150.2(b)1E
Air
Distribution
System –
Duct
Insulation
The proposed efficiency levels.
The requirements of Sections 150.2(b)1D,
and for new or replacement air-cooled air
conditioners, Section 150.2(b)1Fiv.
The existing efficiency levels.
Water
Heating
Systems
The requirements of Section 150.2(b)1Hii The existing efficiency level.
Roofing
Products
The requirements of Section 150.2(b)1I. The requirements of Section
150.2(b)1I
24
0290179_20250826_ms29
C.The proposed design shall be based on the actual values of the altered
components.
16.17.150 Reserved
16.17.160 Reserved
16.17.170 Infeasibility Exemption.
(a)Exemption. If an applicant for a Covered Project believes that
circumstances exist that makes it infeasible to meet the requirements of
this Chapter, the applicant may request an exemption as set forth below.
In applying for an exemption, the burden is on the Applicant to show
infeasibility.
(b)Application. If an applicant for a Covered Project believes such
circumstances exist, the applicant may apply for an exemption at the time
of application submittal in accordance with the Planning and
Development Services administrative guidelines. The applicant shall
indicate the maximum threshold of compliance the energy compliance
design professional believes is feasible for the covered project and the
circumstances that make it infeasible to fully comply with this Chapter.
Circumstances that constitute infeasibility include, but are not limited to
the following:
(1) There is conflict with the compatibility of the currently adopted
California Building Standards Code;
(2) There is a lack of commercially available materials and
technologies to comply with the requirements of this Chapter;
(3) Applying the requirements of this Chapter would effectuate an
unconstitutional taking of property or otherwise have an
unconstitutional application to the property.
(c)Granting of Exemption. If the Director of Planning and Development
Services, or designee, determines that it is infeasible for the applicant to
fully meet the requirements of this Chapter based on the information
provided, the Director, or designee, shall determine the maximum feasible
threshold of compliance reasonably achievable for the project. The
decision of the Director, or designee, shall be provided to the applicant in
writing. If an exemption is granted, the applicant shall be required to
comply with this Chapter in all other respects and shall be required to
All Other
Measures
The proposed efficiency levels. The existing efficiency levels.
*NOT YET APPROVED*
25
0290179_20250826_ms29
achieve, in accordance with this Chapter, the threshold of compliance
determined to be achievable by the Director or designee.
(d)Denial of Exemption. If the Director of Planning and Development
Services or designee determines that it is reasonably possible for the
applicant to fully meet the requirements of this Chapter, the request shall
be denied, and the Director or designee shall so notify the applicant in
writing. The project and compliance documentation shall be modified to
comply with this Chapter prior to further review of any pending planning
or building application.
(e)Council Review of Exemption. For any covered project that requires
review and action by the City Council, the Council shall act to grant or deny
the exemption, based on the criteria outlined above, after
recommendation by the Director of Planning and Development Services.
16.17.180 Appeal.
(a) Any aggrieved Applicant may appeal the determination of the Director
of Planning and Development Services or designee regarding the
granting or denial of an exemption pursuant to 16.17.170.
(b) Any appeal must be filed in writing with the Planning and
Development Services Department not later than fourteen (14) days after
the date of the determination by the Director. The appeal shall state the
alleged error or reason for the appeal.
(c) The appeal shall be processed and considered by the City Council in
accordance with the provisions of Section 18.77.070 (f) of the City of Palo
Alto Municipal Code.
SECTION 3. The Council adopts the findings for local amendments to the California
Energy Code, 2025 Edition, attached hereto as Exhibit “A” and incorporated herein by reference.
SECTION 4. Under the authority granted by Public Resources Code Section
25402.1(h)(2), which permits local California Energy Code amendments, and based on staff’s
analysis of the “2022 Cost-Effectiveness Study: Existing Single Family Building Upgrades ,” “2025
Cost-Effectiveness Study: Single Family AC to Heat Pump Replacement,” and “Application of the
2022 Studies to the 2025 Energy Code: Existing Single Family Building Upgrades” developed for
the California Energy Codes and Standards Program and attached to staff’s report to Council, the
Council finds that the proposed local amendments to the 2025 California Energy Code that affect
building energy performance are cost-effective and will require buildings to be designed to
consume less energy than permitted by Title 24, Part 6.
SECTION 5. If any section, subsection, clause or phrase of this Ordinance is for any
reason held to be invalid, such decision shall not affect the validity of the remaining portion or
sections of the Ordinance. The Council hereby declares that it should have adopted the Ordinance
26
0290179_20250826_ms29
and each section, subsection, sentence, clause or phrase thereof irrespective of the fact that any
one or more sections, subsections, sentences, clauses or phrases be declared invalid.
SECTION 6. The Council finds that this ordinance is exempt from the provisions of the
California Environmental Quality Act (“CEQA”), under Section 15308 of the CEQA Guidelines,
because it is a regulatory action 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
energy standards, there are no reasonably foreseeable adverse environmental impacts and there
is no possibility that the activity in question may have a significant effect on the environment.
//
//
//
//
//
//
//
//
//
//
//
//
//
//
//
//
//
27
0290179_20250826_ms29
SECTION 7. Pursua tont Pal o Al Muto nicipa Col Sde ection 2.0 4.27 th0, ordiis nance
shall be effective immediately upon adoption if passed by a vote of four-fifths of the council
members present. Unless otherwise specified in this ordinance, its provisions shall become
applicable 180 days after publication of the 2025 Edition of California Energy Code, Title 24, Part
6. Until that date, the provisions of the 2022 Edition of the California Energy Code, as adopted
and amended by Ordinance 5627, shall apply and remain in effect.
INTRODUCED: ^ Wd D Zϴ͕ϮϬϮϱ
PASSED: SEPTEMBER 8, 2025
AYES: BURT, LAUING, LU, LYTHCOTT-HAIMS, RECKDAHL, STONE, VEENKER
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
________________________________________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
________________________________________________________
City Attorney or Designee City Manager
____________________________
Director of Planning and
Development Services
____________________________
Director of Administrative Services
28
0290179_20250826_ms29
Exhibit A
FINDINGS FOR LOCAL AMENDMENTS TO CALIFORNIA ENERGY CODE, 2025 EDITION
TITLE 24, PART 6
Section 17958 of the California Health and Safety Code provides that the City may make changes
to the provisions of the California Building Standards Code. Sections 17958.5 and 17958.7 of the
Health and Safety Code require that for each proposed local change to those provisions of the
California Building Standards Code which regulate buildings used for human habitation, the City
Council must make findings supporting its determination that each such local change is reasonably
necessary because of local climatic, geological, or topographical conditions.
Regarding the Energy Code, local jurisdictions have the authority to adopt local energy
efficiency ordinances—or reach codes—that exceed the minimum standards defined by Title 24
(as established by Public Resources Code Section 25402.1(h)2 and Section 10-106 of the
Building Energy Efficiency Standards), provided the City Council finds that the requirements of
the proposed ordinance are cost-effective and do not result in buildings consuming more
energy than is permitted by Title 24.
Local building regulations having the effect of amending the uniform codes, which were adopted
by the City prior to November 23, 1970, were unaffected by the regulations of Sections 17958,
17958.5 and 17958.7 of the Health and Safety Code. Therefore, amendments to the uniform
codes which were adopted by the City Council prior to November 23, 1970 and have been carried
through from year to year without significant change, need no required findings. Also,
amendments to provisions not regulating buildings used for human habitation do not require
findings.
Code: California Energy Code, Title 24, Part 6
Chapter(s),
Sections(s),
Appendices
Title Add Deleted Amended Justification
(See below of keys)
100.0 Scope 33 C & E
100.1(b) Definitions 3 C & E
150.0 Mandatory Features and Devices 3 C & E
150.2(b) Energy Efficiency Standards for Additions
and Alterations to Existing Single-Family
Residential Buildings - Alterations
3 C & E
Table 150.2-
G
Standard Design for an Altered Component 3 C & E
29
0290179_20250826_ms29
Key to Justification for Amendments to Title 24 of the California Code of Regulations
A This is an administrative amendment to clarify and establish civil and administrative
procedures, regulations, or rules to enforce and administer the activities by the Palo Alto
Building Inspection Department. These administrative amendments do not need to meet
HSC 18941.5/17958/13869 per HSC 18909(c).
C This amendment is justified on the basis of a local climatic condition. The seasonal climatic
conditions during the late summer and fall create severe fire hazards to the public health
and welfare in the City. The hot, dry weather frequently results in wild land fires on the
brush covered slopes west of Interstate 280. The aforementioned conditions combined
with the geological characteristics of the hills within the City create hazardous conditions
for which departure from California Energy Code is required. Failure to address and
significantly reduce greenhouse gas (GHG) emissions could result in rises in sea level,
including in San Francisco Bay, that could put at risk Palo Alto homes and businesses,
public facilities, and Highway 101 (Bayshore Freeway), particularly the mapped Flood
Hazard areas of the City. Energy efficiency is a key component in reducing GHG emissions,
and the construction of more energy efficient buildings can help Palo Alto reduce its share
of the GHG emissions that contribute to climate change. The burning of fossil fuels used
in the generation of electric power and heating of buildings contributes to climate change,
which could result in rises in sea level, including in San Francisco Bay, that could put at
risk Palo Alto homes and businesses 1 public facilities, and Highway 101. Due to a decrease
in annual rainfall, Palo Alto experiences the effect of drought and water saving more than
some other communities in California.
E Energy efficiency enhances the public health and welfare by promoting the
environmental and economic health of the City through the design, construction,
maintenance, operation, and deconstruction of buildings and sites by incorporating green
practices into all development. The provisions in this Chapter are designed to achieve the
following goals:
(a)Increase energy efficiency in buildings;
(b)Increase resource conservation;
(c)Provide durable buildings that are efficient and economical to own and operate;
(d)Promote the health and productivity of residents, workers, and visitors to the city;
(e)Recognize and conserve the energy embodied in existing buildings; and
(f)Reduce disturbance of natural ecosystems.
G This amendment is justified on the basis of a local geological condition. The City of Palo Alto
is subject to earthquake hazards caused by its proximity to San Andreas fault. This fault
runs from Hollister, through the Santa Cruz Mountains, epicenter of the 1989 Loma Prieta
earthquake, then on up the San Francisco Peninsula, then offshore at Daly City near Mussel
Rock. This is the approximate location of the epicenter of the 1906 San Francisco
Infeasibility Exemption 33 A
Appeal 3 A
30
0290179_20250826_ms29
earthquake. The other fault is the Hayward Fault. This fault is about 74 mi long, situated
mainly along the western base of the hills on the east side of San Francisco Bay. Both of
these faults are considered major Northern California earthquake faults which may
experience rupture at any time. Thus, because the City is within a seismic area that
includes these earthquake faults, the modifications and changes cited herein are designed
to better limit property damage as a result of seismic activity and to establish criteria for
repair of damaged properties following a local emergency.
T The City of Palo Alto topography includes hillsides with narrow and winding access, which
makes timely response by fire suppression vehicles difficult. Palo Alto is contiguous with
the San Francisco Bay, resulting in a natural receptor for storm and waste water run-off.
Also the City of Palo Alto is located in an area that is potentially susceptible to liquefaction
during a major earthquake. The surface condition consists mostly of stiff to dense sandy
clay, which is highly plastic and expansive in nature. The aforementioned conditions
within the City create hazardous conditions for which departure from California Building
Standards Codes is warranted.
Certificate Of Completion
Envelope Id: CB5E50DF-BE23-4893-ADF5-184AAC3490BB Status: Completed
Subject: URGENT: ORD 5665 - Emergency Ordinance of the Council of the City of Palo Alto Amending Ch 16.17
Source Envelope:
Document Pages: 30 Signatures: 6 Envelope Originator:
Certificate Pages: 2 Initials: 0 Francesca Reyes
AutoNav: Enabled
EnvelopeId Stamping: Enabled
Time Zone: (UTC-08:00) Pacific Time (US & Canada)
250 Hamilton Ave
Palo Alto , CA 94301
Francesca.Reyes@CityofPaloAlto.org
IP Address: 170.85.54.96
Record Tracking
Status: Original
9/16/2025 8:21:52 AM
Holder: Francesca Reyes
Francesca.Reyes@CityofPaloAlto.org
Location: DocuSign
Security Appliance Status: Connected Pool: StateLocal
Storage Appliance Status: Connected Pool: City of Palo Alto Location: Docusign
Signer Events Signature Timestamp
Madeleine Salah
Madeleine.Salah@paloalto.gov
Deputy City Attorney
City of Palo Alto
Security Level: Email, Account Authentication
(None)
Signature Adoption: Pre-selected Style
Using IP Address:
2601:645:c681:9a00:e02f:d4b1:470e:548d
Sent: 9/16/2025 8:33:40 AM
Viewed: 9/16/2025 8:44:52 AM
Signed: 9/16/2025 8:47:31 AM
Electronic Record and Signature Disclosure:
Not Offered via Docusign
Lauren Lai
Lauren.Lai@paloalto.gov
Director Administrative Services/CFO
COPA
Security Level: Email, Account Authentication
(None)
Signature Adoption: Drawn on Device
Using IP Address: 199.33.32.254
Sent: 9/16/2025 8:47:32 AM
Viewed: 9/16/2025 10:16:32 AM
Signed: 9/16/2025 10:17:03 AM
Electronic Record and Signature Disclosure:
Not Offered via Docusign
Jonathan Lait
Jonathan.Lait@paloalto.gov
Director, Planning and Development Services
City of Palo Alto
Security Level: Email, Account Authentication
(None)
Signature Adoption: Pre-selected Style
Using IP Address: 165.225.242.80
Sent: 9/16/2025 10:17:04 AM
Viewed: 9/16/2025 4:40:29 PM
Signed: 9/16/2025 4:40:42 PM
Electronic Record and Signature Disclosure:
Not Offered via Docusign
Ed Shikada
Ed.Shikada@paloalto.gov
Ed Shikada
City of Palo Alto
Security Level: Email, Account Authentication
(None)
Signature Adoption: Pre-selected Style
Using IP Address: 199.33.32.254
Sent: 9/16/2025 4:40:43 PM
Viewed: 9/16/2025 4:50:38 PM
Signed: 9/16/2025 4:51:11 PM
Electronic Record and Signature Disclosure:
Not Offered via Docusign
Signer Events Signature Timestamp
Ed Lauing
Ed.Lauing@paloalto.gov
Security Level: Email, Account Authentication
(None)
Signature Adoption: Pre-selected Style
Using IP Address:
2601:647:6880:a6f0:d01b:2bb3:33c3:f42
Sent: 9/16/2025 4:51:13 PM
Resent: 9/17/2025 7:45:03 AM
Resent: 9/17/2025 1:42:14 PM
Viewed: 9/17/2025 4:07:42 PM
Signed: 9/17/2025 4:08:42 PM
Electronic Record and Signature Disclosure:
Not Offered via Docusign
Mahealani Ah Yun
Mahealani.AhYun@paloalto.gov
Security Level: Email, Account Authentication
(None)
Signature Adoption: Pre-selected Style
Using IP Address:
2601:640:8e80:6e70:493c:d0e6:ea59:a0d5
Sent: 9/17/2025 4:08:44 PM
Viewed: 9/17/2025 4:19:44 PM
Signed: 9/17/2025 4:20:07 PM
Electronic Record and Signature Disclosure:
Not Offered via Docusign
In Person Signer Events Signature Timestamp
Editor Delivery Events Status Timestamp
Agent Delivery Events Status Timestamp
Intermediary Delivery Events Status Timestamp
Certified Delivery Events Status Timestamp
Carbon Copy Events Status Timestamp
Christine Prior
christine.prior@paloalto.gov
Deputy City Clerk
Copa
Security Level: Email, Account Authentication
(None)
Sent: 9/17/2025 4:20:09 PM
Viewed: 9/17/2025 4:49:10 PM
Electronic Record and Signature Disclosure:
Not Offered via Docusign
Witness Events Signature Timestamp
Notary Events Signature Timestamp
Envelope Summary Events Status Timestamps
Envelope Sent Hashed/Encrypted 9/16/2025 8:33:40 AM
Envelope Updated Security Checked 9/17/2025 1:59:24 PM
Certified Delivered Security Checked 9/17/2025 4:19:44 PM
Signing Complete Security Checked 9/17/2025 4:20:07 PM
Completed Security Checked 9/17/2025 4:20:09 PM
Payment Events Status Timestamps