HomeMy WebLinkAboutStaff Report 2506-4898CITY OF PALO ALTO
CITY COUNCIL
Monday, October 06, 2025
Council Chambers & Hybrid
5:30 PM
Agenda Item
10.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. Staff Presentation
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
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.
BACKGROUND
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.
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.
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:
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.
STAKEHOLDER ENGAGEMENT
ENVIRONMENTAL REVIEW
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:
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Ordinance No.
Ordinance of the Council of the City of Palo Alto Repealing Chapter 16.04
and Chapter 16.19 of the Palo Alto Municipal Code and Adopting a New
Chapter 16.04, California Building Code, and a New Chapter 16.19,
California Historical Building Code and California Existing Building Code,
2025 Editions, and Local Amendments and Related Findings
The Council of the City of Palo Alto does ORDAIN as follows:
SECTION 1. Chapter 16.04 of the Palo Alto Municipal Code is hereby amended by
repealing it in its entirety and adopting a new Chapter 16.04 to read as follows:
CHAPTER 16.04
CALIFORNIA BUILDING CODE,
CALIFORNIA CODE OF REGULATIONS, TITLE 24, PART 2, VOLUMES 1 & 2
Sections
16.04.010 2025 California Building Code, Title 24, Part 2, Volumes 1 & 2
adopted and amended.
16.04.020 Cross - References to California Building Code.
16.04.030 Local Amendments.
16.04.040 Adoption of 2025 California Building Code Chapter 1,
Division II – Scope and Administration, Part 1 – Scope and
Application and Part 2 – Administration and Enforcement.
16.04.050 Section 101.1 Title.
16.04.060 Section 101.2.1 Appendices.
16.04.070 Section 101.4 Referenced codes.
16.04.080 Section 103 Code Compliance Agency.
16.04.090 Section 104.2.4.1 Flood hazard area.
16.04.100 Section 104.3.1 Determination of substantially improved or
substantially damaged existing buildings and structures in flood
hazard areas.
16.04.110 Section 105.2 Work exempt from permit.
16.04.120 Section 105.3.2 Time limitation of application.
16.04.130 Section 105.5 Expiration.
16.04.140 Section 106.1 Live loads posted.
16.04.150 Section 109.6 Refunds.
16.04.160 Section 109.7 Re-Inspection fees.
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16.04.170 Section 110.2.1 Preliminary accessibility compliance inspection.
16.04.180 Section 110.3.3 Lowest floor elevation.
16.04.190 Section 111.1 Use and occupancy.
16.04.200 Section 111.3 Temporary occupancy.
16.04.210 Section 111.5 Posting.
16.04.220 Section 113 Means of Appeals.
16.04.225 Section 114 Violations.
16.04.230 Section 115 Stop Work Order.
16.04.235 Section 202 Definitions.
16.04.240 Section 502.1 Address identification.
16.04.250 Reserved
16.04.260 Section 903.2 Automatic sprinkler systems, where required.
16.04.270 Section 903.3.1.1 NFPA 13 sprinkler systems.
16.04.280 Section 903.3.1.2 NFPA 13R sprinkler systems.
16.04.290 Section 903.3.1.3 NFPA 13D sprinkler systems.
16.04.300 Section 903.3.1.3.1 Increase in fire sprinkler design criteria.
16.04.310 Section 903.4.4 Floor control valves.
16.04.320 Section 905.3.1 Height.
16.04.330 Section 907.2.11.2.4 Smoke alarms.
16.04.340 Section 909.20.7 Smoke control systems schedule.
16.04.345 Section 915.6 Maintenance.
16.04.350 Section 1008.3 Illumination required by an emergency electrical system.
16.04.360 Section 1031.2 Where required.
16.04.370 Reserved.
16.04.380 Section 1205.3.4 Roof guards at courts.
16.04.390 Section 1208.6 Dwelling unit and congregate residence superficial floor
area.
16.04.400 Section 1503.2.1 Locations.
16.04.410 Section 1612.1.1 Palo Alto Flood Hazard Regulations.
16.04.420 Section 1613.8 Suspended ceilings.
16.04.430 Reserved
16.04.440 Section 1705.3 Concrete construction.
16.04.450 Section 1803.2 Investigations required.
16.04.460 Section 1803.5.11 Seismic design categories C through F.
16.04.470 Section 1809.7 Prescriptive footings for light-frame construction.
16.04.480 Section 1809.8 Plain concrete footings.
16.04.490 Section 1901.2 Plain and reinforced concrete.
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16.04.500 Section 1905.6.2 Seismic Design C, D, E and F.
16.04.510 SECTION 1906 FOOTINGS FOR LIGHT-FRAME CONSTRUCTION
16.04.520 Section 1906.1 Plain concrete footings.
16.04.530 Section 1907.1 Structural slabs-on-ground
16.04.535 Section 1907.2 Nonstructural slabs-on-ground
16.04.540 Reserved
16.04.550 Reserved
16.04.560 Section 2308.10.4 Braced wall panel construction.
16.04.570 Section 2308.10.5 Alternative bracing.
16.04.580 TABLE 2308.10.1 WALL BRACING REQUIREMENTS.
16.04.590 TABLE 2308.10.3(1) BRACING METHODS.
16.04.600 Section 2308.10.9 Attachment of sheathing.
16.04.610 SECTION 2505 SHEAR WALL CONSTRUCTION.
16.04.620 Reserved
16.04.630 Chapter 31B Public Pools.
16.04.640 Section 3304.1 Excavation and fill.
16.04.010 2025 California Building Code, Title 24, Part 2, Volumes
1 & 2 adopted and amended.
The California Building Code, 2025 Edition, Title 24, Part 2, Volumes 1 & 2 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.
Unless superseded and expressly repealed, references in City of Palo Alto forms,
documents and regulations to the chapters and sections of any former iteration 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. 5564 and No. 5664 of the City of Palo Alto and all other ordinances or parts of
ordinances in conflict herewith are hereby expressly repealed.
Wherever the phrases “California Building Code” or “Building Code” are used in this code
or any ordinance of the City, such phrases shall be deemed and construed to refer and
apply to the California Building Code, 2025 Edition, Title 24, Part 2 of the California Code
of Regulations, as adopted by this chapter.
One (1) copy of the California Building 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.
16.04.020 Cross - References to California Building Code.
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The provisions of this Chapter contain cross-references to the provisions of the California
Building Code, 2025 Edition, in order to facilitate reference and comparison to those
provisions.
16.04.030 Local Amendments.
The provisions of this Chapter shall constitute local amendments to the cross-referenced
provisions of the California Building 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. Where used in this Chapter 16.04, ellipses shall indicate text of the California
Building Code, 2025 Edition, that has been adopted without amendment but is omitted for
brevity.
16.04.040 Adoption of 2025 California Building Code Chapter 1,
Division II – Scope and Administration, Part 1 – Scope and
Application and Part 2 – Administration and Enforcement
Chapter 1, Division II, Parts 1 – Scope and Application and Part 2 – Administration and
Enforcement of the 2025 California Building Code are adopted in their entirety, as
amended herein.
16.04.050 Section 101.1 Title.
Section 101.1 of the California Building Code is amended to read:
101.1 Title. These regulations shall be known as the Building Code of City of Palo
Alto, hereinafter referred to as “this code”.
16.04.060 Section 101.2.1 Appendices.
Section 101.2.1 of the California Building Code is amended to read:
The following Appendix chapters and sections of the California Building Code,
2025 Edition, are adopted and hereby incorporated in this Chapter by reference
and made a part hereof the same as if fully set forth herein:
A. Appendix I – Patio Covers (Sections I101 through I105)
B. Appendix J – Grading (Section J109.4 Drainage across property lines)
C. Appendix Q – Emergency Housing (Sections Q101 through Q110)
16.04.070 101.4 Referenced codes.
Section 101.4 of the California Building Code is amended to add subdivisions 101.4.9
through 101.4.13, as follows:
101.4 Referenced codes. The other codes listed in Section 101.4.1 through
101.4.13 and referenced elsewhere in this code shall be considered part of the
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requirements of this code to the prescribed extent of each such reference.
[. . .]
101.4.9 Historical Buildings. The provisions of the California Historical
Code shall apply to the alteration, addition, and relocation to qualified
historical buildings or properties.
101.4.10 Electrical. The provisions of the California Electrical
Code shall apply to the installation of electrical systems, including
alterations, repairs, replacement, equipment, appliances, fixtures,
fittings and appurtenances thereto.
101.4.11 Residential Buildings. The provisions of the California
Residential Code shall apply to all matters governing the design and
construction of detached, one- and two-family dwellings, townhouses
not more than three stories and separate means of egress, and
structural accessory thereto.
101.4.12 Green Building Standards. The provisions of the California
Green Building Standards Code shall apply to all matters governing the
"green building" related planning, design construction, operation, use
and occupancy of newly constructed and altered buildings.
101.4.13 International Swimming and Spa Code. The provisions of the
2024 International Swimming and Spa Code shall apply to the installation
of private swimming pools and spa facilities.
16.04.080 Section 103 Code Compliance Agency.
Section 103 of the California Building Code is amended to read:
103.1 Creation of enforcement agency. The Planning and Development
Services Department is hereby created and the official in charge thereof shall be
known as the chief building official, also referred to as building official or code
official. The function of the department shall be the implementation,
administration, and enforcement of the provisions of this code.
103.2 Appointment. The building official shall be appointed by the chief
appointing authority of the jurisdiction.
103.3 Deputies. In accordance with the prescribed procedures of this jurisdiction
and with the concurrence of the appointing authority, the building official shall
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have the authority to appoint assistant chief building officials, manager
supervisors, and other technical officers, inspectors, and other employees. Such
employees shall have powers as delegated by the building official.
16.04.090 Section 104.2.4.1 Flood hazard area.
Section 104.2.4.1 of the California Building Code is amended to read:
104.2.4.1 Flood hazard areas. The city engineer or designee shall not grant
modifications to any provision required in flood hazard areas as established by
Section 1612.3 unless a determination has been made that:
1. A showing of good and sufficient cause that the unique
characteristics of the size, configuration or topography of the site
render the elevation standards of Section 1612 inappropriate.
2. A determination that failure to grant the variance would result in
exceptional hardship by rendering the lot undevelopable.
3. A determination that the granting of a variance will not result in
increased flood heights, additional threats to public safety,
extraordinary public expense, cause fraud on or victimization of the
public, or conflict with existing laws or ordinances.
4. A determination that the variance is the minimum necessary to
afford relief, considering the flood hazard.
5. Submission to the applicant of written notice specifying the difference
between the design flood elevation and the elevation to which the
building is to be built, stating that the cost of flood insurance will be
commensurate with the increased risk resulting from the reduced
floor elevation, and stating that construction below the design flood
elevation increases risks to life a property.
16.04.100 Section 104.3.1 Determination of substantially improved or
substantially damaged existing buildings and structures in flood
hazard areas.
Section 104.3.1 of the California Building Code is amended to read:
104.3.1 Determination of substantially improved or substantially damaged
existing buildings and structures in flood hazard areas. For applications for
reconstruction, rehabilitation, repair, alteration, addition or other improvement
of existing buildings or structures located in flood hazard areas, the city engineer
or designee shall determine if the proposed work constitutes substantial
improvement or repair of substantial damage. Where the city engineer or
designee determines that the proposed work constitutes substantial
improvement or repair of substantial damage, and where required by this code,
the city engineer or designee shall require the building to meet the requirements
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of Section 1612 of the California Building Code, Section R306 of the California
Residential Code as amended, or Palo Alto Municipal Code 16.52 Flood Hazard
Regulations, whichever is more stringent.
16.04.110 Section 105.2 Work exempt from permit.
Section 105.2 of the California Building Code is amended to read:
105.2 Work exempt from permit. Exemptions from permit requirements of this
code shall not be deemed to grant authorization for any work to be done in any
manner in violation of the provisions of this code or any other laws or
ordinances of this jurisdiction. Permits shall not be required for the following:
Building:
1. One-story detached accessory structures used as tool and storage
sheds, playhouses and similar uses, provided that the floor area
does not exceed 120 square feet (11.15 m2). It is permissible that
these structures still be regulated by Section 710A, despite
exemption from permit.
2. Wood fences, other than swimming pool barriers, not over 7 feet
(2134 mm) high or concrete or masonry wall not over 4 feet
(1219 mm) high when not subject to specific city of Palo Alto
Planning and Zoning regulations.
3. Retaining walls that are not over 4 feet (1219 mm) in height
measured from the bottom of the footing to the top of the wall,
unless supporting a surcharge or impounding Class I, II or IIIA
liquids.
4. Oil derricks.
5. Water tanks supported directly on grade if the capacity is not
greater than 5,000 gallons (18 925 L) and the ratio of height to
diameter or width is not greater than 2:1.
6. Sidewalks and driveways not more than 30 inches (762 mm)
above adjacent grade and not over any basement or story below
and are not part of an accessible route, accessible parking
spaces, or required exits.
7. Wood decks not over 30 inches above surrounding grade or
finishes, not attached to a structure, or serving any part of the
means of egress.
8. Painting, papering, tiling, carpeting, cabinets, counter tops and
similar finish work.
9. Temporary motion picture, television and theater stage sets and
scenery.
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10. Prefabricated swimming pools accessory to a Group R-3
occupancy that are less than 24 inches deep, do not exceed
5,000 gallons and are installed entirely above ground.
11. Shade cloth structures constructed for nursery or agricultural
purposes, not including service systems.
12. Swings and other playground equipment accessory to detached
one- and two- family dwellings and not considered a public
playground.
13. Window awnings supported by an exterior wall that do not
project more than 54 inches (1,372 mm) from the exterior wall
and do not require additional support of Group R-3 and U
occupancies.
14. Nonfixed and movable fixtures, cases, racks, counters and
partitions not over 5 feet 9 inches (1753 mm) in height.
Electrical:
1. Repairs and maintenance: Minor repair work, including the
replacement of lamps or the connection of approved portable
electrical equipment to approved permanently installed
receptacles.
2. Radio and television transmitting stations: The provisions of
this code shall not apply to electrical equipment used for radio
and television transmissions, but do apply to equipment and
wiring for a power supply and the installations of towers and
antennas.
3. Temporary testing systems: A permit shall not be required for
the installation of any temporary system required for the testing
or servicing of electrical equipment or apparatus.
4. Temporary decorative lighting: Exterior listed plug-in decorative
lighting plugged into a waterproof GFCI receptacle outlet.
5. Replacement of overcurrent devices: Replacement of any
overcurrent device less than 1,200 amps of the same capacity in
the same location.
6. Wiring for temporary theatre, motion picture or television stage
sets.
7. Electrical wiring, devices, appliances, apparatus, or equipment
operating at less than 25 volts and not capable of supplying more
than 50 watts of energy.
Gas:
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1. Portable heating appliance.
2. Replacement of any minor part that does not alter approval of
equipment or make such equipment unsafe.
Mechanical:
1. Portable heating appliance.
2. Portable ventilation equipment.
3. Portable cooling unit.
4. Steam, hot or chilled water piping within any
heating or cooling equipment regulated by this code.
5. Replacement of any part that does not alter its listing/approval
or make it unsafe.
6. Portable evaporative cooler.
7. Self-contained refrigeration system containing 10 pounds (4.54
kg) or less of refrigerant and actuated by motors of 1 horsepower
(0.75 kW) or less.
Plumbing:
1. The stopping of leaks in drains, water, soil, waste or vent pipe,
provided however, that if any concealed trap, drain pipe, water, soil,
waste or vent pipe becomes defective and it becomes necessary to
remove and replace the same with new material, such work shall be
considered as new work and a permit shall be obtained and
inspection made as provided in this code.
2. The clearing of stoppages or the repairing of leaks in pipes, valves or
fixtures and the removal and reinstallation of water closets, provided
that such repairs do not involve or require the replacement or
rearrangement of valves, pipes or fixtures.
[. . .]
16.04.120 Section 105.3.2 Time limitation of application.
Section 105.3.2 of Chapter 1 of the California Building Code is amended to read:
105.3.2 Time limitation of application. An accepted application for a permit for
any proposed work shall be deemed to have been abandoned twelve (12)
months after the date of filing, unless such application has been pursued in good
faith or a permit has been issued; except that the building official is authorized
to grant one or more extensions and/or reactivations for additional periods not
exceeding ninety (90) days each. The extension shall be required in writing and
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justifiable cause demonstrated.
16.04.130 Section 105.5 Expiration.
Section 105.5 of Chapter 1 of the California Building Code is amended to read:
105.5 Expiration. Every permit issued shall become invalid unless the work on
the site authorized by such permit is commenced within twelve (12) months after
its issuance, or if the work authorized on the site by such permit is suspended or
abandoned for a period of twelve (12) months after the time the work is
commenced. For the purpose of this section, failure to progress a project to the
next level of required inspection, as determined by the chief building official,
shall be deemed to be suspension of the work.
The chief building official or designee is authorized to grant, in writing, no more
than three extensions and reactivations of permits that would otherwise expire
or reactivations of expired permits, for periods not more than 180 days each and
may require:
1. that construction documents be revised to partially or fully to comply
with current codes and ordinances; and
2. payment of fees; and
3. payment of a penalty pursuant to Chapter 16.62 of the Palo Alto
Municipal Code.
Extensions and reactivations shall be requested in writing and justifiable cause
demonstrated. Additional extensions or reactivations beyond three may only be
granted with the approval of the City Council.
105.5.1 Term limit for permits. All work associated with a building permit must
be completed, and final inspection issued, within forty-eight (48) months of
permit issuance. Once a term limit has been exhausted without obtaining an
approved final inspection the permit will automatically become void. The chief
building official or designee is authorized to allow a new permit application to be
applied for the original scope of work and may require:
1. that construction documents be revised to partially or fully to comply
with current codes and ordinances; and
2. payment of partial or all plan review and permit fees; and
3. payment of a penalty pursuant to Chapter 16.62 of the Palo Alto
Municipal Code.
16.04.140 Section 106.1 Live loads posted.
Section 106.1 of the California Building Code is amended to read:
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106.1 Live Loads Posted. In commercial, institutional or industrial buildings, for
each floor or portion thereof designed for live loads exceeding 50 psf (2.40
kN/m2), such design live loads shall be conspicuously posted by the owner or
the owner's authorized agent in that part of each story in which they apply,
using durable signs. It shall be unlawful to remove or deface such notices.
16.04.150 Section 109.6 Refunds.
Section 109.6 of Chapter 1 of the California Building Code is amended to read:
109.6 Refunds. The building official or designee may authorize the refund of any
fee paid hereunder which was erroneously paid or collected. The building official
or designee may authorize the refund of not more than eighty percent (80%) of
the Permit Fee paid when no work has occurred under a permit issued pursuant
to this Chapter. The building official or designee may authorize the refund of not
more than eighty percent (80%) of the Plan Review Fee paid when a permit
application is withdrawn or canceled before any plan review work has started.
16.04.160 Section 109.7 Re-Inspection fees.
Section 109.7 of Chapter 1 of the California Building Code is added to read:
109.7 Re-Inspection Fees. A re-inspection fee may be assessed/authorized
by the building official or designee for each occurrence as itemized below:
1. inspection record card is not posted or otherwise available on the
work site; or
2. approved plans are not readily available for the inspector at the time
of inspection; or
3. inspector is unable to access the work at the time of inspection; or
4. when work has substantially deviated from the approved plans
without the prior approval of required revision; or
5. when work for which an inspection is requested is not ready for
inspection; or
6. when required corrections noted during prior inspections have not
been completed.
When a re-inspection fee is assessed, additional inspection of the work will not be
performed until the fee has been paid.
16.04.170 Section 110.2.1 Preliminary accessibility compliance inspection.
Section 110.2.1 of Chapter 1 of the California Building Code is added to read:
110.2.1 Preliminary accessibility compliance inspection. Before issuing a permit,
the building official or designee is authorized to examine or cause to be examined
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the pre- construction accessibility compliance conditions of the buildings,
structures, and sites for which an application has been filed.
16.04.180 Section 110.3.3 Lowest floor elevation.
Section 110.3.3 of Chapter 1 of the California Building Code is amended to read:
110.3.3 Lowest floor elevation. In flood hazard areas, upon placement of the
lowest floor, including the basement, and prior to further vertical construction,
the elevation certification shall be submitted to City Public Works Engineering for
inspection approval prior to foundation inspection by City Building Inspection
staff.
16.04.190 Section 111.1 Use and occupancy.
Section 111.1 of Chapter 1 of the California Building Code is amended to read:
111.1 Use and occupancy. A building or structure shall not be used or occupied,
and a change in the existing occupancy of a building or structure or portion
thereof shall not be made, until the chief building official has issued a certificate
of occupancy therefor as provided herein. Issuance of a certificate of occupancy
shall not be construed as an approval of a violation of the provisions of this code
or of other ordinances of the jurisdiction.
Exception: Certificates of occupancy are not required or issued for:
1. Work exempted from permits under Section 105.2
2. Group R – Division 3 and Group U occupancies located on a single-family
residential/agricultural lot.
3. Non-residential “core and shell” or similar construction (exterior
envelope and structural framework) without finalized tenant
improvement(s).
4. Site development without a building or buildings as defined in section
202.
111.1.1 Change of occupancy or tenancy. Each change of occupancy, official
name or tenancy of any building, structure, or portion thereof, shall require a
new certificate of occupancy, whether or not any alterations to the building are
required by this code.
Before any application for a new certificate of occupancy is accepted, a fee
shall be paid by the applicant to cover the cost of the inspection of the
building required by the change of occupancy or tenancy.
When application is made for a new certificate of occupancy under this
section, the building official and fire chief shall cause an inspection of the
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building to be made. The inspector(s) shall inform the applicant of those
alterations necessary, or if none are necessary, and shall submit a report of
compliance to the building official.
If a portion of any building does not conform to the requirements of this code
for a proposed occupancy, that portion shall be made to conform. The
building official may issue a new certificate of occupancy without requiring
compliance with all such requirements if it is determined that the change in
occupancy or tenancy will result in no increased hazard to life or limb, health,
property, or public welfare.
16.04.200 Section 111.3 Temporary occupancy.
Section 111.3 of Chapter 1 of the California Building Code is amended to read:
111.3 Temporary occupancy. The building official or designee is authorized to
issue a temporary certificate of occupancy before the completion of the entire
work covered by the permit, or as otherwise required, provided that such portion
or portions shall be occupied safely. The building official or designee shall set a
time period during which the temporary certificate of occupancy is valid.
16.04.210 Section 111.5 Posting.
Section 111.5 of Chapter 1 of the California Building Code is added to read:
111.5 Posting. The temporary certificate of occupancy or certificate of occupancy
shall be posted in a conspicuous, readily accessible place in the building or
portion of building to be occupied and shall not be removed except when
authorized by the building official.
16.04.220 Section 113 Means of Appeals.
Section 113 of Chapter 1 of the California Building Code is amended to read:
SECTION 113 MEANS OF APPEALS
113.1 Appeals. A person requesting an order, decision, or determination made
by the building official relative to the California Building Code (as amended) may
appeal such order,
decision or determination by completing a request for hearing form and
returning it to the City within thirty calendar days from the date of the decision,
together with all applicable fees authorized by the City’s Municipal Fee Schedule.
A request for hearing shall be based on a claim that the true intent of the
California Building Code (as amended) or the rules legally adopted thereunder
have been incorrectly interpreted, the provisions of this code do not fully apply
or an equivalent or better form of construction is proposed.
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(a) The person requesting the hearing shall be notified of the time and place set
for the hearing at least ten days prior to the date of the hearing.
(b) If the building official submits an additional written report concerning the
decision to hearing officer for consideration at the hearing, then a copy of this
report shall also be served on the person requesting the hearing at least five days
prior to the date of the hearing.
(c) The appeal procedure set out in this Section 113.1 et seq. does not apply to:
(1) decisions by the building official or any other City official related to
administrative enforcement actions taken under Chapter 1.12 or Chapter 1.16
of the Palo Alto Municipal Code; (2) decisions by the City to enforce the
California Building Code under any provision of criminal law; or (3) any other
action taken by the City that specifies its own appeal procedure.
113.2 Hearing Officer. The building official shall designate a hearing officer for
the appeal hearing. The hearing officer may consist of one person or a body of
people. The hearing officer shall not be the building official or any directly
subordinate employees.
(a) The hearing officer does not have authority to waive requirements of the
California Building Code (as amended) or interpret the administration of the
Code.
(b) The hearing officer does not have authority to issue an order, decision, or
determination on his or her own authority. This includes the issuance or
amendment of building permits.
(c) The hearing officer shall be qualified by experience and training to pass on
matters pertaining to building construction.
113.3 Hearing procedures.
(a) No appeal hearing before a hearing officer shall be noticed unless the
applicable fee(s) been paid in advance in accordance with Section 113.1.
(b) A hearing before the hearing officer shall be set for a date that is not less
than fifteen days and not more than sixty days from the date that the request for
hearing is filed in accordance with the provisions of this chapter. The party
requesting the hearing may request one continuance for any reason, provided
that the hearing officer is given the request for continuance at least forty-eight
hours in advance of the scheduled hearing and that the deferred hearing shall
not be deferred more than ninety days after the request for hearing was made.
A request for continuance made less than forty-eight hours before the scheduled
hearing may be granted by the hearing officer based upon exigency only. The
parties may stipulate to an alternative hearing date schedule outside of these rules upon
a finding of good cause and approval from the hearing officer.
(c) At the hearing, the appellant shall be given the opportunity to testify and to
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present evidence and cross-examine witnesses concerning the appeal. The
appellant may appear personally or through a representative. Prehearing
discovery is not authorized, but subpoena of witnesses and documents shall be
permitted as authorized by law. The hearing officer may conduct the hearing
informally, both as to rules of procedure and admission of evidence, in any
manner which will provide a fair hearing.
(d) The failure of the appellant to appear at the hearing or, in the alternative, to
present written or demonstrative evidence shall constitute the dismissal of the
appeal with prejudice.
(e) The administrative record and any additional report submitted by the
building official shall constitute presumptive evidence of the respective facts
contained in those documents. The building official shall have the same rights as
the appellant to testify, present evidence, and cross-examine witnesses
concerning the appeal.
(f) The hearing officer may continue the hearing and request additional
information from the building official or appellant prior to issuing a written
decision.
113.4 Hearing Officer’s decision.
(a) After considering all the testimony and evidence submitted at the hearing,
the hearing officer shall issue a written decision to uphold or amend the building
official’s order, decision or determination, and the reasons for that decision. The
decision of the hearing officer shall be issued within thirty days following
completion of the hearing. The decision of the hearing officer shall be final upon
service on the appellant, subject only to judicial review as allowed by law.
(b) The hearing officer shall consider any written or oral evidence submitted at
the hearing consistent with ascertainment of the facts regarding the issues of the
appeal.
(c) If the hearing officer determines that the building official’s order, decision,
or determination should not be upheld as originally given, then the hearing
officer shall direct the building official to make any amendments or changes
necessary to implement the hearing officer’s decision. The hearing officer shall
also give the building official a reasonable deadline to complete such actions.
(d) The appellant shall be served with a copy of the hearing officer's written
decision within ten calendar days following its issuance.
16.04.225 Section 114 Violations.
Section 114 of Chapter 1 of the California Building Code is amended to read:
SECTION 114 VIOLATIONS
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114.1 Unlawful acts. 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, 1.16 and 16.62 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, in his or her sole discretion, 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.
[. . .]
114.5 Criminal enforcement authority. The employee positions designated in this
section are authorized to exercise the authority provided in California Penal Code
section 836.5 for violations of this Chapter. The designated employee positions are: (1)
chief building official, (2) assistant chief building official, (3) building inspection manager, (4)
Building Inspector or Building Inspector Specialist as designated by the chief building official
and
(5) code enforcement officer.
16.04.230 Section 115 Stop Work Order.
Section 115 of Chapter 1 of the California Building Code is amended to read:
SECTION 115 STOP WORK ORDER
115.1 Authority. Whenever the building official finds any work regulated by this
code being performed in a manner that is contrary to the provisions of this code,
without a permit, beyond the scope of the issued permit, in violation of the Palo
Alto Municipal Code or Zoning Ordinance, or dangerous or unsafe, the building
official is authorized to issue a stop work order.
115.2 Issuance. The stop work order shall be in writing and shall be posted in a
visible location near the location where the work is being conducted. If the owner
or owner’s agent is not on site at the time of posting, a notice advising the
reasons for the stop work order issuance shall be hand delivered or mailed first-
class to the owner of the property involved, or to the owner’s agent, or to the
person doing the work. Upon issuance of a stop work order, the cited work shall
immediately cease. The stop work order shall state the reason for the order, the
conditions under which the cited work will be permitted to resume, and the
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name and contact information of the official or agency issuing the order.
115.3 Emergencies. Where an emergency exists, the building official shall not be
required to give a written notice prior to stopping the work.
115.4 Unlawful continuance. Any person who continues to engage in any work
after having been served with a stop work order, except such work as that person
is directed to perform to remove a violation or unsafe condition, shall be guilty
of a misdemeanor.
115.5 Removal of posted stop work order. Any person who removes a posted
stop work order without written consent of the Building Official shall be guilty of
a misdemeanor.
115.6 Response required. Violators receiving a stop work order are required to
respond to Planning and Development Services within five (5) business days of
the issued notice to receive instructions on how to rescind the order.
115.7 Permit application required. A building permit application with
construction or demolition plans and supporting (structural calculations, energy
calculations, accessible access) documents must be submitted for approval
within twenty (20) working days following response to Planning and
Development Services. Plans will be reviewed and correction letters issued or
permit application approved by Planning and Development Services. A response
to any correction letter must be submitted within fifteen (15) working days of
the date of the correction letter. Ten (10) working days will be required to review
this second submission and a permit approved for issuance. Permits ready for
issuance must be issued within five (5) working days thereafter. All construction
must be inspected as work progresses and signed off by all (affected)
departments within the permit term limits outlined in Section 105.5.1 or as
determined by the building official.
115.8 Stop work order penalty. The Building Official may impose Stop Work
Order Penalties in accordance with Section 1.14.050 of this code and/or other
applicable law.
16.04.235 Section 202 Definitions.
Section 202 of Chapter 2 of the California Building Code is amended to read:
[…]
FLOOR AREA, GROSS. The floor area within the inside perimeter of the exterior walls of the
building under consideration, exclusive of vent shafts and courts, without deduction for
corridors, stairways, ramps, closets, the thickness of interior walls, columns or other
features. The floor area of a building, or portion thereof, not provided with surrounding
exterior walls shall be the usable area under the horizontal projection of the roof or floor
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above. The gross floor area shall not include shafts with no openings or interior courts. For
the purposes of Title 18 (Zoning), the definition of “gross floor area” in Section 18.04.030
shall apply.
[…]
FLOOR AREA, NET. The actual occupied area not including unoccupied accessory areas such
as corridors, stairways, ramps, toilet rooms, mechanical rooms and closets. For the
purposes of Title 18 (Zoning), the definition of “net floor area” in Section 18.04.030 shall
apply.
[…]
16.04.240 Section 502.1 Address identification.
Section 502.1 of Chapter 5 of the California Building Code is amended to read:
502.1 Address identification. New and existing buildings shall be provided with approved
address identification. The address identification shall be legible and placed in a position
that is visible from the street or road fronting the property. Address identification
characters shall contrast with their background. Address numbers shall be Arabic numbers
or alphabetical letters. Numbers shall not be spelled out. Each character shall be not less
than 4 inches (102 mm) high with a minimum stroke width of ½ inch (12.7 mm) unless
required to be larger by Section 502.1.2. When required by the fire code official, address
identification shall be provided in additional approved locations to facilitate emergency
response. Where access is by means of a private road and the building address cannot be
viewed from the public way, a monument, pole or other approved sign or means shall be
used to identify the structure. Address numbers shall be maintained.
502.1.1 Address illumination. Address identification required by Section 502.1
shall be illuminated.
502.1.2 Address identification size. Address numbers and letters shall be sized as
follows:
1. When the structure is between thirty-six (36) and fifty (50) feet from the
road or other emergency means of access, a minimum of one-half inch
(0.5") stroke by six inches (6") high is required.
2. When the structure is fifty (50) or more feet from the road or other
emergency means of access, a minimum of one inch (1") stroke by nine
inches (9") high is required.
16.04.250 Reserved.
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16.04.260 Section 903.2 Automatic sprinkler systems, where required.
Section 903.2 of Chapter 9 the California Building Code is amended to read:
903.2 Automatic sprinkler systems, where required. Approved automatic
sprinkler systems in new buildings and structures and in existing modified
buildings and structures, shall be provided in the locations described in this
section. Automatic fire sprinklers shall be installed per the requirements set forth
in Sections 903.2.1 through 903.2.18 and as follows, whichever is the more
restrictive:
1. An automatic sprinkler system shall be provided throughout all new
buildings and structures.
Exception: New non-residential occupancies, buildings or structures
that do not exceed 350 square feet of building area and contain no
plumbing fixtures.
2. An automatic sprinkler system shall be provided throughout all
existing buildings when modifications are made that create
conditions described in Sections 903.2.1 through 903.2.18, or that
create an increase in fire area to more than 3600 square feet or when
the addition is equal or greater than 50% of the existing building
square footage whichever is more restrictive.
3. An automatic sprinkler system is required in basements when any of
the following occur:
a. New basements used for storage, utility, occupancy or habitable
space regardless of size.
b. Existing basements that are altered for the use of storage, utility,
occupancy, or habitable space regardless of size.
c. Existing basements that are expanded by more than 50%. If the
addition or alteration is only the basement, then only the basement is
required to be fire sprinkler protected.
4. An automatic sprinkler system shall be installed throughout when
either the roof structure and/or exterior wall structure have been
removed, altered, and/or replaced by at least 50% of the existing
structure.
5. An automatic sprinkler system shall be installed throughout when any
change in use or occupancy creates a more hazardous fire/life-safety
condition, as determined by the fire code official.
6. All new trash enclosures regardless of size require installation of fire
sprinklers (nonresidential only).
Exception: A fire extinguishing system will not apply when all of the
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following conditions are met:
a. The trash enclosure including the door(s) and roof are constructed
of noncombustible materials.
b. The trash enclosure is a stand-alone structure, be a minimum of 20
feet away from adjacent buildings and 10-feet away from property
line(s); and
c. The enclosure is used exclusively for waste garbage, recyclables,
and organize waste/composting contained within the approved trash
bins/containers. No outdoor storage is permitted within the trash
enclosure.
7. Phone booths and pods when installed in a building equipped with a
fire sprinkler system (nonresidential only).
8. Fume hoods when installed in a building equipped with a fire
sprinkler system (nonresidential only).
Exception: Spaces or areas in telecommunications buildings used
exclusively for telecommunications equipment, associated electrical
power distribution equipment, batteries and standby engines,
provided that those spaces or areas are equipped throughout with an
automatic smoke detection system in accordance with Section 907.2
and are separated from the remainder of the building by not less than
1-hour fire barriers constructed in accordance with Section 707 or not
less than 2-hour horizontal assemblies constructed in accordance
with Section 711, or both.
16.04.270 Section 903.3.1.1 NFPA 13 sprinkler systems.
Section 903.3.1.1 of Chapter 9 of the California Building Code is amended to read:
903.3.1.1 NFPA 13 sprinkler systems. Where the provisions of this code require
that a building or portion thereof be equipped throughout with an automatic
sprinkler system in accordance with this section, sprinklers shall be installed
throughout in accordance with NFPA 13 and State and local requirements except
as provided in Section 903.3.1.1.
1. For new buildings having no designated use or tenant, the minimum
sprinkler design density shall be Ordinary Hazard Group II/1500
square feet.
2. Where future use or tenant is determined to require a higher density,
the sprinkler system shall be augmented to meet the higher density.
3. Light hazard occupancy shall be hydraulically designed to a 1500
square feet most remote area or as required by the fire code official
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4. Laboratory areas within buildings shall be hydraulically designed to
Ordinary Hazard II density.
5. Parking areas where mechanical vehicle storage equipment is used
shall be hydraulically designed to Extra Hazard II density.
6. In multi-residential apartments, townhomes, and condominiums.
7. In new commercial buildings that will have power micro mobility devices,
the fire sprinkler system shall be designed to Ordinary Hazard II.
8. Energy Storage Systems in nonresidential buildings shall comply with one
of the following:
a. ESS units with a maximum stored energy capacity of 50 kWh, as
described in Section 1207.5.1 shall be designed with a minimum
density of 0.40 gpm/ft2 (1.14 L/min) based over the area of the room
or 2,500 square-foot design area, whichever is smaller.
b. ESS units (groups) exceeding 50 kWh shall use a density based on large-
scale fire testing complying with Section 1207.1.7.
16.04.280 Section 903.3.1.2 NFPA 13R sprinkler systems.
Section 903.3.1.2 of Chapter 9 of the California Building Code is amended to read:
903.3.1.2 NFPA 13R sprinkler systems. Where allowed in buildings of Group R
Occupancies, automatic sprinkler systems shall be installed throughout in
accordance with NFPA 13 and State and local standards.
16.04.290 Section 903.3.1.3 NFPA 13D sprinkler systems.
Section 903.3.1.3 of Chapter 9 of the California Building Code is amended to read:
903.3.1.3 NFPA 13D sprinkler systems. Where allowed, automatic sprinkler
systems installed in one-and two-family detached dwellings shall be installed
throughout in accordance with NFPA 13D and State and local standards. Fire
sprinkler protection is required under rear covered patios extending 4 feet
perpendicular from the exterior of the structure.
16.04.300 Section 903.3.1.3.1 Increase in fire sprinkler design criteria.
Section 903.3.1.3.1 of Chapter 9 of the California Building Code is added to read:
903.3.1.3.2 Increase in fire sprinkler design criteria. Structures determined by
the fire code official to have higher firefighting hazardous conditions or located
in the Wildland- Urban Interface Fire Area shall have an increase in fire sprinkler
design criteria as determined by the fire code official.
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16.04.310 Section 903.4.4 Floor control valves.
Section 903.4.4 of Chapter 9 of the California Building Code is amended to read:
903.4.4 Floor control valves. Automatic sprinkler systems serving buildings two
(2) or more stories in height shall have valves installed so as to control the system
independently on each floor including basements.
16.04.320 Section 905.3.1 Height.
Section 905.3.1 of the California Building Code is amended to read:
905.3.1 Height. A Class I standpipe system shall be installed in buildings where
the roof edge/parapet is greater than 27 feet above the lowest level of fire
apparatus access roadway and in below grade levels.
16.04.330 Section 907.2.11.2.4 Smoke alarms.
Section 907.2.11.2.4 of the California Building Code is amended to read:
907.2.11.2.4 Smoke alarms. Smoke alarms shall be tested and maintained in
accordance with the manufacturer's instructions. Smoke alarms that no longer
function or are 10 years or older from the date of installation shall be replaced.
16.04.340 Section 909.20.7 Smoke control systems schedule.
Section 909.20.7 is added to the California Building Code to read as follows:
909.20.7 Smoke control systems schedule. A routine maintenance and
operational testing program shall be initiated immediately after the smoke
control system has passed the acceptance tests. A written schedule for routine
maintenance and operational testing shall be established and both shall occur at
least annually.
16.04.345 Section 915.6 Maintenance
Section 915.6 of the California Building Code is amended to read:
915.6 Maintenance. Carbon monoxide alarms and carbon monoxide detection
systems shall be maintained in accordance with NFPA 72. Carbon monoxide
alarms and carbon monoxide detectors that become inoperable or begin
producing end-of-life signals or are 10 years or older shall be replaced.
16.04.350 Section 1008.3 Illumination required by an emergency electrical system.
Section 1008.3 of the California Building Code is amended to read as follows:
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1008.3 Illumination required by an emergency electrical system. In the event of
power supply failure, an emergency electrical system shall automatically
illuminate all of the following areas:
1. In rooms or spaces that require two or more exits or access to exits:
1.1 Aisles.
1.2 Corridors.
1.3 Exit access stairways and ramps.
2. In buildings that require two or more exits or access to exits:
2.1 Interior exit access stairways and ramps.
2.2 Interior and exterior exit stairways and ramps.
2.3 Exit passageways.
2.4 Vestibules and areas on the level of discharge used for exit discharge in
accordance with Section 1028.2.
2.5 Exterior landings as required by Section 1010.1.5 for exit doorways that
lead directly to the exit discharge.
2.6 Group I-2 exit discharge stairways, ramps, aisles, walkways and escalators
leading to a public way or to a safe dispersal area in accordance with Section
1028.5.
3. In other rooms and spaces:
3.1. Electrical equipment rooms.
3.2. Fire command centers.
3.3. Fire pump rooms.
3.4. Generator rooms.
3.5. Public restrooms.
16.04.360 Section 1031.2 Where required.
Section 1031.2 of Chapter 10 of the California Building Code is amended to read:
1031.2 Where required. In addition to the means of egress required by this chapter,
emergency escape and rescue openings shall be provided in Group R occupancies.
Basements and sleeping rooms below the fourth story above grade plane shall
have not fewer than one emergency escape and rescue opening in accordance
with this section. Where basements contain one or more sleeping rooms, an
emergency escape and rescue opening shall be required in each sleeping room
but shall not be required in adjoining areas of the basement. Such openings shall
open directly into a public way or to a yard or court that opens to a public way or
to an egress balcony that leads to a public way.
Exceptions:
1. In Group R-1 and R-2 occupancies constructed of Type I, Type IIA,
Type IIIA or Type IV construction equipped throughout with an
approved automatic sprinkler system in accordance with Section
903.3.1.1.
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2. Group R-2.1 occupancies meeting the requirements for delayed
egress in accordance with Section 1010.2.13 may have operable
windows that are breakable in sleeping rooms permanently
restricted to a maximum of 4-inch open position.
3. Emergency escape and rescue openings are not required from
basements or sleeping rooms that have an exit door or exit access
door that opens directly into a public way or to a yard, court or
exterior egress balcony that leads to a public way.
4. Storm shelters and basements used only to house mechanical
equipment not exceeding a total floor area of 200 square feet
(18.58 m2)
16.04.370 Reserved.
16.04.380 Section 1205.3.4 Roof guards at courts.
Section 1205.3.4 of Chapter 12 of the California Building Code is added to read:
1205.3.4 Roof guards at courts. Roof openings into courts where not bounded
on all sides by walls shall be protected with guardrails. The top of the guards shall
not be less than 42 inches in height. Required guards shall not have openings that
allow passage of a sphere twelve inches (12) in diameter from the walking surface
to the required guard height.
Exception: Where the roof opening is greater than 600 square feet in area.
16.04.390 Section 1208.6 Dwelling unit and congregate residence superficial floor
area.
Section 1208.6 of Chapter 12 of the California Building Code is added to read:
1208.6 Dwelling unit and congregate residence superficial floor area. Every
dwelling unit and congregate residence shall have at least one room which shall
have not less than 120 square feet of superficial floor area. Every room which is
used for both cooking and living or both living and sleeping purposes shall have
not less than 144 square feet of superficial floor area. Every room used for
sleeping purposes shall have not less than 70 square feet of superficial floor area.
When more than two persons occupy a room used for sleeping purposes the
required superficial floor area shall be increased at the rate of 50 square feet for
each occupant in excess of two. Guest rooms with cooking shall contain the
combined required superficial areas of a sleeping and a kitchen, but not less than
144 square feet. Other habitable rooms shall be not less than 70 square feet.
Notwithstanding any provision of this Section, children under the age of six shall
not be counted for purposes of determining whether a family with minor children
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complies with the provisions of this Code.
For the purposes of this section, "superficial floor area" means the net floor area
within the enclosing walls of the room in which the ceiling height is not less than
seven feet six inches, excluding built-in equipment such as wardrobes, cabinets,
kitchen units, or fixtures which are not readily removable.
16.04.400 Section 1503.2.1 Locations.
Section 1503.2.1 of Chapter 15 of the California Building Code is amended to read:
1503.2.1 Locations. Flashing shall be installed at wall and roof intersections,
gutters, wherever there is a change in roof slope or direction, and around roof
openings. Where flashing is of metal, the metal shall be corrosion resistant with
a thickness of not less than
0.019 inches (0.483 mm) (e.g. no. 26 galvanized sheet) and shall be primed and
painted.
16.04.410 Section 1612.1.1 Palo Alto Flood Hazard Regulations.
Section 1612.1.1 of Chapter 16 of the California Building Code is added to read:
1612.1.1 Palo Alto Flood Hazard Regulations. Notwithstanding the provisions of
Section 1612.1, all construction or development within a flood hazard area(areas
depicted as a Special Flood Hazard Area on Flood Insurance Rate Maps published
by the Federal Emergency Management Agency) shall comply with the City of
Palo Alto Flood Hazard Regulations (Palo Alto Municipal Code Chapter 16.52).
Where discrepancies exist between the requirements of this code and said
regulations, the more stringent requirements shall apply.
16.04.420 Section 1613.8 Suspended ceilings.
Section 1613.8 of Chapter 16 of the California Building Code is added to read:
1613.8 Suspended ceilings. Minimum design and installation standards for
suspended ceilings shall be determined in accordance with the requirements of
Section 2506.2.1 of this Code and this section.
1613.8.1 Scope. This part contains special requirements for suspended ceilings
and lighting systems. Provisions of Section 13.5.6 of ASCE 7 shall apply except as
modified herein.
1613.8.2 General. The suspended ceilings and lighting systems shall be limited to
6 feet (1828 mm) below the structural deck unless the lateral bracing is designed
by a licensed engineer or architect.
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1613.8.3 Sprinkler heads. All sprinkler heads (drops) except fire-resistance-rated
floor/ceiling or roof/ceiling assemblies, shall be designed to allow for free
movement of the sprinkler pipes with oversize rings, sleeves, or adaptors through
the ceiling tile. Sprinkler heads and other penetrations shall have a 2-inch
(50mm) oversize ring, sleeve, or adapter through the ceiling tile to allow for free
movement of at least 1 inch (25mm) in all horizontal directions. Alternatively, a
swing joint that can accommodate 1 inch (25 mm) of ceiling movement in all
horizontal directions is permitted to be provided at the top of the sprinkler head
extension. Sprinkler heads penetrating fire-resistance-rated floor/ceiling or
roof/ceiling assemblies shall comply with Section 714 of this Code.
1613.8.4 Special requirements for means of egress. Suspended ceiling
assemblies located along means of egress serving an occupant load of 30 or more
and at lobbies accessory to Group A Occupancies shall comply with the following
provisions.
1613.8.4.1 General. Ceiling suspension systems shall be connected and braced
with vertical hangers attached directly to the structural deck along the means of
egress serving an occupant load of 30 or more and at lobbies accessory to Group
A Occupancies. Spacing of vertical hangers shall not exceed 2 feet (610 mm) on
center along the entire length of the suspended ceiling assembly located along
the means of egress or at the lobby.
1613.8.4.2 Assembly device. All lay-in panels shall be secured to the suspension
ceiling assembly with two hold-down clips minimum for each tile within a 4-foot
(1219 mm) radius of the exit lights and exit signs.
1613.8.4.3 Emergency systems. Independent supports and braces shall be
provided for light fixtures required for exit illumination. Power supply for exit
illumination shall comply with the requirements of Section 1008.3 of this Code.
1613.8.4.4 Supports for appendage. Separate support from the structural deck
shall be provided for all appendages such as light fixtures, air diffusers, exit signs,
and similar elements.
16.04.430 Reserved
16.04.440 Section 1705.3 Concrete construction.
Section 1705.3 of Chapter 17 of the California Building Code is amended to read:
1705.3 Concrete construction. The special inspections and tests of concrete
construction shall be as required by this section and Table 1705.3.
Exceptions: Special inspections and tests shall not be required for:
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1. Isolated spread concrete footings of buildings three stories or less
above grade plane that are fully supported on earth or rock, where
the structural design of the footing is based on a specified
compressive strength, f’c, no greater than 2,500 pound per square
inch (psi) (17.2 MPa).
2. Continuous concrete footings supporting walls of buildings three
stories or less above grade plane that are fully supported on earth or
rock where:
2.1. The footings support walls of light-frame construction;
2.2. The footings are designed in accordance with Table 1809.7; or
2.3. The structural design of the footing is based on a specified
compressive strength, f ′c, no greater than 2,500 pounds per
square inch (psi) (17.2 MPa), regardless of the compressive
strength specified in the construction documents or used in the
footing construction.
3. Nonstructural concrete slabs supported directly on the ground,
including pre- stressed slabs on grade, where the effective pre-stress
in the concrete is less than 150 psi (1.03 MPa).
4. Concrete foundation walls constructed in accordance with Table
1807.1.6.2.
5. Concrete patios, driveways and sidewalks, on grade.
16.04.450 Section 1803.2 Investigations required.
Section 1803.2 of Chapter 18 of the California Building Code is amended to read:
1803.2 Investigations required. Geotechnical investigations shall be conducted in
accordance with Sections 1803.3 through 1803.5
Exceptions:
1. The building official or designee shall be permitted to waive the
requirement for a geotechnical investigation where satisfactory data
from adjacent areas is available that demonstrates an investigation is
not necessary for any of the conditions in Sections 1803.5.1 through
1803.5.6 and Sections 1803.5.10 and 1803.5.11.
2. Light-frame construction building utilizing the prescriptive continuous
footings per Table 1809.7 amended in section 16.04.470. For addition,
the engineer of record shall certify in writing that the existing
foundation system matches the proposed foundation system.
3. Accessories and minor additions may be exempted by the Building
Official or designee.
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16.04.460 Section 1803.5.11 Seismic design categories C through F.
Section 1803.5.11 of Chapter 18 of the California Building Code is amended to read:
Section 1803.5.11 Seismic design categories C through F. For structures assigned
to Seismic Design Category C, D, E or F, a geotechnical investigation shall be
conducted, and shall include an evaluation of all of the following potential
geologic and seismic hazards:
1. Slope instability.
2. Liquefaction.
3. Total and differential settlement.
4. Surface displacement due to faulting or seismically induced lateral
spreading or lateral flow.
Exception: Refer to section 1803.2 exception.
16.04.470 Section 1809.7 Prescriptive footings for light-frame construction.
Section 1809.7 of Chapter 18 of the California Building Code is amended to read:
1809.7 Prescriptive footings for light-frame construction. Where a specific
design is not provided, concrete or masonry-unit footings supporting walls of
light-frame construction shall be permitted to be designed in accordance
with Table 1809.7.
TABLE 1809.7
Prescriptive Footings Supporting Walls of Light-Frame Construction abcd
Number of Floors
Supported by the
Footing e
Thickness of
Foundation Wall
(inches)
Width of Footing
(inches)
Thickness of
Footing
(inches)
Depth of
Foundation Below
Natural Surface of
Ground or Finish
Grade (inches)
1 & 2 8 15 8 20
3 8 18 8 30
Group U Occupancies 8 12 8 12
ADU Conversionsf 8 12 8 12
a. Ground under the floor shall be permitted to be excavated to elevation of footing.
b. Interior stud-bearing walls shall be permitted to be supported by isolated footings.
Footing width and length shall be twice the width shown in this table, and footings
shall be spaced not more than 6 feet on center.
c. See Section 1905 for additional requirements for concrete footings of
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structures assigned to Seismic Design Category C, D, E or F.
d. All foundations as required in the above Table shall be continuous and have a
minimum of three #4 bars of reinforcing steel, except for one story, detached
accessory buildings of Group U occupancy where two bars are required.
e. Footings shall be permitted to support a roof in addition to the stipulated number of
floors. Footings supporting roof only shall be as required for supporting one floor.
f. If existing detached accessory building is being converted to an Accessory Dwelling
Unit (ADU) and the existing foundation is being utilized, then a designer, architect or
engineer shall provide a letter that the existing foundation complies with the
conditions above and is deemed structurally sound.
16.04.480 Section 1809.8 Plain concrete footings.
Section 1809.8 of Chapter 18 of the California Building Code is deleted.
16.04.490 Section 1901.2 Plain and reinforced concrete.
Section 1901.2 of Chapter 19 of the California Building Code is amended to read:
1901.2 Plain and reinforced concrete. Structural concrete shall be designed and
constructed in accordance with the requirements of this chapter and ACI 318 as amended
in section 1905 of this code and PAMC 16.14.240. Except for the provisions of Sections
1904 and 1907, the design and construction of slabs on grade shall not be governed by this
chapter unless they transmit vertical loads or lateral forces from other parts of the
structure to the soil.
16.04.500 Section 1905.6.2 Seismic Design Categories C, D, E and F.
Section 1905.6.2 of Chapter 19 of the California Building Code is amended to read:
1905.6.2 Seismic Design Categories C, D, E and F.
Structures assigned to Seismic Design Category C, D, E or F shall not have elements
of structural plain concrete, except as follows:
1. Left intentionally blank.
2. Isolated footings of plain concrete supporting pedestals or columns
are permitted, provided the projection of the footing beyond the face
of the supported member does not exceed the footing thickness.
3. Plain concrete footings supporting walls are permitted, provided
the footings have at least three continuous longitudinal reinforcing
bars not smaller than No. 4, with a total area of not less than 0.002
times the gross cross-sectional area of the footing except for one
story, detached accessory buildings of Group U occupancy where two
bars are required. A minimum of one bar shall be provided at the top
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and bottom of the footing. Continuity of reinforcement shall be
provided at corners and intersections.
16.04.510 SECTION 1906 FOOTINGS FOR LIGHT-FRAME CONSTRUCTION
Section 1906 of Chapter 19 of the California Building Code is deleted.
16.04.520 Section 1906.1 Plain concrete footings.
Section 1906.1 of Chapter 19 of the California Building Code is deleted.
16.04.530 Section 1907.1 Structural slabs-on-ground.
Section 1907.1 of Chapter 19 of the California Building Code is amended to read:
1907.1 Structural slabs-on-ground. Structural concrete slabs-on-ground shall
comply with all applicable provisions of this chapter. Slabs-on-ground shall be
considered structural concrete where required by ACI 318 or where designed to
transmit either of the following:
1. Vertical loads or lateral forces from other parts of the structure to the soil.
2. Vertical loads or lateral forces from other parts of the structure to foundations.
Structural slabs-on-ground shall have 6x6-10/10 wire mesh or equal at mid-
height.
16.04.535 Section 1907.2 Nonstructural slabs-on-ground.
Section 1907.2 of Chapter 19 of the California Building Code is amended to read:
1907.2 Nonstructural slabs-on-ground. Nonstructural slabs-on-ground shall be
required to comply with Sections 1904.2, 1907.3 and 1907.4. Portions of the
nonstructural slabs-on-ground used to resist uplift forces or overturning shall be
designed in accordance with accepted engineering practice throughout the
entire portion designated as dead load to resist uplift forces or overturning.
Nonstructural slabs-on-ground shall have 6x6-10/10 wire mesh or equal at mid-
height.
16.04.540 Reserved
16.04.550 Reserved
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16.04.560 Section 2308.10.4 Braced wall panel construction.
Section 2308.10.4 of Chapter 23 of the California Building Code is amended to read:
2308.10.4 Braced wall panel construction. For Methods DWB, WSP, SFB, PBS,
PCP and HPS, each panel must be not less than 48 inches (1219 mm) in length,
covering three stud spaces where studs are spaced 16 inches (406 mm) on center
and covering two stud spaces where studs are spaces 24 inches (610 mm) on
center. Braced wall panels less than 48 inches (1219 mm) in length shall not
contribute toward the amount of required bracing. Braced wall panels that are
longer than the required length shall be credited for their actual length.
Vertical joints of panel sheathing shall occur over studs and adjacent panel joints
shall be nailed to common framing members. Horizontal joints shall occur over
blocking or other framing equal in size to the studs except where waived by the
installation requirements for the specific sheathing materials. Sole plates shall be
nailed to the floor framing in accordance with Section 2308.10.7 and top plates
shall be connected to the framing above in accordance with Section 2308.10.7.2.
Where joists are perpendicular to braced wall lines above, blocking shall be
provided under and in line with the braced wall panels.
16.04.570 Section 2308.10.5 Alternative bracing.
Section 2308.10.5 of Chapter 23 of the California Building Code is amended to read:
2308.10.5 Alternative bracing. An alternate braced wall (ABW) or a portal frame with
hold-downs (PFH) described in this section is permitted to substitute for a 48-inch (1219 mm)
braced wall panel of Method DWB, WSP, SFB, PCP or HPS.
16.04.580 TABLE 2308.10.1 WALL BRACING REQUIREMENTS.
Footnote “b” of TABLE 2308.10.1 of Chapter 23 of the California Building Code is amended
to read:
b. See section 2308.10.3 for full description of bracing methods. Method GB is
prohibited in Seismic Design Categories D & E.
16.04.590 TABLE 2308.10.3(1) BRACING METHODS.
TABLE 2308.10.3(1) Bracing Methods of Chapter 23 of the California Building Code is
amended by adding footnote “b” and footnote “b” superscript to METHODS, MATERIAL
column title as follows:
TABLE 2308.10.3(1) BRACING METHODS
METHODS,
MATERIAL b
MINIMUM
THICKNESS FIGURE
a CONNECTION CRITERIA
Fasteners Spacing
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b. Method GB is prohibited in Seismic Design Categories D & E.
16.04.600 Section 2308.10.9 Attachment of sheathing.
Section 2308.10.9 of Chapter 23 of the California Building Code is amended to read:
2308.10.9 Attachment of sheathing. Fastening of braced wall panel sheathing
shall not be less than that prescribed in Table 2308.10.1 or 2304.10.2. Wall
sheathing shall not be attached to framing members by adhesives. Staple
fasteners in Table 2304.10.2 shall not be used to resist or transfer seismic forces
in structures assigned to Seismic Design Category D, E, or F unless the allowable
shear values are substantiated by cyclic testing and approved by the Building
Official or designee.
All braced wall panels shall extend to the roof sheathing and shall be attached to parallel
roof rafters or blocking above with framing clips (18 gauge minimum) spaced at
maximum 24 inches on center with four 8d nails per leg (total eight-8d nails per clip).
Braced wall panels shall be laterally braced at each top corner and at maximum 24-inch
intervals along the top plate of discontinuous vertical framing.
16.04.610 SECTION 2505 SHEAR WALL CONSTRUCTION.
Section 2505 Chapter 25 of the California Building Code is deleted in its entirety including
its subsections.
16.04.620 Reserved
16.04.630 Chapter 31B Public Pools.
Chapter 31B of the California Building Code has been adopted in its entirety.
16.04.640 Section 3304.1 Excavation and fill.
Section 3304.1 of Chapter 33 of the California Building Code is amended to read:
3304.1 Excavation and fill. Excavation and fill for buildings and structures shall
be constructed or protected so as not to endanger life or property. Stumps and
roots shall be removed from the soil to a depth of not less than 12 inches
(305mm) below the surface of the ground in the area to be occupied by the
building. Wood forms that have been used in placing concrete, if within the
ground or between foundation sills and the ground, shall be removed before a
building is occupied or used for any purpose. Wooden stakes shall not be
embedded in concrete. Before completion, loose or casual wood shall be
removed from direct contact with the ground under the building.
SECTION 2. Chapter 16.19, California Historical Building Code and Existing Building
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Code, of Title 16 (Building Regulations) of the Palo Alto Municipal Code is repealed in its
entirety and readopted to read as follows:
CHAPTER 16.19
CALIFORNIA HISTORICAL BUILDING CODE,
CALIFORNIA CODE OF REGULATIONS, TITLE
24, PART 8
and
CALIFORNIA EXISTING BUILDING CODE,
CALIFORNIA CODE OF REGULATIONS, TITLE 24,
PART 10
Sections
16.19.010 2025 California Historical Building Code, Title 24, Part 8 adopted.
16.19.020 2025 California Existing Building Code, Title 24, Part 10 adopted and
amended.
16.19.030 Cross - References to California Existing Building Code.
16.19.040 Local Amendments.
16.19.050 101.2.1 Appendices.
16.19.060 Administration & Enforcement of 2025 California Existing Building Code
16.19.070 Adoption of 2025 California Existing Building Code Chapter 1 , Division
II – Scope and Administration
16.19.080 Section 101.1 Title.
16.19.090 Section 324 Dwelling unit and congregate residence superficial floor area.
16.19.100 Section 503.21 Suspended ceiling systems.
16.19.110 Section 503.22 Mechanical and electrical equipment in seismic design
categories D, E or F.
16.19.120 Section 405.2.3.1 Seismic evaluation and design procedures for repairs.
16.19.010
2025 California Historical Building Code, Title 24, Part 8 adopted.
The California Historical Building Code, 2025 Edition, Title 24, Part 8 (authorized by
Health and Safety Code Sections 18950 through 18961), which provides alternative
building regulations for the rehabilitation, preservation, restoration, or relocation of
designated historic buildings, is adopted and hereby incorporated in this Chapter by
reference and made a part hereof the same as if fully set forth herein.
One copy of the California Historical Building 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.
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16.19.020 2025 California Existing Building Code, Title 24, Part 10 adopted and amended.
The California Existing Building Code, 2025 Edition, Title 24, Part 10 of the California Code
of Regulations, which provides alternative building regulations for the rehabilitation,
preservation restoration or relocation of existing buildings, 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.
One copy of the California Existing Building 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.
16.19.030 Cross - References to California Existing Building Code.
The provisions of this Chapter contain cross-references to the provisions of the California
Existing Building Code, 2025 Edition, in order to facilitate reference and comparison to
those provisions.
16.19.040 Local Amendments.
The provisions of this Chapter shall constitute local amendments to the cross-referenced
provisions of the California Existing Building 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.
16.19.050 101.2.1 Appendices.
Section 101.2.1 of Chapter 1 of the California Existing Building Code is amended to read:
2025 California Existing Building Code and International Existing Building Code
Appendix Chapters Adopted.
The following Appendix Chapters of the California Existing Building Code (CEBC),
2025 Edition, and International Existing Building Code (IEBC), 2024 Edition, are
adopted and
hereby incorporated in this Chapter be reference and made a part hereof the
same as if fully set forth herein:
A. CEBC Appendix A1 – Seismic Strengthening Provisions for
Unreinforced Masonry Bearing Wall Buildings
B. CEBC Appendix Chapter A2 – Earthquake Hazard Reduction in Existing
Reinforced Concrete and Reinforced Masonry Wall Buildings with
Flexible Diaphragms
C. CEBC Appendix A3 – Prescriptive Provisions for Seismic Strengthening
of Cripple Walls and Sill Plate Anchorage of Light, Wood-Frame
Residential Buildings
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D. CEBC Appendix A4 – Earthquake Risk Reduction in Wood-Frame
Residential Buildings with Soft, Weak or Open Front Walls
E. CEBC Appendix A5 – Referenced Standards
16.19.060 Administration & Enforcement of 2025 California Existing Building 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.
16.19.070 Adoption of 2025 California Existing Building Code Chapter 1 , Division
II – Scope and Administration
Chapter 1, Division II, Parts 1 and 2 of the 2025 California Existing Building Code is
adopted by the City of Palo Alto to supplement, to the extent it does not conflict with,
Chapter 1, Division II of the 2025 California Building Code, as amended.
16.19.080 Section 101.1 Title.
Section 101.1 of Chapter 1 of the California Existing Building Code is amended to read:
101.1 Title. These regulations shall be known as the Existing Building Code of City
of Palo Alto, hereinafter referred to as “this code.”
16.19.090 Section 324 Dwelling unit and congregate residence superficial floor area.
Section 324 of Chapter 3 of the California Existing Building Code is added to read:
324 Dwelling unit and congregate residence superficial floor area. Every
dwelling unit and congregate residence shall have at least one room which shall
have not less than 120 square feet of superficial floor area. Every room which is
used for both cooking and living or both living and sleeping purposes shall have
not less than 144 square feet of superficial floor area. Every room used for
sleeping purposes shall have not less than 70 square feet of superficial floor area.
When more than two persons occupy a room used for sleeping purposes the
required superficial floor area shall be increased at the rate of 50 square feet for
each occupant in excess of two. Guest rooms with cooking shall contain the
combined required superficial areas of a
sleeping and a kitchen, but not less than 144 square feet. Other habitable rooms
shall be not less than 70 square feet.
Notwithstanding any provision of this Section, children under the age of six shall
not be counted for purposes of determining whether a family with minor children
complies with the provisions of this Code.
For the purposes of this section, "superficial floor area" means the net floor area
36
0290186_20250923_ms29
within the enclosing walls of the room in which the ceiling height is not less than
seven feet six inches, excluding built-in equipment such as wardrobes, cabinets,
kitchen units, or fixtures which are not readily removable.
16.19.100 Section 503.21 Suspended ceiling systems.
Section 503.21 of Chapter 5 the California Existing Building Code is added to read:
503.21 Suspended ceiling systems. In existing buildings or structures, when a
permit is issued for alterations or repairs, the existing suspended ceiling system
within the area of the alterations or repairs shall comply with ASCE 7-22 Section
13.5.6.
16.19.110 Section 503.22 Mechanical and electrical equipment in seismic design
categories D, E or F.
Section 503.22 of Chapter 5 of the California Existing Building Code is added to read:
503.22 Mechanical and electrical equipment in seismic design categories D, E
or F. In existing buildings or structures, when a permit is issued for alteration or
repairs, the existing mechanical and electrical equipment on the area of the roof
shall comply with ASCE 7-22 Section 13.4 Nonstructural Component Anchorage.
16.19.120 Section 405.2.3.1 Seismic evaluation and design procedures for repairs.
Section 405.2.3.1 of Chapter 5 of the California Existing Building Code is amended to read:
405.2.3.1 Evaluation and design procedures. The building shall be evaluated by
a registered design professional, and the evaluation findings shall be submitted
to the code official. The evaluation shall establish whether the damaged building,
if repaired to its pre-damage state, would comply with the provisions of the
California Building Code for load combinations that include wind or earthquake
effects, except that the seismic forces shall be reduced seismic forces. Evaluation
for earthquake loads shall be required if the substantial structural damage was
caused by or related to earthquake effects or if the building is in Seismic Design
Category C, D, E or F. The seismic evaluation and design shall be based on the
procedures specified in the building code, ASCE 41 Seismic Evaluation and
Upgrade of Existing Buildings. The procedures contained in Appendix A of the
International Existing Building Code (IEBC) shall be permitted to be used as
specified in Section 405.2.3.1. Wind loads for this evaluation shall be those
prescribed in Section 1609.
405.2.3.1.1 CEBC level seismic forces. When seismic forces are required to meet
the building code level, they shall be one of the following:
1. One hundred percent of the values in the building code. The R factor
37
0290186_20250923_ms29
used for analysis in accordance with Chapter 16 of the building code
shall be the R factor specified for structural systems classified as
"Ordinary" unless it can be demonstrated that the structural system
satisfies the proportioning and detailing requirements for systems
classified as "intermediate" or "special".
2. Forces corresponding to BSE-1 and BSE-2 Earthquake Hazard Levels
defined in ASCE 41. Where ASCE 41 is used, the corresponding
performance levels shall be those shown in Table 405.2.3.1.
3. Forces corresponding to BSE-1 and BSE-2 Earthquake Hazard Levels
defined in ASCE 41. Where ASCE 41 is used, the corresponding
performance levels shall be those shown in Table 405.2.3.1.
38
0290186_20250923_ms29
TABLE 405.2.3.1
ASCE 41 PERFORMANCE LEVELS
RISK CATEGORY (BASED
ON CBC TABLE 1604.5)
PERFORMANCE LEVEL FOR USE WITH
ASCE 41 BSE-1 EARTHQUAKE HAZARD
LEVEL
PERFORMANCE LEVEL FOR USE
WITH ASCE 41 BSE-2
EARTHQUAKE HAZARD LEVEL *
I Life Safety (LS) Collapse Prevention (CP)
II Life Safety (LS) Collapse Prevention (CP)
III Damage Control Limited Safety
IV Immediate Occupancy (IO) Life Safety (LS)
* Only applicable when Tier 3 procedure is used.
405.2.3.1.2 Reduced CEBC level seismic forces. When seismic forces are
permitted to meet reduced building code levels, they shall be one of the
following:
1. Seventy-five percent of the forces prescribed in the building code. The
R factor used for analysis in accordance with Chapter 16 of the
building code shall be the R factor as specified in Section 405.2.3.1.1.
2. In accordance with the California Existing Building Code and
applicable chapters in Appendix A of the International Existing
Building Code, as specified in Items (a.) through (e.) below. Structures
or portions of structures that comply with the requirements of the
applicable chapter in Appendix A shall be deemed to comply with the
requirements for reduced building code force levels.
a. The seismic evaluation and design of unreinforced masonry
bearing wall buildings in Risk Category I or II are permitted to be
based on the procedures specified in CEBC Appendix ChapterA1.
b. Seismic evaluation and design of the wall anchorage system in
reinforced concrete and reinforced masonry wall buildings with
flexible diaphragms in Risk Category I or II are permitted to be
based on the procedures specified in IEBC Appendix Chapter A2.
c. Seismic evaluation and design of cripple walls and sill plate
anchorage in residential buildings of light-frame wood
construction in Risk Category I or II are permitted to be based on
the procedures specified in CEBC Appendix Chapter A3
d. Seismic evaluation and design of soft, weak, or open-front wall
conditions in multi-unit residential buildings of wood construction
in Risk Category I or II are permitted to be based on the
procedures specified in CEBC Appendix Chapter A4.
39
0290186_20250923_ms29
e. Seismic evaluation and design of concrete buildings and concrete
with masonry infill buildings in all risk categories are permitted to
be based on the procedures specified in IEBC Appendix Chapter
A5.
Those associated with the BSE-1 Earthquake Hazard Level defined in ASCE 41 and the
performance level as shown in Table 405.2.3.1. Where ASCE 41 is used, the design
spectral response acceleration parameters SXS and SX1 shall not be taken less than
seventy-five percent of the respective design spectral response acceleration parameters
SDS and SD1 defined by the California Building Code and its reference standards.
SECTION 3. The Council adopts the findings for local amendments to the California
Building Code, 2025 Edition, attached hereto as Exhibit “A” and incorporated herein by reference.
SECTION 4. The Council adopts the findings for local amendments to the California
Existing Building Code, 2025 Edition, attached hereto as Exhibit “B” and incorporated herein by
reference.
SECTION 3. 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 would have adopted the Ordinance
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 4. The Council finds that to the extent they affect residential units, the
changes or modifications to the California Building Code (Title 24, Part 2) and the California
Existing Building Code (Title 24, Part 10) adopted by this ordinance are substantially equivalent
to changes or modifications that were previously filed by the governing body of the City and were
in effect as of September 30, 2025, and are therefore exempt from the moratorium on new
residential building standards imposed by Assembly Bill 130 (2025).
SECTION 5. The Council finds that this ordinance is exempt from the provisions of the
California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA
Guidelines, because it can be seen with certainty that there is no possibility that the amendments
herein adopted will have a significant effect on the environment.
//
//
40
0290186_20250923_ms29
SECTION 6. This Ordinance shall be effective on the thirty-first day after the date of
its adoption.
INTRODUCED:
PASSED:
AYES:
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
41
0290186_20250923_ms29
Exhibit A
FINDINGS FOR LOCAL AMENDMENTS TO CALIFORNIA BUILDING CODE,
TITLE 24, PART 2, VOLUMES 1 AND 2
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.
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 Building Code, Title 24, Part 2, Volumes 1 and 2
Chapter(s),
Section(s),
Table(s),
Appendices
Title Added Amended Deleted Justification
(See below
for keys)
Ch. 1, Div. II SCOPE OF ADMINISTRATION A
Part 1 Scope of Application A
Part 2 Administration and Enforcement A
101.1 Title A
101.2.1 Appendices A
101.4 Referenced codes A
101.4.9 Historical Buildings A
101.4.10 Electrical A
101.4.11 Residential Buildings A
101.4.12 Green Building Standards A
101.4.13 International Swimming and Spa Code A
103.1 Creation of enforcement agency A
103.2 Appointment A
103.3 Deputies A
104.2.4.1 Flood hazard area C, G, T
104.3.1 Determination of substantially improved
or substantially damaged existing buildings
and structures in flood hazard zones
C, G, T
42
0290186_20250923_ms29
105.2 Work exempt from permit A, G, T
105.3.2 Time limitation of applications A
105.5 Expiration A
105.5.1 Term limits for permits A
106.1 Live load posted G , T
109.6 Refunds A
109.7 Re-Inspection fees A
110.2.1 Preliminary accessibility compliance
inspection
A
110.3.3 Lowest floor elevation A
111.1 Use and occupancy A
111.1.1 Change of occupancy or tenancy A
111.3 Temporary occupancy A
111.5 Posting A
113 Means of Appeals A
114.1 Unlawful acts A
114.5 Criminal enforcement authority A
115.1 Authority A
115.2 Issuance A
115.3 Unlawful continuance A
115.4 Removal of posted stop work order A
115.5 Response required A
115.6 Permit application required A
115.7 Stop work order penalty A
202 Definitions A
502.1 Address identification T
502.1.1 Address illumination T
502.1.2 Address identification size T
903.2 Automatic sprinkler system, where
required
G, T
903.3.1.1 NFPA 13 sprinkler systems G, T
903.3.1.2 NFPA 13R sprinkler systems G, T
903.3.1.3 NFPA 13D sprinkler systems G, T
903.3.1.3.1 Increase in fire sprinkler design criteria G, T
43
0290186_20250923_ms29
903.4.4 Floor control valves G, T
905.3.1 Height G, T
907.2.11.2.4 Smoke Alarms -
G, T
909.20.7 Smoke control systems G, T
915.6 Maintenance
T
1008.3 Illumination required by an emergency
electrical system
G, T
1031.2 Where required G, T
1205.3.4 Roof guards at courts G
1208.6 Dwelling unit and congregate residence
superficial floor area
A, G
1503.2.1 Locations C
1612.1.1 Palo Alto Flood Hazard Regulations C, T
1613.8 Suspended ceilings G
1613.8.1 Scope G
1613.8.2 General G
1613.8.3 Sprinkler heads G
1613.8.4 Special requirements for means of egress G
1613.8.4.1 General G
1613.8.4.2 Assembly device G
1613.8.4.3 Emergency systems G
1613.8.4.4 Supports for appendage G
1705.3 Concrete construction G
1803.2 Investigations required G
1803.5.11 Seismic design categories C through F G, T
1809.7 Prescriptive footings for light-frame
construction
G, T
Tbl. 1809.7 Prescriptive footings for light-frame
construction
G, T
1809.8 Plain concrete footings G, T
1901.2 Plain and reinforced concrete G, T
1905.6.2 Seismic Design Categories C, D, E and F G, T
1906 FOOTINGS FOR LIGHT-FRAME
CONSTRUCTION
G, T
1906.1 Plain concrete footings G, T
1907.1 Structural slab-on-ground G, T
44
0290186_20250923_ms29
1907.2 Nonstructural slabs-on-ground G, T
2308.10.4 Braced wall panel construction G, T
2308.10.5 Alternative bracing G, T
Tbl.
2308.10.1
Wall Bracing Requirements.
Footnote “b”
G, T
Tbl.
2308.10.3(1
)
Bracing Methods
Footnote “b”
G, T
2308.10.9 Attachment of sheathing G, T
2505 SHEAR WALL CONSTRUCTION G, T
Ch. 31B Public Pools G, T
3304.1 Excavation and fill G, T
Appx. I Patio Covers A, G
Appx. J Grading (Section J109.4 Drainage across
property lines)
G, T
Appx. P Emergency Housing A, C, G, T
45
0290186_20250923_ms29
Exhibit B
FINDINGS FOR LOCAL AMENDMENTS TO CALIORNIA EXISTING BUILDING CODE,
Title 24, Part 10
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.
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 Existing Building Code, Title, 24, Part 10
Chapter(s),
Section(s),
Table(s),
Appendices
Title Added Amended Replace
d
Justificat
ion (See
below for
keys)
101.2.1 Appendices A, G, T
Ch. 1, Div. II Scope and Administration A
101.1 Title A
324 Dwelling unit and congregate
residence superficial floor
area.
A, G
503.21 Suspended ceiling system G
503.22 Mechanical and
electrical equipment in
seismic design
categories D, E or F
G
405.2.3.1 405.2.3.1 Seismic evaluation
and
design procedures for repairs
G
405.2.3.1.1 CEBC level seismic forces G
Tbl.
405.2.3.1
ASCE 41 PERFORMANCE LEVELS G
405.2.3.1.2 Reduced CEBC level seismic
forces
G
46
0290186_20250923_ms29
Appx. A1 Seismic Strengthening
Provisions
for Unreinforced Masonry
Bearing Wall
Buildings
G, T
Appx. A2 Earthquake Hazard Reduction
in Existing Reinforced Concrete
and Reinforced Masonry Wall
Buildings with Flexible
Diaphragms
G, T
Appx. A3 Prescriptive Provisions for
Seismic Strengthening of
Cripple Walls and Sill Plate
Anchorage of Light, Wood-
Frame Residential Buildings
G, T
Appx. A4 Earthquake Risk Reduction in
Wood- Frame Residential
Buildings with Soft, Weak or
Open Front Walls
G, T
Appx. A5 Referenced Standards G, T
47
0290186_20250923_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 based on 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 Building Standards Code is required. Natural gas combustion and gas
appliances emit a wide range of air pollutants, such as carbon monoxide (CO), nitrogen oxides
(NOx, including nitrogen dioxide (NO2)), particulate matter (PM), and formaldehyde, which
according to a UCLA Study, have been linked to various acute and chronic health effects, and
additionally exceed levels set by national and California-based ambient air quality standards.
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, 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 construction of more energy efficient
buildings can help Palo Alto reduce its share of the GHG emissions that contribute to climate
change. All-electric new buildings benefit the health, safety, and welfare, of Palo Alto and its
residents. Requiring all-electric construction, without gas infrastructure will reduce the amount
of greenhouse gas produced in Palo Alto and will contribute to reducing the impact of climate
change and the associated risks. Due to decrease in annual rain fall, Palo Alto experiences the
effect of drought and water saving more than some other communities in California. Embodied
carbon of concrete is a significant contributor to greenhouse gas emissions and climate change,
and this amendment includes a requirement to use low-carbon concrete.
G This amendment is justified based on a local geological condition. The City of Palo Alto is
subject to earthquake hazard 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 earthquake. The other fault is
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 faults are considered major Northern California
earthquake faults which may experience rupture at any time. Thus, because the City is within a
seismic area which 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.
48
0290186_20250923_ms29
T The City of Palo Alto topography includes hillsides with narrow and winding access, which
makes timely response by fire suppression and emergency response vehicles difficult. Palo Alto
is contiguous with the San Francisco Bay, resulting in a natural receptor for storm and wastewater
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 Code
is warranted.
1
0290185_20250918_ms29
NOT YET APPROVED
Ordinance No.
Ordinance of the Council of the City of Palo Alto Repealing
Chapter 16.06 of the Palo Alto Municipal Code and Adopting a
New Chapter 16.06, California Residential Code, 2025 Edition, and
Local Amendments and Related Findings
The Council of the City of Palo Alto does ORDAIN as follows:
SECTION 1. Chapter 16.06 of Palo Alto Municipal Code is hereby amended by
repealing the Chapter in its entirety and adopting a new Chapter 16.06 to read as follows:
CHAPTER 16.06
2025 California Residential Code,
CALIFORNIA CODE OF REGULATIONS, TITLE 24, PART 2.5
Sections
16.06.010 2025 California Residential Code adopted and amended.
16.06.015 Local Amendments.
16.06.020 2025 California Residential Code Appendix Chapters adopted.
16.06.030 Cross - References to California Residential Code.
16.06.040 Administration of California Residential Code.
16.06.050 Section R202 Definitions.
16.06.060 Table 301.2 Climatic and Geographic Design Criteria.
16.06.070 Section R301.2.2.6 Irregular buildings.
16.06.075 Section R304.5 Dwelling unit and congregate residence superficial floor
area.
16.06.080 Section R319.1 Emergency escape and rescue openings.
16.06.090 Section R319.4.2.3 Window well fall protection.
16.06.100 Section R319.4.5 Security bars.
16.06.110 Section R309.1.1 Design and installation.
16.06.120 Section R309.2 One- and two-family dwellings automatic fire sprinkler
systems.
16.04.130 Section R309.2.1 Design and installation.
16.04.140 Section R309.2.2 NFPA 13D sprinkler systems increase in design
requirements.
16.04.150 Section R309.3 Dwelling unit fire sprinkler systems.
16.06.160 Section R310.1 Smoke detection and notification.
16.06.170 Section R310.1.3 Smoke alarms or detector end of life replacement
16.06.180 Section R311.7.5. Carbon Monoxide alarms
2
0290185_20250918_ms29
NOT YET APPROVED
16.06.190 Section R308 Address Identification
16.06.200 Section R306.1 General (Palo Alto Flood Hazard Regulations).
16.06.210 Reserved
16.06.220 Section R401 GENERAL
16.06.225 Section R402.2.1 Materials for concrete
16.06.230 Section R403 FOUNDATION.
16.06.240 Section R404.1.3 Concrete foundation walls.
16.06.250 Section R504.3.1 Projections exposed to weather
16.06.260 Section R506.1 General
16.06.270 Section R602.10.4.5 Limits on methods GB and PCP
16.06.280 Table R602.10.3(3) Bracing requirements based on seismic design category
16.06.290 Section R608.5 Materials
16.06.300 Section R703.8.5.1 Locations.
16.06.310 Reserved
16.06.320 Section R1003.9.2.1 Repairs, replacements, and alterations
16.06.330 Section BO109 Preliminary Meeting
16.06.010
2025 California Residential Code adopted and amended.
The California Residential Code, 2025 Edition, Title 24, Part 2.5 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.
Unless superseded and expressly repealed, references in City of Palo Alto forms, documents and
regulations to the chapters and sections of the former California Code of Regulations, Title 24, 2019,
shall be construed to apply to the corresponding provisions contained within the California Code of
Regulations, Title 24, 2025. Ordinance No. 5566 of the City of Palo Alto and all other ordinances or
parts of ordinances in conflict herewith are hereby suspended and expressly repealed.
Wherever the phrases "California Residential Code" or "Residential Code" are used in this
code or any ordinance of the city, such phrases shall be deemed and construed to refer and
apply to the California Residential Code, 2025 Edition, Title 24, Part 2.5 of the California Code
of Regulations, as adopted by this Chapter.
One copy of the California Residential Code, 2025 Edition, has been filed for use and examination of
the public in the Office of the Building Official of the City of Palo Alto.
16.06.015 Local Amendments.
The provisions of this Chapter shall constitute local amendments to the cross-referenced
provisions of the California Residential 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.
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0290185_20250918_ms29
NOT YET APPROVED
Where used in this Chapter 16.06, ellipses shall indicate text of the California Residential
Code, 2025 Edition, that has been adopted without amendment but is omitted for brevity.
16.06.020 2025 California Residential Code Appendix Chapters adopted.
The following Appendix Chapters of the California Residential Code, 2025 Edition, are adopted and
hereby incorporated in this Chapter by reference and made a part hereof the same as if fully set
forth herein:
A. Appendix BF – Patio Covers
B. Appendix BO – Existing Building and Structures
C. Appendix BG – Sound Transmission
D. Appendix CI – Swimming Pool Safety Act
16.06.030 Cross - References to California Residential Code.
The provisions of this Chapter contain cross-references to the provisions of the California
Residential Code, 2025 Edition, in order to facilitate reference and comparison to those provisions.
16.06.040 Administration of California Residential Code
Chapter 1, Division II of the 2025 California Residential Code is replaced in its entirety by
Chapter 1, Division II of the 2025 California Building Code as amended by Palo Alto Municipal
Code Chapter 16.04.
16.06.050 Section R202 Definitions.
Section R202 of the California Residential Code is amended to include the following definitions:
SUPERFICIAL FLOOR AREA. "Superficial floor area" is the net floor area within the
enclosing walls of the room in which the ceiling height is not less than seven feet
six inches, excluding built-in equipment such as wardrobes, cabinets, kitchen
units, or fixtures which are not readily removable.
16.06.060 Table 301.2 Climatic and Geographic Design Criteria.
Table 301.2 of the California Residential Code is amended to read:
4
0290185_20250918_ms29
NOT YET APPROVED
TABLE R301.2
CLIMATIC AND GEOGRAPHIC DESIGN CRITERIA
GROUND WIND DESIGN SEISMIC SUBJECT TO DAMAGE FROM
SNOW LOAD Speed
(mph)
Topographic
effects
DESIGN
CATEGORY
Weathering Frost
line
depth
Termite
0 92 No D0 thru E Negligible 5” Very High
WINTER
DESIGN
TEMP.
(OF)
ICE BARRIER
UNDERLAYEMENT
REQUIRED
FLOOD
HAZARDS
AIR
FREEZING
INDEX
MEAN
ANNUAL
TEMP.
(OF)
40 No See
Footnotes
p thru r
0 55
p The City of Palo Alto entered National Flood Insurance Program in 1979.
q The effective date of the current Flood Insurance Study and Flood Insurance Rate
Map is May 18, 2009.
r The panel numbers and dates of all currently effective FIRMs and FBFMs:
06085CIND0A, 06085C0010H, 06085C0015H through 06085C0019H, 06085C0030H,
06085C0036H , 06085C0038H , 06085C0180H ,06085C0185H (May 18, 2009 for all)
16.06.070 Section R301.2.2.6 Irregular buildings.
Section R301.2.2.6 of the California Residential Code is amended as follows:
The seismic provisions of this code shall not be used for structures, or portions thereof, located
in Seismic Design Categories C, D0, D1 and D2 and considered to be irregular in accordance
with this section. A building or portion of a building shall be considered to be irregular where
one or more of the conditions defined in Items 1 through 8 occur. Irregular structures, or
irregular portions of structures, shall be designed in accordance with accepted engineering
practice to the extent the irregular features affect the performance of the remaining structural
system. Where the forces associated with the irregularity are resisted by a structural system
designed in accordance with accepted engineering practice, the remainder of the building shall
be permitted to be designed using the provisions of this code.
1. Shear wall or braced wall offsets out of plane. Conditions where exterior shear wall
lines or braced wall panels are not in one plane vertically from the foundation to the
uppermost story in which they are required.
2. Lateral Support of roofs and floors. Conditions where a section of floor or roof is not
laterally supported by shear walls or braced wall lines on all edges.
5
0290185_20250918_ms29
NOT YET APPROVED
Exception: Portions of floors that do not support shear walls, braced wall panels
above, or roofs shall be permitted to extend not more than 6 feet (1829 mm)
beyond a shear wall or braced wall line.
3. Shear wall or braced wall offsets in plane. Conditions where the end of a braced wall
panel occurs over an opening in the wall below.
4. Floor and roof opening. Conditions where an opening in a floor or roof exceeds the
lesser of 12 feet (3658 mm) or 50 percent of the least floor or roof dimension.
5. Floor level offset. Conditions where portions of a floor level are vertically offset.
6. Perpendicular shear wall and wall bracing. Conditions where shear walls and braced
wall lines do not occur in two perpendicular directions.
7. Wall bracing in stories containing masonry or concrete construction. Conditions
where stories above grade plane are partially or completely braced by wood wall
framing in accordance with Section R602 or cold-formed steel wall framing in
accordance with Section R603 include masonry or concrete construction. Where this
irregularity applies, the entire story shall be designed in accordance with accepted
engineering practice.
Exceptions: Fireplaces, chimneys and masonry veneer in accordance with this code.
8. Hillside light-frame construction. Conditions in which all of the following apply:
8.1 The grade slope exceeds 1 unit vertical in 5 units horizontal where averaged
across the full length of any side of the dwelling.
8.2 The tallest cripple wall clear height exceeds 7 feet (2134 mm), or where a post
and beam system occurs at the dwelling perimeter, the post and beam system
tallest post clear height exceeds 7 feet (2134 mm).
8.3 Of the total plan area below the lowest framed floor, whether open or enclosed,
less than 50 percent is living space having interior wall finishes conforming to
Section R702.
Where Item 8 is applicable, design in accordance with accepted engineering practice
shall be provided for the floor immediately above the cripple walls or post and beam
system and all structural elements and connections from this diaphragm down to and
including connections to the foundation and design of the foundation to transfer lateral
loads from the framing above.
Exception: Light-frame construction in which the lowest framed floor is supported
directly on concrete or masonry walls over the full length of all sides except the
downhill side of the dwelling need not be considered an irregular dwelling under
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Item 8.
16.06.75 Section R304.5 Dwelling unit and congregate residence superficial floor
area.
Section R304.5 of the California Residential Code is added to read:
R304.5 Dwelling unit and congregate residence superficial floor area.
Every dwelling unit and congregate residence shall have at least one
room which shall have not less than 120 square feet of superficial floor
area. Every room which is used for both cooking and living or both living
and sleeping purposes shall have not less than 144 square feet of
superficial floor area. Every room used for sleeping purposes shall have
not less than 70 square feet of superficial floor area. When more than
two persons occupy a room used for sleeping purposes the required
superficial floor area shall be increased at the rate of 50 square feet for
each occupant in excess of two. Guest rooms with cooking shall contain
the combined required superficial areas of a sleeping and a kitchen, but
not less than 144 square feet. Other habitable rooms shall be not less
than 70 square feet.
Notwithstanding any provision of this Section, children under the age of
six shall not be counted for purposes of determining whether a family
with minor children complies with the provisions of this Code.
For the purposes of this section, "superficial floor area" means the net
floor area within the enclosing walls of the room in which the ceiling height
is not less than seven feet six inches, excluding built-in equipment such as
wardrobes, cabinets, kitchen units, or fixtures which are not readily
removable.
16.06.080 Section R319.1 Emergency escape and rescue openings.
Section R319.1 of the California Residential Code is amended to read:
R319.1 Emergency escape and rescue opening required. Basements,
habitable attics and every sleeping room shall have not less than one
operable emergency escape and rescue opening. Where basements
contain one or more sleeping rooms, an emergency escape and rescue
opening shall be required in each sleeping room. Emergency escape and
rescue openings shall open directly into a public way, or to a yard or court
that opens to a public way.
Exceptions:
1. Storm shelters and basements used only to house
mechanical equipment not exceeding a total floor area of 200
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square feet (18.58 m2)
16.06.090 Section R319.4.2.3 Window well fall protection.
Section R319.4.2.3 of the California Residential Code is added to read:
R319.4.2.3 Window well fall protection. Window wells with a vertical
depth greater than 30 inches shall have guards on all sides. The guards shall
be provided in accordance with Section R321.1. Openings shall comply with
Section R321.1.3. Access ladder shall comply with Section R319.4.2.1 and
shall extend from the bottom of the well to the top of the guard. Grates or
similar barriers shall not be installed over the window well.
16.06.100 Section R319.4.5 Security bars.
Section R319.4.5 of the California Residential Code is added to read:
R319.4.5 Security bars. Fire Department plan check review and approval of
all security bar submittals shall be required prior to the issuance of a
Building Permit.
16.06.110 Section R309.1.1 Design and installation.
Section 309.1.1 of the California Residential Code is amended to read:
R309.1.1 Design and installation. Where allowed, automatic sprinkler
systems installed in townhouses shall be installed throughout in
accordance with NFPA 13 and State and local standards.
16.06.120 Section R309.2 One and two-family dwellings automatic fire sprinkler
systems.
Section R309.2 of the California Residential Code is amended to read:
R309.2 One and two-family dwellings automatic fire sprinkler systems.
Approved automatic sprinkler systems in new buildings and structures and
in existing modified buildings and structures, shall be provided in the
locations described in this section. Automatic fire sprinklers shall be
installed per the requirements set forth in Sections
903.2.1 through 903.2.18 of the California Building Code and as follows,
whichever is the more restrictive:
1. An automatic sprinkler system shall be provided throughout all new
buildings and structures.
Exception: New residential occupancies, buildings or
structures that do not exceed 350 square feet of building
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area and contain no interior plumbing fixtures.
2. An automatic sprinkler system shall be provided throughout all
existing buildings when modifications are made that create an
increase in fire area to more than 3600 square feet or when the
addition is equal to or greater than 50% of the existing building
square footage, whichever is more restrictive.
3. An automatic fire sprinkler system is required in basements when
any of the following occurs:
a) New basements used for storage, utility, occupancy, or habitable space
regardless of size.
b) Existing basements that are altered for the use of storage, utility,
occupancy, or habitable space regardless of size.
c) Existing basements expanded by 50% or more.
If the addition or alteration is only the basement, then only the basement
is required to be protected by fire sprinklers.
4. An automatic fire sprinkler system is required when either the roof structure,
exterior walls, or combination of both has been removed, altered and/or
replaced in at least 50% of the existing structure.
5. An automatic sprinkler system shall be installed throughout when
any change in use or occupancy creating a more hazardous fire/life
safety condition, as determined by the Fire Chief.
16.04.130 Section R309.2.1 Design and installation.
Section R309.2.1 of the California Residential Code is amended to read as follows:
R309.2.1 Design and installation. R309.2.1 Design and installation.
Where allowed, automatic sprinkler systems installed in one-and two-
family detached dwellings shall be installed throughout in accordance
with NFPA 13D and State and local standards. Fire sprinkler protection is
required under rear covered patios extending over 4 feet perpendicular
from the exterior of the structure.
16.04.140 Section R309.2.2 NFPA 13D sprinkler systems
increase in design requirements.
Section R309.2.2 of the California Residential Code is added to read as follows:
R309.2.2 Section R309.2.2 NFPA 13D sprinkler systems increase in
design requirements. In a higher fire fighting hazardous conditions a four
head fire sprinkler calculation and coverage in all closets, bathrooms and
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attics will be required in Residential and Group U Occupancies as
determined by the Fire Code Official in the following conditions:
1. Structures located in the High Hazardous Fire Areas.
2. Structures where the combined fire area is 3600 sq ft or larger.
3. Structures located 150 ft or greater from the Fire Department access roadways.
4. Basements and below grade structures.
16.04.150 Section R309.3 Dwelling unit fire sprinkler systems.
Section R309.3 of the California Residential Code is deleted in its entirety and
amended as follows:
R309.3 Dwelling unit fire sprinkler systems. Fire sprinkler systems shall
be designed and installed in accordance with NFPA 13D, State and local
standards.
16.06.160 Section R310.1 Smoke detection and notification.
Section R310.1 of the California Residential Code is amended to read:
R310.1 Smoke detection and notification. Listed single- and multiple-
station smoke alarms complying with UL 217 shall be installed in
accordance with the California Fire Code Sections 907.2.11.1 through
907.2.11.5 and manufacturer’s installation and use instructions.
Smoke alarms and smoke detectors shall be in compliance with this code
or subject to the provisions of the Health and Safety Code, they shall also
be listed and approved for rapid response to smoldering synthetic
materials. All smoke alarms or detectors shall be of the photoelectric type
or shall have equivalent detection capabilities in compliance with UL 217.
Exception: A photoelectric smoke alarm or detector shall be
installed if located within 20 feet to a kitchen, fireplace or
woodburning stove or within 5 feet of a bathroom.
16.06.170 Section R310.1.3 Smoke alarms or detector end of life replacement.
Section R310.1.3 of the California Residential Code is added to read:
R310.1.3 Smoke alarms or detector end of life replacement . Smoke
alarms or detectors shall be replaced every 10 years or according to the
manufacture guidelines, whichever is more restrictive.
16.06.180 Section R311.7.5. Carbon Monoxide alarms.
Section R311.7.5 of the California Residential Code is added to read:
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R311.7.5 Carbon Monoxide alarms or detectors end of life replacement .
Carbon monoxide alarms or detectors shall be replaced every 10 years
or according to the manufacture guidelines, whichever is more
restrictive.
16.06.190 Section R308 - Site Address.
Section R308 of the California Residential Code is amended to read:
R308.1 Address Identification. Buildings shall be provided with approved
address identification. The address identification shall be legible and
placed in a position that is visible from the street or road fronting the
property. Address identification characters shall contrast with their
background. Address numbers shall be Arabic numbers or alphabetical
letters. Numbers shall not be spelled out. Each character shall be not less
than 4 inches (102 mm) in height with a stroke width of not less than 0.5
inch (12.7 mm). Where required by the fire code official, address
identification shall be provided in additional approved locations to
facilitate emergency response. Where access is by means of a private
road and the building address cannot be viewed from the public way, a
monument, pole or other sign or means shall be used to identify the
structure. Address identification shall be maintained.
R308.1.1 Address illumination. Address identification required by Section
R308.1 shall be illuminated.
R308.1.2 Address identification size. Address numbers and
letters shall be sized as follows:
1. When the structure is between thirty-six (36) and fifty (50) feet from the
road or other emergency means of access, a minimum of one-half inch
(0.5") stroke by six inches (6") high is required.
2. When the structure is fifty (50) or more feet from the road or other
emergency means of access, a minimum of one inch (1") stroke by nine
inches (9") high is required.
16.06.200 Section R306.1 – General (Palo Alto Flood Hazard Regulations).
The following paragraph is added to Section R306.1 of the California Residential Code:
Palo Alto Flood Hazard Regulations. Notwithstanding the provisions of
this section R306, all construction or development within a flood hazard
area (areas depicted as a Special Flood Hazard Area on Flood Insurance
Rate Maps published by the Federal Emergency Management Agency)
shall comply with the City of Palo Alto Flood Hazard Regulations (Palo Alto
Municipal Code Chapter 16.52). Where discrepancies exist between the
requirements of this code and said regulations, the more stringent
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requirements shall apply.
16.06.210 Reserved.
16.06.220 Section R401 GENERAL.
Section R401 of the California Residential Code is amended to read:
R401.1 – R401.3 {CRC text not modified}
R401.4 Soils tests. Exception is added at end of the CRC text as
follows: Exception: Refer to PAMC 16.04.450
R401.4.1 Geotechnical evaluation. When permitted by the building official or designee,
in lieu of a complete geotechnical evaluation, the load bearing values in T401.4.1(1)
shall be assumed.
T401.4.1(2), R401.4.1.1 – R401.4.2 {CRC text not modified}
16.06.225 Section R402.2.1 Materials for concrete.
Section 402.2.1 of the California Residential Code is amended to read:
R402.2.1 Materials for concrete. Materials for concrete shall comply with
the requirements of Section R608.5.1, as amended by PAMC 16.14.240.
16.06.230 Section R403 FOUNDATION.
Section R403 of the California Residential Code is amended as follows:
R403.1 – R403.1.1 {CRC text not modified}
R403.1.2 Continuous footing in Seismic Design Categories D 0, D1, and D2.
Exterior walls of buildings located in Seismic Design Categories D 0, D1 and
D2 shall be supported by continuous solid or fully grouted masonry or
concrete footings. All required interior braced wall panels in buildings
located in Seismic Design Categories D0, D1 and D2 shall be supported on
continuous foundations.
R403.1.3 Footing and stem wall reinforcing in Seismic Design Categories
D0, D1, and D2. Concrete footings located in Seismic Design Categories D 0,
D1 and D2, as established in Table R301.2(1), shall have not fewer than
three No. 4 horizontal bars. One No. 4 horizontal bar shall be installed
within 12 inches (305 mm) of the top of the stem wall and two No. 4
horizontal bars shall be located 3 to 4 inches (76 mm to 102 mm) from the
bottom of the footing.
R403.1.3.1 Concrete stem walls with concrete footings. In Seismic Design
Categories D0, D1 and D2 where a construction joint is created between a
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concrete footing and a stem wall, not fewer than one No. 4 vertical bar
shall be installed at not more than 4 feet (1219 mm) on center. The vertical
bar shall have a standard hook and extend to the bottom of the footing and
shall have support and cover as specified in Section R403.1.3.5.3 and
extend not less than 14 inches (357 mm) into the stem wall. Standard hooks
shall comply with Section R608.5.4.5. Not fewer than one No. 4 horizontal
bar shall be installed within 12 inches (305 mm) of the top of the stem wall
and two No. 4 horizontal bars shall be located 3 to 4 inches (76 mm to 102
mm) from the bottom of the footing.
R403.1.3.2 Masonry stem walls with concrete footings. In Seismic Design
Categories D0, D1 and D2 where a grouted masonry stem wall is supported on a
concrete footing, not fewer than one No. 4 vertical bar shall be installed at not more
than 4 feet (1219 mm) on center. The vertical bar shall have a standard hook and
extend to the bottom of the footing and have support and cover as specified in Section
R403.1.3.5.3 and extend not less than 14 inches (357 mm) into the stem wall. Standard
hooks shall comply with Section R608.5.4.5. Not fewer than one No. 4 horizontal bar
shall be installed within 12 inches (305 mm) of the top of the wall and two No. 4
horizontal bars shall be located 3 to 4 inches (76 mm to 102 mm) from the bottom of
the footing. Masonry stem walls shall be solid grouted.
In Seismic Design Categories D0, D1 and D2 masonry stem walls without
solid grout and vertical reinforcing are not permitted.
R403.1.3.3 – R403.1.7.4 {CRC text not modified}
R403.1.8 Foundations on expansive soils. Foundations and floor slabs for
buildings located on expansive soils shall be designed in accordance with
Section 1808.6 or Table 1809.7 of the California Building Code as amended
in Municipal Code Section 16.04.470.
R403.1.8.1 {CRC text not modified}
16.06.240 Section R404.1.3 Concrete foundation walls.
Section 404.1.3 of the California Residential Code is amended to read:
R404.1.3 Concrete Foundation Walls. Concrete foundation walls that
support light- frame walls shall be designed and constructed in accordance
with the provisions of this section, ACI 318, ACI 332, or PCA 100, as
amended by PAMC Section 16.14.240. Concrete foundation walls that
support above-grade concrete walls that are within the applicability limits
of Section R608.2 shall be designed and constructed in accordance with
the provisions of this section, ACI 318, ACI 332, or PCA 100, as amended by
PAMC Section 16.14.240. Concrete foundation walls that support above-
grade concrete walls that are not within the applicability limits of Section
R608.2 shall be designed and constructed in accordance with the
provisions of ACI 318, ACI 332, or PCA 100, as amended by PAMC Section
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16.14.240. When ACI 318, ACI 332, PCA 100 or the provisions of this
section, as amended by PAMC Section 16.14.240 are used to design
concrete foundation walls, project drawings, typical details and
specifications are not required to bear the seal of the architect or engineer
responsible for design, unless otherwise required by the state law of the
jurisdiction having authority.
16.06.250 Section R504.3.1 Projections exposed to weather.
Section R504.3.1 of the California Residential Code is added to read:
R504.3.1 Projections exposed to weather. Floor projections exposed to the weather and
sealed underneath, including but not limited to balconies, landings, decks, and stairs shall be
constructed of naturally durable wood, preservative-treated wood, corrosion-resistant (e.g.
galvanized) steel, or similar approved materials.
16.06.260 Section R506.1 General.
Section R506.1 of the California Residential Code is amended to read:
R506.1 General. Concrete slab-on-ground floors shall be designed and
constructed in accordance with the provisions of this section of ACI 332, as
amended by PAMC Section 16.14.240. Floors shall be a minimum 3 1/2
inches (89mm) thick (for expansive soils, see Section R403.1.8). The specified
compressive strength of concrete shall be as set forth in Section R402.2.
16.06.270 Section R602.10.4.5 Limits on methods GB and PCP.
Section R602.10.4.5 of the California Residential Code is added to read:
R602.10.4.5 Limits on methods GB and PCP. In Seismic Design Categories
D0, D1, and D2, Method GB is not permitted for use as an intermittent
braced wall panels, but gypsum board is permitted to be installed when
required by this Section to be placed on the opposite side of the studs form
other types of braced wall panel sheathing. In Seismic Design Categories
D0, D1, and D2, the use of Method PCP is limited to one-story single family
dwelling and accessory structures.
16.06.280 Table R602.10.3(3) Bracing requirements based on seismic design category.
Footnote e to Table R602.10.3(3) is amended to read as follows:
e. In Seismic Design Categories D0, D1 and D2, Method GB is not permitted and
PCP is limited to one-story dwellings and accessory structures.
16.06.290 Section R608.5 Materials.
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Section R608.5 of the California Residential Code is amended to read:
R608.5 Materials. Materials used in the construction of concrete walls
shall comply with this section, as amended by PAMC Chapter 16.14.240.
16.06.300 Section R703.8.5.1 Locations.
Section R703.8.5.1 of the California Residential Code is added to read:
R703.8.5.1 Locations. Flashing shall be installed at wall and roof
intersections, gutters, wherever there is a change in roof slope or direction,
and around roof openings. Where flashing is of metal, the metal shall be
corrosion resistant with a thickness of not less than
0.019 inches (0.483 mm) (e.g. no. 26 galvanized sheet) and shall be primed and
painted.
16.06.310 Reserved.
16.06.320 Section R1003.9.2.1 Repairs, replacements and alterations.
Section R1003.9.2.1 is added to the California Residential Code to read:
R1003.9.2.1 Repairs, replacements and alterations. When any repair,
replacement or alteration to the roof of an existing structure is performed,
a spark arrester shall be installed on the existing chimney in accordance
with Section R1003.9.2.
16.06.330 Section BO109 Preliminary Meeting.
Section BO109 of Appendix BO of the California Residential Code is added to read:
Section BO109.1 General. If a building permit is required at the request of
the prospective permit applicant, the building official or his or her designee
may meet with the prospective applicant to discuss plans for any proposed
work under these provisions prior to the application for the permit. The
purpose of this preliminary meeting is for the building official to gain an
understanding of the prospective applicant’s intentions for the proposed
work, and to determine, together with the prospective applicant, the
specific applicability of these provisions.
SECTION 2. The Council adopts the findings for local amendments to the
California Residential Code, 2025 Edition, attached hereto as Exhibit “A” and incorporated
herein by reference.
SECTION 3. 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
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portion or sections of the Ordinance. The Council hereby declares that it would have
adopted the Ordinance 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 4. The Council finds that the changes or modifications to the California
Residential Code adopted by this ordinance are substantially equivalent to changes or
modifications that were previously filed by the governing body of the City and were in
effect as of September 30, 2025, and are therefore exempt from the moratorium on new
residential building standards imposed by Assembly Bill 130 (2025).
SECTION 5. The Council finds that this project is exempt from the provisions of the
California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA
Guidelines, because it can be seen with certainty that there is no possibility that the
amendments herein adopted will have a significant effect on the environment.
//
//
//
//
//
//
//
//
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SECTION 6. This ordinance shall be effective on the thirty-first day after the date of its
adoption.
INTRODUCED:
PASSED:
AYES:
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
____________________________
Director of Public Works
Exhibit A
FINDINGS FOR LOCAL AMENDMENTS TO CALIFORNIA RESIDENTIAL CODE, TITLE 24,
PART 2.5
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.
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 Residential Code, Title 24, Part 2.5
Chapter(s),
Section(s),
Table(s),
Appendices
Title Add Deleted Amended Justification
(See below
for keys)
R202 Superficial floor area A, G
Table R301.2 Climatic and
Geographic Design
Criteria
C, G, T
R301.2.2.6 Irregular Buildings G
R304.5 Dwelling unit and
congregate residence
A, G
R319.1 Emergency Escape
and Rescue Openings
C, T
R319.4.2.3 Window Well Fall Protection T
R 319.4.5 Security Bars T
R309.1.1 Design and installation T
R 309.2 One and Two Family
Dwellings
Automatic Spr. Syst.
T
R309.2.1 Design and installation T
R309.2.2 NFPA 13D sprinkler increase
in design requirements
T
R309.3 Dwelling unit fire sprinkler
systems
T
R 310.1 Smoke Detection and
Notification
C, T
R310.1.3 Smoke alarms or detector
end of life replacement
T
311.7.5 Carbon monoxide alarms
or detectors end of life
replacement
T
R 308 Address identification T
R 306.1 Flood Hazard Regulations T
R401 General T, G
R402.2.1 Materials for concrete C
R403,
R403.1.2,
R403.1.3,
R403.1.3.1,
R403.1.3.2
Foundation G, T
R 403.1.8 Foundation on
expansive Soils
G, T
R404.1.3 Concrete foundation
walls
C
R 504.3.1 Projections exposed to
weather
G, T
R506.1 Concrete Floors on
ground
C
CR602.10.
4.5
Limits on methods GB
and PCP
G
Table
R602.10.3(3
)
Bracing Requirements Based
on
Seismic Design Category
G
R608.5 Materials C
R703.8.5.
1
Flashing Locations T
R1003.9.2
.1
Repairs, Replacements and
Alterations
T
Appendix
BF
Patio Covers C
Appendix
BO
Existing Building and
Structures
C, T
Appendix
BG
Sound Transmission C
Appendix
CI
Swimming Pool Safety Act C, G
BO109 Preliminary Meeting,
General
A, C, G
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 based on 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 Building Standards Code is required. Natural gas combustion and gas appliances emit a
wide range of air pollutants, such as carbon monoxide (CO), nitrogen oxides (NOx, including
nitrogen dioxide (NO2)), particulate matter (PM), and formaldehyde, which according to a UCLA
Study, have been linked to various acute and chronic health effects, and additionally exceed levels
set by national and California-based ambient air quality standards. 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, 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 construction of more energy efficient buildings can help Palo Alto reduce its share
of the GHG emissions that contribute to climate change. All-electric new buildings benefit the
health, safety, and welfare, of Palo Alto and its residents. Requiring all-electric construction,
without gas infrastructure will reduce the amount of greenhouse gas produced in Palo Alto and
will contribute to reducing the impact of climate change and the associated risks. Due to decrease
in annual rain fall, Palo Alto experiences the effect of drought and water saving more than some
other communities in California. Embodied carbon of concrete is a significant contributor to
greenhouse gas emissions and climate change, and this amendment includes a requirement to
use low-carbon concrete.
G This amendment is justified based on a local geological condition. The City of Palo Alto is
subject to earthquake hazard 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 earthquake. The other fault is
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 faults are considered major Northern California
earthquake faults which may experience rupture at any time. Thus, because the City is within a
seismic area which 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 and emergency response vehicles difficult. Palo Alto
is contiguous with the San Francisco Bay, resulting in a natural receptor for storm and wastewater
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 Code
is warranted.
Not Yet Adopted
1
0290181_20250915_ms29
Ordinance No.
Ordinance of the Council of the City of Palo Alto Repealing Chapter
16.16 of the Palo Alto Municipal Code and Amending Title 16 to Adopt
a New Chapter 16.16, California Electrical Code, 2025 Edition, and
Local Amendments and Related Findings
The Council of the City of Palo Alto does ORDAIN as follows:
SECTION 1. Chapter 16.16 of the Palo Alto Municipal Code is hereby amended by repealing
in its entirety 16.16 and adopting a new Chapter 16.16 to read as follows:
CHAPTER 16.16
CALIFORNIA ELECTRICAL CODE,
CALIFORNIA CODE OF REGULATIONS, TITLE 24, PART 3
Sections
16.16.010 2025 California Electrical Code, Title 24, Part 3 adopted and amended.
16.16.020 Cross - References to California Electrical Code.
16.16.030 Local Amendments.
16.16.040 Adoption of SECTION 89.101 GENERAL.
16.16.050 Article 89.101.3.3 Exempted from This Code.
16.16.060 Article 89.101.4 2025 California Electrical Code Annexes adopted.
16.16.070 Administration & Enforcement of 2025 California Electrical Code.
16.16.080 Article 110.13 Mounting and Cooling of Equipment.
16.16.010 2025 California Electrical Code, Cal. Code of Regs., Title 24, Part 3 adopted and
amended.
The California Electrical Code, 2025 Edition, Title 24, Part 3 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.
Unless superseded and expressly repealed, references in City of Palo Alto forms, documents and
regulations to the chapters and sections of the former California Code of Regulations, Title 24, 2022, shall
be construed to apply to the corresponding provisions contained within the California Code of
Regulations, Title 24, 2025. Ordinance No. 5568 of the City of Palo Alto and all other ordinances or parts
of ordinances in conflict herewith are hereby suspended and expressly repealed.
Wherever the phrases "California Electrical Code" or "Electrical Code" are used in this code or any
ordinance of the City, such phrases shall be deemed and construed to refer and apply to the California
Not Yet Adopted
2
0290181_20250915_ms29
Electrical Code, 2025 Edition, as adopted by this Chapter.
One copy of the California Electrical 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.
16.16.020 Cross - References to California Electrical Code.
The provisions of this Chapter contain cross-references to the provisions of the California Electrical
Code, 2025 Edition, in order to facilitate reference and comparison to those provisions.
16.16.030 Local Amendments.
The provisions of this Chapter shall constitute local amendments to the cross-referenced provisions of
the California Electrical 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.
16.16.040 Adoption of SECTION 89.101 GENERAL.
SECTION 89.101 GENERAL of the 2025 California Electrical Code is adopted by the City of Palo Alto
as amended herein.
16.16.050 Article 89.101.3.3 Exempted from This Code.
Section 89.101.3.3 is amended as follows (additions underlined; sections omitted without change
noted by [. . .]):
89.101.3.3 Exempted from This Code.
This code does not cover:
1. Installations in ships, watercraft other than floating dwelling units, railway rolling stock,
aircraft, automotive vehicles, commercial coaches, mobile homes, and recreational
vehicles.
[. . .]
7. ADDITIONAL EXEMPTIONS: Electrical work that is exempt from permits pursuant to Palo
Alto Municipal Code Section 16.04.110, Section 105.2 Work exempt from permit.
16.16.060 Article 89.101.4 2025 California Electrical Code Annexes adopted.
The following Annexes of the California Electrical Code, 2025 Edition, are adopted and hereby
incorporated in this Chapter by reference and made a part hereof the same as if fully set forth
herein:
A. Annex B – Application Information for Ampacity Calculations
B. Annex C – Conduit, Tubing, and Cable Tray Fill Tables for Conductors and Fixture Wires of
the Same Size
Annex I – Unit Recommended Tightening Torque Tables from UL Standard486A - 486B
Not Yet Adopted
3
0290181_20250915_ms29
16.16.070 Administration & Enforcement of 2025 California Electrical 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.
16.16.080 Article 110.13 Mounting and Cooling of Equipment.
Article 110.13 (A) (1) of Article 110 of the California Electrical Code is added to read:
110.13 (A) (1) Concrete Slab Supporting Electrical Equipment. When electrical equipment is to
be placed on a concrete substrate, a 4-inch concrete housekeeping pad shall be installed to
elevate and protect the equipment.
SECTION 2. The Council adopts the findings for local amendments to the California
Electrical Code, 2025 Edition, attached hereto as Exhibit “A” and incorporated herein by reference.
SECTION 3. The Council finds that the changes or modifications to the California
Electrical Code adopted by this ordinance are substantially equivalent to changes or modifications
that were previously filed by the governing body of the City and were in effect as of September 30,
2025, and are therefore exempt from the moratorium on new residential building standards
imposed by Assembly Bill 130 (2025).
SECTION 4. The Council finds that this ordinance is exempt from the provisions of the
California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA Guidelines,
because it can be seen with certainty that there is no possibility that the amendments herein adopted
will have a significant effect on the environment.
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 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.
//
//
//
//
//
Not Yet Adopted
4
0290181_20250915_ms29
SECTION 6. This Ordinance shall be effective on the thirty-first day after the date of its
adoption.
INTRODUCED:
PASSED:
AYES:
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
Not Yet Adopted
5
0290181_20250915_ms29
Exhibit A
FINDINGS FOR LOCAL AMENDMENTS TO CALIFORNIA ELECTRICAL CODE,
TITLE 24, PART 3
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.
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 Electrical Code, Title, 24, Part 3
Section(s)
or Article(s)
Title Added Amended Deleted Justification
(See below
for keys)
89.101 GENERAL A
89.101.3.3 Exempt from This Code A
110.13 (A) (1) Mounting and Cooling of Equipment C
Annex B Application Information for
Ampacity Calculations
G
Annex C Conduit, Tubing, and Cable Tray Fill Tables
for Conductors and Fixture Wires of the
Same Size
A
Annex I Unit Recommended Tightening Torque
Tables
from UL Standard 486A - 486B
A
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 based on 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 Building Standards Code is required.
G This amendment is justified based on a local geological condition. The City of Palo Alto is
subject to earthquake hazard 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
earthquake. The other fault is 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
faults are considered major Northern California earthquake faults which may experience
rupture at any time. Thus, because the City is within a seismic area which 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 and emergency response vehicles difficult.
Palo Alto is contiguous with the San Francisco Bay, resulting in a natural receptor for
storm and wastewater 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 Code is warranted
6
0290181_20250915_ms29
NOT YET APPROVED
1
0290180_20250915_ms29
Ordinance No.
Ordinance of the Council of the City of Palo Alto Repealing Chapter
16.05 of the Palo Alto Municipal Code and Amending Title 16 to Adopt a
New Chapter 16.05, California Mechanical Code, 2025 Edition,
and Local Amendments and Related Findings
The Council of the City of Palo Alto does ORDAIN as follows:
SECTION 1. Chapter 16.05 of the Palo Alto Municipal Code is hereby amended by
repealing in its entirety 16.05 and adopting a new Chapter 16.05 to read as follows:
CHAPTER 16.05
CALIFORNIA MECHANICAL CODE,
CALIFORNIA CODE OF REGULATIONS, TITLE 24, PART 4
Sections
16.05.010 2025 California Mechanical Code, Title 24, Part 4 adopted and amended.
16.05.020 Cross - References to California Mechanical Code.
16.05.030 Local Amendments.
16.05.040 Administration & Enforcement of 2025 California Mechanical Code.
16.05.045 Adoption of Chapter 1, Division II Administration.
16.05.050 Section 102.8 Appendices.
16.05.060 Section 104.2 Exempt from this code.
16.05.070 Section 510.7 Interior installations.
16.05.010 2025 California Mechanical Code, Title 24, Part 4 adopted and amended.
The California Mechanical Code, 2025 Edition, Title 24, Part 4 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.
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. 5565 of the City of Palo Alto and all other
ordinances or parts of ordinances in conflict herewith are hereby suspended and expressly repealed.
Wherever the phrases "California Mechanical Code" or "Mechanical Code" are used in this code
or any ordinance of the City, such phrases shall be deemed and construed to refer and apply to
the California Mechanical Code, 2025 Edition, Title 24, Part 4 of the California Code of Regulations,
as adopted by this Chapter.
One copy of the California Mechanical Code, 2025 edition, has been filed for use and examination
of the public in the Office of the Building Official of the City of Palo Alto.
NOT YET APPROVED
2
0290180_20250915_ms29
16.05.020 Cross - References to California Mechanical Code.
The provisions of this Chapter contain cross-references to the provisions of the California
Mechanical Code, 2025 Edition, in order to facilitate reference and comparison to those provisions.
16.05.030 Local Amendments.
The provisions of this Chapter shall constitute local amendments to the cross-referenced provisions of
the California Mechanical 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.
16.05.040 Administration & Enforcement of 2025 California Mechanical 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.
16.05.045 Adoption of Chapter 1, Division II Administration.
Chapter 1, Division II Administration of the 2025 California Mechanical Code is adopted by the City
of Palo Alto to supplement, to the extent it does not conflict with, Chapter 1, Division II of the 2025
California Building Code, as amended.
16.05.050 Section 102.8 Appendices.
The following Appendix Chapters of the California Mechanical Code, 2025 Edition, are adopted and
hereby incorporated in this Chapter by reference and made a part hereof the same as if fully set
forth herein:
A. Appendix B – Procedures to be followed to place gas equipment in operation
B. Appendix C – Installation and testing of oil (liquid) fuel-fired equipment
16.05.060 Section 104.2 Exempt from this code.
Subdivision (6) of Section 104.2 of Chapter 1 of the California Mechanical Code is added to read:
(6) ADDITIONAL EXCEPTIONS: Reference Mechanical Section under PAMC 16.04.110 Section 105.2
Work exempt from permit.
16.05.070 Section 510.7 Interior installations.
Section 510.7 of Chapter 5 of the California Mechanical Code is amended to read:
Section 510.7 Interior installations. In all buildings, the ducts shall be enclosed in a
continuous enclosure extending from the lowest fire-rated ceiling or floor above the hood,
through any concealed spaces, to or through the roof so as to maintain the
NOT YET APPROVED
3
0290180_20250915_ms29
integrity of the fire separations required by the applicable building code provisions. The
enclosure shall be sealed around the duct at the point of penetration of the lowest fire-rated
ceiling or floor above the hood in order to maintain the fire resistance rating of the enclosure
and shall be vented to the exterior of the building through weather-protected openings.
[NFPA 96:7.7.1.2 – 7.7.1.4]
SECTION 2. The Council adopts the findings for local amendments to the California
Mechanical Code, 2025 Edition, attached hereto as Exhibit “A” and incorporated herein by
reference.
SECTION 3. The Council finds that the changes or modifications to the California
Mechanical Code adopted by this ordinance are substantially equivalent to changes or
modifications that were previously filed by the governing body of the City and were in effect as of
September 30, 2025, and are therefore exempt from the moratorium on new residential building
standards imposed by Assembly Bill 130 (2025).
SECTION 4. The Council finds that this project is exempt from the provisions of the
California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA Guidelines,
because it can be seen with certainty that there is no possibility that the amendments herein
adopted will have a significant effect on the environment.
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
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.
//
//
//
//
//
//
//
//
//
NOT YET APPROVED
4
0290180_20250915_ms29
SECTION 6. This Ordinance shall be effective on the thirty-first day after the date of its
adoption.
INTRODUCED:
PASSED:
AYES:
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
NOT YET APPROVED
5
0290180_20250915_ms29
Exhibit A
FINDINGS FOR LOCAL AMENDMENTS TO CALIFORNIA MECHANICAL CODE,
TITLE 24, PART 4
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.
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 Mechanical Code, Title, 24, Part 4
Chapter(s),
Sections(s),
Appendices
Title Added Amended Replaced Justification
(See below
for keys)
Ch. 1, Div. II ADMINSTRATION A
102.8 Appendices A
Administration and Enforcement A
104.2 Exempt from this code A
510.7 Interior installations G
Appx. B Procedures to be followed to place gas
equipment in operation
A
Appx. C Installation and testing of oil (liquid) fuel-
fired equipment
A
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 based on 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 Building Standards Code is required.
G This amendment is justified based on a local geological condition. The City of Palo Alto is subject to earthquake hazard 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 earthquake. The other fault is 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 faults are considered major Northern California earthquake faults which may experience rupture at any time. Thus, because the City is within a seismic area which 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 and emergency response vehicles difficult. Palo Alto is contiguous with the San Francisco Bay, resulting in a natural receptor for storm and wastewater 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 Code is warranted.
5
0290180_20250915_ms29
*NOT YET APPROVED*
1
0290183_20250918_ms29
Ordinance No.
Ordinance of the Council of the City of Palo Alto Repealing
Chapter 16.08 of the Palo Alto Municipal Code and Amending Title
16 to Adopt a New Chapter 16.08, California Plumbing Code, 2025
Edition, and Local Amendments and Related Findings
The Council of the City of Palo Alto does ORDAIN as follows:
SECTION 1. Chapter 16.08 of the Palo Alto Municipal Code is hereby amended by
repealing in its entirety 16.08 and adopting a new Chapter 16.08 to read as follows:
CHAPTER 16.08
CALIFORNIA PLUMBING CODE,
CALIFORNIA CODE OF REGULATIONS, TITLE 24, PART 5
Sections
16.08.010 2025 California Plumbing Code, Title 24, Part 5 adopted and amended.
16.08.020 Cross - References to California Plumbing Code.
16.08.030 Local Amendments.
16.08.040 Administration & Enforcement of 2025 California Plumbing Code.
16.08.050 Adoption of Chapter 1, Division II Administration.
16.08.060 Section 102.8 Appendices.
16.08.070 Section 306.3 Palo Alto sewer use.
16.08.080 Section 701.2, (4) Drainage piping.
16.08.090 Section 719.7 Cleanouts.
16.08.100 Section 808.2 Single pass cooling water systems prohibited.
16.08.110 Section 1014.1 Grease Interceptors - General.
16.08.115 Section 1014.2.1.1 Grease Capacity
16.08.120 Section 1101.4 Material use.
16.08.130 Section 1101.4.1 Copper and copper alloys.
16.08.140 Section 1101.4.2 Conductors.
16.08.150 Section 1101.4.3 Leaders.
16.08.160 Section 1102.1 Applications.
*NOT YET APPROVED*
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0290183_20250918_ms29
16.08.010 2025 California Plumbing Code, Title 24, Part 5 adopted and amended.
The California Plumbing Code, 2025 Edition, Title 24, Part 5 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.
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. 5567 of the City of
Palo Alto and all other ordinances or parts of ordinances in conflict herewith are hereby
suspended and expressly repealed.
Wherever the phrases "California Plumbing Code" or "Plumbing Code" are used in this code
or any ordinance of the City, such phrases shall be deemed and construed to refer and apply
to the California Plumbing Code, 2025 Edition, Title 24, Part 4 of the California Code of
Regulations, as adopted by this Chapter.
One copy of the California Plumbing Code, 2025 edition, has been filed for use and examination
of the public in the Office of the Building Official of the City of Palo Alto.
16.08.020 Cross - References to California Plumbing Code.
The provisions of this Chapter contain cross-references to the provisions of the California
Plumbing Code, 2025 Edition, in order to facilitate reference and comparison to those
provisions.
16.08.030 Local Amendments.
The provisions of this Chapter shall constitute local amendments to the cross-referenced
provisions of the California Plumbing 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.
Where used in this Chapter 16.08, ellipses shall indicate text of the California Plumbing Code,
2025 Edition, that has been adopted without amendment but is omitted for brevity.
16.08.040 Administration & Enforcement of 2025 California Plumbing 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.
16.08.050 Adoption of Chapter 1, Division II Administration.
Chapter 1, Division II Administration of the 2025 California Plumbing Code is adopted by the
City of Palo Alto to supplement, to the extent it does not conflict with, Chapter 1, Division II
of the 2025 California Building Code as amended.
16.08.060 Section 102.8 Appendices.
*NOT YET APPROVED*
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0290183_20250918_ms29
The following Appendix Chapters of the California Plumbing Code, 2025 Edition, are adopted
and hereby incorporated in this Chapter by reference and made a part hereof the same as if
fully set forth herein:
A. Appendix A – Recommended rules for sizing the water supply system
B. Appendix D – Sizing storm water drainage systems
16.08.070 Section 306.3 Palo Alto sewer use.
Section 306.3 of Chapter 3 of the California Plumbing Code is added to read:
306.3 Palo Alto sewer use. All non-domestic waste shall comply with the City of Palo Alto Sewer
Use Ordinance (Palo Alto Municipal Code Chapter 16.09). Where discrepancies exist between
the requirements of this code and said ordinance, the provisions of said ordinance shall apply.
16.08.080 Section 701.2, (4) Drainage piping.
Subdivsion (4) of Section 701.2 of Chapter 7 of the California Plumbing Code is amended to
read:
701.2 Drainage Piping
Materials for drainage piping shall be in accordance with one of the referenced
standards in Table 701.2 except that:
[. . .]
(4) Copper, copper alloys, lead and lead alloys, including brass, shall not be used for
building sanitary drainage lines, connectors or seals coming in contact with sewage
except for domestic waste sink traps and short lengths of associated connecting pipes
where alternate materials are impracticable.
Where permitted by the building official or their designee, copper tube for drainage
piping shall have a weight of not less than that of copper drainage tube type DWV.
[. . .]
16.08.090 Section 719.7 Cleanouts.
Section 719.7 of Chapter 7 of the California Plumbing Code is added to read:
719.7 Cleanouts. A cleanout shall be provided at the point of connection between the
building sewer and the city lateral and an approved fitting shall be used to bring the
cleanout riser to grade. Where sewer cleanouts are to be connected to existing city
laterals, such connections shall be accomplished by use of a City of Palo Alto Utility
approved fitting.
*NOT YET APPROVED*
4
0290183_20250918_ms29
16.08.100 Section 808.2 Single pass cooling water systems prohibited.
Section 808.2 of Chapter 8 of the California Plumbing Code is added to read:
808.2 Single pass cooling water systems prohibited. Clean running water used
exclusively as a cooling medium in an appliance, device, or apparatus is prohibited.
Refer to PAMC 16.14.350 for additional CALGreen measures.
16.08.110 Section 1014.1 Grease Interceptors - General
Section 1014.1 of Chapter 10 of the California Plumbing Code is amended to read as follows
(additions to the 2025 California Plumbing code are underlined, deletions are struck through):
1014.1 General. Where it is determined by the Authority Having Jurisdiction that
waste pretreatment is required, an approved type of grease interceptor(s) shall
comply with ASME A112.14.3, ASME A112.14.4, CSA B481, ANSI/CAN/IAPMO Z1001,
PDI G-101, or PDI G-102, and sized in accordance with Sections 1014.2.1 and
1014.2.1.1 or Section 1014.3.6, shall be installed in accordance with the
manufacturer’s installation instructions to receive the drainage from fixtures or
equipment that produce grease-laden waste. Grease-laden waste fixtures shall
include, but not be limited to, sinks and drains, such as floor drains, floor sinks, and
other fixtures or equipment in serving establishments, such as restaurants, cafes,
lunch counters, cafeterias, bars and clubs, hotels, hospitals, sanitariums, factory or
school kitchens, or other establishments where grease is introduced into the drainage
or sewage system in quantities that can effect line stoppage or hinder sewage
treatment or private sewage disposal systems. A combination of hydromechanical,
gravity grease interceptors and engineered systems shall be allowed to meet this code
and other applicable requirements of the Authority Having Jurisdiction where space
or existing physical constraints of existing buildings necessitate such installations. A
grease interceptor shall not be required for individual dwelling units or private living
quarters. Water closets, urinals, and other plumbing fixtures conveying human waste
shall not drain into or through the grease interceptor.
[…]
1014.1.2 Maintenance. Grease interceptors shall be maintained in efficient operating
condition by periodic removal of the accumulated grease and latent material. No such
collected grease shall be introduced into drainage piping or a public or private sewer.
Where the Authority Having Jurisdiction determines that a grease interceptor is not
being properly cleaned or maintained, the Authority Having Jurisdiction shall have the
authority to mandate the installation of additional equipment or devices. The
Authority Having Jurisdiction shall have the authority and to mandate a maintenance
program for grease interceptors.
1014.1.3 Food Waste Disposers and Dishwashers.
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Unless specifically required or permitted by the Authority Having Jurisdiction, no No
food waste disposer or dishwasher shall be connected to or discharge into a grease
interceptor. Commercial food waste disposers shall be permitted to discharge directly
into the building’s drainage system. Commercial Food Waste Disposal Units are
prohibited.
Exception: Food waste disposers shall be permitted to discharge to grease
interceptors that are designed to receive the discharge of food waste.
1014.1.4 Wastewater Discharge through Grease Interceptors. Wastewater
Discharge through grease interceptors shall be by means of gravity only. Unless
otherwise approved by the Authority Having Jurisdiction, mechanical pumping of
wastewater through a grease interceptor shall not be allowed. Pumps and/or other
mechanical pumping equipment to convey wastewater shall only be installed to
convey wastewater after the wastewater has passed through the grease interceptor.
1014.1.5 Two-Way Lateral Cleanouts. Two-way Lateral cleanouts shall be installed on
the inlet and outlet sides of grease interceptors for ease of maintenance and flushing
of the lateral line(s).
1014.1.6 Acceptable Materials. Grease interceptors made of the following materials
shall not be installed in the City: materials susceptible to corrosion in low pH
environments, concrete, metal, and acid-resistant enamel or epoxy (A.R.E.) coatings.
Examples of acceptable materials of construction include thermoplastic (low or high-
density polyethylene) or similar non-corrosive materials.
1014.1.7 Sharing of Grease Interceptors Prohibited. Unless specifically required or
permitted by the Authority Having Jurisdiction, a grease interceptor may be used by
only one food facility. Sharing grease interceptors between multiple food facilities is
prohibited.
16.08.115 Section 1014.2.1.1 Grease Capacity
Section 1014.2.1.1 of Chapter 10 of the California Plumbing Code is added to read:
1014.2.1.1 Grease Capacity. In addition to the sizing criteria based on flow rate specified
in Section 1014.2.1, hydromechanical grease interceptors shall meet the sizing criteria
based on grease capacity outlined in the “Palo Alto Regulations for Food Facilities
Related to Water Pollution Prevention and Management of Fats, Oils, and Grease.” The
correctly sized grease interceptor will have both the minimum flow rate determined
according to Section 1014.2.1 and the minimum grease storage capacity determined
according to this section.
16.08.120 Section 1101.4 Material use.
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0290183_20250918_ms29
Section 1101.4 of Chapter 11 of the California Plumbing Code is amended to read:
1101.4 Material use. Pipe, tube, and fittings conveying rainwater shall be of such
materials and design as to perform their intended function to the satisfaction of
the Authority Having Jurisdiction. Conductors within a vent or shaft shall be of cast-
iron, galvanized steel, wrought iron, Schedule 40 ABS DWV, Schedule 40 PVC DWV,
stainless steel 304 or 316L [stainless steel 304 pipe and fittings shall not be installed
underground and shall be kept not less than 6 inches (152 mm)
aboveground], or other approved materials, and changes in direction shall be in
accordance with the requirements of Section 706.0. ABS and PVC DWV piping
installations shall be installed in accordance with applicable standards referenced in
Chapter 17 and the firestop protection requirements in the California Building Code.
Except for individual single- family dwelling units, materials exposed within ducts or
plenums shall have a flame- spread index of not more than 25 and a smoke-developed
index of not more than 50, where tested in accordance with ASTM E84 or UL 723.
Plastic piping installed in plenums shall be tested in accordance with all requirements
of ASTM E84 or UL 723. Mounting methods, supports and sample sizes of materials for
testing that are not specified in ASTM E84 or UL 723 shall be prohibited.
[HCD 1 & HCD 2] ABS or PVC installations are limited to not more than two stories of
areas of residential accommodation.
[OSHPD 1, 2, 3 & 4] ABS and PVC installations are not allowed.
16.08.130 Section 1101.4.1 Copper and copper alloys.
Section 1101.4.1 of Chapter 11 of the California Plumbing Code is amended to read:
1101.4.1 Copper and copper alloys. Joints and connections in copper and copper
alloy pipe and tube is prohibited.
16.08.140 Section 1101.4.2 Conductors.
Section 1101.4.2 of Chapter 11 of the California Plumbing Code is amended to read:
1101.4.2 Conductors. Conductors installed aboveground in buildings shall comply with
the applicable standards referenced in Table 701.2 for aboveground drain, waste, and
vent pipe. Conductors installed aboveground level shall be of Schedule 40 copper pipe or
Schedule 40 copper alloy pipe; service weight cast-iron soil pipe or hubless cast-iron
soil pipe; standard weight galvanized steel pipe; stainless steel 304 or 316L [stainless
steel 304 pipe and fittings shall not be installed underground and shall be kept not less
than 6 inches (152 mm) aboveground], or Schedule 40 ABS or Schedule 40 PVC plastic
pipe.
16.08.150 Section 1101.4.3 Leaders.
Section 1101.4.3 of Chapter 11 of the California Plumbing Code is amended to read:
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1101.4.3 Leaders. Leaders installed outside shall be in accordance with the applicable
standards referenced in Table 701.2 for aboveground drain, waste, and vent pipe;
aluminum sheet metal; or galvanized steel sheet metal.
16.08.160 Section 1102.1 Applications.
Section 1102.1 of Chapter 11 of the California Plumbing Code is amended to read:
1102.1 Applications. Roof drains shall be constructed of aluminum, cast-iron, stainless
steel, ABS, PVC, polypropylene, polyethylene, or nylon and shall comply with ASME
A112.3.1 or ASME A112.6.4.
SECTION 2. The Council adopts the findings for local amendments to the California
Plumbing Code, 2025 Edition, attached hereto as Exhibit “A” and incorporated herein by
reference.
SECTION 3. The Council finds that, with the exception of the changes codified at
PAMC Section 16.08.110 and 16.08.115, the changes or modifications to the California Plumbing
Code adopted by this ordinance are substantially equivalent to changes or modifications that
were previously filed by the governing body of the City and were in effect as of September 30,
2025, and are therefore exempt from the moratorium on new residential building standards
imposed by Assembly Bill (AB) 130 (2025). The changes codified at PAMC Section 16.08.110 and
16.08.115 do not affect residential units and are therefore not subject to the AB 130
moratorium.
SECTION 4. The Council finds that this project is exempt from the provisions of the
California Environmental Quality Act (“CEQA”) pursuant to Section 15308 of the CEQA
Guidelines, because it is an action by the City as a regulatory body for the protection of the
environment, and Section 15061 of the CEQA Guidelines, because it can be seen with certainty
that there is no possibility that the amendments herein adopted will have a significant effect
on the environment.
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 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.
//
//
*NOT YET APPROVED*
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SECTION 6. This Ordinance shall be effective on the thirty-first day after the date of its
adoption.
INTRODUCED:
PASSED:
AYES:
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
____________________________
Director of Public Works
*NOT YET APPROVED*
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0290183_20250918_ms29
Exhibit A
FINDINGS FOR LOCAL AMENDMENTS TO CALIFORNIA PLUMBING CODE,
TITLE 24, PART 5
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.
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 Plumbing Code, Title, 24, Part 5
Chapter(s),
Sections(s),
Appendices
Title Added Amended Replaced Justification
(See below
for keys)
Ch. 1, Div. II ADMINSTRATION A
Administration and Enforcement A
306.3 Palo Alto sewer use C
701.2 (4) Drainage piping C
719.7 Cleanouts C
808.2 Single pass cooling water systems
prohibited
C
1014.1 Grease Interceptors - General C, T
1014.2.1.1 Grease Capacity C, T
1101.4 Material use C
1101.4.1 Copper and copper alloys C
1101.4.2 Conductors C
1101.4.3 Leaders C
1102.1 Applications C
Appx. A Recommended rules for sizing the water
supply system
A, C, T
*NOT YET APPROVED*
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Appx. D Sizing storm water drainage systems A, C, T
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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 based on 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 Building Standards Code is required. In addition, Palo Alto’s local climatic conditions
create unique challenges for grease management in the sewer system. Heavy winter rains
contribute to infiltration and inflow, increasing flows that reduce the system’s tolerance for
blockages and making effective grease control devices (GCDs) critical to preventing backups and
overflows. Seasonal temperature variations further exacerbate the risk: hot summer conditions
can liquefy grease, allowing it to migrate through pipes, while cooler winter conditions cause
grease to solidify, increasing the likelihood of blockages. Bay-influenced humidity and saline air
accelerate corrosion of interceptor components and piping, making it necessary to prohibit
materials susceptible to corrosion in low-pH environments to ensure long-term reliability of
GCDs.
G This amendment is justified based on a local geological condition. The City of Palo Alto is
subject to earthquake hazard 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 earthquake. The other fault is
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 faults are considered major Northern California
earthquake faults which may experience rupture at any time. Thus, because the City is within a
seismic area which 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 and emergency response vehicles difficult. Palo Alto
is contiguous with the San Francisco Bay, resulting in a natural receptor for storm and wastewater
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 Code
is warranted. In addition, much of Palo Alto has very low slope gradients. In flatter areas, sanitary
sewer lines experience reduced flow velocity. This condition increases the risk of grease
NOT YET APPROVED
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accumulation and blockages in the system, making the use of appropriately sized grease
interceptors more critical.
*NOT YET APPROVED*
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Ordinance No. ____
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
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 Ac on 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 ac ons in eight areas, one of which is energy and more
specifically, energy efficiency and electrifica on. 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 reduc on) and to
modernize the electric grid to support increased electric demand to accommodate state-
of-the-art technology.
C. One key ac on 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 electrifica on in both exis ng buildings and new
construc on projects where feasible.
D. The purpose of this ordinance is to formally adopt California Code of Regula ons, 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 restric ve than
the building standards in Title 24, Part 6.
E. This ordinance is intended to supplement, not to supersede, Ordinance 5565, which was
passed by the Council on September 8, 2025 and which adopted the 2025 California
Energy Code along with local amendments related to FlexPath and Air Condi oner Time-
of-Replacement Requirements.
F. Recent legisla on, Assembly Bill (AB) 130 (2025), limits local jurisdic ons’ authority to
amend the California Building Standards Code beginning October 1, 2025, and ending
June 1, 2031. The Council finds that to the extent they affect residen al units, the
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changes or modifica ons to the California Energy Code (Title 24, Part 6) adopted by this
ordinance are substan ally equivalent to changes or modifica ons that were previously
filed by the governing body of the City and were in effect as of September 30, 2025, and
are therefore exempt from the moratorium on new residen al building standards
imposed by AB 130.
G. Addi onally, the Council finds that these changes or modifica ons 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 residen al construc on consistent with federal law while also incen vizing all-
electric construc on as part of an adopted greenhouse gas emissions reduc on 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-effec ve renewable resources”) and Goal N-8 (“Ac vely support
regional efforts to reduce our contribu on to climate change while adap ng to the
effects of climate change on land uses and city services”) and associated policies and
programs. These include Policy N-7.4 (“Maximize the conserva on and efficient use of
energy in new and exis ng residences and other buildings in Palo Alto”), Program N-
7.4.1 (“Con nue mely incorpora on of State and federal energy efficiency standards
and policies in relevant City codes, regula ons and procedures and higher local
efficiency standards that are cost-effec ve”), Policy N-7.7: (“Explore a variety of cost-
effec ve ways to reduce natural gas usage in exis ng 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 Ac on Plan (S/CAP) and its
subsequent updates and other future planning efforts, reduce greenhouse gas emissions
from City opera ons and from the community”). The amendments herein promote
building electrifica on by imposing broader electric readiness requirements than the
California Energy Code.
H. California Health and Safety Code sec ons 17958.5 and 17958.7 require that the City, in
order to make changes or modifica ons in the requirements contained in the California
Building Standards Code on the basis of local condi ons, make express finding that such
modifica ons or changes are reasonably necessary because of local clima c, geological
or topographical condi ons. The required findings are a ached to this ordinance as
Exhibit A.
SECTION 2. Sec on 16.17.070 of the Palo Alto Municipal Code is hereby amended to
read as follows:
*NOT YET APPROVED*
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0290184_20250918_ms29
16.17.070 Section 110.10 MANDATORY REQUIREMENTS FOR SOLAR READY BUILDINGS
Section 110.10 of Subchapter 2 of the California Energy Code is amended by adding Section
110.10 (f) to read:
(f) Existing tree canopies. In the event of a conflict between the provisions of this Code, the
Solar Shade Act of 2009, and the Palo Alto Tree Ordinance (Chapter 8.10), the most
protective of existing tree canopies shall prevail.
SECTION 3. Sec on 16.17.080 of the Palo Alto Municipal Code is hereby amended to
read as follows:
16.17.080 SUBCHAPTER 3 NONRESIDENTIAL, HOTEL/MOTEL OCCUPANCIES, AND
COVERED PROCESSES—MANDATORY REQUIREMENTS
SECTION 120.0 NONRESIDENTIAL, HOTEL/MOTEL OCCUPANCIES, AND COVERED
PROCESSES—MANDATORY REQUIREMENTS – GENERAL.
Section 120.0 of Subchapter 3 of the California Energy Code is amended to read:
Sections 120.1 through 120.10 establish requirements for the design and
installation of building envelopes, ventilation, space-conditioning and service
water-heating systems and equipment in nonresidential and hotel/motel
buildings as well as covered processes that are within the scope of Section
100.0(a).
Note: The requirements of Sections 120.1 through 120.10 apply to newly
constructed buildings. Section 141.0 specifies which requirements of Sections
120.1 through 120.10 also apply to additions or alterations to existing buildings.
The electric readiness requirements specified in Section 120.6 (k) and Section
120.6 (l) apply to substantial remodels.
SECTION 4. Sec on 16.17.090 of the Palo Alto Municipal Code is hereby amended to
read as follows:
16.17.090 SECTION 120.6(l) ELECTRIC READINESS REQUIREMENTS FOR SYSTEMS USING GAS
OR PROPANE
Subchapter 3 of the California Energy Code is amended to add Section 120.6(l) to be
numbered, entitled, and to read:
120.6(l) ELECTRIC READINESS REQUIREMENTS FOR SYSTEMS USING GAS OR PROPANE
*NOT YET APPROVED*
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Where nonresidential systems using gas or propane are installed, the construction
drawings shall indicate electrical infrastructure and physical space
accommodating the future installation of an electric appliance in the following
ways, as certified by a registered design professional or licensed electrical
contractor.
a) Branch circuit wiring, electrically isolated and designed to serve all electric
heating appliances in accordance with manufacturer requirements and
the California Electrical Code, including the appropriate voltage, phase,
minimum amperage, and an electrical receptacle or junction box within
five feet of the appliance that is accessible with no obstructions.
Appropriately sized conduit may be installed in lieu of conductors; and
b) Labeling of both ends of the unused conductors or conduit shall be with
“For Future Electrical Appliance”; and
c) Reserved circuit breakers in the electrical panel for each branch circuit,
appropriately labeled (e.g. “Reserved for Future Electrical Appliance”),
and positioned on the opposite end of the panel supply conductor
connection; and
d) Connected subpanels, panelboards, switchboards, busbars, and
transformers shall be sized to serve the future electric heating appliances.
The electrical capacity requirements shall be adjusted for demand factors
in accordance with the California Electrical Code; and
e) Physical space for future electric appliances, including equipment
footprint, and if needed a pathway reserved for routing of ductwork to heat
pump evaporator(s), shall be depicted on the construction drawings. The
footprint necessary for future electric appliances may overlap with non-
structural partitions and with the location of currently designed
combustion equipment.
SECTION 5. Sec on 16.17.150 of the Palo Alto Municipal Code is hereby amended to
read as follows:
16.17.150 SECTION 160.9 MANDATORY REQUIREMENTS FOR ELECTRIC READY BUILDINGS
Section 160.9 of Subchapter 10 of the California Energy Code is amended to read:
Mandatory requirements for electric-ready buildings apply to newly constructed
buildings and substantial remodels.
Section 160.9 Sections (a) – (f) are adopted without amendments.
*NOT YET APPROVED*
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0290184_20250918_ms29
SECTION 6. 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 7. If any sec on, subsec on, clause or phrase of this Ordinance is for any reason
held to be invalid, such decision shall not affect the validity of the remaining por on or sec ons
of the Ordinance. The Council hereby declares that it would have adopted the Ordinance and
each sec on, subsec on, sentence, clause or phrase thereof irrespec ve of the fact that any one
or more sec ons, subsec ons, sentences, clauses or phrases be declared invalid.
SECTION 8. 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.
//
//
//
//
//
//
//
//
*NOT YET APPROVED*
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0290184_20250918_ms29
SECTION 9. This Ordinance shall be effective on the thirty-first day after the date of
its adoption.
INTRODUCED:
PASSED:
AYES:
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
____________________________
Director of Public Works
*NOT YET APPROVED*
7
0290184_20250918_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)
110.10 (f) Existing tree canopies C & E
120.0 Nonresidential, Hotel/Motel
Occupancies, and Covered
Processes—Mandatory
Requirements
C & E
120.6(l) Electric Readiness Requirements
for Systems Using Gas or Propane
C & E
160.9 Mandatory Requirements for
Electric Ready Buildings
C & E
*NOT YET APPROVED*
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0290184_20250918_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.
*NOT YET APPROVED*
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0290184_20250918_ms29
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 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.
NOT YET ADOPTED
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0290182_20250918_ms29
Ordinance No.
Ordinance of the Council of the City of Palo Alto Repealing
Chapter 16.18 of the Palo Alto Municipal Code and Adopting a
New Chapter 16.18, International Swimming Pool and Spa Code,
With Local Amendments
The Council of the City of Palo Alto does ORDAIN as follows:
SECTION 1. Chapter 16.18 of the Palo Alto Municipal Code is hereby amended by
repealing it in its entirety and adopting a new Chapter 16.18 to read as follows:
CHAPTER 16.18
2024 International Swimming Pool and Spa Code (ISPSC)
Sections
16.18.010 2024 International Swimming Pool and Spa Code (ISPSC) adopted in part and
amended.
16.18.020 Violations -- Penalties.
16.18.030 Enforcement -- Criminal Enforcement Authority.
16.18.040 References to California Building Codes.
16.18.050 Precedence of California Building Codes.
16.18.060 Administration & Enforcement of 2024 International Swimming Pool and Spa
Code (ISPSC)
16.18.070 Section 101.1 Title.
16.08.080 Section 105.1.1 Agreements to build; notice of provisions.
16.18.090 Section 110.17 Final approval.
16.18.100 Section 301.1.2 Conflicts.
16.18.110 Section 303.3.1 Operating time.
16.18.120 Section 303.1.3 Covers.
16.18.130 Section 305.2 Outdoor swimming pools and spas.
16.18.140 Section 305.9 Private swimming pools.
16.18.150 Section 305.10 Enclosure.
16.18.160 Section 311.2 Construction requirements for building a pool or spa.
16.18.170 Section 317.2.1 Certification and installation.
16.18.180 Section 504.1 Emergency shutoff switch.
16.18.190 Section 903 to 908.
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16.18.010 2024 International Swimming Pool and Spa Code (ISPSC) adopted in part
and amended.
Chapters 1 through 3 and chapters 7 through 11 of the International Swimming Pool and Spa
Code, 2024 Edition, are adopted and hereby incorporated into this Chapter by reference and
made a part hereof as if fully set forth herein. The provisions of this Chapter shall constitute local
amendments to the referenced provisions of the International Swimming Pool and Spa Code,
2024 Edition.
One copy of the International Swimming Pool and Spa Code, 2024 Edition, has been filed for
use and examination by the public in the Office of the Chief Building Official of the City of Palo
Alto.
16.18.020 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.
16.18.030 Enforcement -- Criminal Enforcement Authority.
The employee positions designated in this section are authorized to exercise the authority
provided in California Penal Code section 836.5 for violations of this Chapter. The designated
employee positions are: (1) chief building official, (2) assistant chief building official, (3) building
inspection manager, and (4) code enforcement officer.
16.18.040 References to California Building Codes.
The International Swimming Pool and Spa Code, 2024 Edition, is hereby amended to refer to
those building regulations adopted by the California Building Standards Commission in Title 24
of the California Code of Regulations, as follows:
1. Where the term “International Building Code” is used it shall be replaced with
the term “California Building Code (CBC).”
2. Where the term “International Residential Code” is used it shall be replaced with
the term “California Residential Code.”
3. Where the term “International Plumbing Code” is used it shall be replaced with
the term “California Plumbing Code.”
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4. Where the term “International Energy Conservation Code” is used it shall
be replaced with the term “California Energy Code.”
5. Where the term “International Fire Code” is used it shall be replaced with the
term “California Fire Code.”
6. Where the term “International Fuel Gas Code” is used it shall be replaced with
the term “California Plumbing Code.”
7. Where the term “International Mechanical Code” is used it shall be replaced
with the term “California Mechanical Code.”
8. Where the term “NFPA 70” is used it shall be replaced with the term
“California Electrical Code.”
16.18.050 Precedence of California Building Codes.
In the event of any conflict between this Chapter and provisions of the California Health and
Safety Code or the building regulations adopted by the California Building Standards
Commission in Title 24 of the California Code of Regulations, the provisions of the Health and
Safety Code and Title 24 shall prevail.
16.18.060 Administration & Enforcement of 2024 International Swimming Pool and Spa
Code (ISPSC)
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, and any
sections of the 2024 International Swimming Pool and Spa Code that are adopted by the City of
Palo Alto in this Chapter 16.18.
16.18.070 Section 101.1 Title.
Section 101.1 of the International Swimming Pool and Spa Code is hereby amended to read:
101.1 Title. These regulations shall be known as the International Swimming Pool and
Spa Code of the City of Palo Alto, hereinafter referred to as “this code.”
16.08.080 Section 105.1.1 Agreements to build; notice of provisions.
Section 105.1.1 of the International Swimming Pool and Spa Code is hereby added to read:
105.1.1 Agreements to build; notice of provisions. Any person entering into an
agreement to build a swimming pool or spa, or to engage in permitted work on a pool
or spa covered by this article, shall give the consumer notice of the requirements of
this code.
Pursuant to existing law, the California Department of Health Services shall have
available on the department's web site, commencing January 1, 2007, approved pool
safety information available for consumers to download. Pool contractors are
encouraged to share this information with consumers regarding the potential dangers a
pool or spa poses toddlers. Additionally, pool contractors may provide the consumer
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with swimming pool safety materials produced from organizations such as the United
States Consumer Product Safety Commission, Drowning Prevention Foundation,
California Coalition for Children's Safety & Health, Safe Kids Worldwide, Association of
Pool and Spa Professionals, or the American Academy of Pediatrics. [CBC 3109.1,
115924]
16.18.090 Section 111.17 Final approval.
Section 110.17 of the International Swimming Pool and Spa Code is hereby added to read:
111.17 Final Approval. Prior to the issuance of any final approval for the completion
of permitted construction or remodeling work, the code official shall inspect the
drowning safety prevention devices required and if no violations are found, shall give
final approval. [CBC 3109.1, 15922(b)]
16.18.100 Section 301.1.2 Conflicts.
Section 301.1.2 of the International Swimming Pool and Spa Code is hereby added to read:
301.1.2 Conflicts. In the event of a conflict between the provisions of the Swimming
Pool Safety Act, the International Swimming Pool and Spa Code, 2024 Edition, the 2025
California Building Code, or the 2025 California Residential Code, the Building Official
shall implement the most restrictive measures cited.
16.18.110 Section 303.3.1 Operating time.
Section 303.3.1 of the International Swimming Pool and Spa Code is hereby added to read:
303.3.1 Operating time. The time switch or other control mechanism shall be installed
as part of a pool water circulation control system that will allow all pumps to be set or
programmed to run only during off-peak electric demand period, and for the minimum
time necessary to maintain the water in the condition required by applicable public
health standards. [California Energy Code (CEnC) 110.4(b)4ii]
16.18.120 Section 303.1.3 Covers.
Section 303.1.3 of the International Swimming Pool and Spa Code is hereby amended to read:
303.1.3 Covers. Outdoor pools and outdoor spas shall be provided with a vapor
retardant cover.
16.18.130 Section 305.2 Outdoor swimming pools and spas.
Section 305.2 of the International Swimming Pool and Spa Code is hereby amended to read:
305.2 Outdoor swimming pools and spas. All outdoor pools and spas and indoor
swimming pools shall be surrounded by a barrier that complies with Sections 305.2.1
through 305.7. [CBC 3109.1, 115922]. Refer to 305.9 for additional drowning
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prevention safety features.
16.18.140 Section 305.9 Private swimming pools.
Section 305.9 of the International Swimming Pool and Spa Code is hereby added to read:
305.9 Private swimming pools. Whenever a building permit is issued for construction
of a new swimming pool or spa, or any building permit is issued for remodeling of an
existing pool or spa, at a private, single-family home, it shall be equipped with at least
two of the following seven drowning prevention safety features:
1. The pool/spa shall be isolated from access to a home by an enclosure that
meets the requirements of Section 305.10.
2. The pool shall incorporate removable mesh pool fencing that meets ASTM
F2286 in conjunction with a gate that is self-closing and self-latching and can
accommodate a key lockable device.
3. The pool shall be equipped with an approved safety pool cover that meets
all requirements of the ASTM F 1346-23 standards.
4. The residence shall be equipped with exit alarms on those doors and windows
providing direct access to the pool and spa without any intervening enclosure.
Whenever any door or window is opened or left ajar, exit alarms shall make
either an audible, continuous alarm sound or a repeating verbal warning, such
as a repeating notification that “the door to the pool is open.”
5. All doors providing direct access from the home to the swimming pool or
spa shall be equipped with a self-closing, self-latching device with a release
mechanism placed no lower than 54 inches (1372 mm) above the floor.
6. An alarm that, when placed in a swimming pool or spa, will sound upon
detection of accidental or unauthorized entrance into the water. The alarm shall
meet and be independently certified to the ASTM Standard F2208 “Standard
Safety Specification for Residential Pool Alarms,” which includes surface motion,
pressure, sonar, laser, and infrared type alarms. A swimming protection alarm
feature designed for individual use, including an alarm attached to a child that
sounds when the child exceeds a certain distance or becomes submerged in
water, is not a qualifying drowning prevention safety feature.
7. Other means of protection, if the degree of protection afforded is equal to or
greater than that afforded by any of the devices set forth in items 1 - 4 and have
been independently verified by an approved testing laboratory as meeting
standards for those devices established by the ASTM or ASME.
Exceptions:
1. Public swimming pools.
2. Hot tubs or spas with locking safety covers that comply with the ASTM ES
13-89. b)]
3. An apartment complex, or any residential setting other than a single-
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family home.
16.18.150 Section 305.10 Enclosure.
Section 305.10 of the International Swimming Pool and Spa Code is hereby added to read:
305.10 Enclosure. The enclosure for private swimming pools shall have all of the
following characteristics:
1. Any access gates through the enclosure open away from the swimming pool
and are self-closing with a self-latching device placed no lower than 60 inches
(1524 mm) above the ground.
2. A minimum height of 60 inches (1524 mm).
3. A maximum vertical clearance from the ground to the bottom of the enclosure
of 2 inches (51 mm).
4. Gaps or voids, if any, do not allow passage of a sphere equal to or greater than
4 inches (102 mm) in diameter.
5. An outside surface free of protrusions, cavities or other physical characteristics
that would serve as handholds or footholds that could enable a child below the
age of five years to climb over.
16.18.160 Section 311.2 Construction requirements for building a pool or spa.
Section 311.2 of the International Swimming Pool and Spa Code is hereby added to read:
311.2 Construction requirements for building a pool or spa. Whenever a building
permit is issued for the construction of a new private swimming pool or spa, the pool
or spa shall meet all of the following requirements:
(a) (1) The suction outlets of the pool or spa for which the permit is issued shall be
equipped to provide circulation throughout the pool or spa as prescribed in
paragraphs (2) and (3).
(2) The swimming pool or spa shall either have at least two circulation suction
outlets per pump that shall be hydraulically balanced and symmetrically
plumbed through one or more “T” fittings, and that are separated by a distance
of at least three feet in any dimension between the suction outlets, or be
designed to use alternatives to suction outlets, including, but not limited to,
skimmers or perimeter overflow systems to conduct water to the recirculation
pump.
(3)The circulation system shall have the capacity to provide a complete turnover
of pool water, as specified in Section 3124B of Chapter 31B of the California
Building Code (Title 24 of the California Code of Regulations).
Suction outlets shall be covered with anti-entrapment grates, as specified in the
ANSI/APSP-16 performance standard or successor standard designated by the
federal Consumer Product Safety Commission, that cannot be removed except
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with the use of tools. Slots or openings in the grates or similar protective devices
shall be of a shape, area, and arrangement that would prevent physical
entrapment and would not pose any suction hazard to bathers.
(b) Any backup safety system that an owner of a new swimming pool or spa may
choose to install in addition to the requirements set forth in subdivisions (a) and
(b) shall meet the standards as published in the document, “Guidelines for
Entrapment Hazards: Making Pools and Spas Safer,” Publication Number 363,
March 2005, United States Consumer Product Safety Commission.
16.18.170 Section 317.2.1 Certification and installation.
Section 317.2.1 of the International Swimming Pool and Spa Code is hereby added to read:
317.2.1 Certification and installation.
(a) Certification by manufacturers. Heating systems and equipment shall be
certified by the manufacturer that the heating system and equipment complies
with the following:
1. Efficiency. A thermal efficiency that complies with the Appliance Efficiency
Regulations in Title 20, Division 2, Chapter 4, Article 4 of the California Code
of Regulations; and [CEnC 110.4(a)1]
2. On-off switch. A readily accessible on-off switch, mounted on the outside of
the heater that allows shutting off the heater without adjusting the
thermostat setting; and [CEnC 110.4(a) 2]
3. Instructions. A permanent, easily readable and weatherproof plate or card
that gives instruction for the energy efficient operation of the pool or spa
heater and for the proper care of pool or spa water when a cover is used;
and [CEnC 110.4(a)3]
(b) Installation. Any pool or spa system or equipment shall be installed with all
of the following:
1. Heating equipment: Equipment installed to heat water for pools and/or spas
shall be selected from equipment meeting the standards shown in Table
110.4-A. [CEnC 110.4(b)1]
Table 110.4-A Heating Equipment Standards
Heating Energy Source Standard
Electric Resistance UL 1261
Gas-fired ANSI Z21.56/CSA 4.7a
Heat Pump AHRI 1161 and one of the
following: CSA C22.2 No. 236,
UL1995, or UL/CSA 60335-2-40
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Solar ICC/APSP902/SRCC400 for solar
pool heaters, ICC 901/SRCC100 for
solar collectors
2. Piping. At least 18 inches of horizontal or vertical pipe shall be installed
between the filter and the heater or dedicated suction and return lines, or
built-in or built-up connections shall be installed to allow for the future
addition of solar heating equipment. [CEnC 110.4(b)2]
3. Covers. A cover for outdoors pools or outdoor spas.
4. Directional inlets. The swimming pool shall have directional inlets
that adequately mix the pool water. [CEnC 110.4(b)4i]
16.18.180 Section 504.1 Emergency shutoff switch.
Section 504.1 of the International Swimming Pool and Spa Code is hereby amended to read:
504.1 Emergency shutoff switch. One emergency shutoff switch shall be provided to
disconnect power to circulation and jet system pumps and air blowers. Emergency shutoff
switches shall be clearly labeled, accessible, located within sight of the spa and shall be
located not less than 5 feet (1524 mm) but not greater than 10 feet (3048 mm) horizontally
from the inside walls of the spa. [California Electrical Code (CEC), 680.41]
16.18.190 Section 903 to 908.
Sections 903 to 908 of the International Swimming Pool and Spa Code are added as follows:
SECTION 903
MATERIALS
903.1 Pumps and motors. Pumps and motors shall be listed and labeled for use in spas.
SECTION 904
STRUCTURE AND
DESIGN
904.1 Water depth. The maximum water depth for spas shall be 4 feet (1219 mm) measured
from the design waterline except for spas that are designed for special purposes
and approved by the authority having jurisdiction. The water depth for exercise spas shall
not exceed 6 feet 6 inches (1981 mm) measured from the design waterline.
904.2 Multilevel seating. Where multilevel seating is provided, the maximum water depth
of any seat or sitting bench shall be 28 inches (711 mm) measured from the design waterline
to the lowest measurable point.
904.3 Floor slope. The slope of the floor shall not exceed 1 unit vertical in 12 units
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horizontal (8.3-percent slope). Where multilevel floors are provided, the change in depth
shall be indicated.
SECTION 905
PUMPS AND MOTORS
905.1 Emergency shutoff switch. One emergency shutoff switch shall be provided to
disconnect power to circulation and jet system pumps and air blowers. Emergency shutoff
switches shall be accessible, located within sight of the spa and shall be located not less than
5 feet (1524 mm) but not greater than 10 feet (3048 mm) horizontally from the inside walls
of the spa.
Timer. The operation of the hydrotherapy jets shall be limited by a cycle timer having a
maximum setting of 10 minutes. The cycle timer shall be located not less than 5 feet (1524
mm) away, adjacent to, and within sight of the spa.
SECTION 906
RETURN AND SUCTION FITTINGS
906.1 Return fittings. Return fittings shall be provided and arranged to facilitate a
uniform circulation of water and maintain a uniform sanitizer residual throughout the
entire spa or exercise spa.
906.2 Suction fittings. Suction fittings shall be in accordance with Sections 505.2.1
through 505.2.4.
906.2.1 Testing and certification. Suction fittings shall be listed and labeled
in accordance with APSP 16.
906.2.2 Installation. Suction fittings shall be sized and installed in accordance with
the manufacturer’s specifications. Spas and exercise spas shall not be used or
operated if the suction outlet cover is missing, damaged, broken or loose.
906.2.3 Outlets per pump. Suction fittings shall be provided in accordance with
Section 311.
906.2.4 Submerged vacuum fittings. Submerged vacuum fittings shall be in
accordance with Section 311.
SECTION 907
HEATER AND TEMPERATURE REQUIREMENTS
907.1 General. This section pertains to fuel-fired and electric appliances used for heating spa
or exercise spa water.
907.2 Water temperature controls. Components provided for water temperature controls
shall be suitable for the intended application.
907.2.1 Water temperature regulating controls.
Water temperature regulating controls shall comply with UL 873 or UL 372. A means
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shall be provided to indicate the water temperature in the spa.
Exception: Water temperature regulating controls that are integral to the heating
appliance and listed in accordance with the applicable end use appliance standard.
907.2.2 Water temperature limiting controls. Water temperature limiting controls
shall comply with UL 873 or UL 372. Water temperature at the heater return outlet
shall not exceed 140°F (60°C).
SECTION 908
WATER SUPPLY
908.1Water temperature.
The temperature of the incoming makeup water shall not exceed 104°F (40°C).
SECTION 2. The Council finds that adoption of this code and its local amendments is
not a change or modification to the California Building Standards Code pursuant to Health and
Safety Code Section 17958.5. The California Building Standards Commission does not require
that an ordinance adopting and amending the International Swimming Pool and Spa Code be
filed with the Commission or supported by local conditions
SECTION 3. 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 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 4. The Council finds that this project is exempt from the provisions of the
California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA
Guidelines, because it can be seen with certainty that there is no possibility that the
amendments herein adopted will have a significant effect on the environment.
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SECTION 5. This Ordinance shall be effective on the thirty-first day after the date of
its adoption.
INTRODUCED:
PASSED:
AYES:
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
*NOT YET APPROVED*
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Ordinance No. ____
Ordinance of the Council of the City of Palo Alto Amending
Chapter 16.14 (California Green Building Standards, California
Code of Regulations, Title 24, Part 11) of the Palo Alto Municipal
Code to Adopt the 2025 Green Building Standards Code, Along
With Local Amendments
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 11, 2025 California Green Building Standards 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 11.
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 finds that, with the exception of the changes codified at PAMC
Sections 16.14.070, 16.14.080, 16.14.285, 16.14.355, and 16.14.400, the changes or
modifications to the California Green Building Standards Code adopted by this
ordinance are substantially equivalent to changes or modifications that were previously
filed by the governing body of the City and were in effect as of September 30, 2025, and
are therefore exempt from the moratorium on new residential building standards
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imposed by Assembly Bill (AB) 130 (2025). The changes codified at the PAMC Sections
listed above, to the extent that they are not substantially equivalent to changes in effect
as of September 30, 2025, do not affect residential units and are therefore not subject
to the AB 130 moratorium.
F. California Health and Safety Code sections 17958.5 and 17958.7 requires that the City,
in order to make changes or modifications in the requirements contained in the
California Green Building Standards 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.
G. The required findings are attached to this ordinance as Exhibit A.
SECTION 2. Chapter 16.14 (California Green Building Standards, California Code of
Regulations, Title 24, Part 11) of the Palo Alto Municipal Code is hereby amended by repealing in
its entirety existing 16.14 and adopting a new Chapter 16.14 to read as follows:
CHAPTER 16.14
CALIFORNIA GREEN BUILDING STANDARDS CODE,
CALIFORNIA CODE OF REGULATIONS, TITLE 24, PART 11
Sections
Part 1 – General
16.14.010 2025 California Green Building Standards Code, Title 24, Part
11 adopted and amended.
16.14.020 Cross ‐ References to California Green Building Standards Code.
16.14.030 Local Amendments.
Part 2 – Local Modifications to CHAPTER 1 – ADMINISTRATION
16.14.040 Administration & Enforcement of 2025 California Green Building
Standards Code.
16.14.050 Adoption of Chapter 1 Administration.
16.14.060 Section 101.4 Appendices.
Part 3 – Local Modifications to CHAPTER 2 – DEFINITIONS
16.14.070 Section 202 Definitions.
Part 4 – Local Modifications to CHAPTER 3 – GREEN BUILDING
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16.14.080 Section 301 – Voluntary Tiers Added.
Part 5 – Local Modifications to CHAPTER 4 – RESIDENTIAL
MANDATORY MEASURES
16.14.090 Section 4.106.5 Full Electrification
16.14.100 Section 4.306 Swimming Pool and Spa Covers.
16.14.110 Reserved
Part 6 – Local Modifications to CHAPTER 7 – INSTALLER AND
SPECIAL INSPECTOR QUALIFICATIONS
16.14.120 Section 702.2 Special Inspection.
Part 7– Local Modifications to APPENDIX A4 – RESIDENTIAL
VOLUNTARY MEASURES
16.14.130 Residential Projects. Appendix A4 Preface: Green Building
Measures for Project Type and Scope.
16.14.140 Section A4.104 Site Preservation.
16.14.150 Section A4.105 Deconstruction and Reuse of Existing Materials.
16.14.160 Section A4.106.8 Electric Vehicle (EV) Charging for New Construction.
16.14.170 Section A4.106.9 Bicycle Parking.
16.14.180 Section A4.106.10 Light Pollution Reduction.
16.14.190 Section A4.203.1 Performance Approach for Newly Constructed Buildings.
16.14.200 Section A4.304.3 Irrigation Metering Device.
16.14.210 Section A4.305 Water Reuse Systems.
16.14.220 A4.305.4 Additions and Alterations.
16.14.230 Section A4.403.1 Frost Protection Foundation Systems.
16.14.240 Section A4.403.2 Reduction in Cement Use.
16.14.250 Section A4.408.1 Enhanced Construction Waste Reduction.
16.14.260 Section A4.504.1 Compliance with formaldehyde limits.
16.14.270 Section A4.504.3 Thermal Insulation.
Part 8 – Local Modifications to CHAPTER 5 – NONRESIDENTIAL
MANDATORY MEASURES
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16.14.280 Nonresidential Projects: Chapter 5 Preface Green
Building Project Type and Scope.
Requirements
for
16.14.285 Section 5.105.1 Scoping
16.14.290 Section 5.106.1.1 Local Storm Water Pollution
Prevention.
16.14.295 Section 5.106.8 Light Pollution Reduction.
16.14.300 Section 5.106 Full Electrification.
16.14.310 Reserved
16.14.320 Reserved
16.14.330 Section 5.304.2 Invasive Species Prohibited.
16.14.340 Section 5.306 Nonresidential Enhanced Water Budget.
16.14.350 Section 5.307 Cooling Tower Water Use.
16.14.355 Section 5.409 Life Cycle Assessment
16.14.360 Section 5.410.4.6 Energy STAR Portfolio Manager.
16.14.370 Section 5.410.4.7 Performance Reviews – Energy.
16.14.380 Section 5.410.4.8 Performance Reviews – Water.
16.14.390 Section 5.506 Indoor Air Quality.
Part 9 – Local Modifications to APPENDIX A5 – NONRESIDENTIAL
VOLUNTARY
MEASURES
16.14.400 Section A5.106.5.3 Electric Vehicle (EV) Charging for New Construction.
16.14.410 Section A5.203.1 Performance Approach for Newly Constructed Buildings.
16.14.420 Section A5.405.5 Cement and Concrete.
16.14.430 Section A5.408 Construction Waste Reduction, Disposal and Recycling.
Part 1 – General
16.14.010 2025 California Green Building Standards Code, Title 24, Part 11
adopted and amended.
The California Green Building Standards Code, 2025 Edition, Title 24, Part 11 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.
*NOT YET APPROVED*
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Unless superseded and expressly repealed, references in City of Palo Alto forms,
documents and regulations to the chapters and sections of the former 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. 5626 of the City of Palo Alto and all other ordinances or parts of
ordinances in conflict herewith are hereby suspended and expressly repealed.
Wherever the phrases “California Green Building Standards Code” or “CALGreen”
are used in this code or any ordinance of the City, such phrases shall be deemed
and construed to refer and apply to the California Green Building Standards Code,
2025 Edition, as adopted and amended by this chapter.
One copy of the California Green Building Standards 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.
16.14.020 Cross ‐ References to California Green Building Standards Code.
The provisions of this Chapter contain cross‐references to the provisions of the
California Green Building Code, 2025 Edition, in order to facilitate reference and
comparison to those provisions.
16.14.030 Local Amendments.
The provisions of this Chapter shall constitute local amendments to the cross‐
referenced provisions of the California Green Building Standards 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.
Part 2 – Local Modifications to CHAPTER 1 – ADMINISTRATION
16.14.040 Administration & Enforcement of 2025 California Green Building
Standards 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.
16.14.050 Adoption of Chapter 1 Administration.
Chapter 1 Administration of the 2025 California Green Building Code is adopted
by the City of Palo Alto to supplement, to the extent it does not conflict with,
Chapter 1, Division II of the 2025 California Building Code, as amended.
16.14.060 Section 101.4 Appendices.
The following Appendix Chapters of the California Green Building Standards Code,
2025 Edition, are adopted and hereby incorporated in this Chapter by reference and
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made a part hereof the same as if fully set forth herein:
A. Appendix A4 ‐ Residential Voluntary Measures (Tier 1 and Tier2)
B. Appendix A5 ‐ Nonresidential Voluntary Measures (Tier 1 and Tier 2)
Part 3 – Local Modifications to CHAPTER 2 – DEFINITIONS
16.14.070 Section 202 Definitions.
Section 202 of Chapter 2 of the California Green Building Standards Code is amended
to include the following definitions:
ALL‐ELECTRIC BUILDING / SITE. A building or parcel of land whose sole
source of energy is electricity and contains no combustion equipment or
plumbing for combustion equipment.
CPAU. City of Palo Alto Utilities Department.
CALGREEN INSPECTOR is a person certified as a CALGreen Inspector/Plans
Examiner through the International Code Council (ICC), demonstrating
knowledge and application of Green Building concepts during plan review
and inspection. For projects that require a CALGreen Inspector/Plans
Examiner verification, the Inspector must be contracted directly with the
owner and may not be a contractor or employee of the design or
construction firm.
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.
GREEN BUSINESS CERTIFICATION INC. (GBCI™). Green Business Certification
Inc. (GBCI™) is an independent third‐party organization that provides
certification, credentialing, and verification services for green building and
sustainability programs, including serving as the official certification body for
LEED projects and professional credentials.
LEADERSHIP IN ENERGY AND ENVIRONMENTAL DESIGN (LEED®). The
Leadership in Energy and Environmental Design (LEED®) is a green building
certification program developed by the U.S. Green Building Council that
provides a framework for green buildings through a point‐based rating
system that evaluates building performance across multiple sustainability
categories. Projects shall follow the U.S. Green Building Council’s
standards for selecting the appropriate LEED® rating system.
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LEED AP WITH SPECIALTY. An advanced professional credential signifying
expertise in green building and a LEED rating system. To earn a LEED AP
with specialty, candidates must first pass the LEED Green Associate exam.
The exams measure knowledge about green building, a specific LEED
rating system and the certification process and are ideal for individuals
who are actively working on green building and LEED projects.
MODEL WATER EFFICIENT LANDSCAPE ORDINANCE. The California
Department of Water Resources Model Water Efficient Landscape
Ordinance.
SALVAGE. Salvage means the controlled removal of items and material
from a building, construction, or demolition site for the purpose of on‐ or
off‐site reuse, or storage for later reuse. Examples include air conditioning
and heating systems, columns, balustrades, fountains, gazebos, molding,
mantels, pavers, planters, quoins, stair treads, trim, wall caps, bath tubs,
bricks, cabinetry, carpet, doors, ceiling fans, lighting fixtures, electrical
panel boxes, fencing, fireplaces, flooring materials of wood, marble, stone
or tile, furnaces, plate glass, wall mirrors, door knobs, door brackets, door
hinges, marble, iron work, metal balconies, structural steel, plumbing
fixtures, refrigerators, rock, roofing materials, siding materials, sinks,
stairs, stone, stoves, toilets, windows, wood fencing, lumber and plywood.
SUBSTANTIAL REMODEL (or “50‐50‐50” RULE). Any project that affects
the removal or replacement of 50% or more of the linear length of the
existing exterior walls of the building, 50% or more of the 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 301.1.2).
SQUARE FOOTAGE. For application of green building requirements,
“square footage” refers to all new or altered square footage, including
basement areas (7 feet or greater in height), as calculated based on outer
boundary of proposed construction area, including exterior walls.
U.S. Green Building Council (USGBC). The U.S. Green Building Council
(USGBC) is a nonprofit organization that promotes sustainability in
building design, construction, and operation through market
transformation initiatives and the development of green building
standards, most notably the Leadership in Energy and Environmental
Design (LEED®) certification program.
Part 4 – Local Modifications to CHAPTER 3 – GREEN BUILDING
16.14.080 SECTION 301 ‐ Voluntary Tiers Added.
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SECTION 301 of Chapter 3 of the California Green Building Standards Code is amended
to read:
SECTION 301 GENERAL
301.1 Scope. Buildings shall be designed to include the green building
measures specified as mandatory in the application checklists contained
in this code and any applicable local amendments. In addition, the City
requires the use of Voluntary Tiers, as provided in Appendices A4 and
A5, for certain residential and nonresidential new construction,
additions, and alterations.
Projects that only trigger Mandatory measures are not required to fulfill
Tier 1 or Tier 2 measures in Appendix A4 and A5.
To achieve Tier 1 status, a project must comply with measures identified
in Appendix A4, Division A4.6, Section A4.601.4 for residential projects
and Appendix A5, Division A5.6, Section A5.601.2 for nonresidential
projects. Projects subject to Tier 1 must fulfill all mandatory measures,
all Tier 1 prerequisite measures and a defined number of Tier 1 elective
measures.
To achieve Tier 2 status, a project must comply with requirements
identified in
Appendix A4, Division A4.6, Section A4.601.5 for residential projects and
Appendix
A5, Division A5.6, Section A5.601.3 for nonresidential projects. Projects
subject to
Tier 2 must fulfill all mandatory measures, all Tier 2 prerequisite
measures and a
defined number of Tier 2 elective measures.
301.1.1 Residential additions and alterations. [HCD] The Mandatory
provisions of Chapter 4 shall be applied to additions and/or alterations of
existing residential buildings where the addition and/or alteration
increases the building's conditioned area, volume, or size. The
requirements shall apply only to and/or within the specific area of the
addition or alteration. Tier 1 adopted (Residential). All residential
building additions and/or alterations exceeding 1000 square feet must
meet CALGreen Mandatory plus the Tier 1 measures, as amended by this
Chapter and as applicable to the scope of work.
For Tier 1 projects, the area of alterations will include any
construction or renovation to an existing structure other than repair or
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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 Tier 1 projects.
The area of alteration should be limited to the footprint of element(s) being
altered.
This does not exclude mandatory CALGreen measures. The sum of the
footprint of the elements being altered with respect to Tier 1, 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
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 Green Building Standards Code Mandatory measures
only.
301.1.2 Substantial Remodel (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.
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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.
The Chief Building Official or designee shall make the final determination
regarding the application if a conflict occurs.
[…]
301.2 Low‐rise and high‐rise residential buildings. [HCD] The provisions
of individual sections of CALGreen may apply to either low‐rise residential
buildings, high‐rise residential buildings, or both. Individual sections will be
designated by banners to indicate where the section applies specifically to
low‐rise only (LR) or high‐rise only (HR). When the section applies to both
low‐rise and high‐rise buildings, no banner will be used.
301.2.1 Low‐Rise residential new construction – Tier 2 adopted. All new
constructed or substantial remodel projects must meet CALGreen
Mandatory plus Tier 2 measures, as amended by this ordinance and as
applicable to the scope of work.
301.3 Nonresidential additions and alterations. [BSC‐CG] The provisions
of individual sections of Chapter 5 apply to building nonresidential
additions of 1,000 square feet or greater, and/or building alterations with
a permit valuation of $200,000 or above (for occupancies within the
authority of California Building Standards Commission). Code sections
relevant to additions and alterations shall only apply to the portions of the
building being added or altered within the scope of the permitted work.
A code section will be designated by a banner to indicate where the
code section only applies to newly constructed buildings [N] or to
additions and alterations [A]. When the code section applies to both, no
banner will be used.
Tier 1 adopted. Nonresidential alterations (including tenant
improvements or renovations) of 5,000 square feet that include
replacement of at least two of the following: HVAC system, building
envelope, hot water system, or lighting system, must comply with
CALGreen Mandatory plus Tier 1 measures, as amended by this Chapter
and as applicable to the scope of work.
Tier 1 alternative compliance path. Nonresidential alterations
projects that would otherwise be subject to CALGreen Mandatory plus
Tier 1 measures may elect an alternative compliance pathway by
achieving LEED® Silver certification or higher from the U.S. Green
Building Council. The Green Business Certification Inc. (GBCI™) shall
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serve as the independent third‐party certification body responsible for
reviewing project documentation, conducting compliance verification,
and issuing official LEED® certification. Projects electing this pathway
are exempt from all individual Tier 1 CALGreen prerequisite and
elective requirements with exception of the following:
PAMC 16.14.430 Section A5.408 Construction Waste
Reduction, Disposal and Recycling.
Projects must maintain compliance with all applicable base CALGreen
mandatory measures and building code requirements.
Tier 2 adopted. Nonresidential additions of 1000 square feet or greater must
comply
with CALGreen Mandatory plus Tier 2 measures, as amended by this
Chapter and as applicable to the scope of work.
Tier 2 alternative compliance path. Nonresidential additions of
1000 square feet or greater that would otherwise be subject to
CALGreen Mandatory plus Tier 2 measures may elect an alternative
compliance pathway by achieving LEED® Gold certification or higher
from the U.S. Green Building Council. The Green Business Certification
Inc. (GBCI™) shall serve as the independent third‐party certification
body responsible for reviewing project documentation, conducting
compliance verification, and issuing official LEED® certification.
Projects electing this pathway are exempt from all individual Tier 2
CALGreen prerequisite and elective requirements with exception of
the following:
PAMC 16.14.430 Section A5.408 Construction Waste
Reduction, Disposal and Recycling.
Projects must maintain compliance with all applicable base
CALGreen mandatory measures and building code
requirements.
301.3.1 ‐ 301.3.2 Unmodified
301.3.3 Nonresidential new construction – Tier 2 adopted. All new
nonresidential construction must meet CALGreen Mandatory plus Tier 2
measures (including initial occupancy tenant improvements), as amended
by this ordinance and as applicable to the scope of work.
Tier 2 alternative compliance path. All new nonresidential
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construction that would otherwise be subject to CALGreen Mandatory
plus Tier 2 measures may elect an alternative compliance pathway by
achieving LEED® Gold certification or higher from the U.S. Green
Building Council. The Green Business Certification Inc. (GBCI™) shall
serve as the independent third‐party certification body responsible for
reviewing project documentation, conducting compliance verification,
and issuing official LEED® certification. Projects electing this pathway
are exempt from all individual Tier 2 CALGreen prerequisite and
elective requirements with exception of the following:
PAMC 16.14.430 Section A5.408 Construction Waste
Reduction, Disposal and Recycling.
PAMC 16.14.400 Section A5.106.5.3 Electric Vehicle (EV)
Charging for New Construction.
Projects must maintain compliance with all applicable base CALGreen
mandatory
measures and building code requirements.
301.6 Special inspector requirements. Residential and nonresidential
project owners subject to CALGreen Mandatory, CALGreen Mandatory
plus Tier 1, or CALGreen Mandatory plus Tier 2 measures shall contract a
City‐approved Green Special Inspector (GBSI) in accordance with section
702.2 of CALGreen, as amended.
A City‐approved GBSI is required to verify compliance with CALGreen
mandatory measures when the project elects to use the alternative LEED
compliance pathway per section 301.3 and 301.3.3 of this Chapter. A LEED
Accredited Professional with applicable specialty (LEED AP) shall certify
that the project has been designed to meet the requirements for LEED
Silver or LEED Gold certification, as applicable. The LEED AP shall provide
two letters to certify the alternative compliance pathway:
1. At Building Permit Application – A letter confirming that said project
has been registered with the U.S. Green Building Council (USGBC) and
is anticipated to achieve the required number of points for the
specified certification level.
2. Prior to any Approved Occupancy ‐ A letter based on the actual
construction confirming that the project has been built in accordance
with the approved plans and is expected to be eligible for certification
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at the approved LEED level. This letter must also state whether, and
when, the final submittal certification documents will be submitted to
the USGBC.
Provide proof of LEED Silver/Gold Certification to the Building Department
within two years of initial occupancy as part of the project record.
301.7 Low‐carbon concrete requirements for Tier 1 and Tier 2 projects.
Plain and reinforced concrete installed as part of any project subject to the
application of this code shall demonstrate compliance with the
requirements of PAMC 16.14.240.
Part 5 – Local Modifications to CHAPTER 4 – RESIDENTIAL MANDATORY
MEASURES
Division 4.1 – PLANNING AND DESIGN
16.14.090 Section 4.106.5 Full Electrification
Section 4.106 of Chapter 4 of the California Green Building Standards Code is
amended to add new subsection, 4.106.5 as follows:
4.106.5 Full electrification. Full electrification is recommended for new buildings,
substantial remodels, and new outdoor appliances/equipment such as fireplaces,
firepits, heaters for swimming pool/spa, and similar equipment. Full
electrification is required for outdoor grills, stoves, and barbecues. This
subsection does not prohibit freestanding and/or portable grills, stoves, or
barbecues whose sole source of energy is self‐contained fuel canisters.
Division 4.3 – WATER EFFICIENCY AND CONSERVATION
16.14.100 Section 4.306 Swimming Pool and Spa Covers
Section 4.306 of Chapter 4 of the California Green Building Standards Code is added to
read:
4.306 Swimming pool and spa covers. Swimming pools and spas shall be provided
with a vapor retardant cover.
Part 6 – Local Modifications to CHAPTER 7 – INSTALLER AND SPECIAL INSPECTOR
QUALIFICATIONS
16.14.120 Section 702.2 Special Inspection.
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Section 702.2 of Chapter 7 of the California Green Building Standards Code is amended
to read:
702.2 Green building special inspection. When required by the enforcing
agency, the owner or responsible entity acting as the owner’s agent shall
employ one or more Green Building Special Inspectors to provide
inspection or other duties necessary to substantiate compliance with this
code. Green Building Special Inspectors shall demonstrate competence to
the satisfaction of the enforcing agency for the particular type of
inspection or task to be performed. In addition to other certifications or
qualifications acceptable to the enforcing agency, the following
certifications or education may be considered by the enforcing agency
when evaluating the qualifications of a Special Inspector. The City shall
maintain a list of pre‐approved Special Inspectors in accordance with this
section. The owner shall contract a Special Inspector from the pre‐
approved list meeting one of the following:
1. Certification by a national or regional green building program:
ICC Certified CALGreen Inspector/Plans Examiner
2. Other programs acceptable to the enforcing agency.
Note: Special Inspectors shall be independent entities with no financial
interest in the materials or the project they are inspecting for compliance
with this code.
Part 7– Local Modifications to APPENDIX A4 – RESIDENTIAL VOLUNTARY
MEASURES
Division A4.1 – PLANNING AND DESIGN
16.14.130 Residential Projects. Appendix A4 Preface: Green Building
Measures for Project Type and Scope.
A preface is added to Chapter A4 of the California Green Building Standards Code to
read:
Preface ‐ Green Building Requirements for Project Type and Scope. For
design and construction of residential projects, the City of Palo Alto
requires compliance with the mandatory measures of Chapter 4, in
addition to use of Tier 1 and Tier 2 as specified in Palo Alto Municipal Code
Chapter 16.14. See Section 202 for definitions on CALGreen Mandatory,
Tier 1 Prerequisites and Electives, and Tier 2 Prerequisites and Electives.
All elective measures are adopted as written under Appendix A4 unless
otherwise indicated in this Section.
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16.14.140 Section A4.104 SITE PRESERVATION.
Section A4.104.1 of Appendix A4 of the California Green Building Standards Code
is adopted as a Tier 1 and Tier 2 elective measure and is amended to read:
A4.104.1 Supervision and education by a special inspector. Individuals
with oversight authority on the project, as defined in section 16.14.120
of this code, who have been trained in areas related to environmentally
friendly development, shall teach green concepts to other members of the
builder’s staff and ensure training and written instruction has been
provided to all parties associated with the development of the project.
Prior to the beginning of the construction activities, the builder shall
receive a written guideline and instruction specifying the green goals of
the project.
Note: Lack of adequate supervision and dissemination of the project goals
can result in negative effects on green building projects. If the
theme of green building is not carried through the project, the
overall benefit can be substantially reduced by the lack of
knowledge and information provided to the various entities
involved with the construction of the project.
16.14.150 Section A4.105 Deconstruction and Reuse of Existing Materials.
Section A4.105 of Appendix A4 of the California Green Building Standards Code is
not adopted as an elective measure and is amended to read:
Section A4.105.1 Chapter 5.24 of Title 5 of the Municipal Code. See
Chapter 5.24 of the Municipal Code for the local deconstruction
requirements.
Section A4.105.2 is adopted as a Tier 1 and Tier 2 elective measure.
A4.105.2 Reuse of materials. Nonhazardous materials which can
be easily reused include but are not limited to the following:
1. Light fixtures
2. Plumbing fixtures
3. Doors and trim
4. Masonry
5. Electrical devices
6. Appliances
7. Foundations or portions of foundations
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Note: Reused material must be installed to comply the appropriate Title 24
provisions.
16.14.160 Section A4.106.8 Electric Vehicle (EV) Charging for New Construction.
Sections A4.106.8 – A4.106.8.2.2 of the California Green Building Standards
Code are deleted in its entirety, adopted as mandatory measures and is
amended to read:
A4.106.8 Electric vehicle (EV) charging for residential structures. Newly
constructed single‐family and multi‐family residential structures,
including residential structures constructed as part of a mixed‐use
development, shall comply with the following requirements for electric
vehicle supply equipment (EVSE). All parking space calculations under this
section shall be rounded up to the next full space. The requirements
stated in this section are in addition to those contained in Section 4.106.4
of the California Green Building Standards Code. In the event of a
conflict between this section and Section 4.106.4 of the California Green
Building Standards Code, the more robust EV Charging requirements shall
prevail.
A4.106.8.1 New single‐family, duplex and townhouse dwellings. The
following standards apply to newly constructed detached and attached
single‐family, duplex and townhouse residences.
(a) In general. The property owner shall provide One (1) Level 2
electrical vehicle supply equipment (EVSE) or one (1) EV ready
space for each residence (except for accessory dwelling unit
(ADU)).
(b) Location. The proposed location of a charging station may be
internal or external to the dwelling and shall be in close proximity
to an on‐site parking space consistent with city regulations.
A4.106.8.2 New multi‐family dwellings. In addition to the applicable
standards in the 2025 California Green Building Standards Code, the
following standards apply to newly constructed residences in a multi‐
family residential structure.
(a) Resident parking. The property owner shall provide at least one
(1) Level 2 electrical vehicle supply equipment (EVSE) or one (1)
Level 2 EV Ready space for each residential unit in the structure .
(b) Location. The EVSE, receptacles, and/or raceway required by this
section shall be placed in locations allowing convenient installation
of and access to EVSE. In addition, if parking is deed‐restricted to
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individual residential units, the EVSE or receptacles required by
subsection (a) shall be located such that each unit has access to its
own EVSE or receptacle. Location of EVSE or receptacles shall be
consistent with all city regulations.
A4.106.8.3 New hotels and motels. The following standards apply to
newly constructed hotels.
(a) In general. The property owner shall comply with Section
4.106.4.2.6 of the California Green Building Standards Code.
(b) Location. The EVSE and/or receptacles, required by this section
shall be placed in locations allowing convenient installation of and
access to EVSE. Location of EVSE or receptacles shall be consistent
with all City guidelines, rules, and regulations.
16.14.170 Section A4.106.9 Bicycle Parking.
Section A4.106.9 of Appendix A4 of the California Green Building Standards Code
is not adopted as a Tier 1 and Tier 2 elective measure. Projects must comply with
the bicycle parking requirements in the Palo Alto Municipal Code.
16.14.180 Section A4.106.10 Light Pollution Reduction.
Section A4.106.10 is added and adopted as a Tier 1 and Tier 2 elective measure
for all covered projects and is amended to read:
A4.106.10 Light pollution reduction. Outdoor lighting systems shall be
designed and installed to comply with the following:
1. The minimum requirements in the California Energy Code for
Lighting Zones 1‐4 as defined in Chapter 10 of the California
Administrative Code; and
2. Backlight, Up light and Glare (BUG) ratings as defined in IES TM‐15‐11; and
3. Allowable BUG ratings not exceeding those shown in TABLE 5.106.8 [N];
or
Comply with a local ordinance lawfully enacted pursuant to
Section 101.7 of this code, whichever is more stringent.
Projects may use an approved equal reference standard for light
fixtures where BUG ratings are unavailable.
Exceptions:
1. Luminaires that qualify as exceptions to the California Energy Code.
2. Emergency lighting.
3. One‐ and two‐family dwellings.
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Note: The International Dark‐Sky Association (IDA) and the Illuminating
Engineering Society of North America (IESNA) have developed a Model
Lighting Ordinance (MLO). The MLO was designed to help municipalities
develop outdoor lighting standards that reduce glare, light trespass, and
skyglow. The model ordinance and user guides for the ordinance may be
accessed at the International Dark‐Sky Association web site.
Division A4.2 – ENERGY EFFICIENCY
16.14.190 Section A4.203.1 Performance Approach for Newly Constructed Buildings.
Section A4.203.1 of Appendix A4 of the California Green Building Standards Code
is not adopted as a Tier 1 and Tier 2 elective measure. Projects shall comply with
Chapter 16.17 of the Palo Alto Municipal Code (California Energy Code).
Division A4.3 – WATER EFFICIENCY AND CONSERVATION
16.14.200 Section A4.304.3 Irrigation Metering Device.
Section A4.304.3 of Appendix A4 of the California Green Building Standards Code
is adopted as a Tier 1 and Tier 2 elective measure and is amended to read:
A4.304.3 Irrigation metering device. Dedicated irrigation meters from
CPAU are to be installed in all new construction and rehabilitated
landscapes when the landscape is greater than 1,000 square feet.
16.14.210 Section A4.305 Water Reuse Systems.
Sections A4.305.1, A4.305.2, and A4.305.3 of Appendix A4 of the California
Green Building Standards Code are adopted as Tier 1 and Tier 2 elective
measures and are amended to read:
A4.305.1 Graywater. Alternative plumbing piping is installed to permit the
discharge from the clothes washer and other fixtures (except toilets and
kitchen sinks) to be used for an irrigation system in compliance with the
California Plumbing Code. In the event that the whole house graywater
system is installed in compliance with the California Plumbing Code, then
this measure shall count as 3 electives.
A4.305.2 Recycled water piping. Based on projected availability, dual
water piping is installed for future use of recycled water at the following
locations:
1. Interior piping for the use of recycled water is installed to serve all
water closets, urinals, and floor drains.
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2. Exterior piping is installed to transport recycled water from the
point of connection to the structure. Recycled water systems shall
be designed and installed in accordance with the California
Plumbing Code.
A4.305.3 Recycled water for landscape irrigation. Recycled water piping
is used for landscape irrigation.
16.14.220 A4.305.4 Additions and Alterations.
Section A4.305.4 is added as Tier 1 and Tier 2 prerequisite to read:
A4.305.4 Additions and alterations. All multi‐family residential additions
and alterations must install recycled water infrastructure for irrigation
when the landscape area exceeds 1,000 square feet.
Division A4.4 – MATERIAL CONSERVATION AND RESOUCE EFFICIENCY
16.14.230 Section A4.403.1 Frost Protection Foundation Systems.
Sections A4.403.1 is not adopted as a Tier 1 and Tier 2 elective measure.
16.14.240 Section A4.403.2 Reduction in cement use.
Section A4.403.2 of Appendix A4 of the California Green Building Standards Code is
adopted as a Mandatory measure for all Tier 1 and Tier 2 projects and is amended to
read:
A4.403.2 Low carbon concrete requirements.
A4.403.2.1 Purpose. The purpose of this chapter is to provide practical
standards and requirements for the composition of concrete, as defined
herein, that maintains adequate strength and durability for the intended
application and at the same time reduces greenhouse gas emissions
associated with concrete composition. This code includes pathways for
compliance with either reduced cement levels or lower‐emission
supplementary cementitious materials.
A4.403.2.2 Definitions. For the application of this section the following
definitions shall apply:
Concrete. Concrete is any approved combination of mineral aggregates
bound together into a hardened conglomerate in accordance with the
requirements of this code.
Environmental product declaration (EPD). EPDs present quantified
environmental information on the life cycle of a product to enable
comparisons between products fulfilling the same function. EPDs must
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conform to ISO 14025, and EN 15804 or ISO 21930, and have at least a
"cradle to gate" scope (which covers product life cycle from resource
extraction to the factory).
Upfront embodied carbon (embodied carbon). The greenhouse gasses
emitted in material extraction, transportation and manufacturing of a
material corresponding to life cycle stages A1 (extraction and upstream
production), A2 (transportation), and A3 (manufacturing). Definition is as
noted in ISO 21930 and as defined in V2.3 Product Category Rule for
Concrete by NSF dated November 2023.
https://d2evkimvhatqav.cloudfront.net/documents/PCR‐Product‐Category‐Rules/PCR‐
Concrete‐2023‐deviation.pdf https://d2evkimvhatqav.cloudfront.net/documents/PCR‐Product‐
Category‐Rules/PCR‐Concrete‐2023‐deviation.pdf?v=1701797590
A4.403.2.3 Compliance. Compliance with the requirements of this chapter
shall be demonstrated through any of the compliance options in Sections
A4.403.2.3.2 through A4.403.2.3.5:
TABLE A4.403.2.3 Cement and Embodied Carbon Limit
Pathways
A4.403.2.3.1 Allowable increases.
(1) Cement and Embodied Carbon Limit Allowances. Cement or Embodied
Carbon limits shown in Table A4.403.2.3 can be increased by 30% for
concretes demonstrated to the Building Official as requiring high early
strength. Such concretes could include, but are not limited to, precast,
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prestressed concrete; beams and slabs above grade; and shotcrete
(2) Approved Cements. The maximum cement content may be increased
proportionately above the tabulated value when using an approved
cement, or blended cement, demonstrated by approved EPD to have a
plant‐specific EPD lower than 1040 kg CO2e/metric ton. The increase in
allowable cement content would be (1040 / plant=specific EPD) %.
A4.403.2.3.2 Cement limit method — mix. Cement content of a concrete
mix using this method shall not exceed the value shown in the Table
A4.403.2.3. Use of this method is limited to concrete with specified
compressive strength not exceeding 5,000 psi.
A4.403.2.3.3 Cement limit method — project. Total cement content shall
be based on total cement usage of all concrete mix designs within the same
project. Total cement content for a project shall not exceed the value
calculated according to Equation A4.403.2.3.3.
Equation A4.403.2.3.3:
Cem proj < Cem allowed
where
Cem proj = ΣCem n v n and Cem allowed = ΣCem lim v n
and
n = the total number of concrete mixtures for
the project Cem n = the cement content for
mixture n , kg/m 3 or lb/yd 3
Cem lim = the maximum cement content for mixture n per Table
A4.403.2.3, kg/m 3 or lb/yd 3
v n = the volume of mixture n concrete to be placed, yd 3 or m 3
Applicant can use yd 3 or m 3 for calculation, but must keep same units
throughout
A4.403.2.3.4. Embodied carbon method — mix. Embodied carbon of a
concrete mix, based on an approved environmental product declaration
(EPD), shall not exceed the value given in Table A4.403.2.3.
A4.403.2.3.5. Embodied carbon method — project. Total embodied
carbon (EC proj ) of all concrete mix designs within the same project shall not
exceed the project limit (EC allowed ) determined using Table A4.403.2.3 and
Equation A4.403.2.3.5.
Equation A4.403.2.3.5:
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EC proj < EC allowed
where
EC proj = ΣEC n v n and EC allowed = ΣEC lim v n
and
n = the total number of concrete mixtures for the project
EC n = the embodied carbon potential for mixture n per mixture EPD, kg/m 3
EC lim = the embodied carbon potential limit for mixture n per Table
A4.403.2.3, kg/m3 v n = the volume of mixture n concrete to be placed,
yd 3 or m 3
Applicant can use yd 3 or m 3 for calculation, but must keep same units
throughout.
A4.403.2.3.6. Enforcement.
As a condition prior to the issuance of every building permit involving
placement of concrete, the permit applicant shall be required to submit a
completed low‐carbon concrete compliance form or other acceptable
methods that shall be provided by and reviewed for compliance by the
building department prior to issuing the permit.
As a condition of such building permits, and prior to approving construction
inspections following placement of concrete, the permit applicant shall be
required to submit batch certificates and/or EPDs provided by the concrete
provider that demonstrate compliance with the low‐carbon concrete compliance
form on file with the building permit. The batch certificates and/or EPDs shall be
reviewed for compliance by the building department prior to approving any
further inspections.
When deviations from compliance with this section occur, the chief
building official or his designee is authorized to require evidence of
equivalent carbon reductions from the portions of remaining construction
of the project to demonstrate alternative compliance with the intent of this
chapter.
For projects involving placement of concrete by, or on behalf of, a public
works, parks, or similar department the director of such department, or
his/her assignee, shall maintain accurate records of the total volume (in
cubic yards) of all concrete placed, as well as the total compliant volume
(in cubic yards) of all concrete placed, and shall report this data annually to
the governing body in a form expressing an annual compliance percentage
derived from the quotient of total compliant concrete volume placed
divided by total concrete volume placed.
A4.403.2.3.7. Exemptions.
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(a) Hardship or infeasibility exemption. If an applicant for a project subject
to this chapter believes that circumstances exist that make it a hardship or
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 hardship or infeasibility. The applicant
shall identify in writing the specific requirements of the standards for
compliance that the project is unable to achieve and the circumstances that
make it a hardship or infeasible for the project to comply with this chapter.
Circumstances that constitute hardship or infeasibility may include, but are
not limited to the following:
(1) There is a lack of commercially available material necessary to comply with this
chapter;
(2) The cost of achieving compliance is disproportionate to the overall cost of the
project;
(3) Compliance with certain requirements would impair the historic
integrity of buildings listed on a local, state or federal list or register of
historic structures as regulated by the California Historic Building Code
(Title 24, Part 8).
(b) Granting of exemption. If the chief building official determines that it
is a hardship or infeasible for the applicant to fully meet the requirements
of this chapter and that granting the requested exemption will not cause
the building to fail to comply with the California Building Standards Code,
the chief building official shall determine the maximum feasible threshold
of compliance reasonably achievable for the project. In making this
determination, the chief building official shall consider whether alternate,
practical means of achieving the objectives of this chapter can be satisfied.
If an exemption is granted, the applicant shall be required to comply with
this chapter in all other respects and shall be required to achieve the
threshold of compliance determined to be achievable by the chief building
official.
(c) Denial of exception. If the chief building official determines that it is
reasonably possible for the applicant to fully meet the requirements of this
chapter, the request shall be denied and the applicant shall be notified of
the decision in writing. The project and compliance documentation shall be
modified to comply with the standards for compliance.
16.14.250 Section A4.408.1 Enhanced Construction Waste Reduction.
Section A4.408.1 of Appendix A4 of the California Green Building Standards Code
is adopted as a mandatory measure and is amended to read:
A4.408.1 Enhanced construction waste reduction. Nonhazardous
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construction and demolition debris generated at the site is diverted to
recycle or salvage in compliance with the following:
Projects with a given valuation of $25,000 or more must have at least an
80‐percent reduction. Any mixed recyclables that are sent to mixed‐waste
recycling facilities shall include a qualified third party verified facility
average diversion rate. Verification of diversion rates shall meet minimum
certification eligibility guidelines, acceptable to the local enforcing agency.
Exceptions:
1. Residential stand‐alone mechanical, electrical or plumbing
permits.
2. Commercial stand‐alone mechanical, electrical or plumbing
permits.
A4.408.1.1 Documentation. Documentation shall be provided to the
enforcing agency which demonstrates compliance with all construction
and demolition waste reduction requirements.
Division A4.5 – ENVIRONMENTAL QUALITY
16.14.260 Section A4.504.1 Compliance with Formaldehyde Limits.
Section A4.504.1 of Appendix A5 of the California Green Building Standards Code
is adopted as a Tier 1 and Tier 2 elective measure.
16.14.270 Section A4.504.3 Thermal Insulation.
Section A4.504.3 of Appendix A5 of the California Green Building Standards Code
is not adopted as a Tier 1 and Tier 2 prerequisite. Section A4.504.3 is adopted as
a Tier 1 and Tier 2 elective measure.
Part 8 – Local Modifications to CHAPTER 5 – NONRESIDENTIAL MANDATORY
MEASURES
Division 5.1 – PLANNING AND DESIGN
16.14.280 Nonresidential Projects: Chapter 5 Preface Green Building
Requirements for Project Type and Scope.
A Preface is added to Chapter 5 of the California Green Building Standards Code to
read:
Preface – Green Building Requirements for Project Type and Scope. For
design and
construction of nonresidential projects, the City requires compliance with
the mandatory measures of Chapter 5, in addition to use of Tier 1 and Tier
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2 as specified in Palo Alto Municipal Code Chapter 16.14. See Section 202
for definitions on CALGreen MANDATORY, Tier 1 prerequisites and
electives, and Tier 2 prerequisites and electives. All elective measures are
adopted as written under Appendix A5 unless otherwise indicated in this
Section.
16.14.285 Section 5.105.1 Scoping
Section 5.105.1 of Chapter 5 of the California Green Building Standards Code is
amended to read:
5.105.1 Scope. [BSC‐CG] Effective July 1, 2024, alteration(s) to existing
building(s) where the combined altered floor area is 100,000 square feet
or greater shall comply with either Section 5.105.2, 5.409.2, or 5.409.3.
Addition(s) to existing building(s) where the total floor area combined
with the existing building(s) is 100,000 square feet or greater shall
comply with either Section 5.105.2, Section 5.409.2, or Section 5.409.3.
Effective January 1, 2026, the combined floor area shall be 25,000 square
feet or greater.
Exception [BSC‐CG, DSA‐SS]: Combined addition(s) to existing building(s)
of two times the area or more of the existing building(s) is not eligible to
meet compliance with Section 5.105.2.
16.14.290 Section 5.106.1.1 Local ordinance.
Section 5.106.1.1 of Chapter 5 of the California Green Building Standards Code
is amended to read:
5.106.1.1 Local ordinance. Newly constructed projects and additions shall
comply with additional City of Palo Alto stormwater runoff management
and pollution prevention measures as applicable, and as may be amended
from time to time.
16.14.295 Section 5.106.8 Light Pollution Reduction.
Section 5.106.8 of Chapter 5 of the California Green Building Standards Code is amended
to read:
5.106.8 Light pollution reduction. Outdoor lighting systems shall
be designed and installed to comply with the following:
1. The minimum requirements in the California Energy Code for
Lighting Zones 0‐4 as defined in Chapter 10, Section 10‐114 of the
California Administrative Code; and
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2. Backlight (B) ratings as defined in IES TM‐15‐11 (shown in Table A‐1 in
Chapter 8);
3. Uplight and Glare ratings as defined in California Energy Code
(shown in Tables 130.2‐A and 130.2‐B in Chapter 8); and
4. Allowable BUG ratings not exceeding those shown in Table 5.106.8 [N]; or
Comply with a local ordinance lawfully enacted pursuant to
Section 101.7, whichever is more stringent.
Projects may use an approved equal reference standard for light
fixtures where BUG ratings are unavailable.
Exceptions:
1. Luminaires that qualify as exceptions in Section 103.2(b) and
140.7 of the California Energy Code.
2. Emergency lighting.
3. Building facade meeting the requirements in Table 140.7‐B of
the California Energy Code, Part 6.
4. Custom lighting features as allowed by the local enforcing
agency, as permitted by Section 101.8 Alternate materials,
designs and methods of construction.
5. Luminaires with less than 6,200 initial luminaire lumens.
16.14.300 Section 5.106.13 Full Electrification.
Section 5.106 of Chapter 4 of the California Green Building Standards Code is
amended to add new subsection, 5.106.13 as follows:
5.106.13 Full electrification. Full electrification is recommended for new
buildings, substantial remodels, and new outdoor appliances/equipment
such as fireplaces, firepits, heaters for swimming pool/spa, and similar
equipment. Full electrification is required for outdoor grills, stoves, and
barbecues. This subsection does not prohibit freestanding and/or portable
grills, stoves, and barbecues whose source of energy is self‐contained fuel
canisters.
16.14.310 Reserved
16.14.320 Reserved
Division 5.3 – WATER EFFICIENCY AND CONSERVATION
16.14.330 Section 5.304.2 Invasive Species Prohibited.
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Section 5.304.2 of Chapter 5 of the California Green Building Standards Code
is added as mandatory measure to read:
5.304.2 Invasive species prohibited. All nonresidential new construction,
additions, and alterations shall not install invasive species in a landscape
area of any size.
16.14.340 Section 5.306 Nonresidential Enhanced Water Budget.
Section 5.306 of Chapter 5 of the California Green Building Standards Code is
added as mandatory measure to read:
5.306 Nonresidential enhanced water budget. Nonresidential buildings
anticipated to use more than 1,000 gallons of water a day shall complete
an Enhanced Water Budget Calculator as established by the Chief Building
Official or designee.
16.14.350 Section 5.307 Cooling Tower Water Use.
Section 5.307 Cooling Tower Water Use is added as mandatory to read:
5.307 COOLING TOWER WATER USE
5.307.1. Cooling tower water use in high rise residential or nonresidential
buildings.
Cooling tower water use must meet the conditions as follows and as outlined in
Palo Alto
Municipal Code Section 16.08.100. Projects are required to perform a
potable water analysis at the site to meet the maximum concentration of
parameters noted in Table 5.307.1
TABLE 5.307.1
Ca (as CaCO3) 600 ppm
Total alkalinity 500 ppm
SiO2 150 ppm
Cr 300 ppm
Conductivity 3300 Us/cm
Calculate maximum number of cycles that can be achieved
with these levels of concentration shall be included in the
plumbing design plans.
Division 5.4 – MATERIAL CONSERVATION AND RESOUCE EFFICIENCY
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16.14.355 Section 5.409 Life Cycle Assessment
Section 5.409 of Chapter 5 of the California Green Building Standards Code is
amended to read:
5.409.1 Scope. [BSC‐CG] Effective July 1, 2024, nonresidential projects consisting
of newly constructed building(s) with a combined floor area of 100,000 square
feet or greater shall comply with either Section 5.409.2 or Section 5.409.3.
Alteration(s) to existing building(s) where the combined altered floor area is
100,000 square feet or greater shall comply with either Section 5.105.2, 5.409.2,
or 5.409.3. Addition(s) to existing building(s) where the total floor area
combined with the existing building(s) is 100,000 square feet or greater shall
comply with either Section 5.105.2, Section 5.409.2, or Section 5.409.3. Effective
January 1, 2026, the combined floor area shall be 25,000 square feet or greater.
16.14.360 Section 5.410.4.6 Energy STAR Portfolio Manager.
Section 5.410.4.6 of Chapter 5 of the California Green Building Standards is added as
mandatory measure to read:
5.410.4.6 Energy STAR portfolio manager. All nonresidential projects exceeding
$100,000 valuation must provide evidence of an Energy STAR Portfolio
Manager project profile for both water and energy use prior to Permit
Issuance, acquire an Energy STAR Portfolio Manager Rating, and submit
the rating to the City of Palo Alto once the project has been occupied after
12 months.
16.14.370 Section 5.410.4.7 Performance Reviews – Energy.
Section 5.410.4.7 of Chapter 5 of the California Green Building Standards is added to
read:
5.410.4.7 Performance reviews – energy. All projects over 10,000 square
feet. The City reserves the right to conduct a performance review, no more
frequently than once every five years unless a project fails review, to
evaluate the building's energy use to ensure that resources used at the
building and/or site do not exceed the maximum allowance set forth in the
rehabilitation or new construction design. Following the findings and
recommendations of the review, the City may require adjustments to the
energy usage or energy‐using equipment or systems if the building is no
longer compliant with the original design. Renovation or rehabilitation
resulting from such audit activity shall be considered a project and shall
be subject to applicable documentation submittal requirements of the
City. This section is effective only for those projects for which a building
permit was issued after January 1, 2009.
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16.14.380 Section 5.410.4.8 Performance Reviews – Water.
Section 5.410.4.8 of Chapter 5 of the California Green Building Standards is added to
read:
5.410.4.8 Performance reviews – water. All sites greater than one acre:
The City reserves the right to conduct performance reviews, no more
frequently than once every five years unless a project fails review, to
evaluate water use to ensure that resources used at the building and/or
site do not exceed a maximum allowance set forth in the rehabilitation or
new construction design. Water use reviews may be initiated by CPAU, or
as a coordinated effort between the CPAU and the Santa Clara Valley
Water District (SCVWD), or as part of SCVWD's established water
conservation programs. Following the findings and recommendations of
the review, the City may require adjustments to irrigation usage, irrigation
hardware, and/or landscape materials to reduce consumption and
improve efficiency. Renovation or rehabilitation resulting from such audit
activity shall be considered a project and shall be subject to applicable
documentation submittal requirements of the City.
16.14.390 Section 5.506 Indoor Air Quality.
Section 5.506.4 of Chapter 5 of the California Green Building Standards is added
as mandatory measure to read:
Section 5.506.4 Indoor air quality management plan. All commercial and
multi‐ family projects must submit an Indoor Air Quality Management Plan
(IAQ) with building permit application in accordance with the Sheet Metal
and Air Conditioning Contractors National Association (SMACNA IAQ)
Guidelines for Occupied Buildings Under Construction, 2nd edition
ANSI/SMACNA 008‐2008.
Part 9 – Local Modifications to APPENDIX A5 – NONRESIDENTIAL VOLUNTARY
MEASURES
Division A5.1 – PLANNING AND DESIGN
16.14.400 Section A5.106.5.3 Electric Vehicle (EV) Charging for New Construction.
Section A5.106.5.3 – A5.106.5.3.4 of the California Green Building Standards
Code are adopted as mandatory measures and amended to read:
A5.106.5.3 Electric vehicle (EV) charging for nonresidential structures.
New non‐ residential structures shall comply with the following
requirements for electric vehicle supply equipment (EVSE). All parking
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space calculations under this section shall be rounded up to the next full
space. The requirements stated in this section are in addition to those
contained in Section 5.106.5.3 of the California Green Building Standards
Code.
A5.106.5.3.1 Nonresidential structures other than hotels. The following
standards apply to newly constructed nonresidential structures other than
hotels.
Comply with Section 5.106.5.3.1 EV capable spaces, Section 5.106.5.3.2
Electric vehicle charging stations and associated Table A5.106.5.3.3, or
Section A5.106.5.3.4 Electric vehicle charging stations (EVCS)—power
allocation method and associated Table A5.106.5.3.4.
Refer to Section 5.106.5.3.2 for the permitted use of Level 2 or
Direct Current Fast Charger (DCFC) to create EVCS. Refer to Section
5.106.3.2.1 for the allowed use of DCFC to comply with both EV capable
spaces and Level 2 EVSE. Refer to Section 5.106.5.3.3 for the allowed use
of Automatic Load Management System (ALMS).
Table A5.106.5.3.3—Tier 2 EV Capable Spaces and EVCS
Total Number of Actual
Parking Spaces
Number of
Required EV Capable
Spaces
Other than Office and
Retail
Number of Required EVCS
2, 3
Office and Retail
Number of Required EVCS
2, 3
1–9 3 2 2
10–25 8 4 6
26–50 17 9 13
51–75 28 14 21
76–100 40 20 30
101–150 57 29 43
151–200 79 40 59
201 and over 45 percent of actual
parking spaces1
50 percent of EV capable
spaces1
75 percent of EV capable
spaces1
1. Calculation for spaces shall be rounded up to the nearest whole number.
2. Each EVCS shall reduce the number of required EV capable spaces by the same number.
3. At least one Level 2 EVSE shall be provided.
Table A5.106.5.3.4—Tier 2 EVCS – Power Allocation Method
Total Number of Actual
Parking Spaces
Minimum Total kVA
@ 6.6 kVA
Other than Office and
Retail
Total kVA Required
in any Combination of EV
Capable3,4, Low Power
Office and Retail
Total kVA Required
in any Combination of EV
Capable3,4, Low Power
Level 2
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Level 2
Level 21, 2, or DCFC
Level 21, 2, or DCFC
1–9 19.8 19.8 19.8
10–25 52.8 52.8 52.8
26–50 112.2 112.2 112.2
51–75 184.8 184.8 184.8
76–100 264.0 264 264
101–150 376.2 376.2 376.2
151–200 521.4 521.4 521.4
201 and over
45 percent of
actual parking spaces x
6.6
Total required kVA = P x
.45 x 6.6
Where P = Parking
spaces in facility
Total required kVA = P x
.45 x 6.6
Where P = Parking
spaces in facility
1. Level 2 EVSE @ 6.6 kVA minimum.
2. At least one Level 2 EVSE shall be provided.
3. Maximum allowed kVA to be utilized for EV capable spaces is 75 percent.
4. If EV capable spaces are utilized, they shall meet the requirements of Section 5.106.5.3.1 EV
capable spaces.
5. For office and retail buildings the maximum allowed kVA to be utilized for EV capable spaces
is 25 percent.
Location. The EVSE, receptacles, and/or raceway required by this section
shall be placed in locations allowing convenient installation of and access
to EVSE. Location of EVSE or receptacles shall be consistent with all city
regulations.
Division A5.4 – ENERGY EFFICIENCY
16.14.410 Section A5.203.1 Performance Approach for Newly Constructed Buildings.
Section A5.203.1 of Appendix A5 of the California Green Building Standards Code
is not adopted as a Tier 1 and Tier 2 elective measure. Projects shall comply with
Chapter 16.17 of the Palo Alto Municipal Code (California Energy Code).
Division A5.4 – MATERIAL CONSERVATION AND RESOUCE EFFICIENCY
16.14.420 Section A5.405.5 Cement and Concrete.
Section A5.405.5 of Appendix A5 of the California Green Building Standards
Code is adopted as a Mandatory measure for Tier 1 and Tier 2 projects and is
amended to read:
A5.405.5 Cement and concrete. Use cement and concrete made with
recycled products and complying with the following sections and
requirements per PAMC Chapter 16.14.240.
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16.14.430 Section A5.408 Construction Waste Reduction, Disposal and Recycling.
Section A5.408 of Appendix A5 of the California Green Building Standards Code is
adopted as a Mandatory measure for Tier 2 projects and is amended to read:
A5.408.3.1 Waste enhanced construction waste reduction. (80%
construction waste reduction) as a mandatory requirement for all
nonresidential construction, including new construction, additions, and
alterations, as long as the construction has a valuation of
$25,000 or more. Nonresidential projects with a lower valuation shall remain
subject to
California Green Building Standards Code Chapter 5 mandatory measures.
Exceptions:
1. Residential stand‐alone mechanical, electrical or plumbing permits.
2. Commercial stand‐alone mechanical, electrical or plumbing permits.
A5.408.3.1.1 ‐ Deleted
A5.408.3.1.2 Documentation. Documentation shall be provided to the
enforcing agency which demonstrates compliance with all construction and
demolition waste reduction requirements.
SECTION 3. The Council adopts the findings for local amendments to the California
Green Building Standards Code, 2025 Edition, attached hereto as Exhibit “A” and incorporated
herein by reference.
SECTION 4. 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
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 5. The Council finds that this project is exempt from the provisions of the
California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA Guidelines,
because it can be seen with certainty that there is no possibility that the amendments herein
adopted will have a significant effect on the environment and Section 15308, because the
amendments herein adopted is an action taken by the City to assure the maintenance,
restoration, enhancement, or protection of the environment.
//
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SECTION 6. This Ordinance shall be effective on the thirty‐first day after the date of its
adoption.
INTRODUCED:
PASSED:
AYES:
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
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Exhibit A
FINDINGS FOR LOCAL AMENDMENTS TO CALIFORNIA GREEN BUILDING STANDARD CODE
TITLE 24, PART 11
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.
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 Green Building Standard Code, Title 24, Part 11
Chapter(s),
Sections(s),
Appendices
Title Add Deleted Amended Justification
(See below of keys)
101.4 Appendices A, C, E
202 Definitions A
301 Voluntary Tiers Added C, E
301.1 Scope C, E
301.1.1 Residential additions and alterations C, E
301.1.2 Substantial Remodel (50‐50‐50 rule) C, E
301.2 Low‐rise and high‐rise residential buildings C, E
301.2.1 Low‐Rise residential new construction –
Tier 2 adopted
C, E
301.3 Nonresidential additions and alterations C, E
301.3.3 No‐residential new construction – Tier 2 C, E
301.6 Special inspector requirements C, E
301.7 Low‐carbon concrete requirements for Tier
1 and Tier 2 projects
C, E
4.106.5 Full Electrification
C, E
4.306 Swimming pool and spa covers C, E
702.2 Green building special inspection C, E
A4.104.1 Supervision and education by a special
inspector
C, E
*NOT YET APPROVED*
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A4.105.1 Chapter 5.24 of Title 5 of the Municipal
Code
C, E
A4.105.2 Reuse of materials C, E
A4.106.8 Electric vehicle (EV) charging for
residential structures
C, E
A4.106.8.1 New single‐family, duplex and townhouse
dwellings
C, E
A4.106.8.2 New multi‐family dwellings. C, E
A4.106.8.3 New hotels and motels C, E
A4.106.9 Bicycle Parking C, E
A4.106.10 Light pollution reduction C, E
A4.203.1 Performance Approach for Newly
Constructed Buildings
C, E
A4.304.3 Irrigation metering device C, E
A4.305.1 Graywater C, E
A4.305.2 Recycled water piping C, E
A4.305.3 Recycled water for landscape irrigation C, E
A4.305.4 Additions and alterations C, E
A4.403.1 Frost Protection Foundation Systems C
A4.403.2 Reduction in cement use C, E
A4.403.2.1 Purpose C, E
A4.403.2.2 Definitions C, E
A4.403.2.3 Compliance C, E
Table
A4.403.2.3
Cement and Embodied Carbon Limit
Pathways
C, E
A4.403.2.3.1 Allowable increases C, E
A4.403.2.3.2 Cement limit method ‐ mix C, E
A4.403.2.3.3 Cement limit method ‐ project C, E
A4.403.2.3.4 Embodied carbon method ‐ mix C, E
A4.403.2.3.5 Embodied carbon method ‐ project C, E
A4.403.2.3.6 Enforcement A
A4.403.2.3.7 Exemptions A
A4.408.1 Enhanced construction waste reduction C, E
A4.408.1.1 Documentation A
A4.504.1 Compliance with Formaldehyde Limits C, E
A4.504.3 Thermal Insulation C, E
5.105.1 Scoping C, E
5.106.1.1 Local ordinance C, E
5.106.8 Light pollution reduction C, E
5.106.3 Full Electrification C, E
*NOT YET APPROVED*
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5.304.2 Invasive species prohibited C
5.306 Nonresidential enhanced water
budget
C, E
5.307.1 Cooling tower water use in high‐rise
residential or nonresidential buildings
C, E
5.409.1 Scope
C, E
5.410.4.6 Energy STAR portfolio manager C, E
5.410.4.7 Performance reviews – energy C, E
5.410.4.8 Performance reviews – water C, E
5.506.4 Indoor air quality management plan E
A5.106.5.3 Electric vehicle (EV) charging for
nonresidential structures
C, E
A5.106.5.3.1 Nonresidential structures other than hotels C, E
A5.203.1 Performance Approach for Newly
Constructed Buildings
C, E
A5.405.5 Cement and concrete C, E
A5.408.3.1 Waste enhanced construction waste
reduction
C, E
A5.408.3.1.1 Enhanced construction waste reduction –
Tier 2
A
A5.408.3.1.2 Documentation A
*NOT YET APPROVED*
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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 Building Standards Code is
required. Natural gas combustion and gas appliances emit a wide range of air pollutants,
such as carbon monoxide (CO), nitrogen oxides (NOx, including nitrogen dioxide (NO2)),
particulate matter (PM), and formaldehyde, which according to a UCLA Study, have
been linked to various acute and chronic health effects, and additionally exceed levels
set by national and California‐based ambient air quality standards. 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, 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 construction of more
energy efficient buildings can help Palo Alto reduce its share of the GHG emissions that
contribute to climate change. All‐electric new buildings benefit the health, safety, and
welfare, of Palo Alto and its residents. Requiring all‐electric construction, without gas
infrastructure will reduce the amount of greenhouse gas produced in Palo Alto and will
contribute to reducing the impact of climate change and the associated risks. Due to
decrease in annual rain fall, Palo Alto experiences the effect of drought and water saving
more than some other communities in California. Embodied carbon of concrete is a
significant contributor to greenhouse gas emissions and climate change, and this
amendment includes a requirement to use low‐carbon concrete. Providing additional
capacity for electric vehicle use reduces use of gasoline which is a major contributor to
climate change.
E Green building 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 green provisions in this Chapter are designed to achieve the
following goals:
(a) Increase energy efficiency in buildings;
(b) Reduce the use of natural gas in buildings which improves indoor environmental
quality and health;
*NOT YET APPROVED*
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(c) Reduce the use of natural gas which will reduce the natural gas infrastructure and fire
risk over time;
(d) Reduce the embodied carbon of concrete which reduces greenhouse gas
emissions;
(e) Increase water and resource conservation;
(f) Reduce waste generated by construction and demolition projects;
(g) Provide durable buildings that are efficient and economical to own and operate;
(h) Promote the health and productivity of residents, workers, and visitors to the city;
(i) Recognize and conserve the energy embodied in existing buildings;
(j) Increase capacity for use of electric vehicles which reduces greenhouse gas
emissions and improves air quality;
(k) Encourage alternative transportation; and
(l) 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 hazard 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
earthquake. The other fault is 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 which
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. Reduction or eliminating of
natural gas infrastructure over time will reduce maintenance costs and fire risk in difficult
geological conditions.
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 Code is warranted. In addition, the reduction or elimination of natural gas
infrastructure reduces the likelihood of fire or environmental damage should they
become disrupted due to challenging topographic conditions during construction or
repair.
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TO: George Hoyt and David Chung, City of Palo Alto
FROM: Melanie Jacobson, Michelle Mann, and Leila Silver, ID360
CC: Jonathan Abendschein, Timothy Scott, Christine Luong, Evon
Ballash, Julia Knight, City of Palo Alto
DATE: July 3, 2025
SUBJECT: Evaluation of CALGreen vs. LEED for Palo Alto Nonresidential
Projects
BACKGROUND
At the request of the City of Palo Alto Staff Reach Code Team, ID360
conducted an evaluation comparing the performance and
requirements of nonresidential projects subject to the City’s Green
Building Ordinance with the Leadership in Energy and Environmental
Design Version 5 (LEED v5) rating system.
This memo evaluates three completed nonresidential construction
projects in Palo Alto, examining how each aligns with LEED v5 criteria.
Each project received approval of the Building 101 Final Inspection
during the current 2022 code cycle, which became effective January 1,
2023.
The goal of this study is to assess the extent to which current local
building practices meet or exceed LEED standards and to identify
opportunities for enhancing the City’s green building ordinance. For
the 2025 building code update, staff is exploring the benefits and
challenges of allowing LEED certification as an alternative compliance
pathway to the City’s CALGreen Tier 1 and Tier 2 requirements. In the
surrounding region, it is common for neighboring jurisdictions to
require LEED certification for various building types.1 The findings aim
to inform policy discussions and guide potential updates to strengthen
environmental performance requirements for new and renovated
commercial buildings.
1 Appendix C includes a comprehensive table of LEED certification requirements for 9
neighboring jurisdictions in the San Francisco Peninsula.
1
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CALGreen Tiers and LEED Overview
Both CALGreen Tier standards and LEED certification systems establish mandatory baseline
requirements (prerequisites) that each project must meet. In addition, they offer a flexible
framework that allows project teams to select optional measures (electives or credits) that
best align with the specific scope and goals of the project. While both systems aim to
promote sustainable building practices, they differ significantly in terms of scope, intent,
structure, category coverage, certification criteria, and verification processes.
It is important to note that a project that pursues LEED will have to comply with the
mandatory requirements of the California Green Building Code (Title 24, Part 11), California
Energy Code (Title 24, Part 6), and the City's local amendments (PAMC).
Scope and Intent
• CALGreen Tiers
o Part of California’s mandatory building code (Title 24, Part 11).
o Focuses on minimum sustainability standards for energy efficiency, water
conservation, material conservation, indoor air quality, and site development.
o Tier 1 and Tier 2 are voluntary enhancements beyond the base CALGreen
code:2
§ Tier 1 = moderate increase in performance.
§ Tier 2 = higher level of performance.
• LEED v5
o A voluntary national/international rating system administered by the U.S.
Green Building Council (USGBC).
o Broad scope that covers site selection, innovation, social equity, and
operational performance.
o Offers certification levels (Certified, Silver, Gold, Platinum) based on point
accumulation.
Structure and Flexibility
• CALGreen Tier 1 & Tier 2
2 The City of Palo Alto has continued to adopt CALGreen Tier 1 and Tier 2 standards for both residential and
nonresidential construction projects. The level of CALGreen Tier depends on the project’s scope of work.
2
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o Prescriptive and performance-based options but less flexible.
o Limited ability to substitute measures (projects must choose specific number
of electives from each category).
o Tier 1 and 2 require specific checklists and documentation for compliance.
• LEED v5
o Prerequisite measures must be met based on project type.
o Flexible credit-based system allowing project teams to choose how they earn
points. Many options and paths available for each credit.
o Encourages innovation and trade-offs across categories.
Mixed Occupancy Buildings
• CALGreen Tier 1 & Tier 2
o In a mixed occupancy building, each portion must follow the green building
rules that apply to its specific use. (CALGreen Section 302.1).3
• LEED v5
o The entire gross floor area of a LEED project must be certified under a single
rating system and is subject to all prerequisites and attempted credits in that
rating system, regardless of mixed construction or space usage type.
o The “40/60” rule is used to determine which rating system and credits apply.
If 60% or more of the project’s gross floor area consists of a specific project
type, the project must meet the requirements for that type.
Green Categories
Table 1 includes a brief summary of the general green building categories across
CALGreen and the LEED v5 rating system. The LEED categories aim to drive high-
performance, sustainable, and resilient buildings by addressing environmental and human
health priorities. The newly released LEED v5 also emphasizes carbon tracking, equity, and
climate resilience, which are not included in CALGreen. The 2022 CALGreen categories
continue to focus on green building standards for sustainability, health, and resource
efficiency.
3 For example, retail spaces on the first floor would comply with the nonresidential requirement of Chapter 5
and the residential dwelling units on the second and third floor would comply with the residential
requirements of Chapter 4.
3
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Table 1: Green Building Categories
Green Category CALGreen Tiers LEED v5
Water Focuses on indoor/outdoor
efficiency, submetering
Comprehensive, including Water
Balance Table and lifecycle thinking
Materials Emphasizes VOC limits, recycled
content
Emphasizes embodied carbon, EPDs,
circularity
Indoor Air
Quality
Filtration, ventilation, low-emitting
materials
More comprehensive IAQ plans and
monitoring
Site/Location Minimal (stormwater, bike parking,
heat island)
Strong focus on location efficiency,
connectivity, resilience
Operations Cx, O&M, Not addressed post-
occupancy
Includes commissioning, metering,
ongoing performance
Certification and Verification
• CALGreen Tiers
o Verified by local code officials or third-party reviewers as part of the building
permit and inspection process.
o The City of Palo Alto requires third-party Green Building Special Inspectors
(GBSIs) to support the plan check and inspection compliance process for
each green building project.
• LEED v5
o Third-party verified by GBCI (Green Business Certification Inc.), requiring
rigorous documentation and sometimes additional modeling or
commissioning.
METHODOLOGY
To conduct the evaluation, the project team analyzed existing building permit data to select
three representative nonresidential projects that reflect a variety of building types and
demonstrate different levels of compliance with the City’s current Green Building Ordinance.
• Case Study 1: NR Tenant Improvement (Tier 1) - A nonresidential tenant
improvement project subject to CALGreen Tier 1 requirements. The scope of work
includes modifications of an existing 37,150 sq ft 2-story building with a one level
basement, including expansion of an existing café, a new restroom block,
reorganizing the existing large medium room into smaller meeting rooms, and finish
updates.
4
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• Case Study 2: NR New Construction (Tier 2) - A two-story nonresidential core and
shell construction project subject to CALGreen Tier 2 requirements. The scope of
work includes a 21,933 sq ft office building over one level basement garage, site
improvements, surface parking, outdoor landscape amenities, and plaza areas. The
building is designed for a single tenant’s occupancy.
• Case Study 3: NR Mixed Use New Construction (Tier 2) - A three-story mixed-use new
construction project subject to CALGreen Tier 2 requirements. The scope of work
includes 6,995 sq ft commercial office, 19 residential dwelling units, and one level
below grade parking. The project includes relevant site work, including excavation,
grading, paving, landscaping, and utility connections.
Each project was evaluated using construction documents, permit records, and relevant
compliance materials available in the City’s permitting software system, Accela. The team
then conducted a comparative assessment of how each project would perform if it were
evaluated using the LEED v5 rating system for Building Design and Construction (BD+C) or
Interior Design and Construction (ID+C)4, as appropriate.
The analysis focused on identifying which LEED prerequisites and credits would likely be
met by each project based on documented compliance with the City's ordinance, and
which would not. The comparison was used to assess both the stringency and the scope of
the City’s green building requirements relative to LEED v5.
LEED Scorecard
As part of the evaluation of the CALGreen and LEED rating systems, the project team
prepared LEED v5 Scorecards for each of the three projects included in this analysis. These
scorecards reflect the most current published versions of the LEED v5 Building Design and
Construction (BD+C) and Interior Design and Construction (ID+C) rating systems. The
completed scorecards are provided in Appendix A for reference. Appendix B is also
included for reference and outlines each prerequisite and elective measure the project
4 The U.S. Green Building Council (USGBC) launched the latest version, LEED v5, of the Leadership in Energy
and Environmental Design (LEED) green building program on April 28, 2025. LEED v5 registration is now
available for new construction, interior and existing commercial building projects through USGBC’s ARC
platform.
5
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pursued to demonstrate compliance with CALGreen and the Palo Alto Municipal Code
(PAMC).
The key sections of the LEED Scorecards used in the analysis are summarized below:
• LEED Credit Categories: The LEED rating system organizes the prerequisites and
credits into eight categories: Integrative Process, Planning, and Assessments (IP),
Location and Transportation (LT), Sustainable Sites (SS), Water Efficiency (WE),
Energy and Atmosphere (EA), Materials and Resources (MR), Indoor Environmental
Quality (EQ), and Project Priorities (PR).
• LEED Prerequisite/Credit: Each LEED prerequisite and credit for each credit category
is listed on the scorecard.
• Yes, Maybe, No Columns: Each prerequisite and credit in the LEED Scorecards was
labeled as “Yes” (Y), “Maybe” (M), or “No” (N) based on a review of the project’s
approved plans, supporting documentation, GB-1 Sheet, and applicable CALGreen
and Palo Alto Green Building/Energy Reach Code requirements. The assumptions
informing these determinations are detailed in the “Assumptions” section of this
memo.
• Notes: Brief notes have been included to provide additional context for each
prerequisite and credit. Assumptions were necessary in some cases due to
discrepancies between the LEED rating systems and the applicable code cycles.
• Points: The scorecard summarizes the total number of “Yes” (Y), “Maybe” (M), and
“No” (N) responses for each credit category. These totals are also provided at the
bottom of the scorecard for overall reference. For the purpose of this evaluation,
both “Yes” and “Maybe” points are counted toward estimating the project’s
potential LEED certification level. LEED does not award points for prerequisites, which
are mandatory for certification. However, the project team labeled prerequisites as
“Yes” or “Maybe” based on information from the GB-1 Sheet and assumed
compliance in alignment with LEED’s prerequisite requirements.
6
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ASSUMPTIONS
Several assumptions were made during the analysis in order to standardize comparisons
and account for variations in project documentation and code cycles:
• Code Cycle Alignment: Two of the projects analyzed were originally permitted
under earlier editions of the California Building Standards Code (Title 24, California
Code of Regulations).5 For the purpose of this study, the project team assumed these
projects would comply with the most current applicable code requirements, including
the 2022 Title 24 standards, CALGreen, and relevant local amendments to the Palo
Alto Municipal Code (PAMC), to better align the analysis with the City’s current
policy framework and regulatory environment.
• LEED Version: LEED v5 rating systems were applied based on project type:
o LEED v5 BD+C: New Construction for ground-up new buildings
o LEED v5 ID+C: Commercial Interiors for tenant improvement projects
Assumptions were made about standard compliance approaches (e.g.,
modeled performance for energy credits, prescriptive pathways for water
and materials) where documentation was incomplete.
• Documentation and Credit Estimation: In cases where documentation did not
explicitly demonstrate compliance with a specific LEED credit, credit achievement
was estimated based on known building practices, required code compliance, or
typical strategies used for similar project types.
• Standardized Interpretation: To ensure consistency across case studies, a
standardized LEED v5 compliance checklist was developed and used for all three
projects. The checklist reflects commonly used pathways and default thresholds
unless project-specific evidence suggested otherwise.
5 Case Study 2 submitted under the 2019 building code cycle and was required to meet the City’s Green
Building Ordinance 5485 and Energy Reach Code Ordinance 5481. Case Study 3 submitted under the 2016
code cycle and was required to meet the City’s Green Building Ordinance 5383 and Energy Reach Code
Ordinance 5393. Case Study 1 is subject to the current 2022 code cycle and relevant local PAMC
requirements.
7
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• Project Priorities Credit Category: At the time of this evaluation, the "Project
Priorities” credit category was not yet made available to the public. Therefore, the
ID360 team conservatively assumed each case study would earn 5 out the 9 credits
available to each project. This assumption is based on our experience on similar
projects in the region and the previous Regional Priority credit category.
These assumptions were necessary to provide a consistent and fair evaluation framework
across all selected projects, especially given varying levels of documentation and the
evolving nature of the City's green building requirements.
RESULTS
Case Study #1: Tenant Improvement (Tier 1)
Project Type: Nonresidential Tenant Improvement
Code Cycle: 2022
CALGreen Compliance Tier: Tier 1
LEED Rating System Used for Comparison: LEED v5 ID+C: Commercial Interiors
Scope of Work
Case Study 1 is a tenant improvement within an existing, single-tenant building. The scope
includes demolition and reconstruction of non-load-bearing partitions, as well as updates to
lighting and ceilings. On Level 1, the work expands the existing café, including the front-of-
house seating area, back-of-house kitchen, and service line, and adds two manually
operated sliding partitions. A new restroom block has also been added to meet the City of
Palo Alto’s plumbing fixture requirements. On Level 2, the updates are limited to refreshing
the existing pantry and converting a large meeting room into smaller ones, along with
general finish upgrades throughout. The total area of work is 37,150 sq ft.
Key Findings
• Based on the submitted permit information, the project is anticipated to meet 8 of
the 14 LEED prerequisites. The project would be required to pursue additional design
and construction elements to meet the minimum standards which are not included in
the local building code. Several of these prerequisite elements include owner-related
policies and operational standards not typically associated with the building code.
These are marked as “Yes” (Y) on the LEED project scorecard. The remaining 6
8
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prerequisites are designated as “Maybe” (M), as they are either not required under
the CALGreen code or would require the applicant to undertake additional efforts
not mandated by CALGreen Tiers or the Palo Alto Municipal Code (PAMC). Because
all prerequisites must be met for LEED certification, none were marked as “No” (N) in
the scorecard.
• The potential LEED rating for the project is based on the combined total of credits
identified as “Yes” (Y) and “Maybe” (M). In total, the project includes 27 points
classified as “Yes” and 35 points classified as “Maybe.” For a conservative estimate,
assuming the project achieves 75% of the “Maybe” credits, the projected total is 53
points—qualifying the project for a potential LEED Silver rating. If all “Maybe” credits
are ultimately achieved (100%), the project is anticipated to earn approximately 62
points, aligning with a potential LEED Gold rating.
• The following LEED credit categories are strongly aligned with the City’s ordinance:
o Location and Transportation (LT)
o Water Efficiency (WE)
o Materials & Resources (MR)
o Indoor Environmental Quality (EQ)
• Gaps were observed in the following LEED credit areas:
o Integrative Process, Planning, and Assessments (IP)
o Energy and Atmosphere (EA)
o Project Priorities & Innovation (PR)
Case Study #2: New Construction (Tier 2)
Project Type: Nonresidential New Construction
Code Cycle: 2019
CALGreen Compliance Tier: Tier 2
LEED Rating System Used for Comparison: LEED v5 BD+C: Building Design & Construction
Scope of Work:
Case Study 2 is a 21,933 sq ft two-story office building over one level basement garage.
Site improvements include new access drive, surface parking and outdoor landscape
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amenity / plaza areas. Existing ground water extraction treatment facility toward rear of site
to remain.
Key Findings:
• Based on the submitted permit information, the project is anticipated to meet 12 of
the 16 LEED prerequisites. The project would be required to pursue additional design
and construction elements to meet the minimum standards which are not included in
the local building code. Several of these prerequisite elements include owner-related
policies and operational standards not typically associated with the building code.
These are marked as “Yes” (Y) on the LEED project scorecard. The remaining 4
prerequisites are designated as “Maybe” (M), as they are either not required under
the CALGreen code or would require the applicant to undertake additional efforts
not mandated by CALGreen Tiers or the Palo Alto Municipal Code (PAMC). Because
all prerequisites must be met for LEED certification, none were marked as “No” (N) in
the scorecard.
• The potential LEED rating for the project is based on the combined total of credits
identified as “Yes” (Y) and “Maybe” (M). In total, the project includes 33 points
classified as “Yes” and 28 points classified as “Maybe.” For a conservative estimate,
assuming the project achieves 75% of the “Maybe” credits, the projected total is 54
points—qualifying the project for a potential LEED Silver rating. If all “Maybe” credits
are ultimately achieved (100%), the project is anticipated to earn approximately 61
points, aligning with a potential LEED Gold rating.
• The following LEED credit categories are strongly aligned with the City’s ordinance:
o Location and Transportation (LT)
o Sustainable Sites (SS)
o Water Efficiency (WE)
o Energy and Atmosphere (EA)
o Materials and Resources (MR)
• Gaps were observed in the following LEED credit areas:
o Integrative Process, Planning, and Assessments (IP)
o Indoor Environmental Quality (EQ)
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o Project Priorities & Innovation (PR)
Case Study #3: Mixed Use New Construction (Tier 2)
Project Type: Mixed-Use New Construction
Code Cycle: 2016
Compliance Tier: Tier 2
LEED Rating System Used for Comparison: LEED v5 BD+C: Building Design & Construction
Scope of Work:
Case Study 3 is a 47,074 sq ft three-story mixed-use building with one level of below-grade
parking commercial office spaces on the first and second floor, as well as 19 residential
dwelling units. The project includes relevant site work, including excavation, grading,
paving, landscaping, a covered courtyard and utility connections.
Key Findings:
• Based on the submitted permit information, the project is anticipated to meet 11 of
the 16 LEED prerequisites. The project would be required to pursue additional design
and construction elements to meet the minimum standards which are not included in
the local building code. Several of these prerequisite elements include owner-related
policies and operational standards not typically associated with the building code.
These are marked as “Yes” (Y) on the LEED project scorecard. The remaining 5
prerequisites are designated as “Maybe” (M), as they are either not required under
the CALGreen code or would require the applicant to undertake additional efforts
not mandated by CALGreen Tiers or the Palo Alto Municipal Code (PAMC). Because
all prerequisites must be met for LEED certification, none were marked as “No” (N) in
the scorecard.
• The potential LEED rating for the project is based on the combined total of credits
identified as “Yes” (Y) and “Maybe” (M). In total, the project includes 39 points
classified as “Yes” and 18 points classified as “Maybe.” For a conservative estimate,
assuming the project achieves 75% of the “Maybe” credits, the projected total is 52
points—qualifying the project for a potential LEED Silver rating. If all “Maybe” credits
are ultimately achieved (100%), the project is anticipated to earn approximately 57
points, aligning with a potential LEED Silver rating.
11
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• The following LEED credit categories are strongly aligned with the City’s ordinance:
o Location and Transportation (LT)
o Sustainable Sites (SS)
o Water Efficiency (WE)
o Energy and Atmosphere (EA)
o Materials and Resources (MR)
• Gaps were observed in the following LEED credit areas:
o Integrative Process, Planning, and Assessments (IP)
o Indoor Environmental Quality (EQ)
o Project Priorities & Innovation (PR)
Notable Gaps, Risks and Opportunities:
• CALGreen Tier Prerequisites: To achieve CALGreen Tier 1 or Tier 2 status, a project
must comply with all applicable prerequisite measures for the selected tier and
select the required number of elective measures from each CALGreen division. Most
CALGreen and Palo Alto Municipal Code (PAMC) prerequisites do not have direct
equivalents in the LEED rating system.6, Notable CALGreen Tier prerequisites without
LEED prerequisite counterparts include:
o Designated parking for clean air vehicles
o Cool roof requirements to reduce the heat island effect
o Minimum recycled content in building materials
o Enhanced construction waste reduction
o VOC limits for resilient flooring systems
o Formaldehyde limits for thermal insulation
o Electric vehicle charging infrastructure requirements
While these measures are not LEED prerequisites, projects may still earn LEED credits
if they meet relevant criteria aligned with these CALGreen requirements.
6 See Appendix E for a comparison of the LEED v5 BD+C and CALGreen Tier 1 and Tier 2 prerequisites.
7 See Appendix F for a comparison of the LEED v5 ID+C and CALGreen Tier 1 and Tier 2 prerequisites.
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• LEED Prerequisites: If a project elects to pursue LEED certification, all LEED
prerequisites must be fully addressed and integrated into the project's design and
construction phases. For the purpose of this evaluation, all measures referenced are
assumed to comply with the mandatory LEED prerequisite requirements. New
prerequisites and credits introduced in LEED v5 are not required by CALGreen and
go further than the statewide requirements. Most of these prerequisites and credits
are tied to decarbonization strategies, embodied carbon of building materials,
health, comfort and community impact.8
• Embodied Carbon: The City’s ordinance does not currently address whole building
embodied carbon or life-cycle impact reductions, which are encouraged in LEED v5.
CALGreen Embodied Carbon requirements currently impact new nonresidential
buildings 100,000 sq ft or more.9
• Commissioning: Enhanced commissioning and performance verification practices go
beyond the City’s current Tier 1 requirements. These additional measures may
require substantial effort, particularly for nonresidential tenant improvement projects
or smaller nonresidential alterations. The California Energy Code (Title 24, Part 6,
Section 120.8) mandates building commissioning for new nonresidential buildings
(excluding healthcare facilities) with conditioned floor areas of 10,000 sq ft or more.
CALGreen (Section 5.410.2) adopts the same 10,000 sq ft threshold for full-scope
commissioning. For new buildings under 10,000 sq ft or new systems serving
additions or alterations, CALGreen requires system testing and adjusting, similar to
the Energy Code.10 However, these requirements are less rigorous than full building
commissioning, which state code requires for new construction only.
8 In particular, a climate resilience assessment (IPp1), human impact assessment (IPp2), and an embodied
carbon assessment (IPp3), are now prerequisites for all projects pursuing LEED certification.
9 The threshold for triggering the CALGreen Embodied Carbon requirements will lower to 50,000 sq ft in the
2025 code cycle, effective January 1, 2026.
10 Energy-related systems including heating, ventilation, air conditioning (HVAC) systems and controls, indoor
lighting system and controls, as well as water heating systems and controls, refer to California Energy Code
Section 120.8 for commissioning requirements and Sections 120.5, 120.6, 130.4, and 140.9(b)3 for additional
testing requirements of specific systems. CALGreen requires a written plan for testing and adjusting of
renewable energy systems, landscape irrigation systems, and water reuse systems if applicable to the project
(Section 5.410.4).
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• LEED Platinum: A new standard for LEED Platinum Certification was introduced in
LEED v5. In addition to achieving 80 or more points, projects will also need to
demonstrate compliance with additional performance benchmarks, such as zero
operational emissions, full electrification, and a comprehensive embodied carbon
analysis. Although setting LEED Platinum as an alternative compliance route is likely
to not conflict with federal law, through the evaluation, the ID360 team is not
recommending setting LEED Platinum as the alternative compliance threshold.
However, it is worth noting the significant level of effort and commitment this level of
LEED certification would reflect of a project if achieved.
• CPAU Carbon-Free: Since 2013, City of Palo Alto Utilities (CPAU) provides 100%
carbon-neutral electricity and since 2017 offers 100% carbon-neutral gas services.
CPAU is also a certified Green‑e® Energy participant as of 2023 and was the first
Green‑e Climate certified gas offset program offered by a municipal utility.11 Due to
this, projects that receive off-site renewable energy and fuels are eligible for points
under LEED’s Tier 3 Renewable Energy (EAc3) pathway. For the purposes of this
evaluation, the project team assumes the project meets these criteria.
• Regional Alignment: Jurisdictions across California—including those neighboring the
City of Palo Alto—require LEED certification or LEED equivalency for certain project
types, particularly larger commercial, institutional, and municipal developments.
There is an opportunity for Palo Alto to align with these regional standards, which
would provide a more consistent permitting experience for applicants already
pursuing LEED in nearby cities. This alignment would reduce duplication of effort,
support sustainability objectives, and reinforce Palo Alto’s commitment to high-
performance building practices. Appendix C provides a summary of LEED
requirements adopted by neighboring jurisdictions.
• Noncompliance and Noncertified Results: One risk of pursuing the LEED
Certification Compliance pathway is that a project may ultimately fail to achieve
formal LEED certification, despite choosing that route. This could lead to delays in
obtaining the final certificate of occupancy, depending on the City’s enforcement
11 CRS 2024 Green-e Verification Report. https://resource-solutions.org/g2024/ and City of Palo Alto Utilities.
https://www.paloalto.gov/Departments/Utilities/Customer-Service/About-CPAU/Carbon-Neutral-Electricity-and-
Natural-Gas/FAQs. Accessed June 25, 2025.
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mechanisms. Additionally, the project applicant may incur LEED design review and
construction fees without receiving certification. A potential way to mitigate this risk is
to adopt a model like San Francisco’s, where building permit closeout is contingent
upon obtaining the LEED certificate.
• Third-Party Review Limitations: If a project fails to achieve LEED certification and no
mitigating measures are in place, the City has no control over the outcome, as
certification is solely at the discretion of GBCI.
RECOMMENDATION
Based on the ID360 team’s analysis, the findings support allowing permit applicants to use
LEED certification as an alternative compliance pathway for CALGreen Tier 1 and Tier 2
requirements. The team recommends establishing LEED Silver as the minimum acceptable
level for this alternative, with LEED Gold as the maximum. Additionally, the team suggests
considering a tiered approach aligned with project scope—requiring LEED Silver for
CALGreen Tier 1 projects and LEED Gold for Tier 2 projects.
The CALGreen Tiers and the LEED v5 rating systems are both green building standards that
support the design and construction of high-performance buildings, but the standards differ
significantly in scope, stringency, flexibility, and intent.12 In certain areas, LEED v5 includes
more stringent and additional requirements, particularly in the areas of commissioning,
carbon tracking, equity, and climate resilience strategies. In other ways, the CALGreen Tiers
require certain prerequisites that can typically be claimed under optional credits in the
LEED rating system. A summary table of the potential options outlined below is provided in
Appendix D.
Potential Options for Palo Alto
• Option 1 – LEED Certification as a Standalone Compliance Pathway: Allow LEED
Gold Certification to serve as an alternative compliance pathway for nonresidential
projects in lieu of CALGreen Tier 1 and Tier 2 requirements, provided the project
12 See Appendix E for a comparison of CALGreen Tier prerequisite requirements against the LEED v5 BD+C
rating system and Appendix F for a comparison of CALGreen Tier prerequisite requirements against the LEED
v5 ID+C rating system. The CALGreen Tiers and LEED Overview section of this memo highlights and compares
the intent, scope, structure, and green building categories between CALGreen and LEED v5.
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complies with all CALGreen Mandatory Measures (Chapter 5) and applicable local
amendments (e.g., energy reach codes, low-carbon concrete requirements).
o Reasoning: This option streamlines the compliance process for project teams
already pursuing LEED certification by removing the additional burden of Tier
1 and Tier 2 prerequisites and electives. It leverages a well-established third-
party certification system—administered by Green Business Certification Inc.
(GBCI)—to verify sustainability outcomes, while ensuring that local baseline
standards remain enforced.
o Benefits:
§ Simplified Compliance: Removes additional CALGreen requirements
for projects already pursuing LEED Gold, reducing administrative
burden and additional design/construction considerations.
§ Third-Party Verification: Relies on GBCI’s established review process
to assess and verify sustainability performance.
§ Voluntary LEED Compliance: Discussions with City staff highlighted
that many projects that pursue LEED Certification on their own are
typically driven by owner sustainability goals, design team strategies,
and marketability of the building as LEED certified.
o Considerations:
§ Exemption from Tier Prerequisites: Projects utilizing this pathway
would not be required to meet CALGreen Tier 1 or Tier 2 prerequisite
measures.
§ Third-Party Oversight: Certification and compliance would be
determined by GBCI, outside of City control.
§ City Verification Mechanism: A system for confirming LEED
certification must be established. Options used by other jurisdictions
include:
• Temporary Certificate of Occupancy: Conditional occupancy
granted pending verification of LEED certification (e.g., San
Francisco).
• LEED AP Verification Letters: Require pre-permit and pre-
occupancy letters from a LEED Accredited Professional
confirming compliance (e.g., Mountain View).
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• Green Building Refundable Deposit: Require a deposit at
permit issuance, refunded upon verification of certification
achievement (e.g., San José).
• Option 2 – LEED Certification with CALGreen Tier Prerequisites: Allow LEED Gold
Certification to serve as an alternative compliance pathway for nonresidential
projects subject to CALGreen Tier 1 or Tier 2 requirements, with the stipulation that
all applicable CALGreen Tier prerequisite measures must still be incorporated into
the project’s design and construction.
o Reasoning: This approach maintains alignment with the City’s environmental
goals by ensuring that projects meet the baseline CALGreen mandatory
requirements and integrate the minimum sustainability measures required
under Tier 1 or Tier 2. It offers project teams greater flexibility, particularly
those already pursuing LEED certification, while preserving the integrity of the
CALGreen tiered framework.
o Benefits:
§ Consistency and Accountability: Ensures all projects meet the City’s
and CALGreen’s identified mandatory sustainability standards,
regardless of the compliance pathway.
§ Efficiency and Synergy: Many CALGreen Tier prerequisites support
specific LEED credits, creating an opportunity for streamlined
documentation and reduced duplication of effort.
§ Incentivizes High Performance: By recognizing LEED Gold as a valid
compliance route, the City can encourage broader adoption of third-
party verified green building practices.
§ Flexibility for Project Teams: Provides an alternate route for
compliance that may align better with the project’s sustainability
strategy or certification goals.
o Considerations:
§ Documentation: Documentation must clearly demonstrate that all
applicable CALGreen Tier 1 or Tier 2 prerequisites are met within the
LEED-certified project.
§ City Verification Mechanism: Project teams must submit some form of
documentation (e.g., GB-1 Sheet, compliance form) showing how
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CALGreen prerequisites are satisfied under the LEED framework and
incorporated into the design. Additionally, a system for confirming
LEED certification must be established as mentioned under Option 1
(e.g., TCO, green building deposit, verification letter).
§ Evaluation of Requirements: Periodic review of LEED equivalency
should be conducted to ensure continued alignment with evolving
CALGreen standards.
• Option 3 – Tiered LEED Standards Differentiated by Project Scope: Permit LEED
Gold Certification as an alternative compliance option for nonresidential CALGreen
Tier 2 projects involving new construction or substantial remodels. For CALGreen Tier
1 projects, City staff would determine one of the following pathways: 1) Require LEED
Silver Certification as the minimum standard; or 2) Exclude CALGreen Tier 1 projects
from the LEED alternative compliance pathway entirely.
o Reasoning: This tiered approach provides flexibility for larger-scope projects
(Tier 2) to leverage LEED Gold certification while maintaining oversight of Tier
1 projects or providing a lower threshold for smaller projects. By establishing
differentiated requirements, the City can ensure that sustainability outcomes
remain robust and consistent with the intent of the CALGreen tiers.
o Benefits:
§ Flexible Compliance for Tier 2: Supports streamlined compliance for
complex projects already pursuing LEED Gold.
§ City Control over Tier 1 Approach: Allows the City to decide whether
to permit LEED Silver as a sufficient alternative or to require full
CALGreen Tier 1 adherence in lieu of an alternative pathway.
§ Aligns Effort with Project Scope: Differentiates between the scale and
impact of Tier 1 and Tier 2 projects, applying more rigorous
certification standards to larger or more intensive developments.
o Considerations:
§ City Decision Point: City staff must select the preferred approach for
Tier 1 (LEED Silver or no alternative pathway).
§ Documentation and Verification: LEED-certified projects must still
demonstrate compliance with all applicable CALGreen Mandatory
Measures and relevant local code amendments.
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§ Enforcement Mechanism: The City should implement a verification
process to confirm that LEED certification is achieved, consistent with
practices used in other jurisdictions (e.g., deposits, third-party
confirmation, temporary occupancy permits).
§ Tier 1 Project Scopes: Under PAMC, nonresidential Tier 1 projects are
defined as alterations or tenant improvements (TIs) over 5,000 sq ft
that include the replacement of at least two systems— HVAC, building
envelope, hot water, or lighting. For smaller TIs, the limited scope may
make it difficult to meet LEED prerequisites or earn enough credits,
particularly for requirements like commissioning. The cost of LEED
registration, the design and construction review fees may deter project
teams from selecting LEED as a viable alternative.
Recommended Next Steps
If the City chooses to move forward with offering LEED Certification as an alternative
compliance pathway, the project team recommends the following next steps.
Policy Development Next Steps
1. Select preferred policy option based on City priorities, administrative capacity, and
staff feedback.
2. Present to the community and City Council to gather feedback and ensure
alignment with broader sustainability goals and priorities.
Post-Policy Adoption Next Steps
1. Choose verification mechanism(s) aligned with existing permitting processes.
2. Develop implementation timeline and staff training, community training, and GBSI
training requirements.
3. Establish periodic review process for policy effectiveness and LEED-CALGreen
alignment during each building code cycle or new cycle of the LEED Rating System.13
4. Coordinate with Planning and Building Division staff on permitting workflow
integration, procedures, and implementation of enforcement requirements.
13 The LEED program has recently moved to a five-year development cycle starting with the 2025 release of the
balloted LEED v5 rating systems. https://www.usgbc.org/leed/v5. Accessed June 23, 2025.
19
Appendix A
This page is left intentionally blank.
See next page for Appendix details.
20
Page 1
LEED ID+C® v5.0 SCORECARD
PROJECT:DATE:6/20/25 LEED for Interior Design and Construction
INTEGRATIVE PROCESS, PLANNING & ASSESSMENTS (IP)1 /1 Points Possible
Y M N PTS Prerequistie/Credit
0 0 Prerequisite
0 0 Prerequisite
0 0 Prerequisite
1 1 Credit
1 0 0 1
LOCATION AND TRANSPORTATION (LT)5 /14 Points Possible
Y M N PTS Prerequistie/Credit
4 4 8 Credit Public Transportation/Walkable Location
1 3 4 Credit
2 2 Credit EV parking shown on plans, not in scope
5 7 2 14
WATER EFFICIENCY (WE)2 /10 Points Possible
Y M N PTS
0 0 Prerequisite
1 1 2 Credit Permanent water meters/submeters
1 7 8 Credit 25% reduction fixture and fittings
2 0 8 10
ENERGY AND ATMOSPHERE (EA)3 /31 Points Possible
Y M N PTS
0 0 Prerequisite
0 0 Prerequisite Meet Title 24 Energy Code
0 0 Prerequisite Fundamental Commissioning
0 0 Prerequisite Energy Metering and Reporting
0 0 Prerequisite Fundamental Refrigerant Management
5 5 Credit Electrification
4 8 12 Credit Enhanced Energy Efficiency
2 3 5 Credit Renewable Energy
4 4 Credit Enhanced Commissioning
1 2 3 Credit Grid Interactive
2 2 Credit
3 4 24 31
MATERIALS & RESOURCES (MR)9 /26 Points Possible
Y M N PTS
0 0 Prerequisite Planning for Zero Waste Operations
0 0 Prerequisite Quantify and Assess Embodied Carbon
1 4 4 Credit Interior Materials Reuse
1 3 4 Credit Reduce Embodied Carbon
2 2 4 Credit Low-Emitting Materials
2 8 10 Credit Building Product Selection and Procurement No project specifications included
3 4 Credit Construction and Demolition Waste Diversion
9 17 0 26
INDOOR ENVIRONMENTAL QUALITY (EQ)1 /18 Points Possible
Y M N PTS
0 0 Prerequisite Construction Management
Initial project analysis by applicant
Initial project analysis by applicant
Initial project analysis by applicant
Meeting early in design
Case Study 1
Tier 1 TI
Minimum Energy Efficiency
D
D/C
D
D
D
D
D/C
D/C
Climate Resilience Assessment
Human Impact Assessment
Carbon Assessment
Integrative Design Process
Minimum Water Efficiency
Des/Con Notes
D
D/C
D
Existing building reuse, recycled content
Low emitting flooring, insulation, base code
80% diversion rate / CWM
Enhanced Refrigerant Management
Reduce harmful refrigerants
C
Requires enhanced refrigerant calcs.
Construction plan for air quality
No indication of enhanced cs efforts
D/C
D/C
D
D/C
D/C
D
C
Initial project analysis by applicant
Initial project analysis by applicant
D
Des/Con
D
D/C
CALGreen low flow and flush fixtures
D
D/C
D/C
Water Metering and Leak Detection
lighting contol system / controlled receptacles DR
Advanced lighting, HVAC
No solar PV; Carbon Free CPAU
Estimated Energy Use/Operational Carbon Projection D
D/C
D
D
Compact and Connected Development
Transportation Demand Management
Electric Vehicles
Enhanced Water Efficiency
Installed meters and reports
Initial project analysis by applicant
Meet Title 24 Energy Commissioning
Reuse of existing buildings
Mixed fuel building
21
Page 2
0 0 Prerequisite Fundamental Air Quality
0 0 Prerequisite No Smoking
1 1 2 Credit Enhanced Air Quality
1 6 7 Credit Occupant Experience
1 1 2 Credit Accessibility and Inclusion
3 3 Credit Resilient Spaces
4 4 Credit Air Quality Testing and Monitoring
1 3 14 18
PROJECT PRIORITIES & INNOVATION (PR)6 /10 Points Possible
Y M N PTS
5 4 9 Credit Project Priorities
1 1 Credit LEED AP
6 4 0 10
LEED Rating System Point Requirements
N
48 110
C
Y M
C
D/C
D
D
POSSIBLE POINTS
D 1 project team must be LEED AP w/ specialty
D
27 35
D
CALGreen equivalent
No smoking signs & policy
Mech ventilation complies w/ CEC
Possible for windows or lighting or acoustics
Complies with CBC Chp 11B ADA
No indication of testing and monitoring
D
Multiple pathways for points
LEED Certified LEED Silver LEED Gold LEED Platinum
40-49 Pts 50-59 Pts 60-79 Pts 80+ Pts
22
Page 1
LEED BD+C® v5.0 SCORECARD
PROJECT:DATE:6/27/25 LEED for Building Design + Construction
INTEGRATIVE PROCESS, PLANNING & ASSESSMENTS (IP)1 /1 Points Possible
Y M N PTS Prerequistie/Credit
0 0 Prerequisite Climate Resilience Assessment
0 0 Prerequisite Human Impact Assessment
0 0 Prerequisite Carbon Assessment
1 1 Credit Integrative Design Process Meeting early in design
1 0 0 1
LOCATION AND TRANSPORTATION (LT)5 /15 Points Possible
Y M N PTS Prerequistie/Credit
1 1 Credit Sensitive Land Protection Infill site
1 2 Credit Equitable Development
1 6 Credit Compact and Connected Development
2 2 4 Credit Transportation Demand Management Bicycle network/storage/shower
2 2 Credit Electric Vehicles 4 EVSE, 6 EV Ready
5 2 2 15
SUSTAINABLE SITES (SS)5 /11 Points Possible
Y M N PTS
0 0 Prerequisite
2 2 Credit Project restoring disturbed areas
1 1 Credit Landscape/outdoor area not 30%
2 1 3 Credit 85th percentile rainwater management
1 1 2 Credit
2 2 Credit SRI included for 2 roof products
1 1 Credit BUG ratings per Tier 2 prerequisite
5 1 5 11
WATER EFFICIENCY (WE)2 /9 Points Possible
Y M N PTS
0 0 Prerequisite
0 0 Prerequisite
1 1 Credit
2 6 8 Credit 31% indoor water use reduction; app.
2 0 7 9
ENERGY AND ATMOSPHERE (EA)9 /33 Points Possible
Y M N PTS
0 0 Prerequisite
0 0 Prerequisite Meet Title 24 Energy Code
0 0 Prerequisite
0 0 Prerequisite
0 0 Prerequisite
5 5 Credit
1 4 5 Credit Reduce Peak Thermal Loads
1 9 10 Credit
3 2 5 Credit
4 4 Credit FPT: BMS, HVAC, plumbing, electrical
2 2 Credit No DR or BAS in plans
Case Study 2
Tier 2 New Construction
D
D/C
D
D/C
D/C
Installed meters and reports
Reduce harmful refrigerants
Permanent water meter on site
Solar ready area/ CPAU Green-e Certified
Accessible Outdoor Space
Rainwater Management
Enhanced Resilient Site Design Climate/natural hazard design
Meter only, not included for all uses
CALGreen low flow and flush fixtures
D/C
D
D
D
D
Initial project analysis by applicant
Initial project analysis by applicant
Initial project analysis by applicant
All-electric building design
Meet Title 24 Energy Commissioning
Energy Recovery Ventilator (ERV)
Core and shell, all-electric building
No on-site combustion
D
D
D
D/C
D
D/C
Electrification
Enhanced Energy Efficiency
Renewable Energy
Enhanced Commissioning
Grid Interactive
D/C
D/C
D/C
D
Light Pollution Reduction
Water Metering and Reporting
Minimum Water Efficiency
Water Metering and Leak Detection
Carbon Projection and Decarbonization Plan
Minimum Energy Efficiency
Fundamental Commissioning
Energy Metering and Reporting
Fundamental Refrigerant Management
Des/Con
D
D
Erosion control/site assessmentD/C
D
Des/Con
D
D/C
D
D/C
D
Heat Island Reduction
Enhanced Water Efficiency
D
D/C
Minimize Site Disturbance
Biodiverse Habitat
23
Page 2
2 2 Credit
9 9 15 33
MATERIALS & RESOURCES (MR)5 /18 Points Possible
Y M N PTS
0 0 Prerequisite
0 0 Prerequisite
3 3 Credit
6 6 Credit
1 1 2 Credit
2 3 5 Credit Choice materials CALGreen elective
2 2 Credit 80% C&D diversion
5 3 10 18
INDOOR ENVIRONMENTAL QUALITY (EQ)0 /13 Points Possible
Y M N PTS
0 0 Prerequisite
0 0 Prerequisite
0 0 Prerequisite
1 1 Credit
7 7 Credit
1 1 Credit
2 2 Credit
2 2 Credit
0 9 4 13
PROJECT PRIORITIES & INNOVATION (PR)6 /10 Points Possible
Y M N PTS
5 4 9 Credit Project Priorities
1 1 Credit LEED Accredited Professional
6 4 0 10
LEED Rating System Point Requirements
Initial project analysis by applicant
New construction
No WBLCA, EPD, or carbon tracking
1 pt for C/S, CALGreen categories
D
Requires enhanced refrigerant calcs.
Recyclables & ZW Operations Plan
D Enhanced Refrigerant Management
D 1 project team must be LEED AP w/ specialty
C
Construction and Demolition Waste Diversion
Construction Management
Fundamental Air Quality
Planning for Zero Waste Operations
Quantify and Assess Embodied Carbon
Building and Materials Reuse
Reduce Embodied Carbon
Low-Emitting Materials
Building Product Selection and Procurement
D
D/C
C
D/C
D
D
D/C
D
No Smoking or Vehicle Idling
Enhanced Air Quality
Occupant Experience
Accessibility and Inclusion
Resilient Spaces
D/C
C
C
Multiple pathways for points
No IAQ testing indicated
Project team develop CM practices
ASHRAE 62.1, MERV 13
CALGreen tabacco requirements/ No idle
Increased outdoor air rates or IAQ limits
Project analysis by team required
Additional accessibility strategies
No operable windows or passive technique
Y M N POSSIBLE POINTS
33 28 43 110
D
Air Quality Testing and Monitoring
D
D
LEED Certified LEED Silver LEED Gold LEED Platinum
40-49 Pts 50-59 Pts 60-79 Pts 80+ Pts
24
Page 1
LEED BD+C® v5.0 SCORECARD
PROJECT:DATE:6/27/25 LEED for Building Design + Construction
INTEGRATIVE PROCESS, PLANNING & ASSESSMENTS (IP)1 /1 Points Possible
Y M N PTS Prerequistie/Credit
0 0 Prerequisite Climate Resilience Assessment
0 0 Prerequisite Human Impact Assessment
0 0 Prerequisite Carbon Assessment
1 1 Credit Integrative Design Process
1 0 0 1
LOCATION AND TRANSPORTATION (LT)8 /15 Points Possible
Y M N PTS Prerequistie/Credit
1 1 Credit Sensitive Land Protection
2 2 Credit Equitable Development
3 6 Credit Compact and Connected Development
1 3 4 Credit Transportation Demand Management
3 2 Credit Electric Vehicles
8 0 5 15
SUSTAINABLE SITES (SS)9 /11 Points Possible
Y M N PTS
0 0 Prerequisite
2 2 Credit Biodiverse Habitat
1 1 Credit Accessible Outdoor Space
2 1 3 Credit Rainwater Management
2 2 Credit Enhanced Resilient Site Design
1 1 2 Credit Heat Island Reduction
1 1 Credit Light Pollution Reduction
9 0 2 11
WATER EFFICIENCY (WE)2 /9 Points Possible
Y M N PTS
0 0 Prerequisite Water Metering and Reporting
0 0 Prerequisite Minimum Water Efficiency
1 1 Credit Water Metering and Leak Detection
1 2 8 Credit
2 2 0 9
ENERGY AND ATMOSPHERE (EA)6 /33 Points Possible
Y M N PTS
0 0 Prerequisite Carbon Projection and Decarbonization Plan
0 0 Prerequisite Minimum Energy Efficiency
0 0 Prerequisite Fundamental Commissioning
0 0 Prerequisite Energy Metering and Reporting
0 0 Prerequisite Fundamental Refrigerant Management
5 5 Credit Electrification
2 2 5 Credit Reduce Peak Thermal Loads
3 10 Credit Enhanced Energy Efficiency
3 2 5 Credit Renewable Energy
Enhanced Water Efficiency
Des/Con
D
D
Erosion control/site assessmentD/C
D
Des/Con
D
D/C
D
D/C
D/C
D
D
D/C
D
D
D
D
D
D
D/C
D
Minimize Site Disturbance
D/C
D/C
D/C
D
Indoor plumbing, irrigation systems
D/C
1 point for 30% reduction
Initial project analysis by applicant
Meet Title 24 Energy Code
Cx not requied per CALGreen/CEC
Installed meters and reports
Reduce harmful refrigerants
Project includes on site combustion.
Permanent water meter on site
CALGreen low flow and flush fixtures
ASHRAE 90.1 Building Envelope
Initial project analysis by applicant
Solar Ready only, CPAU Green-e certified
Case Study 3
Tier 2 Mixed Use
D
D/C
D
Assessment provided by applicant.
Assessment provided by applicant.
Assessment provided by applicant.
Meeting early in design
Infill site
Area with developmental challenges
Walk Score is 92
Bicycle network and storage
CPA EV requirements > LEED requirements
D
Project restoring disturbed areas
30% Open/Outdoor Space
LID - 85th percentile rainfall
Climate/natural hazard design
SRI 78 required in specs 07 54 23
Met through compliance with CALGreen
25
Page 2
4 4 Credit Enhanced Commissioning
2 2 Credit Grid Interactive
1 2 Credit Enhanced Refrigerant Management
6 7 11 33
MATERIALS & RESOURCES (MR)4 /18 Points Possible
Y M N PTS
0 0 Prerequisite Planning for Zero Waste Operations
0 0 Prerequisite Quantify and Assess Embodied Carbon
3 3 Credit Building and Materials Reuse
6 6 Credit Reduce Embodied Carbon
2 2 Credit Low-Emitting Materials
2 3 5 Credit Building Product Selection and Procurement
2 2 Credit Construction and Demolition Waste Diversion
4 2 12 18
INDOOR ENVIRONMENTAL QUALITY (EQ)3 /13 Points Possible
Y M N PTS
0 0 Prerequisite Construction Management
0 0 Prerequisite Fundamental Air Quality
0 0 Prerequisite No Smoking or Vehicle Idling
1 1 Credit Enhanced Air Quality
2 5 7 Credit Occupant Experience
1 1 Credit Accessibility and Inclusion
1 1 2 Credit
2 2 Credit
3 3 7 13
PROJECT PRIORITIES & INNOVATION (PR)6 /10 Points Possible
Y M N PTS
5 4 9 Credit Project Priorities
1 1 Credit LEED Accredited Professional
6 4 0 10
LEED Rating System Point Requirements
Resilient Spaces
D/C
D
D
Y M N POSSIBLE POINTS
39 18 37 110
D/C
C
C
D
D/C
C
D
D/C
D
D
D
C
1 project team must be LEED AP w/ specialty
Air Quality Testing and Monitoring
D
D
D
D/C
No WBLCA, EPD, or carbon tracking
D/C
No IAQ testing indicated
Project team develop CM practices
ASHRAE 62.1, MERV 13
CALGreen tabacco requirements/ No idle
Increased outdoor air rates or IAQ limits
Additional accessibility strategies
Quality Views 75%
Operable windows included
Multiple pathways for points
No Commissioning in plans
No DR or BAS in plans
Requires enhanced refrigerant calcs.
Recyclables & ZW Operations Plan
Initial project analysis by applicant
New construction
CALGreen VOC limits
Choice materials CALGreen (2022)
80% C&D diversion
LEED Certified LEED Silver
26
Appendix B
1
CALGreen Tier Prerequisite and Elective Measures by Project
The following is a list of the prerequisite and elective measures marked “Yes” (Y) on the project’s approved
GB-1 Sheet.
Case Study #1: Tenant Improvement (Tier 1)
Planning & Design
A5.105.1.1 Existing Buildings Structure (75%)
A5.105.1.2 Existing non-Structure elements (50%)
Water Efficiency & Conservation
5.303.1.2 Excess consumption (submeters for additions that consume over 1,00 gal/day)
A5.303.2.3.1 Water reduction - 12% (Table A5.303.2.3.1)
5.303.3.1 Indoor Water Use: Water closets (1.28 gpf)
5.303.2.1 Indoor Water Use: Wall mounted Urinals 0.125 gpf
5.303.3.4.1 Indoor Water Use: Nonresidential lavatory faucets (0.5 gpm at 60 psi)
5.303.4.2 Indoor Water Use: Kitchen faucets (1.8 gpm at 60 psi)
5.303.4 Commercial kitchen equipment
5.303.4.1 Food waste disposers
5.303.5 Indoor water use: areas of addition or alteration
5.303.6 Indoor water use: Standards for plumbing fixtures and fittings (2022 CA Plumbing Code)
A5.303.2.3.3 Water reduction - 25%
A5.303.3 Appliances and fixtures for commercial application
Material Conservation & Resource Efficiency
5.408.1 Construction waste management
5.408.1.1 Construction waste management plan
5.408.1.2 Waste management company
5.408.1.3 Waste stream reduction alternative
5.408.1.4 Documentation - CWM, Waste management company, waste stream reduction alternative
5.408.2 Universal Waste [AA]
5.408.3 Excavated soil and land clearing debris (100% reuse or recycle)
PAMC 16.14.410/
A5.408.3.1
Enhanced construction waste reduction (80% diversion w/ job valuation >$25,000)
5.410.1 Recycle by occupants (with exceptions)
5.410.1.1 Recycle by occupants: Additions (with exceptions)
27
Appendix B
2
5.410.4.3 Testing and adjusting: Procedures
5.410.4.3.1 Testing and adjusting: HVAC balancing
5.410.4.4 Testing, adjusting and balancing: Reporting for HVAC balancing
5.410.4.5 Operation and maintenance (O&M) Manual
5.410.4.5.1 Inspection and reports
PAMC 16.14.360/
5.410.4.6
ENERGY STAR Portfolio Manager profile setup (for projects >$100,000 in value)
PAMC 16.14.370/
5.4.10.4.7
Performance Review. - Energy (For projects over 10,000 SF)
PAMC 16.14.070 &
16.14.080/ A5.405.4
Recycled content of the total material cost: 10%
A5.405.3 Reused materials (5% of total value)
Environmental Quality
5.504.1 Temporary ventilation (MERV 8)
5.504.3 Covering of duct openings and protection of mechanical equipment during construction
5.504.4.4.1 Adhesives, sealants, caulks: Comply with VOC limits (Table 5.504.4.1 & 5.504.4.2 for VOC limits)
5.504.4.4.3 Paints and Coatings: Comply with VOC Limits (Table 5.504.4.3)
5.504.4.4.1 Carpet systems: carpet cushion
5.504.4.4.2 Carpet systems: carpet adhesive (Table 5.504.4.1 for VOC Limits)
5.504.4.5 Composite wood products: Formaldehyde limits (Table 5.504.4.5)
5.504.4.5.3 Composite wood products: Documentation
5.504.4.6.1 Verification of compliance, for resilient flooring systems
PAMC 16.16.070/
16.14.080/ A5.504.4.7
Resilient flooring system - 90%
PAMC 16.16.070 /
16.14.808 / A5.504.4.8
Thermal insulation - Tier 1 requirement
5.504.5.3 Filters: Labeling (MERV 13, with exceptions)
5.504.7 Environmental tobacco smoke (ETS) control
5.505.1 Indoor moisture control
5.506.1 Outside air delivery (For Indoor Air Quality)
5.506.2 Carbon dioxide (CO2) monitoring (For Indoor Air Quality)
PAMC 16.14.390/
5.506
Indoor Air Quality Management Plan (locally amended)
5.507.4 Acoustical control (STC Values per ASTM E90 and ASTM E413)
28
Appendix B
3
5.507.4.3 Interior sound transmission (with note)
5.508.1 Ozone depletion and greenhouse gas reductions
5.508.2 Supermarket refrigerant leak reduction
5.508.2.1 Refrigerant piping
5.508.2.2 Refrigerant piping valves
5.508.2.2.2 Refrigerant piping access valves
5.508.2.3 Refrigerated service cases
5.508.2.4 Refrigerant receivers
5.508.2.5 Pressure testing
5.508.2.6 Evacuation after pressure testing
A5.504.4.9 Entryway systems
A5.507.1.2 Lighting and thermal comfort controls: Multi-occupant spaces
A5.601.2.4 Acoustic ceiling/ Panels
Case Study #2: New Construction (Tier 2)
Planning & Design
29
Appendix B
4
A5.106.4.3 Changing rooms
A5.106.6 Parking capacity
Energy Reach Code
PAMC 16.17.080 All-electric design
PAMC 16.14.380/
5.410.4.6
Energy STAR Portfolio manager
PAMC 16.14.390/
5.410.4.7
Performance review - for projects over 10,000 SF
PAMC 16.14.400/
5.410.4.8
Performance review (For sites > 1 acre)
Water Efficiency & Conservation
5.303.1 Meters, separate submeters or metering devices
A5.303.2.3.2 Water Reduction - 20%
5.303.1 Indoor water use: Water closets (not exceed 1.28 gpf)
5.303.3.2.1 Indoor water use: Wall-mounted urinals (0.125 gpf)
5.303.3.2.2 Indoor water use: Floor-mounted urinals (0.5 gpf)
5.303.3.3.1 Indoor water use: Single showerhead (1.8 gpm at 80 psi)
5.303.3.4.1 Indoor water use: Nonresidential lavatory faucets (0.5 gpm at 60 psi)
5.303.3.4.2 Indoor water use: kitchen faucets (1.8 gpm at 60 psi)
5.303.3.4.4 Indoor water use: Metering faucets (0.2 gallons/cycle)
5.303.6 Indoor water use: standards for plumbing fixtures and fittings
5.304.1 Outdoor potable water use in landscape areas (MWELO)
PAMC 16.12.030 Recycled water supply systems
PAMC 16.14.360/
5.304.2
Invasive species prohibited
A5.303.2.3.3 Indoor water use: 25% reduction
A5.304.6 Outdoor water use: Restoration of areas disturbed by construction
A5.305.2 Irrigation system: Recycled water
Material Conservation & Resource Efficiency
A5.405.4 Recycled content: 15%
5.407.1 Weather protection
5.407.2.1 Moisture control: sprinklers
5.407.2.2 Moisture control: Entries + Openings
30
Appendix B
5
5.407.2.2.1 Moisture control: Exterior door protection
5.407.2.2.2 Moisture control: Flashing
5.408.1 Construction waste management
5.408.1.1 Construction waste management plan
5.408.1.2 Waste management company
5.408.1.4 Documentation: Construction WMP, waste management company, waste stream reduction alternative
5.408.3 Excavated soil and land clearing debris (100% reuse or recycle)
PAMC 16.14.370/
A5.408.3.1.1
Enhanced construction waste reduction (80% diversion)
5.410.1 Recycling by occupants
5.410.2 Commissioning (≥ 10,000 SF)
5.410.2.3 Commissioning plan
5.410.2.4 Functional Performance Testing
5.410.2.5.1 Documentation and Training: Systems manual
5.410.2.5.2 Documentation and Training: Systems operations training
5.410.2.6 Commissioning Report
5.410.4 Testing and adjusting for [N] buildings < 10,000 SF or new systems serving addition or alterations
5.410.4.2 Testing and adjusting for systems: renewable energy, landscape irrigation, water reuse
5.410.4.3 Testing and adjusting procedures
5.410.4.3.1 Testing and adjusting: HVAC balancing
5.410.4.4 Testing, adjusting, and balancing: Reporting for HVAC balancing
5.410.4.5 Operation and maintenance (O&M) manual
PAMC 16.14.400/
5.410.4.8
Performance reviews. - water (sites > 1 acre)
5.410.4.5.1 Inspection and reports [AA} + [N] < 10,000 SF
A5.405.2.1 Bio-based materials: certified wood
A5.406.1.1 Choice of materials: Service life
A5.406.1.2 Choice of materials: Reduced maintenance
A5.406.1.3 Choice of materials: Recyclability
Environmental Quality
5.504.1 Temporary ventilation (MERV 8)
31
Appendix B
6
5.504.3 Covering of duct openings and protection of mechanical equipment during construction
5.504.4.1 Adhesives, sealants and caulks: Comply with VOC Limits (Table 5.504.4.1 and 5.504.4.2 for VOC limits)
5.504.4.3 Paints and coatings: comply with VOC limits (Table 5.504.4.3)
5.504.4.3.1 Aerosol paints and coatings
5.504.4.3.2 Verification for paints and coatings
5.504.4.5 Composite wood products: Formaldehyde limits (Table 5.504.4.5)
5.504.4.5.3 Composite wood products: Documentation
PAMC 16.14.070/
A5.504.4.7.1
Resilient Flooring system, 100%
A5.504.4.8.1 Thermal insulation: No added formaldehyde
5.504.7 Environmental tobacco smoke (ETS) control
5.506.1 Outside air delivery (For Indoor Air Quality)
PAMC 16.14.410 Indoor Air Quality Management Plan
5.507.4 Acoustical control (STC Values per ASTM E90 and ASTM E413)
5.507.4.1 Exterior noise transmission, prescriptive method (with exceptions)
5.507.4.1.1 Noise exposure where noise contours are not readily available
5.507.4.2 Exterior noise transmission, performance method
5.507.4.2.1 Site features
5.507.4.2.2 Documentation of compliance
5.507.4.3 Interior sound transmission (with note)
5.508.1 Ozone depletion and greenhouse gas reductions
5.508.1.1 Chlorofluorocarbons (CFCs)
5.508.1.2 Halons
A5.504.1.2 Indoor Air Quality during construction: Additional IAQ measures
A5.504.5.1 Entryway systems (to control pollutants)
A5.504.5.2 Isolation of pollutant sources (to control pollutants)
A5.508.1.3 Hydro-chlorofluorocarbons (HCFCs) (for HVAC and refrigeration equipment)
32
Appendix B
7
Case Study #3: Mixed Use New Construction (Tier 2)
Planning & Design
PAMC 16.14.290/
5.106.1
Stormwater pollution prevention for projects that disturb < 1 acre of land
PAMC 16.14.290/
5.106.1.1
Local storm water pollution prevention
5.106.1.2 Best management practices (BMP's)
PAMC 18.54.060/
5.106.4
Bicycle parking for additions or change of use that results in increased parking
PAMC 18.54.060/
5.106.4.1.1
Short term bicycle parking (exception for additions or alterations which add nine or less visitor
vehicular parking spaces)
PAMC 18.54.060/
5.106.4.1.2
Long term bicycle parking
PAMC
16.14.295/5.106.8
Light pollution reduction
5.106.10 Grading and paving (exception for additions and alterations not altering the drainage path)
PAMC 16.16.070 &
16.14.080/ A5.106.11.2
Cool roof for reduction of heat island effect
A5.103.1 Community connectivity
A5.106.3 Low impact development (LID)
A5.106.6 Parking capacity
Energy Reach Code
PAMC 16.17.050 Mixed-fuel design 10%
PAMC 16.14.3980/
5.410.4.6
Energy STAR Portfolio Manager
Water Efficiency & Conservation
5.303.1 Meters, separate submeters or metering devices installed as follows:
5.303.1.1 New buildings or additions in excess of 50,000 square feet
5.303.1.2 Excess consumption (Submeters for additions that consume over 1,000 gal/ day)
A5.303.2.3.2 Indoor Water Use Reduction- 20% savings over the "water use baseline" Table A5.303.2.3.1
5.303.3.1 Indoor Water Use: Water closets (shall not exceed 1.28 gallons per flush)
5.303.3.2.1 Indoor Water Use: Wall-mounted urinals (0.125gpf)
5.303.3.2.2 Indoor Water Use: Floor-mounted urinals (0.5 gpf)
5.303.3.3.1 Indoor Water Use: Single showerhead (1.8 gpm at 80 psi)
5.303.3.3.2 Indoor Water Use: Multiple showerheads serving one shower (flow rate of 1.8 gpm at 80 psi)
5.303.3.4.1 Indoor Water Use: Nonresidential lavatory faucets (0.5 gpm at 60 psi)
5.303.3.4.2 Indoor Water Use: Kitchen faucets (1.8 gpm at 60 psi)
33
Appendix B
8
5.303.3.4.3 Indoor Water Use: Wash fountains (1.8 gpm at 60 psi)
5.303.3.4.4 Indoor Water Use: Metering faucets (0.2 gallons/ cycle)
5.303.3.4.5 Indoor Water Use: Metering faucets for wash fountains (0.2 gallons/ cycle)
5.303.4 Commercial kitchen equipment
5.303.4.1 Food waste disposers
5.303.5 Indoor water use: Areas of addition or alteration [AA]
PAMC 16.12.035 Dual plumbing (locally amended)
5.303.6 Indoor Water Use: Standards for plumbing fixtures and fittings (2022 California Plumbing Code)
5.304.1 Outdoor potable water use in landscape areas (MWELO)
PAMC 16.12.030 Recycled water supply systems
PAMC 16.14.330
Section 5.304.2
Invasive species prohibited
PAMC 16.14.340
Section 5.306
Non-residential enhanced water budget required when use > 1,000 gal/day
PAMC 16.14.350
Section 5.307
Cooling Tower Water Use (locally amended)
A5.303.2.3.3 Indoor water use: 25% reduction
A5.303.2.3.4 Nonpotable water systems for indoor water use
A5.303.3 Appliances and fixtures for commercial application
A5.303.4.1 Nonwater supplied urinals
A5.304.6 Outdoor Water Use: Restoration of areas disturbed by construction
A5.304.7 Outdoor Water Use: Previously developed sites: restore or protect 50 % of site area
A5.304.8 Outdoor Water Use: Graywater irrigation system
A5.305.1 Nonpotable water systems
A5.305.2 Irrigation system: Recycled water
Material Conservation & Resource Efficiency
A5.405.4 Recycled content: 15% of materials based on estimated total cost or use two products from Table
A5.405.4 for at least 75% by cost
5.407.1 Weather protection
5.407.2.1 Moisture control: Sprinklers
5.407.2.2 Moisture control: Entries + Openings
5.407.2.2.1 Moisture control: Exterior door protection
34
Appendix B
9
5.407.2.2.2 Moisture control: Flashing
5.408.1 Construction waste management
5.408.1.1 Construction waste management plan
5.408.1.2 Waste management company
5.408.1.3 Waste stream reduction alternative
5.408.1.4 Documentation: Construction waste management plan, waste management company, waste stream
reduction alternative
5.408.2 Universal Waste [AA]
5.408.3 Excavated soil and land clearing debris (100% reuse or recycle)
5.409.2 Whole building life cycle assessment
5.409.3 Product GWP compliance—prescriptive path
PAMC 16.14.430/
A5.408.3.1.1
Enhanced construction waste reduction
(80% Diversion w/ job valuation >$25,000, less than $25,000 must meet state standards of 65%)
5.410.1 Recycling by occupants (with exceptions)
5.410.2 Commissioning (≥ 10,000 SF) [N]
5.410.2.3 Commissioning plan [N]
5.410.2.4 Functional performance testing [N]
PAMC 16.14.360 /
5.410.4.6
ENERGY STAR Portfolio Manager profile setup (for projects exceeding $100,000 in value)
PAMC 16.14.370 /
5.410.4.7
Performance Review- For projects over 10,000 SF
PAMC 16.14.380/
5.410.4.8
Performance Review (For sites > 1 acre)
5.410.2.5.1 Documentation and Training: Systems manual
5.410.2.5.2 Documentation and Training: Systems operations training [N]
5.410.2.6 Commissioning report [N]
5.410.4 Testing and adjusting for new buildings < 10,000 SF or new systems that serve additions or
alterations [N] [AA]
5.410.4.2 Testing and adjusting for systems: Renewable energy, landscape irrigation, and water reuse
5.410.4.3 Testing and adjusting: Procedures
5.410.4.3.1 Testing and adjusting: HVAC balancing
5.410.4.4 Testing, adjusting and balancing: Reporting for HVAC balancing
5.410.4.5 Operation and maintenance (O&M) manual
PAMC 16.14.380/ Sect
5.410.4.8
Performance reviews- Water (sites > 1 acre)
35
Appendix B
10
5.410.4.5.1 Inspection and reports (new buildings / additions and alterations < 10,000 SF) [AA] + [N]
A5.404.1.1 Wood Framing: Structural or fire-resistance integrity
A5.404.1.2 Wood Framing: Framing specifications
A5.406.1.3 Choice of materials: Recyclability
Environmental Quality
5.504.1 Temporary ventilation (MERV 8)
5.504.3 Covering of duct openings and protection of mechanical equipment during construction
5.504.4.1 Adhesives, sealants and caulks: Comply with VOC limits (Table 5.504.4.1 and 5.504.4.2 for VOC limits)
5.504.4.3 Paints and Coatings: Comply with VOC Limits (Table 5.504.4.3)
5.504.4.3.1 Aerosol paints and coatings
5.504.4.3.2 Verification, for paints and coatings
PAMC 16.16.070 &
16.14.080/ A5.504.4.8.1
Thermal Insulation: No added formaldehyde
5.504.5.3 Filters: Labelling (MERV 13, with exceptions)
5.504.7 Environmental tobacco smoke (ETS) control
5.506.2 Carbon dioxide (CO2) monitoring (For Indoor Air Quality)
PAMC 16.14.390 Indoor Air Quality Management Plan
5.507.4 Acoustical control (STC Values per ASTM E90 and ASTM E413)
5.507.4.2 Exterior noise transmission, performance method
5.507.4.3 Interior sound transmission (with note)
A5.504.1.1 Indoor air quality (IAQ) during constructions: Temporary ventilation
A5.504.1.2 Indoor air quality (IAQ) during constructions: Additional IAQ measures
A5.507.3.1 Views: Direct line of sign to outdoors: interior office spaces
36
Appendix C
1
LEED Certification Requirements by California Jurisdiction
Jurisdiction Trigger
Belmont • Residential alteration projects adding less than 400 SF with a construction valuation of 0 to
$50,000: One Build It Green (BIG) Green Building Practice from the Existing Home Checklist
• Residential alteration projects adding less than 400 SF with a construction valuation of
$50,001.00 to $99,999: Three BIG Green Building Practices from the Existing Home Checklist
• Residential alteration projects adding less than 400 SF with a construction valuation of
$100,000.00: 25 BIG points Elements or 50 BIG points Whole House
• New residences and residential alteration projects adding 400 SF or greater: 70 BIG points
Whole House
• Tenant improvement or new construction commercial projects 10,000 SF or greater: LEED
Silver Certification
Cupertino • New SF and MF (greater than 9 homes): GPR Certified at min. 50 points or LEED Silver or
Alternate Reference Standard
• NR Mid-size (25,000-50,000 SF): LEED Certified or Alternate Reference Standard
• NR Large (> 50,000 SF): LEED Silver or Alternate Reference Standard
• MF Renovations/Additions (w/ FAR increase 50% and at least 35,000 SF and replace or
substantially alter the HVAC system and at least two systems - building envelope, hot water
system, and lighting system): GPR min. 50 pts, LEED Certified or LEED EBOM Certified, or
Alternative Reference Standard
• NR Renovations/Additions (35,000 SF or more and replace or substantially alter the HVAC
system and two systems - building envelope, hot water system, and lighting system): LEED
Certified (applicable only to the area of renovation/addition), LEED EBOM Certified, or
Alternative Reference Standard
Menlo Park • LEED: Project applicants will have the option to select whether they wish to pursue LEED
certification or demonstrate LEED -equivalent performance through the LEED performance
program (LPP).
• New NR 10,000 sq. ft.—25,000 sq. ft: Designed to meet LEED Silver BD+C
• New NR 25,001 sq. ft.—100,000 sq. ft.: Designed to meet LEED Silver BD+C
• New NR 100,001 sq. ft. and above: Designed to meet LEED Gold BD+C1
• NR Additions/Alterations 10,000 sq. ft.—25,000 sq. ft. of conditioned area, volume or size:
Designed to meet LEED Silver ID+C1 or update core and shell of entire building to current
California Energy Code and meet Section 16.43.140 (Local GB and Energy Standards)
• NR Additions/Alterations 25,001 sq. ft. and above of conditioned area, volume or size:
Designed to meet LEED Gold ID+C1 or update core and shell of entire building to current
California Energy Code2 and meet Section 16.43.140 (Local GB and Energy Standards)
Mountain
View
• The MVGBC does not require formal certification from a third-party organization. Instead,
projects will be required to be designed and constructed to “meet the intent” of a third-party
rating system.
• New Multi-Family 3 Units +: Meet the intent of LEED Gold
• New Mixed Use: Meet the Intent of LEED Gold
• New Hotel: Meet the Intent of LEED Gold
• New Commercial: Meet the Intent of LEED Gold
37
Appendix C
2
LEED Certification Requirements by California Jurisdiction
Jurisdiction Trigger
San
Francisco
• New Large Commercial ≥ 25,000 SF: LEED v4 Gold
• New Res All Sizes: GreenPoint Rated or LEED v4 Silver
• Major Res Alterations ≥ 25,000 SF AND significant structural upgrade AND mechanical,
electrical, or plumbing: GreenPoint Rated or LEED v4 Silver
• Large First-Time Commercial Interiors ≥ 25,000 SF: LEED v4 Gold
• Major Nonres Alterations ≥ 25,000 SF: LEED v4 Gold
• Municipal New Construction, Additions/Alterations ≥10,000 square feet, including
leasehold improvements: LEED v4 Gold
San José • Municipal projects 10,000 SF or more: LEED Gold certification
• Large commercial industrial building or a large residential project or high-rise MF: Green
building refundable deposit.
• Municipal buildings 15,000 SF or more and Privately-owned Residential or Nonresidential
Buildings 20,000 SF or more: Energy and Water Building Performance Ordinance.
Commercial/Industrial - Tier 1 < 25,000 square feet: LEED Applicable NC Checklist
Commercial/Industrial - Tier 2 ≥ 25,000 square feet: LEED Silver
• Residential < 10 units Tier 1: GreenPoint or LEED Checklist
• Residential ≥ 10 units Tier 2: GreenPoint Rated 50 points or LEED Certified
• High Rise Residential (75' or higher): LEED Certified
Saratoga • Public buildings 5,000 SF or more: LEED Silver and City maintains LEED AP list
Foster City • LEED Silver for individual projects (Gilead Sciences, Pilgrim Triton Master Plan and
Chess/Hatch Offices)
Sunnyvale • Bonus and Max FAR for Nonresidential Development: LEED BD+C Platinum and whole
building life cycle assessment
• New NR and Initial TIs > 5,000 sq. ft. 30,000 sq. ft. CALGreen Mandatory Measures and LEED
Gold Level with verification by a LEED AP
• New NR and Initial TIs > 30,000 sq. ft. CALGreen Mandatory Measures and LEED Gold Level
with USGBC Certification, including Design Phase Credits reviewed and approved by USGBC:
• All Major Alterations CALGreen Mandatory Measures and LEED Silver with verification by a
LEED AP
• New Public Facility ≤ 5,000 sq. ft.: CALGreen Mandatory Measures as applicable to the
scope of work. Reviewed by City staff.
• New Public Facility > 5,000 sq. ft.: CALGreen Mandatory Measures and LEED Gold Level with
verification by a LEED AP --
• All Major Alterations: CALGreen Mandatory Measures and LEED Silver with verification by a
LEED AP
38
Appendix D
LEED Certification Alternative Compliance Policy Options Summary Table
Policy Option Scope LEED Level CALGreen Requirements Key Benefits Implementation Considerations
Option 1:
Standalone
LEED
Pathway
Allow LEED Gold
Certification as a
complete alternative
to CALGreen Tier 1
and Tier 2
requirements. Projects
still must comply with
CALGreen Mandatory
and local PAMC code
amendments.
LEED Gold
Certification
• Mandatory Measures
(Chapter 5)
• Local amendments
• Tier prerequisites/electives
do not apply
• Simplified compliance for
LEED projects
• Third-party verification via
GBCI
• Reduced administrative
burden
• Industry alignment
• Third-party oversight outside
City control
• Requires City verification
mechanism
• No Tier prerequisite
compliance
Option 2:
LEED + Tier
Prerequisites
Allow LEED Gold
Certification as an
alternative pathway
only if all CALGreen
Tier 1 or Tier 2
prerequisite measures
are still incorporated
into the project design
and construction.
LEED Gold
Certification
• Mandatory Measures
(Chapter 5)
• Local amendments
• All applicable Tier 1 or
Tier 2 prerequisites apply
• Maintains CALGreen
baseline standards
• Leverages LEED -
CALGreen synergies
• Preserves City
environmental goals
• Flexible compliance
pathway
• Requires documentation of
Tier prerequisite compliance
• More complex verification
process
• Need for periodic LEED -
CALGreen alignment review
Option 3:
Differentiate
by Project
Scope
Allow LEED Gold
Certification as an
alternative only for
Tier 2 projects. For Tier
1, the City selects one
of the following: 1)
Require LEED Silver, or
2) Exclude from LEED
option.
Tier 2:
LEED Gold
Tier 1:
LEED Silver
OR no
alternative
pathway
• Mandatory Measures
(Chapter 5)
• Local amendments
• Tier requirements as
applicable and
determined by City staff
• Tailored approach by
project complexity
• City control over Tier 1
pathway
• Aligns certification level
with project scope
• Requires City decision on Tier
1 approach
• Differentiated enforcement
mechanisms
• More complex policy
framework
39
Appendix E
This page is left intentionally blank.
See next page for Appendix details.
40
CALGreen / LEED BD+C v5 Comparison: Nonresidential Projects
CALGreen/ PAMC Requirement LEED Equivalent Analysis
• Designated parking for clean air
vehicles - 35% (CALGreen A5.106.5.1.1)
No LEED BD+C equivalent prerequisite. LEED credit Electric Vehicles (LTc5) requires that 5% of all parking spaces (or
min. 2) for 1 pt or 10% (or min. 4) for 2 pts have electric vehicle supply
equipment (EVSE) installed. Alternatively, nonres projects can install 10% EV
Readiness (or min. 10 spaces) for 1pt. LEED does not enhance this PAMC
requirement. Projects would be subject to local amendments and Tier 1
requirements.
• Cool roof for reduction of heat island
effect - Tier 1 standards (CALGreen
A5.106.11.2)
No LEED eBD+C equivalent prerequisite. LEED credit Heat Island Reduction (SSc5) includes Option 1 Nonroof and Roof
strategies, Option 2 100% Parking under cover, Option 3: Tree Equity. For roof
areas, CALGreen Tier 1 requires an aged SRI value of 75 for low-sloped
roofs (≤ 2:12), and 16 for steep-sloped roofs (> 2:12), and LEED requires an
aged SRI value of 64 for low-sloped roofs (≤ 2:12), and 32 for steep-sloped
roofs (> 2:12).
Tier 1 Water
Prerequisites
• Indoor water use reduction - 12%
(CALGreen A5.303.2.3.1)
LEED BD+C equivalent prerequisite. LEED prerequisite (WEp2) requires minimum efficiency for indoor and
outdoor water use, prescriptive and performance pathways are available.
Performance path requires 20% indoor water use reduction and no irrigation
for outdoor water use or 30% reduction from the baseline.
CALGreen: Tier 1 only requires 12% reduction in indoor water use. CALGreen
sets maximum prescriptive flow rates for kitchen faucets, wash fountains,
metering faucets and metering faucets for wash fountains. Further, CALGreen
Tier 2 and LEED requires 20% indoor water use reduction on all applicable
water use fixtures compared to base case water consumption calculations as
a prerequisite. CALGreen is more stringent than LEED at a fixture level in
some cases, but LEED is a performance based calculation and projects could
meet or exceed the reduction rates of CALGreen prescriptive rates.
• Recycled content: 10% of materials
(CALGreen A5.405.4)
No LEED BD+C equivalent prerequisite. CALGreen Tier 1 requires projects to use materials, equivalent in
performance to virgin materials with a total (combined) recycled content
value (RCV) of 10% by cost.
LEED does not have a requirement for installing products or using building
materials with recycled content. Recycled content can be a strategy used for
the Quantify and Assess Embodied Carbon (MRp2) and Building Product
Selection and Procurement (MRc4).
• Enhanced construction waste
reduction - 80% (PAMC
16.14.410/CALGreen A5.408.3.1)
No LEED BD+C equivalent prerequisite. LEED credit Construction and Demolition Waste Diversion (MRc5) requires
C&D Materials Management Plan and awards points based on diversion
achieved: 1 pt for 50% diversion and at least 10% of diverted materials must
be salvaged or source-separated or 2pts for 75% diversion and at least 25%
salvaged or source-separated. Projects would be subject to locally amended
C&D diversion rate.
• Resilient flooring system - 90%
(CALGreen A5.504.4.7)
No LEED BD+C equivalent prerequisite. LEED credit Low-Emitting Materials (MRc3) focuses on VOC limits for materials
on the building interior (flooring is part of the Path 1 product categories).
LEED does not enhance this PAMC requirement. Projects would be subject to
local amendments.
• Thermal insulation - no added
formaldehyde (CALGreen A5.504.4.8)
No LEED BD+C equivalent prerequisite. CALGreen requires projects to use composite wood products approved by
the California Air Resources Board (ARB) with no-added formaldehyde (NAF)
based resins or ultra-low emitting formaldehyde (ULEF) resins.
LEED credit Low-Emitting Materials (MRc3) includes insulation as an option to
choose under Path 2. LEED does not enhance this PAMC requirement.
Projects would be subject to local amendments.
CALGreen/ PAMC Requirement LEED Equivalent Analysis
• Designated parking for clean air
vehicles - 50% (CALGreen A5.106.5.1.1)
No LEED BD+C equivalent prerequisite. LEED credit Electric Vehicles (LTc5) requires that 5% of all parking spaces (or
min. 2) for 1 pt or 10% (or min. 4) for 2 pts have electric vehicle supply
equipment (EVSE) installed. Alternatively, nonres projects can install 10% EV
Readiness (or min. 10 spaces) for 1pt. LEED does not enhance this PAMC
requirement. Projects would be subject to local amendments and Tier 1
requirements.
Tier 2 Site
Prerequisites
Note: The following table includes PAMC locally amended provisions from the 2022 code cycle based on 2025 express terms. Similar to Tier 1 and Tier 2 projects, any project
pursuing LEED certification need to comply with all state and local building requirements.1, 2, 3
Tier 1 CALGreen/ PAMC Requirements
Tier 1 Site
Prerequisites
Tier 1
Material
Prerequisites
Tier 1
Environmental
Quality
Prerequisites
Tier 2 CALGreen/ PAMC Requirements
41
CALGreen / LEED BD+C v5 Comparison: Nonresidential Projects
Note: The following table includes PAMC locally amended provisions from the 2022 code cycle based on 2025 express terms. Similar to Tier 1 and Tier 2 projects, any project
pursuing LEED certification need to comply with all state and local building requirements.1, 2, 3
Tier 1 CALGreen/ PAMC Requirements• EV Charing Infrastructure
º parking areas 10-20 spaces - 20%
EVSE or 20% EV Capable or EVSE Ready
º parking areas ≥ 20 spaces - 15%
EVSE and 15% EV Capable or EVSE
Ready (PAMC 16.14.400/ CALGreen
A4.106.5.3)
No LEED BD+C equivalent prerequisite. LEED credit Electric Vehicles (LTc5) requires that 5% of all parking spaces (or
min. 2) for 1 pt or 10% (or min. 4) for 2 pts have electric vehicle supply
equipment (EVSE) installed. Alternatively, nonres projects can install 10% EV
Readiness (or min. 10 spaces) for 1pt. PAMC currently requires 20% EV
Capable or EV Ready, 20% EVSE Installed (10-20 parking spaces) and 15% EV
Capable or EV Ready and 15% EVSE Installed (over 20 parking spaces).
CALGreen requires 10% for existing when electrical/lighting or panel
upgrade is included in scope, PV added, or alterations trigger CALGreen.
LEED does not enhance this PAMC requirement. Projects would be subject to
local amendments.
• Cool roof for reduction of heat island
effect Tier 2 standards (CALGreen
A5.106.11.2)
No LEED BD+C equivalent prerequisite. LEED credit Heat Island Reduction (SSc5) includes Option 1 Nonroof and Roof
strategies, Option 2 100% Parking under cover, Option 3: Tree Equity. For roof
areas, CALGreen Tier 2 requires an aged SRI value of 82 for low-sloped
roofs (≤ 2:12), and 27 for steep-sloped roofs (> 2:12) and LEED requires an
aged SRI value of 64 for low-sloped roofs (≤ 2:12), and 32 for steep-sloped
roofs (> 2:12).
Tier 2 Water
Prerequisites
• Indoor water use reductions - 20%
(CALGreen A5.303.2.3.1)
LEED BD+C equivalent prerequisite. LEED prerequisite (WEp2) requires minimum efficiency for indoor and
outdoor water use, prescriptive and performance pathways are available.
Performance path requires 20% indoor water use reduction and no irrigation
for outdoor water use or 30% reduction from the baseline.
CALGreen: 20% reduction required for Tier 2. CALGreen sets maximum
prescriptive flow rates for kitchen faucets, wash fountains, metering faucets
and metering faucets for wash fountains. Further, CALGreen and LEED
require 20% water use reduction on all applicable water use fixtures
compared to base case water consumption calculations. CALGreen is more
stringent than LEED at a fixture level in some cases, but LEED is a
performance based calculation and projects could meet or exceed the
reduction rates of CALGreen prescriptive rates.
• Recycled content: 15% of materials
(CALGreen A5.405.4)
No LEED BD+C equivalent prerequisite. CALGreen Tier 2 requires projects to use materials, equivalent in
performance to virgin materials with a total (combined) recycled content
value (RCV) of 15% by cost.
LEED does not have a requirement for installing products or using building
materials with recycled content. Recycled content can be a strategy used for
the Quantify and Assess Embodied Carbon (MRp2) and Building Product
Selection and Procurement (MRc4).
• Enhanced construction waste
reduction - 80% (PAMC
16.14.410/CALGreen A5.408.3.1)
No equivalent LEED BD+C prerequisite. LEED credit Construction and Demolition Waste Diversion (MRc5) requires
C&D Materials Management Plan and awards points based on diversion
achieved: 1 pt for 50% diversion and at least 10% of diverted materials must
be salvaged or source-separated or 2pts for 75% diversion and at least 25%
salvaged or source-separated. Projects would be subject to locally amended
C&D diversion rate.
• Resilient flooring system - 100%
(CALGreen A5.504.4.7)
No LEED equivalent BD+C prerequisite. LEED credit Low-Emitting Materials (MRc3) focuses on VOC limits for materials
on the building interior (flooring is part of the Path 1 product categories).
LEED does not enhance this PAMC requirement. Projects would be subject to
local amendments.
• Thermal insulation - no added
formaldehyde (CALGreen A5.504.4.8)
No LEED equivalent BD+C prerequisite. CALGreen requires projects to use composite wood products approved by
the California Air Resources Board (ARB) with no-added formaldehyde (NAF)
based resins or ultra-low emitting formaldehyde (ULEF) resins.
LEED credit Low-Emitting Materials (MRc3) includes insulation as an option to
choose under Path 2. LEED does not enhance this PAMC requirement.
Projects would be subject to local amendments.
1 Projects that pursue LEED Certification would still be subject to CALGreen Mandatory requirements (Chapter 4 for residential and Chapter 5 for nonresidential), as well as any applicable locally
amended building requirements in PAMC 16.14 (CALGreen) and PAMC 16.17 (Energy Code).
3 LEED v5 BD+C includes the following prerequisites: IPp1 Climate Resilience Assessment, IPp2 Human Impact Assessment, IPp3 Carbon Assessment, IPp4 Tenant Guidelines (C&S), SSp1 Minimized
Site Disturbance, WEp1 Water Metering and Reporting, WEp2 Minimum Water Efficiency, EAp1 Operational Carbon Projection and Decarbonization Plan, EAp2 Minimum Energy Efficiency, EAp3
Fundamental Commissioning, EAp4 Energy Metering and Reporting, EAp5 Fundamental Refrigerant Management, MRp1 Planning for Zero Waste Operations, MRp2 Quantify and Assess Embodied
Carbon, EQp1 Construction Management, EQp2 Fundamental Air Quality, EQp3 No Smoking or Vehicle Idling.
Tier 2 Site
Prerequisites
Tier 2
Material
Prerequisites
2 CALGreen Divisions A4.6 and A5.6 outline the Tier 1/Tier 2 prerequisites a project must meet to achieve CALGreen tier status. In addition the divisions specify the number of electives from each
CALGreen Division Category a project must choose. PAMC does not require Tier 1 and Tier 2 projects to comply with the CALGreen Energy Efficiency Tier requirements due to the local Energy Reach
Code requirements.
Tier 2
Environmental
Quality
Prerequisites
42
Appendix F
This page is left intentionally blank.
See next page for Appendix details.
43
CALGreen / LEED ID+C v5 Comparison: Nonresidential Projects
CALGreen/ PAMC Requirement LEED Equivalent Analysis
• Designated parking for clean air
vehicles - 35% (CALGreen A5.106.5.1.1)
No LEED ID+C equivalent prerequisite. LEED credit Electric Vehicles (LTc3) requires that 5% of all parking spaces (or
min. 2) for 1 pt or 10% (or min. 4) for 2 pts have electric vehicle supply
equipment (EVSE) installed. LEED does not enhance this PAMC requirement.
Projects would be subject to local amendments and Tier 1 requirements.
• Cool roof for reduction of heat island
effect - Tier 1 standards (CALGreen
A5.106.11.2)
No LEED ID+C equivalent prerequisite. There is no LEED v5 ID+C cool roof requirement.
Tier 1 Water
Prerequisites
• Indoor water use reduction - 12%
(CALGreen A5.303.2.3.1)
LEED ID+C equivalent prerequisite. LEED prerequisite (WEp2) requires minimum efficiency for indoor and
outdoor water use, prescriptive and performance pathways are available.
Performance path requires 20% indoor water use reduction and newly
installed appliances must meet additional water use requirements.
CALGreen: Tier 1 only requires 12% reduction in indoor water use. CALGreen
sets maximum prescriptive flow rates for kitchen faucets, wash fountains,
metering faucets and metering faucets for wash fountains. Further,
CALGreen Tier 2 and LEED requires 20% indoor water use reduction on all
applicable water use fixtures compared to base case water consumption
calculations as a prerequisite. CALGreen is more stringent than LEED at a
fixture level in some cases, but LEED is a performance based calculation and
projects could meet or exceed the reduction rates of CALGreen prescriptive
rates.
• Recycled content: 10% of materials
(CALGreen A5.405.4)
No LEED ID+C equivalent prerequisite. CALGreen Tier 1 requires projects to use materials, equivalent in
performance to virgin materials with a total (combined) recycled content
value (RCV) of 10% by cost.
LEED does not have a requirement for installing products or using building
materials with recycled content. Recycled content can be a strategy used for
the Quantify and Assess Embodied Carbon (MRp2) and Building Product
Selection and Procurement (MRc4).
• Enhanced construction waste
reduction - 80% (PAMC
16.14.410/CALGreen A5.408.3.1)
No LEED ID+C equivalent prerequisite. LEED credit Construction and Demolition Waste Diversion (MRc5) requires
C&D Materials Management Plan and awards points based on diversion
achieved: 1 pt for 35% diversion and at least 10% of diverted materials must
be salvaged or source-separated, 2 points for 50% diversion and at least
20% of diverted materials must be salvaged or source-separated, 3 points
for 65% diversion and at least 30% of diverted materials must be salvaged or
source-separated.
Additionally, 1 point may be achieved if the project exceeds 10% of all
salvaged or source separated and recycled clean gypsum, carpet, ceiling
and furniture.
Projects would be subject to locally amended C&D diversion rate.
• Resilient flooring system - 90%
(CALGreen A5.504.4.7)
No LEED ID+C equivalent prerequisite. LEED credit Low-Emitting Materials (MRc3) focuses on VOC limits for
materials on the building interior (flooring is part of the Path 1 product
categories). LEED does not enhance this PAMC requirement. Projects would
be subject to local amendments.
• Thermal insulation - no added
formaldehyde (CALGreen A5.504.4.8)
No LEED ID+C equivalent prerequisite. CALGreen requires projects to use composite wood products approved by
the California Air Resources Board (ARB) with no-added formaldehyde (NAF)
based resins or ultra-low emitting formaldehyde (ULEF) resins.
LEED credit Low-Emitting Materials (MRc3) includes insulation as an option to
choose. LEED does not enhance this PAMC requirement. Projects would be
subject to local amendments.
CALGreen/ PAMC Requirement LEED Equivalent Analysis
• Designated parking for clean air
vehicles - 50% (CALGreen A5.106.5.1.1)
No LEED ID+C equivalent prerequisite. LEED credit Electric Vehicles (LTc3) requires that 5% of all parking spaces (or
min. 2) for 1 pt or 10% (or min. 4) for 2 pts have electric vehicle supply
equipment (EVSE) installed. LEED does not enhance this PAMC requirement.
Projects would be subject to local amendments and Tier 1 requirements.
Tier 2 Site
Prerequisites
Note: The following table includes PAMC locally amended provisions from the 2022 code cycle based on 2025 express terms. Similar to Tier 1 and Tier 2 projects, any project
pursuing LEED certification need to comply with all state and local building requirements.1, 2, 3
Tier 1 CALGreen/ PAMC Requirements
Tier 1 Site
Prerequisites
Tier 1 Material
Prerequisites
Tier 1
Environmental
Quality
Prerequisites
Tier 2 CALGreen/ PAMC Requirements
44
CALGreen / LEED ID+C v5 Comparison: Nonresidential Projects
Note: The following table includes PAMC locally amended provisions from the 2022 code cycle based on 2025 express terms. Similar to Tier 1 and Tier 2 projects, any project
pursuing LEED certification need to comply with all state and local building requirements.1, 2, 3
Tier 1 CALGreen/ PAMC Requirements• EV Charing Infrastructure
º parking areas 10-20 spaces - 20%
EVSE or 20% EV Capable or EVSE Ready
º parking areas ≥ 20 spaces - 15%
EVSE and 15% EV Capable or EVSE
Ready (PAMC 16.14.400/ CALGreen
A4.106.5.3)
No LEED ID+C equivalent prerequisite. LEED credit Electric Vehicles (LTc5) requires that 5% of all parking spaces (or
min. 2) for 1 pt or 10% (or min. 4) for 2 pts have electric vehicle supply
equipment (EVSE) installed. PAMC currently requires 20% EV Capable or EV
Ready, 20% EVSE Installed (10-20 parking spaces) and 15% EV Capable or EV
Ready and 15% EVSE Installed (over 20 parking spaces). CALGreen requires
10% for existing when electrical/lighting or panel upgrade is included in
scope, PV added, or alterations trigger CALGreen.
LEED does not enhance this PAMC requirement. Projects would be subject to
local amendments.
• Cool roof for reduction of heat island
effect Tier 2 standards (CALGreen
A5.106.11.2)
No LEED ID+C equivalent prerequisite. There is no LEED v5 ID+C cool roof requirement.
Tier 2 Water
Prerequisites
• Indoor water use reductions - 20%
(CALGreen A5.303.2.3.1)
LEED ID+C equivalent prerequisite. LEED prerequisite (WEp2) requires minimum efficiency for indoor and
outdoor water use, prescriptive and performance pathways are available.
Performance path requires 20% indoor water use reduction and and newly
installed appliances must meet additional water use requirements.
CALGreen: 20% reduction required for Tier 2. CALGreen sets maximum
prescriptive flow rates for kitchen faucets, wash fountains, metering faucets
and metering faucets for wash fountains. Further, CALGreen and LEED
require 20% water use reduction on all applicable water use fixtures
compared to base case water consumption calculations. CALGreen is more
stringent than LEED at a fixture level in some cases, but LEED is a
performance based calculation and projects could meet or exceed the
reduction rates of CALGreen prescriptive rates.
• Recycled content: 15% of materials
(CALGreen A5.405.4)
No LEED ID+C equivalent prerequisite. CALGreen Tier 2 requires projects to use materials, equivalent in
performance to virgin materials with a total (combined) recycled content
value (RCV) of 15% by cost.
LEED does not have a requirement for installing products or using building
materials with recycled content. Recycled content can be a strategy used for
the Quantify and Assess Embodied Carbon (MRp2) and Building Product
Selection and Procurement (MRc4).
• Enhanced construction waste
reduction - 80% (PAMC
16.14.410/CALGreen A5.408.3.1)
No equivalent LEED ID+C prerequisite. LEED credit Construction and Demolition Waste Diversion (MRc5) requires
C&D Materials Management Plan and awards points based on diversion
achieved: 1 pt for 35% diversion and at least 10% of diverted materials must
be salvaged or source-separated, 2 points for 50% diversion and at least
20% of diverted materials must be salvaged or source-separated, 3 points
for 65% diversion and at least 30% of diverted materials must be salvaged or
source-separated.
Additionally, 1 point may be achieved if the project exceeds 10% of all
salvaged or source separated and recycled clean gypsum, carpet, ceiling
and furniture.
Projects would be subject to locally amended C&D diversion rate.
• Resilient flooring system - 100%
(CALGreen A5.504.4.7)
No LEED ID+C equivalent prerequisite. LEED credit Low-Emitting Materials (MRc3) focuses on VOC limits for
materials on the building interior (flooring is part of the Path 1 product
categories). LEED does not enhance this PAMC requirement. Projects would
be subject to local amendments.
• Thermal insulation - no added
formaldehyde (CALGreen A5.504.4.8)
No LEED ID+C equivalent prerequisite. CALGreen requires projects to use composite wood products approved by
the California Air Resources Board (ARB) with no-added formaldehyde (NAF)
based resins or ultra-low emitting formaldehyde (ULEF) resins.
LEED credit Low-Emitting Materials (MRc3) includes insulation as an option to
choose under Path 2. LEED does not enhance this PAMC requirement.
Projects would be subject to local amendments.
1 Projects that pursue LEED Certification would still be subject to CALGreen Mandatory requirements (Chapter 4 for residential and Chapter 5 for nonresidential), as well as any applicable locally
amended building requirements in PAMC 16.14 (CALGreen) and PAMC 16.17 (Energy Code).
3 LEED v5 ID+C includes the following prerequisites: IPp1 Climate Resilience Assessment, IPp2 Human Impact Assessment, IPp3 Carbon Assessment, WEp1 Minimum Water Efficiency, EAp1 Estimated
Energy Use and Operational Carbon Projection, EAp2 Minimum Energy Efficiency, EAp3 Fundamental Commissioning, EAp4 Energy Metering and Reporting, EAp5 Fundamental Refrigerant
Management, MRp1 Planning for Zero Waste Operations, MRp2 Quantify and Assess Embodied Carbon, EQp1 Construction Management, EQp2 Fundamental Air Quality, EQp3 No Smoking.
Tier 2 Site
Prerequisites
Tier 2 Material
Prerequisites
2 CALGreen Divisions A4.6 and A5.6 outline the Tier 1/Tier 2 prerequisites a project must meet to achieve CALGreen tier status. In addition the divisions specify the number of electives from each
CALGreen Division Category a project must choose. PAMC does not require Tier 1 and Tier 2 projects to comply with the CALGreen Energy Efficiency Tier requirements due to the local Energy Reach
Code requirements.
Tier 2
Environmental
Quality
Prerequisites
45
OCTOBER 6, 2025 PaloAlto.gov
Local Amendments to the 2025 Building Standards Code
George Hoyt, Chief Building Official
Tim Scott, Resource Planner
Building Standards Code Update Process
California updates its Building Standards Code every
three years.
•Current 2022 code update took effect January 1, 2023
•2025 code update will take effect January 1, 2026
Local jurisdictions may adopt local amendments to
the 2025 California Building Standards Code once
the state code is published.
•Must be more restrictive/stringent than the state code
•Must make express findings that each amendment is
reasonably necessary due to local geological,
topographical, climatic or environmental conditions
2
Legislative Updates
AB 130 (formerly AB 306) passed on June 30, 2025
Includes language that limits the ability of
jurisdictions to adopt new residential local
amendments to California Building Standards Code
from Oct 1, 2025 through 2031
Code adoption timeline was modified this year to
pass new residential local amendment ahead of
October 1, 2025.
3
Code Adoption Timeline
•September 8, 2025: City Council approved select
new residential proposals for immediate adoption
•Proposals have been submitted to CEC for review
•October 6, 2025 (tonight): City Council to consider new non-
residential proposals for adoption and prior local
amendments for re-adoption
•November 3, 2025: City Council to consider potential local
amendments to the California Fire Code on consent
•Spring 2026: City Council to consider energy reach codes for
multi-family and non-residential projects (delayed to align
with availability of cost effectiveness studies)
4
California Building Standards Codes New Local
Amendments
Renewed Local
Amendments
Council Consideration, Discussion & Action
Part 1: CA Administrative Code No No N/A
Part 2: CA Building Code Yes Yes October 2025
Part 2.5: CA Residential Code No Yes October 2025
Part 3: CA Electrical Code No Yes October 2025
Part 4: CA Mechanical Code No Yes October 2025
Part 5: CA Plumbing Code Yes Yes October 2025
Part 6: CA Energy Code Yes Yes September & October 2025 (& Spring 2026)
Part 7: Wildland-Urban Interface Code No N/A November 2025
Part 8: CA State Historical Building Code No Yes October 2025
Part 9: CA Fire Code Yes Yes November 2025
Part 10: CA Existing Building Code No Yes October 2025
Part 11: CA Green Building Standards Code Yes Yes October 2025
Part 12: CA Reference Code Standards No No N/A
International Swimming Pool & Spa Code No Yes October 2025
Summary of Local Code Amendments
5
New local
amendments
are proposed
to 5 of the
13 parts of
the CA
Building
Standards
Code.
New Local Amendments to
Energy and Green Building
Standards Code (CALGreen)
6
Green Building and Energy Amendment Timeline
paloalto.gov/GreenBuildingCodeRequirements 7
Adoption Date Local Code Amendments
Green Building Reach Code Energy Reach Code
September 2025
•None •Air Conditioner Time of
Replacement
•FlexPath
October 2025
•Carry forward previous local Green Building
Code amendments (including CALGreen
Tier 1 & 2 adoption)
•LEED Certification Alternative Compliance
Pathway
•Embodied Carbon Threshold
•EV Readiness
•Carry forward previous local Energy
Code amendments, as supported by
cost effectiveness studies
Spring 2026
•None •Potential additional Energy Code
amendments as supported by newly
available cost effectiveness studies
and model code language. e.g., Gas
Water Heater Time of Replacement,
Source Energy Compliance Margin
•Adopted by Palo Alto in October 2024 as
part of the “One Margin” effort after the all-
electric new construction requirements
were reversed
•Requires new construction to meet stricter
source energy compliance margins that
exceed the state requirement levels
•Must be supported by cost-effectiveness
studies, which are not expected to be
published until late 2025 or early 2026
•Staff will propose new source energy
requirements after the new cost-
effectiveness studies are completed in 2026
Source Energy Compliance Requirement
paloalto.gov/GreenBuildingCodeRequirements 8
Picture
LEED Certification Compliance Pathway
paloalto.gov/GreenBuildingCodeRequirements
Proposal: Allow LEED certification as an
alternative to CALGreen Tier 1 and Tier 2
standards for non-residential buildings.
Objective: Simplify code compliance for
projects interested in pursuing LEED
certification and align codes more closely
with other local jurisdictions.
State Code: CALGreen Mandatory
requirements.
Existing Local Amendment: Enforce
CALGreen Tier 1 and Tier 2 requirements
for qualifying remodel/addition projects
and new construction.
9
CALGreen
Tier 2
CALGreen
Tier 1
LEED Certification Compliance Pathway - Cont.
paloalto.gov/GreenBuildingCodeRequirements
Details:
•LEED Silver certification as an alternative
compliance pathway for Tier 1 projects
•LEED Gold certification as an alternative
compliance pathway for Tier 2 projects
•Projects must still comply with a couple
key Tier 1/2 prerequisites
•EV charging infrastructure
•Construction & demolition waste
10
CALGreen
Tier 2
CALGreen
Tier 1
LEED Certification Compliance Pathway - Cont.
paloalto.gov/GreenBuildingCodeRequirements 11
Changes in Prerequisites: LEED vs. CALGreen Tier 1 and Tier 2
CALGreen Tier
Prerequisites
•Designated parking for clean air vehicles
•Cool roof requirements to reduce the heat island
effect
•Minimum recycled content in building materials
•Enhanced construction waste reduction
•VOC limits for resilient flooring systems
•Formaldehyde limits for thermal insulation
•Electric vehicle charging infrastructure requirements
LEED
Prerequisites1
•Climate Resilience Assessment
•Human Impact Assessment
•Carbon Assessment
•Operational Carbon Projection and Decarbonization
Plan
•Fundamental Commissioning
•Planning for Zero Waste Operations
•Quantify and Assess Embodied Carbon
1 This table shows select key LEED prerequisites met by using LEED as an alternative
compliance path.
* Certain mandatory CALGreen
(e.g. enhanced C&D waste diversion, EV Charging).
CALGreen
Tier 2
CALGreen
Tier 1
Proposal: Lower the threshold for
embodied carbon compliance to 25,000 sf.
Objective: Promote GHG emissions
reduction in more Palo Alto construction.
State Code: 2025 CALGreen drops the
embodied carbon compliance threshold
from nonresidential buildings from
100,000 sf to 50,000 sf.
Existing Local Amendment: No change
beyond 2022 state code.
Embodied Carbon
paloalto.gov/GreenBuildingCodeRequirements 12
Picture
Proposal: Replace the existing nonresidential local code
with the CALGreen Tier 2 requirements calculated using
either the standard methodology (Table A5.106.5.3.3 Tier 2)
or the Power Allocation Method (Table A5.106.5.3.4 Tier 2)
Objective: Simplify code compliance and promote GHG
emissions reduction through EV charger availability.
State Code: Comply with charger infrastructure
requirements using either the standard methodology
(Table 5.106.5.3.1) or the Power Allocation Method (Table
5.106.5.3.6)
Existing Local Amendment:
•10 to 20 parking spaces: 20% EV Capable Spaces AND
20% Level 2 EV Chargers Installed
•Over 20 parking spaces: 15% EV Capable Spaces AND
15% EV Chargers Installed
Nonresidential EV Readiness
paloalto.gov/GreenBuildingCodeRequirements 13
Picture
All Other New Local
Amendments
Limited New Local Amendments
In addition to the Energy and CALGreen codes, the
City is only proposing new local amendments to the
California Building, Plumbing and Fire Codes.
Staff recommends the City readopt prior local
amendments, as applicable, for all other parts of the
code.
Prior local amendments that have been incorporated
into the model code have been removed and
applicable references updated.
15
California Building and Plumbing Codes
California Building Code: New local amendments to
identify triggers for automatic sprinkler systems and
require more intense fire sprinkler design for
different types of new and existing nonresidential
buildings
California Plumbing Code: New local amendments
to update requirements for the management of fats,
oils, and grease as outlined in PAMC Chapter 16.13.
16
California Fire Code
New local amendments to the fire code will be reviewed by Council in
November on consent and may include:
•Administrative updates to definitions and code standards
•Fire apparatus access: turning radius, security gates, and minimum widths
(county recommendations)
•Address identification requirements
•Regulations related to enclosed garages, including requiring a Knox Box
•Revised sprinkler requirements for trash enclosures
•Sprinkler requirements for indoor energy storage systems
•Smoke alarm maintenance and replacement requirements
•Regulations related to the number of energy storage systems in enclosed areas
•Fire flow requirements during construction
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Staff Recommendation
Staff recommends that the City Council:
1.Adopt the ordinances in Attachments A through H that amend
chapters of the Palo Alto Municipal Code (PAMC) related to the 2025
California Building Standards Codes (Cal. Code of Regulations Title 24)
and proposed local amendments; and
2.Direct staff to return to Council on the Consent Calendar with
ordinances adopting the 2025 editions of the California Wildlands-
Urban Interface Code and California Fire Code and local amendments
thereto; and
3.Approve an amendment to the Fiscal Year 2026 Budget appropriation
in the General Fund (requires a 2/3 majority vote) by:
a. Increasing the Planning and Development Services expenditure
appropriation by $96,000; and
b. Decreasing the Budget Stabilization Reserve by $96,000.
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George Hoyt
Chief Building Official
Planning & Development Services
George.Hoyt@paloalto.gov
Tim Scott
Resource Planner
Utilities
Timothy.Scott@paloalto.gov