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Palo Alto committee recommends emergency reach-code amendments including AC-to-heat-pump replacement rule

September 06, 2025 | Palo Alto, Santa Clara County, California


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Palo Alto committee recommends emergency reach-code amendments including AC-to-heat-pump replacement rule
The Climate Action and Sustainability Committee recommended that the City Council adopt emergency local amendments to the city energy code on Sept. 5, 2025, including a provision that when air conditioners are replaced homeowners must either install a heat pump or implement specified efficiency measures; staff said the AC-to-heat-pump requirement would take effect Jan. 1, 2027 if approved.

Committee staff said the package also includes a FlexPath compliance option for remodels larger than 1,000 square feet that requires projects to achieve 12 points by choosing measures from a flexible list of energy-efficiency and electrification options. Tim Scott, resource planner, said the 12-point target is intended to provide clear, cost-effective routes that can make all‑electric pathways viable for remodel projects.

Why it matters: Staff and committee members framed the amendments as a near-term step to increase residential electrification and reduce greenhouse gas emissions while responding to a state law, AB 130, that narrows some local reach-code authority beginning Oct. 1. Staff accelerated the residential pieces so the city can present them before the statutory deadline.

Key details
- Staff recommended the committee recommend Council adoption of the residential amendments at the Sept. 8 City Council meeting; nonresidential and additional green building amendments will follow on a later October timeline.
- Brad Eggleston, director of public works, announced a separate but related staff initiative: new permit-fee rebates to reduce the cost barrier for residential heat-pump water heaters and heat-pump HVAC projects. Eggleston said staff is planning to add these permit rebates to the city rebate hub and launch them around Oct. 2 to coordinate with state incentive timing.
- Permit-fee rebate amounts staff cited: about $328 for instant permits and about $638 for standard permits; tech-clean state incentives cited for comparison range from roughly $1,100–$1,800 for heat-pump water heaters and $1,000–$1,500 for heat-pump HVAC systems.
- Staff presented a compliance exemption pathway tied to the city’s General Plan and existing greenhouse-gas reduction strategy; deputy city attorney Maddie (identified in the meeting as McMadeline’s Law, deputy city attorney) explained staff’s view that an exemption in the state law could allow local amendments that incentivize all‑electric construction while permitting mixed‑fuel construction consistent with the General Plan.

Questions and concerns raised
- Committee members and attendees pressed staff for clarification on multiple points: whether the required heat pump must be sized to serve primary heating for the home, how the rule treats installations where an existing AC does not serve the whole home, and exemptions when a heat pump heating system is already installed. Scott said the requirement is that a replacement heat pump be sized to serve as the home’s primary heating source, and staff explained there is an exemption when installing a heat pump would require a system more than about one ton larger than the existing system.
- Public commenters asked staff to add a specific exemption for homes that already use a combination heat-pump system for water heating and space heating so they could add AC without being required to resize to serve whole-home heating. Staff said that configuration had not been on their radar and that they expect to evaluate and, if needed, adopt additional exceptions in the period between adoption and the rule’s effective date.
- Several speakers asked about FlexPath point values and whether staff could adjust points to more strongly incentivize heat pumps; staff said point values are drawn from the cost-effectiveness study and changing them would require an additional study.

Committee action and next steps
- The committee voted to recommend Council adoption of the emergency ordinance with the local amendments reviewed in the staff report. The motion passed on a voice/roll-call vote; committee members recorded as voting in the affirmative during the roll call included Council member Lee and Vice Mayor Banquert (motion carried). Staff will present the recommendation verbally at the Sept. 8 City Council meeting and, if Council approves, staff will submit the local amendments to the California Energy Commission and the California Green Building Standards Commission for state review.

Context and implementation
- Staff said the CEC/CBSC review typically takes about two months. Staff indicated the AC-to-heat-pump requirement would be effective on 01/01/2027 and that some other requirements would be effective 01/01/2026 if approved by the state agencies.
- Staff will continue outreach and additional cost-effectiveness work on items not ready for the accelerated timeline (for example, gas water‑heater time‑of‑replacement and updates to new‑construction source‑energy compliance margins), which staff projected could be complete in spring 2026.

Ending: The committee’s recommendation moves the city one step closer to local reach-code changes intended to accelerate building electrification; Council action is required next for the measures to proceed to state review and final effect.

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