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Staff to propose reach-code changes; committee hears risks from pending state bill and schedule delays
Summary
City staff proposed carry-forward and new reach-code measures for the 2026–28 cycle, including LEED as an alternative compliance path and time-of-replacement requirements for some HVAC and water-heater swaps.
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City staff presented a draft strategy for Palo Alto’s 2026–28 reach-code cycle, recommending continued use of the state’s Tier 1/Tier 2 green-building framework, a potential alternative compliance path through LEED certification for some projects, and new “time-of-replacement” standards that would require heat-pump or equivalent upgrades when certain equipment is replaced.
Tim Scott, resource planning in the utilities department, told the committee the staff recommendation would keep the city’s green-building tier structure while adding options to lower embodied-carbon thresholds and to allow LEED as an alternative compliance path. Scott said the proposed schedule aims to adopt green-building reach codes for the January 1, 2026 code cycle and to phase in multifamily and nonresidential energy updates on July 1, 2026 if the needed cost-effectiveness studies are completed.
The proposal included three energy-code pathways: time-of-replacement, time-of-renovation and an energy-performance standard for new construction based on hourly source-energy metrics (the “hourly source energy” approach used in previous local work). Scott flagged practical barriers for time-of-replacement mandates, including unpermitted equipment changes and potential confusion if local requirements are not aligned with regional air-district rules.
Public commenters supported time-of-replacement standards. Dashiell Leeds of the Sierra Club’s Loma Prieta chapter told the committee she supported “time-of-replacement standards for air conditioners and gas water heaters,” saying the city is well positioned to pursue AC-to-heat-pump policies because it operates a municipal utility with low-carbon electricity.
At the same time, speakers warned that state legislation could affect the city’s authority to adopt local reach codes. A public commenter, Steven Arnn, flagged AB306, which he said would limit local zoning and building-code changes; staff and committee members said the city had sent an opposed letter and will track the bill closely.
Why it matters: Reach codes set local requirements that can accelerate electrification and reduce building-sector emissions. The committee must weigh timing, legal risk and the results of upcoming cost-effectiveness studies when deciding which provisions to adopt in the next code cycle.
Timelines and next steps Staff proposed finalizing green-building and single-family energy proposals in June, extensive outreach through summer, a committee recommendation in August and a council adoption in October with an effective date of January 1, 2026 for green-building measures. Multifamily and nonresidential energy-code updates were proposed for a later effective date (July 1, 2026) because state cost-effectiveness studies that inform those updates will be delayed.
Officials also identified specific regulatory coordination points: the Bay Area Air Quality Management District’s NOx appliance rules and statewide cost-effectiveness studies that inform local energy standards. The city’s building official (George Hoyt) noted that low-carbon concrete provisions are already part of the local green-building code (Palo Alto Municipal Code sections cited by staff) and staff said they will return with more detail on embodied-carbon thresholds.
Ending: Committee members asked staff to return with draft language, impact analyses and outreach plans, and to monitor AB306 and other state bills closely before finalizing local amendments.

