HomeMy WebLinkAboutCED Triennial Building Code Ordinance Amendments____________________________________________________________________________________
FOR CITY CLERK ONLY
Council Meeting: 09/02/2025
Disposition: Introduced the Ordinance, waived further reading, refered to it by title only, and set the
public hearing for Monday, September 15, 2025
Agenda Item No: 6.b
Meeting Date: September 2, 2025
SAN RAFAEL CITY COUNCIL AGENDA REPORT
Department: Community Development
Prepared by: Don Jeppson, AIA CBO
Chief Building Official
Cory Bytof
Sustainability Program Manager
City Manager Approval: ______________
TOPIC: TRIENNIAL BUILDING CODE ORDINANCE AMENDMENTS
SUBJECT: INTRODUCTION OF AN ORDINANCE AMENDING TITLE 12 (BUILDING
REGULATIONS) OF THE MUNICIPAL CODE OF THE CITY OF SAN RAFAEL, BY
REPEALING TITLE 12 AND AMENDING TITLE 12 THEREOF; ADOPTING THE 2025
EDITION OF THE CALIFORNIA BUILDING CODE, THE CALIFORNIA RESIDENTIAL
CODE, THE CALIFORNIA MECHANICAL CODE, THE CALIFORNIA PLUMBING
CODE, THE CALIFORNIA ELECTRICAL CODE, THE CALIFORNIA EXISTING
BUILDING CODE, THE CALIFORNIA GREEN BUILDING STANDARDS CODE, THE
CALIFORNIA ENERGY CODE, AND THE CALIFORNIA REFERENCED STANDARDS
CODE WITH APPENDICES AND AMENDMENTS HEREIN; ADOPTING THE 2024
EDITION OF THE INTERNATIONAL PROPERTY MAINTENANCE CODE AND THE
INTERNATIONAL POOL AND SPA CODE WITH AMENDMENTS; AMENDING
CHAPTER 12.360 SINGLE-FAMILY MODEL REACH CODE – FLEXPATH; HEREIN;
AND ADOPTING FINDINGS OF FACT SUPPORTING THE AMENDMENTS TO THE
CODE
RECOMMENDATION:
Staff recommend that the City Council introduce the Ordinance, waive further reading, refer to it by title
only, and set a public hearing for Monday, September 15, 2025.
BACKGROUND:
The State of California Code of Regulations Title 24 construction codes are typically updated and
published on a three-year cycle. The California Building Standards Commission publishes the triennial
codes, and State law mandates that these codes become effective throughout California 180 days after
the publication date. For this latest cycle, the publication date was July 1, 2025, meaning that the current
cycle of State construction codes becomes effective on January 1, 2026. This fosters uniformity in fire
prevention, life/safety, and construction standards statewide. Local jurisdictions are permitted to amend
the published codes based on and to suit local climatic, geological, or topographical conditions.
The proposed ordinance adopts the latest version of California Title 24 construction codes. Specifically,
this includes the 2025 California Building Code, 2025 California Residential Code, the 2025 California
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 2
Mechanical Code, the 2025 California Plumbing Code, the 2025 California Electrical Code, the 2024
International Property Maintenance Code, the 2024 International Pool and Spa Code, the 2025 California
Existing Building Code, the 2025 California Green Building Standards Code, and the California
Referenced Standard Code with appendices and local amendments. State law mandates that these
codes become effective statewide on January 1, 2026, with or without the incorporation of local
jurisdiction amendments. Building permit applications filed with the City before January 1, 2026, would
be subject to the currently adopted codes and City ordinance.
The purpose of the codes is to establish the minimum requirements to safeguard the public health, safety,
and general welfare through requirements for structural strength, means of egress, access to persons
with disabilities, sanitation, adequate lighting and ventilation, and energy conservation; and to provide
safety to firefighters and emergency responders during emergency operations. Below is a summary of
each of these codes:
2025 California Building Code: The provisions of this code shall apply to the construction, alteration,
movement, enlargement, replacement, repair, equipment, use and occupancy, location,
maintenance, removal, and demolition of every building or structure or any appurtenances connected
or attached to such buildings or structures.
2025 California Residential Code: The provisions of this code shall apply to the construction,
alteration, movement, enlargement, replacement, repair, equipment, use and occupancy, location,
removal and demolition of detached one- and two-family dwellings and townhouses not more than
three stories above-grade in height with a separate means of egress and their accessory structures
not more than three stories above the grade plane in height.
2025 California Mechanical Code: The provisions of this code shall apply to the installation,
alteration, repair, and replacement of mechanical systems, including equipment, appliances, fixtures,
fittings, and appurtenances, including ventilating, heating, cooling, air conditioning , and refrigeration
systems, incinerators, and other energy-related systems.
2025 California Plumbing Code: The provisions of this code shall apply to the installation, alteration,
repair, and replacement of plumbing systems, including equipment, appliances, fixtures, fittings, and
appurtenances, where connected to a water or sewage system, gas system, and all aspects of
medical gas systems.
2025 California Electrical Code: The provisions of this code shall apply to the installation and
removal of electrical conductors, equipment, and raceways; signaling and communications
conductors, equipment, and raceways; and optical fiber cables and raceways to public and private
properties, including yards, lots, parking lots, buildings, structures, mobile homes, recreational
vehicles, and floating buildings.
2024 International Property Maintenance Code: The provision of this code shall apply to all existing
residential and nonresidential structures and all existing premises and constitute minimum
requirements and standards for premises, structures, equipment and facilities for light, ventilation,
space, heating, sanitation, protection from the elements, life safety, safety from fire and other hazards,
and for safe and sanitary maintenance; the responsibility of owners, operators and occupants; the
occupancy of existing structures and premises, and for administration, enforcement and penalties.
2024 International Pool and Spa Code: The provisions of this code shall apply to the construction,
alteration, movement, renovation, replacement, repair, and maintenance of aquatic recreation
facilities, pools, and spas. The pools and spas covered by this code are either permanent or
temporary and shall be only those that are designed and manufactured to be connected to a
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 3
circulation system and that are intended for swimming, bathing, or wading. The purpose of this code
is to establish minimum standards to provide a reasonable level of safety and protection of life, health,
property, and public welfare by regulating and controlling the design, construction, installation, quality
of materials, location, and maintenance or use of pools and spas.
2025 California Existing Building Code: The provisions of this code provide flexibility to permit the
use of alternative approaches to achieve compliance with minimum requirements to safeguard the
public health, safety, and welfare insofar as they are affected by the repair, alteration, change of
occupancy, addition, and relocation of existing buildings. This code shall apply to the repair, alteration,
change of occupancy, addition, and relocation of all existing buildings, regardless of occupancy.
2025 California Historical Building Code: The provisions of this code provide regulations for the
preservation, restoration, rehabilitation, relocation, or reconstruction of buildings or properties
designated as qualified historical buildings or properties. The intent is to facilitate and provide cost-
effective solutions for the preservation and continuing use of historical buildings or properties, while
providing reasonable safety for building occupants and access for persons with disabilities.
2025 California Energy Code: The provisions of this code shall set minimum efficiency requirements
for new and renovated buildings, assuring reductions in energy use and emissions over the life of the
building.
2025 California Green Building Standards Code: The provisions of this code improve public health,
safety, and general welfare by enhancing the design and construction of buildings through the use of
building concepts having a reduced negative impact or positive environmental impact and
encouraging sustainable construction practices.
2025 California Referenced Standard Code: The provisions of this code provide construction
standards.
Update: A version of this item was originally presented to the City Council on August 18, 2025. Instead
of having a second reading at the September 2nd City Council meeting, we must revisit the item because,
on the morning after its initial adoption on August 19th, staff were notified by the California Energy
Commission (CEC) that they could not approve the ordinance as written. They are supportive of
increasing the Target Scores for the FlexPath Reach Code until January 1, 2027, but stated that the
January 1, 2029, increase could not be approved at this time since it would have to be an amendment to
the 2028 State Code, which is not available yet. The Ordinance amendment under consideration at this
September 2nd Council meeting reflects the direction from the CEC, including a new requirement that the
State Codes Team develop jurisdiction-specific cost-effectiveness memos and have them referenced in
any proposed Ordinances. This memo, specific to San Rafael, is provided as Attachment 2 to this report.
The public hearing on the proposed ordinance will be held at the next regularly scheduled meeting of the
City Council on September 15, 2025, a procedure required because the ordinance adopts various
adopted State codes by reference, with appropriate local amendments, per Government Code Sections
50022.1 through 50022.10. The City Council last adopted the State codes on November 21, 2022, and
the most recent Reach Code on May 20, 2024.
ANALYSIS:
Assembly Bill (AB) 130, adopted in June 2025, prohibits cities from adopting local amendments to the
residential code unless certain exceptions are met, including fire safety and home hardening. One of the
exceptions allows local amendments if they are “substantially equivalent” to codes in effect September
30, 2025. Another allows local amendments if the amendments are necessary to implement an
amendment adopted to align with a general plan adopted or approved on or before June 10, 2025, and
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 4
that permits mixed-fuel residential construction consistent with federal law while also incentivizing all -
electric construction as part of an adopted greenhouse gas emissions reduction strategy. Staff believe
these exceptions would apply to the City of San Rafael since the City Council adopted the initial FlexPath
Reach Code on May 20, 2024, and since San Rafael maintains a qualified greenhouse gas emissions
reduction strategy and has conforming policies in the General Plan 2040. These exceptions are reflected
in the Findings in Attachment 1.
Many of the proposed local amendments, including Reach Codes, are carried over from previously
adopted codes and have been adjusted for reference changes or format changes in the new codes. New
amendments include a definition for “kitchen” and increasing the width of stair landings when a fire riser
is present. Other amendments pertaining to fire safety, such as the International Pool and Spa Code and
the International Property Maintenance Code, are included as well . Previously adopted electric vehicle
(EV) amendments have been removed because the State Code has been improved to a similar standard.
An amendment to the Single-Family Model Reach Code – FlexPath is included as well, to proactively
amend the target scores upward, which was the intention when the Code was adopted in 2024. Due to
AB 130, this amendment allows the City to proceed with the original plan using a future implementation
date, while meeting the September 30, 2025, effective date of the exceptions in AB 130. Target scores
will increase for each building vintage (year of construction) as shown in Table 12.360 A-1 on page 11 of
the Ordinance in Attachment 1. However, further increases for 2029 have not been included in the
ordinance due to a recent ruling by the California Energy Commission disallowing code amendments in
future triennial code cycles. Should data and feedback from the building community not support these
new target scores, they would not need to be implemented at the discretion of the Chief Building Official.
These amendments are all supported by the 2022 Cost-Effectiveness Study: Single Family Building
Upgrades and subsequent memos commissioned by the California Statewide Energy Codes and
Standards program. These are reflected in the Findings in Attachment 1 and the data in Attachments 2
and 3.
The proposed ordinance adopts the California Green Building Standards and incorporates them into the
City’s local building code. This is consistent with the action taken by the Council at the last code adoption
hearings in 2013, 2017, 2019, and 2022. Staff may recommend adopting additional non-residential Reach
Codes for the City Council in the future.
FISCAL IMPACT:
There is no fiscal impact associated with this action.
ENVIRONMENTAL REVIEW:
It has been determined that the proposed ordinance amendments are covered by the ‘general rule’ that
the California Environmental Quality Act (CEQA) applies only to projects that have the potential to cause
a significant, physical environmental impact. Under CEQA Section 15061(b)(3), the ordinance
amendments are not subject to environmental review.
OPTIONS:
The City Council has the following options to consider on this matter:
1. Introduce the Ordinance and set the public hearing for adoption as proposed.
2. Introduce the Ordinance with amendments as directed by the Council at the meeting and set the
public hearing for adoption.
3. Postpone the introduction of the Ordinance to allow amendments to be incorporated into the
Ordinance. Should the City Council decide to postpone adoption of the Ordinance, the State
codes will become effective on January 1, 2026, without the benefit of the recommended local
amendments.
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 5
RECOMMENDED ACTION:
Staff recommend that the City Council introduce the Ordinance, waive further reading, refer to it by title
only, and set a public hearing for Monday, September 15, 2025.
ATTACHMENT:
1. Draft Ordinance: Title 12, 2025 Building Codes
2. Cost-Effectiveness Results Summary - San Rafael
3. 2022 to 2025 FlexPath Memo
4896-5923-3369 v2 1
ORDINANCE NO. ____
AN ORDINANCE OF THE SAN RAFAEL CITY COUNCIL AMENDING TITLE 12 (BUILDING
REGULATIONS) OF THE MUNICIPAL CODE OF THE CITY OF SAN RAFAEL, BY
REPEALING TITLE 12 AND AMENDING TITLE 12 THEREOF; ADOPTING THE 2025 EDITION
OF THE CALIFORNIA BUILDING CODE, THE CALIFORNIA RESIDENTIAL CODE, THE
CALIFORNIA MECHANICAL CODE, THE CALIFORNIA PLUMBING CODE, THE
CALIFORNIA ELECTRICAL CODE, THE CALIFORNIA EXISTING BUILDING CODE, THE
CALIFORNIA GREEN BUILDING STANDARDS CODE, THE CALIFORNIA ENERGY CODE,
AND THE CALIFORNIA REFERENCED STANDARDS CODE WITH APPENDICES AND
AMENDMENTS HEREIN; ADOPTING THE 2024 EDITION OF THE INTERNATIONAL
PROPERTY MAINTENANCE CODE AND THE INTERNATIONAL POOL AND SPA CODE
WITH AMENDMENTS; AMEND CHAPTER 12.360 SINGLE-FAMILY MODEL REACH CODE –
FLEXPATH; HEREIN AND ADOPTING FINDINGS OF FACT SUPPORTING THE
AMENDMENTS TO THE CODES
THE CITY COUNCIL OF THE CITY OF SAN RAFAEL DOES ORDAIN AS FOLLOWS:
DIVISION 1. AMENDMENTS TO MUNICIPAL CODE.
Section 12.100.010 of the Municipal Code of the City of San Rafael is amended to repeal and
replace the chapter with the following:
12.100.010 Adopted codes. The following recognized codes are hereby adopted by the City of
San Rafael together with the supplements, listed changes, additions, and deletions as noted:
1.2025 Edition, California Building Code (“CBC”), chapters 2 through 28, 30, 31, 32, 33,
35, and Appendices C, G, H, I, N, and O.
2.2025 Edition, California Electrical Code (“CEC”).
3.2025 Edition, California Energy Code (“CEgC”).
4.2025 Edition, California Existing Building Code (“CEBC”), chapters 2 through 16 and
Appendices.
5.2025 Edition, California Green Building Construction Standards Code (“CalGreen”),
chapters 1 through 8.
6.2025 Edition, California Historical Building Code (“CHBC”)
7.2025 Edition, California Mechanical Code (“CMC”) chapters 2 through 17.
8.2025 Edition, California Plumbing Code (“CPC”), chapters 2 through 17 and
Appendices A, C, D, and I.
9.2025 Edition, California Referenced Standards Code.
10.2025 Edition, California Residential Code (“CRC”), chapters 2 through 10, chapter 44,
and Appendices BB, BF, BG, BI, BJ, BK, BL, BM, BO, and CI.
11.2024 International Property Maintenance Code (“IPMC”) chapters 1 through 8 and
Appendix A.
12.2024 Edition, International Swimming Pool and Spa Code (“ISPSC”), chapters 2
through 11.
CHAPTER 12.200 - CALIFORNIA BUILDING CODE AMENDMENTS
Chapter 12.200 of the Municipal Code of the City of San Rafael is hereby repealed in its entirety
4896-5923-3369 v2 2
and replaced with the following:
12.200.010 General. For purposes of this Chapter:
Deleted language from the base code has been stricken through.
Added language to the base code has been underlined.
12.200.020 Amendments. The 2025 California Building Code is amended or modified as
follows:
Amend Section 202 to read as follows:
The definition of “Kitchen” is deleted and added to read as follows:
KITCHEN. An area in which the preparation of food for eating occurs (that has provisions
for cooking or heating of food; washing and storing of dishware and utensils; and
refrigeration or storing of food).
The definition of “Substantial Remodel” is added to read as follows:
SUBSTANTIAL REMODEL. Substantial remodel shall mean the alteration of any structure
which, combined with any additions to the structure, performed within any three (3) year
period, affects a floor area which exceeds fifty percent (50%) of the existing floor area of the
structure. When any changes are made in the building, such as walls, columns , beams or
girders, floor or ceiling joists and coverings, roof rafters, roof diaphragms, foundations, piles
or retaining walls or similar components, the floor area of all rooms affected by such changes
shall be included in computing floor areas for purposes of applying this definition. This
definition does not apply to the replacement and upgrading of residential roof coverings or
exterior wall finishes.
Amend Section 903.2 is amended to read as follows:
903.2 Where Required. Approved automatic fire sprinkler systems in new buildings and
structures shall be provided in the locations described in Sections 903.2.1 through 903.2.12
and 903.2.14 through 903.2.21 and in all of the following:
1.Newly constructed buildings or facilities, except detached Group U occupancies not
more than one thousand (1,000) square feet in floor area and provided with exterior wall
and opening protection as per Table 602 of the California Building Code.
2.Newly created, attached, second dwelling units which meet the definition of a substantial
remodel.
3.All other existing buildings, fire sprinkler systems may be required by the fire chief in
accordance with the following:
3.1. All buildings where improvements occur during any three (3) year period that
cumulatively meet the definition of a substantial remodel.
3.2. All buildings, except R-3 occupancies, in excess of three thousand (3,000) square
4896-5923-3369 v2 3
feet that have more than ten percent (10%) floor area added within any three (3)
year period. Exceptions may be granted by the fire chief when alternate means of
protection are installed as approved by the fire code official.
3.3. A change in the use of a building that results in a higher fire or life safety hazard
when the square footage of the area changing use is more than 50% of the square
footage of the existing building.
3.4. Where fire sprinklers are required by provisions of this code, they shall be
extended throughout the building.
4. All public storage facilities. Exceptions may be granted by the fire chief when alternate
means of protection are installed as approved by the fire code official
5. All tunnels used for the transportation of people or any type of vehicle.
The requirements for fire sprinkler systems in this code section are not meant to disallow
the provisions for area increase, height increase, or fire-resistive-rated substitution if
otherwise allowed by this code.
Exception [Unchanged.]
Section 903.2.1 through 903.2.17. [Unchanged.]
Amend Section 903.2.18 by deleting the exception.
Section 903.2.19. [Unchanged.]
Amend Section 909.2. by adding the following sentence at the end of the paragraph:
Replacement of an existing smoke alarm that is hardwired and/or interconnected shall be
made with an alarm of the same functionality.
Amend Section 1011.6 to read as follows:
1011.6 Stairway Landings. There shall be a floor or landing at the top and bottom of each
stairway. The width of landings, measured perpendicularly to the direction of travel, shall be
not less than the width of stairways served. Every landing shall have a minimum depth,
measured parallel to the direction of travel, equal to the width of the stairway or 48 inches
(1219 mm), whichever is less. Every landing with a fire riser or other fire system apparatus
shall increase the minimum required depth, measured parallel to the direction of travel, by
an additional 8 inches (203 mm). Doors opening onto a landing shall not reduce the landing
to less than one-half the required width. When fully open, the door shall not project more
than 7 inches (178 mm) into the required width of a landing. Where wheelchair spaces are
required on the stairway landing in accordance with Section 1009.6.3, the wheelchair space
shall not be located in the required width of the landing and doors shall not swing over the
wheelchair spaces. Exceptions [Unchanged.]
Amend Section 1015.2 by adding the following concluding sentence:
Guards are also required at waterfront bulkheads, fixed piers, and gangways.
4896-5923-3369 v2 4
Add Section 1015.8.2 & 1015.8.3 to read as follows:
1015.8.2 Existing Hotels. The provisions of sections 1015.8 shall apply retroactively to all
existing hotels.
1015.8.3 Clear area adjacent to hotel window opening. There shall be no furniture, fixed
or movable, placed within thirty-six inches (36") of any openable portion of a window. Hotels
shall also provide notice to prospective guests of this requirement.
Amend Section 1505.1 by deleting the last sentence and the referenced Table 1505.1.
Exception [Unchanged]
Amend Section 1505.1.1 to read as follows:
1505.1.1 Roofing requirements within Fire Hazard Severity Zone or in the Wildland-
Urban Interface (WUI). Roofing requirements for structures located within Fire Hazard
Severity Zones or in the Wildland-Urban Interface Fire (WUI) shall be a fire-retardant roof
covering that is at least Class A and shall also comply with Section 705A.
Amend Section 1505.1.2 to read as follows:
1505.1.2 Roof coverings within all other areas. The entire roof covering of every existing
structure, where more than 50% of the total roof area is replaced within any one-year period,
the entire roof covering of every new structure, and any roof covering applied in the
alteration, repair or replacement of the roof of every existing structure, shall be a fire-
retardant roof covering that is at least Class C A fire classification.
All roof coverings that are not at least Class A shall be a fire-retardant roof covering that is
at least Class A by May 31, 2027.
Add Section 1807.4 to read as follows:
1807.4 Wooden retaining walls. Wooden retaining walls may not be used to support any
building surcharge or vehicular way. In addition, wooden retaining walls shall not be
employed to retain soils above or below a building where failure of the wall may subject the
building to damage.
CHAPTER 12.210 - CALIFORNIA ELECTRICAL CODE AMENDMENTS
12.210.010 No amendment. The 2025 California Electrical Code is not amended or modified.
CHAPTER 12.220 - CALIFORNIA ENERGY CODE AMENDMENTS
12.220.010 No amendment. The 2025 California Energy Code is not amended or modified.
4896-5923-3369 v2 5
CHAPTER 12.230 - CALIFORNIA EXISTING BUILDING CODE AMENDMENTS
12.230.010 General. For purposes of this Chapter:
Deleted language from the base code has been stricken through.
Added language to the base code has been underlined.
12.230.020 Amendments. The 2025 California Existing Building Code is amended or modified
as follows:
Add Section 406.2.1 & 406.2.2 to read as follows:
406.2.1 Existing Hotels. The provisions of section 406.2 shall apply retroactively to all
existing hotels.
406.2.2 Clear area adjacent to hotel window opening. There shall be no furniture, fixed
or movable, placed within thirty-six inches (36”) of any openable portion of a window. Hotels
shall also provide notice to prospective guests of this requirement.
CHAPTER 12.235 - CALIFORNIA GREEN BUILDING CONSTRUCTION STANDARDS CODE
AMENDMENTS
12.235.010 No amendment. The 2025 California Green Building Construction Standards Code
is not amended or modified.
CHAPTER 12.240 - CALIFORNIA HISTORICAL BUILDING CODE AMENDMENTS
12.240.010 No amendment. The 2025 California Historical Building Code has not been
amended or modified.
CHAPTER 12.245 - CALIFORNIA MECHANICAL CODE AMENDMENTS
12.245.010 No amendment. The 2025 California Mechanical Code is not amended or
modified.
CHAPTER 12.250 - CALIFORNIA PLUMBING CODE AMENDMENTS
12.250.010 No amendment. The 2025 California Plumbing Code is not amended or modified.
CHAPTER 12.255 - CALIFORNIA RESIDENTIAL CODE AMENDMENTS
12.255.010 General. For purposes of this Chapter:
Deleted language from the base code has been stricken through.
4896-5923-3369 v2 6
Added language to the base code has been underlined.
12.255.020 Amendments. The 2025 California Residential Code is amended or modified as
follows:
Amend Section R202 to read as follows:
The definition of “Kitchen” is deleted and added to read as follows:
KITCHEN. An area in which the preparation of food for eating occurs (that has provisions
for cooking or heating of food; washing and storing of dishware and utensils; and
refrigeration or storing of food).
The definition of “Substantial Remodel” is added to read as follows:
SUBSTANTIAL REMODEL. Substantial remodel shall mean the alteration of any structure,
which, combined with any additions to the structure, performed within any three (3) year
period, affects a floor area that exceeds fifty percent (50%) of the existing floor area of the
structure. When any changes are made in the building, such as walls, columns, beams or
girders, floor or ceiling joists and coverings, roof rafters, roof diaphragms, foundations, piles
or retaining walls or similar components, the floor area of all rooms affected by such changes
shall be included in computing floor areas for purposes of applying this definition. This
definition does not apply to the replacement and upgrading of residential roof coverings or
exterior wall finishes.
Delete exception to Section R309.1 and amend Section R309.1 to read as follows:
R309.1 Townhouse automatic fire sprinkler systems. An automatic residential fire
sprinkler system shall be installed in all newly constructed townhouses and in existing
townhouses where alterations and/or additions to the existing structure, performed over any
3-year period, qualify as a "Substantial Remodel" as defined in this code. Any addition to a
building with an existing fire sprinkler system shall have that system extended to the new
portions of the building, irrespective of the size of the addition.
R309.1.1 [Unchanged]
Amend Section R309.2 to read as follows:
R309.2 One-and two-family dwellings automatic fire systems. An Automatic residential
fire sprinkler system shall be installed in all newly constructed one-and two-family dwellings
and in existing one-and two-family dwellings where alterations and/or additions to the
existing structure, performed over any 3-year period, qualify as a "Substantial Remodel" as
defined in this code. Any addition to a building with an existing fire sprinkler system shall
have that system extended to the new portions of the building, irrespective of the size of the
addition.
R309.2.1. [Unchanged]
Amend Section R309.3.1.2 by deleting exception #4.
Amend Section R310.7.2 by adding the following:
4896-5923-3369 v2 7
Smoke alarms shall be tested and maintained in accordance with the manufacturer's
instructions. Smoke alarms that no longer function shall be replaced. Replacement of an
existing smoke alarm that is hardwired and/or interconnected shall be made with an alarm
of the same functionality.
Amend Section R902.1.1 to read as follows:
R902.1.3 Roofing requirements with Fire Hazard Severity Zones or a Wildland-Urban
Interface (WUI) area. Roofing requirements for structures located within Fire Hazard
Severity Zones or in a Wildland-Urban Interface (WUI) area shall be a fire-retardant roof
covering that is at least Class A and shall also comply with Part 7, California Wildland-Urban
Interface Code.
Amend Section R902.1.2 to read as follows:
R902.1.2 Roof coverings in all other areas other than the Fire Hazard Severity Zones
or a Wildland-Urban Interface (WUI) area. The entire roof covering of every existing
structure where more than 50% of the total roof area is replaced within any one-year period,
the entire roof covering of every new structure, and any roof covering applied in the
alteration, repair or replacement of the roof of every existing structure, shall be a fire-
retardant roof covering that is at least Class C A fire classification and shall also comply with
Part 7, California Wildland-Urban Interface Code.
All roof coverings that are not at least Class A shall be a fire-retardant roof covering that is
at least Class A by May 31, 2027.
CHAPTER 12.260 – INTERNATIONAL PROPERTY MAINTENANCE CODE AMENDMENTS
12.260.010 General. For purposes of this Chapter:
Deleted language from the base code has been stricken through.
Added language to the base code has been underlined.
12.260.020 Amendments. The 2024 International Property Maintenance Code is amended or
modified as follows:
Delete Section 101.1, 103, 104, 106, and 107
Amend Section 109.4 to read as follows:
109.4 Notice. Whenever the code official determines that there has been a violation of this
code or has grounds to believe that a violation has occurred, notice shall be given in the
manner prescribed in Section 1.08.060 of the San Rafael Municipal Code. 109.4.1 and
109.4.2 to the owner or the owner’s authorized agent, for the violation as specified in this
code. Notices for condemnation procedures shall comply with this section.
Delete Section 109.4.1 and 109.4.2.
4896-5923-3369 v2 8
Amend Sections 110.2, 110.3, and 110.4 to read as follows:
110.2 Temporary safeguards. Notwithstanding other provisions of this code, whenever, in
the opinion of the code official, there is imminent danger due to an unsafe condition, the
code official shall may order the necessary work to be done, including the boarding up of
openings, to render such structure temporarily safe whether or not the legal procedure
herein described has been instituted; and shall cause such other action to be taken as the
code official deems necessary to meet such emergency.
110.3 Closing streets. When necessary for public safety, the code official shall may
temporarily close structures and close or order the authority having jurisdiction to close,
sidewalks, streets, public ways and places adjacent to unsafe structures, and prohibit the
same from being utilized.
110.4 Emergency repairs. For the purposes of this section, the code official shall may
employ the necessary labor and materials to perform the required work as expeditiously as
possible.
Delete Sections 110.5 and 110.6.
Amend Sections 111.2 and 111.3 to read as follows:
111.2 Notices and orders. All notices and orders shall comply with Section 109.4 Chapter
1.46 of the San Rafael Municipal Code.
111.3 Failure to comply. If the owner of a premises fails to comply with a demolition order
within the time prescribed, the code official shall may cause the structure to be demolished
and removed, either through the forces of the an available public agency or by contract or
arrangement with private persons, and the cost of such demolition and removal shall be
charged against the real estate upon which the structure is located and shall be a lien upon
such real estate.
Delete Sections 112 and 113.
Amend Section 202 to read as follows:
The definition for “Code Official” is added as follows:
CODE OFFICIAL. Where used in this code, the term code official shall mean the planning
manager, code enforcement manager, or the building official of the City of San Rafael, and
their designees.
Amend Section 302.4 to read as follows:
302.4 Weeds. Premises and exterior property shall be maintained free from weeds or plant
growth in excess of 6 inches tall. Noxious weeds shall be prohibited. Weeds shall be defined
as all grasses, annual plants and vegetation, other than trees or shrubs, provided however,
this term shall not include cultivated flowers and gardens. [Rest of section to remain
unchanged.]
Amend Section 304.14 to read as follows:
4896-5923-3369 v2 9
304.14 Insect Screens. During the period from [DATE] to [Date] every Every door, window
and other outside opening required for ventilation of habitable rooms, food preparation
areas, food service areas or any areas where products to be included or utilized in food for
human consumption are processed, manufactured, packaged or stored shall be supplied
with approved tightly fitting screens of not less than 16 mesh per inch (16 mesh per 25
mm),and every screen door used for insect control shall have a self -closing device in good
working condition.
Exception [Unchanged.]
Amend Section 308.2.2 to add these words to the end of the sentence:
or securing the doors in an approved manner.
Amend Section 308.3.1 by adding the following:
Every person maintaining or using any solid waste can or receptacle shall keep the same
clean and sanitary.
Amend Section 308.3.2 by adding the following:
Within all residential districts in the city, no person shall use, locate, or maintain (store) any
solid waste can, garbage container, or other waste receptacle within the public right-of-way
other than on the day of removal service. Such waste receptacles shall be stored out of
public view on non-service dates, whenever practical, or stored nearest the main structure.
Amend Section 602.3 to read as follows:
602.3 Heat supply. Every owner and operator of any building who rents, leases or lets one
or more dwelling units or sleeping units on terms, either expressed or implied, to furnish
heat to the occupants thereof shall supply heat during the period from [DATE] to [DATE] to
maintain a temperature of not less than 68°F (20°C) in all habitable rooms, bathrooms and
toilet rooms.
Exceptions [Unchanged.]
Amend Section 602.4 to read as follows:
602.4 Occupiable work spaces. Indoor occupiable work spaces shall be supplied with
heat during the period from [DATE] to [DATE] to maintain a temperature of not less than
65°F (18°C) during the period the spaces are occupied.
Exceptions [Unchanged.]
CHAPTER 12.265 – INTERNATIONAL SWIMMING POOL AND SPA CODE AMENDMENTS
12.265.010 General. For the purposes of this Chapter:
Deleted language from the base code has been stricken through.
Added language to the base code has been underlined.
12.265.020 Amendments. The 2024 International Swimming Pool and Spa Code is amended
4896-5923-3369 v2 10
or modified as follows:
Amend Section 202 to add the following definition:
PRIVATE SWIMMING POOL means a swimming pool or pool located at and intended
primarily for the use of the occupants of a single or two-family dwelling unit.
Amend Section 301 by adding the following:
301.2 Existing swimming pools. Any person who owns or is in possession of an existing
private swimming pool that does not conform to the requirements of this section shall make
the pool conform to the requirements of this section within ninety (90) days from its effective
date.
Exceptions: The chief building official is hereby authorized to exempt any private
swimming pool from the provisions of the Health and Safety Code 115922:
1. If it is secured from unauthorized entry by a natural or artificial barrier that provides
the same or a greater degree of protection than would an enclosure.
An application for exception shall be filed in writing with the chief building official. The
application shall contain a brief statement evidencing that the applicant is entitled to the
exception and such other information as the chief building official may prescribe.
Delete Sections 302 and 305.
Amend Section 305 by adding the following:
305.1 General. Pool barriers and enclosures shall meet the requirements of the California
Swimming Pool Safety Act. The text in CBC 3109.2 contains the statutory language that is
required to be duplicated and published in the California Code of Regulations, Title 24. As
such, the section numbers reflect those within the Health and Safety Code.
305.2 Enclosure required for private swimming pools. Every person who owns or is in
possession of any land on which there is situated a private swimming pool shall secure the
pool from unauthorized entry by an enclosure that meets all of the requirements of the
Health and Safety Code 115923. The enclosure shall be specifically designed to prevent
unauthorized entry from adjacent private and/or public property. This enclosure shall be in
addition to the "safety features" required by the Health and Safety Code 115922.
Chapter 12.360 of the Municipal Code of the City of San Rafael is amended to read as follows,
with additions shown as underlined and deletions shown with strikethrough:
CHAPTER 12.360 – SINGLE-FAMILY MODEL REACH CODE - FLEXPATH
12.360.010 Purpose. The purpose of this chapter is to specify additional energy efficiency
and renewable energy measures for additions, alterations and remodels of Covered Single -
Family Projects.
12.360.20 Definitions. For the purpose of this chapter, the following definitions shall apply:
4896-5923-3369 v2 11
1. “Single-Family Building” shall mean any of the following:
a. Residential building of Occupancy Group R-3 or under the California
Residential Code with two or fewer dwellings.
b. A townhouse.
c. A building of Occupancy Group R-3.1, or
d. A building of Occupancy Group U when located on a residential site.
2. “Covered Single-Family Project” shall mean the addition, alteration, or remodel of a
Single-Family Building originally permitted for construction before 2011 that affects a
floor area which exceeds 500 square feet of existing floor area and/or new floor area.
When any changes are made in the building, such as walls, columns, beams or
girders, floor or ceiling joists and coverings (subfloor and drywall), roof rafters, roof
diaphragms, foundations, piles or retaining walls or similar components, the floor area
of all rooms affected by such changes shall be included in computing floor areas for
purposes of applying this definition.
These definitions does not apply to project scopes that are solely limited to any of the
following: the replacement and upgrading of residential roof coverings, exterior wall finishes
and/or floor finishes; alterations that add no more than 75 square feet of fenestration;
alterations that add no more than 16 square feet of skylight area with a maximum U -factor of
0.55 and a maximum SHGC of 0.30; alterations that are limited to providing access for
persons with disabilities; or voluntary state seismic retrofit program. A Covered Single-Family
Project shall not include a project that is a newly constructed building under the California
Energy Code, Title 24, Part 6.
12.360.020 Scope. In addition to all requirements of the California Energy Code applicable
to Single Family Building additions and alterations, the provisions of this chapter shall apply
to all Covered Single-Family Projects.
12.360.020 Requirements. A Covered Single-Family Project shall install a set of measures
based on the building vintage from the Measure Menu in Table 12.360 B, to achieve a total
Measure Point Score that is equal to or greater than the Target Score in Table 12.360 A. In
addition, all mandatory measures listed in Table 12.360 B shall be installed. The installed
measures shall meet the specifications in Table 12.360 C.
Beginning January 1, 2027, or later as determined by the Chief Building Official, Covered
Single Family Projects shall install a set of measures based on the building vintage from the
Measure Menu in Table 12.360 B, to achieve a total Measure Point Score that is equal to or
greater than the Target Score in Table 12.360 A-1. In addition, all mandatory measures listed
in Table 12.360 B shall be installed. The installed measures shall meet the specifications in
Table 12.360 C.
Building vintage is the year in which (1) a building permit for construction of the structure was
submitted, as documented by building department records, or (2) a building permit was issued
for an addition or alteration that satisfied the Performance Standards (California Energy Code,
Title 24, Part 6, Section 150.1(b)) in effect at time of building permit issuance, whichever is
later. Unless otherwise specified, the requirements shall apply to the entire dwelling unit, not
just the additional or altered portion. Measures from the Measure Menu table that already
exist in the home may be counted towards compliance with these requirements. Measures
4896-5923-3369 v2 12
from the Measure Menu table that are to be installed to satisfy requirements under the
California Energy Code, Title 24, Part 6, may not count towards compliance with these
requirements. Where these requirements conflict with other California Energy Code
requirements, the stricter requirements shall prevail.
Exceptions
1. If the applicant demonstrates that the Energy Budget of the building under the
proposed project would be less than or equal to the Energy Budget of the building
under the proposed project if it included any set of measures that would achieve
compliance under this chapter 12.360. For purposes of this section, “Energy Budget”
shall have that meaning set forth in CBC section 100.1(b), as that section may be
amended.
2. Mobile Homes, Manufactured Housing, or Factory-built Housing as defined in Division
13 of the California Health and Safety Code (commencing with Section 17000 of the
Health and Safety Code).
3. Due to conditions specific to the project, if it is technically or economically infeasible to
achieve compliance, the Building Official may reduce the Target Score and/or waive
some or all of the mandatory requirements.
4. A measure that is necessary for compliance is prohibited because of a covenant or
other deed restriction on the property, such as a homeowners’ association covenant.
5. The Building Official may reclassify the vintage of the building based on existing
conditions.
6. An applicant who resides in the dwelling unit and qualifies as a low-income utility
customer, or is the owner of the dwelling unit which is occupied by a dependent who
qualifies as a low-income utility customer, may comply by either a) installing the duct
sealing measure, the lighting measure and water heating package, or b) installing at
least 1 kW of solar PV that meets the requirements of 2022 Title 24 Reference
Appendix JA11. A low-income utility customer is anyone who is eligible for the
California Alternative Rates for Energy (CARE) or Family Electric Rate Assistance
Program (FERA) program. A Covered Single-Family Project that consists solely of
medically necessary improvements or solely of seismic safety improvements.
7. Nothing in this ordinance shall be construed to prohibit any one appliance covered by
the Energy Policy and Conservation Act (EPCA) (42 U.S.C. 6292(a)). Should an
applicant establish that this ordinance, as applied, prohibits a covered appliance in the
applicant’s project, the Building Official shall waive that portion of the ordinance
causing such prohibition.
Table 12.360 A
Target Scores, Climate Zone 2
Building Vintage Pre-1978 1978-1991 1992-2010
Target Score 12 8 40*
4896-5923-3369 v2 13
*Note: 1992-2010 Building Vintages are only required to complete the Mandatory Lighting
Measure if not already complete.
Table 12.360 A-1
Target Scores, Climate Zone 2
(effective January 1, 2027)
Building Vintage Pre-1978 1978-1991 1992-2010
Target Score 16 9 60*
*Note: 1992-2010 Building Vintages are only required to complete the Mandatory Lighting
Measure if not already complete.
Table 12.360 B
Measure Menu, Climate Zone 2
ID Measure Building Vintage
Pre-1978 1978-1991 1992-2010
E1 Lighting Measures Mandatory
E2 Water Heating Package 1 1 1
E3 Air Sealing 2 2 1
E4 Attic Insulation (R-38) 6 2 1
E5 Duct Sealing 6 4 1
E6 New Ducts + Duct Sealing 9 6 2
E7 Windows 5 3 3
E8 Wall Insulation (R-1315) 7 -- --
E10 Raised floor insulation (R-19)/(R-30) 8/10 8/9 --
FS1 Heat Pump Water Heater Replacing Gas 12 12 12
FS2 High Eff. Heat Pump Water Heater Replacing
Gas 14 14 14
FS3 Heat Pump Water Heater Replacing Electric 4 4 4
FS4 High Eff. Heat Pump Water Heater Replacing
Electric 6 6 6
FS5 Heat Pump Space Heater 23 18 15
FS6 High Eff. Heat Pump Space Heater 25 19 17
FS7 Dual Fuel Heat Pump Space Heater 20 15 14
FS8 Heat Pump Clothes Dryer 2 2 2
FS9 Induction Cooktop 1 1 1
PV Solar PV 16 15 13
The measures in the Measure Menu shall conform to the specifications in Table 12.360C.
Table 12.360 C
4896-5923-3369 v2 14
Measure Specifications
ID Energy Measure Specification
Energy Measures
E1 Mandatory - Lighting Measures – Replace all interior and exterior screw-in
incandescent, halogen, and compact fluorescent lamps with LED lamps. Install
photocell controls on all exterior lighting luminaires. Install lighting with an efficiency of
45 lumens per watt or greater in all interior and exterior screw-in fixtures. Install
photocell, occupancy sensor, or energy management system controls that meet the
requirements of 150.0(k)3 in all outdoor lighting permanently mounted to a residential
building or to other buildings on the same lot.
E2 Water Heating Package: Insulate all accessible hot water pipes with pipe insulation a
minimum of ¾ inch thick. This includes insulating the supply pipe leaving the water
heater, piping to faucets underneath sinks, and accessible pipes in attic spaces or crawl
spaces. Upgrade fittings in sinks and showers to meet current California Green Building
Standards Code (Title 24, Part 11) Section 4.303 water efficiency requirements.
Exception: Upgraded fixtures are not required if existing fixtures have rated or measured
flow rates of no more than ten percent greater than the 2022 2025 California Green
Building Standards Code (Title 24, Part 11) Section 4.303 water efficiency requirements.
E3 Air Sealing: Seal all accessible cracks, holes, and gaps in the building envelope at
walls, floors, and ceilings. Pay special attention to penetrations including plumbing,
electrical, and mechanical vents, recessed can light luminaires, and windows. Weather-
strip doors if not already present. Verification shall be conducted following a prescriptive
checklist that outlines which building aspects need to be addressed by the permit
applicant and verified by an inspector. Compliance can also be demonstrated with
blower door testing conducted by a certified HERS ECC Rater no more than three
years prior to the permit application date that either: a) shows at least a 30 percent
reduction from pre-retrofit conditions; or b) shows that the number of air changes per
hour at 50 Pascals pressure difference (ACH50) does not exceed ten for Pre-1978
vintage buildings, seven for 1978 to 1991 vintage buildings and five for 1992-2010
vintage buildings. If combustion appliances are located within the pressure boundary of
the building, conduct a combustion safety test by a certified ECC Rater or a
professional certified by the Building Performance Institute, in accordance with the BPI
Technical Standards for the Building Analyst Professional. professional certified by the
Building Performance Institute in accordance with the ANSI/BPI-1200-S-2017 Standard
Practice for Basic Analysis of Buildings, the Whole House Combustion Appliance Safety
Test Procedure for the Comfortable Home Rebates Program 2020 or the California
Community Services and Development Combustion Appliance Safety Testing Protocol.
E4 R-38 Attic Insulation: Attic insulation shall be installed to achieve a weighted assembly
U-factor of 0.025 or insulation installed at the ceiling level shall have a thermal
resistance of R-38 or greater for the insulation alone. Recessed downlight luminaires in
the ceiling shall be covered with insulation to the same depth as the rest of the ceiling.
Luminaires not rated for insulation contact must be replaced or fitted with a fire-proof
cover that allows for insulation to be installed directly over the cover.
Exception: In buildings where existing R-30 is present and existing recessed downlight
luminaires are not rated for insulation contact, insulation is not required to be installed
over the luminaires.
E5 Duct Sealing: Air seal all space conditioning ductwork to meet the requirements of the
2025 Title 24, Part 6, Section California Energy Code 150.2(b)1E. The duct system
4896-5923-3369 v2 15
must be tested by a HERS ECC Rater no more than three years prior to the Covered
Single Family Project permit application date to verify the duct sealing and confirm that
the requirements have been met. This measure may not be combined with the New
Ducts and Duct Sealing measure in this Table.
Exception: Buildings without ductwork or where the ducts are in conditioned space.
E6 New Ducts, R-6 insulation + Duct Sealing: Replace existing space conditioning
ductwork with new R-6 ducts that meet the requirements of 2022 2025 Title 24 Section
150.0(m)11. This measure may not be combined with the Duct Sealing measure in this
Table. To qualify, a preexisting measure must have been installed no more than three
years before the Covered Single Family Project permit application date.
E7 Windows: Replace at least 50% of existing windows with high-performance windows
with an area-weighted average U-factor no greater than 0.3027.
E8 R-13 15 Wall Insulation: Install wall insulation in all exterior walls to achieve a weighted
U-factor of 0.102 0.095 or install wall insulation in all exterior wall cavities that shall
result in an installed thermal resistance of R-1315 or greater for the insulation alone.
E9 Reserved for future use
E10 R-19 / R-30 Floor Insulation: Raised-floors shall be insulated such that the floor
assembly has an assembly U-factor equal to or less than U-0.037 / U-0.0340.028 or
shall be insulated between wood framing with insulation having an R-value equal to or
greater than R-19 / R-30.
Fuel Substitution Measures
FS1 Heat Pump Water Heater (HPWH) Replacing Gas: Replace the existing natural gas
water heater with a heat pump water heater that meets the requirements of Sections
110.3 and 150.2(b)1.H.iii.b.
FS2 High Efficiency Heat Pump Water Heater (HPWH) Replacing Gas: Replace the existing
natural gas water heater with a heat pump water heater with a Northwest Energy
Efficiency Alliance (NEEA) Tier 3 or higher rating that also meets the requirements of
Sections 110.3 and 150.2(b)1.H.iii.c.
FS3 Heat Pump Water Heater (HPWH) Replacing Electric: Replace the existing electric
resistance water heater with a heat pump water heater that meets the requirements of
Sections 110.3 and 150.2(b)1.H.iii.b.
FS4 High Efficiency Heat Pump Water Heater (HPWH) Replacing Electric: Replace the
existing electric resistance water heater with a heat pump water heater with a
Northwest Energy Efficiency Alliance (NEEA) Tier 3 or higher rating.
FS5 Heat Pump Space Heater: Replace all existing gas and electric resistance primary
space heating systems with an electric-only heat pump system that also meets the
requirements of Sections 110.3 and 150.2(b)1.H.iii.c.
FS6 High Efficiency Heat Pump Space Conditioning SystemHeater: Replace all existing gas
and electric resistance primary space heating systems with an electric-only heat pump
system that meets the requirements of Sections 110.3 and 150.2(b)1.C, 150.2(b)1.E,
150.2(b)1.F, and 150.2(b)1.G and one of the following:
A. A ducted electric-only heat pump system with a SEER2 rating of 16.5 or
greater, an EER2 rating of 12.48 or greater and an HSPF2 rating of 9.5 or greater;
or
B. A ductless mini-split heat pump system with a SEER2 rating of 14.3 or
greater, an EER2 rating of 11.7 or greater and an HSPF2 rating of 7.5 or greater
FS7 Dual Fuel Heat Pump Space Heater: Either
4896-5923-3369 v2 16
A. Replaces all existing gas and electric resistance primary heating systems
with a hybrid gas and electric heat pump system, or
B. Install an electric-heat pump system in tandem with a gas furnace and
install controls to operate the heat pump to use the existing gas furnace for
backup heat only.
FS8 Heat Pump Clothes Dryer: Replace the existing electric resistance clothes dryer with a
heat pump dryer with no resistance element and cap the gas line.
FS9 Induction Cooktop: Replace all existing gas and electric resistance stove tops with an
inductive induction stove top and cap the gas line.
Solar PV and Electric-Readiness Measures
PV Solar PV + Electric Ready Pre-Wire: Install a solar PV system that meets the
requirements of California Energy Code Section 150.1(c)14. In addition, upgrade the
panelboard to meet the requirements of Item ER1 in this Table and install any one other
measures from Item ER2. Solar PV + Electric Ready Pre-Wire: Install a solar PV
system that meets the requirements of California Energy Code Section 150.1(c)14. In
addition, for existing PV systems that had been installed prior to the application date of
the current project, install any one measure from the list below.
A. Heat Pump Water Heater Ready, as specified in California Energy Code Section
150.0(n)1.
B. Heat Pump Space Heater Ready, as specified in California Energy Code Section
150.0(t).
C. Electric Cooktop Ready, as specified in California Energy Code Section 150.0(u).
D. Electric Clothes Dryer Ready, as specified in California Energy Code Section
150.0(v).
E. Energy Storage Systems (ESS) Ready, as specified in California Energy Code
Section 150.0(s).
F. EV Charger Ready. Install a dedicated 208/240-volt branch circuit as specified in the
California Green Building Code, Title 24, Part 11, Section A4.106.8.1, which
otherwise applies to new construction.
DIVISION 2 FINDINGS.
California Health and Safety Code Sections 17958, 17958.5, 17958.7, and 18941.5 allow the City,
by ordinance, to make modifications or changes to building standards within the California
Building Standards Code in Title 24 of the California Code of Regulations and other regulations
adopted pursuant to Health and Safety Code Section 17922.
The Health and Safety Code requires such changes to be determined to be reasonably necessary
because of local climatic, geologic, or topographic conditions.
The Health and Safety Code requires that the City, before making any modifications or changes,
make an express finding that each such modification or change is needed.
The Health and Safety Code requires such findings to be made available as a public record and
a copy of such findings to be filed with the California Building Standards Commission.
4896-5923-3369 v2 17
Staff has recommended that changes and modifications be made to the California Building
Standards Code in Title 24 of the California Code of Regulations as reasonably necessary due to
the unique local climatic, geologic, or topographic conditions in the City of San Rafael.
The City Council finds that certain local climatic, geologic, or topographic conditions exist as
follows:
A. The City of San Rafael has within its borders and along its boundaries significant
areas of grass, brush, and heavily forested lands. These hazardous conditions
present an exceptional and continuing fire danger to the residents of the
community due to the difficulty of the terrain and topography of the area, much of
it consisting of boxed canyons with steep, brush-covered slopes; narrow winding
streets used by residents of the area and the Fire Department for ingress and
egress, steep hills which hinder Fire Department response time; older and
inadequate water systems in certain areas of the community; and the location of
buildings and structures with relation to these dangerous areas. (Topography)
B. A great number of structures located within the City of San Rafael were built in the
late 1800s and early 1900s, thus lacking the built-in protection of modern
construction. Many of the residential structures had been built on steep slopes
with boxed canyons, and a large percentage are located in areas of heavy natural
growth. Many structures (new and old) are constructed of highly combustible
material, which offers little resistance to fire and could contribute to the spread of
fire. (Topography)
C. Many of the City’s street and pathway system was laid out in the late 1800s and
early 1900s. Many of the City’s streets have less than 20 feet of unobstructed
width and turning radius. Roadways with less than 20 feet of unobstructed paved
surface are considered hazardous in terms of fire access and protection. In the
event that the Fire Department is called to respond to a fire emergency in any of
these areas, its response time to an emergency is increased by these topographic
conditions. (Topography)
D. The desire of the community to preserve natural vegetation and open space has
resulted in the encroachment of brush and grass on fire roads, trails, breaks, and
streets within the City, thus rendering such separations ineffective against the
spread of fires. Natural growth, which is highly flammable during the summer and
fall months, encroaches upon many properties, thus posing a potential fire threat
to many structures and creating a substantial hindrance to the control of such fires.
(Climate, Topography)
E. The City’s precipitation ranges from 15 to 42 inches per year, with an average of
approximately 31 inches per year. Approximately 90% of the precipitation falls
during the months of October through April, and 10% from May through
September. Times of little or no rainfall, of low humidity, and high temperatures
create extremely hazardous fire conditions. (Climate)
F. The City’s natural topographic and geological features create an increased risk
from flooding, hillside runoff, and landslides due to a combination of factors,
4896-5923-3369 v2 18
including periodic heavy winter rainfalls, soil conditions, proximity to San Francisco
Bay, and other related factors. Low-lying areas can also be subject to tidal
fluctuations and liquefaction following an earthquake. (Topography, Geology)
G. Seismically, the City sits between two active earthquake faults (San Andreas and
Hayward) and numerous potentially active faults. Fire following an earthquake has
the potential of causing greater loss of life and damage than the earthquake itself.
Should a significant seismic event occur, public safety resources would have to be
prioritized to mitigate the greatest threat and may not be available for every
structural fire. In such events, individual structures should be equipped to help in
mitigating the risk of damage. (Geology)
H. Many areas of the City, including some highly developed industrial and commercial
areas, are located on bay alluvial soils which are subject to liquefaction in the event
of an earthquake. (Topography, Geology)
I. The United Nations Intergovernmental Panel on Climate Change (IPCC) has
warned that failure to address the causes of global climate change within the next
few years will result in significant sea level increases and frequency of wildland
fires, and reduced freshwater resources, which will significantly increase the cost
of providing local governmental services and protecting public infrastructure.
(Climate)
J. Sea levels could rise from as little as 2 to 3 feet if emissions trend downward, to
as much as 8.5 to 35 feet by the end of the century if emissions continue to rise in
a “business as usual” scenario. Sea level rise will expand the areas subject to
flooding and will directly impact low-lying areas of San Rafael. (Climate,
Topography)
Pursuant to Health and Safety Code Section 17958, 17958.5, and 17958.7, the San Rafael City
Council hereby expressly finds that the local amendments to the building standards within the
California Building Standards Code in Title 24 of the California Code of Regulations are necessary
for the protection of public health, safety, and welfare, due to the following local climatic, geologic,
or topographical conditions:
Code Sections Findings
CBC 202
903.2
909.2
1011.6
1015.2
1015.8.2
1015,8,3
1505.1.1
1505.1.2
1807.4
3110
A, B, C, D, E, G, H, J, K
A, B, C, D, E, F, H, J
A, B, C, D, E, F, H, J
A, B, C, D, E, F, H, J
H
H
H
A, B, C, D, E, F, H, J
A, B, C, D, E, F, H, J
A, B, C, D, E, G, H, J, K
A, B, C, D, E, F, H, J
CBC
Appendices
C
G
H
A, B, C, D, E, F, H, J
G, H, I, J
H
4896-5923-3369 v2 19
I
N
O
A, B, C, D, E, F, H, J
J, K
J, K
CEBC 505.2.1
505.2.2
H
H
CPC
Appendices
A
C
D
I
F, J, K
F, J, K
F, J, K
F, J, K
CRC R202
R309.1
R309.2
R309.3.1.2
R310.7.2
R902.1.1
R902.1.2
A, B, C, D, E, G, H, J, K
A, B, C, D, E, F, H, J
A, B, C, D, E, F, H, J
A, B, C, D, E, F, H, J
A, B, C, D, E, F, H, J
A, B, C, D, E, F, H, J
A, B, C, D, E, F, H, J
CRC
Appendices
BB
BF
BG
BI
BJ
BK
BL
BM
BO
CI
A, B, C, D, E, F, H, J
A, B, C, D, E, F, H, J
A, B, C, D, E, F, H, J
A, B, C, D, E, F, H, J
A, B, C, D, E, F, H, J
A, B, C, D, E, F, H, J
A, B, C, D, E, F, H, J
A, B, C, D, E, F, H, J
A, B, C, D, E, F, H, J
A, B, C, D, E, F, H, J
In addition, the City Council finds that:
1. The 2025 California Building Standards Code is scheduled to take effect statewide on
January 1, 2026.
2. Cities are empowered to adopt local amendments to the code before the effective date of
the new code so that the adopted amendments may be implemented concurrently with the
state Code.
3. This ordinance is in effect as of September 30, 2025, and will be implemented with the
state Code on January 1, 2026.
4. Changes to the Building and Energy Codes, including Reach Codes, are substantially
equivalent to those previously filed and in effect as of September 30, 2025.
5. Changes to the Building and Energy Codes, including Reach Codes are necessary to
implement a local code amendment adopted to align with the City of San Rafael’s General
Plan 2040, approved before June 10, 2025, and permits mixed-fuel residential
construction consistent with Federal law, while also incentivizing all-electric construction
as part of the City’s Greenhouse Gas Reduction Strategy.
6. Changes to the Building and Energy Codes, including Reach Codes, have been
determined at a regular Council meeting to be cost-effective and will require buildings to
be designed to consume less energy than permitted by the California Energy Code as
demonstrated by the 2022 Cost-Effectiveness Study: Single Family Building Upgrades
and subsequent Memos commissioned by the California Statewide Energy Codes and
Standards Program, including Cost-Effectiveness Explorer Evidence City-of-San-Rafael.
4896-5923-3369 v2 20
DIVISION 3. CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)
This Ordinance is exempt from the California Environmental Quality Act (CEQA), pursuant to 14
CCR Section 15061(b)(3), since it can be seen with certainty that there is no possibility that the
adoption of this Ordinance may have a significant effect on the environment. (14 Cal. Code Regs.
Section 15061(b)(3), ‘general rule’ provision).
DIVISION 4 SEVERABILITY.
If any section, subsection, sentence, 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 of this Ordinance.
The City Council of the City of San Rafael 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 shall be declared
invalid.
DIVISION 5. EFFECTIVE DATE OF ORDINANCE.
This Ordinance shall be published once, in full or in summary form, before its final passage, in a
newspaper of general circulation, published and circulated in the City of San Rafael, and shall be
operative and implemented on January 1, 2026, to coincide with the effective date of the 2025
California Building Standards Code statewide. If published in summary form, the summary shall
also be published within fifteen (15) days after the adoption, together with the names of those
Council members voting for or against the same, in a newspaper of general circulation published
and circulated in the City of San Rafael, County of Marin, State of California.
THE FOREGOING ORDINANCE was first read and introduced at a regular meeting of the San
Rafael City Council on the 18th day of August 2025, and was passed and adopted at a regular
meeting of the San Rafael City Council on the 2nd day of September 2025 by the following vote, to
wit:
AYES: COUNCILMEMBERS:
NOES: COUNCILMEMBERS:
ABSENT: COUNCILMEMBERS:
______________________________
Kate Colin, Mayor
Attest:
_____________________________
LINDSAY LARA, City Clerk
Cost-Effectiveness Results Summary
City of San Rafael
Climate Zone 2
Generated August 20, 2025 by the Cost-Effectiveness Explorer
https://explorer.localenergycodes.com/policies/4876/documents?per_component_name=PolicyExistingBuildingsWithFlexiblePathRequirements&per_climate_zone_raw=2-MCE&per_c
LEGAL NOTICE: This tool was prepared by Pacific Gas and Electric Company and funded by the California utility customers under the auspices of the California Public
Utilities Commission. Copyright 2025, Pacific Gas and Electric Company. All rights reserved, except that information from this tool may be used, copied, and
distributed without modification. Neither PG&E nor any of its employees makes any warranty, express or implied; or assumes any legal liability or responsibility for
the accuracy, completeness or usefulness of any data, information, method, product, policy or process disclosed in this tool; or represents that its use will not infringe
any privately-owned rights including, but not limited to, patents, trademarks or copyrights.
Cost-Effectiveness Results Summary
City of San Rafael
Generated August 20, 2025 by the Cost-Effectiveness Explorer Cost-Effectiveness Evidence
Single Family | Climate Zone 2
Pre-1978 | Existing Single Family Building Upgrades ¹ | Release Date: May 23, 2024
Maximum Cost-Effective Target Score Calculation
Cost-Effective Measures and Packages Energy
Savings
site MMBtu/year
Flexible
Score
R-30 Raised Floor Insulation 9.03 9
New Ducts, R-8 Insulation + Duct Sealing 8.48 8
R-13 Wall Insulation 6.29 6
R-49 Attic insulation 5.81 6
(On-Bill (2025))
29.61
Maximum Cost-Effective Score
The maximum cost-effective score is the highest flexible score that can be met
cost-effectively, based on the energy savings of measures for your policy. Any required
flexible score that falls below or is equal to this maximum score has a cost-effective
pathway available to permit applicants.
Cost-Effectiveness Results Summary
City of San Rafael
Generated August 20, 2025 by the Cost-Effectiveness Explorer Cost-Effectiveness Evidence
Single Family | Climate Zone 2
1978-1991 | Existing Single Family Building Upgrades ¹ | Release Date: May 23, 2024
Maximum Cost-Effective Target Score Calculation
Cost-Effective Measures and Packages Energy
Savings
site MMBtu/year
Flexible
Score
R-30 Raised Floor Insulation 8.80 9
New Ducts, R-8 Insulation + Duct Sealing 5.93 6
R-49 Attic insulation 2.45 2
(On-Bill (2025))
17.18
Maximum Cost-Effective Score
The maximum cost-effective score is the highest flexible score that can be met
cost-effectively, based on the energy savings of measures for your policy. Any required
flexible score that falls below or is equal to this maximum score has a cost-effective
pathway available to permit applicants.
Sources
1 Existing Single Family Building Upgrades (May 23, 2024)
https://localenergycodes.com/download/1222/file_path/fieldList/Single%20Family%20Retrofits%20CostEff%20Report.pdf
Generated August 20, 2025 by the Cost-Effectiveness Explorer
https://explorer.localenergycodes.com/policies/4876/documents?per_component_name=PolicyExistingBuildingsWithFlexiblePathRequirements&per_climate_zone_raw=2-MCE&per_c
LEGAL NOTICE: This tool was prepared by Pacific Gas and Electric Company and funded by the California utility customers under the auspices of the California Public
Utilities Commission. Copyright 2025, Pacific Gas and Electric Company. All rights reserved, except that information from this tool may be used, copied, and
distributed without modification. Neither PG&E nor any of its employees makes any warranty, express or implied; or assumes any legal liability or responsibility for
the accuracy, completeness or usefulness of any data, information, method, product, policy or process disclosed in this tool; or represents that its use will not infringe
any privately-owned rights including, but not limited to, patents, trademarks or copyrights.
Application of the 2022
Studies to the 2025
Energy Code: Existing Single Family Building Upgrades
Prepared by:
Frontier Energy, Inc
Misti Bruceri & Associates, LLC
Prepared for:
Kelly Cunningham, Codes and
Standards Program, Pacific Gas
and Electric
Revision: 1.0
Last modified: 2025/08/15
2025 Energy Code: Existing Single Family Building Upgrades
1
2025/08/15
Table 1 Summary of Revisions
Date Description Reference (page or section)
8/15/2025 Original Release N/A
Legal Notice
This report was prepared by
Pacific Gas and Electric Company
and funded by the California utility
customers under the auspices of
the California Public Utilities
Commission.
Copyright 2025, Pacific Gas and
Electric Company. All rights
reserved, except that this
document may be used, copied,
and distributed without
modification.
Neither PG&E nor any of its
employees makes any warranty,
express or implied; or assumes
any legal liability or responsibility
for the accuracy, completeness or
usefulness of any data,
information, method, product,
policy or process disclosed in this
document; or represents that its
use will not infringe any privately-
owned rights including, but not
limited to, patents, trademarks or
copyrights.
2025 Energy Code: Existing Single Family Building Upgrades
2
2025/08/15
Acronym List
B/C – Lifecycle Benefit-to-Cost
Ratio
CASE – Codes and Standards
Enhancement
CFL – Compact Fluorescent
Lamps
CPAU – City of Palo Alto Utilities
CPUC – California Public Utilities
Commission
CZ – California Climate Zone
kWh – Kilowatt Hour
NPV – Net Present Value
PG&E – Pacific Gas and Electric
Company
PV – Photovoltaic
SCE – Southern California
Edison
SDG&E – San Diego Gas and
Electric
SMUD – Sacramento Municipal
Utility District
SoCalGas – Southern California
Gas Company
Therm – Unit for quantity of heat
that equals 100,000 British
thermal units
2025 Energy Code: Existing Single Family Building Upgrades
1
2025/08/15
Table of Contents
1 Summary ...................................................................................................................... 2
2 Air Sealing at the Ceiling ............................................................................................. 4
3 Lighting Measures ..................................................................................................... 10
4 Water Heating Package .............................................................................................. 14
5 PV ................................................................................................................................ 15
6 References ................................................................................................................. 22
List of Tables
Table 1 Summary of Revisions ............................................................................................. 1
Table 2. [Pre-1978] Air Sealing at the Ceiling (Std) ............................................................... 4
Table 3. [1978-1991] Air Sealing at the Ceiling (Std) ............................................................ 5
Table 4. [1992-2010] Air Sealing at the Ceiling (Std) ............................................................ 6
Table 5. [Pre-1978] Air Sealing at the Ceiling (CARE) .......................................................... 7
Table 6. [1978-1991] Air Sealing at the Ceiling (CARE) ........................................................ 8
Table 7. [1991-2010] Air Sealing at the Ceiling (CARE) ........................................................ 9
Table 8. [All Vintages] LED Lamp vs. CFL ........................................................................... 11
Table 9. [All Vintages] Exterior Photosensor ........................................................................12
Table 10. [All Vintages] LED and Photosensor ....................................................................13
Table 11. [All Vintages] Water Heating Package ..................................................................14
Table 12. [Pre-1978] 3 kW PV without Solar Tax Credit (Std) ..............................................16
Table 13. [1978-1991] 3 kW PV without Solar Tax Credit (Std) ...........................................17
Table 14. [1992-2010] 3 kW PV without Solar Tax Credit (Std) ............................................18
Table 15. [Pre-1978] 3 kW PV without Solar Tax Credit (CARE) ..........................................19
Table 16. [1978-1991] 3 kW PV without Solar Tax Credit (CARE) .......................................20
Table 17. [1992-2010] 3 kW PV without Solar Tax Credit (CARE) .......................................21
List of Figures
No table of figures entries found.
2025 Energy Code: Existing Single Family Building Upgrades
2
2025/08/15
1 Summary
The California Codes and Standards (C&S) Reach Codes program provides technical
support to local governments considering adopting a local ordinance (reach code) intended
to support meeting local and/or statewide energy efficiency and greenhouse gas reduction
goals. The program facilitates adoption and implementation of the code when requested by
local jurisdictions by providing resources such as cost-effectiveness studies, model
language, sample findings, and other supporting documentation.
In April 2024, the Statewide Reach Codes Team published the 2022 Cost-Effectiveness
Study: Existing Single Family Building Upgrades. This study focuses on existing single
family buildings identifying cost-effective measures and measure package upgrades in all 16
California climate zones. The study was conducted to complement Part 6 of the California
Building Code (the Energy Code) for the 2022 code cycle, effective January 1, 2023. In the
2019 code cycle the 2019 Cost-Effectiveness Study: Existing Single Family Residential
Building Upgrades study included outdoor lighting and a water heater package that was
discontinued in the 2022 study but has been brought back in this memo by request from
jurisdictions. The studies document the estimated costs, benefits, energy impacts and
greenhouse gas emission reductions that may result from implementing an ordinance to
help local leadership, residents, and other stakeholders make informed policy decisions.
The Statewide Reach Codes Team reviewed the cost-effectiveness study for impacts of
code changes implemented in the 2025 Energy Code. Measures that are now required by
code may alter the results presented in the 2022 study. Below is a summary of the changes
to the additions and alterations for residential buildings sections of the 2025 Energy Code.
• Mandatory wall insulation R-value has been increased from R-13 to R-15. [Section
150.2(a) of the Energy Code]
• Prescriptive window U-factor has decreased from 0.30 to 0.27 in Climate Zones 1-5,
11 -14, and 16. [Section 150.2(b)1B of the Energy Code]
The wall insulation measure has been re-evaluated with R-15 instead of R-13. There is
generally a slight increase in utility cost savings as expected with the increase in efficiency.
However, there is not a substantial impact on the cost-effectiveness results.
For the prescriptive window U-factor, the original study modeled U-0.28 in all climate zones.
This updated memo drops the U-factor from 0.28 to 0.27 in all climate zones. The SHGC is
maintained at 0.23 for climate zone 2, 4, and 6-15 and 0.35 for CZ 1, 3, 5, 16. There is
minimal impact on the cost-effectiveness results due to this update. However, there are two
instances in the 1978-1991 vintage where cost-effectiveness flips from cost-effective to not
cost-effective. Climate zone 4 in PGE territory utilizing standard rates and the modest gas
escalation is no longer cost-effective on-bill by the smallest margin. Climate zone 10 in
SDGE territory utilizing CARE rates and the modest gas escalation has also become no
longer cost-effective on-bill.
2025 Energy Code: Existing Single Family Building Upgrades
3
2025/08/15
The 2022 study included a whole building air sealing measure defined as a 30% reduction in
air leakage. A new measure – air sealing of the ceiling floor, representing a 14% reduction in
air leakage – is added in this memo. Further details and cost-effectiveness results are
provided in Section 2.
Lighting measures were previously presented in the 2019 Cost-Effectiveness Study: Existing
Single Family Residential Building Upgrades study but were not analyzed in the 2022 study.
Updated cost-effectiveness analysis for this measure is presented in Section 3.
The water heating package measure was previously presented in 2019 Cost-Effectiveness
Study: Existing Single Family Residential Building Upgrades study. Updated cost-
effectiveness analysis for this measure is presented in Section 4.
The 3 kW PV measure from the 2022 study is revised here with an updated cost-
effectiveness analysis that accounts for the elimination of the Federal Solar tax credit
December 31, 2025. Additional details and analysis are provided in Section 5.
The 2022 report, model ordinance language and other resources are posted on the C&S
Reach Codes Program website at LocalEnergyCodes.com. Local jurisdictions that are
considering adopting an ordinance may contact the program for further technical support at
info@localenergycodes.com.
2025 Energy Code: Existing Single Family Building Upgrades
4
2025/08/15
2 Air Sealing at the Ceiling
Unlike full air sealing, which has previously been presented, air sealing of the ceiling floor
may be an attractive measure for an attic remodel project. The whole building air sealing
measure estimated a 30% reduction in air leakage, while air sealing at the ceiling measure
results in a 14% reduction in air leakage.
Table 2 through Table 7 present the cost-effectiveness results for the air sealing at the
ceiling plane measure. The estimated incremental cost for air sealing at the ceiling plane is
$1,963 which is from the 2022 Residential Additions and Alterations CASE Report
(Statewide CASE Team, 2020).
Table 2. [Pre-1978] Air Sealing at the Ceiling (Std)
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025
LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $1,963 $33 ($465) ($997) ($432)
CZ02 PGE $1,963 $18 ($1,114) ($1,433) ($1,118)
CZ03 PGE $1,963 $17 ($1,180) ($1,463) ($1,171)
CZ04 PGE $1,963 $25 ($1,081) ($1,290) ($979)
CZ04 CPAU $1,963 $21 ($1,081) ($1,379) ($1,069)
CZ05 PGE $1,963 $16 ($1,230) ($1,500) ($1,235)
CZ05 PGE/SCG $1,963 $14 ($1,230) ($1,555) ($1,325)
CZ06 SCE/SCG $1,963 ($2) ($1,797) ($1,987) ($1,937)
CZ07 SDGE $1,963 ($3) ($1,813) ($2,008) ($1,934)
CZ08 SCE/SCG $1,963 $7 ($1,680) ($1,775) ($1,703)
CZ09 SCE/SCG $1,963 $10 ($1,597) ($1,693) ($1,592)
CZ10 SCE/SCG $1,963 $17 ($1,497) ($1,540) ($1,420)
CZ10 SDGE $1,963 $23 ($1,497) ($1,366) ($1,237)
CZ11 PGE $1,963 $32 ($1,014) ($1,120) ($816)
CZ12 PGE $1,963 $22 ($1,147) ($1,348) ($1,064)
CZ12 SMUD/PGE $1,963 $17 ($1,147) ($1,468) ($1,190)
CZ13 PGE $1,963 $31 ($1,114) ($1,162) ($918)
CZ14 SCE/SCG $1,963 $32 ($897) ($1,130) ($832)
CZ14 SDGE $1,963 $42 ($897) ($845) ($519)
CZ15 SCE/SCG $1,963 $40 ($1,297) ($1,041) ($946)
CZ16 PGE $1,963 $30 ($581) ($1,071) ($551)
2025 Energy Code: Existing Single Family Building Upgrades
5
2025/08/15
Table 3. [1978-1991] Air Sealing at the Ceiling (Std)
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025
LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $1,963 $23 ($931) ($1,292) ($903)
CZ02 PGE $1,963 $13 ($1,364) ($1,570) ($1,341)
CZ03 PGE $1,963 $10 ($1,480) ($1,668) ($1,496)
CZ04 PGE $1,963 $16 ($1,330) ($1,522) ($1,292)
CZ04 CPAU $1,963 $13 ($1,330) ($1,575) ($1,356)
CZ05 PGE $1,963 $11 ($1,447) ($1,649) ($1,466)
CZ05 PGE/SCG $1,963 $10 ($1,447) ($1,684) ($1,522)
CZ06 SCE/SCG $1,963 ($1) ($1,830) ($1,967) ($1,934)
CZ07 SDGE $1,963 ($4) ($1,896) ($2,040) ($1,991)
CZ08 SCE/SCG $1,963 $4 ($1,797) ($1,860) ($1,813)
CZ09 SCE/SCG $1,963 $5 ($1,747) ($1,823) ($1,764)
CZ10 SCE/SCG $1,963 $10 ($1,663) ($1,722) ($1,652)
CZ10 SDGE $1,963 $14 ($1,663) ($1,603) ($1,517)
CZ11 PGE $1,963 $25 ($1,264) ($1,320) ($1,096)
CZ12 PGE $1,963 $16 ($1,380) ($1,520) ($1,314)
CZ12 SMUD/PGE $1,963 $12 ($1,380) ($1,604) ($1,402)
CZ13 PGE $1,963 $23 ($1,364) ($1,373) ($1,199)
CZ14 SCE/SCG $1,963 $22 ($1,230) ($1,397) ($1,182)
CZ14 SDGE $1,963 $28 ($1,230) ($1,212) ($974)
CZ15 SCE/SCG $1,963 $32 ($1,463) ($1,225) ($1,154)
CZ16 PGE $1,963 $21 ($1,014) ($1,357) ($1,001)
2025 Energy Code: Existing Single Family Building Upgrades
6
2025/08/15
Table 4. [1992-2010] Air Sealing at the Ceiling (Std)
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025
LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $1,963 $14 ($1,314) ($1,550) ($1,309)
CZ02 PGE $1,963 $9 ($1,530) ($1,687) ($1,529)
CZ03 PGE $1,963 $7 ($1,613) ($1,744) ($1,618)
CZ04 PGE $1,963 $11 ($1,530) ($1,653) ($1,501)
CZ04 CPAU $1,963 $9 ($1,530) ($1,701) ($1,557)
CZ05 PGE $1,963 $7 ($1,613) ($1,759) ($1,637)
CZ05 PGE/SCG $1,963 $6 ($1,613) ($1,788) ($1,686)
CZ06 SCE/SCG $1,963 $1 ($1,863) ($1,936) ($1,911)
CZ07 SDGE $1,963 $0 ($1,896) ($1,944) ($1,911)
CZ08 SCE/SCG $1,963 $3 ($1,830) ($1,885) ($1,851)
CZ09 SCE/SCG $1,963 $3 ($1,780) ($1,892) ($1,853)
CZ10 SCE/SCG $1,963 $6 ($1,763) ($1,814) ($1,767)
CZ10 SDGE $1,963 $8 ($1,763) ($1,741) ($1,681)
CZ11 PGE $1,963 $14 ($1,530) ($1,581) ($1,437)
CZ12 PGE $1,963 $10 ($1,580) ($1,693) ($1,560)
CZ12 SMUD/PGE $1,963 $8 ($1,580) ($1,737) ($1,606)
CZ13 PGE $1,963 $12 ($1,580) ($1,643) ($1,531)
CZ14 SCE/SCG $1,963 $12 ($1,530) ($1,639) ($1,503)
CZ14 SDGE $1,963 $16 ($1,530) ($1,537) ($1,382)
CZ15 SCE/SCG $1,963 $17 ($1,680) ($1,572) ($1,532)
CZ16 PGE $1,963 $14 ($1,314) ($1,556) ($1,314)
2025 Energy Code: Existing Single Family Building Upgrades
7
2025/08/15
Table 5. [Pre-1978] Air Sealing at the Ceiling (CARE)
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025
LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $1,963 $26 ($465) ($1,212) ($766)
CZ02 PGE $1,963 $14 ($1,114) ($1,550) ($1,302)
CZ03 PGE $1,963 $13 ($1,180) ($1,574) ($1,343)
CZ04 PGE $1,963 $18 ($1,081) ($1,459) ($1,216)
CZ04 CPAU $1,963 $0 ($1,081) ($1,963) ($1,963)
CZ05 PGE $1,963 $12 ($1,230) ($1,604) ($1,395)
CZ05 PGE/SCG $1,963 $11 ($1,230) ($1,648) ($1,467)
CZ06 SCE/SCG $1,963 ($1) ($1,797) ($1,969) ($1,928)
CZ07 SDGE $1,963 ($1) ($1,813) ($1,976) ($1,918)
CZ08 SCE/SCG $1,963 $5 ($1,680) ($1,824) ($1,768)
CZ09 SCE/SCG $1,963 $8 ($1,597) ($1,764) ($1,686)
CZ10 SCE/SCG $1,963 $12 ($1,497) ($1,659) ($1,566)
CZ10 SDGE $1,963 $16 ($1,497) ($1,546) ($1,443)
CZ11 PGE $1,963 $23 ($1,014) ($1,353) ($1,116)
CZ12 PGE $1,963 $17 ($1,147) ($1,503) ($1,279)
CZ12 SMUD/PGE $1,963 $11 ($1,147) ($1,623) ($1,406)
CZ13 PGE $1,963 $22 ($1,114) ($1,394) ($1,205)
CZ14 SCE/SCG $1,963 $23 ($897) ($1,352) ($1,120)
CZ14 SDGE $1,963 $30 ($897) ($1,163) ($905)
CZ15 SCE/SCG $1,963 $27 ($1,297) ($1,334) ($1,266)
CZ16 PGE $1,963 $24 ($581) ($1,270) ($859)
2025 Energy Code: Existing Single Family Building Upgrades
8
2025/08/15
Table 6. [1978-1991] Air Sealing at the Ceiling (CARE)
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025
LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $1,963 $18 ($931) ($1,442) ($1,135)
CZ02 PGE $1,963 $10 ($1,364) ($1,658) ($1,477)
CZ03 PGE $1,963 $8 ($1,480) ($1,734) ($1,598)
CZ04 PGE $1,963 $12 ($1,330) ($1,627) ($1,446)
CZ04 CPAU $1,963 $0 ($1,330) ($1,963) ($1,963)
CZ05 PGE $1,963 $8 ($1,447) ($1,719) ($1,575)
CZ05 PGE/SCG $1,963 $7 ($1,447) ($1,746) ($1,619)
CZ06 SCE/SCG $1,963 ($0) ($1,830) ($1,959) ($1,933)
CZ07 SDGE $1,963 ($2) ($1,896) ($2,003) ($1,964)
CZ08 SCE/SCG $1,963 $3 ($1,797) ($1,886) ($1,848)
CZ09 SCE/SCG $1,963 $4 ($1,747) ($1,859) ($1,813)
CZ10 SCE/SCG $1,963 $7 ($1,663) ($1,790) ($1,736)
CZ10 SDGE $1,963 $10 ($1,663) ($1,710) ($1,641)
CZ11 PGE $1,963 $18 ($1,264) ($1,500) ($1,325)
CZ12 PGE $1,963 $12 ($1,380) ($1,631) ($1,469)
CZ12 SMUD/PGE $1,963 $8 ($1,380) ($1,716) ($1,558)
CZ13 PGE $1,963 $16 ($1,364) ($1,545) ($1,411)
CZ14 SCE/SCG $1,963 $16 ($1,230) ($1,545) ($1,378)
CZ14 SDGE $1,963 $20 ($1,230) ($1,422) ($1,233)
CZ15 SCE/SCG $1,963 $22 ($1,463) ($1,460) ($1,410)
CZ16 PGE $1,963 $16 ($1,014) ($1,491) ($1,211)
2025 Energy Code: Existing Single Family Building Upgrades
9
2025/08/15
Table 7. [1991-2010] Air Sealing at the Ceiling (CARE)
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
First-year
Utility
Savings
Lifecycle NPV Savings
2025
LSC NPV
On-Bill NPV
Modest Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $1,963 $11 ($1,314) ($1,642) ($1,452)
CZ02 PGE $1,963 $7 ($1,530) ($1,749) ($1,625)
CZ03 PGE $1,963 $6 ($1,613) ($1,793) ($1,693)
CZ04 PGE $1,963 $8 ($1,530) ($1,729) ($1,609)
CZ04 CPAU $1,963 $0 ($1,530) ($1,963) ($1,963)
CZ05 PGE $1,963 $5 ($1,613) ($1,804) ($1,708)
CZ05 PGE/SCG $1,963 $5 ($1,613) ($1,827) ($1,747)
CZ06 SCE/SCG $1,963 $1 ($1,863) ($1,940) ($1,920)
CZ07 SDGE $1,963 $0 ($1,896) ($1,944) ($1,918)
CZ08 SCE/SCG $1,963 $2 ($1,830) ($1,905) ($1,879)
CZ09 SCE/SCG $1,963 $2 ($1,780) ($1,908) ($1,878)
CZ10 SCE/SCG $1,963 $4 ($1,763) ($1,855) ($1,819)
CZ10 SDGE $1,963 $6 ($1,763) ($1,805) ($1,758)
CZ11 PGE $1,963 $10 ($1,530) ($1,685) ($1,572)
CZ12 PGE $1,963 $7 ($1,580) ($1,759) ($1,654)
CZ12 SMUD/PGE $1,963 $5 ($1,580) ($1,802) ($1,700)
CZ13 PGE $1,963 $9 ($1,580) ($1,732) ($1,644)
CZ14 SCE/SCG $1,963 $9 ($1,530) ($1,722) ($1,615)
CZ14 SDGE $1,963 $11 ($1,530) ($1,652) ($1,529)
CZ15 SCE/SCG $1,963 $12 ($1,680) ($1,696) ($1,667)
CZ16 PGE $1,963 $11 ($1,314) ($1,645) ($1,454)
2025 Energy Code: Existing Single Family Building Upgrades
10
2025/08/15
3 Lighting Measures
LED lighting and exterior lighting control measures were previously evaluated in the 2019
Cost-Effectiveness Study: Existing Single Family Residential Building Upgrades study.
These measures are not included in the 2022 Cost-Effectiveness Study: Existing Single
Family Building Upgrades study, but have been re-evaluated and included in this memo.
The updated analysis follows the same methodology as the 2019 study, but with updated
costs for equipment and updated utility rates.
The three measures evaluated are LED lighting, exterior photosensor, and LED lighting plus
photosensor. Table 8 through Table 10 show the results for the different lighting measures
evaluated. Each measure is explained in more detail below.
LED Lighting: Replace screw-in (A-based for lamps) incandescent lamps and compact
fluorescent lamps (CFLs) with light-emitting diode (LED) A-lamps. This analysis was
conducted external to the energy model and evaluated replacement of a 13 W CFL lamp
with an 9.6 W LED lamp operating 620 hours annually. Annual hour estimates were based
on whole building average hours of operation from a 2010 lighting study by KEMA (KEMA,
2010). Lifetime assumptions were 10,000 hours for CFLs and 25,000 hours for LED lamps.
For incremental cost calculations it was assumed CFLs have a lifetime of 15 years, are
installed five years prior to the retrofit, and would need to be replaced at year ten and 25.
Exterior Lighting Controls/Photosensor: Evaluation of exterior lighting controls was
completed on a per-luminaire basis external to the energy model and assumes a screw-in
photosensor control is installed in outdoor lighting luminaires. Energy savings of 12.1 kWh
per year was applied based on analysis done by the Consortium for Energy Efficiency,
assuming LED lamps, 2.6 hours per day of operation, and that photosensor controls reduce
operating hours on average 20 percent each day (CEE, 2014). Energy savings will be
higher for incandescent or CFL luminaires.
Exterior Lighting Controls/Photosensor+LED: An additional evaluation was completed
for exterior lighting controls on a per-luminaire basis external to the energy model and
assumes a screw-in photosensor control is installed in outdoor lighting luminaires and
incandescent lamps CFLs are replaced with light-emitting diode (LED) A-lamps. Energy
savings of 14.3 kWh per year was applied based on the sum of the LED lighting and
Exterior Lighting Controls with Photosensor kWh energy savings.
For the measures including a LED, a cost of $3.49 for LED dimmable A19 lamp 60 W
equivalent is used. A cost of $1.74 is used for an equivalent CFL product which was used to
estimate total replacement costs at years 10 and 25. Costs are based on a single LED lamp
replacement. For the photosensor, an incremental cost of $12.62, based on a screw-in
photosensor control, was obtained from an on-line product search of available products. A
five-year lifetime for this type of control was assumed.
2025 Energy Code: Existing Single Family Building Upgrades
11
2025/08/15
Table 8. [All Vintages] LED Lamp vs. CFL
Climate
Zone
Electric/ Gas
Utility
Measure
Cost
Electricity
Savings
First Year
Utility
Cost
Savings
Customer On-Bill
Modest Gas Escalation
Customer On-Bill
High Gas Escalation
B/C Ratio NPV B/C Ratio NPV
CZ01 PGE $1.75 2.2 $0.77 10.05 $15.82 10.58 $16.74
CZ02 PGE $1.75 2.2 $0.86 11.26 $17.94 11.85 $18.98
CZ03 PGE $1.75 2.2 $0.78 10.14 $15.99 10.68 $16.92
CZ04 PGE $1.75 2.2 $0.80 10.39 $16.42 10.94 $17.38
CZ04 CPAU $1.75 2.2 $0.41 5.32 $7.56 5.60 $8.05
CZ05 PGE $1.75 2.2 $0.78 10.14 $15.99 10.67 $16.92
CZ05 PGE/SCG $1.75 2.2 $0.78 10.14 $15.99 10.67 $16.92
CZ06 SCE/SCG $1.75 2.2 $0.66 8.44 $13.01 8.99 $13.97
CZ07 SDGE $1.75 2.2 $0.95 13.15 $21.24 13.03 $21.04
CZ08 SCE/SCG $1.75 2.2 $0.74 9.51 $14.89 10.14 $15.98
CZ09 SCE/SCG $1.75 2.2 $0.71 9.17 $14.29 9.77 $15.33
CZ10 SCE/SCG $1.75 2.2 $0.73 9.38 $14.65 9.99 $15.72
CZ10 SDGE $1.75 2.2 $1.07 14.86 $24.24 14.74 $24.02
CZ11 PGE $1.75 2.2 $0.85 11.05 $17.57 11.63 $18.59
CZ12 PGE $1.75 2.2 $0.79 10.32 $16.29 10.86 $17.24
CZ12 SMUD/PGE $1.75 2.2 $0.47 6.08 $8.88 6.40 $9.44
CZ13 PGE $1.75 2.2 $0.86 11.27 $17.96 11.86 $19.00
CZ14 SCE/SCG $1.75 2.2 $0.74 9.58 $15.00 10.21 $16.10
CZ14 SDGE $1.75 2.2 $1.06 14.68 $23.93 14.56 $23.71
CZ15 SCE/SCG $1.75 2.2 $0.78 10.01 $15.75 10.66 $16.90
CZ16 PGE $1.75 2.2 $0.77 9.98 $15.71 10.51 $16.62
2025 Energy Code: Existing Single Family Building Upgrades
12
2025/08/15
Table 9. [All Vintages] Exterior Photosensor
Climate
Zone
Electric/ Gas
Utility
Measure
Cost
Electricity
Savings
First Year
Utility
Cost
Savings
Customer On-Bill
Modest Gas Escalation
Customer On-Bill
High Gas Escalation
B/C Ratio NPV B/C
Ratio NPV
CZ01 PGE $54.03 12.1 $4.16 1.75 $40.75 1.85 $45.74
CZ02 PGE $54.03 12.1 $4.16 1.75 $40.75 1.85 $45.74
CZ03 PGE $54.03 12.1 $4.16 1.75 $40.75 1.85 $45.74
CZ04 PGE $54.03 12.1 $4.16 1.75 $40.75 1.85 $45.74
CZ04 CPAU $54.03 12.1 $2.12 0.89 ($5.69) 0.94 ($3.15)
CZ05 PGE $54.03 12.1 $4.16 1.75 $40.75 1.85 $45.74
CZ05 PGE/SCG $54.03 12.1 $4.16 1.75 $40.75 1.85 $45.74
CZ06 SCE/SCG $54.03 12.1 $3.48 1.45 $24.36 1.55 $29.48
CZ07 SDGE $54.03 12.1 $5.07 2.27 $68.58 2.25 $67.53
CZ08 SCE/SCG $54.03 12.1 $3.48 1.45 $24.36 1.55 $29.48
CZ09 SCE/SCG $54.03 12.1 $3.48 1.45 $24.36 1.55 $29.48
CZ10 SCE/SCG $54.03 12.1 $3.48 1.45 $24.36 1.55 $29.48
CZ10 SDGE $54.03 12.1 $5.07 2.27 $68.58 2.25 $67.53
CZ11 PGE $54.03 12.1 $4.16 1.75 $40.75 1.85 $45.74
CZ12 PGE $54.03 12.1 $4.16 1.75 $40.75 1.85 $45.74
CZ12 SMUD/PGE $54.03 12.1 $1.46 0.62 ($20.73) 0.65 ($18.98)
CZ13 PGE $54.03 12.1 $4.16 1.75 $40.75 1.85 $45.74
CZ14 SCE/SCG $54.03 12.1 $3.48 1.45 $24.36 1.55 $29.48
CZ14 SDGE $54.03 12.1 $5.07 2.27 $68.58 2.25 $67.53
CZ15 SCE/SCG $54.03 12.1 $3.48 1.45 $24.36 1.55 $29.48
CZ16 PGE $54.03 12.1 $4.16 1.75 $40.75 1.85 $45.74
2025 Energy Code: Existing Single Family Building Upgrades
13
2025/08/15
Table 10. [All Vintages] LED and Photosensor
Climate
Zone
Electric/ Gas
Utility
Measure
Cost
Electricity
Savings
First Year
Utility Cost
Savings
Customer On-Bill
Modest Gas Escalation
Customer On-Bill High
Gas Escalation
B/C Ratio NPV B/C Ratio NPV
CZ01 PGE $55.77 14.3 $4.93 2.01 $56.57 2.12 $62.48
CZ02 PGE $55.77 14.3 $5.02 2.05 $58.70 2.16 $64.72
CZ03 PGE $55.77 14.3 $4.94 2.02 $56.74 2.12 $62.66
CZ04 PGE $55.77 14.3 $4.95 2.03 $57.17 2.13 $63.12
CZ04 CPAU $55.77 14.3 $2.53 1.03 $1.87 1.09 $4.90
CZ05 PGE $55.77 14.3 $4.94 2.02 $56.74 2.12 $62.66
CZ05 PGE/SCG $55.77 14.3 $4.94 2.02 $56.74 2.12 $62.66
CZ06 SCE/SCG $55.77 14.3 $4.13 1.67 $37.37 1.78 $43.45
CZ07 SDGE $55.77 14.3 $6.02 2.61 $89.82 2.59 $88.57
CZ08 SCE/SCG $55.77 14.3 $4.22 1.70 $39.25 1.82 $45.46
CZ09 SCE/SCG $55.77 14.3 $4.19 1.69 $38.65 1.80 $44.82
CZ10 SCE/SCG $55.77 14.3 $4.21 1.70 $39.01 1.81 $45.20
CZ10 SDGE $55.77 14.3 $6.14 2.66 $92.82 2.64 $91.55
CZ11 PGE $55.77 14.3 $5.00 2.05 $58.33 2.15 $64.33
CZ12 PGE $55.77 14.3 $4.95 2.02 $57.05 2.13 $62.98
CZ12 SMUD/PGE $55.77 14.3 $1.93 0.79 ($11.85) 0.83 ($9.54)
CZ13 PGE $55.77 14.3 $5.02 2.05 $58.71 2.16 $64.73
CZ14 SCE/SCG $55.77 14.3 $4.22 1.71 $39.37 1.82 $45.58
CZ14 SDGE $55.77 14.3 $6.13 2.66 $92.51 2.64 $91.24
CZ15 SCE/SCG $55.77 14.3 $4.26 1.72 $40.12 1.83 $46.38
CZ16 PGE $55.77 14.3 $4.92 2.01 $56.46 2.12 $62.36
2025 Energy Code: Existing Single Family Building Upgrades
14
2025/08/15
4 Water Heating Package
This package includes the following:
• R-6 water heater blanket
• R-3 hot water pipe insulation
• Low flow fixtures: two low flow showerheads and three sink aerators.
This analysis assumes the homeowner installs these measures themselves and therefore
no labor costs. Costs are based on Home Depot prices from August of 2025. The water
heater package is evaluated over a 15-year analysis period and assumes the modest gas
escalation rate.
Table 11 . [All Vintages] Water Heating Package
Climate
Zone
Electric/ Gas
Utility
Measure
Cost
Gas
Savings
(therms)
Customer On-Bill
First Year Utility
Cost Savings B/C Ratio NPV
CZ01 PGE $125.68 14.69 $31.11 3.96 $371.76
CZ02 PGE $125.68 15.60 $35.20 4.48 $437.15
CZ03 PGE $125.68 15.70 $31.43 4.00 $376.88
CZ04 PGE $125.68 16.05 $32.62 4.15 $395.78
CZ04 CPAU $125.68 16.05 $31.99 4.07 $385.77
CZ05 PGE $125.68 15.83 $31.37 3.99 $375.88
CZ05 PGE/SCG $125.68 15.83 $28.29 3.60 $326.59
CZ06 SCE/SCG $125.68 16.67 $29.18 3.71 $340.84
CZ07 SDGE $125.68 16.75 $37.25 4.74 $469.81
CZ08 SCE/SCG $125.68 16.78 $29.36 3.74 $343.80
CZ09 SCE/SCG $125.68 16.66 $29.27 3.72 $342.34
CZ10 SCE/SCG $125.68 16.58 $28.99 3.69 $337.73
CZ10 SDGE $125.68 16.58 $37.77 4.80 $478.19
CZ11 PGE $125.68 15.87 $32.96 4.19 $401.32
CZ12 PGE $125.68 15.90 $32.85 4.18 $399.47
CZ12 SMUD/PGE $125.68 15.90 $32.85 4.18 $399.47
CZ13 PGE $125.68 16.32 $33.00 4.20 $401.93
CZ14 SCE/SCG $125.68 16.11 $29.79 3.79 $350.57
CZ14 SDGE $125.68 16.11 $39.23 4.99 $501.49
CZ15 SCE/SCG $125.68 17.40 $30.16 3.84 $356.50
CZ16 PGE $125.68 15.14 $31.75 4.04 $381.87
2025 Energy Code: Existing Single Family Building Upgrades
15
2025/08/15
5 PV
The results for 3 kW PV have been updated from the 2022 study to remove the federal solar
tax credit from the cost-effectiveness calculations. The removal of the solar tax credit has a
substantial impact on many climate zones across all vintages and will impact the FlexPath.
The following describes the impacts and changes to cost-effectiveness from the 2022 study.
These observations are utilizing standard rates. Previously, with the solar tax credit, the 3
kW PV measure in the pre-1978 vintage was on-bill cost effective in all climate zones using
both the modest and high gas escalation rates. However, with the credit removed, Climate
Zones 1-3, 5, 6, and 12 are no longer cost effective on-bill for both the modest and high gas
escalations.
Previously for the 1978-1991 vintage the only cases that were not on-bill cost effective were
climate zones 2 and 6 utilizing the modest gas escalation. Now, with the credit removed,
many more climate zones are no longer cost effective. Using the modest gas escalation,
climate zones 1-3, 5, 6, 12, and 16 are not cost effective on-bill. Using the high gas
escalation, climate zones 1-3, 5, 6, and 12 (SMUD) are not cost effective on-bill.
Previously for the 1992-2010 vintage the following cases were not cost effective on-bill:
climate zones 1-3, 5, and 6 utilizing the modest gas escalation and climate zone 6 using the
high gas escalation. With the credit removed an increased number of climate zones are no
longer cost effective. Using the modest gas escalation, climate zones 1-3, 4 (PGE) 5-9, 10
(SCE/SCG),12, and 16 are not cost effective on-bill. Using the high gas escalation, climate
zones 1-3, 4 (PGE), 5-7, 9, 12, and 16 are not cost effective on-bill.
The cost-effectiveness results are presented in Table 12 through Table 1717.
2025 Energy Code: Existing Single Family Building Upgrades
16
2025/08/15
Table 12. [Pre-1978] 3 kW PV without Solar Tax Credit (Std)
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
On-Bill Savings
On-Bill B/C
Modest Gas
Escalation
On-Bill NPV
Modest Gas
Escalation
On-Bill B/C
High Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $13,726 0.80 ($3,074) 0.85 ($2,410)
CZ02 PGE $13,726 0.80 ($3,072) 0.85 ($2,409)
CZ03 PGE $13,726 0.77 ($3,567) 0.81 ($2,930)
CZ04 PGE $13,726 1.11 $1,652 1.16 $2,564
CZ04 CPAU $13,726 1.38 $5,983 1.45 $7,123
CZ05 PGE $13,726 0.78 ($3,431) 0.82 ($2,786)
CZ05 PGE/SCG $13,726 0.78 ($3,431) 0.82 ($2,786)
CZ06 SCE/SCG $13,726 0.87 ($2,118) 0.92 ($1,231)
CZ07 SDGE $13,726 1.31 $4,886 1.30 $4,711
CZ08 SCE/SCG $13,726 1.30 $4,655 1.38 $5,984
CZ09 SCE/SCG $13,726 1.18 $2,821 1.26 $4,030
CZ10 SCE/SCG $13,726 1.29 $4,622 1.38 $5,948
CZ10 SDGE $13,726 1.99 $15,550 1.97 $15,284
CZ11 PGE $13,726 1.55 $8,684 1.64 $9,967
CZ12 PGE $13,726 1.07 $1,117 1.13 $2,002
CZ12 SMUD/PGE $13,726 0.93 ($1,109) 0.98 ($342)
CZ13 PGE $13,726 1.80 $12,597 1.90 $14,085
CZ14 SCE/SCG $13,726 1.58 $9,098 1.68 $10,717
CZ14 SDGE $13,726 2.15 $17,983 2.13 $17,695
CZ15 SCE/SCG $13,726 2.24 $19,477 2.39 $21,774
CZ16 PGE $13,726 1.04 $579 1.09 $1,435
2025 Energy Code: Existing Single Family Building Upgrades
17
2025/08/15
Table 13. [1978-1991] 3 kW PV without Solar Tax Credit (Std)
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
On-Bill Savings
On-Bill B/C
Modest Gas
Escalation
On-Bill NPV
Modest Gas
Escalation
On-Bill B/C
High Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $13,726 0.77 ($3,570) 0.81 ($2,932)
CZ02 PGE $13,726 0.71 ($4,549) 0.75 ($3,963)
CZ03 PGE $13,726 0.74 ($4,106) 0.78 ($3,497)
CZ04 PGE $13,726 1.00 $7 1.05 $833
CZ04 CPAU $13,726 1.35 $5,517 1.42 $6,633
CZ05 PGE $13,726 0.75 ($3,985) 0.79 ($3,369)
CZ05 PGE/SCG $13,726 0.75 ($3,985) 0.79 ($3,369)
CZ06 SCE/SCG $13,726 0.73 ($4,249) 0.78 ($3,501)
CZ07 SDGE $13,726 1.17 $2,623 1.16 $2,466
CZ08 SCE/SCG $13,726 1.20 $3,086 1.27 $4,313
CZ09 SCE/SCG $13,726 1.09 $1,487 1.17 $2,609
CZ10 SCE/SCG $13,726 1.18 $2,884 1.26 $4,097
CZ10 SDGE $13,726 1.85 $13,356 1.84 $13,108
CZ11 PGE $13,726 1.41 $6,420 1.48 $7,583
CZ12 PGE $13,726 0.97 ($512) 1.02 $287
CZ12 SMUD/PGE $13,726 0.93 ($1,109) 0.98 ($342)
CZ13 PGE $13,726 1.63 $9,953 1.72 $11,302
CZ14 SCE/SCG $13,726 1.42 $6,655 1.52 $8,115
CZ14 SDGE $13,726 2.00 $15,653 1.98 $15,386
CZ15 SCE/SCG $13,726 1.94 $14,686 2.06 $16,670
CZ16 PGE $13,726 0.95 ($737) 1.00 $49
2025 Energy Code: Existing Single Family Building Upgrades
18
2025/08/15
Table 1414. [1992-2010] 3 kW PV without Solar Tax Credit (Std)
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
On-Bill Savings
On-Bill B/C
Modest Gas
Escalation
On-Bill NPV
Modest Gas
Escalation
On-Bill B/C
High Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $13,726 0.71 ($4,475) 0.75 ($3,885)
CZ02 PGE $13,726 0.73 ($4,198) 0.77 ($3,593)
CZ03 PGE $13,726 0.72 ($4,411) 0.76 ($3,817)
CZ04 PGE $13,726 0.80 ($3,121) 0.84 ($2,459)
CZ04 CPAU $13,726 1.16 $2,477 1.22 $3,433
CZ05 PGE $13,726 0.73 ($4,299) 0.76 ($3,700)
CZ05 PGE/SCG $13,726 0.73 ($4,299) 0.76 ($3,700)
CZ06 SCE/SCG $13,726 0.61 ($6,143) 0.65 ($5,520)
CZ07 SDGE $13,726 0.94 ($931) 0.93 ($1,057)
CZ08 SCE/SCG $13,726 0.98 ($242) 1.05 $767
CZ09 SCE/SCG $13,726 0.88 ($1,890) 0.94 ($988)
CZ10 SCE/SCG $13,726 0.96 ($676) 1.02 $305
CZ10 SDGE $13,726 1.51 $8,054 1.50 $7,852
CZ11 PGE $13,726 1.10 $1,569 1.16 $2,477
CZ12 PGE $13,726 0.80 ($3,169) 0.84 ($2,510)
CZ12 SMUD/PGE $13,726 0.93 ($1,109) 0.98 ($342)
CZ13 PGE $13,726 1.27 $4,170 1.33 $5,215
CZ14 SCE/SCG $13,726 1.15 $2,295 1.22 $3,470
CZ14 SDGE $13,726 1.66 $10,386 1.65 $10,164
CZ15 SCE/SCG $13,726 1.37 $5,788 1.46 $7,191
CZ16 PGE $13,726 0.81 ($3,006) 0.85 ($2,338)
2025 Energy Code: Existing Single Family Building Upgrades
19
2025/08/15
Table 1515. [Pre-1978] 3 kW PV without Solar Tax Credit (CARE)
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
On-Bill Savings
On-Bill B/C
Modest Gas
Escalation
On-Bill NPV
Modest Gas
Escalation
On-Bill B/C
High Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $13,726 0.62 ($6,030) 0.65 ($5,522)
CZ02 PGE $13,726 0.64 ($5,707) 0.67 ($5,182)
CZ03 PGE $13,726 0.60 ($6,344) 0.63 ($5,853)
CZ04 PGE $13,726 0.83 ($2,725) 0.87 ($2,042)
CZ05 PGE $13,726 0.60 ($6,266) 0.63 ($5,771)
CZ05 PGE/SCG $13,726 0.60 ($6,266) 0.63 ($5,771)
CZ06 SCE/SCG $13,726 0.71 ($4,578) 0.75 ($3,852)
CZ07 SDGE $13,726 0.71 ($4,508) 0.71 ($4,604)
CZ08 SCE/SCG $13,726 0.97 ($483) 1.03 $510
CZ09 SCE/SCG $13,726 0.90 ($1,530) 0.96 ($605)
CZ10 SCE/SCG $13,726 0.97 ($465) 1.03 $530
CZ10 SDGE $13,726 1.19 $3,032 1.18 $2,872
CZ11 PGE $13,726 1.07 $1,150 1.13 $2,036
CZ12 PGE $13,726 0.79 ($3,324) 0.83 ($2,673)
CZ13 PGE $13,726 1.23 $3,587 1.29 $4,601
CZ14 SCE/SCG $13,726 1.17 $2,662 1.25 $3,861
CZ14 SDGE $13,726 1.28 $4,436 1.27 $4,264
CZ15 SCE/SCG $13,726 1.57 $8,962 1.67 $10,572
CZ16 PGE $13,726 0.79 ($3,342) 0.83 ($2,692)
2025 Energy Code: Existing Single Family Building Upgrades
20
2025/08/15
Table 1616. [1978-1991] 3 kW PV without Solar Tax Credit (CARE)
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
On-Bill Savings
On-Bill B/C
Modest Gas
Escalation
On-Bill NPV
Modest Gas
Escalation
On-Bill B/C
High Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $13,726 0.60 ($6,343) 0.63 ($5,851)
CZ02 PGE $13,726 0.56 ($6,845) 0.59 ($6,380)
CZ03 PGE $13,726 0.57 ($6,757) 0.60 ($6,287)
CZ04 PGE $13,726 0.76 ($3,715) 0.80 ($3,085)
CZ05 PGE $13,726 0.57 ($6,686) 0.60 ($6,213)
CZ05 PGE/SCG $13,726 0.57 ($6,686) 0.60 ($6,213)
CZ06 SCE/SCG $13,726 0.61 ($6,195) 0.64 ($5,575)
CZ07 SDGE $13,726 0.62 ($6,004) 0.61 ($6,087)
CZ08 SCE/SCG $13,726 0.91 ($1,483) 0.96 ($555)
CZ09 SCE/SCG $13,726 0.85 ($2,368) 0.90 ($1,497)
CZ10 SCE/SCG $13,726 0.90 ($1,597) 0.96 ($676)
CZ10 SDGE $13,726 1.10 $1,560 1.09 $1,413
CZ11 PGE $13,726 0.98 ($295) 1.03 $515
CZ12 PGE $13,726 0.72 ($4,320) 0.76 ($3,722)
CZ13 PGE $13,726 1.12 $1,893 1.18 $2,818
CZ14 SCE/SCG $13,726 1.07 $1,051 1.14 $2,144
CZ14 SDGE $13,726 1.18 $2,878 1.17 $2,719
CZ15 SCE/SCG $13,726 1.37 $5,735 1.45 $7,135
CZ16 PGE $13,726 0.74 ($4,126) 0.78 ($3,517)
2025 Energy Code: Existing Single Family Building Upgrades
21
2025/08/15
Table 1717. [1992-2010] 3 kW PV without Solar Tax Credit (CARE)
Climate
Zone
Electric/ Gas
Utility
First
Incremental
Cost
On-Bill Savings
On-Bill B/C
Modest Gas
Escalation
On-Bill NPV
Modest Gas
Escalation
On-Bill B/C
High Gas
Escalation
On-Bill NPV
High Gas
Escalation
CZ01 PGE $13,726 0.56 ($6,963) 0.59 ($6,504)
CZ02 PGE $13,726 0.26 ($11,640) 0.20 ($12,611)
CZ03 PGE $13,726 0.55 ($6,997) 0.58 ($6,540)
CZ04 PGE $13,726 0.62 ($5,900) 0.66 ($5,385)
CZ05 PGE $13,726 0.56 ($6,932) 0.59 ($6,471)
CZ05 PGE/SCG $13,726 0.56 ($6,932) 0.59 ($6,471)
CZ06 SCE/SCG $13,726 0.51 ($7,652) 0.55 ($7,127)
CZ07 SDGE $13,726 0.48 ($8,115) 0.48 ($8,180)
CZ08 SCE/SCG $13,726 0.78 ($3,430) 0.83 ($2,629)
CZ09 SCE/SCG $13,726 0.72 ($4,462) 0.76 ($3,728)
CZ10 SCE/SCG $13,726 0.76 ($3,748) 0.81 ($2,968)
CZ10 SDGE $13,726 0.86 ($2,225) 0.85 ($2,340)
CZ11 PGE $13,726 0.79 ($3,259) 0.83 ($2,605)
CZ12 PGE $13,726 0.63 ($5,876) 0.66 ($5,359)
CZ13 PGE $13,726 0.89 ($1,678) 0.94 ($941)
CZ14 SCE/SCG $13,726 0.89 ($1,676) 0.95 ($761)
CZ14 SDGE $13,726 0.95 ($838) 0.94 ($964)
CZ15 SCE/SCG $13,726 0.99 ($142) 1.06 $873
CZ16 PGE $13,726 0.63 ($5,850) 0.66 ($5,333)
2025 Energy Code: Existing Single Family Building Upgrades
22
2025/08/15
6 References
California Energy Commission. (2017). Rooftop Solar PV System. Measure number: 2019-
Res-PV-D Prepared by Energy and Environmental Economics, Inc. Retrieved from
https://efiling.energy.ca.gov/getdocument.aspx?tn=221366
California Energy Commission. (2021b). Final Express Terms for the Proposed Revisions to
the 2022 Energy Code Reference Appendices. Retrieved from
https://efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=21-BSTD-01
California Energy Commission. (2023). 2025 Energy code Hourly Factors. Retrieved from
https://www.energy.ca.gov/files/2025-energy-code-hourly-factors
California Energy Commission. (2023). Draft 2025 Energy Code Express Terms. Retrieved
from
https://efiling.energy.ca.gov/GetDocument.aspx?tn=252915&DocumentContentId=88
051
California Public Utilities Commission. (2021a). Utility Costs and Affordability of the Grid of
the Future: An Evaluation of Electric Costs, Rates, and Equity Issues Pursuant to
P.U. Code Section 913.1. Retrieved from https://www.cpuc.ca.gov/-/media/cpuc-
website/divisions/office-of-governmental-affairs-division/reports/2021/senate-bill-695-
report-2021-and-en-banc-whitepaper_final_04302021.pdf
California Public Utilities Commission. (2021b). Database for Energy-Efficient resources
(DEER2021 Update). Retrieved April 13, 2021, from
http://www.deeresources.com/index.php/deer-versions/deer2021
E-CFR. (2020). https://www.ecfr.gov/cgi-
bin/retrieveECFR?gp=&SID=8de751f141aaa1c1c9833b36156faf67&mc=true&n=pt1
0.3.431&r=PART&ty=HTML#se10.3.431_197. Retrieved from Electronic Code of
Federal Regulations: https://www.ecfr.gov/cgi-
bin/retrieveECFR?gp=&SID=8de751f141aaa1c1c9833b36156faf67&mc=true&n=pt1
0.3.431&r=PART&ty=HTML#se10.3.431_197
Statewide CASE Team. (2020). Residential Energy Savings and Process Improvements for
Additions and Alterations.
Statewide CASE Team. (2023). Multifamily Domestic Hot Water. Retrieved from
https://title24stakeholders.com/wp-content/uploads/2023/08/2025_T24_CASE-
Report-_MF-DHW-Final-1.pdf
Statewide CASE Team. (2023). Residential HVAC PErformance. Retrieved from
https://title24stakeholders.com/wp-
content/uploads/2023/11/Revised_2025_T24_Final-CASE-Report-RES-HVAC -
Performance.pdf
2025 Energy Code: Existing Single Family Building Upgrades
23
2025/08/15
Statewide Reach Codes Team. (2021). 2019 Cost-Effectiveness Study: Existing Single
Family Residential Buidling Upgrades. Retrieved from
https://localenergycodes.com/content/resources
2025 Energy Code: Existing Single Family Building Upgrades
24
2025/08/15
Get In Touch
The adoption of reach codes can differentiate
jurisdictions as efficiency leaders and help accelerate
the adoption of new equipment, technologies, code
compliance, and energy savings strategies.
As part of the Statewide Codes & Standards
Program, the Reach Codes Subprogram is a
resource available to any local jurisdiction located
throughout the state of California.
Our experts develop robust toolkits as well as provide
specific technical assistance to local jurisdictions
(cities and counties) considering adopting energy
reach codes. These include cost-effectiveness
research and analysis, model ordinance language
and other code development and implementation
tools, and specific technical assistance throughout
the code adoption process.
If you are interested in finding out more about local
energy reach codes, the Reach Codes Team stands
ready to assist jurisdictions at any stage of a reach
code project.
Visit
LocalEnergyCodes.com to
access our resources and
sign up for newsletters
Contact
info@localenergycodes.com
for no-charge assistance from
expert Reach Code advisors
Explore
The Cost-Effectiveness
Explorer is a free resource to
help California local
governments and
stakeholders develop energy
policies for buildings.
Follow
us on Linkedin
Revision: 1.0
Last modified: 2025/08/15
August 18, 2025
San Rafael City Council
1400 5th Avenue
San Rafael, CA 94901
RE: Building Code Ordinance Amendments
Honorable Mayor and Council Members,
Sustainable San Rafael appreciates the City's efforts to
strengthen the Flexpath portions of the proposed State
Building Code to bring them into closer alignment with San
Rafael's conditions and goals.
By updating scoring targets for evaluating the rehabilitation
of homes built prior to 1992, the recommended San Rafael
ordinance improves on the version adopted last year. The
approach suggested by staff is an innovative response to
recently enacted State constraints.
However, rather than zeroing out the currently required score
for homes built between 1992 and 2010, we request that the
City maintain a minimal score of 1 for those buildings.
Assuming that it satisfies State calculations, such a low score
would at least keep in place the process by which building
owners consider additional energy efficiency improvements
from the wide menu of potential improvements offered.
We applaud the City's adoption of the portions of the new
State code relating to new construction, which we understand
will encourage significantly greater electrification and energy
efficiency. It is also our understanding from the Staff Report
that the portions of the new State code relating to EV
readiness closely match the City requirements being replaced.
Thank you for the Council's commitment to a more
sustainable community, and for recognizing the importance of
building electrification in meeting our greenhouse gas goals
and in maintaining the health of our residents.
Sincerely,
William Carney,
Vice President
BOARD OF DIRECTORS
Annika Osborn, Co-President
Ben Snyder, Co-President
William Carney, Vice President
Miles Smith, Secretary
Greg Brockbank
Kay Karchevski
Kiki La Porta
Rina Lopez
Phil Muller
Marisa Nordstrom
Stuart Siegel
415.302.0110