Approval of Local Energy Efficiency and Conservation Standards Application Findings Submitted by the City of Palo Alto for the 2025 Energy Code Cycle

The California Energy Commission (CEC) adopts and regularly updates regulations that define a process for local governments to apply to the CEC to make certain findings regarding locally adopted energy conservation or energy insulation standards (CCR, Title 24, Part 1, section 10-106 and section 10-110; Public Resources Code section 25402.1(h)(2)). The local government’s proposed standards are often referred to as the Local Reach Codes and require local governments submit an application to the CEC consistent with the requirements listed in section 10-106(b). Before the local standards may be enforced, the CEC must make two non-discretionary findings pursuant to PRC section 25402.1(h)(2) and as listed in section 10-106(a): 1) The proposed local standards will require the diminution of energy consumption levels compared to the 2022 Energy Code, and 2) The local government has filed the basis of its cost-effectiveness determination with the CEC. On September 25, 2025, the City of Palo Alto (the City) submitted an application to the CEC that included: 1) the basis of its determination that the locally adopted energy efficiency standards contained in Ordinance No. 5665 are cost-effective; and (2) documentation that the locally adopted energy efficiency standards contained in Ordinance No. 5665 will require the diminution of energy consumption levels compared to the 2025 Building Energy Efficiency Standards (Energy Code), as required by PRC section 25402.1(h)(2) and by CCR, Title 24, Part 1, section 10-106 (section 10-106). Based on the information submitted, staff analysis, and the Executive Director's recommendation, the CEC approved findings of the City’s section 10-106 application at the CEC’s January 21, 2026, Business Meeting.