Palo Alto Leads on Energy Efficiency Codes, Proposes City Council Adoption of 2016 Reach Code

Earlier this month, the City of Palo Alto shared its findings on adoption of reach code to require building energy efficiencies 10% above the 2016 Building Energy Efficiency Standards (Title 24, Part 6).

Excerpts from the City’s report to City Council are available below – these excerpts provide a great overview of how reach codes work and are filed in California, as well as how Palo Alto came to the recommendations of the proposed reach code. For the full update from Palo Alto, and the findings of their cost effectiveness test (conducted by TRC Solutions), click here.

To review the 2016 Building Energy Efficiency Standards (which will be available for local government adoption starting July 1st, with adoption required by January 1st, 2017), click here.

Executive Summary

The attached ordinance proposing Local Amendments to the 2016 California Energy Code (Title 24, Chapter 6 of the California Code of Regulations (Energy Reach Code ordinance) would continue Palo Alto’s leadership position in promoting energy efficient and high-performance building design and construction. Staff has collaborated with the Green Building Advisory Group and other city departments to develop the proposed ordinance. The criteria proposed in this ordinance were studied to be cost-effective in compliance with the California Energy Commission requirements and the results of the study are in Attachment 2. The Energy Reach Code ordinance differs from the State minimum in the following areas: 1) the ordinance includes an updated energy “reach code” requiring building design to exceed the minimum State energy code requirements by a certain percentage based on project type and scope; 2) the ordinance continues solar-ready infrastructure requirements for new residential buildings; and 3) the ordinance promotes all-electric building design by providing an exemption from “reach code” requirements above the state minimum.

…[During a 2015 retreat, Palo Alto’s Green Building Technical Advisory Committee determined it would develop 1) the] new Energy Reach Code, which is based on the 2016 California Energy Code. The energy reach code ordinance creates an incremental step towards Zero Net Energy for new single-family residential, new multi-family residential, and new commercial “non-residential” construction; and 2) The development of the new green building ordinance, based on the 2016 California Green Building Standards Code, which staff will be presenting to the City Council later in the year along with the remainder of the 2016 Building Standards Code updates. Staff is presenting the Energy Reach Code to the City Council ahead of the typical code adoption schedule due a required 60-day public comment period and approval process required by the California Energy Commission.

Once staff files the adopted ordinance with the California Energy Commission, a 60-day public comment period administered by the CEC will begin. City staff will be asked to respond to public comments on an as-needed basis. After the close of the 60-day public comment period, it is normal for the Energy Commission to request revisions to the energy ordinance. In the case of necessary revisions, staff will plan to come back to the City Council to present the revisions in the fall of 2016 in preparation for a target effective date of January 1, 2017.

In addition to the 60-day public comment period, the California Energy Commission requires that a cost-effectiveness study be conducted and filed in the case of a local amendment to the California Energy Code. It is required that the City demonstrate to the California Energy Commission, using the cost-effectiveness study, that the local amendments to the code are financially responsible to the applicants. 

To meet the California Energy Commission requirements for the cost-effectiveness study, staff conducted an informal bid process to select a consultant. Staff selected TRC Solutions based on their ability to provide both residential and non-residential services within the same study and their ability to meet the project timeline. TRC Solutions attended the 2015 GBAG retreat and participated as an expert consultant on the Green Building Technical Advisory Committee (GBTAC). In coordination with direction from the GBAG Retreat and GBTAC meetings, TRC performed the study using CEC-approved energy modeling software. The results of this study are located in Attachment 2 of this report.


With the updated Energy Reach Code ordinance, the City of Palo Alto will increase the minimum requirements for building energy performance compared to the 2016 California Energy Code. The proposed energy ordinance adopts specific cost-effective compliance options and would be triggered on permit application for the following project types: 1) new single-family residential, 2) new multi-family residential and 3) new commercial “non-residential” construction.

There are two methods for demonstrating compliance with the statewide 2016 California Energy Code. The first type of compliance is called the “performance approach”. This approach is typically used for new construction projects and is the methodology selected for the proposed local Energy Reach Code, as explained later in this report. The secondary type of compliance approach, called the “prescriptive approach”, is not typically used as a compliance pathway for new construction and is more conservative. Therefore, no local amendments are proposed for this approach.

Using the performance approach, projects throughout the State are required to develop an energy budget that assigns a maximum amount of energy that a building can use within the design. Each budget is unique to the project is based on many factors. Examples of the components that contribute to an energy budget include location, size, orientation, building geometry, exterior wall design, roof design, and heating and cooling system design. The allowable energy budget for a building is referred to as the “standard” design. The actual energy budget for the design of a building is referred to as the “proposed” design.

Energy budgets are developed within energy modeling software approved by the California Energy Commission. The primary metric associated with measuring the energy budget in California is called Time-Dependent Valuation (TDV). TDV is a California-specific measurement system, used within the energy modeling software, and assigns a cost value to energy use associated with each hour during the year. “TDV Energy” is the term used to describe an amount of energy when expressed in TDV.

Design and construction teams throughout California are required to demonstrate, using a computer simulation energy model, that the TDV Energy use of the “proposed” design does not use more energy than the TDV Energy in the “standard” design. The proposed local Energy Reach Code incorporates the “performance approach” compliance methodology for new construction described earlier in this report. Under the local code, the requirements for the “proposed” design are defined as using a percentage less TDV Energy than the “standard” design. This concept is referred to as “percent-savings” when compared to the standard design. 

While developing the criteria for the ordinance, the Green Building Advisory Group recommended providing design teams with compliance options rather than one specific requirement. As a result, the proposed policy outlines two compliance options for each of the following project types: 1) new single-family residential, 2) new multi-family residential and 3) new commercial “non-residential” construction. The applicable compliance path for each project type is dependent on the presence or absence of solar photovoltaic power in the design. Of the compliance options outlined, the first option is intended for projects that are not pursuing solar photovoltaic (PV) power. The second option is intended for those projects that are pursuing solar photovoltaic (PV) power. The requirements are outlined in Figures 1a and 1b. In the case of commercial construction, the requirement structure is modified due to the lack of “PV Credit,” as explained later in this report.

For more, see the City of Palo Alto’s full report here.

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