REPORT TO COUNCIL
SUBJECT
Title
Action on Adoption of a Resolution Establishing the Necessary Findings of Fact for Modifications to the California Building Standards; Action on Introduction of an Ordinance Amending Title 15 (“Buildings and Construction”) of “The Code of the City of Santa Clara, California” for the Adoption of the 2025 California Building Standards Code, Including Updates to the City’s “Reach Code”; and Setting October 21, 2025 for a Public Hearing on Adoption of such Ordinance
Report
BACKGROUND
Title 24 of the California Code of Regulations, also referred to as the California Building Standards Code, governs the design and construction of buildings, facilities and associated equipment throughout California. The California Building Standards Commission updates the Building Standards Code on a triennial basis to improve safety, sustainability, and resiliency, and to incorporate new technology, design, and construction methods. The City of Santa Clara adopted the current 2022 Building Standards Code, with modifications including “Reach Code” provisions, in November of 2022, and those standards have been in effect since January 1, 2023.
Every three years, the local adoption process provides an opportunity for each jurisdiction to make modifications to the Building Standards Code to align with local concerns, by making findings that local climatic, geographical, or topographical conditions justify making the modifications. Local modifications are commonly made to address local context and concerns that may not be applicable statewide. This ordinance is the typical process to adopt the new 2025 California Building Standards Code with local amendments as noted below, and will be effective January 1, 2026.
In Santa Clara, the local modifications will allow the City to continue implementing the Santa Clara “Reach Code,” which makes local amendments to the California Energy Code and California Green Building Standards Code to support sustainability goals. The City adopted its first Reach Code in November 2021, following a long public process, and updated it in November 2022. Both versions of the Code increased requirements on new construction to install electric vehicle infrastructure, imposed new obligations to install solar paneling, and mandated the use of electricity as a power source in new construction. As a result of a Federal Appeals Court ruling involving the City of Berkeley, on January 14, 2025, the City Council indefinitely suspended the all-electric provisions of the Reach Code. Staff will return to Council in early 2026 with alternative approaches to encourage electrification in mixed-fuel buildings.
Title 15 (“Buildings and Construction”) of “The Code of the City of Santa Clara, California” provides for regulations pertaining to design and construction of buildings in the City. For Santa Clara to adopt the 2025 California Building Standards Code, Chapters in Title 15 will need to be amended accordingly in the proposed Ordinance. Local modifications are also incorporated into the proposed Ordinance, accompanied by Resolutions of Findings detailing the local climatic, geological, and topographical conditions justifying those modifications. Following adoption by the City, the Building Official will file a copy of the Ordinance and Resolutions with the California Building Standards Commission and the California Energy Commission.
DISCUSSION
Throughout each code adoption cycle, amendments to the building codes are developed through a lengthy public participation process. State Code Advisory Committees provide recommendations to the California Building Standards Commission on the various proposed amendments to the Building Standards. Following this process, the California Building Standards Commission adopted the 2025 California Building Standards Code and published it on July 1, 2025. The 2025 California Building Standards Code will become effective statewide on January 1, 2026.
Local jurisdictions are encouraged to participate in the development of the California Building Standards Code, to be adopted throughout the State, establishing a common level of standards that are universally applicable. Local jurisdictions may then adopt the California Building Standards Code to act as the governing Building Standards Code within their jurisdiction. As part of the triennial code adoption cycle, and pursuant to California Health and Safety Code Sections 17958 and 18941.5, staff recommends that the City Council adopt the 2025 California Building Standards Code. The parts of the 2025 California Building Standards Code that are included in the proposed adoption are the 2025 California Administrative Code, Building Code, Residential Code, Electrical Code, Mechanical Code, Plumbing Code, Existing Building Code, Energy Code, Historical Building Code and Green Building Standards Code. In addition, staff recommends that the Council adopt the 2024 International Property Maintenance Code published by the International Code Council.
Building Code alignment with Fire Safety
Staff is recommending local amendments affecting two of the 2025 California Codes: the Building Code and the Residential Code to align with existing Fire Safety requirements. The Building Division collaborated with the Community Risk Reduction Division of the Fire Department on these local amendments, which primarily concern fire sprinklers and egress paths that are already in place with the Fire Code. These local amendments are intended to address building safety side with relevance to Santa Clara and include the following elements:
1) 2025 California Building Code Chapter 9: Additional Automatic Fire Sprinkler Requirements for existing Group R3 Occupancies; i.e. single-family homes, duplexes, triplexes, etc.
2) 2025 California Building Code, Chapter 10: Additional requirements for safe stairway configuration and the routing of emergency exit paths to facilitate emergency egress out of multi-story buildings.
3) 2025 California Building Code, Chapter 19: Additional requirements for Structural Plain Concrete in Seismic Design Category C, D, E or F.
4) 2025 California Residential Code Chapter 3: Additional Automatic Fire Sprinkler System Requirements for existing Group R3 Occupancies; i.e. single-family homes, duplexes, triplexes, etc.
These proposed amendments are intended to promote building safety for future residents in the context of Santa Clara’s growing urban environment, particularly as the City is increasingly granting land use entitlements for higher density Type III and, in some cases, Type I construction, including the use of towers located above podiums. These measures will align with the Fire Code to facilitate egress from such high-rise construction, which is of particular concern in a serious seismic event that could result in structural damage and fires.
Adoption of the 2025 California Building Standards Code, incorporating the proposed local amendments, would further the following General Plan policies related to the adoption of building codes and use of the Building Permit process to minimize safety risks for new development:
5.9.3-G1 A safe and secure environment for people and property in the community.
5.9.3‐P1 Encourage design techniques that promote public and property safety in new development and public spaces.
5.10.5-P6 Require that new development is designed to meet current safety standards and implement appropriate building codes to reduce risks associated with geologic conditions.
2025 Reach Code
The local modifications to the Energy Code and CALGreen will allow the continuation of the existing Reach Code provisions on EV Charging and PV panels, and will exceed 2025 state requirements. The proposed ordinance also adopts the 2025 versions of the California Energy Code and California Green Building Standards Code, with modifications to the following sections:
1) 2025 California Energy Code, Section 110.10: Additional requirements for Solar Readiness for Non-Residential and Multi-Family Buildings.
2) 2025 California Green Building Standards Code, Section 4.106: Additional requirements for increased electric vehicle charging stations for Residential projects and
3) 2025 California Green Building Standards Code, Section 5.106: Additional requirements for increased electric vehicle charging stations for Non-Residential development.
With regards to Electric Vehicle (EV) and Photovoltaic (PV) standards, in some cases the new State standards exceed the requirements of the current (2022) Reach Code; in other cases, the City’s Reach Code continues to exceed the state standards. Consequently, staff recommends the Council adopt amendments that would align the current Reach Code with the relevant 2025 code sections, but maintain all portions of the existing Reach Code that provide higher standards.
Attachment 4 includes two charts regarding EV and PV standards comparing the current 2022 Reach Code to the 2025 Green Building Standards Code (“CalGreen”), and what is proposed to be included in the 2025 updated Reach Code. The charts show that the majority of the City’s current Reach Code standards for EV and PV are proposed to be continued in the updated 2025 Reach Code because the current Reach Code has higher requirements for sustainability than the new 2025 CalGreen standards. There are a few areas where the CalGreen standard is higher and proposed to be adopted instead of the current Reach Code standard. Specifically, the 2025 state standards for EV charging for hotels and motels; and the state photovoltaic requirements for single family, duplex, and multifamily developments are higher than the current Reach Code, so it is proposed that the state standards be adopted in those categories.
The third component of the prior Reach Codes were the all-electric requirements. Sections 15.36.040 through 15.36.080 of the City Code mandated the use of electricity as a power source in new construction, and limits the installation of natural gas plumbing and meters. The City of Berkeley adopted a similar ordinance in 2019, and the California Restaurant Association sued, alleging that the ordinance was preempted by a federal statute, the “Energy Policy and Conservation Act,” which established energy efficiency requirements for certain appliances. The case ultimately made its way to the Federal Ninth Circuit Court of Appeals, which struck down the Berkeley Code, concluding that the Federal law preempted not just State and local regulation of gas appliances, but also local regulations that prohibited natural gas delivery systems in new development. In response, on January 14, 2025, the Santa Clara City Council indefinitely suspended the all-electric provisions of the Reach Code, and gave staff direction to prepare a revised Reach Code utilizing one or more alternate approaches that do not directly prohibit natural gas infrastructure. Staff is in the process of drafting the revised text and will return in early 2026 with alternative approaches to encourage electrification in mixed-fuel buildings.
Findings
In order to adopt the above modifications, the City must prepare findings describing the climatic, geologic, and topographic conditions justifying the modifications, which must be submitted to the California Building Standards Commission (CBSC). In addition, for the Reach Code provisions, a set of findings must be submitted to the California Energy Commission (CEC). To that end, Attachment 2 is a resolution containing the findings for the adoption of the changes to the Building Code and Residential Code; attachment 3 is a resolution of findings containing the Reach Code changes. Both resolutions will be submitted to the CBSC; the second resolution will be submitted to the CEC. Although CEC pre-approval is required for certain kinds of modifications, in this case, because the City’s local standards are not changing substantively, they be in effect on January 1, 2026.
Recommendation
The 2025 Building Codes will take effect on January 1, 2026, even if the Council declines to take action. The Council must adopt the ordinance, however, if the local modifications described above are to become effective. Therefore, the Council’s options are to adopt the proposed ordinance with the proposed local modifications, or take no action, in which case the local modifications will not go into effect. The local modifications to the Building Code and Residential Code are similar to those adopted in 2022 and will promote public safety goals and alignment with the Fire Code. The local modifications to the Energy Code and CALGreen will allow the continuation of the existing Reach Code provisions on EV Charging and PV panels, to the extent that they exceed 2025 state requirements. Consequently, staff recommends that the Council adopt the local modifications.
ENVIRONMENTAL REVIEW
To the extent the proposed modifications revise existing standards, the action being considered is exempt from the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines section 15305 in that it is a minor alteration in land use limitations that will not result in any changes in land use or density, and section 15308 in that it is an action taken by a regulatory agency as authorized by California law to assure maintenance or protection of the environment. However, the large majority of the contemplated actions do not modify existing standards, and to that extent, do not constitute a “project” subject to CEQA.
FISCAL IMPACT
There is no cost to the City other than administrative staff time and expense.
COORDINATION
This report has been coordinated with the Fire Department and the City Attorney’s Office.
PUBLIC CONTACT
A public notice of the public hearing to be held on October 21, 2025, is scheduled to be advertised in the Santa Clara Weekly on October 8, 2025, and October 15, 2025. Public contact was made by posting the Council agenda on the City’s official-notice bulletin board outside City Hall Council Chambers. A complete agenda packet is available on the City’s website and in the City Clerk’s Office at least 72 hours prior to a Regular Meeting and 24 hours prior to a Special Meeting. A hard copy of any agenda report may be requested by contacting the City Clerk’s Office at (408) 615-2220, email clerk@santaclaraca.gov or at the public information desk at any City of Santa Clara public library.
RECOMMENDATION
Recommendation
1. Waive first reading and Introduce an Ordinance amending Chapter 15.05 ("Administrative Code"), Chapter 15.15 (“Building Code”), Chapter 15.17 (“Residential Code”), Chapter 15.18 ("Property Maintenance Code"), Chapter 15.20 (“Electrical Code”), Chapter 15.30 (“Mechanical Code”), Chapter 15.35 (“Plumbing Code”), Chapter 15.36 (“Energy Code”), Chapter 15.37 (“Historical Building Code”), Chapter 15.38 (“Green Building Code”), and Chapter 15.75 ("Existing Building Code") of Title 15 (“Buildings and Construction”) of “The Code of the City of Santa Clara, California” for the adoption of the 2025 California Building Standards Code;
2. Adopt a Resolution Making Findings of Fact Necessary for the Specified Modifications to the 2025 California Building Code and 2025 California Residential Code Reflected in the Proposed Ordinance;
3. Adopt a Resolution Making Findings of Fact Necessary for the Specified Modifications to the 2025 California Energy Code and 2025 California Green Building Standards Code Reflected in the Proposed Ordinance; and
4. Set a public hearing on October 21, 2025, pursuant to California Government Code Section 50022.3 for adoption of the Ordinance.
Staff
Reviewed by: Afshan Hamid, Director of Community Development
Approved by: Jovan Grogan, City Manager
ATTACHMENTS
1. Building Division Code Adoption Ordinance 2025
2. Findings Resolution / Building and Residential Code Adoption 2025
3. Findings Resolution / Energy and CALGreen Code Adoption 2025
4. Comparison Table for EV and PV: 2022 Reach Code, 2025 CalGreen Code, and Updated 2025 Reach Code