AB 130 froze new local home codes. Menlo Park's reach code got approved.
AB 130 froze new local home codes until 2031 — but not entirely. Here's how Menlo Park's reach code got approved anyway.
If you've been telling clients "AB 130 means no new local building rules on homes until 2031," you're about to be wrong at a plan-check counter.
On April 27, 2026, the California Energy Commission approved a local energy ordinance for the City of Menlo Park — Ordinance No. 1127 — under the 2025 Energy Code. It adds a new cooling requirement for altered space-conditioning systems in existing single-family homes. That's a brand-new, more-restrictive residential energy rule, approved nearly seven months into a statewide freeze on exactly that kind of thing.
Here's the thing: it's not a loophole. It's two gates, and Menlo Park cleared both.
Gate 1: AB 130's freeze has carve-outs
AB 130 (Chapter 22, Statutes of 2025) enacted a moratorium on state and local building standards affecting residential units — beginning October 1, 2025 and ending June 1, 2031. (The full mechanics of how a city makes Title 24 stricter live in our local-amendments explainer; this post is the energy-ordinance wrinkle, so we won't re-cover them.)
"Moratorium" doesn't mean "nothing." Per CBSC Information Bulletin 25-03, a city can still file a residential amendment if it fits a narrow exception — for instance, one that's substantially equivalent to an amendment the jurisdiction already had in effect as of September 30, 2025, an emergency standard, or home hardening. The Commission recommends a city cite the specific exception its ordinance relies on, and it reviews each filing for compliance.
Which exception a given ordinance rode is a verify-with-the-jurisdiction question — don't assume. But the point for plan check is simpler: a residential local amendment filed after the freeze began is not automatically void. Check whether it cleared AB 130 review.
Gate 2: energy reach codes earn a CEC finding
Energy ordinances carry a step the rest of Title 24 doesn't. Under Public Resources Code §25402.1(h)(2) and Title 24, Part 1, §10-106, a city that wants to enforce energy standards stricter than the state Energy Code must apply to the Energy Commission and win two findings: that the local standards will cut energy use below the 2025 Energy Code, and that the city has filed the basis for its cost-effectiveness determination. Until the CEC makes those findings, the local standard can't be enforced.
Menlo Park filed its application on November 20, 2025; the CEC made the findings on April 27, 2026. And since October 1, 2025, the CEC's formal review doesn't even start until the city provides a CBSC acceptance letter confirming the reach code complies with AB 130 — so Gate 1 is baked into Gate 2.
Verified against the Energy Commission's "Local Ordinances Exceeding the 2025 Energy Code" list (Menlo Park, Ordinance 1127, approved 4/27/2026) and the Commission's April 27, 2026 business-meeting agenda, which describes the new cooling requirement verbatim.
What a Menlo Park HVAC change-out now asks for
Read the actual requirement before you quote it. When a space-conditioning system is altered in an existing single-family home, the ordinance's new mechanical cooling requirement encourages installing an air-source heat pump — while still allowing an air conditioner if additional efficiency measures are installed. It doesn't ban AC; it reshapes the swap into a heat-pump-or-AC-plus-upgrades choice.
A separate piece applies to certain single-family additions and alterations valued at $100,000 or more, which must pick two measures from a menu of energy-efficiency and electrification options. The ordinance also adds electric-readiness requirements for certain building types.
The takeaway: check the list
"AB 130 froze local codes" is a dangerous shortcut. The real move is to check the CEC's "Local Ordinances Exceeding the 2025 Energy Code" page for your city before you assume the state Energy Code is the whole rule. Menlo Park isn't alone — Mountain View, Palo Alto, and Moreno Valley carry the same existing-home cooling requirement, and Corte Madera, Encinitas, San Rafael, Santa Cruz, and Ojai have their own approved additions-and-alterations efficiency rules. Each filed local ordinance also lands on the CBSC's local-amendments registry. When the stakes are real, verify against the filed ordinance text and confirm it's in effect in that jurisdiction.
What CrossBeam does with it
CrossBeam reads a plan against the rule that actually governs the address — the statewide Energy Code plus any local reach code on record for that city — so a Menlo Park HVAC change-out gets checked against Menlo Park's cooling rule, not just the state default. When a new local ordinance clears the Energy Commission, it shows up where you're reviewing the plan, in plain language.