Sub-1.0 by design: the rooftop table's No Requirement cells

Table 141.0-E-1 was sized to reach under 5.42 tons, 65,000 Btu/hr, across four listed building types, and then it goes no further. Its reputation is a sweeping heat-pump mandate; the sizing is where that reputation stops matching the text. Every cell the table marks No Requirement sits on a benefit-cost ratio the state's own analysis could not push above 1.0, and that is the whole account of the exemptions. Not politics, arithmetic. Table 141.0-E-1 is new in the 2025 cycle, and it did not exist in the 2022 Standards at all. The California Energy Commission adopted the standards on September 11, 2024, and they govern any permit application filed on or after January 1, 2026. So the table is now the thing a plan checker reads on a commercial changeout, and before you quote one it is worth knowing where its holes are and why they sit where they do.

Every exempt cell is a cell that failed 1.0

The table covers four building types: retail and grocery, school, office and financial institution, and library. Read the No Requirement cells across those four rows and a pattern falls straight out. Retail and office carry No Requirement in Climate Zones 1, 2, 14 and 16. School carries it only in 16, and library in 2 and 16. Now set the Commission's own cost-effectiveness tables next to that grid, row for row. Small Office runs a benefit-cost ratio of 0.8 at Climate Zone 1 and N/A at 2, 14 and 16; Medium Retail reads N/A across all four; Small School reads N/A only at 16; Library reads N/A at 2 and 16. Every cell the table exempts is a cell where the state's own arithmetic came in under 1.0, or would not compute at all.



The cells that do carry a requirement went the other way, and it is the same arithmetic run in reverse. There the incremental cost of the heat pump came out negative, so the benefit-cost ratio ran to infinite. Which means the line between required and exempt is not a policy judgment about which buildings deserve a break. It is the 1.0 threshold, worked on a spreadsheet, showing through the code text.

The table tops out at 5.42 tons, not 20

So the reach of this rule is narrow, and the narrowness is a capacity argument. Table 141.0-E-1 applies to single-zone packaged direct-expansion rooftop units rated under 65,000 Btu/hr. Call it 5.42 tons. The new-construction heat pump baseline for the same class of equipment, Section 140.4(a)2, runs all the way to 240,000 Btu/hr, or 20 tons.



The replacement ceiling is a little over a quarter of the new-construction ceiling, roughly 3.7 times smaller. A 7.5 ton unit on a strip-retail pad falls outside the table. So does every restaurant, warehouse, medical office and hotel, because those four listed building types are the whole of it. The rule people keep describing as broad reaches under 5.42 tons on four building types, and then it stops.

No line in the table requires a heat pump

Here is what the table does not do: it does not require a heat pump anywhere. Nearly every non-exempt cell reads SZHP or SZAC1, and the lone exception, a single cell at Climate Zone 11, comes below. SZAC1 is a single-zone air conditioner with a furnace, a variable-speed fan and an economizer, or a dual-fuel heat pump carrying the same fan and economizer. A gas furnace unit complies, provided it brings that fan and that economizer along. And a project that would rather skip the table entirely has a stated way out, because Section 141.0(b)2Cii lets a system meet either Table 141.0-E-1 or the performance compliance path at Section 141.0(b)3. The code then makes the underlying point explicit: Exception 1 to Section 141.0(b)2C states that Sections 140.4(a)2 and 140.4(a)3, the two new-construction heat pump baselines, do not apply to new or replacement space-conditioning systems. Those baselines are switched off for changeouts by name. The Commission's own January 2026 announcement puts it as plainly as anyone could ask: the update, it says, "does not mandate specific technologies or fuel types."

One footnote in the adopted table does complicate the grid, and it is worth flagging rather than smoothing over. The office and financial-institution cell at Climate Zone 11 reads SZAC2, a term the table's own footnotes never define. Its column position is on the page; its meaning is not.

The equipment is cheaper; the panel is where the money shows

So if the heat pump is optional, why does everyone assume it costs the owner more? The record the rule rests on says the opposite on equipment. In the Commission's cost basis, a 2 ton gas furnace rooftop unit and a 2 ton heat pump unit both land at $3,600. At 3 tons it is $8,000 gas against $6,300 heat pump; at 4 tons, $9,000 against $7,100; at 5 tons, $9,800 against $7,400. The heat pump is the cheaper box at every size above two tons, and the rulemaking averaged its two distributor estimates to a saving of $221 per ton. One of those two estimates only turned negative once a Low NOx burner was added to the gas unit, which is the kind of detail that swings a cost-effectiveness finding and never once reaches a jobsite. These are distributor quotes used in a rulemaking, not a price anyone gets at a counter, and that distinction carries more weight than the averages do.

The real added cost the same report identifies is electrical, and it is one specific case rather than a general allowance for wiring. Where a heat pump in a cold-enough location needs supplementary electric resistance heat, and that heat in turn forces a service upgrade, the report prices a 100 amp 277/480V three-phase panel at $4,200 to $6,000. So the money is not in the compressor, it is in the panel, and only when the panel actually has to move.

Like-for-like was never a status you could claim

One more assumption to retire, because it predates this cycle entirely. There is no code category called like-for-like. The Standards define a repair as reconstruction or renewal for maintenance, then state that replacing any component the Standards regulate is an alteration and not a repair. A rooftop changeout is an alteration, and it was one under the 2022 cycle too. What the trade calls like-for-like describes the equipment on the truck, not a status you can claim at the counter. And the freeze people keep citing does not reach this either: AB 130 barred new residential building standards from October 1, 2025 through June 1, 2031, but it leaves the nonresidential cycle running and does not touch this table.

PermitFeed reads rooftop-replacement permits as they post across SoCal permit portals, and the read on who just pulled one is priced month to month. The table did not widen the work. It narrowed the requirement to the cells where the state's arithmetic said a heat pump paid for itself.