Air Conditioning to Heat Pump Reach Codes

November 4, 2025

Dear Mayor Aftab and Saratoga Councilmembers,

The Sierra Club Loma Prieta Chapter supports the adoption of the 2025 CALGreen reach code to encourage that all air conditioning (AC) replacements in single-family homes include both cooling and heating modes. These two-way ACs, commonly known as heat pumps, reduce climate pollution, improve indoor air quality, and lower energy costs. Our communities are already directly experiencing the impacts of the climate crisis, and the time for bold action is now.

The policy, often referred to as an Air Conditioner to Heat Pump Replacement Policy or “AC2HP” code, is in line with Saratoga's sustainability goals. With available incentives, the upfront cost of a heat pump is equivalent to AC replacement, and the superior efficiency of heat pumps can provide monthly bill savings, making this policy a win-win for Saratoga.

AC2HP Policies Help Achieve Saratoga’s Climate Action Plan Goals
Saratoga’s Climate Action Plan (CAP) establishes targets of 40% emissions reductions below 1990 levels by 2030, and 80% below 1990 levels by 2050. To achieve these goals, Saratoga will need to address the approximately 44% of emissions that come from residential and commercial buildings, as identified in the 2017 greenhouse gas emissions inventory. The CAP contains the following strategy, of “continued reductions in natural gas consumption in residential and commercial buildings.” To achieve this strategy, Saratoga should seek to encourage homeowners to electrify at the most cost-efficient stages of appliance life cycles. When an air conditioning unit is broken and needs to be replaced, this is an optimal time to encourage homeowners to replace that unit with a high efficiency electric heat pump.

Heat Pumps Reduce Greenhouse Gas Emissions and Air Pollution
AC2HP policies not only incentivize appliances with twice the functionality of conventional air conditioning units, they also help to offset or completely eliminate the use and future replacement of fossil fuel powered furnaces, because heat pumps can both heat and cool homes.

A heat pump with a backup furnace uses about 95% less gas compared to a conventional air conditioner paired with a gas furnace. Greenhouse gas emissions are reduced significantly in the first year, and over the life of the appliance, emissions will continue to decline toward zero as the electric grid is decarbonized.

Beyond just greenhouse gas emission reductions, heat pumps also eliminate harmful indoor and outdoor nitrogen oxides (NOx), which cause smog. This local air pollution worsens many health conditions, such as asthma. Malfunctioning gas furnaces can also cause fatal carbon monoxide poisoning. Based on national trends, outdoor air pollution disproportionately impacts low income and Black, Indigenous and People of Color (BIPOC) communities, as non-white racial and ethnic groups are disproportionately exposed to ozone and other criteria pollutants such as NOx, PM2.5, and CO.1 By adopting AC2HP policy, Saratoga would take meaningful steps to reduce this pollution, and ensure clean air for all.

AC2HP Policies Can Save Households Money on Monthly Energy Bills
The best time for households to switch to a heat pump is when they need to replace their air conditioner, rather than when they need to replace their furnace. This is because an existing AC system has the necessary electric wiring and capacity in place to allow for a drop-in replacement with a heat pump. In contrast, replacing a gas furnace with a heat pump could require electric upgrades that could make installation more costly.

However, when air conditioners fail, HVAC contractors often recommend like-for-like replacements, depriving customers of the opportunity to instead install a heat pump which displaces polluting gas heating and the need for an expensive furnace replacement later. While the initial cost of installing two-way heat pumps is about $2,000 more than one-way air conditioning, the significant financial incentives in place at the state level and through the Silicon Valley Clean Energy Community Choice Aggregator can actually make these appliances more affordable for Saratoga residents.2 Furthermore, eliminating the need to replace a gas furnace will avoid thousands of dollars in future costs.

In addition to being all electric, heat pumps are also extremely efficient, generally 3 to 4 times more so than conventional gas furnaces. This means that when households make the switch to heat pumps, they can reduce their monthly energy consumption and utility bills.

We urge you to adopt the AC2HP reach code to further Saratoga’s progress in reducing air and climate pollution and helping residents save money on their energy bills. We support additional efforts to make permitting for these appliance replacements quicker and easier for residents.

Thank you for your consideration.


Sincerely,

Dashiell Leeds
Conservation Coordinator
Sierra Club Loma Prieta Chapter


1 Timothy Q. Donaghy et al., “Fossil fuel racism in the United States: How phasing out coal, oil, and gas can protect communities," Energy Research & Social Science 100:103104, June 2023.

2 Silicon Valley Clean Energy, Home Rebates, https://svcleanenergy.org/home-rebates/