SB 222 speeds up the heat pump permit, and leaves the panel number unwritten.

The calculation California makes a contractor certify sizes the heat pump, not the panel.

October 1, 2026 · 11 minute read

California's new real-time heat pump permit, which cities and counties must offer by July 1, 2028, covers only an installation that "does not require installation of a new electrical panel or structural work." That is the first of three criteria in Government Code Section 51297.55, added by SB 222, which Governor Newsom signed on September 28, 2026 as Chapter 738 of the Statutes of 2026. The third criterion makes the contractor certify a load calculation under penalty of perjury, and that calculation sizes the heat pump. Whether the panel can carry the heat pump is a different calculation, done in amps, and the law does not name it or ask anyone to produce it. A homeowner in Sacramento or San Joaquin County can ask for it in writing before signing a contract.

What does SB 222 change about heat pump permits in California?

SB 222 changes three things about permits for a residential heat pump water heater or heat pump HVAC system: the fee, the inspection and the way the permit is issued. The bill adds Sections 51297.50 through 51297.59 to the Government Code. Section 51297.57 caps the permit fee at $150 for a heat pump water heater and $200 for a heat pump HVAC system, unless the city or county adopts a written finding with substantial evidence that its cost is higher. Section 51297.52 requires cities and counties, beginning July 1, 2027, to offer asynchronous inspections, meaning an inspection that does not require the contractor and the building inspector to be present at the same time. Section 51297.55 requires them, on or before July 1, 2028, to run an online, automated permitting process that issues the permit in real time.

The fee cap and the automated permit do not apply to a city under 5,000 people or a county under 150,000, including the cities inside that county. Sacramento County and San Joaquin County are both far above the county line, so locally the exemption reaches only a city as small as Isleton.

The automated permit has three criteria. The installation "does not require installation of a new electrical panel or structural work." The installation is a swapout. For an HVAC system, the contractor certifies a load calculation. Everything fast about SB 222's real-time permit sits behind the first of those.

Which load calculation does SB 222 make the contractor certify?

SB 222 makes the contractor certify a heating and cooling load calculation, not an electrical one. For a heat pump HVAC system, Section 51297.55 says the licensed contractor certifies under penalty of perjury that they performed a load calculation "to properly size the new residential heat pump HVAC equipment." The law names the methods: the Air Conditioning Contractors of America Association, Inc. Manual J Residential Load Calculation, the Sheet Metal and Air Conditioning Contractors' National Association Residential Comfort Systems Installation Standards Manual, or the California Mechanical Code. The contractor also "provides the load calculation to the local authority having jurisdiction upon request."

A Manual J calculation answers how much heating and cooling a house needs. It works from the size of the home, the insulation, the windows and the climate, and its result is used to pick the right size of equipment.

A Manual J calculation says nothing about amps. It does not look at the main breaker, the service rating, or what else in the house already draws power. The words "Electrical Code" do not appear in SB 222.

What decides whether a home qualifies for the fast heat pump permit?

Whether a home qualifies for SB 222's automated heat pump permit depends in part on whether the installation requires a new electrical panel, and that is answered by an electrical load calculation. An electrical load calculation adds up what the home already draws, adds the new equipment, and compares the total to the rating of the service and the panel. New York's state guide for heat pump installers describes the step in one line: compare the total peak load with the existing service capacity. The same guide notes that the project's electrician performs this calculation, and that it can be helpful for the HVAC contractor to obtain preliminary results.

In California the calculation has a name a homeowner can ask for. Article 220 of the California Electrical Code gives two methods for an existing home. Section 220.83 builds the load from the square footage and the nameplate ratings of the appliances. Section 220.87 starts from the highest demand recorded at the home over a year, multiplies it by 125 percent and adds the new load. Either one ends in a number of amps that can be set against the main breaker.

SB 222 names neither method. The panel condition is a criterion the installation has to meet, and the text attaches no calculation, no certification and no document to it.

An open slot in the panel is space. It is not capacity. A panel can have room for a new breaker and no room for the load, and a quick look inside the panel door only answers the first question.

How much load does a heat pump add to a 100 amp panel?

A heat pump that replaces a central air conditioner of the same size can add almost nothing to the calculated load on a 100 amp panel, and the same heat pump with a 10 kilowatt electric resistance backup strip can put the calculation past 100 amps. A worked example under Section 220.83 of the California Electrical Code shows where the line gets crossed.

Take a 1,500 square foot house with a 100 amp, 240 volt service, a gas furnace, a gas water heater, a 12 kilowatt electric range, a 5 kilowatt electric dryer, a 1,200 watt dishwasher and a central air conditioner that draws 18 amps. Lighting and general receptacles count at 3 volt-amperes per square foot, which is 4,500. Two kitchen circuits and a laundry circuit count at 1,500 each, which is 4,500. The range, dryer and dishwasher count at nameplate, which is 18,200. That totals 27,200 volt-amperes. The first 8,000 counts in full and the rest at 40 percent, which gives 15,680. The air conditioner adds 4,320 at full value. The house calculates at 20,000 volt-amperes, or 83 amps.

Replace the air conditioner with a heat pump of the same size and no backup strip, and the house still calculates at about 83 amps. A 100 amp panel carries it, and the finding is that no upgrade is needed.

Add a 10 kilowatt strip and the heating load, counted at full value, is 10,000 for the strip alone. The house calculates at 25,680 volt-amperes, or 107 amps. With the compressor running alongside the strip it is 30,000, or 125 amps. Same house, same heat pump, and the strip is what moves the job off the fast permit.

These are example nameplate figures, not a finding about any house. Whether a particular home needs a new panel is for a licensed electrician's calculation and the local building department to decide. The real ones come off the equipment labels and the main breaker. A smaller strip, or no strip, can bring the result back under the rating without touching the panel, and the Manual J is the document that shows how much backup heat the house calls for.

Does a heat pump water heater need a load calculation under SB 222?

No. SB 222 requires no load calculation of either kind for a heat pump water heater. The certified sizing calculation in Section 51297.55 applies only to a heat pump HVAC system, and the bill names no electrical calculation for any equipment.

ENERGY STAR's installation guidance says a 240 volt heat pump water heater typically uses a 30 amp circuit breaker, the same as a standard electric storage water heater. Replacing an electric water heater is close to a wash. Replacing a gas water heater adds a 30 amp, 240 volt circuit the house never had.

SB 222's definition of a swapout turns on location, not fuel: a new heat pump water heater installed in the same location as the water heater it replaces. A gas to heat pump water heater change can qualify as a swapout, add a 30 amp, 240 volt circuit, and reach the real-time permit with no sizing calculation and no electrical one, as long as the installation does not require a new electrical panel. Nothing in SB 222 requires paper showing how that last question was answered.

The same ENERGY STAR guidance notes that some 240 volt models work on a 25 or 20 amp circuit, and that several manufacturers offer plug-in 120 volt models designed for gas replacement. On a panel with little capacity left, one of those can be the answer that costs nothing at the service.

What happens when a real-time heat pump permit issues and the panel cannot carry the load?

When a real-time heat pump permit issues for a home whose panel cannot carry the load, the permit itself can still go through, because SB 222 does not require the automated process to check the number. The problem can then show up later, in one of four places.

1. At the main breaker. A service calculated past its rating can trip the main on a cold morning when the backup strip, the range and the dryer run together.

2. At the final inspection, as a correction, after the equipment is installed.

3. In a change order. If the shortfall is found once the old furnace or water heater is already out, the panel work gets priced and decided with the house waiting on heat or hot water.

4. At the utility. A larger service involves the utility, SMUD in most of Sacramento County and PG&E in most of San Joaquin County, and that part of the job runs on the utility's schedule, not the contractor's.

Each of those is cheaper to find on paper before the contract is signed than in the garage afterward.

Doesn't the electrical code already require someone to check the panel?

The strongest objection to this argument is that the California Electrical Code already applies to every heat pump installation, however the permit is issued. SB 222 does not waive it. A contractor who submits a job to the automated path is representing that it needs no new electrical panel, and an inspection still happens. On that view the electrical load calculation is already required, and there is no gap.

Most of that objection is correct, and it narrows the claim. Section 51297.55 lists three criteria. The penalty of perjury certification sits in the third, the sizing calculation, along with the duty to hand that calculation over on request. The panel condition is the first, and it carries neither. Somebody does assert that the panel is adequate. SB 222 does not require anybody to show the math.

A plan checker was not a guaranteed backstop before SB 222 either. A simple equipment replacement permit could be issued over the counter in some jurisdictions with no load calculation review. What changes is that a real-time automated path becomes required for qualifying swapouts in every city and county above the population thresholds, and Section 51297.52 has cities and counties offer an inspection without the contractor and the inspector standing at the panel together.

The evidence of harm is thin. The law was signed on September 28, 2026, the deadlines are in 2027 and 2028, and a local application form may end up asking for more than the statute does. Nothing here shows that a homeowner has been harmed. It shows where the written record stops.

What should a homeowner ask for before signing a heat pump contract?

Before signing a heat pump contract, a homeowner should ask for the electrical load calculation in writing, done under California Electrical Code Section 220.83 or 220.87. Five details make the answer useful:

1. Who did it: the HVAC contractor, or a licensed electrician.

2. What it found: the calculated load in amps, set against the rating of the service and the main breaker.

3. What it included: the new equipment, any electric backup heat, and the large loads already in the house, such as a range, a dryer or an EV charger.

4. Whether it looked at capacity or only at open breaker space.

5. What happens to the scope and the permit path if the answer is that the panel cannot carry the load.

If the document that comes back is the Manual J, that is the other calculation. It is one of the sizing calculations SB 222 names, and it sizes the equipment. Ask again for the electrical one.

A written electrical load calculation also protects the homeowner from the opposite mistake. A finding that a 100 amp panel has room for the heat pump is a finding too, and it is the one that saves the cost of an upgrade nobody needed.

A panel can have room for a new breaker and no room for the load, and a quick look inside the panel door only answers the first question.

The question to ask on the phone is short: what does my service calculate at in amps with the new equipment included, and can I have that on a page with my home's address on it?