Equipment Replacement Code Changes in 2023, 2025, and 2027

Overview

The Energize Denver ordinance was passed by Denver City Council on November 22, 2021. It established planned updates to the Denver Building and Fire Code. These updates require partial electrification for all existing commercial and multifamily buildings when replacing gas-fired space and water heating and cooling equipment. This happens:  

  • Upon system replacement, at the end of system life
  • When installing an electric heat pump will not cause economic hardship
  • Regardless of building size  

These electrification requirements change the way you prepare and apply for building permits. They also change the types of equipment you are allowed to install when replacing space and water heating and cooling systems. The first set of changes went into effect on March 1, 2023. 

Requirements will phase in over time, through additional updates to the Denver Building Code. 

DISCLAIMER: The information below should be considered a summary of the code requirements only. If you will be replacing your heating or cooling equipment, we highly recommend that you read the full Denver Building and Fire Code sections relevant to equipment replacement.

 

Who Does this Apply To?

These electrification requirements apply to all existing commercial and multifamily buildings. These buildings are regulated by the Denver Energy Code’s Commercial Provisions. This includes commercial buildings, multifamily apartment buildings, and multifamily condominium buildings. Single family dwellings, two-family dwellings, and townhomes are not subject to these electrification requirements. Not sure what kind of building yours is? Check out this graphic(PDF, 63KB) to help you out. If you prefer, you can read a text version(PDF, 146KB) of the graphic instead.
 

If you have additional questions about whether or not your building is regulated by the Denver Energy Code’s Commercial Provisions, please contact Community Planning and Development's Architectural/Structural Plan Review at archstruc.review@denvergov.org.

 

2023 Updates 

As of March 1st, 2023, the city has changed the permit process for replacing a unitary air conditioner or condensing unit, natural gas heating system, or natural gas water heater in commercial and multifamily buildings. These systems will no longer be allowed to go through the quick permit process. Instead, the process to replace these systems with a like-for-like replacement is the same as the permit process for heat pumps.  

 

2025 Updates 

No later than January 1, 2025, the Denver Building and Fire Code will be amended to expand the electrification requirements: 

  • When replacing a gas-fired warm air furnace located outside a building, the primary heating system is required to be electric. Another gas-fired furnace can be installed to provide supplementary heat only. 
  • When replacing a unitary air conditioner or condensing unit, you will need to replace it with electric equipment that can also provide space heating (like a heat pump). Other heating equipment in the building can provide supplementary heat only. 
  • When replacing a storage water heater or instantaneous water heater you will be required to replace it with an electric water heater.  

There will be exemptions to these requirements for emergency replacement and economic hardship: You may qualify for an exemption if replacing your gas-fired equipment with electric equipment will cost 15% or more than a like-for-like gas-fired replacement. This includes all incentives and rebates, as well as the social cost of carbon dioxide from gas-fired equipment. Denver’s Office of Climate Action, Sustainability and Resiliency will review your exemption request and make a final decision.  

 

2027 Updates

No later than January 1, 2027, the Denver Building and Fire Code will be amended to further expand the electrification requirements:  

  • When it is time for you to replace your gas-fired boiler used for space heating the new equipment that you install must meet at least 50% of your space heating needs with electric space heating. The other 50% can be met with another gas-fired boiler, unless you qualify for an exemption. If you do install a replacement gas-fired boiler to provide supplementary heat or due to an approved exemption, you must do at least two (2) of the following:
    • Submit an Electrification Feasibility Report
    • Get an analysis of the building envelope, ventilation requirements, and energy load prepared by a registered design professional. You will also have to right-size the equipment based on the Denver Building and Fire Code. 
    • Pressure test all the natural gas piping in the building.
  • When replacing a gas-fired boiler used for water heating, the new equipment you install must meet at least 50% of your water heating with electric water heating. The other 50% can be another gas-fired boiler, unless you qualify for an exemption. If you do install a replacement gas-fired boiler, to provide supplementary heat or due to an approved exemption, you must do at least one (1) of the following: 
  • If you replace an air conditioner that serves space you also heat, you must replace it with electric equipment that does both heating and cooling (like a heat pump). Any other space heating equipment in the building should be used for supplementary heat only.  

As with the 2025 updates, there will be exemptions for emergency replacement and economic hardship available. Denver’s Office of Climate Action, Sustainability and Resiliency will review exemption applications to make a final determination.