SBCC economic-impact work group presses for small-business input as contract delays push analysis past CR-102 filing

Members of the State Building Code Council’s work group on economic impact on Sept. 2 reviewed the status of cost-benefit and small-business economic impact work for the 2024 code cycle and discussed steps to gather stakeholder input after contracting delays slowed delivery of contractor analyses for the energy codes.

The group’s staff lead, Dustin (Staff member), told attendees that "the final results of the contract is not anticipated till the December," and that preliminary contractor deliverables were unlikely to arrive in time for the council’s CR-102 filing on Oct. 1, 2025. He said staff would prepare draft cost-benefit material from the proposal documents and that the small-business economic impact statements — required by the Regulatory Fairness Act (RCW 19.85.040) — posed a particular timing challenge.

The work group’s concern centered on two, related constraints: the statutory filing requirements tied to CR-102 and limited staff capacity. Dustin explained the council can file a preliminary cost-benefit analysis with CR-102 and supplement it later, but the small-business economic impact statement historically has been expected with the CR-102 filing and is harder to complete without additional, solicited input from affected small businesses.

Why it matters: the Regulatory Fairness Act requires agencies to consider how rules affect small businesses and to document mitigation efforts for disproportionate impacts. The SBCC’s code package covers many cross-cutting…