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Embodied-carbon proposal draws split: proponents urge work, opponents cite cost and timing
Summary
Committee accepted a single combined draft of an embodied-carbon appendix for further work but members and industry speakers raised feasibility and timing concerns; proponents said they will continue to revise values and coordinate with Buy Clean and EPD working groups.
The BFRW standing committee agreed to convert existing comment versions into a single BFRW draft of an embodied-carbon appendix for further review, but the discussion revealed sharp differences among proponents, industry groups, and some committee members about feasibility, cost, and whether the proposal is premature.
Why it matters: the proposed appendix would require project-level consideration of embodied global warming potential (GWP) using environmental product declarations (EPDs) or equivalent metrics. If adopted, the appendix would add supply-chain and reporting obligations on producers and project teams and could affect material selection for public and private projects.
Proponents from the Carbon Leadership Forum (CLF) and the New Buildings Institute (NBI) argued the draft requires further revision and stakeholder coordination. Ariel Brenner (New Buildings Institute) and Amy Lewis (NBI) reiterated willingness to adjust values and working definitions. Brenner noted the IBC-reporting process and ICC committee had provided feedback and that the proponents will revise values during the public-comment window.
Opponents raised practical and cost concerns. Matthew (CalPortland) said producers and contractors have not had an equal opportunity to shape the text and expressed concern about fairness: "we are the producers that have to implement and comply with these codes" and said industry lacked an adequate opportunity to shape the draft. Tim Atterberry read a note from contractor Craig Holt about a pilot at University of Washington Tacoma, saying the pilot required paying suppliers and fabricators tens of thousands of dollars and consumed 60–70 staff hours. Tim read the message, which said the project "had to pay our mass timber supplier $35,000 and the steel fabricator, $50,000... [and] it will consume roughly 60 to 70 staff hours on the construction side to manage the process." Committee members and staff noted the pilot predated current data and that the CLF/NBI proponents and a separate Commerce Buy Clean working group are actively refining methods and data.
Several committee members cautioned that ICC voted to disapprove a similar model-code proposal on the grounds that it was premature and that the International Code Council recommended scope clarifications and additional consensus work. Committee members asked that the proponents coordinate with the Buy Clean/Commerce working group (the 1282/Buy Clean effort) and with national associations (NRMCA, etc.) before bringing a final BFRW draft forward.
Formal action: the committee voted to direct staff to consolidate the CLF and Northwest Concrete Masonry Association comment versions into a single BFRW proposal (version R4 combined) and to post that draft publicly for stakeholder review. The motion carried.
Next steps: staff will post the consolidated Word draft and the committee asked proponents and affected manufacturers to provide written suggested language. The committee also discussed coordinating legislative outreach and additional stakeholder sessions to ensure producers and fabricators can participate in developing implementable compliance pathways.
Ending note: proponents said they will continue to refine EPD values and definitions and to coordinate with Commerce’s Buy Clean work; opponents asked for clearer industry off-ramps, cost estimates, and additional time to assess implementation challenges.
