The Building Code Council BFRW standing committee on June 27 heard more than two hours of public comment and committee debate on a proposed appendix addressing embodied carbon in building materials. After hearing proponents and opponents, the committee voted not to adopt the embodied‑carbon appendix as part of the code this cycle.

The debate focused on three compliance pathways in the petition (a whole‑building life‑cycle analysis, a product‑based prescriptive pathway, and a reuse pathway), the availability and comparability of product EPDs and PCRs, regional supply constraints (especially for low‑carbon cementitious materials), and the relationship between the appendix and state work mandated by recent legislation (the HB 1282 / "12 82" Commerce working group on EPDs).

Why it matters: the committee's decision affects whether jurisdictions can adopt an optional code appendix that would set embodied‑carbon metrics for new construction, potentially influencing material selection, supplier markets and contractor eligibility in Washington.

Public commenters and industry groups presented competing views. Amy Lewis of the New Buildings Institute, the proposal's proponent, urged the committee not to halt the appendix and said NBI was ready to incorporate technical suggestions. Ariel Brenner (New Buildings Institute) emphasized keeping three compliance options to preserve flexibility for project teams. A coalition of concrete, steel and precast producers cautioned that product availability, regional aggregate differences and constrained supplies of supplementary cementitious materials (SCMs such as slag and fly ash) could limit competition; CalPortland recommended jurisdictions require a market assessment before adopting strict limits. Max Puchel of the American Institute of Steel Construction recommended changes to fabricated/unfabricated steel lines and asked that wood products — including CLT — be included so materials are treated on an equal footing.

Representative Duerer, who sponsored recently enacted legislation referenced during discussion, told the committee that the Commerce working group established by the 2024 legislation cannot be expected to accomplish all implementation work and urged continued engagement with the legislature and workgroups while moving the technical discussion forward. Representative Duerer said local governments lack the resources to perform the market studies some commenters requested and suggested nonbinding approaches such as performance specs and whole‑building carbon budgets.

The committee considered motions and settled on one: Tom Handy moved that the committee not adopt the appendix (or any part of it) into the code this cycle; Angela Haupt seconded. The roll-call vote was recorded by staff: Dan Young (yes), Angela Haupt (yes), Tom Handy (yes), Todd Byreuther (no) and Chair Roger Haringa later registered his vote as no. The motion carried by a 3–2 vote. Roger Haringa asked that his opposing vote be entered into the record.

Discussion vs. decision: the committee's motion is a formal action to withhold adoption during this code cycle; the vote does not prohibit future work. Several committee members and external speakers asked for continued technical work and stakeholder engagement. Proponents — including New Buildings Institute and Carbon Leadership Forum supporters — said they wished to continue refining the drafted pathways, preserving flexibility (three pathways) and improving EPD data quality. Opponents asked for delay until the Commerce working group's EPD recommendations and the state's Buy Clean/Buy Fair policy work are further along; some urged requiring a local supplier market assessment before adoption.

Clarifying details captured during the meeting included the proposed whole‑building numeric threshold mentioned by a proponent (Todd Byreuther referenced a cap of about "500 kilograms per square meter" as a comparison point used in the proposal discussion), the three-pathway structure (whole-building LCA, product compliance, reuse), and specific market‑availability concerns (limited slag cement and diminishing fly ash supplies) raised by CalPortland and other producers.

Ending: The committee voted not to adopt the embodied‑carbon appendix this cycle. Members and attendees said they would continue technical work in the interim; proponents asked that the draft remain open for public comment and further stakeholder input. The item will be documented in committee minutes and transmitted with the committee's recommendation to the full Building Code Council for its consideration in the council's agenda cycle.