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State building code council opens four-week comment period on 'site vs. source' energy debate, directs tags to use site energy pending decision

February 22, 2025 | Building Code Council, Governor's Office - Boards & Commissions, Executive, Washington


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State building code council opens four-week comment period on 'site vs. source' energy debate, directs tags to use site energy pending decision
The Washington State Building Code Council on Feb. 21 opened a four‑week written comment period and scheduled a March 21 public hearing on a petition that asks the council to change how the code measures energy use — commonly framed as a choice between "site" and "source" energy.

The council voted to begin the public comment window for the two options, with written testimony due before the hearing and time‑limited oral comments allowed at the March meeting. The council also directed the code tags to continue using site energy as the measurement basis until the council makes a final decision and asked the council’s attorney to advise whether using source energy would raise legal risks under the federal Energy Policy and Conservation Act (EPCA).

Why it matters: the choice between site and source energy affects whether the code favors electrification measures such as heat pumps or equipment that burns fuels on‑site. Proponents say source or carbon‑aware metrics better reflect greenhouse gas impacts; opponents say site metrics better align with federal EPCA limits on state appliance regulation and are easier for code administrators.

Proponent: Greg Johnson, who identified himself as affiliated with Avista and as the petition’s proponent, framed the issue for the council and urged members to research both approaches. "I'm not going to be advocating for one choice or the other," Johnson said during his presentation, adding the proposal was written to be unbiased so the council could deliberate later.

Tag chair: Council member Kjell Anderson, commercial energy code tag chair, summarized the technical distinction: site energy counts energy delivered and used at a building; source energy accounts for generation and delivery losses across the grid. Anderson noted federal guidance and past legal decisions factor into the council’s options and said the topic affects both residential and commercial performance pathways.

Public comment: more than a dozen stakeholders spoke during the meeting’s public‑comment period. Supporters of a deliberative approach included Tony Uzavelli (retired state energy official), Deepa Sivarajan of Climate Solutions and Arvia Morris of the Climate Rail Alliance, who said energy efficiency and electrification are important for public health and resilience. Building industry and utility commenters urged clarity. Patrick Hanks of the Building Industry Association of Washington asked staff to confirm the special submittal window for 2021 petitions runs Feb. 10–April 7; staff confirmed the window is open for 2021 residential and commercial petitions related to the item.

Next steps: the council’s motion (as amended) opens the four‑week written comment period, prefers that written material be submitted in advance of the hearing so council members can review it, and schedules the hearing for the council’s March 21 meeting. The council asked the attorney general’s office to provide an opinion on whether adopting a source‑energy metric would place the council at legal risk under EPCA before the March hearing.

Council members and stakeholders said they expect substantial technical testimony and urged that written submissions be posted promptly so members and the public can review them before March.

Ending: The council’s action does not change the code immediately; it establishes a public process and a timeline for the broader technical and legal debate over how Washington measures building energy in upcoming code work.

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Scribe from Workplace AI
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