SBCC reviews new cost‑benefit format for 2024 UPC, flags need for third‑party economic vetting

The Building Code Council on Feb. 13 reviewed a newly formatted preliminary cost‑benefit analysis (CBA) for the 2024 Uniform Plumbing Code and related code packages. Dustin (staff) said the new report adds a table of contents, a small‑business engagement statement, and per‑proposal summaries including rationale, estimated net economic impacts and NAICS mappings.

Brandon, who walked the committee through the document, said the format shows key findings, cumulative economic analyses and a per‑proposal section with description, rationale and estimated impacts. Dustin told the committee staff used proponent data supplemented with available resources but acknowledged limits: "we are heavily reliant on the proponents, submitting code change proposals to also submit accurate economic data," he said, and recommended third‑party evaluation where budgets allow.

Committee members praised the format but pressed on methodology. Patrick Hanks of the Building Industry Association called the draft “light years better” and suggested clearer wording (avoid the term “global” for a report‑level statement), adding that the Regulatory Fairness Act requires a cost‑per‑employee, cost‑per‑hour, or cost‑per‑$100‑sales metric and asked for a revenue/sales estimate or explanation when such data are unavailable. Scott questioned whether some life‑cycle benefit claims understate near‑term design and construction costs, saying the presentation “doesn't seem real” if initial costs are nearly negligible compared with lifecycle savings.

Dustin said staff have budgeted third‑party support for the energy code work (PNNL) and would like to expand contracted analysis to other codes when feasible; he described the current approach as overburdensome for staff. Committee members suggested efficiency improvements for 2027, such as prioritizing proposals with the largest estimated impacts for third‑party review and adding clearer appendices showing how the analysis complies with RCW requirements.

The committee also used the agenda to review technical advisory group (TAG) composition for the MVP (mechanical, ventilation and plumbing) tag, noting vacancies and confirming that Sidharth Prim Kumar had been appointed an alternate at the Dec. 5 executive committee meeting; staff asked whether applicant Teresa (attendee) could be placed in another available tag seat. Staff noted that tags are composed of technical experts and that any code proposal must receive TAG approval before moving forward.

Dustin said staff hope to post a near‑final version of the CBA for council review next week; full contracted energy‑code analysis remains on a March–April timeline. Members asked staff to (1) add clearer labeling (e.g., a column indicating net impact category), (2) show which proposals trigger specific statutory appendices (e.g., RCW 34.05.328 and the Regulatory Fairness Act), and (3) pursue third‑party vetting options for higher‑impact proposals.