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Building Code Council advances David Reddy package for energy-credit targets after hour-long debate
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Summary
After extended debate and public comment about costs, climate-zone equity and federal preemption risks, the Washington State Building Code Council voted to advance David Reddy’s C406 v3 credit-target proposal into the CR-102 public-review stage. A competing set of targets from Greg Johnson failed in a roll-call vote.
Council members spent the largest portion of the April 24 special meeting debating which set of energy-credit targets to advance for the C406 commercial-energy credit tables. The council heard technical presentations from Pacific Northwest National Laboratory contributors and from two competing proponents — Greg Johnson and David Reddy — before holding successive roll-call votes.
Krista and staff explained PNNL’s modeling of credit values and urged the council to include modeled credit numbers in the CR-102 filing so the public could comment on concrete values rather than placeholders. Greg Johnson, who helped coordinate the PNNL work, said the lab “did it with the highest level of integrity” and that the modeled values reflect system and climate-zone differences across the state. Kjell Anderson, who led the technical advisory work group, described how the tables convert specific measures to percent-reduction “points” and noted interactive effects between envelope improvements and equipment credits.
Two distinct options for the C406.1 targets were presented. Greg Johnson’s approach aimed to balance aggregate statewide savings between West-side (climate zone 4C) and East-side (5B) building stocks; he said that produced a different distribution of required credits by occupancy. David Reddy’s v3 proposal used a different methodology that would yield higher credit requirements in some East-side categories but, proponents argued, was more consistent across occupancies and easier to explain to the public.
Public commenters — representing trade groups, utilities, solar advocates, contractors and housing advocates — urged varying approaches. Builders and contractor representatives warned of higher construction costs and potential impacts on housing affordability if targets were set too high. Energy and climate advocates urged more stringent targets to keep the state on the statutory glide path toward the 2031 energy reduction goals.
Council members discussed federal preemption under the Energy Policy and Conservation Act (EPCA). Derek Marbach, assistant attorney general, cautioned the body that EPCA-related legal questions are complex and that concerns could be raised during the public comment period or in litigation, but that the council should seek public input on potential legal risks.
The council first moved to adopt Greg Johnson’s target set; that motion failed on a roll-call vote. The council then voted to advance David Reddy’s v3 package for CR-102 public review (roll call resulted in the motion passing 6–3). Chair closed debate by noting the decision sends Reddy’s option into the formal rulemaking record for public comment and analysis.
What’s next: The C406.1 and related C406.2 values will be published in the CR-102 proposed rule materials, where industry, utilities, local governments and members of the public can submit formal comment. Staff said a May 1 internal deadline was set for final edits to materials before the filing deadline.
