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Debate over embodied carbon proposals pits architects and climate advocates against construction industry groups
Summary
Architects and building scientists urged optional embodied‑carbon pathways in the building code to advance low‑carbon procurement; industry groups, including concrete and aggregate interests, argued the SBCC lacks statutory authority and warned of enforcement burdens, seeking legislative or industry-driven approaches.
Several witnesses at the June 12 SBCC hearing addressed proposed embodied-carbon measures (including Proposal 24GP1-118R4 and Appendix S options). Supporters said the three-pathway approach (product compliance using EPDs, whole-building lifecycle assessment, and building reuse) is feasible for many public project types and would drive market transformation. "The product compliance pathway uses EPDs against published CLF baselines. No LCA software is acquired. This is achievable on day one for a school district or a public housing authority," said Jesse Walton, a Seattle architect with Mahlum.
Chad Anderson, an architect at LMN (and former Building Code Council member), recommended optional adoption and emphasized that the pathway would be voluntary at the jurisdictional level: "These proposals would be optional. Only jurisdictions that choose to adopt them would be in force in places where jurisdictions chose to adopt them," he said.
Industry opposition centered on the SBCC's statutory scope and administrative practicality. Cory Shaw of the Washington Aggregate and Concrete Association asked the Council to table or reject the embodied-carbon proposals and argued "embodied carbon reduction is not a health and safety line, according to RCW1927020," raising the question of whether the Council has authority to adopt such provisions as statewide code. Shaw also warned of compliance burdens and urged an industry-driven or legislative path instead.
The Council did not act at the hearing. Staff noted written comments will be posted and will inform workshop deliberations.
Ending: The Council plans workshops to review written testimony and will consider the embodied-carbon proposals during its rulemaking cycle before the August 28, 2026 adoption date.
