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State agencies and building advocates back optional embodied‑carbon appendix for 2024 IBC
Summary
State and regional officials, architects and nonprofit groups urged the State Building Code Council to adopt a voluntary embodied‑carbon appendix (Options 1 or 2) to the 2024 International Building Code to help jurisdictions measure and reduce materials‑related emissions in larger projects.
State officials, industry groups and sustainability advocates urged the Washington State Building Code Council during its June 10 public hearing to adopt an optional embodied‑carbon appendix to the 2024 International Building Code.
Hannah Waterstratt, director of the State Efficiency and Environmental Performance Office at the Washington Department of Commerce, told the council the agency supports IBC amendments (24GP118R4 and related) that would give local jurisdictions optional pathways to require reporting on embodied carbon for projects above either 50,000 or 100,000 square feet. "Of the two proposed amendments, we prefer the option with three embodied carbon reduction pathways," she said, arguing it offers jurisdictions and builders greater flexibility.
Advocates from the nonprofit Carbon Leadership Forum and the New Buildings Institute echoed that support. Meghan Lewis, program director at the Carbon Leadership Forum and a registered architect, said CLF research shows materials account for more than a third of building emissions in Washington. "Now is the time for Washington to begin testing voluntary options for how the code can address embodied carbon," Lewis said. Arielle Brenner of the New Buildings Institute, the proponent behind the original appendix proposal, told the council Appendix S is voluntary, complements the state's Buy Clean and Buy Fair policy, and would provide consistency for market‑facing reporting.
Supporters emphasized the appendix is optional and contains waiver provisions to reduce implementation burdens where projects cannot meet requirements. Meghan Lewis noted each compliance pathway includes a built‑in waiver "allowing a training‑wheels approach to embodied carbon in code that supports measurement and reduction strategies instead of a compliance burden."
King County's embodied carbon program manager, Gemma Holt, asked the council to adopt the appendix and signaled a preference for a whole‑building lifecycle assessment compliance pathway, which she said would align with industry practice and simplify implementation for jurisdictions and project teams.
Proponents framed adoption as a way to scale local Buy Clean and Buy Fair policies and improve statewide transparency without mandating a single approach. The Department of Commerce said the approach would be complementary to existing state policies and support jurisdictions that choose to adopt the appendix.
The council did not vote at the hearing; the record for the proposed rules remains open and a final decision is scheduled for Aug. 28, 2026.
