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State building code council weighs optional embodied‑carbon appendix, debates authority and thresholds
Summary
At a July 7 SBCC work session, council members reviewed two options for an optional embodied‑carbon appendix after receiving 19 public comments (6 opposed, 13 supporting). Members debated statutory authority, compliance thresholds (50,000 vs. 100,000 sq ft), whether alterations should trigger requirements, and proposed drafting sponsor amendments and staff trackers.
The Washington State Building Code Council on July 7 discussed whether to recommend an optional embodied‑carbon appendix for the 2024 code cycle, focusing on two competing options and a set of public comments that split roughly two‑to‑one in support.
Dustin, SBCC staff, told the council the appendix petitions have generated 19 comments: six in opposition and 13 in support. He said supporters argued the appendix would align building codes with state climate goals, offer a consistent framework for jurisdictions that choose to adopt it, and that local architects are already performing many of the reporting tasks being proposed. Opponents, he said, raised concerns that the council lacks statutory authority to adopt embodied‑carbon requirements, that reporting and materials tracking would increase design costs and administrative burdens, and that supply‑chain constraints could raise housing costs.
"We received 19 specific comments on this proposal," Dustin said, summarizing the record and the principal points on both sides.
Why it matters: The appendix would be optional—jurisdictions could elect to adopt it—but council members noted that optional state frameworks still shape local policy decisions and market practice. The council discussed two main approaches: Option 1, which includes multiple compliance pathways (performance pathway, materials tracking, and building‑reuse pathways and an exemption for reuse in some cases); and Option 2, a slimmer approach that centers on a whole‑building life‑cycle analysis (WBLCA) and in staff’s description applies chiefly to new construction.
Members pressed two legal and practical questions. First, several speakers said public commenters argue SBCC lacks explicit statutory authority to adopt embodied‑carbon provisions. Dustin and others noted prior legislative direction to related work groups and an SBCC report directive in recent sessions but acknowledged the concern that no statute currently says "adopt embodied‑carbon provisions in the building code." The council asked legal counsel to analyze that issue and return with advice.
Second, the council spent extensive time on numeric thresholds and project scope. Angela said she prefers keeping a floor rather than leaving bracketed numbers blank: "I like the brackets. I like the minimum, maximum. I think it keeps overzealous jurisdictions from imposing this onto, say, small multifamily." Council members described a working range of 50,000 or 100,000 gross square feet for covered projects and debated whether alterations (not just new construction) should also trigger requirements. Roger observed that at 50,000 square feet a multifamily project could be roughly 40–50 units and would not be a small project; Vikram and others urged consistency and comparability across compliance pathways.
Council members proposed practical next steps rather than voting on policy today. Several members said they will draft council‑member amendments (for example, to reconcile wording differences between Option 1 and Option 2, to clarify whether alterations are covered, and to decide how bracketed thresholds are presented). Dustin agreed to add a column to the comment tracker that clarifies each commenter’s representation, to batch editorial fixes where possible, and to post the CR102/CR103 materials and spreadsheets so members can review proposed redlines side‑by‑side.
Legal counsel (Derek) and staff agreed to work on focused legal questions, including whether local amendments that would affect residential triggers require SBCC review, and to report back at a future meeting. The council did not take final action on any petition; members said they aim to develop written amendments and run them through the upcoming weekly work sessions ahead of the statutory posting deadlines in August.
Next steps: Staff will prepare trackers, post the proposed amendments and CR102 materials, and the council requested a legal memo on authority and on when local residential amendments would require council review.
