Council debates whether 80/90/100 thresholds will drive cuts or allow a reporting default
Members split on whether to keep 80, 90 and 100 percent options in the appendix table; some argued a 100% default plus table proxies would let jurisdictions meet the appendix without real reductions, while others favored 100% to ease initial adoption.
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Council members spent substantial time debating numeric thresholds that jurisdictions could adopt under the materials (product compliance) pathway. Several council members expressed concern that a 100% option, when combined with CLF table values used as proxies for absent EPDs, could be gamed to meet the appendix without achieving net reductions.
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