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Stakeholders urge SBCC to fix errors and reissue complete CR102 before adoption
Summary
Multiple commenters — unions, contractors, consultants and jurisdiction staff — warned the council that the CR102/CR103 package includes errors, omitted credit values and sections still under technical work; several urged the council to finish the working-group work, publish corrected text and allow a new comment period.
Labor leaders, code consultants and local government staff told the council that the CR102 package is incomplete in places and that substantive changes continued to be made after the notice was filed, undermining the public’s ability to comment meaningfully.
Mallory Davies (Washington and Northern Idaho District Council of Laborers) and other labor organizers urged the council not to "adopt a package that is still being written while the public is commenting on it," citing downstream costs and notice problems under the Administrative Procedures Act. Lisa Rosenau (Evergreen Technology Consulting) and Mike Kennedy (contractor to Northwest Energy Efficiency Alliance) identified errors, omissions, and inconsistent tables (notably blank credit values in C406 and the residential U-value discrepancy), and recommended reissuing corrected documents so the public and jurisdictions can review a stable text.
Several speakers asked the council to delay adoption until technical working-group edits are completed and the commercial credits package is fully documented. The council acknowledged the comments; no rule adoption occurred at the hearing and written comments will be part of the official record.
