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Council members flag loophole in product‑compliance pathway, debate 70/80/90 versus 100% options

State Building Code Council · August 5, 2026
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Summary

Members warned that a 100% product‑compliance option could be gamed by using table baseline values when EPDs are absent; several members recommended limiting adoption options (70/80/90) and treating the 100% choice as a separate policy amendment.

Council members debated whether the product‑compliance pathway should include a 100% option that some said could be achieved without collecting Environmental Product Declarations (EPDs).

Roger Haringa warned of an easy shortcut: "If you do not have EPDs, you pull the value you are allowed to pull the values out of the table... and you're gonna come up with a 100% without doing anything." Several members agreed that allowing 100% risks making the pathway a reporting exercise rather than a tool for reducing embodied carbon.

The council discussed alternative thresholds — 70, 80 or 90 percent — to give adopting jurisdictions options that would not require returning to the state council for changes. "I suggested adding 70% ... there may be a city that wants to do 70 and makes it's a little bit more inclusive," Roger said to illustrate a more flexible menu for jurisdictions. Jay Arnold proposed separating the 100% policy question into a standalone amendment so the full council can debate the policy tradeoffs.

Members also discussed verification language intended to avoid requiring removal of installed materials when projects cannot meet a pathway; instead, a registered design professional could provide updated calculations and a narrative explaining why criteria were unmet. That verification provision was described as enabling a reporting‑first approach while avoiding punitive retrofits.