The Building Fire, Residential and WUI (BFRW) standing committee on April 11 tabled consideration of a proposed voluntary embodied‑carbon appendix (24GP118) and directed the committee to prepare a consolidated amendment for public review and public comment.

The committee’s action followed presentations from proponents and technical commenters who described three compliance pathways under the draft appendix and recommended edits to wording, thresholds and data sources. Ariel Brenner, New Buildings Institute, described the appendix as voluntary and said it provides three compliance paths: a product‑level pathway based on product and facility‑specific EPDs, a whole‑building LCA pathway with an absolute intensity cap (a draft cap of 500 kilograms CO2e per square meter was cited), and a building‑reuse pathway that would allow compliance when 45% of structure and envelope is retained. Brenner said the product pathway aggregates line‑item GWPs across the building and compares the project total against reference totals from the proposal’s product table.

Aurora Jensen, Carbon Leadership Forum, said CLF supports the general approach but recommended several clarifying edits. Jensen proposed eliminating industry‑average EPDs as an allowed path under the product compliance option, tightening product GWP reference values, clarifying that the metric is a sum across materials (not a simple average), and adding modeling guidance for salvage/reuse and for separate reporting of biogenic carbon. Jensen said CLF will publish benchmarking data soon that could inform the panel’s selection of an intensity cap and other thresholds.

Committee members and other commenters raised questions about several technical and policy matters: whether the whole‑building intensity cap should be an absolute number or relative to a modeled reference building; what baseline data or percentile (mean/median/percentile) to use when setting thresholds; how jurisdictions adopting the appendix locally would align the appendix to local ordinances and planning; and how to coordinate the appendix with other state processes (for example, procurement working groups). Todd Bayer (committee member) and others suggested the SE 2050/SE 2050 benchmarking datasets and CLF’s forthcoming benchmarking report as resources for a consistent methodology.

Industry commenters said compliance paperwork and tracking could create additional cost and staff time. Tim Atterbury, Associated General Contractors of Washington, recalled a local contractor’s difficult experience completing EPD work for a university project and urged caution about burdens that might reduce bidder participation on public projects. Corey Shaw, Washington Aggregate and Concrete Association, and other trade commenters encouraged coordination with the existing Buy Clean and procurement efforts and recommended assigning follow‑up economic‑impact analysis to the appropriate work group.

The BFRW committee voted to table the item and directed committee staff to publish the most current working draft, gather written comments, and return amendment language for public review at a future meeting. The committee asked staff and proponents to integrate technical edits and to coordinate economic‑impact and small‑business analyses as part of subsequent steps.

Why it matters: The appendix, if adopted by jurisdictions, would create a consistent statewide approach to reporting or limiting embodied carbon in buildings and could affect design, material procurement and public projects. The committee’s decision to consolidate proposals and to collect more evidence means the draft will get additional technical and economic review before any formal rulemaking or recommended code change to the State Building Code Council (SBCC).

What’s next: The committee directed staff to post the working draft and accept public comments, with the committee planning further consideration at a later meeting so it can return a consolidated amendment for public review.