State council posts commercial and residential energy code cost‑benefit analyses to CR‑102; opens July 1 public comment period

The Washington State Building Code Council voted June 26 to move the preliminary commercial and residential cost‑benefit analyses (CBAs) for the 2024 Washington Energy Code to CR‑102 for public notice and comment.

Staff and consultants described the commercial CBA format: a large set of proposals (67) listed in an appendix as having no economic impact, with roughly 25 proposals analyzed in the main body as having cost savings or neutral effects. Moore/McLeod provided deeper analysis for higher‑impact proposals and grouped measures by envelope, mechanical, lighting, whole‑building and existing‑building categories.

Why it matters: The CR‑102 filing starts the formal comment period under the Administrative Procedure Act. That window — July 1 through Aug. 7 — and the scheduled hearings (Aug. 5 in Olympia; Aug. 7 in Spokane) give stakeholders an opportunity to review assumptions and submit detailed, itemized comments that staff will later use to revise analyses or code language.

Krista, who presented the commercial analysis, summarized the structure and said she will fix minor indexing and labeling issues prior to publication. "The commercial cost benefit analysis is done in a slightly different format than the other ones... the majority of the proposals are located in appendix B where it says these are all the ones with no economic impact," she said. (Krista)

Staff described the filing schedule and the council’s intent to publish the preliminary CBAs by CR‑102 (preliminary filing) so public comments can be accepted beginning July 1. Staff plans two hearings, one in Olympia and one in Spokane, and will accept written comments through Aug. 7; after the comment period closes staff will assemble comments, prepare responses, and bring proposed revisions back for council deliberation and final adoption.

Stakeholders asked for clearer presentation of cost results and suggested convening an economic work group during the comment period to improve collaboration and technical review. Industry representatives — including Greg Johnson (Vista), Patrick Hanks (Building Industry Association of Washington), and concrete masonry interests — urged the council and consultants to ensure the analyses properly reflect multifamily and commercial project differences and to provide clarity on signs used in the tables (cost increases vs. savings).

The council moved the commercial CBA into CR‑102 and passed the motion by voice vote. It then moved the residential CBA (including updated Moore/McLeod inputs) into CR‑102; that motion also passed by voice vote.

Next steps: The CR‑102 filing will be published in the Washington State Register on July 22; public comments will be accepted beginning July 1 and will close Aug. 7. Staff plans to convene work sessions and, as needed, an economic work group to review substantive comments, then draft responses and any code amendments for later council consideration. Implementation of adopted changes is scheduled for May 3, 2027, following the legislative session.

(At the meeting: staff presented the commercial CBA and schedule; council moved commercial and residential CBAs to CR‑102 for public comment.)