Stakeholders urge SBCC to reissue CR102 after errors and evolving proposals

Multiple participants told the State Building Code Council that the CR102 packet posted for this rulemaking was incomplete or changed after notice, preventing meaningful public review.

"When the rule keeps changing after notice, the opportunity becomes an illusion," said Steven Bosarch, a labor organizer who testified in Spokane. Several speakers pointed to specific discrepancies: Lisa Rosno, who performs crosswalks between adopted and proposed code, said CR102 contained errors and unreliable strike/underline signals that make it difficult to determine what the TAG actually changed.

Witnesses repeatedly cited statutory notice and comment obligations. Elizabeth Torske (Cascade Natural Gas) and others noted that credit values for some compliance tables were not published, undermining the ability to assess compliance cost and impacts. Kelly Fukai (Northwest Gas Association) asked the council to withdraw CR102, allow the technical working group to finish its work, and publish a complete proposal for a new comment period. Several speakers framed this as a procedural fairness issue under RCW and the Administrative Procedure Act.

Council staff and the chair recorded the comments into the rulemaking docket. The council left the record open for written comments and set its adoption meeting for Sept. 25, 2026.