Sign AWB's letter rejecting State Building Code Council capping emissions on manufacturing of steel and concrete
Stoyan Bumbalov          
Managing Director
Washington State Building Code Council
1500 Jefferson St. SE
P.O. Box 41449
Olympia, WA 98504

Todd Beyreuther
Technical Advisory Group, Washington State Building Code Council
PO Box 41449
Olympia, WA 98504

Dear Mr. Bumbalov and Mr. Beyreuther,

We are strongly concerned with the proposal currently before the International Building Code (IBC) and International Existing Building Code (IEBC) Technical Advisory Group (TAG) Members of the State Building Code Council (SBCC), regarding greenhouse gas emissions on the manufacturing of concrete and steel.

The Association of Washington Business (AWB) is Washington’s oldest and largest statewide business association, with nearly 7,000-member companies, including many who will be directly impacted by this proposal. AWB serves as both the state’s chamber of commerce and the manufacturing and technology association.  

Setting aside the question of whether the SBCC has the authority to impose such a policy, (we believe it does not), we want to highlight the potential impacts of capping emissions on the manufacturing of concrete and steel.  

The proposal will drive up the price for all commercial, residential, and public works construction projects across the state. This would be at a time when Washington employers are already facing record growth in inflation, fuel prices, and other volatile supply chain constraints.

The “pass through” cost implication made by proponents is false. There will be significant implementation costs, as well as material, price, and other market adjustments that will impact the concrete and steel industries across the state and likely passed on to each project.

Discriminating against steel and concrete will also create competitive advantages for alternative materials, thus leaving the SBCC in the position of providing preferential treatment to certain construction products.

There is also a range of uncertainty on how the proposal would affect the performance of steel and concrete in various construction uses including its fresh and hardening properties, early and long-term strength gain, durability, mix feasibility, life cycle maintenance, set times that affect project scheduling, compatibility with other materials, etc.

In recent years, the Washington State Legislature has considered but rejected similar proposals like Buy Clean and other prescriptive procurement alternatives to reduce greenhouse gas emissions in building materials. In 2021, legislators instead created a work group to study these strategies. That group has been meeting and is required to provide a report and recommendations to the legislature by June 30, 2022.

We recognize that the SBCC performs important work with creating safe, fair, and standard building practices, but this proposal goes too far, with too many uncertainties, and exceeds the Council’s authority. It also ignores the work of the legislature and input from impacted stakeholders. We urge the SBCC to consider these ramifications and reject the proposal.

Sincerely,
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