WBPA - SBCC Natural Gas Letter

September 16, 2021

Stoyan Bumbalov, Managing Director

WA State Building Code Council

1500 Jefferson St SE

Olympia, WA 98501


Via Email:            sbcc@des.wa.gov

CC:                        stoyan.bumbalov@des.wa.gov


RE: Please OPPOSE Proposals 21-GP1-103, 136, & 179


Members of the Washington State Building Codes Council:


On behalf of the Washington Business Properties Association (WBPA), and numerous commercial real estate companies throughout Washington, we share our strong OPPOSITION to the commercial energy code proposals 21-GP1-103, 21-GP1-136 and 21-GP1-179. The Washington State Building Code Council should not include proposals 103, 136, or 179 in their version of the State’s proposed Energy Code.


Proposal Costs and our Housing Shortage


Washington is facing a severe housing shortage, with a shortfall of more than 300,000 homes already. We need to create at least 10,000 new apartments each year just to keep up with demand. All costs must be factored into the financial analysis for building new housing. Three key SBCC proposals would increase costs for the development and management of housing. The proposals of greatest concern to Washington’s housing market are:


  • Proposal 21-GP1-103 will require electric heat pumps for space heat in all new commercial construction and retrofits, banning natural gas furnaces (and even gas heat pumps). These systems are expensive and will increase costs for new homes and increase the cost of rent for new apartments.


  • Proposal 21-GP1-136 ban natural gas water heating in new commercial construction and retrofits. This proposal will increase costs, especially for businesses that require large quantities of hot water such as commercial laundries, large multifamily, hotels and restaurants. This system would add both installation and operating costs of up to $2.43 per square foot.


  • Proposal 21-GP1-179, specific to multifamily housing construction, will require installation of an electric receptacle wherever a gas appliance is installed, adding significant cost with no efficiency or emissions reduction benefits. It will make multifamily housing more expensive.


These proposals will increase the costs to build new multifamily housing, leading to a decrease in supply in the short term, and even higher housing costs in the long term as these additional costs are absorbed.


Legal and Political Issues



There is NO legislative authority for either the TAG or the SBCC to ban gas use or to reduce greenhouse gas emissions. The charter of this group is to improve efficiency and drive down energy use. It is also highly concerning that the members of the Energy Code TAG did not broadly and actively seek to engage industry input.


Additionally, it appears that these groups have allowed politics to influence their technical decisions and legislative responsibilities. Further, they have ignored their clear lack of authority in order to push a favored political outcome even with a lack of consensus and have refused to acknowledge the expert technical testimony from the utility companies (the only subject-matter experts in the meetings). 


Please OPPOSE proposals 103, 136, and 179; they exceed the TAG and SBCC authority and should not be included in the final version of the State’s proposed Energy Code.


Thank you for your consideration.





Chet Baldwin


Washington Business Properties Association