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03.12.22 NWGA Letter to WA SBCC



March 12, 2022


Washington State Building Code Council


ATTN: Washington State Building Code Council Members (via email)

1500 Jefferson St SE

Olympia, WA 98501


RE: NWGA Comments Concerning Commercial Energy Code Proposals 103, 136 and 179


Members of the Washington State Building Code Council (SBCC):


The Northwest Gas Association represents the four natural gas distribution companies and two interstate transmission pipelines that serve warmth and comfort to 3.5 million residents and productive energy to 110,000 businesses, institutions and industries that employ hundreds of thousands of people in Washington State. Our members own and operate 45,000 miles of safe, reliable energy delivery infrastructure here.


NWGA members acknowledge the climate imperative and the need to act together to decarbonize. We embrace our role in helping the region achieve its decarbonization goals. Indeed, we maintain that the region cannot achieve its ambitious objectives without relying on the natural gas delivery system.


Within the constraints of existing policy and regulations, NWGA members are keenly focused on and investing in energy efficiency, innovation, fuel decarbonization and replacing dirtier fuels. Furthermore, policies recently passed by the Legislature will accelerate the process of decarbonization and should be allowed to work before piling on ill-considered and detrimental proposals without regard for the consequences of those proposals.


To date, the 2021 commercial energy code process has lacked sound reasoning and careful analysis. It has instead been biased in the consideration of and advocacy for commercial energy code proposals 103, 136 and 179. We strongly oppose these ill-considered code proposals and ask the SBCC to remove proposals 103, 136 and 179 from the package that goes to the CR103.


It has been wrongly suggested that there is no plan for how the gas system will meet the State’s greenhouse gas emission (GHG) reduction goals. On the contrary, the gas industry supported Washington’s historic Climate Commitment Act (CCA) in 2021, which prescribes a compliance pathway that must be met. Additionally, the integrated resource planning process conducted by gas utilities at the direction of the Utilities and Transportation Commission (UTC) describes how each investor-owned utility will acquire requisite resources to serve anticipated demand in compliance with existing laws and regulations.


These electrification code proposals lack the requisite data to warrant adoption. In fact, securing necessary data to inform future carbon policies is the very rationale for why we and other stakeholders negotiated in good faith, and agreed to the UTC Proviso for system research. Finally, these code proposals add nothing to the CCA in terms of achieving the State’s GHG reduction goals. The CCA mandates that GHG reductions occur in line with the State’s goals and provides a market-based mechanism to facilitate compliance.


These code proposals add costs to buildings while doing nothing to achieve GHG reductions beyond those already mandated by the CCA. In fact, this approach fails to promote innovation and creative thinking by prematurely determining which decarbonization pathways must be pursued. Washington is a geographically diverse state. What is good local government policy in Sprague is not necessarily good in Sequim.


Each of these proposals individually – and collectively – deprive the building sector of using market-based solutions to achieve carbon reduction. Instead, they mandate an approach that ignores feasibility and cost considerations. These measures threaten life-long, good paying careers. They will burden residents and building owners with higher costs and create duplicative regulatory requirements already addressed by existing economy-wide directives to reduce emissions on a trajectory based on the best climate science.


It is also clear that the SBCC can meet Washington’s 2030 commercial building energy goal of reducing energy use by 70 percent using off-the-shelf natural gas technologies. Research by the NW Energy Efficiency Alliance specifically on Washington State’s 2030 commercial energy code goals shows that the 70 percent energy use reduction goal can be met using existing natural gas technologies.


Additionally, in the commercial scenarios NEEA researched, gas technologies were comparable to electric technologies in energy reduction. This comprehensive research, by an unbiased and highly respected research organization dedicated to energy efficiency, was presented to the TAG and summarily ignored.


NWGA members are held accountable by the regulatory compact for understanding the impact of policies on their systems and particularly on the customers served by those systems. It is our informed perspective that these three code proposals will not achieve the state’s energy reduction goals. What they will do is create more pressure on an already fragile grid, increase building construction and O&M costs, require the installation of equipment that is not widely available and will not perform as needed in certain applications, and have no material effect on energy use or emissions reductions....






Thank you for your consideration,






DAN S. KIRSCHNER

Executive Director




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