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Washington SBCC Commercial Form Letter

Copy and paste the following into an email and send to the Washington State Building Code Council (SBCC) at [email protected]:

Subject Line:

Washington State Proposed Building Codes 21-GP1-103 & 21-GP1-136


Dear Members of the Washington State Building Code Council,

I am writing to express my opposition to the following proposed code changes for the state energy code:

  • 21-GP1-136 – Bans the use of natural gas for commercial water heating uses and requires the use of electric heat pumps for water heating purposes.
  • 21-GP1-103- Requires electric heat pumps for all new commercial construction and retrofits and bans the use of natural gas for commercial space heating (HVACs).

As a business that relies on the use of natural gas, I am concerned these proposals will raise the cost of operating in Washington, while impacting my ability to make energy decisions that best suit my and my customer’s needs.

I am further confused why this ban is being proposed when viable alternatives to a natural gas ban have already been enacted in WA State. The Clean Buildings Act of 2019 codifies natural gas energy efficiency targets and mandates biennial conservation planning (BCP). SB 5126, the Washington Climate Commitment Act puts a cap-and-trade program into effect in Jan 2023. With such laws now in place, it’s unclear why the elimination of the gas industry is being considered before these laws even have a chance to take effect.

A heat pump is an expensive and insufficient alternative for my needs, which the code recognizes, by allowing backup resistance heaters in certain areas of the state.  This requires me to pay for two separate heating solutions for my building at additional costs, and disallows high-performance natural gas back up heat which is more efficient and affordable than electric resistance heating.

Natural gas from buildings is responsible for less than 10% of the amount of the state’s emissions. We didn’t ban the electric transmission system or electric equipment just because non-renewable fuels can be used to generate electricity. Nor should we ban the gas system and gas equipment for the same reason. Wind and solar have become more affordable over time, and so too will renewable natural gas and hydrogen.

It’s for these reasons that I urge a no vote on these two proposals. They will do little to advance the state’s climate goals and will harm businesses such as my own.

Thank you for your consideration.